Rockdale County’s NPDES General Permit Requirements
What is the Clean Water Act?
The Clean Water Act (CWA) is a federal law, originally enacted by Congress and signed by the President in 1972, that established environmental programs to protect the Nation’s waters from pollutants and authorizes the U.S. Environmental Protection Agency (EPA) to develop, implement, and enforce regulations consistent with this law. Under the CWA, the EPA has implemented pollution control programs and set water quality standards for all contaminants in surface waters.
How has the Clean Water Act (CWA) helped?
Since the passage of the CWA, our Nation’s water quality has improved dramatically. Despite this progress, however, approximately 40% of surveyed U.S. water bodies are still impaired by pollution and do not meet water quality standards. A leading source of this impairment is polluted stormwater runoff. When unmanaged, this water pollution can result in: a loss in aesthetic value; the destruction of fish, wildlife, and aquatic habitats; and threats to public health due to contaminated food, drinking water supplies, and recreational waterways.
What is the National Pollutant Discharge Elimination System (NPDES) permit program?
Section 402 of the CWA specifically required the EPA to develop and implement the National Pollutant Discharge Elimination System (NPDES) permit program to address water quantity and quality problems in the U.S. The NPDES permit program is a comprehensive, two-phased national program for addressing the non-agricultural sources of pollution which negatively affects the quality of our nation’s water sources. Basically, the NPDES program requires a permit to be obtained before any discharge is allowed into a water body; unpermitted discharges are considered illegal. The NPDES program regulates discharges from three potential pollution sources: municipal separate storm sewer systems (MS4s), construction activities, and industrial activities.
Under the Water Quality Act of 1987, Congress mandated Rockdale County (as well as other municipalities) to obtain an NPDES Stormwater permit from the Georgia Environmental Protection Division (EPD) to discharge stormwater runoff from the County’s MS4. The NPDES stormwater permit requires the development and implementation of effective stormwater management programs (SWMPs), control measures, and best management practices (BMPs) that effectively reduce or prevent the discharge of pollutants into local surface waters, such as streams, rivers, lakes, and wetlands. The EPA authorizes state governments to perform many of the permitting, administrative, and enforcement aspects of the NPDES program. The Georgia Environmental Protection Division (EPD) is the state governmental authority with jurisdiction over Rockdale County.
Under the national NPDES program, Rockdale County is considered a regulated small Phase II MS4 operator, and must meet the requirements of the NPDES stormwater permit to legally discharge stormwater from the County’s MS4.
What is a Municipal Separate Storm Sewer System (MS4)?
Rockdale County’s municipal separate storm sewer system (MS4) is any structure, feature, or facility that collects, treats and/or conveys stormwater, including but not limited to: county highways, county streets, curbs, gutters, inlets, catch basins, storm sewers, culverts, ditches, swales, natural and man-made drainage channels, streams, ponds, lakes, reservoirs, and wetlands. The MS4 does not include water supply systems, sanitary sewer systems, septic systems, drinking water treatment facilities, or wastewater treatment facilities.
Why are stormwater discharges a problem?
As urbanization spreads throughout the metropolitan area, more people live in, work in, and travel through Rockdale County. This urbanization requires an ever-increasing amount of land to be developed. Land development generally includes clearing, grading, and construction of impervious surfaces such as buildings, roads, driveways, parking lots, and sidewalks. As a result, land development increases the volume of stormwater runoff, which can lead to flooding and erosion. The amount of pollutants such as pesticides, fertilizers, oils, solvents, litter, and sediment increases with population growth. These pollutants accumulate on lawns, roads, and other surfaces, until they are washed into the MS4 by stormwater; contaminated stormwater is then discharged from the MS4 into local water bodies. The combination of increased stormwater runoff volume and contamination can threaten safety, property, and the environment.
What are the NPDES requirements for Rockdale County?
Rockdale County, as a small MS4 operator regulated by NPDES permit requirements, must develop, implement, and enforce an effective stormwater management program by the end of the 5-year permit period (December 2012). The program must be designed to reduce the discharge of pollutants from the County’s MS4 to waters of the state to the “maximum extent practicable,” to meet water quality requirements of the Clean Water Act. The County’s stormwater management program includes the following required six minimum control measures:
1. Public Education and Outreach- The County must educate the general public about the impacts of stormwater pollution and offer methods on how to reduce or prevent stormwater pollution. The current program includes distributing educational brochures, creating and updating a stormwater website, and holding yearly meetings for builders, developers, and engineers.
2. Public Participation and Involvement- The County must create a program to involve the general public in events to help prevent or reduce stormwater pollution. The current program includes the storm drain stenciling program, community stream cleanup events, and offering a 24-hour environmental hotline.
3. Illicit Discharge Detection and Elimination- The County must develop, implement, and enforce a program to detect and eliminate illicit discharges and illegal connections to the County’s MS4. The current program includes the adoption of the Illicit Discharge Detection and Elimination ordinance to prohibit all non-stormwater discharges into the County’s MS4. It also includes storm sewer outfall mapping, dry weather screening of the mapped outfalls, and source tracing and removal of illegal discharges and connections to the County’s MS4.
4. Construction Site Stormwater Runoff Control- The County must develop, implement, and enforce a program to reduce pollutants in stormwater runoff to the County’s MS4 from construction activities. The current program includes the adoption of the Erosion and Sediment Control ordinance, the requirements of implementing erosion and sediment control best management practices, site plan review, site inspection, and enforcement of control measures.
5. Post-Construction Stormwater Management- The County must develop, implement, and enforce a program to address stormwater runoff to the County’s MS4 from new development and redevelopment projects to ensure that controls are in place to prevent or minimize water quality impacts. The current program includes the adoption of the Georgia Stormwater Management Manual for design of structural and non-structural best management practices for stormwater management and adoption of the Stormwater Management ordinance to address post-construction runoff. The program also includes a plan to ensure adequate long-term operation and maintenance of stormwater management facilities (detention ponds), which includes inspection of all facilities.
6. Pollution Prevention and Good Housekeeping-The County must develop and implement an operation and maintenance program to reduce and prevent stormwater pollution resulting from County operations and facilities. The current program includes training County employees, regular MS4 inspection and maintenance, and future water quality improvement projects.
Summaries of how the County implemented and evaluated the effectiveness of the stormwater management program are included in annual reports submitted to the Georgia Environmental Protection Division (EPD) for review and approval. These annual reports document the yearly actions taken by Rockdale County to meet the County’s NPDES permit requirements.
Rockdale County’s Metropolitan North Georgia Water Planning District Requirements
The Metropolitan North Georgia Water Planning District (Metro Water District) was created by the Georgia General Assembly in 2001 to establish policy, create plans and promote intergovernmental coordination of all water issues in the District from a regional perspective. The Metro Water District includes 15 counties and over 90 cities within the metro Atlanta region, including Rockdale County. The primary purpose of the District is to develop regional and watershed-specific plans for stormwater management, wastewater treatment and water supply conservation. The three comprehensive water plans were adopted in 2003:
1. District-wide Watershed Management Plan-enforcing five Model Stormwater Ordinances
2. Long-term Wastewater Management Plan
3. Water Supply and Water Conservation Management Plan
These plans will protect water quality and public water supplies in and downstream of the region, protect recreational values of the water in and downstream of the region, and minimize potential adverse impacts of development on waters in and downstream of the region. Under these plans, municipalities are required to implement effective stormwater management plans, which can be broken down into the following six areas:
1. Watershed Planning-Using the watershed as the framework for managing land use and developing large scale solutions to regional stormwater quantity and quality problems.
2. Development Requirements-Addressing the stormwater impacts of new development and redevelopment through stormwater management requirements and minimum standards.
3. Erosion and Sediment Control-Controlling erosion and soil loss from construction areas and resultant downstream sedimentation.
4. Floodplain Management-Preserving the function of floodplain areas to reduce flood hazards, minimize risks to human life and property, reduce modifications to streams and protect water quality.
5. Operations and Maintenance-Ensuring that stormwater management systems and structural controls work as designed and constructed, including the retrofitting of existing problem areas and stream bank stabilization activities.
6. Pollution Prevention-Preventing stormwater from coming in contact with contaminants and becoming polluted through a number of management measures.
Local governments and utilities in the Metro Water District must meet requirements of the Metropolitan North Georgia Water Planning District Act, which is Georgia law, and are responsible from implementing the plans at the local level. Municipalities within the District are required to adopt the five Model Stormwater Management Ordinances:
1. Model Ordinance for Post-Development Stormwater Management for New Development and Redevelopment
2. Model Floodplain Management / Flood Damage Prevention Ordinance
3. Model Stream Buffer Protection Ordinance
4. Model Illicit Discharge and Illegal Connection Ordinance
5. Model Litter Control Ordinance
In order for a local government to receive a permit for an increased water withdrawal, a new or increased discharge, or for a MS4 permit, that jurisdiction must be in compliance with the District plans. Compliance with the plans is enforced through the Georgia EPD’s permitting process.
Why does Rockdale County need a Stormwater Utility?
Rockdale County is authorized by the 1983 Georgia Constitution to provide stormwater management services, systems, and facilities throughout the unincorporated areas of the County. These stormwater services and systems contribute to the protection and preservation of the public health, safety and welfare, and protection of the natural resources of the County.
By Federal and State mandate, Rockdale County is charged with the responsibility under the National Pollutant Discharge Elimination System (NPDES) permit program, to develop, implement, and enforce an effective Stormwater Management Program designed to reduce the discharge of pollutants from the municipal separate storm sewer system (MS4) to waters of the state, in order to protect and improve water quantity and quality.
To meet Federal and State mandates, as well as, provide stormwater management services to the County, a stormwater utility was created. The Rockdale County Stormwater Utility was effective as of October 1, 2005. The Stormwater Utility Enterprise funds are only utilized for stormwater management program needs; this includes meeting NPDES permit requirements, and maintenance, repair, and/or replacement of existing infrastructure.