NCS000431_Conover Self Audit_20200228

DRAFT PHASE II MS4 AUDIT TEMPLATE
FOR PERMITS ISSUED PRIOR TO 2019
Edit yellow highlighted items to be
specific to the MS4 being audited.
MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000431
CONOVER, NORTH CAROLINA
Post Office Box 549
Conover, North Carolina 28613
DEQAudit Date: 10/22/2019
Self -Audit Report Date: 02/23/2020
North Carolina Department of Environmental Quality
Division of Energy, Mineral &Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

Preface:
This document has been filled out/written with the context of the changes made or in the
progress of being made in the time between the initial NCDEQ MS4 Audit (10-22-2019), and
the time this self -audit will be reviewed by the NCDEQ. The majority of the responses focus
on the modifications to the Draft SWMP and the Best Management Practices the City uses. If
a status is marked as 'Not Reviewed' this is due to it being found previously acceptable
according to the NCDEQ Audit. The City has contracted the Western Piedmont Council of
Governments to assist in bringing their stormwater program into compliance with the
shortcomings found during the MS4 Audit. The Draft SWMP will be finalized and submitted to
NCDEQ prior to the 2-28-2020 deadline.

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
(This page intentionally left blank)
Audit Date: 01/25/2020

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
TABLE OF CONTENTS
AuditDetails..............................................................................................................................4...................1
PermitteeInformation..................................................................................................................................2
SupportingDocuments..................................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................4
Public Education and Outreach.....................................................................................................................8
Public Involvement and Participation.........................................................................................................11
Illicit Discharge Detection and Elimination(IDDE)......................................................................................13
ConstructionSite Runoff Controls. . I I & . . . . . . . I . 1 4 4 1 1 1 1 1 1 . . . . . . . . . 6 , 4 , 4 , 4 . . . . . . . . . 6 . 6 , 4 4 , 4 . 4 . . . . . .
. . . . . . . . . . . . . . . . . . . .
. . . . . . . . b 4 6 , 4 , , 4 1 6
Post -Construction Site Runoff Controls . .......... ......:........... ................... ..........
....... .................. ...................
19
Pollution Prevention and Good Housekeeping for Municipal Operations.. ....
4 ......... 6,44,4 ............
4,44.4 ... & ..... 25
Total Maximum Daily Loads(TMDLs)..........................................................................................................28
Site Visit Evaluation: Municipal Facility No. 1................................................
Error! Bookmark
not defined.
Site Visit Evaluation: Municipal Facility No. 2................................................
Error! Bookmark
not defined.
Site Visit Evaluation: MS4 Outfall No. 1.........................................................
Error! Bookmark
not defined.
Site Visit Evaluation: MS4 Outfall No. 2..........................4..............................
Error! Bookmark
not defined.
Site Visit Evaluation: Construction Site No. 1.................................................
Error! Bookmark
not defined.
Site Visit Evaluation: Construction Site No. 2.................................................
Error! Bookmark
not defined.
Site Visit Evaluation: Post -Construction Stormwater Control Measure No,
1Errorl Bookmark
not defined.
Site Visit Evaluation: Post -Construction Stormwater Control Measure No,
2Error! Bookmark
not defined.
Appendix A: Supporting Documents
Appendix B: Photograph Log
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
Audit Date: 01/25/2020 ii

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
This page intentionally left blank
Audit Date: 01/25/2020 iii

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Audit Details
Audit ID Number:
Audit Date(s):
NCS000431_CONOVER MS4 Audit_20200125
01,25,2020
Minimum Control Measures Evaluated:
® Program Implementation, Documentation & Assessment
® Public Education & Outreach
® Public Involvement & Participation
® Illicit Discharge Detection & Elimination
® Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
® Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
® Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
® Total Maximum Daily Loads (TMDLs)
Field Site Visits:
❑ Municipal Facilities. Number visited: Choose an item.
❑ MS4 Outfalls. Number visited: Choose an item.
❑ Construction Sites. Number visited: Choose an item.
❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
❑ Other: . Number visited: Choose an item.
Inspector(s) Conducting Audit
Name, Title
Or¢anization
Alison Adams, Community and Regional Planning Director
Western Piedmont Council of Governments
Terry Lail, Environmental Coordinator/Construction Manager
City of Conover
Audit Report Author: jl/� H
Date:
Signature CA tjZ�Qua6tnc�a
a
Audit Report Author: fE� _ LA 1L
Signature //l� ^�
Date
OZ 77 ZVZa
Audit Date(s): 2/20/2020 Page 1 of 31

M54 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Permittee Information
MS4 Permittee Name:
City of Conover
Permit Effective Date:
February 20, 2017
Permit Expiration Date:
February 19, 2022
City, State, ZIP:
Post Office Box 549 Conover, North
Carolina 28613
Date of Last MS4 Inspection/Audit:
October 22, 2019
Co-permittee(s), if applicable:
n/a
Permit Owner of Record: Donald Duncan,
City Manager
Primary
M54 Representatives
Participating in Audit
Name, Title
Organization
Terry Lail, Environmental
Coordinator/Construction Manager
City of Conover
M54 Receiving
Waters
Waterbodv
Classification
Impairments
Clark Creek
C
N/A
Cline Creek
C
N/A
Conover Branch
C
N/A
Hildebran Creek
C
N/A
Long Creek
WS-IV
N/A
Lyle Creek
C
N/A
McLin Creek
C
N/A
Miller Branch
C
N/A
Mull Creek
WS-IV
N/A
Mahaffie Branch
C
N/A
Audit Date(s): 2/20/2020 Page 2 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Supporting Documents
Item
Number
Document Title
When Provided
(Prior to/During/After)
1
Draft SWMP (Pending Approval)
After (02.23.2020)
Audit Date(s): 2/20/2020 Page 3 of 31

M54 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Program Implementation, Documentation & Assessment
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting Doc No.
ILA.1
The permittee maintained adequate funding and staffing to implement and manage
Staffing and
the provisions of the Stormwater Plan and meet all requirements of the permit.
Yes
Funding
The Stormwater Plan identifies a specific position(s) responsible for the overall
Yes
--
coordination, implementation, and revision to the Plan.
Responsibilities for all components of the Stormwater Plan are documented and
Yes
position(s) assignments provided.
The permittee is current on payment of invoiced administering and compliance
Not
monitoring fees (see Stormwater e-payments on DEMLR MS4 web page).
Reviewed
Comments (Briefly describe funding mechanism, number of staff, etc.)
The City of Conover has now updated their SWMP to include current staff responsible for the program. In part the adequate funding
is being addressed through contracting with the WPCOG stormwater administration program. The City also contracts their plan
review through WK Dickson & Co, Inc.
The permittee evaluated the performance and effectiveness of the program
II.A.2 Stormwater
Plan
components at least annually.
Yes
Implementation
and Evaluation
If yes, the permittee used the results of the evaluation to modify the program
Not
components as necessary to accomplish the intent of the Stormwater Program.
Applicable
Did the permitted MS4 discharges cause or contribute to non -attainment of an
Not
applicable water quality standard?
Applicable
If yes, did the permittee expand or better tailor its BMPs accordingly to address
Not
---
the non -attainment?
Applicable
Comments
The updated SWMP includes metrics/plans for evaluation, modifications, and updates to SWMP components.
Audit Date(s): 2/20/2020 Page 4 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NC5000431
Program Implementation, Documentation & Assessment
ILA.3
Keeping the
The permittee kept the Stormwater Plan up to date.
Yes
---
Stormwater Plan
Up to Date
The permittee notified DEMLR of any updates to the Stormwater Plan.
Yes
---
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
Previously the SWMP was not kept up to date. The new draft SWMP has provisions to ensure timely/necessary modifications on a
varying schedule depending on the component (quarterly, semi-annually, annually, etc.)
The permittee kept an up-to-date version of its Stormwater Plan available to the
II.A.4 Availability
of the Stormwater
Division and the public online.
Yes
Plan
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
Yes
---
authority necessary to implement and enforce the requirements of the permit.
Comments (Note what materials are available on line)
The WPCOG will ensure that the updated SWMP and all relevant documents will be available on their website, as well as the City
will ensure availability on their website.
Not
II.A.3 & II.A.5
Stormwater Plan
Did DEMLR require a modification to the Stormwater Plan?
Reviewed
___
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Reviewed
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)
Not
ILA& Sharing
Responsibility
Are an control measures implemented b an entity other than the permittee?
Y P Y Y p
Reviewed
If yes, is there a written agreement in place?
Not
Reviewed
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable) The City of Conover has contracted with the WPCOG to help administer all aspects of their Stormwater Program
excluding SCM plan review
The permittee maintained written procedures for implementing the six minimum
IIA3
Written
control measures.
Yes
---
Procedures
Written procedures identified specific action steps, schedules, resources and
Yes
responsibilities for implementingthe six minimum measures.
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
The updated SWMP has procedures for documentation and recordkeeping outlined
Audit Date(s): 2/20/2020 Page 5 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Program Implementation, Documentation & Assessment
III, A The permittee maintained documentation of all program components including, but
Program not limited to, inspections, maintenance activities, educational programs, Yes ---
Documentation implementation of BMPs, enforcement actions etc., on file for a period of five years.
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
The updated SWMP addresses specific documentation metrics for all of the minimum measures from both the City and the WPCOG.
The WPCOG Stormwater Program already has tracking metric procedures in place.
III.B The permittee submitted annual reports to the Department within twelve months
Not
Annual Report from the effective date of the permit (See Section 111.B. for the annual reporting Reviewed
Submittal period specific to this MS4).
The permittee submitted subsequent annual reports every twelve months from the Not
scheduled date of the first annual report submittal. Reviewed
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation Not
of each major component of the Stormwater Plan for the past year and Reviewed
schedules and plans for the year following each report.
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for Yes ---
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater Yes
Plan.
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the Yes
Stormwater Plan.
S. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement Yes
actions.
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The updated SWMP includes procedures for modifying components of the program, metrics that can be used to summarize and
assess the program for the year— expanding from the prior outreach focused reports
IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific ves ---
quantities achieved and summaries of enforcement actions.
2. A description of the effectiveness of each program component. Yes I ---
Planned
activities and changes for the next reporting period, for each Yes ---
program component or activity.
Audit Date(s): 2/20/2020 Page 6 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Program Implementation, Documentation & Assessment
4. Fiscal analysis. Yes ---
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
The updated SWMP focuses heavily on tracking and analysis of the program. Thorough documentation of the program will be used
to develop more compliant annual reports for all components of the stormwater program.
Audit Date(s): 2/20/2020 Page 7 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NC5000431
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Permit Citation
Supporting
Program Requirement Status
Doc No,
II.B.2.a
The permittee defined goals and objectives of the Local Public Education and Not
Goals and
Outreach Program based on community wide issues. Reviewed
Objectives
Comments (Generally describe process for establishing goals/objectives)
The permittee maintained a description of the target pollutants and/or stressors and
II.B.2.b
yes
---
Target Pollutants
likely sources.
Comments (List target pollutants, note any that are missing or not appropriate)
The WPCOG has a program in place to educate the public and municipal employees on target pollutants and the effects they have.
These pollutants include: Litter, sediment, fecal bacteria, gray water, fats oils and grease, animal operations (albeit minor),
underground storage/septic tanks, chemicals, Illicit discharges, illegal dumping, and ensuring the correct disposal of waste.
The permittee identified, assessed annually and updated the description of the target
I B,2.c
Target Audiences
audiences likely to have significant storm water impacts and why they were selected.
Yes
Comments (Describe any changes made, if applicable)
The updated SWMP has plans to address Target Audiences with a focus on preventing further issues through education/outreach.
Audit Date(s): 2/20/2020 Page 8 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NC5000431
Public Education and Outreach
11.B.2.d Residential
The permittee described issues, such as pollutants, the likely sources of those
and Industrial/
pollutants, potential impacts, and the physical attributes of stormwater runoff in
Not
Reviewed
commercial Issues
their education/outreach program.
Comments (Generally describe the residential/industrial/commercial issues addressed)
promoted and maintained an internet web site designed to convey theInformational
II.13.2.e
[Thepermittee
Yes
ram's message.
Web Site
Comments (list web page address and general contents, or attach screen shot of landing page)
The City of Conover will be using the updated/expanded WPCOG stormwater page (which will have an education & outreach
section) in addition to adding this to their own municipal website.
The permittee distributed stormwater educational material to appropriate target
ves
11.B.2.f
Public Education
Materials
groups.
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
As outlined in the Draft SWMP the WPCOG will be creating and using materials that will be distributed during presentations, at
select municipal facilities, conferences, events, and available elsewhere.
The permittee promoted and maintained a stormwater hotline/helpline for the
11.13.2.>;
Hotline/Help Line
purpose of public education and outreach.
Yes
Comments (Note hotline contact information and method(s) for advertising it)
The City will be utilizing the W PCOG stormwater hotline as well as forwarding from their own number. The hotline will be
advertised on distributed materials, social media posts, and both the WPCOG and Conover's website.
Audit Date(s): 2/20/2020 Page 9 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Public Education and Outreach
11.B.2.h The permittee's outreach program, including those elements implemented locally or
Not
Public Education
through a cooperative agreement, included a combination of approaches designed to gevtewea
and Outreach reach the target audiences.
Program
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent Yes ---
of exposure.
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
WPCOG will document the audience and estimates of the number of people reached per event, presentation, or otherwise. This is
outlined in the Draft SWMP
Additional
Comments:
Audit Date(s): 2/20/2020 Page 30 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Public Involvement and Participation
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
SYaYUS Supporting
Program Requirement Doc No.
II.C.2.a Volunteer
Community
The permittee included and promoted volunteer opportunities designed to promote Yes
Involvement
ongoing citizen participation.
Program
Comments (Note opportunities promoted and date(s) of volunteer events)
Previously the City took part in some events or held clean up events (adopt a creek, drain stenciling, taking part in a stormwater
advisory board, etc.) but did not document the needed metrics to analyze how effective the events were. Events and activities will
be more thoroughly documented (number of people, activities, amt, of waste collected, etc. as outlined in the draft SWMP)
II.C.2.b
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Not
Public
provides for input on stormwater issues and the stormwater program.
Reviewed
Involvement
Comments (Note mechanism(s)for input and how promoted)
The permittee promoted and maintained a hotline/helpline for the purpose of publicF:Yes77H
II.C.2.c
otline/Help Line
involvement and participation.
Comments (Note hotline contact information and how it is promoted)
The City will utilize the WPCOG stormwater hotline — it will be advertised on both websites and written on educational materials
Audit Date(s): 2/20/2020 Page 11 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Public Involvement and Participation
Additional
Comments:
Audit Date(s): 2/20/2020 Page 12 of 31

M54 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title,
Role)
Permit Citation
Status Supporting
Program Requirement Doc No,
II.D.2.a
IDDE Program
The permittee maintained a written IDDE Program. Yes ---
If yes, the written program includes provisions for program assessment and
Yes -
evaluation and integrating program.
Comments (Note any deficiencies)
The City already has a IDDE program in place with written Standard Operating Procedures, however they were not as in-depth as
required by the permit. This will be rectified as the IDDE program is expanded and the ordinance is updated.
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
Not
provides the legal authority to prohibit illicit connections and discharges to the MS4.
Reviewed
II.D.2.b
Legal Authorities
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part I.D]
Reviewed
Comments
The permittee maintained a current map showing major outfalls* and receiving
II.D.2.c
Storm Sewer
ves
streams.
System Map
Comments
A previous MS4 map exists but is somewhat missing some required elements. The City plans to update this map into compliancy by
contracting the WPCOG for the map updates/additions.
"Major outfalls are discharges from > 36"diameter pipes or drainage areas of > 50 acres. In areas zoned far industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
II.D.2.d The permittee maintained a program for conducting dry weather flow field
Yes
Dry Weather Flow
observations in accordance with written procedures.
Program
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)
The City previously did not do dry weather outfall/flow monitoring. This will be rectified by doing annual inspections of outfalls
during the winter each year
Audit Date(s): 2/20/2020 Page 13 of 31

VIS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Illicit Discharge Detection and Elimination (IDDE)
II.D.2.e
The permittee maintained written procedures for conducting investigations of
Yes
Investigation
identified illicit discharges.
Procedures
Comments (Generally describe what procedures are documented)
The City already has a IDDE program in place with written Standard Operating Procedures, however they were not as in-depth as
required by the permit. This will be rectified as the IDDE program is expanded. The new procedures include recording: date of
report, source of report, type of issue, specific details/report of issue, actions to remediate the issue, and when the issue was
repaired.
II.13.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
Track and following:
Document
Investigations
1. The date(s) the illicit discharge was observed
Yes
---
2. The results of the investigation
Yes
---
3. Any follow-up of the investigation
Yes
---
4. The date the investigation was closed
Yes
---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism fs
used)
The Draft SWMP has the documentation/tracking/analysis built into our Standard Operating Procedures as this will enable annual
analysis and see where our shortcomings may be.
II.D.2,g Employee
The permittee implemented and documented a training program for appropriate
Training
municipal staff who, as part of their normal job responsibilities, may come into
Not
Reviewed
contact with or otherwise observe an illicit discharge or illicit connection.
Comments (Generally describe the staff training program, including frequency and which staff are trained)
The permittee informed public employees of hazards associated with illegal
II.D.2.h
Public Education
discharges and improper disposal of waste.
Yes
The permittee informed businesses of hazards associated with illegal discharges and
yes
improper disposal of waste.
The permittee informed the general public of hazards associated with illegal
Not
---
discharges and improper disposal of waste.
Reviewed
Audit Date(s): 2/20/2020 Page 14 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Illicit Discharge Detection and Elimination (IDDE)
Comments (Note how each sector was informed, if applicable)
The updated WPCOG education program now focuses on municipal employees, the general public, and businesses
as well. This will
be accomplished through presentations, trainings, events, and distributed materials.
The permittee promoted, publicized, and facilitated a reporting mechanism for the
Not
II.13.2.i
Public Reporting
public to report illicit discharges.
Reviewed
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
Not
to report illicit discharges.
Reviewed
The permittee established and implemented response procedures for citizen
Yes
requests/reports.
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)
The WPCOG illicit discharge program already has a focus on responding to citizen requests/complaints. As calls
come in from either
the citizen directly or from a municipal employee (town planner or manager usually) will contact the WPCOG on their behalf.
The permittee implemented a mechanism to track the issuance of notices of violation
II.D.2.0
Enforcement
and enforcement actions administered by the permittee.
Yes
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance.
Yes
---
Comments (Generally describe the established tracking mechanism, if applicable)
The existing WPCOG illicit discharge program tracks all issues as they are reported. The method of which the incidents are recorded
(tracking sheets, a GIS online map, and reports) allow us to see repeat violators.
Audit Date(s): 2/20/2020 Page 15 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Construction Site Runoff Controls
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Program Delegation Status:
® The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
❑ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Supporting
Status .
No.
II.E.3 Construction
Site Runoff Controls The permittee provides and promotes a means for the public to notify the
(NPDES Permit No. appropriate authorities of observed erosion and sedimentation problems (e.g., Yes ---
NCS0004351 promoting the existence of the DEQ DEMLR "Stop Mud" hotline).
Comments (Describe how provided and promoted)
Catawba County manages the Sediment and Erosion control for the City of Conover. The City (and WPCOG) will direct citizens to the
correct place or investigate issues on behalf of the citizen to report back to the County. The main contact information can be found
on Catawba Counties website
SPCA Citation
Delegated Program Requirement
Status
Supporting
Doc No,
113A-60 Local
The permittee has adopted an ordinance or other regulatory mechanism to enforce
Not
erosion and
the erosion and sedimentation control program.
Applicable
sedimentation
control programs (a)
If yes, the ordinance meets or exceeds the minimum requirements of the
Not
SPCA.
Applicable
If yes, the ordinance applies throughout the corporate limits of the permittee.
Not
[Permit Part 1.D]
Applicable
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
The City has included a sediment and erosion control section in their ordinance, however it only points to Catawba County for
depth/procedures.
§ 113A-60 Local
erosion and
The permittee collects a fee paid by each person who submits an erosion and
Na
sedimentation
sedimentation control plan.
control programs (d)
Audit Date(s): 2/20/2020 Page 16 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Construction Site Runoff Controls
Comments (indicate the fee amount, if applicable)
As Catawba County is delegated to permit SEC for the City, the County collects the fee and SEC plans
Has any person initiated a land -disturbing activity (within the permittee's
§ 113A-60 Local
erosion and
jurisdiction) for which an erosion and sedimentation control plan is required in the
Not
Reviewed
sedimentation
absence of an approved plan?
control programs (e)
If yes, the permittee has notified the North Carolina Sedimentation Control
Not
Commission of all such cases.
Reviewed
Has the permittee determined that a person engaged in a land -disturbing activity
Not
has failed to comply with an approved erosion and sedimentation control plan?
Reviewed
If yes, has the permittee referred any such matters to the North Carolina
Not
Sedimentation Control Commission for inspection and enforcement?
Reviewed
Comments
The permittee reviews each erosion and sedimentation control plan submitted to
11§ 3A-61 Local
approval of erosion
them and notifies the person submitting the plan that it has been approved,
Not
Applicable
and sedimentation
approved with modification, or disapproved within 30 days of receipt.
control plans
The permittee only approves an erosion and sedimentation control plan upon
Not
determining that it complies with all applicable State and local regulations.
Applicable
The permittee has disapproved of an erosion and sedimentation control plan in
Not
order to protect riparian buffers along surface waters.
Applicable
If yes, the permittee notified the Director of the Division of Energy,
Not
Mineral, and Land Resources within 10 days of the disapproval.
Applicable
Comments
§ 113A-61.1
Inspection of land-
The certificate of approval of each erosion and sedimentation control plan
Not
disturbing activity;
approved by the permittee includes a notice of the right to inspect.
Applicable
notice of violation
(a)
The permittee provides for inspection of land -disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
PPcable
Applicable
erosion and sedimentation control plan are effective.
Comments
Audit Date(s): 2/20/2020 Page 17 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NC5000431
Construction Site Runoff Controls
§ 113A-61.1
When the permittee determines that a person engaged in land -disturbing activity
Inspection of land-
has failed to comply with the SPCA, the Permittee immediately issues a notice of
Not
Applicable
disturbing activity;
violation upon that person.
notice of violation
Each notice of violation issued by the permittee specifies the date by which the
Not
(c)
person must comply.
Applicable
Each notice of violation issued by the permittee informs the person of the actions
Not
that need to be taken to comply.
Applicable
Comments
The City will initiate an investigation for individuals who fail to comply with SPCA, but Catawba County ultimately enforces it.
Does the permittee issue civil penalties as part of the erosion and sedimentation
§ 113A-64 Penalties
No
program?
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
Catawba County assesses violations and collected penalties
Audit Date(s): 2/20/2020 Page 18 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Post -Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Audit Date(s): 2/20/2020 Page 19 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Post -Construction Site Runoff Controls
Implementation (check all that apply):
® The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure:
® The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) —15A NCAC 26 .0212
❑ Water Supply Watershed II (WS-II) —15A NCAC 213,0214
❑ Water Supply Watershed III (WS-III) —15A NCAC 213,0215
® Water Supply Watershed IV (WS-IV) —15A NCAC 2B .0216
❑ Freshwater High Quality Waters (HQW)-15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 213 .0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B.0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
® DEQ model ordinance
❑ MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Instructions:
For MS4s not implementing a S.L. 2006-246 deemed -compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed -compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed -compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed -compliant program.
Session Law 2006- Status Program Requirement supporting
Program
246
Audit Date(s): 2/20/2020 Page 20 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Post -Construction Site Runoff Controls
Deemed -Compliant
The permittee implements deemed -compliant Program requirements in
Program(s)
accordance with the applicable 15A NCAC rules.
The permittee implements deemed -compliant Program requirements throughout
FReviewed
the entire MS4 area (If not, also complete the Permit Citation section below.)
The permittee applies deemed -compliant Program requirements to all federal,state
and local government projects within the permitted MS4 area who do not
Reviewed
have their own NPDES stormwater permit.
The permittee included deemed -compliant Program reporting in their MS4 Annual
Not
Reports,
Reviewed
included deemed -compliant Program implementation in theirNot
[Thoerpermitlee
mwater Management Plan,
Reviewed
Comments
Permit Citation
Program Requirement
Status
Supporting
ooP No.
II.F2.a
The permittee maintained an ordinance or other regulatory mechanism designed
Legal Authorityto
meet the objectives of the Post -Construction Site Runoff Controls Stormwater
1
Not
Reviewed
Management Program.
If yes, the ordinance applies throughout the corporate limits of the permittee
(Verify permit coverage area listed in Part LD of permit and modify
Not
Reviewed
accordingly).
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
Not
Reviewed
control measures will be installed, implemented, and maintained.
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
Not
evaluate compliance with the Post -Construction Stormwater Management
Reviewed
Program.
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
Not
Reviewed
_
- —
related to stormwater discharges.
Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement
the program within the MS4 area)
Not
ILF.2.b
Stormwater Control
The permittee utilizes strategies which include SCMs appropriate for the MS4.
Reviewed
Measures (SCMs)
Not
SCMs comply with 15A NCAC 02H .1000.
Reviewed
Audit Date(s): 2/20/2020 Page 21 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Post -Construction Site Runoff Controls
Comments
The permittee conducted site plan reviews of all new development and
II.F.2.c
Plan Reviews
redeveloped sites that disturb greater than or equal to one acre (including sites
Not
that disturb less than one acre that are part of a larger common plan of
Reviewed
development or sale).
If yes, the site plan reviews addressed how the project applicant meets the
Not
performance standards.
Reviewed
If yes, the site plan reviews addressed how the project will ensure long-term
Not
maintenance.
Reviewed
_
Comments
The City has contracted WK Dickson & Co, inc. for plan reviews and the WPCOG will handle the documentation/tracking side of
SCM/Stormwater permitting.
The permittee maintained an inventory of projects with post -construction
II.F.2.d
Inventory of Projects
structural stormwater control measures installed and implemented at new
Yes
---
development and redeveloped sites.
The inventory included both public and private sector sites located within the
permittee's corporate limits that are covered by its post -construction ordinance
Yes
---
requirements.
Comments
The City of Conover will be using/added to the preexisting WPCOG SCM tracking sheets as outlined in the Draft SWMP
The permittee provided mechanisms such as recorded deed restrictions and
II.F2.e
Deed Restrictions
protective covenants that ensure development activities will maintain the project
Yes
and Protective
consistent with approved plans.
Covenants
Comments
The mechanisms for deed restrictions and their covenants will be developed and enforced as per the Draft SWMP
The permittee implemented or required an operation and maintenance plan for
Not
II.F.2.f
Mechanism to
the long-term operation of the SCMs required by the program.
Reviewed
___
Require Long-term
Operation and
The operation and maintenance plan required the owner of each SCM to perform
Not
Maintenance
and maintain a record of annual inspections of each SCM.
Reviewed
Annual inspection of permitted structural SCMs are required to be performed by a
Not
qualified professional.
Reviewed
_
Comments
Audit Date(s): 2/20/2020 Page 22 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Post -Construction Site Runoff Controls
II.F.2.g The permittee conducted and documented inspections of each project site covered
Inspections of under performance standards, at least one time during the permit term (Verify this Yes
Structural is a permit condition in Part II.F.2.g of permit and modify accordingly).
Stormwater Control Before issuing a certificate of occupancy or temporary certificate of occupancy, the
Measures permittee conducted a post -construction inspection to verify that the permittee's
performance standards have been met or a bond is in place to guarantee Yes
completion( Verify this is a permit condition in Part II.F.2.g of permit and modify
The permittee developed and implemented a written inspection program for SCMs I
installed pursuant to the post -construction program(Verify this is a permit Yes
condition in Part II.F.2.q of permit and modify accordingly.
The permittee documented and maintained records of inspections. I ves ---
The permittee documented and maintained records of enforcement actions. ves I --
Comments
The WPCOG will be managing the inspection program for the City which
operating procedures.
II.F2.h The permittee made available through paper or elects
Educational post -construction requirements, design standards chf
Materials and appropriate for developers.
Training for Note: New materials may be developed by the permit
Developers materials adapted from other programs and adapted
development and redevelopment program.
Comments (if the permittee has adopted materials from other programs, im
II.F_2.i Enforcement The permittee tracked the issuance of notices of violati n
Ves
actions.
If yes, the tracking mechanism included the ability to identify chronic violators
Yes
for initiation of actions to reduce noncompliance.
Comments
The WPCOG will be handling Post -Construction violations and their enforcement on behalf of the City. Part of the standard
operating procedure for these violations is tracking and documentation. Should a situation requiring an NOV occur, it will be
addressed and documented.
Audit Date(s): 2/20/2020 Page 23 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Post -Construction Site Runoff Controls
II.F3.b
The permittee fully complies with post construction program requirements on its
New Development
own publicly funded construction projects.
ves
---
Comments
The City has not had any municipal developments or publically owned projects that require post -construction management. Should
one come up the City will follow that standard
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
NotF
II.F.3.c
Nutrient Sensitive
15A NCAC 02H .0150?
Applicable
__
Waters
If yes, does the permittee use SCMs that reduce nutrient loading in order to
Not
meet local program requirements.
Applicable
If yes, does the permittee also still incorporate the stormwater controls
Not
required for the project's density level.
Applicable
If yes, does the permittee also require documentation where it is not feasible to
Not
use SCMs that reduce nutrient loading.
Applicable
_
Comments (Provide reference for local requirements)
II.F3.d
The permittee ensured that the design volumes of SCMs take into account the
Not
Design Volume
runoff at build out from all surfaces draining to the system.
Reviewed
Where "streets" convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
Not
Reviewed
streets, driveways, and other impervious surfaces.
Comments
Audit Date(s): 2/20/2020 Page 24 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Permit Citation
Program Re uirement
g 9
Status Supporting
Doc No.
II.G.2.a
The permittee maintained a current inventory of facilities and operations owned
Facility Inventory
and operated by the permittee with the potential for generating polluted
Yes ---
stormwater runoff.
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
The WPCOG has aggregated a municipally owned facility list for The City of Conover with the building/lot types
identified and
categorized. These facilities
will be inspected to ensure they are following good housekeeping procedures per the
Draft SWMP
The permittee maintained and implemented an 0&M program for municipally
II.G.2.b
Operation and
owned and operated facilities with the potential for generating polluted
Yes
Maintenance (O&M)
stormwater runoff.
for Facilities
If yes, the O&M program specifies the frequency of inspections.
Yes
---
If yes, the O&M program specifies the frequency of routine maintenance
Yes
---
requirements.
If yes, the permittee evaluated the O&M program annually and updated it as
Yes
---
necessary.
Comments
The WPCOG will develop O&M plans for municipal facilities that can potentially generate runoff. The 0&M's will
specify frequency,
maintenance requirements, and updating procedures.
Not
II.G.2.c
Spill Response
The permittee had written spill response procedures for municipal operations.
Reviewed
Procedures
Comments
The permittee evaluated existing and new BMPs that reduce polluted stormwater
II.G.2.d Streets,
Roads, and Public
runoff from municipally -owned streets, roads, and public parking lots within its
Yes
corporate limits annually.
Audit Date(s): 2/20/2020 Page 25 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Pollution Prevention and Good Housekeeping for Municipal Operations
Parking Lots
If yes, the permittee evaluated the effectiveness of existing and new BMPs
Not
Maintenance
based on cost and the estimated quantity of pollutants removed.
Applicable
Comments
The City has evaluated its preexisting street sweeping program and will include metric tracking (lane miles swept/cleaned) for
future analysis
The permittee maintained and implemented an O&M program for the stormwater
II.G.2.f
O&M for Catch
sewer system including catch basins and conveyance systems that it owns and
Yes
---
Basins and
maintains.
Conveyance Systems
Comments (Briefly describe O&M program)
Along with MS4 Map Updates, The WPCOG (on behalf of the city) will be noting outfall and basin condition, this information will be
used to develop O&M plans for conveyances/basins.
maintained a current inventory of municipally -owned or operatedStructural
7Thepermittee
stormwater controls installed for compliance with the permittee's post-
res
Stormwater Controlon
ordinance.
Comments (Describe inventory information and number of controls in inventory)
At the time of this audit, The City of Conover does not have any publically owned SCM's in which to inventory. Should one be
developed/built the procedures are in place for its development and maintenance.
The permittee maintained and implemented an 0&M program for municipally -
II.G.2.h
O&M for Structural
owned or maintained structural stormwater controls installed for compliance with
Not
Applicable
_
Stormwater Controls
the permittee's post -construction ordinance. If yes, then:
The O&M program specified the frequency of inspections and routine
Not
maintenance requirements.
Applicable
The permittee documented inspections of all municipally -owned or maintained
Not
structural stormwater controls.
Applicable
The permittee inspected all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee maintained all municipally -owned or maintained structural
Not
stormwater controls in accordance with the schedule developed by permittee.
Applicable
The permittee documented maintenance of all municipally -owned or
Not
maintained structural stormwater controls.
Applicable
Comments
At the time of this audit, The City of Conover does not have any publically owned SCM's in which to develop O&M plans. Should one
be developed/built the procedures are in place for its development and maintenance.
Audit Date(s): 2/20/2020 Page 26 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.i
The permittee ensured municipal employees are properly trained in pesticide,
Not
Pesticide, Herbicide
herbicide and fertilizer application management.
Reviewed
and Fertilizer
Application
The permittee ensured contractors are properly trained in pesticide, herbicide and
Not
Management
fertilizer application management.
Reviewed
The permittee ensured all permits, certifications, and other measures for
Not
applicators are followed.
Reviewed
Comments
The permittee implemented an employee training program for employees involvedFRevNewed
II.G.2.j
Staff Training
in implementing pollution prevention and good housekeeping practices.
Comments
II.G.2.k
he permittee described and implemented measures that prevent or minimize
Vehicle andontamination
7'iing(
of stormwater runoff from all areas used for vehicle and equipment
Not
Reviewed
Equipment Clealeaning.
Comments
Audit Date(s): 2/20/2020 Page 27 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
Terry Lail, Environmental Coordinator
(Name, Title, Role)
Program Status:
❑ The permittee is not subject to an approved TMDL (skip the rest of this section).
❑x The permittee is subject to an approved TMDL for: Clark Creek Fecal Coliform 11/12/2002
There ® is ❑ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.1-1.1-5
below. If there is not a WLA, skip to item II.1-1.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee's annual reports included
a description of existing programs, controls, partnerships, projects and strategies to Yes ---
address impaired waters.
Within 12 months of final TMDL approval, the permittee's annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and Yes ---
strategies address impaired waters.
Comments
As written in the Clark Creek TMDL document: 'However, two of these permitees, Fairgrove WWTP and Conover WWTP, did not
discharge effluent during the study period, 1996 through 2000."The City does not have a point source discharge into Clark Creek, so
their options on reducing impairment of the stream must come from non -point sources and outreach. The draft SWMP contains
BMPs focused on educating about fecal issues as well as implementing both pet waste and waste water sections in an updated
stormwater/illicit discharge ordinance.
Within 24 months of final TMDL approval, the permittee's annual reports included
ILH.4 TMDLs
an assessment of whether additional structural and/or non-structural BMPs are
Yes
---
necessary to address impaired waters.
Within 24 months of final TMDL approval, the permittee's annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
Yes
---
strategies address impaired waters.
Comments
During the next permit cycle, the City will evaluate if a structural BMP would be effective in comparison to non-
structural/educational BMPs.
Audit Date(s): 2/20/2020 Page 28 of 31

VIS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
Total Maximum Daily Loads (TMDLs)
II.H.S TMDLs
Within 36 months of final TMDL approval, the permittee's annual reports included
a description of activities expected to occur and when activities are expected to
Yes
occur.
Comments
The Draft SWMP outlines BMP's and activities that will be aimed to reducing fecal coliform loads on Clark Creek,
If there is no Waste Load Allocation in the approved TMDL, the permittee
II.H.6 TMDLs
evaluated strategies and tailored and/or expanded BMPs within the scope of the
Not
six minimum measures to enhance water quality recovery strategies in the
Applicable
watershed(s) to which the TMDL applies.
The permittee described strategies and tailored and/or expanded BMPs in their
Not
Stormwater Management Plan and annual reports
Applicable
Comments
Audit Date(s): 2/20/2020 Page 29 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No. NCS000431
APPENDIX A: SUPPORTING DOCUMENTS
Audit Date(s): 2/20/2020 Page 30 of 31

MS4 Permit Audit Report
CONOVER, NC: NPDES Permit No, NCS000431
APPENDIX B: PHOTOGRAPH LOG
Audit Date(s): 2/20/2020 Page 31 of 31