The Town of Concord, MA failed to take required measures to detect and eliminate illicit discharges ( IDDE ) under EPAÂs NPDES General Permit for Storm Water Discharges from Small Municipal Separate Storm Sewer Systems ( Small MS4 Permit ). The Permit requires that permittees develop, implement and enforce a program to reduce the discharge of pollutants from municipal separate storm sewer systems to the maximum extent practicable and satisfy the water quality requirements of the Clean Water Act (ÂCWAÂ) and state water quality standards. EPA took an administrative penalty action on 8/13/09 and settled the matter on 6/1/10. The Town agreed to pay a penalty of $10,000.