Illicit Discharge Elimination Program

Illicit Discharge

An illicit discharge is defined as any discharge to the municipal separate storm sewer system that is not composed entirely of storm water, except for discharges allowed under an NPDES permit or waters used for firefighting operations. These non-stormwater discharges can occur due to illegal connections to the storm drain system from any residential, commercial, or other establishments.

As a result of these illicit connections, contaminated wastewater can enter into storm drains or directly into local water ways without receiving treatment from a wastewater treatment plant. Illicit connections may be intentional or unknown to the business owner. These connections are most often due to the floor drains connected to the storm drainage system. Additional sources of illicit discharges are failing septic systems, illegal dumping practices, and the improper disposal of sewage from recreational practices such as boating or camping. Illicit discharges also can be generated by persons using antiquated methods for tasks such as cleaning pool filters, cleaning paint brushes, car washing and other common activities.

A "point source discharge" is defined as an outfall from a drainage system to waters of the state, or a point where a storm water drainage system discharges into a system operated by another public body. "Waters of the State" are defined to mean all of the following: the Great Lakes and their connecting waters, all inland lakes, rivers, streams, impoundments, open drains, and other surface bodies of water within the confines of the State.

Illicit Discharge Elimination Plan (IDEP)

The development and enforcement of an Illicit Discharge Elimination Plan (IDEP) has been a major requirement of the City of East Lansing's stormwater discharge permits. An approvable IDEP must include the following components: verifying point source discharge locations, field screening of all discharges to identify potential problems, eliminating problem discharges once identified and tested, enacting an enforceable ordinance to provide for the elimination of illicit discharges, and providing for proper siting and maintenance of on-site sewage disposal systems.

As defined in the Stormwater Management Plans, the City of East Lansing drains to two different major watersheds, 1) the Red Cedar River Watershed and 2) Looking Glass River Watershed. The City has identified 13 waters of the state within the Looking Glass River Watershed and four waters of the state within the Red Cedar Watershed.

The City has reviewed their records and completed a field investigation of these 17 waters of the state and has identified over 220 individual point source discharges. Specific information has been gathered for all such point source discharges. Each of the point source discharges was inspected during dry weather flow to determine if flow was present. Any point source discharges which exhibited discharge during dry weather conditions and/or showed signs of odors, deposits, floatable matter, or other signs of an illicit discharge were then sampled, tested, and investigated. If the results from the chemical and biological test indicate the presence of a sanitary waste, chemical waste, or other illicit discharge, the upstream system will be investigated until the source of the illicit discharge can be found. The City will then make sure that any illicit discharge is removed from the storm water system.

Municipal Code Revisions

In order to assure that the City of East Lansing has the ability to enforce the concepts of the IDEP, the City Council approved revisions to the
Municipal Code - Chapter 46 - Utilities, Article IV., Separate Storm Sewer System Service in 2007.

Over 99% of the parcels within the City of East Lansing are served by public sanitary sewers. As such, only a few isolated parcels are still served by individual on-site sewage disposal systems. The on-site sewage disposal systems are permitted through the individual County Departments of Health.

Report Illicit Discharges

Anyone who is aware of or suspects an illicit discharge is entering a water of the state should contact the City of East Lansing Department of Public Works at (517) 337-9459.