In general, illicit discharges include any discharge into a storm drain system that is not entirely composed of stormwater. The exceptions include water from firefighting activities and discharges from facilities already under an NPDES permit. Illicit discharges are a problem because, unlike wastewater, which flows to a treatment plant, stormwater generally flows to waterways without any additional treatment. Illicit discharges often contain pathogens, nutrients, surfactants, and various toxic pollutants.
Phase II MS4s are required to develop a program to detect and eliminate these illicit discharges. This primarily includes developing:
· a storm sewer system map,
· an ordinance prohibiting illicit discharges,
· a plan to detect and address these illicit discharges, and
· an education program on the hazards associated with illicit discharges.
An effective illicit discharge program needs to be both reactive and proactive. The program is reactive in addressing spills and other illicit discharges to the storm drain system that are found. The program must also be proactive in preventing and eliminating illicit discharges through education, training, and enforcement.
MINIMUM CONTROL MEASURE #3
ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE)
Berks County, Pennsylvania
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