city of cumming storm water management programsedimentation, and post -construction); 2) standard...

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City of Cumming Storm Water Management Program

Revised September, 2013

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General Information for Submitting a SWMP

• Your Storm Water Management Program (SWMP) becomes a part of the NPDES Permit, upon SWMP approval. It must be a complete document containing all the necessary components. Although ordinances, procedures, etc., were submitted with the previous SWMPs, the current SWMP must include the most recent version of these documents. Ensure that you submit all of the necessary components, including copies of the latest versions of the following: 1) Adopted stormwater ordinances (Illicit Discharge, Erosion and

Sedimentation, and Post-Construction); 2) Standard Operating Procedures (e.g. dry weather screening procedures,

construction site inspection procedures, street sweeping procedures); 3) Blank copies of forms to be used to implement the SWMP, including

inspection forms; 4) Signed Memorandum of Agreements; and 5) Maps and inventories.

• The NPDES Permit contains a table for each of the minimum control measures

(MCMs). For four of the MCMs, the BMPs in the table contain a measurable goal that states what must be submitted with each annual report. Incorporate this information into the BMP’s measurable goal in your SWMP. If the Permit does not specify what must be submitted, then the measurable goal for each BMP in your SWMP must still state what documentation will be submitted with the annual report.

• Documentation to be submitted as appendices to the SWMP can be submitted by

hard copy or on CD. For example, copies of ordinances or maps can be submitted using either method. If information is submitted on a CD, EPD must be able to open and read all files on the CD (e.g. GIS maps).

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STATE OF GEORGIA DEPARTMENT OF NATURAL RESOURCES ENVIRONMENTAL PROTECTION DIVISION

Storm Water Management Program (SWMP)

General NPDES Permit No. GAG610000 for Small Municipal Separate Storm Sewer Systems (MS4)

1. General Information

A. Name Of small MS4:_City Of Cumming B. Name of responsible official: Jonathan W. Heard

Title: Director of Utilities Mailing Address: 100 Main Street

City: Cumming State: GA. Zip Code: 30040 Telephone Number: (770) 781-2020 C. Designated stormwater management program contact: Name: Jonathan W. Heard Title: Director of Utilities Mailing Address: 100 Main Street City: Cumming State: Ga. Zip Code: 30040 Telephone Number: (770) 781-2020 Email Address: [email protected] 2. Sharing Responsibility

A. Has another entity agreed to implement a control measure on your behalf? Yes_______ No (If no, skip to Part 3)

Control Measure or BMP: 1. Name of entity: N/A

2. Control measure or component of control measure to be implemented by entity on your behalf: N/A

B. Attach an additional page if necessary to list additional shared responsibilities. It is mandatory that you submit a copy of a written agreement between your MS4 and the other entity Demonstrating written acceptance of responsibility.

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3. Minimum Control Measures* and Appendices

A. Public Education and Outreach B. Public Involvement/Participation C. Illicit Discharge Detection and Elimination D. Construction Site Stormwater Runoff Control E. Post-Construction Stormwater Management in New Development and

Redevelopment F. Pollution Prevention/Good Housekeeping G. Appendix – Enforcement Response Plan H. Appendix – Impaired Waters

4. Certification Statement I certify under penalty of law that this document and all attachments were

prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based upon my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Printed Name: Jonathan W. Heard Date: __________________ Signature: _______________________________ Title: Director of Utilities

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Storm Water Management Program

Public Education and Outreach on Storm Water Impacts

40 CFR Part 122.34(b)(1) Requirement: The permittee must implement a public education program to distribute educational materials to the community and/or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and the steps that the public can take to reduce pollutants in storm water runoff. See Table 4.2.1(a) of the Permit A. Best Management Practice (BMP) #1- Consumer Confidence Report Storm

Water Education Section

1. Target audience: All City of Cumming Water and Sewer Customers

2. Description of BMP: Include an educational section within the annual Consumer Confidence Report (CCR). Examples of educational subjects to be discussed are the SWAP program as it relates to drinking water, lists of potential pollutants, the City’s Storm Water Marking Program, a hotline to call to report illegal dumping or illegal discharges, and the City’s Web Site which will contain additional and more in depth information on storm water protection.

3. Measurable goal(s): a. Select subjects to be discussed in CCR. b. Reach 100% of all City of Cumming water and sewer customers- a total of approximately 17,360 customers.

4. Documentation to be submitted with each annual report: A copy of the Consumer Confidence Report will be included in the annual report.

5. Schedule:

a. Interim milestone dates (if applicable): N/A

b. Implementation date (if applicable): Currently Implemented

c. Frequency of actions (if applicable): Annually d. Month/Year of each action (if applicable: Once per year during

permit cycle

6. Person (position) responsible for overall management and implementation of the BMP: Jonathan W. Heard, Director of Utilities

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7. Rationale for choosing BMP and setting measurable goal(s): The public is already familiar with this publication. This will help the City to educate the public about water, utilizing a holistic approach- allowing the City to tie storm water quality to drinking water quality.

8. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Storm water awareness to the public is a great method to help us know when related issues arise, along with the corrective and preventative measures in place. No changes to this BMP at this time.

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B. BMP #2 – Educational Section on the Cumming Utilities Web Site (

www.cummingutilities.com).

1. Target audience: Citizens who visit Cumming Utilities Web Site

2. Description of BMP: The City includes storm water educational material, information, and downloads on its Department of Utilities web site. This information has been obtained from the USEPA, The Clean Water Campaign, and the Metropolitan North Georgia Water Planning District web sites. Materials include, but are not limited to, the EPA the solution to stormwater pollution brochure, EPA Children’s Storm Water Stickers, EPA’S Urban Runoff Poster. Other topics that are discussed are the City’s SWAP program, City’s Storm Water Marking program. The City advertises this website by placing a notice on of the 17,360 water bills that go out each month. In addition, the website will be advertised on the annual CCR (mailed out to our 17,360 customers).

3. Measurable goal(s): Install a “ counter” on the website and reach

100% of all those citizens who visit www.cummingutilities.com.

4. Documentation to be submitted with each annual report: The number of

visitors and screen shots will be included in the annual report. 5. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Annual Updates d. Month/Year of each action (if applicable): Ongoing

6. Person (position) responsible for overall management and implementation

of the BMP: Jonathan W. Heard, Director of Utilities 7. Rationale for choosing BMP and setting measurable goal(s): Citizens

visit the Cumming Utilities Web Site on a regular basis to find information about water, sewer, and garbage services. These citizens will be impacted while researching this website.

http://www.cummingutilities.com/

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8. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: The City of Cumming Utilities website is a great resource for our customers to find out information. A useful tool updated on the events, policy and ordinance changes along with general information needed for the convenience to the public. No changes to BMP at this time.

Note: At a minimum, the MS4 must include a BMP in the SWMP for each BMP listed in

the NPDES Permit. For those minimum control measures (MCM) without specific BMPs listed in the Permit, the MS4 should implement at least 2 BMPs for each MCM. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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C. BMP #3- Display Storm Water Pamphlets at City Hall and Other Events

1. Target audience: Those citizens visit City Hall to pay a utility bill, investigate the availability of water and sewer service, and those who visit events throughout the year.

2. Description of BMP: The City provides pamphlets to City Hall and

different events throughout the year so interested citizens can obtain more information about storm water and water pollution. The City uses the EPA pamphlet “A Citizens Guide to Storm Water”. These pamphlets are restocked quarterly.

3. Measurable goal(s): The minimum number of pamphlets stocked on

the shelves is based on the number we are allocated from suppliers to provide to our citizens. Usually 25 to 50 of each pamphlet.

4. Documentation to be submitted with each annual report: Inventory lists

and the number of pamphlets handed out to public at City Hall, Mailings, and events annually.

5. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Quarterly Restock d. Month/Year of each action (if applicable): Ongoing


of the BMP: Jonathan W. Heard, Director of Utilities 7. Rationale for choosing BMP and setting measurable goal(s): Citizens

who are seeking more information about a specific subject will go to the local library or to a local government building. These citizens will probably be concerned citizens who wish to become involved and help with environmental issues such as protection of storm water quality.

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8. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Designed to educate public about storm water issues around the home and businesses. Potential hazards and proper methods on correcting these issues. Hopefully answer questions about any storm water related issues. No changes to this BMP at this time.



Public Education & Outreach

D. BMP #4 – Septic Tank Workshop

1. Target audience/stakeholder group: Residential citizens, contractors, and community leaders who live and/or

work in the City of Cumming. 2. Description of BMP:

The City to conduct an annual workshop in a classroom environment that focuses on educating the public about the importance of septic sewer system maintenance and its potential hazards to the storm water system.

3. Measurable goal(s):

The City’s goal is to reach at least 5 citizens, contractors, and/or community leaders to attend the workshop per year.

4. Documentation to be submitted with each annual report:

Sign-up sheet documenting the workshop attendance along with any handouts or other information relevant to the workshop

5. Schedule:

a. Implementation date: 2015

b. Frequency of actions: Annually c. Month/Year of each action: Summer Month

6. Person (position) responsible for overall management and

implementation of the BMP: Jonathon W. Heard, Director of Utilities City of Cumming, Georgia 7. Rationale for choosing BMP and setting measurable goal(s):

The City believes that a septic tank workshop will increase the community awareness of the issue. The workshop should educate citizens/contractors of the importance of septic system maintenance and the potential impact it can have on the storm water system.

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Public Involvement/Participation

40 CFR Part 122.34(b) (2) Requirement: The permittee must, at a minimum, comply with State and local public notice requirements when implementing a public involvement/ participation program. See Table 4.2.2 (a) of the Permit A. Best Management Practice (BMP) #1- Annual Stream Cleanup Using Rivers Alive Format.

1. Target audience/stakeholder group: Community Groups and Volunteers

2. Description of BMP: The City sponsors an annual stream cleanup

using the Rivers Alive format. Each fall, the City organizes a cleanup event of a stream within the city limits of Cumming. The City determines the quantity of tires, trash, and appliances removed from the streams during the annual event. A City employee (event coordinator) is heavily involved with the event and is on site to ensure that the event is properly implemented. The coordinator hands out tee shirts and posters at the event.

3. Measurable goal(s): Hold one stream cleanup event annually

4. Documentation to be submitted with each annual report: Total number of

volunteers and trash data along with pictures of the event. Receipts from items bought to hold the event.

5. Schedule:



c. Frequency of actions (if applicable): Ongoing Annually d. Month/Year of each action (if applicable): Annually Each Fall


of the BMP: Jonathan W. Heard

7. Rationale for choosing BMP and setting measurable goal(s): The Rivers Alive program is already in existence and already recognizable by many citizens. Citizens will become more aware of our local streams and the issues associated with water quality. Streams will no longer be “out of sight out of mind”.

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8. How you will determine whether this BMP is effective in accordance with

Part 5.1.4 of the Permit: It is obvious that the effectiveness of this BMP will be beneficial to reduce the amount of trashes along our streams and waterways. The help of the community volunteers will keep our City a great place to live. No changes to this BMP at this time.

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B. BMP #2 – Great American Cleanup

1. Target audience/stakeholder group: Community Groups and Volunteers

2. Description of BMP: The City sponsors an annual Great American Cleanup event annually with Keep Forsyth Beautiful. Each spring the event is held, and trash is picked up along roadways, waterways, and surrounding areas within the city and county. A City employee or team is heavily involved in the organizing, planning, and conducting the event so that it is properly implemented. The volunteers and groups receive a free lunch and tee shirts from sponsors at the completion of the event.

3. Measurable goal(s): Hold one event annually 4. Documentation to be submitted with each annual report: Total number of

volunteers, trash totals, and pictures. Receipts from costs of holding the event.

5. Schedule:



c. Frequency of actions (if applicable): Advertise the Great American Cleanup in the spring- ongoing

d. Month/Year of each action (if applicable): Annually in the spring


of the BMP: Jonathon W. Heard, Director of Utilities

7. Rationale for choosing BMP and setting measurable goal(s): The Great American cleanup is already implemented on an annual basis, and has been a great success story in the community. It seems to grow each year and thus reduces pollution.


Part 5.1.4 of the Permit: This BMP is an effective tool to reduce the amount of trash and pollution from roads and waterways. It is very cost effective and it allows the community to feel involved by making a difference. No changes to this BMP at this time.

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C. BMP#3 – Storm Drain Marking Program

1. Target audience: Residential, Commercial, and Industrial Water and Sewer Customers.

2. Description of BMP: City coordinated storm drain marking program to

raise awareness among residential, commercial, and industrial land owners. The City asks that property owners volunteer to install storm sewer decals on their local storm drains on their property. The City also works with local school groups, Boy Scout Troops, and other groups to help instruct them on how to properly install the decals. The Storm Sewer Marking Program is advertised in the annual CCR. Other modes of informing businesses of the Storm Water Marking Program are through flyers distributed with business licenses and with water bills and on the web site www.cummingutilities.com. Section 23 and 24.

3. Measurable goal(s): Install at least 50 decals on storm sewers within

the City Limits each year. Require new developments to mark 100% of their storm drains. Contact volunteer groups to install the decals.

4. Documentation to be submitted with each annual report: The number of

decals applied to streets, list of streets getting decals, and pictures of volunteers and groups

5. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Annually and ongoing d. Month/Year of each action (if applicable): Each Spring- Contact

Volunteer Groups to help

6. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard

7. Rationale for choosing BMP and setting measurable goal(s). Ease of

communication with City Water and Sewer customers and those who hold a City business license. Industrial Pretreatment Coordinator interacts with industrial and commercial customers to generate interest in the program. The public has begun seeing the decals along the roadways and sidewalks. And this generates interest in


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additional marking. When an individual sees a Storm Sewer decal, they are reminded that what they place in the storm drain eventually leads to a body of water.

8. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: The objective here is to let people know not to put trash in or around catch basins to prevent trash from getting into our waterways. It also provides a warning not to do it. Hopefully it effectively limits the amount of trash going into the drains. No changes to this BMP at this time.


the NPDES Permit. For those MCMs without specific BMPs listed in the Permit, the MS4 should implement at least 2 BMPs for each MCM. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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Illicit Discharge Detection and Elimination

40 CFR Part 122.34(b) (3) Requirement: The permittee must develop, implement and enforce a program to detect and eliminate illicit discharges into your small MS4. You must:

A) Develop, if not already completed, a storm sewer system map, showing the location of all outfalls and the names and location of all waters of the State that receive discharges from those outfalls;

B) Effectively prohibit, through ordinance, or other regulatory mechanism,

non-storm water discharges into your storm sewer system and implement appropriate enforcement procedures and actions;

C) Develop and implement a plan to detect and address non-storm water

discharges, including illegal dumping, to your system; and D) Inform public employees, businesses, and the general public of hazards

associated with illegal discharges and improper disposal of waste.

See Table 4.2.3 (a) of the Permit A. Best Management Practice (BMP) #1 Legal Authority

1. Description of BMP: Legal and binding City Utility Ordinance to hold

Public responsible for illegal discharges and connections to the storm water system.

2. Measurable goal(s): To ensure that the storm water system is

protected from any wrong doing, and correct problems that are observed according to the ordinance.

3. Documentation to be submitted with each annual report: Copy of the

Utilities Ordinance with Sections 70-421 through 70-426 to be observed

4. Schedule:



c. Frequency of actions (if applicable): Daily

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d. Month/Year of each action (if applicable): Annually


of the BMP: Jonathon W. Heard, Director of Utilities 6. Rationale for choosing BMP and setting measurable goal(s): The City has

to set standards and legal ordinances to protect the public and community from illegal discharges and connections. It is important that our water quality is in the best state of existence before we potentially consume it.


Part 5.1.4 of the Permit: This BMP is regulated through the City ordinance, and there are no changes to this BMP at this time.

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B. BMP #2 City Outfall Map and List of Total Outfalls

1. Description of BMP: City Outfall Map and List of Total Number of Identified Outfalls

2. Measurable goal(s): Continue to update Outfall Map from new

construction and newly identified outfalls in the storm water system.

3. Documentation to be submitted with each annual report: Revised map

and List of existing and newly identified outfalls discovered 4. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Ongoing d. Month/Year of each action (if applicable): Annually


of the BMP: Jonathon W. Heard 6. Rationale for choosing BMP and setting measurable goal(s): The City is

obligated to map its existing Utilities for public uses.

7. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Mapping utilities is important to future development, and other entities. There are no changes to this BMP at this time.


the NPDES Permit. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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C. BMP #3 Dry Weather Flow- Outfall Screening Program for Illicit Discharges,

-- Source Tracing and Removal Procedures.

1. Target audience: Residential, Commercial Outfall Sites 2. Description of BMP:

The City has developed a dry weather screening program to inspect outfalls and sample dry weather flow to determine if the upstream facilities/connections are discharging non-Storm Water flows to the drainage systems in the City of Cumming limits. City staff developed procedures that included:

a. What constitutes dry weather flow (i.e., any flow after 72

hours without significant rain event of over 0.1- inches). b. Parameters to be sampled for, if dry weather flow is

detected. c. Acceptable baseline limits for chosen parameters. d. Equipment used for sampling. e. Identify field sampling team. f. Staff training. g. Laboratory to be used for fecal coliform testing. h. Sampling schedule. i. Procedure for reporting a potential illicit discharge.

City staff determined the outfall locations that will be sampled annually and submitted them to the EPD with dry weather screening procedures. If there is dry weather flow, and if the limits of any of the sampling parameters are above their acceptable baseline limits, the City will initiate the source tracing and removal program.

Once an illicit discharge is detected through the dry weather screening program, it is the responsibility of the City to attempt to trace the source and, remove the illicit connection within the urbanized area. The source tracing program involves four elements:

a. Visual inspection. b. Additional Field Sampling. c. Dye Testing, if necessary. d. Storm Water Site Inspection.

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Upon detection of a potential illicit discharge, City staff visually inspect upstream of the outfall in question to search for evidence indicating the source of the illicit discharge or illegal dumping. If the upstream search does not definitive evidence of the source, the City staff may elect to perform one or all of the following: additional field sampling, dye testing, sewer line televising, and or Storm Water inspection. Additional field sampling may be performed within the conveyance system. Samples are taken at Storm Sewer line connections and convergences to determine the source of illicit discharge. A composite or 24- hour mechanical sampling device may also be utilized in the event there is evidence of intermittent discharging. The City may also elect to perform a Storm Water Site inspection at a facility suspected of having an illicit connection. A standard Storm Water Inspection Checklist has been developed for use during these site inspections. Potential illegal connections, such as floor drains, will be investigated as part of the inspection. Dye testing may be performed if the suspected illicit connection is likely to be an illegal sanitary sewer line tie in or leaking septic tank. ( i.e. sampling revealed high levels of fecal coliform, detergent, or high conductivity). In dye testing, nontoxic fluorescent dye is flushed down the drain, or toilet, and if the dye appears in the Storm Sewer System, then an illegal tie in is confirmed. Upon identification of a source of illicit discharge, it will be the City of Cumming Director of Utilities responsibility to enforce the Illicit Discharge provisions as called for in local ordinances. These regulations give the City the authority to require parties illegally discharging to the MS4 to remove the illicit connection as well as penalize violators of the ordinance. 3. Measurable goal(s): Dry weather screening of selected outfalls at 20% per year. 100% of suspected illicit discharges investigated and 100% of identified illicit discharges removed.

4. Documentation to be submitted with each annual report: Outfall inspection forms and any Dry weather flow testing results if any are found during inspection. 5. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Ongoing d. Month/Year of each action (if applicable). Annually

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of the BMP: Jonathon W. Heard 7. Rationale for choosing BMP and setting measurable goal(s): This

program has been implemented to stop illegal discharges into the local MS4. This BMP utilizes the City staff to screen strategic drainage outfalls in the City to identify and trace prohibited connections to our systems. This BMP meets specific requirements of the NPDES Phase II MS4 Permit.


Part 5.1.4 of the Permit: By Eliminating illegal discharges when found, and using the proper trace and removal procedures the City can use enforcement measures to ensure it is corrected. No changes to this BMP at this time.



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D. BMP #4 – City of Cumming Website

1. Description of BMP: The City of Cumming maintains a website for disseminating information to the public and City employees. This page has been expanded by the City staff to include a link to a new Storm Water management page that houses information about the City’s Storm Water Management Program including information on tips for lawn care and garden activities, water conservation, proper disposal of household wastes, household recycling, septic tank maintenance, hazards of illegal discharge and dumping, and other sources of water quality violations. Electronic versions of informational brochures are included on the website. A citizen complaint contact number has been listed, and a link has been included so that citizens can report water quality and E & S violations electronically via email. The website is updated on an on-going basis to provide new Storm Water related information and links. The web site host includes a “hits counter” that enables the City to determine how many people visited the site during a specific time period.

2. Measureable Goal(S): Reach 100% of all those citizens who visit www.cummingutilities.com.

3. Schedule:

a. Interim Milestone Dates ( if applicable) : N/A b. Implementation Date ( if applicable): Currently implemented c. Frequency of actions ( if applicable): Ongoing d. Month/ Year of each action ( if applicable) : N/A

4. Person ( position) responsible for overall management and implementation of the

BMP: Jonathon W. Heard, Director of Utilities

5. Rationale for choosing BMP and setting measurable goal(s): Citizens visit the Cumming Utilities website on a regular basis to find information about water, sewer, and garbage services. These citizens will be impacted while searching this website.

6. How will you determine whether this BMP is effective in reducing storm water pollution in accordance with 5.1.4 of the permit: The website is another tool used to educate, provide public awareness, and information so the City can get instant notifications out to the community. No changes to this BMP at this time.


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E. BMP#5- Complaint Response for Illicit Discharge, Investigating, and Tracking.

1. Target audience / stakeholder group: Residential, Commercial, and general public.

2. Description of BMP: Receive complaints regarding illicit discharges and

connections and responding to them in an investigation, and tracking procedures described in BMP#3. Complaints can be generated through phone call or website. A complaint sheet will be filled out with the date, time, type of complaint, and the status of that complaint.

3. Measureable Goal: The City’s goal is to eliminate any illicit discharges or

connections upon discovery through inspection or complaints from general public. Corrective measures are taken immediately once discharge is found and track to the source. Violations are then handled by the Director of Utilities.

4. Documentation to be submitted with each annual report: All complaint

forms, and tracking information if the complaint is found true. Any violation commits from Director of Utilities will also be submitted.

5. Schedule:

a. Interim milestone dates (if applicable): N/A b. Implementation Date (if applicable): Currently Implemented c. Frequency of actions (if applicable): Ongoing d. Month/ year of each action (if applicable) Annually

6. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities. 7. Rationale for choosing BMP and setting measureable goal(s): Any complaint concerning an illicit discharge or connection is considered a hazard and threat to the community and it is important to address any complaint and follow through with procedures to eliminate such hazards. 8. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Effective in handling any illicit discharge complaints that may be received by using tracking, and violation procedures that are in place. No changes with this BMP at this time.

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Construction Site Storm Water Runoff Control

40 CFR Part 122.34(b)(4) Requirement: The permittee must develop, implement, and enforce a program to reduce pollutants in any storm water runoff to the MS4 from construction activities that result in a land disturbance of greater than or equal to one acre. Storm water discharges from construction activity disturbing less than one acre must be included in the permittee’s program if that construction activity is part of a larger common plan of development or sale that would disturb one acre or more. The program must include:

A) An ordinance or other regulatory mechanism to require erosion and sediment controls, as well as sanctions to ensure compliance;

B) Requirements for construction site operators to implement appropriate

erosion and sediment control best management practices; C) Requirements for construction site operators to control waste such as

discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality;

D) Procedures for site plan review which incorporate consideration of

potential water quality impacts; E) Procedures for receipt and consideration of information submitted by the

public; and F) Procedures for site inspection and enforcement of control measures.

See Table 4.2.4 (a) of the Permit

A. Best Management Practice (BMP) #1

1. Description of BMP: Ordinance adoption date April 20, 2010. The

Litter Control and Storm Water ordinance work jointly to ensure all construction waste is removed before final acceptance is approved by the City. Section 70-208, and Section 70-373,374.

2. Measurable goal(s): To make sure all waste including construction

waste is properly disposed of before final approval is accepted on a construction project.

3. Documentation to be submitted with each annual report: Copy of

ordinance referring to these particular sections

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4. Schedule:



c. Frequency of actions (if applicable): Ongoing d. Month/Year of each action (if applicable: Annually

5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard

6. Rationale for choosing BMP and setting measurable goal(s): To ensure

all waste including construction waste is properly disposed of.

7. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: During inspections to see if the proper disposal techniques have been implemented. No Changes to this BMP at this time.

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C. BMP #2 – Site Plan Review

1. Target audience/stakeholder group: Any contractor, developer, or citizen that wishes to develop land in the City Limits.

2. Description of BMP: The City is its own Issuing Authority, and

remains in compliance with the Georgia Erosion and Sediment Control Act (GESA) of 1975 as amended in 2003. Accordingly, all developers are required to comply with local E&S Ordinance and obtain a land disturbance permit prior to the start of any land disturbing activities within the corporate city limits of Cumming.

Site plans that are submitted to the City of Cumming for land

disturbing activities that disturb more than one acre of land or are within 200 feet of state waters are considered a Major Permit Site Plan. All Major Permit Site Plans are sent to the Natural Resource Conservation Service (NRCS) for review. Major Permit Site Plans are reviewed for their compliance with the requirements of Georgia Erosion Soil Act, which includes the requirement to control turbidity in the site runoff, control impacts on receiving streams and the implementation of the minimum control measures. Major Permit Site Plan is also reviewed for compliance with the Georgia Erosion Sediment Manual, the “Green Book”, which contains specific design standards and requirements for E&S BMPS. Once the Major Permit Site Plan is approved by NRCS, it is returned to the City of Cumming. The City will then review the Major Permit Site Plan to ensure that there are provisions for non-sediment related pollution control, e.g. secondary containment for fuel storage. Once the Major Permit Site Plan is approved, the developer is issued a Land Disturbance Permit (LDA) and can commence with land disturbing activities.

Minor Permit Site Plans are reviewed by City staff for compliance

with the requirements of the Georgia Erosion Soil Act, which includes the requirement to control turbidity in site runoff, control impacts on receiving streams and the implementation of the minimum control measures. Minor Permit Site Plans are also reviewed for compliance with the Georgia Erosion and Sediment Manual, the “Green Book”, which contains specific design standards and requirements for E&S BMPs. Minor Permit Site Plans are considered minor if the land disturbing activities associated with the project disturb less than one acre and no more than 200 feet from state waters. The City also reviews the Miner Permit Site Plan to ensure that there are provisions for non-sediment related pollution control, e.g. secondary containment for fuel storage. Once the Minor Permit Site Plan is approved, the developer is issued a Land

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Disturbance Permit (LDA) and can commence with land disturbing activities.

The City of Cumming has adopted the new Model E&S Ordinance. This amended ordinance requires that local developers pay permit fees of $40.00 per disturbed acre to the City and $40.00 per disturbed acre to the EPD.

3. Measurable goal(s): a. NRCS reviews site plans for compliance with GESA and the Green Book if one acre or more than 1- acre is disturbed or if the land is within 200 feet of State waters. City of Cumming reviews all Site Plans for compliance with GESA and the Green Book if less than 1- acre of land is disturbed and if the land is more than 200 feet away from State waters. b. 100% of Land Disturbance Permits are granted by the City of Cumming only after Site Plan is approved by the NRCS (for developments that disturb one acre or more acres or are within 200 feet of State waters.) or the City (for developments that disturb less than one acre and are more than 200 feet away from State waters).

4. Documentation to be submitted with each annual report: List of site plans received, reviewed, approved, or denied during the annual reporting cycle.

5. Schedule:


b. Implementation date (if applicable): Currently Implemented c. Frequency of actions (if applicable):

i. Review Site Plan – For each plan submitted ii: Issue LDA Permits- For all approved Site Plans

d. Month/Year of each action (if applicable): N/A


of the BMP: Scott Morgan, Director of Planning and Zoning

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7 Rationale for choosing BMP and setting measurable goal(s): Basic set up already exists. BMP has been implemented. The City is performing this effort as part of its responsibility as an Issuing Authority under the States Erosion and Sedimentation Act.

8. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Effectively directing storm water measures that need to be implemented before construction takes place. No changes to this BMP at this time.


the NPDES Permit. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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D. BMP#3 – Inspection Program

1. Target audience/ stakeholder group: Any contractor, developer, or person with a Land Disturbance Permit.

2. Description of BMP: The City of Cumming inspects active construction

projects within the City limits of Cumming that maintain Land Disturbance Permits. Sites are inspected for compliance with their approved Site Plan. All construction sites are inspected shortly after land disturbing activities have commenced to ensure that all E&S BMP’s are in place. Regular inspections are performed during construction based on the following priorities: o Evidence of erosion or sediment leaving the site. o History of noncompliance with approved site plan and E&S

regulations o Citizen complaints. o Proximity to local water ways. o A major rain event. o Size and nature of the development.

All construction sites are inspected after construction activity has ceased to ensure that the site has been properly stabilized. A checklist has been developed so that inspections are uniform, and also provide the City and the Land Disturbance Permit holder with a written record of the inspection findings. A log is kept by the City staff of all E&S inspection records.

3. Measureable Goal(s): a. 100% of construction sites with LDA permits will be inspected at the start of land disturbing activities.

b. 100 % of construction sites with LDA permits will be inspected at the close of land disturbing activities. c. 100% of construction sites found to be in noncompliance with their site plan will receive written notification of their violation. d. 100 % of construction sites that are found to be in noncompliance will be re-inspected to ensure that appropriate measures are implemented. e. 100% of records of inspections entered into City E&S log.

4. Documentation to be submitted with each annual report: All inspection site checklist and LDA permits for the year.

5. Schedule:

a. Interim Milestone Dates ( if applicable) : N/A

b. Implementation Date ( if applicable): Currently Implemented

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c. Frequency of actions (if applicable) : Ongoing

d. Month / Year of each action ( if applicable) Annually

6. Person ( position ) responsible for overall management and implementation of

the BMP: Scott Morgan, Director of Planning and Zoning

7. Rationale for choosing BMP and setting measurable goal(s): BMP is already implemented. The City is performing this effort as part of its responsibility as an ISSUING Authority under the States Erosion and Sedimentation Act.

8. How will you determine whether this BMP is effective in reducing storm water pollution in accordance with 5.1.4 of the permit: Ensure direction and procedure on keeping the construction site contained from runoff. Effectiveness determined by downstream inspections. No changes to this BMP at this time.

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D. BMP#4 Enforcement Procedures for Inspection Violations

1. Target audience/ stakeholder group: Any person or company holding a Land Disturbance Permit, or a violator digging without one.

2. Description of BMP: A site found to be in non-compliance, the Land Disturbance Permit holder is notified verbally at the time of inspection (if possible), and in written form, thereafter. The contractor is provided a copy of the inspection report and is given a timeline for compliance (not to exceed five days). At the end of the timeline, City E&S inspectors then re-inspect the site to ensure that the appropriate measures have been implemented. If the site is found to be in non-compliance with the approved Site Plan, the site will be considered in violation and the responsible person may be issued a Stop Work Order, given a citation, or could forfeit their bond. City E&S inspectors also inspect construction sites for improper disposal of litter and construction debris during all E&S inspections. Inspections are conducted to ensure that the non-sediment related pollution control measures described in the Site Plan and defined in the NPDES Phase II Storm water Permit are properly implemented/ addressed. When such activity is discovered, the City will require the responsible party to clean up the site, or face enforcement measures described in the applicable ordinance.

3. Measurable Goal(s): 100% of construction sites found in non-compliance with their Site Plan will receive written notification of their violation. 100 % of construction sites that are found to be in noncompliance will be re-inspected to ensure that appropriate measures are implemented.

4. Documentation to be submitted with each annual report: Copies of all

violations notices including Stop Work Orders, citations, or bond forfeitures if any are given.

5. Person (position) responsible for overall management and implementation of the BMP: Scott Morgan, Director of Planning and Zoning.

6. Rationale for choosing BMP and setting measureable goal(s): BMP is already in place. The City is doing its part to enforce the ordinance as an Issuing Authority under the States Erosion and Sedimentation Act.

7. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Ensure that enforcement of the ordinance and Permit is

upheld.

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E. BMP#5 –Citizen Complaint Database

1. Target audience/stakeholder group: Any citizens for how complaints to report to the City for possible violation

2. Description of BMP: The City has a Citizen Complaint database for City staff to record citizens’ complaints related to water quality, including those dealing with erosion and sedimentation. The City member who receives the complaint call is responsible for entering the date, time, location, and nature of the complaint as well as contact information for the electronic Citizen Complaint Database. The Database is shared so all City departments can access it for updates. The Citizen Complaint Database is checked daily by City Inspectors, and Utilities personal.

3. Measure Goal(s):

a. Continuous update of database. b. Inspectors investigate 100% of all water quality violation calls

received within two business days. c. City staff takes appropriate action for 100% of complaints that require

it. d. Website complaints are recorded and a response is made if

necessary.

4. Documentation to be submitted with each annual report: Any complaint documentation including date of, type of complaint, and complaint status.

5. Schedule :

a. Interim Milestone Dates( if applicable): N/A b. Implementation Date (if applicable): Currently Implemented c. Frequency of actions ( if applicable):

i. Database update- as calls are received. ii. Complaint Investigations- as calls are received.

d. Month/ Y ear of each action ( if action) : Ongoing

6. Person (position) responsible for overall management and implementation of the BMP. Jonathan W. Heard, Director of Utilities, and Scott Morgan, Director of Planning and Zoning.

7. Rationale for choosing BMP and setting Measurable goal(s): The citizen

complaint database provides a way for residents of the City of Cumming to be involved ensuring that water quality violations are being investigated, This BMP helps citizens engage in local water resources protection thereby educating them about causes and effects of water pollution.

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8. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Effectiveness is determined by the way a complaint is handled in a timely manner, and the violator is informed about the issue along with a resolution to it. No changes to the BMP at this time.

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F. BMP#6 Erosion and Sedimentation Certification

1. Target audience/stakeholder group: City Employees

2. Description of BMP: GESA, as amended in 2003, now requires that all local government staff involved with E&S inspections or Site Plan review receive training from GWSCC on proper E&S control. This training is currently made available to City employees. The City has required that all of its E&S inspectors receive this training as well as those involved with ground disturbing activities such as water distribution crews. The City has certified several employees working in the scope of this BMP.

3. Measurable Goal(s): a. 100% of City E&S inspectors, site plan reviewers, are

certified as required by GESA, and existing certified personal are re-certified as required.

4. Documentation to be submitted with each annual report: The total number and type of E&S certifications held by City employees.

5. Schedule: a. Interim Milestone Dates (if applicable): N/A b. Implementation date (if applicable): Currently Implemented

c. Frequency of actions (if applicable): Ongoing

e. Month/Year of each action ( if applicable): Annually

6. Person (position) responsible for overall management and implementation of the BMP. Scott Morgan, Director of Planning and Zoning

7. Rationale for choosing BMP and setting measurable goal(s): E&S

certification/education is now a requirement of GESA, as amended in 2003.

8. How will you determine whether this BMP is effective in reducing storm water pollution in accordance with Part 5.1.4 of the Permit: Ensure all City employees are trained and certified in E&S. No changes to this BMP at this time.

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Post-Construction Storm Water Management in New Development and Redevelopment

40 CFR Part 122.34(b)(5) Requirement: The permittee must develop, implement, and enforce a program to address storm water runoff into the MS4 from new development and redevelopment projects, including projects less than one acre if they are part of a larger common plan of development or sale. You must:

A) Develop and implement strategies which include a combination of structural and/or non-structural BMPs appropriate for your community;

B) Use an ordinance or other regulatory mechanism to address post-

construction runoff from new development or redevelopment projects; and C) Ensure adequate long-term operation and maintenance of BMPs.

See Table 4.2.5 (a) of the Permit A. Best Management Practice (BMP) #1

1. Description of BMP: The City of Cumming has Post Construction

measures for New and Re-development in its Ordinance, Section 70-281 through Section 70-452. Adopt Georgia Storm Water Management Manual is also referenced.

2. Measurable goal(s): All approved storm water management plans

must follow guidelines of City Ordinance and the Georgia Storm water Management Manual.

3. Documentation to be submitted with each annual report: A certified copy

of the City of Cumming Utilities Ordinance with the above referenced sections tabbed.

4. Schedule:



c. Frequency of actions (if applicable): Ongoing d. Month/Year of each action (if applicable): Ongoing

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5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities

6. Rationale for choosing BMP and setting measurable goal(s): The City of

Cumming as the Issuing Authority has set standards in an Ordinance, approved by the EPD. To ensure that proper records and maintenance is done on storm water structures after final inspection has occurred.

7. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Keeping the ordinance updated. No changes to this BMP at this time.

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B. BMP #2 Inventory of Post Construction Structures

1. Description of BMP: Include an inventory of all post construction structures such as catch basins, junction boxes, Detention Ponds and Outfalls.

2. Measurable goal(s): Goal is to add new post construction structures

to the existing inventory for future inspection and maintenance.

3. Documentation to be submitted with each annual report: A copy of existing inventory of post construction inventory of the Stormwater system within the City Limits.

4. Schedule:


b. Implementation date (if applicable): January 1, 2015 c. Frequency of actions (if applicable): Ongoing d. Month/Year of each action (if applicable): Annually


of the BMP: Jonathon W. Heard, Director of Utilities 6. Rationale for choosing BMP and setting measurable goal(s): Keep

accurate records of existing Stormwater system

7. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Inventory of new and existing structures are important to refer to for planning and mapping purposes. No changes to this BMP at this time.

Note 1: Part 4.2.5.2 of the Permit requires an evaluation of the MS4’s building codes,

ordinances, and other regulations to ensure they do not prohibit or impede the use of Green Infrastructure/Low Impact Development (GI/LID). Include a BMP at the end of the Post-Construction minimum control measure to address this requirement.

Note 2: At a minimum, the MS4 must include a BMP in the SWMP for each BMP

listed in the NPDES Permit. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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C. BMP#3 Inspections of Post Construction Structures

1. Description of BMP: All Storm water structures are inspected at a rate of 20% annually. Included are catch basins and detention pond structures. Each inspection becomes a record, and a history begins for each within the system.

2. Measurable Goal(s): Inspect 20 % of catch basins and detention ponds

annually to complete the entire system on a five year cycle.

3. Documentation to be submitted with each annual report: Inspection forms for each type of structure.

4. Schedule:

a. Interim Milestone Dates ( if applicable) : N/A

b. Implementation Date (if applicable); Ongoing

c. Frequency of actions (if applicable): Annually, or 5 year cycle

d. Month/Year of each action (if applicable): 20% of Catch basins and Detention ponds annually.

5. Person (position) responsible for overall management and implementation of the

BMP: Jonathan W. Heard, Director of Utilities

6. Rationale for choosing BMP and setting measurable goal(s): Performing inspections allows a record of each structure to be generated, and records allow a timeline on proper maintenance.

7. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Inspections will help in planning and maintaining the system. No changes to BMP at this time.

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D. BMP#4 Maintenance of Post Construction Storm Water Structures

1. Target audience/ stakeholder group: Private owners, and the City of Cumming

2. Description of BMP: Required Maintenance will be done on detention pond

structures owned by the City of Cumming, and those owned by private owners in the existing City Limits. Proper maintenance of detention pond structures as defined in the City Ordinance will be the owner’s responsibility per maintenance agreement, and additional repairs may be needed during City inspections of these ponds. Regarding maintenance of these ponds: Each pond will be cleared of trees, trash, and debris will be cleared from around structure weir rack, outfalls coming into and exiting the pond. A fence will be around each pond and will be maintained as well. The City wants natural grasses and or cattails etc…The ponds should be cut bi-annually at the least. The dams to these ponds are to be clear of trees and obstructions as well.

3. Measurable Goal(s): The City of Cumming wants the detention pond structures to be presentable, and clear of obstruction. It makes the inspection process easier, and obvious the structure is functioning properly. When a breakdown occurs it will be easier to fix also.

4. Documentation to be submitted with each annual report: The City of Cumming will include any maintenance done on any City owned ponds, and will require private owners to submit maintenance documentation going forward with this BMP. A list of ponds requiring maintenance will be submitted also if any.

5. Schedule: a. Interim milestone dates: N/A

b. Implementation Date: January 1, 2014. c. Frequency of actions: Ongoing d. Month/Year of each action: Annually

6. Person (position) responsible for implementation of the BMP: Jonathon W. Heard, Director of Utilities.

7. Rationale for choosing BMP and setting measurable goals: The City of

Cumming as the Issuing Authority is responsible for proper maintenance, and the protection of the Storm Water System. These structures are important to preserving water quality.

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8. How will you determine whether this BMP is effective in accordance with Part

5.1.4 of the permit: No changes to this BMP at this time.

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E. BMP#5 Green Infrastructure/ Low Impact Development (GI/LID) Structure Inventory List

1. Target audience /stakeholder group: Developers, contractors, land owners

2. Description of BMP: Develop an inventory of water quality related GI/LID

structures located in the City Limits. Include the total number of structures( e.g. bio swales, pervious pavement, rain gardens, cisterns, and green roofs).

3. Measurable goals: Provide an inventory list of all GI/LID structures in the City Limits.

4. Documentation to be submitted with each annual report: List of GI/LID Structures if any.

5. Schedule: a. Interim milestone date (if applicable): N/A

b. Implementation date (if applicable): January 1, 2014 c. Frequency of actions (if applicable: Annually d. Month/ Year of each action( if applicable): N/A

6. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities

7. Rationale for choosing BMP and setting measurable goal(s): The City of

Cumming as Issuing Authority must maintain an inventory of GI/LID structures in the system for mapping and planning purposes.

8. How will you determine whether this BMP is effective in accordance with part5.1.4 of the Permit: No Changes to the BMP at this time

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F. BMP#6 Dumpster Pad Drains- New Developments

1. Target audience/stakeholder group: Developers, contractors, Land owners

2. Description of BMP: The City requires that all new developments to have Dumpster Pad Drains to the sanitary sewer before sign-off of the final plat by the City. (See ordinance specifications).

3. Measurable Goals: a. Enforce Dumpster Pad Drain to sanitary sewer requirement as described in the ordinance for each new development in the City Limits. b. Inventory number of Dumpster Pad Drains with each new development and inspect each to ensure compliance with ordinance

4. Documentation to be submitted with each annual report: A list of new developments with approved Dumpster Drain Pads.

5. Schedule:

a. Interim milestone dates ( if applicable) : N/A

b. Implementation date: (if applicable): Currently implemented c. Frequency of actions (if applicable): On-going d. Month/Year of each action (if applicable): On-going

6. Person (position) responsible for management and implementation of the BMP: Jonathon W. Heard, Director of Utilities.

7. Rationale for choosing BMP and setting measurable goal(s): Easier to force new developments to install dumpster drain pads. If they do not comply, then they do not receive final plat approval and cannot sell their homes or lease/ sell commercial buildings.

8. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: Make sure this BMP has been implemented upon inspection. No changes to this BMP at this time

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Pollution Prevention/Good Housekeeping for Municipal Operations

40 CFR Part 122.34(b) (6) Requirement: The permittee must develop and implement an operation and maintenance program that includes a training component and has the ultimate goal of preventing or reducing pollutant runoff from municipal operations. Using training materials available from the USEPA and other organizations as guidance, the permittee must, as a part of this program, include employee training to prevent and reduce storm water pollution from activities such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and storm water system maintenance. See Table 4.2.6 (a) of the Permit A. Best Management Practice (BMP) #1 Inventory and Map of the MS4 control

structures. 1. Description of BMP: Inventory and map of the MS4 control structures.

2. Measurable goal(s): Develop or update an inventory and map of the

MS4 control structures. At a minimum, the inventory and map must include catch basins, ditches (miles or linear feet). The inventory and map must be submitted to the EPD in accordance with a schedule established in the SWMP, but the completion date must not exceed February 15, 2015.

3. Documentation to be submitted with each annual report: Inventory of all

catch basins, and ditches in the City Limits. 4. Schedule:


b. Implementation date (if applicable): January 1, 2014 c. Frequency of actions (if applicable): N/A d. Month/Year of each action (if applicable): N/A


of the BMP: Jonathon W. Heard, Director of Utilities. 6. Rationale for choosing BMP and setting measurable goal(s): The City of

Cumming as the Issuing Authority must provide and maintain records for the Storm Water System for future planning, and to provide staff with accurate records.

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7. How you will determine whether this BMP is effective in accordance with Part 5.1.4 of the Permit: No Changes to this BMP at this time.

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B. BMP #2 Inspection Program on MS4 Control Structures.

1. Description of BMP: Inspections of all Control Structures

2. Measurable goal(s): Conduct Inspections on MS4 control structures so that 100% of the structures are inspected within a 5 year period. Provide the number and percentage of structures inspected during the reporting period in each report.

3. Documentation to be submitted with each annual report: 20% of MS4

control structures will be inspected annually, with the number of inspection forms to be submitted. Rotating in a 5 year cycle.

4. Schedule:



c. Frequency of actions (if applicable): On-going d. Month/Year of each action (if applicable): Annually


of the BMP: Jonathon W. Heard, Director of Utilities 6. Rationale for choosing BMP and setting measurable goal(s): Inspections

are important to make sure the system is functioning properly and pointing out what maintenance needs to be done in problem areas also.


Part 5.1.4 of the Permit: Maintain the current 20% inspections annually to achieve goal set forth in the permit. No changes to this BMP at this time.

Note: At a minimum, the MS4 must include a BMP in the SWMP for each BMP listed

in the NPDES Permit. If additional BMPs are chosen, then you should attach an additional sheet for each BMP.

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C. BMP#3 Storm Sewer Maintenance Program 1. Description of BMP: The City has developed a program to maintain the

City’s MS4 including any pipes, catch basins, ditches, etc… The city will maintain and clean pipes and ditches so they flow properly and efficiently. During inspection or complaint, the City will schedule maintenance on any problem related to the storm water system such as cleaning out catch basins and replacing failed pipes within 3 business days of identifying the problem. In an emergency situation, the city will perform emergency repairs immediately

2. Measurable Goal(s): a. Develop an MS4 maintenance program in the City Limits for existing storm water system. b. The City will conduct maintenance on MS4 control structures as needed.

3. Documentation to be submitted with each annual report: A list of all repaired structures and receipts, repair lists will be included in the annual report.

4. Schedule: a. Interim milestone dates (if applicable): N/A b. Implementation date (If applicable): Currently Implemented c. Frequency of actions (if applicable): On-going d. Month/ Year of each action (if applicable): Annually 5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities. 6. Rationale for choosing BMP and setting measurable goal:

Many of the storm water quality devices will not work properly unless they are maintained. In addition, ditches and pipes must be cleaned so they can flow easily to convey storm water effectively.

7. How will you determine whether this BMP is effective in reducing storm water pollution in accordance with Part 5.1.4 of the permit: Maintaining ditches, catch basins, and pipes to ensure effective drainage within the City Limits. No changes to BMP at this time.

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D. BMP#4 Street Sweeping and Adopt a Road Programs 1. Description of BMP:

The City currently sweeps the streets in the City Limits, and facilities on a monthly rotation. This is a great way to keep debris out of catch basins, ditches, and pipes. The Adopt A Road Program is important also in the fact that community volunteers pick up litter deposited in areas to prevent it from reaching our streams, and storm water structures.

2. Measurable Goals: Provide clean streets and roadways within the City Limits to prevent debris and litter from getting into storm drains, and ditches by sweeping monthly, along with the Adopt a Road Program. Providing specific streets and roads that have been cleaned.

3. Documentation to be submitted with each annual report: Submit Street Sweeper Log Book, and all Adopt -a-Road totals and streets cleaned for the year.

4. Schedule: a. Interim milestone dates (if applicable): N/A b. Implementation Date (if applicable): Currently Implemented c. Frequency of actions (if applicable): On-going d. Month/Year of each action (if applicable): Annually 5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities 6. Rationale for choosing BMP and setting measurable goals:

The City of Cumming has an obligation to the community to maintain and keep streets, and right of ways clean of debris and trash to protect our storm water system and nearby streams and waterways.

7. How will you determine whether this BMP is effective in accordance with Part 5.1.4: By following the trash totals annually and determining which areas need most attention. No changes to this BMP at this time.

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E. BMP#5 Employee Training 1. Target audience/ stakeholder group: City employees involved with Stormwater

maintenance. 2. Description of BMP: To ensure employees receive proper storm water training

annually on topics such as illicit discharges, maintenance issues, pollution prevention etc…

3. Measurable Goal(s): Employee training on storm water related topics will be

conducted annually along with documentation to be submitted in the annual report.

4. Documentation to be submitted with each annual report: Copies of all Employee

training logs and material used in the annual report.

5. Schedule:

a. Interim milestone dates( if applicable): N/A

b. Implementation Date ( if applicable): Currently Implemented

c. Frequency of actions (if applicable): On-going


6. Person (position) responsible for the overall management and implementation of BMP: Jonathon W. Heard, Director of Utilities.

7. Rationale for choosing BMP and setting measurable goals: The more education

that can be provided to employees will help in the inspection and maintenance process of the Storm Water System.

8. How will you determine whether this BMP is effective in accordance with Part 5.1.4

of the Permit: By employee response to the training, and its effectiveness in the field. No additional changes to this BMP at this time.

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F. BMP#6 Storm Water Proper Waste Disposal Measures 1. Description of BMP:

The City of Cumming generates a variety of wastes on a daily basis. These wastes include, but are not limited to, accumulated sediment, wastewater sludge, floatables, leaves, trash, and brush. These wastes are disposed of in either the Pine Bluff or the Eagle Point sanitary landfills. Waste oils are recycled and are not to be stockpiled in an area that could cause storm water contamination. All waste oils and spent fluids are stored in a City- approved tank that is equipped with a containment wall. These oils and fluids are removed from the tank by an approved waste hauler and proper manifests are maintained.

2. Measurable Goal(s): a. Maintain manifest for waste oil and spent fluid disposal.

b. Maintain manifests for the disposal of wastes such as sediments, trash, floatables, leaves, and brush.

3. Documentation to be submitted with each annual report: All waste manifests will be included in the annual report

4. Schedule:

a. Interim Milestone Dates (if applicable): N/A

b. Implementation Date (if applicable): Currently Implemented



5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities. 6. Rationale for choosing BMP and setting measurable goal(s): The City currently practices proper waste disposal techniques. This BMP will help ensure that the runoff from the City operations is not contaminated by City generated wastes. 7. How will you determine whether this BMP is effective in accordance with Part5.1.4. of the permit: Keeping accurate records of waste manifests. No changes to this BMP at this time.

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G. BMP#7 New Flood Management Projects

1. Description of BMP: The City of Cumming has developed and implemented review procedures required in the City of Cumming Utilities Ordinance adopted in 2010. These will ensure new flood management projects are assessed for impacts to water quality and water quantity. The City will continue to implement these requirements going forward.

2. Measurable Goal(s): The City of Cumming will continue to review all New

Flood Management plans during the design phase, and follow the basic principles of the Georgia Stormwater Management Manual, and Utilities Ordinance in Section 70-350 to determine and/or mitigate potential water quality impacts to receiving waters and report the number of plans reviewed annually.

3. Documentation to be submitted to with each annual report: City will provide the number of plans reviewed for New Flood Management Projects.

4. Schedule:


b. Implementation Date (if applicable): Currently Implemented


d. Month/year of each action (if applicable): On-going

5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities.

6. Rationale for choosing BMP and setting Measurable goal(s): This will help

reduce the amount of pollution discharged into city streams via storm drains. This will reduce the City of Cummings liability regarding adverse impacts from less efficient stormwater management detention structures that may have been approved in the past.

7. How will you determine whether this BMP is effective in reducing pollution to

stormwater in accordance with 5.1.4 of the permit: By review, and proper inspection during the time construction is being done.

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H. BMP# 8 Existing Flood Management Projects

1. Description of BMP: The City of Cumming does publicly own 6 Stormwater management control structures. However; if a stormwater control structure is dedicated to the City; then the City of Cumming will evaluate the stormwater structures for the addition of water quality protection devices and/or practices. Those stormwater facilities that are eligible for retrofit are those structures that discharge into 303d listed streams and that discharge the pollutants specified for streams in the 303d list. The City has through its Utilities ordinance adopted the Georgia Storm Water Design Manual and enforces compliance with this manual for each future City owned management control structures, and each new development.

2. Measurable Goal(s): a. Determine how many Flood Management Project ponds there are in the MS4 that are publicly owned by the City, and b. Determine how many need retrofitting to increase water quality and prevent pollution into 303D streams and waterways. c. Evaluate the costs and impact of the retrofit.

3. Documentation to be submitted with each annual report: Report any repairs and cost associated with any retrofitted Flood Management Project that is publicly owned by the City. (The city does publicly own 6 management control structures that do not dump into a 303d stream at this time).

4. Schedule:

a. Interim Milestone Dates (if applicable) : N/A

b. Implementation Date (if applicable) : Currently Implemented

c. Frequency of actions ( if applicable) : On-going

d. Month/Year of each action ( if applicable): On-going

5. Person (position) responsible for overall management and implementation of the BMP: Jonathon W. Heard, Director of Utilities.

6. Rationale for choosing BMP and setting measurable goals: It is the

responsibility of the City to address the Management control structures that it currently owns and to see if they need retrofitted to prevent pollutants from getting into 303d listed streams in the future.

7. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the permit: The City will access its 6 publicly owned ponds and address any retrofit needed to improve water quality and prevent pollutants from getting into any 303d listed streams.

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I. BMP#9 Municipal Facilities

1. Description of BMP: The City of Cumming will inventory, and inspect all Municipal Facilities for the potential to cause pollution of local water bodies. The City must ensure that all chemicals and fuel tanks are located within properly contained areas. Material Safety Data Sheets are required on all chemicals, and flammable materials that might cause harm to stormwater quality, thus impacting streams nearby. Any spillages and or discharges must be contained and properly remediated. Cleanup procedures may include the removal of soils contaminated with hazardous chemicals or petroleum based products and disposal of these materials in a landfill that accepts them.

2. Measurable Goals: a. The City will inventory all Municipal Facilities with the potential cause for pollution. b. Develop inspection procedures. c. Conduct 100% of inspections of the Municipal Facilities within the 5 year permit cycle. The City will inspect 2 of its facilities each year and will have all inspected during the 5 year permit cycle.

3. Documentation to be submitted with each annual report: All inspection forms conducted during the reporting period. Receipts and or costs to repair any problem found at any facility.

4. Schedule:


b. Implementation Date (if applicable): January, 1 2014. c. Frequency of actions (if applicable): N/A d. Month/Year of each action (if applicable): N/A

5. Person (position responsible for overall management and implementation of this BMP: Jonathon W. Heard, Director of Utilities

6. Rationale for choosing BMP and setting measurable goals; The City must

ensure the containment of all potential chemical hazards that could potentially impact a stream or body of water.

7. How will you determine whether this BMP is effective in accordance with Part 5.1.4 of the permit: Inspections will achieve the effectiveness of this BMP

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and ensure that corrective measures are taken to handle problems that are discovered. No corrections to this BMP at this time.

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Enforcement Response Plan January, 2015

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Impaired Waters Plan January, 2015

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Appendix

Enforcement Response Plan

1. The MS4 must develop and implement an Enforcement Response Plan (ERP) that describes the action to be taken for violations of the Storm Water Management Program. The ERP must be completed and submitted with the second annual report following permit issuance, February 15, 2014.

Final completion date: __________________ Date of submittal to EPD: ________________

2. In accordance with Part 4.3 of the NPDES Permit, the ERP must include

escalating enforcement responses for repeat and continuing violations. At a minimum, the ERP must address the following categories (refer to Part 4.3 of the NPDES Permit for more detail):

• Names of ordinances and citations; • Types of enforcement mechanisms; • Description of the use of these enforcement mechanisms; • Time frames; and • Description of the tracking and reporting mechanism.

NOTE: Upon completion, the ERP will be included as an Appendix to the SWMP.

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Appendix

Impaired Waters

1. Population based on the 2010 U.S. Census: _____________

If the population is less than 10,000, then see items #2 and #3 below. If the population exceeds 10,000, then see items #4 and #5 below.

2. If the population is less than 10,000, then the MS4 must develop an Impaired

Waters Plan (see Part 4.4.1 of the NPDES Permit) including: • A list of impaired waters and the pollutant(s) of concern; • A map showing the location of the impaired waters and all identified MS4

outfalls located on the impaired waters or occurring within one linear mile upstream of the waters;

• BMPs that will be implemented to address each pollutant of concern; and • A schedule for implementing the BMPs.

3. The Impaired Waters Plan must be submitted with the annual report due

February 15, 2015.

Final completion date/date of submittal to EPD:_______________ 4. If the population exceeds 10,000, then the MS4 must develop an Impaired

Waters Plan/Monitoring and Implementation Plan (see Part 4.4.2 of the NPDES Permit) including: • A list of impaired waters and the pollutant(s) of concern. • A Monitoring and Implementation Plan, that includes:

a. Sample location; b. Sample type, frequency, and seasonal considerations; c. Monitoring implementation schedule; d. A map showing the location of the impaired waters and all identified

MS4 outfalls located on the impaired waters or occurring within one linear mile upstream of the waters or a schedule for confirming those outfalls; and

e. Description of proposed BMPs. • Description of the method used to annually assess data trends for each

pollutant of concern. 5. The Impaired Waters Plan/Monitoring and Implementation Plan must be

submitted with the annual report due February 15, 2015.

Final completion date/date of submittal to EPD: __________________ NOTE: Upon completion, the Impaired Waters Plan will be included as an Appendix to

the SWMP.

city of cumming storm water management programsedimentation, and post -construction); 2) standard...

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