&EPA
United States
Environmental Protection
Agency
Office Of Water
(4203)
EPA 833-K-94-002
March 1995
Storm Water Discharges
Potentially Addressed By
Phase II Of The National
Pollutant Discharge
Elimination System
Storm Water Program
\\ Report To Congress
m
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This report has been prepared by the U.S. Environmental Protection Agency, Office of
Wastewater Management, Permits Division (4203), 401 M Street, S.W., Washington, B.C.
20460. Inquiries pertaining to this report should be sent to this address or may be made by
calling (202) 260-9545. Copies are available from the Office of Water Resource Center
(202) 260-7786.
March 1995
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4 ^-. \
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DC 20460
MAR 29B95
THE ADMINISTRATOR
Honorable Albert Gore, Jr.
President of the Senate
Washington, D.C. 20510
Dear Mr. President:
I am pleased to present the Environmental Protection
Agency's (EPA) "Report to Congress on Storm Water Discharges
Potentially to be Addressed by Phase II of the National Pollutant
Discharge Elimination System Storm Water Program." With this
Report as a starting point, I believe, together with Congress and
our other partners, we can make substantial progress in utilizing
more cost-effective and resourceful ways to control storm water
pollution and to protect public health and the environment.
This Report responds to Section 402(p)(5) of the Clean Water
Act and provides data, analysis, and recommendations concerning
the number and type of discharges potentially to be covered by a
phase II storm water program. The Report also identifies the
nature and extent of these discharges and discusses one possible
approach to implementing a phase II storm water program.
Although this Report discusses only one possible approach
for a phase II storm water program, EPA looks forward to working
with Congress, States, Tribes, local governments, and other
stakeholders to identify other options for a phase II program.
Already, EPA is taking steps to explore additional possibilities
by developing partnerships and seeking ideas from all groups that
will be involved. We will draw on our experience with the phase
I storm water program and collaborative efforts with our
stakeholders to ensure a cost-effective storm water program.
As a first step, EPA is establishing an urban wet-weather
advisory group composed of stakeholders from industry, States,
municipalities, commercial and retail establishments,
environmental groups and others, to address policy and technical
issues related to urban wet weather. A storm water phase II
subgroup will be formed to consider cost-effective ways of
addressing pollution from phase II storm water discharges. We
will share the results of these efforts with Congress as they
develop.
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In addition to the phase II efforts, we plan to review and
streamline the phase I storm water program. We will consider
changes to existing monitoring and permitting requirements for
regulated phase I municipal dischargers and will resolve
questions regarding what cities must do under the Act's storm
water control "maximum extent practicable" requirements.
I believe this Report responds fully to the mandates of
Section 402(p)(5) of the Clean Water Act, and I hope Congress
finds it useful in determining how to proceed with the storm
water program.
Sincerely
Carol
Enclosure
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON D C 20460
WR 29
THE ADMINISTRATOR
Honorable Newt Gingrich
Speaker of the House
of Representatives
Washington, D.C. 20515
Dear Mr. Gingrich:
I am pleased to present the Environmental Protection
Agency's (EPA) "Report to Congress on Storm Water Discharges
Potentially to be Addressed by Phase II of the National Pollutant
Discharge Elimination System Storm Water Program." With this
Report as a starting point, I believe, together with Congress and
our other partners, we can make substantial progress in utilizing
more cost-effective and resourceful ways to control storm water
pollution and to protect public health and the environment.
This Report responds to Section 402(p)(5) of the Clean Water
Act and provides data, analysis, and recommendations concerning
the number and type of discharges potentially to be covered by a
phase II storm water program. The Report also identifies the
nature and extent of these discharges and discusses one possible
approach to implementing a phase II storm water program.
Although this Report discusses only one possible approach
for a phase II storm water program, EPA looks forward to working
with Congress, States, Tribes, local governments, and other
stakeholders to identify other options for a phase II program.
Already, EPA is taking steps to explore additional possibilities
by developing partnerships and seeking ideas from all groups that
will be involved. We will draw on our experience with the phase
I storm water program and collaborative efforts with our
stakeholders to ensure a cost-effective storm water program.
As a first step, EPA is establishing an urban wet-weather
advisory group composed of stakeholders from industry, States,
municipalities, commercial and retail establishments,
environmental groups and others, to address policy and technical
issues related to urban wet weather. A storm water phase II
subgroup will be formed to consider cost-effective ways of
addressing pollution from phase II storm water discharges. We
will share the results of these efforts with Congress as they
develop.
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In addition to the phase II efforts, we plan to review and
streamline the phase I storm water program. We will consider
changes to existing monitoring and permitting requirements for
regulated phase I municipal dischargers and will resolve
questions regarding what cities must do under the Act's storm
water control "maximum extent practicable" requirements.
I believe this Report responds fully to the mandates of
Section 402(p)(5) of the Clean Water Act, and I hope Congress
finds it useful in determining how to proceed with the storm
water program.
Sincerely,
Carol M. Browner
Enclosure
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TABLE OF CONTENTS
EXECUTIVE SUMMARY ES-1
Introduction • ES-1
Summary of Key Findings ...... . — . ES-2
Background ES-3
Water Quality Impacts ES-3
Clean Water Act Framework ES-4
Findings ES-6
Municipal Separate Storm Sewer Systems ES-6
Individual Phase II Facilities ES-7
President Clinton's Clean Water Initiative ES-10
CHAPTER 1. INTRODUCTION 1-1
1.1 BACKGROUND ON THE STORM WATER PROBLEM 1-2
1.1.1 National Summary of Impacts 1-3
1.2 THE NPDES STORM WATER PERMIT PROGRAM 1-6
1.2.1 Early Regulatory Approaches 1-6
1.2.2 Water Quality Act of 1987 1-11
1.2.3 Phase I Regulatory Framework 1-13
1.2.4 Phase I Implementation Activities 1-18
1.2.5 September 9, 1992 Notice—Phase II Issues 1-21
1.2.6 Rensselaerville Phase II Effort 1-22
1.2.7 President Clinton's Clean Water Initiative 1-22
1.2.8 NPDES Watershed Strategy 1-25
1.3 RELATED NONPOINT SOURCE PROGRAMS 1-26
1.3.1 Section 319 of the CWA 1-26
1.3.2 Section 6217 of CZARA 1-27
1.3.3 President Clinton's Clean Water Initiative—Nonpoint Source Programs 1-30
1.3.4 President Clinton's Clean Water Initiative—Watershed Management . . 1-30
1.4 DEVELOPMENT OF THIS REPORT 1-31
1.5 ORGANIZATION OF THIS REPORT 1-31
CHAPTER 2. APPROACH 2-1
2.1 OVERVIEW OF APPROACH 2-1
2.2 ANALYSIS OF MUNICIPAL SEPARATE STORM SEWER SYSTEMS 2-4
2.2.1 Identifying Municipal Separate Storm Sewer Systems 2-4
2.2.2 Determining the Nature and Extent of Pollutants Associated With
Municipal Separate Storm Sewer Systems 2-9
2.3 ANALYSIS OF INDIVIDUAL PHASE II DISCHARGES 2-21
2.3.1 Identifying Individual Phase II Storm Water Discharges 2-22
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Table of Contents
2.3.2 Determining the Nature and Extent of Pollutants Associated With
Industrial and Commercial Discharges 2-28
2.4 LITERATURE REVIEW PROCESS '.'.'.'.'. 2-33
2.4.1 Libraries 2-33
2.4.2 Additional Resources 2-34
2.4.3 Potential for Obtaining Additional Information 2-35
CHAPTER 3. MUNICIPAL SEPARATE STORM SEWER SYSTEMS 3-1
3.1 IDENTIFICATION OF MUNICIPAL SEPARATE STORM SEWER SYSTEMS 3-1
3.1.1 Population Distributions 3-2
3.1.2 Identification of Phase I Municipal Systems 3-7
3.1.3 Identification of Potential Phase II Municipal Systems 3-16
3.1.4 Development Trends 3.34
3.2 NATURE OF DISCHARGES FROM MUNICIPAL SYSTEMS 3-36
3.2.1 Major Pollutant Sources 3.39
3.2.2 Imperviousness 3-46
3.2.3 Modification of Natural Stream Channels and Riparian Vegetation .... 3-48
3.2.4 Design Objectives of Drainage System 3-49
3.3 THE EXTENT OF DISCHARGES FROM MUNICIPAL SYSTEMS 3-53
3.3.1 Pollutant Concentrations of Runoff From Residential and Commercial
Areas 3.53
3.3.2 Pollutant Concentrations from Other Urban Land Uses 3-61
3.3.3 Pollutant Loading Estimates 3-62
3.3.4 Floatables/Litter/Plastics 3-65
3.3.5 Population Densities and Imperviousness 3-66
3.4 SUMMARY 3-68
CHAPTER 4. INDIVIDUAL PHASE II DISCHARGES 4-1
4.1 OVERVIEW OF INDIVIDUAL PHASE II SOURCES 4-1
4.1.1 The Phase I Permitting Framework for Industrial Discharges 4-4
4.1.2 Industrial, Commercial, and Retail Sources Not Subject to Phase I Permit
Requirements 4.7
4.2 NATURE AND EXTENT OF POLLUTANTS ASSOCIATED WITH
INDIVIDUAL PHASE II SOURCES 4-22
4.2.1 Nature of Pollutants Associated With Individual Phase II Sources .... 4-24
4.2.2 Geographic Extent of Facilities 4-35
4.3 SUMMARY .- 4.44
4.3.1 Identification of Phase II Sources 4-44
4.3.2 Nature of Phase II Sources 4-45
4.3.3 Geographic Distribution 4-46
BIBLIOGRAPHY
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Table of Contents
APPENDICES
APPENDIX A LIST OF PHASE I MUNICIPAL SEPARATE STORM SEWER SYSTEMS
APPENDIX B OVERVIEW OF IMPACTS FROM STORM WATER DISCHARGES
APPENDIX C NON-STORM WATER DISCHARGES TO STORM WATER
CONVEYANCES
APPENDIX D NPDES STORM WATER PROGRAM QUESTION AND ANSWER
DOCUMENT JULY 1993
APPENDIX E GROUP APPLICATION PART 2 SAMPLING DATA AND INDUSTRY
DESCRIPTIONS ORGANIZED BY INDUSTRY SECTOR
APPENDIX F GROUP APPLICATION PART 2 SAMPLING DATA ORGANIZED BY
POLLUTANT
APPENDIX G GEOGRAPHIC ANALYSIS OF SIC CODES .
APPENDIX H EPA REQUEST FOR COMMENT ON ALTERNATIVE APPROACHES
FOR PHASE II STORM WATER PROGRAM
APPENDIX I REPORT ON THE EPA STORM WATER MANAGEMENT PROGRAM
(RENSSELAERVILLE STUDY)
APPENDIX! SUMMARY OF PHASE II COMMENTS
APPENDIX K SELECTED MANAGEMENT MEASURES DEVELOPED UNDER
SECTION 6217 OF CZARA
APPENDIX L PRESIDENT CLINTON'S CLEAN WATER INITIATIVE (PORTIONS
RELATED TO STORM WATER PROGRAM)
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Table of Contents
LIST OF TABLES
Table ES-1. Five Leading Sources of Water Quality Impairment for Selected Classes of
Waters ES-4
Table ES-2. Estimated Pollutant Loadings From Urban Runoff ES-7
Table ES-3. Geographic Distribution of Potential Phase II Facilities in Relation to
Urbanized Areas ES-10
Table 1-1. Major Sources of Water Quality Impairment 1-5
Table 1-2. Five Leading Sources of Water Quality Impairment for Selected Classes of
Waters 1-5
Table 2-1. Bureau of the Census Definitions of Municipal Entities 2-6
Table 2-2. Population Classifications of Bureau of the Census 2-7
Table 2-3. NURP Project Locations 2-11
Table 2-4. NURP and USGS Summary Statistics—Water Quality Characteristics of
Urban Runoff 2-15
Table 2-5. List of All Two-Digit SIC Code Groups and Industry Description .... 2-24
Table 2-6. List of Periodicals and Journals Searched 2-34
Table 3-1. Size Distribution of Urbanized Areas in 1990 3-5
Table 3-2. Populations in Urbanized Areas 3-6
Table 3-3. Populations Inside and Outside of Metropolitan Areas in 1990 3-7
Table 3-4. Municipalities Addressed by Phase I of the NPDES
Storm Water Program 3-10
Table 3-5. Summary of Phase I Municipalities (by State) 3-11
Table 3-6. Cities With Populations of 100,000 or More Given Exemption Under
Phase I of the NPDES Storm Water Regulations Due to
Combined Sewers 3-14
Table 3-7. Urbanized Areas With One or More Municipality in Phase I of the
NPDES Storm Water Program 3-17
Table 3-8. Municipalities in Urbanized Areas With One or More Phase I
Municipalities 3-20
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality . . 3-25
Table 3-10. Urbanized Areas Without a Municipality in Phase I of the NPDES Storm
Water Program 3-31
Table 3-11. Urbanized Areas With a City With a Population of 100,000 or More but
Without a Phase I Municipality 3-32
Table 3-12. Growth of Urbanized Areas in the United States Between 1950 and 1990 3-34
Table 3-13. Total Resident Population by State: 1990 and 1980 3-38
Table 3-14. Common Pollutants and Non-Industrial Pollutant Sources Associated With
Urban Runoff 3-40
Table 3-15. Summary of Non-Storm Water Discharge Problems 3-43
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Table of Contents
Table 3-16. Summary of Event Mean Concentrations From NURP for Selected
Pollutants . . . 3-55
Table 3-17. Priority Pollutants Detected in at Least 10 Percent of the NURP Samples 3-56
Table 3-18. Comparison of Mean Pollutant Concentrations in Runoff From
Residential and Commercial Areas to Sewage Treatment Plant
Receiving Secondary Treatment ..... i ........ 3-59
Table 3-19. Summary of Water Quality Criteria Exceedances for Pollutants
Detected in at Least 10 Percent of NURP Samples—Percentage of
Samples in Which Pollutant Concentrations Exceed Criteria 3-60
Table 3-20. Estimated Pollutant Loadings in Runoff From Urbanized Areas 3-63
Table 3-21. Annual Pollutant Loadings in Pounds for Selected Pollutant Sources .. 3-64
Table 4-1. Summary of Major SIC Divisions of U.S. Commerce 4-2
Table 4-2. Industrial Facilities That Must Submit Applications for Storm Water
Permits (Phase I) 4-5
Table 4-3. Categories of Activities Not Regulated Under Phase I 4-13
Table 4-4. SIC Codes Selected for Study Based on Screening Procedure . 4-19
Table 4-5. Summary of Group B Phase II Sectors 4-21
Table 4-6. SICs Not Considered as Potential Phase II Sectors 4-23
Table 4-7. Summary of Sampling Data from Phase I Group Permit Applications (with
comparison to NURP and USGS studies) 4-25
Table 4-8. Correspondence Between Potential Phase II Sectors and Phase I Sectors
and Potential Pollutants of Concern 4-31
Table 4-9. Geographic Distribution of Potential Phase II Facilities hi Relation to
Urbanized Areas 4-41
LIST OF TABLES IN APPENDICES
Table B-l. Top Five Pollution Sources and Contaminants B-9
Table B-2. Typical Values of Annual Storm Event Statistics for Rain Zones B-31
Table C-l. Summary of U.S. Coast Guard National Response Center Data on
Discharges of Oil and CERCLA-Regulated Materials During 1987 and
1988 C-ll
Table E-l. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 1 E-3
Table E-2. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 2 . . . E-4
Table E-3. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 3 E-5
Table E-4. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 4 E-7
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Table of Contents
Table E-5. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 5 E-9
Table E-6. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 6 E-10
Table E-7. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 7 E-12
Table E-8. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 8 E-14
Table E-9. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 9 E-15
Table E-10. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 10 E-17
Table E-ll. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 11 E-19
Table E-12. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 12 E-21
Table E-13. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 13 E-23
Table E-14.1. Materials and Sources of Pollutants of Concern E-24
Table E-14.2. Other Potential Pollutant Source Activities E-29
Table E-14.3. Significant Materials Reported in Group Application Number 195 .... E-30
Table E-14.4. Summary Statistics for Waste Recycling Facilities in Group
Application Number 195 (SIC 5093) (Recyclable Liquid Wastes) .... E-31
Table E-14.5. Types of Potential Pollutant-Causing Activities at Waste Recycling
Facilities that Handle Liquid Recyclable Wastes E-32
Table E-14.6. Other Potential Sources of Storm Water Contamination E-33
Table E-14.7. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 14 E-34
Table E-15. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 15 E-35
Table E-16. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 16 E-37
Table E-17. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 17 E-39
Table E-18. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 18 E-41
Table E-19. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 19 E-42
Table E-20. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 20 E-44
Table E-22. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 22 E-45
Table E-23. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 23 E-47
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Table of Contents
Table E-24. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 24 E-48
Table E-25. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 25 E-50
Table E-26. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 26 E-52
Table E-27. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 27 E-53
Table E-28. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 28 £.55
Table E-29. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 29 E-57
Table E-30. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 30 . E-59
Table E-31. Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 31 E-61
Table F-l. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Data) for BOD5 (mg/1) ....... F-2
Table F-2. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for COD (mg/1) . .... F-7
Table F-3. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Data) for NO2 + NO3 - N (mg/1) F-12
Table F-4. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for TKN (mg/1) .... F-17
Table F-5. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Data) for Oil and Grease (mg/1) F-22
Table F-6. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Data) for Total Phosphorus . . F-25
Table F-7. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for TSS (mg/1) F-30
Table F-8. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for Copper (mg/1) . . . F-35
Table F-9. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for Lead (mg/1) .... F-36
Table F-10. Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Studies) for Zinc (mg/1) F-37
VII
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Table of Contents
LIST OF FIGURES
Figure 2-1. Location of NURP Sites 2-12
Figure 2-2. National Distribution of Rainfall Zones and Average Annual Precipitation
(inches/year) 2-18
Figure 2-3. Relationship of Watershed Imperviousness to Runoff Coefficient 2-19
Figure 2-4. Runoff Coefficient Calculated as a Function of Population Density ... 2-21
Figure 3-1. Urbanized Areas of the United States 3-3
Figure 3-2. Metropolitan Areas of the United States 3-8
Figure 3-3. Phase I and Phase II Portions of Milwaukee, Wisconsin, Urbanized Area 3-22
Figure 3-4. Phase I and Phase II Portions of Washington, DC, Urbanized Area ... 3-23
Figure 3-5. Population Growth Forecast Between 1980 and 2010 3-37
Figure 3-6. Population of Bellevue and Peak Annual Discharge hi Kelsey Creek. Data
From USGS and Bellevue Planning Dept, 1977 3-48
Figure 3-7. Relationship Between Population Density and Percent Imperviousness . 3-67
Figure 4-1. Geographic Distribution of Facilities With Selected 4-Digit SIC Codes
(counties with less than 250 facilities are not shown) 4-38
Figure 4-2. Geographic Distribution of Facilities With Selected 4-Digit SIC Codes by
Density (counties with less than .25 facilities per square mile are not
shown) 4-39
LIST OF FIGURES IN APPENDICES
Figure B-l. Population of Bellevue and Peak Annual Discharge hi Kelsey Creek (O).
Data From U.S.G.S. and Bellevue Planning Dept. 1977 . B-7
Figure B-2. Spatial Distribution of the Precipitation-Amount-Weighted Annual Mean
Hydrogen-Ion Concentration (expressed as pH) in North America hi 1980B-19
Figure B-3. Rain Zones of the United States B-30
Figure C-l. Disposal Practices of Households Generating Used Motor Oil C-7
Figure C-2. Disposal Practices of Households Generating Radiator Flushings C-7
Figure C-3. Disposal Practices for Households Generating Waste Paints and Thinner . C-8
Figure C-4. Disposal Practices of Households Pouring Used Oil on the Ground .... C-8
Figure F-l. BOD5 Concentration Storm Water Discharges Grab Samples by Industry
Sector F'3
Figure F-2. BOD5 Concentration Storm Water Discharges Composite Samples by
Industry Sector F~4
Figure F-3. BOD5 Concentration Storm Water Discharges Grab Samples by Industry
Sector F'5
Figure F-4. BOD5 Concentration Storm Water Discharges Composite Samples by
Industry Sector
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Figure F-5. COD Concentration Storm Water Discharges Grab Samples by Industry
Sector p-8
Figure F-6. COD Concentration Storm Water Discharges Composite Samples by
Industry Sector F-9
Figure F-7. COD Concentration Storm Water Discharges Grab Samples by Industry
Sector . . . . i F-10
Figure F-8. COD Concentration Storm Water Discharges Composite Samples by
Industry Sector . F-ll
Figure F-9. Nitrate Plus Nitrite Nitrogen Concentration Storm Water Discharges Grab
Samples by Industry Sector F-13
Figure F-10. Nitrate Plus Nitrite Nitrogen Concentration Storm Water Discharges
Composite Samples by Industry Sector F-14
Figure F-ll. Nitrate Plus Nitrite Nitrogen Concentration Storm Water Discharges Grab
Samples by Industry Sector F-15
Figure F-12. Nitrate Plus Nitrite Nitrogen Concentration Storm Water Discharges
Composite Samples by Industry Sector F-16
Figure F-13. TKN Concentration Storm Water Discharges Grab Samples by Industry
Sector F-18
Figure F-14. TKN Concentration Storm Water Discharges Composite Samples by
Industry Sector F-19
Figure F-15. TKN Concentration Storm Water Discharges Grab Samples by Industry
Sector F-20
Figure F-16. TKN Concentration Storm Water Discharges Composite Samples by
Industry Sector F-21
Figure F-17. Oil & Grease Concentration Storm Water Discharges Grab Samples by
Industry Sector F-23
Figure F-18. Oil & Grease Concentration Storm Water Discharges Grab Samples by
Industry Sector . F-24
Figure F-19. Phosphorus Concentration Storm Water Discharges Grab Samples by
Industry Sector F-26
Figure F-20. Phosphorus Concentration Storm Water Discharges Composite Samples by
Industry Sector F-27
Figure F-21. Phosphorus Concentration Storm Water Discharges Grab-Samples by
Industry Sector F-28
Figure F-22. Phosphorus Concentration Storm Water Discharges Composite Samples by
Industry Sector F-29
Figure F-23. TSS Concentration Storm Water Discharges Grab Samples by Industry
Sector F-31
Figure F-24. TSS Concentration Storm Water Discharges Composite Samples by
Industry Sector F-32
Figure F-25. TSS Concentration Storm Water Discharges Grab Samples by Industry
Sector F-33
Figure F-26. TSS Concentration Storm Water Discharges Composite Samples by
Industry Sector F-34
IX
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Executive Summary
EXECUTIVE SUMMARY
Introduction
Storm water discharges have been linked to one-third of all assessed surface water
quality impairments nationwide by transporting large quantities of pollutants to our Nation's
waterways.1 Significant sources of contaminated storm water include urban runoff,
industrial activities, construction, mining, other types of resource extraction, and different
commercial activities. To address this problem, Congress amended the Clean Water Act
(CWA) in 1987 to establish a phased approach for issuing National Pollutant Discharge
Elimination System (NPDES) permits for storm water discharges.
Phase I of the storm water program, now underway, controls storm water discharges
only from industrial activity and municipal separate storm sewer systems serving populations
greater than 100,000. Many other sources of polluted storm water remain unaddressed. To
deal with them, Congress required the United States Environmental Protection Agency (EPA)
to prepare a study identifying additional sources of storm water contamination and
establishing procedures and methods to control these discharges under a Phase II storm water
program.
This report presents the results of the study to identify potential sources for consideration
hi a Phase II program and a discussion of the nature and extent of pollutants in their
discharges. This report also contains recommendations for how to control Phase n storm
water sources.
1 This estimate is based on information contained in EPA's National Water Quality Inventory, 1992 Report to
Congress, prepared pursuant to the Clean Water Act, Section 305(b), which is based on State reports of assessments of
surface water impacts.
ES-1 •
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Executive Summary
The storm water sources identified in this report and the recommendations for controlling
t»
these sources, represent one possible approach, developed by EPA, to a Phase II storm water
program. Other approaches are also feasible and EPA plans to explore these through a broad
inclusionary process with stakeholders from industry, municipalities, commercial and retail
establishments, environmental groups and other interested parties. This will be done by
establishing a Federal Advisory Committee Act (FACA) subcommittee on Phase II. This
subcommittee will be tasked with examining the key issues for a Phase II storm water
program and with recommending cost-effective ways of addressing pollution from Phase II
sources. The outcome of this effort may be the formulation of a Phase II storm water
program that will differ hi scope and procedure from the approach discussed in this report.
This report includes an introduction to the study (Chapter 1), a description of the
approach used (Chapter 2), an analysis of municipal sources to be included in Phase II
(Chapter 3), and a review of individual sources to be addressed in Phase II (Chapter 4), as
well as numerous appendices, which provide supporting data and information.
Summary of Key Findings
EPA has identified two major classes of potential Phase II storm water discharges that
are described in this report: (1) discharges from municipal separate storm sewer systems not
subject to Phase I and (2) discharges from individual (industrial, commercial, and
institutional) facilities not subject to Phase I.
Based on the identification and analysis of potential Phase II sources and available
information on impacts of storm water discharges, this report recommends that Phase II of
the storm water program focus on the 405 urbanized areas identified by the Bureau of the
Census. As described in President's Clinton's Clean Water Initiative, municipalities hi these
urbanized areas would be authorized to regulate industrial dischargers and to address, as
necessary, commercial, institutional, and retail services within then: jurisdiction using a
flexible approach rather than EPA or the States permitting these sources directly.
ES-2
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Executive Summary
Significant environmental benefit, including reduced pollutant loadings from urbanized
areas, will be obtained by extension of the storm water program to these areas. As
summarized below and explained in detail in this report, urbanized areas contain a large
percentage of population and population growth, as well as industrial, commercial, and retail
facilities, while constituting only 2 percent of the total land area. Focusing Phase II of the
storm water program on urbanized areas thus targets the highest concentration of pollutant
sources and maximizes the potential benefits.
Background
Water Quality Impacts
While rainfall and snow are natural events, the nature of runoff and its impact on water
resources are highly dependent on human activities and the use of the land. Storm water
runoff can affect surface water quality in two basic ways: (1) natural flow patterns can be
radically altered; and (2) pollution concentrations and loadings can be highly elevated.
The National Water Quality Inventory, a report prepared every 2 years summarizing
biennial State reports required by Section 305(b) of the CWA, provides a national assessment
of surface water impacts associated with runoff from various land uses. The most recent
report hi this series, The National Water Quality Inventory, 1992 Report to Congress,
concludes that storm water runoff from a number of diffuse sources, including agricultural
areas, municipal separate storm sewers, urban runoff, and atmospheric deposition, are the
leading cause of surface water quality impairment cited by States. Five leading contributors
to use impairment are shown in Table ES-1.
Storm water runoff from urbanized areas and industrial and commercial activities can
contain high levels of contaminants, such as sediment, suspended solids, nutrients, heavy
metals, pathogens, toxics, oxygen-demanding substances, and floatables.2 In urban areas,
2 National Water Quality Inventory: 1992 Report to Congress, EPA, 1994.
ES-3
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Executive Summary
Table ES-1. Five Leading Sources of Water Quality Impairment
for Selected Classes of Waters
Rank
1
2
3
4
5
Rivers
Agriculture
Municipal Point Sources
Urban Runoff / Storm Sewers
Resource Extraction
Industrial Point Sources
Lakes
Agriculture
Urban Runoff / Storm Sewers
Hydrologic / Habitat Modification
Municipal Point Sources
Onsite Wastewater Disposal
Estuaries
Municipal Point Sources
Urban Runoff / Storm Sewers
Agriculture
Industrial Point Sources
Contaminated Sediments
Source: National Water Quality Inventory, 1992 Report to Congress, EPA, 1994.
the cumulative effect of widespread development will also change natural drainage patterns,
causing much higher wet-weather peak flows and reduced dry-weather base flows hi urban
streams and wetlands. Increased peak flows can cause severe hydromodifications such as
stream bank erosion, streambed scour, flooding, channelization, and alteration and/or
elimination of habitat.3 These flows will also accumulate and transport pollutants to
receiving waters. These pollutants are generated from the numerous human activities within
the urban area. Industrial and commercial operations, which are generally located hi urban
areas, can be significant sources of storm water contamination because of the nature of
activities conducted, and materials stored, outdoors.
Appendix B provides an overview of the impacts associated with different pollutant
classes and types of receiving waters and ground water. Pollutants associated with
widespread urban development are discussed hi Chapter 3. Pollutants associated with
selected classes of industrial and commercial activities are discussed hi Chapter 4.
Clean Water Act Framework
The 1972 amendments to the Federal Water Pollution Control Act (referred to as the
Clean Water Act [CWA]) prohibit the discharge of any pollutant to navigable waters from a
3 Environmental Impacts of Storm Water Discharges—A National Profile, EPA, June 1992, EPA 841-R-92-001.
ES-4
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Executive Summary
point source unless the discharge is authorized by a National Pollutant Discharge Elimination
System (NPDES) permit issued under Section 402. In 1987, Section 402(p) was added to the
CWA to modify the framework for addressing point source discharges composed entirely of
storm water ("storm water discharges") under the NPDES program,4 establishing a phased
'approach for issuing NPDES storm water permits. Phase I of the program addresses storm
water from industrial facilities and discharges from municipal separate storm sewer systems
serving populations of 100,000 or more. Section 402(p)(5) of the CWA directs EPA, in
consultation with the States, to study additional storm water discharges not addressed by
Phase I. Sections 402(p)(5)(A) and (B) direct EPA, hi consultation with the States, to:
• Identify those storm water discharges or classes of storm water discharges for which
National Pollutant Discharge Elimination System (NPDES) permits are not required
under Phase I of the NPDES storm water program
• Determine, to the maximum extent practicable, the nature and extent of pollutants hi
such discharges.
Section 402(p)(5)(C) of the CWA requires EPA to establish procedures and methods to
control Phase II storm water discharges necessary to mitigate impacts on water quality.
Recommendations for procedures and methods to control Phase II storm water discharges are
summarized hi this report and described hi detail hi President Clinton's Clean Water
Initiative, which is found hi Appendix L. Together, this report, and President Clinton's
Clean Water Initiative, fulfill the requirements of Section 402(P)(5) of the CWA.
Section 402(p)(6) of the CWA requires EPA, hi consultation with State and local
officials, to issue regulations for controlling designated Phase II storm water discharges
necessary to protect water quality. The regulations must, at a minimum, establish priorities,
requirements for State storm water management programs, and expeditious deadlines. The
4 Storm water is defined in the NPDES regulations as "storm water runoff, snow melt runoff, and surface runoff
and drainage." (40 CFR 122.26(b)(13))
ES-5
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Executive Summary
program may include performance standards, guidelines, guidance, management practices,
and treatment requirements, as appropriate.
Findings
Municipal Separate Storm Sewer Systems
The Bureau of the Census estimates that the population of the United States and
associated territories was more than 252.2 million in 1990s. The concept of urbanized areas
as defined by the Bureau of the Census served as an important tool for analyzing potential
approaches to a Phase II program that addresses municipal separate storm sewer systems.
More than 160 million people (63 percent of the total U.S. population) reside hi the 405
urbanized areas, each with a population of 50,000 or more. The Bureau of the Census has
defined an urbanized area as a central city (or cities) surrounded by a densely settled area.
To meet the Bureau of the Census definition, the population of the entire urbanized area must
be greater than 50,000 persons and the closely settled area outside of the city, the urban
fringe, must have a population density generally greater than 1,000 persons per square mile
(just over 1.5 persons per acre). These areas occupy less than 2 percent of the Nation's total
land area and represent the largest, most widespread areas of dense urban development in the
country.
The majority of new urban development also occurs hi these urbanized areas.
Construction activity related to new development is recognized as a significant source of
pollution and impairment of waterbodies, providing some of the best opportunities for
implementing storm water management controls hi a highly cost-effective fashion. Between
1980 and 1990, the population of urbanized areas increased by 21.2 million.6 Statistics on
5 Population estimates based on the 50 States, the District of Columbia, Guam, the Commonwealth of Puerto
Rico, the Virgin Islands, American Samoa, and the Commonwealth of the Northern Mariana Islands.
6 About 7 percent of this increase, (1.5 million people) are associated with the net addition of 30 new urbanized
areas between 1980 and 1990.
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Executive Summary
the population, number of urbanized areas, and estimated pollutant loads in runoff in
urbanized areas are summarized in Table ES-2 and discussed below.
Phase I of the NPDES program for storm water discharges addresses 81.7 million people
in portions of 136 urbanized areas.7 EPA estimates that about 40 percent of the pollutant
loads hi storm water discharged from urbanized areas come from Phase I municipalities.
The portions of these 136 urbanized areas that are not addressed by Phase I had a
combined population of 35.8 million people in 1990. EPA estimates that 28 percent of the
pollutant loads hi storm water discharged from urbanized areas come from these Phase II
portions of the 136 urbanized areas with a Phase I municipality.
Of the Census-designated urbanized areas, 269 do not have any municipalities subject to
Phase I of the storm water program. EPA estimates that 32 percent of the pollutant loads hi
storm water discharged from urbanized areas come from these 269 urbanized areas.
In addition to populations within urbanized areas discussed above, the Bureau of the
Census has identified an additional urban population of 29 million people that live outside
urbanized areas, as well as 62.8 million people classified as rural. Although discharges from
municipal separate storm sewers serving these populations are potential Phase II sources,
they are not addressed in detail in this report.
Individual Phase II Facilities
The findings of this report are summarized hi terms of the identification, nature, and
extent of unregulated individual facilities. Due to very limited national data on which to base
7 There are 621 incorporated places (cities) and portions of 77 counties within these 136 urbanized areas. Of
these municipalities, 140 cities and 45 counties are specifically identified in the NPDES regulations that were
published in November 1990. EPA and authorized NPDES States have designated an additional 481 cities and 32
counties as Phase I municipalities. In addition, approximately 30 municipalities (located in 21 urbanized areas) have
received combined sewer exclusions where the total population served by separate storm sewers is less than 100,000
after subtracting the population served by combined sewers. The methodology used to classify municipalities as
Phase I vs. Phase II for the purposes of this report is discussed in Chapter 2.
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Executive Summary
Table ES-2. Estimated Pollutant Loadings From Urban Runoff
Population
Classification Category
NATIONAL
ALL URBANIZED AREAS 50,000 - 99,999
100,000 -249,999
Over 250,000
TOTAL
URBANIZED AREAS AFFILIATED WITH PHASE I
MUNICIPAL SEPARATE STORM SEWER SYSTEMS (MS4)
- Phase I MS4s within Phase I
affiliated Urbanized Areas 50,000 - 99,999
100,000 - 249,999
Over 250,000
SUBTOTAL
- Phase n Portions of Phase I
affiliated Urbanized Areas 50,000 - 99,999
100,000 - 249,999
Over 250,000
SUBTOTAL
TOTAL
URBANIZED AREAS NOT AFFILIATED WITH A PHASE I
MS4
- Urbanized Areas Not Affiliated
with Phase I MS4s 50,000 - 99,999
100,000 -249,999
Over 250,000
TOTAL
- Urbanized Areas Containing a
City with a CSO Exemption** 50,000 - 99,999
100,000 -249,999
Over 250,000
TOTAL
PHASE I MS4s OUTSIDE URBANIZED AREAS
Number of
Urbanized
Areas*
405
176
125
104
405
8
47
81
136
8
47
81
136
136
168
78
23
269
0
7
14
21
NA
Population1"
(millions)
252.2
12.2
19.5
128.7
160.4
0.4
6.3
75.0
81.7
0.2
1.9
33.7
35.8
117.5
11.6
11.3
20.0
42.9
• 0
1.5
16.0
17.5
4.3
Percentage of
Urbanized Area
Loading
NA
12
16
72
100
0
5
35
40
1
2
25
28
68
11
9
12
32
0
1
9
10
NA
* Totals are based upon 1990 Census, and include Puerto Rico, Guam, Virgin Islands, American Samoa, and the
Commonwealth of the Northern Mariana Islands.
** Some municipalities identified in the November 1990 application regulations (55 FR 47990) as Phase I based on 1980
census data received combined sewer exclusions from Phase I where the total population served by separate storm sewers
was less than 100,000 after subtracting the population served by combined sewers. (The 21 urbanized areas [with a
population of 17.5 million] containing these municipalities are also contained in the above totals and are not in addition to
those totals.)
ES-8
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Executive Summary
loadings estimates, the discussion of the extent of unregulated storm water discharges is
limited to an analysis of the number and geographic distribution of the potential Phase II
facilities. In general, the distribution of these facilities follows the distribution of population
with a large percentage of facilities concentrated within urbanized areas.
EPA's efforts to identify sources and categories of storm water discharges for Phase II of
the storm water program started with an examination of approximately 7.7 million
commercial, retail, industrial, and institutional facilities for which permits are not required in
Phase I. This examination resulted hi the identification of two general classes of facilities
with the potential for discharging pollutants to waters of the United States through storm
water point sources. The first group (Group A) includes sources that are very similar, or
identical, to Phase I activities but that were not included hi Phase I due to the specific
language of the statute or EPA's regulatory specificity hi defining the universe of Phase I
industrial activities. The second general class of facilities (Group B) were identified on the
basis of potential activities and pollutants that may contribute to storm water contamination.
EPA estimates that there are approximately 100,000 facilities in Group A. Facilities in
this group, which may be of high priority for Phase II due to their similarity to Phase I
industrial facilities include: auxiliary facilities or secondary activities (i.e., maintenance of
construction equipment and vehicles, local trucking for an unregulated facility such as a
grocery store); facilities intentionally omitted from Phase I (i.e., treatment works with a
design flow of less than 1 MGD, landfills that have not received industrial waste); and
facilities exempted by the Intermodal Surface Transportation Efficiency Act of 1991 (most
industrial activities owned or operated by municipalities of less than 100,000 people8).
Group B consists of nearly one million facilities. These have been organized into 18
Phase II sectors for the purposes of this report. Of these 18 sectors, the automobile service
8 The Intermodal Surface Transportation Efficiency Act of 1991 exempted industrial activities owned or
operated by municipalities of less than 100,000 population from Phase I permitting requirements with the exception of
powerplants, airports, and uncontrolled sanitary landfills.
ES-9
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Executive Summary
sector (composed of gas/service stations, general automobile repair, car dealers, new and
used, car and truck rental, etc.) makes up more than one-third of the total number of
facilities identified in all 18 sectors. The 18 Phase II sectors are listed in Table ES-3.
EPA conducted a geographical analysis of these industrial and commercial facilities.
The geographical analysis shows that the majority are located in urbanized areas, as
presented in Table ES-3. In general, about 30 percent of potential Phase II facilities are
found within the geographic jurisdiction of a Phase I municipality. Including the urbanized
areas surrounding these Phase I municipalities adds another 12 to 13 percent of potential
Phase n facilities. If all urbanized areas are included, an additional 16 percent of potential
Phase n facilities are represented. Thus, nearly twice as many industrial facilities are found
in all urbanized areas as are found in Phase I municipalities alone.9
President Clinton's Clean Water Initiative
President Clinton's Clean Water Initiative provides recommendations on how best to
address the additional storm water sources identified by the study hi a Phase II NPDES storm
water program. The goal of President Clinton's Clean Water Initiative is to ensure that
future storm water pollution prevention and management programs are focused where the
maximum potential benefits can be obtained for the least cost, as well as to provide
additional flexibility. A cost-benefit analysis was prepared for the President's Initiative and
is summarized hi Appendix L. No further cost-benefit analyses were conducted for this
report.
The President's Initiative recommends that Phase II requirements focus on system-wide
permits for municipal separate storm sewer systems hi Census-designated urbanized areas.
These areas consist of only 2 percent of the total land area, yet contain 63 percent of the
9 Notable exceptions to this generalization include lawn/garden establishments, small currently unregulated feedlots,
wholesale livestock, farm and garden machinery repair, bulk petroleum wholesale, farm supplies, lumber and building
materials, agricultural chemical dealers, and petroleum pipelines, which can frequently be associated with smaller
municipalities or rural areas.
ES-10
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Executive Summary
Table ES-3. Geographic Distribution of Potential Phase H Facilities
in Relation to Urbanized Areas
Potential Phase II Facilities Identified
Description
Phase n - Group A
Phase n - Group B
Group B Sectors
Automotive Service
Machinery & Electrical Repair
Intensive Ag. Chemical Use
Wholesale, Machinery
Laundries
Wholesale, Wood Products
Livestock, Feedlots
Petrol. Pipelines & Distributors
Photographic Activities
Various Utilities
Extensive Ag Chem Use
Transport, Rail and Other
Wholesale, Metal Products
Wholesale, Food
Laboratories
Muni. Services, Vehicle Maint.
National Security
Wholesale, Coal & Ores
Count
100,000*
1,015,239
Cumulative % of Facilities
Located Within:
Phase I Areas
32
28
Phase I Areas +
UAs
45
40
All UAs
61
56
369,870
135,744
121,861
77,562
51,376
48,593
43,421**
35,319
30,684
22,242
18,992
14,808
14,303
11,372
10,683
4,611
2,414
1,384
27
29
26
32
38
26
8
16
40
24
31
47
36
36
38
25
34
23
38
40
38
47
52
36
11
25
53
36
42
64
54
49
56
35
43
31
55
56
54
65
71
53
20
39
70
53
62
81
75
67
74
51
60
48
* This figure is an approximation based on the total number of facilities in SIC codes 10 through 45 after
subtracting an estimate of the number of facilities covered under Phase I. Geographical distribution information
is based on all facilities in SIC codes 10 through 45, and may not be representative of all classes of facilities in
this group. For the geographic distribution of specific SIC codes, refer to Appendix G.
** This number is based on SIC codes and does not reflect all feedlots potentially subject to Phase II. The
United States Department of Agriculture has estimated that there are approximately 378,000 animal feeding
operations between 20 and 1000 animal units. The facilities identified here should be representative of feedlots
in general and allow estimation of the distribution of these facilities as a class.
ES-11
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Executive Summary
total population. Phase H areas account for nearly 60 percent of the loadings from urbanized
areas, one and a half times the loadings from Phase I areas. In addition, 57 percent of the
national population growth over the past decade has occurred in Phase II areas, compared to
30 percent in Phase I.
The President's Initiative contains flexibility hi its recommendation that municipalities be
authorized to regulate industrial discharges and to address commercial, institutional, and
retail sources as necessary within their jurisdiction. This would allow municipalities to
control Phase H sources using a flexible approach which would be less costly than having
EPA or States permitting individual Phase II sources directly through individual or general
permits. Facilities which could certify that there will be no exposure of contaminant sources
to rain water and snow melt could be exempted from the storm water program altogether.
This change would release low-risk facilities from NPDES requirements, allowing allocation
of resources to more critical areas. This would also effectively create incentives for facilities
to eliminate exposure of contaminants to rain and snow.
ES-12
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Chapter 1—Introduction
CHAPTER 1. INTRODUCTION
The 1972 amendments to the Federal Water Pollution Control Act (referred to as the
Clean Water Act [CWA]) prohibited the discharge of any pollutant to navigable waters from
a point source unless the discharge is authorized by a National Pollutant Discharge
Elimination System (NPDES) permit. In 1987, Section 402(p) was added to the CWA to
modify the framework for addressing point source discharges of storm water under the
NPDES program. This provision established a phased approach for issuing NPDES permits
for storm water discharges. Phase I of the program addresses storm water from industrial
facilities and discharges from municipal separate storm sewer systems serving a population of
100,000 or more. Section 402(p)(5) of the CWA directs the United States Environmental
Protection Agency (EPA), in consultation with the States, to study additional storm water
discharges not addressed by Phase I of the program. Section 402(p)(5) requires a study for
the purpose of:
(A) Identifying those storm water discharges or classes of discharges for which
permits are not already required as part of the first phase of the NPDES storm
water program, and
(B) Determining, to the maximum extent practicable, the nature and extent of
pollutants hi such discharges.
(C) Establishing procedures and methods to control storm water discharges to the
extent necessary to mitigate impacts on water quality.
Section 402(p)(6) of the CWA provides for EPA to issue regulations that designate
additional storm water discharges to be controlled to protect water quality under Phase II of
the program and to establish a comprehensive program to regulate such designated sources.
The program shall, at a minimum, establish priorities, requirements for State storm water
management programs, and expeditious deadlines. The program may include performance
standards, guidelines, guidance, and management practices and treatment requirements, as
1-1
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Chapter 1—Introduction
appropriate. This report presents the results of the study required under Section 402(p)(5) of
the CWA.
1.1 BACKGROUND ON THE STORM WATER PROBLEM
While rainfall and snow are natural events, the nature of runoff and its impact on water
resources is highly dependent on human activities and use of land. Runoff from lands
modified by human activities can affect surface water resources in two ways: (1) natural
flow patterns can be modified; and (2) pollution concentrations and loadings can be elevated.
Prior to development of land, a natural hydraulic cycle exists. Rainfall infiltrates to
recharge ground water supplies and surface runoff drains through the natural streams which
flow to form a watershed. Natural flow patterns can be modified by activities that make the
land surfaces more impervious. Activities that alter the natural vegetation can change the
natural infiltration characteristics of a watershed. This is particularly evident where
widespread urban development occurs. Urban land use results in the removal of vegetation
cover and the building of impervious structures such as roads, parking lots, sidewalks, and
buildings. In urban areas, the cumulative effect of widespread development may bring
dramatic changes to natural drainage patterns, which can cause much higher wet-weather
peak flows and reduced dry-weather base flows in urban streams and wetlands. Increased
peak flows can cause hydromodifications such as stream bank erosion, streambed scour,
flooding, channelization, and elimination and/or alteration of habitat.1 Additional
hydromodifications result from engineered activities to accommodate higher peak flows, such
as channel excavation, lining (retaining walls, rip-rap), realignment, underground culverts,
and draining of wetlands.
Increased imperviousness and loss of wetlands and natural flow channels associated with
urban development also decreases the amount of rainwater available for ground water
1 Environmental Impacts of Storm Water Discharges—A National Profile, EPA, June 1992, EPA 841-R-92-001.
1-2
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Chapter 1—Introduction
recharge. Reduced ground water levels lower base flows in streams during dry weather
periods, which impairs the aquatic habitat, impairs riparian wetlands, and makes receiving
streams more sensitive to other pollutant inputs and sedimentation.
Different activities and land uses can also contribute a wide variety of pollutants to
runoff. Appendix B provides an overview of different types of impacts associated with
different pollutant classes and types of receiving waters and ground water. Pollutants
associated with widespread urban development are discussed in Chapter 3. Pollutants
associated with selected classes of industrial and commercial activities are discussed in
Chapter 4. Chapter 2 provides a description of the methodology and analysis used to
develop Chapters 3 and 4.
1.1.1 National Summary of Impacts
The National Water Quality Inventory, a report prepared every 2 years summarizing
biennial State reports, as required by Section 305(b) of the CWA, provides a national
assessment of surface water impacts associated with runoff from various land uses. The
most recent report hi this series, The National Water Quality Inventory, 1992 Report to
Congress provides a general assessment of water quality based on State reports indicating the
portion of the States' waters that have been assessed that are not supporting designated uses.
The report identifies the sources of use impairment for those waters (e.g., diffuse sources,
point sources, and natural sources). Based on information from 51 States and Territories that
reported on sources of pollution, the 1992 report indicates that roughly 40 to 60 percent of
assessed rivers, lakes, and estuaries are not supporting the uses for which they are
designated. In addition, 98 percent of the Great Lake shorelines assessed and 20 percent of
the Ocean Coastal Waters were not fully supporting designated uses.
The National Water Quality Inventory, 1992 Report to Congress concludes that storm
water runoff from a number of diffuse sources, including agricultural areas, separate storm
sewers, urban runoff, and atmospheric deposition, is the leading cause of water quality
1-3
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Chapter 1—Introduction
impairment cited by States. Summaries of the major sources contributing to use impairment
are provided in Tables 1-1 and 1-2.
The National Water Quality Inventory indicates that where impairment occurs, the type
of land use (e.g., agriculture, urban, resource extraction) within a watershed is often related
to the impairment. Urban land use, while only occupying a small fraction of the total land
area of the country,2 is responsible for a disproportionately high percentage of impairment.
Urban land use is expected to be correlated to a number of major sources of impairment
identified in the National Water Quality Inventory, including municipal point sources,
separate storm sewers, urban runoff, combined sewer overflows, and many industrial point
sources. At the same time, surface water resources in and near urban populations supply
drinking water to 200 million U.S. citizens and provide recreational opportunities for
millions more.3
The agricultural category listed hi the Inventory comprises a number of activities, most
of which are exempt from the definition of "point source" hi Section 502(14) of the CWA
which, in part, determines the jurisdiction of the NPDES program. One class of sources
related to agriculture that is specifically identified in the statutory definition of point source is
concentrated animal feeding operations (CAFOs). As discussed below, EPA has issued
regulations to define the scope of the term "concentrated animal feeding operation."
Although the contribution of various agricultural activities is difficult to evaluate
independently, EPA has estimated that feedlots (which include both CAFOs identified as
point sources under the NPDES regulations and other feedlots that are not addressed by the
regulatory definition) contribute to 13 percent of impaired river miles, 7 percent of unpaired
2 For example, the 1990 Census indicates that 64 percent of the United States population lives in Census-
designated urbanized areas of 50,000 or more. However, these urbanized areas are located on less than 2 percent of
the total land area of the country. Other development, including smaller urban populations in areas of 10 acres or
more and rural transportation, account for an additional 2 percent of land area. By comparison, agricultural
activities, including cropland, pasture land and range land, account for 49 percent of the land in the United States.
(See Summary Report, 1987National Resources Inventory, Soil Conservation Service, December 1987).
President Clinton's Clean Water Initiative, 1994.
1-4
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Chapter 1—Introduction
Table 1-1. Major Sources of Water Quality Impairment
Percent of Waters Assessed
Percent of Assessed Waters Not Fully
Supporting Use
Percent of Waters Not Fully Supporting
Use That is Attributed to Source
Industrial Point Sources
Municipal Point Sources
Combined Sewer Overflows
Separate Storm Sewers/Urban Runoff
Agriculture
Resource Extraction
Hydrologic/Habitat Modification
On-Site Wastewater Disposal
Contaminated Sediments
Land Disposal
Atmospheric Deposition
Rivers
18
44
7
15
11
72
11
7
Lakes
46
57
21
24
56
23
16
Estuaries
74
44
23
53
43
43
12
Great Lake
Shorelines
99
98
8
11
40
31
50
Ocean Coastal
Waters
6
20
29
59
25
42
Explanation of Pollutant Sources
Industrial Point Sources: Industrial process discharges and cooling water
Municipal Point Sources: Sewage treatment plants, including package plants
Combined Sewer Overflows: Discharges from sewage collection systems of sanitary sewage and runoff
Separate Storm Sewers/Urban Runoff: Discharges from separate storm sewers and other urban runoff
Agriculture: Crop production, pastures, rangeland, feedlots, animal holding/management areas, manure lagoons,
aquaculture, and irrigation return flows
Silviculture: Forest management, harvesting, residue maintenance and road construction and maintenance
Resource Extraction: Mining and mine drainage
Hydrologic/Habitat Modification: Channelization, dredging, dam construction, flow regulation, bridge construction,
streambank modification/destabilization, drainage/filling of wetlands
Land Disposal: Sludge, wastewater, landfills, industrial land treatment, septic systems, hazardous waste, sewage disposal
Source: National Water Quality Inventory: 1992 Report to Congress, EPA, 1994.
Table 1-2. Five Leading Sources of Water Quality Impairment
for Selected Classes of Waters
Rank
1
2
3
4
5
Rivers
Agriculture
Municipal Point Sources
Urban Runoff / Storm Sewers
Resource Extraction
Industrial Point Sources
Lakes
Agriculture
Urban Runoff / Storm Sewers
Hydrologic / Habitat Modification
Municipal Point Sources
Onsite Wastewater Disposal
Estuaries
Municipal Point Sources
Urban Runoff / Storm Sewers
Agriculture
Industrial Point Sources
Contaminated Sediments
Source: National Water Quality Inventory, 1992 Report to Congress, EPA, 1994.
1-5
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Chapter 1—Introduction
lake acres, 3 percent of impaked estuary square miles, and negligible amounts of impairment
in the Great Lakes and Coastal areas.4
1.2 THE NPDES STORM WATER PERMIT PROGRAM
The appropriate means of regulating storm water point sources within the NPDES
program has been debated since the establishment of the NPDES program in 1972. Each
attempt to devise a workable program has been the focus of substantial controversy
concerning the water quality impacts, large number of storm water sources, nature of storm
water runoff, and constraints of program priorities and resources.
1.2.1 Early Regulatory Approaches
In 1973, EPA promulgated regulations that exempted a number of categories of point
sources from NPDES permit requkements, including: silvicultural point sources; CAFOs
below a certain size; irrigation return flows from areas of less than 3,000 contiguous acres or
3,000 noncontiguous acres that use the same drainage system; nonfeedlot, nonirrigation
agricultural point sources; and separate storm sewers containing only storm runoff
uncontaminated by any industrial or commercial activity (38 FR 13530 (May 22, 1973)).
The Agency maintained that exemptions were appropriate to conserve the Agency's
enforcement resources for more significant point sources of pollution. In addition, the
Agency noted that the characteristics of runoff pollution make it difficult to promulgate
numeric effluent limitations for most of the point sources exempted by the 1973 regulations.
The Natural Resources Defense Council (NRDC) brought suit in the U.S. District Court
for the District of Columbia challenging the Agency's authority to selectively exempt
categories of point sources from permit requkements, NRDC v. Train, 396 F.Supp. 1393
(D.D.C. 1975), aff'd, NRDC v. Costle, 568 F.2d 1369 (D.C. Ck. 1977). The District Court
held that EPA could not exempt discharges identified as point sources from regulation under
4 The Report of the EPA/State Feedlot Workgroup, EPA, September 1993.
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Chapter 1—Introduction
the NPDES permit program. However, in acknowledging the administrative burden placed
on the Agency by requiring individual permits, the court recognized EPA's discretion to use
certain administrative devices, such as area or general permits, to help manage its workload.
In addition, the court recognized some discretion on EPA's part to define what constitutes a
point source.
In response to the District Court's decision in NRDC v. Train, EPA issued a series of
regulations addressing discharges from separate storm sewers (March 18, 1976, (41 FR
11307)), CAFOs (March 18, 1976, (41 FR 11458)), agricultural activities (July 12, 1976 (41
FR 28493)), silviculture activities (June 18, 1976 (41 FR 24709)), and aquaculture projects
(May 17, 1977 (42 FR 25478)). Each of these regulations defined classes of point source
discharges that would be subject to the NPDES permit program and exempted other classes
of discharges from NPDES jurisdiction.
The regulations addressing NPDES requirements for agricultural activities defined the
term agricultural point source to include any discernible, confined, and discrete conveyance
from which any irrigation return flow is discharged into navigable waters. In response to
these regulations, Congress amended the CWA hi 1977 to specifically exclude return flows
from irrigated agriculture from the definition of agricultural point source.5 In 1987,
Congress further amended the CWA to exclude agricultural storm water from the definition
of agricultural point source.
The regulations addressing NPDES requirements for silvicultural activities defined the
term silvicultural point source to include any discernible, confined, and discrete conveyance
related to rock crushing, gravel washing, log sorting or log storage facilities which are
5 President Clinton's Clean Water Initiative (1994) recommends that EPA, with the concurrence of the
Departments of Agriculture and the Interior, and after consultation with States and other Federal agencies, should
submit a report to Congress within two years after reauthorization of the CWA that evaluates the nature and extent of
water quality problems presented by irrigation return flows, identifies the most promising and cost-effective technical
and programmatic solutions to these problems, and recommends appropriate actions, including programmatic
improvements and necessary legislative changes.
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Chapter 1—Introduction
operated in connection with silvicultural activities and from which pollutants are discharged
into navigable waters. The regulation clarified that the term did not include nonpoint source
activities inherent to silviculture such as nursery operations, site preparation, reforestation
and subsequent cultural treatment, thinning, prescribed burning, pest and fire control,
harvesting operations surface drainage, and road construction and maintenance from which
there is runoff.
The regulations addressing NPDES requirements for CAFOs clarified that CAFOs are
point sources. CAFOs are defined as animal feeding operations that discharge to waters of
the United States at times other than during events greater than a 25-year, 24-hour storm and
that (1) have more than 1,000 animal units; (2) have more than 300 animal units and
pollutants are discharged into navigable waters through a man-made flushing system.or other
man-made device, or pollutants are discharged directly into waters of the United States which
originate outside of and pass over, across or through the facility or otherwise come into
direct contact with the animals confined hi the operation; or (3) are designated by EPA or an
authorized NPDES State upon determining that it is a significant contributor of pollution to
waters of the United States.
The regulations addressing NPDES requirements for concentrated aquatic animal
production facilities (CAAPFs) clarified that CAAPFs are point sources. CAAPFs are
defined as a hatchery, fish farm or other facility which harvest fish over specified limits or
which is otherwise designated by EPA or an authorized NPDES State upon determining that
it is a significant contributor of pollution to waters of the United States.
The regulations addressing separate storm sewers established a comprehensive permit
program. This rule substantially increased the number of storm water discharges subject to
the NPDES program. Permits continued to be required for conveyances carrying
contaminated storm water runoff from areas used for industrial or commercial activities, as
well as storm water discharges designated by the permit-issuing authority as significant
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Chapter 1—Introduction
contributors of pollution. These sources were required to submit individual permit
applications required of industrial and commercial process wastewater dischargers. In
addition, the 1976 rule brought into the permitting program separate storm sewers defined as
"a conveyance or system of conveyances . . . located in an urbanized area and primarily
operated for the purpose of collecting and conveying storm water runoff." Channelized
storm water runoff from rural areas that did not contain runoff from commercial or industrial
activity was not defined as a point source unless designated otherwise by the permitting
authority. Permit applications were not required for separate storm sewers at that time.
EPA planned to study these discharges and issue general or area permits to address these
sources because these discharges were expected to be less significant than runoff from
industrial facilities. During this time, permitting efforts for storm water discharges focused
on industrial facilities with effluent guideline limitations for their storm water discharges.6
On June 7, 1979, and May 19, 1980, EPA published comprehensive revisions to the
NPDES regulations (44 FR 32854 (June 7, 1979); 45 FR 33290 (May 19, 1980)). These
rules essentially retained the March 18, 1976, broad definition of storm water discharges
subject to NPDES permit requirements but required more stringent application data for storm
water point sources. Under these regulations, the same application information required of
all industrial and commercial process wastewater dischargers would be required of all storm
water point sources. The new requirements included testing under certain circumstances for
a substantially greater number of pollutants identified in the 1977 amendments to the CWA.
This regulation brought suits hi several Courts of Appeals and District Courts by
numerous major trade associations, several of their member companies, NRDC, and Citizens
for a Better Environment. The suits challenged many aspects of the NPDES regulations,
including the storm water provisions. Eventually all petitions for review were consolidated
* The following effluent limitations guidelines address storm water or a combination of storm water and process
water: cement manufacturing (40 CFR Part 411); concentrated animal feeding operations (40 CFR Part 412);
fertilizer manufacturing (40 CFR Part 418); petroleum refining (40 CFR Part 419); phosphate manufacturing (40 CFR
Part 422); steam electric (40 CFR Part 423); coal mining (40 CFR Part 434); mineral mining and processing (40 CFR
Part 436); ore mining and dressing (40 CFR Part 440); and asphalt emulsions (40 CFR Part 443).
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Chapter 1—Introduction
in the U.S. Court of Appeals for the D.C. Circuit (NRDC v. EPA, 673 F.2d 392 (DC Cir.
1980)).
After 2 years of intensive settlement negotiations with representatives of most of the
petitioners, the Agency and industry petitioners signed a settlement agreement on July 7,
1982, which addressed a number of issues relating to the NPDES program, including storm
water. Under the terms of the agreement, EPA agreed to changes to the storm water
regulations which were finalized on September 26, 1984 (49 FR 37998).
The 1984 final rale recognized two fundamental issues regarding the NPDES regulation
of storm water: (1) which storm water discharges should be classified as point sources, and,
therefore, within the NPDES program and (2) what is the best way to regulate these sources.
On the first issue, data available to EPA, such as the Nationwide Urban Runoff Program
(NURP) study, indicated that there are water quality problems associated with storm water
runoff. The final rale retained the broad coverage of the 1980 rale in mandating the
permitting of all storm water point sources that discharge pollutants into waters of the United
States. The September 26, 1984, rale defined a storm water point source as a channelized
conveyance of storm water runoff that (1) is located in an urbanized area, as defined by the
Bureau of the Census, (2) discharges from lands or facilities used for industrial or
commercial activities, or (3) is designated by the Director of the NPDES Program.
To address the second issue of how to regulate these sources administratively, the final
rule set forth two categories of storm water point sources, each with different application
requirements. Group I storm water point sources were defined as sources either subject to
effluent limitations guidelines, located at an industrial plant, or plant-associated area, or
designated by the Director. All other storm water point sources were classified as Group II.
Group I dischargers were required to submit the NPDES application form for industrial and
commercial process wastewater discharges, including certain sampling and testing data. The
application requirements for Group II were significantly reduced. Group II sources were
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Chapter 1—Introduction
required to submit only Form 1 and a narrative description of the drainage area, receiving
water, and any treatment applied to the discharge.
These storm water regulations generated considerable controversy (through post-
promulgation comment) and, once again, suits were filed. The 1984 rules deleted the term
"contaminated" and relied instead on geographic criteria to define sources subject to
permitting. Some commenters claimed that the new definitions would subject thousands of
discharges to the program for the first time. However, in EPA's view, the scope of
coverage of storm water point sources under the NPDES program was essentially unchanged
by the September 26, 1984, rulemaking.
Upon consideration of post-promulgation comments, EPA concluded that it would be
appropriate to obtain additional data on storm water discharges to assess their significance as
an environmental problem and to identify the best means of control. Although the number of
dischargers required to submit quantitative testing data had been reduced by the 1984 rule,
tens of thousands of storm water point sources remained to be identified, tested, and
analyzed. Despite the improvements made in the 1984 regulation, EPA realized it was
appropriate to request comments on whether the collection of data from each individual
Group I discharger was necessary and efficient. In addition, EPA realized that new
deadlines would need to be established. EPA published proposed changes to the storm water
regulations on March 7, 1985, at 50 FR 9362 and on August 12, 1985, at 50 FR 27354.
These proposals were not finalized because of the passage of the Water Quality Act of 1987.
1.2.2 Water Quality Act of 1987
Section 402(p) was added to the CWA in 1987 to require implementation of a
comprehensive two-phased approach for addressing storm water discharges under the NPDES
program. Section 402(p)(l) prohibits EPA or NPDES States from requiring permits for
discharges composed entirely of storm water ("storm water discharges") until October 1,
1992 (this deadline was later extended to October 1, 1994, by the Water Resources
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Chapter 1—Introduction
Development Act of 1992), except for the following five classes of Phase I storm water
discharges specifically listed under Section 402(p)(2):
* Storm water discharges issued a permit before February 4, 1987
• Storm water discharges associated with industrial activity
• Discharges from a municipal separate storm sewer system serving a population of
250,000 or more
• Discharges from a municipal separate storm sewer system serving a population of
100,000 or more but less than 250,000
• Storm water discharges that EPA or an NPDES State determine to be contributing to a
violation of a water quality standard or a significant contributor of pollutants to the
waters of the United States.
Section 402(p)(3)(A) of the CWA requires storm water associated with industrial activity
to meet all applicable provisions of Sections 402 and 301 of the CWA, including technology-
based requirements and any necessary water quality-based requirements. Section
402(p)(3)(B) makes significant changes to the permit standards for discharges from municipal
separate storm sewer systems.7 Permits for discharges from municipal separate storm
sewers:
May be issued on a system- or jurisdiction-wide basis
Shall include a requirement to effectively prohibit non-storm water discharges into the
storm sewers
Shall require controls to reduce pollutant discharges to the maximum extent
practicable, including management practices, control techniques and system, design
and engineering methods, and such other provisions determined appropriate for the
control of such pollutants.
7 The 1987 amendments to the CWA did not specifically address requirements for water quality-based permit
conditions hi NPDES permits for discharges from municipal separate storm sewer systems. EPA interprets the Act
to require that permits for discharges from municipal separate storm sewers include any requirements necessary to
achieve compliance with water quality standards.
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Chapter 1—Introduction
Section 402(p)(4) of the CWA establishes statutory deadlines for the initial steps in
implementing the Phase I program. Deadlines are established for the development of permit
application regulations, submission of permit applications, issuance of permits for Phase I
sources, and compliance with permit conditions.
The 1987 amendments did not identify what sources would be subject to the NPDES
program after the temporary moratorium on permit requirements of Section 402(p)(l)
expired. Rather, the amendments established a process for EPA to evaluate potential Phase
II sources and designate sources for regulation to protect water quality. Section 402(p)(5) of
the CWA requires EPA, hi consultation with the States, to conduct a study of storm water
discharges other than Phase I sources (i.e., potential Phase II sources). The study is to
identify storm water discharges not covered under Phase I and determine, to the maximum
extent practicable, the nature and extent of pollutants in such discharges. The study is also
to establish procedures and methods to control storm water discharges to the extent necessary
to mitigate impacts on water quality.
Section 402(p)(6) of the CWA requires EPA, in consultation with State and local
officials, to issue regulations designating additional Phase II storm water discharges to be
regulated to protect water quality and to establish a comprehensive program to regulate such
designated sources. The comprehensive program to regulate such designated sources must,
at a minimum, establish priorities, requirements for State storm water management
programs, and expeditious deadlines. The program may include performance standards,
guidelines, guidance, management practices, and treatment requirements, as appropriate.
1.2.3 Phase I Regulatory Framework
i
EPA promulgated regulations for Phase I storm water discharges on November 16, 1990
(55 FR 47990). These regulations clarified the scope of the Phase I storm water program by
providing regulatory definitions for the major classes of storm water discharges identified
under Section 402(p)(2)(B), (C), and (D) of the CWA:
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Chapter 1—Introduction
Storm water discharges associated with industrial activity
Discharges from municipal separate storm sewer systems serving a population of
100,000 or more.8
In addition, the November 16, 1990, regulations established permit application
requirements, including submittal deadlines, for these classes of discharges.
The November 16, 1990, regulations define municipal separate storm sewer systems
serving a population of 100,000 or more to include municipal separate storm sewers within
the boundaries of 173 incorporated cities and within unincorporated portions of 47 counties
with populations of 100,000 or more in their unincorporated areas.9 The regulations allowed
for additional municipal separate storm sewers to be designated by the NPDES permitting
authority (EPA or an authorized NPDES State) as being part of a municipal separate storm
sewer system subject to Phase I requkements. In addition, the regulations established
comprehensive two-part permit applications for discharges from municipal separate storm
sewer systems serving a population of 100,000 or more. Among other things, the permit
applications require municipal applicants to propose municipal storm water management
programs to control pollutants to the maximum extent practicable and to effectively prohibit
non-storm water discharges to the municipal system.10 Municipal storm water management
programs are a combination of source controls and management practices that address
targeted sources within the boundaries of the municipal system. Under this program, EPA
has defined the role of municipalities hi a flexible manner that allows local governments to
assist in defining priority pollutant sources within the municipality and to develop and
* Consistent with Section 402(p)(2) of the CWA, the November 16, 1990, regulations address two subclasses of
municipal separate storm sewer systems serving a population of 100,000 or more. Large municipal separate storm
sewer systems are defined as systems serving a population of 250,000 or more (40 CFR 122.26(b)(4)). Medium
municipal separate storm sewer systems are defined as systems serving a population of 100,000 or more, but less
than 250,000 (40 CFR 122.26(b)(7)).
9 See Appendices F, G, H, and I to 40 CFR 122.
10 See 40 CFR 122.26(d)(2)(iv).
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Chapter 1—Introduction
implement appropriate controls for such discharges. Municipal programs can establish
requirements for the control of discharges to the municipal system from privately owned
lands (e.g., sediment and erosion control for construction sites) and can address municipal
activities that affect storm water quality (e.g., maintenance of leaking sanitary sewers, road
de-icing and maintenance, operation of municipal landfills, and some flood control efforts).
Moreover, the November 16, 1990, regulations defined the term "storm water discharges
associated with industrial activity" to include 11 categories of industrial facilities (see 40 CFR
122.26(b)(14)) and established application requirements for such discharges.11 In light of
concerns raised by the industrial community about the complexity of the November 1990
storm water regulations, the difficulty in determining whether particular facilities were
subject to the new rules, and administrative delays hi permit issuance, EPA issued a series of
extensions to permit application deadlines for discharges associated with industrial activity.12
With these extensions, October 1, 1992, was established as the date by which any facility
with a storm water discharge associated with industrial activity must submit either an
individual or group application or obtain coverage under an applicable general permit.
Congress also has acted to grant extensions to the application deadlines for selected
classes of discharges associated with industrial activity. In March 1991, Congress adopted
Section 307 of the Dire Emergency Supplemental Appropriations Act of 1991, which ratified
EPA's extension of Part I of the group applications to September 30, 1991. On December
18, 1991, the Intermodal Surface Transportation Efficiency Act of 1991 (or Transportation
Act), extended NPDES permit application deadlines for storm water discharges associated
with industrial activity from facilities that are owned or operated by municipalities. In
addition, Section 1068(c) of the Transportation Act amended the Clean Water Act to provide
11 As discussed below, on June 4, 1992, the U.S. Court of Appeals for the Ninth Circuit found EPA's rationale
for exempting construction sites of less than 5 acres and certain uncontaminated storm water discharges from light
industrial facilities from Phase I of the storm water program to be invalid and has remanded these exemptions for
further proceedings (see NRDC v. EPA, 966 F.2d 1292 (9th Cir. 1992)).
12 See 56 PR 12098 (March 21, 1991), 56 FR 56548 (November 5, 1991), 57 FR 11524 (April 2, 1992).
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Chapter 1—Introduction
that EPA shall not require any municipality with a population of less than 100,000 to apply
for or obtain a permit for any storm water discharge associated with industrial activity other
than an airport, power plant, or uncontrolled sanitary landfill owned or operated by such
municipalities before October 1, 1992. In response to this provision, EPA has reserved
application deadlines for these facilities.13
EPA also has modified the NPDES regulations to provide a greater degree of emphasis
on site inspections as an alternative or supplement to discharge monitoring in permits for
storm water discharges associated with industrial activity.14
On June 4, 1992, the United States Court of Appeals for the Ninth Circuit issued an
opinion granting hi part a petition for review of EPA's 1990 storm water regulations (NRDC
v. EPA, 966 F.2d 1292 (9th Cir. 1992)). The court upheld several provisions of the
regulations, including the definition of municipal separate storm sewer system, the standards
for municipal storm water controls, the scope of the permit exemption for oil and gas
operations, and EPA's decision not to provide public comment on Part 1 of the group
applications for storm water discharges associated with industrial activity.
The Court did declare EPA's extension of the statutory deadlines for storm water permit
applications to be unlawful, but declined to strike down the deadlines as the plaintiff had
requested. In addition, the Court struck down and remanded two exemptions from the
definition of storm water discharges associated with industrial activity.
One of the remanded exemptions addressed construction activities that result hi the
disturbance of less than 5 acres of total land area which are not part of a larger common plan
of development or sale. EPA noted that State and local sediment and erosion controls may
13 See 57 FR 11524 (April 2, 1992), 40 CFR 122.26(e)(l)(ii).
14 See 57 FR 11524 (April 2, 1992), 40 CFR 122.44(1).
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Chapter 1—Introduction
address construction activities of less than 5 acres and that the acreage limit reflected land
disturbances that were industrial in magnitude because disturbances on large tracts of land
will employ more heavy machinery and industrial equipment. The Court noted that EPA had
proposed to exempt only sites for commercial and industrial construction smaller than 1 acre
and sites for residential construction smaller than 5 acres. In the final rule, the exemption
was increased to 5 acres for all construction sites, based on the Agency's determination that
smaller sites would not have levels of activity similar to other industrial activities. The court
ruled, however, that the record did not indicate "that construction sites on less than five acres
are non-industrial hi nature" (966 F.2d at 1306). The court rejected EPA's argument that the
5-acre cutoff constituted a de minimis exemption, because the record lacked information to
suggest whether smaller discharges would be de minimis.
A second remanded exemption addressed light manufacturing facilities where material
handling equipment or activities, raw material, intermediate products, final products, waste
materials, byproducts, or industrial machinery are not exposed to storm water. With respect
to the light industry category, EPA had adopted the exemption based on the belief that if (1)
the activities hi the selected facilities are undertaken hi buildings; (2) emissions from stacks
are minimal or nonexistent; (3) there is no unhoused manufacturing and heavy industrial
equipment, outside storage, disposal, or handling of raw, finished, or waste materials; (4)
and the activities being performed do not generate significant dust or particulates, the facility
posed a much smaller risk of storm water contamination. Based on these factors, the Agency
believed that these facilities were similar to commercial businesses, such as retail and service
facilities.
The court noted, however, that the statutory term associated with industrial activity was
very broad and concluded that Congress intended only to exempt discharges from non-
industrial facility areas such as parking lots. The court rejected EPA's argument that
industrial pollutant levels hi storm water would be minimal at light industrial facilities,
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Chapter 1—Introduction
finding nothing in the record to support that conclusion. Therefore, the court found this
exemption to be arbitrary and capricious (966 F.2d at 1304-05).
In response to the Ninth Circuit decision, EPA promulgated rules on December 18,
1992, specifying dates for permit approval or denial and permit compliance. In the
December 18, 1992, notice, EPA also noted that it did not believe that the court's opinion
had the effect of automatically subjecting small construction sites and light industries to the
existing application requirements and deadlines for storm water discharges associated with
industrial activity. The Agency also indicated that it believed that additional notice and
comment ndemaldng was necessary to clarify the status of these facilities under the storm
water program.
1.2.4 Phase I Implementation Activities
The initial efforts to implement the Phase I storm water program have focused on
reviewing group applications for industrial storm water, issuing general permits for industrial
storm water, publishing draft general permits for storm water discharges from 29 industrial
sectors, reviewing applications for municipal separate storm sewer systems, issuing permits
for municipal separate storm sewer systems, and conducting outreach activities. In addition,
the Agency, in conjunction with the Rensselaerville Institute, completed a study to develop
recommendations for making Phase I of the program more effective.
1.2.4.1 General Permits
In September 1992 (April 1993 for Puerto Rico) EPA issued general permits for storm
water discharges associated with industrial activity in the 11 States without NPDES authority,
as well as for Territories, States where EPA issues permits for Federal facilities, and Federal
Indian Reservations. Unlike traditional NPDES permits, these permits generally do not
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Chapter 1—Introduction
establish numeric effluent limitations for most discharges authorized by the permits.15
Rather, the permits establish requirements for notices of intent, site inspections conducted by
dischargers, and site-specific pollution prevention plans. The requirements for pollution
prevention plans provide a framework for dischargers to identify sources of pollution and
best management practices to prevent, reduce and/or control such pollutant sources. In
addition, targeted facilities are required to sample and analyze their storm water discharges.
When the storm water application rules were issued in November 1990, only 17 out of
the 39 authorized States authorized to administer the NPDES program were also approved to
issue NPDES general permits. Since then, an additional 21 States have requested and
received EPA approval to issue general permits, and one additional State has received
NPDES authorization, including general permit authority. All but one of the States that now
have general permit authority have issued general permits for storm water discharges.
1.2.4.2 Group Applications
EPA has received more than 1,200 Part I group applications representing more than
60,000 industrial facilities with storm water discharges. EPA has requested public comment
on draft permits to address discharges identified hi these applications that are hi States
without authorized NPDES programs.16 The draft general permits contain requirements for
29 different industrial sectors.
1.2.4.3 Municipal Applications
Permit applications have been received for almost all municipal separate storm sewer
systems serving a population of 100,000 or more. This represents a substantial initial
The permits do establish numeric effluent limitations for some classes of storm water discharges. These
limitations are either based on best available technology or established pursuant to State certifications under Section 401
oftheCWA.
16 See 58 FR 61146 (November 19, 1993).
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Chapter 1—Introduction
investment into Phase I of the storm water program by municipalities.17 At the heart of
these applications are proposed municipal storm water management programs, which will
identify a variety of site-specific pollution prevention measures, source controls, and best
management practices to control pollutants from targeted sources within the municipality.18
EPA and authorized NPDES States have started to issue permits for these municipal separate
storm sewer systems. The Agency estimates that 263 permits will be issued for Phase I
municipal separate storm sewer systems; as of May 1994, 24 permits have been issued.
1.2.4.4 Rensselaervffle Phase I Effort
In 1992 EPA completed a study, in conjunction with the Rensselaerville Institute, to
obtain direct public input and develop recommendations for improving Phase I of the storm
water program. These studies are discussed in more detail in Appendix I. The study raised
five key issues relating to Phase I sources:
Study participants thought that EPA has not been clear enough about the intended
goals of the regulations and should communicate storm water risks, objectives, and
requirements more clearly to the general public, as well as to the regulated
community.
Participants noted that the cost of program implementation is significantly higher than
original EPA estimates and that there is great concern regarding the real costs of the
program and of achieving compliance.
Participants agreed that EPA and States must accelerate general permit issuance and
focus on general permits to achieve efficient implementation of the program.
17 The National Association of Flood and Stormwater Management Agencies estimates based on a 1992 survey
that municipalities have spent more than $130 million on preparing NPDES permit applications for discharges from
Phase I municipal separate storm sewer systems.
18 A review of cost estimates for proposed municipal storm water management programs provided in 20
applications indicates that municipalities estimate the cost of program implementation (excluding permit application
costs) to range from $23.91 to $37.00 per person. (See draft Review of Program Costs in Part 2 NPDES Municipal
Storm Water Permit Applications, EPA, 1993.)
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Chapter 1—Introduction
• Participants felt that technical outreach should be targeted at the State and local level
rather than the national level and should provide better guidance on the regulations
and their implementation.
• Participants noted that coverage under certain industrial storm water categories should
be clarified.
EPA agreed with these recommendations and has taken steps to follow up hi each area.
1.2.5 September 9, 1992 Notice—Phase H Issues
On September 9, 1992, EPA published a notice requesting information and public
comment on the Phase II program. The notice is included hi Appendix H of this report.
The notice identified three sets of issues associated with developing Phase II regulations:
• How should sources that are to be subject to Phase II regulations be identified?
• What types of control strategies should be developed for these sources?
• What are appropriate deadlines for implementing Phase II requirements?
The September 9, 1992, notice presented a range of alternatives under each issue hi an
attempt to illustrate, and obtain input on, the full range of potential approaches for a Phase II
strategy. The notice recognized that potential sources for coverage under Phase II fall into
two main categories: municipalities; and individual sources (commercial and residential)
activities. EPA recognized that a major distinction between most options for identifying
Phase II commercial/residential sources was either to require targeted municipalities to
develop source controls and management programs for storm water discharges within then-
jurisdictions or to require permits for discharges from individual facilities.
EPA received more than 130 comments on the September 9, 1992, notice.
Approximately 43 percent of the comments were from municipalities, 29 percent from trade
groups or industries, 24 percent from State or Federal agencies, and approximately 3 percent
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Chapter 1—Introduction
from other miscellaneous sources.19 No comments were received from environmental
groups. Appendix J contains a detailed summary of comments received as they relate to the
specific issues raised in the notice.
1.2.6 Rensselaerville Phase H Effort
In early 1993, the Rensselaerville Institute and EPA held public and expert meetings to
assist in developing and analyzing options for identifying Phase II sources and controls.
These meetings and the resulting options are discussed hi more detail hi Appendix I of this
report. The report on the effort indicates that the two options most favored by the various
groups participating were:
A program where States would select sources to be controlled hi a manner that was
consistent with criteria developed by EPA. The Phase II program would provide
States with flexibility to either rely on NPDES requirements or other frameworks to
control targeted sources.
A tiered approach that would provide for EPA selection of high priority sources for
control by NPDES permits and State selection of other sources for control under a
State program other than the NPDES program.
1.2.7 President Clinton's Clean Water Initiative
On February 1, 1994, President Clinton's Clean Water Initiative was issued. The
President's Initiative addresses a number of issues associated with NPDES requirements for
storm water discharges, including:
• Compliance of discharges from municipal separate storm sewer systems with water
quality standards
• Industrial facilities with no activities or significant materials exposed to storm water
• Deadline extensions for Phase II of the storm water program
19 Percentages have been rounded off, and hence may not total 100 percent.
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Chapter 1—Introduction
• Phase II storm water program requirements, including regulation of storm water from
industrial facilities by municipalities
• Control of discharges from inactive and abandoned mines (lAMs) located on Federal
lands.
To address municipal compliance with water quality standards, the President's Initiative
recommends that the CWA be amended to establish a phased permit compliance approach
that requires best management practices in first-round municipal storm water permits and
unproved best management practices in second-round permits, where necessary, to move
towards compliance with water quality standards. In later permits, compliance with water
quality standards will occur using water quality-based effluent limits, where necessary. This
would give EPA and municipalities additional time to evaluate the technical feasibility of
establishing numeric effluent limits to meet water quality standards and give States time to
develop specific water quality standards appropriate for storm water discharges, if necessary.
The President's Initiative further supports clarifying authority under section 402(p)(3)(B)
concerning "maximum extent practicable" (MEP).
The President's Initiative recommends that EPA be authorized to exempt from individual
storm water permitting requirements facilities that can certify that there is no—nor will there
be—exposure of industrial or other activities or significant materials to rain water and snow
melt. This change would ensure that several hundred thousand low-risk facilities are not
subject to NPDES requirements, allowing allocation of resources to more critical areas. This
would also effectively create incentives for facilities to eliminate contamination of storm
water.
The President's Initiative recommends that the statutory deadline for EPA to issue Phase
II regulations be extended. The President's Initiative also recommends that the deadline for
Phase II sources to obtain a permit be extended. The President's Initiative indicated that
extensions would allow EPA to work with States and municipalities hi developing workable,
effective regulations. A new deadline for permits would give municipalities an opportunity
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Chapter 1—Introduction
to begin to build institutional frameworks and provide the funding necessary to implement
storm water management programs. It would also allow permits to be issued to Phase II
municipalities at the same time Phase I permits are expiring. This would promote regional
and watershed-wide permitting by allowing different municipalities to be co-applicants and to
coordinate their storm water programs.
With respect to NPDES requirements for Phase II storm water discharges, the
President's Initiative recommends20 that NPDES Phase II requirements for storm water
focus on system-wide permits for municipal separate storm sewer systems in
Census-designated urbanized areas.21 The President's Initiative recommends tiered
permitting requirements. Storm water management programs would be developed for
municipal separate storm sewer systems located within an urbanized area hi which a
municipal separate storm sewer system is already addressed under Phase I. The programs
would, at a minimum, address non-storm water discharges into storm sewers and storm water
runoff from growth and development and significant redevelopment. NPDES permitting
authorities should be encouraged to implement watershed approaches which implement a
more comprehensive municipal storm water management program where appropriate based
on water quality impairments or other factors for municipal separate storm sewer systems hi
these urbanized areas. In the remaining Census-designated urbanized areas, municipal storm
water management programs would be required which focus only on controlling non-storm
water discharges into storm sewers and storm water runoff from growth, development, and
significant redevelopment activities. The President's Initiative recommends that Phase II of
the NPDES program not directly regulate Phase II light industrial, commercial, retail, and
20 While the President's Initiative generally speaks to recommended statutory changes, EPA notes that under the
existing CWA, with the exception of extending the deadline for permits for discharges from municipal separate storm
sewer systems to comply with water quality-based requirements, EPA could issue Phase II regulations covering the
same facilities to the same extent as suggested in the President's Initiative.
21 The Bureau of the Census defines urbanized areas as a central city (or cities) with a surrounding area that is
densely settled (i.e., urban fringe). The population of the entire urbanized area must be greater than 50,000 persons,
and the urban fringe must have a population density generally greater than 1,000 persons per square mile
(approximately 1.5 persons per acre). A complete description of the Bureau of the Census definition is provided in
Chapter 3.
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Chapter 1—Introduction
institutional storm water discharges, and municipalities outside of Census-designated
urbanized areas unless designated by the permitting authority for inclusion in the NPDES
program under Section 402(p)(2)(E) of the CWA. Rather, such discharges, if a targeted
source, should be addressed by Nonpoint Source programs.
The President's Initiative recommends authorizing municipalities to directly control Phase
I industrial storm water facilities within their jurisdictions under the NPDES program. This
recommendation is similar to the industrial pretreatment program currently authorized under
the CWA. The President's Initiative recommends clarifying authority to issue permits on a
statewide basis for lAMs, allowing Federal land managers to establish priorities and make
the most effective use of available resources. Land managers would be allowed up to 10
years to meet appropriate water quality standards, while continuing to identify additional
impacts from lAMs and implementing targeted controls once identified. A cost-benefit
analysis was prepared for the President's Initiative and is summarized hi Appendix L. No
further cost-benefit analyses were conducted for this report.
1.2.8 NPDES Watershed Strategy
EPA issued the NPDES Watershed Strategy hi March 1994. The Strategy discusses
integration of NPDES program functions into a broader watershed protection approach and
areas for coordination with stakeholders to promote implementation of the approach. The
NPDES Watershed Strategy is based on the following principles:
Watershed protection approaches may vary in terms of specific elements, timing, and
resources, but all should share a common emphasis and insistence on integrated
actions, specific action items, and measurable environmental and programmatic
milestones.
Related activities within a basin or watershed must be coordinated to achieve the
greatest environmental benefit and most effective level of stakeholder involvement.
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Chapter 1—Introduction
• Actions relating to restoration and protection of surface water, ground water, and
habitat within a basin should be based upon an integrated decision-making process, a
common information base, and a common understanding of the roles, priorities, and
responsibilities of all stakeholders within a basin.
• Staff and financial resources are limited and must be allocated to address
environmental priorities as effectively and efficiently as possible.
• Program requirements that interfere or conflict with environmental priorities should be
identified and revised to the extent possible.
• Accurate information and high quality data are necessary for decision-making and
should be collected on an incremental basis; interim decisions should be made based
on available data to prevent further degradation and promote restoration of natural
resources.
1.3 RELATED NONPOINT SOURCE PROGRAMS
1.3.1 Section 319 of the CWA
In 1987, Section 319 was added to the CWA to provide a framework for funding State
and local efforts to address pollutant sources not addressed by the NPDES program (e.g.,
nonpoint sources). To obtain funding, States were required to submit Nonpoint Source
Assessment Reports identifying State waters that, without additional control of nonpoint
sources of pollution, could not reasonably be expected to attain or maintain applicable water
quality standards or the goals and requirements of the CWA. States were also required to
prepare and submit for EPA approval a statewide Nonpoint Source Management Program for
controlling nonpoint source water pollution to navigable waters within the State and
improving the quality of such waters. State program submittals were to identify specific best
management practices (BMPs) and measures that the State proposes to implement in the first
4 years after program submission to reduce pollutant loadings from identified nonpoint
sources to levels required to achieve the stated water quality objectives.
State programs funded under Section 319 can include both regulatory and nonregulatory
State and local approaches. Section 319(b)(2)(B) specifies that a combination of "non-
regulatory or regulatory programs for enforcement, technical assistance, financial assistance,
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Chapter 1—Introduction
education, training, technology transfer, and demonstration projects" may be used, as
necessary, to achieve implementation of the BMPs or measures identified in the Section 319
submittals.
Although most States have generally emphasized the use of voluntary approaches hi their
319 programs, some States and local governments have implemented regulations and policies
to control pollution from urban runoff. States such as Delaware and Florida, as well as local
jurisdictions such as the Lower Colorado River Authority, are pursuing storm water
management goals through numerical treatment standards for new development. Many States
and local governments have enforceable erosion and sediment control regulations. On a
broader scale, nonpoint source pollution is being addressed at the watershed level by
programs such as those being implemented by the State of Wisconsin, the Puget Sound Water
Quality Authority, the States that are parties to the Great Lakes Water Quality Agreement,
and other States. A number of individual States and local communities have adopted
legislation or regulations similar to Maryland's Critical Areas Act, which limits development
and/or requires special management practices in areas surrounding water resources of special
concern.
1.3.2 Section 6217 of CZARA
Section 6217 of the Coastal Zone Act Reauthorization Amendments (CZARA) of 1990
provides that States with approved coastal zone management programs must develop and
submit coastal nonpoint pollution control programs to EPA and the National Oceanic and
Atmospheric Administration (NOAA) for approval. Failure to submit an approvable program
will result in a reduction of Federal grants under both the Coastal Zone Management Act and
Section 319 of the CWA.
State coastal nonpoint pollution control programs under CZARA must include
enforceable policies and mechanisms that ensure implementation of the management measures
throughout the coastal management area. Section 6217(g)(5) defines management measures
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Chapter 1—Introduction
as "economically achievable measures for the control of the addition of pollutants from
existing and new categories and classes of nonpoint sources of pollution, which reflect the
greatest degree of pollutant reduction achievable through the application of the best available
nonpoint pollution control practices, technologies, processes, siting criteria, operating
methods, or other alternatives." Congress mandated a technology-based approach based on
technical and economic achievability under the rationale that neither States nor EPA have the
money, time, or other resources to create and expeditiously implement a program that
depends on establishing cause and effect linkages among particular land use activities and
specific water quality problems. If this technology-based approach fails to achieve and
maintain applicable water quality standards and to protect designated uses, CZARA Section
6217(b)(3) requires additional management measures.
EPA issued Guidance Specifying Management Measures for Sources of Nonpoint
Pollution in Coastal Waters under Section 6217(g) hi January 1993. The Guidance identifies
management measures for five major categories of nonpoint source pollution: Agriculture,
Forestry, Urban, Marinas and Recreational Boating, and Hydromodification. The
management measures reflect the greatest degree of pollutant reduction that is economically
achievable for each of the listed sources. These management measures provide reference
standards for the States to use hi developing or refining their coastal nonpoint programs. In
general, the management measures were written to describe systems designed to reduce the
generation of pollutants. A few management measures, however, contain quantitative
standards that specify pollutant loading reductions.22 The management measures approach
was adopted to provide State officials flexibility hi selecting strategies and management
systems and practices that are appropriate for regional or local conditions, provided that
equivalent or higher levels of pollutant control are achieved. Appendix K of this report
summarizes the management measures for urban areas, animal feedlots, and marinas that
were identified hi the guidance.
22 For example, the New Development Management Measure, which is applicable to construction in urban areas,
requires: (1) that by design or performance that the average annual total suspended solid loadings be reduced by
80 percent; and (2) to the extent practicable, that the predevelopmentpeak runoff rate and average volume be maintained.
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Chapter 1—Introduction
Storm water discharges regulated under Phase I of the NPDES program, such as
discharges from municipal separate storm sewers serving a population of 100,000 or more
and construction activities that disturb 5 or more acres, do not need to be addressed in
Coastal Nonpoint Pollution Control Programs. However, potential Phase II sources, such as
urban development adjacent to or surrounding Phase I municipal systems, smaller urbanized
areas, and construction sites that disturb less than 5 acres, that are identified hi management
measures under Section 6217 guidance need to be addressed in Coastal Nonpoint Pollution
Control Programs until such discharges are issued an NPDES permit. EPA and NOAA haVe
worked, and continue to work, together hi their activities to ensure that there is not an
overlap of authorities between NPDES and CZARA.
EPA and NOAA published Coastal Nonpoint Pollution Control Program: Program
Development and Approval Guidance, which addresses such issues as the basis and process
for EPA/NOAA approval of State Coastal Nonpoint Pollution Control Programs; how EPA
and NOAA expect State programs to implement management measures hi cpnformity with
EPA guidance; and procedures for reviewing and modifying State coastal boundaries to meet
program requirements. The guidance clarifies that States generally must implement
management measures for each source category identified hi the guidance developed under
Section 6217(g). This guidance sets quantitative performance standards for some measures.
Coastal Nonpoint Pollution Control Programs are not required to address sources that are
clearly regulated under the NPDES program as point source discharges. The guidance also
clarifies that regulatory and nonregulatory mechanisms may be used to meet the requirement
for enforceable policies and mechanisms, provided that nonregulatory approaches are backed
by enforceable State authority ensuring that the management measures will be implemented.
Backup authority can include sunset provisions for incentive programs. For example, a State
may provide additional incentives if too few operators participate hi a tax incentive program
or develop mandatory requirements to achieve the necessary implementation of management
measures.
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Chapter 1—Introduction
1.3.3 President Clinton's Clean Water Initiative—Nonpoint Source Programs
President Clinton's Clean Water Initiative proposes a fundamental restructuring and
strengthening of the nonpoint source pollution (NFS) control programs under Section 319 of
the CWA. The President's Initiative proposes legislative changes that will result in upgraded
and strengthened existing State NFS management programs within seven and one-half years
of reauthorization of the CWA. These programs will implement best available management
measures for nonpoint sources causing, contributing to, or threatening water quality
impairments and for new nonpoint sources, except for new sources hi States with an
approved watershed management program. The President's Initiative recommends that the
initial implementation period be followed by a second, five-year period to implement further
measures where necessary (considering the actual and expected environmental benefits of the
original management measures) to achieve water quality standards.
The President's Initiative recommends that strengthened Section 319 State programs rely
on a mix of voluntary and regulatory approaches and that State programs include
enforcement authorities to be used as needed to ensure implementation of management
measures. Under the proposal, State authorities will be backed by Federal enforcement
authorities to be exercised if a State should fail to implement the management measures.
Where States do not develop an approvable program, Section 319 grants will be withheld
from the State and EPA will be authorized to establish enforceable minimum NFS controls.
The President's Initiative proposes that funding be increased for State implementation of NFS
programs and that State revolving loan fund eligibility be clarified for NFS projects whose
principal purpose is protecting and improving water quality. The President's Initiative also
proposes that the CWA be clarified to require that Federal agencies comply with State or
local requirements hi nonpoint source programs to the same extent as non-Federal parties.
1.3.4 President Clinton's Clean Water Initiative—Watershed Management
President Clinton's Clean Water Initiative proposes that provisions for comprehensive
watershed management be added to the CWA. Under the proposal, States can choose to
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Chapter 1—Introduction
implement comprehensive watershed programs which will be approved by EPA after
conference with other Federal agencies. The States will determine the boundaries for all
watersheds in the State and set a schedule for addressing them. States will oversee watershed
management entities with appropriate representation of stakeholder interests and approve their
watershed management plans. State watershed plans will include rankings based on
environmental objectives as well as evidence of enforceable policies and mechanisms needed
to implement the plans.
The President's Initiative proposes other changes to the CWA that: (1) provide
guidelines for States wishing to adopt market-based approaches to point and NFS pollution
controls within watersheds; (2) promote the development of wetland management plans that
lead to increased flexibility and predictability of the wetlands permit process on a watershed
basis; and (3) create comprehensive State inventories of waters that are threatened, impaired,
or hi need of special protection. The President's Initiative also recommends that States give
urban watersheds a high level of priority in their State-wide ranking of watershed initiatives.
1.4 DEVELOPMENT OF TfflS REPORT
A Draft of this report was circulated extensively hi November 1993. Copies were
distributed to States, EPA Regions, the Association of State and Interstate Water Pollution
Control Administrators (ASIWPCA), and other interested parties. Comments received on
that draft have been reviewed and appropriate changes to the Report have been made.
1.5 ORGANIZATION OF TfflS REPORT
Chapter 2 of this report presents the approach and methodology for identifying categories
of storm water sources and methods for estimating the distribution and content of these
discharges. The next two chapters identify storm water discharges not regulated by the
current program and discusses the nature of such discharges and the extent of pollutant
loadings from these sources, as well as their geographic distribution for municipalities
(Chapter 3) and industrial and commercial facilities (Chapter 4).
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Chapter 2—Approach
CHAPTER 2. APPROACH
This chapter describes the approach taken by the U.S. Environmental Protection Agency
(EPA) to identify and characterize storm water discharges that are not subject to the first
phase of the National Pollutant Discharge Elimination System storm water permit
requirements under Section 402(p) of the Clean Water Act (CWA).
The study considered two major classes of storm water discharges: (1) discharges from
municipal separate storm sewer systems (addressed hi Section 2.2) and (2) industrial and
commercial discharges (Section 2.3). EPA relied on existing information and data,
particularly the 1990 U.S. census, and on a number of previous studies, as described hi the
literature review (Section 2.4). As a part of this study, EPA developed estimates of annual
loadings for discharges from municipal separate storm sewer systems. Section 2.1 gives a
brief overview of the approach.
2.1 OVERVIEW OF APPROACH
A main purpose of this report is to identify storm water discharges not addressed by
Phase I of the NPDES program for storm water discharges and to determine the nature and
extent of pollutants hi these discharges. The analytical approach to this objective followed
two separate paths—one for Phase II discharges from municipal separate storm sewer systems
and another for individual Phase II sources. This section briefly summarizes both aspects of
the approach. Sections 2.2 and 2.3 provide more detailed explanation.
In the analysis of municipal separate storm sewer systems, municipal systems addressed
by Phase I of the NPDES program had to be identified to allow identification of the
remaining potential Phase II municipal systems. EPA limited the analysis of potential Phase
II municipal separate storm sewer systems to those municipalities that had populations that
were classified as urban by the Bureau of the Census. Census information was used to
identify the type of municipality, geographic location, and urban population. Selected
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Chapter 2—Approach
geographic areas of potential concern, such as urbanized areas, coastal areas, and fast
growing areas, were identified and evaluated following the procedures described below.
Pollutant loading estimates were developed for populations located hi urbanized areas that
were designated by the Bureau of the Census, including both Phase I and Phase II
discharges. Pollutant loadings were estimated by using a simplified loadings model described
in Section 2.2.2. Pollutant concentration data for seven pollutants, including conventional
pollutants, nutrients, and metals, were taken from the results of the National Urban Runoff
Program (NURP) (EPA, 1983). Runoff volume was estimated as the product of land area,
the annual amount of precipitation, and the "runoff coefficient" (a fraction that indicates the
proportion of precipitation that runs off the land and enters receiving waters). Land area for
urbanized areas was provided by the 1990 U.S. census. Precipitation estimates were based
on the rainfall zones established hi the NPDES Permit Application Requirements for Storm
Water Discharges (November 16, 1990). The runoff coefficient is a function of the
imperviousness of the land surface, which is related to the density of roads, buildings, and
other paved surfaces hi an urban area. The amount of impervious area in urban settings can
be estimated from population densities. The runoff coefficient used hi this analysis was
estimated by using a relationship based on population density (calculated from census data)
that was published hi the technical literature and hi EPA documents (Heaney et al., 1977).
In the analysis of individual Phase II sources, identification of potential sources also
proceeded hi two steps. Fkst, a review of the regulatory definition identified which types of
facilities were clearly regulated under Phase I. This review aided the development of a list
of facilities similar or identical to Phase I industrial facilities that were not covered under
Phase I for a variety of statutory and regulatory reasons. Second, a literature review (see
Section 2.4) identified, hi general terms, additional commercial and retail sources of potential
concern, based on the types of pollutants used or activities conducted. These potential Phase
n sources were specified hi detail using the Standard Industrial Classification (SIC) code
system of the Office of Management and Budget. The use of SIC codes for identification of
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Chapter 2—Approach
potential Phase II sources also facilitated the quantitative analysis performed hi Chapter 4.
Thus, the identification step covered the full range of industrial and commercial business
activities that may be contributing to storm water pollution. A complete listing of industries
classified within the SIC code system is provided later hi this section.
The nature and extent of pollutants from individual Phase II sources were determined hi
two parts. The nature of pollutants was addressed qualitatively hi two steps. First, pollutant
sampling data from Phase I industrial sources was evaluated, summarized, and compared to
previous studies of urban storm water content. This formed a basic reference on the nature
of discharges from a wide variety of specific industrial categories. Second, potential Phase H
sources were classified into groups and compared with Phase I sectors, where possible, to
enable comparison to the pollutant concentration data from Phase I facilities and to determine
the types and quantities of pollutants likely to be associated with unregulated discharges.
This qualitative assessment of potential pollutant associations was supplemented with
information documented hi State and local nonpoint source programs, urban runoff programs,
estuary programs, and technical articles identified through the literature review.
The extent of potential Phase II individual discharges was addressed by determining the
geographic location and distribution of facilities that may contribute pollutants to storm
water, rather than calculating pollutant loads as hi the municipal analysis. The analysis
focused on location rather than loadings because data on industrial and commercial pollutant
discharges was insufficient to allow estimation of loadings on a national basis. Moreover, an
attempt to estimate loads for industrial and commercial sources would lead to double
counting, because many potential Phase II facilities are located hi municipal or urban areas
and the loading analysis for municipal sources already accounts for some of their
contributions.
Using EPA's Facility and Company Tracking System (FACTS) computer file based on
Dun & Bradstreet information about economic activity, the number of facilities hi each SIC
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Chapter 2—Approach
code was found for each county in the country.1 From the 1990 census for each county, the
proportion of population associated with geographic jurisdictions of interest was calculated.
For each county and each SIC code, the number of facilities was multiplied by the proportion
of population hi each geographic area to yield an estimate of the number of facilities hi that
portion of the county. Summing over all counties provides an estimate of the proportion of
facilities hi each SIC code nationally that are located hi the geographic jurisdictions of
interest.
The two paths, municipal separate storm sewer systems and individual sources, were
related through the geographical analysis of extent of discharges, which shows the proportion
of pollutant loadings from municipal separate storm sewers and the proportion of individual
facilities associated with various areas of concern. Although the effect cannot be quantified,
the nature and extent of pollutants from industrial and commercial sources overlaps with the
nature and extent of pollutant loadings calculated hi the municipal analysis.
2.2 ANALYSIS OF MUNICIPAL SEPARATE STORM SEWER SYSTEMS
This section describes the procedure used to identify potential Phase II municipal
separate storm sewer systems. The section also explains how the pollutant load estimates
were developed for discharges from municipal separate storm sewer systems hi urbanized
areas.
2.2.1 Identifying Municipal Separate Storm Sewer Systems
Municipal separate storm sewer systems addressed by Phase I of the NPDES program
had to be identified to allow identification of the remaining potential Phase II municipal
systems. EPA limited the analysis of potential Phase II municipal separate storm sewer
1 The FACTS data base is leased by EPA from Dun & Bradstreet Information Services, which created, maintains,
and annually updates the information based on State and industry reports and on primary data collection in the business
community including detailed surveys and personal interviews. It has been estimated that this data base accounts tor
more than 96 percent of the U.S. Gross National Product (Caskins, 1992). FACTS was made available for this study
through EPA's National Computer Center in North Carolina.
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Chapter 2—Approach
systems to populations that were classified as urban by the Bureau of the Census. The only
other population classification available from the Bureau of the Census was rural populations.
Rural populations and rural areas were generally excluded from this part of the analysis
because the Agency was generally unable to tie these areas to development patterns and
demographics that were thought to result hi the installation of municipal separate storm sewer
systems. Census information was used to identify the type of municipality, geographic
location, and urban population.
2.2.1.1 Phase I Definitions
Section 402(p) of the CWA identifies discharges from municipal separate storm sewer
systems serving a population of more than 100,000 people as requiring permit coverage
under the first phase of the NPDES program. Phase I municipal systems are defined hi the
NPDES regulations at 40 CFR 122.26(b)(4) and (7) and explained hi the preamble to include:
• Incorporated cities with populations greater than 100,000 served by separate storm
sewers, according to the latest Decennial Census by the Bureau of the Census
• Counties with a population of 100,000 or more hi unincorporated, urbanized areas.
according to the latest Decennial Census by the Bureau of the Census (excluding the
population of towns and townships')
• Municipalities that are designated by EPA or an authorized NPDES State.2
Phase I municipal systems also include systems that are designated by EPA or an
authorized NPDES State under section 402(p) of the CWA as needing an NPDES permit
because they are significant contributors of pollutants to waters of the United States or
contribute to a violation of water quality standards.
2 Designation of a Phase I municipal system is based on one of the following factors: physical interconnections
with a municipal separate storm sewer system serving a population of 100,000 or more identified in the NPDES
regulations, discharges from several municipal separate storm sewer systems, the quantity and nature of pollutants in
the discharge, and the nature of the receiving waters.
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Chapter 2—Approach
For the purposes of determining Phase I populations, the NPDES regulations allow
municipalities to reduce the population of the municipality to account for populations served
by combined sewers.3
Census definitions data from the 1990 census was used to identify urban populations of
potential Phase n municipal separate storm sewer systems. The Bureau of the Census
organizes population information according to political and demographic factors. Political
jurisdictions include entities with governmental structures, such as States, counties,
incorporated places (e.g., cities, towns, villages), and minor civil divisions (MCDs), which
include towns and townships in 20 States. Table 2-1 summarizes the definitions of these
political entities.
Table 2-1. Bureau of the Census Definitions of Municipal Entities
Incorporated Places—Places incorporated under the laws of their States as cities, boroughs, towns, and
villages, with the following exceptions: boroughs hi Alaska and New York, and towns hi the six New
England States, New York, and Wisconsin.
Minor Civil Divisions—Minor civil divisions are primary divisions of counties established under State law
hi 20 States. Townships are minor civil divisions hi 12 States (Illinois, Indiana, Kansas, Michigan,
Minnesota, Missouri, Nebraska, New Jersey, North Dakota, Ohio, Pennsylvania, and South Dakota).
Towns are recognized as minor civil divisions hi eight States (Connecticut, Maine, Massachusetts, New
Hampshire, New York, Rhode Island, Vermont, and Wisconsin).
Counties—In most States, the primary divisions are termed counties. In Louisiana, these divisions are
known as parishes. In Alaska, which has no counties, the county equivalents are the organized boroughs.
In four States (Maryland, Missouri, Nevada, and Virginia), there are one or more cities that are
independent of any county organization and thus constitute primary divisions of their States.
Source: Census of Population and Housing, 1990.
3 See 40 CFR 122.26(f)(3). Combined sewers are conveyances that are designed to collect and convey both
storm water and sanitary sewage. Combined sewers are not regulated under the storm water permitting program
because they are regulated as part of the total discharge from the combined system under the existing NPDES permit
conditions for that system. Combined sewers are addressed hi this report only as an adjustment factor used to
estimate storm water flows from urban areas.
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Chapter 2—Approach
Two additional geographical classifications were evaluated in the report, urbanized areas
designated by the Bureau of the Census and metropolitan areas (MAs) defined by the Office
of Management and Budget (OMB). The definitions of these terms are summarized in
Table 2-2. Census-designated urbanized areas are based primarily on demographics and
represent densely settled areas of 50,000 or more people. OMB identifies metropolitan areas
based on economics and social trends, in addition to population densities. Metropolitan areas
are defined based on county boundaries and are significantly more inclusive than urbanized
areas, which more closely follow population distributions.
Table 2-2. Population Classifications of Bureau of the Census
URBANIZED AREAS—An urbanized area (UA) comprises an incorporated place and adjacent densely
settled surrounding area that together have a minimum population of 50,000. The densely settled
surrounding areas consists of:
1. Contiguous incorporated places or census designated places having:
a. A population of 2,500 or more; or
b. A population of fewer than 2,500 but having either a population density of 1,000 persons per
square mile, a closely settled area containing a minimum of 50 percent of the population, or a
cluster of at least 100 housing units.
2. Contiguous unincorporated area which is connected by road and has a population density of at least
1,000 persons per square mile.
3. Other contiguous unincorporated area with a density of less than 1,000 per square mile, provided
that it:
a. Eliminates an enclave of less than 5 square miles which is surrounded by built-up area.
b. Closes an indentation in the boundary of the densely settled area that is no more than 1 mile
across the open end and encompasses no more than 5 square miles.
c. Links an outlying area of qualifying density, provided that the outlying area is:
(1) Connected by road to, and is not more than 1.5 miles from, the mam body of the UA.
(2) Separated from the main body of the UA by water or other undevelopable area, is
connected by road to the main body of the UA, and is not more than 5 miles from the
main body of the UA.
4. Large concentrations of nonresidential urban area (such as industrial parks, office area, and major
airports) which have at least one-quarter of their boundary contiguous to a UA.
URBAN POPULATIONS—All persons living in urbanized areas and in places of 2,500 or more inhabitants
outside of urbanized areas. The urban population consists of all persons living in (1) places of 2,500 or
more inhabitants incorporated as cities, villages, boroughs (except in Alaska and New York), and towns
(except in the New England States, New York, and Wisconsin), but excluding those persons living in the
rural portions of extended cities; (2) census designated places of 2,500 or more inhabitants; and (3) other
territory, incorporated or unincorporated, included in urbanized areas.
RURAL POPULATIONS—Population not classified as urban.
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Chapter 2—Approach
The following information was obtained from the 1990 census data (Summary Tape
Ftte-lA) for all parts of the United States4:
• State and County location
• Population
• Land Area
• Population Density
• Growth Projections.
Information on urbanized areas, urban populations, and metropolitan areas was obtained from
documents published by the Census Bureau.
2.2.1.2 Identification of Phase I and Phase II Municipalities
The following steps were taken to identify municipalities with Phase I municipal separate
storm sewer systems:
• Cities Specifically Identified in Phase I Regulations: Based on the 1980 census, 173
cities were originally identified as having populations exceeding 100,000. Of these, a
survey of authorized NPDES States and EPA Regions indicated that 30 cities with
populations of 100,000 or more have been exempted from Phase I storm water
requirements due to populations served by combined sewers. An additional 5 cities'
populations dropped below 100,000 based on the 1990 census. Permit applications
have not been required from these cities unless they have been designated for inclusion
in Phase I by EPA or a State. For the purposes of this report, 140 of the 173 cities
identified in the Phase I regulations are considered to be Phase I.
• Counties Specifically Identified in Phase I Regulations: Based on the 1980 census,
47 counties were originally identified as having populations in urbanized,
unincorporated.areas that exceeded 100,000 after the population in the incorporated
places, townships, or towns was excluded. Incorporated places with a population of
less than 100,000 that were located hi these counties were treated as potential Phase II
municipalities unless they were identified as being designated into Phase I by an
authorized NPDES State or EPA Region. The population of 2 of these counties had
4 Information obtained for Guam, the Virgin Islands, American Samoa, and the Commonwealth of the Northern
Mariana Islands was limited to population and growth projections. For the Commonwealth of Puerto Rico and the
District of Columbia, all information described above was obtained and used in the analysis.
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Chapter 2—Approach
dropped below 100,000 based on the 1990 census, leaving 45 Phase I counties
specifically identified in Phase I regulations for the purposes of this report.
• Municipalities Designated by NPDES Authorities: Authorized NPDES States and
EPA Regions have the authority to designate additional municipalities as subject to
Phase I. A survey of authorized NPDES States and EPA Regions was used to identify
designated municipalities. This report identifies designations that occurred before
January 1994 and considers them to be Phase I sources for the purposes of this
analysis.
All remaining municipalities with urban populations not identified as a part of Phase I of
the NPDES storm water program were considered to be potential Phase II sources. Chapter
3 provides the specific numbers of municipal entities in various categories. Municipalities
were differentiated based on characteristics such as size, density, or association with other
levels and types of geographical and political jurisdictions. The designation of municipalities
as Phase I vs. Phase II in this report is based on a "snapshot" of currently regulated
municipalities as of January 1994.
2.2.2 Determining the Nature and Extent of Pollutants Associated With
Municipal Separate Storm Sewer Systems
A review of the literature on urban runoff, including past studies conducted by EPA and
the USGS, was used to develop a general descriptive profile of the nature of discharges from
municipal separate storm sewer systems. Section 2.4 discusses this review.
Estimates of loads were developed for selected pollutants hi runoff from urbanized areas.
The approach used to estimate loadings of pollutants associated with discharges from
municipal separate storm sewer systems was based on existing data and follows standard
engineering practice (McCuen, 1989; American Society of Civil Engineers, 1969).
These estimates were developed to provide an overview of the extent of pollutant
discharges associated with urban runoff and a relative ranking of the pollution potential from
urbanized areas. The results can be used to compare potential Phase II municipal systems hi
2-9
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Chapter 2—Approach
urbanized areas with Phase I municipal systems. This approach was not designed to estimate
actual loads for any specific locality.5 Thus, it would not be appropriate to use load
estimates generated as part of this study in assessing potential storm water impacts within a
specific receiving water body.
To estimate pollutant loadings from municipal separate storm sewer systems, the
following equation was used for each pollutant of concern and for each urbanized area:
Load = Pollutant Concentration x Land Area x Rainfall x Runoff Coefficient x
Conversion Factor,
where:
Load = Storm water pollutant load in thousands of pounds per year6
Concentration = Mean pollutant concentrations determined from NURP (mg/1)
Area = Land area for the urban site or place from the U.S. census (square miles)
Rainfall = Average annual rainfall, based on rainfall zone (niches per year)
Runoff Coefficient = A fraction that represents the proportion of rainfall that runs off
the land to surface waters. It is related to the amount of land covered by impervious
surfaces, such as roads and buildings
Conversion Factor = Adjusts units into pounds per year.
2.2.2.1 Pollutant Concentrations
A review of the literature showed that data from NURP (EPA, 1983) are the most
frequently cited and often used reference values for urban runoff pollutant concentrations.
NURP data were used as the basis for loadings calculations for this study after evaluating the
procedures used in NURP and comparing the results with other independent studies of urban
runoff undertaken by USGS.
3 In particular, rainfall and concentration data were not site-specific.
6 The units of the final loading estimate were converted to thousands of pounds per year so that the results could
be simplified.
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Chapter 2—Approach
NURP, which was conducted during the early 1980s, remains the most comprehensive
assessment of pollutants in runoff from residential and commercial areas. The program was
developed in the late 1970s, after EPA reviewed State 208 Water Quality Management Plan
Reports and determined that additional and consistent data were needed to describe pollutants
in urban runoff.
Under NURP, EPA provided direction and assistance to 28 planning projects located
throughout the United States (Figure 2-1) that were selected from 93 area-wide agencies that
had identified urban runoff as a potentially significant problem. (Table 2-3 lists the 28
NURP project locations according to EPA Regions.) Each project was separate and distract
but shared the common goal of conducting field monitoring to characterize pollutants in
runoff from residential and commercial areas. The sampling locations within the 28 NURP
projects included 81 specific sites and more than 2,300 separate storm events. The resulting
data base represented a cross section of regional climatology, residential and commercial land
use types, slopes, and soil conditions and, thereby, provided a basis for identifying patterns
of similarities or differences and testing their significance.
Table 2-3. NURP Project Locations
EPA
Region
I
n
ra
IV
NURP
Code
MAI
MA2
NH1
NY1
NY2
NY3
DC1
MD1
FL1
NCI
SCI
TNI
Project Name/Location
Lake Quinsigamind (Boston Area)
Upper Mystic (Boston Area)
Durham, New Hampshire
Long Island (Nassau and Suffolk
Counties)
Lake George
Irondequoit Bay (Rochester Area)
WASHCOG (D.C. Metropolitan Area)
Baltimore, Maryland
Tampa, Florida
Winston-Salem, North Carolina
Myrtle Beach, South Carolina
Knoxville, Tennessee
EPA
Region
V
VI
vn
Vffl
DC
X
NURP
Code
IL1
IL2
Mil
ME
MIS
WI1
AR1
TX1
KS1
CO1
SD1
UT1
CA1
CA2
OR1
WAI
Project Name/Location
Champaign-Urbana, Illinois
Lake Ellyn (Chicago Area)
Lansing, Michigan
SEMCOG (Detroit Area)
Ann Arbor, Michigan
Milwaukee, Wisconsin
Little Rock, Arkansas
Austin, Texas
Kansas City
Denver, Colorado
Rapid City, South Dakota
Salt Lake City, Utah
Coyote Creek (San Francisco Area)
Fresno, California
Springfield-Eugene, Oregon
Bellevue (Seattle Area))
Source: U.S. Environmental Protection Agency, 1983
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Chapter 2—Approach
Figure 2-1. Location of NURP Sites
NURP focused on the following ten constituents, which were considered standard
pollutants characterizing urban runoff:
• Total Suspended Solids (TSS)
• Biochemical Oxygen Demand (BOD)
• Chemical Oxygen Demand (COD)
• Total phosphorus (TP)
• Soluble phosphorus (SP)
• Total Kjeldahl Nitrogen (TKN)
• Nitrate + nitrite (N)
• Total copper (Cu)
• Total lead (Pb)
• Total zinc (Zn).
2-12
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Chapter 2—Approach
These pollutants are commonly associated with urban runoff and are often targets of
point and nonpoint source studies. In addition, some of these pollutants can be surrogates
for larger categories of pollutants such as oxygen consuming constituents and nutrients.
NURP also examined coliform bacteria and priority pollutants (other than oil and grease).
However, these parameters were only evaluated for a subset of sites and were not the
primary focus of the NURP study. Moreover, they were not presented in a summary fashion
suitable for estimating loadings. Soluble phosphorus is not discussed in this report because it
was not addressed in USGS results or NPDES permit applications for industrial facilities
(addressed later in this chapter).
NURP attempted to characterize the nature of storm water from residential and
commercial areas. The data summaries excluded monitoring sites that were downstream of
storm water controls. Sites were selected to focus on runoff from residential areas (primarily
low density) and to avoid heavy industrial areas. NURP commercial site results did not
include heavy industrial sites but hi several cases reflected industrial park type use. Sites
were also selected so that there were no extraneous sources of pollutants in the storm water
discharge, such as illicit connections to the storm sewers^ In addition, unusually high
pollutant concentrations were eliminated from the data base as being atypical of storm water
discharges.
Because of its site selection approach, NURP results represent normal or baseline urban
runoff conditions from residential and commercial areas, not actual urban conditions which
could include heavy industrial activities which were avoided by NURP. Because the NURP
sites represent average runoff conditions from a mix of residential, commercial, and
industrial park sites, loading estimates based on the NURP concentrations (described earlier
in this Chapter and in Chapter 3) will be influenced by loadings from some of the sources
considered hi the industrial and commercial analysis (see Section 2.3 and Chapter 4) that
were located hi the catchments monitored.
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Chapter 2—Approach
NURP showed that the concentrations of pollutants hi urban runoff vary considerably
from site to site. Concentrations at individual sites also varied through the course of a storm
event and between events. This variability is the natural result of variations hi rainfall
intensity, occurrence, and site-specific factors (e.g., slope, land use) that affect runoff
quantity and quality. NURP data were summarized using average values for storm events,
with an event mean concentration (EMC, i.e., the total pollutant mass discharged divided by
the total runoff volume). To determine typical storm water concentrations, NURP
researchers examined the data hi various ways using standard statistical procedures, each
exploring the effects of different factors (e.g., slope, land use category) on final
concentration values. Based on these statistical tests, NURP concluded that geographic
location, land use categories, or other factors appear to be of little utility hi explaining the
overall site-to-site variability, and the best general characterization of urban runoff is
obtained by pooling the site data for all sites (except the open/non-urban ones). NURP
recommended the total pollutant mass discharged divided by the total runoff volume (i.e., the
event mean concentration [EMC]) as the best single measure for characterizing overall storm
water pollutant concentrations. The data summarized from NURP are recommended for
planning purposes rather than site-specific characterization. Table 2-4 presents summary
statistics from NURP for different sites and results from other USGS studies, discussed
below.
Comparison to USGS Urban Storm Water Data Base
In addition to EPA's efforts to characterize urban runoff, USGS has collected urban
rainfall, runoff, and water quality data nationally for several decades. In the mid-1980s,
much of this information was compiled into a national data base. This data base contains
information on 717 storms at 99 stations hi 22 metropolitan areas throughout the United
States (Driver et al., 1985). The USGS examined a set of constituents similar to those used
hi NURP. The USGS also reported its data hi terms of flow-weighted samples so that
concentration and loading values could be compared directly to NURP results.
2-14
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Chapter 2—Approach
Table 2-4. NURP and USGS Summary Statistics-
Water Quality Characteristics of Urban Runoff
Pollutant units/notes
BODS
COD
N02+NOL,-N
TKN
Total P
TSS
Copper
Lead
Zinc
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
/«g/l
Jtg/1
pen
NURP (1983)
Median Urban Site (d)
EMC Mean
a
12
82
0.86
1.90
0.42
180
43
182
202
EMC Median
b
9
65
0.68
1.50
0.33
100
34
144
160
90th%-ile
b
15
140
1.75
3.30
0.70
300
93
350
500
Commercial
EMC Median
b
9
57
0.57
1.18
0.20
69
29
104
226
USGS (various years)
Residential
Mean
c
12
NR
0.57
NR
0.46
1163
43
222
145
Median
c
7
NR
0.46
NR
0.36
228
20
120
100'
Commercial Sites
Mean
c
16
NR
0.38
NR
0.31
248
28
215
311
Median
c
8
NR
0.25
NR
0.18
109
16
73
110
Industrial Sites
Mean
c
NR
NR
1.71
NR
6.61
671
89
97
706
Median
c
NR
NR
1.20
NR
6.40
492
74
78
550
a - EMC mean reported on page 6-60 of NURP report in the context of loading estimate comparisons. EMC should be used when comparing cumulative effects
such as WQ impacts in lakes or when comparing loads on a long-term basis.
b - EMC median reported on 6-43 of NURP as the best description of urban runoff characteristics in terms of water assessing short-term water quality impacts in
rivers and streams.
c - Simple mean and median calculated from raw data from USGS. Because the data were not normally distributed, the median is the base measure of central
tendency.
d - NURP's "median urban site" is a composite of land use types.
NR - Not Reported.
To provide a comparison to the NURP data for this study, the USGS data were analyzed
statistically to develop mean and median pollutant concentration values for 7 of the 10 NURP
pollutants. (The USGS data did not include COD, TKN, or soluble P. As previously noted,
soluble phosphorus is not discussed in this report because it is not addressed in USGS or
NPDES permit applications for industrial facilities.) To provide some perspective on NURP,
different land use categories (i.e., residential, commercial, and industrial park sites) were
analyzed separately. Table 2-4 summarizes the results from the USGS data base next to the
NURP results. Although NURP results (for the median) are higher for BOD, nitrate +
nitrite, copper, lead, and zinc, most of the results differ by less than 50 percent, except for
TSS results, which are highly variable. Both sets of results are hi the same range,
2-15
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Chapter 2—Approach
supporting the idea that these values are representative of the nature of urban runoff. This
determination is consistent with the findings of Driver and Lystrom (1986), who also
compared certain aspects of the two data sets.
As described hi this chapter and hi Chapter 3, this report uses historical data, generated
by the Nationwide Urban Runoff Program (NURP) and by the U.S. Geological Survey
(USGS), to generally and comparatively characterize metal contamination hi storm water
runoff from urban areas.
Recently, concerns have been raised regarding the validity and use of historical data for
metals where adequate QA/QC cannot be properly documented (USGS, 1992). The quality
of trace level metal data, especially at levels hi the 1-5 part per billion (ppb) range, may be
compromised due to contamination of samples during collection, preparation, storage, and
analysis. These concerns have also been expressed as applying to the NURP metals data.
EPA believes that the metals data for urban runoff from USGS and NURP as used hi this
report are valid. Mean concentrations of copper, lead, and zinc observed under NURP and
USGS were found to be hi the range of 30 to 700 ppb (see Table 2-4), well above the
1-5 ppb range that has been identified as questionable. Furthermore, hi dealing with the
metals issue generally, EPA believes that most historical data for metals collected and
analyzed with appropriate QA and QC at levels of 1 ppb or higher are reliable (EPA, 1993).
It should also be pointed out that the historical sampling data presented in this report is
intended to provide a general, qualitative characterization of urban storm water runoff rather
than a precise empirical relationship. The metals loadings estimated using NURP data are
only used to illustrate relative loadings contributions from different geographical areas of the
country. Quantitative loadings estimates, which could possibly be affected by suspect data,
have not been presented hi this report.
2-16
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Chapter 2—Approach
2.2.2.2 Land Area
Population and land area data (or population density) for all urbanized areas were
obtained from the 1990 census. Phase I sources and potential Phase II sources were
identified based on the procedure described hi Section 2.2.1. An adjustment factor was
developed to address combined sewer systems. Combined sewer systems are not considered
to be part of the storm water regulatory program (although combined sewer overflows from
combined sewer systems are addressed by the NPDES program). Therefore, storm water
volume estimates hi this report were adjusted to account for the flows entering combined
sewers. Estimates of the land area served by combined sewer systems were based on data
reported by the States for The 1984 Needs Survey Report to Congress (EPA, 1985).
2.2.2.3 Rainfall
Annual rainfall estimates were obtained from Methodology for Analysis of Detention
Basins for Control of Urban Runoff Quality (Driscoll et al., 1986). This document identifies
9 rainfall zones in the United States (see Figure 2-2). Although these rainfall zones have
been updated in Analysis of Storm Event Characteristics for Selected Rainfall Gauges
Throughout the United States (Driscoll et al., 1989), (see Appendix B of this report) to
include 15 more precisely defined rainfall zones, the 9 rainfall zones from the earlier report
were used to simplify estimation procedures.
For each of the 3,141 counties hi the country, the appropriate rainfall zone was
identified, along with the average annual rainfall for that zone. This information was merged
with the larger census data base at the county level to provide rainfall estimates for each
municipality.
2-17
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Chapter 2—Approach
Not Shown: Alaska (Zone 7); Hawaii (Zone 7); Northern Mariana Islands (Zone 7); Guam
(Zone 7); American Samoa (Zone 7); Puerto Rico (Zone 3); Virgin Islands (Zone 3).
Zone 1
Zone 2
ZoneS
33.1
39.6
50.9
Zone 4
Zone 5
Zone 6
41.2
19.2
7.5
Zone 7
Zone 8
Zone 9
23.0
11.0
14.3
Source: 55 FR 47990, 1990
EPA, 1990
figure 2-2. National Distribution of Rainfall Zones and Average
Annual Precipitation (inches/year)
2-18
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Chapter 2—Approach
2.2.2.4 Runoff Coefficient
The runoff coefficient represents the portion (percentage) of total precipitation reaching
the ground that becomes runoff to surface waters. A number of factors, such as the nature
of the soils, topography, and amount or type of vegetative cover, can affect the runoff
coefficient. However, the most important factor in determining the quantity of runoff from a
given storm in a given area is the amount of impervious area (MWCOG, 1987). Impervious
areas include all types of paved areas (e.g., streets, sidewalks, parking lots, driveways),
buildings, roof tops, and other similar structures. The extent of impervious area is a
function of many local considerations, such as the density and type of development.
Generally, the runoff coefficient is directly related to watershed imperviousness, as illustrated
hi Figure 2-3, which contains data from 44 small urban catchments monitored during the
national NURP study.
1.00'
0. 90-
-.0-80-
£0.60-
o
0. 40-
.
0.30-
o. ?.o-
0. 10-
0.00'
Source: MWCOG, 1987
10
20
80
90
100
30 40 SO 60 70
WATERSHED IMPERVIOUSNESS (7.)
NOTE: 44 small urban catchments monitored during th« national
NURP study.
Figure 2-3. Relationship of Watershed Imperviousness to Runoff Coefficient
The runoff coefficient used hi the analysis of this report was estimated as a function of
population density, based on equations that are widely used in the engineering literature, in
previous studies by EPA's Office of Research and Development, and hi the Corps of
Engineers' Storage, Treatment, Overflow and Runoff Model (STORM) (which was designed
2-19
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Chapter 2—Approach
for planning purposes and simulation of storm events [Heaney et al., 1977]). The two
equations are:
Impervious Proportion = 0.096 x population density'0-573-0391 ********
Runoff Coefficient = 0.15 (1 -impervious proportion) + 0.90 (impervious proportion).
Combining the two equations yields:
Runoff Coefficient = 0.15 + 0.75 x [0.096 x population density<°-573--0391xl°»ation
where population density is in persons per acre.
The first equation estimates the site-specific level of imperviousness from population
density. This empirical equation is based on data from another study of hundreds of
municipalities in New Jersey (Stankowski, 1974). The second equation estimates a runoff
coefficient from an empirical equation that depends on the level of imperviousness. Using
this model, an area with no impervious surfaces would be assigned a runoff coefficient of
0.15, while a completely impervious area would have a runoff coefficient of 0.90. These
equations produce results that are similar to those presented in Figure 2-3.
The model can be used to estimate runoff coefficients when only population density is
known. Figure 2-4 shows how the model predicts the relationship between population
density, expressed hi persons per acre and the runoff coefficient. For example, for an urban
area with 10 people per acre (or 6,400 people per square mile), the model estimates a runoff
coefficient of 0.4, meaning that, on average, 40 percent of the rainfall runs off to surface
water. The model estimates that places with higher population densities will have higher
runoff coefficients. Although limitations are associated with this relationship (e.g., the
original equation is based on land use conditions in the 1960s and the estimates are limited
by the uncertainty of the assumed variables), the model can make use of population density
data from the 1990 census hi estimating runoff coefficients for different municipalities for
comparative purposes.
2-20
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Chapter 2—Approach
u.
u.
S
o
u.
u.
0.52
0.5
Q.4B
0.46
0.44
0.42.
0.4
0.38
0.36
0.34
0.32
0..3
'0.28
O.26
0.24
O.22
0.2
\3\5 I 7 I 9 I 11 I 13 I 15 I 17 | 19 I
2 4 6 8 10 12 14 16 18 20
POPULATION DENSITY CPEOPLE/ACRE}
Figure 2-4. Runoff Coefficient Calculated as a Function of Population Density
2.3 ANALYSIS OF INDIVIDUAL PHASE H DISCHARGES
The second major focus of this study was to (1) identify types of industrial, commercial,
and institutional storm water discharges for which permits are not already required as part of
Phase I and (2) determine, to the maximum extent practical, the nature and extent of
pollutants in such discharges. This section explains the approach used to select classes of
facilities for study and the data analyses undertaken to develop the information presented in
Chapter 4.
To develop information on remaining unregulated sources, sources regulated under
Phase I were clearly defined and eliminated from consideration along with sources that have
been statutorily exempted from both Phase I and Phase II. Then, from the remaining set of
2-21
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Chapter 2—Approach
sources and facilities, classes of facilities with the potential to contribute pollutants to storm
water discharges were identified. The analysis of the nature and extent of individual Phase II
discharges addresses both pollutant concentrations and the geographic distribution of
facilities. The geographical analysis was developed to determine the distribution and location
of individual Phase n facilities in relation to Urbanized Areas and the Phase II municipalities
identified in the first part of this study. Although there was not enough data available on a
national basis to estimate pollutant loadings from individual Phase II sources, the approach
taken could later be related to an assessment of water quality conditions at the local,
regional, or State level.
2.3.1 Identifying Individual Phase n Storm Water Discharges
The storm water discharge regulations (Phase I) require permit applications from
facilities with "storm water discharges associated with industrial activity," as defined hi 40
CFR 122.26(b)(14) (55 FR 47990). This definition describes the 11 specific categories of
industrial activities which are regulated. For the categories of industries identified, the term
includes storm water discharges from:
. . . industrial plant yards; immediate access roads and rail lines used or created by
the facility; material handling sites; refuse sites; sites used for the application or
disposal of process waste waters . . .; sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage or disposal;
shipping and receiving areas; manufacturing buildings; storage areas (including tank
farms) for raw materials, and intermediate and finished products; and areas where
industrial activity has taken place hi the past and significant materials remain and are
exposed to storm water [40 CFR 122.26(b)(14)].
The definitions of the 11 categories include both narrative descriptions of activities and
specific designations of industrial operations based on Standard Industrial Classification (SIC)
code.7 For example, category (i) mentions facilities subject to effluent limitations guidelines
7 The SIC code is the statistical classification standard underlying all Federal economic statistics classified by
industry (OMB, 1987).
2-22
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Chapter 2—Approach
developed by EPA, while category (xi) designates many specific SIC codes. Because of the
comprehensiveness of the SIC system, even narrative descriptions can be correlated with SIC
designations. For example, category (vii) covers steam electric power generating facilities,
which are included primarily in SIC 4911, and category (ix) covers domestic treatment
works, which are included primarily in SIC 4952. The practical effect of these narrative
definitions and specific SIC code designations is that most of the industrial facilities subject
to permit application requirements are represented by major SIC groupings 10 through 45.8
As a basis for identifying Phase EL facilities and obtaining information about their
distribution and abundance, this study focused on SIC codes. Major sectors of the economy
are defined on the basis of the two-digit SIC code group. The two-digit code is a relatively
general categorization of the Nation's economic activity; all industrial, commercial, and retail
activities are organized into less man 100 two-digit SIC codes, which are listed in Table 2-5.
The more specific four-digit SIC code provides a more detailed breakdown of these
enterprises and is much more descriptive of the activities conducted at the establishment.
The SIC code identifies facilities based on the "primary activity" in which a facility is
engaged. Chapter 4 discusses selected advantages and disadvantages of using the SIC code
system for identification of storm water sources. Focusing on SIC codes for the purposes of
this study does not imply that EPA must regulate on a SIC code basis. Also, although some
potential Phase II categories or concerns may be defined or discussed hi terms of narrative
descriptions, these can be evaluated in terms of SIC code designations.
Although all unregulated facilities which have point source discharges of storm water are
potential Phase n sources, in practical terms, only a subset of four-digit SIC codes have real
8 The NPDES regulations specifically exempt some categories of activity from the definition of point source,
including storm water runoff from agricultural sources and silviculture activities (mostly in SIC codes 01 through 09)
(40 CFR Part 122.3(e)), irrigation return flows (40 CFR Part 122.3(f)), and uncontaminated runoff from mining sites
and oil and gas facilities (40 CFR 122.26(a)(2)). In addition, construction activities are regulated based on the site
where activity is occurring, not based on the SIC code for contractors and builders that may participate in the
construction (SIC 15-17).
2-23
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Chapter 2—Approach
Table 2-5. List of All Two-Digit SIC Code Groups and Industry Description
SIC
CODE
01
02
07
08
09
10
12
13
14
15
16
17
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
DESCRIPTION
Ag. Product.-Crops
Ag. Product.-Livestock
Ag. Services
Forestry
Fishing, Hunting
Metal Mining
Coal & Lignite Mining
Oil & Gas Extraction
Nonmetallic Minerals
Building Contractors
Heavy Const. Contractors
Spec. Trade Contractors
Man. Food, etc.
Man. Tobacco
Man. Textile
Man. Apparel
Lumber & Wood
Furniture & Fixtures
Paper & Allied Prod.
Printing & Publish.
Chemicals & Allied
Petroleum & Coal
Rubber & Plastic Products
Leather/Products
Stone, Clay & Glass
Primary Metal Ind.
Fab. Metal Products
Machinery-electric
Electronic Equip.
Transportation Equip.
Instrument & Related
Misc. Manufacturing
Railroad Transport
Local Pass. Transit
Trucking
U.S. Postal Service
Water Transport
Air Transport
Pipe Lines-Nat. Gas
Transport Services
Communication
Electric, Gas & Sanitation
SIC
CODE
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
67
70
72
73
75
76
78
79
80
81
82
83
84
86
87
88
89
91
92
93
94
95
96
97
99
DESCRIPTION
Wholesale-Durables
Wholesale-Nondurables
Bldg. & Gard. Mats.
General Stores
Food Stores
Auto Dealers & Service
Apparel Stores
Furniture Stores
Eat & Drink Places
Misc. Retail
Banking
Credit Agencies
Security Brokers
Insurance Carriers
Insurance Agents
Real Estate
Investment Offices
Hotels & Lodging
Personal Services
Business Services
Auto Repair Services
Misc. Repair
Motion Pictures
Amusement Services
Health Services
Legal Services
Educational Services
Social Services
Museums
Membership Orgs.
Research & Development
Households w/Employees
Services, NEC
Executive, Gen'l Govt.
Justice, Public Order
Public Finance, Taxes
Human Resource Admin
Env. Qual. & Housing Admin.
Economic Program Admin.
National Security
Non-Classifiable
2-24
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Chapter 2—Approach
potential to use, process, or store sources of pollutants, or engage in activities that could lead
to contamination of storm water. In addition, there are many general sources of storm water
contamination such as parking lots, trash dumpsters, and failing septic systems which could
be associated with almost any commercial or residential activity. Some general information
on these sources is presented hi Chapter 4; however, the focus of this report is in identifying
specific classes of facilities with greater than average potential for contribution of pollutants
to storm water discharges based on their activities.
EPA identified two major groups of facilities for potential inclusion hi Phase II. The
first group of potential Phase II facilities identified (Group A) consists of facilities in the
same SIC code groups as Phase I facilities (SICs 10-45) that are conducting activities that are
essentially the same as Phase I industrial activities but that were not included hi Phase I due
to the specific language of the statute or EPA's regulatory specificity hi defining the universe
of Phase I industrial activities. The second major group (Group B) consists of facilities hi all
other SIC code groups where discharges of pollutants are suspected based on case studies,
expert opinions, literature reviews, and other sources of information such as experience with
Phase I of the storm water program.9
2.3.1.1 Group A Facilities
Group A is comprised of facilities which are generally identical to regulated Phase I
industrial activities but that have been excluded from Phase I due to the specific language of
the statute or EPA's regulatory specificity. While some of the facilities that make up Group
A are obvious, (i.e., those with a specific statutory exemption from Phase I), others are more
difficult to identify. Because these facilities may be described by SIC codes identical to
Phase I regulated facilities, the FACTS data base was of little use hi identifying these
9 Although some sources similar to Phase I industrial activities were not identified in the 1990 application regulations
(55 FR 47990) directly, EPA or an authorized NPDES State has the authority under Section 402(p)(2)(E) to designate
individual facilities as needing an NPDES permit. Although some designations of this type have been made, this report
bases the distinction of individual Phase I and Phase II facilities based on the regulatory definition and not on any
individual designations which may have been made.
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Chapter 2—Approach
facilities. Instead, each of the 11 industrial categories that make up Phase I (see Chapter 4,
Table 4-2) was examined for possible omissions and discrepancies. The result of this effort
was a list of sources that are not covered under Phase I but that are closely related to one of
the eleven categories of industrial activity. This list appears in Table 4-3. In order to help
define these facilities, sources on the list were categorized into three major groups. Group A
sources are described in Chapter 4.
2.3.1.2 Group B Faculties
The second general class of facilities were identified on the basis of potential activities
and pollutants that may contribute to storm water contamination (Group B). Unlike Group A
facilities which are generally represented by the same range of SIC code groups as Phase I
facilities (SICs 10-45), Group B facilities have distinctly different SIC codes but may be
performing similar activities or using similar materials as Phase I facilities. Based on the
review and analysis of the types of industrial sources not covered under Phase I, several
categories of Group B facilities were identified that have activities inherently similar to Phase
I but are not currently regulated. Some SIC code groups were also identified using other
criteria, described below.
Commercial facilities were specifically excluded from Phase I by Congress. However,
many commercial sources represent an important environmental concern. These concerns are
documented in State and local nonpoint source programs, urban runoff programs, and estuary
programs identified through the literature review (see Section 2.4). The Rensselaerville
Study (1992) reflected this view by identifying "gas, auto, service stations, transportation
related activities, highway systems, land development, agricultural sources and related
activities, commercial activities with industrial components, and large retail complexes" as
sources of concern.10
10 No SIC codes specifically identify all large retail complexes. However, these complexes are partially
addressed through the loading analysis of storm water from urban/urbanized areas in the municipal section
(Chapter 3).
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Chapter 2—Approach
Another class of facilities included in Group B is commercial agricultural-related
activities. Categories that are specifically exempted from regulation under Section 402 of the
CWA (or, hi certain cases, under existing NPDES regulations) were eliminated from
consideration in Group B as potential Phase II sources. (These include agriculture and most
silviculture activities generally included in SIC code groups 01, 02, 07, 08, and 09.u)
However, several specific SIC codes were retained on the list as potential Phase II sources
because they are not specifically included under the agricultural exemption. These include
nurseries, feedlots (the larger of which are already regulated under the NPDES permitting
program),12 some forestry operations, and miscellaneous others.13
A final review of other miscellaneous sources that have been identified as potential
contributors to storm water pollution was conducted to reveal any sources not addressed by
the criteria discussed above. The facilities identified use or handle materials containing
pollutants of concern to publicly owned treatment works (POTWs). To the extent that these
materials are used, stored, processed, or disposed of outdoors at Group B facilities, they may
also represent a source of storm water contamination.
The procedure used to identify specific SIC codes with significant potential to discharge
pollutants to storm water resulted in the identification of 90 categories of facilities.
Table 4-4 lists the subset of 90 four-digit SIC codes identified from this analysis. The
analysis was comprehensive and inclusive, while at the same time carefully determining
whether a category had the potential to contribute pollution to storm water.
11 The NPDES regulations at 40 CFR 122.27 cover discharges from certain types of silviculture activities but do
not cover other discharges that are nonpoint hi nature.
12 Feedlots that are not contained within the regulatory definition of concentrated animal feeding operation (CAFO)
are not point sources unless designated on a case-by-case basis under 40 CFR 122.23(c).
13 Under 402(p)(6), EPA may establish regulations that could include sources that are not currently defined as point
sources or examined as potential Phase n sources in this report, including some operations related to silviculture.
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Chapter 2—Approach
The geographic distribution analysis was completed for all major two-digit SIC code
groups and for the 90 specific four-digit SIC codes identified in Table 4-4. Information
about the distribution of all facilities is presented hi the report, even for categories that are
not among the 90 potential Phase II categories, including all Phase I facilities, financial and
service groups, and agricultural activities.
2.3.1.3 Service Sectors
Major SIC code groups in the service sectors, such as banking, finance, insurance firms,
and food services were not considered to be potential Phase II sources. The activities of
these enterprises are generally conducted indoors and do not inherently use or produce
contaminants that may enter storm water. Although these facilities may have general sources
such as parking lots or trash dumpsters which could contaminate storm water discharges, the
municipal analysis considers pollutant loadings from these types of sources. All of the major
SIC groups excluded on this basis are listed in Table 4-6. Regardless, the geographic and
distributional analysis was conducted for these facilities at the major group (two-digit SIC)
level. These results are presented in Appendix G.
2.3.2 Determining the Nature and Extent of Pollutants Associated With Industrial and
Commercial Discharges
The nature and extent of discharges from potential Phase II industrial and commercial
discharges were analyzed hi a manner that allows comparison with the municipal analysis in
terms of geographic distribution. The potential pollutant content of storm water from
industrial and commercial sites was characterized and the locations of these potential
discharges were analyzed with respect to urbanized areas. The nature of discharges was
evaluated by comparison to existing studies (i.e., NURP and USGS), by analysis of
discharge data from Phase I sources, and by compilation of qualitative information from a
literature survey. The geographic extent of discharges was evaluated by analyzing the
location of facilities using the FACTS data base hi conjunction with information from the
census, as explained below.
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Chapter 2—Approach
2.3.2.1 Identifying Pollutants Associated With Industrial and Commercial Discharges
Storm water discharged from industrial, commercial, and retail facilities has the potential
to come into contact with raw materials, products, and waste streams, which can result in
pollutant contamination of storm water discharges. A number of general categories of
activities and conditions that have the potential to generate contaminants in storm water have
been identified in both the proposed and final NPDES Permit Application Regulations for
Storm Water Discharges (53 FR 49416; 55 FR 47990):
• Outside loading of dry bulk or liquid materials that may be spilled or accumulated and
washed with rainfall into storm sewers or receiving waters
• Outside storage of raw materials, wastes, or products
• Outside processing of materials where rainfall may come into contact with materials in
the process stream
• Practices with the potential for spills to the storm sewer or wash down of processing
areas to floor drains
• High volume water use in material processing
• Direct application of wastes to the ground
• Dust and particulate generating processes
• Vehicle and equipment maintenance activities.
Most of these activities are specifically mentioned in the definition of discharges associated
with industrial activity (40 CFR 122.26(b)(14)).
To characterize potential industrial and commercial storm water discharges, data on
industrial and commercial sites and land uses were taken from the NURP and USGS studies
and analyzed statistically and presented for comparison purposes. Chapter 4 provides further
comparison and discussion. The results provide general insight into the nature of storm
water runoff from light industrial areas.
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Chapter 2—Approach
The nature of industry-specific storm water quality data was characterized by analyzing
sampling data submitted by group permit applicants under Phase I. These sampling results
provide insight into the nature of storm water from these industrial sites and storm water
from potential Phase n facilities which may have similar characteristics.
This analysis focused on the pollutants that were required to be analyzed for in the
Part n NPDES storm water permit group application plus copper, lead, and zinc. For each
pollutant and each industrial sector, the mean, median, and 95th percentile were calculated
for both grab and composite samples, where the pollutant was identified. Where applicants
reported none detected, the result was treated as zero, an approach consistent with the
analysis of data from Phase I industrial facilities as presented hi Appendix F. Chapter 4
summarizes these data. Appendix F contains detailed data summaries for each of 29
industrial sectors developed for the group application process.
To facilitate characterization of the nature of discharges from potential Phase II sources,
similarities between Phase I and Phase II facilities were highlighted by comparing categories
with similar activities, where possible. For facilities hi Group A, comparison to Phase I
sectors is generally straightforward and yields valuable information about these potential
Phase n facilities. For Group B facilities, the corresponding Phase I activity may not be as
similar. Comparisons were made only hi general terms at the industrial sector level and not
at the level of specific SIC codes or facilities. The resulting information presented hi
Chapter 4, therefore, can only be used as a guide to the general types and levels of pollutants
that may be found at facilities of a given category, rather than a definitive determination of
the degree of contamination at a particular site. These results are presented hi Chapter 4.
To supplement the Phase I data analysis, a literature review was conducted to locate and
summarize the available information on the nature of pollutants with emphasis on the groups
of categories selected by the screening procedure outlined above. The literature review
focused on identifying the types of pollutants that may be associated with particular
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Chapter 2—Approach
categories of facilities. General qualitative information on storm water discharges and
potential pollutants is available in the literature from a number of case studies and
assessments of specific locations and types of facilities. Although providing useful
background information, it is usually not comprehensive for any one category and may not
be comparable across categories.
2.3.2.2 Determining the Extent of Individual Phase II Sources
The extent of storm water discharges from Phase II sources was determined by
identifying the locations of the facilities in those categories, rather than the pollutant loads
associated with them, as in the municipal analysis. Nation-wide information on the extent of
pollutants from these facilities is limited. However, detailed quantitative information on the
geographic extent and distribution of these facilities can be developed by combining two data
sources
14.
• FACTS provides data, including name and address, county affiliation, primary
business activity (SIC), employment, and sales, on more than 7.7 million industrial,
commercial, retail, and government facilities.
• The 1990 Census of Population and Housing, discussed previously, provides detailed
information on population and area for most political subdivisions in the country.
County-level information on population associated with urbanized areas was used hi
this analysis.
An analysis was conducted to determine the distribution of individual Phase II facilities
and categories in relation to population patterns. To develop information comparable to the
municipal analysis, the analysis of individual sources was conducted at the county level.
This analysis was conducted to examine the distribution of industrial, commercial, and retail
enterprises to determine how they are distributed relative to jurisdictions of potential interest
hi development of potential Phase n regulatory approaches.
14 Information on number and location of facilities was limited to the 50 States and the District of Columbia.
Analysis of these statistics in relation to urbanized areas was not performed for the facilities and urbanized areas in the
Commonwealth of Puerto Rico.
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Chapter 2—Approach
The geographic analysis involved developing, for each county, population, and area, data
for all the same political and geographic jurisdictions studied in the municipal analysis, based
on the 1990 census data base. Jurisdictions of interest included urbanized areas and Phase I
cities, as discussed in Section 2.2, for municipal discharges. For each county, then, the
proportion of individual facilities within urbanized areas could be calculated, and the number
of facilities located in Phase I and Phase II areas could be determined.
Because the facility location data was not available at the same level of detail as census
data used hi the municipal analysis, the next step of the procedure made use of the
approximate correlation between the location of business and economic activity and the
distribution of population. Specifically, the analysis relies on the premise that industrial and
commercial facilities are distributed similarly to population within county jurisdictional
boundaries. For example, the percentage of facilities estimated to be hi the urbanized area of
a county is allocated based on the percentage of population hi the urbanized area of the
county. The premise may be more valid for urban retail activities, such as automobile
service activities, and less valid for agricultural activities, which are generally less likely to
be associated with urban areas. However, when considering all counties together, as shown
hi Chapter 4, this procedure produces reasonable results, even for rural businesses, because
they are more often located hi counties with small urban populations.
Using FACTS, individual facilities were counted for each SIC code and for each
county.15 By basing the distribution of facilities on the distribution of population within a
county, it was possible to allocate a portion of the facilities hi each county to urbanized
areas. The national total for each jurisdictional class was obtained by summing over all
counties.
15 A few facilities had incomplete records for county name and so could not be analyzed using this procedure.
Given the intensive data collection activities of Dun & Bradstreet and the focus on economic activity for marketing
purposes, the largest and most economically important facilities probably have the most complete records. Thus, the
types of facilities with incomplete records are probably small and economically less significant.
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Chapter 2—Approach
2.4 LITERATURE REVIEW PROCESS
The literature review for information about storm water discharges, sources, and
pollutants was fundamental to the approach. The following sections describe the activities
conducted during the literature search.
2.4.1 Libraries
An extensive literature search was conducted at several libraries, including the University
of Maryland and George Washington University, the Library of Congress, the USGS library,
and the National Agricultural Library. The On-Line Computer Library Center (OCLC), a
national bibliographic data base of 27 million records representing the holdings of more than
15,000 libraries worldwide, was accessed at the University of Maryland. Libraries that use
OCLC primarily include public libraries, university libraries, and governmental agency
libraries, such as the Department of Interior, Department of Agriculture, and the USGS.
The system enables the user to search for periodicals, books, and other publications by using
author, title, or subject key words. Numerous key words and phrases were searched,
including key words associated with the activities of industries selected for the Phase II
analysis. General terms such as storm water, industrial pollution, and names of products or
contaminants thought to be associated with particular industries were also searched using
OCLC.
At the Library of Congress, a data base search was conducted for information hi trade
association journals and other publications, environmental engineering journals and
periodicals, environmental business journals and periodicals, and other publications that
potentially have information related to the industrial analysis. Many of the trade association
publications are only available to association members. For those publications found hi
library holdings, a search was conducted for articles that did not show up during the OCLC
search. The data base used at the Library of Congress comprises numerous computerized
disk files, each containing information on various subjects, such as science and engineering.
The science and engineering disk (the most closely related topic area) was used to search for
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Chapter 2—Approach
periodicals available through local libraries. Back-issues of many of the more topical
publications were scanned for information relevant to the industrial analysis. The majority of
periodicals searched are included in the list given hi Table 2-6. At each library, library-
specific data bases were searched for documents located hi the individual library but not
entered into the OCLC data base.
Table 2-6. List of Periodicals and Journals Searched
Autoracing Digest
Automotive Industries
Automotive Repair News
Automotive Review
Automotive Week
Chemical Business
Chemical Industry Notes
Chemical Engineering
Chemical Marketing
American Petroleum Institute's Annual Report
Service Station Management
Petroleum Independent
Petroleum Marketer
Environmental Progress
Environmental Pollution
Environmental Research
Environmental Science and Technology
Water Research
Water Resources Bulletin
Water Resources Research
Oil and Gas Journal
Water Science and Technology
Pollution Engineering
Journal of Testing and Evaluation
Successful Farming
Plant Engineering
Water/Engineering and Management
Waste Age
Modern Casting
Journal of Environmental Quality
Journal of Water Pollution Control Federation
Journal of Water Resource Planning and
Management
Journal of Transportation Engineering
Journal of Irrigation and Drainage Engineering
Science
Pipeline and Gas Journal
American Industrial Hygiene Association
Journal
Pipe Line Industry
JAPCA
Material Handling Engineering
Engineering News Record
The Engineer
Highway and Heavy Construction
Plastics World
ISA Transactions
Chemical and Engineering News
Biocycle
The Management of World Wastes
Metal Finishing
2.4.2 Additional Resources
Other resources used hi the literature search included EPA documents and periodicals hi
the Pollution Prevention Information Clearinghouse and Toxic Release Information System,
documents available through EPA, EPA's docket, topic-related development documents and
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Chapter 2—Approach
effluent guidelines limitations, and publications from State offices related to potential
Phase II industries. Additional organizations and individuals were contacted to obtain
information on pollutant concentrations in storm water discharges from industrial facilities,
especially potential Phase II sources. Only a few documents obtained contained industry-
specific pollutant concentration data. The rest provided background information on potential
Phase n sources. Organizations contacted specifically for information include the U.S.
Department of Defense, the number and a list of military bases; the U.S. Department of
Transportation, for an estimate on the acreage or miles of road disturbed per year; the Forest
Service at the U.S. Department of Agriculture, for data on storm water discharges from the
construction of roads for logging and related activities; and the National Estuary Program, to
ascertain data on storm water impacts outlined hi estuary management programs.
A list of the documents obtained from the various sources mentioned above is included in
the bibliography at the end of this report. Other documents available hi the EPA docket
(Record For Proposed NPDES Storm Water Implementation Package) were also reviewed.
2.4.3 Potential for Obtaining Additional Information
Based on research efforts for the Report to Congress, quantitative information on
pollutant concentrations (and loadings) from industrial activities, especially potential Phase II
(unregulated) categories, is limited. EPA's literature search for information on industrial
sources identified many major categories of information. Pursuing additional sources of
information and extending the literature review effort would probably yield more qualitative
information to enhance the existing information on industrial sources. In particular,
information on the processes and activities associated with the facilities and a better idea of
the types of pollutants involved could potentially be documented. By focusing on particular
industry sectors, it may be possible to get more information on the number and size of
facilities, as well as information on quantities of products mined, distributed, etc.
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Chapter 3—Municipal Separate Storm Sewer Systems
CHAPTERS. MUNICIPAL SEPARATE STORM SEWER SYSTEMS
Section 402(p)(2) of the Clean Water Act (CWA) requires the control of discharges from
municipal separate storm sewer systems serving a population of 100,000 or more under
Phase I of the NPDES storm water program. This chapter identifies municipal separate
storm sewer systems not identified hi Phase I that potentially may be subject to requirements
under Phase II of the NPDES storm water program. In addition, this chapter describes the
nature and extent of pollutants associated with municipal separate storm sewer systems, with
an emphasis on potential Phase II sources. To provide an appropriate context for the
discussion of potential Phase II sources, this chapter also discusses Phase I municipal
systems.
Municipal separate storm sewer systems are comprised of conveyances designed to
collect and convey storm water (but not sanitary sewage1) that are owned or operated by a
municipality. Section 402(p)(3) of the CWA authorizes EPA and NPDES States to issue
system-wide or jurisdiction-wide permits for discharges from municipal separate storm sewer
systems. NPDES permits for discharges from municipal separate storm sewer systems are to
contain requirements to reduce the discharge of pollutants to the maximum extent practicable
(MEP) and to effectively prohibit non-storm water discharges to the municipal system hi
order to meet water quality standards. These requirements can be implemented through
municipal storm water management programs to control pollutants from targeted commercial,
residential, industrial, and other sources that discharge storm water (or other non-storm water
discharges) through the municipal system.
3.1 IDENTIFICATION OF MUNICIPAL SEPARATE STORM SEWER SYSTEMS
The Bureau of the Census estimates that the population of the United States and
associated territories was more than 252.2 million hi 1990.2 There are 19,289 incorporated
1 Combined sewers are conveyances designed to collect and convey both storm water and sanitary sewage. This
report generally does not address combined sewers.
2 Population estimates based on the 50 states, the District of Columbia, Guam, the Commonwealth of Puerto
Rico, the Virgin Islands, American Samoa, and the Commonwealth of the Northern Mariana Islands.
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Chapter 3—Municipal Separate Storm Sewer Systems
places and 17,796 minor civil divisions hi the continental United States, Alaska, and Hawaii.
These incorporated places and minor civil divisions are located hi 3,141 counties or county
equivalents. As discussed hi Chapter 2, Table 2-2 provides the Bureau of the Census
definitions for the major forms of municipal government.
3.1.1 Population Distributions
The Bureau of the Census defines two classes of population: urban and rural. The
majority of the population hi the United States is classified as urban (188 million or 75
percent of the total U.S. population), with only 25 percent of the population classified as
rural.
3.1.1.1 Urbanized Areas
To provide a better separation of urban and rural population and housing in the vicinity
of large cities, the Bureau of the Census defines an urbanized area as a central city (or cities)
with a surrounding area that is densely settled (i.e., urban fringe). The population of the
entire urbanized area must be greater than 50,000 persons, and the urban fringe must have a
population density generally greater than 1,000 persons per square mile (just over 1.5
persons per acre). As discussed hi Chapter 2, Table 2-2 provides the definitions of urban
populations, rural populations, and urbanized areas used hi the 1990 census.
The Bureau of the Census identified 405 urbanized areas of 50,000 or more people based
on the 1990 census. The combined population of these areas was more than 160 million
people (63 percent of the total U.S. population and 85 percent of the urban population).
However, these areas occupy less than 2 percent of the Nation's total land area. Figure 3-1
shows the location of the 405 urbanized areas.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-1 gives the number of urbanized areas in different size classes. Table 3-2
provides the distribution of urbanized populations and municipalities by State.
Table 3-1. Size Distribution of Urbanized Areas in 1990
Urbanized Area
Population
Range
Over 1,000,000
500,000 - 999,999
250,000 - 499,999
150,000 - 249,999
100,000 - 149,999
75,000 - 99,999
60,000 - 74,999
50,000 - 59,999
TOTALS
Number of
Urbanized
Areas
34
26
44
62
63
58
55
63
405
Total
Population
95,237,380
17,955,916
15,470,005
11,945,413
7,538,363
5,045,917
3,705,855
3,485,284
160,384,133
Total
Area
(sq.mi.)
27,749
8,122
7,732
5,877
4,366
3,058
2,375
2,241
61,520
Average
Area
(sq.mi.)
816
312
176
95
69
53
43
36
Average
Population
Density
(pop./sq.mi.)
3,432
2,211
2,001
2,033
1,727
1,650
1,560
1,555
Source: 1990 Census of Population and Housing, Bureau of the Census, U.S. Dept. of Commerce
3.1.1.2 Metropolitan Areas
The Office of Management and Budget (OMB) identifies metropolitan areas based on
economic and social trends, as well as population densities. The general concept of a
metropolitan area is one of a large population nucleus, together with adjacent communities
which have a high degree of economic and social integration. Metropolitan areas have a
total population of 100,000 or more (75,000 in New England) and contain either a place with
a population of 50,000 or more or an urbanized area of 50,000 or more. A metropolitan
area is comprised of one or more central counties and outlying counties that have close
economic and social relationships with the central county. Unlike a Census-designated
urbanized area with boundaries that follow population patterns, the boundaries of a
metropolitan area follow county boundaries3 and can contain significant tracts of rural land.
3 In New England, metropolitan areas follow town boundaries.
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Chapter 3—Municipal Separate Storm Sewer Systems
Figure 3-1. Urbanized Areas of the United States
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Chapter 3—Municipal Separate Storm Sewer Systems
URBANIZED AREA POPULATION
it 1,000,000 « mon
• 250,000 - 999,999
A 100,000 - 249,999
• 50,000 - 99,999
Figure 3-1. Urbanized Areas of the United States (continued)
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-2. Populations in Urbanized Areas
State
Alaska
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
District of Columbia
Delaware
Florida
Georgia
Hawaii
Iowa
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Maine
Michigan
Minnesota
Missouri
Mississippi
Urbanized
Area
Population
221,883
1,839,966
591,420
2,655,997
25,466,131
2,377,820
2,455,697
606,900
458,749
10,177,624
3,260,674
747,109
942,653
278,200
8,478,687
2,692,676
1,018,604
1,276,855
2,228,018
4,730,382
3,581,461
266,732
5,812,473
2,370,935
2,782,738
617,412
Number of
Urbanized
Areas
1
12
6
3
38
8
12
1
2
27
11
2
8
3
18
13
5
7
9
13
7
4
16
7
6
5
State
Montana
North Carolina
North Dakota
Nebraska
New Hampshire
New Jersey
New Mexico
Nevada
New York
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Virginia
Vermont
Washington
Wisconsin
West Virginia
Wyoming
TOTAL
Urbanized
Area
Population
208,883
2,512,866
202,334
687,875
339,454
6,629,540
649,793
911,095
14,116,042
6,656,974
' 1,354,343
1,420,059
7,207,497
2,125,255
824,534
1,426,739
163,986
2,218,007
11,372,246
1,319,551
3,829,739
87,088
3,214,738
2,464,721
388,840
114,138
160,384,133
Number of
Urbanized
Areas
3
17
3
3
5
7
4
2
14
20
4
5
20
9
3
10
3
9
32
4
11
1
10
15
7
2
467*
*Urbanized areas which crossed state boundaries were counted more than once. There are 405 distinct urbanized areas
nationwide.
Source: 1990 Census of Population and Housing, Bureau of the Census, U.S. Dept. of Commerce
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Chapter 3—Municipal Separate Storm Sewer Systems
OMB has defined 284 metropolitan areas based on the 1990 census. Figure 3-2
shows the location of the 284 metropolitan areas. These areas have a combined population
of 192.7 million or 77 percent of the total U.S. population. This total includes rural
populations of 26.5 million (14 percent of the metropolitan area population). Metropolitan
areas occupy about 16.6 percent of the land area of the United States (about 88 percent of
which is rural). There are 6,998 incorporated places (2,732 of which are rural) and 823
counties located hi metropolitan areas. Table 3-3 provides a distribution of population inside
and outside of metropolitan areas.
Table 3-3. Populations Inside and Outside of Metropolitan Areas in 1990
Inside Metropolitan Area
Urban in Urbanized Area
Urban Not in Urbanized Area
Rural
Outside Metropolitan Area
Urban in Urbanized Area
Urban Not in Urbanized Area
Rural
Population
159,624,517
8,854,157
27,032,065
1,537,739
19,583,295
35,701,936
Area (sq.mi.)
66,311
9,507
551,310
1,394
18,023
3,136,894
Source: Bureau of the Census
3.1.2 Identification of Phase I Municipal Systems
Section 402(p) of the CWA identifies discharges from municipal separate storm sewer
systems serving a population of 100,000 or more as Phase I sources under the NPDES storm
water program. Municipal separate storm sewer systems serving a population of 100,000 or
more are defined hi the NPDES regulations at 40 CFR 122.26(b)(4) and (7) to include:
• Incorporated cities with a population of 100,000 or more
• Counties with populations of 100,000 or more hi unincorporated, urbanized areas
(excluding the population of towns and townships)
• Municipalities designated by EPA or an authorized NPDES State as having Phase I
municipal separate storm sewer systems.
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Chapter 3—Municipal Separate Storm Sewer Systems
Figure 3-2. Metropolitan Areas of the United States
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Chapter 3—Municipal Separate Storm Sewer Systems
Figure 3-2. Metropolitan Areas of the United States (continued)
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Chapter 3—Municipal Separate Storm Sewer Systems
In addition, discharges from municipal separate storm sewer systems can be addressed
under Phase I of the NPDES program if they are designated under Section 402(p)(2)(E) of
the CWA as significant contributors of pollutants to waters of the United States or if they
have contributed to a violation of a water quality standard.
Table 3-4 summarizes population and area estimates for municipalities with separate
storm sewer systems subject to Phase I of the NPDES program. Appendix A lists Phase I
municipal separate storm sewer systems. All but eight States (i.e., Maine, Montana, North
Dakota, New Hampshire, New Jersey, Rhode Island, Vermont, and Wyoming) have one or
more Phase I municipal separate storm sewer system. Table 3-5 summarizes Phase I
municipal separate storm sewer systems by State.
Table 3-4. Municipalities Addressed by Phase I of the NPDES Storm Water Program
Phase I Municipalities
Identified by Regulation* Cities
Counties
Designated by EPA/States Cities
Counties
Other ***
Number
140
45
481
32
60
Population
(millions)
50.9
17.1 **
14.5
3.5**
NA
Area
(sq.mi.)
17,634
83,254 **
5,017
27,862 **
NA
* These counts exclude cities with a population of 100,000 or more that are exempted from Phase I of the
water program due to populations served by combined sewers.
** Includes all of regulated counties. Of the 17.1 million people in counties identified by regulation, 14.6
are in urbanized unincorporated areas. Of the 3.5 million people hi designated counties, 2.1 million are in
urbanized unincorporated areas.
*** "Other" pertains to a municipality that is not defined by U.S. census political boundaries (i.e., State
DOTs, drainage districts, universities, etc.).
3-10
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-5. Summary of Phase I Municipalities (by State)
State / Territory
Alaska
Alabama
American Samoa
Arkansas
Arizona
California
Colorado
Connecticut
District of Columbia
Delaware
Florida
Georgia
Guam
Hawaii
Iowa
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Maine
Michigan
Minnesota
Missouri
Mississippi
Montana
Identified by Regulation
Incorporated
Places
1
4
0
1
4
25
4
1
1
0
8
4
0
0
2
1
1
2
3
2
3
2
1
0
5
2
3
1
0
Counties
0
0
0
0
1
9
0
0
0
1
9
4
0
1
0
0
0
0
0
1
1
0
4
0
0
0
0
0
0
Designated
Incorporated
Places
0
35
0
0
0
217
1
0
0
13
126
35
0
0
1
1
0
0
0
0
4
1
6
0
0
0
0
0
0
Counties
0
5
0
0
0
6
1
0
0
0
4
5
0
0
0
0
0
0
0
0
1
0
6
0
0
0
0
0
0
Phase I
Population
226,338
1,233,803
0
175,795
2,066,289
23,496,438
1,330,143
108,056
606,900
441,946
8,824,892
2,870,325
0
847,952
397,271
132,107
139,426
904,399
573,661
753,618
1,498,681
847,481
3,809,266
0
702,153
640,618
687,941
196,637
0
3-11
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-5. Summary of Phase I Municipalities (by State) (continued)
State / Territory
North Carolina
North Dakota
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
Northern Mariana Islands
Ohio
Oklahoma
Oregon
Palau
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Virgin Islands
Virginia
Vermont
Washington
Wisconsin
West Virginia
Wyoming
TOTAL
Identified by Regulation
Incorporated
Places
5
0
2
2
0
0
1
5
0
6
2
3
0
2
0
0
0
1
4
15
1
0
6
0
2
2
0
0
140
Counties
1
0
0
1
0
0
0
0
0
0
0
1
0
0
0
0
2
0
0
1
1
0
4
0
3
0
0
0
45
Designated
Incorporated
Places
1
0
0
3
0
0
0
0
0
0
0
23
0
0
0
0
0
0
9
4
0
0
1
0
0
0
0
0
481
Counties
0
0
0
1
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
32
Phase I
Population
1,325,072
0
527,767
981,688
0
0
384,736
7,322,564
0
2,240,572
812,021
1,349,799
0
1,690,667
0
0
397,573
100,814
1,484,247
7,843,991
434,446
0
2,909,207
0
1,895,943
819,350
0
0
86,032,593
3-12
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Chapter 3—Municipal Separate Storm Sewer Systems
3.1.2.1 Incorporated Cities With a Population of 100,000 or More
The Phase I NPDES storm water regulations initially specifically identified 173
incorporated places with a population of more than 100,000.4 However, 30 of the 173 cities
with a population of 100,000 or more have been excluded from Phase I of the NPDES storm
water program because, after the population served by combined sewers is subtracted from
the total city population, the population served by separate storm sewers is less than
100,000.5 Table 3-6 lists the cities excluded from Phase I because of populations served by
combined sewers.
The description of Phase I sources presented in this report includes available information
on cities given exemptions from Phase I because of populations served by combined sewers.
3.1.2.2 Counties With Urbanized, Unincorporated Populations of 100,000 or More
Phase I of the NPDES storm water regulations specifically identify municipal separate
storm sewer systems in unincorporated portions of 45 counties as needing an NPDES
permit.6 Counties specifically identified hi the Phase I regulations were described as having
100,000 or more people (based on the 1980 census) who live hi unincorporated areas and are
part of an urbanized area designated by the Bureau of the Census. EPA identified counties
with large unincorporated, urbanized populations for regulation under Phase I of the NPDES
4 The specific cities listed in the current NPDES storm water regulations were based on 1980 census data.
Thirty-five cities had populations of less than 100,000 under the 1980 census but have populations of 100,000 or
more based on the 1990 census. Five cities had populations of more than 100,000 under the 1980 census but have
populations of less than 100,000 based on the 1990 census. For the purposes of this Report, these 40 cities are not
addressed as Phase I municipalities, unless they have been designated by EPA or an authorized NPDES State as
needing a permit as of January 1994.
5 To account for populations served by combined sewers, 40 CFR 122.26(f)(3) allows municipalities to petition
EPA or an authorized NPDES State to reduce their population for the purpose of Phase I population determinations.
6 The specific counties listed in the current NPDES storm water regulations were based on 1980 census data.
Thirteen counties had unincorporated, urbanized populations of less than 100,000 under the 1980 census but have
unincorporated, urbanized populations of 100,000 or more based on the 1990 census. Two counties had
unincorporated, urbanized populations of more than 100,000 under the 1980 census but have unincorporated,
urbanized populations of less than 100,000 based on the 1990 census. For the purposes of this Report, these 15
counties are not addressed as Phase I municipalities, unless they have been designated by EPA or an authorized
NPDES State as needing a permit.
3-13
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-6. Cities With Populations of 100,000 or More Given Exemption Under
Phase I of the NPDES Storm Water Regulations Due to Combined Sewers
State
California
Connecticut
Illinois
Indiana
Massachusetts
Michigan
Missouri
New Jersey
New York
Pennsylvania
Rhode Island
Virginia
Washington
TOTAL
City
San Francisco
Bridgeport
Hartford
New Haven
Waterbury
Chicago
Peoria
Evansville
Gary
South Bend
Springfield
Detroit
Livonia
Lansing
St. Louis
Elizabeth
Jersey City
Newark
Paterson
Buffalo
Albany
Rochester
Syracuse
Yonkers
Pittsburgh
Erie
Providence
Alexandria
Richmond
Spokane
City
Population
723,959
141,686
139,739
130,474
108,961
2,783,726
113,504
126,272
116,646
105,511
156,983
1,027,974
100,850
127,321
396,685
110,002
228,537
275,221
140,891
328,123
101,082
231,636
163,860
188,082
369,879
108,718
160,728
111,183
203,056
177,196
9,198,485
CSO Service
Population
723,959
50,000
110,000
84,300
99,947
2,783,726
77,000
50,425
116,646
100,000
156,983
1,017,880
100,850
50,000
396,685
107,000
223,532
275,221
140,891
328,123
96,500
231,636
140,800
184,812
369,879
108,719
160,728
66,000
352,775
135,600
8,840,617
3-14
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Chapter 3—Municipal Separate Storm Sewer Systems
storm water program because they were the primary municipal entity governing
unincorporated areas. Because they are the primary municipal entity, these counties are the
functional equivalent to an incorporated city for the purposes of a storm water program (i.e.,
the county generally performs many of the same functions and has the same legal and land
use authority as incorporated cities). The 45 counties identified hi this manner are located hi
17 States, with the majority of the counties (33) being located hi 6 States—Florida (9
counties), California (9 counties), Georgia (4 counties), Maryland (4 counties), Virginia (4
counties), and Washington (3 counties).
In 20 States, unincorporated portions of counties or county equivalents are divided into
minor civil divisions. The criteria used to define Phase I municipal separate storm sewer
systems did not address systems hi counties with a population of 100,000 or more hi these
States, even where the unincorporated portions of the county were heavily urbanized. The
Agency did not address such areas under Phase I of the program because of the complexities
of the intergovernmental relationship between the county and incorporated places and minor
civil divisions.
3.1.2.3 Designated Municipalities
The NPDES regulations authorize EPA or NPDES States to designate additional
municipal systems as needing a permit under Phase I of the storm water program.7 To date,
481 incorporated places and 32 counties have been designated by EPA and authorized
NPDES States. These designated municipalities have a combined population of more than 18
7 Designations can occur under two authorities. 40 CFR 122.26(b)(4) and (7) provide that additional municipal
separate storm sewers may be designated as part of a system serving a population of 100,000 or more because of the
interrelationship between the discharges of the designated storm sewers and the discharges from municipal separate
storm sewers located in an incorporated place with a population of 100,000 or more or a county with an urbanized,
unincorporated population of 100,000 or more. Additional municipal separate storm sewers within a region defined
by a storm water management regional authority can be designated based on a jurisdictional, watershed, or other
appropriate basis that includes an incorporated place with a population of 100,000 or more or a county with an
urbanized, unincorporated population of 100,000 or more. Section 402(p)(2)(E) of the CWA provides that storm
water discharges, including discharges from municipal separate storm sewer systems, that are a significant
contributor of pollutants to waters of the United States or that have contributed to a violation of a water quality
standard can be designated as needing a permit.
3-15
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Chapter 3—Municipal Separate Storm Sewer Systems
million. The majority of the designations (464 incorporated places and 28 counties) are in
eight States (Alabama, California, Delaware, Florida, Georgia, Maryland, Oregon, and
Tennessee). Municipalities have been designated as part of the Phase I NPDES storm water
program in seven other States.
3.1.3 Identification of Potential Phase H Municipal Systems
Municipal separate storm sewer systems that are potentially subject to requirements under
Phase H of the NPDES storm water program will be identified in terms of the following
classes:
• Municipalities not addressed by Phase I, but located hi an urbanized area with one or
more Phase I municipalities
• Municipalities associated with an urbanized area without a Phase I municipality
• Urban populations outside of urbanized areas
• Rural populations
• Populations not addressed in the census.
3.1.3.1 Potential Phase H Municipalities Associated With Urbanized Areas With One or
More Phase I Municipalities
Of the 405 urbanized areas designated by the Bureau of the Census, 136 have one or
more municipalities with a separate storm sewer system addressed by Phase I of the NPDES
storm water program. In most of these 136 urbanized areas, municipalities not addressed
under Phase I are also found in the urbanized area. Table 3-7 lists the 136 urbanized areas
with one or more Phase I municipalities. Table 3-8 summarizes the number of municipalities
associated with different sizes of urbanized areas with a municipality with separate storm
sewers subject to Phase I of the storm water program. Note that some urbanized areas cross
state lines and are listed in the table hi multiple states. In those cases, the portion of the
urbanized area in each state is listed, rather than the total population within the urbanized
area.
3-16
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-7. Urbanized Areas With One or More Municipality in Phase I
of the NPDES Storm Water Program
State
AK
AL
AR
AZ
CA
CO
CT
DC
DE
PL
Urbanized Area
Anchorage, AK
Birmingham, AL
Columbus, GA— AL
Huntsville, AL
Mobile, AL
Montgomery, AL
Little Rock— North Little Rock, AR
Memphis, TN— AR— MS
Phoenix, AZ
Tucson, AZ
Antioch— Pittsburg, CA
Bakersfield, CA
Fairfield, CA
Fresno, CA
Hemet— San Jacinto, CA
Hesperia — Apple Valley— Victorville, CA
Indio— Coachella, CA
Lancaster — Palmdale, CA
Los Angeles, CA
Modesto, CA
Oxnard — Ventura, CA
Palm Springs, CA
Riverside — San Bernardino, CA
Sacramento, CA
Salinas, CA
San Diego, CA
San Francisco— Oakland, CA
San Jose, CA
Simi Valley, CA
Stockton, CA
Colorado Springs, CO
Denver, CO
Pueblo, CO
Stamford, CT— NY
Worcester, MA— CT
Washington, DC— MD— VA
Wilmington, DE— NJ— MD— PA
Fort Lauderdale— Hollywood — Pompano Beach,
FL
Fort Myers — Cape Coral, FL
Jacksonville, FL
Lakeland, FL
Miami — Hialeah, FL
Orlando, FL
Pensacola, FL
Sarasota — Bradenton, FL
Spring Hill, FL
Tallahassee, FL
Total
Population
221,883
622,774
32,288
180,315
300,912
210,007
305,353
34,600
2,006,239
579,235
153,768
302,605
99,964
453,388
90,929
153,176
56,038
187,190
11,402,946
230,609
480,482
129,025
1,170,196
1,097,005
122,225
2,348,417
3,629,516
1,435,019
128,043
262,046
352,989
1,517,977
106,155
187,180
555
606,900
407,962
1,238,134
220,552
738,413
147,628
1,914,660
887,126
253,558
444,385
52,056
155,884
Phase I
Population
221,883
577,979
0
173,623
255,494
187,106
175,795
0
1,410,951
567,493
146,205
302,605
99,897
403,065
90,929
66,646
2,624
21,990
11,402,946
164,730
387,907
13,200
1,170,196
100,4620
108,777
2,348,417
2,644,467
1,411,091
128,043
210,943
280,995
918,955
98,640
108,056
0
606,900
407,962
1,183,036
102,337
627,128
147,628
1,902,397
746,006
225,628
375,194
3,463
124,773
No. of
Incorporated
Places
1
25
1
2
6
2
7
3
15
3
3
1
2
2
2
3
2
2
115
2
7
6
13
5
1
18
63
14
2
1
3
23
1
1
0
1
9
27
2
6
2
25
17
2
8
1
1
No. of
Minor
Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
1
0
0
0
0
0
0
0
0
0
0
0
0
No. of
Counties
1
2
2
1
1
3
2
1
2
1
1
1
1
1
1
1
1
1
4
1
2
1
2
3
1
1
7
1
1
1
1
7
1
1
1
1
, 1
1
1
3
1
1
2
2
3
2
1
3-17
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-7. Urbanized Areas With One or More Municipality in Phase I
of the NPDES Storm Water Program (continued)
State
FL
GA
HI
IA
ID
IL
IN
KS
KY
LA
MA
MD
MI
MN
Urbanized Area
Tampa— St.Petersburg— Clearwater, FL
West Palm Beach— Boca Raton— Debray Beach,
FL
Winter Haven, FL
Atlanta, GA
Augusta, GA— SC
Chattanooga, TN— GA
Columbus, GA— AL
Macon, GA
Savannah, GA
Honolulu, HI
Kailua, HI
Cedar Rapids, IA
Davenport— Rock Island— Moline, IA— IL
Des Moines, IA
Omaha, NE— IA
Boise City, ID
Davenport— Rock Island— Moline, IA— IL
Rockford, IL
Fort Wayne, IN
Indianapolis, IN
Louisville, KY— IN
Kansas City, MO— KS
Topeka, KS
Wichita, KS
Cincinnati, OH— KY
Lexington-Fayette, KY
Louisville, KY— IN
Baton Rouge, LA
New Orleans, LA
Shreveport, LA
Boston, MA
Lowell, MA-NH
Worcester, MA— CT
Annapolis, MD
Baltimore, MD
Frederick, MD
Hagerstown, MD— PA— WV
Washington, DC— MD— VA
Wilmington, DE— NJ— MD— PA
Ann Arbor, MI
Detroit, MI
Flint, MI
Grand Rapids, MI
Toledo, OH-MI
Minneapolis— St.Paul, MN
Total
Population
1,708,710
794,848
86,427
2,157,806
217,002
46,194
188,410
129,496
198,630
632,603
114,506
136,190
128,950
293,666
59,890
167,941
135,068
207,826
248,424
914,761
100,159
480,249
132,711
338,789
236,349
220,701
654,797
365,943
1,040,226
256,489
2,775,370
180,716
315,111
78,590
1,889,873
58,393
68,226
1,420,999
13,732
222,061
3,697,529
326,023
436,336
18,817
2,079,676
Phase I
Population
1,680,343
791,286
86,427
2,031,973
151,214
0
173,196
125,952
194,888
632,603
114,506
108,751
94,942
193,187
0
132,107
0
139,426
173,072
731,327
0
149,767
119,883
304,011
0
218,925
508,493
322,070
938,384
198,525
574,283
103,439
169,759
78,488
1,889,873
14,100
28,321
1,169,907
0
109,592
262,674
140,761
189,126
0
640,618
No. of
Incorporated
Places
28
34
4
38
2
4
2
2
7
0
0
4
6
9
2
2
11
5
2
24
4
17
1
6
33
1
97
5
5
2
19
1
1
2
2
2
4
39
1
3
76
8
7
0
92
No. of
Minor
Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10
5
9
20
5
3
5
10
0
0
0
0
0
0
76
8
18
0
0
0
0
0
0
7
33
12
8
3
3
No. of
Counties
3
2
1
11
2
3
2
2
1
1
1
1
1
3
1
1
2
1
1
6
2
2
1
1
3
2
2
3
5
2
7
1
1
1
5
1
1
4
1
2
5
1
2
1
8
3-18
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-7. Urbanized Areas With One or More Municipality in Phase I
of the NPDES Storm Water Program (continued)
State
MO
MS
NC
NE
NH
NJ
NM
NV
NY
OH
OK
OR
PA
SC
SD
TN
Urbanized Area
Kansas City, MO— KS
Springfield, MO
Jackson, MS
Memphis, TN— AR— MS
Charlotte, NC
Durham, NC
Fayetteville, NC
Greensboro, NC
Raleigh, NC
Winston-Salem, NC
Lincoln, NE
Omaha, NE— IA
Lowell, MA-NH
Allentown— Bethlehem — Easton, PA— NJ
New York, NY— Northeastern New Jersey
Philadelphia, PA— NJ
Wilmington, DE— NJ— MD— PA
Albuquerque, NM
El Paso, TX— NM
Las Vegas, NV
Reno, NV
New York, NY— Northeastern New Jersey
Stamford, CT— NY
Akron, OH
Cincinnati, OH— KY
Cleveland, OH
Columbus, OH
Dayton, OH
Toledo, OH-MI
Oklahoma City, OK
Tulsa, OK
Eugene — Springfield, OR
Portland— Vancouver, OR— WA
Salem, OR
Allentown— Bethlehem— Easton, PA— NJ
Hagerstown, MD— PA— WV
Philadelphia, PA— NJ
Wilmington, DE— NJ— MD— PA
Augusta, GA— SC
Columbia, SC
Greenville, SC
Sioux Falls, SD
Chattanooga, TN— GA
Knoxville, TN
Memphis, TN— AR-MS
Nashville, TN
Total
Population
795,068
159,086
289,285
29,341
455,597
205,355
241,763
194,508
305,925
185,184
192,558
484,402
935
24,817
5,113,880
944,875
26,043
497,120
8,179
697,348
213,747
10,930,132
20
527,863
976,326
1,677,492
945,237
613,467
470,338
784,425
474,668
189,192
1,004,676
157,079
385,619
1,212
3,277,336
1,879
69,536
328,349
248,173
100,843
250,761
304,466
761,252
573,294
Phase I
Population
545,197
140,494
196,637
0
395,934
136,611
222,522
183,521
207,951
143,485
191,972
335,795
0
0
0
0
0
384,736
0
697,348
213,747
7,322,564
0
223,019
364,040
505,616
632,910
182,044
332,943
438,922
367,302
112,669
978,531
94,983
105,090
0
1,585,577
0
0
130,589
147,464
100,814
152,466
165,121
637,326
508,828
No. of
Incorporated
Places
31
2
8
2
6
3
3
1
4
4
1
6
0
2
192
43
1
4
1
3
2
125
0
20
40
76
24
17
12
23
6
2
22
2
18
0
67
0
3
9
6
1
9
5
3
10
No. of
Minor
Civil
Divisions
20
9
0
0
0
0
0
0
0
0
0
0
1
2
96
37
2
0
0
0
0
36
1
14
20
16
24
16
7
0
0
0
0
0
18
1
84
4
0
0
0
3
0
0
0
0
No. of
Counties
4
2
3
1
2
2
2
1
1
2
1
2
1
1
12
3
1
2
1
1
1
10
1
5
4
7
5
4
3
5
5
1
3
2
2
1
5
2
2
2
3
2
1
4
1
4
3-19
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-7. Urbanized Areas With One or More Municipality in Phase I
of the NPDES Storm Water Program (continued)
State
TX
UT
VA
WA
WI
WV
Urbanized Area
Abilene, TX
Amarillo, TX
Austin, TX
Beaumont, TX
Corpus Christi, TX
Dallas— Fort Worth, TX
El Paso, TX-NM
Houston, TX
Laredo, TX
Lubbock, TX
San Antonio, TX
Waco, TX
Salt Lake City, UT
Norfolk— Virginia Beach— Newport News, VA
Petersburg, VA
Richmond, VA
Roanoke, VA
Washington, DC— MD— VA
Portland— Vancouver, OR— WA
Seattle, WA
Tacoma, WA
Madison, WI
Milwaukee, WI
Hagerstown, MD— PA— WV
Total
Population
107,836
157,934
562,008
122,841
270,006
3,198,259
562,838
2,901,851
123,651
187,906
1,129,154
144,372
789,447
1,323,098
103,526
589,980
178,277
1,335,132
167,482
1,744,086
497,210
244,336
1,226,293
768
Phase I
Population
106,654
157,615
465,622
114,323
257,453
2,493,364
515,187
2,468,419
122,899
186,206
935,933
103,590
430,716
1,204,925
12,115
363,740
96,397
1,088,797
0
1,193,945
435,194
191,262
628,088
0
No. of
Incorporated
Places
3
1
7
3
2
56
3
34
1
1
18
8
16
10
3
1
3
8
1
30
11
7
35
0
No. of
Minor
Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
6
11
0
No. of
Counties
2
2
2
2
3
9
1
7
1
1
3
1
2
12
6
4
5
9
1
3
2
1
5
1
Table 3-8. Municipalities in Urbanized Areas With One or More Phase I Municipalities
Urbanized
Area
Population
50,000 - 74,999
75,000 - 99,999
100,000 - 124,999
125,000 - 149,999
150,000 - 249,999
Over 250.000
TOTALS
Number
of
Urbanized
Areas
4
4
8
7
32
81
136
Phase I Municipalities
Incorp.
Places
0
9
6
8
37
504
564
Counties
4
2
2
2
9
53
72
Phase I
Population
48,508
355,741
778,728
747,047
4,780,942
75,004,440
81,715,406
Portions of Urbanized Areas Not in Phase I
Incorp.
Places
9
1
7
17
45
1,508
1,587
Minor
Civil
Divisions
1
0
3
5
50
575
634
Counties
3
1
14
4
44
239
305
Phase n
Population
188,185
169
122,855
200,418
1,542,672
33,650,057
35,704,356
Total
Population
236,693
355,910
901,583
947,465
6,323,614
108,654,497
117,419,762
3-20
-------
Chapter 3—Municipal Separate Storm Sewer Systems
The 136 urbanized areas with one or more municipality with a separate storm sewer
system addressed by Phase I have a total population of 117.5 million (47 percent of the total
U.S. population). The portions of these urbanized areas currently not addressed by Phase I
of the NPDES storm water program have a combined population of 35.7 million people. Of
the 35.7 million people, 32.9 million people live in 1,587 incorporated places and 634 minor
civil divisions. The remaining 2.9 million people live hi unincorporated areas. EPA
estimates that 305 counties currently not addressed by Phase I of the NPDES storm water
program are part of an urbanized area in which one or more municipalities are in Phase I.
Two general patterns of municipal governments can be used to describe the 136
urbanized areas that have one or more Phase I municipalities. Most of the 136 urbanized
areas can be described as having a large core city with a population of 100,000 that is
addressed by Phase I of the program, with a large number of smaller potential Phase II
incorporated places and minor civil divisions surrounding the core city. Figure 3-3 provides
an example of this pattern, which illustrates the Milwaukee, Wisconsin, urbanized area.
The second pattern of municipal government for the 136 urbanized areas consists of
counties that do not have minor civil divisions. Urbanized areas that follow this pattern are
comprised of a core city (which is usually addressed by Phase I) surrounded by a
combination of unincorporated portions of counties and incorporated places. In urbanized
areas that follow this pattern, unincorporated portions of one or more of the counties
surrounding the core city may be in Phase I, while the smaller incorporated places
surrounding the core city are generally not addressed by Phase I. Figure 3-4 gives an
example of this pattern, which illustrates the Washington, D.C., urbanized area. Figure 3-4
also shows that Phase I jurisdiction for this urbanized area generally extends beyond the 1990
boundaries of the urbanized area. In this manner, Phase I addresses much of the new
development associated with the expanding urbanized population, even though it occurs
outside of the 1990 urbanized area boundary.
3-21
-------
Chapter 3—Municipal Separate Storm Sewer Systems
CEDARBURG
CEDARBURG
PhuclMuniciptlily
PotonblPhiMllMunldptlly
Figure 3-3. Phase I and Phase n Portions of Milwaukee, Wisconsin, Urbanized Area
3-22
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Urbanized
Population
Within Phase I
Urbanized
Area
Within Phase I
827 sq. mi.
,< -x-x.
f- Ar
> -.
Listed Phase I Municipality
Designated Phase I Municipality
D.C. Urbanized Area Boundary
WAV W/////////.
Figure 3-4. Phase I and Phase H Portions of Washington, DC, Urbanized Area
3-23
-------
Chapter 3—Municipal Separate Storm Sewer Systems
3.1.3.2 Potential Phase H Municipalities Associated With Urbanized Areas Without a
Phase I Municipality
A total of 269 of the Census-designated urbanized areas currently do not have any
municipalities with separate storm sewers subject to Phase I of the storm water program.
Table 3-9 lists these urbanized areas. As in Table 3-7, note that some urbanized areas cross
state lines and are listed hi the table in multiple states along with the portion of the
population in that state. Table 3-10 summarizes the population and number of municipalities
associated with different classes of urbanized areas without a municipality with separate
storm sewers subject to Phase I of the storm water program. Of the 269 urbanized areas,
101 (more than a third) have a population of more than 100,000 and 23 have a population of
more than 250,000. These 269 urbanized areas without a Phase I municipal separate storm
sewer system have a combined population of 42.9 million people (16 percent of the total
U.S. population). Of the 42.9 million people, 37.1 million people live in 1,470 incorporated
places and 966 minor civil divisions. The remaining 5.8 million people live in
unincorporated areas. EPA estimates that 380 counties that are part of an urbanized area do
not have a municipality addressed by Phase I of the NPDES storm water program.
Twenty-one urbanized areas have an incorporated city with a population of 100,000 or
more that are not subject to Phase I of the NPDES storm water program because of
populations served by combined sewers. Table 3-11 lists these urbanized areas. The 21
urbanized areas have a combined population of 17.5 million people, of which an estimated
11.7 million people are served by separate storm sewers. Three of these urbanized areas
(i.e., Chicago, St. Louis, and Pittsburgh) have populations of more than a million people that
are served by separate storm sewers. Of the remaining urbanized areas, 10 have a
population of more than 250,000 and 7 have a population of more than 175,000, but less
than 250,000. Of the 17.5 million people that live hi the 21 urbanized areas, 6.0 million
people live hi cities with a population of 100,000 or more.
3-24
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
State
AL
AR
AZ
CA
CO
CT
DE
FL
Urbanized Area
Anniston, AL
Auburn — Opelika, AL
Decatur, AL
Dothan, AL
Florence, AL
Gadsden, AL
Tuscaloosa, AL
Fayetteville — Springdale, AR
Fort Smith, AR— OK
Pine Bluff, AR
Texarkana, TX— Texarkana, AR
Yuma, AZ-CA
Chico, CA
Davis, CA
Lodi, CA
Lompoc, CA
Merced, CA
Napa, CA
Redding, CA
San Luis Obispo, CA
Santa Barbara, CA
Santa Cruz, CA
Santa Maria, CA
Santa Rosa, CA
Seaside— Monterey, CA
Vacaville, CA
Visalia, CA
Watsonville, CA
Yuba City, CA
Yuma, AZ— CA
Boulder, CO
Fort Collins, CO
Grand Junction, CO
Greeley, CO
Longmont, CO
Bridgeport— Milford, CT
Bristol, CT
Danbury, CT-NY
Hartford— Middletown, CT
New Britain, CT
New Haven— Meriden, CT
New London— Norwich, CT
Norwalk, CT
Springfield, MA— CT
Waterbury, CT
Dover, DE
Daytona Beach, FL
Deltona, FL
Fort Pierce, FL
Fort Walton Beach, FL
Total
Population
68,150
56,510
63,541
58,925
69,186
71,630
106,428
74,880
91,870
61,941
22,776
70,523
71,831
52,711
55,590
56,591
64,742
68,049
78,364
50,305
182,163
152,355
88,989
194,560
133,188
71,535
83,594
51,378
77,167
432
98,910
105,809
71,938
71,578
52,464
413,863
92,418
112,647
546,198
143,064
451,486
156,286
108,888
68,045
175,067
50,787
221,341
58,053
126,342
112,522
No. of
Incorporated
Places
5
2
4
5
4
6
2
5
3
2
1
1
1
1
1
1
1
1
1
1
2
3
1
3
7
1
1
1
2
0
1
1
1
4
1
6
1
1
2
1
3
3
1
0
2
3
9
0
3
7
No. of
Minor Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
14
7
7
19
5
16
13
5
6
8
0
0
0
0
0
No. of
Counties
2
1
2
2
2
2
1
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
2
3
2
3
1
3
1
1
2
2
1
1
1
1
3
3-25
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
FL
GA
IA
ID
IL
IN
* Urbanized Area
Gainesville, FL
Kissimmee, FL
Melbourne— Palm Bay, FL
Naples, FL
Ocala, FL
Panama City, FL
Punta Gorda, FL
Stuart, FL
Titusville, FL
Vero Beach, FL
Albany, GA
Athens, GA
Brunswick, GA
Rome, GA
Warner Robins, GA
Dubuque, IA— IL
Iowa City, IA
Sioux City, IA— ME— SD
Waterloo—Cedar Falls, IA
Idaho Falls, ID
Pocatello, ID
Alton, IL
Aurora, IL
Beloit, WI— EL
Bloomington— Normal, IL
Champaign— Urbana, IL
Chicago, IL— Northwestern Indiana
Crystal Lake, EL
Decatur, EL
Dubuque, IA— IL
Elgin, EL
Joliet, IL
Kankakee, EL
Peoria, EL
Round Lake Beach— McHenry, IL— WI
Saint Louis, MO-EL
Springfield, IL
Anderson, Dtf
Bloomington, IN
Chicago, EL— Northwestern Indiana
Elkhart— Goshen, IN
Evansville, IN— KY
Kokomo, IN
Lafayette— West Lafayette, IN
Muncie, IN
South Bend— Mishawaka, IN— MI
Terre Haute, IN
Total
Population
126,215
55,419
305,978
94,344
68,004
103,667
67,033
80,069
51,549
64,707
87,223
73,282
50,066
51,589
60,976
61,048
71,372
83,277
108,260
56,356
53,903
86,236
192,043
13,371
94,186
115,524
6,301,112
72,498
96,039
2,657
123,899
170,717
59,695
242,353
112,640
328,299
124,524
74,037
71,440
490,975
98,787
156,570
57,146
100,103
88,073
215,182
77,019
No. of
Incorporated
Places
1
1
13
1
1
6
1
3
1
2
1
2
1
1
2
2
3
2
5
3
2
7
7
3
2
3
179
7
4
1
7
8
4
12
14
26
5
7
1
19
2
2
1
2
3
5
3
No. of
Minor Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8
10
3
4
7
61
6
8
1
6
9
5
16
10
19
7
7
4
12
6
7
5
6
5
9
6
No. of
Counties
1
1
1
1
1
1
1
2
1
1
2
2
1
1
1
1
1
1
1
1
2
1
3
1
1
1
5
3
1
1
2
1
1
3
2
3
1
2
1
2
1
2
1
1
1
2
1
3-26
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
KS
KY
LA
MA
MD
ME
MI
MN
MO
Urbanized Area
Lawrence, KS
St. Joseph, MO— KS
Clarksville, TN— KY
Evansville, IN— KY
Huntington— Ashland, WV-KY-OH
Owensboro, KY
Alexandria, LA
Houma, LA
Lafayette, LA
Lake Charles, LA
Monroe, LA
Slidell, LA
Brockton, MA
Fall River, MA-RI
Fitchburg — Leominster, MA
Hyannis, MA
Lawrence— Haverhill, MA— NH
New Bedford, MA
Pittsfield, MA
Providence— Pawtucket, RI— MA
Springfield, MA— CT
Taunton, MA
Cumberland, MD— WV
Bangor, ME
Lewiston— Auburn, ME
Portland, ME
Portsmouth — Dover — Rochester, NH— ME
Battle Creek, MI
Bay City, MI
Benton Harbor, MI
Holland, MI
Jackson, MI
Kalamazoo, MI
Lansing— East Lansing, MI
Muskegon, MI
Port Huron, MI
Saginaw, MI
South Bend — Mishawaka, IN — MI
Duluth, MN— WI
Fargo— Moorhead, ND — MN
Grand Forks, ND— MN
LaCrosse, WI— MN
Rochester, MN
St. Cloud, MN
Columbia, MO
Joplin, MO
St. Joseph, MO-KS
St. Louis, MO— JL
Total
Population
65,755
1,100
21,724
26,517
56,122
60,645
86,001
65,879
129,592
119,067
110,737
54,084
160,910
126,508
82,249
66,713
212,000
139,082
55,047
93,090
464,702
58,884
51,648
61,402
71,598
120,220
13,512
77,921
74,118
57,744
62,418
78,126
164,430
265,095
106,252
62,774
140,079
22,750
95,356
34,923
8,658
4,725
73,560
74,037
75,854
60,208
74,295
1,618,227
No. of
Incorporated
Places
1
1
1
1
8
1
3
1
4
3
3
1
1
1
2
0
2
1
1
1
5
1
2
3
2
3
0
2
2
4
2
1
3
2
5
3
2
1
3
2
1
1
1
4
1
15
2
95
No. of
Minor Civil
Divisions
1
1
0
0
0
0
0
0
0
0
0
0
9
4
2
5
7
3
3
10
14
3
0
2
2
.4
5
4
5
4
4
4
7
7
5
7
8
3
1
2
, 0
1
3
5
4
5
4
39
No. of
Counties
1
1
1
1
2
1
1
2
1
1
1
1
3
1
1
1
1
1
1
3
2
1
1
1
1
1
1
2
1
1
2
1
1
3
1
1
1
2
1
1
1
1
1
3
1
2
2
4
3-27
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
MS
MT
NC
ND
NE
NH
NJ
NM
NY
OH
Urbanized Area
Biloxi— Gulijport, MS
Hattiesburg, MS
Pascagoula, MS
Billings, MT
Great Falls, MT
Missoula, MT
Asheville, NC
Burlington, NC
Gastonia, NC
Goldsboro, NC
Greenville.NC
Hickory, NC
High Point, NC
Jacksonville, NC
Kannapolis, NC
Rocky Mount, NC
Wilmington, NC
Bismarck, ND
Fargo— Moorhead, ND— MN
Grand Forks, ND— MN
Sioux City, IA— NE— SD
Lawrence— Haverhill, MA— NH
Lowell, MA— NH
Manchester, NH
Nashua, NH
Portsmouth— Dover— Rochester, NH— ME
Atlantic City, NJ
Trenton, NJ— PA
Vineland— Millville, NJ
Las Graces, NM
Santa Fe, NM
Albany— Schenectady— Troy, NY
Binghamton, NY
Buffalo— Niagara Falls, NY
Danbury, CT— NY
Elmira, NY
Glens Falls, NY
Ithaca, NY
Newburgh, NY
Poughkeepsie, NY
Rochester, NY
Syracuse, NY
Utica— Rome, NY
Canton, OH
Hamilton, OH
Huntington— Ashland, WV— KY-OH
Lima, OH
Lorain— Elyria, OH
Total
Population
179,643
59,757
59,386
88,181
63,506
57,196
110,429
74,053
113,637
60,230
55,884
69,914
108,686
101,297
78,177
50,870
101,357
66,476
86,413
49,445
10,915
25,362
935
114,918
96,791
101,448
169,993
255,696
94,236
81,471
63,023
509,106
158,405
954,332
3,593
66,612
56,475
50,132
71,584
148,527
619,653
388,918
158,553
244,576
118,315
33,791
68,621
224,087
No. of
Incorporated
Places
8
2
3
1
1
1
7
6
9
1
2
6
4
1
4
1
4
3
2
1
1
0
0
1
1
4
11
4
4
2
1
11
4
14
0
3
4
3
2
4
6
11
9
6
4
6
3
10
No. of
Minor Civil
Divisions
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
2
1
0
3
1
6
5
6
3
7
5
0
0
19
10
16
1
6
4
3
4
8
12
12
11
8
7
6
5
8
No. of
Counties
3
2
1
1
1
1
2
3
1
1
1
2
4
1
2
2
2
2
1
1
1
1
1
3
1
2
2
2
4
1
1
4
2
2
1
1
3
1
1
2
1
2
2
1
2
1
2
2
3-28
-------
Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
OH
OK
OR
PA
PR1
RI
SC
Urbanized Area
Mansfield, OH .
Middletown, OH
Newark, OH
Parkersburg, WV— OH
Sharon, PA— OH
Springfield, OH
Steubenville— Weirton, OH— WV— PA
Wheeling, WV-OH
Youngstown— Warren, OH
Fort Smith, AR— OK
Lawton, OK
Longview, WA— OR
Medford, OR
Altoona, PA
Erie, PA
Harrisburg, PA
Johnstown, PA
Lancaster, PA
Monessen, PA
Pittsburgh, PA
Pottstown, PA
Reading, PA
Scranton— Wilkes-Barre, PA
Sharon, PA— OH
State College, PA
Steubenville— Weirton, OH— WV— PA
Trenton, NJ— PA
Williamsport, PA
York, PA
Aquadilla, PR
Arecibo, PR
Caguas, PR
Cayey, PR
Humacao, PR
Mayaguez, PR
Ponce, PR
San Juan, PR
Vega Baja-Manatil, PR
Fall River, MA-RI
Newport, RI
Providence— Pawtucket, RI— MA
Anderson, SC
Charleston, SC
Florence, SC
Myrtle Beach, SC
Rock Hill, SC
Spartanburg, SC
Sumter, SC
Total
Population
76,521
98,822
54,063
6,840
6,229
88,649
38,855
25,255
361,627
2,616
92,634
. 2,138
66,974
76,551
177,668
292,904
77,841
193,583
65,072
1,678,745
53,371
186,267
388,225
46,587
61,239
392
42,906
57,425
142,675
99,936
88,967
190,922
53,945
57,144
110,904
190,079
1,221,086
112,272
17,850
53,481
753,203
52,492
393,956
54,659
58,384
58,757
104,801
57,632
No. of
Incorporated
Places
3
6
2
1
0
1
4
5
12
2
1
1
3
3
2
17
14
7
20
136
2
16
44
6
1
0
2
4
11
0
1
7
1
10
2
2
2
2
1
No. of
Minor Civil
Divisions
5
8
5
1
2
3
4
4
13
0
0
0
0
6
6
16
10
13
6
73
8
12
19
2
4
1
3
5
10
2
3
17
0
0
0
0
0
0
0
No. of
Counties
1
3
1
1
1
1
1
1
2
2
1
1
1
1
1
5
2
2
3
5
3
1
2
1
1
1
1
1
1
1
1
4
1
3
2
2
1
1
1
3-29
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
SD
TN
XX
UT
VA
VT
WA
WI
Urbanized Area
Rapid City, SD
Sioux City, IA— NE— SD
Bristol, TN-Bristol, VA
Clarksville, TN-KY
Jackson, TN
Johnson City, TN
Kingsport, TN— VA
Brownsville, TX
Bryan— College Station, TX
Denton, TX
Galveston, TX
Harlingen, TX
Killeen, TX
Lewisville, TX
Longview, TX
McAllen— Edinburg— Mission, TX
Midland, TX
Odessa, TX
Port Arthur, TX
San Angelo, TX
Sherman— Denison, TX
Temple, TX
Texarkana, TX— Texarkana, AR
Texas City, TX
Tyler, TX
Victoria, TX
Wichita Falls, TX
Logan, UT
Ogden, UT
Provo— Orem, UT
Bristol, TN— Bristol, VA
Charlottesville, VA
Danville, VA
Fredericksburg, VA
Kingsport, TN— VA
Lynchburg, VA
Burlington, VT
Bellingham, WA
Bremerton, WA
Longview, WA— OR
Olympia, WA
Richland— Kennewick— Pasco, WA
Spokane, WA
Yakima, WA
Appleton— Neenah, WI
Beloit, WI— IL
Duluth, MN— WI
Eau Claire, WI
Total
Population
61,124
2,019
33,790
75,857
53,031
82,382
83,174
117,676
107,599
66,445
58,263
79,309
137,876
79,433
76,429
263,192
91,999
113,672
109,560
85,408
55,522
58,710
42,310
128,211
79,703
55,122
97,151
50,401
259,147
220,556
18,773
67,553
54,315
56,718
4,229
98,138
87,088
59,317
112,977
54,985
95,471
116,118
279,038
88,054
160,918
42,705
27,615
80,293
No. of
Incorporated
Places
1
1
1
1
1
3
3
1
2
1
1
5
4
7
2
9
1
1
4
1
3
2
3
9
1
1
2
7
20
10
1
1
1
1
2
1
4
1
2
2
3
4
2
3
7
1
2
3
No. of
Minor Civil
Divisions
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4
0
0
0
0
0
0
0
8
3
0
7
No. of
Counties
1
1
1
1
1
3
3
1
1
1
1
1
3
3
2
1
2
2
1
1
1
1
1
2
1
1
2
1
2
1
2
2
2
3
1
4
1
1
1
1
1
2
1
1
3
1
1
2
3-30
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-9. List of Urbanized Areas Not Associated With a Phase I Municipality
(continued)
State
WI
WV
WY
Urbanized Area
Green Bay, WI
Janesville, WI
Kenosha, WI
LaCrosse, WI— MN
Qshkosh, WI
Racine, WI
Round Lake Beach — McHenry, IL— WI
Sheboygan, WI
Wausau, WI
Charleston, WV
Cumberland, MD— WV
Huntington— Ashland, WV— KY— OH
Parkersburg, WV— OH
Steubenville— Weirton, OH— WV— PA
Wheeling, WV— OH
Casper, WY
Cheyenne, WY
Total
Population
161,931
52,995
94,292
74,203
58,935
121,788
53
61,012
57,352
164,418
3,007
79,681
51,843
29,871
59,252
52,248
61,890
No. of
Incorporated
Places
5
1
2
3
1
5
0
3
3
14
1
4
3
2
8
3
1
No. of
Minor Civil
Divisions
4
3
2
4
4
2
1
4
3
0
0
0
0
0
0
0
0
No. of
Counties
i •
i
i
i
i
i
i
i
i
3
1
2
1
2
2
1
1
1 Puerto Rico does not use the designations of "incorporated place," "minor civil division," or "county" for any of its
municipalities; therefore the table has been left intentionally blank under these headings.
Table 3-10. Urbanized Areas Without a Municipality in Phase I
of the NPDES Storm Water Program
Urbanized
Area
Population
50,000 - 74,999
75,000 - 99,999
100,000 - 124,999
125,000 - 149,999
150,000 - 249,999
Over 250,000
TOTALS
Number of
Urbanized
Areas
114
54
36
12
30
23
269
Incorp.
Places
287
156
132
48
191
656
1,470
Minor
Civil
Divisions
162
122
82
38
177
385
966
Counties
159
83
43
9
39
47
380
Total
Population
6,954,446
4,690,007
4,050,106
1,639,209
5,621,799
20,008,804
42,964,371
3-31
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-11. Urbanized Areas With a City With a Population of 100,000 or More
but Without a Phase I Municipality
Urbanized
Area
Albany— Schenectady— Troy, NY
Bridgeport— MUford, CT
Buffalo-Niagara Falls, NY
Chicago, IL — Northwestern Indiana
Erie, PA
Evansvffle, IN-KY
Hartford-Middletown, CT
Lansing— East Lansing, MI
New Haven— Meriden, CT
Peoria, IL
Pittsburgh, PA
Ponce, PR
Providence— Pawtucket, RI— MA
Rochester, NY
San Juan, PR
Santa Rosa, CA
South Bend— Mishawaka, IN— MI
Spokane, WA
Springfield, IL
Springfield, MA— CT
St. Louis, MO-IL
Syracuse, NY
Waterbury, CT
Urbanized
Area
Population
509,106
413,863
954,332
6,792,087
177,668
183,087
546,198
265,095
451,486
242,353
1,678,745
190,079
846,293
619,653
1,221,086
194,560
237,932
279,038
124,524
532,747
1,946,526
388,918
175,067
Core City
Albany
Bridgeport
Buffalo
Chicago
Erie
Evansville
Hartford
Lansing
New Haven
Peoria
Pittsburgh
Ponce
Providence
Rochester
San Juan
Santa Rosa
South Bend
Spokane
Springfield
Springfield
St. Louis
Syracuse
Waterbury
Core City
Population
101,082
141,686
328,123
2,783,726
108,718
126,272
139,739
127,321
130,474
113,504
369,879
159,151
160,728
231,636
426,832
113,313
105,511
177,196
105,227
156,983
396,685
163,860
108,961
Population
Served by
Combined
Sewer *
96,500
50,000
328,123
2,783,726
108,719
50,425
110,000
50,000
84,300
77,000
369,879
NA**
160,728
231,636
NA**
0
100,000
135,600
75,000
156,983
396,685
140,800
99,947
* Population served by combined sewers within the core city of the urbanized area.
** Information on combined sewers in Puerto Rico not available.
3-32
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Chapter 3—Municipal Separate Storm Sewer Systems
3.1.3.3 Urban Populations Outside of Urbanized Areas
The Bureau of the Census defines urban populations to consist of persons living in any
densely settled place of 2,500 or more inhabitants. Urban populations outside of urbanized
areas are comprised of distinct population centers of more than 2,500 but less than 50,000
people. The total urban population outside of urbanized areas is 29.0 million people. Of
this total, 25.1 million people live in 3,689 incorporated places. The remaining 3.9 million
people live in either minor civil divisions or unincorporated portions of counties. The urban
population outside of urbanized areas but inside a metropolitan areas as defined by OMB is
10.8 million.
3.1.3.4 Rural Populations
The census population data base classifies any population other than urban populations as
rural populations. In 1990, the rural population totalled 61.5 million people. Of this total,
8.8 million live hi 13,044 incorporated places; the remaining 52.7 million people live hi
either minor civil divisions or unincorporated portions of counties.
3.1.3.5 Populations Not Addressed in Census
The census data does not address certain classes of development, including resort towns
and second home development. The census population data base generally does not reflect
seasonal populations, such as people that only live in a resort town during peak seasons,
second home development, people staying in rental units, or tourists. For example, on some
peak weekends, more than 250,000 people may visit Ocean City, Maryland. According to
the census, however, the permanent population of Ocean City, Maryland, is only 5,146. It
has been estimated that more than two-thirds of recreational subdivisions are situated near
water, often on artificially constructed lakes (Reilly, The Use of Land, 1973).
3-33
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Chapter 3—Municipal Separate Storm Sewer Systems
3.1.4 Development Trends
New development is widely recognized as providing some of the best opportunities for
implementing cost-effective storm water management controls. This section identifies major
trends of new development.
During the twentieth century, the U.S. population has become increasingly urbanized.
The rate of growth occurring over the last four decades is exemplified by Bureau of the
Census data on urbanized areas with a population of 50,000 or more. Table 3-12 shows two
important trends that have occurred since 1950:
• The total populations in urbanized areas have been rapidly increasing.
• Most of this growth has been occurring outside larger central cities in urban fringe
areas.
Table 3-12. Growth of Urbanized Areas in the United States Between 1950 and 1990
Year
1950
1960
1970
1980
1990
Number of
Urbanized
Areas
157
213
273
366
405
Population in Urbanized Areas (millions)
Total
69.2
95.8
120.7
139.2
160.4
Central Cities
48.4
57.9
65.1
67.0
79.7
Urban Fringe
20.9
37.8
55.6
72.1
80.7
Land Area
(sq.mi.)
19,728
25,544
35,081
52,017
61,520
Source: Bureau of the Census, U.S. Dept. of Commerce
Between 1980 and 1990, the population of Census-designated urbanized areas increased
by 21.2 million8 and the cumulative size increased by 9,000 square miles. During the same
period, the rural population of the United States increased by 2.2 million, and the urban
population that lived outside of urbanized areas increased by 0.9 million.
About 7 percent of this increase (1.5 million people) is associated with the net addition of 30 new urbanized
areas between 1980 and 1990. Another part of this increase which has not been estimated here is associated with the
increase hi land area of pre-existing urbanized areas.
3-34
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Chapter 3—Municipal Separate Storm Sewer Systems
Cities with a population of 100,000 or more with municipal systems already addressed by
Phase I of the NPDES storm water program increased in population by about 4.9 million
people (or an increase of 9 percent) between 1980 and 1990.9 Between 1980 and 1990, the
population of urbanized areas with one or more municipal systems addressed by Phase I of
the NPDES storm water program increased by 16.4 million (or 67 percent of the total
national growth). This represented a 25 percent increase in the population of these areas.
The population of urbanized areas without a Phase I municipal system increased by 4.8
million. This represents 20 percent of the total national growth and an 11 percent increase hi
the population of these areas.
Population increase is only one indicator of new development. Significant development
can occur, particular in some of the larger urbanized areas experiencing migration from core
cities to suburban areas. For example, between 1970 and 1990, the total population of the
Chicago urbanized area was relatively stable, increasing by only 77,509 people. However,
during this tune significant migration was occurring from the core city to surrounding
suburban areas. The population of the city of Chicago decreased by 583,257 while the
population of suburban areas increased by 660,766. The Chicago urbanized area increased hi
land area by 307 square miles, or by 25 percent of its 1970 size.
The migration away from central business districts to the suburbs has been occurring at
high rates since the late 1970s. By the mid-1980s, approximately 57 percent of the office
space in the country was located hi the suburbs; before that tune, central business districts
within the urban core contained the majority of office space (Cooper, 1986).
Growth is concentrated in certain geographic regions of the country. For example, the
most growth in urbanized areas is occurring mainly hi the south and west. High rates of
growth are occurring hi coastal and estuarine areas. Population in these areas has increased
9 The 4.9-million increase does not include increases associated with unincorporated, urbanized portions of
Phase I counties and designated municipalities.
3-35
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Chapter 3—Municipal Separate Storm Sewer Systems
by about 30 million people during the last 3 decades (almost half the total U.S. population
increase) and is expected to increase, although at reduced levels (Culliton et al., 1990). The
Bureau of the Census projects that most growth by 2010 will occur on the Pacific, Atlantic,
and Gulf Coasts (Figure 3-5). High growth areas include California and Washington State in
the West, all of the coastal States south of New Jersey in the East, and Florida and Texas in
the Gulf Coast region.
A comparison of 1990 census data to 1980 data supports these projections (Table 3-13).
Twenty-five of 30 coastal States have seen dramatic population increases since 1980 (Bureau
of the Census, 1991). The largest increases occurred hi California (6.1 million people),
Florida (3.2 million people), and Texas (2.7 million people). While the major population
corridors extend from New York to Washington, DC, Los Angeles to San Diego, and within
the San Francisco Bay metropolitan area, estuaries in the Middle Atlantic contain the greatest
percentage of urban land and is the most densely populated among regions (NOAA, 1990).
3.2 NATURE OF DISCHARGES FROM MUNICIPAL SYSTEMS
A number of features of the urban environment affect the manner hi which discharges
from municipal separate storm sewers may affect surface water resources, including:
• Urban activities and sources that generate or contribute to pollutants
• Increased levels of imperviousness
• Modifications and destruction of natural drainage features, including removal of
riparian vegetation
• Design objectives of drainage system.
The degree of impact on a receiving water can also depend on other factors, including
the frequency and duration of the storm water discharges, the quality and quantity of storm
water discharges, the occurrence of other wet weather discharges (e.g., combined sewer
3-36
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Chapter 3—Municipal Separate Storm Sewer Systems
Source: Bureau of the Census, 1980
New Persons 1980 to 2010
(in thousands)
1014 to!3679
455 to 1014
0 to 455
.730 to 0
Figure 3-5. Population Growth Forecast Between 1980 and 2010
3-37
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-13. Total Resident Population by State: 1990 and 1980
1990 Total
Population Rank
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
State
California
New York
Texas
Florida
Pennsylvania
Illinois
Ohio
Michigan
New Jersey
North Carolina
Georgia
Virginia
Massachusetts
Indiana
Missouri
Wisconsin
Tennessee
Washington
Maryland
Minnesota
Louisiana
Alabama
Kentucky
Arizona
Puerto Rico
South Carolina
Colorado
Connecticut
Oklahoma
Oregon
Iowa
Mississippi
Kansas
Arkansas
West Virginia
Utah
Nebraska
New Mexico
Maine
Nevada
New Hampshire
Hawaii
Idaho
Rhode Island
Montana
South Dakota
Delaware
North Dakota
District of Columbia
Vermont
Alaska
Wyoming
Guam
Virgin Islands
American Samoa
North. Mariana Islands
1990 Total
Population
29,760,021
17,990,455
16,986,510
12,937,926
11,881,643
11,430,602
10,847,115
9,295,297
7,730,188
6,628,637
6,478,216
6,187,358
6,016,425
5,544-, 159
5,117,073
4,891,769
4,877,185
4,866,692
4,781,468
4,375,099
4,219,973
4,040,587
3,685,296
3,665,228
3,522,037
3,486,703
3,294,394
3,287,116
3,145,585
2,842,321
2,776,755
2,573,216
2,477,574
2,350,725
1,793,477
1,722,850
1,578,385
1,515,069
1,227,928
1,201,833
1,109,252
1,108,229
1,006,749
1,003,464
799,065
696,004
666,168
638,800
606,900
562,758
550,043
453,588
133,152
101,809
46,773
43,345
1980 Total
Population
23,667,902
17,558,072
14,229,191
9,746,324
11,863,895
11,426,518
10,797,630
9,262,078
7,364,823
5,881,766
5,463,105
5,346,818
5,737,037
5,490,224
4,916,686
4,705,767
4,591,120
4,132,156
4,216,975
4,075,970
4,205,900
3,893,888
3,660,777
2,718,215
3,196,520
3,121,820
2,889,964
3,107,576
3,025,290
2,633,105
2,913,808
2,520,638
2,363,679
2,286,435
1,949,644
1,461,037
1,569,825
1,302,894
1,124,660
800,493
920,610
964,691
943,935
947,154
786,690
690,768
594,338
652,717
638,333
511,456
401,851
469,557
* 107,000
* 98,000
* 32,000
* 17,000
Number Change
1980 to 1990
6,092,119
432,383
2,757,319
3,191,602
17,748
4,084
49,485
33,219
365,365
746,871
1,015,111
840,540
279,388
53,935
200,387
186,002
286,065
734,536
564,493
299,129
14,073
146,699
24,519
947,013
325,517
364,883
404,430
179,540
120,295
209,216
-137,053
52,578
113,895
64,290
-156,167
261,813
8,560
212,175
103,268
401,340
188,642
143,538
62,814
56,310
12,375
5,236
71,830
-13,917
-31,433
51,302
148,192
-15,969
* 26,000
* 4,000
* 15,000
* 26,000
Percent Change
1980 to 1990
25.7
2.5
19.4
32.7
0.1
0.0
0.5
0.4
5.0
12.7
18.6
15.7
4.9
1.0
4.1
4.0
6.2
17.8
13.4
7.3
0.3
3.8
0.7
34.8
10.2
11.7
14.0
5.8
4.0
7.9
-4.7
2.1
4.8
2.8
-8.0
17.9
0.5
16.3
9.2
50.1
20.5
14.9
6.7
5.9
1.6
0.8
12.1
-2.1
-4.9
10.0
36.9
-3.4
*24.2
*4.1
*47.9
* 152.9
1 Estimated 1980 census populations
3-38
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Chapter 3—Municipal Separate Storm Sewer Systems
overflow discharges), and the quantity and quality of the base flow (dry weather flow) of the
stream. Appendix B further discusses the potential impacts from storm water discharges to
different classes of receiving waters.
3.2.1 Major Pollutant Sources
Pollutants in discharges from municipal separate storm sewer systems originate from a
variety of diffuse sources. This subsection discusses both runoff-related and non-storm water
sources of pollutants.
3.2.1.1 Runoff-Related Pollutant Sources
The urban environment has many sources that can contribute pollutants to storm water.
Table 3-14 provides selected examples of the major common sources of pollutants in the
urban environment. Many of these sources, such as those related to vehicles, building
materials, and road maintenance, are ubiquitous in the urban environment. The complex
interactions of the various pollutant sources hi the urban environment have limited efforts to
quantify the contribution of pollutants from specific sources. Rather, most studies of the
quality of urban runoff have characterized pollutant concentrations hi runoff from general
land use categories (e.g., residential, commercial, open land). However, several recent
studies have begun to look at smaller segments of the urban environment that may generate
runoff with elevated levels of pollutants.10 At least one recent study has attempted to
evaluate the contribution of pollutants from different formulations of a commercial product
(brake pads) to urban runoff.11 Another recent study addressing deposition of air pollutants
to waters identified fossil fuel combustion hi industrial, commercial, and residential units;
10 For example, see Bannerman, R., et al., 1993 Sources of Pollutants in Wisconsin Stormwater, Water Science
& Technology (28): 3-5, pp. 241, which indicates that streets and roads may be the most significant source of
pollutants associated with residential, commercial and industrial land use. Pitt, R., et al. The Treatdbility of Urban
Stormwater Toxicants, International Congress on Integrated Stormwater Management, 1991, which reported that
runoff from vehicle service areas and parking lots generally had higher concentrations of polynuclear aromatic
hydrocarbons and metal than runoff from street surfaces. In addition, a higher frequency of runoff from vehicle
service areas and parking lots exhibited toxicity.
11 See Public Review Draft of Contribution of Heavy Metals to Storm Water from Automotive Disc Brake Pad
Wear, Santa Clara Valley Nonpoint Source Pollution Control Program, 1994.
3-39
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-14. Common Pollutants and Non-Industrial Pollutant Sources
Associated With Urban Runoff
Pollutant
Lead
Zinc
Copper
Cadmium
Chromium
Nickel
Manganese
Bromide
Mercury
Iron
Cyanide
PAHs
Chloride
Sulphates
Nitrogen,
Phosphorus
Source
Vehicles: exhaust, tire wear (filler
Structures and roads: paint
Vehicles: tire wear (filler material)
metal corrosion
Paved surfaces: deicing salts
Structures: paint, metal corrosion,
(Category: Components)
material), lubricating oil and grease
, oil and grease (stabilizing additive), brake pads,
wood preservatives
Vehicles: parts wear (brakes, metal plating, bearings and bushings), diesel fuel
Structures: paint, metal corrosion, wood preservative
Other: pesticides
Vehicles: tire wear (filler material)
Other: pesticides
Vehicles: parts wear (brakes, metal plating, engine parts)
Vehicles: diesel fuel, lubricating oil, parts wear (brakes, metal plating, and bushings)
Paved surfaces: asphalt
Vehicles: parts wear (engine parts)
Vehicles: exhaust
Other: coal combustion
Vehicles: fuel combustion
Structures: paint
Vehicles: body rust, engine wear
Structures: rust
Paved surfaces: deicing salts
Structures: wood preservatives
Vehicles: exhaust
Other: incomplete combustion
Paved surfaces: deicing salts
Other: combustion product
Vehicles: exhaust
Paved surfaces: road beds, deicing
salts
Vehicles: exhaust
Other: combustion product
Landscape maintenance: fertilizers
Soil erosion: land disturbance, exposed soils
Sewage: leaking sanitary systems, septic systems
Sources: EPA, 1992, 1990, 1983; Kobriger et al., 1984.
3-40
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-14. Common Pollutants and Non-Industrial Pollutant Sources
Associated With Urban Runoff (continued)
Pollutant
Sediments,
Particulates
Pesticides
Floatables
Bacteria
Oil and grease
PCBs
Benzene
Toluene
Chloroform
Oxygen
Demand
Phthalate,
bis(2-eth.)
Source (Category: Components)
Soil erosion: land disturbance, exposed soils
Streambank erosion: high flows
Vehicles: body rust, tire wear, other wear
General outdoor application
Structures: wood preservatives, paint
Litter: residential, commercial, industrial, recreation
Waste disposal: residential, commercial, industrial recreation
Vegetation: leaves, branches, trunks
Sewage: leaking sanitary systems, septic systems
Other: animal droppings
Soil erosion: exposed soils
Vehicles: drippings, leaks
Paved surfaces: asphalt
Equipment maintenance: exposed surfaces
Other: wood preservatives, wood/coal combustion
Vehicles: catalyst in synthetic tires
Other: electrical, insulation
Vehicles: fuel
Other: solvent use
Vehicles: fuel and asphalt
Other: solvent use
Vehicles: form by mixing salt, gasoline and asphalt
Vegetation: leaves
Litter: various sources
Soil erosion: land disturbance, exposed soils
Structures: plasticizer
Other: plasticizer
Sources: EPA, 1992, 1990, 1983; Kobriger et al., 1984.
municipal waste combustion and hazardous waste and sewage sludge incineration; and
various manufacturing processes, such as cement production as major local sources of
metals. The report also identified fossil fuel and biomass combustion in petroleum
refineries, motor vehicles, and industrial commercial and residential units as major local
sources of polycyclic organic matter.
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Chapter 3—Municipal Separate Storm Sewer Systems
A number of the sources provided in Table 3-14 are related to materials exposed to
precipitation. Examples of these sources include zinc from galvanized gutters and roofs and
lead from certain exterior paints. Other sources are generally released to the environment,
such as metals and polynuclear aromatic hydrocarbons (PAHs) in automobile emissions, zinc
in tire wear, and emissions from industrial sites. Pollutants from these sources can be
carried away from their original point of generation and accumulate on other impervious
surfaces where they are eventually washed off. In addition, erosion of land and streambanks
can contribute sediments and other pollutants.
Pollutant concentrations in runoff from different land uses are discussed below.
3.2.1.2 Non-Storm Water Sources
Although separate storm sewers are primarily designed to remove runoff from storm
events, materials other than storm water end up in and are ultimately discharged from
separate storm sewers. For example, in Sacramento, California, it is estimated that less than
half of the water discharged from the storm water drainage system is directly attributed to
precipitation.12 Non-storm water discharges to storm sewers come from a variety of
sources,13 including:
• Illicit connections and cross connections from industrial, commercial, and sanitary
sewage sources
• Leaking sanitary sewage systems
• Malfunctioning onsite disposal systems (septic systems)
• Improper disposal of wastes such as used oil, wastewaters, and litter
12 Urban Runoff Discharge from Sacramento, CA, Montoya, B., CA Regional Water Control Board, Central
Valley Region, 1987, Report Number 87-1SPSS.
13 A more complete description of non-storm water discharges to storm sewers is given in Investigation of
Inappropriate Pollutant Entries into Storm Drainage Systems: A User's Guide, EPA, January 1993, EPA/600/
R-92/238.
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Chapter 3—Municipal Separate Storm Sewer Systems
• spills
• Infiltration of ground water contaminated by a variety of sources, including leaking
underground storage tanks
• Wash waters, lawn irrigation, and other drainage sources.
Appendix C provides a more complete description of these sources of non-storm water.
Table 3-15 summarizes numerous studies involving problems with non-storm water
discharges. These case studies illustrate the wide range of pollutants (e.g., pathogens,
metals, nutrients, oil and grease, phenols, and solvents) that can be contributed to storm
sewers from non-storm water discharges. Removal of these non-storm water sources of
pollutants often provides opportunities for dramatically improving the quality of discharges
from separate storm sewers and is required by Section 402(p)(3)(B)(ii).
Table 3-15. Summary of Non-Storm Water Discharge Problems
Study Site
Comments
Jones Falls Watershed
Baltimore City and
County, MD
During the NURP study of the Jones Falls Watershed, 15 illicit connections
were discovered hi portions of the watershed. The illicit connections were
grouped into four types: direct discharges from residences, leakage from
cracked or broken sewer lines, decades-old overflows from the sanitary sewer,
and sanitary sewage pumping station malfunctions. Elevated levels of
pathogens, TSS, ammonia, TKN, total nitrogen, COD, and TOC were
identified.
Tulsa, Oklahoma
A physical inspection was conducted on 120,000 feet of storm sewer 48 inches
and larger serving a drainage area of approximately 12 square miles. 35
potential non-storm water discharges were observed. 23 of these were observed
and/or suspected sanitary sewer connections, 4 were potable water discharges,
and 8 were of an unknown source. In addition, 12,900 feet of sanitary sewer
were laid within the storm sewer where the storm sewer served as a conduit.
Most illicit connections were associated with development that occurred before
1970. Other documented observations were structural defects (900 feet of pipe
showed signs of structural defects), pipe cross through (176 total), and debris
buildup.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-15. Summary of Non-Storm Water Discharge Problems (continued)
Study Site
Comments
Washtenaw County, MI
Of the 1,067 businesses, homes, and other buildings inspected, 154 of the
buildings inspected (14%) had illicit connections, including connections in
restaurants, dormitories, car washes, and auto repair facilities. About 60% of
the automobile-related businesses inspected had illicit discharges. A majority of
the illicit connections discovered had been approved connections when installed.
Pollutants that were detected include heavy metals, nutrients, TSS, oil and
grease, radiator fluids, and solvents.
Fort Worth, TX
24 outfalls hi a 10-mile radius were targeted for end-of-pipe observations. The
success of the program was judged by a decline in the number of undesirable
features at the target outfalls, from an average of 44 undesirable observations
per month hi 1986 (522 total) to an average of 21 undesirable observations per
month in 1988. The Fort Worth investigation indicated problems associated
with allowing septic systems, self-management of liquid waste by industry, and
construction of municipal overflow bypasses from the sanitary sewer to the
storm drams. These problems were attributed to the inability of the POTW to
expand as rapidly as urban growth occurred. During a 30-month period,
problems detected include 133 hazardous spills, 125 incidents related to
industrial activity, 265 sanitary sewer line breaks, and 21 bypass connections of
the sanitary sewer to the storm sewer. Highlighted cases include a 20 gallon-
per-minutfe' flow from a cracked sanitary sewer from a bean processing plant to
a storm drain and an illicit connection of a sanitary sewer line from a 12-story
office building to a storm sewer. Most industrial pollution enters the storm
sewer system from illegal dumping, storm runoff, accidental spills, and direct
discharges. Metals were not detected hi dry-weather discharges but were found
in significant levels in receiving water sediment. City officials state that the
high metal concentrations hi sediment are consistent with otherwise unexplained
serious reported fish kills.
Seattle, WA
The city of Seattle has detected improper disposal and illicit connections from
industrial sites by investigating sediment hi storm sewers. One storm drain
outfall that represented a major source of lead to the Duwamish River was
traced back to a former smelter that crushed batteries to recover lead. Lead
concentrations hi the sediment were high enough to allow the city to send it to
an operating smelter to be refined. Another storm drain contained high levels
of creosote, pentachlorophenol, copper, arsenic, and PCBs, which (except for
the PCBs) were traced back to a wood treatment facility. Thirty cubic yards of
contaminated sediments removed from the storm drain contained 145 pounds of
contaminants. Sediments removed from storm drains hi another industrial area
contained very high levels of PCBs (about 1 pound of PCBs in 70 cubic yards
of sediment).
Upper Mystic Lake, NY
The NURP study for the Upper Mystic Lake Watershed project identified
contamination of storm water runoff and, subsequently, surface water
contamination of surface waters by sanitary discharges as a major problem hi
the watershed that contributed large quantities of phosphorus, certain metals,
and bacteria. Interactions at 19 manholes serving both sanitary and storm sewer
lines were identified as the major contributor of pollutants.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-15. Summary of Non-Storm Water Discharge Problems (continued)
Study Site
Comments
Bellevue, WA
The NURP report for Bellevue, WA, recorded 50 voluntary citizen reports of
illegal dumping and other non-storm water discharges during a 27-month period.
The incidents reported were varied and resulted in at least two significant fish
kills. 25 percent of the citizen reports involved improper disposal of used oil to
the storm sewer. Other reports involved spills, illicit connections of floor
drains, septic system pipes, and a car wash, as well as chemical dumping and
concrete trucks rinsing out into catchbasins or streams.
Ann Arbor, MI
Studies hi 1963, 1978, and 1979 found that discharges from the Allen Creek
storm drain contained significant quantities of fecal coliform, fecal streptococci,
solids, nitrates, and metals. Of the 160 businesses dye-tested, 61 (38%) were
found to have improper storm drain connections. Chemical pollutants, including
detergents, oil, grease, radiator wastes, and solvents, were causing water quality
problems. Monitoring of the storm drainage system during storm events
indicated a decrease in the concentration of 32 of 37 chemicals monitored after
the improper connections were removed.
Medford, OR
Fecal coliform tests at storm drain outfalls in city parks were used to detect 4
leaking sanitary sewer lines that were either located above the storm lines or
saturated the ground with effluent, which entered the nearby storm drams; an
agricultural equipment wash rack; and a house with sanitary lines plumbed to
the storm drain. In addition, in one of the oldest sections of town, a large
storm drain bored hi the early 1900s also contained the sanitary sewer line.
Under manholes, the sanitary line was only a trough. Even minor clogs or
breaks resulted in a spillover of effluent into the storm drain below.
Toronto, Ontario*
Dry weather samples of discharges were taken from 625 storm drains hi the
Humber River watershed. About 10 percent of the outfalls were considered
significant sources of nutrients, phenols, and/or metals, while 30 of the outfalls
had fecal coliform levels of greater than 10,000 per 100 ml. Investigations
identified 93 industrial and sanitary sewage illicit connections. Problems
included residential connections of sanitary sewage to the storm sewers and yard
runoff from a meat packing plant to a storm drain.
Grays Harbor, WA
Dry weather sampling of 29 outfalls of separate storm drains indicated that
discharges from 6 of the outfalls had abnormally high pollutant levels with
suspected illicit connections. The area under consideration had originally been
served by combined sewers. Earlier efforts to separate the system had been
incomplete, with some residences discharging sanitary sewage to the storm
drain.
Seward, NY
Sewage from septic systems with clogged drainfields hi clay soils flowed into
open storm sewers. The open storm sewers posed health risks to neighborhood
children and lowered property values.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-15. Summary of Non-Storm Water Discharge Problems (continued)
Study Site
Comments
Norfolk Naval Station,
VA
The Norfolk Naval Shipyard was originally built in 1767 and has had numerous
additions since. It has an extensive network of underground pipes, including
both separate storm sewers and sanitary/industrial sewers. In response to a
lawsuit, officials at the Shipyard conducted dye-testing of sanitary facilities
throughout the shipyard, which led to the identification and elimination of 25
cross-connections of sanitary and industrial waste to the separate storm sewer
system.
Sacramento, CA
The city of Sacramento is currently undertaking a project to identify pollutant
discharges and illegal connections to the storm water drainage systems. Recent
studies identified acute toxicity in storm water and determined that less than half
of the water discharged from the drainage system was not directly attributable to
precipitation. Mass loading estimates of copper, lead, and zinc discharged by
the drainage system were several times higher than the estimated pollutant loads
of these metals from the Sacramento Regional Treatment Plant secondary
effluent.
Hazardous Waste Case
Studies
These case studies determined that onsite waste disposal where pollutants were
added to runoff, eventually ending up in drainage systems, and other situations
where a generator dumped wastes directly down a drain were common. Of the
36 cases of illegal dumping investigated in a GAO report, 14 cases investigated
involved disposal of hazardous wastes directly to, or with drainage to, a storm
sewer, flood control structure, or the side of a road. An additional 10 sites
involved disposal to the ground, to landfills (other than those receiving
hazardous wastes), or to trash bins, which can ultimately result in additional
pollutants to subsequent storm water discharges. ^^
* Information from cities outside of the United States included for informational purposes only.
3.2.2 Imperviousness
The level of watershed imperviousness can be linked to impacts to streams and other
surface water resources (Schueler et al.). Urbanization and development increase the
imperviousness of land, which alters the natural vegetation and infiltration characteristics of
watersheds. These increases in imperviousness can dramatically alter natural flow patterns of
streams, wetlands, and other surface water resources. Increased levels of imperviousness
replace natural vegetation and decrease the natural infiltration characteristics of a watershed,
increasing the amount of runoff during wet weather events. Schueler estimates that hi
undeveloped watersheds, 5 to 15 percent of the annual stream flow is delivered during storm
events. As a general rule, the amount of runoff occurring during storm events is directly
proportional to the amount of watershed imperviousness. For example, runoff from storm
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Chapter 3—Municipal Separate Storm Sewer Systems
events will typically comprise half the annual stream flow in a watershed that is 50 percent
impervious (Schueler, 1987). Figure 3-6 illustrates how storm water peak flows increase as
population (and, consequently, imperviousness) increases based on data from the United
States Geological Survey (USGS) and the Bellevue Planning Department (1977). In addition
to causing increased flooding, changes in the hydrology of a stream can result in accelerated
stream bank or stream bed erosion. Such erosion can cause or contribute to a number of
generally detrimental effects on stream hydrology and morphology. For example, erosion
can widen or deepen the stream channel, eliminate pools and other structures in the stream,
and shift gravel or sand bars (Schueler, 1992).
Increased levels of imperviousness also cause less infiltration of rainfall to recharge
ground water supplies, thereby lowering the water table. One result of lowered water tables
is that baseline stream flows can be significantly decreased during dry weather. Reduced
flows between storms may significantly affect the aquatic habitat and the ability of a stream
to dilute toxic spills or other dry weather pollutants within the stream system (Bellevue
NURP project). In some cases, the installation of storm sewers in a watershed results in
previously perennial streams running dry several tunes a year (Long Island NURP project).
The level of watershed imperviousness is probably the most significant factor affecting
pollutant loadings hi runoff from many land uses, including residential and commercial areas
(NURP, EPA 1984). Increasing imperviousness increases runoff volumes, which, hi turn,
increase pollutant loads. Increased imperviousness can also increase stream temperatures,
resulting hi adverse effects on cold water habitats. Moreover, increased imperviousness can
result hi decreases in fish diversity (Schueler and Galli, 1992).w
14 For more information on the relationship of watershed imperviousness and biological quality see Jones and Clark,
1987; Klein, 1979; Limburg and Schmidt, 1990; Pedersen and Perkins, 1986; and Booth and Jackson, 1994.
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Chapter 3—Municipal Separate Storm Sewer Systems
til
o
o
2
O
I
2
O
DL
Ul
i
LU
m
BELLEVUE POPULATION
1390 1900 1910 1920 19JU
Source: Scott, Steward, and Stober
1940
YEW
I960
1980
1970
1980
1990
Figure 3-6. Population of Bellevue and Peak Annual Discharge in Kelsey Creek.
Data From USGS and Bellevue Planning Dept., 1977
3.2.3 Modification of Natural Stream Channels and Riparian Vegetation
During the process of development, the natural drainage system (e.g., streams, wetlands,
and other receiving waters) and surrounding vegetation is often modified. Streams can be
diverted through underground culverts or channelized. Wetlands can be drained or filled,
reducing the natural capacity of the drainage systems to dampen peak flows associated with
storm events. After development has occurred, the natural drainage system is often unable to
handle the higher volume of flows. The higher volume of flows can result hi high stream
bank and stream bed erosion rates or flooding. Drainage systems that have undergone these
changes often need additional engineered modifications downstream, such as channelization
or lining projects or direction of streams through underground culverts.
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Chapter 3—Municipal Separate Storm Sewer Systems
Removal of riparian vegetation, coupled with increased watershed imperviousness, can
result in significant increases in water temperatures. Such changes can reduce or eliminate
sensitive stream insects and fish species. Modification of riparian vegetation can also have
significant impacts on stream habitat value.15
3.2.4 Design Objectives of Drainage System
The manner in which a storm sewer system is installed, and its design objectives,
affect the quality and quantity of the storm water discharge, as well as the potential presence
of non-storm water discharges. The historical development of storm sewers can be
characterized hi terms of four overlapping tune periods. A description of storm water
management during these periods shows how some of the water quality problems associated
with storm sewer discharges have come about.16
1800-1850 The first storm sewers were installed primarily to reduce flooding and
ponding. Sanitary sewage connections resulted when adequate sanitary sewers
were not provided.
1850-1950 In some municipalities, combined sewers designed to carry both storm water
and sanitary sewage were installed.
1900-Present In other municipalities, separate systems were installed for sanitary and storm
sewers. Storm sewers were designed to provide for the rapid removal of
storm water runoff from a site.
1970-Present Some communities begin to address storm water as a resource to be used to
recharge ground water and to supply fresh water to surface waters. In
addition, properly managed storm water avoids problems with erosion,
flooding and adversely impacting natural drainage features such as streams,
wetlands and lakes. The multiple goals of water quality and water quantity are
addressed when managing storm water.
15 For a more detailed discussion of the relationship between streams and the hyporheic zone, the area that is
biologically and hydrologically connected to the surface water of a system, see Entering the Watershed, A New
Approach to Save America's River Ecosystem, Doppet, B. et al., 1993.
16 NURP - Ann Arbor, MI Report, 1984, and Water and the City: The Next Century, Rosen and Keating, American
Public Works Association, 1991.
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Chapter 3—Municipal Separate Storm Sewer Systems
3.2.4.1 Early Sewers (1800-1850)
The oldest urban storm sewers in the United States date back to the early 1800s.
Ponding of surface waters, coupled with poor sanitary conditions hi urban areas, led to the
installation of these early storm sewers to provide drainage. Little is known of the early
storm sewers, as they were constructed by individuals or small districts at their own expense
with little or no engineering or public supervision. Early storm sewers preceded the
development of sanitary sewers. Once these early storm sewers were hi place, they received
wastes from other sources, some from direct connections of ditches and pipes to the storm
sewers and others from materials dumped into the streets or storm sewers. Wastes which
ended up in storm sewers included house wastes (most buildings lacked indoor plumbing),
cesspool overflows, garbage, and excrement from horses and livestock. These practices
created health and aesthetic problems, as storm sewers were often oversized on a flat grade,
resulting hi accumulation of sewage hi storm sewers during dry weather. Wastes which
accumulated during dry weather were then discharged into receiving streams during rain
events. Many cities prohibited the discharge of domestic sewage to storm sewers but failed
to provide public sanitary sewers, resulting hi secret connections built without public
supervision. Other illegal connections to the storm sewer were often overlooked by
municipal officials because of the lack of proper sanitary sewers (NURP, 1984) (APWA,
1991).
3.2.4.2 Combined Sewers (1850-1950)
By the second half of the 19th century, combined sewer systems, designed to carry both
sanitary sewage and storm runoff, were being installed to limit the costs associated with
separate systems. At the tune, these systems were chosen over separate systems because of
their lower costs, even though it was known that separate systems were preferred on the
basis of sanitary conditions. By 1875, although 67 cities in the United States with
populations of greater than 100,000 had combined sewer systems, none treated waste before
discharging it to the nearest receiving water body. In many cities, streams were covered to
minimize the resulting nuisance. Pollution and health problems forced the expensive
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Chapter 3—Municipal Separate Storm Sewer Systems
installation of interceptors to collect dry weather flows from hundreds of combined sewer
outlets for conveyance or pumping to treatment plants prior to discharge.
As cities expanded, storm runoff and sewage flows increased. Combined interceptors
which had been installed prior to expansion could not handle increases in flow to the point
that even modest rain events could cause flooding of streets and basements. Combined sewer
overflows (CSOs) that discharged storm water and sewage directly to surface waters were
installed to minimize flooding problems, including sewage backing up into the basements of
commercial and residential buildings. These systems bypassed treatment and the general
sanitary quality of receiving waters again deteriorated (NURP, 1984) (APWA, 1991).
3.2.4.3 Separate Sewers for Water Removal (1900-Present)
The first large scale sewer system to provide separate collection of storm runoff and
sanitary sewage was built in 1880 in Memphis, TN, although the construction of combined
systems was continued and extended hi most major cities. As early as 1900, many State
regulatory agencies would not permit further construction of combined sewers. Where water
quality impacts from CSOs were extreme, some cities implemented programs to separate
portions of the older combined system.
Problems arose with separate storm water and sewage systems. As city populations
increased, the demand for sewer service increased. However, sewer mams, interceptors,
pumping stations and treatment plants were slow to grow. The post-World War II boom for
sewer service into fast growing suburban areas was often associated with high infiltration
rates and many illegal rain water connections which overloaded the system during ram
events. To limit raw sewage backups in basements, hundreds of connections were made to
bleed sewage from the sanitary sewers to the storm drains to limit flows hi the sanitary
sewers. Improper connections of grey waters such as automobile repair shop floor drams
were either encouraged or implicitly allowed to discharge to storm drams.
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Chapter 3—Municipal Separate Storm Sewer Systems
Other problems arise with separate storm sewers, as storm water management often
focuses on the rapid removal of storm water runoff from a site. The assumption is that
problems will disappear after storm water leaves the site. Under this approach, which
usually involves concrete channels and underground piping networks, storm drains are
constructed without regard for the control and slow release of storm water or for possible
downstream effects. This approach to storm water management has been characterized by
simplistic goals, rigid design standards (such as requiring piping for drainage instead of
relying on natural drainage features), low engineering review costs, and high construction
and maintenance costs. In some cases, flood problems are only shifted to downstream sites
(NURP, 1984) (APWA, 1991).
3.2.4.4 Storm Water Management for Water Quantity and Water Quality Purposes
(1970-Present)
A few communities have developed programs where storm water is managed for multiple
purposes including controlling water quantity (to avoid flooding and stream scour and to
maintain stream flows during dry weather by recharging ground water during storms) and
improving water quality. A range of alternative storm water control measures and facilities
can be implemented to serve multiple purposes effectively. The natural cycles and processes
which occur prior to the development of the land are used as a guide for managing storm
water after development has occurred. Natural flow patterns and rates of discharge are
retained through special storm water control facilities and measures. Natural processes are
incorporated into the design of many "soft" engineered systems, including vegetated buffers,
greenways, revegetation of storm water systems, wetland creation or retention for storm
water management, and onsite retention, detention or infiltration systems. Policies emerging
from these programs include:
• Reducing peak flows and improving storm water quality by onsite retention
• Reducing the volume of storm water leaving the site by natural infiltration
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Chapter 3—Municipal Separate Storm Sewer Systems
« Releasing storm water from onsite facilities at a rate similar to the pre-development
runoff rate
• Managing for smaller storm events as well as those larger storm events that can cause
major floods
• Protecting wetlands and floodplains as natural storm water storage areas
• Making storm water facilities amenities of the development (such as retaining natural
drainage channels or providing attractive landscaping for storm water management
ponds) and encouraging open space and recreational uses
• Developing programs that relate erosion and sediment controls during construction
with storm water management after construction is completed.
The implementation of this approach typically involves somewhat higher costs for
development plan review by local governments, but lower costs for storm water facility
construction, and results in reduced social costs (NURP, 1984) (APWA, 1991).
3.3 THE EXTENT OF DISCHARGES FROM MUNICIPAL SYSTEMS
3.3.1 Pollutant Concentrations of Runoff From Residential and Commercial Areas
Many studies have examined the nature of pollutants hi municipal storm water discharges
on a local level, but few have attempted to do so on a national level. The two most
extensive assessments of pollutants in urban runoff are the Nationwide Urban Runoff
Program (NURP) and information compiled in the USGS data base. These two data bases
primarily reflect pollutant concentrations associated with runoff from residential and
commercial areas.
From 1978 to 1983, EPA provided funding and guidance to NURP to provide a better
understanding of the nature of urban runoff from residential and commercial areas. NURP
included 28 projects that were conducted separately at the local level but were centrally
reviewed, coordinated, and guided by EPA. Project locations across the country were
selected by EPA to provide a range of types of receiving waters and beneficial uses,
hydrologic characteristics, and urban characteristics.
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Chapter 3—Municipal Separate Storm Sewer Systems
The major focus of NURP was to characterize the water quality of runoff from
residential, commercial, and industrial park sites. The NURP program evaluated data from
81 sites in 22 cities covering more than 2,300 separate storm events. Of the 81 sites
selected, 39 were completely or primarily residential, 10 were commercial, 20 were mixed
commercial and residential, 4 were industrial parks, and 8 were open spaces in urban areas.
Because the industrial park category did not represent heavy industrial activity, the data from
industrial parks were merged with commercial land use data. Each project was separate and
distinct but shared common field monitoring protocols.
The NURP study provides insight on what can be considered background levels of
pollutants for runoff from residential and commercial land uses. Sites evaluated in NURP
were carefully selected so that they were not influenced by pollutant contributions from
construction sites, industrial activities, or illicit connections. Several sites were eliminated
from the study because of elevated pollutant loads associated with these or other sources.
NURP showed that the concentrations of pollutants in runoff from residential and
commercial areas vary considerably from site to site. NURP postulated that the best general
characterization of runoff from commercial and residential areas for planning purposes,
where local information is lacking, can be obtained by pooling data from many sites.
The majority of samples collected under NURP were analyzed for seven conventional
pollutants (biochemical oxygen demand, chemical oxygen demand, total suspended solids,
total Kjeldahl nitrogen, nitrate plus nitrite, total phosphorus, and soluble phosphorus) and
three metals (total lead, total copper, total zinc). Table 3-16 presents average discharge
concentrations for these pollutants hi runoff from the residential and commercial sites studied
in NURP.17
17 Recently, concerns have been raised regarding the validity and use of historical data for metals. As discussed
in Chapter 2, EPA believes that historical data on storm water runoff from NURP and USGS are suitable for the
purposes of this report.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-16. Summary of Event Mean Concentrations From NURP
for Selected Pollutants
Constituent
TSS (mg/1)
BOD (mg/1)
COD (mg/1)
Total P (mg/1)
soluble P (mg/1)
TKN (mg/1)
Nitrate plus nitrite (mg/1)
Total Cu (mg/1)
Total Pb (mg/1)
Total Zinc (mg/1)
Mean
239
12
94
0.50
0.15
2.3
0.86
0.05
0.24
0.35
Median Site
100
9
65
0.33
0.12
1.5
0.68
0.03
0.14
0.16
90th Percentile
Site
300
15
140
0.70
0.21
3.3
1.75
0.09
0.04
0.50
Coefficient of
Variability for
Events
1-2
0.5-1
0.5-1
0.5-1
0.5-1
0.5-1
0.5-1
0.5-1
0.5-1
0.5-1
In addition, the Section 307(a) priority pollutants were measured at 20 of the sites. Of
the 119 pollutants analyzed, 77 were detected. All 13 metals on the priority pollutant list
were detected, and all but 3 of the metals were detected at frequencies greater than 10
percent of the samples. Copper, lead, and zinc, found in at least 91 percent of the samples,
were the most frequently detected metals. Of the 106 organic pollutants measured, 63 were
detected. A plasticizer (bis (2-ethylhexyl) phthalate) and a pesticide (alpha-
hexachlorocyclohexane (alpha-BHC)) were found in at least 20 percent of the samples
analyzed. An additional 11 organic pollutants were reported at frequencies between 10 and
20 percent, including 4 pesticides, 3 phenols, 4 polycyclic aromatics, and a single
halogenated aliphatic compound. NURP data also showed that during warm weather
conditions, fecal coliform counts hi urban runoff are typically in the tens to hundreds of
thousands per 100 milliliters of runoff. Table 3-17 lists pollutants that were detected hi 10
percent or more of the NURP samples.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-17. Priority Pollutants Detected in at Least 10 Percent of the NURP Samples
Pollutant
Metals and inorganics
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanides
Lead
Nickel
Selenium
Zinc
Pesticides
Alpha-hexachlorocyclohexane
Alpha-endosulfan
Chlordane
Lindane
Halogenated aliphatics
Methane, dichloro-
Phenols and cresols
Phenol
Phenol, pentacholoro-
Phenol, 4-nitro
Phthalate esters
Phthalate, bis(2-ethylhexyl)
Polycyclic aromatic hydrocarbons
Chrysene
Fluoranthene
Phenanthrene
Pyrene
Detection Frequency (%)
13
52
12
48
58
91
23
94
43
11
94
20
19
17
15
11
14
19
10
22
10
16
12
15
Source: EPA, 1983
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Chapter 3—Municipal Separate Storm Sewer Systems
The USGS has also collected urban rainfall, runoff, and water quality data nationally for
several decades. In the mid-1980s, a data base containing information on 717 storms at 99
stations in 22 metropolitan areas throughout the United States (Driver et al., 1985) was
compiled. The USGS examined a set of constituents similar to those compiled for NURP;
the USGS also reported its data in terms of flow-weighted samples so that concentrations and
loading values could be compared directly to NURP results. As described in Section 2.1.2.1
of this report, EPA compared information from the USGS data base to the findings from
NURP.
In general, the findings between the two studies were very similar. Both data bases
identified sediments and metals as the most significant pollutants measured. This
determination is consistent with the findings of Driver and Lystrom (1986), who also
compared the two data sets.
Two major trends related to automobiles that have occurred since the bulk of NURP data
were collected are expected to affect urban runoff quality. The first trend involves the
dramatic reductions in the levels of lead in gasoline. NURP data were generally collected
during the tune period when leaded gasoline was being phased out, and current
concentrations of lead in runoff are expected to be generally lower than indicated by the
NURP data.18 Storm water monitoring data collected since that time tend to show a
significant decrease in lead, but much less of a reduction then the percentage reductions of
18 Tetraethyl lead has been extensively used as an inexpensive anti-knock, octane boosting gasoline additive since
1923. Aside from the Surgeon General temporarily suspending the production and sale of lead in gasoline in 1925,
the use of lead in gasoline was largely unregulated until 1978. Decreases since that time are the result of two
regulatory programs under the Clean Air Act (CAA): regulation of the amount of lead in leaded gasoline; and
automobile emission standards resulting in new technology, catalytic converters, requiring the use of unleaded
gasoline. Beginning in 1975, many automobile manufacturers began installing catalytic converters, which were
poisoned by lead in gasoline, to meet emission standards. In 1978, EPA began to lower the level of lead in leaded
gasoline under sections 211(c)(l) and (2) of the CAA to protect the public health and welfare and to safeguard the
performance of emission control devices in general use. Most recently, EPA lowered the low-lead standard to 0.10
gplg, effective January 1, 1986, (March 7, 1985 (50 FR 9386)).
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Chapter 3—Municipal Separate Storm Sewer Systems
lead in gasoline. Other remaining sources of lead include industrial sources, paint,
background levels hi soil, and soil contaminated after 65 years of using lead in gasoline.19
The second trend pertains to the prohibition of the use of asbestos hi brake pads and
clutch linings. This is expected to result hi a decrease hi asbestos hi runoff, which was not
monitored hi NURP, and an increase hi copper and zinc, which are a substitute for asbestos
hi some brake pads.
3.3.1.1 Comparison of Pollutant Concentrations in Runoff from Residential/Commercial
Areas to Discharges From Publicly Owned Treatment Works
The concentration of pollutants hi runoff from residential and commercial areas (based on
NURP and USGS data bases) can be compared to the typical concentration of pollutants
found hi the discharges from publicly owned treatment works (POTWs) that provide
secondary treatment?0 (see Table 3-18). The concentration of total suspended solids (TSS)
hi runoff from residential and commercial areas is about an order of magnitude greater than
the concentrations from POTWs receiving secondary treatment. The concentrations of COD,
total lead, and total copper were somewhat higher hi runoff from residential and commercial
areas. The concentration of phosphorus and nitrogen were about an order of magnitude
greater hi discharges from POTWs.
19 This is consistent with the finding of Deposition of Air Pollutants to the Great Waters, 1994 Report to
Congress, EPA, 1994, which indicates that the environment may act as an important reservoir or source of persistent
contaminants that have been released previously.
20 EPA estimates that 76 million people, or 42 percent of the population served by sanitary sewage treatment
works, are served by systems that either provide greater than secondary treatment or have no discharge. 7992 Needs
Survey Report to Congress, EPA, 1993.
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-18. Comparison of Mean Pollutant Concentrations in Runoff From Residential
and Commercial Areas to Sewage Treatment Plant Receiving Secondary Treatment
Constituent
TSS (mg/1)
BOD (mg/1)
COD (mg/1)
Total P (mg/1)
Soluble P (mg/1)
TKN (mg/1)
Nitrate plus nitrite (mg/1)
Total Cu (mg/1)
Total Pb (mg/1)
Total Zn (mg/1)
Runoff from Residential and
Commercial Sites (NURP)
239
12
94
0.5
0.15
2.3
0.86
0.05
0.24
0.35
Sewage Plant With Secondary
Treatment
20
20
33
6
5
20
NA
0.05
0.03
0.14
Source: POTW discharge concentrations for lead, zinc, copper, BOD, COD, TSS, and oil and grease were
based on data reported in Fate of Priority Pollutants in Publicly Owned Treatment Works (EPA, 1981). This
report summarizes monitoring data from POTWs receiving secondary treatment hi 50 cities. Pollutant
concentrations for total phosphorus, soluble phosphorus, and total Kjeldahl nitrogen were based on personal
communication with Dolloff Bishop or the EPA Wastewater Engineering Laboratory in Cincinnati, Ohio.
Recently, concerns have been raised regarding the validity and use of historical data for metals. As discussed
in Chapter 2, EPA believes that historical data on storm water runoff from NURP and USGS are suitable for
the purposes of this report.
3.3.1.2 Comparison of Pollutant Concentrations in Runoff from Residential/Commercial
Areas to Water Quality Criteria
NURP determined that toxic metals were the most prevalent priority pollutants in runoff
from commercial and residential areas. All 14 inorganic priority pollutants (13 metals, plus
cyanides, excluding asbestos) were detected in urban storm water. As shown in Table 3-19,
a number of these constituents were detected at levels exceeding EPA water quality criteria.
The table also identifies organic pollutants found that exceeded certain EPA water quality
criteria. These exceedances were observed less frequently than exceedances for the
inorganic constituents. Levels of coliform bacteria were also found to exceed EPA water
quality criteria during and immediately after storm events in many surface waters (EPA,
1983).
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Chapter 3—Municipal Separate Storm Sewer Systems
Table 3-19. Summary of Water Quality Criteria Exceedances for Pollutants
Detected in at Least 10 Percent of NURP Samples—Percentage of Samples
in Which Pollutant Concentrations Exceed Criteria1
Pollutant
I. Pesticides
a-Hexachlorocyclohexane
•y-Hexachlorocyclohexane
(Lindane)
Chlordane
a-Endosulfan
II. Metals and Inorganics5
Antimony
Arsenic
Beryllium
Cadmium6
Chromium6'7
Copper6
Cyanides
Lead5
Nickel6
Selenium
Zinc6
IV. Halogenated Aliphatics
Methane, dichloro-
VII. Phenols and Cresols
Phenol
Phenol, pentachloro
Phenol, 4-nitro-
Vni. Phthalate Esters
Phthalate, bis(2-ethylhexyl)
DC. Polycyclic Aromatic
Hydrocarbons
Chrysene
Fluoranthene
Phenanthrene
Pyrene
Frequency of
Detection(*)
20
15
17
19
13
52
12
48
58
91
23
94
43
11
94
11
14
19
10
22
10
16
12
15
Detection
Samples2
21/106
15/100
7/42
9/49
14/106
45/87
11/94
44/91
47/81
79/87
16/71
75/80
39/91
10/88
88/94
3/28
13/91
21/111
11/107
15/69
11/109
17/109
13/110
16/110
Criteria Exceedances
None
X
X
X
X
FA
2
8
47
3
23
14
1*
FC
8
17
10
6*
48
1*
82
22
94
5
5
77
11*
22*
OL
1
HH
1
4
73
21
10
HC4
8,18,20
0,10,15
17,17,17
52,52,52
12,12,12
0,0,11
10,10,10
12,12,12
15,15,15
DW
1
1
1
73
10
indicates FTA or FTC value substituted where FA or FC criterion not available (see below).
1 Based on 121 sample results received as of September 30, 1983, adjusted for quality control review. Where a value is reported for
criteria exceedances, this value is a percentage of the number of samples where the pollutant was detected and blanks indicate no
exccedances by any of the samples for which the pollutant was detected.
1 Number of times detected/number of acceptable samples.
5 FA •« Freshwater ambient 24-hour instantaneous maximum criterion ("acute" criterion).
FC « Freshwater ambient 24-hour average criterion ("chronic" criterion).
FTA = Lowest reported freshwater acute toxic concentration. (Used only when FA is not available.)
FTC s Lowest reported freshwater chronic toxic concentration. (Used only when FC is not available.)
OL = Taste and odor (organoleptic) criterion.
HH ** Non-carcinogenic human health criterion for ingestion of contaminated water and organisms.
HC = Protection of human health from carcinogenic effects for ingestion of contaminated water and organisms.
DW « Primary drinking water criterion.
4 Entries in this column indicate exceedances of the human carcinogen value at the 10~5, 10"6, and 10"7 risk level, respectively. The
numbers are cumulative (i.e., all 10'3 exceedances are included in 10"6 exceedances, and all 10'6 exceedances are included in 10~7
exceedances).
5 Concerns have been raised regarding the validity and use of historical data for metals. As discussed in Chapter 2, EPA believes that
historical data on storm water runoff from NURP and USGS are suitable for the purposes of this report.
6 Where hardness dependent, hardness of 100 mg/1 CaCO3 equivalent assumed.
7 Different criteria are written for the trivalent and hexavalent forms of chromium. For purposes of this analysis, all chromium is
assumed to be in the less toxic trivalent form.
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Chapter 3—Municipal Separate Storm Sewer Systems
3.3.2 Pollutant Concentrations from Other Urban Land Uses
The NUKP data base is limited to runoff from residential, commercial and industrial
park land uses. These land uses typically comprise between 55 to 85 percent of the area of
urban areas (EPA, 1990). Other major urban land uses which have the potential to
contribute runoff with higher levels of pollutants include central business districts, industrial
areas (typically 10 to 20 percent of the area of urban areas), and construction activities.
3.3.2.1 Central Business Districts
NURP noted that data describing runoff from central business districts are limited.
However, NURP suggested that some central business districts may produce pollutant
concentrations in runoff that are significantly higher than those from other sites hi a given
urban area. Pollutant loads from central business districts are thought to be significant
because of the high pollutant concentrations coupled with the high degrees of imperviousness.
3.3.2.2 Industrial Land Uses
No truly industrial sites were included in any of the NURP projects. However,
NURP suggested that runoff from industrial sites may have significantly higher contaminant
levels than runoff from other urban land use sites. Several studies tend to support this
suggestions, such as the Fresno, CA, NURP project which showed that industrial areas had
the poorest storm water runoff quality of the four land-uses evaluated. Of the 62 non-
pesticide constituents monitored, 52 were statistically highest in industrial site runoff. A
study conducted hi Spokane, WA, showed that industrial and commercial sites clearly
contributed greater quantities of total dissolved solids, COD, total Kjeldahl nitrogen, lead and
zinc (Oregon, 1986—Spokane Water Quality Management Program).
Given the range of different industrial activities hi different urban areas, it would be
difficult to characterize industrial runoff on a national basis. However, recent data collection
efforts describing runoff from different types of industrial activities can be used to evaluate
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Chapter 3—Municipal Separate Storm Sewer Systems
the potential for pollutants in runoff from specific industrial areas. Chapter 4 summarizes
some of these efforts.
3.3.2.3 Construction Activities
The amount of sediment in storm water discharges from construction sites can vary
considerably, depending on whether effective management practices are implemented at the
construction site. Uncontrolled or inadequately controlled construction site sediment loads
have been reported to be on the order of 35 to 45 tons/acre/year (Novotny and Chesters,
1981). Sediment runoff rates from construction sites are typically 10 to 20 times that of
agricultural lands, with runoff rates as high as 100 times that of agricultural lands; the rates
are typically 1,000 to 2,000 times those of forest lands. Over a short period of tune,
construction sites can contribute more sediment to streams than was previously deposited
over several decades.21
3.3.3 Pollutant Loading Estimates
EPA has developed loading estimates for selected pollutants in discharges from municipal
separate storm sewer systems associated with urbanized areas.22 Chapter 2 describes the
methods used for estimating pollutant loads.
Table 3-20 summarizes pollutant load estimates for different classes of municipalities
currently addressed by Phase I of the NPDES storm water program and potentially addressed
under Phase n. EPA estimates that in 1990, about 40 percent of the pollutant loads
associated with runoff from urbanized areas came from Phase I municipalities. About one-
quarter of the pollutant loads in runoff from urbanized areas came from potential Phase II
21 Under current regulations, construction activities resulting in the disturbance of 5 or more acres are covered by
the NPDES storm water program.
22 The model used to estimate pollutant loads assumed constant concentrations for each of the seven pollutants.
This assumption results hi the ratio of loadings of different pollutants remaining constant for different classes of
municipalities. Thus, where the percentage of pollutant loadings is presented, the percentage is the same for all
seven pollutants.
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Chapter 3—Municipal Separate Storm Sewer Systems
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3-63
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Chapter 3—Municipal Separate Storm Sewer Systems
portions of urbanized areas with a Phase I municipality. An additional one-third of the
pollutant loadings associated with urbanized areas came from urbanized areas that do not
have a Phase I municipality.
Table 3-21 compares annual pollutant loadings for three metals, zinc, lead, and copper,
from urban runoff from the Metropolitan Washington urbanized area, with a sewage
treatment plant that provides advanced treatment and that serves about 2 million people (the
Blue Plains sewage treatment plant), and major industrial process wastewater discharges
located in Maryland and Virginia. In general, the data hi Table 3-21 indicates that the
annual loadings of metals, nutrients, and oxygen demanding pollutants hi urban runoff from
the Washington, DC, area are higher than the loadings from the predominant sewage
treatment plant for the area (the Blue Plains Sewage Treatment Plant provides advanced
treatment and serves approximately two million people). The data also indicate that the
annual loadings of zinc and lead hi urban runoff from the Washington, DC, area are higher
than the loadings from all industrial point source discharges from facilities hi Maryland and
Virginia that reported pollutant release information hi 1987 to the Toxic Release Inventory
established under the Emergency Planning and Community Right-to-Know Act.
Table 3-21. Annual Pollutant Loadings in Pounds for Selected Pollutant Sources
Pollutant
Zinc
Lead
Copper
Nitrogen
Phosphorus
BODS
Urban Storm Water from
Metropolitan Washington
480,000
132,600
113,000
30,000,000
1,200,000
9,500,000
Blue Plains Sewage
Treatment Plant1
137,000
5,500
21,000
12,000,000
113,000
1,400,000
All MD and VA Direct
Industrial Discharges in 1987
Toxic Release Inventory
132,000
31,300
127,000
not available
not available
not available
1 Portions of collection system for Blue Plains are combined sewers carrying both runoff and sewage. The
POTW loadings do not account for discharges from combined sewer overflows. The loadings estimate does
account for urban storm water that is conveyed to Blue Plains, treated, and discharged. Recently, concerns
have been raised regarding the validity and use of historical data for metals. As discussed in Chapter 2, EPA
believes that historical data on storm water runoff are suitable for the purposes of this report.
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Chapter 3—Municipal Separate Storm Sewer Systems
A number of factors are expected to result in future changes to total loadings and the
distribution of loadings between Phase I and Phase II municipalities. Factors that would
generally increase loadings include increases in population and the area of urbanized areas.
If recent development trends continue, most increases hi loadings are expected to occur hi
urbanized areas with a Phase I municipality. The majority of the increase hi loadings hi
these areas is expected to occur in suburban areas surrounding core cities.
The increased implementation of storm water management measures is expected to
generally decrease pollutant loadings. Given the existing Federal mandate for storm water
controls, such decreases are expected to occur hi Phase I municipalities sooner than hi
potential Phase II municipalities.
Widespread product substitutions associated with activities that generate pollutants
ultimately discharged hi storm water may either increase or decrease pollutant loads,
depending on the nature of such substitutions.
When analyzing annual loadings associated with urban runoff, it is important to
recognize that discharges of urban runoff are highly intermittent and that the short-term
loadings associated with individual events will be high and may have shockloading effects on
receiving water.
3.3.4 Floatables/Litter/Plastics
Litter is common hi urbanized areas. During storm events, litter can be washed into
separate storm sewers or carried through other storm water conveyances to receiving waters.
Litter is also commonly disposed of directly to storm sewer catchbasins. Discharges from
separate storm sewers were identified as major sources of plastics to the surface waters hi
Methods to Manage and Control Plastics Wastes—Report to Congress, (EPA, 1989).
Another study concluded that the majority of floating litter that washes up on New Jersey's
beaches originates from discharges from separate storm sewers (New Jersey DEP, 1988).
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Chapter 3—Municipal Separate Storm Sewer Systems
Litter can cause significant aesthetics problems and impact the operating effectiveness of
drainage systems and related management practices such as detention ponds.
3.3.5 Population Densities and Imperviousness
As discussed previously, the amount of imperviousness in urban watersheds can be
linked to impacts to streams and other surface water resources. The population density of a
municipality can be used as an indicator of the level of imperviousness. Figure 3-7
summarizes several studies that attempted to link population densities to percent
imperviousness (Kobriger, 1984). However, using population density as an indicator of
imperviousness does not account for high levels of day-time use associated with many
commercial or industrial areas with high levels of imperviousness.
Population density is related to the total urban population hi an area. Table 3-1,
presented previously, indicates that as the total population of an urbanized area increases, so
does the average population density. The average population density of urbanized areas with
a total population of 1,000,000 or more (3,413 persons per square mile) is more than double
the average population density of urbanized areas with a population of 50,000 to 100,000
(about 1,600 persons per square mile).
The population density varies within urbanized areas. Core cities generally have a
higher population density than outlying suburban areas. However, other smaller cities that
are part of larger urbanized areas can have high population densities. In 1990, the Bureau of
the Census reported more than 600 incorporated places with populations under 100,000 but
with a population density of at least 5,000 persons per square mile. Approximately 550 of
the more than 600 incorporated places meeting this criterion were hi an urbanized area.
Approximately 415 of these incorporated places are hi an urbanized area where at least one
Phase I municipality is located.
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Chapter 3—Municipal Separate Storm Sewer Systems
100
persons/htttort
0 10203040906070
IMPCKVIOUSNUS Cut TO STNCCTS OMLT
OS IO 19 20 29 30
DEVELOPED POPULATION DENSITY, PDd,p«fS
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Chapter 3—Municipal Separate Storm Sewer Systems
3.4 SUMMARY
Bureau of the Census estimates that the population of the United States and associated
territories was more than 252.2 million in 199023 and that there are 19,289 incorporated
places and 17,796 minor civil divisions in the continental United States, Alaska and Hawaii.
These incorporated places and minor civil divisions are located in 3,141 counties or county
equivalents.
The concept of Bureau of the Census-designated urbanized areas served as an important
tool for analyzing potential approaches to a Phase II program that addresses municipal
separate storm sewer systems. More than 160 million people (63 percent of the total United
States population) reside in the 405 urbanized areas with a population of 50,000 or more that
have been designated by the Bureau of the Census. These areas occupy less than 2 percent
of the Nation's total land area. These areas represent the largest, most widespread areas of
dense urban development in the country.
The majority of new urban development also occurs in Census-designated urbanized
areas. Construction activity related to new development is recognized as a significant source
of pollution and impairment of waterbodies, providing some of the best opportunities for
implementing storm water management controls in a highly cost-effective fashion. Between
1980 and 1990, the population of Census-designated urbanized areas increased by 21.2
million.24 During the same time period, the rural population of the United States increased
by 2.2 million, and the urban population that lived outside of urbanized areas increased by
0.9 million. Between 1980 and 1990, the population of urbanized areas with one or more
municipal systems addressed by Phase I of the NPDES storm water program increased by
16.4 million (or 75 percent of the total National growth). This represents a 25 percent
23 Population estimates based on the 50 States, the District of Columbia, Guam, the Commonwealth of Puerto
Rico, the Virgin Islands, American Samoa, and the Commonwealth of the Northern Mariana Islands.
24 About 7 percent of this increase, (1.5 million people) are associated with the net addition of 30 new urbanized
areas between 1980 and 1990. Another part of this increase which has not been estimated here is associated with the
increase in land area of pre-existing urbanized areas.
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Chapter 3—Municipal Separate Storm Sewer Systems
increase in the population of these areas. The population of urbanized areas without a Phase
I municipal system increased by 2.6 million. This represents 12 percent of the total national
growth and a 7 percent increase in the population of these areas.
The population and number of municipalities hi urbanized areas, and estimated
percentage of pollutant loads in runoff from urbanized areas are summarized in Table 3-20
and discussed below.
Phase I of the NPDES program for storm water discharges addresses 621 incorporated
places (cities) and portions of 77 counties.25 These municipalities had a combined
population of 86 million people in 1990. Cities with a population of 100,000 or more whose
municipal systems are already addressed by Phase I of the NPDES storm water program
increased in population by about 4.9 million between 1980 and 1990.26 The majority of the
population of Phase I municipalities, 81.7 million people live in 136 of the 405 Census-
designated urbanized ares. EPA estimates that about 40 percent of the pollutant loads hi
storm water discharged from urbanized areas come from Phase I municipalities.
The Phase II portions of the 136 urbanized areas with one or more Phase I municipal
separate storm sewer system had a combined population of 35.8 million people. The
population of those portions of these urbanized areas increased by 2.6 million between 1980
and 1990. EPA estimates that 1,587 incorporated places, 634 minor civil divisions, and
parts of 305 counties are located hi the Phase II portions of these urbanized areas. EPA
estimates that 28 percent of the pollutant loads hi storm water discharged from urbanized
areas come from Phase II portions of the 136 urbanized areas with a Phase I municipality.
25 Of these municipalities, 140 cities and 45 counties are specifically identified in the NPDES regulations that were
published hi November of 1990. EPA and authorized NPDES States have designated an additional 481 cities and 32
counties as Phase I municipalities. In addition, approximately 30 municipalities (located in 21 urbanized areas) have
received combined sewer exclusions where the total population served by separate storm sewers is less than 100,000 after
subtracting the population served by combined sewers. The methodology used to classify municipalities as Phase I vs.
Phase II for the purposes of this report is explained in Chapter 2.
26 The 4.9 million increase does not include increases associated with unincorporated, urbanized portions of Phase
I counties and designated municipalities.
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Chapter 3—Municipal Separate Storm Sewer Systems
A total of 269 of the Census-designated urbanized areas do not have a municipality with
separate storm sewers subject to Phase I of the storm water program. The 269 urbanized
areas without a Phase I municipal separate storm system have a combined population of 42.9
million people. EPA estimates that 1,470 incorporated places, 966 minor civil divisions, and
parts of 380 counties are located in these urbanized areas. EPA estimates that about one-
third of the pollutant loads in storm water discharged from urbanized areas come from the
269 urbanized areas without a Phase I municipality. Of the 269 urbanized areas without a
Phase I municipal system, 101, or over a third, have a population of more than 100,000, and
23 have a population of more than 250,000.
In addition to populations within urbanized areas discussed above, the Bureau of the
Census has identified an additional urban population of 29 million people that live outside of
urbanized areas, as well as 62.8 million people classified as rural. Of this total, 25.1 million
people live in 3,689 incorporated places. The remaining 4 million people live in either
minor civil divisions or unincorporated portion of counties. Although discharges from
municipal separate storm sewer systems serving these populations are potential Phase II
sources, they are not addressed in this report.
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Chapter 4—Individual Phase II Discharges
CHAPTER 4. INDIVIDUAL PHASE H DISCHARGES
This chapter identifies the discharges of storm water other than those from municipal
separate storm sewer systems for which permits are not currently required and assesses, to
the extent practicable, the nature and extent of pollutants in those discharges. To provide a
context for this analysis, this chapter begins with an overview of the industrial categories that
are addressed under Phase I of the storm water regulatory program. Using an approach
described hi Chapter 2 of this report, other categories of industrial, commercial, and retail
facilities that may be sources of polluted storm water discharges are identified. For these
potential Phase II sources, the type of their discharges and statistics on their geographic
distribution are described. The nature of industrial storm water discharges is characterized
using a summary of the sampling data reported by Phase I group permit applicants and
comparing groups of Phase II sources to these Phase I industries. In an analysis patterned
after that hi Chapter 3, this chapter also explores the relationship between individual Phase II
industrial, commercial, and retail facilities and urbanized areas of different configurations.
The final section of this chapter summarizes the results of the analyses and offers some
perspectives on individual Phase II storm water discharges. The results of these analyses are
meant to be guideposts and are not intended to be an identification of specific industrial
categories that must be regulated under Phase II.
4.1 OVERVIEW OF INDIVIDUAL PHASE H SOURCES
There are more than 7.7 million industrial, commercial, retail, and government facilities
in the United States.1 The Office of Management and Budget classifies businesses into
categories based on similarity of economic activity. Some aspects of this discussion are
1 This estimate is based on data from the FACTS data base, which is leased by EPA from Dun & Bradstreet
Information Services, which created, maintains, and annually updates information based on a variety of sources.
This estimate does not include inactive and abandoned mines which may constitute hundreds of thousands of
additional sources.
4-1
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Chapter 4—Individual Phase n Discharges
based on this Standard Industrial Classification (SIC) code system.2 Table 4-1 presents a
breakdown of the major categories of industry and commerce. The current storm water
regulatory program potentially applies to some types of individual facilities within the
niining, construction, manufacturing, and transportation divisions. There are more than
850,000 enterprises hi these divisions; however, only a portion of these are within the 11
categories of activities "associated with industrial activity" as defined by the November 1990
storm water permit application regulations.3 As a result, from these 850,000 enterprises,
EPA has estimated that approximately 150,000 facilities are currently subject to Phase I
requirements.
Table 4-1. Summary of Major SIC Divisions of U.S. Commerce
Description
Agriculture, Forestry, and Fishing
Mining
Construction
Manufacturing
Transportation and Public Utilities
Wholesale Trade
Retail Trade
Finance, Insurance, and Real Estate
Services
Public Administration
Total
Total
Facilities
310,086
39,936
805,100
511,831
306,894
582,681
1,850,121
672,693
2,585,750
71,379
7,736,471
SIC Codes
Covered
01-09
10- 14
15- 17
20-39
40-49
50-51
52-59
60-67
70-89
90-97
The remaining universe of facilities fall into two main groups, those that have a statutory
or regulatory exemption, including agricultural and most silvicultural activities, and those
that are considered to be potential Phase II activities. Many of these potential Phase II
2 The Standard Industrial Classification (SIC) code system organizes industries into categories and
subcategories. Major groups are designated by a two-digit code number between 01 and 99. Within major groups,
facilities are further categorized at the industry group (3-digit) level and industry (4-digit) level.
3 This figure excludes about 800,000 building, construction, and specialty contractors, which are regulated to
the extent that they engage in construction activities disturbing 5 acres or more.
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Chapter 4—Individual Phase II Discharges
sources, however, are not expected to become subject to Phase II regulation. Sources that
are not in Phase I and are not expected to become subject to NPDES storm water regulation
in Phase II consist of sources that lack the potential to contribute significant levels of
pollutants to storm water, including financial institutions, some governmental activities and
many types of service organizations.
The remaining categories of light industrial, commercial, retail, governmental
establishments, and residential activities represent the universe of facilities under
consideration for potential inclusion in Phase II. These facilities fall into several general
categories with respect to Phase II:
• Facilities with activities essentially identical or closely related to those "associated
with industrial activity," that are not covered for a variety of statutory and regulatory
reasons.
• Facilities with activities similar to those "associated with industrial activity," such as
transportation activities, energy producers and distributors, and utilities.
• Commercial activities with industrial components, such as assembly and repair
operations.
• Agriculture-related operations that include currently unregulated feedlots.4
• Non-agricultural operations with potential for use of pesticides and fertilizers.
• Facilities and households with failing septic systems.
• Other facilities with potential to use or produce toxic substances, including
laboratories and some governmental facilities.
In general, the geographic distribution of industrial, commercial, and retail activity—in
short, economic activity—tends to be closely associated with population and population
4 To be subject to the NPDES program, sources must have point source discharges of pollutants to waters of the
United States. EPA has defined concentrated animal feeding operations (CAFOs) as point sources currently subject
to permitting under NPDES. This study looks at feedlots which do not meet the regulatory definition of CAFO to
study their impacts on water quality and to identify them as potential sources to be covered under Phase II.
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Chapter 4—Individual Phase n Discharges
density. Through this relationship between population and economic activity, this industrial
analysis can be compared with the municipal analysis undertaken hi the previous chapter.
The Phase I municipal approach is taken as the starting point for a locational analysis of
industrial Phase I and potential Phase n sources hi this chapter. The municipal component of
Phase I of the storm water regulatory program focuses on the largest cities and counties,
which contain about one-third of all the facilities hi both regulated and nonregulated
categories. There are a few notable exceptions to this relationship between economic activity
and population, including agricultural and mining activity. These are discussed hi more
detail later hi this chapter.
4.1.1 The Phase I Permitting Framework for Industrial Discharges
Section 402(p) of the CWA provides that EPA or NPDES-approved States cannot require
a permit for storm water discharges from individual sources before October 1, 1994, except
for discharges "associated with industrial activity" or those that had a permit prior to
February 4, 1987, unless they are significant contributors of pollutants to waters of the
United States or contribute to the violation of a water quality standard. The Act also
clarifies that permits for discharges associated with industrial activity must meet all of the
applicable provisions of CWA Sections 402 and 301, including both applicable technology-
based requirements and water quality-based standards. All other storm water discharges that
are potential candidates for coverage fall under Phase II of the program. The basic
permitting framework for Phase I of the NPDES storm water program is established hi 40
CFR 122, primarily Section 122.26.
The November 16, 1990, storm water regulations described 11 categories of industrial
facilities that defined the term "discharges associated with industrial activity." The
categories were derived from a combination of narrative descriptions and specific SIC code
designations to define and identify Phase I sources (40 CFR 122.26(b)(14)). The types of
industrial facilities covered by the definition are illustrated hi Table 4-2.
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Chapter 4—Individual Phase II Discharges
Table 4-2. Industrial Facilities That Must Submit Applications
for Storm Water Permits (Phase I)
40CER
122.26(b)(14)
Subpart
Description
(i)
Faculties subject to storm water effluent limitations guidelines, new source performance standards, or
toxic pollutants effluent standards under 40 CFR, Subchapter N [except facilities which are exempt
under category (xi)].
(H)
Facilities classified as:
SIC 24 (except 2434) Lumber and Wood Products
SIC 26 (except 265 and 267) . Paper and Allied Products
SIC 28 (except 283 and 285) . Chemicals and Allied Products
SIC 29 Petroleum and Coal Products
SIC 311 Leather Tanning and Finishing
SIC 32 (except 323) Stone, Clay and Glass Products
SIC 33 Primary Metal Industries
SIC 3441 Fabricated Structural Metal
SIC 373 Ship and Boat Building and Repairing
Facilities classified as SIC 10 through 14, including active or inactive mining operations and oil and
gas exploration, production, processing, or treatment operations, or transmission facilities that
discharge storm water contaminated by contact with, or that has come into contact with, any
overburden, raw material, intermediate products, finished products, byproducts, or waste products
located on the site of such operations.
SIC 10 Metal Mining
SIC 11 Anthracite Mining
SIC 12 Coal Mining
SIC 13 Oil and Gas Extraction
SIC 14 Nonmetallic Minerals, except Fuels
Civ)
Hazardous waste treatment, storage, or disposal facilities, including those that are operating under
interim status or a permit under Subtitle C of the Resource Conservation and Recovery Act (RCRA).
(v)
Landfills, land application sites, and open dumps that receive or have received any industrial wastes
including those that are subject to regulation under subtitle D or RCRA.
(vi)
Facilities involved in the recycling of material, including metal scrapyards, battery reclaimers, salvage
yards, and automobile junkyards, including but not limited to those classified as:
SIC 5015 Motor Vehicle Parts, Used
SIC 5093 Scrap and Waste Materials
(vii)
Steam electric power generating facilities, including coal handling sites.
(viii)
Transportation facilities which have vehicle maintenance shops, equipment cleaning operations, or
airport de-icing operations. Only those portions of the facility that are either involved in vehicle
maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication),
equipment cleaning operations, or airport de-icing operations, or which are otherwise listed in another
category, are included.
SIC 40 Railroad Transportation
SIC 41 Local and Suburban Transit
SIC 42 (except 4221-25) .... Motor Freight and Warehousing
SIC 43 U.S. Postal Service
SIC 44 Water Transportation
SIC 45 Transportation by Air
SIC 5171 Petroleum Bulk Stations and Terminals
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Chapter 4—Individual Phase EL Discharges
Table 4-2. Industrial Facilities That Must Submit Applications
for Storm Water Permits (Phase I) (continued)
40CFX
122.26(b)(14)
Subpart
Description
Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system,
used in the storage, treatment, recycling, and reclamation of municipal or domestic sewage, including lands
dedicated to the disposal of the sewage sludge that are located within the confines of the facility, with a design flow
of 1.0 million gallons per day or more, or required to have an approved pretreatment program under 40 CFR Part
403. Not included are farm lands, domestic gardens, or lands used for sludge management where sludge is
beneficially reused and which are not physically located in the confines of the facility, or areas that are in
compliance with Section 405 of the CWA.
00
Construction activity including clearing, grading, and excavation activities except operations that result in the
disturbance of less than 5 acres of total land area and those that are not part of a larger common plan of
development or sale. _.^_^^__^^^^^_^_^___^^______________
(xi)
Facilities under the following SICs [which are not otherwise included in categories (ii)-(x)], including only storm
water discharges where material handling equipment or activities, raw materials, intermediate products, final
products, waste materials, byproducts, or industrial machinery are exposed to storm water.
SIC 20 Food and Kindred Products
SIC 21 Tobacco Products
SIC 22 Textile Mill Products
SIC 23 Apparel and Other Textile Products
SIC 2434 Wood Kitchen Cabinets
SIC 25 Furniture and Fixtures
SIC 265 Paperboard Containers and Boxes
SIC 267 Converted Paper and Paper Board Products
(except containers and boxes)
SIC 27 Printing and Publishing
SIC 283 Drugs
SIC 285 Paints, Varnishes, Lacquer, Enamels
SIC 30 Rubber and Misc. Plastics Products
SIC 31 (except 311) Leather and Leather Products
SIC 323 Products of Purchased Glass
SIC 34 (except 3441) Fabricated Metal Products
Sic 35 Industrial Machinery and Equipment, except Electrical
SIC 36 Electronic and Other Electric Equipment
SIC 37 (except 373) Transportation Equipment
SIC 38 Instruments and Related Products
SIC 39 Miscellaneous Manufacturing Industries
SIC 4221 Farm Products Warehousing and Storage
SIC 4222 Refrigerated Warehousing and Storage
SIC 4225 General Warehousing and Storage ^^^
Source: Federal Register, Vol. 55, No. 222, p. 48065, November 16, 1990.
Note: On June 4, 1992, the U.S. Court of Appeals for the Ninth Circuit remanded the exemption for construction sites of less than five
acres and for manufacturing facilities in category (xi) which do not have materials or activities exposed to storm water to the EPA
for further rulemaldng. NRDC v. EPA, 966 F.2d 1292 (9th Cir. 1992). In response to the remands, the Agency intends to
conduct further rulemakings on both the light manufacturing and the construction activities. In the December 18, 1992, Federal
Register, EPA stated that it is not requiring permit applications from construction activity under five acres or light industry
without exposure until this further rulemaking is completed.
For a more complete discussion of the interpretation of this definition, refer to the
NPDES Storm Water Program Question and Answer Document, Parts I and II (EPA, 1992,
1993), which appear in Appendix D.
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Chapter 4—Individual Phase n Discharges
The original permitting framework of Phase I provided operators of industrial facilities
with three options for applying for NPDES permit coverage. They could (1) submit
individual applications, (2) participate hi a group application, or (3) submit a notice of intent
to be covered by a general permit.5 For the first phase of the storm water program, EPA
issued general permits to facilitate permitting the large number of facilities covered by the
program on September 9, 1992 (57 FR 41176), September 25, 1992 (57 FR 44412), and
April 14, 1993 (58 FR 19427). This Phase I framework is the result of a lengthy rulemaking
process that included opportunities for, and response to, public comment. In addition,
authorized NPDES States have issued numerous other general permits for facilities within
then: States.
Section 402(p)(2)(E) of the CWA allows EPA or States to require permits for any other
discharges determined to be a contributor to a violation of a water quality standard or a
significant contributor of pollutants to waters of the United States. Thus, the Phase I
approach provides the foundation for extending regulation to additional sources and classes of
discharges, as appropriate.
4.1.2 Industrial, Commercial, and Retail Sources Not Subject to Phase I Permit
Requirements
This section responds to Congress' first mandate hi CWA Section 402(p)(5): to
identify the sources of storm water discharges for which permits are not currently required
under Phase I. This chapter addresses individual Phase II sources; municipal separate storm
sewer systems were discussed in Chapter 3. Based on a review of those facilities not subject
to Phase I permitting requirements and a screening procedure based on information drawn
from the literature review, activities were identified that may present opportunities for
pollutant releases to storm water. The purpose of the source identification is to present the
5 The group application permitting option is no longer available to permit applicants because the application
deadlines have passed. EPA proposed an industry-specific multi-sector model general permit based on the
information received through the group application process on November 19, 1993. EPA will be finalizing the
multi-sector general permit in the near future.
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Chapter 4—Individual Phase n Discharges
full range of potential Phase n sources and to characterize them to the extent possible to
facilitate decision making on the appropriate scope and approach of Phase II. The screening
process was used to narrow consideration to a subset of facilities that may be appropriate for
coverage under Phase n. Both the regulatory analysis and screening procedure are described
below.
4.1.2.1 Phase I Regulatory Review
In defining "storm water discharges associated with industrial activity," the Phase I
regulations identify 11 categories of facilities considered to be engaging in "industrial
activity" (see Table 4-2). Only those facilities described in the 11 categories of the definition
that have point source discharges of storm water are required to apply for storm water permit
coverage under Phase I of the program. As shown hi Table 4-2, regulated activities under
Phase I were identified by SIC category, narrative descriptions of activities, or, in some
cases, both. For example, Category viii regulated activities are defined as "only those
portions of the facility that are either involved hi vehicle maintenance . . ., equipment
cleaning operations, or airport de-icing operations, or which are otherwise listed in another
category . . . ." Seven separate SIC codes are then listed, including six two-digit codes and
one four-digit code; several four-digit codes were specifically omitted from coverage.
There are a number of sources closely related to Phase I activities that are currently
unregulated. One general class includes construction activities that disturb less than 5 acres
(Category x) and light industrial activities that have no exposure of materials to storm water
(Category xi). On June 4, 1992, the Court of Appeals for the Ninth Circuit remanded the
exemption of both of these categories from the original storm water regulations.6 The court
found that EPA had not adequately established that light industrial facilities without exposure
of materials or operations to storm water and construction sites disturbing less than 5 acres
were non-industrial hi nature.
6 Natural Resources Defense Council v. EPA, 966 F.2d 1292 (9th Cir. 1992).
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Chapter 4—Individual Phase n Discharges
In response to the Ninth Circuit Court ruling, EPA issued a Federal Register notice on
December 18, 1992, to explain the outcome of the ruling and to request comment and
specific factual information to assist in the development of a new proposal to address light
industry and small construction site categories. EPA noted that it did not believe that the
court's decision has the effect of automatically subjecting small construction sites and light
industries to the existing application requirements and deadlines. The Agency also indicated
that it believed that additional notice and comment were necessary to clarify the status of
these facilities. To the extent that some or all of these facilities may not be addressed by
Phase I, they would be potential Phase II sources.
Additional categories of potential Phase II facilities have been identified based on the
screening procedure described below.
4.1.2.2 Screening Procedure
Potential Phase II sources, categories, and activities were identified using previous
information and additional screening based on the major sectors of the economy identified by
SIC codes. Identifying potential Phase II sources based on SIC codes facilitates quantitative
analysis of the numbers of facilities potentially subject to Phase II and provides a basis for a
geographical location analysis that parallels the municipal analysis in Chapter 3. The
geographical analysis (discussed in Section 4.2.2) was developed to show the distribution and
"concentration" of non-domestic enterprises across the country and their association with
various sizes and types of population centers. This geographical approach could later be
related to a water quality or environmental assessment at a finer level of detail at the
regional, state or local level.
As discussed in Chapter 2, major sectors of the economy are defined on the basis of the
two-digit SIC code. This two-digit code is a relatively general categorization of the Nation's
economic activity: all industrial, commercial, and retail activities are organized into 83 two-
digit SIC codes. The four-digit SIC code provides a more detailed breakdown of these
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Chapter 4—Individual Phase n Discharges
enterprises and is much more specific to the activities conducted at the establishment.
Although all unregulated activities are potential Phase II sources, in practical terms, only a
subset of four-digit SIC industry groups has real potential to use, process, or store pollutant-
bearing materials or to engage hi activities that could lead to contamination of storm water.
SIC codes are assigned by economic activity, not pollution potential. However,
economic activities often correspond to physical activities or use of specific materials that can
be assessed relative to the potential to generate storm water pollution. Thus, SIC codes can
serve as an indicator of the underlying activities or materials of concern, even if they cannot
be used to directly assess environmental effects.
The screening process described below focuses on two broad classes of facilities. The
first (designated Group A) consists of facilities that fall within the same general range of SIC
codes as Phase I industrial activities but that are not covered under Phase I. The second
major group (designated Group B) consists of a specific subset of four-digit SIC codes of
concern (outside SIC codes 10-45) where discharges of pollutants are suspected based on case-
studies, expert opinion, literature review, other EPA programs and concerns, and experience
with Phase I of the storm water program.
This screening process does not establish negative environmental effects from storm
water discharges. It does serve as a tool for focusing attention on those categories potentially
contributing to storm water pollution. The geographical analysis reported in Section 4.2.2
allows EPA to determine how these specific categories of potential Phase II facilities are
distributed nationally hi geographic areas of concern (e.g., urbanized areas).
The following criteria were used to identify four-digit SIC codes of primary
environmental concern. First, facilities highly similar to Phase I facilities are identified
(Group A). Next, an additional 12 categories of potential Phase II sources are identified
based on their similarity to Phase I activities or based on case studies and expert opinion
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Chapter 4—Individual Phase II Discharges
(Group B). These 12 Group B categories are then related to specific SIC code groupings for
subsequent analysis in Section 4.2. The categories identified through this process represent
the types of establishments or activities that may warrant further investigation and control
under Phase II. This preliminary identification does not establish that water quality impacts
are occurring.
As noted earlier, the SIC code system is a useful framework for identifying the numbers
and locations of facilities. The SIC approach allows EPA to access information from many
sources with a very precise level of detail, because of the efforts of many organizations (e.g.,
Commerce Department) to record and track economic activity by industrial category. Still,
focusing on SIC codes for the purposes of this study does not imply that a regulatory strategy
must proceed on this basis. The types of activities conducted at these facilities could be
regulated through narrative descriptions, as was done for some categories in Phase I.
Experience with the Phase I definition of "discharges associated with industrial activity"
suggests that SIC designations alone may not be completely satisfactory because activities of
concern may be conducted at a wide variety of facilities that do not happen to have the same
primary SIC code. In addition, other potential Phase II sources that are not reflected by the
SIC code system, including parking lots, large retail complexes, and facilities or residences
with septic systems for septic wastewater disposal, can similarly be studied for impacts on
water quality or regulated based on narrative description. Even within an SIC-based
regulatory framework, additional factors, such as size, location, pollutant usage, or activity
cutoffs or restrictions, can be used to identify specific facilities for regulation based on a
potential correlation between facilities and water quality impacts.
The SIC system does not capture some types of facilities or activities that generate storm
water discharges. SIC codes are designated based on the primary activity in which an
establishment is engaged. A business that is involved in a number of different activities will
be classified according to a single industrial code, which may not reflect activities associated
with storm water discharges. In addition, some facilities carry out activities off-site, such as
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Chapter 4—Individual Phase II Discharges
material storage and vehicle maintenance, that will not have independent business identities
and, thus, no separate SIC designations. Similarly, the SIC system may not identify all
facilities that are owned or operated from a remote central business location. The SIC
system also does not individually identify industrial activities associated with municipalities.
Although some municipal services (e.g., public ambulance services) are identified, other
types of activities (e.g., municipal power generating facilities) are not captured within the
SIC system. Even with these limitations, EPA analysis of potential Phase II sources in terms
of SIC code assignments provides an extremely valuable analytical tool to assess the location
and concentration of these activities at the national level.
Group A Sources
Although Phase I industrial activities generally fall within SIC codes 10-45, there are
many omissions and exceptions within this range. While some of these omissions were
intentional, others are the result of the specificity of the 1990 application regulations. Other
facilities have been excluded from Phase I based on specific legislative changes. These
classes of facilities are deserving of special attention due to their extreme similarity to Phase
I industrial activities. For the purposes of discussion and analysis hi this report, these
facilities have been classified as Group A.
To clearly identify Phase II facilities that fall within the SIC range 10-45, a list of
unregulated activities related to Phase I sources hi each of the 11 industrial categories was
developed. This list appears in Table 4-3. The similarity of many of the facilities on this
list to Phase I facilities makes them difficult to distinguish from Phase I facilities for the
purposes of the analyses hi this report. In order to help characterize these sources, they have
been categorized below according to three mam criteria. The three groups identified together
make up Group A. Although these groups do not encompass every one of the possible
exceptions presented hi Table 4-3, they represent the majority of facilities in SIC codes 10-45
that were not addressed under Phase I.
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Chapter 4—Individual Phase n Discharges
Table 4-3. Categories of Activities Not Regulated Under Phase I
Category
i
ii
iii
iv
V
vi
vi
viii
ix
X
xi
Activities and Facilities
• Facilities that were not considered for inclusion in the effluent guideline formulations
• Offsite warehouses (unless auxiliary to a regulated facility)
• Offsite salt storage piles
• Chemical distributors that conduct incidental mixing and blending of products
• Distributors of farm products and equipment with mixing and blending of fertilizers (not SIC
2875)
• Pipelines
• Petroleum product distribution, including SIC 49
• Hazardous waste generation/storage sites subject to certain RCRA Subtitle C requirements
but not permitting
• Landfills that have not received or do not receive industrial waste (Municipal Solid Waste
Landfills (MSWLFs))
• Solid waste transfer stations with no vehicle maintenance or that are owned or operated by
the entity that owns the final disposal site
• Land application of sewage treatment plant effluent (exempted from RCRA requirements)
• Incinerators (BIFs and municipal incinerators) (hazardous waste incinerators are permitted
under RCRA Subtitle C and therefore are regulated under Phase I)
• Temporary offsite waste storage sites
• Interim recycling facilities (collection sites, satellite storage sites)
• Faculties that generate electricity, but do not use steam electric generation
• General equipment and vehicle storage/maintenance yards (municipal fire trucks, police cars,
park maintenance; construction equipment yards)
• Vehicle maintenance of garbage collection trucks owned by landfill operator
• SIC 40-45 facilities without vehicle maintenance
• Material handling/storage areas at SIC 40-45 faculties
• School bus maintenance faculties owned or operated by school districts
• Mining related equipment maintenance
• Warehouses under SIC 4226 that do not have vehicle maintenance
• Petroleum product wholesalers (SIC 5172) and bulk stations (SIC 5171) without vehicle
maintenance
• Treatment works with design flows less that 1 MOD (Transportation Act of 1991 exempted
POTWs owned or operated by municipalities with population of less than 100,000)
• Off-site non-domestic sewage treatment plants and sludge drying beds
• Portable sanitary and septage service facilities
• Water treatment plants
• Construction operations that result in the disturbance of less that five acres of total land area
are under review due to the court opinion in Natural Resources Defense Council v. EPA, 966
F.2d 1292 (9th Cir. 1992)
• Facilities where there is no exposure of material are under review due to the court opinion on
Natural Resources Defense Council v. EPA, 966 F. 2d 1292 (9th Cir. 1992)
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Chapter 4—Individual Phase n Discharges
Auxiliary Facilities or Secondary Activities—SIC codes are assigned on the basis of
the primary activity from a financial standpoint that is taking place at a particular
facility. Facilities with industrial activities that are in support of, or auxiliary to, a
non-regulated activity would not be covered under Phase I. Examples include
maintenance of construction equipment and vehicles and local trucking for an
unregulated facility (grocery stores etc.).
Facilities Intentionally Omitted from Phase I—Another class of facilities which are
not addressed under Phase I are those that are related to, but were intentionally
omitted from, one of the 11 industrial categories. For example, category ix does not
cover treatment works with a design flow of less than 1 MOD, and category v does
not address landfills that have not received industrial waste. While these activities
may be slightly different from Phase I activities hi size, scope, or specific materials
present, there are many similarities which may make these facilities a potential
concern hi Phase n.
Facilities Exempted by the Transportation Act—The Intermodal Surface
Transportation Efficiency Act of 1991 (Transportation Act) exempted most industrial
activities owned or operated by municipalities of less than 100,000 people from permit
coverage under Phase I.7 This exemption applies to approximately 19,000
incorporated places and 17,000 minor civil divisions hi over 3000 counties. It is
important to note that these activities are identical to Phase I facilities and are not
located hi municipalities which are covered under Phase I.
The overlap in SIC code assignments between Group A facilities and Phase I regulated
activities make accurate estimation of the number of facilities hi Group A very difficult. The
estimates used are based on a process of elimination. Beginning with the total number of
facilities in SIC codes 10-45 and subtracting the number of facilities accounted for under
Phase I gives approximately 100,000 to 200,000 facilities. This is roughly equivalent to the
size of Phase I. The difficulty hi distinguishing these facilities from then- closely related
Phase I analogues also makes the geographic analysis conducted in section 4.2 difficult.
Although the analysis has been conducted on a general basis for the entire group, this will
only yield an overall approximation. Sub-classes of facilities within this group may be
7 The Transportation Act exempted industrial activities owned or operated by municipalities of less than 100,000
population from Phase I permitting requirements with the exception of powerplants, airports, and uncontrolled
sanitary landfills.
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Chapter 4—Individual Phase U Discharges
distributed quite differently. For information on the distribution of specific two-digit SIC
codes within group A, see Appendix G.
Group B Sources
Based on the regulatory review and analysis of the types of industrial sources not covered
under Phase I (discussed previously), several categories of facilities that are inherently
similar or related to Phase I sources, but that fall into SIC code categories outside of SIC
codes 10-45, were identified. A number of criteria were used to develop a comprehensive
list of facilities which should be considered for inclusion in Phase n. This list constitutes
Group B.
The first criteria used to identify Group B facilities were activities with industrial
components or closely related activities. The main categories identified include:
Transportation Activities and Services—SIC series 478x, which are similar to those
identified in Category viii of the Phase I definition (see Table 4-2)
Energy Producers and Distributors—Similar to Categories iii and vii, including
pipelines (SIC 46 Ix) and petroleum producers (SIC 4925)
Other Utilities—Water supply, irrigation, and sanitation services that may often be
municipally operated (SICs 494x, 495x, and 497x), which are related to Category ix
Municipal or Governmental Activities or Services—In the 922x series that may have
industrial components (Category ii) or activities related to transportation or vehicle
maintenance (Category viii) (e.g., police stations, jails, and fire stations).
The next criterion used was commercial facilities with industrial components or similar
operations. Commercial facilities were specifically excluded from Phase I by congressional
intent. However, officials engaged hi controlling urban runoff and nonpoint source pollution
at the local, State, and national level believe that many commercial sources represent an
important environmental concern. These concerns are documented hi State and local
nonpoint source programs, urban runoff programs, and estuary programs identified through
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Chapter 4—Individual Phase n Discharges
the literature review. The Rensselaerville Study (1992) reflected potential areas of concern
by identifying "gas, auto, service stations, transportation related activities, highway systems,
land development, agricultural sources and related activities, commercial activities with
industrial components, and large retail complexes. "8 Taking a broad view of these
descriptions, facilities were identified in two main categories. The first category comprises
commercial or retail establishments with industrial components or activities:
* Many types of establishments that provide automotive or transportation services,
including car dealers and gas/service stations (SICs in the 55xx series) and other
automobile-related services and maintenance with SIC codes from 75 Ix to 754x, such
as truck and car renters, various types of repair and body shops, parking structures,
and car washes
• Commercial enterprises involved in fuel wholesaling and distribution, such as gas and
petroleum storage and distribution (SICs 493x and 517x) and fuel oil and coal dealers
(SIC 598x)
• Commercial or wholesale enterprises with manufacturing or assembly activities,
mainly hi the 50xx and 52xx series
• Commercial or wholesale facilities that include food processors or wholesalers that
may have organic wastes (SIC 514x), photographic studios (SIC 7221) and photo
finishing labs (SIC 7384), small repair shops that may have metal wastes (SIC 769x),
including repair of communications devices, refrigeration units, other electrical or
electronic devices, and welding; research and testing laboratories (SIC 873x) and
laundries (SIC 721x)
• National security entities (SIC 9711); although industrial activities at military facilities
are regulated hi Phase I, potential Phase II activities may be located on these sites as
well and would not show up individually hi the analysis that follows.
The second category consists of commercial or retail facilities and other sources that are
similar or related to agricultural activities or sources and includes:
8 No SIC codes specifically identify all large retail complexes. However, these are partially addressed through
the loading analysis of storm water from urban/urbanized areas in the municipal section (Chapter 3). If such items
were to be addressed in a regulatory framework, it would likely be on the basis of a narrative description rather than
a SIC designation.
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Chapter 4—Individual Phase H Discharges
• Agriculture-related operations in the SIC groups 021x and 025x because they may
represent confined animal facilities or feedlots.9 Wholesale livestock facilities (SIC
5154) were also included under this criterion as were animal husbandry operations
aside from general farms, such as zoos (SIC 8422), racetracks and stables (SIC 7948),
which may have operations that are similar to feedlots.
• Because of potential for use of pesticides and fertilizers, the following were included:
nurseries and lawn and garden facilities (SIC 078x) and other facilities that may store,
mix, or use agricultural chemicals or other pesticides, such as farm products and raw
materials sellers (SIC 5159), wholesalers of chemicals and allied products (SIC 5169),
farm suppliers (SIC 5191), lawn and garden suppliers (SIC 5261), and exterminators
(SIC 7342).
• Other facilities that may use pesticides or fertilizers in substantial quantities, such as
golf courses and other recreational establishments with large lawns (SIC 799x) and
colleges and schools (SIC 822x), which may have lawns, gardens, nurseries, or
experimental agricultural areas. (These may also operate power plants or treatment
works or engage in other activities similar to regulated industrial categories.)
From the 12 categories of Group B Phase II sources identified above, the universe of
facilities was screened to identify a specific subset for further analysis. Through this
selection process, potential Phase II facilities were identified, including those associated with
products or waste materials that contain pollutants, such as metals, pesticides, and nutrients,
and those associated with processes, practices, or events that can lead to the discharge of
those pollutants into storm water. The SIC manual identifies 83 major groups of SIC codes
in 10 major divisions (identified hi Table 4-1). These major groups are divided into 1,047
four-digit categories. Of these, 604 fall into Phase I regulated activities or closely related
facilities which make up Group A (SIC 10-45). Of the 443 that remain hi agricultural,
commercial, and retail divisions, 168 fall into the excluded service sectors. Of the remaining
275 categories, the screening process and the 12 categories identified above correspond to 90
individual categories of facilities and activities for further study as potential Phase II sources.
9 See footnote 4 regarding feedlots currently regulated under the NPDES program.
4-17
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Chapter 4—Individual Phase n Discharges
This subset of 90 four-digit SIC codes is listed in Table 4-4. More than a million facilities
were identified for these SIC categories by searching EPA's Facility and Company Tracking
System (FACTS) data base.10
To facilitate analysis, some additional grouping is necessary. These 90 individual
categories could be grouped together based on the 12 criteria used to identify them.
However, some of the criteria group together dissimilar activities. For example,
"commercial wholesalers" include four dissimilar categories: wood, ore, metal, and
machinery wholesalers. Based on these distinctions, the 12 groups were further subdivided,
forming 18 potential Phase n sectors. The 18 sectors are listed in Table 4-5. The affiliation
of each specific SIC code with a sector is shown in Table 4-4, along with the numbers of
facilities in that SIC code. This grouping into sectors facilitates discussion of similarities and
differences among categories later in the chapter.
The data on numbers of facilities in Table 4-4 reveal some interesting facts about
individual categories. Of the 18 Group B sectors, the automobile service sector (comprised
of gas/service stations (SIC 5541), general automobile repair (SIC 7538), top, body repair
(SIC 7532), repair shops and services (SIC 7699), car dealers, new & used (SIC 5511), car
dealers, used only (SIC 5521), car washes (SIC 7542), passenger car rental (SIC 7514),
truck rental (SIC 7513), parking structures (SIC 7521), and miscellaneous auto services (SIC
7549)) make up more than one-third of the total number of facilities identified in all 18
sectors.
Table 4-5 also shows facility counts for the 18 Group B sectors, illustrating even more
clearly the dominant categories. Facilities engaged hi automotive service and vehicle
maintenance are far more numerous than other groups of potential Phase II sources.
Machinery and electrical repair facilities are the second largest group, and intensive users of
agricultural chemicals, including lawn and garden establishments and nurseries, are the third
largest group.
10 As discussed in Chapter 2, the FACTS data base is leased by EPA from Dun & Bradstreet Information
Services, which created, maintains, and annually updates information based on a variety of sources.
4-18
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Chapter 4—Individual Phase II Discharges
Table 4-4. SIC Codes Selected for Study Based on Screening Procedure
SIC
Code
5541
7538
7699
7532
5084
5511
0782
5211
5521
7539
7216
7622
5191
7221
9629
5261
5085
0212
7692
5031
5083
7217
7549
7542
7342
4731
0241
5172
0181
4953
7384
5169
5051
7623
5171
7514
7513
7212
0783
5983
5082
8221
8731
5984
5147
4941
Description
Selected (90) 4-Digit Code
Gas/Service Stations
General Auto Repair
Repair Shops & Related Svcs., NEC
Top, Body Repair
Industrial Mach. & Equipment
Car Dealers, New & Used
Lawn & Garden Services
Lumber & Bldg. Materials
Car Dealers, Used Only
Specialized Repair
Dry Cleaning
Radio and Television Repair
Farm Supplies
Photographic Studios
Electrical Repair Shops, NEC
Lawn & Garden Supply
Industrial Supplies
Beef Cattle, not Feedlots
Welding Repair
Lumber, Millwork
Farm Mach. & Equip.
Carpet Cleaners
Misc. Automotive Services
Car Washes
Disinfect/Exterminating
Arrangement Freight Trans.
Dairy Farms
Petroleum Products/Dist.
Ornamental Nurseries
Refuse Systems
Photo Finishing Labs
Chem & Allied Prod, NEC
Metal Service Centers
Refrig. & Air Condition. Repair
Petroleum, Bulk
Passenger Car Rental
Truck Rental
Garment Cleaners
Shrub & Tree Services
Fuel Oil Dealers
Constr. & Mm. Mach.
Colleges and Universities
Comm. Research Labs
Fuel and Coal Dealers
Meat & Products
Water Supply
Number of
Facilities
91,924
87,994
70,095
48,800
38,880
37,387
36,369
34,757
32,145
26,381
22,042
20,527
20,189
20,010
19,448
19,443
17,869
14,684
14,305
13,836
13,670
13,636
13,571
12,842
12,359
12,303
12,298
11,128
11,019
10,797
10,674
10,355
10,267
8,504
8,086
7,939
7,799
7,280
7,260
7,233
7,143
6,829
6,382
6,226
5,298
4,904
Phase n*
Sector
Automotive Service
Automotive Service
Machinery & Electrical Repair
Automotive Service
Wholesale, Machinery
Automotive Service
Intensive Ag. Chemical Use
Wholesale, Wood Products
Automotive Service
Automotive Service
Laundries
Machinery & Electrical Repair
Intensive Ag. Chemical Use
Photographic Activities
Machinery & Electrical Repair
Intensive Ag. Chemical Use
Wholesale, Machinery
Livestock, Feedlots
Machinery & Electrical Repair
Wholesale, Wood Products
Wholesale, Machinery
Laundries
Automotive Service
Automotive Service
Intensive Ag. Chemical Use
Transport, Rail and Other
Livestock, Feedlots
Petrol. Pipelines & Distributors
Intensive Ag. Chemical Use
Various Utilities
Photographic Activities
Intensive Ag. Chemical Use
Wholesale, Metal Products
Machinery & Electrical Repair
Petrol. Pipelines & Distributors
Automotive Service
Automotive Service
Laundries
Intensive Ag. Chemical Use
Petrol. Pipelines & Distributors
Wholesale, Machinery
Extensive Ag. Chemical Use
Laboratories
Petrol. Pipelines & Distributors
Wholesale, Food
Various Utilities
4-19
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Chapter 4—Individual Phase n Discharges
Table 4-4. SIC Codes Selected for Study Based on Screening Procedure (continued)
SIC
Code
Description
Selected (90) 4-Digit Code
Number of
Facilities
Phase H*
Sector
8249
5146
7219
5154
0213
8734
7992
5039
9511
7521
0211
7211
7694
9221
9711
7948
5159
4959
8222
9223
5144
5052
7996
0252
0219
4783
5989
0251
7218
4789
0254
4971
0214
4925
0273
4612
9229
4613
4785
4939
8422
4932
4741
4619
Vocational Schools
Fish & Seafoods
Laundry Services
Livestock
Hogs
Testing Laboratories
Golf Courses, Public
Construct Materials
Air, H2O & Solid Waste Mgmt.
Parking Structures
Beef Cattle Feedlots
Laundries
Armature Rewinding Shops
Police Protection
National Security
Race Tracks/Stables
Farm Prods. Raw Mats
Sanitary Svcs., NEC
Junior Colleges
Jails
Poultry & Products
Coal/Minerals & Ores Wholesale
Amusement Parks
Chicken Eggs
General Livestock, not Dairy
Packing and Crating
Fuel Oil Dealers, NEC
Broiler, Fryer, Roaster Chicken
Ind. Launderers
Transport Services, NEC
Poultry Hatcheries
Irrigation System
Sheep and Goats
Gas Producers, Distributors
Animal Aquaculture
Crude Petroleum Pipelines
Fire Protection
Refined Petroleum Pipelines
Weighing: Vehicle Trans.
Utilities, NEC
Botanical Gardens & Zoos
Gas & Service
Rental of Railroad Cars
Pipelines, NEC
4,647
4,579
4,575
4,351
4,328
4,301
4,295
4,036
3,688
3,088
2,972
2,940
2,865
2,508
2,414
2,271
1,895
1,894
1,850
1,714
1,495
1,384
1,371
1,171
1,160
1,099
1,075
941
903
899
719
662
618
604
595
390
389
347
332
297
285
212
175
18
Extensive Ag. Chemical Use
Wholesale, Food
Laundries
Livestock, Feedlots
Livestock, Feedlots
Laboratories
Extensive Ag. Chemical Use
Wholesale, Metal Products
Various Utilities
Automotive Service
Intensive Ag. Chemical Use
Laundries
Machinery & Electrical Repair
Munic. Services, Vehicle Maint.
National Security
Livestock, Feedlots
Intensive Ag. Chemical Use
Various Utilities
Extensive Ag. Chemical Use
Munic. Services, Vehicle Maint.
Wholesale, Food
Wholesale, Coal & Ores
Extensive Ag. Chemical Use
Livestock, Feedlots
Livestock, Feedlots
Transport, Rail and Other
Petrol. Pipelines & Distributors
Livestock, Feedlots
Laundries
Transport, Rail and Other
Livestock, Feedlots
Various Utilities
Livestock, Feedlots
Petrol. Pipelines & Distributors
Livestock, Feedlots
Petrol. Pipelines & Distributors
Munic. Services, Vehicle Maint.
Petrol. Pipelines & Distributors
Transport, Rail and Other
Various Utilities
Livestock, Feedlots
Petrol. Pipelines & Distributors
Transport, Rail & Other
Petrol. Pipelines & Distributors
TOTAL
1,015,239
*Phase II sector is a grouping devised to facilitate discussion of similar facilities. The sectors are further
described hi the text and summarized in Table 4-5.
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Chapter 4—Individual Phase II Discharges
Table 4-5. Summary of Group B Phase II Sectors
Description of Phase n Sectors
Automotive Service
Machinery & Electrical Repair
Intensive Ag. Chemical Use (a)
Wholesale, Machinery
Laundries
Wholesale, Wood Products
Livestock, Feedlots
Petroleum Pipelines & Distributors
Photographic Activities
Various Utilities
Extensive Ag. Chemical Use (b)
Transport, Rail and other
Wholesale, Metal Products
Wholesale, Food
Laboratories
National Security
Municipal Services, Vehicle Maint.
Wholesale, Coal & Ores
Total
No. of Facilities
369,870
135,744
121,861
77,562
51,376
48,593
43,421
35,319
30,684
22,242
18,992
14,808
14,303
11,372
10,683
4,611
2,414
1,384
1,015,239
(a) e.g., nurseries, farm chemical suppliers & distributors
(b) e.g., large lawns, golf courses
Remaining Phase II Activities
The identification of all Phase I facilities together with facilities in Groups A and B only
account for approximately 1.5 million of the estimated 7.7 million total facilities. This
leaves over 6 million facilities "unaccounted for" in this analysis. These remaining facilities
include a wide range of activities which fall into a number of general classifications.
General Sources—Widespread sources of potential storm water contamination which are not
necessarily associated with any one particular activity are a large category of sources not
addressed hi this analysis. These include parking lots, trash dumpsters, leaking and failing
septic systems, and activities related to individual residences such as fertilizer and pesticide
application. The tremendous number of these sources would make individual permitting
virtually impossible. Although the identification and analysis of individual Phase II sources
does not focus on these sources, the municipal analysis does account for pollutant loadings
from these types of sources which are related to the general process of urbanization.
4-21
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Chapter 4—Individual Phase n Discharges
Service Sectors—Major SIC groups in the service sectors, such as banking, finance,
insurance firms, and all types of food services were not considered to be potential Phase II
sources. The activities of these enterprises are generally conducted indoors and do not
inherently use or produce contaminants that may enter storm water. However, these
facilities may also have some of the general sources of storm water contamination discussed
above, such as parking lots or trash dumpsters. All of the major SIC groups excluded on
this basis are listed in Table 4-6. Although the analysis of this report does not focus on
service sector facilities in detail at the four-digit SIC level, the geographic and distributional
analysis was conducted for these facilities at the major group (two-digit SIC) level. These
results are presented in Appendix G.
4.2 NATURE AND EXTENT OF POLLUTANTS ASSOCIATED WITH INDIVIDUAL
PHASE n SOURCES
This section responds to the second congressional mandate in CWA Section 402(p)(5):
to determine the nature and extent of pollutants in storm water discharges to the maximum
extent practicable. EPA developed quantitative and qualitative information on the types of
activities or materials associated with potential Phase II sources and their locations relative to
various geographic jurisdictions.n
The nature of storm water discharges from industrial and commercial sources was
addressed hi two ways. First, sampling data on quality of runoff from Phase I industrial
sources were analyzed and summarized to provide a basis of comparison for potential Phase
n sources. The data submitted with group permit applications are among the most
comprehensive sources of data on pollutant concentrations in industrial runoff. Second,
descriptive information on the potential for storm water discharges from industrial and
commercial activities was identified and summarized. This was based on the literature
review, inference from descriptions of the activities associated with industrial and
11 As discussed in Chapter 2, EPA was not able to identify adequate data to support the calculation of pollutant
loadings on a national scale.
4-22
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Chapter 4—Individual Phase II Discharges
Table 4-6. SICs Not Considered as Potential Phase H Sectors
Transportation and Public Utilities Sector:
SIC 48 Communication Facilities
Retail Trade Sector:
SIC 53 General Merchandise Stores
54 Food Stores
56 Apparel and Accessory Stores
57 Home Furniture, Furnishings and Equipment Stores
58 Eating and Drinking Places
Finance, Insurance, and Real Estate Sector all facilities:
SIC 60 Banking
61 Credit Agencies
62 Security Brokers
63 Insurance Carriers
64 Insurance agents
65 Real Estate
67 Investment Offices
Services Sector:
SIC 70 Hotels and Lodging Places
78 Motion Pictures
Health Services Sector:
SIC 80 Doctors' Offices and Medical Clinics
81 Legal Services
83 Social Services
86 Membership Organizations
88 Private Households with Employees
Public Administration Sector:
SIC 91 General Government, Except Finance
93 Public Finance and Taxation
94 Administration of Human Resource Programs
96 Administration of Economic Programs
Source: OMB, 1987
commercial facilities, the documented experiences of municipalities operating storm water
management programs, and EPA's experience in assisting the regulated community in
meeting group application requirements under Phase I of the regulatory program.
Determining the extent of pollutants was addressed by identifying the geographic
distribution of the sources that may contribute pollutants to storm water. Through a
locational analysis, categories of facilities were analyzed to determine to what extent they are
located in various sizes of cities, urban areas, and other political jurisdictions. This
quantitative assessment of location is informative and useful for certain policy discussions but
4-23
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Chapter 4—Individual Phase II Discharges
does not establish the presence of pollutants in storm water for any potential Phase II
sources.
4.2.1 Nature of Pollutants Associated With Individual Phase II Sources
This section presents information on pollutants and activities associated with industrial,
commercial, and retail categories that may contribute to storm water contamination.
4.2.1.1 Phase I Industrial Group Applicant (Part D) Data
Phase I Industrial Group Applicant (Part II) Data provides a basis for identifying the
areas and activities that may be of concern when associated with nonregulated categories of
facilities. This section presents analyses of storm water runoff quality data from Phase I
(industrial) permit applicants. As part of the permitting process, 44,000 Phase I group
applicants hi 700 groups were organized into 29 sectors based on general similarity for
purposes of writing a multisector general permit.12 Part II of the permit application
required approximately 10 percent of the members of each group to submit sampling results
for pollutants in storm water discharges, including conventional, nutrients, and other toxic
pollutants that might be present. Table 4-7 summarizes these results by reporting the
composite sample mean concentration for each sector for nine of the basic pollutants studied
in NURP plus oil and grease. Although the sources and methods of data collection differ,
this industrial sector concentration data can be compared with summary data from NURP or
USGS to provide some insight into storm water runoff quality. Comparisons can also be
made among sectors to determine which are more likely to discharge higher concentrations of
certain classes of pollutants. Appendix E provides a comprehensive summary of the industry
sectors and sampling data from the group application process.
12 The sectors were designed to group similar facilities together. Facilities were separated into 31 sectors for
analysis of the Part II Group Application data for this report. Only 29 sector permits were developed in the multi-
sector general permit. After some groups were combined, and others withdrew, only 700 groups representing
44,000 facilities remained from approximately 60,000 which began the group application process.
4-24
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Chapter 4—Individual Phase II Discharges
Table 4-7. Summary of Sampling Data from Phase I Group Permit Applications
(with comparison to NURP and USGS studies1)
Sector
NURP
USGS
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
22
23
24
25
26
27
28
29
30
31
33
Description
Median Urban Site *
Commercial Site *
Lumber & Wood Products
Paper & Allied Prod.
Chemicals & Allied Products
Petrol Refining & Related Ind.
Stone, Clay, Glass Products
Primary Metal Ind.
Metal Mining
Coal & Lignite Mining
Oil & Gas Extraction
Nonmetallic Mineral Mining
Hazardous Waste TSDFs
Industrial Landfills & Dumps
Used Motor Vehicle Parts
Scrap & Waste Materials
Steam Electric Power Plants
Railroad Transport
Transport: Trucks, Freight, etc.
Water Transport
Ship & Boat Building, Repair
Air Transport
Wastewater Treatment
Food, Tobacco Manufact.
Textile & Apparel Manufact.
Furniture & Fixtures
Printing & Publish.
Rubber & Plastic Prods.
Leather/Products
Fabricated Metal Prod., Jewelry
Ind. & Comm & Transport Equip.
Electronic Equip & Instruments
Military Indust. Activities
Pollutant Composite Mean (mg/1)
Conventional
BODS
12
16
45.37
24.25
11.74
10.87
7.32
34.08
10.63
6.55
10.59
6.89
9.44
9.04
11.77
24.00
5.69
9.27
11.07
6.00
6.27
21.34
46.11
42.54
9.82
8.80
6.95
11.21
22.32
10.04
7.32
7.48
16.51
COD
82
NR
242.50
133.90
77.24
86.93
77.53
109.84
195.07
26.86
115.94
66.20
51.93
102.02
66.23
203.71
69.47
189.46
85.64
75.79
69.96
75.63
187.09
141.65
48.05
76.33
42.37
72.08
91.94
86.17
46.09
36.32
54.50
TSS
180
248
575
44
94
165
386
162
623
690
413
1576
83
1850
839
376
212
249
454
224
45
80
114
200
80
143
31
119
115
125
97
67
126
O&G
NR
NR
2.54
0.19
0.00
1.55
2.97
2.14
0.00
1.06
2.90
5.28
6.36
2.96
5.03
1.56
0.00
6.83
0.00
3.40
3.68
Nutrients
NO2+3
0.86
0.38
0.75
0.76
4.29
0.82
1.40
1.38
0.90
1.00
0.60
1.27
0.39
1.38
1.62
5.88
0.75
1.41
1.99
0.66
0.82
1.29
20.50
0.98
1.14
1.51
1.35
1.26
1.88
1.27
1.28
0.66
0.88
TKN
1.90
NR
2.32
3.17
17.75
1.63
2.37
3.00
3.39
2.65
1.69
2.41
1.07
3.03
2.27
3.38
1.95
2.48
2.04
9.41
2.20
16.00
4.74
4.07
1.92
4.40
1.57
1.63
6.22
1.78
1.76
1.34
1.28
P
0.42
0.31
6.29
0.36
9.51
0.28
0.87
0.52
1.06
0.12
3.41
1.13
0.11
0.95
2.23
0.77
0.63
0.92
0.73
0.15
0.86
0.29
0.68
1.32
0.31
0.26
0.35
0.34
0.83
0.84
0.39
1.02
7.12
Metals
Copper
0.04
0.03
0.05
0.03
0.12
0.16
2.25
0.59
0.00
0.01
,
0.63
0.03
0.02
0.08
0.01
0.05
0.05
0.07
0.00
0.02
0.03
0.46
0.08
0.01
0.17
Lead
0.18
0.22
0.03
0.02
0.25
0.19
6.07
20.64
0.88
0.02
0.01
0.05
0.09
0.01
0.01
0.04
0.01
0.01
0.02
0.06
0.22
0.01
0.14
Zinc
0.20
0.31
0.36
0.78
1.74
0.39
6.55
3.87
0.06
0.29
3.35
0.37
0.28
1.34
0.42
0.33
0.35
0.12
0.79
0.30
0.59
0.47
0.80
2.17
0.42
0.15
0.68
*Recently, concerns have been raised regarding the validity and use of historical data for metals. As discussed in chapter 2, EPA believes that
historical data on storm water runoff from NURP and USGS are suitable for the purposes of this report.
Although it focuses on Phase I sources rather than Phase n, this analysis is an important
contribution to the literature and this report because it may be the most comprehensive data
available on sector-specific industrial discharges. This information can assist EPA and States
in evaluating and targeting Phase II sources, at least those that may be similar to Phase I
sources. The information can also be used to compare with other sources of information and
to give some perspective on which Phase II sectors are of most concern (to the extent they
are similar to Phase I activities). This exercise also demonstrates the usefulness of the data
4-25
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Chapter 4—Individual Phase II Discharges
collection effort involved in the group application process. These summary data can also
provide a baseline from which to measure future improvements in runoff quality and a basis
for developing measurable indicators for performance evaluation of State, local, or industrial
programs in the future.
An understanding of the group application sampling data is necessary. EPA approved
facilities chosen for sampling within a group (ranging from 50 percent of small groups to 10
percent of large groups but no more than 100 facilities per group) only if they were
representative, based on industrial activity, significant materials exposed, and geographic
distribution. All data received from samplers were checked and double key punched and
verified during entry.13 At the same time, it is important to understand that the facilities
submitting sampling data were not randomly selected but rather were identified by the group
applicants. These facilities also chose the sampling locations at their sites and conducted
monitoring in accordance with EPA guidance on the selection of suitable locations, storm
events, and methodology.
In addition to the Phase I permit application data, historical data from past studies can
provide some perspective on the nature of storm water from regulated and unregulated
sources. Historical data on storm water quality from various types of sites from NURP and
USGS were presented in Chapter 2. These data were collected from general urban,
commercial, or industrial areas, not from specific industrial facilities. However, these data
do provide useful historical reference points. In particular, the mean and median for the
NURP urban site and USGS commercial sites were chosen for comparison with the new
industry-specific data from permit applications. These levels provide a reference point based
on past studies of the nature of storm water discharges. The pollutant concentrations
observed hi the NURP study should not be considered to be "acceptable" or normal levels of
storm water contamination.
13 Only those applications received before January 1993 are included in the data base used in this analysis.
4-26
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Chapter 4—Individual Phase II Discharges
Permit application data were analyzed for 11 pollutants, including 9 pollutants studied in
NURP—biochemical oxygen demand (BOD), chemical oxygen demand (COD), total
suspended solids (TSS), nitrate plus nitrite nitrogen, total Kjeldahl nitrogen (TKN), total
phosphorus, copper, lead, and zinc—plus oil and grease and pH. As discussed, Table 4-7
reports summary results for the composite mean from the permit application data for 31
Phase I sectors. Appendix F gives more detailed results for each pollutant and each
industrial sector, including the mean, median, and 95th percentile, as well as the number of
samples taken. To provide a basis for comparing across industrial categories, the mean of
the composite sample results was chosen as an indicator of average storm water quality.
Composite samples are preferable to grab samples for comparing average runoff conditions
because grab sample results (also reported hi the tables) may represent pollutant spikes,
rather than more long term average storm conditions. The following paragraphs review these
results.
Conventional
Among the conventional pollutants, total suspended solids appears to be the pollutant
with highest concentration. Half of the Phase I industrial sectors had concentrations higher
than NURP and average results hi the hundreds of parts per million are common. Composite
mean concentrations were over 1,500 mg/1 for mineral mining and for landfills. These data
confirm the result in NURP and other literature that sediment is an important component of
storm water runoff. It should be noted that sediments can also carry additional pollutants,
such as metals and organics. As reported on Table 4-7, COD results for the composite mean
are higher than NURP in about half of the sectors (14 sectors out of 31). The highest
reported composite mean value for COD was 242 mg/1 and five sectors had concentrations
greater than 150 mg/1, including lumber and wood products, scrap and waste materials, metal
mining, railroad transport, and wastewater treatment. All sectors had concentrations higher
than the average of commercial sites found hi USGS studies. Results for BOD indicate that
average runoff quality is not appreciably higher than the secondary treatment standard for
POTWs of 30 mg/1. Although 10 sectors have higher levels of BOD than reported hi NURP
4-27
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Chapter 4—Individual Phase II Discharges
and USGS, the highest composite mean value for BOD was 46 mg/1. Most results for pH
(reported in Appendix F) are hi the range of 6.8 to 8.5, indicating that acidity or alkalinity is
not the greatest concern associated with runoff from these industrial sites. For oil and
grease, composite results are highly variable, and neither NURP nor USGS provides a
baseline for comparison. The highest concentrations, over 5 mg/1, are engaged in industrial
sectors associated with transportation and vehicle and machinery maintenance, as might be
expected.
Nutrients
Overall, storm water discharges from industrial sites do not appear to be contributing
high concentrations of nutrients. Results reported hi Table 4-7 indicate that concentrations
for TKN exceed NURP results hi 22 cases, including wastewater treatment plants, chemical
manufacturers, scrap yards, mining sectors, transportation sectors, and leather manufacturers.
However, most of the results were hi the range of 2 to 5 mg/1. Concentrations (for the
composite mean) over 16 mg/1 were reported for me chemical and allied products sector and
the air transport sector. Concentrations of nitrogen hi the form of nitrates and nitrites for the
industrial sites represented hi the permit application data are generally hi the range of 0.8 to
2.0 mg/1, but there are some important exceptions. The highest concentrations for the
composite mean occurred in the wastewater treatment sector (20.5 mg/1) and the scrap and
waste materials sector (5.9 mg/1). Phosphorus results also do not show generally high
concentrations; only nine sectors had composite mean results over 1 mg/1. The highest
concentrations occurred for chemical and allied products manufacturers (9.5 mg/1), military
facilities (7.1 mg/1), lumber and wood products manufacturers (6.3 mg/1), and oil extractors
(3.4 mg/1). In summary, nutrient concentrations exhibit a mixed pattern across industrial
groups, with some very low and very high results. Results for the two forms of nitrogen and
for phosphorus indicate that storm water discharges of nutrients tend to be site- and pollutant-
specific. That is, discharge of one form of nutrient does not hi general indicate that other
forms are present or suspect, although the chemical and allied products sector is associated
with all three.
4-28
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Chapter 4—Individual Phase II Discharges
Because sampling for metals proceeded on the basis of whether individual facilities had
reason to believe they were present in then- discharge, not all sectors reported results for
metals. Again, referring to Table 4-7, results for copper show that 13 sectors had composite
mean concentrations higher than NURP. The highest of these included the primary metals
sector (2.25 mg/1) and scrap and waste materials (0.63 mg/1). Eight sectors reported no
sampling results for copper. For lead, the table shows that the majority of sectors (15 out of
23) had concentrations below the mean value reported in NURP (0.18 mg/1). However, two
of those with higher concentrations had extremely high values: the highest concentrations of
lead found hi industrial runoff were associated with industrial landfills and dumps (20.6
mg/1) and metal mining (6.1 mg/1). The next highest values came from the scrap and waste
materials sector (.88 mg/1) and the stone, clay, and glass products sector (.25 mg/1). Results
for zinc show that most of the sectors (22 of 25) had composite mean concentrations higher
than the 0.20 mg/1 value reported in NURP for general urban runoff. Nineteen sectors had
concentrations higher than the 0.31 mg/1 value reported in USGS studies for commercial
sites. The highest concentrations found were associated with the primary metals (6.6 mg/1),
metal mining (3.9 mg/1), and scrap and waste materials (3.6 mg/1) sectors. Six sectors did
not report results for zinc. In summary, higher concentrations of metals tended to be
associated with the primary metals sector, metal mining, industrial landfills, scrapyards, and
metal fabricators.
4.2.1.2 Qualitative Assessment of Potential Phase II Categories
The sampling data presented previously were used to assist hi understanding the nature
of storm water discharges hi Phase II sectors. To facilitate comparison of potential Phase II
sources with the sampling results reported above, where possible, categories of Phase II
sources were compared to similar Phase I sectors. These comparisons were made
qualitatively and are not meant to suggest that the sectors conduct exactly the same activities
or operations. Similarities were identified for 12 of the 18 Phase II sectors, as summarized
in Table 4-8. The remaining categories of potential Phase II sources were generally not
4-29
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Chapter 4—Individual Phase n Discharges
classifiable based on similarities to Phase I sources. Using this correspondence to Phase I
and information from the literature review, a summary table was developed showing the
potential pollutants associated with each of the potential Phase II sectors. For some sectors,
permit application data were used as the basis for determining which pollutants could be
present. For other sectors, literature review information and other documents were used.
This information is summarized in Table 4-8, which can be used as a guide to the possible
presence of pollutants at Phase II facilities. This does not indicate that the pollutants will be
found in substantial quantities or that water quality will be impaired. In particular, pollutants
are associated with categories similar to Phase I facilities based on the fact that the Phase I
sector had among the highest (top ten) concentrations of that pollutant. Thus, it is based on
a relative ranking: an industrial category may be among the highest, even when overall
concentrations are not very high.
Based on the literature review, assessments of SIC descriptions, the selection criteria
outlined above, and the pollutant data summarized hi Table 4-8, information about the 18
potential Phase n categories can be summarized into several major groups. The first major
group includes facilities with activities similar to those regulated under Phase I, even though
they may be small commercial or retail establishments, rather than industrial ones. This
class includes about 80 percent of the potential Phase II sources. One of the chief activities
of concern hi this group is vehicle maintenance and related transport, storage, and machine
repair activities. Other activities conducted at these facilities that are substantially similar to
those already regulated include loading and unloading operations, which include pumping of
gases or liquids, pneumatic transfer of dry materials, or transfer of containers to or
from vehicles; outdoor storage, including storage of fuels, raw materials, byproducts,
intermediates, final products, and process residuals or wastes; and other outdoor activities
and land disturbing operations, such as small construction and landscape maintenance. The
types of products or waste materials at facilities in this class could include a wide variety of
materials that potentially contribute pollutants to storm water runoff. Although discharges
could include the whole range of pollutants, these sources may be more likely to contribute
4-30
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Chapter 4—Individual Phase II Discharges
Table 4-8. Correspondence Between Potential Phase II Sectors and Phase I Sectors
and Potential Pollutants of Concern
Description
Phase n "Sectors"
Automotive Service
Machinery & Electrical Repair
Intensive Ag. Chemical Use
Wholesale, Machinery
Laundries
Wholesale, Wood Products
Livestock, Feedlots
Petrol. Pipelines & Distributors
Photographic Activities
Various Utilities
Extensive Ag Chem Use
Transport, Rail and Other
Wholesale, Metal Products
Wholesale, Food
Laboratories
National Security
Munic. Services, Vehicle Maint.
Wholesale, Coal & Ores
Rank by #
of Faculties
369,870
135,744
121,861
77,562
51,376
48,493
43,421
35,319
30,684
22,242
18,992
14,808
14,303
11,372
10,683
4,611
2,414
1,384
Corresp.
to Phase I
Sectors
17, 13
31
NA
30
NA
1
NA
9, Other
NA
11, 12,22
NA
16
14
23
NA
17, 29, 33
17,29
8
Potential Pollutants of Concern
Conventionals
B/COD
S
s
X
s
s
X
s
X
X
X
s
X
TSS
X
s
X
s
X
s
s
s
X
s
X
O&G
X
X
s
X
s
s
X
X
X
Nutrients
N
*
S
S
S
*
*
s
*
*
*
*
p
*
*
s
s
*
s
*
s
*
*
#
Metals
X
X
X
S
X
s
X
X
X
X
Pesticides
& Toxics
S
S
s
s
s
s
s
s
s
X -
s -
NA -
*
Indicates similar Phase I sector ranked in top ten of all sectors for this pollutant class
Indicates pollutant is suspected, based on literature review and expert opinion
Not applicable: No clear correspondence with Phase I Sectors
Overall, nutrient levels were not high in Phase I application data. This indicates that the pollutant was found in
the top ten, but actual concentration levels were not high.
Blanks indicate that such pollutants are not pollutants of concern for the Phase n sectors.
toxics, in addition to conventionals and nutrients. Pollutants of concern include organic and
inorganic chemicals; fuels, such as coal and oil; paints; metals; solvents; and oil and grease.
Although not specifically addressed in this analysis, off-site storage and maintenance
activities, which may be owned and operated by Phase I facilities but are not currently
regulated, could also fall into this class.
The second major classification of facilities includes categories of industrial, commercial,
or retail activities and businesses with discharges that may be similar to those from
agricultural sources (which are exempt from NPDES regulation under the CWA). For
example, smaller feedlots that are not currently regulated and large users of pesticides and
fertilizers may be similar to agricultural discharges but are not specifically exempted by
statute. This class of facilities includes more than 180,000 facilities or about 20 percent of
4-31
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Chapter 4—Individual Phase n Discharges
those selected for study. This group includes lawn and garden services (SIC 0782), farm
supplies (SIC 5191), and lawn and garden supply (SIC 5283), which are among the largest
SIC groups selected for study (see Table 4-4). Fertilizers and pesticides from these facilities
have the potential to contaminate storm water from activities such as land application, spills
and leaks, rinsing of containers and trucks, and improper disposal. Thus, the pollutants of
concern include conventionals, pesticides, and nutrients that are associated with uses of open
space that superficially resemble agricultural uses, such as lawn and landscape care or
commercial/retail production, transport, or storage of nursery products.
The third major class of potential Phase II sources includes categories of facilities with
the potential to use or produce toxic substances but about which there is little information.
Research and development laboratories and some kinds of governmental activity (such as
justice and public order facilities, SIC 92xx) fall into this category. Some of these facilities
may be administrative centers with little potential to discharge pollutants. Others, such as
police and fire protection services, however, may include vehicle maintenance activities with
potential for discharges similar to those described above. This group includes about 20,000
facilities, representing only about 2 percent of those chosen for study.
This section described the categories of facilities and evaluated the nature of potential
pollutant discharges qualitatively based on similarity to Phase I sources and information from
storm water literature. However, from a national perspective, little quantitative information
exists on discharge quality from these potential Phase II sources.
The majority of Group A facilities are so similar to Phase I activities that data collected
from Phase I permit application data may be used to evaluate their pollution potential. There
are also a very few classes of unregulated facilities for which some data is already available.
One category of facilities for which substantial information is currently available is feedlots.
Although feedlots which meet the definition of Concentrated Animal Feeding Operation
(CAFO) are currently subject to NPDES permitting requirements, many smaller feedlots do
4-32
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Chapter 4—Individual Phase II Discharges
not meet the current regulatory definition of CAFO and hence are not subject to current
NPDES regulations.14
The United States Department of Agriculture (USDA) has estimated that there are
approximately 6,000 animal feeding operations with 1,000 or more annual units.15 EPA's
Permit Compliance System (PCS) data base indicates that, as of October of 1994, EPA and
authorized States have individual permits covering 928 CAFOs and general permits covering
at least another 2,130 facilities. The total number of NPDES permits for feedlots is
significantly less than the approximately 6,000 facilities that have more than 1,000 animal
units. The discrepancy between the number of facilities authorized to discharge by NPDES
permits and the total number of feedlots over 1,000 animal units is believed to be due to a
number of factors, including: (1) due to limited State and Federal resources, some feedlots
that should have a permit have not been brought into the NPDES program; (2) some
regulatory authorities misinterpret the Federal regulations for CAFOs and mistakenly exempt
facilities that should have permits; and (3) permits are only required for facilities that
discharge at times other than the event of a 25-year/24-hour storm. USDA estimates that
there are approximately 378,000 animal feeding operations with less than 1,000 animal units
but more than 20 animal units.
Animal feedlots contribute to a significant degree of water quality impairment. States
report the scope and sources of water quality impairments under Sections 305(b) and 319 of
the CWA. Information from these sources indicates that, nationally, feedlots cause 7 percent
14 As discussed in Chapter 1, CAFOs are defined as animal feeding operations that discharge to waters of the
United States at times other than during events greater than a 25-year, 24-hour storm and that: (1) have more than
1,000 animal units; (2) have more than 300 animal units and pollutants are discharged into navigable waters through
a man-made flushing system or other man-made device, or pollutants are discharged directly into waters of the
United States which originate outside of and pass over, across or through the facility or otherwise come into direct
contact with the animals confined in the operation; or (3) are designated by EPA or an authorized NPDES State upon
determining that it is a significant contributor of pollution to the waters of the United States.
15 U.S. Department of Agriculture, Office of Budget and Policy Analysis, Draft Report, 1992. Progress and
Status of Livestock and Poultry Waste Management to Protect the Nation's Waters.
4-33
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Chapter 4—Individual Phase II Discharges
of impairment in lakes and 13 percent of impairments in rivers.16 Feedlot impact is less
significant, on average, in estuaries and ocean coasts, although there are estuaries, such as
the Chesapeake Bay and Puget Sound, where animal waste is a significant water quality
problem. In addition, the U.S. Fish and Wildlife Service estimated in 1984 that feedlots
impair fisheries in nearly 60,000 miles of streams nationally. EPA is unable to identify the
relative contributions to impairment of facilities currently subject to NPDES permits and
those that are not; however, waterbodies have been identified in case studies where
impairment is due to smaller feedlots not subject to permits, e.g., the Chesapeake Bay.
Feedlots produce an estimated 400 million tons of animal waste per year, twice as much
waste as humans produce. These wastes contain ammonia, phosphorus, nitrogen, oxygen
demanding materials, and high levels of pathogenic bacteria. When used properly, animal
wastes are a valuable resource, but when such wastes are discharged into surface or ground
water, they often cause impairment.
High pollutant concentrations can be associated with feedlot runoff. Nutrients, oxygen
demanding materials, and bacteria in runoff from feedlots are often present hi concentrations
that are 10 to 100 tunes those of untreated sanitary sewage17 or combined sewer
overflows.18 Fish kills may result from runoff, wastewater, or manure entering surface
waters, due to ammonia and dissolved oxygen depletion. The decomposition of organic
materials can deplete dissolved oxygen supplies hi water, resulting hi anoxic or anaerobic
conditions. Methane, amines, and sulfide are produced hi anaerobic waters causing the water
to acquire an unpleasant odor, taste, and appearance. Such waters can be unsuitable for
drinking, fishing, and other recreational uses. Solids deposited hi water bodies can
16 Water Pollution from Feedlot Waste: An Analysis of its Magnitude and Geographic Distribution, EPA Feedlot
Workgroup, December 1992.
17 Report of the EPA/State Feedlot Workgroup, EPA Feedlot Workgroup, September 1993.
18 Water Pollution from Feedlot Waste: An Analysis of its Magnitude and Geographic Distribution, EPA Feedlot
Workgroup, December 1992.
4-34
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Chapter 4—Individual Phase II Discharges
accelerate eutrophication through the release of nutrients over extended periods of time.
Animal diseases can be transmitted to humans through contact with animal feces. Animal
waste has been responsible for shellfish contamination in some coastal waters.19 Animal
wastes discharged to waterways perform the same nutritional function for aquatic plants as
they do for field crops, with high levels of nitrogen and phosphorus promoting algae growth
in receiving waters. Pathogens, nitrates, and salts in manure can impair ground water, with
problems being reported in at least 17 States.
4.2.2 Geographic Extent of Facilities
This section addresses the extent of potential Phase II facilities through a geographic
analysis of their location with respect to urbanized areas, regulated Phase I municipalities,
and other population centers. The procedures used to generate this information were
discussed in Chapter 2. This analysis does not provide any information on the quantity or
quality of storm water discharged by these facilities. This is locational data only. Some
facilities may have completely enclosed operations. Some may be connected to sanitary or
combined sewers, rather than to separate storm sewer systems. Finally, some may have few
pollutants of concern in use or in their discharges.
Even so, determining location and geographic distribution lends some valuable insights.
The location of facilities is important for both environmental and for policy reasons. From
an environmental perspective, facilities located in populous, urban, or dense areas may be
larger and more heavily used, with the potential for larger amounts or concentrations of
pollutants to be discharged. At the same time, however, runoff from these urban facilities
may be more likely to discharge to storm or sanitary sewers, where it will mix with other
storm water flows before ultimate discharge to receiving waters. Facilities located in more
rural areas may be no different hi terms of pollutant content but may have a greater potential
for discharging directly into the Nation's waters.
19 Guidance Specifying Management Measures for Sources ofNonpoint Pollution in Coastal Waters, EPA,
January 1993.
4-35
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Chapter 4—Individual Phase II Discharges
From a policy perspective, urban and rural storm water discharges could also be treated
differently. Industrial, commercial, and retail facilities in urban areas will more often fall
within the boundaries of a municipal storm water control program. Thus, any control,
detention, or sampling efforts by municipalities may help to locate and mitigate the impact of
the storm water discharges within their jurisdictions, whether these discharges are federally
regulated or not. The rural discharger, on the other hand, is more likely to be a direct
discharger or to be located in a smaller municipality with no storm water program and, thus,
may be relatively uncontrolled unless located hi a high priority watershed that receives
special State attention.
As discussed in Chapter 2, Phase n of the storm water program could cover additional
commercial sources directly through permitting requirements for individual facilities or
indirectly by requiring local governments to address commercial sources. With respect to the
second approach, there are many ways of expanding control strategies to additional
geographic areas and political jurisdictions, beyond those covered in Phase I. For example,
FJPA could expand regulatory or control requirements to:
• The urbanized fringe around existing Phase I cities
• All urbanized areas not covered in Phase I
_ • Additional cities (incorporated areas) based on size
• Growing areas, where both development pressures and opportunities for preventive
measures are greatest
• Coastal areas, where storm water quality impacts have been identified.
Of course, a combination of options can also be considered, such as urbanized areas in
coastal areas or cities of a certain size hi fast growing counties. To evaluate alternatives,
consideration must be given to how industrial, commercial, and retail establishments are
distributed in different jurisdictions, such as cities or urbanized areas of a certain size. The
analysis on the following pages demonstrates how these various options would affect
4-36
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Chapter 4—Individual Phase II Discharges
industrial and commercial facilities (i.e., what portion of facilities in a given sector would be
covered by a particular geographic approach). This analysis of location was completed for
each of these perspectives. This section presents and discusses results for urbanized areas,
primarily. Other relevant results are discussed hi the text, but full numerical details are
reported hi Appendix G.
As discussed hi Chapter 2, this presentation is based on the premise that individual
commercial and retail activities are distributed similarly to the population at the county level.
That is, if 40 percent of the people hi a county live hi urbanized areas, this analysis assumes
that 40 percent of the industrial, commercial, and retail sources are located in urbanized
areas. This premise may not hold true for activities that are usually located hi rural areas,
such as agricultural or silvicultural operations. However, because rural counties have a
lower proportion of urbanized population, facilities that are commonly located hi rural
counties would be allocated to the non-urbanized portion of the county under this procedure.
Thus, on average on a national scale,20 the premise provides a useful estimation tool even
for typically rural enterprises. This procedure is explained hi more detail in Chapter 2.
The results of the distributional analysis of facilities and SIC-code activities are presented
graphically hi this section. Figure 4-1 shows the geographic distribution of facilities (by
county) hi the 90 selected four-digit SIC codes (potential Phase II) chosen for analysis.
Counties are shaded hi the map based on the number of facilities located hi each. Counties
with more than 1,000 facilities are shown hi black, those with 500 to 999 facilities are shown
hi cross-hatch shading, and those with 250 to 499 facilities are shown hi light shading.
Counties with facility counts lower than 250 are shown hi white but are not outlined.
Figure 4-2 shows similar information, except that counties are shaded on the basis of
density of facilities (facilities per square mile) rather than straight facility counts. The
20 The analysis does not address individual commercial and retail activities that are located in Territories other
than the District of Columbus.
4-37
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Chapter 4—Individual Phase n Discharges
Number of Facilities
0-249
500-999
250-499
1,000+
Figure 4-1. Geographic Distribution of Facilities With Selected 4-Digit SIC Codes
(counties with less than 250 facilities are not shown)
4-38
-------
Chapter 4—Individual Phase II Discharges
6- ,K
.88-10
S.O*
Figure 4-2. Geographic Distribution of Facilities With Selected 4-Digit SIC Codes by
Density (counties with less than .25 facilities per square mile are not shown)
4-39
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Chapter 4—Individual Phase n Discharges
counties with the densest concentrations of facilities are shown in black, counties in the next
density class are shown in cross-hatch shading, and the third density class is shown hi light
shading. Counties in the lowest density class are shown in white, but are not outlined.
As illustrated, the largest numbers and concentrations of facilities occur along the
Eastern Seaboard; the industrialized southern Great Lakes Region; southern Florida; the Gulf
Coast; and major cities of the southwest, California, and the Pacific Northwest. Although
results for density show more focus around population centers, especially in the East and
Midwest, both maps illustrate that potential Phase n facilities, which represent economic
activity in industries, businesses, offices, and government services, are highly associated with.
population centers, in general. The same generalizations apply whether based on numbers of
facilities or density of facilities, indicating that the most populous places tend also to have the
greatest concentrations of potential Phase II facilities.
This geographic information on facility location is also presented quantitatively to lend
additional insights. As described in the approach hi Chapter 2, facility-specific information,
including SIC code and county location, was combined with information from the 1990
census, which includes county population and area. These two sources of data were used to
analyze the geographic distribution of all facilities in all two-digit SIC codes and of the 90
four-digit SIC codes selected as Group B Phase II categories. The results of this analysis are
reported in detail hi Appendix G. This section reviews some of the data and highlights
important findings for the Group B sectors.
Table 4-9 presents information about the geographic distribution of industrial and
commercial facilities hi urbanized areas, based on the location with respect to Phase I cities.
The columns of the table illustrate the locational relationships among jurisdictions when
taking the perspective of expanding from current core (Phase I) cities out to the urbanized
areas surrounding them, then on to remaining urbanized areas. Note that some urbanized
areas encompass Phase I cities, while others are not contiguous with them.
4-40
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Chapter 4—Individual Phase II Discharges
Table 4-9. Geographic Distribution of Potential Phase II Facilities
in Relation to Urbanized Areas
Potential Phase II Faculties Identified
Description
Phase n - Group A
Phase H - Group B
Group B Sectors
Automotive Service
Machinery & Electrical Repair
Intensive Ag. Chemical Use
Wholesale, Machinery
Laundries
Wholesale, Wood Products
Livestock, Feedlots
Petrol. Pipelines & Distributors
Photographic Activities
Various Utilities
Extensive Ag Chem Use
Transport, Rail and Other
Wholesale, Metal Products
Wholesale, Food
Laboratories
Munic. Services, Vehicle Maint
National Security
Wholesale, Coal & Ores
Count
100,000'
1,015,239
Cumulative % of facilities
located within:
Phase I
Areas
32
28
Phase I Areas
+ UAs
45
40
All UAs
61
56
369,870
135,744
121,861
77,562
51,376
48,593
43.4212
35,319
30,684
22,242
18,992
14,808
14,303
11,372
10,683
4,611
2,414
1,384
27
29
26
32
38
26
8
16
40
24
31
47
36
36
38
25
34
23
38
40
38
47
52
36
11
25
53
36
42
64
54
49
56
35
43
31
55
56
54
65
71
53
20
39
70
53
62
81
75
67
74
51
60
48
1 This figure is an approximation based on the total number of facilities in SIC codes 10 through 45 after
subtracting an estimate of the number of facilities covered under Phase I. Geographical distribution information
is based on all facilities in SIC codes 10 through 45 and may not be representative of all classes of facilities in
this group. For the geographic distribution of specific SIC codes, refer to Appendix G.
2 This number is based on SIC codes and does not reflect all feedlots potentially subject to Phase II. The
United States Department of Agriculture has estimated that there are approximately 378,000 animal feeding
operations between 20 and 1,000 animal units. The facilities identified here should be representative of feedlots
hi general and allow estimation of the distribution of these facilities as a class.
The rows of the table show each potential Phase II sector and the proportion of industrial
facilities located in each of the geographic jurisdictions. Other major groups of
industries—all facilities nationally, agricultural and silvicultural categories, manufacturing
categories, and all commercial and retail categories—are included in the table to show by
comparison how the potential Phase II categories are distributed relative to other major
4-41
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Chapter 4—Individual Phase II Discharges
industrial and commercial sectors. As shown in the table, about one-third of the potential
Phase n industrial and commercial facilities within the United States are located within
municipalities already covered under Phase I of the storm water program. As a point of
reference, agricultural and silvicultural activities (SIC Codes Olxx to 09xx) are less often
associated with cities or urban areas. Only about 14 percent of the facilities hi these
agricultural sectors are associated with Phase I cities. Only about half of them are associated
with urban areas, as compared to three-quarters for other more industrial sectors. This
distribution holds also for the Phase II sector containing livestock and feedlot activities.
The table also shows the cumulative effect of expanding control of individual sources
outward from central cities to encompass larger urbanized areas. In general, 30 percent of
facilities are located in regulated Phase I municipalities, an additional 15 percent are located
in the urbanized areas associated with Phase I cities, and an additional 15 percent are found
hi the remaining urbanized areas. Thus, about twice as many industrial facilities are found
hi all urbanized areas as are found hi Phase I cities alone. This result holds for most of the
potential Phase n categories. However, there are some exceptions. Petroleum pipelines and
distributors show a weaker association with urban areas. It also is not surprising that
feedlots are less closely associated with highly urbanized areas.
In another series of analyses, the distribution of industrial facilities was examined
according to other geographic areas of potential interest. The results of these analyses are
reviewed briefly here; Appendix F contains complete results. Urbanized areas of various
population size classes were analyzed. This analysis shows that most facilities (about 45 to
50 percent) are located hi the largest urbanized areas (over 250,000 people). An additional 7
percent are found hi medium UAs (from 100,000 to 250,000 people). An additional 5
percent are found hi UAs containing 50,000 to 100,000 people. These results show that the
majority of facilities are located in the largest UAs and only a small increment is gamed by
including smaller UAs hi the regulatory scenario.
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Chapter 4—Individual Phase II Discharges
For additional perspective on potential Phase II areas of concern, an analysis was
conducted on the relationship between facility distribution and fast growing geographic areas.
This analysis focused on counties expected to grow by more than 15 percent hi the 15 years
between 1990 and 2005 (based on Census Bureau projections).21 The results show that
about a quarter of Phase II facilities are located in these fast-growing counties. Of these,
almost three-quarters are located in urbanized areas.22
Because coastal areas are also a potential concern, as reflected hi the CZARA program,
another analysis addressed the geographic distribution of industrial and commercial facilities
hi coastal counties. The definition used by the National Oceanic and Atmospheric
Administration and the Bureau of the Census of the Department of Commerce is used hi
determining coastal counties. Of the 3,141 counties hi the United States, 672 are defined as
coastal by NOAA and have at least 15 percent of their land area hi a coastal watershed or hi
a coastal cataloging unit (note that this is quite different from the "coastal zone" definition
used hi CZARA). The results reveal that coastal areas represent an important component of
the industrial and commercial base hi the country. As many as 44 percent of the potential
Phase II facilities are located hi coastal areas. Of these, about one-third are hi areas that are
already regulated hi Phase I and almost three-quarters are located hi urbanized areas.
The results hi this section covered the 18 Group B sectors. The detailed results of this
analysis for all two-digit and selected four-digit SIC codes are reported hi Appendix G. The
four-digit analysis provides a more detailed look at certain subsets within the two-digit
groups. Generally, the four-digit breakdowns follow the pattern of the major (two-digit)
groups: for the most part, the additional detail about selected four-digit SICs does not reveal
much beyond that provided by the major group distribution.
21 Note that this designation of "growing counties" differs from that used in Chapter 3.
22 While this result holds in general, petroleum pipelines, wholesale coal and ores, and livestock feedlots appear
to be less closely associated with fast growing areas.
4-43
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Chapter 4—Individual Phase n Discharges
4.3 SUMMARY
This section summarizes the findings on individual sources in terms of the main elements
identified by Congress for discussion in this report: identification, nature and extent of
unregulated discharges. Due to very limited national data on which to base loadings
estimates, the discussion of the extent of unregulated storm water discharges is limited to an
analysis of the number and geographic distribution of potential Phase II facilities.
4.3.1 Identification of Phase n Sources
The effort to identify sources and categories of storm water discharges for which permits
are not required in Phase I of the program resulted in the identification of two general classes
of facilities. The first group includes sources that are very similar or identical to Phase I
activities but that were omitted from Phase I for a variety of statutory and regulatory reasons
(Group A). The second general class of facilities were identified on the basis of potential
activities and pollutants that may contribute to storm water contamination (Group B). The
report also discussed general sources of storm water contamination which are widespread and
not necessarily associated with specific activities or facilities.
Although the difficulty hi differentiating Group A facilities from existing Phase I
regulated activities makes quantitative analysis difficult, EPA estimates that there are
approximately 100,000 facilities in this group. Facilities in Group A, which may be of high
priority for Phase n due to their similarity to Phase I industrial facilities, are described and
categorized in this report but are not included hi the subsequent geographical analysis hi the
same level of detail as Group B facilities. Activities identified hi Group A can be classified
into three distinct categories: auxiliary or secondary activities such as vehicle maintenance in
support of an unregulated activity; facilities which are related to Phase I facilities but that
were intentionally omitted such as POTWs with a capacity of less than 1 MGD; and facilities
which were specifically exempted from Phase I by the Transportation Act which include
industrial activities owned or operated by municipalities of less than 100,000 population.
4-44
-------
Chapter 4—Individual Phase II Discharges
Group B consists of over one million facilities in 90 SICs. These 90 SIC categories
have been organized into 18 Phase II sectors for the purposes of this report. Of these 18
sectors, the automobile service sector (comprised of gas/service stations (SIC 5541), general
automobile repair (SIC 7538), top, body repair (SIC 7532), repair shops and services (SIC
7699), car dealers, new & used (SIC 5511), car dealers, used only (SIC 5521), car washes
(SIC 7542), passenger car rental (SIC 7514), track rental (SIC 7513), parking structures (SIC
7521), and miscellaneous auto services (SIC 7549)), make up more than one-third of the total
number of facilities identified hi all 18 sectors.
Other general sources of storm water discharges discussed but not clearly identified in
the report include parking lots, trash dumpsters, leaking and failing septic systems, and
activities related to individual residences such as fertilizer and pesticide application.
Facilities in the service sectors, such as banking, finance, insurance firms, and all types of
food services, were also discussed but not included hi much of the analysis.
4.3.2 Nature of Phase II Sources
There is little quantitative or comprehensive data from a national perspective on the
concentrations and loadings of storm water discharges from the industrial, commercial, and
retail facilities selected for study as potential Phase II sources. As a result, it is not currently
possible to estimate national concentrations or loadings from these sources. It is clear,
however, that a significant number of facilities remain hi unregulated Phase II categories that
conduct operations that have the potential to discharge contaminated storm water. It is
possible to classify the unregulated categories into three major groups:
All of the potential Phase II facilities hi Group A may have discharges similar or
identical to discharges associated with industrial activity regulated under Phase I.
Of the facilities in Group B, 80 percent may have discharges similar or identical to
discharges associated with industrial activity regulated under Phase I. Facilities in this
class have activities analogous to Phase I activities but are covered by different SIC
codes. These facilities are also likely to employ substances that could result hi
4-45
-------
Chapter 4—Individual Phase II Discharges
pollutants, such as toxics, metals, solvents and oil and grease, entering storm
water.23 This class includes wholesale operations and vehicle repair and maintenance
categories.
Almost 20 percent of the facilities in Group B had activities that resemble exempted
agricultural sources but do not fall under the statutory exclusion of agriculture. These
include smaller, currently unregulated feedlots, nurseries, and retailers of farm supply
chemicals. Facilities in this class are likely to have activities that result hi
contributions of pesticides or fertilizers and nutrients to storm water.
In general, industries with large areas of industrial activity and significant materials
exposed to storm water exhibited the highest concentrations of pollutants in their storm water
discharges. Suspended solids, which can also carry metals and organic pollutants, appear to
be the pollutant with the highest concentrations overall. Chemical oxygen demand appears at
relatively high concentration levels in some industrial sectors. Oil and grease results were
highly variable but highest hi industrial sectors associated with transportation and vehicle and
machinery maintenance. Results for metals varied across industrial sectors, but those that
handle, process, manufacture, or mine metals, as well as landfills, had higher concentrations
than other categories. Biochemical oxygen demand, and nutrients (nitrogen and phosphorus)
were generally not found at high concentration levels hi Phase I data, although results were
variable for nutrients.
4.3.3 Geographic Distribution
The geographical analysis shows that the majority of industrial and commercial facilities
are located hi or near population centers (cities and other urban places). To the extent that
they are located hi populous, urbanized areas, they are more likely to be served by municipal
storm sewers (either separate or combined) than to be discharging directly to streams.
23 About 2 percent of these facilities conduct other activities that may use toxic pollutants but are not
substantially similar to the other facilities in this group. These include research laboratories and some kinds of
municipal or governmental entities, which may engage in a wide variety of activities. There is very little information
available about the pollution potential of facilities in this class.
4-46
-------
Chapter 4—Individual Phase II Discharges
In general, about 30 percent of potential Phase II facilities are found within the
geographic jurisdiction of a Phase I municipality. An additional 20 to 30 percent of Phase II
facilities fall into Census-designated urbanized areas. Thus, nearly twice as many industrial
facilities are found hi all urbanized areas as are found hi Phase I municipalities alone.
Notable exceptions to these generalizations include lawn/garden establishments, feedlots,
wholesale livestock, farm and garden machinery repair, bulk petroleum wholesale, farm
supplies, lumber and building materials, and petroleum pipelines, which are (relatively) more
frequently associated with smaller municipalities or rural areas. Because a larger portion of
these facilities are outside the confines of regulated municipalities, a larger portion of storm
water discharges from these facilities may be going directly to receiving waters rather than
into municipal separate storm sewer systems.
4-47
-------
-------
BIBLIOGRAPHY
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10
-------
APPENDIX A
LIST OF PHASE I MUNICIPAL SEPARATE STORM SEWER SYSTEMS
-------
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places)
State
Alaska
Alabama
A rlfun^fl^
Place Name
Anchorage city*
Adamsville city
Alabaster city
Bessemer city
Birmingham city*
Brighton city
Brookside town
Chickasaw city
Creola city
Daphne city
Fairfield city
Fairhope city
Fultondale city
Gardendale city
Graysville city
Helena city
Homewood city
Hoover city
Hueytown city
Huntsville city*
Indian Springs
Irondale city
Leeds city
Lipscomb city
Madison city
Maytown town
Midfield city
Mobile city*
Montgomery city*
Moody town
Mountain Brook city
Mulga town
Pelham city
Pleasant Grove city
Prichard city
Saraland city
Satsuma city
Tarrant city
Trussville city
Vestavia Hills city
T ittle RnrV Htv*
Population
226,338
4,161
14,732
33,497
265,968
4,518
1,365
6,649
1,896
11,290
12,200
8,485
6,400
9,251
2,241
3,918
22,922
39,788
15,280
159,789
NA
9,454
9,946
2,892
14,904
651
5,559
196,278
187,106
4,921
19,810
261
9,765
8,458
34,311
11,751
5,194
8,046
8,266
19,749
175 7Q5
Area (sq.mi.)
1697.65
3.07
18.85
38.70
148.49
1.40
2.38
3.58
14.60
11.03
3.36
7.70
7.57
15.14
2.79
13.73
7.37
23.85
8.65
164.39
NA
8.83
21.48
1.15
20.01
2.74
2.45
118.03
134.98
11.05
11.61
0.19
13.80
6.17
25.39
11.40
5.97
6.36
14.84
8.83
102.86
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-l
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
Arizona
California
Place Name
Mesa city*
Mesa city*
Phoenix city*
Tempe city*
Tucson city*
Agoura Hills city
Alameda city
Albany city
Alhambra city
Anaheim city*
Arcadia city
Artesia city
Atherton town
Azusa city
Bakersfield city*
Baldwin Park city
Bell city
Bellflower city
Bell Gardens city
Belmont city
Berkeley city*
Beverly Hills city
Big Bear Lake city
Bradbury city
Brisbane city
Burbank city
Burlingame city
Camarillo city
Campbell city
Carlsbad city
Carson city
Cerritos city
Chula Vista cityt
Claremont city
Colma town
Commerce city
Compton city
Concord city
Contra Costa county (15 cities)
Coronado city
Population
288,091
288,091
983,403
141,865
405,390
20,390
76,459
16,327
82,106
266,406
48,290
15,464
7,163
41,333
174,820
69,330
42,355
34,365
61,815
24,127
102,724
31,971
5,351
829
2,952 .
93,643
26,801
52,303
36,048
63,126
83,995
53,240
135,163
32,503
1,103
12,135
90,454
111,348
-553,831
26,540
Area (sq.mi.)
108.59
108.59
419.91
39.52
156.29
8.17
10.75
1.70
7.62
44.28
10.88
1.62
4.89
9.00
91.84
6.60
2.51
2.56
6.08
4.53
10.46
5.68
6.24
1.67
3.33
17.35
4.35
18.44
5.61
37.67
18.84
8.61
28.99
11.01
1.90
6.53
10.17
29.47
~ 172.65
7.71
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-2
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
California
(continued)
Place Name
Covina city
Cudahy city
Culver City city
Cupertino city
Daly City city
Del Mar city
Diamond Bar city
Downey city
Duarte city
Dublin city
East Palo Alto city
El Cajon city
El Monte cityt
El Segundo city
Emeryville city
Encinitas city
Escondido cityt
Fairfield city
Fillmore city
Folsom city
Foster City city
Fremont city*
Fresno city*
Fullerton city*
Gait city
Gardena city
Garden Grove city*
Gilroy city
Glendale city*
Glendora city
Half Moon Bay city
Hawaiian Gardens city
Hawthorne city
Hayward cityt
Hermosa Beach city
Hidden Hills city
Hillsborough town
Huntington Beach city*
Huntington Park city
Imperial Beach city
Industry city
Inglewood cityt
Irvine cityt
Population
43,207
22,817
38,793
40,263
92,311
4,860
53,672
91,444
20,688
23,229
23,451
88,693
106,209
15,223
5,740
55,386
108,635
77,211
11,992
29,802
28,176
173,339
354,202
114,144
8,889
143,050
49,847
31,487
180,038
47,828
8,886
13,639
71,349
111,498
18,219
1,729
10,667
181,519
56,065
26,512
631
109,602
110,330
Area (sq.mi.)
6.90
1.10
5.10
10.30
7.51
1.77
15.09
12.44
7.21
8.56
2.55
14.41
9.50
5.55
1.22
17.95
35.64
35.85
2.64
21.43
3.76
77.03
99.14
22.12
5.60
17.94
5.28
10.26
30.61
19.47
6.47
0.95
5.93
43.45
1.43
1.62
6.22
26.42
3.05
4.25
11.56
9.17
42.32
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-3
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
California
(continued)
Place Name
Irwindale city
La Canada Flintridge city
Laguna Beach city
La Habra Heights city
Lakewood city
La Mesa city
La Mirada city
La Palma city
La Puente city
La Verne city
Lawndale city
Lemon Grove city
Livermore city
Lomita city
Long Beach city*
Los Alamitos city
Los Altos city
Los Altos Hills town
Los Angeles city*
Los Gates town
Lynwood city
Manhattan Beach city
Maywood city
Menlo Park city
Millbrae city
Milpitas city
Modesto city*
Monrovia city
Montebello city
Monterey Park city
Monte Sereno city
Moorpark city
Moreno Valley cityt
Mountain View city
National City city
Newark city
Norwalk city
Oakland city*
Oceanside cityf
Ojai city
Ontario cityf
Orange cityt
Orange county (17 cities)
Population
1,050
19,378
23,170
6,226
73,557
52,931
40,452
15,932
36,955
30,897
27,331
23,984
56,741
19,382
429,433
11,676
7,514
26,303
3,485,398
27,357
61,945
32,063
27,850
28,040
20,412
50,686
164,730
35,761
3,287
59,564
60,738
25,494
118,779
67,460
54,249
37,861
94,279
372,242
128,398
7,613
133,179
110,658
-841,825
Area (sq.mi.)
9.32
8.67
8.68
6.37
9.39
9.22
7.85
1.82
3.49
7.79
1.98
3.79
19.63
1.89
50.02
4.03
8.42
6.37
469.34
10.38
4.86
3.93
1.17
10.06
3.21
13.76
30.18
13.37
1.61
8.26
7.64
12.26
49.13
12.03
7.57
13.96
9.76
56.06
40.67
4.43
36.75
23.34
-179.74
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rale
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-4
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
California
(continued)
Place Name
Oxnard city*
Pacifica city
Palo Alto city
Palos Verdes Estates city
Paramount city
Pasadena city*
Pico Rivera city
Piedmont city
Pleasanton city
Pomona cityt
Port Hueneme city
Poway city
Rancho Cucamonga cityf
Rancho Palos Verdes city
Redondo Beach city
Redwood City city
Riverside city*
Riverside county (10 cities)
Rolling Hills city
Rolling Hills Estates city
Rosemead city
Sacramento city*
Salinas cityf
San Bernardino city*
San Bernardino county (13 cities)
San Bruno city
San Carlos city
San Diego city*
San Dimas city
San Fernando city
San Gabriel city
San Jose city*
San Leandro city
San Marcos city
San Marino city
San Mateo city
Santa Ana city*
Santa Clara
Santa Clarita cityf
Santa Fe Springs city
Santa Monica city
Santa Paula city
Population
142,216
37,670
55,900
13,512
47,669
131,591
59,177
10,602
50,553
131,723
20,319
43,516
101,409
41,659
60,167
66,072
226,505
-161,120
7,789
1,871
51,638
369,365
108,777
164,164
-558,047
38,961
26,167
1,110,549
32,397
22,580
37,120
782,248
68,223
38,974
12,959
85,486
293,742
93,613
110,642
15,520
86,905
25,062
Area (sq.mi.)
24.44
12.64
23.68
4.81
4.70
22.99
7.98
1.68
16.21
22.83
4.43
39.28
37.81
13.66
6.28
19.04
77.68
-133.44
3.54
3.05
5.12
96.29
18.63
55.08
-231.35
6.43
5.63
324.00
15.52
2.39
4.14
171.26
13.11
23.19
3.77
12.21
27.09
18.30
40.48
8.67
8.27
4.60
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-5
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
California
(continued)
Colorado
Connecticut
District of
Columbia
Delaware
Place Name
Santee city
Saratoga city
Seal Beach city
Sierra Madre city
Signal Hill city
Simi Valley cityf
Solana Beach city
South El Monte city
South Gate city
South Lake Tahoe city
South Pasadena city
South San Francisco city
Stockton city*
Suisun City city
Sunnyvale city*
Temple City city
Thousand Oaks cityf
Torrance city*
Union City city
Vallejo cityt
Vernon city
Vista city
Walnut city
West Covina city
West Hollywood city
Westlake Village city
Whittier city
Woodside town
Aurora city*
Colorado Springs city*
Denver city*
Lakewood city*
Pueblo city
Stamford city*
Washington city*
Arden village
Ardencroft village
Ardentown village
Bellefonte town
Delaware City city
Elsmere town
Middletown town
Population
52,902
28,061
25,098
10,762
8,371
100,217
12,962
20,850
86,284
21,585
23,936
54,312
210,943
22,686
117,229
31,100
104,352
133,107
53,762
109,199
152
71,872
29,105
96,086
36,118
7,455
77,671
5,035
222,103
281,140
467,610
126,481
98,640
108,056
606,900
477
282
325
1,243
1,682
5,935
3,834
Area (sq.mi.)
15.87
11.97
11.72
3.00
2.22
33.03
3.52
2.89
7.35
10.06
3.43
8.96
52.57
3.56
21.90
4.01
49.56
20.52
18.76
30.22
4.93
17.94
8.86
16.20
1.88
5.21
12.53
11.74
132.53
183.19
153.28
40.80
35.90
37.72
61.41
0.27
0.11
0.17
0.18
1.24
0.98
3.41
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
f 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-6
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
Delaware
(continued)
Florida
Place Name
Newark city
New Castle city
Newport town
Odessa town
Townsend town
Wilmington city
Atlantis city
Auburndale city
Bartow city
Belle Glade city
Boca Raton city
Boynton Beach city
Briny Breezes town
Broward County (24 cities)
Century town
Clearwater city
Cloud Lake town
Dade County (19 cities)
Davenport city
Delray Beach city
Dundee town
Eagle Lake city
Fort Lauderdale city*
Fort Meade city
Frostproof city
Glen Ridge town
Golf village
Golfview town
Greenacres City city
Gulf Stream town
Haines City city
Haverhill town
Hialeah city*
Highland Beach town
Highland Park village
Hillcrest Heights town
Hollywood city*
Homestead city
Hypoluxo town
Jacksonville city*
Juno Beach town
Jupiter town
Jupiter Inlet Colony town
Population
25,098
4,837
1,240
303
322
71,529
1,653
8,858
14,716
60
61,492
46,194
400
1,050,742
1,989
98,784
121
886,235
1,529
47,181
2,335
1,758
149,377
4,976
2,808
207
234
153
18,683
11,727
11,683
1,058
188,004
3,209
155
221
121,697
26,866
830
635,230
2,121
405
24,986
Area (sq.mi.)
8.62
2.22
0.37
0.44
0.21
10.78
1.35
4.10
8.59
0.06
27.19
15.14
0.07
322.96
3.28
24.88
0.06
118.42
1.47
14.84
3.10
0.72
31.36
3.17
2.39
0.23
0.83
0.16
4.05
2.84
8.01
0.52
19.24
0.49
0.45
0.16
27.26
11.61
0.60
758.67
1.08
0.18
13.11
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-7
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
Florida
(continued)
Place Name
Lake Alfred city
Lake Clarke Shores town
Lake Hamilton town
Lakeland city
Lake Park town
Lake Wales city
Lake Worth city
Lantana town
Longboat Key town
Manalapan town
Mangonia Park town
Miami city*
Miramar city
Mulberry city
North Palm Beach village
North Port city
Ocean Ridge town
Orange County (8 cities)
Orlando city*
Pahokee city
Palm Beach town
Palm Beach Gardens city
Palm Beach Shores town
Palm Springs village
Pembroke Pines city
Pennsuee
Pensacola city
Pinellas County (21 cities)
Plant City city
Polk City town
Riviera Beach city
Royal Palm Beach village
St. Petersburg city*
Sarasota city
Seminole city
South Bay city
South Palm Beach town
Tallahassee ciryf
Tampa city*
Temple Terrace city
Tequesta village
Venice city
West Palm Beach city
Population
3,622
3,364
1,128
6,704
9,670
28,564
70,576
8,392
5,937
312
1,453
358,548
40,663
2,988
11,343
11,973
1,570
239,522
164,693
6,822
22,965
1,040
9,814
9,763
65,452
NA
58,165
586,612
66,692
1,439
27,639
14,589
238,629
50,961
9,251
3,558
1,480
124,773
280,015
16,444
4,499
16,922
67,643
Area (sq.mi.)
2.52
0.98
3.03
1.80
6.40
5.62
38.39
2.28
4.92
0.45
0.71
35.57
29.67
2.87
3.31
74.78
0.86
103.68
67.27
5.34
26.28
0.25
3.93
1.33
31.94
NA
22.64
NA
21.75
0.59
7.49
8.81
59.19
14.62
2.25
1.93
0.13
63.27
108.67
4.94
1.71
7.42
49.33
NOTE: Unless Indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-8
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
Georgia
Iowa
Idaho
Illinois
Place Name
Winter Haven city
Acworth city
Alpharetta city
Atlanta city*
Austell city
Bloomingdale city
Buford city
Chamblee city
Clarkston city
College Park city
Columbus city*
Decatur city
Doraville city
Duluth city
East Point city
Fairburn city
Forest Park city
Garden City city
Hapeville city
Jonesboro city
Kennesaw city
Lawrenceville city
Lilburn city
Lithonia city
Macon city*
Marietta city
Morrow city
Norcross city
Palmetto city
Pooler city
Powder Springs city
Riverdale city
Roswell city
Savannah city*
Smyrna city
Snellville city
Stone Mountain city
Sugar Hill city
Thunderbolt town
Union City city
Cedar Rapids city*
Davenport city
Des Moines city*
Boise City city*
Garden City city
Rockford city*
Population
24,725
4,519
13,002
394,017
4,173
2,271
8,771
7,668
5,385
20,457
178,681
17,336
7,626
9,029
34,402
4,013
16,925
7,410
-5,483
3,635
8,936
16,848
9,301
2,448
106,612
44,129
5,168
5,947
2,612
4,453
6,893
9,359
47,923
137,560
30,981
12,084
6,494
4,557
2,786
8,375
108,751
95,333
193,187
125,738
6,369
139,426
Area (sq.mi.)
12.19
4.63
19.02
131.78
4.97
9.23
13.35
3.14
1.05
9.70
216.14
4.16
3.58
7.39
13.76
4.46
8.59
5.10
2.37
2.40
5.58
12.34
6.20
0.79
47.88
20.38
2.83
3.92
5.02
11.07
5.35
4.10
32.57
62.59
11.37
9.13
1.62
5.91
1.28
8.04
53.46
61.36
75.26
46.13
3.33
NOTE: Unless indicated otherwise, municipalities have been designated
* Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated
NA Not available
A-9
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
Indiana
Kansas
Kentucky
Louisiana
Massachusetts
Maryland
Michigan
Minnesota
Missouri
Mississippi
Nebraska
New Mexico
Nevada
Place Name
Fort Wayne city*
Indianapolis city*
Kansas City city*
Topeka city*
Wichita city*
Lexington-Fayette*
Louisville city*
Baton Rouge city*
Gretna city
Harahan city
Kerner city
New Orleans city*
Shreveport city*
Westwego city
Boston city*
Lowell city
Worcester city*
Baltimore city*
Aberdeen
Annapolis
Bowie
Bel Air
Havre de Grace
Takoma Park city
Ann Arbor city*
Flint city*
Grand Rapids city*
Sterling Heights city*
Warren city*
Minneapolis city*
St. Paul city*
Independence city*
Kansas City city*
Springfield city*
Jackson city*
Lincoln city*
Omaha city*
Albuquerque city*
Henderson city
Las Vegas city*
North Las Vegas city
Reno city*
Sparks city
Population
173,072
731,327
149,767
119,883
304,011
225,366
269,063
219,531
17,208
9,927
72,033
496,938
198,525
11,218
574,283
103,439
169,759
736,014
13,087
33,187
8,860
37,589
8,952
16,700
109,592
140,761
189,126
117,810
144,864
368,383
272,235
112,301
435,146
140,494
196,637
191,972
335,795
384,736
64,942
258,295
47,707
133,850
53,367
Area (sq.mi.)
62.66
361.67
107.79
55.16
115.14
284.52
62.11
73.95
3.2
1.98
15.13
180.65
98.61
3.19
48.42
13.78
37.56
80.81
5.29
6.33
2.57
12.86
3.31
2.01
25.90
33.83
44.26
36.64
34.28
54.93
52.79
78.19
311.53
67.95
109.01
63.29
100.65
132.20
71.54
83.29
60.97
57.50
14.25
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified hi November 1990 rule
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-10
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
New York
North
Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Place Name
New York city*
(Bronx Borough)
(Brooklyn Borough)
(Manhattan Borough)
(Queens Borough)
(Staten Island Borough)
Charlotte city*
Durham city*
Fayetteville city
Greensboro city*
Raleigh city*
Winston-Salem city*
Akron city*
Cincinnati city*
Cleveland city*
Columbus city*
Dayton city*
Toledo city*
Oklahoma City city*
Tulsa city*
Banks city
Barlow city
Beaverton city
Cornelius city
Durham city
Eugene city*
Fairview city
Forest Grove city
Gaston city
Gladstone city
Gresham city
Happy Valley city
Hillsboro city
Johnson City city
King City city
Lake Oswego city
Milwaukee city
North Plains city
Portland city*
Rivergrove city
Sherwood city
Tigard city
Tualatin city
West Linn city
Wilsonville city
Allentown city*
Philadelphia city*
Population
7,322,564
395,934
136,611
75,695
183,521
207,951
143,485
223,019
364,040
505,616
632,910
182,044
332,943
444,719
367,302
563
118
53,310
6,148
748
112,669
2,391
13,559
563
10,152
68,235
1,519
37,520
586
2,060
30,576
18,692
972
437,319
294
3,093
29,344
15,013
16,367
7,106
105,090
1,585,577
Area (sq.mi.)
308.95
174.26
69.27
40.60
79.79
88.13
71.12
62.19
77.22
77.02
190.92
55.00
80.57
608.16
183.52
0.33
0.06
13.82
1.79
0.43
38.04
3.16
40.22
2.45
22.06
2.30
19.26
0.06
0.41
9.54
4.76
1.63
4.69
0.18
.13
3.21
10.19
7.10
6.63
6.39
17.71
135 13
NOTE:
Unless indicated otherwise, municipalities have been designated.
• Identified in November 1990 rule.
t 1990 Census population increased to over 100,000 and municipality has been designated
NA Not available
A-ll
-------
Appendix A
List of Phase I Municipal Separate Storm Sewer Systems (Incorporated Places) (continued)
State
South Dakota
Tennessee
Texas
Utah
Virginia
Washington
Wisconsin
Place Name
Sioux Falls city
Belle Meade city
Berry Hill city
Chattanooga city*
Forest Hills city
Goodlettsville city
Knoxville city*
Lakewood city
Memphis city*
Nashville-Davidson city*
Oak Hill city*
Ridgetop town
Abilene cityt
Amarillo city*
Arlington city*
Austin city*
Beaumont city*
Corpus Christi city*
Dallas city*
El Paso city*
Fort Worth city*
Garland city*
Houston city*
Irving city*
Laredo cityt
Lubbock city*
Mesquite cityt
Pasadena city*
Piano cityt
San Antonio city*
Waco city*
Salt Lake City city*
Chesapeake city*
Hampton city*
Newport News city*
Norfolk city*
Portsmouth city*
Roanoke city
Virginia Beach city*
Seattle city*
Tacoma city*
Madison city*
Milwaukee city*
Population
100,814
2,839
802
152,466
4,231
11,219
165,121
2,009
610,337
488,374
4,301
1,132
106,654
157,615
261,721
465,622
114,323
257,453
1,006,877
515,342
447,619
180,650
1,630,553
155,037
122,899
186,206
101,484
119,363
128,713
935,933
103,590
159,936
151,976
133,793
170,045
261,229
103,907
96,397
393,069
516,259
176,664
191,262
628,088
Area (sq.mi.)
45.05
3.14
0.90
118.43
9.28
13.65
77.25
0.96
256.04
473.33
7.88
1.49
103.09
87.93
93.00
217.78
80.06
134.97
342.41
245.36
281.08
57.35
539.88
67.62
32.87
104.11
42.84
43.77
66.25
333.03
75.79
109.02
340.68
51.82
68.34
53.76
33.14
42.90
248.32
83.89
48.05
57.76
96.08
NOTE: Unless indicated otherwise, municipalities have been designated.
* Identified in November 1990 rule
t 1990 Census population increased to over 100,000 and municipality has been designated.
NA Not available
A-12
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Appendix A
List of Phase I Municipal Separate Sewer Systems (Counties)
State
Alabama
Arizona
California
Colorado
Delaware
Florida
County
Baldwin county1
Jefferson county1
Mobile county2
Shelby county3
St. Clair county4
Pima County*
Alameda County*
Contra Costa County*
Kern County*
El Dorado County
Fresno County
Los Angeles County*
Orange County*
Placer County
Riverside County*
Sacramento County
San Bernardino County*
San Diego County*
San Mateo County
Santa Clara County
Ventura County
Arapahoe Countyt
New Castle County*
Broward County*
Dade County*
Escantbia County*
Hillsborough County*
Lee Countyt
Manatee Countyt
Orange County*
Palm Beach County*
Pasco Countyt
Pinellas County*
Polk County*
Sarasota County*
Seminole Countyt
Unincorporated/
Urbanized Population
0
78,608
45,418
16,148
0
162,202
115,082
131,815
128,504
0
48,863
886,780
223,081
10,564
166,509
594,889
162,202
250,414
50,250
75,464
41,020
103,248
296,996
142,329
1,014,504
167,463
398,593
102,337
123,828
378,611
360,553
148,907
255,772
121,528
172,600
127,873
Total
Population
98,380
651,525
378,643
99,358
50,009
666,880
1,279,182
803,732
543,447
125,995
667,490
8,863,164
2,410,556
172,796
1,170,413
1,041,219
1,418,380
2,498,016
649,623
1,497,577
669,016
391,511
441,946
1,255,488
1,937,094
262,798
834,054
335,113
211,707
677,491
863,518
281,131
851,659
405,382
277,776
287,529
County was listed in regulation; however, population dropped below 100,000 in 1990 census.
2 Unincorporated areas defined as: beginning at the mouth of the South Fork Deer River and extending west to SW comer Section 18, Township 6 South, Range 2 West, thence
north to NW corner, Section 6, Township 2 South, Range 2 West, thence east to the Mobile County line, thence south along the county line to U.S. Highway 90 bridge.
3 All unincorporated areas of Shelby County within die drainage basin of the Cahaba River upstream of the confluence of Shoal Creek and file Cahaba River.
4 Unincorporated areas of St Clair County within the drainage basin of the Cahaba River.
'•'Identified in November 1990 rule
f!990 Census unincorporated, urbanized population increased to more than 100,000 and municipality has been designated.
A-13
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Appendix A
List of Phase I Municipal Separate Sewer Systems (Counties) (continued)
State
Georgia
Hawaii
Kentucky
Louisiana
Maryland
North Carolina
Nevada
Oregon
South Carolina
Texas
Utah
Virginia
Washington
County
Bibb County
Chatham County
Clayton County*
Cobb County*
DeKalb County*
Fulton Countyt
Gwinnett Countyt
Muscogee County
Richmond County*
Honolulu County*
Jefferson County*
East Baton Rouge Parishf
Jefferson Parish*
Anne Arundel County*
Baltimore County*
Carroll County
Charles County
Frederick County
Harford County
Howard Countyt
Montgomery County*
Prince George's County*
Washington County
Cumberland County*
Clark County*
Washoe County
Clackamas County
Multnomah County
Washington County*
Greenville County*
Richland County*
Harris County*
Salt Lake County*
Arlington County*
Chesterfield County*
Fairfax County*
Henrico County*
Prince William Countyt
King County*
Pierce County*
Snohomish County*
Unincorporated/
Urbanized Population
19,340
40,649
133,237
322,595
448,686
127,776
237,305
0
126,476
114,506
239,430
102,539
331,307
344,654
627,593
0
0
14,100
82,302
157,972
599,028
494,369
28,321
146,827
327,618
26,530
65,088
52,923
116,687
147,464
130,589
729,206
270,989
170,936
174,488
760,730
201,367
157,131
520,468
258,530
157,218
Total
Population
149,976
216,935
182,052
447,745
545,837
648,951
352,910
179,278
189,719
836,231
664,937
380,105
448,306
427,239
692,134
123,372
101,154
150,208
182,132
187,328
757,027
729,268
121,393
274,566
741,459
254,667
278,850
583,887
311,554
320,167
285,720
2,818,199
725,956
170,936
209,274
818,584
217,881
215,686
1,507,319
586,203
465,642
identified in November 1990 rule
t!990 Census unincorporated, urbanized population increased to more than 100,000 and municipality has been designated.
A-14
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Appendix A
List of Municipal Separate Storm Sewer Systems (Boundaries Not Defined by Census)
State
Alaska
Alabama
Arizona
California
Colorado
Delaware
Florida
Hawaii
Idaho
Illinois
Indiana
Kansas
Louisiana
Maryland
Michigan
Minnesota
North Carolina
Nevada
New Mexico
Ohio
Municipal Separate Storm Sewer System
DOT1
University of Alaska
Port of Anchorage
Highway Department
DOT
Alameda County Flood Control District
Zone 7 of the Alameda County Flood Control District
DOT
Calabases Flood Control District
Coachella Valley Area
Contra Costa County Flood Control District
Fresno Metro Flood Control District
Malibu Flood Control District
Orange County Flood Control District
Riverside Flood Control District
San Bernardino Flood Control District
San Diego Unified Port District
Santa Clara Valley Water District
DOT
Highway Department
DOT
DOT
Reedy Creek Improvement District
DOT
DOT
DOT
DOT
Kaw Valley Drainage District
DOT
.Louisiana State University
Southern University
State Highway Administration
University of Michigan
DOT
DOT
Herrepin County Public Works
Minneapolis Parks and Recreation
University of Minnesota
DOT
Clark County Flood Control District
DOT
Albuquerque Metropolitan Flood Control Authority
DOT
DOT
1 Department of Transportation
A-15
-------
Appendix A
List of Municipal Separate Storm Sewer Systems (Boundaries Not Defined by Census)
(continued)
State
Oklahoma
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Utah
Washington
Wisconsin
Municipal Separate Storm Sewer System
DOT
Turpike Authority
DOT
Port of Portland
Multhomah County Drainage Districts (3)
DOT
Harbor of Charleston
DOT
Harris County Flood Control District
DOT
University of Texas- Arlington
University of Texas-Austin
DOT
DOT
DOT
University of Wisconsin
A-16
-------
APPENDIX B
OVERVIEW OF IMPACTS FROM STORM WATER DISCHARGES
-------
-------
Appendix B
APPENDIX B - OVERVIEW OF IMPACTS FROM STORM WATER DISCHARGES
This appendix provides an overview of the types of impacts that storm water discharges
have on receiving waters. Section B.I describes the role of storm water discharges and the
physical nature of storm water discharges. Section B.2 discusses the types of adverse impacts
on receiving waters caused by storm water discharges. Section B.3 gives a general
description of adverse impacts on various types of receiving waters that may be associated
with storm water discharges.
B.1 THE PHYSICAL NATURE OF STORM WATER DISCHARGES
B.1.1 The Hvdrologic Cycle
The hydrologic cycle is the continuous, unsteady circulation of water from the atmosphere
to the Earth's surface and back to the atmosphere. Major features of the hydrologic cycle
include precipitation, snow melt, surface runoff and drainage, infiltration, interflow, ground
water recharge, and evapotranspiration. Each of these factors is discussed briefly below:
• Precipitation—Precipitation occurs as rain, sleet, hail, and snow. Precipitation is one
of the key factors hi analyzing storm water discharges because it is the initiating force
in creating a discharge. Precipitation events are highly variable in nature and extent.
As discussed in more detail below, the nature of precipitation patterns varies greatly in
different parts of the country. Seasonal patterns also are usually important
considerations.
• Snow Melt—When precipitation falls in the form of snow, surface runoff does not
occur until the snow melts. In this case, the rate and volume of surface runoff
discharges is controlled by the rate of snow melt.
• Infiltration—Infiltration occurs as rain water passes into the soil. The ability of soil
to infiltrate water depends on a number of factors, including soil properties, soil
B-l
-------
Appendix B
moisture content, vegetation cover, and the presence of impervious structures, such as
pavement. Water that infiltrates into the soil can be subject to interflow, ground water
recharge, and evapotranspiration.
Interflow—Interflow (i.e., subsurface flow) occurs when water infiltrates into the soil
and flows through the soil above the water table. Interflow can occur until water
enters a drainage ditch, storm sewer, surface receiving water, or the ground water.
Ground Water Recharge—Ground water recharge occurs when water infiltrates into
the soil and enters the water table. Ground water then flows toward and into natural or
artificial channels or other receiving waters. The flow of ground water to surface
waters maintains flows in natural and manmade drainage ways and impoundments
during dry weather conditions.
Evapotranspiration—The term evapotranspiration describes two processes—
evaporation and transpiration. Evaporation is the process where liquid water changes
to a vapor. Transpiration occurs when water moves through vegetation and is then
evaporated.
Surface Runoff and Natural Drainage—Surface runoff (i.e., overland flow) occurs
when water generated from precipitation or snow melt moves across the ground to a
natural or constructed channel or some other receiving water. Natural drainage defines
the flow of water through naturally occurring receiving waters and into the ocean.
Because the natural drainage system contains a wide range of receiving waters,
including wetlands and intermittent streams, it is often difficult to determine the point
at which surface runoff ends and natural drainage begins. Although such distinctions
may be important in our legal system, they have limited importance in the workings of
the hydrologic cycle.
B-2
-------
Appendix B
B.1.2 Impacts of Land Use Activities on the Hydrology of Watersheds
Typically, a watershed is a geographic region in which surface waters flow towards a
common receiving point such as a stream, river, lake, or estuary. The natural drainage system
of a watershed may comprise many types of surface water features, including wetlands,
intermittent streams, small perennial streams, and larger receiving waters. In other uses of the
term, watersheds may also be defined based on ground water flows and aquifers.
As watersheds are developed for urban or agricultural uses, resource extraction, or other
purposes, the natural drainage features of the water are often altered. Wetlands are dredged
or filled, reducing the natural storage capacity of the drainage system, which, prior to its loss,
damped peak flows associated with storm events. Smaller streams can be channelized, rip-
rapped, or diverted into underground culverts, all of which allow the flow rates in the channel
to increase.
The hydrology of the watershed also is changed by activities occurring on land. The
natural drainage features of undeveloped land slow the flow of runoff by incorporating rainfall
into the natural hydrologic cycle. Many types of development cause an increase in the
volume of surface runoff and its rate of discharge. A given storm event will yield more
runoff with a faster rate of discharge for a developed area than for an undeveloped area of the
same size. These increases in the rate of flow and the total volume of flow often have a
decided effect on pollutant loads, erosion rates, and flooding.
A number of factors can increase the volume and rate at which runoff flows from a
developed site. Clearing land removes the vegetation cover that previously intercepted
precipitation before it hit the earth. The thick humus layer associated with the vegetative
cover is often removed or eroded away during grading activities, decreasing the ability of the
surface to infiltrate and retain precipitation. The land is graded to make the surface smoother
by removing natural depressions. Site slopes may be increased as part of terracing to improve
site drainage. Wetlands, which may have previously soaked up water associated with peak
flows, are drained or filled. Impervious structures, such as roads, parking lots, driveways,
B-3
-------
Appendix B
rooftops and sidewalks, are built. In other heavily used areas, soils become compacted and
lose their ability to infiltrate precipitation.
After development has occurred, the natural drainage system (e.g., streams, wetlands, and
other receiving waters) is often unable to handle the higher volume flows, resulting in high
erosion rates or flooding. Drainage systems that have undergone these changes often need
additional "improvement" from channelization or lining projects. In addition, streams are
often directed through underground culverts.
The same characteristics of land development that cause higher peak flows also cause less
infiltration of rainfall to recharge ground water supplies and a lowering of the water table.
One result of lowered water tables is that surface stream flows during dry weather can be
lowered significantly. Lower flows during periods between storms may significantly affect
the aquatic habitat and the ability of a stream to dilute toxic spills or other dry weather
pollutants within the stream system (Bellevue NURP). In some cases, the installation of
storm sewers in a watershed results in small, previously perennial, streams running dry several
times a year (Long Island NURP).
B.1.3 General Physical Characteristics of Storm Water Discharges
Storm water discharges are diffuse in nature; discharges in a watershed are generated by
an extremely large number of points. Three characteristics of storm water discharges are
particularly important when analyzing potential impacts of these diffuse sources within a
watershed. Storm water discharges 1) may affect broad portions of a watershed, 2) can have
high volumes, and 3) are generally of limited duration.
B.l.3.1 Effects on Broad Portions of a Watershed
Unlike many other major point source discharges that are directed to larger receiving
water bodies or to relatively remote offshore locations, storm sewers discharge to essentially
all of the portions of the drainage system within developed areas of the watershed. As a
B-4
-------
Appendix B
result, the impacts of storm water discharges, although more subtle, may be more widespread
and potentially may affect a greater degree of the natural drainage system than traditional
point source discharges.
Perhaps the widespread nature of storm water discharges is most evident when
considering large urbanized areas.1 Essentially all receiving waters in urbanized areas receive
storm water discharges from some type of urban land, regardless of the sensitivity of the
receiving water to potential impacts. This is because typical storm water management
practices attempt to drain water from the land as soon as possible and discharge it to the
nearest receiving water whether or not the receiving water has the ability to handle increased
flows and pollutant loads.
In heavily developed areas, urbanization results in widespread alteration or destruction of
much of the natural drainage system. Many of wetlands in these areas are drained or filled,
while smaller streams can be heavily modified. These alterations to the natural drainage
system decrease the system's ability to remove pollutants, function as habitat, and handle
large flows. The cumulative impacts of these widespread effects can potentially affect larger
downstream components of the watershed.
B.l.3.2 High Volumes/Velocities
A typical storm may generate a large number of storm water discharges within a
watershed. The cumulative volume of these discharges may be high relative to the typical
volume of flow of receiving waters. These high volume discharges may dramatically increase
flow velocities in streams and drainage channels. High volume storm water discharges and
resultant rapid stream velocities cause the combined effect of increasing:
1 As discussed in more detail in Chapter 3, the 366 urbanized areas designated by the Bureau of Census range in
area from 17 square miles (Grand Forks, ND-MN) to more that 2,800 square miles (New York, NY-NJ).
B-5
-------
Appendix B
• Pollutant loads
• The ability of discharges to erode the land and carry pollutants off the land
• The ability of streams to resuspend pollutants in bottom sediments and erode stream
beds and stream banks
• The ability of streams to carry pollutants to slower flowing water bodies where
pollutants may accumulate
• The need for stream channelization, installation of concrete walls, riprap, or other
modification projects.
Figure B-l shows the relationship between population and the volume of the peak annual
flow in the Bellevue, Washington, watershed. The volume of the peak annual flow in the
watershed almost doubled as the population in the city increased from 10,000 to 67,000. Peak
flows that used to return every 10 years can now be expected to return at least every other
year. Although the monthly average total volume of flows in the watershed increased only
slightly over pre-urbanization years, the volume of flows during peak events increased two to
three tunes as a result of urbanization. This increase in the volume of the peak annual
watershed flow volumes increased stream bank erosion and stream bed scour, as well as the
frequency of flooding. The increase in intensity of runoff has created unstable stream banks,
which have eroded at a rapid rate. The stream channel is narrower and deeper than those of
typical undisturbed streams serving similar watersheds. Pools and other sites along the stream
bed that had slowed flows in the past have been removed by the higher flows.
B.l.3.3 Limited Duration
Although storm events and the resulting storm water discharges are of limited duration,
pollutants hi these discharges can cause both short- and long-term impacts on receiving
waters. Short-term impacts generally occur during or shortly after a storm event. These
impacts are usually caused by high levels of pollutants associated with the storm water
discharges. Materials other than storm water, such as spills or dumped material, that
discharge from a separate storm sewer may also cause short-term water quality impacts.
B-6
-------
Appendix B
i
1990
Source: Scott, Steward, and Stober
Figure B-l. Population of Bellevue and Peak Annual Discharge in Kelsey Creek (O).
Data From U.S.G.S. and Bellevue Planning Dept. 1977
Long-term water quality impacts associated with storm water may be caused by pollutants
accumulating in a watershed or by repeated exposures to pollutants from a large number of
events. In addition, habitat destruction and other physical impacts, such as stream bed scour,
can occur over a long period of time.
Although individual storm events are of relatively short duration, receiving waters may be
affected by storm water discharges for time periods that are significantly longer than the
storm event. The length of tune that pollutants from storm water discharges remain in a
receiving water will depend on four factors: 1) the duration of the storm event, 2) the size of
the watershed, 3) flow rates in the receiving water, and 4) the tendency for pollutants to
accumulate in bottom sediments.
B-7
-------
Appendix B
Small streams with small drainage basins respond immediately to the pollutants in storm
water discharges, with pollutants passing through at relatively high velocities as a discrete
pulse. High pollutant levels in large flowing rivers may occur at downstream locations for an
extended period of time. Pollutant concentrations in large rivers initially rise with the onset
of a storm event. After a storm is over, pollutants from storm water discharges to feeder
streams draining upstream portions of a watershed can keep pollutant levels elevated at
downstream locations of the river for an extended period of tune. Pollutants in storm water
discharges from upstream land uses may continue to impact a location for several days after
the event.
Receiving waters with slower flows and longer resident times, such as impoundments,
lakes, reservoirs and estuaries, may be affected for long tune periods by pollutants from short-
duration storms. Hence, the limited duration of individual storm water discharge events is of
less importance when considering potential impacts on these receiving waters. In these
receiving waters, slower velocities will result in many types of pollutants accumulating in
bottom sediments where they may cause long-term impacts.
B.2 TYPES OF ADVERSE IMPACTS ASSOCIATED WITH STORM WATER
DISCHARGES
Table B-l summarizes the pollutant classes and pollutant sources identified in the 1992
National Water Quality Inventory as major causes of water quality impairment. The National
Water Quality Inventory summarizes information regarding water quality impacts that is
submitted by States in Section 305(b) reports. The summary generally identifies conventional
pollutants, such as nutrients, sediment (siltation), oxygen demand, and pathogens, as the
leading causes of surface water impairment reported by the States. Toxicity, caused by
metals, priority organics, pesticides, oil and grease, and inorganic pollutants, is also identified
as a major cause of impairment.
B-8
-------
Appendix B
Table B-l. Top Five Pollution Sources and Contaminants
Five Leading Sources of Water Quality Impairment
Rank
1
2
3
4
5
Rivers
Agriculture
Municipal Point Sources
Urban Runoff/Storm Sewers
Resource Extraction
Industrial Point Sources
Lakes
Agriculture
Urban Runoff/Storm Sewers
Hydrologic/Habitat
Modification
Municipal Point Sources
Onsite Wastewater Disposal
Estuaries
Municipal Point Sources
Urban Runoff/Storm Sewers
Agriculture
Industrial Point Sources
Resource Extraction
Five Leading Causes of Water Quality Impairment
Rank
1
2
3
4
5
Rivers
Siltation
Nutrients
Pathogens
Pesticides
Organic Enrichment/Low
DO
Lakes
Metals
Nutrients
Organic Enrichment/Low DO
Siltation
Priority Organic Chemicals
Estuaries
Nutrients
Pathogens
Organic Enrichment/Low
DO
Siltation
Suspended Solids
Source: National Water Qualify Inventory, 1992 Report to Congress, EPA, 1994.
The National Water Quality Inventory primarily addresses larger receiving water bodies
and does not address major portions of the natural drainage system of most watersheds, such
as smaller feeder streams and wetlands.
This section briefly describes the major classes of pollutants associated with water quality
impacts. For each class, special considerations regarding storm water discharges are
discussed. Three additional pollutant classes, acidity, temperature, and floatables, that are of
special concern when addressing storm water discharges are also discussed.
B-9
-------
Appendix B
B.2.1 Siltation/Sedimentation
Siltation from sediment pollutant loads can cause a broad range of interrelated impacts in
receiving waters, including the following:
• Loss of Benthic Habitat—Increased stream flows and velocities produced by high
volume storm water discharges may cause channel scour and bank erosion that result in
habitat destruction. Suspended solids are deposited as sediment bars or sediment
blankets in pools and other areas of reduced stream energy. These blankets can
smother benthic organisms, including the eggs and immature forms of free-swimming
organisms (Gupta, 1981; Novotny and Chesters, 1981).
• Reduced Water Storage Capacity—Increased sediment loads reduce water storage
capacity in reservoirs (Novotny and Chesters, 1981). Nationwide, the average annual
depletion rate of reservoir storage capacity caused by sedimentation is estimated at 0.2
percent (Tourbier, 1981). Sediment loads also decrease the depths of streams, which
decreases the retention and conveyance capacity of streams and may result in increased
flooding.
• Impaired Oxygen Exchange—Increased turbidity levels impair the ability of aquatic
organisms to obtain dissolved oxygen from the water by interfering with the gill
movements and associated water circulation (Novotny and Chesters, 1981).
• Decreased Light Penetration—The depth of light penetration into surface waters is
sharply diminished by turbidity. As a result, photosynthetic activity and food sources
are reduced. Loss of submerged aquatic vegetation may also remove habitat for
juvenile fish and shellfish.
• Impaired Navigation—Accumulated sediments in river channels limit the passage of
deeper draft boats, preventing navigational access or increasing the frequency of
required channel maintenance dredging (Gupta et al., 1981; Novotny and Chesters,
B-10
-------
Appendix B
1981). In some locations, sediments are so contaminated with pollutants that they
should be handled as hazardous wastes, which dramatically increases disposal costs.
Dredging activities result in re-suspension of pollutants in the sediment, causing
additional water quality and aquatic habitat impacts (Novomy and Chesters, 1981).
• Increased Water Treatment Costs—Sediments can increase the costs of treating
potable water supplies. Inadequate sediment removal may limit the germ-killing effects
of chlorination.
• Accumulation of Pollutants—Many of the pollutants associated with many types of
storm water discharges become chemically or physically bound with sediment particles.
As these particles settle, the attached pollutants also sink (Brown et al., 1985; Novomy
and Chesters, 1981). Sediments with attached pollutants can act as a source of
contamination to the overlying water, to the benthic biota, and to the food chain. Over
long periods of tune, sediments may accumulate such high levels of toxics and other
pollutants that exceedances of ambient water quality standards may occur in the water
columns, increasing exposure of organisms to toxic chemicals (Harrington, 1986).
Oxygen demanding pollutants in sediment deposits may also create oxygen deficits
during and after storm water discharge events (Heaney and Huber, 1984; Mancini and
Plummer, 1986; Novotny and Chesters, 1981).
• Resuspension of Pollutants—Highly variable flows in receiving waters can resuspend
sediments, thereby increasing water column concentrations of those pollutants that had
accumulated in bottom sediments. The repetitive process of deposition, re-suspension,
and re-deposition of sediments may result in pollutants associated with sediments
taking a long time to pass through a receiving stream (Novotny and Chesters, 1981).
B.2.2 Nutrients
Nutrients support and stimulate aquatic plant life. Natural nutrient cycles may be altered
by land use activities within a watershed. Excessive nutrients overstimulate the growth of
B-ll
-------
Appendix B
aquatic plants, which may result in low oxygen levels, accelerate eutrophication, cause
unsightly conditions, interfere with navigation, interfere with treatment processes, and cause
unpleasant and disagreeable tastes and odors. Eutrophic conditions are evidenced by surface
algal scums, reduced water clarity, odors, and dense algal growth on shallow water substrates
(Schueler, 1987). Algal blooms block light from submerged aquatic vegetation, which may
remove habitat for juvenile fish and shellfish. After blooms or at the end of a growing
season, the decomposition of dead vegetation may cause reduced oxygen levels. Reduced
oxygen levels may, in turn, cause fish kills and mass mortality of benthic organisms.
Excessive nutrients may have more adverse effects in surface water bodies that have slow
flushing rates, such as slow moving rivers, lakes, and estuaries. Nutrients delivered during
storm events settle to sediments of such waters. Once hi sediments, the nutrients can be
solubilized or re-suspended by anaerobic conditions, currents, changes in concentration
gradients, or the mixing effects of boat wakes (Field and Turkeltaub, 1981).
Aquatic vegetation requires both nitrogen and phosphorus to grow. Excess quantities of
nitrogen are commonly present in fresh water, so plant growth is usually controlled by the
levels of phosphorus input (Schueler, 1987). In marine waters, however, phosphorus is often
in greater supply, and plant growth is controlled by nitrogen concentrations. In either case,
when the controlling nutrient is added, greater plant growth is expected.
Several forms of phosphorus occur in the aquatic environment. Major forms of
phosphorus include orthophosphorus (OP), dissolved or soluble phosphorus (DP), particulate
phosphorus (PP), and total phosphorus. Orthophosphorus is the form immediately available
for algal growth. Particulate phosphorus is considered to be potentially available after
conversion to OP. During stream transport, OP is likely to become incorporated into the
particulate fraction. A portion of the phosphorus bound to sediment particles can also be
released as OP. Exchange between available and potentially available forms continues though
processes of sediment and algal uptake and release. Transport distance from phosphorus
sources to impacted receiving waters is recognized as a major factor in determining the
B-12
-------
Appendix B
availability and timing of load delivery. Strict control of phosphorus levels from direct and
proximal discharges to affected receiving waters is recommended because of the high level of
OP delivered from these discharges.2
Nutrient loading is directly related to the frequency of runoff events in developed
watersheds and can vary by a factor of 3.5 between wet and dry years at the same location
(Lung, 1986). High quantities of nitrogen and phosphorus may be transported in surface run-
off in the dissolved form or attached to sediments; the relative significance of these two forms
may vary seasonally, reflecting differing winter and summer runoff conditions (Jones, 1986;
Urbonas and Roesner, 1986). Nitrogen and phosphorus concentrations in storm water from
residential and commercial areas may occur at levels sufficient to stimulate excess growth of
algae and aquatic macrophytes (i.e., eutrophication), partly because most of these nutrients
occur in soluble forms that are readily assimilated by plants (Schueler, 1987).
Nitrate (generally the most stable form of nitrogen) at levels above the drinking water
standard of 10 milligrams per liter can cause methemoglobinemia in infants under six months.
This rare, but potentially fatal disease limits the oxygen carrying ability of the blood.
B.2.3 Organic Enrichment/Oxygen Demand
Aquatic organisms, such as fish and water-dwelling insects, require minimum levels of
dissolved oxygen (DO). Excessive oxygen demanding pollutants can lead to periods of
oxygen sag, which may cause fish kills and create anoxic conditions accompanied by
foul-smelling odors. Oxygen levels in receiving waters can be lowered by the decomposition
of organic matter by microorganisms, by the chemical oxidation of material, or by aquatic
vegetation, which uses more oxygen at night than it produces.
Oxygen demand is the term applied to pollutant loads that result in reduced dissolved
oxygen levels. The two parameters most commonly used to describe the oxygen demand of
Phosphorus: A Summary of Information Regarding Lake Water Quality, IL EPA, August 1986.
B-13
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Appendix B
pollutants are the 5-day biochemical oxygen demand (BODS) and chemical oxygen demand
(COD). BOD measures oxygen demanding substances that can be metabolized by bacteria
and is an indicator of biodegradable organic matter. COD measures oxygen demanding
substances that react with an oxidizing chemical in a heated acid bath. COD is an indicator
of both organic matter and reduced inorganic chemicals. Of the two, COD is more accurate
for the purpose of comparing the oxygen demand of storm water discharges to the oxygen
demand of other types of discharges. The BODS test underestimates the true oxygen demand
of storm water because the heavy metals in the storm water slow the bacterial action used in
the test
Storm water runoff may contain both organic and inorganic pollutants that consume
oxygen in receiving waters. Storm water discharges generally occur on overcast days when
the amount of sunlight available to oxygen producing plants in water is limited. Lower
oxygen production rates increase the adverse impacts of oxygen demanding pollutant loads.
Much of the oxygen demanding pollutant load of many types of storm water discharges is
associated with suspended solids, which may form deposits in receiving waters. These
deposits may result in long periods of low dissolved oxygen through gradual decomposition or
may re-suspend during later runoff events. The impacts of oxygen demanding pollutants may
be more dramatic in shallow, slow-moving waters due to limited aeration and the tendency of
these pollutants to accumulate in bottom sediments of slow-moving waters.
Dissolved oxygen depletions may occur at times substantially different from the actual
storm event, which originally discharged the oxygen demanding pollutants. Re-suspension of
sediments with attached oxygen demanding pollutants during high flows worsen and delay the
dissolved oxygen depletions.
B.2.4 Pathogens
Pathogens are disease-causing organisms, including viruses and some bacteria.
Waterborne pathogens may be transmitted to humans or animals through direct recreational
B-14
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Appendix B
contact, drinking water supplies, or through eating contaminated shellfish. Major pathogen
sources include human and animal wastes.
Separate storm sewers, unlike combined storm sewers, are not designed to carry sanitary
sewage. However, pathogens may enter separate storm sewers from leaking sanitary sewers,
illegal cross connections with sanitary sewers, and malfunctioning septic tanks. In addition,
runoff can pick up pathogens from animal wastes on the land. Conditions inside a storm
sewer system are often conducive to pathogen reproduction.
Due to difficulties and expenses associated with measuring pathogens directly, bacteria,
including total coliform, fecal coliform, and fecal streptococci, are used as indicators of
pathogens even though many of these bacteria are harmless. EPA studies indicate that
although fecal coliforms are a good indicator of human pathogens for POTW discharges, they
are inadequate indicators of human pathogens for many types of storm water discharges (51
FR 8012, March 7, 1986). However, most State and local health criteria for recreational
contact and shellfish are based on fecal coliform levels, partially due to the low cost of testing
procedures. As a result, storm water discharges are responsible for a significant number of
restrictions placed on recreational uses and shellfishing.
B.2.5 Toxicity (metals, toxic organics, pesticides, inorganics, and oil and grease)
A wide range of chemicals may exhibit toxicity. Five major classes of chemicals that
have toxic impacts recognized in the National Water Quality Inventory are metals, toxic
organics, pesticides, inorganic pollutants, and oil and grease.
Toxic impacts may be classified in terms of acute and chronic effects. Acute toxicity
refers to lethal concentrations or doses of toxic materials, which result in death of aquatic
organisms in a relatively short time. Chronic toxicity refers to impacts, such as the formation
of tumors, lowered reproductive, growth, or survival rates, that occur after a longer exposure
to toxic substances. Bioaccumulation, or the accumulation of toxic chemicals in tissues of
organisms, is another long-term effect of toxic substances that may affect the organism
B-15
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Appendix B
directly exposed to the chemical, or other animals, including humans, that consume
contaminated organisms. For a given chemical constituent (or a mix of constituents) chronic
toxicity occurs at lower concentrations than the concentrations that may cause acute effects.
However, the exposure time necessary to trigger chronic effects is longer than the exposure
times that cause acute effects.
Pollutants that are highly resistant to natural degradation processes are referred to as
conservative pollutants. Conservative pollutants have a greater opportunity to cause chronic
toxic effects or to bioaccumulate in organisms. Conservative pollutants also have the potential
for wider dispersal in the environment through bioaccumulation and subsequent transfer in
living organisms, such as fish, plankton, and fish eating birds and mammals. Toxic
conservative pollutants include trace metals and some organic compounds, such as chlordane,
polychlorinated biphenyls, and other halogenated hydrocarbons. Metals do not degrade, and
some organic compounds degrade so slowly that they may remain in sediments for decades.
Many of the toxic metals and other toxic constituents in storm water discharges are
attached to suspended solids hi the discharge and settle out and accumulate in the bottom
sediments of receiving waters where they may persist for long periods of time. Toxics
concentrated hi bottom sediments may cause adverse impacts on benthic organisms, may
become resuspended during high flows resulting from other large storm events, or may
dissolve into the water as parameters such as pH and dissolved oxygen change. Accumulated
pollutants hi bottom sediments may also adversely affect fish during periods of continuous
low flow.
B.2.6 Flow Alterations
Activities on the land may cause dramatic changes to the natural hydrologic cycle.
Changes in peak flow rates of receiving streams and associated increases in flow velocities
cause changes hi the stream shape and structure. Increased flow velocities have a greater
ability to erode stream beds or stream banks. Stream channels may either be widened or
made deeper, with large amounts of soils being swept downstream, forming shifting sandbars
B-16
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Appendix B
or other sediment deposits. Streams may widen to two to four times their pre-development
width if storm water is uncontrolled from developed areas. High erosion rates adversely
affect habitat by destroying benthic structures and habitat. High creek flows may also sweep
poor swimming fish from the creeks and transport leaf material at higher rates, limiting the
availability of food for macroinvertebrate organisms. Channelization projects that drain
natural wetlands for development may dramatically alter natural flow patterns. These projects
will greatly diminish or destroy the pollutant removal and flow attenuation abilities of the
wetlands.
Increased flows associated with urbanization are often accompanied by the installation of
extensive channelization projects to increase the flow capacity of the water course and limit
erosion damage during storm conditions. Typical channelization projects include riprap,
concrete retention walls or lining along stream banks, channel realignment, and diversion of
streams through culverts.
After the initial construction of a channelization project is completed, both direct and
indirect sources of pollution occur. Channelization projects reduce channel roughness to
further increase flow velocities. Increased flow velocities that exceed the stability velocities
of the bottom or bank materials cause erosion or scour. Such activity degrades the channel
and furnishes sediment for stream transport, destroys natural habitats, and detracts from the
aesthetics of the stream. In general, the more extensive the modification, the more damage
caused to habitat areas. For example, concrete lining of channels eliminates habitat areas and
aesthetic values for practical purposes. Increased channel dimensions may deprive the stream
flow of shade from trees along streams banks, resulting in increased water temperatures.
These types of projects may worsen downstream flood problems where storm flows are unable
to spread out onto a flood plain and increased velocities increase erosion along unprotected
banks downstream.
B-17
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Appendix B
B.2.7 Acidity
Aquatic life may only be supported in a limited range of pHs. Receiving waters that are
highly acidic (have a low pH) may be totally devoid of life. In other receiving waters, fish
kills may be caused by periodic highly acidic conditions. Periodic episodes of acidity may be
particularly harmful to juvenile fish, which tend to be more sensitive and reside in the smaller
streams of a watershed, which are more likely to experience wider pH swings. In addition,
acidic rain generally will have higher concentrations of heavy metals and other pollutants,
which leach under acidic conditions.
Acidity in storm water may be caused by two sources—air pollutants and certain land use
activities. Mining is the land use with the most well known acidic storm water discharges.
Coal mining in the eastern United States generally involves coal that is high in sulfur and is
historically associated with some of the most dramatic water quality impacts caused by
acidity.
Nitrogen oxides (NOJ and sulfur dioxide (SO2) are the primary air pollutants that result
in acid ram and, hence, highly acidic storm water. Acid rain occurs when SO2, emitted
primarily by electric utilities fired by eastern coal, and nitrogen oxides (NOJ, emitted
primarily by transportation sources and utilities, are deposited in the form of wet or dry
deposition. Rain in the western United States typically has a regional pH of 5.5 or above.
Rain hi the eastern United States is more acidic, with regional pH values below 4.2 in some
regions. More than 80 percent of the SO2 emissions in the United States originates in the 31
States bordering or east of the Mississippi River, with a heavy concentration from States in or
adjacent to the Ohio River Valley. These airborne emissions are transported by prevailing
winds to the east. Figure B-2 indicates regional acid rain patterns.
Several aspects of urbanization tend to create local conditions that may make receiving
waters susceptible to impacts from acidity. High levels of airborne SO2 and NOX in large
urbanized areas increases the acidity of the rainfall hi the urbanized area to levels above those
typically found for the region. Runoff from paved surfaces and other impervious surfaces
B-18
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Appendix B
Data from four networks are plotted: Canada, CANSAP (circles) and AAPN (squares); United
States, NADP (circles) and MAP3S (squares).
Source: Barrie and Hales, 1984.
Figure B-2. Spatial Distribution of the Precipitation-Amount-Weighted Annual Mean
Hydrogen-Ion Concentration (expressed as pH) hi North America in 1980
B-19
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Appendix B
may have little or no opportunity to contact soils that may buffer the acidity of the rainfall.
In urbanized areas with acidic rain, higher runoff volumes and rates associated with the urban
development can increase the acidity of receiving streams rapidly and to high peak acidity
levels. This results from more acid being deposited to receiving streams in a shorter amount
of time.
B.2.8 Temperature
Increased temperature may have detrimental effects on fish and other aquatic life during
various stages of their life cycle. Water holds less oxygen as it gets warmer, which may affect
habitat and make the water more susceptible to oxygen demanding pollutants. Sustained
water temperatures in excess of 70°F are considered stressful or lethal to many cold water fish
species and stream insects. The availability of food, attendant life cycle chemistry, and water
quality changes are all affected by water temperature.
During warm weather, the temperature of storm water discharges is generally higher than
receiving water temperatures. High volumes of runoff from hot paved surfaces and rooftops
may cause a rapid increase in surface water temperatures. Discharges from storm water
management devices, which retain collected runoff in unshaded ponds for extended tune
periods, may also increase stream temperatures.
B.2.9 Fioatables. Including Plastics
A large percentage of the litter and plastics that is found on land, if not removed, will
eventually be flushed, swept, or blown down a storm sewer. Plastics, metals, and many other
types of fioatables degrade at extremely slow rates, increasing the tune that they remain in
receiving waters.
Litter and other fioatables degrade aesthetic values, which play a role in the recreational
uses of receiving waters, property values of nearby lands, and other broad community-level
values. Economic losses caused by the aesthetic degradation of recreational areas, such as
E-20
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Appendix B
beaches, are significant. Plastic debris presents hazards to wildlife. Ingestion of plastic
material by turtles and seabirds appears to present the biggest threat to wildlife. Floatables
and plastics may also clog outlet structures of various types of storm water management
devices, resulting in flooding or other system malfunctions.
B.3 ADVERSE IMPACTS BY TYPE OF RECEIVING WATER
Impacts on receiving waters associated with storm water discharges may be discussed in
terms of three general classes: 1) short-term changes in water quality, 2) long-term water
quality impacts, and 3) physical impacts.
Use impairment of receiving streams often is caused by a combination of all three types
of impacts. Physical impacts and short-term water quality changes are generally more critical
than long-term water quality impacts for receiving waters with relatively short residence times
(such as smaller streams and rivers). Receiving waters with long residence times (lakes,
estuaries) are generally more sensitive to long-term water quality changes, although certain
physical changes, such as loss of reservoir capacity due to siltation, can be important.
Short-term changes hi water quality occur during and shortly after storm events.
Examples include periodic dissolved oxygen depressions due to oxidation of pollutants, short-
term increases in the receiving water concentrations of one or more toxic pollutants, high
bacteria levels, and high acidity. These conditions can result hi fish kills, loss of submerged
macrophytes, and other temporary use impairments.
Long-term water quality impacts are caused by the cumulative effects associated with
repeated storm water discharges. These impacts often result from the cumulative effects of
pollutants from a number of different types of sources. When evaluating long-term impacts,
the cumulative and relative effects of seasonal and long-term pollutant loadings from all
relevant sources (e.g., storm water, publicly owned treatment works, industrial discharges,
nonpoint sources, atmospheric deposition, in-place pollutants) should be considered.
B-21
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Appendix B
Examples of the long-term water quality impacts that storm water discharges may cause
or contribute to include depressed dissolved oxygen caused by the oxygen demanding
pollutants in bottom sediments, biological accumulation of toxics as a result of uptake by
organisms hi the food chain, chronic toxicity to organisms subject to repeated exposures of
toxic pollutants, destruction of benthic habitat, loss of storage capacity in receiving waters,
and increased lake eutrophication. Long-term water quality impacts are also caused by
pollutants attached to suspended solids that settle in receiving waters and by nutrients that
enter receiving water systems with long retention tunes. In both cases, long-term water quality
impacts are caused by increased residence tunes of pollutants in receiving waters. Long-term
water quality impacts of pollutants from storm water discharges may be manifested during
critical periods other than during storm events (e.g., during low stream flow conditions and/or
during sensitive life cycle stages of organisms).
Physical impacts may occur due to the erosional effects of high-volume flows and high-
stream velocities that occur after the natural hydrologic cycle is altered. These changes are
often accompanied by the installation of engineered structures, such as concrete walls or
underground culverts, which may further degrade the habitat and aesthetic values of the
receiving water. In addition, if ground water recharge is limited by the placement of
impervious structures on the land, dry weather base flows may be lowered to the detriment of
the receiving water.
B.3.1 Rivers and Streams
The National Water Quality Inventory -1992 Report to Congress (EPA, 1992) indicates
that the States identified the most extensive causes of impairment in the Nation's rivers as
siltation (affecting 45 percent of impaired river miles), nutrients (affecting 37 percent),
pathogen indicators (affecting 27 percent), pesticides (affecting 26 percent) organic
enrichment/low dissolved oxygen (affecting 24 percent), and metals (affecting 19 percent).
Discharges from storm sewers are identified as affecting 11 percent of the impaired river
miles. The assessments focused primarily on larger streams and rivers and did not address
many of the heavily degraded small streams found in urban areas and elsewhere.
B-22
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Appendix B
The effect of human activities on the natural hydrologic system may be most evident on
smaller streams. Development of a site may dramatically increase the volume and the
maximum discharge rate of storm water discharges. Where a sufficient number of sites within
the drainage basins of smaller rivers and streams occurs, the stream may experience increases
in the magnitude and frequency of flooding, as well as extremely high-stream velocities
associated with storm events.
Such changes in the hydrology of a stream may result in accelerated stream bank or
stream bed erosion. Such erosion may cause or contribute to a number of generally
detrimental effects, including widening or deepening of the stream channel, elimination of
pools and other structures in the stream, and shifting of gravel or sand bars. In addition, base
flows may be lowered during dry weather.
Streams that have experienced increased flooding or peak velocities often undergo a high
degree of additional human flow modification, including channel excavation, lining,
realignment, or diversion through underground culverts, which may have, for all practicable
purposes, destroyed both fish and wildlife habitat and natural aesthetics. In many cases,
highly modified streams are considered to be part of the storm sewer system.
Pollutant concentrations in smaller streams and rivers may experience relatively short-
duration increases due to storm water discharges. However, hi smaller streams, the
concentration of pollutants may be almost as high as the concentrations found in discharges
where dry weather base flows are significantly lower than wet weather flows and provide only
limited dilution.
Larger rivers often respond slower to storm events than do smaller streams. After a storm
event hits a large drainage basin, a given segment of the river may experience degraded water
quality for several days because a single location on the river is sequentially affected by
pollutants from different upstream sources caused by the same storm. For example, a segment
may be influenced by urban runoff, only to then be influenced by agricultural runoff
B-23
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Appendix B
generated upstream of the storm water source, followed by silvicultural runoff from the river's
headwaters.
In many streams, flow velocities slow substantially with increases in stream width or
decreases in stream gradient. At these points, sedimentation of fine particles and associated
pollutants result. The settled sediments can act as a reservoir for pollutants affecting the
water column and the food chain long after the rain has ceased. In addition, disturbance of
the deposited sediments by scouring from storm water discharges or combined sewer outfalls,
navigation, construction, or dredging may re-introduce the sediments and their pollutants to
the water column. The result can be a recurrence of adverse impacts originally associated
with the storm water discharge.
The degree of impact on the river or stream depends on a number of factors, including
the frequency and duration of the storm water discharges, the quality and quantity of storm
water discharges, the occurrence of other wet weather discharges (combined sewer overflow
discharges), and the quantity and quality of the base flow (dry weather flow) of the stream.
Because larger rivers receive pollutants from a wide variety of sources in urbanized areas, the
qualify of the base flow may be marginal or poor, thereby increasing the sensitivity of the
receiving stream to storm water discharges. In streams with very low base flows, on the other
hand, the storm water discharge may be the major determinant of the water quality of the
stream.
B.3.2 Lakes and Reservoirs
The most extensive causes of use impairment in lakes are metals (affecting 47 percent of
impaired acres), nutrients (affecting 40 percent), organic enrichment/low dissolved oxygen
(affecting 34 percent), siltation (affecting 42 percent of impaired acres), and priority organic
chemicals (affecting 20 percent). The States reported that 63 percent of lake acres assessed
were not fully supporting designated beneficial uses. In addition, the States reported that
discharges from separate storm sewers affect 24 percent of the impaired acres of lakes
excluding the Great Lakes. Onsite wastewater disposal impaired 16 percent of the impaired
B-24
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Appendix B
acres. For the Great Lakes, discharges from storm sewers were identified as affecting 11
percent of the impaired shore miles, and land disposal 31 percent of impaired shore miles.
Compared with rivers and streams, lakes and reservoirs have long residence times. The
tune scale of water quality impacts and recovery may be on the order of years, decades, or
even centuries (Manning et al., 1977). The impacts that occur are more likely to be the result
of seasonal or annual loadings of pollutants rather than loadings from individual events.
Lakes and reservoirs, with longer residence times and slower flow rates, tend to become sinks
for many pollutants that attach to the sediments typically carried by storm water. Longer
residence tune, coupled with poorer aeration, also increases the impacts of nutrients and other
oxygen demanding pollutants. The peak concentrations of pollutants in storm water
discharges are less important in determining the severity of adverse impacts than the total
loading of pollutants delivered to the lake because of the larger capacitance of the system.
In lakes and reservoirs that are deep enough to become thermally stratified, the impacts of
introduced pollutants vary seasonally. Pollutants that settled to the bottom attached to solids
may become re-introduced into the water column during the strong currents and mixing that
can accompany storms, particularly in autumn. This effect has been illustrated dramatically in
the Great Lakes (Rosa, 1985; Eadie et al., 1984; Charlton and Lean, 1987).
B.3.3 Estuaries and Coastal Waters
The States reported that the most extensive causes of use impairment in estuaries are
nutrients (affecting 55 percent of impaired square miles), pathogen indicators (affecting 42
percent) and organic enrichment/low dissolved oxygen (affecting 34 percent). Discharges
from separate storm sewers affected 43 percent of the impaired estuarine area. The States
reported that storm sewers affected 59 percent of ocean shore miles and land disposal affected
42 percent of ocean shore miles.
The pattern of water flow in a given estuary results from the effects of tides and density
differences between surface and deeper waters. In most estuaries, fresh waters have an
B-25
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Appendix B
outward, seaward current. Pollutants are initially carried by the fresh water currents. As
pollutants attach to sediment and as the flow rates in the estuary slow due to larger flow
basins, the pollutants and sediment sink and their outward flow is reversed when they enter
heavier, saltier bottom waters that have a net flow landward. As a result, many pollutants
remain trapped hi estuaries and never reach open waters. Once these sediments have been
deposited, they exert long-term effects on water quality through toxicity, bioaccumulation, or
nutrient release.
Much of the nutrient load that is present in surface waters can be incorporated into algae,
which then settle. As the algae settle, nutrients are released back into the deeper, inflowing
waters. As the inflowing waters mix with outflowing surface waters, the nutrients are once
again incorporated' into algae. This vertical cycling of nutrients in estuaries, referred to as the
nutrient trap, allows the slow accumulation of nutrients in the water column. Contributions of
nutrients from storm water discharges increase the rate of this nutrient accumulation,
worsening the problems of estuarine eutrophication, which is increasingly one of the major
focuses of many of the National Estuary Program projects.
B.3.4 Wetlands
Wetlands are generally located adjacent to the other kinds of surface waters. Wetlands
buffer the ultimate receiving water by slowing and storing high, wet weather flows and by
removing pollutants. In addition, the intensive levels of biological activity in wetlands play
an important role hi the ecology of the receiving water.
Wetlands are often dredged or filled when development occurs near surface water or near
the floodplain. The destruction of wetlands without appropriate storm water management
destroys the capability of wetlands to hold runoff and remove pollutants before discharging to
other surface waters. This, in turn, results in higher runoff volumes, which discharge to
receiving waters at a faster rate.
B-26
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Appendix B
Wetlands that are used to receive storm water discharges from upland development may
also experience impacts. In some cases, the large flow volumes, flow velocities, and pollutant
loads delivered by storm water discharges can alter or destroy stable wetland ecosystems.
Storm water discharges with high sediment levels from sources such as uncontrolled
construction site runoff may fill or alter flow patterns in wetlands over a long time period.
Persistent toxics may also accumulate in sediments, vegetation, and the food chain.
If the adverse physical impacts of the storm water discharges can be minimized, the
organically rich, shallow, biologically productive wetlands may act as a buffer or treatment
for nutrients in storm water, thereby mitigating the impacts of storm water discharges on the
receiving waters.
B.3.5 Ground Water
Due to hydrological connections between surface water and ground water, storm water
management may affect ground water in two major ways. First, human activities on the land
may have dramatic impacts on the hydrologic cycle, increasing the amount of surface runoff
and decreasing the amount of infiltration that recharges ground water supplies. Decreasing
ground water recharge can lower the water table, which results hi lower dry weather base
flows in surface waters and may make the operation of wells more costly. Second, pollutants
in precipitation and runoff that infiltrates into an aquifer may not be removed by the soil and
may enter an aquifer. This may be a particular concern where storm water management
techniques used to control flooding and to improve surface water quality infiltrate surface
runoff generated by development to an aquifer.
The types of pollutants in the infiltrated precipitation and the subsurface geology
determine the beneficial value of infiltrated precipitation for recharging an aquifer or the
potential for polluting ground water. Pollutants that are highly soluble in water (e.g.,
chlorides, nitrates) pass through the overlying soils into the ground water without attenuation.
For example, chlorides from highway runoff containing road salt are shown to have adverse
B-27
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Appendix B
impacts on ground water, as well as surface waters. Other chemical parameters that are less
soluble in water tend to adsorb to the soils before reaching ground water supplies.
The potential for ground water contamination strongly depends on the types of land use
activities occurring on the surface. Two NURP projects (Long Island, New York, and Fresno,
California) addressed sole-source aquifers recharged by runoff from residential and
commercial areas for more than two decades. These studies concluded that no change in the
use of these practices was warranted. Both studies found that soil processes at the sites were
efficient in retaining the pollutants in the runoff close to the land surface, and pollutant
breakthrough of the upper soil had not occurred. The EPA report Class V Injection Wells:
Current Inventory; Effects on Ground Water; and Technical Recommendations (1987), rated
the ground water contamination potential of storm water and industrial drainage wells as
moderate.
B.4 REGIONAL AND SEASONAL DIFFERENCES
Precipitation patterns vary dramatically in different parts of the United States. A number
of parameters are important in characterizing these regional differences, including the
duration, intensity, frequency, and annual number of storm events of a given region.
Variations in the precipitation patterns of a given region also occur seasonally. These
variations affect the volume of storm water discharges produced, can result in seasonal
impacts, and may affect management practices. In addition, snow removal and management
activities have a special impact on the quality of discharges.
Among the more dominant regional characteristics are the dry summers on the west coast,
the abrupt changes in the desert States of the southwest, the peaks occurring in spring and
winter in the central gulf and Ohio Valley States, the uniformity of monthly totals throughout
the year hi the New England States, and snowfall and melt runoff occurring in the northern
States.
B-28
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Appendix B
Seasonal differences may change the nature of storm water discharges and the
characteristics of receiving waters. Many smaller rivers in areas with extended dry seasons do
not flow all year. The dry seasons hi areas like the west coast result in higher than normal
pollutant loads associated with the first several storms of the wet season. These discharges
may occur when rivers and receiving waters are at low flow levels. Areas with higher
intensity storms are prone to flooding and high erosion. Accumulation of pollutants in snow
and snow removal activities may adversely affect the quality of snowmelt. In areas were
rainfall patterns are non-uniform, soils can become saturated during wet seasons, resulting in
higher storm water discharge volumes and erosion rates, as well as overloading of storm water
management controls, such as retention and infiltration basins.
Figure B-3 shows 15 rainfall zones for the continental United States that EPA has defined
based on annual precipitation statistics.3 These zones are defined to provide a guide for
defining regional patterns, with the geographical area assigned to a zone made as large as
possible. Table B-2 summarizes annual precipitation statistics for these zones. The annual
precipitation statistics shown in the table only include storm events that were greater than 0.1
inches and consider multiple storms separated by less than a 6-hour period of dry weather as
one event. It should be noted that, in general, site-specific data should be used for developing
designs for a specific location and that local deviations could be significant, particularly in
western parts of the country where mountains, deserts, and coastal patterns result in large
differences over relatively small distances.
3 EPA, Analysis of Storm Event Characteristics for Selected Rainfall Gages Throughout the United States, Draft,
Driscoll, E.D., et al., November 1989. These 15 rainfall zones represent a refinement of the 10 rainfall zones which
appeared in a 1986 draft of the Driscoll reference and which are used in 40 CFR Part 122 Appendix E for the purposes
of group applications for storm water discharges associated with industrial activity.
B-29
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Appendix B
Figure B-3. Rain Zones of the United States
B-30
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Appendix B
Table B-2. Typical Values of Annual Storm Event Statistics for Rain Zones
Rain Zone
Northeast
Northeast-Coastal
Mid-Atlantic
Central
North Central
Southeast
East Gulf
East Texas
West Texas
Southwest
West Inland
Pacific South
Northwest Inland
Pacific Central
Pacific Northwest
Annual Statistics
No. of Storms
Avg
70
63
62
68
55
65
68
41
30
20
14
19
31
32
71
cov
0.13
0.12
0.13
0.14
0.16
0.15
0.17
0.22
0.27
0.30
0.38
0.36
0.23
0.25
0.15
Precipitation
Avg
(in)
34.6
41.4
39.5
41.9
29.8
49.0
53.7
31.2
17.3
7.4
4.9
10.2
11.5
18.4
35.7
COV
0.18
0.21
0.18
0.19
0.22
0.20
0.23
0.29
0.33
0.37
0.43
0.42
0.29
0.33
0.19
Independent Storm Event Statistics
Duration
Avg
(hrs)
11.2
11.7
10.1
9.2
9.5
8.7
6.4
8.0
7.4
7.8
9.4
11.6
10.4
13.7
15.9
COV
0.81
0.77
0.84
0.85
0.83
0.92
1.05
0.97
0.98
0.88
0.75
0.78
0.82
0.80
0.80
Intensity
Avg
(in/hr)
0.067
0.071
0.092
0.097
0.087
0.122
0.178
0.137
0.121
0.079
0.055
0.054
0.057
0.048
0.035
COV
1.23
1.05
1.20
1.09
1.20
1.09
1.03
1.08
1.13
1.16
1.06
0.76
1.20
0.85
0.73
Volume
Avg
(in)
0.50
0.66
0.64
0.62
0.55
0.75
0.80
0.76
0.57
0.37
0.36
0.54
0.37
0.58
0.50
COV
0.95
1.03
1.01
1.00
1.01
1.10
1.19
1.18
1.07
0.88
0.87
0.98
0.93
1.05
1.09
DELTA
Avg
OUT)
126
140
143
133
167
136
130
213
302
473
786
476
304
265
123
COV
0.94
0.87
0.97
0.99
1.17
1.03
1.25
1.28
1.53
1.46
1.54
2.09
1.43
2.00
1.50
COV = Coefficient of Variation = Standard Deviation/Mean
DELTA = Interval between storm midpoints
B-31
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APPENDIX C
NON-STORM WATER DISCHARGES TO STORM WATER CONVEYANCES
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Appendix C
APPENDIX C—NON-STORM WATER DISCHARGES TO STORM WATER
CONVEYANCES
Although separate storm sewers are primarily designed to remove runoff from storm
events, materials other than storm water find their way into and are ultimately discharged
from separate storm sewers. Non-storm water discharges to storm sewers come from a
variety of sources (EPA, 1990), including:
• Illicit connections and cross connections from industrial, commercial, and sanitary
sewage sources
• Improper disposal of wastes, wastewaters, and litter
• Spills
• Leaking sanitary sewage systems
• Malfunctioning septic tanks
• Infiltration of ground water contaminated by a variety of sources, including leaking
underground storage tanks.
One of the significant differences between storm water discharges and discharges from
separate storm sewers affected by non-storm water is that non-storm water discharges may
occur during dry weather when certain recreational uses of the receiving waters are more
prevalent and stream flows are lower. In addition, pollutants from non-storm water discharges
may accumulate in separate storm sewers until they are flushed out during a storm event,
thereby contributing to higher pollutant concentrations and loads.
A wide range of pollutants may be contributed to storm sewers from non-storm water
discharges, including pathogens, metals, nutrients, oil and grease, metals, phenols, and
solvents. Removal of these non-storm water sources of pollutants often improves the quality
of discharges from separate storm sewers dramatically.
C-l
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Appendix C
The non-storm water discharges listed previously have a high potential for contributing
pollutants to storm sewers (EPA, Pitt, 1992). Other non-storm water discharges may have
less potential for contributing pollutants1:
• Water from street cleaning drainage
• Water from fire hydrant flushing
• Water from fire fighting activities
• Runoff from noncommercial residential activities, such as lawn watering, car washing,
swimming pool discharges
• Water from water line breaks
• Certain cleaning water from commercial activities
• Condensate from residential and commercial air conditioning units
• Infiltration of uncontaminated ground water
• Industrial process wastewater, which has been issued a National Pollutant Discharge
Elimination System (NPDES) permit2
C.1 ILLICIT OR CROSS CONNECTIONS
Illicit connections, also referred to as cross connections, to separate storm water sewers
are physically connected conveyances used to carry untreated wastewaters other than storm
water. For many of these connections, there is a mistaken belief that materials are going to a
sanitary sewer or some other type of treatment facility.
1 See 55 FR 47990 (November 16, 1990) and "Investigations of Inappropriate Pollutant Entries Into Storm
Drainage Systems", EPA, January 1993.
2 EPA has 'clarified that it does not interpret the effective prohibition on non-storm water discharges to municipal
separate storm sewers of Section 402(p)(3) of the CWA to prohibit non-storm water discharges in compliance with the
conditions of an NPDES permit that discharge through a municipal separate storm sewer (see November 16, 1990, 55
FR 48037).
C-2
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Appendix C
Illicit connections may take a variety of forms, including improper connections of
residential sewer service lines or sumps, cross-connections with sanitary sewers, improper
connections of industry sewer lines, and improper disposal of wastes to floor drains or
outdoor drains connected to the separate storm sewer.
C.I.I Improper Installation
In older sections of cities with separate storm sewers, the potential for improper
connections to a separate storm sewer may be high. Problems with illicit connections in the
oldest developed areas are often traced to the initial development of the storm sewer system
(AWPA, 1990). Early storm sewers preceded the development of sanitary sewers. Once
storm sewers were in place, however, they received other non-storm water sources of
pollutants, some by direct connections and others from wastes dumped into the streets or
storm sewers. Many cities prohibited the discharge of domestic sewage to storm sewers but
failed to provide public sanitary sewers, resulting in secret illegal connections built without
public supervision. Other illegal connections to the storm sewer were overlooked by
municipal officials because of the lack of proper sanitary sewers or because the municipality
did not have a program addressing the quality of discharges from the storm sewer system.
During redevelopment or infill development, illicit connections may arise when storm
sewers are either mistaken for sanitary lines or the developer intentionally installs improper
connections to a storm sewer that is more easily accessed than a sanitary sewer. Expanding
or retrofitting large, older industrial complexes creates special problems if maps of the
sanitary and storm sewer lines do not exist or are inaccurate and confusion arises regarding
the appropriate function of the sewer lines. In addition, when the activities within an
industrial facility change, floor drams and other discharge points, which are connected to the
separate storm sewer, may begin to receive drainage and discharges that should be sent to a
treatment plant. Such floor drains may receive a wide variety of discharges, including spills,
rinse waters, cooling waters, and even process wastewaters.
C-3
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Appendix C
Numerous factors may cause floor drains to be directed toward separate storm sewers.
Many floor drains in commercial and industrial facilities are positioned so that they collect
storm water running into a building, as well as cleaning water, spillage, and other non-storm
water discharges generated within a building. Urbanized areas have experienced rapid growth
since 1950. During much of that time, many municipalities did not provide adequate publicly
owned treatment works (POTW) service; the development of POTW capacity often lagged far
behind the rapid development of the urbanized area. When faced with limited POTW
capacity or inadequate POTWs, which could not handle toxic materials (e.g., solvents and
heavy greases), many municipalities encouraged developers to connect floor drains and other
nonsanitary sewage lines from commercial and industrial facilities to separate storm sewers.
Some municipal ordinances prohibited floor drains from being connected to the sanitary sewer
system.3 The operators of facilities with these types of improper connections usually do not
know whether floor drains and other types of drains discharge to a separate storm sewer or to
a sanitary sewer.
Recent studies in Michigan recognized that development that occurred while undersized
POTWs were in operation can create wide-spread illicit connections. For example, the Huron
River Pollution Abatement Program inspected 660 businesses, homes, and other buildings
discharging storm water to the Allen Creek drain in Washtenaw County, Michigan. Of the
buildings inspected, 14 percent were identified as having improper storm drain connections.
Illicit discharges were detected at a higher rate of 60 percent for automobile-related
businesses, including service stations, automobile dealerships, car washes, body shops, and
light industrial facilities. While some of the problems discovered in this study were the result
of improper plumbing or illegal connections, most connections were approved at the time they
were built.
3 Some municipalities have prohibited floor drain connections to sanitary sewers in overbroad efforts to comply with
EPA regulations at 40 CFR 35.927-4, which require grant applicants to demonstrate that municipalities have sewer use
ordinances prohibiting any new connections from inflow sources into the sanitary sewer portions of the sewer system.
C-4
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Appendix C
C.1.2 Sewer Maintenance/Restoration
As urban development grows, flows in the sanitary sewer system increase. In some
systems where flows during dry or wet weather have grown to exceed the hydraulic capacity
of sanitary sewers, the sanitary sewer has been intentionally cross connected to a storm sewer
systems. In some cases, formal connections or overflow devices have been installed and, in
others, holes are punched into the sanitary sewer to relieve the sanitary sewer of high flows.
Some cross-connections result in wet weather combined sewer overflows; others discharge
during dry weather events. Discharges from malfunctioning sanitary sewage pumping stations
are often directed toward storm sewers.
Incomplete separation of combined sewers may result in significant numbers of cross-
connections between the sanitary sewer system and the storm sewer system. Most
municipalities separate sewers primarily to prevent basement and street floodings, with
secondary consideration given to water quality concerns. Because separation operations are
expensive and can cause significant disruptions to street usage, short cuts may be taken to
satisfy flooding concerns at the lowest cost. EPA has recently issued a Combined Sewer
Overflow (CSO) Control Policy.4
C.2 INTERACTIONS WITH SEWAGE SYSTEMS
As sanitary sewage collection systems age, the systems develop leaks and cracks.
Municipalities have long recognized the problems of storm water infiltrating into sanitary
sewers, because this type of infiltration disrupts the operation of a POTW. However, the
reverse problem of sewage exfiltrating out of the sanitary sewer collection system can occur
during dry weather periods. Many sanitary collection systems were initially built between the
early 1900s and the mid-1950s. Sewer mams were constructed of asbestos cement,
bituminous fiber, brick, cast iron, redwood, or vitrified clay. Manholes were prepared from
brick and mortar or reinforced concrete. These aged materials, poorly constructed manholes
and joints, and main breaks may permit exfiltration. Sewage from a leaky sanitary system
4 Combined Sewer Overflow (CSO) Control Policy, EPA, 59 FR 18688 (April 19, 1994)
C-5
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Appendix C
can flow to a storm sewer or contaminate ground water supplies. An EPA study on sewer
exfiltration found significant ratios of the rate of exfiltration of raw sewage to the rate of
infiltration of ground water or storm water into sanitary sewers. Field and laboratory results
determined that this ratio varied between 1.5 to 1 and 14 to I.5 Not only are the ratio to
rates high, but exfiltration can occur during dry periods, as well as wet weather periods;
infiltration is more limited to wet weather periods or periods when the water table is high.
Separate storm sewers and sanitary sewers interactions can be caused by numerous
conditions. For example, interaction may occur at manholes and where sanitary sewer laterals
and storm sewer trenches cross. In addition, separate storm sewers and sanitary sewers may
share the same trench, which is generally filled with very porous material, such as gravel.
C.3 IMPROPER DISPOSAL
Improper disposal of materials may result in contaminated discharges from separate storm
sewers in two major ways. First, materials may be disposed of directly to a catchbasin or
other storm water conveyance. Second, materials disposed of on the ground may either drain
directly to a storm sewer or be washed into a storm sewer during a storm event.
Improper disposal to a separate storm sewer often occurs because many believe that
disposal of materials to street catchbasins and other separate storm sewer inlets is an
environmentally sound practice. Part of the confusion occurs because some areas are served
by combined sewers, which are part of the sanitary sewer collection system, and people
assume materials discharged to a catchbasin will reach an appropriate sewage treatment plant.
Materials that are commonly disposed of improperly Include used oil; household toxic
materials; radiator fluids; and litter, such as disposable cups, cans, and fast-food packages.
5 U.S. EPA, "Results of the Evaluation of Groundwater Impacts of Sewer Exfilttation", Municipal Facilities
Division, February 1989, Washington, DC.
C-6
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Appendix C
A 1984 survey of household disposal practices estimated that the following percentages of
households typically disposed of the materials listed directly to a storm sewer or a street:
• 3 percent of households—paints and thinners
• 11 percent of households—used motor oil
• 83 percent of households that flushed their own auto radiators—used radiator fluid
(anti-freeze contaminated with metals).
In addition, although common practice may have changed since 1985, the study estimated
that an additional 14 percent of households that changed their own motor oil disposed of the
motor oil by pouring it on the ground. Figures C-l through C-3 depict these data.
11%
32%
Contribute to Pollutant
Loads to Storm Water
Ground
Trash
Street
Recycle
Storage
Other
11%
Source: Russell and Meiorin, 1985.
Figure C-l. Disposal Practices of Households Generating Used Motor Oil
Sewer 83%
Street
17%
Source: Russell and Meiorin, 1985.
Figure C-2. Disposal Practices of Households Generating Radiator Flushings
C-7
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Appendix C
3%
• Sewer
D Ground
H Trash
E3 Street
76%
Contribute to pollutant
loads of storm water
Source: Russell and Meiorin, 1985.
Figure C-3. Disposal Practices for Households Generating Waste Paints and Thinner
A Department of Energy study (Brinkman, 1981) addresses common disposal methods of
used oil produced by do-it-yourself (DIY) oil changers. The study estimated that 342 million
gallons of used oil were drained during DIY oil changes annually and that 40 percent of this
used oil was poured on the ground. Figure C-4 shows the variety of types of oil disposal
methods used for the 40 percent of DIY oil disposed of by pouring on the ground. EPA
estimates that, 267 million gallons of used oil, including 135 million gallons of used oil from
DIY automobile oil changes, are disposed of improperly each year.
6%
•
3%
Poured on Gravel Driveway/Road
Dumped in Backyard
Used as a Weed Killer
Dumped in Woods/Vacant Lot
Buried
Poured into Storm Sewer
25% Let it Drain Where the Car Was
Source: Brinkman, 1981.
11%
30%
17%
jpigure c-4. Disposal Practices of Households Pouring Used Oil on the Ground
The General Accounting Office (GAO) report, Illegal Disposal of Hazardous Waste:
Difficult to Detect or Deter (1985) investigated illegal dumping of materials defined as
hazardous wastes under the Resource Conservation and Recovery Act (RCRA). Although the
C-8
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Appendix C
report was unable to estimate the extent of illegal dumping of hazardous wastes, it reported
that, based on surveyed officials in four States (i.e., Illinois, California, New Jersey, and
Massachusetts), some officials believed that many cases of illegal disposal occurred. The
report indicated that the Director of EPA's National Enforcement Investigation Center thinks
that many cases of criminal disposal occur on a widespread basis, and that EPA receives more
allegations than it can handle. The Director stated that the center received about 240
allegations that were judged as having good potential to involve violations during fiscal years
1982 through 1984.
The report indicated that cases of onsite waste disposal where pollutants were added to
runoff, which eventually ended up in drainage systems, and cases where a generator dumped
wastes directly down a drain, were common. Of the 36 cases of illegal dumping investigated
in the GAO report, 14 cases involved disposal of hazardous material directly to or with
drainage to a storm sewer, flood control structure, or side of a road. An additional 10 sites
involved disposal to the ground, landfills (other than those receiving hazardous wastes), trash
bins, which can then result in adding pollutants to subsequent storm water discharges.
Disposal scenarios in several other cases could not be determined.
The GAO report concluded that because RCRA regulations and compliance inspections
for generators and transporters were not designed to detect illegal disposal, local government
agencies, including flood control agencies and departments of transportation were particularly
important for detecting illegal dumping.
Businesses disposing of small amounts of hazardous waste may be of concern because
they do not fully understand hazardous waste disposal regulations and employee training
programs necessary to ensure proper disposal.
C.4 SPILLS
Spilled material may have a have a high potential for entering human-made drainage
systems. Until recently, an accepted practice to responding to spills was to flush the spilled
C-9
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Appendix C
material away. These removal methods may often result in flushing the spilled material into a
separate storm sewer.
A wide variety of materials, such as petroleum products, other liquid products, and waste
chemicals, may spill during transportation, transfer, use, and storage. The U.S. Coast Guard's
National Response Center (NRC) receives thousands of incident reports, involving hundreds of
substances each year. Summary data, provided by the NRC, categorized spilled materials as
either oil or hazardous substances defined under the CWA or the Comprehensive
Environmental Response, Compensation, and Liability Act. The term oil is used to represent
more than 90 different materials, including various grades of crude oil, naphtha, coal tar,
creosote, refined oils, gasoline, and jet fuel.
Table C-l summarizes the amounts of reported, oil and hazardous substances discharged
and the amounts reported in water during 1987 and 1988. As this table shows, significant
quantities of pollutants are reported to the NRC as spilled or dumped each year. Cleanup
activities are not initiated for each reported discharges. Where cleanup occurs, a significant
portion of a spill is often not recoverable. Although no data are available to substantiate the
number of unreported discharges, Merryman (1989) estimated that less than half of the
reportable incidents occurring each year are reported to the NRC. Many of these incidents
probably involve little cleanup activity because they were not reported to responsible
authorities.
C.5 MALFUNCTIONING SEPTIC SYSTEMS
In rural and suburban areas served by septic systems, malfunctioning septic systems can
contribute pollutants to separate storm sewers. Although septic systems work well in rural,
low-density areas with suitable soil and a deep water table, septic systems are often installed
in inappropriate areas, such as coastal areas, where rapid residential growth, particularly in
second-home development areas, has outdistanced the ability of local governments to build
sanitary sewers.
C-10
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Appendix C
Table C-l. Summary of U.S. Coast Guard National Response Center Data on
Discharges of Oil and CERCLA-Regulated Materials During 1987 and 1988
Oil Spills Affecting Land
Oil Spills Affecting Water
Oil Spills Amount in Water
Hazardous Substances Spills Affecting Land
Hazardous Substances Spills Affecting Water
Hazardous Substances Spills Amount in Water
1987
Gallons
4,988,282
3,613,555
5,278,773
1,969,080
3,664,065
3,636,764
1987
Pounds
-
-
-
3,354,591
656,843
347,230
1988
Gallons
6,426,228
4,637,600
2,949,694
4,201,392
5,244,696
2,320,874
1988
Pounds
-
—
—
2,565,142
856,852
415,204
Oil is defined by the NRC to include 94 materials, including gasoline, crude and refined oils, creosote, jet fuel,
diesel, naphtha, and coal tar.
Hazardous Substances include 494 materials either required by or containing substances regulated by CERCLA.
Surface malfunctions are caused by clogged or impermeable soils or when stopped up or
collapsed pipes force untreated wastewater to the surface. Surface malfunctions can vary in
degree from occasional damp patches on the surface to constant pooling or runoff of
wastewater to a storm sewer. These discharges have high bacteria, nitrate, and nutrient levels
and can contain a variety of household chemicals. One type of improper remedy to a surface
malfunction is to install a pipe or trench over soil absorption systems to route untreated
surface malfunction overflow away from the septic system, resulting in direct discharges to
drainage ditches, empty lots, or surface waters.
Malfunctioning septic systems may be a more significant surface runoff pollution problem
than a ground water problem. This is because a malfunctioning septic system is less likely to
cause ground water contamination where a bacterial mat in the soil retards the downward
movement of wastewater. (Poorly located septic systems that are operating properly are the
greatest threat to ground water.)
In addition to surface malfunctions, insufficiently treated wastewater from a septic system
may contaminate ground water, which may infiltrate into storm sewers, which serve as a
C-ll
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Appendix C
conduit to surface waters. Also, seepage of sewage or effluent into underground portions of
buildings can be pumped to separate storm sewers.
The 1992 Needs Survey estimates that approximately 30 percent of the population in the
United States is served by septic systems6.
C.6 INFILTRATION OF CONTAMINATED GROUND WATER
Many separate storm sewers discharge ground water that infiltrates into the storm sewer.
Usually, these discharges are not contaminated and, in general, do not pose direct pollutant
threats to surface waters. However, if ground water sources are contaminated by industrial or
other sources, the separate storm sewer serves as a conduit for the contaminated ground water
to surface waters. This process can greatly reduce pollutant removal associated with ground
water migration through soils, as well as reduce the dilution processes associated with ground
water plume migration. Conversely, observing contaminated discharges from separate storm
sewers during dry weather may be used as a tool to detect sources of ground water
contamination.
In addition to traditional industrial sources, ground water may be contaminated by a
number of commercial activities. One leading cause of ground water contamination from
commercial activities includes leaks from underground storage tanks (USTs) and underground
pipes. Underground storage tanks are used to store large amounts of potential pollutants, such
as petroleum products and chemicals. In 1987, EPA estimated that 676,000 UST systems
stored retail motor fuel, 651,000 stored other petroleum products, and 54,000 stored hazardous
chemicals in the United States. In addition, EPA estimated that potentially millions of other
small UST systems, such as hydraulic lift tanks and power cable conduits, contain dielectric
fluid. Pollutants leaking from these tanks may infiltrate through soil into either nearby
ditches or storm water pipes (Fields, 1989). A draft EPA report (Kaschak and Hargrove,
1988) reviewed corrective action case histories of 50 leaking UST sites. The report indicated
6 "1992 Needs Survey Report to Congress", EPA, September 1993.
C-12
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Appendix C
that surface water impacts were of concern at 14 percent of these sites, where fuels entered
storm drains or flowed over the surface, or where the source was located close to a stream or
surface waters.
C.7 ROAD OILING
EPA estimates that 70 million gallons of used oil, primarily supplied by service stations
and repair shops, are used for road oiling.
A study of two rural roads in New Jersey treated with waste crankcase oil indicated that
only 1 percent of the total oil applied to the road may remain on the road surface (Freestone
"Runoff of oils from rural roads treated to suppress dust" NERC, EPA, Cincinnati, OH,
1972). The study concluded that oil could have left the road surface by several means such as
volatilization, runoff, adhesion to vehicles, adhesion to dust particles with wind transport, and
biodegradation.
C-13
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APPENDIX D
NPDES STORM WATER PROGRAM QUESTION AND ANSWER DOCUMENT
VOLUMES I AND H
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NPDES
Storm Water Program
Question and Answer Document
SEPA
U.S. Environmental Protection Agency
Office of Wastewater Enforcement and Compliance
Permits Division
401 M Street, SW
Washington, DC 20460
March 1992
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CM0?E\OM030-03-2166-004(2)\Q&A\Q&A.DOC
INDUSTRIAL PERMIT APPLICATION QUESTIONS AND ANSWERS
Category i - Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
What kinds of facilities are included under category (i)?
Category (i) includes facilities subject to storm water effluent limitations
guidelines, new source performance standards, or toxic pollutant effluent
standards under Title 40 subchapter N of the Code of Federal Regulations
(CFR) (except facilities with toxic pollutant effluent standards which are
exempted under category (xi) of the definition of storm water discharge
associated with industrial activity). The term "storm water" modifies only
"effluent limitations guidelines." Facilities subject to subcategories with new
source performance standards, toxic pollutant effluent standards, or storm
water effluent limitation guidelines are required to submit a National Pollutant
Discharge Elimination System (NPDES) permit application for storm water
discharges associated with industrial activity.
What kinds of facilities are subject to storm water effluent guidelines?
The following categories of facilities have storm water effluent guidelines for at
least one of their subcategories: cement manufacturing (40 CFR 411); feedlots
(40 CFR 412); fertilizer manufacturing (40 CFR 418); petroleum refining (40
CFR 419); phosphate manufacturing (40 CFR 422); steam electric power
generation (40 CFR 423); coal mining (40 CFR 434); mineral mining and
processing (40 CFR 436); ore mining and dressing (40 CFR 440); and asphalt
(40 CFR 443). A facility that falls into one of these general categories should
examine the effluent guideline to determine if it is categorized in one of the
subcategories that have storm water effluent guidelines. If a facility is
classified as one of those subcategories, that facility is subject to the standards
listed in the CFR for that category, and as such, is required to submit a storm
water discharge permit application.
What kinds of facilities are subject to "toxic pollutant effluent
standards"?
First, it is important to understand the term toxic pollutant. Toxic pollutants
refers to the priority pollutants listed in Tables II and III of Appendix D to 40
CFR part 122 (not 40 CFR Part 129). If any of these toxic pollutants are
limited in an effluent guideline to which the facility is subject (including
pretreatment standards), then the facility must apply for a storm water permit.
1
March 16, 1992
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CV401E\01-1030-03-2166-004(2)\Q&A\Q&A.DOC
4.
The following categories of facilities have toxic pollutant effluent standards for
at least one subcategory:
Textile mills (40 CFR 410)
Electroplating (40 CFR 413)
Organic chemicals, plastics, and synthetic fibers (40 CFR 414)
Inorganic chemicals (40 CFR 415)
Petroleum refining (40 CFR 419)
Iron and steel manufacturing (40 CFR 420)
Nonferrous metals manufacturing (40 CFR 421)
Steam electric power generating (40 CFR 423)
Ferroalloy manufacturing (40 CFR 424)
Leather tanning and finishing (40 CFR 425)
Glass manufacturing (40 CFR 426)
Rubber manufacturing (40 CFR 428)
Timber products processing (40 CFR 429)
Pulp, paper, and paperboard (40 CFR 430)
Metal finishing (40 CFR 433)
Pharmaceutical manufacturing (40 CFR 439)
Ore mining and dressing (40 CFR 440)
Pesticide chemicals (40 CFR 455)
Photographic processing (40 CFR 459)
Battery manufacturing (40 CFR 461)
Metal molding and casting (40 CFR 464)
Coil coating (40 CFR 465)
Porcelain enameling (40 CFR 466)
Aluminum forming (40 CFR 467)
Copper forming (40 CFR 468)
Electrical and electronic components (40 CFR 469)
Nonferrous metals forming and metal powders (40 CFR 471)
What kinds of facilities are subject to "new source performance
standards"?
Most effluent guidelines listed in subchapter N contain New Source
Performance Standards (NSPS). A facility that is subject to a NSPS as
defined for that particular effluent guideline is required to submit a permit
application for the storm water discharges associated with industrial activity at
that site. The definition of a new source varies based on the publication date
of the particular effluent guideline.
The following categories of 40 CFR Subchapter N facilities do not have new
source performance standards. All other categories have at least one
subcategory with new source performance standards.
2 March 16, 1992.
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CW01EI01-1030-03-2166-004(2)\Q&A\Q&A.DOC
Oil and Gas Extraction (40 CFR 435)
Mineral Mining and Processing (40 CFR 436)
Gum and Wood Chemicals Manufacturing (40 CFR 454)
Pesticide Chemicals (40 CFR 455)
Explosives Manufacturing (40 CFR 457)
Photographic (40 CFR 459)
Hospital (40 CFR 460)
5.
If a facility is included under the description of both category (i) and
category (xi), is that facility required to submit a storm water permit
application if material handling equipment or activities, raw materials,
intermediate products, final products, waste materials, by-products, or
industrial machinery are not exposed to storm water?
The answer depends on why the facility is included in category (i). If the
facility is included in category (i) because it is subject to storm water effluent
standards or new source performance standards, the facility is required to
apply for a permit regardless of whether it has exposure or not. Facilities that
are included in category (i) only because they have toxic pollutant effluent
standards are not required to submit an application if they indeed have no
exposure to material handling equipment or activities, raw materials,
intermediate products, final products, waste materials, by-products, or industrial
machinery.
Categories ii, iii, vi, viii, and xi
6.
What industrial groups are covered by Standard Industrial Classification
(SIC) codes that are used in the definition of storm water discharge
associated with industrial activity?
The following SIC codes and associated industries are included in the
indicated categories of the definition:
Category (ii)
24 (except 2434) - Lumber and Wood Products (except wood kitchen
cabinets)
26 (except 265 and 267) - Paper and Allied Products (except
paperboard containers and products)
28 (except 283 and 285) - Chemicals and Allied Products (except drugs
and paints)
29 - Petroleum Refining Industries
311 - Leather Tanning and Finishing
March 16, 1992
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C\401E\01-1030-03-2166-004(2)\Q&A\Q&A.DOC
32 (except 323) - Stone/Clay/Glass and Concrete Products (except
glass products made of purchased glass)
33 - Primary Metal Industries
3441 - Fabricated Structural Metals
373 - Ship and Boat Building and Repairing
Category
10 - Metal Mining
12 - Coal Mining
13 - Oil and Gas Extraction
14 - Nonmetallic Minerals
Category (vi)
5015 - Motor Vehicles Parts, Used
5093 - Scrap and Waste Materials
Category (viii)
40 - Railroad Transportation
41 - Local Passenger Transportation
42 (except 4221-4225) - Trucking and Warehousing (except public
warehousing and storage)
43 - U.S. Postal Service
44 - Water Transportation
45 - Transportation by Air
5171 - Petroleum Bulk Stations and Terminals
Category (xi)
20 - Food and Kindred Products
21 - Tobacco Products
22 - Textile Mill Products
23 - Apparel Related Products
2434 - Wood Kitchen Cabinets Manufacturing
25 - Furniture and Fixtures
265 - Paperboard Containers and Boxes
267 - Converted Paper and Paperboard Products
27 - Printing, Publishing, and Allied Industries
283 - Drugs
285 - Paints, Varnishes, Lacquer, Enamels, and Allied Products
30 - Rubber and Plastics
31 (except 311) - Leather and Leather Products (except leather
tanning and finishing)
323 - Glass Products
34 (except 3441) - Fabricated Metal Products (except fabricated
structural metal)
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35 - Industrial and Commercial Machinery and Computer Equipment
36 - Electronic and Other Electrical Equipment and Components
37 (except 373) - Transportation Equipment (except ship and boat
building and repairing)
38 - Measuring, Analyzing, and Controlling Instruments
39 - Miscellaneous Manufacturing Industries
4221-4225 - Public Warehousing and Storage
Category iii - Mining and Oil & Gas Operations
7. Are inactive mines included in the regulation?
Two conditions must be met for an inactive mine to be required to submit a
storm water discharge permit application. First, the facility must have a
discharge of storm water that has come into contact with any overburden, raw
material, intermediate products, finished products, byproducts, or waste
products located on the site of the facility. The second condition depends on
the type of mining activity.
Inactive non-coal mining operations must apply until such sites are released
from applicable State or Federal reclamation requirements after December 17,
1990. Non-coal mining operations released from applicable State or Federal
requirements before December 17, 1990, must apply for an NPDES storm
water discharge permit if the storm water discharges are contaminated as
discussed above.
Inactive coal mining operations must apply unless the performance bond
issued to the facility by the appropriate Surface Mining Control and
Reclamation Act (SMCRA) authority has been released.
8.
Are any oil & gas exploration, production, processing, or treatment
operations, or transmission facilities classified under SIC code 13,
exempt from having to apply for a storm water permit?
Yes, such facilities are exempt unless they have discharged storm water after
November 16, 1987, containing a Reportable Quantity (RQ) of a pollutant for
which notification is or was required pursuant to 40 CFR 117.21, 40 CFR
302.6, or 40 CFR 1 10.6; or if a storm water discharge from the facility
contributes to a violation of a water quality standard, as set forth in 40 CFR
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9. What is a reportable quantity for discharges from an oil or gas
operations?
As defined at 40 CFR 110.6, an RQ is the amount of oil that violates
applicable water quality standards or causes a film or sheen upon or a
discoloration of the surface of the water or adjoining shorelines or causes a
sludge or emulsion to be deposited beneath the surface of the water or upon
adjoining shorelines (40 CFR part 110.6). The RQs for other substances are
listed in 40 CFR 117.3 and 302.4 in terms of pounds released over any 24-
hour period.
10. Are access roads for mining operations covered?
Any construction that disturbs 5 acres or more of total land area must apply for
a storm water discharge permit.
After construction, roads for mining operations would not be included unless
storm water runoff from such roads mixes with storm water that is
contaminated by contact with overburden, raw materials, intermediate products,
finished products, byproducts, or waste products. When roads are constructed
out of materials such as overburden or byproducts, an application for an
NPDES storm water discharge permit would be required.
Category iv - Hazardous Waste Treatment, Storage, or Disposal Facilities
11. Is a facility that stores hazardous waste less than 90 days required to
submit an application?
It is EPA's intent to cover those facilities that are operating under interim status
or permit under the Resource Conservation and Recovery Act (RCRA) subtitle
C. As such, only facilities meeting the definition of a hazardous waste
treatment, storage, or disposal facility under RCRA are expressly included in
this category. A facility that stores hazardous waste less than 90 days is not
considered to be a treatment, storage, or disposal facility, and therefore is not
required to submit a storm water permit application.
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Category v - Landfills, Land Application Sites and Open Dumps
12. Do closed or inactive landfills need to apply for a permit?
Yes. Any landfill, active, inactive or closed, must apply for a permit if it
receives, or has received, wastes from the industrial facilities identified under
122.26(b)(14)(i)-(xi). To the extent that control measures and best
management practices address storm water, the permit may incorporate those
control measures.
13. Does a landfill that receives only the office waste and/or cafeteria waste
from industrial facilities have to apply for an NPDES permit?
No. Only landfills that receive or have received waste from manufacturing
portions of industrial facilities need to apply for a permit.
Category vi - Recycling Facilities
14. Are gas stations or repair shops that collect tires or batteries classified in
the "recycling" category?
No. Only those facilities classified in SIC codes 5015 (used motor vehicle
parts) and 5093 (scrap and waste materials) are in the "recycling" category.
This includes facilities such as metal scrap yards, battery reclaimers, salvage
yards, and automobile junk yards.
15. Are municipal waste collection sites included in category (vi)?
No. Municipal waste collection sites where bottles, cans, and newspapers are
collected for recycling purposes are not classified as SIC codes 5015 or 5093.
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Category vii - Steam Electric Power Generating Facilities
16. Are offsite transformer areas regulated under the NPDES storm water
rule?
No. Upon examination of the Toxic Substances Control Act, EPA determined
that the regulation of storm water discharges from these facilities should be
studied under Section 402(p)(5) of the Clean Water Act (CWA) (55 FR 48013).
Future regulations may be developed to address these areas.
17. Are storm water discharges from electrical substations included in the
definition of industrial activity?
No. Electrical substations are not covered by this regulation.
18. Are storm water discharges from coal piles that are located offsite from
the power station included in the definition of industrial activity?
No. Offsite coal piles are not covered by this regulation. In order to be
included, a coal pile must be located on the site of a facility defined by the
regulation as being "engaged in an industrial activity."
19. Are storm water discharges from co-generation facilities included in the
definition of industrial activity?
A heat capture co-generation facility is not covered under the definition of
storm water discharge associated with industrial activity; however, a dual fuel
co-generation facility is included and therefore must submit an application for
the storm water discharges associated with industrial activity.
20. Are university power plants included in the definition of industrial
activity?
Yes. A university steam electric power generating facility is required to apply
for a storm water discharge permit.
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Category viii - Transportation Facilities
21. Are gas stations and automotive repair shops required to apply for an
NPDES storm water discharge permit?
No. These facilities are classified in SIC codes 5541 (gasoline filling stations)
and 7538 (automotive repair shops). The storm water rule generally does not
address facilities with SIC classifications pertaining to wholesale, retail, service
or commercial activities. Additional regulations addressing these sources may
be developed under Section 403(p)(6) of the CWA if studies required under
Section 402(p)(5) indicate the need for regulation.
22. Does a vehicle maintenance shop or an equipment cleaning facility need
to apply for a permit?
Yes, if the shop is categorized by the SIC codes listed in the transportation
category of facilities engaged in industrial activity [i.e., SIC codes 40, 41, 42
(except 4221-25) 43, 44, 45 and 5171]. Only the vehicle maintenance
(including vehicle rehabilitation, mechanical repairs, painting, fueling, and
lubrication) and equipment cleaning areas (such as truck washing areas) must
be addressed in the application.
As explained above, gas stations are classified in SIC code 5541 and
automotive repair services are classified as SIC code 75, which are not
included in the regulatory definition of industrial activity, and therefore are not
required to submit NPDES storm water discharge permit applications.
23. Are municipally owned and/or operated school bus maintenance facilities
required to apply for an NPDES permit?
No. The SIC Manual states that "school bus establishments operated by
educational institutions should be treated as auxiliaries" to the educational
institution. Since the SIC code assigned to educational institutions is 82, the
municipally operated (i.e., by a school board, district, or other municipal entity)
school bus establishments would not be required to apply for an NPDES permit
for their storm water discharges. Private contract school bus services are
required to apply for an NPDES permit for their storm water discharges.
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24. Is SIC code 4212 always assigned to facilities with dump trucks?
No. The maintenance facility must be primarily engaged in maintaining the
dump truck to be characterized as SIC code 4212. Dump trucks used for road
maintenance and construction and facilities that maintain these trucks are
classified under SIC code 16 (heavy construction other than building
construction) and therefore would not be characterized as engaging in
industrial activity.
25.
26.
How does a municipality determine what type of vehicle a particular
maintenance facility is primarily engaged in servicing?
The SIC Manual recommends using a value of receipts or revenues approach
to determine what is the primary activity of a facility. For example, if a
maintenance facility services both school buses and intercity buses, the facility
would total receipts for each type of vehicle and whichever generated the most
revenue, would be the vehicle type that the facility is primarily engaged in
servicing. If data on revenues and receipts are not available, the number of
vehicles and frequency of service may be compared. If a facility services more
than two types of vehicles, whichever type generates the most (not necessarily
greater than half of the total) revenue, or is most frequently serviced, is the
vehicle type the facility is primarily engaged in servicing.
is a municipal maintenance facility that is primarily engaged in servicing
garbage trucks required to apply for a permit?
The answer depends on the SIC code assigned to the establishment. If the
municipality also owns the disposal facility (e.g., landfill, incinerator) that
receives refuse transported by the trucks, then the maintenance facility would
be classified as SIC code 4953 and thus would not be required to apply for a
permit unless the maintenance facility was located at a facility covered under
one of the other categories of industrial activity (e.g., a landfill that receives
industrial waste). If, however, the municipality does not own the disposal
facility, the truck maintenance facility would be classified as SIC code 4212
and thus would be required to apply for a permit. If other vehicles are serviced
at the same maintenance facility, the facility may not be required to submit a
permit application (see question #25 above).
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27. Are fire trucks or police cars included in the transportation SIC codes?
No. The operation of fire trucks and police cars are classified under public
order and safety (SIC code 92); therefore, the operator of a facility primarily
engaged in servicing those vehicles would not be required to apply for a
permit.
Do all airports need to apply for a storm water discharge permit?
28.
29.
30.
No, only those airports classified as SIC code 45. Only those portions of the
facility that are either involved in vehicle maintenance (including vehicle
rehabilitation, mechanical repairs, painting, fueling, and lubrication), equipment
cleaning, or airport deicing or which are otherwise identified under
122.26(b)(14)(i)-(vii) or (ix-xi) are required to be permitted. Airports that are
not engaged in such activities do not require storm water discharge permits.
Facilities primarily engaged in performing services that incidentally use
airplanes (e.g., crop dusting and aerial photography) are classified according to
the service performed.
Is the deicing of airplanes, runways, or both included in airport deicing
operations?
Airports or airline companies must apply for a storm water discharge permit for
locations where deicing chemicals are applied. This includes, but is not limited
to, runways, taxiways, ramps, and areas used for the deicing of airplanes. The
operator of the airport should apply for the storm water discharge permit with
individual airline companies included as co-applicants.
Who is responsible for seeking permit coverage at an airport that has
many companies using the facility and discharging storm water?
The operator is responsible for seeking coverage. EPA strongly encourages
cooperation between the airport authority and all operating airlines at that
airport. Each operator is responsible for coordinating with the others and they
may act as co-applicants. Please note that under 122.26(a)(6) the Director
has the discretion to issue individual permits to each discharger or to issue an
individual permit to the airport operator and have other dischargers to the
same system act as co-permittees to the permit issued to the airport operator.
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31. Are railroad facilities included?
Railroad facilities, classified as SIC code 40, which have vehicle maintenance
activities, equipment cleaning operations or are otherwise identified under
122.26(b)(14)(i)-(vii) or (ix)-(xi) need to apply for a permit.
32. Are repairs along a railroad system considered to be vehicle maintenance
and thus regulated?
No. Only nontransient vehicle maintenance shops are included in the
transportation category.
33. Are tank farms at petroleum bulk storage stations covered by the rule?
No, unless the storm water discharge from the tank farm area commingles with
storm water from any vehicle maintenance shops or equipment cleaning
operations located onsite. However, tank farms located onsite with other
industrial facilities, as defined in 122.26(b)(14), are included in the regulation.
34. is a parking lot associated with a vehicle maintenance shop included in
the regulation?
Yes. Under 122.26 (b)(14)(viii) vehicle maintenance and equipment cleaning
operations are considered industrial activity. Parking lots used to store vehicles
prior to maintenance are considered to be a component of the vehicle
maintenance activity.
35. Is the fueling operation of a transportation facility (SIC codes 40 through
45) covered if there are no other vehicle maintenance activities taking
place at the facility?
Yes. A nonretail fueling operation is considered vehicle maintenance [see
122.26(b)(14)(viii)] and requires an NPDES storm water discharge permit
application.
36. Is a manufacturing facility's offsite vehicle maintenance facility required
to apply for a permit under the transportation category?
No. An offsite vehicle maintenance facility supporting one company would not
be required to apply for a permit if that company is not primarily engaged in
providing transportation services and therefore would not be classified as SIC
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code 42. The maintenance facility would be considered an auxiliary operation
to the manufacturing facility. For a full discussion on auxiliary facilities see
page 13 through 17 of the 1987 Standard Industrial Classification Manual. If
the maintenance facility is located on the same site as the manufacturing
operation, it would be included in the areas associated with industrial activity
and must be addressed in an application.
37. Is a marina required to apply for a storm water permit if it operates a
retail fueling operation, but other vehicle maintenance or equipment
cleaning activities are not conducted onsite?
Facilities that are "primarily engaged" in operating marinas are best classified
as SIC 4493 - marinas. These facilities rent boat slips, store boats, and
generally perform a range of other marine services including boat cleaning and
incidental boat repair. They frequently sell food, fuel, fishing supplies, and
may sell boats. For facilities classified as 4493 that are involved in vehicle
(boat) maintenance activities (including vehicle rehabilitation, mechanical
repairs, painting, fueling, and lubrication) or equipment cleaning operations,
those portions of the facility that are involved in such vehicle maintenance
activities are considered to be associated with industrial activity and are
covered under the storm water regulations.
Facilities classified as 4493 that are not involved in equipment cleaning or
vehicle maintenance activities (including vehicle rehabilitation, mechanical
repairs, painting, and lubrication) are not intended to be covered under 40 CFR
Section 122.26(b)(14)(viii) of the storm water permit application regulations.
The retail sale of fuel alone at marinas, without any other vehicle maintenance
or equipment cleaning operations, is not considered to be grounds for
coverage under the storm water regulations.
Marine facilities that are "primarily engaged" in the retail sale of fuel and
lubricating oils are best classified as SIC code 5541 - marine service stations -
and are not covered under 40 CFR Section 122.26(b)(14)(viii) of the storm
water permit application regulations. These facilities may also sell other
merchandise or perform minor repair work.
Facilities "primarily engaged" in the operation of sports and recreation services
such as boat rental, canoe rental, and party fishing, are best classified under
SIC code 7999 - miscellaneous recreational facilities - and are not covered
under 40 CFR Section 122.26(b)(14)(viii).
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Category ix - Sewage Treatment Works
38. Are storm water permit applications required for offsite (i.e., physically
separated from the main treatment works property) pumping stations?
No, storm water permit applications are not required for such sites.
39. Are separate permit applications required for vehicle maintenance/
washing facilities (located either onsiite or offsite) associated with a
wastewater treatment plant and owned/operated by the wastewater
treatment agency?
Offsite vehicle maintenance facilities would not be required to submit
applications unless they serve multiple clients since they do not fit the SIC
codes listed in the transportation category of facilities engaged in industrial
activity. Onsite vehicle maintenance/cleaning operations are associated with
industrial activity and must be included in the application.
40. Do wastewater treatment facilities that collect their storm water runoff
and treat the storm water as part of the normal inflow that is processed
through the treatment plant have to apply for a permit?
No. If a facility discharges its storm water into the headworks of the treatment
plant, it is essentially the same as discharging to a combined system or to a
sanitary system and is therefore exempt from the requirements of 122.26(c).
41. The definition states that offsite areas where sludge is beneficially reused
are not included as storm water discharges associated with industrial
activity. How is beneficial reuse defined?
Beneficial sludge reuse is the application of sludge as a nutrient builder or soil
conditioner. Examples include agricultural or domestic application.
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Category x - Construction Activities
42. Is a construction site of five acres or more subject to the same deadline
as other industrial facilities?
The individual application deadline for all storm water discharges associated
with industrial activity is 10/1/92. If a construction activity is completed by
10/1/92, an application is not required.
43. What is the duration of an NPDES permit issued for a construction
activity?
The permit will be effective as long the construction activity continues, but no
longer than five years. If the construction continues beyond five years, the
owner/operator must apply for a new permit.
44. Does the construction category only include construction of industrial
buildings?
No. Any construction activity, including clearing, grading, and excavation, that
results in the disturbance of five acres of land or more in total is covered by
the rule. Such activities may include road building, construction of residential
houses, office buildings, or industrial buildings, and demolition activity.
However, this does not apply to agricultural or silvicultural activities, which are
exempt from NPDES permit requirements under 40 CFR 122.4.
45. Does the rule require that storm water discharges after construction be
addressed?
Yes. The individual application must describe proposed measures to control
pollutants in storm water discharges that will occur after construction
operations are complete, including a description of State and local erosion and
sediment control specifications.
Please Note: EPA believes that construction activities should be covered under
a storm water general permit wherever possible. 40 CFR 122.21 (c)(1) allows the
permitting authority to establish different and shorter submittal dates under the
specific terms of a particular general permit.
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46. The definition states that the operators of construction activity that
disturb less than five acres are not required to apply for a permit unless
that construction is part of a larger common plan of development or sale.
What is meant by "part of a larger common plan of development or sale"?
"Part of a larger common plan of development or sale" is a contiguous area
where multiple separate and distinct construction activities may be taking place
at different times on different schedules under one plan. Thus, if a distinct
construction activity has been identified onsite by the time the application
would be submitted, that distinct activity should be included as part of the
larger plan.
47. Who is responsible for applying for a storm water permit?
The operator is responsible for applying for the permit as required by
122.21 (b). In the case of construction, the owner may submit an application
for a construction activity if the operators have not yet been identified.
However, once the operators have been identified, they must become either
sole permittees or co-permittees with the owner. The operator is determined
by who has day to day supervision and control of activities occurring at a site.
In some cases, the operator may be the owner or the developer, at other sites
the operator may be the general contractor.
Category xi - Light Industrial Facilities
48. If a category (xi) facility has determined that there is no exposure of
certain activities or areas listed in the definition to storm water and the
operator does not file a permit application, how does the operator prove,
if asked, that he/she did not need to apply?
There are no requirements set forth under the November 16, 1990, rule.
However, the operator may want to document the facility evaluation which led
to the conclusion that there is no exposure to storm water. This
documentation should be retained onsite. Some States may have specific
requirements. A facility is advised to check with its NPDES permitting authority
for additional requirements.
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49. Do those industries listed in 122.26(b)(14)(xi) that only have access roads
and rail lines exposed to storm water need to apply for a permit?
No. As stated in 122.26 (b)(14), facilities in category (xi) do not have to apply
for a permit if storm water only is exposed to access roads and rail lines.
50. If air pollution control equipment vents on the roof are exposed to storm
water, does this constitute exposure and trigger a permit condition?
No. The exposure of air pollution control equipment vents does not in itself
constitute exposure. It is possible, however, that even with the use of air
pollution control equipment, significant pollutants may be exposed to storm
water. For example, if a cyclone, a common particulate control device, is used
alone, only about 80 percent of the potential pollutants would be removed. 20
percent of the pollutants may then come into contact with storm water. In this
case, a permit application is required.
51. If there has been past exposure, can a facility change its operation to
eliminate exposure, and thus become exempt?
Yes. If a category (xi) facility can change its operation and eliminate all
exposure, the facility may be exempt from the regulation. It is important to
note, however, that eliminating exposure may include clean up as well.
52. Is a covered dumpster containing waste material kept outside considered
exposure?
No, as long as the container is completely covered and nothing can drain out
holes in bottom, or is lost in loading onto a garbage truck, this would not be
considered exposure.
General Applicability
53. How is a storm water outfall from an industrial site defined for the
purpose of sampling?
An industrial outfall is the point at which storm water associated with industrial
activity discharges to waters of the United States or a separate storm sewer.
Separate storm sewers may be roads with drainage systems, municipal
streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains.
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54. Are tank farms considered to be associated with industrial activity?
Yes, if they are located at a facility described in the definition of storm water
discharge associated with industrial activity. Tank farms are used to store
products and materials used or created by industrial facilities, and therefore
are directly related to manufacturing processes. However, tank farms
associated with petroleum bulk storage stations, classified as SIC code 5171,
at which no vehicle maintenance or equipment cleaning operations occur, are
exempt.
55. is an offsite warehouse associated with a regulated industrial facility
required to submit an application?
No. As stated on page 48011 of the preamble to the November 16, 1990, rule,
warehouses of either preassembly parts or finished products that are not
located at an industrial facility are not required to submit an application unless
otherwise covered by the rule.
56. If a facility has more than one industrial activity, how many applications
are required?
Only one application is required per facility. Permit conditions will address the
various operations at the facility. The application must reflect all storm water
discharges from areas associated with industrial activity as described in the
definition at 122.26(b)(14). The activity in which a facility is primarily engaged
determines what SIC code is assigned to that facility. To determine the activity
in which a facility is primarily engaged, The SIC Manual recommends using a
value of receipts or revenues approach. For example, if a facility
manufactures both metal and plastic products, the facility would total receipts
for each operation and the operation that generated the most revenue for the
facility is the operation in which the facility is primarily engaged. If revenues
and receipts are not available for a particular facility, the number of employees
or production rate may be compared. If a facility performs more than two
types of operations, whichever operation generates the most (not necessarily
the majority) revenue or employs the most personnel, is the operation in which
the facility is primarily engaged.
57. Are industrial facilities located in municipalities with fewer than 100,000
residents required to apply for a permit?
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Yes. All industrial discharges of storm water through separate storm sewers or
into waters of the United States must apply for an NPDES permit.
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58. If the SIC code for the activity in which a facility is primarily engaged is
not included in the definition of storm water discharge associated with
industrial activity, but the facility has a secondary SIC code that is
included in the definition, is the facility required to submit an NPDES
storm water permit application?
For purposes of this regulation, a facility's SIC code is determined based on
the primary activity taking place at that facility. In the case described above,
the facility is not required to apply for an NPDES storm water discharge permit.
However, if the facility conducts an activity on the site identified in the narrative
descriptions of categories (i), (iv), (v), (vii), or (x), then the facility would be
required to submit an NPDES storm water permit application for portions of the
facility used for the activities described in those categories.
59. Are military bases or other Federal facilities regulated under this rule?
Yes. Industrial activities identified under 122.26(b)(14)(r)-(xi) that Federal,
State, or Municipal governments own or operate are subject to the regulation.
60. Does the regulation require a permit for storm water discharges to a
publicly owned treatment works?
No. A discharge to a sanitary sewer or a combined sewer system is not
regulated under the storm water regulation. Storm water discharges either to
waters of the United States or separate storm sewer systems require a permit
if associated .with any of the industrial facilities listed in 122.26(b)(i) - (xi).
61. Are there any limits or size restrictions which narrow the scope of
facilities requiring an application?
The only restrictions regarding size are for construction activities and sewage
treatment works. All construction activities must apply for permit coverage
except for operations that disturb less than five acres of total land which are
not part of a larger common plan of development or sale. Sewage treatment
works designed to treat one million gallons per day or more must submit an
NPDES permit application.
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62.
63.
64.
65.
66.
Do pilot plants or research and development facilities classified within
one of the regulated SIC codes need to apply for a permit?
A pilot plant or research facility classified by an SIC code which is specified
under 122.26(b)(14)(i)-(xi) would be required to submit an application. A pilot
plant or research facility's operations can be directly related to the
manufacturing operations of the full-scale facility and therefore warrant a
permit.
Are stockpiles of a final product from an industrial site that are located
away from the industrial plant site, included under the definition of storm
water discharge associated with industrial activity?
Such stockpiles would not be covered because they are not located at the site
of the industrial facility.
If a facility has a NPDES permit for its process wastewater and some, but
not all, of its storm water discharges associated with industrial activity,
does the operator need to apply?
The operator must ensure that all storm water discharges associated with
industrial activity are covered by an NPDES permit. The operator may wish to
submit an individual application, participate in a group application, or seek
coverage under a general permit for any remaining outfalls that are not
covered by an existing NPDES permit. The permitting authority may also wish
to modify the existing NPDES permit to cover the other storm water
discharges.
A facility holds a recently renewed NPDES permit which does not cover
storm water discharges. Does that facility need to apply?
Yes. If the facility is identified in paragraph 122.26(b)(14)(i) through (xi) of the
rule, that facility may wish to submit an individual application, participate in a
group application, or seek coverage under a general permit for any remaining
outfalls that are not covered by an existing NPDES permit. The permitting
authority may also wish to modify or reissue the existing NPDES permit to
cover the other storm water discharges.
If a regulated company owns and operates a subsidiary which is of a
wholesale or commercial nature, would the subsidiary need to apply?
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No. Since the subsidiary facility's operations are of a wholesale or commercial
orientation, the operations are not considered to be industrial and therefore
would not be covered by this rule unless they are specifically covered by one
of the SIC codes or narrative descriptions in 122.26(b)(14).
67. Can an applicant claim confidentiality on information contained in an
NPDES permit application?
No. Under 40 CFR 122.7(b), the permitting authority will deny claims of
confidentiality for the name and address of any permit applicant or permittee,
permit applications, permits, and effluent data.
68. Do the November 16, 1990, regulations modify the requirements of
existing storm water effluent guidelines?
No. Existing storm water effluent guidelines are still applicable.
69. Which application forms are industries responsible for submitting?
For discharges composed entirely of storm water, operators should
submit Form 1 and Form 2F.
For discharges of storm water combined with process wastewater,
operators should submit Form 1, Form 2F, and Form 2C.
For storm water discharged in combination with nonprocess wastewater,
operators should submit Form 1, Form 2F, and Form 2E.
For new sources or new discharges of storm water which will be
combined with other non-storm water, operators should submit Form 1,
Form 2F, and Form 2D.
70. Are Superfund sites regulated under this rule?
Yes, if the site is assigned an SIC code or fits the description of one of the
categories listed in the definition of storm water discharge associated with
industrial activity. Under the Superfund Amendment and Reauthorization Act
(SARA) section 121(E), Superfund sites are required to "substantively comply"
with all environmental regulations.
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71. Are areas used for the disposal of industrial wastewaters and sanitary
wastewaters included in the definition of "associated with industrial
activity"?
Yes, the definition includes sites used for process water land application that
are not used for agricultural activities.
72. Do inactive industrial facilities need to apply?
Yes, if the facility is included in the definition of storm water discharge
associated with industrial activity and significant materials remain on site and
are exposed to storm water runoff (p.48009 of 11/16/91 Federal Register).
The regulation defines significant materials at 122.26 (b)(13) as including, but
not limited to, raw materials; fuels; materials such as solvents, detergents, and
plastic pellets; finished materials such as metallic products; raw materials used
in food processing or production; hazardous substances designated under
section 101(14) of the Comprehensive Environmental Response,
Compensation, and Liability Act; any chemical the facility is required to report
pursuant to section 313 of title III of SARA; fertilizers; pesticides; and waste
products such as ashes, slag and sludge that have the potential to be released
with storm water discharges.
73. Can a facility apply for an individual permit after completing the group
application or applying for coverage under a general permit?
This option is available, but the operator is advised to discuss the matter
directly with the permitting authority.
74. If a facility is totally enclosed with no materials or activities exposed to
storm water, but has a point source discharge of storm water, is a permit
application required?
If the facility is described in categories 122.26(b)(14)(i-x) a permit application is
required regardless of the actual exposure of materials or activities to storm
water. If the facility is described in 122.26(b)(14)(xi), a permit application is
required only if there is exposure of materials or activities to storm water.
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75. How does a municipally owned industrial facility apply for an NPDES
permit?
Such a facility must meet the same application requirements as any other
industrial facility. The facility may submit an individual permit application
(Forms 1 and 2F), participate in a group application, or seek coverage under
an available general permit.
76. Who is required to submit Form 1?
Anyone submitting NPDES application Forms 2C, 2D, 2E, 2F, or a construction
individual application is required to submit Form 1.
77. Before the October 1, 1992, individual application deadline, which forms
must a facility submit to renew its NPDES permit for a storm water
discharge?
Since the individual storm water application is not due until October 1, 1992,
EPA is allowing such facilities to choose whether the storm water discharges
are identified on a Form 2C or a Form 2F. After October 1, 1992, a facility
must submit an application in accordance with 40 CFR 122.26(c) (i.e., Forms 1
and 2F).
78. Are washwaters and/or noncontact cooling waters (e.g., air conditioner
condensate) included in the definition of storm water?
No. "Storm water" means storm water runoff, snow melt runoff, and surface
runoff and drainage. Washwaters are usually considered to be process
wastewater. Noncontact cooling waters are considered a nonprocess
wastewater.
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March 16, 1992
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NPDES
Storm Water Program
Question and Answer Document
Volume II
U.S. Environmental Protection Agency
Office of Wastewater Enforcement and Compliance
Permits Division
401 M Street, SW
Washington, DC 20460
July 1993
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TABLE OF CONTENTS
Pace
I. General Applicability .................................... 1
II. Definition of Storm Water Discharge Associated With Industrial Activity . 6
Category (i): . . ............ . ....... ..................... 6
Category (iii): ......................................... 6
Category (iv): ......................................... 8
Category (v): ......................................... 8
Category (viii): ........................................ 9
Category (x): ......................................... 10
Category (xi): ........................... • ............. 14-
III. Individual Permits ......................... ............. 15
IV. EPA General Permits .................................... 1?
V. Group Applications ........... • ......................... 26
VI. Sampling ................. • .......................... 26
VII. Municipal Permit Applications .............................. 29
VIII. The Intermodal Surface Transportation Efficiency Act of 1991
(Transportation Act) .................................... 31
IX. 9th Circuit U.S. Court of Appeals Decision ..................... 32
X. Phase II . . ........................................... 32
XI. List of Storm Water Contacts ........ . ..................... 35
XII. State NPDES Program Status .............................. 53
XIII. Regulatory Definitions ........ ........ ................... 54
XIV. Industrial Classification of Auxiliary Establishments ............. • • 56
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USEFUL ACRONYMS
BAT Best Available Technology
BCT Best Conventional Technology
BMP Best Management Practice
CFR Code of Federal Regulations
CSO Combined Sewer Overflow
CWA Clean Water Act
CZARA Coastal Zone Act Reauthorization Amendments
DMR Discharge Monitoring Report
EPA Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FR Federal Register
MS4 Municipal Separate Storm Sewer System
NOI Notice of Intent
NOT Notice of Termination
NPDES National Pollutant Discharge Elimination System
NRDC Natural Resources Defense Council
OMB Office of Management and Budget
POTW Publicly Owned Treatment Works
RCRA Resource Conservation and Recovery Act
RQ "Reportable Quantity" release
SIC Standard Industrial Classification
TSDF Treatment, Storage or Disposal Facility (hazardous waste)
TSS Total Suspended Solids
WQA Water Quality Act
WRDA Water Resources Development Act
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STORM WATER QUESTIONS AND ANSWERS PART II
_L
1.
General Applicability
What kinds of storm water discharges are required to obtain an NPDES
permit under Phase I of the storm water program?
A. The National Pollutant Discharge Elimination System (NPDES) storm water
permit application regulations, promulgated by the U.S. Environmental
Protection Agency (EPA), require that the following storm water discharges
apply for an NPDES permit: (1) a discharge associated with industrial
activity; (2) a discharge from a large or medium municipal separate storm
sewer system; or (3) a discharge which EPA or the State determines to
contribute to a violation of a water quality standard or is a significant
contributor of pollutants to waters of the United States. The permit
application deadlines are specified in EPA's regulations.
2. What is a "storm water discharge associated with industrial activity?"
A. The term "storm water discharge associated with industrial activity" means
a storm water discharge from one of the eleven categories of industrial
activity defined at 40 Code of Federal Regulations (CFR) 122.26(b)(14)(i)
through (xi). Five of these categories are identified by Standard Industrial
Classification (SIC) code and the other six categories provide narrative
descriptions of the industrial activity. The complete definition is included
in Section XIII of this document.
If any activity at a facility is covered by one of the five categories which
provide narrative descriptions, storm water discharges from that activity of
facility are subject to storm water permit application requirements. If the
primary SIC code of the facility is identified in one of the remaining six
categories, the facility is subject to the storm water permit application
requirements. Note that only those facilities/activities described above
having point source discharges of storm water to waters of the United
States or to a municipal separate storrh sewer system or other conveyance
are required to submit a storm water permit application. The definition of
"point source" is provided at 40 CFR 122.2. The definition is included in
Section XIII of this document.
3. What are SIC codes and how can a facility find out its proper SIC code?
A. SIC codes are four-digit industry codes that were created by the Office of
Management and Budget (OMB) for statistical purposes. Other
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governmental organizations sometimes use these codes when classifying
business establishments. To find the correct SIC code, an applicant might
check his or her unemployment insurance forms or contact the appropriate
State unemployment services department. In addition, applicants may
consult the Standard Industrial Classification Manual (SIC Manual).
published by OMB in 1987. This manual is available in the resource
section of most public libraries. Questions regarding assignment of
particular codes can be addressed to your State permitting authority. A list
of telephone numbers and addresses for State storm water contacts is
provided as an attachment to this document.
4. What SIC code should a facility use when there are multiple activities
occurring at the site?
A. For the purposes of the storm water program, a facility must determine its
primary SIC code based on the primary activity occurring at the site. To
determine the primary industrial activity, the SIC Manual recommends
using the value of receipts or revenues. If such information is not available
for a particular facility, the number of employees or production rate for
each process may be compared. The operation that generates the most
revenue or employs the most personnel is the operation in which the
facility is primarily engaged. For case-specific determinations, contact the
permitting authority for your State.
5. How is a facility regulated when multiple activities conducted by different
operators are occurring on the same site (airports, for example)?
A. When multiple activities are conducted by different operators at a single
location, each industrial activity is assigned its own SIC code. At an
airport, for example, a passenger airline carrier will receive one SIC code,
but an overnight courier located in the same hanger may receive another
SIC code. Whereas the SIC codes may differ, if both are regulated
industrial activities, EPA generally encourages these operators to become
co-applicants (submit storm water permit application forms together) when
they are located at the same site and when industrial areas/drainage basins
are shared. When a permit is issued (or if the operators are filing for a
general permit) the co-applicants will become co-permittees and share
responsibility of permit compliance.
6. If a facility's primary SIC code is not listed in the regulations, but an
activity that occurs oh site is described in one of the narrative categories
of industrial activity, does that facility have to apply for a permit?
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A. If a facility conducts an activity on the site identified in the narrative
descriptions of categories (i), (iv), (v), (vii), (ix) or (x), then the facility
would be required to submit a storm water permit application for
discharges from those portions of the facility where the activity occurs.
Such narrative activities/facilities include: (i) activities subject to storm
water effluent limitations guidelines, new source performance standards, or
toxic pollutant effluent standards; (iv) hazardous waste treatment storage,
or disposal facilities including those that are operating under interim status
or a permit under subtitle C of the Resource Conservation and Recovery
Act (RCRA); (v) landfills, land application sites and open dumps that
receive or have received industrial wastes; (vii) steam electric power
generating facilities; (ix) sewage treatment works with a design flow of
1.0 mgd or more; and (x) construction activity disturbing five or more
acres of land.
7. Do storm water discharges from non-industrial areas at an industrial facility
(employee parking lots, rental car operations at an airport) have to be
addressed in an NPDES permit?
A. No. Only storm water discharges from those areas that are associated
with industrial activity, as defined at 40 CFR 122.26(b)(14) must be
addressed in the permit. However, if storm water runoff from a non-
industrial area commingles with runoff from a regulated industrial area, the
combined discharge would require permit coverage.
8. How are off site facilities (such as distribution centers, storage facilities,
vehicle maintenance shops) regulated under the storm water program?
A. To determine the regulatory status of off site facilities, first the operator of
a facility must determine if that off site operation can be classified
according to its own SIC code. If there is no SIC code which describes the
off site facility independently, then it would assume the SIC code of the
parent facility it supports. However, certain off site facilities that fall
within the categories of auxiliary facilities described in Section XIV of this
document (or which are specifically described in the SIC code description)
would, in most cases, be classified according to the parent facility they
support. Such supporting establishments include central administrative
offices, research and development laboratories, maintenance garages, and
local trucking terminals.
EPA has determined that off site vehicle maintenance facilities that service
trucks used for local transportation of goods or for local services are
generally considered supporting establishments which would not be
assigned a transportation SIC code; rather, such facilities are classified
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according to the SIC code of the facility they support. Please refer to
Section II of this document for a discussion of off-site vehicle maintenance
facilities.
9. Can authorized NPOES States be more expansive in their use of the
assignment of SIC codes? For example, can they make the rule applicable
to secondary activities?
A. Yes, State storm water regulations can be more expansive and cover more
activities than the Federal regulations.
10. Are all storm water discharges to sanitary sewers exempt from storm
water permitting requirements? What about discharges to combined sewer
systems?
A. Any storm water discharge to a Publicly Owned Treatment Works (POTW)
or to a sanitary sewer is exempt from storm water permit application
requirements. However, it may be subject to EPA's pretreatment program
under Section 307(b) of the CWA. Discharges to combined sewer
systems are also exempt from NPDES permitting but may be subject to
pretreatment requirements.
11. Is a storm water permit application required for an industrial facility that
has constructed a holding pond that usually does not discharge storm
water, but could in the event of a large enough storm?
A. All point source discharges of storm water associated with industrial
activity that discharge to waters of the U.S. or through a municipal
separate storm sewer system must be permitted. Therefore, if an
industrial facility does not have a storm water discharge from its holding
pond during typical storm events but has a storm water discharge in the
event of a large storm, that discharge must be covered under an NPDES
permit. In NPDES authorized States (a list is provided in Section XII of this
document), facilities should consult their permitting authority for State-
specific determinations on such "poteotial discharges."
12. If a facility is QOJ engaged in industrial activity as defined under 40 CFR
122.26(b)(14)(IMxi), but discharges contaminated flows comprised entirely
of storm water into a nearby municipal separatt storm sewer system, is
the facility required to obtain a storm water permit?
A. No, unless EPA or the State designates the discharge as contributing to a
violation of a water quality standard or as significantly contributing
pollutants to waters of the United States. However, industrial dischargers
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should note that large and medium municipalities (population 100,000 or
more) are currently designing storm water management programs that will
control contaminated storm water discharges from entering their separate
storm sewer systems. Additional storm water discharges may be
regulated under Phase II of the storm water program. EPA is currently in
the process of developing Phase II.
13. Are activities associated with industrial activity that occur on agricultural
lands exempted from storm water permitting requirements?
A. No. If a storm water discharge is associated with industrial activity as
defined at 40 CFR 122.26(b)(14), it is subject to permit application
requirements regardless of the location of the industrial activity. For
example, if a gravel extraction activity occurred on land leased from a
: farm, the activity would be classified as mining under SIC code 1442 or
1446 and therefore would be considered a storm water discharge
associated with industrial activity and require a permit.
14. Are NPDES permits transferable from one facility owner to the next?
A. Individual NPDES permits may be transferred to a new owner or operator if
the permit is modified. These procedures are described at 40 CFR 122.61.
Under the general permits for storm water discharges, issued by EPA in the
September 9, 1992 and September 25, 1992, Federal Register notices (57
f_B 41176 and 57 FR 44412), the new operator can submit an NOI two
days prior to the change of ownership but must include the facility's
existing general permit number on the NOI form. Many NPOES authorized
States have similar provisions in their general permits.
15. How does storm water permitting differ in States with approved State
NPDES programs compared to States without NPDES State permit
programs?
A. While Federal storm water regulations (i.e., the November 16, 1990, storm
water permit application regulations) establish minimum requirements
nationwide. State permitting authorities may impose more stringent
requirements or decide to expand the scope of its program to meet State
priorities. EPA Regional offices are the permitting authorities for 12 States
and most Territories; the remaining 38 States and the Virgin Islands
administer their own storm water programs and issue permits to regulate
municipalities and industries in their States. Regulated facilities in these
States should contact the appropriate State permitting authority for
guidance, application forms, general permits and other materials. Please
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note that some of the NPOES States do not issue permits for Federal
facilities located in their States.
For regulated facilities in the 12 non-delegated States (MA, NH, ME, FL,
TX, OK, LA, NM, SO, AZ, AK, ID), the Territories (all except the Virgin
Islands), the District of Columbia, and for facilities located on Indian lands
(in most, if not all, delegated States and in all non-delegated States), and
for Federal facilities in the States of DE, CO, IA, KS, NH, NY, OH, SC, VT
and WA, the storm water program is administered through EPA Regional
offices. Such facilities may be eligible for coverage under the general
permits issued by EPA in the September 9, 1992, and September 25,
1992, Federal Register notices (57 £Q 41176 and 57 £B 44412).
II.
Definition of Storm Water Discharge Associated With Industrial Activity
Category (i): Facilities subject to storm water effluent limitations guidelines,
new source performance standards or toxic pollutant effluent standards under
40 CFR subchapter N.
16. What are toxic pollutant effluent standards?
A. 40 CFR 122.26(b)(14)(i) includes facilities that are subject to storm water
effluent limitations guidelines, new source performance standards, or toxic
pollutant effluent standards. The phrase "toxic pollutant effluent
standards" refers to the standards established pursuant to CWA section
307(a)(2) and codified at 40 CFR Part 129. Part 129 applies only to
manufacturers of six specific pesticide products which are defined as toxic
pollutants. Please note that the phrase "facilities subject to toxic pollutant
effluent standards" does not refer to those industries subject to effluent
limitation guidelines for toxics under 40 CFR subchapter N.
Category (Hi): Mining and oil and gas operations classified as SIC codes 10-14.
17. What constitutes "contamination" at an oil and gas facility?
A. Oil and gas facilities classified as SIC code 13 are required to apply for a
storm water permit if the facility has had a release of a Reportable
Quantity (RQ) in storm water for which notification has been required any
time since November 16, 1987, or if the discharge contributes to a
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violation of a water quality standard. RQs for which notification is required
are defined at 40 CFR Parts 110, 117, and 302. An RQ for oil is defined
at 40 CFR 110 as the amount of oil that violates applicable water quality
standards or causes a film or sheen upon or a discoloration of the water
surface or adjoining shorelines, or causes a sludge or emulsion to be
deposited beneath the water surface or upon adjoining shorelines. For
other substances, RQ levels are expressed in terms of pounds released
over any 24 hour period and are listed at 40 CFR 117.3 and 40 CFR
302.4. A list of these RQ levels is available from the Storm Water Hotline
at (703) 821-4823.
18. Do EPA's industrial storm water general permits apply to discharges from
mine sites that are subject to storm water effluent limitations guidelines,
but which are not covered by an existing NPOES permit?
A. No, storm water discharges from mine sites that are subject to storm
water effluent limitation guidelines are not authorized by industrial storm
water general permits issued by EPA in the September 9, 1992, and
September 25, 1992, Federal Register notices (57 £S 41176 and 57 £R
44412). In States without NPDES permitting authority, the mine operators
submit an individual application to address those storm water discharges,
or could have participated in a group application prior to October 1, 1992
(note: any facility which did not submit an individual application prior to
October 1, 1992 or participate in a timely group application missed EPA's
regulatory deadline and may be subject to enforcement action). However,
certain authorized States may issue general permits authorizing such storm
water discharges from mine sites provided that those permits contain the
applicable guideline requirements.
19. Can point source discharges of contaminated ground water from mine adits
and seeps at active or inactive mine sites be permitted under the storm
water program?
Point source discharges of non-storm water to waters of the United States
must be authorized by an NPDES permit. Point source discharges of either
contaminated ground water from a mine adit or seep that are not related to
specific storm events would not be considered to be storm water.
Discharges that are composed in whole or in part of non-storm water
cannot be addressed solely by the permit applications for storm water
(Forms 1 and 2F), and cannot be authorized by NPDES permits that only
authorize discharges composed entirely of storm water. Rather, Forms 1
and 2C or 2D (and Form 2F if the discharge is mixed with storm water)
must be used when applying for a NPDES permit for non-storm water.
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Category (iv): Hazardous wasta treatment, storage or disposal facilities.
20. If the primary SIC coda of a facility is not covered under the regulations,
but there is a hazardous waste treatment, storage or disposal facility
(TSDF) on site, is the TSOF subject to storm water permitting •
requirements?
A. Yes. If the hazardous waste TSDF is or should be operating under interim
status or a permit under Subtitle C of the Resource Conservation and
Recovery Act (RCRA), regardless of the facility's primary activity, the
storm water discharges from that portion of the site are subject to the
narrative definition of storm water discharges associated with industrial
activity under category (iv). Even if a facility's SIC code is not included in
the regulations, any activity described by one of the narrative categories of
"industrial activity" that is occurring on the site would be regulated under
the storm water program.
Category (v): Landfills, land application sites and open dumps that receive
industrial wasta.
21. At what point does an inactive, closed, or capped landfill cease being an
industrial activity?
A. An inactive, closed or capped landfill is no longer subject to storm water
permit application requirements when the permitting authority determines
the land use has been altered such that there is no exposure of significant
materials to storm water at the site. For example, if an impervious surface
(such as a parking lot or shopping center) now covers the closed landfill,
the permitting authority could determine that storm water discharges from
the area are no longer associated with the previous landfill.activity. These
determinations must be made by the permitting authority on a case-by-
case basis.
22. If construction of calls at a landfill disturbs greater than five acres of land,
is coverage under EPA's construction general permits required?
A. No. EPA considers construction of new cells to be routine landfill
operations that are covered by the landfill's industrial storm water general
permit. However, the storm water pollution prevention plan for the landfill
must incorporate best management practices (BMPs) that address
sediment and erosion control. Where a new landfill is being constructed
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and five or more acres of land are being disturbed, such activity would
need to be covered under EPA's construction general permit until the time
that initial construction is completed and industrial waste is received.
Please note that NPDES authorized States may address this situation
differently.
Category (viii): Transportation facilities
23. If all vehicle maintenance and equipment cleaning operations occur indoors
at a transportation facility, as defined at 40 CFR 122.26(b)(14)(viii), is a
permit application required for discharges from the roofs of these
buildings?
A. Yes. Storm water discharges from all areas that are "associated with
industrial activity," described at 40 CFR 122.26(b)(14), are subject to the
storm water permit application requirements. This would include
discharges from roofs of buildings that are within areas associated with
industrial activity. In addition, storage areas of materials used in vehicle
maintenance or equipment cleaning operations and holding yards or parking
lots used to store vehicles awaiting maintenance are also considered areas
associated with industrial activity.
24. For a facility classified as SIC code 5171 (bulk petroleum storage), is the
transfer of petroleum product from the storage tanks to the distribution
truck considered "fueling", and therefore an industrial activity as defined
by the regulations?
A. No. The transfer of petroleum product from the storage tanks to the
tanker truck is not considered fueling and would not require a storm water
permit. However, fueling of the tanker truck itself at the 5171 facility is
considered to be part of routine vehicle maintenance, and storm water
discharges from these areas must be covered under a storm water permit
application.
25. Is a retail fueling operation that occurs at an SIC code 5171 petroleum
bulk storage facility regulated?
A. No. The provisions of 40 CFR 122.26(b)(14)(viii) apply to fueling
operations conducted at petroleum bulk storage facilities where the
vehicles being fueled are involved with the petroleum bulk storage
operation. Retail fueling of vehicles at such sites does not constitute
"vehicle maintenance" (as defined in the November 16, 1990 Federal
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Register page 48066), and a storm water permit is not required for the
discharges from that area. Only those portions of the SIC code 5171
facility where vehicle maintenance operations (including vehicle
rehabilitation, mechanical repairs, painting, fueling, and lubrication) and
equipment cleaning take place are required to be covered under a storm
water permit application.
26. Are off site vehicle maintenance areas required to submit permit
applications for their storm water discharges?
A. As discussed in Section I of this document, to determine the regulatory
status of off site vehicle maintenance operations, the operator of a facility
must first determine if that off site operation can be classified according to
its own SIC code. If there is no SIC code which describes the off site
facility independently, then it would assume the SIC code of the parent
facility it supports. However, please note that off-site facilities that fall
within the nine categories listed on page 17 of the SIC Manual (or which
are specifically described in the SIC code description) would, in most
cases, be classified according to the parent facility they support. See
Section XIII of this document for the complete list. Such supporting
establishments include central administrative offices, research and
development laboratories, maintenance garages, and local trucking
terminals. EPA has determined that off site vehicle maintenance facilities
that primarily service trucks used for local transportation of goods or for
local services are generally considered supporting establishments which do
not assume a transportation SIC code; rather, such facilities are classified
according to the SIC code of the facility they support. Long-distance
trucking centers, on the other hand, are generally classified as SIC code
4213, and are subject to regulation under 40 CFR 122.26(b)(14)(viii)).
Category (x): Construction activity
27. Who must apply for permit coverage for construction activities?
A. Under the NPDES storm water program, the operator of a regulated activity
or discharge must apply for a storm water permit. EPA clarified that the
operator of a construction activity is the party or parties that either
individually or taken together meet the following two criteria: (1) they
have operational control over the site specifications (including the ability to
make modifications in specifications); and (2) they have the day-to-day
operational control of those activities at the site necessary to ensure
compliance with plan requirements and permit conditions (9/9/92 Federal
Register page 41190). If more than one party meets the above criteria,
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28.
A.
29.
A.
then each party involved must become a co-permittee with any other
operator(s). For example, if the site owner has operational control over
site specifications and a general contractor has day-to-day operational
control of site activities, then both parties will be co-permittees.
When two or more parties meet EPA's definition of operator, each operator
must submit an NOI, and either include a photocopy of the other operators'
NOKs) or the general permit number that was assigned for that project.
Under EPA's storm water construction general permits, the co-permittees
are expected to join in implementing a common pollution prevention plan
prior to submittal of the NOI, and in the retention of all plans and reports
required by the permit for a period of at least three years from the date
that the site is finally stabilized.
For individual storm water discharge permits, applications must be filed 90
days prior to the commencement of construction. If a contractor has not
been selected at the time of application, the owner of the project site
would initially file the application and the contractor should sign on when
selected. Under an individual storm water permit for construction, multiple
operators would have to sign onto the permit, instead of submitting a new
application. Please note that authorized NPOES States may have varying
NOI and/or permit requirements and should be contacted on this issue.
What are the responsibilities of subcontractors at the construction site
under EPA's storm water construction general permits?
EPA storm water construction general permits require subcontractors to
implement the measures stated in the pollution prevention plan and to
certify that he/she understands the terms and conditions of the permit
requirements. Under EPA's general permits, subcontractors are not
required to submit NOIs.
What is meant by a "larger common plan of development or sale?"
A "larger common plan of development or sale" is a contiguous area where
multiple separate and distinct construction activities may be taking place at
different times on different schedules under one plan. For example, if a
developer buys a 20-acre lot and builds roads, installs pipes, and runs
electricity with the intention of constructing homes or other structures
sometime in the future, this would be considered a common plan of
development or sale. If the land is parceled off or sold, and construction
occurs on plots that are less than five acres by separate, independent
builders, this activity still would be subject to storm water permitting
requirements if the smaller plots were included on the original site plan.
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30. Does construction activity encompass repaying of roads?
A. Repaving is not regulated under the storm water program unless five or
more acres of underlying and/or surrounding soil are cleared, graded or
excavated as part of the repaving operation.
31. Is clearing of lands specifically for agricultural purposes regulated
construction activity (40 CFR 122.26(b)(14)(x)) under the storm water
program?
A. No. Although the clearing of land may be greater than five acres, any
amount of clearing for agricultural purposes is not considered an industrial
activity under the storm water regulations. Section 402(0(1) of the 1387
Water Quality Act exempts agricultural storm water discharges from
NPDES permitting requirements including storm water permitting. This
exemption only applies, however, if the clearing of land is solely for
agricultural purposes. (See Question 13).
32. If a construction activity that disturbs five or more acres commences on a
site covered by an existing industrial storm water permit, are the storm
water discharges from the construction area covered by the existing permit
or is a separata permit required?
A. If the existing permit is an individual permit, then the operator must either
request a modification of the existing permit to include the construction
storm water discharges or apply for coverage under a separate permit that
specifically addresses that construction activity. If the permittee decides
to modify the existing individual permit, permit modifications must be
approved prior to initiating any construction activity. If the existing permit
is an EPA storm water industrial general permit, the operator should submit
an NOI for coverage under EPA's storm water general permit for
construction activities. States with NPDES permitting authority may have
different requirements.
33. If a construction activity that disturbs less than five acres occurs on site of
a regulated industrial activity currently covered by EPA's Industrial storm
water general permit, does the regulated industry have to modify its
pollution prevention plan to include controls for the area of construction?
A. Yes. Regulated industrial activities covered by EPA's storm water
industrial general permit must revise their pollution prevention plan to
address all new sources of pollution and runoff including those from
construction activities disturbing less than five acres, that occurred on the
site of the regulated industry. However, if less than five acres, a separate
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storm water permit for the construction activity is not required (see
Question 32).
34. For projects such as a 100-mile highway construction project, what
location should be provided on the NOI?
A. The midpoint of a linear construction project should be used as the site
location on EPA's NOI form. For construction projects that span across
more than one State, the project must meet the application requirements
of each State.
35. Are long-term maintenance programs for flood control channels (such as
vegetation removal) or similar roadside maintenance programs subject to
permitting if five or more acres are disturbed?
A. If grading, clearing or excavation activities disturb five or more acres of
land either for an individual project or as part of a long-term maintenance
plan, then the activity is subject to storm water permit application
requirements.
36. For a construction activity that uses off site "borrow pits" for excavation
of fill material or sand and gravel, should the number of disturbed acres at
the borrow pit be added to the number of acres at the construction site to
determine the total number of disturbed acres?
A. No, off site borrow pits are not considered part of the on site construction
activity. If a borrow pit is specifically used for the removal of materials
such as sand, gravel, and clay, the pit is considered a mine and is
classified under SIC code 14. Such sites would be regulated as industrial
activity as defined at 40 CFR 122.26(b)(14)(iii). However, if the borrow
pit is utilized for the removal of general fill material (e.g. dirt) and disturbs
five or more acres of land, the pit would be considered a construction
activity as defined at 40 CFR 122.26(b)(14)(x).
37. Would building demolition constitute a land disturbing activity and require a
storm water construction permit application?
A. The definition of land disturbing activity includes but is not limited to
clearing, grading and excavation. At a demolition site, disturbed areas
might include the site where building materials, demolition equipment, or
disturbed soil are situated, which may alter the surface of the land.
Therefore, demolition activities that disturb five or more acres of land
would be subject to storm water construction permit application
requirements.
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38. What are the legal responsibilities and liabilities for construction activities
disturbing less than five acres, pursuant to the Ninth Circuit U.S. Court of
Appeals decision on June 4, 1992?
A. In NRDC v. EPA. 966 F.2d 1292, the Ninth Circuit U.S. Court of Appeals
remanded for further rulemaking, EPA's exemption of construction sites
less than five acres which are not part of a larger common plan of
development or sale. The Agency intends to undergo further rulemaking
proceedings for construction sites less than five acres. Until further
rulemaking is completed, permit applications for such activities need not be
submitted to EPA. However, States with NPDES permitting authority may
have more stringent requirements.
39. Do storm water construction general permits authorize non-storm water
discharges?
A. Under EPA's storm water construction general permits, issued on
September 9, 1992, and September 25, 1992, the following non-storm
water discharges are conditionally authorized (5.7 FR 41219) and (57 FR
44419): discharges from fire fighting activities; fire hydrant flushings;
waters used to wash vehicles or control dust; potable water sources
including waterline flushings; irrigation drainage; routine external building
washdown which does not use detergents; pavement washwaters where
spills or leaks of toxic or hazardous materials have not occurred (unless all
spilled material has been removed) and where detergents are not used; air
conditioning condensate; springs; uncontaminated ground water; and
foundation or footing drains where flows are not contaminated with
process materials such as solvents. These discharges, except for flows
from fire fighting activities, must be identified in the pollution prevention
plan and the plan must address the appropriate measures for controlling
the identified non-storm water discharges. Other non-storm water
discharges not listed above or not identified in the storm water pollution
prevention plan, must be covered by a different NPDES permit.
Category (xi): Light manufacturing facilities :
40. If oil drums or contained materials are exposed during loading or unloading
at a category (xi) facility, are storm water discharges from this area subject
to the storm water regulations?
A. The storm water regulations require category (xi) facilities to apply for a
storm water permit where material handling equipment or activities, raw
materials, intermediate products, final products, waste materials, by-
products, or industrial machinery are exposed to storm water. If there is a
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reasonable potential for leaks or spills from these drums which could be
exposed to storm water, discharges from that area would be subject to
storm water permitting requirements. Completely covering loading and
unloading activities may eliminate exposure. Note that permitting
authorities may have more stringent interpretations with respect to
exposure on industrial sites and should be consulted for case-by-case
determinations. For a discussion on the 9th Circuit Court of Appeals
decision (June 1992) and future EPA rulemakings on category (xi)
facilities, please refer to Section IX of this document.
41. Does the storage of materials under a roof at a category (xi) facility
constitute exposure?
A. If materials or products at a light industrial facility are stored outside under
a roof and there is no reasonable potential for wind blown rain, snow, or
runoff coming into contact with the materials or product, then there may
not be exposure at that area. However, if materials are stored under a
structure without sides and storm water comes into contact with material
handling equipment or activities, raw materials, intermediate products, final
products, waste materials, by-products or industrial machinery, the
discharge from that area must be permitted. The permitting authority
should be contacted for specific issues related to exposure.
III.
Individual Permits
42. Will individual permits include requirements for storm water pollution
prevention plans and monitoring?
A. EPA anticipates that many individual permits will include storm water
pollution prevention plans as a means of satisfying Best Available
Technology (BAT)/Best Conventional Technology (BCT) requirements
established in the Clean Water Act (CWA). With regard to monitoring
requirements under individual permits, such requirements will be
determined by the permit writer on a case-by-case basis. At a minimum,
all facilities with storm water discharges associated with industrial activity
must conduct an annual site inspection as prescribed at 40 CFR
122.44(0(4).-
43. Do permitting authorities have the option of subjecting facilities that have
submitted individual storm water permit applications to general permits?
A. Yes, permitting authorities may subject facilities that have submitted
individual permit applications to general permits. Facilities that are covered
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by a general permit may petition the permitting authority to be covered
under an individual permit by submitting an individual permit application
with reasons supporting the request to the permitting authority, pursuant
to40CFR 12
44. What ara the benefits/drawbacks of pursuing an individual storm water
permit over a general permit?
A. An individual storm water permit may be advantageous, as it is designed
to reflect a facility's site-specific conditions, whereas general permits are
much broader in scope, particularly in terms of monitoring requirements.
However, the individual permit application is generally more difficult to
prepare than submitting EPA's notice of intent (NOD to be covered under a
general permit (in part because the individual permit application requires
sampling and EPA's NOI does not). General permits may be advantageous
because regulated facilities know, in advance of submitting their NOI, the
requirements of the permit. In addition, coverage under a general permit
may be automatic (depending on how the permit is written), whereas the
individual permitting process takes longer.
45. When doas EPA anticipate that individual permits will ba issued?
A. Issuance of individual permits may vary on a State by State basis, as
permitting priorities and resources allow. The December 1 8, 1 992, Federal
Register (57 Ffl 60447) established October 1, 1993, as the deadline by
which individual permits ara to be issued. Many authorized States are
already issuing individual permits.
46. Can a facility that has submitted an individual permit application obtain
general permit covaraga upon issuance of a general permit in its State?
A. Yes, an eligible facility may opt for coverage under a. general permit (by
submitting an NOI) up until the time that the permitting authority issues
such facility its individual permit. Authorized States may require a written
request for withdrawal from the individual permit application process. EPA
recommends submitting such requests' to the appropriate Regional office.
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IV.
EPA General Permits (issued on 9/9/92 and 9/25/92)
47. What is the difference between EPA's construction and industrial general
permits?
A. Because the nature of construction activity varies considerably from other
industrial activities, EPA developed two separate general permits: one
covering storm water discharges from construction activity and one for
other storm water industrial discharges. Whereas the pollution prevention
plan for the construction permit focuses on sediment and erosion controls
and storm water management, the pollution prevention plan for industry
emphasizes general site management. Note that some authorized States
have industrial general permits that authorize storm water discharges from
construction activity.
EPA's general permits for storm water discharges associated with
industrial activity, issued on 9/9/92 (57 £B 41236) and 9/25/92 (57 £B
44438), authorize storm water discharges from all new and existing point
source discharges of storm water associated with industrial activity, as
defined at 40 CFR 122.26(b)(14), to waters of the U.S., except for
ineligible storm water discharges that are listed at 1.8.3. (9/9/92 Federal
Register page 41305) and
(9/25/92 Federal Register page 44444) in EPA's general permits.
EPA's general permits for storm water discharges associated with
construction activity, which were issued on 9/9/92 (57 £B 41176) and
9/25/92 (57 £B 44412), authorize storm water discharges associated with
construction activity, as defined at 40 CFR 122.26(b)(14)(x), except for
ineligible discharges that are listed at I.B.3 (9/9/92 Federal Register page
41217) and (9/25/92 Federal Register page 44418) in EPA's general
permits.
48. What is the procedure for applying for coverage under EPA's industrial or
construction general permits?
A. Dischargers of storm water associated with industrial activity located in
non-NPDES States must submit a Notice of Intent (NOD to be authorized to
discharge under the general permit. The NOI form is a one-page document
requesting basic information about the nature of the facility and the
particular storm water discharge under consideration. Under EPA's general
permits, monitoring is not required for submittal of the NOI. States with
NPDES authority may have different requirements for their NOI and should
be contacted directly.
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49. Will a facility automatically be covered by an EPA general permit upon
submittal of an NOI or will it have to cease operations until the Agency
provides notification of acceptance?
A. Permit coverage begins two days after the postmark date on the NOI,
provided the storm water discharges from the facility are eligible for
coverage as established by the permit conditions (see 9/9/92 Federal
Register page 41305 for limitations on coverage). The permitting authority
can require the submittal of an individual application at any time.
However, the facility may continue to discharge under the general permit
until an individual permit is issued or denied.
50. What are the deadlines for compliance with EPA's general permits?
A. Individuals who intend to obtain coverage for a storm water discharge
associated with industrial activity that commenced on or before October 1,
1992, were required to submit an NOI by October 1, 1992; however, EPA
is accepting late NOIs. Regulated facilities wishing to obtain coverage
under the general permit that have not yet submitted an NOI should do so
immediately. EPA's storm water general permits require permittees to
develop and implement a storm water pollution prevention plan. Deadlines
for NOi submittal and development and implementation of plans are listed
in the table below.
Facilities with salt storage or facilities that were not required to report
under Emergency Planning Community Right to Know (EPCRA) Section
313 prior to July 1, 1992, (but must report after that date) must comply
with the special requirements for section 313 facilities and salt storage (if
applicable) within 3 years of the date on which the facility is required to
first report under section 313. Ail other conditions in the permit must be
met within the deadlines listed above. Plans do not have to be submitted
to the Agency but must be kept on site and made available upon request.
Type of Discharge
Existing industrial
activities (other than
construction)
NOI Deadline
October 1 , 1 992
Pollution
Prevention nan
' Development
Deadline
April 1, 1993
Pollution
Prevention Plan
Implementation
Deadline
October 1, 1993
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Type of Discharge
Industrial activities
(other than
construction) that
begin between
October 1, 1992
and January 1,
1993
Industrial activities
(other than
construction) that
begin on or after
January 1, 1993
Oil and gas facilities
previously not
required to be
permitted that have
an RQ after
October 1, 1992
Municipally-owned
or operated
industrial activities
that were rejected
or denied from a
group application
Construction sites in
operation on
October 1, 1992
Construction sites
that begin operation
after October 1 ,
1992
NOI Deadline
2 days prior to the
start of industrial
activity
2 days prior to the
start of industrial
activity
Within 1 4 days of
first knowledge of
the release
Within 1 80 days
of the date of
rejection or denial
October 1 , 1 992
2 days prior to the
start of
construction
Pollution
Prevention Plan
Development
Deadline
Within 60 days of
commencement
of operations
Within 60 days of
commencement
of operations
Within 60 days of
first knowledge of
the release
Within 365 days
of the date of
rejection or denial
October 1 , 1 992
Prior to the
submittal of the
NOI
Pollution
Prevention Plan
Implementation
Deadline
Within 60 days of
commencement
of operations
Upon
commencement
of operations
Within 60 days of
first knowledge
of the release
Within 545 days
of the date of
rejection or denial
October 1 , 1 992
With the initiation
of construction
activities
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51. Is thers a fee for NOI applications?
A. EPA's general permits do not require fees at this time. However,
authorized NPOES States may levy fees and should be contacted directly.
52. Where should NOIs be submitted?
A. Facilities in States and Territories where EPA is the permitting authority
submit NOIs to the central processing center at the following address:
Storm Water Notice of Intent
P.O. Box 1215
Newington, VA 22122.
All permittees in States with NPDES authority submit the NOI to their State
permitting authority except those in New York, who submit to the
processing center at the above address. Note that authorized NPOES
States may develop NOI forms that are different from EPA's NOI form.
Under EPA's general permits, the operator of any industrial activity that
discharges storm water through a municipal separate storm sewer system
in a medium or large municipality must also submit a copy of the NOI to
that municipality. In addition, operators of construction activities must
provide a copy of all applicable NOIs for a site to the local agency
approving sediment and erosion plans or storm water management plans.
53. Is an operating regulated industrial facility required to submit a separate
NOI for each outfall that discharges storm water associated with industrial
activity at the site?
A. Under EPA's general permits, one NOI is generally sufficient for the entire
site, provided there is one operator. In this case, the pollution prevention
plan must address all discharges of storm water associated with industrial
activity from the site. If there are multiple operators at the site, each
operator must submit an NOI. In addition, if a facility that is covered under
EPA's industrial storm water general p'ermit undertakes a construction
activity disturbing more than five acres of land, then the facility must
submit an NOI for those construction-related storm water discharges for
coverage under EPA's construction general permit (or submit an individual
permit application).
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54.
A.
55.
A.
56.
A.
57.
A.
58.
A.
Will a facility receive any notification from EPA after submitting an NOI
under EPA's general permit?
Yes, EPA confirms the receipt of NOIs and will provide the applicant with a
permit number and explains how to get a summary of the guidance on
preparing storm water pollution prevention plans.
Is an entire facility excluded from coverage under EPA's general permits if
a single discharge at the site is excluded from coverage?
No. Eligibility under EPA's general permits should be applied on a
discharge-specific basis. Thus, a site with multiple discharges can be
covered under two different permits: a general permit for some discharges
and a separate NPDES permit for any discharges excluded from coverage
under the general permit. NPDES States should be contacted for additional
guidance on this issue.
Does an industrial facility operating under an EPA industrial general permit
have to apply for a separate permit for all on site construction activities
that disturb more than five acres of land?
Storm water discharges from construction activities that disturb five or
more acres of land must be covered under a separate NPDES permit that
specifically addresses storm water discharges from construction activity.
EPA's industrial storm water general permits do not provide coverage for
storm water discharges from regulated construction activities.
Construction activities that disturb less than five acres of land do not
require a storm water permit at this time. The pollution prevention plan for
the industrial facility must be modified to address site changes due to that
amount of construction activity.
Can a facility submit one NOI for similar but separately located industrial
facilities which are owned by the same corporation?
No. One NOI must be submitted by the operator of each individual facility
that intends to obtain coverage under-a general permit, regardless of
common ownership.
Does an asphalt/concrete batch plant have to submit a new NOI each time
it changes location?
Under EPA's general permits, an NOI must be submitted each time the
plant moves to a new site of operation. However, some authorized States
may have different requirements with respect to asphalt/concrete batch
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plants and, therefore, facilities in such States should contact their
permitting authorities.
59. Who is required to monitor under the conditions of EPA's storm water
general permits?
A. EPA established tiered monitoring requirements in its final industrial storm
water general permits based on the potential to contribute pollutants to
storm water (4/2/92 Federal Register page 11394). Six classes of facilities
are required to monitor semiannually and report annually, ten classes of
facilities are required to monitor annually and keep the data on site, and all
other classes of facilities are not required to monitor. All facilities
authorized by general permits (including those facilities not otherwise
required to monitor) must still conduct an annual site inspection, except for
inactive mining sites where this may be impractical due to remote location
and inaccessibility of sites (inspection no less than once in three years).
The sixteen classes of facilities that are required to monitor are specified in
EPA's industrial general permits (9/9/92 Federal Register page 41248),
which are available from the Storm Water Hotline. EPA's construction
storm water general permits require periodic inspections in lieu of
monitoring.
60. If an industrial facility that is required to monitor under EPA's industrial
storm water general permits does not have any exposure of materials or
activities to storm water, does it still have to conduct sampling?
A. Under EPA's industrial storm water general permits, industrial facilities can
provide a certification in lieu of monitoring results for a given outfall, that
materials and activities are not presently exposed to storm water and will
not be exposed during the certification period (see 9/9/92 Federal Register
page 41314 for a more detailed description). This determination should be
applied on outfall-by-outfall basis (e.g., permittees may elect to monitor
certain outfalls while providing certification for others). The certification
must be updated on an annual basis and retained in the pollution
prevention plan. The six classes of facilities that are required to report
monitoring results annually must submit this certification to the permitting
authority in lieu of the Discharge Monitoring Report (DMR).
61. Within one drainage area leading to a single outfall, if a facility conducts
two separate industrial activities that are subject to both semiannual and
annual monitoring requirements, which set of monitoring requirements will
apply?
A. If the discharges cannot be segregated, the combined discharge would be
subject to both sets'of monitoring requirements. In effect, a combined
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discharge could be subject to annual monitoring requirements for certain
parameters and semi-annual monitoring for others. If a facility can
segregate the discharges from the different activities, separate monitoring
requirements would apply to each discharge.
62. Is it possible to sample only one of several identical outfalls under the
provisions of EPA's general permits?
Yes. To reduce the monitoring burden on the facility, the permit allows an
operator to sample one outfall where it is substantially identical to the
other outfalls. Permittees that intend to use this provision must justify and
document in writing why one outfall is substantially identical to the others.
Criteria for making this determination are presented in the NPDES Storm
Water Sampling Guidance Document. Facilities using this provision must
include the written justification in their storm water pollution prevention
plan. Facilities that are subject to semiannual monitoring requirements
must submit the justification of why an outfall is substantially identical to
the others with the Discharge Monitoring Report. Other facilities required
to monitor under the permit are not required to submit the justification
unless it is requested by the permitting authority.
63. If a facility had to report under section 313 of the Emergency Planning and
Community Right to Know Act (EPCRA) when its NO! was submitted but
no longer uses the quantity of water priority chemicals that makes such
reporting necessary, is that facility still subject to special requirements in
EPA's industrial storm water general permits for facilities that handle
EPCRA section 313 water priority chemicals?
A. No. Such facilities are no longer subject to the special EPCRA requirements
contained in EPA's industrial storm water general permit and should
accordingly modify their pollution prevention plan to indicate the changes
in industrial activity at the facility.
64. Under EPA's general permits, when and where must Discharge Monitoring
Reports (DMR) be submitted for semi-annual monitoring facilities?
A. DMRs must be submitted to the permitting authority according to the
following schedule: a) certain EPCRA section 313 facilities and wood
treatment facilities monitor from January to June and July to December
and report no later than January 28 following the second monitoring
period; b) Primary metal facilities, facilities with coal pile runoff, and
battery reclaimers monitor from March to August and September to
February and report no later than April 28; and c) land disposal facilities
monitor from October to March and from April to September and report no
later than October 28. For facilities in non-NPDES States, DMRs must be
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submitted to the EPA Regional office (Section XI of this document includes
storm water list of contacts for addresses). In States with approved
NPDES permit programs, DMRs must be sent to the location specified in
the State's general permit. The general permits in such States may also
have different schedules for submitting OMRs than the one specified
above.
65. Under the industrial general permit, coal-fired steam electric facilities have
annual monitoring requirements for storm water discharges from coal
handling sites (other than from coal pile runoff). Are access roads
considered coal handling sites?
A. Coal handling sites include those areas of the facility where coal is either
loaded or unloaded. Therefore, those portions of access roads where
loading/unloading operations do not occur are not considered to be coal
handling sites and, therefore, are not subject to annual monitoring
requirements under EPA's general permits.
66. Are there specific numeric effluent limits in EPA's storm water general
permits?
A. EPA's general permits establish pollutant discharge limits for total
suspended solids (TSS) and pH in coal pile runoff. In most other
situations, EPA's industrial storm water general permits focus on storm
water management and the implementation of facility-specific pollution
prevention plans; however, EPA's industrial general permits also include
State-specific conditions that may include additional numeric effluent
limits.
67. What is a storm water "best management practice" (BMP)?
A. A BMP (defined at 9/9/92 Federal Register page 41319) is a technique,
process, activity or structure used to reduce the pollutant content of a
storm water discharge. BMPs include simple, nonstructural methods such
as good housekeeping and preventive maintenance. Additionally, BMPs
may include sophisticated, structural modifications such as the installation
of sediment basins. The focus of EPA's general permits is on preventative
BMPs which limit the release of pollutants into storm water discharges.
EPA has published guidance materials to assist in the selection of
appropriate BMPs in the preparation of storm water pollution prevention
plans, including: Storm Water Management for Industrial Activities:
Developing Pollution Prevention Plans and Best Management Practices (PB-
92-235969) and Storm Water Management for Construct/on Activities:
Developing Pollution Prevention Plans and Best Management Practices (PB-
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92-235951). These Manuals are available from NTIS at (703) 487-1650
and the Office of Water Resource Center at (202)260-7786.
68. What should a facility do when the nature of its activities changes?
A. When the nature of a facility's activities changes, the facility must modify
the pollution prevention plan accordingly. If the facility is subject to new
monitoring requirements as a result of the changes, sampling must begin at
the start of the next monitoring period.
69. Is there a procedure for notifying EPA when a storm water discharge
associated with industrial activity covered by EPA's general permit has
been eliminated?
A. Yes. EPA's general permits include procedures for filing a Notice of
Termination (NOT) form when there is no longer a potential for storm
water discharges associated with industrial activity to occur. Operators of
construction activities can submit an NOT once they have finally stabilized
all areas that were disturbed. For construction activity, final stabilization
means that all soil disturbing activities at the site have been completed,
and that a uniform perennial vegetative cover has been established or
equivalent permanent stabilization measures- (such as the use of riprap,
gabions, or geotextiles) have been employed with a density of 70% of the
previously existing/background cover for unpaved areas and areas not
covered by permanent structures. A copy of the NOT can be found in
Federal Register notices dated September 9, 1992 (57 £B 41232 and
41341), and September 25, 1992 (57 £fi 44434 and 44469).
70. If a NPDES authorized State has general permitting authority but has not
yet finalized an applicable general permit, can a facility still submit an NOI
and assume general permit coverage?
A. No, a facility cannot submit an NOI to obtain coverage under a general
permit until that permit has been finalized. Furthermore, a facility located in
an NPOES State cannot seek coverage under one of EPA's general permits.
71. Will State general permit requirements vary and to what extent?
A. General permit requirements for authorized NPOES States may vary
considerably because these States develop and issue permits
independently from EPA. However, all NPDES permits must meet
minimum technical and water quality-based requirements of the Clean
Water Act. Permittees in NPDES authorized States should consult with
their permitting authorities regarding particular State conditions. Under
EPA's storm water general permits, State-specific requirements vary
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because of different water quality concerns in different States. Each of
the 12 non-authorized States and Territories provided certification that
EPA's general permits comply with State water quality standards, and
added permit requirements where necessary to achieve compliance with
those standards in the final general permits.
72. Can discharges from industrial areas at a construction site such as portable
asphalt plants and/or concrete batch plants be covered under EPA's
construction general permits?
A. No. EPA's construction general permits only authorize discharges from the
construction area; these permits do not authorize storm water discharges
from industrial activities other than construction that are located on the
construction site. Portable asphalt plants and/or concrete batch plants are
considered to be "industrial activity," as defined 40 CFR 122.26(b)(14)(ii).
Therefore, storm water discharges from such industrial activities must be
in compliance with a general or individual storm water permit for industrial
storm water discharges other than construction. At a construction site
which disturbs less than 5 acres of land (and which is, therefore, not
subject to storm water permit application requirements for the construction
activity), the operator of the mobile asphalt or concrete plant still would be
required to obtain storm water permit coverage for discharges from the
plant. Please note that States with approved NPDES permit programs may
allow portable asphalt plants and/or cement batch plants to be covered
under the State's construction general permit.
V.
Group Applications
73. How will group applicants be permitted?
A. EPA is currently developing a model permit using information from Part I
and Part II group applications, and other sources. This model permit will
have sections which address a particular typo of industrial activity. When
the model permit is completed, the permitting authority (EPA or NPDES
States) then has the option to propose and issue final permits to cover
group members within their state based upon the model permit.
VI.
Sampling
74. For what parameters does a facility have to sample under tho individual or
group application?
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A. Applicants are required to obtain quantitative data from samples collected
during storm events from all outfalls that discharge storm water associated
with industrial activity for the following parameters: (1) any pollutant
limited in an effluent guideline to which the facility is subject; (2) Any
pollutant listed in the facility's permit for its process wastewater [if the
facility is operating under an existing NPDES permit]; (3) Oil and grease,
pH, BODS, COO, TSS, total phosphorous, total Kjeldahl nitrogen, and
nitrate plus nitrite nitrogen; (4) certain toxic pollutants listed in Tables II
and III of the Appendix D to 40 CFR Part 122 (also listed as Tables 2F-2
and 2F-3 in the instructions for Form 2F) that are expected to be present in
the storm water.
75. For an individual or group application, how many aliquots (portions) of
storm water are needed to obtain a flow-weighted composite?
A. A flow-weighted composite may be taken as a combination of a minimum
of 3 sample aliquots taken in each hour of discharge for the entire event or
for the first three hours of the event, with each aliquot collection being
separated by a minimum of 15 minutes. If the storm event lasts less than
three hours, aliquots should be collected for as long as there is sufficient
flow. Large and medium municipalities may use a different protocol with
respect to time duration between collection of aliquots with approval of
the permitting authority. EPA's NPDES Storm Water Sampling Guidance
Document discusses several ways to estimate flows. (This manual is
available from the Storm Water Hotline (703) 821-4823) and the Office of
Water Resource Center (202)260-7786].
76. How does a facility measure flow if there are numerous small outfalls?
A. Applicants may provide either measurements or estimates of storm water
flows. One possible method for estimating flow is to create a conveyance
that would combine flows from many of the outfalls. Alternatively, where
flows are similar, the flow at one outfall may be measured to calculate
flows at the other outfalls, provided that the method of measurement is
indicated to the permitting authority. EPA's NPDES Storm Water Sampling
Guidance Document discusses several ways to estimate flows. [This
manual is available from the Storm Water Hotline (703) 821-4823) and the
Office of Water Resource Center (202)260-7786.1
77. For what parameters is only a grab sample appropriate?
A. When collecting storm water samples, grab samples are required for the
following parameters: pH, temperature, cyanide, total phenols, residual
27
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chlorine, oil and grease, fecal coliform and fecal streptococcus. Both grab
and composite samples are required for all other pollutants.
78. Do both a grab and a composite sample have to be taken from a 24-hour
holding pond?
A. No. Only a minimum of one grab sample is required to be taken.for
effluent from holding ponds or other impoundments with a retention period
of greater than 24 hours for the representative event.
79. Can composite and grab samples be taken from separate events?
A. Grab and composite samples for a given outfall should be taken from the
same storm event to provide a basis for comparing the data. If this is
impossible, information describing each storm event used for sample
collection should be recorded and submitted with sampling results.
However, applicants are advised that the permitting authority may request
data to be collected from only one storm event.
80. Is a facility required to sample all of its outfalls during a single storm
event?
A. No. Unless otherwise specified by the permitting authority, a facility may
sample outfalls during different events provided that the storms meet the
criteria established in the application regulations or in the applicable permit
language. Information describing each storm event used for sample
collection should be recorded and submitted with sampling results.
81. If a facility has two conveyances that join and leave the site as one
combined discharge, where should a sample be collected?
A. If the discharge is composed entirely of storm water, the sampling point
should be at the outfall as it leaves the property. If the discharge is a
combination of process wastewater and storm water, the storm water
component of the discharge should be sampled before it commingles with
the process waste water discharges. If sampling at an outfall at the
property boundaries is impossible because of safety reasons,
inaccessibility, or a poor conveyance, sampling may be done closer to the
discharge source.
82. How long of a 'dry' period does a facility need before sampling?
A. A 'dry' period needs to be at least 72 hours. More specifically, all samples
must be collected from the discharge resulting from a storm event that
28
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occurs at least 72 hours from the previously measurable (greater than 0.1
inches) storm event.
83. If two or more outfalls at a facility have identical discharges, does each
outfall have to be sampled?
A. Where a facility has outfalls that discharge "substantially identical
effluent," the permitting authority may allow the applicant to test only one
outfall and report that the quantitative data are representative of the
substantially identical outfalls. EPA's NPDES Storm Water Sampling
Guidance Document (available from the Storm Water Hotline (703-821-
4823)) provides information on how to prepare this petition, or the
applicant should contact their permitting authority to determine what
information is required.
84. Do analyses for storm water need to be done by a certified lab?
A. There is no Federal requirement to use a certified lab. However, certain
States may require that a certified lab be used. Please note, analyses must
comply with the analytical procedures set out in 40 CFR Part 136, as
discussed below.
85. What analytical methods must be used for the pollutants for which
sampling is required?
A. EPA-approved methods must be used where a method for a pollutant has
been promulgated. 40 CFR Part 136 discusses required methods. If there
is no approved method, the applicant may use any suitable method, but
must provide a description of the method in its application. Additional
information on general sampling issues can be obtained through the EPA's
NPDES Storm Water Sampling Guidance Document. The manual is
available from the Storm Water Hotline (703-821-4823).
VII.
Municipal Permit Applications
86. One* a municipal separate storm sewer system (MS4) has submitted Part
2 of its storm .water permit application, when does the term of the permit
actually begin?
A. The term of the permit begins when a permit is issued by the permitting
authority. Pursuant to 40 CFR 122.26(e)(7), storm water permits for
discharges from MS4s are to be issued with in one year after submission
of a complete application. Since applications for medium and large
29
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r
municipal separate storm sewer systems were due on May 17, 1993 and
November 16, 1992, respectively, this results in permit issuance by
November 16, 1993 for large municipalities and by May 17, 1994 for
medium municipalities.
87. How is EPA incorporating 1990 census data into the storm water
program?
A. Most of the municipalities that meet the definition of either a large or
medium MS4 based on the results of the 1990 Census have already begun
to seek an NPOES permit. Headquarters is working with the Regions and
States to determine the best way to incorporate the remaining municipal
entities into the program.
88. How does EPA envision the relationship between large and medium MS4
operators and NPDES permitting authorities in terms of addressing
industrial storm water discharges to MS4s?
A. EPA envisions a partnership between NPDES permitting authorities and
operators of large and medium municipal separate storm sewer systems in
controlling pollutants in storm water discharges associated with industrial
activity through MS4s. In addition, NPOES storm water permits provide a
basis for enforcement actions directly against the owner or operator of the
storm water discharge associated with industrial activity.
A second NPOES permit will be issued to the operator of the large and
medium MS4. This permit will establish the responsibilities of the
municipal operators in controlling pollutants from storm water associated
with industrial activity which discharges through their municipal system.
Under this approach, municipal operators will be able to:
• Assist EPA in identifying priority storm water discharges associated with
industrial activity through their system;
.• Assist EPA in reviewing and evaluating storm water pollution prevention
plans that industrial facilities are required to develop; and
• Assist EPA in compliance efforts regarding storm water discharges
associated with industrial activity to their municipal system.
A more complete description of this policy is provided in the August 16,
1991 Federal Register (56 FR 40973).
30
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VIII. The Intermodal Surface Transportation Efficiency Act of 1991
(Transportation Act)
89. How did the Transportation Act affect permitting requirements for
municipalities under 100,000?
A. Storm water discharges from certain industrial activities owned or operated
by municipalities with a population of less than 100,000 people were
granted a moratorium from the October 1, 1992 deadline for storm water
permit applications. Exceptions to this moratorium include discharges from
powerplants, airports and uncontrolled sanitary landfills.
90. How does the Transportation Act impact privately owned or operated
industrial activities located in municipalities under 100,000?
A. The provisions of the Transportation Act specifically address publicly
owned or operated industrial activities. Privately owned facilities that have
storm water discharges associated with industrial activity, as defined at 40
CFR 122.26(b)(14), must submit a permit application regardless of the size
of the population of the municipality in which they are located.
91. What is an "uncontrolled sanitary landfill?"
A. An uncontrolled sanitary landfill (discussed in the 4/2/92 Federal Register.
page 11410) is a landfill or open dump, whether in operation or closed,
that does not satisfy the runon/runoff requirements established pursuant to
subtitle D of the Solid Waste Disposal Act. However, landfills closed prior
to October 9, 1991 are not subject to RCRA runon/runoff requirements,
and therefore need not submit storm water permit applications if they are
located in municipalities of less than 100,000 population. Landfills closed
after October 9, 1991 and others that meet the above definition would be
subject to the storm water permit application requirements.
92. If a municipally-owned sewage treatment plant is located in a municipality
with a population of laaa than 100,000 people, but the service population
is greater than 100,000 people, is the facility subject to the permitting
requirements?
A. Yes, because service populations are used in determining population for
publicly-owned treatment works [POTWs] (April 2. 1992 Federal Register
page 11394). Additionally, where one sewer district operates a number of
POTWs, the entire service population of the district will be used to
determine the applicable population classification of all the POTWs
operated by the district. For example, if a district with a cumulative
31
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93.
A.
service population of 160,000 operates two sewage treatment plants, one
of which serves 120,000 and the other which serves 40,000, both plants
will be considered to be owned or operated by a municipality with a
population of 100,000 or more.
If a construction operation disturbing five or more acres is owned by a
small municipality (a population of less than 100,000 peopie)but operated
by a private contractor, is the activity regulated?
No. If the construction activity is either owned or operated by a
municipality with a population of less than 100,000 it would not be
required to obtain a storm water permit during Phase I of the storm water
program. Some States, however, may require that an application be
submitted.
IX.
9th Circuit U.S. Court of Appeals Decision
94. What is the current status of light manufacturing facilities without
exposure and construction activities under five acres, pursuant to the 9th
Circuit Court dtcision?
A. The 9th Circuit Court decision remanded two "exemptions" provided in the
NPOES storm water permit application regulations for light manufacturing
facilities without exposure and construction activities under five acres
(11/16/90 Federal Register page 48066). Both exemptions were
remanded for further proceedings. In response to these two remands, the
Agency intends to conduct further rulemakings on both the light
manufacturing and construction activities under five acres. In the
December 18, 1992, Federal Register, the Agency stated that it is not
requiring permit applications from construction activity under five acres or
light industry without exposure until this further ruiemaking is completed.
Phast II of the Storm Water Program*
95. What I* the difference between Phase I and Phase II of the NPDES storm
water program?
A. In the Water Quality Act of 1987, Congress mandated that EPA establish
storm water control programs in two phases. While the first Phase I was
defined on November 16, 1990, Phase II regulations were to be
promulgated by October 1, 1992. However, the Water Resources
Development Act (WRDA) of 1992 extended deadlines for Phase II of the
32
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storm water program as follows: 1) EPA must issue Phase II regulations
by October 1, 1993; and 2) permits for Phase II sources may not be
required by EPA or the State prior to October 1, 1994. EPA is currently
developing regulations that will implement Phase II of the storm water
program. (See Question #1 for more information on Phase I).
96. Will all storm water discharges that are not regulated under Phase I be
regulated under Phase II of the storm water program (e.g., service stations,
retail and wholesale businesses, parking lots, municipalities with
populations of less than 100,000)7
A. Not necessarily. Statutory provisions require that EPA, in consultation
with State and local officials, issue regulations that designate additional
Phase II sources for regulation to protect water quality. EPA is currently
developing approaches to identify and control high risk Phase II sources.
EPA requested initial public comments on a variety of Phase II issues on
September 9, 1992 (57 £B 41344). As part of this process, EPA is
considering all sources of storm water not regulated under Phase I for
potential coverage under Phase II.
33
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-------
APPENDIX E
GROUP APPLICATION PART 2 SAMPLING DATA AND INDUSTRY
DESCRD7TIONS ORGANIZED BY INDUSTRY SECTOR
-------
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APPENDIX E
GROUP APPLICATION PART 2 SAMPLING DATA AND INDUSTRY
DESCRIPTIONS ORGANIZED BY INDUSTRY SECTOR
This appendix contains summary descriptions for the 31 industrial sectors that were
identified hi the group application portion of the Phase I permitting process (four of the
sectors were consolidated into two sectors for permit development purposes). The
summaries describe the industrial activities, significant materials, and pollutants of concern
that were listed hi the applications submitted by the industry groups. The descriptions also
contain tables which summarize the sampling data submitted by the groups. The tables list
the mean values, median values, 95th percentile values, for the grab and composite samples
and the mean, median and 90th percentile values for NURP data for a portion of the
pollutants sampled within each sector.
-------
-------
Appendix £
SECTOR
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
22
23
24
25
26
27
28
29
30
31
INDUSTRIAL SECTORS/GROUP APPLICATIONS
ACTIVITIES REPRESENTED
Lumber and Wood Products
Paper and Allied Products
Chemicals and Allied Products
Asphalt and Lubricant Manufacturers
Stone, Clay, Glass and Concrete Products
Primary Metal Industries
Metal Muiing
Coal and Lignite Mining
Oil and Gas Extraction
Mining and Quarrying of Nonmetallic Minerals
Hazardous Waste Treatment Storage or Disposal Facilities
Industrial Landfills, Land Application Sites and Open Dumps
Used Motor Vehicle Parts
Scrap and Waste Materials
Steam Electric Power Generating Facilities
Railroad Transportation
Local and Suburban Transit and Interurban Highway Passenger Transportation
Motor Freight Transportation
United States Postal Service
Petroleum Bulk Stations
Water Transportation
Ship Building and Repairing
Boat Building and Repairing
Transportation By Air
Domestic Wastewater Treatment Plants
Food and Kindred Products
Tobacco Products
Textile Mill Products
Apparel and Other Finished Products Made From Fabrics and Similar Materials
Furniture and Fixtures Manufacturing
Printing Publishing and Allied Industries
Rubber and Misc. Plastic Products
Leather and Leather Products
Fabricated Metal Products, Except Machinery and Transportation Equipment
Jewelry, Silverware, and Plated Ware
Industrial and Commercial Machinery (Except Computer and Office Equipment)
Transportation Equipment
Electronic and other Electrical Equipment and Components
Measuring, Analyzing, and Controlling Instruments; Photographic and Optical Goods;
Watches and Clocks
E-l
-------
Appendix £
Sector 1: Timber Products Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
category (ii) facilities classified as Standard Industrial Classification (SIC) code 24 (except
2434)." Storm water discharges covered include those from establishments that cut timber
and pulpwood, merchant sawmills, lath mills, shingle mills, cooperage stock mills, planing
mills, and plywood and veneer mills that produce lumber and wood basic materials; and
establishments that manufacture finished articles made entirely of wood or related materials.
These facilities use wood as their primary raw material. Industrial activities include the
following:
Log Storage and Handling activities include loading and unloading of logs onto trucks or
railroad cars for transport to other facilities, log sorting, and storage of logs. In addition,
some cutting may be performed, such as chopping off tree branches and sectioning of tree
trunks for easier handling during transport. Chipping may be performed at facilities serving
pulp industries. Residues generated at these sites may include bark, coarse sawdust, and
wood chunks.
Untreated Wood Lumber and Residue Generation Activities occur at the following: saw
and planing mills (SIC group 242); millwork, veneer, plywood and structural wood member
manufacturing facilities (SIC group 243); wood container manufacturing facilities (SIC group
244); wood building and mobile home manufacturing facilities (SIC group 245); and
miscellaneous wood product manufacturers (SIC group 249). These facilities may engage in
one or more activities such as log washing, bark removal, milling, sawing, resawing edging,
trimming, planing, machining, air drying, and kiln drying. Some facilities generate residue
as a product, while other facilities may generate residues as a waste product. A summary of
the residues generated include: bark, wood chips, planer shavings, and sawdust.
Wood Surface Protection Activities are accomplished by one of the following three
methods: spraying, dipping, and green chain operations. Industrial activities at saw mills
with the potential to contaminate storm water include spills from surface protection areas,
storage and mixing tank areas, treated wood drippage, transport or storage areas,
maintenance and shop areas, and areas used for treatment/disposal of wastes. Fugitive
emissions from negative pressure spraying activities and hand spraying surface protection
formulations may also result hi the contamination of storm water.
Wood Preservation Activities are accomplished by two steps. First, the moisture content of
wood is reduced to increase its permeability (this is referred to as conditioning). After
conditioning, wood is impregnated with a preservative for fire retardency, insecticidal
resistance, and/or fungicidal resistance. Then, the wood stock is often subject to cleaning in
order to remove excess preservative prior to stacking treated lumber products outside.
Wood Assembly/Fabrication Activities such as the fabrication of fiberboard, insulation
board, and hardboard may involve the use of wax emulsions, paraffin, aluminum sulfate,
E-2
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Appendix E
melamine formaldehyde, and miscellaneous thermosetting resins. These chemicals may be
introduced as part of the board formation process or as a coating to maintain the board's
integrity. In the formation of fiberboard/insulation board/hardboards, the digestion of pulp
and fiber by mechanical, thermal, and sometimes chemical means takes place. Another
operation which involves resinous agents is the formation of veneer. In this process, veneer
is placed in hot ponds or vats to soften the wood. Veneer strips are removed and often
bound by glue or a resinous agent. Glues are also used in the assembly of wood
components. Other types of activities include the finishing of wood products. Stains, paints,
lacquers, varnish, water repellents and sealants, etc. may be applied to some of the wood
products.
Significant materials at timber products facilities which can contribute pollutants to storm
water include: uncut logs, wood bark, wood chips wood shavings, sawdust, green lumber,
rough and finished lumber, other waste wood material, non-hazardous wood ash, above and
below ground fuel storage tanks, finishing chemicals, solvents and cleaners, petroleum,
herbicides, pesticides, fertilizers, sawmill equipment, material handling equipment, boiler
water treatment chemicals, scrap metals, scrap equipment and plastics, boiler blowdown
water, and leachate from decaying organic matter.
Pollutants from timber products facilities generally include biological oxygen demand
(BOD5), total suspended solids (TSS), chemical oxygen demand (COD), leachate, wood
wastes, chemicals, heavy metals, and pH.
Table E-l
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 1
Pollutant i
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
Grab Samples (mg/1)
STo. .
19S
19
32
i«9
107
198
an
188
128
16
Mean ;
39.63
297.64
0.05
0.95
15.21
23.91
7.17
2.57
1108.42
0.47
Median
13.00
131.00
0.03
0.32
2.20
0.29
7.30
1.62
242.00
0.37
95%
193.00
1500.00
0.16
2.20
55.00
2.66
8.56
9.26
4800.00
1.70
Composite: Samples (isg/l>
No.
200
198
29
188
199
188
in
IS
Mean
45.37
242.50
0.04
0.75
6.29
2.32
575.27
0.36
Median
17.00
122.50
0.03
0.34
0.30
1.50
230.00
0.30
95%
135.50
1080.00
0.12
1.79
1.72
7.50
2288.00
1.20
KtM» Sesults (tag/l>
Mean
12.00
mm
QM
OJ.S
QM
J*R
0*42
NE
JL90
imM
0,20
Median
9,00
65,00
&04
&14
0.68
NR
0.33
MR
1.50
100.00
0,16
90%
15,00
mm
QM
0,35
L7S
im
0*70
NR
3,30
300JH*
0,50
E-3
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Appendix E
Sector 2: Paper And Allied Products Manufacturing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (ii) facilities classified as Standard Industrial Classification (SIC) code 26
(except 265 and 267)." Storm water discharges covered include those from establishments
primarily engaged in the manufacture of pulps from wood and other cellulose fibers, and
from rags; manufacture paper and paperboard; and the manufacture of paper and paperboard
into converted products, such as paper coated off the paper machine, paper bags, paper
boxes, and envelopes. This major group also includes facilities which manufacture bags of
plastics film and sheet.
Significant materials include fuels (diesel and gasoline), lumber, paper, and paperboard.
Pollutants of concern include total suspended solids (TSS), biochemical oxygen demand
(BOD), and chemical oxygen demand (COD).
Table E-2
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 2
Pollutant
BODS
COD
Copper
Lead
N02+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
No>
121
121
2
" 2,
121
122
120
-ill
"'iai
121
, 1
S?«l> Samj
Mean.
34.72
191.69
0.03
0.05
.095
3.69
0.39
3.83
152.98
0.62
jfeS tajg/l
Median
8.00
61.00
0.03
0.05
0.50
1.00
0.18
6.97
1.76
41.00
0.62
r
95%
115.00
740.00
0.05
0.09
3.93
15.00
1.06
8.22
10.20
520.00
0.62
COt
,!P*
ill
' 113
2
2
111
ill
112
ill
1
aposfte &
Mean
24.25
133.90
0.03
0,03
0.76
0.36
3.17
44.04
0.78
mtjptes (HI
Median
8.00
51.00
0.03
0.03
0.47
0.16
1.77
13.00
0.78
g/t>
95&
93.00
530.00
0.07
0.05
2.44
0.91
10.10
198.00
0.78
MUKJ
Mean;
mm
82JJO
0,04
04*
QM
NR
0.42
NE
i.90
180>W
0.2©
' ResHte
Median
§.00
65.00
0.04
0,14
9M
HR
0.33
: m
1,50
; iw.oo
0,16
(fflg/»
905^
15,<»
140J0
D,0^
0.35
L75
NR
0.70
NR
340
300,00
0*58
E-4
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Appendix E
Sector 3: Chemical and Allied Products Manufacturing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
category (ii) facilities classified as Standard Industrial Classification (SIC) 28 (except 283 and
285)." Storm water discharges covered include those from establishments primarily engaged
in manufacturing: industrial inorganic chemicals; plastic and synthetic materials; cleaning
agents; paint products and varnishes; industrial organic chemicals; fertilizers; adhesives;
explosives; and printing ink. Also covered are storm water discharges from facilities which
manufacture inks and paints under SIC 3952. Storm water discharges from drug
manufacturing facilities (SIC 283) are not covered.
Pollutants at chemical and allied product facilities include Biochemical Oxygen Demand
(BOD), Chemical Oxygen Demand (COD), Copper, Manganese, and Zinc.
Table E-3
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 3
Pollutant
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
Grab Samples (rag/l>
No*
165
168
51
47
164
16$
m
166
171
im
75
.Mean
36.42
96.14
0.19
0.07
5.83
3.75
2.82
6.94
15.50
200.33
2.11
Median
7.00
57.50
O.Q1
0.01
0,80
0.50
0.24
7.10
1.90
40.00
0.24
95%
67.00
290.00
0.21
0.17
16.00
16.30
12.10
8.50
27.00
793.00
7.70
Composite Samples (mg/l>
JSte*
156
15$
46
42
154
158
159
159
70
Meaa
11.74
77.24
0.12
0.02
4.29
9.51
18.30
93.67
1.74
Median.
6.00
41.00
0.00
0.01
0.82
0.23
1.70
25.00
0.24
95%
45.00
320.00
0.19
0.07
17.00
16.40
23.70
453.00
4.20
JWRF Results (Big/0
,Mem,
12U50
82.00
0,04
048
QM
MR
0.42
NK
1.90
180,00
OJO
jMaB.,
$.00
65.00
«WH
0,14
0,68
HR
o.sa
m
1,50
moo
0.16
90%
15,00
140JX*
0,0?
0.35
L75
NK.
0.70
KR
3.30
300.00
0,50
E-5
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Appendix E
Sector 4: Asphalt Paving and Roofing Materials Manufacturers and Lubricant
Manufacturers
The definition of storm water discharges associated with an industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
category (ii) which identifies facilities classified as Standard Industrial Classification (SIC)
code 29." This covers storm water discharges associated with industrial activities at facilities
with a primary SIC code of 2951 (Asphalt Paving Mixtures and Blocks), 2952 (Asphalt Felts
and Coatings), and 2992 (Lubricating Oils and Greases) including portable plants.
Hereinafter, facilities with primary SIC codes 2951 or 2952 will be referred to as 'Asphalt
Facilities,' and facilities with primary SIC code 2992 as 'Lubricant Manufacturers.'
Facilities manufacturing asphalt concrete, paving materials, or block, are classified as SIC
code 2951. Facilities primarily engaged in manufacturing asphalt roofing products, such as
asphalt felts, shingles, and other products including tars, pitch, and roofing cements, are
identified as SIC 2952. Facilities primarily engaged in manufacturing oils and lubricants are
identified as SIC 2992.
Manufacturers of Asphalt Paving Mixtures and Blocks: These facilities stockpile a
variety of raw materials such as sand, gravel, crushed limestone, and recycled asphalt
products (RAP). These facilities produce asphalt concrete, and may also mold and cure
asphalt concrete products such as asphalt blocks. There are two types of facilities associated
with these activities, batch plants and drum plants.
Manufacturers of Roofing Materials: Manufacturers classified hi standard industrial code
2952 typically produce roofing felts, and impregnated roofing felts (shingles) and other
products, such as tar papers, impregnated asphalt siding, expansion joints, roofing cements,
tars and pitches. Many of the roofing products consist of materials coated with asphalt
purchased from a vendor and then cured and stored out of doors until shipped.
Manufacturers of Lubricating Oils and Greases: Facilities primarily engaged in blending,
compounding, and re-refining lubricating oils and greases from purchased mineral, animal,
and vegetable materials are identified as SIC code 2992. SIC code 2992 includes
manufacturers of metalworking fluids, cutting oils, gear oils, hydraulic brake fluid,
transmission fluid, and other automotive and industrial oil and greases.
Significant materials at these facilities include additives, asphalt, asphalt cement, asphalt
concrete, asphalt felt, asphalt release agents, asphalt shingles, crushed stone, fuel, granite,
gravel, limestone, lubricants, mineral spirits, oil, quartzite rock, reclaimed asphalt pavement,
sand, sandstone, and slag. The pollutants of concern at facilities which manufacture asphalt
and lubricant include total, suspended solids (TSS), oil and grease, chemical oxygen demand
(COD), and fuel wastes.
E-6
-------
Appendix E
Table E-4
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 4
PeitateRf:
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (pg/1}
No,
61
64
m,
64
63
%>
&
m
Mean
39.99
151.55
0.97
5.89
0.37
7.1
2.13
286.67
Median
7.00
48.00
0.31
1.25
0.13
7.1
1.13
93.00
95$
47.00
485.00
2.63
28.00
1.65
8.80
7.16
1330.00
Composite Samples 6ag/l}
No,
51
53
52
54
n
54
Mean.
10.87
86.93
0.82
0.28
1.63
165.03
Median
4.00
50.00
0.03
0.15
0.99
46.00
: 9S%
22.00
375.00
2.43
1.28
6.28
860.00
Nra5PHes«Us(jng/l>
Mean
12.00
S2.M
0.04
D48
OM
MR.
0,42
Kfk
W
imm
0,20
Median
$.00
6S.OO
0,04
W4
G<68
MR
: 0.33
m
1,5D
IOG.OO
0.16
90%
15,00
14D.M
om
0^5
I+75
KR
0,70
JvfR
3.30
300.00
0.50
E-7
-------
Appendix E
Sector 5: Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing
Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (ii) which identifies facilities classified as Standard Industrial Classification
(SIC) code 32."
Glass Product Manufacturing - Facilities primarily engaged hi the manufacturing of glass
and glassware, or manufacturing glass products from purchased glass are classified under
standard industrial groups 321-323. Manufacturing processes include the storage of raw
materials, weighing the materials, charging, melting and forming. Significant materials may
include silica sand, limestones, feldspars, borates, soda ash, boric acid, potash and barium
carbonate.
Cement Manufacturing - Facilities primarily engaged in manufacturing hydraulic cement
(e.g., portland, natural, masonry, and pozzolana cements) are identified as SIC code 3241.
The three basic steps hi cement manufacturing are: 1) proportioning, grinding and blending
raw materials; 2) heating raw materials to produce a hard, stony substance known as
"clinker"; and 3) combining the clinker with other materials and grinding the mixture into a
fine powdery form.
Clay Product Manufacturing - Facilities primarily engaged hi manufacturing clay products,
including brick, tile (clay or ceramic), or pottery products are classified as standard industrial
groups 325 and 326. Although clay product manufacturing facilities produce a wide variety
of final products, there are several similar processing steps shared by most facilities in this
industry: 1) storage and preparation of raw materials; 2) forming; 3) drying; 4) firing; and
5) cooling. Manufacturers classified as standard industrial groups 325 and 326 typically use
clay (common, silt, kaolin and/or phyllite) and shale (mud, red, blue and/or common) as
their primary raw materials. Raw materials are generally stored outside.
Concrete Products - Facilities primarily engaged hi manufacturing concrete products,
including ready-mixed concrete, are identified as SIC group 327. Although concrete product
facilities hi SIC group 327 produce a variety of final products, they all have common raw
materials and activities.
Concrete products manufacturers combine cement, aggregate, and water to form concrete.
Aggregate generally consists of: sand, gravel, crushed stone, cinder, shale, slag, clay, slate,
pumice, vermiculite, scoria, perlite, diatomite, barite, limonite, magnetite, or ilmenite.
Admixtures including fly ash, calcium chloride, triethanolamine, calcium salt, lignosulfunic
acid, vinosol, saponin, keratin, sulfonated hydrocarbon, fatty acid glyceride, vinyl acetate,
and styrene copolymer of vinyl acetate may be added to obtain desired characteristics, such
as slower or more rapid curing tunes.
E-8
-------
Appendix E
Gvpsum Products Manufacturing - Facilities primarily engaged in manufacturing plaster,
wallboard, and other products composed wholly or partially of gypsum (except plaster of
paris and papier-mache) are classified as SIC code 3275. The gypsum product manufacturing
process begins with calcining the gypsum: finely ground raw gypsum (referred to as "land
plaster") is fed into imp mills or calcining kettles where extreme heat removes 75 percent of
the gypsum's molecular moisture. The result is a dry powder called stucco, which is cooled
and conveyed to storage bins. To produce wallboard, stucco is fed into phi mixers where it
is blended with water and other additives to produce a slurry. The slurry is then applied to
continuous sheets of paper to form wallboard. In addition to producing wallboard, some
facilities may combine stucco with additives (excluding water) to produce plaster.
As a result of the industrial activities such as materials handling and storage and other
industry specific activities, pollutants of concern include: total suspended solids (TSS),
chemical oxygen demand (COD), oil and grease, lead, aluminum, zinc, potassium and
sulfate.
Table E-5
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 5
Pollutant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples &ȣ$
Ho.
310
313
<5
15
303
315
313
297
304
311
8
Mean '.
14.30
107.47
0.13
0.24
1.99
4.67
1.21
8.59
3.82
1066.79
0.35
Median
5.00
51.30
0.02
0.01
0.60
1.40
0.28
8.50
1.16
200.00
0.14
95%
32.00
317.00
0.40
3.30
3.03
17.10
4.96
11.30
7.00
2620.00
1.17
Composite Samples (tng/l)
No,
300
302
5
15
292
300
292
302
7
.Meatt
7.32
77.53
0.16
0.25
1.40
0.87
2.37
385.51
0.39
Median.
4.20
43.15
0.04
0.01
0.55
0.25
1.00
149.00
0.18
95%
26.00
240.00
0.40
3.40
3.03
3.24
5.00
1440.00
1.12
NURF Resolfe 6ng/l}
.Mean..
12,60
&.J&
0,04
04S
o>m
NR
0.42
NR
L90
180.00
0,20
Mediaa
9.00
65.00
0.04
044
0><58
HR
0.33
NR
1,50
10CKQQ
0.16
..Mi,.
15,60.
140.00
0,09
0*35
1.75
NR
0.70
NR
3*3$
300,00
0,50
E-9
-------
Appendix E
Sector 6: Primary Metals Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges from eleven major categories of facilities, including: "(ii) facilities
classified as Standard Industrial Classification (SIC) 33 [primary metals facilities]." Storm
water discharges covered include those from the following types of activities: Steel works,
blast furnaces, and rolling and finishing nulls (SIC 331); Iron and steel foundries (SIC 332)
Primary smelting and refining of nonferrous metals (SIC 333); Secondary smelting and
refining of nonferrous metals (SIC 334); Rolling, drawing, and extruding of nonferrous
metals (SIC 335); Nonferrous foundries (SIC 336); and Miscellaneous primary metal
products, not elsewhere classified (SIC 339).
Facilities in the primary metals industry are typically involved in one or more of the
following general operations: raw material storage and handling; furnace and oven related
processes; preparation of molds, casts, or dies; metal cleaning, treating and finishing; and
waste handling and disposal.
Pollutants at primary metals facilities include Aluminum, Copper, Iron, Manganese, Total
Suspended Solids (TSS), and Zinc.
Table E-6
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 6
Pollutant
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
£»t> Samites («g/fr
Nfo, '
163
162
14$
138
14$
163
163
163
160
m
144
M$a8 I
32.15
221.34
3.46
0.78
1.17
8.88
1.25
7.07
3.56
368.45
8.85
Median.
11.00
70.50
0.10
0.02
0.68
1.00
0.17
7.30
1.98
71.75
0.46
fc#
83.00
870.00
3.40
1.41
3.60
47.00
1.80
8.90
13.00
1700.00
11.80
C«Hip0$jte SSfflftfeS (qj$/ft
No,
140
151
131
113
13$
149
I4S
i49
132
Mfeiffl
34.08
109.84
2.25
0.19
1.38
0.52
3.05
162.28
6.55
MJ&tlaa
8.30
60.00
0.07
0.02
0.77
0.14
1.60
69.00
0.43
$5*
61.50
420.00
3.10
1.00
4.30
0.96
9.70
717.00
9.67
m£&P Iteflritt ftigfl.>
wfem
J&QG
mm
0.04
04*
0.8$
RE
0.42
MR
1,90
1S0.00
0,20
Median
9,00
65.00
O.Q4
044
0,6$
N»
0<33
J*R
1.S0
100,00
50
E-10
-------
Appendix E
Sector 7: Metal Mining (Ore Mining and Dressing)
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (iii) facilities classified by Standard Industrial Classification (SIC) codes 10
through 14 including active or inactive mining operations (except for areas coal mining
operations no longer meeting the definition of reclamation area under 40 CFR 434.11(1)
because the performance bond issued to the facility by the appropriate SMCRA authority has
been released, or except for areas of non-coal mining operations which have been released
from applicable State or Federal reclamation requirements after December 17, 1990) and oil
and gas exploration production, processing or treatment operations, or transmission facilities
that discharge storm water contaminated by contact with or that has come into contact with
any overburden, raw material, intermediate products, finished products, byproducts or waste
products located on the site of such operations." The following is a listing of the types of
mining/milling facilities that are covered under SIC code 10:
Iron Ores (SIC 1011)
Copper Ores (SIC 1021)
Lead and Zinc Ores (SIC 1031)
Gold Ores (SIC 1041)
Silver Ores (SIC 1044)
Ferroalloy Ores, Except Vanadium (SIC 1061)
Metal Mining Services (SIC 1081)
Uranium-Radium-Vanadium Ores (SIC 1094)
Miscellaneous Metal Ores, Not Elsewhere Classified (SIC 1099)
The term "metal mining" includes all ore mining and/or dressing and beneficiating
operations, whether performed at mills operated in conjunction with the mines served or at
mills, such as custom mills, operated separately. The above establishments are primarily
engaged in mining, developing mines, or exploring for metallic minerals (ores). This group
also includes all ore dressing and beneficiating operations, whether performed at mills
operated hi conjunction with the mines served or at mills, such as custom mills, operated
separately. These include mills which crush, grind, wash, dry, sinter, calcine, or leach ore,
or perform gravity separation or flotation operations.
Pollutants of concern include total suspended solids (TSS), total dissolved solids (TDS),
heavy metals, oil and grease, dust, and turbidity.
E-ll
-------
r
Appendix E
Table E-7
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 7
Pollutant
BODS
COD
Copper
Lead
N02+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
No,
18
18
19
M
16
16
21
24
15
17
14
" Oral? &u
Mean
10.02
144.54
3.88
0.89
1.10
2.36
1.83
7.23
3.27
6995.78
3.04
ttpjeg (ing
Median
9.00
71.10
0.14
0.00
0.75
0.00
0.30
7.45
2.60
403.00
0.59
$>
95%
27.00
630.00
46.80
1.20
5.30
22.00
11.00
8.00
9.40
100000.00
16.30
CQrtppsite$ainpfe*(TOg/i>
No.
12
15
13
13
13
16
13
15
8
Mean
10.63
195.07
0.59
6.07
0.90
1.06
3.39
623.09
3.87
Median
6.00
160.00
0.09
0.05
0.86
0.38
3.20
330.00
0.66
95&
44.00
740.00
3.40
65.00
2.10
7.00
11.80
3049.00
20.90
WKP Results (tng/i>
Mean
12,00
$%m
QM
048
GM
NR
0.42
KfR
1-90
180.0&
0,20
Median
$.00
63.00
0.04
0,14
QM
m.
0.33
ttfc
1,50
100,00
0,16
90%
ISM
140.50
0.09
Ov35
J.75
NR
0.70
NR
3-30
3QO.SO
0,50
E-12
-------
Appendix E
Sector 8: Coal Mines and Coal Mining-Related Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (iii) facilities classified by Standard Industrial Classification (SIC) codes 10
through 14 including active or inactive mining operations (except for areas coal mining
operations no longer meeting the definition of reclamation area under 40 CFR 434.11(1)
because the performance bond issued to the facility by the appropriate SMCRA authority has
been released, or except for areas of non-coal mining operations which have been released
from applicable State or Federal reclamation requirements after December 17, 1990) and oil
and gas exploration production, processing or treatment operations, or transmission facilities
that discharge storm water contaminated by contact with or that has come into contact with
any overburden, raw material, intermediate products, finished products, byproducts or waste
products located on the site of such operations." Coal mining activities are classified as
Standard Industrial Classification (SIC) code 12, and includes the following operations:
• Bituminous Coal and Lignite Surface Mining (SIC 1221)
• Bituminous Coal Underground Mining (SIC 1222)
• Anthracite Mining (SIC 1231)
• Coal Mining Services (SIC 1241)
Storm water discharges are covered at all inactive facilities and only from haul roads and rail
lines at active facilities. Haul roads are non-public roads on which coal or coal refuse is
conveyed. Access roads are non-public roads providing light vehicular traffic within the
facility property and to public roadways. Railroad spurs, sidings, and internal haulage lines
are rail lines used for hauling coal within the facility property and to off-site commercial
railroad lines or loading areas. Inactive coal mines and related areas are abandoned and
other inactive mines, refuse disposal sites and other mining-related areas.
Significant materials include coal, refuse coal, used equipment, and other equipment used to
haul coal.
Pollutants of concern include total suspended solids (TSS), total dissolved solids (TDS),
turbidity, oil and grease, dust, heavy metals, and acid/alkaline wastes.
E-13
-------
Appendix E
Table E-8
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 8
Pollutant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
0«rf> Ssflsptes C«g/l> :
No,
7
#
i
2
8
19
8
21
5>
10
2
Mean
3.63
16.45
0.00
0.02
0.77
2.17
0.12
7.40
2.56
5607.60
0.17
Median
1.80
6.00
0.00
0.02
0.40
1.20
0.04
7.58
2.60
150.00
0.17
- 95& •
9.00
83.90
0.00
0.04
3.12
13.90
0.66
8.45
5.20
33240.00
0.30
^ £dffl£0$fa! .&*$&* 08g/f}
Jfe
4
8
$
z
$
5
; s.
8
Z.
Msm
6.55
26.86
0.00
0.00
1.00
0.12
2.65
689.75
0.06
Median
3.90
13.50
0.00
0.00
0.61
0.00
1.46
251.00
0.06
)?5$
17.40
115.00
0.00
0.00
3.12
0.58
7.40
3880.00
0.09
RORPS^vdsfelg/l)
Mesa
12.00
n.m
QM
04$
QM
NR
0*42
NR
IM
mm
0,20
Median
9.00
6S'.00
0.04
i 0,i4
! 0<<58
m
\ 0.33.
j KR
1,50
; too
-------
Appendix E
Sector 9: Oil and Gas Extraction Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (iii)...oil and gas exploration production, processing or treatment operations, or
transmission facilities that discharge storm water contaminated by contact with or that has
come into contact with any overburden, raw material, intermediate products, finished
products, byproducts or waste products located on the site of such operations." Oil and gas
extraction facilities are classified as Standard Industrial Classification (SIC) code 13. The
activities subject to storm water regulations include the following types of operations:
• Crude Petroleum and Natural Gas (SIC 1311)
• Natural Gas Liquids (SIC 1321)
• Drilling Oil and Gas Wells (SIC 1321)
• Oil and Gas Field Exploration Services (SIC 1382)
• Oil and Gas Field Services, Not Elsewhere Classified (SIC 1389)
Table E-9
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 9
pollutant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (jag/l)
No,
3$
3
-------
Appendix E
Sector 10: Mineral Mining and Processing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...(iii) facilities classified as Standard Industrial Classifications 10 through 14 (mineral
industry) including active or inactive mining operations (except for areas of coal mining
operations no longer meeting the definition of a reclamation area under 40 CFR 434.11(1)
because the performance bond issued to the facility by the appropriate SMCRA authority has
been released, or except for areas of non-coal mining operations which have been released
from applicable State or Federal reclamation requirements after December 17, 1990) and oil
and gas exploration, production, processing, or treatment operations, or storm water
contaminated by contact with, any overburden, raw material, intermediate products, finished
products, by-products or waste products located on the site of such operations."
Mineral mining and processing facilities subject to storm water regulations include the
following types of operations:
• Dimension Stone, (SIC Code 1411);
• Crushed and Broken Limestone, (SIC Code 1422);
• Crushed and Broken Granite, (SIC Code 1423);
• Crushed and Broken Stone, (SIC Code 1429);
• Construction Sand and Gravel, (SIC Code 1442);
• Industrial Sand and Gravel, (SIC Code 1446);
• Kaolin and Ball Clay, (SIC Code 1455);
• Clay, Ceramic, and Refractory Minerals, (SIC Code 1459);
• Potash, Soda, and Borate Minerals, (SIC Code 1474);
• Phosphate Rock, (SIC Code 1475);
• Chemical and Fertilizer Mineral Mining, (SIC Code 1479); and
• Miscellaneous Nonmetallic Minerals, Except Fuels, (SIC Code 1499).
There are typically three phases to a mining operation: the exploration and construction
phase; the active phase; and the reclamation phase. The exploration and construction phase
entails exploration and a certain amount of land disturbance to determine the financial
viability of a site. Construction includes building of site access roads, and removal of
overburden and waste rock to expose minable ore. These land-disturbing activities are
significant potential sources of storm water contaminants. The active phase includes each
step from extraction through production of a saleable product. The active phase may include
periods of inactivity due to the seasonal nature of these mineral mining activities. The final
phase of reclamation is intended to return the land to its pre-mining state. Non-metallic
minerals are recovered using four basic forms of extraction techniques: open pit, open face
or quarry mining; dredging; solution mining; and underground mining. Each type of
extraction method may be followed by varying methods of beneficiation and processing.
Storm water discharges covered include all discharges where precipitation and run-on come
into contact with significant materials commonly found at mining facilities which include:
E-16
-------
Appendix E
overburden; waste rock; sub-ore piles; tailings; petroleum-based products; solvents and
detergents; manufactured products; and other waste materials. This includes storm water
discharges from haul roads, access roads, and rail lines used or traveled by carriers of raw
materials, manufactured products, waste materials, or by-products created by the facility. In
addition, overflows from facilities governed by effluent limitation guidelines with
impoundments such as settling or sedimentation ponds, tailings ponds or piles, or other
impoundments designed to contain a 10-year, 24-hour storm event are also covered.
Because of the land-disturbing nature of the mineral mining and processing industry,
contaminants of concern generated by industrial activities in this industry include total
suspended solids (TSS), total dissolved solids (TDS), turbidity, pH, dust, heavy metals,
solvents, and oils.
Table E-10
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 10
Poltotant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
qrat> Sample frjgfl)
m>
: 55;
56:
6
$
50:
60
55
58
&
: 55
: 5
Mean
7.09
58.79
0.05
0.00
0.98
1.08
0.84
7.60
1.81
1848.14
0.18
Mediaa;
5.00
33.00
0.01
0.00
0.65
0.00
0.20
7.55
1.05
181.00
0.18
95%
24.00
247.00
0.15
0.00
3.00
5.45
4.69
9.10
8.00
11120.00
0.34
Composite Samples (mg/1)
No>
51
51
4
4
45
51
50
51
3
Mean
6.89
66.20
0.01
0.00
1.27
1.13
2.41
1576.24
0.29
Median
5.00
37.00
0.01
0.00
0.76
0.24
0.84
296.00
0.30
95%
17.00
185.00
0.01
0.00
4.17
2.61
6.89
10080.00
0.30
miRP Results (ragfl)
Mean
I'iOO
mm
Oufc*
0.18
QM
NR
0,42
NR
1.90
i«Mte
0.20
Median
¥;oij
63.00
0.04
0,14
0,68
MR
0.33
NR
1.50
JOG.QO
046
90%
i5.00
140,00
6M
0.3S
1*75
NR
0,70
Kfc
3.30
3Q04J&
0>50
E-17
-------
Appendix £
Sector 11: Hazardous Waste, Treatment, Storage, or Disposal Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...(iv) hazardous waste treatment, storage, or disposal facilities, including those that are
operating under Subtitle C of RCRA [Resource Conservation and Recovery Act] ...."
Industrial activities at treatment, storage, or disposal facilities (TSDF) can be described as
follows:
At TSDFs, some wastes are disposed without any intervening storage or treatment, while
other wastes are held in storage prior to treatment or disposal. Hazardous wastes are
generally stored hi containers and tanks, which are enclosed by a bermed area to prevent any
releases to the environment from the storage units.
The processes for treating hazardous wastes can be divided into two major categories based
on whether the waste is organic or inorganic in nature. Organic wastes are treated by
destructive technologies, such as incineration, whereas inorganic wastes are treated using
fixation technologies, such as stabilization, in which the hazardous constituents are
immobilized in the residual matrix. Residuals from fixation processes are usually land-
disposed.
Hazardous waste disposal units include landfills, surface impoundments, waste piles, and
land treatment units. Wastes are also disposed of hi incinerators. Some liquid hazardous
wastes are underground-injected into deep wells regulated under the Underground Injection
Control (UIC) program.
Hazardous wastes are also recycled at TSDFs. Recycling is considered a form of treatment,
however, the recycling process itself is not generally regulated under RCRA. Recycling
activities include reclamation, regeneration, reuse, burning for energy or materials recovery,
and use hi a manner constituting disposal (i.e., land application of hazardous waste or
products containing hazardous waste).
E-18
-------
Appendix E
Table £-11
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 11
Pollutant
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
Crab Samples (ing/1) ' '.
Jfa.
g
8
9
9
/ 9
- 1
9
8
••
Mean
17.75
177.40
0.46
9.33
0.24
6.93
1.43
337.63
Median
11.50
41.00
0.47
0.00
0.07
7.29
1.30
127.50
95$
45.00
500.00
0.79
74.00
1.60
7.79
3.00
1100.00
- ' Composite Samples (iag/1)
No<
#
>
•"
9
$
'•
9
9
Wfean .
9.44
48.90
0.39
0.11
1.07
82.67
Median
7.00
34.00
0.34
0.09
0.92
32.00
95%
45.00
131.00
0.67
0.32
3.92
304.00
NUKP 3lesalts fcag/l>
Mean
12J»
82,M
0.
-------
Appendix E
Sector 12: Landfills/Land Application Sites
The definition of storm water discharge associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (v) landfills, land application sites and open dumps that receive industrial
wastes." Special conditions apply to land disposal sites which meet the definition of a
landfill under RCRA Subtitle D. Landfills are defined as areas of land or excavation in
which wastes are placed for permanent disposal, and that are not land application units,
surface impoundments, injection wells, or waste piles. Included in this definition are
municipal solid waste landfills (MSWLFs) and industrial solid non-hazardous waste landfills.
Land application sites are defined as facilities at which wastes are applied onto or
incorporated into the soil surface for the purpose of beneficial use or waste treatment and
disposal. Open dumps are defined as solid waste disposal units not in compliance with
State/Federal criteria established under RCRA Subtitle D.
Municipal Solid Waste Landfills are constructed according to one of two generic designs,
the trench method, area method, or a combination of both. The trench method requires the
excavation of a trench into which wastes will be placed. In the area method, wastes are
placed directly on the ground surface and disposal follows the natural contours of the land.
Some landfills use combinations of the two methods at different times depending on the
location of the active unit.
Most modern landfills contain one or more separate "units," which are final waste
containment areas. Active units continue to receive wastes until they have reached disposal
capacity. When capacity is reached, a unit is capped with a final cover, and additional
wastes are placed in other active units. Within each unit, wastes are added hi layers referred
to as lifts. Received wastes are spread across the working face of the landfill to a depth of
six to twenty feet and then compacted. At the end of each working day a thin layer of soil
(daily cover) is spread on top of the added wastes and compacted. A large unit may consist
of multiple lifts, depending on the planned final depth. When a landfill (or landfill unit) has
reached disposal capacity, a final cover is applied. Final covers generally provide a
relatively impermeable cap over which topsoil is placed and vegetation is established.
Industrial Landfills are similar to MSWLFs, but only receive wastes from industrial
facilities such as factories, processing plants, and manufacturing sites. These facilities may
also receive hazardous wastes from very small quantity hazardous waste generators (less than
one hundred kilograms per month), as defined in RCRA Subtitle C.
Land Application Sites receive wastes (primarily wastewaters and sludges) from facilities in
virtually every major industrial category. Typically, individual land application sites will
only dispose of wastes with specific characteristics. However, the criteria for selection are
site-specific, depending on type of process used and the soil characteristics.
The significant materials at land disposal sites consist of the wastes and the equipment used
to handle the wastes. Examples of wastes disposed at these sites include household waste
E-20
-------
Appendix E
(including household hazardous waste which is excluded from RCRA hazardous waste
regulation), non-hazardous incinerator ashes, commercial wastes, yard wastes, tires, white
goods, construction wastes, municipal and industrial sludges, asbestos, and other industrial
wastes from various industrial facilities.
Pollutants of concern at land disposal sites include total suspended solids (TSS), oil and
grease, heavy metals, leachate, organics, and chemical oxygen demand (COD) and other
toxic pollutants.
Table E-12
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 12
BoJtotant
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (ffig/1)
Ho, ;
5J:
'51
-
9
50
5$
50
54
51;
51.
Mean
13.66
114.46
9.62
1.57
2.97
0.91
7.41
3.36
2978.97
Mitten
7.00
31.00
0.08
0.55
o.oo
0.50
7.32
1.10
633.00
95&
59.00
825.00
83.70
4.10
14.00
3.35
8.40
12.00
19370.00
CoiBpaske Samples (mg/l>
NP.
48
48
7
47
47
-
48
47
Mean
9.04
102.02
20.64
1.38
0.95
3.03
1850.17
Med&n
4.40
27.50
0.18
0.50
0.38
1.04
370.00
95&
34.00
548.00
143.00
6.02
4.08
14.20
9140.00
Ntraa? itesttta (i&g/i)
Mean
12.00
mm
0.04
OJ8
046
NR
0*42
KB.
IM
1«LCH>
0,20
Median
9,00
65,00
0.04
0.14
0.68
NR
033
JS»
1.SO
100.00
0.16
90%
15,00
140.00
0,09
OJ5
IJ5
KfR
0.70
NR
WO
300.00
040
E-21
-------
Appendix £
Sector 13: Automobile Salvage Yards
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven categories of facilities, including: "...
category (vi) facilities classified as Standard Industrial Classification (SIC) code 5015." That
SIC code includes battery reclaimers, salvage yards, and automobile junkyards.
Storm water discharges include discharges where precipitation and storm water runon come
into contact with significant materials including, but are not limited to parts storage and
cleaning, storage of junked vehicles, waste products, by-products, stored materials, fuels,
and areas used for dismantling operations. Dismantlers are a major source for replacement
parts for motor vehicles in service. The primary activity involves the dismantling or
wrecking of used motor vehicles. Some facilities, however, perform vehicle maintenance
and may rebuild vehicles for resale.
Typically, automobile dismantling facilities receive vehicles that are either uneconomical to
run or wrecks that are uneconomical to repair. The nature of operations generally depends
on the size and location of the facility. In urban areas where land is more valuable, vehicles
are typically dismantled upon arrival, parts are segregated, cleaned, and stored. Remaining
hulks are generally sold to scrap dealers rather than stored on site due to limited space. In
more rural areas, discarded vehicles are typically stored on the lot and parts removed as
necessary. Remaining hulks are sold to scrap dealers less frequently.
Once a used vehicle is brought to the site, fluids may be drained and the tires, gas tank,
radiator, engine and seats may be removed. The dismantler may separate and clean parts.
Such cleaning may include steam cleaning of the engine and transmission as well as the use
of solvents to remove oil and grease and other residues. Usable parts are then inventoried
and stored for resale. The remaining car and/or truck bodies are stored on site for future
sale of the sheet metal and glass. Stripped vehicles and parts that have no resale value are
typically crushed and sold to a steel scrapper. Some operations may, however, convert used
vehicles and parts into steel scrap as a secondary operation. This is accomplished by
incineration, shearing (bale shearer), shredding, or baling.
Significant materials include automobile parts (e.g., engine blocks, mufflers, batteries),
solvents, oils, cleaning agents (e.g., detergents), used equipment, and junked automobiles.
Due to the nature of the industrial activities at these facilities, pollutants of concern include:
oil and grease, ethylene glycol, heavy metals, petroleum hydrocarbons, solvents, suspended
solids, acid/alkaline wastes, detergents, phosphorus and salts.
E-22
-------
Appendix E
Table E-13
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 13
Poflatairt
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grafe Samples {rag/l) ;
No,
13
3(2
* 13
30
13
29
13
13
Mean
7.15
135.00
1.70
5.35
0.19
7.38
2.17
474.39
Median
6.00
61.00
0.83
3.00
0.05
7.41
1.90
183.00
95%- ;
16.00
250.00
5.65
32.00
1.08
8.20
4.87
2300.00
CoiaposKe Samples $ng/l)
No,
30
13
30
30
30
30
Mean
12.61
66.23
1.62
3.05
2.27
839.07
Median
6.50
60.00
1.32
0.26
1.77
226.00
95%
48.00
155.00
4.87
15.70
6.63
5100.00
NCTRPResulta (rag/1)
Mean
12.00
82.60
&Q4
0.18
0,S<5
JsfR
0.42
NR
1,90
180,00
0.20
Median:
9.00
35.00
0.04
044
Q
-------
Appendix E
Sector 14: Scrap and Waste Material Processing and Recycling Facilities
The definition of storm water discharge associated with industrial activity includes point
source discharges from eleven major categories of facilities, including: "... category (vi)
facilities involved in the recycling of materials, including metal scrapyards, battery
reclaimers, salvage yards and automobile junk yards, including but limited to those classified
as Standard Industrial Classification (SIC) 5093 and 5015." Automobile junk yards (SIC
5015) are addressed under Sector 13.
SIC 5093 includes establishments engaged in assembling, breaking up, sorting and the
wholesale distribution of scrap and recyclable waste materials including bag, bottle and box
wastes, fur cuttings, iron and steel scrap, metal and non-ferrous metal scrap, oil, plastics,
rags, rubber, textiles, waste paper and rag wastes.
Table E-14.1
Materials and Sources of Pollutants of Concern
Significant Materials: White Goods (Appliances)
Potential Sources: Leaking oil-filled capacitors, ballasts, leaking compressors,
pumps, leaking pressure vessels, reservoirs, sealed electrical components and chipped
or deteriorated painted surfaces
Pollutants of Concern: PCBs, oil, lubricants, paint pigments or additives such as
lead, and other heavy metals
Significant Materials: Ferrous and Non-ferrous turnings and cuttings
Potential Sources: Cutting oil residue, metallic fines
Pollutants of Concern: Oil, heavy metals
Significant Materials: Materials from Demolition projects
Potential Source: Deteriorated/damaged insulation, chipped painted surfaces, lead,
copper, and steel pipes
Pollutants of Concern: asbestos fibers, lead, copper, zinc, cadmium, other metals
E-24
-------
Appendix E
Table E-14.1
Materials and Sources of Pollutants of Concern (continued)
Significant Materials: Electrical Components, transformers, switch gear, mercury
float switches, sensors
Potential Sources: Leaking oil-filled transformer casings, oil-filled switch, float
switches, radioactive materials in gauges, sensors
Pollutants of Concern: PCBs, oils, mercury, ionizing radioactive isotopes
Significant Materials: Fluorescent lights, light fixtures
Potential Sources: Leaking ballasts
Pollutants of Concern: PCBs, oil
Significant Materials: Food/Beverage Dispensing Equipment
Potential Sources: Leaking fluorescent light ballasts, chipped painted surfaces
Pollutants of Concern: PCBs, oil, heavy metals from paint pigments and additives
Significant Materials: Hospital and Dental Waste & Equipment
Potential Sources: Drums/containers of hospital waste, shielding from diagnostic and
other medical equipment, radioactive materials from gauges, sensors and diagnostic
equipment
Pollutants of Concern: Infectious/bacterial contamination, lead, ionizing radioactive
isotopes
Significant Materials: Instruments
Potential Sources: Radioactive material from thickness gages
Pollutants of Concern: Ionizing radioactive isotopes
Significant Materials: Insulated wire
Potential Sources: Insulation and other coatings, wire
Pollutants of Concern: Lead, zinc, copper
E-25
-------
Appendix E
Table E-14.1
Materials and Sources of Pollutants of Concern (continued)
Significant Materials: Lawnmowers, snowmobiles, motorcycles
Potential Sources: Leaking engines, transmissions, fuel, oil reservoirs,leaking
batteries
Pollutants of Concern: Oils, transmission and brake fluids, fuel, grease, battery acid,
lead acid
Significant Materials: Light gage materials
Potential Sources: Deteriorating insulation, painted surfaces and other coatings
Pollutants of Concern: Asbestos, lead, chromium
Significant Materials: Locomotives, rail cars
Potential Sources: Leaking fuel reservoirs, fittings, hydraulic components, engines,
bearings, compressors, oil reservoirs, worn brake pads, damaged insulation
Pollutants of Concern: PCBs, diesel fuel, hydraulic oil, oil, brake fluid, grease from
fittings, asbestos,
Significant Materials: Motor Vehicle Bodies, Engines, Transmissions, Exhaust
systems
Potential Sources: Leaking fuel tanks, oil reservoirs, transmission housings, brake
fluid reservoir and lines, brake cylinders, shock absorber casing, engine coolant,
wheel weights, leaking battery casings/housings and corroded terminals, painted
surfaces and corrosion inhibitors, exhaust system, catalytic converters
Pollutants of Concern: Fuel, benzene, oil, hydraulic oil, transmission fluids, brake
fluids, ethylene glycol (antifreeze), lead, lead acid, lead oxides, cadmium, zinc, other
heavy metals
Significant Materials: Misc. Machinery and obsolete equipment
Potential Sources: Leaking reservoirs, damaged or chipped painted surfaces/coatings
Pollutants of Concern: Fuel, oil, lubricants, lead, cadmium, zinc
E-26
-------
Appendix E
Table E-14.1
Materials and Sources of Pollutants of Concern (continued)
Significant Materials: Pipes/Materials from Chemical and Industrial Plants
Potential Sources: Chemical residue, insulation, lead piping, chipped or damaged
painted surfaces and protective coatings
Pollutants of Concern: Chemical residue, oil, lubricants, damaged insulation
(asbestos), lead, cadmium, zinc, copper
Significant Materials: Sealed containers, hydraulic cylinders
Potential Sources: Leaking liquid reservoirs, containers, cylinders, misc. chemicals
Pollutants of Concern: Oil, PCBs, solvents, chemical residue
Significant Materials: Salvaged Construction Materials
Potential Sources: Chemical residues, oils, solvents, lubricants, damaged insulation,
chipped painted surfaces and protective coatings
Pollutants of Concern: Chemical residue, oily wastes, asbestos, lead, cadmium, zinc
Significant Materials: Tanks, containers, vessels, cans, drums
Potential Sources: Leaking or damaged containers
Pollutants of Concern: Chemical residue, oily wastes, petroleum products, heating
oil
Significant Materials: Transformers (oil filled)
Potential Sources: Leaking transformer housings
Pollutants of Concern: PCBs, oil
1 Institute of Scrap Recycling Industries, Inc.'s Environmental Operating Guidelines. (April
1992)
(2) Material Processing. The type of processes employed at a particular facility depends on
the type of recyclable and waste material. Typical processes include; torch cutting,
shredding, baling, briquetting, wire stripping and chopping, and compacting. Processes such
as shredding and shearing reduce the bulk size of recyclable scrap and waste into a size that
is more easily transportable and which allows separation into uniform grades based on
E-27
-------
Appendix E
manufacturer specifications. Processes such as shredding of automotive bodies include a
means of segregating materials into their ferrous and non-ferrous fractions.
(3) Segregation of Processed Materials into Uniform Grades. Processing, e.g., shearing,
shredding, baling, etc, of recyclable materials is followed by its segregation into uniform
grades to meet a particular manufacturer's specifications. If segregated recyclable material
remains exposed to precipitation, the potential still exists for storm water contamination.
(4) Disposal of Non-recyclable Waste Materials. During recycling of scrap and waste
materials, a significant fraction is non-recyclable waste materials and must be disposed. The
volume or quantity of material that remains un-recyclable may be too large to permit covered
storage prior to shipment. Consequently, un-recyclable waste materials may be left exposed
to both precipitation and runoff and, therefore, they are a likely source of storm water
pollutants.
(5) Other Operations of Concern. There are a number of activities that frequently occur at
scrap and waste recycling facilities including, heavy vehicle traffic over unstabilized areas,
vehicle maintenance and fueling, and material handling operations. Operations associated
with the receipt, handling, and processing of scrap and waste material frequently occur over
areas that are not stabilized to prevent erosion. Erosion of unstabilized soils is potentially a
significant source of suspended solids hi storm water runoff. For example, sampling results
for total suspended solids (TSS) concentrations provided in sampling data indicated a mean
concentration of 466 mg/1. Unless specific measures or controls are provided to either
prevent erosion or trap the sediment, this material will be carried away in storm water runoff
and eventually exit the site. Suspended solids are of significant concern given the potential
amount of unstabilized area and the significant amount of particulate matter that is often
produced at these facilities. Both organic and inorganic pollutants can become bound up or
absorbed to suspended solids in runoff.
Some scrap and waste recycling facilities may also conduct vehicle maintenance on-site.
Although many of these activities frequently occur indoors, there are specific activities which
could contribute pollutants to storm water. This includes washdown of vehicle maintenance
areas, leaks or spills of fuel, hydraulic fluids and oil and outdoor storage of lubricants,
fluids, oils and oily rags. Fueling stations are also frequently conducted outdoors without
any roof cover. Activities such as topping off fuel tanks, or overfilling storage tanks
(without high-level alarms) are also activities that can cause contamination of runoff. One
last activity of concern is vehicle washing which can result hi accumulated residue material
being discharged to a storm sewer system.
The following table highlights activities associated with vehicle maintenance and material
handling that are potential sources of storm water contamination.
E--28
-------
Appendix E
Table E-14.2
Other Potential Pollutant Source Activities
Activity: Material Handling Systems (forklifts, cranes, conveyors)
Potential Sources: Spills and/or leaks from fueling tanks, spills/leaks from
oil/hydraulic fuel reservoirs, faulty/leaking hose connections/fittings, leaking gaskets
Pollutants of Concern: Accumulated particulate matter (ferrous and non-ferrous
metals, plastics, rubber, other), oil/lubricants, PCBs (electrical equipment), mercury
(electrical controls), lead/battery acids
Activity: Vehicle Maintenance
Potential Sources: Parts cleaning, waste disposal of rags, oil filters, air filters,
batteries, hydraulic fluids, transmission fluids, brake fluids, coolants, lubricants,
degreasers, spent solvents
Pollutants of Concern: Fuel (gas/diesel), fuel additives, oil/lubricants, heavy metals,
brake fluids, transmission fluids, chlorinated solvents, arsenic
Activity: Fueling stations
Potential Sources: spills and leaks during fuel transfer, spills due to "topping off"
tanks, runoff from fueling areas, washdown of fueling areas, leaking storage
tanks,spills of oils, brake fluids, transmission fluids, engine coolants,
Pollutants of Concern: gas/diesel fuel, fuel additives, oil, lubricants, heavy metals
Activity: Vehicle & Equipment cleaning & washing
Potential Sources: Washing and steam cleaning
Pollutants of Concern: solvent cleaners, oil/lubricants/additives, antifreeze (ethylene
glycol)
b. Waste Recycling Facilities (SIC 5093) - (Liquid Recyclable Wastes)
This sub-section applies to those facilities engaged hi the reclaiming and recycling of
liquid wastes such as "spent solvents", "used oil", and "used ethylene glycol" typically
identified under SIC 5093. This sub-section is particularly applicable to those facilities that
participated hi EPA group application number 195. EPA received a single group application
hi this category of waste recycling facilities. The following is a profile of industrial activities
E-29
-------
Appendix £
and the types of significant materials associated with facilities participating in this group
activity.
Group application number 195 included 220 facilities of which 214 were classified as
service centers. Service centers accumulate spent solvent, used oil and antifreeze, filter
cartridges and still bottoms contaminated with dry cleaning solvents (typically
perchloroethylene), and used lacquer thinner from paint gun cleaning machines. The typical
service center has a total storage capacity limited to. approximately 10,000 gallons in
individual containers and tanks with a maximum storage capacity of 20,000 gallons each.
Service centers are typically limited to a maximum of 6 tanks (a total of 120,000 gallons).
Twenty (20) of the service centers also function as accumulation centers where they have a
maximum storage capacity of 70,000 gallons of liquid materials in containers. None of the
containers are opened except under conditions where a container begins to leak or is
damaged.
The group application also included four (4) facilities that operated only as container
transfer stations and do not operate storage tanks. These facilities are largely enclosed
warehouses that provide secondarily-contained storage areas. Three (3) facilities were
identified as used oil depots where only oily water and/or used oil are accumulated in storage
tanks. Storage tanks are limited to a maximum capacity of 20,000 gallons each. Used oil is
transported to the facility in tanker trucks (3,500 gallons) and shipped out in tanker trucks
(7,500 gallons). The used oil is ultimately transported to a processing or re-refining facility
(not covered under this permit). The following table summarizes the percentage of facilities
with significant materials stored.
Table E-14.3
Significant Materials Reported in Group Application Number 195
Significant Materials
Mineral Spirits
Immersion Cleaner
Dry Cleaner Solvents
Paint Solvents
Industrial Solvents
Spent Antifreeze
Used Oil
Allied Products
Percent of Facilities
98%
98%
98%
83%
81%
59%
57%
98%
E-30
-------
Appendix E
The types of materials identified in Table E-14.3 are potential sources of storm water
runoff contamination. Since these materials are stored and transported in individual drums
and bulk storage tanks, the potential exists for spills and/or leaks during all phases of waste
transport, waste transfer, container/drum handling and shipping.
There are a number of operations at these facilities that have significant potential to
release pollutants to the environment if recyclable waste materials are not managed properly.
However, in response to other Federal and State environmental regulations, such as RCRA
and 40 CFR 112 (Oil Pollution Prevention), facilities in this group application currently
employ a range of the best management practices and structural controls that also benefit
storm water quality.
(1) Pollutants Found in Storm Water Discharges. Based on data provided in the group
application number 195, pollutants that were most frequently reported included total
suspended solids (TSS), BOD, COD, nitrite plus nitrate, oil & grease. The following table
provides a statistical summary of data provided in group application number 195.
Table E-14.4
Summary Statistics for Waste Recycling Facilities in Group Application Number 195
(SIC 5093) - (Recyclable Liquid Wastes). All values in mg/1.
Paragraph
Sample Type
BODS
COD
TSS
Nitrite + Nitrate
TKN
Oil & Grease
# of Samples
Grab
22
22
21
22
22
22
Comp
17
17
16
17
17
17
Mean
Grab
18
133
51
0.90
3.1
1.8
Comp
9
83
28
0.78
2.0
1.5
Min
Grab
2
12
5
0.05
1.0
1.0
Comp
2
5
5
0.05
1.0
1.0
Max
Grab
94
660
500
3.70
11.0
5.0
Comp
48
400
84
3.50
6.0
3.0
Median
Grab
5
45
28
0.61
1.5
1.5
Comp
5
45
20
0.38
1.0
1.0
99th Percentile
Grab
79
449
68
3.45
9.9
4.0
Comp
38
320
59
3.29
5.7
3.0
Table E-14.4 indicates that, with the exception of BOD and COD, average concentrations
in grab and composite samples were comparable with average values reported hi the NURP
study (NURP did not measure oil & grease). The data also indicates that pollutants such as
industrial solvents were all below detection limits (without values). In the case of oil &
grease, all concentration values were below the reportable concentration of 10 mg/1 (see 40
CFR 110.10 and 117.21).
(2) Waste Material Handling and Storage. Given the nature and type of materials stored
and handled at these facilities, the potential exists for accidental spills and leaks.
Consequently, the types of activities that occur at these facilities which could potentially
E-31
-------
Appendix E
result in contamination of storm water runoff is also of concern to EPA. The following table
is a list of activities which may result in a release of pollutants.
Table E-14.5
Types of Potential Pollutant-Causing Activities at Waste Recycling Facilities that Handle
Liquid Recyclable Wastes
Activity: Drum/Individual Container Storage and Handling
Potential Sources of Pollutants: Leaks or spills due to faulty container/drum
integrity, e.g., leaking seals or ports. Container materials incompatible with waste
material. Improper stacking and storage of containers.
Pollutants of Concern: Mineral spirits, industrial solvents, immersion cleaners, dry
cleaner solvents, paint solvents, spent antifreeze.
Activity: Return and Fill Stations
Potential Sources of Pollutants: Leaks, spills, or overflows from tanker truck
transfer of wastes and hose drainage. Leaking pipes, valves, pumps, worn or
deteriorated gaskets or seals
Pollutants of Concern: Mineral spirits, industrial solvents, immersion cleaners, dry
cleaner solvents, paint solvents, spent antifreeze.
Activity: Individual Container/Drum Storage
Potential Sources of Pollutants: Leaks or spills due to faulty container/drum
integrity, e.g., leaking seals or ports. Improper stacking and storage of containers.
Pollutants of Concern: Mineral spirits, industrial solvents, immersion cleaners, dry
cleaner solvents, paint solvents, spent antifreeze.
E-32
-------
Appendix E
Table E-14.5
Types of Potential Pollutant-Causing Activities at Waste Recycling Facilities
that Handle Liquid Recyclable Wastes (continued)
Activity: Storage Tank Operations
Potential Sources of Pollutants: Overfill of storage tanks, leaking pipes, valves, worn
or deteriorated pumps seals. Leaking underground storage tanks
Pollutants of Concern: Mineral spirits, industrial solvents, immersion cleaners, dry
cleaner solvents, paint solvents, spent antifreeze.
Activity: Material Handling Equipment
Potential Sources of Pollutants: Leaking fuel lines, worn gaskets, leaking hydraulic
lines and connections.
Pollutants of Concern: Fuel, hydraulic fluid, oil and grease.
3. Other Activities of Concern:
The following table highlights other types of activities that are potential sources of storm
water contamination.
Table E-14.6
Other Potential Sources of Storm Water Contamination
Activity: Vehicle and Equipment Maintenance (if applicable)
Potential Sources of Pollutants: Replacement of fluids such as transmission and brake
fluids, antifreeze, oil and other lubricants, washdown of maintenance areas, dumping
fluids down floor drains connected to storm sewer system, outside storage of fluids
and oily rags and waste material.
Pollutants of Concern: Oil and grease, fuel, accumulated paniculate matter,
antifreeze.
Activity: Vehicle or Equipment Washing (if applicable)
Potential Sources of Pollutants: Wash water or steam cleaning
Pollutants of Concern: Oil, detergents, chlorinated solvents, suspended solids and
accumulated paniculate matter.
E-33
-------
Appendix E
Table E-14.7
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 14
Pollutant i
BODS
COD
Copper
Lead
NOj+NOa-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
O&fe Sitmptes Oag/H)
No*
130
130
102
StO?
129
135
127
136
127
130
97
Mean
23.49
253.33
0.77
0.85
1.78
8.95
0.81
7.52
3.44
437.11
3.16
Median
9.00
120.00
0.26
0.21
0.62
5.00
0.30
7.47
2.05
148.00
1.40
95&
89.00
1100.00
3.00
4.00
3.30
32.00
2.20
9.10
11.10
2096.00
12.00
5D
100,00
0,16
90%
15,00
140,00
&M
Dv3S
L75
NR
0*tG
NR
Sv30
300.00
0.50
E-34
-------
Appendix E
Sector 15: Steam Electric Power Generating Facilities, Including Coal Handling Areas.
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (vii) steam electric power generating facilities." The steam electric power
generating category includes facilities which are coal, oil, gas, or nuclear fired. Heat
captured co-generation facilities are not covered under the definition of storm water discharge
associated with industrial activity, however, dual fuel co-generation facilities are included in
the definition. Ancillary facilities such as fleet centers, gas turbine stations, and substations
that are not contiguous to a steam electric power generation facility are not included in this
classification.
Pollutants of concern include fuel, oil, heavy metals, ammonia, chlorine, sulfuric acid,
sodium hydroxide, ethylene glycol, arsenic, and solvents.
Table E-15
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 15
Pollutant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (a»g/l>
No.
76
76
70
28
Tfi
88
75
v 70
76
76
35
Mean
5.71
104.02
0.08
0.02
5.62
1.38
0.79
7.32
2.41
516.25
0.32
Median
4.25
32.50
0.00
0.00
0.36
0.00
0.29
7.42
1.25
44.00
0.05
95%
20.00
360.00
0.21
0.08
3.70
6.00
3.09
8.28
8.55
1200.00
0.66
Composite Samples (rag/I)
No.
7«
r?
75.
23
77
n
n
77
3$
Mean
5.69
69.47
0.03
0.02
0.75
0.63
1.95
212.35
0.27
Median
4.00
39.50
0.02
0.01
0.45
0.27
1.00
40.00
0.06
: 95%
20.00
280.00
0.13
0.07
3.20
3.10
10.00
810.00
0.92
JSTURP Results (rag/I}
Mean
12J»
82.60
Dv04
048
0,86
NR
0.42
NH
1.90
180.00
0,20
Median
$.00
„ £5.GO
0,04
0,14
0,68
HR
0.33
NR
1.50
mOQ
0.16
90%
15J30
140.00
0.0?
0.35
L75
HR
0.70
Nfc
3.30
300,00
OJO
E-35
-------
Appendix E
Sector 16: Motor Freight Transportation Facilities, Passenger Transportation Facilities,
Rail Transportation Facilities, and United States Postal Service Transportation Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (viii) facilities classified as Standard Industrial Classification (SIC) codes 40, 41,
42 (except 4221-25), 43, 44, and 5171 that have vehicle and equipment maintenance shops,
or equipment cleaning operations." The category further states that only those portions of
the facility that are either involved hi vehicle and equipment maintenance (including vehicle
and equipment rehabilitation, mechanical repairs, painting, fueling, and lubrication) or
equipment cleaning operations are associated with industrial activity.
Vehicle and equipment maintenance is a broad term used to include the following activities:
vehicle and equipment fluid changes, mechanical repairs, parts cleaning, sanding, refinishing,
painting, fueling, locomotive sanding (loading sand for traction), storage of vehicles and
equipment waiting for repair or maintenance, and storage of the related materials and waste
materials, such as oil, fuel, batteries, tires, or oil filters. Equipment cleaning operations
include areas where the following types of activities take place: vehicle exterior wash down,
interior trailer washouts, tank washouts, and rinsing of transfer equipment.
SIC code 40 includes facilities primarily engaged in furnishing transportation by line-haul
railroad, and switching and terminal establishments. The following types of facilities are
examples of those covered under SIC code 40: electric railroad line-haul operation, railroad
line-haul operation, interurban railways, beltline railroads, logging railroads, railroad
terminals, and stations operated by railroad terminal companies.
SIC code 41 includes facilities primarily engaged hi furnishing local and suburban
transportation, such as those providing transportation hi and around a municipality by bus,
rail, or subway. The following types of facilities are examples of those covered under SIC
code 41: bus line operations, airport transportation services (road or rail), cable car
operations, subway operations, ambulance services, sightseeing buses, van pool operations,
limousine rental with drivers, taxicab operations, and school buses not operated by the
educational institution.
SIC code 42 includes facilities providing local or long-distance trucking, transfer, and/or
storage services. The following types of facilities are examples of those covered under SIC
code 42: hauling by dump truck, trucking timber, contract mail carriers, furniture moving,
garbage collection without disposal, over-the-road trucking, long distance trucking, and
freight trucking terminal.
SIC code 43 includes all establishments of the United States Postal Service.
SIC code 5171 includes establishments engaged hi the wholesale distribution of crude
petroleum and petroleum products from bulk liquid storage facilities.
E-36
-------
Appendix E
Significant materials include oily rags, air filters, batteries, hydraulic fluids, paints, and
vehicles awaiting service.
Pollutants include fuel, oil, heavy metals, chlorinated solvents, acid/alkaline wastes, ethylene
glycol, arsenic, heavy metals, organics, hydraulic fluids, dust, paint solids, sediment,
detergents, phosphorus, salts, suspended solids, and biochemical oxygen demand (BOD).
Table E-16
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 16
Militant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
<3fab Samples (mg/1)
No.
116
117
-
m
118
118
114
118
118
I
Mean
11.29
318.10
1.59
9.56
1.47
7.30
3.75
517.01
0.14
Median
6.00
118.00
0.92
0.00
0.54
7.40
1.50
171.50
0.14
m%
34.00
781.00
6.07
27.00
8.10
8.80
13.40
2800.00
0.14
Composite Samples (fflg/1)
No.
105
102
102
m
102
«fc
1
Mean
9.27
189.46
1.41
0.92
2.48
248.51
0.28
Median
6.00
89.00
0.78
0.45
1.40
89.50
0.28
: &*
28.00
489.00
4.26
3.05
8.80
917.00
0.28
NUKP Results (fitg/l>
Mean
um
8&DG
0.04
0.18
DM
m
0,42
NR
IJO
I&LO&
0<29
Median
9,00
65,00
0.04
0.14
&m
NH
0,35
NR
1.50
&XKOO
0,16
W%
ism
140.0&
0,®
OJ5
L75
NR
0.70
NR
3.30
300,00
Q.S&
E-37
-------
Appendix £
Sector 17: Vehicle and Equipment Maintenance and Cleaning Operations
The definition of storm water discharge associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (viii) transportation facilities classified as Standard Industrial Classification (SIC)
codes 40, 41, 42 (except 4221-25), 43, 44, 45, and 5171 that have vehicle and equipment
maintenance shops, equipment cleaning operations, or airport deicing operations."
SIC code 41 includes facilities primarily engaged hi furnishing local and suburban
transportation, such as those providing transportation hi and around a municipality by bus,
rail, or subway. The following types of facilities are examples of those covered under SIC
code 41: bus line operation, airport transportation service (road or rail), cable car operation,
subway operation, ambulance service, sightseeing buses, van pool operation, limousine rental
with drivers, taxicab operation, and school buses not operated by the educational institution.
SIC code 42 includes facilities providing local or long-distance trucking, transfer, and/or
storage services. The following types of facilities are examples of those covered under SIC
code 42: hauling by dump truck, trucking timber, contract mail carriers, furniture moving,
garbage collection without disposal, over-the-road trucking, long distance trucking, and
freight tracking terminal.
SIC code 43 includes all establishments of the United States Postal Service.
SIC code 5171 includes establishments engaged in the wholesale distribution of crude
petroleum and petroleum products from bulk liquid storage facilities.
Vehicle and equipment maintenance is a broad term used to include the following activities:
vehicle and equipment fluid changes, mechanical repairs, parts cleaning, sanding, refinishing,
painting, fueling, storage of vehicles and equipment waiting for repair or maintenance, and
storage of the related materials and waste materials, such as oil, fuel, batteries, or oil filters.
Equipment cleaning operations include areas where the following types of activities take
place: vehicle exterior wash down, ulterior trailer washouts, tank washouts, and rinsing of
transfer equipment.
Significant materials include oils, washing equipment, used equipment, vehicle parts,
vehicles, fuels, paint, waste rags, oil filters, storage tanks, and detergents. Pollutants from
these facilities include fuel, oil, heavy metals, organics, solvents, suspended solids,
phosphorus, salts, acid/alkaline wastes and arsenic.
E-38
-------
Appendix E
Table E-17
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 17
BeJlutaat i
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
,Qrafo Satrapies iipjg/1)
No.
400
408
19
33
39?
418
405
380
405
406
30
Mean i
17.11
135.16
0.02
0.03
2.99
16.38
1.12
7.13
2.69
503.15
0.23
Median
8.00
63.95
0.01
0.01
0.61
2.80
0.33
7.26
1.40
104.00
0.13
95$
60.50
498.00
0.06
0.11
9.00
41.00
3.90
8.89
7.70
1890.00
1.10
Composite Samples (Jrag/J)
No*
"Iff
374
20
n
m
373
m
375
28
Mean i
11.07
85.64
0.02
0.01
1.99
0.73
2.04
454.20
1.34
Median
6.00
48.00
0.01
0.00
0.52
0.29
1.13
67.00
0.11
95$
41,00
250.00
0.08
0.06
5.10
2.91
6.30
1100.00
0.66
mjRP Results (rag^l)
Mean
TOOT
82.W
0.9*
048
QM
NR
0,42
NR
I.90
180*00
-------
Appendix E
Sector 18: Water Transportation Facilities, Vehicle Maintenance/Equipment Cleaning
Operations
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
...category (viii) water transportation facilities classified as Standard Industrial Classification
(SIC) code 44 that have vehicle maintenance shops and/or equipment cleaning operations.
The category further states that only those portions of the facility that are either involved hi
vehicle and equipment maintenance (including vehicle and equipment rehabilitation,
mechanical repairs, painting, fueling, and lubrication), or equipment cleaning operations are
associated with industrial activity. Vehicle and equipment maintenance is a broad term used
to include the following activities: vessel and equipment fluid changes, mechanical repairs,
parts cleaning, sanding, blasting, welding, refinishing, painting, fueling, storage of the
related materials and waste materials, such as oil, fuel, batteries, or oil filters. Equipment
cleaning operations include areas where vessel and vehicle exterior washdown occurs.
SIC code 44 includes facilities primarily engaged hi furnishing water transportation services.
The folio whig types of facilities are examples of those covered under SIC code 44:
Deep Sea Foreign Transportation of Freight (SIC 4412)
Deep Sea Domestic Transportation of Freight (SIC 4424)
Freight Transportation on the Great Lakes - St. Lawrence Seaway (SIC 4432)
Water Transportation of Freight, Not Elsewhere Classified (SIC 4449)
Deep Sea Transportation of Passengers, Except by Ferry (SIC 4481)
Ferries (SIC 4482)
Marine Cargo Handling (SIC 4491)
Towing and Tugboat Services (SIC 4492)
Marinas (SIC 4493)
Water Transportation Services, Not Elsewhere Classified (SIC 4499)
Pollutants of concern include paint solids, heavy metals, suspended solids, spent abrasives,
solvents, dust, paint, paint thinner, spent solvents, dust, oil, ethylene glycol, acid/alkaline
wastes, detergents, fuel, trash, petroleum products, sanitary waste bilge & ballast water,
biochemical oxygen demand (BOD), and bacteria.
E-40
-------
Appendix E
Table E-18
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 18
PoJLutaot i
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
GK* Samples Crog/1}
No.
15
15
4
^ 15
15
15
IS
15
15
4
Mean
8.60
130.93
0.20
4.23
11.93
0.27
7.14
2.64
633.80
0.68
Median
7.00
93.00
0.05
0.60
2.00
0.10
7.00
1.60
135.00
0.22
95%
39.00
500.00
0.70
54.00
96.00
1.20
8.80
16.00
4330.00
2.20
Composite Samples Sag/ft
No,
14
14
3
14
14
14
14
3
Mean.
6.00
75.79
0.10
0.66
0.15
9.41
224.14
0.42
Median
6.00
50.50
0.10
0.65
0.17
0.75
67.50
0.21
95%
11.00
203.00
0.10
1.61
0.32
118.00
944.00
0.87
N13RP Results (mg/l>
Mean
12,00
$2.00
0.04
0,18
0.86
NR
0,42
m
I.9Q
180.00
0,20
Median
9.00
65,00
Q.Q4
0.14
0<68
JJR
0.33
i NH
1,50
*W
-------
Appendix £
Sector 19: Ship Building & Repairing and Boat Building & Repairing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (ii) facilities classified as Standard Industrial Classification (SIC) code 373."
SIC code 373 includes facilities primarily engaged in ship and boat building and repairing
services, and include the following:
• Ship Building and Repairing (SIC code 3731). These are establishments primarily
engaged in building and repairing ships, barges, and lighters, whether self-propelled
or towed by other crafts. The industry also includes the conversion and alteration of
ships and the manufacture of off-shore oil and gas well drilling and production
platforms (whether of not self-propelled). Examples include building and repairing of
barges, cargo vessels, combat ships, crew boats, dredges, ferryboats, fishing vessels,
lighthouse tenders, naval ships, offshore supply boats, passenger-cargo vessels, patrol
boats, sailing vessels, towboats, trawlers, and tugboats.
• Boat Building and Repairing (SIC code 3732). These facilities are primary engaged
in building and repairing boats. Examples include building and repairing of fiberglass
boats, motor-boats, sailboats, rowboats, canoes, dinghies, dories, small fishing boats,
houseboats, kayaks, lifeboats, pontoons, and skiffs.
Pollutants of concern include spent abrasives, solvents, dust, oil, ethylene glycol,
acid/alkaline wastes, detergents, paint solids, heavy metals, spent solvents, biochemical
oxygen demand (BOD), bacteria, suspended solids.
Table E-19
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 19
Sollumnt
BOD5
COD
Copper
Lead
NO2+N03-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Saffljjfes (fflg/1)
No,
44
51
5
6
51
52
51
43
51
$L
*
MSita
5.00
73.22
0.16
0.75
0.79
0.98
0.21
7.20
1.19
92.33
0.31
iM&J&a
2.80
53.00
0.15
0.04
0.72
0.00
0.00
7.30
1.00
17.00
0.31
$5%
15.00
260.00
0.32
4.24
1.60
5.00
0.91
8.11
2.40
505.00
0.36
Composite Samples (aig/l)
No,
"W
43
5
S
45
45
43
45
1
M«aa
7.40
68.80
0.08
11.00
0.85
0.88
2.20
2.36
39.00
Ms4iaS
0.90
28.00
0.09
0.06
0.72
0.00
0.97
8.00
0.33
95&
23.00
240.00
0.13
0.33
1.80
0.76
3.90
200.00
0.33
mm1 Results (mg/l>
M<&8
mm
82M
0*04
GJ.S
VM
NR
0.42
NR
1^0
mw
0^0
M>00
04$
90%
15*0&
14QM
-------
Appendix E
Sector 20: Vehicle Maintenance Areas, Equipment Cleaning Areas, or Deicing Areas
Located at Air Transportation Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
category (viii) facilities classified as Standard Industrial Classification (SIC) 45 that have
vehicle and equipment maintenance shops, equipment cleaning operations, or airport deicing
operations." Only those portions of the facility that are either involved in vehicle and
equipment maintenance (including vehicle and equipment rehabilitation, mechanical repairs,
painting, fueling, and lubrication), equipment cleaning operations, or airport deicing
operations are considered associated with industrial activity. SIC code 45 generally applies
to airports, airport terminals and flying fields. Industrial activities include the following:
Aircraft Deicing includes both deicing to remove frost, snow or ice, and anti-icing which
prevents the accumulation of frost, snow or ice. Deicing of an airplane is accomplished
through the application of a freezing point depressant fluid, commonly ethylene glycol or
propylene glycol, to the exterior surface of an airplane. Both ethylene and propylene glycol
have high biochemical oxygen demands (BOD) when discharged to receiving waters.
Environmental impacts on surface waters due to glycol discharges includes glycol odors and
glycol contaminated surface water and ground water systems, diminished dissolved oxygen
levels and fish kills.
Runway Deicing/Anti-icing activities include deicing/anti-icing operations conducted on
runways, taxiways and ramps. Runway deicing/anti-icing commonly involves either the
application of chemical fluids such as ethylene glycol or propylene glycol, or solid
constituents such as pelletized urea. Urea has a high nitrogen content, therefore degradation
of urea in a receiving water causes an increase in nutrient loadings resulting in an accelerated
growth of algae and eutrophic conditions. Under certain ambient conditions, the degradation
of urea in receiving waters can also result in ammonia concentrations toxic to aquatic life.
Aircraft, Ground Vehicle and Equipment Maintenance and Washing. Maintenance
activities included hi this section include both minor and major operations conducted either
on the apron adjacent to the passenger terminal, or at dedicated maintenance facilities.
Potential pollutant sources from all types of maintenance activities includes spills and leaks of
engine oils, hydraulic fluids, transmission oil, radiator fluids, and chemical solvents used for
parts cleaning. In addition, the disposal of waste parts, batteries, oil and fuel filters, and
oily rags also have a potential for contaminating storm water runoff from maintenance areas
unless proper management practices and operating procedures are implemented. The spent
wash water from aircraft and ground vehicle washing activities could potentially be
contaminated with surface dirt, metals, and fluids (fuel, hydraulic fluid, oil, lavatory waste).
Runway Maintenance. Over time, materials such as tire rubber, oil and grease, paint chips,
and jet fuel can buildup on the surface of a runway causing a reduction hi the friction of the
pavement surface. When the friction level of the runway falls below a specific level, then
maintenance on the runway must be performed. The Federal Aviation Administration (FAA)
E-43
-------
Appendix E
recommends several methods for removing rubber deposits and other contaminants from a
runway surface including high pressure water, chemical solvents, high velocity particle
impact, and mechanical grinding. If not properly managed, the materials removed from the
runway surface could be discharged into nearby surface waters. Similarly, if chemical
solvents are used in the maintenance operation, improper management practices could result
in discharges of the chemical solvents in the storm water runoff from runway areas to nearby
surface waters.
Table E-20
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 20
Pollutant
BODS
COD
Copper
Lead
N02+N03-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
Grab Saropfes (mg/l)
No.
96
£5
1
*
75
98
86
94
$5
96
8
Mean
23.95
81.49
0.03
0.02
1.27
4.66
0.44
7.23
19.79
184.73
0.14
Median
7.50
44.00
0.03
0.02
0.41
1.85
0.20
7.60
1.58
29.00
0.08
95%
42.00
286.00
0.04
0.03
7.90
20.00
1.84
8.30
27.00
1080.00
0.58
€oniposjte Samples (mg/l>
No*
m
88
3
3
65
n
88
87
3
Meaa
21.34
75.63
0.01
0.00
1.29
0.29
16.00
79.59
0.35
Median.
5.30
36.00
0.01
0.00
0.43
0.20
1.40
22.00
0.04
95%
41.40
182.00
0.02
0.00
7.70
0.88
18.80
258.00
1.00
NUIUPJtesalfc (rag/I}
Mean
12JDO
82.00
0.04
048
Q>m
NK
0.42
N»
1^0
X80JW
0.20
Median
9.00
65.00
0,04
044
0>68
NR
6.33
HR
1,50
100,00
0.16
9Q&
15*00
140 JX)
0,09
0,35
1x75
NR
OJO
NR
3.39
300,00
0,50
E44
-------
Appendix £
Sector 22: Domestic Wastewater Treatment Plants
The definition of storm water discharge associated with industrial activity includes point
source discharges from eleven major categories of facilities, including: ".. .category (ix)
treatment works treating domestic sewage or any other sewage sludge or wastewater
treatment device or system, used in the storage treatment, recycling, and reclamation of
municipal or domestic sewage, including land dedicated to the disposal of sewage sludge that
are located within the confines of the facility, with a design flow of 1.0 mgd or more or
required to have an approved pretreatment program under 40 CFR part 403." This category
does not includes farm lands, domestic gardens or lands used for sludge management where
beneficially reused which are not physically located in the confines of the facility, or areas
that are hi compliance with section 405 of the CWA.
Pollutants of concern include diesel, gasoline, petroleum products other than fuels:
numerous grades of motor oils, gear and chassis lubricants, turbine oils, grease and hydraulic
fluids, acid/alkaline wastes, arsenic, organics, chlorinated ethylene glycol, acids and bases
for pH adjustments, disinfectants, polymers and coagulants, alum, ferric chloride, soda ash,
lime, methanol, sodium aluminate, sodium hypochlorite, sodium hydrochloride mineral
spirits, acetone, paint thinner, and lacquer thinner, toluene, TCE, isopropandlamine, and
methyl-ethyl-ketone, dust, paint solids, paint, spent chlorinated solvents, commercial brands
of balance fertilizers (6-6-6, 8-8-8 or 12-12-12), commercial sludge based products, fuel,
process chemicals, diazanon, malathion, amdro, dimethylphthalate, diethyl phthalate,
dichlorvos, carbaryl, skeetal, batex, liquid copper, bacteria, biochemical oxygen demand
(BOD), suspended solids, oil, heavy metals, chlorinated solvents, ethylene glycol, detergents,
metals, phosphorous.
Table E-22
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 22
Pollutant
BODS
COD
Copper
Lead
NOj+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
<3tab Samples (fflg/1)
No.
9®
84
28
2?
84
&
m
82
7§
9G
23
Mean
33.26
133.03
0.07
0.03
20.86
24.24
0.95
6.80
8.10
160.17
0.23
Median
11.50
68.65
0.01
0.00
1.09
0.90
0.50
6.98
1.52
68.10
0.06
$5%
53.40
410.00
0.22
0.15
136.00
26.00
3.17
7.83
18.00
575.00
0.75
Composite Samples (ffig/1)
J?o.
m
84
17
26
83
84
78
88
22
Mean.
46.11
157.95
0.05
0.01
20.50
0.68
4.74
114.44
0.12
Median
8.00
61.59
0.02
0.00
0.87
0.45
1.33
55.50
0.06
95$
200.00
880.00
0.11
0.09
131.27
1.89
11.00
414.00
0.43
NtMP Results (aig/l>
Mean
vim
82x00
0,04
0.18
QM
NR
0.42
HR
L90
180,00
93$
Median
9M
65,00
0.04
0.14
&6S
NR
&33
: MR
1.50
HXXOO
Oa$
90$
ism
mm
0,09
OJS
U75
NR
0.70
NR
SJft
300JDQ
0^9
E-45
-------
Appendix E
Sector 23: Food and Kindred Products Manufacturing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (xi) facilities under Standard Industrial Classification (SIC) codes 20, 21 ..."
• Meat Products (SIC Codes 2011, 2013, and 2015)
• Dairy Products (SIC Codes 2021, 2022, 2023, 2024, and 2026)
• Canned, Frozen, and Preserved Fruits, Vegetables, and Food Specialties (SIC Codes
2032, 2033, 2034, 2035, 2037, and 2038)
• Grain Mill Products (SIC Codes 2041, 2043, 2044, 2045, 2046, 2047, and 2048)
• Bakery Products (SIC Codes 2051, 2052, and 2053)
• Sugar and Confectionery Products (SIC Codes 2061, 2062, 2063, 2064, 2066, 2067,
and 2068)
• Fats and Oils (SIC Codes 2074, 2075, 2076, 2077, and 2079)
• Beverages (SIC Codes 2082, 2083, 2084, 2085, 2086, and 2087)
• Miscellaneous Food Preparations and Kindred Products (SIC Codes 2091, 2092, 2095,
2096, 2097, 2098, and 2099)
• Tobacco Products (SIC Codes 2111, 2121, 2131, and 2141).
Meat Products (SIC Code 201X) - Production related activities include stockyards,
slaughtering (killing, blood processing, viscera handling, and hide processing), cutting and
deboning, meat processing, rendering, and materials recovery.
Dairy Products (SIC Code 202X) - Typical operations may include: culturing, churning,
pressing, curing, blending, condensing, sweetening, drying, milling, and packaging.
Canned, Frozen, and Preserved Fruits, Vegetables, and Frozen Specialties (SIC Code
203X) -Fruits and vegetables are washed, cut, blanched, and cooked prior to being classified
as finished product. Additional operations may include drying, dehydrating, and freezing.
Grain Mills (SIC Code 204X) - Process operations performed in the grain mill subsector
include: washing, milling, debranning, heat treatment (i.e., steeping, parboiling, drying and
cooking), screening, shaping (i.e., extruding, grinding, molding, and flaking), and vitamin
and mineral supplementing.
Bakery Products (SIC Code 205X) - Process operations in this subsector include mixing,
shaping of dough, cooling, and decorating.
Sugar and Confectionery (SIC Code 206X) - Typical processes include mixing, cooking,
and then forming using various techniques. The manufacture of chocolate products requires
shelling, roasting, and grinding of the cocoa beans followed by the typical processing
operations.
E-46
-------
Appendix E
Fats and Oils (SIC Code 207X) Typical process operations at an animal and marine fats and
oils facility include cooking of inedible fats and oils. Operations at an edible oils
manufacturer include refining, bleaching, hydrogenation, fractionation, emulsification,
deodorization, filtration, and blending of the crude oils into edible products.
Beverages (SIC Code 208X) - Process operations may include brewing, distilling,
fermentation, blending, and packaging (i.e., bottling, canning, or bulk packaging).
Miscellaneous Food Preparation and Kindred Products (SIC Code 209X) - Process
operations may include shelling, washing, drying, shaping, baking, frying, and seasoning.
Tobacco Products (SIC Code 21XX) - Typical process operations may include drying,
blending, shaping, cutting and rolling.
Significant materials exposed to storm water at food and kindred products manufacturing
facilities consist mostly of food products or byproducts and include acids (phosphoric,
sulfuric), activated carbon, ammonia, animal cages, bleach, blood, bone meal, brewing
residuals, calcium oxide, carbon dioxide, caustic soda, chlorine, cheese, coke oven tar,
detergent, eggs, ethyl alcohol, fats (greases, shortening, oils), feathers, feed, ferric chloride,
fruits, vegetables, coffee beans, gel bone, gram (flour, oats, wheat), hides, lard, manure,
milk, salts (brine), skim powder, starch, sugar (sweetener, honey, fructose, syrup), tallow,
wastes (off-spec product, sludge), whey, and yeast.
The pollutants of concern are biological oxygen demand (BOD5), total suspended solids
(TSS), oil and grease, pH, and chemicals from applications of pesticides.
Table E-23
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 23
Poltotant i
BODS
COD
Copper
Lead
N02+N03-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
<3o* Samples (mg/l>
No* ^
2§a
aw
i?
12
301
300
3£S
•m
300
2m
33
Mesa i
51.15
192.46
0.08
0.01
1.17
5.35
5.13
7.06
4.95
252.39
0.78
Median
13.90
77.00
0.04
0.01
0.56
1.05
0.56
7.10
2.35
72.50
0.21
9S%
206.00
745.00
0.27
0.03
3.70
20.95
9.06
8.40
18.00
1320.00
2.10
Conjppsfte Samples (mg/l>
No.
287
286
17
W
289
,
•287.
•.
2<&
28(5
31
Mean
42.54
141.65
0.05
0.01
0.98
1.32
4.07
200.06
0.79
Median
11.00
63.00
0.03
0.01
0.55
0.48
2.00
53.50
0.24
95%.
180.00
463.00
0.24
0.04
3.60
5.96
17.00
900.00
5.83
NURP SeMte (»f /J}
Mean
12410
82y80
0,04
04$
QJS
urn
0.42
NfiL
J*9£
l&M
" 0*28
Median
&QO
65.00
tf.04
075
MR
0.70
M&
$*30
£00.90
0*59
E-47
-------
Appendix E
Sector 24: Textile Mills, Apparel and other Fabric Product Manufacturing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (xi) facilities under Standard Industrial Classification (SIC) code 22." Storm
water discharges from the following activities are covered: Textile Mill Products, of and
regarding facilities and establishments engaged in the preparation of fiber and subsequent
manufacturing of yarn, thread, braids, twine, and cordage, the manufacturing of broadwoven
fabrics, narrow woven fabrics, knit fabrics, and carpets and rugs from yarn; processes
involved in the dyeing and finishing of fibers, yarn fabrics, and knit apparel; the integrated
manufacturing of knit apparel and other finished articles of yarn; the manufacturing of felt
goods (wool), lace goods, nonwoven fabrics, and miscellaneous textiles.
Pollutants of concern include biochemical oxygen demand (BODS), total suspended solids
(TSS), pH, total chromium, total aluminum, total copper, total lead, total zinc, COD,
phenols, sulfides, oil and grease, and benzene.
Table E-24
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 24
Pollutant
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (mg/l>
No.
Jio
iio
1$
&
no
111
110
105
Vie
no
&
Mean
11.41
69.19
0.03
0.07
1.33
2.94
0.35
6.72
2.72
126.22
0.33
Median
7.75
44.00
0.01
0.02
0.39
0.00
0.14
6.85
1.70
35.50
0.19
95%
38.00
228.00
0.15
0.28
2.50
14.00
0.66
8.60
6.50
410.00
1.06
Composite Samples Crag/I}
No.
107
ffl
14
7
m
107
107
107
14
Mean
9.82
48.05
0.07
0.04
1.14
0.31
1.92
80.04
0.30
Median.
7.00
37.00
0.01
0.03
0.39
0.11
1.50
22.00
0.21
95%
29.00
111.00
0.61
0.11
1.87
0.60
5.40
380.00
0.88
PTORP Results (mg/l)
Mean
12,00
82,00
QM
0.18
GM
NR
0,42
KR
J-90
180*00
0,20
Median
$.00
63.00
0,04
&14
0,68
m
0,33
N&
1,50
iOG
-------
Appendix E
Sector 25: Wood and Metal Furniture and Fixture Manufacturing Facilities
The definition of storm water discharges associated with an industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (xi) facilities classified as Standard Industrial Classification (SIC) codes 2434
and 25." Furniture and fixture manufacturing facilities eligible for coverage include facilities
identified by the following SIC codes:
Wood Kitchen Cabinets (SIC Code 2434)
Household Furniture (SIC Code 251)
Office Furniture (SIC Code 252)
Public Buildings and Related Furniture (SIC Code 253)
Partitions, Shelving, Lockers, and Office and Store Fixtures (SIC Code 254)
Miscellaneous Furniture and Fixtures (SIC Code 259).
The process of manufacturing wood furniture begins with the delivery and storage of wood.
There are three different raw wood materials, lumber, veneer, and particle board. Once
delivered, raw lumber is allowed to air dry up to one year. After the lumber is sufficiently
air dried it is then transported to a dry kiln for further drying. Once the lumber has been
dried to a desired moisture content, the dried lumber is taken to the processing area. The
remaining furniture manufacturing processes are all completed indoors, including cutting,
planing, sanding, finishing, and lathing.
Veneer is another raw material used hi the production of furniture. In this process logs are
placed in a steam vat to increase moisture content. The logs are turned on a lathe to peel off
the veneer. The resulting veneer sheets are layered into stacks or "hacks." Moisture is
removed from the hacks by kiln drying. After a desired moisture content has been achieved
the hacks are disassembled.
Particle board is the third raw material incorporated into the manufacturing of wood
furniture. The board is received, cut to size, and banded on all four edges with solid wood.
The banding is accomplished hi continuous, steam heated units utilizing adhesives. The
panels are allowed to cool and then they are sanded.
The significant materials identified as exposed to storm water at wood furniture and fixture
manufacturing facilities include raw wood, sawdust, coal, kiln ash, solvent-based finishing
materials and waste products, used rags, raw glue and waste materials, and petroleum-based
products.
Metal furniture manufacturing facilities may purchase wood pieces ready for assembly or
they may have all the industrial activities of wood manufacturing facilities in addition to the
metal manufacturing facilities. Facilities that manufacture metal household furniture maintain
all operations including: machining and assembly, finishing, and temporary storage of
finished products within an enclosed building. Cold roll steel is initially received and
temporarily stored within the manufacturing building. However, steel may be stored outside
E-49
-------
Appendix E
prior to use. The steel is cut to size, bent, and welded to design specifications to fabricate
raw metal household furniture. Final grinding, sanding, finishing, spot welding, and painting
are then completed.
The significant materials identified as exposed to storm water at metal furniture and fixture
facilities include metals, sawdust, solvent-based finishing materials and waste products,
electroplating solutions and sludges, used rags, raw glue and waste materials, and petroleum-
based products.
Pollutants at wood and metal furniture manufacturing facilities include TSS, pH, cadmium,
arsenic, COD, BOD5, lead, solvents, oil & grease, diesel fuel, and gasoline.
Table E-25
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 25
Pollutant
BODS
COD
Copper
Lead
N02+N03-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
'.' Grab Samples (rag/I)
No-.
25
" #
4
3
25
25
2$
23
"15
25
4
Mean
12.22
95.96
0.04
0.08
1.73
3.84
0.27
7.54
4.37
187.83
2.97
Median
9.00
83.00
0.04
0.06
0.90
0.00
0.20
7.50
1.70
130.00
0.78
: 95%
44.00
230.00
0.07
0.16
6.20
14.00
0.89
8.90
15.00
440.00
10.00
Composite Samples (iag/1)
Sfo*
24
24
4
3
24
24
24
24
4
: Mean
8.80
76.33
0.00
0.01
1.51
0.26
4.40
142.88
0.59
Median
5.95
72.50
0.00
0.01
0.68
0.19
1.35
90.50
0.40
; 95%
26.00
180.00
0.02
0.02
5.60
0.71
13.00
550.00
1.50
NtflU? faults #Bg/l)
Mean
HLflO
S2.QO
0.04
048
0,86
m
0.42
im
IM
180.00
$M
Median
9.00
65,00
0,04
0.14
0.68
MR
0,33
m
1,50
100.00
6.16
90%
15,00
140.00
0,09
OJ5
L75
WH
0.70
KR
3.30
300.00
0,50
E-50
-------
Appendix E
Sector 26: Printing and Publishing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (xi) facilities classified as Standard Industrial Classification (SIC) Code 27 which
includes facilities primarily engaged in printing and publishing services. The following
facilities are covered under SIC code 27:
• Book Printing (SIC Code 2732): Establishments primarily engaged in printing, or hi
printing and binding, books and pamphlets, but not engaged in publishing.
• Commercial Printing, Lithographic (SIC Code 2752): Establishments primarily
engaged in printing by the lithographic process. Offset printing, photo-offset printing,
and photolithographing are also included in this industry.
• Commercial Printing, Gravure (SIC Code 2754): Establishments primarily engaged
hi gravure printing.
• Commercial Printing, Not Elsewhere Classified (SIC Code 2759): Establishments
primarily engaged hi commercial or job printing. This industry includes general
printing shops, as well as shops specializing hi printing newspapers and periodicals for
others.
• Platemakmg and Related Services (SIC Code 2796): Establishments primarily
engaged hi making plates for printing purposes and hi related services. Also included
are establishments primarily engaged hi making positive or negatives from which
offset lithographic plates are made.
Pollutants of concern include toxic waste ink with solvents chromium, lead, dust, sludge, ink
- sludges with chromium or lead, solvents, photographic processing wastes, fuel, oil, heavy
metals, trash, and petroleum products.
E-51
-------
Appendix £
Table E-26
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 26
J>oliUttftt
BODS
COD
Copper
Lead
NOZ+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
•Grab Sample's (aig/l)
No.
11
27
7
1
20
£?
27
20
2?
17
4
Mean.
10.99
57.19
0.03
0.03
1.27
12.58
0.37
7.07
3.13
91.52
0.48
M&iiaA
9.00
49.00
0.03
0.03
0.82
2.50
0.14
7.03
1.50
30.00
0.37
95*
49.00
176.00
0.08
0.03
4.00
56.00
1.50
8.46
10.00
433.00
1.00
Composite Samples (ffig/t)
J?Q*
27
27
6
0
20
27
27
27
3
Mean
6.95
42.37
0.02
1.35
0.35
1.57
30.83
0.47
Median
6.40
39.00
0.03
1.05
0.13
0.84
28.00
0.52
95*
22.20
119.00
0.04
4.49
1.30
4.60
82.00
0.65
NtJKP itesute (aig/i)
M^u
' nm
S2>W
0,04
0.1$
OJ<$
NR
0,42
m
L9Q
180.00
Q3&
MedlsR
9-QO
65,00
0.04
0.14
0.68
NJR
0,33
NR
1.50
160.00
046
%>%
mm
140.W
0*0^
0.35
L75
J«R
0x70
NK.
3JO
300,00
0+50
E-52
-------
Appendix E
Sector 27: Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing
Industries
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
(xi) facilities classified as Standard Industrial Classification (SIC) major groups 30 and 39."
Storm water discharges from category (xi) facilities are only regulated where precipitation
and storm water runon come into contact with areas associated with industrial activities and
significant materials. Sector 27 covers all storm water discharges from facilities classified as
SIC 30 and 39, except for those facilities classified as SIC code 391 - Jeweler, Silverware,
and Plated ware. Facilities classified as SIC code 391 are subject to Sector 29 permitting
requirements.
Major SIC group 30 includes rubber and miscellaneous plastic products. Specifically, this
SIC group includes manufacturers of tires and inner tubes, rubber and plastic footwear,
rubber and plastic hose and belting, gaskets, packing and sealing devices, and miscellaneous
fabricated rubber products. This SIC group also includes miscellaneous plastic products such
as unsupported plastic film, sheet, rods and tubes, laminated plastic plate, sheet and profile
shapes, plastic pipe and bottles, plastic foam products such as cups, ice chests and packaging
materials, plastic plumbing fixtures, and miscellaneous plastic products.
Major SIC group 39 (except 391) includes miscellaneous manufacturing industries.
Specifically, this group includes manufacturers of musical instruments, games, toys and
athletic goods, pens, pencils and artists' supplies, buttons, and pins and needles.
Pollutants found in storm water discharges from rubber and miscellaneous plastic products
manufacturers may include total suspended solids (TSS), oil and grease, zinc, and acids.
Table E-27
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 27
jPoJtaiant
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Grab Samples (mg/1)
No,
90
90
5
1
&
94
&
86
*fr
90
34
Mean
13.92
100.00
0.00
0.00
0.86
4.26
0.41
7.17
2.34
188.55
0.98
Me3«n
7.15
53.00
0.00
0.00
0.58
0.50
0.19
7.10
1.36
44.00
0.19
9S%
51.00
330.00
0.01
0.00
2.93
18.00
1.61
8.40
6.00
893.00
4.90
Composite Samples (ffig/1)
No.
m
&?
5
1
8$
85
M
87
34
Meaji
11.21
72.08
0.03
0.01
1.26
0.34
1.63
119.32
0.80
Median
7.00
43.00
0.05
0.01
0.67
0.16
1.25
30.00
0.25
9S% ;
34.00
240.00
0.05
0.01
3.56
0.83
4.70
476.00
2.86
MJKP Results (lag/l)
Mem
nm
82s,eo
0.04
0.18
0.8$
NR
Q4Z
m.
i.9&
mm
0,20
Median
9/.00
63.00
0,04
: 0.14
QM
Jffi
0.33
NR
1,50
100,00
0.16
90%
i5,00
140,00:
0.09
0.3S
1*73
NR
0,70
NfR
3.30
300.00
0,50
E-53
-------
Appendix £
Sector 28: Leather Tanning and Finishing Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (ii) facilities classified as Standard Industrial Classification (SIC) code 3111."
Storm water discharges covered include those from leather tanning facilities and facilities
which make fertilizer solely from leather scraps and leather dust where precipitation and
storm water runon come into contact with significant materials including, but not limited to,
raw materials, waste products, by-products, stored materials, and fuels.
Leather tanning or finishing is the conversion of animal hides or skins into leather. Leather
is made from the inner layer of the animal skin, which consists primarily of the protein
collagen. Tanning is the reaction of the collagen fibers with tannins, chromium, alum or
other tanning agents. Tanning processes use sodium dichromate, sulfuric acid and detergents
and a variety of raw and intermediate materials.
There are three major processes required to make finished leather. These are beamhouse
operations, tanyard processes and retanning and finishing processes.
• Beamhouse Operations—These consist of four activities: side and trim; soak and
wash; fleshing and unhairing. Side and trim is the cutting of the hide into two sides
and trimming of areas which do not produce good leather. In soak and wash
processes, the hides are soaked in water to restore moisture lost during curing.
Washing removes dirt, salt, blood, manure, and nonfibrous proteins. Fleshing is a
mechanical operation which removes excess flesh. The removed matter is normally
recovered and sold for conversion to glue. Unhairing involves using calcium
hydroxide, sodium sulfhydrate, and sodium sulflde to destroy the hair (hair pulp
process) or remove hair roots.
• Tanyard Processes—These consist of bating, pickling, tanning, wringing, splitting, and
shaving. Bating involves the addition of salts of ammonium sulfate or ammonium
chloride used to convert the residual alkaline chemicals present from the unhairing
process into soluble compounds which can be washed from the hides or skins.
"Pickling" the hide with sulfuric acid provides the acid environment necessary for
chromium tanning. In the tanning process, tanning agents such as trivalent chromium
and vegetable tannins convert the hide into a stable product which resists
decomposition. Wringing of the "blue hides" (hides tanned with chromium) removes
excess moisture with a machine similar to a clothes wringer. Splitting adjusts the
thickness of the tanned hide to the requirements of the finished product and produces a
"split" from the flesh side of the hide. The hide is then shaved to remove any
remaining fleshy matter.
• Retanning and Wet Finishing Processes—These include retanning, bleaching, coloring,
fatliquoring, and finishing. The most common retanning agents are chromium,
vegetable extracts and syntans (based upon naphthalene and phenol). Sodium
E-54
-------
Appendix E
bicarbonate and sulfuric acid are sometimes used to bleach leather. Coloring involves
the use of dyes (usually aniline based) on the tanned skin. Animal or vegetable
fatliquors are added to replace the natural oils lost in the beamhouse and tanyard
processes. Finishing includes all operations performed on the hide after fatliquoring,
and includes finishing to enhance color and resistance to stains and abrasions,
smoothing and stretching of the skin, drying, conditioning, staking, dry milling,
buffing and plating.
Significant materials include raw materials, brine or salt cured hides and skins, fuels,
materials such as solvents, detergents, finished materials, fertilizers, pesticides, waste
products, leather shavings and dust, leather scrap, blue hides and splits, empty chemical
containers, spent solvents, and emissions from spray booths.
Pollutants include aluminum, manganese, Total Kjeldahl Nitrogen (TKN), nitrate 4- nitrite as
N, and Biochemical Oxygen Demand (BOD5).
Table E-28
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 28
Fetufcsit
BOD5
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
(Srab Samples (tng/1}
JffDv
?t
31
2
31
n
31
31
31
31
Mean
33.07
205.45
0.02
1.86
13.87
0.36
7.21
7.70
309.84
M&imn
11.00
82.00
0.02
1.20
0.00
0.16
7.40
4.30
49.00
95%
140.00
900.00
0.04
4.70
120.00
1.60
8.60
22.00
1300.00
Composite Saitiples (fflg/l>
Ma,
31
31
2
31
31
31
31
.Mean,
22.32
91.94
0.02
1.88
0.83
6.22
114.81
Metfka
10.00
50.00
0.02
0.90
0.18
3.50
86.00
9S%
77.00
340.00
0.04
9.10
1.30
15.00
460.00
NOSt Resulfe (iftgifl.)
Mean
I2.M
82.00
0.04
0,13
0.86
MR
0.42
NR
L90
. 180JO
0.20
MstOSfo,
9,00
65,00
0.04
0.14
Q.m
NX
0,33
MR
1.50
100.00
9>Ifi
90%
15,00
140.00
0,09
OJS
1.73
im
0.70
NR
3.30
300J&
0,50
E-55
-------
Appendix E
Sector 29: Fabricated Metal Products Facilities
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including:
"...category (xi) facilities classified as Standard Industrial Classification (SIC) codes 34 and
391." Storm water discharges from fabricated metal and processing facilities eligible for
coverage include the following types of operations:
• Fabricated Metal Products, Except Machinery and Transportation Equipment, SIC
code 34 (3429, 3441, 3442, 3443, 3444, 3451, 3452, 3462, 3465, 3471, 3479, 3494,
3496, 3499)
• Jewelry, Silverware, and Plated Ware, SIC code 391.
This section covers establishments engaged in fabricating ferrous and nonferrous metal
products, such as metal cans, tinware, general hardware, automotive parts, tanks, road mesh,
structural metal products, nonelectrical equipment, and a variety of metal and wire products
made from purchased iron or steel rods, bars, or wire materials.
These facilities are engaged hi the manufacturing of a variety of products that are constructed
primarily by using metals. The operations performed usually begin with materials hi the
form of raw rods, bars, sheet, castings, forgings, and other related materials and can
progress to the most sophisticated surface finishing operations. There are typically several
operations that take place at a fabrication facility: machining operations, grinding, cleaning
and stripping, surface treatment and plating, painting, and assembly. The machining
operation involves turning, drilling, milling, reaming threading, broaching, grinding,
polishing, cutting and shaping, and planing. Grinding is the process using abrasive grams
such as aluminum oxide, silicon carbide, and diamond to remove stock from a workpiece.
Cleaning and stripping is a preparatory process involving solvents for the removal of oil,
grease and dirt. Both alkaline and acid cleaning are employed. Surface treatment and
plating is a major component that involves batch operations to increase corrosion or abrasion
resistance. This is generally hi the form of galvanizing. Painting is generally practiced at
most facilities to provide decoration and protection to the product. Assembly is the fitting
together of previously manufactured parts into a complete unit or structure.
Areas with significant materials include those with waste storage, outside product storage,
used for pickling acids, storage of cutoff scrap metal, aluminum scraps, hazardous materials,
galvanized steel components, solvent storage, waste paper storage, and machinery storage.
Pollutants at these facilities include aluminum, copper, manganese, nitrate + nitrite as N,
iron, and zinc.
E-56
-------
Appendix E
Table E-29
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 29
Pollutant
BODS
COD
Copper
Lead
N02+N03-N
Oil & Grease
P, Total
PH
TKN
TSS
Zinc
Graft Samples (rag/1)
No,
115
115
36
32
115
114
113
103
115
115
60
Mean.
28.31
118.16
0.63
0.11
1.48
6.11
1.03
7.06
2.61
186.58
4.20
Mtt&ttX
7.60
56.00
0.03
0.00
0.74
2.00
0.22
7.05
1.37
76.00
0.36
95%
81.00
440.00
4.30
0.89
7.00
21.00
9.80
8.70
7.20
758.00
9.77
Composite Samples Cmg/l}
No,
111
114
33.
30
114
114
114
114
58
Mean.
10.04
86.17
0.46
0.06
1.27
0.84
1.78
125.39
2.17
MscBaa
7.00
47.50
0.02
0.00
0.77
0.21
1.20
32.00
0.21
95%
40.00
249.00
0.64
0.22
3.50
4.80
5.75
423.00
10.50
KTJRPItes«fe(
Mean
12,00
82,00
0.04
0,18
0.8S
KR
0,42
MR
1,90
180.00
0,20
Median
$.00
6S.OO
0,04
O.I4
0,68
NR
0.33
MR
1,50
100,00
0.16
90%
15,00
140,00
0.09
0,35
1.75
NR
OJQ
m
3,30
300.00
0,50
E-57
-------
Appendix E
Sector 30: Transportation Equipment, Industrial or Commercial Machinery
Manufacturing Facilities
The definition of storm water discharge associated with industrial activity includes point
source discharges of storm water from eleven categories of facilities, including: ".. .category
(xi) facilities classified as Standard Industrial Classification (SIC) codes ... 34 (except 3441),
35, 37 (except 373),..." Under these SIC codes, the facilities subject to storm water
regulations include:
Fabricated Structural Metal Products, (SIC Code 344)
Metal Forgings and Stampings, (SIC Code 346)
Miscellaneous Fabricated Metal Products (SIC Code 349)
Engines and Turbines (SIC Code 351)
Farm and Garden Machinery and Equipment (SIC Code 352)
Construction, Mining, and Materials Handling Machinery and Equipment (SIC Code
353)
Metalworking Machinery and Equipment (SIC Code 354)
Special Industry Machinery, Except Metalworking Machinery (SIC Code 355)
General Industrial Machinery and Equipment (SIC Code 356)
Refrigeration and Service Industry Machinery (SIC Code 358)
Miscellaneous Industrial and Commercial Machinery and Equipment (SIC Code 359)
Motor Vehicles and Motor Vehicle Equipment (SIC Code 371)
Aircraft and Parts (SIC Code 372)
Motorcycles, Bicycles, and Parts (SIC Code 375)
Guided Missiles and Space Vehicles and Parts (SIC Code 376)
Miscellaneous Transportation Equipment (SIC Code 379)
The general manufacturing process is conducted indoors, and includes activities such as
cutting, shaping, grinding, cleaning, coating, forming, and finishing. Specific processes are
referred to as "unit operations." These operations occur predominately indoors, so
contamination of storm water discharges from manufacturing processes is unlikely.
Significant materials include ferrous and nonferrous metals, such as aluminum, copper, iron,
steel and alloys of these metals; either in raw form or as intermediate products, paints,
solvents (e.g., paint thinners, degreasers), chemicals (e.g., acids, bases, liquid gases), fuels
(e.g., gasoline and diesel fuel), lubricating and cutting oils, and plastics.
Pollutants of concern at these facilities include total suspended solids (TSS), turbidity,
fugitive dust, oil and grease, organics, heavy metals, and chemical oxygen demand (COD).
E-58
-------
Appendix E
Table E-30
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 30
J^lftflaot;
BODS
COD
Copper
Lead
NO2+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
Grab Samp fes (mg/l>
No<
J82
174
79
7$
184
, J8&
ra
17$
170
> 173
88
Mean
13.01
66.89
0.20
0.22
1.20
7.84
0.29
6.93
2.47
162.81
0.58
Median
6.00
36.00
0.01
0.00
0.58
0.00
0.14
7.09
1.30
30.00
0.20
95%
32.00
310.00
0.84
0.97
5.00
34.00
1.00
8.34
5.80
576.00
2.55
Composite Samples (tag/1)
No,
m
16£
74
75
174
m
$•65
16?
85
Mean
7.34
46.55
0.06
0.18
1.28
0.40
1.81
100.41
0.39
Median
5.00
29.00
0.01
0.00
0.45
0.13
1.10
17.00
0.14
«SL
19.00
149.20
0.36
0.94
4.50
1.12
4.75
319.00
1.40
TSTOKF
.Mm..
12M
&LOO
0.0*
048
QM
MR
0,42
m
Iv90
moo
G.20
.Results <
Median
£.00
6$ .GO
0,04
! &I4
0<68
JiJH
fc.33
N&
1,50
I00<00
o.is
H«/l>
90%
15,00
140,00
049
0,35
1*73
NR
0,70
KBfe
3.30
300.00
0.50
E-59
-------
Appendix E
Sector 31: Electronic and Electrical Equipment and Components, Photographic and
Optical Goods
The definition of storm water discharges associated with industrial activity includes point
source discharges of storm water from eleven major categories of facilities, including: "...
category (xi) facilities classified as Standard Industrial Classification (SIC) codes 36, 38, and
357."
Major SIC group 36 includes manufacturers of a broad range of electronic and electrical
equipment and components, not including computer equipment. Specifically, this group
includes manufacturers of electricity distribution equipment such as transformers and switch-
gear, electrical industrial equipment such as motors and generators, household appliances,
electric lighting and wiring equipment such as light bulbs and lighting fixtures, and audio and
video equipment including phonograph records and audio tapes and disks. Also included are
manufacturers of communication equipment including telephone and telegraph equipment,
radio and television equipment, electronic components such as printed circuit boards and
semiconductors and related devices, and miscellaneous electrical items such as batteries and
electrical equipment for automobiles. Storm water discharges from facilities in this category
are only regulated where precipitation and storm water runon come into contact with areas
associated with industrial activities and significant materials.
Major SIC group 38 includes manufacturers of measuring, analyzing, and controlling
instruments, photographic, medical and optical goods, and watches and clocks. Specifically,
this group includes facilities which manufacture search, detection, navigation, or guidance
systems such as radar and sonar equipment, measurement and control instruments and
laboratory apparatus, surgical, medical and dental instruments and supplies, photographic
equipment and supplies, and watches and clocks.
Computer and office equipment is included in industrial SIC group 357. This group includes
manufacturers of computers, computer storage devices, and peripheral equipment for
computers such as printers and plotters. Manufacturers of miscellaneous office machines are
also included in this group.
Pollutants found in storm water discharges from Electronic and Electrical Equipment and
Components, Photographic and Optical Goods manufacturers may include total suspended
solids (TSS), heavy metals, organics, oil and grease, and acids.
E-60
-------
Appendix E
Table E-31
Summary Statistics From (Part 2) Sampling Results by Industrial Sector
Industrial Sector 31
•£
PoMafent
BODS
COD
Copper
Lead
NOZ+NO3-N
Oil & Grease
P, Total
pH
TKN
TSS
Zinc
<3rab Samples (mgfl)
No,
64
65.
54
6$
64
m
64
m
61
m
si
Meaa.
8.81
59.19
0.04
0.02
0.83
0.58
1.50
7.43
1.46
89.21
0.16
MecBaa
5.50
46.00
0.00
0.00
0.51
0.00
0.13
7.54
1.05
29.00
0.09
95%
32.00
170.00
0.11
0.08
2.80
4.10
1.10
8.60
4.09
348.00
0.53
Composite Samples 5agfl>
No<
56
SS
50
m
Iff
57
n
m
48
Mean.
7.48
36.32
0.01
0.01
0.66
1.02
1.36
67.12
0.15
Median
5.10
24.00
0.00
0.00
0.51
0.16
1.01
14.00
0.09
95%
14.00
200.00
0.05
0.04
1.43
1.20
3.70
370.00
0.47
STOEPJtesuUsCmg/l)
Mean
nm
&M
I4
&68
\ m
1 0.33
NR
1.50
100,00.
0.16
W%
iSM
140.M
Qm
D,35
1*75
KB.
O.W
J^R
J.30
300*4)0
0.50
E-61
-------
-------
APPENDIX F
GROUP APPLICATION PART 2 SAMPLING DATA
ORGANIZED BY POLLUTANT
-------
-------
APPENDIX F
GROUP APPLICATION PART 2 SAMPLING DATA
ORGANIZED BY POLLUTANT
This appendix contains tabular and graphical descriptions of the sampling data for the
31 industrial sectors that were identified in the group application portion of the Phase I
permitting process (four of the sectors were consolidated into two sectors for permit
development purposes, only tablular data is presented for copper, lead, and zinc). This
appendix summarizes the sampling data on a pollutant by pollutant basis. The tables and
figures display the mean values, median values, 95th percentile values, for the grab and
composite samples and the mean, median and 90th percentile values for NURP data for a
portion of the pollutants sampled within each sector.
-------
-------
Appendix F
SECTOR
i
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
22
23
24
25
26
27
28
29
30
31
INDUSTRIAL SECTORS/GROUP APPLICATIONS (TABLE 1)
ACTIVITIES REPBHSBNTED
Lumber and Wood Products
Paper and Allied Products
Chemicals and Allied Products
Asphalt and Lubricant Manufacturers
Stone, Clay, Glass and Concrete Products
Primary Metal Industries
Metal Mining
Coal and Lignite Mining
Oil and Gas Extraction
Mining and Quarrying of Nonmetallic Minerals
Hazardous Waste Treatment Storage or Disposal Facilities
Industrial Landfills, Land Application Sites and Open Dumps
Used Motor Vehicle Parts
Scrap and Waste Materials
Steam Electric Power Generating Facilities
Railroad Transportation
Local and Suburban Transit and Interurban Highway Passenger Transportation
Motor Freight Transportation
United States Postal Service
Petroleum Bulk Stations
Water Transportation
Ship Building and Repairing
Boat Building and Repairing
Transportation By Air
Domestic Wastewater Treatment Plants
Food and Kindred Products
Tobacco Products
Textile Mill Products
Apparel and Other Finished Products Made From Fabrics and Similar Materials
Furniture and Fixtures Manufacturing
Printing Publishing and Allied Industries
Rubber and Misc. Plastic Products
Leather and Leather Products
Fabricated Metal Products, Except Machinery and Transportation Equipment
Jewelry, Silverware, and Plated Ware
Industrial and Commercial Machinery (Except Computer and Office Equipment)
Transportation Equipment
Electronic and other Electrical Equipment and Components
Measuring, Analyzing, and Controlling Instruments; Photographic and Optical Goods;
Watches and Clocks
F-l
-------
Appendix F
Table F-l
Summary of Sampling Data From Phase I Part II Permit Applications
(With Comparison to NURP and USGS Data) for BOD5 (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Products
03 Chemicals & Allied Products
04 Petrol Refining & Related Ihd.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
1 1 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Lid. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
BODS
198
121
165
61
310
163
18
7
35
55
8
51
13
130
76
116
400
15
44
96
90
298
110
25
27
90
31
115
182
64
39.63
34.72
36.42
39.99
14.30
32.15
10.02
3.63
13.79
7.09
17.75
13.66
7.15
23.49
5.71
11.29
17.11
8.60
5.00
23.95
33.26
51.15
11.41
12.22
10.99
13.92
33.07
28.31
13.01
8.81
13.00
8.00
7.00
7.00
5.00
11.00
9.00
1.80
9.71
5.00
11.50
7.00
6.00
9.00
4.25
6.00
8.00
7.00
2.80
7.50
11.50
13.90
7.75
9.00
9.00
7.15
11.00
7.60
6.00
5.50
193.00
115.00
67.00
47.00
32.00
83.00
27.00
9.00
44.00
24.00
45.00
59.00
16.00
89.00
20.00
34.00
60.50
39.00
15.00
42.00
53.40
206.00
38.00
44.00
49.00
51.00
140.00
81.00
32.00
32.00
Composite Samples
No.
Mean
Median
BODS
200
111
156
51
300
140
12
4
33
51
9
48
30
120
78
105
376
14
37
89
89
287
107
24
27
89
31
111
179
56
12
16
45.37
24.25
11.74
10.87
7.32
34.08
10.63
6.55
10.59
6.89
9.44
9.04
12.61
24.00
5.69
9.27
11.07
6.00
7.40
21.34
46.11
42.54
9.82
8.80
6.95
11.21
22.32
10.04
7.32
7.48
9
8
17.00
8.00
6.00
4.00
4.20
8.30
6.00
3.90
7.00
5.00
7.00
4.40
6.50
9.00
4.00
6.00
6.00
6.00
0.90
5.30
8.00
11.00
7.00
5.95
6.40
7.00
10.00
7.00
5.00
5.10
95 %
15
NR
135.50
93.00
45.00
22.00
26.00
61.50
44.00
17.40
21.80
17.00
45.00
34.00
48.00
88.00
20.00
28.00
41.00
11.00
23.00
41.40
200.00
180.00
29.00
26.00
22.20
34.00
77.00
40.00
19.00
14.00
*NURP and USGS results were reported only as composite samples, not grab.
NR - Not Reported
F-2
-------
Appendix F
o
« 3
cd ^^3
Q) O
*- ^ *
b h •O
c — 2
«
• es e»
t
2
F-3
-------
Appendix F
R
O
•M
O
a>
00
I §
•§ B
» >>
i e
•a o
at
E
p
o
^
•M G O •
O9 O ** O
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TS a & ^
•ri « **
3 |||
O< '"** *O
M «< 1^1
«S •" "
s s ^
a «S *;
o •"• 2
a ^ I
&
** e
F-4
-------
Appendix F
& s
* g
£33
t-l
o
M
e
P
(. O
I *
g s.
•a
L, *« o S
w *•» =•
*-> e o *
wa
-------
Appendix F
a
at
ON
Ok
"M I
o
o
CO
CO
I
eo
E
p
o
B 2
2
•a
co«
O g o
S M fc«
2 £ S
IB*
a| *O S
Co
& " •§
S ° 5
00 « Z
«" ~
MOW
e « O
Sag
: 21
CO M i"^
jj 8 ^
« «a >
en
S
&
03
-21
«£
.8*
*25
d &
U aj
fiT"^
o I
^a
F-6
-------
Appendix F
Table F-2
Summary of Sampling Data From Phase I Part H Permit Applications (With
Comparison to ISfURP and USGS Studies) for COD (mg/1)
1 1
Sector DESCRIPTION ||
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
Grab Samples
No.
Mean
Median
COD
198
121
03 Chemicals & Allied Products 168
04 Petrol Refining & Related Ind. 64
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
1 1 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
119 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
313
162
18
13
36
56
8
51
30
130
76
117
408
15
51
95
84
296
110
25
27
90
3
11
17
II 31 Electronic Equip. & Instruments || 6
297.64
191.69
96.14
151.55
107.47
221.34
144.54
16.45
140.12
58.79
117.40
114.46
135.00
253.33
104.02
318.10
135.16
130.93
73.22
81.49
133.03
192.46
69.19
95.96
57.19
100.00
205.45
118.1
66.8
59.1
=^=i^^=
131.00
61.00
57.50
48.00
51.30
70.50
71.10
6.00
82.00
33.00
41.00
31.00
61.00
120.00
32.50
118.00
63.95
93.00
53.00
44.00
68.65
77.00
44.00
83.00
49.00
53.00
82.00
56.0
36.0
46.0
—
95 %
Composite Samples ||
No.
Mean
Median
95 %
COD
1500.00 198
740.00 113
290.00
485.00
317.00
870.00
630.00
83.90
352.00
247.00
159
53
302
151
15
8
31
51
500.00 9
825.00 1 48
250.00
1100.00
360.00
781.00
498.00
500.00
260.00
286.00
410.00
745.00
228.00
230.00
176.00
330.00
900.00
440.00
310.00
170.00
===^
13
117
77
102
374
14
43
88
84
286
107
24
27
87
3
114
16
5
82
NR
242.50
133.90
77.24
86.93
77.53
109.84
195.07
26.86
115.94
66.20
48.90
102.02
66.23
203.71
69.47
189.46
85.64
75.79
68.80
75.63
157.95
141.65
48.05
76.33
42.37
72.08
91.94
86.17
46.5
36.3
65
NR
122.50
51.00
41.00
50.00
43.15
60.00
160.00
13.50
92.00
37.00
34.00
27.50
60.00
110.00
39.50
89.00
48.00
50.50
28.00
36.00
61.59
63.00
37.00
72.50
39.00
43.00
50.00
47.50
29.0
24.0
140
NR
1080.00
530.00
320.00
375.00
240.00
420.00
740.00
115.00
445.00
185.00
131.00
548.00
155.00
700.00
280.00
489.00
250.00
203.00
240.00
182.00
880.00
463.00
111.00
180.00
119.00
240.00
340.00
249.00
149.20
200.00 1
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-7
-------
Appendix F
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Appendix F
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Appendix F
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F-ll
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Appendix F
Table F-3
Summary of Sampling Data From Phase I Part H Permit Applications (With
Comparison to NURP and USGS Data) for NO2 + NO3 - N (mg/I)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
No.
Grab Samples
Mean
Median
95 %
NOz+NOj-N
189
121
164
62
303
148
16
8
35
50
9
50
13
129
76
118
399
15
51
75
84
301
110
25
20
89
31
115
184
64
0.95
0.95
5.83
0.97
1.99
1.17
1.10
0.77
0.52
0.98
0.46
1.57
1.70
1.78
5.62
1.59
2.99
4.23
0.79
1.27
20.86
1.17
1.33
1.73
1.27
0.86
1.86
1.48
1.20
0.83
0.32
0.50
0.80
0.31
0.60
0.68
0.75
0.40
0.15
0.65
0.47
0.55
0.83
0.62
0.36
0.92
0.61
0.60
0.72
0.41
1.09
0.56
0.39
0.90
0.82
0.58
1.20
. 0.74
0.58
0.51
2.20
3.93
16.00
2.63
3.03
3.60
5.30
3.12
4.10
3.00
0.79
4.10
5.65
3.30
3.70
6.07
9.00
54.00
1.60
7.90
136.00
3.70
2.50
6.20
4.00
2.93
4.70
7.00
5.00
2.80
Composite Samples
No.
Mean
Median
95 %
NO2+NO3-N
188
111
154
52
292
135
13
6
31
45
9
47
30
117
77
102
372
14
45
65
83
289
107
24
20
86
31
114
174
57
0.86
0.38
0.75
0.76
4.29
0.82
1.40
1.38
0.90
1.00
0.60
1.27
0.39
1.38
1.62
5.88
0.75
1.41
1.99
0.66
0.85
1.29
20.50
0.98
1.14
1.51
1.35
1.26
1.88
1.27
1.28
0.66
0.68
0.25
0.34
0.47
0.82
0.30
0.55
0.77
0.86
0.61
0.12
0.76
0.34
0.50
1.32
0.80
0.45
0.78
0.52
0.65
0.72
0.43
0.87
0.55
0.39
0.68
1.05
0.67
0.90
0.77
0.45
0.51
1.75
NR
1.79
2.44
17.00
2.43
3.03
4.30
2.10
3.12
3.30
4.17
0.67
6.02
4.87
12.00
3.20
4.26
5.10
1.61
1.80
7.70
131.27
3.60
1.87
5.60
4.49
3.56
9.10
3.50
4.50
1.43
*NURP and USGS results were reported only as composite samples, not grab.
NR - Not Reported
F-12
-------
Appendix F
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Appendix F
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F-16
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Appendix F
Table F-4
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Studies) for TKN (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
TKN
188
121
171
63
304
160
15
9
36
55
9
51
13
127
76
118
405
15
51
95
79
300
110
25
27
89
31
115
170
62
2.57
3.83
15.50
2.13
3.82
3.56
3.27
2.56
1.39
1.81
1.43
3.36
2.17
3.44
2.41
3.75
2.69
2.64
1.19
19.79
8.10
4.95
2.72
4.37
3.13
2.34
7.70
2.61
2.47
1.46
1.62
1.76
1.90
1.13
1.16
1.98
2.60
2.60
0.76
1.05
1.30
1.10
1.90
2.05
1.25
1.50
1.40
1.60
1.00
1.58
1.52
2.35
1.70
1.70
1.50
1.36
4.30
1.37
1.30
1.05
9.26
10.20
27.00
7.16
7.00
13.00
9.40
5.20
5.20
8.00
3.00
12.00
4.87
11.10
8.55
13.40
7.70
16.00
2.40
27.00
18.00
18.00
6.50
15.00
10.00
6.00
22.00
7.20
5.80
4.09
Composite Samples
No.
Mean
Median
95 %
TKN
188
112
159
51
292
149
13
8
30
50
9
48
30
114
78
102
373
14
43
88
78
290
107
24
27
86
31
114
165
56
1.90
NR
2.32
3.17
18.30
1.63
2.37
3.05
3.39
2.65
1.69
2.41
1.07
3.03
2.27
3.38
1.95
2.48
2.04
9.41
2.20
16.00
4.74
4.07
1.92
4.40
1.57
1.63
6.22
1.78
1.81
1.36
1.50
NR
1.50
1.77
1.70
0.99
1.00
1.60
3.20
1.46
0.93
0.84
0.92
1.04
1.77
2.20
1.00
1.40
1.13
0.75
6.97
1.40
1.33
2.00
1.50
1.35
0.84
1.25
3.50
1.20
1.10
1.01
3.30
NR
7.50
10.10
23.70
6.28
5.00
9.70
11.80
7.40
5.67
6.89
3.92
14.20
6.63
9.20
10.00
8.80
6.30
118.00
3.90
18.80
11.00
17.00
5.40
13.00
4.60
4.70
15.00
5.75
4.75
3.70
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-17
-------
Appendix F
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F-18
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Appendix F
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Appendix F
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Appendix F
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F-21
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Appendix F
Table F-5
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Data) for Oil and Grease (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related tod.
05 Stone, Clay, Glass Products
06 Primary Metal tod.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials'
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 tod. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
Oil & Grease
207
122
169
64
315
163
16
19
36
60
9
53
30
135
88
118
418
15
52
98
89
300
111
25
27
94
31
114
189
69
15.21
3.69
3.75
5.89
4.67
8.88
2.36
2.17
10.18
1.08
9.33
2.97
5.35
8.95
1.38
9.56
16.38
11.93
0.98
4.66
24.24
5.35
2.94
3.84
12.58
4.26
13.87
6.11
7.84
0.58
2.20
1.00
0.50
1.25
1.40
1.00
0.00
1.20
3.00
0.00
0.00
0.00
3.00
5.00
0.00
0.00
2.80
2.00
0.00
1.85
0.90
1.05
0.00
0.00
2.50
0.50
0.00
2.00
0.00
0.00
55.00
15.00
16.30
28.00
17.10
47.00
22.00
13.90
49.00
5.45
74.00
14.00
32.00
32.00
6.00
27.00
41.00
96.00
5.00
20.00
26.00
20.95
14.00
14.00
56.00
18.00
120.00
21.00
34.00
4.10
Composite Samples
No.
Mean
Median
95 %
Oil & Grease
NR
NR
NR
NR
NR
NR
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-22
-------
Appendix F
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Appendix F
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F-24
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Appendix F
Table F-6
Summary of Sampling Data From Phase I Part H Permit Applications (With
Comparison to NURP and USGS Data) for Total Phosphorus (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Lid.
05 Stone, Clay, Glass Products
06 Primary Metal Lid.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Lid. & Comm. & Transport Equip
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
P, Total _
198
120
170
63
313
163
21
8
36
55
9
50
13
127
75
118
405
15
51
86
86
298
110
25
27
89
31
113
176
64
23.91
0.39
2.82
0.37
1.21
1.25
1.83
0.12
15.82
0.84
0.24
0.91
0.19
0.81
0.79
1.47
1.12
0.27
0.21
0.44
0.95
5.13
0.35
0.27
0.37
0.41
0.36
1.03
0.29
1.50
0.29
0.18
0.24
0.13
0.28
0.17
0.30
0.04
0.18
0.20
0.07
0.50
0.05
0.30
0.29
0.54
0.33
0.10
0.00
0.20
0.50
0.56
0.14
0.20
0.14
0.19
0.16
0.22
0.14
0.13
2.66
1.06
12.10
1.65
4.96
1.80
11.00
0.66
144.90
4.69
1.60
3.35
1.08
2.20
3.09
8.10
3.90
1.20
0.91
1.84
3.17
9.06
0.66
0.89
1.50
1.61
1.60
9.80
1.00
1.10
Composite Samples
No.
Mean
Median
95 %
P, Total
199
111
158
54
300
149
16
5
33
51
9
47
30
114
78
102
373
14
45
79
84
287
107
24
27
85
31
114
179
57
0.42
0.31
6.29
0.36
9.51
0.28
0.87
0.52
1.06
0.12
3.41
1.13
0.11
0.95
3.05
0.77
0.63
0.92
0.73
0.15
0.88
0.29
0.68
1.32
0.31
0.26
0.35
0.34
0.83
0.84
0.40
1.02
0.33
0.18
0.30
0.16
0.23
0.15
0.25
0.14
0.38
0.00
0.07
0.24
0.09
0.38
0.26
0.29
0.27
0.45
0.29
0.17
0.00
0.20
0.45
0.48
0.11
0.19
0.13
0.16
0.18
0.21
0.13
0.16
0.70
NR
1.72
0.91
16.40
1.28
3.24
0.96
7.00
0.58
19.46
2.61
0.32
4.08
15.70
1.80
3.10
3.05
2.91
0.32
0.76
0.88
1.89
5.96
0.60
0.71
1.30
0.83
1.30
4.80
1.12
1.20
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-25
-------
Appendix F
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Appendix F
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Appendix F
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F-29
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Appendix F
Table F-7
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Studies) for TSS (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
3 1 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
TSS
198
121
169
63
311
162
17
10
37
55
8
51
13
130
76
118
406
15
51
96
90
.298
110
25
27
90
31
115
173
63
1108
153
200
287
1067
368
6996
5608
353
1848
338
2979
474
437
516
517
503
634
92
185
160
252
126
188
92
189
310
187
163
89
242
41
40
93
200
72
403
150
75
181
128
633
183
148
44
172
104
135
17
29
68
73
36
130
30
44
49
76
30
29
4800
520
793
1330
2620
1700
100000
33420
1520
11120
1100
19370
2300
2096
1200
2800
1890
4330
505
1080
575
1320
410
440
433
893
1300
758
576
348
Composite Samples
No.
Mean
Median
95 %
TSS
198
111
159
54
302
149
15
8
30
51
9
47
30
116
77
102
375
14
45
87
88
286
107
24
27
87
31
114
169
56
180
248
575
44
94
165
386
162
623
690
413
1576
83
1850
839
376
212
249
454
224
2
80
114
' 200
80
143
31
119
115
125
100
67
100
109
230
13
25
46
149
69
330
251
48
296
32
370
226
85
40
90
67
68
8
22
56
54
22
91
28
30
86
32
17
14
300
NR
2288
198
453
860
1440
717
3050
3880
2056
10080
304
9140
5100
1700
810
917
1100
944
200
258
414
900
380
550
82
476
460
423
319
370
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-30
-------
Appendix F
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Appendix F
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F-34
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Appendix F
Table F-8
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Studies) for Copper (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
Copper
32
2
51
6
143
19
1
6
102
70
19
5
2
28
17
16
4
7
5
36
79
54
0.05
0.03
0.19
0.13
3.46
3.88
0.00
0.05
0.77
0.08
0.02
0.16
0.03
0.07
0.08
0.03
0.04
0.03
0.00
0.63
0.20
0.04
0.03
0.03
0.01
0.02
0.10
0.14
0.00
0.01
0.26
0.00
0.01
0.15
0.03
0.01
0.04
0.01
0.04
0.03
0.00
0.03
0.01
0.00
0.16
0.05
0.21
0.40
3.40
46.80
0.00
0.15
3.00
0.21
0.06
0.32
0.04
0.22
0.27
0.15
0.07
0.08
0.01
4.30
0.84
0.11
Composite Samples
No.
Mean
Median
95 %
Copper
29
2
46
5
131
13
2
4
95
75
20
5
3
27
17
14
4
6
5
33
74
50
0.04
0.03
0.04
0.03
0.12
0.16
2.25
0.59
0.00
0.01
0.63
0.03
0.02
0.08
0.01
0.05
0.05
0.07
0.00
0.02
0.03
0.46
0.06
0.01
0.04
0.02
0.03
0.03
0.00
0.04
0.07
0.09
0.00
0.01
0.22
0.02
0.01
0.09
0.01
0.02
0.03
0.01
0.00
0.03
0.05
0.02
0.01
0.00
0.09
NR
0.12
0.07
0.19
0.40
3.10
3.40
0.00
0.01
2.50
0.13
0.08
0.13
0.02
0.11
0.24
0.61
0.02
0.04
0.05
0.64
0.36
0.05
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-35
-------
Appendix F
Table F-9
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Studies) for Lead (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Lid.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
Lead
2
47
15
136
23
2
6
9
103
28
32
4
6
2
27
12
8
3
1
1
2
32
76
60
0.05
0.07
0.24
0.78
0.89
0.02
0.00
9.62
0.85
0.02
0.03
0.20
0.75
0.02
0.03
0.01
0.07
0.08
0.03
0.00
0.02
0.11
0.22
0.02
0.05
0.01
0.01
0.02
0.00
0.02
0.00
0.08
0.21
0.00
0.01
0.05
0.04
0.02
0.00
0.01
0.02
0.06
0.03
0.00
0.02
0.00
0.00
0.00
0.09
0.17
3.30
1.41
1.20
0.04
0.00
83.70
4.00
0.08
0.11
0.70
4.24
0.03
0.15
0.03
0.28
0.16
0.03
0.00
0.04
0.89
0.97
0.08
Composite Samples
No.
Mean
Median
95 %
Lead
2
42
15
123
13
2
4
7
96
23
31
3
5
3
26
10
7
3
0
1
2
30
75
56
0.18
0.22
0.03
0.02
0.25
0.19
6.07
0.00
0.00
20.64
0.88
0.02
0.01
0.10
11.00
0.00
0.01
0.01
0.04
0.01
0.01
0.02
0.06
0.18
0.01
0.14
0.07
0.03
0.01
0.01
0.02
0.05
0.00
0.00
0.18
0.22
0.01
0.00
0.10
0.06
0.00
0.00
0.01
0.03
0.01
0.01
0.02
0.00
0.00
0.00
0.35
NR
0.05
0.07
3.40
1.00
65.00
0.00
0.00
143.00
3.40
0.07
0.06
0.10
0.33
0.00
0.09
0.04
0.11
0.02
0.01
0.04
0.22
0.94
0.04
*NURP and USGS results were reported only as composite samples, not grab.
NR - Not Reported
F-36
-------
Appendix F
Table F-10
Summary of Sampling Data From Phase I Part II Permit Applications (With
Comparison to NURP and USGS Studies) for Zinc (mg/1)
Sector DESCRIPTION
FOR POLLUTANT
NURP Median Urban Site *
USGS Commercial Site *
01 Lumber & Wood Products
02 Paper & Allied Prod.
03 Chemicals & Allied Products
04 Petrol Refining & Related Ind.
05 Stone, Clay, Glass Products
06 Primary Metal Ind.
07 Metal Mining
08 Coal & Lignite Mining
09 Oil & Gas Extraction
10 Nonmetallic Mineral Mining
11 Hazardous Waste TSDFs
12 Industrial Landfills & Dumps
13 Used Motor Vehicle Parts
14 Scrap & Waste Materials
15 Steam Electric Power Plants
16 Railroad Transport
17 Transport: Trucks, Freight, etc.
18 Water Transport
19 Ship & Boat Building, Repair
20 Air Transport
22 Wastewater Treatment
23 Food, Tobacco Manufact.
24 Textile & Apparel Manufact.
25 Furniture & Fixtures
26 Printing & Publishing
27 Rubber & Plastic Products
28 Leather/Products
29 Fabricated Metal Products, Jewelry
30 Ind. & Comm. & Transport Equip.
31 Electronic Equip. & Instruments
Grab Samples
No.
Mean
Median
95 %
Zinc
16
1
75
8
144
14
2
5
97
35
1
30
4
2
8
23
33
16
4
4
34
60
88
51
0.47
0.62
2.11
0.35
8.85
3.04
0.17
0.18
3.16
0.32
0.14
0.23
0.68
0.31
0.14
0.23
0.78
0.33
2.97
0.48
0.98
4.20
0.58
0.16
0.37
0.62
0.24
0.14
0.46
0.59
0.17
0.18
1.40
0.05
0.14
0.13
0.22
0.31
0.08
0.06
0.21
0.19
0.78
0.37
0.19
0.36
0.20
0.09
1.70
0.62
7.70
1.17
11.80
16.30
0.30
0.34
12.00
0.66
0.14
1.10
2.20
0.36
0.58
0.75
2.10
1.06
10.00
1.00
4.90
9.77
2.55
0.53
Composite Samples
No.
Mean
Median
95 %
Zinc
15
1
70
7
132
8
2
3
90
39
1
28
3
1
3
22
31
14
4
3
34
58
85
48
0.20
0.31
0.36
0.78
1.74
0.39
6.55
3.87
0.06
0.29
3.20
0.27
0.28
1.34
0.42
39.00
0.35
0.12
0.79
0.30
0.59
0.47
0.80
2.17
0.39
0.15
0.16
0.11
0.30
0.78
0.24
0.18
0.43
0.66
0.06
0.30
1.40
0.06
0.28
0.11
0.21
0.33
0.04
0.06
0.24
0.21
0.40
0.52
0.25
0.21
0.14
0.09
0.50
NR
1.20
0.78
4.20
1.12
9.67
20.90
0.09
0.30
10.00
0.92
0.28
0.66
0.87
0.33
1.00
0.43
5.83
0.88
1.50
0.65
2.86
10.50
1.40
0.47
*NURP and USGS results were reported only as composite samples, not grab.
NR = Not Reported
F-37
-------
-------
APPENDIX G
GEOGRAPHIC ANALYSIS OF SIC CODES
-------
-------
Appendix G
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APPENDIX H
EPA REQUEST FOR COMMENT ON ALTERNATIVE APPROACHES FOR
PHASE H STORM WATER PROGRAM
-------
-------
Wednesday
September 9.1992
Part IV
Environmental
Protection Agency
40 CFR Part 122
National Pollutant Discharge Elimination
System, Request for Comment on
Alternative Approaches for Phase II
Storm Water Program
Recycled/Recyclable
Printed on paper that contains
at least 50% recycled fiber
-------
41344 Federal Register / Vol. 57. No. 175 / Wednesday, September 9. 1992 / Proposed Rules
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 122
[FRL-4202-9]
National Pollutant Discharge
Elimination System, Request for
Comment on Alternative Approaches
for Phase II Storm Water Program
AGENCY: Environmental Protection
Agency.
ACTION: Request for comment.
SUMMARY: In a memorandum dated
January 28,1992, the President asked
regulatory agencies to review existing
and proposed rules to improve cost
effectiveness, minimize economic
impact, and reduce regulatory burden. In
response, today's notice requests
information and public input on Phase II
of the national storm water program
mandated under section 402(p)(6) of the
Clean Water Act (CWA). More
specifically, EPA is today requesting
public comment on a number of issues
including scope of coverage under Phase
II, identification of high risk Phase II
discharges, alternative control
strategies, and appropriate deadlines.
With respect to each of these issues, the
Agency is requesting input on how to
meet environmental objectives and
requirements set forth under section
402(p)(8) while at the same time
identifying cost-effective control
strategies that minimize the economic
impact on the regulated community as
well as the administrative burden on
Federal, State and local government.
DATES: Comments on this notice must be
received on or before November 9,1992.
ADDRESSES: Respondents should send
an original and two copies of their
comments to Michael Plehn, Office of
Wastewater Enforcement and
Compliance (EN-336), United States
Environmental Protection Agency, 401M
Street. SW.. Washington, DC, 20460,
(202) 260-6929. The public record for this
notice is located at EPA Headquarters,
ME Mall room 220,401M Street, SW.,
Washington, DC, 20460. Appointments
to view the record can be made by
contacting Michael Plehn at the above
address. A reasonable fee may be
charged for copying. The public record
for previous rulemaking activity related
to Phase I of the storm water program is
located at EPA Headquarters, EPA
Public Information Reference Unit, room
2402,401M Street, SW., Washington,
DC. 20460.
FOR FURTHER INFORMATION CONTACT:
For further information on this notice,
contact the NPDES Storm Water Hotline
at (703) 821-4823, or Michael Plehn,
Office of Wastewater Enforcement and
Compliance (EN-336), United States
Environmental Protection Agency, 401 M
Street, SW., Washington, DC 20460,
(202) 260-6929.
SUPPLEMENTARY INFORMATION:
I. Background
A. Environmental Impacts
B. Water Quality Act of 1987
C. Current (Phase I) Storm Water Permitting
Program
II. Today's Notice
A. Purpose and Intent
B. Alternative Approaches
1. Targeting
(a) Seek Amendments to the CWA to
eliminate Phase II and use designation
authority to bring additional sources
under Phase I
(b) Identify targeted MS4s as needing an
NPDES permit under section 402(p)(6) of
the CWA
(c) Continued reliance on Phase I MS4s to
control Phase II source which discharge
through their system
(d) Identify additional Phase II activities
other than MS4s based on comparative
loadings
(e) Geographic targeting
(f) Establish requirements for State storm
water management programs
(g) Rensselaerville focus groups
2. Control Strategies
(a) Continued reliance on NPDES program
(b) Continued reliance on nonpoint source
program
(c) Mandatory performance standards,
guidelines, management practices and/or
treatment requirements
(d) Rensselaerville focus groups
3. Deadlines
III. Request for Comments
A. General Issues for Comment
B. Current Classification of Regulated
Discharges
IV. Review and Analysis Requirements
I. Background
The 1972 amendments to the Federal
Water Pollution Control Act (FWPCA,
later referred to as the Clean Water Act
or CWA) prohibit the discharge of any
pollutant to the navigable waters of the
United States from a point source unless
the discharge is authorized by a
National Pollutant Discharge
Elimination System (NPDES) permit.
Efforts to improve water quality under
the NPDES program have focused
traditionally on reducing pollutants in
discharges of industrial process
wastewater and discharges from
municipal sewage treatment plants. This
program emphasis developed because
many industrial and municipal sources
were not controlled at that time and
were easily identified as contributing to
water quality impairment. Over time, as
pollution control measures were
implemented for these discharges and as
data collection efforts have provided
additional information, it has become
evident that more diffuse sources of
water pollution, such as agricultural and
urban runoff, are important contributors
to water quality problems and use
impairment. Some diffuse sources of
water pollution, such as agricultural
runoff and irrigation return flows, are
exempted statutorily from the NPDES
program. Controls for other point source
discharge of storm water runoff,
however, are addressed in this notice.
A. Environmental Impacts
. Several national assessments have
been conducted to evaluate the impacts
of diffuse sources of storm water runoff
on receiving water quality. The
"National Water Quality Inventory, 1990
Report to Congress" provides a general
assessment of water quality based on
biennial reports submitted by the States
under section 305(b) of the CWA. In
section 305(b) Reports, States indicate
the fraction of the States' waters that
have been assessed, the fraction of
those assessed waters that are not
supporting designated uses, and the
sources of use impairment for those
waters (e.g., diffuse sources, point
sources, and natural sources). The
Report indicates that roughly 30 to 40
percent of assessed rivers, lakes and
estuaries are not supporting the uses for
which they are designated. Based on
information from 51 States and
Territories that reported on sources of
pollution, the Report indicates that
storm water runoff from a number of
diffuse sources, including agricultural
areas, urban areas, construction sites,
land disposal activities, and resource
extraction activities, is the leading cause
of water quality impairment cited by
States. For those States reporting in
each category, diffuse sources were
cited as causing use impairments in the
following magnitudes: For rivers and
streams, 11 percent of impaired river
miles are caused by separate storm
sewers, 6 percent are caused by
construction activities, and 14 percent
are caused by resource extraction. For
lakes, 28 percent of impaired lake acres
are caused by separate storm sewers
and 25 percent are caused by land
disposal. For the Great Lakes' shoreline,
6 percent of impaired shoreline miles are
caused by separate storm sewers, and
41 percent are caused by land disposal.
For estuaries, 30 percent of impaired
acres are caused by separate storm
sewers. For coastal areas, 36 percent of
impairments are caused by separate
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41345
storm sewers, and 37 percent are caused
by land disposal.
In 1985, the States conducted a
different study of diffuse pollution
sources under the sponsorship of the
Association of State and Interstate
Water Pollution Control Administrators
(ASIWPCA) and EPA. The study
resulted in the report entitled
"America's Clean Water—The States'
Nonpoint Source Assessment, 1985." In
that study, 38 States reported urban
storm water runoff as a major cause of
beneficial use impairment. In addition,
21 States reported construction site
runoff as a major cause of use
impairment.
Studies conducted by the National
Oceanic and Atmospheric
Administration (NOAA) indicate that
urban storm water runoff is indeed a
major pollutant source that adversely
affects shellfish growing waters.1 The
NOAA studies concluded that urban
runoff affects 39 percent of harvest-
limited area on the East Coast, 59
percent in the Gulf of Mexico, and 52
percent on the West Coast.
B. Water Quality Act of 1987
In response to growing concerns with
the environmental impact of storm
water runoff, Congress addressed this
issue as part of the Water Quality Act of
1987 (WQA) by adding section 402(p) to
the CWA to require the establishment of
a comprehensive two-phased approach
for the control of storm water
discharges. Section 402(p)(l) prohibits
EPA or NPDES States from requiring
permits for storm water discharges until
October 1,1992, except for 5 classes of
storm water discharges specifically
listed under section 402(p)(2) (see
appendix A). These 5 classes of
discharges make up Phase I of the
existing national storm water program
and include storm water discharges:
(A) Permitted before February 4,1987;
(B) Associated with industrial activity;
(C) From a municipal separate storm
sewer system serving a population of
250,000 or more;
(D) From a municipal separate storm
sewer system serving a population of
100,000 or more, but less than 250,000;
(E) Which EPA or a NPDES State
determines contributes to a violation of
a water quality standard or is a
significant contributor of pollutants to
the waters of the United States.
Section 402(p)(3) confirms that, like all
other point source discharges under'the
1 "The Quality of Shellfish Growing Waters on
the East Coast of the United States," 1989: "The
Quality of Shellfish Growing Waters in the Gulf of
Mexico," 1988; and "The Quality of Shellfish
Growing Waters on the West Coast of the United
States," 1989.
CWA, discharges of storm water
associated with industrial activity must
meet all applicable provisions of CWA
sections 402 and 301, including
technology-based requirements and any
necessary water quality-based
requirements. Permits for discharges
from municipal separate storm sewer
systems may be issued on a system- or
jurisdiction-wide basis and must meet a
new statutory standard requiring
controls to reduce pollutant discharges
to the maximum extent practicable
(MEP).
Phase II of the storm water program
covers all storm water discharges not
addressed under the five Phase I classes
described above. Under the current
provisions of section 402(p), the existing
statutory prohibition against permitting
Phase II storm water discharges expires
on October 1,1992 (see appendix B).
Under CWA section 402(p)(5), EPA, in
consultation with the States, is required
to conduct two studies on Phase II storm
water discharges for which permits
cannot be required before October 1,
1992. The first study will identify those
sources or classes of discharges that
may be addressed in Phase II and
determine the nature and extent of
pollutants in such discharges. The
second study is to establish procedures
and methods to control Phase II storm
water discharges to the extent necessary
to mitigate impacts on water quality.
These studies have not been completed.
Under section 402(p)(6), EPA, in
consultation with State and local
officials and based on the two studies, is
required to issue regulations by October
1,1992, which designate particular
sources or classes of Phase II storm
water discharges to be regulated to
protect water quality and which
establish a comprehensive program to
regulate such designated sources. This
program must establish priorities,
requirements for State storm water
management programs, and expeditious
deadlines. The program may include
performance standards, guidelines,
guidance, and management practices
and treatment requirements, as
appropriate.
The approach mandated by section
402(p)(2) is fully consistent with the
intent and requirements of Section 319
of the WQA of 1987. Section 319 was
enacted to require States to prevent and
control nonpoint source pollution.
Under section 319 States are required
to submit Nonpoint Source Assessment
Reports identifying State waters which,
without additional control of nonpoint
sources of pollution, cannot be expected
to attain or maintain designated uses.
States were also required to prepare and
submit for EPA approval a statewide
management program for controlling
nonpoint source water pollution to
navigable waters within the State and
improving the quality of such waters to
levels sufficient for attaining or
maintaining applicable water quality
standards or goals. Furthermore, the
State program submittal was to identify
specific best management practices and
measures which the state proposes to
implement, in the first four years after
program submission, to reduce pollutant
loadings from identified nonpoint
sources to levels required to achieve the
stated water quality objectives.
Although the State nonpoint source
programs are not enforceable under
Federal law, States were encouraged to
adopt both regulatory and non-
regulatory approaches under State and
local law. Section 319(b)(2)(B) specifies
that a combination of "non-regulatory or
regulatory programs for enforcement,
technical assistance, financial
assistance, education, training,
technology transfer, and demonstration
projects" may be used, as necessary, to
achieve implementation of the best
management practices or measures
identified in the section 319 submittal.
To date, all States have approved
section 319 assessments and approved
management programs. EPA has
awarded approximately $38 million in
FY90 funds, $51 million in FY91 funds,
and is in the process of awarding $52.5
million in FY92 funds to assist States in
implementing the section 319 programs.
EPA expects that State nonpoint source
management programs will be revised
and refined periodically in response to
re-evaluated priorities and new
strategies and technologies.
Numerous States and local
governments have implemented
regulations and enforceable policies to
control nonpoint source pollution. States
such as Delaware and Florida as well as
local governments such as the Lower
Colorado River Authority are
aggressively pursuing storm water
management goals through numerical
treatment standards for new
development. Many States and local
governments have enforceable erosion
and sediment control regulations. On a
broader scale, nonpoint source pollution
is being addressed at the watershed
level by programs such as those being
implemented by the State of Wisconsin
and the Puget Sound Water Quality
Authority and the states which are
parties to the International Agreement
on the Great Lakes. A number of
individual States and local communities
have adopted legislation or regulations
like Maryland's Critical Areas Bill
which limits development and/or
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41346 Federal Register / Vol. 57, No. 175 / Wednesday, September 9, 1992 / Proposed Rules
requires special management practices
in areas surrounding water resources of
special concern. California has also
recently created Storm water
management districts to better address
the control of nonpoint source pollution.
A further development in the area of
Federally-mandated nonpoint source
management occurred in 1990 with the
enactment of section 6217 of the Coastal
Zone Act Reauthorization Amendments
(CZARA). Section 6217 provides that
States with approved coastal zone
management programs must develop
and submit to EPA and NOAA for
approval a coastal nonpoint pollution
control program. Failure to submit an
approvable program will result in the
loss of Federal grants under both the
Coastal Zone Management Act and
section 319 of the CWA. State nonpoint
pollution control programs must also
include enforceable policies and
mechanisms which ensure
implementation of the management
measures throughout the coastal
management area. Management
measures as defined in section
6217(g)(5) are: "Economically achievable
measures for the control of the addition
of pollutants from existing and new
categories and classes of nonpoint
sources of pollution, which reflect the
greatest degree of pollutant reduction
achievable through the application of
the best available nonpoint pollution
control practices, technologies,
processes, siting criteria, operating
methods, or other alternatives."
The section 6217(g) guidance was
issued for public comment in May, 1991.
Final guidance is expected by October,
1992. The technology-based approach
used in the guidance provides State
Officials flexibility to meet the
management measures using best
management practices identified in the
guidance or other methods and
strategies which achieve equivalent or
higher levels of pollutant control. If the
technology-based approach fails to
achieve and maintain applicable water
quality standards and protect
designated uses, additional management
measures are required under CZARA
section 6217(b)(3). Congress mandated a
technology-based approach founded on
technical and economic achievability
under the rationale that neither States
nor EPA have the money, time, or other
resources to create and implement a
program which depends on establishing
cause and effect linkages between
particular land use activities and
specific water quality problems.
Nonpoint sources addressed in the
proposed guidance include: urban runoff
from both developing and developed
areas, roads, highways and bridges,
agriculture, forestry, marinas,
hydromodification, dams and levees.
C. Current (Phase I) Storm Water
Permitting Program
EPA promulgated permit application
regulations for Phase I storm water
discharges on November 16,1990 (55 FR
47990). The November 16,1990
regulations established the scope of the
Phase I storm water program by defining
two major classes of storm water
discharges identified under section
402(p)(2)(B), (C), and (D) of the CWA:
Storm water discharges associated with
industrial activity;2 and discharges from
municipal separate storm sewer systems
(MS4s] serving a population of 100,000
or more.3 In addition, the November 16,
1990 regulations established permit
application requirements, including
deadlines for these two classes of
discharges (for a summary of Phase I see
appendix A).
The November 16,1990 regulations
defined municipal separate storm sewer
system serving a population of 100,000
or more to include municipal separate
storm sewers within the boundaries of
173 incorporated cities, and within
unincorporated portions of 47 counties
that were identified as having
populations of 100,000 or more in
unincorporated, urbanized portions of
the county.4 In addition, the regulations
allowed for additional municipal
separate storm sewers to be designated
by the Director of the NPDES program
as being part of a large or medium MS4.
The November 16,1990 regulations
establish comprehensive two part
permit applications for discharges from
large or medium MS4s. The permit
application requirements for large and
medium MS4s, among other things,
require municipal applicants to propose
municipal storm water management
programs to control pollutants to the
maximum extent practicable and to
2 On June 4,1992 the United States Court of
Appeals for the Ninth Circuit found that EPA's
rational for exempting construction sites of less
than Five acres and certain uncontaminated storm
water discharges from light industrial facilities from
Phase I of the storm water program to be invalid
and has remanded these exemptions for further
proceedings (see Natural Resources Defense
Council versus EPA No. 91-70176).
3 Consistent with Section 402(p)(2) of the CWA,
the November 16,1990 regulations address two
subclasses of municipal separate storm sewer
systems serving a population of 100,000 or more.
Large municipal separate storm sewer systems are
defined as systems serving a population of 250,000
or more (see 40 CFR 122.26(b)(4)). Medium
municipal separate storm sewer systems are
defined as systems serving a population of 100,000
or more, but less than 250,000 (see 40 CFR
122.26(b)(7)).
4 See appendices F, G, H, and I to 40 CFR part
122.
effectively prohibit non-storm water
discharges to the MS4.5
The November 16,1990 regulations
also defined the term "storm water
discharges associated with industrial
activity" to include 11 categories of ;
industrial facilities (see 40 CFR
122.26(b)(14)). The November 16,1990
regulations establish two sets of
application requirements for storm
water discharges associated with
industrial activity: Individual
applications and group applications. In
addition, the notice recognizes a third
set of application procedures for storm
water discharges associated with
industrial activity referred to as "notice
of intent" (NOI) requirements associated.
with general permits.
The Phase I storm water program
takes two very different approaches to
defining the roles of EPA and authorized
NPDES States in controlling pollutants
in storm water discharges. With respect
to permits for large and medium MS4s,
the efforts of the NPDES permitting
authority (EPA or an authorized NPDES
State) are directed to ensuring that
municipalities develop and implement
storm water management programs to
control pollutants to the maximum
extent practicable. Municipal programs
address the control of pollutants in
storm water from all areas within the
boundaries of the MS4 that discharge to
the system, including privately-owned
lands, as well as modifying municipal
activities (e.g. road deicing and
maintenance, flood control efforts,
maintenance of municipal lands, etc.) to
address storm water quality concerns.
The Agency has defined the role of
municipalities under this program in a
flexible manner that allows local
governments to assist in defining
priority pollutant sources within the
municipality, and to develop and
implement appropriate controls for such
discharges. With respect to permits for
storm water discharges associated with
industrial activity, the NPDES permitting
authority has a more direct role in
regulating facilities.8
While today's request for comments
focuses on developing Phase II of the
storm water program, readers may find
that a brief summary of progress to date
8 See 40 CFR 122.26(d)(2)(iv).
e NPDES permits for discharges from large and
medium MS4s will establish municipal
responsibilities for assisting EPA and authorized
NPDES States in implementing controls to reduce
pollutants in storm water discharges associated
with industrial activity which discharge through
large and medium MS4s. A more detailed
description of the role of municipalities in
addressing industrial storm water sources under
this Federal/State/Municipal partnership, is
provided at 56 FR 40972 (August 16,1991).
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Federal Register / Vol. 57, No. 175 / Wednesday, September 9, 1992 / Proposed Rules 41347
in implementing the first phase of the
program would be helpful. Part of
current implementation activities
include outreach efforts and two
rulemakings discussed in more detail
below which are specifically designed to
provide more flexibility and minimize
regulatory and administrative burdens
where possible.
As discussed above, the November
1990 storm water rule provided for three
different options for storm water
discharges associated with industrial
activity to seek coverage under the
program: individual, group, and general
permit applications. Since November
1990, there has been a great deal of
activity as EPA and the States have
worked with the regulated community to
provide guidance and implement the
program. The Agency has established a
four tier risk-based storm water
permitting strategy which emphasizes
the use of general permits (April 2,1992,
(57 FR11394)). As part of the strategy,
EPA called for the development of State
storm water management programs to
track permit issuance, provide for
prioritization of risk, and create
baselines against which to assess
environmental results. As part of the
same rule, the Agency extended the
deadline for Part 2 of group applications
until October 1,1992, and also deferred
regulation of storm water discharges
from industrial activities owned or
operated by municipalities with a
population under 100,000 until Phase 2 of
the program, pursuant to section 1068(c)
of the Intermodal Surface
Transportation Efficiency Act of 1991. In
providing for greater flexibility, reduced
burdens, extended deadlines, and
deferred regulation, this recent storm
water rulemaking addresses many of the
goals underlying the President's January
28,1992 request to review existing
regulations.
Since November 1990, the Agency has
received over 1,200 Part I group
applications representing more than
60,000 facilities. EPA is currently
processing these applications. Final
decisions have been reached on over
1,000 to date. Approximately 75% have
been approved, 20% withdrawn or
determined not to be covered, and 5%
denied. Part I group applications were
due on September 30,1991. Part II
sampling information from approved
groups is due on October 1,1992.
At the same time that EPA has been
receiving and processing group
applications, States have been actively
moving to provide for storm water
general permit issuance. When the
storm water application rules were
issued in November 1990, only 17 out of
39 States authorized to administer the
NPDES program were also approved to
issue NPDES general permits. Since
then, an additional 16 States have
requested and received Federal
approval to issue general permits. Over
two thirds of the States that now have
general permit authority are presently
developing specific general permits to
cover storm water discharges.
For the 12 States without NPDES
authority, EPA is in the process of
issuing storm water general permits that
rely heavily upon industrial facilities
developing and implementing their own
storm water pollution prevention plans.
As part of the four tier risk-based
permitting strategy referred to above
and discussed in more detail in the
Agency's April 2,1992 notice, EPA
believes that the majority of storm water
discharges associated with industrial
activities should be covered by general
permits. The Agency urges all
authorized NPDES States without
general permit approval to obtain
NPDES general permit authority.7 EPA
places a high priority on this effort and
is providing direct technical guidance
and assistance to support States both in
obtaining general permit approval and
in developing specific general storm
water permits.
With regard to guidance, training, and
outreach, EPA has undertaken a number
of efforts to provide technical assistance
and also to get public input on ways to
streamline the existing program. In the
area of guidance, EPA has published
and distributed thousands of municipal
and industrial permit application
manuals in addition to numerous
summaries, fact sheets and work shop
materials over the past eighteen months.
The Agency has issued additional
guidance on storm water sampling,
pollution prevention plan development,
and storm water best management
practices (BMPs), and is developing
guidance for part 2 municipal
applications. A list of EPA technical
guidance, summaries, and storm water
fact sheets can be obtained by calling
the Agency's storm water hotline at
(703) 821-4823.
In the area of training and outreach,
EPA staff has participated in over 60
workshops and presentations
throughout the country, training
permitting authorities and educating the
regulated community. For example, EPA
Regions held fourteen public hearings to
receive public comment on the Agency's
proposed general permits in August and
September of 1991. EPA held an
* Currently, DE. IA. KS. MI, NV, NY. OH, SC, VT
and the Virgin Islands have authorized NPDES
programs, but do not have general permit authority.
additional 26 storm water workshops
across the country this summer and
would welcome hearing from groups or
organizations interested in receiving
workshop materials for further in-house
or local training.
While EPA recognizes the importance .
of ongoing training and outreach efforts
to provide information on the storm
water program, the Agency also regards
these activities as an effective
mechanism for getting feedback on the
program and identifying areas for
further improvement. The new guidance
documents referred to above and
presently being developed reflect input
from States and the regulated
community on high priority areas
requiring clarification and further
technical assistance.
In addition to these activities, EPA
has recently completed a study, in
conjunction with the Rensselaerville
Institute, to obtain direct public input
and develop recommendations for
streamlining the program and making it
more effective. This study has two
objectives. The first is to develop
recommendations to streamline program
implementation under existing
regulations and legislation (Phase I). The
second is to develop cost-effective
options for addressing risks from storm
water sources not currently required to
be permitted that could potentially be
addressed under Phase II of the storm
water program.
Under the first objective, the
Rensselaerville Institute sponsored 6
focus groups across the country with
members representing state and local
government, the regulated community,
and environmental interests for
uninterrupted full day discussions on
ways to improve the storm water
program. Five key issues were raised by
all groups: (1) Groups felt that EPA has
not been very clear about the intended
goals of the regulations and should
communicate storm water risks,
objectives, and requirements more
clearly to the general public as well as
the regulated community, (2)
participants noted that the cost of
program implementation is significantly
higher than original EPA estimates and
there is great concern regarding the real
costs of the program and of achieving
compliance, (3) there was consensus
that EPA and States must accelerate
general permit issuance and focus on
general permits to achieve efficient
implementation of the program, (4)
participants felt that technical outreach
should be targeted at the State and local
level as opposed to the national level
and should provide better guidance on
the regulations and how to implement
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41348 Federal Register / Vol. 57. No. 175 / Wednesday, September 9, 1992 / Proposed Rules
them, and (5) groups noted that coverage
under certain industrial storm water
categories should be clarified.8 EPA
agrees with these recommendations and
Is taking steps, some of which are
outlined above, to follow up in each of
these areas.
The second objective of the
Rensselaerville study, consistent with
the purpose of today's notice, is to get as
much input as possible on different
options for identifying and addressing
those Phase II storm water discharges
not regulated under the current program.
Under the study, however, the
mechanism for encouraging feedback
was more targeted and interactive. The
Rensselaerville Institute has obtained
input from national experts
(representing permitting authorities, the
environmental community, and
regulated interests) and then followed
up with a series of 3 expert discussion
forums that were open to the public in
June.
The public meetings were held in
Denver, San Francisco and Washington,
DC. Attendees were divided into task
teams and asked to develop their own
strategy for addressing Phase II sources.
There were 16 task teams: Five each at
the Denver and San Francisco meetings,
and six in Washington, DC. They were
given a strategy template to guide them
in their discussion, but were not
confined to the template in developing
their strategies and recommendations.
Each team considered and then
presented the option they had developed
over a four hour period. There were
common strategy characteristics
mentioned across groups within
meetings and also across meetings. The
recommendations of the focus groups
covered four specific areas: Targeting
strategies, controls that should be put in
place, timetable, and the role of EPA in
Phase II. The recommendations made by
focus groups regarding the first three
areas are discussed below along with
the options presented for comment.
With regard to the role of EPA,
participants identified the areas of
responsibility they felt it would be
appropriate for EPA to assume under
Phase II. Their recommendations can be
classified by four common themes: (1)
Teams felt that EPA shduld provide
technical assistance, information
dissemination, and do any research
necessary as a part of Phase II; (2)
participants suggested that EPA should
provide funding for research or
demonstration projects, but not for
program implementation; (3) groups
stressed that EPA should set broad
guidelines for the program, but allow
State and local governments to
determine the level of specificity needed
to effectively implement the program;
and (4) teams felt that EPA should be
responsible for training regulators in the
program.
II. Today's Notice
A. Purpose and Intent
CWA sections 402(p)(5) and (6)
require EPA to identify storm water
discharges not covered under Phase I
which should be regulated to protect
water quality.9 'The purpose of this
notice is to solicit public comment on
ways to implement the second phase of
the storm water permitting program for
sources and activities not regulated
under the existing program. EPA is
seeking comments on approaches for
meeting CWA Phase II storm water
requirements while at the same time
minimizing the economic impacts and
regulatory and administrative burdens
associated with additional Phase II
storm water controls. There are a
number of ways to identify additional
categories of storm water activities for
further controls and EPA requests
comment on the alternatives listed
below as well as on any other
approaches that may not be identified in
today's notice.
B. Alternative Approaches
EPA is interested in comments from
the general public, state and local
government, the regulated community
and environmental groups on each of
the options outlined below. The goal of
the CWA is to restore and maintain the
chemical, physical, and biological
integrity of the Nation's waters. In
practice, programs implemented under
the Clean Water Act have two basic
goals: To reduce pollutant loadings to
the environment and to require more
stringent controls where necessary to
assure attainment of State water quality
standards and designated uses. These
goals are compatible. However, the
specific regulatory strategy and
pollution reduction alternatives to be
chosen for addressing Phase II storm
water discharges could have a large
impact on the size of the regulated
universe and regulatory burden
• associated with the program.
To generate discussion and input from
commenters, today's notice discusses
several alternative approaches for
controlling storm water discharges from
currently unregulated sources under
Phase II of the storm water program. A
number of different control strategies,
with variations in scope and timing, are
outlined below. They range from
comprehensive permitting of all
municipal, light industrial, and
commercial activities that generate
storm water runoff to little or no NPDES
permitting of Phase II sources.
A major distinction between several
of the options listed below is whether
Phase II efforts should focus on
developing requirements for targeted
municipalities to develop source
controls and management programs for
storm water discharges within their
jurisdictions (for example, see options
(b) and (c) below) or whether Phase II
should, instead, focus on point source
discharges of storm water without
reference to the municipality in which
they may be located. Under the first
approach, EPA would develop NPDES
requirements that required targeted
municipalities to develop and implement
storm water management programs
which address storm water discharges
within their jurisdiction 10 to the
maximum extent practicable. This
approach would allow for flexibility
based on local factors, but could lead to
varying levels of control from one area
to another. EPA requests comments on
the ability of municipalities to
effectively regulate storm water
discharges. In addition, the Agency
requests comment on appropriate
funding mechanisms for municipal
programs, in particular the feasibility of
implementing storm water utilities,
which are currently being used in more
than 100 communities nationwide.11
To facilitate comment and analysis,
the following discussion is organized in
terms of three issues: Targeting, control
strategies, and deadlines. Each of these
areas overlap and any final decision
must reflect choices from each group.
However, the objective is to solicit input
• The regulatory definition of storm water
diichnrge aisoclated with Industrial activity
Identifies 11 categories of Industrial facilities (see 40
CFR 12Z2fl(b){14)). In particular, category viii
(certain transportation facilities) and category xi
(certain manufacturing facilities with materials and/
or materials handling equipment exposed to
precipitation) were identified as needing
clarification.
" Section 502(14) of the CWA excludes
agricultural storm water runoff from the definition
of point source. Section 402(1)(2) prohibits EPA from
requiring an NPDES permit for certain
"uncontaminated" storm water discharges from
mining sites and oil and gas operations. EPA cannot
regulate these discharges under section 402(p)(6) of
the CWA.
10 One issue that needs to be resolved is whether
targeted municipalities should be responsible for
controlling all priority storm water discharges
within their jurisdiction or only those that discharge
directly to the MS4.
11 For more information see "Storm Water
Utilities: Innovative Financing for Storm Water
Management", EPA, Water Policy Branch. OPPE,
1992.
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Federal Register / Vol. 57. No. 175 / Wednesday. September 9. 1992 / Proposed Rules 41349
on three basic questions. First, what
should be covered under Phase II; that
is, what additional municipal separate
storm sewer systems, municipal
industrial activities, commercial, light
industrial, retail, or residential activities
not presently covered under Phase I of
the storm water program should be
targeted or identified as needing
additional controls? Second, what
control strategies should be developed
and implemented to address these Phase
II activities? Third, what deadlines or
time frames should apply in
implementing Phase II of the storm
water program?
In addressing each of these questions,
commenters are requested not only to
provide their views on appropriate
alternatives (including approaches that
may not be included in this notice), but
also where possible detailed rationales
and additional data or other information
which address the practical,
administrative and legal feasibility and/
or the environmental benefits, of a
particular option. In addition, each of
the approaches presented could be
combined with others to achieve
specific environmental objectives. For
example, dischargers of specific
pollutants in particular water bodies
could be targeted for permits or more
stringent controls. Along with input on
individual options EPA requests
comments on possible combinations or
other approaches not outlined above.
Commenters are also asked to address
the roles and responsibilities of Federal,
State and local governments under
various approaches, particularly with
respect to: (1) Identifying approaches
that target MS4s in currently
unregulated municipal areas as needing
permits, and (2) approaches that identify
classes of individual facilities (e.g.
commercial or retail facilities) as
needing permits.
The Agency also requests input on
what type of information should be used
in identifying sources to be covered and
whether commenters believe there is
presently sufficient information or
monitoring data at the state and local
level to expeditiously implement a
particular option listed below. If on a
national or regional basis there are not
sufficient data, the next question to be
addressed is whether a comprehensive
monitoring and data gathering effort is
warranted to assure effective
implementation of one approach over
another. In other words, there may be a
trade off between: (1) Near term general
targeting approaches combined with
flexible control strategies based on
information currently available, and (2)
a heavier reliance on longer term
specific geographic, watershed, or water
body related targeting mechanisms
which may require more comprehensive
data gathering efforts on both a facility
and stream reach basis.
1. Targeting
(a) Seek amendments to the CWA to
eliminate Phase II and use designation
authority to bring additional sources
under Phase I. Section 402(p)(2)(E)
presently provides that EPA or a State
may designate non-industrial storm
water discharges and discharges from
MS4s other than those serving a
population of 100,000 or more for control
under Phase I where the discharge
contributes to water quality violations
or is a significant contributor of
pollutants to waters of the U.S. Some
commenters may conclude that the
remaining unregulated discharges of
storm water (associated with smaller
municipalities, commercial activities,
and some retail or residential activities)
constitute, on the whole, a negligible
source of environmental risks, relative
to the discharges already regulated.
Under this option, Congress would
amend the CWA to eliminate section
402(p)(6) (Phase II requirements) as a
part of the NPDES program and expand
use of the existing designation authority
under 402(p)(2)(E) to designate
individual or classes of storm water
activities on a category, watershed,
stream reach, loadings, or other basis
for specific regulation under existing
Phase I requirements. Under this option,
those storm water activities not
designated for Phase I controls could be
addressed by an alternative means,
possibly under the State nonpoint
source management programs funded
under section 319 of the CWA or coastal
nonpoint pollution control programs
developed pursuant to section 6217 of
the CZARA. The Agency requests
comments on: (1) Whether State
programs funded under Section 319 can
better ensure appropriate control of
diffuse pollutant sources and; (2)
whether heavier reliance on State
nonpoint source programs to address
Phase II storm water point source
discharges would have adverse impacts
on States' program resources and the
ability of States to address agricultural
sources. The selective nature of this
designation option could reduce the
potential economic impact on the
economy and small entities. However,
using 402(p)(2)(E) may be viewed by
some commenters as a reactive
approach which does not recognize the
advantages of prevention of storm water
pollution problems over remediation of
these problems after they have been
identified. This approach may also
increase the administrative burden on
States and local government to identify
and undertake the necessary
administrative process to include
additional storm water activity under
Phase I.
(b) Identify targeted MS4s as needing
an NPDES permit under section
402(p)(6) of the CWA. The Phase IMS4
program currently only applies to
municipal separate storm sewer systems
serving a population of 100,000 or more.
EPA has defined the scope of these
Phase I requirements to specifically
identify 173 incorporated cities with a
population of 100,000 or more and 47
counties with a population of 100,000 or
more in unincorporated, urbanized
areas.12 In general, this approach
focuses on core cities of large
metropolitan areas, but with the
exceptions of 47 counties addressed,
does not address urban fringes or
suburban areas in large metropolitan
areas, urbanized areas without large
core cities, or smaller isolated cities or
population centers.13 EPA requests
comments on factors that should be
considered when evaluating options for
addressing Phase II MS4s.14
12 The 220 cities and counties addressed by these
definitions have a combined population of over 87.5
million people under the 1990 Census. However, a
significant percentage of the population of the 220
municipalities are served by combined sewers (not
addressed by the storm water program), which are
found primarily in areas of older development.
13 The 1990 Census indicates that 87.3 million
people lived in areas designated as urbanized areas
but outside of incorporated cities with a population
of 100.000 or more. Portions of over 5,400
incorporated cities, towns and villages, 900 counties
and about 1,500 minor civil divisions
(unincorporated towns and townships) are in Phase
II municipalities that are part of urbanized areas.
14 EPA outlined seven factors it considered when
defining the scope of large and medium MS4s (see
December 7,1988 (53 FR 49444), and November 16.
1990 (55 FR 48038)). These factors included: the
advantages of developing system-wide storm water
management programs for municipal systems; the
inter-jurisdictional complexities associated with
municipal governments: the fact that many
municipal storm water programs have traditionally
focused on water quantity concerns, and have not
evaluated water quality concerns; the geographic
basis necessary for planning comprehensive
management programs to reduce pollutants in
discharges from MS4s; the geographic basis
necessary to provide flexibility to target controls on
areas where water quality impacts associated with
discharges from MS4s are the greatest and to
provide an opportunity to develop cost effective
controls; the need to establish a reasonable number
of permits; Congressional intent to allow the
development of jurisdiction-wide, comprehensive
storm water programs with priorities given to the
most heavily populated areas of the country. The
Agency requests comment on which of these factors
should be considered in identifying Phase IIMS4
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41350 Federal Register / Vol. 57, No. 175 / Wednesday. September 9. 1992 / Proposed Rules
The Agency also requests comment on
the advantages of municipalities
associated with urbanized areas
coordinating storm water management
efforts on a regional basis. The Agency
notes that a number of municipalities
have developed regional administrative
approaches to flood control
management.15 Regional administrative
approaches appear to provide
opportunities for municipalities to lower
overall administrative burdens,
consolidate efforts to study or evaluate
approaches, and adequately plan cost-
effective approaches to consider and
address the needs of all represented
municipalities. The Agency requests
input on how it could or should
encourage the development and use of
regional approaches to storm water
management under the NPDES program.
Specifically, EPA requests comments on
the following targeting options as well
as any that may not be included in this
notice.
(i) Focus on population. Expand
coverage to address additional
municipalities based on population.
Following the Phase I approach,
coverage of municipalities could be
expanded by lowering the minimum
population requirement across the board
or by designating additional
municipalities or municipal systems by
name. EPA requests comments on the
appropriate role of county governments
and appropriate ways to characterize
the population of counties under this
approach.18 This approach controls
more sources of storm water, but
imposes regulatory burdens on
additional municipal entities.
(ii) Focus on population density.
Alternatively, EPA could focus on the
population density of metropolitan areas
instead of the population within a
particular municipality or municipal
system, and require permits for
discharges from municipal separate
storm sewers in areas of a specified
density. Urban storm water runoff is
related to the density of urban
development, the increase in impervious
areas, and the reduction in the area of
recharge and infiltration zones. EPA
requests comment on the use of
urbanized areas designed by the Bureau
ef Census as a tool for characterizing
" For more information see: William A. Macaitis,
"Regional Storm Water Management Trends", and:
L. Scott Tucker, "Current Programs and Practices in
Storm Water Management". Water and the City: the
Next Century. Public Works Historical Society,
1991.
'•The 1990 Census indicates that 447 counties
have a population of 100,000 or more. The current
definitions of large and medium MS4 address 47 of
these counties not already covered by Phase I of the
program.
population density and development
patterns.17
(Hi) Focus on population growth.
Focussing on population growth in
addition to, or in place of, population
density might be an additional
consideration in implementing this
option.18 Studies have shown that it is
much more cost effective to develop
measures to prevent or reduce
pollutants in storm water during new
development than it is to correct these
problems later on.19 In addition,
appropriate storm water measures for
new development can prevent or
minimize irreversible degradation to
surface waters. This approach might
serve to minimize the impact of small
and lightly-developed population
centers, but it would still increase the
burden on a number of municipalities
not presently regulated under Phase I.
(c) Continued reliance on Phase I
MS4s to control Phase II sources which
discharge through their system. Under
this approach, EPA would generally not
designate additional individual sources
(such as commercial and light industrial
sources) which discharge through a
large or medium MS4 as needing their
own NPDES permit. Instead, EPA would
continue to rely on municipalities to
identify priority storm water discharges
and develop appropriate controls for
those discharges as part of requirements
to develop and implement municipal
storm water management programs.
This option addresses some currently
unregulated sources, allows for
flexibility and consideration of local
factors, and avoids duplicative
regulation at the local, national and
State level. This approach also relies on
existing institutional frameworks of
17 The Bureau of Census defines urbanized areas
comprised of a central city (or cities) with a
surrounding closely settled area. The population of
the entire urbanized area must be greater than
50.000 people, and the closely settled area outside
the city, the urban fringe, must have a population
density generally greater than 1,000 persons per
square mile (just over 1.5 persons per acre) to be
included. The Bureau of Census defined 396
urbanized areas in the United States based on the
1990 Census. These urbanized areas have a
combined population of 158.3 million, or 63.6 percent
of the nation's total population. However, these
areas only account for 1.5 to 2 percent of the land
surface of the country.
" Most Urban growth occurs in urban fringe
areas outside of large core cities. For example,
between 1970 and I960, the population in those
parts of Census designated urbanized areas that are
outside of incorporated cities with a population of
100.000 or more increased by 18.9 million. During
this same time period, the population of
incorporated cities with a population of 100,000 or
more (Phase I cities) increased by only 0.6 million,
with the population of many of these cities
decreasing.
19 For example, see "Results from the Nationwide
Urban Runoff Program, Vol 1—Final Report", EPA,
1983.
municipalities 20 as well as the
institutional framework that EPA
envisions municipalities will develop
pursuant to NPDES requirements.21
However, it imposes additional
administrative and regulatory costs on
local governments and may result in
varying levels of control among
municipal programs. The Agency
requests comment on whether
municipalities are in the best position
(with assistance from EPA and
authorized NPDES States through
technical guidance) to identify priority
sources which discharge through their
MS4, or whether EPA should attempt to
designate such additional sources as
needing an NPDES permit. The Agency
also requests comments on the
appropriate funding mechanisms for
MS4s (e.g. storm water utilities, various
fees, general revenues, etc.), and
opportunities for municipalities to
modify existing functions to address
storm water concerns.
(d) Identify additional Phase II
activities other than MS4s based on
comparative loadings. EPA could use
available information (such as case-
studies and other research) to prioritize
Phase II sources in terms of their
relative pollutant loadings as well as the
type and nature of those loadings. On
this basis the Agency could issue
regulations to target those general
activities which contribute the highest
loadings of pollutants to receiving
waters as needing an NPDES permit.
This option is consistent with the
technology-based approach reflected in
the existing CWA. It would provide
more comprehensive coverage and
clarify the program. It would also avoid
expensive and time consuming debates
regarding the specific causal
relationship between a particular storm
water discharge and site by site specific
receiving water quality impact.
However, it would impose further
administrative and analytical burdens in
terms of gathering additional loadings
information on a national basis. This
approach may also result in including
20 Examples of municipal functions that can be
adapted to provide for consideration of storm water
concerns include oversight of new development, fire
safety inspections, pretreatment program
implementation, flood control activities,
management of municipal lands and activities, and
maintenance of public roads.
21 The NPDES regulatory framework for permits
for large and medium MS4s envision that
municipalities will be required to develop and
implement storm water management programs to
reduce pollutants in non-storm water discharges
(e.g. illicit connections and improper dumping);
storm water from residential and commercial areas:
storm water discharges from industrial activities:
and storm water discharges from construction
activities.
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Federal Register / Vol. 57, No. 175 / Wednesday, September 9, 1992 / Proposed Rules 41351
more sources than necessary due to
differences in loadings and existing
storm water controls, both structural
and non-structural, across similar
activities. The regulatory burden would
be determined in large part by the
overall control strategy chosen to
implement this approach.
This approach differs from those
outlined under options (b) and (c) in that
it relies on direct permitting by EPA and
authorized NPDES States rather than
requiring municipalities to develop
programs to address sources. The
Agency requests comments on which
sources of pollutants are better
addressed by specific NPDES permit
requirements rather than through
municipal storm water management
programs required pursuant to NPDES
permits for MS4s. For example,
activities generally located in rural
areas such as feedlots, orchards, and
golf courses most likely are not suited
for control through municipal storm
water management programs required
under permits for MS4s. Although large
feedlots (those subject to effluent
limitations guidelines) presently are
covered under Phase I, smaller feedlots
represent a significant source of
pollutants such as suspended solids,
BOD, and nutrients such as nitrates and
phosphates. In addition, storm water
discharges from commercial activities
such as greenhouses, nurseries, and golf
courses might be more effectively
controlled under a separate NPDES
permit requirement than through a MS4
program. As another example, many
commenters from all levels of State and
local government have expressed
concern about municipalities being
required to control pollutants from State
highways (see November 16,1990 (55 FR
48041)).
(e) Geographic targeting. EPA could
regulate Phase II storm water activities
on a watershed, waterbody, or regional
basis to protect water quality, control
water quality problems and attain
designated uses in specific areas. EPA
could:
(i) Designate additional municipal
and individual sources for permitting in
specific areas. A key aspect of this
approach would be developing a list of
waters that are not meeting designated
uses due to pollution from storm water
runoff (from section 305(b) reports or
from the section 304(1) list of waters) or
where sensitive waters or outstanding
national resource waters need special
protection. This approach could help to
achieve water quality goals and would
avoid imposing a burden on other
dischargers, but would not be uniformly
applied on a national basis. This option
is also reactive in nature, and overlooks
the advantages of prevention over
remediation. The availability of
technical information and water quality
data limitations and the administrative
and regulatory burden associated with
collecting and analyzing additional data
would have to be carefully considered in
evaluating the feasibility of this
approach.
(ii) Designate additional sources for
permitting or special requirements
within rainfall zones. The nature of
storm water problems varies between
areas with frequent rainfall, where
storm water flows are high with
continual pollutant loadings, and areas
with low or seasonal rainfall, where
intermittent flows carry highly
concentrated loadings of pollutants
accumulated during dry weather which
result in high shock loadings to receiving
waters. This option would recognize
these regional variations and tailor
regulatory requirements for Phase II
discharges (monitoring, best
management practices, reporting) to the
local nature of rain events. However,
immediate environmental benefits could
be delayed due to the inexact nature of
rainfall zones and the scarcity of
comprehensive information upon which
to base regulatory requirements.
(f) Establish requirements for State
storm water management programs.
Under this approach, EPA could develop
requirements for State storm water
management programs under section
402(p)(6) for the CWA which would
require States to identify additional
classes of storm water discharges for
control. This approach may offer the
advantages of additional flexibility for
States to target sources based on State
specific factors (climate, water
resources, development patterns) and
provide additional flexibility in the type
of administrative program developed.
However, the disadvantages of this
approach include the need for
generating additional resources at the
State level at a time when State
capacity is also strained, and possible
disparities in programs in different
States. Such disparities could make it
hard for a State to develop an
aggressive program when neighboring
States have lesser requirements. Further,
this approach may create additional
burdens on EPA to provide adequate
oversight of the State programs. EPA
also requests comments on the
appropriate role of EPA in reviewing
State plans or developing minimum
requirements for State plans and how
that role should change, if at all, for
States without authorized NPDES
programs. The Agency requests
comments on appropriate criteria for
evaluating the adequacy of State
programs, and appropriate procedures
for periodic review and evaluation of
such programs. EPA also requests
comments on whether this approach
could be harmonized with the
requirements of section 402(p)(6) for EPA
to take the lead in developing
management practices and controls for
Phase II sources, or whether this
approach might also require statutory
change.
(g) Rensselaerville focus groups.
There were several common themes
recognized by the focus groups with
regard to identifying potential sources to
be included in Phase II:
(i) Groups suggested that targeting be
done on a watershed basis, with
information gathered as a part of Phase I
used to help identify sensitive
watersheds. It was noted that this type
of targeting approach may require
intergovernmental agreements for
effective implementation.
(ii) Teams emphasized that the focus
of Phase II should be on "bad actors",
i.e. those sources that are known to
cause significant water quality
problems. Sources identified by team
members included: Gas/auto service
industries, transportation, highway
systems, land use development and
agricultural sources. There was a
consensus among groups that facilities
not contributing to impairment of water
quality should be able to gain an
exemption from controls, permits, fees,
and implementation of BMP's. Teams
concluded that SIC categories are an
ineffective way to designate covered
sources and that targeting should be
done based on the degree of risk that a
given facility poses, due to possible
differences between facilities in any one
industry.
(iii) Focus groups recommended that
small municipalities be included in
Phase II but with simplified application
requirements. Participants felt that
municipalities impacting watersheds of
concern or those connected to larger
MS4s should be targeted.
(iv) Participants in the study felt that
EPA should hold off on selecting sources
for Phase II until the Agency has
carefully looked at the date gathered
during Phase I. It was noted that
numerous sources of information are
available which could help determine
targeting priorities, for example, 305(b)
reports, information from Phase I
program sources, NURP, and the first
Report to Congress.
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41352 Federal Register / Vol. 57, No. 175 / Wednesday. September 9. 1992 / Proposed Rules
2. Control Strategies
The current Phase I storm water
program for industrial sources is
implemented through the NPDES
program with a heavy emphasis on the
use of general NPDES permits which
require the implementation of best
management practices including
development of site specific pollution
prevention plans. Phase I requirements
for large and medium MS4s focus on
system-wide permits which require the
development and implementation of
municipal storm water management
programs:
Regardless of how additional Phase II
storm water activities are identified—
whether they are designated under
402(p)(2)(E), comprehensively covered,
or selectively targeted for further
controls, a key issue on which EPA
requests comment is what are the
appropriate tools or control strategies to
put in place which assure pollutant
loading reductions and water quality
improvement?
(a) Continued reliance on NPDES
program. One option is the continued
reliance oh individual or general NPDES
permits for individual sources, and
system-wide permits for MS4s.
Developing or processing specific
application forms for and issuing
individual permits for all Phase II
sources may well be the most resource
intensive of any control approach.
Consistent with EPA's four tier Phase I
permitting strategy for industrial storm
water sources, individual permits may
be most appropriate in those case
specific situations where a particularly
difficult or complex discharge situation
needs to be addressed. By contrast,
input from the public and regulated
community to date suggests that heavy
reliance on general permits may well be
a very effective alternative within the
NPDES system. EPA solicits comments
on whether continued reliance on
NPDES permitting as the overall control
strategy for Phase II is the most
appropriate approach. An extensive
State and national administrative
NPDES infrastructure already exists and
is being relied upon for Phase I and
reliance on the general permit is
increasingly favored as an appropriate
storm water control strategy. However,
the capacity of the current system with
its existing resources to accommodate a
significant number of additional
permittees has already been called into
question for Phase I. A very real issue
exists as to whether the permitting
Agencies have the resources to address
more than a limited number of
additional Phase II permittees.
(b) Continued reliance on'nonpoint
source program. Another approach
includes continued reliance on the State
nonpoint source programs under section
319 of the CWA and future reliance on
programs under section 6217 of the
CZARA in coastal areas to control
Phase II storm water sources not
explicitly addressed or designated under
Phase I.
The structure, organization, and
working relationship within EPA and
State offices for the section 319 program
are established and proven successful.
The States have taken the lead under
section 319 to develop assessments of
storm water/nonprofit source impacts
and management programs to implement
controls. EPA has approved all States
assessments, 44 complete management
programs, and portions of all the
remaining State management programs.
The States management programs
typically include continued problem
assessments and monitoring, voluntary
control measures, mandatory control
measures established under State and
local authorities, State funding
assistance, public outreach, technical
assistance, enforcement, targeting of
priority waters, and coordination with
other Federal and State programs and
agencies. Therefore, the section 319
program's potential ability to control
Phase II sources is high. Also-, section
319 programs are founded on a
watershed planning and pollution
prevention/source reduction approach
which may be an effective vehicle to
provide program and technical
assistance to State and local
governments.
In addition, the new CZARA program
provides an excellent tool to address
Phase II sources in the coastal zone in a
comprehensive manner. EPA
emphasizes that the goals of the NPDES
and CZARA programs are
complementary. Many of the techniques
and practices used to control urban
runoff are equally applicable to both
programs. While different legal
authorities and geographic coverage
may apply to specific sources, States
have the option to implement CZARA
section 6217(g) management measures
throughout the coastal zone, as long as
NPDES requirements are met for those
entities subject to NPDES requirements.
States outside of the coastal zone may
also voluntarily incorporate the
management measures appropriate to
particular sources or specific problems
into the State's CWA section 319
program.
(c) Mandatory performance
standards, guidelines, management
practices and/or treatment
requirements. An alternative option
might also be to develop a set of
mandatory national Phase II control
guidelines that apply directly to Phase II
storm water activities without a permit.
The national pretreatment categorical
effluent guidelines is an example of this
approach. Permits by rule or general
permits without application or reporting
requirements are a similar concept. A
variation on this approach might include
the development of minimum categories
or classes of BMP's or pollution
prevention approaches with a
requirement that elements from each
class be chosen and implemented on a
facility or system specific basis. At one
level, this approach would appear to
reduce the regulatory and administrative
burden associated with submission of
Phase II storm water applications.
However, as a technical matter, it may
be extremely difficult to develop one
national rule that appropriately
addresses all Phase II storm water
activities. Developing such a rule may
take a significant amount of time and
may also entail substantial monitoring
and data collection. A further issue upon
which EPA solicits comment is whether
a national rule would be the most
effective approach given that many
members of the Phase II universe may
not be familiar with national regulations
and may not even be aware that such
requirements apply to them. EPA
recognizes that implementation of
control strategies other than NPDES
permitting would probably require
statutory change and requests comments
on what changes would be appropriate.
(d) Rensselaerville focus groups.
Focus groups identified several common
themes with regard to controls that
should be put in place for Phase II:
(i) Focus groups recommended that if
a permitting process is to be continued
for Phase II sources, NPDES general
permits should be used, and the focus
should be on the implementation of
effective BMP's. Participants felt that
permits, should be simpler, less costly,
and that EPA should make absolutely
clear to applicants what information is
required through the use of checklists of
inclusion, a menu of potential BMP's,
and other documents to assist permitees.
The team members again stressed that
exemptions from permitting should be
available for sources not contributing to
water quality problems.
(ii) The teams concluded that
education is often overlooked and that it
should be a primary component of any
Phase II program. Team members felt
that education is important for all
audiences and that local level education
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Federal Register / Vol. 57, No. 175 / Wednesday, September 9, 1992 / Proposed Rules 41353
for the public and affected industry is
critical to the success of the program.
(iii) There was an agreement among
teams that there should be more
emphasis on voluntary programs,
perhaps similar to those under the 319
nonpoint source program. Groups also
suggested that for facilities that have
contact with storm water, there should
be limited additional governmental
intervention, but rather an emphasis on
pollution prevention incentives, BMP's,
and specific pollution prevention
techniques. Participants stressed that
pollution prevention should be
emphasized, particularly with new
development. Some suggested
prevention methods included: recycling
storm water, good housekeeping
practices, plantings to minimize runoff,
street sweeping of work areas on a daily
basis, storm water collection methods,
coverage of storage areas, changing
manufacturing processes to minimize
pollutants and better controls of air
emissions.
(iv) Groups felt that there should be
correlation between the severity of the
problem and the degree of controls
required and that fines and fee
structures could be used as "carrot-
stick" measures to aid implementation.
3. Deadlines
Section 402(p) presently provides that
the current prohibition against
permitting Phase II sources expires on
October 1,1992. EPA solicits comment
on the possible options for alternative
deadlines for Phase II permit application
requirements and statutory revisions of
the CWA. One option is for Congress to
extend the current October 1,1992
deadline for Phase II sources. Under this
option, EPA requests comment on what
the new Phase II date should be and
why one particular extension is more
appropriate than another. For example,
one possible date might be October 1,
1995, to allow one year for additional
data gathering and public input on
appropriate Phase II sources and control
strategies and then two additional years
to propose and finalize Phase II
regulations.
Another strategy might be to adopt a
phased set of Phase II deadlines with
high priority storm wajer sources
covered first and lower risk sources
addressed at a later date.
A third approach follows option 1
under Targeting; that is, to eliminate the
Phase II deadlines and follow option 1
or direct EPA to follow some other
option.
Focus group recommendations from
the Rensselaerville study suggested that
a minimum of 2-3 years is needed to
prepare for Phase II, with at least a year
dedicated to looking at data gained from
Phase I of the storm water program and
other documents such as the first Report
to Congress. Participants also felt that
the effectiveness of presently used
BMP's needs to be looked at to
determine variations in effectiveness
between different geographic locations
and pollutants.
III. Request for Comments
EPA is requesting comments on all
aspects of the Phase II storm water
permitting program. EPA is soliciting
general comments on environmental
objectives and economic impacts, as
well as specific recommendations and
implementation advice on each of the
options outlined above. Based on
comments received and the results of
the two studies required under CWA
section 402(p)(5), EPA may propose a
rule under section 402(p)(6) or solicit
additional comments on options again
when more data becomes available. In
addition, EPA welcomes data or
information from ongoing studies that
support specific comments or
recommendations.
A. General Issues for Comment
Based on the discussion above and
the President's memorandum on
reducing the burden of government
regulation, EPA requests comment on
the advantages and disadvantages of
each option outlined above as well as
any other potential approaches in terms
of the following factors.
1. How well does the approach
perform with respect to the
environmental goals of protecting water
quality, reducing pollutant loadings, and
achieving designated uses in impaired
waters? EPA requests comment on
which of these approaches most lends
itself to the documentation and
establishment of environmental
baselines and identification of
appropriate environmental indicators
against which to evaluate progress. EPA
specifically solicits input on appropriate
environmental indicators in connection
with any of the approaches outlined
above or identified by a commenter.
2. Does the option balance the need
for regulation to protect/improve the
environment with the desire to minimize
the regulatory burden and maximize the
cost effectiveness of the approach?
3. Does the option help to reduce the
regulatory burden on potential
permittee, while still maintaining
environmental benefits?
4. Does the option help to reduce the
administrative burden on Federal, State
and local government, so that resources
are used to address important
environmental problems efficiently?
5. To what extent does the option
support or provide an incentive or
additional flexibility for implementing
pollution prevention and other
innovative permit approaches?
6. Does the option allow or encourage
the use of market incentives or trading
to promote greater or more effective
loadings reductions and water quality
improvements?
7. What is the impact of the proposed
approach on small businesses 2Z and
communities?
8. does the option allow consideration
of the issue of affordability as a factor in
determining which Phase II sources
should be controlled? For example, some
data indicates that average per capita
income in suburban fringe areas is
substantially higher than in core cities.
Does the option allow this to be factored
in when identifying high priority groups
or selecting appropriate control
strategies?
EPA requests specific implementation
recommendations based on the
respondent's general evaluation of the
options outlined above. EPA also seeks
detailed comments on how the option
will be implemented and ways to refine
the respondent's preferred approach. For
example, address issues of affordability,
cost effectiveness and possible funding
mechanisms and sources, in addition to
providing case examples where
available of successful State or local
implementation of a preferred option.
Respondents should also consider the
need for statutory changes or
rulemaking to implement recommended
approaches.
B. Current Classification of Regulated
Discharges
The current regulatory framework of
Phase I is summarized in appendix A.
This information may help respondents
to understand which types of
municipalities and commercial and light
industrial activities are not currently
regulated under Phase I of the program.
Sources exempted from Phase II and
some sources potentially covered under
Phase II are summarized in appendix B.
IV. Review and Analysis Requirements
Various reviews and analyses are
required to assess the economic or
paperwork impact of new rulemaking
activities under Executive Order 12291,
the Paperwork Reduction Act (44 U.S.C.
3501. et. seq.), and the Regulatory
Flexibility Act (5 U.S.C. 601, et. seq.).
" With respect to impacts on municipalities, the
agency requests comments on options
municipalities have for generating the revenue
required to run such programs.
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41354 Federal Register / Vol. 57, No. 175 / Wednesday, September 9. 1992 / Proposed Rules
These assessments are not necessary for
this notice, which merely requests
comments on ways to reduce the
regulatory burden of potential future
rulemaking.
Dated: September 1,1992.
Martha G. Prothro,
Acting Assistant Administrator.
Appendix A. Facilities Covered in Phase
1
1. Industrial Facilities
EPA has defined the term "storm
water discharge associated with
industrial activity" in a comprehensive
manner to address over 100,000
facilities. All storm water discharges
associated with industrial activity that
discharge directly to waters of the
United States or through municipal
separate storm sewer systems are
required to obtain NPDES permits,
including those which discharge through
systems located in municipalities with
populations of less than 100,000.
Discharges of storm water to a
combined sewer system or to a Publicly
Owned Treatment Works (POTW) are
excluded. Facilities with storm water
discharges associated with industrial
activity include: manufacturing/
industrial facilities; construction
operations disturbing five or more acres;
hazardous waste treatment, storage, or
disposal facilities; landfills; certain
sewage treatment plants; recycling
facilities; powerplants; mining
operations; some oil and gas operations;
airports; and certain other
transportation facilities. Operators of
industrial facilities that are Federally,
State or municipally owned or operated
(with the exception of certain facilities
owned or operated by a municipality of
less than 100,000 people ' that meet the
description of the facilities listed in
122.26(b}(14) (i)-(xi), described below,
must also submit applications.
SUMMARY OF INDUSTRIAL ACTIVITIES COVERED UNDER PHASE I OF THE STORM WATER PROGRAM
40 CFR
122,26{b)(14)
Subpart
&....
(8)....
(so...
(v)...
(vi).,.
(vii)...
(vi)..
fa) „
(X)....
(xi)..,.
Facilities subject to storm water effluent limitations guidelines, new source performance standards, or toxic pollutants effluent standards under 40
CFR, Subchapter N Cexcept facilities which are exempt under category (xi)].
Facilities classified as:
SIC 24 (except 2434)—Lumber and wood products.
SIC 26 (except 265 and 267)—Paper and allied products.
SIC 28 (except 283 and 285)—Chemicals and allied products.
SIC 29—Petroleum and coal products.
SIC 311—Leather tanning and finishing.
SIC 32 (except 323)—Stone, clay and glass products.
SIC 33—Primary metal industries.
SIC 3441—Fabricated structural metal.
SIC 373—Ship and boat building and repairing.
Facilities classified as:
SIC 10—Metal mining.
SIC 11—Anthracite mining.
SIC 12—Coal mining.
SIC 13—Oil and gas extraction.
SIC 14—Nonmetallic minerals, except fuels.
Hazardous waste treatment, storage, or disposal facilities, including those that are operating under interim status or a permit under Subtitle C of
the Resource Conservation and Recovery Act (RCRA).
Landfills, land application sites, and open dumps that receive or have received any industrial wastes including those that are subject to regulation
under subtitle D or RCRA.
Facilities involved in the recycling of material, including metal scrapyards, battery reclaimers, salvage yards, and automobile junkyards, including
but limited to those classified as:
SIC 5015—Motor vehicle parts, used.
SIC 5093—Scrap and waste materials.
Steam electric power generating facilities, including coal handling sites.
Transportation facilities covered by the following SIC codes which have vehicle maintenance (including vehicle rehabilitation, mechanical repairs,
painting, fueling, and lubrication), equipment cleaning operations, or airport de-icing operations, or which are otherwise listed in another category,
are included.
SIC 40—Railroad transportation.
SIC 41—Local and suburban transit
SIC 42 (except 4221-25)—Motor freight and warehousing.
SIC 43—U.S. Postal Service.
SIC 44—Water transportation.
SIC 45—Transportation by air.
SIC 5171—Petroleum bulk stations and terminals.
Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system, used in the storage, treatment,
recycling, and reclamation of municipal or domestic sewage, including lands dedicated to the disposal of the sewage sludge that are located
within the confines of the facility, with a design flow of 1.0 Million Gallons per Day (MGD) or more, or required to have an approved pretreatment
program under 40 CFR Part 403. Not included are farm lands, domestic gardens, or lands used for sludge management where sludge is
beneficially reused and which are not physically located in the confines of the facility, or areas that are in compliance with Section 405 of the
CWA.
Construction activity including clearing, grading, and excavation activities except operations that result in the disturbance of less than 5 acres of
total land area which are not part of a larger common plan of development or sale1.
Facilities under the following SICs [which are not otherwise included in categories (ii)-(x)], including only storm water discharges where material
handling equipment or activities, raw materials, intermediate products, final products, waste materials, byproducts, or industrial machinery are
exposed to storm water1.
SIC 20—Food and kindred products.
SIC 21—Tobacco products.
SIC 22—Textile mill products.
1 In the Intermodal Surface Transportation
Efficiency Act of 1991, Congress provided that
industrial activities owned or operated by
municipalities with a population of less than 100.000
be placed into Phase II of the storm water program
with the exception of airports, power plants and
uncontrolled sanitary landfills.
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Federal Register / Vol. 57, No. 175 / Wednesday, September 9. 1992 / Proposed Rules 41355
SUMMARY OF INDUSTRIAL ACTIVITIES COVERED UNDER PHASE I OF THE STORM WATER PROGRAM—Continued
40CFR
122.26(b)(14)
Subpart
SIC 23—Apparel and other textile products.
SIC 2434—Wood kitchen cabinets.
SIC 25—Furniture and fixtures.
SIC 265—Paperboard containers and boxes.
SIC 267—Converted paper and paper board products (except containers and boxes).
SIC 27—Printing and publishing.
SIC 283—Drugs.
SIC 285—Paints, varnishes, lacquer, enamels.
SIC 30—Rubber and misc. plastics products.
SIC 31—(except 311)—Leather and leather products.
SIC 323—Products of purchased glass.
SIC 34 (except 3441)—Fabricated metal products.
SIC 35—Industrial machinery and equipment, except electrical.
SIC 36—Electronic and other electric equipment.
SIC 37 (except 373)—Transportation equipment.
SIC 38—Instruments and related products.
SIC 39—Miscellaneous manufacturing industries.
SIC 4221—Farm products warehousing and storage.
SIC 4222—Refrigerated warehousing and storage.
SIC 4225—General warehousing and storage.
1 On June 4, 1992 the United States Court of Appeals for the Ninth Circuit found that EPA's rational for exempting construction sites of less than five acres and
certain uncontaminated storm water discharges from category xi light industrial facilities from Phase I of the storm water program to be invalid and has remanded
these exemptions for further proceedings (see Natural Resources Defense Councils. EPA No. 91-70176).
Source: FEDERAL REGISTER, Vol. 55, No. 222, p. 48065, November 16, 1990.
2. Municipal Facilities
"Municipal separate storm sewer" is
defined as any conveyance or system of
conveyances that is owned or operated
by a State or local government entity
designed for collecting and conveying
storm water which is not part of a
Publicly Owned Treatment Works. The
application requirements do not apply to
discharges from combined sewers
(systems designed as both a sanitary
sewer and a storm sewer). Municipal
separate storm sewer systems that are
addressed by the November 16,1990
regulations include storm sewers
located in one of 173 cities with a
population of 100,000 or more; located in
one of the 47 counties identified by EPA
as having large populations in
unincorporated, urbanized areas; and
systems that are designated by the
Director based on consideration of the
location of the discharge with respect to
waters of the United States, the size of
the discharge, the quantity and nature of
the pollutants discharged to waters of
the United States, and other relevant
factors. These are named in Appendices
F-L of the November 16,1990,
regulation.
INDUSTRIAL AND MUNICIPAL PERMIT APPLICATION DEADLINES
Type of Application
• Individual
• Group
All industrial activities except those owned or operated by a municipality with a
population of less than 250,000..
Industrial activities owned or operated by a municipality with a population of
100.000 to 250.000..
• General Permit NOI
Large Municipalities
Medium Municipalities
Deadline
October 1, 1992
Part 1
September 30, 1991
May 18, 1992
Part 2
October 1 1992
May 17 1993
Deadline established in the general permit, but no later than October 1, 1992
for existing sources.
Part 1
November 18 1991 Novern
May 18 1992 May 17
Part 2
ber 16, 1992
', 1993
Appendix B. Potential Universe of Phase
II Dischargers
Phase II potentially includes all point
source discharges of storm water to
waters of the United States (including
Municipal Separate Storm Sewer
Systems) that are not regulated under
Phase I of the storm water program (See
Appendix A). The following table
illustrates those types of operations
which have been statutorily exempted
from both Phase I and Phase II of the '
NPDES storm water program along with
a general list of potential Phase II
sources:
Statutory / Regulatory exemptions:
General categories of sources..
• Non Point Source Silviculture Activities.
• Agricultural Runoff and Irrigation Return Flows.
• Uncontaminated discharges from Mining, Oil and Gas Operations.
• All municipalities with populations less than 100,000.
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41356 Federal Register / Vol. 57, No. 175 / Wednesday, September 9, 1992 / Proposed Rules
• All industrial activities not regulated under Phase I (including those owned/operated by
municipalities under 100,000) (tank farms, "auxiliary facilities").
• Commercial activities with industrial components (gas stations, dry cleaners).
• Construction activities involving less than 5 acres '•
• Large parking lots (shopping malls, stadiums).
• Residential property.
• Recreational areas (ski areas, golf courses, amusement parks).
• Livestock facilities (stables, feedlots not addressed by Phase I regulations 2, etc.).
• Greenhouses, nurseries.
'On June 4,1992 the United States Court of Appeals for the Ninth Circuit found that EPA's rational for exempting construction sites of less than five acres from
Phase I of the storm water program to be invalid and has remanded the exemption for further proceedings (see Natural Resources Defense Council v. EPA No.
91-70176).
'Feedlots, as a class of facilities, have been associated with high loadings of pollutants such as suspended solids, BOD, and nutrients such as nitrogen and
phosphorus, and could be an example of a targeting approach based on high loadings.
[FR Doc. 92-21653 Filed 9-8-92; 8:45 am]
BILLING CODE 656O-50-M
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APPENDIX I
REPORT ON THE EPA STORM WATER MANAGEMENT PROGRAM
(RENSSELAERVILLE STUDY)
-------
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United States
Environmental Protection
Agency
EPA830-R-92-001
October 1992
Report on
The EPA Storm Water Management Program
Conducted for the U.S. EPA Office of Wastewater Enforcement and Compliance
by The Rensselaerville Institute
Volume 1
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For additional information, please contact:
The Rensselaerville Institute
Pond Hill Road
Rensselaerville NY 12147
(518) 797-3783
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Report on
The EPA Storm Water
Management Program
Conducted for the U.S. EPA Office of
Wastewater Enforcement and Compliance
by The Rensselaerville Institute
Volume I
Final Report Submitted: October 1992
EPA Report # 830-R-92-001
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ACKNOWLEDGEMENTS
We are most grateful for direction and guidance for this project provided by the Office of
Wastewater Enforcement and Compliance, Michael B. Cook, Director; James Home,
Project Officer.
We also acknowledge the efforts of those persons who participated in the focus groups,
the expert surveys, the public forums, and the "design team" session. The thoughtfulness
of opinions and insights voiced is impressive.
We are encouraged by the willingness of people with very different perspectives to not
only listen carefully to each other but to seek common ground. The prospects for
collaborative work are strong.
Mary E. Marsters
Harold S. Williams
The Rensselaerville Institute
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TABLE OF CONTENTS
Executive Summary
Page No.
1
Part I: Improving Phase I of the Storm Water Program
Focus Groups
Description
Findings
11
12
13
Part II: Designing Phase II of the Storm Water Program
Expert Survey
Description
Survey Findings
Nonpoint Source Perspectives
Public Meetings
Description
Meeting Findings
Reflections on Meeting Format
Design Team Session
Description
Session Findings
Additional Advice
27
28
28
32
34
35
38
40
41
48
General Recommendations
49
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EXECUTIVE SUMMARY
In December 1991, the Deputy Administrator of the U.S. Environmental Protection Agency
(EPA) asked the Office of Water to undertake a research project with two objectives: 1)
identify ways to improve and streamline the existing storm water regulatory program
implemented by the agency under Section 402 (p) (2) of the Clean Water Act; and 2)
define and annotate options for controlling sources of storm water runoff designed for
Phase II of this same section.
In response to this request, the Office of Wastewater Enforcement and Compliance
(OWEC) engaged The Rensselaerville Institute to develop a two-part project to gather and
integrate diverse opinion and insight on ways to improve the efficiency and effectiveness
of the existing Phase I program and the best possible response for the Phase II program
designed to cover remaining storm water sources and problems.
Part I of the project was conducted during February and March, 1992 when six focus
groups were held around the U.S. to gain user feedback on how the current regulations
and implementation procedures could be improved and streamlined. These groups,
which included representation by both public- and private-sector permittees as well as
regulatory agencies, private consulting firms, industry, and environmental interests,
identified numerous ways EPA and others could address permitting and compliance
procedures seen as difficult or problematic.
Part II of the project began with an Expert Survey of 32 persons highly knowledgeable in
storm water and its control who represented different perspectives (academic/research,
state/local government, commercial development, environmental advocacy, and
consultant/engineering) and different geographic areas. Experts were asked to respond
to a set of options for targeting and controlling sources and to suggest additional
alternatives as well. Insights on voluntary measures that have proven effective in storm
water control were solicited through a separate survey of five experts in nonpoint
program approaches.
Based on the results of these surveys, three public meetings were announced in the
Federal Register and held in Denver, San Francisco and Washington, DC during June,
1992. Those attending were divided into teams and asked to define their own preferred
strategies for a Phase II program response, including definition of sources to be
regulated, the preferred method of control (permit-based or other) and their sense of both
timetable and the role EPA should play.
Finally, a small group of insightful individuals representing diverse viewpoints from both
point source and nonpoint source programs was convened for a strategy design meeting
for the purpose of adding greater depth and breadth to one or more Phase II approaches
identified in the public meetings. From this group, a ten-point strategy was created, as
well as a series of recommendations to EPA on developing the second phase of the
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storm water program.
This Executive Summary presents the findings from each of these activities in summary
form. More complete recommendations are contained in the body of Volume i. Tiu
project data base is contained in Volume II.
1C.
Summary of Findings on Improving Phase I of the Storm Water Program
Forty individuals participated in focus groups held in Atlanta, GA; Hartford, CT; Chicago.
IL; Washington, DC; Seattle, WA; and Phoenix, AZ. Together, the participants included
all identified viewpoints and separable interests-including EPA regional staff, state and
local government officials, engineering consultants, environmental advocates, and
representatives of corporations included in Phase I permitting.
Participants responded to a set of questions which probed for opinion and insight on
such matters as the unclear aspects of the Phase I regulations, additional steps that
should be taken to simplify the process and help permittees to achieve compliance, and
the relative merits of individual and group permits. In addition to participant responses
to core questions, the afternoon of each session was used to further elaborate problems
and solutions of interest to participants in an informative format.
While many issues raised were location- or source-specific, some spanned geographic
and demographic boundaries. Eight issues common across all focus groups were
identified as key areas to be clarified and/or modified to improve program implementation:
1. EPA has not been clear about the intended goals of the regulations. A
stronger sense of the relative importance of storm water in the framework
of environmental risk is needed, as is clarity about short range and long
term targets. There is a difference, for example between clean water
standards and stream health standards. It is clear that there are storm
water permits. It is not clear how the permits reflect a coherent program.
2. The expense of program implementation is significantly higher than EPA has
estimated. There is great concern over what the program's real costs have
been in terms of dollars and manpower costs of preparing a permit
application, and the anticipated costs of achieving compliance. A broader
concern: municipalities now beleaguered by resource shortfalls cannot
reasonably afford the combined costs of compliance with all environmental
regulations.
3. The administrative complexity of the program is enormous at the federal,
state and local levels, and has quickly outpaced the availability of resources
and manpower needed to carry it out. In some cases, field staff have been
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pulled in simply to process the paperwork involved.
4. Clarification is needed on the roles and expectations EPA has for itself,
states and permittees. What js clear to everyone is that EPA does not have
the capacity to administer and enforce the program alone. This cannot be
seen as an EPA program administered in a "command and control" style
totally from Washington. It must involve active participation, not simply
passive compliance, from all levels involved.
5. More technical support for the program is needed. Expanded information
explaining the regulations and how to implement them is especially needed.
Also, there should be less "national level" support and more focus on
regional conditions. Much of the content of storm water workshops held at
EPA headquarters is irrelevant to any given participant.
6. States need EPA to either clarify how to interpret unclear points of the
regulations, or allow them the latitude to make the interpretations
themselves. One unclear area is the inconsistencies and inequalities
created by use of industrial SIC codes in such areas as transportation.
Another murky area is the group application process.
7. EPA should consider consolidating programs in order to address water
pollution in an efficient and cost-effective manner. A watershed approach
is preferable to current practices of separating problems by media.
8. General permits are "the way to go" and EPA should continue to focus on
and accelerate efforts in this direction.
Many focus group members made a point of indicating their pleasure with the focus
group format used and the ways in which EPA had 1) encouraged interaction and
customer insight and 2) listened carefully to their advice. A complete report on focus
group responses and conclusions is contained in the body of this publication.
Summary of Findings on Designing Phase II of the Storm Water Program
Expert Survey
The second part of the Rensselaerville project began with a survey of a select group of
32 point source storm water program experts from across the country. The purpose was
to solicit opinions on ways to implement the second phase of the storm water program.
Five perspectives were represented: academic/research; commercial development;
consultant engineering/legal; environmental advocacy; and state/local government. A
first mail-back survey round gained opinion and consensus on relevant issues and
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options for addressing Phase II sources. Data from the first set of returned surveys were
analyzed and given back to participants in a second survey round, which refined positions
and created more options for Phase II consideration.
To ensure inclusion of all critical perspectives, five nonpoint source program experts were
asked to provide feedback, with emphasis on potential voluntary approaches for
addressing Phase II sources.
While approaches recommended differed by profession and geography, these common
targeting themes emerged for identifying whom to include in Phase II:
• develop a geographically-based phasing plan by watershed
impairment/severity of threat;
• determine selection criteria for pollution sources and use these to identify
municipalities that should participate;
• do pilot projects first, evaluate, and then develop and implement a strategy;
• encourage and fund comprehensive basin research and planning to guide
targeting;
• require Phase II industries to be covered under Phase I general permits;
• develop national guidelines, and leave selection of sites and methods to
state discretion;
• require smaller communities (< 100,000) to apply for permits only when their
storm water contributes a significant pollution problem;
• designate problem areas, establish permit requirements for municipals
regardless of population, and allow municipals to exclusively regulate
industries; and
• initiate a focused dialogue with key stakeholders (applies to both targeting
and controls).
Common themes expressed for control strategies included:
• build a Best Management Practices (BMPs) menu that can be used by
states to implement and verify progress;
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• require localities to select from a list of BMPs the ones most appropriate for
their needs and apply industry-specific BMPs nationwide with allowance for
state/local officials to modify;
• provide nationwide public education and community-wide public education
on the need for storm water control;
• establish national or industry-specific minimum practices for controlling
storm water;
• implement good housekeeping and source reduction practices;
• require routine certification and audit of storm water pollution plans and
practices;
• establish industry-specific arid watershed-specific BMPs; and
• establish BMPs required nationwide and strictly enforce. Require facilities
to further treat storm water discharges where BMPs are not effective.
The strongest additional factor in nonpoint survey responses was the degree of emphasis
placed on education at all levels, including the general public, local and state officials, and
local businesses and industry. Education was seen as the key to making voluntary
approaches effective. Voluntary compliance, in turn, was then advanced as highly cost
effective.
Respondents feel that EPA must be the "stick" that would fall-with permit requirements,
fines, etc.~if a storm water source does not voluntarily take action and achieve certain
minimum goals. But limited manpower and financial resources form a rationale for not
addressing Phase II with the costly conventional federal mandates of Phase I.
Public Meetings
Three meetings were conducted to gain public responses to options for targeting and
controlling Phase II sources. They were held in Denver, CO; San Francisco, CA; and
Washington, DC during June, 1992. At each meeting, three experts selected from the
Expert Survey process presented their ideas on a regulating strategy for the moratorium
sources. Participants were then divided into small task teams, and given the charge of
devising their own strategies for targeting and controlling Phase II sources. A strategy
template was provided to guide group consideration of three key issues: 1) who should
be covered under Phase II; 2) what controls are needed; 3) over what timeframe the
program should be implemented. At the end of each public meeting, the task teams
presented their options to other participants for discussion.
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Common strategy characteristics emerged, in many cases paralleling those apparent in
the expert survey. For targeting:
O Targeting should be done by watershed. Information gathered from Phase
I should help identify sensitive watersheds. This may require
intergovernmental agreements.
O The focus should be on "bad actors", i.e., those that are known problem
sources. The ones most frequently identified were: gas/auto service
industries, transportation, highway systems, land use development and
agricultural sources. There needs to be the ability for facilities not
contributing impairment of water to gain an exemption from permits, fees,
implementation of BMPs. Categories are an ineffective way to designate
covered sources - should be done by the degree of risk a given facility
poses, because it may not be a whole industry, but rather individual
facilities.
O Small municipalities should be included, but they should have a much
simpler application process. Or, only small municipalities where a storm
water problem is identified should there be required action.
O EPA should defer on selecting targeted sources until the agency has
carefully looked at the data gathered during Phase I. Numerous sources
of information are available which would help determine targeting priorities,
e.g., information gathered through 305b reports, information from Phase I
program sources, the NURP study.
For needed and desirable controls, these themes emerged:
D if a permitting process is to be continued for point sources, NPDES general
permits should be used, and focus should be on implementing Best
Management Practices (BMPs). Permits should be simpler, and much less
costly. EPA should make clearer to the applicant what information is
required, e.g. provide the permittee with a "checklist of inclusions" for the
application, develop a menu of BMPs. Permit exemptions should be
granted to those targeted sources who offer no contribution to the problem.
D Education should be seen not as an "add-on", but rather as a primary tool
for effective control. Locally implemented education for public and industry
is especially important; the premise is that information and conviction born
of education will encourage many to take the needed preventive and
remedial steps.
D More emphasis should be placed on voluntary programs, e.g., 319 nonpoint
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source-like programs. For facilities with contact with storm water, there
should be little or no government intervention, but rather emphasis on
pollution prevention incentives. BMPs, and measures of pollution prevention.
Pollution prevention programs should be emphasized, particularly with new
development. Some suggested prevention methods included: recycling
storm water, "good housekeeping" practices, plantings to minimize runoff,
street sweeping of work areas on a daily basis, storm water collection
methods, coverage of storage areas, changing manufacturing processes to
minimize pollutants, and improvement of air emissions.
D Closer correlation should exist between the severity of the problem and the
degree of controls required. Fines and fee structures could be used as
"carrot-stick" measures.
n BMPs should be required based upon the specific pollutant problem. EPA
should develop a menu of BMPs to assist businesses in determining the
appropriate BMP for their problem.
In terms of a timetable for phasing in Phase II, two widespread opinions emerged:
0 A minimum of two years is needed to prepare for Phase II, with at least a
year dedicated to looking at data gained from Phase I of the storm water
program. Effectiveness of presently used BMPs needs to be studied to
determine differences in effectiveness between geographic locations and
pollutants.
0 Whatever the period established for phase-in, it should not begin until
promulgation of the regulations.
A final question in the strategy template: "For whatever strategy is chosen, what could
EPA do to make the decision-making process for Phase II more responsive?"
generated responses focused on some common themes:
£ Coordinate information dissemination, e.g., set up regional clearinghouses
offering such program information as general permit writing, effective
applications of BMPs, and examples of successful efforts from programs
around the country.
£i Provide funding not for program implementation but for needed research,
e.g., on BMP effectiveness, and for demonstration projects.
D Set broad guidelines for the program and establish minimum standards, and
then allow state and local regulatory agencies determine how to achieve
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them.
6 Develop and implement training programs for regulators, including regional
and state, on the program. These people are the ones who will be the
informational source for the regulated community, and need to know the
details of the program.
As with the focus groups the participants in the public meetings felt positive about the
format used. A mail-back survey returned by more than 30% of meeting participants
showed that they strongly favored this interactive process over what they perceived as
the conventional practice of a stream of public comments that encouraged adversarial
positioning and boredom for those listening. Comments of attendees included:
o The opportunity to formulate an entire strategy to deal with this issue was
very useful;"
o "I obtained a better point of view of government's problems and felt that
government representatives also obtained a better point of view of
industry's problems;"
o "Result was a much less confrontational and much more problem-solving
atmosphere;" and
o "It was a valuable way to address drafting of regulations, allowing the
regulated community to feel a part of the process."
The body of this report contains a further elaboration of the process and the ways in
which it might be used by the EPA in other communication and outreach efforts.
Design Team Meeting
A meeting of seven point and non-point storm water program experts, all of whom were
survey respondents, and selected EPA staff was convened in Washington DC on
September 17-18, 1992. The purpose was to gain the experts' varied insights on
development of the Phase II storm water program and to build a strategy, or multiple
strategies, for addressing Phase II sources.
Many discussions were specific to certain types of acth/ity-not only municipal or industrial,
but to specific kinds and levels of enterprise. Others focused on regional differences-tor
example the strong distinctions from places that are uniformly wet, uniformly dry, or highly
volatile in hydrological terms. Still others found differentiation in scale-such as the
difference in impact a regulation would have on a city as compared to a small town.
These distinct findings are contained in the full report which follows in this volume.
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A broader set of ten recommendations emerged for the major Phase II challenge which
generally transcend such differences. They include:
1. It is possible and desirable to identify priority target areas for which
there is widespread consensus concerning their contribution to water
pollution. These areas begin with new development and redevelopment-
both residential and commercial. They also include transportation corridors,
dense existing development and automotive services.
2. EPA needs to communicate more clearly and regularly with everyone
impacted by the storm water regulations. The priority focus should be
less on the amount of communication and more on different kinds of
communication.
3. EPA could improve program effectiveness, efficiency and cost control
in Phase II by "starting small". The concept of regional and even local
prototypes is a way of getting proposed new Phase II frameworks into the
hands of users in prompt fashion to build and refine based on early use.
4. Selectivity in data collection and monitoring is essential. At present,
some data collection frameworks consume tremendous time and money
only to yield bad or useless data or murky or disputed conclusions. At other
times, very simple actions taken with known consequences require simple
verification, not extensive measuring.
5. More customer differentiation is also needed. At present the mind-set
appears to be that one size fits all. While giving the appearance of equity,
this concept actually creates strong inequalities. The same programs and
regulations that befit a large corporation or municipality are simply not
equitable for smaller enterprise and communities, for example.
6. While the ultimate goal is water quality standards, this is very difficult
to achieve and/or to measure in the short term. Therefore, while
retaining water quality standards as the ultimate goal, EPA should be
focusing on best management practices, and in particular those that reflect
preventive and non-structural solutions.
7. The most functional unit of both analysis and intervention is the
watershed. Most people in our samples for opinion and recommendation
strongly suggested the watershed approach-not only on the macro level
(e.g., Chesapeake Bay) but the micro-level as well.
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8. EPA's role is to offer technical support and direction more than
program funding or even full guidelines for state and local
implementation. In particular, building useful data bases and collection
methodologies not only on water quality but on practices to achieve it is
critical. Such practices should include education, given that prevention and
voluntary compliance are much less costly than litigation.
9. A collaborative approach to developing effective solutions is possible.
The interactive elements of this project are one reflection of the ability of
those with strikingly different perspectives (ranging from strong
environmental protection to a focus on economic development) to work
cooperatively.
10. Agriculture's absence from the storm water program is notable and
regrettable. In many regions, agriculture (which includes livestock as well
as crops) is a primary contributor to surface water pollution. Permitting or
in other ways controlling the transport of agricultural products introduces
intervention too late.
The remainder of Volume I amplifies these findings and presents the rationales and key
data points which underlie them. Volume II includes the complete data base, including
all instruments used to collect and analyze information.
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PART I: IMPROVING PHASE I OF THE STORM WATER PROGRAM
In December, 1991, the Deputy Administrator of the U.S. Environmental Protection
Agency asked the Office of Water to undertake a project that would achieve two results:
first, identify ways to improve and streamline the existing storm water regulatory program
currently being implemented by the agency; and second, develop options for controlling
sources of storm water runoff not currently required to be permitted under Section
402(p)(2) of the Clean Water Act.
In response to this request, the Office of Wastewater Enforcement and Compliance
(OWEC), working with The Rensselaerville Institute, developed a two-part project. This
section addresses the outcomes from Part I, which focused on identifying improvements
to the existing regulatory program.
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Description
As the first part of The Rensselaerville Institute's project to help EPA assess the
effectiveness and efficiency of the existing Storm Water Program, focus groups were held
in diverse regions of the country to gain feedback on how the regulations promulgated
on November 16, 1990 could be streamlined and improved. Six such meetings
comprising representatives from state, municipal, private industrial and environmental
groups were conducted between February 24 - March 2, 1992.
A total of 40 individuals participated in the focus groups, which were held in Atlanta, GA;
Hartford, CT; Chicago, IL; Washington, DC; Seattle, WA; and Phoenix, AZ. The format
for each meeting was the same: participants provided feedback on eleven questions
developed by EPA and Institute staff. The questions:
1. Which aspects of the storm water regulations are least clear?
2. What additional steps would be helpful in assisting permittees achieve
compliance in the allotted timeframe? Who should take those steps?
3. Exactly what kinds of guidance and information are needed to help people
implement the program? How would you prioritize these listed storm water
program activities in terms of their usefulness?
Is there a need for EPA to do more national workshops on the storm water
regulations? What about regional or local workshops? On which subjects?
What support should states, as opposed to EPA or other organizations, be
expected to provide to their "universe" of permittees? What resources do
they need in order to provide those supports?
If you had to name three ways to streamline the permitting process, what
would they be?
What could EPA do to encourage those states without general permit
authority to get it? What steps are needed to get general permits out?
What simple, short-term grassroots efforts can associations and trade
groups take to help this effort, and how could EPA support those efforts?
8. What outreach efforts to explain to permittees what they have to do to
comply with the regulations have been most effective to date? Are there
informational pieces that EPA could prepare that would best help these
efforts?
4.
5.
6.
7.
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9. What are the techniques, methods or strategies you would recommend to
help permittees achieve water quality standards? In what timeframe should
permittees be required to comply with WQS?
10. Given that construction activities are most often local in nature and
temporary in duration, do you have suggestions about how EPA could more
effectively regulate such activities?
11. What suggestions would you offer in terms of the most efficient way to
enforce EPA existing regulation requirements, both application requirements
and substantive permitting requirements?
Responses to question #6 were revisited in the afternoon of each session, when
participants were asked to further define their recommendations, indicate who they felt
should be responsible for initiating the changes, and list the initial steps they would take.
Response summaries were drafted following each meeting and sent to participants for
additions and modifications. Their changes were incorporated into their respective
reports. This overall report summarizes, interprets, and analyzes group discussions and
conclusions.
Focus Group Findings
Despite the many issues surrounding implementation of the regulations, the consensus
of all focus groups, including industrial representatives, was that storm water control is
needed and appropriate. There was general agreement that storm water is a significant
contributor to water pollution. Some felt that a regulatory program was appropriate to
address the problem. A number of participants expressed that, overall, the storm water
program is significantly more rational and easier to deal with than other EPA water
programs, for example, the wetlands program.
Yet the storm water regulations still inspire much confusion and frustration. There is
frustration with EPA, as well. Many felt there was a lack of consideration given to their
inputs by the agency prior to promulgation of the regulations, and some thought that EPA
had been unresponsive to questions and concerns voiced since the regulations went into
effect. When pressed, however, most admitted that they perceived this to be an endemic
or generic problem of government. For a few, this perception will not be changed.
However, most were impressed that EPA was now willing to actually look at the storm
water program and solicit input from those dealing with the regulations on how they
could be improved or streamlined.
Reservation was voiced, however, that EPA would do nothing with the recommendations
generated from these focus groups. Their concern was that the results would have as
little impact on EPA's decision-making and responsiveness as had previous efforts to
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1.
make their opinions known.
It is critical, therefore, that EPA identify those procedural changes made in response to
the recommendations, and make them known both to focus group participants specifically
and to the permitted and regulatory communities in general.
The range of concerns voiced was large, and differed between geographic regions and
the representational make-up of the group. Each group raised issues that were quite
specific to themselves or their region, e.g., New York City was concerned about the
effects of tidal flow and backwater as they relate to water quality; Utah and other arid and
semi-arid states were concerned about sampling procedures when there was scarce
rainfall; Seattle felt that the regulations did not allow its storm water program to build on
earlier work; general contractors do not understand why concrete mixing requires a
separate permit even though it is done on the construction site, etc. The specificity of
concerns for each group is reflected in the individual summary reports, which are included
in Volume II.
Some issues and concerns identified, however, spanned geographic and demographic
boundaries. They were raised across groups as key areas in need of clarification and/or
modification. There were seven broad areas identified where members felt efforts should
be made to improve and streamline the storm water regulations.
Permittees and regulatory agencies feel that the EPA has not been clear
about the intended goals of the regulations. A view of the "bigger picture"
is wanted.
While group members agree that storm water is a contributory factor to water
pollution, there does not seem to be an understanding of what EPA hopes to
achieve with the regulations promulgated in November 1990. A frequently heard
comment was that "the big picture" is missing. Participants felt that EPA has not
been clear about how these regulations will accomplish the goal of achieving clean
water, and in what timeframe. This has hampered efforts to comply because many
do not understand what they should be setting as performance targets.
One participant said, "What j§ a clean urban stream?" The point: participants were
not sure what goals they need to attain to comply with the regulations and protect
themselves from being sued or fined for non-attainment. Almost all participants felt
that water quality standards were useful as the ultimate goal toward which to work,
but were unachievable in a two- or three-year period. When asked what they felt
would be a reasonable timeframe, estimates ranged from five to thirty years, with
a few participants indicating that, given the large number of pollutant sources
impacting on a given water body, achievement of water quality standards through
the storm water program alone is a strong improbability. One participant stated
that the scientific community's perspective is, "...there is no way water quality
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2.
standards can be achieved with known storm water technologies"; it will take
further research and development of BMPs before water quality standards could
be achieved.
It was clear that members need more guidance about where the program is
headed. Participants want EPA to be more explicit about what should be achieved
in terms of improvement of water quality in the timeframes that have been given
and with the technologies that are presently available.
Group members were aware that environmental advocacy groups will bring
pressure on EPA to hold to established numerical water quality standards, and that
reducing or replacing them is not likely a viable option. As one representative from
an environmental advocacy organization stated regarding water quality standards,
"...(they are) the heart of the Clean Water Act." Participants felt, however, that
EPA needs to explicitly acknowledge that cleaning up the waters of the U.S. is a
long-term effort that requires federal, state and local governments to work in
partnership with permittees rather than through "command and control"
relationships. Permittees fear being sued for non-compliance when in fact they are
making the best efforts possible.
Permittees and regulatory agencies want EPA to provide them the time and
support they need to design and implement storm water programs that make
sense in terms of effectiveness and cost. They feel that EPA, by not clearly stating
goals, has hampered efforts to deal with the problem; permittees are not sure
which approaches to take because they don't know what they have to achieve.
They want the guidance and information necessary to implement the most
appropriate measures available for their discharges, and the time to evaluate those
efforts. As one group member observed, "...What is needed is a longer period
(than the permit period) to do BMPs - and then monitor their effectiveness. Where
necessary, go back and change things. It's an evolutionary process. This is not
a quick tech fix! EPA is creating more problems than answers. October 1 should
not be 1992, it should be 1995."
If EPA is to achieve success with the program, it needs to address confusion over
program goals and timeframes. The agency needs to be explicit about what it
expects industrial and municipal permittees to accomplish in the first permit period,
what they expect them to achieve in the longer term, and what they anticipate the
impact of the storm water program to be on overall water quality.
The cost of program implementation is significantly higher than EPA
estimates. There is great concern over what the program's rea] costs have
been in terms of dollars and manpower.
A great concern of focus group members was the excessive cost of preparing a
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permit application, and the anticipated costs of achieving compliance. A number
of state representatives indicated that implementation of their state program took,
in terms of staff time alone, more than all other water programs combined - without
the concomitant added federal dollars that those programs provided. That EPA
has provided minimum federal dollars for the program is a major issue.
Municipalities and industries were concerned with the significant additional costs
of manpower and technology needed for both application and compliance. One
focus group participant brought for discussion a study done by the School of
Public and Environmental Affairs at Indiana University. The study has identified that
the actual mean cost for Part 1 of the municipal application process for 59 cities
exceeded by six times the EPA-estimated costs of the program [Gebhardt &
Lindsey (1992), "NPDES Requirements for Municipal Separate Storm Sewer
Systems: Costs and Concerns"].
That EPA has set aside some monies to assist in program development is not
commonly known information. There was confusion among a number of focus
group members about the availability and applicability of grant monies, e.g. 104(b)
funds, that §re_ dedicated to implementation of the program. For example, within
the same focus group, one person said that they had applied for and received the
funds to help prepare their application; another member replied that they were told
that the monies could not be used for that purpose. Members of some groups
were unaware that the funds were available at all. This indicates that
communication from EPA has been inadequate in letting eligible groups know that
there are some, albeit limited, dollars available to help them in setting up their
programs, and that there has been inconsistent communication about the
guidelines for use of those funds. Further, every person who indicated knowledge
of the money also noted that the funds available were minuscule in comparison to
what was needed to actually get their programs up and running.
Some states have developed the necessary revenue-gathering mechanisms to fund
their storm water program. One state representative indicated that, by charging
permit fees, they have been able to hire six staff people for the program. A few
other state representatives indicated that storm water utilities had been successful
in helping to raise the funds necessary for program operations. A significant
number, however, contend that their state does not have the funds to implement
the program, nor do they have a system devised to raise these funds. Therefore,
wholehearted efforts are not being made to respond to the regulations. Further,
some states have implied that they do not consider storm water a priority, and
therefore are not willing to devote any portion of their budget to the program. This
latter point creates a significant problem for the thousands of permittees in such
a state that are then without a critical support system to provide them guidance
and technical assistance.
The storm water field in general is perplexed that EPA could promulgate these
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regulations, without at least providing "seed monies" to assist the application
process and help states set up their own revenue-generating systems. To some.
the message EPA sent by not providing funds is that the agency itself is not
invested in the program. If EPA plans to continue to regulate storm water without
providing financial assistance, one way it could assist permittees is to provide
guidance and examples of successful fund raising systems that some states have
devised, e.g., storm water utilities.
3. The administration of the program is enormous. Clarification is needed on
the roles and expectations EPA has for itself, states and permittees.
Much of the controversy surrounding the regulations arises from unclear
delineation of the roles, responsibilities and authority of each level. What is clear
to everyone is that EPA alone does not have the capacity to administer and
enforce the program. Therefore, much responsibility must fall on state and
municipal levels. However, the regulations do not delineate the responsibilities of
each level. Group members were clear that they want EPA to be more decisive
and explicit about what js expected of states and municipalities in terms of
administration and enforcement, and the areas where they will be allowed authority
and flexibility in decision-making.
Some state and local governments have not waited for EPA to define their roles.
The regulatory deadlines were powerful motivators for them to move forward
without such guidance. Thus, frequently heard was states' hesitancy to discuss
with EPA what they were doing programmatically, because they were afraid they
might not be doing it "right", i.e. in accord with what EPA wants done. They were
concerned about asking EPA for clarity they feared the agency might take awav
their assumed authority since it had not been specifically assigned in the first
place. A number of state representatives admitted that they interpret the
regulations in their own way rather than wait for EPA to provide interpretation. As
one state representative put it, "...we looked at the regs as guidance rather than
rules. We do it our own way. We are not sure if it is appropriate, (so) I have
concerns asking for guidance from EPA because they may take away our latitude
to make our own judgments."
The vagueness in assignment of responsibility and authority has clearly hampered
program implementation. It may have been the intention of EPA to be less specific
so that other entities would make their own interpretations, but they clearly do not
feel comfortable assuming responsibility or authority. Many have been frustrated
by the agency's lack of response when trying to gain clarity of the regulations.
For example, one trade association representative stated that, in order to inform
his membership about the regulations, he wanted to publish in their trade
newsletter an article that outlined their members' responsibilities under them. To
ensure that his interpretation was in accord with EPA's, he submitted the article to
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4.
EPA for review. In his words, "I waited a month, and when EPA did not respond,
I went ahead and printed it. They [EPA] didn't like that."
Some state representatives said that they were unwilling to help industrial people
make decisions on whether they are covered by the regulations, because they do
not want to be held accountable when EPA has not specifically given states the
authority to make interpretations of the SIC codes. Participants felt that the states
are more likely than EPA to know the specifics of the industries in their boundaries,
and also to know which ones are high-risk pollutant sources. But states do not
feel that EPA has given them the authority to use that knowledge to make their
own judgments on whether an industry is covered or not.
Industries also feel unsure about their responsibilities under the regulations, and
are turning to the states for guidance. The regulations are unclear, for example,
about what level of program implementation is expected in a given timeframe. As
one state representative put it, "...there needs to be some guidance from EPA to
the states on what (industries) need to do!"
States feel they have more knowledge of the industrial risks within their boundaries,
and know what is needed to bring those risks into compliance. A number of focus
group members cited the uselessness of having EPA develop requirements and
guidance for soy. given industry when it did not understand specific industries.
They felt it far more effective for EPA to work with industrial representatives when
developing materials to ensure clarity and correctness. This would likely create the
added benefit of gaining industry's commitment to achieving certain results.
Given the magnitude of these regulations, the lack of funding available to support
implementation, the fiscal constraints under which all levels of government are
operating, and the limited staff at each level, working in partnership with states and
permittees rather than through a "command and control" relationship could get the
program in place more quickly and maximize its effectiveness. EPA needs to
determine each government level's responsibilities, be explicit about what decisions
and flexibility can be allowed, and be clear about what results are expected from
each level of government if given the authority to interpret certain aspects of the
regulations.
More supporting information for the program is needed, and dissemination
of that information needs to be improved.
Information supplementary to the regulations, explaining them and providing
explicit information on how to implement them, was cited as a critical need that had
only partially been met. All focus group members gave feedback on those pieces
of EPA-generated information they thought was useful, what they felt was not
helpful, and what other information they desired or felt was needed. They also
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addressed the regulations themselves as a source of information.
a. Written Documents
Written information EPA has provided to supplement the regulations, such as
guidance documents and supportive materials, received overall good reviews.
Numerous participants stated that both the Industrial and Municipal Permit
Application Guidances were helpful.
The primary problem with much of the written guidance and information is that it
is coming out too late to be useful. A number of participants indicated that a
model general permit would have been helpful, but that they were at the point of
writing their own, so for them it was too late. Often group members' suggestions
for specific informational documents were accompanied by the caveat that it was
needed now, e.g., permit writers guidance; Model Permits for MS4s; a BMP
manual; Construction Activity Guidance.
Not everyone wants to receive new information at this point in the program. A
number of participants said, "Don't do anything...We have a track: anything that
would confuse that would be a problem. Even clarification. We have an idea for
what we want to do and if guidance comes out now, it might conflict with what we
want to do."
One person commented that EPA should prepare guidance documents so that
they can be released concurrently with promulgation of the regulations. This would
avoid not having them ready in a useful timeframe. A number of participants felt
that EPA should be more willing to release information in draft form if the final
document is going to be late. EPA should make preparing information for Phase
II of the program a priority; the timeliness of delivery is a reflection of the
program's credibility and of EPA's commitment to the program. It is clear that
those who have gone forth without the support of written guidance are going to
be highly resistant to any input by EPA that would require them to modify what
has already been done.
Dissemination of EPA documents has been inconsistent. Regions vary in their
thoroughness of distribution. One group member said, "...EPA needs to be better
at getting this stuff to us. I often have somebody walk into the office with
something that has been out for three months that I have not seen." This
frustration was echoed in a number of the focus groups. EPA needs to publish a
list of available documents which people can request either in writing or through
the Hotline.
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b. Verbal Communications
The Storm Water Hotline received mixed reviews from group members. The
primary response was that it effectively addressed very basic questions, but that
the program had advanced quickly to the point where more technical information
was needed. Trust in the ability of those answering the phones to address
complex issues was low. However, this is not an unusual response to Hotlines;
often callers complain that information given is inadequate, inconsistent, or not
appropriate to the situation of the caller.
Some focus group members stated they were pleased with the response they had
gotten from the Hotline. Some indicated that they were relieved just to have
someone to call for program information. Others felt it was a good way to confirm
their "hunches". Overall, given the size of the program and the number of phone
calls that have been received, the perception of the Hotline is relatively positive.
Some alternative roles were suggested for the Hotline. Members stated that it
could be used as an information clearinghouse, having available a list of sources
that callers could turn to for more technical information. One person suggested
that operators have lists of experts in categories to whom they could refer callers
for more information.
One frustration voiced was that reaching EPA staff people was a problem. This
has created for some the perception that EPA headquarters staff are
unapproachable. On the practical side, however, responding to all the phone calls
they receive would tie up all available staff for the duration of the program;
headquarters staff would do nothing but answer phone calls. Yet it is important
to recognize that this problem influences people's perception of EPA's commitment
to the program. Perhaps with EPA's attention to the more substantive items listed
in this report, e.g., getting documentation out in a more timely manner and with
more thorough dissemination, etc., this perception will self-correct.
c.
Workshops and Presentations
All groups felt that workshops of national scope were no longer needed, because
the issues being dealt with were now more technically specific to certain industries
or areas. The consensus was that state and local workshops, providing industry-
specific guidance and information on water pollution control, were most needed.
Most felt that such workshops should be sponsored and planned by trade
associations and other membership associations like APWA, WEF, ASIWPCA, etc.
rather than EPA. They did feel that EPA should be a speaker at the programs, and
be willing to help address the federal perspectives in response to local concerns.
A main concern of group members, from coast to coast, is reaching those
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industries who are covered by the regulations; many businesses covered under
the regulations do not know that they must apply for a permit. Trade associations
were recommended as one of the best ways to get to the harder-to-reach
permittees (usually referred to as "Mom-and-Pops"), but even they are limited to
those businesses who are members. Group members mentioned other avenues
through which they have tried to reach these businesses, such as direct mailings
to municipalities and working through Chambers of Commerce. None have been
completely effective. Most members said that this was not solely EPA's
responsibility, but also one of states, local governments and trade associations as
well. EPA could support this effort by suggesting methods for reaching these
businesses, and contacts at the national level that could be helpful, e.g., Small
Business Administration.
d. The Regulations as Information
The Federal Register notice of the regulations was considered by participants to
be a key source of information about the program. Numerous comments were
made about its inability to convey needed information clearly and concisely.
Length, layout, language and accessibility were identified as deterrents for many
"laypeople" to comprehend them.
One member said the length was approximately 127 pages too long; he felt it
should have been three pages, with a focus on what the regulations will do to
reduce water pollution. Many felt that the regulations were not user-friendly
because of the language used, which they referred to as "legalese". One person
remarked, 'What is needed is an English version of the regs!" The citations were
claimed to be confusing, and some felt substantive requirements were "buried" in
the wrong section, e.g., important permitted industrial activities were in the
Definitions section, and municipal requirements were scattered throughout rather
than placed in a "Municipals" section. Another noted that the three-column format
was difficult to read for most not used to the Federal Register format.
Many noted that the Federal Register is a publication that may be picked up by
some large businesses, but would rarely find its way into the smaller ones. Given
the widespread impact of the regulations, there is valid concern that EPA views the
Federal Register as a primary method to "get the word out." They felt this was not
a good assumption, since circulation of the Federal Register is very limited, leaving
the vast majority of those industries covered by the regulations unaware that they
are affected.
There is need for a more clearly stated version of the storm water regulations.
Trade associations have done a great deal to try to reduce the regulations to
laymen's terms for their members. But when supplemental guidance documents,
which are more reader-friendly than the regulations, are not quickly forthcoming
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and the regulations provide the only source of information, confusion is inevitable.
5. The regulations lack clarity on a number of key aspects. State authorities
need EPA to either clarify these points of the regulations, or they need EPA
to allow them the latitude to make the interpretations themselves.
During each focus group, members discussed many particular points of the
regulations that they had found unclear. These varied from group to group,
depending on the perspectives represented. As one would guess, points that to
a municipal person lacked clarity were often different than issues of concern to an
industrial representative. For example, industrial representatives spoke of confusion
with deadlines as a result of the Surface Transportation Act amendments, how to
pick the appropriate permit to apply for, and how industries connected to municipal
sewer systems should deal with the regulations. Municipal representatives, on the
other hand, mentioned specific sampling and field screening methods, the
definition of Maximum Extent Practicable, what to do about application sampling
requirements in the face of drought conditions, and how to classify industrial parks
as issues that lacked clarity. Further, participants felt there were some aspects
where there was room for interpretation. Important to them was knowing where
they would have latitude to make interpretations.
Presented here are the areas commonly identified as in need of clarification by
EPA.
a. Who is covered under the industrial SIC codes:
Every group questioned EPA's use of the Standard Industrial Classification
codes to determine which industries should be included under the
regulations. The consensus was that these codes, which are economic
indicators, are inappropriate for regulations that deal with environmental
issues. Their use has caused a great deal of confusion as various
industries try to apply them to their "primary" activities. Businesses don't
know how to use them to determine if they are included under the
regulations - and regulatory agencies are very reluctant to make that call for
them given the "downside" of either decision. Group members indicated
that the Transportation category (#8) and the category of Exposure (#11)
were the most problematic and inconsistent.
One state representative said that trying to get businesses past this first
decision point had consumed most of the manpower in their office. They
were receiving 80-90 phone calls a day just on that question; they had to
hire a "temp" to respond to these phone calls and refer callers either to an
EPA field office or a consultant. Another group member said that they did
one informational mailing to businesses in their county, and were flooded
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with 7,000 phone calls; they did not know how to respond to callers, so
they ended up hiring a consultant to handle the questions.
One comment from a member in the Phoenix group accurately represents
the feeling expressed across focus groups: "It is virtually impossible to
determine who needs a permit...You are not looking at the runoff quality
with the SIC codes. I do not know of an existing code that looks at runoff,
and that ought to be the basis of the code (used for these regulations)."
EPA needs to clarify how these codes are to be used. As one member
stated, "OMB decided to use the SIC codes for other than they were
intended. EPA (therefore) must define how to use it; this needs research
and an environmental interpretation done." EPA also needs to be explicit
about states' liability if their interpretations of coverage are different from
what EPA's would have been. One group member suggested that EPA put
together a brief (1-2 page) guidance summary to help industries decide
whether they are covered, and also to develop descriptive categories of
industries covered. EPA needs to define the minimum criteria for coverage
to help regulatory agencies and industries determine their status, and then
give latitude to states to use Best Professional Judgment when making
decisions to include or exclude a given industry.
b. Exposure:
The category of "exposure" was cited by all groups as one of the two most
difficult to determine. Members requested that EPA allow regulatory
agencies to use Best Professional Judgment in determining which industries
should be covered. Examples were mentioned, included the artist doing
metal sculptures (all his activities took place indoors), and the farmer
trucking potatoes to the potato chip factory (he was advised to cover his
load with a tarp). As one member stated, decisions on whether an industry
falls under the exposure category need to be determined on a case-by-case
basis, and may require a site visit for a final decision to be made. Members
did feel this category was "good" because it is the only one that is risk-
based, yet "bad" primarily because exposure is "fuzzy".
EPA needs to allow states to develop their own definition and criteria for
exposure, reach agreement with them, and be comfortable with the
possibility that states may be different. The enormous number of covered
industries under the category would otherwise exhaust EPA's resources to
deal with it.
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6.
c. The group application process:
Focus group members feel that the group application process has created
significant confusion among permittees; there is no such thing as a group
permit, yet there are large numbers of industries that participated in a group
application still under the impression that they will be covered by a group
permit. As a number of participants stated, "(those who applied for one)
think group applications mean group permits. And that is not the case."
One industrial member voiced their frustration: "Industry feels that the group
application was misrepresented. (We thought,) this looks good; we can
band together, demonstrate our likeness, devise sampling techniques, and
regulate accordingly. Then we heard that you don't get a group permit; you
get sent to the next tier down - the state. And the state then decides what
you get... This has discouraged us from being proactive, forward thinking,
because the rules keep changing in mid-stream."
Some members thought the group application was a useful process. One
stated, 'The group application process will get the best information at the
least cost. It is the best research process because you can control it. For
example, the textile industry: consultants will get together with them to
determine how sampling and BMPs will be done. It provides a source of
comparison within industry."
EPA needs to let participating industries know what the process is about,
what the next steps will be for them after application review, and where
there will be extended timeframes for them to submit a NOI under a general
permit or an individual permit application.
EPA needs to consider consolidating programs in order to address water
pollution in an efficient and cost-effective manner.
All groups suggested that EPA look at consolidating the different water programs
for greater cost-efficiency and effectiveness. Rather than looking at it by different
water source, e.g., storm water, wastewater, wetlands, etc., limited federal
resources could be applied on a prioritized basis by watershed. Group members
felt that this approach would eliminate redundant efforts across programs, allow
dollars to be spent by risk priority rather than through separate program allocation,
and have a more profound effect on reducing water pollution.
The perception is that present programs are more interested in "bean counting";
that is, keeping their present funding levels at the expense of the environment.
One group member said, "Avoid bean counting-Transfer the funds to where it
makes sense. Some water bodies have five different funding streams. (EPA)
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should look at one water body, and look at point and non-point factors. See if we
can pull the program together to yield an environmentally efficient program that
brings all this together. This would form a prototype of pollution elimination by
integration of programs." Another suggested the development of a "water
pollution block grant."
in no group was there a concrete discussion on how EPA would accomplish this
at a federal level, although many thought that a start would be to get people from
each of the programs to "sit down together in the same room" to discuss ways of
working together toward the same goals. State representatives were aware of
program separation at their level, and cited the different funding streams - with
some programs having far more than others - available for each one. It is clear
that most would like to see a strategy in place that allows monies to be allocated
based upon watershed priority. This ability to be able to shift funds between
programs many felt would have eased the financial burden of getting their storm
water programs up and running.
7. EPA should continue to focus on general permits in order to get the program
implemented as efficiently as possible.
One of the most-mentioned ways of reducing regulatory burden was the use of
general permits to cover as many industries as possible. Many state participants
voiced frustration at EPA's slowness in getting a model general permit out, and
some remarked on their slowness in reviewing state applications for general permit
authority. One indicated that it had taken their state nine months for approval. Yet
groups were unanimous that general permits are an excellent way to streamline the
program.
Participants felt that states should want permit authority; as one member put it,
"...they should want control over their own destiny." States that have not applied
for general permit authority, such as New York, are seen by permit applicants as
unhelpful. One voiced frustration that his state DEC office could not provide
assistance when he needed it, because the state had chosen to "ignore" the
regulations; he has looked to the regional EPA office for assistance, even though
he was not sure that was the "right" route for him to go. Another state
representative said that her state wants authority because "they could then issue
more permits, cover more people. It's revenue-producing, and the dollars would
come into (our) department."
Many participants predicted that states without general permit authority will be
overwhelmed by the number of individual permits. They felt that EPA, as well as
state and national trade associations, should make states aware of the
consequences of not having general permit authority. One suggestion often heard
was to get trade associations involved in lobbying state legislatures to put pressure
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on their state government. Some members recommended that EPA also put
pressure on states to apply for permit authority by using a carrot-stick approach:
assist them to apply, but withhold program monies from non-delegated states.
Others suggested that the carrot be dollars, such as the 106 monies, used as an
incentive. Participants felt that getting most industries into the program under a
general permit umbrella would establish a baseline for the program so that a tiered
approach could be used to identify and deal with pollutant sources.
it was evident from comments that some state representatives would like to see
a model general permit. They are looking for guidance in developing their own,
and models-either EPA-generated or state-generated~wou9d obviously assist
states in drafting their own. Critical to this effort is that this assistance be made
available as quickly as possible.
There is a common thread across these seven issues. That thread is the need for more
and clearer communication, from use of terminology and language more familiar to the
"layperson", to explicit guidance on fund raising approaches to support program
implementation.
In many organizations, "improved communication" is cited as a sought-after end, but it is
often set forth without identification of the means by which to achieve it. With this project,
EPA addressed the means by asking the "experts"-those people at the regional, state
and local levels who have to ensure that the regulations are implemented-where
communication has faltered and what is needed to address the problem. It will be the
continued involvement of these people in working on solutions that will ensure successful
achievement of the end.
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PART II: DESIGNING PHASE i! OF THE STORM WATER PROGRAM
The second part of The Rensselaerville Institute project was conducted during April-
September 1992. It consisted of three distinct efforts: a survey of point source and
nonpoint source program experts to gain their insights on the development of a strategy
for Phase II of the storm water program; three public meetings to gain citizen advice on
key elements that should be considered for the Phase II program; and facilitation of a
"design team" effort with selected experts to generate a detailed strategy to guide EPA
in planning and implementing Phase II of the storm water program.
For each effort, the focus was on three elements: targeting (which sources shall be
included and by what categories); control (e.g., should permits be used or another
strategy developed); and timetable (with what schedule and over what period of time
should Phase II be implemented, particularly with regard to the October 1,1992 deadline
established in the Clean Water Act amendment).
This report profiles project activities, then summarizes the findings from each of them.
The reader is referred to the supporting documentation in Volume II of this report for the
database compiled during this project, including analysis and comments from the Expert
Survey.
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Expert Survey
Part II of the project began with survey input from a select group of 32 storm water
experts from throughout the country. Five perspectives were represented:
academic/research; commercial development; consultant engineering/legal:
environmental advocacy; and state/local government. A Delphi-type survey approach
was used to obtain initial opinion and consensus on relevant issues and options for
addressing Phase II sources.
Two survey rounds were conducted with point source program experts. The instruments
presented respondents with a series of potential targeting and control strategies along
with timing options. Survey participants were asked to identify the strengths and
weaknesses as well as steps and resources needed to implement each option and were
also given the chance to suggest an alternative strategy to the ones presented.
Five nonpoint program experts received one survey designed to capture more specific
information on voluntary approaches for achieving program success. They were asked
to provide the same level of detail for their preferred strategy as point source experts.
Please see Volume II of this report for survey transcripts and analyses.
Survey Findings
Respondents were asked to identify, from a list of 18 potential sources, which sources
they felt to be the top five that "must be" regulated in Phase II. In descending order with
frequency of response in parentheses, the sources identified were:
1. "Some industrial activities not covered under Phase I because of anomalies in the
SIC codes." (24)
2. "Suburban areas of large metro areas outside city boundaries." (20)
3. "Some commercial activities with industrial components." (18)
4. "Large retail complexes." (15)
5. "State highway systems." (13)
The themes that characterized the designation of these sources as the top five included:
1) contribution to pollution load; 2) risk posed; 3) administrative efficiency of control; and
4) cost-effectiveness of control.
Respondents were presented with specific strategies for targeting and controlling Phase
II storm water sources. They were asked to assign a level of desirability and feasibility
to each. The scale used ranged from IT (least desirable, least feasible) to IT (most
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desirable, most feasible).
The three targeting strategies, and ratings and comments they received, are listed below.
Responses to Strategy I were spread across the scale; 39% of respondents felt it was
"very desirable" and 36% rated it "not desirable". The same response pattern was given
to feasibility: 21% rated it highly feasible while 29% rated it not feasible. That strategy
was:
Strategy I: "Eliminate Phase II as a separate part of the storm water program and
expand the current designation authority under Section 402 (p)(2)(e)."*
* 402(p)(2)(e): A discharge for which the Administrator or the State, as the
case may be, determines that the storm water discharge contributes to a
violation of a water quality standard or is a significant contributor of
pollutants to waters of the United States.
Some of the comments made by experts regarding this strategy included:
• "Gives the Administrator too much authority."
• 'This approach provides the greatest flexibility and provides time so that we
can learn from current programs."
« "Not feasible...unfortunately, the science is often not good enough to
pinpoint culprits; the database...is weak; it is difficult to single out one of
many candidate polluters."
• "Allows resources to be focused strictly on problem sources from the Phase
II universe."
• "Arbitrary and capricious interpretation of intent of Congress."
• 'Very desirable and feasible. It makes sense to target programs to areas
that contribute to water quality standard violations and are significant
contributors of pollutants."
Responses to Strategy I were the most mixed. While some saw it desirable because
sources covered would be more selective and limited and therefore the program would
require less resources and administration to implement, others did not support it because
they were unsure what criteria would be used for targeting sources, and were concerned
about the types of information used in decision-making as well as the experience of those
making the decisions.
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Most respondents felt that Strategy II would be costly, complex and unwieldy, and
resemble Phase I in terms of its drain on resources and manpower. Some respondents
felt it would expand the number of groups opposing storm water regulations.
Strategy II: "Cover all remaining point source storm water discharges under existing
Phase I requirements."
This strategy received a mean rating for desirability of 2.25 and a mean rating of feasibility
of 2.43.
Some of the comments regarding this strategy included:
• "Inadequate resources would pose a major implementation problem."
• "III advised and will be increasingly costly. There is no need to promulgate
new regulations that we know will not be enforced."
• 'Would be an administrative nightmare."
• Too broad with respect to potential benefits."
Strategy III was seen by a majority of respondents to be the most equitable and rational
of the three choices, as well as the most scientifically based. Concern that political
pressures might sway the development of targeting criteria was expressed by some
respondents. That strategy is:
Strategy III: "Apply Phase II controls selectively (e.g. on the basis of such factors
as population density, pollutant loadings, or geographic targeting, or others you
find to be appropriate)."
This strategy received a mean rating for desirability of 4.64 and a mean rating of feasibility
of 3.75. It was rated the most desirable and feasible of the three suggested strategies.
Some expert comments on this strategy were:
• "Best of all worlds - reasonably objective."
• "Strategy III is the most desirable of the three strategies because it
maximizes efficiency, effectiveness, and the flexibility to address water
pollution problems based on site-specific factors, especially risk."
• "Sound on a technical basis, but probably requires too many resources,
particularly information needed to do intelligent targeting."
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• "Desirable - this focuses scarce resources on likely and easily identifiable
problem areas. Feasible - the factors (e.g. population density) are easily
identifiable."
In the second round of surveys, respondents were asked to recommend a fourth strategy
if they did not support one of the three suggested by EPA. Most frequently mentioned
was a strategy that was a combination of Strategies I and III.
Four control strategies were presented to respondents for similar ratings of desirability
and feasibility. These strategies were:
1. "Mandatory reliance on general permits."
2. "Direct regulation under a national Phase II guideline, which may well
require a national rulemaking by EPA."
3. "Requiring direct regulation of Phase II municipalities under 100,000
and requiring them to develop necessary controls for priority sources
discharging into the municipal storm water system."
4. "Control under the nonpoint source program authorized under Section
319 of the Clean Water Act."
Desirability ratings for the first three strategies were approximately the same: respondents
felt that they were "somewhat" desirable. The fourth strategy was rated as slightly less
desirable. The greatest feasibility was assigned to Strategy 1. The least feasible strategy,
in the respondents' opinions, was Strategy 4.
In the second survey round, respondents were asked to describe implementation of their
preferred strategy. When asked what minimum control strategies they would use, the
following methods were mentioned:
• a menu or roster of BMPs from which could be selected the most
appropriate approaches for the industry or watershed;
• public education;
• erosion and sediment control methods;
• "good housekeeping" and source reduction/elimination methods;
• establishment of national minimum standards;
• elimination of illicit connections;
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• emphasis on pollution prevention.
Few respondents saw the implementation of Phase II to be a short-term process. Most
suggested a phase-in approach over a period of five to ten years. During this time, BMPs
could be tested for effectiveness and cost-benefit in terms of reducing and eliminating
storm water pollutant problems, and programs could establish solid components of
education, training and technical assistance.
Nonpoint Source Perspectives
Nonpoint program experts also favored Strategy III: "Apply Phase II controls selectively..."
for targeting Phase II sources, with a mean rating of 4.0 on Desirability. The ratings
ranged, however, from "1" (not desirable) to "6" (very desirable). Some of the comments
included:
• "Is inequitable. Establishes economic hardships for those required to
participate. Only strength is less administrative burden."
• "Would be easy to identify sources that fall under criteria. Could be
preventive since you are not waiting for a problem to happen."
• "Excellent in theory, but would require a lot of data for prioritization, and
would create confusion for some period of time."
The survey instrument used for nonpoint program experts was a modified version of the
point source expert survey that included a fourth EPA-suggestedtargeting strategy for
consideration. It was:
Strategy IV: Target and address problems and significant storm water sources and
pollutant loadings by using Section 319 and CZARA programs."
Respondents' mean ratings of the strategy were 3.2 for desirability and 2.8 for feasibility.
Comments included:
• These programs lack real regulatory teeth. CZARA 6217 applies only to
coastal regions. They just aren't aggressive enough."
• "Section 319 is broader than NPDES and has more technical experience
with BMPs. CZARA 6217 results in specification by EPA of management
measures, in effect setting standards and providing impetus to explore
alternatives.11
• "Since only limited 319 funds are available, it would be difficult to get much
done."
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• This is an important piece of a multifaceted approach, but not adequate
alone."
Respondents were given the same control strategies for consideration as the point source
program experts. Of the four, #3: "Requiring direct regulation of Phase II municipalities
under 100,000..." was most favored, with a mean rating of 5.2 for desirability and 3.8 for
feasibility. This control strategy was the only one to receive ratings higher than UL for
either desirability or feasibility.
The majority of respondents were opposed to extending the October 1, 1992 deadline.
The reasons given included:
• 'The longer we wait to address the problem, the more costly, less
technically capable and less environmentally effective the solution will be.
There are more opportunities today, especially in less populated areas, than
tomorrow to solve and prevent problems."
• "Storm water-related use impairment is a serious problem. Currently, there
is little being done to remediate existing problems and no assurance that
problems related to new development will be prevented. It is clear that the
voluntary approach is not adequate."
• 'Things aren't getting better. Forum and impetus are already in place -
capitalize on it."
Many of the recommendations made by point source program experts for targeting and
controlling storm water sources were echoed by nonpoint survey respondents. Some of
the targeting similarities include:
• selection of Strategy III: "Apply Phase II controls selectively..." as the most
desirable of EPA-suggested strategies. The most mentioned reasons for
preference were ease of identifying targeted sources, and the more efficient
use of resources;
• target by watershed impairment/threat severity;
• conduct pilot projects first, evaluate, and then develop and implement a
strategy;
• develop minimum national guidelines, and leave selection of sites and
methods to state discretion;
• initiate a focused dialogue with key stakeholders (for both targeting and
controls).
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Some of the similarities in preferred control strategies included:
• build a BMP menu that can be used to implement and verify progress; allow
selection of most appropriate BMPs based on industry and watershed;
• provide public education on need for storm water control;
• provide national criteria with flexibility for local implementation of most
appropriate controls;
• develop baseline control standards for all new development.
One primary difference between point and nonpoint respondents was the application of
the "stick" by EPA, with the "stick" being the requirement of permits for those sources that
did not achieve significant movement toward program goals via voluntary efforts within
a reasonable timeframe. As one nonpoint respondent phrased it, EPA should keep permit
requirements as the "gorilla in the closet" .to be used as needed when voluntary efforts
were not adequate for the problem.
A number of nonpoint respondents indicated that the 319 and CZARA 6217 programs do
not have the "teeth" they need to ensure compliance. Most feel that a combination of
programs is needed for successful achievement of water quality goals.
EPA STORM WATER PUBLIC MEETINGS
Description of the Meeting Format:
Three public meetings were conducted to gain citizen suggestions on options for targeting
and controlling Phase II sources. These meetings were held in Denver, CO; San
Francisco, CA; and Washington, DC. Approximately 200 people attended the three
meetings.
At each meeting, three experts selected from the survey process presented their ideas
on a regulating strategy for the moratorium sources. Following their presentations,
attendees were divided into small task teams with an assigned facilitator, and given the
charge of devising their own strategies for targeting and controlling Phase II sources. The
strategy template provided to guide group consideration of key issues is presented below.
During the latter half of the meeting, each task team presented their option to the other
attendees for discussion.
Teams were asked to consider these issues:
1. Targeting (What light industrial, commercial, retail, residential, or
other areas or other areas do you include in Phase II?)
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4.
5.
6.
7.
8.
9.
Meeting Findings:
2. Control (Do you use continued reliance on the existing NPDES
permitting process or something else such as nonpoint source
programs, selected permitting based on risk, geographic targeting,
etc.?)
3. Timetable (How would you phase in the major components of the
strategy and over what timeframe? Do you suggest full
implementation on October 1, 1992 [as stated in CWA] or do you
recommend a different set of deadlines and why?)
Key steps to implement (Please indicate up to five critical, major
steps to take in implementing your strategy and the timetable for
each.)
How will costs of your strategy be distributed over key players and
how will costs be understood and controlled?
What measures of performance will you use and how will you verify
the environmental results? (Do you rely on numerical measures and
quantitative pollution indices or other factors?)
Strategy Strengths (Name four key strengths of your strategy which,
in your judgement, make it preferable over alternative strategies.)
Strategy Vulnerabilities (Name four most critical points at which your
strategy is most vulnerable to failure or shortfall in implementation.)
For whatever strategy is chosen, what could EPA do to make the
decision-making process for Phase II more responsive?
A total of sixteen task teams presented their strategies for Phase II of the storm water
program. The individual task team strategy outlines offered a diversity of approaches for
designing, implementing, monitoring, and funding Phase II of the storm water program.
Individual strategies presented a large range of methods for targeting and controlling
sources, and many different timeframes over which the program could be phased in.
Despite the different representations, experiences and expertise, there were points of
congruence between many of the proposed strategies. Common strategy characteristics
across task teams included the following:
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Targeting:
a. Targeting should be done by watershed. Information gathered from Phase
I should help identify sensitive watersheds. May require intergovernmental
agreements.
b. The focus should be on "bad actors", i.e. those that are known problem
sources. The ones most frequently identified were: gas/auto service
industries, transportation, highway systems, land development and
agricultural sources. There needs to be the ability for facilities not
contributing impairment of water to gain an exemption from permits, fees,
implementation of BMPs. Categories are an ineffective way to designate
covered sources. Selection should be done by the degree of risk a given
facility poses rather than categorical inclusion.
c. Small municipalities should have a much simpler application process, or
have the opportunity to be excluded if they do not contribute to the pollution
problem. In addition to impact on a watershed, proximity to larger
municipalities should be considered as well.
d. EPA should defer on selecting targeted sources until the agency has
carefully looked at the data gathered during Phase I. Numerous sources
of information are available which would help determine targeting priorities,
e.g. information gathered through 305b reports, information from Phase 1
program sources, NURP.
Controls:
a. If a permitting process is to be continued for point sources, NPDES general
permits should be used, and focus should be on BMPs. Permits should be
simpler, and much less costly. EPA should make clearer to the applicant
what information is required, e.g. checklist of inclusions, menu of BMPs.
Exemptions should be available for non-contributors.
b. Education should be a primary form of control. It is important at all levels
and for all audiences, yet is often overlooked or underrated.
c. There should be more emphasis on voluntary programs, e.g. the "319"
nonpoint source program. For facilities with contact with storm water, there
should be little or no more government intervention, but rather emphasis on
pollution prevention incentives, BMPs, and practical measures of pollution
prevention.
Pollution prevention programs should be emphasized, particularly with new
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d.
development. Some suggested prevention methods include: recycling storm
water, good housekeeping practices, plantings to minimize runoff, street
sweeping of work areas on a daily basis, storm water collection methods,
coverage of storage areas, changing manufacturing processes to minimize
pollutants, improvement of air emissions.
BMPs should be required based upon the specific pollutant problem and
strategies known to be effective in its mitigation or elimination. The focus
must be a known connection between solution and its effect on the
problem. BMPs must also recognize financial constraints, providing actions
that are relatively higher in terms of cost-effectiveness.
Timetable:
a. A minimum of two years is needed to prepare for Phase II, with at least a
year dedicated to looking at data gained from Phase I of the storm water
program. Effectiveness of presently used BMPs needs to be looked at to
determine differences in effectiveness between geographic locations and
pollutants.
b. Whatever the period established for phase-in, it should not begin until
promulgation of the regulations.
Role of EPA Headquarters.
a. Research, information dissemination, technical assistance.
EPA should also provide focus within these areas. Also, the current efforts
are too diffuse, and imply a complexity that makes applications seem
difficult and formidable.
b. Funding, not for program implementation, but for research.
Two areas of research requested are water basin pollution control and
determination of effectiveness of BMPs. The majority of participants
recognize that EPA does not have the fiscal resources to fund programs.
What they do want from EPA is guidance in establishing fund raising
mechanisms, such as storm water utilities.
c. Establishing broad guidelines for the program within which local flexibility is
allowed and encouraged.
Flexibility, at the same time, does not provide an excuse for inaction or
postponement. Rather, it recognizes that different actions and action
sequences are appropriate to different contexts and conditions.
d. Responsibility for training regulators in the storm water program.
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Until those administering the program are well equipped to enable action,
effective responses will be difficult.
Please see Volume II of this report for copies of the individual strategies developed at
each of the public meetings.
Reflections on Meeting Format
A presumption shared by EPA and the contractor, The Rensselaerville Institute, was that
the conventional format for public hearings and meetings is of limited value in engaging
citizens or of making the critical transition from criticism to advice on how best to do
things. Given this belief, a different format was devised that proved quite different from
the typical approach of lectures by experts and/or testimonies read to the record by
concerned citizens.
in the interactive approach used, participants were advised that they would be asked to
form into task teams to first listen to experts offer their insights, then to develop, as a
team, a preferred strategy for responding to Phase II of the storm water program. Each
team comprised a cross-section of those attending-including where there are possible
strong environmental, industrial, and local government perspectives.
In all three meetings, participants accepted the format and energetically engaged in the
task of constructing a preferred solution. This included the session held in Washington,
D.C. where participants from major interest groups were in the habit of providing critical
feedback and criticism more than engaging in a positive design process.
To gauge participant responses to the different public meeting format, a mail-back
questionnaire was used inviting comments by the some two hundred participants in the
three public meetings. Approximately 35% of those attending completed the survey.
They were first asked to comment on their assessment of the more traditional public
hearing format. Most held a clear and consistent view of the traditional approach as
focusing primarily on prepared statements. Where dialogue was included, it was seen as
argumentative and contentious. The general conclusions:
• opinions are solicited for the record and to insure the perception of public
participation but not to provide genuine input. The sense is not of active
government listening.
• primary participants are those with strong convictions and often special
interests; they are not a representative sampling of public opinion and tend
to run the gamut of extreme perspectives on a given issue.
• sessions tend to become adversarial or at best argumentative. No
mechanism for cooperation is available and differences tend to get
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magnified, not resolved.
• the focus is on the problem much more than on ideas for resolving it. On
the one hand this attracts critics more than implementors. On the other, it
provides little guidance to people who full well know the problem and are
looking for ways to deal with it.
Participants were much more positive about the format used. Among the sentiments
voiced:
1. Participants had a full chance to participate-not only to be heard but to be
directly engaged in finding solutions.
"It was a valuable way to address the drafting of regulations-allowing the
regulated community to feel part of the process";
"Encouraged the regulated community to get involved and feel involved";
"Participants felt that EPA was actually listening and dialoguing."
2. The process was genuinely two-way, allowing both EPA staff and those
effected to better understand each other.
"It made you appreciate the USEPA's tough job of satisfying the concerns
of many people while protecting the environment";
"Felt it draws out better data";
"Actually got to interact one on one with industry and government and
consultant representatives. Obtained a better point of view of government's
problems and felt that government representatives also obtained a better
point of view of industry's problems."
3. The format created an atmosphere for cooperation and even for
collaboration among people with very different viewpoints.
The meeting went a long way towards promoting the creative thinking,
open discussion, and presentation of ideas";
"Group discussion is a fine vehicle to provide input as well as learning tool.
It forces you to think through participation, rather than just simply sitting and
trying to absorb by osmosis.";
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"Small diverse groups allowed ideas to be evaluated fairly and fostered
"brainstorming" and allowed ideas to be developed to better fit broad based
objectives."
The positive elements of the meeting extended beyond the effective communication of
opinion and position to EPA to broader understandings of issues, complexities, and
solutions. Indeed, the sessions seemed as influential in creating new insights as in
communicating old ones.
Respondents suggested two primary ways to improve the format for future uses. The first
is the need for more detailed advance preparation--in part, needed to change the mind-
set and expectations which people tend to have for a traditional public hearing or
meeting. The second suggestion: minimize expert presentations, even when used in the
"pump-priming" mode employed in this session. Trust the process and get right to the
participants.
When asked if they would advise the EPA to use this kind of interactive task-focussed
approach with other meetings designed to get public input, over 90% said "Yes." Two
persons indicated that it depends on the issue and only two indicated that they preferred
to remain more passive.
THE "DESIGN TEAM" MEETING
Meeting Description:
A meeting of seven point and non-point storm water program experts, all of whom were
survey respondents, and selected EPA staff was convened in Washington, D.C. on
September 17-18,1992. The purpose was to gain the experts' insights on development
of Phase II storm water regulations, and the intended outcome was to build a strategy,
or multiple strategies, for regulating Phase II sources.
Participants included:
Mr. Gail Boyd
Woodward-Clyde Consultants, Portland, Oregon
Ms. Diane Cameron
Natural Resources Defense Council, Washington, D.C.
Mr. Dennis Dreher
Northeastern Illinois Planning Commission
Mr. Tom Mumley
San Francisco Bay Regional Water Quality Control Board
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Mr. Earl Shaver
State of Delaware Department of Natural Resources and Environmental Control
Ms. Coleen Sullins
State of North Carolina Division of Environmental Management
The participants selected were deemed, by their peers nationwide and EPA, insightful and
highly articulate exponents of all major viewpoints on the storm water program.
Also in attendance were these key people from U.S. EPA:
Mr. Michael Cook, Director
U.S. EPA, Office of Wastewater Enforcement and Compliance
Mr. Geoffrey Grubbs, Director
Assessment and Watershed Protection Div.
U.S. EPA, Office of Wetlands, Oceans and Watersheds
Mr. James Home, Special Assistant to the Director
U.S. EPA, Office of Wastewater Enforcement and Compliance
Mr. Ephraim King, Chief
NPDES Program Branch, Permits Div.
U.S. EPA, Office of Wastewater Enforcement and Compliance
Mr. Jack Lehman, Deputy Director
U.S. EPA, Office of Wastewater Enforcement and Compliance
Session Findings:
1. Development of a ten-point outline describing a potential strategy for Phase II of
the storm water program.
Consistent with the overall purpose of the meeting, participants identified ten core
elements that they feel constitute a potential strategy for Phase II of the storm water
program. These elements are:
A. Objective: To get certain BMPs, ordinances and education programs into
place over a 10-15 year period. Progress would be measured by getting
these elements into place, with direction toward water quality standards and
beneficial uses over a longer period of time. EPA would work with all states
to help them develop Phase II programs.
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B. Priorities: EPA would set these. They would include: the sources listed by
the group, using a watershed approach where feasible, focusing first on
those local governments with the size and capability to get going.
C. Education/outreach/technical assistance: these are all critical components
of a successful program.
E. Mandatory Interim Milestones: EPA needs to determine interim milestones
state programs need to meet which would show they are on track.
F. Financial Plan: states/local governments need to develop plans for financing
the program.
G. Guidance: guidance is needed on BMPs and local ordinances. These
would be generated at the federal level, and states could adapt/modify as
needed.
H. "Default" system: local governments would take the lead with their
programs, but there would be a built-in default system where the states or
EPA would take over with more stringent controls if the locals fail to meet
requirements.
I. Permit issuance: for high priority categories, could issue permits that allow
flexibility or some alternative mechanism at state's option. Permits might be
just for high priority categories; would include site design performance
standards.
J. Phasing: there would be a schedule for issuing permits to key
municipalities: high priority to low (e.g. coordinate by watershed); high
flexibility to "getting tough" with recalcitrant localities. These would be based
on inspections, on-site reviews.
K. Monitoring: this would be the difficult part of the program because of cost.
Need is to be able to design something useful. The system might be "tiered"
- highest to lowest priority; or "strategic" - focused only on gathering what
we really need to know.
2. Sources to be targeted in Phase II.
The participants identified a number of specific unregulated pollutant sources that need
to be targeted in Phase II of the storm water program. An approach recommended by
some of the participants for controlling these sources is a "whole basin approach", which
would focus attention and resources on activities impacting the water quality of a given
watershed.
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The group identified approximately 40 pollutant sources that they believe need to be
included in Phase II of the storm water program. The sources identified include the
following:
New Development/Redevelopment (commercial and residential)
Transportation Corridors
Dense Existing Development (commercial and residential)
Automotive Services
Federal facilities/military facilities
Feedlots (including dairy)
Failing septic systems
All incorporated places with less than 100,000
Non-urbanized watersheds yet to be determined
Parts of watersheds where land use is in a state of flux
Dry cleaning shops
Parking lots
Some forest operations
Nurseries/orchards
Recreational areas (e.g., stadiums, golf courses)
Landfills
Office parks
Grain elevators
Concrete cutting sites
Commercial pesticides
Landscaping industry
Car washes
Mobile washing units
Equipment maintenance
Boat yards
Tank farms
Shopping malls
Restaurants
Airports
Janitorial services
On-site solid waste (collection, hauling, transfer stations)
Atmospheric deposition
Cemeteries
Commercial strips
Wood stoves
Marine ports
Animal waste
Warehouses/storage facilities
Exterior building maintenance
Bridge maintenance
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Members of the group suggested that rather than use the Phase I approach of including
sources by category into the regulations, regulatory staff time and resources should be
allocated on a water basin approach, i.e., target a watershed, identify impacting activities
and their location within the watershed, and determine a set of criteria to deal with the
problems impairing the watershed. This would allow limited resources to have maximum
impact.
3. Source priorities.
After listing the range of sources that they felt should be included in the Phase II program,
participants voted for what they considered to be the top priority sources, i.e. those
sources that EPA should address immediately and diligently. The top sources selected
are listed below, in order of decreasing number of votes received. All sources were
selected by at least 50% of the participants. The sources identified as top priority for
addressing in this order:
A. New Development/Redevelopment (commercial and residential)
B. Transportation Corridors
C. Dense Existing Development (commercial and residential)
D. Automotive Services
E. Federal facilities/military facilities
F. Feedlots (including dairy)
G. Failing septic systems
4. Lessons from a case study.
One participant presented an outline of the basic components of the Puget Sound Water
Quality Management program. The program is a multifaceted approach toward the
achievement of improved water quality which heavily emphasizes voluntary measures in
its implementation strategy.
The program includes minimum BMP standards for all jurisdictions with additional water
quality treatment BMPs, guidance and requirements for higher risk storm water
dischargers. Key facets include: vigorous technical assistance, education, state financial
support, education and support for storm water utility development, highway runoff
regulations, a full nonpoint watershed management program, storm water operation and
maintenance requirements, source controls, and local control and flexibility.
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The program is being phased in over several years. It is a combination of mandatory
requirements, technical guidance and voluntary compliance. There are specialized focus
areas, such as shellfish protection districts and conservation districts. There is a
coordination effort with individual and general permittees in the Puget Sound area.
The program views its strengths to be greater local flexibility and acceptance of
requirements, a strong sense of teamwork between all levels, better water quality results,
and better targeting and use of limited resources than if they were regulated by NPDES.
They view the NPDES program as the "gorilla in the closet" that can be brought to bear
if and when a source does not meet minimum standards and requirements.
5. Principles for Phase II.
Participants discussed the basic principles they believed should drive the Phase II
program at the national level. For the program to be successful, it would require that the
following pieces be put into place:
A. Require that people gather documentation of information regarding
dischargers' activities and accomplishments and provide outsiders with that
documentation;
B. Formally define gaps where additional information and understanding is
needed. There needs to be an incentive to close these gaps;
C. Support (with encouragement and incentives) efforts that will close these
gaps, and advance the state of the art and/or provide a technically sound
basis for the programs' requirements;
D. Actively encourage a broad spectrum of understanding and involvement
(the general public, community leaders, service groups, environmental
groups) via educational programs and materials;
E. Strategically identify "good" guys and "bad" guys in the regulated
community;
F. Provide clear guidance regarding programmatic and physical actions that
are required/expected. Actively seek out evidence that people know what
to do, and provide technical training to be sure that people know how to do
what is required (technical transfer);
G. Require relevant/credible/useful monitoring only. Don't waste people's
time/money/energy running data collection programs that yield bad or
irrelevant data.
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6. State suggestions of what EPA needs to consider in developing the Phase II
program.
A sub-group of participants from state regulatory agencies met, and set forth a list of
suggestions for EPA to consider in developing Phase II. The following recommendations
were made:
A. EPA needs to provide states with the minimum program requirements they
must achieve, and then allow states flexibility on how they will do it. The
components must include:
• requirements/BMP standards for new development
• education/technical assistance
• control requirements for illicit connections/dumping
• developing state-specific priorities
B. EPA should require states to adopt regulations that specify program
components that must be included:
C. To assure program funding, EPA needs to require that state and local
governments set up funding mechanisms, e.g. storm water utilities, permit
fees, etc.;
D. EPA needs to compile and disseminate technical information that would
support programs, e.g. set up a national or regional clearinghouse of
information on storm water plans being implemented, BMP-specific
information and materials, etc.;
E. EPA needs to compile a national BMP manual that would assist members
of the regulated community in determining and implementing appropriate
BMPs to address their storm water problems. EPA needs to recognize,
however, that BMP application will differ between regions, e.g. climatic
differences will require different approaches;
F. EPA needs to require that states develop and implement education,
technical assistance, and training programs; EPA also needs to hold the
states responsible for effectiveness of these programs, and require
permitting in the event that these measures do not work;
G. EPA needs to maintain the right to require permits in a reasonable amount
of time (e.g. 2-3 years) if a state's program is not meeting federally
determined requirements;
H. EPA needs to determine what short and long term goals they wish the
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storm water program to achieve.
7. Identification of problem areas and needs of the regulated community in dealing
with the storm water program.
Participants were asked to identify what their "hot buttons" were, i.e. elements or
considerations that EPA might include in the Phase II program which would cause major
problems for them, or those which if not considered by EPA would create needs for the
regulated community.
The list of "hot buttons" include the following:
A. Penalizing those who have already solved their problems by requiring
permits.
B. Liability for water quality standards, sediment standards, and resource
damage clean-up in the first round.
C. Failure to provide technical transfer - permittees need to know what to do
and how to do it.
D. Failure to promulgate revised and simplified NPDES regulations that get
around the complicated approval process.
E. Possible backlash from local governments if they are held responsible for
instances of independent commercial activity that they cannot address or
control when they don't know about it.
F. Lack of research on BMP effectiveness from a watershed perspective.
There is inadequate federal/state money to look at BMPs because
monitoring is so expensive.
G. Possibility of EPA not basing the program on permits (except in cases
where the state can show that it can reach goals alternatively).
H. The inherent substantial risk of tremendous backlash that would affect
people's livelihoods, i.e. failure to try to sell the program to regulators and
public, including the NPDES permit process.
I. Prevention v. wetlands - determining how to prevent storm water problems
while protecting wetlands.
J. Not addressing the roadblocks created by the regulations themselves. The
system is so complicated, it now takes two generations for permits to get
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to goals.
K.
L
M.
N.
O.
P.
Q.
Lack of federal monetary assistance. Some states may be reluctant to
develop adequate programs without it.
Not getting rid of the acronyms in the regulatory language. No one
understands what EPA is saying.
Concern that mainstream design is end-of-pipe treatment. This is not
prevention! CZARA is on a better track.
Allowing states to cut monitoring activities first. They need to be
encouraged to not eliminate that element disproportionately from their
budget.
Need to figure out how to sell the program - to get through to OMB and top
levels of state governments exactly what it is going to take to get the
program into place.
Not identifying funding incentives and disincentives.
Not giving praise for progress.
Additional Advice
Additional suggestions for development of the Phase II program were generated by the
group during the two-day meeting. Included in those recommendations are the following:
1. EPA needs to revisit and revise the terminology used in the regulations.
• the problems are often with the common words, e.g. runoff, storm water,
nonpoint source, point source. EPA staff have attached certain meanings
to words that are not conveyed to the regulated community, so there is
inherent danger that people are not talking about the same thing. Words
need to have clear and referenced meanings.
• the enormous number of acronyms used by EPA creates significant
comprehension problems for regulatees. The regulations need to be written
with fewer acronyms, and all communications need to be sensitive to the
level of use.
2. EPA needs to clearly define the goals of the program.
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• all levels of feedback (focus group, survey, and meeting results) generated
during The Rensselaerville Institute project have pointed out that the
regulated community does not understand what EPA is trying to achieve
with the storm water program. Assumption of what the goal is ranges from
achievement of set water quality numerical limits to returning a water body
to its original uses.
Confusion over the goals causes confusion for regulatees in terms of selecting the tools
that need to be used to reach them. EPA needs to determine what the federal purpose
is with regard to the storm water regulations given the reality of limitations of presently
available methods and resources for preventing and treating storm water pollution.
3. Citizen involvement can play an important role in achieving program goals.
EPA, states and local governments need to promote citizen education and
enforcement authority.
Participants gave numerous examples of how citizens could play an active role in
implementing and monitoring pollution reduction efforts. Given the limited resources of
federal, state and local governments, voluntary citizen involvement can support successful
program outcomes, including enforcement. Education of citizens at different levels, e.g.
qualitative vs. quantitative monitoring, stream health vs. compliance monitoring, etc. would
be needed. Guidance manuals can be developed to guide public education.
General Recommendations
The ten summary recommendations stated at the conclusion of the Executive Summary
are here amplified to reflect the discussions and insights generated in this project. While
not all persons involved agree with each observation and recommendation, these are
advanced as having widespread support.
1. It is possible and desirable to identify priority target areas for which there is
widespread consensus concerning their contribution to water pollution.
These areas begin with new development and redevelopment-both residential and
commercial. They also include transportation corridors, dense existing
development and automotive services. Further, the priority of these target sources
is relative to the watershed upon which they are impacting.
Strategically, approaches that focus on a small number of priorities based on
relative risk will show stronger results than one that initially targets a broad set of
sources in Phase II. Also, it much more cost-effective to identify and pursue the
"bad actors" (eg, those contributing toxicity as opposed to sediments or turbidity)
as a priority, then get to those adding incremental pollution through routine activity.
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2. EPA needs to communicate more clearly and regularly with everyone
impacted by the storm water regulations.
The priority focus should be less on the amount of communication and more on
different kinds of communication. Specifically, communications should be:
• more interactive-the examples of the focus groups and public
meetings used in this project are often cited as productive formats
for future citizen input;
• more localized to contexts-as in more regional workshops and fewer
national ones. This means communications less inclined to reflect the
national complexity of the program and more inclined toward
addressing the specific information and guidance needs of the local
person involved in a specific and delimited way. It also means less
"canned" content and more consultative dialogue;
• less laden with acronyms and technical language that confuse and
irritate many of the people who are the true "customers" of the
program, and who are required to carry out the federal mandate.
Along with this, more attention should be paid to finding and
marketing simplicities rather than complexities.
3. EPA could improve program effectiveness, efficiency and cost control in
Phase II by "starting small".
The concept of regional and even local prototypes was advanced by many people
as a way of getting proposed new Phase II frameworks into the hands of users in
prompt fashion to build and refine based on early use. This was generally seen
as preferable to the comprehensive approach in which new programs are
developed fully and then introduced comprehensively at a point when modification
is difficult and expensive.
Related to prototypes is the case study-in which an analytical eye is turned to
current programs that demonstrate one or more strategies or best practices for
storm water implementation. An example is the Puget Sound model, with its focus
on the tangible and cost-saving values of voluntary compliance by small
businesses (a summary of this approach is contained in Volume 2).
The use of a small scale plays to the strength of regional differences as well as the
reality that an equal stress on comprehensive large programs may so paralyze
states and localities that nothing is done expeditiously.
4. Selectivity in data collection and monitoring is essential.
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At present, some data collection frameworks consume tremendous time and
money only to yield bad or useless data or murky or disputed conclusions. More
attention should be paid as to what constitutes "good science" and activities that
may show the appearance of effective activity but in reality be consuming scarce
resources to no clear gain. This also relates to the adage, "what you measure is
what you will get." While the tendency is to see monitoring and assessment as
questions of methodology, they must first be viewed as questions of substance.
What are we trying to measure and at what level of detail and accuracy?
Not all measuring and assessment need be arcane. In development projects, for
example, the use of hay bales is known to contain overflows. No great study of
cause or effect is needed. And if there is floating oil on a body of water, we can
start by verifying that it is there-a useful step even if we do not "measure" its
amount. At the same time, other kinds of assessment are meaningless without
extensive (and expensive) levels of detail and analysis.
A related point is that documentation of discharger activity and accomplishment
is as critical as scientific study of water conditions.
5. More customer differentiation is also needed.
At present the mind-set appears to be that one size fits all. While giving the
appearance of equity, this concept actually creates strong inequalities. The same
programs and regulations that befit a large corporation or municipality are simply
not equitable for smaller enterprise and communities, for example. More broadly,
some specific operations within a given source category contribute significant
pollution; others contribute none. Some way to either make the initial process
much less costly or to more quickly separate out those who do not need
continuing attention must be found.
One form of general differentiation is between those who are causing a problem
by clearly inappropriate activity (the "bad actors") and those contributing to storm
water pollution by standard and at times inadvertent practice.
6. While the ultimate goal is water quality standards, this is very difficult to
achieve and/or to measure in the short term.
While retaining water quality standards as the ultimate goal, EPA should be
focusing on best management practices, and in particular those that reflect
preventive and non-structural solutions. An example is stronger standards and
technologies for storm water control in new residential and commercial
construction. In many instances, the correlation is clear between the management
practice and the consequences for cleaner water.
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The codification and communication of best management practices applies not
only to those targeted and controlled but to state and local actors implementing
storm water programs. For example, a set of "carrots and sticks" known to
promote voluntary compliance is just as critical to disseminate as a new approach
to storm retention ponds in a sub-division.
While BMPs are set in place, interim milestones for water quality are also critical--
and feasible-as a way of measuring progress. The transition from progress by
practice to achievement by water quality measure must begin now.
7. The most functional unit of both analysis and intervention is the watershed.
Most people in our samples for opinion and recommendation strongly suggested
the watershed approach-not only on the macro level (e.g., Chesapeake Bay) but
the micro-level as well. In particular, this means looking at stream quality issues
beginning at the headwaters for early contributions and alterations. Most felt that
functional differentiation of pollutant sources is not really meaningful in terms of
either regulation or effective change at the watershed level.
8. EPA's role is to offer technical support and direction more than program
funding or even full guidelines for state and local implementation. In
particular, building useful data bases and collection methodologies not only on
water quality but on practices to achieve it is critical. Also key are training and
support programs and development of effective dissemination networks. In all EPA
roles, the need is to recognize both regional differences and the need for a multi-
faceted set of strategies, tools, approaches, solutions.
Another EPA function is to focus on the connection between best management
practices and long term consequences for water quality. While those who
introduce them are in the best position to refine BMP's, they often do not have the
tools to verify a correlation (let alone a causal connection) to water quality. This is
an important EPA function.
9. A collaborative approach to developing effective solutions is possible. The
interactive elements of this project are one reflection of the ability of those with
strikingly different perspectives (ranging from strong environmental protection to
a focus on economic development) to work cooperatively. If adversarial and
polemical dynamics can be set aside, the gains are far greater.
Collaboration must begin within EPA itself, where there is a tendency for those
focussing on permits and "harder" tools of compliance and those focussing on
education and "softer" elements of prevention to not fully connect with each other.
In reality, there is a strong common theme from the need to see the storm water
program as a way of enabling local communities and industries to change their
behaviors to help the environment in ways that will directly benefit them as well as
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all other citizens.
10. Agriculture activities should be included more directly in the storm water
program.
In many regions, agriculture (which includes livestock as well as crops) is a
primary contributor to surface water pollution. While the present NPDES program
requires permitting of the transport of agricultural products, this brings intervention
too late. The critical first steps of agricultural activities, e.g. soil preparation,
growing, and harvesting, must be included.
Beyond this reality is the signal sent that for whatever set of reasons, some
interests are exempt from a program in which they clearly belong.
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The Rensselaerville Institute is an independent, not-for-profit educational center
chartered in 1963 by the Board of Regents of the State of New York.
The Institute specializes in organizational and community development.
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THE U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER
EPA GROUP INVOLVEMENT PROJECT
CONDUCTED BY:
THE RENSSELAERVILIiE INSTITUTE
REPORT SUBMITTED: SEPTEMBER 14, 1993
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EPA GROUP INVOLVEMENT PROJECT
Int r oduc t. i on
In early 1993, The Rensselaerville Institute undertook a project
designed to gain various groups' involvement in development of
Phase II of the Storm Water program. Working with the U.S. EPA
Office of Wastewater Enforcement and Compliance, The Institute
implemented an approach whereby groups and people with interest in
the Storm Water program became actively involved in identifying and
discussing a series of program design options.
A series of meetings were held in Dallas, TX; Washington, DC;
Chicago, IL; and Falls Church, VA. Approximately 150 people
participated in the meetings.
This report describes project implementation and the method
utilized, highlights the results of the project, and provides a set
of recommendations for program development.
Project Implementation
One of the first steps of the project was to craft a number of
options to describe how the Phase II program could be organized and
implemented. At a Phase II Options Identification Meeting held in
January 1993, 14 different options for target and control of Phase
II storm water discharges were outlined. From the original 14,
seven options were developed; each designated certain program
responsibilities and authority between federal, state and local
entities.
These seven options were used as the basis for focusing team work
at each of the meetings. Briefly, the presented options were:
1. State Target Selection - Non-NPDES Control.
Phase II sources would be targeted by the states, using
information from 305(b), 303(d) and 304(1) reports to target
sources in watersheds where storm water is a significant
source of impairment. Individual States would be able to
select from a mix of controls to attain water quality
standards. There would be no provision for Federal oversight
of State control options.
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2. Eliminate Phase II; Expand Phase I Designation Authority.
This option would eliminate Phase II of the storm water
program. NPDES permitting authorities would retain
designation authority to target and control any high risk
sources of concern under Phase I of the program. The
remainder of Phase II sources would be prioritized and
controlled by States through existing non-NPDES control
strategies.
3. NPDES Permits for Federally Selected Municipalities Not
Covered Under Phase I.
Under this option, EPA would target urbanized areas and
emerging growth area portions of municipalities and counties.
NPDES permits would be issued to selected
municipalities/counties and would require the implementation
of _a storm water management program through which the
municipality would control commercial/industrial/residential
sources within their jurisdiction.
4. Tiered Federal and State Target Selection - Tiered NPDES
and Non-NPDES Control.
The first tier of high risk sources would be selected on a
national basis with this option. Potential targets would
include categories of facilities or activities, and urbanized
and associated developing area portions of municipalities and
counties. Additional sources may be selected by individual
States based on information available to the State, including
watershed data generated through 305(b) reports as well as
303(d) and 304(1) information. First tier high risk sources
would be controlled through NPDES permits (State/EPA). Second
tier sources would be controlled through a range of control
measures under State discretion.
5. Federal Target Selection - Non-NPDES Control.
With this option, high risk sources would be Federally
selected. Potential targets include categories of facilities
or activities and municipalities located in urbanized and
associated developing areas. Individual States would select
their own control mechanisms for all Federally selected
sources. There would be no provision for Federal oversight of
State control mechanisms.
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6. State Target Selection Consistent with. Federal Criteria -
State NPDES or non-NPDES Control.
EPA would develop selection criteria for sources (criteria
would include watershed targeting and reliance on 305(b)
reports as well as 303(d) and 304(1) lists as appropriate).
States would identify high risk activities using these
criteria. Potential targets would include categories of
facilities or activities, urbanized and associated developing
area portions of municipalities and counties,, and sources
located in affected watersheds. The State may implement
either point or non-point source control measures as they see
fit. Federal oversight would be exercised; sub-options would
provide for different oversight schemes.
7. Federal Target Selection - NPDES Control.
With this option, high risk sources would be selected at the
Federal level. Potential targets would include categories of
facilities- or activities, and urbanized and associated
developing are portions of municipalities and counties. All
sources identified would be controlled through NPDES permits.
At each of the three public meetings held, participants were
presented the above list of options, and were provided the
opportunity to ask clarifying questions about each one. For their
first task, they were asked to identify strengths and weaknesses of
each option in terms of targeting, control and timing strategies,
and decide what changes if any they would make in the option to
improve it. Participants were also given the opportunity to create
their own option(s) for consideration.
The second task for participants at each public meeting was to list
the key components that they felt should be included in a Phase II
program for it to be successful, and to identify actions that EPA
should avoid taking because the actions would have major
detrimental effects on program success.
Participants were divided into small working teams of 6-8 people.
Each team appointed one person to record group responses to each of
the tasks. Following each task, teams reported out to the rest of
the group.
Individual meeting reports of team responses to the options are
appended to this Executive Summary. The list of options for the
first meeting was slightly different than the list used for the
remaining meetings in both order of option presentation and
wording. The list was modified for two reasons: 1) there was a
sense that, because the options were presented from most to least
Federal control, people in the first two meetings may have been
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unintentionally drawn to "middle of the road" options; and 2)
initially, one option explicitly included a watershed approach, and
therefore people may have felt that it was the only option that
could incorporate it, even though the other options in no way
excluded using the approach. Thus, participants in the second two
meetings received the options in a different order and with
explicit reference to the watershed approach given in a number of
option descriptions.
Two final "expert meetings" was held in Chicago, IL and Falls
Church,_VA, where national storm water experts convened to review
the options and suggest overall criteria for selecting a Phase II
option.
Project Results
Task I: Identifying Strengths and Weaknesses of Options
At each public meeting, individual teams presented their responses
to each of the options listed above. The responses of all teams
for all meetings were compiled for this report. The responses of
any individual team can be found, by meeting, in the appendix.
Below, in discussion of various favored options, a sampling of
responses across teams and meetings is presented.
Option Responses:
Across the board, meeting participants identified Option #6, "State
Target Selection Consistent with Federal Criteria - State NPDES or
non-NPDES Control" and Option #4. "Tiered Federal and State Target
Selection - Tiered NPDES and Non-NPDES Control" as their most
favored options.
Option #6, which would have States target high risk sources based
upon Federally established criteria for selection and would include
Federal oversight of State programs, was seen to provide the
consistency needed nationwide for target selection while still
allowing states the flexibility needed to control sources and
identify high-risk polluters. This option was seen as easily
incorporating a watershed approach, and including both point and
non-point sources. Some of the strengths identified for Option #6
included:
• uniformity of selection criteria of sources among States;
removal of the burden on States to develop selection
criteria of their own;
• the_flexibility to allow non-point source controls;
giving States, who are closer to the problems and issues,
more input into the decision-making process;
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giving States more latitude to develop programs which
meet their own needs and high risks;
establishing a partnership model between EPA and States,
not a command-and-control model.
Some of the weaknesses that participants associated with Option #6
included:
the probability that there would be inconsistencies
between States on requirements;
that it does not protect unimpaired waters, because the
focus is on remediation not prevention;
• the potential for disagreement between State and Federal
levels on the criteria established. The State may differ
in the prioritization of pollutant sources;
that Federal criteria may not be applicable to the State
because of geographic, industrial, or other unique
characteristics;
a State may not have the resources to handle the program;
the potential for State and local disagreement over
controls used;
that it could penalize progressive States that have
already taken the initiative to develop a program, only
to have EPA set criteria that don't "mesh" with their
progress;
the possibility that industries with multiple facilities
in different States would have to deal with differences
in requirements, timing, etc.
Option #4 was identified by participants as the next most favored
option. According to that option, EPA would identify the first
tier of high risk sources, and then the States would target
additional sources as appropriate. The EPA-targeted sources would
be permitted by EPA or delegated States, and then the States would
have the latitude to use a range of control strategies for
additional identified sources. Some of the strengths that teams
listed for Option #4 included:
would allow for quickly addressing severe problems, so
the State would have more time to deal effectively with
other problem sources they identified;
• provides more options for compliance in its latitude for
control strategies;
allows States more discretion and time to identify and
prioritize sources;
provides a potential advantage for industries to keep
themselves clean enough so that they are not targeted for
(State-selected) Tier II. This option might act as an
incentive to get industries to focus on pollution
prevention;
-------
offers the ability to incorporate less resource-intensive
controls to lesser risk sources such as 404-type permits;
Tier I allows non-contributors out of the system (since
EPA would be targeting only determined high risk
sources);
seems to be more equitable than Phase I targeting and
control strategies.
permitting provides a clear point of control, i.e. the
"gorilla in the closet".
Some of the weaknesses that teams associated with Option #4
included:
• the time and expense of performing risk assessments,
which the States would need to do in order to target Tier
II sources;
• promotes 'buck-passing' of responsibility between Federal
and State levels;
• the possibility that it would create inconsistencies
among States for 'targeting and controlling industrial
categories (high risk sources);
• EPA/State coordination could be difficult, which could
prolong the time it would take to implement this option;
• the potential inconsistencies that could occur for States
regulating interstate waters, e.g. Chesapeake Bay.
EPA may not have adequate information to screen and
identify high risk sources on a national basis.
There did not seem to be a consistent "worst choice" option among
meetings. However, among teams at the Dallas meeting, one option -
Option #7, in which high risk sources would be selected at the
Federal level and controlled through NPDES permits - stood out as
unfavorable for six out of eight teams. Their common reason was
that the Federal level would be the primary decision-maker in this
option. Across all meetings, teams favored options that promoted
a system of shared decision-making and responsibility reflecting
the need for a partnership between Federal and State entities.
In one of the Washington public meetings, two options - option #5,
in which high-risk sources would be Federally selected, with no
provision for Federal oversight of control mechanisms; and Option
#1, in which States would select sources and controls, with no
provision for Federal oversight - were deemed the least favorable.
In terms of Option #5, participants did not see the federal "teeth"
that they felt would be needed to enforce the program. Many people
across meetings felt that if there was not "the gorilla in the
closet", i.e. the threat of EPA enforcement of the regulations
after incentives were tried and failed, the program would not work.
-------
Sentiment was similar regarding Option #1, and again centered
around the sense that some States would do very little if the
Federal government were not driving them.
It was quite apparent that, while involved groups do not want a
standard command and control situation with every aspect of the
program dictated at the Federal level, they still see a need and
role for Federal regulatory enforcement as a motivator to get
States and the regulated community to implement effective storm
water programs.
Task II: Contributors to Program Success
The purpose of Task II was to have participants identify the
critical factors that would help to ensure a successful storm water
program, no matter which option or combination of options was
selected. Teams were asked to identify the essential and basic
components of a program that they believed would be required for.
the program to be successful. Further, they were asked to advise
EPA on what the agency needed to avoid doing in order to further
ensure successful program outcomes.
A summary of team responses to each of these tasks is. presented
below.
Task II a: Key Components for Program Success
Teams were asked to identify and list what they believed to be the
key components of a successful storm water program. Responses to
this task differed between group representation (e.g. State
government, local government, etc.) and geographic region. There
were, however, common components listed by teams across meetings.
The first four items were mentioned by more than half of all work
teams; the remainder were mentioned by 25-50% of the teams. The
items teams identified as key to a successful program included: (in
parentheses are comments made by some of the individual teams re:
the item)
Public education and awareness programs (e.g. through
trade associations, at schools, use of various media -
everybody needs to be educated);
Training for regulators and the regulated community
(e.g. for States, regions, permit writers, permittees;
periodic regional/national meetings; hands-on training
for municipalities and industry; dialogue and feedback
between EPA, States and locals; technical assistance);
-------
3.
4.
6,
7,
9.
10
Timely guidances (get guidances out ahead of time as
regulations are passed; provide guidance on technology
transfer and innovative technology; include case studies
and a data clearinghouse);
Determination of what lessons were learned from Phase I
of the program, and mechanisms for Phase II that will
allow tracking and assessment of the program within
reasonable timeframes. A key factor is to allow enough
time for an adequate review process of Phase I to see how
Phase II could build on and expand those efforts;
Clear regulations (e.g. straightforward as possible; user
friendly, clarity of coverage/applicability; clarity in
criteria; be more specific in naming industrial
activities covered under the regulations);
Use of a Watershed approach to implement the program;
National guidelines for the program (e.g. identify
measurable goals for regulated sources, standards,
designated use impairments, mechanisms for oversight,
long range planning; recognize cost and implementation of
compliance; provide realistic measures of success);
A phased-in approach for the Phase II program (e.g.
reasonable time schedule, long-term phase-in). The most
common timeframe mentioned by teams was 3-5 years for
program implementation?
Pollution prevention incentives (send out guidance on
pollution prevention to potentially regulated facilities
now; offer exemptions; reduce requirements as an
incentive for successful use; possibly provide a menu of
programs on pollution prevention plans from which
entities can pick and choose);
Program flexibility (e.g. to change deadlines based on
hydrological flow; to implement and use elements of a
watershed approach to bring in stakeholders and implement
a program) .
Approximately half the teams noted that there need to be some
dedicated funding sources available to States, local government and
permittees to assist in successful implementation of these program
components. Teams felt that EPA should either provide funds or
provide guidance on how States and local governments could
implement fund-generating systems, e.g. storm water utilities.
Team suggestions included: funding could first be made available
through congressional appropriation to EPA to help programs start,
and then programs could generate on-going funds through permit
8
-------
fees; EPA should make available federal grants and loans to States,
locals and permittees.
Task II b: EPA Actions that would be a Barrier to Program Success
Teams were asked to identify and list those actions that EPA should
avoid taking lest those actions prevent programs from being
successful. The actions most frequently mentioned include:
1. Unnecessary/unusable program requirements, including
excessive monitoring, unrealistic BMPs and compliance
criteria, cost-prohibitive Best Management Practices;
2. Fully developing requirements before pilot testing
various proposed components of the program to catch
inconsistencies, problems,-etc. In other words, do small
scale testing of program elements and use knowledge
gained from those pilot tests to refine the regulations
before they are put into effect;
3.
4.
5.
Unrealistic deadlines and goals;
Implementing program regulations
dedicated program funding;
without providing
Promulgating the requirements without providing written
guidances and technical assistance concurrent to doing
so.
Criteria for Selecting A Phase II Option
The final meetings brought together storm water experts from across
the country to . develop an option in detail for the Phase II
program. One of the products from those meetings was a developed
set of criteria on which to base option selection.
Those criteria are that the program:
1. Does not rely solely on the actions of just one player.
The program needs to include multiple levels: EPA,
States, targeted municipalities and industries. For
example, the Federal government should not be designer
and decision-maker, educator, enforcer and funder. The
program needs a balance of players across levels, each
with a clearly defined role. Also, there needs to be a
clear avenue for intervention at the Federal level if
States or municipalities fail to implement the program,
i.e. "the gorilla in the closet".
-------
5.
6.
Provides clear guidance and unambiguous targeting
categories and words (e.g., words like "sufficient"
should be avoided, at least if there is no way to define
what they mean in a given context) . Simplicity and
clarity should be favored; words that are ambiguous or
hazy should be avoided. The regulations must be clear to
the regulated community in terms of goals, objectives and
implementation if EPA is to gain "buy-in" from them.
Provides the resources (not only dollars, but people as
well) or suggests how they can be obtained for that
option. The program needs to be clear on who pays for
what, e.g. Federal, State, local, permittee.
Is flexible, especially in recognizing regional and local
differences, not only in terms of storm water pollutant
loadings but also in terms of their environmental impact.
For example, even if all gas stations put out an equal
volume of pollution, the environmental impact may vary
depending on location. Or as another example,
recognition of the vast differences between States, such
as mid-Atlantic compared to Southwest, which would mean
a vast difference in what they need in terms of a storm
water program.
Needs to be nationally consistent in the underlying
methodology used, i.e. consistent national guidelines,
identified goals, measures of success, etc. while at the
same time recognizing regional differences and allowing
flexibility to implement a program that 'best addresses
the particular characteristics of local problems.
Emphasizes the need for program responsibility and
authority that is "pushed" down to a local level. The
sense of some of the participants in this meeting was
that the best understanding of the problem and how to
deal" with it is the people closest to the problem who
have to deal with it, i.e. local problem/local government
and groups. Note: People representing local government
at the meetings were extremely concerned about the lack
of resources and technical expertise that might be found
at the local level in many situations. The need for
adequate funding was again identified as a critical
issue, and some suggested that utility districts would be
the only real way to fund the program unless the cost is
low enough that it could be covered in a regular budget.
The group agreed as a whole that resources and technical
expertise not withstanding, this program must be accepted
and supported at the local level if it is to be
successful.
10
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Provides the opportunity to integrate other water issues
and concerns—e.g., groundwater. For example,
restriction on certain BMPs affects groundwater impacts.
The methodology used should allow integration with
groundwater, habitat, and other water programs. It needs
to integrate or be compatible with other sections of the
Clean Water Act, e.g. right now 402 causes 401 and 404
compliance problems.
Needs to build on and tie to Phase I, where much work was
done and where momentum has been established. A lull now
means the need for a new start up - right now the energy
level is high and awareness of the storm water program
has been growing, so EPA needs to tap into that forward
movement. If EPA waits too long in getting Phase II out,
inertia will set in, and it will take much more energy
and effort to get it in place. And the talented people
will go on to something else (208 was given as an
example).
Other key areas of expert discussion around Phase II program
considerations included:
1. EPA needs to recognize the potential gaps between "best
efforts" and performance standards. On the one hand, we have
a variety of ways of characterizing best efforts: Best
Management Practices (BMP's) and Maximum Extent Practicable
(MEP) are examples. These are inputs, presumed to influence
water quality. On the other hand, we have water quality
standards that are outcomes. One question: what do we do if
people follow BMP's and water quality does not improve to the
standards we set? What if the "maximum extent practicable" is
deemed in place and we still have an outcome shortfall?
2. Two distinct structural premises are in play. One is of
a national program which is administered by the States. In
this view, EPA provides mandates, and supports state and local
efforts to reach them. The other premise is more
decentralized. It is seen as a set of State programs and
initiatives which share a national performance target. In at
least some respects, the structural premise held suggests
different programmatic approaches in such areas as desired and
allowable variability among states and localities.
3. Much wisdom about storm water controls are not readily
generalizable. BMP's in the residential development field,
for example, were said, by some experts, to hold true for a
scale of 5 - 50 acres. And many watersheds for which
solutions are designed are actually very small. It is hard to
"scale up" answers.
11
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4. Program "champions" are often a factor in program
success. One expert observed, and others agreed, that the
individuals involved in storm water programs were as much a
reason for high program performance as was the program plan.
We should be careful to allow for this factor in the emphasis
on rules, procedures, and even workplans.
5. Pollution prevention should be emphasized. While often
anecdotal, a variety of examples were offered of situations in
which preventive steps solved a water quality problem. These
examples, like the Puget Sound program discussed in our
earlier report, were generally focused and interactive. They
did not rely on the spread of information alone to prompt
changes in behavior.
6. EPA needs to allow state and local flexibility to address
priorities as they have identified them. The theme of
selectivity combined often with local flexibility, e.g., in
some areas, a little more grease has a tremendous negative
impact on the environment. In others, it does not.
Selectivity on targeting is also clear, e.g., that BMP's on
new land development (commercial as well as residential) would
pay high dividends vs. other generalized targets.
7. Several equity or fairness issues emerge and persist.
One concerns those sources targeted. If a discharger has done
everything in their permit — all the BMP's are in place —
and the water is still dirty, is 'he or she liable? Another is
the distinction between larger organizations (corporate or
municipal) with resources to handle permits and processes and
much smaller ones which lack that capacity. To what extent is
the same rule as "fair" for the small town as for the big
city?
8. The Federal role in the program to establish a partnership
with States, and be an enabler rather than an enforcer.
Participants felt that EPA's responsibilities would be to
develop national goals and guidelines, set national selection
criteria, establish a selection methodology, and develop a
universal methodology for selecting controls that would allow
programs to choose alternatives based upon their needs, e.g.
regional and local differences. Participants felt strongly
that Federal oversight is a necessary component to ensure that
States do implement programs, i.e. be the "gorilla in the
closet". However, in a partnership capacity, participants
felt EPA should first be ready to provide support and
technical assistance rather than punitive measures to programs
that were not meeting standards despite best efforts.
12
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APPENDIX J
SUMMARY OF PHASE H COMMENTS
-------
-------
Appendix J
Organization of Phase II Comments
I. Targeting
A. General Targeting Approaches for Both Municipalities and Industries
,,
• Examine Phase I data before selecting Phase II sources, [l.g.iv]
• Amend CWA and eliminate Phase II/ cover additional sources under Phase I
[La]
• Establish requirements for State storm water programs to identify additional
sources, [l.fj
Yes
52
28
18
No
0
7
5
Examine Phase I data before selecting Phase n sources, [l.g.iv]
The majority of the commenters (52 commenters) agree that a close examination of
Phase I is essential before launching into Phase II. Many of these commenters also
stressed that EPA should complete the Reports to Congress, as specified under section
402(p)(2)(5) of the CWA. Such an examination would allow EPA to evaluate whether
the current approach is achieving the intended goals, or whether another approach to
storm water permitting would be more effective. As discussed hi detail later,
commenters expressed a number of concerns about the storm water program,
including 1) the high cost associated permit compliance and program administration;
2) the ineffectiveness and inequity of "blanket coverage" of particular industrial
activities that do not pollute while other "bad polluters" remain unregulated; and 3) a
general uncertainty about the goals of the storm water program and whether, hi fact,
these goals are being achieved under current program.
Amend CWA and eliminate Phase II by covering additional sources under Phase
I; administer through NPDES or section 319 (NFS) or section 6217 (CZARA).
[l.a]
To address these problems associated with Phase I, commenters indicate that a change
hi how facilities are targeted is necessary. Of the 91 commenters, approximately a
third (28) favor amending the CWA to eliminate Phase II of the storm water program
and to bring additional sources under Phase I. As far as regulating these Phase n
sources under Phase I, the majority of commenters prefer a continued reliance on the
NPDES program as opposed to State non-point source programs (funded under
Section 319 of the CWA and/or section 6217 of the CZARA). While commenters
support continued reliance on NPDES, they overwhelmingly agreed that Phase II
J-l
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Appendix J
sources should not be targeted by EPA headquarters but rather by State and/or local
entities.
These commenters argue that by eliminating Phase II and bringing additional sources
under Phase I, the problems associated with Phase I storm water permitting will be
most effectively addressed. In particular, by designating facilities under section
402(p)(2)(E), States can target those industrial activities that are impacting sensitive
watersheds and/or posing the greatest environmental risk. One State agency notes
EPA should "maintain national data for determining environmental risk, establish
priorities for additional activities to be covered under a storm water permit, and
coordinate compliance, enforcement and educational information among the States."
The majority of commenters believe that designation authority hi tfie hands of the
State would be the most cost-effective targeting approach. However, other
commenters express concern over shrinking State budgets and indicate that additional
funding would be needed, particularly if the program were administered under section
319.
Those commenters opposing the elimination of Phase II (7 commenters) argue that for
reasons of equity Phase II sources should be subject to the same requirements as
Phase I. The concern is that State designation of Phase II sources may result hi
inconsistencies throughout the country. One municipality argues that hi order to
effectively protect water quality, smaller municipalities should be required to develop
the same storm water management programs as the medium and large municipalities
were required to under Phase I.
Establish requirements for State storm water programs to identify additional
sources, [l.fj
18 commenters out of 91 commenters favor the targeting option whereby EPA would
establish Phase II requirements for State NPDES storm water programs to identify
additional sources. 5 oppose this option.
Those supporting this option believe that States and local entities (not EPA) should be
identifying additional sources for Phase II permitting, adding that EPA should
somehow direct the States and municipalities to develop programs appropriate to their
unique requirements and monitor the progress of these programs. As far as EPA's
exact role hi this process, some commenters assert that EPA should establish baseline
effluent limitations for particular industries and then establish control measures for
these industries. Other commenters believe that such determinations should be made
by the State, with EPA maintaining its important role as an information and guidance
clearinghouse. One State agency writes that "minimum criteria hi the area of funding
levels and educational requirements seems appropriate." These commenters indicate
J-2
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Appendix J
that this approach is preferable as it establishes consistent criteria for the development
of State storm water programs.
B. Options for Targeting Phase II Industrial Sources
V sv. v. ™ .. ,
• Geographic Targeting: Designate additional individual sources in
watersheds of concern (those not meeting designated water uses) and hi
specific rainfall zones [l.e/l.g.i]
• Focus on high-risk polluters and exempt facilities that don't pollute.
[l.d/l.g.ii]
• Rely on Phase I MS4s to target industrial sources that discharge through
. their system, [l.c]
Yes
48
39
9
No
5
3
11
Geographic Targeting: Designate additional individual sources in watersheds of
concern (those not meeting designated water uses) and hi specific rainfall zones.
Almost half of the 91 commenters (45 commenters) support targeting sensitive
watersheds, i.e., those that have high pollutant loadings and/or those not meeting
designated uses. These commenters argue that such an approach is the most cost-
effective way to improve the quality of the Nation's water. (Please note that within
this category, more commenters support permitting watersheds under the NPDES
program than under State nonpoint source programs). Commenters suggested that this
approach should be coupled with identifying the industry "bad actors" within
watersheds of concern. (Identification of "bad actors" is discussed in the following
section).
A number of commenters believe that watersheds should be prioritized based on
criteria such as threats to high quality resources or significant degradation. One
industry offered the following suggestions for a watershed strategy: "1) Conduct a
survey of receiving watersheds and rank them based upon their designated uses and
level of contamination; 2) Identify and prioritize major sources of pollutant loadings;
3) Analyze the control measures to control these pollutant sources and prioritize them
based on cost effectiveness." Some commenters stress the importance of developing
national criteria for evaluating watersheds so as to avoid inconsistencies among
different regions.
J-3
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Appendix J
In terms of evaluating watersheds, commenters suggest using the following CWA
mechanisms: Section 303(d) which prioritizes a ranking of waters, section 305(b)
which describes water quality of all navigable waters in the State, section 319
watershed listings, and section 304(1) which lists waters not expected to meet water
quality standards. Some commenters suggest that sampling data from Phase I cities
be used to generate regionalized watershed loading criteria.
Regarding costs, a number of commenters agree that targeting watersheds would be
more cost-effective for both industries and States than current targeting strategies.
However, some States express concern over the cost of gathering watershed-specific
information in a timely manner. One State argues that "entirely too much effort
would need to be invested to determine what waters have been negatively impacted by
storm water runoff. Using the lists from 305(b) reports is not sufficient nor
acceptable."
As far as designating specific sources by rainfall zone, there was some scattered
support for this measure. However, most commenters agreed that it could be difficult
and costly to generate timely, meaningful data that could justify variances or special
conditions between regions.
Focus on high-risk polluters and exempt facilities that don't pollute, [l.d/l.g.ii]
Nearly half of the commenters (39 commenters) supported targeting high-risk
industrial polluters. Only three commenters opposed the option. As discussed above,
many commenters believe that targeting of "bad actors" should be linked to the
targeting of sensitive watersheds.
In general, commenters feel that the Phase I targeting of industries based on SIC
codes was not cost-effective. In addition, many commenters believe that a number of
the big industrial polluters were not included under Phase I of the storm water
program. Commenters unanimously agree that bad actors who are contributing to
water quality degradation should be targeted for Phase II permitting, while those
"good actors" who don't pollute should be exempted. This approach, commenters
say, would reduce the regulatory burden on all those facilities that are not
contributing to water quality problems.
One State agency stressed that determinations of "bad actors" must be done on a State
or local basis, not by EPA. "Controlling activities that are specifically designated by
EPA could be a significant waste of time and resources if a particular jurisdiction has
other activities that contribute to higher pollutant loads." This commenter suggested
using data gleaned from municipal applications to determine Regional water quality
information.
J-4
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Appendix J
As far a which particular "bad actors" should be targeted under Phase II, commenters
suggested the following industries: gas/auto service, State highways, large parking
lots (malls), tank farms, commercial activities with industrial components, and
construction activities of less than five acres. Please note, however, that a number of
trade organizations representing the above industries submitted lengthy comments
outlining why their industries do not pose environmental risks.
Those commenters opposing the option (3 commenters) claim that focusing on "bad
actors" is a reactive strategy rather than a preventative one. Further, one commenter
argues that using impairment would be imprudent as States (after more than a decade)
still have not completed inventories of their waters. The commenter further states
that agricultural runoff and irrigation return flows, which are exempted under the
CWA, constitute some of the worst pollution in the country. One commenter
suggests the continued use of SIC codes but with exemptions provided for those who
have proven that they don't pollute.
Rely on Phase I MS4s to target industrial sources that discharge through their
system, [l.c]
11 commenters opposed the targeting option whereby Phase I MS4s would target
industrial sources discharging through their systems; 9 commenters supported the
option.
Those commenters opposing this option feel that the burden of regulating Phase n
industrial dischargers would be too great, and that this role rightfully belongs to the
State. Further, commenters believe that water quality problems are not confined to
individual municipalities, but rather they span entire watersheds. These commenters
argue that standards would not be uniforni~or efforts might not be coordinated—
between different municipalities and, therefore, regulation through State or EPA
would be more equitable. Municipalities indicate a willingness to assist States in
targeting Phase II sources, for example, by providing a list of potentially high-risk
industries. Commenters supporting this option believe that because Phase I
municipalities already have their storm water management plans hi place, they are the
most appropriate entity to identify additional sources under Phase II.
J-5
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Appendix J
C. Options for Targeting Phase II Municipalities
' 1 " ' ,'v,a ,./" •X'- ?i ••""",'•, ,
• Identify MS4s based on population, population density, and/or
population growth, [l.b]
• Geographic Targeting: Designate additional municipal sources
impacting watersheds of concern (those not meeting designated water
uses) and in specific rainfall zones [Le/l.g.i]
• Permit small municipalities but establish simplified application
requirements, [l.g.iii]
Yes
20
48
15
No
20
5
1
Identify MS4s based on population, population density, and/or population
growth, [l.b]
Commenters are split evenly (20 hi favor, 20 against) Phase II MS4s being targeted
on the basis of population, population density and/or population growth.
Commenters hi support of this approach argue that municipalities having particularly
dense populations and those experiencing intense population growth due to new
development should be of primary concern under Phase II of the storm water
program. One commenter also notes that MS4s could be targeted on the basis of
watershed population. At any rate, numerous commenters agree that effective Phase
n storm water programs must be coordinated on a regional basis [perhaps hi
conjunction with those already established under Phase I]. This would allow for the
development/implementation of regional policies and regional BMPs, and would
facilitate addressing specific issues such as land use, structural controls and
construction activities. As discussed later, the majority of commenters supporting this
approach also advocate the establishment of simplified permit application
requirements.
The majority of the comments opposing this option are from small municipalities.
Approximately half of these commenters believe that municipal storm water
management should be conducted on a watershed basis rather than by determining
population density and/or growth. The other half opposes Phase II regulation of small
municipalities altogether. "Phase II regulations will have a very significant impact on
municipal budgets if implemented similar to Phase I," 11 municipalities wrote.
"These will entail increased staff levels, testing, consulting fees and other costs which
are unduly burdensome, particularly where there is no Phase I documentation to show
J-6
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Appendix J
that environmental quality is enhanced." Of primary concern among municipal
commenters is the astronomical cost associated with completing municipal storm
water permit applications. They argue that funds do not exist to implement the storm
water program and that political pressures would prevent them from securing storm
water utilities.
Geographic Targeting: Designate municipalities impacting watersheds of concern
(those not meeting designated water uses) and in specific rainfall zones.
[l.e./l.g.i]
As discussed under the "Industrial Targeting" section, nearly half of the 91
commenters (45 commenters) support targeting sensitive watersheds, i.e., those that
have high pollutant loadings and/or those not meeting designated uses. While
targeting these watersheds can help identify significant industrial polluters, many
commenters also believe that this approach is useful in identifying MS4s for storm
water permitting.
These commenters argue that since watersheds are oftentimes a patchwork of rural,
suburban and urban lands comprised of incorporated and unincorporated areas, storm
water permits should apply to the jurisdiction as a whole, not just to individual
municipalities within the watershed. Commenters note that in watersheds of concern,
all Phase II municipalities could become co-permittees with Phase I municipalities.
Where it is determined that watersheds are not polluted, Phase II municipalities would
not be required to obtain a storm water permit. This option provides opportunities for
municipalities to reduce administrative burdens, consolidate efforts to study or
evaluate approaches, and greatly reduce costs of program development and
implementation. Although a great deal of regional coordination would be requked,
commenters believe that such an approach would yield the greatest envkonmental
benefit.
(Please refer to the "Industrial Targeting" section for a summary of options for
targeting on a watershed basis).
Permit small municipalities but establish simplified application requirements.
15 commenters support the idea of permitting small municipalities but establishing
simplified application requirements. Arguing that Phase I municipal permit
application requirements (particularly Part 2 requkements) were burdensome and
overly costly, these commenters suggest that Phase II municipalities be covered under
a simplified general permit that requires a storm water management plan and flexible
watershed-specific monitoring requkements. One commenter suggests the following
components of a Phase II municipal program: 1) Sediment and Erosion Control:
J-7
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Appendix J
Applicants incorporate erosion control into the development review and local
permitting process; 2) Storm Water Quality Control: Applicants incorporate storm
water BMPs into the municipal development review and approval process and into
municipal operations; and 3) Illicit Discharges: Applicant prohibits illicit connections
and improper dumping, he/she develops a spill prevention and response plan.
A.
Control Strategies
General Control Strategies for Both Municipalities and Industries
•
•
•
;-/__- •^&&2*:t'^" ^
Continue to rely on NPDES programs; use NPDES general
permits that focus on BMPs. [2.a/2.d.i]
Rely on nonpoint source programs administered under section 319
of the CWA and section 6217 of CZARA. [2.b]
Establish mandatory national Phase II performance standards
without a permit. [2.c]
Yes
32
20
14
No
4
3
10
Continue to rely on NPDES programs; use NPDES general permits that focus on
BMPs [2.a.]
Approximately 32 commenters favor the continued use of NPDES programs to
regulate storm water discharges. 19 commenters prefer reliance on State nonpoint
source programs under section 319. Most commenters state that it would be
inefficient to discontinue the current program, and, as one commenter notes,
displacing the NPDES program would "create a significant amount of confusion
among authorized NPDES States and the regulated community." Additionally, the
NPDES storm water permit program is in the initial stages of development and results
may not be realized for at least two years. The majority of the commenters who
support reliance on the NPDES program encourage use of general permits, for an
"emphasis on the development of effective programs, not on lengthy and expensive
application processes." Most commenters believe that BMPs are a more effective
control strategy and a better allocation of resources than monitoring and numeric
effluent limitations. BMPs utilized should be those which proved cost effective for
Phase I sources.
J-8
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Appendix J
Rely on nonpoint source programs administered under section 319 of the CWA
and section 6217 of CZARA. [2.b.]
Approximately 21 commenters favor the use of State nonpoint source programs and/or
section 6127 of CZARA to regulate Phase II storm water discharges. Many of these
commenters assert that storm water runoff is a nonpoint source rather than a point
source and therefore should be regulated under section 319. Moreover, State
nonpoint source programs are already developed and utilizing them would lessen the
repetition of water quality programs. Several commenters emphasize, however, that if
State nonpoint source programs were expanded to include storm water runoff,
additional funding would be essential. Those commenters that supported the use of
section 319 see it beneficial in that the program encourages flexibility through
voluntary control measures, pollution prevention, and watershed planning. Several
commenters express some trepidation that nonpoint sources may be moved under the
NPDES program, and assert that nonpoint sources should continue to be covered
under section 319, not NPDES.
Establish mandatory national Phase II control strategies without requiring a
permit. [2.c.]
Commenters are fairly divided on whether EPA should establish national control
strategies for Phase II sources. Various statements from the 12 commenters who
support mandatory guidelines indicate that this approach would be cost-effective and
would alleviate the administrative burdens of permit applications. A few commenters
also state that, hi order to be most effective, the guidelines and management practices
should be industry-specific. A model that is mentioned by several commenters is the
Puget Sound Water Quality Management Plan and the Washington State Department
of Ecology's Stormwater manual for the Puget Sound Basin. These commenters
suggest that all States adopt a similar storm water management plan which would be
required to at least meet a national standard; all municipalities within the State would
have to adhere to the plan.
11 of the commenters who address this control strategy oppose mandatory national
control guidelines for Phase II activities. Several commenters believe it would be
difficult to effectively notify and educate the general population concerning the details
of such a program. Other commenters express concern that the diversity hi climate
and topography throughout the country requires more flexibility than national
standards would provide.
J-9
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Appendix J
B. Key Elements of a Control Strategy
"" '„„,,, " ,^B>^^? ' '\ "'
• Focus on education for public and affected industry. [2.d.ii]
• Emphasize pollution prevention incentives and BMPs, particularly
for new development. [2.d.iii]
• Establish correlation between severity of pollution and controls
required, using fines to aid implementation. [2.d.iv]
Yes
18
17
3
No
0
0
0
Focus on education for public and affected industry. [2.d.ii]
14 commenters state that education needs to be a primary focus of the Phase II
program. One commenter notes that EPA should "keep it simple," particularly on
issues on coverage, since Phase II dischargers may be smaller and less familiar with
environmental regulations than Phase I dischargers. Commenters unanimously stress
the importance of public education and outreach. They urge that EPA/States 1)
distribute guidance documents and fact sheets prior to implementing the rule, 2)
provide examples of pollution prevention programs, 3) conduct workshops, 4) prepare
video presentations for distribution, and 5) launch public education campaigns geared
towards explaining water quality problems associated with storm water.
Emphasize pollution prevention incentives and BMPs, particularly for new
development. [2.d.iii]
14 commenters support an emphasis on voluntary pollution prevention programs.
This approach is favored because of its cost-effectiveness, flexibility, and reduction hi
regulatory burden. Additionally, several commenters indicate that it would establish a
'partnership' between the regulated community and regulatory agencies by
encouraging dialogue and guidance concerning pollution prevention techniques. One
State notes that the voluntary measures hi its nonpoint source program have proven
very successful in improving water quality, and that similar practices could be
implemented for storm water runoff. The State recommends, however, that voluntary
approaches be used hi conjunction with mandatory approaches and that "provisions be
included for requirements placed on 'bad actors' if cooperation is not attained through
the voluntary programs." Numerous commenters point out that education would need
to be far-reaching if the voluntary programs were implemented.
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Appendix J
Establish correlation between severity of pollution and controls required, using
fines to aid implementation. [2.d.iv.]
Only 3 commenters address this control strategy, and all 3 support a correlation
between severity of pollution and controls required. One commenter writes that,
"market based incentives structured to incorporate true economic externalities
associated with pollution can be a valuable tool hi helping society balance economic
growth and levels of pollution." Another commenter notes that State agencies should
administer the fine/implementation system, as States can adjust their controls based on
the types of pollutant sources and sensitivity of the watersheds in a particular region.
HI. Deadlines
A. Options for Program Deadlines [3]
., ,,
• October 1, 1995 or later
• Prioritize sources; establish phased deadlines
• Eliminate Phase II; no deadlines
• Pending thorough review of Phase I
• H.R. 6167 deadlines satisfactory
• Before October 1, 1994
Yes
12
3
1
20
3
3
No
Commenters unanunously feel that Phase II should not be implemented until a
thorough review of Phase I has been completed. A number of these commenters
indicated that Phase II regulations should not be published before October 1, 1995.
J-ll
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Appendix J
IV. Costs/Regulatory Burden
A. Issues associated with costs and regulatory burden
Balancing the need to protect the environment with the cost-effectiveness of
the program [HI.A.2]
Examining the impacts of the storm water program on small businesses and
communities pn.A.7]
Assessing the regulatory burden on permittees and regulators [m.A.3/IH.A.4]
General Cost/Benefit Concerns
Nearly a third of the commenters (26 commenters) express concern over the costs
associated with implementing the storm water program, and whether these costs
justify the need to protect the environment.
Municipalities, in particular, voice concern over the costs associated with completing
municipal permit applications and implementing storm water management programs.
One commenter argues that while cities across the nation have spent over $1 trillion
dollars to implementing the program, water quality is not significantly improving
because of upstream discharges not regulated under the CWA. This commenter
further states that since urban runoff affects only 11% of river impairment and 29%
of lake impairment, the price tag of implementing storm water management programs
is not justified. (Please note that a number of commenters question EPA's
methodology in 305(b) reports as it pertains to assessing "designated uses" for
waterbodies).
Comments indicate that across the board—among cities, small business owners, and
trade associations~the storm water program is viewed as a major financial burden on
communities and industries. Of particular concern for cities (and especially small
cities) is the number of growing number of projects/regulations that need to be
supported by shrinking municipal budgets. Generating a storm water utility to
support the program has proven politically difficult in a number of cities. On the
industrial side of the program, there are equally as many concerns over costs and
benefits. In particular, commenters argue that a number of small industries which
pose little risk to the environment were required to apply for a storm water permit
under Phase I, while "higher risk" industries such as oil and gas, agriculture, and
retail gasoline facilities were not covered by the rule. A number of small industries
claim that sampling is cost-prohibitive and that the quantitative data generated are
oftentimes inaccurate/meaningless. Regarding Phase II, one construction operator
J-12
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Appendix J
argues that inclusion of construction operations under 5 acres would render these
small-scale activities cost-prohibitive.
Strategies for Phase II
In closing, commenters offer the following suggestions for maximizing cost-
effectiveness and environmental benefit under Phase II:
• Phase I of the storm water program must be thoroughly assessed in terms of
dollars spent and environmental benefits gained before launching into Phase II.
• EPA and/or States must incorporate a more realistic benefit/cost analysis of
Phase II, particularly for the municipal side of the program.
• Under Phase II, emphasize storm water management and pollution prevention
rather than sample gathering and analysis. (A number of the quantitative
requirements under Part 2 of the municipal permit application were viewed as
unnecessary and overly costly)
• EPA and States should use data generated from Phase I of the program so as to
make Phase II more cost-effective and environmentally beneficial.
• Rely more heavily on State or local entities for storm water program
administration.
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Appendix J
V. General Concerns/Issues Related to the Storm Water Program [4]
Lack of adequate outreach/public education/timely guidance during Phase I
resulted in confusion about:
* Which facilities are subject to regulation (use of SIC codes viewed as
confusing, inappropriate)
The types of permit application options available
Deadlines
The relationship between the industrial and municipal programs
The overall relevance of the program
*
*
*
*
Confusion resulted from different requirements in different States (i.e., those
with approved NPDES programs and those without) particularly in regards to
the group application process.
Lack of adequate outreach/public education/timely guidance during Phase I
resulted in confusion over a number of issues, including:
Use of SIC codes. A number of commenters indicated that there was widespread
confusion during Phase I over which facilities were subject to regulation. In
particular, the use of SIC codes to determine regulatory status was viewed as
confusing. Multiple activities commonly occur at a single facility and people were
frequently unclear as to how they are classified under the SIC code system. Due to
this excessive confusion, commenters generally feel that SIC codes are an ineffective
way of targeting facilities for regulation under the storm water program.
Application Options. Commenters complained that the storm water permit
application options were not spelled out clearly in the beginning of the program. In
particular, some expressed anger over the group application process. One commenter
notes that while the group application option seemed preferable a year ago, it became
clear that this option was problematic given that certain States are not accepting group
applications as legal coverage. In addition, a number of group applicants would have
opted for coverage under the general permit had that option been available in the first
place. Commenters resented that it was oftentimes necessary to hire expensive
consultants simply to understand the regulations and stay informed of their application
options.
Deadlines. Commenters indicate that there was confusion surrounding permit
application deadlines. In the future, this could be alleviated by improved outreach
and public education.
J-14
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Appendix J
The relationship between the industrial and municipal programs.
One commenter recommends separating municipalities and industries into two distinct
rules so as to avoid confusion over the differences between the two programs.
The "Big Picture" of the storm water program. As discussed throughout this
report, commenters seem frustrated over the fact that huge costs are being incurred to
implement the storm water program without a clear indication that environmental
benefits are being achieved. Commenters write that it essential for EPA to step up
public education and outreach efforts hi the future.
Confusion resulted from different requirements in different States (i.e., those
with approved NPDES programs and those without) particularly in regards to the
group application process.
Numerous commenters state that the conflicting time frames between States and EPA
in developing and issuing the permits created enormous confusion for the regulated
community. As discussed above, this situation was particularly frustrating members
of group applications.
J-15
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APPENDIX K
SELECTED MANAGEMENT MEASURES DEVELOPED UNDER
SECTION 6217 OF CZARA
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Appendix K
SELECTED MANAGEMENT MEASURES DEVELOPED UNDER SECTION 6217 OF
CZARA1
MANAGEMENT MEASURES FOR URBAN AREAS (Chapter 4 of CZARA guidance)
I. INTRODUCTION
H. URBAN RUNOFF
A. New Development Management Measure
(1) By design or performance:
(a) After construction has been completed and the site is permanently stabilized, reduce
the average annual total suspended solid (TSS) loadings by 80 percent. For the
purposes of this measure, an 80 percent TSS reduction is to be determined on an
average annual basis,2 or
(b) Reduce the postdevelopment loadings of TSS so that the average annual TSS
loadings are no greater than predevelopment loadings, and
(2) To the extent practicable, maintain postdevelopment peak runoff rate and average
volume at levels that are similar to predevelopment levels.
Sound watershed management requires that both structural and nonstructural measures be
employed to mitigate the adverse impacts of storm water. Nonstructural Management
Measures for new development (B&C) can be effectively used in conjunction with this
Management Measure reduce both the short-and long-term costs of meeting the treatment
goals of this management measure.
B. Watershed Protection Management Measure
Develop a watershed protection program to:
(1) Avoid conversion, to the extent practicable, of areas that are particularly susceptible to
erosion and sediment loss;
1 See "Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters,"
January 1993, U.S. EPA, 840-B-92-002.
2 Based on the average annual TSS loadings from all storms less than or equal to the 2-year/24-hour storm.
TSS loadings from storms greater than the 2-year/24-hour storm are not expected to be included in the calculation of
the average annual TSS loadings.
K-l
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Appendix K
(2) Preserve areas that provide important water quality benefits and/or are necessary to
maintain riparian and aquatic biota; and
(3) Site development, including roads, highways, and bridges, to protect to the extent
practicable the natural integrity of waterbodies and natural drainage systems.
C. Site Development Management Measure
Plan, design, and develop sites to:
(1) Protect areas that provide important water quality benefits and/or are particularly
susceptible to erosion and sediment loss;
(2) Limit increases of impervious areas, except where necessary;
(3) Limit land disturbance activities such as clearing and grading, and cut and fill to
reduce erosion and sediment loss; and
(4) Limit disturbance of natural drainage features and vegetation.
HI. CONSTRUCTION ACTIVITIES
A. Construction Site Erosion and Sediment Control Management Measure
(1) Reduce erosion and, to the extent practicable, retain sediment onsite during and after
construction, and
(2) Prior to land disturbance, prepare and implement an approved erosion and sediment
control plan or similar administrative document that contains erosion and sediment
control provisions.
B. Construction Site Chemical Control Management Measure
(1) Limit application, generation, and migration of toxic substances;
(2) Ensure the proper storage and disposal of toxic materials; and
(3) Apply nutrients at rates necessary to establish and maintain vegetation without causing
significant nutrient runoff to surface waters.
K-2
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Appendix K
IV. EXISTING DEVELOPMENT
A. Existing Development Management Measure
Develop and implement watershed management programs to reduce runoff pollutant
concentrations and volumes from existing development:
(1) Identify priority local and/or regional watershed pollutant reduction opportunities,
e.g., improvements to existing urban runoff control structures;
(2) Contain a schedule for implementing appropriate controls;
(3) Limit destruction of natural conveyance systems; and
(4) Where appropriate, preserve, enhance, or establish buffers along surface waterbodies
and their tributaries.
V. ONSITE DISPOSAL SYSTEMS
A. New Onsite Disposal Systems Management Measures
(1) Ensure that new Onsite Disposal Systems (OSDS) are located, designed, installed,
operated, inspected, and maintained to prevent the discharge of pollutants to the
surface of the ground and to the extent practicable reduce the discharge of pollutants
into ground waters that are closely hydrologically connected to surface waters. Where
necessary to meet these objectives: (a) discourage the installation of garbage disposals
to reduce hydraulic and nutrient loadings; and (b) where low-volume plumbing
fixtures have not bee installed hi new developments or redevelopments, reduce total
hydraulic loadings to the OSDS by 25 percent. Implement OSDS inspection schedules
for preconstruction, construction, and postconstruction.
(2) Direct placement of OSDS away from unsuitable areas. Where OSDS placement is
unsuitable areas is not practicable, ensure that the OSDS is designed or sited at a
density so as not to adversely affect surface waters or ground water that is closely
hydrologically connected to surface water. Unsuitable areas include, but are not
limited to, areas with poorly or excessively drained soils; areas with shallow water
tables or areas with high seasonal water table; areas overlaying fractured bedrock that
drain directly to ground water; areas within fioodplains; or areas where nutrient
and/or pathogen concentrations in the effluent cannot be sufficiently treated or reduced
before the effluent reaches sensitive waterbodies;
(3) Establish protective setbacks from surface waters, wetlands, and fioodplains for
conventional as well as alternative OSDS. The lateral setbacks should be based on
soil type, slope, hydrologic factors, and type of OSDS. Where uniform protective
K-3
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Appendix K
setbacks cannot be achieved, site development with OSDS so as not to adversely affect
waterbodies and/or contribute to a public health nuisance;
(4) Establish protective separation distances between OSDS system components and
groundwater which is closely hydrologically connected to surface waters. The
separation distances should be based on soil type, distance to ground water, hydrologic
factors, and type of OSDS;
(5) Where conditions indicate that nitrogen-limited surface waters may be adversely
affected by excess nitrogen loadings from ground water, require the installation of
OSDS that reduce total nitrogen loadings by 50 percent to ground water that is closely
hydrologically connected to surface water.
B. Operating Onsite Disposal Systems Management Measure
(1) Establish and implement policies and systems to ensure that existing OSDS are
operated and maintained to prevent the discharge of pollutants to the surface of the
ground and to the extent practicable reduce the discharge of pollutants into ground
waters that are closely hydrologically connected to surface waters. Where necessary
to meet these objectives encourage the reduced use of garbage disposals, encourage
the use of low-volume plumbing fixtures, and reduce total phosphorus loadings to the
OSDS by 15 percent (if the use of low-level phosphate detergents has not been
required or widely adopted by OSDS users). Establish and implement policies that
requke an OSDS to be repaired, replace, or modified where the OSDS fails, or
threatens or impairs surface waters;
(2) Inspect OSDS at a frequency adequate to ascertain whether OSDS are failing;
(3) Consider replacing or upgrading OSDS to treat influent so that total nitrogen loadings
in the effluent are reduced by 50 percent. This provision applies only:
(a) where conditions indicate that nitrogen-limited surface waters may be adversely
affected by significant ground water nitrogen loadings from OSDS, and
(b) where nitrogen loadings from OSDS are delivered to ground water that is closely
hydrologically connected to surface water.
VI. POLLUTION PREVENTION
A. Pollution Prevention Management Measure
Implement pollution prevention and education programs to reduce nonpoint source pollutants
generated from the following activities, where applicable:
K-4
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Appendix K
• The improper storage, use, and disposal of household hazardous chemicals, including
automobile fluids, pesticides, paints, solvents,
• Lawn and garden activities, including the application and disposal of lawn and garden
care products, and the improper disposal of leaves and yard trimmings;
|':'V^ '
• Turf management on golf courses, parks, and recreational areas;
• Improper operation and maintenance of onsite disposal systems;
• Discharge of pollutants into storm drains including floatable, waste oil, and litter;
• Commercial activities including parking lots, gas stations, and other entities not under
NPDES purview, and . t
I
• Improper disposal of pet excrement. j
VH. ROADS, HIGHWAYS, AND BRIDGES
A. Management Measure for Planning, Siting, and Developing Roads and Highways
Plan, site, and develop roads and highways to:
(1) Protect areas that provide important water quality benefits or are particularly
susceptible to erosion or sediment loss;
(2) Limit land disturbance such as clearing and grading and cut and fill to reduce erosion
and sediment loss; and
(3) Limit disturbance of natural drainage features and vegetation.
B. Management Measure for Bridges
Site, design, and maintain bridge structures so that sensitive and valuable aquatic ecosystems
and'areas providing important water quality benefits are protected from adverse effects.
C. Management Measure for Construction Projects
(1) Reduce erosion and, to the extent practicable, retain sediment onsite during and after
construction and
K-5
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Appendix K
(2) Prior to land disturbance, prepare and implement an approved erosion control plan or
similar administrative document l|at contains erosion and sediment control provisions.
D. Management Measure for Construction Site Chemical Control
(1) Limit the application, generation, and migration of toxic substance;
(2) Ensure the proper storage and disposal of toxic materials; and
(3) Apply nutrients at rates necessary to establish and maintain vegetation without causing
significant nutrient runoff to surface water.
E. Management Measure for Operation and Maintenance
Incorporate pollution prevention procedures into the operation and maintenance of roads,
highways, and bridges to reduce pollutant loadings to surface waters.
F. Management Measure for Road, Highway, and Bridge Runoff Systems
Develop and implement runoff management systems for existing roads, highways, and
bridges to reduce runoff pollutant concentrations and volumes entering surface waters.
(1) Identify priority and watershed pollutant reduction opportunities (e.g., improvements
to existing urban runoff control structures; and
(2) Establish schedules for implementing appropriate controls.
K-6
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Appendix K
MANAGEMENT MEASURES FOR ANIMAL FEEDE0TS
CZARA guidance)
(Chapter 2.II.B of
Bl. Management Measures for Facility Wastewater and Runoff from Confined
Animal Facility Management (Large Units not subject to NPDES permit
requirements)
Limit the discharge from the confined animal facility to surface waters by:
(1) Storing both the facility wastewater and the runoff from confined animal facilities that
is caused by storms up to and including a 25-year, 24-hour frequency storm. Storage
structures should:
(a) Have an earthen lining or plastic membrane lining, or
(b) Be constructed with concrete, or
(c) Be a storage tank;
and
(2) Managing stored runoff and accumulated solids from the facility through an
appropriate waste utilization system.
B2. Management Measures for Facility Wastewater and Runoff from Confined
Animal Facility Management (Small Units not subject to NPDES permit
requirements)
Design and implement systems that collect solids, reduce contaminant concentrations, and
reduce runoff to minimize the discharge of contaminants in both facility wastewater and in
runoff that is caused by storms up to and including a 25-year, 24-hour frequency storm.
Implement these systems to substantially reduce significant increases in pollutant loadings to
ground water.
Manage stored runoff and accumulated solids from the facility through an appropriate waste
utilization system.
K-7
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APPENDIX L
PRESIDENT CLINTON'S CLEAN WATER INITIATIVE
(PORTIONS RELATED TO STORM WATER PROGRAM)
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United States
Environmental Protection
Agency
Office of Water
Washington, D.C.
EPA 800-B-94-00?
February 1994
PRESIDENT CLINTON'S
CLEAN WATER INITIATIVE
Recycted/fteeydabte
Printed with Soy/Canola Ink on paper that
contains at toast 50% recycled fiber
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STORM WATER PROGRAMS
ISSUE:
How should CWA storm water requirements be revised to strengthen and facilitate
implementation of storm water controls?
BACKGROUND:
States report that approximately 30 percent of remaining surface water quality
impairment is attributable to storm water discharges. Significant sources of storm
water discharges include urban runoff, industrial activity, construction, and resource
extraction (mining). For example, in urban areas, loadings from storm water runoff
for heavy metals, sediment, bacteria, polycyclic aromatic hydrocarbons (PAHs),
acidity, and floatables are higher than those from POTWs.
To address these environmental risks, Congress established in 1987 a two-phased
storm water program under CWA §402(p). Phase I applies to municipal storm sewer
systems serving a population over 100,000, as well as storm water discharges
associated with industrial activity.
In November of 1990, EPA issued regulations that identified 220 municipalities whose
separate storm sewer systems are subject to Phase I of the NPDES program. States
and EPA have designated an additional 550 municipalities as part of the Phase I
program. The Agency estimates that the Phase I municipalities have a population of
over 90 million people (about 36 percent of the total U.S. population). EPA and
authorized States have received comprehensive permit applications from many of the
municipalities, and are in the process of developing and issuing permits for these
dischargers.
In addition, the Phase I regulations established regulation of over 100,000 industrial
facilities in eleven categories, including manufacturing, mining, waste management,
construction, and transportation. Permits for storm water discharges from Phase I
industries generally were required to be issued by October 1, 1993. The Ninth Circuit
struck down EPA's exemption from Phase I regulations of construction sites under 5
acres and light industrial activities "with no exposure" to rain water.
Phase II applies to all remaining light industrial, commercial, retail, and residential
facilities with storm water discharges that are not in Phase I. Preliminary estimates
indicate that millions of facilities are not addressed by Phase I. Phase II is potentially
ten times larger in scope than Phase I, and could address a large number of
municipalities without significant urban populations. EPA was required to issue
Phase II regulations by October 1, 1993, which would designate classes of Phase II
storm water discharges to be regulated to protect water quality. Phase II sources are
- 116 -
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required to obtain a permit by October 1, 1994. EPA did not meet the October 1993
deadline for Phase II regulations.
Municipal Compliance with Standards
Municipal separate storm sewer systems (or "MS4"--those municipal systems that are
covered by the storm water program) have stated that it is both technologically and
financially impossible to establish treatment or management practices that can ensure
that urban storm water runoff complies with water quality standards. They have
indicated that it is highly uncertain whether feasible storm water control measures
(source controls, traditional structural controls, and best management practices) will
ensure that storm water discharges will meet water quality standards. They further
argue that the only other alternative, collecting and treating essentially all of the storm
water from widespread urbanized areas, would be infeasible and result in significant
destruction of urban streams and wetlands.
Under the existing CWA, §402(p)(3)(B)(iii), a statutory standard exists that NPDES
storm water discharge permits issued to municipal separate storm sewer systems
' require controls to reduce the discharge of pollutants in storm water to the "maximum
extent practicable" (MEP). The statutory standard can include management practices,
control techniques, and system design and engineering methods and other such
provisions that the Administrator or State determines are necessary for the control of
such pollutants. Because of the lack of a more specific definition of the statutory
standard of MEP, municipalities, permitting authorities, and members of the public are
uncertain as to the extent of storm water control requirements a municipality must
implement in its storm water management program.
Provisions for Facilities with No Exposure
EPA attempted to exempt from storm water control requirements certain industrial
facilities that had no exposure of materials, equipment, or wastes to storm water.
However, this exemption of facilities without storm water exposure was overturned
by the Ninth Circuit. Such an exemption, if reinstated through legislation, would
create a.strong incentive for facilities to implement pollution prevention. It would
simultaneously accomplish environmental objectives (reducing pollutants in storm
water) and greatly reduce administrative burdens for EPA, States, and industries.
Deadline Extensions for Phase II
EPA is presently required to issue Phase II regulations designating sources for
permitting and establishing deadlines by October 1, 1993. In the absence of new
regulations, Phase II sources are required to have permits after October 1, 1994.
Given the scope and complexity of Phase II, EPA was unable to meet the October 1,
1993 regulatory deadline. Furthermore, EPA and authorized States will not be able
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to issue permits to all Phase II sources by October 1, 1994. This may expose
unpermitted dischargers, including many small municipalities or commercial enterprises
posing small risks, to litigation for discharging without a permit. In addition, potential
Phase II municipalities need additional time to develop the financial capabilities and
institutional frameworks needed to comply with storm water requirements.
Phase II Storm Water Requirements
Phase II regulations must be reasonable in scope and establish a workable program
that will focus on sources of storm water discharges that pose the highest risk. The
Bureau of Census has designated 396 urbanized areas which represent the most
widespread and dense urban development. These urbanized areas occupy less than
2 percent of the total land area of the United States but contain 165 million people,
or about 65 percent of the total population of the United States. In addition, most
new development occurs in or adjacent to these urbanized areas. Between 1980 and
1990, over 75 percent of the national increase in population occurred in these
urbanized areas. However, over 5,000 municipal entities in urbanized areas are not
in Phase I of the NPDES storm water program.
Authorize Municipalities to Directly Regulate Storm Water Facilities Within Their
Jurisdiction
Under current CWA provisions, the storm water program requires permits for industrial
activities even if they are discharging to municipal separate storm sewer systems
which also must obtain storm water permits. Municipalities argue that this is
redundant and inefficient, and also undercuts their effectiveness in directly dealing
with an industrial facility.
Inactive and Abandoned Mines
It is estimated that there are in the range of 400,000 or more inactive and abandoned
mine sites (lAMs) on Federal lands. The environmental damages posed by these sites
can vary significantly. While many sites are relatively benign, releases from other
sites result in significant environmental degradation, even decades after active
operations have ceased. A major administrative challenge is to (1) prioritize these
sites that cause environmental problems so that the United States can address them
in a rational environmentally protective manner, and (2) effectively protect water
resource quality by addressing these sites according to the prioritized order. Another
major challenge is to target control measures so as to achieve the greatest
improvement in environmental quality for the limited Federal resources that may be
available. Although the estimates of total costs of mitigating water resource quality
impacts from lAMs vary significantly, they range into the many tens of billions of
dollars without such cost-effective, risk-based prioritization.
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A significant number of lAMs on Federal lands are believed to have point source
discharges of pollutants, as defined under current statute and regulation, to waters
of the United States subject to regulation under the NPDES permit program. Given
the large number of lAMs and the costs of mitigating sites causing environmental
impacts; there is a need for a phased, cost-effective, risk-based prioritized approach
to mitigating these sources.
RECOMMENDATIONS:
The Administration recommends that the CWA be amended to do the following--
Municipal Compliance with Standards
> Establish a phased permit compliance approach that requires best management
practices in first-round municipal storm water permits, and through improved
best management practices in second-round permits, where necessary, to move
towards compliance with water quality standards. In later permits, compliance
with water quality standards will occur using water quality based effluent
limits, where necessary. This would give EPA and municipalities additional time
to evaluate the technical feasibility of establishing numeric effluent limits to
meet water quality standards and give States time to develop specific water
quality standards appropriate for storm water discharges, if necessary.
»• The Administration supports clarifying authority under section 402(p)(3)(B)
concerning "maximum extent practicable" (MEP). In contrast to best available
technology economically achievable (BAT) and best conventional pollutant
control technology (BCT) that are applicable for storm water discharges
associated with industrial activities, under MEP, storm water management
programs can be implemented in a site-specific and flexible manner to address
the storm water management concerns in the municipality. It should be made
clear that MEP allows for the consideration of different factors including: (1)
the severity of the impairment caused by the source, (2) the effectiveness of
alternative approaches at reducing storm water discharges, and (3) the cost of
control measures. Under MEP, a storm water management program can target
controls based on differences in the type and size of sources, climate,
geography, and water quality concerns. Based on a statutory clarification, EPA
will then issue guidance on the best methods by which to implement MEP in
NPDES permits.
> The Administration supports encouraging States to review and revise their
designated uses and water quality standards implementation procedures, as
they develop water quality-based permits, to reflect the episodic nature of
storm water runoff, the varying loadings during storm water events, and the
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potential resilience of natural ecosystems to some infrequent, temporary
incremental loadings.
Provisions for Facilities with No Exposure
»• Authorize EPA to exempt from individual storm water permitting requirements
facilities that can certify that there is no nor will be exposure of industrial or
other activities or significant materials to rain water and snow melt. This
change would ensure that several hundred thousand low-risk facilities are not
subject to NPDES requirements, allowing allocation of resources to more critical
areas. This would also effectively create incentives for facilities to eliminate
contamination of storm water.
Deadline Extensions for Phase II
»• Extend the Phase II deadline for EPA issue to regulations to October 1, 1997.
Also, extend the deadline to obtain a permit to October 1, 1999. These
extensions are necessary to allow EPA to work with States and municipalities
in developing workable, effective regulations. Extending the deadline for
permits would give municipalities an opportunity to begin to build institutional
frameworks and provide the funding necessary to implement storm water
management programs. It would also allow permits to be issued to Phase II
municipalities at the same time Phase I permits are expiring. This will promote
regional and watershed-wide permitting by allowing different municipalities to
be co-applicants and coordinate their storm water programs.
Phase II Storm Water Requirements
»• Focus Phase II requirements on system-wide permits for municipal separate
storm sewer systems in Census-designated urbanized areas with a population
of 50,000 or more.
> Target storm water management programs for municipal separate storm water
systems (MS4) in the 138 Phase II urbanized areas associated with a Phase I
permitted MS4 to address, at a minimum, non-storm water discharges into
storm sewers and storm water runoff from growth and development and signifi-
cant redevelopment. The CWA should encourage NPDES permitting authorities
as part of a watershed approach to implement a more comprehensive municipal
storm water management program where appropriate based on water quality
impairments or other factors for the MS4s in these urbanized areas. In the
remaining 258 Phase II urbanized areas, storm water management programs
would be required which focus only on controlling non-storm water discharges
into storm sewers and storm water runoff from growth and development and
significant redevelopment activities.
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»• Under Phase II for those MS4s required to implement a storm water
management program targeted to growth, development and significant
redevelopment and illicit connections, the municipal program will control those
Phase II storm water sources, including discharges from construction of less
than 5 acres, which are part of growth, development, and significant
redevelopment activities and may address, where appropriate, subject to the
MEP standard, those Phase II sources causing water quality impairment. For
those municipal separate storm sewer systems required by the NPDES
permitting authority to implement a more comprehensive storm water
management program, Phase II light industrial, commercial, retail, and
institutional storm water sources would be addressed through the program
under the municipality's NPDES storm water permit, which meets the MEP
standard. Phase II sources not addressed through a municipal program would
not be covered by the NDPES program.
> Do not directly regulate Phase II light industrial, commercial, retail, and
institutional storm water discharges, and municipalities outside of Census-
designated urbanized areas under the NPDES program, unless otherwise
designated by the permitting authority for inclusion in the NPDES program
under §402(p)(2)(E) of the CWA. (EPA does not expect that this designation
process would be used, except in highly-unusual circumstances, to require an
NPDES permit for a typical homeowner.) Rather, such discharges could be
addressed by NPS program, if they were a targeted source.
Authorize Municipalities to Directly Phase I Industrial Regulate Storm Water Facilities
Within Their Jurisdiction Under the NPDES Program
> Allow EPA and authorized States to authorize municipalities to establish
programs for Phase I industrial storm water permit issuance and controls, where
it has the appropriate authority, and is willing to commit to implement Federal
requirements. EPA does not envision Federal funding to be available to
municipalities to perform this function. This recommendation is similar to the
industrial pretreatment program currently authorized under the CWA. As in the
industrial pretreatment program, storm water permits and controls that are
issued by municipalities in an EPA-approved program would be Federally
enforceable.
Inactive and Abandoned Mines
> The Administration recommends that the CWA be amended to make the
following changes to the NPDES permitting program to target control measures
so as to achieve the greatest improvement in environmental quality for the
limited Federal resources available for inactive and abandoned mine sites (I AMs)
without an operator present:
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o
The Administration supports clarifying authority to issue NPDES permits
on a State-wide basis for lAMs within resource management units (e.g.,
one permit per State for the National Forest Service, National Park
System, Bureau of Land Management, or Fish and Wildlife Service
resource areas). This would allow Federal land managers to establish
State-wide priorities based on impairment or threats to water resource
quality and the most effective use of the available resources. Such
priorities could allow some sites not to be controlled or be subject to
relatively less stringent controls.
The Administration supports an amendment to substitute, for existing
technology-based requirements under the NPDES program for lAMs on
Federal lands, the authority for Federal land managers to identify water
resource quality that is threatened or impaired by lAMs and to implement
targeted controls for such sites, similar to existing authority for permits
for municipal separate storm sewer systems contained in section
402(p){3)(B).
The Administration further supports allowing, in general, no more than
up to ten years to meet appropriate water quality standards within a
resource management unit, as defined in the language above, from the
date of issuance of an NPDES permit to the Federal land manager. The
Federal land manager would be expected during this period to 1) strive
to achieve water quality standards as expeditiously as possible, 2)
continue to assess the water resource quality impacts of lAMs where
they are currently unknown, and 3) continue to implement targeted
controls for those sites causing impairments or threats once identified.
This provision should not apply to lAMs which were permitted under the
NPDES program prior to the date of enactment.
The Administration supports encouraging States to review and revise
their designated uses and water quality standards implementation proce-
dures, as they develop water quality-based permits, to reflect the
episodic nature of storm water runoff, the varying loadings during storm
water events, and the potential resilience of natural ecosystems to some
infrequent, temporary incremental loadings.
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United States
Environmental Protection
Agency
Office of Water
Washington, D.C
EPA 800-R-94-002
March 1994
PRESIDENT CLINTON'S
CLEAN WATER INITIATIVE:
Analysis of Benefits and Costs
Recycled/Recyclabt*
Printed with Soy/Canda Ink on paper thai
contains at least 50% recycled fiber
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4.0 Storm Water
EPA's current Phase I storm water program requires NPDES permits of cities and
counties with municipal separate storm sewer systems (MS4s) serving populations of 100,000
or more and "storm water discharges associated with significant industrial activity." The Phase
II program, currently suspended due to a Congressional moratorium, could require permits for
all private sources of storm water (commercial, industrial, retail, and institutional) and all MS4s
serving all populations that have the potential to affect water quality. In the Initiative, EPA has
addressed the potentially high costs of the Phase II program while still providing protection from
private sources and additional MS4s.
The "worse case" scenario for storm water permitting reflects the most inclusive option
of all potential options that EPA would consider in proposing rules for the types of facilities
covered under Phase II. If EPA were to propose regulations for permitting Phase II facilities,
EPA may propose to cover only a portion of these facilities, based on consideration of costs
incurred and environmental benefits gained. EPA could propose regulations covering the same
facilities to the same extent as suggested in the Initiative.
The Initiative's Phase II program will focus on system-wide permits for MS4s in Census-
designated urbanized areas~i.e., areas with a population of 50,000 or more and a population
density of 1,000 persons per square mile. The Census Bureau has identified 396 such urbanized
areas nationwide. Phase II MS4s will be required to implement storm water management
programs that are subject to a "maximum extent practicable" (MEP) standard. These programs
will, at a minimum, address: (1) nonstorm water discharges to their systems (i.e., illicit
connections) and (2) storm water runoff from growth and development and significant
redevelopment activities (including discharges from construction of less than 5 acres) and, where
appropriate, those Phase II sources causing water quality impairment.
Where the NPDES authority deems it necessary, MS4s in the 138 urbanized areas
associated with a Phase I permitted MS4 may be required to have a more comprehensive storm
water management program (consistent with the Phase I storm water requirements). The
comprehensive storm water management programs would cover Phase II light industrial,
commercial, retail, and institutional storm water sources under a municipality's storm water
permit. The NPDES program would not cover Phase II sources not addressed through a
municipal program. Such discharges could be addressed by the NFS program if they were a
targeted source.
4.1 Private Sources
Under a stringent interpretation of the CWA, the current Phase I program is estimated
to cost industrial permittees $3.99 billion per year, while Phase II under a similarly stringent
interpretation could cost as much as $16.23 billion in annual costs.
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To account for the uncertainty in estimating the potential costs, EPA has developed
ranges. These ranges account for variations in both the number of sources affected and the costs
incurred. The Initiative's Phase II plan would reduce these impacts on commercial, service, and
institutional facilities considerably, imposing costs of between $0.34 billion and $1.67 billion
per year, as follows:
10,000 facilities x $22,340/facility
28,000 facilities x $34,700/facility
96,000 facilities x $630/facility
269,000 facilities x $l,885/facility
100,000 sites x $630/site
100,000 sites x $l,885/site
TOTAL
Low
$0.22 billion
$0.06 billion
$0.06 billion
$0.34 billion
High
$0.97 billion
$0.51 billion
$0.19 billion
$1.67 billion
From a universe of 1.1 million significant sources, EPA has identified 100,000 that are
similar to Phase I industrial sources while the remaining 1.0 million are retail, commercial, and
institutional. Of the 100,000 industrial sources, approximately 60 percent or 60,000 have no
storm water exposure. Of the remaining 40,000 sources, EPA has assumed that municipalities
will require between 25 and 70 percent of the facilities to install storm water controls. To
further account for the uncertainty inherent in projecting costs, EPA has used $22,340 per
facility at the low end and $34,700 per facility at the high end of the estimated cost to comply
(EPA, 1994c). The total cost for industrial look-a-likes is estimated to be between $0.22 billion
and $0.97 billion per year.
Of the remaining 1.0 million sources, 60 percent are located in urbanized areas and may
be addressed under storm water management programs for the urbanized areas. As above, 36
percent, or 216,000 sources, are estimated to have no storm water exposure. Of the remaining
384,000 sources, or 64 percent, the low-end number of facilities (96,000 sources or 25 percent)
could incur costs as low as $630 per facility, while the high-end number of facilities (269,000
sources or 70 percent) could incur costs as high as $1,884 per facility.
In addition, 40 percent of the private sources that are not covered by a municipal
program would be covered by the NPS program. Under the NPS program, only the sites
located in impaired watersheds would need controls. EPA believes roughly 25 percent of these
sites are in impaired watersheds. At a range of $630 and $1,885 per site and 100,000 sites, the
annual costs will be between $0.06 billion and $0,. 19 billion.
Based on these estimates, the Initiative's total cost on private sources is between $0.34
billion and $1.67 billion. Compared to EPA's best interpretation of current law and assuming
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that the moratorium will expire, the Initiative will avoid costs (or yield a cost savings) of
between $14.6 billion and $15.9 billion.
The Initiative may also result in potential cost savings for those facilities currently or
soon to be permitted under the existing storm water Phase I regulations. About 60 percent of
existing permitted industrial sources and 100 percent of potentially permitted light industrial
sources will not require NPDES permits under the Initiative's provisions. In addition, small
(less than 5 acre) construction sites will be considered Phase II sources, and this would result
in additional cost savings of $70 million per year. As a result, additional cost savings to private
sources from Phase I requirements will be between $1.1 billion and $1.6 billion.
The above estimates are derived in EPA, 1994c, and are summarized here. Based on a
stringent interpretation of the current law, the overall cost savings (or costs avoided) to private
sources from these provisions would be in the range of $15.7 billion and $17.5 billion, as shown
in Table 21.
4.2 Municipalities
Costs for the current Phase I program for municipal sources are estimated at between
$1.6 billion and $2.6 billion annually, based on a covered population of 69.3 million people and
per person costs of between $23.91 and $37.00 per person.8
If the Phase II moratorium expires, EPA could be required to promulgate regulations
covering an additional population of at least 74.1 million people (25.3 million in 138 urbanized
areas associated with Phase I MS4s, 29 million in 258 additional urbanized areas between the
population of 50,000 and 100,000, and potentially 19.8 million in other MS4s). EPA's best
interpretation of the current law is that it would not include these additional 28 million in other
MS4s. Using the same unit costs ($23.91 to $37.00), the existing Phase II program could cost
between $1.8 and $2.7 billion per year.
To account for the uncertainty of the impact in terms of the number of municipalities
affected and the costs incurred, EPA has estimated a range of costs for the Phase II provision
in the Initiative. The following estimates are derived in EPA, 1994c, and are summarized here.
About 25.3 million people live in 138 urbanized areas (UAs) with growth and development and
illicit discharge. Costs range from a low of $15.33 per capita to a high of $23.72 per capita.
The range of total costs for these urbanized areas is between $0.39 billion and $0.60 billion.
Next, EPA assumed that between 25 and 70 percent of the population in these UAs will be
covered by a comprehensive program based in part on the percentage of impaired urban waters.
The population affected will be between 6.33 million and 17.7 million. The additional cost of
8 Population estimates for the municipal storm water costs are from the draft "Report to Congress on Storm
Water Dischargers Not Regulated Under Phase I of the NPDES Storm Water Program" (EPA, 1993d). Average
costs are from the draft EPA report "Review of Program Costs in Part 2 NPDES Municipal Storm Water Permit
Applications" (EPA, 1993c).
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a comprehensive plan above the cost of addressing growth and development and illicit discharges
will be in the range of $8.58 and $13.28 per capita. The total cost of the comprehensive
coverage will vary from a low of $0.05 billion to a high of $0.24 billion.
EPA identified 29 million people in another 258 UAs who will be affected by the Phase
II provisions. The cost of compliance will vary from $15.33 per capita to $23.72 per capita.
The total cost of this coverage will be in the range of $0.44 billion and $0.69 billion. The final
element of this cost on municipalities is the cost of addressing private sources and industrial
look-a-likes that impact water quality in areas without the comprehensive program and in areas
with combine sewers. At a per capita cost of $2.00, EPA estimates that about 75.7 million
people will incur $0.15 billion. At a per capita cost of $5.00, the upper-end cost would be
$0.38 billion.
25.3 million population x $15.33 per capita
25.3 million population x $23.72 per capita
6.33 million population x $8.58 per capita
17.7 million population x $13.28 per capita
29.0 million population x $15.33 per capita
29.0 million population x $23.72 per capita
75.7 million population x $2.00 per capita
75.7 million population x $5.00 per capita
TOTAL
Low
$0.39 billion
$0.05 billion
$0.44 billion
$0.15 billion
$1.03 billion
High
$0.60 billion
$0.24 billion
$0.69 billion
$0.38 billion
$1.91 billion
The total cost to the municipalities of the proposed Phase II requirements is between
$1.03 billion and $1.91 billion, as shown in Table 20.
Compared with the cost of Phase II requirements under a stringent interpretation of the
current law, total savings to municipalities will be between $755 million and $850 million per
year.
4.3 State Water Programs
The impacts of the Phase II storm water provisions on states have not been estimated but
are expected to be minimal.
4.4 Federal Agencies
Additional costs of the storm water provisions on federal agencies will total $19 million
per year. EPA will account for $2 million per year of this cost, and DOI will account for $17
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million per year.
4.5 Benefits9
The benefits of storm water control as proposed in the Initiative are based on numerous
case studies and are summarized as follows:
> 75 to 80 percent reduced loadings in urbanized areas prior to and during
development,
> 15 to 25 percent reduced loadings in areas already developed,
> Greater environmental protection at lower cost,
>• Improved water resource quality, habitat, and aquatic life; reduced flooding;
improved recreational opportunities; increased commercial fishing; improved
human health; and increased employment.
(Note that more cost-effective and institutionally feasible prevention and management methods
are available for new development than for areas that have already been developed.)
Case Studies10
Bellevue, Washington (see longer summary in Appendix B)
Bellevue has a population of nearly 87,000 and covers a 30-square mile area that contains
five lakes and over 50 miles of open streams. The city established a storm water utility in 1974
to maintain a hydrologic balance, prevent property damage, and protect water quality.
The city requires newly developing areas to include on-site storm water management that
provides protection for 24-hour, 100-year storm events.
Examples of program benefits:
Flood control. One of the most successful aspects of the program is flood
control, which relies on eight remote-controlled regional detention basins along
major stream corridors to monitor rainfall, stream flow, and water levels. This
helps ensure that flood gates control peak flows. Small detention basins reduce
peak flow rates up to 60 percent, providing flood and stream-bank erosion control
and protecting stream-side property.
9 See also the EPA (1994e) background paper "CWA Benefits of Storm Water Controls," January 1994.
10 Costs for these case studies were not available and hence are not included here.
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Reduced property damage. As a result of storm water controls over the previous
10 years, property damages were avoided during a 100-year storm in January
1986.
- Reduced pollutant loadings. Runoff concentrations of lead and total solids were
reduced by 10 to 25 percent through biannual cleaning of storm drainage inlet
pumps and catch basins; oxygen demanding substances, nutrients, and zinc
concentrations were reduced by 5 to 10 percent. Conventional street-sweeping
operations reduced toxic loadings by 5 to 10 percent. Installation and mainte-
nance of oil/water separators reduced floatables in the drainage system.
Reduced illegal dumping. Dumping of motor oil and debris in storm drains was
significantly reduced through increasing public awareness of storm water issues
and volunteer stenciling of storm drains. A recent survey indicates that 85
percent of area residents dispose of used oil at a recycling facility.
— Increased recreational opportunities. Clean-up of Mercer Slough (a 325-acre
wetland) along with stream and wildlife enhancement of the park resulted in
increased canoeing on the slough and increased visitation to the park's trails.
Murray City, Utah
Murray City (population 31,000) worked with the Utah Department of Transportation
(DOT) to develop a storm water control system for runoff from a 4.5-mile stretch of highway
in conjunction with the construction of an 18-hole, 135-acre municipal golf course.
Storm water runoff from the highway and subsurface waters is collected and routed
through a series of streams and wetlands into four ponds on the golf course.
Examples of program benefits:
— Reduction in pollutant loadings. The pond system removes approximately 90
percent of the sediment, oil and grease, and dissolved materials from the highway
runoff.
Flood control. The system successfully handled the runoff from two 25-year
storms.
~ Savings in irrigation water costs. The detention ponds provide 7 acres of flood
retention area and created nearly 11 acres of wetlands. The ponds also provide
water to irrigate the golf course, which saves nearly $80,000 per year in watering
costs.
~ Savings in highway construction costs. Because runoff was diverted to irrigate
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the golf course, DOT saved $300,000 in land acquisition and storm water piping
costs by eliminating the need to construct a separate storm water discharge system
for the highway.
Orlando, Florida
The city of Orlando (population 160,000) receives over 50 inches of rain annually, over
half of which converts to storm water runoff and flows into the city's 83 lakes. One example
of a project to manage storm water is the creation of the Greenwood Urban Wetland, which
consists of several ponds in a series.
Examples of program benefits:
Increased property values. Overall, whenever Orlando constructs a storm water
control lake, property values in that area increase.
A savings was realized in construction of the Greenwood Urban Storm Water
Control Wetland with the sale of fill dirt that was excavated ($5/cubic yard).
Creation of a natural park. The Greenwood Urban Wetland created a natural
park atmosphere (with footbridges, walking paths, picnic areas, and opportunities
for observing wetland wildlife) in an urbanized area.
Irrigation and drinking water supply. Cleansed storm water is used to irrigate the
upland areas of the park, which conserves the drinking water supply.
Santa Clara Valley, California
Santa Clara Valley has a municipal storm water permit covering 15 co-permittees
(14 municipal entities and one water control district). Three of the municipalities have
populations over 100,000, four are between 50,000 and 100,000, and seven are less than 50,000.
Transportation activities have been identified as potentially the most significant source
of storm water pollutants. Copper and zinc have been identified as significant contaminants in
the storm water runoff into south San Francisco Bay. These metal are carried by suspended
particles. Brake pad dust is believed to be a major source of the copper.
Examples of program benefits:
Significant reduction in copper loadings. Street sweeping activities clean 19,000
miles per month and have prevented 2,500 pounds of copper and 46,000 cubic
yards of material throughout the area from entering storm sewers.
Reduction in floatables. Cleaning 34,000 catch basins has removed 1,000 cubic
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yards of material. Inspection and cleaning of 160 miles of conveyances has
removed 400 cubic yards of material.
Identification of illegal dumping activities. The co-permittees identified 867 cases
of illegal dumping, of which 700 have been resolved.
Tulsa, Oklahoma
The city of Tulsa (population 367,000) has been recognized as having an effective storm
water management program. EPA recently issued a draft municipal storm water permit for
Tulsa.
Discharges from Tulsa's storm sewer collection system were identified as a source of
pollutant loadings in the Zinc Lake portion of the Arkansas River. The storm sewer's discharges
showed a high concentration of bacteria.
Examples of program benefits:
Removal of suspended solids. Tulsa estimates that its construction site storm
water controls average 70 percent effectiveness in removing total suspended solids
from storm water runoff. In addition, the city estimates that its street sweeping
and .structural operation and maintenance reduce suspended solids by up to 50
percent; metals by up to 10 percent; total solids and lead by 10 to 25 percent; and
oxygen demanding substances, nutrients, and zinc by 5 to 10 percent.
Improved Water Quality in the Arkansas River. The city identified 35 illicit
storm sewer connections drained into Zinc Lake and the Arkansas River. Tulsa
removed these discharges from the storm sewer system and states that water
resource quality has improved as a result.
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APPENDIX B
STORM AND SURFACE WATER UTILITY
BELLEVUE, WASHINGTON
Bellevue, Washington, is a suburban community located in the Puget Sound area east of
Lake Washington in the Seattle metropolitan area. The city experienced substantial population
growth during the last 30 years and particularly rapid growth over the last 20 years. When
Bellevue incorporated as a city in 1953, the population was approximately 6,000 and the city
limits covered five square miles. By 1990, Bellevue had grown to a population of 86,000 and
an area that covered 30 square miles, making it the fourth largest city in Washington State.
Recent estimates indicate that the watershed is over 90 percent developed, primarily with
residential units and commercial and light industrial uses.
Rapid growth and development created storm water runoff problems in most of the
natural streams draining the area. The city's 30-square mile area contains over 50 miles of open
streams and five lakes. Much of the average annual rainfall of 42 inches is carried by existing
streams into the following receiving waters: Kelsey Creek, Meydenbauer Bay and the Lake
Washington East Channel, Yarrow Bay on Lake Washington, Lake Sammamish, and Coal
Creek. Of these, Lake Washington is considered the primary receiving water body. The types
of storm water runoff problems documented in the Bellevue area include increased flooding and
streambank erosion; property damage; stream sedimentation/siltation; diminished salmon runs;
water quality degradation by discharges of nutrients, heavy metals, pesticides, and oil; and illicit
connections.
In response to citizen concerns about environmental degradation caused by storm water
runoff, the city of Bellevue established a storm water utility in 1974. The mission of Bellevue's
Storm and Surface Water Utility (SSWU) is to manage the storm and surface water system in
Bellevue, to maintain a hydrologic balance, to prevent property damage, and to protect water
quality for the safety and enjoyment of citizens and the preservation and enhancement of wildlife
habitat.
STORM AND SURFACE WATER UTILITY PROGRAMS
When first established, Bellevue's utility focused on examining various solutions to
control flooding and preserve waterways. The utility selected an "open stream concept" using
streams as the main conveyance system for storm water runoff. This system uses regional,
in-stream flood control facilities to attenuate peak flows for older development. The utility also
manages the municipal storm drainage system. In addition, regulations require developers to
provide erosion and sedimentation controls at all construction sites and on-site storm water
controls for new development. With successful flood control systems in place, the focus has
recently shifted to water quality controls, including requirements mandated by the federal Clean
Water Act. For the most part, SSWU's comprehensive effort to solve storm water quality
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problems is preventive in nature, but the utility also recognizes the need for retrofitting and new
capital improvements for treatment.
Management of Bellevue's storm drainage system and open streams involves five major
programs: a capital improvement program, operations and maintenance, water quality control,
public education, and administration. Activities conducted under each of the major programs
are summarized below.
• Capital improvement program. SSWU's capital improvement program (CIP)
involves planning, design, property acquisition, flood control construction, water
quality treatment, and stream enhancement projects. The utility constructed a
series of 11 in-stream flood control facilities (detention basins) within the
Bellevue stream system to provide protection for the 24-hour, 100-year storm
event. SSWU also improves stream passages for carrying capacity, stability,
wildlife habitat, and migratory fish passage.
• Operations and maintenance. The operations and maintenance (O&M) program
involves those functions typically associated with urban drainage, such as repair
and minor replacement of SSWU's structural facilities. Bellevue's O&M program
also includes operation of structures for flood control, including a telemetry
control system for structures and an emergency storm response program, a
drainage system inventory, and advice to private citizens on private drainage
concerns.
• Water quality control. Activities conducted for water control include drainage
system cleaning, routine monitoring of receiving waters, investigative monitoring
of pollution events and sources, emergency response for water pollution events,
coordination with other water quality control agencies, participation in lake
restoration studies and projects, a private maintenance inspection program, and
a streams enhancement program.
• Public education. SSWU's public education efforts focus on available services
and the environment. Specific activities include articles in local publications
about SSWU services and the effects of human practices on the environment, the
Stream Team Program (includes a water quality newsletter, workshops, and
citizen activities), City Hall's "Mini Salmon Hatchery" and annual salmon
release, storm drain stenciling projects, and a business water quality program.
• Administration. Administrative programs for SSWU include financial
management, rate administration, comprehensive drainage planning, general
administration, and support for the City Council and Storm and Surface Water
Advisory Commission. SSWU assures quality control of utility services by
tracking all service requests through an automated Customer Action Request
system.
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UTILITY FINANCING
The city decided that the most equitable system of drainage service charges entails basing
changes on the estimated amount of runoff that individual properties contribute to the surface
water system. All properties are classified according to their intensity of development. Each
classification is assigned a rate (per 2,000 square feet of property area), with current rates set
as follows: undeveloped ($0.17), light development ($0.99), moderate development ($1.23),
heavy development ($1.83), and very heavy development ($2.46). Wetlands are also a class;
however, wetlands are not charged due to their value in water quantity and quality control. The
classification combined with the total square footage of the property determines the service
charge, which is billed every two months.
Revenues grew slowly until rates were raised to fund the adopted Capital Improvement
Program, which was initiated by issuance of $10 million in revenue bonds. Three major rate
increases occurred in 1980 (70 percent), 1982 (90 percent), and 1986 (35 percent), and
subsequent rate increases have remained in the single-digit category largely to cover inflation.
Although the majority of SSWU revenue is from service charges, other revenue sources include
clearing and grading permit fees, general facilities charges, and interest on fund accounts.
Revenues from the utility service charges and these other sources cover the full costs of
Bellevue's storm and surface water management program.
Single-family customers make up 92 percent of the 24,000 accounts and contribute 45
percent of the revenue. An average single-family household pays $16.44 every two months ($98
per year) for 10,000 to 12,000 square feet of property with a typical home. Tax-exempt
properties are not exempt from the utility charges. (Washington State highways and Bellevue
streets are the SSWU's two biggest ratepayers.)
BENEFITS OF THE STORM AND SURFACE WATER PROGRAM
One of the most successful of SSWU's programs is flood control, and several different
approaches to managing storm water discharges are achieving water quality improvements. In
addition, Bellevue's reputation as a well-planned, environmentally sensitive city is enhanced
through SSWU programs that preserve the city's numerous streams.
Reductions in Peak Flows
• Bellevue's use of the natural stream system to manage storm water preserves the
environment and reduces costs. Bellevue's storm water management activities to
address flooding and stream erosion problems range from four to ten times less
costly than traditional storm sewer improvements.
• Small detention basins (detention times of 30 minutes or less) reduced peak flow
rates by up to 60 percent, providing flood and streambank erosion control that
protects streamside property.
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• With a computerized remote control system, maximum flood protection along
major stream corridors is achieved through eight regional detention basins. The
remote control system monitors rainfall, stream flow, and water levels to ensure
optimal operation of flood gates to control peak flows.
• During a 100-year storm experienced by the Bellevue area in January 1986,
property damages occurred only where planned improvements were not yet
constructed. Capital improvements totalling $15 million and constructed over the
previous 10 years reduced flooding and streambank erosion, thereby avoiding
property damages.
• Calls for emergency service during storm events continue to decrease, indicating
that SSWU's flood control system has significantly reduced hazards to life and
property.
Reductions in Pollutant Loadings/Discharges
• Runoff concentrations of lead and total solids were reduced by between 10 to 25
percent over a two-year period through biannual cleaning of storm drainage inlet
sumps and catch basins. Chemical oxygen demand (COD), nutrient, and zinc
concentrations were reduced by between 5 to 10 percent over a two-year period.
• Toxic loadings were reduced by between 5 and 10 percent by conventional street-
sweeping operations.
• Introduction of floatables to the drainage system was reduced by the installation
and maintenance of oil/water separators, some of which have the capability of
reducing oil and grease during oil spill events to levels generally associated with
background levels in urban storm water.
• Dumping of motor oil and debris in storm drains was significantly reduced by
increasing public awareness of storm water issues through SSWU's Stream Team
Program and volunteer stenciling of storm drains. A recent survey indicates that
85 percent of area residents dispose of used oil at a recycling facility.
• Dumping of motor oil and household chemicals was also reduced through
SSWU's Oil Recycling and Hazardous Waste Program. SSWU collected 2,100
gallons of petroleum products at a recycling event in October 1993.
• Total solids in urban runoff originating from residential yards were reduced by
increasing public awareness of practices such as pet waste and litter control.
• A wide variety of local businesses work with SSWU water quality staff to prevent
storm water pollution at the source through an innovative program called Business
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Partners for Clean Water.
Protection or Restoration of Ecological Resources
• Volunteers have planted thousands of native trees and shrubs along 10 miles of
Bellevue's open streams to shade stream waters and enhance fish habitat. Other
stream enhancement projects conducted through the Stream Team Program have
reduced streambank erosion which also lowered water temperatures and provided
shade to enhance fish habitat.
• Kelsey Creek's salmon fishery was enhanced through installation of regional
detention basins that help mitigate peak flows and habitat improvements from
streambank revegetation projects. Previously, this salmon fishery was limited and
unhealthy because of high peak flows from urban runoff that altered the stream
channel and carried pollutants.
• Anadramous fish populations are enhanced because SSWU's flood control system
is designed to provide maximum flood protection with minimum impact on
fisheries and fish migration. During salmon spawning season, flood control gates
remain open until significant heavy rainfall occurs.
• Sensitive areas (floodplains, wetlands, and steep slopes) are protected through the
city's Natural Determinants Regulations, which prohibit development of
designated areas, including 740 acres of wetlands.
• The city is restoring Phantom and Larsen Lakes in partnership with the
Washington Department of Ecology. Restoration measures for Phantom Lake
over a two-year period reduced annual internal phosphorus loading to the lake by
approximately 75 percent and reduced annual external phosphorus loading by 39
to 54 percent. The trophic status of Phantom Lake improved substantially after
implementation of restoration measures, although it remains a eutrophic lake.
• Ecological and aesthetic features of the natural environment are preserved through
regulation of new development under city codes and a Comprehensive Plan to
reflect the philosophy that development should be integrated naturally with the
environment and preserve rather than overcome natural features.
Recreation Activity
• Kelsey Creek, a natural water channel that was developed to convey storm water
from the city of Bellevue to Lake Washington, provides recreational opportunities
such as canoeing, birdwatching, and hiking.
• Cleanup of Mercer Slough (a 325-acre wetland), along with stream and wildlife
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enhancement in Mercer Slough Nature Park, resulted in increased canoeing on the
slough and increased visitation to the park's interpretive trail.
• Phantom and Larsen Lakes furnish recreational opportunities such as fishing and
educational opportunities for school children, who visit the lakes for environmen-
tal education projects.
Economic Activity
Clean water in Bellevue and the surrounding Puget Sound area is important for
drinking, food sources, recreation, and industry.
References
"Bellevue Washington: A Leader in Surface Water Management." Storm and Surface Water
Utility Department, City of Bellevue, Washington.
Diessner, D. "The Bellevue Storm and Surface Water Utility: A Case History of a Successful
Urban Surface Water Management Program." prepared for Storm and Surface Water Utility
Department, City of Bellevue, Washington.
"The Metro Monitor," Municipality of Metropolitan Seattle, October 1993.
Personal communication with Wendy Skony, Program Coordinator, Bellevue Storm and Surface
Water Utility, December 8, 1993.
Personal communication with John Frodge, Municipality of Metropolitan Seattle, December 9,
1993.
"Phantom/Larsen Lake Phase IIB Restoration Project." Final report prepared by KCM, October
1993.
"Storm Water Utilities: Innovative Financing for Storm Water Management." Prepared by
Apogee Research, Inc., for the Water Policy Branch, Office of Policy Analysis, Office of
Policy, Planning and Evaluation, U.S. Environmental Protection Agency. Draft final report,
March 1992.
EPA. 1992. "Environmental Impacts of Storm Water Discharges: A National Profile." EPA
841-R-92-001. Office of Water. June 1992.
EPA. 1990. "Storm Water Guidance Impact Analysis: Volume II: Case Studies." Draft. Office
of Water. May 15, 1990.
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