NCS000240_Charlotte 2019 Annual Report_20191031

City of Charlotte
NPDES MS4 Permit Program

Stormwater
Management Program Plan

FY2019 Annual Report

Permit Number NCS000240

October 2019

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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Table of Contents

Section 1 Introduction ................................................................................................1

Section 2 Background Information ..........................................................................3

Section 3 Public Education and Outreach Program .............................................10

Section 4 Public Involvement and Participation Program ...................................25

Section 5 Illicit Discharge Detection and Elimination Program ..........................36

Section 6 Construction Site Stormwater Runoff Control Program.....................70

Section 7 Post-Construction Stormwater Management Program .......................76

Section 8 Pollution Prevention/Good Housekeeping Program.............................82

Section 9 Industrial Facilities Evaluation and Monitoring Program ..................99

Section 10 Water Quality Assessment and Monitoring Program ........................110

Section 11 Total Maximum Daily Load (TMDL) Program ..................................126

Acronyms Used in This Document:

BMP: Best Management Practice
CAR: Corrective Action Request
CATS: Charlotte Area Transit System
CDOT: Charlotte Department of Transportation
CFD: Charlotte Fire Department
CITY: City of Charlotte
CMANN: Continuous Monitoring Alert Notification Network
CMCSI: Charlotte-Mecklenburg Certified Site Inspector
CMPD: Charlotte-Mecklenburg Police Department
CMSWS: Charlotte-Mecklenburg Storm Water Services
CW: Charlotte Water Department (formerly Charlotte-Mecklenburg Utilities)
DEMLR: Division of Energy, Mining, and Land Resources
DO: Dissolved Oxygen
DWF: Dry Weather Flow
DWQ: Division of Water Quality
EPM-SWS: Engineering and Property Management Dept.-Storm Water Services Division
EPM-LD: Engineering and Property Management Dept.-Land Development Division
ETJ: Extra Territorial Jurisdiction
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FY: Fiscal Year
GIS: Geographic Information System
GSD-SWS: General Services Department-Storm Water Services Division
HDD: Horizontal Directional Drilling
IDDE: Illicit Discharge Detection and Elimination
IDEP: Illicit Discharge Elimination Program
MEP: Maximum Extent Practicable
MS4: Municipal Separate Storm Sewer System
MST: Microbial Source Tracking
NCDEQ: North Carolina Department of Environmental Quality
NCGA: North Carolina General Assembly
NOV: Notice of Violation
NPDES: National Pollutant Discharge Elimination System
O&M: Operation & Maintenance
PCSO: Post-Construction Stormwater Ordinance
QA/QC: Quality Assurance/Quality Control Program
RSWP : Regional Stormwater Partnership
SAP: Standard Administrative Procedure
SARA: Superfund Amendments and Reauthorization Act
SCM: Stormwater Control Measure
SOP: Standard Operating Procedure
SSO: Sanitary Sewer Overflow
SWAC: Stormwater Advisory Committee
SWMP: Stormwater Management Program Plan
SPPP: Stormwater Pollution Prevention Plan
TMDL: Total Maximum Daily Load
TP: Total Phosphorus
TSS: Total Suspended Solids
UNCC: University of North Carolina at Charlotte
USEPA: United States Environmental Protection Agency
WLA: Waste Load Allocation
WQ: Water Quality
WQS: Water Quality Standards
WTP: Water Treatment Plant
WWTP: Wastewater Treatment Plant
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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Section 1: Introduction

On November 1, 1993, the City of Charlotte began operating under National Pollutant Discharge
Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit Number
NCS000240. This permit has subsequently been renewed for a 5-year permit term on four
occasions and is currently in its 5th permit cycle effective October 10, 2018 through October 9,
2023.

This document provides the Annual Report for the Stormwater Management Program Plan
(SWMP) for FY2019 under the current permit term as required by Part III, paragraph 2 and Part
IV, paragraph B of the NPDES MS4 permit. The overall objective of this Annual Report is to
document activities conducted in support of the SWMP during FY2019 (July 1, 2018 to June 30,
2019) and discuss future proposed program activities and/or SWMP changes as necessary.

The City General Services Department-Storm Water Services Division (GSD-SWS) (formerly
Engineering and Property Management Department-Storm Water Services Division (EPM-
SWS)) is the primary agency responsible for managing the City’s NPDES MS4 permit, the MS4
system and the SWMP. The implementation of the requirements within the permit program and
SWMP are coordinated with other applicable City departments as necessary. In addition,
coordination is conducted with the NPDES MS4 permit programs for the jurisdictions in
Mecklenburg County adjacent to the City where appropriate and feasible. This coordination is
conducted to help ensure uniformity between the local NPDES MS4 stormwater permit programs
and jurisdictions. Mecklenburg County stormwater staff along with GSD-SWS staff collectively
form Charlotte-Mecklenburg Storm Water Services (CMSWS). City and County water quality
staff within CMSWS work together to accomplish many of the activities discussed in this report.

Included in this SWMP Annual Report are:

• Best management practices (BMPs) that are being used to fulfill the program
requirements;
• Frequency and status of each BMP;
• Measurable program goals and planned future activities;
• Implementation schedule;
• Responsible positions; and
• An assessment of program activities conducted during the reporting year.

Staff of GSD-SWS, under the direction of the City’s Surface Water Quality and Environmental
Permitting Program Manager, is responsible for the fulfillment of most of the activities discussed
in this SWMP. Exceptions to this include the City’s General Services Department-Land
Development Division (EPM-LD), which is the primary agency responsible for the Development
and Redevelopment Plan Review and Construction Site Stormwater Runoff Control programs
within the SWMP. In addition, the City’s Department of Transportation-Street Maintenance
Division and Solid Waste Services Department have responsibility for routine maintenance of
certain portions of the MS4, in coordination with GSD-SWS. Funding for the BMPs specified in
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the SWMP is provided by local stormwater utility fees, except where noted. The City’s SWMP
includes the following core permit programs:

1. Public Education and Outreach Program – This program provides the public and businesses
with information on general water quality, pollution prevention, and reporting problems, as
well as specialized information on various activities that have the potential to cause pollution
and harm water quality. This information is delivered through a wide range of methods
including print, web, radio, social media, television, presentations, and public events.

2. Public Involvement and Participation Program – This program provides the public and
businesses the opportunity to participate in various programs within the City’s SWMP.
Charlotte-Mecklenburg government maintains a Storm Water Advisory Committee (SWAC),
which is an appointed citizen panel to review and comment on the City’s and County’s
stormwater programs. In addition, public volunteer opportunities are available with
City/County programs such as Storm Drain Marking, Adopt-a-Stream, and the annual Big
Spring Clean event.

3. Illicit Discharge Detection and Elimination Program – This program is designed to protect
water quality by detecting and eliminating pollution sources such as improper sewage or
wastewater connections; illegal discharges of chemicals, paint, or oil; and accidental
discharges from sanitary sewer lines and vehicle accidents. As part of this program, the City
enforces the “City of Charlotte - Stormwater Pollution Control Ordinance,” which prohibits
the discharge of pollutants to the storm drainage system and receiving streams. The City
relies on reports from the public, various monitoring programs, and a wide range of other
activities to assist in identifying and eliminating these sources of pollution.

4. Construction Site Stormwater Runoff Control Program – This program maintains the City’s
delegated erosion and sediment control program to control sediments and other pollutants
from construction sites. As part of this program, the City enforces the “City of Charlotte -
Soil Erosion and Sedimentation Control Ordinance,” which requires suitable erosion control
on project sites. The City conducts routine inspections of construction sites and issues
violation notices and fines when necessary to ensure compliance with the ordinance.

5. Post-Construction Stormwater Management Program – This program is designed to control
the discharge of pollutants in stormwater runoff from new development and redevelopment
projects. As part of this program, the City enforces the “City of Charlotte – Post-
Construction Stormwater Ordinance,” which requires structural stormwater controls for
applicable new development and redevelopment projects as defined in the ordinance. The
program involves review and approval of project plans as well as site inspections and
maintenance activities to ensure that treatment practices are properly operated and
maintained.

6. Pollution Prevention/Good Housekeeping Program – This program focuses on ensuring that
City facilities and field operations are managed in a way that minimizes stormwater pollutant
discharges. Stormwater Pollution Prevention Plans and Spill Response Plans are maintained
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for applicable facilities that conduct activities with the potential for stormwater pollutant
discharges. The City conducts inspections and training sessions at these facilities to ensure
that requirements are being met. Field operations are evaluated for impacts on stormwater
quality and best management practices are developed and implemented in order to minimize
those impacts.

7. Industrial Facilities Evaluation and Monitoring Program – This program focuses on industrial
facilities that discharge stormwater to the City’s MS4 and receiving streams. Inspections are
conducted at these facilities on a rotational basis to review site operations and materials
handling practices. In addition, if the facility has a stormwater permit, it is reviewed to
ensure that permit conditions are adhered to.

8. Water Quality Assessment and Monitoring Program – This program maintains a water
quality monitoring plan designed to monitor major streams to determine water quality
conditions and assist in evaluating the effectiveness of various stormwater management
programs. The program is also used to assist in locating illicit discharges and connections
where possible.

9. Total Maximum Daily Load (TMDL) Program – This program maintains a TMDL watershed
plan designed to address applicable TMDL pollutants of concern by implementing best
management practices (BMPs) within the six minimum NPDES stormwater permit measures.
These BMPs are designed to reduce the TMDL pollutant of concern within the Permittee’s
assigned MS4 NPDES regulated waste load allocation to the maximum extent practicable
(MEP), and to the extent authorized by law.

Section 2: Background Information

2.1 Population Served

The SWMP covers the jurisdictional area, including the incorporated area and extra territorial
jurisdiction (ETJ), for the City, as applicable and defined by the NPDES MS4 permit. Table 2-1
provides the population for the City based on the 2000 and 2010 US census. This census data
was obtained from the following website of the US Census Bureau:

https://www.census.gov/quickfacts/table/PST045216/3712000,00

Table 2-1: Population and Growth Rate for the City of Charlotte.
2018 Population
(est.)
2010 Population 2000 Population Average Annual Percent
Change (2010-2018)
872,498 731,424 540,828 2.4%

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2.2 Growth Rate

Table 2-1 shows the population growth rate represented as an “Average Annual Percent
Change” for the City. This growth rate was calculated by dividing the overall percent change
between the 2010 and 2018 population by the 8-year interval.

2.3 Jurisdictional and MS4 Service Areas

The jurisdictional and MS4 service area for the City is provided in Table 2-2. The location of
this area within Mecklenburg County and corresponding watershed areas are provided in Figure
2-1. The source of this information is the City Planning Department, which updates
jurisdictional and geographical boundaries as annexations occur.

Table 2-2: Jurisdictional and MS4 Service Area for the City of Charlotte.
Incorporated Area (Sq. Miles) ETJ (Sq. Miles) Total Jurisdiction (Sq. Miles)
309 67 376

2.4 MS4 Conveyance System

The existing MS4 serving the City is composed of curbs, gutters, catch basins, culverts, pipes,
ditches, and outfalls that collect and convey stormwater for discharge to receiving streams.
Currently, there are an estimated 6,997 outfalls, 3,702 miles of storm drain pipe and 163,751
catch basins and drop inlets within the City’s MS4. Pipe systems are typically 15 inches or
larger in diameter and are designed for the ten-year storm event. Outlet energy is commonly
dissipated through the use of end-walls or flared end sections with riprap aprons. Although the
natural alignment of many receiving streams has been altered over the past century, many of the
stream banks remain mostly vegetated as a result of the City’s stormwater management
philosophies. Stream banks that were previously armored with riprap are currently allowed to
re-vegetate naturally, and new projects incorporate “soft” methods involving tree plantings and
other vegetation.

Maintenance and improvements to the MS4 system are funded by stormwater utility fees
collected within the City. Maintenance activities include cleaning inlets of debris and sediment,
maintaining channels to reduce erosion and maximize pollution reduction capabilities, and the
removal of blockages. Improvements to the MS4 system include solving infrastructure
problems, channel stabilization, safety improvements, stream habitat enhancement, water quality
enhancement, and resolving flooding problems associated with stormwater generated from
public streets.

2.5 Land Use Composition Estimates

The number of square miles and percentage of the MS4 service area under residential,
commercial, industrial and open space land use categories are provided in Table 2-3. These
percentages include the incorporated area and ETJ for the City. Figure 2-2 provides a map of
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these land use areas. Land use estimates are derived from Mecklenburg County land parcel
geographic information system (GIS) data (2019).

Table 2-3: Percentage of Land Uses in the City of Charlotte (including ETJ).
Land use Category Number of Square Miles % of Land Use within City of
Charlotte and ETJ
Residential 132 35
Commercial 56 15
Industrial 13 4
Open Space 98 26
Institutional 20 5
Transportation/Other 54 14
Lake Water/Open Space 3 1

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FIGURE 2-1
Charlotte Jurisdictional Area and Watersheds

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FIGURE 2-2

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2.6 Receiving Waters

Approximately two-thirds of the City of Charlotte land area drains west in the Catawba River
Basin while the remaining one-third drains east in the Yadkin-Pee Dee River Basin. MS4
receiving stream information by river basin is provided in Table 2-4 (Catawba) and Table 2-5
(Yadkin-Pee Dee). The information for the development of these tables was obtained from the
2018 Category 5 303(d) list. The location of the watershed areas in the City of Charlotte is
illustrated in Figure 2-1.

Table 2-4: Catawba River Basin Streams
Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Catawba River
(Mountain Island
Lake below
elevation 648)
11-(114) WS-IV, B, CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(117) WS-IV-CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(122) WS-IV, B, CA Impaired PCB Fish Tissue Advisory(5)
Catawba River
(Lake Wylie below
elevation 570)
11-(123.5) WS-IV, B Impaired PCB Fish Tissue Advisory(5)
Long Creek 11-120-(0.5) C Not Rated None
Long Creek 11-120-(2.5) WS-IV Not Rated None
Dixon Branch 11-120-1 C Not Rated None
McIntyre Creek 11-120-3-(1) C Not Rated None
McIntyre Creek 11-120-3-(2) WS-IV Not Rated None
Gutter Branch 11-120-4-(1) C Not Rated None
Gutter Branch 11-120-4-(2) WS-IV Not Rated None
Gum Branch 11-120-5 WS-IV Not Rated None
Paw Creek 11-124 C Not Rated None
Ticer Branch 11-124-1 C Not Rated None
Little Paw Creek 11-125 C Not Rated None
Beaverdam Creek 11-126 C Not Rated None
Stowe Branch 11-127 C Not Rated None
Porter Branch 11-133 C Not Rated None
Studman Branch 11-134 C Not Rated None
Sugar Creek Portions of 11-
137a,b,c
C Impaired Fecal Coliform (4t); Turbidity
(1t); Benthos Impairment(5)
Irwin Creek 11-137-1 C Impaired Dissolved Oxygen (1t); Fecal
Coliform (4t); Turbidity (4t);
Fish impairment
Stewart Creek 11-137-1-2 C Not Rated None
Taggart Creek 11-137-2 C Not Rated None
Coffey Creek 11-137-4 C Not Rated None
Kings Branch 11-137-6 C Not Rated None
McCullough Branch 11-137-7 C Impaired Benthos impairment
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Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Little Sugar Creek 11-137-8 C Impaired Copper(5) Mercury(5)
Turbidity(1t) Dissolved
Oxygen(1t); Fecal Coliform (4t);
Benthos impairment(4s)
Dairy Branch 11-137-8-1 C Not Rated None
Briar Creek 11-137-8-2 C Not Rated None
Edwards Branch 11-137-8-2-1 C Not Rated None
Little Hope Creek 11-137-8-3 C Not Rated None
McAlpine Creek 11-137-9 C Impaired Dissolved Oxygen(1t); Fecal
Coliform (4t);Turbidity (1t);
Benthos and fish impairment(5)
Campbell Creek 11-137-9-1 C Not Rated None
Irvins Creek 11-137-9-2 C Not Rated None
Fourmile Creek 11-137-9-4 C Not Rated None
Rocky Branch 11-137-9-4-1 C Not Rated None
McMullen Creek 11-137-9-5 C Impaired Benthos impairment(5)
Steele Creek 11-137-10 C Not Rated None**
Walker Branch 11-137-10-1 C Not Rated None
Polk Ditch 11-137-10-1-1 C Not Rated None
Clems Branch 11-137-11 C Not Rated None
Sixmile Creek 11-138-3 C Impaired Fish impairment(5)
Twelvemile Creek 11-138 C Impaired Dissolved Oxygen(5);
Copper(5); Turbidity(5); Fish
impairment(4s)
Flat Branch 11-138-3-2 C Not Rated None

Table 2-5: Yadkin-Pee Dee River Basin Streams
Receiving Stream
Name
Stream Segment
Index #
WQ
Classification
Use Support Rating WQ Issues
(303(d) Listing)
Mallard Creek 13-17-5b C Impaired Turbidity(5)
Clarks Creek 13-17-5-2 C Impaired Benthos impairment(5)
Doby Creek 13-17-5-3 C Impaired Benthos impairment(5)
Toby Creek 13-17-5-4 C Impaired Benthos impairment(5)
Stony Creek 13-17-5-5 C Impaired Benthos impairment(5)
Back Creek 13-17-7 C Impaired Benthos impairment(5)
Fuda Creek 13-17-7-1 C Not Rated None
Reedy Creek 13-17-8 C Impaired Benthos impairment(5)*
McKee Creek 13-17-8-4 C Impaired Fecal Coliform(4t); Benthos
impairment(5)
Use Support Ratings
(1t) No criteria exceeded but approved TMDL for parameter of interest
(4s) Impaired biological integrity with an identified Aquatic Life Standards Violation listed in Category 5
(4t) Designated use impaired with an approved TMDL
(5) Designated use impaired because of biological or ambient water quality standards violations and needing a
TMDL
** Listed as impaired on South Carolina 303(d) list for Fecal Coliform; TMDL developed May 2007.
Source: North Carolina’s 2018 303(d) Report

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Section 3: Public Education and Outreach Program

During the annual report period, the Public Education and Outreach Program distributed
educational materials to the community and conducted outreach activities focused on the impacts
of stormwater discharges on water bodies per the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Target audience and pollution sources;
• Outreach strategy;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

3.1 BMP Summary Table

Table 3-1 provides information concerning the BMPs implemented to fulfill the Public
Education and Outreach Program requirements.

Table 3-1: BMP Summary Table for the Public Education and Outreach Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Describe target
pollutants and
target pollutant
sources
Describe the target pollutants and target pollutant
sources the permittee’s public education program is
designed to address and why they are an issue.

X X X X X Water Quality
Program
Manager
Describe target
audiences
Describe the target audiences likely to have
significant stormwater impacts and why they were
selected.
X X X X X Water Quality
Program
Manager
Informational Web
Site
The permittee shall promote and maintain an
internet web site designed to convey the program’s
message.
X X X X X Water Quality
Program
Manager
Distribute public
education materials
to identified user
groups.
Distribute general stormwater educational material to
appropriate target groups as likely to have a
significant stormwater impact. Instead of developing
its own materials, the permittee may rely on state-
supplied Public Education and Outreach materials, as
available, when implementing its own program.
X X X X X Water Quality
Program
Manager
Promote and
maintain
Hotline/Help line
Promote and maintain a stormwater hotline/helpline. X X X X X Water Quality
Program
Manager
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.
X X X X X Water Quality
Program
Manager
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3.2 Target Pollutants and Sources

Table 3-2 provides the specific pollution sources targeted for the public education program as
well as a description as to why the sources were important for protecting water quality in the
City.

Table 3-2: Targeted Pollution Sources for the Public Education and Outreach Program.
Target
Pollutant
Pollution Source Issue
Bacteria Improper Waste Disposal
Sanitary Sewer Overflows
Pet Waste
Improper handling and disposal of wastes can result in the discharge
of a variety of pollutants to the storm drainage system, causing
increases in harmful bacteria. Discharges of food wastes such as
fats, oils, and greases to the sanitary sewer system can result in line
blockages that cause sanitary sewer overflows. Improper disposal
of pet waste can also cause discharges of bacteria to the storm
drainage system.
Sediment Construction Erosion
Stream Bank Erosion
Improper erosion control practices at construction sites can result in
sediment discharges to the storm drainage system. In addition,
uncontrolled volumes of stormwater runoff can cause scouring of
stream banks resulting in increased sediment volumes in streams.

3.3 Target Audience

The City’s public education and outreach program reaches a fairly broad representation of the
city’s population through various methods as explained in Section 3.4 with the goal of reaching
certain target audiences for particular reasons as explained below. The target audiences are
evaluated with each annual SWMP update and as part of the development of the SWMP
following permit renewal.

Multi-Family Residential Apartment Complexes: This target audience has been selected because
private sanitary sewer systems at apartment complexes are often not well-maintained and have
been found to be significant contributors to SSOs in the municipal sewer system due to improper
disposal of grease and other items by apartment residents.

Construction Industry: This target audience has been selected because it has the greatest
potential for affecting erosion and sedimentation control at construction sites, which can be a
significant contributor of sediment to the City’s waterways.

Commercial Sectors: Various commercial sectors are targeted for education each year due to the
significant negative impacts they can have on water quality by improperly handling and
disposing of wastes and practicing poor housekeeping at their facilities. Each year an evaluation
of previous pollution service requests, illicit discharges, and notices of violation is conducted to
determine which commercial sectors are commonly demonstrating non-compliance. Based on
that evaluation, education and outreach efforts are focused on particular sectors for a certain time
period, typically a fiscal year.

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School-aged Children: Children are very important when it comes to protecting surface waters.
They play in creeks and lakes and, therefore, want to protect them. They bring home what they
learn and encourage their parents to adopt positive behaviors for protecting water quality.
Lessons about surface water quality and stormwater pollution often fit into and enhance science
learning principles required by school curricula. Also, teaching children instills a sense of
responsibility for the environment that can carry forward and grow into their adult lives. For
these reasons, the City’s public education program focuses significant resources on teaching
students at various grade levels.

Pet Owners: Pet waste has been identified as a significant source of bacteria in surface waters,
so starting two years ago, CMSWS added pet owners as a target audience as one way to help
combat elevated fecal coliform counts in local creeks.

CMSWS has also been exploring ways to educate an even more diverse representation of our
population. A research and strategizing phase is underway to establish priorities and determine
effective methods for sharing water quality messages with various audiences and getting more of
them involved in volunteering and advocating for protection of water resources. A focus group
and stormwater learning session are planned for FY2020. These events will be marketed to a
diverse audience in order to gain awareness of our public education and involvement programs.

3.4 Stormwater Public Education and Outreach Program

The City’s Stormwater Public Education and Outreach Program provides water quality and
pollution prevention messages to educate residents and businesses about the ways they can help
protect water quality and get involved to help reduce stormwater pollution. The program
provides these messages through the following activities:

• Mass Media;
• Social Media;
• Public Hotline Promotion;
• School Presentations;
• Public Presentations and Events;
• Website; and
• Public Education Materials.

3.4.1 Mass Media

Significant resources were spent on providing water quality messages through mass media
channels because they are one of the most effective ways to reach adult audiences. The media
campaign focused on four main themes:

• Report Pollution;
• Volunteer;
• Flood Safety; and
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• Aging Infrastructure.

Media channels utilized to promote events and messages consisted of television, radio, website,
and print advertisements. A total of 876 television ads ran on local stations WBTV, WCNC and
WCCB. In addition, 48 total radio ads ran on WFAE 90.7 FM and 102.1 Latina Radio.
CMSWS also worked with WCCB to produce “Wilson’s World” segments that focused on the
importance of recognizing and reporting stormwater pollution. WCNC produced “Walk and
Talk” segments that were filmed at various sites and focused on sources of pollution and
volunteering. These segments are considered “added value” segments as they provided
additional media impressions at no additional cost.

Print media for the City’s program included the use of:

• Vehicle wraps;
• A parking garage banner; and
• Utility bill inserts.

3.4.2 Social Media

CMSWS continued efforts to build a social media presence this past year as more and more
people are receiving information through this media source. Four social media channels used by
CMSWS are shown in Table 3-3.

Table 3-3: Social Media Channels
Social Media Account Name Handle URL
Facebook CMSWS* @StormWaterCM https://www.facebook.com/StormWaterCM
Twitter CMSWS* @StormWaterCM https://twitter.com/StormWaterCM
Instagram CMSWS* @StormWaterCM https://www.instagram.com/stormwatercm/
YouTube CMSWS* N/A https://www.youtube.com/user/StormWaterServices
*Abbreviation for Charlotte-Mecklenburg Storm Water Services

CMSWS posted various videos and news stories on its YouTube channel. CMSWS also
provided more content, pictures and videos related to stormwater pollution, surface water
quality, pollution prevention and flood messages on Facebook, Twitter and Instagram and
boosted some posts to reach tens of thousands of users. There are 6,947 Facebook fans, a 2%
increase from last fiscal year. There are 766 Instagram followers, a 55% increase from last fiscal
year. There are 1,171 Twitter followers, a 23% increase from last year. There are 43 subscribers
to our YouTube page, a 16% increase from last fiscal year. Figure 3-1 shows a typical
Facebook post.

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During 2013, CMSWS launched a mobile application called
“Water Watchers” for citizens to report pollution. There
were 98 downloads of the application during FY2019,
making for a total of 1,817 downloads since the application
was first launched. This past year, there were 38 reports of
pollution using the application. The application allows users
to provide pictures of their concern and this feature has
proven very helpful to staff for providing follow-up services.

A variety of tools and events were used to promote the 311
reporting hotline and the Water Waters mobile application
including:

• Giving away promotional products such as magnets
and water bottles with 311 and Water Watcher
information;
• Providing information about reporting pollution on a
website;
• Working with local TV stations to produce news segments focused on reporting
pollution;
• Buying media time and airing a TV ad focused on reporting pollution;
• Designing and mailing the October utility bill insert, focused on volunteering and
reporting pollution, to approximately 255,300 residents; and
• Hanging a six-story banner on a parking garage across from a popular exit ramp off I-277
(Figure 3-2).

3.4.3 Public Hotline

The City, in cooperation with Mecklenburg County, operates
a joint customer service hotline to receive information about
a variety of concerns. Citizens can call 311 to report
pollution, flooding, and blockages to the drainage system as
well as request other City/County services. The 311 call
center is staffed to receive calls Monday through Friday from
7 am to 7 pm. Citizens can also submit requests for service
to 311 online anytime (24/7/365). All personnel from the
customer service group receive training on stormwater issues
and pollution to ensure calls are directed to appropriate
personnel and handled in a timely manner.

During this past fiscal year, a total of 8,934 calls were
received by 311 and referred to EPM-SWS and/or CMSWS.
Out of this total number, 553 resulted in service requests
related to surface water quality issues within the City. Of the
calls received, the highest number came from citizens.
Figure 3-1: Typical Facebook post
Figure 3-2: Typical Parking Garage
Banner
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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Calls from citizens as a group made up 62% of all calls, which was 47% higher than from the
next most frequent caller type, Mecklenburg County Storm Water Services staff, which
accounted for 15% of calls. This is important information for targeting education campaigns
related to pollution reporting. Table 3-4 provides information about the number and type of
callers that reported these issues.

Table 3-4: FY2019 Service Request Source Summary
Caller Type Number of Service Requests*
Public Citizen 342
Business 4
Charlotte Fire Department staff 24
Charlotte-Mecklenburg Police Department staff 0
Charlotte Storm Water Services staff 45
Charlotte Water staff 33
Mecklenburg County Storm Water Services staff 83
State – NCDEQ staff 5
Environmental Protection Agency/NRC 2
Other 15
TOTAL 553
* Source summary data includes all types of service requests within the City jurisdiction

An additional unique outreach tool for
publicizing pollution reporting was the
design and implementation of three
vehicle wraps (Figure 3-3). These
vehicle wraps have been placed on
three CMSWS vehicles and each
addressed a different subject – storm
drains lead to streams, smelly and
discolored streams, and mud pollution.
In addition to informing and
educating, these wraps encourage
residents to recognize and report
pollution by calling 311. The vehicle
wraps were completed toward the end
of FY2016 and have been driven since
then by CMSWS staff while
conducting illicit discharge investigations and service request responses. It is estimated that the
vehicle wraps will last about five years. Discussions about a fourth vehicle wrap took place
during FY2019 with plans to complete the wrap during FY2020.

3.4.4 School Presentations

During FY2019, CMSWS staff provided 117 school presentations to 2,872 students, grades K-
12, at 16 different schools. There were seven different programs available to the schools which
included:
Figure 3-3: Vehicle Wrap on a CMSWS vehicle
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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• Blue Planet;
• Common Water;
• Freddie the Fish;
• Enviroscape Model and Video;
• CMANN Demo and Power Point;
• Festival Table Demonstrations; and
• Career Day.

Two stormwater pollution videos (made by a former local
meteorologist) and the Enviroscape model were also available on
loan to schools upon their request. Figure 3-4 shows a
presentation using the Enviroscape model.

3.4.5 Public Presentations and Workshops

A variety of water quality presentations and workshops were available from CMSWS to the
public, interest groups, businesses and industrial facilities upon request. Each presentation,
while similar in nature, was also changed depending on the topic of interest and the audience
receiving the presentation. For example, this past year presentations were given about yard
waste, grease, pollution prevention, general water quality information, and landscaping tips.
Table 3-5 shows the public presentations that were provided by CMSWS during FY2019.

Table 3-5: FY2019 Public Presentations and Workshops
Date Event Name Number of Attendees
07/19/2018 County Floodplain Future Conditions Stakeholder Workshop 13
09/22/2018 Volunteer Monitoring Training 13
10/27/2018 City of Charlotte Civic Leadership Academy 36
12/06/2018 Stormwater Ordinance Training 151
01/12/2019 Citizen’s Water Academy 35
02/28/2019 Plaza Eastway Partners 43
03/23/2019 City of Charlotte Civic Leadership Academy 40
03/28/2019 Master Naturalist Training 22
04/04/2019 NC DEQ 55
04/10/2019 League of Women Voters 55
04/10/2019 League of Women Voters 30
04/10/2019 Providence Country Club HOA Meeting 25
04/11/2019 Kings Creek HOA Meeting 20
04/12/2019 Land Development Design Initiative 35
04/26/2019 Surveyors' Conference 55
05/23/2019 Master Naturalist Training 22
05/09/2019 Master Naturalist Training 22
05/25/2019 Catawba Riverkeeper Young Allies of the River Event 10
TOTAL 620
Figure 3-4: Enviroscape Model Presentation
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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3.4.6 Public Events

CMSWS staff participated in a variety of community events that were used to promote education
campaigns, give away promotional products, provide face-to-face education opportunities, and
provide formal presentations on water quality topics when appropriate. Table 3-6 shows the
public event participation during FY2019.

Table 3-6: FY2019 Public Event Participation
Date Conducted Event Name Number of Attendees Interacted With
08/17/2018 Mountain Island Lake Takeover 13
08/17/2018 Mountain Island Lake Takeover 3
09/22/2018 Charlotte Monarch Celebration 62
09/30/2018 Open Streets 124
10/04/2018 Meet & Eat CLTMeckGov 15
10/09/2018 Meet & Eat CLTMeckGov 15
10/18/2018 Meet & Eat CLTMeckGov 15
10/20/2018 Nature at Night 172
10/23/2018 Meet & Eat CLTMeckGov 15
10/25/2018 Meet & Eat CLTMeckGov 15
10/29/2018 Meet & Eat CLTMeckGov 15
11/08/2018 Air Quality Forum 25
11/30/2018 Charlotte Career Discovery Day 150
01/19/2019 MLK Day Parade 600
03/14/2019 Realtor Expo 400
03/15/2019 Weatherfest 350
03/14-15/2019 Passport to Stem 400
03/23/2019 National Puppy Day Fair 100
04/07/2019 Charlotte Checkers Pooch Party 500
04/10/2019 Air Quality Forum 40
04/18/2019 Ballantyne Earth Day 125
04/03/2019 UNCC Earth Day 100
04/06/2019 Paws in the Park 150
04/06/2019 Animal Control Pet Adoption 30
04/10/2019 Flood/Infrastructure Talk 40
04/13/2019 Char-Meck Rabies Clinic 30
04/26/2019 Earth Day Celebration at CMGC 130
04/27/2019 Pet Palooza 150
04/27/2019 Earth Jam 70
04/27/2019 Highland Mill Montessori Sustainability Fair 45
04/28/2019 Open Streets 150
05/09/2019 Hurricane Awareness

300
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Date Conducted Event Name Number of Attendees Interacted With
05/18/2019 Pints for Paws 40
TOTAL 3,970

3.4.7 Informational Website

A significant amount of resources were utilized to continue promoting and maintaining the
CMSWS website http://charlottenc.gov/StormWater (Figure 3-5). During September 2016, the
City launched a new, redesigned website. The new website provides an updated and enhanced
site that continues to be one of the best ways to provide the public with water quality
information. A vast amount of water quality information is provided on this website including,
but not limited to, pollution prevention fact sheets, activities and lessons for kids, volunteer
activities, sediment and erosion, regulations, data, maps, watershed information, and stormwater
projects. The number of website page views during FY2019 was 376,617; of these, the number
of unique page views (i.e. the number of times a page was accessed at least once during a
browsing session) was 158,480.

Figure 3-5: CMSWS Main Webpage
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3.4.8 Public Education Materials

This outreach mechanism was used to target specific
pollution sources associated with the public and
industrial/commercial facilities including lawn care
practices, handling of used oil and other automotive wastes,
housekeeping techniques, etc. Public outreach materials
were also used to increase public reporting of pollution
problems. Figure 3-6 shows an example of a brochure that
was distributed during responses to citizen service requests.
The following provides a list of topics for the written
outreach materials/handouts available to staff for
distribution during citizen requests for service:

• A Guide to Used Oil Recycling
• Scoop the Poop (proper handling of animal
waste)
• Only Rain Goes Down The Storm Drain – The
Citizen’s Guide to Pollution Prevention
• Volunteer Opportunities (updated for FY2019)
• A Brief Look at Charlotte-Mecklenburg Storm Water Services – Your Storm Water
Fees at Work
• Flow Free (proper disposal of grease from Charlotte Water Department)
• Household Hazardous Waste – What do you do with left over chemicals
• Mobile Detailer Best Management Practices
• Landscapers Best Management Practices
• Painters Best Management Practices
• Contractors Best Management Practices
• Carpet Cleaners Best Management Practices
• Vehicle Service Best Management Practices
• Food Service Best Management Practices
• Multi-family Best Management Practices
• Stone Cutting & Fabrication Industry Best Management Practices
• Concrete Industry Best Management Practices
• Commercial Property Management Best Management Practices
• Asphalt Sealing Best Management Practices
• Swimming Pool & Spa Industry Best Management Practices
• Dry Detention BMP Maintenance
• Rain Garden BMP Maintenance
• Sand Filter BMP Maintenance
• SW Wetland BMP Maintenance
• Wet Pond BMP Maintenance
Figure 3-6: Example of a Food
Services Best Management Practices
flyer distributed as part of service
requests
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• Environmental Notices – Disposal into the storm drain is against the law (available in
English, Spanish, Chinese, Vietnamese, and Korean)

3.4.8.1 Promotional Items

Promotional items were designed and distributed to complement outreach activities such as
group presentations, workshops and public events. All promotional items have the CMSWS
website and include other messages as space allows. Table 3-7 shows the promotional items
distributed during FY2019.

Table 3-7: FY2019 Promotional Items
Promotional Item Message
Ink Pens 6 rotating messages – report pollution, street to stream,
volunteer, turn around don’t drown, flooding can happen
anywhere, buy flood insurance
Umbrella Rain Gauge General stormwater information;
Stormwater.CharMeck.org
Flashlight General stormwater information;
Stormwater.CharMeck.org
Sunscreen General stormwater information;
Stormwater.CharMeck.org
Stormy’s Guide to Stormwater Coloring Book General stormwater information

3.4.8.2 Utility Bill Inserts

During FY2019, CMSWS included utility bill inserts in five of the monthly water/sewer utility
bills issued by Charlotte Water. The inserts focus on various topics which included volunteering,
water quality, flooding, CMSWS services and fee changes. The total number of stormwater
related utility bill inserts that were mailed during FY2019 was 1,330,520. Figure 3-7 shows a
typical utility bill insert that was mailed.

Figure 3-7: October 2018 Utility Bill Insert
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3.4.9 Regional Stormwater Partnership

The City serves on the Executive Committee of the Regional Stormwater Partnership of the
Carolinas (RSPC); a partnership which includes 18 municipalities throughout the region that
collaborating on meeting NPDES MS4 permit requirements, particularly education and outreach
initiatives. Formed in 2006 and originally comprised of professionals from six municipalities in
the Charlotte metropolitan area, the RSPC was developed as a forum for stormwater
professionals to work collaboratively on local stormwater issues. The RSPC has grown
significantly and obtained a registered 501(c)(3) organization designation during FY2019. The
RSPC provides an opportunity to leverage limited resources to fulfill common needs of the
partners.

During FY2019, the RSPC’s media campaign ran television, radio and web-based television
advertisements on WCCB CW, GCCB MeTV, HCCB Antenna TV and WCCB charlotte.com.
Television advertisements had a total of 8,966,574 media impressions (7,588,067 on regular
television and 1,378,459 on web-based television). WCCB ran a Carolina Insight story
highlighting stormwater infrastructure and two Rising Spotlight segments that discussed the
benefits of stormwater fees to homeowners and ways citizens can help keep waterways clean.
Furthermore, radio advertisements resulted in 444,000 radio media impressions.

In addition to these media endeavors, the RSPC held two Tech Talk Training workshops during
FY2019. The first was titled “GIS Mapping for Stormwater Applications” with 27 attendees and
the second was titled “Managing Stormwater Service Requests From Citizens” with 29
attendees. There were also 48 attendees from across the area to the Elected Officials Stormwater
Workshop. This workshop discussed stormwater basics, permit requirements, fees, infrastructure
and control measures. Also, during FY2019 there were 2,284 total visits to the RSPC website.
Of the website visits, 2,271 were new users and 344 were returning users.

3.4.10 Special Campaigns and Programs

Pet Waste Campaign: During FY2019, CMSWS delivered a
“Scoop the Poop” campaign during April 2019 that targeted
pet owners as a way to educate them about water quality
impacts from pet waste and the importance of cleaning it up.
This program included many components such as the
temporary flagging of deposits of dog waste (Figure 3-8) in
five parks and greenway locations along with signs that
provided information about harmful impacts to water quality
and human health. The campaign also included social media
consisting of five posts on Facebook, six posts on Instagram,
and six posts on Twitter. The social media campaign resulted
in 276 shares on Facebook, 123 reactions on Instagram, and
20 retweets on Twitter. The campaign also received local
media coverage which helped to raise awareness. One other
component of this program included having educational tables
Figure 3-8: Pet waste flag
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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at nine events including a Charlotte Checkers hockey game, Animal Control’s Pet Adoption
event, the Charlotte-Mecklenburg Rabies Clinic, and the Pet Palooza festival.

Stormy Mascot: Two years ago, CMSWS worked with a vendor to
create a “Stormy the Turtle” mascot which was based on previous
use of the Stormy character in various education and outreach
materials. Stormy has quickly become popular and appeared 14
times during FY2019 at various events including parades, photo
shoots, and festivals. CMSWS will continue to utilize Stormy in
this way to enhance the education and outreach program and has
plans to expand use of the character as part of the Storm Water
Services brand. Figure 3-9 shows Stormy riding in a city parade.

Creek Week: During FY2019, CMSWS participated for the first
time in a nationwide program called Creek Week in order to bring
more attention to the importance of creeks in the community.
CMSWS partnered with several other governmental and non-profit
organizations to develop and market events that tied into the overall
water quality theme. A logo was created and 20 events were held
from March 23 to March 30, 2019, examples including several story
times at libraries, a volunteer monitoring workshop, a stream
restoration educational walk, and various stream cleanups and educational workshops.

3.5 Measurable Goals/Planned Activities for Future Program Years

Table 3-8 describes the various Public Education and Outreach BMPs and the Measurable Goals
and Planned Activities for Future Program Years for each BMP by permit term year.

[THIS SPACE INTENTIONALLY BLANK]
Figure 3-9: Stormy mascot
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Table 3-8: BMP Measurable Goals for the Public Education and Outreach Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Describe target
pollutants and target
pollutant sources
Describe the target pollutants and target
pollutant sources the permittee’s public
education program is designed to address
and why they are an issue.

Identify target
pollution sources
utilizing
monitoring and
service request data
Review and update target pollution sources as necessary. (On-going, years 2 – 5+)
Describe target
audiences
Describe the target audiences likely to
have significant stormwater impacts and
why they were selected.
Identify target
audiences to adopt
desired water
quality
improvement
behaviors
Review and update target audiences as necessary. (On-going, years 2 – 5+)
Informational Web
Site
The permittee shall promote and
maintain an internet web site designed to
convey the program’s message.
Continue to maintain an informational website to provide program information to the public . (On-going,
years 1 – 5+)
Distribute public
education materials to
identified user groups.
Distribute general stormwater educational
material to appropriate target groups as
likely to have a significant stormwater
impact. Instead of developing its own
materials, the permittee may rely on state-
supplied Public Education and Outreach
materials, as available, when
implementing its own program.
Distribute educational materials at public events, workshops and presentations. (On-going, years 1 – 5+)
Promote and maintain
Hotline/Help line
Promote and maintain a stormwater
hotline/helpline.
Maintain a hotline that receives information from the public 24 hours a day. (On-going, years 1 – 5+)
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.
Continue to implement a plan to conduct education & outreach activities, including a media campaign, that
address target pollutants and audiences. (On-going, years 1 – 5+)
City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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3.6 Program Assessment

The overall Public Education and Outreach Program was successfully implemented during the
annual report period. Table 3-9 shows a summary of the various items and corresponding data
results for activities conducted under the program.

Table 3-9: Program Summary
PUBLIC EDUCATION PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Television advertising spots 876
Radio advertising spots 48
Social Media Followers/Subscribers1. 8,927
Social media posts 620
Social media responses 1,045
Water Watchers Mobile App Downloads 98
Public requests to stormwater hotline 8,934
Public requests to stw. hotline - WQ related 553
School presentations 117
Students educated at school presentations 2,872
Public presentations 18
Citizens educated at public presentations 620
Public events 33
Attendees at public events 3,970
Website page views 376,617
Website unique page views 158,480
Utility bill inserts 1,330,520
Flow Free (FOG) brochures distributed 2,231
Flow Free (FOG) presentations 12
Citizens educated on Flow Free program 1,640
1. Includes Facebook, Twitter, Instagram, and YouTube.

Overall: A combination of evaluation tools indicates that the City’s residents were successfully
being exposed to water quality education messages. It is always difficult to measure the true
impact of an education program, but continued program offerings and continued participation in
them indicate that messages were successfully provided through a diverse set of communication
channels. To be successful, CMSWS must build on its strengths and invest in new learning
opportunities that attract and motivate current, new and expanding audiences to actively engage
in activities that reduce the impacts of stormwater discharges to our surface waters. Staff has
developed plans and done research on potential methods that can be used to reach more diverse
audiences and expand the outreach program. The following provides more detail regarding some
of the numbers reported above.

Utility Bill Inserts: During FY2019 there was an increase in the number of utility bill inserts
from FY2018. This is due to the increase in distribution frequency.
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Public Events & Public Presentations: The number of events and presentations during FY2019
remained consistent.

School Presentations: The number of school presentations and the number of students educated
at school presentations increased for FY2019.

Website Page views: The number of website page views increased by 37% from the previous
fiscal year.

Social Media: CMSWS gained over 600 additional followers/subscribers to its social media
channels in FY2019

Section 4: Public Involvement and Participation Program

During the annual report period, the Public Involvement and Participation Program provided
opportunities for the public to participate in program development and implementation per the
SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Target audience;
• Volunteer opportunities;
• Public involvement mechanisms;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

4.1 BMP Summary Table

Table 4-1 provides information concerning the BMPs implemented to fulfill the Public
Involvement and Participation Program requirements.

Table 4-1: BMP Summary Table for the Public Involvement and Participation Program.
BMP

BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Volunteer
community
involvement
program
The permittee shall include and promote volunteer
opportunities designed to promote ongoing citizen
participation.

X X X X X Water Quality
Program
Manager
Establish a
Mechanism
for Public
involvement
The permittee shall provide and promote a mechanism
for public involvement that provides for input on
stormwater issues and the stormwater program.

X X X X X Stormwater
Division
Manager
Establish
Hotline/Help line
The permittee shall promote and maintain a
hotline/helpline for the purpose of public involvement
X X X X X Water Quality
Program
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and participation. Manager
Public Review
and Comment
The permittee shall make copies of their most recent
Stormwater Plans available for public review and
comment.
X X X X X Water Quality
Program
Manager
Public Notice Pursuant to 122.34 the permittee must, at a minimum,
comply with State, Tribal and local public notice
requirements when implementing a public
involvement/ participation program.
X X X X X Water Quality
Program
Manager

4.2 Volunteer Involvement Program

4.2.1 Target Audience

Public involvement is essential for ensuring the success of volunteer programs. The City
recognizes that without public involvement and support, little progress can be made toward
protecting and improving water quality in its streams. The primary target audience for volunteer
participation includes citizens between the ages of 25 and 55 due to their likelihood to become
involved in volunteer activities. There is a special emphasis to improve outreach to the African-
American and Hispanic populations and to increase the diversity of engaged citizens in general.
The following sub-sections discuss the volunteer programs used in the City’s overall Public
Involvement and Participation Program.

4.2.2 Storm Drain Marking Program

CMSWS continued to provide volunteers the
opportunity to help educate their community about
stormwater pollution through the Storm Drain
Marking program. This program enabled volunteers
to adhere vinyl printed markers (Figure 4-1) to
storm drains along streets they had selected in their
neighborhoods. CMSWS provided the decals,
adhesive, safety vests and information forms for completion by the groups. Following the
completion of storm drain marking activities, the groups submitted a report that included the
street names and number of drains that were marked, information concerning the condition of
storm drains, and whether any pollution problems were observed. CMSWS staff recorded the
storm drains that had been marked and ensured any issues reported received follow-up
investigation.

During FY2019, a total of 1,699 storm drains were marked by 352 volunteers for a combined
total of 1,019 volunteer hours for this program. Storm Drain Marking activities are tracked in
order to help determine programmatic gaps and where resources should be focused. Figure 4-2
shows Storm Drain Marking activities conducted during FY2019. The Storm Drain Marking
program is a well-organized and a relatively easy-to-manage activity for successfully including
citizens of all ages in stormwater education. By using a more focused approach and targeting
families and volunteer groups, the program saw an increase in participation.

Figure 4-1: Storm Drain Marker
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4.2.3 Adopt-A-Stream Program

The objective of this program is for volunteers to “adopt” segments of streams and agree to walk
them, picking up trash and reporting any pollution problems found along the way. The program
not only serves as a public involvement initiative, but it also allows for interaction and
observations of the City’s streams by its citizens, which can lead to the identification and
elimination of pollution sources.

The Adopt-A-Stream Program is designed in a way that empowers volunteers and provides them
with the necessary resources and educational information to assist in improving water quality
conditions in Charlotte-Mecklenburg streams. Individuals, families, organized groups, schools,
businesses, and industry “adopt” their favorite stream sections and were responsible for walking
these sections a minimum of two times per year. The current Adopt-A-Stream Program format
promotes a sense of community ownership and responsibility for local water resources.

During FY2019, a total of 101 groups of volunteers completed 190 stream cleanups under the
Adopt-A-Stream Program in the City. A total of 2,470 volunteers dedicated 6,345 hours to
picking up trash and reporting pollution in Charlotte-Mecklenburg streams. In addition,
volunteers removed approximately 23 tons of trash and debris. Adopt-A-Stream activities are
tracked in order to help determine programmatic gaps and where resources should be focused.
Figure 4-3 shows Adopt-A-Stream activities conducted during FY2019.

[THIS SPACE INTENTIONALLY BLANK]
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FIGURE 4-2

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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FIGURE 4-3

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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4.2.4 The Big Spring Clean

The Big Spring Clean is a one-day annual event promoted by CMSWS and the local organization
Keep Mecklenburg Beautiful. The event is held on a selected Saturday morning during the
spring season and typically provides seven to nine locations where citizens can go to remove
trash from local streams. These locations are conveniently situated at greenway trailheads with
ample parking and staffed by CMSWS to provide the volunteers with supplies, drinks and
snacks. CMSWS coordinates the logistics during this event and collects statistics such as
number of volunteers participating, volunteer hours, and the amount of trash removed at each
location. CMSWS also coordinates with the Mecklenburg County Parks and Recreation
Department to have the collected trash removed and properly disposed.

During FY2019, a total of 470 volunteers dedicated 1,880 hours to participating in the event and
removed 11 tons of trash from local waterways at six locations throughout the City. Figure 4-4
shows one of the promotional information items used for the event.

Figure 4-4: Big Spring Clean Utility Bill Insert

4.2.5 Volunteer Monitoring Program

During FY2019, the Volunteer Monitoring Program was expanded after discussion and analysis
led staff to determine that, based on the amount of time and staff resources expended, not enough
volunteers were being recruited for the existing program. Additionally, volunteers for the most
part were not being consistent with conducting monitoring and submitting data.

Two new activities called Visual Assessment and Snapshot Assessment were added for FY2019
as a result of the discussion and analysis. For the visual assessment program, volunteers are
trained in workshops about surface water quality, common stream pollutants, and how to identify
them. Trained individuals then select a stream site from among a list and agree to send in
qualitative, visual assessment forms every month for their assigned sites. One workshop was
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help during FY2019 with 13 attendees and the plan is to hold two workshops per year going
forward.

The snapshot assessment program is available to all
citizens without having to attend a workshop. Three
signs were posted along stream greenways that have a
number for people to text a picture and report the
condition of the stream. Staff then follow up on any
reports of pollution. Most of the pictures were of
trash, but there were several that were verified as
pollution sources. The snapshot program was a pilot
program conducted during FY2019 and staff are
currently evaluating it to determine the path forward.

Existing volunteer monitoring programs including
stream chemical monitoring and macroinvertebrate
monitoring will continue; however, rather than
holding weekend workshops to recruit volunteers as
was done previously, staff will train volunteer groups upon request. These programs tend to be
most popular among school groups.

During FY2019, there were 33 attendees at two Volunteer Monitoring workshops. A total of 144
trained volunteers dedicated 288 hours to participating in the Volunteer Monitoring program.
Figure 4-5 shows workshop attendees receiving training.

4.2.6 Second Saturday Volunteer Events

As a way to involve more citizens in volunteering to improve surface water quality, CMSWS
started “Second Saturday” events during FY2018. These events have taken place on the second
Saturday of every month and ran typically from 9 am to 12 noon at different locations that are
selected based on clean-up or maintenance needs. The events rotate between stream cleanups,
tree maintenance, and storm drain marking. To make it easy for citizens to participate,
registration is not required and the location of each event is made known to the public the month
prior to each event.

During FY2019, there were 423 volunteers who participated in nine Second Saturday events held
within the City including five stream clean-ups, two tree maintenance events, and two storm
drain marking events. This program has proven to be quite popular and successful mostly
because it allows citizens to participate in a one-time event as opposed to our other programs that
require a longer-term commitment. Plans are to continue the events through the next fiscal year
at a minimum.

4.3 Public Involvement Mechanism

The City of Charlotte and Mecklenburg County established a citizen Storm Water Advisory
Figure 4-5: Volunteer Monitoring workshop attendees
learning sampling techniques
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Committee (SWAC) during 1994 in conjunction with the development of their stormwater utility
(CMSWS).

SWAC members are nominated and subsequently appointed by the Mecklenburg Board of
County Commissioners, Charlotte City Council, Charlotte Mayor and Town Boards. SWAC
includes residents from the City of Charlotte. SWAC serves as the City’s stormwater
management citizen advisory panel for involving the public in the development and
implementation of the permit program. The SWAC reviews:

• Capital and operational programs;
• Appeals;
• Stormwater program policies;
• Long-range plans; and
• Budgets.

These reviews assist CMSWS in making recommendations and offering comments to the City
Council and the Board of County Commissioners on program matters and annual budgets. The
committee also adjudicates appeals for erosion control violations, pollution control violations,
service charges, and fee credits and adjustments. During FY2019, nine monthly SWAC
meetings were conducted with a combined total of 167 meeting attendees for the year.

4.4 Public Hotline

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to
receive information about a variety of concerns. Citizens can call 311 to report pollution,
flooding, and blockages to the drainage system as well as request other City/County services.
The 311-call center is staffed to receive calls Monday through Friday from 7 am to 7 pm.
Citizens can also submit requests for service to 311 online anytime (24/7/365). All personnel
from the customer service group receive training on stormwater issues and pollution to ensure
calls are directed to appropriate personnel and handled in a timely manner.

4.5 Public Review and Comment Opportunities

The City provided opportunities for public review and comment in the implementation of its
permit and SWMP Plan through website information. During FY2019, the draft FY2020 SWMP
was prepared and placed on the CMSWS website and a public notice was published in the local
newspaper to notify the public of the opportunity to provide comments on the SWMP.

4.6 Public Notice

A public notice was published in the main local newspaper concerning the City’s FY2020
SWMP. The draft plan was placed on the CMSWS website and made available for review. No
comments were received by the City.

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4.7 Measurable Goals/Planned Activities for Future Program Years

Table 4-2 describes the various Public Involvement and Participation Program BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

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Table 4-2: BMP Measurable Goals for the Public Involvement and Participation Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Volunteer
community
involvement
program
The permittee shall include and
promote volunteer opportunities
designed to promote ongoing citizen
participation.

Continue to maintain a public involvement and participation program that outlines campaigns and tools to
encourage public involvement. (On-going, years 1 – 5+)
Establish a
Mechanism
for Public
involvement
The permittee shall provide and
promote a mechanism for public
involvement that provides for input on
stormwater issues and the stormwater
program.
Maintain the Stormwater Advisory Committee. (On-going, years 1 – 5+)
Establish
Hotline/Help line
The permittee shall promote and
maintain a hotline/helpline for the
purpose of public involvement and
participation.
Maintain a hotline that receives information from the public 24 hours a day. (On-going, years 1 – 5+)
Public Review and
Comment
The permittee shall make copies of
their most recent Stormwater Plans
available for public review and
comment.
Maintain an informational website which includes the SWMP available for review and comment. (On-going,
years 1 – 5+)
Public Notice Pursuant to 122.34 the permittee must,
at a minimum, comply with State,
Tribal and local public notice
requirements when implementing a
public involvement/ participation
program.
Comply with State and local public notice requirements when making major changes to the stormwater program
and/or applying for permit renewals. (On-going, as needed)
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4.8 Program Assessment

The Public Involvement and Participation Program was successfully implemented during the
annual report period. In addition, although not currently listed as a required BMP in the City’s
NPDES MS4 permit or SWMP, the City coordinates with Mecklenburg County to sponsor an
annual Big Spring Clean event. Data on this additional program is included in the table below
for reference. Table 4-3 shows a summary of the various items and corresponding results for
activities conducted under the program.

Table 4-3: Program Summary
PUBLIC INVOLVEMENT PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Storm drains marked 1,699
Storm Drain Marking volunteers 352
Storm Drain Marking volunteer hours 1,019
Adopt-A-Stream groups 101
Adopt-A-Stream clean-ups conducted 190
Adopt-A-Stream volunteers 2,470
Adopt-A-Stream volunteer hours 6,345
Adopt-A-Stream trash removed (tons) 23
Adopt-A-Stream miles cleaned 136
Big Spring Clean volunteers 470
Big Spring Clean volunteer hours 1,880
Big Spring Clean trash removed (tons) 11
Big Spring Clean stream miles cleaned 16
Trees planted by volunteers 486
Adopt-A-Street volunteer hours 6,487
Adopt-A-Street bags of trash collected 2,563
Adopt-A-Street bags of recyclables collected 483
Adopt-A-Street miles cleaned 460
Volunteer Monitoring training sessions 2
Volunteer Monitoring participants trained 33
Volunteer Monitoring total participants 144
Volunteer Monitoring participant hours 288
Volunteer Monitoring samples collected 32
Volunteer Monitoring visual observations 102
SWAC meetings conducted 9
Persons attending SWAC meetings 167

The City’s Public Involvement and Participation Program provides a combination of activities
that allows residents to be involved in the City’s stormwater management program and the
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opportunity to comment on components of the City’s plan to meet NPDES MS4 permit
requirements. The following provides an overview of the program’s effectiveness:

Storm Drain Marking Program: The number of volunteers and storm drains marked increased
during FY2019.

Adopt-A-Stream Program: The number of volunteers and volunteer hours increased during
FY2019. One-time stream clean-ups are becoming more popular with groups versus signing up
to conduct two clean-ups per year, which has traditionally been required.

Big Spring Clean: The number of volunteers for the Big Spring Clean more than doubled for
FY2019.

Volunteer Monitoring Program: The number of volunteer monitoring participants and hours
dedicated to volunteer monitoring increased slightly during FY2019.

SWAC meetings: Meeting frequency and participation continues to be maintained. These
meetings continue to be a highly effective method for involving the public in policy decisions
related to the overall stormwater program.

Public Hotline/ Helpline: The 311 hotline continued to be a successful tool for allowing the
public to report water pollution problems. Use of the Water Watchers app by the public as a
reporting tool has declined over the past couple years. The reason for this decline is theorized to
be that so many smartphone apps are now available that people are deleting the ones they do not
use very often. CMSWS is currently evaluating whether to continue with the Water Watchers
app and working with City Corporate Communications to transition to an app that allows citizens
to report all municipal issues including stormwater pollution.

Section 5: Illicit Discharge Detection and Elimination (IDDE) Program

During the annual report period, staff implemented the Illicit Discharge Detection and
Elimination (IDDE) program to identify and eliminate sources of pollution to the MS4 per the
SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

5.1 BMP Summary Table

Table 5-1 provides information concerning the BMPs implemented to fulfill the IDDE Program
requirements.
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Table 5-1: BMP Summary Table for the Illicit Discharge Detection and Elimination Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Maintain
appropriate legal
authorities
Maintain adequate ordinances or other legal
authorities to prohibit illicit connections and
discharges and enforce the approved IDDE Program.
X X X X X Water Quality
Program
Manager
Maintain a Storm
Sewer System Base
Map
The permittee shall maintain a current map showing
major outfalls and receiving streams.

X X X X X Water Quality
Program
Manager
Inspection /
detection program
to detect dry
weather flows at
MS4 outfalls
Maintain written procedures and/or Standard
Operating Procedures (SOPs) for detecting and
tracing the sources of illicit discharges and for
removing the sources or reporting the sources to the
State to be properly permitted. Written procedures
and/or SOPs shall specify a timeframe for monitoring
and how many outfalls and the areas that are to be
targeted for inspections.
X X X X X Water Quality
Program
Manager
Employee Training Conduct training for appropriate municipal staff on
detecting and reporting illicit connections and
discharges.
X X X X X Water Quality
Program
Manager
Maintain a public
reporting
mechanism
Maintain and publicize reporting mechanism for the
public to report illicit connections and discharges.
Establish citizen request response procedures.
X X X X X Water Quality
Program
Manager
Documentation The permittee shall document the date of
investigations, any enforcement action(s) or
remediation that occurred.
X X X X X Water Quality
Program
Manager

5.2 Ordinance Administration and Enforcement

The City adopted its Stormwater Pollution Control Ordinance on January 30, 1995 for the initial
NPDES MS4 permit term. The ordinance was subsequently updated and amended on March 22,
2004 and most recently on June 9, 2008. This ordinance continued to be implemented as part of
the NPDES MS4 permit program and SWMP. All procedures and guidelines for proper
administration and enforcement of the ordinance were reviewed and updated, as necessary.
These procedures and guidelines along with all other information relevant to the IDDE program
were included in the IDDE Manual.

Currently, the ordinance has four sections that are considered prohibitions (violations) for which
the issuance of a Notice of Violation (NOV) and/or other enforcement remedies is authorized.
Those sections are:

• Section 18-80(a) Illicit Discharges and Disposals;
• Section 18-80(b) Illicit Connections;
• Section 18-80(c) Accidental Discharges; and
• Section 18-80(d) Obstruction.

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Cumulatively from FY1995 through FY2019, a total of 1,331 violations of the ordinance have
been discovered resulting in the issuance of an NOV. Historically, the majority of these
violations have occurred under Section 18-80(a) with many of these being either for the improper
disposal of washwater or wastewater, or the illicit discharge of sewage.

During FY2019, a total of 125 violations of the ordinance were discovered resulting in the
issuance of an NOV. Of these, 11 also resulted in the issuance of a civil penalty assessment to
the violator. The number of violations observed for each ordinance section was:

• Section 18-80(a) Illicit Discharges and Disposals (120);
• Section 18-80(b) Illicit Connections (1);
• Section 18-80(c) Accidental Discharges (4); and
• Section 18-80(d) Obstruction (0).

The violations are further categorized based on the type of material discharged. Table 5-2 shows
the number of NOVs issued per material category per each month during FY2019.

Table 5-2: NOVs Issued per Material Category per Month

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Figure 5-1 shows the graphical representation of these material categories for which NOVs were
issued, and Figure 5-2 shows the number of NOVs issued per month during FY2019.

Figure 5-1: NOVs issued by material category.

Figure 5-2: NOVs issued per month.
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5.3 Stormwater System Inventory and Storm System Base Map

The City collects stormwater system inventory using a Stream Walk Program and a Stormwater
Inventory Program.

Stream Walk Program: This program focuses on CMSWS staff walking stream channels to
inspect outfalls, identify and collect data on new outfalls, and to identify dry weather flows.
Stream walks are scheduled in every sub-basin within the City at least one time every five years.
All Stream Walk Program data is transferred to the City’s Inventory Program annually.

During FY2018, a new five-year stream-walk plan was developed based on an analysis of the
previous five-year stream-walk program and the following conclusions:

• The high priority basins (history of poor water quality and illicit discharges) that were
walked every other year did not result in a significant number of new outfalls or illicit
discharges as compared to the other basins.
• The large number of miles walked in the high priority basins each year made it difficult
for staff to walk different basins if the need was identified.

The analysis led to changes in protocol to develop the new five-year stream walk plan that
groups the sub-basins by watershed in both the City and Mecklenburg County. The same
number of miles will be walked each year as previously, but the plan will also allow for a 20-
mile per year reserve that can be used for walking in any basin(s) when the need is identified.
Figure 5-3 shows the new five-year (FY2018 – FY2022) stream walk plan and Figure 5-4
shows the sub-basins that were walked during FY2019 within the McAlpine watershed.

Stormwater Inventory Program: This program verifies the outfall data collected by the Stream
Walk Program and collects additional data on other components of the stormwater system such
as catch basins, inlets, pipes, etc. The Inventory Program also collects stormwater infrastructure
data from the analysis of new development and municipal project areas received from the EPM-
SWS Design and Engineering Teams, and EPM’s Engineering Services and Land Development
divisions. All inventory data receives QA/QC and is converted digitally into GIS.

During FY2019, the following activities were conducted as part of Stream Walk Program:

• One watershed and 21 sub-basins covering 218 stream miles were walked and assessed;
• Added to the system inventory were 340 new outfalls; and
• Of the previously inventoried outfalls, 684 received inventory QA/QC.

During FY2019, the following activities were conducted as part of the Inventory Program:

• Of the MS4 area, 31 sub-basins and 24.6 square miles were inventoried for drainage
infrastructure. The inventory collection included: 285 miles of pipe; 138 miles of open
drainage; 41,167 stormwater features; and 349 municipal and new private development
projects.
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FIGURE 5-3

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FIGURE 5-4

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5.4 Illicit Discharge Detection and Elimination Program

5.4.1 Outfall Inspection and Dry Weather Flow Detection

Each year, outfalls are inspected for physical condition, the presence of dry weather flows
(DWFs), and illicit discharges. These inspections are primarily conducted during Stream Walks
and Hot Spot Investigations. Standard Operating Procedures for these activities are documented
in the NPDES MS4 IDDE Manual and reviewed and updated annually. Outfall inspections also
occur during service request and field investigations, municipal facility inspections, and
industrial facility inspections.

Stream Walk Program: As discussed in Section 5.3, this program involves CMSWS staff
walking the stream channel to inspect outfalls, sample DWFs, and document a variety of other
water quality related problems. Various reasons make it impossible to sample all DWFs
including very low flows (seepage), frozen water, etc. DWFs are sampled for physical
parameters (temperature, conductivity, pH, etc.), fecal coliform and total phosphorus. Fecal
coliform samples are also collected from areas where tributaries enter the channel being walked
and staff document stream blockages, areas of severe stream bank erosion, wetlands and new
stream reference reaches as they observe them.

During FY2019, the Stream Walk program produced the following results:

• Inspection of 1,024 outfalls;
• Detection of 267 DWFs at outfalls;
• Sampling of 93 of the 267 DWFs, which included 61 fecal coliform and 32 total
phosphorous samples;
• Analysis of 428 data points for fecal coliform and total phosphorous including sampling
of DWFs, flows during follow up investigations, and points where tributaries meet the
main stream;
• Investigation of 14 fecal coliform sample locations where the analysis result exceeded the
program action limit threshold; and
• Discovery of ten illicit discharges, 42 stream blockages, 30 areas of severe stream bank
erosion, and 48 other potential issues.

In addition, CMSWS staff inspected 213 outfalls as part of service request response, field
investigations, municipal facilities inspections, and industrial facility inspections.

5.4.2 Water Quality Monitoring

Water quality in-stream monitoring is used to identify problems and to track long and short-term
water quality trends. The two main monitoring programs used to support IDDE efforts are the
Fixed Interval and CMANN (Continuous Monitoring and Alert Notification Network) stream
monitoring programs. The Fixed Interval program conducts in-stream monitoring for various
chemical and physical parameters on a monthly basis and is discussed further in Section 10. The
CMANN program is an automated monitoring network that takes in-stream readings every 60
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minutes at monitoring sites for dissolved oxygen, temperature, pH, conductivity, and turbidity.
This parameter data is transferred to a database in real-time using cellular telemetry. Figure 5-5
shows the monitoring locations for this program.

“Watch” and “Action” levels for the monitoring parameters are used as part of the program to
determine when follow-up investigations are needed to address potential problems. The Watch
and Action levels are based on state water quality standards and historical local data for the
chemical and physical parameters. Exceedance of these levels will trigger a field investigation.

During FY2019, eight follow-up investigations were conducted as a result of watch and action
level exceedances detected by the Fixed Interval and CMANN stream monitoring programs.
These investigations resulted in the discovery of several water quality issues (water main breaks,
elevated turbidity levels, etc.) and three illicit discharges.

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FIGURE 5-5

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5.4.3 Illicit Discharge Elimination Program (IDEP)

The IDEP program is a sub-set of the overall IDDE program. This program conducts illicit
discharge detection, investigation and outreach activities in areas where data and staff experience
indicate the greatest likelihood for the occurrence of illicit discharges and/or poor housekeeping
practices. This past fiscal year, the IDEP program conducted the following activities:

• Hot Spot Investigations
• Multi-Family Residential Community Inspections
• Business Corridor Runs
• Industry-wide Investigations
• Pet Waste Flagging Campaign

Standard operating procedures have been developed to describe all IDEP program activities and
protocols which are reviewed annually.

Hot Spot Investigations: This activity conducts investigations in areas where analysis of
monitoring and/or service request data indicates a priority problem area. These investigations
require more experienced staff with extensive field investigation expertise to locate sources of
pollution in these priority areas. The field investigations typically include use of one or more of
the following techniques:

• Establishing a temporary CMANN monitoring station;
• Collecting grab samples in tributaries, pipes, and manholes;
• Dye testing businesses and homes;
• Monitoring suspect facilities;
• Smoke testing sanitary sewers; and/or
• Conducting pipe video inspections.

During previous years, Hot Spot investigations included the identification of a priority sub-basin
in which IDEP staff would walk the sub-basin and sample minor outfalls to locate pollution
sources and/or problems. From analysis of past program data, this method was determined to be
largely unsuccessful. As a result, during FY2019 four priority areas were instead determined
based on the methodology described above. These areas received Hot Spot investigations as
summarized below:

• Worthington Drainage Basin, Irwin Creek Watershed: During FY2018, bacteria levels in
Irwin Creek led staff to the Worthington drainage basin stormwater outfall where
intermittent discharges of sewage were evident and extensive sampling of manholes was
unsuccessful in identifying the location of a source(s). During FY2019, IDEP staff
worked with Charlotte Water staff, CMSWS pipe video staff and a private contractor to
conduct smoke testing, dye testing, and pipe video in various areas of the Worthington
drainage basin. This work led to the identification and correction of a leaking sewer pipe
and the dramatic reduction of sewage indicators at the Worthington drainage basin
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stormwater outfall. Follow-up investigations are planned for FY2020 to ensure that there
are no other sewage sources in this drainage area.

• Little Sugar Creek at 4th Street, Little Sugar Creek Watershed: During FY2018, high
bacteria results in the Little Sugar Creek watershed led staff to establish a new CMANN
monitoring station at a major stormwater outfall located on Little Sugar Creek at 4th
Street. This outfall discharges stormwater from a portion of the Charlotte central
business district. During FY2019, CMSWS staff sampled multiple manholes within this
drainage area and conducted pipe video inspections, which identified a cross-connection
between the sanitary sewer and stormwater systems. This connection was subsequently
eliminated and resulted in the dramatic reduction of DWFs and bacteria counts at the
stormwater outfall.

• Sink Holes at 12th Street Fleet Management, Irwin Creek Watershed: During FY2018,
sink holes in the parking area of the City’s Fleet Management Shop revealed sewage
sources in a tributary to Irwin Creek. During FY2019, CMSWS staff worked with
Charlotte Water to smoke test public sewer lines and conducted multiple dye tests at
various facilities in the area. A private sewer lateral was identified to be a source of the
sewage and staff worked with the facility to ensure elimination of the discharge.

• Amtrak Creekside, Little Sugar Creek Watershed: During a construction project to
replace aging stormwater infrastructure, strong sewage odors were noticed. CMSWS
staff conducted multiple efforts to evaluate this problem. The efforts included sampling
at stormwater manholes and stream tributaries and dye testing and smoke testing of three
municipal sanitary sewer lines in the area. Results of these efforts pointed to an existing
building within a commercial redevelopment project called Amtrak Creekside. Pipe
video inspection of a private sewer lateral serving the building revealed a blockage that
was causing a sewage discharge to the storm drain system. CMSWS staff worked with
the property owner to ensure the private lateral was
monitored and cleared of blockage until the building was
permanently vacated. The private sewer lateral will be
replaced as part of the redevelopment project.

Multi-Family Residential Community Inspections: This activity
conducts inspections of privately maintained multi-family
residential sewer systems to look for signs of problems with the
operation and maintenance of these systems. CMSWS inspectors
check system manholes and clean outs looking for signs of current
or potential overflows and pipe blockages and/or evidence of
previous problems such as limed areas, sewage solids on ground,
etc. The multi-family systems selected are based on their sewer
overflow history. During FY2019, 11 multi-family inspections
were conducted with no illicit discharges noted. Figure 5-6
shows a sewage discharge from a multi-family system.
Figure 5-6: Overflowing manhole at
a multi-family residential system
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Business Corridor Runs: This activity conducts windshield surveys along streets throughout the
City that have a high concentration of commercial businesses where illicit discharges and poor
housekeeping practices may potentially be found. The surveys allow staff to quickly survey
these business areas for the presence of practices such as dumping of washwater, mobile pressure
washing, motor oil discharges from automotive maintenance practices, and cooking oil/grease
discharges at restaurants. Staff will also inspect storm drain inlets and outfalls in these areas
when illicit discharges are suspected.

During FY2019, business corridor efforts included the inspection of 2,457 businesses and 358
catch basins. This led to the discovery of 12 illicit discharges resulting in the issuance of NOVs
and the distribution of four environmental notices for poor housekeeping practices.

Industry-wide Investigations: This activity involves staff focusing on a specific industry or
commercial business sector for inspections. During FY2019, the beer brewing industry was
targeted due to the potential for illicit discharge from the improper storage of process waste.
Staff prepared a list of breweries within the City and conducted inspections at two facilities
resulting in the discovery of poor housekeeping practices. Staff worked with the breweries to
assist in developing BMPs to reduce pollution potential from their facilities. Staff will conduct
additional inspections at breweries during FY2020.

Pet Waste Flagging Campaign: This effort began during FY2018 and has continued with the
goal of reducing the amount of improperly disposed pet waste. Greenways and park areas
known for pet waste problems were targeted and IDEP staff used small flags (i.e. utility marking
flags) with messages of the environmental and health risks resulting from improper disposal of
pet waste, specifically marking and drawing attention to visible obvious deposits of canine
waste. Staff also used chalk to mark deposits in areas where the soil was too compact for the use
of flags. Each week throughout April, staff visited these areas to mark pet waste deposits and
educate residents. These activities were also combined with social media/on-line outreach,
attendance at community events for pet owners, and interviews with local TV personalities and
on-line media staff. During FY2019, staff marked 306 deposits of pet waste and engaged with
25 residents during the flagging campaign.

Figure 5-7 shows the locations where IDEP activities occurred during FY2019 and Figure 5-8
shows the business corridors evaluated during FY2019.

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FIGURE 5-7

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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FIGURE 5-8

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5.5 Employee IDDE Training and Education

Employee IDDE Training and Education involves training municipal employees about the
detection of illicit connections and discharges, and the various methods for reporting suspected
pollution problems. Training is provided through a combination of the following methods:

• Staff meeting presentations;
• On-site, in-person training sessions;
• On-line training module; and
• Other methods such as posters, fliers, light box displays, emails, websites, and displays
and information at employee gatherings

Staff meeting presentations: This method involves providing a ten-minute presentation at a
regularly scheduled staff meeting to provide information about identifying common illicit
discharges in the community, the importance of reporting them, and the various methods that can
be used to report them. Staff meeting presentations can also include workshops when internal
staff attends and at least ten minutes are dedicated to providing information about identifying and
reporting illicit discharges.

The following staff presentations were provided during FY2019 reaching 264 employees:

• Housing and Neighborhood Services Department - Code Enforcement Staff Retreat
• EPM - Stormwater Division Pipe Video Crew staff meeting
• Charlotte Department of Transportation - Utility Stakeholders Meeting
• Charlotte Planning, Design and Development Staff Meeting

On-site, in-person training sessions: This method uses specially scheduled classroom style
sessions that occur annually and include a power point presentation and video covering:

• Common illicit discharges in the community;
• How to detect them when they enter surface water;
• The importance of reporting them and the various ways they can report them as well as
more in-depth pollution prevention information related to their facility and field work;
• Stormwater Pollution Prevention Plans;
• Spill prevention and response (Figure 5-9);
• Pollution prevention and the role of the employees to protect the environment and set an
example for the community; and
• Results from recent facility inspections.

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Presentations are given by CMSWS staff at
all facilities except those owned by the
Charlotte Area Transit System (CATS) and
the Airport. The presentations provided by
CMSWS and CATS were customized to
reflect field work pollution prevention
practices related to the audiences’ daily work,
the most recent facility inspection and a three-
minute Spill Response Video which covered
the importance of spill response.

Presentations provided by the Airport were
targeted at employees as well as contractors
who are then responsible for training their own staff.

On-line training module: This method provides a power point presentation and video that is very
similar to the on-site, in-person training session version, but allows field or shift-work staff to
take the training at times more convenient for them.

Other methods: Additional methods used during FY2019 to reach internal staff with messages of
report pollution included:

• Participation in the City’s Earth Day event;
• Piloting a Rewards Program; and
• The use of Report Pollution Posters.

Participation in the City’s Earth Day event included EPM-SWS staff attendance at the City
employee Earth Day event held in the courtyard of the Charlotte-Mecklenburg Government
Center. This event provided the opportunity to engage approximately 130 employees with a
table-top display about stormwater pollution and reporting, promotional products, and a hands-
on demonstration.

The Rewards Program was a pilot program
conducted during FY2019 over a four-month period
that targeted EPM-SWS staff only. The program
began by e-mailing all EPM-SWS staff to announce
that rewards would be provided to anyone who
reported stormwater pollution and the report
resulted in a valid investigation. The rewards that
staff could choose from included coffee cups, water
bottles and stuffed animals (Stormy the Turtle with
Report Pollution messaging). Each month, an e-
mail was sent to EPM-SWS staff highlighting the
reports received and rewards provided. Over the
course of the four-month period, 19 staff members
Figure 5-9: Spill Response Video used for Training
Figure 5-10: Rewards Program advertisement
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reported potential pollution problems and received
rewards. Figure 5-10 shows an advertisement for the
rewards program.

The Report Pollution Poster involved the development
of a poster (Figure 5-11) and posting it at 47 locations
across City departments. Locations included break
rooms, copy rooms, and bulletin boards for all floors
of the Charlotte Mecklenburg Government Center and
old City Hall and at four field operation facilities.

5.5.1 Commercial Sector Education and Outreach

Certain businesses can be frequent sources of illicit
discharges and connections. To improve compliance
and reduce the number and severity of illicit
discharges coming from the commercial sector, the
City proactively provides education to certain
commercial business sectors each year.

During FY2019, CMSWS provided 16 two-page best
practices publications and guidance documents for
commercial sectors available on-line. CMSWS also
distributed these publications as part of service requests, mailings, training sessions and public
events. The following provides a complete list of the commercial sector publications that have
been developed:

• Landscape Maintenance • Concrete
• Pressure Washers • Horizontal Directional Drilling
• Mobile Vehicle Detailers • Painting
• Food Service Industry • Swimming Pools and Spas
• Managers of Apartments and Condos • Rooftop Work
• Asphalt Sealing • Stone Cutting
• Carpet Cleaning • Vehicle and Equipment Repair
• Commercial Property Management • Municipal Contractors

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Figure 5-11: Report Pollution Poster
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Food Service Industry: During
FY2019, CMSWS updated the
format for the Food Services best
practices publication to reduce
wording and focus on highlighting
the most important information for
prevention and response to illicit
discharges relevant to the industry.
The intent of this effort was to
increase the likelihood that this
publication would be used as a
poster for employee education
(Figure 5-12) and that the
publication will be read when
distributed during service requests.

This new format will also be used
as a template to update the other 15
best practices publications over
time. Multiple social media posts
and a Utility Bill Insert also
highlighted reporting leaking grease
bins (the most common illicit
discharge from this industry) and
provided a link to this updated
publication.

Swimming Pools and Spas: During FY2019,
CMSWS staff implemented an outreach plan
specific to the Swimming Pool and Spa Industry.
Staff first met with 15 commercial pool operators
at an annual meeting held by the Mecklenburg
County Environmental Health division to discuss
the best way to reach this sector of contractors
most effectively. As a result of the discussion
with operators, it was decided that outreach
efforts should focus on helping residents who
have pools to understand the best practices that
contractors should employ when servicing the
resident’s pool and/or spa. This effort was
conducted by developing a GIS coverage and
associated mailing list of all 8,300 residents with
pools located within the City of Charlotte. A post
card (Figure 5-13) and webpage were developed
Figure 5-13: Pool and Spa Post Card
Figure 5-12: Food Service poster
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to highlight the best practices for pool and spa owners and contractors. The postcard was mailed
to all 8,300 residents with pools on the mailing list.

5.5.2 Sanitary Sewer Overflows and Septic Systems

CMSWS works with two separate City/County departments to reduce sources of bacteria from
sanitary sewer overflows (SSOs) and septic systems: Charlotte Water (CW) and Mecklenburg
County Groundwater and Wastewater Services.

Sanitary Sewer Overflows(SSOs): CW is
the department responsible for operating
the municipal water supply and sanitary
sewer systems in the City. During
FY2019, there were 162 SSOs (total
volume of 4,434,266 gallons) from the
municipal sanitary sewer system. This is a
decrease in volume of ~78.5% from
FY2018.

It is important to note that the largest
overflow during FY2019 was caused by a
large tree falling on a wastewater pipe
which accounted for 59.5% of the total
volume spilled. Heavy rain events and
two tropical storms also caused large
overflows. Together these large events accounted for 97% of the total gallons spilled for the
year. Figure 5-14 summarizes the causes for these SSOs.

In addition, the number of spills per 100 miles of pipe system continued to show a steady
decline. For example, during FY2007 there were 10.8 SSOs per 100 miles of pipe system
compared to 3.7 SSOs per 100 miles during FY2019. This represents a 65.7% decrease over the
11-year period.

The City works to decrease SSOs in four main ways:

• Infrastructure maintenance and inspections;
• Commercial/restaurant/ industrial inspections;
• Multi-family residential outreach; and
• The Flow Free (Fats, Oils, and Grease) education campaign.

Infrastructure maintenance and inspection: CW implements a number of infrastructure
maintenance and inspection programs designed to reduce inflow and infiltration and sanitary
sewer losses. During FY2019, the following was accomplished:

• 20.1 miles of sanitary sewer pipe were relined;
Figure 5-14: FY2019 SSOs by cause
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• 8,906 sanitary sewer system manholes were inspected;
• 21.5 miles of wastewater pipe and 301 manholes were rehabilitated, repaired or replaced;
• 259 miles of sanitary sewer pipe were treated with root control chemicals;
• 971 miles of sanitary sewer pipe were cleaned;
• 248 sewer service connections were replaced;
• 83 miles of sanitary sewer line rights of way were cleared to maintain access for
inspection and maintenance;
• 172 miles of sewer line were inspected using closed circuit television recording; and
• 161 preventative maintenance tasks were conducted at the system’s 82 lift stations.

Commercial/restaurant/industrial inspections: During FY2019, CW performed the following
activities:

• Inspections of grease handling facilities at 5,449 food service establishments and
restaurants;
• 200 inspections of industrial pretreatment facilities;
• 39 NOVs were issued for violation of the City’s Sewer Use Ordinance (includes NOVs
issued to commercial and industrial facilities);
• 231 Notices of Deficiency (NOD) were sent to businesses;
• 44 grease traps were installed by businesses to fulfill NOD requirements;
• CW continued to provide educational information about proper disposal of pipe-blocking
items (Flow Free education);
• Inspectors mailed information to 1,236 customers near SSO sites and handed out
information to 2,231 customers at multi-family communities.
• 1,640 adults and children received presentations from staff;
• Staff continued to distribute door-hangers to maintenance personnel and property
managers of multi-family communities.
• CW created the Pipes Hate Wipes campaign to educate residents about the impact
flushable wipes have on the collection system and wastewater treatment plants. The
campaign primarily used videos and paid Facebook/Instagram advertisements and
YouTube Pre-roll.

A copy of Charlotte Water’s full FY2019 Wastewater Performance Report can be found here:
https://charlottenc.gov/Water/Documents/FY19%20Wastewater%20Report.pdf.

Multi-Family Residential Program: Since 2009, CMSWS has been working with CW to prevent
SSOs through education and inspection. From FY2010 through FY2018, the following was
accomplished:

• Over 350 informational letters were mailed to multi-family residential communities to
advise them of private sewer system requirements;
• Six workshops were provided, educating over 190 personnel about the operation &
maintenance (O&M) requirements for private sanitary sewer systems;
• Over 200 multi-family residential communities were inspected; and
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• Assistance was provided to 187 multi-family residential communities to complete an
O&M plan.

During the fall of 2018 (FY2019), CMSWS and CW met four times to comprehensively evaluate
the previous years of effort and the accomplishments related to the program. The results of the
evaluation led the two groups to determine that, for FY2019, the number of inspections of
private and public sewer systems should be increased and concentrated in prioritized areas where
the greatest number of SSOs had occurred within the past five years. The groups would also
work together to implement new ways of educating multi-family facility managers and their
residents about proper O&M practices. In addition, the groups would meet with NCDEQ
officials to understand how they can all work together to promote and enforce the program.

During FY2019, the CMSWS part of the program accomplished the following:

• 48 multi-family residential communities received informational letters;
• 26 O&M plans were submitted by multi-family facilities;
• 48 inspections were conducted at multi-family facilities and eight of the inspections
revealed problems in the private sanitary sewer system such as built up debris, missing
sewer clean-out caps, and evidence of recent overflows.
• Ten NOVs for violation of the Stormwater Pollution Control Ordinance were issued to
multi-family facilities for SSOs from their private sanitary sewer system that resulted in
an illicit discharge to the storm drainage system and/or surface waters.

Figure 5-15 shows the locations of the 48 multi-family facilities inspected by CMSWS during
FY2019.

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FIGURE 5-15

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Septic Systems: CMSWS works with Mecklenburg County Groundwater and Wastewater
Services each year to monitor discharges from septic systems. The County conducts the
permitting, inspections, education and enforcement activities related to septic systems and
CMSWS reviews this information to look for potential impacts on surface waters.

During FY2019, a total of 67 failing septic systems were discovered in the City, 13 were repaired
and 54 were connected to the municipal sanitary sewer system. These failures were not localized
to any particular watershed area. No follow-up field investigations or monitoring were deemed
necessary by CMSWS during the fiscal year. Figure 5-16 shows locations of septic system
failure activities during FY2019.

5.6 Public Reporting Hotline

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to
receive information about a variety of concerns. Citizens can dial 311 to report pollution,
flooding, and blockages to the drainage system as well as request other City/County services.
The 311 call center is staffed and open Monday through Friday from 7 am to 7 pm to receive
calls. Citizens can also submit requests for service to 311 on-line anytime (24/7/365). The City
promotes this hotline throughout all of the activities provided as part of the Stormwater Public
Education and Outreach Program. EPM-Storm Water Services works with the 311 customer
service group to make sure calls are directed to appropriate personnel and/or are handled in a
timely manner. The hotline/help line is discussed further in sub-section 3.4.3.

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FIGURE 5-16

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5.6.1 Public Education and Outreach

The City continued to maintain a public education and outreach program to inform businesses,
industries and the public about illicit discharges and improper waste disposal and how they
impact the environment. This education and outreach program included instructions regarding
the proper method for reporting illicit discharges. The primary education and outreach
mechanisms used were:

• Media campaign (included mass media and social media);
• Website;
• Utility bill inserts;
• Handouts/brochures;
• Public events; and
• In-person education and training sessions.

Handouts and brochures were reviewed and revised as necessary and were distributed during the
performance of facility inspections, when responding to citizen requests for service, and at event
displays. These public education and outreach items for the IDDE Program were included as a
component of the Public Education and Outreach Program described in more detail in Section 3.

5.7 Service Requests and Documentation

Responding to service requests continued to be one of the most important methods for detecting
and eliminating illicit discharges and connections in the City. During FY2019, a total of 553
service requests related to surface water pollution were investigated. These included 31
emergency response situations that typically involve oil, fuel, or other hazardous material
releases, as discussed further in sub-section 8.5. All service requests were investigated and
follow-up was provided to ensure efforts were taken to remediate the discharge and restore
impacted areas. Enforcement activities were implemented as appropriate and are described in
more detail in sub-section 5.2. Table 5-3 shows the caller type and corresponding number of
service requests received.

Table 5-3: FY2019 Service Request Source Summary
Caller Type Number of Service Requests*
Public Citizen 342
Business 4
Charlotte Fire Department staff 24
Charlotte-Mecklenburg Police Department staff 0
Charlotte Storm Water Services staff 45
Charlotte Water staff 33
Mecklenburg County Storm Water Services staff 83
State – NCDEQ staff 5
Environmental Protection Agency/NRC 2
Other 15
TOTAL 553
* Source summary data includes all types of service requests within the City jurisdiction
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The City utilizes the Cityworks® database platform to maintain electronic and hard copy files
documenting all IDDE activities including citizen requests. These were tracked from the original
call for service, through investigations and applicable enforcement actions, and until final
remedial work was completed.

The database stores information such as reporting party contact information, date, time,
investigator information, pollutant category, investigation reports, monitoring data, photos and
attachments, applicable enforcement information, and geo-location.

During FY2019, the following watershed areas recorded the highest number of activities
including service requests, emergency responses, and NOVs:

• Little Sugar Creek;
• Briar Creek;
• Irwin Creek; and
• Stewart Creek.

Figure 5-17 shows a summary report of a service request activity, and Figure 5-18 shows the
FY2019 spatial distribution of service requests within the City.

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FIGURE 5-17

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City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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FIGURE 5-18

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5.8 Measurable Goals/Planned Activities for Future Program Years

Table 5-4 describes the various Illicit Discharge Detection and Elimination program
BMPs and the Measurable Goals and Planned Activities for Future Program Years for each BMP
by permit term year.

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Table 5-4: BMP Measurable Goals for the Illicit Discharge Detection and Elimination Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Maintain
appropriate legal
authorities
Maintain adequate ordinances or other
legal authorities to prohibit illicit
connections and discharges and
enforce the approved IDDE Program.
Continue administration and enforcement of the Pollution Control Ordinance and IDDE Program. (On-going,
years 1 – 5+)
Maintain a Storm
Sewer System Base
Map
The permittee shall maintain a current
map showing major outfalls and
receiving streams.

Continue to maintain storm sewer map in GIS and update as necessary to show additional outfalls. (On-going,
years 1 – 5+)
Inspection /
detection program
to detect dry
weather flows at
MS4 outfalls
Maintain written procedures and/or
Standard Operating Procedures (SOPs)
for detecting and tracing the sources of
illicit discharges and for removing the
sources or reporting the sources to the
State to be properly permitted. Written
procedures and/or SOPs shall specify a
timeframe for monitoring and how
many outfalls and the areas that are to
be targeted for inspections.
Maintain and update SOPs for detecting and eliminating illicit discharges and performing outfall inspections.
Roughly 20% of identified outfalls will be inspected each year, with extra emphasis on hotspot areas. (On-going,
years 1 – 5+)
Employee Training Conduct training for appropriate
municipal staff on detecting and
reporting illicit connections and
discharges.
Maintain an employee training program and conduct employee training. (On-going, years 1 – 5+)
Maintain a public
reporting
mechanism
Maintain and publicize reporting
mechanism for the public to report
illicit connections and discharges.
Establish citizen request response
procedures.
Maintain the public reporting hotline and publicize through the media outreach campaign.
(On-going, years 1 – 5+)
Documentation The permittee shall document the date
of investigations, any enforcement
action(s) or remediation that occurred.
Continue to maintain IDDE program records and databases to accurately document the activities in the program.
(On-going, years 1 – 5+)
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5.9 Program Assessment

The overall Illicit Discharge Detection and Elimination Program was successfully implemented
during the annual report period. Table 5-5 shows a summary of the various items and
corresponding data results for activities conducted under the program.

Table 5-5: Program Summary
IDDE PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Stream miles assessed 218
Watershed sub-basins assessed 21
Outfalls inspected/inventoried/updated 1,236
Dry weather flows detected 267
Dry weather flows sampled 61
Citizen service requests responded to 553
Emergency spills responded to 31
Illicit discharges detected/corrected 371
Ordinance violations/NOVs issued 125
Penalty enforcements issued 11
Municipal employee IDDE training sessions 86
Municipal employees trained on IDDE 1,993
SSOs detected/referred 76
Sanitary sewer use ordinance NOVs issued 39
Sanitary sewer system pretreatment
inspections 200
Sanitary sewer system FOG inspections 5,449
Sanitary sewer system pipe miles cleaned 971
Sanitary sewer system ROW miles cleared 83
Sanitary sewer system miles re-lined 20.1
Sanitary sewer system manholes inspected 8,906
Sanitary sewer system lift stations
maintained 82
Sanitary sewer system overflows corrected 162
Pet waste deposits flagged 306
Pet waste receptacles provided 100
Septic system failures detected/corrected 67

The following is clarification of certain numbers provided in Table 5-5:

• Outfalls inspected/inventoried/updated includes outfalls from stream-walks, IDEP
program, and municipal and industrial inspections;
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• Dry weather flows detected and sampled includes those from outfalls inventoried during
Streamwalks;
• Illicit discharges detected includes those found during service requests (102) (including
emergency response and private sewage system discharges), IDEP (12), septic system
failures (67), stream-walks (10), water quality monitoring (3), and municipal (3) and
industrial inspections (12);
• Employee IDDE training sessions includes the number of classroom sessions, number of
facilities assigned the on-line training module, and employee training/outreach events
• Number of employees trained on IDDE includes all those trained during the sessions
described in the bulleted item above; and
• Number of SSOs includes those from both municipal and private systems.

As part of a continual evaluation process, CMSWS started a new initiative during FY2018 called
“IDDE Think Tank Meetings.” These meetings are used to evaluate the effectiveness of current
activities, identify new methods for identifying illicit discharges, and coordination of program
implementation. The following highlights some of the results from FY2019:

• Discussion of various initiatives to evaluate new technology for potential use in
identifying illicit discharges;
• Installation of ammonia probes at two locations to assist in identifying illicit discharges;
• Targeting beer brewery facilities;
• Targeting stormwater outfall inspections and sampling in neighborhoods with old
infrastructure;
• Continuation of the Pet Waste Flagging Campaign; and
• Increased focus on ambient flow and oxygen dynamics to potentially identify illicit
discharges.

The annual evaluation of the IDDE program also resulted in the following conclusions:

• GIS analysis of illicit discharges continues to show that most of these occur in highly
urbanized areas of the City. As such, the IDEP program will continue to be implemented
as support for the Stream-Walk program in priority basins;
• Education targeting pool and spa contractors will continue to build upon efforts this past
year;
• Targeting multi-family residential communities with education and inspections will
continue as these communities are a significant source of SSOs. CMSWS and CW will
continue to coordinate their efforts with each other and the State to improve effectiveness
of the program in FY2020;
• The public and internal staff continue to be the number one source of illicit discharge
reporting. The public reporting hotline, public education campaigns, internal education
and service request response will continue to be a staple for IDDE efforts;
• The Cityworks® database and use of smart phones for field data entry continues to
facilitate data entry, storage and query capabilities; and
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• The City’s vast and varied surface and stormwater monitoring program continues to be an
important resource for detecting illicit discharges and understanding long term trends in
water quality.

Section 6: Construction Site Stormwater Runoff Control Program

During the annual report period, the Construction Site Stormwater Runoff Control program
conducted site evaluations and enforced the local ordinance per the SWMP. The following sub-
sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

6.1 BMP Summary Table

Table 6-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Construction Site Stormwater Runoff Control Program. Funding for the BMPs in this section
is covered by local land development fees.

Table 6-1: BMP Summary Table for the Construction Site Stormwater Runoff Control Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Erosion and
Sediment Control
Program
The permittee has a delegated Sediment and
Erosion Control Program. As such, to the extent
authorized by law, the permittee is responsible for
compliance with the Sediment Pollution Control
Act of 1973 and Chapter 4 of Title 15A of the
North Carolina Administrative Code. The
delegated Sediment and Erosion Control Program
effectively meets the maximum extent practicable
(MEP) standard for Construction Site Runoff
Controls by permitting and controlling
development activities disturbing one or more
acres of land surface and those activities less than
one acre that are part of a larger common plan of
development as authorized under the Sediment
Pollution Control Act of 1973 and Chapter 4 of
Title 15A of the North Carolina Administrative
Code.
X X X X X Land
Development
Division
Manager
Develop
requirements for
construction site
operators
The NCG010000 permit establishes requirements
for construction site operators to control waste
such as discarded building materials, concrete
truck washout, chemicals, litter, and sanitary waste
at the construction site that may cause adverse
impacts to water quality, as part of the Permittee’s
X X X X X Land
Development
Division
Manager
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delegated program.
Public information
and reporting
The permittee shall provide and promote a means
for the public to notify the appropriate authorities
of observed erosion and sedimentation problems.
The permittee may implement a plan promoting
the existence of the NCDEQ, Division of Land
Resources “Stop Mud” hotline to meet the
requirements of this paragraph.
X X X X X Land
Development
Division
Manager
Plan reviews Implement construction site plan reviews as part of
the Permittee’s delegated program. For new
development and redevelopment projects to be
built within the permittee’s planning jurisdiction
by entities with eminent domain authority, the
permittee shall, to the maximum extent
practicable, coordinate the approval of the
construction site runoff control with the Division
of Land Resources of NCDEQ.
X X X X X Land
Development
Division
Manager

6.2 Erosion and Sediment Control Program

The City has operated a soil erosion and sediment control program locally since 1983, which is
currently a delegated Sediment and Erosion Control Program under authority granted by the
North Carolina Sedimentation Commission. As such, to the extent authorized by law, the City is
responsible for compliance with the Sediment Pollution Control Act of 1973 and Chapter 4 of
Title 15A of the North Carolina Administrative Code. During FY2019 the program served to
provide added protection to surface water resources in the City by ensuring that builders and
developers followed minimum standards for erosion and sediment control per State and Local
guidelines.

The “City of Charlotte-Soil Erosion and Sedimentation Control Ordinance,” amended and
adopted by council in 2008, serves as the backbone of the program. Ordinance highlights
include the following requirements:

• An approved soil erosion and sediment control plan for all qualifying land disturbances
of one acre or greater;
• An on-site preconstruction conference prior to the installation of any measures or
commencement of land disturbing activities;
• Issuance of a grading permit prior to the commencement of land disturbing activities;
• Weekly inspections at a minimum by the permit holder of erosion control measures
depending on sensitivity of receiving waters;
• Inspections by the permit holder of measures after any rainfall event totaling one-half
inch or greater;
• Documentation and maintenance of inspection records performed by the permit holder;
• Maintenance and optimal performance of all measures for the life of the project
performed by the permit holder;
• Requirements for controls to minimize erosion and prevent offsite sedimentation; and
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• Enhanced local erosion control requirements which were deemed essential for protecting
sensitive environmental features and were developed based on years of field experience
and observations.

The ordinance also provides EPM-LD staff with the following:

• Authority to issue NOVs for practices and/or impacts contravening ordinance
requirements; and
• Authority to issue civil penalties for violations of the Soil Erosion & Sedimentation
Control Ordinance.

6.2.1 Inspection Procedures

All construction sites that required a preconstruction meeting and approved plan were logged,
filed and placed in the queue for regular inspections. Staff goals were to visit and inspect every
logged site utilizing a scheduled inspection process. Sites that generated citizen complaints, had
a history of non-compliance, or were in close proximity to a critical area (e.g., sites adjacent to
water features or within a water-supply watershed) were considered a priority for additional
inspections and follow-up.

6.3 Construction Site Requirements

The program requires that all land disturbing activities comply with ordinance requirements for
controlling erosion and sediment on site. As an additional requirement, and in compliance with
NPDES regulations, all construction sites one acre or greater must have an approved soil erosion
and sediment control plan designed specifically for the site as required by NPDES General
Permit NCG010000 for Construction Related Activities. After plan approval, responsible parties
were required to follow the approved plan for all phases of construction, as well as maintain
measures in a state that ensured optimal performance throughout the duration of construction
activities and until final site stabilization was achieved. Regular self-inspections were a
requirement for optimal performance and all sites were required to employ a competent person to
conduct inspections and maintain logbooks and documentation for ready-review by local or state
representatives.

6.4 Public Information and Reporting

The City’s Erosion Control Program maintains a website to assist with the dissemination of
information to the development community and the public. In addition, the City maintains an
information/help line and citizens can dial 311 to report erosion, pollution, flooding, and
blockages to the drainage system as well as request other City/County services. The 311 call
center is staffed and open Monday through Friday from 7 am to 7 pm to receive calls. Citizens
can also submit requests for service to 311 on-line anytime (24/7/365). The help line serves as a
clearinghouse for general information and ensures that erosion control related issues are directed
to appropriate EPM-LD staff for resolution. Information sharing and inter-department training
between City and County agencies also ensures that problems, questions, or requests for
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information from the public can be processed and resolved quickly. The City’s erosion control
webpage can be viewed at:
http://charlottenc.gov/ld/Pages/default.aspx

6.4.1 Education and Training Materials

The City maintained an education and training program for developers, contractors and other
interested parties within the region. Although program policies and procedures dictated that self-
inspectors maintain a level of competence necessary to ensure compliance, the City took a
proactive role in providing local training and handout materials for affected parties.

In a cooperative effort with Mecklenburg County, the City maintained the Charlotte-
Mecklenburg Certified Site Inspector (CMCSI) training program, which to date has provided
training to over 6,180 individuals since its inception in 2003. CMCSI is a full day training
course that provides attendees with an understanding of the importance of water resources to our
community, the local and state requirements for controlling construction site runoff, principles of
erosion control, common site problems, recommendations for conducting effective inspections,
and a certification exam. The CMCSI program was offered three times in classroom sessions
during FY2019 as well as being offered as an online option throughout the year for
renewal/recertification purposes. This effort provided training to 349 people (Table 6-2).

In addition to the CMCSI education program, all developers, builders and responsible parties
received handouts and materials at preconstruction meetings and at other times as necessary to
explain ordinance requirements, minimum standards and other relevant information for the
financially responsible party and/or site operators.

Table 6-2: CMCSI Training Program Dates and Attendance – FY2019
Date Registered Attended
10/22/2018 136 98
01/23/2019 132 117
05/09/2019 98 74
Online training option N/A 60
Totals 366 349

6.5 Plan Reviews

All land disturbing activity one acre or greater was required to obtain plan approval of the soil
erosion and sediment control plan prior to scheduling a preconstruction conference. Erosion
control plans submitted by the applicants were reviewed and approved by EPM-LD erosion
control staff.

All EPM-LD erosion control staff obtained and/or maintained their status as a Certified
Professional in Erosion and Sediment Control (CPESC) which provided accreditation for plan
review. Plans were reviewed for suitability of selected measures and to ensure that design
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parameters and calculations were appropriately employed and minimum standards were
achieved.

6.6 Measurable Goals/Planned Activities for Future Program Years

Table 6-3 describes the various Construction Site Stormwater Runoff Control BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

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Table 6-3: BMP Measurable Goals for the Construction Site Stormwater Runoff Control Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Erosion and
Sediment Control
Program
The permittee has a delegated Sediment and Erosion
Control Program. As such, to the extent authorized by
law, the permittee is responsible for compliance with the
Sediment Pollution Control Act of 1973 and Chapter 4
of Title 15A of the North Carolina Administrative Code.
The delegated Sediment and Erosion Control Program
effectively meets the maximum extent practicable
(MEP) standard for Construction Site Runoff Controls
by permitting and controlling development activities
disturbing one or more acres of land surface and those
activities less than one acre that are part of a larger
common plan of development as authorized under the
Sediment Pollution Control Act of 1973 and Chapter 4
of Title 15A of the North Carolina Administrative Code.
Continue to implement the delegated Sediment and Erosion Control program and enforce the
City ordinance. (On-going, years 1 – 5+)
Develop
requirements for
construction site
operators
The NCG010000 permit establishes requirements for
construction site operators to control waste such as
discarded building materials, concrete truck washout,
chemicals, litter, and sanitary waste at the construction
site that may cause adverse impacts to water quality, as
part of the Permittee’s delegated program.
Continue requirements for BMPs and waste control through issuance of General Construction
Permit NCG010000. (On-going, years 1 – 5+)
Public information
and reporting
The permittee shall provide and promote a means for the
public to notify the appropriate authorities of observed
erosion and sedimentation problems. The permittee may
implement a plan promoting the existence of the
NCDENR, now NCDEQ, Division of Land Resources
“Stop Mud” hotline to meet the requirements of this
paragraph.
Continue to maintain reporting hotline and website. (On-going, years 1 – 5+)
Plan reviews Implement construction site plan reviews as part of the
Permittee’s delegated program. For new development
and redevelopment projects to be built within the
permittee’s planning jurisdiction by entities with
eminent domain authority, the permittee shall, to the
maximum extent practicable, coordinate the approval of
the construction site runoff control with the Division of
Land Resources of DENR.
Continue plan reviews to ensure program requirements are met. Coordinate with NCDEQ –
DEMLR as necessary. (On-going, years 1 – 5+)
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6.7 Program Assessment

The overall Construction Site Stormwater Runoff Control Program was successfully
implemented during the annual report period. Table 6-4 shows a summary of the various items
and corresponding data results for activities conducted under the program.

Table 6-4: Program Summary
CONSTRUCTION SITE RUNOFF PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
CMCSI education workshops conducted 3
Citizens trained via CMCSI program 349
Project/site plans reviewed 1,254
Erosion control citizen requests responded to 500
Site inspections conducted 3,513
NOVs issued 51
Penalty enforcements issued 60

Section 7: Post-Construction Stormwater Management Program

During the annual report period, the City conducted implementation of its Post-Construction
Stormwater Management program in accordance with the Post-Construction Stormwater
Ordinance (PCSO) and program administrative manual. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

7.1 BMP Summary Table

Table 7-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Post-Construction Stormwater Management Program. Funding for the BMPs in this section
is covered by local stormwater utility fees and land development fees.

Table 7-1: BMP Summary Table for the Post-Construction Stormwater Management Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Post-Construction
Stormwater
Management
Program
Maintain an ordinance (or similar regulatory
mechanism) and program to address stormwater
runoff from new development and redevelopment.

X X X X X
Water Quality
Program
Manager
Strategies which
include BMPs
appropriate for the
MS4
Maintain strategies that include a combination of
structural and/or non-structural BMPs implemented
in concurrence with ordinance above. Provide a
mechanism to require long-term operation and
X X X X X
Water Quality
Program
Manager
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maintenance of structural BMPs. Require annual
inspection reports of permitted structural BMPs
performed by a qualified professional.

A qualified professional means an individual
trained and/or certified in the design, operation,
inspection and maintenance aspects of the BMPs
being inspected, for example, someone trained and
certified by NC State for BMP Inspection &
Maintenance.

Deed Restrictions
and Protective
Covenants
The permittee shall provide mechanisms such as
recorded deed restrictions and protective covenants
so that development activities maintain the project
consistent with approved plans.

X X X X X
Water Quality
Program
Manager
Operation and
Maintenance Plan
The developer shall provide the permittee with an
operation and maintenance plan for the stormwater
system, indicating the operation and maintenance
actions that shall be taken, specific quantitative
criteria used for determining when those actions
shall be taken, and who is responsible for those
actions. The plan must clearly indicate the steps that
shall be taken and who shall be responsible for
restoring a stormwater system to design
specifications if a failure occurs and must include
an acknowledgment by the responsible party.
Development must be maintained consistent with
the requirements in the approved plans and any
modifications to those plans must be approved by
the Permittee.

X X X X X
Water Quality
Program
Manager
Educational
materials and
training for
developers
Provide educational materials and training 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.

X X X X X Water Quality
Program
Manager

7.2 Post-Construction Stormwater Management Program

The City’s post-construction program is designed to meet the stormwater management and water
quality protection requirements of North Carolina Administrative Code at 15A 02H Sections
.0126, .0150 - .0154 (NPDES) and at 15A 02H Section .1000 (Stormwater Management) to
address post-construction stormwater runoff from new development and applicable
redevelopment projects as required b y the NPDES MS4 permit program and as allowable under
current State law. The City has developed a Post-Construction Stormwater Ordinance (PCSO)
which covers the entire jurisdictional area (incorporated and ETJ areas) of the City. An
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administrative manual has been developed to ensure successful implementation of the program
and ordinance.

7.3 Post-Construction BMP Strategies

BMP strategies for the City’s Post-Construction Stormwater Management program consist
mainly of structural stormwater control measures (SCMs) such as sand filters, wet ponds,
wetlands, and bioretention areas. SCMs and design procedures are detailed in a local manual
developed by the City and County. SCMs are required on projects that have 24% or greater built
upon area as defined by the program. This threshold is reduced to 10-12% built upon area for
developments disturbing more than an acre and/or adding more than 20,000 sf of built upon area
in sensitive watersheds as defined by the ordinance. In addition, SCMs must be designed to:

• Remove 85% of Total Suspended Solids (TSS) for the runoff volume generated from the
first 1-inch of rainfall;
• Control the runoff volume from the 1-year – 24-hour storm event; and
• Control the peak flow from the 10 and 25-year storm events for residential and
commercial development.

The program also requires proper operation, maintenance, and inspection of SCMs as discussed
in later sub-sections. Green infrastructure practices such as rain gardens, pervious pavements,
vegetated conveyances, and rain water harvesting are allowed, depending on development needs.
Undisturbed natural areas and natural resource protection as well as tree preservation
requirements are part of the program. Additional requirements include:

• 70% Total Phosphorus removal in certain watersheds;
• Various buffer requirements and widths from 30 – 200 feet based on stream jurisdictional
determination; and
• Design standards depending on watershed location and sensitivity.

All of these requirements combine to make a much more sound and protective ordinance and
program.

7.4 Deed Restrictions and Protective Covenants

As part of the PCSO program, the City required deed restrictions and protective covenants to
ensure that development projects remain consistent with approved plans. Streams and buffer
boundaries were required to be specified on all surveys and record plats. An operation and
maintenance agreement for SCMs was required to be referenced on record plats and recorded in
deeds. In addition, a maintenance easement was required to be recorded to provide access to
structural SCMs.

7.4.1 Setbacks for Built-Upon Areas

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The PCSO program required a minimum of 30-foot buffers on all perennial and intermittent
streams draining less than 50 acres, and incrementally increased required buffer widths up to
100-feet for streams draining 640 acres or more. A special provision in the program required
200-foot buffers on all perennial streams and 100-foot buffers on all intermittent streams in the
Six Mile Creek watershed due to the potential presence of the federally endangered species,
Carolina Heelsplitter (Lasmigona decorata). These buffers were recorded on record plats as
noted in sub-section 7.4.

7.5 Operation and Maintenance Plan

The PCSO program required an operation and maintenance agreement executed by the
responsible party (owner) of each stormwater control measure (SCM). As part of the program,
the owner was required to:

• Conduct annual inspections of SCMs;
• Maintain proper records documenting operation and maintenance activities; and
• Submit inspection reports to the City.

In the case of single family residential projects, at the request of the homeowner’s association the
City may assume the responsibility for operating, maintaining, and inspecting required SCMs
after an initial two-year period for SCMs that are constructed and functioning properly.

7.6 Education and Training Program

The City implemented an education and training program designed to provide developers and
designers with the information necessary to comply with the City’s Post-Construction
Stormwater Ordinance. Training included information on:
• Overall ordinance requirements;
• Review processes;
• Land development and SCM design requirements;
• Deed restrictions and protective covenants;
• Buffer requirements; and
• Operation, maintenance, and inspection requirements for SCMs.

Education and training was accomplished by providing the following:

• Website information;
• Individual meetings with developers and designers;
• Presentations at public meetings;
• Periodic seminars and training sessions; and
• Training City design staff.

A half-day Post-Construction Stormwater Ordinance education workshop was held on December
6, 2018 with 128 people in attendance. Attendees included representatives from local
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government; engineering, land development and design firms; and survey companies. The
presentation topics included:

• Background about City and County PCSOs;
• City Redevelopment Mitigation Option;
• Built Upon Area, As-Built Survey & Polaris Case Study;
• Stormwater SCM Inspections;
• Huntersville’s LID Ordinance; and
• Question & Answer Session.

7.7 Measurable Goals/Planned Activities for Future Program Years

Table 7-2 describes the various Post-Construction Stormwater Management Program BMPs and
the Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

[THIS SPACE INTENTIONALLY BLANK]
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Table 7-2: BMP Measurable Goals for the Post-Construction Stormwater Management Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Post-Construction
Stormwater
Management
Program
Maintain an ordinance (or similar regulatory mechanism) and program to address
stormwater runoff from new development and redevelopment.

Maintain the City’s Post- Construction Ordinance (PCSO) and
implement and enforce the ordinance. (On-going, years 1 – 5+)
Strategies which
include BMPs
appropriate for the
MS4
Maintain strategies that include a combination of structural and/or non-structural BMPs
implemented in concurrence with (a) above. Provide a mechanism to require long -term
operation and maintenance of structural BMPs. Require annual inspection reports of
permitted structural BMPs performed by a qualified professional.

A qualified professional means an individual trained and/or certified in the design,
operation, inspection and maintenance aspects of the BMPs being inspected, for example,
someone trained and certified by NC State for BMP Inspection & Maintenance.

Continue PCSO program and ensuring proper BMP operation,
maintenance, and annual inspections. (On-going, years 1 – 5+)
Deed Restrictions
and Protective
Covenants
The permittee shall provide mechanisms such as recorded deed restrictions and protective
covenants so that development activities maintain the project consistent with approved
plans.

Continue to implement Deed Restrictions and Protective
Covenants through administration of the PCSO Program. (On-
going, years 1 – 5+)
Operation and
Maintenance Plan
The developer shall provide the permittee with an operation and maintenance plan for the
stormwater system, indicating the operation and maintenance actions that shall be taken,
specific quantitative criteria used for determining when those actions shall be taken, and
who is responsible for those actions. The plan must clearly indicate the steps that shall be
taken and who shall be responsible for restoring a stormwater system to d esign
specifications if a failure occurs and must include an acknowledgment by the responsible
party. Development must be maintained consistent with the requirements in the approved
plans and any modifications to those plans must be approved by the Permitt ee.

Continue to implement BMP operation, maintenance, and
inspection plan and procedures. (On-going, years 1 – 5+)
Educational
materials and
training for
developers
Provide educational materials and training 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.

Continue to provide and update education/ training tools for
developers. (On-going, years 1 – 5+)
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7.8 Program Assessment

The overall Post-Construction Stormwater Management Program was successfully implemented
during the annual report period. Table 7-3 shows a summary of the various items and
corresponding data results for activities conducted under the program.

Table 7-3: Program Summary
POST-CONSTRUCTION PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Site plans reviewed 126
SCMs added 112
SCM inspections conducted1. 1,600
NOVs and CARs issued2. 948
Education workshops conducted 1
Citizens educated at workshops 128
1. Includes Post-Construction and Peak Detention SCMs inspected.
2. Includes NOVs and Corrective Action Requests (CARs); and notice of maintenance and report due letters to remind the property owner that a
yearly inspection report is due.
3. Number includes only attendees at workshops. Others were educated about aspects of the Post-Construction program through phone calls,
website, and other ways.

There has been a significant increase in SCM inspections during FY2019 over previous years.
This has been an ongoing goal of the Post-Construction Stormwater Management Program. As
SCMs increase in the City it is the goal of the program to continue with these efforts such that
additional staff would be added to conduct inspections (i.e. the program started with one SCM
inspector and now has three).

In addition, the number of NOVs and CARs issued during FY2019 was higher than FY2018;
however, relative to the number of inspections that were conducted during FY2019, this was
consistent.

The reduction in SCMs added compared to previous years is due to a shift in reporting from the
number of SCMs approved for construction to the number of SCMs constructed and verified as-
built.

Section 8: Pollution Prevention/Good Housekeeping Program

During the annual report period, inspection, training, and program development activities were
conducted for municipal facilities and operations as part of the Pollution Prevention and Good
Housekeeping Program per the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
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• Program assessment.

8.1 BMP Summary Table

Table 8-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Pollution Prevention & Good Housekeeping Program.

Table 8-1: BMP Summary Table for the Pollution Prevention/Good Housekeeping Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Operation and
maintenance program
for municipal
facilities and
operations.
Maintain and implement an operation and
maintenance program for municipal facilities
owned and operated by the permittee that have
been determined by the permittee to have
significant potential for generating polluted
stormwater runoff that has the ultimate goal of
preventing or reducing pollutant runoff.
X X X X X
Water Quality
Program
Manager
Site Pollution
Prevention Plans for
municipal facilities
and operations.
Maintain and implement Site Pollution Prevention
Plans for municipal facilities owned and operated
by the permittee that have been determined by the
permittee to have significant potential for
generating polluted stormwater runoff that has the
ultimate goal of preventing or reducing pollutant
runoff.
X X X X X
Water Quality
Program
Manager
Inspection and
evaluation of
municipal facilities
and operations.
Maintain an inventory of municipal facilities and
operations owned and operated by the permittee
that have been determined by the permittee to have
significant potential for generating polluted
stormwater runoff, including the MS4 system and
associated structural SCMs, conduct inspections
at facilities and operations owned and operated by
the permittee for potential sources of polluted
runoff, the stormwater controls, and conveyance
systems, and evaluate the sources, document
deficiencies, plan corrective actions, implement
appropriate controls, and document the
accomplishment of corrective actions.
X X X X X
Water Quality
Program
Manager
Spill Response
Procedures municipal
facilities and
operations.
Maintain spill response procedures for municipal
facilities and operations owned and operated by
the permittee that have been determined by the
permittee to have significant potential for
generating polluted stormwater runoff.
X X X X X Water Quality
Program
Manager
Prevent or Minimize
Contamination of
Stormwater Runoff
from all areas used
for Vehicle and
Equipment Cleaning
Describe measures that prevent or minimize
contamination of the stormwater runoff from all
areas used for vehicle and equipment cleaning,
including fire stations that serve more than three
fire trucks and ambulances. Perform all cleaning
operations indoors, cover the cleaning operations,
ensure wash water drains to the sanitary sewer
system, collect stormwater runoff from the
cleaning area and providing treatment or recycling,
or other equivalent measures. If sanitary sewer is
X X X X X Water Quality
Program
Manager
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not available to the facility and cleaning operations
take place outdoors, the cleaning operations shall
take place on grassed or graveled areas to prevent
point source discharges of the wash water into the
storm drains or surface waters.
Where cleaning operations cannot be performed as
described above and when operations are
performed in the vicinity of a storm drainage
collection system, the drain is to be covered with a
portable drain cover during cleaning activities.
Any excess standing water shall be removed and
properly handled prior to removing the drain
cover.

Facilities that serve three or fewer fire trucks and
ambulances and that cannot comply with these
requirements shall incorporate structural measures
during facility renovation.
Streets, roads, and
public parking lots
maintenance
The permittee shall evaluate BMPs to reduce
polluted stormwater runoff from municipally-
owned streets, roads, and public parking lots
within the corporate limits. Within 12 months of
permit issuance, the permittee must update its
Stormwater Plan to include the BMPs selected.
X Water Quality
Program
Manager
Streets, roads, and
public parking lots
maintenance
Within 24 months of permit issuance, the
permittee must implement BMPs selected to
reduce polluted stormwater runoff from
municipally-owned streets, roads, and public
parking lots identified by the permittee in the
Stormwater Plan.
X X X X Water Quality
Program
Manager
Operation and
Maintenance (O&M)
for municipally-
owned or maintained
structural SCMs and
the storm sewer
system (including
catch basins, the
conveyance system,
and structural
stormwater controls).
Within 12 months of permit issuance, the
permittee shall develop and implement an
operation and maintenance program for structural
SCMs and the storm sewer system (including
catch basins, the conveyance system, and
structural stormwater controls).

X X X X X Water Quality
Program
Manager
Staff training Maintain and implement a training plan that
indicates when, how often, who is required to be
trained and what they are to be trained on.
X X X X X Water Quality
Program
Manager

8.2 Operation and Maintenance Program

The City continued to provide an extensive network of municipal operations designed to serve its
citizens and keep vital infrastructure functioning properly. A number of these operations impact
the storm drainage system directly, such as storm drainage system maintenance and street
sweeping, and indirectly, such as landscape management and municipal building maintenance.
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The cumulative impact of all these operations can potentially be significant, so it is important to
maintain operation and maintenance programs to minimize impacts to the storm drainage system.

Operation and maintenance of municipal facilities was managed through implementation of
Stormwater Pollution Prevention Plans (SPPPs) and the municipal facility inspection program.
Those programs are discussed below in sub-sections 8.3, 8.4, 8.5 and 8.9. Operation and
maintenance of the municipal stormwater system is discussed separately in sub-section 8.8.

EPM-SWS staff continued to work with various departments to improve and refine best
management practices to minimize negative impacts to the storm drainage system. This is
primarily accomplished through observations in the field and response to reports from concerned
residents and internal staff about field operation practices where improvements are needed.
CMSWS staff then work with staff from various departments to refine established BMPs for
field operations and/or establish new BMPs. Implementation of BMPs then occurs through a
combination of communications with management, training of field operations staff, and revision
of contract requirements.

During FY2019, EPM-SWS staff also accomplished activities related to improving pollution
prevention from City contractors and City field crews, as follows:

• Worked with EPM-SWS construction staff, land development erosion control staff, and
CW Engineering to share resources, coordinate efforts, and develop the best procedures
and methods for improving contractor and subcontractor performance related to soil
erosion and sediment control;
• Continued to support the use of a “Surface Water Quality Protection” clause for EPM-
SWS construction contracts that included requirements related to:
- Concrete washouts;
- Spill response and mobile fueling; and
- Erosion control and pollution prevention before street washing.
• Continued discussions with CDOT and research of stormwater BMPs for street milling;
• Worked with EPM-SWS contractors and EPM-SWS construction inspectors to determine
standards for power washing water from spin casting;
• Continued communications and meetings with CW regarding stormwater BMPs for
slurry created during emergency water main breaks;
• Continued communications with City Solid Waste Services regarding street sweeping
discharges;
• Communicated snow disposal BMP to CDOT before an ice and snow event; and
• Continued discussion with the City’s Risk Management Department regarding spill
response preparedness.

8.3 Municipal Facility Stormwater Pollution Prevention Plans

SPPPs are developed for all 32 municipal facilities listed in Table 8-2 regardless of whether or
not they are required; however, SPPPs are not required or developed for fire stations. The SPPPs
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are reviewed and updated annually with all documentation kept in the SPPPs, including site
maps. The SPPPs are used as an implementation guide for maintaining good housekeeping and
reducing stormwater pollution. All appropriate topics are covered in the SPPPs including:

• Best management practices;
• Facility inspections;
• Facility monitoring;
• Employee training;
• Spill prevention and response;
• Vehicle/equipment cleaning and fueling; and
• Preventative maintenance.

Table 8-2: City Facilities within the Pollution Prevention/Good Housekeeping Program.
Municipal Facility Physical Address
Charlotte-Douglas International Airport 5501 Josh Birmingham Pkwy., Charlotte, NC 28208
CATS Bus Maintenance Operations Facility 3145 S. Tryon St., Charlotte, NC 28217
CATS Transit Maintenance Operations Center 901 N. Davidson St., Charlotte, NC 28202
CATS Transit Center 310 E. Trade St., Charlotte, NC 28202
CATS Light Rail Maintenance Facility – North Yard 1911 North Brevard Street, Charlotte NC 28202
CATS Light Rail Maintenance Facility – South Yard 3305 Pelton St., Charlotte, NC
CDOT - Traffic Engineering Operations Center 3701 Craig Ave., Charlotte, NC 28211
CDOT – Street Maintenance Division - Northwest
District 4411 Northpointe Industrial Blvd., Charlotte, NC 28216
CDOT – Street Maintenance Division - Northeast
District 6001 General Commerce Dr., Charlotte, NC 28213
CDOT – Street Maintenance Division - Southwest
District 4600 Sweden Rd., Charlotte, NC 28273
Charlotte Water Department - Irwin Creek WWTP 4000 Westmont Dr., Charlotte, NC 28217
Charlotte Water Department - Mallard Creek WWTP 12400 Hwy 29 N, Charlotte, NC 28262
Charlotte Water Department - McAlpine Creek
WWTP & Zone 3 Water/Wastewater Operations 12701 Lancaster Hwy, Pineville, NC 28134
Charlotte Water Department - McDowell Creek
WWTP 4901 Neck Rd., Huntersville, NC 28078
Charlotte Water Department - Sugar Creek WWTP 5301 Closeburn Rd., Charlotte, NC 28210
Charlotte Water Department - Franklin WTP 5200 Brookshire Blvd, Charlotte, NC 28216
Charlotte Water Department - Lee S Dukes WTP 7980 Babe Stillwell Rd., Huntersville, NC 28078
Charlotte Water Department - Vest WTP 820 Beatties Ford Rd., Charlotte, NC 28216
Charlotte Water Department – Zone 1
Water/Wastewater Field Operations 11609 Hord Dr., Huntersville, NC 28078
Charlotte Water Department – Zone 2
Water/Wastewater Field Operations 5730 General Commerce Dr., Charlotte, NC 28213
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Municipal Facility Physical Address
Charlotte Water Department – Zone 4
Water/Wastewater Field Operations 4100 W. Tyvola Rd., Charlotte, NC 28208
Charlotte Water Department – Catawba Pump
Station 12548 Pump Station Rd., Charlotte, NC 28216
Engineering & Property Management - Heavy
Equipment Shop 4600 Sweden Rd., Charlotte, NC 28273
Engineering & Property Management - Heavy Truck
Shop / Central Yard Truck Wash 829 Louise Ave., Charlotte, NC 28204
Engineering & Property Management - Light Vehicle
Shop 1031 Atando Ave., Charlotte, NC 28216
Engineering & Property Management - Small Engine
Repair Shop 701 Tuckaseegee Rd., Charlotte, NC 28208
Engineering & Property Management - 12th Street
Vehicle Garage 900 W 12th St, Charlotte, NC 28206
CFD - Fire Logistics 1501 N. Graham St., Charlotte, NC 28206
CMPD - Animal Control Shelter 8315 Byrum Dr., Charlotte, NC 28217
CMPD - Police and Fire Training Academy 1770 Shopton Rd., Charlotte, NC 28217
Solid Waste Services - Street Sweeper Facility &
Sanitation Packer Lot 829 Louise Ave., Charlotte, NC 28204
Landscape Management Operations 701 Tuckaseegee Rd., Charlotte, NC 28208

8.4 Municipal Facility Inventory and Site Inspections

All parcels of land owned or operated by the City continued to be examined to determine
whether they should be included in the Municipal Facilities Inventory within the Pollution
Prevention/Good Housekeeping Program. A Standard Administrative Procedure (SAP) is
followed when evaluating parcels for this inventory. Once included in the inventory, applicable
facilities receive:

• Preparation and implementation of a SPPP;
• Regular inspections; and
• Annual employee training.

All facilities included in the inventory are inspected annually with the exception of fire stations
which are inspected once every five years. The following are elements of all facility inspections:

• Thorough assessment of facility operations and maintenance activities;
• Evaluation of waste disposal and storage methods;
• Evaluation of the stormwater drainage system, including catch basin inlets, structural
best management practices and outfalls;
• Review of spill response and clean up procedures with recommended revisions as
appropriate;
• Evaluation of housekeeping practices with recommended revisions as necessary to
eliminate potential pollution sources;
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• Evaluation of outdoor storage facilities and recommendations for elimination of potential
pollution sources;
• Identification and elimination of dry weather discharges;
• Review of SPPPs where applicable including outfall monitoring (if required by an
NPDES permit); and
• Completion of a written report documenting findings and recommendations.

Follow-up inspections, communication and meetings with appropriate personnel are conducted
as necessary to eliminate potential pollution sources. The supervisor and other management
personnel of each facility are contacted and provided with a copy of the written report. Reports
include information about areas and equipment that have a potential for pollution,
recommendations for continuing good practices or making minor improvements, any
deficiencies requiring more significant improvements, and/or any illicit discharges observed.
All inspections are conducted following the procedures outlined in the Municipal Inspections and
Monitoring SAP which is reviewed and updated annually.

During FY2019 the following activities were conducted as part of the municipal facility site
inspections:

• 32 inspections were conducted;
• 12 pollution control ordinance deficiencies were detected (including three illicit
discharges); and
• 13 SPPP issues were noted.

Ordinance deficiencies and SPPP issues required corrective action by facility staff.
Figure 8-1 shows the locations of the facilities inspected during FY2019. (Note: Some CW
facilities are located outside the City limits.)

[THIS SPACE INTENTIONALLY BLANK]
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FIGURE 8-1

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

90

8.4.1 NPDES Stormwater Permitted Municipal Facilities Review

Twelve of the 32 municipal facilities discussed in sub-section 8.3 above have been issued
NPDES Stormwater permits (*Note: The airport’s permit is a combined stormwater/wastewater
individual permit). Table 8-3 shows these facilities.

Table 8-3: Municipal Facilities with NPDES Stormwater Permits
Municipal Operation Permit
Number
Certificate of Permit
Coverage Number
Address
CATS Transit Maintenance
Operations Center
NCG080000 NCG080029 901 N. Davidson Street
CATS Bus Maintenance
Operations Facility
NCG080000 NCG080710 3145 S. Tryon Street
Heavy Truck Shop, Truck
Wash & Street Sweeper
Yard
NCG080000 NCG080822 829 Louise Avenue
Heavy Equipment Shop NCG080000 NCG080840 4600 Sweden Road
Light Vehicle Maintenance
Shop
NCG080000 NCG080879 1031 Atando Avenue
12th Street Fleet
Maintenance
NCG080000 NCG080063

900 West 12th Street
Charlotte-Douglas
International Airport*
NC0083887 Not applicable 5501 Josh Birmingham Parkway
Irwin Creek WWTP NCG110000 NCG110008 4000 Westmont Drive
Mallard Creek WWTP NCG110000 NCG110114 12400 Highway 29 North
McAlpine Creek WWTP NCG110000 NCG110010 12701 Lancaster Hwy
McDowell Creek WWTP NCG110000 NCG110011 4901 Neck Road
Sugar Creek WWTP NCG110000 NCG110012 5301 Closeburn Road

Annual inspections were conducted at each facility listed in Table 8-3. The same inspection
items listed in sub-section 8.4 were reviewed at these permitted facilities. Emphasis was placed
on elimination of illicit discharges, good housekeeping improvements, and compliance with
permit and SPPP requirements, including inspections, monitoring and training. The SPPPs were
reviewed and updated annually as required. Environmental management personnel at the airport
and five wastewater treatment plants are responsible for updating the SPPPs at their facilities,
while staff of EPM-SWS reviewed and updated SPPPs for the other facilities listed in Table 8.3.

8.5 Municipal Spill Response Procedures

Numerous activities conducted by City employees, both in the field and at facilities, have the
potential to generate spills that may enter the MS4 and contaminate surface waters. Because of
that potential, Spill Prevention and Response Procedures have been developed for all facilities
(and associated field operations) listed in Table 8-2. These procedures are incorporated into the
facility SPPPs. The procedures and proper implementation of them was evaluated as part of the
annual inspections. Items that have been evaluated and incorporated into the procedures
included the following:

• Product storage tanks/containers, exposure, and secondary containment;
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• Flow path and potential for entry into the MS4;
• Spill history, response to those spills, and documentation;
• Activities that may generate spills;
• Operating procedures to prevent spills;
• Spill response procedures and reporting;
• Spill response equipment and other countermeasures; and
• Employee training.

In addition, to address spills that may occur on municipal streets, roads, and in other areas as
related to the overall IDDE program, CMSWS staff maintained a 24-hour emergency response
team that responds to environmental emergencies. Members of the team act in an advisory role
to the CFD Hazmat Unit. Once Hazmat secures a scene and contains the spill, the team worked
with the responsible party to ensure that spills were cleaned up properly and had minimal
impacts to the environment. The team’s actions are guided by a set of written emergency
response protocols.

During FY2019, the team responded to 31 emergency response calls, but none were related to
the municipal facilities listed in Table 8-2. Figure 8-2 shows a downward trend in the number
of emergency response calls from FY1995 through FY2019, while Figure 8-3 shows the
locations of the emergency response calls.

FIGURE 8-2

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FIGURE 8-3

City of Charlotte – MS4 Stormwater Management Program – FY2019 Annual Report

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8.6 Vehicle and Equipment Cleaning Operations

The City recognizes the negative impacts that municipal vehicle and equipment wash water
runoff can have on stormwater and, ultimately, surface waters. Municipal employees washed the
majority of vehicles and equipment at commercial or municipal vehicle wash facilities that drain
to the sanitary sewer system. Vehicle and equipment washing at municipal facilities continued
to be assessed during annual inspections at facilities listed in Table 8-2, where applicable.

8.7 Streets, Roads, and Public Parking Lots Maintenance

Streets and parking lots can be a significant source of stormwater pollution. During previous
years, the City has implemented various BMPs to address these pollutants within the MS4 such
as cleaning catch basins. The City has evaluated additional types of BMPs that are considered to
best address polluted stormwater runoff from these sources. As a result of the evaluation, the
City implemented the following non-structural BMPs:

• Street sweeping program;
• Adopt-A-Street program;
• Leaf and yard waste collection program;
• Trash receptacles along downtown streets;
• Trash receptacles and litter control activities at Park and Ride parking lots; and
• Public education to address polluted stormwater runoff from municipally-owned streets
and public parking lots.

During FY2019 the following activities were conducted by the City Solid Waste department as
part of efforts to clean and maintain public roads and parking lots:

• 58,818 miles of streets swept;
• 1,260 tons of street sweeping debris/ROW trash removed;
• 61,692 tons of yard waste collected;
• 460 street miles received litter collection from volunteers contributing 6,487 hours to
participation in the Adopt-a-Street program; and
• 2,563 bags of trash and 483 bags of recycling were removed from street rights-of-way
through the Adopt-a-Street program

8.8 Municipal SCMs and MS4 System Operation and Maintenance

During previous years, the City inventoried municipal structural SCMs and developed a list of
over 120 SCMs to be inspected at various frequencies based on the type of SCM. The list
continues to be updated as new SCMs are constructed. Routine maintenance activities for these
SCMs included:

• Mowing;
• Woody growth removal;
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• Cattail removal; and
• Inlet and outlet clearing.

These inspection and maintenance activities have been conducted to ensure proper function of
structural SCMs.

The EPM-Landscape Management Division and Building Services Division have primary
responsibility for conducting inspections and ensuring proper maintenance. Employees at certain
facilities where SCMs are located also assist with routine maintenance, such as grass mowing.
Standard inspection forms have been developed and were utilized to conduct and document
inspections. Completed inspection forms were provided to EPM-SWS SCM inspection and
maintenance coordinators, who then entered the information into the Cityworks® database. The
coordinators also worked with City staff responsible for inspections to ensure they were
completed as required.

The City conducted extensive cleaning and maintenance of the MS4 system during FY2019.
Work included, but was not limited to:

• Catch basin cleaning (manually and with vacuum trucks);
• Storm drain top cleaning;
• Curb and gutter cleaning;
• Culvert/channel cleaning;
• Drainage structure installation and repair;
• Ditch reshaping; and
• Erosion control.

During FY2019, a total of:

• 47,377 catch basin tops were cleaned;
• 1,366 catch basins were vacuumed out; and
• 12,781 linear feet of stormwater pipes were vacuumed out.

8.9 Employee/Staff Training at Municipal Facilities

Training was conducted for employees at all of the facilities listed in Table 8-2. The goal of
training was to inform employees of the actions necessary to reduce the discharge of pollutants
from their facilities/operations and protect water quality. Topics for this training included:

• Description of common pollutants, their sources and water quality impacts;
• Description of the actions that each facility should take to reduce discharges of
pollutants, with an emphasis on good housekeeping;
• Description of effective spill prevention measures that should be employed at each
facility;
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• Discussion of typical pollution sources at municipal operations and specific actions that
should be taken to eliminate these sources and protect water quality;
• Review of the facility SPPP, where applicable;
• Explanation of the potential negative consequences of failing to control pollutants at
facilities; and
• Overview of IDDE Program and how to report observed water quality problems.

High priority facilities were provided in-person classroom presentations while lower priority
facilities were assigned on-line training. More details about the classroom and on-line training
for municipal facilities is described in sub-section 5.5 as it is combined with education for
employees related to the identification and reporting of illicit discharges.

During FY2019, training was conducted as follows:

• 19 on-site, in-person training sessions were provided by CMSWS staff to 612 employees
at 17 of the municipal facilities listed on Table 8-2;
• Three in-person training sessions were provided by CATS staff to 93 employees at two
facilities (CATS S. Tryon, CATS Davidson);
• Five on-site in-person training sessions were provided by CW staff to 97 employees at
five wastewater facilities;
• Two on-site in-person training sessions were provided by Charlotte airport staff to 75
vendors of the airport who then provided 39 training sessions to an additional 518 of their
employees. This totals to 593 people who received training; and
• 344 employees from nine facilities were assigned an on-line training module.

8.10 Measurable Goals/Planned Activities for Future Program Years

Table 8-4 describes the various Pollution Prevention/Good Housekeeping Program BMPs and
the Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

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Table 8-4: BMP Measurable Goals for the Pollution Prevention/Good Housekeeping Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Operation and maintenance program for
municipal facilities and operations.
Maintain and implement an operation and maintenance program for
municipal facilities owned and operated by the permittee that have
been determined by the permittee to have significant potential for
generating polluted stormwater runoff that has the ultimate goal of
preventing or reducing pollutant runoff.
Review and update Operation and Maintenance programs as
necessary. Continue operation and maintenance activities
per established procedures. (On-going, years 1 – 5+)
Site Pollution Prevention Plans for
municipal facilities and operations.
Maintain and implement Site Pollution Prevention Plans for municipal
facilities owned and operated by the permittee that have been
determined by the permittee to have significant potential for generating
polluted stormwater runoff that has the ultimate goal of preventing or
reducing pollutant runoff.
Review and update facility SPPPs as necessary. Continue
implementation of SPPPs. (On-going, years 1 – 5+)
Inspection and evaluation of municipal
facilities and operations.
Maintain an inventory of municipal facilities and operations owned
and operated by the permittee that have been determined by the
permittee to have significant potential for generating polluted
stormwater runoff, including the MS4 system and associated structural
SCMs, conduct inspections at facilities and operations owned and
operated by the permittee for potential sources of polluted runoff, the
stormwater controls, and conveyance systems, and evaluate the
sources, document deficiencies, plan corrective actions, implement
appropriate controls, and document the accomplishment of corrective
actions.
Review and update inventory of facilities for inspection.
Conduct inspections of applicable facilities and make
corrective actions where necessary. (On-going, years 1 – 5+)
Spill Response Procedures municipal
facilities and operations.
Maintain spill response procedures for municipal facilities a nd
operations owned and operated by the permittee that have been
determined by the permittee to have significant potential for generating
polluted stormwater runoff.
Review facility spill response procedures and update as
necessary. Continue implementation of procedures. (On-
going, years 1 – 5+)
Prevent or Minimize Contamination of
Stormwater Runoff from all areas used
for Vehicle and Equipment Cleaning
Describe measures that prevent or minimize contamination of the
stormwater runoff from all areas used for vehicle and equipment
cleaning, including fire stations that serve more than three fire trucks
and ambulances. Perform all cleaning operations indoors, cover the
cleaning operations, ensure wash water drains to the sanitary sewer
system, collect stormwater runoff from the cleaning area and providing
treatment or recycling, or other equivalent measures. If sanitary sewer
is not available to the facility and cleaning operations take place
outdoors, the cleaning operations shall take place on grassed or
graveled areas to prevent point source discharges of the wash water
into the storm drains or surface waters.
Review procedures for vehicle and equipment cleaning
operations and update as necessary. Ensure that corrective
actions are implemented where operations are found to not
be in compliance with the permit. (On-going, years 1 – 5+)
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Where cleaning operations cannot be performed as described above
and when operations are performed in the vicinity of a storm drainage
collection system, the drain is to be covered with a portable drain cover
during cleaning activities. Any excess standing water shall be
removed and properly handled prior to removing the drain cover.

Facilities that serve three or fewer fire trucks and ambulances and that
cannot comply with these requirements shall incorporate structural
measures during facility renovation.

Streets, roads, and public parking lots
maintenance
The permittee shall evaluate BMPs to reduce polluted stormwater
runoff from municipally-owned streets, roads, and public parking lots
within the corporate limits. Within 12 months of permit issuance, the
permittee must update its Stormwater Plan to include the BMPs
selected.

Evaluate various types
of BMPs that would
best address polluted
stormwater runoff
from municipally-
owned streets and
parking lots and select
BMPs based on the
evaluation by Feb 28,
2014.
None (years 2 – 5+)
Streets, roads, and public parking lots
maintenance
Within 24 months of permit issuance, the permi ttee must implement
BMPs selected to reduce polluted stormwater runoff from municipally-
owned streets, roads, and public parking lots identified by the
permittee in the Stormwater Plan.
None Implement
BMPs selected
from year one
evaluation by
Feb 28, 2015.
Continue to
implement
selected BMPs.
(On-going, years
3 – 5+)
Operation and Maintenance (O&M) for
municipally-owned or maintained
structural SCMs and the storm sewer
system (including catch basins, the
conveyance system, and structural
stormwater controls).
Within 12 months of permit issuance, the permittee shall develop and
implement an operation and maintenance program for structural SCMs
and the storm sewer system (including catch basins, the conveyance
system, and structural stormwater controls).

Continue to implement structural SCM operation,
maintenance, and inspection program. Continue operation
and maintenance program for the MS4 system. (On-going,
years 1 – 5+)
Staff training Maintain and implement a training plan that indicates when, how often,
who is required to be trained and what they are to be trained on.

For facilities included in the municipal facility inspection
program, conduct staff training on SPPPs and Spill Response
Procedures according to the Training Plan. (On-going, years
1 – 5+)
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8.11 Program Assessment

The overall Pollution Prevention and Good Housekeeping Program was successfully
implemented during the annual report period. Table 8-5 shows a summary of the various items
and corresponding data results for activities conducted under the program.

Table 8-5: Program Summary
MUNICIPAL GOOD HOUSEKEEPING PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
City owned parcels inventoried 35
Municipal facilities inspected1. 32
Municipal program evaluations 17
Problems detected/corrected at City facilities 72
Municipal facility employee training sessions 86
Municipal facility employees trained 1,993
1. Not all parcels are included in the municipal inspection program. See Sec 8.4

The following is clarification of numbers provided in Table 8-5:

• Number of City owned parcels inventoried includes properties purchased in the previous
calendar year;
• Number of municipal facilities inspected includes those at which CMSWS staff
conducted inspections;
• Municipal program evaluations include reviews (field observations, meetings, etc.) of
municipal field operations for development and/or implementation of stormwater
pollution prevention best practices;
• Problems detected/corrected includes the number of facility and SWPPP
recommendations made as a result of municipal facility inspections that needed
correction;
• Employee training sessions includes classroom sessions (conducted by CMSWS, CW,
CATS, and the Airport) and number of facilities assigned the on-line training module;
and
• Employees trained includes all employees who completed training as described in the
previous bullet.

The City maintains a very comprehensive Good Housekeeping and Pollution Prevention program
which has expanded in program depth and scope each year. With the frequency of inspections
and training received, municipal facility staff has grown in awareness and knowledge of
stormwater pollution prevention issues. However, with the large growth in the City, there is still
plenty of need for process improvement. Specific focus areas for this will include:

• Develop and improve upon stormwater pollution prevention best management practices
among municipal field operations;
• Investigate and support the allocation of more resources for street sweeping to support
water quality improvements;
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• Implement procedures that help departments utilize city-wide spill response contracts;
• Improve contract language and guidance for contractors regarding the expectation for
preventing illicit discharges and the BMPs that may be used in various operations;
• Integrate structural stormwater BMPs and green infrastructure into municipal projects
and infrastructure; and
• Continue to implement various means of training municipal staff about BMPs for
facilities and field practices.

Section 9: Industrial Facilities Evaluation and Monitoring Program

During the annual report period, inspection and monitoring activities were conducted under the
Industrial Facilities Inspection and Monitoring Program per the SWMP. The following sub-
sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

9.1 BMP Summary Table

Table 9-1 provides information concerning the BMPs implemented to fulfill the requirements of
the Industrial Facilities Program.

Table 9-1: BMP Summary Table for the Industrial Facilities Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Maintain an
Inventory of
Industrial Facilities
Maintain an inventory of permitted hazardous
waste treatment, disposal, and recovery facilities,
industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity
permitted to discharge stormwater to the
permittee’s MS4, or as identified as an illicit
discharge under the IDDE Program.

For the purposes of this permit, industrial activities
shall mean all permitted industrial activities as
defined in 40 CFR 122.26.

X X X X X Water Quality
Program
Manager
Inspection Program Identify priorities and inspection procedures. At a
minimum, priority facilities include those
identified above in subsection II.H.2.a.

X X X X X Water Quality
Program
Manager

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BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Evaluate Industrial
Facilities discharging
stormwater to the
City’s MS4
The Permittee is required to evaluate control
measures implemented at permitted hazardous
waste treatment, disposal, and recovery facilities,
industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity
permitted to discharge stormwater to the
permittee’s MS4, or as identified as an illicit
discharge under the IDDE Program.

For permitted facilities, the municipality shall
establish procedures for reporting deficiencies and
non-compliance to the permitting agency. Where
compliance with an existing industrial stormwater
permit does not result in adequate control of
pollutants to the MS4, municipality will
recommend and document the need for permit
modifications or additions to the permit issuing
authority.

For the purposes of this permit, industrial activities
shall mean all permitted industrial activities as
defined in 40 CFR 122.26. For the purpose of this
permit, the Permittee is authorized to inspect the
permitted hazardous waste treatment, disposal, and
recovery facilities as an authorized representative
of the Director.
X X X X X Water Quality
Program
Manager

9.2 Industrial Facility Inventory

An inventory of facilities is maintained showing those facilities that discharge to the City’s MS4
and have the potential to discharge significant pollutant loads. The inventory is used to select
each year’s facilities for inspection and monitoring. Facilities included in the inventory fit into
one or more of the following categories:

• Hazardous waste TSD facility;
• SARA Title III facility (TRI reporter);
• NPDES Stormwater permitted facility;
• Stormwater No Exposure Certificate facility;
• Industrial Wastewater Pre-Treatment permitted facility; and
• Facilities identified as having an illicit discharge under the IDDE Program.

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9.3 Industrial Facilities Inspection Program

The purpose of the Industrial Facilities Inspection program is to evaluate activities at industrial
facilities that may impact stormwater discharges, and then work with identified problem facilities
to reduce stormwater pollution from the facility.

The overall goal of the program is to inspect all permitted facilities listed in the facility inventory
approximately once every five (5) years, but a facility may be inspected more frequently if it has
had previous compliance issues or it has been deemed to have a higher potential for stormwater
pollution. Likewise, a permitted facility may be inspected less frequently if it has been deemed
to have less potential for stormwater pollution. During FY2018, a strategy was finalized for
prioritizing industrial facilities for inspection which designates different priority tiers for
permitted facilities based on several criteria that indicate a facility’s potential to impact surface
waters. To support this prioritization strategy, CMSWS staff developed a document that details
the criteria for each priority tier and a flow chart that guides the ongoing prioritization of
facilities. Each year staff update the facility database by assigning a priority tier for each facility.

Non-permitted industrial facilities are also selected for inspection based on the recommendation
of CMSWS staff, citizen complaints, or from viewing aerial photography that indicate potential
pollution issues at a site. In addition, vehicle maintenance facilities and machine shops are
included as part of the program due to the potential of finding poor housekeeping practices and
illicit discharges at these facilities. Aerial photography and drive-by visits are used to select
vehicle maintenance and machine shop facilities for inspection based on their appearance of
having a higher potential to pollute.

To effectively accomplish the goals of the program, an Industrial Facilities Inspection and
Monitoring Procedures Manual is utilized. The manual objectives are as follows:

• Provide instructions and guidance about the selection of facilities for inspections, prepare
for and conduct industrial inspections and monitoring, collect vital information, write
reports and conduct follow-up activities;
• Provide consistency for program implementation as a means of quality assurance and
control; and
• Provide forms, templates and examples to aid in implementation of the program.

The manual also details the inspection process. Listed below are general tasks conducted as part
of an industrial inspection:

• Thorough assessment of facility operations and maintenance activities;
• Evaluation of waste disposal and storage methods;
• Evaluation of the stormwater drainage system, including catch basin inlets, structural
best management practices and outfalls;
• Review of spill response and clean up procedures;
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• Evaluation of housekeeping practices with recommended revisions as necessary to
eliminate potential pollution sources;
• Evaluation of outdoor storage facilities and recommendations for elimination of potential
pollution sources;
• Identification and elimination of dry weather discharges;
• Review of SPPP implementation where applicable, including outfall monitoring (if
required by permit);
• Sampling/monitoring of site stormwater runoff and/or dry weather flows;
• Evaluation of monitoring data results; and
• Completion of a written report documenting findings and recommendations.

A standard inspection form is used for conducting all industrial facility inspections with the
exception of vehicle maintenance facility inspections which utilizes a separate inspection form.
For inspections at NPDES stormwater permitted facilities, any deficiencies related to NPDES
stormwater permit requirements are identified and included in the report, with a copy sent to the
NCDEQ. The understanding between CMSWS and NCDEQ is that the State is responsible for
following up on permit-related deficiencies and violations since they are the regulatory authority
for the issued permits. Facilities that are found without coverage under an appropriate general
stormwater permit category are also brought to the attention of NCDEQ. All facilities where
deficiencies were noted received follow-up correspondence and inspections from CMSWS staff
to assist with compliance.

During FY2019 the Industrial Facilities Inspection and Monitoring Program completed the
following activities:

• 40 industrial facilities inspected (32 permitted and 8 non-permitted);
• 20 vehicle maintenance shops and three machine shops inspected;
• 12 illicit discharges were identified and corrected;
• Five of the NPDES permitted sites’ inspection results were unsatisfactory as well as 23 of
the non-permitted sites (includes vehicle maintenance and machine shops);
• Two non-permitted facilities obtained a new NPDES permit as a result of program
inspections; and
• For the 23 vehicle maintenance and machine shop facilities inspected, 32 deficiencies
were identified and four NOVs were issued.

Tables 9-2 and 9-3 provide a list of the facilities inspected while Figures 9-1 and 9-2 show the
location of those facilities.

Table 9-2: FY2019 List of Industrial Facility Inspections
Facility NPDES Permit # Address
Auto Parts U Pull, Inc NCG100240 9820 Statesville Rd
Salvage Auto Supply LLC NCG100207 3301 Robinson Cir
Queen City Transfer Station NCG130079 3130 Jeff Adams Drive
CMC Commercial Metals NCG200351 419 Atando Avenue
Thomas Concrete of Carolina Inc. NCG140308 3701 N Graham St
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Facility NPDES Permit # Address
Custom Pallet & Crating NCG210417 5104 N Graham St
Queen City Metal Recycling NCG200458 2800 North Tryon Street
Migway, Inc NCG080959 9349 China Grove Church Rd.
Elan Trading (doing business as South Resources) NCG200461 3826 Raleigh Street
West Plant - Concrete Supply NCG140054 3030 West Trade Street
Charlotte Rebar Division - Gerdau AmeriSteel NCG030284 301 Black Satchel Dr
Masonite Entry Doors NCG030422 7300 Reames Rd
Macleod Construction - Ready Mix Plant NCG140448 4304 Northpointe Industrial
Thomas Concrete of Carolina Inc. NCG140373 4217 Keeter Dr
Wire Bond NCG140373 400 Rountree Rd
Stevenson Weir, Inc. NCG140455 3725 Westinghouse Road
Huntsman International NCG060037 3400 Westinghouse Blvd
Frito Lay Incorporated NCG060175 2911 Nevada Blvd
Old Dominion Freight Line-Mecklenburg NCG080019 2911 Nevada Blvd
Logistic Leasing LLC (Charlotte) NCG080870 5600 Wilkinson Blvd
Norfolk Southern Railway Co - Liddell St NCG080620 11906 General Dr
CHEP Recycled Pallet Solutions, LLC NCG210454 901 Carrier Dr
DBA/S&R Auto & Truck Salvage NCG100076 1420 W Craighead Rd
Full Stream Recycling NCG130078 2214 North Graham Street
Blue Dot Readi-Mix - Exchange Street NCG140430 1022 Exchange St
TRANSFLO Charlotte West Terminal NCG080802 6816 Csx Way
CSX Intermodal NCG080774 5430 Hovis Rd
Carolina Service Center - Frito Lay NCG080950 10230 Ridge Creek Dr.
Charlotte GP Transflo Terminal NCG080664 601 N Hoskins Rd
Greenteknology Electronics Recycling Solutions
LLC NCG200514 5019 Hovis Road Suite G
ReCommunity Recycle NCG130046 1007 Amble Drive
Genpak, LLC NCG050366 11401 Wilmar Blvd
Non permitted:
Streeter Trucking

N/A

6824 Old Statesville
Piedmont Grading and Wrecking 3652 Beatties Ford Road
Brenntag Chemicals 11750 Fruehauf Dr.
Carolina Foods 1807 South Tryon Street
Linda Construction Company 1805 North Tryon
AB Investments, LLC 6145 Brookshire Blvd
Andino's Metal Recycling 4715 Nations Crossing Rd.
Car Parts NC 11900 N Tryon Street

Table 9-3: FY2019 List of Vehicle Maintenance and Machine Shop Facility Inspections
Facility Address
Mario Auto Repair / Taller Mexicano 7720 Pence Road
Lloyds Auto 7852 Pence Road
Ell Chapulin Colorado Repair and Towing 7611 Pence Road
Almanza Complete Auto Care 10725-E Albemarle Road
R&S Auto Sales and Service 10619 Albemarle Road
Greg's Automotive Repair 10417 Albemarle Road
Chelito Auto Repair 5734 North Tryon Street
World Wide Used Tires 5542 North Tryon
Blessy Auto Repair (NAPA, AJ Auto) 6833 Orr Road
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Facility Address
Hildreth Volkswagen Service 6735 Orr Road
Polanco Auto Care 6431 Orr Road
RBM Automotive 6637 Orr Road
Tryon Auto Repair 5701 Orr Road
Ali and Sons Auto Care 3036 Milton Road
F&Z Tabares Auto Repair 3744 Rozzelles Ferry
Joes Auto Service 3308 Rozzelles Ferry Road
A&R Auto and Engineworks 3600 Brookshire Boulevard
El Monchis 5341 Salem Church Road
Charlotte Truck Repair 855 North Hoskins Road
Charlotte Auto Mall 3512 Odum Avenue
Kloeckner Metals Corporation (Machine Shop) 624 Black Satchel Rd.
Banner Service Corporation (Machine Shop) 6424 South Blvd.
Bevans Steel Fabrication, Inc. (Machine Shop) 4017 Hargrove Ave.

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FIGURE 9-1

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FIGURE 9-2

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9.3.1 Industrial Facilities Monitoring Program

The purpose of the Industrial Facilities Monitoring Program is to monitor stormwater runoff
from select industrial facilities and identify and correct pollution sources related to industrial
activities. Facilities monitored consist of both those with and without an NPDES stormwater
permit. Facilities are selected based on input from the CMSWS inspectors who inspected these
facilities under the Industrial Inspections Program during the previous fiscal year. Table 9-4
shows the facilities where one outfall was monitored during wet weather at least one time during
FY2019.

Table 9-4: FY2019 List of Industrial Facility Monitoring Sites
Facility Address
Hunter Salvage 5310 David Cox Road
Atlantic Ingredients 512 Domino Court
Orbit Energy Charlotte 600 Johnson Road
Lucas Concrete 401 Rountree Road
JML Resources 327 Old Hebron
Blythe Construction 10500 Old Nations Ford Road
Concrete Supply – South Plant 400 Minuet Lane
Concrete Supply – North Plant 3823 Raleigh Street
Concrete Supply – Reames Road 9950 Metromont Boulevard
Argos, LLC – Hebron Plant 325 East Hebron Street
Southern Concrete Materials 715 State Street
Thomas Concrete – North Graham 3701 North Graham Street

All monitoring data from these facilities was reviewed and compared with permit benchmarks (if
applicable), past monitoring results from the CMSWS industrial monitoring program, and in-
stream state water quality standards. During FY2011, an SAP was developed for comparing
industrial stormwater monitoring results to these numbers. The SAP is reviewed and updated
annually.

Once data is reviewed, a letter summarizing the analytical sampling results is sent to each
monitored facility. Copies of this letter are also provided to NCDEQ for NPDES permitted
facilities for potential follow-up for permit deficiencies or recommendations for acquiring or
modifying a permit. For facilities with elevated pollutant levels, recommendations are made to
improve outdoor operations, housekeeping, material storage practices, and other measures that
should result in reduced pollutant runoff. Follow-up inspections are then conducted to ensure
that recommendations/requirements for eliminating pollution sources were implemented.

During FY2019, the Industrial Facilities Monitoring Program monitored 12 facilities (ten
permitted and two non-permitted). Of the permitted facilities monitored, seven were Ready Mix
concrete facilities covered under the Industrial Stormwater General Permit NCG140000. The
two non-permitted facilities appeared to need a permit and were notified that they should apply
for one. Analysis of the monitoring data revealed the following conclusions:

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• All 12 facilities showed elevated pollutant levels in the stormwater and/or process water
samples when compared to CMSWS historical industrial monitoring data, permit
benchmarks, and NCDEQ in-stream water quality standards. The parameters that were
above the state in-stream water quality standards by the greatest value were zinc, copper,
chromium, COD, and turbidity;
• The two non-permitted facilities showed monitoring results that would exceed several
benchmarks had the facilities been permitted under general permits applicable to the type
of respective facility operations;
• One facility (Atlantic Ingredients) covered under general permit NCG060000 (Food and
Kindred) exceeded the benchmarks for TSS and COD. The results also exceeded the
CMSWS historical industrial monitoring average for BOD; and
• The seven facilities covered under the NCG140000 Ready Mix Concrete general permit
showed monitoring results as shown below. Follow-up was conducted, as appropriate,
including directing facilities to implement corrective actions, follow-up inspections,
issuance of notices of violation, and referral to NCDEQ:

- Only one facility was below/compliant with the benchmark/effluent limit for TSS and
pH, respectively (Southern Concrete Materials);
- Six of the seven facilities were in exceedance of the effluent limit for pH. (Concrete
Supply - South Plant, Concrete Supply - North Plant, Concrete Supply - South Plant,
Concrete Supply – Reames Road Plant, Argos, LLC – Hebron Plant, Thomas
Concrete – North Graham Plant); and
- One facility was in exceedance of its effluent limit for pH and TSS (Lucas Concrete).

All procedures for the Industrial Facilities Monitoring Program are outlined in the Industrial
Inspection Procedure Manual and reviewed annually.

9.4 Evaluation Measures

As discussed in sub-section 9.3, the appropriate evaluation measures that were implemented to
reduce polluted discharges to the City’s MS4 were industrial inspections and monitoring.
Inspection letters noted that the inspection was being conducted to satisfy both State and City
NPDES MS4 permit requirements. As pollution sources were identified through the inspection
and monitoring program, CMSWS worked with the NCDEQ and facility personnel to eliminate
the pollution sources. When violations of illicit discharge prohibitions and other applicable
regulations were identified, enforcement measures were implemented by the City or NCDEQ, as
applicable.

9.5 Measurable Goals/Planned Activities for Future Program Years

Table 9-5 describes the various Industrial Facilities Program BMPs and the Measurable Goals
and Planned Activities for Future Program Years for each BMP by permit term year.
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Table 9-5: BMP Measurable Goals for the Industrial Facilities Program.

BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Maintain an
Inventory of
Industrial
Facilities
Maintain an inventory of permitted hazardous waste treatment, disposal, and
recovery facilities, industrial facilities that are subject to Section 313 of Title III of
the Superfund Amendments and Reauthorization Act of 1986 (SARA), industrial
facilities identified with an industrial activity permitted to discharge stormwater to
the permittee’s MS4, or as identified as an illicit discharge under the IDDE
Program.

For the purposes of this permit, industrial activities shall mean all permitted
industrial activities as defined in 40 CFR 122.26.

Maintain and update the industrial facility inventory as needed.
(On-going, years 1 – 5+)
Inspection
Program
Identify priorities and inspection procedures. At a minimum, priority facilities
include those identified above in subsection II.H.2.a.
Update current Industrial Inspection and Monitoring
Procedures and develop an inspection prioritization strategy.
(On-going, years 1 – 5+)
Evaluate
Industrial
Facilities
discharging
stormwater to
the City’s MS4
The Permittee is required to evaluate control measures implemented at permitted
hazardous waste treatment, disposal, and recovery facilities, industrial facilities that
are subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), industrial facilities identified with an
industrial activity permitted to discharge stormwater to the permittee’s MS4, or as
identified as an illicit discharge under the IDDE Program.

For permitted facilities, the municipality shall establish procedures for reporting
deficiencies and non-compliance to the permitting agency. Where compliance with
an existing industrial stormwater permit does not result in adequate control of
pollutants to the MS4, municipality will recommend and document the need for
permit modifications or additions to the permit issuing authority.

For the purposes of this permit, industrial activities shall mean all permitted
industrial activities as defined in 40 CFR 122.26. For the purpose of this permit, the
Permittee is authorized to inspect the permitted hazardous waste treatment,
disposal, and recovery facilities as an authorized representative of the Director.
Conduct inspection activities based on established procedures
and prioritization strategy at 50 facilities for years 1 and 2; and
40 facilities in years 3 -5+. Conduct stormwater runoff
monitoring at 10 facilities for years 1 and 2; and 8 facilities in
years 3 -5+.
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9.6 Program Assessment

The overall Industrial Facilities and Monitoring Program was successfully implemented during
the annual report period. Table 9-6 shows a summary of the various items and corresponding
data results for activities conducted under the program.

Table 9-6: Program Summary
INDUSTRIAL FACILITIES PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Master industrial inspection inventory sites 514
Industrial facilities inspected 40
Vehicle maintenance facilities inspected 20
Machine shop facilities inspected 3
Industrial facilities monitored 12
Industrial facility Notice of Deficiencies issued 15
Illicit discharges or connections
detected/corrected 12

The following is clarification of certain numbers provided in Table 9-6:

• Site inventory includes: 187 industrial facilities with an NPDES stormwater permit; 77
facilities with a stormwater No Exposure Certificate; 60 facilities with a CW pre-
treatment permit; 181 facilities classified as a TRI submitter; and 9 facilities classified as
a TSD facility; and
• Number of industrial facility (not including vehicle maintenance facilities) deficiencies
with notices issued includes industrial facilities whose reports were issued as an NOV or
Unsatisfactory with regard to their compliance with the City’s Stormwater Pollution
Control Ordinance. Facilities with strictly NPDES permit compliance issues (e.g., lack of
required monitoring or training) were not counted in this number.

Section 10: Water Quality Assessment and Monitoring Program

During the annual report period, monitoring activities were conducted per the Water Quality
Assessment and Monitoring program plan and the SWMP. The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

10.1 BMP Summary Table

Table 10-1 provides information concerning the BMPs implemented to fulfill the requirements
of the Water Quality Assessment and Monitoring Program.
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Table 10-1: BMP Summary Table for the Water Quality Assessment and Monitoring Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment and
Monitoring Plan. The Plan shall include a schedule
for implementing the proposed assessment and
monitoring activities.

X X X X X Water Quality
Program
Manager
Water Quality
Monitoring
Maintain and implement the Water Quality
Assessment and Monitoring Plan submitted to
DWQ.

X X X X X Water Quality
Program
Manager

10.2 Water Quality Assessment and Monitoring Plan

The City has been conducting water quality monitoring of streams and stormwater discharges
since the inception of its NPDES MS4 Permit Program in 1992. Initially, the monitoring
program focused mainly on identifying illicit discharges and especially SSOs, and therefore
included sampling for fecal coliform bacteria. Data was used to identify and eliminate these
illicit discharges to the MS4 and surface waters and proved to be highly successful. While
current water quality monitoring efforts continue to be used for this purpose, the program has
been expanded over the years to include a wider array of water quality parameters (Table 10-2)
with the additional goal of identifying short-term and long-term water quality trends and gauging
overall program effectiveness.

Table 10-2: Water Quality Monitoring Parameters.
Parameter Sample Type Frequency (Minimum)
Fecal Coliform Grab Quarterly
E-Coli Grab Quarterly
Total Phosphorus Grab Quarterly
Nitrite + Nitrate Grab Quarterly
Total Kjeldahl Nitrogen Grab Quarterly
Ammonia Nitrogen Grab Quarterly
Total Suspended Solids Grab Quarterly
Turbidity Grab Quarterly
Copper Grab Quarterly
Zinc Grab Quarterly
Chromium Grab Quarterly
Lead Grab Quarterly
Dissolved Oxygen In Situ Quarterly
Temperature In Situ Quarterly
Conductivity In Situ Quarterly
pH In Situ Quarterly

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The City implements the Water Quality Assessment and Monitoring Plan developed during the
previous permit term. The plan specifies the basic water quality monitoring program and
activities to be performed on a quarterly basis at 15 stream sites within the major watersheds in
the City (Figure 10-1; Table 10-3). Monitoring is conducted for chemical and physical
parameters listed in Table 10-2 on a fixed interval monitoring basis.

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FIGURE 10-1

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Table 10-3: Description of City of Charlotte Water Quality Monitoring Sites.
Site # Stream Location
MY11B Mallard Creek Pavilion Blvd Bridge, S. of US Hwy 29
MY12B Back Creek Stream location, off of Wentwater Street, near Caldwell Rd.
MY13 Reedy Creek Reedy Creek Rd. Bridge, S. of Plaza Rd. Ext.
MY7B McKee Creek Reedy Creek Rd. Bridge, S. of Harrisburg Rd.
MC14A Long Creek Pine Island Dr. at End of Street at Golf Course
MC17 Paw Creek Hwy 74 Culvert, Between Sam Wilson & Little Rock Rd.
MC22A Irwin Creek Westmont Dr. Bridge, at Irwin Creek WWTP
MC27 Sugar Creek Hwy. 51 Bridge, E. of Downs Rd.
MC38 McAlpine Creek Sardis Rd. Bridge, Between Sardis Ln. & Sardis Rd. N.
MC40A Four Mile Creek Elm Ln. Bridge, S. of Hwy. 51
MC42 McMullen Creek Sharon View Rd. Bridge, Between Sharon Rd. & Colony Rd.
MC45 McAlpine Creek McAlpine Creek WWTP
MC47A Steele Creek Carowinds Blvd. Culvert, W. of Carowinds Amusement Park
MC49A Little Sugar Creek Hwy. 51 Bridge, W. of Carolina Place Mall
MC51 Six Mile Creek Marvin Rd. Bridge, S. of Ardrey Kell Rd.

10.3 Water Quality Monitoring Implementation

The City conducts a basic quarterly fixed interval monitoring program at the 15 monitoring sites
listed in Table 10-3. Following completion of monitoring activities at the end of each permit
reporting year (June 30th), monitoring data is visually assessed to determine whether water
quality trends are apparent. This can help to gauge the combined effectiveness of NPDES
program efforts. In addition to the basic monitoring required in the plan, the City also conducts
an enhanced monitoring program which includes additional parameters, sites and frequencies to
support other initiatives and management activities.

10.4 Water Quality Assessment and Monitoring Plan Revisions

The City has reviewed the basic monitoring program plan and data generated during FY2019 and
proposes no major changes to that plan at this time.

10.5 Measurable Goals/Planned Activities for Future Program Years

Table 10-4 describes the Water Quality Assessment and Monitoring Program BMPs and the
Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.

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Table 10-4: BMP Measurable Goals for the Water Quality Assessment and Monitoring Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5
Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment
and Monitoring Plan. The Plan shall
include a schedule for implementing
the proposed assessment and
monitoring activities.
Maintain the WQ Assessment & Monitoring Plan and update as necessary. (On-going, years 1 – 5+)
Water Quality
Monitoring
Maintain and implement the Water
Quality Assessment and Monitoring
Plan submitted to DWQ.

Maintain and implement the monitoring plan and conduct WQ assessment and monitoring activities per the plan.
(On-going, years 1 – 5+)
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10.6 Program Assessment

The overall Water Quality Assessment and Monitoring Program was successfully implemented
during the annual report period. Table 10-5 shows a summary of the various items and
corresponding data results for activities conducted under the program.

Table 10-5: Program Summary
WATER QUALITY MONITORING PROGRAM FY2019 FY2020 FY2021 FY2022 FY2023 FY2024
Stream sites monitored1. 15
Stream samples collected1. 60
Laboratory sample analyses conducted1. 720
Stream physical measurements (DO, Temp, pH, Cond) 1. 240
IDDE problems detected/corrected through monitoring 1
1. Data reported is the minimum quarterly amount per the basic monitoring plan.

10.6.1 Water Quality Monitoring Program Evaluation

During FY2017, an evaluation of the enhanced water quality monitoring program was conducted
to determine whether any changes were needed to improve the cost-effectiveness of the program.
This evaluation resulted in the removal of enhanced program parameters Enterococcus and
several total metals (beryllium, selenium, cadmium, and silver) from the monitoring program.
Enterococcus was removed because it was determined to be unnecessary to collect in addition to
E. coli and fecal coliform. The total metals mentioned above were removed because they were
consistently below detection limits and water quality standards. Data analysis continued through
FY2019, but no additional changes to the monitoring program have been made.

10.6.2 Water Quality Trend Analysis

The City utilizes water quality data generated from various monitoring programs, including
NPDES MS4, to generate a Stream Use Support Index. This spatial index visually represents
water quality conditions by sub-basin and can be compared year by year to determine general
trends. The index map for calendar year 2018 is shown below in Figure 10-2. The map shows
general WQ conditions to be in the partially supporting to impaired category for the sub-basins
within the City.

Figure 10-3 shows time series graphs for each non-metal parameter in the monitoring plan for
the ten-year period from Jan 2009 to Jun 2019 (metals are shown separately in Figure 10-4).
Each graph displays median analyte values across all sites for each particular fixed interval
sampling event (i.e., quarterly at minimum, though typically monthly). Additional analyses,
considering each analyte and watershed individually combined with normalization for flow
conditions at the time of sampling, will likely be needed to further discern water quality trends.
These analyses are ongoing and may be reported in future annual reports.

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FIGURE 10-2

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FIGURE 10-3

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Figure 10-4 shows data for the metals included in the monitoring plan for the period of July
2010 through June 2019. These data have been plotted as the difference between individual
sample results and the acute dissolved standard at the sample’s hardness value to better illustrate
exceedances and non-exceedances on a temporal basis. As a result, the vertical axes represent
how far above or below the standard a given sample was, as opposed to showing absolute sample
concentrations. Samples collected prior to implementation of the dissolved metals standards are
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also shown relative to the current dissolved metals standards, as this gives a better picture of
historical toxicity.

The City has analyzed fixed interval samples for dissolved copper, dissolved lead, and dissolved
zinc since July 2015, given that historically total metals samples of those elements have
exceeded the new dissolved metals standards at least once. For chromium, which has never
exceeded the total metal standard or the more protective dissolved standard, the City continues to
analyze on a total basis. It can be seen from Figure 10-4 that copper is the only metal for which
the dissolved standard has been exceeded at any sites since coming into effect in 2015.

FIGURE 10-4

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Section 11: Total Maximum Daily Load (TMDL) Program

The City continued to fulfill the NPDES MS4 permit requirements regarding the TMDL
Program by implementing the following BMPs within the six minimum NPDES MS4 permit
measures. The BMPs are designed to reduce the TMDL pollutant of concern within the TMDL
assigned MS4 NPDES regulated waste load allocation to the maximum extent practicable (MEP)
within the impaired water bodies in the City’s jurisdiction that are subject to approved TMDLs.
The following sub-sections explain:

• The BMPs implemented to meet program requirements;
• Measures of success;
• Future goals and planned activities; and
• Program assessment.

11.1 BMP Summary Table

Table 11-1 provides information concerning the BMPs implemented to fulfill the Total
Maximum Daily Load (TMDL) Program requirements.

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Table 11-1: BMP Summary Table for Total Maximum Daily Load (TMDL) Program.
BMP

BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Identify, describe
and map
watershed, outfalls,
and streams

Within 24 months the permittee shall prepare a plan
that:
• Identifies the watershed(s) subject to an
approved TMDL with an approved Waste Load
Allocation (WLAs) assigned to the permittee,
• Includes a description of the watershed(s),
• Includes a map of watershed(s) showing streams
& outfalls
• Identifies the locations of currently known major
outfalls within its corporate limits with the
potential of contributing to the cause(s) of the
impairment to the impaired segments, to their
tributaries, and to segments and tributaries
within the watershed contributing to the
impaired segments and
• Includes a schedule to discover and locate other
major outfalls within its corporate limits that
may be contributing to the cause of the
impairment to the impaired stream segments, to
their tributaries, and to segments and tributaries
within the watershed contributing to the
impaired segments.
X X X X Water Quality
Program
Manager
Existing measures

Within 24 months the Permittee’s plan:
• Shall describe existing measures being
implemented by the Permittee designed to
achieve the MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP
within the watershed to which the TMDL
applies; and
• Provide an explanation as to how those measures
are designed to reduce the TMDL pollutant of
concern.
• The Permittee shall continue to implement the
existing measures until notified by DWQ.
X X X X Water Quality
Program
Manager
Assessment of
available
monitoring data
Within 24 months the permittee’s plan shall include
an assessment of available monitoring data. Where
long-term data is available, this assessment should
include an analysis of the data to show trends.
X X X X Water Quality
Program
Manager
Monitoring Plan

Within 36 months the permittee shall develop and
submit to the Division a Monitoring Plan for the
permittee’s assigned NPDES regulated WLA as
specified in the TMDL. The permittee shall maintain
and implement the Monitoring Plan as additional
outfalls are identified and as accumulating data may
suggest. Following any review and comment by the
Division the permittee shall incorporate any
necessary changes to monitoring pla n and initiate the
plan within six months. Modifications to the
monitoring plan shall be approved by the Division.
Upon request, the requirement to develop a
X X X Water Quality
Program
Manager
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Monitoring Plan may be waived by the Division if
the existing and proposed measures are determined
to be adequate to achieve the MS4’s NPDES WLA
to MEP within the watershed to which the TMDL
applies.

Additional
Measures
Within 36 months the permittee’s plan shall:
• Describe additional measures to be
implemented by the permittee designed to
achieve the permittee’s MS4’s NPDES
WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to
which the TMDL applies; and
• Provide an explanation as to how those
measures are designed to achieve the
permittee’s MS4’s NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
X X X Water Quality
Program
Manager
Implementation
Plan
Within 48 months the permittee’s plan shall:
• Describe the measures to be implemented
within the remainder of the permit term
designed to achieve the MS4’s NPDES
WLA and to reduce the TMDL pollutant of
concern to the MEP and
• Identify a schedule, subject to DWQ
approval, for completing the activities.
X X Water Quality
Program
Manager
Incremental
Success

The permittee’s plan must outline ways to track and
report successes designed to achieve the MS4’s
NPDES regulated WLA and to reduce the TMDL
pollutant of concern to MEP within the watershed to
which the TMDL applies.
X X Water Quality
Program
Manager
Reporting The permittee shall conduct and submit to the
Division an annual assessment of the program
designed to achieve the MS4’s NPDES WLA and to
reduce the TMDL pollutant of concern to the MEP
within the watershed to which the TMDL applies.
Any monitoring data and information generated from
the previous year are to be submitted with each
annual report.
X X X X Water Quality
Program
Manager

11.2 TMDL Watershed Plan

The City developed a TMDL watershed plan during February 2015 for the applicable identified
watersheds that are subject to an approved TMDL within the City’s jurisdiction as defined in
Part II, Sec J.1 and J.2 within the City’s current NPDES MS4 permit. The plan utilizes BMPs as
outlined in the permit within the six minimum NPDES MS4 permit measures that are designed to
reduce the TMDL pollutant of concern within the TMDL assigned MS4 NPDES regulated waste
load allocation to the MEP. In addition, per Part II, Sec J.3 within the City’s current NPDES
MS4 permit, the plan addresses the pollutant of concern for approved TMDLs that do not assign
a waste load allocation for the pollutant of concern to the municipal stormwater system by
evaluating strategies and tailoring BMPs within the scope of the six minimum permit measures
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to address the pollutant of concern to the MEP in the watershed(s) to which the TMDL applies.
The plan is available for review on the City’s website:
http://charlottenc.gov/StormWater/SurfaceWaterQuality/Documents/CLT%20NPDES%20MS4
%20TMDL%20Watershed%20Plan%20Updates%20-%20Feb%202017%20-%20FINAL.pdf

11.2.1 TMDL Watershed Identification

Section 303(d) of the federal Clean Water Act requires States to identify and establish a priority
ranking for water bodies that do not meet applicable water quality standards (303(d) list),
establish TMDLs for the pollutants causing impairment of these water bodies, and submit the list
of impaired waters and TMDLs to the USEPA. The TMDL process establishes the allowable
loadings of pollutants or other quantifiable parameters for a water body based on the relationship
between pollution sources and in-stream water quality conditions. The TMDL process is used by
States to establish water quality-based controls to reduce pollutants from point and non-point
sources and restore and maintain the quality of the water resources in compliance with applicable
standards. In addition to the 303(d) list, the federal Clean Water Act requires States to submit a
report describing how well water bodies support designated uses (e.g., swimming, aquatic life
support, water supply), as well as likely causes and potential sources of impairment (305(b) list).

As part of the TMDL watershed plan development during FY2015, the City reviewed the
NCDEQ website to determine which TMDLs were in place within the City’s jurisdiction.
Currently, there are seven approved TMDLs applicable to multiple streams in the City, some of
which also include portions of Mecklenburg County. Table 11-2 and Figure 11-1 provide
information on, and a map of, these TMDLs and affected watersheds, respectively. Additional
information concerning these TMDLs is provided in the City’s TMDL Watershed Plan
referenced in section 11.2.

Table 11-2: City of Charlotte Streams with Approved TMDLs
Receiving Stream
Name
WQ
Classification
TMDL Approved TMDL Pollutant of Concern
Irwin Creek C February 1996 Dissolved Oxygen
Little Sugar Creek C February 1996 Dissolved Oxygen
McAlpine Creek C February 1996 Dissolved Oxygen
Lake Wylie WS-IV, B, CA February 1996 Chlorophyll-a
Irwin Creek C March 2002 Fecal Coliform
Little Sugar Creek C March 2002 Fecal Coliform
McAlpine Creek C March 2002 Fecal Coliform
Sugar Creek C March 2002 Fecal Coliform
McKee Creek C August 2003 Fecal Coliform
Irwin Creek C February 2005 Turbidity
Little Sugar Creek C February 2005 Turbidity
Long Creek C February 2005 Turbidity
McAlpine Creek C February 2005 Turbidity
Sugar Creek C February 2005 Turbidity
Steele Creek C May 2007 Fecal Coliform
Statewide All October 2012 Mercury
Source: 2017 NCDEQ – Division of Water Resources website:
http://deq.nc.gov/about/divisions/water-resources
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FIGURE 11-1
Charlotte Approved TMDL Streams

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11.2.2 Outfall Identification for TMDL Watersheds

As part of the development of the TMDL watershed plan, during FY2015 the City developed an
existing outfall inventory for the applicable TMDL watersheds. This inventory is maintained
using a GIS coverage to show existing outfalls within the TMDL watersheds that have the
potential of contributing to the cause(s) of the impairment to the impaired segments, to their
tributaries, and to segments and tributaries within the watershed contributing to the impaired
segments. Additional information on the outfall inventory is provided in the City’s TMDL
Watershed Plan referenced in section 11.2.

11.3 Identification of Existing Measures

As part of the development of the TMDL watershed plan, during FY2015 the City identified
existing programs and measures which are currently in use within the City’s NPDES MS4 permit
and water quality monitoring programs that are designed to address the assigned MS4 NPDES
regulated waste load allocation (WLA) and to reduce the TMDL pollutant of concern to the MEP
within the watershed to which the TMDL applies. Additional information on the existing
measures is provided in the City’s TMDL Watershed Plan referenced in section 11.2.

11.4 Assessment of Available Monitoring Data

Fixed interval surface water quality data collected from 2006 through 2019 have been analyzed
for all applicable TMDL watersheds and pollutants of concern in the City and County. These
data help to illustrate surface water quality trends in relation to the NC surface water quality
standards. The City’s current NPDES MS4 permit, effective October 10, 2018, states that the
“The permittee is not responsible for attaining water quality standards (WQS). The Division
expects attaining WQS will only be achieved through reduction from all point and nonpoint
source contributors identified in the approved TMDL.” It is infeasible to monitor every MS4
stormwater outfall to determine how progress is being made toward achieving MS4 NPDES
WLAs; therefore, the City will utilize fixed interval surface water data to investigate water
quality trends. The data presented below, while illustrating how in-stream water quality has
changed over time, unfortunately are not able to distinguish MS4 contributions from other point
and nonpoint sources that are not under the control of the MS4. Consequently, increases in
surface water contaminants observed in the data do not necessarily indicate that MS4
contributions are also increasing.

11.4.1 Fecal Coliform

Data from the six watersheds listed as being subject to fecal coliform TMDLs in Table 11-2 are
discussed in this sub-section. Of the six watersheds listed in Table 11-2, a MS4 NPDES WLA
was only developed for McKee and Steele Creeks. According to Part II, Section J.3 of the City’s
NPDES MS4 permit, for approved TMDLs where a MS4 NPDES WLA for the pollutant of
concern is not assigned to the municipal stormwater system, the Permittee is still required to
“evaluate strategies and tailor BMPs within the scope of the six minimum permit measures to
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address the pollutant of concern in the watershed(s) to which the TMDL applies.” Watersheds
with and without MS4 WLAs are discussed in the subsections below.

11.4.1.1 McKee Creek

Fixed interval stream data for fecal coliform was collected at the CMSWS monitoring site
MY7B on McKee Creek. A summary of the data collected from July 2006 through July 2019 is
provided in Figure 11-2. A total of 157 samples have been collected over this period under the
fixed interval monitoring program. Of these, 53% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be more frequent and more extreme under wet
weather influenced sampling conditions (meaning some precipitation within the County in the
72-hour preceding the sampling event), however exceedances did occur under both ambient and
wet weather influenced conditions.

Figure 11-2: McKee Creek –MY7B - Overall Monitoring Data

11.4.1.2 Steele Creek Watershed

Fixed interval stream data for fecal coliform were collected at the CMSWS monitoring site
MC47A on Steele Creek. A summary of the data collected from July 2006 through July 2019 is
provided in Figure 11-3. A total of 171 samples have been collected over this period under the
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fixed interval monitoring program. Of these, 51% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be more frequent and more extreme under wet
weather influenced sampling conditions (meaning some precipitation within the County in the
72-hour preceding the sampling event), however exceedances did occur under both ambient and
wet weather influenced conditions.

Figure 11-3: Steele Creek –MC47A - Overall Monitoring Data

11.4.1.3 Sugar/Irwin Creek Watershed

There are two fixed interval monitoring locations in the Sugar Creek watershed, MC27 in
southern Mecklenburg County, and MC22A on Irwin Creek just before its confluence with Sugar
Creek. An assessment of available watershed and water quality data was conducted utilizing
fixed interval stream data for fecal coliform collected at these two monitoring locations. A
summary of the data collected from July 2006 through July 2019 is provided in Figures 11-4
and 11-5.

A total of 165 samples have been collected at MC27 over this period under the fixed interval
monitoring program. Of these, 43% exceeded the 400 cfu/100mL State standard with 90%
confidence. Exceedances tended to be more frequent and more extreme under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
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preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

Figure 11-4: Sugar Creek –MC27 - Overall Monitoring Data

During the same period, a total of 162 samples were collected at MC22A under the fixed interval
monitoring program. Of these, 47% exceeded the 400 cfu/100mL State standard with 90%
confidence. Exceedances tended to be more frequent and more extreme under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

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Figure 11-5: Irwin Creek –MC22A - Overall Monitoring Data

11.4.1.4 Little Sugar Creek Watershed

There are two monitoring locations on Little Sugar Creek, MC49A in southern Mecklenburg
County just outside the City, and MC29A-1 just downstream of downtown area of the City. An
initial assessment of available watershed and water quality data was conducted utilizing fixed
interval stream data for fecal coliform collected at these two monitoring locations. A summary
of the data collected from July 2006 through July 2019 is provided in Figures 11-6 and 11-7.

A total of 166 samples have been collected at MC49A over this period under the fixed interval
monitoring program. Of these, 53% exceeded the 400 cfu/100mL State standard with 90%
confidence. Exceedances tended to be more frequent and more extreme under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

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Figure 11-6: Little Sugar Creek –MC49A - Overall Monitoring Data

A total of 173 samples have been collected at MC29A-1 over this period under the fixed interval
monitoring program. Of these, 79% exceeded the 400 cfu/100mL State standard with 90%
confidence. Exceedances tended to be more frequent and more extreme under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

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Figure 11-7: Little Sugar Creek –MC29A-1 - Overall Monitoring Data

11.4.1.5 McAlpine Creek Watershed

There are two monitoring locations on McAlpine Creek, MC45B just downstream of the North
Carolina/South Carolina border, and MC38 downstream of the confluence with Campbell Creek
and Irvins Creek. An initial assessment of available watershed and water quality data was
conducted utilizing fixed interval stream data for fecal coliform collected at these two
monitoring locations. A summary of the data collected from July 2006 through July 2019 is
provided in Figures 11-8 and 11-9.

A total of 161 samples have been collected at MC45B over this period under the fixed interval
monitoring program. Of these, 34% exceeded the 400 cfu/100mL State standard with 90%
confidence. Exceedances tended to be much more frequent under wet weather influenced
sampling conditions (meaning some precipitation within the County in the 72-hour preceding the
sampling event), however exceedances did occur under both ambient and wet weather influenced
conditions.

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Figure 11-8: McAlpine Creek –MC45B - Overall Monitoring Data

A total of 166 samples have been collected at MC38 over this period under the fixed interval
monitoring program (Figure 11-9). Of these, 48% exceeded the 400 cfu/100mL State standard
with 90% confidence. Exceedances tended to be much more frequent and more extreme under
wet weather influenced sampling conditions (meaning some precipitation within the County in
the 72-hour preceding the sampling event), however exceedances did occur under both ambient
and wet weather influenced conditions.
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Figure 11-9: McAlpine Creek –MC38 - Overall Monitoring Data

11.4.1.6 Fecal Coliform Summary

The State standard for fecal coliform is exceeded by more than 10% with 90% confidence for all
watersheds with a fecal coliform TMDL identified above, based on fixed interval data collected
between 2006 and 2019. These exceedances are more common in wet weather influenced
conditions, but exceedances also occurred during ambient conditions in each of these watersheds.
Since exceedance rates are highly influenced by wet weather, long term variations in the
exceedance rates should account for how many samples in a given year are influenced by wet
weather conditions. For instance, between August 2008 and July 2009, approximately 27% of
samples were collected during wet weather conditions, whereas in the past two years (Aug 2017-
July 2018 and Aug 2018 – July 2019), 69% and 87% of fixed interval samples were collected
during wet weather conditions, respectively. A higher percentage of wet weather events on fixed
interval sampling days is expected to result in a higher percentage of samples that exceed water
quality standards. Since “wet weather” is defined as at least 0.1 inches of rainfall recorded
anywhere in the City of Charlotte/Mecklenburg County in the 72 hours prior to sampling, future
analysis may also attempt to utilize rain gages in closer proximity to each monitoring station to
more accurately verify whether a sample was influenced by wet weather conditions, as rainfall in
one part of the City/County does not necessarily mean it is raining everywhere in the
City/County.

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11.4.2 Turbidity

As discussed in sub-section 2.2, the turbidity TMDL developed in 2005 included five Charlotte-
Mecklenburg watersheds but only developed a WLA for turbidity for Long Creek since the water
quality data assessment performed for the TMDL demonstrated that the remaining four
watersheds had less than a 10% exceedance rate of the 50 NTU State standard. Therefore, this
sub-section includes an assessment of turbidity data only for Long Creek.

11.4.2.1 Long Creek Watershed

An initial assessment of available watershed and water quality data was conducted utilizing
stream data for turbidity collected at the CMSWS monitoring site MC14A on Long Creek. A
summary of the data collected from January 2010 through July 2019 is provided in Figure 11-
10. A total of 156 samples were collected during this period, with 16% exceeding the 50 NTU
State standard with 90% confidence. These exceedances all occurred under wet weather
conditions.

Figure 11-10: Long Creek –MC14A - Overall Monitoring Data

11.4.3 Dissolved Oxygen

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As stated in sub-section 2.3, the 1996 dissolved oxygen (DO) TMDL for Irwin Creek, McAlpine
Creek, and Little Sugar Creek did not include a MS4 NPDES WLA. Nevertheless, since the
City’s NPDES MS4 permit states in Part II, Section J.3, for approved TMDLs where a MS4
NPDES WLA for the pollutant of concern is not assigned to the MS4, the Permittee is still
required to “evaluate strategies and tailor BMPs within the scope of the six minimum permit
measures to address the pollutant of concern in the watershed(s) to which the TMDL applies.”
For this reason, the dissolved oxygen data is provided below in Figures 11-11 through 11-15.

Unlike the other parameters, for dissolved oxygen the State standard is violated when
concentrations go below the standard rather than exceeding the standard. Based on the fixed
interval sampling conducted between July 2006 and July 2019, only one sample collected from a
TMDL watershed was lower than the instantaneous State standard of 4 mg/L. On October 10,
2017, a value of 3.81 mg/L was recorded at McAlpine Creek (MC38). No other sample violated
the standard during this period of record. The 2018 NC Integrated Report categorizes each of
these watersheds as 1i for DO, meaning that they have a TMDL but are not impaired and are
supporting their designated uses.

Figure 11-11: Irwin Creek–MC22A - Overall Monitoring Data

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Figure 11-12: McAlpine Creek –MC45B - Overall Monitoring Data

Figure 11-13: McAlpine Creek –MC38 - Overall Monitoring Data
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Figure 11-14: Little Sugar Creek –MC49A - Overall Monitoring Data

Figure 11-15: Little Sugar Creek –MC29A-1 – Overall Monitoring Data
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11.4.4 Chlorophyll a

As stated in sub-section 2.4, Mecklenburg County is responsible for providing annual assessment
reports for the Lake Wylie chlorophyll-a TMDL under their NPDES MS4 permit program.

11.4.5 Mercury

NCDEQ did not consider it necessary to include an MS4 NPDES WLA for mercury in their
statewide TMDL. For this reason, mercury data is not analyzed under the City’s TMDL
Watershed Plan.

11.5 Monitoring Plan for Assigned MS4 NPDES Regulated Waste Load Allocation

As part of the TMDL watershed plan, during FY2016 the City developed a monitoring plan for
each pollutant of concern with an assigned MS4 NPDES regulated WLA within each watershed
with an approved TMDL within the City’s jurisdiction. The purpose of the monitoring plan is to
guide activities for data collection and assessment of pollutants of concern as well as to evaluate
the effectiveness of achieving the regulated waste load allocation (WLA) identified within the
TMDL. In developing the monitoring plan, sample locations were selected to assess water
quality conditions within each TMDL watershed. Additional information concerning the
monitoring plan is provided in the City’s TMDL Watershed Plan referenced in section 11.2.

11.6 Identification of Additional Measures

As part of the TMDL watershed plan, during FY2016 the City identified additional measures for
implementation within the City’s MS4 permit program that are designed to achieve the assigned
MS4 NPDES regulated WLA and to reduce the TMDL pollutant of concern to the MEP within
the watershed to which the TMDL applies. The plan also discusses how the additional measures
are designed to reduce the TMDL pollutant of concern. Additional information concerning these
measures is provided in the City’s TMDL Watershed Plan referenced in section 11.2.

11.7 Implementation of Additional Measures

During FY2017 the TMDL watershed plan was updated to discuss the implementation of the
additional programs and measures identified in sub-section 11.6. Additional information
concerning these measures is provided in the City’s TMDL Watershed Plan referenced in section
11.2 above.

11.8 Tracking Incremental Success

During FY2017, various BMP data parameters were identified to track incremental success
within the TMDL watershed plan. These parameters and corresponding data for FY2019 are
shown in sub-section 11.10 below.

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11.9 Measurable Goals

Table 11-3 describes the various Total Maximum Daily Load (TMDL) Program BMPs and the
Measurable Goals for each BMP by permit term year.

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Table 11-3: BMP Measurable Goals for Total Maximum Daily Load (TMDL) Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5+
Identify, describe
and map
watershed, outfalls,
and streams

Within 24 months the permittee shall prepare a plan that:
• Identifies the watershed(s) subject to an approved
TMDL with an approved Waste Load Allocation
(WLAs) assigned to the permittee,
• Includes a description of the watershed(s),
• Includes a map of watershed(s) showing streams &
outfalls
• Identifies the locations of currently known major
outfalls within its corporate limits with the potential of
contributing to the cause(s) of the impairment to the
impaired segments, to their tributaries, and to
segments and tributaries within the watershed
contributing to the impaired segments and
• Includes a schedule to discover and locate other major
outfalls within its corporate limits that may be
contributing to the cause of the impairment to the
impaired stream segments, to their tributaries, and to
segments and tributaries within the watershed
contributing to the impaired segments.
None Develop TMDL
Watershed Plan
per requirements
of the MS4
permit by Feb
28, 2015.
Update TMDL Watershed Plan as necessary. (On-going, years
3 – 5+)
Existing measures

Within 24 months the Permittee’s plan:
• Shall describe existing measures being implemented
by the Permittee designed to achieve the MS4’s
NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to which the
TMDL applies; and
• Provide an explanation as to how those measures are
designed to reduce the TMDL pollutant of concern.
• The Permittee shall continue to implement the existing
measures until notified by DWQ.
None Identify existing
measures within
TMDL plan by
Feb 28, 2015.
Continue to implement existing measures per TMDL plan.
(On-going, years 3 – 5+)
Assessment of
available
monitoring data
Within 24 months the permittee’s plan shall include an
assessment of available monitoring data. Where long-term
data is available, this assessment should include an
analysis of the data to show trends.

None Conduct a
review and
assessment of
available
monitoring data
by Feb 28, 2015.
Continue to review and assess monitoring data as it becomes
available. (On-going, years 3 – 5+)
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Monitoring Plan

Within 36 months the permittee shall develop and submit
to the Division a Monitoring Plan for the permittee’s
assigned NPDES regulated WLA as specified in the
TMDL. The permittee shall maintain and implement the
Monitoring Plan as additional outfalls are identified and as
accumulating data may suggest. Following any review and
comment by the Division the permittee shall incorporate
any necessary changes to monitoring plan and initiate the
plan within six months. Modifications to the monitoring
plan shall be approved by the Division. Upon request, the
requirement to develop a Monitoring Plan may be waived
by the Division if the existing and proposed measures are
determined to be adequate to achieve the MS4’s NPDES
WLA to MEP within the watershed to which the TMDL
applies.

None None Develop
monitoring
plan for each
TMDL
watershed for
the TMDL
pollutants of
concern by
Feb 28, 2016.
Complete monitoring
activities specified in
the plan by June 30,
2017. Assess
monitoring data
collected under the
monitoring plan to
determine
effectiveness of
Water Quality
Programs by
December 31, 2017.
Update monitoring
plan as necessary
based on data review
and assessment
activities.

Complete monitoring
activities specified in
the plan by June 30,
2018. Assess
monitoring data
collected under the
monitoring plan to
determine
effectiveness of
Water Quality
Programs by
December 31, 2018.
Update monitoring
plan as necessary
based on data review
and assessment
activities.

Additional
Measures
Within 36 months the permittee’s plan shall:
• Describe additional measures to be implemented
by the permittee designed to achieve the
permittee’s MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP within
the watershed to which the TMDL applies; and
• Provide an explanation as to how those measures
are designed to achieve the permittee’s MS4’s
NPDES regulated WLA to the MEP within the
watershed to which the TMDL applies.

None None Determine
additional
measures that
may be needed
to achieve
assigned MS4
NPDES
regulated
WLA and
address TMDL
pollutant of
concern by
Feb 28, 2016.
Continue to evaluate and update additional
measures per TMDL plan, as needed. (On-
going, years 4 – 5+)
Implementation
Plan
Within 48 months the permittee’s plan shall:
• Describe the measures to be implemented within
the remainder of the permit term designed to
achieve the MS4’s NPDES WLA and to reduce
the TMDL pollutant of concern to the MEP and
• Identify a schedule, subject to DWQ approval, for
completing the activities.

None None None Develop an
implementation plan
for identified
additional measures
that may be needed to
achieve assigned
MS4 NPDES
regulated WLA and
address TMDL
Continue to
implement additional
measures per the
plan.
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pollutant of concern
by Feb 28, 2017.
Incremental
Success

The permittee’s plan must outline ways to track and report
successes designed to achieve the MS4’s NPDES regulated
WLA and to reduce the TMDL pollutant of concern to
MEP within the watershed to which the TMDL applies.

None None None Develop a
methodology to track
and report data and
successes for
identified additional
measures that may be
needed to achieve
assigned MS4
NPDES regulated
WLA and address
TMDL pollutant of
concern by June 30,
2017.
Continue to track and
report successes per
the plan.
Reporting The permittee shall conduct and submit to the Division an
annual assessment of the program designed to achieve the
MS4’s NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to which the
TMDL applies. Any monitoring data and information
generated from the previous year are to be submitted with
each annual report.

None Prepare an annual assessment of activities and data analysis for the TMDL
watershed plan. Provide this information in the NPDES MS4 permit annual report.
(On-going, years 2 – 5+)
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11.10 Program Assessment and Reporting

The overall TMDL Program and Watershed Plan were successfully implemented during the
annual report period. Table 11-4 shows a summary of the various BMPs implemented and
corresponding data results per TMDL watershed for the report period. BMPs that apply to the
City or a program as a whole, such as television advertisements, cannot be differentiated by
watershed and are therefore reported as “Citywide.” Additional information concerning these
BMPs is provided in the City’s TMDL Watershed Plan referenced in sub-section 11.2.

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Table 11-4: TMDL Program Summary for FY2019
TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Public Education and Outreach
Television advertising spots 876
Radio advertising spots 48
Social media posts 620
Social media responses 1,045
Public requests to stormwater hotline – WQ related 553
School presentations 2 01. 11 15 27 01. 4 1
Students educated at school presentations 56 01. 342 360 696 01. 96 20
Public presentations 18
Citizens educated at public presentations 620
Public events 33
Attendees at public events 3,970
Website page views 376,617
Website unique page views 158,480
Utility bill inserts 112,995 71,651 231,569 73,270 301,779 9,846 38,574 53,728
CMCSI education workshops conducted 3
Citizens educated at CMCSI workshops 289
Pet waste messages 17
Environmental notices and brochures distributed 4
Flow Free (Fats Oils & Grease-FOG) brochures distributed 2,231
Flow Free (FOG) presentations 12
Citizens educated on Flow Free (FOG) program 1,640
1. Activity not conducted in this watershed during fiscal year 2019.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Public Involvement
Storm drains marked 119 01. 70 66 538 01. 01. 402
Adopt-A-Stream trash removed (lbs.) 8,050 01. 27,678 405 4,838 01. 785 1,070
Adopt-A-Stream miles cleaned 23 01. 56 3 28 01. 4.5 4.3
Big Spring Clean trash removed (lbs.) 2,410 10,850 3,525 01. 5,690 01. 01. 01.
Big Spring Clean stream miles cleaned 2 6 3 01. 5 01. 01. 01.
Volunteer Monitoring samples collected 4 01. 01. 01. 28 01. 01. 01.
Volunteer Monitoring visual observations 15 01. 87 01. 01. 01. 01. 01.
Trees planted during tree planting volunteer events 486
Adopt-A-Street bags of trash collected 2,563
Adopt-A-Street bags of recyclables collected 483
Adopt-A-Street miles cleaned 460
1. Activity not conducted in this watershed during fiscal year 2019.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Illicit Discharge Detection and Elimination (IDDE)
Stream walk miles inspected 01. 01. 15.47 01. 201.49 01. 01. 01.
Stream walk outfalls inspected 01. 01. 102 01. 910 01. 01. 01.
Dry weather flows detected 01. 01. 25 01. 239 01. 01. 01.
Dry weather flows sampled 01. 01. 8 01. 84 01. 01. 01.
Stream walk IDDE problems detected/corrected 01. 01. 01. 01. 10 01. 01. 01.
Multi-family sewer system inspections 6 01. 19 01. 15 01. 01. 7
Multi-family sewer system personnel trained 01.
Stormwater pollution ordinance violations/NOVs issued 32 5 40 5 19 01. 3 7
Stormwater pollution ordinance penalty enforcements
issued 3 01. 3 01. 2 01. 01. 3
Septic system failures detected/corrected 8 01. 4 12 11 4 01. 9
Municipal employees trained on IDDE 1,993

Sanitary sewer use ordinance NOVs issued 39
Sanitary sewer system pretreatment inspections 200
Sanitary sewer system FOG inspections 5,449
Sanitary sewer system pipe miles cleaned 971
Sanitary sewer system ROW miles cleared 83
Sanitary sewer system miles re-lined 20.1
Sanitary sewer system manholes inspected 8,906
Sanitary sewer system lift stations maintained 82
Sanitary sewer system overflows corrected 162
Pet waste deposits flagged 306
Pet waste receptacles provided 100
IDEP business corridor inspections 2,457
IDEP outfall inspections 01. 01. 01. 01. 01. 01. 01. 01.
IDEP problems detected/corrected 3 01. 5 01. 01. 01. 01. 01.
IDEP fecal sampled collected 12 01. 15 01. 01. 01. 01. 01.
Citizen service requests responded to 85 5 164 31 128 1 14 33
1. Activity not conducted in this watershed during fiscal year 2019.
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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Construction Site Stormwater Runoff Control
Erosion control ordinance NOVs issued 51
Erosion control ordinance penalty enforcements issued 60
Project/site plans reviewed 1,254
Sites inspected 3,513
Post-Construction Stormwater Management
Post-Construction ordinance NOVs and CARs issued 948
Post-Construction education workshops conducted 1 Citizens educated at Post-Construction workshops 128
Project/site plans reviewed 126
Buffer protected/added (acres) 71
Buffer mitigation plans approved 1 01. 4 01. 01. 2 1 2
SCMs added 7 5 17 5 4 01. 5 8
SCMs inspected 137 65 129 102 210 5 113 238
Pollution Prevention/Good Housekeeping
City facilities inspected 11 01. 9 01. 2 01. 01. 5
Stormwater pollution prevention plans implemented 11 01. 9 01. 2 01. 01. 5
Spill prevention response plans implemented 11 01. 9 01. 2 01. 01. 5
Catch basin tops cleaned 47,377
Catch basins cleaned 1,366
Stormwater pipe cleaned (feet) 12,781
Street sweeping (miles swept) 58,818
Street sweeping debris/ROW trash removed (tons)2. 1,260
Yard waste collected (tons) 61,692
1. Activity not conducted in this watershed during fiscal year 2019.
2. Tonnage includes debris/trash picked up from street sweepers and street
ROW debris/trash collected by hand.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Industrial Facilities
Industrial facilities inspected 15 01. 9 3 01. 01. 5 4
Vehicle maintenance facilities inspected 7 01. 4 01. 3 1 01. 4
Industrial facilities monitored 2 01. 2 1 01. 01. 01. 5
Illicit discharges or connections detected/corrected 25 01. 19 1 3 1 1 1
Water Quality Monitoring
Fixed interval TSS samples collected 13 13 52 13 65 13 13 26
Fixed interval Turbidity samples collected 13 13 52 13 65 13 13 26
Fixed interval Dissolved Oxygen samples collected 12 12 48 12 60 12 12 24
Fixed interval Fecal Coliform samples collected 22 13 80 19 92 23 19 36
CMANN Turbidity observations/readings2. 5,738 1,472 62,354 9,689 17,901 3,293 4,677 10,948
CMANN Dissolved Oxygen observations/readings 2. 6,544 2,227 86,226 13,174 23,557 7,055 9,444 14,303
Action/watch level follow-up investigations conducted3. 3 01. 16 2 10 5 4 2
1. Activity not conducted in this watershed during fiscal year 2019.
2. CMANN is an automated monitoring network that collects data readings typically once per hour (select sites collect readings every 15 min.). Data reported is QA/QC accepted data only.
3. Includes Fixed Interval and CMANN program investigations.

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