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About this file
MS4 Inspection and Assessment Program Manual
This document is the Inspection, Maintenance, and Operations Program (IMOP) Manual for the City of Brookhaven, Georgia, which establishes standard operating procedures for inventory, mapping, inspection, operations, and maintenance activities for all stormwater management systems within the City's corporate limits. The City of Brookhaven's stormwater system includes over 12,000 drainage structures, nearly 200 miles of conveyances, and more than 350 detention/retention facilities, of which the Municipal Separate Storm Sewer System (MS4) consists of over 1,900 catch basins, 38 miles of pipes, 10 miles of ditches, and 39 detention/retention facilities. The City divides its service area into five geographical zones and conducts comprehensive inspections on a rolling five-year schedule, ensuring 100 percent inspection coverage of all stormwater assets every five years through qualified contractors selected via qualifications-based selection processes. The program encompasses inventory and mapping verification, condition assessments using ESRI Collector software on GPS-enabled tablets, and classification of assets into condition ratings from 5 (Excellent) to 1 (High Priority), with High Priority assessments requiring independent verification and corrective action within one year of discovery.
The IMOP Manual defines specific maintenance standards and procedures for different asset types, including catch basins (cleaning when sediment equals or exceeds one-third sump depth), storm drain lines (cleaning when deposits block more than 35 percent of pipe diameter), open drainage features (cleaning when sediment exceeds 35 percent of functional depth), and municipally-owned detention ponds (sediment removal before 50 percent capacity loss). Maintenance responsibility varies based on asset ownership—City-owned facilities are maintained by the City, publicly-owned facilities by other public entities, and privately-owned facilities by private owners, though the City provides inventory and mapping services for all stormwater assets within its corporate boundaries to maximum extent practicable. The program includes remedial maintenance performed on an as-needed basis for system failures identified through citizen complaints and condition assessments, emergency maintenance authority to protect public welfare, and employee training requirements covering pollution prevention, illicit discharge detection, and erosion control. The City maintains comprehensive records of all inspection and maintenance activities through CityWorks Work Order systems and Service Requests via the Brookhaven Connect portal, with annual MS4 SWMP Annual Reports documenting compliance with the General NPDES Stormwater Permit (GAG610000, effective December 6, 2017 to December 5, 2022).
Text of this file
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CITY OF BROOKHAVEN
MUNICIPAL INSPECTION, MAINTENANCE, AND
OPERATION PROGRAM
(IMOP)
MANUAL
City of Brookhaven, Georgia
Revision History:
Version Number Date Summary of Revisions
1.0 15 Feb 2020 First Version
1.1 31 Aug 2020 Minor Edits – Response to EPD 21 Jul 2020 comments
1.11 13 Nov 2020 Name Change: Establishment of Municipal and MS4 (EPD) Version (V2.0)
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Applicability Guide
Purpose: To document the inspection, maintenance, and operation procedures used for the various components of the storm drainage systems located wihin the corporate boundaries of the City of Brookhaven, including the regulated MS4, and designation of the responsible parties for each.
Audience: Public Works staff, City maintenance supervisors, EPD/EPA SWMP regulators, professional service providers in the regulated development community, property managers in the regulated development community Applicable to: Publicly-owned (by deed) and maintained (City-owned) facilities
Publicly-owned (by dedication) and maintained (City-owned) facilities Facilities publicly-owned by other Public entities and maintained by other Public entities Privately-owned and maintained facilities (privately-owned) Privately-owned and City-maintained (drainage easements)
Asset Types Covered: Outfalls, catch basins, detention/retention ponds, ditches, swales, storm drain lines, treatment facilities, control structures, runoff reduction facilities (green infrastructure), and other conveyances (except privately owned ditches/swales)
Related Programs: Illicit Discharge Detection and Elimination (IDDE) Program Post-Construction Stormwater Management Program Green Infrastructure (GI)/Low Impact Development (LID) Program
Related Permit: General NPDES Stormwater Permit No. GAG610000, Authorization to Discharge Under the National Pollutant Discharge Elimination System, Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems, effective 12/6/2017 to 12/5/2022.
SWMP BMPs Covered:
BMP C-2 – Outfall Map and Inventory BMP C-3 – IDDE Plan BMP E-2 – Post-Construction Stormwater Structure Inventory BMP E-3 – Post-Construction Stormwater Structure Inspections BMP E-4 – Post-Construction Stormwater Structure Maintenance BMP E-5 – Post-Construction GI/LID Inventory BMP E-6 – Post-Construction GI/LID Program BMP E-7 – Post-Construction GI/LID Inspection and Maintenance BMP F-1 – MS4 Control Structures Inventory and Map BMP F-2 – MS4 Control Structures Inspection BMP F-3 – MS4 Control Structures Maintenance BMP F-4 – Street Sweeping
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BMP F-5 – Employee Training BMP F-6 Waste Disposal
BMP F-9 Municipal Facilities
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1.0 Introduction
A stormwater system is the group of infrastructure assets that collect, convey, provide flood storage, treat, and discharge flows generated by storm runoff. The City of Brookhaven (CoB) is responsible to operate and maintain a subset of the stormwater system known as the CoB Municipal Separate Storm Sewer System (MS4), which is a regulatory as well as functional term.
Other subsets of the stormwater system include other MS4’s, i.e. Georgia Department of Transportation, privately-owned and maintained systems, and systems owned by other non-City public entities.
The MS4 includes all stormwater infrastructure and assets owned and/or maintained by the CoB.
To ensure the entire stormwater system continues to operate as intended, the City takes mapping and inspection responsibility over non-MS4 portions of stormwater system located inside its corporate boundaries. This helps to ensure that owners of the remaining subsets of the stormwater system properly maintain and operate their stormwater system infrastructure and assets.
GDOT owned and maintained infrastructure is covered under the GDOT MS4 permit and is excluded from discussion in this Manual.
This document, known as the Inspection, Maintenance, and Operations Program (IMOP) Manual, provides definitions of terminology used and establishes the standard operating procedures (SOPs) necessary to conduct the appropriate level of inventory, mapping, inspection, operations, and maintenance activities for the stormwater management systems. These procedures are universally referred to as the IMOP in this document unless the discussion is specific to a component of the program and refinement of the terminology is necessary.
1.1 Plats, Dedications, and Extent of Services
Section 25-558 – Scope of Responsibility of the Stormwater Utility provides clear and concise inspection, maintenance, and operations responsibilities for components of the City’s stormwater system, and defines the portions of the stormwater system that are included in the CoB MS4. From Sec 25-558 the policy reads as follows:
“(a)The stormwater utility shall be responsible for plan approval and construction inspection of both private stormwater facilities and public stormwater facilities located within the City. The stormwater utility shall be responsible for the design and construction of public stormwater facilities owned by the city and shall inspect, operate, and maintain them as prescribed herein.
(b) The City owns or has legal access for purposes of operation, maintenance and improvement of those stormwater systems and facilities which:
(1)Are located within public streets, rights-of-way and easements;
(2)Are subject to easements, rights-of-entry, rights-of-access, rights-of-use or other permanent provisions for adequate access for operation, maintenance and/or improvement of systems and facilities;
(3)Are located on public lands to which the city has adequate access for operation, maintenance and/or improvement of systems and facilities; or
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(4)Are determined by the city attorney to be the city's responsibility.
(c)The stormwater utility shall provide for inspection of private facilities to ascertain that the stormwater facilities are functioning as designed and approved. The stormwater utility shall provide for remedial maintenance of facilities based upon the severity of stormwater problems and potential hazard to the public health, safety, and welfare, and in cases where such remedial maintenance is required the city may bill the owner of the private facility for the costs of such maintenance.”
When the City incorporated in 2013, it “inherited” a number of existing public and residential-subdivision stormwater system operation and maintenance commitments and dedications approved by DeKalb County through the Final Plat process. Beginning at the end of the 1950’s, the information, acknowledgements, dedications, and certifications shown on Final Plats significantly increased over previous years. Over the years since, the amount of information shown on plats has significantly increased, and the maintenance and operational responsibilities of the “public,” taken to mean the county or municipal government, has become more detailed as well.
CoB staff has identified at least seven different residential subdivision plat “styles,” or standard language, each conveying operation and maintenance responsibilities to different parties and at different levels. These designations are summarized in the Appendices. The IMOP Manual clearly identifies the operation and maintenance role of these responsible parties.
1.2 Organization
The IMOP Manual serves to summarize a variety of functions both required to properly manage and operate the CoB MS4 and address regulatory and reporting requirements from EPA and EPD.
The page proceeding this document’s title page provides a quick guide to the applicability of this IMOP Manual. The body of the IMOP Manual deals with the procedures necessary to inventory, map, inspect, operate, and maintain the different stormwater asset types that together comprise the CoB MS4, and the Appendices expand on terminology, responsibilities, and regulatory environment.
Appendix A contains Definitions and Terminology used in the IMOP Manual and are provided for clarity and continuity with other MS4 related documents. Appendix B summarizes the somewhat complicated configurations of asset ownership and maintenance responsibilities. Appendix C provides an overview of the various types of stormwater assets typically encountered in the CoB.
Appendix D provides the full text of Section 25-558 – Scope and Responsibility for the Stormwater Utility.
1.3 Regulatory Relationships
This IMOP is essential to guide the Department of Public Works Stormwater Utility Division’s management staff to procure professional, technical, operations, and maintenance services;
understand the mix, type, age, condition, and changes to the City’s existing stormwater infrastructure assets; identify maintenance and replacement trends for future routine and capital spending; and, in time, proactively manage, identify, and program life-cycle asset management into the City’s daily operations. The IMOP Manual is a key component of the City’s
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The CoB MS4 is a subset of the complete stormwater system and network located within the CoB corporate limits. Under the purview of the Clean Water Act, the General Permit allows the City to discharge stormwater from the MS4 to Waters of the US and Waters of the State.
For the non-regulated portions of the stormwater systems located in the City of Brookhaven, only the inventory and mapping provisions of the IMOP apply.
The General Permit applies to all designated Phase II permittees, most of which are municipalities, in the State of Georgia. Through the Notice of Intent process, each permittee provides formal notice to the State of Georgia that it intends to use the discharge rights provided by the General Permit in exchange for developing a SWMP containing BMPs specific to that municipality’s MS4.
Each BMP contains a description, establishes measurable goals, defines the documentation to be provided to self-report compliance to the terms of the SWMP, and an implementation schedule.
The SWMP is the regulatory document and framework for identifying, tracking, operating, and maintaining the stormwater assets directly in the control of the permittee (MS4) and helps ensure the permittee has the legal authority or jurisdiction, through the adoption of specific ordinances, to regulate portions of the stormwater system that are not part of the MS4.
Each February, the MS4 activities conducted during the preceding year are summarized in the MS4 SWMP Annual Report. Compliance and enforcement activities, when necessary, are initiated through the self-reporting of the Annual Report.
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2.0 Program Description
The inventory of the stormwater drainage system components located in the City, as reported through the City’s geographic information system (GIS), includes over 12,000 drainage structures, nearly 200 miles of conveyances, and more than 350 stormwater detention/retention facilities. Of these, the CoB MS4 consists of over 1,900 catch basins, 38 miles of pipes, 10 miles of ditches, and 39 detention/retention facilities. The system is under continual inspection, as-needed maintenance, programmatic maintenance, and capital improvements.
2.1 Inventory, Inspection, Mapping, and Condition Assessments The City’s existing storm drainage system components are inventoried, mapped, and inspected on a rolling five-year schedule by City contractors, chosen through a qualifications-based selection process. Public Works and GIS professional staff members provide quality assurance / quality control for the inventory, mapping, and conditions assessment of MS4 structures.
The contractors conduct the inventory, mapping, and conditions assessments using ESRI Collector software on cell- and GPS-enabled tablets. The Collector database is connected in real-time to ESRIs web-based GIS database. Data is immediately available once saved. This database is maintained separately from the City’s physical servers, thus providing an additional measure of data integrity.
For the purpose of performing inspections on the stormwater system, the CoB is divided into five geographical areas (map of geographic areas attached). Each year, the inventory and GIS maps are updated and condition assessments are completed in one of these five areas such that 100% of the City’s stormwater system, including the MS4, is inspected every five years. The City’s Stormwater System IMOP goes beyond the regulatory requirements of the MS4 Phase II Program.
The following stormwater assets are inventoried, mapped, and inspected in the corresponding geographic area each year:
• Outfalls. Each is re-verified to meet the requirements of an outfall. Dry weather screening is also provided. Required by BMP C-2 and BMP C-3.
• Post-construction stormwater management structures (detention pond/retention ponds/ underground vaults). Required by BMP E-2 and BMP E-3
• GI/LID structures. Required by BMP E-5 and BMP E-7
• MS4 Control Structures (catch basins, storm drain pipes, ditches, post-construction stormwater management structures). Required by BMP F-1 and BMP F-2
• Other accessible stormwater system assets not specifically covered by the SWMP.
The approach selected by the City to best serve its residents is to inventory, map, and inspect all assets to the maximum extent practicable. This means that unless a stormwater asset is
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• After a reasonable search, the asset is not visible on the surface, e.g. blind junction box, buried structure, etc.
• Access to the asset is considered to pose a danger to life and limb of a reasonably fit and equipped inspector.
• There are other physical barriers, e.g. chain link fences, privacy fences, etc.
• A landowner has refused Right-of-Entry. (this is atypical for MS4 structures, but from time to time, is encountered on privately owned and maintained stormwater assets.)
The City’s comprehensive IMOP incorporates three other types of inspection activities:
1. Quality assurance inspections: verification of prior year’s condition ranking
2. Remedial inspections
3. Condition driven inspection and monitoring
2.1.1 Inventory and Mapping
All inventory and mapping data are stored in the CoB integrated Stormwater Asset ESRI GIS and CityWorks® Work Management System. The initial inventory was provided by DeKalb County when the City of Brookhaven incorporated. During the first five-year cycle, there was a focus on correcting deficiencies in the inventory and to add to the inventory stormwater assets that had not been previously mapped. Data sources used in the initial mapping included plats, Land Development Permits, as-built drawings, and observations. The inventory and mapping process is constantly being updated and refined.
Updates to the existing inventory and asset maps are driven by as-built drawings and approved plats that are submitted at the end of development or redevelopment. These assets are then field verified no later than the next quinquennial update.
Physical structures and conveyances are located with the coordinates of the center of structure or apparent centroid of structure. The upstream and downstream ends of conveyances are also mapped, and the ID of the corresponding nearest upstream and downstream structure is added to the asset’s GIS metadata. Also captured at the time of mapping is the nearest address to the structure or center of conveyance. Physical characteristics of the asset are noted, as is condition (discussed below).
Once initially mapped, assets are not typically re-mapped unless there are compelling reasons to do so. If an asset can be found and uniquely distinguished from nearby assets, then its mapped location in the GIS is typically preserved.
Re-mapping often causes issues with the effect of rendering the data less reliable than it was prior to re-mapping. For example, the former unique naming convention for assets was to concatenate portions of its northing and easting coordinates. If the asset is moved, that unique identifier would
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Each individual asset contains dozens of additional metadata records. To provide additional refinement in the CityWorks® Work Order system, there are over 20 unique stormwater asset classes with between 9 and 15 user accessible attributes, each providing critical location and condition data. At least one photograph is taken of each structure, and one picture is taken at the upstream and downstream end of each conveyance. These data are accessible to users by clicking on the asset. In addition, the GIS staff has access to additional data that is not normally displayed.
2.1.2 Newly Annexed Areas
When new areas are annexed into the City, DeKalb County provides an initial GIS database upon which the City begins to inventory, map, and assess the systems under City specific guidelines.
The City’s MS4 annexation approach is to complete the initial inventory, mapping, and assessments for the added portions of the expanded stormwater system within 12 months of annexation. City Council established a special taxing district in each newly incorporated area, which is used to pay for required infrastructure inspections, assessments, maintenance, and capital improvements inside the boundaries of the newly annexed area. Funds raised by the special tax districts can be used for City-owned infrastructure (roads, sidewalks, curb, gutters, right-of-way, and the stormwater system) and parks projects.
2.1.3 Condition Assessment and Maintenance
Stormwater Conveyances and Structures For stormwater conveyances and structures, the condition assessment is completed at the time of inventory and mapping verification. The current condition assessment (most recent) for each asset accompanies the inventory and mapping data in the GIS. Overall condition is assessed on a sliding integer scale from 5 – Excellent to 1-High Priority. A note describing the condition is provided.
If there is a specific defect or concern, additional photographs are taken. For the interior of structures and closed conduits (pipes), a pole camera is used to both inspect the interior of the structure and document internal defects.
Stormwater Detention/Retention and GI/LID Structures Stormwater detention, retention, and GI/LID structures require a trained eye, and, due to the number of potential operation and maintenance issues, require a checklist to complete condition assessments. The CoB uses both electronic forms and paper forms to these assessments. The checklists are, at a minimum, based on the Operation and Maintenance Inspection Checklists provided in the GSMM for each type of post-construction stormwater management or GI/LID structure. Where deficiencies are found, they are noted in the GIS.
Overall condition is assessed on a sliding integer scale from 5 – Excellent to 1-High Priority. A note describing the condition is provided. If there is a specific defect or concern, additional photographs are taken.
High Priority Rated Assessments For all stormwater system asset classes, High Priority assessment scores are independently verified by members of the City’s Stormwater Utility team. Corrective actions shall be taken within a year
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City forces (contracted) assess maintain the City’s regulated MS4 stormwater control structures and other City-owned stormwater system assets on a regular basis. The regulated MS4 Control Structures include MS4 Structures covered by SWMP BMP E-4, BMP E-7, and BMP F-3: catch basins, pipes, ditches, stormwater ponds; and GI/LID structures.
2.1.4 Other Assessments and Maintenance
In addition to the City’s annual contract for stormwater system inspections, the City performs a host of other inspections. The list below summarizes each inspection class.
Periodic inspection is a proactive activity to perform inspections and monitor condition on the established geographic area based, five-year rolling schedule. MS4 Asset Assessments.
This assessment can result in both Remedial Inspection and Maintenance (Assessment scores of 1-HIGH PRIORITY) or Condition Driven Maintenance (Assessment scores of 2 to 5).
Remedial inspection and maintenance are reactive maintenance activities performed on an as-needed basis. Need for this level of inspection and maintenance is established from evidence of system failure through other ongoing City asset operation and maintenance activities, previous-years’ MS4 Asset Assessments, or through citizen reported issues and/or complaints.
Condition driven maintenance is a predominately proactive activity that performs maintenance when certain criteria are met or are anticipated to be met.
For privately-owned or other public entity-owned stormwater infrastructure, the City provides inventory, mapping, and condition assessment inspection services on the same rolling five-year basis. When necessary, the City will attempt to provide information/ recommendations on proper maintenance to the private owners of those systems as a courtesy.
Because the MS4 is inspected on a 5-yr rolling basis, structure conditions can be tracked and compared from one inspection cycle to the next. Maintenance is either deferred and monitored on low- and medium-risk structures so that higher priority issues can be addressed first, or proactive maintenance may be conducted on selected assets.
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3.0 Maintenance Procedures
3.1 Prioritization
These procedures apply to assets within the CoB MS4. Primary drainage systems are systems where significant harm or damage could occur if the system were to fail. The highest priority is assigned to those systems that cannot be allowed to fail due to the potential for serious threat to life/safety, public roadways, structures, and/or natural resources. Loss of access to residences and/or businesses due to roadway failures or flooding can limit access of emergency services, and, in turn, poses indirect threats to life.
Secondary drainage systems include all other drainage systems not classified as primary systems.
A high priority secondary system includes systems that could cause road closures but not necessarily result in loss of access to an area. Other high priority secondary systems include those that result in flooding of non-livable structures (i.e. sheds, storage buildings, etc.) and those that cause nuisance flooding.
A drainage system’s classification ties into the City’s performance siltation and structural damage.
Heavy siltation in a catch basin and/or pipe conveyance on a primary drainage system may receive a higher priority ranking than a severely damaged headwall on the downstream side of the ROW on a residential street.
For private systems, the same prioritization criteria utilized to document system condition. This information is passed on to the Owner of Record in the DeKalb County Tax Commissioner’s office.
3.2 Remedial Inspection and Maintenance Procedures
Remedial maintenance is performed based on evidence of system impairment or failure identified through citizen complaints, City staff inspection, and/or annual MS4 Asset Assessments. Re-inspection and maintenance activities are performed on an as needed basis.
Upon receipt of a complaint (excluding High Priority assessments), City staff will generate a Service Request (SR) for the preliminary assessment. A member of the City’s Stormwater Utility team will perform an inspection of that complaint within five (5) business days. City staff will assess the system for condition, material, water quality issues, structural issues, etc. document the conditions, and make a recommendation for the next step. Maintenance will be recommended and performed based on the condition driven maintenance standards established below..
Maintenance is logged in as work performed through the Cityworks Work Order system. This type of maintenance can include minor maintenance activities such as sediment/litter removal, vegetation clearing, channel stabilization, and outlet structure repairs. Minor maintenance activities are performed by the City’s full-time maintenance contractor.
When structural or specialized repairs are required, the work is typically performed by outside contractors who are licensed and/or qualified to perform the higher level of repair. Three quotes are generally required, and the best qualified firm with the lowest apparent quote is selected. The limit for repair versus capital improvement is based on the Scope of Work. There are no proscriptive requirements for elevating a project to a Capital Improvement versus repair.
Generally, if the repair/replacement consists of like-for-like replacement of a small portion of a
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3.3 Condition Driven Maintenance
Condition driven maintenance is performed based on the results of City staff inspections conducted as part of a periodic or remedial inspection program. If certain standards are not met during inspection, the City’s maintenance contractor will perform applicable maintenance procedures including removal of litter, debris, or sediment; re-grading; minor repair; replacement; etc.
Standards for System Components:
• Catch Basins: Catch basins with sumps should be cleaned if accumulated sediment, debris or other deposits are equal to or greater than one-third the depth from the invert of the basin sump to the invert of the lowest pipe into or out of the basin. If catch basins are found to significantly exceed this standard, they should be inspected and cleaned more often. If deposits of concern are rarely found during regular inspections, inspection may be moved to a more infrequent schedule.
• Storm Drain Lines: Storm sewers should be inspected as the catch basins are inspected. Storm pipes shall be cleaned if accumulated sediment, debris or other deposits are blocking more than 35% of the pipe diameter.
• Culverts: Woody debris and other blockages should be immediately removed from culverts and other critical conveyance components.
• Open Drainage: Open drainage refers to ditches, canals, swales, etc. Drainage ditches should be inspected and cleaned if accumulated sediment, debris or other deposits exceed 35% of the functional depth. Excess vegetation shall be removed manually if it is restricting flow.
• Municipally-Owned Detention Ponds and other Regional Controls (systems designed one-year after the date of designation as a regulated MS4, October 3, 2014):
Inspections of inflow and outflow structures are required. Sediment should be removed before 50% of the capacity has been lost (typically every 10 to 20 years).
Stormwater structural control facilities shall be maintained according to criteria or procedures present in Volume 2 of the Georgia Stormwater Management Manual.
Maintenance requirements are detailed at the end of each structural control design criteria section.
• Municipally-Owned Detention Ponds and other Regional Controls (systems constructed before the date of designation as a regulated MS4): Inspections of inflow and outflow structures are required.
o If as-designed elevations / depths can be determined, sediment should be removed before 50% of the capacity has been lost (typically every 10 to 20 years). Stormwater structural control facilities shall be maintained according to criteria or procedures present in Volume 2 of the Georgia Stormwater Management Manual.
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• Outfalls: :
o Dry weather flows: If dry weather flows are observed in an outfall during inspection a source-tracking investigation should be immediately initiated to identify the source and eliminate any illegal dumping and /or illicit connections. The procedures for source-tracking and definition of dry-weather flow should be in accordance with the City’s IDDE Program.
o Regardless dry weather or wet weather flow, if flow from an outfall is causing erosion, energy dissipating BMPs should be installed as part of a programmed system improvement plan.
3.4 Emergency Maintenance
The City may conduct emergency maintenance operations within drainage easements to protect the common good. Emergency maintenance includes maintenance necessary to remedy a condition which is potentially damaging to life, property, or public roads. Section 25-558 Scope and Responsibility for the Stormwater Utility provides sufficient authority to conduct Emergency Maintenance. Such emergency maintenance shall not be construed as constituting accepting a continuing maintenance obligation by the City, nor prevent the City from seeking reimbursement for expenses from the property owner(s) of the land that generated the condition.
3.5 Funding Issues (Set Funding Allocated in Budget)
The Mayor and City Council may allocate funding for stormwater projects during each budget cycle. Projects will be recommended for implementation based on the determination of City responsibility, by Category, and by approved funding level.
3.6 Record Keeping
The City staff will keep records of all inspection and maintenance activities performed as part of the MS4 inspection program. Service Requests will be generated based on citizen complaints or other unforeseen maintenance activities not usually performed as part of scheduled maintenance.
The Service Request portal on the City’s website, Brookhaven Connect (also known as CitySourced) shall be residents’ primary means for reporting issues with the stormwater system:
https://www.brookhavenga.gov/community/page/brookhaven-connect-service-request When a service request is posted in CitySourced, a CityWorks Service request generated, which contains an ongoing association with CitySourced.
Service Requests will detail the source of the complaint, nature of the stormwater issues, inspection results, and all maintenance and/or enforcement activities. The service request will detail the project from start to finish including dates, activities and staff. City Crews will also keep daily activity logs detailing all of their inspection and maintenance activities as they relate to system inspection and maintenance. These logs will include structures inspected, activities performed, https://www.brookhavenga.gov/community/page/brookhaven-connect-service-request https://www.brookhavenga.gov/community/page/brookhaven-connect-service-request
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In addition, a project specific folder will be created, in the format of Street Name (address), in a SERVICE REQUEST folder under the STORMWATER parent directory. Copies of pertinent communications, including e-mails saved as Acrobate *.pdf files and photographs, shall be stored in this location.
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4.0 Street Sweeping and Waste Disposal
4.1 Street Sweeping
Annually, the City will engage a Street Sweeping contractor to sweep all City maintained streets within the City limits at least one time per year, assuming funding is available. At a minimum, the City shall ensure that the minimum requirement for SWMP BMP F-4 is achieved.
The City shall maintain a list of streets for which the City is responsible, street names swept, dates swept, curb miles swept, and the amount (tonnage) of debris collected through the street sweeping activities.
4.2 Waste Disposal
Public Works maintains a waste hauling contract with private haulers to lawfully dispose of waste City crews collect during the normal course of their duties. This excludes the domestic/office types of waste collected in waste bins and dumpsters at City facilities. Differentiation between the two types can be made by the identification of the waste haulers. DeKalb County Sanitation Division collects, hauls, and disposes of this domestic/office wastes. These wastes are not covered by the IMOP.
City crews collect landscaping debris, debris collected from the right-of-way, tree trimmings, concrete, aggregate, drainage structures, asphalt, and similar debris in containers positioned at different locations in the City. The private hauler routinely, weekly, semi-weekly, monthly, collects and transports this waste to the appropriate landfill. Collection frequency varies by need, but collection shall be at lease monthly.
The periodic invoices for payment contain the tonnage of waste collected and disposed of during each period. These invoices are controlled by the Public Works Office Manager and copies are maintained in the Finance sub-directory under the Public Works parent folder.
5.0 Employee Training
Each year, the City shall conduct training sessions for Public Works employees, Parks and Recreation employees, and members of the City’s full-time right-of-way and parks maintenance crews. At a minimum, direct supervisors of the employees performing the work shall attend the training and implement that training in execution of maintenance worth throughout the City.
Topics to be addressed may include:
• Pollution Prevention
• Landscape Waste Control
• Illicit Discharge Detection
• Source Tracing for Illicit Discharges
• Identification of Potential MS4 Defects
• Spill Prevention
• Proper Protection of Stored Erodible Materials
• Erosion & Sediment Control During Municipal Operations, etc.
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The Stormwater Manager shall maintain a log and sign-in sheet of all training activities, subject matter, dates, and attendees.
Appendix A – Definitions
1. City right-of-way 2. City right-of-way, drainage structures and pipes
Best Management Practices (BMPs) mean structural and non-structural methods to support one of the MCMs and improve water quality.
DryWeather Flow means flowing water in MS4 conveyances / structures when there has been no precipitation greater than or equal to 0.1” within 72 hours. Dry weather flow is associated with illegal or illicit connections or dumping polluted water into the MS4.
Dry-Weather Flow-Screening means the screening of dry weather flow grab samples through color, odor, turbidity, floating materials, temperature, conductivity, pH, surfactants, fluoride, and fecal coliform.
Georgia Stormwater Management Manual (GSMM) means the latest addition of the GSMM published and maintained by the Atlanta Regional Commission (ARC) and any documents adopted in the GSMM by reference. The CoB adopted the GSMM on December 5, 2014.
Green Infrastructure means the variety of measures that reduce volumes of runoff introduced into downstream sewer systems and/or surface waters through storage, infiltration, evapotranspiration, reuse, diversion, landscaping. Examples are pervious pavement, bioswales, raingardens, integrated tree wells, etc. LID and GI are complementary and are often termed together, GI/LID.
Illicit Connection means any man-made conveyance connecting a non-stormwater discharge directly to a municipal separate storm sewer system.
Illicit Discharge means any direct or indirect non-stormwater discharge to a municipal separate storm sewer system, including, but not limited to, sewage, process wastewater, and wash water.
The discharge may be continuous or intermittent in occurrence.
Low Impact Design / Development (LID) means the use of natural or semi-natural systems to manage stormwater at its source and to reduce or eliminate the development of stormwater runoff so it does not require or requires significantly reduced construction of stormwater management facilities. LID and GI are complementary and are often termed together, GI/LID.
Minimum Control Measure (MCM) one of the six control measures that are deemed sufficient to meet the water quality goals of the CWA. The MCMs include: Public Education and Outreach, Public Involvement, Illicit Discharge Detection and Elimination (IDDE), Construction Site Runoff Control, Post-construction Stormwater Management, and Pollution Prevention/Good Housekeeping.
Maximum Extent Practicable means the controls necessary for the reduction of pollutants discharged from a municipal separate storm sewer system. These controls may consist of a combination of BMPs, control techniques, system design and engineering methods, and such other provisions for the reduction of pollutants discharged from an MS4 as described in the SWMP.
Municipal Separate Storm Sewer System (MS4) means a specific and legally recognized stormwater management system comprised of stormwater management system components that operates under an approved SWMP. In the CoB, the MS4s which may be encountered are systems typically owned and/or operated by either a city (Brookhaven, Doraville, Atlanta, Chamblee, etc.), Inpsection, Mainteance, and Operation Plan 18 February 15, 2020 .H:\Public Works\STORMWATER\08-EPD & MS4 PROGRAMS\2022 RFP - MS4 Inventory Inspections\Appendix\Municipal_Insp_Ops_Maint_Prog_20201113.docx
DeKalb County (unincorporated portions of DeKalb County), or the Georgia Department of Transportation (GDOT).
Specifically, the Georgia Environmental Protection Division (EPD) definition for an MS4 is a conveyance or system of conveyances including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, manmade channels or storm drains, owned or operated by a municipality or other public body, designed or used for collecting or conveying stormwater runoff and is not a combined sewer or part of a Publicly Owned Treatment Works.
MS4 Control Structures mean catch basins, ditches, detention/retention ponds, and storm drain lines. These structures/assets must be inventoried, mapped, inspected, and maintained per the requirements of MCM #6 Pollution Prevention / Good Housekeeping. Regulatory Term.
National Pollutant Discharge Elimination System (NPDES) means the permitting program authorized by the Clean Water Act (CWA), approved by the US EPA, and implemented by the Georgia Department of Natural Resources (DNR) Environmental Protection Division (EPD) that provides authority to discharge into Waters of the United States (WOTUS) and Waters of the State.
Notice of Intent or NOI means the mechanism used to register for coverage under the Phase II General Permit.
Phase II General Permit means the general stormwater permit issued under the NPDES program by EPD and authorized by the US EPA that allows Phase II designated MS4s to discharge stormwater into WOTUS and Waters of the State of Georgia. The Phase II permit contains six Minimum Control Measures (MCMs) that are qualitative rather that quantitative standards deemed by EPA and EPD sufficient to meet the goals of the CWA. The City of Brookhaven was designated a Phase II City requiring a Phase II General Permit on October 3, 2013.
Post-Construction Stormwater Management Structures mean detention/retention ponds, water quality vaults, and similar (to be called Ponds hereafter) that must be inventoried and mapped under Minimum Control Measure Post-Construction Stormwater Management in New Development and Redevelopment. This includes all City-owned Ponds, publicly-owned by other public entities, and all privately-owned ponds designed and built after adoption of the GSMM.
Outfall means the most downstream point (i.e. final discharge point) on a MS4 where is discharges to receiving waters of the State.
Source Tracing means an investigation, which is initiated immediately upon the discovery of new and unknown dry weather flow in the MS4, to determine the location and character of the flow source and to screen the flow for water quality pollutants in the flow.
Stormwater Management Program (SWMP) means the CoB program authorized by EPD that meets the requirements of the NPDES Phase II General Permit.
Stormwater Management Systems mean the systems that convey, collect, and treat stormwater runoff, and, by doing so, reduce localized flooding and may provide some measure of water quality protection and enhancement.
Stormwater Runoff means water produced from precipitation events that is not caught in the pore spaces of asphalt, concrete, vegetation, detritus, buildings, unsaturated soil, etc. or absorbed into the ground; thus, it “runs off” the ground. The amount of stormwater runoff that is produced for
Inpsection, Mainteance, and Operation Plan 19 February 15, 2020 .H:\Public Works\STORMWATER\08-EPD & MS4 PROGRAMS\2022 RFP - MS4 Inventory Inspections\Appendix\Municipal_Insp_Ops_Maint_Prog_20201113.docx a given precipitation event is a factor of the amount of precipitation; the timeframe for the production of rainfall (known as both duration and intensity); the ground cover; the slope of the ground; the shape of the ground (terrain); antecedent rainfall; the time of year; geography; natural and manmade hydrologic features; and other factors.
Structures, conveyances, stormwater treatment facilities, and natural drainage-ways:
generic drainage related terms used to describe a special set of infrastructure assets known as stormwater management systems.
Waters of the State mean any and all rivers, streams, creeks, branches, lakes, reservoirs, ponds, drainage systems, springs, wells, wetlands, and all other bodies of surface or subsurface water, natural or artificial, lying within or forming a part of the boundaries of the State which are not entirely confined and retained completely upon the property of a single individual, partnership, or corporation.
Appendix B Residential Plat Dedications and Language Classes Stormwater Asset Inspection and Maintenance Responsibility
City Maintenance Responsibilities
1. City right-of-way 2. City right-of-way, drainage structures and pipes 3. City right-of-way, drainage structures and pipes, stormwater ponds 4. None 5. Per SWFMA
The following list summarizes the classes of stormwater asset dedications generally found in recorded plats in the City of Brookhaven. Until 2013, the area of DeKalb County that became the City of Brookhaven was unincorporated DeKalb County. A review of the dedication language found in the plats reviewed prior to the publication of the IMOP identified the following types of dedications. Following the description, in an italics font, is a brief description describing the status of the City’s designation as a Phase II MS4 and adoption of the Georgia Stormwater Management Manual (GSMM) as the City’s Stormwater Manual at the time the plat was recorded. Following the Regulatory status summary is a number or series of numbers representing the level of the City’s maintenance responsibilities that are consistent with the plat dedication language. This number signifies what, as a result of any dedication language, the extent of City operation and maintenance responsibility is, e.g. a designation of 1. Indicates the City is responsible for assets in the public right-of-way. A key to the numbering scheme is found at the bottom of each page.
1. No designation of stormwater O&M responsibilities, no drainage easements provided (generally up to the mid 1960’s). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 1.
2. Dedication of all infrastructure to the “Public forever.” As-built drainage infrastructure are shown and subsequently dedicated. Drainage easements may or may not be shown (generally mid 1960’s up to the mid 1980’s). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 2.
3. Dedication of all infrastructure to the “Public forever,” and acknowledgment of a “special taxing district” for the maintenance of stormwater detention facilities.
Drainage easements and as-built drainage infrastructure are shown and subsequently dedicated (generally mid 1980’s up to the mid 1990’s). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 3.
4. Establishment of drainage and access easements and dedication of all drainage infrastructure and detention facilities to a mandatory Home Owners Association (HOA) (generally mid 1990’s up to the mid 2000’s). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 1. if the ROW is public. 4.
if the ROW (aka, access and utility easements) is privately owned.
5. Establishment of drainage and access easements and dedication of all drainage infrastructure and detention facilities to a mandatory Home Owners Association (HOA). Reference to a Stormwater Facility Maintenance Agreement in the Plat (generally the early 2000’s). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 1. if ROW public. 4. if ROW private.
6. Clear language making all drainage and access easements and all drainage infrastructure and detention facilities private, Reference to a Stormwater Facility Maintenance Agreement may or may not be in the Plat (generally from 1980’s and
City Maintenance Responsibilities
1. City right-of-way 2. City right-of-way, drainage structures and pipes 3. City right-of-way, drainage structures and pipes, stormwater ponds 4. None 5. Per SWFMA later, when used). Prior to designation as a Phase II municipality – Prior to adoption of the GSMM. 4.
7. Establishment of drainage and access easements and dedication of all drainage infrastructure and detention facilities to a mandatory Home Owners Association (HOA). Reference to a Stormwater Facility Maintenance Agreement in the Plat (generally early to mid 2010’s to present). After designation as a Phase II municipality – After adoption of the GSMM. 1.
Inspection, Operation, Maintenance, and Reporting Responsibilities By Asset Type
Asset Type: Post-Construction Stormwater Management Structures Applies to: Ponds owned by City of Brookhaven Ownership Designation: City-owned Inventory and Mapping Responsibility: CoB Inspection Responsibility: CoB Maintenance Agreement Required: No Maintenance Responsibility: CoB Standard for Maintenance: GSMM where “as-designed” data exists. Structural repairs. City
Property Maintenance Code MS4 Annual Reporting Required:
• One full geographic area each year, 100% in five years:
• Applies to Inventory, Map, Inspection, and Maintenance
• Report date of inspection, number, type, ownership, condition, and priority
• Update Inventory and Map
• Perform maintenance on 100% of HIGH PRIORITY
• Work Orders with work performed for completed and incomplete maintenance Assets are owned and maintained by the CoB. The SWMP and MS4 Permit also refers to these assets as permittee-owned or publicly-owned.
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