08 CMSWS IDDE Manual

Charlotte - Mecklenburg Storm Water Services

Illicit Discharge Detection and Elimination Manual

Developed for Compliance with Phase I and Phase II Storm Water Permit Requirements
Version 2.0

Updated February 2021
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

i

Table of Contents

Revision History: .................................................................................................... 1
Section 1: Introduction .......................................................................................... 2
1.1 Regulations ....................................................................................................................... 2
1.2 Goal and Objectives ......................................................................................................... 2
1.3 Location and Geography .................................................................................................. 2
1.4 Program History ............................................................................................................... 3
1.5 Legal Authority ................................................................................................................ 6
1.6 Coordination between the City, the County and the Towns ............................................ 6
1.7 Allowable Discharges of Non-Stormwater ...................................................................... 7
1.8 Updates for the IDDE Manual ......................................................................................... 8
Section 2: Monitoring to Detect Illicit Discharges .................................................. 9
2.1 Fixed Interval Monitoring ................................................................................................ 9
2.2 Lake Monitoring ............................................................................................................. 10
2.3 Continuous Monitoring and Alert Notification Network (CMANN) ............................ 11
2.4 Analysis of Monitoring Data .......................................................................................... 11
2.4.1 Watch and Action Levels ........................................................................................ 11
2.4.2 Stream Use and Lake Use Support Indices ............................................................. 13
Section 3: Identification of Illicit Discharges ......................................................... 18
3.1 Field Observations.......................................................................................................... 18
3.2 Stream Walk Program .................................................................................................... 20
3.3 Storm Sewer Inventory Program .................................................................................... 22
3.3.1 City of Charlotte Storm Sewer Inventory Program ................................................ 22
3.3.2 Mecklenburg County Storm Sewer Inventory Program ......................................... 25
3.4 Service Requests ............................................................................................................ 26
3.5 Emergency Response ..................................................................................................... 26
3.6 Illicit Discharge Elimination Program (IDEP) ............................................................... 26
3.6.1 Business Corridor Inspections ................................................................................ 27
3.6.2 Multi-Family Inspections ........................................................................................ 27
3.6.3 Hot Spot Investigations ........................................................................................... 28
3.6.4 Past Enforcement Reinspection Program................................................................ 28
3.7 Education and Outreach ................................................................................................. 28
3.8 Public Involvement ........................................................................................................ 30
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

ii

3.9 Facility Inspections ........................................................................................................ 31
Section 4: Tracking Illicit Discharges and Connections to a Source ....................... 32
4.1 Records Review.............................................................................................................. 32
4.2 On-Site Inspection .......................................................................................................... 33
4.3 Storm Drain Inspections ................................................................................................. 36
4.4 Sanitary Sewer System Inspections................................................................................ 36
4.5 Dye Testing .................................................................................................................... 37
Section 5: Eliminating Sources of Illicit Discharges and Connections .................... 44
5.1 Purpose ........................................................................................................................... 44
5.2 Procedures for Conducting Investigations of Identified Illicit Discharges .................... 44
5.3 Identify the Responsible Party ....................................................................................... 44
5.4 Unknown Spillers ........................................................................................................... 45
5.5 Issuing a Notice of Violation (NOV) ............................................................................. 45
5.6 Documentation, Review and Mailing............................................................................. 47
5.7 Follow Up Investigations ............................................................................................... 48
5.8 Enforcement Procedures ............................................................................................... 48
Section 6: Sanitary Sewer System Failures ........................................................... 55
6.1 Purpose ........................................................................................................................... 55
6.2 Background on Fecal Coliform ...................................................................................... 55
6.3 Action and Watch Levels ............................................................................................... 55
6.4 Field Indicators for Sewage............................................................................................ 56
6.5 Identifying and Eliminating the Source of Sewer System Failures ............................... 59
6.6 Sewer Discharges in Lake Norman, Mountain Island Lake, or Lake Wylie ................. 59
6.7 Municipal Sanitary Sewer System ................................................................................. 62
6.8 Private Sanitary System Repairs .................................................................................... 63
6.9 Septic System Repairs .................................................................................................... 64
Section 7: Documentation ................................................................................... 67
7.1 Purpose........................................................................................................................... 67
7.2 Cityworks Server ............................................................................................................. 67
7.3 Inspection Report ........................................................................................................... 67
7.4 Notices of Violation ........................................................................................................ 68
7.5 Photos and Maps ............................................................................................................ 71
7.6 Monitoring Data ............................................................................................................. 72
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

iii

7.7 Review and Approval of Reports .................................................................................... 74
7.8 Accessing Reports in Cityworks ...................................................................................... 74
7.8.1 Searching for Inspection Reports by ID Number ................................................... 74
7.8.2 Searching for the Work History of a Specific Feature ............................................ 74
7.8.3 Searching History by Location ............................................................................... 75
7.9 Documentation of Enforcement Actions ....................................................................... 75
Section 8: Assessment and Evaluation ................................................................. 77
8.1 Purpose ................................................................................................................................ 77
8.2 Adaptive Management ........................................................................................................ 77
8.3 Evaluation Metrics .............................................................................................................. 77
Appendices .......................................................................................................... 79

List of Figures:
Figure 1-1: Coverage Area for the IDDE Procedures ...................................................................... 4
Figure 1-2: Mecklenburg County Watersheds and Reservoirs. ...................................................... 5
Figure 2-1: SUSI Map for FY19-20 Q1 ........................................................................................... 15
Figure 3-1: Field observations indicating an illicit discharge. ....................................................... 19
Figure 3-2: Dry weather flow sampling by CMSWS staff during stream walk. ............................. 20
Figure 3-3: Stream Walk Basin Schedule ...................................................................................... 21
Figure 3-4: Example of Emergency Response call. Transportation accidents account for most
Emergency Response incidents. ................................................................................................... 26
Figure 4-1: Environmental Data Management System – online database produced and
maintained by CMSWS.................................................................................................................. 33
Figure 4-2: Short-term monitoring plan used to help identify an illicit discharge/connection
following an elevated stream sample. .......................................................................................... 35
Figure 4-3: A successful dye test reveals a discharge of sewage from apartments. .................... 38
Figure 4-4: Smoke exiting a manhole while conducting a smoke test in the area. ...................... 39
Figure 4-5: Storm system pipe video identifies an illicit discharge entering the MS4. ................ 40
Figure 4-6: Sanitary sewer pipe video identifies a broken pipe that was leaking into a storm
drain system directly below the pipe. .......................................................................................... 41
Figure 4-7: Illicit connection verified using a dye test and stationary camera setup in a drop inlet
to monitor the progression of dye. ............................................................................................... 42
Figure 4-8: Image of a fish kill resulting from a sewer leak. ......................................................... 43
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

iv

Figure 5-1: Example return receipt for certified mail. .................................................................. 48
Figure 6-1: Flowchart for Identifying and Eliminating Sanitary Sewer Failures ........................... 60
Figure 6-2: Discharge from sewer clean out. ................................................................................ 63
Figure 6-3: Common septic tank design and components. .......................................................... 65
Figure 6-4: Conventional septic system, with a traditional drainfield network. .......................... 66

List of Tables:
Table 2-1 FIM Parameters ............................................................................................................. 10
Table 2-2 Lake Monitoring Parameters ........................................................................................ 10
Table 2-3: State Water Quality Standards and Local Watch/Action Levels.................................. 11
Table 2-4: Overall SUSI Score for MC49a, September 2019 ......................................................... 14
Table 2-5: SUSI Rating Scale .......................................................................................................... 14
Table 2-6: Fecal Coliform Sub-Index Score ................................................................................... 16
Table 5-1: Applicable Local Ordinances and NOV Shells .............................................................. 46
Table 5-2: Guidance for Assessment of Civil Penalties for Mecklenburg County and Towns ...... 50
Table 7-1: Information to be Contained in Digital Files for Enforcement Actions ....................... 75

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

1

Revision History:

Version Effective Date Author Summary of Changes
1.0 February 2008 Rusty Rozzelle Original Draft
1.1 January 2009 John McCulloch Minor Revisions
1.2 February 2010 John McCulloch Minor Revisions
1.3 October 2010 John McCulloch Minor Revisions
1.4 June 2012 John McCulloch Minor Revisions
1.5 February 2014 John McCulloch Minor Revisions
2.0 March 2021 Ryan Spidel
Major Document Revisions – updated
document to reflect the latest
procedures and techniques that
CMSWS staff utilize.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

2

Section 1: Introduction

1.1 Regulations
This Illicit Discharge Detection and Elimination (IDDE) Policies and Procedures Manual
documents the current Standard Operating Procedures (SOP) for CMSWS' IDDE Program. It is
meant to satisfy Part II, Section D of the Phase I NPDES Storm Water Permit (Permit No.
NCS000240) issued to the City of Charlotte, and the Phase II NPDES Storm Water Permit (Permit
No. NCS000395) issued to Mecklenburg County and the Towns.
1.2 Goal and Objectives
The goal of Charlotte-Mecklenburg Storm Water Services’ (CMSWS’) Illicit Discharge Detection
and Elimination (IDDE) Program is to find and eliminate illicit discharges of pollution and restore
the quality and usability of Charlotte-Mecklenburg’s surface water resources.

The objectives to meet this goal are:
• Detect and eliminate illicit discharges, including preventable spills and illegal dumping to
the Municipal Separate Storm Sewer Systems (MS4s) for the City of Charlotte,
Mecklenburg County and the Towns.
• Address significant contributors of pollutants to the MS4s.
• Implement appropriate enforcement procedures and actions.
• Develop a map showing the major MS4 outfalls to State waters receiving discharges.
• Inform employees, businesses, and the general public of hazards associated with illegal
discharges and improper disposal of waste
1.3 Location and Geography
The IDDE Program is implemented throughout Mecklenburg County, the City of Charlotte and
the Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville (hereafter
referred to as “the Towns”). A map of these areas is provided as Figure 1-1: Coverage Area for
the IDDE Procedures.

Mecklenburg County covers approximately 525 square miles in the Piedmont physiographic
province of North Carolina and is characterized by an undulating topography consisting of an
alternation of valleys and rounded hills, which lends itself to a highly segmented stream
network. The drainage divide between the Catawba and Yadkin River basins runs through the
County. Approximately one-third of the land area of the County drains eastward to the Yadkin
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

3

and two-thirds drains westward to the Catawba. The County has over 3,000 miles of streams
with year-round flow and an estimated 190 miles of shoreline along its western border in three
(3) of the 11 reservoirs that comprise the Catawba River system, including Lake Norman,
Mountain Island Lake and Lake Wylie. A map of these areas is provided as Figure 1-2
Mecklenburg County Watersheds and Reservoirs.

There are an estimated 3,000 miles of storm drainpipe and 100,000 catch basins and drop inlets
in the City of Charlotte’s MS4, which directs storm water flow to the above described streams
and lakes from developed areas within the City. The MS4 serving the outlying areas of the
County and the Towns includes several hundred miles of ditches and/or pipes depending on
land development conditions. At a minimum, pipe systems in Charlotte-Mecklenburg are 15
inches in diameter and are designed for the ten-year storm event. The MS4s for all jurisdictions
are designed to carry only stormwater flows.

1.4 Program History
Charlotte-Mecklenburg has long recognized the adverse effects that illicit discharges have on
receiving waters. A program for the identification and elimination of these illicit discharges has
existed in Charlotte-Mecklenburg since 1970. In the early years of the program, thousands of
illicit discharges were eliminated in and around uptown Charlotte in Sugar and Little Sugar
Creeks and their tributaries. In 1969, aquatic surveys performed in these creeks found them to
be void of life. A survey conducted at the same locations 30 years later revealed significant
aquatic populations, largely due to restored water quality conditions resulting from the
elimination of illicit discharges.

In November 1993, the City of Charlotte was issued a Phase I Storm Water Permit that required
the development of an IDDE Program. To meet this requirement, the program that had been in
existence since 1970 was significantly modified to ensure effective coverage of the City’s
growing storm drainage system and compliance with permit requirements. In July 2005,
Mecklenburg County and the Towns were issued a Phase II Storm Water Permit and the IDDE
Program was again modified to ensure coverage of the streams and storm drains in the Towns
and County outside the City of Charlotte.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

4

Figure 1-1: Coverage Area for the IDDE Procedures

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

5

Figure 1-2: Mecklenburg County Watersheds and Reservoirs.

LAKE WYLIE
LONG CREEK MALLARD CREEK
MC DOWELL
BRIAR CREEK
LAKE NORMAN
CLARKE CREEK
MCMULLEN
PAW CREEK
SUGAR CREEK IRVINS CREEK
FOUR MILE CREEK
MID MC ALPINE CREEKSTEELE CREEK
CLEAR CREEK
REEDY CREEK
UPPER IRWIN CREEK
SIX MILE CREEK
GAR CREEK
COFFEY CREEK
UPPER LITTLE SUGAR CREEK
STEWART CREEK
BACK CREEK
TORRENCE CREEK
ROCKY RIVER WEST BRANCH
STEVENS CREEK
CAMPBELL CREEK
TAGGART CREEK MC KEE CREEK
UPPER MC ALPINE CREEK
LOWER LITTLE SUGAR CREEK
LOWER MC ALPINE CREEK
KINGS BRANCH
UPPER MTN ISLAND LAKE
LOWER MTN ISLAND / UPPER WYLIE
Lake Norman
Mountain Island Lake
Lake Wylie
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

6

1.5 Legal Authority
The City of Charlotte, Mecklenburg County and the Towns are authorized to adopt an IDDE
ordinance pursuant to North Carolina law, including but not limited to Article 14, Section 5 of
the Constitution of North Carolina; Rules promulgated by the Environmental Management
Commission pursuant to North Carolina General Statute 143-214.7; Session Law 2004-163; and
North Carolina General Statute 153A-121. The following ordinances have been developed and
are in use in Charlotte-Mecklenburg to provide the authority necessary to eliminate illicit
discharges:
1. Charlotte Stormwater Pollution Control Ordinance: Effective Date: January 30, 1995;
updated May 26, 2020. Applies within the corporate limits of the City of Charlotte (see
Appendix A).
2. Mecklenburg County Surface Water Pollution Control Ordinance: Effective Date: May 5,
2004; updated May 21, 2020. Applies in all unincorporated areas of Mecklenburg
County as well as within the corporate limits of Cornelius, Huntersville, Mint Hill and
Pineville (see Appendix B).
3. Town of Davidson Surface Water Pollution Control Ordinance: Effective Date: January
2004; updated August 25, 2020. Applies within the corporate limits of the Town of
Davidson (see Appendix C).
4. Town of Matthews Surface Water Pollution Control Ordinance: Effective Date:
November 27, 2000; updated January 14, 2020. Applies within the corporate limits of
the Town of Matthews (see Appendix D).

Right-of-Entry Section 18-82 of the Charlotte Storm Water Pollution Control Ordinance and
Section 6 of the Surface Water Pollution Control Ordinances for Mecklenburg County and the
Towns stipulate that City of Charlotte and Mecklenburg County personnel or other duly
authorized representative(s), bearing proper identification, shall be permitted to enter upon all
properties for the purpose of inspection, observation, measurement, sampling and testing in
accordance with ordinance provisions.
1.6 Coordination between the City, the County and the Towns
CMSWS is responsible for implementing the IDDE Program and administering pollution control
regulations in coordination with the City of Charlotte, Mecklenburg County and the Towns.
CMSWS consists of staff from both the City of Charlotte and Mecklenburg County. The City of
Charlotte is responsible for compliance with its Phase I Storm Water Permit but participates
with Mecklenburg County in the performance of certain duties required by the Permit,
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

7

including the implementation of its IDDE Program. The specific duties performed by the County
in the City of Charlotte are laid out in an annual Work Plan.

The Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville have
individually entered into a legally binding inter-local agreement with Mecklenburg County that
describes the specific storm water management responsibilities of each participating MS4. This
agreement, called a “Storm Water Management Program Inter-Local Agreement,” describes the
specific duties and responsibilities of Mecklenburg County and the Towns for fulfillment of
Phase II Storm Water Permit requirements. The agreements specify that the Towns are
responsible for protecting the quality of storm water runoff and surface waters within their
jurisdictions to the extent required by applicable laws and regulations. However, on behalf of
the Towns, the County will fulfill the NPDES Phase II Storm Water Permit requirements for the
Towns and the County provided the Towns adopt and enforce the regulations necessary to
support specific permit requirements, including but not limited to pollution control ordinances.

In addition to coordinating with local jurisdictions, CMSWS also works cooperatively with the
State in the implementation of its IDDE Program. In August 1986, Mecklenburg County entered
into a Memorandum of Agreement with the N.C. Department of Environment and Natural
Resources (NCDENR), now known as N.C. Department of Environmental Quality (NCDEQ) to
protect and restore water quality conditions in Mecklenburg County.

1.7 Allowable Discharges of Non-Stormwater

All jurisdictions within Mecklenburg County have provisions for allowable discharges of non-
stormwater within their ordinances. Stormwater is the only Discharge permitted in the
Stormwater System or the Waters of the State with exception of the following allowable
Incidental Non-Stormwater Discharges; provided that said Discharges do not negatively impact
surface water quality. Allowable Incidental Non-Stormwater Discharges include:

(1) Water line flushing, provided the discharge does not cause an exceedance of surface water
quality standards;
(2) Landscape irrigation;
(3) Diverted stream flows;
(4) Uncontaminated groundwater infiltration (as defined at 40 CFR §35.2005(20));
(5) Uncontaminated, pumped groundwater;
(6) Rising groundwaters;
(7) Discharges from Uncontaminated Potable Water sources;
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

8

(8) Collected infiltrated Stormwater from foundation drains or footing drains;
(9) Air conditioning condensate from residential or commercial units;
(10) Irrigation water (does not include reclaimed water as described in 15A NCAC 2H .0200);
(11) Uncontaminated springs;
(12) Uncontaminated, collected groundwater and infiltrated Stormwater from basement or
crawl space pumps;
(13) Lawn watering;
(14) Swimming pool and hot tub/spa Discharges, provided that the Discharge does not contain
chlorine, bromine, salt, or any other treatment chemicals. These Discharges do not include
swimming pool or hot tub/spa filter backwash Discharge or saltwater pool Discharge, which are
expressly prohibited;
(15) Street Washwater only when Unmodified Potable Water is used;
(16) Flows from emergency fire and rescue operations other than those resulting from
negligence on the part of the Person who owned or controlled the Pollutant. This
allowance does not include discharge flows from fire and rescue training operations.
(17) Single-family residential and Charity Vehicle Washing (*see note below);
(18) Flows from riparian habitats and wetlands;
(19) NPDES permitted discharges authorized by NCDEQ, EPA, or delegated local authority,
provided said discharges are in compliance with the requirements, conditions and discharge
limitations of the permit;
(20) Dye testing, using suitable dyes, for verifying cross-connections, tracing plumbing lines,
determining flow direction or rate and for similar purposes, provided that verbal notification by
non-governmental entities is provided to the Director prior to testing;
(21) Water used for removal of Stormwater System blockages only when Unmodified
Potable Water is used; and
(22) Splash pad (spray ground) water from a Potable Water source only; refer to Sec. 18-
81(14) if the water is treated with chemicals used similarly for a swimming pool or hot tub/spa.

1.8 Updates for the IDDE Manual
Once every five years, CMSWS will review and update this IDDE Manual and record the date of
the most recent review on the front cover. The IDDE Manual includes numerous Standard
Operating Procedures (SOPs) that provide additional detail regarding the IDDE process. These
SOPs will change more often than the manual; therefore, they will be reviewed and updated
annually.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

9

Section 2: Monitoring to Detect Illicit Discharges

CMSWS collects and evaluates qualitative and analytical monitoring data to identify significant
contributors of pollution and focus IDDE activities in priority areas. This section of this manual
provides a general overview of monitoring activities conducted to collect that data, and the
analysis of that data.

All of the water quality monitoring activities described in this section are performed in strict
accordance with a Quality Assurance and Project Plan (QAPP) where there are more detailed
procedures.
2.1 Fixed Interval Monitoring
Fixed Interval Monitoring (FIM) represents all the activities associated with collecting data on
the second Tuesday/Thursday of every month at 32 designated stream sites throughout
Mecklenburg County. At each location, physical parameters (field parameters) are measured
using a YSI Multiprobe monitoring unit, and grab samples are collected for analysis at a certified
laboratory. Monitoring activities occur regardless of weather conditions although events may
be postponed if unsafe conditions exist in the streams.

The designated long-term FIM sites are located at publicly accessible, fixed locations, generally
at bridge crossings and USGS stream flow gauging stations across Mecklenburg County to
monitor a specific watershed. The following criteria were considered during the site selection
process:
• Sites must drain >1 square mile.
o Sites draining <1 square mile have been excluded due to concerns they will not
support diverse macroinvertebrate and fish populations.
• Fairly uniform coverage of all watersheds.
o Sites are not focused up and downstream of treatment plants, nor are they
placed at restoration or BMP sites.
• Sites with established USGS Stream Gages are given greater importance.
• Sites corresponding to NC-DEQ compliance points are given greater importance.
• Single geographic features, such as the airport, are not given greater importance.

For each site, direct-grab surface water samples and in-stream instantaneous measurements
are analyzed for the parameters outlined in Table 2-1.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

10

Table 2-1 FIM Parameters (Italics parameters are instantaneous measurements collected with a
handheld device)
Dissolved oxygen Hardness Specific Conductivity Total Metals *
Dissolved metals * N-NH3 SSC TP
E Coli NO2-NO3 Temperature TSS
Fecal Coliform pH TKN Turbidity
* Parameters that are site specific and subject to change based on current year’s workplan.
2.2 Lake Monitoring
Lake Monitoring represents all the activities associated with collecting field parameters, grab
samples, and depth integrated samples across Lake Norman, Mountain Island Lake, Lake Wylie,
Lake Cornelius, and Lake Davidson (Mecklenburg County Lakes).

Most lake monitoring stations are established at publicly accessible, fixed locations that can be
accessed by boat. Where launching a boat is problematic, samples are also collected using self-
propelled kayaks (Lake Cornelius and Lake Davidson). The following criteria are considered
during the site selection process:
• Sites indicative of overall water quality.
• Sites located along the primary flow path through the reservoirs. Additionally, sites that
are in major coves along the Mecklenburg County shoreline.

Grab and depth integrated samples are collected at twenty-eight (28) lake monitoring sites
across the Mecklenburg County Lakes, during the months of January, March, May, July,
September, and November. Physical parameters (field parameters) are also measured at the
time of sample collection using a YSI EXO2 multi-parameter monitoring unit. All samples are
submitted to a certified laboratory for analysis of the parameters listed in Table 2-2 Lake
Monitoring Parameters, except for the field parameters in italics.

During the summer recreational season (May – September), surface grab samples are collected
at fourteen (14) sites across the Mecklenburg County Lakes. Samples are obtained for fecal
coliform and E. coli bacteria to help ensure that the lakes are safe for public recreation and to
help identify possible sources of contamination.

Table 2-2 Lake Monitoring Parameters (Italics parameters are instantaneous measurements
collected with a handheld device)
Dissolved oxygen N-NH3 Temperature Turbidity
Chlorophyll a NO2-NO3 TKN Turbidity
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

11

E. coli pH Total Metals (Jan/July
only) *

Fecal Coliform Specific Conductivity TP
* Parameters that are site specific and subject to change based on current year’s workplan.

2.3 Continuous Monitoring and Alert Notification Network (CMANN)
The Continuous Monitoring and Alert Notification Network (CMANN) is a network of automated
monitoring devices deployed across the County where data is collected once per hour, 24 hours
per day at thirty-four (34) fixed monitoring locations in streams and lakes. CMANN helps
identify pollution problems that need a quick response and provides data for evaluating long
and short-term water quality trends. Twenty-four (24) of the thirty-four (34) stations are
located so that they are monitoring waters that drain the City of Charlotte’s MS4. The other 10
stations are located along the lakes or in the Towns. There are two (2) mobile stations that are
moved throughout the City of Charlotte to monitor known water quality “Hot Spots” for
pollution problems.

CMANN data is collected on a fixed time interval (usually every hour, with several higher
priority sites collecting data every 15 minutes) using automated equipment. CMANN uses YSI
6820 and EXO2 multi-parameter sondes to measure turbidity, pH, temperature, conductivity,
and dissolved oxygen. All data is collected by a datalogger and transmitted via a wireless
modem to CMSWS servers for storage and display on the CMANN website
(https://cmann.mecknc.gov).

2.4 Analysis of Monitoring Data
2.4.1 Watch and Action Levels
All FIM, Lake Monitoring, and CMANN data are continually evaluated by CMSWS staff to assist
in the detection of potential pollution sources. The NC State Water Quality Standards and Local
Watch and Action Levels identified for each parameter are listed in Table 2-3: State Water
Quality Standards and Local Watch/Action Levels.

Table 2-3: State Water Quality Standards and Local Watch/Action Levels
Parameter State Standard Local Watch Level Local Action Level
Streams
Fecal coliform 200 col./100 ml(1) 400 col./100 ml(2) 3000 col./100 ml(2)
pH <6.0 and >9.0 SU < 6.5 or > 8.5 SU < 6.0 or > 9.0(2) SU
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

12

Parameter State Standard Local Watch Level Local Action Level
Temperature Narrative Standard 28o C 32o C(2)
Total phosphorus No Standard 0.05 ppm 0.10 ppm
Turbidity 50 NTU 25 NTU 50 NTU(2)
Dissolved oxygen 5.0 ppm 5.0 ppm 4.0 ppm(2)
Conductivity No Standard 250 uS/cm 550 uS/cm (3)
Lakes
Fecal coliform 200 col./100 ml(1) 100 col./100 ml 200 col./100 ml(2)
pH <6.0 and >9.0 SU <6.5 or >8.5 SU <6.0 or >9.0(2) SU
Temperature Narrative Standard 28o C 32o C
Chlorophyll a 40 ppb 12 ppb 40 ppb(2)
Secchi Disk Depth No Standard 2 meters 1 meter
Total phosphorus No Standard 0.02 ppm 0.04 ppm
Turbidity 25 NTU 15 NTU 25 NTU(2)
Dissolved oxygen 5.0 ppm 5.0 ppm 4.0 ppm(2)
Conductivity No Standard 125 uS/cm 250 uS/cm (3)
Nitrate/Nitrite No Standard 0.4 ppm 0.65 ppm
(1) N.C. Water Quality Standards states the following: “Fecal coliforms shall not exceed a geometric mean of
200/100ml. (MF count) based upon at least five consecutive samples examined during any 30 day period, nor
exceed 400/100ml. in more than 20% of the samples examined during such period; violations of the fecal
coliform standard are expected during rain events and, in some cases, this violation is expected to be caused
by uncontrollable nonpoint sources; all coliform concentrations are to be analyzed using the membrane filter
technique unless high turbidity or other adverse conditions necessitate the tube dilution method; in case of
controversy over results, the MPN 5-tube dilution technique shall be used as the reference method.”
(2) Violation of N.C. Water Quality Standards.
(3) These are “Secondary” Action and Watch Levels, meaning that an exceedance of these levels detected
through routine monitoring activities will not result in an automatic notification to the Supervisor as does an
exceedance of a “Primary” Action or Watch Level. These Secondary levels are used in field monitoring (using
the YSI) in conjunction with other indicators to identify pollution sources as discussed in Sections 2 and 3 of
this document.

All data collected from FIM and Lake monitoring are delivered to a Quality Assurance and
Quality Control (QA/QC) Officer with CMSWS, who is responsible for the compilation, review,
verification, validation, and warehousing of all water quality monitoring data products. The
Data Analyst position with CMSWS is the designated QA/QC Officer for CMSWS. On at least a
monthly basis, the QA/QC Officer compiles, assures quality, and compares samples collected
during baseflow conditions for exceedances of local Watch/Action Levels and State water
quality standards (see Table 3). Within one business day from receipt of data, the QA/QC
Officer reports all exceedances to Supervisors for the initiation of follow up actions.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

13

CMANN units have thresholds input into their systems for select parameters and an email
“Alert” is issued to an assigned staff person when CMANN detects an exceedance of one or
more of these thresholds. This alert email directs the field staff to evaluate the data and see if
this threshold exceedance is an anomaly or needs to be investigated for potential pollution
problems. CMANN data is also carefully analyzed for trends that might indicate a water quality
problem even though an alert has not been issued. Field staff review data routinely to identify
long-term trends that could be indicative of a pollution problem. If a possible pollution problem
is detected, the field staff will initiate steps to begin verifying and tracking the potential
problem. CMANN data is evaluated for quality assurance and quality control and verified by the
Senior Environmental Specialist responsible for the CMANN program bi-weekly.
2.4.2 Stream Use and Lake Use Support Indices
All FIM, CMANN and Lake Monitoring data are also evaluated quarterly through the calculation
and analysis of the locally developed water quality indices called the Stream Use Support Index
(SUSI) and the Lake Use Support Index (LUSI). In 1988, Charlotte-Mecklenburg began the use of
a water quality index developed by the National Sanitation Foundation (NSF). In 1995, this
index was combined with macroinvertebrate scores to develop what was termed the Water
Quality Rating (WQR). In 2007, CMSWS replaced the WQR with the SUSI.

These water quality indices transform large quantities of water quality data into non-technical
or quasi-technical terms that can be easily graphed and mapped for water quality managers,
policy makers and the public. A water quality index also allows comparison of water quality in a
body of water over space and time, which enables CMSWS staff to establish trends and
evaluate the effectiveness of watershed management efforts.
Stream Use Support Index (SUSI)
The SUSI index is constructed around categories of parameters determined to have the greatest
impact on the quality and usability of surface waters in Charlotte-Mecklenburg. Parameters are
equally weighted by five broad categories called sub-indices as follows:
1. Bacteria (fecal coliform bacteria),
2. Metals (chromium, copper, lead and zinc),
3. Biological (Ephemeroptera, Plecoptera, Trichoptera Index (EPT), North Carolina Biotic
Index (NCBI) and Mecklenburg Habitat Assessment Protocol (MHAP)),
4. Physical (temperature, dissolved oxygen, pH and turbidity), and
5. Nutrients (total phosphorus).

SUSI incorporates three-time horizons as follows:
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

14

1. Short Term – Includes the most recent month of data collected for the physical sub-
index. Approximately 30% of data used to calculate SUSI originates from the current
month.
2. Middle Term – Includes data collected over the past 12 months for the bacteria, metals
and nutrients sub-indices. Approximately 45% of data used to calculate SUSI is collected
over the previous 10 – 12 months. An ancillary benefit of using longer term data is to
attenuate short-term spikes or lows. Furthermore, one of the goals of the index is to
provide an indication of water quality trends.
3. Long Term – Includes data collected over the past one to two years for the biological
sub-index. Approximately 25% of the data used to calculate SUSI is collected over a one
to two-year period.

Table 2-4 shows the process for aggregating each of the sub-indices into a larger overall SUSI
Score.

Table 2-4: Overall SUSI Score for MC49a, September 2019
Sub-Index Weight Sub-Index Score Score (base 20)
Bacteria 20% 33.3 6.7
Metals 20% 100 20
Macroinvertebrate/Habitat 20% 70.1 14
Physical Parameters 20% 100 20
Nutrients 20% 0 0
Final SUSI Score for MC49a, September 2019 60.7

The SUSI Score is represented by the Rating Scale shown in Table 2-5 SUSI Rating Scale which is
used to assign adjectives to the score.

Table 2-5: SUSI Rating Scale
Overall SUSI Score Assigned Adjective Map Color
100 – 90 Supporting Green
70 – 89 Partially Supporting Yellow
50 – 69 Impaired Orange
0 – 49 Degraded Red

The overall SUSI Score for each site is assigned to the appropriate watershed. The watershed is
then colored using the Rating Scale shown in Table 2-5 and maps are produced as illustrated in
Figure 2-1 SUSI Map. Maps show each of the five SUSI sub-index ratings by watershed. These
sub-index maps identify specific watershed areas that are supporting, partially supporting,
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

15

impaired or degraded. The most significant indicator of pollution problems in Charlotte-
Mecklenburg is fecal coliform bacteria, which constitutes one of the five sub-indices in SUSI.
The fecal sub-index is based upon fecal coliform samples collected during monthly fixed interval
sampling at select sites. The index compares the current month’s sample result along with the
sample results from the previous 11 months to determine the overall score on a 100-point
scale. Each month’s fecal result is compared against the 400 cfu/100 ml portion of the State
water quality standard and if the sample result is less than or equal to 400, the month is
assigned a score of 8.33 (100 ÷ 12); if the result is greater than 400, the month is assigned a
score of 0.

Figure 2-1: SUSI Map for FY19-20 Q1
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

16

These scores are totaled for the past 12 months to calculate the overall SUSI score. Table 2-6
Fecal Coliform Sub-Index Score is presented as an example calculation for a SUSI sampling site.

Table 2-6: Fecal Coliform Sub-Index Score
Month Month Number Fecal Result Monthly Score
October 2018 1 3650 0
November 2018 2 2800 0
December 2018 3 640 0
January 2019 4 230 8.33
February 2019 5 3100 0
March 2019 6 200 8.33
April 2019 7 22000 0
May 2019 8 640 0
June 2019 9 1530 0
July 2019 10 500 0
August 2019 11 350 8.33
September 2019 12 220 8.33
Overall SUSI Score (out of 100 points) 33.33

The other primary contributors of stream impairment in Charlotte-Mecklenburg in order of
priority are turbidity (physical sub-index), biological, metals and nutrients. This priority is based
on an analysis of twenty years’ worth of data collected in Charlotte-Mecklenburg as well as an
evaluation of the State’s 303(d) list of impaired water bodies. Like fecal coliform, each of these
priority pollutants represents a sub-index in SUSI, which is calculated based on 12 months of
data. Sub-index results are made available to Supervisors quarterly using sub-index maps.
These maps and underlying index data are useful for identifying trends in degraded water
quality conditions, which trigger follow up actions to identify and eliminate pollution problems.

Lake Use Support Index (LUSI)
A separate water quality index is used for the lakes called the Lake Use Support Index (LUSI)
and is very similar to SUSI in how it is structured in that it has five (5) sub-indices most of which
are based on a trailing average of data from the last 12 months. The five (5) sub-indices for LUSI
are as follows:
• Human Health - fecal coliform bacteria
• Sediment - turbidity
• Eutrophication (algae growth) - North Carolina Trophic State Index (NCTSI)
• Physical/Chemical - field data (temperature, dissolved oxygen and pH)
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

17

• Metals - 12 mineral and toxic metals

Maps are produced every other month from the LUSI index using a colored coded key ranging
from “Degraded” to “Supporting” as illustrated in Figure 2-2. Each lake monitoring site is
colored based on its water quality index rating. The Lake Water Quality Index and fecal coliform
bacteria results from lake monitoring are presented to the local marine commissions on a
routine basis.

Figure 2-2: LUSI Map for Lake Wylie from November 2020.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

18

Section 3: Identification of Illicit Discharges

This section describes programs and activities employed by CMSWS to proactively identify illicit
discharges beyond the monitoring activities described in Section 2.

3.1 Field Observations
Illicit discharges are detected and confirmed through field observations. Figure 3-1 includes
images of typical field observations that indicate illicit discharges except for the picture of iron
bacteria, which is oftentimes reported as a water quality problem but is naturally occurring
from the intrusion into a water body of groundwater with a high iron content. Iron bacteria is
very similar in appearance to sewage fungus which is an indicator of a long-term sewage
discharge except sewage fungus is gray in color instead of orange. Unusual odors are another
field observation that can indicate an illicit discharge. Steam from a storm drain and/or surface
waters caused by a temperature differential as well as the accumulation of foam on surface
waters can also indicate the presence of an illicit discharge; however, some foam on the water
can be naturally occurring. Oil staining or other discoloration of the soil is another indication of
an illicit discharge as well as other visible alterations of the natural environment due to the
influence of a foreign chemical or substance.

If any of the above field observations are made there is a very strong likelihood that an illicit
discharge is involved, and actions must be immediately taken to identify and eliminate the
source. These actions take priority over all other work being performed. If necessary, contact
your Supervisor and obtain backup but under no circumstances are you to leave an active illicit
discharge. If the discharge is intermittent in nature, you may never observe it again. Illicit
connections can be more difficult to detect. They are usually observed as pipes, ditches or over
land flow. When inactive, the connections often cannot be distinguished from the storm drain
system. It is important to look for residue, discolored soil, odors or other indicators of a
previous discharge. If in doubt, all suspected illicit connections must be traced to their source
for confirmation of illegal activity using the techniques specified in Section 4.

The challenge with detecting an illicit discharge is to be in the right place at the right time to
make the necessary field observations described above. The more observations made the more
likely problems will be detected making citizen education and involvement important. The
following subsections describe the techniques used by CMSWS to identify illicit discharges.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

19

Figure 3-1: Field observations indicating an illicit discharge.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

20

3.2 Stream Walk Program
Stream walks are conducted throughout the City, Mecklenburg County and the Towns. The
Stream Walk Program aims to accomplish the following activities:
- Collect new stormwater outfall inventory and confirm previously documented
inventory;
- Screen stormwater outfalls for dry weather flows (DWF) and potential illicit discharges
and connections; and
- Identify areas of severe stream bank erosion, blockages, potential reference reaches.

Streams in each six-square mile basin with
stream drainages of 50 acres or more,
and/or areas with industrial land use and
drainages of 2 acres or more, are walked
at least once every five-years. Stormwater
outfalls twelve inches or larger are
surveyed for DWFs during these walks
(see Figure 3-1)

The Stream Walk Basin Schedule shows
the schedule for walking basins and
surveying stormwater outfalls for DWFs
during fiscal years 2018 through 2022
(Figure 3-2).

Stream walks are conducted during ambient conditions, 72 consecutive hours of no measurable
rainfall (<0.10”), so that dry weather flows are more easily detected. If flow is detected in the
storm sewer system under dry conditions, then there may be an illicit discharge to the system.
However, the DWF may be originating from groundwater intrusion or an allowed discharge as
listed in Section 1.6. Samples are collected from DWFs an analyzed for fecal coliform, TP and
physical water measurements (DO, pH, specific conductivity) with a handheld YSI sonde.
Figure 3-2: Dry weather flow sampling by
CMSWS staff during stream walk.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

21

Figure 3-3: Stream Walk Basin Schedule

The purpose of inventorying and sampling dry weather flows is to create a GIS inventory of the
DWF locations for potential follow up action and to determine if the flow is causing a pollution
problem. This data is used to eliminate illegal discharges.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

22

Some basins may be walked more than once every five years. In 2013 – 2018, specific basins
(Briar, Taggart, Little Sugar, Upper Little Sugar and McMullen) were targeted as priority basins
and walked once every two years. These basins were prioritized based on monitoring data
results and the significant number of illicit discharges and service requests that had occurred in
these areas. In 2018, staff changed this strategy as they developed a new basin schedule. For
2018 – 2022, the Program established a “slush fund” of approximately 20 extra miles each year.
Annually, staff will conduct an analysis of data across the City and County related to illicit
discharges, monitoring data and service requests and use this data to decide if the extra miles
will be used and which basin(s) will be targeted.

Data from the Stream Walk Program is also used to generate a map of the storm sewer system.
A more detailed description can be found in the next section 3.2 Storm Sewer Inventory
Program.

More detailed procedures for the Stream Walk Program can be found in the Quality Assurance/
Quality Control Plan and Procedures for Stream Walks and Outfall Inventory Collection/
Inspection (Appendix E) and Stream Walks & Storm Water Outfall Inventory Collection/
Inspection Procedures (Appendix F).
3.3 Storm Sewer Inventory Program
The Storm Sewer Inventory Program includes activities performed in the City, Mecklenburg
County and the Towns that help build and maintain a comprehensive GIS map of each
municipalities’ storm sewer system including inlets, outfalls, stormwater structures, drainage
areas and receiving streams. During all Storm Sewer Inventory activities, if a dry weather flow is
identified, follow-up investigations are conducted to determine if it is an illicit discharge.

The City of Charlotte, Mecklenburg County and the Towns all collect information about their
storm sewer systems during the previously described Stream Walk Program, but the City of
Charlotte and Mecklenburg County also implement additional programs to map other assets of
the storm sewer system detailed in separate operating procedures. These programs are
described separately below.

3.3.1 City of Charlotte Storm Sewer Inventory Program

Since 1991, the City of Charlotte’s Storm Sewer Inventory Program has collected data on the
existing storm drainage infrastructure to effectively manage these assets and to provide data to
permitting agencies. This program identifies stormwater structures, such as catch basins, inlets,
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

23

pipes in the field, verifies the outfall data collected by the Stream Walk Program, and collects
additional stormwater infrastructure data from the analysis of new development and municipal
project areas received from the CSWS Design and Engineering Teams and the City of Charlotte’s
Land Development division. All inventory data receives QA/QC, is converted digitally into GIS,
and made available to internal users on the City of Charlotte’s spatial data warehouse, and to
external users to view on the Virtual Charlotte website (vc.charmeck.org) or for download on
the City’s open data portal.

From 2004 - 2009, Storm Water inspectors, contractors, interns, and data collection technicians
collected data using WISE mobile GIS software and added a significant amount of data to the
original database. In January 2009, the data collection technicians began using ArcPad software
in place of WISE. As of July 1, 2009, all inventory data is collected using ArcPad.

As of July 1, 2017, the Inventory Team employs seven full-time staff members. One Inventory
Manager (job class is “GIS Coordinator”) manages the program, supervises all staff, and
maintains the databases. One Inventory Coordinator (Business Systems Specialist) performs
data QC, desktop and field data collection. Five GIS/GPS Data Collection Technicians (GIS
Technicians) perform field and desktop data collection. The team falls under the Strategic
Planning Program which was formed July 1, 2018.

All inventory data is stored in the “HydroNetwork” dataset which includes four feature classes:
structures/junctions (point layer), pipes (line), open drainage/channels (line), and connectivity
(line layer used when there is no defined open drainage or no accessible pipe). There is also a
polygon feature class for Inventory Work Zones.

The inventory database is versioned to allow multiple editors. Each data editor has their own
edit version in which they complete their work. They must reconcile their version with the
parent version in order to see all updates posted to the parent version. In turn, they must post
their own updates to the parent version for other editors to see. Conflicts arise when changes
to the same features are made in different versions. Editors reconcile their versions at the start
and end of each editing session and post only at the end of the editing session. The Inventory
Manager reconciles and posts all versions at least bi-weekly to cleanly compress the entire
database.

ArcGIS 10.4 is used for database management and data editing. ArcPad 10.2 is used with
customization for mobile data collection. Trimble Positions extension for ArcPad is used for
translating X, Y coordinate information to ArcGIS. A subscription to NC RTN GPS network is used
for real-time differential correction of GPS signals (eliminates need for post-processing GPS
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

24

data). Trimble R2 GPS receivers are used for X, Y coordinates on structures/junctions and
Toughbook CF-20 ruggedized field computers with Verizon broadband subscription are used
with an internet connection to access the RTN network.

The majority of the inventory data is collected directly in the field In December 2012, two, 2-
person full-time crews were assigned to field data collection. As of January 2019, the inventory
was estimated to be 60% complete. With potentially more than 550,000 features to collect and
two field crews continuing to collect data, the inventory was estimated to take seven (7) more
years to be 100% complete. However, in 2019, the City entered into an agreement with a
private firm (ESP) to help with field collection efforts. This work began in 2020 and should be
completed by July 1, 2021. After this collection effort with ESP has been completed, the focus
of the Inventory Team will then be on data QA/QC and re-inventory efforts in each 1-sq mile
work area.

To create manageable field data collection areas, Mecklenburg County was divided into 1-
square mile drainage basins, or Inventory Work Zones. The average data collection time per
basin is 2 weeks. The Inventory Work Zones are prioritized for data collection based on various
factors such as pending construction projects, completed construction projects, and pending
land acquisition. A crew may also be assigned a smaller data collection area where capital or
maintenance work was recently been completed.

Once a crew is assigned a data collection area, they create the ArcPad field project by “checking
out” the existing inventory data from their edit version of the master dataset in ArcGIS. In the
field, they start at the most downstream point of the basin and work upstream through all of
the open and closed systems in that basin, going outside of the basin when needed to capture
connected systems. They can update the geometry and attributes of existing inventory
features and add new features. They may not delete any features, only set them to “Inactive”
status. They also take pictures of all slab-top drop inlets, end sections, open drainage, and any
structures in poor condition.

When they return to the office, they “check in” the data to their edit version in ArcGIS.
Checking in data is basically an overwrite process and ensures that duplicate records are not
created. The crew checks data in and out of their edit version so that the data in the master
version is preserved until they are ready to post their updates. The crew is responsible for
performing a preliminary attribute and geometric QC. If they are not able to fully locate a
system in the field, they can search for construction or Land Development plans and use them
to create or edit features in ArcGIS. When they are done, either the Inventory Manager or
Inventory Coordinator will further review the data in ArcGIS.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

25

Inventory data can also be created from various types of plan sets such as: existing condition
surveys, construction record drawings for stormwater, engineering services, neighborhood
improvement & transit projects, as-built surveys (stream & pond restoration projects only), and
approved Land Development plans. Plans may be in Auto-CAD format (.dwg) which can be
added directly into an ArcGIS document, .pdf format which can be georeferenced in ArcGIS, or
on paper. Data editors will create inventory data from plans in their edit versions of the master
dataset in ArcGIS. When possible, they will work downstream to upstream. They can update the
geometry and attributes of existing inventory features and add new features. They may not
delete any features, only set them to “Inactive” status. When they are done, either the
Inventory Manager or Inventory Coordinator will further QC the data in ArcGIS.

3.3.2 Mecklenburg County Storm Sewer Inventory Program

The County jurisdiction was initially mapped in 2006 using a large collection effort by Water
Quality staff. Since that initial collection effort, Water Quality staff collects new inventory while
conducting stream walks and the Permitting and Compliance Program of Storm Water Services
has been responsible for updating the map as new infrastructure is built in the permitted
jurisdictions.

Beginning in December 2020, the Water Quality Program identified a need to update the
inventory map in a more efficient manner. In doing so, the Water Quality Program enlisted the
help of the Mecklenburg County GIS department. The GIS department is utilizing its staff to
identify potential areas of missing inventory by examining the existing inventory layers overlaid
with aerial photography (which is updated quarterly by GIS). Staff then manually adds the
missing inventory (inlets and outfalls) that is identified on the aerial photography to the feature
class. The above process was completed in January 2021.

To update the inventory layer as new development occurs, a process has been incorporated
into the daily work responsibilities for GIS staff who update impervious surface coverage for
recalculating the stormwater fee billing rate. These staff are now looking for new storm sewer
inventory (inlets and outfalls) while updating this impervious surface coverage. On a quarterly
basis, GIS staff provides the Water Quality Program a list of the newly collected outfalls. Water
Quality staff subsequently complete a field validation to add attribute information using the
ArcGIS Collector application. Staff will collect the outfall type (FES, endwall, exposed pipe, etc.),
outfall shape, outfall material, and endwall material, and record the diameter of the outfall.
Staff will also complete an outfall inspection using the Cityworks Mobile App to record the
condition of the outfall, DWFs and any other potential illicit discharges.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

26

3.4 Service Requests
Most illicit discharges and connections are identified through Citizen’s Requests for Service or
Service Requests. Service Requests are reports from other government agencies, businesses
and the general public that indicate potential stormwater pollution that needs investigation.
CMSWS responds to between 300-700 service requests a year. CMSWS’ response to these
requests is extremely important not only from a customer service standpoint, but also from a
Health, Safety and Environmental standpoint. All staff members receive annual training
regarding responses to service requests and providing proper customer service. For detailed
procedures related to responding to Service Requests, refer to the Procedures for Responding
to Citizen’s Requests for Service (Appendix G).

3.5 Emergency Response
CMSWS receives an average of 60 reports
annually that require staff to respond to
after-hour spills and emergencies that
threaten surface water quality. The purpose
of the Emergency Response Program is to
ensure that detailed response procedures
are in place and that staff are properly
trained and prepared to effectively and
efficiently respond to after-hour
emergencies so that pollution sources can
be quickly eliminated and negative water
quality impacts minimized (see Figure 3-3).
For more detailed procedures, refer to the
Emergency Response Guidelines for
CMSWS’ Water Quality Program (Appendix
H).

3.6 Illicit Discharge Elimination Program (IDEP)
The purpose of the Illicit Discharge Elimination Program (IDEP) is to support and enhance the
Illicit Discharge Detection and Elimination (IDDE) Program and proactively use a variety of
methods to locate illicit discharges. IDEP activities are conducted throughout the City and the
Towns. For details regarding the current program focus and actions as well as implementation
procedures, see the IDEP SOP (Appendix I).
Figure 3-4: Example of Emergency Response
call. Transportation accidents account for
most Emergency Response incidents.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

27

The IDEP Program has a long history of employing various methods to proactively search for
pollution sources. As such, some methods have been determined to be ineffective while some
continue to be used because of their successes. Examples of methods that are no longer used
are as follows:

• Minor outfall (<36”) inventory and dry weather screening in prioritized drainage basins.
• Use of CHEMetrics K-1510 Ammonia Sampling during stream walks.
• Aerial Infrared Surveys
• Optical brighteners

The current IDEP Program includes the following activities:
• Business Corridor Inspections
• Multi-Family Inspections
• Hot Spot Investigations
• Past Enforcement Reinspection Program

3.6.1 Business Corridor Inspections

Staff perform Business Corridor Inspections by driving in preselected commercial /
transportation corridors to quickly screen for illicit discharges common to commercial activities.
They also perform evaluations of storm drain inlets and outlets for signs of current or
previously occurring pollution problems. Business Corridor Inspections can be conducted during
ambient and non-ambient conditions, but not when it is actively raining.

The most common illicit discharges found in these areas include poor grease management at
restaurants, wastewater from washing equipment at the facility, wastewater from mobile
washers, oil discharges from automotive practices, and grease and debris in sanitary sewer
systems of multifamily communities that can potentially result in sanitary sewer overflows.

3.6.2 Multi-Family Inspections

As part of the IDEP program, staff conduct inspections at multi-family residential complexes to
identify improperly maintained private sewer systems. Multi-family complexes have been
selected in targeted sub-basins based upon previously identified priority basins and sanitary
sewer overflow occurrence.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

28

Ambient conditions are not needed for this program activity. Inspectors drive and walk around
complexes to look for obvious overflows and signs of previous problems (limed areas, toilet
paper, etc.). Inspectors also remove manhole covers to look for blockages or low flow
conditions which may indicate a problem in the sanitary sewer system on site. All problems are
documented in Cityworks and forwarded to lead staff for follow-up inspections, Notices of
Violation, or possible penalties. All complexes adjacent to streams include a downstream
inspection.

3.6.3 Hot Spot Investigations

Hot Spot Investigations are conducted in areas where analysis of monitoring and/or service
request data indicates a priority problem area where the source cannot be easily found.
Hot Spot investigations typically include one or more of the following techniques:
• Establishing a temporary CMANN monitoring station.
• Collecting grab samples in tributaries, pipes and/or manholes.
• Targeting specific industries for inspections.
• Dye testing businesses and homes.
• Monitoring suspect facilities.
• Smoke testing sanitary sewers.
• Conducting pipe video inspection.

3.6.4 Past Enforcement Reinspection Program

IDEP includes semi-annual re-inspections of all fixed locations that have received civil penalties
within the past three fiscal years to ensure continued compliance. The County’s Sr.
Environmental Specialist and Environmental Supervisor of the Pollution Control Team will work
with the City to develop a list of sites for re-inspection.

All violations observed are documented in Cityworks and a written Notice of Violation is issued
to the responsible party within two business days. All follow-up activities are documented in
Cityworks. For more information about procedures used during these investigative techniques,
please see Section 4.

3.7 Education and Outreach
The CMSWS ongoing public education campaign targets businesses and residents in the City of
Charlotte and Mecklenburg County. For residents, the campaign seeks to increase public
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

29

awareness of illicit discharges and connections, the negative impact on their quality of life, and
how to report suspected stormwater pollution problems. A broad range of education activities
and media outlets are utilized in this campaign, including television, radio and print
advertisements, social media , newsletters, postcards, brochures and flyers, utility bill inserts,
banners and vehicle wraps, in-person presentations for schools and community organizations,
and attendance at special events. Efforts have been highly successful as indicated by the
increase in the number of reports received from citizens regarding suspected illicit discharges.
For more detailed procedures related to the public education programs please see Public
Education SOP (Appendix J).

For businesses in the City of Charlotte and Mecklenburg County, the CMSWS ongoing public
education campaign includes the selection of two commercial business sectors each year for
the distribution of educational materials regarding common illicit discharges and the Best
Management Practices (BMP) that should be used to avoid these discharges. Common methods
of outreach include letters, postcards, and workshops targeting the specific business sector.
CMSWS has developed BMP flyers for the following business sectors to support this effort as
well as for use in response to Service Requests.

• Landscaping
• Pressure washers, Vehicle Detailers and other surface cleaning operations
• Food Service
• Carpet Cleaning
• Commercial Property Management
• Concrete
• Horizontal Directions Drilling
• Painting
• Swimming Pools and Spas
• Rooftop Work
• Stone Cutting
• Vehicle and Equipment Repair
• Breweries

The public education program not only targets specific identified primary pollutants such as
sediment and bacteria, but it is also equipped to provide education on numerous pollution
issues common to various land uses and specific times of year. For example, during the fall, the
social media campaign highlights how to properly dispose of leaves without impacting the
storm drain system. There are also numerous education materials available to staff and the
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

30

public on the CMSWS website regarding best management practices for a variety of topics such
as swimming pool maintenance, lawn debris disposal, car washing, etc.

Each year, CMSWS conducts training, education and outreach targeting internal municipal
employees of the City of Charlotte, Mecklenburg County, all six towns, CMS and CPCC that work
in areas that have the greatest potential to impact water quality such as mechanics, shop
workers, utility workers, etc. Education includes information about common illicit discharges
and how to report them. This outreach is performed via in-person presentations, online
training, and internal campaigns. For more detailed procedures related to Mecklenburg County
and the City of Charlotte’s internal education efforts, please see the Mecklenburg County
Employee Training Plan (Appendix K) and the City of Charlotte Employee Training Plan for IDDE
and Municipal Pollution Prevention (Appendix L).

CMSWS has also developed a short, 3-minute video titled Water Pollution, What To Do which
illustrates how to identify pollution in the field and how to report it. The video is targeted at
municipal employees that are routinely in the field and driving around as part of their jobs
where they may witness an illicit discharge. This group of employees may be code inspectors,
social workers, tax assessors, etc. and are not included in the groups mentioned above.

3.8 Public Involvement
The Public Involvement Program engages individuals, families, organized groups, schools,
businesses and industries of Charlotte-Mecklenburg in activities that help protect and restore
surface water resources, including the identification of illicit discharges and connections and
how to report them. These include the following three (3) volunteer programs.

• Adopt-A-Stream
• Storm Drain Marking
• Volunteer Monitoring

Volunteers for each of the activities are trained to identify illicit discharges and connections and
are encouraged to report illicit discharges immediately. Each volunteer group must also
complete a data sheet where problems or potential illicit discharges are reported to CMSWS
staff for review. If an illicit discharge or connection is indicated, staff are sent to the specified
location within four (4) hours of receipt of notification from their supervisor. A detailed
description of these programs can be found in the Public Involvement SOP (Appendix M).

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

31

The Adopt-A-Stream Program engages volunteers to “adopt” stream sections that are typically
a mile in length. Each volunteer group is responsible for walking their adopted stream section a
minimum of two (2) times a year during which time volunteers remove trash and debris from
the stream and look for illicit discharges.

The Storm Drain Marking Program engages volunteers to apply decals on storm drain hoods
that read “Do Not Dump – Drains To Creek” in both English and Spanish. When applying these
decals, volunteers check the storm drain for dry weather flow or evidence of an illicit discharge
or connection. Observations are reported to CMSWS for follow up and the initiation of the
necessary corrective actions.

The Volunteer Monitoring Program has three (3) opportunities for involvement, including
Streamside Assessment, Streamside Snapshot, and Chemical Monitoring. The Streamside
Assessment involves volunteers performing qualitative water quality monitoring at select
locations and recording data online. The Streamside Snapshot engages volunteers to take
pictures of specific stream locations where signs are located with phone numbers for texting
photos and indicating if waters look good or bad. Chemical monitoring provides an opportunity
for volunteers to check out water quality monitoring test kits that they use to conduct
monitoring for a variety of chemical parameters at select stream monitoring locations.
Volunteers report results online that are outside of normal watch ranges. All three (3) programs
have a common goal of getting citizens involved with identifying potential pollution problems
and reporting known or suspected issues that are follow up on by CMSWS for the identification
of pollution problems.

3.9 Facility Inspections
CMSWS inspects and conducts monitoring of stormwater discharge locations at both municipal
and industrial facilities in the City of Charlotte and Mecklenburg County to evaluate operations,
identify pollution problems and/or illicit discharges, to assist with pollution prevention and to
ensure compliance with Phase I and Phase II Storm Water Permit requirements. Facilities are
selected for inspection and monitoring based on their potential to cause negative water quality
impacts and NPDES industrial stormwater permit monitoring requirements. Facility inspections
include a detailed records review, an on-site inspection, evaluation of discharge locations, and
completion of comprehensive inspection reports. For more detailed procedures related to
these inspections please see the Phase II Pollution Prevention and Good Housekeeping
Inspection Program SOPs (Appendix N), Phase II Industrial and Vehicle Maintenance Inspection
SOP (Appendix O) and the City of Charlotte Industrial Facility Inspection SOP (Appendix P).
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

32

Section 4: Tracking Illicit Discharges and Connections to a Source

When an illicit discharge, connection, or pollution problem has been detected, actions must be
taken to determine the source. This section describes the various techniques used by CMSWS
to track illicit discharges to a source.

4.1 Records Review
The first step to confirm the source of an illicit discharge or connection is to conduct a Records
Review. This includes identifying the search area and any obvious pollution sources that are
immediately upstream of the discharge.

Staff begin the Records Review process by locating the storm sewer systems and assessing
aerial photos of properties upstream of an illicit discharge or connection. This information is
accessed primarily through two Geographic Information System (GIS) tools: Mecklenburg
County Property Ownership Land Records Information System (POLARIS) and Charlotte
Explorer. POLARIS and Charlotte Explorer are designed for access and retrieval of maps, aerial
photos, and GIS data layers associated with real estate property in Mecklenburg County and the
City of Charlotte. Charlotte Explorer also houses the most up-to-date Storm Water Inventory for
the City of Charlotte.

The second step of the Records Review process is to research water quality related data
upstream of the illicit discharge or connection via the Environmental Data Management System
(EDMS) (Figure 4-1). EDMS is an online database used by CMSWS to house and access all water
quality related data and staff activities with records dating back to 2011. EDMS also stores all
information about historic Service Requests and NOVs making this an exceptional resource to
help identify previously documented problems at an address or facility. EDMS has a direct
database connection to Cityworks software. Cityworks is an online accessible software that
CMSWS utilizes to document all activities. Cityworks contains a GIS platform where staff can
overlay multiple feature classes to help identify a search area and potential pollution sources.
Historical water quality compliance records are also available for some facilities. Cityworks
displays the most up-to-date Storm Water Inventory for the Phase 2 jurisdictions.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

33

Figure 4-1: Environmental Data Management System – online database produced and
maintained by CMSWS.

4.2 On-Site Inspection
Once the Records Review process is complete, staff inspect the area around and upstream of
the discharge, connection or pollution problem to narrow the search area and locate the
source. On-site inspection requires the use of various equipment that may include but not
limited to:
• iPhone to geocode locations for data entry into Cityworks and taking photographs;
• YSI Multiparameter Sonde to collect field measurements for dissolved oxygen,
temperature, pH, turbidity, and conductivity;
• Bottles for collection of laboratory samples;
• Safety equipment including waders, boots, gloves, glasses, hard hat, safety vest, etc.;
• Tape measure to measure pipe sizes and estimate flow rates; and
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

34

• Boat for collection of lake samples.
Detailed procedures for all monitoring activities, including the use of the YSI Multiparameter
Sonde, are performed in strict accordance with SOPs outlined in the CMSWS Water Quality
Monitoring Program QAPP (Appendix Q).
The following general procedures are followed during On-site Inspections:
1. Identify the search area upstream of the illicit discharge or connection.
2. Travel to the location of the discharge or connection and determine if an active
discharge is occurring.
3. Conduct a “windshield” survey of the search area using an automobile or walking the
area. Make note of all businesses, industries and other activities that may be a potential
pollution source. Check the storm drains for discoloration and the presence of dry
weather flow. Make note of anything suspicious such as an accumulation of drums,
stained soil, and unusual odors. If a pollution source is confirmed during the windshield
survey, immediately undertake corrective measures.
4. If the windshield survey fails to confirm a pollution source, but a potential source was
identified during the records review, initiate an on-site inspection at this potential
source.
5. If the windshield survey and records review failed to confirm or identify a pollution
source, then on-site inspection activities should begin at the most downstream location
where the pollution problem(s) was identified which will usually be in a stream or lake.
Staff use field observations or short-term monitoring measurements to work their way
upstream until the source is confirmed as illustrated in Figure 4-2. By starting at the
most downstream end, you avoid contaminating samples or obstructing visual
observations caused by the sediment disturbance and plume from walking instream.
6. If the pollution source is confirmed as a result of this inspection, immediately undertake
corrective measures.
Visual field observations are often a very effective tool for identifying pollution sources when a
continuous discharge is occurring. If field observations are unsuccessful, short-term monitoring
with the YSI Multiparameter Sonde are used to measure pH, temperature, dissolved oxygen
and conductivity. Staff begin at the confirmed discharge point or connection and record field
measurements at regular intervals (typically every 100 feet) while moving upstream.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

35

For tracking the location of a problem, the instantaneous data provided by the YSI
Multiparameter Sonde can be more useful than the delayed data results provided by a
laboratory. There are times when laboratory analysis may be needed at which time staff should
consult with a Supervisor and develop a monitoring plan before collecting samples. An example
sampling plan is illustrated in Figure 4-2 following the exceedance of the fecal coliform bacteria
Action Level reported from a routine FIM monitoring event.

Figure 4-2: Short-term monitoring plan used to help identify an illicit discharge/connection
following an elevated stream sample.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

36

If the above techniques are unsuccessful at tracking the source of the discharge, connection or
pollution problem, the techniques described in Sections 4.3 through 4.7 are utilized, typically in
the order presented below. Transitory and intermittent discharges are often extremely difficult
to track to their source, in which case the techniques described below can be very helpful.

4.3 Storm Drain Inspections

An inspection of the storm drain system upstream of an illicit discharge or connection can be an
effective technique for tracking a pollution source when other inspection techniques as
previously described are unsuccessful. In some circumstances, an inspection of the storm drain
system may be required in conjunction with the previous techniques.

Never enter any pipe to conduct an inspection. This is considered “confined space” and without
the proper training and protective equipment confined space entry violates numerous
regulations and is extremely dangerous. If confined space entry is necessary, CMSWS will
contract with an outside agency, which requires that you consult with your Supervisor.

Conduct your inspection of the storm drain system from outside the pipe being sure to carefully
observe all inlets and outlets looking for any of the field observations that are indicative of an
illicit discharge or connection. Be cognizant of topographic conditions, always being sure to
track the discharge or connection upstream.

The following are conditions that can be observed in the pipe system which indicate a potential
illicit connection:

• Any pipes smaller than 10 inches in diameter or unusually shaped pipes or pipes made
of different material connected to the storm drain system.
• A pipe connected at the top of the storm drainpipe or at an unusual angle.
• A metal pipe entering a concrete storm drain system.
• Dry weather flow.

4.4 Sanitary Sewer System Inspections
An inspection of the sanitary sewer system may be necessary when tracking a surface water
pollution source. Examples of how a sanitary sewer system inspection can assist pollution
source tracking in the storm drain system are:
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

37

• A white discharge is observed in the creek and a white discoloration is observed in the
upstream sanitary sewer system.
• A wastewater line is reportedly piped to the sanitary sewer, but an inspection reveals
there is no pipe.

To inspect the sanitary sewer system, use a manhole puller to carefully raise the manhole
cover. From outside the pipe, visually assess the sewer water for discoloration and/or unusual
flow conditions. Never enter any pipe or other confined spaces to conduct an inspection. Entry
of confined spaces is extremely dangerous without the proper training and PPE. Mecklenburg
County employees are not allowed to enter a confined space. As mentioned above,
discoloration in the stream and similar discoloration in the sanitary sewer system indicates a
potential cross connection and can be confirmed using Dye Testing.

Another visual indicator of a potential problem in the sanitary system is an orange, muddy tint
which can indicate an intrusion of clay soil from a sewer break.

4.5 Dye Testing

Dye testing involves placing liquid powder tracing dye into a pipe to see where it leads. It is very
helpful for identifying outlets. All field staff with CMSWS are equipped with multiple 16-ounce
bottles of tracing dye. The most used color is fluorescent green because of its high visibility but
a multitude of colors are available including red, blue, orange, and yellow. When dyeing
multiple pipes, it is important to use different colors so that the flows can be distinguished.

Dye testing is often used in conjunction with the storm drain and sanitary sewer system
inspections already described. For example, if a pipe outlet is observed as a potential illicit
connection but the source of that pipe is unknown, different colored dyes can be injected at the
upstream inlets of the suspected sources followed by a flush of water. By observing the dye
discharging from the outlet, it is possible to confirm the source. Dye testing can also be used to
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

38

Figure 4-3: A successful dye test reveals a discharge of sewage from apartments.

identify sewer leaks by injecting dye into the sewer system and observing whether it discharges
to an adjacent storm drain or creek.

Although the dye is safe for use in surface waters and will not cause negative water quality
impacts, be sure to use a minimal amount of dye and always inform your Supervisor of a dye
test. Too much dye can cause the discoloration to linger for extended periods generating calls
from citizens, which may lead to unnecessary follow up activities.

Avoid allowing the dye to contact your skin or clothing. The dye is not harmful to your health,
but it will stain your skin and clothing. It is extremely important that when you insert the dye
into a drain you do not allow it to contact plumbing fixtures (sinks, toilets, washing machines,
etc.) because this will result in staining that is very difficult to remove.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

39

4.6 Smoke Testing

In most cases, it is best to use a dye test when attempting to track the source of a discharge.
Smoke testing involves injecting smoke into a sanitary sewer manhole to help identify any
potential illicit connections or discharges from the sanitary sewer lines to the storm drain
infrastructure. The benefit of using smoke as the test media as opposed to dye is that the
smoke will penetrate through small cracks in pipes that would impede the flow of the dye.
Another benefit is that the smoke will rise in a pipe and exit cracks above the water flow that
dye would not reach. This can be a significant benefit if you are attempting to detect a
discharge that only occurs during high flow conditions from a break in the top of a sewer pipe.
If a dye test is performed during low flow conditions, the discharge will not be detected;
whereas, if a smoke test is performed, the rising smoke will exit the break and confirm the
discharge. The smoke also does not cause a discoloration of surface waters that can lead to
complaints from citizens.

Always obtain approval from your Supervisor prior to performing any smoke tests. CMSWS does
not have the necessary equipment to perform a smoke test. This test is almost always done in
cooperation with Charlotte Water who does have the proper equipment and are responsible
for the sanitary sewer infrastructure.

Figure 4-4: Smoke exiting a manhole while conducting a smoke test in the area.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

40

4.7 Pipe Video Inspection

A pipe video inspection can be helpful for inspecting the confined space of a storm drain or
sanitary sewer system when all other investigative methods have been exhausted.

Figure 4-5: Storm system pipe video identifies an illicit discharge entering the MS4.

In most cases, a dye or smoke test is enough to confirm an illicit connection or discharge;
however, in some circumstances, the flow in the sanitary sewer pipe is too great causing the
dye to dilute and lose its visibility. In other circumstances, a significant accumulation of soil
between the sewer leak and the creek or storm drain system prevents the dye or smoke from
being detected. In both these examples, a pipe video of the storm or sanitary system may be
needed.

City SWS has a CCTV team that can be used for conducting pipe video inspections in storm
drains in the City jurisdiction. Outside the city, CMSWS can retain a contractor to perform a
pipe video for storm drain inspections. Charlotte Water also has a pipe video team that can be
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

41

used for inspecting the sanitary sewer. Prior to requesting any video inspections, staff must
obtain their Supervisor’s approval.

Figure 4-6: Sanitary sewer pipe video identifies a broken pipe that was leaking into a storm
drain system directly below the pipe.

Pipe video inspection shows the exact location of all pipe defects and illicit connections using a
closed-circuit television and computer data logging technology. A high-quality video image at
close range of the interior of the pipe can be viewed in real-time, and a videotape is provided
for viewing later and documenting conditions. The video is a very non-destructive, non-
intrusive technique for viewing the interior of all shapes, sizes, and types of underground pipe
greater than 6 inches in diameter.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

42

Dye testing is often used in combination with pipe videos. Once an illicit connection is detected
using the video equipment, suspected sources are usually dyed, and the camera is used to
document whether the dye exits the illicit connection. If it does, the illicit discharge is
confirmed.

Figure 4-7: Illicit connection verified using a dye test and stationary camera setup in a drop
inlet to monitor the progression of dye.

Video pipe tests are also a very valuable tool for use in verifying cracks or leaks in sanitary
sewer pipes causing discharges to a storm drain system or creek. In both these situations, a
video of the sanitary sewer system is the most effective tool for identifying the discharge.

4.8 Fish Kills

Sometimes, as a result of an illicit discharge, a fish kill can occur. Fish kills most often occur
from depleted oxygen levels associated with the breakdown of organic material in the
discharge (see Figure 4-8). In rarer situations, a toxicant in the discharge results in a fish kill.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

43

All fish kills, as well as the destruction of any
other aquatic life, must be thoroughly
documented in an Activity Report. The
responsible party must immediately
eliminate the source causing the fish kill and
remove all dead fish and other dead aquatic
organisms from surface waters and dispose
of them properly at the sanitary landfill. If
these organisms remain in
the surface waters, significant negative
water quality impacts could result. The
NCDEQ fish kill investigation form contained
in Appendix R must be completed for all
observed fish kills (>50 dead fish) in waters
of the State, which includes everything
except private ponds not connected to a
stream. This form requires the identification
of affected fish to the species level. This
work is performed by Water Quality staff with help from a fisheries biologist for CMSWS. The
Activity Report narrative documenting the inspection activities associated with the fish kill and
a map are attached to this form and the package is forwarded to the NCDEQ in Raleigh. For kills
that exceed 500 fish, notify the Mooresville regional office of NCDEQ-DWR at 704-663-1699
during normal work hours. If the fish kill exceeds 1,000, report the incident to the N.C. Wildlife
Resources Commission at 704-986-6109.

If the fish kill occurs in an impounded water body such as a lake or pond, aeration of the water
using a large pump can sometimes raise oxygen levels and stop the fish kill. This should be
recommended to pond owners. Immediate aeration can often save a large quantity of fish. In
the long term, it is good for all pond owners to maintain an aeration system.

Figure 4-8: Image of a fish kill resulting
from a sewer leak.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

44

Section 5: Eliminating Sources of Illicit Discharges and Connections

5.1 Purpose
The purpose of eliminating the source of an illicit discharge and/or connection is to remove a
source of pollution and restore water quality conditions. This section contains the procedures
for conducting investigations of identified illicit discharges to eliminate the pollution source.

5.2 Procedures for Conducting Investigations of Identified Illicit Discharges
The below procedures are followed when investigating illicit discharges for elimination as
described in more detail in the following sections.
1. Identify the responsible party (see Sections 5.3 and 5.4).
2. Issue Notice of Violation (NOV) (see Sections 5.5 and 5.6).
3. Conduct follow up investigations to ensure compliance (see Section 5.7).
4. Initiate enforcement actions in accordance with established criteria (see Sections 5.8
and 5.9).
5. Complete all documentation (see Section 7).

5.3 Identify the Responsible Party
The first step to eliminate the source of a pollution problem, illicit discharge and/or connection
is to identify the responsible person and provide them with a “Notice of Violation” or NOV. The
responsible person is required by State and local laws to immediately cease the discharge, illicit
connection and/or illegal dumping and take whatever steps are necessary to restore the
affected area and prevent future discharges from occurring. Local and State regulations specify
that the responsible person is the one who caused the discharge or connection to occur. A
“person” is defined as any individual, partnership, co-partnership, firm, company, corporation,
association, commission, institution, utility, joint stock company, trust, estate, governmental
entity or other legal entity, or their legal representative, agents or assigns.

In most cases the property owner is the responsible person, but not in all cases. For example, in
a situation where an illicit discharge originates from rental property, the renter, not the owner
of that property, is responsible if the renter caused the discharge to occur. It is extremely
important to collect as much information as possible regarding the responsible person during
the field investigation. For example, be sure to interview witnesses and obtain license tag
numbers, names, addresses, etc. If the property owner is the responsible party, confirm the
name and address using POLARIS.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

45

5.4 Unknown Spillers
Investigating staff is responsible for interviewing other agency representatives at the scene of an
illicit discharge, as well as by-standers, neighbors or other parties that are possible witnesses to
the incident in order to obtain as much information as possible regarding the responsible party.
This task is second in priority only to efforts to ensure that the discharge has been ceased and all
spilled materials properly contained. If the responsible person cannot be identified after all
reasonable efforts have been undertaken, a contractor can be contacted to perform the necessary
cleanup. The Program Manager (County or Town spills) or Supervisor (City of Charlotte NPDES
Permit Supervisor) must approve the contractor prior to issuance of authorization to proceed.
Investigating staff must remain on-scene and supervise all cleanup activities.

When a responsible party cannot be identified, the investigating staff is also responsible for
immediately notifying the National Response Center (NRC) at 1-800-424-8802 and receiving an
NRC case number for an incident when the spill has impacted a jurisdictional waterway. This may
allow for the reimbursement of cleanup costs.

5.5 Issuing a Notice of Violation (NOV)
Once the responsible person has been identified, an NOV is issued as soon as possible and no
later than two (2) business days from detection of the violation. The NOV identifies the nature
of the violation, sets forth the measures necessary to comply with the Ordinance and provides
a specific time period for compliance.

An NOV may be issued in the field or served by certified mail, hand delivery or any other
means. Refusal to accept the notice does not relieve the violator’s obligation to comply with
the Ordinance or to pay a penalty.

A field NOV is used when there is a minor violation (Class I or Class II). Field NOVs are also used
when the violator operates a transient-type business or when the violation occurs away from
the business’ home location (mobile washers, painters, etc.). All field NOVs must be
documented in a Cityworks Server report, including the date of issuance and the name and title
of the person who issued the NOV.

In most cases, written NOVs are issued to ensure compliance when there has been a
documented impact to surface waters or to the ground (i.e. oil or chemicals dumped on the
ground or in the storm drain). The Supervisor must approve all written NOVs prior to issuance.
Always review records for documentation of previous violations prior to the issuance of an
NOV. If there is a history of noncompliance within the past three (3) years, enforcement action
is typically recommended. Civil penalties are the most commonly used enforcement remedy;
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

46

however, Charlotte-Mecklenburg’s ordinances include other compliance mechanisms that may
be warranted depending on circumstances, including a compliance agreement, compliance
order, cease and desist order, and withholding inspections, permits or other approvals.. The
determination for recommending enforcement is made after consulting with your Supervisor
and if necessary, the Program Manager. NOVs with recommendation for enforcement (NREs)
must be reviewed by the Program Manager.

The template letter or shell that staff use for writing an NOV depends on the jurisdiction,
section of ordinance applicable, and whether there is a recommendation for enforcement. See
Table 5-1 for a list of the local ordinances and NOV shells which are also contained in the file:
\\Luestwfs01\stw\Water Quality\WQ_Xfer\WQ\IDDE\Notices of Violation.

Table 5-1: Applicable Local Ordinances and NOV Shells
Jurisdiction Violation Town Code Shell Name
City of
Charlotte
Illicit Discharge(s) Section 18-80(a)
Charlotte – SWPCO (Sec 18-
80a) – 1st NOV
Illicit Connection(s) Section 18-80(b)
Accidental Discharge(s) Section 18-80(c)
Improper Storage,
Handling, or Processing
of Materials.
Section 18-80(d)
Failure to Comply Section 18-80(e)
Use of High PAH
Pavement Products
Prohibited.
Section 18-80(f)
Obstruction Section 18-80(g)
Mecklenburg
County
(Cornelius,
Huntersville,
Mint Hill,
Pineville, &
Unincorporated
areas)
Illicit Discharge(s) Section 5(a)
Mecklenburg County NOV
Illicit Connection(s) Section 5(b)
Accidental Discharge(s) Section 5(c)
Improper Storage,
Handling, or Processing
of Materials.
Section 5(d)
Failure to Comply Section 5(e)
Use of High PAH
Pavement Products
Prohibited.
Section 5(f) Mecklenburg County High
PAH NOV
Obstruction Section 5(g) Mecklenburg County NOV
Town of
Davidson
Illicit Discharge(s) Sec. 30-175(a)
Town of Davidson NOV Illicit Connection(s) Sec. 30-175(b)
Accidental Discharge(s) Sec. 30-175(c)
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

47

Jurisdiction Violation Town Code Shell Name
Improper Storage,
Handling, or Processing
of Materials.
Sec. 30-175(d)
Failure to Comply Sec. 30-175(e)
Use of High PAH
Pavement Products
Prohibited.
Sec. 30-175(f) Town of Davidson High PAH
NOV
Obstruction Sec. 30-175(g) Town of Davidson NOV
Town of
Matthews
Illicit Discharge(s) and
Improper Disposal(s) 52A.05(a)
Town of Matthews NOV Illicit Connection(s) 52A.05(b)
Accidental Discharge(s) 52A.05(c)
Obstruction 52A.05(d)
Town of
Matthews
Coal Tar Sealant and
High PAH Sealant
Limitations.
52A.05(e) Town of Matthews High
PAH NOV

5.6 Documentation, Review and Mailing
In Cityworks, staff create an NOV Activity Report for all NOVs (field and written) which is linked
to a Service Request or Activity Report as appropriate. All attachments relating to the NOV,
including the signed NOV and written response letter, must be attached to the NOV Activity
Report. Carefully review all documentation for spelling and punctuation before forwarding to a
Supervisor for review.

If the person committing the offense is different from the property owner, send a copy of the
written Notice of Violation to the property owner. In some situations, both the person
committing the offense and the property owner should be held responsible for the violation.
Consult with your Supervisor to make this determination.

All NOVs are signed by the generating staff person’s Supervisor. The Supervisor will review the
report for content, punctuation, and proper documentation and work with the staff person to
correct any errors. Once it is finalized and signed, it is scanned and attached to the NOV Activity
Report. Only the final signed copy of the NOV should be attached in Cityworks. The generating
staff person is then responsible for sending NOVs by “Certified Mail Return Receipt Requested.”
This is not required by local Ordinances but in the event a case goes to enforcement, proof that
the letter was received via the return receipt is important. The return receipt (green card –
Figure 5-1) will be mailed back to the investigating staff member. This staff person is
responsible for retaining this return receipt, scanning it, and attaching it to the NOV Activity
Report.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

48

Figure 5-1: Example return receipt for certified mail.

Service Request and/or inspection/NOV Activity Reports remain open until corrective actions
have been implemented and a written response received. Once that has been done, the service
request is forwarded to the Supervisor for review and closure.

5.7 Follow Up Investigations
It is extremely important to conduct a timely and effective follow up field investigation to
ensure compliance with a Notice of Violation. Investigations must be conducted on the
compliance date specified in the field or written notice (typically 10 working days) to ensure
that all violations have been addressed and the prescribed remedial actions have occurred.

Follow up inspections are required for field and written NOVs to confirm that the violation has
been corrected. The completed corrective actions and inspection results are documented in the
Cityworks report, including whether the NOV has been resolved.

5.8 Enforcement Procedures
Any person who violates local or state water quality ordinances is subject to a civil penalty,
which can be assessed from the date the violation first occurs. No penalty is assessed until the
person alleged to be in violation has been notified of the violation.

The maximum civil penalty for each violation is $10,000 per day of violation within the
corporate limits of the City of Charlotte and the Towns as well as outside these corporate limits
in Mecklenburg County, except for within Matthews’ corporate limits where the maximum
penalty is $5,000 per day for each violation. For a State NOV, it is $25,000, with each day of
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

49

violation considered a separate violation. The ordinances specify that in determining the
amount of a civil penalty, all relevant mitigating and aggravating factors shall be considered
including, but not limited to the following:

• the degree and extent of harm caused by the violation;
• the cost of rectifying the damage;
• whether the violator saved money through noncompliance;
• whether the violator took reasonable measures to comply with this Ordinance;
• whether the violator voluntarily took reasonable measures to restore any areas
damaged by the violation;
• whether the violation was committed willfully;
• whether the violator reported the violation to CMSWS; and
• the prior record of the violator in complying or failing to comply with this Ordinance or
any other local or State water pollution control ordinance or regulation.

In addition to the per diem civil penalty, penalties for costs to restore damaged property may
be assessed based on restoration costs, which include but are not limited to cleanup costs,
devaluation of the property, value of animal and plant life damaged and administrative costs
incurred by CMSWS. In most circumstances, the Person responsible for a violation is directed by
CMSWS to restore all areas affected by the violation to the conditions existing prior to the
violation. This authority is in addition to any other enforcement authority. The Director of the
Mecklenburg County Land Use & Environmental Services Agency sets the penalty amount for
Mecklenburg County and the Towns except for the Town of Matthews where the Town
Manager sets the amount. In the City of Charlotte, the Storm Water Services’ Water Quality
Program Manager establishes the penalty amount.

Once the penalty amount is set, the Person responsible for the violation is notified of the
penalty and the reason it is being assessed. The notice of penalty is issued in writing and sent
via certified mail or other means reasonably calculated to give actual notice to the Person
responsible for the violation. The notice directs the violator to either pay the assessment or
appeal within thirty (30) days of receipt of notice. If the violator does not pay a civil penalty or
file an appeal within 30 days after it is due, the case is turned over to the appropriate legal staff
for initiation of collection actions, including but not limited to, filing a civil action in
Mecklenburg County General Court of Justice or in any other court of competent jurisdiction. A
civil action must be filed within three years of the date the assessment was due.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

50

Civil penalties collected pursuant to local ordinances and State law are credited to the
Charlotte-Mecklenburg school system. Ordinance violations do not constitute a misdemeanor
or infraction punishable under North Carolina General Statute 14-4. In addition to the
imposition of a civil penalty, local ordinances may be enforced by an appropriate equitable
remedy issuing from a court of competent jurisdiction as authorized by North Carolina General
Statute 153A-123(d) or by injunction issued pursuant to authorization contained in N.C. General
Statute 153A-123(e). For Mecklenburg County and the Towns, Table 5-2 provides guidance for
assessing civil penalty amounts. In FY21, the City of Charlotte plans to update similar guidance
and procedures for their Pollution Control Ordinance which was updated in FY20.

Table 5-2: Guidance for Assessment of Civil Penalties for Mecklenburg County and Towns

Violation Category Examples Penalty
Class I
Minor
unintentional/non-
willful violation not
resulting in any
detrimental
impacts to surface
water quality
a) Improper disposal
of yard waste
b) Improper disposal
of pet/animal
waste
c) Private vehicle
leaking excessive
fluids
d) Improper disposal
of cooking oil on
ground
1st Offense - Written NOV + Educational
material + Restore the affected area - No
penalty
2nd Offense - Written NOV/NRE +
$100/occurrence + Restore the affected
area
3rd Offense - Written NOV/NRE +
$500/occurrence + Restore the affected
area
4th Offense and beyond - Written
NOV/NRE + Fine incrementally increases
$1,000/occurrence up to the max +
Restore the affected area
Class II
Minor
intentional/willful
violation not
resulting in any
detrimental
impacts to surface
water quality
a) Discharge from
commercial car
wash
b) Discharge of
chlorinated
swimming pool
water
c) Improper disposal
of latex paint
waste
d) Washing machine
discharge
1st Offense – Written NOV + Educational
material + Restore the affected area - No
penalty
2nd Offense – Written NOV/NRE + $500
fine/day + Restore the affected area
3rd Offense – Written NOV/NRE + $1,000
fine/day + Restore the affected area
4th Offense and beyond – Written
NOV/NRE + Fine incrementally increases
$1,000/day up to the max of $10,000 +
Restore the affected area
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

51

5.9 Civil Penalty Assessment Process – Mecklenburg County and Towns

The following process is to be used when assessing penalties in Mecklenburg County and the
Towns, which includes the ETJ area for the City of Charlotte.

1. For all violations resulting in measurable negative water quality impacts, the inspector
consults with the Supervisor for possible initiation of immediate enforcement action.
For all other violations, the inspector consults with the Supervisor if the 1st NOV fails to
achieve compliance in which case a 2nd NOV is issued. The Supervisor also contacts the
violator prior to the issuance of this 2nd NOV to discuss the necessary compliance
measures and the fines associated with a failure to comply.

Class III
Unintentional/non-
willful violation
resulting in
documented
detrimental
impacts to surface
water quality
a) Leaking private
sewage system
b) Improper
fertilizer/pesticide
c) Illicit connection
to the storm
system or surface
waters unknown
to the responsible
party
d) Accidental
discharge to
storm system
1st Offense – Written NOV + Educational
material + Restore the affected area - No
penalty
2nd Offense – Written NOV/NRE + $1,000
fine/day + Restore the affected area
3rd Offense – Written NOV/NRE + $2,500
fine/day + Restore the affected area
4th Offense and beyond - Written
NOV/NRE + Max fine/day of $10,000 +
Restore the affected area
Class IV
Intentional
violation resulting
in documented
detrimental
impacts to surface
waters
a) Willful discharge
of harmful
substances
b) Willful connection
to the storm
system or surface
waters
c) Willful dumping of
waste materials
directly to storm
drain or surface
waters.
1st Offense – Written NOV/NRE +
Educational material + Restore the
affected area + $1,500 fine/day
2nd Offense – Written NOV/NRE + $2,500
fine/day + Restore the affected area
3rd Offense – Written NOV/NRE +
Maximum fine/day + Restore the affected
area
4th Offense and beyond - Written
NOV/NRE + Max fine/day of $10,000 +
Restore the affected area
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

52

2. If the violator has failed to correct the violation in response to the 2nd NOV, additional
NOVs are issued and the violator is consulted as necessary by the Supervisor until
compliance is achieved. It is important to achieve compliance prior to assessment of civil
penalties because compliance measures and their associated costs are important
mitigating factors in determining the penalty amount as well as the violator’s degree of
cooperation. In some rare circumstances, it may not be possible to achieve compliance.
If a discharge is ongoing as a result of failure to comply, the following options are
available in the ordinance and should be discussed with the Supervisor and Program
Manager for immediate implementation: Compliance Agreement; Compliance Order;
Cease and Desist Order; Withholding of Inspections, Permits, or Other Approvals; and
Injunctive Relief. In some circumstances, violators fail to properly restore an affected
area, in which case the ordinance includes a provision whereby the County can
complete the restoration and recover all costs from the violator, including cleanup costs,
costs associated with permanent devaluation of the property, value of animal and plant
life damaged, and County administrative costs.

3. When it has been determined by the Supervisor that compliance has been achieved or
that it is otherwise appropriate that enforcement action be taken, the Inspector and
Supervisor consult with the Program Manager and upon receipt of approval to proceed,
the enforcement process begins.

4. The Supervisor makes verbal contact with the violator to discuss the corrective actions
required and the consequences of noncompliance, including the assessment of a civil
penalty.

5. The Inspector completes the Notice of Civil Penalty Assessment (NOCP) and Penalty
Assessment Worksheet & Report (see Appendix S for all jurisdictions), which includes
the Case Number, and forwards to the Supervisor for review and approval. Digital
versions of these documents are available in the following file: \\Luestwfs01\stw\Water
Quality\WQ_Xfer\WQ\IDDE\Enforcement. For the Town of Matthews, a special penalty
assessment notification has been developed to replace the NOCP (see Appendix T). This
document is also available digitally in the above referenced file. Upon completion of
these documents, the inspector forwards them to the Supervisor for review and
approval. The inspector logs the penalty into the Meck Co Penalty Assessment Tracking
Table located at the link above.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

53

6. The Supervisor reviews the NOCP and Penalty Assessment Report and returns them to
the inspector for any necessary revisions. Following approval of revisions, the Supervisor
forwards the documents to the Program Manager for review.

7. The Program Manager reviews the NOCP and Penalty Assessment Report and returns
them to the inspector for any necessary revisions. The Program Manager forwards the
documents to the Division Manager for review. The final version of both the Penalty
Assessment Report and NOCP, or in the case of Matthews the Penalty Assessment
Notification, is attached to the Cityworks report.

8. Following approval from the Division Manager, the digital documents are emailed to the
Department Head if the penalty is for the County or Towns or to the City Engineer for
the City of Charlotte. Following review and approval, the Department Head signs the
NOCP and the digital documents are forwarded to the inspector attaching to the
Cityworks’ report. For the Town of Matthews, the Town Manager is forwarded this
information for review, approval and mailing.

9. The inspector mails the NOCP to the responsible party via “Certified Mail Return Receipt
Requested.” The Penalty Assessment Report is not mailed but is maintained in the
digital file along with a copy of the NOCP. The “Green Receipt” for the mailing is also
placed in the digital file. The Penalty Assessment Spreadsheet discussed in #5 above is
also updated by the inspector with the date of the mailing, etc.

10. The “Green Return Receipt” is received from the post office and provided to the
inspector who scans it and adds it to the Cityworks’ report. The penalty is to be
appealed or paid within 30 days of receipt of the NOCP. The inspector adds 30 days to
the date the NOCP was received based on the Green Return Receipt and enters this into
the spreadsheet as the penalty due date. It is the Inspector’s responsibility to follow up
to ensure that within the 30-day time period the penalty is paid, or an appeal filed.

11. When the penalty payment is received, a copy of the check is scanned and attached to
the Cityworks’ report. The check is sent to Finance for depositing. An email is sent to the
inspector, Supervisor and Program Manager indicating that the penalty has been paid.

12. The responsible party has the right to contact the Program Manager within the 30 days
prior to penalty payment and request a penalty conference during which the penalty
can be negotiated based on information provided regarding aggravating and/or
mitigating factors. Negotiations cannot occur until all violations are corrected. The
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

54

inspector and Program Manager or Supervisor must attend this meeting. The inspector
is responsible for documenting the results of this meeting on the Penalty Assessment
Conference form contained in Appendix U, including information provided and
decisions made. A digital version of this form is contained in the following file:
\\Luestwfs01\stw\Water Quality\WQ_Xfer\WQ\Policies &
Procedures\IDDE\Enforcement. If the penalty is reduced and hearing waived, then the
Request for Penalty Remission and Waiver of Right to Appeal form contained in
Appendix V is completed during the Penalty Conference and signed by the Program
Manager or Supervisor and the responsible party. A digital version of this document is
maintained in the following file: \\Luestwfs01\stw\Water Quality\WQ_Xfer\WQ\Policies
& Procedures\IDDE\Enforcement. All completed forms are attached to the Cityworks
report. The responsible party must submit payment of any negotiated amount within 30
days of signing the form. If a negotiated penalty is not reached, payment must be made
within 30 days of receipt of the NOCP.

13. If the responsible party does not pay the civil penalty or file an appeal within 30 days
after it is due, the case is referred to the attorney’s office for initiation of appropriate
civil action to recover the amount of the assessment. The civil action shall be brought in
Mecklenburg County General Court of Justice or in any other court of competent
jurisdiction. A civil action must be filed within three (3) years of the date the assessment
was due.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

55

Section 6: Sanitary Sewer System Failures

6.1 Purpose
The purpose of this section is to address the importance of eliminating sources of sewage from
failing or improperly installed sanitary sewer systems. Discharge of raw sewage to creeks and
lakes from failing sanitary sewer systems is the one of the biggest sources of water pollution in
Charlotte-Mecklenburg. These discharges pose a significant human health threat, making them
important to identify and eliminate.
6.2 Background on Fecal Coliform
Discharge of raw sewage to creeks and lakes poses a significant human health threat because
human contact with surface waters contaminated with sewage can result in the transmission of
a variety of diseases, including cholera (Vibrio cholerae), typhoid fever (Salmonella typhi),
shigellosis (Shigella), salmonellosis (Salmonella), and gastroenteritis (Campylobacter jejuni,
Escherichia coli, Giardia lamblia) as well as a form of Hepatitus virus that is found in the
digestive tract. These pathogenic (disease-causing) organisms pass through the human body in
fecal excrement. The threat of such disease transmission becomes more serious as the
population density increases and more sewage pollutes public water supplies, carrying human
intestinal pathogens. This threat is particularly significant in surface waters used for swimming
and as a raw drinking water supply, which includes the three lakes on Mecklenburg County’s
western border.
6.3 Action and Watch Levels
To monitor for fecal bacteria levels that could indicate potential sewage sources, CMSWS has
developed “Action” and “Watch” Levels based on fecal coliform bacteria data collected locally
over a span of 20 years (see Table 2-3 above). These levels provide a more accurate
representation of local surface water conditions than do the State standard. In addition, the
State standard requires the collection of five consecutive samples over a 30-day period, which
is difficult and time consuming, whereas the local levels are based on one sampling event. For
these reasons, the local Action Level is used to trigger follow up activities for the identification
and elimination of pollution sources as opposed to the State standard.

Despite its limitations, fecal coliform bacteria serve as the primary indicator of failing sanitary
sewer systems in Charlotte-Mecklenburg. On occasion, other tests as described above are
performed in combination with the fecal coliform testing to narrow down the fecal source, but
most often follow-up field screening is used for this purpose.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

56

CMSWS performs routine monitoring for fecal coliform bacteria monthly at 33 designated sites
in streams throughout Charlotte-Mecklenburg. In addition, fecal coliform monitoring is
performed every other month from October - April at 28 sites on Lake Norman, Mountain
Island Lake, Lake Wylie, Lake Davidson, and Lake Cornelius. From May through September
(swimming season), these sites with an additional 14 sites are sampled monthly and 2 sites are
sampled twice/week September (Ramsey Creek Swim Beach and Lake Norman YMCA Swim
Area). All results from these monitoring activities are delivered to a Quality Assurance and
Quality Control (QA/QC) Officer with CMSWS, who is responsible for the compilation, review,
verification, validation, and warehousing of all water quality monitoring data products. The
primary laboratory used by CMSWS for analysis of water quality samples is owned and
operated by Charlotte Water. This laboratory provides finalized data electronically and in hard
copy to the QA/QC Officer within 5 days of sample collection.

On at least a monthly basis, data is compiled, quality assured and added to the Water Quality
Database (WQD). During this process, fecal coliform data is carefully assessed for exceedances
of local Watch / Action Levels and State water quality standards. Within one workday from
receipt of data, the QA/QC Officer reports all exceedances to Supervisors. Supervisors dispatch
field staff to confirm pollution problems. Once confirmed, staff initiates the procedures
contained in Sections 4 and 5 above to identify and eliminate the pollution source. Staff
conducting field monitoring activities using the YSI Multiprobe sonde is responsible for
immediately initiating procedures to ensure sources are tracked and corrections are made
when measurements indicate an exceedance of an Action or Watch Level. Oftentimes, when an
Action Level for pH, dissolved oxygen or conductivity has meet a threshold, this can indicate a
sewer discharge.
6.4 Field Indicators for Sewage
Field observations are often the quickest and easiest way to identify a sanitary sewer system
failure. If you are close to the sewer discharge, the physical observations are much more
profound, including odors, discoloration, solids, etc. If you are far from the source, physical
observations are often subtle. The following is a list of field observations that indicate a sewer
system failure:

1. Broken sewer line or lateral: If a broken sewer line is found, a sewer source has been
confirmed. However, the broken line may not be actively discharging. It is common for
sewage to discharge from a broken line under high flow conditions, which may not always
be occurring. Peak flows vary depending on where you are in the collection system, but
usually it occurs between 7:00 a.m. and 11:00 a.m., and 5:00 p.m. and 9:00 p.m. It may be
necessary to investigate the broken line during these times to confirm an active discharge.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

57

You can also place a minor obstruction in the pipe such as leaves or a rag and check back to
determine if it has been dislodged, which would indicate an active discharge. Other
methods can be used such as dye and smoke testing, deployment of a mobile CMANN unit,
and/or a camera.

2. Colored surface waters: Sewage can turn surface waters a variety of colors. It typically takes
on a grey tint when discharged to surface waters.

3. Debris in surface waters: Whatever is flushed down the toilet will likely end up discharged
to surface waters when there is a break or leak in the sewer system, including toilet paper,
tampons, condoms, cigarette butts, feces, grease, food particles, etc. The heavier material
will settle out first such as tampons, condoms and food particles. If you see this material in
the surface water, you are likely very near the discharge point. The lighter material settles
out much later. Oftentimes very small, almost invisible flecks of toilet paper are visible
many miles downstream of a sewer leak, particularly in larger, swiftly flowing streams.
Attention to detail is required or these tiny flecks will go unnoticed.

4. Sewage fungus: Sewage fungus (Fusarium aquaedutunna) is a filamentous growth occurring
on solid surfaces in a water body when organics become elevated, such as with a sewer
discharge. It is often described as “lamb’s tails” and appears very slimy or furry. Fast moving
stream flow reduces the ability of sewage fungus to attach to solid surfaces but enhances
oxygenation which promotes fungal growth. Sewage fungus usually occurs very near (within
100 feet) of a sewer discharge; however, larger discharges or discharges with an abundance
of biodegradable substances may result in significant sewage fungus growth for long
distances downstream. Sewage fungus looks very similar to iron bacteria, which are
naturally occurring and not indicative of a sewer discharge. The best way to distinguish
between the two is by their color. Iron bacteria have an orange tint whereas sewage fungus
is normally grey.

5. Unusual odors: Sewer discharges omit foul odors that might smell like rotten eggs, a musty
odor, or even a soapy smell. However, sewer manholes will also vent odors into the air
making odors somewhat of an unreliable indicator of a sewer discharge. Odors typically
don’t carry for long distances so if you are close enough to smell the discharge, the other
field observations will probably have been readily apparent.

6. Dead fish and/or other aquatic life: If a sewer discharge is ongoing for a week or more, or if
it is occurring in a slow-moving body of water, the organic material contained in the sewer
will begin to decay pulling oxygen from the water, which can lead to a fish kill. Toxicants in a
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

58

sewer discharge can also cause a fish kill. The type and quantity of dead fish is significant. If
only dead adult fish are observed, the discharge may be less significant. Generally, adult fish
require more oxygen. If all age groups of fish have died, then a more significant oxygen
depletion is indicated, which could mean a larger spill or one that has been ongoing for a
long period of time. Also, dead, air breathing aquatic organisms, such as turtles and
crayfish, can indicate that a toxicant in the sewer discharge and not oxygen depletion is the
cause of the die off. The toxicant could also originate from an illicit discharge other than a
sewer leak. When fish are stressed from oxygen depletion, they will come to the surface
and gasp for air, which is called piping. A fish kill is likely to follow within less than 24 hours
of such an occurrence. After fish have been dead for a few days they turn white in color (see
Figure 4-8), which can provide some indication as to the period of time when the discharge
occurred.

7. Unusual vegetative growth: The organic material in sewer can cause the unusually rapid or
prolific growth of terrestrial plants around a discharge. In some cases, tomato plants will
germinate from the seeds in human waste at a sewer discharge. If such unusual plant
growth is observed immediately around a sewer system, a sewer discharge is highly
suspect.

8. Algae blooms and/or other aquatic plant growth: The organic material in sewer can cause
the unusually rapid or prolific growth of aquatic plants around a discharge. If such aquatic
plant growth is observed in a free-flowing stream, a sewer or another discharge rich in
organic material is highly suspect.

9. Overflowing manholes or debris: When grease, roots or other obstructions create a
blockage in a sewer line, a discharge will occur along the path of least resistance, usually the
manhole. If a manhole is actively discharging, a source of sewage has been found. If a
manhole is not actively discharging sewage at the time of your observation, it may still be a
source. Sewer discharges may be intermittent, only occurring during peak flow conditions.
In such a case, you may observe a variety of debris around a manhole such as tampons,
condoms, cigarette butts, toilet paper, feces, food particles, etc. If such evidence is fresh, a
sewer discharge has occurred and should be reported so the obstruction can be removed. If
the evidence is old, the blockage has probably been freed and the discharge is no longer
active, but this should be confirmed with Charlotte Water or the property owner.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

59

6.5 Identifying and Eliminating the Source of Sewer System Failures
Once a sewer system failure has been confirmed as an illicit discharge and/or connection, it
must be tracked to its source and eliminated. This involves screening the area for field
indicators as previously described. It may also involve dye, smoke and video testing which are
commonly used. With the source confirmed, the next step involves identifying the responsible
party. The owner of the sanitary sewer system is responsible for all repairs and for restoring
areas affected by the discharge, including the removal of solids and debris from the ground and
surface waters. In Charlotte-Mecklenburg, the owner and operator of the municipal sanitary
sewer system is Charlotte Water. All other systems are privately owned by a business, property
owner or private utility. Septic systems can also be a source of a sanitary sewer system failure
and they are always privately owned. A description of the process for eliminating sanitary
sewer system failures and restoring affected areas is provided in the flowchart in Figure 6-1.
6.6 Sewer Discharges in Lake Norman, Mountain Island Lake, or Lake Wylie
When a sewer discharge reaches Lake Norman, Mountain Island Lake, Lake Wylie, Lake
Davidson, Lake Cornelius, drinking water supply reservoirs and swimming areas, the processes
for eliminating the discharge varies significantly. This modification is necessary due to
heightened concerns regarding waterborne disease transmission. One of the primary functions
of our lake monitoring program is to protect the citizens of Charlotte-Mecklenburg from
exposure to elevated bacteria levels in these lakes and to prevent the outbreak of waterborne
diseases. In 2002, Mecklenburg County developed a “Waterborne Disease Outbreak Prevention
Policy” to achieve this goal (Appendix W). The following procedures are included in this Policy
for implementation by CMSWS:

1. Review all fecal coliform data collected from lake monitoring activities immediately upon
receipt from the lab and always within 5 working days of collection. If bacterial
contamination is suspected in an area, notify the lab to RUSH the sample analyses and to
contact you immediately when results are available, which should be within 24 hours of
delivery to the lab. If you don’t hear from the lab in 24 hours, call them.

2. If one or more of the following conditions are observed, notify your Supervisor or Program
Manager immediately. If the observation is made in the field, contact should be made
immediately by cell phone.
a. Any unusual observations are made during lake monitoring activities (i.e. fish kill,
odors, unusual colors).
b. A sewer discharge to the lake is confirmed. Sampling results indicate fecal coliform
bacteria concentrations >200 colonies/100 millimeters for one or more samples.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

60

Figure 6-1: Flowchart for Identifying and Eliminating Sanitary Sewer Failures
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

61

c. Sampling results indicate an exceedance of any of the established Action Levels for
the lakes.

3. The Supervisor is to immediately notify the Program Manager of staff notifications as
described in 2 above. The Program Manager will immediately notify the Health Director of
any sampling results indicating greater than 200 colonies/100 milliliters for any one or more
samples collected as specified in “c” above. Conditions reported in “a, b or d” will be
relayed to the Health Director as is deemed necessary by the Program Manager. Through
consultation with the Health Director, the Program Manager will decide whether a
“SWIMMING ADVISORY” will be issued and for what area(s).

4. Upon receipt of notification from the Supervisor and/or Program Manager, staff will
immediately post “SWIMMING ADVISORY” signs along the shore to adequately mark the
affected area and place a buoy in the lake to warn boaters. If you are going into the field to
investigate a possible pollution problem (i.e. reported sewer overflow, etc.), be sure to take
the “SWIMMING ADVISORY” signs with you and notify the Supervisor if one or more of the
conditions in 2 above are confirmed. Following approval from the Program Manager, signs
can be posted prior to leaving the site.

5. Carefully document all activities in your Service Request or Cityworks Server Activity Report.
This documentation shall include a complete description of all observations and lab results.
The report must also contain the date and time when the “SWIMMING ADVISORY” was
issued and the area posted. You must also document all follow up activities and monitoring
results and indicate the date and time when the advisory was lifted. Get copies of all
“Media Releases” from the Program Manager and attach to your report.

6. The Program Manager will immediately notify all interested parties by way of email
including CMSWS leadership, the Outlook group Stormwater Media, the Mecklenburg
County Health Department, the Catawba Riverkeepers, Mecklenburg County Public Service
and Information, DEQ Mooresville Regional Office, Gaston County Environmental Health,
Chairman of the Marine Commission where the discharge occurred and SCDHEC.

7. The Program Manager will immediately consult with staff and issue a “Media Release.”

8. Within 24 hours of receiving lab results, resampling must be performed in the area where
elevated fecal coliform levels were detected (or other Action Level Exceedances) under
direction from the Supervisor and Program Manager. The sampling area will be expanded to
determine the full extent of contamination and all potential sources. For all resampling,
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

62

notify the lab to RUSH the sample analyses and to contact you immediately when results
are available which should be within 24 hours of delivery to the lab. If you don’t hear from
the lab in 24 hours, call them. This resampling will continue at 24 hours intervals until
results fall below the Action Level and the Program Manager has lifted the “SWIMMING
ADVISORY.”

9. Immediately upon receipt of results, notify the Supervisor and Program Manager who will
make the determination, after consulting with the Health Department, as to whether the
“SWIMMING ADVISORY” will be lifted at which time the signs will be removed and another
media release will be issued by CMSWS. The Program Manager will also send an email
containing all resampling results and the status of the swimming advisory to the above
listed contacts.

10. If in doubt as to if a “SWIMMING ADVISORY” should be lifted or not, error on the side of
caution and leave it in place until additional information can be provided.

6.7 Municipal Sanitary Sewer System
Charlotte Water owns and operates the municipal sanitary sewer system in Mecklenburg
County and beyond. As of 2020, the system includes seven wastewater treatment plants (five
within the County), 4,375 miles of collection pipe and 82 sewage lift stations that collect and
treat an average of 91 million gallons of wastewater a day from approximately 265,000 service
connections for businesses and residents throughout the region.

Charlotte Water owns and operates all sewer lines located in public streets, all feeder lines,
most manholes along stream banks and sewer aerials. If you encounter a leak or any other type
of failure in any part of the sewer system owned by Charlotte Water, immediately contact their
dispatch office at 704-378-6632 and follow the steps described in Figure 6-1 to eliminate the
discharge and restore the affected area. This discharge violates both State and local ordinances;
however, all notices of violation to Charlotte Water are issued by the State.

Charlotte Water provides a 1-hour response time to all sewer spills, which is half the 2-hour
response guideline set by the State. In accordance with State regulations, Charlotte Water
maintains a record of all spills of any amount. For all spills that reach surface waters, Charlotte
Water notifies CMSWS and the State by telephone within 24 hours and files a written report
within five days. For all spills greater than 1,000 gallons regardless of whether they reached
surface waters, Charlotte Water notifies CMSWS and the State by telephone within 24 hours
and files a written report within five days. For all spills where 1000 gallons or more reaches
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

63

surface waters, Charlotte Water issues a news release within 48 hours. For all spills where
15,000 gallons or more reaches surface waters, Charlotte Water issues a news release within 48
hours and publishes a legal ad in the Charlotte Observer within 10 days. By September 1 of
every year, Charlotte Water produces a wastewater performance report detailing their
wastewater collection and treatment system performance during the previous fiscal
year, including details of all spills and is available on Charlotte Water’s website.

Every year CMSWS completes an analysis of its fecal coliform monitoring data and reported
sewer spills and compiles a written report identifying those portions of the municipal sewer
system where chronic sewer leaks have occurred or elevated levels of fecal coliform have been
detected. This report is provided to Charlotte Water for use in identifying areas where sewer
system rehabilitation is needed as part of their Capital Improvements Program to help reduce
sewer system spills.

6.8 Private Sanitary System Repairs
Businesses and dwellings abutting public
streets are connected to the municipal
sewer system by a pipe called a lateral,
which is privately owned and maintained
by the property owner. The wastewater
from the home or business runs into this
lateral and flows to the municipal line,
usually by gravity, where it is carried to a
municipal wastewater plant for
treatment prior to being discharged to a
creek. In some cases, the municipal line is
higher than the lateral and the sewage
must be pumped. This pump as well as any other device connected to the lateral is also owned
and maintained by the property owner. The property owner is responsible for making repairs
and eliminating sewer discharges originating from any part of a private sewer system. There is
usually a small pipe (4 inches in diameter) called a clean out (see Figure 6-2) that exits the
ground vertically and is connected to the lateral between the house and municipal sewer line.
The clean out is used to clean the lateral and free blockages and is supposed to be capped to
prevent sewage from flowing out of the line in the event of a blockage. Oftentimes a property
owner will remove this cap or break off the clean out pipe to allow the sewage to flow into the
yard instead of back up into their home. This cleanout is part of the private sewer system and
the property owner is responsible for removing the blockage and replacing the cap. Sometimes
Figure 6-2: Discharge from sewer clean out.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

64

the blockage is in the municipal line, but the leak occurs from a cleanout. If the blockage is in
the municipal line, Charlotte Water is responsible for removing the blockage from their line and
the property owner is responsible for repairing the cleanout.

Sanitary sewer collection systems located in private roads for apartment complexes, and some
townhomes and condominiums, are usually privately owned. Some large commercial facilities
or business parks and schools may also have privately owned sewer collection systems. These
systems carry significant quantities of sewage to the municipal sewer system from multiple
households or businesses or from large facilities and can include large pipes, manholes or even
sewage lift stations. It is sometimes difficult to distinguish these private systems from the
municipal system. Staff can access the Charlotte Water sewer infrastructure map using the
ArcCollector application for verification of manholes, lines, and ownership. If the sewer
discharge is originating from a private system, the owner of the apartment, townhome,
condominium, business park, etc. is responsible for the repairs. In some cases, this will be a
property management company.

There are three (3) wastewater treatment plants and accompanying sanitary sewer collection
systems in Charlotte-Mecklenburg that are owned by private utilities and are not connected to
the municipal sewer system. These systems are permitted and inspected by the State. Any
sanitary sewer system failure at these facilities is the responsibility of the private utility
company that owns the system. There are two such companies operating in Charlotte-
Mecklenburg, including Aqua North Carolina, Inc. and Carolina Water Service. There are two
systems operated by Homeowners associations and one at Berryhill Elementary that is owned
by Charlotte-Mecklenburg Schools. State law requires that contact information be posted at the
wastewater treatment plant. These systems are all located outside the City of Charlotte and
Towns in the unincorporated area of the County. The steps described in Figure 6-1 are followed
to eliminate discharges from privately owned sanitary sewer systems and restore all affected
area. All sewer discharges from private systems violate both State and local ordinances and the
process previously described will be used for notifying the owner of the system and issuing the
appropriate Notices of Violation.

6.9 Septic System Repairs
A private wastewater treatment and disposal system called a “septic system” is often used for
individual homes when municipal sewer or sewer service from a private utility is not available.
In a typical septic system, wastewater flows from the house into a septic tank where settling
occurs. The heavier solids (e.g., organic waste) sink to the bottom of the tank to form a sludge
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

65

layer, while the lighter solids (e.g., grease, soapsuds) float to the top to form a scum layer. The
clear liquid in the middle layer is the effluent (Figure 6-3).

Figure 6-3: Common septic tank design and components.

After settling out for 24 or more hours, the effluent flows out of the septic tank to a leachfield,
where it is discharged into the soil for final treatment and disposal (see Figure 6-4). If properly
installed and maintained, septic systems will provide effective treatment of household sewage.
However, when septic system failures occur, they can result in discharges of sewage to the
surface of the ground or surface waters.

Septic systems are regulated by Mecklenburg County Groundwater and Wastewater Services
(MCGWS), which is a component of the Environmental Health Division, in the Mecklenburg
County Department of Public Health. CMSWS coordinates with MCGWS to identify areas where
septic system failures result in discharges to surface waters and then work together to
eliminate these discharges. On a quarterly basis, CMSWS maps MCGWS’ data regarding
locations of failures and compare it to fecal coliform monitoring data. If elevated fecal levels are
Photo from: https://www.epa.gov/septic/types-septic-systems
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

66

occurring in areas where septic system failures are identified, then immediate follow up actions
are conducted by CMSWS to identify and eliminate discharges. In addition, MCGWS will notify
CMSWS if their staff observes a discharge of sewage to surface waters and work with them to
identify responsible party(s), issue a Notice of Violation and ensure correction. All sewer
discharges from septic systems violate both State and local ordinances. The owner of the
property is responsible for all repairs.

Figure 6-4: Conventional septic system, with a traditional drainfield network.

Photo from: https://www.epa.gov/septic/types-septic-systems
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

67

Section 7: Documentation

7.1 Purpose
This Section describes the documentation performed by CMSWS for the Illicit Discharge
Detection and Elimination Program. This includes different types of documentation, the specific
information required for each, and the reports that can be generated from the Cityworks
Server.

Proper documentation serves many purposes. It provides the information necessary to ensure
the proper follow up and elimination of an illicit discharge and/or connection. It provides
documentation for assessment of penalties and for taking other administrative actions to
eliminate an illicit discharge such as injunctive relief by a court, etc. It provides a historical
record of violators for use in the implementation of measures that discourage repeat offenders
such as increased penalties, etc. It documents activities for compliance with NPDES Phase I and
Phase II Storm Water Permits. Finally, it helps to assesses the effectiveness of the Illicit
Discharge Detection and Elimination (IDDE) Program.
7.2 Cityworks Server
All IDDE Program documentation is stored in Cityworks Server. Cityworks Server is a “suite” of
GIS-based applications and databases used by CMSWS to house and access all water quality
related data, provide mobile tools for use by staff in solving environmental problems, schedule
and track work load and provide a platform for report generation.

Cityworks is typically used following the identification of a discharge or connection for the
purpose of accessing data and information regarding the prior history of a suspected facility
that might be identified through POLARIS. The GIS component of Cityworks allows for the
mapping of monitoring sites, inspection locations, citizens requests for service received and
other important information for identifying potential sources. Monitoring data is also linked to
Cityworks through a data repository.

Supervisors assign work related to IDDE activities using Cityworks and all data and information
collected is geocoded and entered into the system by the investigator.
7.3 Inspection Report
All activities associated with the detection and elimination of illicit discharges must be
thoroughly documented in Cityworks. This is extremely important if penalties or other forms of
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

68

legal or administrative actions are involved. A complete Inspection Report will include the
following components: inspection reports, copies of Notices of Violation, photos, maps, and
sampling data.

At a minimum, Inspection Reports must include the information highlighted in red font on the
inspection report template. Additional information relevant to the incident will be captured in
the “General” section, along with a brief description written in the “Comments” fields. The
Inspection Reports must generally include:
• How the incident was detected, including the name, address and phone number of
others involved in reporting (including citizens, staff, etc.);
• The dates, exact place, and time of all inspections (a new Inspection Report should
be generated for each site visit);
• The first and last name of the inspector(s) and always refer to them in the 3rd
person;
• The actions taken during the investigation such as sampling, field investigation, etc.;
• The full names, titles and contact information for all contacts made during the
inspection and any other activities associated with the illicit discharge or connection;
• The full names, titles and contact information for all witnesses to the incident;
• A detailed description of what was observed during the inspection, including specific
locations, etc.;
• The names and locations of all surface waters impacted and locations of impacted
storm sewer systems as well as the exact location(s) of the discharge point;
• The material discharged and specify the amount (attach SDS if available);
• Any techniques used to track the source of the discharge (dye test, smoke test, etc.);
• Any other information pertinent to the investigation; and
• Repeat the above steps for all follow up inspections.

7.4 Notices of Violation
The following is the process followed to create and enter an NOV into Cityworks.

Creating an NOV:
o If the NOV is generated due to a service request, then create the NOV from the Service
Request so that the NOV is linked to it. Click on Create from the Service Request, and
then follow the steps below.
o If NOV is not associated with a Service Request, then you will still create the NOV by
clicking on Activity, then New. Under Entity Group click on Administration, under
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

69

Template click on Administration, then double click on Notice of Violation. If the NOV is
being issued to an entity (facility, business, etc.) that is already set up as an attribute
within a shapefile in the Cityworks Server GIS mapping service, then you can
select/highlight the attribute and create the NOV.
o Once the Notice of Violation template has opened, an NOV Activity Report # will
automatically be generated.
o If the NOV was created from the Service Request or from an attribute within a shapefile,
then the NOV should automatically geolocate to the location address, business/facility,
etc. If it was not created from a Service Request or an attribute within a shapefile, then
you can use the Locate tool in your Cityworks Server GIS mapping service along with the
“Get from Map” function under Assets in the NOV Activity Report template.
o NOVs need to be associated with all corresponding General Inspection Activity Report(s)
by entering the NOV Activity Report # into the NOV field of the General Inspection
report.

Notice of Violation Activity Reports
If the title of a field in an NOV Activity Report is highlighted in red, completion of the field is
required. Otherwise the field should be completed if applicable. The following describes the
fields available for filling in an NOV Activity Report.

• Location: The Basin No., District, and Municipality should automatically fill in once it’s
geolocated. The Location Name is the actual place (facility, business, etc.) the violation
occurred. The Resp. P. Name/Contact/Address is information for the Responsible Party.

• Inspected By: This field should be filled out with the inspector’s name after all activities
associated with the NOV are complete.

• Status: The field should be changed to say To Review or To Close upon completion and
prior to submittal to be reviewed or closed.

• Submit To: This field may include the inspector’s name until the inspector is ready to
have the Activity Report reviewed or closed, and then the inspector should complete
the Submit To field with the person’s name that needs to review or close the report
(Supervisor).

• Activity Type: The Activity Type should indicate the type of activity that was occurring
when the violation was observed. For example: a service request, BMP inspection,
industrial inspection, IDEP activity, stream walk, etc.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

70

• Activity Stage: The Activity Stage should be left blank as there is no such thing as an
initial NOV or follow-up NOV.

• Customer: The Customer is the jurisdiction in which the problem was found.

• Actual Start and Actual Finish: These will be completed based on when the violation was
first observed and finish when the problem is completely resolved.

• Problem Found & Resolved: On the NOV template, the number of problems found and
problems resolved should always be 0. The problems found and resolved should be
tracked in the general inspection activity reports. Theoretically, the number of problems
found should always equal the number of problems resolved before closing the service
request.

• Service Request: This field should have a number associated with the NOV, if applicable.
If it is created from a Service Request then the service request # should already be filled
in.

• Activity(s): This field lists all Activity Report #’s (General Inspections, etc.) associated
with the NOV.

• NOV: This field should be left blank unless an additional NOV is generated.

• Violation Observation: Use the drop-down boxes to answer the four questions related to
the NOV. Use the NOV Database and/or Cityworks to see if a violator is a repeat violator.

• NOV: Use the drop-down boxes to answer the four questions, if applicable. Use the
comment fields under each question to explain or clarify your answer further.
The Continuing NOV is only used for Erosion Control purposes.

• CAR: Use the drop-down boxes to answer the three questions, if applicable. CARs are
generally issued only for violations related to BMP inspections.

• Violation Type: Cite the appropriate Ordinance that was violated based on the Activity
Type and jurisdiction.

• Compliance: Complete applicable fields.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

71

• Penalty: Applicable fields will only be completed if a penalty was issued.

After the above information has been entered into the Cityworks Server, staff complete the
following:
o Complete your NOV draft and submit it to your Supervisor for review.
o Make the suggested changes and have your Supervisor sign the final.
o Scan the signed copy and mail the NOV via Certified Mail to the responsible party as well
as anyone cc: on the NOV. Email Activity Report #’s to City instead of a hard copy. Attach
the signed NOV to your NOV Activity Report in Cityworks.
o Make sure all information related to the NOV is up-to-date in the NOV Activity Report
and any other Activity Reports (General Inspections, etc.) so they can be referenced.
o Perform a follow-up investigation by the day indicated in the NOV, if possible, (normally
10 working days) and confirm that the violation has stopped/been remediated.
o Once the written response from the violator is received, scan it and attach it to your
NOV Activity Report.
o If the response and remediation of the violation are acceptable, submit the NOV Activity
Report to your Supervisor to close. Your Supervisor may want you to submit the NOV
Activity Report when you submit all other Activity Reports, Service Request, etc.
o If no response is received or the violation has not been corrected, a second NOV with
NRE, an NOV with Notice of Penalty, or other enforcement option are possibilities
(coordinate with your supervisor and the City to decide the steps forward).

Notices of Violation Attachments - Attachments to the NOV template should be limited to the
actual NOV document, the certified mail return receipt, the NOV response letter, and any
associated penalty documentation as applicable. All additional related attachments will reside
on the initial Activity Report. Hard copies must be scanned and attached in PDF format. Only
signed NOVs should be attached.

It is important to note that anytime edits are made to a document in Cityworks, the document
must be reloaded, and the former version deleted. If the file name stays the same, the system
will save over the document currently attached and it will not need to be deleted.

7.5 Photos and Maps
It is very important to include digital photo documentation of the incident. A photograph(s)
must be taken of the following:
1. The scene of the incident;
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

72

2. The exact point of discharges such as a broken fuel line, ruptured saddle tank, floor
drain in a facility, etc.;
3. The entry point of the discharge to surface waters and/or storm drains;
4. Impacts of the discharge on surface waters and/or storm drain, including discoloration,
solids, foam, oil sheen, etc.;
5. Conditions upstream and downstream of the discharge point;
6. Impacts to aquatic flora and fauna, including fish kills, dead vegetation, etc.
7. Impacts of the discharge to the surface of the ground, including dead vegetation, solids,
etc.;
8. Cleanup activities; and
9. Completed cleanup with affected areas fully restored.

Photos must be attached to the Inspection Report. When directly uploading photos as an
attachment, a description of the photo must be entered into the filename of the image. Photos
should be referenced in the text of the Inspection Report when describing the investigation. An
alternative to directly uploading photos to Cityworks is to create a narrative documenting your
work in a Word document and attaching the document to the Activity Report. This gives the
staff member the ability to directly correlate photos to the documenting text. This is especially
useful on large discharge events where you might find Cityworks text boxes limiting your ability
to thoroughly and accurately document the activities.

If a discharge entered storm drains and/or surface waters, attach an aerial map illustrating
where the discharge occurred, the path of flow, any storm drains impacted, the impacted
receiving streams, as well as any other environmental impacts observed and monitoring
performed. Upload the map as an attachment to the Inspection Report. Make attachments to
the Inspection Report or Service Request as appropriate. If other attachments are necessary
such as a SDS, digitize and attach them as well. All attachments should be referred to in the
Comments field of the Inspection Report.

7.6 Monitoring Data
Monitoring data is collected for illicit discharges for one or more of the following reasons:
1. To determine the type and source of the discharge: Short term monitoring is typically
performed. Figure 4-2 above describes this monitoring.
2. To identify an unknown substance that has been discharged: This is the most difficult
and costly monitoring to perform and should be avoided if possible. If this monitoring is
necessary, it should be performed by the responsible party. CMSWS will perform this
monitoring only when the responsible party cannot be identified.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

73

3. To determine the extent of contamination: This monitoring is usually performed on
large spills requiring extensive cleanup and should typically be performed by the
responsible party. Monitoring is usually performed where the spill enters the storm
drain or surface waters as well as upstream above the discharge and downstream below
the mixing zone. Multiple samples may need to be collected downstream depending on
circumstances.
4. To document environmental impacts for enforcement action: This monitoring is done by
CMSWS. If a discharge has occurred or is suspected to have occurred, monitoring must
be performed to document violations and the extent of environmental impacts. In
addition, a photograph must be taken at every location where a sample is collected. If
the discharge can be effectively documented using pH, temperature, dissolved oxygen,
conductivity or turbidity, then the YSI Multiprobe sonde should be used in accordance
with the QAPP procedures described below. Monitoring must be performed at the
origin of the discharge and where the discharge enters the storm drain and/or surface
waters as well as upstream and downstream of this location. Surface water sampling
must be performed for all discharges even if the discharge is observed to discontinue
within a conveyance such as a pipe or ditch prior to reaching surface waters.

Monitoring data will either be collected in the field using a YSI Multiprobe sonde or through the
collection of water samples for laboratory analysis. All data collection must follow the policies
and procedures described in the QAPP. Inspectors can use their discretion for determining the
collection of field measurements; however, approval must be obtained from the Supervisor or
Program Manager prior to turning in a sample to the laboratory for analysis. If the Supervisor or
Program Manager cannot be reached, collect the sample and hold off on delivery to the
laboratory until approval is obtained. Be sure to maintain the chain of custody and meet all
sample holding times. The nature of the sampling performed, including the type, frequency,
location and parameters measured, will need to be determined on a case by case basis
consulting with your Supervisor.

All monitoring information must be documented in the Inspection Report, including the date,
time, location, person collecting samples, parameters measured, sampling technique (grab,
CMANN, YSI, etc.) and reasons for sampling. All sample ID numbers should also be included in
the report as well as the name of the laboratory performing the analysis. The locations of all
monitoring sites should be shown on a map in relationship to the discharge location. Once data
is received, it must be recorded in the Inspection Report and laboratory sheets digitized and
attached. The attachment(s) should be uploaded to the Inspection Report along with a
description of the attachment.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

74

7.7 Review and Approval of Reports
After the inspector completes a service request, the service request along with all associated
inspections and NOVs are forwarded to the Supervisor for review and approval. The Supervisor
will review all the information contained in the Inspection Report, including all attachments.
The Supervisor is reviewing for content as well as punctuation and grammar. If problems are
detected, the Supervisor will forward the report back to the inspector for correction. Following
correction, the inspector sends the Inspection Report back to the Supervisor. This process
continues until the Supervisor approves and closes the Inspection Report.

7.8 Accessing Reports in Cityworks
The reports associated with the IDDE Program are contained in Cityworks and are referred to as
“Activity Reports.” There are thousands of Activity Reports in Cityworks; therefore, in order to
access a particular report, you must complete an Activity Report search. There are many
methods for searching Activity Reports but the most commonly used include searching by ID
numbers, the work history of a specific feature, an address or street, and an open search on
select fields. The following sections describe these searches and additional information can be
found in the Cityworks SOP (Appendix X).

7.8.1 Searching for Inspection Reports by ID Number
On the Cityworks toolbar, click “Activity” and this will open the internal search function. In the
Search window, enter the appropriate Activity Report number in the “Inspection ID(s)” field.
Alternatively, the Activity Report number can be typed in the window next to the login
information. Cityworks will then open the specified Activity Report.

7.8.2 Searching for the Work History of a Specific Feature
If the ID number is not known, you can perform a GIS search to find all activities associated with
a specific feature. First, you will need to select the specific feature:
1. On the Cityworks Server toolbar, click “GIS Search.”
2. In the GIS Search window, select the appropriate Entity Group (Administration, Assets,
Education, Inspections, and Monitoring) and Entity (the choices available will depend
upon what you selected in the Entity Group option).
3. The resulting search window will allow you to select or enter certain attributes. These
choices are based on the entity that is selected. Once you have entered your search
criteria, click “Search”.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

75

4. Candidates that meet your search criteria will be displayed. Highlight the asset in which
you’re interested (do not click on the underlined OBJECTID; this will open the attributes
of the asset). Then click on the barricade icon; this will open the asset’s work history.
5. Cityworks will generate a tabbed list of Requests, Inspections, Work Orders, Assets, and
Permits associated with the asset. You can click the different tabs to view the different
types of search results. Click on the underlined ID number to open an activity report.

7.8.3 Searching History by Location
You may want to try a location search to find all historic activities that have occurred within a
specific area. The easiest way to do this is using the Cityworks Map and the Navigation tool,
found in the “Tools” menu.
1. Open the map service in Cityworks. Zoom to the area that you would like to search on
your screen. Cityworks uses an internal extent calculator based upon your current zoom
level.
2. Using the Navigation tool, be sure that the tool is expanded to show all options, click on
the item you would like to search (Request, Inspections, or Asset History).
3. This will take you to the internal search function with the X&Y extent specified. You can
then select additional options to help you narrow your search.

7.9 Documentation of Enforcement Actions
All enforcement actions are documented through digital files. No hard files are maintained. A
description on the information contained in these files is provided in Table 7-1. These files are
established on the LAN by the assigned inspector and reviewed/approved by their supervisor as
attachments to the NOV Activity Report. Specific information regarding the Notice of Violation
and enforcement action is entered in the “Custom Fields” section of the NOV Activity Report by
the assigned inspector and reviewed/approved by their supervisor. Reports will be developed
from these custom fields to summarize and track notices of violation issued, and enforcement
actions initiated.

Table 7-1: Information to be Contained in Digital Files for Enforcement Actions
Information Type
1. Inspection Reports
2. Pictures (showing violations and compliance) – All pictures must be dated
3. Notices of Violation (NOV)
4. Continuing Notices of Violation (CNOV)
5. Notice of Violation with Immediate Penalty (NOVP)
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

76

Information Type
6. Penalty FAXes
7. Penalty Assessment Report (PAR)
8. Determination of Fine Amount
9. Notice of Penalty Assessment
10. Documentation of Penalty Assessment Conference
11. Request for Remission of the Civil Penalty
12. Copy of Check for Payment of Penalty
13. Documentation of Mitigation Measures Completed in Lieu of the Penalty
14. All correspondence with the violator, including response letters, emails, meeting minutes, etc.
15. Any other information relevant to the investigation and enforcement process.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

77

Section 8: Assessment and Evaluation

8.1 Purpose
The purpose of assessing and evaluating the Illicit Discharge Detection and Elimination Program
is to determine if it is effective at identifying and eliminating illicit discharges and restoring
water quality conditions as well as to identify specific actions that can be taken to improve the
Program. The Illicit Discharge Detection and Elimination Program operates under an adaptive
management philosophy; therefore, once improvements have been identified they are
implemented as quickly and effectively as possible.

8.2 Adaptive Management
Several factors influence both the Program and Water Quality Measures described above, many
of which are in no way associated with the Illicit Discharge Detection and Elimination Program.
For example, the reporting of pollution problems can be affected by socioeconomic factors and
water quality can change significantly with weather conditions. Therefore, no one measure can
stand alone but instead they must be evaluated as a whole and in consideration of outside
influences before any conclusions can be drawn and even these conclusions can be
questionable. It is also important to look at long term trends for patterns. This is all taken into
consideration by the Program Manager and Supervisors when they evaluate the Program and
Water Quality Measures during monthly meetings. Additional data and information are
gathered as necessary regarding those measures that fail to meet their established goal. This
information is used to develop Action Plans for addressing Program deficiencies preventing the
goals from being achieved. Supervisors are responsible for implementing these Action Plans for
their assigned areas.

8.3 Evaluation Metrics
Program effectiveness is generally measured by observed improvements in measured water
quality and the number of water quality issues identified and eliminated. Program effectiveness
is measured through the following metrics:
• # illicit discharges identified and reported
• # of illicit discharges eliminated
• Have surface water quality conditions improved?

Data to answer these questions is collected and evaluated annually by the City of Charlotte,
Mecklenburg County and the Towns as part of the Annual reports for NPDES and Total
Maximum Daily Load (TMDL) regulations.
Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

78

For Mecklenburg County and the Towns, there are two measures of success for the IDDE
Program as described below. These measures are assessed and reported annually to NCDEQ
through the Annual reporting process. Program improvements are identified and implemented
as necessary.

1. Increasing Pollution Problems Identified – Mecklenburg County tracks the ratio of the
number of notices of violation issued to the number of IDDE inspections conducted with
an increase from the previous fiscal year serving as an indicator of the success of efforts
to find and eliminate pollution sources.
2. Repeat Violators Minimized (added in FY2021) – Mecklenburg County tracks the
percentage of written Notices of Violation issued to repeat violators compared to the
average of the percentages for the past three (3) fiscal years with a percentage equal to
or less than this average serving as an indicator of success.

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

79

Appendices

Appendix A: Charlotte Stormwater Pollution Control Ordinance
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Charlott
e Stormwater Pollution Control Ordinance.pdf

Appendix B: Mecklenburg County Surface Water Pollution Control Ordinance
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Mecklen
burg County Surface Water Pollution Control Ordinance.pdf

Appendix C: Town of Davidson Surface Water Pollution Control Ordinance
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Town of
Davidson Surface Water Pollution Control Ordinance.pdf

Appendix D: Town of Matthews Surface Water Pollution Control Ordinance
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Town of
Matthews Surface Water Pollution Control Ordinance.pdf

Appendix E: Quality Assurance/ Quality Control Plan and Procedures for Stream Walks and
Outfall Inventory Collection/ Inspection
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Outfall
Collection and Stream Walks QA_QC Plan Procedures.pdf

Appendix F: Stream Walks & Storm Water Outfall Inventory Collection/ Inspection Procedures
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Streamw
alk Procedures.pdf

Appendix G: Procedures for Responding to Citizen’s Requests for Service
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Procedur
es for Responding to Citizen’s Requests for Service.pdf

Appendix H: Emergency Response Guidelines for Charlotte-Mecklenburg Storm Water Services’
Water Quality Program
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/CMSWS
Emergency Response Manual.pdf

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

80

Appendix I: Illicit Discharge Elimination Program (IDEP) SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/IDEP
SOP.pdf

Appendix J: Public Education SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Public
Education SOP.pdf

Appendix K: Mecklenburg County Employee Training Plan
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Mecklen
burg County Employee Training Plan.pdf

Appendix L: City of Charlotte Employee Training Plan
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/City of
Charlotte Employee Training Plan.pdf

Appendix M: Public Involvement SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Public
Involvement SOP.pdf

Appendix N: Phase II Pollution Prevention and Good Housekeeping Inspection Program SOPs
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Phase II
Pollution Prevention and Good Housekeeping Inspection Program SOPs.pdf

Appendix O: Phase II Industrial and Vehicle Maintenance Inspection SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Phase II
Industrial and Vehicle Inspection SOP.pdf

Appendix P: City of Charlotte Industrial Facility Inspection SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/City of
Charlotte Industrial Facility Inspection SOP.pdf

Appendix Q: CMSWS Water Quality Monitoring Program QAPP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/CMSWS
Water Quality Monitoring Program QAPP.pdf

Illicit Discharge Detection and Elimination (IDDE) Program Plan Version 2.0

81

Appendix R: NCDEQ Fish Kill Investigation Form
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/NCDEQ
Fish Kill Investigation Form.pdf

Appendix S: Penalty Assessment Worksheet & Report
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Penalty
Assessment Worksheet & Report.pdf

Appendix T: Town of Matthews Penalty Assessment Notification
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Town of
Matthews Penalty Assessment Notification.pdf

Appendix U: Penalty Assessment Conference Form
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Penalty
Assessment Conference Form.pdf

Appendix V: Request for Penalty Remission and Waiver of Right to Appeal Form
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Request
for Penalty Reduction & Waiver of Right to Appeal.pdf

Appendix W: CMSWS Waterborne Disease Outbreak Prevention Policy
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/CMSWS
Waterborne Disease Outbreak Prevention Policy.pdf

Appendix X: Cityworks SOP
https://mecklenburgcounty.exavault.com/p/waterquality/IDDE_PolicyAndProcedures/Citywork
s SOP.pdf