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Illicit Discharge Detection and Elimination

According to the MPCA's Guidance Manual For Small Municipal Separate Storm Sewer Systems:

Federal regulations define an illicit discharge as "...any discharge to a MS4 that is not composed entirely of storm water..." with some exceptions. These exceptions include discharges from NPDES-permitted industrial sources and fire-fighting activities. Illicit discharges are considered "illicit" because MS4s are not designed to accept, process, or discharge such non-storm water wastes. It is important to note that illicit does not mean illegal.

Illicit discharges enter the system through either direct connections (i.e. wastewater piping either mistakenly or deliberately connected to the storm drains) or indirect connections (i.e. infiltration into the MS4 from cracked sanitary systems, spills collected by drain outlets, or paint or used oil dumped directly into a drain). The result is untreated discharges that contribute high levels of pollutants including heavy metals, toxics, oil and grease, solvents, nutrients, viruses, and bacteria to receiving waterbodies. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife, and human health.

According to EPA definition in 40 CFR Part 122.26, non-storm discharges can include ‘Water line flushing, landscape irrigation, diverted stream flows, rising groundwaters, uncontaminated ground water infiltration, and uncontaminated potable water sources, foundation drains, air conditioning condensation, irrigation water, springs, water from crawl space pumps, footing drains, lawn watering, individual residence car washing, flows from riparian habitats and wetlands, dechlorinated swimming pool discharges, and street wash water.’ The EPA does not consider these discharges as "illicit" unless they are identified as significant contributors of pollutants by the individual MS4. UMD has not identified any of these discharges to be illicit in and of themselves and therefore none are specifically part of the SWPPP.

For additional Information see Minimum Control Measure 3: Illicit Discharge Detection and Elimination in UMD's Storm Water Pollution Prevention Program.

Best Management Practices: New practices will be added as they are completed

UMD 3a-1 Storm Sewer System Map

UMD 3b-1 Regulatory Control Program

UMD 3c-1 Illicit Discharge Detection and Elimination Plan

UMD 3d-1 Public and Employee Illicit Discharge Information Program

UMD 3e-1 Identification of Non Stormwater Discharges and Flows


Illicit Discharge Detection and Elimination Best Management Practice Summaries

UMD 3a-1 Storm Sewer System Map

UMD has detailed storm sewer maps for each campus property, available from Facilities Management. These maps meet the goal of identifying all storm sewer pipes greater than 24 inches and include most pipes much smaller. These maps also identify the receiving waters, interconnected City of Duluth lines and wetland areas.

UMD 3b-1 Regulatory Control Program

As a land grant institution with its own building code official, the University has the legal authority to operate its storm water system in a manner necessary to comply with the applicable regulations. The University therefore has the power to formulate administrative procedures for the operation, management, and maintenance of the storm water system, as well as the power to control illicit discharges, spills and dumping.

UMD 3c-1 Illicit Discharge Detection and Elimination Plan

Illicit discharges outside of construction activities are believed to be rare. There is no reason for our constituents to improperly dispose of waste. Environmental Health and Safety Department has systems in place to dispose of chemicals and other hazardous waste, and garbage service is available at all our buildings. The areas that we could have illicit discharges are from improperly connected plumbing features, ground water contamination and/or uninformed employees or students.

UMD 3d-1 Public and Employee Illicit Discharge Information Program

Provide employees with information on procedures that will stop or prevent illicit discharges to our storm water system.

UMD 3e-1 Identification of Non Stormwater Discharges and Flows

Review storm water systems, drain tile and sumps to identify non storm water discharges.
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Last modified on 10/29/12 01:52 PM
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