Justin BraggDEQ-WRD Gaylord Field OfficeEnvironmental Quality Analyst

Introduction Discharges of raw or partially treated sewage

Pose significant risks to public health and the environment

Prohibited by State and Federal laws

Why Report CSOs/SSOs According to Michigan Act 451, Public Acts of 1994, as

amended, Part 31, Section 324.3112a any discharge of untreated sewage from a sewer system must be reported.

Failure to do so could result in significant fines and penalties.

Types of Discharges Sanitary Sewer Overflows (SSO)

Combined Sewer Overflows (CSO)

Retention Treatment Basin (RTB) discharges

“Other” discharges

WWTP Bypasses

WWTP Blending

Types of Discharges to Report CSO Discharge – untreated discharges of

combined sewage during wet weather events

RTB Discharge – those from RTB or equivalent structures designed and approved by DEQ to meet CSO permit requirements

SSO Discharge Discharges from separate sewer system during wet or dry

weather

Discharges from combined sewer systems during dry weather

Types of Discharges to Report (cont’d)

Other Bypass events – discharges that bypass one or more treatment

units at a WWTP e.g. disinfection system is down and WWTP discharges secondary

effluent that has not been disinfected

Blending Term used specifically for anticipated wet weather treatment

scenario approved as an interim means to address wet weather flow issues in some NPDES permits.

Generally, during wet weather events, a portion of the influent receives only primary treatment, which is blended with secondary effluent. Blended flow receives disinfection and is then discharged.

Only a few approved blending scenarios in MI

First things First You must contact the following people immediately,

and no more than 24hrs after the discharge: 1. DEQ

2. Local Health Department

3. A daily news paper of general circulation located in the county of the discharge

4. Municipalities may request that you notify them as well if the discharge affects waters in their jurisdiction

if they do not require this you must contact them annually to inform them of any discharges that may have affected them

First things First (cont’d) If discharged to Surface Waters, you are required to test the

receiving waters for E.Coli to access the risk to public health.

Provide a copy of the test results to the local health department and the DEQ.

Testing shall be done at locations specified by the local health department affected.

Testing can be waived by the local health department if they feel testing is unnecessary to access the risk to public health.

At the conclusion of dischargeFile a CSO/SSO report with the following information to the DEQ:

Volume and quality of discharge as measured pursuant to procedures and analytical methods approved by the department – work with DEQ district staff to determine what is acceptable

Reason for discharge

Waters/land affected

Start/stop time of discharge as measured pursuant to procedures approved by the department – work with DEQ district staff to determine what is acceptable

Verification of compliance status

Do you need to report?

If untreated sewage overflows from a sanitary line onto the road, but does not enter the storm drain, do you have to report it?

Yes!

According to Section 324.3112a(1)- If untreated sewage or partially treated sewage is directly or indirectly discharged from a sewer system onto land or into waters of the state, the person responsible for the sewer system

shall immediately, but not more than 24 hours after the discharge begins, notify the department; local health department; a daily newspaper of general circulation in the county in which the discharge occurred or is

occurring.

Do you need to report?If untreated sewage overflows onto the ground from a break in a service line coming from a single residence, do you have to report it?

Why Not? According to 324.3112a (1): Except for sewer systems described in subsection (8), if

untreated sewage or partially treated sewage is directly or indirectly discharged from a sewer system onto land or into the waters of the state, the person responsible for the sewer system shall immediately, but not more than 24 hours after the discharge begins….

According to 324.3112a(9) (b): “Sewer system” means a public or privately owned sewer system designed and used to convey or treat sanitary sewage or sanitary sewage and storm water. Sewer system does not include an on-site wastewater treatment system serving 1 residential unit or duplex.

This has been interpreted to include reporting exemptions for discharges from service lines from single residential units or duplexes. Therefore a discharge from the service line of a single residence doesn’t have to be reported unless the municipality has accepted responsibility in writing for the sewerage system, or was notified by the department of its responsibility for the sewerage system.

.

Do you need to report?Does a discharge from a line servicing a commercial or industrial facility need to be reported (i.e. hotel manufacturing plant)?

Yes!

As we previously talked about, only the reporting exemptions are for single residential units or duplexes. The owner of the of the commercial or industrial facility is required to report the discharge from their service line or any portion of their private sanitary system.

However, they may need help!

Program Updates

No. of SSO Events Per Year & Volume

DEQ Report Form “Report of Discharge” form provided by DEQ (recent

version updated December 2011)

Available at www.michigan.gov/deq , then search “CSO SSO”

Submit by fax or email to DEQ district staff

Make sure form is complete, accurate and timely

Form includes guidance. Also may direct any questions to DEQ district staff

DEQ Report Form

General Information

Prefer in “Millions of Gallons”

cont’d

cont’d

Online Database CSO and SSO Online Database accessible to public

Required by law – Part 31, 3112c

Includes

Discharge information reported

to DEQ

Other general information

Available at:

www.deq.state.mi.us/csosso/

DEQ CSO/SSO Staff Map

http://www.michigan.gov/documents/deq/wrd-cso-sso_350680_7.pdf

Questions?

Justin Bragg

DEQ-WRD Gaylord Field Office

Environmental Quality Analyst

Braggj@Michigan.gov

989-731-4920