Storm Water Management Program - City of Sikeston, Missouri - NPDES MS4 Permit MOR04C019 Permit Operating Period 2022-2027
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City of Sikeston, Missouri
Storm Water
Management
Program
NPDES MS4 Permit MOR04C019
Permit Operating Period 2022-2027
1
Table of Contents
Introduction
Purpose 3
Background 3
Climate and Hydrology 4
Permit Restrictions and Requirements 5
Storm Water Management Program 6
Minimum Control Measure 1: Public Education and Outreach 7
Minimum Control Measure 2: Public Involvement and Participation 10
Minimum Control Measure 3: Illicit Discharge Detection and Elimination 11
Minimum Control Measure 4: Construction Site Storm Water Runoff Control 15
Minimum Control Measure 5: Post Construction Storm Water Management 18
Minimum Control Measure 6: Pollution Prevention and Good Housekeeping 21
Monitoring, Recordkeeping, and Reporting 26
Appendices
Appendix A Ordinance #5816 on Construction Site Runoff; Post Construction Management
Appendix B Ordinance #6016 on Illicit Discharge and Elimination Ordinance
Appendix C Sikeston`s Municipal Boundary`s Map
Appendix D Sikeston`s Watershed Map
Appendix E Sikeston`s Major Ditches
Appendix F Sikeston`s MS4 with Major Outfalls
Appendix G City of Sikeston Storm Water Runoff Control Inspection Report
Appendix H City of Sikeston Illicit Discharge Reporting Form
Appendix I City of Sikeston Facilities Storm Water Pollution Inspection Form
Appendix J City of Sikeston Outfall Inspection Form
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Introduction
1.1 Purpose
1.1.A The City of Sikeston implements a Storm Water Management Program (SWMP) to
protect water quality and effectively reduce pollutants in storm water runoff to the maximum
extent practicable. This five-year plan was developed in accordance with the Clean Water Act
Phase II requirements outlined in Permit MOR04C019. This document replaces the SWMP for
the permit period of October 1, 2016, through September 30, 2021. It is divided into the six
Minimum Control Measures (MCMs) as outlined in Section 4.2 of the City’s MS4 Permit. For
each MCM, it contains Best Management Practices (BMPs) and measurable goals. Measurable
goals are selected to evaluate the effectiveness of individual control measures and the Storm
Water Management Program as a whole. This plan will be reviewed on a yearly basis and
updated as necessary.
1.2 Background
1.2.A The City of Sikeston is located in the southern portion of Scott County and northern
portion of New Madrid County. Major highways include Interstates 55 and 57, along with US
Highway 60, US Highway 61, and US Highway 62. Burlington Northern Railroad has a rail service
through the City. The City is also served by the Sikeston Memorial Airport. According to the 2020
census, Sikeston has a population of 16,291 citizens. The City of Sikeston is located at Lat. 36
degrees 52`39.43” N and Lon. 89 degrees 35`21.46” W. Sikeston has a total area of 17.48 square
miles, of which 17.32 square miles is land and 0.16 square miles is water. The City is situated
upon the Sikeston Ridge which runs north and south from 10 miles north of Sikeston south to
New Madrid. Prior to 1927, the New Madrid-Sikeston Ridge Levee was constructed to protect
the area from flooding from the Mississippi River. In the 1920s, the Little River Drainage District
was formed to drain the low land area west of the Sikeston Ridge.
1.2.B The City of Sikeston owns and operates a small Municipal Separate Storm Sewer System
(MS4). The City is identified as a traditional small MS4 that serves a population of at least 10,000
but less than 40,000. The system consists of over 2,400 storm water drains, over a hundred
miles of pipe, 6 City owned basins and 14 privately owned basins.
1.2.C Sikeston was the first community in the region to develop a Storm Water Management
Plan and Ordinance which was adopted in 1983. In 2004, the city became regulated under the
National Pollutant Discharge Elimination System (NPDES) Storm Water Phase II Rule. In 2010 an
updated ordinance, compliant with current storm water regulations was adopted. Since
becoming regulated, the City has spent a substantial amount of time educating the public
through internet resources, web pages, newspaper articles, social media, and brochures.
Sikeston has organized public outreach through programs such as public access to the City`s
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Yard Waste Disposal Site, leaf collection programs and bulk trash collections. The City has also
formed a Storm Water Advisory Board that meets regularly and invites the public. New
ordinances addressing illicit discharges have been adopted by the City recently, as well as a
detailed GIS map, and a Storm Water pollution hotline for citizens to report pollution concerns.
The City has ordinances in place for construction zone runoff, as well as detailed and
comprehensive inspections. City employees as well as area engineers are continually searching
and developing new post construction storm water management plans. And lastly, the City
continually educates their employees on good housekeeping practices and preventing pollution.
Sikeston`s Street Department maintains over 130 miles of roadway through street sweeping and
maintenance of storm pipe.
1.3 Climate and Hydrology
1.3.A Sikeston`s climate is thought to be moderate but can become erratic at times.
Temperatures range on average in the winter from a low of 27 degrees F to a high of 92 degrees
F in the summer, with an average of 59.3 F overall through the year. The City`s annual rainfall is
49.32 inches per year, with the higher totals in May and the lowest in September. The City
averages about 3 inches of snowfall per year.
1.3.B The City of Sikeston is located within two watershed districts. The watersheds are split
predominately by US Highway 61 (Business 61/ Kings Highway through the center of the City).
The Saint John’s Bayou watershed is located on the east side of the City while the Richland
Drainage District is on the west. The City`s two major outfalls that are covered by permit MO
R040025 are Saint John`s Ditch located on the east side of the City, and the Richland Drainage
District Ditch #4 which is located on the west side of the City. The City of Sikeston has over 47
miles of major and roadside ditches, including two lateral’s that flow to Saint John`s Ditch.
1.4 Sikeston`s Major Ditches
• Richland Drainage District Ditch # 4 7.4 Miles
• Saint John`s Ditch 3.7 Miles
• Saint John`s Ditch Lateral B 0.8 Miles
• Saint John`s Ditch Lateral C 1.8 Miles
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Permit Restrictions & Requirements
2.1 Permit restrictions and exemptions
2.1.A The City will prohibit non-storm water discharges and storm water discharges that
combine with sources of non-storm water into the MS4 except as authorized by the
MOR04C019 permit.
2.1.B The City`s SWMP will not affect, remove, or replace any requirement of the Endangered
Species Act; Historic Preservation Act; Comprehensive Environmental Response, Compensation,
and Liability Act; or the Resource Conservation and Recovery Act.
2.1.C The City will implement Best Management Practices (BMPs) via an iterative process to
reduce the discharge of pollutants to the Maximum Extent Practicable into the MS4 for the goal
of attainment with Missouri`s Water Quality Standards.
2.1.D The City will implement and enforce a Storm Water Management Program per the
requirements of the operating permit in accordance with the Clean Water Act, NPDES
regulations, and in accordance with the Missouri Clean Water Act.
2.1.E The City will comply with all provisions and requirements contained in the permit and
with its individual SWMP including plans, ordinances, and schedules developed in fulfillment of
the permit.
2.2 Authorization to discharge and application requirements
2.2.A The City has submitted a complete application for the MS4 general permit which seeks
authorization to discharge storm water from its regulated MS4. The City submitted its
application on Form K, Form M, as well as a Form K Municipal Map on March 30, 2021.
2.2.B The City`s permit applications were signed and certified by the City`s MS4 Coordinator in
accordance with Missouri state law.
2.2.C The City`s permit applications were submitted within 180 days prior to the expiration
date of its current operating permit.
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Storm Water Management Program & Plan
3.1 Storm Water Management Program
3.1.A To the extent allowable under state and local law, this Storm Water
Management Program (SWMP) was developed and will be implemented and enforced
according to the requirements of the general permit. The previous SWMP was assessed
and modified as seen necessary.
3.1.B The City is updating its SWMP with appropriate appendices and supplemental
attachments explaining the SWMP. The SWMP will describe schedules, procedures, contacts, or
other items as required by the permit.
• The SWMP will be maintained to ensure consistency with the implantation, continuity of
the SWMP, and iterative reviews of programmatic BMPs and procedures.
• The SWMP will be updated within 90 days after the renewal of the permit.
3.1.C Supplemental items were added to the SWMP. They are as follows:
• Maps of watersheds, municipal boundaries, major ditches, and major outfalls.
• Ordinances for illicit discharges, construction site runoff control, and post construction
runoff control.
• Inspection forms for dry weather screening, construction site runoff control and
municipal inspections.
3.1.D The City will implement programmatic BMPs consistent with the provisions of the
permit to achieve compliance with the standard of reducing pollutants to the maximum extent
practicable. The City will replace or modify ineffective BMPs with effective BMPs when deemed
necessary.
3.2 Sharing responsibility
3.2.A The City currently does not share any responsibilities or control measures for its MS4
program within its boundaries with another governmental entity. The City of Sikeston is solely
responsible for oversite to ensure compliance with the permit.
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Minimum Control Measures
4.1 Public Education and Outreach on Storm Water Impacts
4.1.A The City will implement a public education program to distribute materials to the
community and conduct outreach activities that educate about the impacts of storm water
discharges on water bodies and the steps that the public can take to reduce pollutants in storm
water runoff.
4.1.B The City will target the following audiences who are most likely to have significant storm
water impacts. They are as follows:
• The City of Sikeston residents being served by the MS4
• Schools, educational organizations, and other youth groups
• Developers and or construction site owners
• Contractors
4.1.C In order to minimize pollutants in storm water runoff the City will target specific
pollutants for each target audience. They are as follows:
Target Audience: Target Pollutant:
City of Sikeston Residents Yard Waste; Litter & Trash; Dumping of
Solid Waste;
Schools, Educational Organizations, Litter & Trash Containment; Charity Car
Youth Groups Washes
Developers and Construction Site Litter & Trash Containment; Sediment
Owners Runoff from Construction/ Land
Disturbance
Contractors Yard Waste; Fertilizers
4.1.D The City will utilize appropriate educational resources to be used as BMPs in conjunction
with the selected pollutants for the selected target audiences. During the permit cycle the City
will continually evaluate the effectiveness of each BMP and modify or replace BMPs that are
judged to be ineffective. The appropriate educational resources to be used as BMPs are as
follows:
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BMPs Target Pollutant: Target Audience: Permit Year
Storm Water Management Yard Waste; Litter & City of Sikeston 2022-2027
Web Services- The City of Trash; Sediment Residents; Schools &
Sikeston operates a web page Runoff from Youth Organizations;
found at www.sikeston.org Construction; Developers &
that provides easy access to Fertilizers Construction Site
storm water issues Owners; Contractors
Storm Water Management Yard Waste; Litter & City of Sikeston 2022-2027
Social Media- The City has Trash; Dumping of Residents; Schools &
established accounts with Solid Waste; Sediment Youth Organizations;
social media services such as Runoff from Developers &
Facebook where information Construction; Construction Site
can be shared with the public Fertilizers; Charity Owners; Contractors
and targeted groups Carwashes;
StormWater brochures and Yard Waste; Litter & City of Sikeston 2022-2027
factsheets- The City has Trash; Dumping of Residents; Schools &
published brochures that deal Solid Waste; Sediment Youth Organizations;
with StormWater pollution. Runoff from Developers &
The pamphlets can be mailed Construction; Construction Site
with citizens utility bills, Fertilizers Owners; Contractors
distributed with land
disturbance permits, and are
made available at different
City facilities.
Informative Sign Making Yard Waste; Litter & City of Sikeston 2022-2027
Capabilities- The City`s Street Trash; Dumping of Residents; Schools &
Department has the Solid Waste; Sediment Youth Organizations;
capability to create signage Runoff from Developers &
to place around the City to Construction Construction Site
inform the public on issues of Owners; Contractors
Storm Water Management
4.1.E The City will create opportunities and support activities that are coordinated by citizen
groups, for residents and others to become involved with the SWMP. These opportunities and
activities will make every effort to have a positive impact on storm water runoff. They are as
follows:
8BMPs Measurable Goals Tracking & Adaptive
Management
City of Sikeston`s Adopt-A- Many miles of roadway have The number of volunteers at
Road Program- Sikeston been adopted by citizen these activities and the
offers and encourages groups, school clubs, youth quantity of refuse collected
groups to participate in the organizations, social clubs, can provide quantitative
City`s Adopt-A-Road and church groups. There is numbers to judge the
program a portion of adopted effectiveness of the BMP
roadways that have parallel
ditches that benefits from
these organized cleanup
events
City of Sikeston’s Once per year, residents The number of citizens using
Community Clean Up Event- have the opportunity to this service and descriptions
Sikeston offers an bring trash and bulky items of refuge is recorded at each
opportunity for residents to to the City`s Yard Waste event. These records
dispose of bulky items Disposal Site to be properly provide quantitative
disposed of. It is believed numbers and results which
this program helps keep our helps judge the
City and its roadways and effectiveness of this BMP
ditches clean
The City of Sikeston`s It’s believed this will help The number of citizens using
Compost Program- Sikeston eliminate polluters from this service is recorded at
residents are given access illegally dumping compost each event. These records
twice per month to its City material and tires in area provide quantitative
Yard Waste Disposal Site to ditches and waterways numbers and results which
dispose of leaves, grass, helps judge the
compost, limbs, and tires effectiveness of this BMP
The City of Sikeston`s Leaf Residents and contractors The number of citizens using
Collection Program- The City are allowed access on a daily this service is recorded at
promotes clean gutters, basis to the City`s Yard each event. These records
roadside ditches and drains Waste Disposal Site to provide quantitative
by offering its citizens with a dispose of leaves in the fall numbers and results which
free leaf collection program helps judge the
effectiveness of this BMP
4.1.F The City will make every effort to support each BMP listed in 4.1.E. Support given to the
residents of Sikeston and coordinating groups will be as follows:
• Assist with planning the event or activity
• Contribute supplies, materials, tools, and equipment
9• Make a space available for projects, meetings, and events
• Provide assistance from MS4 personal
• Provide assistance from with recruiting volunteers
• Advertise for the event
• Supply disposal services
• Arrange land access
• Financial support
• In-kind donations
4.1.G Once per year in preparation for the City`s annual MS4 Storm Water Management
Program report to the Department, the City will use adaptive management to review its Public
Education and Outreach Program. The Public Education and Outreach Programs BMPs and
implementation programs will be updated as necessary within the requirements of the permit.
4.2 Public Participation
4.2.A The City will develop and implement a comprehensive public participation program that
provides opportunities for public participation in the development and oversite of the City`s
Storm Water Program. The program will provide opportunities for participation in the permit
renewal and comply with state and local requirements for public notice. Additionally, the public
will be encouraged to participate in the developing and implementing of the City`s Storm Water
Management Program.
4.2.B On February 3, 2021, a copy of the state’s draft for coverage under the Comprehensive
General Permit for Phase II MS4`s was posted on the city`s webpage for public review and a 30
day comment period along with a summary of the city`s SWMP. The city also began an
informational campaign on its social media sites concerning the new permit as well as our
SWMP. Multiple Facebook articles were created for the campaign as well as a segment on KFVS
news. Although public comment was encouraged during this campaign there was no comments
or questions presented to the City.
4.2.C On March 16, 2021, a Storm Water Advisory Board meeting was held to allow public
comment on the states permit as well as the city`s SWMP. As required by City law, a public
notice was advertised on the City`s web site, social media account, and the local newspaper
concerning the Storm Water Advisory Board meeting. The notice of the meeting included the
date, time, and location. The meeting was held at the City`s Administrative Building located
within the MS4.
4.2.D The City has made available publicly several methods to accept public inquiries and
concerns about storm water and storm water related topics. These methods are as follows:
• The City has established a hotline for storm water pollution reporting. Citizens may now
call a dedicated phone number that will put them in contact with appropriate
personnel. Examples of concerns addressed include illegal dumping, storm sewer
blockages, construction site issues, and erosion. The storm water hotline is advertised
on the City`s website and social media services. The hotline also has a recording option
for citizens to leave pertinent information to the storm water issue.
10• The City has established accounts with social media services such as Facebook. Storm
water issues can be reported on these services. These services can be a resourceful tool
to take concerns across all MCMs. Citizens are informed instantly on storm water
topics, and the service provides a feedback tool to the city.
4.2.E The City has an established storm water advisory board (SWAB). This board meets
regularly to discuss storm water related issues such as the permit application, the City`s SWMP,
storm water related ordinances, and other storm water related issues. To date the board is
made up of City personal from various departments, members of the local utilities company,
and a local engineer. It is the hope of the City to attract more citizen representees to serve on
the board in the future.
4.2.F The City of Sikeston currently has a City Manager form of government, with an elected
governing City Council-Mayor. A representative of the MS4 will once per year provide an update
to the City Council and Mayor on the status and compliancy of the City`s SWMP. On March 29,
2021, the City Council and Mayor was counseled on the State’s new permit as well as the city`s
SWMP.
4.2.G The City`s Public Participation Program has been evaluated to ensure compliance with
the permit and has been promoted to the community. Tracking mechanisms were used for
tracking attendance, inquiries, and concerns per the requirements of the permit.
4.2.H Once per year in preparation for the City`s annual MS4 Storm Water Management
Program report to the Department, the City will use adaptive management to review its Public
Participation Program. This will be used to review how best to reach the public, the
effectiveness of the mechanisms, the effectiveness of reaching the public, and if the City and
public are working together for water quality.
4.3 Illicit Discharge Detection and Elimination
4.3.A The City will implement and enforce a program to detect and eliminate illicit discharges
as defined in 10 CSR 20-6.200 at 40 CFR 122.26 (b)(2) into its MS4.
4.3.B In 2011, the City partnered with Midland Integrity GIS to develop a detailed map of the
City`s storm water sewer system. The City of Sikeston retains full editing rights to this map and is
updated on a regular basis when required. The map is stored electronically with Midland
Integrity GIS and can be accessed at any time by City personal. MS4 features which can be
viewed on the map are as follows:
• Detailed locations of all MS4 outfalls that are accurately located
• The names and locations of all receiving waters of the State that receives discharges
from the MS4 outfalls
• The boundary of the regulated MS4
• The map is readily available to City staff in the field via electronic devices
• The map and any accompanying information will be made available to the Department
upon request
4.3.C The City will record the sources of information used for the map. They are as follows:
11• A naming of all outfalls
• Dates that the outfalls were verified and last surveyed in the field
• The date for new outfalls that were added to the storm system
4.3.D The City will effectively prohibit non-storm water discharges into the City`s storm sewer
system and implement appropriate enforcement procedures and actions. The prohibition is
enforced through an ordinance, to the extent allowable under state and local law. Non-storm
water discharges are also covered in the City`s illicit storm water discharge control regulations.
The City`s Ordinance #6016, which deals with illicit discharges and connections can be located
in this SWMP, Appendix D.
4.3.E The City`s dry weather screening strategy.
1. The City`s MS4 designee will conduct outfall field assessments. The screening
will be conducted during dry weather (a minimum of 72 hours after the last
precipitation event) to check for the presence of a discharge. A minimum of
60% of all outfalls will be inspected during the permit cycle and priority areas
will be screened each year.
2. The screenings will include a checklist that will note the following general
observations and physical characteristics. They are as follows:
• Date and time
• Weather conditions and temperatures
• Color of discharge
• Estimate of flow rate
• Odor
• Surface scum, algae bloom, floatables or oil sheen present
• Deposits or stains
• Turbidity
• Steam impact including vegetation, fish, and wildlife
• Length of impacted stream.
• Notes of an obvious source of flow
4.3.F The City will maintain diagnostic monitoring procedures to detect and investigate
unknown non-storm water flows as part of its dry weather screening program. When unknown
non-storm water flows are detected and investigated, the City will conduct the following
procedures. They are as follows:
• A description of the dry weather screening strategy which detected the non-storm
water discharge to the City`s MS4 will be attached to the original dry weather screening
checklist.
• A description of how the discharge is evaluated and the possible parameters tested will
be listed with the original dry weather screening checklist.
• If further analyze is needed a sample will be collected and analyzed by a contracted lab.
A copy of the results will be attached to the original dry weather checklist.
4.3.G The City will maintain procedures for tracing the source of an illicit discharge. If initial
screening indicates that a dry weather discharge contains pollutants, or if an illicit discharge is
suspected from another reporting method, the source will be traced using a variety of
investigative tools. They are as follows but not limited to:
12• Visually following the flow
• Storm sewer system sampling
• Closed circuit camara
• Smoke or dye tracing
• Tunnel entry
4.3.H The City will maintain procedures for removing the source of the discharge. After
locating the source, the pollutant and source must be removed. The exact procedure will
depend on the source and the circumstances. These procedures can be located in the City`s
Ordinance #6016, which deals with illicit discharges and connections. A copy explaining the
procedures used for removing the source of the illicit discharge, including names and contacts
for environmental cleaning companies, will be attached to the original dry weather screening
checklist.
4.3.I In order to prevent further illicit discharges, the City will identify priority areas.
Examples of areas suspected of illicit discharges, but not limited to are as follows:
• Areas with evidence of ongoing illicit discharges
• Areas with a history of illicit discharges
• Certain land use influencing storm water of potential pollutant sources
• Areas of higher population density
• Areas with known litter or dumping issues
• Areas with large or increased number of citizen complaints
• Industrial areas
The City will annually evaluate this priority list and/or map and update as necessary to reflect
changing priorities.
4.3.J The City will maintain written procedures for implementing the Illicit Discharge
Detection and Elimination program described within this section to ensure program continuity
and consistency. This includes a description of its dry weather screening strategies,
implantations to detect and address non-storm water discharges, and a description of how the
discharge is evaluated and the possible parameters that are tested.
4.3.K The City will conduct investigations in response to field screening discoveries, spills, or in
response to complaints from the public or municipal staff. Responses will meet the following
investigation timelines:
1. Immediately respond to all illicit discharges, including spills, which are determined to
constitute a threat to human health, welfare, or environment.
2. Investigate (or refer to the City Managers appointed designee to act) within 5 business
days, on average, any complaints, reports, or monitoring information that indicates a
potential illicit discharge which does not constitute a threat to human health, welfare,
or environment.
At this time, the City does not have an adjacent MS4 operator in which to communicate with
concerning illicit discharges and connections.
4.3.L The City will have procedures for appropriate enforcement, which includes fines, the
ability to collect cleanup and abatement costs, and actions to ensure that the City`s illicit
13discharge ordinance is being implemented. The City`s Ordinance #6016, which deals with illicit
discharges and connections can be located in this SWMP, Appendix D.
4.3.M The City will maintain a database to track dry weather field screenings, spills, incidents,
and investigations. The City will record annually at a minimum:
1. Number of outfalls screened
2. Number of complaints received and investigated
3. Number of illicit discharges removed
4. Documented dates the illicit discharge was observed and investigated
5. Summaries of procedures used to investigate the illicit discharge
6. Documented outcomes of investigations including sample results and findings
7. Any follow up of the investigation including cleanups, site visits, and enforcement
actions
8. Documented date the investigation or issue was closed.
The database will be maintained and stored with the office of the City Managers designee.
4.3.N The City will continually inform the public and businesses on the hazards associated with
illegal discharges and improper disposal of waste through its Public Education and Outreach
Program. City resources include social media, electronic mail, door hangers, and pamphlets.
And City employees are continually trained to identify and detect illicit pollution and
connections through the City`s Pollution Prevention and Good Housekeeping for Municipal
Operations Program.
4.3.O The City will maintain and improve upon its training program for all municipal staff,
who, as part of their normal job responsibilities, may come into contact with or otherwise
observe an illicit discharge or illicit connection to the storm sewer system. Training for staff
who may handle materials which may become an illicit discharge will include, but not be
limited to the following:
1. Training for new staff members within a year of employment
2. Fleet maintenance staff
3. Staff at facilities with fuel, chemicals, washing of vehicles and equipment
4. Road maintenance staff
5. Parks staff who encounter spills, equipment washing, fueling and chemicals
training dates, topics, and the attendance will be recorded and stored with the City Managers
designee. Reviews of the training effectiveness will be considered after municipal site
inspections or after an incident has occurred. The City will then consider if the training is
enough or is ineffective.
4.3.P Once per year in preparation for the City`s annual MS4 Storm Water Management
Program report to the Department, the City will use adaptive management to review its Illicit
Discharge Detection and Elimination Program. Data collected through the City`s dry weather
screening process and illicit discharge detection processes will be used to continuously evaluate
the effectiveness of each BMP and the implementation of each BMP. Any additional BMPs will
be acknowledged in the Storm Water report.
144.4 Construction Site Storm Water Runoff Control
4.4.A The City will continue to implement and enforce a program to reduce pollutants in any
storm water runoff to their MS4 due to construction activities that result in land disturbance of
greater than or equal to one acre. Reduction of storm water discharges from construction
activity disturbing less than one acre will be included in the program if that construction activity
is part of a larger development or sale that would disturb one acre or more.
4.4.B The City currently has an ordinance (Ordinance #5816) that requires construction site
runoff control BMPs at construction/ land disturbances sites greater than or equal to one acre.
The City`s ordinance must be updated to include construction site runoff controls for
construction/ land disturbances less than one acre but when they are part of a larger common
plan or development that would disturb one acre of more. The City`s ordinance includes
sanctions that are designed to ensure compliance, to the extent allowable under State, or local
law. A copy of the City`s ordinance (Ordinance #5816) can be found in this SWMP Appendix C.
4.4.C The City will review pre-construction plans. These reviews will consider the following:
1. Evaluate threats to water quality which include but are not limited to:
• Soil erosion
• Site slope
• Project size and type
• Sensitivity of receiving waterbodies
• Discharge flow type (pipe or sheet flow)
• Location of discharge point in revelation to receiving water
• Proximity to the site to receiving waterbodies
• Other factors relevant to the MS4 service area
2. A checklist will be used to ensure consistency and completeness.
3. Requirements for construction site operators to select, install, implement, and maintain
appropriate storm water controls measures. This includes temporary BMPs throughout
the life of the land disturbance, and permanent BMPs which remain on site as required
by local codes and ordinances.
4. Consideration of ways to minimize disturbed areas through actions such as, phased
construction requirements, temporary seeding or sodding, or erosion mats to exposed
areas.
5. Requirements for construction site operators to control construction-site waste that
may cause adverse impacts to water quality. (Trash, concrete wash-out, etc.)
4.4.D The City will continue to apply its ordinance (Ordinance #5816) to establish authority for
site inspections and for the enforcement of control measures, to the extent allowable under
State and local law. The City will continue to implement procedures detailed in its ordinance for
inspecting construction/ land disturbance projects. The City`s procedures includes, but are not
limited to the following:
• Identify priority sites for inspection based on nature of the construction activity,
topography, disturbed area, and the characteristics of soil and sensitivity of, or
proximity to, receiving water.
15• Construction site inspections will include assessment of compliance with the MS4
Operators construction site storm water runoff control ordinance or regulatory
mechanism, and other applicable ordinances.
• The inspections will evaluate any structure that functions to prevent pollution of storm
water or to remove pollutants from storm water and use enforcement policies to
require BMPs are implemented and effective.
• Final inspection, upon completion of the land disturbance and prior to final approval of
construction project. Ensure all disturbed areas have been stabilized, that all temporary
erosion and sediment control measure are removed.
• The inspections conducted by the City will be documented with a checklist. The checklist
will include structural BMPs and check on the self-inspection which are conducted by
the construction site operator.
• A copy of the checklist used by City inspectors can be found in this SWMP, Appendix J.
4.4.E The City`s construction site runoff control program includes an established, escalating
enforcement ordinance that clearly describes the action to be taken for violators. The program
has written procedures to ensure compliance with the City`s construction site runoff control
ordinance. The ordinance includes sanctions and enforcement mechanisms to ensure
compliance. They are as follows:
• The construction site owner is required by ordinance to adhere strictly to the storm
water management plan. Any changes must be approved by the City Managers
designee.
• The City Managers designee may issue written notice to the construction site owner
specifying the nature and location of the alleged non-compliance, with the remedial
steps necessary to bring the project into compliance.
• The City Managers designee may issue a stop work order directing the construction site
owner to cease and desist all or any portion of the work which violates the provisions of
the ordinance.
• The ordinance allows any person, whether owner, lessee, principal, agent, employer or
otherwise, who violates or causes to be violated any provision of the ordinance to be
punished by a fine not to exceed $500.00, or to be imprisoned for a period not to
exceed 60 days.
A copy of the City`s ordinance (Ordinance #5816) can be found in this SWMP Appendix C.
4.4.F The City will require the construction site operator to conduct inspections at a
minimum:
• Every fourteen days, when construction is active
• Within 72 hours of any storm event, and within 48 hours after any storm event
equal to or greater than a 2-year, 24 hour storm has ceased.
The City will verify that these inspections are being conducted by the construction site operator
during MS4 City inspections. A copy of the construction site operator’s checklist can be found in
this SWMP Appendix J.
4.4.G The City will maintain an inventory of active public and private land disturbance sites, as
defined in Section 4.4 of the permit. The inventory will be maintained as follows:
• The inventory will be maintained and updated through the City`s Code Enforcement
Department by the City Managers designee.
16• Relevant contact information for each project will be maintained in the inventory
including but not limited to tracking number, name, address, phone, etc.
• Size of the project/ area of disturbance.
• If the site is a priority site/ how high of priority.
4.4.H The City will track their oversite inspections by retaining copies of inspection checklists.
The City will make these inventories available to the Department upon request. The tracking will
be maintained and contain at a minimum:
• Inspection dates and times
• Inspector’s name
• Inspection findings
• Follow up actions and dates, including corrective actions and enforcement actions.
A copy of the inspector’s checklist can be found in this SWMP Appendix J.
4.4.I The City`s Storm Water Management Program including its ordinances, permitting
procedures, review procedures, inspection procedures and enforcement procedures will be
reviewed to ensure compliance with the permit. Any changes necessary to be in compliance
with the permit will be completed within one year of the permit issuance.
The inventory of active sites will be updated as new projects are reviewed and projects are
completed within one year of the permit issuance.
4.4.J The SWMP includes mechanisms for the City to receive and consider information
submitted by the public about land disturbance sites. They include:
• The City uses social media often to educate the public on land disturbance issues which
provides a tool to receive questions and comments about construction site pollutants.
• Currently the City has a local engineer sitting on its Storm Water Advisory Board who
can voice the concerns about land disturbance.
4.4.K The City will provide, or support access to, construction site runoff control training for
MS4 inspectors and plan reviewers at minimum once during the permit cycle. Training dates,
topics, and the attendance will be recorded and stored with the City Managers designee.
Reviews of the training effectiveness will be considered during and after construction site
compliance inspections. The City will then consider if the training is enough or is ineffective.
4.4.L The City does not at this time provide written procedures outlining local inspections and
enforcement procedures to their inspectors. However, the inspectors do rely upon the
construction site runoff control inspection checklist and the City`s ordinances to ensure
compliance and consistency with construction site runoff controls. The City will within a year of
the permit issuance provide its inspectors a more detailed written procedure for outlining local
inspections and enforcement procedures.
4.4.M Once per year in preparation for the City`s annual MS4 Storm Water Management
Program report to the Department, the City will use adaptive management to review its
Construction Site Storm Water Runoff Control Program and evaluate the ordinances, review
procedures, inspection procedures, enforcement procedures, receipt of public information
procedures, and effectiveness of training procedures to ensure compliance with the
17requirements of the permit and determine if changes are needed. The annual review may
include but is not limited to:
• Evaluating the most common violations, how the violations are handled, and how many
are escalated
• If the education program can assist in reducing violations
• Determining if the site plans match the sites when violations arise or if additional items
need to be evaluated at plan review
• Assessing public complaints being addressed in a timely manner
• Evaluating if the inspections are thorough and consistent across different sites
Any additional programmatic BMPs and when they were added to the Storm Water
Management Program will be reported to the Department as part of the City`s annual report.
4.5 Post Construction Strom Water Management in New Development and Redevelopment
4.5.A The City will continue to develop, implement, and enforce a program to address the
quality of long-term storm water runoff from new development and redevelopment projects
that disturb equal to or greater than one acre, including projects less than one acre that are part
of a larger common plan of development or sale that would disturb one acre or more and that
discharge into the regulated MS4. The City’s program will ensure that controls are in place that
have been designed and implemented to prevent or minimize water quality controls.
4.5.B The City maintains and utilizes an ordinance to address post-construction runoff from
development and redevelopment projects to the extent allowable under State and local law for
sites equal to or greater than one acre. The City`s ordinance must be updated to address post-
construction runoff from development and redevelopment projects less than one acre but when
they are part of a larger common plan or development that would disturb one acre of more. A
copy of the City`s ordinance (Ordinance #5816) can be found in this SWMP Appendix C.
4.5.C The City will continue to and develop upon a strategy to minimize water quality impacts.
This includes a combination of structural and/or non-structural controls (BMPs) appropriate for
the City`s community. Structural and/or non-structural controls (BMPs) can be found in the
City`s ordinances which include the following:
• Structural controls include but are not limited to drain-dry earthen basins, permanent
ponds, underground piping and basins, and parking lots to a maximum depth of 12
inches.
• The ordinance includes design criteria of numerical and technical performance
standards to control post-construction discharges. The hydrologic designs and summary
runoff complications must be prepared by a professional engineer registered in the
State of Missouri and must be made using the Rational Method (with “C” factors based
upon percent of impervious site area from the tabulation in this paragraph), Soil
Conservation Service Technical Release 55 (TR-55) or other technical methods
acceptable to the City.
• The ordinance includes standards to address surface runoff for a two-year frequency
storm, historical rates and volumes of storm water runoff, and runoff computations
based on critical situations.
18The City`s ordinance (Ordinance #5816) at this time does not include non-structural controls
(BMPs). The City will within a year of the permit issuance update its ordinance to include non-
structural controls to include but are not limited to:
• Policies that provide requirements to direct development to identified areas
• Protection of sensitive areas
• Maintain and/or increase open space
• Maintain requirements for buffer zones along water bodies
• Require minimizing impervious surfaces
• Require minimizing disturbance of soils and vegetation
• Programs which incentivize the use of green infrastructure
• Requirements for minimization of directly connected impervious areas
• Tree preservation ordinances
4.5.D At this time the City does review pre-construction plans to assess site characteristics at
the beginning of the construction site design phase to ensure adequate planning for storm
water program compliance. The City relies upon the engineers listed within the construction
plans for compliance with structural and non-structural controls chosen and/or hires a third
party engineer/hydrologist to review construction site plans. The City will within a year of the
permit issuance update its plan review processes to include a checklist for ensuring correct
structural and non-structural controls. Non-structural BMPs will be evaluated first, such as
comprehensive plans, zoning ordinances, buffer strips and/or preservation of open spaces.
4.5.E The City will continue to rely upon its ordinance (Ordinance #5816) to ensure adequate
long-term maintenance and operations of the selected BMPs including, as appropriate,
agreements between the City and other parties such as post-development landowners or
regional authorities. The ordinance ensures long term M&O through the following:
• Responsibilities for post-construction M&O between private landowners and the
developer must assure perpetual maintenance of the BMPs through the adoption of
maintenance agreements and covenants to be noted on and recorded with the
subdivision plat and referenced on the deeds for any such BMPs.
• M&O responsibilities for BMPs must remain with the legal owner of the site. Typical
M&O activities include period inspections for defects affecting performance, removal of
accumulated silt and debris, and mowing and turf maintenance.
• If the owner of the post-construction BMPs fails to provide adequate operation and
maintenance and the facilities become inoperative or ineffective or become a nuisance,
the City may perform remedial work at the developers or owner’s expense.
4.5.F The City will inspect, or require inspection of, each water quality structural and non-
structural water post-construction BMP according to the following minimum:
• A minimum of one inspection will be conducted during the construction, and one
inspection before the site is finalized, to verify water quality facilities are built as
designed and any applicable boundaries or practices for non-structural BMPs are being
observed.
• A minimum of once in the first three years after the instillation by the City.
• Annually by the owner or operator of the post-construction BMP, or by the City. If
completed by the BMP owner or operator, this inspection report shall be submitted to
the City for evaluation and review.
19• The City will inspect a minimum of 60% of all water quality post-construction BMPs
within the five year permit cycle. This must include installations with ongoing or open
enforcement issues.
4.5.G At this time the City`s ordinance (Ordinance #5816) addresses failures to provide
adequate operations and maintenance and violations and penalties for post-construction
controls. They are as follows:
• The City may perform remedial work at the owner’s expense to correct a failing BMP.
• Any person, whether owner, lessee, principal, agent, employer or otherwise, who
violates or causes to be violated any provision of this Article or permits any such
violation or fails to comply with any of the requirements shall be punished by a fine not
to exceed five hundred dollars ($500.00), or by imprisonment for a period not to exceed
sixty (60) days, or by both such fine and imprisonment. Each day upon which such
violation shall continue shall constitute a separate offense hereunder.
Within one year of the issuance of the permit, the City will update its ordinances to include
enforcement responses to violations such as, but not limited to:
• The effect the violation has on the receiving water
• Compliance history of the post-construction BMP owner or operator
• Cooperation of the owner or operator with compliance efforts
4.5.H Within one year of issuance of the permit, the City will update its ordinances to ensure
effective enforcement actions are taken in a timely order against structural and non-structural
violations. The ordinance will reflect that enforcement actions be taken within 30 days of the
violation.
However, the City`s ordinance (Ordinance #5816) does maintain a minimum of two possible
sanctions. They are as follows:
• Written warnings or notice of violations
• Property liens
• Fines
4.5.I Within one year of the issuance of the permit, the City will develop and implement an
inventory tracking the water quality post-construction BMPs. The inventory will be maintained
by the City Managers designee and include at a minimum the following:
• Relevant contact information for each project (e.g., project number, name, address,
phone, etc.)
• The type of post-construction BMP
• Applicable maintenance and operations documents
• The date the City approved the construction project
• For City owned water quality facilities, the tracking must also include any maintenance,
such as sediment clean-out or replanting
4.5.J The City will also track the post-construction BMP inspections. This will be done by
retaining copies of records such as inspection checklists and email correspondence. The tracking
of the post construction BMP inspections will be stored and maintained by the City Managers
designee. The tracking will maintain at a minimum the following:
• Inspection dates and times
• Inspector’s name
20• Inspector’s findings
• Follow up actions and dates, including corrective actions and enforcement actions
4.5.K The City will continue to evaluate its ordinances, permitting procedures, review
procedures, inspection procedures, inspection procedures and enforcement procedures to
ensure compliance with the permit requirements and determine if more changes are needed.
An inventory of water quality facilities will be developed and tracked as new facilities are added
and projects are completed. Changes necessary to be in compliance with the permit will be
completed within the first year of permit issuance.
4.5.L The City will provide appropriate training for the City inspectors at minimum once every
permit cycle, including Green Infrastructure training or specific operation of proprietary post-
construction BMPs. The City will also provide overall training to explain the function of both
structural and non-structural post-construction water quality BMPs. Training dates, topics, the
training provider, and the attendance will be recorded and maintained with the City Managers
designee.
4.5.M Once per year in preparation for the City`s annual MS4 Storm Water Management
Program report to the Department, the City will use adaptive management to review its Post-
Construction Site Storm Water Management in New Development and Redevelopment
Program and evaluate effectiveness of the overall program and determine if additional changes
are needed. The annual review may include but is not limited to the following:
• Reviewing the number and types of developments
• How many BMPs were installed/inspected
• The amount of watershed area being treated
• The types of violations found and how frequently
• Evaluating how education could improve the effectiveness of the program
Any additional programmatic BMPs will be acknowledged in the Storm Water Management
Program Report.
4.6 Pollution Prevention/ Good Housekeeping for Municipal Operations
4.6.A The City will develop and implement on a maintenance and operation program that
includes a training component and has the ultimate goal of preventing or reducing pollutant
runoff from municipal operations.
4.6.B The City will maintain and utilize an employee training program for MS4 operations
staff. The training will be given at minimum annually to all MS4 staff who work with material
handling, at MS4 owned or operated vehicle/ equipment maintenance areas, storage yards, and
material storage facilities. This will be broken up into staff units on applicable topics. Training
dates, topics, the training provider, and the attendance will be recorded and maintained with
the City Managers designee.
4.6.C The training will be used to prevent and reduce storm water pollution and will cover a
minimum of the following topics/ activities:
21Topic Years Covered in Departments Trained Number of
Training Staff Trained
Vehicle and
equipment washing
Fluid disposal and
spills
Fleet, equipment,
and building
maintenance
Park and open
space maintenance
procedures
(Including fertilizer,
herbicide, pesticide
application)
New construction,
road maintenance,
and land
disturbances
Storm water
system
maintenance
MS4 operated salt
and de-icing
operations
Fueling
Solid waste
disposal
Street sweeper
operations
Illicit discharges
Other
4.6.D The City will:
• Maintain, as part of its training program, materials to use in the training program, such
as those available from the Environmental Protection Agency, the State, other
organizations, and/or other MS4s.
22• Continually train City employees using a Municipal Operations manual on Pollution
Prevention and Good Housekeeping. Each maintenance and operation program includes
a description of what pollutant employees can find at each city owned facility and has
been developed to create controls for reducing and eliminating discharges of pollutants
from City construction projects, street and right of way projects, city storm sewers,
parks, and landscaping projects. The City also takes advantage to train employees
through web-based conferences, area storm water conferences, and books and
publications.
• The City`s Municipal Operations manual is maintained separately and offers specific
training when it is appropriate. Topics included are but not limited to leaf disposal in the
fall and proper salt clean-up and usage in the winter.
4.6.E The city maintains a list of all municipal operations and facilities that are impacted by
the maintenance and operation program. Properties of the City that are impacted by this
maintenance and operations program include administration buildings, public safety buildings,
multiple parks, streets and public right of ways, public works buildings, an animal shelter,
Sikeston`s municipal airport, and a fuel site. Data on each of the municipal operations and
facilities listed in the M&O manual includes:
• Addresses
• GPS coordinates for municipal operations and facilities
• A detailed map for each location
• Facility manager
• Potential pollutants for each municipal operation and/or facility listed
A copy of the Municipal Operations manual with a list of all municipal operations and facilities
can be located with City`s Managers MS4 designee.
4.6.F The City at this time does not own or operate an industrial facility that is subject to
NPDES permits for discharges of storm water associated with industrial activity.
Sikeston`s Board of Municipal Utilities owns and operates two wastewater treatment plants that
discharges into Sikeston`s MS4 and operates independently of the City of Sikeston. These two
wastewater plants operate under Missouri Operating Permits #0035009 and #0120863.
Sikeston`s Board of Municipal Utilities owns and operates a coal fired power plant that
discharges into Sikeston`s MS4 and operates independently of the City of Sikeston. This power
station operates on Missouri Operating Permit #0095575.
4.6.G The City will continue to develop and maintain controls for reducing and/or eliminating
the discharge of floatables and pollutants from municipal facilities. These controls will include at
a minimum:
• A list of potential pollutant sources at each facility, such as materials used and stored for
on site.
23• A minimum of annual inspections of all municipally owned or operated facilities for
storm water issues. A checklist of inspections and follow ups will be filed and
maintained by the City Managers designee.
• Use of structural controls/BMPs to reduce or prevent pollutants from entering waters of
the State where needed. A map with descriptions of these BMPs will be maintained for
each facility.
• All paints, solvents, petroleum products, and petroleum waste products (except fuels)
under the control of the City will be stored so these materials are not exposed to storm
water.
• Sufficient practices of spill prevention, control, and/or management will be provided to
prevent any spills of these pollutants from entering waters of the State. Spill kits will be
provided at facilities where liquid product is stored, and any containment system used
to implement this requirement will be constructed of materials compatible with the
substances contained and will prevent the contamination of groundwater.
• Rock salt/brine or other deicer products will be tracked.
• Municipal salt storage areas will be maintained after use included sweeping and/or
shoveling spillage in loading area and unloading salt hoppers or keeping under cover
when not in use.
4.6.H The City continues with its procedures for proper disposal of waste removed from MS4
structures and areas of jurisdiction. The City utilizes its Yard Waste Disposal Site to properly
dispose of sweeper collected debris, dredged materials, compost debris and materials collected
with its storm water pipe maintenance vacuum truck. The City`s Yard Waste Disposal Site offers
a unique design in that it contains all materials disposed of and prevents those materials from
reentering the storm water system.
4.6.I The City will maintain and utilize the following procedures, at minimum, for the washing
of all municipal vehicles and equipment:
• The use of any soap or detergent will only be where there is connection to sanitary
sewer or equivalent treatment.
• Any wash or rinse water that contains pollutants such as salt, oils, grease, sediment,
grass clippings, lawn chemicals, or pesticides will not be discharged to the waters of the
State or MS4 system without appropriate treatment.
• Any washing or rinsing activities will be conducted in an appropriate area so the water is
treated. This area will be marked on the map of the facility.
Currently all City vehicles are washed in covered facilities with sanitary sewer connections.
There is also a dedicated area for rinsing heavily soiled equipment such as the City`s street
sweeper, bush hog tractors, backhoes, etc. This area is protected with control devices and
BMPs.
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