NCS000240_2017 Annual Report_20170901

City of Charlotte
NPDES MS4 Permit Program

Stormwater
Management Program Plan

FY2017 Annual Report

Permit Number NCS000240

September 2017

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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Table of Contents

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

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

Section 3 Public Education and Outreach Program ...............................................8

Section 4 Public Involvement and Participation Program ...................................21

Section 5 Illicit Discharge Detection and Elimination Program ..........................31

Section 6 Construction Site Stormwater Runoff Control Program.....................61

Section 7 Post-Construction Stormwater Management Program .......................67

Section 8 Pollution Prevention/Good Housekeeping Program.............................73

Section 9 Industrial Facilities Evaluation and Monitoring Program ..................90

Section 10 Water Quality Assessment and Monitoring Program ........................100

Section 11 Total Maximum Daily Load (TMDL) Program ..................................116

Acronyms Used In This Document:

BMP: Best Management Practice
CAR: Corrective Action Request
CATS: Charlotte Area Transit System
CDOT: Charlotte Department of Transportation
CFD: Charlotte Fire Department
CMANN: Continuous Monitoring Alert Notification Network
CMCSI: Charlotte-Mecklenburg Certified Site Inspector
CMPD: Charlotte-Mecklenburg Police Department
CMSWS: Charlotte-Mecklenburg Storm Water Services
DEMLR: Division of Energy, Mining, and Land Resources
DO: Dissolved Oxygen
DWF: Dry Weather Flow
DWQ: Division of Water Quality
EPM-SWS: Engineering and Property Management Dept.-Storm Water Services Division
ETJ: Extra Territorial Jurisdiction
FY: Fiscal Year
GIS: Geographic Information System
HDD: Horizontal Directional Drilling
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IDDE: Illicit Discharge Detection and Elimination
IDEP: Illicit Discharge Elimination Program
MEP: Maximum Extent Practicable
MS4: Municipal Separate Storm Sewer System
MST: Microbial Source Tracking
NCDEQ: North Carolina Department of Environmental Quality
NCGA: North Carolina General Assembly
NOV: Notice of Violation
NPDES: National Pollutant Discharge Elimination System
O&M: Operation & Maintenance
PCSO: Post-Construction Stormwater Ordinance
QA/QC: Quality Assurance/Quality Control Program
RSWP : Regional Stormwater Partnership
SAP: Standard Administrative Procedure
SARA: Superfund Amendments and Reauthorization Act
SCM: Stormwater Control Measure
SOP: Standard Operating Procedure
SSO: Sanitary Sewer Overflow
SWAC: Stormwater Advisory Committee
SWMP: Stormwater Management Program Plan
SPPP: Stormwater Pollution Prevention Plan
TMDL: Total Maximum Daily Load
TP: Total Phosphorus
TSS: Total Suspended Solids
UNCC: University of North Carolina at Charlotte
USEPA: United States Environmental Protection Agency
WLA: Waste Load Allocation
WQ: Water Quality
WQS: Water Quality Standards
WTP: Water Treatment Plant
WWTP: Wastewater Treatment Plant
City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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Section 1: Introduction

On November 1, 1993, the City of Charlotte “City” began operating under National Pollutant
Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit
Number NCS000240. This permit has subsequently been renewed for a five-year permit term on
three occasions and is currently in its 4th permit cycle effective March 1, 2013 through February
28, 2018.

This document provides the Annual Report for the Stormwater Management Program Plan
(SWMP) for FY2017 under the current permit term as required by Part III, paragraph 2 of the
NPDES MS4 permit. The overall objective of this Annual Report is to document activities
conducted in support of the SWMP during FY2017 (July 1, 2016 to June 30, 2017) and discuss
future proposed program activities and/or SWMP changes as necessary.

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

Included in this SWMP Annual Report are:

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

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

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

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

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

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

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

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

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

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

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

Section 2: Background Information

2.1 Population Served

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

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

Table 2-1: Population and Growth Rate for the City of Charlotte.
2016 Population
(est.)
2010 Population 2000 Population Average Annual Percent
Change (2000-2010)
842,051 731,424 540,828 3.5%

2.2 Growth Rate

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Table 2-1 shows the population growth rate represented as an “Average Annual Percent
Change” for the City. This growth rate was calculated by dividing the overall percent change
between the 2000 and 2010 Census by the 10-year interval.

2.3 Jurisdictional and MS4 Service Areas

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

Table 2-2: Jurisdictional and MS4 Service Area for the City of Charlotte.
Incorporated Area (Sq. Miles) ETJ (Sq. Miles) Total Jurisdiction (Sq. Miles)
307 69 376

2.4 MS4 Conveyance System

The existing MS4 serving the City is composed of curbs, gutters, catch basins, culverts, pipes,
ditches, and outfalls that collect and convey stormwater for discharge to receiving streams.
Currently, there are an estimated 6,238 outfalls, 3,546 miles of storm drain pipe and 163,751
catch basins and drop inlets within the City’s MS4. Pipe systems are typically 15 inches or
larger in diameter and are designed for the ten-year storm event. Outlet energy is commonly
dissipated through the use of end-walls or flared end sections with riprap aprons. Although the
natural alignment of many receiving streams has been altered over the past century, many of the
stream banks remain mostly vegetated as a result of the City’s stormwater management
philosophies. Stream banks that were armored with riprap as a result of previous stabilization
efforts are currently allowed to re-vegetate naturally, and new projects incorporate “soft”
methods involving tree plantings and other vegetation.

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

2.5 Land Use Composition Estimates

The number of square miles and percentage of the MS4 service area under residential,
commercial, industrial and open space land use categories are provided in Table 2-3. These
percentages include the incorporated area and ETJ for the City. Figure 2-2 provides a map of
these land use areas.

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

2.6 Estimate Methodology

Land use estimates are derived from Mecklenburg County land parcel geographic information
system (GIS) data (2015).

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FIGURE 2-1
Charlotte Jurisdictional Area and Watersheds

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FIGURE 2-2

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Section 3: Public Education and Outreach Program

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

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

3.1 BMP Summary Table

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

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

X X X X X Water Quality
Program
Manager
Describe target
audiences
Describe the target audiences likely to have
significant stormwater impacts and why they were
selected.
X X X X X Water Quality
Program
Manager
Informational Web
Site
The permittee shall promote and maintain an
internet web site designed to convey the program’s
message.
X X X X X Water Quality
Program
Manager
Distribute public
education materials
to identified user
groups.
Distribute general stormwater educational material to
appropriate target groups as likely to have a
significant stormwater impact. Instead of developing
its own materials, the permittee may rely on state-
supplied Public Education and Outreach materials, as
available, when implementing its own program.
X X X X X Water Quality
Program
Manager
Promote and
maintain
Hotline/Help line
Promote and maintain a stormwater hotline/helpline. X X X X X Water Quality
Program
Manager
Implement a Public
Education and
Outreach Program.
The permittee’s outreach program, including those
elements implemented locally or through a
cooperative agreement, shall include a combination
of approaches designed to reach the target
audiences. For each media, event or activity,
including those elements implemented locally or
through a cooperative agreement the permittee shall
estimate and record the extent of exposure.
X X X X X Water Quality
Program
Manager
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3.2 Target Pollutants and Sources

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

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

3.3 Target Audience

The target audiences for the public education program included those entities that could have
significant positive and/or negative impacts on water quality conditions. The audiences that
were selected are listed below along with an explanation as to why they were targeted for
educational outreach.

Homeowners (ages 25 - 55): This subgroup of the general public has been selected because, as
compared to younger or older generations, they have the greatest potential for affecting
stormwater quality. They represent about 55% of the City’s residents, are likely to care for a
home and property, and have the greatest potential for engaging in target activities such as yard
care, disposal practices, pet ownership, car maintenance, and pollution reporting.

Multi-Family Residential Apartment Complexes: This target audience has been selected because
the City’s sanitary sewer overflows (SSOs) are commonly caused by improper grease disposal at
multi-family residential communities.

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

3.4 Stormwater Public Education and Outreach Program

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

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

3.4.1 Mass Media

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

 Report Pollution;
 Volunteer; and
 Flood Safety.

Media channels utilized to promote events and messages consisted of television, radio, website,
and print advertisements. A total of 706 television ads and 94 radio ads ran and CMSWS also
worked with a local TV station to produce “Water Wise” segments that were shown on the local
news station. The segments covered topics such as “Stormwater Pollution,” “Reporting
Pollution,” and “Volunteering.”

Print media included use of:

 Vehicle wraps;
 A parking garage banner;
 Magazine ads;
 Newspaper ads; and
 Utility bill inserts.

3.4.2 Social Media

CMSWS continued efforts to build a social media presence this past year as more and more
people are receiving information through this media source. Four social media channels were
used:

 YouTube Account https://www.youtube.com/user/StormWaterServices
 Facebook Page https://www.facebook.com/waterwatchers
 Twitter Account https://www.twitter.com/WaterWatcherCLT
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 Instagram Account https://www.instagram.com/stormwatercm

CMSWS posted various videos and news stories on
the You Tube channel. CMSWS also provided
more content, pictures and videos related to
stormwater pollution, surface water quality,
pollution prevention and flood messages on
Facebook, Twitter and Instagram and boosted some
posts to reach tens of thousands of users. There are
5,978 Facebook followers, 406 Instagram
followers, 792 Twitter followers and 30 subscribers
to our YouTube page. Figure 3-1 shows a typical
Facebook post.

CMSWS provided the public with a mobile
application called “Water Watchers” to report
pollution. There were 141 downloads of the
application during FY2017, making for a total of
1,646 downloads since the application was
launched in FY2013. This past year, there were 64
reports of pollution using the application. The
application allows users to provide pictures of their
concern and this has proven very helpful to staff for
providing follow-up services.

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

 Giving away promotional products such as magnets and
water bottles with 311 and Water Watcher information;
 Providing information about reporting pollution on a
website;
 Working with local TV stations to produce news
segments focused on reporting pollution;
 Buying media time and airing a TV ad focused on
reporting pollution;
 Designing and mailing the October utility bill insert,
focused on volunteering and reporting pollution, to
approximately 255,000 residents; and
 Hanging a six-story banner on a parking garage across
from a popular exit ramp off I-277 (Figure 3-2).

Figure 3-2: Typical Parking
Garage Banner
Figure 3-1: Typical Facebook Post.
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3.4.3 Public Hotline

The City, in cooperation with Mecklenburg County, continued to operate a joint customer
service hotline that helps direct citizens to appropriate resources for their questions and concerns
including reporting of pollution. Citizens were able to dial 311 any time of the day (24/7/365) to
report a variety of stormwater issues such as pollution, flooding, and blockages to the drainage
system.

During this past fiscal year, a total of 7,509 calls were received by 311 and referred to CMSWS.
Out of this total number, 507 resulted in service requests related to water quality issues within
the City. Of the calls received, the highest number came from citizens.

Calls from citizens as a group made up 46% of all calls, which was 26% higher than from any
other audience. This is important information for targeting education campaigns related to
pollution reporting. Table 3-3 provides information about the number and type of callers that
reported these issues.

Table 3-3: FY2017 Service Request Source Summary
Caller Type Number of Service Requests*
Citizen 233
Charlotte Fire Department 40
Charlotte Water 41
Charlotte Storm Water Services 51
Charlotte-Mecklenburg Police Dept. 1
City Departments (other, not specified) 103
State – Division of Water Resources 9
Environmental Protection Agency 5
Business 7
Towns 0
Other 17
TOTAL 507
* Source summary data includes all types of service requests within the City jurisdiction

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

3.4.4 School Presentations

During FY2017, CMSWS staff provided 80 school
presentations to 2,097 students, grades K-12, at 32
different schools. There were eight different programs
available to the schools which included:

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

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

3.4.5 Public Presentations

A variety of water quality presentations were available from CMSWS to the general public,
interest groups, businesses and industrial facilities upon request. Each presentation, while
similar in nature, was also changed depending on the topic of interest and the audience receiving
the presentation. For example, this past year presentations were given about yard waste, grease,
pollution prevention, general water quality information, and landscaping tips. Table 3-4 shows
the public presentations that were provided by CMSWS during FY2017.

Table 3-4: FY2017 Public Presentations
Date Event Name Number of Attendees
08/18/16 North Carolina Association of Environmental Professionals 50
09/12/16 APWA (NC) Annual Stormwater Management Division
Conference Presentation
125
09/13/16 APWA (NC) Annual Stormwater Management Division
Conference Presentation
170
09/23/16 University of North Carolina at Charlotte 26
10/12/16 MORA Community Meeting 25
11/30/16 Mecklenburg Co. 811 Utility Coordinating Committee 50
11/30/17 North Carolina Lake Management Society 50
01/10/17 811 – Mecklenburg Co. Utility Coordinating Committee 25
Figure 3-4: Enviroscape Model Presentation
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Date Event Name Number of Attendees
01/11/17 Ansco & Associates 100
01/21/17 Mecklenburg County BSA Council 60
01/26/17 Habitat Stewards 23
02/09/17 Greater Charlotte Apartment Association 150
03/03/17 Girl Scout Journeys 75
03/15/17 Webelos Cub Scouts 52
04/27/17 Clanton Park Neighborhood Meeting 15
04/29/17 Unitarian Universalist Church of Charlotte 22
05/03/17 Southgate Commons HOA 60
05/09/17 Community Alliance for Wildlife 8
05/16/17 League of Women Voters 25
TOTAL 1111

3.4.5.1 Public Events

CMSWS staff participated in a variety of community events that were used to promote education
campaigns, give away promotional products, provide face-to-face education opportunities, and
provide formal presentations on water quality topics when appropriate. Table 3-5 shows the
public event participation during FY2017.

Table 3-5: FY2017 Public Event Participation
Date Conducted Event Name Number of Attendees Interacted With
08/20/16 Hummingbird Festival 200
09/21/16 Landscapers Breakfast 120
10/01/16 Neighborhood Exchange and Leadership
Awards
120
10/07/16 City Environmental Vendor Fair 100
10/23/16 Open Streets 704 500
11/09/16 Aquatic Pesticides and Stormwater
Management Workshop
113
11/10/16 Post Construction Stormwater Ordinance
Training
118
11/10/16 Leadership Charlotte Gov't and Politics Day 45
11/17/16 Annual Air Quality Forum 100
11/19/16 Passport to STEM 150
01/19/17 STEM Fair 200
02/19/17 Raise Awareness: Fee Increases 20
02/25/17 Soil & Water Tree Event 50
03/04/17 Auto Bell Creek Challenge 28
03/16/17 Sanitary Sewer Overflow Reduction
Workshop for Multi-family Communities
32
03/16/17 Civic Leadership Academy: Govt. 101 40
03/24/17 Hope for Youth Rally 100
03/24/17 Weatherfest 300
04/19/17 UNCC Earth Day 300
04/20/17 Ballantyne Earth Day 150
04/22/17 Roots Festival 100
04/23/17 UNCC Earth Day Festival 150
04/25/17 Charlotte Fire/Flood Workshop 6
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Date Conducted Event Name Number of Attendees Interacted With
05/05/17 Charlotte Knights 150
05/06/17 Kids Connect with Nature Day 153
05/07/17 Open Streets 704 400
05/20/17 Fresh Expo 150
06/26/17 Charlotte Knights 130
TOTAL 4,025

3.4.6 Informational Website

A significant amount of resources were used to continue promoting and maintaining the
CMSWS website http://charlottenc.gov/StormWater (Figure 3-5). During September 2016, the
City launched a new, redesigned website. The new website provides an updated and enhanced
site that continues to be one of the best ways to provide the general public with water quality
information. A vast amount of water quality information is provided on this website including,
but not limited to, pollution prevention fact sheets, activities and lessons for kids, volunteer
activities, sediment and erosion, regulations, data, maps, watershed information, and stormwater
projects. The number of website page views during FY2017 was 183,759; of these, the number
of unique page views (i.e. the number of times a page was accessed at least once during a
browsing session) was 117,744.

Figure 3-5: CMSWS Main Webpage

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3.4.7 Public Education Materials

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

 A Guide to Used Oil Recycling
 Scoop the Poop (proper handling of animal
waste)
 Only Rain Goes Down The Storm Drain – The
Citizen’s Guide to Pollution Prevention
 Volunteer Opportunities
 A Brief Look at Charlotte-Mecklenburg Storm
Water Services – Your Storm Water Fees at
Work

 Grease Free (proper disposal of grease from Charlotte Water Department)
 Household Hazardous Waste – What do you do with left over chemicals
 Mobile Detailer Best Management Practices
 Landscapers Best Management Practices
 Painters Best Management Practices
 Contractors Best Management Practices
 Carpet Cleaners Best Management Practices
 Vehicle Service Best Management Practices
 Food Service Best Management Practices
 Multi-family Best Management Practices
 Stone Cutting & Fabrication Industry Best Management Practices
 Concrete Industry Best Management Practices
 Commercial Property Management Best Management Practices
 Asphalt Sealing Best Management Practices
 Swimming Pool & Spa Industry Best Management Practices
 Dry Detention BMP Maintenance
 Rain Garden BMP Maintenance
 Sand Filter BMP Maintenance
Figure 3-6: Example of a brochure
distributed as part of Citizen Requests
for Service and at public events
City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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 SW Wetland BMP Maintenance
 Wet Pond BMP Maintenance
 Environmental Notices – Disposal into the storm drain is against the law (available in
English, Spanish, Chinese, Vietnamese, and Korean)

3.4.7.1 Promotional Items

Promotional items were designed and distributed to complement outreach activities such as
group presentations, workshops and public events. All promotional items have the CMSWS
website and include other messages as space allows. Table 3-6 shows the promotional items
distributed during FY2017.

Table 3-6: FY2017 Promotional Items
Promotional Item Message
Magnets Water Watchers App, Reporting Pollution
Pens Six rotating WQ messages
Stainless Steel Water Bottles Be the Solution to Water Pollution. Volunteer.
Key Chains You’re the Key to Clean Water
Wildflower seed bookmarks Minimize fertilizer application
Dog Waste bags Scoop the Poop
Tattoos and Stickers “Stormy” mascot
Sunscreen and lip balm Website address

3.4.7.2 Utility Bill Inserts

Each month throughout the annual report period, the City distributed a water/sewer utility bill to
between 255,276 – 282,322 residents. During FY2017, CMSWS included utility bill inserts in
seven of the 12 monthly water/sewer utility bills. The inserts focus on various topics which
included volunteering, water quality, flooding, CMSWS services and fee changes. The total
number of utility bill inserts that were mailed during FY2017 was 1,785,000. Figure 3-7 shows
a typical utility bill insert that was mailed.

Figure 3-7: June 2017 Utility Bill Insert
City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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3.5 Measurable Goals/Planned Activities for Future Program Years

Table 3-7 describes the various Public Education and Outreach BMPs and the Measurable Goals
and Planned Activities for Future Program Years for each BMP by permit term year.

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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Table 3-7: BMP Measurable Goals for the Public Education and Outreach Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5
Describe target
pollutants and target
pollutant sources
Describe the target pollutants and target
pollutant sources the permittee’s public
education program is designed to address
and why they are an issue.

Identify target
pollution sources
utilizing
monitoring and
service request data
Review and update target pollution sources as necessary. (On-going, years 2 – 5)
Describe target
audiences
Describe the target audiences likely to
have significant stormwater impacts and
why they were selected.
Identify target
audiences to adopt
desired water
quality
improvement
behaviors
Review and update target audiences as necessary. (On-going, years 2 – 5)
Informational Web
Site
The permittee shall promote and
maintain an internet web site designed to
convey the program’s message.
Continue to maintain an informational website to provide program information to the public . (On-going,
years 1 – 5)
Distribute public
education materials to
identified user groups.
Distribute general stormwater educational
material to appropriate target groups as
likely to have a significant stormwater
impact. Instead of developing its own
materials, the permittee may rely on state-
supplied Public Education and Outreach
materials, as available, when
implementing its own program.
Distribute educational materials at public events, workshops and presentations. (On-going, years 1 – 5)
Promote and maintain
Hotline/Help line
Promote and maintain a stormwater
hotline/helpline.
Maintain a hotline that receives information from the public 24 hours a day. (On-going, years 1 – 5)
Implement a Public
Education and
Outreach Program.
The permittee’s outreach program,
including those elements implemented
locally or through a cooperative
agreement, shall include a combination
of approaches designed to reach the
target audiences. For each media, event
or activity, including those elements
implemented locally or through a
cooperative agreement the permittee
shall estimate and record the extent of
exposure.
Continue to implement a plan to conduct education & outreach activities, including a media campaign, that
address target pollutants and audiences. (On-going, years 1 – 5)
City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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3.6 Program Assessment

The overall Public Education and Outreach Program was successfully implemented during the
annual report period. Table 3-8 shows a summary of the various items and corresponding data
results for activities conducted under the program.

Table 3-8: Program Summary
PUBLIC EDUCATION PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Utility bill inserts 3,300,000 2,913,000 2,916,000 1,707,629 1,785,000
Public events 9 15 14 18 28
Attendees at public events 1,335 2,884 2,683 13,514 4,025
Public presentations 2 7 11 15 19
Citizens educated at public presentations 473 254 737 559 1,111
School presentations 54 56 61 56 80
Students educated at school presentations 1,402 1,421 1,510 1,330 2,097
Website page views 99,958 149,786 274,129 288,432 183,759
TV and radio advertising spots 492 1,977 3,761 1,146 800
Public requests to hotline 2,576 3,262 2,429 3,127 7,509

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

Utility Bill Inserts: For FY2017, the increase in numbers from FY2016 reflects an increase in
the number of customers receiving paper bills.

Public Events & Public Presentations: The number of events and presentations during FY2017
increased.

School Presentations: The number of presentations and students who participated increased from
FY2016.

Website Page views: The number of website page views decreased by 36% during FY2017. In
September 2016 CMSWS transitioned to a new website. During this transition, there was a gap
in website analytic data collection which could have led to the decrease in page views.
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Social Media: The number of followers and subscribers to CMSWS social media channels
increased during FY2017.

Stormwater Public Opinion Survey: According to the most recent CMSWS public opinion
survey, an awareness level of 53% is being maintained, meaning 53% of residents surveyed
indicated that they had heard or seen information about stormwater pollution and flooding within
the past year. This is a slight decrease from the previous survey awareness level of 57%. To
further improve awareness of campaign messages, CMSWS plans to target Hispanic and African
American audiences with the media campaigns during FY2018. These populations represent
13% and 32% of Charlotte-Mecklenburg overall population and were not specifically targeted
during FY2017. Plans also potentially include the release new water quality and volunteer
commercials to refresh the media campaigns.

Section 4: Public Involvement and Participation Program

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

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

4.1 BMP Summary Table

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

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

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

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

X X X X X Stormwater
Division
Manager
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BMP

BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Establish
Hotline/Help line
The permittee shall promote and maintain a
hotline/helpline for the purpose of public involvement
and participation.
X X X X X Water Quality
Program
Manager
Public Review
and Comment
The permittee shall make copies of their most recent
Stormwater Plans available for public review and
comment.
X X X X X Water Quality
Program
Manager
Public Notice Pursuant to 122.34 the permittee must, at a minimum,
comply with State, Tribal and local public notice
requirements when implementing a public
involvement/ participation program.
X X X X X Water Quality
Program
Manager

4.2 Volunteer Involvement Program

4.2.1 Target Audience

Public involvement is essential for ensuring the success of volunteer programs and the City
recognizes that without public involvement and support, little progress can be made toward
protecting and improving water quality in its streams. Currently, the primary target audience for
volunteer participation includes homeowners between the ages of 25 and 55 due to their
likelihood to take an interest in their community and become involved in volunteer activities.
The following sub-sections discuss the volunteer programs used in the City’s overall Public
Involvement and Participation Program.

4.2.2 Storm Drain Marking Program

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

This past year, a total of 2,646 storm drains were marked by 297 volunteers for a combined total
of 624 volunteer hours for this program. Storm Drain Marking activities are tracked in order to
help determine programmatic gaps and where resources should be focused. Figure 4-3 shows
Storm Drain Marking activities conducted during FY2017. The Storm Drain Marking program
is a well-organized and a relatively easy-to-manage activity for successfully including citizens of
all ages in stormwater education. By using a more focused approach and targeting families and
volunteer groups, the program saw an increase in participation.
Figure 4-1: Storm Drain Marker
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4.2.3 Adopt-A-Stream Program

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

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

During FY2017, a total of 95 groups of volunteers completed 155 stream cleanups under the
Adopt-A-Stream Program in the City. A total of 1,928 volunteers dedicated 4,516 hours to
picking up trash and reporting pollution in Charlotte-Mecklenburg’s streams. In addition,
volunteers removed approximately 13.8 tons of trash and debris. Adopt-A-Stream activities are
tracked in order to help determine programmatic gaps and where resources should be focused.
Figure 4-4 shows Adopt-A-Stream activities conducted during FY2017 and Table 4-3 provides
a summary of important results relating to the program.

4.2.4 The Big Spring Clean

From the mid 1990’s until 2015, the City and County hosted an annual one-day clean-up event
called Big Sweep. It was part of clean-up events coordinated across North Carolina by the
nonprofit organization “NC Big Sweep,” which dissolved in 2015. In 2016, the event was
renamed locally as “The Big Spring Clean” and CMSWS partnered with Keep Mecklenburg
Beautiful to begin hosting the event on the second Saturday in May each year.

During FY2017, a total of 199 volunteers dedicated 796 hours participating in The Big Spring
Clean event and removed 2.7 tons of trash from local waterways at 7 locations throughout the
City. Figure 4-2 shows the promotional information used for the event.

4.2.5 Volunteer Monitoring Program

The Volunteer Monitoring Program allows volunteers to monitor local streams in order to
evaluate the stream’s health, and flag problem areas for further investigation by CMSWS staff.
Volunteers learn about the chemical composition of the water and can also compare data with
other volunteer monitoring groups.

Although CMSWS has historically supported volunteer monitoring programs in the schools, this
is the first year that a significant effort has been put forth to develop and promote an actual
citizen volunteer monitoring program. During FY2017, a total of 222 volunteers dedicated 654
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hours to participating in the Volunteer Monitoring program. Table 4-3 provides a summary of
important results relating to the program.

Figure 4-2: Big Spring Clean advertisement

4.3 Public Involvement Mechanism

The City, along with Mecklenburg County, established a citizen Stormwater Advisory
Committee (SWAC) in 1994 with the development of their joint stormwater utility (Charlotte-
Mecklenburg Storm Water Services). SWAC members are nominated and subsequently
appointed by the Mecklenburg Board of County Commissioners, Charlotte City Council,
Charlotte Mayor and Town Boards. SWAC includes residents from the City and serves as the
City’s stormwater management citizen advisory panel for the purpose of involving the public in
the development of the SWMP and the implementation of program requirements. The SWAC
reviews:

 Capital and operational programs;
 Regulatory appeals;
 Stormwater program policies;
 Long-range plans; and
 Budgets.

These reviews assisted SWAC in making recommendations and offering comments to the City
Council and the Board of County Commissioners on program matters and annual budgets. The
committee also adjudicated appeals for erosion control violations, service charges, credits and
adjustments, as needed throughout the program year.

4.4 Public Hotline

The City, in cooperation with Mecklenburg County, continued to operate a joint customer
service hotline that helps direct citizens to appropriate resources for their questions and concerns.
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Citizens were able to dial 311 any time of the day (24/7/365) to report pollution, flooding, and
blockages to the drainage system as well as request other City/County services. CMSWS staff
worked with the customer service group to make sure calls were directed to appropriate
personnel and handled in a timely manner. The hotline/help line is discussed further in sub-
section 3.6 above.

4.5 Public Review and Comment Opportunities

The City provided opportunities for public review and comment in the implementation of its
permit and SWMP Plan through website information and interactions with the stormwater
advisory committee (SWAC).

4.6 Public Notice

A public notice was issued in the Charlotte Observer newspaper on June 28 and 29, 2017 to
solicit public review and comment on the City’s NPDES MS4 permit renewal application and
associated SWMP report, which was submitted to the North Carolina Department of
Environmental Quality (NCDEQ) during August 2017.

4.7 Measurable Goals/Planned Activities for Future Program Years

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

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

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

Table 4-3: Program Summary
PUBLIC INVOLVEMENT PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Storm Drain Marking volunteers 231 89 125 119 297
Storm Drain Marking volunteer hours 668 216 198 286 624
Storm drains marked 1,663 956 983 927 2646
SWAC meetings conducted 8 9 10 10 12
Persons attending SWAC meetings 76 88 82 96 109
Adopt-A-Stream groups 81 84 64 67 95
Stream clean-ups conducted 128 141 98 106 155
Adopt-A-Stream volunteers 1,540 1,983 1,211 1,280 1928
Adopt-A-Stream volunteer hours 3,556 5,324 2,514 2,736 4516
Adopt-A-Stream trash removed (Tons) 9 16 9.6 14.9 13.8
Big Spring Clean volunteers N/A N/A N/A 265 199
Big Spring Clean volunteer hours N/A N/A N/A 928 796
Big Spring Clean trash removed (Tons) N/A N/A N/A 9.4 2.7
Volunteer Monitoring volunteers N/A 122 97 619 222
Volunteer Monitoring volunteer hours N/A 7076 194 773 654

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

 Storm Drain Marking Program – The number of volunteers increased significantly thus
also increasing the number of storm drains marked during FY2017. Figure 4-3 shows
Storm Drain Marking activities conducted during FY2017;

 Adopt-A-Stream Program – The number of groups participating increased from FY2016
to FY2017. One-time stream clean-ups are becoming more popular with groups verses
conducting two clean-ups per year, which has traditionally been required. Figure 4-4
shows Adopt-A-Stream activities conducted during FY2017;

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 Big Spring Clean – The number of volunteers for the Big Spring Clean decreased slightly
during FY2017. There was rain on the day of the event which impacted volunteer
turnout. During FY2018, a Second Saturday Stream cleanup program will be
implemented to supplement participation in this program;

 Volunteer Monitoring Program – The number of volunteer monitoring volunteers and
volunteers decreased during FY2017. Volunteer monitoring has typically been focused
in the schools and this was the first year that citizens were directly targeted for this
program;

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

 Public Hotline/ Helpline – The 311 hotline and the Water Watchers Application
continued to be successful tools for allowing the public to report water pollution
problems.
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FIGURE 4-3

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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FIGURE 4-4

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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

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

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

5.1 BMP Summary Table

Table 5-1 provides information concerning the BMPs implemented to fulfill the IDDE Program
requirements.

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

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

5.2 Ordinance Administration and Enforcement

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

Currently, the ordinance has four sections that authorize the issuance of a Notice of Violation
(NOV). Those sections are:

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

Cumulatively from FY1995 through FY2017, a total of 1,089 NOVs have been issued under this
Ordinance. Historically, the majority of these NOVs have been issued under Section 18-80(a)
for either the improper disposal of wash water or wastewater, or the illicit discharge of sewage.

During FY2017, a total of 121 NOVs were issued, which resulted in seven penalty enforcement
cases. The number of NOVs issued by ordinance section was:

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

The NOVs are further categorized based on the type material discharged. During FY2017 the
number of NOVs issued per material category was:

 Concrete (4);
 Cooking grease (23);
 Motor oil (16);
 Paint (3);
 Petroleum fuels (2);
 Sediment (9);
 Sewage (41);
 Wash water (11);
 Wastewater (6);
 Trash (1); and
 Other (5).

Figure 5-1 shows the material type and location of the NOVs issued during FY2017 and Figure
5-2 shows a corresponding graphical representation of this information.

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FIGURE 5-1

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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0
5
10
15
20
25
Materials for NOVs FY 16 -17
Figure 5-2: NOVs issued by material type

5.3 Stormwater System Inventory and Storm System Base Map

The City collects stormwater system inventor y using a Stream Walk Program and an Inventory
Program.

The Stream Walk Program focuses on CMSWS staff walking stream channels to inspect outfalls,
identify and collect data on new outfalls, and to identify dry weather flows. Stream Walks are
scheduled in every sub-basin within the City at least one time every five years. High priority
sub-basins with a history of poor water quality and a higher number of illicit discharges are
scheduled to be walked every other year. A five-year stream-walk plan was developed during
FY2013 for outfall data collection (Figure 5-3). All Stream Walk Program data is provided to
the Inventory Program annually.

The Inventory Program verifies the outfall data collected by the Stream Walk Program and
collects additional data about other parts of the stormwater system such as catch basins, inlets,
pipes, etc. The Inventory Program also collects stormwater infrastructure data from the analysis
of new development and municipal project areas received from the EPM-SWS Design and
Engineering Teams, and Engineering and Property Management’s Engineering Services and
Land Development divisions. All inventory data receives QA/QC and is converted into a
Stormwater System Base Map called “Virtual Charlotte” http://virtualcharlotte/.

During FY2017, the following activities were conducted as part of Stream Walk Program:

 26 sub-basins covering 198 stream miles were walked and assessed;
 262 new outfalls were added to the inventory; and
 319 previously inventoried outfalls received inventory QA/QC.

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Figure 5-4 shows the sub-basins and outfalls inventoried by the Stream Walk Program.

During FY2017, the following activities were conducted as part of the Inventory Program:

 17 square miles were inventoried; and
 132 municipal and new private development projects were analyzed for additional
inventory.

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FIGURE 5-3

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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FIGURE 5-4

City of Charlotte – MS4 Stormwater Management Program – FY2017 Annual Report

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5.4 Illicit Discharge Detection and Elimination Program

5.4.1 Outfall Inspection and Dry Weather Flow Detection

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

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

During FY2017, the following Stream Walk activities occurred:

 581 outfalls were inspected;
 97 DWFs were detected at outfalls and 29 of these were sampled;
 370 fecal coliform and seven total phosphorous samples were collected;
 Five fecal coliform sample results that exceeded the program action limit were
investigated; and
 Seven illicit discharges were detected and eliminated.

CMSWS staff also documented:

 36 stream blockages;
 12 areas of severe stream bank erosion;
 18 riparian wetlands; and
 Seven potential stream reference reaches.

Hot Spot Investigations:
Hot Spot Investigations, or IDEP, involves CMSWS staff conducting outfall inspections in
targeted basins with a higher potential for illicit discharge activities based on criteria such as
monitoring data, prior identified illicit discharges, age of sanitary sewer infrastructure,
commercial land use density, and others. This program is discussed in more detail in Section
5.4.3.

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During FY2017, Steele Creek was the target basin and the IDEP program inspected 12 minor
outfalls (<36” in diameter) with no DWFs detected.

In addition, during FY2017 CMSWS staff also inspected 88 outfalls as part of service requests
and field investigations, municipal facilities inspections, and industrial facility inspections.

5.4.2 Water Quality Monitoring

Water quality in-stream monitoring is used to identify problems and to track long and short-term
water quality trends. The two main monitoring programs used to support IDDE efforts are the
Fixed Interval and CMANN (Continuous Monitoring and Alert Notification Network) stream
monitoring programs. The Fixed Interval program conducts in-stream monitoring for various
chemical and physical parameters on a monthly basis and is discussed further in Section 10. The
CMANN program is an automated monitoring network that takes in-stream readings every 15 to
60 minutes at monitoring sites for dissolved oxygen, temperature, pH, conductivity, and
turbidity. This parameter data is transferred to a data base in real-time using cellular telemetry.
Figure 5-5 shows the monitoring locations for this program.

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

During FY2017, twenty-one (21) follow-up investigations were conducted which resulted in the
discovery of several water quality issues (water main breaks, elevated turbidity levels, etc.) and
one illicit discharge (SSO).

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FIGURE 5-5

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5.4.3 Illicit Discharge Elimination Program (IDEP)

IDEP, or Hot Spot Investigations as previously described, is a sub-set program of the overall
IDDE program. It is implemented as a means to quickly assess field conditions and identify
illicit discharges in priority stream basins. As part of IDEP, a priority basin(s) or “hot spot(s)”
is/are selected each year based on the analysis of a variety of monitoring and service request
data. Within the priority basin(s), CMSWS staff inspects minor outfalls and multi-family private
sanitary sewer collection systems, and collects fecal coliform samples in areas that drain less
than 50 acres. Staff uses visual observation, sensory cues, and quick field tests to determine if
abnormal conditions exist. This quick assessment method allows staff to conduct assessments
more frequently and throughout the year. It has also proved to be effective for identifying illicit
discharges. Figure 5-6 shows the IDEP activities conducted during FY2017.

Also as part of the IDEP program, “business corridor runs” or windshield surveys are conducted
along streets throughout the City that have a high concentration of commercial businesses. Such
areas are considered hot spots for illicit discharges and poor housekeeping. Standard operating
procedures have been developed to describe all IDEP program activities and protocols and they
are reviewed annually. Figure 5-7 shows the business corridors evaluated during FY2017 and
Figure 5-8 shows cooking grease overflowing from a restaurant grease bin discovered as a result
of an IDEP business corridor run.
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FIGURE 5-6

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FIGURE 5-7

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Figure 5-8: An illicit discharge found and corrected under the IDEP program

During FY2017, the following IDEP activities were conducted:

 Steele Creek was identified as the priority basin;
 12 minor outfalls were inspected;
 22 multi-family residential complexes were inspected;
 13 stream sites were sampled for fecal coliform;
 1936 businesses and 328 catch basins were inspected and 21 poor housekeeping issues
were identified as part of business corridor runs. All of them were related to restaurant
and grocery store grease bins;
 Seven Environmental Notices were issued for poor housekeeping issues that were minor
in nature; and
 14 Notices of Violation were issued for poor housekeeping issues that were clearly
discharging to the storm drainage system.

Locations for IDEP activities within the Steele Creek basin are shown in Figure 5-9.

An additional effort that has been implemented as part of IDEP since FY2014 is Microbial
Source Tracking (MST). Fecal Coliform samples are collected in the priority basin(s) based on
high fecal coliform data that has been collected and/or from locations in other basins where
monitoring data and/or Stream Walk samples have shown fecal coliform levels above Action
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levels but sources could not be identified. Samples are analyzed to identify beaver, avian,
canine, human, and ruminant sources.

During FY2017, two MST samples were collected in the Steele Creek basin. Analysis showed
that the highest levels were from ruminant sources with one sample having particularly high
levels. It is theorized that these samples were from bovine sources based on numerous field
observations of bovine feces and tracks in the stream. Small amounts of human and canine, and
trace amounts of avian were also detected in these samples.

In addition, during FY2017, five additional MST samples were collected; one each in the Little
Sugar Creek watershed, the Irwin Creek watershed, the McAlpine Creek watershed, the Gar
Creek watershed (Stream Walk follow up site), and the Lake Wylie watershed (Stream Walk
follow up site). MST samples from these locations did not produce results that helped identify
any particular source.

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FIGURE 5-9

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5.5 Employee IDDE Training and Education

Employee IDDE Training and Education involves training municipal employees about the
detection of illicit connections and discharges, and the various methods for reporting suspected
pollution problems. Training is provided through in-person presentations, classroom style
training sessions, online training modules, or a variety of other methods such as posters, fliers,
light box displays, emails, websites, and displays and information at employee gatherings.

Staff meeting presentations are as simple as providing a 10 – 15 minute presentation at a
regularly scheduled staff meeting that provides information about common illicit discharges in
the community, how to detect them when they enter surface water, the importance of reporting
them, and the various ways they can report them.

In-person presentations are specially scheduled classroom style sessions that include a power
point presentation and video covering:

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

The power point is followed by a 30-minute video called Pollution Prevention BMPs (Excal
Visual) that covers pollution prevention techniques related to:

 Vehicle and equipment washing;
 Vehicle and equipment maintenance;
 Good housekeeping and spill prevention;
 Spill reporting and response;
 Street maintenance;
 Outdoor storage; and
 Landscaping and lawn care.

Online training modules provide a power point presentation similar to the in-person classroom
style session and featured BMP videos from Preventing Stormwater Pollution (North Texas
Council of Governments) which cover job specific pollution prevention for the following
activities:

 Fleet maintenance;
 Land disturbance;
 Parks and recreation;
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 Solid waste;
 Streets and drainage; and
 General municipal jobs.

Other methods to reach employees with information about illicit discharges and the methods to
report them included:

 Staffing information tables and providing promotional products at employee events such
as Earth Day and the City Environmental Vendor Fair;
 Providing digital display messages on monitors located at various locations in the
Charlotte-Mecklenburg Government Center; and
 Providing information in the weekly employee e-newsletter and on City websites.

During FY2017, the following Employee IDDE Training and Education activities occurred:

 82 employees were trained with staff meeting presentations;
 651 employees were trained with classroom presentations;
 274 employees were trained with online training modules; and
 150 employees were contacted during Earth Day and Environmental Vendor Fair events.

5.5.1 Commercial Sector Education and Outreach

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

During FY2017, CMSWS provided 17 two-page best practices publications and guidance
documents for commercial sectors available on-line. This includes a new two page best practice
publication targeting the Horizontal Directional Drilling industry that was developed during
FY2017. CMSWS also distributed these publications as part of service requests, mailings,
training sessions and public events. The following provides a complete list of the commercial
sector publications that have been developed:

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

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During FY2017, CMSWS provided additional outreach to the landscaping and the horizontal
directional drilling sectors as follows:

Landscape sector:
During FY2017, outreach was provided to the Landscape sector through three events:

 Presentation and display at the City’s Landscape Contractor’s Breakfast;
 Display at the Carolina Green Industry Network Landscaping Tradeshow; and
 Sponsorship of the first Aquatic Pesticides and Stormwater BMP Workshop.

The City’s Landscape Contractor’s Breakfast is an annual event organized by the City’s
Landscape Management division that targets landscape related service companies that already
have a contract with the City or have an interest in acquiring a contract. During FY2017,
CMSWS provided a presentation that covered common illicit discharges to the landscape
industry, city contract requirements related to landscaping and illicit discharges, and a brief
overview of the growing business sector of stormwater BMP maintenance and advertisement of
the Aquatic Pesticides and Stormwater BMP Workshop. Staff also set up a landscape and water
quality display with promotional products and brochures at this event. The event was attended
by approximately 70 people.

The Carolina Green Industry Network Landscaping Trade Show is an annual event held in Union
County attended by an average of 500 landscaping professionals from the region each year.
During FY2017, CMSWS partnered with the Regional Stormwater Partnership (RSWP) to
provide a landscape and water quality display and interactive prize wheel with landscaping
questions and promotional products. It is estimated that approximately 115 landscapers visited
the display and interacted with staff.

The Aquatic Pesticides and Stormwater BMP Workshop was a newly developed during FY2017
in partnership with Central Piedmont Community College, Carolina Green Industry Network, the
RSWP, NCSU, and NCSU Cooperative Extension. The workshop was a half-day event and
targeted landscapers in the Charlotte region with information about local water quality, common
illicit discharges associated with landscaping, proper use and safety associated with aquatic
pesticides, beneficial and invasive aquatic plants identification, and stormwater BMP inspection
and maintenance. The workshop was held on November 9, 2016 and attended by 113 people
who represented municipal and private landscape professionals, private country clubs/ golf
courses, pond and lake management companies, engineering firms, non-profit organizations, and
interested residents.

Horizontal Directional Drilling sector:
During FY2017, CMSWS staff continued implementing an outreach plan specific to Horizontal
Directional Drilling (HDD). In addition to distributing and making the BMP publication specific
to the HDD sector available online, staff also performed the following:
 Attended Mecklenburg County Utility Coordinating Committee meetings and presented
information about the City’s Pollution Control Ordinance and common violations
associated with the HDD sector;
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 Provided social media graphics and information for the Mecklenburg County Utility
Coordinating Committee to post on their social media;
 Researched local disposal facilities for HDD contractors;
 Discussed HDD illicit discharges with city right-of-way inspectors;
 E-mailed HDD contractors information about the City’s Pollution Control Ordinance,
common violations associated with the HDD sector, and the BMP publication;
 Posted HDD information on the CMSWS’s website and social media; and
 Conducted a presentation about best practices for complying with the Pollution Control
Ordinance with approximately 100 HDD contractor staff in attendance.

5.5.2 Sanitary Sewer Overflows and Septic Systems

CMSWS works with two separate departments to reduce sources of bacteria from SSOs and
septic systems: Charlotte Water (formerly Charlotte-Mecklenburg Utilities) and the Mecklenburg
County Groundwater and Wastewater Services.

Sanitary Sewer Overflows:
Charlotte Water is the department responsible for operating the water supply and sanitary sewer
systems in the City. During FY2017, there were 189 SSOs from the municipal sanitary sewer
system. This is a decrease of 35 SSOs from FY2016. The number of spills per 100 miles of
pipe system continued to show a steady decline from FY2007 to FY2017 despite the fact that the
City has continued to grow and develop.

The City works to decrease SSOs in four main ways:

 Infrastructure maintenance and inspections;
 Commercial/restaurant/industrial inspections;
 Multi-family residential outreach; and
 The Grease Free education campaign.

Infrastructure maintenance and inspection:
Charlotte Water implements a number of infrastructure maintenance and inspection programs
designed to reduce inflow and infiltration and sanitary sewer losses. During FY2017, the
following was accomplished:

 15.75 miles of sanitary sewer pipe were rehabilitated, repaired or replaced;
 287 manholes were rehabilitated, repaired or replaced;
 321 miles of sanitary sewer pipe were treated with root control chemicals;
 1265.6 miles of sanitary sewer pipe were cleaned;
 299 service connections were replaced;
 82 lift stations received preventative maintenance and twice weekly inspections; and
 154.5 miles of rights-of-way were cleared.

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Commercial/restaurant/industrial inspections:
During FY2017, Charlotte Water performed the following activities:

 4,193 inspections of grease handling/ food service establishments;
 24grease traps installed by businesses as a result of Notices of Deficiency;
 1,980 customers were mailed or handed educational information about proper disposal of
pipe-blocking items (Flow Free education);
 1,046 adults and children received presentations from staff;
 200 compliance inspections at facilities with wastewater pre-treatment permits
(Significant Industrial Users); and
 233 permit limit violations at Significant Industrial User facilities which resulted in
enforcement actions.

Multi-Family Residential Program:
Since 2009, CMSWS has been working with Charlotte Water to prevent SSOs by providing
mailings, workshops and inspections for the multi-family residential sector. During FY2017,
this program accomplished the following:

 Multi-family residential complexes were prioritized based on monitoring data such as
surface water quality and the locations of SSOs and related service requests;
 50 complexes received informational letters explaining the ten state regulatory
requirements for private sanitary sewer collection systems and the resources available
from CMSWS and Charlotte Water to comply;
 32 personnel from multi-family residential complexes attended a training seminar on
March 16, 2017 where presentations focused on responsibilities for managing a private
sanitary system and the best practices for compliance with state regulations;
 Templates for Operation and Maintenance Plans, sanitary sewer system maps and other
compliance documents were provided and made available on the City’s website; and
 30 compliance inspections were conducted by CMSWS staff at facilities that were sent
the informational letter the previous fiscal year. This is an increase of 10 inspections
from FY2016. In addition, there were two inspections conducted as a follow-up to an
initial inspection. During these inspections, staff assisted facility personnel to develop
Operation and Maintenance plans.

Figure 5-10 shows the locations of the 50 multi-family complexes targeted for education during
FY2017 and the 30 sites inspected for compliance.

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FIGURE 5-10

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Septic Systems:

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

During FY2017, a total of 28 failing septic systems were discovered in the City, six were
repaired and 22 were connected to the municipal sanitary sewer system. These failures were not
localized to any particular watershed area. No follow-up field investigations or monitoring were
necessary by CMSWS. Figure 5-11 shows locations of septic system failure activities during
FY2017 as well as the cumulative locations of septic failures since November 2006.

5.6 Public Reporting Hotline

The City, in cooperation with Mecklenburg County, continued to operate a joint customer
service hotline that helps direct citizens to appropriate resources for their questions and concerns.
Citizens were able to dial 311 any time of the day (24/7/365) to report pollution, flooding, and
blockages to the drainage system as well as request other City/County services. CMSWS staff
worked with the customer service group to make sure calls were directed to appropriate
personnel and handled in a timely manner. The hotline/help line is discussed further in sub-
section 3.6 above.

5.6.1 Public Education and Outreach

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

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

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

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FIGURE 5-11

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5.7 Documentation and Citizen Service Requests

Responding to citizen service requests continued to be one of the most important methods for
detecting and eliminating illicit discharges and connections in the City.

During FY2017, a total of 507 citizen service requests related to surface water pollution were
investigated. These included 41 emergency response situations that typically involve oil, fuel, or
other hazardous material releases, as discussed further in sub-section 8.5. All service requests
were investigated and follow-up was provided to ensure efforts were taken to remediate the
discharge and restore impacted areas. Enforcement activities were implemented as appropriate
and are described in more detail in sub-section 5.2.

The City utilizes the Cityworks® database platform to maintain electronic and hard copy files
documenting all IDDE activities including citizen requests. These were tracked from the original
call for service, through investigations and enforcement actions, and until final remedial work.
The database stores information such as reporting party contact information, date, time,
investigator information, pollutant category, investigation reports, monitoring data, photos and
attachments, enforcement information, and geo-location.

Figure 5-12 shows an example of a summary report of a service request activity that can be
generated, and Figure 5-13 shows the FY2017 spatial distribution of service requests and
emergency responses within the City.

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FIGURE 5-12

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FIGURE 5-13

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5.8 Measurable Goals/Planned Activities for Future Program Years

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

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

The overall Illicit Discharge Detection and Elimination Program was successfully implemented
during the annual report period. Table 5-3 shows a summary of the various items and
corresponding data results for activities conducted under the program.

Table 5-3: Program Summary
IDDE PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Stream miles assessed 227 230 209 229 198
Watershed sub-basins assessed 19 18 18 21 26
Outfalls inspected/inventoried/updated 763 1,364 1,265 820 669
Dry weather flows detected 102 240 103 88 97
Dry weather flows sampled 59 138 28 15 29
Citizen service requests responded to 362 355 432 476 507
Emergency spills responded to 49 31 47 43 41
Illicit discharges detected/corrected 448 578 723 829 470
NOVs issued 83 96 86 109 121
Penalty enforcements issued 1 3 6 7 7
Municipal employee IDDE training sessions 45 36 39 34 44
Municipal employees trained on IDDE 1,195 2,206 2,587 965 1,157
SSOs detected/referred 257 247 177 224 189
Septic system failures detected/corrected 22 38 38 26 28

The following is clarification of certain numbers provided in Table 5-3:

 Outfalls inspected/inventoried/updated includes outfalls from stream-walks, IDEP
program, and municipal and industrial inspections;
 Dry weather flows detected includes those from outfalls included in the bulleted item
above;
 Illicit discharges detected includes those found during service requests (includes ERs and
private sewage discharges), SSOs from the public system, IDEP, septic failures, stream-
walks, water quality monitoring, and municipal and industrial inspections;
 Employee IDDE training sessions includes classroom sessions (including those
conducted under the work plan and by wastewater treatment and airport facilities),
number of facilities assigned the online training module, and employee training/outreach
events;
 Number of employee staff trained on IDDE includes all those trained during the sessions
described in the bulleted item above; and
 Number of SSOs includes those from both public and private systems.

CMSWS staff conducted a review and analysis of IDDE activities. The purpose was to evaluate
the effectiveness of current activities, identify new methods for identifying illicit discharges, and
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move forward with program implementation based on the evaluation. As a result of this effort
and discussions in previous years, the following are highlights of that evaluation:

 GIS analysis of illicit discharges continues to show that most of them occur in highly
urbanized areas of the city. As such, the Hot Spot Investigation program (IDEP) will
continue to be implemented as support for the Stream-Walk Program in priority basins;
 Education targeting the landscaping sector will continue to build upon efforts in previous
years including a second Aquatic Pesticides and Stormwater BMPs workshop to assess if
there is continued demand from this audience for this education annually. Commercial
section education during FY2017 would target concrete, paint and pool contractors;
 Targeting multi-family residential complexes with education and inspections will
continue as these complexes are one of the largest sources of SSOs. More inspections at
multi-family complexes targeted in previous years will be conducted during FY2017.
This is due to the finding during previous inspections that quite a few complexes have not
implemented Operation and Maintenance Plans as required by state law;
 The public and internal employee staff continues to be the number one source of illicit
discharge reporting. The hotline, public education campaigns, internal education and
service request response will continue to be a staple for IDDE efforts;
 The Cityworks® database and use of smart phones for field data entry continues to
improve data entry, storage and query capabilities; and
 The City’s vast and varied surface and stormwater monitoring program continues to be an
essential component for finding illicit discharges.

Section 6: Construction Site Stormwater Runoff Control Program

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

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

6.1 BMP Summary Table

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

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

6.2 Erosion and Sediment Control Program

The City has operated a soil erosion and sediment control program locally since 1983, which is
currently a delegated Sediment and Erosion Control Program under authority granted by the
North Carolina Sedimentation Commission. As such, to the extent authorized by law, the City is
responsible for compliance with the Sediment Pollution Control Act of 1973 and Chapter 4 of
Title 15A of the North Carolina Administrative Code. During FY2017 the program served to
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provide added protection to surface water resources in the City by ensuring that builders and
developers followed minimum standards for erosion and sediment control per State and Local
guidelines.

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

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

The ordinance also provides City staff with the following:

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

6.2.1 Inspection Procedures

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

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6.3 Construction Site Requirements

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

6.4 Public Information and Reporting

The City’s Erosion Control Program maintained a website to assist with the dissemination of
information to the development community and the general public. The City also maintained an
information/help line and citizens were able to dial 311 any time of the day (24/7/365) to report
problems. The help line served as a clearinghouse for general information and ensured that
erosion control related issues were directed to appropriate staff for resolution. Information
sharing and inter-department training between City and County agencies also ensured that
problems, questions, or requests for information from the general public were processed and
resolved quickly. The City’s erosion control webpage can be viewed at:
http://charlottenc.gov/ld/Pages/default.aspx

6.4.1 Education and Training Materials

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

In a cooperative effort with Mecklenburg County, the City maintained the Charlotte-
Mecklenburg Certified Site Inspector (CMCSI) training program, which to date has provided
training to over 5,500 individuals since its inception in 2003. CMCSI is a full day training
course that provides attendees with an understanding of the importance of water resources to our
community, the local and state requirements for controlling construction site runoff, principles of
erosion control, common site problems, recommendations for conducting effective inspections,
and a certification exam. The CMCSI program was offered three times during FY2017,
providing training to 383 people (see Table 6-2).

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

Table 6-2: CMCSI Training Program Dates and Attendance – FY2017
Date Registered Attended
August 25, 2016 146 115
January 12, 2017 144 133
May 11, 2017 163 135
Totals 453 383

6.5 Plan Reviews

All land disturbing activity one acre or greater was required to obtain plan approval of the soil
erosion and sediment control plan prior to scheduling a preconstruction conference. Erosion
control plans submitted by the applicants were reviewed and approved by erosion control staff.
All local erosion control staff obtained and/or maintained their status as a Certified Professional
in Erosion and Sediment Control (CPESC) which provided accreditation for plan review. Plans
were reviewed for suitability of selected measures and to ensure that design parameters and
calculations were appropriately employed and minimum standards were achieved.

6.6 Measurable Goals/Planned Activities for Future Program Years

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

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

Table 6-4: Program Summary
CONSTRUCTION SITE RUNOFF PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Education workshops conducted 3 3 3 3 3
Citizens educated 307 356 367 425 383
Project/site plans reviewed 823 1,048 1,043 711 881
Erosion control citizen requests responded to 131 275 ~300 ~375 ~400
Site inspections conducted 3,142 2,852 2,323 2,948 3,853
NOVs issued 38 50 47 109 131
Penalty enforcements issued 24 40 32 41 45

Section 7: Post-Construction Stormwater Management Program

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

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

7.1 BMP Summary Table

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

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

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

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

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

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

X X X X X
Water Quality
Program
Manager
Educational
materials and
training for
developers
Provide educational materials and training for
developers. New materials may be developed by
the permittee, or the permittee may use materials
adopted from other programs and adapted to the
permittee’s new development and redevelopment
program.

X X X X X Water Quality
Program
Manager

7.2 Post-Construction Stormwater Management Program

The City began development of its Post-Construction Stormwater Ordinance & Management
(PCSO) program in 2004 with participation in a Charlotte-Mecklenburg Stormwater
Stakeholders Group. The group consisted of representatives from the development and
environmental communities as well as local government staff. The stakeholders were charged
with making recommendations to the City and County for the development of their respective
post-construction stormwater ordinances. During 2006-2007, the City worked to develop the
ordinance, which was approved by City Council on November 26, 2007, effective July 1, 2008.
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In October 2011, the City Council approved revisions to the ordinance that resulted in the
following:

 A mitigation fee for redevelopment where no increase in impervious coverage occurs;
 Required minimum buffers for all projects; and
 Minor text changes that did not affect the governance of the ordinance.

In October 2014, City Council approved an additional time extension of October 2011 revisions
until December 31, 2017. On July 1, 2016, part of the ordinance was revised to include a
modified version of this redevelopment mitigation option and removed the sunset date in the
ordinance.

The ordinance and post-construction program are designed to meet the stormwater management
and water quality protection requirements of NCGA Session Law 2006-246, as promulgated in
North Carolina Administrative Code at 15A 02H Sections .0126, .0150 - .0154 (NPDES) and at
15A 02H Section .1000 (Stormwater Management) to address post-construction stormwater
runoff from new development and redevelopment projects as required by the NPDES MS4
permit program and as specified and defined in the City’s Post-Construction Stormwater
Ordinance. The ordinance covers the entire jurisdictional area of the City. An administrative
manual has been developed to ensure successful implementation of the program.

7.3 Post-Construction BMP Strategies

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

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

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

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

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

7.4 Deed Restrictions and Protective Covenants

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

7.4.1 Setbacks for Built-Upon Areas

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

7.5 Operation and Maintenance Plan

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

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

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

7.6 Education and Training Program

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

Education and training was accomplished by providing the following:

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

A half-day Post-Construction Stormwater Ordinance education workshop was held on November
10, 2016 with 118 people in attendance. Attendees included representatives from local
government; engineering, land development and design firms; and survey companies. The
presentation topics included:

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

Another half-day workshop entitled “Aquatic Pesticides and Stormwater SCM Workshop” was
held on November 9, 2016 with 113 people in attendance. The workshop targeted landscapers in
the Charlotte region and included sessions on stormwater SCM inspection and maintenance and
beneficial and invasive aquatic plant identification. The workshop ended with an outdoor tour of
two wet ponds where inspection and maintenance items were pointed out and questions were
answered. Attendees represented municipal and private landscape professionals, private country
clubs/ golf courses, pond and lake management companies, engineering firms, and non-profit
organizations. This workshop is also discussed in Section 5.5.1.

7.7 Measurable Goals/Planned Activities for Future Program Years

Table 7-2 describes the various Post-Construction Stormwater Management Program BMPs and
the Measurable Goals and Planned Activities for Future Program Years for each BMP by permit
term year.
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Table 7-2: BMP Measurable Goals for the Post-Construction Stormwater Management Program.
BMP BMP Description Measurable Goals
(by permit term year)
1 2 3 4 5
Post-Construction
Stormwater
Management
Program
Maintain an ordinance (or similar regulatory mechanism) and program to address
stormwater runoff from new development and redevelopment.

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

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

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

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

Continue to implement BMP operation, maintenance, and
inspection plan and procedures. (On-going, years 1 – 5)
Educational
materials and
training for
developers
Provide educational materials and training for developers. New materials may be
developed by the permittee, or the permittee may use materials adopted from other
programs and adapted to the permittee’s new development and redevelopment program.

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

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

Table 7-3: Program Summary
POST-CONSTRUCTION PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Site plans reviewed 57 96 103 121 145
SCMs added 38 97 109 151 171
SCM inspections conducted 27 93 6061. 7261. 10061.
NOVs issued 10 6 2582. 4152. 4042.
Education workshops conducted 1 4 5 2 1
Citizens educated 18 105 183 194 231
1. Includes Post-Construction and Peak Detention SCMs inspected.
2. “NOVs issued” includes Corrective Action Requests (CARs) and letters to remind the property owner that a yearly inspection report is due.

As illustrated in Table 7-3, there has been a significant increase in SCM inspections during
FY2017 over previous years. This has been an ongoing goal of the Post-Construction
Stormwater Management Program. As SCMs increase in the City it is the goal of the program to
continue with these efforts such that additional staff has been added to conduct inspections.

In addition, the number of NOVs and CARs issued during FY2017 was consistent with FY2016;
however, relative to the number of inspections that were conducted during FY2017, this was a
significant decrease. This equates to an approximate 17% reduction in issues relative to
inspections. This relative decrease emphasizes the overall effectiveness of the program as the
responsible parties are becoming more informed and educated of the SCM maintenance
requirements.

Section 8: Pollution Prevention/Good Housekeeping Program

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

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

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8.1 BMP Summary Table

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

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

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

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

8.2 Operation and Maintenance Program

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

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EPM-Storm Water Services continued to work with various operations to implement best
management practices to minimize negative impacts to the storm drainage system. This has been
accomplished through a process of observing field operations, updating best management
practices and SOPs, and training employees. Stormwater protection best practices have been
developed for a total of ten field operations as follows:

 Central Business District Maintenance Operations;
 Landscape Management;
 Facility Maintenance;
 Road, Sidewalk and Facility Construction;
 Street Sweeping;
 Street Maintenance;
 Water/Wastewater Utility Maintenance & Repair;
 Traffic Engineering Operations;
 Transit Amenities Maintenance; and
 Hazardous Materials Operations.

During FY2017, CMSWS staff focused on developing and implementing pollution prevention
practices at EPM-SWS construction projects. Activities included:

 Working with EPM-SWS construction staff to understand the best procedures and
methods for improving contractors and subcontractor performance related to preventing
illicit discharges and implementing pollution prevention practices;
 Developing a new Surface Water Quality Protection section for EPM-SWS construction
contracts that includes requirements for contractors to:
- properly contain, collect and dispose of concrete and concrete waste water;
- have spill response materials onsite and properly respond to leaks/spills at all times;
- implement pollution prevention to ensure streets are clean before washing; and
- develop a Refueling Operations Plan, if a fuel tank will be onsite, that includes the
location of fuel tanks 50’ from any storm drain or water body and procedures for
fuel handling, spill/leak containment, proper disposal of contaminated materials,
emergency response, and protection of storm drains during refueling.
 Developing new language on the general notes section of plan sheets that includes the
following:
- 401/404 jurisdictional area(s) have been permitted under Charlotte Storm Water
Services regional general permit #163/GC #4100, or applicable permit document.
The contractor shall follow all applicable permit requirements; and
- By City ordinance, the discharge of stormwater pollutants to the stormwater system
or water bodies is prohibited.
 Issuing an NOV to a trucking subcontractor for excessive oil leaks from their truck and
improper leak response.

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In addition, the following FY2017 activities occurred to improve field practices in other City
departments:

 New language in the Charlotte Department of Transportation’s Street Maintenance
Standards that requires prevention of waste discharges associated with street cutting; and
 Evaluation of spill response procedures across the City and gaining consensus from
department leadership to develop new spill response education and procedures.

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

8.3 Facility Stormwater Pollution Prevention Plans

SPPPs are developed for all facilities listed in Table 8-2 with the exception of fire stations. The
SPPPs are reviewed and updated annually with all documentation kept in the SPPPs, including
site maps. The SPPPs are used as an implementation guide for maintaining good housekeeping
and reducing stormwater pollution. All appropriate topics are covered in the SPPPs including:

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

Table 8-2: Municipal Sites Included in the Pollution Prevention/Good Housekeeping Program.
Facility Physical Address
Charlotte-Douglas International Airport 5501 Josh Birmingham Pkwy., Charlotte, NC 28208
CATS Bus Maintenance Operations Facility 3145 S. Tryon St., Charlotte, NC 28217
CATS Transit Maintenance Operations Center 901 N. Davidson St., Charlotte, NC 28202
CATS Transit Center 310 E. Trade St., Charlotte, NC 28202
CATS Light Rail Maintenance Facility 3305 Pelton St., Charlotte, NC
CDOT - Traffic Engineering Operations Center 3701 Craig Ave., Charlotte, NC 28211
CDOT – Street Maintenance Division - Northwest
District 4411 Northpointe Industrial Blvd., Charlotte, NC 28216
CDOT – Street Maintenance Division - Northeast
District 6001 General Commerce Dr., Charlotte, NC 28213
CDOT – Street Maintenance Division - Southwest
District 4600 Sweden Rd., Charlotte, NC 28273
Charlotte Water Department - Irwin Creek WWTP 4000 Westmont Dr., Charlotte, NC 28217
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Facility Physical Address
Charlotte Water Department - Mallard Creek WWTP 12400 Hwy 29 N, Charlotte, NC 28262
Charlotte Water Department - McAlpine Creek
WWTP & Zone 3 Water/Wastewater Operations 12701 Lancaster Hwy, Pineville, NC 28134
Charlotte Water Department - McDowell Creek
WWTP 4901 Neck Rd., Huntersville, NC 28078
Charlotte Water Department - Sugar Creek WWTP 5301 Closeburn Rd., Charlotte, NC 28210
Charlotte Water Department - Franklin WTP 5200 Brookshire Blvd, Charlotte, NC 28216
Charlotte Water Department - Lee S Dukes WTP 7980 Babe Stillwell Rd., Huntersville, NC 28078
Charlotte Water Department - Vest WTP 820 Beatties Ford Rd., Charlotte, NC 28216
Charlotte Water Department – Zone 1
Water/Wastewater Field Operations 11609 Hord Dr., Huntersville, NC 28078
Charlotte Water Department – Zone 2
Water/Wastewater Field Operations 5730 General Commerce Dr., Charlotte, NC 28213
Charlotte Water Department – Zone 4
Water/Wastewater Field Operations 4100 W. Tyvola Rd., Charlotte, NC 28208
Charlotte Water Department – Catawba Pump
Station 12548 Pump Station Rd., Charlotte, NC 28216
Financial & Management Services - Heavy
Equipment Shop 4600 Sweden Rd., Charlotte, NC 28273
Financial & Management Services - Heavy Truck
Shop / Central Yard Truck Wash 829 Louise Ave., Charlotte, NC 28204
Financial & Management Services - Light Vehicle
Shop 1031 Atando Ave., Charlotte, NC 28216
Financial & Management Services - Small Engine
Repair Shop 701 Tuckaseegee Rd., Charlotte, NC 28208
CFD - Fire Logistics 1200 Otts St., Charlotte, NC 28205
CMPD - Animal Control Shelter 8315 Byrum Dr., Charlotte, NC 28217
Police and Fire Training Academy 1770 Shopton Rd., Charlotte, NC 28217
Solid Waste Services - Street Sweeper Facility &
Sanitation Packer Lot 829 Louise Ave., Charlotte, NC 28204
Landscape Management Operations 701 Tuckaseegee Rd., Charlotte, NC 28208

8.4 Facility Inventory and Site Inspections

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

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

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

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

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

During FY2017 the following activities were conducted as part of the Municipal Facility
Inspections:

 51 inspections (including 21 fire stations);
 Three illicit discharges and 12 deficiencies were detected; and
 149 recommendations were made

Figure 8-1 shows the locations of the facilities inspected during FY2017.

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FIGURE 8-1

8.4.1 NPDES Stormwater Permitted Municipal Facilities Review

Eleven (11) City facilities, which are listed in Table 8-3, have been issued NPDES Stormwater
permits (*Note: The airport’s permit is a combined stormwater/wastewater individual permit).

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Table 8-3: Municipal Operations That Have Been Issued NPDES Stormwater Permits
Municipal Operation Permit
Number
Certificate of Permit
Coverage Number
Address
CATS Transit Maintenance
Operations Center
NCG080000 NCG080029 901 N. Davidson Street
CATS Bus Maintenance
Operations Facility
NCG080000 NCG080710 3145 S. Tryon Street
Heavy Truck Shop, Truck
Wash & Street Sweeper
Yard
NCG080000 NCG080822 829 Louise Avenue
Heavy Equipment Shop NCG080000 NCG080840 4600 Sweden Road
Light Vehicle Maintenance
Shop
NCG080000 NCG080879 1031 Atando Avenue
Charlotte-Douglas
International Airport*
NC0083887 Not applicable 5501 Josh Birmingham Parkway
Irwin Creek WWTP NCG110000 NCG110008 4000 Westmont Drive
Mallard Creek WWTP NCG110000 NCG110114 12400 Highway 29 North
McAlpine Creek WWTP NCG110000 NCG110010 12701 Lancaster Hwy
McDowell Creek WWTP NCG110000 NCG110011 4901 Neck Road
Sugar Creek WWTP NCG110000 NCG110012 5301 Closeburn Road

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

8.5 Municipal Spill Response Procedures

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

 Product storage tanks/containers, exposure, and secondary containment;
 Flow path and potential for entry into the MS4;
 Spill history, response to those spills, and documentation;
 Activities that may generate spills;
 Operating procedures to prevent spills;
 Spill response procedures;
 Spill response equipment and other countermeasures; and
 Employee training.
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In addition, as part of the overall IDDE program, CMSWS staff maintained a 24-hour emergency
response team that responds to environmental emergencies, including spills. Members of the
team act in an advisory role to the CFD Hazmat Unit. Once Hazmat secures a scene and
contains the spill, the team worked with the responsible party to ensure that spills were cleaned
up properly and had minimal impacts to the environment. The team’s actions are guided by a set
of written emergency response protocols.

During FY2017, the team responded to 41 hazardous materials releases. Figure 8-2 shows the
locations of those releases.

8.6 Vehicle and Equipment Cleaning Operations

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

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8.7 Streets, Roads, and Public Parking Lots Maintenance

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

 Street Sweeping Program;
 Adopt-A-Street Program;
 Leaf and Yard Waste Collection Program;
 Trash Receptacles along Downtown Streets;
 Trash Receptacles and Litter Control activities at Park and Ride Parking Lots; and
 Public Education to address polluted stormwater runoff from municipally-owned streets
and public parking lots.

During FY2017, EPM-SWS staff finished a study that began in FY2016 to determine the
effectiveness of lot sweeping by street/lot sweeping equipment. Four municipal lots with varied
uses were selected for the study and a private contractor was selected to conduct the work. Two
heavy-use lots were swept twice per month and two lighter-use lots were swept once per month.
Samples were weighed and analyzed by UNC Charlotte faculty and staff. The final report was
received in late FY2017 and results will be analyzed to determine the cost effectiveness of using
vehicle sweepers to clean municipal lots in the future.

8.8 Municipal SCMs and MS4 System Operation and Maintenance

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

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

These inspection and maintenance activities have been conducted to ensure proper function of
structural SCMs. During FY2017, Standard Operating Procedures (SOP) were updated for the
program, and a meeting was held with all involved staff to review the SOP.

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

The City conducted extensive cleaning and maintenance of the MS4 system during FY2017.
Work included, but was not limited to:

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

During FY2017, a total of:

 589 catch basins were manually cleaned;
 99,394 catch basin tops were manually cleaned;
 2,689 catch basins were vacuumed out;
 3,393 catch basin tops were vacuumed;
 45,995 linear feet of stormwater pipes were vacuumed out; and
 2,461 citizen service requests were addressed.

All of this work was conducted according to written SAPs for each activity with associated work
information recorded and entered into a database.

8.9 Employee/Staff Training at Municipal Facilities

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

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

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

For FY2017, training was conducted as follows:

 13 on-site training sessions were provided by CMSWS staff at 13 of the municipal
facilities listed on Table 8-2;
 Eight facilities elected to train their own staff (CATS Tryon, CATS Davidson, 5
wastewater facilities, airport);
 274 employees from nine facilities were assigned an online training module.

Of those who were assigned the module, 274 employees completed it, which is 89%. EPM-SWS
staff works with facility management each year to ensure the completion percentage is above
75%.

8.10 Measurable Goals/Planned Activities for Future Program Years

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

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

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

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

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

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

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

Table 8-5: Program Summary
MUNICIPAL GOOD HOUSEKEEPING PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
City owned parcels inventoried 90 75 130 56 43
City facilities inspected1. 31 31 31 50 51
Municipal program evaluations 10 9 9 2 28
Problems detected/corrected at City facilities 45 55 56 43 15
Municipal facility employee training sessions 32 34 32 32 39
Municipal facility employees trained 925 891 1118 760 1808
1. Not all parcels are included in the municipal inspection program. See Sec 8.4

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

 Number of city owned parcels inventoried includes properties purchased in the previous
calendar year (in this case, 2016);
 Number of city facilities inspected includes those at which CMSWS staff conducted
inspections (during FY2017 it included roughly half of the fire stations, which are
inspected once every 5 years);
 Municipal program evaluations include reviews (field observations, meetings, etc.) of
municipal field operations for development and/or implementation of stormwater
pollution prevention best practices;
 Includes problems found during city facility inspections (doesn’t include very small
issues);
 Number of training sessions held includes classroom sessions (including those conducted
under the work plan and by wastewater treatment and airport facilities) and number of
facilities assigned the online training module; and
 Employees trained category includes all employees who completed training in the
sessions described in the bulleted item above.

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

 Continuing to develop and improve upon stormwater pollution prevention best practices
among city field operations;
 Municipal street and lot sweeping, with a specific focus on water quality improvement;
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 Comprehensive improvement in the spills program including training, written
procedures, cleaning, reporting, recording, and other elements;
 Contractor training and expectations;
 Continuous improvement in inspection and maintenance of city-owned structural
SCMs; and
 Increased communication and work with other departments and committees to integrate
more stormwater pollution prevention, green infrastructure, and other stormwater
measures into city projects and infrastructure.

Section 9: Industrial Facilities Evaluation and Monitoring Program

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

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

9.1 BMP Summary Table

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

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

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

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

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

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

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

9.2 Industrial Facility Inventory

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

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

The goal is to inspect all NPDES permitted facilities in the inventory every five (5) years, with
more frequent inspections conducted at facilities with previous compliance issues or facilities
that are deemed to have a higher potential to pollute. Non-permitted industrial facilities are
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selected for inspection based on the recommendation of CMSWS staff, citizen complaints, or
from viewing aerial photography that indicated potential pollution issues on site.

During FY2017, significant work was performed to review the strategy for inspecting industrial
facilities and in FY2018, it is anticipated that this new strategy will used and finalized for
selecting facilities for inspection. The new strategy focuses on establishing different priority
tiers for NPDES-permitted facilities based on several criteria that indicate a facility’s potential to
impact surface waters. The purpose of the priority tiers is to use program resources to conduct
more frequent inspections and follow-up activities at facilities that have a history of non-
compliance with the City’s Stormwater Pollution Control Ordinance or facilities that generally
have a greater potential to impact surface waters. To support this new prioritization strategy,
CMSWS staff developed a document detailing the goal of the strategy and the criteria for each
priority tier, created a flow chart that guides the ongoing prioritization of a facility, and updated
the NPDES database to assign an initial priority rank for each facility.

Vehicle maintenance facilities are also inspected as part of the Industrial Facility Inspection
program because they are a known source of poor housekeeping and illicit discharges. Facilities
are selected for inspection based on of a combination of targeting priority watershed basins,
aerial photography suggesting potential to pollute, and staff recommendations. For FY2017, the
watersheds prioritized for inspection were Taggert Creek, Upper Little Sugar Creek, and Upper
Irwin Creek.

9.3 Industrial Facilities Inspection and Monitoring Program

The purpose of the Industrial Facilities Inspection program is to evaluate activities at industrial
facilities that may impact stormwater discharges, and then work with problem facilities to reduce
identified stormwater pollution. To effectively accomplish the goals of the program, an
Industrial Facilities Inspection and Monitoring Procedures Manual is utilized. The manual
objectives are as follows:

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

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

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

A standard inspection form is used for conducting all inspections. A separate inspection form is
used for Vehicle Maintenance Facility inspections. For inspections at NPDES permitted
facilities, any deficiencies related to NPDES stormwater permit requirements are identified and
included in the report, with a copy sent to the NCDEQ. The understanding between the City and
NCDEQ is that the State is responsible for following-up on permit-related deficiencies and
violations since they are the issuing regulatory authority for the permits. Facilities that are found
without coverage under an appropriate general stormwater permit category are also brought to
the attention of NCDEQ.

During FY2017 the Industrial Facilities Inspection and Monitoring Program inspected 41
industrial facilities (31 permitted and 10 non-permitted) and 16 vehicle maintenance shops.
Tables 9-2 and 9-3 provide a list of the facilities inspected while Figures 9-1 and 9-2 show the
location of these facilities.

Table 9-2: FY2017 List of Industrial Facility Inspections
Facility NPDES Permit # Address
Vulcan Construction Materials - Pineville NCG020049 10500 Old Nations Ford Road
Martin Marietta - Charlotte NCG020051 4551 Beatties Ford Road
Textile Rubber & Chemical Company Inc. NCG050013 2321 N Davidson Street
Genpak, LLC NCG050147 1001 Westinghouse Blvd.
International Paper - Charlotte Container Plant NCG050169 5419 Hovis Road
Snyder's - Lance Incorporated NCG060148 8600 S Blvd.
Howell's Motor Freight Incorporated NCG080283 10028 Metromont Ind. Blvd.
Schneider National Carriers - DWJ1 NCG080583 2420 Starita Road
Academy Bus Sunway Charters (formerly
Evergreen Trails) NCG080770 1251 W Craighead Road
YRC, Inc. dba. YRC Freight (653) NCG080777 11010 Reames Road
NS Thoroughbred Bulk Terminal NCG080906 2820 Nevada Blvd.
Southeastern Freightlines NCG080912 1200 Amble Drive
Valspar Industries USA Incorporated NCG090033 10300 Claude Freeman Drive
Ferebee Asphalt Corporation NCG160200 830 E Westinghouse Blvd.
Wise Recycling, LLC-Charlotte Plant NCG200454 4923 Brookshire Blvd.
Auto Parts U Pull and Scrap Metal NCG200509 9820 Statesville Road
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Facility NPDES Permit # Address
United Scrap Metal, Inc. NCG200513 9925 Brookford Street
Safety Kleen Systems, Inc. (Goodrich Dr.) NCG080923 12040 Goodrich Drive
Sonoco Products Co-Charlotte NCG130011 3901 Barringer Drive
Safety Kleen Corp-Mecklenburg NCG130025 2320 Yadkin Avenue
Charlotte Recycle Plant (Int'l Paper) NCG130033 201 E 28th Street
Concrete Supply - North Plant NCG140041 3823 Raleigh Street
Concrete Supply - Croft Plant NCG140053 6528 Lakeview Road
Thomas Concrete Of Carolina Inc. NCG140308 3701 N Graham Street
BCI Materials, Inc. NCG160210 1131 Atando Avenue
Custom Pallet & Crating NCG210417 5104 N Graham Street
National Welders DBA Airgas National
Welders NCS000045 5313 Old Dowd Road
DART Acquisitions NCS000312 4132 Pompano Road
Salvage Auto Supply LLC NCG100207 3301 Robinson Circle
Metromont Corporation NCG070028 4101 Greensboro Street
Ward Trucking, LLC NCG080109 3005 Queen City Drive
Non permitted:
Total Distributors
n/a

4201 Chesapeake Drive
Univar 2001 Continental Blvd.
Carowinds 14523 Carowinds Blvd.
Starnes Pallet Service 4000 Jeff Adams Drive
C&M Recycling 2930 Jeff Adams Drive
Central Transport 601 Johnson Road
Hunter Auto 5310 David Cox Road
Southern Cast Foundry 847 North Church Street
Carolina Environmental Response Team 5648 Daphne Drive
Doggett Concrete 1425 Cressida Drive

Table 9-3: FY2017 List of Vehicle Maintenance Facility Inspections
Facility Address
Me-K-Nica Auto Repair 4500 Old Pineville Road
Sam's Body Shop 2215 Freedom Drive
Quality Repair Work 245 Yeoman Road
F&R Auto Repair (formerly Chavez Auto) 124 East Peterson Drive
Sunshine Auto Service 223 East Cama Street
Charlotte's Auto Repair 132 East Cama Street
Fico Car Sale and Services 4214 South Tryon Street
Izabal Auto Repair 3419 South Tryon
EZ Auto Service and Collision Center 4425 South Blvd.
Hondaworks Inc. 200 Scaleybark Road
David's Auto and Performance 117 West 28th Street
Cruz Auto and Towing 100 Dalton Avenue
R&S Auto and Tire 2338 Lucena Street
Tundea Automotive Services 4009 Hargrove Avenue
CJR Auto Repair Center 5409 Wilkinson Blvd.
A&P Automotive 2711 Midland Avenue
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FIGURE 9-1

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FIGURE 9-2
9.3.1 Industrial Facilities Monitoring Program

The purpose of the Industrial Facilities Monitoring Program is to monitor stormwater runoff
from industrial NPDES stormwater permitted and/or non-NPDES permitted facilities and
identify pollution sources related to industrial activities. Facilities are selected based on input
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from the CMSWS inspectors who inspected these facilities under the Industrial Inspections
Program during the previous fiscal year.

During FY2011, a SAP was developed for reviewing, interpreting and following up on
monitoring data from the Industrial Facilities Monitoring Program. The main purpose of the
SAP is to make analysis of the monitoring data as objective as possible. As part of the SAP,
summary statistics and tables were created from all past monitoring data at local industrial sites.
Comparing individual monitoring results to the summarized data set allows staff to compare
results at a particular facility with the entire data set.

When an analysis of the monitoring data is conducted and results found to be above State surface
water quality standards or the CMSWS statistical analysis values of past monitoring data for
industrial facilities, a letter summarizing the analytical sampling results is sent to each monitored
facility. Copies of this letter are also provided to NCDEQ for NPDES permitted facilities. For
facilities with elevated pollutant levels, follow-up inspections were conducted and
recommendations were made to improve outdoor operations, housekeeping, material storage
practices, and other measures that should result in reduced pollutant runoff.

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

9.4 Evaluation Measures

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

9.5 Measurable Goals/Planned Activities for Future Program Years

Table 9-4 describes the various Industrial Facilities Program BMPs and the Measurable Goals
and Planned Activities for Future Program Years for each BMP by permit term year.
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Table 9-4: BMP Measurable Goals for the Industrial Facilities Program.

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

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

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

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

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

The overall Industrial Facilities and Monitoring Program was successfully implemented during
the annual report period. Table 9-5 shows a summary of the various items and corresponding
data results for activities conducted under the program.

Table 9-5: Program Summary
INDUSTRIAL FACILITIES PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Master industrial inspection site inventory 358 384 468 342 374
Industrial facilities inspected 51 51 50 40 41
Vehicle maintenance facilities inspected 15 20 21 15 16
Industrial facilities monitored 10 10 10 8 8
Industrial facility Notice of Deficiencies issued 13 7 7 5 9
Illicit discharges or connections
detected/corrected 3 0 0 3 5

The following is clarification of certain numbers provided in Table 9-5:

 Includes industrial facilities with an NPDES Stormwater permit, Stormwater No
Exposure Certificate, Charlotte Water pre-treatment permit and/or is a TRI submitter or
TSD facility; and
 Number of industrial facility (not including vehicle maintenance facilities) deficiencies
with Notices issued includes industrial facilities whose reports were issued as an NOV or
Unsatisfactory with regard to their compliance with the City’s Stormwater Pollution
Control Ordinance. Facilities with strictly NPDES permit compliance issues (e.g., lack of
required monitoring or training) were not counted in this number.

Of the 41 industrial inspections conducted, five illicit discharges were discovered, five of the
permitted sites were unsatisfactory and one of the non-permitted sites was unsatisfactory. Five
of the non-permitted facilities were observed to likely be subject to an NPDES stormwater
permit because of their SIC Code, exposure of outdoor materials, and the presence of at least one
outfall onsite. CMSWS staff notified NCDEQ about those facilities. Of the 16 vehicle
maintenance facilities inspected, 29 deficiencies were identified.

All facilities where deficiencies were noted received follow-up correspondence and inspections
from CMSWS staff to assist with compliance. As a result of communicating the results of these
inspections with NCDEQ, one facilit y obtained a new stormwater permit and no facilities
received a Notice of Violation for operating without a permit.

Stormwater monitoring was conducted at eight facilities (seven permitted and one non-
permitted). No illicit discharges or illicit connections were observed during monitoring
activities, but 62% of the facilities monitored exceeded the state standard for turbidity and zinc.
Letters summarizing the analytical sampling results were sent to each monitored facility and
copies were provided to NCDEQ for NPDES permitted facilities.
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Section 10: Water Quality Assessment and Monitoring Program

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

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

10.1 BMP Summary Table

Table 10-1 provides information concerning the BMPs implemented to fulfill the requirements
of the Water Quality Assessment and Monitoring Program.

Table10-1: BMP Summary Table for the Water Quality Assessment and Monitoring Program.
BMP BMP Description Schedule (years) Responsible
Position 1 2 3 4 5
Water Quality
Assessment and
Monitoring Plan
Maintain a Water Quality Assessment and
Monitoring Plan. The Plan shall include a schedule
for implementing the proposed assessment and
monitoring activities.

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

X X X X X Water Quality
Program
Manager

10.2 Water Quality Assessment and Monitoring Plan

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

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

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

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FIGURE 10-1

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

10.3 Water Quality Monitoring Implementation

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

10.4 Water Quality Assessment and Monitoring Plan Revisions

The City has reviewed the basic monitoring program plan and data generated during FY2017 and
proposes no major changes to that plan at this time.

10.5 Measurable Goals/Planned Activities for Future Program Years

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

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

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

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

Table 10-5: Program Summary
WATER QUALITY MONITORING PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018
Stream sites monitored1. 15 15 15 15 15
Stream samples collected1. 60 60 60 60 60
Laboratory sample analyses conducted1. 720 720 720 720 720
Stream physical measurements (DO, Temp, pH, Cond) 1. 240 240 240 240 240
IDDE problems detected/corrected through monitoring 0 1 0 2 0
1. Data reported is the minimum quarterly amount per the basic monitoring plan.

10.6.1 Water Quality Monitoring Program Evaluation

During FY2017, an evaluation of the water quality monitoring program was conducted to
determine whether any changes were needed to improve the cost-effectiveness of the program.
This evaluation resulted in the changes discussed in the following paragraphs.

During FY2009, Enterococcus was added to the enhanced monitoring program to develop a
baseline for this parameter in case a future Enterococcus freshwater standard would be
developed for North Carolina. This parameter has been monitored for nine years under the
City’s program and since there is no indication that a freshwater standard will be developed in
the foreseeable future, it was decided to discontinue this monitoring effort.

In addition, the State’s implementation of a new dissolved metals standard during FY2015 in
place of the previous total metals standard led the City’s program to collect and evaluate
dissolved and total metals comparative data to determine which parameters might exceed the
new dissolved standard and therefore should continue to be monitored. A review of 18 months
of monthly fixed interval data showed that total arsenic, total beryllium, total selenium, total
cadmium and total silver could be removed from the City’s enhanced monitoring program since
these parameters were consistently below laboratory detection limits and State standards for
dissolved metals.

These changes do not impact the parameter list or sampling frequencies for the basic monitoring
program identified in Table 10-2.

10.6.2 Water Quality Trend Analysis

The City utilizes water quality data generated from various monitoring programs, including
NPDES MS4, to generate a Stream Use Support Index. This spatial index visually represents
water quality conditions by sub-basin and can be compared year by year to determine general
trends. The index map for calendar year 2016 is shown below in Figure 10-2. The map shows
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general WQ conditions to be in the partially supporting to impaired category for the sub-basins
within the City.

Figure 10-3 shows time series graphs for each non-metal parameter in the monitoring plan for
the eight-year period from Jan 2009 to Jun 2017 (metals shown separately in Figure 10-4). Each
graph displays median analyte values across all sites for each particular fixed interval sampling
event (i.e., quarterly at minimum, though typically monthly). These graphs do appear to show
small reductions in peak concentrations for some analytes over time (e.g. TSS, Total Phosphorus,
and Total Kjeldahl Nitrogen); while in other cases no trend is apparent. Additional analyses,
considering each analyte and watershed individually combined with normalization for flow
conditions at the time of sampling, will likely be needed to further discern water quality trends.
These analyses are ongoing, and may be reported in future annual reports.

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FIGURE 10-2

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FIGURE 10-3

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Figure 10-4 shows data for the metals included in the monitoring plan for the period of July
2010 through June 2017. These data have been plotted as the difference between individual
sample results and the acute dissolved standard at the sample’s hardness value to better illustrate
exceedances and non-exceedances on a temporal basis. As a result, the vertical axes represent
how far above or below the standard a given sample was, as opposed to showing absolute sample
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concentrations. Samples collected prior to implementation of the dissolved metals standards are
also shown relative to the current dissolved metals standards, as this gives a better picture of
historical toxicity.

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

FIGURE 10-4

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Section 11: Total Maximum Daily Load (TMDL) Program

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

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

11.1 BMP Summary Table

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

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

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

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

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

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

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

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

11.2 TMDL Watershed Plan

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

11.2.1 TMDL Watershed Identification

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

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

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

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11.2.2 Outfall Identification for TMDL Watersheds

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

11.3 Identification of Existing Measures

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

11.4 Assessment of Available Monitoring Data

Fixed interval surface water quality data collected from 2006 through 2017 have been analyzed
for all applicable TMDL watersheds and pollutants of concern in the City and County. These
data help to illustrate surface water quality trends in relation to the NC surface water quality
standards. The City’s current NPDES MS4 permit, effective March 1, 2013, states that the
“MS4 Permittee is not responsible for attaining water quality standards (WQS) and the Division
expects that attaining WQS will only be achieved through reduction of the TMDL pollutant of
concern from the MS4, along with reductions from all other point and nonpoint source
contributors.” It is infeasible to monitor every MS4 stormwater outfall to determine how
progress is being made toward achieving MS4 NPDES WLAs; therefore, the City will utilize
fixed interval surface water data to investigate water quality trends. The data presented below,
while illustrating how in-stream water quality has changed over time, unfortunately are not able
to distinguish MS4 contributions from other point and nonpoint sources that are not under the
control of the MS4. Consequently, increases in surface water contaminants observed in the data
do not necessarily indicate that MS4 contributions are also increasing.

11.4.1 Fecal Coliform

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

11.4.1.1 McKee Creek

Fixed interval stream data for fecal coliform was collected at the CMSWS monitoring site
MY7B on McKee Creek. A summary of the data collected from January 2007 through July 2017
is provided in Figure 11-2. A total of 143 samples have been collected over this period under
the fixed interval monitoring program. Of these, 76 samples (or 53.1%) exceeded the 400
cfu/100mL State standard. Exceedances tended to be more frequent under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

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

11.4.1.2 Steele Creek Watershed

Fixed interval stream data for fecal coliform were collected at the CMSWS monitoring site
MC47A on Steele Creek. A summary of the data collected from January 2007 through July 2017
is provided in Figure 11-3. A total of 143 samples have been collected over this period under
the fixed interval monitoring program. Of these, 76 samples (or 53.1%) exceeded the 400
cfu/100mL State standard. Exceedances tended to be more frequent under wet weather
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influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.

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

11.4.1.3 Sugar/Irwin Creek Watershed

There are two fixed interval monitoring locations in the Sugar Creek watershed, MC27 in
southern Mecklenburg County, and MC22A on Irwin Creek just before its confluence with Sugar
Creek. An assessment of available watershed and water quality data was conducted utilizing
fixed interval stream data for fecal coliform collected at these two monitoring locations. A
summary of the data collected from January 2007 through July 2017 is provided in Figures 11-4
and 11-5.

A total of 143 samples have been collected at MC27 over this period under the fixed interval
monitoring program. Of these, 64 samples (or 44.8%) exceeded the 400 cfu/100mL State
standard. Exceedances tended to be more frequent under wet weather influenced sampling
conditions (meaning some precipitation within the County in the 72-hour preceding the sampling
event), however exceedances did occur under both ambient and wet weather influenced
conditions.

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

During the same period, a total of 146 samples were collected at MC22A under the fixed interval
monitoring program. Of these, 73 samples (or 51.0%) exceeded the 400 cfu/100mL State
standard. Exceedances tended to be more frequent under wet weather influenced sampling
conditions (meaning some precipitation within the County in the 72-hour preceding the sampling
event), however, since 2008 there has been a decrease in the frequency of exceedances during
ambient conditions compared to 2006-2007 (Figure 11-5).

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

11.4.1.4 Little Sugar Creek Watershed

There are two monitoring locations on Little Sugar Creek, MC49A in southern Mecklenburg
County just outside the City, and MC29A-1 just downstream of downtown area of the City. An
initial assessment of available watershed and water quality data was conducted utilizing fixed
interval stream data for fecal coliform collected at these two monitoring locations. A summary
of the data collected from January 2007 through July 2017 is provided in Figures 11-6 and 11-7.

A total of 146 samples have been collected at MC49A1 over this period under the fixed interval
monitoring program. Of these, 80 samples (or 55.9%) exceeded the 400 cfu/100mL State
standard. Exceedances tended to be more frequent under wet weather influenced sampling
conditions (meaning some precipitation within the County in the 72-hour preceding the sampling
event), however exceedances did occur under both ambient and wet weather influenced
conditions.

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

A total of 146 samples have been collected at MC49A1 over this period under the fixed interval
monitoring program. Of these, 120 samples (or 82.2%) exceeded the 400 cfu/100mL State
standard. Exceedances tended to be more frequent under wet weather influenced sampling
conditions (meaning some precipitation within the County in the 72-hour preceding the sampling
event), however exceedances did occur under both ambient and wet weather influenced
conditions.

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

11.4.1.5 McAlpine Creek Watershed

There are two monitoring locations on McAlpine Creek, MC45B just downstream of the NC/SC
border, and MC38 downstream of the confluence with Campbell Creek and Irvins Creek. An
initial assessment of available watershed and water quality data was conducted utilizing fixed
interval stream data for fecal coliform collected at these two monitoring locations. A summary
of the data collected from January 2007 through July 2017 is provided in Figures 11-8 and 11-9.

A total of 141 samples have been collected at MC45B over this period under the fixed interval
monitoring program. Of these, 43 samples (or 30.5%) exceeded the 400 cfu/100mL State
standard. Exceedances tended to be more frequent under wet weather influenced sampling
conditions (meaning some precipitation within the County in the 72-hour preceding the sampling
event), however exceedances did occur under both ambient and wet weather influenced
conditions.

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

A total of 144 samples have been collected at MC38 over this period under the fixed interval
monitoring program (Figure 11-9). Of these, 76 samples (or 52.8%) exceeded the 400
cfu/100mL State standard. Exceedances tended to be more frequent under wet weather
influenced sampling conditions (meaning some precipitation within the County in the 72-hour
preceding the sampling event), however exceedances did occur under both ambient and wet
weather influenced conditions.
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Figure 11-9: McAlpine Creek –MC38 - Overall Monitoring Data

11.4.1.6 Fecal Coliform Summary

The State standard for fecal coliform is exceeded by more than 10% for all watersheds with a
fecal coliform TMDL identified above, based on fixed interval data collected between 2006 and
2017. These exceedances are more common in wet weather influenced conditions but samples
collected during ambient conditions also exceed the standard by more than 10%, with the
exception of McAlpine Creek at monitoring point MC45B, where only 5% of samples collected
in ambient conditions exceed the standard.

11.4.2 Turbidity

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

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11.4.2.1 Long Creek Watershed

An initial assessment of available watershed and water quality data was conducted utilizing
stream data for turbidity collected at the CMSWS monitoring site MC14A on Long Creek. A
summary of the data collected from July 2006 through July 2017 is provided in Figure 11-10.
One hundred and thirty (130) samples were collected during this period, with 24 samples
exceeding the 50 NTU State standard. These exceedances all occurred under wet weather
influenced conditions.

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

11.4.3 Dissolved Oxygen

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

Unlike the other parameters, for dissolved oxygen the State standard is violated when
concentrations go below the standard rather than exceeding the standard. Based on the fixed
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interval sampling conducted between July 2006 and July 2017, there have been no violations of
the instantaneous State standard of 4 mg/L in any of the DO TMDL watersheds. The 2012 NC
Integrated Report categorizes each of these watersheds as 1t for DO, meaning that they have a
TMDL but are not impaired and are supporting their designated uses.

Figure 11-11: Irwin Creek–MC22A - Overall Monitoring Data
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Figure 11-12: McAlpine Creek –MC45B - Overall Monitoring Data

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

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

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

11.4.5 Mercury

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

11.5 Monitoring Plan for Assigned MS4 NPDES Regulated Waste Load Allocation

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

11.6 Identification of Additional Measures

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

11.7 Implementation of Additional Measures

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

11.8 Tracking Incremental Success

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

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11.9 Measurable Goals

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Table 11-4: TMDL Program Summary for FY2017
TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Public Education and Outreach
Utility bill inserts 194,080 82,313 401,699 109,784 424,231 14,597 61,613 79,570
Environmental notices and brochures distributed 181
Media advertisements (TV and radio) 800
Pet waste messages 916
Pet waste receptacles 100
Website inquiries 183,759

Social media posts 977
Social media responses 496
Public requests to hotline 7,509
CMCSI education workshops conducted 3
Citizens educated at CMCSI workshops 383
Public events 28
Attendees at public events 4,025
Public presentations 19
Citizens educated at public presentations 1,111
School presentations 1 01. 3 01. 1 01. 4 1
Students educated 40 01. 425 01. 18 01. 127 83
Fats Oils & Grease (FOG) brochures distributed 1,980
FOG presentations 15
Citizens educated on FOG program 1,046
Public Education and Outreach
Storm drains marked 467 01. 739 14 519 01. 25 40
Adopt-A-Stream trash removed (lbs.) 1830 01. 13410 300 2297 01. 1010 1000
Adopt-A-Stream miles cleaned 8.87 01. 27.59 2 14.35 01. 3.46 2.94
Big Spring Clean trash removed (lbs.) 1084 1040 1130 01. 01. 01. 01. 01.
Big Spring Clean stream miles cleaned 4 3 2 01. 01. 01. 01. 01.
Volunteer Monitoring samples 01. 01. 1 01. 9 01. 01. 01.
Trees planted 15,322
Adopt-A-Street bags of trash collected 1,891
1. Activity not conducted in this watershed during fiscal year 2017.
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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Illicit Discharge Detection and Elimination (IDDE)
Stream walk miles inspected 01. 01. 24 80 1 01. 01. 1
Stream walk outfalls inspected 01. 01. 89 207 3 01. 01. 2
Dry weather flows detected 01. 01. 7 31 01. 01. 01. 2
Dry weather flows sampled 01. 01. 2 7 01. 01. 01. 01.
Stream walk IDDE problems detected/corrected 01. 1 01. 3 01. 01. 1 01.
Multi-family sewer system inspections 01. 01. 3 01. 2 01. 2 2
Multi-family sewer system O&M plans prepared 3 01. 1 1 2 01. 1 01.
Multi-family sewer system personnel trained 32
Stormwater pollution ordinance NOVs issued 27 3 22 8 38 01. 4 7
Stormwater pollution ordinance penalty enforcements
issued 1 01. 2 01. 4 01. 01. 01.
Septic system failures detected/corrected 1 4 3 4 10 01. 01. 2
Municipal employees trained on IDDE 1,157

Sanitary sewer ordinance NOVs issued 5
Sanitary sewer system pretreatment inspections 200
Sanitary sewer system FOG inspections 4,193
Sanitary sewer system miles cleaned 1,266
Sanitary sewer system ROW miles cleared 155
Sanitary sewer system miles re-lined 16
Sanitary sewer system manholes inspected 8,120
Sanitary sewer system lift stations maintained 82
Sanitary sewer system overflows corrected 189
IDEP business corridor inspections 44
IDEP outfall inspections 01. 01. 01. 01. 1 01. 7 01.
IDEP problems detected/corrected 01. 01. 4 01. 4 01. 1 01.
IDEP fecal sampled collected 1 1 1 01. 1 01. 13 01.
Citizen service requests responded to 33 4 83 38 68 2 16 29
1. Activity not conducted in this watershed during fiscal year 2017.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Construction Site Stormwater Runoff Control
Erosion control ordinance NOVs issued 6 2 2 01. 8 1 1 2
Erosion control ordinance penalty enforcements issued 2 4 1 01. 1 01. 01. 3
Project/site plans reviewed 128 33 12 58 39 8 79 69
Sites inspected 288 258 76 166 236 30 131 182
Post-Construction Stormwater Management
Post-Construction ordinance NOVs and CARs issued 404
Post-Construction education workshops conducted 1 Citizens educated at Post-Construction workshops 231
Project/site plans reviewed 145
Buffer protected/added (acres) 72
Buffer mitigation plans approved 1 01. 01. 01. 2 01. 01. 4
SCMs added 8 6 12 12 10 1 1 9
SCMs inspected 70 26 61 70 125 2 70 137
Pollution Prevention/Good Housekeeping
City facilities inspected 10 1 8 2 8 1 1 8
Stormwater pollution prevention plans implemented 10 01. 8 01. 2 01. 01. 5
Spill prevention response plans implemented 10 01. 8 01. 2 01. 01. 5
Catch basin tops cleaned (manual or vacuum) 102,786
Catch basins cleaned (manual or vacuum) 2,616
Street sweeping (miles swept) 19,280
Street sweeping debris/ROW trash removed (tons)2. 3,076
Yard waste collected (tons) 56,207 City street ROW dead animal removal (tons) 15
1. Activity not conducted in this watershed during fiscal year 2017.
2. Tonnage includes debris/trash picked up from street sweepers and street
ROW debris/trash collected by hand.

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TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar
Industrial Facilities
Industrial facilities inspected 9 01. 1 5 01. 01. 4 3
Vehicle maintenance facilities inspected 9 01. 01. 01. 01. 01. 01. 01.
Industrial facilities monitored 1 01. 01. 1 01. 01. 01. 1
Illicit discharges or connections detected/corrected 4 01. 01. 1 01. 01. 1 01.
Water Quality Monitoring
Fixed interval TSS samples collected 13 22 52 13 65 13 13 26
Fixed interval Turbidity samples collected 13 22 52 13 65 13 13 26
Fixed interval Dissolved Oxygen samples collected 11 21 45 12 57 12 12 24
Fixed interval Fecal Coliform samples collected 14 23 55 14 69 14 14 28
CMANN Turbidity samples collected2. 7,891 6,929 33,537 5,916 24,359 6,340 8,673 8,997
CMANN Dissolved Oxygen samples collected2. 7,844 5,782 49,998 7,061 42,034 7,850 11,056 14,774
Action/watch level follow-up investigations conducted3. 01. 1 5 1 3 01. 3 3
1. Activity not conducted in this watershed during fiscal year 2017.
2. CMANN is an automated monitoring network that collects data readings typically once per hour (select sites collect readings every 15 min.). Data reported is QA/QC accepted data only.
3. Includes Fixed Interval and CMANN program investigations.

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