Public Lab Research note


How to report pollution entering your local stormwater system in the US

by bhamster | August 20, 2021 15:55 20 Aug 15:55 | #27606 | #27606

Lead image: Andrew Wamboldt / KOMU, CC BY


Purpose

This activity explains how to report pollution entering your local stormwater system. Cities and towns with Municipal Separate Storm Sewer Systems (MS4) direct stormwater runoff directly to local waterbodies rather than treatment plants. Pollution entering this system, for instance through storm drains and other catch basins, might be an "illicit discharge" that's not allowed under an existing stormwater permit.

Under US EPA requirements, cities and towns with MS4 permits must have an Illicit Discharge Detection and Elimination (IDDE) program in place. As part of this program, each municipality will have a contact person to whom residents can report illicit discharges. This contact must then detect and eliminate the problem discharge.

This activity is based on tips shared by Courteny Morehouse, an environmental planner with the Berkshire Regional Planning Commission in Massachusetts. Thanks, Courteny!


Materials needed

  • Note-taking materials (paper/pen, note app on a smartphone)
  • Computer/tablet/phone with a connection to the internet
  • Phone for calling hotlines or municipality contacts


Steps

Step 1

Observe an illicit discharge of wastewater or common warning signs of one. According to the Greater Lansing Regional Committee for Stormwater Management, there are four common clues that could indicate illicit discharges:

  • Dry weather flow: it hasn't rained for 72 hours but you still see flow into or out of a storm drain.
  • Suds or foam: you see soapy bubbles or foam at an outlet. You could try a "stick test" to see if the foam is likely naturally-occurring or potential pollution.
  • Sewage: you see sanitary waste, gray water, or black staining inside the outlet pipe. This can come from leaking sanitary sewer pipes, for example.
  • Oil and gas: you see a rainbow sheen on the water's surface. Again, you can try a "stick test" to see if it's naturally-occurring or oil/gas.

oil sheensewage channel

Left: Oil sheen, by Jomegat, CC BY SA. Right: Dry weather flow and a stained pipe.


This comment by @jesseslone also lists several signs of under-treated wastewater that could be applicable here too (en español thanks to @alejobonifacio).

Places you might see clues of illicit discharges include storm drain inlets along a roadway, pipes draining into ditches, and stormwater system outlets/outfalls draining into larger waterbodies.


Step 2

Note details about the discharge. Take note of where, when, and what you see and smell at the discharge point. 📝


Step 3

Find contact information for the municipality in which you found the illicit discharge. If you're in a city or town, it's probably easiest to start by searching for the city's general public website. If you don't have access to an internet-connected device, you can also find the city's general contact phone number in a phone book.


Step 4

Once you're on your city's website homepage, you can try a few things to locate the specific contact for reporting illicit discharges:

  1. Look for a "Services" category and see if "Environment" or "Stormwater" is listed. Then look for something like a "Stormwater hotline." If you find a hotline number---success! 👍🏻
  2. If that doesn't work, try using the website's search bar to search for "illicit discharge" or "illicit discharge detection and elimination." From any results, try locating a contact number.
  3. If you can't find a stormwater-specific contact number, try the city's general reporting phone line, like 311.

When I tried finding this information at a few different city websites, there wasn't a single approach that consistently led me to the right place.

For example, the City of Bellingham in Washington state has a webpage about stormwater management and easy-to-see resources that include a stormwater hotline. In contrast, the City of Somerville in Massachusetts uses 311 to accept reports about illicit discharges, and I found this information buried in a PDF listed on a results page after I searched for "illicit discharge."

You might have to poke around a bit. 🔎

If you can't find reporting contacts for your city or town, you can try going up a level and contacting your state's environmental agency. The EPA lists Health and Environmental Agencies of U.S. States and Territories here. Click on your state and then follow the link for the agency that has "environment" in its name. Some states have combined environmental and public health agencies. If you don't see an agency that mentions "environment," try "natural resources" or "ecology."

💬 Edited to add: check out this comment below for more tips on different ways to report stormwater pollution. And thanks to Kirsten at RE-Sources for the information!


Step 5

Report the illicit discharge with information you noted in step 2!


Wrap up

Follow up activities


More resources


Have you reported an illicit discharge report and have tips to share? If you have any ideas for improving this activity, please comment below!


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5 Comments

This "How to Spot and Report Pollution" guide from RE-Sources in Bellingham, WA, also has fantastic tips and images about safely spotting pollution that might be related to wastewater. They also have more video guides here.

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Please report everything that you are being discharged into the water seems weird. But a question. Every now and then, a storm sewer in a relatively remote location with a small plant would need sampled. The ISCO sampler was pulled out and since many were on vacation, I was volunteered to go out and help sample ( usually a group of 2 people). We put the sampler in and came back a day later to get the water sample. It was interesting. The probe had toilet paper on it. And while we were there, we saw brown waste flowing down the storm sewer. The EPA was contacted. But apparently, there are some situations where this is perfectly legal. My point- please report and keep track of all situations like this, but don't expect immediate action.

Thanks for sharing and making this point. Do you know if the location you sampled was part of a separate storm sewer or combined storm sewer system? Combined systems can permit overflows when the system would otherwise be overloaded, unfortunately. And apparently, even in separate systems, it's possible that sanitary sewer overflows are allowed under the NPDES permit.

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I don't know that. The company with a plant nearby had a discharge permit. No idea anymore of the permit number. Most plants would prefer to discharge into storm sewers, rather than sanitary sewers, wherever possible. That's not usually a possibility with sanitary discharges, though.

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I recently was fortunate to talk with Kirsten McDade, who creates community programs on stormwater monitoring at RE-Sources. She had some excellent tips on several places to report stormwater issues, and the benefits of each:

  1. The municipal pollution hotline (Step 4 above), required under an MS4 permit. This might result in the fastest response as the city often has necessary equipment on hand.
  2. Environmental agencies in your county or state. Washington state, for example, has an environmental report tracking system (ERTS) here. They may be helpful in cases where you aren’t sure who’s supposed to handle the pollution, or if the city or other permit owner is unresponsive. The state is responsible for holding permit owners accountable.
  3. Waterkeeper organizations! They are also required to have a pollution reporting hotline. Kirsten’s organization is a Waterkeeper, and contacting someone like her is helpful because she knows who best to contact in a given situation. She can also keep contacting people until the problem is fixed, raise public awareness of an issue, and ultimately help prevent similar issues from happening again. Knowing where residents are reporting stormwater issues can inform Waterkeeper community monitoring programs, as well.

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