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City of Charlotte NPDES MS4 Permit Program

Stormwater Management Program Plan

FY2018 Annual Report

Permit Number NCS000240

September 2018

City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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...... 64

Section 7 Post-Construction Stormwater Management Program ...... 70

Section 8 Pollution Prevention/Good Housekeeping Program...... 76

Section 9 Industrial Facilities Evaluation and Monitoring Program ...... 92

Section 10 Water Quality Assessment and Monitoring Program ...... 103

Section 11 Total Maximum Daily Load (TMDL) Program ...... 119

Acronyms Used In This Document:

BMP: Best Management Practice CAR: Corrective Action Request CATS: Charlotte Area Transit System CDOT: Charlotte Department of Transportation CFD: Charlotte Fire Department CITY: City of Charlotte CMANN: Continuous Monitoring Alert Notification Network CMCSI: Charlotte-Mecklenburg Certified Site Inspector CMPD: Charlotte-Mecklenburg Police Department CMSWS: Charlotte-Mecklenburg Storm Water Services CW: Charlotte Water Department (formerly Charlotte-Mecklenburg Utilities) DEMLR: Division of Energy, Mining, and Land Resources DO: Dissolved Oxygen DWF: Dry Weather Flow DWQ: Division of Water Quality EPM-SWS: Engineering and Property Management Dept.-Storm Water Services Division EPM-LD: Engineering and Property Management Dept.-Land Development Division ETJ: Extra Territorial Jurisdiction

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FY: Fiscal Year GIS: Geographic Information System HDD: Horizontal Directional Drilling IDDE: Illicit Discharge Detection and Elimination IDEP: Illicit Discharge Elimination Program MEP: Maximum Extent Practicable MS4: Municipal Separate Storm Sewer System MST: Microbial Source Tracking NCDEQ: 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

ii City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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. The City submitted an application for permit renewal on August 28, 2017 and is currently awaiting issuance of a new permit by the North Carolina Department of Environmental Quality (NCDEQ). Per permit regulations, the term of the current permit is extended past the expiration date of February 28, 2018 if an application for permit renewal has been submitted to NCDEQ; therefore, the City continues to operate under the current permit until such time as a new permit is issued.

This document provides the Annual Report for the Stormwater Management Program Plan (SWMP) for FY2018 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 FY2018 (July 1, 2017 to June 30, 2018) 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 MS4 permit programs for the jurisdictions in Mecklenburg County adjacent to the City where appropriate and feasible. This coordination is conducted to help ensure uniformity between the local NPDES MS4 stormwater permit programs and jurisdictions. Mecklenburg County stormwater staff along with 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 Surface Water Quality and Environmental Permitting Program Manager, is responsible for the fulfillment of most of the activities discussed in this SWMP. Exceptions to this include the City’s Engineering and Property Management Department-Land Development Division (EPM-LD), which is the primary agency responsible

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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 local stormwater utility fees, except where noted. The City’s SWMP includes the following core permit programs:

1. Public Education and Outreach Program – This program provides the 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

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maintenance activities to ensure that treatment practices are properly operated and maintained.

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

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

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

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

Section 2: Background Information

2.1 Population Served

The SWMP covers the jurisdictional area, including the incorporated area and extra territorial jurisdiction (ETJ), for the City, as applicable and defined by the NPDES MS4 permit. Table 2-1 provides the population for the City based on the 2000 and 2010 US census. This census data was obtained from the following website of the US Census Bureau: https://www.census.gov/quickfacts/table/PST045216/3712000,00

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Table 2-1: Population and Growth Rate for the City of Charlotte. 2017 Population 2010 Population 2000 Population Average Annual Percent (est.) Change (2010-2017) 859,035 731,424 540,828 2.5%

2.2 Growth Rate

Table 2-1 shows the population growth rate represented as an “Average Annual Percent Change” for the City. This growth rate was calculated by dividing the overall percent change between the 2010 and 2017 population by the 7-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 6,659 outfalls, 3,775 miles of storm drain pipe and 195,173 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.

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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.

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 (2018).

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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 1 2 3 4 5 Position Describe target Describe the target pollutants and target pollutant X X X X X Water Quality pollutants and sources the permittee’s public education program is Program target pollutant designed to address and why they are an issue. Manager sources Describe target Describe the target audiences likely to have X X X X X Water Quality audiences significant stormwater impacts and why they were Program selected. Manager Informational Web The permittee shall promote and maintain an X X X X X Water Quality Site internet web site designed to convey the program’s Program message. Manager Distribute public Distribute general stormwater educational material to X X X X X Water Quality education materials appropriate target groups as likely to have a Program to identified user significant stormwater impact. Instead of developing Manager groups. its own materials, the permittee may rely on state- supplied Public Education and Outreach materials, as available, when implementing its own program. Promote and Promote and maintain a stormwater hotline/helpline. X X X X X Water Quality maintain Program Hotline/Help line Manager Implement a Public The permittee’s outreach program, including those X X X X X Water Quality Education and elements implemented locally or through a Program Outreach Program. cooperative agreement, shall include a combination Manager 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.

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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 Pollution Source Issue Pollutant Bacteria Improper Waste Disposal Improper handling and disposal of wastes can result in the discharge Sanitary Sewer Overflows of a variety of pollutants to the storm drainage system, causing Pet Waste 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 Improper erosion control practices at construction sites can result in Stream Bank Erosion sediment discharges to the storm drainage system. In addition, uncontrolled volumes of stormwater runoff can cause scouring of stream banks resulting in increased sediment volumes in streams.

3.3 Target Audience

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

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

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

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

School-aged Children: Children are very important when it comes to protecting surface waters. They play in creeks and lakes and, therefore, want to protect them. They bring home what they

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learn and encourage their parents to adopt positive behaviors for protecting water quality. Lessons about surface water quality and stormwater pollution often fit into and enhance science learning principles required by school curricula. Also, teaching children instills a sense of responsibility for the environment that can carry forward and grow into their adult lives. For these reasons, the City’s public education program focuses significant resources on teaching students at various grade levels.

During spring 2018, a targeted Scoop the Poop campaign was launched by CMSWS in an effort to combat increasing fecal coliform counts in local creeks. This targeted program flagged 1,400 deposits of dog waste in seven area parks in order to raise awareness about the potential water quality impacts of not cleaning up after your pet. The campaign also received local media coverage which helped to raise awareness.

The City is also exploring ways to educate an even more diverse representation of our population. A research and strategizing phase is underway to establish priorities and determine effective methods for sharing water quality messages with various audiences and getting more of them involved in volunteering and advocating for protection of water resources.

3.4 Stormwater Public Education and Outreach Program

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

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

3.4.1 Mass Media

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

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

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Media channels utilized to promote events and messages consisted of television, radio, website, and print advertisements. A total of 636 television ads ran on local stations WSOC, WJZY, and WTVI. In addition, 95 radio ads ran on WFAE 90.7 FM. CMSWS also worked with WJZY TV to produce “Ask the Pros” segments that focused on “Reporting Pollution” and “Volunteering.” WSOC TV produced “Rainy Day” segments that covered “Flood Safety.” These segments are considered “Added Value” segments as they provided additional media impressions at no additional cost.

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

 Vehicle wraps;  A parking garage banner;  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 used by CMSWS are shown in Table 3-3.

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

CMSWS posted various videos and news stories on 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 6834 Facebook followers, a 14% increase from last fiscal year. There are 511 Instagram followers, a 26% increase from last fiscal year. There are 971 Twitter followers, a 23% increase from last year. There are 37 subscribers to our YouTube page, a 23% increase from last fiscal year. Figure 3-1 shows a typical Facebook post.

CMSWS provided the public with a mobile application Figure 3-1: Typical Facebook post called “Water Watchers” to report pollution. There were 73

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downloads of the application during FY2018, making for a total of 1719 downloads since the application was launched during FY2013. This past year, there were 46 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 Figure 3-2: Typical Parking from a popular exit ramp off I-277 (Figure 3-2). Garage Banner

3.4.3 Public Hotline

The City, in cooperation with Mecklenburg County, operates a joint customer service hotline to receive information about a variety of concerns. Citizens can dial 311 to report pollution, flooding, and blockages to the drainage system as well as request other City/County services. The 311 call center is staffed and open Monday through Friday from 7 am to 7 pm to receive calls. Citizens can also submit requests for service to 311 on-line anytime (24/7/365). The City promotes this hotline throughout all of the activities provided as part of the Stormwater Public Education and Outreach Program.

During this past fiscal year, a total of 8,329 calls were received by 311 and referred to EPM- SWS and/or CMSWS. Out of this total number, 519 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 57% of all calls, which was 40% higher than from any other audience. This is important information for targeting education campaigns related to pollution reporting. Table 3-4 provides information about the number and type of callers that reported these issues.

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Table 3-4: FY2018 Service Request Source Summary Caller Type Number of Service Requests* Public Citizen 296 Business 14 Charlotte Fire Department staff 24 Charlotte-Mecklenburg Police Department staff 2 Charlotte Storm Water Services staff 38 Charlotte Water staff 36 Mecklenburg County Storm Water Services staff 86 State – NCDEQ staff 9 Environmental Protection Agency 1 Other 13 TOTAL 519 * Source summary data includes all types of service requests within the City jurisdiction

An additional unique outreach tool for publicizing pollution reporting was the design and implementation of three vehicle wraps (Figure 3-3). These vehicle wraps have been placed on three CMSWS vehicles and each addressed a different subject – storm drains lead to streams, smelly and discolored streams, and mud pollution. In addition to informing and educating, these wraps encourage residents to recognize and report pollution by calling 311. The vehicle wraps were completed toward the end Figure 3-3: Vehicle Wrap on a CMSWS vehicle 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 FY2018, CMSWS staff provided 63 school presentations to 2070 students, grades K-12, at 20 different schools. There were seven different programs available to the

schools which included:

 Blue Planet;  Common Water;  Freddie the Fish;  Enviroscape Model and Video;  CMANN Demo and Power Point;

Figure 3-4: Enviroscape Model Presentation 13 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Festival Table Demonstrations; and  Career Day.

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

3.4.5 Public Presentations and Workshops

A variety of water quality presentations and workshops were available from CMSWS to the 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 3-5 shows the public presentations that were provided by CMSWS during FY2018.

Table 3-5: FY2018 Public Presentations and Workshops Date Event Name Number of Attendees 07/18/17 Greater Charlotte Apartment Association Green Committee 50 07/19/17 County Career Exploration 120 08/15/17 Greater Charlotte Apartment Association Green Committee 10 09/23/17 Volunteer Monitoring Training 28 11/01/17 Aquatic Pesticides and SCM Maintenance 104 11/30/17 Post Construction Stormwater Ordinance Training 120 02/10/18 Catawba River Keeper Urban Stream Workshop 35 03/13/18 Apartment Managers & Maintenance staff 20 03/15/18 Engagement Café 30 03/16/18 Girl Scout Troop 1782 35 03/20/18 Webelos Cub Scout Pack 3 41 04/07/18 Volunteer Monitoring Training 17 04/26/18 Greater Charlotte Apartment Association Maintenance Staff 20 05/10/18 Master Naturalist 20 05/15/18 Camp Green Neighborhood Association 20 05/24/18 Master Naturalist 20 TOTAL 690

3.4.6 Public Events

CMSWS staff participated in a variety of community events that were used to promote education campaigns, give away promotional products, provide face-to-face education opportunities, and provide formal presentations on water quality topics when appropriate. Table 3-6 shows the public event participation during FY2018.

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Table 3-6: FY2018 Public Event Participation Date Conducted Event Name Number of Attendees Interacted With 07/22/17 Girl Scout Service Unit Kick-off 70 08/19/17 Hummingbird Festival 200 City of Charlotte's 2017 Neighborhood 09/23/17 100 Exchange & Leadership Awards (NEXLA) 09/29/17 Catawba River STEM Festival 300 10/03/17 Meet & Eat CLTMeckGov 97 10/10/17 Meet & Eat CLTMeckGov 75 10/12/17 Meet & Eat CLTMeckGov 70 10/15/17 Open Streets 250 10/17/17 Meet & Eat CLTMeckGov 51 10/24/17 Meet & Eat CLTMeckGov 100 10/25/17 MoRa Community Meeting 25 10/30/17 Meet & Eat CLTMeckGov 100 11/09/17 Air Quality Annual Forum 50 01/23/18 Carolina Green Network 150 02/02/18 CMGC Employees – First Friday 50 02/08/18 to 02/11/18 Mid-Atlantic Boat Show 250 02/17/18 Soil & Water Conservations District Tree Sale 25 Game for Volunteer 03/09/18 500 Appreciation Night 03/31/18 Weenie Walk 100 04/06/18 CMGC First Friday Environmental Fair 20 04/11/18 Waggle For Your Beer 30 04/14/18 Matthews Earth Day 100 04/14/18 CMPD Rabies/Microchip Event 50 04/17/18 Charlotte Career Discovery Day 150 04/18/18 Waggle For Your Beer 30 04/18/18 UNCC Earth Day 75 04/20/18 Ballantyne Earth Day 75 04/20/18 CMGC GovPorch Earth Day 50 04/21/18 Pet Palooza 250 04/23/18 Food Fair w/Health Dept. 20 04/29/18 Open Streets 704 350 05/12/18 Discovery Place Takeover 181 05/26/18 Mint Hill Madness Parade 300 TOTAL 4,244

3.4.7 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

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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 FY2018 was 275,595; 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 108,352.

Figure 3-5: CMSWS Main Webpage

3.4.8 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:

Figure 3-6: Example of a brochure distributed as part of Citizen Requests for Service and at public events

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 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  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)

3.4.8.1 Promotional Items

Promotional items were designed and distributed to complement outreach activities such as group presentations, workshops and public events. All promotional items have the CMSWS website and include other messages as space allows. Table 3-7 shows the promotional items distributed during FY2018.

Table 3-7: FY2018 Promotional Items Promotional Item Message Dog waste bags Scoop the Poop Insulated, stainless steel water bottles Report water pollution, volunteer Wildflower seed bookmark Soil test, reduce fertilizer use Stormy tattoos and stickers “Stormy” the mascot branding Sunscreen Stormwater.Charmeck.org

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Promotional Item Message Golf towels Stormwater.Charmeck.org Boat whistles Stormwater.Charmeck.org

3.4.8.2 Utility Bill Inserts

During FY2018, CMSWS included utility bill inserts in four 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 FY2018 was 1,329,196. Figure 3-7 shows a typical utility bill insert that was mailed.

Figure 3-7: June 2018 Utility Bill Insert

3.4.9 Regional Stormwater Partnership

The City serves on the Executive Committee of the Regional Stormwater Partnership of the Carolinas (RSPC); a partnership which includes municipalities throughout the region that are interested in collaborating on education and outreach initiatives to meet NPDES stormwater permit requirements. Formed in 2006 and originally comprised of professionals from six municipalities in the Charlotte metropolitan area, the RSPC was developed as a forum for stormwater professionals to work collaboratively on local stormwater issues. The RSPC provides an opportunity to leverage limited resources to fulfill common needs of the partners. During FY2018 the RSPC’s media campaign ran advertisements on WFAE, WCCB and MeTV; these advertisements had 4,296,900 impressions.

3.5 Measurable Goals/Planned Activities for Future Program Years

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

18 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Table 3-8: BMP Measurable Goals for the Public Education and Outreach Program. BMP BMP Description Measurable Goals (by permit term year) 1 2 3 4 5+ Describe target Describe the target pollutants and target Identify target Review and update target pollution sources as necessary. (On-going, years 2 – 5+) pollutants and target pollutant sources the permittee’s public pollution sources pollutant sources education program is designed to address utilizing and why they are an issue. monitoring and service request data Describe target Describe the target audiences likely to Identify target Review and update target audiences as necessary. (On-going, years 2 – 5+) audiences have significant stormwater impacts and audiences to adopt why they were selected. desired water quality improvement behaviors Informational Web The permittee shall promote and Continue to maintain an informational website to provide program information to the public. (On-going, Site maintain an internet web site designed to years 1 – 5+) convey the program’s message. Distribute public Distribute general stormwater educational Distribute educational materials at public events, workshops and presentations. (On-going, years 1 – 5+) education materials to material to appropriate target groups as identified user groups. 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. Promote and maintain Promote and maintain a stormwater Maintain a hotline that receives information from the public 24 hours a day. (On-going, years 1 – 5+) Hotline/Help line hotline/helpline. Implement a Public The permittee’s outreach program, Continue to implement a plan to conduct education & outreach activities, including a media campaign, that Education and including those elements implemented address target pollutants and audiences. (On-going, years 1 – 5+) Outreach Program. 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.

19 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

3.6 Program Assessment

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

Table 3-9: Program Summary PUBLIC EDUCATION PROGRAM FY2013 FY2014 FY2015 FY2016 FY2017 FY2018 Utility bill inserts 3,300,000 2,913,000 2,916,000 1,707,629 1,785,000 1,329,196 Public events 9 15 14 18 28 35 Attendees at public events 1,335 2,884 2,683 13,514 4,025 4,394 Public presentations 2 7 11 15 19 16 Citizens educated at public presentations 473 254 737 559 1,111 720 School presentations 54 56 61 56 80 63 Students educated at school presentations 1,402 1,421 1,510 1,330 2,097 2,070 Website page views 99,958 149,786 274,129 288,432 183,759 275,595 Social Media Followers/Subscribers1. N/A N/A 1,0002. 3,9002. 7,206 8,353 TV and radio advertising spots 492 1,977 3,761 1,146 800 731 Public requests to hotline 2,576 3,262 2,429 3,127 7,509 8,329 1. Includes Facebook, Instagram, Twitter, and YouTube follower data for FY2017 and FY2018. 2. Includes only Facebook follower data for the fiscal year.

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

Utility Bill Inserts: During FY2018, the decrease in numbers from FY2017 reflects the decrease in the frequency at which utility bill inserts were distributed.

Public Events & Public Presentations: The number of events and presentations during FY2018 increased.

School Presentations: The number of school presentations decreased while the number of students educated remained in line with FY2017.

Website Page views: The number of website page views increased by 50% during FY2018.

20 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Social Media: The number of followers and subscribers to CMSWS social media channels increased during FY2018.

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 1 2 3 4 5 Position Volunteer The permittee shall include and promote volunteer X X X X X Water Quality community opportunities designed to promote ongoing citizen Program involvement participation. Manager program Establish a The permittee shall provide and promote a mechanism X X X X X Stormwater Mechanism for public involvement that provides for input on Division for Public stormwater issues and the stormwater program. Manager involvement Establish The permittee shall promote and maintain a X X X X X Water Quality Hotline/Help line hotline/helpline for the purpose of public involvement Program and participation. Manager Public Review The permittee shall make copies of their most recent X X X X X Water Quality and Comment Stormwater Plans available for public review and Program comment. Manager Public Notice Pursuant to 122.34 the permittee must, at a minimum, X X X X X Water Quality comply with State, Tribal and local public notice Program requirements when implementing a public Manager involvement/ participation program.

21 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

4.2 Volunteer Involvement Program

4.2.1 Target Audience

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

4.2.2 Storm Drain Marking Program

CMSWS continued to provide volunteers the opportunity to help educate their community about stormwater pollution through the Storm Drain Marking program. This program enabled volunteers to adhere vinyl printed markers (Figure 4-1) to storm drains along streets they had selected in their Figure 4-1: Storm Drain Marker 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 2,590 storm drains were marked by 246 volunteers for a combined total of 635 volunteer hours for this program. Storm Drain Marking activities are tracked in order to help determine programmatic gaps and where resources should be focused. Figure 4-2 shows Storm Drain Marking activities conducted during FY2018. 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.

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.

22 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 FY2018, a total of 111 groups of volunteers completed 196 stream cleanups under the Adopt-A-Stream Program in the City. A total of 2,441 volunteers dedicated 5,811 hours to picking up trash and reporting pollution in Charlotte-Mecklenburg streams. In addition, volunteers removed approximately 26.6 tons of trash and debris. Adopt-A-Stream activities are tracked in order to help determine programmatic gaps and where resources should be focused. Figure 4-3 shows Adopt-A-Stream activities conducted during FY2018 and Table 4-3 provides a summary of important results relating to the program.

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23 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 4-2

24 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 4-3

25 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

4.2.4 The Big Spring Clean

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

During FY2018, a total of 210 volunteers dedicated 810 hours to participating in the event and removed seven tons of trash from local waterways at seven locations throughout the City. Figure 4-4 shows the promotional information used for the event.

Figure 4-4: Big Spring Clean advertisement

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, macro invertebrate identification, and stream habitat, and can also compare data with other volunteer monitoring groups (Figure 4-5).

Although CMSWS has historically supported volunteer monitoring programs in the schools, this Figure 4-5: Volunteer Monitoring Workshop attendees learning sampling techniques 26 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

was only the second year that a significant effort has been put forth to develop and promote an actual citizen volunteer monitoring program. During FY2018, two Volunteer Monitoring Workshops trained 44 attendees and a total of 125 trained volunteers dedicated 250 hours to participating in the Volunteer Monitoring program. Table 4-3 provides a summary of important results relating to the program.

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;  Appeals;  Stormwater program policies;  Long-range plans; and  Budgets.

These reviews assisted CMSWS in making recommendations and offering comments to the City Council and the Board of County Commissioners on program matters and annual budgets. The committee also 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, operates a joint customer service hotline to receive information about a variety of concerns. Citizens can dial 311 to report pollution, flooding, and blockages to the drainage system as well as request other City/County services. The 311 call center is staffed and open Monday through Friday from 7 am to 7 pm to receive calls. Citizens can also submit requests for service to 311 on-line anytime (24/7/365). The City promotes this hotline throughout all of the activities provided as part of the Stormwater Public Education and Outreach Program. The hotline/help line is discussed further in sub-section 3.4.3 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. During FY2018, CMSWS also submitted an application for renewal of the City’s NPDES MS4 permit. This application and associated

27 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Stormwater Management Report was placed on the CMSWS website and a public notice was published in the newspaper to notify the public of the opportunity to provide comments on these documents.

4.6 Public Notice

A public notice was published in the main local newspaper concerning the City’s MS4 permit renewal application. The application was placed on the CMSWS website and made available for review. No comments were received by the City.

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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28 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 The permittee shall include and Continue to maintain a public involvement and participation program that outlines campaigns and tools to community promote volunteer opportunities encourage public involvement. (On-going, years 1 – 5+) involvement designed to promote ongoing citizen program participation.

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

29 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 89 125 119 297 246 Storm Drain Marking volunteer hours 668 216 198 286 624 635 Storm drains marked 1,663 956 983 927 2,646 2,590 SWAC meetings conducted 8 9 10 10 12 11 Persons attending SWAC meetings 76 88 82 96 109 92 Adopt-A-Stream groups 81 84 64 67 95 111 Stream clean-ups conducted 128 141 98 106 155 196 Adopt-A-Stream volunteers 1,540 1,983 1,211 1,280 1,928 2,441 Adopt-A-Stream volunteer hours 3,556 5,324 2,514 2,736 4,516 5,811 Adopt-A-Stream trash removed (Tons) 9 16 9.6 14.9 13.8 26.6 Big Spring Clean volunteers N/A N/A N/A 265 199 210 Big Spring Clean volunteer hours N/A N/A N/A 928 796 810 Big Spring Clean trash removed (Tons) N/A N/A N/A 9.4 2.7 7 Volunteer Monitoring participants N/A 122 97 619 222 125 Volunteer Monitoring participant hours N/A 7,076 194 773 654 250

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 and storm drains marked remained steady during FY2018;

 Adopt-A-Stream Program – The number of groups participating increased from FY2017 to FY2018. One-time stream clean-ups are becoming more popular with groups verses conducting two clean-ups per year, which has traditionally been required;

 Big Spring Clean – The number of volunteers for the Big Spring Clean increased slightly during FY2018;

30 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Volunteer Monitoring Program – The number of volunteer monitoring participants and hours decreased during FY2018. Volunteer monitoring has typically been focused in the schools and this was only the second 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.

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 1 2 3 4 5 Position Maintain Maintain adequate ordinances or other legal X X X X X Water Quality appropriate legal authorities to prohibit illicit connections and Program authorities discharges and enforce the approved IDDE Program. Manager Maintain a Storm The permittee shall maintain a current map showing X X X X X Water Quality Sewer System Base major outfalls and receiving streams. Program Map Manager Inspection / Maintain written procedures and/or Standard X X X X X Water Quality detection program Operating Procedures (SOPs) for detecting and Program to detect dry tracing the sources of illicit discharges and for Manager weather flows at removing the sources or reporting the sources to the MS4 outfalls 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

31 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

targeted for inspections. Employee Training Conduct training for appropriate municipal staff on X X X X X Water Quality detecting and reporting illicit connections and Program discharges. Manager Maintain a public Maintain and publicize reporting mechanism for the X X X X X Water Quality reporting public to report illicit connections and discharges. Program mechanism Establish citizen request response procedures. Manager Documentation The permittee shall document the date of X X X X X Water Quality investigations, any enforcement action(s) or Program remediation that occurred. Manager

5.2 Ordinance Administration and Enforcement

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

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

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

Cumulatively from FY1995 through FY2018, a total of 1,206 violations of the ordinance have been discovered resulting in the issuance of an NOV. Historically, the majority of these violations have occurred under Section 18-80(a) with many of these being either for the improper disposal of wash water or wastewater, or the illicit discharge of sewage.

During FY2018, a total of 117 violations of the ordinance were discovered resulting in the issuance of an NOV. Of these, 13 also resulted in the issuance of a civil penalty assessment to the violator. The number of violations observed for each ordinance section was:

 Section 18-80(a) Illicit Discharges and Disposals (112);  Section 18-80(b) Illicit Connections (4);  Section 18-80(c) Accidental Discharges (1); and  Section 18-80(d) Obstruction (0).

The violations are further categorized based on the type of material discharged. During FY2018 the number of violations discovered per material category was:

32 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Sediment (1)  Paint (1)  Drilling Slurry (5)  Trash (1)  Concrete wash (9)  Motor oil (15)  Wash water (6)  Heating oil (2)  Wastewater (4)  Gasoline (1)  Process water (12)  Chemicals (1)  Private sewage SSO (41)  Pool Discharges (1)  Food waste/grease (12)  Animal waste (1)

Figure 5-1 shows the graphical representation of these material categories for which NOVs were issued, and Figure 5-2 shows the number of NOVs issued per month during FY2018.

Figure 5-1: NOVs issued by material category.

33 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Figure 5-2: NOVs issued per month.

5.3 Stormwater System Inventory and Storm System Base Map

The City collects stormwater system inventory 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. All Stream Walk Program data is transferred to the City’s Inventory Program annually.

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

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

The analysis led to changes in protocol to develop the new five-year stream walk plan that groups the sub-basins by watershed in both the City and Mecklenburg County. The same

34 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

number of miles will be walked each year as previously, but the plan will also allow for a 20- mile per year reserve that can be used for walking in any basin(s) when the need is identified. Figure 5-3 shows the new five-year (FY2018 – FY2022) stream walk plan and Figure 5-4 shows the sub-basins that were walked during FY2018 within the Sugar Creek, Little Sugar Creek, Twelve Mile Creek, and Six Mile Creek watersheds.

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

During FY2018, the following activities were conducted as part of Stream Walk Program:

 Four watersheds (Sugar, Little Sugar, Twelve Mile, and Six Mile Creeks) and 24 sub- basins covering 199.10 stream miles were walked and assessed;  258 new outfalls were added to the inventory; and  117 previously inventoried outfalls received inventory QA/QC.

During FY2018, the following activities were conducted as part of the Inventory Program:

 21 square miles of the MS4 area were inventoried; and  321 municipal and new private development projects were analyzed for additional inventory.

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35 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-3

36 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-4

37 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 FY2018, the following Stream Walk activities occurred:

 375 outfalls were inspected;  114 DWFs were detected at outfalls and 87 of these were sampled;  347 fecal coliform and 24 total phosphorous samples were collected;  12 fecal coliform sample results that exceeded the program action limit were investigated; and  10 illicit discharges were detected and eliminated.

CMSWS staff also documented:

 32 stream blockages;  35 areas of severe stream bank erosion; and  6 potential stream reference reaches.

Hot Spot Investigations Hot Spot Investigations, a subset of the Illicit Discharge Elimination Program (IDEP), is a program where CMSWS staff conducts 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. These activities and additional activities conducted under IDEP are discussed in more detail in Section 5.4.3.

38 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

During FY2018, a section of Briar Creek was the target basin and the IDEP program inspected three minor outfalls (<36” in diameter) with one DWF detected.

In addition, during FY2018 CMSWS staff also inspected 80 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 60 minutes at monitoring sites for dissolved oxygen, temperature, pH, conductivity, and turbidity. This parameter data is transferred to a database in real-time using cellular telemetry. Figure 5-5 shows the monitoring locations for this program.

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

During FY2018, 30 follow-up investigations were conducted which resulted in the discovery of several water quality issues (water main breaks, elevated turbidity levels, etc.) and three illicit discharges.

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39 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-5

40 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

5.4.3 Illicit Discharge Elimination Program (IDEP)

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

 Hot Spot Investigations  Multi-Family Community Inspections  Business Corridor Runs  Industrywide Investigations  Pet Waste Flagging Campaign

Hot Spot Investigations includes inspection of outfalls and overland areas where analysis of monitoring and service request data indicates a priority area(s). In these instances, experienced IDEP staff investigate the stream, manholes and surrounding areas during ambient conditions (>72 hours since a measurable storm event). If staff observes DWFs at outfalls and in manholes, they then use visual and sensory cues and quick field tests (CHEMetrics K-1510 Ammonia test kit) to sample for the presence of wastewater. If the Ammonia level is >1.0 ppm, then staff track the DWF using fecal coliform sampling. Staff may also request smoke testing of sanitary systems, conduct dye testing, and monitor suspect facilities to investigate. A variety of investigation methods may be employed and IDDE protocol is used until the source is identified.

This year a sub-basin of the Briar Creek watershed was identified as the priority area or “Hot Spot”, but intensive investigations also occurred in the Irwin Creek and Little Sugar Creek watersheds. In the Briar Creek watershed, “sweet sewage smells” at 919 Colonade Drive led the team to use a variety of investigations methods and ultimately to an industrial facility that was issued an NOV for an illicit connection of sugar water into the storm drainage system. This facility will be inspected by the Industrial Inspection Program during FY2019. In the Irwin Creek Watershed, high bacteria levels in Stewart Creek (sub-basin of Irwin Creek) in past years have led to the identification and correction of several cross connections, but bacteria levels have remained high. This past year, the IDEP team used a number of investigation methods to survey and sample this area. These investigations led the team to request a pipe video inspection for approximately 5,800 feet of underground stormwater pipe system to be conducted during FY2019. In the Little Sugar Creek watershed, a new location for a CMANN monitoring station located at a major stormwater outfall draining downtown Charlotte, at 4th street, detected a number of intermittent flows during dry weather. This led to a number of follow-up investigations which did not determine an exact source. CMSWS is now evaluating if conducting an underground pipe video inspection would be a feasible next step.

Multi-Family Inspections are inspections of privately maintained multi-family residential sewer systems to look for signs of problems with the operation and maintenance of these systems. CMSWS inspectors open manholes and look for obvious overflows and signs of pipe blockages and/or previous problems (limed areas, toilet paper on ground, etc.). The communities selected were based upon their sewer overflow history and their location within a hot spot or priority

41 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

basin. During FY2018, twenty-two (22) multi-family inspections were conducted with no illicit discharges discovered.

Business Corridor Runs are windshield surveys conducted along streets throughout the City that have a high concentration of commercial businesses where illicit discharges and poor housekeeping are most commonly found. These surveys allow staff to quickly survey these business areas for practices such as dumping wastewater from mop buckets, mobile washers, oil discharges from automotive practices, and grease discharges at restaurants. Staff will also inspect storm drain inlets and outfalls when illicit discharges are suspected. Figure 5-6: An illicit discharge detected under the IDEP program

This past year, 2,548 businesses and 371 catch basins were inspected. Six illicit discharges were discovered and corrected with Notices of Violations issued. There were also eight Environmental Notices distributed for poor housekeeping practices. Figure 5-6 shows cooking grease overflowing from a restaurant grease bin discovered as a result of a Business Corridor Run.

Industry-wide Investigations includes staff focusing on a specific industry for inspections. This past fiscal year, the stone cutting industry was targeted. Staff gathered a list of 53 stone cutting businesses within the City, inspected 34 facilities, and found and corrected seven illicit discharges. This effort resulted in the issuance of seven NOVs and corresponding civil penalty assessments. Staff plans to inspect the remaining 19 facilities during FY2019 to complete this task.

The Pet Waste Flagging Campaign was a new activity conducted during FY2018 which used both IDEP and Education staff. The goal of the campaign was to reduce the amount of pet waste the public does not pick up and properly dispose. Greenways and parks known for pet waste problems were targeted. The campaign designed small flags (similar to those used to mark utilities) with messages of environmental and health risks that undisposed pet waste poses. Each week throughout April, staff visited these areas to mark pet waste with the flags. These activities were also combined with social media/on-line outreach, attendance at community events for pet owners, and interviews with local TV and on-line media. Staff deployed 1,400 pet waste flags and engaged with 64 residents during pet waste flagging. A number of media outlets featured stories about the campaign.

42 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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

Figure 5-7 shows the locations where IDEP activities occurred during FY2018 and Figure 5-8 shows the business corridors evaluated during FY2018.

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43 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-7

44 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-8

45 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

5.5 Employee IDDE Training and Education

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

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

Workshops involve attracting target audiences and providing training presentations about topics appropriate for their interests including stormwater BMPs. This training may also provide continuing education credits to attract its attendance. Staff also provides displays to interact with this audience one-on-one. The following workshops were attended by a number of people that were city staff and from private industry:

 Aquatic Pesticides and Stormwater BMP Workshop  Landscape Contractors Breakfast

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

The following staff presentations were provided this past year:

 EPM-SWS Construction Management Team - Seniors Inspectors and Supervisors  EPM-SWS construction inspectors staff meeting  Charlotte Water Department (CW) construction inspectors staff meeting  EPM-LD staff meeting

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

 Common illicit discharges in the community;  How to detect them when they enter surface water;  The importance of reporting them and the various ways they can report them as well as more in-depth pollution prevention information related to their facility and field work;

46 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Stormwater Pollution Prevention Plans;  Spill prevention and response (Figure 5-9);  Pollution prevention and the role of the employees to protect the environment and set an example for the community; and  Results from recent facility inspections

Presentations are given by CMSWS staff at all facilities except those owned by the Charlotte Area Transit System (CATS) and the Airport. Presentations provided by CMSWS and CATS were customized to reflect field work pollution prevention practices related to the audiences’ daily work, the most recent facility inspection and a three-minute Spill Response Video which covered the importance of spill response. Figure 5-9: Spill Response Video used for Training

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

The on-line training module provides a power point presentation and video that is very similar to the in-person training session, but allows field or shift-work staff to take it when it’s convenient for them.

Other methods used this past year to reach internal staff with messages of report pollution included attendance at various City staff events and a Stormy Contest.

During FY2018, EPM-SWS staff also attended a City employee First Friday of the Month event and an Earth Day event, both held in the lobby of the Charlotte-Mecklenburg Government Center. These events provided the opportunity to engage employees with a table-top display about stormwater pollution and reporting, distribute promotional products, and provide a hands- on activity.

During FY2018, the Stormy’s Report Pollution Contest was sponsored by EPM-SWS and entailed a month-long on-line contest for internal staff to win gift cards. Each week during the month of June, an image of CMSWS’ mascot, Stormy the Turtle, catching an illicit discharger in action was posted on internal e-mails and websites. These images linked to a Stormy website where a different illicit discharge was highlighted each week and a link to a weekly contest of questions was provided. The contest asked three questions about the information on the Stormy website for a chance to win a gift card. The contest was promoted with the four weekly images

47 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

on digital display boards in the Charlotte-Mecklenburg Government Center and Solid Waste Services buildings and four weekly city-wide e-newsletters and Engineering department emails (Figure 5-10).

During FY2018, a total of 1,670 employees were trained from the following Employee IDDE Training and Education activities:

 168 employees were trained with staff meeting presentations;  844 employees were trained with in-person training sessions;  223 employees were trained with on-line training modules;  90 employees were contacted during Earth Day and First Friday events; and  345 employees participated in the Stormy Contest.

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 Figure 5-10: Stormy Contest image education to certain commercial business sectors each year. highlights leaking grease bins.

During FY2018, CMSWS provided 15 two-page best practices publications and guidance documents for commercial sectors available on-line. CMSWS also distributed these publications as part of service requests, mailings, training sessions and public events. The following provides a complete list of the commercial sector publications that have been developed:

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

During FY2018, CMSWS provided additional outreach to the landscaping, concrete and paint, and food service sectors as follows:

48 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Landscape Contractors: During FY2018, outreach was provided to the landscaping sector through three events:

 Presentation and display at the City’s Landscape Contractor’s Breakfast (Figure 5-11);  Display at the Carolina Green Industry Network Landscaping Tradeshow; and Figure 5-11: Stormwater BMP presentation for the  Sponsorship of the second Aquatic Landscaper Contractor’s Breakfast 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 FY2018, 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 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 75 people.

The Carolina Green Industry Network Landscaping Trade Show is an annual event held in Union County attended by landscaping professionals from the region each year. During FY2018, 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 150 landscapers visited the display and interacted with staff.

The Aquatic Pesticides and Stormwater BMP Workshop was provided for a second year in a row through a partnership with Central Community College, Carolina Green Industry Network, the RSWP, NC State University (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, pond management, and stormwater BMP inspection and maintenance. The workshop was held on November 1, 2017 and attended by 104 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.

49 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Concrete and Paint Contractors: During FY2018, CMSWS staff implemented an outreach plan specific to concrete and paint contractors. After staff researched ways to reach these sectors directly, it was decided that outreach would focus on residents hiring these contractors or seeing them at construction sites.

During the month of June 2018, paint and concrete dumping was the theme for two of the weekly Stormy contests for City staff. A utility bill insert and social media posts were also used to reach residents.

A total of six concrete testing firms under contract by EPM-SWS were also contacted via direct mail due to issues observed at City projects.

: Food Service – Restaurants: Outreach to the food service sector included setting up a display at the Health Department’s Food Summit workshop where over 100 people from the food service sector attended. It also included outreach through the Stormy contest when images highlighting dumping mop water and leaking grease Figure 5-12: New Storm Drain Marker for Business Corridors bins to thousands of city staff.

In addition, a new storm drain marker was designed that focuses on the message, “No Dumping Mop Water” in English and Spanish (Figure 5-12). These new markers will be placed on catch basins near restaurants where dumping would likely occur as part of IDEP Business Corridor Runs next fiscal year.

5.5.2 Sanitary Sewer Overflows and Septic Systems

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

Sanitary Sewer Overflows: CW is the department responsible for operating the Municipal water supply and sanitary sewer systems in the City. During FY2018, there were 164 SSOs (total volume of 20,670,684 gallons) from the municipal sanitary sewer system. This is a decrease of 25% from FY2017. It is important to note that two overflows during FY2018 were caused by large trees falling and accounted for 97.98% (20,231,505 gallons) of the total volume spilled. Figure 5-13 summarizes the causes for these spills.

50 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

In addition, the number of spills per 100 miles of pipe system continued to show a steady decline. For example, during FY2007 there were 10.8 SSOs per 100 miles of pipe system compared to 3.8 SSOs per 100 miles during FY2018. This represents a 65% decrease over the 11-year time frame.

The City works to decrease SSOs in four main ways:

 Infrastructure maintenance and inspections;  Commercial/restaurant/ Figure 5-13: FY2018 SSOs by cause industrial inspections;  Multi-family residential outreach; and  The Grease Free education campaign.

Infrastructure maintenance and inspection: CW implements a number of infrastructure maintenance and inspection programs designed to reduce inflow and infiltration and sanitary sewer losses. During FY2018, the following was accomplished:

 15.75 miles of sanitary sewer pipe were relined;  8,906 sanitary sewer system manholes were inspected;  374 manholes were rehabilitated, repaired or replaced;  392 miles of sanitary sewer pipe were treated with root control chemicals;  1,051 miles of sanitary sewer pipe were cleaned (including some multiple cleanings at the same location);  513 service connections were replaced;  81 lift stations received preventative maintenance for a total of 2,676 work hours (not including station checks, wet well cleaning, generator testing and emergency/ routine repairs); and  107.6 miles of rights-of-way were cleared to maintain access to off-street sanitary wastewater pipes and to help prevent root intrusions.

51 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Commercial/restaurant/industrial inspections: During FY2018, CW performed the following activities:

 4,440 inspections of grease handling/ food service establishments occurred;  140 Notices of Deficiency (NOD) were sent to businesses of which 106 returned to compliance and 34 were still under investigation at the time of the CW fiscal year report.  5 NOVs were sent to businesses.  CW continued to provide educational information about proper disposal of pipe-blocking items (Flow Free education);  Inspectors mailed information to 1,236 customers near SSO sites and handed out information to 2,107 customers at multi-family communities.  5,783 adults and children received presentations from staff;  Staff continued to distribute door-hangers to maintenance personnel and property managers of multi-family communities.  More than 200 compliance inspections were conducted at facilities with wastewater pre- treatment permits (Significant Industrial Users);  261 permit violations were recorded at Significant Industrial User facilities and 44 of them were issued NOVs with civil penalties.

Multi-Family Residential Program: Since 2009, CMSWS has been working with CW to prevent SSOs by providing mailings, workshops and inspections for the multi-family residential sector. Each year, staff selects multi- family residential communities to receive a mailing that explains the ten state regulatory requirements for private sanitary sewer collection systems and the resources available from CMSWS and CW to comply. These multi-family communities are selected based on monitoring data such as surface water quality and the locations of SSOs and related service requests. Staff then works with these communities to help them develop Operation and Maintenance (O & M) Plans for their private sanitary sewer system. This includes providing resources such as templates for their O&M plans and assisting with the development of a sanitary sewer system map. These resources are also available on the City’s website.

CMSWS staff then conduct compliance inspections at those communities that were sent information the year before. Staff also provides outreach activities to educate maintenance staff and property managers about the regulations, how to comply with them and why it’s important. Since 2010, the main avenue for this outreach has been an SSO workshop, although attendance has been waning.

During FY2018, the program aimed to improve outreach to maintenance staff and property managers about the SSO Workshop by partnering with the Greater Charlotte Apartment Association (GCAA). Through this partnership there were two workshops held: The CMSWS SSO Workshop and a GCAA Lunch n Learn. The workshops were both certified by the GCAA to provide maintenance continuing education credits. They were both posted on the GCAA and CMSWS websites and two sets of postcards advertising the SSO workshop were directly mailed

52 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

to the 200 multi-family communities that are located closest to problem SSO areas in the municipal sanitary sewer system.

During FY2018, this program accomplished the following:

 51 multi-family communities received informational letters  17 operation and maintenance plans were submitted by communities;  29 compliance inspections were conducted at multi-family sites, of these: o 22 sites were found non-compliant o 15 sites had developed an operation and maintenance plan o only 7 of 15 sites were implementing their plan  24 personnel from multi-family residential communities attended the two training workshops.  12 NOVs were issued to multi-family communities for illicit discharges and disposal of sewage

Figure 5-14 shows the locations of the 51 multi-family communities sent compliance letters and the 29 sites inspected for compliance during FY2018.

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 FY2018, a total of 40 failing septic systems were discovered in the City, 12 were repaired and 28 were connected to the municipal sanitary sewer system. These failures were not localized to any particular watershed area. No follow-up field investigations or monitoring were deemed necessary by CMSWS. Figure 5-15 shows locations of septic system failure activities during FY2018 as well as the cumulative locations of septic failures since November 2006.

5.6 Public Reporting Hotline

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

53 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-14

54 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-15

55 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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.

5.7 Service Requests and Documentation

Responding to service requests continued to be one of the most important methods for detecting and eliminating illicit discharges and connections in the City. During FY2018, a total of 519 service requests related to surface water pollution were investigated. These included 31 emergency response situations that typically involve oil, fuel, or other hazardous material releases, as discussed further in sub-section 8.5. All service requests were investigated and follow-up was provided to ensure efforts were taken to remediate the discharge and restore impacted areas. Enforcement activities were implemented as appropriate and are described in more detail in sub-section 5.2. Table 5-2 shows the caller type sources for the 519 service requests.

Table 5-2: FY2018 Service Request Source Summary Caller Type Number of Service Requests* Public Citizen 296 Business 14 Charlotte Fire Department staff 24 Charlotte-Mecklenburg Police Department staff 2 Charlotte Storm Water Services staff 38 Charlotte Water Department staff 36 Mecklenburg County Storm Water Services staff 86 State – NCDEQ staff 9 Environmental Protection Agency 1 Other 13 TOTAL 519 * Source summary data includes all types of service requests within the City jurisdiction

56 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

The City utilizes the Cityworks® database platform to maintain electronic and hard copy files documenting all IDDE activities including citizen requests. These were tracked from the original call for service, through investigations and applicable enforcement actions, and until final remedial work was completed.

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

During FY2018, the following watershed areas recorded the highest number of activities including service requests, emergency responses, and NOVs:

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

Figure 5-16 shows a summary report of a service request activity, and Figure 5-17 shows the FY2018 spatial distribution of service requests within the City.

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57 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-16

58 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

59 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 5-17

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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 Maintain adequate ordinances or other Continue administration and enforcement of the Pollution Control Ordinance and IDDE Program. (On-going, appropriate legal legal authorities to prohibit illicit years 1 – 5+) authorities connections and discharges and enforce the approved IDDE Program. Maintain a Storm The permittee shall maintain a current Continue to maintain storm sewer map in GIS and update as necessary to show additional outfalls. (On-going, Sewer System Base map showing major outfalls and years 1 – 5+) Map receiving streams.

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

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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 227 230 209 229 198 199 Watershed sub-basins assessed 19 18 18 21 26 24 Outfalls inspected/inventoried/updated 763 1,364 1,265 820 669 599 Dry weather flows detected 102 240 103 88 97 114 Dry weather flows sampled 59 138 28 15 29 87 Citizen service requests responded to 362 355 432 476 507 519 Emergency spills responded to 49 31 47 43 41 31 Illicit discharges detected/corrected 448 578 723 829 470 368 Ordinance violations/NOVs issued 83 96 86 109 121 121 Penalty enforcements issued 1 3 6 7 7 13 Municipal employee IDDE training sessions 45 36 39 34 44 43 Municipal employees trained on IDDE 1,195 2,206 2,587 965 1,157 1,743 SSOs detected/referred 257 247 177 224 189 164 Septic system failures detected/corrected 22 38 38 26 28 40

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 (including emergency response and private sewage system discharges), SSOs from the municipal system, IDEP, septic failures, stream-walks, water quality monitoring, and municipal and industrial inspections;  Employee IDDE training sessions includes classroom sessions, number of facilities assigned the on-line 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 municipal and private systems.

As part of a continual evaluation process, CMSWS started a new initiative during FY2018 called “IDDE Think Tank Meetings.” These quarterly meetings were used to evaluate the effectiveness

63 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

of current activities, identify new methods for identifying illicit discharges, and coordination of program implementation. The following highlights some of the results:

 Discussion of various initiatives to evaluate new technology for potential use in identifying illicit discharges.  The purchase of drones, ammonia probes, and a FLIR iPhone camera (infrared attachment) to assist in identifying illicit discharges;  Targeting granite and marble countertop facilities as part of IDEP;  Targeting stormwater outfall inspections and sampling in neighborhoods with old infrastructure;  Implementation of the Pet Waste Flagging Campaign; and  Potential use of CMANN units and 24-hour fecal coliform monitoring at one site each for Little Sugar Creek and Edwards Branch, to potentially identify illicit discharges.

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

 GIS analysis of illicit discharges continues to show that most of these occur in highly urbanized areas of the City. As such, the IDEP program will continue to be implemented as support for the Stream-Walk program in priority basins;  Education targeting the landscaping sector will continue to build upon efforts in previous years;  Targeting multi-family residential communities with education and inspections will continue as these communities are one of the largest sources of SSOs. CMSWS and CW will discuss how to improve the program for FY2019 as numbers at workshops continue to wane and compliance with state regulations related to maintaining private sewer systems at multi-family residential communities is low;  The public and internal employee staff continues to be the number one source of illicit discharge reporting. The public reporting hotline, public education campaigns, internal education and service request response will continue to be a staple for IDDE efforts;  The Cityworks® database and use of smart phones for field data entry continues to improve data entry, storage and query capabilities; and  The City’s vast and varied surface and stormwater monitoring program continues to be an important resource for detecting 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

64 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Program assessment.

6.1 BMP Summary Table

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

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

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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 FY2018 the program served to provide added protection to surface water resources in the City by ensuring that builders and developers followed minimum standards for erosion and sediment control per State and Local guidelines.

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

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

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

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

6.2.1 Inspection Procedures

All construction sites that required a preconstruction meeting and approved plan were logged, filed and placed in the queue for regular inspections. Staff goals were to visit and inspect every logged site utilizing a scheduled inspection process. Sites that generated citizen complaints, had

66 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

a history of non-compliance, or were in close proximity to a critical area (e.g., sites adjacent to water features or within a water-supply watershed) were considered a priority for additional inspections and follow-up.

6.3 Construction Site Requirements

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

6.4 Public Information and Reporting

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

6.4.1 Education and Training Materials

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

In a cooperative effort with Mecklenburg County, the City maintained the Charlotte- Mecklenburg Certified Site Inspector (CMCSI) training program, which to date has provided training to over 5,840 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

67 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

erosion control, common site problems, recommendations for conducting effective inspections, and a certification exam. The CMCSI program was offered three times during FY2018, providing training to 342 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 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 – FY2018 Date Registered Attended August 17, 2017 150 123 January 10, 2018 120 105 May 24, 2018 158 114 Totals 428 342

6.5 Plan Reviews

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

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

[THIS SPACE INTENTIONALLY BLANK]

68 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 The permittee has a delegated Sediment and Erosion Continue to implement the delegated Sediment and Erosion Control program and enforce the Sediment Control Control Program. As such, to the extent authorized by City ordinance. (On-going, years 1 – 5+) Program 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. Develop The NCG010000 permit establishes requirements for Continue requirements for BMPs and waste control through issuance of General Construction requirements for construction site operators to control waste such as Permit NCG010000. (On-going, years 1 – 5+) construction site discarded building materials, concrete truck washout, operators 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. Public information The permittee shall provide and promote a means for the Continue to maintain reporting hotline and website. (On-going, years 1 – 5+) and reporting 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. Plan reviews Implement construction site plan reviews as part of the Continue plan reviews to ensure program requirements are met. Coordinate with NCDEQ – Permittee’s delegated program. For new development DEMLR as necessary. (On-going, years 1 – 5+) 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.

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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 3 Citizens educated 307 356 367 425 383 342 Project/site plans reviewed 823 1,048 1,043 711 881 1,415 Erosion control citizen requests responded to 131 275 ~300 ~375 ~400 ~465 Site inspections conducted 3,142 2,852 2,323 2,948 3,853 4,097 NOVs issued 38 50 47 109 131 112 Penalty enforcements issued 24 40 32 41 45 46

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 1 2 3 4 5 Position Post-Construction Maintain an ordinance (or similar regulatory X X X X X Stormwater mechanism) and program to address stormwater Water Quality Management runoff from new development and redevelopment. Program Program Manager Strategies which Maintain strategies that include a combination of X X X X X include BMPs structural and/or non-structural BMPs implemented Water Quality appropriate for the in concurrence with ordinance above. Provide a Program MS4 mechanism to require long-term operation and Manager

70 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 The permittee shall provide mechanisms such as X X X X X and Protective recorded deed restrictions and protective covenants Water Quality Covenants so that development activities maintain the project Program consistent with approved plans. Manager

Operation and The developer shall provide the permittee with an X X X X X Maintenance Plan operation and maintenance plan for the stormwater Water Quality system, indicating the operation and maintenance Program actions that shall be taken, specific quantitative Manager 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.

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

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, including EPM-SWS and EPM- LD 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

71 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

November 26, 2007, effective July 1, 2008. 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:

73 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 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 30, 2017 with 120 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 1, 2017 with 104 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.

74 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 Maintain an ordinance (or similar regulatory mechanism) and program to address Maintain the City’s Post- Construction Ordinance (PCSO) and Stormwater stormwater runoff from new development and redevelopment. implement and enforce the ordinance. (On-going, years 1 – 5+) Management Program Strategies which Maintain strategies that include a combination of structural and/or non-structural BMPs Continue PCSO program and ensuring proper BMP operation, include BMPs implemented in concurrence with (a) above. Provide a mechanism to require long-term maintenance, and annual inspections. (On-going, years 1 – 5+) appropriate for the operation and maintenance of structural BMPs. Require annual inspection reports of MS4 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 The permittee shall provide mechanisms such as recorded deed restrictions and protective Continue to implement Deed Restrictions and Protective and Protective covenants so that development activities maintain the project consistent with approved Covenants through administration of the PCSO Program. (On- + Covenants plans. going, years 1 – 5 )

Operation and The developer shall provide the permittee with an operation and maintenance plan for the Continue to implement BMP operation, maintenance, and Maintenance Plan stormwater system, indicating the operation and maintenance actions that shall be taken, inspection plan and procedures. (On-going, years 1 – 5+) 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.

Educational Provide educational materials and training for developers. New materials may be Continue to provide and update education/ training tools for materials and developed by the permittee, or the permittee may use materials adopted from other developers. (On-going, years 1 – 5+) training for programs and adapted to the permittee’s new development and redevelopment program. developers

75 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 96 103 121 145 145 SCMs added 38 97 109 151 171 127 SCM inspections conducted 27 93 6061. 7261. 1,0061. 1,5441. NOVs issued 10 6 2582. 4152. 4042. 5702. Education workshops conducted 1 4 5 2 1 1 Citizens educated 18 105 183 194 231 120 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 FY2018 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 FY2018 was higher than FY2017; however, relative to the number of inspections that were conducted during FY2018, this was consistent.

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

Section 8: Pollution Prevention/Good Housekeeping Program

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

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

76 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 1 2 3 4 5 Position Operation and Maintain and implement an operation and X X X X X maintenance program maintenance program for municipal facilities Water Quality for municipal owned and operated by the permittee that have Program facilities and been determined by the permittee to have Manager operations. significant potential for generating polluted stormwater runoff that has the ultimate goal of preventing or reducing pollutant runoff. Site Pollution Maintain and implement Site Pollution Prevention X X X X X Prevention Plans for Plans for municipal facilities owned and operated Water Quality municipal facilities by the permittee that have been determined by the Program and operations. permittee to have significant potential for Manager generating polluted stormwater runoff that has the ultimate goal of preventing or reducing pollutant runoff. Inspection and Maintain an inventory of municipal facilities and X X X X X evaluation of operations owned and operated by the permittee Water Quality municipal facilities that have been determined by the permittee to have Program and operations. significant potential for generating polluted Manager 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. Spill Response Maintain spill response procedures for municipal X X X X X Water Quality Procedures municipal facilities and operations owned and operated by Program facilities and the permittee that have been determined by the Manager operations. permittee to have significant potential for generating polluted stormwater runoff. Prevent or Minimize Describe measures that prevent or minimize X X X X X Water Quality Contamination of contamination of the stormwater runoff from all Program Stormwater Runoff areas used for vehicle and equipment cleaning, Manager from all areas used including fire stations that serve more than three for Vehicle and fire trucks and ambulances. Perform all cleaning Equipment 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

77 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 The permittee shall evaluate BMPs to reduce X Water Quality public parking lots polluted stormwater runoff from municipally- Program maintenance owned streets, roads, and public parking lots Manager within the corporate limits. Within 12 months of permit issuance, the permittee must update its Stormwater Plan to include the BMPs selected. Streets, roads, and Within 24 months of permit issuance, the X X X X Water Quality public parking lots permittee must implement BMPs selected to Program maintenance reduce polluted stormwater runoff from Manager municipally-owned streets, roads, and public parking lots identified by the permittee in the Stormwater Plan. Operation and Within 12 months of permit issuance, the X X X X X Water Quality Maintenance (O&M) permittee shall develop and implement an Program for municipally- operation and maintenance program for structural Manager owned or maintained SCMs and the storm sewer system (including structural SCMs and catch basins, the conveyance system, and the storm sewer structural stormwater controls). system (including catch basins, the conveyance system, and structural stormwater controls). Staff training Maintain and implement a training plan that X X X X X Water Quality indicates when, how often, who is required to be Program trained and what they are to be trained on. 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.

78 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

EPM-SWS staff continued to work with various municipal 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 pollution prevention best management 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 FY2018, EPM-SWS staff also accomplished the following activities related to improving pollution prevention from City contractors and City field crews:

 Met with EPM-SWS construction management staff and EPM-LD erosion control staff several times to coordinate and develop the best procedures and methods for improving contractor and subcontractor performance related to preventing illicit discharges, spills, and implementing pollution prevention practices;  Continued to support the Surface Water Quality Protection section of EPM-SWS construction contracts that includes requirements related to: - Concrete washouts; - Spill response and mobile fueling; and - Erosion control and pollution prevention before street washing.  Sent letters to EPM-SWS geotechnical contractors and presented about what concrete washouts should look like at a EPM-SWS construction inspector staff meeting;  Met with EPM - Engineering Services Division construction inspectors to discuss erosion control efforts and to conduct the trial use of inlet filter mats as an alternative to silt sacs;  Conducted communications with CDOT regarding stormwater BMPs for street milling;  Conducted communications and meetings with CDOT and CW regarding stormwater BMPs for slurry created during street cutting operations and applicable emergency water main breaks;  Conducted communications and meetings with CW to discuss BMPs for water line flushing;  Conducted communications and a meeting with City Solid Waste Services regarding street sweeping discharges;  Conducted communications with CATS and City Code Enforcement regarding contract language and stormwater BMPs related to graffiti removal;

79 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Provided recommendations to City Management and Financial Services for improving spill response contract language;  Provided recommendations to EPM-Landscape Management Division for improving spill response contract language; and  Provided landscape standards for use on EPM-SWS project design plan sheets regarding pollution prevention practices.

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

8.3 Municipal Facility Stormwater Pollution Prevention Plans

SPPPs are developed for all 31 municipal facilities listed in Table 8-2 regardless of whether or not they are required; however, SPPPs are not required or developed for fire stations. The SPPPs are reviewed and updated annually with all documentation kept in the SPPPs, including site maps. The SPPPs are used as an implementation guide for maintaining good housekeeping and reducing stormwater pollution. All appropriate topics are covered in the SPPPs including:

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

Table 8-2: City Facilities within the Pollution Prevention/Good Housekeeping Program. Municipal Facility Physical Address Charlotte-Douglas International Airport 5501 Josh Birmingham Pkwy., Charlotte, NC 28208 CATS Bus Maintenance Operations Facility 3145 S. Tryon St., Charlotte, NC 28217 CATS Transit Maintenance Operations Center 901 N. Davidson St., Charlotte, NC 28202 CATS Transit Center 310 E. Trade St., Charlotte, NC 28202 CATS Light Rail Maintenance Facility – South Yard 3305 Pelton St., Charlotte, NC CDOT - Traffic Engineering Operations Center 3701 Craig Ave., Charlotte, NC 28211 CDOT – Street Maintenance Division - Northwest District 4411 Northpointe Industrial Blvd., Charlotte, NC 28216 CDOT – Street Maintenance Division - Northeast District 6001 General Commerce Dr., Charlotte, NC 28213 CDOT – Street Maintenance Division - Southwest District 4600 Sweden Rd., Charlotte, NC 28273 Charlotte Water Department - Irwin Creek WWTP 4000 Westmont Dr., Charlotte, NC 28217

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Municipal 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 Engineering & Property Management - Heavy Equipment Shop 4600 Sweden Rd., Charlotte, NC 28273 Engineering & Property Management - Heavy Truck Shop / Central Yard Truck Wash 829 Louise Ave., Charlotte, NC 28204 Engineering & Property Management - Light Vehicle Shop 1031 Atando Ave., Charlotte, NC 28216 Engineering & Property Management - Small Engine Repair Shop 701 Tuckaseegee Rd., Charlotte, NC 28208 Engineering & Property Management - 12th Street Vehicle Garage 900 W 12th St, Charlotte, NC 28206 CFD - Fire Logistics 1200 Otts St., Charlotte, NC 28205 CMPD - Animal Control Shelter 8315 Byrum Dr., Charlotte, NC 28217 CMPD - Police and Fire Training Academy 1770 Shopton Rd., Charlotte, NC 28217 Solid Waste Services - Street Sweeper Facility & Sanitation Packer Lot 829 Louise Ave., Charlotte, NC 28204 Landscape Management Operations 701 Tuckaseegee Rd., Charlotte, NC 28208

8.4 Municipal Facility Inventory and Site Inspections

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

 Preparation and implementation of a SPPP;  Regular inspections; and

81 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Annual employee training.

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

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

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

During FY2018 the following activities were conducted as part of the municipal facility site inspections:

 31 inspections were conducted;  22 pollution control ordinance deficiencies were detected (including six illicit discharges); and  30 SPPP problems were noted.

Ordinance deficiencies and SPPP problems required corrective action by facility staff. Figure 8-1 shows the locations of the facilities inspected during FY2018. (Note: Some CW facilities are located outside the City limits.)

82 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 8-1

83 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

8.4.1 NPDES Stormwater Permitted Municipal Facilities Review

Twelve of the 31 municipal facilities discussed in sub-section 8.3 above have been issued NPDES Stormwater permits (*Note: The airport’s permit is a combined stormwater/wastewater individual permit). Table 8-3 shows these facilities.

Table 8-3: Municipal Facilities with NPDES Stormwater Permits Municipal Operation Permit Certificate of Permit Address Number Coverage Number CATS Transit Maintenance NCG080000 NCG080029 901 N. Davidson Street Operations Center CATS Bus Maintenance NCG080000 NCG080710 3145 S. Tryon Street Operations Facility Heavy Truck Shop, Truck NCG080000 NCG080822 829 Louise Avenue Wash & Street Sweeper Yard Heavy Equipment Shop NCG080000 NCG080840 4600 Sweden Road Light Vehicle Maintenance NCG080000 NCG080879 1031 Atando Avenue Shop 12th Street Fleet NCG080000 NCG080063 900 West 12th Street Maintenance Charlotte-Douglas NC0083887 Not applicable 5501 Josh Birmingham Parkway International Airport* Irwin Creek WWTP NCG110000 NCG110008 4000 Westmont Drive Mallard Creek WWTP NCG110000 NCG110114 12400 Highway 29 North McAlpine Creek WWTP NCG110000 NCG110010 12701 Lancaster Hwy McDowell Creek WWTP NCG110000 NCG110011 4901 Neck Road Sugar Creek WWTP NCG110000 NCG110012 5301 Closeburn Road

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

8.5 Municipal Spill Response Procedures

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

 Product storage tanks/containers, exposure, and secondary containment;

84 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 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.

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 FY2018, the team responded to 31 emergency response calls, but none were related to the municipal facilities listed in Table 8-2. Figure 8-2 shows a downward trend in the number of emergency response calls from FY1995 through FY2018.

8.6 Vehicle and Equipment Cleaning Operations

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

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85 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 8-2

8.7 Streets, Roads, and Public Parking Lots Maintenance

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

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

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8.8 Municipal SCMs and MS4 System Operation and Maintenance

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

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

These inspection and maintenance activities have been conducted to ensure proper function of structural SCMs. During FY2018, Standard Operating Procedures (SOP) were updated for the program, and a meeting was held with all involved staff to review the SOP.

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

The City conducted extensive cleaning and maintenance of the MS4 system during FY2018. 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 FY2018, a total of:

 80,714 catch basin tops were manually cleaned;  1,639 catch basins were vacuumed out;  2,975 catch basin tops were vacuumed;  22,726 linear feet of stormwater pipes were vacuumed out

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8.9 Employee/Staff Training at Municipal Facilities

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

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

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

During FY2018, training was conducted as follows:

 26 on-site training sessions were provided by CMSWS staff at 31of the municipal facilities listed on Table 8-2;  Eight facilities elected to train their own staff (CATS S. Tryon, CATS Davidson, the five wastewater facilities, and the airport);  251 employees from nine facilities were assigned an on-line training module.

Of those employees who were assigned the module, 177 completed it which is a 70.5% completion rate. In addition, 43 employees elected to complete the training even though it was not assigned to them. EPM-SWS staff works with facility management each year to have a completion rate of 75% or higher for those employees assigned the training. During FY2019, more emphasis will be placed on encouraging the CATS Light Rail and Landscape Management facilities to improve their completion rates, as their numbers were among the lowest.

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 Maintain and implement an operation and maintenance program for Review and update Operation and Maintenance programs as municipal facilities and operations. municipal facilities owned and operated by the permittee that have necessary. Continue operation and maintenance activities been determined by the permittee to have significant potential for per established procedures. (On-going, years 1 – 5+) generating polluted stormwater runoff that has the ultimate goal of preventing or reducing pollutant runoff. Site Pollution Prevention Plans for Maintain and implement Site Pollution Prevention Plans for municipal Review and update facility SPPPs as necessary. Continue municipal facilities and operations. facilities owned and operated by the permittee that have been implementation of SPPPs. (On-going, years 1 – 5+) determined by the permittee to have significant potential for generating polluted stormwater runoff that has the ultimate goal of preventing or reducing pollutant runoff. Inspection and evaluation of municipal Maintain an inventory of municipal facilities and operations owned Review and update inventory of facilities for inspection. facilities and operations. and operated by the permittee that have been determined by the Conduct inspections of applicable facilities and make permittee to have significant potential for generating polluted corrective actions where necessary. (On-going, years 1 – 5+) 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. Spill Response Procedures municipal Maintain spill response procedures for municipal facilities and Review facility spill response procedures and update as facilities and operations. operations owned and operated by the permittee that have been necessary. Continue implementation of procedures. (On- determined by the permittee to have significant potential for generating going, years 1 – 5+) polluted stormwater runoff. Prevent or Minimize Contamination of Describe measures that prevent or minimize contamination of the Review procedures for vehicle and equipment cleaning Stormwater Runoff from all areas used stormwater runoff from all areas used for vehicle and equipment operations and update as necessary. Ensure that corrective for Vehicle and Equipment Cleaning cleaning, including fire stations that serve more than three fire trucks actions are implemented where operations are found to not and ambulances. Perform all cleaning operations indoors, cover the be in compliance with the permit. (On-going, years 1 – 5+) 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.

89 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 The permittee shall evaluate BMPs to reduce polluted stormwater Evaluate various types None (years 2 – 5+) maintenance runoff from municipally-owned streets, roads, and public parking lots of BMPs that would within the corporate limits. Within 12 months of permit issuance, the best address polluted permittee must update its Stormwater Plan to include the BMPs stormwater runoff selected. from municipally- owned streets and parking lots and select BMPs based on the evaluation by Feb 28, 2014. Streets, roads, and public parking lots Within 24 months of permit issuance, the permittee must implement None Implement Continue to maintenance BMPs selected to reduce polluted stormwater runoff from municipally- BMPs selected implement owned streets, roads, and public parking lots identified by the from year one selected BMPs. permittee in the Stormwater Plan. evaluation by (On-going, years Feb 28, 2015. 3 – 5+) Operation and Maintenance (O&M) for Within 12 months of permit issuance, the permittee shall develop and Continue to implement structural SCM operation, municipally-owned or maintained implement an operation and maintenance program for structural SCMs maintenance, and inspection program. Continue operation structural SCMs and the storm sewer and the storm sewer system (including catch basins, the conveyance and maintenance program for the MS4 system. (On-going, system (including catch basins, the system, and structural stormwater controls). years 1 – 5+) conveyance system, and structural stormwater controls). Staff training Maintain and implement a training plan that indicates when, how often, For facilities included in the municipal facility inspection who is required to be trained and what they are to be trained on. 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 34 Municipal facilities inspected1. 31 31 31 50 51 31 Municipal program evaluations 10 9 9 2 28 17 Problems detected/corrected at City facilities 45 55 56 43 15 52 Municipal facility employee training sessions 32 34 32 32 39 36 Municipal facility employees trained 925 891 1,118 760 1,808 1,743 1. Not all parcels are included in the municipal inspection program. See Sec 8.4

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

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

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

 Continuing to develop and improve upon stormwater pollution prevention best management practices among municipal field operations;  Municipal street and lot sweeping, with a specific focus on water quality improvement;  Comprehensive improvement in the spills program including training, written procedures, cleaning, reporting, recording, and other elements;

91 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

 Contractor training and expectations;  Continuous improvement in inspection and maintenance of municipality-owned structural SCMs; and  Increased communication and coordination with other departments and committees to integrate more stormwater pollution prevention, green infrastructure, and other stormwater measures into municipal 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 1 2 3 4 5 Position Maintain an Maintain an inventory of permitted hazardous X X X X X Water Quality Inventory of waste treatment, disposal, and recovery facilities, Program Industrial Facilities industrial facilities that are subject to Section 313 Manager 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.

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

92 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

BMP BMP Description Schedule (years) Responsible 1 2 3 4 5 Position Evaluate Industrial The Permittee is required to evaluate control X X X X X Water Quality Facilities discharging measures implemented at permitted hazardous Program stormwater to the waste treatment, disposal, and recovery facilities, Manager City’s MS4 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.

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 for stormwater pollution. Non-permitted industrial

93 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

facilities are selected for inspection based on the recommendation of CMSWS staff, citizen complaints, or from viewing aerial photography that indicated potential pollution issues at a site.

During FY2018, a strategy was finalized and used for inspecting industrial 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 can potentially have poor housekeeping practices and illicit discharges. Facilities are selected for inspection based on of a combination of targeting priority watershed basins, aerial photography suggesting potential for stormwater pollution, and staff recommendations. During FY2018, the watersheds prioritized for inspection were Irwin Creek, Little Sugar Creek, and Sugar Creek.

9.3 Industrial Facilities Inspection Program

The purpose of the Industrial Facilities Inspection program is to evaluate activities at industrial facilities that may impact stormwater discharges, and then work with 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;  Review of spill response and clean up procedures;

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 Evaluation of housekeeping practices with recommended revisions as necessary to eliminate potential pollution sources;  Evaluation of outdoor storage facilities and recommendations for elimination of potential pollution sources;  Identification and elimination of dry weather discharges;  Review of SPPP implementation where applicable, including outfall monitoring (if required by permit);  Sampling/monitoring of site stormwater runoff and/or dry weather flows;  Evaluation of monitoring data results; and  Completion of a written report documenting findings and recommendations.

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

During FY2018 the Industrial Facilities Inspection and Monitoring Program completed the following activities:

 43 industrial facilities (30 permitted and 13 non-permitted) and 15 vehicle maintenance shops were inspected;  11 illicit discharges were identified and corrected;  Seven of the NPDES permitted sites were unsatisfactory and six of the non-permitted sites were unsatisfactory.  Eight non-permitted facilities were observed to potentially be subject to an NPDES stormwater required permit based on 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 15 vehicle maintenance facilities inspected, 22 deficiencies were identified.

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

Table 9-2: FY2018 List of Industrial Facility Inspections Facility NPDES Permit # Address Refabco Incorporated NCG030385 200 E 27th St Mallard Creek Polymers Incorporated NCG090006 14800 Mallard Creek Rd Hunter Auto & Wrecker Service NCG100075 1114 N Davidson St Lakeview Auto Parts Incorporated NCG100101 5500 Wilkinson Blvd

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Facility NPDES Permit # Address Queen City Transfer Station NCG130079 3130 Jeff Adams Drive Lucas Concrete Products, Inc. NCG140446 401 Rountree Road Blythe Construction Inc. NCG160115 10500 Old Nations Ford Rd Southern Metals Company NCG200347 2200 Donald Ross Rd Wire Bond NCG030629 400 Roundtree Rd Trane US, Inc. NCG030098 4500 Morris Field Dr. Bendel Corporation NCG030234 4823 N Graham Orbit Energy Charlotte NCG060387 600 Johnson Road Contech Construct Prod-Mecklenburg NCG030391 4242 Raleigh St A. O. Smith Water Systems NCG030486 4302 Raleigh St Otto Industries NCG050149 12700 General Dr. ADM Milling Co NCG060028 620 W 10th St Snyder Production Center NCG060081 4901 Chesapeake Drive Cargill Incorporated NCG060036 5000 S Blvd Advantage Machinery Services Inc. NCG080286 3027 N Tryon St Central Freight Lines NCG080323 7500 Statesville Rd Novem Industries NCG210443 3901 North Graham Street USF Holland Inc - CN NCG080792 5201 Sunset Rd Elan Trading (dba South Resources) NCG200461 3826 Raleigh Street Full Stream Recycling NCG130078 2214 North Graham Street Blythe Brothers Asphalt Co, LLC NCG160221 10447 Old Nations Ford Road Charlotte Turbine Generator Plant NCS000021 5101 Westinghouse Blvd Ameristeel Corporation NCS000304 6601 Lakeview Rd Jci Jones Chemicals Incorporated NCS000334 1500 Tarheel Rd Nexeo Solutions, LLC NCS000315 3930 Glenwood Drive Schaefer Systems International Inc NCG050427 10124 Westlake Drive Non permitted: SiteOne Hardscape Center 1615 East Westinghouse Atlantic Ingredients / Atlantic Sweetener 512 Domino Court IBC Beverage 3936 Corporation Circle Pavestone LLC (Quikrete) 1101 Westinghouse Blvd Kelly Pipe 11024 Nations Ford Road n/a JML Energy Resources 327 Old Hebron

Arborscapes 8924 Crump Road Zachary Industrial 255 East Hebron Road Sam Auto Salvage 2711 Wilkinson Blvd MigWay Trucking 9349 China Grove Church Road Streeter Trucking 6824 Old Statesville Road Hunter Salvage Yard 5310 David Cox Road Blythe Brothers Construction Yard 10447 Old Nations Ford Road

Table 9-3: FY2018 List of Vehicle Maintenance Facility Inspections Facility Address Royal Cab (fleet maintenance garage) 2000 North Tryon Street Premiere Logistics and Auto LLC 110 West 27th Street Advance Collision 2504 North Tryon Street Taitt’s Tire and Automotive Service 2325 North Tryon Street Uno's Used Tire and Auto Repair 905 East Sugar Creek Road Los Angeles Auto Service 401 West 32nd Street

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Facility Address Adams Truck Service 614 Atando Avenue Escobar Auto Repair 122 Lambeth Drive Jacintos Auto Center 2837 Sparta Avenue Larry's Service Center 3730 Wilkinson Blvd Teliwel Automotive Services 3837 Lousiana Avenue Morningside II Auto Care 3020 Rozzelles Ferry Road The Mechanic Man 539 State Street Clyburn Motorspots and Collision 3032 Rozzelles Ferry Road Fleet Truck Service 700 Griffith Road

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97 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 9-1

98 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

FIGURE 9-2

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9.3.1 Industrial Facilities Monitoring Program

The purpose of the Industrial Facilities Monitoring Program is to monitor stormwater runoff from select industrial facilities and identify and correct pollution sources related to industrial activities. Facilities monitored consist of both those with and without an NPDES stormwater permit. Facilities are selected based on input from the CMSWS inspectors who inspected these facilities under the Industrial Inspections Program during the previous fiscal year. One outfall from each of the following nine facilities was monitored during wet weather at least one time during FY2018:

 Full Stream Recycling;  DART Acquisitions;  Ferebee Asphalt Corporation;  Wise Recycling;  Sonoco Products Co.-Charlotte;  Southern Cast Foundry;  Safety Kleen Systems, Inc. (Goodrich Dr.);  Thomas Concrete of Carolina Inc; and  Starnes Pallet Service

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

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

During FY2018, monitoring data from the above facilities showed pollutant levels in the stormwater that were elevated when compared to CMSWS historical industrial monitoring data, permit benchmarks, and NCDEQ in-stream water quality standards. The following summarizes some results of this analysis:

 CMSWS Industrial Monitoring Database: o The highest values on record in the CMSWS database for turbidity, TSS and copper were recorded at Wise Recycling; zinc, chromium, and lead were all at or above the 96th percentile.

100 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

o The highest values on record in the CMSWS database for BOD and COD were recorded at Full Stream recycling; fecal coliform, e-coli, and zinc were all at or above 85th percentile. o Turbidity values were in the 90th percentile and zinc was in the 80th percentile at Starnes Pallet. o Chromium values were in the 97th percentile and a pH limit violation was detected at Thomas Concrete.

 NPDES industrial permit benchmarks (four facilities had permit requirements to conduct analytical monitoring): o two permit effluent limitations were exceeded at Thomas Concrete. (effluent limits applied for concrete process water) o five permit benchmarks were exceeded at Wise Recycling.

 North Carolina in-stream water quality standards (note that in-stream standards do not apply to stormwater runoff, but are used as one basis of analysis) o All nine facilities exceeded at least one parameter o 89% of the facilities monitored exceeded the in-stream standard for copper o 67% exceeded the in-stream standard for zinc. o 56% exceeded the in-stream standard for turbidity.

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

9.4 Evaluation Measures

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

9.5 Measurable Goals/Planned Activities for Future Program Years

Table 9-4 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.

101 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 Maintain an inventory of permitted hazardous waste treatment, disposal, and Maintain and update the industrial facility inventory as needed. Inventory of recovery facilities, industrial facilities that are subject to Section 313 of Title III of (On-going, years 1 – 5+) Industrial the Superfund Amendments and Reauthorization Act of 1986 (SARA), industrial Facilities 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.

Inspection Identify priorities and inspection procedures. At a minimum, priority facilities Update current Industrial Inspection and Monitoring Program include those identified above in subsection II.H.2.a. Procedures and develop an inspection prioritization strategy. (On-going, years 1 – 5+) Evaluate The Permittee is required to evaluate control measures implemented at permitted Conduct inspection activities based on established procedures Industrial hazardous waste treatment, disposal, and recovery facilities, industrial facilities that and prioritization strategy at 50 facilities for years 1 and 2; and Facilities are subject to Section 313 of Title III of the Superfund Amendments and 40 facilities in years 3 -5+. Conduct stormwater runoff discharging Reauthorization Act of 1986 (SARA), industrial facilities identified with an monitoring at 10 facilities for years 1 and 2; and 8 facilities in stormwater to industrial activity permitted to discharge stormwater to the permittee’s MS4, or as years 3 -5+. the City’s MS4 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.

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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 358 384 468 342 374 379 Industrial facilities inspected 51 51 50 40 41 43 Vehicle maintenance facilities inspected 15 20 21 15 16 9 Industrial facilities monitored 10 10 10 8 8 43 Industrial facility Notice of Deficiencies issued 13 7 7 5 9 15 Illicit discharges or connections detected/corrected 3 0 0 3 5 17

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

 Site inventory includes industrial facilities with an NPDES Stormwater permit, Stormwater No Exposure Certificate, CW 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.

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.

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

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

10.2 Water Quality Assessment and Monitoring Plan

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

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

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

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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 FY2018 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 Maintain a Water Quality Assessment Maintain the WQ Assessment & Monitoring Plan and update as necessary. (On-going, years 1 – 5+) Assessment and and Monitoring Plan. The Plan shall Monitoring Plan include a schedule for implementing the proposed assessment and monitoring activities. Water Quality Maintain and implement the Water Maintain and implement the monitoring plan and conduct WQ assessment and monitoring activities per the plan. Monitoring Quality Assessment and Monitoring (On-going, years 1 – 5+) Plan submitted to DWQ.

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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 15 Stream samples collected1. 60 60 60 60 60 60 Laboratory sample analyses conducted1. 720 720 720 720 720 720 Stream physical measurements (DO, Temp, pH, Cond) 1. 240 240 240 240 240 240 IDDE problems detected/corrected through monitoring 0 1 0 2 0 1 1. Data reported is the minimum quarterly amount per the basic monitoring plan.

10.6.1 Water Quality Monitoring Program Evaluation

During FY2017, an evaluation of the enhanced water quality monitoring program was conducted to determine whether any changes were needed to improve the cost-effectiveness of the program. This evaluation resulted in the removal of enhanced program parameters Enterococcus and several total metals (beryllium, selenium, cadmium, and silver) from the monitoring program. Enterococcus was removed because it was determined to be unnecessary to collect in addition to E. coli and fecal coliform. The total metals mentioned above were removed because they were consistently below detection limits and water quality standards. Data analysis continued through FY2018 but no additional changes to the monitoring program have been made.

10.6.2 Water Quality Trend Analysis

The City utilizes water quality data generated from various monitoring programs, including NPDES MS4, to generate a Stream Use Support Index. This spatial index visually represents water quality conditions by sub-basin and can be compared year by year to determine general trends. The index map for calendar year 2017 is shown below in Figure 10-2. The map shows general WQ conditions to be in the partially supporting to impaired category for the sub-basins within the City.

Figure 10-3 shows time series graphs for each non-metal parameter in the monitoring plan for the nine-year period from Jan 2009 to Jun 2018 (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). 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 2018. These data have been plotted as the difference between individual sample results and the acute dissolved standard at the sample’s hardness value to better illustrate exceedances and non-exceedances on a temporal basis. As a result, the vertical axes represent how far above or below the standard a given sample was, as opposed to showing absolute sample concentrations. Samples collected prior to implementation of the dissolved metals standards are

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also shown relative to the current dissolved metals standards, as this gives a better picture of historical toxicity.

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

FIGURE 10-4

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118 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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 1 2 3 4 5 Position Identify, describe Within 24 months the permittee shall prepare a plan X X X X Water Quality and map that: Program watershed, outfalls,  Identifies the watershed(s) subject to an Manager and streams 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. Existing measures Within 24 months the Permittee’s plan: X X X X Water Quality  Shall describe existing measures being Program implemented by the Permittee designed to Manager 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. Assessment of Within 24 months the permittee’s plan shall include X X X X Water Quality available an assessment of available monitoring data. Where Program monitoring data long-term data is available, this assessment should Manager include an analysis of the data to show trends. Monitoring Plan Within 36 months the permittee shall develop and X X X Water Quality submit to the Division a Monitoring Plan for the Program permittee’s assigned NPDES regulated WLA as Manager 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

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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 Within 36 months the permittee’s plan shall: X X X Water Quality Measures  Describe additional measures to be Program implemented by the permittee designed to Manager 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. Implementation Within 48 months the permittee’s plan shall: X X Water Quality Plan  Describe the measures to be implemented Program within the remainder of the permit term Manager 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. Incremental The permittee’s plan must outline ways to track and X X Water Quality Success report successes designed to achieve the MS4’s Program NPDES regulated WLA and to reduce the TMDL Manager pollutant of concern to MEP within the watershed to which the TMDL applies. Reporting The permittee shall conduct and submit to the X X X X Water Quality Division an annual assessment of the program Program designed to achieve the MS4’s NPDES WLA and to Manager 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.

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 WQ TMDL Approved TMDL Pollutant of Concern Name Classification 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 2018 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 2018 is provided in Figure 11-2. A total of 145 samples have been collected over this period under the fixed interval monitoring program. Of these, 51% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

Figure 11-2: 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 2018 is provided in Figure 11-3. A total of 147 samples have been collected over this period under the fixed interval monitoring program. Of these, 51% exceeded the 400 cfu/100mL State

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standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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

11.4.1.3 Sugar/Irwin Creek Watershed

There are two fixed interval monitoring locations in the Sugar Creek watershed, MC27 in southern Mecklenburg County, and MC22A on Irwin Creek just before its confluence with Sugar Creek. An assessment of available watershed and water quality data was conducted utilizing fixed interval stream data for fecal coliform collected at these two monitoring locations. A summary of the data collected from January 2007 through July 2018 is provided in Figures 11-4 and 11-5.

A total of 141 samples have been collected at MC27 over this period under the fixed interval monitoring program. Of these, 42% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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

During the same period, a total of 138 samples were collected at MC22A under the fixed interval monitoring program. Of these, 44% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however, 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 2018 is provided in Figures 11-6 and 11-7.

A total of 142 samples have been collected at MC49A over this period under the fixed interval monitoring program. Of these, 53% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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

A total of 142 samples have been collected at MC29A-1 over this period under the fixed interval monitoring program. Of these, 53% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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Figure 11-7: 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 2018 is provided in Figures 11-8 and 11-9.

A total of 137 samples have been collected at MC45B over this period under the fixed interval monitoring program. Of these, 30% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be much more frequent under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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

A total of 141 samples have been collected at MC38 over this period under the fixed interval monitoring program (Figure 11-9). Of these, 48% exceeded the 400 cfu/100mL State standard with 90% confidence. Exceedances tended to be much more frequent and more extreme under wet weather influenced sampling conditions (meaning some precipitation within the County in the 72-hour preceding the sampling event), however exceedances did occur under both ambient and wet weather influenced conditions.

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Figure 11-9: McAlpine Creek –MC38 - Overall Monitoring Data

11.4.1.6 Fecal Coliform Summary

The State standard for fecal coliform is exceeded by more than 10% with 90% confidence for all watersheds with a fecal coliform TMDL identified above, based on fixed interval data collected between 2006 and 2018. These exceedances are more common in wet weather influenced conditions but exceedances did occur during ambient conditions in each of these watersheds.

11.4.2 Turbidity

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

11.4.2.1 Long Creek Watershed

An initial assessment of available watershed and water quality data was conducted utilizing stream data for turbidity collected at the CMSWS monitoring site MC14A on Long Creek. A summary of the data collected from July 2006 through July 2018 is provided in Figure 11-10. A

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total of 138 samples were collected during this period, with 16% exceeding the 50 NTU State standard with 90% confidence. 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 interval sampling conducted between July 2006 and July 2018, there have been no violations of the instantaneous State standard of 4 mg/L in any of the DO TMDL watersheds. The 2016 NC Integrated Report categorizes each of these watersheds as 1i for DO, meaning that they have a TMDL but are not impaired and are supporting their designated uses.

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

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

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Figure 11-13: McAlpine Creek –MC38 - Overall Monitoring Data

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

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

11.4.4 Chlorophyll a

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

11.4.5 Mercury

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

11.5 Monitoring Plan for Assigned MS4 NPDES Regulated Waste Load Allocation

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

136 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

11.6 Identification of Additional Measures

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

11.7 Implementation of Additional Measures

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

11.8 Tracking Incremental Success

During FY2017, various BMP data parameters were identified to track incremental success within the TMDL watershed plan. These parameters and corresponding data for FY2018 are shown in sub-section 11.10 below.

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 Within 24 months the permittee shall prepare a plan that: None Develop TMDL Update TMDL Watershed Plan as necessary. (On-going, years and map  Identifies the watershed(s) subject to an approved Watershed Plan 3 – 5+) watershed, outfalls, TMDL with an approved Waste Load Allocation per requirements and streams (WLAs) assigned to the permittee, of the MS4  Includes a description of the watershed(s), permit by Feb  Includes a map of watershed(s) showing streams & 28, 2015. 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. Existing measures Within 24 months the Permittee’s plan: None Identify existing Continue to implement existing measures per TMDL plan.  Shall describe existing measures being implemented measures within (On-going, years 3 – 5+) by the Permittee designed to achieve the MS4’s TMDL plan by NPDES WLA and to reduce the TMDL pollutant of Feb 28, 2015. 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. Assessment of Within 24 months the permittee’s plan shall include an None Conduct a Continue to review and assess monitoring data as it becomes available assessment of available monitoring data. Where long-term review and available. (On-going, years 3 – 5+) monitoring data data is available, this assessment should include an assessment of analysis of the data to show trends. available monitoring data by Feb 28, 2015. 138 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

Monitoring Plan Within 36 months the permittee shall develop and submit None None Develop Complete monitoring Complete monitoring to the Division a Monitoring Plan for the permittee’s monitoring activities specified in activities specified in assigned NPDES regulated WLA as specified in the plan for each the plan by June 30, the plan by June 30, TMDL. The permittee shall maintain and implement the TMDL 2017. Assess 2018. Assess Monitoring Plan as additional outfalls are identified and as watershed for monitoring data monitoring data accumulating data may suggest. Following any review and the TMDL collected under the collected under the comment by the Division the permittee shall incorporate pollutants of monitoring plan to monitoring plan to any necessary changes to monitoring plan and initiate the concern by determine determine plan within six months. Modifications to the monitoring Feb 28, 2016. effectiveness of effectiveness of plan shall be approved by the Division. Upon request, the Water Quality Water Quality requirement to develop a Monitoring Plan may be waived Programs by Programs by by the Division if the existing and proposed measures are December 31, 2017. December 31, 2018. determined to be adequate to achieve the MS4’s NPDES Update monitoring Update monitoring WLA to MEP within the watershed to which the TMDL plan as necessary plan as necessary applies. based on data review based on data review and assessment and assessment activities. activities.

Additional Within 36 months the permittee’s plan shall: None None Determine Continue to evaluate and update additional Measures  Describe additional measures to be implemented additional measures per TMDL plan, as needed. (On- by the permittee designed to achieve the measures that going, years 4 – 5+) permittee’s MS4’s NPDES WLA and to reduce may be needed the TMDL pollutant of concern to the MEP within to achieve the watershed to which the TMDL applies; and assigned MS4  Provide an explanation as to how those measures NPDES are designed to achieve the permittee’s MS4’s regulated NPDES regulated WLA to the MEP within the WLA and watershed to which the TMDL applies. address TMDL pollutant of concern by Feb 28, 2016. Implementation Within 48 months the permittee’s plan shall: None None None Develop an Continue to Plan  Describe the measures to be implemented within implementation plan implement additional the remainder of the permit term designed to for identified measures per the achieve the MS4’s NPDES WLA and to reduce additional measures plan. the TMDL pollutant of concern to the MEP and that may be needed to  Identify a schedule, subject to DWQ approval, for achieve assigned completing the activities. MS4 NPDES regulated WLA and address TMDL 139 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

pollutant of concern by Feb 28, 2017. Incremental The permittee’s plan must outline ways to track and report None None None Develop a Continue to track and Success successes designed to achieve the MS4’s NPDES regulated methodology to track report successes per WLA and to reduce the TMDL pollutant of concern to and report data and the plan. MEP within the watershed to which the TMDL applies. 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. Reporting The permittee shall conduct and submit to the Division an None Prepare an annual assessment of activities and data analysis for the TMDL annual assessment of the program designed to achieve the watershed plan. Provide this information in the NPDES MS4 permit annual report. MS4’s NPDES WLA and to reduce the TMDL pollutant of (On-going, years 2 – 5+) 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.

140 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

11.10 Program Assessment and Reporting

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

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Table 11-4: TMDL Program Summary for FY2018 TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar Public Education and Outreach Utility bill inserts 113,912 68,985 125,077 73,105 330,703 9,038 38,413 53,167 Environmental notices and brochures distributed 116 Media advertisements (TV and radio) 731

Pet waste messages 0 Pet waste receptacles 120 Website inquiries 275,595 Social media posts 1,389 Social media responses 1,458

Public requests to hotline 8,329 CMCSI education workshops conducted 3 Citizens educated at CMCSI workshops 342 Public events 35 Attendees at public events 4,394

Public presentations 16 Citizens educated at public presentations 690 School presentations 3 01. 2 5 1 01. 12 01. Students educated 77 01. 340 372 95 01. 387 01. Fats Oils & Grease (FOG) brochures distributed 2,107 FOG presentations 15 Citizens educated on FOG program 5,783 Public Involvement Storm drains marked 430 01. 154 6 921 41 39 214 Adopt-A-Stream trash removed (lbs.) 10,620 01. 26,540 340 8,360 01. 1,625 1,680 Adopt-A-Stream miles cleaned 25 01. 46 2 34 01. 7 6 Big Spring Clean trash removed (lbs.) 755 100 275 01. 55 01. 01. 01. Big Spring Clean stream miles cleaned 4 1 2.5 01. 3 01. 01. 01. Volunteer Monitoring samples 01. 01. 1 01. 2 01. 01. 01. Trees planted 1,550 Adopt-A-Street bags of trash collected 1,293 1. Activity not conducted in this watershed during fiscal year 2018. 142 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

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. 65 01. 01. 01. 01. 92 Stream walk outfalls inspected 01. 01. 176 01. 9 01. 01. 132 Dry weather flows detected 01. 01. 56 01. 2 01. 01. 38 Dry weather flows sampled 01. 01. 56 01. 4 01. 01. 45 Stream walk IDDE problems detected/corrected 01. 01. 4 01. 0 01. 01. 5 Multi-family sewer system inspections 1 01. 17 1 6 01. 1 2 Multi-family sewer system O&M plans prepared 01. 01. 9 01. 5 1 1 1 Multi-family sewer system personnel trained 12 Stormwater pollution ordinance violations/NOVs issued 19 4 39 8 13 1 3 18 Stormwater pollution ordinance penalty enforcements 2 01. 2 1 2 01. 01. 5 issued Septic system failures detected/corrected 5 1 6 8 10 1 1 3 Municipal employees trained on IDDE 1,723 Sanitary sewer ordinance NOVs issued 42 Sanitary sewer system pretreatment inspections 200 Sanitary sewer system FOG inspections 4,400 Sanitary sewer system miles cleaned 1,168

Sanitary sewer system ROW miles cleared 107 Sanitary sewer system miles re-lined 15 Sanitary sewer system manholes inspected 8,906 Sanitary sewer system lift stations maintained 81 Sanitary sewer system overflows corrected 164 IDEP business corridor inspections 128 IDEP outfall inspections 1 01. 2 01. 01. 01. 01. 01. IDEP problems detected/corrected 4 01. 5 1 01. 01. 01. 2 IDEP fecal sampled collected 01. 01. 01. 01. 01. 01. 01. 01. Citizen service requests responded to 66 1 180 29 94 2 12 35 1. Activity not conducted in this watershed during fiscal year 2018.

143 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar Construction Site Stormwater Runoff Control Erosion control ordinance NOVs issued 5 2 23 01. 38 01. 01. 01. Erosion control ordinance penalty enforcements issued 5 5 7 01. 1 1 01. 01. Project/site plans reviewed 96 73 177 40 84 15 52 81 Sites inspected 21 362 947 87 406 50 135 196 Post-Construction Stormwater Management Post-Construction ordinance NOVs and CARs issued 570 Post-Construction education workshops conducted 1

Citizens educated at Post-Construction workshops 120 Project/site plans reviewed 145 Buffer protected/added (acres) 57 Buffer mitigation plans approved 1 1 5 01. 4 01. 2 2 SCMs added 5 1 13 3 16 01. 3 3 SCMs inspected 114 64 130 95 37 1 111 205 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 0 8 01. 2 01. 01. 5 Catch basin tops cleaned (manual or vacuum) 83,688 Catch basins cleaned (manual or vacuum) 1,639 Pipe cleaned (manual or vacuum) 22,037 Street sweeping (miles swept) 57,449 Street sweeping debris/ROW trash removed (tons)2. 3,199 Yard waste collected (tons) 55,889

City street ROW dead animal removal (tons) 31 1. Activity not conducted in this watershed during fiscal year 2018. 2. Tonnage includes debris/trash picked up from street sweepers and street ROW debris/trash collected by hand.

144 City of Charlotte – MS4 Stormwater Management Program – FY2018 Annual Report

TMDL WATERSHED BMP Citywide Irwin Lake Wylie Little Sugar Long McAlpine McKee Steele Sugar Industrial Facilities Industrial facilities inspected 9 01. 10 3 01. 01. 01. 14 Vehicle maintenance facilities inspected 3 01. 8 01. 01. 01. 01. 4 Industrial facilities monitored 5 01. 2 01. 01. 01. 1 1 Illicit discharges or connections detected/corrected 4 01. 6 1 01. 01. 01. 4 Water Quality Monitoring Fixed interval TSS samples collected 13 13 53 13 66 13 13 26 Fixed interval Turbidity samples collected 13 13 53 13 66 13 13 26 Fixed interval Dissolved Oxygen samples collected 12 12 45 12 57 12 12 24 Fixed interval Fecal Coliform samples collected 18 13 66 18 80 16 16 34 CMANN Turbidity observations/readings2. 7,496 7,228 57,940 7,044 18,533 6,364 12,020 10,761 CMANN Dissolved Oxygen observations/readings 2. 7,305 8,289 66,273 7,894 29,780 7,807 18,794 11,631 Action/watch level follow-up investigations conducted3. 2 01. 3 2 2 01. 01. 1 1. Activity not conducted in this watershed during fiscal year 2018. 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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