NCG080063_Tier Three Exceedance_20220815

burg
Y� j� STORM TOM
,WATER
�1 Services
StormW ater.CharMeck.org
August 10, 2022
NC Department of Environmental Quality
DEMLR Stormwater Program h°ors°o�.
Attention: Mr. Zahid Khan "S VQ, 1
°di
610 E. Center Avenue, Suite 301
Mooresville, NC 28115 9'Ooa co
Re: Tier III status at City of Charlotte Fleet Management of
NPDES Industrial Stormwater General Permit NCG080000
Dear Mr. Khan:
This letter is to inform you that the City of Charlotte Fleet Management facility (COC NCG080063)
has exceeded its permit benchmark for total suspended solids (TSS) at Outfall 006 four times
during the current permit term.
The NPDES Industrial Stormwater General Permit NCG080000 standard for TSS is 100 mg/L. The
following summarizes the exceedances that have occurred:
Fleet Management - Outfall 006
Permit Term - TSS Exceedances to date
Date
TSS m L
11 4 2021
194
3 16 2022
126
4/5/2022
240
6 14 2022
201
Outfall 006 is the only outfall sampled at Fleet Management and is representative of the other
outfalls on site. Outfall 006 is sampled where the discharge leaves the paved curb cut surrounding
a dumpster pad. After the sample location, stormwater runoff diffuses through a grassy slope
before entering surface waters.
A stormwater management inspection to identify possible causes and determine feasible actions to
reduce the concentration of TSS was conducted on July 28, 2022. Persons in attendance included
Jeremy Henderson and Ken Bonham from Fleet facility management, Craig Miller and Andrew
DeCristofaro from City of Charlotte Storm Water Services, and Matthew Phillips from Mecklenburg
County Storm Water Services. No industrial activities exposed to stormwater occur in the drainage
area of outfall 006. Several bay doors from the covered vehicle maintenance building have the
potential to discharge to the drainage area if a spill were to occur inside the maintenance area. A
small unused building (former covered equipment wash building), a used tire storage roll -off bin, a
municipal trash dumpster, and a municipal recycling dumpster are also within the drainage area.
No bare earth or stored sediment is present, and all landscaped areas are well covered with grass.
•
21a5Su0e, Avenue
'-� �,�� CM1arlotle, NC 28208
ChE"e.. Streel
� CM1aMfle. NC 28A2
charlottenc.gov

NCDEQ DEMLR Stormwater Program
Attention: Mr. Zahid Kahn
August 10, 2022
Page 2
The asphalt parking lot is worn, with visible cracking. Evaluation of the color and substance of
particulate accumulated at outfall 006 corroborates the source of the TSS concentrations as
particulate generated from the asphalt parking lot deteriorating.
The standard operating and good housekeeping procedures were evaluated for applicability and
efficacy. Several good housekeeping best management practices (BMPs) in the SWPPP were
determined to be applicable. One specific good housekeeping BMP, which states "Sweep waste
product from floors and outdoor concrete surfaces", could be improved by permanently changing
the location of the municipal trash dumpster. This would allow more complete sweeping of the
area immediately surrounding the paved curb cut where outfall 006 is sampled.
In response to this evaluation, specific actions have been selected to include the following:
Permanently changing the location of the municipal trash dumpster for improved sweeping
efficacy in the drainage area - effective immediately
Weekly inspection of the drainage area to assess sediment/particulate accumulation by the
facility manager - effective immediately and continuously ongoing
Increased sweeping schedule for the drainage area - monthly to start effective immediately
and to be modified and further increased as needed and determined by the weekly
inspections
The long-term solution to the problem of the failing asphalt parking lot is to have the area repaved.
The Citys Department of General Services operates the facility but is not the property owner. The
property owner, Mecklenburg County, is aware of this need and will be allocating funds to have a
portion of the facility's parking area repaved in the future. Evaluation of the parking lot condition
has determined the drainage area of outfall 006 as priority for use of these funds. This will be
completed as soon as funds are available for use.
The required monthly analytical monitoring conducted at outfall 006 is sufficient to verify that this
action plan has addressed the source and concentration of TSS discharged with stormwater runoff
from this drainage area.
It is our understanding that this action plan requires your approval. Until approval is received, this
action plan shall be implemented effective immediately. If you request any changes to this plan,
please let me know so they can be incorporated. Feel free to contact me at [phone] with
any questions or concerns regarding this plan.
Sincerely,
Andrew DeCrlstofaro
Water Quality Program Specialist
City of Charlotte Storm Water Services
O •
2145 Sa Avenue 60D Eost mh Street
Chadotl' NC2B2J8 Ct tte. NC 28M
cherlotten<.gov