NCS000395_Meck Co FY2021 SWQMP Eval Recs_20201028

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FY2021 Recommendations for Improvement for Phase II Permit
Mecklenburg County Permit No. NCS000395
October 28, 2020

In October 2020, an annual assessment of the SWMP was completed and a report was submitted
to the NCDEQ. The assessment included a review by all supervisors and key staff as well as the
program manager responsible for implementation of the SWMP. As a result of this assessment,
the SWMP was found to effectively and efficiently describe the measures undertaken by
Mecklenburg County for compliance with Permit requirements. Some changes to the SWMP
were identified for implementation in FY2021 to better describe existing practices and improve
documentation that do not necessarily affect Permit compliance. These changes are described in
Table 1 below. In addition, several changes were made in grammar and wording throughout the
document that are not listed below. All changes are documented using the Track Changes
feature in Word. This document is location on the LAN as follows: G:\WaterQuality\
WQ_Xfer\WQ\ Phase II Permit\Storm Water Management Plan\FY2021 Storm Water Quality
Management Program Plan with Track Changes. In addition to the changes to the SWMP, the
annual assessment also resulted in changes to the FY2021 Work Plan that is used to describe in
detail the procedures, including staff assignments and deadlines, for implementation of the
SWMP. These changes are described in Table 2 below. The annual assessment and the FY2021
SWMP are posted on the website at http://stormwater.charmeck.org (select Surface Water
Quality, select Program Overview, select Phase II Permit).

Table 1: Changes to the FY2020 SWMP for Implementation in FY2021
# Location of
Change Description of Change Justification Impact to Storm Water
Plan
1 Section 2.5 Updated Table 3 to reflect changes to the
TMDLs for Mecklenburg County’s Phase I
and II jurisdictions.
Document changes to
TMDLs since FY2019.
Compliance with Permit
requirements.
2 Section 2.8 Changed Table 8 to include a column
describing “Potential Impacts/Physical
Attributes” of Targeted Pollutants.
This is a 2020 Internal
Audit recommendation.
Required by Section B,
2, d of or Permit
(#NCS000395).
Compliance with Permit
requirements.
3 Section 2.8 Table 8 was changed to add “Litter” as
Targeted Pollutants.
Litter is a significant
pollutant in
Mecklenburg’s Phase II
areas.
Improve targeting of
educational efforts.
4 Section 3.2 Changed Table 9 to reflect that David
Caldwell and not Deania Russo is the
Responsible Staff assigned to PE-9.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
5 Section
3.4.6
Added a description of targeted outreach on
a watershed scale such as for compliance
with TMDLs.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
6 Section 3.5 Added this Section to describe our outreach
to the County’s diverse population.
Necessary to reach the
targeted audiences.
Compliance with Permit
requirements.
7 Section 3.6 Added this Section to describe the new
Communication Plan that includes the
methodology and tools that we use to
promote public education and involvement
as well as to communicate information
This is a 2020 Internal
Audit recommendation.
Recommended by EPA.
Improves consistency of
communications.
2

# Location of
Change Description of Change Justification Impact to Storm Water
Plan
regarding spills and other incidents
responded to by CMSWS.
8 Section 4.2 Changed Table 10 to reflect that Ashley
Smith and not Deania Russo is the
Responsible Staff assigned to PE-I(14).
Reflects how this work
is being performed.
Reflects how this work is
being performed.
9 Section 5.2 Changed Table 11 to reflect changes in
staff responsibilities for ID-1, ID-3, ID-5,
and ID-U.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
10 Section 5.4 Changed Figures 8, 11, and 12 to reflect
current Cityworks screen shot.
Reflects current
database.
Reflects current database.
11 Section 5.5 Added a description of ordinance changes
in FY2020.
Reflect changes. Reflects current
enforcement provisions.
12 Section
5.7.1.2
Updated Figure 10 (SUSI Map) to the
current 2020 version.
Reflects current map. Reflects current map.
13 Section
5.7.1.2
Added the second Thursday to the second
Tuesday of each month for Fixed Interval
Monitoring.
Reflects a change made
due to COVID.
Reflects a change made
due to COVID.
14 Section
5.7.2.1
Changed description of Illicit Discharge
Elimination Program (IDEP).
Reflects how this work
is being performed.
Reflects how this work is
being performed.
15 Section 5.10 Added a new measure of success for the
IDDE Program based on minimizing the
number of repeat violators.
Measure effectiveness
of ordinances adopted
in FY2020 and
accompanying
enforcement
procedures.
Measure of success of
BMPs.
16 Section 6 Added a description of the Town of
Huntersville’s role in the implementation of
the erosion control program in their
jurisdiction.
Reflects change in how
work is being done
effective July 1, 2019.
Reflects change in how
work is being done
effective July 1, 2019.
17 Section 8.3 Changed wording to better reflect process
for identifying facilities subject to the
Pollution Prevention & Good
Housekeeping Program.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
18 Section 8.3 Changed Table 17 to include the Latta
Plantation and McDowell Nature Preserves.
These facilities were
added in FY2020.
Compliance with Permit
requirements.
19 Section 8.3 Updated Tables 19 and 20 to include
current contact information and to remove
the Charlotte Recycling Center.
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
20 Sections 8.5
and 8.9
Added the language that CMSWS obtains
pesticide license numbers for all employees
and contractors performing application
activities and conducts a search on the NC
Dept. of Agriculture and Consumer
Services website to ensure all licenses are
valid.
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
21 Section 8.9 Added the language that during annual
inspections CMSWS will obtain a copy of
annual pesticide application records. These
records will be reviewed by the inspector
and compared to previous years to
determine if there have been significant
increases in the quantities applied or areas
treated in which case further investigations
Reflects changes made
in personnel in
FY2020.
Compliance with Permit
requirements.
3

# Location of
Change Description of Change Justification Impact to Storm Water
Plan
will be performed to determine if permit #
NCG560000 should be obtained. The
application records, results of further
investigations and copies of permits issued
will be maintained in the facility’s file.
22 Section 9.2 Changed Table 24 to reflect that Tim Besier
and not Rusty Rozzelle is the Responsible
Staff assigned to IW-1, IW-2, and IW-4.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
23 Section
9.3.2
Changed the Section title from
Chlorophyll-a to Nutrient TMDL and
described the impacts of nutrients on water
quality as well as the use of Chlorophyll-a
as proxy to nutrient standards in N.C.
Improved description of
TMDL.
Focuses on nutrient issues
relating to the TMDL.
24 Section
9.9.1
Changed Table 29 to include new numbers
for 2019 and increases from 2011.
Reflects current data. Reflects current data.
25 Sections
9.9.1, 9.9.2,
and 9.9.3
Updated to include a discussion of data
collected through 2019.
Reflects current data. Reflects current data.
26 Section
9.10.1 and
9.10.2
Added the additional BMP measures
implemented in FY2020.
Reflects current data. Reflects current data.
27 Section
9.10.4
Added the additional BMP measures
implemented in FY2021.
Reflects compliance
measures to be
implemented in
FY2021
Compliance with Permit
requirements.
28 Section 10.2 Added section describing how activities are
documented for Permit compliance.
This is a 2020 Internal
Audit recommendation.
Reflects how this work
is being performed.
Compliance with Permit
requirements.
29 Section 10.3 Added section to describe the annual
assessment of the SWMP and
recommended changes as well as
recommended changes to the FY21 Work
Plan.
Documentation of
existing process.
Compliance with Permit
requirements.
30 Section 10.4 Changed text and Table 31 to reflect
FY2021 budget numbers.
Represents current data. Represents current data.
31 Appendix A Changed PE-I(14), PE-9, ID-U, IW-1, IW-
2, and IW-4 to reflect new staff
assignments and contact information.
Reflects how this work
is being performed.
Reflects how this work is
being performed.
32 Appendix B Updated organizational chart. Reflects staffing
changes from FY2020.
Reflects staffing changes
from FY2020.
33 Appendix D Updated procedures for inclusion of
facilities and/or operations into the
Pollution Prevention Program
Reflects changes that
will be implemented
effective FY2021.
Compliance with Permit
requirements.
34 Appendix E Updated inspection checklist. Reflects changes that
will be implemented
effective FY2021.
Compliance with Permit
requirements.

Table 2: Changes to the FY2021 Work Plan
# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
Public Education and Outreach
4

# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
1 Continue to promote Stormy (mascot) for various
education events and use Stormy for pollution
prevention messages and videos.
Increase
Awareness
PE-10 Deania Russo
2 Investigate creating a children’s video using Stormy to
promote storm water education.
Increase
Awareness
PE-10 Deania Russo
3 Investigate the feasibility of hosting and promoting a
hip hop / rap video using key stormwater pollution
prevention terms for the purpose of promoting
stormwater education.
Increase
Awareness
PE-10 Deania Russo
4 Develop virtual school presentations to use for various
age groups due to COVID19 challenges.
Increase
Awareness
PE-10 Deania Russo
5 Implement the plan for education regarding the use and
negative impacts of coal tar sealants.
Increase
Awareness
PE-10 Deania Russo
6 Partner with the Regional Stormwater Partnership of
the Carolinas and JC Smith University on a WRRI
grant to improve public awareness and education of
storm water / water quality issues in underserved
communities in Charlotte.
Increase
Awareness
PE-10 David Caldwell
7 Use results from the 2020 Census to evaluate ethic and
economic groups, and languages spoken throughout
Mecklenburg County. Based on this information,
develop a plan to reach appropriate groups with public
education and outreach messaging and material.
Increase
Awareness
PE-10 Deania Russo
Public Involvement and Participation
1 Implement components of the Adaptive Management
Strategy to increase community involvement.
Increase
Volunteerism
SBP-Involvement David Caldwell
/ Ashley Smith
2 Create and implement a volunteer competition and
promote on social media
Increase
Volunteerism
PE-10 Ashley Smith
3 Promote the virtual Streamside Assessment Volunteer
Monitoring training module on social channels and
volunteer newsletter
Increase
Volunteerism
PE-10 Ken Friday
4 Continue to create monthly newsletters aimed at
volunteers to create motivation and notify them of
upcoming events.
Increase
Volunteerism
PE-10 Ashley Smith
5 Implement Adopt a Drain Program in Matthews. Increase
Volunteerism
SBP-Involvement Deania Russo
6 Continue to create monthly volunteer spotlights to
promote volunteerism and praise volunteers.
Increase
Volunteerism
PE-I(14) Ashley Smith
7 Target specific neighborhoods where storm drains have
not been marked and develop marketing to get them
involved with the Storm Drain Marking program.
Increase
Volunteerism
PI-3 Deania Russo
Illicit Discharge Detection and Elimination
1 Identify and implement new technologies or
applications to improve outfall re-inspections.
Permit
Compliance
ID-1 Silvio Conte
2 Update the IDDE manual. Permit
Compliance
ID-10 Andrew
DeCristofaro
3 Identify areas of missing stormwater inventory in the
Phase II jurisdictions and implement a collection
initiative.
Permit
Compliance
ID-1 Ryan Spidel
4 Expand the used oil inspection (ID-U) program to
include inspections at marinas.
Increase Pollution
Problems
Identified
ID-U Matt Santiago
5

# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
Construction Site Storm Water Runoff Control
1 Mecklenburg County will continue working on
changing all Erosion Control ordinances to meet the
new State model ordinance.
Improve
Compliance
CS-1 Corey Priddy
2 The Town of Huntersville will create procedural
documents and checklists for developers and
contractors to use for ordinance compliance.
Improve
Compliance
N/A Kevin Fox,
Town of
Huntersville
3 Mecklenburg County will move CMCSI to an online
platform that utilizes technology, video and County
erosion control resources.
Improve
Compliance
CS-2 Corey Priddy
4 Mecklenburg County will fully implement State
remission changes and follow through with
implementation procedure at the local level.
Improve
Compliance
CS-1 Corey Priddy
Post-Construction Site Runoff Control
1 Continue efforts to increase BMP compliance and
reduce repeat problems.
Improve
Compliance
PC-2 Corey Priddy
2 Mecklenburg County will work with the Town of
Huntersville to better transition BMPs from the
construction phase to the annual inspection phase.
Improve
Compliance
PC-3 Corey Priddy
3 Develop a process to better identify when BMPs need
to be inspected based on the Ordinance for which they
were installed.
Improve
Compliance
PC-2 Corey Priddy
Pollution Prevention/Good Housekeeping for Municipal Operations
1 Continue efforts to ensure Phase II municipal
operations and facilities are complying with NPDES
storm water permit requirements by emphasizing the
importance of ensuring compliance prior to the State
audit in 2021.
Permit
Compliance
PP-2 Richard Farmer
2 Increase efforts to ensure pesticide licenses are current
and verify continuing education requirements through
the North Carolina Department of Agriculture and
Consumer Services website and document for each
applicator.
Permit
Compliance
PP-2 Richard Farmer
Total Maximum Daily Loads
1 Routine fixed interval monitoring will continue to be
performed monthly at MY-9 on Goose Creek at Stevens
Mill Road, MY-14 on Duck Creek at Tara Oaks Lane,
and at MY1B located upstream of the Rocky River
TMDL watershed. Monthly samples will be analyzed
for 16 parameters including fecal coliform and E. Coli.
Exceedances of established water quality watch and
action levels will be identified and follow up actions
conducted as necessary for the identification and
elimination of pollution sources.
Permit
Compliance
ID-4.1 Olivia Edwards
2 By June 30, 2021, CMSWS will complete a review of
Health Department records to determine where failed
septic systems have been identified in both the Rocky
River and Goose Creek TMDL watersheds. Follow up
inspections and monitoring will be performed as
necessary to ensure the elimination of sources of fecal
coliform bacteria associated with failed septic systems
thereby addressing impaired waters.
Permit
Compliance
IW-2 Andrew
DeCristofaro
6

# Improvements Identified for Implementation in
FY2021 Desired Result
Work Plan
Program
Element
Responsible
Staff
3 By June 30, 2021, major outfalls will be inspected in
the Rocky River TMDL watershed. Dry weather flows
will be identified, and pollution sources eliminated
thereby addressing impaired waters.
Permit
Compliance
IW-2 Iva Barnes
4 By August 2020, the contractor selection process for
the proposed West Branch Rocky River restoration will
be completed. Construction activities associated with
Phase I of the project will begin by October 2020.
Currently, the Rocky River is severely eroded by storm
water flows that eat away at the stream banks. The
restoration project will stabilize the stream banks to
reduce erosion and improve water quality in the creek.
Permit
Compliance
Engineering &
Mitigation
Program
Tim Trautman