HomeMy WebLinkAboutNCS000540_Mooresville 2019 Annual Report Narrative_20191030
Town of Mooresville
NPDES Phase II Stormwater Report
Permit number NCS000540
July 1, 2018 – June 30, 2019
Report submitted on October 30, 2019
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Table of Contents
Introduction .................................................................................................................................... 5
Section 1: Public Education and Outreach Program ...................................................................... 8
1.1 Goals and Objectives .............................................................................................................. 8
1.2 Target Pollutants and/or Stressors ....................................................................................... 8
1.3 Target Audiences ................................................................................................................... 8
1.4 Residential and Industrial/Commercial Issues ..................................................................... 9
1.5 Informational Website ........................................................................................................... 9
1.6 Distribution of Public Education Materials ..........................................................................10
1.7 Hotline/Helpline ................................................................................................................... 11
1.8 Public Education and Outreach Program ............................................................................. 11
Section 2: Public Involvement and Participation Program ........................................................... 14
2.1 Public Review and Comment on Stormwater Plan .............................................................. 14
2.2 Target Pollutants and/or Stressors ...................................................................................... 14
2.3 Target Audiences .................................................................................................................. 14
2.4 Residential and Commercial Issues ..................................................................................... 14
Section 3: Illicit Discharge Detection and Elimination Program .................................................. 16
3.1 Illicit Discharge Detection and Elimination Program .......................................................... 16
3.2 Legal Authorities .................................................................................................................. 16
3.3 Storm Sewer System Map of Major Outfalls ........................................................................ 16
3.4 Dry Weather Flow Detection Program ................................................................................. 16
3.5 Investigate Sources of Identified Illicit Discharges.............................................................. 16
3.6 Track and Document Investigations of Illicit Discharges .................................................... 17
3.7 Employee Training ............................................................................................................... 17
3.8 Public Education .................................................................................................................. 18
3.9 Public Reporting................................................................................................................... 18
3.10 Enforcement of the IDDE Ordinance ................................................................................. 18
Section 4: Construction Site Runoff Controls Program ................................................................ 21
Section 5: Post Construction Site Runoff Controls Program ......................................................... 21
5.1 Legal Authorities ................................................................................................................... 21
5.2 Strategies which include SCMs appropriate for the MS4 ................................................... 22
5.3 Plan Reviews........................................................................................................................ 22
5.4 Inventory of Projects with Post-Construction Structural Stormwater Control Measures .. 22
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5.5 Deed Restrictions and Protective Covenants ...................................................................... 22
5.6 Mechanism to require long-term operation and maintenance of Stormwater Control
Measures (SCMs) ...................................................................................................................... 22
5.7 Inspections .......................................................................................................................... 23
5.8 Educational materials and training for developers ............................................................. 23
5.9 Enforcement ........................................................................................................................ 23
Section 6: Good Housekeeping and Pollution Prevention for Municipal Operations .................. 27
6.1 Inventory of municipally owned or operated facilities ........................................................ 27
6.2 Operation and Maintenance (O&M) for municipally owned or operated facilities ............ 27
6.3 Spill Response Procedures .................................................................................................. 27
6.4 Streets, roads, and public parking lots maintenance .......................................................... 27
6.5 Operation and Maintenance (O&M) for municipally-owned or maintained catch basins
and conveyance systems ........................................................................................................... 28
6.6 Identify municipally owned or maintained structural stormwater controls ...................... 28
6.7 O&M for municipally-owned or maintained structural stormwater controls .................... 28
6.8 Pesticide, Herbicide and Fertilizer Application Management ............................................ 28
6.9 Staff Training ...................................................................................................................... 29
6.10 Prevent or Minimize Contamination of Stormwater Runoff from all areas used for Vehicle
and Equipment Cleaning .......................................................................................................... 29
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Table of Tables
Table 1: Town of Mooresville Approximate Land Use Composition .............................................. 5
Table 2: Town of Mooresville Receiving Waters ............................................................................ 6
Table 3: Target Pollutants for the Public Education and Outreach Program ................................ 8
Table 4: Pollutants associated with residential and industrial/commercial issues ....................... 9
Table 5: Events attended by Stormwater Program Specialist in fiscal year 2019 (July 1, 2018-
June 30, 2019) ...............................................................................................................................10
Table 6: Stormwater-related articles published in Town of Mooresville Town Voice Newsletter in
fiscal year 2019 (July 1, 2018-June 30, 2019) ...............................................................................10
Table 8: Public Education and Outreach BMP Table .................................................................... 13
Table 9: Public Involvement and Participation BMP Table .......................................................... 15
Table 10: Illicit Discharge Training in fiscal year 2019 ................................................................. 17
Table 11: Illicit Discharge Detection and Elimination Program BMP Table ................................. 19
Table 12: Post Construction Site Runoff Controls Program BMP Table ...................................... 24
Table 13: Good Housekeeping and Pollution Prevention Program BMP Table ........................... 30
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Introduction
This report documents the Town of Mooresville’s compliance with the National Pollutant
Discharge Elimination System (NPDES) permit number NCS000540 to discharge stormwater as
effective February 20, 2017. This report covers the reporting period from July 1, 2018 through
June 30, 2019.
The Town of Mooresville began operating under a National Pollutant Discharge Elimination
System (NPDES) Phase II Municipal Separate Storm Sewer System (MS4) Permit on December
1, 2011. The permit has a 5-year cycle. The current permit is effective from February 20, 2017 to
February 19, 2022.
The tables within each of the Minimum Control Measure sections indicate the BMPs for each
minimum control measure and the associated measurable goal. Documentation is included
within each section showing what has been accomplished during the reporting period. Tables
detailing the implementation schedule and frequency of each BMP prescribed by the Town of
Mooresville’s Stormwater Permit can be found at the end of each section.
Based on the US Census Bureau data, the population estimate for the Town of Mooresville in
July 2018 was 38,431. In April 2010, the population estimates base for the Town of Mooresville
was 34,303. The US Census Bureau data indicates an 11.9% growth in population between April
2010 and July 2018.
The Town of Mooresville MS4 jurisdictional area is approximately 24 square miles. The Town of
Mooresville is located in southern Iredell County in the Piedmont region of North Carolina. The
Town of Mooresville is within the Catawba and Yadkin/Pee-Dee River Basins and the municipal
limits extend into the WS-IV Critical and Protected areas as well as the WS-II Critical Area.
According to the Drainage Master Plan completed by ESP in January 2016, the land use
composition within the Town of Mooresville is as detailed in the table below:
Table 1: Town of Mooresville Approximate Land Use Composition
Land Use Category % Total Area
Commercial 15%
Industrial 7%
Institutional 6%
Multi-Family 3%
Single-Family – High 19%
Single-Family – Low 5%
Single-Family – Medium 8%
Utility 2%
Woods/Undeveloped 36%
The existing MS4 serving the Town of Mooresville is comprised of a network of open ditches,
swales, pipes, culverts and structural SCMs that are within the incorporated limits. The
stormwater maintenance crew maintains all stormwater drainage infrastructure within the
rights-of-way of Town owned and maintained roads and within easements dedicated to the
Town.
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The Town of Mooresville MS4 conveyance system discharges to the following streams within the
Yadkin/Pee-Dee River Basin: Back Creek, Dye Branch, Rocky River, South Fork Withrow Creek
and West Branch Rocky River. It also discharges to the following streams within the Catawba
River Basin: Byers Creek, Davidson Creek, McCrary Creek, Reeds Creek and Work Creek. Table
2 below shows the Town of Mooresville receiving waters.
Table 2: Town of Mooresville Receiving Waters
River Basin Receiving Stream Name
Stream
Segment
Water Quality
Classification
TMDL
(Yes/No)
Catawba
Byers Creek 11-89-(1) WS-IV No
Byers Creek 11-89-(2) WS-IV; CA No
Davidson Creek 11-106 WS-IV; CA No
McCrary Creek 11-91. WS-IV,B; CA No
Reeds Creek 11-104-(1) WS-IV,B No
Reeds Creek 11-104-(2) WS-IV,B; CA No
Work Creek 11-105 WS-IV,B; CA No
Yadkin Pee-
Dee
Back Creek 12-108-21-1-(0.5) WS-II;HQW No
Dye Branch 13-7-2 C No
Rocky River 13-17 C No
South Fork Withrow
Creek 12-108-21-3-2 C No
West Branch Rocky
River 13-7-3 C No
Maintenance of the Town’s MS4 conveyance system is currently funded using the stormwater
utility fee established in January 2015. The annual revenue of the stormwater utility fee for
fiscal year 2019 was approximately $1,645,729 and is used for permit compliance, maintenance
of the Town’s MS4 and capital improvements to the Town’s MS4.
Requirements of Watershed Protection Overlay Districts are detailed in the Town of Mooresville
Zoning Ordinance, established in accordance with the requirements in North Carolina General
Statutes Section 143-214.5. These standards are designed to regulate density and impervious
surface cover in water supply watershed areas in order to promote public health, safety, and
general welfare through control of non-point source pollution within watershed protection
areas.
The Town of Mooresville restructured the stormwater employees during fiscal year 2019. The
former Stormwater Program Specialist position has been vacant since October 2018 with active
recruiting attempts. Since then, a stormwater services consultant was brought on board to
manage certain aspects of the NPDES program and provide miscellaneous support, and other
responsibilities were divided between the Stormwater Maintenance Supervisor and the newly
hired Senior Engineer. The stormwater maintenance crew, which was formerly part of the
Streets/Public Works Department, was also moved over to the Engineering Department. The
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figure below displays the organizational structure of the Town of Mooresville stormwater
employees.
Figure 1: Organizational Chart
Deputy Town
Manager
Engineering
Services Director
Senior Engineer
Engineering
Technician
Land Development
Inspectors
External Consultant
for Misc.
Stormwater
Services
Stormwater
Maintenance
Supervisor
Stormwater Crew
Leader
Stormwater
Equipment
Operator
Stormwater Tech II
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Section 1: Public Education and Outreach Program
The Town of Mooresville’s Public Education and Outreach Program educates residents, business
owners and other people within the community about the impacts of stormwater on the Town’s
receiving waters, and what members of the community can do to reduce pollutants in
stormwater runoff. This program is funded through the Stormwater Utility Fee, and in past
years, the Stormwater Program Specialist was responsible for implementation of the program.
During Fiscal Year ‘19, the majority of the Public Education and Outreach program was fulfilled
through the Town’s membership with the Regional Stormwater Partnership of the Carolinas,
which is further discussed at the end of this section.
The following sections discuss the BMPs implemented to fulfill these requirements. See Table 8
for the measurable goals, frequency and implementation schedule for each BMP.
1.1 Goals and Objectives
The goals and objective of the Town of Mooresville’s Public Education and Outreach Program is
to educate the community about the impacts of stormwater discharges on water bodies and the
steps the public can take to reduce pollutants in stormwater runoff through the distribution of
educational materials and/or outreach activities.
1.2 Target Pollutants and/or Stressors
Table 3 below describes the pollutants and pollutant sources targeted for the public education
and outreach program for the current permit cycle. Educational information provided will
include the impacts of stormwater pollution on water bodies and the steps the public can take to
reduce pollutants in stormwater runoff. Target pollutants are chosen based on citizen
complaints and requests for service, and information provided by Town staff.
Table 3: Target Pollutants for the Public Education and Outreach Program
Target Pollutant Pollution Source
Grass Clippings, leaves
and yard waste
Residential areas, landscaped areas
Automotive Fluids Residential areas
Pet Waste Residential areas, public open areas
Trash Garbage and litter
Illegal Dumping
Dumpsters
The Stormwater Program Specialist has provided education and stormwater pollution
prevention information for the targeted pollutants through the distribution of flyers at town
events, the distribution of door hangers after volunteer storm drain marking events, and articles
published in the Town Voice newsletter included with the utility bill. See Section 1.6 for
additional information regarding the distribution of educational information addressing target
pollutants and/or stressors.
1.3 Target Audiences
Homeowners and business owners are the target audiences for the public education and
outreach program. Homeowners were chosen as a target audience for the Public Education and
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Outreach program because they are most likely to engage in activities that produce or involve
the target pollutants listed in Table 3. The Town of Mooresville has a wide variety of businesses
which have the potential to contribute to stormwater pollution. A selection of businesses and
facilities (such as restaurants) which conduct activities that produce the target pollutants will
receive targeted education providing information regarding stormwater pollution prevention
specific to their business.
1.4 Residential and Industrial/Commercial Issues
The following residential and industrial/commercial stormwater issues will be addressed in the
Town’s Public Education and Outreach Program.
Table 4: Pollutants associated with residential and industrial/commercial issues
Issue Pollutant Impacts
Lawn and garden
care activities
Grass clippings,
leaves, yard waste
Excess nutrients discharged from the
Town’s MS4 and into receiving waters
increase algae growth which negatively
impacts aquatic plants and wildlife.
Automotive
Maintenance
Automotive Fluids Negative environmental impacts on the
Town’s receiving waters.
Pet Waste Pet Waste Excess nutrients and bacteria discharged
from the Town’s MS4 can negatively impact
the Town’s receiving waters.
Littering in
neighborhoods,
Dumpsters and Trash
Cans
Trash Increase in bacteria in stormwater runoff
which can negatively impact human health.
Public education handouts and other distributed material addresses the pollutants listed above
that are associated with residential and industrial/commercial issues. Distributed materials
address the pollutants listed in the table above. Specifically, handouts are being distributed to
restaurants that address stormwater pollution issues typical to restaurants and other issues are
addressed in articles in a newsletter distributed to both residents and businesses who receive a
utility bill. See Sections 1.6 and 1.8 for further information regarding distributed educational
materials.
1.5 Informational Website
A website containing information on the Town’s stormwater program is maintained by the
Stormwater Program Specialist. The link for the website is:
http://www.ci.mooresville.nc.us/Stormwater
The website includes a link to the Town of Mooresville Post Construction and Illicit Discharge
and Connection Ordinance, contact information for the Stormwater Maintenance Supervisor,
forms for post construction stormwater control measures and general stormwater pollution
prevention information.
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1.6 Distribution of Public Education Materials
Educational information about stormwater, stormwater pollution, and stormwater pollution
prevention is distributed periodically through the utility bill mailer and through flyers and
handouts distributed at various events in Mooresville throughout the year.
The Stormwater Program Specialist previously attended events within the Town and distributed
handouts to citizens. These handouts contain information regarding stormwater pollution and
stormwater pollution prevention tips including: don’t litter, pick up after your pet and pile
leaves, grass clippings and other yard waste above the curb and away from storm drains. Below
is a table containing information on the date, event and approximately how many citizens were
reached at each event. Because the Stormwater Program Specialist position was vacant and
trying to be filled during FY ’19, not as many events were attended as in years past. Moving
forward, these events and activities will be handled by the Stormwater Maintenance Supervisor.
Table 5: Events attended by Stormwater Program Specialist in fiscal year 2019 (July 1, 2018-June 30,
2019)
Date of Event Event Approximate Number of Citizens Reached
8/2/2018 Touch-A-Truck 15
4/27/2019 Household
Hazardous Waste
Collection Event
Event was held, but stormwater department was
unable to attend
5/11/2019 Race City Festival Event was cancelled due to weather
7/10/2019 Touch-A-Truck 25
Articles focused on stormwater pollution prevention information or on topics related to
stormwater are published in the Town of Mooresville utility mailing, the Town Voice, several
times per year. Approximately 14,500 residents and businesses receive a copy of the Town Voice
every month and it is also available online at http://ci.mooresville.nc.us/478/Town-Voice-
Newsletter. Stormwater specific article topics are chosen based on citizen reports, complaints
and requests for service as well as information provided by Town of Mooresville staff. See the
table below for the article topics published this year.
Table 6: Stormwater-related articles published in Town of Mooresville Town Voice Newsletter in
fiscal year 2019 (July 1, 2018-June 30, 2019)
Month Article Topic Article Description
July 2018 Fats, Oils & Grease (Town of
Mooresville F.O.G program)
Article includes information advising citizens to
never pour grease or used oil into the storm
drains or in the ground.
April 2019 Fats, Oils & Grease (Town of
Mooresville F.O.G program)
Article includes information advising citizens to
never pour grease or used oil into the storm
drains or in the ground.
Door hangers are distributed in residential neighborhoods following a volunteer storm drain
marking event in that neighborhood. Door hangers help to bring attention to the storm drain
markers and provide information about stormwater pollution prevention. Stormwater pollution
prevention tips for residents include requesting that citizens pile leaves, grass clippings and
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other yard waste above the curb and away from storm drains. From July 1, 2018 through June
30, 2019, 30 storm drains were marked by volunteers in the storm drain marking program.
Flyers of Stormwater Pollution Prevention Information for Restaurants are currently being
distributed to restaurants within the Town of Mooresville by the Town of Mooresville F.O.G.
department staff. These flyers encourage restaurant staff to use best management practices
such as to properly dispose of all waste, regularly check outdoor dumpsters and trash cans for
leaks and debris and to not direct wash water towards storm drains. Approximately 20
handouts have been distributed to restaurants in the Town of Mooresville by F.O.G staff. These
flyers will continue to be distributed by the F.O.G. Compliance Officers in welcome packets and
during inspections.
1.7 Hotline/Helpline
A stormwater hotline/helpline for requesting assistance with stormwater related issues is
maintained and advertised on the Town’s stormwater website.
(http://www.ci.mooresville.nc.us/Stormwater). The hotline/helpline is also listed on
distributed educational materials.
The Stormwater Supervisor received and documented a total of 216 work orders, including
phone calls from the number listed on the stormwater website, in fiscal year 2019. Service
requests and work orders are used to track issues reported by citizens that may require
maintenance. In fiscal year 2019, a total of 136 service requests were entered on behalf of
citizens and addressed by Town staff, and the remaining 80 inquiries were general questions
that did not require any physical work.
1.8 Public Education and Outreach Program
The Town’s Stormwater Public Education and Outreach Program provides educational
information to residents about how they can protect water quality and reduce stormwater
pollution. Information is provided through Town Voice articles, the Town of Mooresville
Stormwater website, handouts and door hangers. Educational demonstrations and
presentations are also available upon request.
The Town of Mooresville is a member of the Regional Stormwater Partnership of the Carolinas,
which is a non-profit organization that provides an opportunity for municipalities in the region
to collaborate on projects related to public education, outreach, and training. The RSPC allows
the Town of Mooresville to reach a wider audience and provide more outreach, education, and
public information than would be possible for us as an individual municipality. The RSPC
maintains an educational website with stormwater information and information on how to
report an illicit discharge, http://regionalstormwater.org.
Additionally, the RSPC holds numerous workshops and educational events. One particularly
beneficial workshop, Stormwater Workshop for Elected Officials, occurred on February 28,
2019. This workshop introduced the Clean Water Act and Municipal Stormwater Permit
requirements, and discussed the goals and objectives of a stormwater program, including fees,
stormwater control measures, maintenance of aging infrastructure, and stream buffers. This
workshop had a particularly far reach, as those elected officials were then able to use the newly
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acquired knowledge to make better decisions related to policy and educate and inform their
citizens.
The RSPC also completed a media campaign that ran throughout the fiscal year and included a
radio campaign, television platforms, and web-based television platforms. There was a total of
975 TV media spots in fiscal year 2019, resulting in about 7,588,067 impressions, and online
articles and stories reached about 1,378,459 viewers in the greater Charlotte area.
The Stormwater Program Specialist participated in the Town of Mooresville’s Citizen’s Academy,
which was held on September 27, 2018, and offered two sessions. Between the morning and
afternoon sessions, about 25 citizens were reached. The Stormwater Program Specialist
discussed the six minimum measures detailed in the Town’s NPDES Phase II Stormwater
Permit, as well as the maintenance of Town-owned stormwater infrastructure. Unfortunately,
the educational demonstrations for children through the recreational department were not able
to occur due to the Selma Burke Center being closed for construction/renovations. These
programs are expected to continue next fiscal year, once construction is complete and the
programs are able to be held again.
Table 7: Public Education and Outreach BMP Table
No. BMP Measurable Goal Implementation
Schedule
Frequency
1.1
Goals and Objectives Defined goals and objectives of the Local
Public Education and Outreach Program
based on community wide issues.
Implemented in year one of
the permit cycle.
Review annually
and update if
needed.
1.2 Describe target
pollutants and/or
stressors
The permittee shall maintain a description of
the target pollutants and/or stressors and
likely sources.
Target pollutants and/or
stressors are identified in
year one of the permit cycle.
Review annually
and update if
needed.
1.3 Describe target
audiences
The permittee shall maintain a description of
the target audiences likely to have significant
storm water impacts and why they were
selected.
Target audiences are
identified in year one of the
permit cycle.
Review annually
and update if
needed.
1.4 Describe residential
and
industrial/commercial
issues
The permittee shall describe issues, such as
pollutants, likely sources of those pollutants,
impacts, and the physical attributes of
stormwater runoff, in their
education/outreach program.
Residential and
industrial/commercial
issues are identified in year
one of the permit cycle.
Review annually
and update if
needed.
1.5 Informational Web
Site
The permittee shall promote and maintain,
an internet web site designed to convey the
program’s message.
Informational website will
continue to be maintained
throughout permit cycle.
Review annually
and update if
needed.
1.6 Distribute public
education materials to
identified target
audiences and user
groups. For example,
schools, homeowners,
and/or businesses.
The permittee shall distribute stormwater
educational material to appropriate target
groups. Instead of developing its own
materials, the permittee may rely on Public
Education and Outreach materials supplied
by the state, and/or other entities through a
cooperative agreement, as available, when
implementing its own program.
Public education materials
will be distributed
beginning in year one of
permit cycle.
Public education
materials will be
distributed at least
twice per year
throughout the
permit cycle.
1.7 Maintain Hotline/Help
line
The permittee shall promote and maintain a
stormwater hotline/helpline for the purpose
of public education and outreach.
Hotline/Helpline will
continue to be maintained
throughout the permit cycle.
Continuously
maintained.
1.8 Implement a Public
Education and
Outreach Program.
The permittee’s outreach program, including
those elements implemented locally or
through a cooperative agreement, shall
include a combination of approaches
designed to reach the target audiences. For
each media, event or activity, including those
elements implemented locally or through a
cooperative agreement the permittee shall
estimate and record the extent of exposure.
Public Education and
Outreach program will be
continued throughout the
permit cycle.
Review annually
and update if
needed.
Section 2: Public Involvement and Participation Program
The Town of Mooresville implements a Public Involvement and Participation Program with the
goal of involving the citizens of the Town of Mooresville in the Stormwater Program and
complying with State and Local notice requirements. The Stormwater Program Specialist is
responsible for implementation and the program is funded through the Stormwater Utility Fee.
The following sections discuss the BMPs implemented to fulfill these requirements. See Table 9
for the measurable goal, frequency and implementation schedule for each BMP.
2.1 Public Review and Comment on Stormwater Plan
The Town of Mooresville Stormwater Plan is posted on the Town’s Stormwater website
(http://www.ci.mooresville.nc.us/Stormwater). The Stormwater Maintenance Supervisor and
Senior Engineer are available to respond to any questions or comments from citizens.
2.2 Target Pollutants and/or Stressors
See Section 1.2 for information regarding targeted pollutants and/or stressors.
2.3 Target Audiences
Volunteers with the storm drain marking program are encouraged to mark storm drains in
lower-income neighborhoods to provide additional education through the Public Involvement
and Participation program for these areas. This group was chosen because a higher number of
illicit discharges were noted in the lower income neighborhoods within the Town of Mooresville.
Neighborhoods where volunteer storm drain marking events take place also receive additional
education through doorhangers. These doorhangers have general stormwater pollution
prevention information in English and Spanish.
2.4 Residential and Commercial Issues
See Section 1.4 for information regarding residential and commercial issues.
Table 8: Public Involvement and Participation BMP Table
No. BMP Measurable Goal Implementation
Schedule
Frequency
2.1 Allow the public an
opportunity to review
and comment on the
Stormwater Plan
The permittee shall conduct at least one
public meeting during the term of the
permit to allow the public an
opportunity to review and comment on
the Stormwater Plan.
Stormwater Plan is made
available to the public
throughout the permit cycle.
Stormwater Plan will
be available
throughout the permit
cycle.
2.2 Describe target
pollutants and/or
stressors
The permittee shall maintain a
description of the target pollutants
and/or stressors and likely sources.
Target pollutants and/or
stressors are identified in year
one of the permit cycle.
Review annually and
update if needed.
2.3 Describe target
audiences
The permittee shall maintain a
description of the target audiences likely
to have significant storm water impacts
and why they were selected.
Target audiences are identified
in year one of the permit cycle.
Review annually and
update if needed.
2.4 Describe residential
and
industrial/commercial
issues
The permittee shall describe issues,
such as pollutants, likely sources of
those pollutants, impacts, and the
physical attributes of stormwater
runoff, in their education/outreach
program.
Residential and
industrial/commercial issues are
identified in year one of the
permit cycle.
Review annually and
update if needed.
Section 3: Illicit Discharge Detection and Elimination Program
The Town of Mooresville implements an Illicit Discharge Detection and Elimination program
with the goal of detecting, eliminating and prohibiting non-stormwater discharges. The
Stormwater Program Specialist is responsible for implementation and the program is funded
through the Stormwater Utility Fee. The following sections discuss the BMPs implemented to
fulfill these requirements. See Table 11 for the measurable goal, frequency and implementation
schedule for each BMP.
3.1 Illicit Discharge Detection and Elimination Program
The Illicit Discharge Detection and Elimination Program and the procedures associated with it
are detailed in the IDDE Program and Procedures Manual. The manual describes how to
investigate and track illicit discharges, how to conduct dry weather outfall inspections,
enforcement procedures, and how the program is to be evaluated. This manual also describes
how the Wastewater Treatment Plant and the Water Sewer Maintenance Department is involved
with the Illicit Discharge Detection and Elimination Program.
3.2 Legal Authorities
The Town of Mooresville Post Construction and Illicit Discharge and Connection Ordinance
became effective September 2, 2014. Article V of the Post Construction and Illicit Discharge and
Connection Ordinance defines illicit discharges and illicit connections. Article VI of the
ordinance discusses enforcement and the procedure to be followed in the event of violations of
the ordinance. There have been no updates to the ordinance since the chapter took effect on
September 2, 2014.
3.3 Storm Sewer System Map of Major Outfalls
The Town of Mooresville maintains a GIS map of the municipal storm sewer system including
inlets, pipes, outfalls and major outfalls. This map also shows rivers and streams in the area.
This map is updated periodically to reflect new construction and new information.
Per the Engineering Department GIS Specialist, approximately 1,450 new features were added
to the drainage structures dataset and about 1,000 new features were added to the drainage
pipes dataset in fiscal year 2019. The GIS system now contains approximately 11,500 total
stormwater structures.
3.4 Dry Weather Flow Detection Program
Details and written procedures associated with the dry weather flow detection program are
detailed in the Illicit Discharge Detection and Elimination program and procedures manual.
3.5 Investigate Sources of Identified Illicit Discharges
Article VI, Section 25-31 of the Phase II Post Construction and Illicit Discharge and Connection
Ordinance details the procedure for investigating reported illicit discharges. The Illicit
Discharge Detection and Elimination Program and Procedures Manual also details the process
for investigating illicit discharges.
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In fiscal year 2019, 19 illicit discharge reports were made, 16 reports of which were made by
citizens. Out of these 19 reported suspected illicit discharges, 9 were determined to be illicit
discharges. The Stormwater Maintenance Supervisor addressed illicit discharges through letters
or phone calls. If the Stormwater Maintenance Supervisor requests action to be taken by the
responsible party to correct the illicit discharge, a follow up investigation is conducted to
confirm the required action has been taken.
3.6 Track and Document Investigations of Illicit Discharges
Each report of an illicit discharge is tracked using a spreadsheet. Data tracked for each report
includes: the date(s) the illicit discharge was observed and reported, the results of the
investigation, any follow-up that was required, and the date the investigation was closed. This
database and all other documentation of illicit discharges is maintained by the Stormwater
Maintenance Supervisor. Locations of illicit discharges are tracked using ArcGIS.
3.7 Employee Training
All employees who as part of their normal job responsibilities may come into contact with or
otherwise observe an illicit discharge receive stormwater-related training at least once per year.
Training includes information on how to recognize an illicit discharge and how to report the
illicit discharge. Training can be in the form of posters, handouts and presentations.
Documentation of training. In the past the records have been kept by the Stormwater Program
Specialist, but moving forward they will be maintained by the Stormwater Maintenance
Supervisor.
Training was provided to departments most likely to encounter illicit discharges during normal
activities. A flyer showing examples of illicit discharges, the information needed to report an
illicit discharge and the contact information to use when reporting an illicit discharge was
posted in or distributed to the managers of several facilities with employees that would be likely
to encounter illicit discharges during normal daily activities. Additionally, training workshops
were conducted on October 23, 2018 and October 25, 2018 for staff in the Public Services
division. The following table shows the department and the number of individuals that attended
the training session.
Table 9: Illicit Discharge Training in fiscal year 2019
Facility Date Departments
Trained
Number
Employees that
Attended Training
Public Services
Operations Facility
10/23/2018 Streets (including
Stormwater and
Traffic)
22
Public Services
Operations Facility
10/23/2018 Sanitation 19
Public Services
Operations Facility
10/25/2018 Water and Sewer 23
18
3.8 Public Education
During fiscal year 2019, an article on illicit discharges was published in the Town Voice
newsletter. This newsletter is included with the utility bill and is sent to approximately 14,500
customers. The article discussed the definition of an illicit discharge, what citizens can do to
prevent illicit discharges, and how citizens can report suspected illicit discharges.
3.9 Public Reporting
The Town’s stormwater website includes a section on illicit discharges which includes a phone
number and email address that the public is encouraged to use to report suspected illicit
discharges. The report of an illicit discharge will prompt the Stormwater Program Specialist to
begin carrying out procedures detailed in Article VI of the Phase II Post Construction and Illicit
Discharge and Connection Ordinance and the Illicit Discharge Detection and Elimination
Program and Procedures Manual. In fiscal year 2019, 16 of the 19 reports of suspected illicit
discharges were made by citizens.
3.10 Enforcement of the IDDE Ordinance
A spreadsheet with data showing the date and address for each NOV issued is maintained by the
Stormwater Program Specialist. This database can be used to track the number of NOVs sent to
each address over time so that chronic violators can be recognized, and appropriate measures
can be pursued.
Table 10: Illicit Discharge Detection and Elimination Program BMP Table
No. BMP Measurable Goal Implementation
Schedule
Frequency
3.1 Maintain an Illicit
Discharge Detection
and Elimination
Program
Maintain a written Illicit Discharge Detection
and Elimination Program, including provisions
for program assessment and evaluation and
integrating program.
A written IDDE program is
maintained throughout the
permit cycle.
IDDE program
will be reviewed
and updated as
needed.
3.2 Maintain adequate
legal authorities
The permittee shall maintain IDDE ordinances
or other regulatory mechanisms that provides the
legal authority to prohibit illicit connections and
discharges.
Phase II Post Construction
and Illicit Discharge and
Connection Ordinance
became effective September
2, 2014.
Review annually
and update if
needed.
3.3 Maintain a Storm
Sewer System Map of
Major Outfalls.
The permittee shall maintain a current a map
showing major outfalls and receiving streams.
Map of storm sewer system
with major outfalls is
updated periodically
throughout the permit cycle.
Map will be
updated as
needed.
3.4 Implement a program
to detect dry weather
flows
The permittee shall maintain a program for
conducting dry weather flow field observations in
accordance with written procedures.
Dry weather flow detection
program is maintained
throughout the permit cycle.
Review annually
and update if
needed.
3.5 Investigate sources of
identified illicit
discharges.
The permittee shall maintain written procedures
for conducting investigations of identified illicit
discharges.
Procedures for investigation
of identified illicit discharges
are implemented during year
one of the permit cycle.
Review annually
and update if
needed.
3.6 Track and document
investigations illicit
discharges
For each case the permittee shall track and
document 1) the date(s) the illicit discharge was
observed; 2) the results of the investigation; 3)
any follow-up of the investigation; and 4) the
date the investigation was closed.
Tracking and documentation
of illicit discharges is
implemented at the start of
the permit cycle.
Illicit discharge
investigations will
be tracked and
documented
throughout the
permit cycle.
20
3.7 Provide Employee
Training
The permittee shall implement and document 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.
Employee training for
appropriate municipal staff
is implemented in the first
year of the permit cycle.
Appropriate
municipal staff
will receive
training at least
once per year.
3.8 Provide Public
Education
The permittee shall inform public employees,
businesses, and the general public of hazards
associated with illegal discharges and improper
disposal of waste.
Public education materials
will be distributed beginning
in year one of permit cycle.
Public education
materials will be
distributed at least
once per year
throughout the
permit cycle.
3.9 Provide a public
reporting mechanism
The permittee shall promote, publicize, and
facilitate a reporting mechanism for the public
and staff to report illicit discharges and establish
and implement citizen request response
procedures.
A public reporting
mechanism is provided and
maintained throughout the
permit cycle.
Continuously
provided and
maintained
throughout the
permit cycle.
3.10 Enforcement of the
IDDE ordinance
The permittee shall implement a mechanism to
track the issuance of notices of violation and
enforcement actions as administered by the
permittee. This mechanism shall include the
ability to identify chronic violators for initiation
of actions to reduce noncompliance.
A mechanism to track the
enforcement of the IDDE
ordinance is maintained
throughout the permit cycle.
Enforcement of
the IDDE
ordinance will be
tracked and
documented
throughout the
permit cycle.
Section 4: Construction Site Runoff Controls Program
The Town of Mooresville relies upon the North Carolina Division of Energy, Mineral, and Land
Resources Sediment and Erosion Control Program and Iredell County Erosion Control Section
to comply with this minimum measure. The Town of Mooresville and Iredell County entered
into an Interlocal Agreement for Enforcement Services of Iredell County Soil Erosion and
Sediment Control Ordinance on September 15, 2009.
A spreadsheet is maintained by the Stormwater Maintenance Supervisor that details reported
construction site runoff issues and communication with Iredell County Erosion Control Section.
The Town of Mooresville Stormwater Maintenance Supervisor will continue to document
reports of issues with construction site runoff controls and reports to Iredell County Erosion
Control Section.
Section 5: Post Construction Site Runoff Controls Program
The Town of Mooresville implements and enforces a Post-Construction Site Runoff Controls
Program with the goal of addressing stormwater runoff from new development and
redevelopment projects that disturb greater than or equal to one acre, including projects less
than one acre that are part of a larger common plan of development or sale, that discharge into
the MS4. Another objective of this program is to address post-construction runoff with the
Phase II Post Construction and Illicit Discharge and Connection Ordinance and to ensure long-
term operation and maintenance of stormwater control measures. The Engineering Technician
and Stormwater Maintenance Supervisor share the responsibility for implementation and the
program is funded through the Stormwater Utility Fee. The following sections discuss the BMPs
implemented to fulfill these requirements. See Table 12 for the measurable goal, frequency and
implementation schedule for each BMP.
5.1 Legal Authorities
The Town of Mooresville adopted the Post Construction and Illicit Discharge and Connection
Ordinance, effective September 2, 2014. This ordinance establishes the legal authorities to meet
the objectives of the Post Construction Site Runoff Controls program.
The ordinance details requirements for stormwater control measures and refers to the Town of
Mooresville Land Development Standards, which references the latest edition of the Stormwater
Best Management Practices Manual prepared by NCDEQ, for the design requirements. The
ordinance establishes design and review criteria for the construction, function and use of
structural stormwater control measures (SCMs) that may be used to meet the standards
established by this ordinance and the Town of Mooresville Land Development Standards as well
as the administrative procedures for the submission, review, approval and disapproval of
stormwater management plans, and for the inspection of approved projects. Plan reviews and
inspections are carried out by Planning Department and Engineering Department staff.
Owners of post-construction structural SCMs are required to record and submit an Operation
and Maintenance agreement for each SCM. The operation and maintenance agreement includes
22
a statement that the Stormwater Maintenance Supervisor has the right to enter the facility if
they have reason to believe it has become necessary to inspect, monitor, maintain, repair or
reconstruct the SCM. Owners are also required to submit annual inspection reports that have
been signed by a qualified professional as defined by the ordinance beginning January 1st of the
calendar year after the date of the as-built certification and each year thereafter on or before
March 31st of that calendar year.
5.2 Strategies which include SCMs appropriate for the MS4
The Town of Mooresville Land Development Standards states that structural stormwater control
measures are to be designed following using the latest version of the Stormwater Design Manual
prepared by NCDEQ.
5.3 Plan Reviews
The Land Development process is described on the Land Development website,
https://ci.mooresville.nc.us/231/Land-Development. Plan reviews and approvals are conducted
by Planning Department and Engineering Department staff. In fiscal year 2019, 33 plans with a
total lot size over 1 acre were approved for construction by Town staff.
5.4 Inventory of Projects with Post-Construction Structural
Stormwater Control Measures
An inventory of post-construction structural stormwater control measures located within the
Town’s corporate limits and required by the Phase II Post Construction and Illicit Discharge and
Connection Ordinance is maintained by the Engineering Technician.
5.5 Deed Restrictions and Protective Covenants
The Town of Mooresville issues plan approval for the final construction plans. Once the
construction begins Town staff inspects the project for plan compliance throughout the entire
process. Once construction is complete the Town requires as-builts and certifications from the
consulting engineer that all infrastructure is built according to plan and subsequently Town
standards.
Stormwater Operation and Maintenance Agreements, signed by owners of Post Construction
Stormwater Control Measures, include a statement that the owner of the SCM agrees to notify
the Town of Mooresville of any problems with the system or prior to any changes to the system
or responsible party.
5.6 Mechanism to require long-term operation and maintenance of
Stormwater Control Measures (SCMs)
The Phase II Post Construction and Illicit Discharge and Connection Ordinance requires that all
owners of post construction structural stormwater control measures installed as a requirement
of this ordinance to submit an Operation and Maintenance Agreement to the Engineering
Technician. The Operation and Maintenance Agreement requires the owner to continuously
operate and maintain the stormwater control and management facilities. The agreements also
detail the important maintenance procedures and inspection activities to be performed for the
specific type of structural stormwater control measure. Owners of these structural stormwater
23
control measures are also required by the ordinance to submit annual inspection reports
performed by a qualified professional as defined by the ordinance. Operation and maintenance
plans and annual inspection reports for Town owned and maintained stormwater control
measures are maintained by the Stormwater Maintenance Supervisor. In fiscal year 2019, 21
new Operation and Maintenance Agreements for Stormwater Control Measures were recorded
with Iredell County Record of Deeds and submitted to the Engineering Technician.
5.7 Inspections
Procedures for inspections are included in the Operation and Maintenance Agreement signed,
recorded and submitted by the owning entity of the structural stormwater control measure. The
Town of Mooresville requires that owners of post-construction structural stormwater control
measures submit an annual inspection report performed by a qualified professional, as defined
by the ordinance, beginning January 1st of the calendar year after the date of the as-built
certification and each year thereafter on or before March 31st of that calendar year. All
inspection reports and any related documentation submitted to the Town of Mooresville is
maintained by the Stormwater Maintenance Supervisor.
5.8 Educational materials and training for developers
The Land Development Process Manual gives an overview of the land development process for
plan review. This manual refers to the Land Development Standards for design standards. After
plan approval, the developer receives a checklist that details requirements including recording
and submitting the Operation and Maintenance Agreement.
5.9 Enforcement
The Stormwater Supervisor tracks information regarding issued notices of violation and any
enforcement actions taken including the property owner and location of the structural
stormwater control measure. Letters are mailed to two owners of post-construction stormwater
control measures for not submitting annual inspection reports by March 31, as required by the
Town of Mooresville Post Construction and Illicit Discharge and Connection Ordinance. No
letters were mailed during fiscal year 2019.
Table 11: Post Construction Site Runoff Controls Program BMP Table
No. BMP Measurable Goal Implementation
Schedule
Frequency
5.1 Adequate legal
authorities
Maintain through ordinance, or other regulatory mechanism,
adequate legal authorities to meet the objectives of the Post-
Construction Site Runoff Controls Stormwater Management
program.
The permittee shall have 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.
The permittee shall have 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.
The permittee shall have the authority to enter private
property for the purpose of inspecting at reasonable times
any facilities, equipment, practices, or operations related to
stormwater discharges to determine whether there is
compliance the Post-Construction Stormwater Management
Program.
The Phase II Post
Construction and
Illicit Discharge and
Connection
Ordinance became
effective September
2, 2014.
Review annually
and update if
needed.
5.2 Strategies which
include Stormwater
Control Measures
(SCMs) appropriate
for the MS4
Strategies with include Stormwater Control Measures
(SCMs) appropriate for the MS4, include, but are not
limited to compliance with 15A NCAC 02H Section .1000
effectively meets the Post-construction Stormwater Runoff
control requirements
Post Construction
and Illicit Discharge
and Connection
Ordinance became
effective September
2, 2014
Review annually
and update if
needed.
25
5.3 Plan reviews The permittee shall conduct 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). The site plan review shall address
how the project applicant meets the performance standards
and how the project will ensure long-term maintenance.
Implemented during
first year of permit
cycle.
Plan reviews
conducted as
required
throughout
permit cycle.
5.4 Inventory of projects
with post-
construction
structural
stormwater control
measures
The permittee shall maintain an inventory of projects with
post-construction structural stormwater control measures
installed and implemented at new development and
redeveloped sites, including both public and private sector
sites located within the permittee’s corporate limits that are
covered by its post-construction ordinance requirements.
An inventory is
maintained
throughout the
permit cycle.
Review annually
and update if
needed.
5.5 Deed Restrictions
and Protective
Covenants
The permittee shall provide mechanisms such as recorded
deed restrictions and protective covenants that ensure
development activities will maintain the project consistent
with approved plans.
Implemented as part
of the plan approval
and construction
inspection process.
Review and
update as
needed.
5.6 Provide a
mechanism to
require long-term
operation and
maintenance of
Stormwater Control
Measures (SCMs)
The permittee shall implement or require an operation and
maintenance plan for the long-term operation of the SCMs
required by the program. The operation and maintenance
plan shall require the owner of each SCM to perform and
maintain a record of annual inspections of each SCM.
Annual inspection of permitted SCMs shall be performed
by a qualified professional.
Operation and
Maintenance
Agreements and
annual inspection
reports are required
per the Post
Construction and
Illicit Discharge and
Connection
Ordinance, which
became effective
September 2, 2014
Operation and
Maintenance
Plans are
required to be
submitted upon
as-built
certification.
Annual
inspection
reports are
required to be
submitted by
March 31st of
each year.
26
5.7 Inspections To ensure that all stormwater control measures meet the
permittee’s performance standards and are being
maintained pursuant to the maintenance agreement, the
permittee shall develop and implement a written inspection
program for structural stormwater controls installed
pursuant to the permittee’s post-construction program.
The permittee shall document and maintain records of
inspections, findings and enforcement actions and make
them available for review by the permitting authority.
Written procedures
per the Post
Construction and
Illicit Discharge and
Connection
Ordinance, effective
September 2, 2014.
Inspection records
Written
procedures will
be reviewed
annually and
updated if
needed.
Inspection
records
submitted
annually to the
Town will be
maintained
continuously
throughout
permit cycle.
5.8 Educational
materials and
training for
developers
The permittee shall make available through paper or
electronic means, ordinances, post-construction
requirements, design standards checklist, and other
materials appropriate for developers. 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.
Information
available throughout
the permit cycle.
Information and
materials will be
available to
developers
throughout the
permit cycle.
5.9 Enforcement The permittee shall track the issuance of notices of violation
and enforcement actions. This mechanism shall include the
ability to identify chronic violators for initiation of actions
to reduce noncompliance.
Implemented in year
one of the permit
cycle.
Enforcement will
be tracked and
documented
continuously
throughout the
permit cycle.
Section 6: Good Housekeeping and Pollution Prevention for
Municipal Operations
The Town of Mooresville implements a Good Housekeeping and Pollution Prevention Program
for municipal operations with the goal of preventing or reducing pollutant runoff from
municipal operations. This program includes employee training to prevent and reduce
stormwater pollution from municipal activities. The Stormwater Supervisor is responsible for
implementation and the program is funded through the Stormwater Utility Fee. The following
sections discuss the BMPs implemented to fulfill these requirements. See Table 13 for the
measurable goals, frequency and implementation schedule for each BMP.
6.1 Inventory of municipally owned or operated facilities
An inventory of all municipally owned or operated facilities that have the potential to generate
polluted stormwater runoff has been developed and is maintained by the Stormwater
Supervisor.
6.2 Operation and Maintenance (O&M) for municipally owned or
operated facilities
All municipally owned or operated facilities identified by the inventory as having the potential to
generate polluted stormwater runoff have a Stormwater Operation and Maintenance (O&M)
Plan. Stormwater O&M Plans detail the stormwater pollution prevention and good
housekeeping practices utilized by the employees at that facility. Each Stormwater O&M Plan
also details the frequency of facility inspections and the regular maintenance activities.
Stormwater O&M Plans for each facility are located either at the facility or in the Stormwater
Supervisor’s office if it is impractical to keep the plan at the facility. Operation and Maintenance
Plans for each facility are reviewed periodically and amended as needed. Amendments to the
Operation and Maintenance Plans are documented in the Operation and Maintenance Plan for
the facility.
6.3 Spill Response Procedures
The Stormwater O&M Plan for each facility contains Spill Response Procedures and a Spill
Response Log to be completed in the event of a spill.
6.4 Streets, roads, and public parking lots maintenance
The Town of Mooresville implements BMPs to reduce polluted stormwater runoff from
municipally-owned streets, roads, and public parking lots. The Town of Mooresville utilizes a
street sweeper to clean municipal streets and roads regularly and parking lots as needed. The
Stormwater Supervisor tracks the streets swept by the street sweeper using an ArcGIS map
which is updated monthly. The Sanitation Department hauled 174.64 tons of sediment and
debris from the decant area to the Iredell County Landfill in fiscal year 2019. The decant area is
primarily used by the street sweeper but is also used by various other departments such as
streets maintenance and buildings and grounds maintenance.
28
6.5 Operation and Maintenance (O&M) for municipally-owned or
maintained catch basins and conveyance systems
The stormwater maintenance staff is responsible for maintaining the municipally-owned and
maintained catch basins and conveyance systems. Stormwater maintenance staff conducts
routine maintenance as well as respond to maintenance requests from citizens. The Town of
Mooresville also issues contracts to outside contractors for improvements to existing
municipally owned drainage systems that cannot be handled by Town of Mooresville staff or are
part of a larger infrastructure improvement project.
The Town of Mooresville has two projects currently designed with plans to construct. The Town
is including one to two projects every year in the five-year Capital Improvement Plan for the
Stormwater Utility to improve the stormwater infrastructure in areas of Mooresville identified
as having drainage issues by the Drainage Master Plan completed by ESP in January 2016.
The Town is also implementing a “Find it Fix It” program within GIS that includes a criticality
analysis so that aging infrastructure can be replaced according to a condition rating. The
application is being created by the GIS Specialist and the program will be implemented by the
Stormwater Maintenance Supervisor. The Stormwater Maintenance Crew has begun analyzing
drainage features, and the upgrades will begin in fiscal year 2020.
6.6 Identify municipally owned or maintained structural stormwater
controls
An inventory of all municipally owned or maintained structural stormwater controls installed
for compliance with the Town of Mooresville Post Construction and Illicit Discharge and
Connection Ordinance will be maintained by the Stormwater Supervisor. The list of
municipally-owned stormwater control measures is updated periodically as new stormwater
control measures are constructed.
6.7 O&M for municipally-owned or maintained structural stormwater
controls
All municipally owned or maintained structural stormwater controls installed for compliance
with the Town of Mooresville Post Construction and Illicit Discharge and Connection Ordinance
will be operated and maintained in accordance with the guidelines in the NCDEQ Stormwater
Design Manual at the time of construction and according to the engineered plans for the control
measure. These structural stormwater control measures will be regularly inspected by the
Stormwater Supervisor, Engineering Technician, or their designee. Inspection and maintenance
records will be maintained by the Stormwater Supervisor.
6.8 Pesticide, Herbicide and Fertilizer Application Management
All employees who are required to apply pesticide, herbicide and/or fertilizer as part of their
regular duties possess the proper training and certifications to do so. Records of the necessary
training and certifications for each employee are maintained by the employee’s supervisor as
part of the employee’s personnel file.
29
6.9 Staff Training
Employees involved in implementing pollution prevention and good housekeeping practices are
to receive training from the Stormwater Program Specialist at least once per year, every year of
the permit cycle. Training will cover the stormwater pollution prevention and good
housekeeping practices utilized at that employee’s facility or stormwater pollution prevention
information to be used while performing regular duties. With the restructuring of the
stormwater department, the training will be performed by the Stormwater Maintenance
Supervisor and the Senior Engineer moving forward.
All new employees that attend new employee orientation receive stormwater training that
discusses general stormwater information such as the definition of stormwater, stormwater
pollution, and what employees can do to prevent or minimize stormwater pollution. This
training is conducted either through a training video or a handout. During fiscal year 2018, 50
new employees received this training. New employees based in the maintenance departments at
the Public Operations Services facility receive additional training in the form of a New Employee
checklist. The checklist describes specific actions employees can take to minimize or prevent
stormwater pollution at the Public Services Operations Center as well as at their work sites. This
checklist has been completed by 14 new employees in fiscal year 2019.
Flyers are typically distributed to managers of the Buildings and Grounds facility, the Water
Treatment Plant, the Wastewater Treatment Plant, Fire Department, and Public Service
Operations Center. These flyers show examples of common examples of illicit discharges, detail
why it is important to prevent illicit discharges, and how to report a potential illicit discharge.
6.10 Prevent or Minimize Contamination of Stormwater Runoff from
all areas used for Vehicle and Equipment Cleaning
Employees are encouraged to use the vehicle wash bay located in the Fleet Services Building at
the Public Services Operations Facility. This vehicle wash bay drains to an oil/water separator
and then to the sanitary sewer system. If the vehicle cannot be washed in the vehicle wash bay,
employees are encouraged to wash their vehicle at a commercial car wash facility.
Fire Station vehicles are washed per the instructions in the Fire Administration and Operations
Department Apparatus Washing General Order. This General Order requires that Mooresville
Fire Rescue limit the amount of water discharged during cleaning or washing of vehicles, use a
hose with a low GPM discharge of water, and not discharge chemical of any type into storm
drains or environment.
Table 12: Good Housekeeping and Pollution Prevention Program BMP Table
No. BMP Measurable Goal Implementation
Schedule
Frequency
6.1 Inventory of
municipally owned
or operated facilities
The permittee shall maintain a current inventory of
facilities and operations owned and operated by the
permittee with the potential for generating polluted
stormwater runoff.
Inventory is
maintained
throughout the permit
cycle.
Review annually and
update if needed.
6.2 Operation and
Maintenance (O&M)
for municipally
owned or operated
facilities
The permittee shall maintain and implement, evaluate
annually and update as necessary an Operation and
Maintenance (O&M) program for municipal owned
and operated facilities with the potential for
generating polluted stormwater runoff. The O&M
program shall specify the frequency of inspections and
routine maintenance requirements.
Implemented in first
year of permit cycle.
Review annually and
update if needed.
6.3 Spill Response
Procedures
The permittee shall have written spill response
procedures for municipal operations.
Implemented in first
year of permit cycle.
Review annually and
update if needed.
6.4 Streets, roads, and
public parking lots
maintenance
The permittee shall evaluate existing and new BMPs
annually that reduce polluted stormwater runoff from
municipally-owned streets, roads, and public parking
lots within their corporate limits. The permittee must
evaluate the effectiveness of these BMPs based on cost
and the estimated quantity of pollutants removed.
Implemented in first
year of permit cycle.
BMPs are evaluated
annually and updated
if needed.
6.5 Operation and
Maintenance (O&M)
for municipally-
owned or
maintained catch
basins and
conveyance systems
The permittee shall develop and implement an O&M
program for the stormwater sewer system including
catch basins and conveyance systems that it owns and
maintains.
Implemented in first
year of permit cycle.
Review annually and
update if needed.
31
6.6 Identify municipally
owned or
maintained
structural
stormwater controls
The permittee shall maintain a current inventory of
municipally-owned or operated structural stormwater
controls installed for compliance with the permittee’s
post-construction ordinance.
Implemented in first
year of permit cycle.
Reviewed and
updated as needed.
6.7 O&M for
municipally-owned
or maintained
structural
stormwater controls
The permittee shall maintain and implement an O&M
program for municipally-owned or maintained
structural stormwater controls installed for
compliance with the permittee’s post-construction
ordinance.
The O&M program shall specify the frequency of
inspections and routine maintenance requirements.
The permittee shall inspect and maintain municipally-
owned or maintained structural stormwater controls
in accordance with the schedule developed by
permittee. The permittee shall document inspections
and maintenance of all municipally-owned or
maintained structural stormwater controls.
Implemented in first
year of permit cycle.
Review annually and
update if needed.
6.8 Pesticide, Herbicide
and Fertilizer
Application
Management.
The permittee shall ensure municipal employees and
contractors are properly trained and all permits,
certifications, and other measures for applicators are
followed.
Implemented in first
year of permit cycle.
All training and
certifications are
continuously
maintained and
updated as needed.
6.9 Staff training The permittee shall implement an employee training
program for employees involved in implementing
pollution prevention and good housekeeping
practices.
Implemented in first
year of permit cycle.
Staff training for the
employees described
here will be
conducted at least
once per year.
6.10 Prevent or Minimize
Contamination of
Stormwater Runoff
from all areas used
for Vehicle and
Equipment Cleaning
The permittee shall describe and implement measures
to prevent or minimize contamination of the
stormwater runoff from all areas used for vehicle and
equipment cleaning.
Implemented in year
one of permit cycle.
Review annually and
update if needed.
32