Why are Ashland, Catlettsburg, and Boyd County required to have a Phase II Storm Water Management Program?
The City of Ashland, City of Catlettsburg, and Boyd County are part of the larger Huntington-Ashland WV/KY/OH urbanized area as calculated by the US Bureau of the Census. Being a part of this urbanized area each entity is designated a small municipal separate storm water sewer system (small MS4) by the US Environmental Protection Agency (USEPA), subject to the Clean Water Act and the NPDES Phase II storm water program requirements. In the state of Kentucky, the Kentucky Division of Water (KDOW) under the Department of Environmental Protection is the administrator of the Phase II storm water program.
History of NPDES Program
The National Pollutant Discharge Elimination System (NPDES) originally began as part of the 1972 Clean Water Act (CWA). The U.S. Environmental Protection Agency (USEPA) initially targeted point-source pollution (industrial plants, wastewater sewage plants) with sampling, monitoring, water treatment, improved material handling, better manufacturing technology, etc. This portion of the NPDES program has been very effective at improving water quality in our streams and rivers.
As more data was gathered, it was learned that most pollution comes from nonpoint sources where it is difficult to identify the source and responsible party. Nonpoint pollution sources include: soil erosion, aerially-deposited particles, roadside trash, leaves and sticks, automotive fluids from leaking vehicles onto roadways and parking lots, products of incomplete combustion, food processing wastes, and transportation spills of chemicals and other pollutants. In 1987 the Clean Water Act was amended to include provisions for reducing nonpoint pollution sources.
The NPDES permit program is managed by the Kentucky Division of Water (KDOW) under the Department for Environmental Protection, with federal oversight maintained by USEPA.
Under the storm water portion of the NPDES program, operators of large, medium and regulated small municipal separate storm sewer systems (MS4s) require authorization to discharge pollutants under an NPDES permit. A municipal separate storm sewer system means a conveyance or system of conveyances, including roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man- made channels, or storm drains.
The Phase I Rules promulgated in 1990 requires operators of medium and large MS4s, that is, those that generally serve populations of 100,000 or greater, to implement a storm water management program as a means to control polluted discharges from these MS4s.
Phase II Storm Water Program
The Phase II Rules promulgated in 1990 requires operators of small MS4s to obtain a NPDES permit and develop a storm water management program designed to prevent harmful pollutants from being washed by storm water runoff into the MS4 or from being dumped directly into the MS4 and then discharged into local waterbodies. The Phase II Rule automatically covers on a nationwide basis all small MS4s located in “urbanized areas” as defined by the Bureau of the Census. An urbanized area is a land area comprising one or more places and the adjacent densely settled surrounding area, “urban fringe”, that together have a residential population of at least 50,000 and an overall population density of at least 1,000 people per square mile.
Operators of Phase II MS4s are required to design their programs to:
- Reduce the discharge of pollutants to the “maximum extent practicable” (MEP);
- Protect water quality;
- Satisfy the appropriate water quality requirements of the Clean Water Act.
The Phase II Rule defines a small MS4 storm water management program as a program comprising six elements that, when implemented in concert, are expected to result in significant reductions of pollutants discharged into receiving waterbodies.
The six MS4 program elements, termed “minimum control measures,” are outlined below:
Public Education and Outreach: Distributing educational materials and performing outreach to inform citizens about the impacts polluted storm water runoff discharges can have on water quality.
Public Participation/Involvement: Providing opportunities for citizens to participate in program development and implementation, including effectively publicizing public hearings and/or encouraging citizen representatives on a storm water management panel.
Illicit Discharge Detection and Elimination: Developing and implementing a plan to detect and eliminate illicit discharges to the storm sewer system (includes developing a system map and informing the community about hazards associated with illegal discharges and improper disposal of waste).
Construction Site Runoff Control: Developing, implementing, and enforcing an erosion and sediment control program for construction activities that disturb 1 or more acres of land (controls could include silt fences and temporary storm water detention ponds).
Post-Construction Runoff Control: Developing, implementing, and enforcing a program to address discharges of post-construction storm water runoff from new development and redevelopment areas. Applicable controls could include preventative actions such as protecting sensitive areas (e.g., wetlands) or the use of structural BMPs such as grassed swales or porous pavement.
Pollution Prevention/Good Housekeeping: Developing and implementing a program with the goal of preventing or reducing pollutant runoff from municipal operations. The program must include municipal staff training on pollution prevention measures and techniques (e.g., regular street sweeping, reduction in the use of pesticides or street salt, or frequent catch-basin cleaning).
Background on Ashland, Catlettsburg, and Boyd County SWMP
To meet these Phase II storm water program requirements Ashland, Catlettsburg, and Boyd County collectively called the “MS4 Group”, decided to join together in developing and implementing a comprehensive SWMP. An audit of City and County departments were conducted to obtain information regarding day to day operations and ongoing programs and activities as they pertain to storm water quality issues and the six minimum controls.
The Kentucky Transportation Cabinet is also a permittee in the Phase II program and assist local MS$ groups with storm water issues in the various areas of the state.
The SWMP incorporates existing storm water quality related activities and identifies new activities and programs to meet the Phase II storm water program requirements. The SWMP identifies the activity, task required, measure goals, and milestone dates for the following MS4 program elements:
- Public Education and Outreach
- Public Participation/Involvement
- Illicit Discharge Detection and Elimination
- Construction Site Runoff Control
- Post-Construction Runoff Control
- Pollution Prevention/Good Housekeeping
The original SWMP was adopted by the MS4 Group and in March 2002 a comprehensive SWMP and Notice of Intent for Storm Water Discharges from small MS4s was submitted to KDOW.
The current Phase II Storm Water Permit (KYG200000) was issued March 1, 2010, to Ashland (permittee) and Catlettsburg and Boyd County (co-permittees) and became effective April 1, 2010. The permit is for a term of five years.What Phase II Storm Water Program activities have Ashland, Catlettsburg, and Boyd County completed?
The MS4 Group has completed numerous activities as part of the SWMP. Several of these activities are performed on an annual basis while others are on-going.
A few of these activities and programs are listed below:
- Conduct Storm Water Advisory Committee (SWAC) meetings to discuss SWMP and related storm water quality issues.
- Distribute water quality brochures in water bills.
- Provide NPDES Phase ll storm water pamphlets and flies at the County fair, Catlettsburg Labor Day Parade, Poage Landing Days, and other various events and civic groups.
- Participate in FIVCO River Sweep Program.
- Participate in the US 23 Alliance Beautification Program – clean up trash and debris.
- Participate in the Ashland Tree Board Tree Give-A-Way Program providing tree seedlings for planting to promote ‘green’.
- Conduct Fall and Spring County Wide Cleanup Program – clean up trash, household pesticides, chemicals, electronics, etc.
- Participate in the State Tire Recycle Program.
- Offer recycling bins for residents to drop off recyclable materials.
- Developed map of MS4 outfalls.
- Passed an ordinance prohibiting illicit discharges.
- Performing dye and smoke testing in areas of potential or probable illicit connections.
- Investigate all reports of illicit discharges.
- Passed an ordinance to address construction site runoff.
- Adopted KDOW BMP Manual.
- Developed a process for having contractors/developers to obtain an Erosion Control Permit.
- Established procedures for construction site inspection and enforcement.
- Passed an ordinance to reduce storm water runoff from new development and redevelopment projects.
- Providing street sweeping.
- Provide culvert and channel maintenance.
- Continually provide Phase II training and workshops for City and County employees
- Perform an audit each year on a city/county department to identify ways to prevent and reduce storm water pollution runoff from municipal activities.
Who do I contact to become involved or obtain more information on the Ashland, Catlettsburg, and Boyd County SWMP?
- City of Ashland – Marion Russell, Public Works Director at 606/327-2007 or e-mail: firstname.lastname@example.org.
- City of Catlettsburg – Catlettsburg City Building at 606/739-4533.
- Boyd County – Tim Wallin at 606/928-1285 or e-mail: email@example.com.
How Do I Report an Illegal or Illicit Discharge?
An illegal or illicit discharge is any direct or indirect not-storm water substance, pollutant, or hazardous material disposed, deposited, spilled, poured, injected, seeped, dumped, leaked, or placed by any means, intentionally or unintentionally, into storm sewers, culverts, drainage ditches, swales, creeks, rivers, or any other storm water conveyance system.
Hazardous may include any substance, waste, or combination thereof, which because of it quantity, concentration, or physical, chemical, biological or infectious characteristics may cause, or significantly contribute to, a substantial present or potential hazard to human health, safety, property, or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
Pollutants may include, but are not limited to: paints, varnishes, and solvents, oils and other automotive fluids; solid wastes and yard wastes, refuse, rubbish, garbage, litter, or other discarded or abandoned objects, and excessive amounts of pesticides, herbicides, and fertilizers.
To report an illegal or illicit discharge, contact:
- In the City of Ashland – Marion Russell at 606/327-2007 or firstname.lastname@example.org.
- In the City of Catlettsburg – 606/739-4533.
In Boyd County – Nickie Smith at 606/739-0010 or email@example.com.
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