NCS000395_MeckCo Self Audit_20210513

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2020 Internal Audit Report
Permit No. NCS000395

Table of Contents:

Section 1: Purpose..................................................................................................................... 1
Section 2: Background ............................................................................................................. 1
Section 3: Documentation of Permit Compliance Activities ................................................. 1
Section 4: Audit Preparation ................................................................................................... 2
Section 5: Audit Process ........................................................................................................... 2
Section 6: Audit Results ........................................................................................................... 3
6.1 Audits Findings & Corrective Actions Completed .......................................... 4
6.2 Permit Compliance Assessment ..................................................................... 10
Section 7: Conclusion & Process Forward ........................................................................... 10

Appendices:

Appendix A: Co-Permittee Responsibilities for Compliance with Phase Permit
Requirements............................................................................................................................... 11
Appendix B: NCDEQ Phase II MS4 Audit Template (completed) ........................................ 15

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Section 1: Purpose

Identify and adequately address issues/concerns related to compliance with Phase II Permit
NCS000395 by the County, Towns, CPCC, and CMS in preparation for the State’s audit in
February 2021.

Section 2: Background

Mecklenburg County, CPCC, CMS and the Towns of Cornelius, Davidson, Huntersville,
Matthews, Mint Hill, and Pineville are covered jointly under NPDES Storm Water Permit
Number NCS000395. The Permit was first issued on July 1, 2005 and subsequently amended on
June 4 and July 30, 2007 at the direction of the NC Environmental Management Commission to
require specific management strategies for protection of the Carolina heelsplitter in response to a
lawsuit filed by the Southern Environmental Law Center. This Permit was renewed on
November 11, 2011 and February 17, 2017 with the next expiration date set for February 16,
2022. The State’s audit is scheduled to occur one year prior to this renewal date. Mecklenburg
County is identified as the lead for the administration of the joint Permit. The activities
performed by Mecklenburg County to ensure compliance with Permit requirements are described
in its annual Work Plan that is provided to all co-permittees. Compliance activities are also
performed by each co-permittee as described in Appendix A. This document is sent to every co-
permittee annually along with the new Work Plan. According to the terms of the Permit, each
co-permittee is responsible for compliance within their respective jurisdiction as described in the
Storm Water Management Program Interlocal Agreements entered into between Mecklenburg
County and all co-permittees effective July 1, 2002. These Agreements identify Charlotte-
Mecklenburg Storm Water Services (CMSWS) as the agency responsible for fulfilling
Mecklenburg County’s role in Permit compliance.

Section 3: Documentation of Permit Compliance Activities

The number one compliance issue identified by State staff in the audits they have completed to
date is the failure to maintain adequate documentation. A major component of our FY2020
internal audit process is to ensure this is not a compliance issue during our audit in 2021.
Toward this end, the following have been identified for maintaining adequate documentation for
our Permit:
1. Time Pro maintains all Work Plans describing CMSWS’s compliance activities.
2. CityWorks maintains documentation of the completion of these compliance activities,
including erosion control and BMP inspections.
3. LAN folder at \\hmcfs01\attachments\WQ serves as the backup destination for
CityWorks documentation generated by the Water Quality Program.
4. LAN folder at G:\Water Quality\WQ_Xfer\WQ\Phase II Permit maintains annual
reports, co-permittee information, permit applications, permit audits, Phase II
Permits, presentations, State correspondence, Storm Water Quality Management
Program Plans, TMDL documentation, and other information relating to the Phase II
Permit.
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5. The Environmental Data Management System (EDMS) serves as the reporting
mechanism for data relating to services requests and notices of violation, including
repeat offenders as required by our Permit.
6. The Emerald System maintains documentation of stormwater drainage service
requests.
7. The Electronic Plan Review (EPM) system maintains documentation of plan and plat
reviews for compliance with Erosion Control and Post-Construction Programs.

Section 4: Audit Preparation

By Friday, February 28, 2020, review the following information that you are not currently
familiar with prior to beginning the audit process:
1. Portion(s) of the Phase II Permit pertaining to their assigned Section(s) described in #1, a
through i below. The current Permit is located on the LAN at the following link:
G:\Water Quality\WQ_Xfer\WQ\Phase II Permit\Phase II Permit. This Permit describes
the requirements for compliance.
2. Portion(s) of the FY2020 Storm Water Quality Management Program Plan pertaining to
their assigned Section(s) described in #1, a through i below. The current Plan is located
on the LAN at the following link: G:\Water Quality\WQ_Xfer\WQ\Phase II Permit\Phase
II Permit\Storm Water Management Plan. This Plan describes the actions to be
undertaken by CMSWS and co-permittees to comply with Permit requirements.
Document in the Audit Template under the appropriate section when these actions do not
meet Permit requirements.
3. Portion(s) of the FY2020 Work Plan pertaining to their assigned Section(s) described in
#1, a through i below. The current Work Plan is contained in Time Pro. This Plan
describes the specific activities to be completed by CMSWS in FY2020 to comply with
Permit requirements. Document in the Audit Template under the appropriate section
when these activities do not meet Permit requirements.
4. Portion(s) of the Phase II Toolhbox pertaining to their assigned Section(s) described in
#1, a through i below. The Tool Box is located at the following link:
https://deq.nc.gov/about/divisions/energy-mineral-and-land-
resources/stormwater/stormwater-program/npdes-ms4-2. This Toolbox includes
presentations, documents, etc. that describe what the State and EPA expect regarding
Permit compliance. In some cases, these expectations are not included in our Permit.
You need to be fully aware of these expectations when you perform your audit and when
our actions do not meet these expectations, you must document this in the Audit
Template under the appropriate section. We will decide as a group if correction actions
are required or if we are going to adhere to the specific wording in the Permit.

Section 5: Audit Process

1. By Tuesday, March 31, 2020, Supervisors and Managers will complete the section(s) of
the Phase II MS4 Audit Template that correspond(s) to their assigned program
responsibilities as follows:
a. Supporting Documents – Rusty Rozzelle
b. Program Implementation, Documentation & Assessment – Rusty Rozzelle
c. Public Education and Outreach – David Caldwell
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d. Public Involvement and Participation – David Caldwell
e. Illicit Discharge Detection and Elimination (IDDE) – Ryan Spidel
f. Construction Site Runoff Controls – Corey Priddy
g. Post-Construction Site Runoff Controls – Don Ceccarelli
h. Pollution Prevention and Good Housekeeping for Municipal Operations – Richard
i. Total Maximum Daily Loads (TMDLs) – Olivia Edwards
All time spent on the completion of the audit must be logged into Time Pro under the
“Task” entitled “Audit.” Supervisors and Managers must do the following for all the
lines in the Audit Template for it to be considered complete:
a. Select the proper response from the dropdown under “Choose an item.”
b. Describe the document that supports your response in the next block to the right.
c. Provide additional information in the “Comments” section for clarification. For
example, if you think our activities comply with Permit requirements but not with
State and/or EPA expectations, note this in the comment field.
d. Complete a minimum of 1 site visit evaluation when this is included in your Audit
Template.
e. Where records’ review is required as part of the audit template, staff should limit
their review to records for FY20 (July 1, 2019 to June 30, 2020).
f. Highlight all rows of the Audit Template where you have identified
noncompliance either with the Permit or with State/EPA expectations, or both.
g. For all audit Finding(s), identified in the “Comments” section the specific Actions
to be undertaken to ensure compliance, including staff assignments and deadlines
for completion. Co-permittees are to be involved in these actions as necessary.
Supervisors and Managers will obtain feedback from other staff in the completion of their
assigned sections of the Audit Template through an iterative review process. All staff
that perform duties relating to the program area being audited must agree on the
responses in the Audit Template. By Tuesday, March 31, 2020, Supervisors and
Managers will provide their completed Audit Templates to the WQ Program Manager
who will compile them into one document.
2. By Friday, August 28, 2020, Supervisors and Managers that documented Findings in the
completion of their Audit Templates will complete all necessary follow up Actions.
These completed Actions are to be documented in the Comments section of the Audit
form, including the date(s) the Actions were completed. The completed Audit form will
be maintained on the LAN in the following folder: G:\Water
Quality\WQ_Xfer\WQ\Phase II Permit\Permit Audit\2020 Internal Audit.
3. February 2021 – Anticipated State Audit.
4. By Friday, August 20, 2021, application for renewal of Permit must be submitted to
NCDEQ. This is 180 days prior to Permit expiration.

Section 6: Audit Results

CMSWS completed its 2020 Phase II Audit of Permit No. NCS000395 on September 24, 2020,
including the completion of the State’s Audit Template (see Attachment 2) and the compilation
of 28 supporting documents. As a result, 22 Findings were identified and follow up Actions
completed to improve the effectiveness and efficiency of Permit compliance activities. These
Findings and Actions Completed are described in the following subsections.

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6.1 Audits Findings & Corrective Actions Completed

Provided below are the 22 Findings and Actions Completed resulting from the 2020 Internal
Audit broken out into the applicable Sections of the Permit. The Finding(s) and Follow Up
Action(s) completed are also provided in red text and yellow highlighting in the State’s Audit
Template included as Attachment 2.

Program Implementation, Documentation & Assessment (findings stated below provided by
Rusty Rozzelle)

1. Finding(s): The Stormwater Plan, Permit and annual report that were on the website
were outdated.
Follow Up Action(s) Completed (Date): On May 18, 2020, Rusty Rozzelle contacted the
web administrator, and the updated documents were placed on the website.

2. Finding(s): The Stormwater Plan does not include a description of the methodology used
to insure proper documentation of Permit compliance activities.
Follow Up Action(s) Completed (Date): On June 18, 2020, Rusty Rozzelle added a
description of the documentation process for Permit compliance activities in Section 10.2
of the FY2021 version of the Stormwater Plan.

Public Education and Outreach (findings stated below provided by David Caldwell)

3. Finding(s): Our target audiences are very broad. Wondering if they are expected to be
more specific. For example, targeting renters in apartments due to grease/overflows,
targeting restaurants due to grease/dumpster housekeeping issues, targeting gas stations
for overflow, petroleum spills, targeting people that live in Goose Watershed (fecal
issues), etc.
Follow Up Action(s) Completed (Date): On 6/5/20, David Caldwell reviewed the DEQ
and EPA websites and determined that the target audiences identified are sufficient. The
Stormwater Plan includes a section explaining our Targeted Outreach program which
includes specific targeted audiences within the general categories. An example of a
specific targeted outreach mailer was added as Figure 5 to the 2021 version of the
Stormwater Plan. The Cityworks Administrator was contacted, and Municipal and
Institutional categories were added to the Educational Distribution dropdown for Activity
Reports so that our targeted education material distribution can be tracked effectively.
David Caldwell informed staff to document the distribution of targeted educational
material in Cityworks. Results will be provided in annual reports.

4. Finding(s): Table 8 in section 2.8 of the Stormwater Plan provides pollutant sources but I
do not see potential impacts or physical attributes of stormwater runoff mentioned here.
Our program includes Environmental Notices available for multiple pollutant sources and
these handouts do address potential impacts of pollutants to our surface waters. There are
2 separate files for these environmental notices. We need to clean up these directories and
get rid of the old versions.
Follow Up Action(s) Completed (Date): On 6/5/20, David Caldwell updated Table 8 in
Section 2.8 of the 2021 version of the Stormwater Plan to include potential pollutant
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impacts and physical attributes of stormwater (see Supporting Document #27). Litter was
also added as a targeted pollutant. The Environmental Notice files on the LAN were
reviewed and organized. Several notices were updated. The Environmental Notices can
be found on the LAN at G:\Water Quality\WQ_Xfer\WQ\Educational Handouts.

5. Finding(s): The Mint Hill and CPCC websites do not contain a link to the CMSWS
website. Also, there should be some information provided with every link that indicates
its purpose as follows: “To obtain information regarding activities undertaken to protect
and restore water quality in our storm sewer systems, creeks and lakes, including
volunteer opportunities.”
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6
towns to request that the above wording and links be established on their websites. Ken
Friday contacted CMS and CPCC and made the same request. On 8/20/20, staff verified
that all Town websites have been updated to ensure consistent wording and links to the
CMSWS website. On 8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS
and Vicki Saville with CPCC making them aware that links from their websites needed to
be restored to the CMSWS. Jeff and Vicki are responsible for compliance with the
Stormwater Permit for their organizations.

6. Finding(s): We have reached all targeted audiences in some manner but not always with
“material.”
Follow Up Action(s) Completed (Date): In July 2020, David Caldwell worked with his
staff to ensure that all the identified target audiences were effectively reached in
compliance with Permit requirements. Table 8 of the Stormwater Plan describes the
various Programs used to reach target audiences for the different targeted pollution
sources. Section 3 describes the ways stormwater education is provided to the target
groups. Cityworks has a field to track educational material provided to the targeted
audiences. Section 3.4.6 of the Stormwater Plan describes the programs that target
specific groups within the audiences. Targeted groups are provided educational material
and messaging when appropriate. During events / presentations, educational materials are
distributed and tracked in the Events / Presentations spreadsheet on the One Drive
Umbrella Team shared file directory.

7. Finding(s): Some town websites do not noticeably promote the hotline for reporting.
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6
towns and requested that this information be added to their websites. Ken Friday
contacted CMS and CPCC and made the same request. On8/20/20, staff verified that all
Town websites have been updated to ensure consistent wording and links to the CMSWS
website. On 8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS and Vicki
Saville with CPCC making them aware that links from their websites needed to be
restored to the CMSWS. Jeff and Vicki are responsible for compliance with the
Stormwater Permit for their organizations.

8. Finding(s): These are some areas of improvement we may want to consider based on a
review of EPA recommendations:
1. Track pollutant locations and target education to those areas vs. the entire community
(i.e. increase and document efforts in “hotspot” locations for effectiveness)?
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2. Maintain a description of the target audiences and why they were selected, including
a description of the types of ethnic and economic groups engaged?
3. Prioritize watersheds or neighborhoods for outreach?
4. Evaluate languages spoken throughout communities?
Follow Up Action(s) Completed (Date): On 6/5/20, Section 3.4.6 of the Stormwater
Plan was reviewed to ensure compliance with targeted audience requirements. Cityworks
is used to track educational material distributed in the corresponding target areas. Section
3.4.6 describes the hotspot targeted audience educational effort, and this was determined
to be adequate for Permit compliance. Cityworks will be used to track the amount of
educational material distributed and the location of the distribution. Descriptions of
targeted audiences are found in section 2.9 of the Stormwater Plan and these were
determined to be adequate for Permit compliance. Ethnic and economic information is
currently not available for the education /outreach program although we do have a form
requesting ethnic information which is handed out at workshops. Up to date information
may be available after the new census data is available, at which time we will evaluate
this topic again. A new section 3.5 was added to the Stormwater Plan to indicate this.
Watersheds are currently prioritized for outreach sometimes based upon specific issues
such as TMDLs or a specific pollutant of concern (i.e. Reedy Creek for bacteria, etc.).
Currently, prioritization for public education usually occurs based upon the targeted
pollution concerns as described in Section 3.4.6 of the Stormwater Plan. For example,
we are currently partners with the Regional Stormwater Partnership of the Carolinas and
Johnson C Smith University on a WRRI grant which involves improving public
education/outreach and public involvement in 3 underserved communities in west
Charlotte. This has been an area identified for needing additional outreach and
involvement and plans are underway to determine ways to engage the citizens in these
communities. Language information is not available for specific areas of Mecklenburg
county. We do have numerous BMP educational flyers printed in various languages, and
we have access to a language services contractor which can translate our informational
handouts to any language which may be needed. This information should also be
available after the new census data is complete, at which time this issue will be discussed
again. We also have a staff member in the Water Quality Program that is proficient in
numerous languages, including Spanish, French and Italian.

Public Involvement and Participation (findings stated below provided by David Caldwell)

9. Finding(s): Town websites do not have a clear “how to volunteer” message, however we
do ask that they repost our educational messages that we post on our social channels.
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6
towns to request that this information be added to their websites. Ken Friday requested
the same from CMS and CPCC. On 8/20/20, staff verified that all Town websites have
been updated to ensure consistent wording and links to the CMSWS website. On
8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS and Vicki Saville with
CPCC making them aware that links from their websites needed to be restored to the
CMSWS. Jeff and Vicki are responsible for compliance with the Stormwater Permit for
their organizations.

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10. Finding(s): The Program would benefit significantly from the development and
implementation of written procedures for methods used to promote events and volunteer
opportunities as recommended by EPA.
Follow Up Action(s) Completed (Date): On 6/5/20, the SOPs for Public
Education/Outreach and Public Involvement were reviewed. Section 1.4 that is entitled
“Promotion” outlines the various methods used for promoting volunteer programs. These
documents are reviewed and updated at the beginning of every fiscal year in cooperation
with the City. Also, in June 2020 David Caldwell completed a Communication Plan that
is provided as Supporting Document #28. Staff was educated regarding this Plan that will
be implemented effective July 1, 2020. In addition, Section 3.6 was added to the
Stormwater Plan to describe the Communication Plan and its use.

Illicit Discharge Detection and Elimination (IDDE) (findings stated below provided by Ryan
Spidel)

None

Construction Site Runoff Controls (findings stated below provided by Corey Priddy)

11. Finding(s): The “Report A Problem” page of the website did not include a description of
erosion and sedimentation control problems.
Follow Up Action(s) Completed (Date): On May 15, 2020, the website administrator
was contacted, and the description was added.

12. Finding(s): The Director of the NCDEMLR is not notified within 10 days when the
permittee disapproves an erosion and sedimentation control plan in order to protect
riparian buffers along surface waters.
Follow Up Action(s) Completed (Date): Effective May 18, 2020, Mecklenburg County
will begin notifying the Director of NCDEMLR within 10 days of disapproval of an
erosion and sedimentation control plan in order to protect riparian buffers along surface
waters.

Post-Construction Site Runoff Controls (findings stated below provided by Rusty Rozzelle and
Don Ceccarelli)

13. Finding(s): The Design Standard for forebay stakes may need to be revised.
Follow Up Action(s) Completed (Date): On September 1, 2020, the design standards for
Wet Ponds, Sand Filters, and Wetland were updated to include clean-out stakes for
forebays and main ponds. Refer to website below:
https://www.mecknc.gov/LUESA/WaterandLandResources/LandDevelopment/Pages/LD
%20Manual%202100%20Series.aspx

14. Finding(s): A field needs to be added into the electronic Accela plan review application
currently under development that designates projects as low-density or high-density.
Follow Up Action(s) Completed: On May 27, 2020, a scope was added to the Accela
project to add the recommended field to the application.

Pollution Prevention and Good Housekeeping for Municipal Operations
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15. Finding(s): CMSWS needs to verify that pesticide licenses are valid.
Follow Up Action(s) Completed (Date): On May 15, 2020, the inspection form and
Stormwater Plan were revised to ensure that pesticide license number for either the co-
permittee’s employee or the contractor is obtained and that the number is verified as
being current through the NC Dept. of Agriculture website.

16. Finding(s): CMSWS needs to confirm compliance with permits, certifications, and other
measures for applicators.
Follow Up Action(s) Completed (Date): On May 19, 2020, it was decided that as part of
our municipal inspections of Phase II facilities we will continue to ask for a copy of
application records. These records will be reviewed by the inspector and compared to
previous years to determine if there have been significant increases in the quantities
applied in which case further investigations will be performed to determine if permit #
NCG560000 should be obtained. The application records, results of further investigations
and copies of permits issued will be maintained in the facility’s file. The Stormwater Plan
was revised to include this requirement.

Total Maximum Daily Loads (TMDLs) (findings stated below provided by Tim Besier)

17. Finding(s): Annual reports should be carefully reviewed prior to submittal as a few
grammatical and content-based errors were identified during the review of the FY2019
TMDL Annual Report as part of the audit process.
Follow Up Action(s) Completed (Date): On March 30, 2020, Rusty Rozzelle corrected
the errors in the TMDL report and saved it on the LAN as follows: G:\Water
Quality\WQ_Xfer\WQ\Phase II Permit\TMDLs\TMDL Annual Report FY2019 FINAL
SUBMITTAL Revised on 3-30-20. This revised version is included as Attachment 2 in
Supporting Document # 12. Future reports will be written by staff and reviewed by their
supervisor, which should reduce errors.

Site Visit Evaluation: Municipal Facility No. 1 (findings stated below provided by Richard
Farmer)

None

Site Visit Evaluation: MS4 Outfall No. 1 (findings stated below provided by Ryan Spidel)

18. Finding(s): During this inspection process we found 2 issues that need to be addressed
with the Collector iPhone Application. 1) The collector app needs to show the feature ID
number for the outfall. This attribute is probably hidden and can be turned on. 2) For the
Phase 2 inventory layer, there is no option to add a photo of the outfall once it has either
been inspected or created. Overall, Tyler did a good job with the inspection and was able
to accurately evaluate the inventory.
Follow Up Action(s) Completed (Date): On September 2, 2020, Ron Bruzzese (Meck
Co. GIS) completed the stormwater inventory map update. He combined all Phase II
inventory maps into a single map. In this process, he also fixed the problem with adding
photos to the attribute when it is inspected. On September 21, 2020, Ryan Spidel worked
with Ron Bruzzese to show an ID number with the inlets and outlets.
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Site Visit Evaluation: Construction Site No. 1 (findings stated below provided by Corey Priddy)

19. Finding(s): Staff are not obtaining requested data when asked, preferably prior to leaving
for the field when conditions are easier to obtain the data. The entire perimeter of a site
should be walked regardless of conditions, to make sure that sediment is not leaving the
site and all measures are functioning properly. A notepad should be kept on hand during
the walk to take any notes at the time items are noted in the field. Official inspection
reports (not emails) should be sent to the owner/contractor after inspecting the site.
Follow Up Action(s) Completion (Date): On 7/16/2020, Corey Priddy met with the
Erosion Control Staff and went over the Recommendation Items, noted above. Staff are
to immediately begin carrying a notepad and camera on all site inspections, and to begin
emailing a copy of the inspection report to the owner/contractor instead of just an email
or phone call describing what is needed. Also, it was pointed out that the entire site
perimeter should be walked every time to make certain that sediment is not leaving the
site.

Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 (findings stated
below provided by Don Ceccarelli)

20. Finding(s): Bonding Undisturbed Open Space should be considered as a standard item
on the Bond Estimate form to ensure compliance.
Follow Up Action(s) Completed (Date): On July 29, 2020, Don Ceccarelli met with Plan
Review / Bond staff and informed them that Bonding of Undisturbed Open Space that
required tree planting would be incorporated into the Bond estimate as part of the
landscaping line item.

21. Finding(s): Need to establish a process to address verification of BMP escrow funding
when required, which may include modifying the O&M agreement, consultation with
county attorney, etc. Along the same lines, need to address two situations: 1)Where the
HOA is taking over maintenance from the developer and the “escrow down payment” has
not been made, and 2) When the owner of the infrastructure bond wants to have his bond
released but the owner of the maintenance bond refuses to post the bond, which holds the
infrastructure bond owner hostage because the infrastructure bond cannot be released
until the maintenance bond is established.
Follow Up Action(s) Completed (Date): On August 3, 2020, a process was agreed to and
Don Ceccarelli changed the PCO19 and PCO#42 forms accordingly.

22. Finding(s): PCO refresher training is needed for BMP inspection staff. This training
should include:
• What to inspect for PCO compliance besides just the BMP (additional BUA,
disturbance of UOS, PC buffers, etc.).
• What documents can be used to find PC compliance data besides approved plans.
• How to address measurement of sediment levels in various BMPs.
• Addressing BMP maintenance funding review, if required.
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Follow Up Action(s) Completed (Date): On August 6, 2020, Don Ceccarelli provided
PCO refresher training, including the four (4) bulleted items from above, to Corey
Priddy, Jason Klingler, Heather Davis, Brian Sifford, and Chanell Hatch.

6.2 Permit Compliance Assessment

In the opinion of CMSWS staff, none of the above Findings would constitute a Permit violation.
However, it is believed that the Follow Up Actions completed as a result of these Findings will
result in significant improvements to the Phase II Program as we prepare for the State Audit in
2021.

Section 7: Conclusion & Process Forward

The 2020 Internal Audit is determined to be a success because it resulted in significant Findings
and the completion substantive Follow Up Actions contributing to the improved effectiveness
and efficiency of Phase II Program activities at achieving compliance with Permit requirements.
The Audit also resulted in six (6) additions/corrections to the 2021 Stormwater Plan that will be
submitted to the State in October 2020 along with the annual report. It is estimated that the 2020
Internal Audit involved a total of 282.5 staff hours at a cost of $30,053.28, which is very
reasonable when considering its benefits to the overall Program.

CMSWS previously performed Internal Audits of the Phase II Program for compliance with
Permit No. NCS000395 in 2010, 2014, and 2019. The State audited the Program in 2012. The
2020 Internal Audit represents the fifth audit of the Program in its 15-year history. The 2020
Internal Audit resulted in more Findings and Follow Up Actions than any of the previous Audits
and is probably the most comprehensive. These Audits were performed in addition to the
Program’s annual Storm Water Management Program Assessment that is provided to the State in
October of every year. It is anticipated that future Internal Audits will be performed every three
(3) years.

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Appendix A: Co-Permittee Responsibilities for Compliance with Phase Permit
Requirements
November 22, 2019

Provided below is a list of those activities that each co-permittee must complete to comply with
Permit requirements. According to the terms of the Permit, each co-permittee is responsible for
compliance within their respective jurisdiction.

1. Ensure educational materials are included in newsletters and/or other regular
communications by the co-permittee and that brochures are maintained in a location
available to the public as requested by Charlotte-Mecklenburg Storm Water Services
(CMSWS). Contact CMSWS if new educational materials are needed. Maintain a link
from the co-permittee web site to the Charlotte-Mecklenburg Storm Water Services web
site.
2. Receive and respond as necessary to reported problems with the storm sewer system
within the co-permittee’s jurisdiction.
3. Ensure compliance with erosion and sediment control requirements at co-permittee
construction sites.
4. Ensure that all co-permittee projects comply with post-construction ordinance
requirements, including transportation projects. Guidance for ensuring compliance by
transportation projects is provided at the following link:
http://charlottenc.gov/StormWater/Regulations/Documents/PostConstructionPolicyforPu
blicTransportationProjects.pdf).
5. Maintain and implement an Operation and Maintenance (O&M) program for
municipally-owned or maintained structural stormwater controls installed for compliance
with the 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. At a minimum, the O&M program shall
specify that annual inspections are to be performed and the routine maintenance that is to
be performed.
6. Perform annual inspections and complete routine maintenance at all municipally owned
or maintained structural stormwater controls as specified in the O&M plan. The
permittee shall document inspections and maintenance of all municipally owned or
maintained structural stormwater controls.
7. Ensure that co-permittee employees receive the training provided by CMSWS regarding
proper pollution prevention and good housekeeping practices at municipal facilities as
well as training on recognizing and reporting illicit discharges and improper waste
disposal. Keep records of employee training for a minimum of five (5) years.
8. Ensure issues identified by CMSWS in inspection reports for the co-permittee’s
municipal facilities and operations are addressed in a timely manner. Submit
documentation of completion to CMSWS.
9. Implement the co-permittee’s Storm Water Pollution Prevention Plan, including (but not
limited to):
a. Perform semi-annual inspections of material storage areas.
b. Perform annual outfall inspections during dry conditions.
c. Keep records of inspections for a minimum of five (5) years.
d. Follow procedures when spills occur.
e. Keep records of spills for a minimum of five (5) years.

12

10. Inform CMSWS if properties are purchased or sold so that an inventory of the co-
permittee’s municipal facilities subject to Permit requirements can be maintained.
11. Implement the following to reduce polluted storm water runoff from the municipally
owned streets, roads, and public parking lots:
a. Continue enforcement of existing litter ordinances.
b. Continue existing solid waste collection and recycling services.
c. Continue public education to encourage the proper disposal and recycling of
waste.
d. Clean parking lots on an as needed basis particularly after special events.
e. Continue providing trash receptacles at public parking lots and performing
scheduled trash pick-up.
f. Sweep co-permittee owned streets at a minimum of twice annually, including in
the spring and in the fall (except Huntersville sweeps 25%/year).
g. Maintain written records documenting the location and number of parking lots
and streets swept and the pounds of pollutants removed as well as costs for a
minimum of five (5) years. Make these reports available to CMSWS by July 31st
of every year.
h. Ensure that waste collected from street sweeping and parking lot cleaning is
properly disposed of.
12. Implement the following to reduce polluted storm water runoff from the municipally
owned storm sewer systems:
a. Continue catch basin and conveyance system cleaning in identified problem areas
for blockages and flooding.
b. Maintain records documenting the number of inlets, outlets, and pipes cleaned
and the pounds of pollutants removed as well as costs for a minimum of five (5)
years. Make these reports available to CMSWS by July 31st of every year.
c. Ensure that waste collected from storm sewer system cleaning is properly
disposed of.
d. Receive and respond to information provided by CMSWS regarding potential
maintenance issues.
e. Receive and respond to service requests from the public regarding storm drain
system maintenance issues.
13. Implement the following to ensure that municipal employees and contractors are
properly trained and all Permits, certifications, and other compliance measures for
pesticide applicators are followed:
a. Verify that employees and/or contractors that apply pesticides are properly
licensed and maintain copies of these licenses (update at least annually and
within 30 days of hire).
b. Comply with pesticide application thresholds described in Table 1 below. Each
co-permittee is responsible for maintaining a list of all locations treated with the
pesticides listed in this table and documenting the date and quantity of material
applied. To obtain guidance for compliance with Permit requirements, notify
Rusty Rozzelle with CMSWS at 980-314-3217 or at
[e-mail] when either or both of the following
conditions are met when applying the pesticides listed in Table 1:
• Co-permittee believes a treatment event may reasonably exceed an annual
applicable threshold quantity as described in the table below.
• Co-permittees discharges pesticide in response to a declared pest
emergency situation.

13

c. Comply with pesticide application limitations in the Goose Creek Watershed
specified in Table 2 below.
14. Implement the following to reduce polluted storm water runoff from vehicle and
equipment cleaning areas:
a. The preferred practice is for vehicle and equipment cleaning activities to occur
indoors or under cover with wash water discharged to the sanitary sewer system.
b. In situations where this practice is infeasible, the wash water must be collected,
pumped and contained for recycling or for transport and disposal into the
sanitary sewer system. These types of cleaning activities are typically performed
on a tarp and wash water is collected using a boom. A vacuum is then used to
pump the wash water into containers where it can be recycled or transported off-
site for disposal into the sanitary sewer system.
c. In situations where cleaning is performed in the vicinity of a storm drainage
collection system or drainage collection feature such a ditch or swale, the storm
drain must be covered or the drainage feature blocked during cleaning activities
and ponded water must be collected and removed for proper disposal or
recycling prior to the removal of the drain cover or blockage.
d. For rinsing operations that do not use high temperature water, detergents or other
cleaning agents, wash water can be discharged to a grassed area where it is
filtered into the soil and not allowed to flow to storm drains or surface waters.

Table 1: Pesticide Treatment Thresholds
Pesticide Use Annual Threshold
Mosquitoes and Other Flying Insect Pests 15,000 acres of treatment area (adulticide
applications only) (1)
Aquatic Weed and Algae Control - In
Water
1,000 acres of treatment area
Aquatic Weed and Algae Control - At
Water’s Edge
200 linear miles of treatment area at water’s
edge (2)
Aquatic Nuisance Animal Control - In
Water
200 acres of treatment area
Aquatic Nuisance Animal Control - At
Water’s Edge
200 linear miles of treatment area at water’s
edge (2)
Forest Canopy Pest Control 10,000 acres of treatment area
Intrusive Vegetation Control 500 linear miles (3)
(1) Multiple applications to the same area are added together only for mosquito and other flying
insect pest control.
(2) Applications that occur at the water’s edge in a ditch or canal are counted only once when
one or both sides are treated.
(3) Applications to both sides of a road are added together for the total miles.

Table 2: Pesticide Application Limitations in the Goose Creek Watershed
Pesticide Active Ingredient Code/Limitations
Azinphos-methyl (2)
Benomyl (1)
Captan (1)
Carbaryl (2)
Carbofuran (1)
Chlorpyrifos (3)

14

Pesticide Active Ingredient Code/Limitations
Diazinon (2)
Dicofol (2)
Dimethoate (2)
Endosulfan (2)
Esfenvalerate (1)
Ethion (2)
Ethoprop (1)
Fenamiphos (2)
Fonofos (2)
Malathion (2)
Methidathion (2)
Methomyl (1)
Mevinphos (2)
Naled (1)
Parathion (ethyl) (2)
Pendimethalin (2)
Permethrin (1)
Phorate (1)
Phosmet (1)
Phosphamidon (1)
Propiconazole (1)
Pyrethrins (2)
Terbufos (2)
Trichlorfon (2)
Code/Limitations:
(1) This pesticide shall not be applied within 20 yards from the edge of water for ground
applications and within 100 yards for aerial applications;
(2) This pesticide shall not be applied within 40 yards from the edge of water for ground
applications and within 200 yards for aerial applications;
(3) This pesticide shall not be applied within 100 yards from the edge of water for ground
applications and within one-fourth mile for aerial applications.

Appendix B: NCDEQ Phase II MS4 Audit Template (completed)

DRAFT PHASE II MS4 AUDIT TEMPLATE
FOR PERMITS ISSUED PRIOR TO 2019

Edit yellow highlighted items to be
specific to the MS4 being audited.

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT

NPDES PERMIT NO. NCS000395
Mecklenburg County, NORTH CAROLINA

Charlotte-Mecklenburg Storm Water Services
2145 Suttle Avenue
Charlotte, NC 28208

Audit Date: June 2020

Report Date: June 2020

North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date: May 2020 i

(This page intentionally left blank)
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date: May 2020 ii
TABLE OF CONTENTS
Audit Details .................................................................................................................................................. 1
Permittee Information .................................................................................................................................. 2
Supporting Documents ................................................................................................................................. 4
Program Implementation, Documentation & Assessment ........................................................................... 5
Public Education and Outreach ................................................................................................................... 10
Public Involvement and Participation ......................................................................................................... 16
Illicit Discharge Detection and Elimination (IDDE) ...................................................................................... 19
Construction Site Runoff Controls .............................................................................................................. 22
Post-Construction Site Runoff Controls ...................................................................................................... 25
Pollution Prevention and Good Housekeeping for Municipal Operations ................................................. 31
Total Maximum Daily Loads (TMDLs) ......................................................................................................... 35
Site Visit Evaluation: Municipal Facility No. 1 ............................................................................................. 40
Site Visit Evaluation: MS4 Outfall No. 1 ...................................................................................................... 42
Site Visit Evaluation: Construction Site No. 1 ............................................................................................. 44
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 ............................................ 47
APPENDIX A: SUPPORTING DOCUMENTS ................................................................................................... 50
APPENDIX B: PHOTOGRAPH LOG ................................................................................................................ 51

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.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date: May 2020 iii

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MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 1 of 51
Audit Details
Audit ID Number: NCS000395 County of Mecklenburg,
Charlotte-Mecklenburg Schools, Central Piedmont
Community College, and Towns of Cornelius, Davidson,
Huntersville, Matthews, Mint Hill, and Pineville
Audit Date(s): April through September 2020

Minimum Control Measures Evaluated:
☒ Program Implementation, Documentation & Assessment
☒ Public Education & Outreach
☒ Public Involvement & Participation
☒ Illicit Discharge Detection & Elimination
☒ Construction Site Runoff Controls – No delegated Sediment and Erosion Control Program
☒ Construction Site Runoff Controls – Delegated Sediment and Erosion Control Program
☒ Post-Construction Site Runoff Controls
☒ Pollution Prevention and Good Housekeeping for Municipal Operations
☒ Total Maximum Daily Loads (TMDLs)

Field Site Visits:
☒ Municipal Facilities. Number visited: 1
☒ MS4 Outfalls. Number visited: 1
☒ Construction Sites. Number visited: 1
☒ Post-Construction Stormwater Runoff Controls. Number visited: 1
☐ Other: ________________________________. Number visited: Choose an item.
☐ Other: ________________________________. Number visited: Choose an item.

Inspector(s) Conducting Audit
Name, Title Organization
Rusty Rozzelle, Environmental Manager (Supporting
Documents & Program Implementation, Documentation &
Assessment)
Mecklenburg County Storm Water Services
David Caldwell, Environmental Supervisor (Public Education
and Outreach & Public Involvement and Participation Mecklenburg County Storm Water Services
Ryan Spidel, Environmental Supervisor (Illicit Discharge
Detection and Elimination (IDDE)) Mecklenburg County Storm Water Services
Corey Priddy, Environmental Supervisor (Construction Site
Runoff Controls) Mecklenburg County Storm Water Services
Don Ceccarelli, Senior Project Manager (Post-Construction
Site Runoff Controls) Mecklenburg County Storm Water Services
Richard Farmer, Environmental Supervisor (Pollution
Prevention and Good Housekeeping for Municipal
Operations)
Mecklenburg County Storm Water Services
Olivia Edwards, Environmental Supervisor (Total Maximum
Daily Loads (TMDLs)) Mecklenburg County Storm Water Services
Audit Report Author:

Signature__________________________________________
Date:
June 2020
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 2 of 51
Permittee Information
MS4 Permittee Name:
Mecklenburg County
Permit Effective Date:
February 17, 2017
Permit Expiration Date:
February 16, 2022
City, State, ZIP:
2145 Suttle Ave. Charlotte, NC 20208
Date of Last MS4 Inspection/Audit:
November 26 and 27, 2012 (NCDEQ);
and January 2019 (Internal)
Co-permittee(s), if applicable:
County of Mecklenburg, Charlotte-Mecklenburg Schools, Central Piedmont Community College, and Towns of Cornelius,
Davidson, Huntersville, Matthews, Mint Hill, and Pineville
Permit Owner of Record:
Charlotte-Mecklenburg County Storm Water Services
Primary MS4 Representatives Participating in Audit
Name, Title Organization
Rusty Rozzelle, Environmental Manager Mecklenburg County Storm Water Services
David Caldwell, Environmental Supervisor Mecklenburg County Storm Water Services
Ryan Spidel, Environmental Supervisor Mecklenburg County Storm Water Services
Corey Priddy, Environmental Supervisor Mecklenburg County Storm Water Services
Don Ceccarelli, Permitting & Compliance Senior
Program Manager Mecklenburg County Storm Water Services
Richard Farmer, Environmental Supervisor Mecklenburg County Storm Water Services
Olivia Edwards, Environmental Supervisor Mecklenburg County Storm Water Services
MS4 Receiving Waters
Waterbody Classification Impairments (Category)
Caldwell Station WS-IV No Data
Four Mile Creek C No Data
Gar Creek WS-IV Fish Tissue Mercury (4t)
Irvins Creek C No Data
Lake Norman (Catawba River) WS-IV; CA Fish Tissue Mercury (4t); PCB Fish Tissue (5)
Little Sugar Creek C Benthos (4s); Copper (5); Fecal Coliform (4t); Fish
Community (4s); Fish Tissue Mercury (4t)
Long Creek C Fish Tissue Mercury (4t)
McAlpine Creek C Benthos (5); Fecal Coliform (4t); Fish Tissue
Mercury (4t)
McCullough Branch C Benthos (5); Fish Tissue Mercury (4t)
McDowell Creek C Fish Community (4b); Fish Tissue Mercury (4t)
Mountain Island Lake (Catawba River) WS-IV; CA Fish Tissue Mercury (4t); Fish Tissue Mercury (4t)
Sugar Creek C Benthos (4s); Copper (5); Fecal Coliform (4t); Fish
Community (4s); Fish Tissue Mercury (4t)
Torrence Creek WS-IV No Data
Cane Creek C No Data
Clarks Creek C Benthos (4s); Fish Tissue Mercury (4t)
Clear Creek C Fecal Coliform (4t); Fish Tissue Mercury (4t)
Duck Creek C Benthos (4b); Fish Tissue Mercury (4t)
Ferreltown Creek C No Data
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 3 of 51
MS4 Receiving Waters
Waterbody Classification Impairments (Category)
Goose Creek C Fish Tissue Mercury (4t)
Long Branch C No Data
N. Fork Crooked Creek C Benthos (5); Fish Tissue Mercury (4t)
N. Prong Clarke Creek C Fish Tissue Mercury (4t)
Ramah Creek C Fish Tissue Mercury (4t)
Rocky River C Benthos (5); Fecal Coliform (4t); Fish Tissue
Mercury (4t)
S. Prong Clarke Creek C Fish Tissue Mercury (4t)
S. Prong W. Branch Rocky River C Fish Tissue Mercury (4t)
Sherman Branch C No Data
Stevens Creek C No Data
W. Branch Rocky River C Fish Tissue Mercury (4t)
Wiley Branch C No Data
Data for the table above was obtained from the 2018 NC Integrated Report at the following link:
https://files.nc.gov/ncdeq/Water%20Quality/Planning/TMDL/303d/2018/2018IR072519.pdf.

The following are descriptions of the categories of impairment indicated in the table above.
• CATEGORY 4B ASSESSMENTS are assigned when a parameter exceeded criteria and there is an
enforceable management strategy in place for that parameter. Most of these were Category 5
assessments prior to management strategy development. A TMDL is not required for
parameters assessed in Category 4b, however the state is required to report on implementation
activities every 2 years.
• CATEGORY 4S ASSESSMENTS were assigned when biological integrity (fish or benthic community
samples) were exceeding criteria but there was another aquatic life parameter with a Category
4t or Category 5 assessment. TMDLs will be developed for the Category 5 assessments.
• CATEGORY 4T ASSESSMENTS were assigned when a parameter exceeded criteria and there is an
approved TMDL in place for that parameter. Prior to TMDL development these were Category 5
assessments. Examples would be nutrient TMDLs in category 4t and chlorophyll a in category 4i.
Prior to TMDL development these were Category 5 assessments.
• CATEGORY 5 ASSESSMENTS are assigned when a parameter exceeded criteria and requires
development of a TMDL. Category 5 assessments are the 303(d) list. States are required to
submit Category 5 assessments to EPA on April 1st of even numbered years. EPA must then
approve the Category 5 assessments. A single water body could have multiple assessments for
different parameters in multiple categories but only the Category 5 assessments are submitted
to EPA for approval. The 2018 303(d) Listing and Delisting Methodology can be found here:
https://files.nc.gov/ncdeq/Water%20Quality/Planning/TMDL/303d/2018/2018%20Listing%20M
ethodology_ApprovedMarch2018.pdf.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 4 of 51
Supporting Documents
The following documents have been saved in a folder on the LAN as follows: G:\Water Quality\WQ_Xfer\WQ\Phase
II Permit\Phase II Audits\2020 Audit\Supporting Document.
Item
Number Document Title When Provided
(Prior to/During/After)
1 Stormwater Plan (FY2020 Version) During
2 FY2019 Internal Audit Report During
3 IDDE Manual During
4 BMP Inspection Manual Version 8 During
5 Post-Construction Ordinance Administrative Manual During
6 Charlotte-Mecklenburg BMP Design Manual During
7 Post-Construction Ordinances for the 6 Towns and County During
8 TMDL Compliance Plan (part of the Stormwater Plan) During
9 Surface Water Pollution Control Ordinances for Mecklenburg County and the
Towns of Davidson and Matthews During
10
Resolutions Extending Jurisdiction of Mecklenburg County Surface Water
Pollution Control Ordinance Within the Town Limits for Cornelius, Huntersville,
Mint Hill and Pineville
During
11 Storm Water Interlocal Agreements for all Co-Permittees During
12 FY2019 Storm Water Management Program Assessment Report During
13 FY2020 Work Plan During
14 FY2020 Work Plan Implementation Guidelines During
15 FY2020 Water Quality Program Funding Strategy During
16 Payment Confirmation for State’s Phase II Permit Fee During
17 Designated Water Quality Program Improvements During
18 Email to Jeanette Powell with Updated Stormwater Plan Attached (11-21-19) During
19 IDDE Manual During
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 5 of 51

Program Implementation, Documentation & Assessment
Staff Interviewed:
(Name, Title, Role)
Rusty Rozzelle, Environmental Manager
Phase II Program Administrator
Permit Citation Program Requirement Status Supporting
Doc No.
II.A.1
Staffing and
Funding
The permittee maintained adequate funding and staffing to implement and manage
the provisions of the Stormwater Plan and meet all requirements of the permit. Yes 15
The Stormwater Plan identifies a specific position(s) responsible for the overall
coordination, implementation, and revision to the Plan. Yes 1 (page
112)
Responsibilities for all components of the Stormwater Plan are documented and
position(s) assignments provided. Yes
1 (pages
118
through
128)
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see stormwater e-payments on DEMLR MS4 web page). Yes 16
20 Erosion Control Ordinances for Mecklenburg County and the Towns of Davidson
and Mint Hill During
21 Mecklenburg County Land Development Fees During
22 Erosion Control Plan Approval Letter During
23 SCMs Maintained by Phase II Entities from Cityworks on 4-7-2020 During
24 Co-Permittee Responsibilities for Complying With Phase II Permit Requirements
11-22-19 During
25 FY20 Public Education SOP During
26 FY20 Public Involvement SOP During
27 Table 8 Targeted Pollutants from Stormwater Plan During
28 Communication Plan During
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 6 of 51
Program Implementation, Documentation & Assessment
Comments (Briefly describe funding mechanism, number of staff, etc.)
Storm Water fee revenue received by the Towns and County provides funding for the Phase II Program as well as revenue from th e
general funds for Charlotte-Mecklenburg Schools and Central Piedmont Community College. The Program consists of a total of 30
staff. A total of 6,801.36 staff hours are estimated for the implementation of the FY2020 Phase II Program. The details of how
costs for the implementation of the Phase II Program are spread among all co -permittees is described in the FY2020 Water Quality
Funding Strategy (see Supporting Document Number 15).
II.A.2 Stormwater
Plan
Implementation
and Evaluation
The permittee evaluated the performance and effectiveness of the program
components at least annually. Yes 12
If yes, the permittee used the results of the evaluation to modify the program
components as necessary to accomplish the intent of the Stormwater Program. Yes 17
Did the permitted MS4 discharges cause or contribute to non-attainment of an
applicable water quality standard? No ---
If yes, did the permittee expand or better tailor its BMPs accordingly to address
the non-attainment?
Not
Applicable ---
Comments

II.A.3
Keeping the
Stormwater Plan
Up to Date
The permittee kept the Stormwater Plan up to date. Yes 1
The permittee notified DEMLR of any updates to the Stormwater Plan. Yes 18
Comments (Indicate the date of latest Stormwater Plan and describe the nature of any updates, if applicable).
The Stormwater Plan is updated annually in October to coincide with the completion of the annual report. On November 21, 2019 ,
an email was sent to Jeanette Powell of NCWEQ with the revised Stormwater Plan attached (see Supporting Document #18)
II.A.4 Availability
of the Stormwater
Plan
The permittee kept an up-to-date version of its Stormwater Plan available to the
Division and the public online. Yes 1 and 18
The online materials included ordinances, or other regulatory mechanisms, or a list
identifying the ordinances, or other regulatory mechanisms, providing the legal
authority necessary to implement and enforce the requirements of the permit.
Yes 9
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 7 of 51
Program Implementation, Documentation & Assessment
Comments (Note what materials are available online)
The following documents are available online: FY2020 Stormwater Quality Management Program Plan; FY2019 Storm Water
Management Program Assessment Report; Post-Construction Ordinances and Administrative Manual applicable to the Phase II
jurisdictions; Surface Water Pollution Control Ordinances applicable to the Phase II jurisdictions; various training and educ ational
materials.
Finding(s): The Stormwater Plan, Permit and annual report that were on the website were outdated.
Follow Up Action(s) Completed (Date): On May 18, 2020, Rusty Rozzelle contacted the web administrator, and the updated
documents were placed on the website.
II.A.3 & II.A.5
Stormwater Plan
Modifications
Did DEMLR require a modification to the Stormwater Plan? No ---
If yes, did the permittee complete the modifications in accordance with the
established deadline?
Not
Applicable ---
Comments (Note date of DEMLR notification, modifications required, and date modifications were completed, as applicable)

II.A.6 Sharing
Responsibility Are any control measures implemented by an entity other than the permittee? No ---
If yes, is there a written agreement in place? Not
Applicable ---
Comments (List the specific control measures implemented by others that do not have adequate written agreements, if
applicable)

II.A.7
Written
Procedures
The permittee maintained written procedures for implementing the six minimum
control measures. Yes 13
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures. Yes 13
Comments (List the specific minimum measures that do not have adequate written procedures, if applicable)
Every fiscal year a Work Plan is developed and approved by all co -permittees that describes the specific action steps, schedules,
resources and responsibilities for implementing the six minimum measures. The Work Plan also includes costs and budgets for each
co-permittee. The database that serves as the platform for the Work Plan is referred to as Time Pro.
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 ---
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 8 of 51
Program Implementation, Documentation & Assessment
Comments (List the specific program components that do not have adequate documentation on file and why, if applicable)
All program components have proper documentation using the following methodology:
8. The Time Pro database maintains all Work Plans describing CMSWS’s compliance activities.
9. The CityWorks database maintains documentation of the completion of these compliance activities including, but not
limited to, inspections, maintenance activities, educational programs, volunteer programs, implementation of BMPs,
enforcement actions etc.
10. The LAN folder at \\hmcfs01\attachments\WQ serves as the backup destination for CityWorks documentation
generated by the Water Quality Program.
11. The LAN folder at G:\Water Quality\WQ_Xfer\WQ\Phase II Permit maintains annual reports, co-permittee
information, permit applications, permit audits, Phase II Permits, presentations , State correspondence, Storm Water
Quality Management Program Plans, TMDL documentation, and other information relating to the Phase II Permit.
12. The Environmental Data Management System (EDMS) serves as the reporting mechanism for data relating to services
requests and notices of violation, including repeat offenders as required by our Permit.
13. The Emerald System maintains documentation of stormwater drainage service requests.
14. The Electronic Plan Review (EPM) system maintains documentation of plan and plat reviews for compliance with
Erosion Control and Post-Construction Programs.
15. Co-permittees are responsible for maintaining documentation for compliance activities that are their responsibility as
described in Supporting Document # 24.
Finding(s): The Stormwater Plan does not include a description of the methodology used to insure proper documentation of
Permit compliance activities.
Follow Up Action(s) Needed: Rusty Rozzelle to include a description in the Stormwater Plan of the documentation process for
Permit compliance activities.
Follow Up Action(s) Completed (Date): On June 18, 2020, Rusty Rozzelle added a description of the documentation process for
Permit compliance activities in Section 10.2 of the FY2021 version of the Stormwater Plan.
III.B
Annual Report
Submittal

The permittee submitted annual reports to the Department within twelve months
from the effective date of the permit (See Section III.B. for the annual reporting
period specific to this MS4).
Yes 12
The permittee submitted subsequent annual reports every twelve months from the
scheduled date of the first annual report submittal. Yes ---
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee’s Stormwater Plan, including, but not limited the following:
1. A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
of each major component of the Stormwater Plan for the past year and
schedules and plans for the year following each report.
Yes 12
2. An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater
Plan (results, effectiveness, implementation schedule, etc.).
Yes 17
3. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
Plan.
Yes 17
4. A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
Stormwater Plan.
Yes 12
5. An assessment of compliance with the permit, information on the
establishment of appropriate legal authorities, inspections, and enforcement
actions.
Yes 12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 9 of 51
Program Implementation, Documentation & Assessment
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
According to the schedule set by NCDEQ, annual reports are to be submitted by October 31st of every year. No deficiencies were
found in the reports. They are very thorough.

IV.B
Annual Reporting The Annual Reports document the following:
1. A summary of past year activities, including where applicable, specific
quantities achieved and summaries of enforcement actions. Yes 12
2. A description of the effectiveness of each program component. Yes 12
3. Planned activities and changes for the next reporting period, for each
program component or activity. Yes 12
4. Fiscal analysis. Yes 12
Comments (Note dates that annual reports cover under current permit and generally describe report deficiencies, if any)
Annual reports for the past 15 years of Mecklenburg County’s Phase II Permit are available on the LAN as follows: G:\Water
Quality\WQ_Xfer\WQ\Phase II Permit\Annual Reports.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 10 of 51
Public Education and Outreach
Staff Interviewed:
(Name, Title, Role)
Review completed by David Caldwell, Environmental Supervisor over Public Education & Involvement .
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a
Goals and
Objectives
The permittee defined goals and objectives of the Local Public Education and
Outreach Program based on community wide issues. Yes 1 &12
Comments (Generally describe process for establishing goals/objectives)
CMSWS’s establishes its goals and objectives for its Public Education and Outreach Program, which are evaluated and updated
annually as necessary, based on the actions necessary to effectively address the targeted pollutants and pollutant sources id entified
in Table 8.

II.B.2.b
Target Pollutants
The permittee maintained a description of the target pollutants and/or stressors and
likely sources. Yes 1 &12
Comments (List target pollutants, note any that are missing or not appropriate)
Bacteria, turbidity, phosphorus, nitrogen, organics, surfactants, hydrocarbons and chemicals, pH and toxic compounds.

II.B.2.c
Target Audiences
The permittee identified, assessed annually and updated the description of the target
audiences likely to have significant storm water impacts and why they were selected. Yes 1 &12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 11 of 51
Public Education and Outreach
Comments (Describe any changes made, if applicable)
They are assessed annually through annual updates to the Stormwater Plan. Municipal was added as a targeted audience in the
FY20 Stormwater Plan. It was not included in the FY19 plan. There was no explanation as to why there was a change.
Finding(s): Our target audiences are very broad. Wondering if they are expected it to b e more specific. For example, targeting
renters in apartments due to grease/overflows, targeting restaurants due to grease/dumpster housekeeping issues, targeting ga s
stations for overflow, petroleum spills, targeting people that live in Goose Watershed (fecal issues), etc.
Follow Up Action(s) Needed: David Caldwell will review the DEQ and EPA websites for guidance and determine if specific target
audiences are required. Indicate below the specific actions completed for compliance, including the date(s) these actions were
completed.
Follow Up Action(s) Completed (Date): On 6/5/20, David Caldwell reviewed the DEQ and EPA websites and determined that the
target audiences identified are sufficient. The Stormwater Plan includes a section explaining our Targeted Outreach program
which includes specific targeted audiences within the general categories. An example of a specific targeted outreach mailer w as
added as Figure 5 to the 2021 version of the Stormwater Plan. The Cityworks Administrator was contacted and Municipal and
Institutional categories were added to the Educational Distribution dropdown for Activity Reports so that our targeted education
material distribution can be tracked effectively. David Caldwell informed staff to document the distribution of targeted
educational material in Cityworks. Results will be provided in annual reports.
II.B.2.d Residential
and Industrial/
Commercial Issues
The permittee described issues, such as pollutants, the likely sources of those
pollutants, potential impacts, and the physical attributes of stormwater runoff in
their education/outreach program.
Yes 1 &12
Comments (Generally describe the residential/industrial/commercial issues addressed)
Finding(s): Table 8 in section 2.8 of the Stormwater Plan provides pollutant sources but I do not see potential impacts or physical
attributes of stormwater runoff mentioned here, but our program includes Environmental Notices available for multiple
pollutant sources and these handouts do address potential impacts of pollutants to our surface waters. There are 2 separate
files for these environmental notices. We need to clean up these directories and get rid of the old versions.
Follow Up Action(s) Needed: David Caldwell will update Table 8 in Section 2.8 of the 2021 version of the Stormwater Plan to
include potential impacts, and the physical attributes of stormwater runoff. This updated table will be included in the
Supporting Documents for this audit document. He will also clean up directories and make other changes as necessary to
address all potential deficiencies. Indicate below the specific actions completed for compliance, including the date(s) these
actions were completed.
Follow Up Action(s) Completed (Date): On 6/5/20, David Caldwell updated Table 8 in Section 2.8 of the 2021 version of the
Stormwater Plan to include potential pollutant impacts and physical attributes of stormwater (see Supporting Document #27).
Litter was also added as a targeted pollutant. The Environmental Notice files on the LAN were reviewed and organized. Several
notices were updated. The Environmental Notices can be found on the LAN at G:\Water Quality\WQ_Xfer\WQ\Educational
Handouts.
II.B.2.e
Informational
Web Site
The permittee promoted and maintained an internet web site designed to convey the
program’s message. Yes 1 &12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 12 of 51
Public Education and Outreach
Comments (list web page address and general contents, or attach screen shot of landing page)
https://charlottenc.gov/stormwater/Pages/default.aspx
https://www.ci.davidson.nc.us/232/Public-Works link to Charmeck STW website
https://www.cornelius.org/206/Public-Works link to Charmeck STW website
https://www.huntersville.org/163/Engineering-Public-Works link to Charmeck STW website
http://www.pinevillenc.gov/Departments/PublicWorks/tabid/129/Default.aspx link to Charmeck STW website
https://www.matthewsnc.gov/pview.aspx?id=20745&catid=567 link to Charmeck STW website
https://www.minthill.com/public_works.php?Public-Works-Department-Stormwater-4 Site mentions CMSWS but no
link to CMSWS website exists.
https://www.cms.k12.nc.us/cmsdepartments/construction/buildingservices/ES/Pages/ENVIRONMENTAL%20STEWARD
SHIP%20POLICY.aspx link to Charmeck STW website
https://www.cpcc.edu/ Cannot locate any link to CMSWS website. Ken noted this in Oct. 19 and is working to have it
reestablished.
Finding(s): The Mint Hill and CPCC websites do not contain a link to the CMSWS website. Also, there should be some information
provided with every link that indicates its purpose as follows: “To obtain information regarding activities undertaken to pro tect
and restore water quality in our storm sewer systems, creeks and lakes, including volunteer opportunities.”
Follow Up Action(s) Needed: David Caldwell will work with Amy Plummer and the Towns, CPCC and CMS as necessary to ensure
the websites are updated sufficiently to ensure full compliance. Indicate below the specific actions completed for compliance,
including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6 towns to request that the above wording and
links be established on their websites. Ken Friday contacted CMS and CPCC and made the same request.
8/20/20 – All Town websites have been updated to ensure consistent wording and links to the CMSWS website. Links for all
websites are as follows:
Town of Davidson
https://www.ci.davidson.nc.us/232/Public-Works
Town of Cornelius
https://www.cornelius.org/206/Public-Works
Town of Huntersville
https://www.huntersville.org/267/Stormwater -Maintenance
Town of Pineville
http://www.pinevillenc.gov/Departments/PublicWorks/tabid/129/Default.aspx
Town of Mint Hill
https://www.minthill.com/public_works.php?Public -Works-Department-Stormwater-4
Town of Matthews
https://www.matthewsnc.gov/pview.aspx?id=20745&catid=567

On 8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS and Vicki Saville with CPCC making them aware that links
from their websites needed to be restored to the CMSWS. Jeff and Vicki are responsible for compliance with the Stormwater
Permit for their organizations. CMS was restored as flows:
https://www.cms.k12.nc.us/cmsdepartments/construction/buildingservices/ES/Pages/Stormwater-Permit-
Information.aspx.
II.B.2.f
Public Education
Materials
The permittee distributed stormwater educational material to appropriate target
groups. Yes 1 &12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 13 of 51
Public Education and Outreach
Comments (List distributed materials and quantity, message, distribution mechanism, target audience for each if not included in
program documentation/annual reporting)
Residential - We have multiple handouts available for residents for numerous targeted pollutants such as poop the scoop,
leaves/grass clipping, oil dripping, etc. These are often handed out at public events and given out du ring SR and sometime mass
mailings in problem areas. We created and provided a leaf disposal mailer for Matthews and they were going to mail it this fa ll. Not
sure about quantifying this. Can a report be run in Cityworks? Also, residential education for s ewer overflows is completed by CW
and not us.
Commercial - Car maintenance posters distributed to auto body shops (Ken) last year. CW does grease education. Multi -family
workshop/program provides materials for fecal target pollutant. Phase II area inclu ded? Usually attend Green Industry Workshop
in Monroe annually and give out materials. Mailing completed to 6 breweries in towns regarding spent grain disposal. CMCSI
workshop for contractors geared towards erosion control and buffer protection. Mobile washing information given out but this was
in Phase I. We have numerous business BMP handouts for commercial.
Institutional - For several years had pesticide/herb. workshop that was well attended by municipal employees and institutional
staff. Did not have this past year. Some materials were available for pick up. Ken provides educational handouts to CMS and CPCC.
Municipal - Auto/maintenance posters provided to all municipal shops several years ago. We usually do not provide materials
during our training. Some are self-trainings and others are in person trainings.
Finding(s): We have reached all targeted audiences in some manner but not always with “material.”
Follow Up Action(s) Needed: David Caldwell will work his staff to ensure the completion of the actions necessary to ensure full
compliance. Indicate below the specific actions completed for compliance, including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): In July 2020, David Caldwell worked with his staff to ensure that all the identified target
audiences were effectively reached in compliance with Permit requirements. Table 8 of the Stormwater Plan describes the
various Programs used to reach target audiences for the different targeted pollution sources. Section 3 describes the ways
stormwater education is provided to the target groups. Cityworks has a field to track educational material provided to the
targeted audiences and Section 3.4.6 describes the Targeted Outreach program which targets specific groups within the
audiences. Targeted groups are provided educational material and messaging when appropriate. During events / presentations,
educational materials are distributed and tracked in the Events/Presentations spreadsheet on the One Drive Umbrella Team
shared file directory.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 14 of 51
Public Education and Outreach
II.B.2.g
Hotline/Help Line
The permittee promoted and maintained a stormwater hotline/helpline for the
purpose of public education and outreach. Yes 1 &12
Comments (Note hotline contact information and method(s) for advertising it)
We promote report pollution to 311 multiple ways, social media channels, UBIs, website, TV ads. We are also member of RSPC
which has an ad campaign for reporting pollution. One area of improvement I found was that some town websites do not have a
clear “where to report pollution” message on their website. We had a “That’s Pollution” campaign on social channels which foc used
on showing pictures of different types of pollution and asking them to report.
Finding(s): Some town websites do not noticeably promote the hotline for reporting.
Follow Up Action(s) Needed: David Caldwell will work his staff to ensure the completion of the actions necessary to ensure full
compliance. Indicate below the specific actions completed for compliance, including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6 towns and requested that this information be
added to their websites. Ken Friday contacted CMS and CPCC and made the same request.
8/20/20 – All Town websites have been updated to ensure consistent wording and links to the CMSWS website. Links for all
websites are as follows:
Town of Davidson
https://www.ci.davidson.nc.us/232/Public-Works
Town of Cornelius
https://www.cornelius.org/206/Public-Works
Town of Huntersville
https://www.huntersville.org/267/Stormwater -Maintenance
Town of Pineville
http://www.pinevillenc.gov/Departments/PublicWorks/tabid/129/Default.aspx
Town of Mint Hill
https://www.minthill.com/public_works.php?Public -Works-Department-Stormwater-4
Town of Matthews
https://www.matthewsnc.gov/pview.aspx?id=20745&catid=567

On 8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS and Vicki Saville with CPCC making them aware that links
from their websites needed to be restored to the CMSWS. Jeff and V icki are responsible for compliance with the Stormwater
Permit for their organizations. CMS was restored as follows:
https://www.cms.k12.nc.us/cmsdepartments/construction/buildingservices/ES/Pages/Stormwater-Permit-
Information.aspx.
II.B.2.h
Public Education
and Outreach
Program

The permittee’s outreach program, including those elements implemented locally or
through a cooperative agreement, included a combination of approaches designed to
reach the target audiences.
Yes 1 &12
For each media, event or activity, including those elements implemented locally or
through a cooperative agreement the permittee estimated and recorded the extent
of exposure.
Yes 1 &12
Comments (Generally describe approaches, extent of exposure. Note any cooperating entities, agreements and scope of services,
or reference comments in Section II.A.6. above.)
Media strategy completed yearly with TV, social, radio, newspaper. This is found in One Drive folder. Reaches are provided in final
reports. Spreadsheets in OneDrive folder provide events and presentations and indicated number reached. School presentations
folder also provides each school reached and number reached. Our outreach program includes different approaches such as
material/handouts, direct mailings, posters, in person interactions at events and presentations, paid media through TV, social,
radio, newspaper, banners. We also have wrapped vehicle messages and a mascot which is used at multiple events to help
promote our messages. In addition to CMSWS outreach program we are also members of the Regional Stormwater Partnership of
the Carolinas which includes regional advertising for report pollution messaging.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 15 of 51
Public Education and Outreach
Additional
Comments:
Finding(s):
These are some areas of improvement we may want to consider based on a review of EPA
recommendations:
5. Track pollutant locations and target education to those areas vs. the entire community (i.e. increase and
document efforts in “hotspot” locations for effectiveness)?
6. Maintain a description of the target audiences and why they were selected, including a description of
the types of ethnic and economic groups engaged?
7. Prioritize watersheds or neighborhoods for outreach?
8. Evaluate languages spoken throughout communities?
Follow Up Action(s) Needed: David Caldwell will work with his staff to incorporate these suggested areas
of improvement into our Phase II Program by first incorporating them into the DRAFT FY2021 version of the
Stormwater Plan located here: G:\Water Quality\WQ_Xfer\WQ\Phase II Permit\Storm Water Management
Plan\FY21 DRAFTS. Secondly, David will make changes to the FY2021 Phase II Work Plan to incorporate
these improvements into the program next FY. Leverage the County’s Equity and Inclusion initiative, where
beneficial. Indicate below the specific actions completed for compliance, including the date(s) these actions
were completed.
Follow Up Action(s) Completed (Date): On 6/5/20, Section 3.4.6 of the Stormwater Plan was reviewed to
ensure compliance with targeted audience requirements. Cityworks is used to track educational material
distributed in the corresponding target areas. Section 3.4.6 describes the hotspot targeted audience
educational effort, and this was determined to be adequate for Permit comp liance. Cityworks will be used
to track the amount of educational material distributed and the location of the distribution. Descriptions
of targeted audiences are found in section 2.9 of the Stormwater Plan and these were determined to be
adequate for Permit compliance. Ethnic and economic information is currently not available for the
education /outreach program although we do have a form requesting ethnic information which is handed
out at workshops. Up to date information may be available after the new census data is available, at which
time we will evaluate this topic again. A new section 3.5 was added to the Stormwater Plan to indicate this.
Watersheds are currently prioritized for outreach sometimes based upon specific issues such as TMDLs or a
specific pollutant of concern (i.e. Reedy Creek for bacteria, etc.). Currently, prioritization for public
education usually occurs based upon the targeted pollution concerns as described in Section 3.4.6 of the
Stormwater Plan. For example, we are currently partners with the Regional Stormwater Partnership of the
Carolinas and Johnson C Smith University on a WRRI grant which involves improving public
education/outreach and public involvement in 3 underserved communities in west Charlotte. This has
been an area identified for needing additional outreach and involvement and plans are underway to
determine ways to engage the citizens in these communities. Language information is not available for
specific areas of Mecklenburg county. We do have numerous BMP educational flyers printed in various
languages, and we have access to a language services contractor which can translate our informational
handouts to any language which may be needed. This information should also be available after the new
census data is complete, at which time this issue will be discussed again. We also have a staff member in
the Water Quality Program that is proficient in numerous languages, including Sp anish, French and Italian.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 16 of 51
Public Involvement and Participation
Staff Interviewed:
(Name, Title, Role)
Review completed by David Caldwell, Environmental Supervisor over Public Education & Involvement ..
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a Volunteer
Community
Involvement
Program
The permittee included and promoted volunteer opportunities designed to promote
ongoing citizen participation. Yes 1 &12
Comments (Note opportunities promoted and date(s) of volunteer events)
May 30,19 – BSC event (have 2 sites in Phase II areas)
AAS- 499 volunteers in FY19 in Phase II
SDM – 279 drains marked in 4 towns
VM – 2 VM sites in towns
Creek ReLeaf – Huntersville / Henderson Park
SDM Rally – Pineville / 46 volunteers in 9/19
These events were all promoted on our social media accounts and on website. BSC is promoted on TV, radio and some paper ads.
II.C.2.b
Mechanism for
Public
Involvement
The permittee provided and promoted a mechanism for public involvement that
provides for input on stormwater issues and the stormwater program. Yes 1 &12
Comments (Note mechanism(s) for input and how promoted)
There is a presentation to SWAC on Phase II permit activities in the third quarter of each fiscal year as part of County Storm Water’s
budget presentation. Public comment is called for at the end of these presentations. The meetings are promoted in the “Upcomi ng
Events” section on the front page of our website. There is also a random public opinion survey completed each year to gauge public
opinion of our programs.
II.C.2.c
Hotline/Help Line
The permittee promoted and maintained a hotline/helpline for the purpose of public
involvement and participation. Yes 1 &12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 17 of 51
Public Involvement and Participation
Comments (Note hotline contact information and how it is promoted)
We promote Volunteer Opportunities to 311 multiple ways, social media channels, UBIs, website, TV ads. Volunteer messages can
be found on our UBIs in the OneDrive City of Charlotte Sharepoint site, the CMSWS website (banners), social media messages which
can be found in our monthly Sprout account posts summaries. RSPC site also promotes reporting on its website and TV ads.
Finding(s): Town websites do not have a clear “how to volunteer” message, however we do ask that they repost our
educational messages that we post on our social channels.
Follow Up Action(s) Needed: David Caldwell will work his staff to ensure the completion of the actions necessary to ensure full
compliance. Indicate below the specific actions completed for compliance, including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): In June 2020, Deania Russo contacted all 6 towns to request that this information be
added to their websites. Ken Friday requested the same from CMS and CPCC.
8/20/20 – All Town websites have been updated to ensure consistent wording and links to the CMSWS website. Links for all
websites are as follows:
Town of Davidson
https://www.ci.davidson.nc.us/232/Public-Works
Town of Cornelius
https://www.cornelius.org/206/Public-Works
Town of Huntersville
https://www.huntersville.org/267/Stormwater -Maintenance
Town of Pineville
http://www.pinevillenc.gov/Departments/PublicWorks/tabid/129/Default.aspx
Town of Mint Hill
https://www.minthill.com/public_works.php?Public -Works-Department-Stormwater-4
Town of Matthews
https://www.matthewsnc.gov/pview.aspx?id=20745&catid=567

On 8/19/2020, Rusty Rozzelle sent emails to Jeff Mitchell with CMS and Vicki Saville with CPCC making them aware that links
from their websites needed to be restored to the CMSWS. Jeff and Vicki are responsible for compliance with the Stormwater
Permit for their organizations. CMS was restored as flows:
https://www.cms.k12.nc.us/cmsdepartments/construction/buildingservices/ES/Pages/Stormwater-Permit-
Information.aspx.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 18 of 51
Public Involvement and Participation
Additional
Comments:
EPA Recommendations…
1. Does the LOCAL GOVERNMENT have a process to involve and receive input from citizens regarding
changes to the local government’s Stormwater Management Plan?
Staff provides an annual report regarding Phase II Permit compliance activities to the Charlotte-
Mecklenburg Storm Water Advisory Committee (SWAC) that is open to the public. During this report SWAC
and the public is informed that the Phase II activities are described in more detail in the Stormwater Plan
located on the website. The Program Manager’s information is on the website if the public wants to follow
up with comments.
2. Does the LOCAL GOVERNMENT have written procedures for methods used to promote events and
volunteer opportunities?
Completed as described below.

Finding(s): The Program would benefit significantly from the development and implementation of written
procedures for methods used to promote events and volunteer opportunities as recommended by EPA.
Follow Up Action(s) Needed: David Caldwell will research the existence of written procedures for methods
used to promote events and volunteer opportunities as well as to communicate information regarding
incidents, etc. He will first start by asking the City what they have . Indicate below the specific actions
completed for compliance, including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): On 6/5/20, the SOPs for Public Education/Outreach and Public
Involvement where reviewed. Section 1.4 that is entitled “Promotion” outlines the various methods used
for promoting volunteer programs. These documents are reviewed and updated at the beginning of every
fiscal year in cooperation with the City. Also, in June 2020 David Caldwell completed a Communication Plan
that is provided as Supporting Document #28. Staff was educated regarding this Plan that will be
implemented effective July 1, 2020. In addition, Section 3.6 was added to the Stormwater Plan to describe
the Communication Plan and its use.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 19 of 51
Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
(Name, Title,
Role)
Review completed by Ryan Spidel, Environmental Supervisor, and Andrew DeCristofaro, Sr. Environmental
Specialist, over the IDDE Program.
Permit Citation Program Requirement Status Supporting
Doc No.
II.D.2.a
IDDE Program The permittee maintained a written IDDE Program. Yes 19
If yes, the written program includes provisions for program assessment and
evaluation and integrating program. Yes 1
Comments (Note any deficiencies)

2020 Phase II Work Plan – Illicit Discharge Detection and Elimination (ID) Section, Evaluation: ID-10 Evaluate Effectiveness of IDDE
Program

IDDE Manual

IDDE Manual is currently in the process of being reviewed and updated (April 8, 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 to the MS4. Yes 9
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes 9
Comments

Mecklenburg County SW Ordinance, Town of Matthews SW Ordinance, Town of Davidson SW Ordinance

Matthews Ordinance was updated in 2019. MC and Davidson will be updated in 2020.

II.D.2.c
Storm Sewer
System Map
The permittee maintained a current map showing major outfalls* and receiving
streams. Yes ---
Comments
2020 Phase II Work Plan – ID-1 Storm Sewer Mapping & ID-2 Storm Water System (MS4) Outfall Inspections
Work to be done: Evaluate the map for missing areas of storm water infrastructure, collect these features using ArcCollector, work
with GIS to add flow direction as a layer in our inventory.
Improvement Made (April 7, 2020): Previously we did not have any symbology to represent an outfall that was draining a parcel
that was zoned industrial (permit requirement). Josh DeMaury worked with Ron Bruzzese to correct this problem. These outfalls
now have a different symbol to distinguish them from non-industrial outfalls.

*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.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 20 of 51
Illicit Discharge Detection and Elimination (IDDE)
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 19
Comments (Generally summarize program, including frequency of observations and # or % of outfalls screened)

2020 Phase II Work Plan – ID-2 Storm Water System (MS4) Outfall Inspections & ID-8 Stream Walk/Outfall Inspection/Inventory &
Dry Weather Flow Analysis

The vast majority of our Dry Weather Flow Program is conducted under ID -8. Data is collected in the field using Arc Collector.
II.D.2.e
Investigation
Procedures
The permittee maintained written procedures for conducting investigations o f
identified illicit discharges. Yes 19
Comments (Generally describe what procedures are documented)

IDDE Manual – Section 3: Methods Used to Identify Illicit Discharges and Connections, Section 4: Tracking Illicit Discharges and
Connections to a Source & Section 5: Eliminating Sources of Illicit Discharges and Connections

II.D.2.f
Track and
Document
Investigations
For each case of an illicit discharge or potential illicit discharge, the permittee documented and tracked the
following:
1. The date(s) the illicit discharge was observed Yes ---
2. The results of the investigation Yes ---
3. Any follow-up of the investigation Yes ---
4. The date the investigation was closed Yes ---
Comments (Note whether a standard inspection form is utilized to capture consistent information and a tracking mechanism is
used)
2020 Phase II Work Plan – ID-6 Responding to Citizen Requests & Emergencies

All investigation work is documented in Cityworks.

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 ---
Comments (Generally describe the staff training program, including frequency and which staff are trained)

Employee Training is conducted by the Pollution Prevention & Education Team.
II.D.2.h
Public Education

The permittee informed public employees of hazards associated with illegal
discharges and improper disposal of waste. Yes ---
The permittee informed businesses of hazards associated with illegal discharges and
improper disposal of waste. Yes ---
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 21 of 51
Illicit Discharge Detection and Elimination (IDDE)
The permittee informed the general public of hazards associated with illegal
discharges and improper disposal of waste. Yes ---
Comments (Note how each sector was informed, if applicable)

Public Education is conducted by the Pollution Prevention & Education Team.
II.D.2.i
Public Reporting
Mechanism
The permittee promoted, publicized, and facilitated a reporting mechanism for the
public to report illicit discharges. Yes ---
The permittee promoted, publicized, and facilitated a reporting mechanism for staff
to report illicit discharges. Yes ---
The permittee established and implemented response procedures for citizen
requests/reports. Yes ---
Comments (Generally describe reporting mechanisms and how promoted/publicized/facilitated/established)

The Public Reporting Mechanism is developed/maintained by the Pollution Prevention & Education Team.
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 ---
If yes, the mechanism includes the ability to identify chronic violators for
initiation of actions to reduce noncompliance. Yes ---
Comments (Generally describe the established tracking mechanism, if applicable)

2020 Phase II Work Plan – ID-3 Enforce Pollution Control Ordinance

All NOVs are saved in Cityworks. Staff can utilize Cityworks and EDMS to identify repeat violators.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 22 of 51

Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Review completed by Jason Klingler, Associate Project Manager, Lead Erosion Control Inspector.
Program Delegation Status:
☒ The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina
Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure (complete the permit
citation and SPCA citation sections).
☐ The permittee does not have a delegated Sediment and Erosion Control Program and relies on DEMLR to comply
with the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 components of this minimum measure
(complete only the permit citation section).
Permit Citation Program Requirement Status Supporting
Doc No.
II.E.3 Construction
Site Runoff Controls
[NPDES Permit No.
NCS000435] The permittee provides and promotes a means for the public to notify the
appropriate authorities of observed erosion and sedimentation problems (e.g.,
promoting the existence of the DEQ DEMLR “Stop Mud” hotline).
Yes
https://c
harlotte
nc.gov/S
tormWat
er/Repor
tAProble
m/Pages
/default.
aspx
Comments (Describe how provided and promoted)
The County uses 311 as a means for citizens to report all types of issues, included erosion and sedimentation control problems.
During the last fiscal year, 197 requests were received that related to erosion issues. These requests could have been from
construction sites or from eroded storm drainage channels. The stormwater website for Charlotte-Mecklenburg is used to promote
the reporting of erosion and sediment control problems through the page entitled “Report A Problem” (see the above link).
Finding(s): The “Report A Problem” page of the website did not include a description of erosion and sedimentation control
problems.
Follow Up Action(s) Completed (Date): On May 15, 2020, the website administrator was contacted, and the description was
added.
SPCA Citation Delegated Program Requirement Status Supporting
Doc No.
§ 113A-60 Local
erosion and
sedimentation
control programs (a)
The permittee has adopted an ordinance or other regulatory mechanism to enforce
the erosion and sedimentation control program. Yes 20
If yes, the ordinance meets or exceeds the minimum requirements of the
SPCA. Yes 20
If yes, the ordinance applies throughout the corporate limits of the permittee.
[Permit Part I.D] Yes 20
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 23 of 51
Construction Site Runoff Controls
Comments (Provide regulatory mechanism reference or Supporting Documentation number)
Mecklenburg County Soil Erosion and Sedimentation Control Ordinance (Cornelius and its ETJ, Matthews and its ETJ, Pineville and
its ETJ, and unincorporated areas of Mecklenburg County. Town of Davidson Soil Erosion and Sedimentation Control Ordinance
(Davidson and its ETJ) Town of Mint Hill Soil Erosion a nd Sedimentation Control Ordinance (Mint Hill and its ETJ).
§ 113A-60 Local
erosion and
sedimentation
control programs (d)
The permittee collects a fee paid by each person who submits an erosion and
sedimentation control plan. Yes 21
Comments (indicate the fee amount, if applicable)
See the Approved Fee Ordinance, revised June 4, 2019. The fee varies based on the type of applications submitted.
§ 113A-60 Local
erosion and
sedimentation
control programs (e)
Has any person initiated a land-disturbing activity (within the permittee’s
jurisdiction) for which an erosion and sedimentation control plan is required in the
absence of an approved plan?
Yes ---
If yes, the permittee has notified the North Carolina Sedimentation Control
Commission of all such cases.
Not
Applicable ---
Has the permittee determined that a person engaged in a land-disturbing activity
has failed to comply with an approved erosion and sedimentation control plan? Yes ---
If yes, has the permittee referred any such matters to the North Carolina
Sedimentation Control Commission for inspection and enforcement?
Not
Applicable ---
Comments
The local erosion control program is not a limited program, and thus can issue Notices of Violations and/or enforcement actions.
§ 113A-61 Local
approval of erosion
and sedimentation
control plans
The permittee reviews each erosion and sedimentation control plan submitted to
them and notifies the person submitting the plan that it has been approved,
approved with modification, or disapproved within 30 days of receipt.
Yes ---
The permittee only approves an erosion and sedimentation control plan upon
determining that it complies with all applicable State and local regulations. Yes ---
The permittee has disapproved of an erosion and sedimentation control plan in
order to protect riparian buffers along surface waters. Yes ---
If yes, the permittee notified the Director of the Division of Energy,
Mineral, and Land Resources within 10 days of the disapproval. Yes ---
Comments
Finding(s): The Director of the NCDEMLR is not notified within 10 days when the permittee disapproves an erosion and
sedimentation control plan in order to protect riparian buffers along surface waters.
Follow Up Action(s) Completed (Date): Effective May 18, 2020, Mecklenburg County will begin notifying the Director of
NCDEMLR within 10 days of disapproval of an erosion and sedimentation control plan in order to protect riparian buffers along
surface waters.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 24 of 51
Construction Site Runoff Controls
§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(a)
The certificate of approval of each erosion and sedimentation control plan
approved by the permittee includes a notice of the right to inspect. Yes 22
The permittee provides for inspection of land-disturbing activities to ensure
compliance with the SPCA and to determine whether the measures required in an
erosion and sedimentation control plan are effective.
Yes ---
Comments
The notice of the right to inspect is included in the approval letter that is sent to owner. The Mecklenburg County Soil Erosion and
Sedimentation Control Ordinance includes a section for inspections (Section 12), as well and The Mint Hill and Town of Davids on
Soil Erosion and Sedimentation Control Ordinance.
§ 113A-61.1
Inspection of land-
disturbing activity;
notice of violation
(c)
When the permittee determines that a person engaged in land-disturbing activity
has failed to comply with the SPCA, the Permittee immediately issues a notice of
violation upon that person.
Yes ---
Each notice of violation issued by the permittee specifies the date by which the
person must comply. Yes ---
Each notice of violation issued by the permittee informs the person of the actions
that need to be taken to comply. Yes ---
Comments
These are requirements of the Mecklenburg County Soil Erosion Control Ordinance (Section 12.c), as well as the ordinances for the
Towns of Mint Hill and Davidson.
§ 113A-64 Penalties Does the permittee issue civil penalties as part of the erosion and sedimentation
program? Yes ---
Comments (indicate when/why a civil penalty is issued, and the amount, if applicable)
Civil penalties are issued for violations of the erosion control ordinance, as described in Section 13 of the Mecklenburg Cou nty Soil
Erosion and Sedimentation Control Ordinance, as well as the ordinances for the Towns of Mint Hill and Davidson.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 25 of 51
Post-Construction Site Runoff Controls
Staff Interviewed:
(Name, Title, Role)
Don Ceccarelli, Program Manager, Permitting & Compliance
Tom Hodge, Lead Project Manager - manages staff responsible for plan/plat/as-built review
Corey Priddy, Environmental Supervisor, manages staff responsible for BMP Inspections
Jason Klingler, Associate Project Manager, performs Erosion Control, Land Development, and BMP
inspections
Implementation (check all that apply):
☒ The permittee implements the components of this minimum measure.
☒ The permittee relies upon another entity to implement the components of this minimum measure: CPCC, CMS, and the Towns
of Cornelius, Davidson, Huntersville, Matthews, Mint Hill, and Pineville rely on Mecklenburg County for partial implementatio n
☒ The permittee implements the following deemed-compliant program(s), which meet NPDES MS4 post-construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
☐ Water Supply Watershed I (WS-I) – 15A NCAC 2B .0212
☐ Water Supply Watershed II (WS-II) – 15A NCAC 2B .0214
☐ Water Supply Watershed III (WS-III) – 15A NCAC 2B .0215
☒ Water Supply Watershed IV (WS-IV) – 15A NCAC 2B .0216
☐ Freshwater High Quality Waters (HQW) – 15A NCAC 2H .1006
☐ Freshwater Outstanding Resource Waters (ORW) – 15A NCAC 2H .1007
☐ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0235
☐ Tar-Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy – 15A NCAC 2B .0258
☐ Randleman Lake Water Supply Watershed Nutrient Management Strategy – 15A NCAC 2B .0251
☐ Universal Stormwater Management Program – 15A NCAC 2H .1020

Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure prog ram
requirements throughout the MS4 permitted area (check all that apply):
☐ DEQ model ordinance
☒ MS4 designed post-construction practices that meet or exceed 15A NCAC 02H .1000.
☐ DEQ approved comprehensive watershed plan
☒ DEQ approved ordinance for a deemed -compliant Program (see list above)

Instructions:
For MS4s not implementing a S.L. 2006-246 deemed-compliant program, complete only the Permit Citation section below.
For MS4s implementing a S.L. 2006-246 deemed-compliant program, complete the Session Law 2006-246 section below. If the MS4
does not implement a deemed-compliant program throughout the entire MS4 permitted area, then complete the Permit Citation
section below for the permitted area(s) not covered under the S.L. 2006-246 deemed-compliant program.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 26 of 51
Post-Construction Site Runoff Controls
Session Law 2006-
246 Program Requirement Status Supporting
Doc No.
Deemed-Compliant
Program(s)
The permittee implements deemed-compliant Program requirements in
accordance with the applicable 15A NCAC rules. Yes ---
The permittee implements deemed-compliant Program requirements throughout
the entire MS4 area (If not, also complete the Permit Citation section below.) No ---
The permittee applies deemed-compliant Program requirements to all federal,
state and local government projects within the permitted MS4 area who do not
have their own NPDES stormwater permit.
Yes ---
The permittee included deemed-compliant Program reporting in their MS4 Annual
Reports. No
The permittee included deemed-compliant Program implementation in their
Stormwater Management Plan. No ---
Comments
According to the FY2019 State Electronic Report, a deemed-compliant Program is an existing state stormwater management
program that satisfies the post-construction stormwater management model practices, including Water Supply Watershed
programs for WS-I – WS-IV waters, the HQW and ORW waters management strategies, the Neuse River Basin Nutrient Sensitive
Waters (NSW) Management Strategy, the Tar-Pamlico River Basin Nutrient NSW Strategy, and the Randleman Lake Water Supply
Watershed program. For Mecklenburg, the Phase II jurisdictions in the northern portion of the County, including Davidson,
Cornelius and Huntersville, enforce Water Supply Watershed programs for WS-IV waters. These northern towns also have post-
construction ordinances along with the other 3 towns in the south and the county that were adopted for compliance with Phase II
Permit requirements. These post-construction ordinances are more protective of water quality than the deemed -compliant
ordinances; therefore, they always supersede. For this reason, the permittee does not include these deemed compliant Programs
into its MS4 Annual Report, but instead provides reporting on the implementation of the post-construction ordinances.
Permit Citation Program Requirement Status Supporting
Doc No.
II.F.2.a
Legal Authority

The permittee maintained an ordinance or other regulatory mechanism designed
to meet the objectives of the Post-Construction Site Runoff Controls Stormwater
Management Program.
Yes 7
If yes, the ordinance applies throughout the corporate limits and the
extraterritorial jurisdictional area of the permittee (Verify permit coverage
area listed in Part I.D of permit and modify accordingly).
Yes ---
The permittee has the authority to review designs and proposals for new
development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained.
Yes ---
The permittee has the authority to request information such as stormwater plans,
inspection reports, monitoring results, and other information deemed necessary to
evaluate compliance with the Post-Construction Stormwater Management
Program.
Yes ---
The permittee has the authority to enter private property for the purpose of
inspecting at reasonable times any facilities, equipment, practices, or operations
related to stormwater discharges.
Yes ---
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 27 of 51
Post-Construction Site Runoff Controls
Comments (If the permittee relies upon another entity, specifically note the legal authority that allows that entity to implement
the program within the MS4 area)

II.F.2.b
Stormwater Control
Measures (SCMs)

The permittee utilizes strategies which include SCMs appropriate for the MS4. Yes 6
SCMs comply with 15A NCAC 02H .1000. Yes ---
Comments
All ordinances together with the BMP Design Manual were approved by NCDEQ for meeting these requirements. In addition,
Mecklenburg County evaluated BMP designs and demonstrated that the local design manual met or exceeded the NCDEQ design
standards.
II.F.2.c
Plan Reviews

The permittee conducted site plan reviews of all new development and
redeveloped sites that disturb greater than or equal to one acre (including sites
that disturb less than one acre that are part of a larger common plan of
development or sale).
Yes ---
If yes, the site plan reviews addressed how the project applicant meets the
performance standards. Yes ---
If yes, the site plan reviews addressed how the project will ensure long-term
maintenance. Yes ---
Comments
Plan reviewers use an Electronic Plans Management System to document that developments meet the performance standards by
ensuring that the SCMs are designed according to the BMP design manual. BMPs designed according to the BMP Design Manual
meet the standards requirements. Long Term maintenance is ensured by completion and recordation of Declaration of BMP
Operation and Maintenance Plan (PCO Form 19).
One Post-Construction plan review project was selected for audit to ensure requirements were being met, Greater Life Church in
Mint Hill:
EPM# 378543 Concept Plan – requirements met
EPM# 381176 Construction Plans – requirements met with the minor exception that the approved plans were missing a required
forebay clean-out stake which is used to determine when the forebay is half full and requires maintenance.
EPM# 386027 RTAP – requirements met for adjustment of undisturbed open space. However, review of aerial photographs prior to
development indicate that a portion of the UOS set aside was not treed land and there was no requir ement to plant trees as
required by the ordinance.
EPM# 395210 Plat – requirements met with the exception of the approved plat was missing the required Undisturbed Open Space
note that explains the long term restrictions in this area.
EPM# 398911 As-builts Storm Drain & BMP – requirements met
Finding(s): The Design Standard for forebay stakes may need to be revised.
Follow Up Action(s) Needed: Don Ceccarelli will ensure that the Design Standard for forebay stakes is revised as necessary.
Indicate below the specific actions completed for compliance, including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): On September 1, 2020, the design standards for Wet Ponds, Sand Filters, and Wetland
were updated to include clean-out stakes for forebays and main ponds. Refer to website below:
https://www.mecknc.gov/LUESA/WaterandLandResources/LandDevelopment/Pages/LD%20Manual%202100%20Series.aspx

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 28 of 51
Post-Construction Site Runoff Controls
Finding(s): Staff training is needed for ensuring compliance with performance standards.
Follow Up Action(s) Needed: Don Ceccarelli will ensure that PCO refresher training is provided to staff that review plans, plats,
and as-builts to ensure all performance standards are met. Indicate below the specific actions completed for compliance,
including the date(s) these actions were completed.
Follow Up Action(s) Completed (Date): On July 29, 2020, Don Ceccarelli provided refresher training to Tom Hodge, Adam
Nowocin, Jonathan Rett, Casena Michael, and Gigi Mullis
II.F.2.d
Inventory of Projects

The permittee maintained an inventory of projects with post-construction
structural stormwater control measures installed and implemented at new
development and redeveloped sites.
Yes Cityworks
The inventory included both public and private sector sites located within the
permittee’s corporate limits that are covered by its post-construction ordinance
requirements.
Yes Cityworks
Comments
Inventories of projects (both public & private) with post-construction BMPs are maintained in the CityWorks BMP Database. In
addition, post-construction projects under review can be found in the electronic EPM system. Supporting Document #23 provides a
list of all publicly owned BMPs.
II.F.2.e
Deed Restrictions
and Protective
Covenants
The permittee provided mechanisms such as recorded deed restrictions and
protective covenants that ensure development activities will maintain the project
consistent with approved plans.
Yes
5
Sections
7,8,9,10
Comments
O&M Plans are required to be recorded in addition to a recorded plat that both spell out restrictions regarding post-construction
compliance.
II.F.2.f
Mechanism to
Require Long-term
Operation and
Maintenance

The permittee implemented or required an operation and maintenance plan for
the long-term operation of the SCMs required by the program. Yes 5
Section 7
The operation and maintenance plan required the owner of each SCM to perform
and maintain a record of annual inspections of each SCM. Yes
5
Section
12
Annual inspection of permitted structural SCMs are required to be performed by a
qualified professional. Yes
5
Section
12
Comments

II.F.2.g
Inspections of
Structural
Stormwater Control
Measures

The permittee conducted and documented inspections of each project site covered
under performance standards, at least one time during the permit term (Verify this
is a permit condition in Part II.F.2.g of permit and modify accordingly). This is not a
permit requirement.
Not
Applicable ---
Before issuing a certificate of occupancy or temporary certificate of occupancy, the
permittee conducted a post-construction inspection to verify that the permittee’s
performance standards have been met or a bond is in place to guarantee
completion(Verify this is a permit condition in Part II.F.2.g of permit and modify
accordingly.
Yes
5
Section
10.1
The permittee developed and implemented a written inspection program for SCMs
installed pursuant to the post-construction program (Verify this is a permit
condition in Part II.F.2.g of permit and modify accordingly . This is not a permit
requirement.
Not
Applicable ---
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 29 of 51
Post-Construction Site Runoff Controls
The permittee documented and maintained records of inspections. Yes Cityworks
The permittee documented and maintained records of enforcement actions. Yes Cityworks
Comments
Although not a permit condition, the permittee does perform annual inspections for most of post -construction BMPs and
documents those inspections in the BMP Database located in Cityworks

Although not a permit condition, the permittee does have a BMP Inspection Manual for staff that describes the inspection program
(see Supporting Document #4).

Although not a current permit condition, the draft Phase II Permit template produced by NCDEQ indicates that inspections of l ow-
density post-construction projects may be required. There is no easy way to produce a list of low-density projects currently.
Finding(s): A field needs to be added into the electronic Accela plan review application currently under development that
designates projects as low-density or high-density.
Follow Up Action(s) Completed: On May 27, 2020, scope was added to the Accela project to add the recommended field to the
application.
II.F.2.h
Educational
Materials and
Training for
Developers

The permittee made available through paper or electronic means, ordinances,
post-construction requirements, design standards checklists, and other materials
appropriate for developers.
Note: New materials may be developed by the permittee, or the permittee may use
materials adopted from other programs and adapted to the permittee’s new
development and redevelopment program.
Yes 5, 6 & 7
Comments (If the permittee has adopted materials from other programs, indicate here which materials they are using)
Ordinances: https://charlottenc.gov/StormWater/Pages/default.aspx
PC Admin Manual: https://charlottenc.gov/StormWater/Regulations/Pages/PostConstAdmManualCountyTowns.aspx
BMP Design Manual: https://charlottenc.gov/StormWater/Regulations/Pages/BMPDesignStandardsManual.aspx
Plan Review checklist:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%204 -3.doc
Plat Review checklist:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%208 -1.doc
As-built review checklist:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%2010 -1%20PCO27.doc
BMP Design Forms:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Forms/PCO%20Design%20Forms/
BMP Review checklists:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%204 -3.doc
BMP Inspection Checklists:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%207 -3/
Post Construction Compliance Checklist:
https://mecklenburgcounty.exavault.com/p/waterquality/PCO%20Administrative%20Manual/Appendix%2012 -1.doc

Also, Post-Construction Training is offered to developers and engineers on an annual basis to review requirements and provide the
development community updates to program requirements.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 30 of 51
Post-Construction Site Runoff Controls
II.F.2.i Enforcement

The permittee tracked the issuance of notices of violation and enforcement
actions. Yes Cityworks
If yes, the tracking mechanism included the ability to identify chronic violators
for initiation of actions to reduce noncompliance. Yes Cityworks
Comments
All records of non-compliance are housed in the BMP Database and violations can be searched by site. Staff perform a history
review of the site in the database (manual process) when issuing NOVs for post-construction issues to ensure the site is not a
repeat violator, which could increase the fine amount.
II.F.3.b
New Development
The permittee fully complies with post construction program requirements on its
own publicly funded construction projects. Yes 23
Comments
PCO ordinances have no exemption for publicly funded projects, and they must follow the same approval process as private
construction projects. The one exception is NCDOT projects; since NCDOT has their own post-construction program, NCDOT
projects comply with their requirements rather than the jurisdiction. Supporting Document #23 provides a list of publicly own ed
BMPs.
II.F.3.c
Nutrient Sensitive
Waters
Does the MS4 have areas draining to Nutrient Sensitive Waters (NSW) pursuant to
15A NCAC 02H .0150? No ---
If yes, does the permittee use SCMs that reduce nutrient loading in order to
meet local program requirements.
Choose
an item.
---
If yes, does the permittee also still incorporate the stormwater controls
required for the project's density level.
Choose
an item.
---
If yes, does the permittee also require documentation where it is not feasible to
use SCMs that reduce nutrient loading.
Choose
an item.
---
Comments (Provide reference for local requirements)
“Nutrient Sensitive Waters” are not defined in 15A NCAC 02H.0150, but “Sensitive receiving waters” are defined. The Goose Creek
Watershed located in the Town of Mint Hill and Matthews is classified as a Sensitive receiving water. The Goose Creek waters hed
does have special storm water treatment requirements (treatment required at any density level, requirement for infiltration BMPs,
additional stream buffers, etc.). The permittee does have to submit documentation if it is not feasible to implement the spe cial
requirements. See Section 6.8.1(305)(A)(4) of Mint Hill’s PC ordinance.
II.F.3.d
Design Volume
The permittee ensured that the design volumes of SCMs take into account the
runoff at build out from all surfaces draining to the system. Yes 6
Where “streets” convey stormwater, the permittee designed SCMs to be sized to
treat and control stormwater runoff from all surfaces draining to the SCM including
streets, driveways, and other impervious surfaces.
Yes 6
Comments
Section 2.5.4 of the BMP Design Manual documents that BMPs must be sized for all drainage areas.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 31 of 51
Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
(Name, Title, Role)
Review completed by Richard Farmer, Environmental Supervisor over the Pollution Prevention & Good
Housekeeping Program.
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 potential for generating polluted
stormwater runoff.
Yes ---
Comments (Note number of facilities, typical inventory data and any facilities that are not inventoried that should be)
Municipal facility inventories are located here: Z:\19-20 City Works Server Attachments\PP-5. The facilities that have the potential
for generating polluted stormwater runoff are identified in the Storm Water Quality Management Plan as follows:
Table 17: Municipal Operations Owned and/or Operated by the County and Towns (24)
Table 18: Municipal Operations Owned and/or Operated by CMS (8 – Note an additional 22 schools are inspected annually on a
rotational basis)
Table 19: Municipal Operations Owned and/or Operated by CPCC (4 campuses)
Table 20: Municipal Operations that have been Issued Stormwater Permits (6)
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 potential for generating polluted
stormwater runoff.
Yes ---
If yes, the O&M program specifies the frequency of inspections. Yes ---
If yes, the O&M program specifies the frequency of routine maintenance
requirements. Yes ---
If yes, the permittee evaluated the O&M program annually and updated it as
necessary. Yes ---
Comments
Each facility with the potential for generating polluted stormwater runoff has a site -specific Stormwater Pollution Prevention Plan
(SWPPP) that serves as the O&M Plan for the facility. The SWPPP specifies the frequency of inspections for preventative
maintenance and good housekeeping including the inspection of equipment, material storage areas, and control devices for
condition and signs of pollution (biannual) and non-storm water discharge assessment (annual). The SWPPPs are
reviewed and updated annually.

4/17/20: R. Farmer asked the State to provide clarification on the meaning of the following 2nd question in this section: “….the
O&M program specifies the frequency of routine maintenance requirements.” What type of maintenance is it referring to? Are
there specified “maintenance requirements” such as a required type or frequency?
4/20/20 - J. Powell with the State responded: “Generally speaking, there should be a written MS4 Facility O&M Plan that specifies
inspection and maintenance frequency. Typically, an MS4 will specify that each municipal facility will be inspected once per permit
term to identify pollution potential, and those facilities with identified stormwater pollution potential will be inspected annually
and have a written facility O&M plan that addresses routine self-inspection, spill response, material management, standard
documentation, etc. The individual facility plan and standard forms are usually based upon a standard template that is part of the
overall MS4 Facility O&M Plan.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 32 of 51
Pollution Prevention and Good Housekeeping for Municipal Operations
4/21/20 – The individual facility plans and standard forms are components of each facility’s SWPPP. The SWPPs do include the
frequency of inspections and any required actions (“routine maintenance”). Based on the response from the State and consideri ng
that our Program addresses all of the items that the State identified, no changes to the Program are recommended.
II.G.2.c
Spill Response
Procedures
The permittee had written spill response procedures for municipal operations. Choose
an item.
---
Comments
Each SWPPP contains a Spill Prevention and Response Plan.
II.G.2.d Streets,
Roads, and Public
Parking Lots
Maintenance

The permittee evaluated existing and new BMPs that reduce polluted stormwater
runoff from municipally owned streets, roads, and public parking lots within its
corporate limits annually.
Yes ---
If yes, the permittee evaluated the effectiveness of existing and new BMPs
based on cost and the estimated quantity of pollutants removed. Yes ---
Comments
The effectiveness of BMPs that reduce polluted stormwater runoff from municipally owned streets, roads, and public parking lo ts
within its corporate limits is evaluated annually based on cost and the estimated quantity of pollutants removed (Program Ele ment
PP-9).
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 ---
Comments (Briefly describe O&M program)
The Towns perform cleaning of the catch basins and conveyance systems. For the most part, these are performed on an as needed
basis due to blockages and subsequent flooding.

II.G.2.g
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 ordinance.
Yes ---
Comments (Describe inventory information and number of controls in inventory)
The County maintains an inventory of all the structural stormwater controls (SCMs) maintained by the co-permittees for compliance
with post-construction ordinance requirements. The inventory is maintained in Cityworks and is updated as new SCMs are added.
As of 4-17-2020, Cityworks indicates there 91 SCMs are maintained by the Phase II co-permittees at 40 separate projects for
compliance with post-construction ordinance requirements. The database includes 70 different fields with information pertaining
to the SCM’s name, location, object ID (for tracking), authority, inspection dat es, compliance information, inspection requirements,
owner information, etc.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 33 of 51
Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
O&M for Structural
Stormwater Controls

The permittee maintained and implemented an O&M program for municipally
owned or maintained structural stormwater controls installed for compliance with
the permittee’s post-construction ordinance. If yes, then:
Yes ---
The O&M program specified the frequency of inspections and routine
maintenance requirements. Yes ---
The permittee documented inspections of all municipally owned or maintained
structural stormwater controls. Yes ---
The permittee inspected all municipally owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee. Yes ---
The permittee maintained all municipally owned or maintained structural
stormwater controls in accordance with the schedule developed by permittee. Yes ---
The permittee documented maintenance of all municipally owned or
maintained structural stormwater controls. Yes ---
Comments

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

The permittee ensured municipal employees are properly trained in pesticide,
herbicide and fertilizer application management. Yes ---
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management. Yes ---
The permittee ensured all permits, certifications, and other measures for
applicators are followed. Yes ---
Comments
Section 8.9 of the Stormwater Plan specifies that each co-permittee is responsible for verifying that an employee or contractor has
the proper license and/or certification for the pesticide and/or herbicide applications to be performed. The license requires
continuing education; therefore, by ensuring proper licenses co-permittees are also ensuring proper training. Richard Farmer
contacted J. Powell with DEQ who offered the following guidance via email: “Generally, during a permit compliance audit we check
to see that the MS4 has a mechanism in place to ens ure that appropriate staff have current licensing. The two popular options for
doing this are; (1) including a check on the license status as part of the employee’s annual review, or (2) annually checking the
NCDA list to verify that staff licenses are current. It is not enough to solely rely on the NCDA and the staff person to ensure
licensing is current.”
Finding(s): CMSWS needs to verify that pesticide licenses are valid.
Follow Up Action(s) Completed (Date): On May 15, 2020, the inspection form and Stormwater Plan were revised to ensure that
pesticide license number for either the co -permittee’s employee or the contractor is obtained and that the number is verified as
being current through the NC Dept. of Agriculture website.
Section 8.9 of the Stormwater Plan specifies that co-permittees will verify annually that they do not exceed the thresholds for
obtaining permit # NCG560000. This is to ensure that all permits are followed as required by Section G.2.h of our Phase II pe rmit.
However, this verification requires that co-permittees track the amount of area where pesticides/herbicides are applied, which they
are not doing. Richard Farmer contacted J. Powell with DEQ who confirmed that we are to ensure compliance with NCG560000, but
that these permit conditions/standards would not be specifically enforced under the MS4 permit since that permit is not speci fically
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 34 of 51
Pollution Prevention and Good Housekeeping for Municipal Operations
named. However, during an MS4 audit DEQ may request supporting documentation to demonstrate general compliance with t hat
permit.
Finding(s): CMSWS needs to confirm compliance with permits, certifications, and other measures for applicators being followed.
Follow Up Action(s) Completed (Date): On May 19, 2020, it was decided that as part of our municipal inspections of Phase II
facilities we will continue to ask for a copy of application records. These records will be reviewed by the inspector and com pared
to previous years to determine if there have been significant increases in the quantities applied in which case further
investigations will be performed to determine if permit # NCG560000 should be obtained. The application records, results of
further investigations and copies of permits issued will be maintained in the facility’s file. The Stormwater Plan was revised to
include this requirement.
II.G.2.j
Staff Training
The permittee implemented an employee training program for employees involved
in implementing pollution prevention and good housekeeping practices. Yes ---
Comments
Yes, annual employee training is provided through the PP-1 Program Element (Municipal Training). Additional guidance is provided
by the inspector during the annual inspections.
II.G.2.k
Vehicle and
Equipment Cleaning
The permittee described and implemented measures that prevent or minimize
contamination of stormwater runoff from all areas used for vehicle and equipment
cleaning.
Yes ---
Comments
Washing areas are listed in the Exposed Significant Material section (Appendix B) of the SWPPP. This section details the exp osed
material and/or activity and the Best management Practices utilized to minimize storm water impacts.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 35 of 51
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Review completed by Olivia Edwards, Environmental Supervisor over the TMDL Program.
Program Status:
☐ The permittee is not subject to an approved TMDL (skip the rest of this section).
☒ The permittee is subject to an approved TMDL for: Rocky River, Fecal coliform, 9/19/02
There ☒ is ☐ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters.
Yes 12
Within 12 months of final TMDL approval, the permittee’s annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Yes 12
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program requirements.

II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
necessary to address impaired waters.
Yes 12
Within 24 months of final TMDL approval, the permittee’s annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Yes 12
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program requirements.

II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included
a description of activities expected to occur and when activities are expected to
occur.
Yes 12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 36 of 51
Total Maximum Daily Loads (TMDLs)
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program requirements.

II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
six minimum measures to enhance water quality recovery strategies in the
watershed(s) to which the TMDL applies.
Not
Applicable ---
The permittee described strategies and tailored and/or expanded BMPs in their
Stormwater Management Plan and annual reports
Not
Applicable ---
Comments
This section is not applicable as the Rocky River TMDL has a Waste Load Allocation.

Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Review completed by Olivia Edwards, Environmental Supervisor over the TMDL Program.
Program Status:
☐ The permittee is not subject to an approved TMDL (skip the rest of this section).
☒ The permittee is subject to an approved TMDL for: Goose Creek, Fecal coliform, 7/8/05
There ☒ is ☐ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters.
Yes 12
Within 12 months of final TMDL approval, the permittee’s annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Yes 12
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 37 of 51
Total Maximum Daily Loads (TMDLs)
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program Requirements.

II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
necessary to address impaired waters.
Yes 12
Within 24 months of final TMDL approval, the permittee’s annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Yes 12
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program Requirements.

II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included
a description of activities expected to occur and when activities are expected to
occur.
Yes 12
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final and the associated Cityworks activity reports. Based on this review,
we are in compliance with these Program Requirements.

II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
six minimum measures to enhance water quality recovery strategies in the
watershed(s) to which the TMDL applies.
Not
Applicable ---
The permittee described strategies and tailored and/or expanded BMPs in their
Stormwater Management Plan and annual reports
Not
Applicable ---
Comments
This section is not applicable as the Goose Creek TMDL has a Waste Load Allocation.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 38 of 51
Total Maximum Daily Loads (TMDLs)
Staff Interviewed:
(Name, Title, Role)
Review completed by Olivia Edwards, Environmental Supervisor over the TMDL Program.
Program Status:
☐ The permittee is not subject to an approved TMDL (skip the rest of this section).
☒ The permittee is subject to an approved TMDL for: Lake Wylie, Chlorophyll a, 2/5/96
There ☐ is ☒ is not a Waste Load Allocation (WLA) in the approved TMDL (If there is a WLA, then complete items II.H.1-5
below. If there is not a WLA, skip to item II.H.6 below)
Permit Citation Program Requirement Status Supporting
Doc No.
II.H.3 TMDLs Within 12 months of final TMDL approval, the permittee’s annual reports included
a description of existing programs, controls, partnerships, projects and strategies to
address impaired waters.
Not
Applicable N/A
Within 12 months of final TMDL approval, the permittee’s annual reports provided
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Not
Applicable N/A
Comments

II.H.4 TMDLs Within 24 months of final TMDL approval, the permittee’s annual reports included
an assessment of whether additional structural and/or non-structural BMPs are
necessary to address impaired waters.
Not
Applicable N/A
Within 24 months of final TMDL approval, the permittee’s annual reports included
a brief explanation as to how the programs, controls, partnerships, projects and
strategies address impaired waters.
Not
Applicable N/A
Comments

II.H.5 TMDLs Within 36 months of final TMDL approval, the permittee’s annual reports included
a description of activities expected to occur and when activities are expected to
occur.
Not
Applicable N/A
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 39 of 51
Total Maximum Daily Loads (TMDLs)
Comments

II.H.6 TMDLs If there is no Waste Load Allocation in the approved TMDL, the permittee
evaluated strategies and tailored and/or expanded BMPs within the scope of the
six minimum measures to enhance water quality recovery strategies in the
watershed(s) to which the TMDL applies.
Yes 12
The permittee described strategies and tailored and/or expanded BMPs in their
Stormwater Management Plan and annual reports Yes 12
Comments
Olivia Edwards reviewed the TMDL Annual Report FY2019 Final, the FY2020 Storm Water Quality Management Plan and the
associated Cityworks activity reports. Based on this review, we are in compliance with these Program Requirements.

General Comment Regarding Total Maximum Daily Loads (TMDLs)
Finding(s): Annual reports should be carefully reviewed prior to submittal as a few grammatical and content -based errors were
identified during the review of the FY2019 TMDL Annual Report as part of the audit process.
Follow Up Action(s) Completed (Date): On March 30, 2020, Rusty Rozzelle corrected the errors in the TMDL report and saved it
on the LAN as follows: G:\Water Quality\WQ_Xfer\WQ\Phase II Permit\TMDLs\TMDL Annual Report FY2019 FINAL SUBMITTAL
Revised on 3-30-20. This revised version is included as Attachment 2 in Supporting Document # 12. Future reports will be written
by staff and reviewed by their supervisor, which should reduce errors.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 40 of 51
Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
Pineville Public Works facility
Date and Time of Site Visit:
4/29/20
Facility Address:
316 College St.
Facility Type (Vehicle Maintenance, Landscaping, etc.):
Public Works
Name of MS4 inspector(s) evaluated:
Matt Santiago, Environmental Specialist (evaluation
performed by Richard Farmer, Environmental
Supervisor)

Most Recent MS4 Inspection (List date and name of
inspector):
4/23/19 – Matthew Storosh

Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name Title
Joey Wheeler Public Works Facility Manager
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility-specific?
Yes
What type of stormwater training do facility employees receive? How often?
Municipal training provided by CMSWS annually.
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
Municipal inspector training provided annually.

Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good
housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form?
Yes
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Audit Date(s): April through September 2020 Page 41 of 51
Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector’s process include taking photos?
The inspector took pictures of the SWPPP documentation as well as some of various areas of the facility.
Does the MS4 inspector’s process include reviewing the facility’s SWPPP (or similar document)?
Yes
Does the MS4 inspector’s process include walking the entire facility and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No
Does the MS4 inspector’s process include presenting the inspection findings to the facility contact?
Yes. After the inspection is complete the inspector reviews any recommendations. Additionally, a written report is
provided to the facility manager that includes any recommendations or deficiencies.
Inspection Results
Did the facility inspection result in any corrective actions to be implemented? If so, for what issue(s)?
No deficiencies were noted. There were some recommendations (See Notes/Comments/Recommendation section
below).
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
If deficiencies are noted then time frames are given to correct them. The Recommendations (minor issues) from this
inspection were not given a specific timeline but are expected to be resolved in a timely manner.
Notes/Comments/Recommendations
One waste dumpster was observed on the property. The dumpster was in good condition; however, the drain plug was
missing. CMSWS recommended replacing the drain plug to protect water quality.
The significant spills page of the SWPPP was not completed. According to facility personnel, no significant spills have
occurred. Richard recommended to the inspector that he indicate "no significant spills were reported" which was done.
No further action is necessary.

MS4 Permit Audit Report
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Audit Date(s): April through September 2020 Page 42 of 51
Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
No outfall ID provided in Collector app.

Date and Time of Site Visit:
June 30, 2020 – 14:30
Outfall Location:
Behind residence at 5535 Versage Drive, Mint Hill, NC

Outfall Description (Pipe Material/Diameter, Culvert, etc.):
FES – RCP, 15” pipe

Receiving Water:
Tributary to Irvin’s Creek (McAlpine Watershed)
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Sheen, Odor, Floatables/Debris, etc.):

No flow present Most Recent Outfall Inspection/Screening (Date):
Unknown – new outfall collected during this inspection

Days Since Last Rainfall:
1 day

Inches:
0.10”

Name of MS4 Inspector(s) evaluated:
Tyler Vanhoy, Environmental Inspector (evaluation performed by Ryan Spidel, Environmental Supervisor)
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
All CMSWS-WQ staff receive annual training on outfall inspections and streamwalks. Streamwalks are where most outfalls are
evaluated except during service request.

Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes, Tyler has been with CMSWS-WQ for 1.5 years and has a good grasp on outfall inspections.
Inspection Procedures
Does the inspector’s process include the use of a checklist or other standardized form?
Outfall inspections are completed using the Collector application on the inspectors County issued iPhone. On the application ,
inspectors use a map called “WQ Outfall Inspections 2020.” This map has all our pre-existing MS4 inventory, sewer lines, a
basemap, and the latest aerial images. The map has the capability to collect new inventory or inspect existing inventory. T he
collection and inspection process has a standardized form that the inspector uses to record data about the outfall.
Does the inspector’s process include taking photos?
The collector application has the capability to take photos and upload them to the server, but for some reason the photo coll ection
capability is not available on the Phase 2 inventory layer. We will have to check with GIS for them to enable this function .
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
The MS4 inspector did a good job using all of his senses to evaluate the MS4 for potential pollution issues.
MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 43 of 51
Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
No work was generated as a result of this inspection.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No follow-up inspection is needed for this outfall.
Notes/Comments/Recommendations
Finding(s): During this inspection process we found 2 issues that need to be addressed with the Collector iPhone Application. 1)
The collector app needs to show the feature ID number for the outfall. This attribute is probably hidden and can be turned o n. 2)
For the Phase 2 inventory layer, there is no option to add a photo of the outfall once it has either been inspected or created.
Overall, Tyler did a good job with the inspection and was able to accurately evaluate the inventory.
Follow Up Action(s) Completed (Date): On September 2, 2020, Ron Bruzzese (Meck Co. GIS) completed the stormwater inventory
map update and resolved the 2 issues identified above. He combined all Phase II inventory maps into a single map. In this
process, he also fixed the problem with adding photos to the attribute when it is in spected. On September 21, 2020, Ryan Spidel
worked with Ron Bruzzese to show an ID number with the inlets and outlets.

MS4 Permit Audit Report
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Audit Date(s): April through September 2020 Page 44 of 51
Site Visit Evaluation: Construction Site No. 1
Site/Project Name:
Mayes Hall
Date and Time of Site Visit:
5/6/2020 @ 1:00pm
Site/Project Address:

Operator:
No one on site during the inspection
Project Type (Commercial, Industrial, Residential, CIP, Roadway,
etc.):
Residential

NCG Permit ID Number:
NCC 193224
Disturbed Acreage:
21.24
Recent Enforcement Actions (Include Date):
An NOV was issued on 4/15/2020. Name of MS4 Inspector(s) evaluated:
Chanell Hatch, Environmental Specialist (evaluation
performed by Corey Priddy, Environmental Supervisor)
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
N/A N/A
Observations
Site Documentation/Training
Does the site have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it site-specific?
Yes. An Erosion Control Plan has been approved for this site, and it is site-specific.
Does the site have approved erosion and sedimentation control plans onsite? Are they representative of current site condition s?
Yes and they are representative of the current site conditions.
What type of stormwater training do site employees receive? How often?
N/A
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
The inspector has to obtain 8 hours of continuing education a year and also helps with the local erosion control workshop that is
put on 3 times per year.

Did the MS4 inspector appear knowledgeable about MS4 and NCG010000 requirements for construction sites?
Yes.
Did the MS4 inspector appear knowledgeable about erosion and sedimentation control/stormwater pollution prevention BMPs?
Yes.
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Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 45 of 51
Site Visit Evaluation: Construction Site No. 1
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist?
No. Notes are taken during the inspection to be entered into an inspection report.
Does the MS4 inspector’s process include taking photos?
No, unless they are needed to help point out a violation.
Does the MS4 inspector’s process include reviewing approved plans (erosion and sedimentation control and/or SWPPP)?
Not during a routine inspection, but prior to the inspection and until the inspector becomes knowledgeable of the site. A co py of
the approved plans was present with the inspector.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious violations? If so, explain:
Yes. There was an area where sediment had been deposited beyond the denuded limits but still on the property. This was pointed
out to the inspector on-site after it was missed.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
The inspector calls or speaks directly with the site contact and fol lows-up with an email stating the violations. The inspection report
is not always sent to the contact/owner.
Does the MS4 inspector’s process include providing construction stormwater educational materials to the site contact?
Not during a routine site inspection, unless needed. There is a pre-construction meeting where educational material is given to the
site contact and expectations are laid out.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
Verbal warning to remove the sediment that left the denuded limits as well as correct other smaller violations noted during t he
inspection.
If compliance issues were identified, what timeline for correction/follow-up was provided?
Issues will need to be addressed within a week.
Notes/Comments/Recommendations
Obtaining some of the information in the field was slow, when it could have already been obtained prior to the inspection. T hese
items were the NCG Permit ID #, recent enforcement actions, and disturbed acreage. The information needed was asked for
several hours earlier but was not gathered until on site. The information was obtained via iPad but should have already been
obtained. The area where the off-site sediment occurred should have been found during the inspection. The inspector noticed that
it looked concerning but was going to watch the area instead of taking a closer look to determine how severe the problem was. The
entire perimeter was walked with this one area not being looked at closely due to soft sediments around it. A more detailed
inspection could have found the issue and should be done regardless of the soil conditions around the site.
Finding(s): Staff are not obtaining requested data when asked, preferably prior to leaving for the field when conditions are
easier to obtain the data. The entire perimeter of a site should be walked regardless of conditions, to make sure that sediment is
not leaving the site and all measures are functioning properly. A notepad should be kept on hand during the walk to take any
notes at the time items are noted in the field. Official inspection reports (not emails) should be sent to the owner/contrac tor
after inspecting the site.
Follow Up Action(s) Completion (Date): On 7/16/2020, Corey Priddy met with the Erosion Control Staff and went over the
Recommendation Items, noted above. Staff are to immediately begin carrying a notepad and camera on all site inspections, and
to begin emailing a copy of the inspection report to the owner/contractor instead of just an email or phone call describing w hat
MS4 Permit Audit Report
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Audit Date(s): April through September 2020 Page 46 of 51
Site Visit Evaluation: Construction Site No. 1
is needed. Also, it was pointed out that the entire site perimeter should be walked every time to make certain that sedime nt is
not leaving the site.
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Audit Date(s): April through September 2020 Page 47 of 51
Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1
Site Name:
Greater Life Church
Date and Time of Site Visit:
May 8, 2020, 10:00-11:00am
Site Address:

3820 Matthews-Mint Hill Rd., Mint Hill, NC
SCM Type:
Wet Pond
Most Recent MS4 Inspection (Include Date and Entity):
NA - New site, just finalized in Sept 2019
Name of MS4 Inspector(s) evaluated:
Jason Klingler, Associate Project Manager (evaluation
performed by Don Ceccarelli, Senior Project Manager)
Most Recent MS4 Enforcement Activity (Include Date):
NA – new site
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name Title
none

Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes
Does the site have records of annual inspections? Are they performed by a qualified individual?
NA – New site. Site had records of initial compliance inspection by a PE.
Inspector Training/Knowledge

What type of stormwater training does the MS4 inspector receive? How often?
Inspector has training through NC State and has received his Storm Water BMP Inspection & Maintenance Certification and
maintain training requirements required by that certification.

Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls?
Yes, however, the inspector initially failed to verify compliance with PC requirements for Undisturbed Open Space areas until
prompted. In addition, the inspector used the grading plans to locate the Undisturbed Open Space areas and these areas were
merely called “Open Space” on the plans, which led to some confusion between PC Undisturbed Open Space and Zoning Open
Space requirements. Once prompted, the inspector knew that UOS could also be found on the As -built survey and Recorded Plat
for the site, looked it up and inspected the UOS area which identified a violation…. A parking lot was expanded into the UOS area.
In addition, it appears there may be an issue on the plan review, as based upon aerial photographs, one of the UOS areas was an
area with no trees and a house. UOS is supposed to be treed area (or supplemented with trees if an open field).
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Audit Date(s): April through September 2020 Page 48 of 51
Did the MS4 inspector appear knowledgeable about post-construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector’s process include the use of a checklist or other standardized form? What format?
Yes, inspector used a digital BMP Inspection checklist on for Wet Ponds within the BMP Database on his i -Pad.
Does the MS4 inspector’s process include taking photos?
Yes, overall photos were taken and photos of maintenance issues were taken by the inspector.
Does the MS4 inspector’s process include reviewing the site’s operation and maintenance plan and records of annual ins pections?
No, however, O&M plans are standard template plans and the inspector verified that one was recorded. The main focus of the
inspector is to ensure the BMPs are maintained and operating properly. There are no O&M financial verification requiremen ts for
commercial properties; however, the inspector indicated typically owners are not asked for proof of accumulation of funding for
non-commercial BMPs.
Does the MS4 inspector’s process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies ? If so, explain:
The inspector did not initially check to see if sediment had accumulated above what was required for maintenance in the foreb ay
and pool areas, but then again, this was a newly constructed BMP. After being prompted, the inspector pulled up the plans an d
was able to determine the design elevation of the pond bottom to compare it to the observed, but admitted taking measurements
of sediment levels in the forebay and pool areas was not part of a typical wet pond inspection. Also of note is that the wet pond
should have a sediment clean-out stake in the forebay, but these plans were prepared and approved without one.
Does the MS4 inspector’s process include presenting the inspection findings to the site contact in writing?
Yes, the site contact receives a full inspection report. As of this writing, the report had not yet been prepared or sent.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
As of this writing, the report was not finalized. The inspector indicated that any violations and maintenance items would be
communicated to the owner. Owner was not present at the inspection.
If compliance issues were identified, what timeline for correction/follow-up was provided?
As of this writing, the compliance and maintenance issues were not communicated to the owner, but the inspector indicated there
would be timelines for correction.
Notes/Comments/Recommendations
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Audit Date(s): April through September 2020 Page 49 of 51
Finding(s):
1. Consider Bonding Undisturbed Open Space as a standard item on the Bond Estimate form to ensure compliance.
2. Meet with the PC Storm Water Administrator and decide how to address verification of BMP escrow funding when
required, which may include modifying the O&M agreement, consultation with county att orney, etc. Along the same
lines, need to address two situations: 1)Where the HOA is taking over maintenance from the developer and the “escrow
down payment” has not been made, and 2) When the owner of the infrastructure bond wants to have his bond releas ed
but the owner of the maintenance bond refuses to post the bond, which holds the infrastructure bond owner hostage
because the infrastructure bond cannot be released until the maintenance bond is established.
3. Provide PCO review refresher training for inspection staff that inspect BMPs. Be sure to include:
a. What to inspect for PCO compliance besides just the BMP (additional BUA, disturbance of UOS, PC buffers,
etc.)?
b. What documents can be used to find PC compliance data besides approved plans.
c. How to address measurement of sediment levels in various BMPs.
d. Addressing BMP maintenance funding review, if required.
Follow Up Action(s) Completed (Date):
1. July 29, 2020 – Met with Plan Review / Bond staff and decided that Bonding of Undisturbed Open Space that required
tree planting would be incorporated into the Bond estimate as part of the landscaping line item .
2. August 3, 2020 – Don Ceccarelli changed the PCO19 form to address escrow funding and updated PCO#42 form.
3. August 6, 2020 – Don Ceccarelli provided PC refresher training to Corey Priddy, Jason Klingler, Heather Davis, Brian
Sifford and Chanell Hatch.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 50 of 51
APPENDIX A: SUPPORTING DOCUMENTS

The documents listed on pages 4 and 5 of this document have been saved in a folder on the LAN as
follows: G:\Water Quality\WQ_Xfer\WQ\Phase II Permit\Phase II Audits\2020 Audit\Supporting Document.

MS4 Permit Audit Report
Mecklenburg County, NC: NPDES Permit No. NCS000395
Audit Date(s): April through September 2020 Page 51 of 51

APPENDIX B: PHOTOGRAPH LOG

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