Phase II Stormwater Illicit Discharge Detection and Elimination Program

State: OH Type: Model Practice Year: 2011

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On March 10, 2003, the U.S. EPA and Ohio EPA Phase II Stormwater regulations went into effect. These regulations required designated Phase II communities to develop and implement a stormwater management plan. This program is comprised of six minimum control measures (MCM). The Cuyahoga County Board of Health (CCBH) focuses its efforts on MCM 3: Illicit Discharge Detection and Elimination (IDDE). The CCBH determined that this was a relevant public health issue, for which it initiated a regional program to assist over 50 regulated Phase II communities in Cuyahoga County and Northeast Ohio. CCBH’s program began in March 2002, just prior to the effective date of the regulations. The overall goal of the CCBH Stormwater Program is to assist Phase II communities with their IDDE program, stormwater management plan goals, and in meeting OEPA permit requirements.

This includes assisting communities in developing and implementing their programs, which is accomplished through completing an initial inventory of all Municipal Separate Storm Sewer System (MS4) outfall locations within the community. Dry weather screening inspections are conducted at all MS4 outfall locations after 72 hours of no rainfall. Water quality monitoring is performed at outfall locations that are observed to be flowing during dry weather conditions. Monitoring consists of utilizing water quality meters to measure pH, conductivity, dissolved oxygen, temperature, and turbidity; in addition, water samples are analyzed for E. coli bacteria. The data obtained from monitoring allows communities to prioritize their MS4 dry weather flows and work towards remediating the problems through their IDDE Ordinance. Communities receive an annual report of their data, which is included in their OEPA Annual Report. Guidance is provided to communities in writing their IDDE management plan, the purpose of which is to find, fix, and prevent illicit discharges, and to develop a series of techniques to meet specific objectives. Discharges from MS4s often include waste and wastewater from non-stormwater sources, including illicit discharges. These discharges enter an MS4 system through various means; the result of which is untreated discharges that contribute to high levels of pollutants, such as bacteria, oil and grease, heavy metals, solvents, nutrients, and viruses. Pollutants from these discharges degrade water quality and threaten aquatic ecosystems and human health.

The objective of the IDDE Program is to allow regulators, operators, and citizens to gain awareness of the types of discharges entering into water bodies. Start-up and in-kind costs are low considering the equipment that must be purchased in order to begin. Necessary equipment consists of existing paper maps, field survey sheets, digital camera, gps unit, waders, safety vests, and coolers for inventory and sampling of MS4 outfalls. Other factors to consider as part of the implementation include expenditures related to full-time staff, summer temporary help, staff fringe benefits, mileage, and bacteriological sampling analysis costs. The primary funding for the Stormwater Program is obtained through a Memorandum of Understanding (MOU) between the CCBH and the individual communities. The MOU states exactly which activities the CCBH is going to perform in the community, which may be a combination of any of the following: MS4 inventory, dry weather screening, sampling of a specified number of MS4 outfalls, source tracking, public involvement and public education, and pollution prevention training. After several years of community MOUs, the CCBH was able to effectively demonstrate the efficiency and quality of its program to the communities it serves. Specific factors that led to the outcomes and overall successes of this practice relate to the evaluation of the IDDE Program. Some contributing factors include: (1) The establishment of partnerships with communities, watershed organizations, and external agencies, (2) The devel

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Cuyahoga County Board of Health
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Phase II Stormwater Illicit Discharge Detection and Elimination Program
On March 10, 2003, the U.S. EPA and Ohio EPA Phase II Stormwater regulations went into effect. These regulations required designated Phase II communities to develop and implement a stormwater management plan. This program is comprised of six minimum control measures (MCM). The Cuyahoga County Board of Health (CCBH) focuses its efforts on MCM 3: Illicit Discharge Detection and Elimination (IDDE). The CCBH determined that this was a relevant public health issue, for which it initiated a regional program to assist over 50 regulated Phase II communities in Cuyahoga County and Northeast Ohio. CCBH’s program began in March 2002, just prior to the effective date of the regulations. The overall goal of the CCBH Stormwater Program is to assist Phase II communities with their IDDE program, stormwater management plan goals, and in meeting OEPA permit requirements. This includes assisting communities in developing and implementing their programs, which is accomplished through completing an initial inventory of all Municipal Separate Storm Sewer System (MS4) outfall locations within the community. Dry weather screening inspections are conducted at all MS4 outfall locations after 72 hours of no rainfall. Water quality monitoring is performed at outfall locations that are observed to be flowing during dry weather conditions. Monitoring consists of utilizing water quality meters to measure pH, conductivity, dissolved oxygen, temperature, and turbidity; in addition, water samples are analyzed for E. coli bacteria. The data obtained from monitoring allows communities to prioritize their MS4 dry weather flows and work towards remediating the problems through their IDDE Ordinance. Communities receive an annual report of their data, which is included in their OEPA Annual Report. Guidance is provided to communities in writing their IDDE management plan, the purpose of which is to find, fix, and prevent illicit discharges, and to develop a series of techniques to meet specific objectives. Discharges from MS4s often include waste and wastewater from non-stormwater sources, including illicit discharges. These discharges enter an MS4 system through various means; the result of which is untreated discharges that contribute to high levels of pollutants, such as bacteria, oil and grease, heavy metals, solvents, nutrients, and viruses. Pollutants from these discharges degrade water quality and threaten aquatic ecosystems and human health. The objective of the IDDE Program is to allow regulators, operators, and citizens to gain awareness of the types of discharges entering into water bodies. Start-up and in-kind costs are low considering the equipment that must be purchased in order to begin. Necessary equipment consists of existing paper maps, field survey sheets, digital camera, gps unit, waders, safety vests, and coolers for inventory and sampling of MS4 outfalls. Other factors to consider as part of the implementation include expenditures related to full-time staff, summer temporary help, staff fringe benefits, mileage, and bacteriological sampling analysis costs. The primary funding for the Stormwater Program is obtained through a Memorandum of Understanding (MOU) between the CCBH and the individual communities. The MOU states exactly which activities the CCBH is going to perform in the community, which may be a combination of any of the following: MS4 inventory, dry weather screening, sampling of a specified number of MS4 outfalls, source tracking, public involvement and public education, and pollution prevention training. After several years of community MOUs, the CCBH was able to effectively demonstrate the efficiency and quality of its program to the communities it serves. Specific factors that led to the outcomes and overall successes of this practice relate to the evaluation of the IDDE Program. Some contributing factors include: (1) The establishment of partnerships with communities, watershed organizations, and external agencies, (2) The devel
According to the U.S. EPA, the top causes of impairment to our water bodies include siltation, nutrients, debris, bacteria, metals, and oxygen-depleting substances. Polluted stormwater runoff and runoff from construction sites are considered leading sources of impairment. A significant portion of these dry weather flows are from illicit discharges and connections to the MS4 system. Possible illicit connections of sanitary sewers can result in bacteria entering into the storm sewer system. Stormwater runoff transports these and other harmful pollutants through the storm sewer system and discharges them, untreated, into waterways. Discharges from MS4s often include waste and wastewater from non-stormwater sources, including illicit discharges. These discharges can enter an MS4 system through various means; the result of which is untreated discharges that contribute to high levels of pollutants, such as bacteria, oil and grease, heavy metals, solvents, nutrients, and viruses. Pollutants from these discharges degrade water quality and threaten aquatic ecosystems and human health. The objective of the IDDE Program is to allow regulators, operators, and citizens to gain awareness of the types of discharges entering into their water bodies. Phase II regulations are intended to reduce adverse impacts to water quality and aquatic habitat by utilizing control methods on unregulated sources of stormwater discharges. These unregulated discharges have the greatest chance of causing continued environmental depletion. When left unmonitored, these discharges could possibly result in fish kills, loss of wildlife habitats and aesthetic value, contamination of drinking water supplies and recreational waterways, thus threatening public health. In Cuyahoga County, all major watersheds and tributaries empty into Lake Erie, which is the location of numerous recreational bathing beaches. As communities in Cuyahoga County continue to develop and redevelop creating additional impervious surfaces, increased volumes of stormwater and non-point source pollution contribute to reduced water quality throughout the watersheds and Lake Erie. Poor water quality results from bacteria and other pollutants on the landscape washing into waterways during acute rain events, thus contributing to elevated bacteria levels.
Agency Community RolesThe CCBH role in the practice was based on the need for community guidance and experience related to EPA stormwater requirements. The CCBH implemented its stormwater program in March 2002 to assist communities in this need. Several stormwater task force groups were created in Northeast Ohio to aid Phase II regulated communities in developing their stormwater management plans. These groups consisted of various watershed organizations, health departments, soil and water conservation agencies, planning agencies, and residents. Guidance documents, along with education and outreach programs were developed to provide communities with the information and tools needed to establish and successfully run their programs. One of the guidance documents developed was created by the Cuyahoga County Board of Health entitled “Illicit Discharge Detection and Elimination Manual: A Guidance Manual for Municipalities in the State of Ohio.” The IDDE Manual Project was supported through the Ohio EPA Environmental Education Fund grant. This manual was designed to assist communities in developing an Illicit Discharge Detection and Elimination Program for finding and eliminating sources of stormwater pollution. The utilization of watershed based planning is emphasized within the CCBH as well as in collaborative efforts with communities and partnering agencies. Costs and ExpendituresOn March 10, 2003, the U.S. EPA and Ohio EPA Phase II Stormwater regulations went into effect. These regulations required designated Phase II communities to develop and implement a stormwater management plan. This program is comprised of six minimum control measures (MCM). The Cuyahoga County Board of Health (CCBH) focuses its efforts on MCM 3: Illicit Discharge Detection and Elimination (IDDE). The CCBH determined that this was a relevant public health issue, for which it initiated a regional program to assist over 50 regulated Phase II communities in Cuyahoga County and Northeast Ohio. CCBH’s program began in March 2002, just prior to the effective date of the regulations. The overall goal of the CCBH Stormwater Program is to assist Phase II communities with their IDDE program, stormwater management plan goals, and in meeting OEPA permit requirements. This includes assisting communities in developing and implementing their programs, which is accomplished through completing an initial inventory of all Municipal Separate Storm Sewer System (MS4) outfall locations within the community. Dry weather screening inspections are conducted at all MS4 outfall locations after 72 hours of no rainfall. Water quality monitoring is performed at outfall locations that are observed to be flowing during dry weather conditions. Monitoring consists of utilizing water quality meters to measure pH, conductivity, dissolved oxygen, temperature, and turbidity; in addition, water samples are analyzed for E. coli bacteria. The data obtained from monitoring allows communities to prioritize their MS4 dry weather flows and work towards remediating the problems through their IDDE Ordinance.Communities receive an annual report of their data, which is included in their OEPA Annual Report. Guidance is provided to communities in writing their IDDE management plan, the purpose of which is to find, fix, and prevent illicit discharges, and to develop a series of techniques to meet specific objectives. Discharges from MS4s often include waste and wastewater from non-stormwater sources, including illicit discharges. These discharges enter an MS4 system through various means; the result of which is untreated discharges that contribute to high levels of pollutants, such as bacteria, oil and grease, heavy metals, solvents, nutrients, and viruses. Pollutants from these discharges degrade water quality and threaten aquatic ecosystems and human health. The objective of the IDDE Program is to allow regulators, operators, and citizens to gain awareness of the types of discharges entering into water bodies. Specific factors that led to the outcomes and overall successes of this practice relate to the evaluation of the IDDE Program. Some contributing factors include: (1) The establishment of partnerships with communities, watershed organizations, and external agencies, (2) The development and creation of a guidance document by CCBH entitled “Illicit Discharge Detection and Elimination Manual: A Guidance Manual for Municipalities in the State of Ohio.” This manual was designed to assist communities in developing an IDDE Program for finding and eliminating sources of pollution, (3) Through the MOU process the CCBH has developed a sustainable funding mechanism to pay for full-time and summer temporary staff with their IDDE programs, (4) Develop a cost effective model to assist communities in meeting Phase II requirements, (5) The data collected in each community is used to improve overall public health through assisting communities with eliminating illicit discharges and household sewage treatment systems, and (6) Development of the stormwater database to collect analytical data on approximately 5,000 MS4 outfalls and source tracking information in over 50 communities. The CCBH contributes its success from working directly with communities, maintaining strong partnerships, and providing efficient and quality services and products. ImplementationThe CCBH initiated a regional program to assist over 50 regulated Phase II Stormwater communities in Cuyahoga County and Northeast Ohio in 2002. On March 10, 2003, the U.S. EPA and Ohio EPA Phase II Stormwater regulations went into effect. These regulations required designated Phase II communities to develop and implement a stormwater management plan. This program is comprised of six minimum control measures: (1) Public Education and Outreach, (2) Public Involvement and Participation, (3) Illicit Discharge Detection and Elimination (IDDE), (4) Construction Site Runoff Control, (5) Post Construction Management, and (6) Pollution Prevention and Good Housekeeping for Municipal Operations. The CCBH determined that this was a relevant public health issue for communities and focuses its efforts on assisting communities with their IDDE programs and meeting the OEPA requirements. The CCBH worked with communities to implement minimum control measure (3) Illicit Discharge Detection and Elimination. This includes: a complete MS4 outfall inventory and mapping of each outfall. Dry weather screening, which is required to be performed at all known MS4 locations and consists of a visual inspection of the outfall location. Outfall samples are collected for the analysis of fecal coliform bacteria in accordance with the CCBH’s Quality Assurance Management Plan. Field data is collected for the pertinent parameters, which are then entered into the Comprehensive Outfall Database. This data is further utilized for the generation of individual community reports, which communities utilize for annual reporting to the Ohio EPA for their Phase II Stormwater requirements. Along with these activities the CCBH also performs source tracking to assist communities in ultimately eliminating these illicit discharges. The timeframe for carrying out these tasks is completed on an annual basis for communities. This includes dry weather screenings and outfall sampling for the analysis of fecal coliform bacteria in accordance with the CCBH’s Quality Assurance Management Plan. This data is further utilized for the generation of individual community reports, which communities utilize for annual reporting to the Ohio EPA for their Phase II Stormwater requirements. Along with these activities the CCBH also performs source tracking to assist communities in ultimately eliminating these illicit discharges. The above mentioned activities are performed on a yearly basis in contract communities. The CCBH meets with each community or stakeholder to discuss dry weather screening, sampling, and source tracking results every year. The action steps are then determined by the community through their IDDE Ordinance.
The CCBH strives to assist communities in reaching their IDDE stormwater management plan goals by providing accurate and credible information on an annual basis. The CCBH has established strong partnerships with more than 50 Phase II communities. Through those partnerships a guidance document was created by the CCBH entitled “Illicit Discharge Detection and Elimination Manual: A Guidance Manual for Municipalities in the State of Ohio.” This manual was created to assist communities in developing an IDDE program for finding and eliminating sources of stormwater pollution. Through partnerships with stakeholders the CCBH has developed a sustainable funding source to pay for staff thru continuous renewals of community MOU’s to assist communities with their IDDE programs. Through the MOU process the CCBH has developed a cost effective model to assist communities in meeting Phase II requirements. Data collected in each community is used to improve overall public health and assist communities in reaching their IDDE stormwater management plan goals. The data includes information pertaining to MS4 dry weather screenings, water quality sampling, and source tracking data. The information is collected by full-time staff and summer temporary help on an annual basis. Annually, staff inspects approximately 5,000 MS4 outfalls and collect approximately 800 bacteriological samples in over 50 communities. Sample results are dropped off at an accredited laboratory to be analyzed for E.coli bacteria. Once analyzed, sample results are then provided to the stormwater program manager. Dry weather screening inspections, water quality sampling data, and source tracking findings are entered into the Comprehensive Stormwater Outfall Database. The database is utilized to run various queries and create reports for communities for insertion in their Ohio EPA Annual Report. Data provided to communities is essential in determining the next step in eliminating illicit discharges considered to be causing a public health nuisance and to bring awareness of pollutants entering into waterways. During the evaluation process the CCBH determined that there currently is no written stakeholder evaluation of the stormwater program. Even though there is not a formal written evaluation, the program manager meets with stakeholders throughout the year to discuss programmatic activities performed and again at the end of each calendar. During the annual meeting the CCBH discusses the community annual report, which includes dry weather screening inspections, water quality sample results, and information pertaining to source tracking findings. During the meeting, the CCBH gains feedback on all aspects of the program and possible modifications that could be made to improve services to the community. Stakeholders provide input during annual meetings and through regular conversations with the program manager. A measurable result of the evaluation process is consistency in continuing to obtain yearly community MOU contracts. Another result of the evaluation process is the fulfillment of contractual obligations through completion of the specified number of dry weather screenings, water quality samples collected, and the performance of source tracking in each community. The data collected is incorporated into an annual report provided to each stakeholder for evaluation. The CCBH is in the process of creating and implementing an evaluation tool for stakeholders to complete on an annual basis, in order to gauge the efficiency and effectiveness of the stormwater program. The stormwater program manager initially receives verbal evaluation results from not only stakeholders, but staff on how to improve and maintain standards within the program. Maintaining these standards is important, since the CCBH strives to provide communities with credible data. Ohio EPA reviews the CCBH’s annual reports when completing community audits of their stormwater program. E
The OEPA Phase II Stormwater Program requires communities to get an NPDES permit, which has a five year permit cycle. This means the program is always changing and evolving so communities will need to find new and innovative ways of performing those activities listed in the permit requirements. The CCBH is for most communities the most economical choice to perform those activities and assist the communities in meeting those permit standards. Currently the funding procedures in place have provided stakeholders with the most sensible way to continue to establish and build their IDDE Program. Stakeholder involvement and commitment is secured through the yearly MOU renewal process with the CCBH. At all times new funding opportunities are continuously sought out to reduce and offset the in-kind cost to the CCBH program. The primary funding for the Stormwater Program is secured through a Memorandum of Understanding (MOU) between the CCBH and the various communities in and around Cuyahoga County. The MOU can vary in length, meaning that most communities prefer to sign a multi-year contract for services. This avoids having to sign a new MOU each year of the NPDES permit cycle. Through the MOU process, it spells out exactly what activities the CCBH is going to perform in the community, which can be a combination of any of the following: MS4 inventory, dry weather screening, sampling of a specified number of MS4 outfalls, source tracking, public involvement and public education, school-aged outreach, and good housekeeping training.
 
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