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Fact Sheet 2.5 — Illicit Discharge Detection and Elimination Minimum Control Measure Page 2 What Is Required? Recognizing the adverse effects illicit discharges can have on receiving waters. the Phase II Final Rule requires an operator of a regulated small MS4 to develop, implement and enforce an illicit discharge detection and elimination program. This program must include the following: ❑ A storm sewer system map. showing the location of all outfalls and the names and location of all waters of the United States that receive discharges from those outfalls; ❑ Through an ordinance, or other regulatory mechanism, a prohibition (to the extent allowable under State, Tribal. or local law) on non - stormwater discharges into the MS4. and appropriate enforcement procedures and actions: ❑ A plan to detect and address non - stormwater discharges. including illegal dumping, into the MS4; ❑ The education of public employees, businesses, and the general public about the hazards associated with illegal discharges and improper disposal of waste; and ❑ The determination of appropriate best management practices (BMPs) and measurable goals for this minimum control measure. Some program implementation approaches, BMPs (i.e., the program actions /activities), and measurable goals are suggested below. Does This Measure Need to Address All Illicit Discharges? No. The illicit discharge detection and elimination program does not need to address the following categories of non - stormwater discharges or flows unless the operator of the regulated small MS4 identifies them as significant contributors of pollutants to its MS4: ❑ 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; ❑ Dechlorinated swimming pool discharges; and ❑ Street wash water. What Are Some Guidelines for Developing and Implementing This Measure? The objective of the illicit discharge detection and elimination minimum control measure is to have regulated small MS4 operators gain a thorough awareness of their systems. This awareness allows them to determine the types and sources of illicit discharges entering their system; and establish the legal. technical. and educational means needed to eliminate these discharges. Permittees could meet these objectives in a variety of ways depending on their individual needs and abilities, but some general guidance for each requirement is provided below. The Map The storm sewer system map is meant to demonstrate a basic awareness of the intake and discharge areas of the system. It is needed to help determine the extent of discharged dry weather flows, the possible sources of the dry weather flows, and the particular waterbodies these flows may be affecting. An existing map, such as a topographical map, on which the location of major pipes and outfalls can be clearly presented demonstrates such awareness. EPA recommends collecting all existing information on outfall locations (e.g., review city records. drainage maps, storm drain maps), and then conducting field surveys to verify locations. It probably will be necessary to walk (i.e., wade through small receiving waters or use a boat for larger waters) the streambanks and shorelines for visual observation. More than one trip may be needed to locate all outfalls. Legal Prohibition and Enforcement EPA recognizes that some permittees may have limited authority under State, Tribal or local law to establish and enforce an ordinance or other regulatory mechanism prohibiting illicit discharges. In such a case, the permittee is encouraged to obtain the necessary authority, if possible. The Plan The plan to detect and address illicit discharges is the central component of this minimum control measure. The plan is dependant upon several factors, including the permittee's available resources, size of staff and degree and character of its illicit discharges. As guidance only. the four steps of a recommended plan are outlined below: •