a) 3.2.3.1.1 & 3.2.3.1.4 Develop, implement, and enforce a program to detect and eliminate illicit discharges into your small MS4 (for illicit discharges to your MS4 via a neighboring interconnected MS4, you are only required to inform the neighboring MS4 and the Ohio EPA in your annual report submission, of their existence).

b) 3.2.3.1.2 Develop a storm sewer system map showing the location of all outfalls and the names and locations of all surface waters of the State that receive discharges from those outfalls.

c) 3.2.3.1.2.1 Within five years of when your coverage under this general permit is granted, you must submit the following to Ohio EPA:

1. 3.2.3.1.2.1.1 A list of all on-site sewage disposal systems connected to discharge
to your MS4 (a.k.a. home sewage treatment systems (HSTS)) including addresses.

2. 3.2.3.1.2.1.2 A storm sewer map showing the location of all HSTS connected
to your MS4. This map shall include details on the type and size of conduits/ditches
in your MS4 that receive discharges from HSTSs, as well as the water bodies receiving
the discharges from your MS4.

d) 3.2.3.1.3 To the extent allowable under State or local law, effectively prohibit through ordinance or other regulatory mechanism illicit discharges to your storm sewer system and implement appropriate enforcement procedures and actions.

e) 3.2.3.1.5 Inform public employees, businesses, and the general public of hazards associated with illegal discharges and improper disposal of waste. 2. Illicit Discharge Detection and Elimination Plan

The BMPs, measurable goals, and responsible parties in this Illicit Discharge Detection and Elimination Plan are detailed in Table 2. In addition to Table 2, per Ohio EPA draft NPDES permit requirement 4.2.3.2, we are documenting our decision process with the following information required by the draft permit. 3.2.3.2.1 How you will develop a storm sewer map showing the location of all outfalls and the names and location of all receiving waters. Describe the sources of information you used for the maps, and how you plan to verify the outfall locations with field surveys. Describe how your map will be regularly updated. A GIS map is being developed to map the outfalls and contributing tributary areas. Where necessary, field investigations will be performed to determine location of outfall. When necessary, GPS survey methods will be used to locate the outfall locations. The map will be updated annually, based on observations made throughout the year. 3.2.3.2.2 The mechanism (ordinance or other regulatory mechanism) you will use to prohibit illicit discharges and why you chose that mechanism. If you need to develop this mechanism, describe your plan and a schedule to do so. If your ordinance or regulatory mechanism is already developed, include a copy of the relevant sections with your program. The Village of Moreland Hills will work with the Board of Health to prohibit illicit discharges through Ohio Revised Code 3707.01 for illicit discharges from HSTS's. The Village is a member of the Chagrin River Watershed Partners, Inc. CRWP will be developing a model ordinance for illicit discharge detection and elimination. We will review this ordinance for its applicability for regulating non-HSTS illicit discharges. 3.2.3.2.3 Your plan to ensure through appropriate enforcement procedures and actions that your illicit discharge regulation is implemented. The Village will implement a program to detect illicit discharges. The Stormwater committee will monitor the progress of the illicit discharge detection program. 3.2.3.2.4 Your plan to detect and address illicit discharges to your system, including discharges from illegal dumping and spills. Your plan must include dry weather field screening for non-storm water flows and field tests of selected chemical parameters as indicators of discharge sources. Your plan must also address on-site sewage disposal systems (including failing on-lot HSTS and off-lot discharging HSTS) that flow into your storm drainage system. Your description must address the following at a minimum: 3.2.3.2.4.1 Procedures for locating priority areas which includes areas with higher likelihood of illicit connections (e.g. areas with older sanitary sewer lines, for example) or ambient sampling to locate impacted reaches. 3.2.3.2.4.2 Procedures for tracing the source of an illicit discharge, including specific techniques you will use to detect the location of the source. 3.2.3.2.4.3 Procedures for removing the source of an illicit discharge. 3.2.3.2.4.4 Procedures for program evaluation and assessment. The priority areas will be identified through consultation with the Board of Health. Initially, areas known to have the oldest HSTS and those with the highest failure rates, based on previous testing and complaints wil be evaluated first. Prioritizing of identified dry weather discharges will then be done by frequency and volume of dry weather flow, and strength of pollutants. Other priority areas will be those outfalls that have commercial properties tributary to them that may have higher concentrations of pollutants. The Village will consult with the Board of Health for testing of dry weather discharges to determine if they are illicit. See the enclosed Memorandum of Understanding regarding testing. Illicit discharges will be traced back to their source through the use of the outfall/drainage maps, visual inspection of flows and dye testing to pinpoint the origin of the discharge. Where needed, television inspection of the storm sewers will be done to locate sources of illicit discharges. The Village will inspect 20-25% of the outfalls annually, due to the large number of HSTS and level of effort that will be necessary due to the their presence. Illicit discharges will be removed, with the assistance of the Board of Health through Ohio Administrative Code 3701-29-02 (Board of Health Powers), Ohio Revised Code 3707.01 and County nuisance regulations. The illicit discharge detection and elimination program will be reviewed by the Stormwater Management Committee and adjusted if necessary. 3.2.3.2.5 How you plan to inform public employees, businesses, and the general public of the hazards associated with illegal discharges and improper disposal of waste. Include in your description how this plan will coordinate with your public education minimum measure and your pollution prevention/good housekeeping minimum measure. Public employees, specifically those in the Service Department, will be trained in the hazards of illicit discharges and the proper good housekeeping during municipal operations through staff meetings and handouts. See MCM #1 for the public education and outreach program that will be used to inform the general public and businesses. 3.2.3.2.6 Who is responsible for overall management and implementation of your storm water illicit discharge detection and elimination plan and, if different, who is responsible for each of the BMPs identified for this plan. The Stormwater Management Committee will be responsible for the implementation of the illicit discharge detection Plan. The Village Engineer will be responsible for the inspection of outfalls, with the assistance of the Service Dept. and the Wastewater Treatment Operator. The County Board of Health will be responsible for the laboratory testing of dry weather flows. The County Board of Health and the appropriate Village officials will be responsible for the elimination of illicit discharges. 3.2.3.2.7 How will you evaluate the success of this minimum measure, including how you selected the measurable goals for each of the BMPs. The information gathered during the illicit discharge detection and elimination program will be tabulated by the Village Engineer and presented to the Stormwater Management Committee. A map will accompany the report to depict the areas inspected, illicit discharge sources found and the status of the elimination of the sources. The measurable goals for illicit discharges will be to:

• Inspect 20-25% of the outfalls per year Eliminate non-HSTS illicit discharges per the current regulations within 12 months of identification of the source
• For HSTS illicit discharges, eliminate or bring into compliance with current regulations within 18 months of identification of the source

Click to view the Memorandum

Table 2: Village of Moreland Hills Illicit Discharge Detection and Elimination Plan