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Communities join forces to find and fix illicit discharges. By Harry Stark
The Cuyahoga County Board of Health (CCBH) Watershed Protection Unit was developed and designed to protect public health and our water-quality resources from the impact of point-source and nonpoint-source pollution. The Watershed Protection Unit stresses the use of watershed-based planning within the CCBH as well as collaborative efforts with partnering agencies. This unit has been evolving and expanding over the last several years and now includes a variety of activities to assist our communities and our partners. These activities include all water-quality programs as well as educational outreach and public involvement programs. The 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. These major watersheds are impacted by both point-source and nonpoint-source pollution. Sources of point-source pollution are often continuous and can typically be identified, minimized, and even eliminated. Sources of nonpoint-source pollution are often very difficult to trace and identify. They are widespread and often intermittent, such as runoff from streets and parking lots, agricultural fields, home lawns, construction sites, and household sewage treatment systems (HSTSs). Contaminants in nonpoint-source pollution include sediment, nutrients, heavy metals, salts, toxic chemicals, and pathogens. These pollutants have the potential to adversely affect both ground and surface waters. CCBH Water-Quality
Background 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 uses the best available technology and exhibits a true concern for the environment. In 1936, the first sewage regulations were adopted. These initial rules dealt only with septic tank sizing. These rules soon were amended to include filter-bed sizing guidelines and incorporated minimum lot-size requirements. In 1974, the first State of Ohio sewage regulations became effective. These regulations were combined with existing county regulations and implemented in 1976. These current state sewage regulations have not been revised since 1977. These rules allow for off-lot discharge of treated wastewater from HSTSs into approved locations, such as running stream and storm sewers, when all means of installing on-lot HSTSs are exhausted. In 1978, the Ohio EPA and the CCBH entered into an agreement that involved policies on subdivision approval. Both organizations agreed that sewage systems that generate off-lot discharge would not be permitted on newly approved subdivision parcels. The early 1980s brought the approval of experimental sewage treatment systems. In 1987, the CCBH clearly defined sewage system evaluation procedures and implemented a “point-of-sale” inspection program. Along with nuisance investigations, sanitarians could now evaluate sewage systems as requested by property owners. These evaluations were in demand as lending institutions required detailed information on sewage systems and their status when properties were sold. This allowed the CCBH to gather data on existing sewage disposal system performance. These evaluations also lead to the repair and replacement of many failing systems throughout the General Health District.
In 1992, the CCBH established its current HSTS Water Pollution Control Program. A broad watershed-based approach was now starting to be utilized when investigating nuisances and identifying individual pollution sources. Sewage system evaluation results could be complemented by water-quality sampling data. In 1993, appendices to the CCBH Sewage Disposal Rules were adopted and included requirements regarding septic system abandonment, aeration system design and maintenance, and the initiation of an operation and maintenance (O&M) program. In the fall of 1993, the CCBH became one of the first local health departments to launch a Household Sewage System Operation and Maintenance Program, which consists of three fundamental activities: HSTS evaluations on a routine basis (once every five years), water-quality sampling, and educational outreach on care and maintenance of systems. 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, who can then determine whether a sanitary sewer installation is practical in a specific area. If it is not, CCBH sanitarians can then proceed with sewage system repair or replacement as necessary to eliminate individual failing systems and the resulting public health concerns. Sanitarians also conduct numerous public information seminars to better educate homeowners using HSTSs. In 2004, the CCBH received a Section 319 grant from the Ohio EPA for the Rocky River Watershed. This grant project allows for the installation of on-lot HSTSs to replace failing off-lot discharging HSTSs within the watershed. The grant has allowed the CCBH to modify its existing mound regulations to allow no pretreatment and to also look at more innovative on-lot systems, such as drip irrigation systems. The CCBH’s water-quality program also has changed over the years. The focus of this program is now an overall watershed-based approach when dealing with water-quality issues. Activities within this program include:
This program allows for the chemical, physical, and biological monitoring of water quality in our watersheds. The information collected from this program has documented the need for the board’s O&M program for household sewage treatment systems. To date, thousands of water-quality samples have been collected. Likewise, in 1999, more than 50 permanent water-quality monitoring sites have been established within the various watersheds in Cuyahoga County. These sites are monitored and sampled every year. The data are used to obtain general baseline conditions and to identify problem areas potentially being impacted by sources of water pollution. The CCBH conducts extensive surveys of specific watersheds. These activities include:
Biological monitoring is an effective means of identifying water-quality problems. Aquatic biological communities reflect overall ecological integrity (chemical, physical, and biological integrity). These communities change in response to a wide variety of pollutants and to the cumulative impacts of those pollutants. Biological monitoring is utilized for detecting the health of aquatic environments and assessing the relative severity of the pollution impacts. Another component of the water-quality program includes conducting physical assessments, including QHEI and HHEI studies. Some of this work is performed through a summer internship program. Specific project areas are chosen each year and studied by an intern, and a report is developed for each specific location. The data are combined with existing water-quality data and shared with other appropriate agencies.
Headwater streams are the small swales, creeks, and streams that are the origin of most rivers. These small creeks join together to form larger streams and rivers or run directly into larger streams and lakes. The HHEI is a method of studying the smallest swales and streams that are the origin of larger water bodies in the state. The chemical, physical, and biological qualities of larger streams and lakes have a close connection to the overall health of headwater streams and their watersheds. The QHEI is designed to provide a measure of habitat that generally corresponds to physical factors that affect fish communities and other aquatic life. In 2002, the CCBH initiated a regional stormwater program to assist our 55 regulated Phase II stormwater communities. On March 10, 2003, the US and Ohio EPA Phase II stormwater regulations went into effect, requiring designated communities to develop and implement stormwater management plans. This program includes Phase II’s 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, several task force groups were created to aid Phase II–regulated communities in developing their stormwater management plans. These task groups comprised various watershed organizations, health departments, and planning agencies. Guidance documents and educational outreach programs were developed to provide these communities with the information and tools they would need. In the CCBH’s jurisdiction, 55 communities are designated Phase II communities. These cities are impacted greatly by the third minimum control measure, illicit discharge detection and elimination, because of the large number of discharging HSTSs within these communities. The 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, communities have five years in which to identify and assess all HSTSs located within their jurisdiction. Because of the CCBH’s O&M program, this information is already available for these communities. The locations of all illicit HSTSs are available through our database system. The assessment of these systems has also been performed over the last 10 years through the evaluation component of the O&M program. A map can be generated for each community showing the locations of these HSTSs. Information as to HSTS performance can also be generated through a query of the database. These communities are appreciative of the CCBH’s overall O&M program and the work we have done over the last 10 years. The CCBH’s water-quality program has now enabled our department to develop memoranda of understanding (MOUs) with our Phase II–designated communities to perform specific activities, including inventorying of MS4 outfall locations located within communities, conducting dry-weather screenings of MS4 outfall locations, sampling of dry-weather flows from MS4 outfall locations, performing source tracking for the detection of illicit discharges, carrying out public education and public involvement outreach efforts, and implementing good housekeeping programs. Watershed-Based Approach
to Stormwater By developing MOUs with over 35 communities within our jurisdiction, the CCBH is now using a more comprehensive watershed-based approach when dealing with stormwater issues. The CCBH uses sound planning strategies within these communities based on drainage areas. The initial work performed in a community is the inventory of all MS4 outfall locations. Information gathered during an inventory consists of global positioning system coordinates of each outfall location, digital photographs, location address, size of pipe, condition of pipe, pipe material, height from outfall invert to stream flow level, side of stream on which the outfall is located (facing downstream), and outfall type (MS4, other, unknown, HSTS off-lot, HSTS on-lot). Once all the inventory fieldwork is completed and all data have been entered into the outfall database, a report is provided to each community, consisting of a CD-ROM with the outfall database, a hard-copy report with an inventory sheet for each outfall, and an aerial map for each community. This map utilizes the 2000 aerial photographs for the county and shows all surface waters within a community and surrounding communities. The designated MS4 outfall locations are shown on these maps by highlighted points and corresponding outfall IDs. The mapping program can also provide watershed maps with the same information. It allows for sound planning when dealing with watersheds—both main and subwatersheds—and provides for a clear planning strategy when water pollution problems are identified in a particular location. Once an inventory is completed for a community, the CCBH performs dry-weather inspections of the outfall locations. These inspections occur after a minimum of 48 hours of no rainfall. The mapping component allows for easier tracking of these MS4 outfall locations and a concise field component. Inspections occur within subwatersheds and across community boundaries. During 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 (such as oil sheens or wastewater). If flow is observed, a water sample is taken and is analyzed by the Cuyahoga County sanitary engineer’s laboratory. The initial parameter tested for is fecal coliform to indicate whether wastewater is present within the flow. The infrastructure within many locations of Cuyahoga County is old, and there historically have been structural problems associated within these sanitary and storm sewer systems as well as many cross-connections causing sanitary sewers to flow directly into storm sewer lines. This initial sampling process is the beginning of a long-term program for our communities, allowing them to prioritize problems at outfall locations. The sampling results provide communities with water-quality standards as to the nature of bacterial contamination. MS4s with the highest levels of bacterial pollution will be addressed by the community and/or communities across city boundaries, allowing the communities to use their resources wisely by directing their illicit discharge detection program to the MS4s with the most immediate impact on water quality. The dry-weather inspections and sampling will be conducted annually to allow communities to obtain the necessary baseline data on their MS4s. Communities will be able to see long-term trends in outfall flows and water-quality sampling results. The inspection and sampling process will provide communities with the necessary information for the most effective use of resources to repair these illicit sources of pollution within their MS4s. Once an illicit discharge is located at an outfall location, the CCBH also assists communities in locating the source of these illicit discharges. This involves upstream tracing. The CCBH and the city begin to trace the illicit discharge upstream—beginning at the outfall. The following actions help isolate the source of the illicit discharge: Visual Inspection of Storm Sewer System 1. Start at outfall.
3. Narrow down areas and potential sources
Education and Outreach
Activities The CCBH will implement and provide all training of a volunteer monitoring program for both schoolchildren and adults. This program will be designed per water body being monitored. The board will determine the best locations for these monitoring programs and work with the community or communities within the watershed. Stream cleanups will be coordinated in a community or watershed. The storm drain stenciling and markers will be coordinated by the CCBH, including the actual installation or coordination of the placement of markers on street basins. The CCBH also works with communities and watershed organizations by assisting in the design and printing of a community-based and watershed-based informational brochure, as well as the development of fact sheets on nonpoint-source pollution and stream stewardship. The CCBH is now undertaking a leadership role by providing the abovementioned services to communities located in adjacent counties and in locations in Ohio. The work in adjacent counties and communities adds support and credence to a true watershed-based approach in these water-quality issues. It is enabling our organization to train other local agencies in providing these services for long-term collaborative and coordination approaches to water-quality studies. The Board of Health’s Watershed Protection Unit also enables numerous water-quality programs to be used to address stormwater issues. Stormwater discharges affect our public bathing beaches. During rain events, the bacterial levels at the Lake Erie public beaches peak and cause warnings for those swimming in these locations. The Beach Program is now using microbial source tracking in locations with high bacterial levels on a consistent basis. This source tracking process will provide data as to the source of the bacterial contamination: human or animal, and if animal, what type. This will allow local communities to address these bacterial levels by targeting the specific group responsible for these pollution sources. In the future, we are hoping that the source tracking process will assist many communities when dealing with illicit discharge flows from their MS4s. The HSTSs and semi-public O&M programs provide consistent and reliable data for storm sewer issues by providing locations of those systems in failure or those that are discharging off-lot. This allows for effective community and watershed planning when looking at infrastructure extensions and installations. The water-quality program, along with the stream assessments and permanent sampling program, allows for identifying those areas with high levels of water-quality impairments and pollution sources. When using all of these programmatic data, and tying these data together based on watersheds, communities can begin to look at the consistent hot spots located throughout the watersheds. In many cases, communities are working together to solve these issues, while others are relying on internal cooperation to ensure they correct their own problems. It is the long-term hope of the Cuyahoga County Board of Health that true collaborative efforts can be made throughout northeast Ohio to solve the many existing water-quality issues. By starting a true watershed-based approach in dealing with water-quality issues, we are encouraged that communities and counties can begin to work together to solve these issues. After all, water quality is essential to public health, our natural environment, and economic development. Harry Stark, RS, MPA, is supervisor of the CCBH in Cleveland, OH. SW July/August 2005
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