Illicit Discharge Elimination Plan Guidance
Eliminating
Illicit Discharges
The Michigan Department of Environmental
Quality National Pollutant Discharge Elimination System General
Wastewater Discharge Permit for Storm Water Discharges from Separate
Storm Water Drainage Systems requires an Illicit Discharge Elimination
Plan (Part I, Section A., 2.b.) It states,
"The applicant shall submit
a plan for effective elimination of illicit discharges, including
discharge of sanitary wastewater, to the applicant's separate storm
water drainage system for which coverage under this permit was requested.
At a minimum, the Illicit Discharge Elimination Plan shall include
the following: 1) a description of a program to find, prioritize,
and eliminate illicit discharges and illicit connections identified
during dry weather screening activities and 2) a description of
a program to minimize infiltration of seepage from sanitary sewers
and septic systems into the applicant's separate storm water drainage
system."
The goal of an illicit detection
program is to eliminate improper discharges to the storm drainage
system in a community so that only authorized discharges as permitted
by the General Storm Water Permit enter the system. These include
point sources permitted under the NPDES program.
There are several possible ways
to meet the goal. Communities must decide what fits with the resources
and efforts already underway and how serious the water quality problems
are. To assist communities, the RPO has developed suggested steps
that need to be taken to implement an illicit detection program.
Resources are limited and thus
it is important that investment in an illicit detection program
have the greatest return. Knowledge of the storm drainage system
is very valuable to have a cost effective program. For instance
combined sewers or storm drains that have no dry weather flows would
be a lower priority for illicit detection investigations. Those
with high dry weather flow would be a higher priority for investigation.
A visual inspection of storm drains and outfalls could determine
what areas do not need investigation. The visual inspection of drains
may also reveal problems that need further investigation.
Sampling drains that have dry weather
flow will determine if they meet water quality standards. If a drain
does not meet water quality standards, there are a few ways to find
the source of the problem. Televising a storm drain may reveal a
connection that is discharging suspicious material. Testing manholes
or surface water in ditches upstream of the discharge can be used
to isolate an area where the problem is coming from.
When a problem has been isolated
to an area, the source can be found by dye testing buildings in
the area. Smoke testing has also been used to find improper sewer
connections. If there are septic systems in the area, these may
require an inspection to determine if they are the source of a problem.
Once a source is identified it will be critical to work with the
source to correct the problem. Most individuals that have a discharge
problem will correct it. Follow up is important to assure the problem
is corrected. If voluntary correction is not obtained, it is necessary
that there be an enforcement process available. Local Plumbing and
Building Codes may apply, as well as the State Drain Code, Environmental
Code, Public Health Code or the Federal Clean Water Act.
A responsibility of the community
is to report the findings of their illicit detection program. Relevant
information should be kept and reported to the DEQ. Wayne County
and the Rouge Program Office can assist in this reporting.
As it is very difficult to find
all illicit discharges, and since physical changes to community
storm water systems are constantly being made, other checks of the
storm drainage system are necessary. Continuing a visual screening
of outfalls and drains will help find changes to the discharges.
Dye testing buildings at the time of a property transfer will assure
buildings are properly connected to the correct storm or sanitary
system. The use of TV equipment in storm sewers for maintenance
could also check for suspicious discharges. Having in place a complaint
system provides important surveillance of the storm drainage system.
The steps to develop an illicit
detection program are; establishing a legal basis for the program,
screening of the storm drainage system to prioritize problem areas,
finding illicit discharges, seeing that corrections are made, and
evaluating and reporting program results. What follows is a more
detailed description of each of these steps along with references
that provide more technical information.
DETAILS OF AN ILLICIT DISCHARGE
ELIMINATION PROGRAM
The General Permit for Storm Water
Discharges requires that an Illicit Discharge Elimination Plan be
developed and submitted with an application for the storm water
permit. A chart, titled Eliminating Illicit Discharges, has been
prepared to summarize the elements of an illicit detection program.
Public education and access to pertinent information are important
to all steps of an Illicit Discharge Elimination Plan. The box on
the chart below each element of an illicit detection program identifies
the targets for education related to that element.
The important elements in an illicit
detection program are:
1. LEGAL BASIS - A legal
basis is necessary to require investigation of illicit discharges
in a community, provide access to buildings and to provide for enforcement
to correct illicit connections that are found. The usefulness of
the local plumbing code, State Drain Code, Environmental Code or
Public Health Code should be evaluated along with amendments to
local ordinances or development of a new ordinance. While enforcement
is primarily the responsibility of the local unit of government,
the Wayne County Compliance and Public Affairs Division, Wayne County
Environmental Health, DEQ, or the Federal Clean Water Act may be
of assistance. The RPO has copies of ordinances that require an
inspection of a home at the time of transfer of the property title,
and of regulations to require regular inspections of septic systems.
2. LOCATION OF PROBLEM AREAS
- Several methods have been used to locate problem areas. Complaints
and visual screening can identify problem areas in a community for
further investigation. Testing of outfalls for ammonia, surfactants
and E. coli have been used to locate storm sewers that are
contaminating surface water. Reference 1 and 2 describes in more
detail screening methods used by communities. Reference 3 projects
the number of illicit discharges in the watershed based on the work
done by Wayne County Department of the Environment. Reference 4
describes screening done in one watershed to find illicit discharges.
The following is a brief description of methods used to prioritize
areas for more detailed investigations.
- Visually screening outfalls and manholes using
the aesthetic survey developed by the RPO or a similar tool can
identify suspicious discharges.
- Testing manholes and outfalls during dry weather
flow in a grid system to cover the community. Reference 2, p.12,
describes the methodology that was used in one watershed.
- Televising storm sewers can identify pipes discharging
questionable material, or show foaming or staining. These conditions
would suggest areas for further investigation.
- Use of infrared and thermal photography can
show temperature of discharges and chlorophyll in discharges.
Areas with warmer water during cold months or high chlorophyll
during warm months give cause for further investigation.
- A complaint system, and use of volunteers to
adopt outfalls and monitor the river broadens the involvement
of the public in surveillance. Establishing a reporting and investigation
system would identify locations for follow up.
3. FINDING THE SOURCE -
Locating problem areas usually does not reveal the source of the
problem. More detailed investigations are usually necessary to find
an illicit discharge. Methods that have been used to find the source
of an illicit discharge are:
- Dye testing buildings in problem areas identified
in the screening of the community. Reference 2 has a description
of field inspection procedures to dye test facilities
- Dye testing or smoke testing buildings at the
time of sale. This should include the evaluation of buildings
served by septic systems. Dye testing of septic systems would
determine if they are failing or are connected to a surface water
discharge.
- Tracing of contamination upstream in the storm
sewer. Testing can isolate the problem to a specific sewer line.
Reference 4 describes the testing of manholes and outfalls.
- A certification program could identify properties
that have checked their buildings and found no illicit connections.
Certification can be done as part of a NPDES Industrial Storm
Water Permit, as part of an environmental audit, or to comply
with the industrial pretreatment program. If you know what buildings
have been evaluated, time could be saved when tracing down contamination,
- An inspection program of existing septic systems.
Inspections can identify a failure or prevent failure of septic
systems. Developing a data base of septic systems can help this
effort. Integrating the septic system information into the sewer
customer data base could be helpful in locating septic systems
and recording information on the systems.
- Televising storm sewers. This method can visually
identify a pipe entering the storm sewer that may be the source
of a problem. Staining on the side of the storm sewer and foaming,
are clues that improper material is entering the sewer.
4. REMOVING/CORRECTING AN ILLICIT
CONNECTION - When an illicit discharge is found, the property
owner must be notified and a time given for correction. Follow up
of notices is necessary to determine what action is being taken
and to verify that the correction is made. The legal basis for the
program will detail the steps to be taken should enforcement be
necessary. Education and working with the facility will be the most
effective technique in achieving correction of an illicit discharge.
Reference 2, p.5, describes the enforcement procedure used by Wayne
County DOE.
The primary enforcement tool in
other illicit detection programs has been the local plumbing and
building code. Other laws that might apply are Act 451, of 1994,
Part 31 of the Michigan Environmental Code, the Drain Code, the
Clean Water Act, PL 92-500 and the Public Health Code, Act 368 of
1978.
5. PROGRAM EVALUATION AND REPORTING
- Documenting the actions taken to find and eliminate illicit connections
or discharges, will show the progress being made to eliminate them
as sources of water quality impairments. Documentation may include
the number of sites inspected or certified, number and types of
violations found, number of violations corrected, estimate of flow
and pollution prevented from entering the river, complaints received,
complaints corrected, number of water samples tested, feet of sewer
televised, number of septic systems inspected and number of facilities
with industrial storm water permits or exemptions. This information
should be made available to Wayne County or the Rouge Program Office
so a watershed summary can be prepared. The summary by Wayne County
would include the community reports and how they relate to river
monitoring.
REFERENCES
These references are available at the Rouge Program Office upon
request.
- Investigation of Inappropriate Pollutant Entries
into Storm Drainage Systems, A User=s
Guide, EPA/600/R-92/238, January 1993.
- Technical Memorandum Summary of Illicit Connection
Detection Programs in Michigan, RPO-NPS01A-TM01.00, February 1996,
Christine Pomeroy, Kelly Cave, Dean Tuomari.
- Estimated Total Pollution Delivered to Rouge
River by Illicit Connections, RPO Memo, February 26, 1997, Jeff
Boerma, Barry Johnson.
- Draft Task Product Memorandum Illicit Connection
Detection in Middle 2, July 1997, Robert G. Gignac, Ashraf A.
Ibrahim, Chris G. Nepszy, David M. Racz, Dean Tuomari.
cc: RPO File URBSW6
On-site Sewage
Disposal Systems
Background
The monitoring on the Rouge River by
the Rouge Program Office, has found high E.coli counts upstream
of areas not served by sanitary sewers or combined sewers. Further
investigation by Oakland County Health Department and Wayne County
Environmental Health Division has found failures of on-site sewage
disposal systems (OSDS) in every area they have evaluated.
(a failure was considered as
recovery of dye that had been placed in a septic system being
recovered in samples taken from the river.)
-
Wayne County 1997 survey
- 24% of systems found failing or would discharge bacteria to
the river during rain events.
-
Wayne County evaluations
of septic systems at the time of property transfer - 11% failure
rate.
Each county in the watershed requires
a permit for the construction of an on-site sewage disposal system
(OSDS). However, none of the counties have any regular review of
systems after they are put into operation. The exception to this
requirement is that a review of the systems must take place if there
is request to evaluate the OSDS at the time of a property transfer.
It is important to address this
source of waste that is contributing to surface water quality problems
for three reasons. There are high bacteria counts, universal failure
of septic systems, and lack of any regular review of septic systems.
How others have addressed OSDS
A review was made of existing programs
that manage OSDS across the United States. The elements of these
programs are summarized in Table 1 and Descriptions of Existing
On-Site System Maintenance Programs. Five different approaches have
been taken. They are:
- inspection programs
- certification of OSDS at the time of sale of
a property
- operational permit
- discharge permit
- mandatory maintenance
These programs provide a choice of ways to manage
OSDS. Programs have been administered through towns, associations,
utility districts, counties, or at the state level.
Financing
Alternatives to Replace OSDS
Methods used by the existing OSDS
management programs to finance replacement of OSDS or extension
of sanitary sewers include the use revolving funds, bonds, loans,
grants and cost sharing.
Revolving Funds
Several methods have been used to finance replacement of on-site
sewage disposal systems and extension of sanitary sewers. One of
the most frequently used is a revolving fund that provides loans
to replace OSDS or extend sewers. Federal, State and local revolving
funds have been established.
The federal revolving fund is a
grant to states to establish a state revolving loan fund (SRF) following
federal requirements for the loans. In Michigan the SRF has been
used for funding sanitary sewers based on need and meeting other
federal requirements such as eligibility. The documentation and
criteria that must be met to qualify for SRF money is extensive.
Those working with the program in Michigan recommend that projects
be over $300,000 to make it worth the effort to apply. The contact
for this is the Municipal Facilities Section, Environmental Assistance
Division, Michigan Department of Environmental Quality. Their phone
number is (517) 373-4732. The interest rate for loans in FY 1997
was 2.25%.
Some states have established a
state revolving loan fund. Massachusetts included $30 million in
a bond issue for septic system compliance problems. Of the total,
$25 million is earmarked for septic system repairs and $5 million
is to pay for sewer connections and zero pollution discharge systems.
Loans in the Massachusetts program had an interest rate of 5% in
1996.
Some local units of government
have established a fund that can be used to extend sewers or meet
other critical needs. It allows a quicker response than having to
issue a bond to finance a project. The funds are replenished as
connections and fees are paid. Interest rates for these are set
by the local unit of government.
Some communities have put a surcharge
on fees for permits or on the disposal of septage to set up a revolving
fund. The funds have been used for grants and loans to individuals
that have failing on-site sewage systems. Two communities that have
septic management programs placed a surcharge of $0.02-0.035 cents
per gallon of septage taken to the treatment plant. The fee is collected
at the treatment plant. One community has a $10 surcharge on permits
that helps fund their program.
Another method that has been used
to establish a revolving fund is the creation of a utility district.
These can transfer the responsibility for maintaining on-site sewage
systems from the property owner to the utility. Inspections, maintenance
and construction are paid from the utility fund. A monthly charge
is collected from each property in the utility district. Low interest
loans are often a service the fund provides. Fees charged are collected
as part of a water bill or added on to the tax statement. Charges
from 3 existing districts are; $53 every two months, $12.50 per
month, and $14.70 per year plus an inspection fee.
Livonia and other municipalities
have established a type of revolving fund that can be used to fund
sewer extensions when a special need arises. Failures of septic
systems can fit into this category. Having a revolving fund available
that can respond to extend a sewer when there is a failure can avoid
the property investing in a new OSDS or a significant repair. Those
resources can be put into paying for a sewer connection.
Having a revolving fund could also
assist in the replacement of OSDS when there is a hardship case
presented.
Bonds
Bond issues have also been used to finance sewer extensions and
could be used for septic system replacements. One type of bond is
a bond designated for environmental improvement. These have been
used for a variety of environmental projects. This could include
sewer extension to areas with problem on-site sewage systems and
replacement of on-site sewage systems. These are often general obligation
bonds.
Another type of bond is a revenue
bond. Revenue from monthly, quarterly of yearly charges are used
to retire the bond.
An area of a community could be
identified as a special assessment district. The district could
be made up of premises that have problems with on-site sewage systems.
A bond is issued that is usually backed by the taxing power of the
community. The money from the bond is used to fund capital projects
in the district. These could be sewer extensions or replacement
of on-site sewage systems. Direct fees or taxes retire the bond.
Loans and Grants
The U.S. Department of Housing and Urban Development, Office of
Housing makes available loans to those who meet the eligibility
requirements. Loans in the Title I Property Improvement and Manufactured
Home Loan Regulations, 24 CFR Part 201, program can be used for
home repairs, including repairing or replacing sewage disposal systems.
The maximum amount of a loan is $25,000. A condition of the loan
is that it substantially protects or improves the basic livability
or utility of the property. Loans under $7500 can be unsecured.
Those over $7500 shall be secured by a recorded lien on the improved
property. (1) The 1995 rate for these loans was 7.3%.
Banks, credit unions and other
institutions will also provide loans for repairs or replacement
of on-site sewage systems. Rates of interest vary. A home equity
loan would start at approximately 9.95% in 1997. Other types of
loans are usually higher.
The U.S. Department of Agriculture
has money available to alleviate health hazards by meeting the need
for new and improved rural water and waste disposal facilities.
Funds support the installation, repair, improvement or expansion
of rural waste disposal facilities. The contact for this the U.S.
Department of Agriculture, Rural Utilities Service, Water Programs,
Room 2234, Stop 1570, 1400 Independence Avenue, SW, Washington,
D.C. 20250. The phone number is (202) 690-2670. Assistance is in
the form of project grants, direct loans and guaranteed/insured
loans. The money is provided under authority of the Consolidated
Farm and Rural Development Act, as amended, Section 306, P.L. 92-419,
7 USC 1926.
Community Development Block grants
are available for urban communities for provision of public facilities
and improvements such as water and sewer facilities. Grants are
available to central cities in a Metropolitan Statistical Area.
The contact for this program is the local field office of Housing
and Urban Development. This money is provided under the authority
of the Housing and Community Development Act of 1974, Title I.
Another grant program is the Sustainable
Development Challenge Grant. This program encourages partnering
among community and government entities to work cooperatively to
develop flexible, locally-oriented approaches that link environmental
management and quality of life activities with sustainable development
and revitalization. Partnerships under this program will increase
a community=s capacity
to take steps to ensure long term ecosystem and human health, economic
vitality and community well-being. The contact for this program
is the U.S. Environmental Protection Agency, Office for Air and
Radiation (MC6101), 401 M Street, Washington, D.C. 20460. Their
phone number is (202) 260-6812.
Cost Sharing
Some sewer extension projects have been assisted by sharing the
costs of the sewer with a major user. At times a major user will
finance the sewer line extension with an agreement that they will
be reimbursed when others connect to the sewer.
KEY ELEMENTS OF AN ON-SITE SEWAGE
DISPOSAL SYSTEM MANAGEMENT PROGRAM AND OPTIONS
Key Elements
Management programs for OSDS in other communities has included the
following key elements.
- an identified problem that septic systems were
contributing to
- a legal basis
- a source of funding
- a data base to track information related to
each system
- inspections of the OSDS
- uniform standards for evaluation of OSDS
Options
Problems that OSDS could be related to in a community are; surface
water contamination, public health hazards related to sewage discharges
on or near homes and into surface water, contamination of groundwater
and well water supplies, and nuisances.
A legal basis for a program could
be a local ordinance, county regulation, state law, subdivision
deed restriction, condominium agreement, utility district requirement,
special assessment district or requirement as a condition of receiving
a permit for an OSDS.
Sources of funding include; annual
bill like tax bill, inspection fee, user charge similar to charge
for wastewater discharged to a sewer system, watershed fee to protect
watershed, surcharge on permits, or septage disposal tipping fee.
The database used in other programs
includes inventories of systems, location and features of the OSDS,
certification, documentation when a system has been evaluated, mailing
or billing information, record of inspections, list of certified
inspectors, record of when a septic tank was pumped and permits
issued.
Inspections have been done by counties,
utility personnel, trained inspectors (private), licensed evaluators,
septic tank cleaners, home owners, or on-site maintenance specialists.
Illicit Discharge
Elimination Plan for the Middle 3 Communities of Dearborn Heights,
Garden City, Livonia and Westland
This Illicit Discharge Elimination
Plan (IDEP) has been developed as part of the application for a
State of Michigan National Pollutant Discharge Elimination System,
N.P.D.E.S. Permit Application for Voluntary Coverage of Storm Water
Discharges. The IDEP is item 7 of the Application.
Introduction
The communities in the Middle 3 Storm Water Management Area,
Dearborn Heights, Garden City, Livonia and Westland, have been working
together to address impairments to the Middle Rouge River. This
IDEP is based on a watershed approach to improve the water quality
of the Rouge River. It depends on the cooperation between municipalities,
Wayne County agencies and the Michigan Department of Environmental
Quality (MDEQ). The IDEP identifies common elements that each community
will implement and areas where cooperation with Wayne County agencies
and MDEQ is important. This document identifies general areas of
agreement among these communities and is intended to be a guide
for each community in the preparation of their Permit Application.
7. Illicit Discharge Elimination
Plan for the Middle 3 Communities of Dearborn Heights, Garden City,
Livonia and Westland
Illicit discharges and connections to the storm water drainage system
described in Items 5 and 6 of the Storm Water Discharge Permit Application,
will be found using the following techniques.
- Water sampling data and other available information
about water quality problems will be reviewed to help prioritize
evaluation of the storm drainage system.
- Development of a complaint system to encourage
reporting of suspicious discharges. The existing Wayne County
Ahot line@
will be a part of this system. Each community will develop or
enhance their complaint system to log complaints, assign them
for follow up and document results of investigations. A
procedure to coordinate complaint response and follow up will
be developed in cooperation with MDEQ and Wayne County.
The complaint system will be in place 6 months after the Certificate
of Coverage (COC) is issued.
- Visual screening of all the outfalls in the
storm sewer system that are under the control of the municipality,
will be done within 12 months of the issuance of the COC under
dry weather conditions. Dry weather is defined as
periods when there has not been precipitation or snow melt for
a minimum of 2 days. The locations screened will be located on
the community map of the storm sewers.
- Locations identified by visual screening, complaints
and water quality data as requiring 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, screening tests, and odor, color and visual
observations. Assistance in sample collection and testing will
be requested of Wayne County and MDEQ when a significant pollutant
or complex problem is found.
- Investigation to find the sources of suspicious
discharges will be by visual inspection and/or testing of discharges
within the storm drainage system upstream of the site of the suspicious
discharge. Other options that will be considered to find an illicit
connection or discharge are televising the sewer or dye testing
premises in the area where a discharge is coming from. Letters
may be sent to residents and businesses alerting them to the problem
that is under investigation to solicit their assistance in finding
the source. A building by building evaluation may also be used
in areas where a problem has been isolated to a small area.
- Field employees of the City will be educated
to be observant for discharges that might pollute the river and
how to report them. (The complaint system will be used).
Illicit Discharges will be prioritized
based on the following criteria.
Sources that are discharging sewage or other pollutants will be
investigated in the following priority.
- Water quality problems that have been identified
based on sampling and inspections by the Wayne County Department
of Environment and Wayne County Department of Public Health, Environmental
Health (EHD) will be reviewed with them to develop a plan for
further investigation or correction.
- Complaints related to the discharge of polluting
materials will be investigated as they are reported.
- Outfalls that have the highest E.coli bacteria
sample results will be investigated by 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 discharge. Other options that will
be considered to find an illicit connection or discharge are televising
the sewer or dye testing premises in the area where there is a
discharge.
- Suspicious discharges other than bacteria,
will be prioritized based on the estimate of the impact on the
river.
Plan to eliminate illicit discharges
and connections.
The general plan for the period covered by this permit is to do
a visual inspection of all outfalls in the storm sewer in the first
year. Suspicious discharges identified from available water sampling
data, complaints and visual inspections will then be prioritized
for sampling. Investigations will be made to find the sources of
pollutants. Those responsible for discharges will be notified for
correction and followed to assure correction is satisfactorily completed.
Public information and involvement issues can be found in the Public
Education Plan. In addition,
- Existing ordinances will be used to address
illicit discharges and connections. Assistance may be requested
from Wayne County Department of Environment, EHD or the MDEQ to
obtain correction. If current ordinances are not adequate to result
in correction of illicit discharges, a new ordinance will be prepared.
If an ordinance change is needed to correct illicit discharges,
the changes will be presented to city council within 9 months
after it is found that existing ordinances are inadequate to require
correction.
- The City will identify the person to be in charge
of the IDEP. The City will determine whether city staff, private
contractors or the Wayne County Department of Environment will
be used to conduct the illicit detection program.
- If overflows of sanitary sewer manholes or cross
connections to a storm sewer are detected, they will be addressed
as part of the communitie's NPDES permit for the sanitary sewer.
If an immediate solution is not practical, a plan will be
developed to solve the problem.
Plan to minimize infiltration
of seepage from sanitary sewers and septic systems into separate
storm water drainage systems.
- If an on-site sewage disposal system (OSDS)
is to be kept in service more than 5 years after the COC, a procedure
to evaluate them will be developed to begin evaluations of OSDS
in the five year period in cooperation with Wayne County EHD.
This may include evaluation of a premise at the time of sale if
city records show it is not connected to a sanitary sewer. If
an ordinance change is needed to require septic system evaluations,
it will be presented to city council within 9 months after it
is found that existing ordinances are inadequate to require
evaluations.
- Any OSDS found to be failing will be sent a
notice to connect to a sanitary sewer if it is available. Failures
are expected to be identified as part of the OSDS evaluation program
and in response to complaints. City policies and requirements
for connection to sanitary sewers will be reviewed to provide
incentives to connect to the sanitary sewer and/or to ease the
financial burden of sewer connection. If municipal sewers are
constructed, appropriate state permits will be obtained.
- OSDS found to be experiencing problems or failing
will be referred to the property owner and Wayne County Environmental
Health Division for a short term and long term solution for sewage
disposal if sanitary sewers are not available.
- Each city will continue their sanitary sewer
maintenance program. Leaks that are found in the sanitary sewers
will be evaluated and appropriate corrective actions taken.
- As a pilot project, Westland will use television
equipment to inspect storm sewers in an older part of the city.
The findings of this pilot project should be available in late
1999. The findings will be shared with other communities. If this
is successful in finding illicit discharges or sanitary sewer
cross connections to the storm sewer, the equipment will be made
available to other communities.
Implementation Schedule.
Twelve months following the issuance of the Certificate of Coverage
the following will be done;
- A plan and timetable will be prepared in cooperation
with Wayne County Department of Environment and EHD staff to find
the sources of suspicious discharges have been identified and
to correct problems from those discharges.
- A complaint system to log complaints and investigate
them will be in place.
- A visual screening of 100% of the outfalls
sewers will be completed.
- The sanitary sewer system will be reviewed
to determine areas of the city that do not have sanitary sewers
available. Cost estimates will be prepared to determine the feasibility
of extending sanitary sewers to those areas.
- Employees of the City will be informed about
the need to find and eliminate illicit discharges and the complaint
system will be made available to them.
- A list of illicit discharges and connections
and correction status will be prepared.
- The legal basis for correcting illicit discharges
will be reviewed and revisions developed to administer the program
when it is found that revisions are needed.
- A procedure will be developed in cooperation
with Wayne County and MDEQ tocoordinate complaint response and
follow up.
Twelve to sixty months following
the issuance of Certificate of Coverage the following will be accomplished.
- Each year a summary report of complaints received,
investigated and the results of the investigation will be prepared.
A map will be available to show the areas under investigation.
- Suspicious outfalls that had a dry weather
flow during visual screening will be tested for suspected pollutants.
- A summary report of the premises found to be
improperly connected to the storm or sanitary sewer will be prepared
each year.
- A summary report of on-site sewage systems
found to be improperly functioning and actions taken to correct
problems will be prepared each year.
- A list of outfalls and manholes tested and
results will be prepared each year.
- A summary of sanitary sewers found to be leaking
and correction of these leaks will be prepared each year.
- Sanitary sewer construction will take into
consideration the needs of on-site sewage systems.
- A plan will be developed in cooperation with
Wayne County EHD to evaluate on-site sewage disposal systems on
a regular basis in areas where sewers will not be available for
5 years or more.
- The results of the pilot project in Westland
using television equipment to find illicit discharges will be
prepared and shared with other communities.
- If an ordinance is needed to correct illicit
discharges or evaluate OSDS, it will be prepared and presented
to council within 9 months after it is found that changes are
needed.
- A summary of sanitary sewers found to be leaking
as part of regular operation and maintenance of the sewer system,
and a timetable for correcting them will be prepared.
April 29, 1998
Michigan General Permit Draft Guidance
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