NCS000542_Henderson Draft SWMP v3_20211018

Draft Stormwater Management Plan
City of Henderson
NCS000542

April 13, 2021

This page intentionally left blank

Table of Contents

PART 1: INTRODUCTION ........................................................................................................................ 1

PART 2: CERTIFICATION ........................................................................................................................ 2

PART 3: MS4 INFORMATION .................................................................................................................. 3
3.1 Permitted MS4 Area ..................................................................................................................... 3
3.2 Existing MS4 Mapping ................................................................................................................. 4
3.3 Receiving Waters .......................................................................................................................... 6
3.4 MS4 Interconnection ..................................................................................................................... 7
3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 7
3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 9
3.7 Industrial Facility Discharges ....................................................................................................... 9
3.8 Non-Stormwater Discharges ......................................................................................................... 9
3.9 Target Pollutants and Sources ..................................................................................................... 11

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 13
4.1 Organizational Structure ............................................................................................................. 13
4.2 Program Funding and Budget ..................................................................................................... 15
4.3 Shared Responsibility ................................................................................................................. 16
4.4 Co-Permittees .............................................................................................................................. 17
4.5 Measurable Goals for Program Administration .......................................................................... 17

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 19

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 24

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 26

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 30

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 33

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 38

List of Tables

Table 1: Summary of MS4 Mapping
Table 2A: Summary MS4 Receiving Waters – Roanoke River Basin
Table 2B: Summary MS4 Receiving Waters – Tar-Pamlico River Basin
Table 3: Summary of Approved TMDLs
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table 5: NPDES Stormwater Permitted Industrial Facilities
Table 6: Non-Stormwater Discharges
Table 7: Summary of Target Pollutants and Sources
Table 8: Summary of Responsible Parties
Table 9: Shared Responsibilities
Table 10: Co-Permittee Contact Information
Table 11: Program Administration BMPs
Table 12: Summary of Target Pollutants & Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BMPs
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program
Table 19: Summary of Existing Post-Construction Program Elements
Table 20: Post Construction Site Runoff Control BMPs
Table 21: Pollution Prevention and Good Housekeeping BMPs

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 1

PART 1: INTRODUCTION

The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which
the City of Henderson will comply with its National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water
Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent
practicable.

This SWMP identifies the specific elements and minimum measures that the City of Henderson will
develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental
Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with
the MS4 Permit number NCS000542, as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the City of Henderson and located
within the corporate limits of the City of Henderson.

In preparing this SWMP, the City of Henderson has evaluated its MS4 and the permit requirements to
develop a comprehensive 5-year SWMP that will meet the community’s needs, address local water
quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will
be evaluated and updated annually to ensure that the elements and minimum measures it contains
continue to adequately provide for permit compliance and the community’s needs.

Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along
with any approved modifications of the SWMP, are incorporated by reference into the permit and become
enforceable parts of the permit. Any major changes to the approved SWMP will require resubmittal,
review, and approval by NCDEQ, any may require a new public comment period depending on the nature
of the changes.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 2

PART 2: CERTIFICATION

By my signature below I hereby certify, under penalty of law, that this document and all attachments were
prepared under my direction or supervision in accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete.

I am aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations.

I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4
Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit
compliance and enforcement authority.

☐ I am a ranking elected official.
☒ I am a principal executive officer for the permitted MS4.
☐ I am a duly authorized representative for the permitted MS4 and have attached the authorization made
in writing by a principal executive officer or ranking elected official which specifies me as (check one):
☐ A specific individual having overall responsibility for stormwater matters.
☐ A specific position having overall responsibility for stormwater matters.

Signature:

Edward Terrell Blackmon

Print
Name:
Edward Terrell Blackmon
Title: City Manager

Signed this __21st__ day of April 2021____ .

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 3

PART 3: MS4 INFORMATION

3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the City of Henderson, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of City of Henderson as of the date of this document. Please note that the corporate city limits are
defined per ordinance but sometimes the city limit line splits parcel lines, these splits occur due to plat
subdivision or recombination. The extra-territorial jurisdiction (ETJ), depicted in green, is an arbitrary
boundary defined as 1 mile from the city limits line, and this boundary has been plagued with split
parcels. However, City of Henderson staff have worked hard to reduce the number of splits to provide
consistent protections for county residents, while trying to limit the negative impacts of city regulations
where a small split may create a burden.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 4

3.2 Existing MS4 Mapping
The City of Henderson’s Engineering Department is in the process of updating the current MS4 map,
which will include the location of stormwater inlets, pipes, junction boxes, stormwater control measures
(SCMs) and Outfalls. Henderson’s mapping to date has not included ditches from an asset inventory
standpoint but, they are delineated on our base maps by knowing how to interpret contour lines. As the
city of Henderson’s MS4 program matures we will map the streams and ditches to include the condition
(physical and water quality) and morphology.

The City of Raleigh’s stormwater department supported the City of Henderson stormwater system
mapping effort by sharing their knowledge, experiences and nomenclature. While this collaboration was
fantastic in getting our mapping program up and going, it was overwhelming due to the limited staff we
had and the extent of work Raleigh had put into their system. Therefore, the City of Henderson had to
limit the scope of what Raleigh has done but with the intent of collecting the majority of the pertinent
data. The City of Henderson hired 2 part-time interns over the last two years to collect the data Our
interns were trained to use GPS equipment (Arrow Gold) and ESRI Collector on an Apple iPad. Initially,
the data collected was labor-intensive due to the amount of post processing and the re-training that was
required due to the GIS technician attrition. The current GIS Technician was able to develop a script to
batch process the points and significantly reduce the amount of post processing, eventually in late 2019
the GPS software was improved and the point data was processed/corrected during collection. The GPS
equipment on the market today is attainable at a price point and the accuracy has significantly improved
so that most of our data has a 1-cm accuracy.

The City of Henderson’s Engineering department has collected the stormwater data in GIS and then
pushed this data over to an asset inventory system (Cartegraph) so our Public Works (PW) Department
can perform work against these assets. The PW crews are currently working with the Engineering
Department to correct the stormwater maps. During the collection of data, the GIS interns were instructed
NOT to remove inlet covers or physically enter these structures due to safety issues and confined space
concerns. These restraints on the data collection hampered the intern’s ability to determine pipe size,
invert depth, condition assessment and flow direction. While the stormwater system map is approximately
90% mapped there are inaccuracies in the data which are being improved on an on-going basis. One of
the more difficult legal issues to address with respect to mapping is distinguishing where private and
public system start and stop (i.e. a strip mall may build and attach to Henderson’s public collection
system route the upstream flow through their private collection system then discharge back into a public
collection system). This brings up questions of construction standards, beneficial use, maintenance and
operations and future improvements.

Please note that the City of Henderson does not have a public facing map to any of our systems (water,
sewer, roads and stormwater). The City of Henderson does not want developers making engineering
decisions based on a map that may contain errors. We require all developers to contact engineering about
their plans then the City of Henderson reviews these plans and ground truths to verify if the system can
accommodate the additional capacity.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 5

City of Henderson – Storm Water Map (Redline is the City Limits)

Table 1: Summary of Current MS4 Mapping
Percent of MS4 Area Mapped 90 %
No. of Major Outfalls* Mapped Unknown** total

*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly
into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major
outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned
areas a 12-inch diameter pipe or a drainage area > 2-acres.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 6

** Receiving streams and their tributaries have been identified as well as the sub-basins. The City of
Henderson needs to evaluate the drainage basin with respect to NCDEQ guidance to identify and classify
the outfalls. In many cases, a stream may receive multiple discharges within a short reach and if this
meets the acreage requirement then the City of Henderson has noted this as an Outfall.

3.3 Receiving Waters
The City of Henderson MS4 is located within the Tar-Pamilco and Roanoke River Basins and discharges
directly into receiving waters as listed in Table 2A and 2B below. Applicable water quality standards
listed below are compiled from the following NCDEQ sources:

o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d) List

Table 2A: Summary MS4 Receiving Waters – Roanoke River Basin
Receiving Water
Name Stream Segment Stream Index /
AU Number
Water Quality
Classification
303(d) Listed
Parameter(s)
Nutbush Creek From source to Crooked Run

23-8-(1) C
Benthos (Nar,
AL, FW)
Fish Community
(Nar, AL, FW)
UT to Crooked Run From source to Crooked Run 23-8-3 B N/A
Crooked Run
From source to Nutbush
Creek Arm of John B. Kerr
Reservoir

23-8-3 B
N/A
Indian Creek
From source to Carolina
Power & Light Company
Power Line
23-8-4-(1)
C
N/A

Table 2B: Summary MS4 Receiving Waters – Tar-Pamlico River Basin
Receiving Stream
Name Stream Segment Index AU
Number
Water Quality
Classification
303(d) Listed
Parameter
Ruin Creek From dam to Tabbs Creek 28-17-2-(2) C; NSW N/A
Red Bud Creek From source to Ruin Creek 28-17-2-3 C: NSW N/A
UT to Ruin Creek From source to Ruin Creek 28-17-2-(2) C: NSW N/A

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 7

Joes Branch From source to Ruin Creek 28-17-2-4 C; NSW N/A
Sandy Creek
From source to dam at
Southerlands Pond

28-78-1-(1)
C; NSW; +
N/A
Martin Creek From source to Sandy Creek 28-78-1-3 C; NSW; + N/A

3.4 MS4 Interconnection
The City of Henderson MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Tables 2A and 2B above.

The MS4 does not interconnect with the statewide NCDOT MS4.

3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map
and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates
whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed
directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program
has been implemented to address the WLA.

Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant(s) of Concern Stormwater
Waste
Load
Allocation
(Y/N)
Water
Quality
Recovery
Program
(Y/N)
Tar River
Total Nitrogen (1.361_e6 Kg/Yr) N N
Total Phosphorus (0.18_e6
Kg/Yr) N N

The City of Henderson recognizes that the Environmental Protection Agency in conjunction with the
North Carolina Department of Environmental Quality has done tremendous work with respect to hypoxia
problems in the lower water column of Pamlico Estuary as well as a thorough review of the factors
leading to this oxygen depletion. The promulgation of the Nutrient Sensitive Waters and the associated
Best Management Practices (BMPs) now known as Stormwater Control Measures (SCMs) have made
positive strides towards reducing the negative impacts of development on downstream water bodies. But
even with these positive steps forward there is so much more that can be done and NCDEQ has
recognized and identified 6 measures to improve stormwater quality which includes; education, citizen
participation, illicit discharge enforcement, construction runoff, post construction runoff and pollution
prevention and good house-keeping at municipal operations.
EPA/DEQ’s report identified Total Nitrogen (TN) and Total Phosphorus (TP) as primary constituents of
interest to reduce the oxygen depletion. The NSW regulations have placed discharge limits from SCMs

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 8

on both these constituents as well as providing the efficiencies of removal for these constituents by the
SCMs. Currently the TN discharge limit is set at 4.0 lbs/acre/year and TP is set at 0.4 lbs/acre/year from
a new development site and a 30% reduction in TN from existing sites. Henderson’s City Engineer
reviews all plans and calculations for compliance to the NSW regulations. New developments and their
associated SCMs work closely with the City and Morgensen Mitigation Bank so the developer can
purchase nutrient credits and come into compliance with the tools provided by NCDEQ.

Henderson’s City Council has received the stormwater Notice of Violation in June 2020 and adopted a
Resolution (No. 20-50) in August 2020 to not only implement the measure outlined in NCDEQ’s MS4
Stormwater Program but also to fund the implementation of this program. Engineering Staff has worked
tirelessly to map all the impervious surfaces in the City with the exception of single-family dwellings.
Staff presented a recommendation to council to hire a consultant to assist us in the development and
implementation of a stormwater utility. Council awarded the Stormwater Utility setup to Dewberry
Engineers and they have developed the documents necessary to implement a stormwater utility. As of the
writing of this report, council action has not moved forward with respect to a Stormwater Utility but, the
new City Manager has slated this important funding stream on his agenda matrix. Stormwater quality and
MS4 compliance for the City of Henderson requires funding of two full time positions, collaboration with
Public Works and the hiring of part-time staff to assist in field data collection and reconciliation by GIS
staff.

Henderson’s Engineering Staff includes an engineering inspector that is certified for BMP construction
and maintenance and this individual has mapped and commented on the condition of existing SCMs
(BMPs) within the City Limits. The engineering inspector is also involved in the inspection and
construction of sedimentation and erosion control measure for which he generates weekly reports during
construction as well as the conversion of sedimentation devices to SCMs once the ground is stabilized.
The engineering inspector and city engineer talk throughout the project to make sure everything is
working smoothly so, by the time the final inspection takes place the revisions are very small. At the final
walk through the contractor, engineer of record, city engineer and engineering inspector draw up a final
punch list to get the site and all its components into compliance. This is a critical step in how the SCM
will perform and any additional modifications prior to the final approval.

Funding is a critical component in Henderson’s stormwater program because it not only allows us to hire
staff but provides training, tools, money for capital improvement projects, hiring consultants with the
expertise to help Henderson develop and hone specific aspects of the program.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 9

3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are not identified
within the regulated MS4 urbanized area. Based upon a review of the Endangered and Threatened Species
and Species of Concern by County for North Carolina Map and Listed species believe to or known to
occur in North Carolina map as provided by the U.S. Fish and Wildlife Service, the species listed in Table
4 have the potential to occur within the regulated MS4 urbanized area. Of those species listed, Table 4
summarizes the species that may be significantly impacted by the quality of surface waters within their
habitat.

Table 4: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing
Status
Haliaeetus
leucocephalus
Bald Eagle Vertebrate BGPA
Noturus furiosus Carolina Madtom Vertebrate ARS
Necturus lewisi Neuse River
Waterdog
Vertebrate ARS
Fusconaia masoni Alantic Pigtoe Invertebrate ARS
Alasmidonta
heterodon
Dwarf Wedgemussel Invertebrate E
Parvaspina
steinstansana
Tar River
spinymussel
Invertebrate E
Elliptio lanceolata Yellow Lance Invertebrate T

3.7 Industrial Facility Discharges
The City of Henderson MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEQ Maps & Permit Data web page.

Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCGNE0460 Timberline Acquisition, LLC
NCG050393 Vescom
NCG210331 Idaho Timber of North Carolina LLC
NCG080713 Henderson Operations & Service Center

3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Henderson as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The City of Henderson has evaluated residential car washing for
possible significant water quality impacts.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 10

Street washing discharges are addressed under the Pavement Management Program in Part 10 of this
SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the
City of Henderson. The City performs street sweeping on curb and gutter streets; however, no street
washing is conducted. A small amount of water is used in the street sweeping activity on the order of 150
gallons per mile or 0.027 gallons/foot. The vast majority of the water used in the street sweeping
operation is bound to the refuse and vacuumed up into the dump bed on the sweeper truck. Approximately
1,000 pounds of refuse is collected per mile and discharged at the landfill.

Wash water associated with car washing that does not contain detergents or does not discharge directly
into the MS4 is considered incidental. However, these types of non-stormwater discharges that do
contain detergents have been evaluated by the City of Henderson to determine whether they may
significantly impact water quality. The City has an unusually high number of commercial car washes
compared to the population for most municipalities therefore, it is unusual to see residential car washing
occurring and rarely does it spill into the street or stormwater system. The discharges directly from
residential home and car washing into the MS4 is considered a possible source of impact to water quality.
The City of Henderson shall make a concerted effort via public education about the use of detergents and
cleaners used in the washing of cars and homes as well as their possible water quality impacts.

Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge Water Quality Impacts
Water line and fire hydrant flushing Incidental
Landscape irrigation Incidental
Diverted stream flows Incidental
Rising groundwater Incidental
Uncontaminated groundwater infiltration Incidental
Uncontaminated pumped groundwater Incidental
Uncontaminated potable water sources Incidental
Foundation drains Incidental
Air conditioning condensate Incidental
Irrigation waters Incidental
Springs Incidental
Water from crawl space pumps Incidental
Footing drains Incidental
Lawn watering Incidental
Residential and charity car washing Possible
Flows from riparian habitats and wetlands Incidental
Dechlorinated swimming pool discharges Incidental
Street wash water Incidental
Flows from firefighting activities Incidental

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 11

3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the City of Henderson is aware of other significant
water quality issues within the permitted MS4 area.

The City needs to perform an environmental assessment on all water bodies within the City limits but the
most ubiquitous issues from a quick visual inspection is sediment and litter. The City monitors and
maintains certain thoroughfares in the City that accumulate litter, then dispatch crews to pick up the litter
before it migrates to our water bodies. Even with monthly or twice a month litter sweeps by Public
Works the crews cannot stay keep up with the litter. City Council and the City Manager have discussed
this problem at length in break-out committee meetings and at the City Council Strategic Retreat.
Council have requested fast food businesses to put in trash receptacles at the end of their drive-throughs
and to assist in the litter sweeps. The attempts by business are short lived and have very little impact. The
Police Chief has stated that no citizen throws out litter while an officer is behind them hence issuing
citations has not occurred and does not appear to be a viable solution to this problem.

Sediment accumulation in the streams appears from historical development of commercial enterprises and
single-family housing. The City of Henderson does not issue erosion control permits for residential areas
unless the disturbance is in excess of 1 acre. While the City does not issue these residential permits, we
do monitor the measures in place and request certain maintenance items be performed to keep sediment
on-site. January 2015 to date the City Inspector has done an excellent job in notifying home builders of
the expectations and the City achieves complete compliance 95% of the time. The builders understand
the City’s request for measures like silt fence, check dams and concrete washout pits therefore putting the
contractor on notice once we are award of the disturbance tends to lead to compliance because they know
we have them on our radar.

Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the
likely activities/sources/targeted audiences attributed to each pollutant, and identifies the associated
SWMP program(s) that address each. In addition, the City of Henderson has evaluated schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.

Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing
Target Pollutant(s)/Audience(s)
Litter Citizens on daily commute Public Education & Outreach
Sediment Historical Developers lacked
attention to sediment transport.
Current Residential and Commercial
Construction
Sediment & Erosion Control
Delegated Authority:
Henderson’s Engineering
Department addresses this issue
from a delegated authority and
permit compliance approach for
larger developments. Single
family homes are discovered via
planning or site drive-bys.
Collaboration with the County
building inspection department
Notification of new building

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 12

permits. The certificate of
occupancy is an ultimate
compliance trigger that we use
for commercial compliance.
Fecal coliform Sewer overflows, failing septic
systems, wildlife, illicit discharges
Public Education & Outreach,
Illicit Discharge Detection &
Elimination
Illicit discharges Residential, commercial, industrial,
municipal staff
Public Education & Outreach,
Illicit Discharge Detection &
Elimination
Illegal dumping Residential, commercial, industrial,
municipal staff
Public Education & Outreach,
Illicit Discharge Detection &
Elimination
General non-point source
pollution
Residential, commercial, schools,
municipal staff
Public Education & Outreach
Nitrogen and phosphorus Residential, commercial, industrial,
municipal staff
Public Education & Outreach

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 13

PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION

4.1 Organizational Structure
The City of Henderson is governed as a City Council – Manager form of government where City Council
has 3 employees: City Manager, City Clerk and City Attorney. All City Staff fall under the
Administrative responsibility of the City Manager. The City’s organizational structure is shown below
where key department heads and their assistant department heads are noted:

Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration City Engineer Mr. Clark Thomas Engineering
SWMP Management City Engineer Mr. Clark Thomas Engineering

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 14

Public Education &
Outreach City Engineer Mr. Clark Thomas Engineering
Public Involvement &
Participation City Engineer Mr. Clark Thomas Engineering
Illicit Discharge
Detection &
Elimination
City Engineer Mr. Clark Thomas Engineering
Construction Site
Runoff Control
City Engineer
Engineering Inspector
Mr. Clark Thomas
Mr. Dale Jones
Engineering
Engineering
Post-Construction
Stormwater
Management
City Engineer Mr. Clark Thomas Engineering
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Public Works Director Mr. Andy Perkinson Public Works Dept.
Municipal Facilities
Operation &
Maintenance Program
Public Works Director Mr. Andy Perkinson Public Works Dept.
Spill Response Program City Engineer Mr. Clark Thomas Engineering
MS4 Operation &
Maintenance Program City Engineer Mr. Clark Thomas Engineering
Municipal SCM
Operation &
Maintenance Program
City Engineer Mr. Clark Thomas Engineering
Pesticide, Herbicide &
Fertilizer Management
Program
Public Works Director
Asst. Public Works
Director
Mr. Andy Perkinson
Mr. Lee Owen Public Works Dept.
Vehicle & Equipment
Cleaning Program
Public Works Director
Garage Supervisor
Mr. Andy Perkinson
Mr. Charles Poteat Public Works Dept.
Pavement Management
Program Public Works Director Mr. Andy Perkinson Public Works Dept.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 15

Total Maximum Daily
Load (TMDL)
Requirements
N/A N/A N/A

4.2 Program Funding and Budget
In accordance with the issued permit, the City of Henderson is required to maintain adequate funding and
staffing to implement and manage the provisions of the SWMP and comply with the requirements of the
NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed
by the Division annually. However, the program is underfunded with respect to compliance with the six
program elements, also referred to as minimum control measures.

The stormwater program currently receives funding of approximately $25,000 per year for emergency
repairs and is funded primarily through the General Funds (Street Division). The street division has a
street sweeper and a jet-vac to clean the streets and stormwater pipes when they get clogged. The City
utilizes a work order system to help department heads schedule their work and assess the quality and costs
of each repair. Cartegraph is the name of the work order/asset management system and it has a
component to assign preventative maintenance for specific assets. The City’s public works departments
plans to implement a program to clean at least 10% of the storm drains each year. The stormwater
program will be developed in the next year to mirror the existing sanitary sewer preventative maintenance
program. Currently public works dedicates 65 manhours a week to addressing the stormwater
infrastructure. As the stormwater program expands; the duties, responsibilities and manhours in the street
department will increase accordingly.

The administration of the city’s stormwater regulatory side is performed by the City Engineer,
Construction Inspector and Engineering Technician which are funded through the Water Fund. In total the
stormwater program receives 5-6 hours a week from the engineering staff. The City of Henderson has
experienced only a small uptick in development over the last 7 years. Therefore, stormwater SCM review
and inspection is only a small component of the department’s workload.

Through the gap analysis, self-evaluation process and NCDEQ audit; it is evident that the City of
Henderson needs to fund a minimum of two full time position equivalents (FTE) which includes at least
two part-time positions for the stormwater program. The key position is a stormwater engineer to head-
up the program along with an administrative assistant (30%) and the City Engineer (20%) to guide and
promote the program with the community and City Council. The part-time positions are critical in data
collection, mapping and assessment.

The City has performed an analysis to create a stormwater utility. The funding arm proposed for this
utility is based on a flat rate for residential (single and duplex occupancies) units. Fees for multi-family,
industrial and commercial zoning is based on acreage of impervious area. Due to the nature of several
large businesses, the analysis showed that 13 businesses in the city would carry 65% of the Utility’s fee.
Henderson is an old textile town that is still reeling from the economic downturn created by NAFTA and
to impose a large monthly fee on these legacy businesses has become untenable to several members of the
City Council. Staff has gone back and revised Stormwater Utility Fee structure to impose a minimum and
maximum monthly fee where the maximum charge to an individual business would be $300 and a
$20/month minimum on every business. This minimum and maximum structure reduces the burden to

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 16

the large businesses and redistributes these costs on smaller businesses while providing the same revenue
stream as the initial impervious acreage fee to the City.

Additional staff via the stormwater utility will address the fundamental tenants of the stormwater
program. The self-audit that was composed by a consultant in conjunction with Henderson’s engineering
staff indicates there are many deficiencies and work to be performed over the coming years. Current
market trends place a trained stormwater engineer in great demand by large and small municipalities as
well as large and small consultants. Henderson along with many other small municipalities without
stormwater utilities can barely afford an Engineering Intern much less a seasoned midlevel engineer with
5-10 years that would not require any training. The City Engineer has for the third year put a stormwater
engineer in the budget along with an administrative assistant and more money for part-time interns. The
City Manager has met with the City Engineer for the Fiscal Year 21-22 and understands the gravity of the
stormwater engineer. The manager also understands the funding mechanism to make this position a
reality.

4.3 Shared Responsibility
The City of Henderson does not share the responsibility to implement any minimum control measures of
the NPDES MS4 Permit requirement. The City of Henderson is solely responsible for compliance.

Table 9: Shared Responsibilities
SWMP BMP or
Permit Requirement Implementing Entity & Program Name
Legal
Agreement
(Y/N)
N/A N/A N

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 17

4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000542 for the City of Henderson.

Table 10: Co-Permittee Contact Information
Co-Permittee MS4
Name
Contact Person Phone & E-Mail Interlocal
Agreement
(Y/N)
N/A N/A N/A N

4.5 Measurable Goals for Program Administration
The City of Henderson will manage and report the following Best Management Practices (BMPs) for the
administration of the Stormwater Management Program.

Table 11: Program Administration BMPs
Permit
Ref. 2.1.2 and Part 4: Annual Self-Assessment
Measures to evaluate the performance and effectiveness of the SWMP program components at least annually.
Results shall be used by the permittee to modify the program components as necessary to accomplish the intent
of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30).
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
1. Annual Self-Assessment
Perform an annual evaluation of
SWMP implementation, suitability of
SWMP commitments and any
proposed changes to the SWMP
utilizing the NCDEQ Annual Self-
Assessment Template.
1. Prepare, certify and
submit the Annual Self-
Assessment to NCDEQ
prior to August 31 each
year.
1. Annually, Permit
Years 1 – 4

1. Yes/No
Permit
Ref. 1.6: Permit Renewal Application
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
2. Permit Renewal Application
Audit stormwater program
implementation for compliance with
the permit and approved SWMP and
utilize the results to prepare and
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and performed
by EPA or NCDEQ.
1. TBD – Typically
Permit Year 4
1. Yes/No

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 18

Table 11: Program Administration BMPs
submit a permit renewal application
package.
2. Self-audit and
document any
stormwater program
components not audited
by EPA or NCDEQ
utilizing the DEQ Audit
Template. Submit Self-
Audit to DEMLR
(required component of
permit renewal
application package).
2. Permit Year 5 2. Yes/No/Partial
3. Certify the
stormwater permit
renewal application
(Permit renewal
application form, Self-
Audit, and Draft SWMP
for the next 5-year
permit cycle) and submit
to NCDEQ at least 180
days prior to permit
expiration.
3. Permit Year 5 3. Date of permit renewal
application submittal

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 19

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Henderson will implement a Public Education and Outreach Program to distribute educational
materials to the community or conduct equivalent outreach activities about the impacts of storm water
discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff.

The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by
the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of
Henderson is required to inform businesses and the general public of the hazards associated with illicit
discharges, illegal dumping and improper disposal of waste.

Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources Target Audience(s)
Litter General Public
Illicit Discharges General Public, Businesses, Municipal Employees
Illegal Dumping General Public, Businesses, Municipal Employees
Improper Disposal of Waste General Public, Businesses, Municipal Employees

The City of Henderson will manage, implement and report the following public education and outreach
BMPs.

Table 13: Public Education and Outreach BMPs
Permit
Ref. 3.2.2 and 3.2.4: Outreach to Targeted Audiences
Measures to identify the specific elements and implementation of a Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The
permittee shall provide educational information to identified target audiences on pollutants/sources identified in
table 12 above, and shall document the extent of exposure of each media, event or activity, including those
elements implemented locally or through a cooperative agreement.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
3. Public Education and Outreach Plan
The City will develop a Public
Education and Outreach Plan (PEOP)
to identify goals and objectives of
the Public Education and
Outreach Program based on
community wide issues. The PEOP
will identify the target pollutants
likely to have significant stormwater
1. Identify goals and
objectives of the public
education and outreach
program.
1. Permit Year 1

1. Y/N/Partial; List of
goals and objectives.
2. Identify target
pollutants likely to have
significant stormwater
impacts.
2. Permit Year 1 2. Y/N/Partial; List of
target pollutants.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 20

Table 13: Public Education and Outreach BMPs
impacts, likely sources, associated
target audiences, and why they were
selected. Schools, homeowners, and
businesses will be evaluated as target
audiences. The PEOP will further
identify the strategies that the City
will use to reach target audiences,
such as types of media, events, and
activities.
3. Identify potential
sources of target
pollutants and the
audiences that impact
those sources.
3. Permit Year 1 3. Y/N/Partial; List of
sources and audiences.
4. Identify strategies to
reach target audiences.
4. Permit Year 1 4. Y/N/Partial; List of
strategies.
5. Develop Public
Education and Outreach
Plan.
5. Permit Year 1 5. Y/N/Partial; Date of
plan.
4. Distribute Public Education Materials to Target Audiences
The City currently distributes
stormwater educational outreach
materials to the Leadership Vance
Program for Business Leaders, as
well as the local Science,
Technology, Engineering, and
Mathematics (STEM) school
program.

The City will continue to distribute
educational materials to the existing
audience listed previously but will
seek to expand its target audience to
include the appropriate target groups
identified in BMP #3. In lieu of
developing new outreach materials,
the City may rely on Public
Education Outreach materials
supplied by the state, and/or other
entities, such as the Triangle J
Council of Governments (TJCOG),
through a cooperative agreement. The
City will implement the strategies
and mediums identified in the PEOP
that will most effectively reach the
target audiences and may seek out
partnerships to fund any public
outreach using the mediums
identified in the PEOP.
1. Provide public
stormwater education
outreach materials to the
Leadership Vance
program for business
leaders.

1. Permit Year 2 1. Y/N/Partial
2. Provide outreach
materials to the STEM
school program.
2. Permit Year 2 2. Y/N/Partial
3. Consider entering into
a partnership with
governmental agencies
such as Triangle J
Council of Governments
(TJCOG) to leverage
their public education
and outreach materials
and strategies.
3. Permit Year 2

3. Y/N/Partial
4. Consider entering into
an agreement with the
Stormwater Association
of North Carolina
(SWANC) to fund public
outreach on television
and other media.
4. Permit Year 2

4. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 21

Table 13: Public Education and Outreach BMPs

Permit
Ref. 2.1.7, 3.2.3 and 3.6.5(c): Web Site
Measures to provide a web site designed to convey the program’s message(s) and provide online materials
including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory
mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit
and SWMP. The web page shall also provide developers with all relevant post-construction requirements,
design standards, checklists and/or other materials.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
5. Stormwater Web Site
The City currently operates and
maintains a stormwater program
website that is located at
https://ci.henderson.nc.us/department
s/engineering/stormwater_program.p
hp. This website includes relevant
background information regarding
the City’s stormwater standards. The
City is currently working on a new
rebranded website that will be used to
convey the stormwater program’s
message. In the interim, pertinent
stormwater information will be added
to the City’s existing website.

1. Post to the web site a
list identifying the
ordinances or other
regulatory mechanisms
providing the legal
authority necessary to
implement and enforce
the requirements of the
permit and SWMP.
1. Permit Year 2

1. Y/N/Partial
2. Post to the website
relevant post-
construction
requirements, design
standards, checklists
and/or other materials for
developers.
2. Permit Year 2

2. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 22

Table 13: Public Education and Outreach BMPs
Upon completion of the new website,
the City will promote and populate
the website with a comprehensive list
identifying City ordinances or other
regulatory mechanisms, relevant
post-construction requirements,
design standards, checklists, and/or
any other useful materials for
developers. Any relevant information
listed on the old website will be
incorporated. `

Permit
Ref. 3.2.5: Stormwater Hotline
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
6. Publish Stormwater Helpline and Email Information
The City will select and advertise an
existing City of Henderson office
number as the stormwater helpline,
create a stormwater program general
email address, and ensure that any
inquiries are directed to Engineering
staff for response/follow-up.

1. Identify an appropriate
existing City phone
number to be utilized as
the stormwater helpline.
1. Permit Year 1

1. Y/N/Partial
2. Post the helpline
phone number and
stormwater program
email address on the new
Stormwater Web Site
with a note explaining
that any inquiries and
public input on the
stormwater program
should be directed to the
helpline.
2. Permit Year 1

2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.
7. Public Education on IDDE
The City will update public education
and outreach materials identified in
BMP #6 with information to inform
public employees,
businesses, and the general
public of hazards associated
with illegal discharges and
improper disposal of waste.

1. Identify methods to
distribute outreach
materials to public
employees, business, and
the general public.
1. Permit Year 1 1. Methods Identified:
Y/N/Methods for each
group.
2. Update existing public
education materials to
include illicit discharges
and illegal dumping.
2. Permit Year 2 2. Materials Updated:
Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 23

Table 13: Public Education and Outreach BMPs
In lieu of developing new materials,
the City may rely on Public
Education Outreach materials
supplied by the state, and/or other
entities through a
cooperative agreement.
3. Distribute materials to
public employees,
business, and the general
public based on methods
identified in BMP
#20.B.1.
3. Permit Year 2 3. Materials Distributed:
Y/N; Distribution
Method; Groups
targeted; Number of
materials distributed.
4. 4. 4.
5. 5. 5.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 24

PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
This SWMP identifies the minimum elements and implementation of a Public Involvement and
Participation Program that complies with applicable State, Tribal and local public notice requirements.
The City of Henderson will manage, implement and report the following public involvement and
participation BMPs.

Table 14: Public Involvement and Participation BMPs
Permit
Ref. 3.3.1: Public Input
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
8. Solicit Public Input on Stormwater Web Site
The City will solicit public input on
stormwater issues and the City
stormwater program through a
statement on the City stormwater web
site, located at
https://ci.henderson.nc.us/department
s/engineering/stormwater_program.p
hp
1. Post the helpline
number on the
Stormwater Web Site
with a note that any
inquiries or input on the
stormwater program
should be directed to the
helpline.
1. Permit Year 1 1. Y/N/Partial
2. Post to the web site a
statement that reads
“Questions or comments
on stormwater issues and
the City of Henderson
Stormwater Program
may be directed to” and
include the helpline
number and stormwater
program email address.

2. Permit Year 1 2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.3.2: Volunteer Opportunities
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
9. Stormwater Volunteer Community Involvement Program

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 25

Table 14: Public Involvement and Participation BMPs
The City will conduct and promote
volunteer opportunities designed to
encourage ongoing citizen
participation. Types of events will be
identified in the PEOP and may
include community litter pick-up,
Citizen Scientist projects, and Adopt-
a-Stream programs. The City will
continue to promote the Stormwater
helpline identified in BMP #9.
1. Identify examples of
volunteer opportunities
in the PEOP
1. Permit Year 1

1. Y/N/Partial
2. Promote volunteer
opportunities
2. Annually, Permit
Years 2-5

2. Y/N/Partial;
Promotion Method.
3. Conduct at least one
volunteer event
3. Annually, Permit
Years 2-5

3. Y/N/Partial
4. 4. 4.
5. 5. 5.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 26

PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The City of Henderson will develop, manage, implement, document, report and enforce an Illicit
Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit
discharge detection and elimination BMPs.

Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
Ref. 3.4.1: MS4 Map
Measures to develop, update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
10. Maintain Storm Sewer System Map of Major Outfalls
The City has mapped stormwater
conveyances, flow direction, inlets,
culverts, receiving streams, and some
stormwater discharge points. Major
outfalls are not identified in the
current MS4 map. Existing
stormwater data has been collected in
GIS and then maintained in the City’s
asset inventory system, Cartegraph.

The City will evaluate the current
GIS data and conduct field
reconnaissance efforts to identify
major outfalls meeting the definition
of 36-inch diameter outfall and 12-
inch diameter outfall for industrial
zoned areas. The MS4 map will be
updated to include discharge points
meeting the definition of major
outfalls. GIS data and Cartegraph
records will be updated with
information such as outfall diameter
based on field-verification during
reconnaissance activities.
1. GIS desktop analysis
to identify potential
major outfalls.
1. Permit Year 1

1. GIS Analysis
Performed: Y/N/Partial
2. Field reconnaissance
to confirm location of
major outfalls.
2. Permit Year 1

2. Fieldwork Conducted:
Y/N/Partial
3. Finalize outfall map to
include major outfalls.
3. Continuously, Permit
Years 1-5

3. Map Finalized:
Y/N/Partial/Date
4. Update the Cartegraph
asset inventory system to
include major outfalls.
4. Permit Year 1

4. Cartegraph Updated:
Y/N/Partial
5. Update map in GIS
and Cartegraph when
there are changes to the
system.
5. Annually, Permit
Years 2-5
5. Map/Cartegraph
Updated:
Y/N/Partial/Date
Permit
Ref. 3.4.2: Regulatory Mechanism
Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to
prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4,
including enforcement procedures and actions.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
11. Illicit Discharge Detection and Elimination (IDDE) Ordinance

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 27

Table 15: Illicit Discharge Detection and Elimination BMPs
The City maintains an Illicit
Discharge Detection and Elimination
(IDDE) ordinance that provides the
legal authority to prohibit illicit
connections and discharges.
The IDDE Ordinance is available
under Subtitle C, Chapter 16,
Division 3, Section 16-37.8.
1. Annual review of
IDDE ordinance to
ensure permit
compliance.
1. Annually, Permit
Years 1-5.
1. Y/N/Partial; Date of
Adoption; Ordinance
Reference
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
12. Enforcement of IDDE Ordinance
The City maintains enforcement
procedures in the IDDE Ordinance.
Illegal dumping and illicit discharges
that are reported to the City result in
issuance of a notice of violation
(NOV) to the discharger.

The City currently maintains a GIS-
based inventory in Cartegraph used to
track each NOV issued, including the
address of the violation. During an
annual review, the inventory will be
sorted by address to identify repeat
offenders.
1. Maintain NOV
tracking inventory in
Cartegraph.
1. Continuously, Permit
Years 1-5
1. Y/N/Partial; Summary
of type and number of
enforcement actions
issued.
2. Sort NOV tracking
spreadsheet to identify
chronic violators.
2. Annually, Permit
Years 1-5
2. Y/N/Partial
3. Implement additional
enforcement actions
against chronic violators.
3. Continuously, Permit
Years 1-5
3. Y/N/Partial; Summary
of type and number of
enforcement actions
issued to chronic
violators.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.4.3: IDDE Plan
Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
13. Written IDDE Plan
The City doesn’t currently have a
written IDDE Plan. The City will
develop an IDDE Plan to include the
1. Identify priority areas
likely to have illicit
discharges.
1. Permit Year 1 1. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 28

Table 15: Illicit Discharge Detection and Elimination BMPs
components specified in Section 3.4.3
of the MS4 Permit.
2. Identify schedule and
frequency for dry
weather inspections of
major outfalls.
2. Permit Year 1 2.Y/N/Partial/Schedule
and Frequency.
3. Develop standard
documentation and
forms.
3.Permit Year 1 3.Y/N/Partial
4. Develop written IDDE
Plan, submit to DEQ for
approval.
4. Permit Year 1 4. Y/N/Date of Plan/Date
submitted to DEQ/Date
DEQ Approved.
5. 5. 5.
14. Dry Weather Outfall Screening and Source Tracing
The City has not yet conducted dry
weather screening. Once the City
identifies its major outfalls (BMP
#12) and develops its written IDDE
Plan (BMP #15) with dry weather
screening schedule, frequency, and
forms, the City will commence
annual dry weather screening of
major outfalls. Outfall inspections
and field observations will be
conducted during dry weather
conditions to identify dry weather
flow in accordance with procedures
in the IDDE plan. If dry weather flow
is observed at a major outfall, the
flow will be traced upstream to
identify the source, as specified in the
IDDE Plan.
1. Complete dry weather
outfall screening of all
mapped outfalls.
1. Annually, Permit
Years 2-5
1. Y/N/Date(s) of
screening; Number of
outfalls screened.
2. Investigate sources of
flowing outfalls during
dry weather.
2. Continuously, Permit
Years 2-5
2. Y/N/Partial; Number
of outfalls with dry
weather flow; Source
investigation findings.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.4.4: IDDE Tracking
Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was
observed, the results of the investigation, any follow-up of the investigation, the date the investigation was
closed, the issuance of enforcement actions, and the ability to identify chronic violators.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
15. IDDE Investigation Tracking and Documentation
The City has not yet conducted dry
weather screening nor tracking or
documentation of suspected illicit
1. Develop IDDE
investigation tracking
spreadsheet.
1. Permit Year 2 1. Tracking Spreadsheet
Developed: Y/N/Partial.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 29

Table 15: Illicit Discharge Detection and Elimination BMPs
discharges or illegal dumping. The
City will begin to track enforcement
actions for confirmed illicit discharge
and illegal dumping, as specified in
BMP #14. Following the
commencement of major outfall dry
weather screening and source
tracking (BMP #16), the City will
develop an IDDE investigation
tracking spreadsheet to track and
document 1) the date(s) the illicit
discharge was observed; 2) the results
of the investigation; 3) any follow-up
of the investigation; and 4) the date
the investigation was closed.
2. Update tracking
spreadsheet following
the identification of a
suspected illicit
discharge, connection, or
illegal dumping and
throughout the
investigation process
through closure.
2. Continuously, Permit
Years 1-5.
2. Tracking Spreadsheet
Updated: Y/N/Partial;
Number of
investigations, potential
illicit discharges, verified
illicit discharges,
remedied illicit
discharges; enforcement
actions.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.4.5: Staff IDDE Training
Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall
include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff
training event shall be documented, including the agenda/materials, date, and number of staff participating.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
16. Employee and Contractor Training
Employees and contractors are not
currently trained on the identification
and reporting of illicit discharges,
illicit connections, or illegal
dumping. The City plans to partner
with an entity to acquire illicit
discharge and connection training
materials in order to begin
conducting annual staff training
events. The City will then begin to
implement and document a training
program for appropriate municipal
staff, who as part of their normal job
responsibilities, may come into
contact with or otherwise observe an
illicit discharge or illicit connection.
1. Partner with entity to
acquire illicit discharge
and connection training
materials.
1. Permit Year 2 1. Training Materials
Acquired: Y/N/Partial
2. Conduct training. 2. Annually, Permit
Years 2-5
2. Training Conducted:
Y/N/Partial; Training
date, topics, and number
trained.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.4.6: IDDE Reporting
Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be
publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 30

Table 15: Illicit Discharge Detection and Elimination BMPs
17. Public Reporting Mechanism
The City does not currently promote
a public reporting mechanism for
illicit discharges, illegal dumping and
spills. The City will begin to solicit
public and staff reporting illicit
discharges, illegal dumping and spills
through a statement on the City
stormwater web site, located at
https://ci.henderson.nc.us/department
s/engineering/stormwater_program.p
hp. The City will investigate reports
as specified in the IDDE Plan and
will document the suspected illicit
discharge, illegal dumping, or spill in
the IDDE tracking excel spreadsheet
developed in BMP #17 with the date
it was reported, findings of the
investigation, source, enforcement
actions, and closure.
1. Post to the web site a
statement that “If you
observe or suspect an
illicit discharge, illegal
dumping, or spill, please
contact the City of
Henderson Stormwater
Program at”, and include
the helpline number and
stormwater program
email address.
1. Permit Year 1 1. Web Site Updated:
Y/N/Partial; Number of
reported illicit
discharges, illegal
dumping and spills;
Summary of responses.
2. Update the IDDE
tracking excel
spreadsheet.
2. Continuously, Permit
Years 1-5.
2. IDDE Tracking
Spreadsheet Updated
with Reported ID:
Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.

PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of Henderson relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 as a qualifying alternative program to meet a
portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The SPCA
requirements include reducing pollutants in stormwater runoff from construction activities that result in
land disturbance of greater than or equal to one acre, and any construction activity that is part of a larger
common plan of development that would disturb one acre or more. The state SPCA Program is either
delegated to a city/town, delegated to a county, or implemented by NCDEQ in non-delegated areas.

Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Permit
Reference State or Local Program Name Legal Authority Implementing
Entity
3.5.1 -
3.5.4
City of Henderson
Delegated SEC Program*
15A NCAC
Chapter 04,
Title V, Chapter
23A of the City
Code of
Ordinances.
City of Henderson
2 * The local delegated Soil and Erosion Control (SEC) Program ordinance can be found at:
https://library.municode.com/nc/henderson/codes/code_of_ordinances?nodeId=TITVINPL_CH23ASO
ERSECO.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 31

The City of Henderson also implements the following BMPs to meet NPDES MS4 Permit requirements.

Table 17: Construction Site Runoff Control BMPs
Permit
Ref. 3.5.6: Public Input
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
18. Municipal Staff Training
The City will train municipal staff
who receive calls from the public on
the protocols for referral and tracking
of construction site runoff control
complaints.
1. Train municipal staff
on proper handling of
construction site runoff
control complaints.
1. Annually, Permit
Years 1-5
1. Number of staff
trained
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
19. Notification System for Public Reporting of SEC Problems
The City will establish and advertise
a dedicated notification system for
the public to use for reporting any
SEC problems or concerns. The City
will also solicit public reporting of
SEC problems observed at
construction sites to the City through
a statement on the City stormwater
web site, located at
https://ci.henderson.nc.us/department
s/engineering/stormwater_program.p
hp
1. Post to the stormwater
website a statement that
reads “Please report
concerns related to
sediment and erosion
control at construction
sites to the City of
Henderson Stormwater
Program at” and include
the helpline number and
stormwater program
email address.
1. Permit Year 5

1. Y/N/Partial
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref. 3.5.5: Waste Management
Measures to require construction site operators to control waste such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to
water quality.
A B C D

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 32

Table 17: Construction Site Runoff Control BMPs
BMP
No. Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
20. Control Construction Site Waste
The City is currently implementing
the delegated SEC program as
published in Chapter 23A of the
City ordinance, as well as complying
with NCG010000 permit
requirements to control construction
site waste that may adversely impact
water quality.

1.Require construction
sites to meet
NCG010000 permit
requirements for private
developments and City
construction projects.
1. Continuously, Permit
Years 1-5.
1. Y/N/Partial
2. 2. 2.
3. 3. 3.
4. 4. 4.
21. SEC Ordinance
The City maintains a Soil Erosion
and Sedimentation Control ordinance
that provides the legal authority to
approve SEC plans submitted to the
City, conduct inspections to ensure
compliance, and enforcement powers.
The SEC Ordinance is available
under Title V, Chapter 23A.
The current ordinance requires
construction site operators to
implement appropriate erosion and
sediment control BMPs while
proving procedures for site plan
review which incorporate the
consideration of adverse water
quality impacts. The current
ordinance also provides procedures
for site inspection and the
enforcement of control measures.
1. Annual review of SEC
ordinance to ensure
permit compliance.
1. Annually, Permit
Years 1-5.
1. Y/N/Partial; Date of
Adoption.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 33

PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
This SWMP identifies the minimum elements to develop, implement and enforce a program to address
stormwater runoff from new development and redevelopment projects that disturb greater than or equal to
one acre, including projects less than one acre that are part of a larger common plan of development or
sale, that are located within the City of Henderson and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures (SCMs) and/or non-structural BMPs appropriate for the community, and ensure adequate long-
term operation and maintenance of SCMs.

In accordance with 15A NCAC 02H .0153 and .1017, the City of Henderson implements the following
State post-construction program requirements, which satisfy the NPDES Phase II MS4 post-construction
site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where
they are implemented.

Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program
State QAP Name State Requirements Local Ordinance / Regulatory
Mechanism Reference
Tar-Pamlico River Basin Nutrient
Sensitive (NSW) Management Strategy
15A NCAC 2B .0258 City Ordinance-Title IV- Public
Utilities; Subtitle C- Public Works,
Chapter 16-Streets and Sidewalks,
Article II-Excavations cuts and
repairs, Division 3-Stormwater
Management
2

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 34

Table 19: Summary of Existing Post-Construction Program Elements

Permit Requirements for
Plan Review and Approval
Municipal Ordinance/Code Reference(s)
and/or Document Title(s) Date Adopted
3.6.2(a) Authority Sec 16.-37.1 Rev 1-27-12
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
3.6.3(b) Plan Review Sec 16-37.6 Rev 1-27-12
3.6.3(c) O&M Agreement Sec 16-37.4.d.2.b.iv Rev 1-27-12
3.6.3(d) O&M Plan Sec 16-37.4.d.2.b.v Rev 1-27-12
3.6.3(e) Deed
Restrictions/Covenants Sec 16-37.4.d.2.b.v Rev 1-27-12
3.6.3(f) Access Easements Sec 16-37.4.d.2.b.v Rev 1-27-12
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s) Date Adopted
3.6.2(b) Documentation Sec 16-37.5 Rev 1-27-12
3.6.2(c) Right of Entry Sec 16-37.7 Rev 1-27-12
3.6.4(a) Pre-CO Inspections Sec 16-37.7 Rev 1-27-12
3.6.4(b) Compliance with Plans Sec 16-37.6 Rev 1-27-12
3.6.4(c) Annual SCM Inspections Sec 16-37.7.b Rev 1-27-12
3.6.4(d) Low Density Inspections N/A N/A
3.6.4(e) Qualified Professional Sec 16-37.7.b.1 Rev 1-27-12
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s) Date Adopted
3.6.6(a) Pet Waste N/A N/A
3.6.6(b) On-Site Domestic
Wastewater Treatment N/A N/A

The annual reporting metrics for the post construction program are provided in Table 20: Post
Construction Site Runoff Control BMPs below.

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref. 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements
Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate
information to accurately describe progress, status, and results.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
22. Standard Reporting
Implement standardized tracking,
documentation, inspections and
reporting mechanisms to compile
appropriate data for the annual self-
1. Track number of low
density and high-density
plan reviews performed.
1. Continuously, Permit
Years 1-5
1. Number of plan
reviews performed for
low density and high
density.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 35

Table 20: Post Construction Site Runoff Control BMPs
assessment process. Data shall be
provided for each Post-Construction/
Qualifying Alternative Program
being implemented as listed in Tables
18 and 19.
2. Track number of low
density and high density
plans approved.
2. Continuously, Permit
Years 1-5
2. Number of plan
approvals issued for low
density and high density.
3. Maintain a current
inventory of low density
projects and constructed
SCMs including SCM
type or low density
acreage, location and last
inspection date.
3. Continuously, Permit
Years 1-5
3. Summary of number
and type of SCMs added
to the inventory; and
number and acreage of
low density projects
constructed.
4. Track number of SCM
inspections performed.
4. Continuously, Permit
Years 1-5
4. Number of SCM
inspections.
5. Track number of low
density inspections
performed.
5. Continuously, Permit
Years 1-5
5. Number of low-
density projects
inspected.
6. Track number and
type of enforcement
actions taken.
6. Continuously, Permit
Years 1-5
6. Number of
enforcement actions
issued.
Permit
Ref. 2.3 and 3.6: Qualifying Alternative Program(s)
Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program
requirements.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
The QAP requirements are fully met by the existing QAP for post-construction, see references provided in Table 18.
Permit
Ref. 3.6.2: Legal Authority
Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review
designs and proposals for new development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained, (b) request information such as stormwater
plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance
with the Post-Construction Stormwater Management Program, and (c) enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater
discharges to determine whether there is compliance with the Post-Construction Stormwater Management
Program.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
This permit requirement is fully met by the existing post-construction program, see references provided in Table 19.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 36

Table 20: Post Construction Site Runoff Control BMPs
Permit
Ref. 3.6.3: Plan Review and Approval
Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal,
State, and local government projects to comply with Post-Construction Program requirements throughout the
entire MS4 permitted area, unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative
program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than
or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that
apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and
protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC 02H 1050 (9) and (10).
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
This permit requirement is fully met by the existing post-construction program, see references provided in Table 19.
Permit
Ref. 3.6.4: Inspections and Enforcement
Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post-
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual
inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance
Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require
that inspections be conducted by a qualified professional
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
This permit requirement is fully met by the existing post-construction program, see references provided in Table 19.
Permit
Ref. 3.6.6: Fecal Coliform Reduction
Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be
achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system
component, if applicable, which may be coordinated with local county health department, to ensure proper
operation and maintenance of such systems.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
23. Pet Waste Management at Dog Parks
Conduct pet waste management
practices at the two City-owned dog
1. Pet waste bag
dispensing.
1. Continuously, Permit
Years 1-5
1. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 37

Table 20: Post Construction Site Runoff Control BMPs
parks: “Pawsome Park” and “Scentral
Bark”.
2. Waste receptacles. 2. Continuously, Permit
Years 1-5
2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.
24. Pet Waste Ordinance
Develop a pet waste ordinance or
amend an existing ordinance with a
pet waste management component.
1. Develop or amend
existing ordinance with
pet waste management
component.
1. Permit Year 3 1. Y/N/Partial; Date
adopted; Ordinance
reference.
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 38

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of Henderson municipal facilities and operations. Pollution prevention and good housekeeping is
accomplished through the implementation of seven required programs, which collectively address the
ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and
open space maintenance, fleet and building maintenance, new construction and land disturbances, and
municipal storm sewer system maintenance.

Pollution prevention and good housekeeping for municipal operations includes the following programs:

1. Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide, Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Maintenance Program
7. Pavement Management Program

The City of Henderson will manage, implement and report the pollution prevention and good
housekeeping BMPs as specified in Table 21 below for each required program.

Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
Ref.
3.7.1: Municipal Facilities Operation and Maintenance Program
Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted
stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections
and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on
general stormwater awareness and implementing pollution prevention and good housekeeping practices. [Please note that
at a minimum, NCDEQ will require that all inventoried municipal facilities be inspected once per permit term to
determine pollution potential, and facilities with potential be inspected at least annually]
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
25. Inventory and Inspect Municipally Owned or Operated facilities
The City maintains a current
inventory of facilities and operations
owned and operated by the City with
the potential for generating polluted
stormwater runoff. The City will
inspect all inventoried municipal
facilities once per permit term
(Permit Year 2) to determine if each
1. Maintain an inventory
of facilities and
operations owned and
operated by the City.
1. Continuously, Permit
Years 1-5.
1. Y/N/Date Updated
2. Inspect all inventoried
municipal facilities to
determine pollution
potential.
2. Permit Year 2 2. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 39

Table 21: Pollution Prevention and Good Housekeeping BMPs
facility has the potential for
pollutants to come in contact with
stormwater and enter the storm sewer
system. The City will identify which
facilities have that pollution potential,
and inspect those facilities on an
annual basis.
3. Inspect municipal
facilities with stormwater
pollution potential.
3. Annually, Permit
Years 2-5
3. Y/N/Partial
4. 4. 4.
5. 5. 5.
26. Operation and Maintenance (O&M) for Municipally Owned or Operated Facilities
Maintain, implement, and annually
evaluate and update as necessary an
O&M program for municipally
owned and operated facilities with
the potential for generating polluted
stormwater runoff. The O&M
program shall specify and establish
the frequency of inspections, routine
maintenance requirements, and
standard documentation.
1. Develop Stormwater
Plan with O&M
specifications for sand
filters and other SCMs at
the Operations Center.
1. Permit Year 1

1. Y/N/Date
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
27. Staff Training on Pollution Prevention and Good Housekeeping
Implement an employee training
program for employees involved in
implementing pollution prevention
and good housekeeping practices.
1. Partner with entity to
acquire pollution
prevention and good
housekeeping training
materials.
1. Permit Year 2

1. Y/N/Partial
2. Conduct training. 2. Annually, Permit
Years 2-5
2. Y/N/Partial; Training
date, topics, and number
trained.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref.
3.7.2: Spill Response Program
Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater
runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response
procedures.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
28. Written Spill Response Procedures
Maintain written spill response
procedures for municipally
owned or operated facilities.
1. Develop written spill
response procedures.
1. Permit Year 1

1. Y/N/Date
2. 2. 2.
3. 3. 3.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 40

Table 21: Pollution Prevention and Good Housekeeping BMPs
4. 4. 4.
5. 5. 5.
Permit
Ref.
3.7.3: MS4 Operation and Maintenance Program
Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and
maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the
collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard
documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
29. O&M for Catch Basins and Storm Sewer Conveyance Systems
Maintain and implement an O&M
program for the storm sewer system
including catch basins and
stormwater conveyance systems that
the City owns and maintains. The
O&M program shall specify and
establish the frequency of
inspections, routine maintenance
requirements, and standard
documentation.
1. Establish an MS4
O&M program.
1. Permit Year 1

1. Y/N/Partial
2. Implement O&M
Program.
2. Continuously, Permit
Years 1-5
2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
Measures to manage municipally-owned, operated, and/or maintained structural stormwater control measures (SCMs) that
are installed for compliance with the permittee’s post-construction program. The permittee shall maintain a current
inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and
documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
30. Identify Structural Stormwater Controls
The City is currently gathering data
on the City’s stormwater system. The
City will update and maintain a
current inventory of municipally-
owned or operated structural
stormwater control measures (SCMs)
installed for compliance with the
City’s post-construction ordinance.
1. Update inventory. 1. Continuously, Permit
Years 1-5.
1. Y/N/Date Updated;
Number/type (summary).
2. 2. 2.
3. 3. 3.
4. 4. 4.
5. 5. 5.
31. O&M for Structural SCMs
Maintain and implement an O&M
program for municipally-owned or
maintained structural SCMs. The
O&M program shall specify and
establish the frequency of
inspections, routine maintenance
1. Establish structural
SCM O&M written
procedures.
1. Permit Year 1 1. Y/N/Partial
2. Implement the
structural SCM O&M
program.
2. Continuously, Permit
Years 1-5
2. Y/N/Partial

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 41

Table 21: Pollution Prevention and Good Housekeeping BMPs
requirements, and standard
documentation.
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref.
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine
pollution prevention and chemical use, storage and handling training, and shall ensure compliance with permits and
applicator certifications.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
32. Pesticide, Herbicide and Fertilizer Application Management
The City employees are currently
licensed. Ensure municipal
employees and contractors are
properly trained and all permits,
certifications, and other
measures for applicators are
followed.
1. Ensure municipal
employees are licensed
and trained.
1. Continuously, Permit
Years 1-5.
1. Y/N/Partial
2. Ensure contractors are
licensed and trained
2. Continuously, Permit
Years 1-5.
2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.
Permit
Ref.
3.7.6: Vehicle and Equipment Maintenance Program
Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and
equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES
industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff,
perform routine inspections, and establish specific frequencies, schedules, and documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
33. Minimize Contamination of Stormwater Runoff from Vehicle and Equipment Cleaning Areas
The City will describe and implement
control measures to prevent or
minimize contamination of the
stormwater runoff from all areas used
for vehicle and equipment
maintenance and cleaning. The City
will ensure municipal industrial
facilities subject to NPDES industrial
permitting comply with permit
requirements, perform routine
inspections, and establish
frequencies, schedules, and standard
documentation.
1. Repair wash pad that
discharges to sanitary
sewer system.
1. Permit Year 3

1. Y/N/Partial
2. Wash vehicles and
equipment at wash pad
or other location
discharging to sanitary
sewer.
2. Continuously, Permit
Years 1-5

2. Y/N/Partial
3. 3. 3.
4. 4. 4.
5. 5. 5.

DRAFT NCS000542 SWMP
City of Henderson
April 13, 2021
Page 42

Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
Ref.
3.7.7: Pavement Management Program
Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots within the
permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid
pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
34. Maintenance of Streets, Roads, and Public Parking Lots
Evaluate existing and new BMPs
annually that reduce polluted
stormwater runoff from municipally-
owned streets, roads and public
parking lots within their corporate
limits. The City will evaluate the
effectiveness of these BMPs based on
cost and the estimated quantity of
pollutants removed. The City will
implement new BMPs where
necessary to control litter and other
pollutants associated with vehicles, as
well as establish frequencies,
schedules, and standard
documentation.
1. Do not conduct street
washing.
1. Continuously, Permit
Years 1-5.
1. Y/N/Partial
2. Conduct street
sweeping.
2. Continuously, Permit
Years 1-5
2. Y/N/Partial
3. Evaluate existing and
new best practices.
3. Annually, Permit
Years 1-5
3. Y/N/Partial
4. 4. 4.
5. 5. 5.