Stormwater - Phase II MS4 Program

Engineering Dept
City Hall, 2nd Floor
300 South 5th Street
P.O. Box 2267
Paducah, KY 42002-2267

What is Phase II MS4 Program?

The Stormwater Phase II MS4 program is an initiative of the United States Environmental Protection Agency that helps control pollutants entering waters of the Commonwealth. As part of the Municipal Separate Storm Sewer System (MS4) program and with oversight from the Kentucky Division of Water, the City of Paducah is responsible for regulating the MS4 located within the corporate limits of the City. A MS4 means a conveyance, or system of conveyances (including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, and storm drains) owned or operated by the City and designed or used for collecting or conveying stormwater that discharges to waters of the Commonwealth. Sanitary and combined sewers are not included in the definition of the municipal separate storm sewer system.

The City of Paducah has developed a Stormwater Quality Management Plan (SWQMP)—a roadmap for stormwater management activities to comply with the Stormwater Phase II MS4 General Permit. The SWQMP is reviewed every year and updated annually if needed. The SWQMP is based on six minimum control measures which are monitored, assessed, and reported on annually with the goal of improving stormwater quality.

  1. Public Education and Outreach
  2. Public Involvement and Participation
  3. Illicit Discharge Detection and Elimination
  4. Construction Site Stormwater Runoff Control
  5. Post-Construction Stormwater Management in New Development and Redevelopment
  6. Pollution Prevention/Good Housekeeping for Municipal Operations

Illicit Discharges

What Is Illicit Discharge?  Illicit discharge is any direct or indirect non-stormwater substance or hazardous material disposed, deposited, spilled, poured, injected, seeped, dumped, leaked, or placed by any means, intentionally or unintentionally, into the MS4 or any area that has been determined to drain directly or indirectly into the MS4.  Illicit discharges are considered illicit because MS4s are not designed to accept, process, or discharge such non-stormwater wastes.

Federal regulations define an illicit discharge as “...any discharge to a MS4 that is not composed entirely of stormwater...” with some exceptions.

Sources of Illicit Discharges include * Sanitary wastewater * Effluent from septic tanks * Car wash wastewaters * Improper oil disposal * Radiator flushing disposal * Laundry wastewaters * Spills from roadway accidents * Improper disposal of Auto and Household toxins

Examples of exempt discharges include * Water line flushing * Landscape irrigation * Diverted stream flows * Rising ground waters * Uncontaminated ground water infiltration * Uncontaminated pumped ground water * Discharges from potable water sources & Foundation drains * Air conditioning condensation * Irrigation water * Springs * Water from crawl space pumps * Footing drains * Lawn watering * Individual residential car washing * Flows from riparian habitats and wetlands * De-chlorinated swimming pool discharges * Street wash water * NPDES-permitted industrial sources * fire-fighting activities

Why Are Illicit Discharge Detection and Elimination Efforts Necessary?  Discharges from MS4s often include wastes and wastewater from non-stormwater sources.  A study conducted in 1987 in Sacramento, California, found that almost one-half of the water discharged from a local MS4 was not directly attributable to precipitation runoff.  A significant portion of these dry weather flows was from illicit and/or inappropriate discharges and connections to the MS4.

Illicit discharges enter the system through either direct connections (e.g., wastewater piping either mistakenly or deliberately connected to the storm drains) or indirect connections (e.g., infiltration into the MS4 from cracked sanitary systems, spills collected by drain outlets, or paint or used oil dumped directly into a drain). The result is untreated discharges that contribute high levels of pollutants, including heavy metals, toxins, oil and grease, solvents, nutrients, viruses, and bacteria to receiving water bodies. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife, and human health.

What Paducah is Doing.  By Paducah Code of Ordinances Chapter 42 - 52, illicit discharge is illegal, punishable by fines up to $500. The City has developed an Illicit Discharge Detection and Elimination (IDDE) Plan to find, stop, and eliminate all illicit discharges encountered. To report a spill or an illicit discharge, contact the Engineering Department at 270-444-8511.

Erosion Prevention and Sediment Control

Erosion is the wearing away of the ground surface as a result of the movement of wind, water, ice, and/or vehicles and equipment associated with land disturbance activities.  Construction activities can increase the amount of soil exposed on a property, which can lead to sediment runoff into adjacent streets, streams, and storm sewers.  To help minimize the amount of sediment runoff, developers of new and redeveloped property may be required to submit an Erosion Prevention and Sediment Control (EPSC) Plan as part of the application process for an EPSC Permit

The requirements for erosion prevention and sediment control are outlined in Chapter 50 Article IV of the Paducah Code of Ordinances and associated forms are available at Site Development and RedevelopmentEPSC Permits are required in the following circumstances:

  1. All land-disturbing activities including development and redevelopment activities that disturb an area greater than or equal to one (1) acre.  Sites that are smaller than one (1) acre are also subject to this requirement if they are part of a larger common plan of development or sale as defined by this article.
  2. Land-disturbing activities of less than one (1) acre that have the potential to negatively impact local water quality, sensitive areas, or result in a nuisance to the public.  This determination will be made at the sole discretion of the City Engineer or his designee. 

Site Development and Redevelopment

Stormwater Management and Water Quality Control Facilities

Stormwater is a concern to the City of Paducah and has to be controlled from both a quantity and quality standpoint.  Construction activities and increased impervious surfaces associated with new development and expansion of existing sites can lead to increased stormwater runoff and pollution.  To control the increase of stormwater runoff, developers of new and redeveloped property may be required to submit a Stormwater Management and Water Quality Plan.

Requirements and design criteria for stormwater management and water quality control facilities are outlined in Chapter 50 Article III of the Paducah Code of Ordinances and associated forms are available at Site Development and Redevelopment. Stormwater management and water quality control facilities are required in the following circumstances:

  1. All land-disturbing activities and all development or redevelopment activities that disturb an area greater than or equal to one (1) acre.
  2. Sites that are smaller than one (1) acre may also be covered by these regulations if they are a part of a larger common plan of development or sale.
  3. Any development or redevelopment project that adds ten thousand (10,000) square feet or more of impervious surface.
  4. At the discretion of the City Engineer this requirement may apply to any existing nonresidential redevelopment project for which the total impervious area of the property is equal to or greater than ten thousand (10,000) square feet.

Site Development and Redevelopment