Council Meeting - June 26th 7:30pm

Illicit Discharges


The City of Cold Spring’s Municipal Separate Storm Sewer System (MS4) is a system that discharges stormwater runoff to surface water, or waters of the state. Phase II regulates discharges from small MS4s located in “urbanized areas” (as delineated by the Census Bureau in the most recent census) and from additional small MS4s designated by the Energy and Environment Cabinet, Department for Environment Protection, Kentucky Division of Water (KDOW).

The Illicit Discharge Detection and Elimination (IDDE) program includes a Standard Operating Procedure (SOP) Manual and IDDE plan that will serve as the draft manual of rules and regulations and guide for the City of Cold Spring to fulfill the IDDE requirements of the Municipal Separate Storm Sewer System (MS4) Permit water quality program. Implementation of an Illicit Discharge Detection and Elimination (IDDE) program is one of the third of six minimum control measures (MCM) of the permit’s Storm Water Quality Program. This SOP is primarily directed at isolating, responding and documenting and reporting any illicit discharges in the compliance annual report to KDOW.

The City of Cold Spring’s Storm Water Quality Program (SWQMP) has multiple BMP components of the IDDE Program including educating the public; the Illicit Discharge Detection and Elimination plan; The IDDE Ordinance (regulatory) the Stormwater System GIS Mapping, Public and Employee Illicit Discharge Information Program, the Identification of Known Storm Water Discharges and Flows and training for the City of Cold Spring Staff for the IDDE stormwater program.

The EPA’s Phase II rule specifies that permitting authorities (i.e., the KDOW) must issue general permits for small Kentucky MS4 communities. The rule required that the Kentucky MS4 communities apply for KPDES permit coverage within 90 days of permit issuance, and no later than March 10, 2003. USEPA’s Stormwater Phase II Final Rule states that this stormwater management program must include the following six minimum control measures: MCM#1 – Public education and outreach on stormwater impacts, MCM#2 – Public involvement and participation, MCM#3 – Illicit discharge detection and elimination (IDDE), MCM#4 – Construction site stormwater runoff control, MCM#5 – Post-construction practices ( new and redevelopment, and MCM#6 – Pollution prevention and good housekeeping for municipal operations.

As part of our application for permit coverage, the City of Cold Spring must identify the best management practices we will use to comply with each of these six minimum control measures and the measurable goals we have set for each minimum control measure.