Cuyahoga County Board of Health Stormwater Program
Phase II prompts communities to detect and replace older household sewage treatment systems.
The Cuyahoga County Board of Health (CCBH) provides public health services to 56 cities, villages, and townships in Cuyahoga County, OH, with an approximate total population of 830,000. Residences in 48 communities use household sewage treatment systems (HSTS). More than 13,000 of these systems currently are being used throughout the General Health District, and the number of sewage systems in each community ranges from only one to more than 1,500. The potential impact that these systems have on the rivers, streams, and surface waters of these communities varies greatly.
Cuyahoga County is on the shores of Lake Erie and contains three major watersheds: Rocky River, Cuyahoga River, and Chagrin River, all of which drain to the lake. Because of limiting factors, such as poor soils, shallow bedrock, or a high water table, and because of limited lot sizes, the majority of the HSTS presently in use in Cuyahoga County are ³discharging systems² that discharge their treated effluent directly into streams, storm sewers, or ditches. This discharge ultimately ends up in Lake Erie. Under Phase II of the National Pollutant Discharge Elimination System (NPDES), those systems discharging to a municipal separate storm sewer system (MS4) are considered to be illicit sources of pollution. Only a small percentage of the existing sewage treatment systems are true ³leaching systems² designed to provide on-lot retention, treatment, and dissipation of wastewater. Locations with suitable soils, no topographical restrictions, and sufficient lot sizes to accommodate leaching systems are limited in Cuyahoga County.
These major watersheds are impacted by both point-source and nonpoint-source pollution. Point sources often are continuous and typically can be identified, minimized, and even eliminated. Nonpoint sources frequently are very difficult to trace and identify; they are widespread and often are intermittent. Examples include runoff from streets and parking lots, agricultural fields, home lawns, construction sites, and HSTS. Contaminants in nonpoint-source pollution include sediment, nutrients, heavy metals, salts, toxic chemicals, and pathogens. These pollutants have the potential to adversely affect both groundwater and surface water. The effluent from failing HSTS has been identified as a major contributor of nonpoint-source pollution in the Cuyahoga, Rocky, and Chagrin Rivers watersheds.
Over the last 10 years, the CCBH has developed and modified an extensive HSTS operation and maintenance (O&M) program to effectively deal with the large number of discharging HSTS. This O&M program will provide Phase IIdesignated communities with a sound strategy in which to deal with their HSTS as illicit discharges.
CCBH Household Sewage Program History
|Three major watersheds in Cuyahoga County|
The current Cuyahoga County Household Sewage Program has evolved dramatically over the last 60 years and has seen a clear shift in fundamental philosophy. What once was a development-minded program now has 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 HSTS into approved locations, such as running stream and storm sewers, when all means of installing on-lot HSTS are exhausted. In 1978, the Ohio Environmental Protection Agency and the CCBH entered into an agreement involving 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, such as the evapotranspiration system. In 1987, the CCBH clearly defined sewage system evaluation procedures and implemented a point-of-sale inspection program. 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 treatment system performance. These evaluations also led to the replacement of many failing systems throughout the General Health District.I
n 1990, the CCBH realized how important it was to change the current strategy used toward HSTS. The inadequacies of the state's rules and the large number of failures and water-quality impairments helped the Board of Health change its HSTS program. In 1992, the CCBH established its current Water Pollution Control Program. This program incorporates a broad watershed-based approach when dealing with any water-quality issues. In 1993, appendices to the CCBH Sewage Disposal Rules were adopted, including requirements regarding septic system abandonment, aeration system design and maintenance, and the initiation of an O&M program. In the fall of 1993, the CCBH became one of the first local health departments to launch a household sewage O&M program in the state of Ohio.
The CCBH's overall O&M program encompasses three major components: education, water-quality sampling, and evaluations of HSTS. The water-quality monitoring component consists of a number of sampling programs. Seventy permanent water-quality monitoring stations are located throughout the various watersheds in Cuyahoga County. These sites were selected to observe water-quality trends over a period of time. The testing parameters for the samples collected at these locations include fecal coliform bacteria, carbonaceous biochemical oxygen demand, suspended solids, total phosphorus, ammonia, and conductivity.
Sample results from any sampling conducted since 1990 are maintained in a computer database. This information is beneficial in assessing bodies of water that receive household sewage system effluent. The sampling data can assist in determining the level of sewage pollution present in a specific area within a watershed. The computer database lists water-sampling results by watershed, municipality, address, specific sampling location, and sampling date. This database currently incorporates approximately 6,000 water-sample results. A new database has been developed that contains outfall and water-quality locations via global positioning system and street address, photos, analysis results, and report and investigation tracking.
Another component comprises biological assessments. This includes macroinvertebrate sampling, qualitative habitat evaluation index, and headwater habitat evaluation index studies. Some of this work is performed through a summer internship program that the CCBH established. The Board of Health has developed a quality assurance management plan for the water-quality program and the work that is performed within it. This consists of training interns and staff on water-quality procedures and policies.
Moreover, the O&M program contains an extensive educational outreach component. It is vital that all operators of HSTS understand how systems operate and the care and maintenance that these systems require. As CCBH sanitarians identify HSTS testing areas, they schedule meetings with local officials and educational seminars for property owners, potential buyers, realtors, and others. These customers are advised on the sewage system evaluation process and the related repair or replacement requirements. The community is kept well informed on the status of the sewage system evaluations being conducted in a particular area. These seminars also provide information on system design guidelines. Along with viewing a PowerPoint presentation and having the opportunity to ask specific questions about their systems, property owners receive informational pamphlets, videos, and other educational materials concerning system maintenance. CCBH representatives often attend and speak at council meetings, gatherings, or fairs on a specific matter or to respond to general concerns they might have regarding sewage system testing or water-quality sampling results. CCBH sanitarians are members of various watershed organizations and participate in water-quality grant projects. By using sound judgment and an overall watershed-based approach, the current O&M program has received a great deal of public support. Many local officials and individual homeowners understand the principles behind this program and realize it is an essential part of any sewage program.
Sewage System Design Information and Drawings
Before the late 1950s, very little information was available on installed HSTS. Many of these systems were installed without the issuance of a permit and without an inspection. As sewage treatment rules changed and the CCBH service area grew, information on sewage system design became more readily available. Installation permits were being required along with an inspection of the system at the time of installation. A drawing of the sewage system is now generated during this installation inspection.
The CCBH maintains active files on HSTS currently in use throughout the county. Each property utilizing a sewage system is represented by a file folder in the household sewage files. These files include sewage system drawings, evaluation reports, and any other correspondence involving that specific property. To help make information on sewage systems easier to access, the CCBH created a comprehensive computer database. Information, such as the property owner's name, sewage system description, evaluation dates, tank pumping dates, and permit numbers, is included in this database.
A separate database is maintained for systems that are abandoned when the property is connected to a sanitary sewer. Due to the installation of sanitary sewer lines and future sewer planning throughout much of Cuyahoga County, this database has become a valuable record-keeping tool that will continue to grow as sanitary sewer service areas are expanded in the future.
To help fund the current O&M program, the CCBH charges an annual operational permit fee of $30. Before the initiation of the O&M program, the CCBH required a property owner to pay an inspection fee for the sewage treatment system evaluation. These evaluations generally were requested when a property was being sold. The previous inspection fee has been replaced by the yearly payment of an operational permit. An application for the permit is mailed to the property owner annually prior to the renewal date of September 1.
Status of Existing HSTS
Because of the limiting factors associated with the county's soils, many of the leaching systems installed before the 1970s were placed in poorly drained clay soils that had very little or no absorption capacity. The soil permeability was very slow and thus did not allow for suitable effluent treatment and dissipation. Only a few traditional leaching systems have been approved for installation in areas with relatively well-drained sandy soils in the last 20 years in Cuyahoga County.
Several types of discharging systems currently are approved for use as replacement systems. Aeration systems and subsurface sand filter beds preceded by septic tanks typically are used. All aeration systems presently installed must be of a fail-safe design so that no effluent is discharged if the aerator is not operational. Many older aeration systems still are in use throughout the county. These systems are of an antiquated design and usually are not capable of properly treating household wastewater prior to discharging an effluent to the environment.
Likewise, many older subsurface filter bed systems still are in use. These systems used gravel as a filtration media instead of approved filter sand, as is now required. Older filter bed systems are smaller in size and were not designed using two separate beds. Modern subsurface sand filter bed systems are substantially larger in size and utilize a sand media rather than gravel.
On-lot system designs include the evapotranspiration, mound, and drip irrigation systems. The evapotranspiration system design incorporates a large leaching field preceded by an aeration unit. Mound and drip irrigation system guidelines have also been created for use in Cuyahoga County. The CCBH does require that all possible means of installing a nondischarging sewage system be addressed before allowing off-lot discharge of an effluent on replacement systems.
Tables 1 and 2 represent current information from the CCBH database system. The original number for failures and ³older² types of systems was much higher, but over the last 10 years, a number of systems have been evaluated and upgraded. Table 1 illustrates the approximate number of sewage treatment systems by their design classification. The system installed the most in Cuyahoga County over the years has been the subsurface filter bed. It represents nearly half of all the systems in use at present. Actually, this number is substantially higher than the total shown in Table 1. Many of the "unknown" systems are, in fact, filter bed systems. Our records have little information on these unknown systems because most were installed more than 40 years ago.
Table 2 provides information on systems installed before January 1, 1976, and those installed after that date. This date is chosen because it represents the time frame in which the current Ohio Sewage Disposal Rules became effective. These rules included the design specifications for HSTS. Likewise, a system installed in 1976 is now more than 20 years old. The average life expectancy of a typical HSTS that is designed to discharge is considered to be 20 years. This date corresponds to the installation date of a system nearing the end of its effectiveness in providing adequate sewage treatment. Table 2 clearly shows that greater than 65% of these systems are more than 20 years old and now are a concern because of their age.
Sewage System Testing Project Areas
Along with conducting nuisance investigations and point-of-sale evaluations, CCBH sanitarians conduct evaluations of HSTS in specific project areas. Before testing these systems, meetings are held with local officials to discuss methods of prioritizing specific areas within a community. By reviewing nuisance investigations and discussing sanitary sewer feasibility, the CCBH can institute a commonsense sewage system testing strategy in that particular area.
As a testing project begins, all homeowners are notified and asked to schedule evaluations with the CCBH. Educational meetings are conducted before initiating these projects so that details can be discussed with homeowners in the area. Topics include sewage system design, operation, and maintenance. This general information allows the homeowner to better understand sewage system testing procedures and, more importantly, why these systems need to be tested.
After a majority of the sewage systems in an area have been evaluated, the CCBH forwards the results to the appropriate local officials. They use the information, along with available water-quality data, as they discuss potential solutions to the HSTS problems identified in the report. In some circumstances, sanitary sewer installation is feasible. In others, the installation of a sewer is not practical. In these situations, replacing failing HSTS is the solution.
Widespread sewage system testing has allowed the CCBH to gather extensive data on the performance of existing residential sewage systems. Numerous sewage system testing projects have been ongoing since the inception of the O&M program in 1993. These projects have led to the upgrade of thousands of failing sewage systems and the installation of new sanitary sewers.
Malfunctioning/Failing Sewage Systems
More than 3,000 sewage systems now in use in Cuyahoga County are 40-plus years old and were installed without an inspection or the issuance of a permit. These systems, referred to as ³unknown² systems, are extremely undersized and often are found to be in failure. The CCBH computer records show that nearly 65% of those systems evaluated since the inception of the program have been in failure. This figure is not surprising considering the age and antiquated design of these systems. Currently the number of failures is dropping. This number reflects the number of systems replaced, eliminated due to sanitary sewers, and having a larger total number of systems evaluated. Presently, basic system assessments are being conducted, which are an educational tool that provides the homeowner with information on his system and its care and maintenance and allows for the observance of any immediate public health nuisance or concern.
During the last 10 years, more than 2,400 failing sewage systems have been replaced and 5,000 systems have been eliminated by sanitary sewer installations. Nearly 8,900 sewage systems currently in use in Cuyahoga County were installed prior to 1976. This figure represents 65% of all current systems, as compared to 90% in 1993. By utilizing the identified failure rates associated with each type of system, we can conclude that approximately 6,500 sewage systems in use are in failure and are not properly treating household sewage.
The CCBH has been able to aid homeowners who must replace their failing HSTS. The first way was through the establishment of a low-interest loan program through Ohio EPA and local banks. This loan program provides installation of on-lot systems or connection of a home to a sanitary sewer. The current interest rate can be 5% lower than the prime rate. The second is an EPA 319 Implementation Grant for the replacement of failing off-lot HSTS with experimental on-lot systems. This grant allows 55% of the cost of the replacement to be paid through Ohio EPA.
Phase II Stormwater Regulations
Beginning March 10, 2003, the United States and Ohio EPA Phase II stormwater regulations went into effect. These regulations require designated communities to develop and implement stormwater management plans. This program is composed of six minimum control measures: public education, public involvement, illicit discharge detection and elimination, construction-site runoff control, postconstruction-site runoff control, and good housekeeping.
In Ohio, several task force groups were created to aid Phase II regulated communities in developing their 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 to develop their stormwater management plans.
In the CCBH's jurisdiction, 55 communities are designated Phase II communities, and they are impacted greatly by the illicit discharge detection and elimination component of Phase II because of their large number of discharging HSTS. Those discharging HSTS that release to an MS4 are considered illicit sources of discharges and must be identified and eliminated. In Ohio, these communities have five years to identify and assess all the HSTS located within their jurisdiction. Because of our O&M program, the CCBH currently has that information available for these communities, and the locations of all illicit HSTS are available through our database system. In addition, the assessment of these systems has been performed over the last 10 years through the evaluation component of the O&M program. A map can be generated for each community with the locations of the HSTS identified. Information regarding the HSTS performance can also be generated through a query of the database. These communities appreciate the CCBH's overall O&M program and the positions taken during those 10 years.
Furthermore, the CCBH's water-quality program has enabled our department to develop Memorandums of Understanding with our Phase IIdesignated communities to perform outfall sampling during dry-weather flows. Cities are willing to provide additional funding to our department to sample and report water-quality data in designated MS4 outfalls. These data will be used to prioritize areas within each city for the detection and elimination of illicit discharges. The source of these discharges might be sanitary cross-connections, discharging HSTS, or other sources. Likewise, some cities have contracted with our department to find and map all of their MS4 outfall locations. With the experience and relationships we have developed with our communities, it was a natural fit for our department to perform this work. The HSTS in communities that will not be eliminated through the extension of sanitary sewers ultimately will be removed under Phase II. The elimination of illicit HSTS can occur by replacing failing off-lot HSTS with on-lot systems. It also can occur by approving and permitting off-lot HSTS through a general NPDES permit. Ohio EPA is developing rules with the Ohio Department of Health for a general NPDES permit for HSTS. Once established, these systems then can gain coverage under this permit program and be assessed annually for the water-quality parameters set forth in that permit.
The overall educational outreach program that has been developed over the years will provide these communities with many of their educational requirement needs. We will provide outreach seminars and programs with a focus on HSTS, water quality, care and maintenance of systems, and other stormwater information. The CCBH's Web site (www.ccbh.net) also will provide residents of Cuyahoga County with quick access to information.
Author's Bio: Harry Stark, RS, MPA, is watershed protection programs supervisor for the Cuyahoga County Board of Health in Parma, OH.