Illicit Discharge Detection and Elimination


The purpose of this policy is to provide for the health, safety, and general welfare of the students, staff and visitors of George Mason University through the regulation of non-storm water discharges to the storm drainage system to the maximum extent practicable as required by federal and state law. This policy establishes methods for controlling the introduction of pollutants into the municipal separate storm sewer system (MS4) in order to comply with requirements of the Virginia Stormwater Management Program permit for George Mason University.


“Best Management Practices” (BMPs) means schedules of activities, prohibitions of practices, general good housekeeping practices, pollution prevention and educational practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants directly or indirectly to storm water, receiving waters, or storm water conveyance systems.  BMPs also include treatment practices, operating procedures, and practices to control site runoff, spillage or leaks, sludge or water disposal, or drainage from raw materials storage.

“De Minimis” means small, minor, or insignificant spills of materials that occur during normal material handling operations (e.g., spills from unloading or transfer of materials, leaks from pipes or valves, minor leaks of process equipment, etc.).

“Hazardous Materials” means any material, including any substance, waste, or combination thereof, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to, a substantial present or potential hazard to human health, safety, property, or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

“Illegal Discharge” means any direct or indirect non-storm water discharge to the storm drain system, except as exempted in Section III of this policy.

“Municipal Separate Storm Sewer System” (MS4) means the system of conveyances (including, roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains) owned and operated by George Mason University and designed or used for collecting or conveying storm water, and that is not used for collecting or conveying sewage.

“Non-Storm Water Discharge” means any discharge to the storm drain system that is not composed entirely of storm water.

“Pollutant” means anything which causes or contributes to pollution. Pollutants may include, but are not limited to: paints, varnishes, and solvents; oil and other automotive fluids; non-hazardous liquid and solid wastes and yard wastes; refuse, rubbish, garbage, litter, or other discarded or abandoned objects, polices, and accumulations, so that same may cause or contribute to pollution; floatables; pesticides, herbicides, and fertilizers; hazardous substances and wastes; sewage, fecal coliform and pathogens; dissolved and particulate metals; animal wastes; wasteland residues that result from constructing a building or structure; and noxious or offensive matter of any kind.

“Storm Drainage System” means publicly-owned facilities by which storm water is collected and/or conveyed, including but not limited to any roads with drainage systems, municipal streets, gutters, curbs, inlets, piped storm drains, pumping facilities, retention and detention basins, natural and human-made or altered drainage channels, reservoirs, and other drainage structures.

“Storm Water” means any surface flow, runoff, and drainage consisting entirely of water from any form of natural precipitation, and resulting from such precipitation.

“Wastewater” means any water or other liquid, other than uncontaminated storm water, discharged from a facility.


No university employee, student, visitor or contractor shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the university’s storm water drainage system any pollutants or waters containing any pollutants, other than storm water. The Environmental Health and Safety Office (EHS), Facilities Land Development, Facilities Construction Management, and Facilities Management work cooperatively to prevent, identify, and respond to illicit discharges.

The commencement, conduct, or continuance of any illegal discharge to the storm drain system is prohibited except as described as follows:

1. Individual non-stormwater discharges or flows that have been identified in writing by Virginia’s Department of Environmental Quality as de minimis discharges that are not significant sources of pollutants to state waters and do not require a VPDES permit;

2. Non-stormwater discharges or flows that are considered to be not significant contributors of pollutants to the MS4, including water line flushing, managed in a manner to avoid instream impact, landscape irrigation, diverted stream flows, rising ground waters, uncontaminated ground water infiltration, uncontaminated pumped ground water, discharges from potable water sources, foundation drains, air conditioning condensate, irrigation water, springs, water from crawl space pumps, footing drains, lawn watering, individual residential car washing, flows from riparian habitats and wetlands, de-chlorinated swimming pool discharges, street wash water; and discharges or flow from firefighting activities;

3. Discharges or flow specified in writing by Facilities Land Development as being necessary to protect public health and safety.

4. Discharges associated with dye testing; however, this activity requires notification to Facilities Land Development prior to the time of the test.

5. The prohibition shall not apply to any non-storm water discharge permitted under an NPDES permit, waiver, or waste discharge order issued to the discharger and administered under the authority of the United States Environmental Protection Agency (EPA), provided that the discharger is in full compliance with all requirements of the permit, waiver, or order and other applicable laws and regulations, and provided that written approval has been granted for the permitted discharge to the storm drain system.


Notwithstanding other requirements of law, as soon as any person responsible for a facility or operation, or responsible for emergency response for a facility or operation has information of any known or suspected release of materials, which are resulting or may result in illegal discharges or pollutants discharging into storm water, the storm drain system, or waters of the United States, said person shall take all necessary steps to ensure the discovery, containment, mitigation, and proper reporting of such release. Failure to provide notification of a release as provided above is a violation of this Policy.

In the event of a suspected release of unknown or hazardous materials, the person identifying the release shall immediately notify University Police, who will then contact EHS. EHS will coordinate all ensuing investigation, emergency response, and remediation activities, in cooperation with emergency response agencies, Facilities Land Development, and Facilities Management. EHS is responsible for reporting emergency illicit discharges to the National Response Center, the Virginia Department of Environmental Quality, and the Virginia Department of Emergency Services, as required.

In the event of a release of non-hazardous materials, the person identifying the release shall notify EHS by phone or email, or by calling University Police, who in turn will contact EHS.  EHS will investigate all reported non-hazardous releases to storm sewers, and will communicate findings to Facilities Land Development.   Facilities Land Development is responsible for reporting all non-emergency illicit discharges to the Virginia Department of Environmental Quality.


A.    The university may suspend or cease activities and operations that are not in full compliance with this policy.

B.    Whenever George Mason University finds that a violation of this Policy has occurred, EHS may order compliance by written notice to the responsible person. Such notice may require, without limitation:

  1. The performance of monitoring, analyses, and reporting;
  2. The elimination of prohibited discharges or connections;
  3. Cessation of any violating discharges, practices, or operations;
  4. The abatement or remediation of storm water pollution or contamination hazards and the restoration of any affected property;
  5. Payment of any fee, penalty, or fine assessed against the university to cover remediation cost;
  6. The implementation of new storm water management practices; and
  7. Disciplinary action up to and including dismissal, where appropriate.

C.   Such notification shall set forth the nature of the violation(s) and establish a time limit for correction of these violation(s). Said notice may further advise that, if applicable, should the violator fail to take the required action within the established deadline.  EHS will then initiate work orders for the appropriate corrective actions and the violator or university department will be charged for the cost.

D.    The remedies listed in this Policy are not exclusive of any other remedies available under any applicable federal, state, or local law.


This policy will become effective upon the date of approval by the Senior Vice President for Administration and Finance and the Provost and Executive Vice President.  This Policy, and any related procedures, shall be reviewed annually.


Carol Dillon Kissal
Senior Vice President for Administration and Finance

Mark R. Ginsberg
Provost and Executive Vice President

Date Approved:  02/21/2013

Revised:  10/26/2021