A Guidance Manual for Illicit Discharge Detection and Elimination
Watershed protection in Cuyahoga County
The Cuyahoga County Board of Health (CCBH) provides public health services to 56 cities, villages, and townships in Cuyahoga County, OH, with an approximate population of 830,000. Cuyahoga County is on the shores of Lake Erie and contains three major watersheds: the Rocky River, the Cuyahoga River, and the Chagrin River, all of which drain to the lake. Of the 56 communities served, 55 are Phase II designated under the National Pollutant Discharge Elimination System (NPDES) Phase II program.
The CCBH Watershed Protection Unit was developed and designed to protect public health and Cuyahoga County’s water-quality resources from the impact of point-source and nonpoint-source pollution. The Watershed Protection Unit also stresses the utilization of watershed-based planning within the Cuyahoga County Board of Health as well as collaborative efforts with partnering agencies and regional authorities. This unit has been evolving and expanding over the last several years and now includes a variety of activities to assist Cuyahoga communities and collaborative partners. These activities include all programs as well as educational outreach and public involvement programs, which have an impact on both surface-and groundwater issues. Through the watershed activities, the Phase II stormwater regional program, and growth of watershed-based programs, the CCBH developed an Illicit Discharge Detection and Elimination (IDDE) Guidance Manual for use by Phase II-designated communities in the state of Ohio. This manual provides the necessary protocol required by Phase II communities for their stormwater management plans. The manual also contains a model IDDE ordinance as well as an IDDE database.
CCBH Water-Quality Background and History
The current Watershed Protection Unit has evolved dramatically over the last 20 years and has seen a clear shift in fundamental philosophy. The initial stages of this program were set in the mid-1980s. During this time, the CCBH developed a water-quality sampling program to assist in identifying failing household sewage treatment systems (HSTSs) throughout the CCBH’s jurisdiction. The sampling parameter used at this time was fecal coliform. These data assisted the Board of Health as well as communities with providing information concerning the HSTS within specific communities and watersheds. The CCBH performed hundreds of water-quality samples per year in ditches, storm sewers, and creeks throughout the county to obtain these data.
The HSTSs located within the Board of Health’s jurisdiction are primarily off-lot discharging systems. Adverse geologic and hydrologic factors prevalent in this area cause most septic systems to discharge directly to receiving waters, ditches, or storm sewers. The evolution of the Board of Health’s HSTS program was a huge factor in the creation of the Watershed Protection Unit. What once was a development-minded HSTS program has now become one that utilizes the best available technology and exhibits a true concern for the environment.
 |
| A Cuyahoga County creek |
 |
| Source tracking |
In 1992, the CCBH established its current HSTS Water Pollution Control Program. A broad watershed-based approach had begun to be utilized when investigating nuisances and identifying individual pollution sources. Sewage system evaluation results could be complemented by water-quality sampling data. In the fall of 1993, the CCBH became one of the first local health departments to launch a Household Sewage Operation and Maintenance Program. The fundamental activities of this program are HSTS evaluations on a routine basis (once every five years), water-quality sampling, educational outreach on care and maintenance of systems, and infrastructure planning and assistance with Cuyahoga County communities. Along with the ongoing nuisance investigation and requested point-of-sale evaluations, sanitarians now conduct widespread sewage system evaluations in clearly defined project areas. These evaluation results are combined with water-quality sampling data and are provided to local officials.
The CCBH’s overall water-quality program also has changed over the years to take an overall watershed-based approach when dealing with water-quality issues. There are a number of activities and programs that are a part of this broad watershed-based approach. These include:
- A regional stormwater program that is based on a more widespread consistent regional approach in dealing with the Phase II stormwater rules and requirements
- A Bathing Beach program, which uses the NOWCAST system to predict bacterial levels at Huntington Beach seven days a week.Signs are posted daily showing the most current prediction, either GOOD or POOR. This system is allowing the use of same-day water-quality data rather than waiting for 24 hours after a water sample has been taken. This model was developed between the CCBH and the US Geological Survey for Huntington Beach and went live in 2006. The data from this system are available daily by 9:30 a.m. at www.ohionowcast.info and Monday through Friday from 9:30 a.m. to 4:30 p.m. at 216-201-2000.
Along with the NOWCAST predictive model, the CCBH is also utilizing DNA source tracking at Huntington Beach to identify regionally the pollution sources. It is currently working with the University of Toledo on the DNA analysis and has started to isolate hot zones where the DNA fingerprints are matching the problems located at the beach. The CCBH is currently planning for expanding investigative activities for 2007 to identify these areas and provide this information back to communities so that they can start to eliminate these problems.
- A household sewage program, which identifies failing systems across community boundaries and is based more on watershed-based boundaries. The CCBH still needs to work with individual communities, but by looking at these systems with a watershed-based approach, it has been able to eliminate some of these pollution sources in specific watersheds or subwatersheds.
- Watershed programs. The CCBH has worked collaboratively over the past seven years on a number of watershed projects by providing data, planning, and leadership on specific projects. It is now the lead agency on the Tinkers Creek Watershed Project. The CCBH went into a collaborative partnership with the Tinkers Creek Land Conservancy to create the Tinkers Creek Watershed Partners, a nonprofit watershed-based organization for the Tinkers Creek Watershed (the largest subwatershed of the Cuyahoga River, encompassing 24 communities and four counties). The CCBH has hired a watershed coordinator to oversee this project and to ensure its success. This has created a regional program dealing with all of the watershed’s communities and counties.
- Water-quality sampling used to identify and eliminate public health nuisances and hazards in Cuyahoga’s surface waters, including the surveying of the various watersheds throughout the county. This includes the use of chemical, physical, and biological monitoring of water quality in the watersheds. In 1999, more than 50 permanent water-quality monitoring sites were established within the various watersheds in Cuyahoga County. These sites are monitored and sampled every year for chemical data. The data are used to obtain general baseline conditions and to identify problem areas potentially being impacted by sources of water pollution. The program is being expanded in 2007 to include biological monitoring as well.
- Education for the public, community officials, and businesses on nonpoint-source pollution issues, including HSTS issues, stormwater issues, and watershed-based issues throughout the region
Stormwater Program
In 2002, the CCBH initiated a regional program to assist its 55 regulated Phase II communities. On March 10, 2003, the USEPA and Ohio EPA Phase II stormwater regulations went into effect. These regulations require designated communities to develop and implement a stormwater management plan. This program is composed of six minimum control measures: public education, public involvement, illicit discharge detection and elimination, construction-site runoff control, post-construction runoff control, and good housekeeping.
In Ohio, the Northeast Ohio Stormwater Task Force was developed to provide guidance and assistance to the Phase II-designated communities located in northeast Ohio. This task force was started in 2000 and was led by the Northeast Ohio Areawide Coordinating Agency (NOACA). Many different organizations and agencies were involved in this group to provide a model stormwater management plan. Guidance documents and educational outreach programs were developed to provide these communities with the information and tools they would need in order to develop their stormwater management plans. During these meetings, it was stressed that it was very important to work across community boundaries and deal more with watershed-based boundaries. This was seen to be difficult because Ohio is a very strong “home rule” state and historically there has not been much collaboration that has occurred across community and county lines.
The 55 Phase II communities within the CCBH’s jurisdiction are impacted greatly by the illicit discharge detection and elimination component of Phase II because of their large number of discharging HSTSs. These HSTSs that discharge to a municipal separate storm sewer system (MS4) are considered illicit sources of discharges and must be identified and eliminated. In Ohio, these communities have five years in which to identify and assess all of their HSTSs that are located within their jurisdiction. This is initially how the CCBH became so involved in the Phase II stormwater program. It knew that it needed to assist its communities with this component.
 |
| Field work |
In 2003, the CCBH developed a program to assist its communities. This initially included an inventory of all designated MS4s located in a community and inspection and sampling of MS4s that were inventoried. The first year, the CCBH contracted with four communities to provide this service. Since then, it has dramatically increased the activities and services it offers. To date, it has inventoried 36 communities and contracted with another five for 2007. It has 45 contracts to provide continued inspection and sampling of MS4s on a yearly basis. It has developed a source tracking component to locate and identify the source of illicit discharges, as well as an outreach program that addresses the general public, businesses, and community officials on all components of the Phase II stormwater rules.
The CCBH’s stormwater program is now based regionally, and it allows Cuyahoga County to start looking at watershed-wide problems and across community boundaries. The information the CCBH is obtaining is now allowing for a more comprehensive look at the pollution sources affecting watersheds as a whole and not just individual communities. The CCBH is also working across county boundaries with other local health departments and across the state in providing guidance on the development of their stormwater programs.
Illicit Discharge Detection and Elimination Guidance Manual
The development of the manual came about over the last five years from the CCBH program and with input from other states’ guidance manuals. In 2001, during the Northeast Ohio Stormwater Task Force meetings, it was clear that a regional approach would be the best in dealing with illicit discharge issues. As the CCBH has developed its own stormwater program, it was instrumental to develop a guidance manual for the state on illicit discharge detection and elimination.
 |
| Measuring an outfall |
The CCBH received a grant from the Ohio Environmental Education Fund through the Ohio EPA for 2006 to develop an IDDE Guidance Manual for the state of Ohio. The CCBH worked with a technical advisory committee made up of engineers, service directors, watershed organizations, and the Ohio EPA on the development of this manual. Committee members include Cathy Becker, North Olmsted assistant city engineer; Dan Bogoevsky of the Ohio EPA; Chris Courtney of C.W. Courtney Co.; Ken Dombrowski of Wade Trim; Kyle Dreyfuss-Wells of Chagrin River Watershed Partners; Jeff Duke of the Northeast Ohio Regional Sewer District; Jeff Filarski of Chagrin Valley Engineering Ltd.; Tom Krezcko, Beachwood staff engineer; Mary Maciejowski of the Northeast Ohio Regional Sewer District; Brian Mader of Steve Hovancsek and Associates; Pam Sawchyn and Harry Stark of the CCBH; Francine Toth of the Lake County General Health District; and Laura Travers of the CCBH.
This IDDE manual was developed using a variety of resources, primarily the CCBH’s stormwater program and the actual field proofing it has done in developing that program. The program has changed and been modified yearly based on evaluation at the end of every year, and the CCBH has been able to use other guidance manuals to strengthen its own protocols. These reference manuals include:
- The Ohio EPA Phase II Storm Water Rules and Regulations (3745-39-03)
- Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments by the Center of Watershed Protection and Robert Pitt, University of Alabama, 2004
- Illicit Discharge Detection and Elimination Manual: A Handbook for Municipalities by the New England Interstate Water Pollution Control Commission, 2003
- Guidelines and Standard Operating Procedures for Stormwater Phase II Communities in Maine
- USEPA Phase II Storm Water Rules and Regulations
- USEPA Phase II Fact Sheets on Illicit Discharge Detection and Elimination Program
All of these guidance documents were instrumental in the development of this IDDE manual for Ohio.
The IDDE Guidance Manual for the state of Ohio is contained on a CD-ROM and features a variety of information, including sections on the following topics:
- What is an MS4?
- What is an illicit discharge?
- How to map your MS4s
- Developing an inspection protocol and tools that can be used to assist in these inspections
- Source tracking for an illicit discharge
- How to eliminate an illicit discharge
- Outreach to officials, businesses, and the general public
- Evaluation of your program
The manual also has an appendix, which contains a model IDDE ordinance; a field guide and field forms; a quality-assurance management plan for developing your own water-quality sampling program; an outfall identification and stream naming convention; and information on the outfall database, which is included on the CD-ROM.
Along with the manual, the Northeast Ohio Regional Sewer District (NEORSD) provided the regional database that is used in northeast Ohio, available as part of this project. This IDDE database is available for use by communities in Ohio. The actual database and information about it is located within the appendix of the manual and can be obtained by contacting the CCBH. The CCBH owes special thanks to the NEORSD for providing the Illicit Discharge Detection and Elimination Manual Outfall Database and Users Manual for this project.
The IDDE manual stresses sound planning strategies within communities based on drainage areas. The initial work performed by any community is knowledge of its streams and drainage areas and any information that is available from sanitary and storm sewer maps. Once a strong knowledge is obtained in the office, then field work is required to document and locate all MS4 outfall locations.
The inventory of the MS4 outfall locations consists of a number of important attributes:
- Global positioning system coordinates of each outfall location
- Digital photographs (important for future inspections)
- Stream
- Watershed
- Community
- Location address (if available)
- Size of pipe
- Shape of pipe
- Condition of pipe
- Pipe material
- Height from outfall invert to stream flow level
- Side of stream outfall is located on (facing downstream)
- Outfall type (MS4, other, unknown, HSTS off-lot, HSTS on-lot)
Once all of the inventory fieldwork is completed and all data are entered into the outfall database, then a report can be generated from the database. These inventory sheets provide all of the information that is obtained on an outfall, including photos and a map showing the location of the outfall.
The inspection protocol established by a community is important for future illicit discharge detection and elimination. The manual stresses that inspections should occur after a minimum of 72 hours of no rainfall. The mapping component allows for easier tracking of these MS4 outfall locations and allows for a concise field component. During these inspections, it is noted if the outfall is flowing, if there is an odor present, and if there is any observable pollution at the outfall locations (oil sheens, wastewater, etc). One important aspect to remember is that just because flow is observed at an outfall during dry weather, this does not mean there is an illicit discharge present. Such flows can be attributed to many things, such as a water line break or high water table. Likewise, just because there is no flow, it does not mean there is not an illicit discharge. Illicit discharges can be intermittent and are not always flowing. That is why it is important to also observe and look for any observable pollution at the outfall location.
One tool that the CCBH uses if flow is observed is water sampling. The initial parameter tested for is fecal coliform to indicate whether wastewater is present within this flow. The infrastructure within many locations of Cuyahoga County is old, and there historically have been structural problems associated with sanitary and storm sewer systems as well as many cross-connections of sanitary flow going directly into storm sewer lines. This initial sampling process is the beginning of a long-term program for communities. It allows for prioritization in determining problems at outfall locations. The sampling results provide communities with water-quality standards as to the nature of bacterial contamination. Those MS4s with the highest levels of bacterial pollution will be addressed by the community and/or communities across city boundaries. This allows the communities to use their resources wisely by directing their illicit discharge detection program toward the MS4s with the most immediate impact on water quality and water-quality impairments.
 |
| Taking a sample |
The sampling program is a long-term process and protocol for communities. The CCBH recommends, if communities can afford it, performing dry-weather inspections and sampling annually so communities can obtain the necessary baseline data on their MS4s. This process allows communities to see long-term trends in outfall flows and water-quality sampling results. It provides communities with the necessary information for the most effective utilization of resources to repair these illicit sources of pollution within their MS4s.
Once an illicit discharge is located at an outfall location, then source tracking is needed to start to identify where the illicit discharge is emanating from. The city starts to trace the illicit discharge upstream, beginning at the outfall. The manual includes the following items that should be performed to help isolate the source of the illicit discharge:
- Visual Inspection of storm sewer system
- Start at outfall
- Check upstream manholes to identify where flow may be coming from. Additional samples may be needed to isolate/prioritize areas.
Utilize available storm sewer mapping to assist in upstream tracing
Notes to assist in isolation of sources
Sanitary blockages (usually higher flows)
Cross-connects (usually much lower flows)
- Narrow down areas and potential sources
- Isolate an area
- Try to isolate sources even further
Perform dye-testing of connections (storm and sanitary)
Perform testing of sanitary sewers for suspect infiltration/inflow
Perform televising as necessary
Discuss with homeowner/occupant
Once the source is detected, then the elimination of these discharges is required. The development of the illicit discharge ordinance is vital to this component. The model ordinance that is provided in this manual provides the needed requirements to detect and eliminate these discharges from entering MS4s.
It is also important to educate the general public, community officials, and businesses on this component of Phase II. For this program to be successful for communities, it is important that there is an educational aspect that discusses the importance of stormwater and the impact it has on the surface waters of the state. Educating all on what an illicit discharge is, why it is important to eliminate them, and how they can impact public health and our water-quality resources can make our jobs a little easier. The general public can assist by letting communities know when they see something at an outfall, and it may help in the elimination of these sources.
The manual also discusses the need for an evaluation of each program once a year. This is an important component for all to undertake. To effectively evaluate a program, a number of questions need to be asked and analyzed.
- Is the program effective? Need to reassess the program by determining what has been achieved.
- Cost-effectiveness: What aspects of the program had the highest quality of effectiveness in relationship to cost?
- Number of illicit discharges detected utilizing each detection method Tracing program: What techniques were used, were these methods successful, and what techniques that were not used would be beneficial for next year?
- How many illicit sources were identified and eliminated?
The development of a tracking system is also vital for any IDDE program. The data and information that are obtained need to be easily tracked, reported, and responded to. A tracking system enables the community to measure the IDDE program effectiveness and assists with the evaluation of the overall IDDE program.
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This IDDE guidance manual is being provided to the 467 Phase II communities in Ohio through a series of informational meetings located throughout the state. The CCBH is making the CD-ROM containing the manual and database available for free to all communities as part of this project in the hopes of assisting other communities in meeting their Phase II stormwater illicit discharge detection and elimination requirements set forth in their stormwater management plans.
For additional information regarding the manual, the IDDE database, or the CCBH’s stormwater program, please contact Harry Stark, RS, MPA, at 216-201-2001, ext. 1205, or e-mail him at hstark@ccbh.net.
Author's Bio: Harry Stark, RS, MPA, is watershed protection programs supervisor for the Cuyahoga County Board of Health in Parma, OH.
January-February 2007
A Guidance Manual for Illicit Discharge Detection and Elimination
Watershed protection in Cuyahoga County
The Cuyahoga County Board of Health (CCBH) provides public health services to 56 cities, villages, and townships in Cuyahoga County, OH, with an approximate population of 830,000. Cuyahoga County is on the shores of Lake Erie and contains three major watersheds: the Rocky River, the Cuyahoga River, and the Chagrin River, all of which drain to the lake. Of the 56 communities served, 55 are Phase II designated under the National Pollutant Discharge Elimination System (NPDES) Phase II program.
The CCBH Watershed Protection Unit was developed and designed to protect public health and Cuyahoga County’s water-quality resources from the impact of point-source and nonpoint-source pollution. The Watershed Protection Unit also stresses the utilization of watershed-based planning within the Cuyahoga County Board of Health as well as collaborative efforts with partnering agencies and regional authorities. This unit has been evolving and expanding over the last several years and now includes a variety of activities to assist Cuyahoga communities and collaborative partners. These activities include all programs as well as educational outreach and public involvement programs, which have an impact on both surface-and groundwater issues. Through the watershed activities, the Phase II stormwater regional program, and growth of watershed-based programs, the CCBH developed an Illicit Discharge Detection and Elimination (IDDE) Guidance Manual for use by Phase II-designated communities in the state of Ohio. This manual provides the necessary protocol required by Phase II communities for their stormwater management plans. The manual also contains a model IDDE ordinance as well as an IDDE database.
CCBH Water-Quality Background and History
The current Watershed Protection Unit has evolved dramatically over the last 20 years and has seen a clear shift in fundamental philosophy. The initial stages of this program were set in the mid-1980s. During this time, the CCBH developed a water-quality sampling program to assist in identifying failing household sewage treatment systems (HSTSs) throughout the CCBH’s jurisdiction. The sampling parameter used at this time was fecal coliform. These data assisted the Board of Health as well as communities with providing information concerning the HSTS within specific communities and watersheds. The CCBH performed hundreds of water-quality samples per year in ditches, storm sewers, and creeks throughout the county to obtain these data.
The HSTSs located within the Board of Health’s jurisdiction are primarily off-lot discharging systems. Adverse geologic and hydrologic factors prevalent in this area cause most septic systems to discharge directly to receiving waters, ditches, or storm sewers. The evolution of the Board of Health’s HSTS program was a huge factor in the creation of the Watershed Protection Unit. What once was a development-minded HSTS program has now become one that utilizes the best available technology and exhibits a true concern for the environment.
|
| A Cuyahoga County creek |
|
| Source tracking |
In 1992, the CCBH established its current HSTS Water Pollution Control Program. A broad watershed-based approach had begun to be utilized when investigating nuisances and identifying individual pollution sources. Sewage system evaluation results could be complemented by water-quality sampling data. In the fall of 1993, the CCBH became one of the first local health departments to launch a Household Sewage Operation and Maintenance Program. The fundamental activities of this program are HSTS evaluations on a routine basis (once every five years), water-quality sampling, educational outreach on care and maintenance of systems, and infrastructure planning and assistance with Cuyahoga County communities. Along with the ongoing nuisance investigation and requested point-of-sale evaluations, sanitarians now conduct widespread sewage system evaluations in clearly defined project areas. These evaluation results are combined with water-quality sampling data and are provided to local officials.
The CCBH’s overall water-quality program also has changed over the years to take an overall watershed-based approach when dealing with water-quality issues. There are a number of activities and programs that are a part of this broad watershed-based approach. These include:
- A regional stormwater program that is based on a more widespread consistent regional approach in dealing with the Phase II stormwater rules and requirements
- A Bathing Beach program, which uses the NOWCAST system to predict bacterial levels at Huntington Beach seven days a week.Signs are posted daily showing the most current prediction, either GOOD or POOR. This system is allowing the use of same-day water-quality data rather than waiting for 24 hours after a water sample has been taken. This model was developed between the CCBH and the US Geological Survey for Huntington Beach and went live in 2006. The data from this system are available daily by 9:30 a.m. at www.ohionowcast.info and Monday through Friday from 9:30 a.m. to 4:30 p.m. at 216-201-2000.
Along with the NOWCAST predictive model, the CCBH is also utilizing DNA source tracking at Huntington Beach to identify regionally the pollution sources. It is currently working with the University of Toledo on the DNA analysis and has started to isolate hot zones where the DNA fingerprints are matching the problems located at the beach. The CCBH is currently planning for expanding investigative activities for 2007 to identify these areas and provide this information back to communities so that they can start to eliminate these problems.
- A household sewage program, which identifies failing systems across community boundaries and is based more on watershed-based boundaries. The CCBH still needs to work with individual communities, but by looking at these systems with a watershed-based approach, it has been able to eliminate some of these pollution sources in specific watersheds or subwatersheds.
- Watershed programs. The CCBH has worked collaboratively over the past seven years on a number of watershed projects by providing data, planning, and leadership on specific projects. It is now the lead agency on the Tinkers Creek Watershed Project. The CCBH went into a collaborative partnership with the Tinkers Creek Land Conservancy to create the Tinkers Creek Watershed Partners, a nonprofit watershed-based organization for the Tinkers Creek Watershed (the largest subwatershed of the Cuyahoga River, encompassing 24 communities and four counties). The CCBH has hired a watershed coordinator to oversee this project and to ensure its success. This has created a regional program dealing with all of the watershed’s communities and counties.
- Water-quality sampling used to identify and eliminate public health nuisances and hazards in Cuyahoga’s surface waters, including the surveying of the various watersheds throughout the county. This includes the use of chemical, physical, and biological monitoring of water quality in the watersheds. In 1999, more than 50 permanent water-quality monitoring sites were established within the various watersheds in Cuyahoga County. These sites are monitored and sampled every year for chemical data. The data are used to obtain general baseline conditions and to identify problem areas potentially being impacted by sources of water pollution. The program is being expanded in 2007 to include biological monitoring as well.
- Education for the public, community officials, and businesses on nonpoint-source pollution issues, including HSTS issues, stormwater issues, and watershed-based issues throughout the region
Stormwater Program
In 2002, the CCBH initiated a regional program to assist its 55 regulated Phase II communities. On March 10, 2003, the USEPA and Ohio EPA Phase II stormwater regulations went into effect. These regulations require designated communities to develop and implement a stormwater management plan. This program is composed of six minimum control measures: public education, public involvement, illicit discharge detection and elimination, construction-site runoff control, post-construction runoff control, and good housekeeping.
In Ohio, the Northeast Ohio Stormwater Task Force was developed to provide guidance and assistance to the Phase II-designated communities located in northeast Ohio. This task force was started in 2000 and was led by the Northeast Ohio Areawide Coordinating Agency (NOACA). Many different organizations and agencies were involved in this group to provide a model stormwater management plan. Guidance documents and educational outreach programs were developed to provide these communities with the information and tools they would need in order to develop their stormwater management plans. During these meetings, it was stressed that it was very important to work across community boundaries and deal more with watershed-based boundaries. This was seen to be difficult because Ohio is a very strong “home rule” state and historically there has not been much collaboration that has occurred across community and county lines.
The 55 Phase II communities within the CCBH’s jurisdiction are impacted greatly by the illicit discharge detection and elimination component of Phase II because of their large number of discharging HSTSs. These HSTSs that discharge to a municipal separate storm sewer system (MS4) are considered illicit sources of discharges and must be identified and eliminated. In Ohio, these communities have five years in which to identify and assess all of their HSTSs that are located within their jurisdiction. This is initially how the CCBH became so involved in the Phase II stormwater program. It knew that it needed to assist its communities with this component.
|
| Field work |
In 2003, the CCBH developed a program to assist its communities. This initially included an inventory of all designated MS4s located in a community and inspection and sampling of MS4s that were inventoried. The first year, the CCBH contracted with four communities to provide this service. Since then, it has dramatically increased the activities and services it offers. To date, it has inventoried 36 communities and contracted with another five for 2007. It has 45 contracts to provide continued inspection and sampling of MS4s on a yearly basis. It has developed a source tracking component to locate and identify the source of illicit discharges, as well as an outreach program that addresses the general public, businesses, and community officials on all components of the Phase II stormwater rules.
The CCBH’s stormwater program is now based regionally, and it allows Cuyahoga County to start looking at watershed-wide problems and across community boundaries. The information the CCBH is obtaining is now allowing for a more comprehensive look at the pollution sources affecting watersheds as a whole and not just individual communities. The CCBH is also working across county boundaries with other local health departments and across the state in providing guidance on the development of their stormwater programs.
Illicit Discharge Detection and Elimination Guidance Manual
The development of the manual came about over the last five years from the CCBH program and with input from other states’ guidance manuals. In 2001, during the Northeast Ohio Stormwater Task Force meetings, it was clear that a regional approach would be the best in dealing with illicit discharge issues. As the CCBH has developed its own stormwater program, it was instrumental to develop a guidance manual for the state on illicit discharge detection and elimination.
|
| Measuring an outfall |
The CCBH received a grant from the Ohio Environmental Education Fund through the Ohio EPA for 2006 to develop an IDDE Guidance Manual for the state of Ohio. The CCBH worked with a technical advisory committee made up of engineers, service directors, watershed organizations, and the Ohio EPA on the development of this manual. Committee members include Cathy Becker, North Olmsted assistant city engineer; Dan Bogoevsky of the Ohio EPA; Chris Courtney of C.W. Courtney Co.; Ken Dombrowski of Wade Trim; Kyle Dreyfuss-Wells of Chagrin River Watershed Partners; Jeff Duke of the Northeast Ohio Regional Sewer District; Jeff Filarski of Chagrin Valley Engineering Ltd.; Tom Krezcko, Beachwood staff engineer; Mary Maciejowski of the Northeast Ohio Regional Sewer District; Brian Mader of Steve Hovancsek and Associates; Pam Sawchyn and Harry Stark of the CCBH; Francine Toth of the Lake County General Health District; and Laura Travers of the CCBH.
This IDDE manual was developed using a variety of resources, primarily the CCBH’s stormwater program and the actual field proofing it has done in developing that program. The program has changed and been modified yearly based on evaluation at the end of every year, and the CCBH has been able to use other guidance manuals to strengthen its own protocols. These reference manuals include:
- The Ohio EPA Phase II Storm Water Rules and Regulations (3745-39-03)
- Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments by the Center of Watershed Protection and Robert Pitt, University of Alabama, 2004
- Illicit Discharge Detection and Elimination Manual: A Handbook for Municipalities by the New England Interstate Water Pollution Control Commission, 2003
- Guidelines and Standard Operating Procedures for Stormwater Phase II Communities in Maine
- USEPA Phase II Storm Water Rules and Regulations
- USEPA Phase II Fact Sheets on Illicit Discharge Detection and Elimination Program
All of these guidance documents were instrumental in the development of this IDDE manual for Ohio.
The IDDE Guidance Manual for the state of Ohio is contained on a CD-ROM and features a variety of information, including sections on the following topics:
- What is an MS4?
- What is an illicit discharge?
- How to map your MS4s
- Developing an inspection protocol and tools that can be used to assist in these inspections
- Source tracking for an illicit discharge
- How to eliminate an illicit discharge
- Outreach to officials, businesses, and the general public
- Evaluation of your program
The manual also has an appendix, which contains a model IDDE ordinance; a field guide and field forms; a quality-assurance management plan for developing your own water-quality sampling program; an outfall identification and stream naming convention; and information on the outfall database, which is included on the CD-ROM.
Along with the manual, the Northeast Ohio Regional Sewer District (NEORSD) provided the regional database that is used in northeast Ohio, available as part of this project. This IDDE database is available for use by communities in Ohio. The actual database and information about it is located within the appendix of the manual and can be obtained by contacting the CCBH. The CCBH owes special thanks to the NEORSD for providing the Illicit Discharge Detection and Elimination Manual Outfall Database and Users Manual for this project.
The IDDE manual stresses sound planning strategies within communities based on drainage areas. The initial work performed by any community is knowledge of its streams and drainage areas and any information that is available from sanitary and storm sewer maps. Once a strong knowledge is obtained in the office, then field work is required to document and locate all MS4 outfall locations.
The inventory of the MS4 outfall locations consists of a number of important attributes:
- Global positioning system coordinates of each outfall location
- Digital photographs (important for future inspections)
- Stream
- Watershed
- Community
- Location address (if available)
- Size of pipe
- Shape of pipe
- Condition of pipe
- Pipe material
- Height from outfall invert to stream flow level
- Side of stream outfall is located on (facing downstream)
- Outfall type (MS4, other, unknown, HSTS off-lot, HSTS on-lot)
Once all of the inventory fieldwork is completed and all data are entered into the outfall database, then a report can be generated from the database. These inventory sheets provide all of the information that is obtained on an outfall, including photos and a map showing the location of the outfall.
The inspection protocol established by a community is important for future illicit discharge detection and elimination. The manual stresses that inspections should occur after a minimum of 72 hours of no rainfall. The mapping component allows for easier tracking of these MS4 outfall locations and allows for a concise field component. During these inspections, it is noted if the outfall is flowing, if there is an odor present, and if there is any observable pollution at the outfall locations (oil sheens, wastewater, etc). One important aspect to remember is that just because flow is observed at an outfall during dry weather, this does not mean there is an illicit discharge present. Such flows can be attributed to many things, such as a water line break or high water table. Likewise, just because there is no flow, it does not mean there is not an illicit discharge. Illicit discharges can be intermittent and are not always flowing. That is why it is important to also observe and look for any observable pollution at the outfall location.
One tool that the CCBH uses if flow is observed is water sampling. The initial parameter tested for is fecal coliform to indicate whether wastewater is present within this flow. The infrastructure within many locations of Cuyahoga County is old, and there historically have been structural problems associated with sanitary and storm sewer systems as well as many cross-connections of sanitary flow going directly into storm sewer lines. This initial sampling process is the beginning of a long-term program for communities. It allows for prioritization in determining problems at outfall locations. The sampling results provide communities with water-quality standards as to the nature of bacterial contamination. Those MS4s with the highest levels of bacterial pollution will be addressed by the community and/or communities across city boundaries. This allows the communities to use their resources wisely by directing their illicit discharge detection program toward the MS4s with the most immediate impact on water quality and water-quality impairments.
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| Taking a sample |
The sampling program is a long-term process and protocol for communities. The CCBH recommends, if communities can afford it, performing dry-weather inspections and sampling annually so communities can obtain the necessary baseline data on their MS4s. This process allows communities to see long-term trends in outfall flows and water-quality sampling results. It provides communities with the necessary information for the most effective utilization of resources to repair these illicit sources of pollution within their MS4s.
Once an illicit discharge is located at an outfall location, then source tracking is needed to start to identify where the illicit discharge is emanating from. The city starts to trace the illicit discharge upstream, beginning at the outfall. The manual includes the following items that should be performed to help isolate the source of the illicit discharge:
- Visual Inspection of storm sewer system
- Start at outfall
- Check upstream manholes to identify where flow may be coming from. Additional samples may be needed to isolate/prioritize areas.
Utilize available storm sewer mapping to assist in upstream tracing
Notes to assist in isolation of sources
Sanitary blockages (usually higher flows)
Cross-connects (usually much lower flows)
- Narrow down areas and potential sources
- Isolate an area
- Try to isolate sources even further
Perform dye-testing of connections (storm and sanitary)
Perform testing of sanitary sewers for suspect infiltration/inflow
Perform televising as necessary
Discuss with homeowner/occupant
Once the source is detected, then the elimination of these discharges is required. The development of the illicit discharge ordinance is vital to this component. The model ordinance that is provided in this manual provides the needed requirements to detect and eliminate these discharges from entering MS4s.
It is also important to educate the general public, community officials, and businesses on this component of Phase II. For this program to be successful for communities, it is important that there is an educational aspect that discusses the importance of stormwater and the impact it has on the surface waters of the state. Educating all on what an illicit discharge is, why it is important to eliminate them, and how they can impact public health and our water-quality resources can make our jobs a little easier. The general public can assist by letting communities know when they see something at an outfall, and it may help in the elimination of these sources.
The manual also discusses the need for an evaluation of each program once a year. This is an important component for all to undertake. To effectively evaluate a program, a number of questions need to be asked and analyzed.
- Is the program effective? Need to reassess the program by determining what has been achieved.
- Cost-effectiveness: What aspects of the program had the highest quality of effectiveness in relationship to cost?
- Number of illicit discharges detected utilizing each detection method Tracing program: What techniques were used, were these methods successful, and what techniques that were not used would be beneficial for next year?
- How many illicit sources were identified and eliminated?
The development of a tracking system is also vital for any IDDE program. The data and information that are obtained need to be easily tracked, reported, and responded to. A tracking system enables the community to measure the IDDE program effectiveness and assists with the evaluation of the overall IDDE program.
This IDDE guidance manual is being provided to the 467 Phase II communities in Ohio through a series of informational meetings located throughout the state. The CCBH is making the CD-ROM containing the manual and database available for free to all communities as part of this project in the hopes of assisting other communities in meeting their Phase II stormwater illicit discharge detection and elimination requirements set forth in their stormwater management plans.
For additional information regarding the manual, the IDDE database, or the CCBH’s stormwater program, please contact Harry Stark, RS, MPA, at 216-201-2001, ext. 1205, or e-mail him at hstark@ccbh.net.