Springfield, Massachusetts, a municipality of about 150,000 people, owns and operates a municipal separate storm sewer system (MS4) that discharges to the Connecticut and Chicopee Rivers, both of which are listed as impaired for bacteria. EPA?s National Pollutant Discharge Elimination System (NPDES) general permit for stormwater discharges from small MS4s requires Springfield, among other things, to develop and implement a program to search for, identify and remove illicit discharges to the MS4. An audit by EPA revealed that the City did not screen most of its outfalls for signs of illicit connections and has done no other investigations for potential illicit discharges. EPA sampling identified two outfalls with clear indications of sanitary sewage discharge (including high pharmaceutical results). Based on this information, the Region issued an administrative order that requires Springfield to screen all of its outfalls for dry weather discharge, to sample those with dry weather discharge, and to investigate those with signs of potential illicit discharges. The order also requires Springfield to immediately investigate the two outfalls where EPA testing revealed sanitary sewage contamination.