Dean Tuomari Wayne County Department of Public Services Water Quality Management Division,

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1 Dean Tuomari Wayne County Department of Public Services Water Quality Management Division, Michigan Water Environment Association Annual Industrial Pretreatment Program Seminar September 26, 2013

2 Introduction Review Elements of the Municipal Separated Storm Sewer System(MS4) Permit Application MS4-Application_40260_7.pdf Permit Application Elements Storm Water Management Program the eight elements Eighty plus procedures required Illicit Discharge Elimination Program Case Histories How IPP staff can be the eyes and ears Accomplishmnets

3 Permit Application Elements Define the regulated urbanized areas as defined by the 2000 Census

4 Permit Application Elements Identify discharges to waters of the State Identify discharge points Identify the point where your system discharges to another jurisdiction Agreements between jurisdictions on follow up is allowable Note- open county drains are considered Waters of the State

5 Permit Application Elements List nested jurisdictions in the application E.g. school districts Community/ies under a county permit Provide name and general description of nested jurisdictions

6 Permit Element Stormwater Management Program Eight Elements - The main objectives of the permit 1. Enforcement Response Procedure 2. Public Participation Program 3. Public Education Program 4. Construction Stormwater Runoff Program 5. Post Construction Stormwater Runoff Program 6. Pollution Prevention and Good Housekeeping Program 7. Total Maximum Daily Load (TMDL) Implementation Program. Illicit Discharge Elimination Program

7 Stormwater Management Program 1. Enforcement Response Procedure Response to violation of permitees ordinances Contain the ordinance/s Method for tracking non-compliance Date/location Nature of the violation Enforcement response used Schedule for compliance Date violation was resolved

8 Stormwater Management Program 2. Public Participation Plan If it a collaborative effort with watershed or regional partners identify, the collaborative activities Procedures on how the public participates in the development of the Stormwater Management Plan How is the Plan made available for public review/comment? How the public is invited to participate in implementation and review?

9 Stormwater Management Program 3. Public Education Program (PEP) Provide procedure to assess high priority community issues and target the issues to reduce pollutants in stormwater Identify /prioritize PEP topics based on assessment of community high priority issues. Eleven PEP topics in the permit application For each topic provide Target audience Key message Delivery mechanism and frequency

10 Stormwater Management Program 3. Public Education Program (PEP) Topics include: Promote public stewardship of watersheds Educate the public on illicit discharges Education on importance of green infrastructure Education on the proper maintenance of septic systems Promote methods for proper riparian lands to protect water quality Identify /educate commercial, industrial, institutional entities that may contribute pollutants to stormwater Provide a procedure for evaluating effectiveness of the PEP Assess changes in public awareness

11 Stormwater Management Program 4. Construction Stormwater Runoff Program Is the permittee a Part 91 agency (Soil Erosion)? If not list the agency it relies on for Part 91 agency Procedure for notifying the Part 91 agency when pollutant from a construction site enters MS4. Procedure to notify MDEQ when pollutant from a construction site enters MS4. Procedure to notify Part 91 agency of construction activity greater than one acre.

12 Stormwater Management Program 5. Post Construction Stormwater Runoff Program Ordinance for post construction runoff Water quality performance standard Treat first inch of runoff from entire site Treat runoff from 90% of all runoff producing storms Source of rainfall data Channel Protection Performance Standard Site runoff does not exceed pre development rate and volume up to 2 year 24 hour storm

13 Stormwater Management Program 5. Post Construction Stormwater Runoff Program Site specific requirements (new and redevelopment) Infiltration BMP should not exaberate current groundwater contamination issues. Do BMPs consider potential pollutants from hotspots (E.g. gas stations, auto recyclers, scrap yards, etc) Off-Site Mitigation/Payment in Lieu Programs Is off-site mitigation allowed for redevelopment? Does ordinance allow Payment in Lieu? Fee paid to permitee for stormwater management project Same jurisdiction, watershed, sewershed

14 Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Municipal Facility and Structural Stormwater Control Inventory Updated inventory of municipal facilities and stormwater structures Municipal facilities Police/Fire stations, vehicle yards, public parking lots, animal control building Structural storm water controls e.g. rain gardens, catch basins, constructed wetlands, pump stations Up-to-date maps with locations for items above Procedure for updating the inventory

15 Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Maintenance Activities for Structural Stormwater Controls Procedure for prioritizing routine inspection, maintenance and cleaning of catch basins Revision procedure for updating priority areas.

16 Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Location of impervious surfaces E.g. streets, parking lots Identify street sweeping methods Seasonal issues e.g. leaf pickup Describe dewatering and disposal of waste material Management of vegetated properties Certified pest control applicator Employee training Employee training program for staff that perform pollution prevention and good house keeping

17 Stormwater Management Program 6. Pollution Prevention and Good Housekeeping Contractor requirements Comply with pollution prevention and good housekeeping practices 7. Total Maximum Daily Load (TMDL) Implementation Plan A TMDL Implementation Plan will have a waste load allocation to the municipality Describe current/future Best Management Practices (BMP)that make progress towards meeting waste load allocation in TMDL plan Monitoring plan to assess effectiveness of BMP to reach load reduction requirement in the TMDL plan.

18 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Definitions Illicit Connection- physical connection to a MS4 that convey non-stormwater discharge or not authorized by local authority Illicit Discharge-any discharge or seep that is not stormwater or uncontaminated ground water

19 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Examples of Illicit Discharges Grey Water Discharge

20 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Up-to date storm sewer system map Identify location of outfalls Identify points of discharge Identify water of the State that receive the discharge Indicate where the maps can be found

21 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Procedure for prioritize areas with potential of illicit discharges E.g. Areas with: History of illicit discharge Onsite Sewage Disposal Systems Older infrastructure Poor dry weather water quality Provide geographical location of priority areas

22 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Procedure for prioritizing areas with potential for illicit discharges

23 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Procedure for field observations of outfalls Water color, clarity, floatables, odor Structural condition, staining, deposits Bacterial sheens, algae, slimes, Field screening procedures ph Ammonia Fluoride Detergents

24 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) Procedure for source investigation How will the source be determined? Procedures for responding to spills Procedure for reporting of polluting material to waters of the state from storm system Polluting material defined by Part 5 rules. Response to illicit discharge Corrective action Compliance schedule

25 Stormwater Management Program. Illicit Discharge Elimination Program (IDEP) IDEP Training of staff Once during permit cycle New staff within the first year of hire Evaluation How is effectiveness of IDEP program evaluated? Wayne County does pollutant load reduction calculations Illicit discharge ordinance

26 Dye Testing Dropping the dye Liquid Packets Alternate colors Green Fluorescent red Rule 97 file notice of intent

27 INTENSIVE SAMPLING TECHNIQUE To find off-hours or intermittent flows or peak activity Automatic samplers Flow meters Multiple sampling at specific sites

28 INTENSIVE SAMPLING TECHNIQUE North Mill East Temp(C) :00 11:09 06:1 01:27 20:36 15: SpCond(mS/cm) :00 11:09 06:1 01:27 20:36 15:45 11/22/06 11/23/06 11/24/06 11/25/06 11/25/06 11/26/06 DateTime(M/D/Y)

29 OTHER TECHNIQUES Smoke testing Televising the storm sewer Drain walk Use your imagination

30 IDEP Case History #1 A Storm Sewer Outfall is discharging a milky white substance into the Lower Rouge River

31 IDEP Case History #1

32 IDEP Case History #1

33 Case History Restoring Recreational Use along the Middle Branch IDEP Case History #2 Clean Livonia case history Dirty 1996 Newburgh Lake to Nankin Lake meets E. coli standards Downstream of Nankin, lake does not meet E. coli standards

34 Problem area E. Coli (CFU/100 ML)

35 IDEP Case History # manholes in drainage area E. Coli (CFU/100 ML)

36 4 #Y #Y #Y #Y 720 Results from May 20, 1997 #Y

37 R e s u l t s o f M a y 2 2, R e s u l t s o f M a y 2 1, E. Coli (CFU/100 ML)

38 IDEP Case History #2 Results May 23, 1997 E. Coli

39 104 IDEP Case History #2 #Y 140 Results May 2, 1997 E. Coli #Y #Y #Y #Y #Y 520 E. Coli (CFU/100 ML) 64

40 #Y 1600 IDEP Case #Y History #2 304 #Y Results June 6 & 11, 1997 E. Coli 304 #Y #Y 160 #Y E. Coli (CFU/100 ML)

41 > IDEP Case History #2 #Y #Y #Y #Y Results June 13, 1997 E. Coli E. Coli (CFU/100 ML)

42 CASE HISTORY RESTORING RECREATIONAL USE ALONG THE MIDDLE BRANCH 1997 city planning TV ed sewer no taps (completed) Sent letters to residents (not completed) Dye tested homes (not completed) 1997 County actions Intermittent monitoring Does problem still exist? Evidence of problem disappeared Continued monitoring

43 CASE HISTORY RESTORING RECREATIONAL USE ALONG THE MIDDLE BRANCH Memorial Day 199 problem back! Sent letters out Dye testing Educational material sent to homeowners Late 199 evidence of problem - disappeared Clean Clean

44 CASE HISTORY RESTORING RECREATIONAL USE ALONG THE MIDDLE BRANCH Probable cause Recreational vehicle/boat dumping sanitary waste Pet waste

45 CASE HISTORY RESTORING RECREATIONAL USE ALONG THE MIDDLE BRANCH WHAT DID WE LEARN? Persistence pays Observable presence in the area had an affect Public education worked

46 IPP Staff Eyes and Ears Be an alert observer Report suspicious discharges Remember - even small discharges are large pollutant sources if they pollute day after day after day

47 IPP Staff Eyes and Ears

48 IPP Staff Eyes and Ears Leaky dumpsters Failing septic system

49 IPP Staff Eyes and Ears Poorly maintained grease trap leaks outside building No dumpster

50 IPP Staff Eyes and Ears Leaking emulsion storage

51 IPP Staff Eyes and Ears

52 Illicit discharge or connection spotted now what? Document details Take pictures (if possible) Report it Follow up

53 What to Report and to Whom? Details of the illicit discharge incident Address or cross-street information Identify person or agency responding Notify appropriate person or agency

54 Reporting Illicit Discharges Emergency 911 MDEQ Pollution Emergency Alerting System (PEAS), 24 hour (00) Non-Emergencies County Health/Environmental contact Local Community IDEP Coordinator Local Soil Erosion Control Agency

55 Wayne County IDEP Accomplishments Over 259 million gallons per year of polluted water removed Over 1,200 miles of county drains inspected Over $1. Million grant funded investigations performed Over 9,700 facilities inspected Over 700 facilities with illicit connections / discharges 2,407 illicit discharge sources identified

56 Dye Testing Type of Illicit Discharges Identified Wayne County Violations less than 3% Outdoor Washing Pads Washing Machines Drinking Fountains Toilets 11% Sump Pumps Swimming Pool Drains Machinery Process Water Showers Urinals Other (Not specified) Sinks 19% Floor Drains 54%

57 Macomb County IDEP Accomplishments Over 75 million gallons per year of pollution removed Over 400 county drains and 5,000 road drains inspected Over $1.5 Million grant funded investigations performed ( ) Partners: Environmental Health, Public Works, Department of Roads, Local Governments & Schools

58 Success Story Middle 3 Rouge

59 Success Story Middle 3 Rouge E. coli Daily Beach Standard

60 Success Story Middle 3 Rouge Macroinvertebrate Communities Middle 3 Storm Water Management Area Macroinvertebtrate Data Trend Spring All Sites (Wayne County Data) 50 SQI Score Site Score Year p = Slope=1.5019

61 USEFUL WEBSITES On-site Sewage Disposal Ordinances online:

62 It takes a partnership for effective pollution prevention County Executive Wayne County Department of Public Services This training session was developed as part of the Rouge River National Wet Weather Demonstration Project, which is funded, in part, by the United States Environmental Protection Agency grant #XP