ILLICIT DISCHARGE ELIMINATION PLAN
FOR OAKLAND COUNTY
Submitted by: George Kuhn, Drain Commissioner
OAKLAND COUNTY, MICHIGAN
ONE PUBLIC WORKS DRIVE, BUILDING 95 WEST
WATERFORD, MI 48328-1909
PH: (248)858-0958
FAX: (248)858-1066
1.0 INTRODUCTION
This document details an illicit discharge elimination plan for all Departments of Oakland County within the Rouge River Watershed. The Oakland County Drain Commissioner’s office (OCDC) is the lead applicant with support from other departments. The Oakland County portion of the Rouge Watershed has been further subdivided into three subwatersheds, the Main 1/2, the Upper and the Middle 1. The OCDC will coordinate the work with the three Storm Water Advisory Groups (SWAGs), the multiple municipal interests, the Rouge Remedial Action Plan Advisory Council (RRAC) and other Oakland County Departments to assure an effective effort. The Oakland County communities within the Rouge watershed include:
•Auburn Hills •Beverly Hills •Bingham Farms
•Birmingham •Bloomfield Hills •Bloomfield Twp.
•Commerce Twp. •Farmington •Farmington Hills
•Franklin •Lathrup Village •Lyon Twp
•Novi •Novi Twp. •Oak Park
•Pontiac •Rochester Hills •Southfield
•Southfield Twp. •Troy •Walled Lake
•West Bloomfield Twp. •Wixom
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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In 1987, the United States Environmental Protection Agency (USEPA) required Phase I storm water NPDES permits for municipal separate storm sewer systems for cities with population over 100,000, certain industries, and construction sites over 5 acres in size to complete the permit process. Phase II of this permit process has been drafted and is currently out for public comment. The requirements as drafted apply to communities with population over 50,000 or more than 1,000 people per square mile, construction sites over 1 acre in size, and several additional industrial categories. It is expected that all of the Rouge River Watershed within Oakland County, except Lyon Township, will be included in Phase II coverage.
In anticipation of the Phase II storm water requirements, the MDEQ developed the Michigan NPDES General Storm Water Permit (General Permit.) Municipal entities which seek coverage under this General Permit are required to fulfill a series of requirements which closely match those expected under the federal program.
This application identifies a program which will fulfill the requirements of both the current General Permit and the anticipated Phase II NPDES Program. The plan also is divided into both a short term program (covering the initial permit period) and a proposed long term program (for application under the Phase II program.) This division recognizes that once a thorough illicit connection program has been completed and the majority of the illicit discharges have been identified and eliminated, a lesser program is sufficient to contain future problems.
This plan includes a description of a program to find, prioritize, and eliminate illicit discharges and illicit connections identified during dry weather screening activities and a description of a program to minimize infiltration of seepage from sanitary sewers and septic systems into the separate storm water drainage system. The plan also identifies the interaction and responsibilities of the OCDC as it pertains to other Oakland County Departments and the local communities which he serves.
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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This general Illicit Discharge Elimination Plan includes a series of department specific assignments. As the program proceeds, these assignments may shift. The final division of work between the departments will be detailed in the Oakland County Storm Water Pollution Prevention Initiative.
Once illicit discharges are identified, the type of remedial action required is dependent on the jurisdiction in which the guilty facility falls. The institutional arrangements to address the problem areas will vary from subwatershed to subwatershed and, in fact, may vary within the subwatershed. Illicit discharges are governed by a combination of state, county and local ordinances. The OCDC as the permit applicant will monitor the entire drainage system currently under the jurisdiction of Oakland County including county drains and county road drainage. As areas are identified as being impacted by illicit discharges, the MDEQ and the contributing local unit of government will be notified. The success or failure of the removal process will be monitored by the OCDC. The actual illicit connection removal will remain the responsibility of the local unit of government.
Some communities have chosen to contract with the OCDC to pursue illicit connections upstream of the county drainage system. In these communities, the OCDC will accept the responsibility of identifying the individual cross connection. In these cases, the actual removal will be coordinated through the local municipality, the County Health Division and/or the Prosecutor’s office. The final enforcement vehicle will be detailed as part of the Oakland County Storm Water Pollution Prevention Initiative.
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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2.0 ILLICIT DISCHARGE ELIMINATION PLAN FOR OAKLAND COUNTY
The Illicit Discharge Investigation Base Program represents the long term program to which Oakland County can commit for both current and future NPDES requirements. As storm water travels downhill it not only transports pollutants but it also passes through multiple political jurisdictions. Thus, an effective illicit connection program must not only identify problems and the sources of those problems but must also identify the entity responsible for the elimination of the pollutants source. For this to work effectively, a variety of government entities must work cooperatively. Additionally to assure that efficiency is maintained, one unit of government must take the lead. In Oakland County, the OCDC has been charged with this leadership role. The Oakland County Board of Commissioners established a study group consisting of multiple county departments to provide guidance to the OCDC. The OCDC will continue to report to the study group, as well as the County Board of Commissioners, as the process proceeds.
One weakness of the Phase I storm water permitting effort was the prescriptive sampling requirements which resulted in large costs but very little useful information. In an effort to eliminate the shortcomings of the Phase I storm water permitting process, the OCDC will focus their efforts on those areas which suggest that the water quality is degraded and that the cause for degradation is unknown. As these problem areas are identified, the OCDC will work upstream to pinpoint the likely entry of the pollutant.
2.1 Environmental Coordinator
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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The OCDC will appoint or designate an Environmental Coordinator to oversee and to be responsible for compliance with the requirements of the General Permit. Initially Phillip Sanzica, P.E. will serve as the Environmental Coordinator. In the event this responsibility is transferred to another individual, the Michigan Department of Environmental Quality (MDEQ) will be notified in writing.
2.2 Existing In Stream Water Quality Data
The Rouge Program Office (RPO) has initiated a long term, instream monitoring program which documents the water quality of the Rouge River under a variety of flow conditions. It is anticipated that the RPO and/or the MDEQ will maintain this monitoring program to measure the success of the multiple water quality programs currently underway. This data will represent the benchmark data from which the field investigations will be designed.
Prior to any field investigations, a complete investigation of existing documentation will be completed to assist in prioritizing all illicit connections detection activities. This investigation will involve the review of the large amount of data collected by the Rouge River National Wet Weather Demonstration Program (RRNWWDP) and information available through the Oakland County Health Division. This water quality data will be screened for consistently high concentrations of bacteria. Bacteria is the most obvious indicator of sanitary discharges into the river. There are also areas where there is little or no benthic life present. This would indicate pollutant sources other than sanitary sewage but may also suggest an illicit discharge. Once an area of the river has been identified as having known contamination, the area will be targeted for future prioritization analysis which will ultimately determine which areas will require additional field activities.
2.3 Complaint Line
The OCDC maintains a 24 hour, 7 days a week complaint line. This operation has historically focused on flooding issues. As part of the General Permit effort, the personnel responding to citizens complaints will receive training on how to properly respond to pollution complaints. This effort coupled with an expanded public education effort will allow the public to become the “eyes and ears” to help identify pollutant sources.
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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To tailor the complaint receipt and documentation effort, local government field departments, such as the Department of Public Works (DPW) will be interviewed to inquire about any complaints received from the public or unusual observations of the river or storm outfalls. In addition, enforcement agencies such as the MDEQ, Oakland County Health Division and/or the Oakland County Prosecutor’s office will also be interviewed to determine if any documentation may exist on occurrences which would be indicative of an illicit discharge. The information collected during these interviews will be used in prioritizing areas of the river for field investigations.
2.4 Reconnaissance Survey
The OCDC maintains an ongoing reconnaissance survey to establish the condition of their drains. Similarly, the Road Commission for Oakland County (RCOC) regularly surveys their drainage system. Once again, this effort has traditionally focused on drainage and flooding issues. As part of the General Permit effort, these inspectors will be given specific training to aid in the detection of illicit discharges. In addition to these general surveys, a one-time specific reconnaissance survey of the outfalls and major discharge points to the river will be performed to locate any dry weather discharges. These dry weather discharge locations may be indicative of illicit connections.
1. The OCDC has identified the location of the drainage systems under their jurisdiction and the point of discharge for each. The OCDC will work with the RCOC to assemble similar information pertaining to the road drainage system. When the discharge is to a drainage systems owned and maintained by yet another, non-county entity, this third entity will be identified and notified. The information collected under this activity will be of sufficient detail for its inclusion in the Oakland County Geographic Information System (GIS).
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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2. As part of their search for illicit drain connections, all outfalls (aboveground discharge points) leaving any county jurisdiction shall be visually inspected during dry weather periods to identify obvious signs of cross connections. These will include indications of
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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fluids, gross solids, discolorations and odors. Ten percent of those outfalls with persistent dry weather discharges will be tested for the presence of E. coli. As experience is gained on this program, the percentage of outfalls to be analyzed may vary.
3. Locations identified by visual screening, complaints and water quality data that require follow-up, will be prioritized and re-visited during dry weather periods. Those that are suspected of discharging polluting material during dry weather periods will be tested based on water quality problems found in the river. Assistance in sample collection and testing may be requested of the Oakland County Health Division (OCHD) and the Michigan Department of Environmental Quality (MDEQ) when a significant pollutant or complex problem is found.
4. Permit engineers, inspectors and maintenance workers and administrators from the OCDC will receive training to help them identify possible illicit discharges and how to report them. Personnel to receive training will include all superintendents, forepeople, crew leaders, survey crews and mowing crews. Potential illicit discharges will be reported to the Environmental Coordinator.
2.5 Support of Local Communities
The OCDC will continue to work with the Main 1-2, Upper and Middle 1 SWAGs, the RRAC and all participating communities to develop watershed management plans and non-duplicative Storm Water Pollution Prevention Initiatives.
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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3.0 ILLICIT DISCHARGES PRIORITIZATION
In addition to the base program described in the previous section, a more intensive program will be required under the initial program. Because there has historically been little effort expended on identifying and eliminating illicit discharges, it is anticipated that during the initial permit program, the program will require an intensive effort. Thus, as the Base Program proceeds, several areas of the river will be selected for further investigation procedures. In addition, based on information collected during the preliminary process, it may become evident that some areas of the river will need no further investigation. In these “clean” areas, only an ongoing review of the continuous water quality monitoring is required. Areas selected for further investigation will most likely contain storm outfalls from numerous drainage areas.
Sources that are discharging sewage or other pollutants will be investigated in the following priority:
1. Areas in which in-stream water quality problems that have been confirmed by sampling will be identified. The Environmental Coordinator will determine if off site drainage is contributing to water quality problems and will develop a plan for further investigation or correction.
2. Complaints related to the discharge of polluting materials will be investigated as they are reported by the county employees or the general public through the compliant system.
3. Those outfalls that are identified to have yielded the highest E. coli bacteria results will be reinvestigated by a visual inspection of the storm drainage system upstream of the outfall. In addition, water sampling and testing will be done as necessary to find the source of the illicit connection.
George W. Kuhn
Oakland County Drain Commissioner
January 26, 1999
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4. Suspicious discharge other than bacteria, will be prioritized based on the estimated impact on the river.