Illicit Discharge Awareness & Reporting


To effectively reduce or eliminate storm water runoff pollution, 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. City inspectors can't be everywhere but the citizens of Bartlett are. You are in a position to aid in reducing or eliminating storm water runoff pollution by reporting it when you see it.

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. Even leaves and grass blown into the streets or placed in gutters are considered illicit discharges. A more thorough listing of illicit discharges and exceptions can be found in the City of Bartlett's storm water ordinance (PDF).

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 uses the process of dry weather monitoring as one means of detecting illicit discharges or connections to the MS4. We check drainage discharge locations for water flow when there hasn't been any rain. If there is a flow present, there may be an illicit discharge occurring. Many times, however, flows are the result of permitted activities such as irrigation or car washing. There may even be a spring leaking into the system. So just because there is a flow doesn't mean there is an illicit discharge. If you notice a flow, report it and we'll send an inspector to investigate.

It's incumbent upon each citizen to help identify illicit discharges so corrective actions can be initiated to eliminate the discharge. Citizens should become familiar with the City's storm water ordinance so they can detect illicit discharges or illegal dumping. 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 385-6499. An inspector will be assigned to investigate the complaint.