Should permittees report outfall sampling for illicit discharge detection and elimination (IDDE) program activities?
A38: In most cases, no. There is a fine distinction between “sampling” and “monitoring.” The intent of this requirement is to report on “monitoring or studies.” That implies some level of a monitoring program, not one-time samples for the single purpose of identifying a potential illicit discharge. Ecology expects to receive the information on IDDE (and Phase I source control efforts) in other parts of the annual report and can follow up as needed. If the IDDE activities require ongoing monitoring to address a problem, you can include it here with a brief description, but this isn’t required if you report the IDDE activity elsewhere in the annual report.
