NCS000040_Fact sheet binder_20240424

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 4/16/2024
Permit Number NCS000040
Owner/Facility Name Charlotte Pipe and Foundry Company/Charlotte
Pipe and Foundry Company
3321 (331511, 332996)/Gray iron foundries(iron
SIC(NAICS)Code/Category foundries, fabricated pipe and pipe fitting
manufacturing)
Basin Name/Sub-basin number Catawba/03-08-34
Receiving Stream/HUC UT to Irwin Creek/030501030101
Stream Classification/Stream Segment C/ 11-137-1
Is the stream impaired on 303 d list]? Yes; See Section 2 below
Any TMDLs? Yes; See Section 2 (below)
Any threatened and/or endangered species? Yes; See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? No
New expiration date 5/31/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Charlotte Pipe and Foundry Company facility is a gray iron foundry manufacturing soil pipe and
fittings by melting iron and then casting pipes and fittings. Information available in the permit file
history states the facility has been operating as a pipe foundry since 1926 and stored and distributed cast
iron scrap, coke, coal, limestone, quartz, sand, silicon, bentonite, petroleum-asphalt, gasoline, and diesel
fuel. The facility is in the process of shutting down and the only process operations remaining are fitting
cleaning,pipe reaming, and pipe E-coat operations.
Per information provided via email 2/l/2024, the only bulk storage tanks currently being used are the
diesel tank gasoline tank, EG diesel tanks, and used oil tank. The feldspar silo is not currently used,but
there is a residual amount remaining to be disposed, and other bulk material tanks/silos have been
emptied. Information in the permit file history states activities onsite previously included loading and
unloading of bulk solid materials from railcars and trucks, storage of raw materials, storage of products
and intermediate products, bulk ASTs, truck fueling station, and wastewater treatment operations.
Per information provided via email 2/5/2024, the facility has stormwater filters in most drains around the
building structure housing process operations and at the culverts where drainage occurs from the
property. Outfalls A and B are sheet flow and are taken at the property line after the filter, and Outfall C
is sheet flow to a storm drain before the filter.
Per the permit renewal application, the following activities are onsite (drainage areas not specified):
• Loading/unloading areas
• One 50-ton sand silo (no longer used)
• One feldspar silo (no longer used)
• One 550-gallon used oil storage tank
Page 1 of 8

• Oil drums
• Materials stored in totes and drums
SW004: Drainage Area 4
Drainage area consists of the Product Bundling Shed(currently unused), office building (currently
unused), water treatment, Shipping Department building (currently unused), Pattern Storage building
(currently unused), and paved areas. There is continuous flow through many of the storm drainage
structures due to groundwater entering the stormwater system upstream of the facility.
SW005: Drainage Area 5
Drainage area consists of two (2) office buildings, a machine shop, a welding shop, scrap iron storage
areas, and parking areas. There is continuous flow through many of the storm drainage structures due to
groundwater entering the stormwater system upstream of the facility.
SW006: Drainage Area 6
Drainage area consists of the Pattern Storage building (currently unused), paved drives and parking, and
a 15,000-gallon hot dip asphalt tank(emptied). There is continuous flow through many of the storm
drainage structures due to groundwater entering the stormwater system upstream of the facility.
SW007: Drainage Area 7
Drainage area consists of the main foundry buildings, support buildings, bulk material spent storage
area, fuel ASTs, fueling station, oil storage building (Oil House),parking and storage areas, fuel AST
area, and the bulk material spent storage area(stores spent bulk materials, fuel storage tanks, bin storage
for finished products, and miscellaneous equipment). There is continuous flow through many of the
storm drainage structures due to groundwater entering the stormwater system upstream of the facility.
Outfall SW008: Outfall A(represents drainage area 4)
Drainage area consists of pipe storage, Product Bundling shed, office building, wastewater treatment,
Shipping Department building, Pattern Storage building, and paved areas.
Outfall SW009: Outfall B (represents drainage areas 5 and 6)
Drainage area consists of the pattern storage building, two (2) office buildings, machine shop, welding
shop, scrap iron storage areas, slag storage, a 15,000-gallon hot dip asphalt tank(emptied), and parking
areas.
Outfall SWO10: Outfall C (represents drainage area 7)
Drainage area consists of main foundry buildings, support buildings, bulk material spent storage area
(spent bulk materials, fuel storage tanks, finished product storage, miscellaneous equipment), one (1)
10,000 gallon gasoline AST, one (1) 10,000 gallon diesel AST, fueling station, oil storage building,
transformer area, and parking areas.
Additional drainage areas:
SW001: Drainage Area 1
Drainage area consists of the Gundrill room(currently unused),parking areas, and storage areas
(including coke, limestone, and slag). This area does not accurately represent stormwater flow from
industrial areas (includes runoff from stormwater drains not on Charlotte Pipe property and I-277).
Page 2 of 8

SW002: Drainage Area 2
Drainage area consists of a warehouse and parking areas. All items are currently in the process of being
removed from the Warehouse. There is no industrial activity in this area.
SW003: Drainage Area 3
Drainage area consists of three (3) storage buildings, the Quality Control building (currently unused),
and paved areas. Stormwater from this area sheet flows and there is no industrial activity in this area.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance Historv:
• October 2018 to June 2023, benchmarks exceeded for:
o SW001 (A): Copper 3x, Zinc 4x,pH 3x
o SW002 (B): Copper 8x, Zinc lOx, TSS 6x, pH min not reached Ix, COD 3x
o SW003 (C): Copper lOx, Zinc 12x, TSS 7x, pH min not reached 2x, COD 4x
• Per letter dated 5/27/2020, tier relief granted for all outfalls for all parameters
o Per additional information provided by the permittee2/l/2024, a letter dated 5/27/2020
granted regulatory relief from the Tier responses based on the condition that the TSS
Abatement/Best Management Plan be continued, and that quarterly reports documenting
maintenance be submitted.
• Per letter dated 5/27/2020 (based on 5/21/2020 inspection report), ROS granted for Outfalls A,
B, and C to be representative of the whole site.
• Per the February 2024 Charlotte-Mecklenburg Stormwater Services inspection report:
o The facility manufactures fittings and started the process of shutting down this location in
August 2023. Most processes have been moved to their new facility in Oakboro,NC
Page 3 of 8

o Defective pipe was observed to be stored outdoors. Bulk material was observed to be
contained within a bay outdoors. Several outdoor material storage areas are no longer in
use. No stormwater pollution issues were observed.
o Most processing has ceased while the facility is moved to a new location. Processing was
observed to occur indoors. No stormwater pollution issues were observed.
303(d) listing:
Irwin Creek C 11. FW Miles
638 From source to Sugar Creek
PARAMETER IR CATEGORY CRITERIA STATUS ' REASON FOR RATING 3031)YEAR
Fish Community(Nar,AL,FW) I K—IlExceeding Criteria IFair,Poor or Severe Biodassificatian [ 20W
Benthos(Nar,AL,FW) 0 Exceedin Criteria Fair,Poor or Severe Bioclassification L
TMDL:
A TMDL exists for fecal coliform for Irwin Creek in the Catawba River Basin, which includes discharge
point(s) for the Charlotte Pipe and Foundry Company.
Threatened/Endangered Species:
There are threatened/endangered species in the nearby vicinity of the facility including Tall Larkspur
(Delphinium exaltatum; NC status: T), Smooth Coneflower(Echinacea laevigata; NC status: T; Federal
status: T), American Peregrine Falcon (Falco peregrinus anatum;NC status: E), and Carolina
Heelsplitter(Lasmigona decorate; NC status: E; Federal status: E).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for October 2018 to June 2023. Quantitative sampling included pH, TSS, O&G, COD, copper,
lead, and zinc.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities. Below is a table of the proposed monitoring for each outfall at the
Charlotte Pipe and Foundry Company site.
Page 4 of 8

Outfalls SW004, SW005, SW006, SW007,
SWO08 (A), SWO09 (B), and SW010 C
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
H BASIS: Pollutant indicator and important to interpreting toxicity potential
p of metals.
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Standard monitoring parameter; Potential pollutant from
lubricants; Method 1664 SGT-HEM targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Standard monitoring parameter; Potential pollutant from drainage
area
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Copper BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Lead BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Zinc BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metals is required
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan (SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
Page 5 of 8

benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Copper Total 10 /L Acute Aquatic Criterion, '/2 FAV
Lead Total 75 /L Acute Aquatic Criterion, '/2 FAV
Zinc Total 126 /L Acute Aquatic Criterion, '/2 FAV
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Page 6 of 8

Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• Regulatory citations added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• Feasibility study requirement removed per updated stormwater program requirements
• Annual online SWPPP certification requirement removed per updated stormwater program
requirements
• eDMR requirement updated
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Outfall-specific monitoring has been implemented to reflect industrial activity and potential
pollutants specific to each discharge area
• Monitoring for total hardness added for outfalls where monitoring for hardness dependent metals
is required
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Page 7 of 8

Section 5. Changes from draft to flnal:
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 1/8/2024
• Initial contact with Regional Office: 1/8/2024
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 3/6/2024
• Final permit sent for supervisor signature: N/A
Section 7. Comments received on draft permit:
• Jenny Pappalardo (Charlotte Pipe; via email 3/11/2024): I have reviewed the draft permit and
have the following comments/questions:
o Representative Outfall Status,p 10 & Table 1,p 15: I have attached a letter from James
Moore dated May 27, 2020 that notes that Outfalls A, B & C shall be the representative
outfalls for the facility. Is this still effective? If so, please update Table 1 header(p15)
and outfall descriptions (p15-16).
■ DEMLR response: Representative outfall status (ROS)resets with permit
issuance. In order to maintain current ROS, as it is a separate review process and
not handled during permit renewal, you will need to attach the completed ROS
Renewal Certification Form and prior documentation that was provided when the
Division originally granted ROS to the Stormwater Upload Form.
o Relief from Monitoring: The attached letter from James Moore dated May 27, 2020 gave
us Relief from Monthly Monitoring for Outfalls A, B & C. Is this still effective?
■ DEMLR response: Per the policy of the Stormwater Permitting Program, Tiered
Response relief effectively ends at the new permit cycle. Conditions start over at
baseline monitoring, and permittees will have to seek relief again if/when
appropriate.
• Byron Hamstead (via email 3/29/2024): Pursuant to Section 7 of the Endangered Species Act
(ESA), we offer the following comments on the draft NPDES Permit for the Charlotte Pipe and
Foundry Co in Mecklenburg Co:
o The draft permit suggests the proposed action area(50CFR 402.02) drains into occupied
habitat for federally listed species including the federally endangered Carolina
heelsplitter(Lasmigona decorata) and federally threatened smooth coneflower
(Echinacea laevigata). Presumably, mention of these species is based on Natural
Heritage Program(NHP) data. According to NHP data, accounts of Carolina heelsplitter
in this reach of Irwin creek are historic (pre-1880) as are records of smooth coneflower
(pre-1900). Based on the information provided, habitats within the proposed action area
are significantly disturbed due to a legacy of urban development activities and are highly
unlikely to support these or any other federally listed species.
Page 8 of 8

The Beaufort Gazette Durham I The Herald-Sun The Modesto Bee
The Belleville News-Democrat Fort Worth Star-Telegram The Sun News-Myrtle Beach
Bellingham Herald The Fresno Bee Raleigh News&Observer
cClatchy Centre Daily Times The Island Packet Rock Hill I The Herald
Sun Herald The Kansas City Star The Sacramento Bee
Idaho Statesman Lexington Herald-Leader San Luis Obispo Tdbune
MBradenton Herald The Telegraph-Macan Tacoma I The News Tribune
The Charlotte Observer Merced Sun-Star Tri-City Herald
The State Miami Herald The Wichita Eagle
Ledger-Enquirer El Nuevo Herald The Olympian
AFFIDAVIT OF PUBLICATION
Account# OrderHwnber IdenffflcaRon OrderPO Amount Cols Depth
3fIS06 519383 F PrtntLewtimPLOtmm-IPLQ16 w W409 1 46 L
Attention: Joyce Sanford Clark
y North Carolina } ss
NC DENR ENGERGY MINERAL&LAND RESOURCES Meddenburg County }
1612 MAIL SERVICE CENTER
RALEIGH,NC 276991612 Before the undersigned,a Notary Public of said
County and State,duly authorized to administer
[e-mail] oaths affirmations,etc.,personally appeared,
being duly sworn or affirmed according to law,
NORTH CAROLINA ENVIRON- cloth depose and say that he/she is a
NIT
CONINILS oN UWrEW TO WSUE representative of The Charlotte Observer
NPDRS STORMWATER Publishing Company,a corporation organized and
DISCHARGE PERMrrS
The North Carolina Environmental doing business under the laws of the State of
to nagementIs"NPD commissionate proposes ; Delaware,and publishing a newspaper known as
to Issue NPDES stommvvater discharge ,
pemzlt(s)to the person(s)listed belm The Charlotte Observer in the city of Charlotte,
Pubilc comment or objection to the ;
draft permits is invited, written com- County of Mecklenburg,and State of North
wants heregarding the proposed permit
will be accepted until 30 days after the Carolina and that as such he/she is familiar with
,
publish date of this notice and consid- the books,records,files,and business of said
ered permit Isnal suance and a a per it`�% Corporation and by reference to the files of said
sloes.The Director of the NC Division publication,the attached advertisement was
of Energy,Mineral,and Land Resourc-
es MLR)may hold a public hearing inserted.The following is correctly copied from
should there be a significant degree of ;
public Interest Please mail comments the books and files of the aforesaid Corporation
and/or Information requests toDEMLR and Publication.
at 1612 Mail Service Center,Raleigh, ,
NC 27699-1612.
Charlotte Pipe and Foundry Company 1 insertion(s)published on:
[PO Box 35430,Charlotte,NC 28235-
354301 has requested renewal of .7. h 03/13/24
pennft NCS000040 for the Charlotte
Pipe and Foundry Company facility In
Mecklenburg County.This facility dis-
charges to an unnamed tributary to Ir-
win Creek In the Catawba Rlver Basin. i
Interested persons may visit DEMLR 8r`++ r
at 512 N. Salisbury Street,Raleigh, 4 '
NC 27604 to review Information onkiVl�•,1^�i'tIJ '
file. Additional information on NP- wci�?f p
DES permits and this notice may be r�e7l ;ij f
found on our website: httpsJ/deq.
nc.gov/about/divisions/energy-min-
eral
-and-land-resou=Wstormwater/ ,
stomiwater-program/stommater--pub- n Testimony ereo I ave hereunto set my an Ilo-notices,or by contacting Brlanna
Young at [e-mail] and affixed my seal on the 13th day of March,2024
or 919-707-3647.
iPL0163566 ;
Mar 13 2024
: Notary Public in and for the state of Texas,_r_e_5di_ngin
Dallas County
r - STEPHANIE HATCHER
,. My Notary III#1&VYAM
•.,«�,. .•` Expirm January 14,202$
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Young, Brianna A
From: Hamstead, Byron A <[e-mail]>
Sent: Friday, March 29, 2024 8:55 AM
To: Young, Brianna A
Subject: [External] USFWS Comments: Draft NPDES Stormwater Permit NCS000040
Attachments: Draft NPDES Permit NCS000040.pdf
You don't often get email from [e-mail]. Learn why this is important
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button located on your Outlook menu bar on the Home tab.
Thanks for the coordination Brianna. I hope your Spring is off to great start.
Pursuant to Section 7 of the Endangered Species Act(ESA),we offer the following comments on the draft NPDES
Permit for the Charlotte Pipe and Foundry Co in Mecklenburg Co:
The draft permit suggests the proposed action area (50CFR 402.02) drains into occupied habitat for federally listed
species including the federally endangered Carolina heelsplitter(Lasmigona decorata)and federally threatened
smooth coneflower(Echinacea laevigata). Presumably, mention of these species is based on Natural Heritage
Program (NHP) data.According to NHP data, accounts of Carolina heelsplitter in this reach of Irwin creek are
historic (pre-1880)as are records of smooth coneflower(pre-1900). Based on the information provided, habitats
within the proposed action area are significantly disturbed due to a legacy of urban development activities and are
highly unlikely to support these or any other federally listed species.
For this and future projects,we encourage you to visit our IPaC website to generate a site-specific list of species
that should be considered for the purposes of ESA compliance.The landing page has some links providing
guidance for generating species lists, but reach out if you have any questions https://ipac.ecosphere.fws.gov/.
Species on an IPaC list should be considered in the action agency's effects analysis, but that doesn't necessarily
mean that suitable habitat for listed species is present onsite.A"no effect"determination is appropriate if suitable
habitat for listed species does not occur within the proposed action area. Our office's Project Review website
provides related guidance that may be useful: https://www.fws.gov/office/asheville-ecological-services/asheviIle-
field-office-online-review-process-overview
Please reach out if you have any questions. I am happy to set up a time for a conversation if that would be helpful.
Regards,
Byron Hamstead
(he/him)
Fish and Wildlife Biologist
U.S. Fish and Wildlife Service
Asheville Ecological Services Field Office
160 Zillicoa Street
Asheville, North Carolina,28801
This email correspondence and any attachments to and from this sender is subject to the Freedom of Information Act and may be disclosed
to third parties.
1

Young, Brianna A
From: Young, Brianna A
Sent: Tuesday, March 12, 2024 12:36 PM
To: Pappalardo,Jenny L.
Cc: Fedorko, Amanda C.
Subject: RE: [External] RE: Draft NPDES stormwater permit NCS000040
Jenny,
Thank you for submitting comments on the draft permit.
Regarding representative outfall status, representative outfall status(ROS) resets with permit issuance. In order to
maintain current ROS, as it is a separate review process and not handled during permit renewal,you will need to
attach the completed ROS Renewal Certification Form and prior documentation that was provided when the
Division originally granted ROS to the Stormwater Upload Form.
Regarding relief from tier monitoring, per the policy of the Stormwater Permitting Program,Tiered Response relief
effectively ends at the new permit cycle. Conditions start over at baseline monitoring, and permittees will have to
seek relief again if/when appropriate.
Thankyou,
Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ / Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Young(a)deq.nc.gov(e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
From: Pappalardo,Jenny L. <[e-mail]>
Sent: Monday, March 11, 2024 3:21 PM
To:Young, Brianna A<[e-mail]>
Cc: Fedorko,Amanda C. <[e-mail]>
Subject: [External] RE: Draft NPDES stormwater permit NCS000040
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon Brianna,
I have reviewed the draft permit and have the following comments/questions:
1

• Representative Outfall Status, p10&Table 1, p15: I have attached a letter from James Moore dated May 27,
2020 that notes that Outfalls A,B &C shall be the representative outfalls for the facility. Is this still effective? If
so, please update Table 1 header(p15)and outfall descriptions (p15-16).
• Relief from Monitoring: The attached letter from James Moore dated May 27, 2020 gave us Relief from
Monthly Monitoring for Outfalls A,B &C. Is this still effective?
Thank you,
Jenny
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, March 6, 2024 9:27 AM
To: Hall, Mike<[e-mail]>
Cc: Pappalardo,Jenny L. <[e-mail]>; Fedorko,Amanda C. <[e-mail]>;
Waggoner, David G.<[e-mail]>
Subject: Draft NPDES stormwater permit NCS000040
Good morning,
Attached is the draft permit for Charlotte Pipe& Foundry(NCS000040).A hard copy of this draft permit will be
placed in the mail to Mike Hall. Please submit any comments on the draft permit by April 8, 2024.
Thankyou,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brian na.Young(codeq.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAILADDRESS
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or
email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Pappalardo,Jenny L. <[e-mail]>
Sent: Monday, March 11, 2024 3:21 PM
To: Young, Brianna A
Cc: Fedorko, Amanda C.
Subject: [External] RE: Draft NPDES stormwater permit NCS000040
Attachments: 2020-05.27 FINAL NCS000040 ROS & RELIEF from Monthly Monitoring.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Good afternoon Brianna,
I have reviewed the draft permit and have the following comments/questions:
• Representative Outfall Status, p10&Table 1, p15: I have attached a letter from James Moore dated May 27,
2020 that notes that Outfalls A,B &C shall be the representative outfalls for the facility. Is this still effective? If
so, please update Table 1 header(p15)and outfall descriptions (p15-16).
• Relief from Monitoring: The attached letter from James Moore dated May 27, 2020 gave us Relief from
Monthly Monitoring for Outfalls A,B &C. Is this still effective?
Thank you,
Jenny
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, March 6, 2024 9:27 AM
To: Hall, Mike<M Hall @charlottepipe.com>
Cc: Pappalardo,Jenny L. <[e-mail]>; Fedorko, Amanda C. <[e-mail]>;
Waggoner, David G.<[e-mail]>
Subject: Draft NPDES stormwater permit NCS000040
Good morning,
Attached is the draft permit for Charlotte Pipe& Foundry(NCS000040).A hard copy of this draft permit will be
placed in the mail to Mike Hall. Please submit any comments on the draft permit by April 8, 2024.
Thankyou,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAILADDRESS
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
1

Email correspondence to and from this address is subject to the North Carolina
Public Records Law and maybe disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or
email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

e„n.STATf a
� N
ROY COOPER Fy o
Governor
MICHAEL S.REGAN y
Secretary r`R mm"moa'
BRIAN WRENN NORTH CAROLINA
Acting Director Environmental Quality
May 27, 2020
Charlotte Pipe & Foundry Co.
Attention: David Waggoner, Contact Person
1335 South Clarkson Street I
Charlotte, North Carolina 28208
f
r.
Subject: Relief from Monthly Monitoring
Stormwater Permit # NCS000040
Charlotte Pipe & Foundry Co.
Mecklenburg County
Dear Mr. Waggoner:
We are in receipt of your 2019 /2020 TSS / Metals monitoring study and your April
28, 2020 email requesting next steps at the Charlotte facility. Based on a May 21, 2020
site inspection, the facility is in compliance with the tiered response actions and other
conditions of the NCS000040 Permit. Therefore, the Division is granting regulatory relief
from the Tier responses based on the condition that the TSS Abatement / Best F
Management Plan be continued and that quarterly reports documenting maintenance be
submitted to this office. Upon receipt of this letter, the subject facility may resume the
permit specified semi-annual analytical monitoring at outfalls A, B and C for the remainder c
of the current permit term which expires on January 31, 2024. This decision applies to all
the permitted benchmarks. Please update your SWPP plan to reflect outfalls A, B & C as
representative for the site industrial activities,
You must notify this office, in writing, within five business days if you become
aware of any other significant source of TSS / Metals at your facility that have the
potential to be exposed to stormwater. The relief granted in this letter is contingent
upon the current industrial practices at Charlotte Pipe & Foundry Charlotte facility.
Please retain and append this letter to your Stormwater Pollution Prevention Plan
(SPPP) or permit. If you have any questions or comments concerning this letter, please
contact James Moore or me at 704-663-1699.
North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
_ Mooresville Regional Office 1 610 East Center Avenue,Suite 301 1 Mooresville,North Carolina 28115
Horrc pvouw.
o.o. iemeoomemn o:,m\ /� 704.663.1699

Letter of Approval with Modifications
Charlotte Pipe & Foundry Company
May 27, 2020
Page 2 of 2
Sincerely,
Zaahhiid' S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Enclosure: Inspection Report
cc: Stormwater Laserfiche File NCS000040

Compliance Inspection Report
Permit:NCS000040 Effective: 02/05/19 Expiration: 01/31/24 Owner: Charlotte Pipe &Foundry Cc '..
SOC: Effective: Expiration: Facility: Charlotte Pipe&Foundry Company-Cast Iron
County: Mecklenburg 1335 S Clarkson St '..
Region: Mooresville '..
Charlotte INC 28208
Contact Person:David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/21/2020 Entry Time 11:30AM Exit Time: 12:15PM
Primary Inspector:James D Moore Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 05/21/2020 Inspection Type:Technical Assistance Reason for Visit: Follow-up
Inspection Summary.
Based on the inspection and a review of 1) outfalls to be representative and 2) TSS abatement plan and record keeping/
reporting it is recommended that outfalls A, B and C be representative for the site and that semi-annual monitoring be
initiated on the condition that quarterly reports be submitted regarding TSS abatement and maintenance Please email the
reports to [e-mail].
i
i
I
i
i
Page 2 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 0 512 1/2 02 0 Inspection Type:Technical Assistance Reason for Visit: Follow-up
i
Page 3 of 3

Young, Brianna A
From: Hawley, Julianna E <[e-mail]>
Sent: Wednesday, February 21, 2024 12:47 PM
To: Young, Brianna A
Cc: Pappalardo, Jenny L.
Subject: [External] FW: Charlotte Pipe Stormwater Inspection Report
Attachments: Charlotte Pipe Stormwater Inspection Report.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Brianna,
Jenny wanted me to send Charlotte Pipe's Stormwater Inspection Report. I accidentally CCed the wrong
Brianna when I sent this the first time.
Thank you!
From: Hawley,Julianna E
Sent: Wednesday, February 21, 2024 12:08 PM
To: Pappalardo,Jenny L. <[e-mail]>
Cc: Khan, Zahid ([e-mail])<[e-mail]>; DeCristofaro, Andrew; Eplin,Jerry W
<[e-mail]>; Chandler, Jeffrey A<[e-mail]>; Kenny, Brianna
<[e-mail]>
Subject: Charlotte Pipe Stormwater Inspection Report
Dear Jenny Pappalardo:
On February 14, 2023, Julianna Hawley of Charlotte-Mecklenburg Storm Water Services (CMSWS) conducted
an inspection of the above referenced facility as a requirement of the City of Charlotte's NPDES Permit,
NCS000240, Part II, Section H. Inspection authority is granted by Charlotte City Code Chapter 18,Article III,
Section 18-82. At the time of inspection, the facility was observed to be in compliance with the City of
Charlotte Storm Water Pollution Control Ordinance.
The inspection was also conducted as part of a cooperative working agreement between Mecklenburg County
and the North Carolina Department of Environmental Quality (NCDEQ)—Division of Energy, Mineral and
Land Resources (DEMLR). NCDEQ—DEMLR has been copied on this report and made aware of the
following observations regarding the facility's NPDES stormwater permit:
1) Stormwater Pollution Prevention Plan (SWPPP)
A Stormwater Pollution Prevention Plan(SWPPP)has been developed, recorded, and implemented.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded.
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded.
1

Thank you for the assistance and cooperation with the site inspection. The attached report provides details
about inspection observations and should be self-explanatory. Please contact me at(704) 654-1394 if you have
any questions or need additional information. For questions specifically regarding your State-issued NPDES
Stormwater Certificate of Coverage NCS000040,please contact Jerry Eplin with NCDEQ—DEMLR at(704)
663-1699.
Thank you again!
Julianna Hawley (she/her)
Environmental Specialist
Land Use and Environmental Services Agency
Mecklenburg County Government
704-654-1394 1 Goo-le�Maps I MeckNC.Gov
Om
2

Charlotte-Mecklenburg
STORM
WATER StormWater.CharMeck.org
Services N
February 20, 2024
Jenny Pappalardo, Environmental Compliance
1335 South Clarkson Street
Charlotte,NC 28208
Subject: Industrial Facility Inspection
Charlotte Pipe and Foundry Company
Dear Jenny Pappalardo:
On February 14, 2023, Julianna Hawley of Charlotte-Mecklenburg Storm Water Services
(CMSWS) conducted an inspection of the above referenced facility as a requirement of the City
of Charlotte's NPDES Permit,NCS000240, Part II, Section H. Inspection authority is granted by
Charlotte City Code Chapter 18, Article III, Section 18-82. At the time of inspection, the facility
was observed to be in compliance with the City of Charlotte Storm Water Pollution Control
Ordinance.
The inspection was also conducted as part of a cooperative working agreement between
Mecklenburg County and the North Carolina Department of Environmental Quality (NCDEQ) —
Division of Energy,Mineral and Land Resources (DEMLR). NCDEQ—DEMLR has been copied
on this report and made aware of the following observations regarding the facility's NPDES
Stormwater permit:
1) Stormwater Pollution Prevention Plan (SWPPP)
A Stormwater Pollution Prevention Plan (SWPPP) has been developed, recorded, and
implemented.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded.
3)Analytical Monitoring
Analytical monitoring has been conducted and recorded.
•
QD Cho Suttllobe, Avenue CD East , Sheet
Charlotte,NC 28208 Charlotte,NC 282p2
charlottenc.gov

Jenny Pappalardo,Environmental Compliance
February 20, 2024
Page 2
Thank you for the assistance and cooperation with the site inspection. The attached
report provides details about inspection observations and should be self-explanatory. Please
contact me at(704) 654-1394 if you have any questions or need additional information. For
questions specifically regarding your State-issued NPDES Stormwater Certificate of Coverage
NCS000040, please contact Jerry Eplin with NCDEQ—DEMLR at(704) 663-1699.
Thank you,
Julianna Hawley
Environmental Specialist III
Charlotte-Mecklenburg Storm Water Services
cc: Andrew DeCristofaro, Charlotte Storm Water Services
Zahid Khan,NCDEQ—DEMLR
Jeffrey Chandler,NCDEQ—DEMLR
Jerry Eplin,NCDEQ—DEMLR
Attachment

ChmrfoN-M4cA4nburg
ji / STORM Facility Inspection
Wi E 5tormW ate r.Cho rMeck.org
SuviceS
Facility Name: Charlotte Pipe&Foundry Company Inspection#: 82225
Contact: Jenny Pappalardo, Environmental Compliance Permit#: NCS000040
Inspector: Julianna Hawley Receiving Stream: IRWIN
Inspection Date: 02/14/2024 Entry Time: 1:00 pm Exit Time: 3:00 pm SIC#:
Facility Description: Charlotte Pipe and Foundry Company is located at 1335 South Clarkson Street on approximately
39.4 acres in Charlotte. The facility manufactures fittings and started the process of shutting down this location in August
2023. Most processes have been moved to their new facility in Oakboro, NC.
File Review/History: Charlotte-Mecklenburg Storm Water Services (CMSWS)previously inspected the facility on 12/20/
2019, and the report was issued as satisfactory.
Inspection Summary:At the time of the inspection,the facility was observed to be in compliance with the City of
Charlotte Storm Water Pollution Control Ordinance. Please refer to the report for comments and recommendations.
Site Inspection Deficiency Comments
Stormwater system (catch basins, Satisfactory Stormwater conveys through the site via sheet flow into drop
inlets, outfalls, etc.) inlets. Two drop inlets serve as two of the facility's outfalls.
The third outfall is an area of concentrated flow. Best
management practices were observed in the drop inlets. No
stormwater pollution issues were observed.
Erosion issues Satisfactory No erosion issues were observed onsite during the inspection
Structural stormwater control N/A
measures(SCMs)
Illicit discharges/connections Satisfactory No illicit discharges/connections were observed onsite during
the inspection.
Aboveground storage tank(s)(ASTs) Satisfactory The complete list of onsite ASTs is included in the SWPPP.
and any associated venting and/or The 10,000-gallon gasoline and 10,000-gallon diesel ASTs
dispenser(s)—list tank size(s)and were observed to be contained within secondary containment.
contents The facility maintains a release log. No stormwater pollution
issues were observed at the dispensers or ASTs throughout
the site.
Underground storage tank(s)(USTs) N/A
and any associated fill port area(s)
and dispenser(s)—list tank size(s)
and contents
Outdoor material storage area(s) Satisfactory Defective pipe was observed to be stored outdoors. Bulk
material was observed to be contained within a bay outdoors.
Several outdoor material storage areas are no longer in use.
No stormwater pollution issues were observed.
Outdoor processing area(s) N/A
Loading/unloading area(s) Satisfactory No stormwater pollution issues were observed in the loading/
unloading areas or in the truck staging area.
To report pollution or drainage problems call: 31 1 :T
CHARLOTTE_ http://stormwater.charmeck.org
2/20/2024 2:14:51 PM Page 1 of 3

Site Inspection Deficiency Comments
Vehicle/equipment area(s)-fueling, Satisfactory Fueling occurs at the covered fuel island. According to
maintenance,washing, storage, etc. facility personnel, maintenance no longer occurs onsite.
Washing is conducted in the wash bay,which drains to the
onsite pre-treatment facility. Vehicles and equipment were
observed to be stored indoors. No stormwater pollution
issues were observed.
Oil/water separator and/or Satisfactory A pre-treatment facility was observed onsite. The facility has
pretreatment a permit with Charlotte Water. A grease trap was also
observed, and according to facility personnel,they are
working with the City of Charlotte to decommission it. No
stormwater pollution issues were observed.
Waste storage/disposal area(s)- Recommendation One municipal waste container was observed with its rain
open tops,waste containers, scrap flaps in place. One waste and two recycling open tops were
metal bins, etc. observed to be uncovered. CMSWS recommends that open
waste containers be covered to protect water quality.
Food service area(s) Satisfactory The facility has one grease trap that they are working on
decommissioning. One grease bin was observed to be well
maintained. No stormwater pollution issues were observed.
Indoor material storage area(s) Satisfactory Several ASTs and totes of miscellaneous chemicals were
observed to be stored indoors. Parts, products, and other
supplies were observed to be stored inside a warehouse. No
stormwater pollution issues were observed.
Indoor processing area(s) Satisfactory Most processing has ceased while the facility is moved to a
new location. Processing was observed to occur indoors.
No stormwater pollution issues were observed.
Floor drains Satisfactory According to facility personnel,the floor drains are connected
to the onsite pre-treatment facility. No stormwater pollution
issues were observed.
Spill response equipment Satisfactory Spill response equipment was observed throughout the
facility, including at the fuel island.
SWPPP Section Observed Comments
Does the facility have a Stormwater Satisfactory
Pollution Prevention Plan (SWPPP)?
Reviewed and updated annually Satisfactory The most recent review and update was in January 2024.
Responsible party Satisfactory
General location (USGS)map Satisfactory
Detailed site map Satisfactory
Narrative description of industrial Satisfactory The facility recently updated the description to reflect
processes changes while the facility is moving operations to its new site
Feasibility study Satisfactory
Evaluation of stormwater outfalls(non Satisfactory The most recent evaluation occurred on 12/27/2023.
-stormwater discharge evaluation)
Stormwater best management Satisfactory
practice(BMP)summary
Secondary containment plan (all Satisfactory The list of ASTs, contents, and secondary containment
necessary secondary containment information is included in the SWPPP.
provided and documented)
Records on every release from a Satisfactory The most recent release that was recorded was on 2/8/2024.
secondary containment system (for
the last 5 years)
To report pollution or drainage problems call: 311
CHARIATTE. http://stormwater.charmeck.org
2/20/2024 2:14:51 PM Page 2 of 3

SWPPP Section Observed Comments
Spill prevention and response Satisfactory
procedures(SPRP)
List of significant spills or leaks(for Satisfactory The facility has recorded significant spills and made a
the last 3 years) notation for years in which no spills occurred.
Solvent management plan (SMP) N/A
Preventative maintenance and good Satisfactory
housekeeping program (PMGHP)
Facility inspections conducted as Satisfactory The most recent facility inspections were conducted and
required recorded on 12/30/2022, 6/15/2023, and 12/27/2023.
Employee training (provided and Satisfactory Employee training was documented and provided in
documented) I December 2023.
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted as Satisfactory Qualitative monitoring was conducted in May 2022, November
required 2022, June 2023, and December 2023. In 2020,the State
granted regulatory relief from monthly monitoring after
conducting a site visit.
Analytical monitoring conducted as Satisfactory Analytical monitoring was conducted in May 2022, November
required 2022, June 2023, and December 2023. In 2020,the State
granted regulatory relief from monthly monitoring after
conducting a site visit.
Analytical monitoring for onsite N/A
vehicle and equipment maintenance
as required
Permit and Outfalls Observed Comments
Copy of permit and certificate of Satisfactory NCS000040. The permit expired in January 2024, and the
coverage onsite facility is working with the State to renew it.
All outfalls observed Satisfactory No stormwater pollution issues were observed.
Number of Outfalls Observed 3
Representative outfall status Satisfactory Representative outfall status was granted in May 2020.
documented by DEMLR
Annual no-exposure self re-certificatio N/A
n documented
To report pollution or drainage problems call: 311
CHARIATTE. http://stormwater.charmeck.org
2/20/2024 2:14:51 PM Page 3 of 3

Compliance Inspection Report
Permit:NCS000040 Effective: 02/05/19 Expiration: 01/31/24 Owner: Charlotte Pipe&Foundry Co
SOC: Effective: Expiration: Facility: Charlotte Pipe&Foundry Company-Cast Iron
County: Mecklenburg 1335 S Clarkson St
Region: Mooresville
Charlotte NC 28208
Contact Person:David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 10/13/2021 Entry Time 10:45AM Exit Time: 11:15AM
Primary Inspector:James D Moore Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 10/13/2021 Inspection Type:Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
Based on the inspection the site is in compliance with the TSS abatement plan required for Tier monitoring relief.
Page 2 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 10/13/2021 Inspection Type:Compliance Evaluation Reason for Visit: Follow-up
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment: Based on the outfall inspections and TSS abatement reports submitted to this office, the site is
in compliance with the TSS Abatement Plan required for Tier monitoring relief.
Page 3 of 3

Compliance Inspection Report
Permit:NCS000040 Effective: 02/05/19 Expiration: 01/31/24 Owner: Charlotte Pipe&Foundry Co
SOC: Effective: Expiration: Facility: Charlotte Pipe&Foundry Company-Cast Iron
County: Mecklenburg 1335 S Clarkson St
Region: Mooresville
Charlotte NC 28208
Contact Person:David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 05/21/2020 Entry Time 11:30AM Exit Time: 12:15PM
Primary Inspector:James D Moore Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Follow-up Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 05/21/2020 Inspection Type:Technical Assistance Reason for Visit: Follow-up
Inspection Summary:
Based on the inspection and a review of 1)outfalls to be representative and 2)TSS abatement plan and record keeping/
reporting it is recommended that outfalls A, B and C be representative for the site and that semi-annual monitoring be
initiated on the condition that quarterly reports be submitted regarding TSS abatement and maintenance.Please email the
reports to [e-mail].
Page 2 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 05/21/2020 Inspection Type:Technical Assistance Reason for Visit: Follow-up
Page 3 of 3

Compliance Inspection Report
Permit:NCS000040 Effective: 02/05/19 Expiration: 01/31/24 Owner: Charlotte Pipe&Foundry Co
SOC: Effective: Expiration: Facility: Charlotte Pipe&Foundry Company-Cast Iron
County: Mecklenburg 1335 S Clarkson St
Region: Mooresville
Charlotte NC 28208
Contact Person:David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 04/23/2019 Entry Time 10:30AM Exit Time: 12:OOPM
Primary Inspector:James D Moore Phone: [phone]
Secondary Inspector(s):
Angela Y Lee
Reason for Inspection: Follow-up Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 04/23/2019 Inspection Type:Technical Assistance Reason for Visit: Follow-up
Inspection Summary:
The inspection was to review recent testing to evaluate sources of TSS and Zinc. Addition testing has been recommended
and a follow up inspection will be conducted in June 2019.
Page 2 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 04/23/2019 Inspection Type:Technical Assistance Reason for Visit: Follow-up
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment:
Page 3 of 3

Compliance Inspection Report
Permit:NCS000040 Effective: 11/06/09 Expiration: 07/31/14 Owner: Charlotte Pipe&Foundry Co
SOC: Effective: Expiration: Facility: Charlotte Pipe&Foundry Company-Cast Iron
County: Mecklenburg 1335 S Clarkson St
Region: Mooresville
Charlotte NC 28208
Contact Person:David Waggoner Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 09/27/2018 Entry Time 09:OOAM Exit Time: 02:OOPM
Primary Inspector:James D Moore Phone: [phone]
Secondary Inspector(s):
Lily C Kay
Reason for Inspection: Routine Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 09/27/2018 Inspection Type:Technical Assistance Reason for Visit: Routine
Inspection Summary:
Based on the site inspection, addition outfall sampling is recommended before the new permit is issued. The MRO will follow
up after the new outfall test results are received.
Page 2 of 3

Permit: NCS000040 Owner-Facility:Charlotte Pipe&Foundry Co
Inspection Date: 09/27/2018 Inspection Type:Technical Assistance Reason for Visit: Routine
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment: Based on the amount of water that flows through the site stormwater collection system from
uupgradient sources on a continual basis, Chad Broadway, Lily Kay and I do not think they are
sampling from locations that best indicate potential stormwater impacts from their industrial
activity. During the inspection we identified 4 new locations that should be sampled during the
next rain event as part of further data for the permit renewal. We asked that they test for all
parameters in the old permit and email the results when received.
Page 3 of 3

Young, Brianna A
From: Pappalardo,Jenny L. <[e-mail]>
Sent: Thursday, February 1, 2024 10:14 AM
To: Young, Brianna A
Cc: Fedorko, Amanda C.
Subject: [External] RE: Charlotte Pipe and Foundry Company (NCS000040)
Attachments: Form 2F, Section 4.2.pdf; Figure 1-Site Location Map.pdf, NC Checklist Analytical
Summary.xlsx; Form 1, Page 3.pdf
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Brianna,
Please see answers in red below and in the attachments.
Please contact me via email or at 704-348-5513 if you need any additional information.
Thank you,
Jenny
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,January 24, 2024 9:00 AM
To: Hall, Mike<M Hall @charlottepipe.com>
Cc:Waggoner, David G. <[e-mail]>; Fedorko,Amanda C.<[e-mail]>;
Pappalardo,Jenny L. <[e-mail]>
Subject: RE: Charlotte Pipe and Foundry Company (NCS000040)
Good morning,
I am following up on the phone call we had regarding the permit path since the facility will be shutting down. As the final
shutdown and clean-up date is not known,the permit renewal process will continue. If the facility completes close-out
procedures before the permit renewal is issued, you may request the renewal application be withdrawn and the current
permit be rescinded. If the renewed permit is issued before facility shut-down procedures are complete,you may
request a permit rescission in the future.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
1

Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Young, Brianna A
Sent: Monday,January 8, 2024 9:35 AM
To: [e-mail]
Cc: [e-mail]; [e-mail]; Pappalardo,Jenny L.
<[e-mail]>
Subject: Charlotte Pipe and Foundry Company (NCS000040)
Good morning,
I am working on renewing the individual stormwater permit for the Charlotte Pipe and Foundry Company
(NCS000040). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of chemicals stored onsite; See attachment Form 2F,Section 4.2;The only bulk storage tanks
currently being used are the diesel tank gasoline tank, EG diesel tanks, and used oil tank. The feldspar silo is not
currently used, but there is a residual amount remaining to be disposed. Other bulk material tanks/silos have
been emptied.
• Confirmation on the number of outfalls, associated coordinates, and respective receiving stream(s); See
attachment Figure 1-Site Location Map. Outfalls A, B, C.
• Description of industrial activity in each drainage area;
Area 1
Area I is approximately 9.19 acres in sizewith one 17,OOOsquare-foot structure (Gundrill Room). The remainder
of the area consists of asphalt paved parking areas,gravel paved storage areas, storage areas (including coke,
limestone, and slag),and natural landscaped areas. Outside areas between the Gundrill Room and on-ramp
to 1-77N are used primarily as storage spacefor coke, limestone,slag. Minimal amounts may remain for
disposal. Outside areas between the Gundrill Room and Clarkson Street are primarily an used parking area. The
Gun Drill building structure is currently unused.
In September 2018, North Carolina Stormwater Division removed our requirement to sample from this area as it
was not deemed to accurately represent stormwater flow from industrial areas (it includes run-off from
stormwater drains not on Charlotte Pipe property and run-off from 1-277).
Area II
Area II isapproximately 2.90acres insizewith one51,000square-foot warehouse structure. The remainder of the
area consists of asphalt paved parking areas and natural landscaped areas. The building structure is used
primarily as a warehouse with approximately 20 percent of the floor space used for offices. All items are
currently in the process of being removed from the Warehouse. Storm drainage from Area II drains via storm
drainage structures and storm drainage pipes to a drop inlet structure located on the southwestern corner of
the area (Appendix A,Figure 2).
In May 2009, North Carolina Stormwater Division removed our requirement to sample from this drop inlet
structure as there is no industrial activity in this area.
Area III
Area III is approximately 3.33 acres in size with four structures totaling approximately 16,918 square-feet. Three
buildings (storage)are located onthe northern portion of the area and one building (Quality Control) is located
on the southern portion of the area. The remainder of the area consists of asphalt paved and gravel paved
2

areas. The Quality Control building is currently unused. Storm drainage from Area III drains via sheet flow to
South Clarkson Streetwhere it is runs into a street storm drainage system (Appendix A,Figure 2). North Carolina
Stormwater Division is not requiring sampling of the sheet flow as there is no industrial activity in this area.
Area IV
Area IV is approximately 7.44acres in size with five structures totaling approximately 17,780 square-feet. Three
buildings are located on the western portion of the area on the main Charlotte Pipe property(Product Bundling
Shed,Small Office Building, and Water Treatment). The Product Bundling Shed and Small Office Building are
unused. The Water Treatment Plant is still in operation. Two buildings are located on the west side of Clarkson
Street(Shipping Department, a portion of the Pattern Storage Building). Both buildings are currently unused.
The remainder of the area consists of asphalt paved areas, gravel paved areas, and natural landscaped
areas. Storm drainage from Area IV drains via storm drainage structures and storm drainage pipes toa pipe
discharginginto Irwin Creek. NC Stormwater Division is aware that there is continuous flow through many of the
storm drainage structures due to groundwater entering the stormwater system upstream of the Charlotte Pipe
facility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall A to be representative of storm
water drainage from Areas V. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area V
Area V is approximately 2.28 acres in size with four structures totaling approximately 23,000 square-feet. Two of
the buildings arethe main office buildings for Charlotte Pipe, one building is the Machine Shop and one building is
the Welding Shop. The building structures are currently mainly unused. The remainder of the area consists of
scrap iron storage areas and asphalt parking areas. Storm drainage from Area V drains via storm drainage
structures and storm drainage pipes to a pipe discharging into Irwin Creek. NC Stormwater Division is aware that
there is continuous flow through many of the storm drainage structures due to groundwater entering the
stormwater system upstream of the Charlotte Pipefacility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall B to be representative of storm
water drainage from Area V. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area VI
Area VI is approximately 1.78 acres in size with two structures totaling approximately 12,109 square-feet. The
Pattern Storage Building, is located west of and across Clarkson Street from the main foundry buildings, is
currently unused. One building, the Main Entrance Guard Shack, is located in the main foundry area. The
Guard Shack is manned 24 hrs/day. The remainder of the area consists of asphalt paved drives and parking,
a15,000-gallon hot dip asphalt tank(emptied) and natural landscaped areas. Storm drainage from Area VI
drains via storm drainage structures and storm drainage pipes to a pipe discharging into Irwin Creek. NC
Stormwater Division is aware that there is continuous flow through many of the storm drainage structures due
to groundwater entering the stormwater system upstream of the Charlotte Pipe facility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall B to be representative of storm
water drainage from Area VI. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area VII
3

Area VII is approximately 12.50acres in size with the main foundry buildings, support buildings, bulk material
spent storage area,fuel aboveground storage tanks(ASTs),fueling station,and oil storage building (Oil House).
The majority of the building structures are currently unused but still store process equipment until it can be
removed. The only operations currently active at the site are the Fitting Cleaning, Pipe Reaming and Pipe E-
Coat Operations. The majority of stormwater from this area is run off from the roofs of the foundry buildings.
The remainder of the area consists of asphalt paved parking and storage areas, gravel paved parking and
storage areas,the fuel AST area,the bulk material spent storage area (currently used to stage materials to be
removed from the site), and natural landscaped areas. The area is used primarily for parking space, and storage
space for spent bulk materials, fuel storage tanks, bin storage for finished products, and miscellaneous
equipment used at the facility. Storm drainage from Area VII drains via storm drainage structures and storm
drainage pipes discharging ultimately into Irwin Creek. NC Stormwater Division is aware that there is continuous
flow through many of the storm drainage structures due to groundwater entering the stormwater system
upstream of the Charlotte Pipe facility. A small quantity of stormwaterfrom Area VII (north of the Rolocast
Finishing building and east of Clarkson Street)drains via sheet flow to South Clarkson Street where it is collected
in the street storm drainage system under 1-277(John Belk Freeway)overpass.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall C to be representative of storm
water drainage from Area VII. In addition, in a letter dated May 27, 2020, the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit; See attachment NC Checklist Analytical Summary.xls
• Verification that the information in the renewal application is still complete and correct; and Information
as submitted, with updates as per this email. See attachment Form 1, Page 3.
• An explanation of any operational changes since the renewal application was submitted. as noted in the
Summary of Significant Changes, Charlotte Pipe is in the process of shutting down this facility. Charlotte Pipe
intends to continue to take stormwater samples and completed BMP activities (as needed).
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form No Change.
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form No Change.
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form No Change.
• Billing contact: Permit Contact Update Request Form No Change.
• Permit contact: Permit Contact Update Request Form No Change.
• Facility contact: Permit Contact Update Request Form No Change.
• Facility address only: Email Bethany Geor o� No Change.
• Stormwater outfall information: Email Bethany Geor og ulias No Change.
• Visit the eDMR Six Steps website and complete Steps 1 and 2 Completed.
• Pay outstanding permit fees: Stormwater ePayment website There are no unpaid invoices.
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
4

same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
5

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040.0004
SECTION •• 1
6-1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
ENPDES(discharges to surface 10 RCRA(hazardous wastes) ❑ UIC(underground injection of
c water) fluids)
� •e'd— NCS000040 2820SCHRLT1335S
w a 0 PSD(air emissions) ❑Nonatlainment program(CAA) NESHAPs(CAA)
c NCMECO626 NCMECO626
U ❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑Other(specify)
SECTIONI
7.1 Have you attached a topographic map containing all required Information to this application?(See instructions for
@ specific requirements.)
0 Yes []No ❑CAFO—Not Applicable(See requirements In Form 2B.)
SECTION 8.NATURE OF r
8.1 Describe the nature of your business.
Gray Iron foundry manufacturing soil pipe and fittings.
Lrru iu. 4�,1�`�^' :=�v ir . {t•i-2[ Oc.xfa5 Ck �Sf�tJr�in�
C �rJ[.i•l - \�I�l '�T/.C-1 N� 1 hC- `l�•lr� �Ultlr r��Ot]�j�pl�
yJ
norQ "nL�.ntnt gyZnj l LtLL�incl p V>e FZ¢c•.�nlnq. 4
A
'P: c ccl;
Z
COOLINGSECTION 9.
1
9A Does your facility use cooling water?
0 Yes ❑ No 4 SKIP to Item 10.1.
3 9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your
o Y NPDES permitting authority to determine what specific Information needs to be submitted and when.)
v Cooling water does not consist of stormwater nor Is cooling water discharged to surface waters.
e
SECTION
1 VARIANCE REQUESTS1 1
10.1 Do you Intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
apply.Consult with your NPDES permitting authority to determine what Information needs to be submitted and
when.)
d ❑ Fundamentally different factors(CWA ❑ Water quality related eff luent limitations(CWA Section
Section 301(n)) 302(b)(2))
❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
Section 301(c)and(g))
Not applicable
EPA Form 3510-1(revised 3-19) Pages

i
Form 2F,Section 4.2 .
Stormwater drainage at the facility is from roof areas,asphalt parking areas,gravel paved areas,loading/
unloading areas,material storage areas,and grass areas. Stormwater Flows into storm drains located throughout
the paved and landscaped areas of the property. Stormwater run-off Flows overland and/or through underground
storm sewers to the west towards Irwin Creek. The following storage areas are located outside:
• One 15,000-gallon hot dip storage tank is located on an asphalt-paved surface south of the main
building. The tank is provided with secondary con jainwienttrThe form of an open-top containment area G(Yl l
concrete sump. The su�approxim'ately 23.2 feet by 17.4 feet by 5 feet,which equates to an I e
approximate storage capacity of 2,018ft3,or approximately 15,097 gallons. Spilled material collected
withinttie containment area is removed and disposed of in accordance with applicable regulations. r-
• One S0-tonsan"lo is located-west of the main_productionbuUding_ In addition,one feldspar silo is
1-t_k'A 'YtA -
located south of the waste treatment building. The silo is not equipped with secondary "�L' 1 )
containment. However,since the contents are not liquid,spilled material will be easily cleaned up and Lo'1';jf'
should not impact stormwater,. U5 d-
• One 550-gallon used oil storage tank is located on an asphalt-paved surface south of the Oil House. The
tank is provided with secondary containment in the form of metal walls. The containment area is
approximately 4 feet X 6 feet X 2 feet,which equates to an approximate storage capacity of 48 ft3,or
approximately 359 gallons. Spilled material collected within the containment area is removed and
disposed of in accordance with applicable regulations.
• One 10,000-gallon gasoline storage double walled tank and one 10,000-gallon diesel storage double
i walled tank are located on an asphalt-paved surface near the northeast corner of the property. The tanks
are provided with secondary containment in the form of concrete walls. The containment area Is
approximately 30 feet by 30 feet by 3 feet,which equates to an approximate storage capacity of 2,700 ft3,
or approximately 20,200 gallons. Spilled material collected within the containment area is removed and
disposed of in accordance with applicable regulations.
• One fueling station with four pumps is located on an asphalt-paved surface near the northeast corner of
the property. The fueling station is covered and equipped with an emergency shut off valve. The fueling
station is provided with secondary containment in the form of a trench drain. Spilled material collected
within the containment area is removed and disposed of in accordance with applicable regulations.
• Oil drums are stored under cover outside the Oil House. The area is not equipped secondary containment
or with a berm.
• Materials are stored in totes and drums in a covered shed located at the northeastern portion of the I"
facility. The entrance to the shed is equipped with an asphalt berm to minimize the potential Impact of r "'`1,"
spills on Stormwater. t ' d
• Materials are stored In totes and drums in a covered shed located at the southeastern portion of the
facility. This area is not equipped with a berm.
• Two totes of oil are stored on the ground without secondary containment in the shell core unloading
area. -- - --

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tyt� OUTFALL! LAT i LONG yl� �' f! �) r 'x "•1
Y A 35JN811 N -80.864?27
B 35.223895 N -80.862312
C 35.224070 N -80.860D25 W ) � s- j
T r .. Jul. '... -Mom--)A
N
0 0.2 0.4 0.6 0.8 1 mi
OURCE: CHARLOTTE WEST, NC 7.5 MINUTE TOPOGRAPHIC QUADRANGLE, 1991
CHARUOTTE SITE LOCATION MAP Figure
PIPE ail FOUNDRY COMPANY 1335 SOUTH CLARKSON STREET 1
CHARLOTTE,NORTH CAROLINA

Summary of Analytical Monitoring Results
SW Outfall A(sheet flow behind Shipping)
10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021 11/2021 05/2022 11/2022 06/2023
Bench- Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter
Characteristic Mark Units Monthly Monthly As Requested As Requested As Requested Semi-AnnI2 Semi-Ann11 Semi-AnnI2 Semi-A-11 Semi-AnnI2 Semi-Ann/1
Oil&Grease 30.00 mg/L ND ND
Cr 1.00 mg/L ND ND
Cu 0.01 mg/L 0.009 0.005 0.010 0.006 0.012 0.008 0.027 0.01 ND ND ND
Pb 0.075 mg/L 0.01 ND 0.009 ND 0.010 0.008 0.037 ND ND ND ND
Ni 0.335 mg/L ND ND
Zn 0.126 mg/L 0.138 0.076 0.048 0.110 0.147 0.093 0.408 0.102 0.130 0.056 0.108
TSS 100 mg/L 31 51.6 22.2 20.8 54.7 27.0 83.3 18 4.2 ND 22.0
pH 6-9 6.8 5.2 5.3 5.2 8.6 6.5 6.9 6.8 7.3 8.7 7.8
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 ND
COD 120 mg/L 39 ND ND 41.2 59.8 54.6 112 31 77 32 59
Total Rainfall I in 1 1.8 1 1.24 1 1.0 1 1.8 1 0.5 1 4.3 1 0.5 1 0.2 1 0.3 1 0.5 1.0
SW Outfall B(sheet flow @ Ecoat)
10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021 11/2021 05/2022 11/2022 06/2023
Bench- Post Filter Post Filter Post Filter Post Filter Post-Filter Post-Filter Post-Filter Post-Filter Post-Filter Post-Filter
Characteristic Mark Units Monthly Monthly As Requested As Requested As Requested Semi-AnnI2 Semi-Ann11 Semi-AnnI2 Semi-Ann/1 Semi-AnnI2 Sem1-Ann/1
Oil&Grease 30.00 mg/L ND 5.8
Cr 1.00 mg/L ND 0.008
Cu 0.01 mg/L 0.009 0.012 0.006 0.93 0.02 0.03 0.02 0.02 0.03 ND 0.04
Pb 0.075 mg/L 0.01 0.014 0.010 0.124 0.027 0.037 0.043 0.030 0.063 ND 0.042
Ni 0.335 mg/L ND ND
Zn 0.126 mg/L 0.223 0.21 0.096 1.27 0.216 0.274 0.334 0.287 0.578 0.156 0.543
TSS 100 mg/L 31 125 24.6 1640 111 101 102 69 147 24 126
pH 6-9 7.6 5.4 5.4 6.2 8.8 8.7 7.2 7.4 7.9 8.0 8.5
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 ND
COD 120 mg/L 44 53.1 ND 183.0 87.7 86.2 159 ND ND 27 158
Total Rainfall in 1 1.8 1 1.24 1 1.0 1 1.8 1 0.5 1 4.3 1 0.5 1 0.2 1 0.3 1 0.5 1.0
SW Outfall C(prefilter sheet flow @ Oil House)
10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021 11/2021 05/2022 06/2023
Bench- Post Filter Pre-Filter Post-Filter Pre-Filter Post-Filter Pre-Filter Post-Filter Pre-Filter Pre-Filter Pre-Filter Pre-Filter Pre-Filter
Characteristic Mark Units Monthly Monthly As Requested As Requested As Requested As Requested As Requested As Requested Semi-AnnI2 Semi-Ann/1 Sem1-AnnI2 Semi-A-11 Semi-Annl1
Oil&Grease 30.00 mg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
Cr 1.00 mg/L 0 0.010
Cu 0.01 mg/L 0.023 0.016 ND 0.006 0.035 0.014 0.039 0.132 0.022 0.016 0.04 ND 0.033
Pb 0.075 mg/L 0.02 0.014 ND 0.005 0.040 0.010 0.035 0.114 0.027 0.014 0.140 ND 0.051
Ni 0.335 mg/L 0.01 0.006
Zn 0.126 mg/L 0.651 0.372 0.404 0.307 0.356 0.577 0.652 0.657 0.691 0.917 0.523 0.07 0.30
TSS 100 mg/L 178 88.3 15.9 27.0 138 14.0 317 836 162 92.7 220 88 183
pH 6-9 7.2 6.4 5.6 5.8 6.0 5.2 9.0 8.7 7.8 7.4 7.7 7.7 7.9
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 0.38
COD 120 mg/L 156 80.9 ND 202 117 60.1 232 678 57.0 77.4 71 46 93
Total Rainfall I in 1 1.8 1 1.24 1 1.0 1 1.8 1 0.5 1 4.3 1 0.5 1 0.2 1 0.5 1 1.0
Rainwater(collected in a Plastic Bucket)
Bench- 10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021
Characteristic Mark Units Monthly Monthly As Requested As Requested As Requested Semi-AnnI2 Semi-Ann/1
pH 6-9 5.6 4.3 5.6 4.4 1 5.5

Young, Brianna A
From: Pappalardo,Jenny L. <[e-mail]>
Sent: Monday, February 5, 2024 11:58 AM
To: Young, Brianna A
Subject: RE: [External] RE: Charlotte Pipe and Foundry Company (NCS000040)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
We have stormwater filters in most drains around the building structure housing process operations and at the culverts
where drainage occurs from the property. Outfalls A and B are sheet flow and are taken at the property line after the
filter. Outfall C is sheetflow going into a stormdrain on-site, so the sample is taken before the filter.
From:Young, Brianna A<[e-mail]>
Sent: Monday, February 5, 2024 10:57 AM
To: Pappalardo,Jenny L. <[e-mail]>
Cc: Fedorko,Amanda C. <[e-mail]>
Subject: RE: [External] RE: Charlotte Pipe and Foundry Company (NCS000040)
Good morning,
I have a follow-up question.The monitoring data provided has "Pre-filter" and "Postfilter" data. Can you provide more
information on what these terms refer to?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent:Thursday, February 1, 2024 10:23 AM
To: Pappalardo,Jenny L. <[e-mail]>
1

Cc: Fedorko,Amanda C. <[e-mail]>
Subject: RE: [External] RE: Charlotte Pipe and Foundry Company (NCS000040)
Jenny,
Thank you for this information. I will reach back out with any questions once I've had a chance to review everything.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Pappalardo,Jenny L. <[e-mail]>
Sent:Thursday, February 1, 2024 10:14 AM
To:Young, Brianna A<[e-mail]>
Cc: Fedorko,Amanda C. <[e-mail]>
Subject: [External] RE: Charlotte Pipe and Foundry Company (NCS000040)
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Hi Brianna,
Please see answers in red below and in the attachments.
Please contact me via email or at 704-348-5513 if you need any additional information.
Thank you,
Jenny
From:Young, Brianna A<[e-mail]>
Sent:Wednesday,January 24, 2024 9:00 AM
To: Hall, Mike<[e-mail]>
Cc:Waggoner, David G.<[e-mail]>; Fedorko,Amanda C.<[e-mail]>;
Pappalardo,Jenny L. <[e-mail]>
Subject: RE: Charlotte Pipe and Foundry Company (NCS000040)
Good morning,
2

I am following up on the phone call we had regarding the permit path since the facility will be shutting down. As the final
shutdown and clean-up date is not known,the permit renewal process will continue. If the facility completes close-out
procedures before the permit renewal is issued, you may request the renewal application be withdrawn and the current
permit be rescinded. If the renewed permit is issued before facility shut-down procedures are complete,you may
request a permit rescission in the future.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent: Monday,January 8, 2024 9:35 AM
To: [e-mail]
Cc: [e-mail]; [e-mail]; Pappalardo,Jenny L.
<[e-mail]>
Subject: Charlotte Pipe and Foundry Company(NCS000040)
Good morning,
I am working on renewing the individual stormwater permit for the Charlotte Pipe and Foundry Company
(NCS000040). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Description of chemicals stored onsite; See attachment Form 2F,Section 4.2;The only bulk storage tanks
currently being used are the diesel tank gasoline tank, EG diesel tanks, and used oil tank. The feldspar silo is not
currently used, but there is a residual amount remaining to be disposed. Other bulk material tanks/silos have
been emptied.
• Confirmation on the number of outfalls, associated coordinates, and respective receiving stream(s); See
attachment Figure 1-Site Location Map. Outfalls A, B, C.
• Description of industrial activity in each drainage area;
Area 1
Area I is approximately 9.19 acres in sizewith one 17,000square-foot structure (Gundrill Room). The remainder
of the area consists of asphalt paved parking areas,gravel paved storage areas, storage areas (including coke,
limestone, and slag),and natural landscaped areas. Outside areas between the Gundrill Room and on-ramp
to 1-77N are used primarily as storage spacefor coke, limestone,slag. Minimal amounts may remain for
disposal. Outside areas between the Gundrill Room and Clarkson Street are primarily an used parking area. The
Gun Drill building structure is currently unused.
3

In September 2018, North Carolina Stormwater Division removed our requirement to sample from this area as it
was not deemed to accurately represent stormwater flow from industrial areas (it includes run-off from
stormwater drains not on Charlotte Pipe property and run-off from 1-277).
Area II
Area 11 isapproximately 2.90acres insizewith one51,000square-foot warehouse structure. The remainder of the
area consists of asphalt paved parking areas and natural landscaped areas. The building structure is used
primarily as a warehouse with approximately 20 percent of the floor space used for offices. All items are
currently in the process of being removed from the Warehouse. Storm drainage from Area II drains via storm
drainage structures and storm drainage pipes to a drop inlet structure located on the southwestern corner of
the area (Appendix A,Figure 2).
In May 2009, North Carolina Stormwater Division removed our requirement to sample from this drop inlet
structure as there is no industrial activity in this area.
Area III
Area III is approximately 3.33 acres in size with four structures totaling approximately 16,918 square-feet. Three
buildings (storage)are located onthe northern portion of the area and one building (Quality Control) is located
on the southern portion of the area. The remainder of the area consists of asphalt paved and gravel paved
areas. The Quality Control building is currently unused. Storm drainage from Area III drains via sheetflowto
South Clarkson Streetwhere it is runs into a street storm drainage system (Appendix A,Figure 2). North Carolina
Stormwater Division is not requiring sampling of the sheet flow as there is no industrial activity in this area.
Area IV
Area IV is approximately 7.44acres in size with five structures totaling approximately 17,780 square-feet. Three
buildings are located on the western portion of the area on the main Charlotte Pipe property(Product Bundling
Shed,Small Office Building,and Water Treatment). The Product Bundling Shed and Small Office Building are
unused. The Water Treatment Plant is still in operation. Two buildings are located on the west side of Clarkson
Street(Shipping Department, a portion of the Pattern Storage Building). Both buildings are currently unused.
The remainder of the area consists of asphalt paved areas, gravel paved areas, and natural landscaped
areas. Storm drainage from Area IV drains via storm drainage structures and storm drainage pipes toapipe
discharginginto Irwin Creek. NC Stormwater Division isaware that there is continuous flow through many of the
storm drainage structures due to groundwater enteringthe stormwater system upstream of the Charlotte Pipe
facility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall A to be representative of storm
water drainage from Areas V. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area V
Area V is approximately 2.28 acres in size with four structures totaling approximately 23,000 square-feet. Two of
the buildings arethe main office buildings for Charlotte Pipe, one building is the Machine Shop and one building is
the Welding Shop. The building structures are currently mainly unused. The remainder of the area consists of
scrap iron storage areas and asphalt parking areas. Storm drainage from Area V drains via storm drainage
structures and storm drainage pipes to a pipe discharging into Irwin Creek. NC Stormwater Division is aware that
there is continuous flow through many of the storm drainage structures due to groundwater entering the
stormwater system upstream of the Charlotte Pipefacility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall B to be representative of storm
water drainage from Area V. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
4

from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area VI
Area VI is approximately 1.78 acres in size with two structures totaling approximately 12,109 square-feet. The
Pattern Storage Building, is located west of and across Clarkson Street from the main foundry buildings, is
currently unused. One building, the Main Entrance Guard Shack, is located in the main foundry area. The
Guard Shack is manned 24 hrs/day. The remainder of the area consists of asphalt paved drives and parking,
a15,000-gallon hot dip asphalt tank(emptied) and natural landscaped areas. Storm drainage from Area VI
drains via storm drainage structures and storm drainage pipes to a pipe discharging into Irwin Creek. NC
Stormwater Division is aware that there is continuous flow through many of the storm drainage structures due
to groundwater entering the stormwater system upstream of the Charlotte Pipe facility.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall B to be representative of storm
water drainage from Area VI. In addition, in a letter dated May 27, 2020,the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
Area VII
Area VII is approximately 12.50acres in size with the main foundry buildings, support buildings, bulk material
spent storage area,fuel aboveground storage tanks(ASTs),fueling station,and oil storage building (Oil House).
The majority of the building structures are currently unused but still store process equipment until it can be
removed. The only operations currently active at the site are the Fitting Cleaning, Pipe Reaming and Pipe E-
Coat Operations. The majority of stormwater from this area is run off from the roofs of the foundry buildings.
The remainder of the area consists of asphalt paved parking and storage areas, gravel paved parking and
storage areas,the fuel AST area,the bulk material spent storage area (currently used to stage materials to be
removed from the site), and natural landscaped areas. The area is used primarily for parking space, and storage
space for spent bulk materials, fuel storage tanks, bin storage for finished products, and miscellaneous
equipment used at the facility. Storm drainage from Area VII drains via storm drainage structures and storm
drainage pipes discharging ultimately into Irwin Creek. NC Stormwater Division is aware that there is continuous
flow through many of the storm drainage structures due to groundwater entering the stormwater system
upstream of the Charlotte Pipe facility. A small quantity of stormwater from Area VII (north of the Rolocast
Finishing building and east of Clarkson Street)drains via sheet flow to South Clarkson Street where it is collected
in the street storm drainage system under 1-277(John Belk Freeway)overpass.
In May 2020, North Carolina Stormwater Division identified sheet flow at Outfall C to be representative of storm
water drainage from Area VII. In addition, in a letter dated May 27, 2020, the Division granted regulatory relief
from the Tier responses based on the condition that the TSS Abatement/Best Management Plan be continued,
and that quarterly reports documenting maintenance be submitted to NC.
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit; See attachment INC Checklist Analytical Summary.xls
• Verification that the information in the renewal application is still complete and correct; and Information
as submitted, with updates as per this email. See attachment Form 1, Page 3.
• An explanation of any operational changes since the renewal application was submitted. as noted in the
Summary of Significant Changes, Charlotte Pipe is in the process of shutting down this facility. Charlotte Pipe
intends to continue to take stormwater samples and completed BMP activities (as needed).
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
5

• Facility/Company name or ownership: Name/Ownership Change Form No Change.
• Owner Affiliation (Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form No Change.
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form No Change.
• Billing contact: Permit Contact Update Request Form No Change.
• Permit contact: Permit Contact Update Request Form No Change.
• Facility contact: Permit Contact Update Request Form No Change.
• Facility address only: Email Bethany Geor og ulias No Change.
• Stormwater outfall information: Email Bethany Geor_og ulias No Change.
• Visit the eDMR Six Steps website and complete Steps 1 and 2 Completed.
• Pay outstanding permit fees: Stormwater ePayment website There are no unpaid invoices.
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, INC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
6

Fecal Coliform Total Maximum Daily Load for the
Irwin, McAlpine, Little Sugar and Sugar Creek Watersheds,
Mecklenburg County
Final
February 2002
Catawba River Basin
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Prepared by:
Mecklenburg County Department NC Department of Environment and
of Environmental Protection Natural Resources
Water Quality Section Division of Water Quality
700 North Tryon Street Water Quality Section — Planning Branch
Charlotte, NC 28202 1617 Mail Service Center
[phone] Raleigh, NC 27699-1617
[phone]

NORTH CAROLINA INDEX OF TMDL SUBMITTAL
303(D) LIST INFORMATION
Basin Catawba
303 d Listed Waters Name of Stream Description Class Index# Miles
Irwin Creek From source to Sugar Creek C 11-137-1 11.8
Sugar Creek From SR1156 Mecklenburg, C 11-137b 11.9
to Hwy 51
Sugar Creek From NC Hwy 51 to NC/SC C 11-137c 1.2
state line
Little Sugar Creek From source to Archdale Rd C 11-137-8a 11.8
Little Sugar Creek From Archdale Rd to NC 51 C 11-137-8b 5.3
Little Sugar Creek From NC 51 to state line C 11-137-8c 3.6
McAlpine Creek From source to SR 3356 C 11-137-9a 8.3
(Sardis Rd)
McAlpine Creek From SR 3356 to NC 51 C 11-137-9b 6.3
McAlpine Creek From NC 51 to NC 521 C 11-137-9c 4.7
McAlpine Creek From NC Hwy 521 to NC/SC C 11-137-9d 1.1
state line
8 Digit Cataloging 03050103
Unit(s)
Area of Impairment 69.3 stream miles
WQS Violated Fecal coliform bacteria
Pollutant of Concern Fecal coliform bacteria
Sources of Impairment Point and nonpoint
PUBLIC NOTICE INFORMATION
Form(s) of Public Notification A stakeholders group consisting of environmental groups, local
utilities, and area residents was formed at the onset of the TMDL.
This group met several times during TMDL development and
reviewed the TMDL before formal public notice. Notification of
the public review draft was accomplished through the internet and
by fliers mailed to the basinwide mailing list for Mecklenburg
County and the City of Charlotte. The public comment period for
the TMDL was open from April 30, 2001 until May 31, 2001.
Did notification contain specific Yes
mention of TMDL proposal?
Were comments received from the No
public?
Was a responsiveness summary N/A
prepared?
TMDL INFORMATION
Critical conditions Site-specific critical conditions occurred during periods of low stream flow
coinciding with high fecal coliform loads from both the SSOs and the WWTPs
Seasonality All seasons addressed
Development tools Watershed model, BASINS Versions

NORTH CAROLINA INDEX OF TMDL SUBMITTAL
Page 2 of 2
Supporting documents "Fecal Coliform Total Maximum Daily Load for the Irwin, McAlpine, Little
Sugar, and Sugar Creek Watersheds, Mecklenburg County"and references listed in
report
TMDL(s) Waterbod TMDL (cfu/100mL)
Sugar Creek 8.4x 10
Little Sugar Creek 9.4x1012
McAlpine Creek downstream of Sardis Road 1.lx1013
McAlpine Creek upstream of Sardis Road 6.8x1012
Loadings Sugar Creek watershed:
Point sources 7.4x1012 col/100mL (63%reduction)
Nonpoint sources 8.9x1011 col/100mL (58%reduction)
Little Sugar Creek watershed:
Point sources 6.7x1012 col/100mL (43%reduction)
Nonpoint sources 2.6x1012 col/100mL (19%reduction)
McAlpine Creek watershed(downstream):
Point sources 7.8x1012 col/100mL (70%reduction)
Nonpoint sources 3.2x1012 col/100mL (28%reduction)
McAlpine Creek watershed (upstream):
Point sources 7.8x1012 col/100mL (32%reduction)
Nonpoint sources 5.9x1011 col/100mL (68%reduction)
Margin of Safety Implicit

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table of Contents
1 INTRODUCTION..................................................................................................... 1
1.1 Background........................................................................................................ 1
1.2 Watershed Description........................................................................................ 2
1.3 Water Quality Monitoring Programs................................................................... 2
1.4 Water Quality Target..........................................................................................4
2 SOURCE ASSESSMENT......................................................................................... 5
2.1 Point Source Assessment .................................................................................... 5
2.2 Non-Point Source Asssessment...........................................................................9
3 MODELING APPROACH AND RESULTS........................................................... 19
3.1 Model Framework Selection ............................................................................. 19
3.2 Model Setup ..................................................................................................... 20
3.3 Fecal Coliform Source Representation.............................................................. 22
3.4 Model Calibration............................................................................................. 23
3.5 Critical Conditions............................................................................................ 30
3.6 Model Results................................................................................................... 31
4 ALLOCATION.......................................................................................................40
4.1 Total Maximum Daily Load.............................................................................40
4.2 Waste Load Allocations (Point sources)............................................................41
4.3 Load Allocations (Non-Point sources) ..............................................................43
4.4 Seasonal Variation............................................................................................48
4.5 Margin of Safety...............................................................................................48
5 RECOMMENDATIONS......................................................................................... 50
6 PUBLIC PARTICIPATION.................................................................................... 51
REFERENCES............................................................................................................. 52
APPENDIX 1. USGS AND DWQ MONITORING DATA
APPENDIX 2. IMPLEMENTATION STRATEGY OUTINE
APPENDIX 3. LAND USE
APPENDIX 4. WWTP FLOWS AND FECAL COLIFORM CONCENTRATIONS
APPENDIX 5. SSO DATABASE
APPENDIX 6. RESULTS OF TMDL FIELD STUDY OF STORM DRAINS
APPENDIX 7. GROUNDWATER CONCENTRATION DATA
APPENDIX 8. MODEL SELECTION CRITERIA
APPENDIX 9. PUBLIC PARTICIPATION

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
1 INTRODUCTION
North Carolina's 2000 303(d) list was approved by EPA Region IV on May 15th, 2001. The 2000 list
identified ten stream segments, totaling 66.0 miles, in the Sugar, Little Sugar, and McAlpine Creek
watersheds, as impaired due to elevated fecal coliform concentrations. The objective of this study is
to develop a fecal coliform TMDL using a watershed approach for Irwin, Sugar, Little Sugar, and
McAlpine Creeks. This TMDL encompasses all the stream segments listed in the 2000 303(d) list for
these watersheds.
Table 1. Impaired stream segments listed in NC's draft 2000 303(d) list as Partially Supporting due
to fecal coliform contamination.
Stream Use Support Index No. Location Impaired Stream Miles
Irwin Creek 11-137-1 From source to Sugar Creek 11.8
Little Sugar Creek 11-137-8a From source to Archdale Rd 11.8
Little Sugar Creek 11-137-8b From Archdale Rd to NC 51 5.3
Little Sugar Creek 11-137-8c From NC 51 to state line 3.6
McAlpine Creek 11-137-9a From source to SR 3356, (Sardis Rd) 8.3
McAlpine Creek 11-137-9b From SR 3356 to NC 51 6.3
McAlpine Creek 11-137-9c From NC 51 to NC 521 4.7
McAlpine Creek 11-137-9d From NC Hwy 521 to NC/SC stateline 1.1
Sugar Creek 11-137b From SR 1156 Mecklenburg, to HWY 51 11.9
Sugar Creek 11-137c From Hwy 51 to NC/SC border 1.2
In response to the high level of interest in this TMDL from local government officials and concerned
citizens, a stakeholder group was formed in 1999. The stakeholder group, lead by the Mecklenburg
County Department of Environmental Protection(MCDEP) and the NC Division of Water Quality
(DWQ), took a very active role in every stage of the TMDL development process. MCDEP has a
well developed and respected water quality management program and was able to take the lead role in
both the source assessment and model development.
1.1 Background
Section 303(d) of the Clean Water Act(CWA)requires states to develop a list of waters not meeting
water quality standards or which have impaired uses. This list,referred to as the 303(d) list, is
submitted biennially to the U.S. Environmental Protection Agency(EPA) for review. The 303(d)
process requires that a Total Maximum Daily Load(TMDL)be developed for each of the waters
appearing on Part I of the 303(d) list. The objective of a TMDL is to allocate allowable pollutant
loads to known sources so that actions may be taken to restore the water to its intended uses (EPA
1991). Generally, the primary components of a TMDL, as identified by EPA(1991, 2000) and the
Federal Advisory Committee(FACA 1998), are as follows:
Target identification or selection of pollutant(s) and end-point(s) for consideration. The pollutant
and end-point are generally associated with measurable water quality related characteristics that
indicate compliance with water quality standards. North Carolina indicates known pollutants on
the 303(d) list.
Source assessment. All sources that contribute to the impairment should be identified and loads
quantified, where sufficient data exist.
page 1

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Assimilative capacity estimation or level of pollutant reduction needed to achieve water quality goal.
The level of pollution should be characterized for the waterbody, highlighting how current
conditions deviate from the target end-point. Generally, this component is identified through
water quality modeling.
Allocation of pollutant loads. Allocating pollutant control responsibility to the sources of
impairment. The wasteload allocation portion of the TMDL accounts for the loads associated with
existing and future point sources. Similarly, the load allocation portion of the TMDL accounts
for the loads associated with existing and future nonpoint sources, stormwater, and natural
background.
Margin of safety. The margin of safety addresses uncertainties associated with pollutant loads,
modeling techniques, and data collection. Per EPA(2000), the margin of safety may be
expressed explicitly as unallocated assimilative capacity or implicitly due to conservative
assumptions.
Seasonal variation. The TMDL should consider seasonal variation in the pollutant loads and end-
point. Variability can arise due to stream flows, temperatures, and exceptional events (e.g.,
droughts, hurricanes).
Section 303(d) of the CWA and the Water Quality Planning and Management regulation(USEPA
2000a)require EPA to review all TMDLs for approval or disapproval. Once EPA approves a TMDL,
the waterbody may be moved to Part III of the 303(d) list. Waterbodies remain on Part III of the list
until compliance with water quality standards is achieved. Where conditions are not appropriate for
the development of a TMDL, management strategies may still result in the restoration of water
quality.
The goal of the TMDL program is to restore uses to water bodies. Thus the implementation of
bacterial controls will be necessary to restore uses in these creeks. Although an implementation plan
is not included in this TMDL, reduction strategies are needed. The involvement of local governments
and agencies will be needed in order to develop implementation plans. The MCDEP and affected
groups began developing the implementation plan during public review of the TMDL.
1.2 Watershed Description
The Sugar, Little Sugar and McAlpine Creek watersheds are all located within Mecklenburg County,
North Carolina. The headwaters of each watershed originates in Mecklenburg County and all three
creeks flow into the State of South Carolina. In South Carolina, Little Sugar and McAlpine Creeks
are tributary to Sugar Creek. Figure 1 shows the location of the three TMDL watersheds within
Mecklenburg County.
Each compliance point utilized for this TMDL is associated with ambient monitoring that occurs in
the watersheds. Water quality and quantity data is collected at multiple locations within these three
watersheds by different agencies. For the purposes of assessing TMDL compliance the DWQ stations
were used. There are five DWQ ambient monitoring stations within the Sugar, Little Sugar, and
McAlpine Creek watersheds. These locations are noted on Figure 1. Other monitoring is discussed
below.
1.3 Water Quality Monitoring Programs
The MCDEP, DWQ, Charlotte Mecklenburg Utilities (CMU),USGS, and South Carolina Department
of Health and Environmental Control(DHEC) collect ambient data in the Sugar, Little Sugar, and
McAlpine Creek watersheds at regular intervals. However, CMU analyses do not include fecal
coliform bacteria. DWQ maintains five ambient monitoring locations in the Sugar, Little Sugar, and
page 2

Figure 1: Location of TMDL Watersheds Within Mecklenburg County
P
m
a
Irwin Creek
Upstream of Sugar ~
Creek VVVVTP '
8 N
Legend WEE
5
• Compliance Points Q
Meck. Co. Streams
Q
Sugar Creek
Little Sugar Creek
McAlpine Creek
0 Mecklenburg County
z o
McAlpine Creek
at Sardis Road ° ore in°�ma wn wn�c��ne Nec�kn°ug
Q Sugar Creek /f
b
at NC 51 Little Sugar Creek McAlpine Creek
at NC 51 at S 29-64

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
McAlpine Creek watersheds. MCDEP maintains over 15 monitoring locations and DHEC maintains
three within North Carolina. A list of USGS flow gauges, DWQ ambient stations, and data
summaries is presented in Appendix 1.
1.4 Water Quality Target
All TMDLs include the establishment of in-stream numeric endpoints, or targets,used to evaluate the
attainment of water quality goals and designated use criteria. The target represents the restoration
objective to be achieved by implementation of load reductions specified by the TMDL. For the
TMDLs presented in this document, the fecal coliform 30-day geometric mean of 200 c.f.u./100 mL
is applicable, as referenced in NC's water quality standard for fecal coliform in Class C waters (15A
NCAC 2B .0211 (3)(e)).
Secondary recreation is the designated use being addressed in this TMDL. Secondary recreation is
defined in NC's standards (15A NCAC 2B .0202 (57)) as including"wading,boating, other uses not
involving human body contact with water, and activities involving human body contact with water
where such activities take place on an infrequent, unorganized, or incidental basis." MCDEP officials
believe that the streams addressed in this document are used for secondary recreation by the local
residents predominantly during warm temperature, non-storm conditions. High stream flow activities
such as white water kayaking are not known to take place on a frequent and organized basis in these
predominantly urban streams. Hence, MCDEP and DWQ have focused the source assessment and
TMDL allocation on those sources and conditions, which represent the highest risk to human health
during the times of highest recreational use by the public.
For calibration purposes fecal coliform contributions delivered to the streams via stormwater runoff
from unidentified sources were estimated and included in the model. However, loadings from
unidentified, stormwater delivered sources were not included as part of the target evaluation and no
load allocation was assigned to these sources which could not be identified.
Four compliance points have been established for these TMDLs, representing every DWQ ambient
monitoring station location in the affected watersheds. Compliance points are physical locations
within a watershed that are used to monitor water quality conditions and assess progress on the
TMDL.
page 4

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
2 SOURCE ASSESSMENT
In an urban setting such as Mecklenburg County,potential sources of fecal coliform in a water body
are numerous and often time transient. For the purpose of this report, the sources of fecal coliform
have been divided into two broad categories; point sources and non-point sources. Point sources can
be defined as sources, either constant or time transient, which occur at a fixed location in a watershed.
Non-point sources are generally accepted to be diffuse sources not entering a water body at a specific
location. Examples of point sources are wastewater treatment plants (WWTP) and documented
sanitary sewer overflows. Examples of non-point sources are stormwater runoff, dry weather flow
from storm drains and groundwater.
The source assessment presented in this document represents the best estimation of the sources of
fecal coliform in the TMDL watersheds at this time. Additional investigation into the sources and
distribution of sources of fecal coliform is critical to achieving the water quality target. Therefore, it
is expected that, in the future, the source assessment will be modified to reflect additional data.
Specifically, seasonal changes and the variation between watersheds needs to be better understood.
Specific investigations and program enhancements are presented in the Implementation Strategy
(Appendix 1).
2.1 Point Source Assessment
All documented point source dischargers were included in the source assessment. Actual discharge
values for fecal coliform concentration and effluent flow rate were used throughout the TMDL. In
the absence of direct measurements,permit limit values were used. This was critical for model
calibration because National Pollutant Discharge Elimination System(NPDES)Permitted dischargers
contribute the vast majority of flow in the TMDL watersheds during dry periods. Furthermore, it was
assumed that discharges recorded during 1999 are typical and effectively estimate future conditions.
However, many of the discharges recorded during 1999 were well below permit limits and increases
in discharges are likely.
2.1.1. NPDES Permitted Dischargers
Tables 2, 3 and 4 present the breakdown of permitted NPDES point source dischargers in the Little
Sugar Creek, McAlpine Creek and Sugar Creek Watersheds respectively. Figure 2 is a map of the
TMDL Watersheds showing the locations of the permitted point source dischargers. Appendix 3
presents the daily flow rates and fecal coliform loadings for the McAlpine Creek WWTP, Sugar
Creek WWTP and Irwin Creek WWTP.
page 5

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 2: Permitted NPDES Dischargers in the TMDL Watersheds
NATIONAL WELDERS SUPPLY COMPANY, INC
F
FRANKLIN WATER TREATMENT PLANT
EYERHAEUSERINC.
WEYERHAEUSER PAPER COMPANY
BP STORE#24763
QUICK MART
HERTZ COUSINS REAL ESTATE TOMMY'S AUTOMOTIVE
CARILLON BUILDING NATIONS BANK
NATIONS BANK/HOUSING
THREE FIRST UNION CENTER
TERRELL PROPERTIES CIRCLE K#8382
r� IRWIN CREEK WWTP
MINT HILL FESTIVAL SHOPPING CENTER
CHARLOTTE DOUGLAS INTERNATIONAL AIRPORT
AMOCO#57
SUGAR CREEK WWTP
CELANESE ACETATE,LLC-2300 ARCHDALE DR FOREST RIDGE WWTP
INDUSTRIAL PIPING,INC
MCALPINE CREEK WWTP
N
Legend
0 Little Sugar Creek Watershed
0 Sugar Creek Watershed
0 McAlpine Creek Watershed
page 6

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 2: NPDES Permitted Dischargers in Little Sugar Creek Watershed
Facility ID Address Sub- NPDES ID Flow Rate Fecal Coliform
Watershed (cfs) Loading
ID cfu/hour
Nations Bank 525 N Tryon St 003 NCG510398 0* -
Nations Bank 401 N Tryon St 003 NCG510277 0.003*
Housing (none)
Three First Union 301 S Tryon St 003 NCO086207 0.008* -
Center 0.029 mgd)
Weyerhaeuser Inc. 201 E 28th St 003 NCO084298 0.0072 -
0.0072 mgd)
BP Store#24768 7214 The Plaza 006 NCG510242 0 -
Tommy's 6000 The Plaza 006 NCG510387 0* -
Automotive
Celanese Acetate 2300 Archdale Dr 008 NCO084301 0.1152 -
Sugar Creek WWTP 5301 Closeburn Rd 008 NCO024937 Daily* Daily*
(20 mgd) (200/100 ml mo
ave
400/100 ml
weekly ave.
Note: *indicates measured values
cfs=cubic feet per second(ft3/sec)
permit limits shown in parentheses
Table 3: NPDES Permitted Dischargers in McAlpine Creek Watershed
Facility ID Address Sub- NPDES ID Flow Rate Fecal Coliform
Watershed (cfs) Loading
ID (cfu/hour)
Circle K#8382 9201 Lawyers Road 001 NCG510200 0.0001* -
(none
Forest Ridge 1076 Kalewood Dr 002 NCO029181 0.138* 4.2E+05*
WWTP (0.15 mgd) (200/100 ml mo
ave
400/100 ml daily
max
Mint Hill Festival 6908 Matthews- 007 NCO063789 0.031* 3.4E+05*
Shopping Center Minthill Road (0.035 mgd) (200/100 ml mo
ave
400/100 ml daily
max
Amoco#57 4475 Randolph 003 NCO085286 0.0144
Road 0.0144 mgd)
McAlpine Creek 12701 Lancaster 006 NCO024970 Daily* Daily*
WWTP Hwy (48 mgd) (200/100 ml mo
ave
400/100 ml
weekly ave.)
Note: *indicates measured values
permit limits shown in parentheses
page 7

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 4: NPDES Permitted Dischargers in Sugar Creek Watershed
Facility ID Address Sub- NPDES ID Flow Rate Fecal Coliform
Watershed (cfs) Loading
ID (cfu/hour
Carillon Building 227 W Trade St 003 NCO085731 0.003* -
(0.0316 mgd)
Cousins Real Estate 800 W Trade St 003 NCO086517 0.05 -
0.05 mgd)
Franklin Water 5200 Brookshire 004 NCO084549 1.36 -
Treatment Plant Blvd none
Quick Mart 2501 Freedom 004 NCG510284 0 -
Drive
Weyerhaeuser Paper 5419 Hovis Road 004 NCO084298 0.0072(0.0072 -
Company mgd)
Irwin Creek WWTP 4000 Westmont 005 NCO024945 Daily*(15 Daily*
mgd) (200/100 ml mo
ave
400/100 nil
weekly ave.)
Terrell Properties 3000 South Blvd 005 NCO085391 0.0007*(0.004 mgd)
Industrial Piping, 800 Culp Rd 006 NCO056669 0.003* 1.2E+05*
Inc (200/100 ml mo
ave
400/100 ml daily
max
National Welders 5305 Old Dowd 010 NCO079758 0.0143 (0.0143 -
Supply Company, Road mgd)
Inc.
Charlotte Douglas 5501 Josh Oil NCO083887 0.01*(none) -
International Airport Birmingham P
Hertz 6521 Old Dowd Oil NCO084000 0* -
Road
Note: *indicates measured values
permit limits shown in parentheses
2.1.2 Sanitary Sewer Overflows
Charlotte Mecklenburg Utilities (CMU) sanitary sewers serve all of the Sugar Creek, Little Sugar
Creek and McAlpine Creek Watersheds. However, there are three private NPDES facilities with
permit limits for fecal coliform in the TMDL watersheds (Tables 2 and 3). Data is not available for
un-permitted overflows from the collection systems of these three private facilities. CMU maintains
the Sanitary Sewer Overflow Database(SSO Database) system, which is a computerized database of
all un-permitted discharges from their collection system. The database includes the location, date and
time the discharge started and stopped, whether or not the discharge reached a surface water body,
estimated discharge volume and additional data not pertinent to this report. Using this information,
all documented un-permitted discharges from CMU's collection system were geocoded using a GIS
system. The resulting GIS coverage was then subdivided by sub-watershed for inclusion in the water
quality model. A fecal coliform concentration in sewage of 6.4 x 10'cfu/100 ml was used to
page 8

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
calculate loading values (Center for Watershed Protection, 1999). It is important to note that the SSO
Database system may not accurately document the start of an unpermitted discharge because the start
time recorded is the moment CMU is first contacted about the discharge(Gallaher, 2001). Processed
SSO Database system data for each of the TMDL watersheds is included with this report in Appendix
4. Note, complete SSO Database system data was only available from July, 1998 through June, 2000.
Figure 3 depicts the location of each CMU overflow included in this study.
2.2 Non-Point Source Assessment
Non-point sources of fecal coliform are generally attributed to stormwater runoff, however, for the
purpose of this report, widely distributed point sources were included in the non-point source
category. Examples of widely distributed point sources are failing septic systems and dry weather
flow from storm drains. Additionally, impacts from sanitary sewer exfiltration and wildlife were
investigated.
2.2.1 Stormwater Runoff
Typically, assessment of the contribution of stormwater runoff is based upon estimations of wildlife,
agricultural operations and typical accumulation rates on built up (urban) areas. However, for this
report, build-up and wash off rates for each land-use in the TMDL watersheds were calculated from
local in-stream stormwater samples collected by the United States Geological Survey(USGS) from
December 1993 to September 1997 (Bales et. Al, 1999). The in-stream samples were collected
seasonally(four sampling events per year) from relatively uniform land-uses. Each TMDL land-use
was paired with a sample site draining a similar land-use as presented in Bales et. Al., 1999 (Note:
calculations were based upon raw data obtained from USGS and summarized in Bales (et. Al., 1999)).
Table 5 presents the build-up and maximum accumulation levels used in this study.
Table 5: Rate of Accumulation and Maximum Storage of Fecal Coliform by Land-Use
TMDL Land-Use Dominant Land-Use Rate of Maximum Storage
from Bales et. Al., Accumulation of of Fecal Coliform
1999 Fecal Coliform (count per acre)
(count per acre per
day)
Heavy Residential/ Institutional& High 9.04 x 109 1.9 x 1010
Institutional Density Residential
Light Residential Woods/Brush& Low 6.86 x 109 1.44 x 1010
DensityResidential
Heavy Industrial Heavy Industrial 2.68 x 109 5.63 x 109
Heavy Commercial Heavy Industrial 2.68 x 109 5.63 x 109
Light Commercial/ Light Industrial& 3.2 x 1010 6.72 x 1010
Light Industrial Light Commercial
Woods/Brush Woods/Brush&Very 5.48 x 109 1.15 x 1010
Low Density
Residential
page 9

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 3: SSO Locations in the TMDL Watersheds
M '
0016
•
S . •
•
% •
M ',•
,. • • . • % •
• • r
•
•
0
•
•
•
' N
Legend
SSO Location
0 Sugar Creek Watershed
0 McAlpine Creek Watershed
0 Little Sugar Creek Watershed
page 10

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
2.2.2 Failing Septic Systems
Failing septic systems have been cited in many TMDLs as a significant contributor of fecal coliform
to water bodies (Tennessee Department of Environment and Conservation, Division of Water
Pollution Control, Watershed Management Section, 2000). Previous studies have used failure rate
values ranging from 4%to 50% of all septic systems. The Mecklenburg County Health Department
has estimated the local septic system failure rate to be 1%, (Daniel, 2000). The Health Department
cited the following reasons for this estimate(Daniel, 2000):
• In general, Mecklenburg County soils are highly conducive to septic system operation;
• Areas where soil types are not conducive to septic system operation have been excluded from
septic system use and existing systems in these areas have been targeted for integration to the
CMU sanitary sewer system; and,
• Mecklenburg County has been a leader in enacting septic system regulation in North Carolina,
which has prevented the installation of sub-standard systems.
Many stakeholders, including Charlotte Mecklenburg Utilities, have questioned the validity of a 1%
failure rate for septic systems. Personal observations and anecdotal evidence appear to indicate a
much higher value. However, no documentation of a local investigation to establish a more accurate
or reproducible value exists. Because of the lack of direct evidence to refute the 1%value cited by
the Health Department, that value has been adopted for the TMDLs presented in this document.
Discussion of additional investigation into the failure rate of septic systems in Mecklenburg County
will be presented in the Implementation Strategy(Appendix 1).
No direct accounting of the number of septic systems in use in the TMDL watersheds was available.
Estimates of the possible number of septic systems were completed through analysis of Mecklenburg
County Finance Department data. Essentially, a listing of all built upon parcels of land meeting the
following criteria was provided:
• Parcels receiving water bills but no sewer bills. It was inferred that these parcels are likely to be
using a septic system. Residences and businesses using small package systems not operated by
CMU were omitted from the list; and,
• Parcels receiving no water bills or sewer bills but that were built upon. It was inferred that these
parcels are likely to be using a septic system. Residences and businesses using small package
systems not operated by CMU were omitted from the list.
The pared down list meeting the above criteria was then geocoded using a GIS system and subdivided
by TMDL sub-watershed. An estimated 2.8 individuals were served by each septic system(Daniel,
2000), an estimated flow rate per person of 70 gallons per individual per day(Horsely and Witten,
1996) and an estimated fecal coliform concentration of 10,000 c.f.u./100 ml(Horsely and Whitten,
1996)were used to calculate the loading and flow rates. Tables 6, 7 and 8 present the septic system
information used in the water quality model by sub-watershed in the Sugar Creek, Little Sugar Creek
and McAlpine Creek Watersheds respectively.
page 11

Irvin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 6: Septic System Loading and Flow for Sugar Creek Watershed
Sub- Number Individua Individuals Failure FC FC Load Flow
Watershed of is per Served Rate Concentration (cfu/hour) (cfs)
Septic System (%) in effluent
Systems c.f.u./100 nil)
001 717 2.8 2007.6 1 10000 2.2E+07 0.0022
002 392 2.8 1097.6 1 10000 1.2E+07 0.0012
003 325 2.8 910 1 10000 1.0E+07 0.0010
004 1117 2.8 3127.6 1 10000 3.4E+06 0.0034
005 426 2.8 1192.8 1 10000 1.3E+06 0.0013
006 43 2.8 120.4 1 10000 1.3E+06 0.0001
007 172 2.8 481.6 1 10000 5.3E+06 0.0005
008 26 2.8 72.8 1 10000 8.0E+05 0.0001
009 520 2.8 1456 1 10000 1.6E+07 0.0016
010 426 2.8 1192.8 1 10000 1.3E+07 0.0013
Oil 169 2.8 473.2 1 10000 5.2E+06 0.0005
Table 7: Septic System Loading and Flow for Little Sugar Creek Watershed
Sub- Number Individua Individuals Failure FC FC Load Flow
Watershed of is per Served Rate Concentration (cfu/hour) (cfs)
Septic System (%) in effluent
Systems c.f.u./100 nil)
001 381 2.8 1066.8 1 10000 1.1E+07 0.0012
002 313 2.8 876.4 1 10000 9.6E+06 0.0009
003 545 2.8 1526 1 10000 1.6E+07 0.0017
004 480 2.8 1344 1 10000 1.4E+07 0.0015
005 388 2.8 1086.4 1 10000 1.1E+07 0.0012
006 271 2.8 758.8 1 10000 8.3E+06 0.0008
009 105 2.8 294 1 10000 3.2E+06 0.0003
008 64 2.8 179.2 1 10000 1.9E+06 0.0002
Table 8: Septic System Loading and Flow for Little Sugar Creek Watershed
Sub- Number Individuals Individuals Failure FC FC Load Flow
Watershed of per System Served Rate Concentration (cfu/hour) (cfs)
Septic in effluent
Systems c.f.u./100 nil)
003 168 2.8 470.4 1 10000 1.2E+08 0.0005
006 709 2.8 1985.2 1 10000 5.2E+08 0.0021
007 344 2.8 963.2 1 10000 2.5E+08 0.0010
008 809 2.8 2265.2 1 10000 6.0E+08 0.0025
009 255 2.8 714 1 10000 1.8E+08 0.0008
010 263 2.8 736.4 1 10000 1.9E+08 0.0008
012 373 2.8 1044.4 1 10000 2.7E+08 0.0011
013 786 2.8 2200.8 1 10000 5.8E+08 0.0024
page 12

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
2.2.3 Dry Weather Flow from Storm Drains
Dry weather flow from storm drains has been the subject of multiple investigations in Mecklenburg
County. Initially, an accounting of the storm drain outfalls for the City of Charlotte,which comprises
most of the TMDL watersheds, was completed in 1991 (Ogden Environmental&Engineering
Services, 1991). This study included the production of a system-wide outfall coverage for use with
GIS systems. Additionally, 500 screening points were selected for a field investigation to document
the presence of dry weather flow. Of the 500 sites visited, 201 (40.2 %)were found to have dry
weather flow. Follow-up activities were completed by the MCDEP from December 1995 to October
1997 at 231 of the outfalls identified as having the potential for dry weather flow pollution(MCDEP,
1998). The follow-up study did not include an assessment of fecal coliform. In order to assess the
fecal coliform loading from the storm drain system for the TMDLs, an additional study was
completed by MCDEP from June 2000 to October 2000. For the TMDL study, 168 outfalls were
randomly selected from the GIS outfall coverage produced in 1991 for screening of flow and fecal
coliform. For the TMDL study, dry weather flow was defined as flow occurring after a minimum of
72 hours without rain. Of the 168 outfalls visited during the TMDL study 165 were located and 33
(19.6%)were found to have dry weather flow. Possible reasons for the reduction in dry weather flow
from the 1991 study(40.2 %)to the 2000 study(19.6 %) are ongoing investigation of dry weather
sources of pollution and different definitions of dry weather flow. Figure 4 shows the locations of the
outfalls evaluated during the TMDL study and the distribution of the outfalls for the entire storm
drain system. Based upon the data collected from the 33 outfalls that had dry weather flow, a flow
rate of 0.0146 cfs and a fecal coliform loading rate of 22,925,015 c.f.u./hour were calculated. Results
of the TMDL study are presented in Appendix 5. Note in Appendix 5, that some outfalls have dry
weather flow but no flow rate or fecal coliform concentration. These outfalls were inaccessible for
sample collection or flow measurement, however dry weather flow was observed. For development
of the TMDL, it was assumed that the results of the TMDL study were representative of the entire
storm drain system in the TMDL watersheds. Using a GIS system and the system-wide outfall
coverage, the total number of outfalls in each of the sub-watersheds in the TMDL watersheds was
determined. Overall flow and fecal coliform loading rates were then calculated for each sub-
watershed using the total number of outfalls per sub-watershed and the results of TMDL study.
Tables 9, 10 and 11 present the results of the TMDL study for the Sugar Creek, Little Sugar Creek
and McAlpine Creek watersheds respectively.
Table 9: Dry Weather Flow and Fecal Coliform Loading for Sugar Creek
Sub-Watershed #of Outfalls #Outfalls Dry Weather Dry Weather
ID w/Dry Weather FC Loading Flow-Rate (cfs)
Flow cfu/hour
001 48 9.3 2.1 x 109 0.1359
002 10 1.9 4.4 x 10 0.0283
003 72 14.0 3.2 x 10' 0.2038
004 134 26.0 5.9 x 10" 0.3793
005 91 17.7 4.0 x 10" 0.2576
006 0 0.0 0 0.0000
007 57 11.1 2.5 x 10 0.1614
008 13 2.5 5.7 x 107 0.0368
009 50 9.7 2.2 x 10" 0.1415
O10 64 12.4 2.8 x 10" 0.1812
Oil 4 0.8 1.7x 10 0.0113
page 13

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 4: Results of TMDL Study of Storm Drain System
• • C
s
s
•
• a
t�
Legend
N a Location Without Dry Weather Flow
from TMDL Study
O Location With Dry Weather Flow from
TMDL Study
Little Sugar Creek Watershed
Sugar Creek Watershed
McAlpine Creek Watershed
page 14

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 10: Dry Weather Flow and Fecal Coliform Loading for Little Sugar Creek
Sub-Watershed #of Outfalls #Outfalls Dry Weather Dry Weather
ID w/Dry Weather FC Loading Flow Rate(cfs)
Flow cfu/hour)
001 105 20.5 4.4 x 10' 1.5312
002 146 28.5 6.1 x 10' 2.1291
003 125 24.4 5.2 x 10 1.8228
004 202 39.4 8.5 x 10" 2.9457
005 147 28.7 6.1 x 107 2.1436
006 120 23.4 5.0 x 10" 1.7499
009 96 18.7 4.0 x 10 1.3999
008 38 7.4 1.6 x 10 0.5541
Table 11: Dry Weather Flow and Fecal Coliform Loading for McAlpine Creek
Sub-Watershed # of Outfalls #Outfalls Dry Weather Dry Weather
ID w/Dry Weather FC Loading Flow-Rate (cfs)
Flow cfu/hour
001 226 44.3 1.0 x 109 0.6460
002 2 0.4 8.9 x 106 0.0057
003 13 2.5 5.8 x 107 0.0372
006 1 0.2 4.5 x 10 0.0029
007 127 24.9 5.7 x 10 0.3630
008 6 1.2 2.6 x 107 0.0171
009 103 20.2 4.6 x 10" 0.2944
O10 132 25.9 5.9 x 10" 0.3773
012 32 6.3 1.4 x 10 0.0915
013 157 30.8 7.0 x 10" 0.4487
2.2.4 Wildlife
Typically, for TMDL purposes, wildlife are accounted for in the calculation of build-up and wash-off
rates, which are then incorporated into a water quality model. For the purpose of this report, build-up
and wash-off rates were developed from direct sampling by land-use and therefore, no direct
assessment of wildlife contributions to fecal coliform concentration in stormwater runoff was
conducted. Excluding the contribution of wildlife to build-up and wash-off rates, the only remaining
pathway of inputting fecal coliform contributions from wildlife to a water body is through direct
application. Examples of wildlife meeting this criterion in the TMDL watersheds, which are largely
urban, are geese(Branta canadensis), ducks (Anas platyrhynchos) and beavers (Castor canadensis).
Estimates of the population of these species were provided by the Mecklenburg County Park and
Recreation Department using anecdotal knowledge of the species and informal surveys (Seriff, 2001).
All species counts were assumed to be adults. No significant populations of livestock exist in these
watersheds and were excluded from the study. Table 12 presents population estimates by TMDL
watershed for geese, ducks and beavers.
page 15

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 12: Wildlife Population Estimates by TMDL Watershed
Species Percentage of Fecal Production Sugar Creek Little Sugar McAlpine
time in direct Rate (total Creek Creek
contact with (count/animal/day) population) (total (total
creeks o ulation) ppopulation)
Geese 0% 4.9 x 1010 40 150 200
Ducks 10% 2.43 x 109 20 50 100
Beaver 25% 2.5 x 10 0 0 10
Fecal production rates obtained from Tetra Tech,Inc.(2001).
Percentage of time in direct contact with active water obtained from Serriff(2001).
To determine the total fecal coliform loading from wildlife, a total load for each TMDL sub-
watershed was determined using species population, fecal production rates and typical species
behavior. For the purposes of this study, fecal coliform contributions from wildlife will occur
through direct application; therefore, wildlife contact must occur with a moving stream or a pond or
wetland, which flows directly to a stream. Ducks and beavers spend a significant percentage of their
time in direct contact with moving water; however, their fecal production rates are very low. Geese
have the highest fecal production rate; however, they have minimal direct contact with the TMDL
creeks, which are typically narrow, shallow and have a wide tree overhang, which is unsuitable
habitat for geese. However, geese are frequently in direct contact with ponds and wetlands, which are
often times hydraulically connected to the TMDL creeks during the wet winter months and
disconnected during the dryer summer months. For the purposes of this study, 1%, 10% and 2 5%of
the fecal coliform load from geese, ducks and beavers respectively was input to the creek. Tables 13,
14 and 15 present the fecal coliform loading for the Sugar Creek, Little Sugar Creek and McAlpine
Creek Watersheds respectively.
Table 13: Fecal Coliform Loading from Wildlife for Sugar Creek
Sub- FC Loading FC loading FC Loading Total Wildlife Notes
Watershed from Geese from Ducks from Beavers FC Load
ID cfu/hour cfu/hour cfu/hour cfu/hour
Geese Not
Contributing in
Summer Months
009 8.17 E+08 2.03E+08 0 1.02E+09
Table 14: Fecal Coliform Loading from Wildlife for Little Sugar Creek
Sub- FC FC loading FC Loading Total Wildlife Notes
Watershed Loading from Ducks from Beavers FC Load
ID from Geese (cfu/hour) (cfu/hour) (cfu/hour)
cfu/hour
Geese
contributing year
002 1.53E+09 2.53E+08 0 1.78E+09 round
Geese
contributing year
008 1.53E+09 2.53E+08 0 1.78E+09 round
page 16

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 15: Fecal Coliform Loading from Wildlife for McAlpine Creek
Sub- FC FC loading FC Loading Total Wildlife Notes
Watershed Loading from Ducks from FC Load
ID from (cfu/hour) Beavers (cfu/hour)
Geese (cfu/hour)
cfu/hour
Geese
contributing
012 1.53E+11 3.04E+09 1.04E+08 1.56E+11 year round
008 0 1.01E+09 0 1.01E+09
001 0 5.06E+08 0 5.06E+08
002 0 5.06E+08 0 5.06E+08
Geese
5.10E+10 contributing
010 1.01E+09 0 5.21E+10 year round
007 0 1.01E+09 0 1.01E+09
Geese not
contributing in
summer
009 8.17E+10 0 0 8.17E+10 months
Geese
contributing
003 5.10E+10 0 0 5.10E+10 year round
Geese
contributing
013 2.04E+10 1.01E+09 0 2.14E+10 year round
Geese
contributing
006 5.10E+10 2.03E+09 0 5.31E+10 year round
2.2.5 Exfiltration from Sanitary Sewer Pipes
In the North Carolina Piedmont Physiographic Province, groundwater flows to the creek except
during runoff events. This provides the possibility for surface water impact from groundwater during
times of moderate to low flow. A previously unstudied possible source of fecal coliform in
Mecklenburg County surface waters is the leaking or exfiltration of untreated sewage from sanitary
sewer pipes to groundwater, which may then flow to surface water. In an effort to investigate this
possible source, 18 shallow groundwater monitoring wells were installed at 9 locations throughout
Mecklenburg County(MCDEP, 2000(a)). The sites were selected by CMU and MCDEP to represent
all line sizes, construction material and construction techniques present in the CMU collection
system. At each of the 9 sites a minimum of 1 well was installed between the sewer line and the
creek and 1 well was installed upgradient of the sewer line. One groundwater sample was collected
and groundwater elevations calculated at each of the 18 monitoring wells weekly from November 13,
page 17

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
2000 to December 27, 2000 (MCDEP, 2000(b)). At 5 of the sites the sewer line was below the water
table, therefore making exfiltration highly unlikely. None of the samples collected at these 5 sites
contained measurable concentrations of fecal coliform in either the upgradient or downgradient well.
At the remaining 4 sites, the sewer line was above the water table, making exfiltration from the sewer
pipe hydraulically possible. At these sites fecal coliform was detected in 3 out of 4 downgradient
wells. None of the samples collected from the upgradient wells at these 4 sites contained measurable
concentrations of fecal coliform. Measured concentrations in the downgradient wells at these sites
ranged from a minimum of<10 c.f.u./100 ml to a maximum of 1700 c.f.u./100 ml. In order to
establish a representative groundwater concentration for use in the water quality models, an average
of all sampling data was calculated. This resulted in an average fecal coliform concentration in
groundwater of 58 c.f.u./100 ml,which was input to the water quality model as a constant
groundwater concentration. The fecal coliform sampling data and analysis is included as Appendix 6.
It is important to note that failing septic systems may discharge to groundwater, which may also flow
to surface water, however discharges from failing septic systems have been assessed as a separate
source(See Section 2.2.2 above). It is important to note that the investigation of exfiltration from
sanitary sewer pipes was extremely limited. It is likely that the conclusions presented in this
document will be modified as additional data becomes available.
page 18

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
3 MODELING APPROACH AND RESULTS
Water quality modeling is an integral part of any TMDL developed for an environmental pollutant.
Establishing the relationship between in-stream water quality and source loadings with a water quality
model is a critical component of TMDL development. Similarly, water quality models have the
ability to support regulatory decisions and the development of implementation strategies.
3.1 Model Framework Selection
In response to the expected increase in water quality modeling due to the TMDL process, the United
States Environmental Protection Agency(USEPA) developed a document entitled"Compendium of
Tools for Watershed Assessment and TMDL Development"(Shoemaker et. Al., 1997). This
document was intended to serve as a guide to model selection, however it does not endorse the use of
a particular model for any pollutant or setting. Model selection is left up to the organization
developing a TMDL and often the most important selection criterion is familiarity. Because of the
lack of firm guidance, the Technical Subcommittee of the TMDL Stakeholders Group developed a
model selection process whereby each model under consideration was carefully assessed based on
fixed criteria. Likewise, future modeling considerations were taken into account such that experience
and similar aspects could be built upon for future modeling projects. The remainder of this section
discusses the rational for model selection.
For the purpose of the TMDL, the top six ranked models in each category in Shoemaker et. Al. (1997)
were selected for evaluation. The models included the following:
Simple Models:
1. Simple Method
2. Watershed Management Model
Moderately Complex Models:
3. SLAMM
4. P8-UCM
Complex Models:
5. NPSM/HSPF
6. SWMM
The following criteria were used to compare the models:
? Ease of Use;
? Defensibility(and/or acceptability);
Accuracy;
Available Sources;
Baseflow/Stormflow;
User Interface;
Tools;
Support;
Data Requirements;
Dynamic(or Steady State);
? Other notable points.
page 19

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Using these criteria a model selection matrix was prepared and is included with this document as
Appendix 7.
With the exception of P8-UCM, all of the models reviewed were capable of modeling fecal coliform
in surface water. An important factor to be considered was the ability of the model to accurately
represent baseflow conditions. Accurate baseflow simulation was important because the TMDL
includes dry weather conditions. Additionally, the model needed to be able to accurately simulate
both point and non-point sources of fecal coliform. Furthermore, the time transient quality of point
sources, such as WWTP effluent and SSOs, warranted the use of a continuous simulation model.
Based upon the aforementioned criteria,NPSM/HSPF was selected for use in preparation of the Fecal
Coliform TMDLs for the Sugar Creek, Little Sugar Creek and McAlpine Creek watersheds. HSPF is
a spatially distributed, lumped parameter, continuous simulation model used to model water quality
conditions in watersheds and river basins. HSPF calculates non-point source loadings of selected
pollutants for specified land use categories in a watershed; represents subsequent pollutant runoff
response to hydrologic influences, such as precipitation; simulates point sources as constant or
variable flow and load; and simulates flow and pollutant routing through a stream network.
3.2 Model Setup
Figures 5 shows the sub-watershed delineations for the Sugar Creek, Little Sugar Creek and
McAlpine Creek Watersheds. Sub-watershed delineation was based upon factors such as the
presence of USGS gaging station, presence of a water quality monitoring site, presence of a
NCDENR compliance point, confluence of major stream segments and presence of major point
source dischargers. Sub-watershed delineation, stream cross section geometry, slope and length were
determined using Mecklenburg County's version of the Watershed Information System, which is a
GIS based application that allows the manipulation of digital elevation data for modeling
applications. Locally developed land use data (based upon individual land parcels)was simplified
and used for model preparation. Table 16 shows the land uses used in the TMDL models along with
percent imperviousness. Percent imperviousness by TMDL land-use was determined by intersecting
the TMDL land-use GIS coverage with an impervious surface GIS coverage. Appendix 2 presents
the distribution of land use by sub watershed for the Sugar Creek, Little Sugar Creek and McAlpine
Creek watershed respectively. Also included in Appendix 2 are maps showing the distribution of
land use in the Sugar Creek, Little Sugar Creek and McAlpine Creek Watersheds. With the exception
of rainfall, all weather data was adopted from the Charlotte Douglas International Airport(WBAN
13881). Rainfall data was adopted from USGS rainfall gages located in each watershed. USGS
station numbers 351331080525945, 351553080562645 and 02146600 were used for the Sugar Creek,
Little Sugar Creek and McAlpine Creek Watersheds respectively.
Table 16. Percent Impervious by Land-Use for TMDL Water Quality Models
Land Use in TMDL Models Percent Impervious
Heavy Commercial 77.2
Heavy Industrial 38.5
Light Commercial/Light 49.2
Industrial
Woods/Brush 7.4
Heavy Residential 32.5
Light Residential 19.6
page 20

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 5: Sub-Watershed Deliniations for the TMDL Watersheds
2 1
00 0
3 6
10 3 05
05
01 00 0 4 001
00-
0
00
002
00 0 9
0
6
N
Legend
Streams
0 Sugar Creek Watershed
0 McAlpine Creek Watershed
0 Little Sugar Creek Watershed
page 21

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
3.3 Fecal Coliform Source Representation
Both point and non-point sources of fecal coliform are represented in the water quality model.
Certain non-point source categories are not associated with land loading processes and are
represented as direct, in-stream source contributions in the model. These include failing septic
systems, dry weather flow from the storm drain system, wildlife in streams and sanitary sewer
overflows. Land loading non-point sources are represented as indirect contributions to the stream
through build-up and wash-off processes (see Section 2.2.1 above). The following sections describe
the assumptions used for the various sources described in Section 2.0.
3.3.1 NPDES Discharges
There are 8, 5 and 11 NPDES point source dischargers in the Little Sugar, McAlpine and Sugar Creek
Watersheds respectively. With the exception of the CMU WWTPs, all NPDES dischargers were
represented in the model as constant(do not vary with time) sources of both flow and fecal coliform.
CMU WWTPs were represented as variable sources in the model with a flow and fecal coliform
loading rate for each day during the simulation period. CMU's self-monitoring data was used to
calculate the loading and flow values. The data used to prepare the CMU WWTP variable source
input files is included as Appendix 3.
3.3.2 Sanitary Sewer Overflows
Sanitary sewer overflows were represented in the water quality models as time variable point sources.
The geocoded sanitary sewer overflow data from CMU's SSO database was transformed into an
hourly loading file appropriate for NPSM/HSPF. In other words, an individual loading value was
developed for each hour an overflow occurred in each sub-watershed. The loading values were
calculated as described in Section 2.1.2.
3.3.3 Urban Development
Fecal coliform loading from urban areas was represented in the model as both pervious and
impervious surfaces. Typically,urban loading rates are adjusted as a primary calibration parameter in
the water quality model. However, for the water quality models developed for the TMDL watersheds
discussed in this report, loading values were determined through local focused land-use sampling.
Therefore, it was assumed that the values calculated were representative of both pervious and
impervious urban loading in Mecklenburg County and were not altered in the model to better fit
observed data. The values used in the model are presented in Section 2.2.1 above.
3.3.4 Dry Weather Flow
Fecal coliform loading values from dry weather flow were input to the water quality models as
continuous point sources by sub-watershed. The fecal coliform loading rates are presented in Section
2.2.3 above.
3.3.5 Failing Septic Systems
Fecal coliform loading values from failing septic systems were input to the water quality models as
continuous point sources by sub-watershed. The fecal coliform loading rates are presented in Section
2.2.2 above.
page 22

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
3.3.6 Wildlife
Fecal coliform loading values from wildlife is represented in water quality simulations as described in
section 2.2.4 above. Approximate counts of each wildlife species by sub-watershed were used to
determine the fecal loading rates. The loading rates were input to the model as continuous point
sources by sub-watershed.
3.3.7 Exfiltration from Sanitary Sewer Pipes
Fecal coliform loading rates contributed by exfiltration from sanitary sewer pipes were input to the
water quality models as a constant groundwater concentration of 58 c.f.u./100 ml(see Section 2.2.5
above)
3.4 Model Calibration
Calibration of a dynamic loading model involves both hydrologic and water quality components. The
model must be calibrated to accurately represent hydrologic response in the watershed before
reasonable water quality simulations can be performed. The hydrologic calibration involves
comparison of simulated stream-flows to observed stream-flow data from stream gaging stations in
the watershed. Simulated stream-flows are generated by the model using both meteorological data
and the physical characteristics of the watershed. Typically, certain model parameters are altered
until a reasonable match is developed between simulated and observed stream flow. Similar
techniques are used to calibrate the water quality portion of the model.
A complete stream-flow data set for the Sugar Creek, Little Sugar Creek and McAlpine Creek
Watersheds was only available from July 1998— June 2000. In order to obtain the best possible
hydrologic calibration and representation of pollutant loads, all model simulations were limited to this
time frame. Although the data set was limited to July 1998— June 2000, all model runs were started
on January 01, 1998 to allow the model to stabilize.
All model inputs, calibration and validation information, and full model results are discussed in the
full modeling report, which is presented in Appendix 8. A condensed presentation of the hydrologic
calibration data is included as Tables 17, 18, 19, 20 and 21 for the Sugar Creek, Irwin Creek, Little
Sugar Creek, McAlpine Creek Downstream of Sardis Road and McAlpine Creek Upstream of Sardis
Road respectively. Much of the difference presented in Tables 17, 18, 19, 20 and 21 may be
attributable to the use of a single rain gage in each of the TMDL watersheds. Although the rain gages
used were located in each TMDL watershed, a significant variation in rainfall distribution has been
reported within each watershed(Sarver et. al., 1999). Figures 6, 7, 8, 9 and 10 are plots of the
hydrology calibration for Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek
Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road respectively. Figures 11,
12, 13, 14 and 15 are plots of the water quality calibration for Sugar Creek, Irwin Creek, Little Sugar
Creek, McAlpine Creek Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road
respectively.
page 23

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 17: Basic Hydrology Calibration Data for Sugar Creek
Parameter Goal Observed Simulated Difference
Total of Highest 10%of
flows 15% 8730 9930 12.1%
Total of Lowest 50%of
flows 10% 5597 5515 1.5%
Observed Summer flow
volume 30% 4484 4555 1.6%
Observed Fall flow
volume 30% 4091 5617 27.2%
Observed Winter flow
volume 30% 8959 9180 2.4%
Observed Spring Flow
volume 30% 5575 5391 3.4%
Observed Total Volume 10% 23109 24744 6.6%
Note: Goal was adopted from HSPEXP.
Note: Units in cfs
Table 18: Basic Hydrology Calibration Data for Irwin Creek
Parameter Goal Observed Simulated Difference
Total of Highest 10%of
flows 15% 4788 5132 6.7%
Total of Lowest 50%of
flows 10% 1961 1770 10.8%
Observed Summer flow
volume 30% 2428 2307 5.3%
Observed Fall flow
volume 30% 1871 1819 2.8%
Observed Winter flow
volume 30% 1809 2288 21%
Observed Spring Flow
volume 30% 3862 4206 8.2%
Observed Total Volume 10% 9970 10620 6.1%
Table 19: Basic Hydrology Calibration Data for Little Sugar Creek
Parameter Goal Observed Simulated Difference
Total of Highest 10%of
flows 15% 12187 10634 14.6%
Total of Lowest 50%of
flows 10% 6024 6267 3.9%
Observed Summer flow
volume 30% 5602 5299 5.7%
Observed Fall flow
volume 30% 4548 5676 19.9%
Observed Winter flow
volume 30% 9919 10334 4.0%
Observed Spring Flow
volume 30% 5584 6010 7.1%
Observed Total Volume 10% 25653 27320 6.1%
Note: Goal was adopted from HSPEXP.
Note: Units in cfs
page 24

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 6: Sugar Creek Hydrology Calibration
10000
observed
simulated
1000
N
� 100
O
LL
10
1
9/30/1998 11/19/1998 1P811999 2/27/1999 4/18/1999 6/7/1999 7/27/1999 9/15/1999
Date
Figure 7: Irwin Creek Hydrology Calibration
10000
Simulated
Observed
1000
g 100
0
LL
10 N V k) VT I 'V1 JAA
1
10/1/1998 11 J2011998 1/9/1999 2/28/1999 4/19/1999 6P811999 7/28/1999 9/16/1999
Date
page 25

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 8: Little Sugar Creek Hydrology Calibration
10000
simulated
observed
1000
3
0
LL
100
10
9/30/1998 11/19/1998 1 P811999 2/27/1999 4/18/1999 6/7/1999 7/27/1999 9/16/1999
Date
Figure 9:McAlpine Creek Downstream of Sardis Road Hydrology Calibration
10000
simulated
observed
1000
100
3
0
LL
10
1
note: VVWTP Flow removed for calibration-USGS Gage is Upstream of VVVVTP Effluent
0.1
10/1/1998 11/20/1998 1/9/1999 2/28/1999 4/19/1999 6P811999 7/28/1999 9/16/1999
Date
page 26

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 10: McAlpine Creek Upstream of Sardis Road Hydrology Calibration
10000
06served
Simulated
1000
100
3
0
LL
10
1
0.1
9/30/1998 11/19/1998 1 P811999 2/27/1999 4/18/1999 6I711999 7/27/1999 9/15/1999
Date
Figure 11: Water Quality Calibration for the Sugar Creek Watershed
10000
E
0
1000
3
C
O
C
C �
O
V
0
V 100
R
V
LL
• DENR Data
MCDEP Ambient
■ MCDEP First Flush
—Standard
—Simulated
10
01101f99 02f20f99 04MJ99 05f31f99 07f20f99 MOWN 10f28f99 12f17f99
Date
page 27

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 12: Water Quality Calibration for the Irwin Creek Watershed
10000
E
0
]coo
3
C
O
• H IN 11 •
C
C • •
O •
V
E
`o
o • •
V 100
R
V
LL •
•
MCDEP Ambient
• • —Standard
—Simulated
• DENR Data
10
VV1999 2f2011999 4MJ1999 5f31f1999 W20f1999 901999 10JM1999 12f17f1999
Date
Figure 13: Water Quality Calibration for the Little Sugar Creek Watershed
100000
■ DENR Data
MCDEP Ambient
—Simulated
MCDEP Storm Data
10000
0
3
V
c 1000
o ■
E 100 ■
L
O ■
O ■
U
V
LL 10
1
Jan-99 Feb-99 Apr-99 May-99 Jul-99 Sep-99 Oct-99 Dec-99
Date
page 28

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 14: McAlpine Creek Downstream of Sardis Road Water Quality Calibration
10000
E
0
0
1000
u
c
0
c
m
u
c
0
V
`o
0 100
V
U MCDEP Storm
m
LL DWQ Data
• DWQ Data
MCDEP Ambient
—Standard
—30 day geomean
10
01 N1 h99 02/20/99 04111/99 05f31 r99 07/20/99 09N8h39 10/28/99 12/17/99
Date
Figure 16:Water Quality Calibration for the McAlpine Creek Watershed Upstream of Sardis Road
100000
■ DWQ Data
MCDEP Ambient Data
—Simulated
10000
0
0
w
0
m 1000
V
C
O
U
E
O
O
U
16 ■
V ■
LL 100
10
01/01/99 02/20/99 04/11/99 05/31/99 07/20/99 09/08/99 10/28/99 12/17/99
Date
page 29

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 20: Basic Hydrology Calibration Data for McAlpine Creek Downstream of Sardis Road
Parameter Goal Observed Simulated Difference
Total of Highest 10%of
flows 15% 17086 16864 1.3%
Total of Lowest 50%of
flows 10% 2366 2603 9.1%
Observed Summer flow
volume 30% 3027 3329 9.0%
Observed Fall flow
volume 30% 2978 4242 29.8%
Observed Winter flow
volume 30% 2936 4213 30.3%
Observed Spring Flow
volume 30% 4810 4847 0.7%
Observed Total Volume 10% 25692 26365 2.6%
Note: Goal was adopted from HSPEXP.
Note: Units in cfs
Table 21: Basic Hydrology Calibration Data for McAlpine Creek Upstream of Sardis Road
Parameter Goal Observed Simulated Difference
Total of Highest 10%of
flows 15% 4616 5003 7.7%
Total of Lowest 50%of
flows 10% 974 1119 13.0%
Observed Summer flow
volume 30% 2000 2023 1.2%
Observed Fall flow
volume 30% 1341 1462 8.3%
Observed Winter flow
volume 30% 1363 1817 25.0%
Observed Spring Flow
volume 30% 5512 7739 28.8%
Observed Total Volume 10% 10216 13042 21.7%
Note: Goal was adopted from HSPEXP.
Note: Units in cfs
In order to assess the status of the hydraulic calibration of the models the goals presented in Table 17,
18, 19, 20 and 21 were adopted from HSPEXP (USGS, 1994). Similarly, for water quality
calibration, model parameters (primarily the first order decay coefficient)were adjusted until the
closest match of simulated and observed concentrations were made. The closeness of the match was
evaluated using the sum of the squares of the differences between simulated and observed values.
The models were evaluated by sources outside MCDEP for reasonableness, completeness and basis in
reality. As a result of the outside evaluation, improvements to the model were suggested and adopted.
3.5 Critical Conditions
Fecal coliform contributions to Sugar Creek, Little Sugar Creek and McAlpine Creek may be
attributed to both point and non-point sources. Critical conditions for waters impaired by non-point
sources generally occur during periods of wet weather, whereas those impaired by point sources
generally occur during dry periods. Among the categories of non-point sources are sources that
continuously discharge directly to the water body. Examples include failing septic systems, dry
weather flow from storm drains and wildlife. It is important to note that the TMDLs discussed in this
document do not include stormwater runoff as an allocation category.
page 30

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
The critical conditions for fecal coliform impairment in Sugar Creek, Little Sugar Creek and
McAlpine Creek are extended periods of dry weather. Typically, these conditions occur during the
summer (June through September)when the minimum stream-flow is available for dilution.
However, critical conditions may occur at practically any time because of the highly dynamic and
time transient quality of both SSO loads and WWTP effluent loads. Therefore, the 30-day geometric
mean of the fecal coliform concentrations produced by the water quality models were used to
determine the critical conditions (in other words, flow was not the only consideration). It is important
to note that the critical low-flow, dry weather conditions occur during periods when there is not
washoff of fecal coliform from the land surface.
3.6 MODEL RESULTS
3.6.1 Existing Conditions
Exclusive of stormwater runoff, model results indicate that the primary sources of fecal coliform
contamination in the Little Sugar, Sugar and McAlpine Creek Watersheds are point sources and direct
input non-point sources (failing septic systems etc.).
3.6.2 Critical Conditions
Results of the year-long water quality simulation of the 30-day geometric mean concentration for
existing conditions at the outlet of the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek
Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road Watersheds are shown in
Figures 16, 17, 18, 19 and 20 respectively. Critical conditions for each watershed occurred during
periods of low stream flow coinciding with high fecal coliform loads from both the SSOs and the
WWTPs. The date of maximum exceedance, according to the model simulation, is the time period
preceding and including the highest simulated exceedance of the 30-day geometric mean standard.
Achieving the water quality criteria for this period ensures that water quality criteria will be achieved
for the remainder of the modeling period. The highest 30-day geometric mean for each watershed is
listed in Table 22.
Table 22: Critical Condition for the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek
Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road Watersheds.
Watershed Date of Predicted Value of Predicted Maximum
Maximum Exceedance (30 day geomean FC
Exceedance Concentration [c.f.u./100 ml]
Sugar Creek 06/28/1999 365.24
Irwin Creek 06/28/1999 362.09
Little Sugar Creek 12/21/1999 297.34
McAlpine Creek 08/17/1999 284.43
Downstream of Sardis
Road
McAlpine Creek 09/12/1999 883.20
Upstream of Sardis
Road
page 31

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 16: Existing and TMDL Conditions for the Sugar Creek Watershed
400
350
—Existing Conditions
—TMDL Conons
c
0
p 300
c
c
0
U
E 250
`o
6
U
,a 30 Day Geometric Mean Standard
m 200
LL
C
N
m
150
E
0
C9
T
N
❑ 100 h�A
0
m
50
0
01f01f99 02f20199 04f11f99 05131f99 07120f99 09f08f99 10f28f99 12f1T99
Date
Figure 17: Existing and TMDL Conditions for the Irwin Creek Watershed
400
350
—Existing Conditions
—TMDL Conditions
c
0
.p 300
c
c
0
U
E 250
`o
6
U
,a 30 Day Geometric Mean Standard
m 200
LL
C
N
m
150
E
0
0
J A- n
N
❑ 100
0
m
50
0
01f01f99 02f20199 04f11f99 05131f99 07120f99 09f08f99 10f28f99 12f17f99
Date
page 32

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 18: Existing and TMDL Conditions for the Little Sugar Creek Watershed
350
—TMDL Conditions
—Existing Conditions
c 300
e
m
V
c 250
V
`o
�j 200 30 Day Geometric Mean Standard
m
m
LL
C
d 150 A 7A A
V
_V V
0
0 100
01
W
O
0
50
0
01 N1/99 02/20/99 04111/99 06 31/99 07/20/99 09/08/99 10/28/99 12/17/99
Date
Figure 19: Existing and TMDL Conditions for the McAlpine Creek Watershed Downstream
of Sardis Road
300
—Existing Conditions
—TMDL Coditions
c
250
m
e
m
V
c
0
200 AAA
`o
0
V
m
m 150
LL
C
01
V
m 100
3=
O
01
0
0 50
m
0
11/1/1998 12/21/1998 2/9/1999 3/31/1999 5/20/1999 7/9/1999 8/28/1999 10/17/1999 1201999 1/25C2000
Date
page 33

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 20: Existing and TMDL Conditions for the McAlpine Creek Watershed Upstream of
Sardis Road
1000
900 —Existing Conditions
0
—TMDL Conditions
c
800
m
u
c
v 700
E
`o
0 600
V
m
u
m 500
LL
C
0
400 AA AA A
C]
C
300
E
m
30 Day Geometric Mean Standard
200
0
0
M
100
0
01 O 99 02/20/99 04/11/99 05/31/99 07720/99 09/08/99 10/28/99 12/17/99
Date
page 34

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Tables 23, 24, 25, 26 and 27 present the contribution of each of the source categories to the date of
maximum exceedance listed in Table 22. Figures 21, 22, 23, 24 and 25 graphically display the fecal
Coliform load by source category during these times for the Sugar Creek, Irwin Creek, Little Sugar
Creek and McAlpine Creek Downstream of Sardis Road and McAlpine Creek Upstream of Sardis
Road Watersheds respectively.
Table 23: Loading Values by Source Category for the Date of Maximum Exceedance in the Sugar
Creek Watershed(05/29/1999— 06/27/1999).
Source Category Source Sub-Category FC Load c.f.u./30 days)
Point Source WWTP 3.8 x 1012
Sanitary Sewer Overflows 1.6 x 1013
Non-Point Source Wildlife 1.5 x 1011
Failing Septic Systems 1.0 x loll
Dry Weather Flow from 1.8 x 10
Storm Drain System
Sewer Exfiltration 1.0 x loll
All Sources 2.0 x 10
13
Table 24: Loading Values by Source Category for the Date of Maximum Exceedance in the Irwin
Creek Watershed(05/29/1999— 06/27/1999).
Source Category Source Sub-Category FC Load c.f.u./30 days)
Point Source WWTP 5.6 x 10
Sanitary Sewer Overflows 1.2 x 10
Non-Point Source Wildlife -
Failing Septic Systems 1.0 x 10
ll
Dry Weather Flow from 1.7 x 1012
Storm Drain System
Sewer Exfiltration 1.5 x 10"
All Sources 1 1.9 x 10
ll
Table 25: Loading Values by Source Category for the Date of Maximum Exceedance in the Little
Sugar Creek Watershed(11/21/1999— 12/20/1999).
Source Category Source Sub-Category FC Load(c.f.u./30 days)
Point Source WWTP 3.2 x 10
Sanitary Sewer Overflows 8.6 x 1012
Non-Point Source Wildlife 1.9 x 1012
Failing Septic Systems 3.1 x 1010
Dry Weather Flow from 1.7 x 1011
Storm Drain System
Sewer Exfiltration 3.9 x 10
11
All Sources 1.6 x 1013
page 35

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 21: Current and TMDL Fecal Coliform Loading by Source Category for the Sugar Creek
Watershed During Critical Condition
1.80E+13
1.60E+13 ■Current Conditions
■TMDL Conditions
1.40E+13
m
c 1.20E+13
L'
1.00E+13
m
0
J
E 8.00E+12
0
0
v 6.00E+12
m
u
m
LL
4.00E+12
2.00E+12
0.00E+00-�+ ' I — I — I I
WWTP SSO Wildlife Septic Dry Weather Flow Sewer Exfiltration
Source Category
Figure 22: Current and TMDL Fecal Coliform Loading by Source Category for the Irwin Creek
Watershed During Critical Condition
1.40E+13
■Current Conditions
1.20E+13
■TMDL Conditions
1.00E+13
0
L'
u 8.00E+12
m
0
J
0
6.00E+12
0
V
m
m 4.00E+12
LL
2.00E+12
0.00E+00 F1
WWTP SSO Wildlife Septic Dry Weather Flow Sewer Exfiltration
Source Category
page 36

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 23: Current and TMDL Fecal Coliform Loading by Source Category for the Little Sugar
Creek Watershed during Critical Condition
9E+12
8E+12 ❑Current Conditions
■TMDL Conditions
7E+12
m
c 6E+12
L'
5E+12
m
0
J
E 4E+12
0
0
v 3E+12
m
u
m
LL
2E+12
1 E+12
0
WWTP SSO Wildlife Septic Dry Weather Flow Sewer Exfiltration
Source Category
Figure 24: Current and TMDL Fecal Coliform Loading by Source Category for the McAlpine
Creek Watershed Downstream of Sardis Road During Critical Condition
1.8E+13
1.6E+13 ■Current Conditions
■TMDL Conditions
1.4E+13
m
c 1.2E+13
L'
1.0E+13 hEL
m
0
J
E 8.0E+12
0
0
v 6.0E+12
m
u
m
LL
4.0E+12
2.0E+12
0.0E+0D
WWTP SSO Wildlife Septic Dry Weather Flow Sewer Exfltration
Source Category
page 37

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Figure 25: Current and TMOL Fecal Coliform Loading by Source Category for the McAlpine
Creek Watershed Upstream of Sardis Road
1.4E+13
■Current Conditions
■TMDL Conditions
1.2E+13
1 E+13
0
L'
u 8E+12
m
0
J
0
6E+12
0
V
m
m 4E+12
LL
2E+12
0
WWTP SSO Wildlife Septic Dry Weather Flow Sewer Exfiltration
Source Category
page 38

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 26: Loading Values by Source Category for the Date of Maximum Exceedance in the
McAlpine Creek Watershed Downstream of Sardis Road(07/18/1999— 08/16/1999).
Source Category Source Sub-Category FC Load c.f.u./30 days)
Point Source WWTP 1.6 x 1013
Sanitary Sewer Overflows 9.8 x 1012
Non-Point Source Wildlife 2.3 x 1012
Failing Septic Systems 5.7 x 1010
Dry Weather Flow from 1.3 x 10
Storm Drain System
Sewer Exfiltration 8.0 x loll
All Sources 3.2 x 1013
Table 27: Loading Values by Source Category for the Date of Maximum Exceedance in the
McAlpine Creek Watershed Upstream of Sardis Road(07/18/1999— 08/16/1999).
Source Category Source Sub-Category FC Load c.f.u./30 days)
Point Source WWTP -
Sanitary Sewer Overflows 1.2 x 10
Non-Point Source Wildlife 6.2 x 10
10
Failing Septic Systems 4.9 x 10
Dry Weather Flow from 9.2 x 1011
Storm Drain System
Sewer Exfiltration 8.8 x loll
All Sources 1.4 x 10
page 39

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
4 ALLOCATION
4.1 Total Maximum Daily Load
The TMDL process quantifies the amount of a pollutant that can be assimilated by a water body,
identifies the sources of the pollutant, and recommends regulatory or other actions to be taken to
achieve compliance with applicable water quality standards based on the relationship between
pollution sources and in-stream water quality conditions. A TMDL can be expressed as the sum of all
point source loads (Waste Load Allocations [WLAs]), non-point source loads (Load Allocations
[LA]), and an appropriate margin of safety(MOS),which takes into account any lack of knowledge
concerning the relationship between the effluent limitations and water quality:
TMDL= WLAs+I LAs+MOS
The objective of a TMDL is to allocate loads among all of the known pollutant sources throughout a
watershed so that appropriate control measures can be implemented and water quality standards
achieved. 40 CFR § 130.2 (I) states that TMDLs can be expressed in terms of mass per time, toxicity,
or other appropriate measure. For fecal coliform, TMDLs are expressed as counts per 30 days to be
consistent with the water quality standard. Therefore, the TMDL represents the maximum fecal
coliform load that can be assimilated by the stream during the critical 30 day period while
maintaining the fecal coliform water quality standard of the geometric mean of 200 c.f.u./100 ml over
30 days.
The total maximum daily load of fecal coliform was determined by adding the WLA and LA. The
MOS was implicitly included in the TMDL analysis through conservative model inputs and
assumptions and does not factor directly in the TMDL equation as shown above. The TMDLs for the
Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek Downstream of Sardis Road and
McAlpine Creek Upstream of Sardis Road Watersheds are listed in Table 28. Also included in Table
28 are the number of exceedances of 400 c.f.u./100 ml predicted by the model for calendar year 1999.
Note that daily average fecal coliform concentrations were used to produce these counts.
Table 28: TMDLs for the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek
Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road Watersheds
Watershed Predicted Critical Predicted TMDL Number of exceedances
Condition (c.f.u./30 days) of 400/100 ml during
1999 % in arentheses
Sugar Creek 07/01/1999* 8.4 x 1012 26 7%
Irwin Creek 06/30/1999** 7.7 x 1012 49 13%
Little Sugar Creek 12/21/1999 9.4 x 1012 15 4%
McAlpine Creek 09/06/1999** l.lx 1013 25 (7%)
Downstream of Sardis
Road
McAlpine Creek 09/06/1999*** 6.8 x 1012 22 (6%)
Upstream of Sardis
Road
*Note: after SSO sources were reduced in the water quality model,the date of maximum exceedance moved from
06/28/1999 to 07/02/1999.
page 40

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
*Note: after SSO sources were reduced in the water quality model,the date of maximum exceedance moved from
06/28/1999 to 07/30/1999.
***Note: after SSO sources were reduced in the water quality model,the date of maximum exceedance moved from
08/17/1999 to 09/06/1999.
****Note: after SSO sources were reduced in the water quality model,the date of maximum exceedance moved from
09/12/1999 to 09/06/1999.
4.2 Waste Load Allocations (Point Sources)
The WLA for the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek Downstream of
Sardis Road and McAlpine Creek Upstream of Sardis Road Watershed is presented in Tables 29, 30,
31, 32 and 33 respectively. The same information is presented graphically in Figures 21, 22, 23, 24
and 25. In all three watersheds, the sum of the fecal coliform load from point sources vastly
outweighs the load from non-point sources during the critical conditions. Therefore, reductions to the
point sources would have the greatest impact on the in-stream fecal coliform concentration. The
reduction strategy for the point sources is as follows:
NPDES Permitted Dischargers: For calculation of the TMDL, the NPDES permitted dischargers
were held to a maximum fecal coliform concentration in their effluent of 1000 c.f.u./100 MI. The
original WWTP time variable input files for the model were altered to reflect these changes and then
re-input to the model.
Sanitary Sewer Overflows: For calculation of the TMDL, the occurrence of overflows was cut by
33.3 %, 25%, 25%and 33% in the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek
Downstream of Sardis Road and McAlpine Creek Upstream of Sardis Road respectively..
Additionally, the remaining SSOs were limited to a maximum of 3 hours of flow. The original SSO
time variable input files for the model were altered to reflect these changes and then re-input to the
model.
Table 29: In Stream Fecal Coliform Load Reductions for the Sugar Creek Watershed(05/30/1999
06/28/1999).
Source Category Source Sub- Original FC FC Load after Reduction
Category Load(c.f.u./30 Reduction
days) (c.fu./30 da s)
Point Source(WLA) WWTP 3.8 x 10 3.5 x 10 7.2 %
Sanitary Sewer 1.6 x 10 3.9 x 10 75.7%
Overflows
Non-Point Source Wildlife 1.5 x 1011 1.5 x 1011 0 %
(LA)
Failing Septic 1.0 x loll 3.8 x 1010 61.7%
Systems
Dry Weather Flow 1.8 x 1012 7.0 x 1011 61.7 %
from Storm Drain
System
Sewer Exfiltration 1.0 x loll 8.5 x 109 91.6 %
All Sources 2.0 x 1013 8.4 x 1012 59.2 %
(TMDL)
page 41

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 30: In Stream Fecal Coliform Load Reductions for the Irwin Creek Watershed(05/30/1999
06/28/1999).
Source Category Source Sub- Original FC FC Load after Reduction
Category Load(c.f.u./30 Reduction
days) c.fu./30 days
Point Source(WLA) WWTP 5.6 x 10 5.4 x 10 3.6 %
Sanitary Sewer 1.2 x 10 1.6 x 10 86.7%
Overflows
Non-Point Source Wildlife - - -
LA
Failing Septic 1.0 x loll 4.0 x 1010 60.0%
Systems
Dry Weather Flow 1.7 x 1012 6.8 x 10" 60.0 %
from Storm Drain
System
Sewer Exfiltration 1.5 x 10 1.3 x 10 91.3 %
All Sources 1.9 x 1013 7.8 x 1012 58.9 %
(TMDL)
Table 31: In-Stream Fecal Coliform Load Reductions for the Little Sugar Creek Watershed
(11/21/1999- 12/20/1999).
Source Category Source Sub- Original FC FC Load after Reduction
Category Load(c.f.u./30 reduction
days) c.fu./30 da s
Point Source(WLA) WWTP 3.2 x 1012 2.7 x 1012 16.7%
Sanitary Sewer 8.6 x 1012 4.0 x 1012 53.2 %
Overflows
Non-Point Source Wildlife 1.9 x 1012 1.9 x 1012 0 %
(LA)
Failing Septic 3.1 x 10 1.2 x 10 60 %
Systems
Dry Weather Flow 1.7 x 1011 6.8 x 1010 60 %
from Storm Drain
System
Sewer Exfiltration 3.9 x 1011 4.4 x 1010 88.7 %
All Sources 1.6 x 1013 9.4 x 1012 40.9 %
(TMDL)
page 42

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 32: In-Stream Fecal Coliform Load Reductions for the McAlpine Creek Watershed
Downstream of Sardis Road(08/07/1999- 09/05/1999).
Source Category Source Sub- Original FC FC Load after Reduction
Category Load(c.f.u./30 Reduction
days) c.f.u./30 da s
Point Source(WLA) WWTP 1.6 x 1013 5.7 x 1012 64.0 %
Sanitary Sewer 9.8 x 1012 2.1 x 1012 78.2 %
Overflows
Non-Point Source Wildlife 2.3 x 1012 2.3 x 1012 0 %
(LA)
Failing Septic 5.7 x 10 3.5 x 10 38.1%
Systems
Dry Weather Flow 1.3 x 1012 7.7 x 1011 39.7%
from Storm Drain
System
Sewer Exfiltration 8.0 x loll 8.7 x 1010 89.1 %
All Sources 3.2 x 1013 1.1 x 1013 65.8 %
(TMDL)
Table 33: In-Stream Fecal Coliform Load Reductions for the McAlpine Creek Watershed Upstream
of Sardis Road(08/07/1999- 09/05/1999).
Source Category Source Sub- Original FC FC Load after Reduction
Category Load reduction
(c.fu./30 (c.fu./30 days)
days)
Point Source(WLA) WWTP - - -
Sanitary Sewer 1.2 x 1013 7.8 x 1012 32.6 %
Overflows
Non-Point Source Wildlife 6.2 x 1010 6.2 x 1010 0 %
(LA)
Failing Septic 4.9 x 109 2.4 x 109 50.7 %
Systems
Dry Weather Flow 9.2 x 1011 4.2 x 1011 53.8 %
from Storm Drain
System
Sewer Exfiltration 8.8 x 10 1.1 x loll 87.7 %
All Sources 1.4 x 1013 6.8 x 1012 52.1 %
(TMDL)
4.3 Load Allocations (Non-Point Sources)
The LA for the Sugar Creek, Irwin Creek, Little Sugar Creek and McAlpine Creek Watershed is
presented in Tables 29, 30, 31, 32 and 33 respectively. Modeling results indicate much less impact
from non-point sources in the TMDL watersheds than from point sources. Therefore, large
reductions in non-point source loads have lesser impact than reductions in point source loads. The
reduction strategy for the non-point sources is as follows:
page 43

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Wildlife: For calculation of the TMDL, no reductions in fecal coliform loading from wildlife were
included.
Failing Septic Systems: For calculation of the TMDL, estimated fecal coliform loads from failing
septic systems were reduced by 60% in the Sugar Creek, Irwin Creek and Little Sugar Creek
Watershed, 40%in the McAlpine Creek Watershed Downstream of Sardis Road and 80% in the
McAlpine Creek Watershed Upstream of Sardis Road. The original constant input files for the model
were altered to reflect this load reduction.
Dry Weather Flow from Storm Drains: For calculation of the TMDL, estimated fecal coliform loads
from dry weather flow from storm drains were reduced by 60% in the Sugar Creek, Irwin Creek and
Little Sugar Creek Watersheds, 40%in the McAlpine Creek Watershed Downstream of Sardis Road
and 80%in the McAlpine Creek Watershed Upstream of Sardis Road. The original constant input
files for the model were altered to reflect this load reduction.
Exfiltration from Sanitary Sewer Pipes: For calculation of the TMDL, estimated groundwater and
interflow concentrations in the model were reduced to 5 c.f.u./100 ml.
Tables 34, 35, 36, 37 and 38 present example reduction strategies that were used to calculate the
TMDLs in the Sugar Creek, Irwin Creek, Little Sugar Creek, McAlpine Creek downstream of Sardis
Road and McAlpine Creek Upstream of Sardis Road respectively. The reductions presented in this
table represent calculated reductions based entirely upon the source assessment. It is highly likely
that once implementation begins, this matrix will change to reflect additional data. The tables are
presented for comparison purposes only.
Table 34: Example Source Reduction Strategy for the Sugar Creek Watershed
Source Original Source Example Reduction Example Source
Category Distribution Scenario Distribution
WWTP No Daily Max Max 1000 c.f.u./100 NA
ml conc. In effluent
SSOs 86 SSOs; 371 hour 33%Reduction and 3 57 SSOs; 165 hour
duration hour duration duration
Wildlife 40 Geese NA 40 Geese
20 Ducks 20 Ducks
Septic Sytems 43.3 Failing Septic 60%Reduction 17.3 Failing Septic
Systems Systems
Dry Weather 105.4 Outfalls with 60%Reduction 42.2 Outfalls with Dry
Flow Dry Weather Flow Weather Flow
Sewer 58 c.f.u./100 ml in 5 c.f.u./100 ml in NA
Exfiltration Ground Water Ground Water
page 44

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 35: Example Source Reduction Strategy for the Irwin Creek Watershed
Source Original Source Example Reduction Example Source
Category Distribution Scenario Distribution
WWTP No Daily Max Max 1000 c.f.u./100 NA
ml conc. In effluent
SSOs 55 SSOs; 228 hour 33%Reduction and 3 36 SSOs; 103 hour
duration hour duration duration
Wildlife NA NA NA
Septic 29.7 Failing Septic 60%Reduction 11.9 Failing Septic
Systems Systems Systems
Dry Weather 68.9 Outfalls with Dry 60%Reduction 27.6 Outfalls with Dry
Flow Weather Flow Weather Flow
Sewer 58 c.f.u./100 ml in 5 c.f.u./100 ml in NA
Exfiltration Ground Water Ground Water
Table 36: Example Source Reduction Strategy for the Little Sugar Creek Watershed
Source Original Source Example Reduction Example Source
Category Distribution Scenario Distribution
WWTP No Daily Max Max 1000 c.f.u./100 NA
ml cone. In effluent
SSOs 93 SSOs; 443 hour 25%Reduction and 3 69 SSOs; 206 hour
duration hour duration duration
Wildlife 150 Geese NA 150 Geese
50 Ducks 50 Ducks
Septic 25.5 Failing Septic 60%Reduction 10.2 Failing Septic
S stems Systems Systems
Dry Weather 191.1 Outfalls with 60%Reduction 76.4 Outfalls with Dry
Flow Dry Weather Flow Weather Flow
Sewer 58 c.f.u./100 ml in 5 c.f.u./100 ml in NA
Exfiltration Ground Water Ground Water
page 45

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 37: Example Source Reduction Strategy for the McAlpine Creek Watershed Downstream of
Sardis Road
Source Original Source Example Reduction Example Source
Category Distribution Scenario Distribution
WWTP No Daily Max Max 1000 c.f.u./100 NA
ml conc. In effluent
SSOs 39 SSOs; 195 hour 25%Reduction and 3 31 SSOs; 93 hour
duration hour duration duration
Wildlife 160 Geese NA 160 Geese
90 Ducks 90 Ducks
10 Beavers 10 Beavers
Septic Sytems 34.5 Failing Septic 40%Reduction 20.7 Failing Septic
Systems Systems
Dry Weather 91.7 Outfalls with Dry 40%Reduction 55.02 Outfalls with
Flow Weather Flow Dry Weather Flow
Sewer 58 c.f.u./100 ml in 5 c.f.u./100 ml in NA
Exfiltration Ground Water Ground Water
Table 38: Example Source Reduction Strategy for the McAlpine Creek Watershed Upstream of
Sardis Road
Source Original Source Example Reduction Example Source
Category Distribution Scenario Distribution
WWTP No WWTP - -
SSOs 40 SSOs; 206 hour 33%Reduction and 3 21 SSOs; 39 hour
duration hour duration duration
Wildlife 40 Geese NA 40 Geese
10 Ducks 10 Ducks
Septic Sytems 2.5 Failing Septic 80%Reduction 0.5 Failing Septic
Systems Systems
Dry Weather 64.9 Outfalls with Dry 80%Reduction in 11.9 Outfalls with Dry
Flow Weather Flow Sub-watershed 001 & Weather Flow
002; 85%in 009
Sewer 58 c.f.u./100 ml in 5 c.f.u./100 ml in NA
Exfiltration Ground Water Ground Water
The data included in Tables 34, 35, 36, 37 and 38 is presented graphically in Figure 26.
Table 39 presents a matrix of reduction strategies that were evaluate prior to arrival at the strategy
discussed above.
page 46

Figure 26- Example Source Reduction Strategies for the TMDL Watersheds
Source Ori¢aum�aa11 Source Reduction Scenario Example Source Source Original Source Reduction Scenario Example Source
Category Disfn'bution Distribution Category Distribution Distribution
WWTP No daily max Max 1000 cfu/100mL in NA WWTP No daily max Max 1000 cfu/100mL in NA
effluent effluent
SSOs 86 SSOa.371 hour 33%Reduction and 3- 57 SSOs,165 hour SSOs 93 SSOs,443 hour 25%Reduction and 3- 69 SSOs,206 hour
duration hour duration duration duration hour duration duration
Wildlife 40 G—e NA 40 G—e Wildlife 150 Geese NA 150 Geese
20 Ducks 20 Ducks 50 Ducks 50 Ducks
Septic Systems 43.Failing Septic 60%Reduction 17.3 Failing Septic Septic Systems 25.5 Failing Septic System 60%Reduction 10.2 Failing Septic
SysDry Weather Flaw 105.4 Outfalls with Dry 60%Reduction 42.2 Outfalls with Dry Dry Weather 191.1 Outfalls with Dry 60%Reduction 76.4 Outfalls with Dry
Weather Flow Weather Flow Flow Weather Flow Weather Flow
Sewer 58 cfu/100mL in Ground 5 cfW100mL in Ground NA Sewer 58 cfu/100mL in Ground 5 cfu/I OOmI•in Ground NA
Exfiltration Water Water Exfiltration Water Water
Source Original Source Reduction Scenario Ex—ple Source
Category Distribution Distribution
WWTP No WWTP
SSOs 40 SSOs,206 hour 33%Reduction and 3- 21 SSOs,39 hour �
duration hour duration duration .
Wildlife 40 Geese NA 40 Gme
10 Ducks 10 Ducks
Septic Systems 2.5 Failing Septic System 80%Reduction 0.5 Failing Septic
Systems
Dry Weather Flow 69.4 Outfalls with Dry 80%Reduction 11.9 Outfalls with Dry
Weather Flow Weather Flow
Sewer Exfiltmtion 58 cfu/100n L in Ground 5 cfu/1001 in NA
Water Ground Water
ti
N
Source Original Source Redaction Scenario Exarnple Source
Category Distribution Distribution Q
WWTP No daily max Max 1000 cfu/100mL in NA n effluent
SSOs 39 SSOs,195 hour duration 25%Reduction and 3- 31 SSOs,93 hour (0
hour duration duration
Wildlife 160 Geese NA 160 Geese
Siuuce ❑riginal Sinirre Fmngdn Redur r:m Fsanilde Smirre 90 Ducks 90 Ducks
Category ➢istribufi- Scenario ➢istiibutimr 10 Beavers 10 Beavers p
wWTP No D y Kla flaz:070 =.u.lOC N6 ^
ml emc..n effluent Septic Systems 34.5 Failing Septic System 40%Reduction 120.7 Failing Septic n
S SOs S,l tour S35o F.ed'acGon aai 3 >!Sk l::;B5 wur Systems Q
curall.. hour d'1r:1 on i—tiol
Wildlife •1 J 11— PIA Il G—e Dry Weather 91.7 Outfalls with Dry 40%Reduction 55.0 Outfalls with Dry
R ?0 Luis e0 Lwcks Flow Weather Flow Weather Flow
pG Septic Sytems 4'3 Fsiling Seritir 67?5 rced'.r cft 17.3 F�i:irg Sepia Sewer 58 cfu/100mL in Ground 5 cfu/l00mL in Ground NA
s"''e1e '''°"" Exfiltiatim Ovate Water y
.A Dry V6eathm 10`.4 i-h 67;s Cced'.r '. 42.2 utrtfalls with Dry
V Flom 1)-v'N-.i:in 7a•n• L4e,r.lir-Fliiw
Sxwxr 56a. "AUU.1 t.r.:.0)R ar NA 0 Little Sugar Creek Watershed b

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Table 39: Reduction Strategies Used during the Allocation Process
Strategy WWTP SSOs Wildlife Septic Dry Sewer
Weather Exfiltration
Flow
1 No Red. 50%, 3 No Red 90% 90% 58 c.fu/100 ml
hour Limit to 5 c.fu./100
ml
2 No Red 50%, 3 No Red 90% 90% 58 c.f.u/100 ml
hour Limit to 5 c.fu./100
ml
3 1000 50%, 3 No Red. 90% 90% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
4 1000 33%, 3 10% 60% 60% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
5 1000 33%, 3 20% 60% 60% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
6 1000 25%, 3 10% 60% 60% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
7 1000 25%, 3 No Red. 60% 60% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
8 1500 25%, 3 No Red. 40% 40% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
9 1000 33%, 3 No Red. 80% 80% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
10 1000 33%, 3 No Red. 60% 60% 58 c.f.u/100 ml
cfu/100ml hour Limit to 5 c.f.u./100
daily max ml
Note: All percentages are in reduction(90%indicates 90%reduction not 90%remaining);No Red.=No Reduction
4.4 Seasonal Variation
Seasonal variation is accounted for in the dynamic water quality model by simulations covering a full
calendar year.
4.5 Margin of Safety
The MOS is a required component of TMDL development. There are two basic methods for
incorporating the MOS: 1)implicitly incorporate the MOS using conservative model assumptions to
develop allocations, or 2) explicitly specify a portion of the total TMDL as the MOS and use the
remainder for allocations. For Sugar Creek, Little Sugar Creek and McAlpine Creek Fecal Coliform
TMDLs, the MOS was both implicitly and explicitly incorporated into the modeling analysis by use
page 48

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
of conservative model assumptions and a water quality target of 180 c.f.u./100 MI. This was
accomplished by selection of conservative model input parameters and incorporation of the critical
period based on the results of a full year simulation. Similarly, the explicit margin of safety was
included in an attempt to account for possible inaccuracies in the source assessment.
page 49

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
5 RECOMMENDATIONS
Implementation of the TMDL can be accomplished cooperatively by the Mecklenburg County
Department of Environmental Protection, Charlotte Mecklenburg Utilities and Charlotte Mecklenburg
Storm Water Services. Local coordination, oversight and reporting for the TMDL should be the
responsibility of the Mecklenburg County Department of Environmental Protection. Each of the three
programs have currently funded efforts dedicated to reducing fecal coliform levels in Charlotte's streams
and these efforts can be augmented to fulfill the requirements of the TMDL Implementation Strategy.
page 50

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
6 PUBLIC PARTICIPATION
The TMDL for Little Sugar, Sugar and McAlpine Creeks was developed from an interactive
stakeholder process involving a group of thirteen(13) individuals representing diverse community
interests from the following organizations:
Mecklenburg County Department of Environmental Protection-2 representatives
Charlotte Mecklenburg Utilities - 1 representative
Charlotte Mecklenburg Storm Water Services -2 representatives
Sierra Club- 1 representative
Catawba River Keeper- 1 representative
N.C. Department of Environment and Natural Resources - 1 representative
S.C. Department of Health and Environmental Control- 1 representative
University of North Carolina at Charlotte- 1 representative
Building Development Commission- 1 representative
Community Resident- 2 representatives
The Mecklenburg County Department of Environmental Protection led the stakeholder process and
worked to provide stakeholders with the facts and information necessary to make informed decisions and
to ensure that ample opportunities were available for stakeholder input and involvement throughout the
process. The stakeholder group met on seven(7) different occasions between December 2, 1999 and
April 3, 2001. Stakeholder involvement included input into the development of the source assessment
strategy, model selection and field data collection methodology. The stakeholders were also given the
opportunity to review and comment on two(2) separate drafts of the TMDL document. Each comment
was carefully considered by staff of the Mecklenburg County Department of Environmental Protection
and the TMDL was revised accordingly. As a result of this process, the stakeholder group has indicated a
high degree of confidence that the TMDL will achieve the desired result of meeting North Carolina's
fecal coliform standard for class C waters.
The draft TMDL was publicly noticed on April 30, 2001. Public notice was achieved by posting the
TMDL to the DWQ web site, sending a notice to multiple electronic mailing lists, and mailing hardcopies
of the notice to interested citizens. Interested citizens were identified using the Planning Branch Catawba
River Basin mailing list for Mecklenburg County and the City of Charlotte. A public comment period
was through May 31, 2001. Written comments were not received from the public as a result of this
review. A copy of the notice is included in Appendix 9.
It is the intent of the Mecklenburg County Department of Environmental Protection to conduct the TMDL
implementation phase using continued community involvement and stakeholder input. The stakeholder
group will continue to meet to finalize the Implementation Strategy for the TMDL. Community
involvement in this process will be expanded by conducting public education and input sessions.
Following the completion of the Implementation Strategy, stakeholder involvement will continue to
provide oversight throughout the implementation phase of the TMDL.
page 51

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
References
Bales, Jerad D., J. Curtis Weaver and Jerald B. Robinson, 1999, Relation of Land Use to Streamflow
and Water Quality at Selected Sites in the City of Charlotte and Mecklenburg County,North
Carolina, 1993-98. U.S. Geological Survey Water-Resources Investigations Report 99-4180,
Raleigh,North Carolina.
Center for Watershed Protection, 1999, Concentrations, Sources, and Pathways in Microbes and
Urban Watersheds. Watershed Protection Techniques, v. 3,n. 1,p. 554-565.
Daniel, Sylvia, 2001, Personal Communication, Mecklenburg County Health Department, January 31,
2001.
Gallaher, Bert, 2001, Personal Communication, Charlotte Mecklenburg Utilities, February 6, 2001.
Horsley&Whitten. 1996. Identification and Evaluation of Nutrient and Bacteriological Loadings to
Maquoit Bay, Brunswick, and Freeport, Maine. Final Report. Casco Bay Estuary Project,
Portland, ME.
Lumb, A.M., McCammon,R.B., and Kittle, J.L., Jr., 1994,Users manual for an expert system
(HSPEXP) for calibration of the Hydrologic Simulation Program--Fortran: U.S. Geological
Survey Water-Resources Investigations Report 94-4168, 102 p.
Mecklenburg County Department of Environmental Protection, 1998, Completion of Follow-Up Field
Screening Activities. Mecklenburg County,North Carolina.
Mecklenburg County Department of Environmental Protection, 2000(a), Well Installation
Report. Mecklenburg County, North Carolina.
Mecklenburg County Department of Environmental Protection, 2000(b), Protocol for theSampling of
Ground Water Monitoring Wells for the presence of Fecal Coliform Bacteria. Mecklenburg
County,North Carolina.
North Carolina Department of Environment and Natural Resources, Division of Water Quality, 2000,
2000 303(d)List(Final Draft),North Carolina Department of Environment and Natural
Resources, Division of Water Quality, Raleigh,North Carolina.
Ogden Environmental& Engineering Services, 1991,National Pollutant Discharge Elimination
System, Storm Water Discharge Permit Application: Part 1. Prepared for the City of
Charlotte,North Carolina. Charlotte,North Carolina.
Ogden Environmental& Engineering Services, 1992,National Pollutant Discharge Elimination
System, Storm Water Discharge Permit Application: Part 2. Prepared for the City of
Charlotte,North Carolina. Charlotte,North Carolina.
Seriff, Don, 2001, Personal Communication, Mecklenburg County Park and Recreation Department,
January 23, 2001.
Sarver, K.M.,W.F. Hazell and J.B. Robinson, 1999, Precipitation, Atmospheric Deposition,
Streamflow, and Water Quality Data from Selected Sites in the City of Charlotte and
page 52

Irwin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
Mecklenburg County,North Carolina, 1997-98. U.S. Geological Survey Open File Report
99-273, Raleigh,North Carolina.
Shoemaker, L., 1997, Compendium of Tools for Watershed Assessment and TMDL Development.
EPA 841-B-97-006. U.S. Environmental Protection Agency, Watershed Branch, Assessment
and Watershed Protection Division, Office of Wetlands, Oceans, and Watersheds,
Washington, D.C.
Tennessee Department of Environment and Conservation, Division of Water Pollution Control,
Watershed Management Section, 2000, Total Maximum Daily Load for Fecal Coliform in
Sinking Creek, Watauga River Watershed, Tennessee(HUC 06010103). Nashville,
Tennessee.
Tetra Tech, Inc., 2001, Fecal Tool User's Guide. Draft report submitted to USEPA. Fairfax,
Virginia.
US Environmental Protection Agency(EPA), 1991, Guidance for Water Quality-based Decisions:
The TMDL Process. EPA 440/4-9 1-00 1. U.S. Environmental Protection Agency, Office of
Water, Washington, D.C.
US Environmental Protection Agency, Federal Advisory Committee(FACA), 1998, Draft final
TMDL Federal Advisory Committee Report. 4/28/98
US Environmental Protection Agency, 2000, Revisions to the Water Quality Planning and
Management Regulation and Revisions to the National Pollutant Discharge Elimination
System Program in Support of Revisions to the Water Quality Planning and management
Regulation; Final Rule. Fed. Reg. 65:43586-43670 (July 13, 2000).
page 53

Twin,McAlpine,Little Sugar, and Sugar Creeks Fecal Coliform TMDL
),age 54

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Chief Executive Officer Chairman of the Board President
Roddey Dowd , Jr W. Frank Dowd , IV E Hooper Hardison , Jr
PO Box 35430 PO Box 35430 PO Box 35430
Charlotte NC 28235 Charlotte NC 28235-5430 Charlotte NC 28235-5430
Chief Financial Officer
Lois Hart Warren
P.O. Box 35430
Charlotte NC 28235
Stock
Class: COMMON
Shares: 5001000
Par Value 1
Class: PREFERRED
Shares: 50000000
Par Value 1
https://www.sosnc.gov/onIine_services/search/Business_Registration_ResuIts 2/2

Young, Brianna A
From: Young, Brianna A
Sent: Wednesday,August 2, 2023 1:30 PM
To: [e-mail]
Cc: [e-mail]; Pappalardo, Jenny L.; [e-mail]
Subject: Charlotte Pipe & Foundary Co. stormwater permit NCS000040
Good afternoon,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your renewal application for coverage under NPDES Permit Number NCS000040.
Please continue to comply with all conditions and monitoring requirements in your current NPDES stormwater
permit. As long as you have submitted a complete renewal request package and maintain compliance with those
permit conditions, stormwater discharges from this facility are authorized by that permit until the Division
issues a renewal permit or notifies you of an alternative action. Please note that due to the current backlog and
staff shortages, review of this permit renewal is not scheduled until 2024,however this schedule is subject to
change. Please let me know if you have any questions in the interim.
Thank you,
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different but email performance will not be impacted.
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
1

CHARL40TTE
PIPE and FOUNDRY COMPANY
P.O. Box 35430 • Telephone [phone]
CHARLOTTE, NORTH CAROLINA 28235
July 27, 2023
Brianna Young
1612 Mail Service Center 1�11 1 4 tit
Raleigh, NC 27699-1612 �1
RE: Individual Stormwater Permit Renewal Application
Charlotte Pipe & Foundry Company
Permit Number NCS000040
Dear Ms. Young,
Please find included with this cover letter the Individual Stormwater Permit
renewal application for Charlotte Pipe and Foundry located in Charlotte, NC.
The following is included and has been sent to your attention via email:
• Completed NC DEQ Certification Form,
• Completed EPA Form 1 with attachments,
• Completed EPA Form 2f with attachments, and
• Completed NC DEQ Supplemental Information Form with
attachments.
Please contact Jenny Pappalardo at [phone] or David Waggoner at
[phone] if you have any questions or need any additional information.
Sincerely,
Jenny L. Pappalardo
Charlotte Pipe and Foundry Co.
Environmental Department

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources-- Stormwater Program
La, � L-
Facility Name: Charlotte Pipe&Foundry Company _
Permit Number: NCSooas40
l o
Location Address: 1335 South Clafton Street 17, G'5
Charlotte,NC 28208
County: MgckEenhurg ""^� �.j]
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all
attachments were developed and implemented under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gather and evaluate the information required by the SPPP.
Based on my inquiry of the person or persons who manage the system, or those persons directly responsible
for gathering the information, the information gathered is, to the best of my knowledge and belief, true,
accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP
has been fully implemented at this facility location in accordance with the terms and conditions of the
stormwater discharge permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification, DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature A-w Date 4-3
Mike Hall VP of Cast iron Operations
Print or type name of person signing above Title
SPPP Certification 10113

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040.0004
Form U.S.Environmental Protection Agency
1 \—.EPA Application for NPDES Permit to Discharge Wastewater
NPDES GENERAL INFORMATION
SECTIONPD r
1.1 Applicants Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
1.1.1 treatment works? 1.1.2 treating domestic sewage?
If yes,STOP.Do NOT complete 0 No If yes,STOP.Do NOT 0 No
Form 1.Complete Form 2A. complete Form 1-Complete
Form 2S.
1.2 Applicants Required to Submit Form 1
1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing,
E operation or a concentrated aquatic animal commercial,mining,or silvicultural facility that is
a- production facility? currently discharging process wastewater?
o ❑ Yes 4 Complete Form 1 ® No Yes 4 Complete Form No
a and Form 2B. 1 and Form 2C.
z
1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
mining,or silvicultural facility that has not yet commercial,mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
Cr ❑ Yes 4 Complete Form 1 0 No Yes 4 Complete Form No
and Form 2D. 1 and Form 2E.
N
61 1.2.5 Is the facility a new or existing facility whose
discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
® Yes 4 Complete Form 1 [] No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
b 15).
SECTIONDD• 1
2,1 Facility Name
Charlotte Pipe&Foundry Company
0 2.2 EPA Identification Number
U
0 110000349267
2.3 Facility Contact
Name(first and last) Title Phone number
David Waggoner Technical Director [phone]
Q
Email address
:R [e-mail]
2.4 Facility Mailing Address
cc E Street or P.O.box
z
1335 South Clarkson Street
City or town State ZIP code
Charlotte INC 2=8
EPA Form 3510-1(revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040-0004
2.5 Facility Location
2 Street,route number,or other specific identifier
a 1335 South Clarkson Street
o County name County code(if known)
Mecklenburg
City or town State ZIP code
z Charlotte NC 28208
SECTION1 NAICS CODES1
3.1 SIC Code(s) Description(optional)
3321 Gray Iron Foundries
a�
0
U
y
U
3.2 NAICS Code(s) Description(optional)
ego 331511 Iron Foundries
U
332996 Fabricated Pipe and Pipe Fitting Manufacturing
4.1 Name of Operator
Charlotte Pipe&Foundry Company
0 4.2 Is the name you listed in Item 4.1 also the owner?
0
® Yes ❑ No
L 4.3 Operator Status
0
2 ❑ Public—federal ❑ Public—state ❑ Other public(specify)
Q ® Private El (specify)
4.4 Phone Number of Operator
[phone]
4.5 Operator Address
Street or P.O.Box
E 1335 South Clarkson Street
c City or town State ZIP code
o a Charlotte NC 28208
i4 U
CL Email address of operator
O [e-mail]
SECTION1 1 I
0 -0 5.1 Is the facility located on Indian Land?
❑ Yes ® No
EPA Form 3510-1(revised 3-191 Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 031D5119
110000349267 NC5000040
Charlotte Pipe&Foundry OMB No.2040-0004
ENVIRONMENTALSECTION 6.EXISTING I CFR 122.21(ffl6))
6.1 Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
❑✓ NPDES(discharges to surface 10 RCRA(hazardous wastes) ❑ UIC(underground injection of
o water) fluids)
NCS000040 28208CHRLT13355
ry ® PSD(air emissions) ❑ Nonattainment program(CAA) NESHAPs(CAA)
NGMECO626 NCMECO626
❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify)
LU
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
C specific requirements.)
® Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
SECTION1
8.1 Describe the nature of your business.
Gray iron foundry manufacturing soil pipe and fittings.
N
N
d
C
.y
7
ca
O
3
Z
SECTIONOO 1
9.1 Does your facility use cooling water?
0 Yes ❑ No -+ SKIP to Item 10.1.
a 9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
:: 2 40 CFR 125,Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your
"' NPDES permitting authority to determine what specific information needs to be submitted and when.)
a Cooling water does not consist of stormwater nor is cooling water discharged to surface waters.
c
I VA RIANCE REQUESTSI I
10.1 Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
N apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
C ❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(n)) 302(b)(2))
❑ Nan-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
M Section 301(c)and(g))
0 Not applicable
EPA Form 3510-1(revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105/19
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040-0004
SECTION 11.CHECKLIST 1 1
11.1 In Column 1 below,mark the sections of Form 1 that you have completed and are submitting with your application.
For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note
that not all applicants are required to provide attachments.
Column 1 Column 2
® Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
® Section 2:Name,Mailing Address,and Location ❑ wl attachments
® Section 3:SIC Codes ❑ wl attachments
® Section 4:Operator Information ❑ wl attachments
® Section 5:Indian Land ❑ wl attachments
® Section 6: Existing Environmental Permits ❑ wl attachments
w
E wl topographic
® Section 7:Map ® map 0 wl additional attachments
U)
a ® Section 8:Nature of Business ❑ wl attachments
0 Section 9:Cooling Water Intake Structures ❑ wl attachments
d
U ® Section 10:Variance Requests ❑ wl attachments
a
c
y ® Section 11:Checklist and Certification Statement ❑ wl attachments
a 11.2 Certification Statement
s
U
t certify under penalty of taw that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted.Based on my inquiry of the person or persons who manage the system,or those persons
directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
belief, true, accurate,and complete, 1 am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Mike Hall VP of Cast Iron Operations
Signature Date signed
f . P T 3
EPA Form 3510-1(revised 3-19) Page 4

r � 5�f•, .r S r t[a e.f..� l i
•� _ '+ _ _ 1 7 nn�r,f��
b: .�. flr.x•1
- J .� 4.4 ` (5
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40
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e,. L �: {EL-: • ..±..,,gam } a�- t.�r +' -i ~l .,�., ..1^ :� jF
bum
41
�' sal v 'a i• tJ '
Irwin;Creek .� "
pohne
pd; Or,
114
l• �, J.
y ���'�y �„ t�+�iE= P � ���,,\x � ���! � �y{�_�Y•»r.y�E' 'j }. +,...� 4 �
_� � v t- rfrj� a. � � �f���� w r.}, f e'er;, K�,�'4 e � -�•� i'
i' '�� •`fir r + ;.kt: > r�. T ' Rom.. �"'• .'.jy}1
- 1 rr- } 4;..f ''4' ,� � r �.... `•�' - -__r.tarn HP j` J '. � �_�. "`tom f ��-; 11'^- ' 'Z, ',.�.•.,.t 1 ,:'�k , , � �a,,v yak =1,:.
4' OUTFALL LAT LONG
A 35.223811 N -80.864227 W ��x`� , ,' :;
B 35.223895 N -30.862312 W i
C 35.224070 N -80.860025 W
.. ! - ..- `.�. i•r'��. f� .... �� `.3}zr-+' 1�FE � :. �2 3 -�' ..e � rho - •_e���'i..)ti�..
N
0 0.2 0.4 0.6 0.8 1 and
OURCE: CHARLOTTE WEST, NC 7.5 MINUTE TOPOGRAPHIC QUADRANGLE, 1991
CHARUOTTE SITE LOCATION MAP Figure
PIPE and FOUNDRY COMPANY 1335 SOUTH CLARKSON STREET
CHARLOTTE,NORTH CAROLINA

ortwwir.c NUMeert
34-�2
IPTR
1. RB101EDWAOFARFA'AORTIE OTNA SIX 0` RON OIRTC7NAIOFSi0R11W119t RAW
2 RBA0IED SIX OFARHMONTIEOTIER SIX OF10000 +•s. cranam serene 40'
1 OTWIO®wWESdIORAAT S - L0GAT0iOFS7=MTERWrFA115
4. EIRIMAREAIATMLOT . ."
S. ADOEOWTFALLW
t ADDEDODIFALLI)MALDOXIMTEM1101I n r- ;
7. AOO WIFAILOGS L-_- T OUTFALL LATITUDE—LONGITUDE
t AOOB)000'AILVA F •' _
-� OLD001 35'13'28"N 8T51'50V
OLD002 351329'N 80'5114699
M OLD002A 35'1737'N 80'51'47V
a OLD ON 35'1127"N 80'51mv
OLD065 35'13'2rN •80'5141V
3 T e OLD 005A 35'112r'N V5140V
OLD006A 35'13'33'N 80'51'45W
�.� -
a _ A 35223811N •80.664271W
B 35123895N 80.862312IN
„' �.'-- �. \ • 1 ��r ___ C 35224070N •80.860025W F
`"`a'Y.-- •v— �' ' ' 3 � �' AREA PERCENT
(ACRES) NPERNOUS
AREA I 9.19 50%
t _ , W -, AREA II 290 95%
- t , w- -_ • _ II ,¢ (i AREA III 3.33 85%
AREAN 10.23 95%
AREAV 128 95%
4b AREAVI 8.14 85%
`d•`,d AREANI 1250 95%
;
v
OUTFALL POTENTIAL POLLUTANTS F
t T _..e_.��=�•t METHS,CiEMiCA1RESID1E5,gLtGRFASE
y1 _ a t"•— pLDaQ METALS,CHEMICAL RESMS,OIL&GREASE
OLD ONA METALS,CHEMICAL RESIDUES,OIL dGREASE _
OLD004 METALS,CUM RESIOLES,OIL&GREASE
-a Q METALS CHEMICAL RESIDUES,OIL&GREASE
,�; - n �` / e. n•L ` �� �� q a W>� d``w OLD 005 METALS:MICALRESIDUES,OIL&GREASE
-"°°F �,oe , ' , �d \ ••'.,�. ,. — m • 24�• OLDOOSA METALS,CtEMICLLRESIDLES,OIL&GREASE
—
T- OLD 006 E
METALS,CR01M'ALRESIDIIES,OIL 9GREASE
;A r t - \! "I.. �--•- y OLD 006A PROPOSED METALS,CWWCALRESMILES,OL&GREASE
8 .$ - •� '"• .� t �• ALL A METALS,CHEWCALREWLES,OIL&GREASE
i ! \
� B METALS,CIEWCAI.PESAl1.ES,CldGREASE
METALS,CIEMICALRESIDUES,OLIGREASE
OLD
� .0
1 S `\ "•. i `T 8g» S1O0�L \DeSSwool
1} •t' OLD
W006(Nwoos 8
SA r e t
SCALE
f. n A 0' too* 200'
OLD OUTFACE
_Sw002A
1
2
I \
i WI6 Revised is Noted
e. RE,
DATE DESCRUMON
LIMITS UNLESS OTHERWISE SPECIFIED
FRACTIONS} 1/64 DEC.FRACTIONS} .01 ANGLES}30'
DECIMALS}.005 SURFACE nNISH 125 R.M.S.
e CHARLOTTE PIPE AND FOUNDRY CO.
1335 SOUTH CLARKSON STREET
CHARLOTTE, NORTH CAROUNA I CAST IRON F
TITLE Environmental SILEve
SCALE DR BY DID o wirtc.uueErt
DATE 4-29-2015 CK V �34"I2

EPA Identification Number NPDES Permit Number Facility Name Farm Approved 03105119
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.20404004
Form U.S Environmental Protection Agency
2F EPA Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
SECTION 1.OUTFALL LOCATIONi
1.1 Provide information on each of the facili 's ouffalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
A Irwin Creek 35' 13' 25.72" N 80, 51, 51.22" W
C
O
;a B Irwin Creek 35' 13' 26.02" N 80' 51' 44.36" W
U
O
C Irwin Creek 35° 13' 26.65" N 80' 51' 36.09" W
O
SECTI
ti r ,
2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing,
upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes 0 No 4 SKIP to Section 3.
22 Briefly identify each applicable project in the table befiow.
Brief Identification and Affected Outfalls Final Compliance Dates
Description of Project (list outfall numbers) Source(s)of Discharge
Required Projected
lu
m
E
a
a
0
n.
E
2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects
that may affect your discharges)that you now have underway or planned?(Optional Item)
❑ Yes 0 No
EPA Form 3510.2F(Revised 3-19) Pagel

EPA identification Number NPDES Permit Number Facility Name Form Approved 03105119
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040-0004
SECTION 3.SITE 1' i
C 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
CD W S specific guidance)
© ® Yes ❑ No
SECTION 4. •• i
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall Impervious Surface Area Total Surface Area Drained
Number (within a mile radius of the facility) (within a mile radius of the facility)
specify units specify units
A 9•72 acres 10.23 acres
specify units specify units
B 4.7 acres 8.14 acres
specify units specify units
C 11.9 acres 12.5 acres
specify units specify units
specify units specify units
specify units specify units
4.2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content
requirements.)
y See Attached Section 4.2
m
L
Q
rn
Id
Q
4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. See instructions fors ecifcguidance.)
Stormwater Treatment
Codes
Outfall from
Number Control Measures and Treatment Exhibit
2F-1
(list)
A-C Roof drains,sheet now on impervious surfaces and underground transport 4A
A-C Drain filter inserts to capture solids around main processing areas 1Q
EPA Form 3510-2F(Revised 3-19) Page 2

Form 2F,Section 4.2
Stormwater drainage at the facility is from roof areas,asphalt parking areas,gravel paved areas,loading/
unloading areas,material storage areas,and grass areas. Stormwater flows into storm drains located throughout
the paved and landscaped areas of the property. Stormwater run-off flows overland and/or through underground
storm sewers to the west towards Irwin Creek. The following storage areas are located outside:
• One 15,000-gallon hot dip storage tank is located on an asphalt-paved surface south of the main
building. The tank is provided with secondary containment in the form of an open-top containment area
concrete sump. The sump is approximately 23.2 feet by 17.4 feet by 5 feet,which equates to an
approximate storage capacity of 2,018ft3,or approximately 15,097 gallons. Spilled material collected
within the containment area is removed and disposed of in accordance with applicable regulations.
• One 50-ton sand silo is located west of the main production building. In addition,one feldspar silo is
located south of the waste treatment building. The silo is not equipped with secondary
containment. However,since the contents are not liquid,spilled material will be easily cleaned up and
should not impact stormwater.
• One 550-gallon used oil storage tank is located on an asphalt-paved surface south of the Oil House. The
tank is provided with secondary containment in the form of metal walls. The containment area is
approximately 4 feet X 6 feet X 2 feet,which equates to an approximate storage capacity of 48 ft3, or
approximately 359 gallons. Spilled material collected within the containment area is removed and
disposed of in accordance with applicable regulations.
• One 10,000-gallon gasoline storage double walled tank and one 10,000-gallon diesel storage double
walled tank are located on an asphalt-paved surface near the northeast corner of the property. The tanks
are provided with secondary containment in the form of concrete walls. The containment area is
approximately 30 feet by 30 feet by 3 feet,which equates to an approximate storage capacity of 2,700 ft3,
or approximately 20,200 gallons. Spilled material collected within the containment area is removed and
disposed of in accordance with applicable regulations.
• One fueling station with four pumps is located on an asphalt-paved surface near the northeast corner of
the property. The fueling station is covered and equipped with an emergency shut off valve. The fueling
station is provided with secondary containment in the form of a trench drain. Spilled material collected
within the containment area is removed and disposed of in accordance with applicable regulations.
• Oil drums are stored under cover outside the Oil House. The area is not equipped secondary containment
or with a berm.
• Materials are stored in totes and drums in a covered shed located at the northeastern portion of the
facility. The entrance to the shed is equipped with an asphalt berm to minimize the potential impact of
spills on Stormwater.
• Materials are stored in totes and drums in a covered shed located at the southeastern portion of the
facility. This area is not equipped with a berm.
• Two totes of oil are stored on the ground without secondary containment in the shell core unloading
area.

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
110000349267 NCS000040 Charlotte Pipe&Foundry OMB No.2040-0004
SECTION 5.NON STORMWATER DISCHARGES I
5.1 1 certify under penalty of taw that the oulfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, t certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C,2D,or 2E application.
Name(print or type first and last name) Official title
Mike Hall VP of Cast Iron Operations
Signature Date signed
CD
O �� 7,,77,,9
rn 5.2 Provide the testing information requested in the table below.
Outtall Onsite Drainage Points
n Number Description of Testing[Method Used Date(s)of Testing Directly Observed
During Test
is
NA
0
SECTION 6.SIGNIFICANT LEAKS
in
0
z
OR SPILLS(40 1
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
'Ln Charlotte Pipe has not experienced any significant leaks or spills of toxic or hazardous pollutants in the last three years.
.a
0
Y
J
C
R
U
G1
SECTION 7,DISCHARGE INFORMATION1
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com lete.Not all applicants need to complete each table.
7.1 Is this a new source or new discharge?
o ❑ Yes 4 See instructions regarding submission of 0 No 4 See instructions regarding submission of
estimated data. actual data.
Q
C Tables A,B,C,and D
7.2 Have you completed Table A for each outfal[?
® Yes ❑ No
EPA Form 3510-21'(Revised 3-19) Page 3

EPA Identification Number NPOE5 Permit Number Facility Name Farm Approved 03105119
110000349267 NC5000040 Charlotte Pipe&Foundry OMB No.2040-0004
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
wastewater?
❑ Yes 0 No 4 SKIP to Item 7.5.
7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or
indirectly in an ELG andlor(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater?
❑ Yes 0 No
7-5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
0 Yes ❑ No 4 SKIP to item 7.7-
7-6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑ Yes 0 No
7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes 4SKIP to Item 7.18. 0 No
7.8 Do you know or have reason to believe any pollutants in Exhibit 2F-3 are present in the discharge?
0 Yes ❑ No 4 SKIP to Item 7.10.
7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
c Table C?
•C
0 Yes ❑ No
U
0 7.10 Do you expect any of the pollutants in Exhibit 2F-3 to be discharged in concentrations of 10 ppb or greater?
w
E 0 Yes ❑ No 4 SKIP to Item 7.12.
0
7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
En concentrations of 10 ppb or greater?
s ® Yes ❑ No
U
n
7.12 Do you expect acrolein,acrylonitdle,2,4-dinitrophenol,or 2-methyl-4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes l No 4 SKIP to Item 7.14.
7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
0 Yes ❑ No
7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)?
® Yes ❑ No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F4 are present in the discharge?
❑ Yes 0 No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
0 Yes ❑ No
7.17 Have you provided information for the storm event(s)sampled in Table D?
0 Yes ❑ No
EPA Farm 3510-2F(Revised 3-19) Page 4

EPA Identificafion Number NPDES Permit Number Facility Name Form Approved 03/05/19
110000349267 NC5000040 Charlotte Pipe&Foundry OMB No.2040-0004
o Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 2F-2 through 217-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
0
Yes ❑ No SKIP to Section 8.
0
0
E
7.19 List the pollutants below,including TCDD if applicable.
0
c 1.Oil&Grease 4.Zinc 7.
a�
rn
s 2.Coppef 5. &
U
Uf
3 Lead 6. 9.
SECTION ! !GICAL TOXICITY TESTING DATA r
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
0
c ❑ Yes 0 No 4 SKIP to Section 9.
.y
1 CU 8.2 Identify the tests and their purposes below.
21' Submitted to NPDES
ra Tesgs) Purpose of Tests) Permitting Authority?
Date Submitted
x
0
~ ❑ Yes ❑ No
M
o El Yes ❑ No
m0
❑ Yes ❑ No
SECTION ! INFORMATION
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
0 Yes ❑ No 4 SKIP to Section 10.
9.2 Provide information for each contract laboratory or consulting firm below.
Laboratory Number 1 Laboratory Number 2 Laboratory Number 3
Name of laboratoryffirm Pace Analytical Services Pace Analytical Services Pace Analytical Services
c Charlotte Asheville Peachtree Corners
b
0
w
C
Laboratory address 9800 KinceyAve.Ste 100, 222S Riverside Drive, 110 Technology Pkwy,
> Huntersville,NC 28078 Asheville,NC 28804 Peachtree Corners,GA
cc
30092
a
L
o Phone number
v [phone]
Polluiant(s)analyzed Total Petroleum Hydrocarbons Total Suspended Solids, Copper,Lead,Zinc
Chemical Oxygen Demand
EPA Form 3510-2F(Revised 3-19) Page 5

EPA Identification Number NPOES Permit Number Facility Name Form Approved 03105119
110000349267 NC5000040 Charlotte Pipe&Foundry Wil No.2040-0004
SECTION I CHECKLIST AND Y
10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to cam lete all sections or provide attachments.
Column 1 Column 2
0 Section 1 ❑ wl attachments(e.g.,responses for additional outfalls)
0 Section 2 ❑ w/attachments
0 Section 3 ❑ wl site drainage map
0 Section 4 ❑ wl attachments
0 Section 5 ❑ wl attachments
c
© Section 6 ❑ wl attachments
® Section 7 0 Table A ❑ wl small business exemption request
o ❑ Table B RI wl analytical results as an attachment
0 Table C 0 Table D
0 Section 8 ❑ wlattachments
y ® Section 9 ❑ wlattachments(e.g., responses for additional contact laboratories or firms)
❑✓ Section 10 ❑
c)
10.2 Certification Statement
I certify under penalty of taw that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person orpersons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of tine
and imprisonment for knowing violations.
Name(print or type first and last name) Official title
Mike Hall VP of Cast Iron Operations
Signature Date signed �J
EPA Form 3510-2F(Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03/05/19
110DO0349267 NCS000040 Charlotte Pipe&Foundry A OMB No.2040-0004
TABLE A. 4t
You must provide the results of at least one anall sis for every pollutant in this table.Complete one table for each outfall.See Instructions for additional details and recluirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new source/new
During First FlComposit ed During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in Instructions)
1. Oil and grease ND 2
2. Biochemical oxygen demand(BOD5) NA
3. Chemical oxygen demand(COD) 59 mg/L 11
4. Total suspended solids(TSS) 22 mg/L 11
5. Total phosphorus NA
6. Total Neldahl nitrogen(TKN) ND 2
7. Total nitrogen(as N) NA
pH(minimum) 5.2 11
8.
pH(maximum) 8.6 11
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Forth 3510-21'(Revised 3-19) Page 7

EPA Identification Number NPDES Permit Number Fadlily Name Cutfali Number Form Approved 03105/19
110000349267 NC5000040 Charlotte Pipe&Foundry B OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON CONVENTIONAL PARAMETERS(40 CFR 122.26(c)(1)(1)(E)(3)),
You must provide the results of at least one anal sis for every pollutant in this table.Com lete one table for each outfall.See instructions for additional details and re uirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Information
Number of Storm
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new sourcetnew
During First Flow-Weighted Sit ed During First Flow-Weighted Events Sampled dischargers only;use
30 Minutes ComposiEe 30 Minutes Composite codes in instructions)
1. Oil and grease 5.8 mg/L 2
2. Biochemical oxygen demand(BODs) NA
3. Chemical oxygen demand(COD) 158 mg/L 11
4. Total suspended solids(TSS) 126 mg/L 11
5. Total phosphorus NA
6. Total Kjeldahl nitrogen(TKN) ND 2
7. Total nitrogen (as N) NA
pH(minimum) 5.4 11
8.
pH(maximum) 8.8 11
' Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510.2F(Revised 3.19) Page 7

EPA Identification Number NPDES Permit Number Facility Name Wall Number Form Approved 030/19
110000349267 NC5000040 Charlotte Pipe&
P Foundry C-Prefilter OMB No.2040-M ,
TABLE A. CONVENTIONAL AND NON CONVENTIONAL PARAMETERS(40 CFR 122.26(c)(1)(i)(E)(3)),
You must provid2 the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and rMequirements.
Maximum Daily Discharge Average Daily Discharge Source of
(spedfyunits) (spedfyunits) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new source/new
During First Flow-Weighted ed During First Flow-Weighted Events Sampled dischargers only,use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease ND 13
2. Biochemical oxygen demand(BOD5) NA
3. Chemical oxygen demand(COD) 93 mg/L 13
4. Total suspended solids(TSS) 183 mg/L 13
5. Total phosphorus NA
6. Total Neldahl nitrogen(TKN) ND 2
7. Total nitrogen(as N) NA
pH(minimum) 5.2 13
8.
pH(maximum) 9.0 13
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21'(Revised 3-19) Page 7

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03A5119
110000349267 NCS000040 Charlotte Pipe&Foundry A.0 OMB No.2040-0004
List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed In the facility's NPDES permit for its process wastewater(if the
facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(sped units s e units Number of Storm Information
Pollutant and CAS Number(If available) Grab Sample Taken Grab Sample Taken (new sourcelnew
During First Flow-Weighted ed During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in Instructions)
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21'(Revised 3-19) Page 9

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Farm Approved 03105J19
110000349267 NCSO0004O Charlotte Pipe&Foundry A.0 OMB No.2040aU
TABLE C.TOXICPOLLUTANTS, A•/• SUBSTANCES, / 41 41
List each pollutant shown in Exhibits 2F-2,2F-3,and 2F4 that you know or have reason to believe is present.Complete one table for each outfall.See the instructions for additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(sped units (sped units Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken Grab Sample Taken (new sourceMew
During First Flo Composite
Flow-Weighted During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Compostte 30 Minutes Composite codes In Instructlons)
See Summary table of sampling analyses
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Forth 3510-217(Revised 3.19) Page 11

EPA Identification Number NPDES Permit Number Facility name Outfall Number Form Approved 030/19
110000349267 NCS000040 Charlotte Pipe&Foundry A-C OMB No.2040-0004
TABLE D. STORM EVENT INFORMATION(40 GFR 122.26(c)(1)(i)(E)(6))
Provide data for the storm event(s)that resulted in the maximum dally discharges for the flow-weighted composite sample.
Number of Hours Between
Total Rainfall During Maximum Flow Rate
Date of Storm Event Duration of Storm Event Storm Event Beginning of Storm Measured and During Rain Event Total Flow from Rain Event
(In hours) (in inches) End of Previous Measurable Rain (In gpm or specfy unHs) M gallons or specify units)
Event
06/19/2023
Unknown 1.0 Unknown Unknown 714,865
Provide a description of the method of flow measurement or estimate.
26.32 Acres*6.27264E+6 sq-in/acre*1 in rainfall*0.00432 gallon/cubic in=714,865 gallons
EPA Form 3510-21'(Revised 3.19) Page 13

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
A4 1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas,process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
1f4 2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled,and storm event data.
l4 3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned,please include
information on these BMP's.
5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
6. Certification of the development and implementation of a Stonmwater Pollution
Prevention Plan for the permitted facility(Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal,then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

Summary of Analytical Monitoring Results
SW Outfall A(sheet flow behind Shipping)
10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021 11/2021 05/2022 11/2022 05/2023
Bench- Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter Post Filter
Characteristic Mark units Monrhly Monrhly As Requested As Requested As Requesred SemiAnnll SemlAnnfl semi-Ann12 Semi-Anna 5emi-Ann12 Semi-Ann11
Oil&Grease 30.00 mg/L NO ND
Cr 1.00 mg/L ND NO
Cu 0.01 mg/L 0.009 0.005 0.010 0.006 0.012 0.008 0.027 0.01 ND ND ND
Ph 0.075 mg/L 0.01 NO 0.009 ND 0.010 0.008 0.037 ND ND NO NO
N1 0.335 mg/L ND ND
Zn 0.126 mg/L 0.138 0.076 0.048 0.110 0,147 0.093 0.408 0,102 0.130 0.056 0.108
TSS 100 mg/L 31 51.6 22.2 20.9 54.7 27.0 83.3 18 4.2 ND 22.0
PH 6-9 6.8 5.2 5.3 5.2 8.6 6.5 6.9 6.8 7.3 9.7 7.8
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 ND
COD 1 120 mg/L 39 N❑ ND 41.2 59.8 54.6 112 31 77 32 59
Total Rainfall in 1-8 1.24 1.0 1 1.8 1 0.5 1 4.3 1 0.5 1 0.2 1 0.3 1 0.5 1.0
SW Outfall B(sheet flow @ Ecoat)
10/2018 01/2019 06/2019 10/2019 03/2020 11/2020 03/2021 12/2021 0512022 11/2022 06/2023
Bench- Post Filter Post Filter Post Filter Post Filter Post-Filter Past-Filter Post-Filter Post-Filter Post-Filter Post-Filter
Characteristic Mark Units M-thly Monthly As Requesred MRequested As Requested semi,AnmU semfAnnll srmf-Annl2 semf-Annll semiAnn12 Semr-Annll
Oil&Grease 30.00 mg/L ND 5.8
Cr 1.00 mg/L ND 0.008
Cu 0.01 mg/L 0.009 0.012 0,006 0.93 0.02 0.03 0.02 0.02 0.03 ND 0.04
Ph 0.075 mg/L 0.01 0.014 0.010 0.124 0.027 0,037 0.043 0.030 0.063 ND 0.042
Ni 0.335 mg/L ND NO
Zn 0.126 mg/L 0.223 0.21 0.096 1.27 0.216 0.274 0.334 0.287 0.578 0.156 0.543
TSS 100 mg/L 31 125 24.6 1640 111 101 102 69 147 24 126
PH 6-9 7.6 5.4 5.4 6.2 8.8 8.7 7.2 7.4 7.9 8.0 9.5
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 ND
COD 120 mg/L 44 53.1 NO 183.0 87.7 86.2 159 ND ND 27 158
Total Rainfall I in 1.8 1.24 7.0 1 1.$ 1 0.5 1 4.3 1 0.5 1 0.2 1 0.3 1 O.5 l.D
SW Outfall C(prefilter sheet flow @ Oil House)
10/2019 01/2019 0612019 SO/2019 03/2020 11/2020 03/2021 11/2021 05/2022 06/2023
Bench- Post Filter Pre-Filter Post-Filter Pre-filter Post-Filter Pre-Filter Post-Filter Pre-Filter Pre-Filter Pre-Filter Pre-Filter Pre-Filter
Characteristic Mark Units Monthly Monthly MRequested MRequesred As Requrrrrd At Requesred As Requesred As Requested Srmi-An f2 semi-Ann11 Semi.Ann12 SrmMnnll Sem1-A-0
Oil&Grease 30.00 mg/L ND ND NO ND ND ND ND NO ND NO ND ND ND
Cr 1,00 mg/L 0 0.010
Cu 0.01 mg/L 0.023 0.016 ND 0.006 0.035 0.014 0.039 0,132 0.022 0.016 0,04 ND 0.033
Ph 0.075 mg/L 0.02 0.014 ND 0.005 0.040 0.010 0.035 0.114 0.027 0.014 0.140 NO 0.051
Ni 0.335 mg/L 0.01 0.006
Zn 0.126 mg/L 0.651 0.372 0.404 0.307 0.356 0.577 0.652 0.657 0,691 0.917 0.523 0.07 0.30
TSS 100 mg/L 179 88.3 15.9 27.0 138 14.0 317 836 162 92.7 220 88 183
PH 5-9 7.2 6.4 5.6 5.8 6.0 5.2 9.0 8.7 7.8 7.4 7.7 7.7 7.9
TKN 20-Jan mg/L ND ND
Phenols 4-Jan mg/L 0.0 0.38
COD 120 mg/L 156 80.9 ND 202 117 60.1 232 678 57.0 77.4 71 46 93
Total Rainfaill in 1 1.$ 1 1.24 1 1.0 1 1.8 1 0.5 1 4.3 1 0.5 1 0.2 1 0.5 1 1.0
Rainwater(collected in a Plastic Bucket)
Bench- 10/2018 01/2019 O6/2019 10/2019 03/2020 11/2020 03/2021
Characteristic Mark Units Monrhfy Monthly A,Requested As Requesred As Requested semi-Anna srmf Annll
PH 1 6-9 5.6 1 1 4.3 1 5.6 1 4.4 1 5.5

Summary of Visual Inspections
Floating Suspended
Precipitation Clarity Solids Solids Foam Oil Sheen Erosion
Date (in) Outfall Color Odor (1 to 5)* (1 to 5)"* (1 to 5)*** Present? Present? Present?
6/19/2023 1.0 A Lt Gray None 1 1 1 No No No
6/19/2023 1.0 B Lt Gray None 2 2 2 No No No
6/19/2023 1.0 C Med Gtay None 2 2 2 No No No
11/6/2022 0.5 A Lt Gray I None 1 1 1 No No I No
11/6/2022 0.5 B Lt Gray None 2 2 2 No No No
11/6/2022 0.5 C Med Gray None 2 2 2 No No No
5/21/2022 0.3 A Lt Gray None 1 1 1 No No No
5/21/2022 0.3 B Med Gray None 3 3 3 No No No
5/21/2022 0.3 C Dark Gray None 4 3 4 No No No
11/22/2021 0.2 A Lt Gray None 1 1 1 No No No
11/22/2021 0.2 B Med Gray None 2 2 2 No No No
11/22/2021 0.2 C Dark Gray None 4 3 4 No No No
5/31/2021 0.5 A Lt Gray None 2 1 1 No No No
3/31/2021 0.5 B Med Gray None 2 2 3 No No No
3/31/2021 0.5 C Dark Gray None 4 3 4 No Yes No
11/12/2020 4.3 A Lt Gray None 2 1 1 No No No
11/12/2020 4.3 B Med Gray None 3 3 3 No No No
11/12/2020 4.3 C Dark Gray None 4 3 4 No No No
3/23/7020 0.5 A Lt Gray None 2 1 1 No No No
3/23/2020 0.5 31 Med Gray None 2 2 3 No No No
3/23/2020 0.5 C2 Dark Gray None 4 3 4 No Yes No
10/22/2019 0.7 A Clear None 2 1 1 No No No
10/22/2019 0.7 131 Med Gray None 2 3 3 No No No
10/22/2019 0.7 e Med Gray None 2 3 3 No No No
6/12/2019 1.0 A Clear None 2 1 1 No No No
6/12/2019 1.0 BI Lt Gray None 2 1 1 No No No
6/12/2019 1.0 C2 Gray None 2 3 2 No No No
3/23/2020 0.5 B' Lt Gray None 2 2 2 No No No
6/12/2019 1.0 B3 Gray None 2. 2 2 No No No
10/22/2019 0.7 63 Gray None 2 2 3 No No No
"where 1 is clear and 5 is very cloudy
"*where 1 is no solids and 5 is the surface covered with floating solids
***where 1 is no solids and 5 is extremely muddy
Nate:
Originally recorded as Outfall C prior to approved removal of Old Outfall B in late 2020 when Outfall C became B
2 Originally retarded as Outfall D prior to approved removal of Old Outfall B in late 2020 when Outfall D became C
3 This Old Outfall B removed in Late 2020

BEST MANAGEMENT PRACTICES
Outfall
Impacted Location BMP Description Approved Date of Completion
OutfaI]A Foundry Areas draining to Sweeping outside areas of foundry Continuous Continuous
SWO `A'
Outfall A Foundry Areas draining to Implemented policy that as galvanized metal siding is 2013 2013
SWO W replaced,galvanized aluminum siding will be used
Outfall A Behind Pipe Storage Installed sock insert at storm culvert: Behind Pipe Storage Nov 2018 Dec 2018
(Swig)
Outfall A Product Storage Cover Product Storage Areas Not Feasible Not Feasible
Outfall B Foundry Areas draining to Sweeping outside areas of foundry Continuous Continuous
Outfall B
Outfall B Melt Sweep up dustings around the Cupola baghouse Continuous Continuous
Outfall B Melt Operation &Collection of Dust in Cupola Baghouse Continuous while in Continuous while in
Operation Operation
Outfall B Hot Dip #2 &#3 Hot Dip Collection Totes relocated to be within the 2008 2008
building
Outfall B Hot Dip Sump from Hot Dip Main Storage Tank piped to WWTP for 2008 2008
treatment
Outfall B Melt Sumps from Coke Unloading piped to WWTP for treatment 2009 2010
Outfall B Melt Sumps from Additives Handling piped to WWTP for 2010 2011
treatment
Outfall B Melt Sumps from Charging System and ground area around 2010 2011
charging area piped to WWTP for treatment
Outfall B Foundry Areas draining to Implemented policy that as galvanized metal siding is 2013 2013
Outfall B replaced, galvanized aluminum siding will be used
Outfall B E-Coat Process Started e-coating fittings; more rust-resistant therefore June 2013 June 2013
less rust present on stored fittings product
Page 1 of 4

BEST MANAGEMENT PRACTICES
Outfall
Impacted Location BMP Description Approved Date of Completion
Outfall B Melt Dust Supression -Water Spray on charging system to keep 2013 2014
metallics from drifting to areas where run-off will go to
stormwater
Outfall B Melt Dust Supression -Water Spray in scrap yard to keep Jan 2015 Mar 2015
metallics contained to that area where run-off will go to
WWTP for treatment
Outfall B Foundry Areas draining to Installed filter inserts into storm drains: Corner of Office Nov 2018 Dec 2018
Outfall B Bldg (SW1), Hot Dip Lean-To (SW2)
Outfall B Main Gate/E-coat Installed sock insert into storm culvert: Outside E-coat Nov 2018 Dec 2018
(SW18)
Outfall B Scrap Yard Cover Scrap Yard Not Feasible Not Feasible
Outfall B Product Storage Cover Product Storage Areas Not Feasible Not Feasible
Outfall B Other Foundry Areas Treat Stormwater Not Feasible Not Feasible
draining to Outfall B
Outfall C Foundry Areas draining to Sweeping outside areas of foundry Continuous Continuous
Outfall C
Outfall C Foundry Areas draining to Operation & Collection of Dust in Baghouses associated Continuous while in Continuous while in
OutfalI C with HWS, NPF and Rolocast areas Operation Operation
Outfall C NPF Sweep dustings around the HWS, NPF and Rolocast Continuous Continuous
baghouses sand handling collection bins
Outfall C Waste Area Installed building to cover Waste Aggregate Area 2009 Jul 2010
Outfall C NPF Dust Supression -Covered NPF & Rolocast baghouse dust 2012 2012
collection boxes
Page 2 of 4

BEST MANAGEMENT PRACTICES
Outfall
Impacted Location BMP Description Approved Date of Completion
Outfall C NPF Bust Supression -Covered HWS baghouse dust collection Feb 2018 Feb 2018
boxes
Outfall C Foundry Areas draining to Installed filter inserts into storm drains: Oil house (SW6), Nov 2018 Nov/Dec 2018
Outfall C NPF Bagouse (SW7), Sand Lab (SW8), 3 hill @ gas pumps
(SW9, SW10,SW11), HWS Baghouse (SW12),Top of Hill
(SW17)
Outfall C Core Storage Cover Core Storage Areas Not Feasible Not Feasible
Outfall C Hill Cover roll-off bins Not Feasible Not Feasible
Outfall C Foundry Areas draining to Treat Stormwater Not Feasible Not Feasible
Outfall C
Misc Areas Facility-Wide Sweeping outside areas of foundry Continuous Continuous
Misc Areas Facility-Wide Dust Supression - Covered facility-wide baghouse dust Continuous Continuous
collection boxes
Misc Areas Facility-Wide Sweep dustings around all baghouse collection bins Continuous Continuous
Misc Areas Facility-Wide Operation &Collection of Facility-Wide Baghouses Continuous while in Continuous while in
Operation Operation
Misc Areas Gun Drill Collect Compressor Condensate in a Tote that is carried to Continuous Continuous
WWTP for treatment
Misc Areas Facility-Wide Implemented policy that as galvanized metal siding is 2013 2013
replaced,galvanized aluminum siding will be used
Misc Areas WWTP Required the feldspar delivery truck to place catch pans Feb 2014 Mar 2014
under hopper bottoms to catch potential leaks
Misc Areas Rolocast Rolocast Office AC Condensate collected and taken to Sep 2014 Oct 2014
WWTP for treatment
Page 3 of 4

BEST MANAGEMENT PRACTICES
Outfall
Impacted Location BMP Description Approved Date of Completion
Misc Areas Rolocast Dust Supression - Replaced Silo Bin Vent with ductwork to Feb 2018 Aug 2018
vent through baghouse for better capture
Misc Areas Shell Core/NPF Installed filter inserts into storm drains: Kitchen Alley side Jun 2018 Jun 2018
(SW13, SW14, SW15), Alley @ Pattern Shop (SW16)
Misc Areas Rolocast Installed filter inserts into storm drains: Corner of Oct 2018 Oct 2018
Substation & Rolo Laempe (SW4), Corner of Substation &
Rolo Electr Rm (SW5)
Misc Areas WWTP Installed filter inserts into storm drain: Water Treatment Nov 2018 Nov 2018
(SW3)
MiscAreas Foundry Areas draining to Treat Stormwater Not Feasible Not Feasible
Misc Areas
Page 4 of 4

Summary of Significant Changes in Industrial Activity
Charlotte Pipe and Foundry has not experienced significant changes in Industrial Activity since
the last permit renewal.
The Charlotte Pipe and Foundry Charlotte location does plan to initiate shutdown of process
equipment during the later part of CY2023.