Illicit Discharge Detection and Elimination

For the City of Bartlett’s Storm Water Management program to be effective there must be a means for detecting and eliminating illicit discharges into the municipal separate storm sewer system (MS4).  The discharge of pollutants into the streets and storm drains of the City of Bartlett is a violation of the Clean Water Act of 1977 (as amended), Tennessee Department of Environment and Conservation (TDEC) regulations and the City of Bartlett Storm Water Ordinance (section 14-2 of the City of Bartlett codified ordinances).

What is an illicit discharge?
Federal regulations define an illicit discharge as “…any discharge to an MS4 that is not composed entirely of storm water…” with some exceptions.  Illicit discharges are considered “illicit” because MS4s are not designed to accept, process or discharge such non-storm water waste.  Some sources of illicit discharges include sanitary wastewater, effluent from septic tanks, car wash wastewaters, improper oil disposal, radiator flushing disposal and laundry wastewaters.  A more thorough listing of illicit discharges and exceptions can be found in the City of Bartlett Storm Water Ordinance by using the link on the left side of this page.

Why are illicit discharge detection and elimination efforts necessary?
Uncontrolled storm water drainage and discharge may have a significant, adverse impact on the health, safety and general welfare of Bartlett and the quality of life of its citizens by carrying pollutants into receiving waters.  Illicit discharges enter the system through either direct connections (e.g., wastewater piping either mistakenly or deliberately connected to the storm drain) or indirect connections (e.g., infiltration into the system from cracked sanitary systems, spills collected by drain inlets, 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 waters.  Pollutant levels from these illicit discharges have been shown in Environmental Protection Agency studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife, and human health.

How can we detect and eliminate illicit discharges?
The City of Bartlett Storm Water Ordinance authorizes the issuance of civil penalties for illicit discharges to the city streets and storm drain system.  However, the intent of the ordinance is to have the discharges cease.  It’s incumbent upon each citizen to help identify illicit discharges so corrective actions can be initiated to eliminate the discharge.  If you see or suspect an illicit discharge is taking place, contact the City of Bartlett by using the Citizen Requests link on the left side of this page or contact the Storm Water Management Division office at (901) 385-6499.  An inspector will be assigned to investigate the complaint.