NCS000431_Conover Draft SWMP v1_20200223

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STORMWATER MANAGEMENT PLAN
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N P D ES N CS000431
February 23, 2020
Prepared by:
VVKA�AG
Planning & Transporation

Table of Contents
PART 1: INTRODUCTION
PART 2: CERTIFICATION
1
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................................................................................................................6
3.5
Total Maximum Daily Loads(TMDLs).................................................................................... 6
3.6
Endangered and Threatened Species and Critical Habitat.......................................................... 7
3.7
Industrial Facility Discharges................................................................................................... 7
3.8
Non-Stormwater Discharges..................................................................................................... 8
3.9
Target Pollutants and Sources................................................................................................... 9
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION.................................12
4.1 Organizational Structure.........................................................................................................12
4.2 Program Funding and Budget.................................................................................................14
4.3 Shared Responsibility............................................................................................................. 15
4.4 Co-Permittees........................................................................................................................ 16
4.5 Measurable Goals for Program Administration....................................................................... 16
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ......................................... 24
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ............................ 27
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................. 37
PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ...................................... 40
PART 10:POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 49

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

PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of
Conover 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 Conover 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 NCS000488, 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 Conover and located within the corporate limits of the City of Conover.
In preparing this SWMP, the City of Conover 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 NCS000431 SWMP
City of Conover
February 23, 2020
Page 1

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 prhicipal 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:
nald Du an
Title:
City Manager
Signed this =day of February 2020.
DRAFTNCS000431 SWMP
City of Conover
February 23, 2020
Page 2

PART 3: MS4 INFORMATION
3.1 Permitted MS4 Area
This Stormwater Management Plan (SWMP) applies throughout the corporate limits of the City of Conover, including all
regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits
of City of Conover as of the date of this document.
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DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 3

3.2 Existing MS4 Mapping
The current MS4 mapping includes outfalls located within the City of Conover. In the future, the City will be adding the
following elements to the map: stormwater conveyances, flow directions, and receiving streams. This is addressed in
development, funding, and maintenance in Permit Reference 3.4.1 BMP 19.
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The City of Conover has a historic count of 153 outfalls per the GIS layer created; however it is not certain that all of
these are major per the definition provided below. The City will be verifying all elements, as mentioned above, in the
completion of BMP 19.13.1 addresses the verification of the existing data, and BMP 19.13.3-4 addresses the updating of the
existing map, as well as, adding additional infrastructure as it comes in.
Table 1: Summary of MS4 Mapping
Percent of MS4 Area Mapped
50
%
No. of Major Outfalls* Mapped
153
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 meetpermit 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.
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City of Conover
February 23, 2020
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3.3 Receiving Waters
The City of Conover 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 May
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303 d List
Table 2: Summary of MS4 Receiving Waters
Stream
Water
303(d) Listed Parameter(s)
Receiving Water Name
Index / AU
Quality
Number
Classification
of Interest
Clark Creek
13-17-4
C
N/A
Cline Creek
11-129-5-2
C
N/A
Conover Branch
1 1-129-5-2-
C
N/A
Hildebran Creek
11-129-5-3
C
N/A
Long Creek
1120- 1-
WS-Iv
N/A
(
Lyle Creek
11-76-(0.5)
C
N/A
McLin Creek
176-5- 1-
C
N/A
(
Miller Branch
11-129-5-1
C
N/A
Mull Creek
11-76-4
WS-Iv
N/A
Mahaffie Branch
11-76-2
C
N/A
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City of Conover
February 23, 2020
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3.4 MS4 Interconnection
The City of Conover MS4 is not interconnected with another regulated 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. Outreach
education and stream cleanup helps with the reduction of waste load allocation with approved TMDL municipalities.
Table 3: Summary of Approved TMDLs
Water Body Name
TMDL Pollutant
Stormwater
Water
Waste
Quality
Load
Recovery
Allocation
Program
Y/N)
Y/N)
Statewide
Mercury
N
N
Clark Creek
Fecal coliform
Y
N
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City of Conover
February 23, 2020
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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
Bald and Golden
Ea le Protection Act
Glyptemys muhlenbergii
Bog turtle
Vertebrate
Threatened due to
similarity in
appearance
Glaucomys sabrinus
Carolina northern
Vertebrate
Endangered
coloratus
flying squirrel
Myotis septentrionalis
Northern long-eared
Vertebrate
Threatened
bat
Alasmidonta varicosa
Carolina hemlock
Vascular Plant
At riskspecies
Hexastylis naniflora
Dwarf -flowered
Vascular Plant
Threatened
heartleaf
Helianthus schweinitzii
Schweinitz's
Vascular Plant
Endangered
sunflower
3.7 Industrial Facility Discharges
The City of Conover 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
NCG030105
Prodelin Corp -Conover
NCG050072
Carpenter Co - Conover
NCG050101
Armacell LLC-Conover Plant
NCG050190
Elite Comfort Solutions
NCG050327
Pregis PolyMask
NCG030673
Hickory Springs Manufacturing -Conover Complex
NCG030680
General Dynamics Mission Systems SATCOM
NCG050402
WestRock Converting Company
NCG080976
Old Dominion Freight Line Inc - HKY
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City of Conover
February 23, 2020
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NCG080428
PJF Southeast, LLC
NCG080285
Zenith Freight Lines LLC
NCG100036
Schronce Used Parts and Cars Inc.
NCG080304
UPS Ground Freight, Inc. -Conover
NCG080911
XPO Logistics Freight, Inc. - NHN
NCG080318
Wilson Trucking Corp -Conover
NCG080428
PJF Southeast, LLC
NCG110145
Northeast WWTP
NCG130044
Republic Services of NC, LLC-GDS-Conover-MRF
NCG160003
J.T. Russell & Sons, Inc.
NCG210330
Tradewinds International Inc
NCG210147
Terra Mulch Products LLC
NCG180012
Vanguard Furniture Co Incorporated
NCG180023
Craftwork Guild Plant
NCG180073
Classic Leather Incorporated
NCG180085
Craftwork Guild Plant
NCG180114
Southern Furniture Co -Plant 1
NCG180118
Southern Furniture Co -Plant 2
NCG180227
Kroehler Furniture Mfg Co Inc
TBD
City of Conover Public Works Facility
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Conover as summarized in
Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The
City of Conover has evaluated residential and charity car washing for possible significant water quality impacts. Street
cleaning is performed with dry street sweeping process; however construction sites occasionally with clean the streets
with potable water as directed by NCDOT and Erosion Control requirements.
The Division has not required that other non-stormwater flows be specifically controlled by the City of Conover.
Wash water associated with car washing that does not contain detergents/surfactants or does not discharge directly into the
MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents/surfactants
have been evaluated by the City of Conover to determine whether they may significantly impact water quality. The City
of Conover will address the possibility of the below mentioned water quality impacts through public education and good
housekeeping, as outlined in Part 5 BMP 3-8 and Part 10 BMP 45-47, 49, 52-54, 56, 57 and 61 with focusing on good
housekeeping training and practices.
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
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February 23, 2020
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Uncontaminated pumped groundwater
Incidental
Uncontaminated potable water sources
Incidental
Foundation drains
Incidental
Air conditioning condensate
Incidental
Irrigation waters
Incidental
Springs
Incidental
Water from crawls ace pumps
Incidental
Footing drains
Incidental
Lawn watering
Incidental
Residential and charity car washing
Possible
Flows from riparian habitats and wetlands
Incidental
De -chlorinated swimming pool discharges
Incidental
Street wash water
Possible
Flows from firefighting activities
Incidental
3.9 Target Pollutants and Sources
In addition to those target pollutants identified above, the City of Conover is aware of other significant water quality
issues within the permitted MS4 area. Target pollutants as listed below are contributors of the stream impairment. TMDL
measures have been put in place to improve water quality.
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 the target pollutants. In addition, the City of Conover has observed and evaluated: schools, homeowners,
businesses, industrial sites, farming, construction activities, and public employees as target audiences that are likely to
have significant stormwater impacts. Within the table and list below the following target pollutants have been found to be
concerns within the community.
Litter: Roadside litter is an ongoing issue for the City. This litter poses a threat to both our water bodies and the MS4
infrastructure, as the litter can create clogs and backups that damage the pipelines/conveyances that lead back to the
stream. Some litter even poses a threat to groundwater if chemical leaching or breakdown of components into heavy
metals occurs due to weathering of the litter. Most litter is found on the side of major roads, around school facilities, and
certain businesses.
Sediment: Sediment buildup is largely attributed to mismanaged construction sites with fallen or incorrectly installed
sediment fences. Erosion control fences failing or being improperly maintained. This has led to sediment buildup near
storm drains, onto down slope private properties, and in some cases causing water to build up in nearby properties as the
sediment is limiting the drains ability to remove runoff. In all cases the city has responded and had the issue solved, but
even being down for a short time can have significant effects. Erosion control fences are required for sediment control
permits during construction by the DEQ throughout the entire construction process.
Gray Water: In the past a few residents have been found with washing machines straight -piped out of their homes by
using water hoses exiting windows. Homes are to be connected to the appropriate sewer system. This proves to be a
source of detergents/soaps entering our storm drains in residential neighborhoods. In addition: residential, charity, and
municipal car washes allow for soaps or waxes to enter the storm drain when vehicles are not being cleaned in the correct
areas (such as vegetated patches or in areas that do not have storm drains). This allows for toxic contaminants to enter
waterways via the storm drain system.
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Fats Oils and Grease: Can become an issue when grease traps are not appropriately maintained. This has led to cases of
the restaurants allowing the grease to drip onto nearby impermeable surface — which would eventually lead to water
quality issues. Overflow from a lack of maintenance or throwing out the grease with general waste contributes to this
problem. This is a health violation since the grease poses a physical risk, but it also can impair water bodies with an influx
of water insoluble grease going down the storm drain. In all cases, code enforcement has responded and the issues have
been remedied.
Chemicals: Industrial sites housing totes/containers of unknown/unmarked chemicals can lead to potential soil and water
contamination, and/or incorrect spill cleanup procedure. Totes/containers are to be correctly stored in a way to minimize
risk to the water bodies from seepage, damage to the containers, or spills. Any reports Code enforcement has responded.
Animal Operations: agricultural runoff often caries excess fertilizer which will cause eutrophication in streams
with its cascading effects. Within the Catawba River Basin roughly 46 streams are/were impacted by fecal
coliform, with 10 being listed on the 303(d) list. As this is a non -point source pollutant it is hard to locate the
exact source of this runoff, however in much of the watershed there is agricultural zoning that makes it likely
for these types of impairments to occur. The City does allow Shetland horses (sub 125 lbs. and under 34 inches
at shoulder), which has a small potential for increasing nutrient load from horse waste.
Underground storage tanks: Storage devices installed below ground can contain gasoline, fuels such as propane,
industrial chemicals/oils, and most often human waste (fecal coliform) in areas not directly connected to the sanitary
sewer. Any underground storage tank must be well maintained/monitored, and correctly installed due to the risk of them
leaking. The leaks can cause whatever chemical the tank is storing to leak into the ground, harming the soil,
groundwater/water table, and even surface waters as they are being fed from groundwater. If a fuel or industrial chemical
tank is leaking, the chemical will leach into the soil — leading to toxic soil, contaminated groundwater, and possibly
impairing a stream/water body. Conover has worked with EPA Brownfield Assessment grants prior to determine the level
of contamination (if any) from former industrial sites.
Some areas of the City still have homes that utilize septic tanks, but the majority of properties in the City are served by
sanitary sewer. If a septic tank is leaking, it can overwhelm the natural processes of the soil (infiltration) leading to
nutrient overload in streams fed by groundwater, or allowing pathogens to enter, increasing the risk of disease. The 10
303(d) fecal coliform impaired streams listed can have some attribution to septic tank leakage. When septic tank failure is
noted, the home is required to connect to sanitary sewer where available.
Illicit discharges: Originate from a variety of sources, with an equally varied number of effects dependent on the
chemical that is released. Typically, illicit discharges come from businesses, residents or municipal facilities who dump
chemicals into storm drains either incidentally due to a lack of IDDE education or general carelessness. These chemicals
can vary greatly, and can include grease, oils, chemicals, cleaning solutions, paints, metals, etc. This is a recognized
problem as we have several 303(d) streams impaired from causes related to substances or attributions given to unclean
discharges into the streams - in addition to reports generated by the municipality. Many of the 303(d) benthos impaired
streams can be attributed to IDDE issues, but they are often from inexact/non-point sources that are attributed to illicit
discharges
Illegal dumping: Waste dumped randomly in non -permitted dumping areas, can cause a variety of problems. For
example, citizens dumping televisions on the side of the road to avoid dumping fees, which allows for the metals or
chemicals inside TVs to leach out as stormwater passes it (mercury, lead, and other metals). It can be a case of businesses
dumping waste in watershed areas where runoff passes through the waste, either carrying it, or residuals of the waste into
water bodies. It can also be a case of graders dumping sediment into areas without the correct allowances/precautions. The
debris and chemicals accumulate over time and lead to chemical impairments, pH issues, turbidity impairments, or debris
entering the stream/MS4 system. The City provides municipal residential solid waste pick-up weekly to all City residents.
DRAFT NCS000431 SWMP
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Improper disposal of waste: Allows chemicals, or difficult to manage waste, to enter the environment in ways that may
be hard to track. For example; not giving a car battery to the correct waste management facility can allow for battery acid
and lead to enter the soil which drains/collects in the groundwater. These types of problems have been noticed by
municipal waste managers and can be difficult to track since the improperly disposed waste is mixed in with the standard
refuse. Other examples include grease going down sinks clogging sanitary MS4 systems, chemicals from batteries
leaching into the groundwater, oil from oil changes not going to the correct facility, etc.
While some of the target audiences are not as prominently found within the City, it is still important to educate because
they can be likely sources of non -point pollution through uninformed management practices.
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
Residents, Businesses, Schools
Public Education & Outreach
Public Participation
Sediment
Construction Activity
Public Education & Outreach,
Construction Program
Post -construction Program
Fecal coliform
Sewer overflows, failing septic
Public Education & Outreach,
systems, wildlife, illicit discharge
Illicit Discharge
Gray water
Residential
Illicit Discharge
Public Education & Outreach
Fats, Oils and Grease
Businesses (Restaurants)
Illicit Discharge
Public Education & Outreach
Chemicals
Industrial, Business and Residential
Illicit Discharge
Public Education & Outreach
Good Housekeeping
Animal Operations
Urban Farming
Illicit Discharge
Public Education & Outreach
Underground Storage Tanks
Business and Residents
Illicit Discharge
Public Education & Outreach
Illicit Discharges
General Public, Businesses,
Illicit Discharge
Municipal Employees
Public Education & Outreach
Good Housekeeping
Illegal Dumping and
General Public, Businesses,
Illicit Discharge
Improper Disposal of Waste
Municipal Employees
Public Education & Outreach
Good Housekeeping
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
The City of Conover has contracted Western Piedmont Council of Governments (WPCOG) to coordinate Stormwater
Management Plan efforts, to ensure the City is facilitating Best Management Practices (BMPs) to protect water quality.
While WPCOG will be the primary operator of the program the City of Conover staff will be trained to handle internal
procedures and report action/s to WPCOG. The following organizational chart is broken down by the six elements
associated with Stormwater Management. Each of the positions under the elements will report back to the primary
manager and then on to the Stormwater Administrator.
Starmwater Program Administrator
(City Manager(
Starmwater 1Management (City Environmental
CoordinatorrwnstructiOn Manager and WPCOG
Senior Planner/Natural Resources Administrator(
Public Education I I Public Involvement I I I II -et Discharge Det—tion I Past Canstruction Site
and Outreach and Participation and Elimination Run-off Control
WPCOG Senior Planner/ WPCOG Senior Planner/ WPCOG Cade WPCOG
Natural Resources Natural Resources Compliance Stormwater
Administrator Administrator I I Enforcement Administrator
WPCOG Senior Planner/
Natural Resources
Administrator
(Ed ucato-r)
Table 8: Summary of Responsible Parties
Pollution Prevention/
Good House keep i ng for
Municipal Operations
WPCOG
Stormwater
Administrator (Municipal
Faci I ities Operation &
Maintenance Program -
Data Collect on and
Re pa rCng; TMDL
requirements)
WPCOG Senior Planner/
Natural Resources
Administrator (Good
House kee p i ng Ed ucator)
City Employees
■ MS49peration & Maintenance
■ Municipal SCM Operation and
Maintenance
■ Vehicle & Equipment Cleaning
■ Pavement Management
■ Pesticides, Herbicide & Fertilizer
Management
SWMP Component
Responsible Position
Staff Name
Department
Stormwater Program
City Manager
Donald Duncan
Administration, City of
Administration
Conover
Environmental Coordinator/
Terry Lail
Planning, City of
Construction Manager
Conover
SWMP Management
Environmental Coordinator/
Terry Lail
Planning, City of
Construction Manager
Conover
Senior Planner/Natural
Johnny Wear (support
Planning, WPCOG
Resources Administrator
contracted staff)
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Public Education &
Environmental Coordinator/
Terry Lail
Planning, City of
Outreach
Construction Manager
Conover
Senior Planner/Natural
Johnny Wear (support
Planning, WPCOG
Resources Administrator
contracted staff)
Public Involvement
Environmental Coordinator/
Terry Lail
Planning, City of
& Participation
Construction Manager
Conover
Senior Planner/Natural
Johnny Wear (support
Planning, WPCOG
Resources Administrator
contracted staff)
Illicit Discharge
Environmental Coordinator/
Terry Lail
Planning, City of
Detection &
Construction Manager
Conover
Elimination
Stormwater Administrator
Jack Cline (support
Planning, WPCOG
contracted staff)
Construction Site
Environmental
Terry Lail
City of Conover
Runoff Control
Coordinator/Construction
(See 4.3 for further
Manager
detail)
Erosion Control Manager
Varies — inspector
Catawba County
availability
Erosion Control Office
Post -Construction
Environmental Coordinator/
Terry Lail
Planning, City of
Stormwater
Construction Manager
Conover
Management
Stormwater Administrator
Jack Cline (support
Planning, WPCOG
contracted staff)
Pollution
Environmental Coordinator/
Terry Lail
Planning, City of
Prevention/Good
Construction Manager
Conover
Housekeeping for
Municipal Operations
Senior Planner/Natural
Johnny Wear (support
Planning, WPCOG
Resources Administrator
contracted staff)
Municipal Facilities
Environmental Coordinator/
Terry Lail
Planning, City of
Operation &
Construction Manager
Conover
Maintenance
Program
Director of Public Works
Jimmy Clark
Public Works, City of
Conover
Stormwater Administrator
Jack Cline (support
Planning, WPCOG
contracted staff)
Spill Response
Environmental Coordinator/
Terry Lail
Planning, City of
Program
Construction Manager
Conover
Fire Department Chief
Mark Hinson
Fire, City of Conover
Stormwater Administrator
Jack Cline (support
Planning, WPCOG
contracted staff)
MS4 Operation &
Environmental Coordinator/
Terry Lail
Planning, City of
Maintenance
Construction Manager
Conover
Program
Director of Public Works
Jimmy Clark
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 13

Public Works, City of
Conover
Stormwater Administrator
Jack Cline (support
contracted staff)
Planning, WPCOG
Municipal SCM
Environmental Coordinator/
Terry Lail
Planning, City of
Operation &
Construction Manager
Conover
Maintenance
Program
Director of Public Works
Jimmy Clark
Public Works, City of
Conover
Stormwater Administrator
Jack Cline (support
Planning, WPCOG
contracted staff)
Pesticide, Herbicide
Environmental Coordinator/
Terry Lail
Planning, City of
& Fertilizer
Construction Manager
Conover
Management
Program
Director of Public Works
Jimmy Clark
Public Works, City of
Conover
Vehicle & Equipment
Environmental Coordinator/
Terry Lail
Planning, City of
Cleaning Program
Construction Manager
Conover
Director of Public Works
Jimmy Clark
Public Works, City of
Conover
Pavement
Environmental Coordinator/
Terry Lail
Planning, City of
Management
Construction Manager
Conover
Program
Director of Public Works
Jimmy Clark
Public Works, City of
Conover
Total Maximum
Environmental Coordinator/
Terry Lail
Planning, City of
Daily Load (TMDL)
Construction Manager
Conover
Requirements
4.2 Program Funding and Budget
In accordance with the issued permit, the City of Conover 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 administration and compliance fee, which is billed by DEQ annually.
The City of Conover's Environmental Coordinator/Construction manager's salary one-third is covered by stormwater and
two-thirds by water and waste water fees. To help cover support expenses Public Works allocated 180,000 from General
Fund and Utility Monies. Leaf collection is complete by City Sanitation Staff and temporary contract workers. During the
non -leaf season Grounds oversees the litter sweep, with $21,500 allocated.
The City of Conover has a two-year contract (which will need to be modified, adopted, and signed every two years) with
Western Piedmont Council of Governments for the following support services: Public Education and Outreach Program,
Public Involvement and Participation Program, Illicit Discharge Detection and Elimination Program, Post -Construction
Site Runoff Control Program, and Pollution Prevention and Good Housekeeping Programs. The current contract amount
for the 2-year period (years 1 and 2 of the NPDES permit cycle) is $53,354.00 of general funds being used. The City will
be responsible for the cost of the annual NPDES permit renewal, which is to be paid to the state. Any fees charged to the
development community for BMP Inspections, Plan Review, and other associated fees will be used to help offset cost.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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The City may determine that stormwater utility fees should be implemented; these fees would be collected by the City
through utility bills.
Should the City of Conover choose not to renew the existing two-year contract, prior to the last month, a revision to the
existing NPDES permit and Stormwater Management Plan would need to occur. The City of Conover would be required
to renew the two-year contract, in years 2022 and 2024, to fully carry out the 5 year NPDES permit cycle.
4.3 Shared Responsibility
The City of Conover will be responsibility, with WPCOG (referred to as entity) providing support service, to implement
the following minimum control measures, which are as stringent as the corresponding NPDES MS4 Permit requirement.
The City of Conover remains responsible for compliance if the other entities fail to perform the permit obligation and both
may be subject to enforcement action, if neither the City of Conover, nor the other entities fully perform the permit
obligation. Table 9 below summarizes individual responsibilities for each program.
Table 9: Shared Responsibilities
SWMP BMP or
Implementing Entity & Program Name
Legal
Agreement
Permit Reference
Y/N)
General Requirements
WPCOG Stormwater Program Planning and Administration
Y
Public Education and
WPCOG Stormwater Program Planning and Administration
Y
Outreach Program
Public Involvement and
WPCOG Stormwater Program Planning and Administration
Y
Participation Program
Illicit Discharge Detection
WPCOG Stormwater Program Planning and Administration
Y
and Elimination Program
Construction Site Runoff
Catawba County Delegated SPCA Program
Y
Control Program
Post -Construction Site
WPCOG Stormwater Program Planning and Administration
Y
Runoff Control Program
Pollution Prevention and
WPCOG Stormwater Program Planning and Administration
Y
Good Housekeeping
Programs
Total Maximum Daily Load
WPCOG Stormwater Program Planning and Administration
Y
(TMDL)
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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4.4 Co-Permittees
There are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000431 for the
City of Conover.
4.5 Measurable Goals for Program Administration
In response to the DEQ MS4 Audit completed in 2018 for the City of Conover - Program Implementation, Documentation
& Assessment (II.A2, II.A.3, II.A.4, II.A.7, III.A., III.B., IV.B. ) the following changes are being implemented.
Per BMP 1 the SWMP will be reviewed on an annual basis to determine if any updates need to occur. All documents
associated to the Stormwater program will be accessible online, either via the City of Conover website or the Western
Piedmont Council of Governments Stormwater Partnership webpage (reference BMP 14 and 30). Documentation of all
actions related to stormwater activities (as mentioned below) will be recorded, so staff can track and evaluate the
effectiveness of each program component.
The City of Conover will manage and report the following Best Management Practices (BMPs) for the administration of
the Stormwater Management Program using Public Education & Outreach, Public Involvement & Participation, Illicit
Discharge Detection & Elimination, Post -Construction Site Runoff Control, and Pollution Prevention & Good
Housekeeping.
Table 11: Program Administration BMPs
Permit
2.1.2 and Part 4: Annual Self -Assessment
Ref.
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 eriod is the fiscal year (Jul 1 — June 30).
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
1.
Annual Self -Assessment
Perform an annual evaluation of
1.Prepare, certify, and
1. Annually for Permit
1. Annual Self-
SWMP implementation,
submit the Annual
Years 1 — 4
Assessment received
suitability of SWMP
Self -Assessment to
(FY19/20 — FY22/23)
by NCDEQ no later
commitments and any proposed
NCDEQ prior to
than August 31 each
changes to the SWMP utilizing
August 31 each year.
year.
the NCDEQ Annual Self -
Assessment Template.
Permit
1.6: Permit Renewal Application
Ref.
Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
2.
Permit Renewal Application
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City of Conover
February 23, 2020
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Table 11: Program Administration BMPs
Audit stormwater program
1. Participate in an
1. TBD — Typically
1. N/A
implementation for compliance
NPDES MS4 Permit
Permit Year 4
with the permit and approved
Compliance Audit, as
SWMP, and utilize the results to
scheduled and
FY22/23
prepare and submit a permit
performed by EPA or
renewal application package.
NCDEQ.
2. Self -audit and
2. Permit Year 5
2. Submit Self -Audit
document any
to DEMLR (required
stormwater program
FY23/24
component of permit
components not
renewal application
audited by EPA or
package).
NCDEQ utilizing the
DEQ Audit Template.
3. Certify and submit
3. Permit Year 5
3. Permit renewal
the stormwater permit
application package
renewal application
FY23/24
received by DEQ at
(NOI, Self -Audit, and
least 180 days prior to
Draft SWMP for the
permit expiration.
next 5-year permit
cycle).
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 17

PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Conover will implement a Public Education and Outreach Program to distribute educational materials to the
community or conduct equivalent outreach activities about the impacts of stormwater discharges into water bodies and
steps the public can take to reduce pollutants in stormwater 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 Conover is required to
inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper
disposal of waste. The City will take a proactive approach in reporting the amount and to whom is reached through public
education and outreach efforts.
Table 12: Summary of Target Pollutants & Audiences
Target Pollutants/Sources
Target Audience(s)
Litter
Residents, Businesses, Schools
Sediment
Construction Activity
Fecal Coliform
Residents, Businesses, Schools
Gray Water
Residents
Fats, Oils and Grease
Businesses (Restaurants)
Animal Operations
Bona fide farms/Urban Farming
Underground Storage Tanks
Businesses and Residents
Chemicals
Industrial, Business and Residents
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 Conover will manage, implement and report the following public education and outreach BMPs.
Table 13: Public Education and Outreach BMPs
Permit
3.2: Outreach to Targeted Audiences
Ref.
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
im lemented locally or through a cooperative agreement.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
3.
Stormwater Fliers
Stormwater fliers will be
1. Develop and
1. Permit Year 1
1-5. Document and
distributed to City residences,
distribute
report the topic and
municipal employees, businesses,
fliers to create
(FY19/20)
number of flyers
and industrial facilities through
stormwater
distributed at each
stormwater events, in government
awareness
event, and other
buildings, and during training and
around best
locations where flyers
educational opportunities. Five
practices.
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February 23, 2020
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Table 13: Public Education and Outreach BMPs
topics will be addressed over the
2. Develop and
2. Permit Year 2
were made available to
term of the permit; general
distribute
the public.
stormwater awarenessibest
fliers for illicit
(FY20/21)
practices, illicit discharges, illegal
discharges.
dumping, chemicals and proper
3. Develop and
3. Permit Year 3
disposal of waste.
distribute
fliers for
(FY21/22)
illegal
dumping.
4. Develop and
4. Permit Year 4
distribute
fliers for
(FY22/23)
chemical
awareness.
5. Develop and
5. Permit Year 5
distribute
fliers for
(FY23/24)
proper waste
disposal.
4.
Public Event Outreach
Provide stormwater educational
1. Staff will have a
1. Annually
1. Number of events
information to the general public
booth at community
held/attended;
at community events.
events to disperse
Permit Years 1-5
Number of attendees;
stormwater outreach
(FY19/20 — FY23/24)
Number of materials
materials through the
handed out.
use of interactive
educational games and
activities.
5.
Student/teacher outreach
Provide educational information
1. Staff will provide in
1. Annually
1. Number of classes
to students and teachers through
class instruction to 7th
provided;
classrooms, workshops, and
and/or 8th grade STEM
Permit Years 1-5
Number of students
hands-on activities related to
students.
(FY19/20 — FY23/24)
present.
stormwater BMPs.
2. Staff will conduct
2. Annually
2. Number of
stormwater related
workshops provided;
workshops with
Permit Years 1-5
Number of teachers
teachers.
(FY19/20 — FY23/24)
attending.
6.
Printed Materials
Staff will design new printed
1. Staff will create
1. Permit Year 1
1. Number of new
materials for target audiences to
printed material for
materials created for
aid stormwater education and will
local government
(FY19/20)
addressing illicit
distribute said materials once they
distribution addressing
discharge and
are designed/developed.
illicit discharge and
stormwater best
stormwater best
practices.
practices.
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February 23, 2020
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Table 13: Public Education and Outreach BMPs
2. Staff will distribute
2. Annually
2. Number of materials
printed materials at
distributed.
events, school
Permit Years 1-5
presentations, and
(FY19/20 — FY23/24)
have them on display
for public attainment
in Government
buildings. Digital
educational
information/
opportunities will also
be provided.
7.
Annual Water Quality Conference
Sponsor the Western Piedmont
1. Provide one
1. Annually
1. Number of
Council of Governments and
presentation about one
attendees;
Lenoir Rhyne University's
of the six NPDES
Permit Years 1-5
Stormwater topic/s
Annual Water Quality Conference
Minimum Control
(FY19/20 — FY23/24)
presented referencing
to provide outreach and public
Measures at each
the minimum control
participation. Staff will conduct
annual conference. A
measures.
the annual regional conference for
different MCM will be
continued education to local
presented on each year
government officials, staff,
educators, and the general public.
8.
Evaluate Pollutants Sources and Audiences
Evaluate the target pollutants,
1. Evaluate following
1. Annually
1- 2. Evaluate and
sources, and associated target
target pollutants:
document number of
audiences likely to have
litter, sediment, gray
Permit Years 1-5
current and new target
significant stormwater impacts
water, fats, oils,
(FY19/20 — FY23/24)
pollutants, sources,
and why they were selected.
grease, urban farming,
and audiences by
underground storage
identifying them in the
tanks, fecal coliform,
annual report and
chemicals, illicit
update the plan (when
discharges, illegal
necessary). This will
dumping and improper
be carried out by
disposal of waste.
WPCOG personnel by
tracking these
pollutants/relevant
audiences through GIS
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 13: Public Education and Outreach BMPs
2. Evaluate the
2. Annually
data and mapping
following target
tools.
audiences: residents,
Permit Years 1-5
businesses, schools,
(FY19/20 — FY23/24)
commercial, farms,
industrial,
development
community, general
public, and municipal
em to ees.
9.
Evaluate Public Education and Outreach BMPs.
Evaluate the successful
1. Administer a
1. Annually
1. Number of
components of outreach through
random survey to City
responses received to
interest and feedback.
residents, businesses,
Permit Years 1-5
determine if current
schools, commercial,
(FY19/20 — FY23/24)
efforts are beneficial to
farms, industrial,
the public education
development
and outreach program.
community, general
public, and municipal
employees.
Permit
2.1.7 and 3.2.3: Web Site
Ref.
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 a hority necessary to im lement and enforce the requirements of the permit
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
10.
Website
Maintain the already established
1. Maintain and update
1. Annually
1. Number of times
website designed to convey the
stormwater program
website material is
program's message. The City
information on the
Permit Years 1-5
updated per year; what
webpage will convey the
existing municipal
(FY19/20 — FY23/24)
changes were made.
importance of water quality and a
website.
link to the WPCOG Stormwater
2. WPCOG staff will
2. Annually, beginning
2. Number of times
Webpage will be placed on the
maintain and update
in Permit Year 2
website material is
City's website. The WPCOG
the regional
updated per year;
Stormwater Partnership webpage
stormwater websites;
Permit Years 2-5
Number of participants
will provide educational resource
by posting the MS4
(FY20/21 — FY23/24)
using the stormwater
links, compliant procedures,
Annual Self-
website, measured
stormwater regulations,
Assessment, verifying
through opening the
stormwater permit information
all links and contact
page link.
and good housekeeping
information are
information.
current/active, posting
the current year fliers
and resetting the view
counter.
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City of Conover
February 23, 2020
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Table 13: Public Education and Outreach BMPs
11.
Education Regarding Illicit Discharges
Provide educational information
1. Train municipal
1. Annually
1. Number of
to municipal employees,
employees in illicit
employees trained;
businesses, citizens, and schools
discharge detection
Permit Years 1-5
Number of trainings
about the hazards associated with
and elimination.
(FY19/20 — FY23/24)
held.
2. Distribute material
2. Annually
2. Amount of material
illicit discharges, illegal
dumping, and improper disposal
to target audiences
distributed to each
of waste.
(municipal employees,
Permit Years 1-5
group:
schools, businesses,
(FY19/20 — FY23/24)
Students
and citizens).
Municipal Employees
Businesses
Citizens.
3. Provide education
3. Continuous, upon
3. Number of
during enforcement
violation investigation.
corrective enforcement
process.
actions; number of
Permit Years 1-5
citizen interactions.
(FY19/20 — FY23/24)
Permit
3.2.5: Stormwater Hotline
Ref.
Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
12.
Hotline
Provide a stormwater
1. Establish a hotline
1. Permit Year 1
1. Yes or No; Phone
hotline/helpline for public
number for stormwater
number.
education and outreach.
complaints and
(FY19/20)
information.
Establish a
"standardized script of
questions" for the
hotline to make data
recording more
consistent
2. Identify specific
2. Permit Year 1
2. Yes or No; Staff
staff members who
name and position.
will serve as
(FY19/20)
stormwater education
and hotline contacts.
3. Record number and
3. Annually, after
3. Number of phone
type of complaints,
establishment of
calls received and the
concerns, and
stormwater hotline.
context of the call;
information related to
Type of call,
each call.
Permit Years 2-5
information provided
(FY20/21 — FY23/24)
during the call, date of
call, and location of
caller.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 13: Public Education and Outreach BMPs
4. Train stormwater
4. Annually, beginning
4. Document and
education and hotline
in Permit Year 1
report number of staff
contacts in general
trained, training dates,
stormwater awareness,
(FY19/20)
and topics covered.
complaint call
Number of updates to
protocols, and
hotlines questions
appropriate contacts
(script for
for referral or typical
standardization).
stormwater issues.
Update the
"standardized script" if
problems are found
after training
5. Publicize contact
5. Continuous from
5. Document and
information on the
date of first annual
report a summary of
City and WPCOG
training (see BMP
the number of
Stormwater
12.13.4. above) in
inquiries received, the
Partnership webpages.
Permit Year 1
general type of inquiry
(education, outreach,
(FY19/20)
complaint), and the
contact mechanism
used (phone, email,
web page, walk-in).
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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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 Conover's Planning Board will
continue to function as the City's stormwater/watershed advisory board. The WPCOG Water Resources Committee will
continue to offer a forum for public comment with input and representation from the City of Conover as a way to
represent their municipality/citizens in these meetings along with other municipalities. The Boards/Committee will also
help provide input and guidance on stormwater issues. The City has a community volunteer program to gain citizen
participation to complete stream clean-ups or litter sweeps. The City of Conover has an established hotline (main number
for the City Hall), but will now be directed to WPCOG stormwater hotline, as well as, the addition of a webpage reporting
form and survey/s, along with the use of the existing WPCOG Water Resource Committee to gather public input. All
events, programs, and public forums will be announced through social media and/or printed handouts. The City of
Conover will manage, implement, and report on the following public involvement and participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit
3.3.1: Public Input
Ref.
Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
13.
Hotline for Public Input
Provide mechanisms for public
1. Establish a direct
1. Permit Year 1
1. Number of calls
input on stormwater issues and
Stormwater Hotline for
received/issues
the stormwater program.
public input. Define
(FY 19/20)
reported.
who is in charge of the
hotline. Establish a
"standardized script of
questions" for the
hotline to make data
recording more
consistent.
2. Maintain the hotline
2. Continuously, once
2. Number of updates
for public input by
established in Year 1
to the hotlines
updating the
questions (script for
`standardized script'
Permit Years 2-5
standardization).
should problems or
(FY20/21 — FY23/24)
new concerns arise.
14.
Web based form reporting
Provide mechanisms for public
1. Establish a web
1. Permit Year 1
1. Tool established —
input via email format for
based email complaint/
Yes or No, status.
stormwater issues and the
reporting tool to be
(FY 19/20)
stormwater program.
housed on the regional
website.
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February 23, 2020
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Table 14: Public Involvement and Participation BMPs
2. Use the tool to log
2. Continuous,
2. Number of
and respond to
following the
questions asked via the
questions regarding the
establishment of the
tool; Number of
public involvement
tool in Permit Year 1.
responses provided by
program.
staff.
Permit Years 2-5
FY20/21 — FY23/24)
3. Maintain a web
3. Continuous,
3. Number of updates
based email
following the
completed to the web
complaint/reporting
establishment of
tool, and reason for
tool on the regional
Permit Year 1.
change.
website.
Permit Years 1-5
(FY19/20 — FY23/24)
15.
Social Media Outreach — Event Promotion
Create and use a social media
1. Establish social
1. Permit Year 1
1. Facebook, or other
page to promote stormwater
presence on (but not
page(s) created — Yes
events, projects, and programs.
limited to) Facebook
(FY 19/20)
or No, status.
The outreach tool will provide
to promote public
exposure to a large audience.
involvement and
participation related to
stormwater programs,
events, and projects.
2. Use both WPCOG
2. Continuous, after
2. Number and type of
and the City's social
Facebook and/or other
events, projects and
media presences to
pages are established
programs promoted.
promote stormwater
in Permit Year 1.
events, projects, and
programs to engage
Permit Years 1-5
public involvement.
(FY19/20 — FY23/24)
16.
Water Resources Committee
Provide mechanisms for public
1. Hold quarterly water
1. Quarterly meetings
1. Number of attendees
input and participation via
resource meetings,
at each meeting, topics
local/regional meetings on
open to the public, for
Permit Years 1-5
discussed, was any
stormwater issues and the
participation in
(FY19/20 — FY23/24)
public input
stormwater program.
discussion related to
given/represented.
water quality issues.
2. Hold an annual
2. Meet Annually
2. Number of attendees
Stormwater Advisory
at each meeting, topics
Board meeting, open
Permit Years 1-5
discussed, was any
to the public, for
(FY19/20 — FY23/24)
public input
participation in
given/represented.
discussion related to
stormwater issues.
17.
Public Survey and Evaluation
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 25

Table 14: Public Involvement and Participation BMPs
Provide mechanisms for public
1. Create and
1. Annually
1. Number of
input by creating a survey to
administer a survey to
invitations sent,
engage the public and gauge
be housed on the
Permit Years 1-5
surveys collected,
public interest in stormwater
regional stormwater
(FY19/20 — FY23/24)
percentage of response
issues and the stormwater
website once a year,
rate and number of
program
open to feedback for a
responses.
total of 4 weeks and
Completed analysis of
shared on both the
the data collected.
WPCOG and City's
social media
a es/websites.
Permit
3.3.2: Volunteer Opportunities
Ref.
Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
18.
Stream Cleanup/Litter Sweep
Provide volunteer opportunities
1. Hold litter cleanup
1. Annually
1. Number of
for ongoing citizen participation
efforts by engaging
events/participants;
through stream cleanup or litter
groups to conduct
Permit Years 1-5
Number of trash bags
sweep activities.
stream cleanup or litter
(FY19/20 — FY23/24)
filled.
sweep activities in
appropriate areas. The
events will be
promoted by the City
and WPCOG, with a
focus towards civic
groups.
2. Provide all materials
2. Annually
2. Number of materials
for litter cleanup
distributed.
activities (i.e. gloves,
Permit Years 1-5
trash bags, and trash
(FY19/20 — FY23/24)
pickers) hosted by City
and WPCOG.
3. The City and
3. Annually
3. Number of
WPCOG will market
attendees;
the event (hosted by
Permit Years 1-5
Number of social
WPCOG) to the public
(FY19/20 — FY23/24)
media tags and shares;
to obtain volunteers
Number of materials
for litter cleanup
distributed/mailed
efforts to assist in
public awareness and
involvement with the
event.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
Per the MS4 Inspection Report the City has written procedures for implementing an IDDE Program. To increase efforts
the City will locate priority areas likely to have illicit discharges, conduct routine dry weather outfall inspections, identify
illicit discharges and trace sources, eliminate the source(s) of an illicit discharge, and evaluate and assess the IDDE
Program.
The City has a stormwater ordinance and other regulatory mechanisms that provide the legal authority to prohibit illicit
connections and discharges to the MS4, as well as the authority to apply enforcement to violators of the ordinance. The
documents will be reviewed, and if necessary, updated to maintain the program and enforce IDDE issues effectively.
The City of Conover has approximately half of the MS4 mapping completed; however as development occurs the map
and associated components will be updated accordingly.
In the last permit cycle the City did not conduct dry weather screening or maintain written procedures for dry weather
field activity (II.D.2.d. Dry Weather Flow Program). Within the Stormwater Management Plan a schedule is to be created
to conduct dry weather screening annually. Data such as date screening occurred, location of inspected outfall, and photos
of outfall will be recorded in GIS.
The City of Conover in the past has investigated IDDE complaints; however there is no tracking mechanism for
documenting violations and enforcement actions (II.D.2.j.). Within the new permit cycle, the use of a GIS application to
track and document IDDE cases will be used. This will allow the City to identify priority areas based on historical data.
Further, the City will continue to train municipal staff and the general public to identify illicit discharges and illegal
dumping through the use of educational outreach materials and training opportunities. Educational material will be
available to help educate public employees, businesses, and the general public about hazards associated with illicit
discharges and the improper disposal of waste.
Public complaints of any kind could be submitted to the City through point contact on the webpage. A webpage portal
will be established on the WPCOG website, as well as, linked to on the City website. The portal will be publicized, as
well as, the stormwater hotline phone number, as mentioned in the public education and outreach and public involvement
sections of this plan. A citizen can make a complaint via hotline number or through an email tool on the WPCOG
webpage.
The City of Conover 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 will be expanded in order to implement a complete
program by permit year 5.
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.1: MS4 Map
Ref.
Measures to develop, update and maintain a municipal storm sewer system map including
stormwater
conveyances, flow direction, major tfalls and waters of the United States receiving stormwater discharges.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
19.
MS4 Map
DRAFT NCS000431 SWMP
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
Update and maintain a municipal
1. Verify accuracy of
1. Permit Year 1
1. Number of
storm sewer system map
existing GIS map/data
(FY 19/20)
corrections needed.
including stormwater
by comparing current
conveyances, flow direction,
data to field located
major outfalls and waters of the
major outfalls.
2. Locate funding
2. Permit Year 2
2. Funding source was
United States receiving
stormwater discharges.
source (such as, but
(FY 20/21)
located: Yes or No;
not limited to grants,
status.
fees, and fundraisers)
for mapping the MS4
area.
3. Update existing map
3. Semi-annually
3. Number of updates;
to include open
approximately 33.3%
channels, storm drain
Permit Years 3-5
of MS4 mapping
information, flow
(FY21/22 - FY23/24)
completed each year
direction,
(miles of pipe, type of
conveyances, and
pipe, number of
major outfalls. This
SCMs, number of
data will be collected
outfalls, flow direction
with a mixture of
located, number of
preexisting GIS data
conveyances mapped,
(following its
were receiving bodies
validation), as well as,
located/marked) Yes
field work based off of
or No.
the City Utilities and
Planning Departments
recommendation and
known information.
4. Add new
4. Annually
4. Number of new
infrastructure to map
outfalls, inlets, MS4
as new construction
Permit Years 1-5
pipes and SCMs were
occurs.
(FY19/20 — FY23/24)
installed.
Permit
3.4.2: Regulatory Mechanism
Ref.
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,
includin enforcement procedures and actions.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
20.
Ordinance Adoption
1. Update and adopt an
1. Permit Year 1
1. Yes or No, status
updated Illicit
summary;
Discharge and
(FY19/20)
Date ordinance
Elimination ordinance.
adopted.
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
Municipality will adopt and apply
2. Train staff (field and
2. Permit Year 1
2. Number of staff
the IDDE ordinance that provides
office) in illicit
trained; record of
legal authority to prohibit, detect,
discharge detection
(FY 19/20)
staff s name, date,
and eliminate illicit connections
and elimination
position, and
and discharges, illegal dumping
procedures and
responsibilities.
and spills into the MS4 -
enforcement actions.
3. Enforcement of the
3. Continuous,
3. Number of
including enforcement procedures
and actions.
IDDE ordinance to
following the adoption
incidences reported;
prohibit, detect, and
of the updated IDDE
Number of incidences
eliminate illicit
Ordinance.
resolved, Number still
connections,
in progress of
discharges, illegal
Permit Years 1-5
abatement at time of
dumping and spills in
(FY19/20 — FY23/24)
annual report.
to the MS4.
Permit
3.4.3: IDDE Plan
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
21.
IDDE Plan Establishment and Revisions
Establish, maintain, and
1. Develop a written
1. Permit Year 1
1. Yes or No, status
implement a written IDDE Plan to
IDDE Plan to define
summary; date draft
detect and address illicit
the process of mapping
(FY 19/20)
plan is developed.
discharges, illegal dumping and
the MS4 (permit
any non-stormwater discharges
reference 3.4.1 MS4
Submit IDDE Plan to
identified as significant
Map), identifying,
DEQ for approval.
contributors of pollutants to the
tracking and
MS4.
processing illicit
discharges, illegal
dumping, and other
significant contributors
of pollutants to the
MS4.
2. Train staff on the
2. Permit Year 1
2. Number of
processes defined in
employees trained,
the IDDE Plan
(FY 19/20)
date of training, and
reference 21.B.1.)
position of employee.
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City of Conover
February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
3. Adopt the IDDE
3. Permit Year 1
3. Yes or No, status
Plan
summary;
(FY 19/20)
Date procedures
adopted.
4. Implement/Enforce
4. Permit Years 2-5
4. Number of IDDE
the adopted IDDE Plan
complaints resolved
(FY 20/21 — 23/24)
5. Maintain and assess
5. Permit Year 5
5. Yes or No; Date
the IDDE Plan based
plan reviewed and
on reporting metrics
(FY23/24)
findings; Number of
from previous year's
changes needed.
findings.
22.
Location of Priority Areas
Establish and maintain procedures
1. Use MS4 map to
1. As BMP 19 is being
1. Number and
to locate priority areas likely to
locate outfalls near
completed, priority
location of each
have illicit discharges.
high pollution risk
areas will be
priority area
areas (based on tax
established.
determined.
office data outlining
land classification for
Continuous,
weighting of the risk
Permit Years 1-5
areas). To establish
(FY19/20 — FY23/24)
high priority areas.
23.
Dry Weather Outfall
Inspections
Establish procedure to conduct
1. Establish a
1. Permit Year 1
1. Yes or No, Status
routine dry weather outfall
procedure for using a
summary, Schedule.
inspections.
GIS application and
(FY19/20)
create a schedule for
dry weather outfall
inspections.
2. Implement
2. Quarterly,
2. Date inspections
procedure established
occurred, location of
under BMP 23.13.1
Permit Years 1-5
inspected outfall, and
(FYI 9/20 — FY23/24)
photos of outfall.
24.
Illicit Discharges and Trace Sources
Establish procedures to track and
1. Establish procedures
1. Permit Year 1
1. Was the tracking
document illicit discharge
to identify illicit
document established
investigations.
discharges and trace
(FY19/20)
Yes or No; Status.
sources.
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
2. Maintain tracking
2. Continuous,
2. The date(s) the
documentation that
following
illicit discharges were
follows the procedures
establishment in Year
observed, the results of
listed in Permit
1.
the investigation,
reference 3.4.3 BMP
follow-up
24.13.1.
Permit Years 1-5
documentation and the
(FY19/20 — FY23/24)
date the investigation
was closed.
25.
IDDE Plan Enforcement and
Documentation
Maintain and implement the
1. Assess the local
1. Continuous, after
1. Provide status
IDDE Plan to detect and address
priority areas likely to
plan is established in
summary; number of
illicit discharges, illegal dumping
have illicit discharges.
Permit Year 1.
priority areas (location
and any non-stormwater
and/or use)
discharges identified as
Permit Years 1-5
determined.
significant contributors of
(FY19/20 — FY23/24)
2. Conduct routine dry
2. Continuous, after
2. Number of outfalls
pollutants to the MS4.
weather outfall
plan is established in
inspected.
inspections — with the
Permit Year 1.
goal of inspecting all
outfalls over the 5 year
Permit Years 1-5
permit period.
(FY19/20 — FY23/24)
3. Identify illicit
3. Continuous, after
3. Number of illicit
discharges and trace
plan is established in
discharges and non -
sources.
Permit Year 1.
illicit discharges
identified.
Permit Years 1-5
(FY19/20 — FY23/24)
4. Eliminate the
4. Continuous, after
4. Number of
sources of illicit
plan is established in
corrective actions
discharge.
Permit Year 1.
completed.
Permit Years 1-5
(FY19/20 — FY23/24)
5. Evaluate and assess
5. Annually
5. Number of
the IDDE program —
recommended
Identify where
Permit Years 1-5
improvements to
improvement can be
(FY19/20 — FY23/24)
achieve best
made based on
management practices.
statistical data
collected. Update the
Changes must be
IDDE plan should the
approved by DEQ
evaluation find issues
from the previously
within the program
approved IDDE Plan.
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City of Conover
February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
Permit
3.4.4: IDDE Tracking
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
26.
IDDE Tracking
Staff will create a mechanism for
1. Establish a GIS
1. Permit Year 1
1. Yes or No, status
tracking and documenting the
database application
summary;
date(s) an illicit discharge, illicit
for tracking illicit
(FY 19/20)
Date application
connection or illegal dumping
discharge connections
created.
was observed, the results of the
and illegal dumping,
investigation, any follow-up of
outlining who made
the investigation, the date the
the complaint, location
investigation was closed, the
of complaint, note
issuance of enforcement actions,
prior offenses, status
and the ability to identify chronic
and action taken.
violators will be recorded.
2. Track illicit
2. Continuous,
2. Number of issues
discharges/connections
following
reported by staff,
and illegal dumping
establishment in
Number of issues
incidents with the GIS
Permit Year 1.
reported by citizens;
tool (Permit reference
Summary of findings.
3.4.4 BMP 18.13.1.)
Permit Years 1-5
Differentiate staff
(FY19/20 — FY23/24)
discovery from citizen
reporting to allow for
review of outreach
program.
3. Upon investigation
3. Continuous,
3. Number of
correct Illicit
following
corrective actions
Discharge/connection
establishment in
taken, documentation
and Illegal Dumping.
Permit Year 1.
of violations.
Permit Years 1-5
FY19/20 — FY23/24)
4. Establish and
4. Continuous,
4. Number of chronic
maintain a list of
following
violators identified.
chronic violators, as
establishment in
applicable
Permit Year 1.
Permit Years 1-5
(FY19/20 — FY23/24)
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Table 15: Illicit Discharge Detection and Elimination BMPs
5. Evaluate and assess
5. Continuous,
5. Number of
the IDDE tracking
following
recommended
application and
establishment in Year
improvement to
program — Identify
1.
achieve best
where improvement
management practices.
can be made based on
Permit Years 2-5
statistical data
(FY20/21 — FY23/24)
collected, problems
encountered and
needs.
Permit
3.4.5: Staff IDDE Training
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
27.
Staff Training
Train municipal staff and
1. Identify staff
1. Annually
1. Number of
contractors to identify and report
members and
employees (contractors
illicit discharges, illicit
contractors that are
Permit Years 1-5
included) identified.
connections, illegal dumping and
likely to observe illicit
(FY19/20 — FY23/24)
spills.
discharges, illicit
connections, and/or
illegal dumping.
2. Hold IDDE training
2. Annually
2. Number of
events to educate staff
events/personnel
and contractors in
Permit Years 1-5
trained; provide
identifying and
(FY19/20 — FY23/24)
specific
reporting illicit
agenda/materials, date
discharges, illicit
and staff.
connections, illegal
dumping ands ills.
28.
IDDE Educator
Establish appropriate staff
1. Identify specific
1. Permit Year 1
1. Document specific
contacts to field inquiries
staff
staff positions.
regarding IDDE education,
members/positions
(FY19/20)
outreach and complaints. This
who will serve as
individual will be contactable
IDDE education and
through an IDDE hotline that will
hotline contacts.
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
educate the caller on issues that
2. Train IDDE
2. Annually, beginning
2. Document and
pertain to illicit discharges.
education and hotline
Permit Year 1
report number of staff
contacts in IDDE
(position) trained,
awareness, complaint
Permit Years 1-5
training dates, and
call protocols, and
(FY19/20 — FY23/24)
topic covered.
appropriate contacts
for referral.
3. Publicize through
3. Continuous, from
3. Document and
social media and City
date of first annual
report a summary of
and WPCOG
training (see BMP
the number of
webpages contact
28.B.2) in Permit Year
inquiries received, the
information about
1
general type of inquiry
IDDE reporting.
(educational outreach
(FY19/20)
or complaint), and the
contact mechanism
(phone, email,
web a e, walk-in).
Permit
3.4.6: IDDE Reporting
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
29.
IDDE Reporting Hotline
Provide a hotline for the public
1. Create a hotline for
1. Permit Year 1
1. Yes or No, status
and municipal employees to
reporting IDDE
summary; date
report illicit discharges, illegal
concerns. Designate
(FY19/20)
application created; list
dumping, and spills.
which staff are in
of staff charged with
charge of resolving the
resolving the reported
issue reported via the
issues.
hotline. Develop a
standard script to
enable consistent
record keeping.
2. Train hotline staff to
2. Continuous, after
2. Were staff trained —
differentiate between
hotline is established.
Yes or No, status;
illicit discharge
Names of trained staff
complaints and
Permit Years 1-5
in list format.
stormwater
(FY19/20 — FY23/24)
complaints. The staff
will also be trained to
keep adequate records
of the calls for metrics.
DRAFT NCS000431 SWMP
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
3. Maintain the hotline
3. Semi-annually
3. Number of phone
as a mechanism for
calls received.
reporting by updating
Permit Years 1-5
the standard script
(FY19/20 — FY23/24)
with problems
recognized by hotline
—employees.
4. Publicize Hotline by
4. Continuous,
4. Amount of materials
including the number
following the
distributed; Number of
in all educational
establishment of the
shares, likes,
materials distributed.
hotline.
comments, reviews
Share the hotlines
and responses on
number on the City
Permit Years 1-5
relevant social media.
and WPCOG websites
(FY19/20 — FY23/24)
and social media
accounts.
30.
IDDE Reporting Web -based Reporting Form
Staff will establish and maintain a
1. Create a form for
1. Permit Year 1
1. Yes or No, status
web -based google form where
web based reporting.
summary;
complaints can be entered and
(FY19-20)
Date form is created.
sent to the appropriate reporting
2. Establish links to
2. Permit Year 1
2. Yes or No, status
individual. Publicize reporting
tool in education outreach
reporting form tool on
summary;
materials.
the City and WPCOG
(FY19-20)
Date links are created.
websites and social
media (included, but
not limited to,
Facebook).
3. Maintain the web
3. Annually, following
3. Number of reports
based reporting tool.
the creation of BMP
made; method of
30.13.1. & 2.
publicizing reporting
option.
Permit Years 1-5
FY19/20 — FY23/24)
3. Publicize web -based
3. Continuously
3. Amount of materials
reporting tool by
following
distributed.
including the URL
establishment of the
address/location in all
web tool.
educational materials
distributed.
Permit Years 1-5
FY19/20 — FY23/24
31.
IDDE Reporting Efficiency
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February 23, 2020
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Table 15: Illicit Discharge Detection and Elimination BMPs
Staff will provide a rapid response
1. Utilize the IDDE
1. Permit Year 1
1. Yes or No, status
to all complaints received. Staff
GIS application to
summary;
will record the response dates and
track time of
(FY19/20)
Date application
summary of results to improve
complaint, site visit,
created.
IDDE program and application.
type of complaint and
all
enforcement/resolution
measures.
2. Evaluate response
2. Annually, following
2. High/Low times
time. Work to
establishment of GIS
elapsed, and overall
minimize response
application.
average time between
time to reported issues
the report and staff
and record what is
Permit Years 1-5
investigation; goal is
causing those issues to
(FY19/20 — FY23/24)
to improve time to
be fixed in later
achieve best
iterations of the plan.
management practices.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153, the City of Conover relies upon the North Carolina Sedimentation Pollution
Control Act (SPCA) of 1973 and the NCGO10000 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
Reference
State or Local Program Name
Legal Authority
Implementing Entity
Meets Whole
or Part of
Requirement
3.5.1 -
Catawba County Delegated SPCA
15A NCAC
Catawba County
Whole
3.5.4
Program*
Chapter 04,
Inter -local
Agreement for
Enforcement
Services of
Catawba
County Soil
Erosion and
Sediment
Control
Ordinance
*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?nodeld=COOR CH31SOERSECO
In addition to the delegated SPCA Program, opportunities for public input through the stormwater hotline, web -page
reporting tool and additional waste management requirements for construction site operators provide a comprehensive
construction site run off control program. The City of Conover will also implement the following BMPs to meet NPDES
MS4 Permit requirements.
Table 17: Construction Site Runoff Control BMPs
Permit
3.5.6: Public Input
Ref.
Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
32.
Municipal Staff Training
Train municipal staff who receive
1. Establish a sheet/list
1. Permit Year 1
1. Number and names
calls from the public on the
of trained municipal
of staff trained;
protocols for referral and tracking
staff and citizens who
(FY19/20)
number of responses
of construction site runoff control
have reported
generated by staff.
complaints.
construction run-off
issues.
DRAFT NCS000431 SWMP
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February 23, 2020
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Table 17: Construction Site Runoff Control BMPs
2. Train municipal
2. Annually, following
2. Document and
staff on proper
establishment of BMP
report number of staff
handling of
32.13.1.
trained, training
construction site runoff
date(s), and topics
control complaints.
Permit Years 1-5
covered.
(FY19/20 — FY23/24)
33.
Means of Public Input
1. Develop a survey to
1. Permit Year 1
1. Was the survey
Develop surveys and programs to
obtain feedback about
developed: Yes or No,
give citizens methods of
public perspective
(FY19/20)
Status.
responding to how construction
about construction
runoff is being managed. Ask
runoff in the City.
questions regarding: how they
view construction runoff in the
City, what they think should be
changed to improve upon said
problems, and where they believe
there should be better focus.
2. Administer the
2. Annually, following
2. Number of surveys
survey to be
the development of the
administered; number
distributed through
survey.
of valid surveys
City utility bills and
received.
left in municipal
Permit Years 2-5
buildings.
(FY 20/21 - FY 23/24)
3. Develop a web-
3. Permit Year 1
3. Web -based tool
based reporting form
developed; Yes or No,
that allows citizens
(FY19/20)
Status.
and the development
community (separately
distinguished) to write
concerns and report
construction runoff
issues. The tool will
be accessible on the
City and WPCOG
webpages and social
media.
4. Administer the web-
4. Continuous,
4. Number of reports
based reporting form
following the
from Citizens; Number
in BMP 33.13.3.
development of the
of reports from
web -based tool in
development
Permit Year 1.
community.
Permit Years 2-5
FY 20/21 - FY 23/24
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 38

Table 17: Construction Site Runoff Control BMPs
5. Publicize the ability
5. Continuous,
5. Number of clicks on
to report concerns
following development
the WPCOG website;
about construction
in Permit Year 1.
number of likes and
runoff issues via forms
shares on WPCOG
(BMP 33.B.3) on the
Permit Years 2-5
social media
City and WPCOG
(FY 20/21 - FY 23/24)
platforms.
websites and social
media.
Permit
3.5.5: Waste Management
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
34.
Establish and Maintain Legal Authority
Require construction site
1. Develop an
1. Permit Year 1
1. Ordinance
operators to control waste at the
ordinance that
developed: Yes or No,
construction site that may cause
addresses construction
(FY19/20)
Status.
adverse impact to water quality.
site waste.
2. Adopt the ordinance
2. Permit Year 1,
2. Ordinance adopted:
established in BMP
following development
Yes or No, Status.
34.B.1.
of ordinance
(FY19/20)
3. Enforce the adopted
3. Continuous,
3. Number of permits
ordinance using a GIS
following adoption of
issued with erosion
application (Permit
the ordinance.
and sedimentation
Reference 3.4.4, BMP
control plans;
26.B.1.) to track and
Permit Years 1-5
Number of corrective
document
(FY19/20 — FY23/24)
actions
construction site
taken/violations issued
waste concerns and
to active construction
corrective actions.
sites identifying waste
management
violations.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 39

PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
The City of Conover SWMP 2013 has policy language for deed restrictions and protective covenants. In the new SWMP
permit cycle the language will also be included in the Stormwater Ordinance. An amendment to the ordinance will allow
the language to have legal significance.
Contracting WPCOG, an inventory of projects will be established (BMP 35.B.1, 2, and 3) for developments within the
municipal limits, this is in response to Permit Citation II.F.2.d, of the latest DEQ MS4 audit (2018). Along with the
inventory list, proactive inspections will be administered by Staff semi-annually and the owner of the privately owned
SCM will be required to have an inspection done by a certified private engineer annually to ensure SCM functionality
(Permit Citation II.F.2.g.). Upon non-compliance, enforcement action will be taken. The City will have a GIS tracking
mechanism to proactively enforce to obtain compliance (II.F.2.i.).
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 Conover
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 Conover implements the following State post -
construction program requirements, which satisfy the NPDES Phase II MS4 post -construction site runoff control
requirements as Qualifying Alternative Program(s) (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
Water Supply Watershed (WS-IV)
15A NCAC 2B
WS-IV Watershed Ordinance (See
.0620 - .0624
map) Protected Areas
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 40

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City of Conover Watersheds
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The City of Conover has a small portion on the east side of the City limits located within a water supply watershed. The
area within the watershed boundaries are required to follow those rules to ensure drinking water quality is being
maintained. This is known as a Qualifying Alternative Program (QAP). The City is also subject to the NPDES Phase II
MS4 post -construction program requirements. These existing requirements will be codified in local ordinance(s) per
BMP 37.13.1 and implementation per BMP 37.13.3-4.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 41

Table 19: Summary of Existing Post -Construction Program Elements
Permit Requirements for Plan Review
Municipal Ordinance/Code Reference(s) and/or
Date Adopted
and Approval
Document Title(s)
3.6.2(a) Authority
Appendix C - Stormwater Ordinance (Phase II) Section
May 7, 2007
10.2
3.6.3(a) & 15A NCAC 02H.0153(c)
Appendix C - Stormwater Ordinance (Phase II) Article
May 7, 2007
Federal, State & Local Projects
II
3.6.3(b) Plan Review
Appendix C - Stormwater Ordinance (Phase II) 30.2
May 7, 2007
3.6.3(c) O&M Agreement
Appendix C - Stormwater Ordinance Phase II) 50.2
May 7, 2007
3.6.3(d) O&M Plan
Appendix C - Stormwater Ordinance Phase II) 50.2
May 7, 2007
3.6.3(e) Deed Restrictions/Covenants
Appendix C - Stormwater Ordinance (Phase II) 40.2
May 7, 2007
and 40.3
3.6.3(f) Access Easements
Appendix C - Stormwater Ordinance (Phase II) 50.8
May 7, 2007
Permit Requirements for Inspections
Municipal Ordinance/Code Reference(s) and/or
Date Adopted
and Enforcement
Document Title(s)
3.6.2(b) Documentation
Appendix C - Stormwater Ordinance (Phase II) 50.1
May 7, 2007
3.6.2(c) Right of Entry
Appendix C - Stormwater Ordinance Phase II) 50.2
May 7, 2007
3.6.4(a) Pre -CO Inspections
Appendix C - Stormwater Ordinance Phase II) 30.3
May 7, 2007
3.6.4(b) Compliance with Plans
Appendix C - Stormwater Ordinance Phase II) 30.3
May 7, 2007
3.6.4(c) Annual SCM Inspections
Appendix C - Stormwater Ordinance Phase II) 50.3
May 7, 2007
3.6.4(d) Low Density Inspections
Appendix C - Stormwater Ordinance (Phase II) 40.2
May 7, 2007
3.6.4(e) Qualified Professional
Appendix C - Stormwater Ordinance (Phase II) 50.1
May 7, 2007
Permit Requirements for Fecal
Municipal Ordinance/Code Reference(s) and/or
Date Adopted
Coliform Reduction
Document Title(s)
3.6.6(a) Pet Waste
Town Code Section 16-11
March 5, 1973
3.6.6(b) On -Site Domestic Wastewater
Town Code Section 22-60
July 1, 2013
Treatment
The post construction stormwater ordinance was adopted in 05.07.2007. It is noted that a new model ordinance has been
endorsed by the State. The City of Conover will be adopting the State's template ordinance within Year One of the
NPDES permit cycle. The section numbers above are subject to change. This will be in addition to the States' new model
watershed ordinance.
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
4.1.3: Minimum Post -Construction Reporting Requirements
Ref.
Measures to document activities over the course of the fiscal year (July 1 — June 30) including appropriate
information to accurately describe rogress, status, and results.
A
B
C
D
BMP
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 42

Table 20: Post Construction Site Runoff Control BMPs
35.
Standard Reporting
Implement standardized tracking,
1. Track number of
1. Continuous
1. Number of plan
documentation, inspections and
low density and high
reviews performed for
reporting mechanisms to compile
density plan reviews
Permit Years 1-5
low density and high
appropriate data for the annual
performed.
(FY19/20 - FY23/24)
density.
self -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
2. Continuous
Permit Years 1-5
2. Number of plan
approvals issued for
low density and high
approved.
(FY19/20 - FY23/24)
density.
3. Maintain a current
3. Continuous
3. Summary of number
inventory of low
and type of SCMs
density projects and
Permit Years 1-5
added to the inventory;
constructed SCMs
(FY19/20 - FY23/24)
and number and
including SCM type or
acreage of low density
low density acreage,
projects constructed;
location and last
Total number of SCMs
date.
at time of review
-inspection
4. Track number of
4. Continuous
4. Number of SCM
SCM inspections
inspections preformed.
performed.
Permit Years 1-5
(FY19/20 - FY23/24)
5. Track number of
5. Continuous
5. Number of low
low density
density inspections
inspections performed
Permit Years 1-5
performed
- with the goal of
(FY19/20 - FY23/24)
inspecting all low
density projects over
the 5 year permit
period.
6. Track number and
6. Continuous
6. Summary of
type of enforcement
Number and type of
actions taken.
Permit Years 1-5
enforcement actions
(FYI 9/20 - FY23/24)
taken.
Permit
2.3 and 3.6: Qualifying Alternative Program(s)
Ref.
Measures to develop, implement and enforce additional BMPs in order to comply with the QAP state program
re uirements.
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
36.
Qualifying Alternative Program
The QAP requirements are applicable to the City of Conover.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 43

Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.2: Legal Authority
Ref.
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.
MP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
37.
Phase II Post -construction Stormwater Ordinance
This permit requirement will be
1. Develop the Phase
1. Permit Year 1
1. Phase 11 Post -
met once the new, compliant,
II Post -construction
construction
Phase 11 Post -Construction
Stormwater
(FY19/20)
Stormwater Ordinance
Stormwater Ordinance is adopted,
Ordinance.
is developed: Yes or
see references provided in Table
No, Status.
2. Adopt the Phase II
2. Permit Year 1
2. Phase 11 Post -
19.
The City will adopt and maintain
Post -construction
construction
in effect the Phase II Stormwater
Stormwater
(FY19/20)
Stormwater Ordinance
Ordinance, which will give the
Ordinance.
adopted: Yes or No,
City legal authority to review
status summary;
designs for new development and
Date ordinance
redevelopment, to ensure
adopted.
adequate stormwater controls, to
3. Train staff (field
3. Permit Year 1
3. Number of staff
request information, to perform
and office) in
trained;
inspections on private property,
Stormwater Ordinance
(FY19/20)
and to perform other compliance
procedures and
activities related to this measure.
enforcement actions.
The ordinance shall reference the
4. Enforcement of the
4. Continuous,
4. Number of notices
DEQ Design Manual as the
Phase II Post-
following the adoption
of violations issued;
source of standards to be used in
construction
and training of staff
Number of Civil
selecting, designing, evaluating,
Stormwater Ordinance
Citations issued;
and maintaining structural and
to ensure compliance.
Permit Years 2-5
Number still in
non-structural BMPs.
progress of abatement
(FY20/21 - FY23/24)
at time of annual
report.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 20: Post Construction Site Runoff Control BMPs
Permit
3.6.3: Plan Review and Approval
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
38.
Plan Review and Approval
This permit requirement will be
1. Establish a post
1. To be completed in
1. Plan review
achieved once the post-
construction plan
Permit Year 1.
checklist was
construction ordinance is adopted
review checklist to
established: Yes or
(Permit Reference 3.6.2 BMP
include all items
(FY19/20)
No, Status.
37.13.2)
needing to be
completed prior to
Review plans for all new
Certificate of
development and redevelopment
Occupancies.
sites that will disturb greater than
2. Review plans for all
2. Continuous,
2. Number of projects
or equal to one acre (including
new development and
following the adopted
reviewed; Number of
projects less than one acre that are
redevelopment sites
of the Post-
projects approved.
part of a larger common plan of
that will disturb greater
construction
development or sale).
than or equal to one
stormwater ordinance,
(To be documented by
acre. This is to
referenced in BMP
listing type - Non -
including projects less
37.13.2.
governmental,
than one acre that are
Federal, State or Local
part of a larger
Permit Years 1-5
Government)
common plan of
(FY19/20 — FY23/24)
development or sale.
This requirement also
applies to Federal,
State, and Local
Government projects.
3. Review checklist
3. Annually, following
3. Number of updates
annually to determine if
establishment of the
made and summary of
items need to be added
checklist referenced in
reason needed.
or modified.
BMP 38.B.1.
Permit Years 1-5
FY19/20 — FY23/24)
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 20: Post Construction Site Runoff Control BMPs
39.
Operation and Maintenance Agreement and Plan
The Operation and Maintenance
1. Ensure that each
1. Continuous
1. Number of
(O&M) agreement requires
project has an approved
approved O & M
owners of structural BMPs to
O & M Agreement
Permit Years 1-5
Agreements.
perpetually maintain and operate
prior to CO. To be
SCMs according to the O&M
included in the project
(FY19/20 — 23/24)
plan submitted during the plan
checklist and required
review process, and require
prior to CO.
submission of annual inspection
2. Ensure that each
2. Continuous, to be
2. Number of O & M
reports written by a qualified
professional.
project has an O & M
included in the project
inspections received
Plan to require annual
checklist and required
and approved.
inspections to be
prior to CO.
completed by a
qualified professional.
Permit Years 1-5
FY19/20 — FY 23/24)
40.
Recordation
The plan review process shall
1. Ensure each project
1. Continuously, to be
1. Number of deed
include verification that
has recorded deed
included in the project
restrictions and
permanent legal mechanisms are
restrictions and
checklist and required
protective covenants
in effect that will ensure
protective covenants in
prior to CO.
recorded. Document
development activities will
effect to ensure
high density versus
maintain the project consistent
development activities
Permit Years 1-5
low density projects.
with approved plans. A recorded
will stay consistent
(FY19/20 — FY 23/24)
deed or protective covenants,
with the approved plans
along with an accesses easement
(low and high density
is established through
-projects).
2. Ensure that each
2. Continuously, to be
2. Number of access
recordation.
SCM and the associated
included in the project
easements recorded.
maintenance access are
checklist and required
recorded in a
prior to CO.
permanent easement to
allow access for
Permit Years 1-5
inspection and
(FY19/20 — FY 23/24)
maintenance of the
SCM.
Permit
3.6.4: Inspections and Enforcement
Ref.
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.
A
I B
C
D
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 46

Table 20: Post Construction Site Runoff Control BMPs
BMP
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
No.
Implementation
Metric
41.
Inspection and Enforcement
This permit requirement will be
1. Prior to issuance of a
1. Continuously,
1. Number of Pre -CO
achieved upon the adoption of the
CO a qualified
inspections completed;
Stormwater Post -construction
professional shall
Permit Years 1-5
Number of duplicate
Ordinance, reference Table 19.
perform an inspection
(FY19/20-FY23/24)
inspections required.
After project completion, but
on all project SCMs to
prior to issuance of a certificate of
ensure compliance
occupancy, an inspection will be
unless corrections are
completed by a qualified
needed. If corrections
professional to ensure the project
are required, then
has been constructed according to
follow up inspections
plan. Following approval, annual
will be required until
inspections by a qualified
the SCM and project
professional will be completed.
site is compliant prior
Low density projects will be
to the issuance of CO.
inspected once in a permit term.
2. Staff will perform
2. Semi -Annual
2. Number of
inspections of all SCMs
inspections completed.
(both government and
Permit Years 1-5
Findings reported in
non -government).
FY19/20 — FY23/24)
chart form.
3. Owner shall have a
3. Annually
3. Number of
certified professional
inspections completed
engineer perform SCM
Permit Years 1-5
and documentation
inspection/s in
(FY19/20 — FY23/24)
received. Number of
accordance with the O
SCM/s not compliant.
& M Agreement and
Document required
DEQ SCM manuals.
corrective action.
4. 20% or more of the
4. Continuously
4. Number of low
inventoried low density
density projects;
sites will be inspected
Permit Years 1-5.
Number of inspection
each year to ensure
(FY19/20-23/24)
completed and
impervious has not
findings.
been added producing a
high density situation
creating the need for an
SCM.
Permit
3.6.5: Documentation
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
42.
Documentation —Low Density
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 20: Post Construction Site Runoff Control BMPs
This permit requirement will be
1. Establish a low
1. Once during the
1. In House: List of
achieved upon the adopted of the
density project list to
permit cycle.
low -density permitted
Stormwater Post -construction
include existing sites.
projects: Status to
Ordinance, reference Table 19.
Upon the issuing a
Permit Years 1-5
include location,
Ensure tracking and records are
zoning permit record
(FY19/20 — FY23/24)
impervious
maintained on low density
the project
calculations,
projects to ensure that upon
demographics on the
enforcement action,
inspection impervious overages
low density list for
chronic violators, date
can be determined and corrective
future reference.
of last inspection and
actions taken. Ensure
findings. Apply
informational materials are
corrective action with
available to guarantee
impervious overages.
accessibility outside of office
A summary will be
hours. Through tracking and
report each year to
inspections chronic violators will
DEQ.
2. Once established
2. Annually
2. Number of projects
be identified.
monitor the low
in violation and
density projects to
Permit Years 1-5
remedy established.
ensure the projects
(FY 19/20 — FY23/24)
have not expanded
into a high density
classification thus
needing a SCM.
3. Provide educational
3. Continuously
3. Number of
material to the general
materials handed out
public about low
Permit Years 1-5
density development,
(FY19/20 — FY23/24)
such as, but not
limited to, during the
issuance of zoning
permits, distributed
through mailings,
social media, and at
events.
43.
Documentation — High Density
Ensure tracking and records are
1. Maintain an
1. Continuous
1. Inventory of high
maintained on projects to ensure
inventory of all
density projects
that upon granting of final CO
developments and
Permit Years 1-5
completed: Yes or No,
and follow-up inspection
redevelopments
(FY19/20 — FY23/24)
status.
impervious overages can be
(public and private)
determined and corrective actions
with SCMs. Update
taken. Ensure informational
inventory as sites are
materials are available to
reviewed, approved,
guarantee accessibility outside of
and constructed.
office hours. Through tracking
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 20: Post Construction Site Runoff Control BMPs
and inspections, chronic violators
2. Prior to Certificate
2. Once prior to CO.
2. Number of recorded
will be identified.
of Occupancy is
plats and deeds to
granted deed
Permit Years 1-5
include name of
restrictions and an
(FY19/20 — FY23/24)
project, type of
access easement plat
Depends on when
document, and
shall specify
project is nearing
impervious limits.
impervious limitations
completion.
and be recorded.
3. Provide educational
3. Continuous, such as,
3. Number of
material to developers
but not limited to,
informational
about high density
during the issuance of
materials are handed
development. At a
zoning permits,
out.
minimum, hyperlinks
distributed through
will be maintained on
mails, social media, and
the City's web page
at events.
directed to the
Ordinance and to the
Permit Years 1-5
BMP Design Manual.
FY19/20 — FY23/24)
4. Establish links to all
4. Annually
4. Items placed on the
ordinances, manuals,
webpage: Yes or No,
policies, checklist,
Permit Years 1-5
Status.
design standards,
(FY19/20 — FY23/24)
and/or other materials.
Permit
3.6.6: Fecal Coliform Reduction
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
44.
Fecal Coliform Reduction
This permit requirement will be
1. Establish a Pet
1. Permit Year 1
1. Pet Waste
met once the Post -Construction
Waste Ordinance to
Ordinance established:
Stormwater Ordinance is adopted,
address fecal
(FY19/20)
Yes or No, Status.
see references provided in Table
coliform stressors
19. Fecal Coliform is a water
from pet waste
quality stressor. Protective
runoff.
2. Establish a Waste-
2. Permit Year 1
2. Waste water
measures will be established
through adoption of pet waste and
water treatment
treatment system
waste water treatment system
ordinance to address
(FY19/20)
Ordinance was
ordinances. The control of Pet
environmental
established: Yes or
Waste and the waste -water
stressors related to
No, Status.
treatment system will be mandated
waste water
in the NPDES Phase 11 Stormwater
management.
Ordinance.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 49

PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of Conover
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 (O & M)
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
The City of Conover will manage, implement and report the pollution prevention and good housekeeping BMPs as
specified in Table 21 below for each required program in response for the MS4 Audit inefficiencies. BMPs 45 and 46 will
require a written inventory of facilities and potential pollutants. Several of the BMPs below address street and parking lot
issues by developing, adopting, and maintaining procedures that focus on pollutant removal in these impervious areas,
along with, Setting schedules and requirements for street/parking lot sweeping (BMP 58), collecting litter/debris (BMP
59), working in collaboration with community outreach program and developing standard spill procedures (BMP 47).
The City of Conover uses a vac -truck to clean the storm sewer conveyance system. An O & M plan had not been created
and maintained at the time of the MS4 DEQ Audit. Permit Reference: 3.7.3, BMP's 48-51 focus on the training,
inspection, and maintenance of said system.
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.1: Municipal Facilities Operation and Maintenance Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
45.
Municipal Facilities Operation & Maintenance (O & M) Plan
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 50

Table 21: Pollution Prevention and Good Housekeeping BMPs
An O & M Plan must be
1. Develop an O & M
1. Permit Year 1
1. Was the O & M
developed, adopted and
plan. The plan will
Plan developed, Yes or
maintained to define the
define required
(FY19/20)
No, Status.
expectations of the municipal
procedures per facility
facilities which are subject to
to inspect, maintain
stormwater/MS4 regulations. The
and evaluate.
O & M plan will provide
2. Adopt the written O
2. Permit Year 1
2. Was the O & M
reference to the expected
& M Plan as
Plan adopted, Yes or
documents to correctly permit
developed in Permit
(FY19/20)
No, Status.
municipal facilities. Each
Reference 3.7.1, BMP
municipal facility in which this is
45.13.1.
applicable will adopt an O&M
3. Administer the O &
3. Continuous,
3. Number of
plan. The adoption of a plan
M Plan as referenced
following development
municipal facilities
entails signing a legally binding
in BMP 45.13.1.
and adoption of the O
inspected; Note any
document that defines the party
& M Plan location in
plan changes that are
charged with ensuring that the
BMP 45.13.1 and 2.
needed. All
facility is correctly maintained
amendments are to be
and documentation of the
Permit Years 2-5
approved by DEQ.
maintenance is adequate. The
(FY20/21 — FY23/24)
documents will also define the
procedures in how the facility will
be maintained.
46.
Municipal Facilities
The municipal facilities operation
1. Verify the existing
1. Permit Year 1
1. Is the facility list
and maintenance program will
list of facilities is
complete: Yes or No,
ensure the facilities are being
correct by using tax
(FY19/20)
Status.
managed/maintained in a way that
records and City data.
does not negatively impact water
Field visits may be
quality. The facilities will be
needed if data is not
maintained in a scheduled and
clear.
well defined manner by
2. Use tax data and
2. Permit Year 1
2. Number of potential
preforming routine inspections. If
facility visits to
pollutant/spill risk
a facility is subject to SPCC
determine if the
(FY19/20)
facilities.
requirements, then specific
facility has a potential
inspection procedures will be
pollutant and/or spill
completed per the SPCC
risk.
requirements.
3. Perform facility
3. Annually
3. Number of facilities
inspections to insure
inspected and dates
the municipality is
Permit Years 1-5
inspected;
performing good MS4
(FY19/20-FY23/24)
Number of SPCC
housekeeping
permitted facilities
measures.
inspected.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 51

Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Document and
4. Annually
4. Number of issues
correct issues found
identified/recorded;
during inspections. If
Permit Years 1-5
Number of corrective
a facility is subject to
(FY19/20-FY23/24)
actions taken
SPCC requirements,
(SPCC permitted
then ensure the correct
facilities and non -
documentation is in
SPCC facilities).
place for compliance
with the regulation/
requirements.
5. Train municipal
5. Permit Years 1-5
5. Document and
facility staff on proper
report number of staff
stormwater awareness
FY 19-20
trained
and good
FY 20-21
housekeeping
FY 21-22
methods.
FY 22-23
FY 23-24
Permit
3.7.2: Spill Response Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
47.
Spill Response
Spill response program for
1. Develop a written
1. Permit Year 1
1. Were the procedures
facilities and operations that store
spill response
created: Yes or No,
and/or use materials. The program
procedures plan
(FY19/20)
status summary.
will be designed in a way that
according to the
tracks likely polluters, as well as,
Permit Citation in
designate the procedures/materials
NPDES MS4 audit.
required for spill response in
2. Adopt the spill
2. Permit Year 1
2. Plan adopted: Yes
those facilities. The spill response
response procedures
or No, status summary
plan is an internal policy
plan as defined by
(FY19/20)
Date of adoption.
document; therefore would need
Permit Reference
to be put in place once completed.
3.7.2, BMP 47.13.1.
3. Maintain spill
3. Annually
3. Number of updates
response procedures in
to the plan and reason
response to problems
Permit Years 1-5
for update.
that may arise from
(FY19/20-FY23/24)
implementation of spill
procedures.
4. Train staff on spill
4. Annually
4. Document and
response procedures.
report number of staff
Permit Years 1-5
trained; Number of
(FY19/20-FY23/24)
facilities trained
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 52

Table 21: Pollution Prevention and Good Housekeeping BMPs
5. Respond in a timely
5. Continuous,
5. Number of issues
manner to spills as
following the
identified — document
they occur and manage
establishment of the
when and where;
the spill/s following
plan in Permit Year 1.
Number of corrective
established spill
actions taken,
procedures.
Permit Years 1-5
documenting type of
(FY19/20-FY23/24)
spill.
Permit
3.7.3: MS4 Operation and Maintenance Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Implementation
Annual Reporting
Metric
48.
MS4 Operation & Maintenance (O & M) Plan
An O & M Plan must be
1. Develop an O & M
1. Permit Year 1
1. Was the O & M
developed, adopted, and
plan to define required
Plan developed: Yes
maintained following the
procedures to schedule
(FY19/20)
or No, status.
requirements of the MS4 NPDES
inspections, perform
Phase II Stormwater collection
maintenance and
system permit. The O&M plan
evaluations of the
must also be submitted to the
stormwater collection
DEQ for approval.
system.
2. Submit the
2. Permit Year 1
2. Was the O&M plan
developed O&M plan
approved by DEQ:
to DEQ for approval.
(FY19/20)
Yes or No, Status.
3. Adopted the
3. Permit Year 1
3. Was the O & M
approved written O &
Plan adopted, Yes or
M Plan as developed
(FY19/20)
No, Status.
in Permit Reference
3.7.3, BMP 48.B.1.
4. Administer the O &
4. Continuously,
4. Number of MS4
M Plan as references
following development
inspections completed;
in BMP 48.B.1.
and adoption of the O
Number of corrections
& M Plan location in
needed based on
BMP 48.B.1 and 2.
inspection findings;
Note any plan changes
Permit Years 2-5
that are needed.
(FY20/21- FY23/24)
49.
MS4 Training
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 53

Table 21: Pollution Prevention and Good Housekeeping BMPs
Provide MS4 training to
1. Hold MS4 training
1. Annually
1. Number of
municipal and contracted staff to
events to educate staff
events/personnel
minimize pollutants in the
on stormwater
Permit Years 1-5
trained; provide
stormwater collection system and
awareness and
(FY19/20-FY23/24)
summary of topics
prevent unnecessary damage and
pollution prevention.
covered during
wear on the system.
training.
50.
MS4 Inspection
MS4 inspections to ensure
1. Inspect and maintain
1. Continuous
1. Number of catch
clogged lines, non-functioning
the MS4 infrastructure
basins, outfalls, and
SCMs, and drainage inadequacies
such as pipes, major
Permit Years 1-5
conveyances
are identified.
outfalls, stormwater
(FY19/20-FY23/24)
inspected; Number of
conveyances, and
issues report.
basins to ensure
functionality.
51.
MS4 Maintenance
MS4 inspections to ensure
1. Catch basin and
1. Continuous, as
1. Number of catch
clogged lines, non-functioning
conveyance system
problems are
basins and conveyance
basins, and drainage inadequacies
maintenance activities
identified.
systems cleaned.
are repaired. If the municipality
are performed
cannot reasonably maintain issues
periodically or as
Permit Years 1-5
with MS4 infrastructure found
needed.
(FY19/20-FY23/24)
that year, it can be contracted out
to licensed engineers if the City
chooses to do so.
2. Maintenance
2. Continuous
2. Number of
Records are to be
completed work order
maintained in Public
Permit Years 1-5
tickets and/or GIS map
Works' automated
(FY19/20-FY23/24)
updates.
work order system
and/or by the WPCOG
GIS application Permit
Reference 3.4.4, BMP
26.
Permit
3.7.4: Municipal SCM Operation and Maintenance Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
52.
Municipal SCMs Operation & Maintenance (O & M) Plan
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 54

Table 21: Pollution Prevention and Good Housekeeping BMPs
Measures to manage (inspect
1. Develop an O & M
1. Year 1
1. Was the O & M
and/or clean) municipally -owned,
plan that will define
Plan developed, Yes or
operated, and/or maintained
required procedures to
(FY19/20)
No, Status.
structural SCMs. This will entail
inspect, maintain and
following the schedule and
evaluate stormwater
procedures defined in the O & M
structures/practices.
Plan once developed and adopted.
2. Adopted the written
2. Year 1
2. Was the O & M
O & M Plan as
Plan adopted, Yes or
Note: The city does not currently
developed in Permit
(FY19/20)
No, Status.
have any municipally
Reference 3.7.4, BMP
owned/managed SCMs — BMPs
52.13.1.
52 & 53 are written for the
3. Administer the O &
3. Continuous,
3. Number of
potential of an SCM to be built
M Plan as referenced
following development
municipal SCMs
during the permit cycle to ensure
in BMP 52.13.1.
and adoption of the O
inspected; Note any
the proper procedures would be in
& M Plan location in
plan changes that are
place if that were to occur.
BMP 52.13.1 and BMP
needed. All
52.13.2
amendments are to be
approved by DEQ.
Permit Years 2-5
(FY20/21-FY23/24)
53.
Municipal SCMs
The municipal SCM operation
1. Verify the existing
1. Permit Year 1
1. Is the SCM list
and maintenance program will
list of municipal SCMs
complete: Yes or No,
ensure the structures are being
is correct by visiting
(FY19/20)
Status
managed/maintained in a way that
the sites to determine
(Location and type to
does not negatively impact water
type and condition.
be documented).
quality. The SCMs will be
Use aerial photography
maintained in a scheduled and
in conjunction with
well defined manner as written in
City records to
the O & M.
determine SCM
location/ ownership.
2. Maintain Inventory
2. Continuous
2. Number of SCMs
of municipally owned
added with type of
SCMs. Add all new
Permit Years 1-5
each SCM, date,
SCMs as they are
(FY19/20-FY23/24)
location documented
constructed.
3. Perform annual
3. Annually
3. Number of SCMs
inspections and
inspected
maintenance of
Permit Years 1-5
municipally owned
(FY19/20-FY23/24)
SCMs to ensure the
operation and
maintenance
agreements are being
followed.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 55

Table 21: Pollution Prevention and Good Housekeeping BMPs
4. Document and
4. Annually
4. Number of issues
correct issues found
identified/recorded;
during inspections.
Permit Years 1-5
Number of corrective
(FY19/20-FY23/24)
actions taken.
5. Train municipal
5. Annually
5. Document and
staff on SCM
report number of staff
housekeeping.
Permit Years 1-5
trained, training
(FY19/20-FY23/24)
date(s) and topics
covered.
Permit
3.7.5: Pesticide, Herbicide and Fertilizer Management Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
54.
Pesticide, Herbicide and Fertilizer Training to Staff
Measures to minimize water
1. Provide training to
1. Annually
1. Number of
quality impacts from the use of
staff on the use,
events/personnel
landscaping chemicals. The only
storage and handling
Permit Years 1-5
certified.
staff who will be allowed to
to get officially
(FY19/20-FY23/24)
utilize pesticides, herbicides, or
certified. The training
fertilizers will be certified
will/should include
individuals who must use methods
methods of using
to minimize the amounts used.
minimal chemicals to
reduce harmful effects,
especially around
SCM maintenance.
55.
Pesticide, Herbicide and Fertilizer Compliance
Ensure compliance with permits
1. Maintaining copies
1. Annually
1. Report Number of
and certifications for the
of licenses and
certified personnel.
administering of pesticides,
certifications of all
Permit Years 1-5
herbicides, and fertilizers to
staff and contractors
(FY19/20-FY23/24)
ensure application of the
who use landscaping
chemicals is less impactful to
chemicals.
stormwater runoff. Only certified
landscapers/sprayers are the ones
applying pesticides, herbicides,
and fertilizers.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 56

Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit
3.7.6: Vehicle and Equipment Cleaning Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual Reporting
Implementation
Metric
56.
Vehicle and Equipment Cleaning
Prevent or Minimize
1. Establish
1. Permit Year 1
1. Was the protocol
Contamination of Stormwater
appropriate protocol
established: Yes or No,
Runoff from all areas used for
for containing and
(FY19/20)
status.
Vehicle and Equipment Cleaning.
disposing of vehicle
and equipment wash
water. Wash water can
be directed to the
sanitary sewer or to
vegetated areas. Where
cleaning operations
cannot be performed
as described above and
when operations are
performed in the
vicinity of a storm
drainage collection
system, the drain is to
be covered with a
portable drain cover
during cleaning
activities. Any excess
standing water shall be
removed and properly
handled prior to
removing the drain
cover. OR another
acceptable method is
installation of a SCM
to capture and treat the
wash water runoff.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
2. Provide routine
2. Continuously,
2. Number of training
pollution prevention
following the
events/personnel
training to staff.
establishment of the
trained
protocol located in
BMP 56.B.1.
Permit Years 1-5
(FY19/20-FY23/24)
3. Wash all municipal
3. Continuous
3. Method of vehicle
light vehicles, City
and equipment
emergency vehicles,
Permit Years 1-5
washing documented
and equipment using
(FY19/20-FY23/24)
to include one of the
an appropriate method
methods listed in BMP
established in BMP
56.B.1. Provide
56.B.1, or utilize a
quarterly invoices
commercial carwash
from commercial
facility contains and
carwash if utilized.
treats wash water
where applicable.
57.
Vehicle and Equipment Maintenance
Measures to ensure that vehicles
1. Ensure the City has
1. Permit Years 1
1. Log of industrial
maintained at municipal facilities
obtained a NPDES
permit/s and status.
have waste (included, but not
industrial permit for all
(FY19/20)
limited to, oils, any running
subject municipal
fluids, batteries, belts and other
facilities/operations
non -fluid vehicle waste) must be
2. Perform waste
2. Annually
2. Number of
disposed of following DEQ
inspections.
inspections and
requirements.
Permit Years 1-5
maintenance actions to
(FY19/20-FY23/24)
include date and
location.
3. Provide routine
3. Annually
3. Number of training
pollution prevention
events; number of
and waste management
Permit Years 1-5
personnel trained.
training to staff.
(FY19/20-FY23/24)
Permit
3.7.7: Pavement Management Program
Ref.
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
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Im lementation
Annual Reporting
Metric
58.
Street and Parking Lot Sweeping
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
Measures to reduce pollutants in
1. Street/curb and
1. Continuous
1. Total number of
stormwater runoff from
gutter sweeping is a
lane miles ran by the
municipally -owned streets, roads,
regular operational
Permit Years 1-5
street sweeper.
and parking lots within the
task that is performed.
(FY19/20-FY23/24)
ermittee's corporate limits.
59.
Litter Management
Collect litter in public areas and
1. Remove litter from
1. Continuous
1. Number of full time
parking lots to reduce negative
downtown city
employees
impacts on water quality.
streets/sidewalks and
Permit Years 1-5
responsible;
empty public waste
(FY19/20-FY23/24)
Number of trash bags
receptacles three times
used.
per week or as needed.
2. Collect litter from
2. Annually
2. Number of
public right-of-ways
collection events and
outside of downtown
Permit Years 1-5
amount of trash
city streets/sidewalks
(FY19/20-FY23/24)
collected/disposed of
is on an as -needed
for each event
basis utilizing
(pounds);
available staff or
Number of staff and/or
community volunteers.
volunteers.
60.
Leaf Collection
Implement measures to control
Collect leaves with
1. Semi -Annually
1. Number of cubic
leaves and debris within the
vacuum -style
yards collected.
municipal City limits (to include
equipment from
Permit Years 1-5
all properties).
October 15 through
(FY19/20-FY23/24)
January 15, with each
street collected twice
during this period.
61.
Vehicle Pollutant Management
Measures to prevent and minimize
1. Train first
1. Annually
1. Number of first
contamination of stormwater
responders for
responders (staff)
runoff from vehicle pollutants
minimizing,
Permit Years 1-5
trained and date of
following an accident.
collecting/disposing of
(FY19/20-FY23/24)
training.
fluids and other
vehicular pollutants
an accident.
—following
2. Continue equipping
2. Annually
2. Amount of materials
the first responder
used/replaced in kits.
vehicles with spill kits
Permit Years 1-5
and material
(FY19/20-FY23/24)
containment tools.
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
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Table 21: Pollution Prevention and Good Housekeeping BMPs
3. Public Education to
3. Annually
3. Number of materials
include information
handed out.
about vehicle leaks in
Permit Years 1-5
distributed materials
(FY19/20-FY23/24)
and other educational
resources. Following
BMP Permit Reference
3.2 outreach to target
audiences for
—guidance.
4. Illicit Discharge
4. Annually
4. Number of issues
enforcement for
documented; number
significant vehicle
Permit Years 1-5
corrected.
leaks from parked cars.
(FY19/20-FY23/24)
Reference Permit
Reference 3.4.2 &
3.4.3
DRAFT NCS000431 SWMP
City of Conover
February 23, 2020
Page 60