NCS000395_MeckCo MS4 AUDIT REPORT_20210505

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT

NPDES PERMIT NO. NCS000395
Mecklenburg County, North Carolina

Audit Date: April 26 - 27, 2021

Report Date: May 5, 2021

North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

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2021 MS4 Compliance Audit Report ii
NPDES Permit No. NCS000395 - Mecklenburg County, NC

TABLE OF CONTENTS
Audit Overview ............................................................................................................................................. 1
Executive Summary ....................................................................................................................................... 1
Permittee Information .................................................................................................................................. 2
Supporting Documents ................................................................................................................................. 4
Program Implementation, Documentation & Assessment ........................................................................... 6
Illicit Discharge Detection and Elimination (IDDE) ...................................................................................... 10
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 14
Appendix A: Supporting Documents

DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Audit Overview
Audit ID Number:
NCS000395_MeckCo MS4 Audit_20210424
Audit Date(s):
April 26 – 27, 2021
Minimum Control Measures Evaluated:
☒ Program Implementation, Documentation & Assessment
☐ Public Education & Outreach
☐ Public Involvement & Participation
☐ Illicit Discharge Detection & Elimination
☐ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program
☐ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program
☐ Post-Construction Site Runoff Controls
☒ Pollution Prevention and Good Housekeeping for Municipal Operations
☐ Total Maximum Daily Loads (TMDLs)

Field Site Visits:
☐ Municipal Facilities. Number visited: Choose an item.
☐ MS4 Outfalls. Number visited: Choose an item.
☐ Construction Sites. Number visited: Choose an item.
☐ Post-Construction Stormwater Runoff Controls. Number visited: Choose an item.
☐ Other: Municipal Stormwater Control Measures. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.

Auditor: Jeanette Powell, MS4 Program Coordinator
Signature__________________________________________
Date: May 5, 2021

Executive Summary

Charlotte Mecklenburg Stormwater Services (CMSWS) leads and coordinates a comprehensive watershed-
based Phase II MS4 Program, which goes above and beyond the Phase II requirements to address local water
quality impacts and issues. The program framework and tools provide consistency and structured
regulatory compliance to the MS4s under this permit; and also coordinates with the City of Charlotte Phase I
MS4 program and requirements. CMSWS provides exceptional leadership, guidance and attention to detail
for all nine permittees. The eight co-permittees are engaged, knowledgeable and well versed in stormwater
management protocols and their specific responsibilities, as defined in an annual Work Plan. The suite of
custom and commercial program management tools, SOPs, templates and databases form the
comprehensive framework for stormwater management program asset and task management, reporting,
and assessment. This program is a shining example of how co-permittee relationships work to provide local
water quality benefits through consistent regional implementation.

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Permittee Information
MS4 Permittee Name:
County of Mecklenburg
Permit Effective Date:
February 17, 2017
Permit Expiration Date:
February 16, 2022
Address:
2145 Suttle Ave, Charlotte NC 28208-5237
Last MS4 Inspection/Audit:
November 10, 2015
Co-permittee(s), if applicable:
Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill, Pineville
Charlotte-Mecklenburg Schools
Central Piedmont Community College

Permit Owner of Record: W.D. Canaan
Primary MS4 Representatives Participating in Audit

See Supporting Document 1: Audit Attendee List

MS4 Receiving Waters

See Supporting Document 2: Stormwater Quality Management Program Plan, Section 3.3, Table 2

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

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Supporting Documents
Item
Number Document Title When Provided
(Prior to/During/After)
01 Audit Attendee List -
02 Stormwater Quality Management Program Plan (March 2021) Prior
03 BMP Summary Tables (March 2021) Prior
04 Annual Reports 2018 – 2020 (See Laserfiche) Prior
05 Program Organizational Charts Prior
06 Link to Stormwater Inventory Map
https://maps.mecklenburgcountync.gov/StormWaterInventory/ Prior
07 Program Implementation Agreements Prior
08 CMSWS IDDE Manual (version 2.0, February 2021) Prior
09 Operation & Maintenance Plan for Municipal Facilities (February 2021) Prior
10 Operation & Maintenance Plan for MS4s, Streets & Parking Lots Prior
11 Operation & Maintenance Plan for Municipal SCMs (March 2021) Prior
12 BMP Maintenance Plan Form PCO#20 (Rev. Jan 08) Prior
13 Post-Construction Ordinances Prior
14 Work Plan Demonstrated
15 Time Pro Database Demonstrated
16 Cityworks Database Demonstrated
17 Environmental Data Management System Demonstrated
18 Emerald System Demonstrated
19 Electronic Plan Review (EPM) System Demonstrated
20 Water Quality Program Policies &Procedure Manual Demonstrated

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

21 Co-Permittee Quarterly Reports Demonstrated
22 SWPPP Demonstrated
23 Municipal Facility Inventory Demonstrated
24 Cost Benefit Analysis Demonstrated
25 CMSWS Training Video After

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
See Supporting Document 1: Audit Attendee List
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1
Legal Mechanisms
The permittee maintained adequate legal mechanisms, such as regulations,
ordinances, policies and procedures to implement all provisions of the Stormwater
Plan.
Yes 7, 13
The permittee notified the Division of major modifications of these authorities, the
reasons and justifications for these changes.
Not
Applicable ---
The Division commented on these modifications as deemed necessary to assure
appropriate implementation of the Stormwater Plan.
Not
Applicable ---
Comments
The permittee maintained appropriate ordinances and program implementation agreements to implement all
provisions of the permit and Stormwater Plan.

II.A.2
Program
Evaluation
The permittee evaluated program compliance at least annually. Yes
4, 9, 10,
11, 14,
24
The permittee evaluated the appropriateness of best management practices at least
annually. Yes ---
The permittee evaluated progress towards achieving measurable goals at least
annually. Yes ---
Comments
The permittee evaluates the program for compliance, appropriateness and progress annually. The SWMP is
reviewed and updated as necessary, but at least on an annual basis to identify modifications and improvements
needed to maximize effectiveness to the maximum extent practicable. As a result of this evaluation, modifications
and improvements are identified for implementation during the following fiscal year. The evaluation is submitted to
NCDEQ annually, including the identification of modifications and improvements to be made to the SWMP as well as
the updated SWMP for the following fiscal year.

II.A.3
Funding & Staffing The permittee maintained adequate funding and staffing to implement and manage
the provisions of the Stormwater Plan and meet all requirements of this permit. Yes 7, 14, 15
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. Responsibilities for all
components of the Plan shall be documented and position(s) assignments provided.
Yes 2, 5, 14

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Program Implementation, Documentation & Assessment
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided. Yes 2, 3, 5,
14
Comments
Program funding is provided through a stormwater utility, review fees, and quarterly billing of co-permittees for
services provided, as defined in the Work Plan and managed in Time Pro.

The Stormwater Plan and program organizational charts clearly define the positions responsible for each stormwater
program component and the Work Plan provides additional detail on responsibilities and tasks.

II.A.4
Stormwater Plan The permittee implements provisions of the Stormwater Plan and evaluates the
performance and effectiveness of the program components at least annually. Yes 4
Results are used by the permittee to modify the program components as necessary to
accomplish the intent of the Stormwater Program. Yes 4, 14, 24
The permittee implements the six minimum control measures and the discharges
have been determined to cause or contribute to non-attainment of an applicable
water quality standard.
Yes 2, 5, 7,
14
If yes, to address the non-attainment, the permittee shall expand or better tailor its
BMPs within the scope of the six minimum control measures Yes 2, 3
Comments
The permittee implements, evaluates and updates the Stormwater Plan to address permit compliance and water
quality issues. The permittee implements appropriate TMDL responses to address non-attainment.

Each co-permittee is responsible for compliance with permit requirements for the operation and maintenance of
facilities, MS4s, stormwater control measures (SCMs), streets, and parking lots that they own and/or maintain.
In the Town of Huntersville and its ETJ, Town staff are responsible for plan reviews and issuing land development
permits as well as conducting inspections during construction to ensure compliance with Permit requirements.

II.A.5
Stormwater Plan
Modifications
The permittee kept the Stormwater Plan up to date. Yes 2
Where the permittee determined that modifications were needed to address any
procedural, protocol, or programmatic change, such changes were made as soon as
practicable, but not later than 90 days, unless an extension was approved by the
Division.
Yes ---
The permittee submitted major modifications to the Stormwater Plan to the Director
for approval.
Not
Applicable ---

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Program Implementation, Documentation & Assessment
Comments
The Stormwater Quality Management Program Plan includes documented annual revisions and updates. The SWMP
is reviewed and updated as necessary, but at least on an annual basis to identify modifications and improvements
needed to maximize effectiveness to the maximum extent practicable. As a result of this evaluation, modifications
and improvements are identified for implementation during the following fiscal year. The evaluation is submitted to
NCDEQ annually, including the identification of modifications and improvements to be made to the SWMP as well as
the updated SWMP for the following fiscal year.

II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the primary
permittee (Mecklenburg County)? Yes 5, 7, 14
If yes, are there written agreements in place? Yes 5, 7, 14
Comments
The Towns of Cornelius, Davidson, Huntersville, Matthews, Mint Hill and Pineville, and CPCC and Charlotte-
Mecklenburg Schools 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 program implementation agreement for each MS4 clearly defines the overarching roles and responsibilities of
each entity, and the annual Work Plan provides specific details.

III. A
Program
Documentation
The permittee maintains documentation of all program components including, but
not limited to, inspections, maintenance activities, educational programs,
implementation of BMPs, enforcement actions etc., on file for a period of five years.
Yes
15, 16,
17, 18,
19, 20,
21
Comments
The permittee maintains documentation of all program components utilizing a comprehensive suite of tools
including Time Pro, Cityworks, EDMS, Emerald, EPM, and co-permittee quarterly reports. Co-permittees maintain
individual documentation associated with facility SPPPs and local pollution prevention and good housekeeping
measures and provide documentation to Mecklenburg County.

III.B
Annual Report
Submittal

The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit. Yes 4
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal. Yes 4
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee’s Stormwater Plan, including, but not limited the following:
1. Completion and submittal of the reporting information contained within the
online BIMS Stormwater Management Program Assessment (SWMPA) Yes 4

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Program Implementation, Documentation & Assessment
Comments
The permittee submitted a Stormwater Management Program Assessment (SWMPA) for each reporting period. The
SWMPA satisfies the annual reporting requirements [Ref. NCS000395 Part IV.B.3].

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Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)
See Supporting Document 1: Audit Attendee List
Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 8
If yes, the written program includes provisions for program assessment and
evaluation and integrating program. Yes 8
Comments
The permittee implements a comprehensive IDDE program, which is documented in the Charlotte-Mecklenburg
Storm Water Services Illicit Discharge Detection and Elimination Manual, as updated February 2021. This document
is updated every five years. 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. In addition to
coordinating with local jurisdictions, CMSWS also works cooperatively with NCDEQ in the implementation of its IDDE
Program through a Memorandum of Agreement.

The Mecklenburg County Surface Water Pollution Control Ordinance applies in all unincorporated areas of
Mecklenburg County as well as within the corporate limits of Cornelius, Huntersville, Mint Hill and Pineville (Effective
Date: May 5, 2004; updated May 21, 2020.).

The Town of Davidson Surface Water Pollution Control Ordinance applies within the corporate limits of the Town of
Davidson (Effective Date: January 2004; updated August 25, 2020).

The Town of Matthews Surface Water Pollution Control Ordinance applies within the corporate limits of the Town of
Matthews (Effective Date: November 27, 2000; updated January 14, 2020).

II.D.2.b
Legal Authorities
The permittee maintained an IDDE ordinance or other regulatory mechanism(s) that
provides the legal authority to prohibit illicit connections and discharges. Yes 8
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes 8

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Illicit Discharge Detection and Elimination (IDDE)
Comments

See above. Surface Water Pollution Control Ordinances are available online.

II.D.2.c
Storm Sewer
System Map
The permittee maintained a current map showing major outfalls* and receiving
streams. Yes 6
Comments
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.

This program identifies stormwater structures, such as catch basins, inlets, 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 is stored in the “HydroNetwork” dataset. 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.

*Major outfalls are discharges from > 36” diameter pipes or drainage areas of > 50 acres. In areas zoned for industrial activity, major outfalls
are > 12” or drainage area > 2 acres.
II.D.2.d
Dry Weather Flow
Program
The permittee maintained a program for conducting dry weather flow field
observations in accordance with written procedures. Yes 8
Comments
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. Some basins may be walked more
than once every five years.

II.D.2.e
Investigation
Procedures
The permittee maintained written procedures for conducting investigations of
identified illicit discharges. Yes 8
Comments
CMSWS maintains a written document describing its IDDE Program that is referred to as the IDDE Manual. All written
procedures and forms for the execution of the IDDE Program are contained in this document, including links to
Standard Operating Procedures (SOPs) that include detailed implementation procedures. The Manual is reviewed
and updated every five (5) years whereas the more detailed SOPs are reviewed and updated annually.

II.D.2.f For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Illicit Discharge Detection and Elimination (IDDE)
Track and
Document
Investigations
1. The date(s) the illicit discharge was observed Yes 16, 18
2. The results of the investigation Yes ---
3. Any follow-up of the investigation Yes ---
4. The date the investigation was closed Yes ---
Comments
IDDE investigations are documented and tracked to closure utilizing a standardized process and reporting forms that
include the above components.

II.D.2.g Employee
Training The permittee implemented and documented a training program for appropriate
municipal staff who, as part of their normal job responsibilities, may come into
contact with or otherwise observe an illicit discharge or illicit connection.
Yes 17, 25
Comments
CMSWS provides comprehensive awareness and pollution prevention/good housekeeping training videos and each town
implements, documents, tracks and reports their own training. CMSWS provides training to CPCC and Charlotte-Mecklenburg
Schools. Training targets municipal employees to identify and report water quality issues utilizing a “street to stream” concept.
Staff targeted for stormwater awareness training include tax assessors, social services, police, parks & recreation, etc.
Appropriate training records are maintained in SPPPs.

II.D.2.h
Public Education

The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste. Yes 2
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. Yes 2
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste. Yes 2
Comments
CMSWS implements a comprehensive multi-media public education and outreach program that informs target
audiences on the physical attributes of stormwater runoff, including the pollutants typically contained in runoff and
their likely sources, as well as the impacts of these pollutants on surface water quality. The program also includes
the steps that the public can take to reduce pollutants in stormwater runoff and protect water quality.

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Illicit Discharge Detection and Elimination (IDDE)
II.D.2.i
Public Reporting
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for the
public to report illicit discharges. Yes 15, 16,
18
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges. Yes 15, 16,
18
The permittee established and implemented response procedures for citizen
requests/reports. Yes 15, 16,
18
Comments
The permittee maintains a phone helpline at 311 from 7 a.m. to 7 p.m. Monday through Friday, except for recognized
holidays. This stormwater helpline receives requests for service, which are forwarded to CMSWS for response,
provides general water quality information, and promotes public involvement and participation through established
volunteer programs. To ensure effectiveness, CMSWS has provided the staff at 311 with a “key word” index that is
used to trigger select responses to water quality related questions and requests. Various media, including television,
radio, print ads, brochures, social media, etc., are used to promote 311 as the number to contact to report suspected
pollution problems and sign-up for volunteer programs.

II.D.2.j
Enforcement The permittee implemented a mechanism to track the issuance of notices of violation
and enforcement actions administered by the permittee. Yes 16
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance. Yes 16
Comments
Violations are tracked in Cityworks and this off the shelf software has the functionality to identify chronic violators.

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NPDES Permit No. NCS000395 - Mecklenburg County, NC

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
See Supporting Document 1: Audit Attendee List
Permit Citation Program Requirement Status Supporting
Doc No.
II.G.2.a
Facility Inventory
The permittee maintained a current inventory of facilities and operations owned
and operated by the permittee with the significant potential for generating
polluted stormwater runoff.
Yes 23
Comments
CMSWS maintains a current inventory of facilities and operations owned and operated by Mecklenburg County,
Central Piedmont Community College, Charlotte-Mecklenburg Schools, and the towns of Cornelius, Davidson,
Huntersville, Matthews, Mint Hill, Pineville. Properties are identified utilizing a standardized process. An annual
evaluation by CMSWS identifies new facilities, and each co-permittee is required to review the inventory annually
and identify facilities that have closed, moved, or changed pollution potential status. The inventory includes a total
of 3,052 properties owned by the co- permittees that have been evaluated based on the standard criteria, with a
total of 38 identified as having a significant potential for generating polluted stormwater runoff that have been
included in the Pollution Prevention and Good Housekeeping Program.

II.G.2.b
Operation and
Maintenance (O&M)
for Facilities

The permittee maintained and implemented an O&M program for municipally
owned and operated facilities with the significant potential for generating polluted
stormwater runoff.
Yes 09, 22
If yes, the O&M program specifies the frequency of inspections. Yes ---
If yes, the O&M program specifies the routine maintenance requirements. Yes ---
If yes, the permittee evaluated the O&M program annually and updated as
necessary. Yes ---
Comments
CMSWS performs an annual compliance inspection of each facility that has been determined to have significant pollution
potential, and each facility has a site-specific SPPP. The town co-permittees utilize the CMSWS SPPP template, and the school
co-permittees and Solid Waste have their own SPPPs. Each SWPP addresses storage, waste, spill and leaks, non-stormwater
discharges, SOPs, training records, preventive maintenance and good housekeeping measures. SPPPs also include a spill plan,
evaluation of BMPs, inspections, cleanup contractor contacts and reporting information. CMSWS performs an annual
compliance inspection of each SPPP facility, and each co-permittee performs at least one additional inspection of each facility,
which results in semi-annual inspections.

II.G.2.c
Spill Response
Procedures
The permittee has written spill response procedures for municipally owned or
operated facilities. Yes 09, 22

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Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
Facility SPPPs include appropriate spill response procedures, which include specific actions to be taken to prevent
and respond to spills, clean up contractors, reporting protocols, etc.

II.G.2.d and e
Streets, Roads, and
Public Parking Lot
Maintenance

The permittee evaluated BMPs to reduce polluted stormwater runoff from
municipally-owned streets, roads, and public parking lots within the corporate
limits.
Yes 10, 16,
18, 24
If yes, the permittee updated the Stormwater Plan within 12 months to include
the selected BMPs. Yes ---
The permittee evaluated existing and new BMPs annually that reduce polluted
stormwater runoff from municipally-owned streets, roads and public parking lots
within the corporate limits.
Yes
10, 14,
15, 16,
18, 24
If yes, the permittee evaluated the effectiveness of these BMPs based on cost
and estimated quantity of pollutants removed. Yes ---
Comments
CMSWS has evaluated BMPs for reducing the discharge of floatables and other pollutants from municipally-owned
streets and parking lots. Each co-permittee cleans streets and parking lots in identified problem areas and performs
seasonal leaf pickup. Problem areas are identified based on accumulations of leaves, trash, debris, blockages,
flooding, etc. Each co-permittee provides trash receptacles at public parking lots and performs scheduled manual
trash pick-up. Each co-permittee maintains records documenting the number of streets and parking lots cleaned, and
the pounds of trash, sediment, and other pollutants removed, as well as the estimated cost of the program. This data
is provided to CMSWS annually for use in evaluating program effectiveness and annual reporting. An O&M Plan has
been developed for parking lot cleaning. CMSWS performs an annual cost-benefit evaluation for housekeeping
measures performed on municipal streets and parking lots and collection systems. The costs and quantity of
pollutants removed are benchmarked to established metrics to determine effectiveness. The county does not
own/operate any streets, but the towns do.

II.G.2.f
O&M for Catch
Basins and
Conveyance Systems
The permittee maintained and implemented an O&M program for the stormwater
sewer system including catch basins and conveyance systems that it owns and
maintains.
Yes
10, 14,
15, 16,
18, 24
Comments
Each co-permittee cleans catch basins and conveyance systems and repairs the MS4 in identified problem areas.
These problem areas are identified based on accumulations of leaves, trash, debris, blockages, flooding, etc. Each co-
permittee maintains record documenting the number of inlets, outlets and pipes cleaned and the pounds of trash,
sediment, and other pollutants removed. This data is provided to CMSWS annually for use in evaluating program
effectiveness and for inclusion in the annual report. CMSWS performs an annual cost-benefit evaluation for
collection systems owned and operated by the towns and in the unincorporated areas of the county (outside the
public NCDOT right of way). The costs and quantity of pollutants removed are benchmarked to established metrics
to determine effectiveness.

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Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.g
O&M for Municipal
Structural
Stormwater Controls
The permittee maintained a current inventory of municipally-owned or operated
structural stormwater controls installed for compliance with the permittee’s post-
construction ordinances adopted by Mecklenburg County and the Towns of
Cornelius, Davidson, Huntersville, Matthews, Mint Hill, and Pineville on June 30,
2007 and by the City of Charlotte on July 1, 2008.
Yes
02, 11,
14, 15,
16
The O&M program specifies the frequency of inspections and routine maintenance
requirements. Yes 11, 12
The permittee inspects and maintains municipally-owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee. Yes
02, 07,
11, 14,
15, 16
The permittee documented inspections and maintenance of all municipally-owned
or maintained structural stormwater controls. Yes 15, 16
Comments
CMSWS maintains a current inventory of municipal SCMs installed to comply with the Phase II MS4 permit
requirements and the 2008 and later City of Charlotte Phase I MS4 SCMs. There are no county-owned SCMs outside
of Charlotte. CMSWS inspects all Phase II SCMs annually and provides the reports to the appropriate co-permittees
for maintenance and/or resolution of any identified issues. Required maintenance and/or remedies are verified as
completed. CMSWS also verifies that the Phase I SCMs in Charlotte have been inspected annually by the device
owners or their contractor.

II.G.2.h
Pesticide, Herbicide
and Fertilizer
Application
Management

The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management. Yes 14, 15,
16
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management.
Not
Applicable ---
The permittee ensured all permits, certifications, and other measures for
applicators are followed. Yes 14, 15,
16
Comments
Each permittee maintains training and certification records in their SPPPs. CMSWS verifies that staff have maintained current
pesticide applicator certifications and training requirements as a standard component of each annual facility inspection.
Pesticide, herbicide and fertilizer contractors (if any) are required by contract to be certified and standard requirements for
certification includes training.

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Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.i
Staff Training The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. Yes
02, 14,
15, 16,
25
Comments
CMSWS provides training materials to the town co-permittees to self-implement. The town co-permittees maintain
training logs and report to CMSWS. CMSWS performs the training for county staff and the school co-permittees.
Standard training includes a video featuring stormwater awareness, identification of issues and reporting
mechanisms. The training teaches the “street to stream” concept and is provided to staff who may identify issues
during their routine duties including tax assessors, social services, police and parks & recreation workers.

Annual training is provided to the employees involved in implementing pollution prevention and good housekeeping
practices at the municipally operated facilities. Training is also provided for other employees involved in municipal
operations that have the potential to cause negative water quality impacts. The goal of this training is to inform
employees of the actions necessary to reduce the discharge of pollution and protect water quality from activities
such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances,
storm sewer system maintenance, and other municipal activities as well as the steps for reporting suspected illicit
discharges and actions required for compliance with permit requirements.

II.G.2.j
Vehicle and
Equipment Cleaning
The permittee described and implemented measures that prevent or minimize
contamination of the stormwater runoff from all areas used for vehicle and
equipment cleaning.
Yes 22
Comments
Each facility SPPP includes a detailed evaluation of site operations and characteristics, which includes vehicle and
equipment cleaning. The primary goal is to eliminate exposure wherever feasible and implement appropriate SOPs
where exposure cannot be eliminated.

2021 MS4 Compliance Audit Page 18 of 18
NPDES Permit No. NCS000395 - Mecklenburg County, NC

APPENDIX A: SUPPORTING DOCUMENTS

SUPPORTING DOCUMENTATION IS ON FILE IN THE ONLINE
STORWATER PROGRAM LASERFICHE REPOSITORY