IDENTIFYING, TREATING AND PREVENTING IT UNDER THE BOROUGH’S
STORMWATER MANAGEMENT PROGRAM.

• STORMWATER : RAINFALL, SNOW/ICE MELT
• STORMWATER FLOWS DIRECTLY INTO STREAMS AND RIVERS AND CARRIES POLLUTANTS AND
CONTAMINANTS WITH IT
• ONE SPECIFIC CAUSE OF STORM WATER POLLUTION IS ILLICIT DISCHARGES. OUR FOCUS
TODAY IS HOW TO IDENTIFY, CORRECT AND PREVENT THEM.

• THE FEDERAL CLEAN WATER ACT ADDRESSES WATER POLLUTION (AND THEREFORE STORMWATER)
• THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) REGULATES “POINT SOURCE
DISCHARGES” OF STORMWATER TO WATERS OF THE U.S.
• IN 1999, FEDERAL REGULATIONS EXTENDED COVERAGE OF THE NPDES PROGRAM TO MUNICIPAL
SEPARATE STORM SEWER SYSTEMS (MS4’S)
• UNDER THESE REGULATIONS, MILLERSVILLE BOROUGH IS AN MS4 COMMUNITY, AND IS REQUIRED TO
OBTAIN AN NPDES PERMIT FOR THEIR STORMWATER DISCHARGES
• AS PART OF THIS NPDES STORMWATER PROGRAM, THE BOROUGH IS REQUIRED TO DEVELOP A
STORMWATER MANAGEMENT PROGRAM

THE EPA DEFINES AN MS4 AS A CONVEYANCE OR SYSTEM OF CONVEYANCES THAT IS:
• OWNED BY A STATE, CITY, TOWN, VILLAGE, OR OTHER PUBLIC ENTITY THAT DISCHARGES TO
WATERS OF THE U.S.;
• DESIGNED OR USED TO COLLECT OR CONVEY STORMWATER (INCLUDING STORM DRAINS,
PIPES, DITCHES, ETC.);
• NOT A COMBINED SEWER; AND
• NOT PART OF A PUBLICLY OWNED TREATMENT WORKS (SEWAGE TREATMENT PLANT).

THE SIX MINIMUM CONTROL MEASURES (MCMS) REQUIRED UNDER THE STATE’S GENERAL NPDES PERMIT FOR
MS4 COMMUNITIES INCLUDE:
• MCM#1: PUBLIC EDUCATION AND OUTREACH
• MCM#2: PUBLIC INVOLVEMENT/PARTICIPATION
• MCM#3: ILLICIT DISCHARGE DETECTION AND ELIMINATION
• MCM#4: CONSTRUCTION SITE STORMWATER RUNOFF CONTROL
• MCM#5: POST-CONSTRUCTION STORMWATER MANAGEMENT IN NEW AND RE-DEVELOPMENT ACTIVITIES
• MCM#6: POLLUTION PREVENTION/GOOD HOUSEKEEPING
EACH MCM HAS A NUMBER OF REQUIRED BEST MANAGEMENT PRACTICES (BMPS)

AN ILLICIT DISCHARGE IS DEFINED AS:
“…ANY DISCHARGE TO THE MUNICIPAL SEPARATE STORM SEWER SYSTEM THAT IS NOT
COMPOSED ENTIRELY OF STORM WATER.” (WITH SOME EXCEPTIONS)
THESE DISCHARGES ARE CONSIDERED “ILLICIT” BECAUSE THE MS4 IS NOT
DESIGNED TO ACCEPT, PROCESS OR DISCHARGE NON-STORMWATER FLOWS

COLOR: RAINBOW SHEEN THAT TENDS TO
SWIRL WHEN DISTURBED.
ODOR: MAY HAVE PETROLEUM OR GASOLINE
SMELL

COLOR: YELLOW, BROWN
ODOR: STALE GREASY SMELL, PETROLEUM,
APPEARANCE: MATERIAL TYPICALLY
CLUMPS/STRINGS TOGETHER

COLOR: ORANGE, YELLOW, RED,
“CHOCOLATE MILK”
ODOR: NONE
APPEARANCE: WATER CAN BE VERY TURBID,
MAY NOT BE ABLE TO SEE BOTTOM OF
STREAM

COLOR: GREY
ODOR: STRONG SEWAGE SMELL, SULFUR,
FECAL MATTER
APPEARANCE: FOAM, BUBBLES, FOOD
WASTES, TOILET PAPER, ETC.

COLOR: MILKY WHITE, GREY, CLOUDY
ODOR: FRAGRANCE LIKE LAUNDRY
DETERGENT/SOAPS, OR NONE AT ALL
APPEARANCE: BUBBLES, FOAM, HIGHLY
TURBID

• PAINT
• PET WASTE
• PESTICIDES, HERBICIDES, FERTILIZERS
• CHLORINATED SWIMMING POOL WATER

• SOME NON-STORMWATER DISCHARGES ARE ALLOWED UNDER THE BOROUGH’S STORMWATER MANAGEMENT
ORDINANCE (SWMO) § 315-81D) AND ARE THEREFORE NOT ILLICIT DISCHARGES:
• DISCHARGES FROM FIREFIGHTING ACTIVITIES
• AIR-CONDITIONING CONDENSATE.
• SPRINGS.
• LAWN WATERING.
• DECHLORINATED SWIMMING POOL DISCHARGES.
• WATER FROM INDIVIDUAL RESIDENTIAL CAR WASHING.
• ROUTINE EXTERNAL BUILDING WASH DOWN (WHICH DOES NOT USE DETERGENTS OR OTHER COMPOUNDS).
• OTHER DISCHARGES APPROVED BY THE BOROUGH

• PROHIBITED CONNECTIONS
• FAILING TREATMENT SYSTEMS (EX. SEPTIC SYSTEMS)
• ILLEGAL DUMPING
• LEAKING FACILITIES (DUMPSTERS, TANKS)
• SPILLS
MORE INDIRECT CAUSES OF ILLICIT DISCHARGE:
• LANDSCAPING/GROUNDS CARE
• SEDIMENT RUNOFF
• AGRICULTURAL RUNOFF (PESTICIDES AND FERTILIZERS)

• THE BOROUGH’S SWMO DEFINES PROHIBITED CONNECTIONS (§315.81):
• (1) ANY DRAIN OR CONVEYANCE, WHETHER ON THE SURFACE OR SUBSURFACE, THAT ALLOWS
ANY NON-STORMWATER DISCHARGE INCLUDING SEWAGE, PROCESS WASTEWATER, AND WASH
WATER TO ENTER A MUNICIPAL SEPARATE STORM SEWER (IF APPLICABLE), OR WATERS OF THIS
COMMONWEALTH, AND ANY CONNECTIONS TO THE STORM SEWER FROM INDOOR DRAINS AND
SINKS; AND
• (2) ANY DRAIN OR CONVEYANCE CONNECTED FROM A COMMERCIAL OR INDUSTRIAL LAND USE
TO THE MUNICIPAL SEPARATE STORM SEWER (IF APPLICABLE) WHICH HAS NOT BEEN DOCUMENTED
IN PLANS, MAPS, OR EQUIVALENT RECORDS, AND APPROVED BY THE BOROUGH.

• CITIZEN REPORTING *
• OUTFALL INSPECTIONS *
• OTHER AGENCY REPORTING

CITIZENS ARE OFTEN THE FIRST TO OBSERVE AN EVENT THAT MAY LEAD TO AN ILLICIT
DISCHARGE. IT IS IMPORTANT THAT THEY CAN EASILY REPORT THESE CONCERNS DIRECTLY TO
THE BOROUGH.
• CALLING THE BOROUGH’S MAIN OFFICE NUMBER AND EITHER SPEAKING TO SOMEONE OR LEAVING
A MESSAGE
• HAVING A WAY TO REPORT A CONCERN ONLINE (EMAIL ADDRESS, LINK)

WHEN A CALL IS RECEIVED TRY TO GET AS MUCH INFORMATION AS POSSIBLE:
SOME KEY QUESTIONS TO ASK:
WHERE DID IT OCCUR?
WHEN DID IT OCCUR?
IS THERE A NOTICEABLE ODOR?
IS THERE A NOTICEABLE COLOR/SHEEN?
REFER INQUIRIES TO THE PUBLIC WORKS DIRECTOR FOR INVESTIGATION

• ROUTINE OUTFALL INSPECTIONS CAN OFTEN REVEAL ILLICIT DISCHARGES
• THE INSPECTIONS CHECK FOR THE FOLLOWING GENERAL PARAMETERS:
• DRY WEATHER FLOWS
• HIGH TURBIDITY
• STRONG ODORS
• UNUSUAL COLORS
• FLOATING OR SUBMERGED SOLIDS
• DEPOSITS/STAINS
• ABNORMAL VEGETATION
IF INSPECTION STAFF ENCOUNTER A DISCHARGE THAT POSES AN IMMEDIATE HEALTH AND SAFETY THREAT TO THE PUBLIC
DURING INSPECTION ACTIVITIES, THE PROBLEM WILL BE IMMEDIATELY REFERRED TO DEP EMERGENCY RESPONSE.

• THE BOROUGH MUST MAINTAIN AND UPDATE A LIST OF “PRIORITY AREAS”: AREAS WITH A
HIGHER LIKELIHOOD OF ILLICIT DISCHARGES, ILLEGAL CONNECTIONS, AND/OR ILLEGAL
DUMPING. THESE CAN INCLUDE:
• AREAS WITH OLDER INFRASTRUCTURE
• A CONCENTRATION OF HIGH RISK ACTIVITIES
• PAST HISTORY OF WATER POLLUTION
THESE AREAS SHOULD INSPECTED ANNUALLY.

• AFTER A COMPLAINT IS RECEIVED OR AN INSPECTION REVEALS A POTENTIAL ILLICIT DISCHARGE, AN
INVESTIGATION WILL BE INITIATED
• AN INVESTIGATION CAN INCLUDE ANY OR ALL OF THE FOLLOWING:
• REVIEW OF CURRENT OUTFALL AND STORM SEWER MAPS
• REVIEW OF PAST INVESTIGATIONS/INSPECTION REPORTS (IF ANY)
• SITE VISIT:
• SAMPLING OF ANY FLOWS
• “TRACING THE SOURCE”
• STORM DRAIN NETWORK INVESTIGATIONS
• DRAINAGE AREA INVESTIGATIONS

• RECORD KEEPING IS EXTREMELY IMPORTANT!! BE SURE TO DOCUMENT AND SAVE EVERYTHING
INCLUDING:
• CITIZEN COMPLAINT ILLICIT DISCHARGE FORM
• RESPONSE FORM (IN IDDE PROGRAM)
• FIELD/INSPECTION NOTES
• LAB RESULTS
• CORRESPONDENCE (MAIL, EMAIL, PHONE LOGS)
• PROOF OF CORRECTED PROBLEM
• ANY ADDITIONAL INFO

WHEN THE CAUSE OF THE ILLICIT DISCHARGE IS DISCOVERED, CORRECTIVE ACTIONS SHOULD
TAKE PLACE INCLUDING:
• NOTIFYING THE PROPERTY OWNER OR OPERATOR OF THE PROBLEM, AND PROVIDING THE
APPROPRIATE EDUCATIONAL MATERIALS AND/OR A COPY OF THE IDDE ORDINANCE
• FOCUS FIRST ON EDUCATION TO PROMOTE VOLUNTARY COMPLIANCE AND ESCALATE TO
INCREASINGLY SEVERE ENFORCEMENT ACTIONS IF VOLUNTARY COMPLIANCE IS NOT OBTAINED.

A CALL IS RECEIVED CLAIMING THAT A STREAM IN THE BOROUGH HAS A STRONG SULFUR SMELL
AND A BUBBLY/FOAMY APPEARANCE. THE AREA IS IN THE VICINITY OF SEVERAL BOROUGH
STORMWATER OUTFALLS.
WHAT WOULD YOU DO NEXT?

1.
THE PERSON RECEIVING THE CALL SHOULD GATHER AS MUCH INFORMATION AS POSSIBLE
AND FORWARD TO THE PUBLIC WORKS DIRECTOR.
2.
THE INVESTIGATION SHOULD INCLUDE A SITE VISIT, SAMPLING AND A STORM DRAIN
NETWORK INVESTIGATION (TO SEARCH FOR ILLICIT CONNECTIONS).
3.
ENFORCEMENT ACTIONS SHOULD TAKE PLACE TO CORRECT THE PROBLEM.
4.
BASED ON FINDINGS, A CALL TO DEP MAY BE NECESSARY.

THE SITUATION ON THE LEFT WAS SPOTTED
ON BOROUGH PROPERTY. A STORM SEWER
INLET IS LOCATED NEARBY IN THE PATH OF THE
FLOW FROM THE DUMPSTER.
• WHAT ARE THE NEXT STEPS?

• CONTACT THE PUBLIC WORKS DEPARTMENT IMMEDIATELY TO INITIATE THEIR CLEAN UP
PROCEDURES
• THIS SHOULD INCLUDE CLEAN UP AND PROPER DISPOSAL OF THE FLUIDS AND AN INSPECTION
OF THE DUMPSTER TO DETERMINE THE CAUSE OF THE LEAK
• THE FACILITY SHOULD BE REPAIRED OR REPLACED BEFORE IT IS USED AGAIN.

• AN OUTFALL INSPECTION REVEALED AN OUTFALL WITH “CHOCOLATE MILK” COLORED FLOW.

1. THE INSPECTOR SHOULD PHOTOGRAPH THE PROBLEM AREA AND CONDUCT A QUICK
VISUAL INSPECTION OF THE SURROUNDING AREA TO IDENTIFY ANY OBVIOUS POLLUTION
SOURCES.
3. A DRAINAGE AREA INVESTIGATION SHOULD BE CONDUCTED TO “TRACE THE SOURCE”
4. ENFORCEMENT ACTIONS SHOULD TAKE PLACE TO CORRECT THE PROBLEM.
5. BASED ON FINDINGS, A CALL TO DEP MAY BE NECESSARY.