HomeMy WebLinkAboutNCS000397_Newton Draft SWMP_20190819NCS000397
STORMWATER MANAGEMENT PLAN
CITY OF NEWTON
AUGUST 19, 2019
PREPARED BY
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 .......................................................................................................................... 5
3.4 MS4 Interconnection ..................................................................................................................... 5
3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 6
3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 6
3.7 Industrial Facility Discharges ....................................................................................................... 7
3.8 Non-Stormwater Discharges ......................................................................................................... 7
3.9 Target Pollutants and Sources ....................................................................................................... 8
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 10
4.1 Organizational Structure ............................................................................................................. 10
4.2 Program Funding and Budget ..................................................................................................... 12
4.3 Shared Responsibility ................................................................................................................. 12
4.4 Co-Permittees .............................................................................................................................. 13
4.5 Measurable Goals for Program Administration .......................................................................... 14
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 16
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 21
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 23
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 28
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 30
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 36
List of Tables
Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
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 NCS000397 SWMP
City of Newton
August 19, 2019
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 Newton 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 Newton 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 NCS000397, 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 Newton and located
within the corporate limits of the City of Newton.
In preparing this SWMP, the City of Newton 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.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
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 principal executive officer or ranking elected official.
☐ I am a duly authorized representative and have attached the authorization made in writing by a principal
executive officer or ranking elected official which specifies me as:
☐ A specific individual having overall responsibility for stormwater matters.
☐ A specific position having overall responsibility for stormwater matters.
Signature:
Name:
Title:
Signed this ____ day of 20____ .
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 3
PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the City of Newton, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of City of Newton as of the date of this document.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 4
3.2 Existing MS4 Mapping
The current MS4 mapping includes stormwater inflows, stormwater manholes, stormwater junction
boxes, culvert drain pipes, stormwater discharges, and settling basins. The MS4 area has been mapped.
However, previously unmapped stormwater infrastructure is still occasionally discovered. Stormwater
inflows include information on material, diameter/box size, depth, and ground cover. Culvert drain pipes
include information on diameter, box size, material, ground cover, and length. Stormwater discharges
include information on material, diameter/box size, ground cover, and receiving stream. The stormwater
discharges include outfalls, but a layer identifying only the major outfalls does not exist. Settling basins
includes stormwater control measures and reports information including material, bank material, baffles,
and weir information.
Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped 95 %
No. of Major Outfalls* Mapped 0 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 NCS000397 SWMP
City of Newton
August 19, 2019
Page 5
3.3 Receiving Waters
The City of Newton MS4 is located within the Catawba River Basin and discharges directly into
receiving waters as listed in Table 2 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 2: Summary of MS4 Receiving Waters
Receiving Water Name Stream Index /
AU Number
Water Quality
Classification
303(d) Listed Parameter(s)
of Interest
Betts Branch 11-129-5-6 C
Bills Branch (Bili Branch) 11-129-5-5 C
Clark Creek (Shooks Lake) 11-129-5-(0.3)b C Benthos (Nar, AL, FW)
Cline Creek 11-129-5-2 C
Henry Fork 11-129-1-(12.5) C
Hildebran Creek (Anthony Creek) 11-129-5-3 C
Jacob Fork 11-129-2-(9.5) WS-III
McLin Creek 11-76-5-(0.3)
11-76-5-(0.7)
C
WS-IV
Benthos (Nar, AL, FW)
Smyre Creek 11-129-5-4-1 C
South Fork Catawba River 11-129-(0.5) WS-V
Town Creek 11-129-5-4 C
C – Class C (fishable/swimmable waters)
WS III/IV/V – Water Source
Benthos (Nar, AL, FW) – Narrative standard, aquatic life, fresh waters
Data from 2018 NC Category 5 Assessments “303(d) List” Final and NC Surface Water Classifications
Map. From the 2018 303(d) Listing and Delisting Methodology for Benthos: “Narrative criterion: Waters
shall be suitable for aquatic life propagation and maintenance of biological integrity. NC uses benthic and
fish community data to assess biological integrity. Biological integrity means the ability of an aquatic
ecosystem to support and maintain a balanced and indigenous community of organisms having species
composition, diversity, population densities and functional organization similar to that of reference
conditions”
3.4 MS4 Interconnection
The City of Newton MS4 is not interconnected with another regulated MS4 and directly discharges to the
receiving waters as listed in Table 2 above.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 6
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) Stormwater
Waste
Load
Allocation
(Y/N)
Water
Quality
Recovery
Program
(Y/N)
Statewide Mercury N N
The Statewide TMDL for Mercury does not require any actions by the NPDES stormwater permittees
because most mercury in stormwater comes from atmospheric deposition.
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are identified within the
regulated MS4 urbanized area, as determined by 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. 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: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing
Status
Haliaeetus leucocephalus Bald eagle Vertebrate BGPA
Hexastylis naniflora Dwarf-flowered
heartleaf
Invertebrate vascular
plant
T
BGPA – Bald and Golden Eagle Protection Act
T- Threatened
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 7
3.7 Industrial Facility Discharges
The City of Newton MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater
Permit List and/or Active Stormwater Permits Map.
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCG020883 Catawba Clay Mine
NCG030314 Special Metals Welding Products Company
NCG030394 Commercial Fabricators Incorporated
NCG030535 Z.F. Chassis Components, LLC
NCG030626 ArcelorMittal Piedmont
NCG030642 GKN Driveline Newton LLC
NCG030686 Corning Optical Communications, LLC - Newton Cable
Annex
NCG050047 Newton Division
NCG050175 International Paper-Newton Container Plant
NCG060158 Renwood Mills, LLC
NCG060298 Flowers Baking Company of Newton, LLC
NCG060307 Target Corp
NCG080399 SunBelt Furniture Xpress LLC
NCG080669 Newton City - Public Works Complex
NCG080868 FedEx Freight, Inc - HKY
NCG110033 Clark Creek WWTP
NCG120001 Catawba County Landfill
NCG180016 Lee Industries Incorporated-Catawba
NCG180213 Lee Industries Incorporated-Plant #3
NCG210384 Industrial Recycling Services
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Newton as
summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The City of Newton has evaluated residential and charity car washing
for possible significant water quality impacts. Street cleaning is performed with a dry street sweeping
process so street washing discharges are not relevant to the MS4.
The Division has not required that other non-stormwater flows be specifically controlled by the City of
Newton.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 8
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 Newton to determine whether they may
significantly impact water quality. They were determined to be a possible cause of water quality impacts
and will be addressed through public education efforts (See BMP No. 5).
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 N/A
Flows from firefighting activities Incidental
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the City of Newton is not aware of other significant
water quality issues within the permitted MS4 area.
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. In addition, the City of Newton has evaluated schools, homeowners and
businesses as target audiences that are likely to have significant stormwater impacts. The schools were
selected as a target audience due to the opportunity to affect positive change through education and
involvement opportunities. Homeowners and businesses were identified as target audiences because they
are likely sources of non-point pollution through poor management practices.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 9
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 Residential, commercial, schools Public Education & Outreach, Public
Involvement & Participation
Yard Waste (leaves and
grass clippings)
Residential, commercial Public Education & Outreach, Pollution
Prevention & Good Housekeeping
Sediment Construction Construction Site Runoff Control
Nutrients Sewer overflows, failing septic systems,
urbanization, schools
Public Education & Outreach, Illicit
Discharge Detection & Elimination,
Construction Site Runoff Control, Post-
Construction Site Runoff Control,
Pollution Prevention & Good
Housekeeping
Fecal coliform Sewer overflows, failing septic systems,
wildlife, illicit discharges
Public Education & Outreach, Illicit
Discharge Detection & Elimination
Mercury/statewide
TMDL
Atmospheric deposition Public Education & Outreach (fish
consumption advisory)
Illicit discharges Residential, commercial, industrial,
municipal staff
Public Education & Outreach, Illicit
Discharge Detection & Elimination,
Illegal dumping Residential, commercial, industrial,
municipal staff
Public Education & Outreach, Pollution
Prevention & Good Housekeeping
Improper disposal of
waste
Residential, commercial, industrial,
municipal staff
Public Education & Outreach, Public
Involvement & Participation, Pollution
Prevention & Good Housekeeping
General non-point
source pollution
Residential, commercial, schools,
municipal staff
Public Education & Outreach
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 10
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The City of Newton stormwater program is implemented in partnership by primarily the Planning and
Public Works departments. The Planning department is responsible for the public outreach and
involvement components, as well as engineering plan reviews; while the Public Works department is
responsible for good housekeeping and municipal pollution prevention activities, storm sewer system
maintenance, and IDDE. The Assistant Planning Director is designated as the Stormwater Program
Administrator.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 11
Table 8: Summary of Responsible Parties
SWMP Component Responsible Position Staff Name Department
Stormwater Program
Administration
Assistant Planning
Director
Alex Fulbright Planning
SWMP Management Assistant Planning
Director
Alex Fulbright Planning
Public Education &
Outreach
Assistant Planning
Director
Alex Fulbright Planning
Public Involvement &
Participation
Assistant Planning
Director
Alex Fulbright Planning
Illicit Discharge
Detection &
Elimination
Assistant Public Works
Director
Dennis Falder Public Works
Construction Site
Runoff Control
Assistant Planning
Director
Alex Fulbright Planning
Post-Construction
Stormwater
Management
Assistant Planning
Director
Alex Fulbright Planning
Pollution
Prevention/Good
Housekeeping for
Municipal Operations
Assistant Public Works
Director
Dennis Falder Public Works
Municipal Facilities
Operation &
Maintenance Program
Assistant Public Works
Director
Dennis Falder Public Works
Spill Response Program Fire Chief Kevin Yoder Fire Department
MS4 Operation &
Maintenance Program
Assistant Public Works
Director
Dennis Falder Public Works
Municipal SCM
Operation &
Maintenance Program
Assistant Public Works
Director
Dennis Falder Public Works
Pesticide, Herbicide &
Fertilizer Management
Program
Assistant Public Works
Director
Dennis Falder Public Works
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 12
Vehicle & Equipment
Cleaning Program
Assistant Public Works
Director
Dennis Falder Public Works
Pavement Management
Program
Assistant Public Works
Director
Dennis Falder Public Works
Total Maximum Daily
Load (TMDL)
Requirements
Assistant Planning
Director
Alex Fulbright Planning
4.2 Program Funding and Budget
In accordance with the issued permit, the City of Newton shall 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.
The stormwater program currently receives funding of approximately $750,000 per year; this is funded
primarily through general funds. However, the Assistant Public Works Director and Utilities Director
positions are funded through the Public Works Enterprise fund. In total the program receives 2 full-time
equivalent staff for pavement management (1 full time street sweeper position and a leaf collection crew
seasonally (13 weeks)) and less than 0.5 dedicated full-time equivalent staff for other program
components.
The program is currently under-funded to conduct all the proactive elements of the permit. Further fiscal
analysis and investigation of funding options (such as additional general fund allocation or a stormwater
fee) will be conducted as indicated in BMP No. 3 in order to fully fund the program by permit year three.
4.3 Shared Responsibility
The City of Newton will share the responsibility to implement the following minimum control measures,
which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The City of
Newton remains responsible for compliance if the other entity fails to perform the permit obligation and
may be subject to enforcement action if neither the City of Newton nor the other entity fully performs the
permit obligation. Table 9 below summarizes who will be implementing the component, what the
component program is called, the specific SWMP BMP or permit requirement that is being met by the
shared responsibility and whether or not a legal agreement to share responsibility is in place.
Table 9: Shared Responsibilities
SWMP BMP or
Permit Reference Implementing Entity & Program Name
Legal
Agreement
(Y/N)
3.2 Outreach to Targeted
Audiences,
3.3.2 Volunteer Opportunities
Western Piedmont Council of Governments
(See BMPs No. 4 and 15)
N
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 13
4.4 Co-Permittees
The are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000397 for the City of Newton. Table 10 summarizes contact information for each co-permittee.
Table 10: Co-Permittee Contact Information
Co-Permittee MS4
Name
Contact Person Phone & E-Mail Interlocal
Agreement
(Y/N)
N/A
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 14
4.5 Measurable Goals for Program Administration
The City of Newton 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 for Permit
years 1 – 4
(FY19/20 – FY22/23)
1. Annual Self-
Assessment received by
NCDEQ no later than
August 31 each year.
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
submit a permit renewal application
package.
1. Participate in an
NPDES MS4 Permit
Compliance Audit, as
scheduled and performed
by EPA or NCDEQ.
1. TBD – Typically
Permit year 4
1. N/A
2. Self-audit and
document any
stormwater program
components not audited
by EPA or NCDEQ
utilizing the DEQ Audit
Template.
2. Permit year 5 2. Submit Self-Audit to
DEMLR (required
component of permit
renewal application
package).
3. Certify and submit the
stormwater permit
renewal application
(NOI, Self-Audit, and
Draft SWMP for the next
5-year permit cycle).
3. Permit year 5 3. Permit renewal
application package
received by DEQ at least
180 days prior to permit
expiration.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 15
Table 11: Program Administration BMPs
Permit
Ref. 2.1.1: Adequate Funding and Staffing
The permittee shall maintain adequate funding and staffing to implement and manage the provisions of the
SWMP and meet all requirements of this permit
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
3. Adequate funding
Perform a fiscal analysis and explore
options to obtain adequate program
funding to fully fund the stormwater
program and meet all requirements of
the permit. Select and implement a
funding strategy for the Phase II
Stormwater Program.
1. Complete a fiscal gap
analysis
1. Permit Year 1
1. Report monetary value
of gap
2. Determine available
funding mechanisms and
evaluate options
2. Permit Year 1 2. Completed? -
yes/no/status
3. Select a funding
mechanism
3.Permit Year 1 3.Report funding
mechanism selected
4. Implement funding
plan
4. Permit Year 2 4. Implemented? -
yes/no/status
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 16
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Newton 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
Newton 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 Residential, commercial, schools
Yard Waste Residential, commercial, municipal staff
Sediment Construction
Nutrients Residential, commercial, schools
Fecal coliform Residential, commercial, schools
Mercury/statewide TMDL Residential, commercial
Illicit discharges Residential, commercial, industrial, municipal staff
Illegal dumping Residential, commercial, industrial, municipal staff
Improper disposal of waste Residential, commercial, industrial, municipal staff
General non-point source pollution Residential, commercial, schools, municipal staff
Two existing city events, the Arbor Day Celebration held by the Parks and Recreation Department and
Newton 101 Citizen’s Academy for residents and business owners, will be used as a platform for
stormwater outreach and education. The City will also develop a stormwater web page and use social
media to reach younger generations and signage on City owned SCMs to reach stakeholders at the site of
stormwater management. Additionally, the City of Newton plans to partner with the Western Piedmont
Council of Governments to more efficiently implement education and outreach activities. The City of
Newton will manage, implement and report the following public education and outreach BMPs.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 17
Table 13: Public Education and Outreach BMPs
Permit
Ref. 3.2: 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 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
4. Partnership with Western Piedmont Council of Governments
The City will engage with the
Western Piedmont Council of
Governments (WPCOG) to develop
Education and Outreach Initiatives
that will be administered by
WPCOG. Initiatives will focus on
residential, commercial, and school
audiences within the MS4 area.
1. Arrange partnership
with Western Piedmont
Council of Governments.
1. Permit year 1. 1. Report date and terms
of partnership when
established.
2. Monitor WPCOG
activities to ensure
partnership commitments
are met
2. Annually, following
establishment of
partnership
2. yes/no/status
5. City Sponsored Event or Festival
The City will distribute information
on stormwater during at least one
City sponsored event or festival a
year such as the Arbor Day
celebration, Folk Art Festival, or
Soldiers Reunion.
1. Develop or identify
one informational
handout for distribution
at the event that covers
litter, nutrients, and non-
point source pollution
(including car washing).
1. Permit year 3 1. Is handout developed
or identified? -
yes/no/status
2. Train municipal staff
to man a stormwater
booth during the event
and distribute the above-
mentioned flyers as well
as information about
leaky septic systems,
illicit
discharges/improper
disposal of waste.
2. Permit year 3 2. Report the number of
staff members trained
3. Man a booth at the one
event/festival chosen and
document the number of
handouts distributed.
3. Permit year 3, and
annually thereafter.
3. Report the chosen
event and number of
handouts distributed at
event
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 18
Table 13: Public Education and Outreach BMPs
6. Newton 101 Citizen’s Academy
Information on Newton’s stormwater
program will be shared during
Newton 101 Citizen’s Academy, a
program that tours all city
departments once a year.
1. Train municipal staff
to include stormwater
program information
during Newton 101
Citizen’s Academy.
1. Permit year 3 1. Report the number of
staff members trained
2. Present on stormwater
program during Newton
101 Citizen’s Academy
2. Permit year 3 2. Report the number of
participants
7. Social Media Campaign
The City’s social media accounts will
be used to share information related
to stormwater issues, with a
minimum of one post per year.
1. Post about keeping
yard waste and litter out
of storm drains.
1. Permit year 1 1. Report the date of the
post.
2. Post about reducing
fertilizer runoff.
2. Permit year 2 2. Report the date of the
post.
3. Post about car
washing.
3. Permit year 3 3. Report the date of the
post.
4. Post about illicit
discharge/illegal
dumping.
4. Permit year 4 4. Report the date of the
post.
5. Post about stopping
vehicle leaks.
5. Permit year 5 5. Report the date of the
post.
8. Add Signage to City-Owned Stormwater Control Measures (SCMs)
Educational signage will be added to
City-owned SCMs that are accessible
by the public.
1. Locate City-Owned
SCMs and add them to
the inventory (See BMP
No. 34).
1. See BMP No. 16 1. See BMP No. 16
2. Develop educational
signage that describes the
use and function of
SCMs, notes the
stormwater hotline, and
website.
2. Permit year 3 2. Report the number of
signs developed.
3. Add signage to
accessible SCMs.
3. Permit year 3/4 3. Report the number of
signs installed.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 19
Table 13: Public Education and Outreach BMPs
Permit
Ref. 2.1.7 and 3.2.3: Web Site
Measures to provide a web site designed to convey the program’s message 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
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
9. Stormwater Page on City Website
The web page will provide
information on the City’s stormwater
program, including the permit,
SWMP, applicable ordinances, and
annual reports. The web page will
also include a stormwater issue
reporting mechanism, educational
materials developed by the city, and
links to additional stormwater
educational resources. The web page
will also serve to advertise the
stormwater hotline, Newton 101
Citizen’s Academy, and opportunities
for involvement.
1. Establish the
stormwater web page.
1. Permit year 1 1. Report the date the
web page goes live, link
to webpage
2. Maintain the webpage
- update any broken
links, upload new
educational material,
upload most recent
SWMP.
2. Annually, once
established
2. Report the date the
web page is reviewed
and updated as well as
what updates are made.
3. Establish and train a
responsible party to
answer stormwater
reporting mechanism.
3. Permit year 1 3. Report the date of
training, and the dates
any additional staff are
trained.
4. Set a hit counter in
order to monitor
engagement.
4. Annually, once web
page is established
4. Report the number of
hits.
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
10. Stormwater Hotline
A hotline will be maintained for
citizens to ask stormwater questions
and report stormwater issues.
1. Establish hotline
phone number and
responsible party
1. Permit year 3 1. Report the date the
hotline is established.
2. Train responsible
individual(s) in general
stormwater knowledge,
appropriate contacts to
direct requests and
further questions to, and
citizen opportunities
within the stormwater
program.
2. Permit year 3 2. Report the date of
training, and the dates
any additional staff are
trained.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 20
Table 13: Public Education and Outreach BMPs
3. Publicize hotline by
including in materials
developed for the
stormwater program and
posting on stormwater
web page
3. Permit year 3 3. yes/no/status
4. Establish a tracking
mechanism to document
the number and type of
calls received.
4. Permit year 3 4. Report the number and
type of calls.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 21
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 planning commission will continue to function as the city’s stormwater advisory board with the
additional provision of a stormwater liaison to highlight stormwater issues. A stormwater hotline and a
stormwater issue reporting mechanism on the webpage will be used to collect public input. The City will
continue to coordinate with the city wide clean up event to provide a volunteer opportunity to prevent
litter from entering the stormwater system.
The City of Newton 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
11. Planning Commission
City Staff will bring stormwater
issues before the planning
commission to receive citizen input
and factor stormwater into
development decisions.
1. Have a bi-annual
agenda item for City
staff to report on
stormwater concerns and
receive input from the
commission.
1. Bi-Annually,
beginning in Permit Year
1
1. Date of meetings and
stormwater topic(s)
discussed
12. Stormwater Hotline
A hotline will be maintained for
citizens to ask stormwater questions
and report stormwater issues. (See
BMP No. 10)
1. See BMP No. 10 1. See BMP No. 10 1. See BMP No. 10
13. Stormwater Page on City Website
The web page will provide links to
information on the City’s stormwater
program, including the permit,
SWMP, applicable ordinances, and
annual reports. The web page will
also include a stormwater issue
reporting mechanism, educational
materials developed by the city, and
links to additional stormwater
educational resources. The web page
will also serve to advertise the
stormwater hotline, Newton 101
Citizen’s Academy, and opportunities
for involvement. (See BMP No. 9)
1. See BMP No. 9 1. See BMP No. 9
1. See BMP No. 9
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 22
Table 14: Public Involvement and Participation BMPs
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
14. Annual City-Wide Clean-Up Event
As part of the annual City-wide
clean-up event, organize volunteers
to pick up trash or clean litter from
public areas with potential to pollute
stormwater.
1. Identify public areas
that could be cleaned by
volunteers.
1. Permit year 1 1.Potential areas
identified? –
yes/no/status
2. Coordinate clean-up of
public areas.
2. Annually 2. Report the number of
participants.
15. Partnership with Western Piedmont Council of Governments
The City will engage with the
Western Piedmont Council of
Governments (WPCOG) to develop
Volunteer Opportunities that will be
administered by WPCOG.
Opportunities will focus on
residential, commercial, and school
audiences within the MS4 area.
1. Arrange partnership
with Western Piedmont
Council of Governments.
1. See BMP No. 4 1. See BMP No. 4
2. Monitor WPCOG
activities to ensure
partnership commitments
are being met.
2. See BMP No. 4 2. See BMP No. 4
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 23
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The City of Newton 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. The existing Illicit Discharge Detection and Elimination Program plan
will be revised and expanded in order to implement a complete program by permit year 5.
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
16. Addition of Major Outfalls to MS4 Map
The MS4 map will be completed and
outfalls will be identified and
numbered, and flow directions and
receiving waters will be added.
1. Add a major outfalls
layer to the map and
number.
1. Permit year 3. 1. Report when map is
completed.
2. Add flow directions to
the map.
2. Permit year 3. 2. Report when map is
completed.
3. Add receiving waters
to the map.
3. Permit year 3. 3. Report when map is
completed.
17. Continual Updates to MS4 Map
The MS4 map will be continuously
updated for completeness.
1. When new
conveyances and outfalls
are located or
constructed add them to
the map.
1. Annually, once BMP
No. 16 is completed.
1. Report whether or not
new outfalls were
identified and if so, how
many.
18. Identify City-Owned SCMs
City-owned SCMs will be identified
and added to the MS4 map. Type will
be noted.
1. Locate City-Owned
SCMs and add them to
the MS4 Map with type
of SCM indicated.
1. Permit year 1 1. Report the number and
type of SCMs added to
the map.
2. Update the map when
new City-owned SCMs
are constructed.
2. Annually, once BMP
No. 18.1 is completed.
2. Note annually whether
new City-owned SCMs
were added.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 24
Table 15: Illicit Discharge Detection and Elimination BMPs
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
19. Maintain Legal Authority
Review existing ordinance (Code of
Ordinances, Chapter 87, Article VI. –
Illicit Discharges) in order to
maintain the legal authority to
prohibit, detect, and eliminate illicit
connections and discharges, illegal
dumping and spills into the MS4,
including enforcement procedures
and actions. Update ordinance if
required.
1. Review ordinance and
update if revision is
required to maintain
legal authority
1. Annually 1. Report if a revision is
required and if a revision
is made.
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
20. Outfall Inspections
Perform regular dry weather (no rain
in previous 72 hours) outfall
inspections to proactively identify
illicit discharges and illicit
connections.
1. Train staff to perform
dry weather outfall
inspections as part of
BMP No. 24
1. See BMP No. 24 1. See BMP No. 24
2. Split major outfalls
into five equal groups for
inspection; so that with
one group inspected per
year, all major outfalls
will be inspected over a
five year period.
2. Permit Year 3, in
conjunction with MS4
Map Update (BMP No.
16).
2. yes/no/status
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 25
Table 15: Illicit Discharge Detection and Elimination BMPs
3. Inspect one group (See
BMP No. 20.2) of
outfalls annually in dry
weather conditions and
document any potential
violations using the
forms and procedure
developed in BMP No.
23
3. Annually, beginning in
Permit Year 4
3. Number of outfalls
inspected and number of
potential Illicit
Discharges identified.
21. Illicit Discharge Identification Procedure
A standard operating procedure for
investigation of potential illicit
discharges, illicit connections, and
illegal dumping.
1. Revise the Illicit
Discharge Detection and
Elimination program
from the previous
SWMP to develop a
standard operating
procedure to follow
when investigating
potential illicit
discharges and
connections.
1. Permit Year 1 1. Completed? -
yes/no/status
22. IDDE Program Evaluation
Yearly evaluation of IDDE program
to promote continuance of effective
components and improvement in
areas that are lacking, as well as,
identification of potential “hot-spot”
areas.
1. Evaluation meeting
with IDDE program
stakeholders; to include
at least Stormwater
Administrator and
Utilities Director.
1. Annually, in
conjunction with SWMP
assessment
1. Report any proposed
changes
2. Review of IDDE
reports and identification
of chronic violators
and/or “hot-spot” areas.
2. Annually, in
conjunction with SWMP
assessment
2. Report any priority
areas identified
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
23. Database Tracking System
A tracking system for observed IDDE
violations and follow on actions will
be developed and implemented in
order to identify “hot-spot” areas and
chronic violators. (To be used for
BMP No. 20 - outfall inspections)
1. Develop a “Potential
Illicit Discharge Report”
form to include observed
illicit discharge
indicators, date, location,
and contacts made.
1. Permit Year 1 1. yes/no/status
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 26
Table 15: Illicit Discharge Detection and Elimination BMPs
2. Develop a tracking
spreadsheet to collect
data from “Potential
Illicit Discharge Report”
as well as, the results of
the investigation, any
follow-up, date of
closure, and enforcement
actions taken.
2. Permit Year 1 2. yes/no/status
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 come into contact with or otherwise observe an illicit discharge, illicit connection or
illegal dumping. Training shall include identifying and reporting illicit discharges, illicit connections and
illegal dumping. 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
24. Staff Training
Develop a program to educate City
staff of indicators of potential illicit
discharges/connections and illegal
dumping and the appropriate avenues
through which to report suspected
illicit discharge. (See BMP No. 20
SOPs by which to train staff)
1. Identify or develop
staff training program for
public works employees.
1. Permit year 3 1. yes/no/status
2. Train staff with Illicit
Discharge & Detection
responsibilities.
2. Permit year 3 2. Report topics, training
date, and number of
attendees.
3. Train new staff that
will be part of the IDDE
program.
3. Permit year 4 and
annually thereafter
3. Report topics, training
date, and number of
attendees
25. Fact Sheets
Hang fact sheet posters in employee
common areas and serve as a
reminder of the basics on identifying
and reporting illicit discharges,
connections, and dumping.
1. Identify or develop
illicit discharge fact sheet
posters to display.
1. Permit Year 3 1. yes/no/status
2.Display posters in
employee common areas.
2. Annually, beginning in
permit year 3
2. number of posters
hung
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 27
Table 15: Illicit Discharge Detection and Elimination BMPs
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
26. Stormwater Hotline
A hotline will be maintained for
citizens to ask stormwater questions
and report stormwater issues. (See
BMP No. 10)
1. See BMP No. 10 1. See BMP No. 10 1. See BMP No. 10
27. Stormwater Page on City Website
The web page will provide links to
information on the City’s stormwater
program, including the permit,
SWMP, applicable ordinances, and
annual reports. The web page will
also include a stormwater issue
reporting mechanism, educational
materials developed by the city, and
links to additional stormwater
educational resources. The web page
will also serve to advertise the
stormwater hotline, Newton 101
Citizen’s Academy, and opportunities
for involvement. (See BMP No. 9)
1. See BMP No. 9 1. See BMP No. 9
1. See BMP No. 9
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 28
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of Newton relies upon the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 and the NCG010000 permit for construction
activities as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all
construction site runoff control measures to reduce 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.
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
Permit
Reference State or Local Program Name Legal
Authority Implementing Entity
Meets Whole
or Part of
Requirement
3.5.1 -
3.5.4
Catawba County
Delegated SPCA Program*
15A NCAC
Chapter 04
Catawba County Whole
2 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at:
https://library.municode.com/nc/catawba_county/codes/code_of_ordinances?nodeId=COOR_CH31SO
ERSECO
In addition to the delegated SPCA Program, opportunities for public input through the stormwater hotline
and additional waste management requirements for construction site operators complete the construction
site run off control program. The City of Newton 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
28. Municipal Staff Training
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 1. Report number of staff
trained, training date(s)
and topics covered.
29. Stormwater Hotline
A hotline will be maintained for
citizens to ask stormwater questions
and report stormwater issues (See
BMP No. 10).
1. See BMP No. 10 1. See BMP No. 10 1. See BMP No. 10
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 29
Table 17: Construction Site Runoff Control BMPs
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
30. Establish and Maintain Legal Authority
Develop and implement an ordinance
to require construction site operators
to control waste.
1. Pass code 1. Permit year 1 1. yes/no/status
2. Maintain legal
authority
2. Continuously, after
ordinance is adopted
2. yes/no
31. Contractor Education
Communicate materials to
construction site operators regarding
new waste management requirement.
1. Identify/develop fact
sheet to share at pre-
construction meetings.
1. Permit year 1, after
code has passed
1. yes/no/status
2. Add fact sheet to
website
2. Permit year 1, after
code has passed
2. yes/no/status
2. Distribute fact sheet
at pre-construction
meetings
2. Permit year 1, after
code has passed
2. Number of fact sheets
distributed
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 30
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 Newton 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 Newton 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
None N/A N/A
2
The City of Newton has existing requirements other than Qualifying Alternative Program(s) for
implementation of the NPDES Phase II MS4 post-construction program requirements. These existing
requirements are codified in local ordinance(s), and implementation is further defined in guidance,
manuals and/or standard operating procedure(s) as summarized in Table 19 below.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 31
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 City of Newton Code of Ordinances -
Chapter 87
6-19-
2007(effective
July 1,2007)
3.6.3(a) & 15A NCAC 02H.0153(c)
Federal, State & Local Projects
City of Newton Code of Ordinances -
Chapter 87-5
6-19-2007
3.6.3(b) Plan Review City of Newton Code of Ordinances -
Chapter 87
6-19-2007
3.6.3(c) O&M Agreement City of Newton Code of Ordinances -
Chapter 87-24 a
6-19-2007
3.6.3(d) O&M Plan
3.6.3(e) Deed
Restrictions/Covenants
City of Newton Code of Ordinances -
Chapter 87-18 c, 87 -19f
6-19-2007
3.6.3(f) Access Easements City of Newton Code of Ordinances -
Chapter 87-30
6-19-2007
Permit Requirements for
Inspections and Enforcement
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.2(b) Documentation City of Newton Code of Ordinances -
Chapter 87-28?
6-19-2007
3.6.2(c) Right of Entry City of Newton Code of Ordinances -
Chapter 87-24 a, 87-24 b 5, 87-25
6-19-2007
3.6.4(a) Pre-CO Inspections City of Newton Code of Ordinances -
Chapter 87-14 d
6-19-2007
3.6.4(b) Compliance with Plans City of Newton Code of Ordinances -
Chapter 87-14 c
6-19-2007
3.6.4(c) Annual SCM Inspections City of Newton Code of Ordinances -
Chapter 87-23.b
6-19-2007
3.6.4(d) Low Density Inspections
3.6.4(e) Qualified Professional City of Newton Code of Ordinances -
Chapter 87-23 b
6-19-2007
Permit Requirements for
Fecal Coliform Reduction
Municipal Ordinance/Code Reference(s)
and/or Document Title(s)
Date Adopted
3.6.6(a) Pet Waste City of Newton Code of Ordinances –
Chapter 14 –Sec. 14-101 (7)
9-18-2002
3.6.6(b) On-Site Domestic
Wastewater Treatment
Catawba County Code of Ordinances –
Chapter 16, Article IV
1995 Code
Catawba County Environmental Health
Application, Evaluation, and Permitting
Procedures For Septic Systems and Well
Construction
July 1, 2005
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 32
The City of Newton will first establish the legal authority to require O&M Plans and perform post
construction inspection of low density sites. Then they will exercise that authority through the
enforcement, inspection, and documentation of the full post construction program. 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. 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
32. Standard Reporting
Implement standardized tracking,
documentation, inspections and
reporting mechanisms to compile
appropriate data for the annual self-
assessment process. Data shall be
provided for each Post-Construction/
Qualifying Alternative Program
being implemented as listed in Tables
18 and 19. (See BMP No. 36)
1. Track number of low
density and high density
plan reviews performed.
1. Continuously 1. Number of plan
reviews performed for
low density and high
density.
2. Track number of low
density and high density
plans approved.
2. Continuously 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,
following establishment
of inventory
3. Summary of number
and type of SCMs added
to the inventory and in
total; and number and
acreage of low density
projects constructed and
in total.
4. Track number of SCM
inspections performed.
4. Continuously,
beginning in permit year
3
4. Number of SCM
inspections.
5. Track number of low
density inspections
performed.
5. Continuously,
beginning in permit year
3
5. Number of low density
inspections.
6. Track number and
type of enforcement
actions taken.
6. Continuously 6. Number and type of
enforcement actions
taken.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 33
Table 20: Post Construction Site Runoff Control BMPs
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
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
33. O&M Plan
Addition of an ordinance to the City
code requiring each stormwater
control measure to have an Operation
and Maintenance Plan that complies
with 15A NCAC 02H .1050(13)
1. Establish legal
authority through code
revision
1. Permit year 2 1. Report code reference
and date adopted
2. Enforcement of new
code by requiring
approval of O&M Plan
by Stormwater
Administrator prior to
plan approval.
2. Continuously after
ordinance passes.
2. Number of O&M
Plans received
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 34
Table 20: Post Construction Site Runoff Control BMPs
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
34. Inspection of low density projects
Establishing legal authority for
inspection of low density projects at
least once during the permit term; and
carrying out the inspections.
1. Establish legal
authority through code
revision.
1. Permit year 2 1. Report code reference
and date adopted.
2. Conduct inspection of
low density projects (See
BMP No. 32.5)
2. See BMP No. 32.5 2. See BMP No. 32.5
Permit
Ref. 3.6.5: Documentation
Measures to maintain adequate documentation and standardized inspection and tracking mechanisms to: (a)
Maintain an inventory of post-construction SCMs and low density projects, (b) Document, track and maintain
records of inspections and enforcement actions. Tracking shall include the ability to identify chronic violators,
and (c) Make available to developers all relevant ordinances, 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
35. Inventory of post-construction SCMs and low density projects
A comprehensive inventory of post-
construction SCMs and low density
projects to be utilized for inspections
and tracking.
1. Establish list of
existing structural SCMs
and low density projects
1. Permit year 1/2 1. Number of SCMs and
low density projects
inventoried
2. Issue letter of
notification to owners
making them aware of
upcoming inspections
2. Permit year 2 2. yes/no/status
3. Add SCMs and low
density projects to
inventory list when
project as-builts are
approved
3. See BMP No. 32 3. See BMP No. 32
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 35
Table 20: Post Construction Site Runoff Control BMPs
36. Inspection Tracking
Tracking the results of regular post-
construction SCM and low density
inspections to provide documentation
and the ability to identify chronic
violators.
1. Establish inspection
tracking mechanism to
meet all requirements of
BMP No. 32 (Permit
4.1.3)
1. Permit year 2 1. yes/no/status
2. Continually update 2.Continually, beginning
in permit year 3
2. yes/no/status
37. Developer Resources
Establish a developer stormwater
resources section on the city website
so relevant materials are easily
accessible for developers.
1. Upload links to
ordinances, post
construction
requirements, link to
design standards, and
other relevant material to
website.
1. Permit year 1, in
conjunction with
stormwater website
development
1. yes/no/status, link to
webpage
2. Update when changes
to resources occur
2. Continuously 2. Report date of updates
and changes made
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
This permit requirement is fully met by the existing post-construction program, see references provided in Table 19
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 36
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of Newton 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 park 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 Cleaning Program
7. Pavement Management Program
Currently, spill response procedures are handled by the Fire Department and all other components of the
pollution prevention and good housekeeping measures are implemented by the Public Works Department.
The City already provides street sweeping and leaf collection services to residents but will begin to
quantify and monitor for assessment. Initially an inventory of municipal facilities will be completed to
serve as a basis for developing the program and creating documentation for inspections. The City of
Newton will manage, implement and report the pollution prevention and good housekeeping BMPs as
specified in Table 21 below for each required program.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 37
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.
BMP
No.
A B C D
Description of BMP Measurable Goal(s) Schedule for
Implementation
Annual Reporting
Metric
38. Inventory of Municipal Facilities
Maintain an up-to-date inventory of
municipal facilities with potential to
generate polluted runoff.
1. Compile list of
existing city-owned
properties and inspect
facilities for potential to
generate polluted runoff,
requiring spill response
procedures, or SPCC.
Create an inventory of
facilities with polluted
runoff potential, an
inventory of facilities
requiring spill response,
and subject to SPCC.
1. Permit Year 3 1. Number of facilities
inventoried
2. Identify areas of
priority at each facility
inventoried.
2. Permit Year 3 2. yes/no/status
3. Update inventory as
needed.
3. As Required 3. Number of facilities
added/revisions made
39. Facility Inspections
Inspection of City facilities to
confirm good housekeeping practices
are being followed, including Vehicle
and Equipment Cleaning (See BMP
No. 50) and that the City Public
Works Complex is in compliance
with Industrial Stormwater Permit
NCG080669.
1. Establish a standard
operating procedure for
city facility inspections,
including an inspection
schedule, inspection
report documentation,
and tracking system
1. Permit Year 2 1. yes/no/status
2. Implement annual
facility inspections
following SOP
established in BMP No.
40.1
2. Annually conduct
inspections beginning in
Permit Year 3
2. Number of inspections
performed
40. Staff Training
Develop or identify a staff training
program for general stormwater
pollution prevention and provide to
public works department employees
(See BMP No. 44)
1. See BMP No. 44 1. See BMP No. 44 1. See BMP No. 44
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 38
Table 21: Pollution Prevention and Good Housekeeping BMPs
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
41. Inventory of facilities with Spill potential
Maintain a list of city facilities and
operations storing materials that
would be a pollutant if spilled and
introduced to the stormwater system
and classify by hazard and quantity.
(Also See BMP No. 39).
1. Update list of city
facilities and operations
with spill potential when
facilities or operations
are changed.
1. When necessitated by
changes in facilities or
operations
1. Number of additions
or revisions.
42. Spill Response Procedures
Maintain spill response procedures
and continue training of appropriate
staff.
1. Review general spill
response procedures.
1. Permit year 1 1. Are procedures
adequate? – yes/no/status
2. Review specific spill
response procedures for
City facilities and
operations with potential
to produce high hazard
spills.
2. Permit year 1 2. Are procedures
adequate? – yes/no/status
3. Update as facilities
and operations are
revised.
3. As required 3. Number of additions
or revisions made
4. Train new fire
department staff in spill
response procedures.
4. As required 4. Number of new staff
trained.
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
43. Staff Training
Develop or identify a staff training
program for general stormwater
pollution prevention and provide to
public works department employees
1. Develop or identify
appropriate training
program
1. Permit year 2 1. yes/no/status
2.Provide initial training
for all employees
2.Permit year 3 and once
per permit cycle later
2. Number of staff
members trained and
topics from training
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 39
Table 21: Pollution Prevention and Good Housekeeping BMPs
3.Provide training for
new hires
3.Annually beginning in
permit year 4, as
necessitated by staffing
changes
3. Number of new hires
trained and topics from
training
44. MS4 System Inspections and Maintenance
A proactive plan for MS4 system
maintenance, requiring regular
inspections and maintenance.
1. Develop a SOP that
includes proactive
inspection schedules,
standard documentation,
staff responsibilities, and
proper maintenance
training.
1. Permit year 2 1. yes/no/status
2. Perform regular
inspections in
accordance with the
SOP.
2. Following schedule
established in SOP, once
SOP (See BMPs No.
45.1 and 45.4) is
established
2. Number of inspections
documented
3. Verify, document, and
prioritize maintenance
activities identified by
inspections or citizen
reports.
3. Continually, as
potential maintenance
activities are identified
3. Number of
maintenance activities
performed
4. Develop an inspection
and maintenance
tracking system to be
used in accordance with
the SOP and to identify
“hot spot” locations for
system maintenance
4. Permit year 2 4. yes/no/status
Permit
Ref.
3.7.4: Municipal SCM Operation and Maintenance Program
Measures to manage municipally-owned, operated, and/or maintained structural 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
45. Inventory of Municipal structural SCMs
Development and maintenance of a
current inventory of municipally
owned structural SCMs.
1. Create an inventory of
existing municipal SCMs
with information
including type, date of
last inspection, and
maintenance actions.
1. Permit year 1 1. Number of municipal
structural SCMs
2. Compile, and develop
as needed, Operation and
Maintenance Plans for all
municipal SCMs
2. Permit year 2 2. Yes/No/Status
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 40
Table 21: Pollution Prevention and Good Housekeeping BMPs
3. Update as necessitated
by new City
development
3. As required 3. Number of updates to
list
46. SCM Inspections and Maintenance
Performance and documentation of
regular inspection and maintenance
of municipally owned structural
SCMs.
1. Maintain NC SCM
Inspections and
Maintenance
Certification for
appropriate personnel
1. Permit Year 2 and
continuously thereafter
1. Number of staff
members with
certification
2. Develop SCM
inspection form
2. Permit year 2 2. Yes/No/Status
3. Inspect using SCM
inspection form
3. Annually, beginning in
permit year 3
3. Number of SCMs
inspected, number
passing inspection,
number requiring
maintenance
4. Perform maintenance
tasks identified in
inspections
4. As needed 4. Number of SCMs
maintained
5. Develop a tracking
document (See BMP No.
46).
5. Permit year 2 5. Yes/No/Status
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
47. Pesticide, Herbicide, Fertilizer Applicator Training
Training of City staff who apply
landscape chemicals in order to
minimize water quality impacts from
pesticides, herbicides, and fertilizers.
1. Maintain Right-of-
Way Pest Control, Public
Health Control, and
Ornamental & Turf Pest
Control applicator
certifications for
appropriate personnel.
1. Continuously 1. Yes/No
2. Develop or identify
pollution prevention and
chemical use, storage
and handling training
program
2. Permit year 2 2. Yes/No/Status
3. Provide staff training
in pollution prevention
and chemical use,
storage and handling
training
3. Yearly, Permit years
3-5
3. Number of Staff
Trained and topics
covered.
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
Page 41
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
Ref.
3.7.6: Vehicle and Equipment Cleaning 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
48. NPDES Industrial Permit Compliance
Ensure that NPDES industrial permit
compliance occurs at all applicable
municipally owned sites.
1. Review municipal
facilities list to determine
for which facilities a
NPDES industrial permit
is required.
1. Permit year 1 1. Number of facilities
determined to require a
NPDES Industrial Permit
2. Permitting of
municipally owned
facilities, apply for new
permits and confirm that
all existing permits are
valid.
2. Permit year 1,
following review of
facilities
2. Report number of new
permits received or
renewed
3. Permit renewal 3. As required 3.Report number of
active permits
4. Facility inspections for
compliance with permit
4. Annually 4. Number of inspections
performed
5. Establish NPDES
Industrial Permit
tracking mechanism to
document list of
municipally owned
facilities with permit,
permit expiration dates,
and inspections.
5. Permit year 1 5.yes/no/status
49. Vehicle and Equipment Cleaning and Maintenance Facility Inspection
Routine inspections as part of general
facility inspections (See BMP No.
40) to ensure that vehicle and
equipment facilities are following
proper procedures to minimize water
quality impacts from vehicle and
equipment cleaning and maintenance.
1. Develop an inspection
checklist
1. Permit Year 2 1. yes/no/status
2. Perform inspections
using inspection
checklist and notify
facility manager of any
corrective actions
required
2. Bi-annually, beginning
in permit year 3
2. Number of inspections
50. Staff Training
Provide pollution prevention training
relating to vehicle and equipment
cleaning and maintenance
1. Identify or develop a
training program for
staff.
1. Permit Year 2 1. yes/no/status
2. Provide staff training 2. Annually, Permit
Years 3-5
2. Number of attendees
and topics covered
DRAFT NCS000397 SWMP
City of Newton
August 19, 2019
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
51. Street Sweeping
Street sweeping following a regular
schedule in order to reduce pollutants
from City owned and maintained
streets.
1. Develop a standard
operating procedure,
including a schedule and
plan to document.
1. Permit Year 2 1. yes/no/status
2. Implement SOP and
documentation
2. Annually, beginning in
Permit Year 3
2. Total number of street
miles swept
52. Leaf Collection
Periodic collection of leaves from
residential and public areas to reduce
pollutants and clogging of storm
system inlets.
1. Develop a standard
operating procedure,
including a schedule and
plan to document.
1. Permit Year 2 1. yes/no/status
2. Implement SOP and
documentation.
2. Regularly, beginning
in Permit Year 3
2. Volume of leaves
collected (tons)
53. Vehicle Spill Cleanup
An organized vehicle spill cleanup
response to prevent pollutants from
vehicular accidents from entering the
storm drain system.
1. Maintain spill
response procedures (See
BMP No. 43)
1. See BMP No. 43 1. See BMP No. 43
2. Public education about
stopping vehicle leaks
(See BMP No. 7.5)
2. See BMP No. 7.5 2. See BMP No. 7.5