WATER QUALITY'MANAGEMENT GUIDANCE
WPD 03-76-04
proceedings
URBAN STORMWATER
MANAGEMENT SEMINARS
ATLANTA, GEORGIA NOV. 4-6 1975
DENVER, COLORADO DEC. 2-4 1975
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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PROCEEDINGS
URBAN STORMWATER MANAGEMENT SEMINARS
Atlanta, Georgia
November 4-6, 1975
and
Denver, Colorado
December 2-4, 1975
Contract No. 68-01-3565
Project Officer
Dennis N. Athayde
Planning Assistance and Policy Branch
Water Planning Division
Office of Water and Hazardous Materials
Washington, D.C. 20460
January 1976
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EPA REVIEW NOTICE
This report has been reviewed by the Environmental Protection Agency and
approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the Environmental Protection
Agency, nor does mention of trade names or commercial products constitute
endorsement or recommendation for use.
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TABLE OF CONTENTS
Preface v
Introduction to Program vli
Welcoming Remarks
Atlanta viii
Denver ix
I. Characterization of the Urban Stormwater Problem 1-1
Best Management Practices, Dennis Athayde 1-2
Considerations in Characterization of Urban Runoff, 1-7
Francis J. Condon
Land Use and Urban Development Affecting Stormwater 1-38
Pollution and Water Quality, Herbert G. Poertner
Instream Impacts of Urban Runoff, Eugene D. Driscoll 1-54
Impact of Combined Sewer Overflows and Storm Sewer 1-83
Discharges on Water Quality, John A. Lager
NFS Impact and Urban Holding Capacity: Major Issues, 1-98
G. Kenneth Young
Runoff and Quality, Eugene D. Driscoll 1-122
Applications of Stormwater Management Models, 1-157
John A. Lager
II. Approaches to the Urban Stormwater Problem II-l
Land Management Techniques for Stormwater Control II-2
in Developed Urban Areas, Kathleen C. Adgate
Land Management Techniques for Developing Areas, 11-38
L. Duane Bartee (Denver)
SCS Practices as Related to Sediment and Erosion 11-56
Control, August Dombusch (Atlanta)
Cost Effective Approach for Combined and Storm 11-62
Sewer Cleanup, William C. Pisano
Collection System Control, John A. Lager 11-83
Treatability Determinations for Prototype 11-99
Swirl Combined Sewer Overflow Regulator/Solids-
Separator, Richard I. Field
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Urban Stonnwater Detention and Flow Attenuation 11-118
for Water Pollution Control, Herbert G. Poertner
III. Institutional/Legal Issues of Urban Stonnwater Management III-l
Urban Stormwater Management - Problems and Solutions, III-2
Herbert G. Poertner
The Intergovernmental Tangle Facing Stormwater Control, 111-15
Andrew Waldo
State/Local Interaction in Stormwater Management, 111-45
Eugene T. Jensen
Legal Aspects of Urban Stormwater Management, 111-57
W. Joseph Shoemaker (Denver)
Legal Aspects of Urban Stormwater Management and 111-67
Related Pollution Abatement Problems,
Frank E. Maloney (Atlanta)
Financing Stormwater Control Projects, Jay Fountain III-107
and Dwight Cochran (Atlanta)
Financing Stormwater Projects, W. Joseph Shoemaker (Denver) III-113
Planning to Narrow the Implementation Gap, Richard Page III-122
and Penelope Wilson (Denver)
Implementation of Urban Stormwater Runoff Plans, III-132
George C. Berteau (Atlanta)
Urban Stonnwater Management Information Form: III-1A1
Summary of Responses, Warren W. Cast
General Comments, Jerry G. Cleveland III-145
Appendix A. Seminar Participants, Atlanta and Denver
Appendix B. Seminar Agendas, Atlanta and Denver
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Preface
The Federal Water Pollution Control Act Amendments of 1972,
Section 208, call for the establishment of a regulatory program to
include urban stonnwater management. The 1974 Needs Survey arrived at
a rough national cost estimate of $235 billion for treatment of
stormwater runoff, in addition to the $31 billion for prevention of
combined sewer violations. Thus, while the elimination of discharges
into navigable waters by 1985 has been established as a national goal,
and while the contribution of storm-generated pollution has been
recognized as a major deterrent to the attainment of this goal,
complete treatment of stormwater pollution is economically unfeasible.
Therefore, approaches other than complete treatment of stormwater must
be developed, approaches which attain acceptable reduction of
pollutants at an acceptable cost.
The traditional philosophy for control of urban stormwater has
been corrective in nature; that is, an after-the-fact attempt to
manage the problem. This has often necessitated development of large
downstream flood prevention facilities to accommodate the volumes and
peak rates resulting from upstream urbanization, and extensive
collection and treatment systems to handle pollutant loadings.
Despite these costly corrective facilities, pollution of receiving
waters, flooding and property damage still occur, for the variability
of storm events assures that, no matter what size storm a facility is
designed for, it will be inadequate for some storm events.
The alternative to this corrective philosophy is the preventative
concept of source control; that is, abating the problem as it occurs,
and before it attains a magnitude that is difficult to control at a
reasonable cost. Applied on a watershed basis, preventative
techniques for stormwater control can cost-effectively reduce the
aggregate amount of pollution and flooding that might otherwise occur
at downstream facilities.
Application of preventative techniques on a watershed basis is
often difficult to accomplish, however. Responsibility for urban stormwater
management is often distributed over numerous Federal, State, and
local government agencies and may be conflicting and ill-defined.
Consideration is often not given to the interjurisdictional nature of
urban runoff. Legal questions arise as to the reasonableness of
regulations for stormwater control, as to operation and maintenance
responsibilities, and as to who should pay for urban stormwater
control systems.
The 208 planning process provides a mechanism through which
interjurisdictional management of urban stormwater can be addressed,
and through which the agencies with expertise (i.e., EPA, USGS, HUD,
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SCS) can interface their knowledge and research for a more holistic
approach to urban stormwater problems.
With these considerations in mind, the Water Planning Division of
the U. S. Environmental Protection Agency conducted two Urban Stormwater
Management Seminars in November-December of 1975. The purpose of these
seminars was to disseminate information to 208 agencies, their consultants,
and State water quality personnel on some of the alternative approaches
to stormwater control and to provide a forum, both formal and informal,
for interagency communication on problems and approaches. The proceedings
from these seminars include the formal presentations as well as many of
the questions and responses from the informal sessions. The presentations
have not been edited, due to the Water Planning Division's desire to provide
this information in a timely fashion for 208 planning purposes.
These seminars were conducted under a contract to Herbert Poertner,
Research and Engineering Consultant, who provided for speaker participation
and for conference arrangements. Regions IV and VIII hosted the seminars,
and recognition and thanks are extended to Scott Berdine and Paul Ferraro
and their staffs for their many contributions.
These proceedings are intended to give the reader a general overview
of the urban stormwater problem. The first section is directed toward:
a characterization of the problem, discussion on the viewpoint of the
Division toward stormwater management, data collection and analysis,
and modeling. Section Two covers some alternative techniques of stormwater
management. Issues concerning implementation are addressed in the last
section and include financial, legal, and institutional problems. This
document does not purport to contain all answers to the reader's specific
stormwater problems, but will, hopefully, provide guidance through the
formal presentations, questions, and responses, and bibliographies that
follow.
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INTRODUCTION TO PROGRAM
by James Meek
Water planning Division
U.S. Environmental Protection Agency
Washington, B.C.
This is the first in a series of technical sessions that we are planning.
There will be another stormwater seminar in Denver, December 2-4, which is a
replay of this one. We are trying to offer these courses in different parts
of the country so that travel isn't prohibitive. A water quality monitoring
course will be given in Cincinnati, December 8-12. We haven't anything else
scheduled, but we're going to have either 1-day or 2-day sessions on other non-
point source problems, such as mining, agriculture, silvaculture, et cetera.
These will be handled by R & D. They will be workshops, organized to provide
an exchange of information.
This brings us to what we want you to get out of this seminar. Basically,
it's three things: first of all, we want a two-way exchange of information.
In other words, we are going to provide the state-of-the-art and we want you
to give us feedback of what your problems are and what you want from us. We
also want an interchange among yourselves. Finally, we want your reactions.
This is the first of the series and we want to know what kind of help really
helps and which future courses can really help you do your job.
We realize that the two-year study and planning period is a very short
time. This makes it practically impossible to document successes and failures
and get such information distributed before it is too late. We are relying
heavily on these kinds of sessions and we want to tailor them to your needs.
We will be very interested in your appraisal of this seminar and what your re-
actions are. Please let us have your evaluations before you leave the seminar.
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WELCOMING REMARKS
by John A. Little
Deputy Regional Administrator, Region IV
U.S. Environmental Protection Agency
Atlanta, Georgia
We had a briefing yesterday with the Office of Management and Budget
in Washington. Each year they pick one EPA region with which to discuss the
upcoming budget. I know that a lot of you are associated with Section 208
planning. One of the things we talked about is non-point-source pollution.
I know that OMB has impressions regarding the fact that the 208 planning areas
are .often SMSA's and, as such, are pretty closely tied to the metropolitan
areas. So, they reason, when you develop your plan, isn't all this non-point-
source runoff going to pollute the streams anyway? Their concept of the non-
point source problem is agriculture, primarily. I tried to tell them that
urban stormwater is probably a much bigger problem than agricultural runoff
in any one of these areas.
We don't have too many stormwater problems in the Southeast, compared
to many areas of the country. However, we have a nice problem in Atlanta.
We have a new plant on the Chattahoochee River which gets overloaded whenever
it rains. We're running into this kind of problem in a few other areas.
One of my former staff from Athens, Georgia has been working on storm-
water problems related to environmental impact statements. There is no area
that EPA and its predecessors have spent more money on, through demonstration
projects, than this total stormwater management problem. I think we're look-
ing for some answers and applications to conquer this problem.
We are very glad to have you here in Atlanta. Have a good meeting!
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WELCOMING REMARKS
by Charles Murray
Director, Division of Water Programs
U.S. Environmental Protection Agency
Region VIII, Denver, Colorado
I am on the program today to give you a welcome from my boss, Jack
Green, Regional Administrator of Region VIII, who is in Washington, D.C. today.
I think it is an interesting coincidence that today is the Environmental Pro-
tection Agency's fifth birthday. Five years ago today we were created by exec-
utive order. Needless to say, it has been an interesting five years. And,
frankly, I think that the system has been successful; and, by the "system",
I'm referring to many of the professionals in this room, including representa-
tives of the Environmental Protection Agency, State governments, local govern-
ments, and industry, as well as private citizens and elected officials.
I think it has been a team effort over the past five years to try to
respond to some very significant national legislation addressed to protecting
our environment. I think real progress has been made in a very substantive
beginning in the past five years. Jack wanted me to touch on some of the
things that we see that are so exciting about the 208 program. We feel that
there are great opportunities, particularly in this Region, to get out in
front and implement our "prevention" strategy which, in our Region, is every
bit as important as "abatement" strategy.
The 208 program is a unique tool to us to do this sort of prevention
planning and get out ahead of the problems to avoid repeating mistakes of the
past. When we look at this 208 program, there are three or four things that
we try to emphasize. Today I have the opportunity to talk to a group of
people who are dealing day-to-day with the 208 program. You are the ones who
have to make it work. I think I ought to share with you where we're coming
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from and things that we see that are so important in this process.
The first thing is that we are trying to develop a greater "environ-
mental awareness" in the planning process—not just for the water dimension,
but to really look at environmental planning and build a continuing planning
process that is financially self-sufficient where it really conserves the en-
vironment in the decision-making process. We're trying to strengthen water
quality management, when you look at the planning part of it, as another tool
for management—a very important tool for management in making decisions that
really consider environmental impact.
We're trying to develop an environmental sensitivity throughout this
planning process so that, whether you wind up with an environmental assessment
or the full-blown environmental impact statement, your planning process is
going to be able to withstand close scrutiny by people who are interested in
protecting the environment.
We're talking very seriously about implementation—and "early-on" im-
plementation, taking actions now and not waiting for the end of the planning
process. I see no real reason for that kind of delay. There are ordinances
and regulations that can be passed today by local government that could really
protect the environment--particularly in relation to activities in managing
the land that impact on water quality. So you're going to hear, when dealing
with EPA Region VIII, these messages and themes, over and over again, because
these, we think, are completely integral to a successful 208 planning process.
Turning to the subject matter today, which is an "Urban Stormwater
Management Seminar", we're turning to a area that I've been interested in for
a long, long time. It is with a great deal of interest that I approach the
subject matter that you're going to be addressing for the next three days.
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Quite frankly, in the past, the planning part was the easy part. The
implementing part was the difficult part, and that's still true of most any-
thing we do. But I think it is particularly true when we deal with storm
drainage because you come face-to-face with money problems, and that is the
"key" problem in implementing storm drainage plans, in my judgement. At least,
that has been my experience.
As a result of five public hearings that we held across the country
dealing with changes in P.L. 92-500, one of the changes that EPA recommended
to Congress was that we eliminate storm sewers as eligible for construction
grant funds. When you look at the national needs for treatment and major
interceptors, you can see the restraints imposed upon the system and why this
kind of recommendation must be seriously considered. I think that this demon-
strates that, when you're dealing with the stormwater runoff element of the
urban environment, funding is going to be critical. So, I think that it be-
hooves you to look at non-structural, "preventive"measures and controlling
new activities. These are things you can do today, and quite simply. So, I
think that, although you are going to have to look at this in the systems con-
text, you are going to have to put a great deal of emphasis on the non-struc-
tural, preventive aspects for the urban stormwater management element in the
208 program.
I've taken longer then I was supposed to, but Jack did want me to share
with you some of his thoughts. He was sorry he could not be here. We think
that this seminar is going to be extremely useful to you in evaluating your
urban storm drainage problems. We are happy to be a part of it and provide
you some assistance in the technical area that you are grappling with.
I am sure that this seminar is going to serve a useful purpose to you.
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I think it goes without saying that it is going to require a very cooperative
team effort from all of us if we are going to be able to isolate and examine
the urban stormwater problem, and then integrate that element into our overall
water quality management program. I wish you a lot of luck in the next three
days and a lot of luck in going back home and applying what you learned to
the 208 process in your area. Thinks very much for coming. It has been a
real pleasure to talk to you.
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I. Characterization of the Urban Stormwater Problem
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Best Management Practices (BMP)
Dennis Athayde
Water Planning Division
This morning I would like to tell you about the latest thinking,
within the Water Planning Division, on the management of urban runoff.
I would like to tell you what the policy is going to be, but 1 can't.
Because the issue of whether or not urban runoff is to be treated,
managed, or brought under the National Pollution Discharge Elimination
System has not been fully resolved by the Agency at this time.
As your know, Section 208 addresses nonpoint sources, of which
urban runoff is one. Or at least has been considered as one in the
past.
In the court decision of the National Resources Defense Council
versus Russell E. Train (DDC 1629-73), known as the Flannery decision,
or the Feedlots Case, the issue that was resolved, after an appeal,
was that the Administrator does not have the latitude to exempt entire
classes of point sources from the NPDES permit requirements. The
order from the decision is that by November 10, 1975 the Agency will
publish proposed regulations extending the NPDES system to include all
point sources, including separate storm sewer categories, and final
regulations are to be published by March 10, 1976. The final
judgement went on to say that the Agency is to determine the approach
and strategy to be followed in regulating previously excluded point
sources ... including determination of appropriate technologies or
management procedures to reduce pollution from these categories.
Best Management Practices (BMP)
What is BMP? What is a best management practice? The Guidelines
for Areawide Waste Treatment Management Planning,August 1975, defines
BMP as "... a practice or combination of practices that is determined
by a State after examination of alternative practices to be
practicable and most effective in preventing or reducing the amount of
pollution generated by a nonpoint source to a level compatible with
water quality goals."
BMP is a mechanism that emphasizes the management of sources of
pollutants, and the preventive approach. A BMP is comprised of
several management techniques and its composition is dependent on the
area it serves. It is these practices or techniques that we will talk
about here.
The Urban Stormwater Problem
The stormwater runoff problem is a direct result of urban growth
and development. Roughly eighty percent of the population of the U.S.
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is now urbanized, with the process of urbanization proceeding at an
estimated rate of about 1,500 square miles per year. While the
problem is growing, the scarcity of information available on the
impact of stormwater flows on receiving water quality poses a serious
problem to the development and administration of effective local
management programs.
Pollution from urban runoff occurs when precipitation flushes the
urban environment and carries pollutants to receiving waters.
Potential pollution - from roof tops, streets, parking lots, shopping
centers, commercial buildings, industrial complexes, automobiles, etc.
- forms across the surface of an urban area, and tends to increase in
depth with an increase in time between precipitation events.
As the surface is flushed, the polluted water flows overland
toward the collection systems. The initial collection systems are the
land surface and roof tops, which slope toward the secondary
collection systems of roadways, streets, gutters and drains, where
surface water concentrates as it flows into the sewerage systems.
These sewerage systems are of two general types, separate and/or
combined. Separate storm sewers generally convey only storm or
snowmelt runoff, whereas combined sewers carry both storm and snowmelt
runoff and untreated municipal wastewater. Separate storm sewers
generally discharge directly into the receiving waters at many
locations. Combined sewers usually have flowsplitting devices which
bypass a high percentage of untreated combined sewage directly to the
receiving waters, and the remaining smaller fraction receives some
treatment before being discharged.
Considering the route that runoff takes, it is not surprising
that polluted runoff contains substantial amounts of organic material,
inorganic solids, nutrients, heavy metals and microorganisms, which
can have a significant impact on receiving water quality.
The total annual pollutant load in stormwater, during storm
runoff periods, can be greater than the annual pollutant load
discharged from municipal treatment plants during dry weather. This
could preclude meeting water quality standards regardless of the
degrees or types of treatment afforded dry weather wastewater flows.
Unregulated runoff leads to a number of inter-related problems,
including accelerated erosion of land area and stream banks,
sedimentation of channels, increased flooding, increased potential for
public health problems, deterioration of aesthetic quality, and
degradation of water quality. To aid in characterizing urban runoff
problems, it is convenient to divide the urban environment into two
parts, existing and new.
Existing urban runoff problems are those resulting from developed
urban areas, areas where structures and pavements are in place,
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population densities are high, and where drainage is accomplished
primarily through man-made conveyances. New urban runoff problems are
those associated with planned or future urban development. These are
areas where man's encroachment is presently minimal and where drainage
is essentially natural.
The objective of stormwater management, from the Agency's point
of view, is to reduce the negative impact of runoff on water quality
and the related problems to acceptable levels, at an acceptable cost.
The four principal alternatives for stormwater management are (a)
source controls, (b) collection system controls, (c) storage and
treatment and (d) more complex approaches embodying elements of each
of the preceding three. Examples of source controls include surface
flow attenuation, erosion control and improved sanitation practices
such as street cleaning. Collection system controls include
inflow/infiltration control, temporarily increased line carrying
and/or storage capacity, and sewer separation. Storage variations
include concrete holding tanks, open basins, and various underground
containers.
For existing urban areas, limited source controls such as street
sweeping and other housekeeping techniques may be the only practical
approaches. Source controls and collection system controls which
emphasize storage for the purpose of attenuating the rate of runoff
rather than for ultimate treatment probably make more sense physically
and economically in newljr developing areas, where their implementation
coincides with the design and construction of new facilities.
BMP; The Preventive Approach to Urban Stormwater Management
The first two management approaches — source controls and
collection system controls — constitute the essential elements of a
"preventive" approach to urban stormwater management. They emphasize
measures for reducing stormwater pollution either (a) within the
drainage basin, before runoff accumulates and enters the sewer
systems, or (b) through management and alteration of the collection
system itself. As such, they both offer a range of alternatives to
costly "after-the-fact" storage and treatment of collected stormwater
runoff.
The preventive approach tends to focus on developing areas,
rather than on already highly developed areas, where source controls
and collection system controls can be implemented more efficiently and
effectively, with less disruption. However, even in heavily urbanized
areas, collection system controls designed to minimize overflows,
leakage and ruptures can be very effective in reducing storm-related
pollution. Also, source controls and collection system controls
become more feasible alternatives in highly developed urban centers
where major urban redevelopment occurs.
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The preventive approach stresses maintenance of the existing
ecological equilibrium in a watershed, by minimizing the impacts of
man's intrusion and preserving the watershed's existing runoff
characteristics. An important means for doing so involves flow
attenuation, that is, controlling the quantity and rate of flow of
urban runoff. Flow attenuation, in an hydrologic sense, means to
increase the time of concentration and decrease the magnitude of the
peak runoff. When runoff velocities are thus reduced, less pollutants
are entrained and the degradation of water quality, mitigated. Also,
less soil erosion results, again because runoff velocity is reduced
and with it the erosion force. Large volumes of water are not allowed
to accumulate at constrictions but instead flow at reduced rates over
a longer period of time, thus reducing the possibility of flooding.
Preventive runoff management is thus a multi-purpose approach,
with water quality being an important consideration but not the only
one. Erosion control, flood control, water supply enhancement,
protection of the public health and enhancement of recreational
opportunities and aesthetic amenities are also important beneficial
effects of flow attenuation. Publicly financed abatement programs
directed primarily toward water quality have been difficult to justify
economically; the preventive approach to urban stormwater management
allows linkages with other environmental management objectives and
programs, and promotes integrated, cost-effective solutions to multi-
faceted problems.
The cost-effectiveness of the preventive approach is enhanced
because it emphasizes less costly solutions, i.e., comprehensive
planning and local regulation in place of capital-intensive treatment
facilities or, where facilities are required, smaller treatment
facilities and relatively less expensive detention devices. Planning
for spatial allocation of development can reduce runoff generation, as
can public acquisition of open space and preservation of permeable
areas. Regulations of certain types of land uses through
establishment of performance standards can also reduce the generation
and accumulation of runoff. Effective anti-litter ordinances, street
cleaning services and infiltration/inflow controls can do much to
reduce the treatment burden resulting from urban runoff. Flow
attenuation techniques can slow the flow of significant amounts of
stormwater into the sewers, and the cost of almost any system for
abating storm sewer discharges and combined sewer overflow pollution
is very sensitive to both the quantity and rate of flow involved.
Dentention of runoff in impervious areas reduces the rate of flow and
hence increases the period in which the same runoff volume can be
treated. Retention of runoff in pervious areas can reduce the total
flow that reaches the sewers by allowing additional groundwater
recharge through percolation. Both techniques thus allow the
construction of smaller treatment facilities and the realization of
lower 0 & M expenses.
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The preventive approach consists of a^ stance which urban areas
can take toward their future growth and development. It postulates
that urbanizing areas don't have to merely accept whatever development
comes along, and simply collect and treat the resulting runoff as if
it were raw sewage. Instead, they can either (a) directly regulate
activities or (b) ensure that the development which does occur is
accompanied by safeguards which will minimize the generation and
accumulation of runoff,,
This seminar is an initial effort in providing timely assistance
in the form of appropriate technologies and management procedures to
reduce pollution from urban runoff.
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Considerations in Characterization
of
Urban Runoff
for
PL 92-500 Section 208 Planning
by
Francis J. Condon, P. E.
Office of Research and Development
Environmental Protection Agency
December ]0, ]975
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Considerations in Character ization
of
Urban Runoff
for
PL 92-500 Section 208 Planning
The information contained in this paper is most-
ly taken from published or soon-to-be published reports
of the Environmental Protection Agency.. The intent is
to pull together the sections of these various reports
which pertain to the topic of Consideration of Charac-
terization.,
When addressing this subject it should be kept in
mind that there are three sources of urban runoff; com-
bined sewer overflows, storm sewer discharges and over-
land or non-point runoff. Each has like and unlike
elements in the consideration of characterization, im-
pacts and remedial methods. The identification of each
is also, to some degree, a function of the definitions
chosen. The intent is not to become involved in de-
fining and discussing each source but rather to present
an overview which is applicable to Section 208 planning.
The principal types of planning programs now under-
way in water qualit/ management can be grouped as follows:
1. Long range framework plans for coordinated manage-
ment, of resources over large areas, such as State
water plans, State land-use plans and framework
studies designated under Public Law 89-80,
Section 102.
2. Medium range plans for identifying specific
action for the development, protection and
conservation of resources such as basin plans
under Section 303(e) of PL 92-500, Section 203,
Level 3 studies of Section 209 and specific
functional plans for energy, transportation,
land use and water resources.
3. Detailed site specific studies for facilities
planning pursuant to Section 201, and evalua-
tion of discharge permit applications.
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Planners and managers responsible for the performance
of the above and other types of planning programs must
deal with the engineering, economic, financial, legal,
institutional and environmental aspects of water quality.
The detail required in the analysis of those aspects de-
pends upon the planning purpose. Broad framework plans
seldom require the detailed analysis appropriate to an
areawide 208 waste treatment management plan, while a
208 investigation seldom requires the detailed engineer-
ing type data of a Section 201 plan. These and the next
few observations are contained in the EPA report entitled
"Cost Effectiveness of Water Quality Decision Methods -
Water Quality Modeling Handbook for Planners," by
Grimsiud, G.P., Finnomore, E.J., Owen, N.J. and
Lewis, D. M.
One of the first crucial decisions encountered by
planners and managers is selection of planning methodo-
logies. The methods chosen should fit the situation and
be capable of execution within the limits of time and
budget. The selection of the planning methodologies
must take into account the types of analyses needed and
the number of analyses to be made. This means that the
first task is a complete problem identification and
description.
The full description of water duality problems or
water quality component of problems requires identifi-
cation of the location, nature, and magnitude of the
pollution sources as well as the resulting impact on
water quality. Preparation of a complete problem de-
scription may be relatively easy in the case of in-
dividual point sources of waste which have been or can
be readily monitored and where ambient water quality
changes can be directly related to specific effluent.
In other and more complex cases, arriving at an adequate
description of the problem may constitute a major por-
tion of the planning process. In these more difficult
cases, the water quality analyst, using modeling or
other appropriate techniques, becomes a key member of
the planning team.
Nonpoint sources of pollution occurring with
variable severity throughout an area or different
portions of an area and in conjunction with one
another present a particularly difficult task for a
planner. Component parts of such pollution loads
must be identified and qualified in at least general
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terms. Otherwise, corrective actions are likely to
to be proposed on a more or less arbitrary basis
and without assurance or even a knowlegable estimate
of their efficacy. The financial and social costs of
pollution abatement measures are too large to permit
such speculative planning. It falls then to the
analyst and planner to set forth an analytical pro-
cedure which will remove the mask of complexity and
enable clear understanding and description of the pro-
blem.
Once the problen is defined technical difficulties
may be encountered in making 208 evaluations. These
may include:
(a) the location, nature and extent of non-point
sources;
(b) the complex biological, chemical and physical
interactions which take place over time be-
tween land use, effluents, discharges and
receiving waters;
(c) effects of various types and amounts of
waste treatment upgrading or the generation
and release of various pollutants which
affect water quality; and
(d) water quality impacts resulting from modifi-
cation of hydraulic regimes, land use, or
other actions.
In addition to technical difficulties, the number
of waste management alternatives which exist and re-
quire evaluation may be large. The complexity of water
quality analyses and the need to investigate large
number of alternatives has stimulated the development
of a varity of tools ranging from simple graphical
techniques to sophisticated computerized models.
Whatever the tool chosen one should know the site
specific characteristics and impacts of urban runoff
within the context of the 208 area land use, the re-
ceiving water characteristics and the planning method
used.
Hence we arrive at our subject - Consideration in
Characterization of Urban Runoff.
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This subject can be interpreted in many ways.
When addressing it the scope is so broad as to be al-
most overwhelming. Many aspects deserve much more
time than can be given here. However, all of the
elements mentioned will be covered in more detail
by other speakers. This presentation is intended
to give an idea of what should be considered in charac-
terization. Therefore, the discussion will focus on
the more pertinent elements and utilize a skeleton
form of presentation.
The first topic in discussing Characterization is:
"Why Data Are Necessary." This topic is fraught with
possibilities. Immediate variants of this theme could
be: "What data are needed for problem definition," or,
"Why reliable site-specific data are necessary;'1 or,
"What the weaknesses of existing data are;" or, 'How
best can scientific data be communicated to the planner
users5' and continuing on for any number of subtopics.
The following observations highlight some of these
variants of "Why Data Are Necessary.
The approach chosen is to paraphase or quote
nationally known experts or publications and then add
some thoughts from personal experience.
1. Wallace and Dague in a paper published in the
J. WPCF in 1973 said the determination of the
effects of land runoff on water quality is
a complex problem and was suited to mathe-
matical modeling. They then pointed out the
difficulties in achieving accurate modeling
results. These are verified land and river
hydrologic data, pollutant characteristics
and receiving water quality data. As an
aside one can say that covers most of every-
thing.
2. Whipple et al in the Journal in 1974 said
that only data that are systematically gather-
ed and classified with respect to population,
industrial activity and hydrologic background
can be expected to be useful for planning
purposes. At a minimum I would add land
use and the drainage system.
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3. Terstreip and Stall in reporting on the Illudas
that is, the Illinois Urban Drainage Area Simi-
lator, in a paper given at the National Symposium
on Urban Rainfall and Runoff and Sediment Control
in 1974 said, and this is a quote, '"The present
limited amount of urban hydrologic data is a
serious deterrent to development and testing
of storm runoff models. It seems unlikely that
any significant improvement in current models is
possible until more data and better quality data
are available." End of quote.
4. An article in the December 1973 Diplomate after
summarizing a portion of known data concluded
that reliable knowledge of storm patterns over
urban areas and the associated runoff pollutant
characteristics is most important on a site
specific basis. Emphasis was placed on the
fact that the engineering significance of such
data for pollution assessment and remedy was
great. It went on to say that rain gage net-
works and sampling programs to determine
pollution loads and receiving water impacts for
planning and determining abatement measures, if
required, are necessary.
5. Barter and Sherrill of the University of Michigan
in their report 'Rainfall-Runoff Relations on
Urban and Rural Areas" noted that there were a
number of basins which did not follow the
expected runoff pattern when basin size and
population density were taken into account. They
went on to conclude that perhaps the
differences could be explained if more were
known of the density and efficiency of the
drainage system and the related land use. They
suggested that some measure of drainage efficiency
could be used in place of population density
as a measure of urbanization.
6. A recent publication entitled "A Practical Frane-
work for River-Quality Assessment," Geological
Survey Circular 715-A by Rickert and Hines sums
up nicely why data are necessary. A resume of
some of the points made in that booklet are as
follows:
1-12
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(a) The tendency today is to conduct
river quality assessments solely
on the basis of existing data.
This approach is mostly ineffec-
tive, because existing data are
seldom adequate to support inten-
sive assessment of multiple pro-
blems .
(b) Correlative data on hydrology and
especially waste discharges are
seldom determined. As a result,
most monitoring and surveillance
data indicate effects rather than
give insight into causes.
(c) Monitoring programs usually collect
limited grab samples at widely
dispersed sites under a variety
of conditions. Such data rarely
provide quantitative knowledge.
(d) The relation between riverflow and
time of travel is seldom known or
is overlooked in the planning of
monitoring programs.
(e) The inherent sampling and analysis
errors for river quality variables
are relative large. A number of
sample sets are necessary to define
a range of error as a index of inherent
variability.
(f) Each new study will be faced with
collecting information to fit
specific needs not covered by exist-
ing data.
(g) Useful assessment requires a mutual
understanding between the resource
scientist or engineer and the plann-
er. The scientist needs to assess in
the context of planners requirements,
and the planner needs to understand
the meaning and implications of the
scientist's findings. Host environ-
1-13
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mental assessment tend to be unila-
teral. (My comment is that Section
208 planning studies provide the
vehicle for cooperative ventures).
This is enough to make the point that more base
data are necessary. You will note that data are required
across the entire spectrum. Site specific rainfall
runoff relations, land use, runoff systems, discharge
characteristics, and receiving water hydrology and
impacts, have all teen identified as lacking reliable
data for engineering type assessments.
Given this litany of needs, where does one start?
Based on our program experience it is strongly recommended
that at the earliest date possible a rain gage network
be made operative in the area(s) under study. This is
one of the most needed and easiest information require-
ments .
If data are to be collected these are the minimum con-
ditions which must be met.
(a) Measurements of runoff characteristics and
impacts are useful only with respect to their
relationships with each other and with associat-
ed conditions.
(b) Flow measuring is as critical as flow sampling.
(c) There must be sufficient base knowledge along
with real time data collection of the receiv-
ing water conditions and hydrology. This is
an often underestimated data need.
(d) There must be reasonably accurate urban hydro-
logic and land use data.
(e) Any study on impacts must be based on compre-
hensive, integrated assessments of present and
future land and water use.
(f) Finally and most importantly there must be time
synchronous data on rainfall, runoff hydrology,
runoff characteristics and receiving water
conditions and hydrology.
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EROSION
TOXICITY
EUTROPHICATION
ALGAL GROWTH
NUTRIENT-PESTICIDES
METALS TRANSPORT
INDICATOR BACT., SEDIMENT
DO, TEMP., DISSOLVED SOLIDS
RELATIVE DIFFICULTY OF APPLIED MODELING FROM "A
PRACTICAL FRAMEWORK FOR RIVER QUALITY ASSESSMENT" BY
D.A. RICKERT AND W. G. HINES. GEOLOGICAL SURVEY CIRCULAR 715-A
An observation on the length of time of such data
gathering is in order. In a statistical evaluation of
rain events done by NOAA one of the findings was that
85 percent of the various intensity and duration rain
events for a given location will be experienced in 2.3
years. This is with 90 percent confidence. Therefore,
in our storm and combined sewer program we maintain
that a minimum of three years of data collection on
rainfall, runoff loads and receiving water impact are
necessary. This does not necessarily mean every run-
off event is sampled. A statistically selected number
of events per season over a three year period may be
sufficient.
Additional reasons on the necessity of base data
are the author's observations. The following points
are specific to urbanized areas and are based on work
done in the EPA R&D program. Firstly, we know generally
the daily deposition rates of pollutants on urban sur-
faces as a function of traffic and land use. We also
have developed a surface sampling procedure for pollu-
1-15
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tant loading in which there is reasonable reproduce-
ability. Secondly, there has been effort put into
determining the "pollution storm" (that rainfall which
will produce measurable runoff for various surface
conditions), the runoff return frequency and the
''design storm" runoff volumes. Thirdly, we have know-
ledge of, and have developed, mathematical models for
application to storm water runoff.
But where dat.a is needed is in the determination
of site specific pollutant accumulation rates as
opposed to deposition rates, and of equal importance
is the determination of the pollutant runoff loading
Attenuation factor.
In the work we have done we have not established,
with reliability, the relations between the pollutants
on the urban surfaces available for flush and the mass
emission being discharged from the outfall in wet
weather flows. We have not obtained a mass balance.
The generalities hold true: dirty land use - dirty
runoff, parking lots worse than roadways, uncontrolled
surface modification - heavy sediment loads, and so
on. But we haven't been able to repeatedly predict
a given pollutant runoff load as a function of sur-
face samples.
This non-relationship may be caused by the attenua-
tion of some pollutants as they are transported from the
surface to the discharge. The sediments loads are
sometimes higher than predicted while BOD is less.
The failure may be in the flow sampling and measuring
techniques. Or, it. may be in the peculiarities (hydrologic
and otherwise) of a given collection-transport system.
We don't know. The only aspect we are sure of is that
site specific runoff and characterization data gathering
is necessary if remedial decisions based on quantitative
data are to be made.
Lastly, the most important point of all is that
we have no nationally verified data of the impacts on
receiving waters cajsed by urban runoff. There is base
information need for: (a) the seasonal differences,
(b) the different types of receiving waters, (c) the
different flow regimes, and (d) the key pollutant
determinations.
1-16
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Up to this point the discussion has pointed out
the deficiencies. This is so because the needs numerat-
ed are at the quantitative level. If the goal of a
given 208 study is principally to provide managerial
and planning guidance then the outlook is somewhat
brighter.
EPA and others have provided, and in the near
future will provide more, data and information which
can be used in the qualitative sense.
Through the various mathematical models including
the EPA developed Stormwater Management Model, and
reports such as "Contributions of Urban Roadway Usage
to Water Pollution," "Urban Stormwater Management and
Technology - An Assessment" "water Quality Management
for Urban Runoff," and "User's Handbook for Assessment
of Water Pollution From Non-Point Sources," we have
provided a foundation upon which the engineer-scientist
can build a specific qualitative method for a timely
preliminary assessment of the cause and effects of
runoff pollution. From this point the planners,
engineers and scientist together can then develop
a program for conducting further work to upgrade
assessments to the quantitative level.
In this vein I will make a suggestion for your
consideration. The original Water Pollution Control
Act of 1956 provided for Comprehensive River Basin
Studies. These studies were carried out from 1956 to
1960. Large amounts of receiving water data were
gathered. Perhaps, if one were to obtain old land
use maps, stream flow data and precipitation records,
and couple these with the River Basin studies findings
and now available data a leg up on qualitative assess-
ment would be gained.
The qualitative assessments which can be obtained
through the 208 program will be highly valuable to the
decision making process. This leads us into the
second topic of Characterization Considerations. That
is, "Sampling Procedures."
In this short discussion let us straight away dis-
perse with any hang-up on the point versus non-point
source definitions. We have to have a channel or con-
tainment of some sort in which to place the sampler.
1-17
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Whether it is a ditch, pipe, gutter, gully, stilling
tank or whatever the sampling has to be done at a
point. Despite legislative definitions most urban
runoff enters receiving waters at a point. The user
can decide if the discharges meet point or non-point
criteria. Therefore,, it matters not in terms of the
following discussion if your concern is point or non-
point. To further limit the subject we will not
address here sampling procedures in receiving waters.
The following base-line conclusions on procedures
are derived from available or soon to be published EPA
reports of our program. These are "Recommended Pro-
cedures for the Conduct of Storm Generated Discharge
Projects," "Collection of Field Data for Stormwater
Model Calibration," and "Nationwide Characterization,
Impacts and Critical Evaluation of Stormwater Dis-
charges, Combined Sewer Overflows and Non-Sewered
Urban Runoff."
1. An automatic liquid sampler is one tool of
several that must be employed for the charac-
terization of runoff. Grab or random samples
have little application in storm generated
runoff. The selection of the sampler must
be based on the consideration of the overall
sampling program, the characteristics of the
flow to be sampled, the physical characteris-
tics of the sampling sites, and the analyses
that are desired.
2. In view of the large number of highly variable
parameters, no single automatic sampler can
exist that is. universally applicable with
equal efficacy. Some requirements are con-
flicting, and careful trade-off studies are
required in order to arrive at a "best"
equipment selection for a particular prograr,
A systems approach is required for either
the choice or design of automatic samplina
equipment in application to runoff.
3. The proper selection of the sampling site can
be as important as the selection of the sampl-
ing methods and equipment. A clear understand-
ing of the data use requirements is necessary
as is familarity of the basin to be evaluated.
1-18
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4. Specifications of equipment to be given care-
ful consideration are: intake design, specimen
intake and transport velocity, line size, and
sample capacity.
5. The most common problems in field use of sam-
plers are: leaks in vaccum operated units,
faulty automatic starters, inlet blockage,
line pluging, limited suction lift, low trans-
port velocities, complicated electrical systems,
and failure of timers, micro switches, relays,
contacts and reed switches.
6. The greatest problem is the selection or de-
sign of a sampler intake that can gather a
representative sample, even in stratified
flow conditions, and at the same time be re-
latively invulnerable to clogging or damage
due to solids or debris in the flow stream.
7. In-situ monitoring, at this time, is not re-
commended to replace analytical laboratory
measures. In situ monitors can be used for
determining changes in characteristics once
reliable relationships between runoff para-
meters are established.
8. Flow measuring rivals sample taking in
importance. Devices for gaging wet weather
flows vary in complexity from a dipstick
or chalked length of rope to sophisticated
electromechanical and electronic instruments.
Float gages and bubble tubes have found most
common use to date. Ultrasonic level gages
and bubble tubes have found most common use
to date. Conductivity or dipper gages are
gaining in use for storm generaged dis-
charges .
In summary the desirable procedures and sampler
characteristics are:
. The ability to take a sequential timed series
of discrete samples.
. Use .an external signal to allow sample freauency
(volume) to be taken proportion to flow rate
or increments of flows.
1-19
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Four different sample containers should be filled
at each sampling:
a) one for solids and BOD testing to hold no
presentatives
b) one for metals and TDD analysis, acid added
to preserve samples.
c) one for nitrogen and phosphorus, HgCl
mercuric chlorine, added.
d) a sterilized container for bacteria analysis,
or grease and oil, or other tests.
A capability of handling 2000 cc containers.
Capability of programming the time interval.
Short sampling intervals in early stages or
runoff, longer intervals as storm continues.
Capability to hold 96 sample containers.
Refrigeration capability to hold samples at 4 C.
Capability of lifting the specimen 25 ft. or
more without affecting sample size.
Have a self contained power source.
Be automatically activated and sample at the
beginning of runoff.
Inlet line sufficiently large to eliminate
plugging.
Inlet sampling velocity sufficiently high to
keep heavy particles in suspension.
Inlet of such configuration to allow representa-
tive samples.
Inlet to be sel:: cleaning and the capability to
purge sample lines.
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INSTRUMENTATION PERFORMANCE
50 TREATMENT FACILITIES
1972-1973
NO. OF CASES
10 15 20 25 30 35
BUBBLER TYPE LEVEL DETECTORS 39
j DIFFERENTIAL PRESSURE, LEVEL DETECTOR
FLOATS
I ALL OTHER LEVEL DETECTORS
WEIRS AND FLUMES
VENTURIS, ORIFICES, NOZZLES, ETC. j
MAGNETIC FLOW RATE j
fr^j J OTHER FLOW METHODS
I NUCLEAR RADIATION DENSITY METERS
RAINFALL TRANSMITTERS
I TEMPERATURE
PRESSURE
SPEED
WEIGHT
POSITION
] TURBIDITY
CONDUCTIVITY
I PHANDORP
THALLIUM DO PROBE
I MEMBRANE DO PROBE
J RESIDUAL CHLORINE
OTHER OFF-LINE ANALYZERS
I GAS MONITORS
SAMPLING SYSTEMS
UNSATISFACTORY [\\| FAIR ] j SATISFACTORY
FROM EPA DRAFT REPORT "INSTRUMENTATION AUTOMATION
EXPERIENCE IN 50 TREATMENT FACILITIES" BY
MOLVAR A. J., ROSLER J. F., WISE R. H., BABCOCK R.
1-21
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The sampler which meets all these specifications
does not exist. But try to fit specifications to
your more critical conditions.
The next topic of Characterization Considerations is
''Analytical Techniques. ' The information given is
covered in the previous cited reports.
I wish to emphasize the fact that we are confronted
with a two fold problem. The urban runoff, although in
a liquid form, has characteristics which will prevent
reproducibility of results for certain standard para-
meters. Secondly, when the urban surfaces are sampled
the dry dust and dirt must be analyzed for pollutants
for which standard methods were developed considering
a wastewater medium., Therefore, modifications to these
methods have to be made in order to analyze particulate
urban surface deposits. Most of these modifications need
to be further evaluated and improved.
A few specific examples are:
a) the digestion procedure used in the estimation
of heavy metals in roadway deposits should be
tested to insure that quantitative recoveries
are achieved.
b) the inability of the classical BOD method to
deal with these types of samples.
c) methods for the determination of rubber and
asbestos. The asbestos analytical method in
particular needs to be upgraded.
Additionally, tnere are other considerations in
data interpretation. As an example, indicator coliform
counts are important in assessing the sanitary quality
of wastewaters and water bodies. The use of this same
characteristics to assess the sanitary quality of runoff
unmixed with sanitary sewage from an urban area could
result in misleading conclusions. Such a conclusion may
lead to a disinfecting requirement when in fact it is not
needed and may do more harm than good.
This brings us to the more useful characteristics
to be analyzed when considering characterization. If
1-22
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we considered all the organic and inorganic compounds
which can be available for flushing the list of possi-
bilities would be near endless. Therefore, let us con-
sider the fundamentals.
The following are usually the more important
classifications.
1. Oxygen Demand - It is universally accepted
that the dissolved oxygen concentration in
the receiving water is a critical criteria
in water quality.
2. Particulate Concentration - In urban runoff
particulates are a large fraction of the
total solids. Suspended solids and turbidity
are critical in water quality.
3. Pathogenic Indicators - Although a classic
criteria the coliform group is not necessarily
a sensitive indicator of pathogenicity as far as
urban runoff is concerned. However, this is a
critical parameter if combined sewage or treat-
ment plant by-pass is to be considered.
4. Eutrophic Potential - The principal nutrient
and trace salts are critical criteria in
most water quality evaluations.
5. Toxicants - In urban runoff this is of special
interest. Some toxicants can directly affect
man (asbestos, lead) while others can have
deleterious effects on the aquatic biota. The
toxicants can be put in the general categories
of heavy metals, pesticides, herbicides and
exotic chemical compounds.
6. In addition to the water quality criteria there
are a number of simple analyses which can be
used to describe the physical state or condition
of storm discharges. These are pH, temperature,
conductivity, color, odor, oils and grease among
others.
To determine these minimum characteristics the following
specific analyses are suggested for urban runoff.
1-23
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The oxygen demand indicator should indicate the effect
of the addition of the discharge or, the oxygen con-
tent in the receiving water. That is, it should qive
an indication of the total oxygen demand on the water.
Additionally, the method should have a standard pro-
cedure and precision so that valid comparisons can
be made for discharges entering widely different receiving
waters.
After weighing the advantages and disadvantages
of the various oxygen demand test, and the accepted
usage, it is suggested that two tests be run. These
are TOD and BOD . The BOD test may require minor
modifications. Even though it is not convenient to
run both tests as an estimate of a single parameter
the importance of oxygen demand needs special consid-
eration.
The suggested measurement of particulate concentration
is influenced by the tremendous array of particulate
solids carried in stormwater discharges. To stay out
of trouble and for the purpose of this discussion,
particulate matter is defined as solids which are
retained on a filter medium upon passage of a sample.
The broad categories of particulates are organic
and inorganic. Runoff has a large amount of inorganics.
But even giving this does not preclude a tremendous
variation at any particular outfall. It is difficult
to predict the concentrations of particulate matter
which one can expect.
Considering the advantages and disadvantages
of the various residue tests, it is suggested that the
suspended residue be used. The analysis is considered
routine and is not time consuming and if need be additional
steps can give the fixed and volatile portion. The
selection of additional tests is dependent on the kind
of data required.
The pathogenic indicator is required with the
above noted cautions. A complicating factor is
that there are many illegal connections and dis-
discharges of sanitary and industrial sewage into
runoff drainage networks. The fecal coliform in-
dicator system is tne superior one at the present
time for assessing the sanitary quality of these
flows. While careful laboratory techniques should
1-24
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be exercised, it is apparent that with the high counts,
high precision is not required. It would be an unnecessary
expense. It is suggested that the MF techniques be
employed for conducting fecal coliform counts. A careful
survey or diagnosis of the stormwater runoff system
for the illegal connections is also in order.
The eutrophication potential has probably re-
ceived more attention in the last 15 years than any
other water resource problem. Eutrophication is a natural
process but men's activities can greatly increase the
rate. At the present time the runoff eutrophication
potential is best determined by the nitrogen and phosphorus
It is suggested that basically two nitrogen analyses
be conducted. The first for total oxidized forms of
nitrogens, that is, the sum of nitrite and nitrate.
The second nitrogen analysis would be for the reduced
forms of nitrogen. For this is is suggested that the
Kjeldahl procedure is used. It is further recommended
that both oxidized and reduced nitrogen analyses be
expressed in terms of weight of nitrogen rather than
individual ions. This way you can add the two values
for total nitrogen content.
The phosphate ion can occur in a variety of solu-
able and insoluable inorganic compounds. It can also
occur in both living and dead organic matter. It is
recommended that total phosphorus analysis be conducted
where impact on receiving water is of concern. In some
investigations it has been shown that analyzing for
soluable phosphate alone can result in erroneous low
conclusions. Therefore, it would be helpful to run
both total soluable phosphate and total phospheous.
To repeat, the two analyses for nitrogen content are
total Kjeldahl and total oxidized. For phosphorus
it is the total phosphorus analysis.
The discussion of analyses for toxicants will not
be detailed. Heavy metal analysis should be done by
atomic adsorption spectroscopy. It is suggested that
first composite samples of the runoff be run for lead,
zinc, copper, chromium, mercury, cadium, arsenic,
nickel, and tin. Then based on the results one can
make a decision on what and how often discrete or
other composite analyses will be necessary. Certain
1-25
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industrial land uses or street salting practices
can be circumstances where determination of uncommon
parameters may be desirable.
In heavy metals, evaluation of the toxic potential
requires that the total amount of the heavy metal be
determined. In some cases it may be necessary to deter-
mine the chemical form of a given heavy metal. Therefore,
because of the organics present, samples should be
digested prior to analysis.
Because of the controversy over pesticides and
polychlor inated biphenyls they do merit special attention.
No pesticide or associated compounds are recommended
for urban runoff routine analysis. However, a study
of the drainage area is necessary to determine the
likelihood of pesticide in the discharges. This will
determine the frequency and season for testing. A
search type of random selection for PCB analysis should
be done early in the evaluation.
There can be a number of pollutants and contaminants
in runoff which are not normally identified in determining
degradation but which may be significant on a site
specific basis. Some of these are asbestos, rubber,
asphaltic materials, oils and grease and sulfates.
Analytical techniques for most of these are undergoing
change. One will need to keep abreast of the literature.
In summary the minimum descrete routine analysis
are:
Potential Oxygen Demand by TOD and
Particulate Concentration by Suspended Solids
Pathogenic Indicators by Fecal Coliform
Eutrophication Potential by Total Oxidized
Nitrogen, Total Reduced
Nitrogen and Total
Phosphorus
Other suggested characteristics - Ph and Conductivity
Flow gaging has been the subject of considerable
R&D effort in industry, government and universities
for the last several years. Despite this, in terms
of the runoff conditions and requirements, flow measurement
is still our most difficult problem.
A procedure will not be given for flow measuring.
1-26
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This is discussed in detail in the paper Collection
of Field Data for Storinwater Model Calibration" by
Phillip E. Shelly. The site, the physical conditions,
the data desired, and a host of other considerations
go into selecting or designing the flow measuring method.
The foregoing are the principal points I wish
to make in sampling procedures. At this juncture a
few words on sample compositing and descrete samples
would be worthwhile. Discrete samples should be taken
on the first sampling runs to establish, if possible,
concentration patterns. They should at least be taken
in the early periods of runoff events. When to begin
compositing will depend on many factors: Observed trends,
economics, needed detail, laboratory capacity available
and other considerations.
Under most conditions the best composite method
is where the volume is proportional to the instantaneous
flow rate. However, with the exception of the simple
composite, the difference in results in urban runoff
are not large between the various proportioning methods.
The subject of compositing is treated in learned
papers, an indepth recitation is not appropriate here.
The point being made is that both flow measurements
and a knowledge of the temporal variation of pollutants
are required to determine the loads and corresponding
impacts, and possible remedial measures.
The last subject in Characterization Considerations
is Mathematical Modeling. This is not to imply that
mathematical models are required to carry out a 208
Plan, but in most instances it will be an importanmt
tool.
Mathematical simulation models, when used properly
and with an understanding of their limitations, can
greatly expand the range of alternatives a planner
may consider and assist in providing information in
an organized form. It should be stressed, however,
that such models are nothing but tools to assist planners
in the difficult task of evaluating alternatives. They
are not a substitute for experience and good judgement,
but a means for permitting these qualities to be used
more effectively.
4
1-27
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Eighteen mathematical models for the nonsteady
simulation of runoff in urban storm and combined sewerage
systems were reviewed in a study sponsored by the U.S.
Environmental Protection Agency entitled "Evaluation
of Mathematical Models for Engineering Assessment Control,
Planning, and Design of Storm and Combined Sewerage
System." The models were evaluated on the basis of
information published by the model builders and model
users. Seven models were also tested by computer runs
using both hypothetical and real catchment data. Most
of the models evaluated include the nonsteady simulation
of the rainfall-runoff process and flow routing in
sewers; a few also include the simulation of wastewater
quality options for dimensioning sewerage system com-
ponents, and features for realtime control of overflows
during rain storms.
All of the 13 reviewed mathematical models are
suitable for the simulation of storm and combined
sewerage systems or for incorporation in comprehensive
simulation models. Considerable differences exist,
however, in the t;^pes of phenomena that are modeled
and in the mathematical formulations for each phenomenon.
The report summarize the objectives, advantages and
limitations of each model. For some applications models
are available with considerable simplifications in
their mathematical detail to reduce input data requirements,
computer storage requirements, and computer running
time. Some models include unnecessary approximations
considering present state-of-the-art of hydrologic
modeling arid computer capability. Some of the simplifi-
cations, however, are based on the need for realtime
control of overflows using a small process computer
with slow execution times but the requirements of repeated
simulations within fixed time constraints.
The models were evaluated on the basis of published
information and communication with model developers.
In addition, seven of the more comprehensive models were
selected for testing by computer runs using hypothetical
and real catrchment data.
In selecting these models, a minimum requirements
was the capability to consider several rain guages, to
compute runoff from several catchments, and to route
flows in a converging branch sewer network. Models
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which rely heavily on mathematical formulations which
cannot be derived readily from catchment and sewer
physical characteristics were not tested, nor were more
models whose oversimplification restricts their use
unnecessarily, considering present computer capabili-
ties and the state-of-the-art of hydrologic modeling.
The 11 models which were evaluated solely on the
basis of published information in reports by model
users are:
1) British Road Research Laboratory (BRRL) Model
2) Chicago Hydrograph Method
3) Colorado State University Urban Runoff Modeling
4) Corps of Engineers Hydrologic Engineering
Center Storage, Treatment, Overflow and Run-
off Model (Storm)
5) Hydrocomp Simulation Program
6) Minneapolis-St. Paul Urban Runoff Model
7) Seattle Computer Augmented Treatment and
Disposal System
8) University of Cinncinnati Urban Runoff Model
9) University of Illinois Storm Sewer System
Simulation Model
10) University of Massachusetts Combined Sewer
Control Simulation Model
11) Wilsey & Ham Urban Vtfatershed System
The seven models which were also tested by com-
puter runs are:
1) Battelle Urban Wastewater Management Model
2) Dorsch Consult Hydrograph-Volume Method
3) Environmental Protection Agency Storm Water
Management Model (SWMM)
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4) Massachusetts Insitute of Technology Urban
Watershed Model
5) Metropolitan Sanitary District Greater
Chicago FLow Simulation Program
6) SOGREAH Lopped Sewer Model
7) Water Resources Engineers Storm Water Manage-
ment Model
A review of all 18 models and preliminary results
of the numerical testing of four models is presented
in the report by Mr. A. Brandstetter.
No single general mathematical model exists that
can simulate all aspects of water quality. Further-
more, it is not clear that such a model should be de-
veloped. Its resulting complexity, assuming that it
could be created, the amount of data needed to validate
it, and the cost of operation would likely make its
use impractical. Instead, a wide variety of specialized
models have been developed to efficiently handle parti-
cular aspects of water quality of interest to planners.
From the planner's viewpoint, models can be classified
by their applicability to various parts of a hydrologic
system, the effects simulated by the model, and the
method of analysis.
In summary, for 208 Planning
1. The first step is to define the problem and
determine both what information is needed
and what cuestions need to be answered.
Remember; The impact on the receiving
water in terms of violations of desired
use and water quality standards is the nut.
2. Use the simplest method that can provide the
answers to your questions.
3. Use the simplest model that will yield ade-
quate accuracy.
4. Do not try to fit the problem to a model, but
select a model that fits the problem.
5. Do not confuse complexity with accuracy.
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6. Always question whether increased accuracy
is worth the increased effort and cost.
7. Do not forget the assumptions underlying
the model used, and do not read more signi-
ficance into the simulation results than is
actually there.
In closing a useable plan at decision time is
worth far more than an excellent one that is late.
Partial List of EPA Storm and Combined Sewer Reports
Applicable to Section 208 Planning not noted in Text.
1. EPA-440/9-75-004 "Water Quality Management Planning
for Urban Runoff." OTIS PB 241 689/AS.
2. EPA-6709/2-75-065 "Short Course Proceedings Appli-
cations of Stormwater Management Models' NTIS -
Pending.
3. EPA-670/2-75-046 "Rainfall-Runoff Relations on
Urban and Rural Areas" NTIS PB 242 830/AS $5.25.
4. EPA-600/2-75-004 "Contributions of Urban Roadway
Usage to Water Pollution" NTIS - Pending
5. EPA-R-2-73-261 "An Assessment of Automatic Sewer
Flow Samplers" GPO Bookstore $2.25, NTIS PB 223
355 $2.60
6. EPA-670-75-041 ''Storm Water Management Model:
Dissemination and User Assistant" NTIS 242 544/AS
$4.25
7. EPA-660/3-74-020 "Estimating Nutrient Loading of
Lakes from Non-Point Sources" OTIS PB 238 355/AS
$3.90
8. EPA-670/2-75-022 "Urban Stormwater Management
Modeling and Decision Making• PB 242 290/AS
$7.00
9. EPA-670/2-74-096 "Characterization and Treatment
of Urban Land Runoff PB 240 987/A3 $6.20
10. EPA-600/2-75-007 "Impact of Hydrologic Modifi-
cations on Water Quality'1 NTIS - Pending
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11. EPA-600/4-75-OC1 "Director of EPA, State and
Local Environmental Quality Monitoring and
Assessment Activities" Office of Monitoring
Systems, EPA Washington
12. EPA-600/5-75-005 "Performance Control for
Sensitive Land: A Practical Guide for Local
Administrators'
13. EPA-907/9-74-005 "Wastewater Sampling Methodology
and Flow Measurement Techniques" by EPA Surveillance
and Analysis Division, Technical Support Branch,
Field Investigation Section
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QUESTIONS AND ANSWERS
(Following Francis Condon's paper "Characterization of Urban Stormwater Problems")
Question (Arthur Jenke, Alamo Area Council of Governments, San Antonio,
Texas): The author of the USGS Circular 715A said that we need more data.
Actually, we have no time to collect this additional data. As far as per-
formance in the 208 area is concerned, we have approximately 20 months. We
must use the data that we have now. Do you have any response to this?
Condon: Yes. You are right and, unfortunately, all of us are right. The item
that I was addressing is quantitative data. This is needed and, in a way, it
is needed to fulfill the requirements of the Act. As you said, the-Act didn't
give you enough time. There is enough data, I believe, to make qualitative
assessments. Soon EPA will have available a User's Handbook giving loading
factors for land use. There is also available the EPA Stormwater Management
Model. EPA has put on short courses in the use of mathematical models and
others are planned.
Question (John Fisher, Consulting Engr., South Bend, Ind.): I share Mr. Jenke's
views about the timing on the 208 Program. I would like to share a few other
points with the 208 people here. We are working on a 208 Program in Western
Michigan, which includes the Grand Rapids area. Because of the funding
formulas which were used, there is not only a time problem but also a dollar
problem in developing an adequate sampling program. So, we had to cut back
somewhat and rely on existing data--STORET data or other programs such as the
Corps of Engineers Urban Studies Programs, some of the U.S.G.S. sampling pro-
grams, and the SCS sampling that has been underway for a number of years. What
I propose is to set up a simple network of the 208 agencies to share the monitor-
ing or water quality data gathering information being developed by them. This
would be a simplified data bank. The outputs might be 8h" x 11", one-page
summaries of the monitoring program—giving the frequency of sampling, the
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constituents being sampled, the p€>riod of record, variation in flow measurement,
the drainage area, land-use classifications that are involved, et cetera. These
summaries could be prepared for use by 208 agencies that can't afford, or don't
have the time, to pursue sampling as they would like to do.
Condon: I think that your suggestion is very good. Timely exchanges of in-
formation is very important. We have some R & D reports coming soon dealing
with characterization and impacts. But, I think that an exchange of hot-line
information such as you suggested would be good.
Comment (John Kingscott, EPA, Washington, D.C.): We have been very aware
that there is a need for lateral exchange of information as it becomes avail-
able. We have taken some steps to formalize an information exchange program
where output reports from 208 agencies, as they are finished, can be published
and distributed to other 208 agencies. There is a need for some specialized
information. The problem with this particular program is that it waits until
the reports are published in a final draft form before they are distributed.
The output will be available toward the end of the planning period. We have
to devise some system that will re!.y on the cooperation of each 208 agency to
give us informal information as it becomes available so that we can distribute
it. I don't see a problem so much with the mechanism. But, there will have
to be a cooperative spirit on the part of each 208 agency to volunteer inform-
ation as it becomes available.
Condon: Sometimes when you try to disseminate information fast you may put out
incorrect information, because it cften hasn't been verified. Once it gets in
the literature, it's gospel and anything you try to do later to change it seems
to make matters worse.
Comment (John Kingscott): There would have to be some kind of dialog established
between 208 people and EPA people through face-to-face contact for such a program
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to work. Otherwise, use of the information may be dangerous. It would have
to be worked over.
Comment (Paul Ferraro, EPA Region VIII): My question is how much data we need
in order to make decisions. We seem to be skirting around the issue here. As
the 208 Coordinator for Region VIII, I am interested in knowing what we need.
We all mention the constraints that we have. There are dollar and time con-
straints. How do we get around this to set up a system that will answer the
needs? I can cite an example of what we did in one case in Region VIII. We
have three lakes where we plan to install a system to handle point-sources.
We suspect there is also a non-point source problem. It doesn't relate to
urban runoff directly, but it was from an urbanized area. We made an intensive,
two-week survey during the runoff periods. We surveyed about once a week during
the summer and then came back during the low flow in the autumn. So with a
few weeks of data gathering, we were able to assess that we did have a serious
non-point problem and that a solution to the point-source problem was not going
to buy us much without looking at the non-point source problem. I wonder if
there are other examples.
Condon: Solutions to such problems are site-specific. I'll give you an example.
NOAH said (that's the National Air and Space agency—whatever they are called)
that, with 90% confidence, a given area will experience in 2.8 years 857o of the
kind of rain and snowfall events that it will ever experience. So, we always
said that we need three years of data collection but we would go for two.
That's part of the answer to the question of how much data collection is needed.
The other part of the answer is that you don't have to sample and collect data
on every storm event. ' It is random, but you can do a statistical analysis
where you can pick out data for the four seasons. The seasonal variance is
the big problem for most of the country. From past records you can try to get
data on the variability of the hydrology of your receiving water. You can
1-35
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build yourself a little statistical analysis that tells you how many storms to
sample and how many sampling rur.s to make. But, I can't give you a flat answer
—because we are dealing with the whole country, having different rainfall-
runoff relationships, different kinds of receiving waters, and different key
pollutants. I don't know if anyone can provide an answer to this for the entire
country—unless they put out a huge publication. It depends upon the depth of
analysis that you wish to make. As someone said this morning, it is an "endless
well". You could sample forever!
Comment (Rod Stroope, Seattle Metro): I am concerned about our discussion of
data collection because it was centered on trying to identify the problem. I
would like to point out the point of view in our area concerning the 1983 goals
and the subjective elements that are input toward these goals. The problem is
something that is not, necessarily, easily quantified in terms of collected
data. Identifying the particular pollutants and their sources isn't going to
be too difficult. Where I think we will have the most difficulty is in form-
ulating solutions, especially non-structural solutions We will have
difficulty in getting politicians to stand behind our solutions unless we can
show the benefits that can occur. That's where I think we will get into a
real bind. So, there is a dichotomy between collecting a lot of data in the
beginning and, alternatively, merely trying to identify the real problems and
anticipate where it will be necessary to sample data from several areas where
you might be able to correlate the solutions—say, between non-urbanized areas
and urbanized areas.
Condon: There are a couple of dichotomies there. I wasn't arguing with Paul
(Ferraro). I was trying to support him by showing that there is a wide diver-
sity of things. The one dichotomy that you brought up was that you have to
tell the decision makers precisely what the effects are of these regulations
that may be adopted for regulating the release rates of stormwater from a given
1-36
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parcel of property. You can do that only with some long-term sampling along-
side of control areas. That kind of data would certainly require a long time
for collection.
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LAND USE AND URBAN DEVELOPMENT AFFECTING
STORWATER POLLUTION AND WATER QUALITY
by
Herbert G. Poertner
Engineering and Research Consultant
Bolingbrook, Illinois
WATER QUALITY STUDIES
The principal objective in water quality studies is to relate the in-
stream water quality and pollutant concentrations to pollutant discharges from
both point and non-point sources, at selected points along a stream, and estimate
the impact of the discharges on water quality. To accomplish this, one alter-
native is to make programmed, physical and chemical measurements of in-stream
water quality and mass pollution emissions of discharges at selected sampling
stations. Concurrent measurements of stream flow and stage would also be taken.
Without the benefit of other correlated information that can be used for predic-
ting changes in water quality as a function of variable parameters that affect
water quality, the measurements would need to be taken at scheduled intervals in
a continuous program. Obviously, this would be prohibitively expensive and im-
practical when viewed with a nationwide perspective.
A more practical solution is to broaden such a study program in an
attempt to develop correlations for each tributary watershed, between measured
in-stream water quality and pollutant discharges with other measured data, such
as: rainfall intensities and patterns, meteorological conditions, time lapse since
last measurable precipitation, deg:ree and extent of imperviousness, hydrologic
and hydraulic characteristics, rainfall-runoff relationships, street sweeping and
other public works activity, and land use. The measurements and other data
collection would need to be continued over a sufficiently long time span to
1-38
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permit verification of the relationships developed between the correlated study
data and the field measurements of pollutant discharges and the quality of re-
ceiving waters. Coeffecients of variation and confidence levels could then be
determined and methods could be developed for making estimates of water quality
for specified values of the manipulatable parameters selected.
After the field studies and analyses, last described, progress to a
satisfactory point, it should be possible to make reasonably valid estimates of
in-stream water quality by predictive methods through the use of mathematical
modeling. Although the state-of-the-art of modeling water quality and hydrology
makes its use practical, the lack of sufficient and reliable field data leaves
much work to be done to make its "application" to urban areas for water quality
prediction a useful and reliable tool. However, when this is accomplished, a
powerful tool will be available to predict in-stream water quality and to project
the "effects" of changing land use, public works practices, urban growth, changes
in the urban environment, and other parameters.
POLLUTANT LOADINGS
The study of the relationships between in-stream water quality and pol-
lutant discharges, is facilitated by developing graphs of mass emissions of pol-
lutants entering the stream from both point and non-point sources, as a function
of time. The vertical scale is usually expressed in pounds of pollutant per day,
or equivalent units and the horizontal scale is time in hours or other time units,
The development of these graphs (usually termed "mass emission pollutographs")
may be accomplished using data from field measurements of many real-world events.
It is also possible to develoD pollutographs by modeling and to determine their
sensitivity to changes in various natural and urban parameters; however, this
approach is practical only in those few places where sufficient, good field data
1-39
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is available for developing and testing computer programs and verifying results
of predictions.
A pollutograph is developed from field data by multiplying the pollu-
tant concentration at a given time and observation point by the value of the
flow past the point at that same time. This product is the time-rate at which
the specific pollutant under study is being discharged past the sampling-gaging
station. When multiplied by an appropriate conversion factor, it is the "pol-
lutant loading" in the discharge stream—at the moment when the flow was gaged
and the sample taken. By plotting "pollutant loading versus time of observation",
a curve can be developed to represent variation in the pollutant loading with
time. This curve is the graphics 1 representation previously referred to as a
"mass emission pollutograph".
The dotted curves in Figure 1 are examples of mass emission polluto-
graphs developed from field data taken in a storm sewer serving a small urban
watershed. These curves show the time variations in pollutant loading—the
upper graph representing biochemical oxygen demand (BOD), and the center graph
representing suspended solids. The pollutant loading are expressed in pounds of
pollutant per day.
A hydrograph showing the variation of flow with time for the study
point is given by the solid curve at the bottom of the figure. Pollutant concen-
trations for BOD and suspended solids are also shown as solid lines. Inspection
of these curves reveals that the peak flow rate was quite low; but, because of
the fairly high concentrations of both BOD and suspended solids associated with
this flow rate, the pollutant loadings were relatively high. During the initial
period of runoff, pollutant, concentrations and runoff were increasing at rapid
rates until a peak was reached after about 15 minutes. This gives evidence of
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Time (hrs)
FIGURE 1. Variation in Flow, BOD, and Suspended Solids During
the Storm of Oct. 27, 1972 at the Urban Sampling
Station.
Source: Stormwater Runoff Quality for Urban and Semi-urban/
Rural Watersheds, by F. T. R. Me Elroy III and J.
M. Bell, February 1974, Purdue University Water Re-
sources Research Center
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1-41
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the ocurrence of the often discussed "first flush" of pollutants from a watershed.
As the runoff event progressed, the flow rate diminished rather uniformly, al-
though there were some dips and rises in the concentrations and in suspended
solids loadings.
For either of the curves in the foregoing illustration of mass emission
pollutographs, the total pollutant discharged during the runoff event can be ob-
tained by summing the incremental pollutant contributions over the entire runoff
event. This is done by computing the area beneath the curve from time zero to
the cut-off time. The values woald be expressed in pounds of BOD for each of
the upper set of curves--and, similarly, pounds of suspended solids for each of
the lower curves. Although the :otal mass of pollutants can be determined as
stated above, of much more significance in water quality studies is the mass "of
pollutants discharged during periods of peak pollutant loading.
In summary, the pollutant loading of a given discharge can be thought of
as being the arithmetic product of the "pollutant concentration" at a specified
time and the discharge flow rate at that time. The basic problem of determining
pollutant loadings from field data is one of sampling and gaging the discharges
at selected time intervals to determine concurrent values for pollutant concen-
tration and flow rate.
The evaluation and study of the "loadings" of various pollutants in
stormwater flows gives one a grasp on understanding water quality characteristics
and the significance of stormwater contributions. It should be kept in mind, in
light of the foregoing discussion, that the in-stream impacts of stormwater run-
off is a function of both the quantity of flow and the pollutant concentration.
In a given runoff event, either one of these variables, or both, may be the
major cause of a quality problem in the receiving waters.
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URBAN WATERSHED vs. SEMI-URBAN/RURAL WATERSHED
In 1972, Me Elroy and Bell of the Purdue University Department Environ-
mental Engineering conducted a field study of stormwater runoff from a small
urban watershed and a larger semi-urban/rural watershed, located nearby. In addi-
tion to studying sampling procedures, the objectives were to characterize and
quantify the pollution in stormwater runoff, compare the runoff from the two
watersheds, examine effects of first flushing, and measure the effects of vary-
ing sampling frequency on the mass emission pollutographs.
The purposes of including a summary of the conduct and results of this
study in this paper are (l) to illustrate the field procedures that can be used
to characterize stormwater pollution, (2) to show some examples of pollutant
loading as a function of time, (3) to compare the pollutant loadings of the storm-
water runoff from the two watersheds to illustrate the effects of different land
uses; and (4) to illustrate how pollutant concentration and runoff flow rates in-
fluence the magnitude of pollutant loadings.
At the urban watershed, flow gaging and sampling of runoff discharges
were conducted at a gaging-sampling station located in a concrete pit receiving
runoff from a storm sewer serving the 29-acre watershed. The watershed is a
fully-developed residential area having 387o impervious area and containing 72
single-family dwellings with a total population of 252 persons (8.7 persons/acre).
The semi-urban/rural watershed has an area of 29? acres. It includes partially-
developed residential land and farm land--178 acres and 114 acres, respectively.
The watershed Is located about 4 miles from the urban watershed. The population
of 1,000 persons results in an average population density of 3.4 persons per acre.
The gaging-sampling station consists of two Parshall flumes in a drainage ditch
and an instrument shelter located underground, nearby. For analyses of the
1-43
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quality of runoff, semi-continuous composite samples of 1000 ml volume were
taken at half-hour intervals at both sampling stations during 4 rainstorms.
The researchers identified BOD and suspended solids along with total
coliforms as the parameters most used for determining the quality of stormwater
runoff. The dotted curve at the top of Figure 2 shows the BOD mass emission
pollutographs for the semi-urban/rural watershed for a rainstorm of November 13,
1972. The units are pounds-per-day plotted against time from start of runoff.
The suspended solids mass emission pollutograph is shown as a dotted line in the
center of the figure. Similarly, the dotted curves in Figure 3 are the polluto-
graphs for BOD and suspended solids for the urban watershed during the same rain-
storm. "Concentrations", both for BOD and suspended solids are shown as solid
lines. Inspection of the curves reveal consistently higher values for the pol-
lutant concentrations at the urban site.
An analysis of the pollutographs for the semi-urban/rural site was made
followed by a comparison of quality of runoff from the two test watersheds. In
order to compare the two watersheds, it was necessary to derive a useful factor
which could reduce the pollutant values to a common scale. This was done by con-
sidering the effect of size of the watershed and rate of runoff on the peak
pounds per day of pollutants produced. The use of the units of pounds of pol-
lutants per day per acre reduces the pollutants to an equal basis with regard to
size of the watershed.. By next considering the effect of flow on the poundage
or by dividing the pounds per acre per day by MGD one has, in effect, reduced
the values to concentration of pollutants generated by storm flow per acre of
watershed. The data shows that the concentration of pollutants resulting from
the runoff from one acre of urban watershed is much greater than that from the
semi-urban/rural watershed. The-ranges of the peak concentrations are shown in
Table 1. Both minimum and maximum peak values are much higher for the urban
1-44
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watershed as compared to those determined for the semi-urban/rural watershed
for all parameters studied--BOD, SS, Total Coliforms and Fecal Coliforms.
TABLE 1. COMPARISONS OF PEAK POLLUTANT CONCENTRATIONS
IN STORMWATER RUNOFF FROM AN URBAN
WATERSHED AND A SEMI-URBAN/RURAL WATERSHED
Parameter Measured
BOD (mg/1)
Suspended Solids (mg/1)
Total Coliform Counts
(organ isms /ml)
Fecal Coliform (organisms /ml)
Range of, Peak Pollutant Concentrations
Semi-urban/Rural Watershed
3 to 7
6 to 170
930 to 46,000
930 to 9,300
Urban Watershed
11 to 44
62 to 250
930 to 240,000
430 to 93,000
Source: Derived from data published in Stormwater Runoff Quality for Urban and
Semi-urban/Rural Watersheds, by F. T. R. Me Elroy III and J. M. Bell, February
1974, Purdue University Water Resources Center, West Lafayette, Indiana
A "first flush" of suspended solids and BOD was exhibited at the urban
sampling station; however, no first flush of BOD was apparent at the semi-urban/
rural station and only a very small first flush of suspended solids was observed.
The authors also pointed out that although "first flush" was evident, several sub-
sequent flushes of suspended solids occurred after the initial flush when the flow
increased dramatically. However, upon reaching maximum flow, solids concentration
decreased and remained constant regardless of the flow pattern. This implies
that minimum flow is required to completely flush the solids from the basin. The
magnitude of this flow is dependent on the characteristics of the watershed and
other parameters such as intensity of rainfall, duration of rainfall, antecedent
dry period, etc.
1-45
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Another conclusion from the study was that the mass emission pollutographs
of BOD and suspended solids were affected by both concentration and flow. The
concentration affected the shape of the pollutograph while the flow affected
both the shape and magnitude of the pollutograph. The flow hydrograph had a much
more dramatic effect on the shape and magnitude of the pollutograph than did
concentration.
Inspection of the hydrographs and the pollutographs in Figure 2 and
Figure 3, reveals that the mass emission of pollutants is greater for the greater
runoff rates. For smaller runoff rates the flows pick up less pollutants and
the mass emission of pollutants into the receiving waters is less. Under the
latter circumstances, there is less impact on "assimilative capacity" of the
receiving waters.
SOURCES of URBAN STORMJATER POLLUTANTS
The many point sources and non-point sources contributing to the pollu-
tion of urban stormwater runoff are difficult to list and classify in a compre-
hensive manner. Also, new sources emerge as the wheels of progress turn. Some
of the more readily and significant sources are listed below:
demolition and construction operations
land grading and excavation
products of erosion from wind and water
material stockpiles
salt application to streets, roads and other paved areas for snow and
ice control
debris from littering and vehicle movements (droppings from trucks, rubber
and asbestos from vehicles, etc.)
particulates from stacks of heating equipment and industry
fertilizer, pesticide and o':her chemical applications
leaves, grass clippings and trimmings from other vegetation
petroleum spillage and leakage
disposal of waste materials in storm sewers (oil, cleaning liquids,
chemicals, animal wastes, etc.)
dumping of refuse in streets and roadside ditches
innundation of wastewater treatment facilities by flood waters
sewer catch basins
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P
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P.
01
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200
160
.too
.600
-*00
13000
10000
5000
rt
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03
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to
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Time (hrs)
FIGURE 2. Variation in Flow, BOD, and Suspended Solids for
the Storm of Nov. 13, 1972 at the Semi-Urban/
Rural Sampling Station.
Source. Stormwater Runoff Quality for Urban and Semi-
urban/Rural Watersheds, by F. T. R. Me Elroy III
and J. M. Bell, February 1974, Purdue University
Water Resources Research Center
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overflows and backups of sanitary sewers
overflows of stagnant ponds and waste disposal lagoons
sewer discharges of washwaters from scrubbers of air pollution control equip.
leachates from sanitary landfills
surface discharges from septic tank leaching fields
cross connections from sanitary sewers, either accidental or illicit
Some of the above sources may also act to pollute groundwater and water
supplies in natural aquifers, wells and reservoirs. Among other potential sources
of underground water pollution are activities of public agencies and private or-
ganizations designed to solve specific oroblems: e.g., land application methods
for wastewater treatment, stormwater injection, disposal of irrigation return
water having high mineral content, brine disposal, etc.
Pollutants in sediments produced by runoff may cause the largest single
impact from urban stormwater runoff on water quality. The amount, or "yield1^ of
sediment varies with land use and site characteristics. It may originate from
runoff flows over rural land, farmland or urbanized areas. High yields of sedi-
ment are produced in connection with land grading, excavation and demolition,
and construction activities. The pollutional constituents in sediment generally
can be classified as non-organic solids, organic materials, trace metals, soil
salts, and chemicals of various types including fertilizers, pesticides and
others.
Sites that have been denuded are often allowed to remain idle pending
land development and this produces erosion and sediment yields. Runoff from
streets, parking lots and other paved surfaces in urban areas is another major
source of sediment yield and pollutants in receiving waters.
Much of the material transported by runoff does not become sediment in
but remains in suspension in the initial receiving waters. These "suspended
solids" constitute another major impact on the water quality of receiving waters.
1-49
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Substances that become dissolved in stormwater also cause an impact on water
quality as they are assimilated and dilluted by the receiving waters.
RELATIVE EFFECTS OF STREETS AND THEIR USE
This section highlights sone of the findings of various studies concerning
the degree to which urban right-of-ways for automotive transportation contribute
to the pollution of stormwater. Some of this information was obtained from a
(2)
paper given by Martin J. Manning in 1975 at the University of Florida.
Streets, alleys and roads constitute one of the major contributors to
stormwater pollution in urban areas. The deposition on these surfaces of con-
taminants from the operation of vehicles, the accumulation of litter and trash,
eroded materials from streets surfaces and nearby paved and unpaved areas,
settling of air borne particulates, application of salts for snow and ice con-
trol, and other activities, combine to make "street accumulations" a contributor
to 507o or more of the pollutant loadings in some urban stormwater runoff. Re-
searchers have found that for high runoff rates over streets, the pollutant
"mass emissions" are about what would be expected based upon measured street
accumulations. But for low runoff rates over streets and paved surfaces,
measurements have shown less pollutant mass emissions than what is usually ex-
pected from theoretical analyses. The reason for this "attenuation", apparently,
is not fully explainable.
Snow and ice readily "accumulate" significant amounts of the pollutants
generated in urban areas. A 1973 report of a Canadian study conducted for
the National Capitol Area reported significant concentrations of various pol-
lutants in samples of snow taken Ln the urban area of Ottawa-Carleton. Also,
the need for and practice of controlling ice and snow in urban areas adds another
1-50
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dimension to the pollutant sources—namely, "purposeful" application of a pol-
lutant to street and road surfaces. Sodium chloride (common salt) is the most-
widely used chemical for ice and snow control, except at airports where less
corrosive materials are used. Salt application rates up to 700 pounds per lane-
mile of road were reported in Toronto. Results of the study included an es-
timate that approximately 84% of the deicing salts used in the Ottawa-Carleton
area ran off as brine after application. Between 6 to 107o of the salt found
its way into receiving waters by runoff from melting of snow and ice that had
been piled-up or hauled away during mechanized snow and ice removal operations.
The type of pavement surface is a factor that contributes to the "litter
accumulations" on streets because of "surface-wear" and effects of weather. It
has been reported that about 25% of the total litter accumulation on street
pavements may be derived from the pavement materials. Also,total accumulations
of litter, dust and dirt have been found to be much heavier on asphalt streets
than on concrete streets.
CONCLUSIONS
Unfortunately, the majority of existing stormwater runoff quality inform-
ation reported is given as "mean" pollutant concentration or "averages" of samples
taken from one or more runoff events. These values are usually given without
regard to their relationships to rainfall, runoff and time variations of other
parameters. This diminishes the usefulness of the field data.
However, on the basis of data of this type, "average" urban stormwater
runoff quality may be characterized as having solids concentrations equal to
or greater than raw sewage, BOD concentrations approximately equal to that of
effluents from secondary sewage treatment, and bacterial contamination from 2
to 4 orders of magnitude less than untreated sewage.
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The state-of-the-art in assessment of pollution of stormwater runoff as
a function of land use and urban development is in a preliminary state of develop-
ment. Because of this and the lack of conclusive findings by researchers, it
seems inappropriate to review here the findings of various studies as they re-
late to the relative effects of different land uses. However, several field
studies in which the effects of land use were investigated are included in the
list of references.
REFERENCES
1. Stormwater Runoff Quality for Urban_and Semi-Urban/Rural Watersheds, by
Felix T. McElroy III and John M. Bell, Purdue University Water Resources Research
Center, West Lafayette, Indiana, February 1974, 156 p
2. Urban Stormwater Pollutant Loadings, M. J. Manning, Second Annual National
Conference on Environmental Engineering Research, Development and Design,
University of Florida, Gainesville, July 20-23, 1975, 18 p
3. Snow Disposal Study for the National Capitol Area, by J. L. Richards &
Associates Limited and Labrecque, Vezina & Associates, Ottawa, Ontario,'Canada,
June 1973, 143 p
OTHER PERTINENT PUBLICATIONS
4. Contributions of Urban Roadway Usage to Water Pollution, by Donald G. Shaheen,
Biospherics, Inc., for the U.S. Environmental Protection Agency, EPA-600/2-75-004,
March 1975, 346 p
5. Urban Stormwater Management and Technology, An Assessment, by John A. Lager
and William G. Smith, Metcalf & Eddy, Inc., Palo Alto, California, for the U.S.
Environmental Protection Agency, EPA-670/2-74-040, December 1974, 447 p
6. Characterization and Treatment of Urban Land Runoff, by Newton V. Colston,Jr.,
North Carolina State University, Dept. of Civil Engineering, Raleigh, for the
U.S. Environmental Protection Agency, EPA-670/2-74-096, December 1974, 117 p
7. Water Quality Management Planning for Urban Runoff, URS Research Company,
San Mateo, California, for the U.S. Environmental Protection Agency, Contract
68-01-1846, December 1974.
8. A Study of the National Scope of Urban Pesticide Runoff, by CONSAD Research
Corporation, Pittsburgh, PA, for the U.S. Environmental Protection Agency,
Contract 68-01-2225, 1975
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9. Toxic Material Analysis of Street Surface Contaminants, by Robert E. Pitt
and Gary Amy, USR Research Company, for the U.S. Environmental Protection Agency,
EPA-R2-73-283, August 1973, 119 p
10. Pollution Attributable to Surface Runoff and Overflows from Combined
Sewerage Systems, by D. H. Waller, Atlantic Industrial Research Institute, for
Central Mortgage and Housing Corporation, Ottawa, Ontario, Canada, April 1971,
160 p
11. A Milti-Phasic Component Study to Predict Storm Water Pollution from Urban
Areas, by AVCO Economic Systems Corporation, for the Office of Water Resources
Research, U.S. Dept. of the Interior, Contract 14-31-0001-3164, December 1970,
187 p
12. Storm Water Pollution from Urban Land Activity, by AVCO Economic Systems
Corporation, for the Federal Water Quality Administration, Contract 14-12-187,
July 1970, 163 p
13. Water Pollution Aspects of Urban Runoff, by the American Public Works
Association, for the Federal Water Pollution Control Administration, Contract
WA 66-23, January 1969, 272 p
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INSTREAM IMPACTS OF
URBAN RUNOFF
E. D. Driscoll - Hydroscience
MAJOR WATER QUALITY PROBLEMS IN URBAN AREAS
The nature of water quality problems associated with the receiving waters
in and around metropolitan areas is quite varied. Although a list of com-
mon potential problems can be drawn up readily, local factors have a
predominant influence in determining both the class of problem, its
severity, and the specific source or sources which are most critical. The
local factors which affect water quality include climate, geography, popula-
tion, population concentration, the nature and degree of industrialization
in the area, the receiving water system, its nature, size and hydrology; and
the nature of the surrounding area - both upstream and downstream of the
urban area itself.
Water quality problems, either real or potential, will be generated by
waste loads which enter the receiving water from the area in question.
There are a number of different types of sources which contribute waste
loads, and these are generally classified as either point sources or
non-point (distributed) waste loads. They include discharges of domestic
sewage, either treated or untreated, industrial waste discharges, storm
runoff from urban, agricultural, or undeveloped land areas, surface
returns from irrigated agriculture, and sub-surface seepage of either
groundwater or percolating agricultural irrigation water. Classification
of these sources into point or distributed sources is somewhat ambiguous
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in certain cases. Storm runoff, for example, is essentially a non-point
source in that it is generated by precipitation falling over a wide area.
It would be considered viewed from the perspective of its impact on water
quality in the receiving water which ultimately receives its runoff, it
can be evaluated either as a distributed source (as in upstream areas), or
as a point source. An example of the latter would be an urban area where
surface runoff from storms are collected and finally enter the stream at
a single point which can be readily intercepted or treated. It is important
in developing an approach to the solution of water quality problems, that
classifications (point vs. non-point), while useful in general discussions,
should not be adopted blindly, but should be adapted to fit the simplest
and most effective approach.
Each of the individual sources has distinctive general characteristics.
The type of pollutant or pollutants which predominate can differ radically
between sources, as can the absolute quantity contributed. Further, the
type of control which may be applied, such as partial containment or treat-
ment will ustially modify both the total quantity of pollutant in the source,
and the predominant type present. The method of analyzing the effect of
all sources on water quality, and the impact of alternative control measures
must be able to handle these variations effectively.
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Types of water quality problems which can result from waste loadings
which exceed the capability of the receiving water to assimilate include
the following (See Tables I and II).
- Aesthetic deterioration - Either general appearance (dirty,
turbid, cloudy) or the actual presence of specific, objection-
able conditions (odors, floating debris, oil films, scum or
slimes, etc.) may make the receiving water unattractive or
repugnant to those in its proximity.
Dissolved Oxygen Depletion - Organic materials stimulate the
growth of bacteria which may consume oxygen faster than natural
processes can replenish. This condition may or may not be
visually apparent. In the extreme, discoloration, gas formation
and odors may be apparent - however well before this extreme is
reached, conditions suitable for a balanced aquatic population
of fish and lower species in the food chain may be violated.
The presence of unoxidized nitrogen compounds (e.g. ammonia)
is in some cases a significant element in water quality problems
related to low dissolved oxygen levels.
Bacteria/Virus Concentrations - The presence of excessive
concentrations of objectionable microorganisms can impair the
ability to utilize the receiving water for certain water supply
and recreational purposes.
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TABLE I
CLASSES OF INSTREAM IMPACTS
AESTHETIC
DISSOLVED OXYGEN DEPLETION
SEDIMENTS AND DEPOSITS
EXCESSIVE AQUATIC GROWTH
PUBLIC HEALTH THREATS
IMPAIRED RECREATION VALUE
ECOLOGICAL DAMAGE
REDUCED COMMERCIAL VALUE
TABLE II
CONTAMINANTS IN URBAN RUNOFF
FLOATABLES AND VISUAL CONTAMINANTS
DEGRADABLE ORGANICS
SUSPENDED SOLIDS
NUTRIENTS
BACTERIA, VIRUS
TOXIC MATERIALS
DISSOLVED SOLIDS
1-57
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Suspended Solids - Particulate matter may contribute to a variety
of problems, such as objectionable aesthetic consideration,
formation of sediment deposits which smother bottom dwelling
aquatic organisms, impeded navigation or restrict river flows
contributing to flooding potential.
Nutrients - The discharge of materials which fertilize or
stimulate excessive or undesirable forms of aquatic growth can
create significant problems in some receiving water systems.
Overstimulation of aquatic weeds or algae (eutrophication) can
be aesthetically objectionable, cause dissolved oxygen problems,
and in extreme cases can interfere with recreational use of
impededing small boat navigation, creating odors, and heavy mats
of floating material at shorelines.
Dissolved Solids - A number of beneficial uses can be impaired
by excessive concentrations of dissolved solids. Both domestic
and industrial water uses are sensitive to dissolved solids
concentrations. Irrigated agricultural is quite sensitive to
the salt content of the applied water. On a practical day to
day basis, farmers must compensate for high salinity in irrigation
water by increased quantities of irrigation water. This imposes
additional demands on water development and conveyance programs,
and further contributes to drainage problems. Effective
agriculture can be destroyed if irrigation rates required to
compensate for high salinity exceed the percolation and drainage
capacity of the soil.
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Toxicity - Toxicity problems can fall into either of two cate-
gories: Metals/Pesticides/Persistent Organics - may exhibit a
subtle, long term effect on the environment in areas well removed
from the area under consideration, by the discharge of small
quantities which gradually accumulate in sensitive areas.
Ammonia, and byproducts of effluent chlorination, under some
conditions can exhibit a local, more immediate impact.
•
It will be useful to examine very briefly some examples of water quality
problems associated with metropolitan areas which we have analyzed. They
are presented to illustrate the wide variety of situations which are en-
countered, and to indicate that no single solution or solution approach
is at all appropriate.
Boston Harbor - One of the more important water quality problems
in this area was closure of beaches at rather frequent intervals
because of excessive coliform counts. Although many sources of
wastes entered the system, it was predominantly combined sewer
overflows which.created the objectionable condition. Other
constituents in the storm runoff were not particularly signifi-
cant. Analysis in this case focused specifically on coliform
bacteria contributed by storm runoff. In the evaluation of
alternative actions which included both reduction in amount
and location of discharge points, the evaluation was made not
on the amount of coliform discharged - but on the basis of the
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effect of each alterrative considered on the number of days in
which objectionable counts would occur. Management decisions
were made by comparing the cost of each alternative to the
number of days beaches would require closing under that
alternative.
Potomac River at Washington, D.C. - In this case, both municipal
and industrial discharges and urban storm overflows were important,
Significant pollutants were bacteria and virus, IDS, and algal
resulting from nutrient discharges. Growth projections for the
area projected critical water supply limitations in dry years.
Alternative approaches included additional reservoir construction
upstream arid withdrawal of supplementary water supply from
the upper reaches of ;he estuary. Because of tidal conditions
and low fresh water outflow under conditions, flow reversals
would occur with the result that downstream sewage discharges
and ocean salts would,, though diluted, be drawn back toward the
water intake. Analyses in this case was directed toward pro-
jections of the effect: of various alternatives on the quality of
water as appropriate for processing by water supply and treat-
ment facilities for Washington, D.C. Total dissolved solids,
coliform, virus, and filter-clogging or taste and odor producing
algae were the important elements, as they would occur at the
point of water intake.
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Milwaukee, Wisconsin - This project evaluated the effect of
retention basins in controlling storm overflow pollution loads,
and evaluating their impact on quality in the Milwaukee River.
In this case dissolved oxygen and suspended solids were the
critical parameters, and were influenced almost totally by
storm runoff - both from the intermediate urban area, and from
upstream agricultural and suburban areas. Suspended solids
caused objectionable deposits in the channel. Low dissolved
oxygen levels were found to be due to direct organic discharges
(BOD), the gross accumulations of putrescible sediments, and
the diurnal variations in dissolved oxygen caused by nutrient
stimulated algae growths in upstream areas.
PROBLEM DEFINITION
The foregoing illustrates several things. First, stormwater overflows
can cause significant waste loads on receiving waters. Further the
relative contribution of storm loads to total receiving water loads from
urban areas increases dramatically as municipal treatment facilities
achieve higher levels of removal efficiency. Figure 1 illustrates this
factor schematically.
Secondly, at some point we must stop speaking of "the" stormwater problem
and focus on which of the possible problems we are concerned with. Each
particular problem is caused by a different set of contaminants.
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ANNUAL BASIS
COMB NED SEWER AREA
STORM
OVERFLOWS — ,
V
/
/
//•"ixr'v ~^^f
IUU /o ^
ANNUAL RAW
SEWAGE
BOD LOAD
_ 5%
' * /° ^" % OF STREAM
LOAD DUE
TO STORM
. OVERFLOWS.
a co/ ^ 1 ' inn0/
— jO /o — ^^ | IUU /o
\ NONE RAW LOAD
I I *" TO STREAM
PRIMARY
—100%
33%
95%-
SECONDARY
15%
ADVANCED
FIGURE I
RELATION OF STORM TO TREATMENT
WASTE LOADS TO STREAMS
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Different contaminants respond differently to control measures. An
effective control program must concentrate on doing an appropriate job
on the contaminants which are causing the problem - and not on those which
have a negligible or insignificant effect. Therefore, an effective control
program requires an accurate definition of the problem.
This isn't always easy to do, but it is important. For reasons which will
become increasingly apparent during this seminar, it is impractical, if
not physically and economically impossible, to control ALL stormwater
overflows. We can't - as we do with municipal or industrial wastewaters -
assign a minimum level of treatment to 100% of the waste load. We must be
selective; we must be smart, to get the maximum "bang for our buck." It
is entirely possible, because of the variable nature of the process genera-
ting these loads, that a control system arbitrarily selected might provide
a less real benefit to receiving water quality, than an equal or even a
less costly alternative. As an example, consider the hypothetical case
illustrated by Figure 2. System A might be a retention tank; and System B,
a smaller retention tank with filtration system, with greater removal
efficiency at lower treatment rates. A treatment system on a storm overflow
will experience a wide range of waste flows, and these flows may have a
frequency distribution approximately as shown. Thus, alternate A, designed
for a lower optimum rate than B, could in effect result in a greater degree
of benefit to receiving water quality.
1-63
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_J
UJ
tr
u
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CJ
LL
LJ
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tr
i-
ASSUME SIZE A AND B SUCH
THAT COST IS EQUAL
WASTE FLOW
©
FREQUENCY DISTRIBUTION OF STORM
OVERFLOWS AT TREATMENT POINT
10
50
95
% OF OBSERVED FLOWS
LESS THAN VALUE
FIGURE 2
RELATIVE PERFORMANCE OF TREATMENT
DEVICES FOR VARIOUS STORMWATER OVERFLOWS
1-64
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How does one define a storm water problem. I submit that it should be
defined - not in terms of how many pounds of contaminant X are discharged
into the receiving water - but rather in terms of what changes in
receiving water quality result from these loads, and how these changes
(a) affect quality measures in relation to stream standards, and (b) how
they impact beneficial uses. We should measure cost effectiveness not
in terms of pounds removed - but in terms of preservation of beneficial
uses.
Since the variability of the storm process makes it unlikely that any
practical level of control will permit a receiving water duality objective
to NEVER be violated, we must begin to think of assessing alternatives in
terms of their influence on how frequently objectives will be violated.
If then, we should define a storm water problem in terms of its effect
on the receiving water, what are the complexities involved in making such
a determination. There are a number, and they relate to the basic nature
of the problem, which might be summarized thus:
Waste loads are flushed into receiving waters because of storms.
The loads are transient; impacts are transient but may exert
cumulative effects; i.e. effects may persist until the next
transient load hits.
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The source of these loads (rainfall) is an extremely variable
phenomenon. Predictability is possible only by invoking the
concept of probability.
It is difficult to measure the load in the sense that one
would on a municipal sewage to design a treatment plant -
because one, or a dozen or a hundred measurements won't tell
(by themselves) what the "design waste load" should be.
There is no way to tell - a priori - whether the critical
receiving water condition results from the biggest 5 or 10
or 50 year storm, or from some sequence of run-of-the mill
storms which occur every year or so.
SOLUTION APPROACHES
The complexities of the problem have been emphasized, not to suggest
that it is a hopeless task, but rather to caution against naive or
simplistic solutions. It may also help to understand the reasons why
so many studies have been undertaken, largely under EPA sponsorship.
Extremely variable phenomena require a lot of data to understand.
We literally can't afford to apply arbitrarily high degrees of
control indiscriminately.
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Storm generated pollution loads can be substantial, and contribute
significantly to receiving water problems.
Effective approaches to the problems of storm water overflow, must there-
fore recognize the nature of the process generating the loads, and the
nature of receiving waters where impacts are felt. The former is a topic
covered by other discussions at this seminar. Let us now examine briefly
the nature of receiving water systems and responses.
RECEIVING WATER SYSTEMS
Instream Impacts for any waste loading condition, will be influenced by
the nature of the receiving water into which the load discharges. The
"nature" of the receiving water is determined by the following elements.
- CLASSIFICATION
- Fresh water streams and river
Tidal rivers and estuaries
Lakes and reservoirs
Harbors and oceans
- STRUCTURE
Dimensionality (1, 2, or 3 dimension)
Geomorphology (drainage area characteristics)
- Hydrology
Meterology
1-67
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- TRANSPORT PROCESSES
- Advection - Transport predominated by translation
Dispersion - transport predominated by mixing forces
- Mixed - Both advection and dispersion are significant
- REACTION OF CONSTITUENTS
- Conservative - e.g. TDS, Cl
- Non-Conservative (Reactive)
Rapid - (Hours - Days) - BOD, Bacteria
Slow - (Months - Years) - Toxic Materials
A generalized characterization of receiving water systems is possible in
a quantitative framework. E-uried in the differential equations which are
needed to adequately define system responses to loads, under transport
and reaction conditions which prevail, is a very useful relationship.
U2
N
Where: K is the reaction rate of a particular contaminant
e.g. BOD decay K = 0.2 per day
Coliform K = 2.5 per day
E is the longitudinal dispersion due to mixing forces,
which may include turbulence, velocity gradients, tidal
2
effects, etc. It is expressed in terms of miles /day
U is the advective flow, miles/day
1-68
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Thus, in a strongly advective stream with little longitudinal mixing,
N approaches 0 as a limit. In a strongly dispersive system where
advective effects are insignificant in defining transport, N approaches
infinity.
Experience permits us to bound this range more narrowly (see Figure 3),
For values of N of 0.1 or less, advection may be considered to be the
only significant transport element defining water quality responses to
waste loads. For values of N of 10 or more dispersion controls water
quality impacts. For intermediate values of N, i.e. on the order of 1,
both mixing and advection significantly influence quality responses
The point here is that receiving waters can be characterized quantita-
tively, as well as the obvious qualitative characterizations. Further the
characterization is of such nature that it will provide intelligence
concerning how a contaminant will react. This permits judgements to be
made concerning the load generation process (i.e. rainfall, runoff, treat-
ment effects, etc.). Finally, these judgements can significantly influence
our selection of the most effective approach to the problem - including
monitoring programs to define the loads or selection and evaluation of
control measures.
Before discussing the practical significance of these receiving water
characteristizations, it is useful and instructive to recognize that the
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• BAYS AND
ESTUARIES
TIDAL RIVERS
FRESH WATER STREAMS
AND RIVERS
2345
U.ADVECTIVE VELOCITY MILES/DAY
NOTE'
FOR K = 0 3
n -- —
FIGURE 3
ix p
EFFECT OF ADVECTION AND DISPERSION ON RATIO —„
U2
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various classes of instream impacts can be associated with characteristic
time and space scales. Figure 4 and 5 provide a generalized representa-
tion of the range of scales which storm overflows can influence. Together
with receiving water characteristics, recognition of these scales can
influence both the selection of appropriate methods for performing analyses,
and selection of control processes.
SIGNIFICANCE - Some Examples
From Time and Space Scales - LOADS (i.e. QxC) will probably never
need to be defined for intervals of less than one hour. This
interval may be required for some highly reactive contaminants
(BOD, coliform, bacteria)-
For other contaminants - hourly variations in load - or even
single storm averages may not be significant. Thus, TDS, or
Metals, or in many cases Nutrients - long term (months, seasons,
years) loadings are significant - not what happens in a single
storm, or a particular moment during that storm.
Important - because some analytical techniques are single event
oriented. They may require excessive effort to provide the amount
of information required in the appropriate time scale.
Even for reactive constituents, the level of temporal detail in
the distribution of loads entering the natural water, will be
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SECONDS
I04 I05
10°
10'
10°
10'
FLOATABLES
BACTERIA - VIRUS
DISSOLVED OXYGEN
SUSPENDED SOLIDS
NUTRIENTS
I
DISSOLVED SOLIDS
METALS
PERSISTENT
ORGANICS
I
HOUR
DAY
MONTH
YEAR
WEEK
SEASON
DECADE
FIGURE 4
TIME SCALES
STORM OVERFLOW WATER QUALITY PROBLEMS
1-72
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HYDRAULIC DESIGN
FLOATABLES
BACTERIA
SOLIDS
DISSOLVED OXYGEN
NUTRIENTS
METALS/ORGANICS
T. D.S
10 '
( 5 FT)
10 '
(50 FT)
10 '
( 500 FT )
10'
EFFECTIVE DISTANCE - MILES
10'
-LOCAL-
ICT
•REGION-
-BASiN-
FIGURE 5
SPACE SCALES
STORM OVERFLOW WATER QUALITY PROBLEMS
1-73
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influenced by the characteristics of the system. For example,
waste loads entering a highly mixed system (tidal estuary) will
be "averaged out" by the mixing forces in the receiving water -
to the extent that a very fine definition of load variation
(i.e. minutes or even hours) may be totally meaningless as far
as instream impacts are concerned.
This applies for advective and combination advective - dispersive
systems as well - though the degree of "averaging" waste loads
which is permissable will be increasingly restrictive as advection
forces predominate. However - even with a purely advective system,
there are practical limits to the level of detail which are
significant. Figure 6 is a hypothetical case, with loads arbitrarily
chosen, however a simiJ.ar examination could be made for a particular
condition. Note that averaging tends to over estimate slightly
the (average) dissolved oxygen deficit generated by the indicated
transient load. The averaging - on the other hand does not permit
identification of the peak deficit. The question which must be
asked now - is whether either beneficial use or stream standards
are to be considered sensitive to the minimum dissolved oxygen
which may occur during an interval as short as 1 hour (as per
this example), versus whether our concern should be with minimum
daily, weekly or monthly values.
1-74
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1-75
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CONCLUSIONS
There are a wide variety of potential classes instream impacts
from storm loads.
Magnitude and persistence of impacts is influenced by loads and
receiving water characteristics.
The nature of the problem and the nature of the receiving water
will strongly influence the control measures which are appropriate
and the most effective way of analyzing the system to make that
determination.
The planning effort should start in the receiving water - and
Identify the problem or problems to be addressed.
Establish the study approach - data collection, analytical
procedures, etc. which will provide the kinds of answers
required.
There is a level of analytical detail which is appropriate in any
situation. An effort should be made to identify it and use it.
Use of "excessive" levels of detail -
- a) Are wasteful of resources.
- b) May limit the completeness of the evaluation.
- c) Will not necessarily add to the accuracy or reliability
of the analysis.
d) May "imply" a greater level of accuracy than they really
provide.
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QUESTIONS AND ANSWERS
(Following Eugene Driscoll's paper "In-stream Impacts of Urban Runoff")
Question: How serious is the urban stormwater pollution problem nationwide?
Driscoll: I don't know.
Condon: You must define what you are studying whether it is combined sewer
overflows or straight stormwater discharges. For combined sewer overflows,
there are documented cases where the stream water quality is violated. Then,
we must define what constitutes a violation, whether it is a 5-day or 30-day
average, or a 24-hour interval. There is a lack of data on the impacts of
straight urban stormwater runoff.
Comment (Representative of U.S.G.S., Colorado District): We have now instru-
mented two basins in the Denver area where we are sampling direct urban storm-
water runoff. We are analyzing, chemically, the samples for major cation and
anion constitutients and trace metals; and we are making bacteriological examin-
ations. This data will be available, on an annual basis, in our surface water
supply papers. Based on our findings this past summer, the basic problem is
bacteriological. Dissolved solids are running about 300 mg/1. There are some
organic problems but, bacteriologically, we are finding coliforms in excess
of 100,000 counts.
Question (Representative of Mountainland 208 Area in Utah): The real problem
that we are having with regard to stormwater management is the "objectives".
Each group is charged with deciding, for itself, what the objectives really are.
We have receiving water standards that are somewhat defined, with only a few
parameters. This problem of setting the objectives, or the levels of specific
contaminants that will be tolerated, is a real problem area. Without some
additional coordination and direction—perhaps nationally or, at least, region-
ally--! see all sorts of different answers coming out of identical problems.
Perhaps you would like to comment on this.
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Driscoll: In trying to preserve water quality, somebody had to start somewhere.
So, they pulled out some standards. One of the roles of 208 studies can be
to identify what costs, alternatives and control measures might be associated
with achieving various levels of water quality, and then compare these with the
standards to see how realistic the preliminary standards really are.
Comment (Rod Stroope, Seattle Metro): As a further comment on this matter,
I feel that the unique nature of Section 208 enables us to look past the
standards and try to define our own local water uses and local desires for
water quality. That is why I think that overall national impacts of urban
drainage come down to, and must te viewed in terms of, unique local situations.
I agree that, in order to define a local water quality desire, a great deal of
commitment is required by the people who must pay the cost. You talked about
the need to define cost-effectiveness in terms of water quality enhancement
or incremental degrees of water quality improvement. In order to define that,
you first must put it in terms such that the person can pay for it. Also, be-
cause of the long term over which degradation occurs, or improvement occurs,
it is very hard to quantify.
Driscoll: That's right! I believe that what can be done in the planning
process is to identify the cause-and-effeet relationships on water quality in
a particular receiving water; i.e., relationships between the quality and the
various waste loads that result in that quality. .Depending on the source of
the load, the cost of modifying, controlling or reducing the contamination
will vary. It may be much easier to treat a certain contaminant, or source,
than another one. The role of the planning process, as I see it, is to clearly
identify the relative influences of each of the waste sources on quality and
how to estimate the extent to which quality will improve with different levels
of control. But a cost has to be associated with that. Then, you should make
comparisons with the standards to determine what is real and what is affordable,
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both on short-term and long-term. People don't want, and shouldn't be asked
to pay for some arbitrary level of quality which has no meaning or a low
priority when compared to other needs. The people that make the standards and
the people that, presumably, modify them really need this kind of information.
They didn't have any choices before. Did this answer your question?
Comment (Rod Stroope): No. I still agree with you, but we come down to that
classic problem of trying to prioritize water quality problems—not only within
the area of urban drainage, but for urban drainage compared with secondary
treatment or advanced treatment or other non-point problems.
Driscoll: Prioritizing the problem can have two aspects. One can be consider-
ations of public health and safety. But, in most cases, it is a political de-
cision--not a technical one. The technicians can define only the alternatives
--clearly and accurately--for introduction into the political process, so
that the public can decide what they can afford and what they want.
Question (Richard Holland, New Mexico): You keep stressing the importance of
the relative contribution. Have you been able to come up with that "reasonable"
data on which public officials can make their judgements? I am speaking, both,
of stormwater drainage as a contaminant vis-e-vis the other sources of con-
taminants—also the causes, within the category of stormwater drainage, of
the particular contaminants that prove to be a problem, in order to identify
what can be done. Have you been able to do this within the studies you have
done.
Driscoll: I think so. But there is a limit.
Question (Richard Holland): Can you give a few examples, in specific areas
you investigated, of the relative impacts of stormwater, versus other sources
--for any particular contaminant, or combination thereof?
Driscoll: We are doing a 208 study for the Salt Lake City area. We identified
the municipal point-source discharges and determined that they account for a
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relatively small percentage of the total dissolved oxygen problem that we
identified. We have not determined exactly what is contributing to the DO de-
ficiency—whether it is accumulated sediments, stormwater discharges, agricult-
ural returns or other factors. But, this is the sequential process that we
are following.
Athayde: I would like to respond to a question raised this morning by a gentle-
man from Utah. It dealt with the levels of quality that we could expect from
urban stormwater runoff. I think that you must first identify which pollutant
is making the stream water qualify limited. Next, you should find out how much
of an impact you can have on that particular pollutant. It may be of such mag-
nitude that the impact can't be very much. You must keep in mind that we are
stressing non-structural techniques and that there, probably, won't be any
funding for stormwater control. Paul Ferraro, who is with EPA Region VIII, said
that he also would like to respord to this question.
Comment (Paul Ferraro, EPA Region VIII, Denver): I understand Laverne's quest-
ion. It is quite broad and has to do with the whole water quality standards
problem. It does not relate only to urban runoff. We recognize this as a
significant problem in all of our 208 study areas. The Colorado Springs study
started over a year ago. They identified water quality standards and brought
this up as an issue. I have discussed the general approach that I like with
the 208 agency in Colorado Spring:? and the State staff. This approach is that
we utilize the criteria that is coming out in the blue book to set the standards
for 1983. Many present water quality standards will not meet the 1983 goals.
It is also necessary to keep in mind that the State is required, every three
years, to revise its water quality standards. I feel that the 208 agencies
can provide the necessary information so that the standards can be revised at
the required times. Our standards expert with EPA Region VIII is Dale Polnow.
Dale, do you wish to add anything?
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Comment (Dale Polnow, EPA Region VIII): I think that you covered it Paul.
I would like to point out that this revision process will get underway at the
beginning of 1976. It is to be completed in, about, a one-year time frame.
I think it is important for 208 agencies to look at their streams, their prob-
lems and their uses, and to start getting this information into a form that
can be fed to the states for use in the standards-making process.
Ferraro: Roy, do you have any response to this?
Comment (Shelby Noll): Our difficulty is in determining how much data we need
to collect to show that we have a significant problem. We started a year too
late in collecting data. We should have started on the first day of our study
period. We would like to know what constitutes an adequate data collection
base for both point and non-point sources and ambient water quality. We would
also like to know what proportion of Region VIII budgets should be spent on
such data collection.
Athayde: Perhaps John Kingscott of our Washington, B.C. Water Planning Division,
EPA, could shed some light on this.
Comment (John Kingscott): Obviously, the more data we have—the more competent
we can be. It is very important to realize that we are limited, primarily, in
our time frame. We have two-year, legislated periods to do the planning and
we are expecting the data gathering and analysis to be completed within a year
so the information can be used. This limits the kind of monitoring program
that we can expect to implement.
Comment (Richard Field): If, in a one-year period, we can collect enough data
to verify within reason the planning models available, we could go back in
time and use available rainfall records and, thus, work with more than one year
of data.
Athayde: If anyone has wrestled with this problem and developed an approach,
I certainly would like to hear about it. I have an example here done by the
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Smithsonian Institution for the Rogue River Watershed, in Maryland. They did
a characterization of a non-point pollution problem in one year. They had five
subbasins within the watershed. They installed five monitoring stations and
monitored five pollutants. I reviewed this study and found it to be an adequate
representation. A copy is on display on the speakers' table for your perusal.
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IMPACT OF CSO/SSD ON WATER QUALITY
by
John A. Lager, Vice President
Metcalf & Eddy, Inc., Palo Alto, California
INTRODUCTION
The impact of combined sewer overflows and storm sewer
discharges on receiving waters is one of the most poorly
defined and under-investigated monitoring areas in our
nation's surveillance program. While the problems are
manyfold, three are believed dominant:
• The causes are intermittent and uncontrolled
and the impacts largely transient
• In the past, dry-weather wastewater discharges
have so dominated receiving water conditions,
that wet-weather impacts were largely masked
or unrecorded
• The costs of wet-weather monitoring are pro-
hibitive and to a great extent dependent upon
fully automated sampling stations
As a result, past investigations have been limited largely
to gross impacts of aesthetics, contamination, and point
source loadings.
Aesthetics
It is human nature to judge a water's purity by its appeal
to our senses of sight and smell. Where gross pollution
occurs, who would question our ability to identify such areas
1-83
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through pictures such as these (series of slides of CSO
discharges on beaches and waterfronts)?
Public Health Concerns
Where water contact is a beneficial use, the safety or
freedom from contamination is measured in terms of plate
or filter counts of indicator organisms—coliforms, fecal
coliforms, etc. Measurements above certain arbitrary levels
then classify such waters as safe or unsafe. Obviously,
if counts rise during and following storms, the impacts may
be traced to the CSO/SSD discharges and the beaches closed
until safe conditions cigain prevail.
Point Source Loadings
Gross point source loadings may be evident through the
formation of sediment and sludge banks, the scouring of
benthic deposits, color and turbidity profiles and patterns,
and detected changes in continuously monitored parameters.
Also, the prevailing life forms in certain sections of
streams and their seasonal variability may be traceable to
CSO/SSD.
QUANTIFICATION OF IMPACTS
Receiving water impacts of wet-weather discharges have been
broadly quantified by a few investigators. The following
examples are believed representative.
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San Francisco
San Francisco is sewered on the combined plan and its annual
rainfall pattern is strongly seasonal with approximately
95 percent of the rain occuring between October and April.
As a result, receiving water comparisons between predom-
inantly wet and predominantly- dry conditions are readily
discerned. Beaches on the San Francisco peninsula shoreline
are posted by the San Francisco Department of Public Health
from October to April each year due to the contamination
from waste discharges, principally overflows. Coliform
data collected from 1967 through 1972 is summarized in
Figure 1 [1]. Typically, coliform levels observed at
beach sampling stations increased 6 to 7 times in changing
from dry-weather to wet-weather conditions. Upon cessation
of wet weather, values decreased to the background dry-
weather levels within five days. Similarly, average flotable
particulate concentrations immediately off the beaches
increased approximately 7 times under the wet-weather
conditions.
Minneapolis-St. Paul
The EPA conducted an extensive river sampling survey of the
Minneapolis and Mississippi Rivers through the Minneapolis-
St. Paul metropolitan area between June 1964 and September
1965. A brief summary of the river water quality at that
time follows [2].
Mississippi River at Anoka. This was the upstream point
in the survey(about 10 miles from the city center).
Water quality was generally good, the water was high in
DO (7.9 mg/1), low in BOD (3.0 mg/1); low in turbidity;
and no visible signs of pollution, such as floating
solids, liquids, or excessive color. These conditions
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1-86
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prevailed except for a steady increase in coliform
values, down to St. Anthony Falls close to the city
center, but above major combined sewer outfalls.
Mississippi River-St. Anthony Falls to dwf Treatment
Plant OutfallTDuring dry weather,the water quality
in this segment of the river was essentially the same
as in the preceding segment. However, during and
immediately after rainfall, discharges from some or
all of more than 80 combined sewer overflows caused
a deterioration in river water quality. Deterioration
was in the form of turbidity (increase from 25 units
to 60 units), and coliform densities (exceeded all limits
for various water uses). Even the use of these
waters for boating, fishing and navigation was consi-
dered to constitute a health hazard.
Mississippi River-dwf Treatment Plant Outfall to Point
20 Miles Downstream. DOs decreased progressively
from an average of 7.5 mg/1 at the plant (offering
only primary treatment at the time) to values of less
than 1.0 mg/1 15 miles downstream, below which the DO
started to increase. During low-flow conditions in
August 1964, gas bubbles, floating sludge, and oil
slicks were observed. There were also dense growths
of fungi along the shore lines.
The next river segment was a part of the pollution
recovery zone as the natural purification processes
came into effect, and as less contaminated streams
contributed their flows.
The above descriptions represent a classical river system-
urban development situation. While the scales of this test
case are large (riverflow 10,000 cfs and population 1.8
million), they may easily be visualized down to the smallest
creek and discharge relationship.
Greater Seattle
Harper et al [3] recently studied the effects of urbanization,
in particular stormwater runoff, on the water quality charac-
teristics in Miller Creek (5,230 acres) and Des Moines Creek
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(3,730 acres) watersheds. The watersheds are characterized
as about 20 percent single family residential, 35 percent
multi-family residential, 10 percent commercial and the
remaining land is open space or agricultural. Approximately
25 to 30 percent of the area is impervious.
The impact of stormwater discharges on the creeks were
qualitatively assessed as follows:
Generally for both creeks, the following increases
in concentration of constituents were measured:
BOD, 4 mg/1; PC>4, 0.5 to 1 mg/1; total solids, 20
to 30 mg/1; turbidity, 10 to 30 FTU; and color, 80
to 120 Pt-Co units. Significant increases in zinc
in Des Moines Creek and lead, copper and zinc in
Miller Creek were also measured and can be attributed
to stormwater discharges. The concentrations of all
other parameters either decreased or did not signi-
ficantly vary to identify stormwater as the sources
of these contaminants.
It was further observed that while the BOD increased
significantly, there was no apparent impact on the dissolved
oxygen because the re-aeration of the creeks also increased
due to the higher velocities and turbulance.
Stormwater impacts were also assessed by measures of
the biological communities within the creeks. While some
toxicity was believed occurring from stormwater discharges
(metals, solids, oil and grease), it was believed that changes
in the communities were more a result of changes in stream
discharges. Scouring of streambanks by the increased flows
compounded sedimentation problems and were of a scale equal
to or greater than sediments brought in through the stormwater
discharges.
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Other qualitative studies are available for Bucyrus, Ohio;
Roanoke, Virginia; and Castro Valley, California [4].
ASSESSMENT TECHNIQUES
The impact of CSO/SSD on receiving water quality requires
the before, during and after comparison of in-stream para-
meter values under varying hydrologic, development, and
control alternative conditions. The logical tool for such
analyses is the mathematical model. In a recent Journal
article, Hines et al [5], present an excellent discussion
of the potentials and limitations of models for such appli-
cations. Figure 2, taken from the article, rates the
relative difficulties of modeling with impact objective.
NUTRIENT AND PESTICIDE TRANSPORT
INDICATOR BACTERIA SEDIMENT TRANSPORT
Figure 2. RELATIVE DIFFICULTY OF
APPLIED MODELING [5]
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The authors conclude thcit a river quality model can be
a powerful predictive tool for river basin planning and
management providing that premises and limitations are
recognized, and that the model is properly formulated,
calibrated, and verified. Selected material from approaches
we have used are presented briefly in the following sections.
Details of the models and their applications are the
subject of a later lecture.
Transient Impacts
Models used to portray transient conditions attempt to
answer the question of what happens during and immediately
following a storm in complex river systems or estuaries.
They are dynamic in principal, and the data requirements
can be extensive.
Washington D.C. In this project, a dynamic (SWMM)
receiving water model of the Potomac estuary was used
to represent critical summer quarter conditions. Super-
imposed on this base we::e the upgrading of the regional
dwf treatment plant (from 90-98% BOD5 removals) and the
impact of a once in two year storm with alternative controls
in effect. The results are compared to the receiving water
standards in Figure 3.
Ch ic ago , 111 ino i s. In this project, the. constaints were in
both quality and quantity (backflow to Lake Michigan was to
be avoided even under the largest storms of record). Thus,
even though a relatively simple river network was modeled
(approximately 75 miles), the flows examined were so extreme
as to cause localized reversals in direction, and a dynamic
representation was required.
1-90
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(T) CHAIN BRIDGE
(fi) HOUTH CF POU CR.
Cy 141 h ST. BSIDGE
(F) MOUTH CF THE ANACOSTIA RIVER
(f) BLUE PLAINS PLANT
FT. WASHINGTON
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CASE:
YEAR
FLO*
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STANDARD ..•«•«•»••«.
ACTUAL DATA
KODEL- DATA
T
10 IS
HUES FROM CHAIN BRIDGE
IMPACT OF UPGRADING REGIONAL PLANT
10 15 20
BILES FROH CHAIN BRIDGE
IMPACT OF 2-YEAR STORM WITH UPGRADED PLANT
Figure 3. TYPICAL DYNAMIC MODEL RESULTS,
POTOMAC ESTUARY
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Steady-State Representation
Where data resources ace low, river regimes non-complex,
and only relative, comparisons required steady-state
representations appear to be quite adequate.
Reno. Thirty miles of the Truckee River running from Lake
Tahoe through Reno, Nevada to Pyramid Lake were modeled
using the well documented DOSAG steady-state model under
the state's 303e program. Seasonal comparisons were made
and the relative impacts of point and nonppint discharges
assessed. Results for DO and BOD are shown in Figure 4.
In all seven parameters were investigated [6].
Rochester. The impacts of CSO discharges at seven locations
in the lower 15 miles of the Genesee River are being
modeled using simple steady-state assumptions [7]. The
results for large discharges, shown in Figure 5, show
considerable promise as a first-cut comparison between
alternatives.
Data Analysis
Where continuous instream quality monitoring is practiced
and the period of record is substantial, statistical corre-
lations of instream quality to storm events and character
offers a desirable adjunct to modeling., This would appear
to be particularly implementable in terms of DO and where
heavy loading exists.
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SEGMENT
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Figure 4. TYPICAL STEADY STATE MODEL RESULTS,
TRUCKEE RIVER
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1-94
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CONCLUSIONS
The impacts of CSO/SSD on receiving waters need greater
attention and quantification. Beyond the obvious
gross impacts, continuous monitoring at key locations
offers the best potential for identifying trends and
sources. Modeling, at its present stage of development
and with the available data base, offers a viable tool
for comparing major alternatives. Modeling and data
collection, with rare exception, should be held to the
simplest level compatible with the objective decision
making.
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REFERENCES
1. J.B. Gilbert & Associates with Metcalf & Eddy, Inc.
Evaluation of San Francisco Wastewater Master Plan.
Prepared for the Department of Public Works. March 1973.
2. Metcalf & Eddy, Inc. Sewerage and Water Planning Report
to the Metropolitan Council of the Twin Cities Area.
November 1968.
3. Harper, M.E., E.B. Welch, T. Weiderholm, and B. Perrot.
Degradation of Urban Streams from Stormwater Runoff.
(Presented at Second Annual National Conference on Envi-
ronmental Engineering Research, Development, and Design.
University of Florida, Gainesville. July 20-23, 1975).
4. Lager, J.A. and W.G. Smith. Urban Stormwater Management
and Technology - An Assessment. Metcalf & Eddy, Inc.
U.S. Environmental Protection Agency Report EPA-670/2-
74-040. December 1974.
5. nines, W.G., D.A. Rickert, S.W. McKenzie, and J.P. Bennett,
Formulation and Use of Practical Models for River Quality
Assessment. Journal of the Water Pollution Control
Federation. October 1975.
6. Walters Engineering with Metcalf & Eddy, Inc. Areawide
Water Quality Management Plan, Washoe County, Nevada.
Washoe Council of Governments. November 1974.
7. O'Brien & Gere Engineers, Inc. Combined Sewer Overflow
Abatement Program, Rochester, N.Y. EPA Grant Y005141
to Rochester Pure Waters District. June 1974.
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QUESTIONS AND ANSWERS
(Following John Lager's paper "Impact of Combined Sewer Overflows and Storm
Sewer Discharges on Water Quality")
Question (Richard Field, EPA, Edison, N.J.): Have you given any thought to
certain kinds of pollutants that are not usually sampled or measured in a con-
ventional water quality survey—such as floatables and heavy solids? These
are highly significant pollutants, affecting aesthetics; and they produce de-
layed contribution to BOD loads, siltation, et cetera. Modeling, usually,
does not take account of these pollutants.
Lager: The question relates to two of the areas of contamination that I men-
tioned and stressed very highly—floating matter and particulate matter that
really aren't monitored and aren't logged on STORET. My recommendation for
an approach to this is to use a camera. The best way of recording some impacts
is through photography. It shows the degree of the problem and why the pro-
lem may be concentrated in one area—such as backwater areas where the pollu-
tants aren't flushing through. I think that aerial reconnaissance is also
applicable here. It is used to pick up zones of influence of discharges,
particularly industrial wastes. Maybe the same techniques can be applied to
stormwater discharges to determine the sources of concentrations of sediments.
A key is to get out on the system and use your eyes and not be solely confined
to desktop analysis or numerical analysis.
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NON-POINT SOURCE IMPACT
AND URBAN HOLDING CAPACITY
by
G. Kenneth Young
GKY & Associates
4900 Leesburg Pike, Suite 311
Alexandria, Virginia 22302
November, 1975
Introduction.
The objectives are: to present a simple model that attempts
to encompass waste generation and receiving water quality; to iden-
tify the impacts of control options that this model implies; to
focus on the effects of density in the urban area; and, finally, to
discuss some of the major issues.
It seems to be popular these days to discuss very complicated
models and data bases to the point where we lose perspective. So,
I am attempting to provide a wide angle focus in order to gain an
overall perspective. A simple model is used in order to be con-
crete .
An analogy is that my broad brush method is an attempt at a
holistic approach. "Holism" is a term that has been used by
ecologists to describe an analysis that encompasses an entire
system and gives equeil balance to the various components of it
with the thought that you have to study all parts of a system; and
study of any part of it is inadequate to understand the whole.
It is a relatively new concept and one that is somewhat anti-
scientific, because scientists must, by the nature of the scien-
tific method, focus in on very detailed, almost minute, issues
to gain more and more; understanding. But, as we get into complex
systems that involve all of us and where and how we live, it seems
important to synthesize all the ecosystem components, some of
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which are poorly understood, and attempt to balance analysis
of their interactions.
Simplified Average Water Quality Model.
As part of the holistic approach, and, in this context, it
is necessary to make major simplifications. The model I have
selected considers three types of land use as shown in Figure 1.
One is an open water body that is to be ecologically and environ-
mentally protected. The second is the shaded developed area,
and the third is open area. The population is distributed on
up ii
the developed area with a density "D". The ratio —=—- defines
the amount of the developed area in acres and "Total Area minus
p
— " defines the undeveloped land. In any developed area, and in
many of these urban runoff studies that are being conducted, this
type of conceptualization is disaggregated to produce a much finer
level of detail encompassing different types of developed land
and different types of open space.
To analyze the capacity of the water body in the center of
this developed land, Figure 2 shows a simple steady-state "oxygen-
demand model" which can be derived from more complicated repre-
sentations. The amount of oxygen that can go into this water
surface, in terms of pounds-per-day, is proportioned to the area
of the water surface and the quantity (S-C) which is termed the
"dissolved oxygen deficit". "S" is the maximum amount of oxygen
that the water can hold. It is normally a small amount, 10 mg/1
or 10 ppm. "C" is the actual dissolved oxygen in the water as
a result of pollutional loads that enter into it. The difference
between the maximum amount of oxygen and the actual amount of
oxygen in the water provides a driving force for oxygen to enter
the water across the air-water interface. Thus, the amount of
dissolved oxygen is proportional to the water area, the dissolved
oxygen deficit, an oxygen transfer coefficient KL (having units
of feet/day) and 2.71 which is a conversion factor to make the
units work out.
There are numerous experiments and publications-'- that give
lEnvironmental Protection Agency, "Simplified Mathematical
Modeling of Water Quality" a report by Hydroscience, Inc.
March 1971.
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AT = TOTAL CITY AREA (Ac)
I. :.. I. I. •:. I. :. i
!.. I. ;. S.. V. i.. I. •- !.. I. !. I i
P = POPULATION
D = DENSITY (PEOP/AC)
P
D
P
D
= DEVELOPED LAND
= UNDEVELOPED LAND
FIGURE I
LAND USE
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Ox = 2.71 KL Aw (S-C)
0¥ = OXYGEN (AIR)
OY = OXYGEN INPUT (LBS/DAY)
Aw= WATER SURFACE AREA (ACRES)
S = SOLUBILITY OF OXYGEN (mg/l)
C = AVERAGE DISSOLVED OXYGEN (mg/l)
KL= Ox TRANSFER COEFF (FT/DAY)
FIGURE 2
SIMPLIFIED STEADY STATE MODEL
1-101
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wide ranges to the coefficient KL which is a function of many
different physical mechanisms. Also, I am neglecting some water
quality parameters and I am considering only the oxygen. Other
important parameters, in an ecological context, would be the
nutrients, oil, solids, toxic materials, and others.
The amount of oxygen shown in Figure 2 which enters the
water is directly related to the amount of waste discharged to
the water.
Figure 3 gives the waste generation from a developed area,
which also has rainfall; this curve has a floor for the point-
source, with a series of peaks that correspond to storm events
that induce non-point source inputs. On the East Coast and the
Florida area which inspired this example , the time between
successive rains or peaks is three days, plus-or-minus. I under-
stand that at Boston it is two days, plus-or-minus. In dry areas
it could be weeks, depending on the time of year.
To complete the simple model we take the point-source loads,
and average them to obtain an "average effective waste input", W,
comprised of the non-point source and point-source loads. The
relationships are given in Figure 4. The "ultimate oxygen demand",
in pounds per day, is considered; this is ari indirect measure of
the organic material going into the system. With "W" being the
"average daily waste" at steady state, the waste input equals the
amount of oxygen that can enter into the system. To estimate W,
it is assumed that the developed land possesses a loading factor,
LQ, in terms of pounds of UBOD per-acre/day. This is an average
of the total arrival emissions caused mainly in wet periods divided
by all days in the ye:ar. There is the same type of loading factor
for the open space.
The point source, in this case, is caused by people; domestic
waste loading is normally expressed in pounds-per-capita per day.
Recall that we have P as "population", D as the density in
Sanibel Island, Lee Co., Fla.; the water body is a fresh
water marsh in the center of a barrier island.
1-102
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t
I
CO
GO
Z
UJ
1
UJ
I
§
± 3 DAYS
N.RS.
W = (NPS +PS)
TIME-
W = AVERAGE DAILY WASTE (NPS + PS)
A= EQUILIBRIUM
FIGURE 3
WASTE AVERAGING
1-103
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D
NPS
PS
DEVELOPED
NPS
= L.BS UBOD/ACRE/DAY
= 1_BS UBOD/ACRE/DAY
t
ps
I_BS/CAPITA/DAY
P = POPULATION; D = DENSITY (P/ACRE)
FOR PS —> f = fraction removed
FIGURE 4-
WASTE GENERATION MODEL
1-104
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"people-per-acre". We introduce another variable "f" which is
the fraction removed of the point source. With these parameters,
I can multiply the loading factors times the areas and get a
waste generation function which gives the average waste input
per day as a function of the non-point source upon the developed
and open lands, plus the point source (or 1 minus f, times the
per capita loading rate times the population).
The ratio of developed-to-undeveloped loading rates can
be on the order of 10 to 100. The developed loading rates are
strongly related to the ratio of pervious and impervious area.
In open space, most of the water sinks in, and you get a soil
removal process. Thus, the loading rates are much smaller.
Application of the Model.
For a typical Florida situation where we were attempting
to develop holding capacity constraints, we used the typical values
shown in Table 1 for the parameters. The desired average dissolved
oxygen, or the water quality standard, is 5-mg/liter; the dissolved
oxygen solubility is 9 mg/1 (this is typical of warm southern
waters); the oxygen-transfer coefficient is 0.15 feet/day (this
is representative of quiet, still waters). For waste generation,
in open land for the non-point source, 0.004 pounds/acre/day of
UBOD is used (yearly average); for the developed land, non-point
source loading, 0.4 pounds/acre/day of UBOD is used. For the
point-source loading, we use 0.25 pounds/capita/day which is more-
or-less a U. S. average for domestic untreated sewage. We have
a point-source removal fraction of 0.85 which corresponds to the
secondary treatment level required by P.L. 92-500. And, for this
Florida demographic situation, there was a total land area of
about 5,000 with a fresh-water marsh of 1,000 acres, a population
of 12,000, and a density of 4 persons per acre (which is rather
low and which would correspond to an affluent suburb).
When I combine these relationships and values into the holistic
model that I referred to, I get the average concentration of the
dissolved oxygen in the water body (in this case, a marsh); the
1-105
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PARAMETER
TYPICAL VALUES
SYMBOL
COMMENT
C3
Avg. D.0.
D.O. Solubility
D.O. Coefficient
C = 5 mg/1
S = 9 mg/1
KL = 0.15 ft/d
Typical W.Q.S,
Southern
Quiet, still
5 Sc °Pen N.P.S.
fv Ct:
LU LU Developed N.P.S,
LU
P. S.
P.S. Removal
L(j) = .004 #/Ac/d
LD = .4 #/Ac/d
Lp = 0.25 #/CAP/d
f = 0.85
Yearly Average
Yearly Average
U. S. Average
PL 92-500
C_J
ol
-------
waste-generation function equals the oxygen-transfer function.
This function is given in Figure 5. Then, I calculate the
partial derivatives (or the marginal rate-of-change) of the
dissolved oxygen concentrations, with respect to the more popular
policy-sensitive variable. Figure 5 shows the rate-of-change of
the concentration with respect to the population (small and
negative), the rate of change with respect to the density (large
and positive), the rate of change of dissolved oxygen concentration
with respect to the removal fraction, the rate of change of C with
respect to the land use loading factor emission rate for developed
land (fairly large) and the rate of change with respect to the
water surface area (rather small).
These coefficients are hard to compare among themselves. But,
they can be combined into a relationship using the total different-
ial, or the first-order terms of the Taylor Series Expansion, and
you get the change; in "C" for changes in the various parameters.
That, is the type function which permits you to assess the impacts
of various policy options.
Table 2 puts this sensitivity information into a scaled format
which makes changes relative and more interesting. I can scale
the policy-sensitive variables, plus-or-minus 10%, as the case may
be, to get positive changes in water quality. So, if I decrease
my population by 10%, I can improve the average water quality in
the system by 7.9%. Tf I increase the water area 10%, or the
assimilative capacity, I can increase the dissolved oxygen by 7.6%.
Tf I decrease the non-point source load by 10% (for the developed
areas), I get an increase in dissolved oxygen of 5.9%. If I
.increase my density 10% (I keep the same number of people, but
put them on Joss land), I get 5.8% increase in dissolved oxygen.
If I decrease my point-source load by 10%, I get a 2.2% increase
in dissolved oxygen.
A change in the water area would correspond to some type of
increase in the assimilative capacity. This is a classical solu-
tion and since the 1900's we have connected our sewers and sewage
treatment plants to points that are further downstream having
increased assimilative capacity.
1-107
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P - °
L» - C>
AT + AW ) + (LD -L^,
2.71 KL Aw
V P .
' D
( 1 - f ) LP P
PARTIAL DERIVATIVES
_ac_
8P
= -0.000.33
_ac_
3D
= +0.73
at
ac
3LD
ac
= +7.38
= -7.38
0.0038
AC = TOTAL. DIFFERENTIAL.
POPULATION ~
PS REMOVAL
WATER SURFACE
AC=-.00033 AP + 0.73 AD-»-7.38 Af-738ALD+0.0038 AAW
DENSITY-
f
N.PS LOAD (DEVELOPED)
FIGURE 5
WATER QUALITY SENSITIVITY
1-108
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PARAMETER
(TYPICAL VALUE)
CHANGE IN
PARAMETER
CHANGE IN
AVG, D,0,
POPULATION
(P = 12000)
-10%
+ 7.9%
WATER AREA
(1000 ACRES)
+10%
+ 7. 6%
NPS LOAD - #/D*
(71,5% TOTAL LOAD)
-10%
+ 5.
DENSITY
(P.ACRE =
+10%
+ 5.8%
PS LOAD - #/D
(27,1% TOTAL LOAD)
*Developed Areas
-10%
+ 2. 2%
RELATIVE IMPACT
TABLE 2
1-109
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Decreasing the non-point source load is definitely an option.
It may be possible to achieve this through urban housekeeping
techniques or improved grading practices. However, it takes
imagination to invent ways to keep material from washing off an
urban surface into water areas.
The one option I feel is very interesting is the density,
because if we increase the density, we improve the water quality.
This leads to Planned Urban Devleopments, parks, and cluster
developments. All the things that planners are excited about
today seem to fit into water quality enhancement in these area-
wide studies.
Changing the point-source load indicates that going to
advanced waste treatment has relatively-low impact. This is
something that seems to be pretty-well known.
Pollutograph Control Model.
If I can digress, I have been discussing a model that handles
the average water quality in the water adjacent to an urban area.
I have also used a very similar analysis^ and looked at the effects
of controlling storm events while focusing on individual polluto-
graphs. Without presenting the detailed mathematics, which are
similar to those presented ;.n the first part of this paper, I'll
show the major components and what the sensitivities are for them.
Whereas, before we were: focusing on one year's worth of
pollution emissions and looking at the various non-point source
spikes and averaging them, now I would like to refocus attention
on an individual storm event, and consider as a decision variable
the point of maximum concentration of BOD. Figure 6 shows that
the decision variable is the maximum UBOD concentration of the
pollutograph that results from a storm event in an urban area.
It is comprised both of urban washoff and combined sewer overflows.
The pollutograph is expressed in terms of parts per million (ppm),
^Young, G.K., "Decision Perspectives on Urban Stormwater
Pollution", J. Water Resources Research, in press, (Dec. 1975]
1-110
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DECISION VARIABLE POINT OF
MAXIMUM IMPACT-URBAN
WASHOFF + C.S.O.
TIME
POLLUTOORAPH
NEW OBJECTIVE •• CONTROL CM(MAXIMUM UBOD) RATHER
THAN AVERAGE (DO) QUALITY
FACTORS' STREAMFLOW, C(STREAM), C(WASHOFF), C(SEWAGE),
POPULATION, STORAGE (PRIMARY + DETENTION ), FRACTION
COMBINED SEWERS, POINT SOURCE REMOVAL
FIGURE 6
STORM EVENT CONTROL
i-in
-------
or milligrams per liter (mg/1). At the start of a rain, we
have an initial condition and this increases to a maximum and
then decreases. Since this isa concentration, it doesn't tell
you how much waste is going in. It could be a small storm with
a high concentration or a large storm with a low concentration.
There is some evidence that for some types of urban areas, it
doesn't matter what type of storm it is (as long as it is of
sufficient magnitude), the maximum concentration is relatively
constant.
Our new objective here is to control C^ which is the maxi-
mum UBOD, rather than the average DO quality. The major factors
entering into this include: the ambient stream flow; the quality
of the water in the stream; the quality of the urban washoff
itself; the quality of the sewage; the population; the storage
that is inherent in the sewer system in terms of the primary
sedimentation tanks, plus any stormwater detention tanks that
may exist; the fraction of combined sewers; and, possibly,
the point-source removal efficiencies.
With this simplified system, I have also calculated the
relative impacts, or elasticities for a typical city that has
70% combined sewers, secondary sewage treatments, and primary
treatment or its equivalent in terms of detention tanks, or three
times the dry weather flow. Table 3 shows the pollutograph control
relative impacts.
If we increase the stream flow, or assimilative capacity,
10%, we can increase this maximum UBOD 6.1%. This was a major
policy variable (increasing the stream flow) in the early 1960's
when dilution was an acceptable solution for pollution. Now,
although dilution storage is called for in some existing Corps
of Engineers reservoirs, it is not actively pursued as a policy
option.
By means of detention or swirl concentrators, if we increase
the effective storage capacity 10%, we change the maximum UBOD
1.9%. This a little misleading because we are starting from a
fairly small amount of storage in existing systems. The amount of
1-112
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TYPICAL CITY: 70% Combined Sewers
Secondary Sewage Treatment
Primary Treat (or eq.) for 3 X DWF
PARAMETER
STREAMFLOW
(WATER AREA)
CHANGE IN
PARAMETER
+10%
CHANGE IN
MAXIMUM UBOD
-6.1%
DETENTION
STORAGE
+10%
-1.9%
FRACTION
COMBINED
SEWERS
-10%
-1.3%
TREATMENT
EFFICIENCY
(SEC AWT)
+10%
-1.3%
POLLUTOGRAPH CONTROL
TABLE 1>
1-113
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storage involved in primary treatment or its equivalent that
provides several hours detention, or handles three times the
dry weather flow, is not a large storage volume, A 10% increase
does not increase storage much. In other words, the 1,9% impact
associated with storage is relatively small, but it is economically
possible to increase storage: several hundred percent.
Changing the fraction of combined sewers 10% decreases the
load 1.3%.
Improving the efficiency from secondary toward advanced waste
treatment of 10%, decreases the maximum UBOD 1.3%.
To get a comparison, for the DO model (first presented) we
changed the water area 10% and got a 7.6% change in DO. Once
again, we see the major effe;ct of improving the assimilative capac-
ity of the system.
Table 3 deals with changes in maximums. Table 2 deals with
changes in averages. One point is that, when we are working with
averages, we can achieve greater changes through controls than
for equivalent controls when we are working in terms of a maxi-
mum. This is a very sensitive point and it bears on the fact
that we really don't have an objective. Are we trying to look at
the worst condition, or a certain probability level, or what have
you ? These analyses seem to indicate major differences in the
averaging interval that is used for protection of our environment.
Conclusions.
Going back through the list of factors influencing average
water quality, population is the most important; water area is
next, followed by control of non-point source loading, density,
and point source loading. The two top policy areas are non-point
source loading and density i because we seem to be beyond the
point of changing the population or increasing the assimilative
capacity. Thus, we are basically looking at urban housekeeping
(or the manipulation of non-point source loads) and density as
two more-or-less equivalent factors.
1-114
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Moreover, I would like to say that the control of environ-
mental quality seems to be suffering from lack of a concrete
objective. This analysis, and any other analysis, tends to
point that out. Are we striving to eliminate non-point source
loadings? Are we striving to improve average quality? Are
we striving just to look at pollutographs and their effects?
Just what are we striving to do and what is the objective?
I think each area-wide waste management project should focus on
objectives at the beginning.
1-115
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Questions and Answers
Question: In the last term of the waste generation function,
what was the variable?
Answer: The variable was Lp, the per capita loading rate.
Question: When you increased the density in that equation, did
you hold all the other factors constant?
Answer: Yes.
Question: Would there not be some kind of compensating effect?
If you increased density, you would probably increase
your non-point source load because you have probably
increased the built-up area in the already developed
area, and therefore, you have much more runoff.
Answer: The answer is "of course" there is going to be an
interactive effect that is neglected in that first
order equation. However, I think the trend is there.
You can increase -the density in planning new towns,
or by looking at undeveloped land in terms of planning
for its development; if you can concentrate people and
use the types of development that are in vogue now,
you will improve the water quality.
Question: What is the upper end on increasing density with regard
to controlling pollution or improving water quality?
Answer: I don't know. :: think that Manhattan is beyond it, to
my way of thinkung.
Question: The type of change proposed in an increase of about
10%. That's all. right for single family housing.
I was wondering why the diminishing returns set in.
Is the curve beginning to drop down after a decreasing
density of 15% to 20% or do we reach some ultimate
increase in density associated with water pollution
control?
Answer: I don't know the answer to your question; but I can
guess that, there must be some point of diminishing
returns. But this type of method and analysis would
1-116
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lend itself toward taking an existing situation and
calibrating the situation and looking at what changes
in these various directions can accomplish. As you
take major steps, you have to redefine the model or
determine what the correlation between variables is.
You have to go to a higher order of analysis.
Question: (Ron Peterson): Other than in the DO saturation
figure, is there any other effect taken into account
for changes in temperature, such as the percentage of
the DO changing with changing temperature; e.g.,
thermal discharge into a stream?
Answer: That effect is not considered in this simple model;
but it certainly could be in fairly simple approaches
to this problem.
Question: As a modeler, I think you are aware that most of the
modeled systems can be parameterized, or subject to
parametric analysis such as you have done. In fact,
you can recreate the model's transfer function to
account for the second order effects that have been
mentioned in the discussion. In fact, some proposals
like this have been advanced for environmental manage-
ment information systems. Do you perceive more work
being needed in this area—shifting away from the more
fundamental approaches where we take a water quality
model and write it in a stream?
Answer: Of course.
1-117
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QUESTIONS AND ANSWERS
(Following Kenneth Young's paper, "Non-point Source Impact and Urban Holding
Capacity")
Comment; Your concepts are interesting and are a novel way of looking at the
whole problem. But, your conclusion on density disturbs me. According to your
model, you are keeping population and land area constant. Therefore, density
would be constant and your conclusion showing change in density for decreasing
pollution may well be an artifact in the way you defined several of the vari-
ables. Concentrating pollutants could be one major source that would do much
more damage than a series of small sources.
Young; The densification is something that is being given serious considera-
tion. It is certainly consistert with transportation planning which is going
toward density as a means of energy conservation. I'll stand pat on the model.
Question; In your example, you said 71.5% of the total load was due to non-
point sources and you told us that it had been included in this model.
Young; This was oxygen demand, and it would include all washoff from the sur-
face of the land, whether or not. it got into the combined sewer. The point
source was all domestic waste. That portion of the combined sewer overflow
where the pollutants came from the land surface would apply in the model, and
that portion of the sanitary sewers that overflowed would be a violation of the
assumptions for the model. For developed land, there is about three times as
much, on an annual average, from non-point sources from storm events as there
is from treated point source discharges. That average is taken over a time
period that includes all storm events and the dry weather intervals.
Question; I believe that: this -ype of modeling simulates a steady-state type
of modeling for decision-making. I believe most 208 Agencies are going in this
direction just for convenience. Ky main concern with this is basing decisions
on impacts that probably aren't occurring in-stream. We are basing decisions
on average results of instant impacted HO.
1-118
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Young: I couldn't agree with you more! My paper was based on a two-day
thinking process; and, perhaps, $ 150 million would add some flesh to it.
Comment (Driscoll): When we get down to a detailed analysis, we need some-
thing more elaborate. But, the value of that particular analysis permits new
approaches and concepts and gives a perspective of the problem and how all
the pieces fit together. It is possible to start out with an approach that
involves assumptions.
1-119
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QUESTIONS AND ANSWERS
(Following G. K. Young's paper "NFS Impact and Urban Holding Capacity
Question: In the last term of the waste generation function, what was the
variable?
Young: The variable was L , the per capita loading rate.
p
Question: When you increased the density in that equation, did you hold all
the other factors constant?
Young: Yes.
Question: Would there not be some kind of compensating effect? If you in-
creased density, you would probably increase your non-point source load be-
cause you have probably increased the built-up area in the already developed
area, and therefore, you have much more runoff.
Young: The answer is-~"of course". There is going to be an interactive
effect that is neglected in that first order equation. However, I think the
trend is there. You can increase the density in planning new towns, or
looking at undeveloped land i~i terms of planning for its development. If
you can concentrate and use tie types of development that are in vogue now,
you will improve the water quality.
Question: What is the upper and on increasing density with regard to control-
ling pollution or improving water quality?
Young: I don't know. I think that Manhattan is beyond it. For me, it is.
Question: The type of change proposed is an increase in density of about 107o.
That's all right for single family housing. I was wondering why the diminish-
ing returns set in. Is the curve beginning to drop down after an increase in
density associated with water pollution control?
Young: I don't know the answer to your question; but I can guess that there
must be some point of diminishing returns. But this type of method and
analysis would lend itself toward taking an existing situation and calibrating
1-120
-------
the situation and looking at what changes in these various directions can
accomplish. As you take major steps, you have to redefine the model or de-
termine what the correlation between variables is. You have to go to a
higher order of analysis.
Question (Ron Peterson): Other than in the DO saturation figure, is there
any other affect taken into account for changes in temperature, such as the
percentage of the DO changing with changing temperature; e.g., thermal dis-
charge into a stream?
Young: That effect is not considered in this simple model; but it certainly
could be in fairly simple approaches to this problem.
Question: As a modeler, I think you are aware that most of the modeled systems
can be parameterized, or subject to parametric analysis such as you have done.
In fact, you can recreate the model's transfer function to account for the
second order effects that have been mentioned in the discussion. In fact,
some proposals like this have been advanced for environmental management in-
formation systems. Do you perceive more work being needed in this area--
shifting away from the more fundamental approaches where we take a water
quality model and write it in a stream?
Youne: Of course.
1-121
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RUNOFF AND QUALITY
E. D. Driscoll - Hydroscience
INSTREAM IMPACTS FROM STORM OVERFLOWS
Water quality changes in receiving waters are caused by contaminant loads,
i.e. by the total pounds of a pollutant which enters the natural water'
because of a storm overflow. There is a growing body of data identifying
storm generated contaminated loads expressed as areal loading factors,
for example pounds per acre per year. Data of this form is useful, and
this approach to identifying loads is necessary for those areas where
loads enter the receiving water in a very diffused manner. Upstream sec-
tions of a drainage basin, or un-sewered areas would require this approach.
Such data is also useful in comparing data from different locations, or
for considering the effect of those contaminants which have a large time
and space scale associated with their instream impact.
For urban settings, however, where storm runoff is collected and conveyed
to the receiving water through a sewer system, where structural control
measures are to be considered and where the transient nature of receiving
water impacts must be defined - identification of storm loads in this
manner lacks adequate definition and detail.
In such situations, storm generated contaminant loads are best characterized
by product of runoff flow and contaminant concentration. This approach to
waste load definition best accounts for the transient nature of the loads,
1-122
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and the variability from event to event. It provides the type of data
base required to evaluate structural solutions, as well as some non-structural
ones.
It then becomes necessary to appropriately characterize runoff flows and
quality for a specific area.
RUNOFF
Stormwater runoff is generated by the rainfall on an area. The rain water
flows across the surface and gravitates toward the natural outlet from the
area either through natural drainage courses or through sewers or other
collection systems. The amount of runoff is related to the quantity of
rain. Not all rain striking the surface will reach the outlet of the
drainage area. Some percolates into the ground or is retained in natural
depressions. The net result is that only a fraction of the rain falling on
an area will ultimately show up as runoff.
This fraction may be quite large, or quite small, and is in fact extremely
variable. A predominant influence on the fraction of rainfall which runs
off is the degree of impreviousness of the area. The major effect is due
to artificial surface cover such as pavement, roof tops, sidewalks, and the
like. Soil types in the other areas also exert an influence. Secondary
effects, such as ground slopes, soil moisture, and the like introduce further
modifications.
1-123
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The amount of runoff generated by rainfall is therefore very sensitive
to local conditions. It is also subject to variation based on specific
characteristics of the storm which generates it - for example, the inten-
sity, the time since the antecedent storm, etc.
Regardless of the significant effect of these factors, it is well to
bear in mind that the predominant influence on the amount of runoff to
be expected at any particular time, is the rainfall process itself.
Figure 1 provides some perspective on the relationship between storm flows
and normal sewage flows for an urban area. It also illustrates the
tremendous range in storm flows which can be generated based on the
particular storm characteristics.
The rainfall process itself is extremely variable, and the approach there-
fore taken to characterize runoff, has been to develop it as a proportional
relationship to the rainfall itself. A convenient approach is to define
the ratio between the amount of rain falling on an area, and the amount
which runs off
,, _ V runoff
V rain
There have been refinements to this approach, some of which are used in
current storm water models. The simple ratio however, because of its
simplicity and familiarity remains a useful basis for exploration of storm-
water problems. This is certainly the case for this discussion, and at
this point it appears that it. will prove to be the most effect basis for
analyzing most problems associated with stormwater overflow, at the
planning level.
1-124
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1-125
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In the following discussion of Factors which influence runoff, we will be
concentrating on the' runoff coefficient, c. It represents the ratio of
the volume of stormwater applied to the area as rainfall, Co the volume
of stormwater leaving a drainage area.
Figure 2 summarizes and condenses some published data. It illustrates
the very substantial effect on runoff due to land use. The effect of
increasing population density over the spectrum of urban development from
rural through industrial and coiumercial envelopment, is primazilyr a reflec-
tion of the extent to which natural land surfaces are covered by impervious
surfaces (pavement, etc.)- The actual value in any area can "ary from the
overall mean value for the equivalent -copulation density, by 25 or 30%.
This appears due in substantial part to the soil characteristics and topo-
graphy of the local area or the cegiee of industrial or commercial development.
The relationship shown here illustrates th* Tnagnii-.ude of the effects that
increasing urban development c?n have on f.he storm •"•unoff problem. Urban
development substantially increases thn atnount of rainfall which reaches
receiving waters quickly. The figures summarized \:y this plot represent
broad average values based on date throughout trie country. The land use
characteristics of a particular area will thus define in a relatively broad
sense the order of the runoff coefficient,
There are however other factors which nodify it. Figure 3 illustrates in a
relatively simple manner the effect that the rainfall process itself can
have on the amount of runoff generated. The curves shown are taken from a
1-126
-------
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published report describing for a particular area the change which the
runoff coefficient undergoes as a storm progresses. For any particular
degree of imperviousness (we show 20% and 30%) the runoff coefficient
increases as the storm progresses due to the effect of continuing rain-
fall on depression storage and on infiltration rate. What is interesting
is a calculation based on this data which shows that for this basin with
30% imperviousness, the average runoff coefficient (c) for a 2-hour storm
is 0.56, whereas for a 4-hour storm it has increased only to 0.62. Other
than for very short storms, the variation in runoff coefficient due to
changes in infiltration and depression storage during the course of a
storm may be only in the order of 10 or 15%.
Another, and quite significant factor influencing the runoff coefficient
relates to the measurement of rainfall itself. Consider Figure 4: the
data comes from two published studies, one for Milwaukee, Wisconsin and
one for Durham, North Carolina. Each provided a substantial amount of
data on individual storms in which both the rainfall was recorded, and the
runoff was measured. Note the substantial spread in the value of the run-
off coefficient for each area when the data is analyzed statistically.
Milwaukee had a higher median runoff coefficient (0.45) compared with
Durham (0.35), as might be expected from differing land use patterns.
There is however a substantial spread in observed coefficients for each
location - well beyond the 10 to 30% differences noted in the previous
graphs. These data are for a specific area, in which nothing changed
during the course of the study other than the rainfall. The degree of
1-129
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PERCENT CF TIME LESS THAN OR EQUAL TO
FIGURE 4-
STATISTICAL VARIATION IN RUNOFF COEFFICIENT
1-130
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variability is due largely to rain gage density rather than to the factors
we have discussed until now.
The effect is substantial, and it is significant. It is due to the fact
that our perception of the rainfall on an area is determined by what is
measured at a particular rain gage or set of gages. The variation in the
statistical plot is a reflection of the degree to which the rainfall inten-
sity measured by the rain gage differs from the average intensity over the
entire drainage area which the gage in question is assumed to represent.
Figure 5 illustrates this point schematically. Rainfall is not distributed
uniformly over an area. Any rain gage at a specific location in this area
will therefore either over-estimate, or under-estimate the average rainfall
over the entire area, which is what ultimately determines the amount of
runoff which leaves the area. The larger the drainage area served by the
gage, (that is the lower the rain gage density), the less likely it is the
gage reading will represent the average rainfall. This will increase the
variability of the data, as is in fact illustrated by Figure 4.
The significance of this is the following:
The runoff calculated from rainfall, as measured by a rain gage
will not have a consistent relationship. Any particular rainfall
recorded by a gage will correspond not to a particular runoff value,
but to a range of possible runoff values. The greater the rain gage
density, the narrower the probability limits on runoff will be.
1-131
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RUNOFF COEFFICIENT (C }
REAL = 0.5
APPARENT = 0.8
(G>RAINGAGE
I = 200
Ir, = 125
R = 100
DRAINAGE AREA
RUNOFF COEFFICIENT ( C
REAL =05
APPARENT =0.2
(G>RAINGAGE
I =200
= 500
R - 100
FIGURE 5
EFFECT OF AREAL DISTRIBUTION OF RAINFALL
ON REAL VS. APPARENT RUNOFF COEFFICIENT
1-132
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Since the variation in runoff due to the limitations in our measurement
of rainfall may be broad, we must examine the significance of any refine-
ments in calculations to account for other effects which have a much
smaller influence on the runoff calculations. We should further examine
the usefulness of considering arbitrary individual events. We must also
keep these factors in mind when establishing a monitoring program or
interpreting data from such a program.
Figure 6 illustrates schematically how our ability to identify "real"
effects of storm properties, land use, etc. may be masked by variations
introduced by a low density of rain gages. A measure of the variability
of a set of such data, is provided by the coefficient of variation (V),
defined as the ratio of the standard deviation to the mean.
V = 1.0 or more indicates extremely variable data - for example
1 standard deviation = ^ 0.5
thus range of C = 0 - ^> 1.0
V = 0.1 and mean C = 0.5
1 standard deviation then is _ 0.05
thus range C = 0.45 to 0.55
(Above ranges for a standard deviation)
1-133
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-MINIMUM VARIATION
IN "C" OBTAINABLE
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RANGE IN C VARIATION DUE TO
VARIATION IN RAINGAGE DENSITIES
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10 20 30 40 50 60 70 80 90
PERCENT OF TIME LESS THAN OR EQUAL TO
95
FIGURE 6
CONCEPTUALIZATION EFFECT RAINGAGE
DENSITY ON RUNOFF COEFFIENT CALCULATION
1-134
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Using this concept to develop a quantiative sense of the significance
of rain gage density, Figure 7 has been developed. Data from a number
of studies has been analyzed and plotted, along with a theoretical
expression for the relationship between rain gage density and the
variance of runoff coefficient. Considering that a coefficient of
variance in the order of 0.1 or 0.2 would limit the standard deviation
to + or - 10 to 20% of the mean, we can estimate that rain gage densities
in the order of 1 to 5 gages per square mile would be desirable.
It is readily conceded that such a figure represents an excessive number
of gages for the typical 208 planning area. It suggests that an effective
approach would be to concentrate study effort on selected smaller areas,
where suitable gage density can be provided. In situations where this is
not possible, it provides a basis for understanding the variability which
will be encountered, and to factor this into conclusions and decisions.
QUALITY
Contaminant concentrations in storm runoff vary considerably, under the
influence of storm patterns, land use, type of constituent, time since
it started raining, and conditions related to size of, and time since
the antecedent storm event.
The predominant influences are land use patterns, and whether the storm
drainage system consists of combined versus separate sewers.
1-135
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•THEORETICAL (AFTER MODEL BY ZAWADSKI)
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PUBLISHED REPORT
NOTE
COEFFICIENT OF VARIATION,
STD DEVIATION
(V)--
001
MEAN
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01 I 10
LOG RAINGAGE DENSITY ( LBS /SO Ml
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FIGURE 7
RAINGAGE DENSITY VS.
VARIABILITY OF MEASURED RUNOFF COEFFICIENT
1-136
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Of the secondary influences, the variation due to time since the start
of rainfall (or runoff) is important. The early stages of storm runoff
carry proportionately higher concentrations of most contaminants than
later runoff, due to first flush effects. Initial runoff flows flush
accumulated debris from catch basins, streets, land surfaces and sewer
lines - and result, on the average, in higher waste concentrations during
the initial runoff period. This relationship can be important because of
the influence it may have on a number of control approaches.
The magnitude of the first flush effect, and its significance may vary
significantly, depending on whether combined or separate sewers are in
use, and the size of the drainage area. Large areas, with significant
times of concentration may cause a masking or damping of first flush
effects as they reach the sampling station in a staggered fashion.
For combined sewers, the effect may be less pronounced than with separate
sewers, because storm flushes will be "diluted" by the high contaminant
levels in raw sewage. Data on combined sewer overflows from 97 storms
at Milwaukee, Wisconsin are summarized by Table I. Although any random,
individual event may not clearly reflect the first flush effect, the net
effect when all events are considered is storm generated concentrations
of BOD, solids, COD, chlorides, Organic Nitrogen and Nitrate, in the
early states of runoff are 1.5 to 2.5 times dry weather concentrations in
sewage. For some contaminants (Ammonia, Phosphorus, Fecal Coliforms),
storm generated concentrations are lower - indicating the predominant
source to be the raw sewage.
1-137
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Some typical data frcmi separate t>ewers is illustrated by Figure 8 for an
urban area, and Figi^e ** "OT a serai urban - rural area. Note that when
cori'-entratiois are- ^OUGJ dei eo, :> f^rsr flush effect is definitely
indicated for all cases,. w;;,ti; i'.-? .'xc^ption of BOD in the runoff from
the rural area,
An important factor illustrate! hy tbe^e plots, is the time variation
of the Mass emissions of E-OD and --impended eolids Mass emission (i.e. #/hr)
as distinct from concentration, foiu-ws a pattern which is dominated by
runoff flow.
DATA__NEF.ps
Considering the variable i"iar;J,n; of rhr process generating storm overflow
loads,, and the van.abil'cy ,.uc I-.' a'zed by data flow storra water studies, it
should be clear that some tocal assesr,m?nt of storm .loads is necessary co
compare with information or, the prot.,?r,s deve.loped from previous studies.
Information on rain gage density, en flows and quality of runoff or over-
flows .is requited to identify the significance of local effects,,
F;:oble-r ,-»-aj y:';.-; and the a.~segment of alternatives, also requires that
pertinent physical data b~> as-,
-------
50
Time (hrs)
FIGURE 8. Variation of Flow, BOD, and Suspended Solids During the
Storm of Nov. 13, 1972 at the Urban Sampling Station.
Source: Stormwater Runoff Quality for Urban and Semi-urban/Rural
Watershed!?, by F. T. R. Me Elroy III and J. M. Bell, February
1974, Purdue University Water Resources Research Center.
1-140
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-800
Time (hrs)
FIGURE 9. Variation in Flow, BOD, and Suspended Solids for the Storm
of Nov. 13, 1972 at the Semi-Urban/Rural Sampling Station.
Source: Stormwater Runoff Quality for Urban and Semi-urban/Rural
Watersheds, by F. T. R. Me Elroy III and J. M. Bell,
February 1974, Purdue University Water Resources Research Center.
1-141
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PROGRAM CONSTRAINTS
The variable nature of the waste loads generated by storm overflows
implies a degree of uncertaintly which will be associated with a limited
numer of measurements. Program constraints - available time and budget
for addressing storm water aspects will limit the effort which can be
made - i.e. limit the number of measurements which can be made - at least
for the initial evaluation.
An effective analysis can be riade if we recognize these facts, and
adopt a program which balances; the level of detail employed in both
monitoring and problem analysis phases of the study program. This means
that we plan the planning study such that we do not adopt for any one
aspect of the study, a level of refinement and detail which is incompa-
tible with levels obtained for other integral components.
Example - waste loads will be the product of Flow X Concentration.
It is not meaningful to determine flow variations very precisely
if concentrations are known only crudely. At a design level, flows
may need to be known with more precision - but not necessarily
at the planning level.
Further, the planning effort should not seek to define loads with greater
detail and refinement than are necessary to identify significant: effect on
receiving water quality..
1-142
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PROGRAM GUIDELINES
RATIONALE - 208 Planning studies operate within a specific budget and
time frame (about 12 to 18 months for technical analysis). The random-
ness of the storm overflow process argues that enough "general" data will
probably not be secured within this time frame to "average out the
variations," to put it simply. It is enough time to identify the key
influences, however, if the effort is focused properly.
1. Select several small areas for detailed analysis, rather than attempt
a broad assessment for a large area. With a good handle on how specific
type areas will behave under storm influences, one can then synthesize
the combined response of a large area.
Small study areas should be selected to include the range of land use
or population density conditions in the area, preferably such that
each area selected has one such pattern which predominates.
2. With a limited number of small areas being studied in detail, we
can afford to eliminate much of the variability due to rain gage
density, by placing an appropriate number of gages in each area.
This becomes esepcially important in areas with significant changes
topography that influence rainfall.
1-143
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3. Locate flow measurement and sampling stations at a common point,
at the outlet of each study area.
4. Obtain data on as many storm events as practical within overall
program constraints, but probably not less than about a dozen events.
Select sampling and analysis interval on the basis of an analysis
of system responses in the receiving water. In most cases, will
not have to consider anything less than 1/2 hour or 1 hour composites
for analysis - in some cases, longer composites may be appropriate.
Composites should be flow weighted, and care should be taken that
even short storms are picked up
If necessary, concentrate analysis on those contaminants which influence
the receiving water problem you are trying to relieve.
CONCLUSIONS
Local determination of Runoi'f and Quality should be made.
Expect variability in data; select program such that you maximize
ability to relate variations, to local causes.
Rain gage spacing (density) can introduce variations substantially
greater than those caused by storm or surface effects.
Adopt a level of detail consistent with the sensitivity of other
elements in the analysis to the level of detail of the inputs.
1-144
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QUESTIONS AND ANSWERS
(Following Mr. Driscoll's paper, "Runoff and Quality")
Question (in reference to a slide shown by Mr. Driscoll): Doesn't that
essentially refute the "first-flush" effect?
Driscoll: No. It actually refines it somewhat. The first-flush effect is
significant in pollutant concentration. The flow itself has such a tremendous
influence on the pounds of pollutant that it can totally distort the first-
flush effect from one rainfall to another because the rain can occur in almost
any pattern.
Question (Dan Goodwin, Illinois): If there is a first flush evident from the
combined sewers in the Chicago area, it lasts more than 15 hours. Do you have
any comment?
Driscoll: That is a long time for a first flush.
Condon: May I add one thing to what you said? All you said is correct. But,
there is one more variable. This is the peculiarities of the collection-trans-
port system. With long, flat slopes there is more opportunity for deposition
in the system. Chicago is an example, and it can have a long first flush be-
cause the system is picking up from all over the District's widespread system.
Question: What is the correlation coefficient that you think we should know?
Driscoll: From a limited amount of data, a correlation coefficient for rain
gage densities of 4 gages per square mile is .87 which removes about 75% of
the variability of measurements.
Question: In a combined sewer system, I assume that there would be a lot more
of the total pollutant loading in the first flush. Is that safe to assume?
Driscoll: No, not necessarily. Some data that I analyzed from a Milwaukee
combined sewer system showed that there was a first flush if one looks at con-
centrations. In the first flush, extra material is picked up at the first
1-145
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stages of the storm. If you look at pounds, though, the flow variation,
where high flows come later in the storm, so overwhelm the picture that the
effect is totally masked.
Question: It has been argued that the first 0.25" of rainfall will pick up
about 90% of the BOD from a combined system. There, obviously, is some con-
flict between sources of information.
Driscoll: I don't recall seeing any data that could support that as a general
statement.
Condon: That "first flush" thing is beated to death! It is a common occurr-
ence; but, because it is common, people like to consider it a truism for all
storm events. There are reports that show, for a given system, that sometimes
first flush occurs and sometimes it doesn't. A report by Rex Chainbelt Com-
pany for Milwaukee illustrates this and effects of antecedent events and the
orientation of a storm path to the collection system.
Question (Lumb): I have a few comments on the Rational Formula Coefficient
that you discussed. I noticed that when you showed data for Durham, N.C.,
you had runoff coefficients ranging from 0.1 to about 0.9. In your analysis,
you decided that the variation was due mostly to the poor precipitation
records or that the gaging coverage was not adequate. My experience indicates
that there are several factors that determine what that runoff coefficient
will be. These are the initial soil moisture condition when the rainfall
starts, the duration of the rainfall, and the amount of rainfall. The latter
two exhibit variations that are much greater than the variation found in pre-
cipitation coverage. It is unfortunate that hydrolegists are plagued with
this "runoff coefficient". It isn't very good and it has limitations. Its
use has, basically, been limited to a 10-year storm, or very large storms,
over small basins. Use of the Rational Method does not represent hydrology
very well. In the Kansas City area, when looking at data for a 5-inch rainfall,
1-146
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it may be that none of the precipitation would run off or possibly 807= may
run off--depending upon the antecedent conditions. If we're going to use a
straight coefficient, say an average between those two, we will get gross
errors in our analysis of the stormwater runoff. If we assume an average
condition, our critical conditions quite often might be the summer low flows.
If we use an average runoff coefficient, we may compute two or three times
the runoff in our modeling as occurred in the real world. This would end up
concluding that possibly we cannot do anything about stormwater runoff. I
think we have to be very careful when we talk about, or use, this rational
coefficient.
Driscoll: Your points are well taken and whether the relative effect of the
rain gage density versus the local effects vary from area to area depends
upon how much of the area is soil that can be dried out and how much is pave-
ment. There is no substitute to gain the best handle on the effects on the
local situation. I accept your comments. My generalization may have been a
little poor, but we get back to the same point—that you have to use the
Rational Formula with consideration and try to relate it to your local situ-
ation. I guess the other point is that there may be so much going on that the
inherent limitations of this very simple approach may be appropriate for the
broad-scale planning studies that we want to make. We have to look at the
significance in each case.
Question (Lumb): Assuming that you have a time variability in BOD loading,
how can you input this into a steady state model, such as you spoke of before,
inputing an average BOD loading?
Driscoll: If you are trying to establish a time variable effect, you can't
put it into a steady state model unless you do it in some steady state fashion
and recognize that you sre getting a steady state approximation to what may
be a totally different time variable situation.
1-147
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Question (Lumb): Is it justified at all, then, to use steady state analysis
in this type of situation?
Driscoll: Perhaps, on a first cut, one might consider making a steady state
analysis, plugging in the order of point-source loads, the order of storm loads,
if they were an average, and several others such as agricultural load and what-
not to get a sense of the relative significance of each source on water quality.
If your storm loads are significant, it is a transient thing and you can't use
a steady state analysis to identify what's going on.
Question: We had considerable discussions so far on mathematical modeling
and data collection and sampling, but what do you do in an area where you have
one first-order meteorological station for 1,600 square miles and, maybe, 5
farmers that collect rain gage information when they get around to it, and ex-
isting water quality information is insufficient for any type of mathematical
model and is generally unrelated to storm events at all?
Driscoll: If you want to have an effective plainning program, you'have to
get some data.
Comment: The 208 program doesn't allow time for this.
Driscoll: You can do a good amount within that time frame.
Comment: Trying to make significant predictions on one or two years data is
difficult.
Driscoll: I guess my point is that the approach you have to take is to put
gages in to identify the runoff and waste land properties of the area that
you can relate to rainfall. Then to do your analysis, you would never use
those two years of data. You would find a weather bureau station located
close by that had 30 or 40 years data and use that to define the rainfall
statistics.
Comment: But you just mentioned that one station will be by-passed by a sig-
nificant number of storms.
T-148
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Driscoll: That's right, but it's better than trying to work with only two
years of data.
Comment: I'm just wondering, under those circumstances, what advantages any
sort of mathematical modeling would have. Wouldn't the general local knowledge
of people familiar with the area's characteristics and waters, and purely
qualitative evaluations be equally valuable, perhaps even more so?
Driscoll: That would certainly be valuable; but, to me, in a complex situa-
tion where there are water quality problems due to rainfall, point sources,
etc., an evaluation like that doesn't really give you much basis for making
competent judgements on specific things that you can do.
Comment: I'm comparing it though, with a one-year sampling period. For some
of us who have to turn out the final plan and make initial assessments by
early 1977, there really isn't much more than a year to go.
Driscoll: I would tend to look at the 208 planning process. It's going to
be of value for the area. It is a step toward telling them what's the most
effective way to go about achieving the water quality objectives. I would
look at it as a staged approach. You answer the questions that you can answer
in the two years and you set a base for following the questions that you will
attempt to answer later.
Comment: This doen't exactly solve the two-year 208 problem, though.
Driscoll: So you do a two-year study.' Some of your conclusions will be very
fuzzy and some will be very positive. And if you draw a conclusion about rain-
fall and urban storm runoff with one gage in the state, you say "this is the
conclusion but this is the limitation of it." Then, when somebody comes to
put up money they're going to think twice about how fast they ought to pour
money into that.
Comment: My point was—when you start dealing with mathemetical models you
have numbers, and numbers have a tendency to be precise. The general public
1-149
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gets an idea from this 'chat, because you have a certain number, the number is
reliable. They feel this way Ear more than the people working with it do.
I'm just wondering how much value there is in trying to do any sort of model-
ing in the time constraint, in view of financial constraints and the general
characteristics of the existing situation.
Driscoll: There can be significant value, I believe. I also agree with you
that one must make certain that more isn't read into these calculations than
is appropriate.
Question: In terms of analysis of the rain gage densities, is this purely a
theoretical analysis, or have you actually looked at data on different rain
gage densities?
Driscoll'. We're in the process of looking at that, and what I presented was
the preliminary results of ths.t effort. We're looking at empirical data. We
are hoping to extract informal ion from all of the studies around the country
and to piece it together.
Question: What is the largest, rain, gage density you found in practical use?
What concept are you using for distribution of gages?
Driscol1: I'm not using anything. I'm looking at published data from studies
that analyze the storm problem for quality and flow, and just working empiri-
cally back to what it was.
Question (Dan Goodwin): Assume you were attempting to define a design
storm. Assume it is a storm beyond which, if you had a violation of water
quality standards, you wouldn't worry about it. But, you'd simply write it
off as something you could not cope with today or within the next 20 years.
What parameters would you look at in selecting that design storm?
Driscoll: I would follow the technique we're trying to develop in a manual
for T'PA. There isn't any particular line that one draws. One sets up an
analysis such that; we can identify the frequency of violation of a standard
with the cost of an. alternative. You have a trade-off.
1-150
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Question (Goodwin): Are you suggesting an approach other than applying
"uniform" standards for an area, region, or for the country?
Driscoll: I am saying that, in each case, you must decide what standard you
will require and what percent of the time it must be met.
Question (Goodwin): Do you have any thoughts on performing the modeling exer-
cise to achieve the trade-off in storm events between intensity and total
rainfall for different kinds of situations?
Driscoll: Yes, I do. The thing to do would be to analyze each of the possible
storms, sequentially. Then, decide which is the worse storm. We are trying
to develop an approach that cuts through this. It looks, statistically, at
the relationships between rainfall characteristics (intensity, duration, and
the interval between rainstorms) and ties this in to properties of the re-
ceiving waters. We feel that can develop an approach that enables one to
operate from a rainfall record into violation frequencies in the receiving
water. Then, you may wish to make a more precise study, later.
Comment (Lumb): My experience is that it is next to impossible to go from
precipitation probabilities to runoff probabilities. I am sure that it is
also equally impossible to go from precipitation probabilities to water quality
probabilities. You suggested picking a number of. different storms for analysis.
It appears that you are talking about continuous simulation. Would you care
to comment on whether this is advisable, or needed?
Driscoll: We will tend to study smaller urban areas. This may modify the
rainfall-runoff probability.
Comment (Lumb): I think you would have more problems with small areas. You
would have combined probabilities of the rainfall, the antecedent conditions
and flow of the receiving water. As yet, no one has demonstrated the ability
to combine these probabilities.
Driscoll: The receiving water flow may have to be handled separately and be
separately interfaced with the output.
1-151
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Comment (Condon): Earlier, I gave a short answer to the man who asked about
the first flush, and my answer was too short. When we set sampling programs,
we always had very short time increments between the sampling periods in the
beginning. We did have changes in concentration. The reason for the short
time increments was not only to identify the first flush, but also because
most of the pollutant loads, on an annual basis, come from high-frequency, low
intensity rainstorms. We didn't want to miss these, so we set very short in-
crements. Our idea is that if you get the first one and one-half hours, you
have the best, and the most, you can get. You can go by flow measurements
for anything later than that because you will have an average concentration.
Although the flow does overweigh the total mass emission, you can use the
flow with the earlier concentration.
Driscoll: I didn't mean to iirply that we would miss the half-hour sampling
interval. You would start sarr.pling as soon as the storm starts. But, you
can composite the samples over a one-hour period.
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QUESTIONS AND ANSWERS
(Following Eugene Driscoll's paper "Runoff and Quality")
Comment (Francis Condon, EPA, Washington, D.C.): In my talk this morning in
respect to the first flush, I was talking about the frequency of sampling in
trying to get quantitative data. I would like to give you some insight into
some of the information that I am trying to put together. The graph you showed
and what you said was perfectly true, but it was a 14-hour storm. Perhaps,
one-hour composite samples would be worthwhile in reducing the amount of ana-
lytical work required. I did a study on the Ohio River Valley. Over 80% of
the pollutant load, on an annual basis, from urban areas came from storms that
produced less than 0.1 inch of precipation with overflow periods of less than
two hours duration. I am saying that we should really have a higher number of
samples and that samples should be taken more frequently in the early part of
any storm. Because it is a random thing, you don't know how long the discharge
is going to last. So, make sure that you catch the frequent, low-intensity
storms. Secondly, although we do not yet have enough data, I think you can
get statistical relationships between different pollutants for a particular
urban area if you take enough discreet samples. Then, later on, you may only
have to sample for one pollutant—and then predict, with reliability, what the
others pollutants are. Finally, I thought that the plot you showed on float-
ables, depicting daily or hourly variation, was excellent. I think that you
must exercise care. For example, you pointed out that, because their cumu-
lative effect is evident only in years or decades, you only have to be concerned
about the annual load of nutrients. You must still collect some hourly data
in order to multiply it through with the runoff events to compute the annual
load. You gave the impression that you only have to take one or two samples
per year for nutrients. I don't believe you meant that. I hope you didn't!
1-153
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Although those events produce long-term, long-range degradation, you must still
have the base of hourly information on rainfall-runoff relationships to be able
to predict an annual load.
Driscoll: I certainly agree with what you said about nutrients and the time
scales. Those time and space scales are guides. It is a perspective.I certainly
did not mean to imply that you should measure nutrients only once per year.
You must measure it often; but in analyzing the data, you may only have to look
at an annual or monthly average ~-oad. My point was that one doesn't have to
know the amount of nitrogen or phosphorus that is entering a stream, minute-
by-minute or hour-by-hour.. I want to know what the cumulative effect is, storm-
by-storm or month-by-month. Your second point, concerned the possibilities for
developing statistical relationships between different pollutants as they are
tied in to inflow to streams. This would be very good. How well this can be
done is a function of how much data is available. Your third point concerned
sampling frequency. 1 coxildn't agree with you more—that we don't want to miss
those one-hour storms, whether they are low intensity or high intensity, short-
duration storms, like thunderstorms. For the level of definition of a load,
in terms of most receiving waters, it may not be important to know how the load
enters a stream at 10-minute intervals. It may be entirely adequate to know
what the average of that Load is over an hour's period. A big chunk of the
waste load is going to be discharged within the first hour after it stops
raining, simply because the majority of rainstorms don't last very long. The
sampling technique, and how you put together your composite sample, is impor-
tant. In many cases, you won't need the internal definition of the variability
within an hour--as long as you have the hour period represented appropriately.
Is that clear?
Question (Richard Field, EPA): For treatment and control design, wouldn't
1-154
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you want to use shorter sampling intervals than for determining receiving
stream impacts?
Driscoll: It is likely that considerations of treatment devices will require
shorter levels of definition than will the receiving waters.
Comment (Field): If we think only in terms of gross receiving water impacts,
we might lose certain data that we want later on for more detailed design.
Drjjscjal^: I don't have a precise answer now as to what the breakoff on the
treatment device is. I doubt very much that it will be 5-minute or 10-minute
intervals.
Question (Field): There are certain catchments in highly-urbanized areas
and combined-sewer areas having 50 acres or less area. The drainage may be
into potentially small streams where, during a summer storm, you can get an
entire effect in, say, 15 or 20 minutes. So, shouldn't the sampling frequency
be set tip with those considerations 5.n mind; i. e., what does the receiving
water look like, and what is the size of the drainage area and the time of
concentration? You may want more definition that %-hour composite samples
can provide.
Driscoll: That is absolutely right. The whole point to all this is that
these comments almost have to be generalizations. To really determine what
is appropriate in any particular area requires that you address the local
situation and apply these constraints and this perspective within that frame-
work.
Comment (Field): I would like to discuss the first-flush effect that you
discussed earlier. You showed a graph for mass emissions where it was indi-
cated that there was not a first-flush effect. You indicated that the first-
flush is more a function of a primary variable "Q". You indicated that this
is more indicative of separate-sewered areas, which it is. But, it is easier
to pick up the first-flush effect in the combined-sewer areas where there is
1-155
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a chance of dry-weather buildup in a low-gradient sewer serving impervious
land areas where there is more dust and dirt accumulation during antecedent
dry periods. A thing that you mentioned that disturbs me a little is "sample
at outfalls". I would like to indicate the difference between an outfall and a
point located a little upstream of the diversion weir or orifice. The outfall
will get the overflow, or excess. In many areas there is a stratification
phenomen. This is more true in combined sewer areas. At the lower reaches
of the sewer flow, there is higher concentration of pollutants. Future plans
may do away with such a dam, aid by sampling only the outfall a significant
solids load may be missed. This is just a word of caution as to potential
differences which can readily exist in loadings.
Driscoll: Your point is well taken. I intended to refer to the outlet of the
particular drainage area.
1-156
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APPLICATIONS OF STORMWATER MANAGEMENT MODELS
by
John A. Lager, Vice President
Metcalf & Eddy, Inc., Palo Alto, California
INTRODUCTION
Stormwater management models offer one of the most useful
tools for system evaluations; however, the uninitiated may
find them an unbearable load of data requirements, programming
bugs, and misunderstanding. In this lecture we will describe
a model selection procedure designed to avoid the more common
problem areas, briefly present the array of available models,
and compare by example the alternatives of simplified and
dynamic modeling applications.
Planning vs. Design Objectives
As used in this presentation the planner is assumed to be
viewing broad and significantly different development senarios,
perhaps basin-wide in scope; whereas the designer is more
closely allied to casting his solution into concrete. Obviously,
the modeling precision requirements of the latter is much more
demanding; however, the range of possibilities to be evaluated
is also more restricted.
Modeling Limitations
Models follow operating rules without exception or inter-
pretation and can process mountains of data with relative
ease. The developer sets the rules (and in most cases options),
and the user furnishes the data and is left with the results.
1-157
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That is the package, plain and simple.
In deciding whether or not to model, the potential user
should assess this process closely. What are the data he
is prepared to give or invest in? What are the operating
rules that he is willing to live by? Where are the mountains
he wishes to overcome? What will he do with the results?
The faults are as obvious as the potential benefits—weak or
incorrect rule(s), erroneous or inadequate data, poorly
selected or defined mountains, unusable or indeterminant
results (i.e., what is the message?). A. poor data base can-
not be overcome by a very sophisticated model.
SELECTION PROCEDURE
Stormwater management models vary significantly in degree of
complexity, solution technique, and costs. It is important,
therefore, that the user know beforehand the expected model
performance and utility of the results.
Definition of Study Objectives
Study objectives should be specific. Why? To facilitate
communication, focus of effort, and commitment. For example,
if the study objective is simply to
Comply with the requirements of PL 92-500
it is unlikely that any two people in the chain of authority
will have the same idea in mind except by default. On the
other hand, if the objective were amplified to
assess the relative impact of the non-point discharges
of urban runoff from within the city limits of
Boomtown to other controllable sources on Segment V
of the High Flow River with respect, to organic loadings,
given that loadings from Segment VI to V will not
change from today's level. It is intended that load-
ings be assessed for two seasonal occurrences...
1-158
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the chance of common understanding would be greatly improved,
and the specifics of model requirements and applicability
would be well underway to identification.
The following, then, are the types of information that require
definition in the model selection phase.
Improve What, How Much, and Where. Suppose a city is investi-
gating the use of polymers to reduce pipeline friction and
thereby increase interception of flows for treatment at the dry-
weather plant, as opposed to constructing a satellite overflow
treatment facility. Models operating off the same input data
(hydrology, catchment characteristics, pipe networks, etc.)
would offer an excellent tool for weighing the two alternatives.
Simplified models could be used to estimate the expected
number of occurrences annually before and after improvements,
and detailed dynamic models could identify design criteria
for specific critical events.
Other representative questions that should be considered in
setting the study objectives include the following:
1. Is flooding the major consideration? If so, then the
use of a dynamic backwater model is essential. Why?
Because flooding is the result of a system's
inability to react to a specific storm event in the
the required time interval (i.e., bottlenecks).
2. Is loading on the receiving stream the control?
If so, is the nature of the impact short term
(Vindicating the need for dynamic modeling) or long
term (simple models--!,e., Streeter-Phelps—
may suffice).
3. Is there a repetitive, defined occurrence that is
to be abated? For example, an overflow occurrence
to be reduced to keep bathing beaches open for the
maximum number of days in season? Note that in
bacterial contamination the occurrence or nonoccur-
rence of an overflow is more important than its
duration.
1-159
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4. What are the keys to the system's performance
today? A major study objective may be to deter-
mine what makes the system respond the way it does.
That is, what and where are the controls and how
do they react?
5. Are there available facilities that are not being
put to maximum use or to effective use? These
may dictate some trial criteria for abatement
schemes.
6. Are the funds available on the basis of the ability
to sell the program? This again is a question of
communications and timing.
7. What is the balance between the known (given) data
and the assumptions? How will this change over
time? An exquisite model running on a series of
assumptions may yield no better results than a
simple model run on the same base data.
Required Sensitivity of Results. If the ranges of given
variables are known, then the model selected must be suffi-
ciently sensitive to display output differences within such
ranges. Also, the modeling requirements might be quite
different if the model's purpose is to locate points on the
system where monitoring information would be most beneficial,
as opposed to additionally projecting expected flow and
concentration ranges at such locations.
Other Constraints. Other constraints include the user or
reviewer, the boundaries of the investigation (including
boundary transfers), timing and budget, and operating personnel
and hardware. In order to be implemented, the results or
operations of the model must be made known to, and approved
by, some person or persons. What are his requirements and
needs? What are the milestone dates of the project, and what
information must be deliverable by these dates? Will the budget
resources support the study objectives? Are direct interfaces
1-160
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with other current modeling/data management operations
essential or desirable? Finally, the output must be
recognizable and usable in terms that the client can easily
relate to and work with, for after all, he has to sell it.
Above all, modeling is an art and should be carried out only
under the direct supervision of a professional.
Assessment of Existing Data
Models require input data upon which to operate, whether
the data are real or fabricated. Also, the quantity and
quality of the data base is likely to change over the
course of the work. To select model programs effectively
requires that the available data base strengths, weaknesses,
and dynamics be identified beforehand.
Static or Fixed Data. This data is available in the early
stages of a project and includes such data as the plans and
specifications of the system, historical rainfall and stream
flow records, census tract enumerations, planning and zoning
documents, aerial photographs, treatment plant records, files
on trouble calls and system maintenance, prior studies and
reports, monitoring records, and state-of-the-art literature.
Generally, the most prized data represent cause-effect
relationships. Examples might include changes in plant
inflow characteristics between dry- and wet-weather periods;
measured rainfall-runoff-quality relationships; intensive
stream surveys correlated with development, treatment per-
formance, and ideally, storm occurrences; and documentation
as to the time, location, and duration of overflows.
1-161
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Dynamic or Progressively Increasing Data. These are the data
that will become available during and subsequent to the study.
To what extent can this effort be modified or redirected to
suit the needs of a specific model? At what milestone points
can "midpoint" corrections be made both in the modeling and
data gathering programs? A major advantage of dynamic model-
ing is that it may identify the key nodes that control or
directly reflect system efficiency. Concentrating dynamic
data gathering at these nodes may be far more cost effective
than, say, a shotgun or intuitive approach.
As a note of caution in setting a value on the dynamic
data: one storm does not represent a season, and one season
does not represent a historical record; however, the ability
or inability of a quantity of flow to get from point A to
point B may be both significant and repetitive.
Assessment of Data Needs and Assumptions
Each model has a specific set of data requirements. Comparing
these with the previously identified given data base will
identify the proportions; of the assumed data base or the
dependency of the results on default values. It should be
noted that the data requirements for a specific dynamic model
may be so exhaustive as to require several months to collect,
check, and apply. As an alternative, or during the interim
period, simplified models may be run to identify gross sen-
sitivities and possible critical data gathering points or
information.
Statics. Typical static: assumptions may include friction
factors, infiltration ratios, retention storage, daily flow
cycles, pre-storm conditions, diffusion coefficients, decay
and replenishment rates, boundary exchanges, accounting for
1-162
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non-modeling discharges, etc.
Dynamics. Dynamic assumptions may include the computational
time steps, the "design" event (may be approached through
trial and error executions), treatment-cost efficiencies,
imperviousness and directly contributing impervious areas,
as well as any of static assumptions where special effort is
to be taken. The point is to make a realistic, pre-applica-
tion appraisal of what types of sensitivity analyses are
likely to be performed and whether or not they are likely to
be converging.
Array of Model Characteristics
Mathematical model usage in stormwater management is basic-
ally a creation of the last decade, and application experi-
ence is even more limited (SWMM was first marketed in 1971).
Significantly, the more sophisticated models are in a
continuous state of refinement and modification as new uses
are attempted or requirements are identified. Documenta-
tion, availability, consultation advice, and record of use
are equally variable and changing.
Where to Find Information. A comprehensive evaluation of
stormwater management models is contained in the study,
"Evaluation of Mathematical Models for Engineering Assess-
ment, Control, Planning, and Design of Storm and Combined
Sewerage Systems," prepared by Battelle Memorial Institute
for EPA [1]. The complete report covers model reviews, model
selection criteria, detailed descriptions of selected models,
test data and results, cost comparisons, and a source listing.
Selected summaries from this and other recent comparative
1-163
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evaluations [2, 3] are shown in Tables 1, 2, and 3 along
with the identified references. The models are separable
by function (planning, design, operation) and by degree
of precision (simple, intermediate, and complex). The
purpose in presenting the three similar listings is to
illustrate the perspectives of these experienced users.
What (Engineering-Hydraulic) Processes are Being Simulated?
The user should screen candidate model documentation to
identify what processes or devices are being simulated and
linked and with what degree of sophistication. Does the
model focus suit the need focus? For example, the Hydrocomp
Model is a multigeneration descendent of the Stanford Water-
shed Model. The original model dealt largely with unimproved
watersheds to determine; yields, streamflows, and flood
characteristics. Thus, its strengths may be presumed to lie
in representation of the natural hydrologic cycle. On the
other hand, the WRE-SWMM transport model modifications were
developed specifically for complex urban pipe networks where
flow reversals, backwaters, and special diversions are not
uncommon. The differentiation is obvious.
Getting from rainfall to runoff quantities may be as simple
a process as applying a direct percentage (perhaps not a
bad assumption when the percent imperviousness is high), or
it may be a sophisticated accounting of depression storage,
infiltration rates, and surface and channel flows. Or it
may be an even more sophisticated accounting of soil types
and moisture content, vegetation, ground slopes, air tempera-
ture, wind direction, etc.
A good model should be able to cope not only with "normal"
conditions but the; abnormal, such as bypassing, surcharging,
1-164
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Table 1. MODEL CHARACTERISTICS BY
BRANDSTETTBR [i]
e o c
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i w i w |
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O ©I©
i w i _.j__;_
9[©' |oj»j
o 19" i a i ot
oi ®,oje:o
a o o
J9J9J9JO
»!9 I ©; 9
9|9 1 i 9
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t -1 --
9ieie » o o ! ®
— f -i—4 --t- ' * ' -' J- • f
1 ! I i ! I I !«: i*i®'®
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I 9 ;O
fe o i » e !ei9
r • —t—-t- -j r t -r -'
i OI 101 9!
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CHARAC1EBISTICS
TABLE I (CfWT'O)
1-165
-------
Table 2. MODEL CHARACTERISTICS BY
HUBER [2]
IDENTIFICATION OF CURRENT URBAN RUNOFF MODELS
AND REPRESENTATIVE REFERENCES
I. Rational Method ASCF.WFCF. Dengn t*d Conitnif lion of Sanitary «mf Storm
Xtwtn, ASCF, 19*9
ft, CUcAfo A.L.Tholjn *nj r.J, k.tftf, ''l^ Hy Jf»l.*y of I rban Runoff.1*
J.Sin. t»g £Jrv. ASCI. V..I »S No SA3. Mir. l'»59
JC UnflHrdroptph f.S, Ucl«i>n, "Unit H).!rr.,f*f>li Chirj. Umiui fcr i,,,-wef«J
A/«« "/. //>J. Du J5tf Vul 81. N., (IYJ MJI Ool
4. Uftil *UM N S. Gnu >l at . "Mrit..ru|1tjn V ^ur Inirlt.^n, • S*»u-m>,"
4. RRL
1. UIT
*p, "Storm Sewer Drtisn
" | f \ HI 7:-O6S,Ocl. I
ti . >u.fc I ¥73
Mwdtl _
y Corpi of
- An F«l««-
,
D«pt. of CivJ t-ntinrrt
"Urban Kunott Slur.
STORM" Hydrology
S*j»t. 1973
J.B. Stall ind M.L. Tn
lioit Of lh< RRL Mcth
llaiky. BM.. Kfk.n%. ..
EhslftbvtctJ ModtU.f Cjlchmrnl n>nJfmtj," MIT 'arsons
Lkboritoiy Report No. UJ, Dec 1 9 TO
A. Bfinditettct, K.L. ( n^d, und ft II. Oarlock. "A M»lhctnatlc»l
tlodd fur Optimum Design ind Cunlrolof Mttrop>l.Uo Wasi«-
( Mj
*. EPA-SWMM
10. WRE-SWMM
Jf rmntt S
No. «,U«c. 1973
MctcjU and I dJy, U
11074 DOC 07 lo 10/1 I.July IV7I
R. P. ShuNniki ind L A. K.ir^ncr.
nw," Iftfrfr Kttourcei ffitttrtl*. Vol. ».
rsity of Honda. Wner Rn<»urcdrocomp Inrornjiionjl. Inc . fjlu
B.C. Ycn/'Mtlhoduinptirur How hi dictio
Drainage Syit^mi," L'nucrsil) nf lltinuis. Wi
Report UlLC-WRC-OO73,Scpt. 1973
COMPARISON OF URBAN RUNOFF MODELS, MARCH 1974
Model
•Rational
Method
Chicago
Unit
Hydro-
graph
Unit
Pulse
STORM
RRL
MIT
BJttellc
EPA-SWMM
WRE-SWMM
Gncin-
nati (UCUR)
Dorsch
(HVM)
SOGREAH
Hydrocomp
Hlinob
OSS)
Sur-
face
Rout-
ing
Peak
Flows
Only
Yes
Yes
Ye*
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Qua!
Ity
Sewer Rout
Routing ing
Peak No
Flows
Only
No No
In com- No
bination
with
surface
In com- No
bination
with
surface
In com- Yes
bination
with
surface
Yes No
No No
Yes Yes
Yes Yes
Yes Yes
Yes Yes
Yes No
Yes 1
Yes Yes.
Yes No
Degree of Degree of Accu- Flex- Re- Degree of
Sophisti- Sophisti- ale ibility of Explicit ceiv- Call
cation of cation of vlodvl- Modeling Modeling Treat- ing bration/
Surface Sewer ing of of Sewer of In- ment Model Venfi-
Flow How Sur- Compo- System Model- Avail- cation
Routing Routing charging nents Storage ing able Required
Low
Moderate
Low
Low-
Moderate
Low
Moderate
High
Low
High
High
High
High
High
Low
NA
Low
Low-
Moderate
Low
Low-
Moderate
NA
Moderate
Moderate
High
Low'
High
High
Moderate Moderate
Moderate
High
No
NA
No
No
No
No
NA
No
No
Yes
No
Yes
Yes
No
No
Low
NA
Low
Low
Low
Low
NA
Moderate
High
High
Low
High
Kigh
Low
Low
No
NA
No
No
No
No
NA
Yes
Yes
No
No
1
t
No
No
NA
NA
NA
NA
Yes
NA
NA
No
Yes
Yes
No
NA
t
No
NA
No
No
No
No
No
No
No
No
Yes
Yes
No
Yes
Yes
Yes
No
Usually not
Moderate
High
High ,
Low
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
Moderate
High
Moderate
Docu- Data
Simulation Avail- men- Require-
Period ability tation ments
Individual Non- Good
Individual Non- Fair
storms proprietary
Individual Non- Fair
storms proprietary
Individual Non- Fair
storms proprietary
Long term Non- Good
proprietary
Individual Non- Good
storms proprietary
Individual Proprietary Fair
storms
Individual Non- Poor
storms proprietary
Individual Non- Good
storms proprietary
Individual Proprietary Poor
storms
Individual Non- Fair
Individual proprietary
norms Proprietary Poor
Individual
storms or
stparjlc Proprietary Poor
Individual
Indmdual f,op,i»>,y Fair
storms or
long term
Individual Non- Good
ttorms proprietary
Low
Moderate
Modente
Moderate
Moderate
Moderate
Moderate
Moderate
Extensive
Extensive
Extensive
Extensive
Extensive
Extensive
Extensive
1-166
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Table 3. MODEL CHARACTERISTICS BY
ROESNER [3]
UTILITY OF URBAN RUNOFF MODELS FOR VARIOUS STAGES OF
STORK>'ATER MANAGEMENT PLANNING
STORM
MITCAT HYDROCOMP EPA SWMM
SF-WRE
Large-Scale Planning
(Alternative Screening)
Excellent
Good
Good
Poor
Poor
Intermediate Scale
Planning
Poor
Excellent Excellent Excellent Excellent*
Detailed Planning/Analysis
(No Significant Backwater)
Poor
Excellent
Fair
Excellent Excellent
Detailed Planning/Analysis
(Complex Drainage Networks)
Runoff Quality Simulation
Flow Computation
Poor
Yes
Rational
Formula
Poor
No
Kinematic
Wave
Poor
Yes
Kinematic
Wave
Fair
Yes
Kinematic
Wave +
Planning
Equ. with
Dynamic
Continuity
Excellent
Yes
Kinematic
Wave +
Complete
Dynamic Flow
Equations
*The Runoff Model is best suited for these applications.
KitK.sa$ «o teen ACQUISITION
- Continued
on - t ropr1«t*ry
Kydrococp Intern*Hon*l, Inc., P*lo Alto, CiUforni*
. .
Rtrf fork, K.I., April 1>7*.
tfj»U_j_on - In Public Oc^ln
1. K/drolosle £nsire*ring UnUr/Corps of Eng1"**".
[Uv1». Utiforni*
2. Viwr Reiourcii E^slneer*. Wilnat Creek, aiifoml*
HeteiU 1 f. 133. OectTier 1370.
Acd. W.iMng-^n.
1-167
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overbank flooding, etc., without losing flow-mass contiuity
or tripping out.
MODELING FOR RESULTS
The success or failure of a modeling attempt can be judged
only by the buyer. Did he get the information he needed
when he needed it? For the price he expected to pay for it?
If an initial attempt was a failure, where did it go wrong--
objectives, data base, model capabilities, assumptions? If
it was successful, where; does the credit lie?
Decision Output D_ata
The display, listing, or packaging of the output data may
be as important to the decision maker as the data itself.
Are the output values to be accepted because they display
eight significant figures or because the cause and effect
relationships are visible, reasonable, arid capable of
verification? If the output is voluminous, where are the
checks and balances? How is it displayed? If part of the
computation was made outside the game rules, how is it
signaled? Corrected? If a trace back into the simulation
is required, can one obtain intermediate results at a specific
location in the system? At a specific point in the computa-
tions? How about restarts to avoid repetitious computations?
A point, perhaps understressed heretofore, is the value of
accuracy in the results. A dynamic model may give the
impression of a very true result for a clean, circular
conduit where, in fact, 50 percent of the line is in a state
of collapse, subsided, or filled with debris. How valuable
is representing the response of a new system when you are
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stuck with the one you have? Further, if the transfer of
quality data from Transport or Storage to Receive is to be
accomplished in hourly blocks, is it necessary that it be
compared at 5-minute intervals? The answer, of course,
goes back to the study objectives as to what is to be im-
proved, how much, and where.
Building Block in Continuing Prcxjiram
One of the advantages of modeling is that almost as much
value might be obtained from a technically failed run as
from a successful one. Why? Because the effort of system
analysis that goes into preparing for and executing a run
forces the issue into areas that have traditionally fallen
into neglect as lost items within a city budget. In
selecting a model, the user should assess its impact on his
broader continuing program. If the present objectives are
met, what is the next step? Will models again be a require-
ment? Should the experience and data base be built up now
in preparation?
Does It Fit
In summing up all of the above selection criteria, it is
seen that there are both choices and opportunities in
modeling urban stormwater runoff. Finding the model of best
fit is best approached by a systematic appraisal, such as
the one outlined herein, with emphasis on the pre-selection
definition of study objectives.
COMPARATIVE EXAMPLES
In the author's experience, there are basically two levels
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of approach available: the simplified and the detailed.
The advantage is that, when understood, they can and should
be entirely complementary. The advantage of the simplified
models is their ability to process long periods of record
and broad areal coverage at low cost. The advantage of the
detailed models is their ability to make a comprehensive
analysis of singular events and systems with a corresponding
increase in accuracy when supported by a viable data base.
In planning studies, the simplified models offer a flexible
screening device to identify consequential storm events and
potentially attractive alternatives. The detailed models
permit the necessary follow-up and technical evaluation
between competing plans.
Simplified Models
Simplified math models or their equivalent analyses are
needed for three reasons:
• To introduce time and probability to
stormwater analyses
• To promote total system consciousness on
the part of the user or reviewer
• To establish size-effectiveness relationships
Just as time and probability analyses are important in
sizing water supply impoundments and safe yields, they are--
or should be—equally inportant in determining the effective
use of stormwater facilities. Since total capture is not a
necessary goal, as oppossed to flood control works, there is
greater latitude in facility sizing and staged implementation,
The trick is determining the relative merits of alternatives,
1-170
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a task for which modeling is ideally suited.
Subsystems. There are typically three subsystems in simpli-
fied models: (.1 ) rainfall characterization, (2) storage-
treatment balance, and !3) discharge-receiving water response.
Rainfalj.__Cha£^cterj._z_ati_qn - Rainfall characterization is
basicalTy" a sorting and ranking of historical rainfall
data from local gages. It requires a simple but precise
storm event definition to permit disassociation of
chronological sequence for statistical analysis. Official
Weather Bureau recordings of hourly data are a practical
data source. It is useful in determining the recurrence
frequency of particular storm events or event series.
Storage-Treatment Balance - Storage-treatment balance
models take historic rainfall data in chronological sequence
as input and log quantities, times, and durations of over-
flows for selected storage-treatment, combinations.
Discharge-Receiving Water Response - Discharge-receiving
water response models apply significant quality character-
istics to the discharges and predict their behavior in the
receiving stream. The latter model can be very complex,
particularly in an estuarine environment.
The storage-treatment balance concept is shown in Figure 1.
In the simulation, historical rainfall is read in chrono-
logical order, converted by a factor (coefficient of runoff)
into runoff, and stored in a specified volume which is
emptying at a. specified rate. When the runoff exceeds the
combined storage-treatment rate, an overflow occurs. Initial
run" a»'» extent£""1 on a daily basis for the full period of
rccojt.c -""id over the range of the viable alternatives.
For periods of greatest interest, those producing overflows,
repeat runs may be cycled cm an hourly basis to develop a
hydrocnaph and ref:;»>e i'>? ?f'H~'cp L^atTrient simulation.
1-171
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The program is used by varying the storage capacity and
treatment rates, and noting the changes in overflow occur-
rences and durations. Input variables at the present time
are simply the land area, runoff coefficient, storage capac-
ity, and treatment rate.
R
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STORAGE
EFFLUENT
Dynamic Models
Figure 1. CONCEPT
Dynamic models are typified by the Stormwater Management
Model (SWMiM) developed fo:r the EPA by Iletcalf & Eddy, T7ater
Resources Engineers, and ~he University of Florida in 1971.
They are capable of modeling everv qtep in the rainfall-runoff-
T-172
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treatment and discharge process in both quantity and quality.
Single events are modeled with rainfall input from one or
several gages at 5-minute intervals. Runoff begins with
overland flow, infiltration and ponding, and proceeds as
gutter flow and through a detailed simulated collection
system to points of storage, treatment and overflow. Con-
tinuous hydrographs and pollutographs are computed and
ultimately disbursed in a dynamically responding receiving water.
Subsystems. Subsystems are in the form of programming blocks
as shown in Figure 2.
CONTROL
AND
SERVICE
BLOCK
COMPUTATIONAL
BLOCKS
DATA CARD
INPUT (TYPICAL)
"•
REQUIRES
NO
I OUTPUT FILE
1
REQUIRES
RUNOFF '
OUTPUT FILE 1
RUNOFF _f? TRANSPORT _-("?
BLOCK V> BLOCK ~ \_/
'
i
t
REQUIRES 1
TRANSPORT I
OUTPUT FILE
STORAGE J^~?
BLOCK ~ \^
1 ^-OUTPUT FILE .i 1
T CREATED T T
, ' -, TYPICAL / 1 -, x ' „
ANY OUT?VT
'""* to
REOUlRtS" ~1
STORAGE OR
TRANSPORT !
OUTPUT FILE I
1
RECEIVING WATER
&L.OCK
-b
^-,
Figure 2. DYNAMIC PROGRAMMING ROUTINE
The output of each computational block is a similarly formatted
tape file which can be input to any other computational block.
The advantages of a dynamic model is that they are true
simulations—pipes, chambers, and surface depressions fill and
draw in real time sequence, pollution is washed from the
ground and scoured from the pipes and channels, and finally,
pollutants spread and decay in the receiving waters. The
program is used by varying development patterns and land use,
simulating alternative relief lines, storage basins and treat-
ment systems and observing the effects on the receiving system.
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Typical Comprehensive Application and Costs
An example of a comprehensive, eight-step program [4] capable
of integrating both simplified and dynamic models is shown
in Figures 3 and 4.. In Step 1, the dynamic model is used
over selected test areas for calibration and setting repre-
sentative runoff and quality coefficients and response times.
In Steps 2 and 3, the simplified model is used to select
critical test hydrology and boundary conditions and to pro-
duce a modified SWMM model for total city coverage. In
Step 4, the dynamic model of the receiving waters is used
to identify key sampling needs which are carried out in
Step 5. In Step 6, the dynamic receiving water model is
reduced to a simplified model through the development of
influence coefficients. This permits the running of many
more alternative conditions at less cost. In Step 7, veri-
fication runs are made on both the dynamic and reduced models
using the new data sets. Finally, in Step 8, the alternative
plans are tested and ranked. In addition with the model
developed to this high state, phased implementation can be
assessed as the construction program progresses.
Costs. While there are no simple rules of thumb for esti-
mating the costs of applying stormwater models, there are
some records from past experience. For example, single
computer runs using the simplified model will take less than
a minute at a cost of $20 machine time. In the SWMM program,
single block runs take from 1 to 5 minutes; thus putting the
machine time cost for a single complete program in the
neighborhood of $100 to $500. Where complex estuaries or
extensive system surcharging are involved, single run costs
may run several times these values. These costs do not
include data gathering or calibration runs but simply machine
time.
1-174
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A comprehensive program such as that diagrammed and including
verification sampling could be expected to cost in the neigh-
borhood of $200,000 to $500,000, including engineering time.
Also, it is interesting to note that fees for directly apply-
ing river models, ranging in complexity from DOSAG to QUAL
and using only available data, ranged from about $20,000 to
$80,000 under EPA's program of a few years ago.
CONCLUSIONS
Stormwater management models are widely, but sometimes not
effectively, used across the nation today. It is strongly
believed that a detailed selection procedure and assessment
of objectives is necessary to lay out an effective modeling
program. Furthermore, experienced professional assistance
is the best guarantee of success, and even then, the degree
of success will be heavily dependent upon the real, on-site
data base.
In the author's judgement, the most cost-effective utili-
zation of modeling in stormwater management will bring
together both simplified and dynamic models in a single
complementary program.
ACKNOWLEDGEMENT
Much of the material for this presentation was drawn from
two previous papers by the author, presented at the EPA
and University of Massachusetts-sponsored short course on
Applications of Stormwater Management Models, July 28-
August 1, 1975. These papers were titled, "Selection of
Stormwater Management Models" anfl "Simplified Management Models
1- 177
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for Planning," and the readers are referred to the short
course proceedings for further information.
REFERENCES
1. Battelle Memorial Institute. Evaluation of Mathematical
Models for Engineering Assessment, Control, Planning,
and Design of Storm and Combined Sewerage Systems.
U.S. Environmental Protection Agency, Project No. CI-
73-0070.
2. Huber, W.C. Modeling for Storm Water Strategies.
APWA Reporter. May 1975.
3. Roesner, L.A. Personal communication to author.
June 1975.
4. Metcalf & Eddy, Inc. and Water Resources Engineers, Inc.
A proposal to the Government of the District of Columbia,
Department of Sanitary Engineering for Overflow Abate-
ment and Receiving Water Response. September 1971.
1-178
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QUESTIONS AND ANSWERS
(Following Mr. Lager's paper "Application of Stormwater Management Models")
Question (David Reynolds): Suspended solids is going to be a significant
problem in most 208 areas. Do you have any suggestions for techniques that
can be used to address suspended solids?
Lager; Version 2 of the EPA Model SWIM includes erosion and sediment trans-
port. It is available and it is documented.
Question; Did I understand you correctly—that in a well-run modeling program
one should expect to spend between $200,000 and $500,000 for headline people?
This is about *;1.00 per capita. We hear that the funding guideline was *>1.25
per capita for the entire program, not only for modeling. From what you say,
it appears that more funds than $1.25 per capita are needed to cover the whole
program.
Lager; The ?500,000, I think, is an accurate figure for the central complex.
But, I am not implying that it is proportioned to population. I would guess
that as much as one-fourth of the total funds allocation should be used for
modeling, another one-fourth for identifying alternatives and about 50% in
the area of implementation and legislation for getting the work into a signi-
ficant program.
Question; What does the cost figure include?
Lager; It includes going back into the system to pick up verification data at
key locations. This would represent 10°'3 of the budget. Tt is not a compre-
hensive evaluation of receiving water, which could take the whole budget figure
that I quoted.
Question (Dan Goodwin, Illinois): Have the suspended solids feature of the
SWIM Model ever been used successfully anywhere?
Lager; I believe it has been accepted by EPA. It was developed by the Uni-
versity of Florida.
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QUESTIONS AND ANSWERS
(Following John Lager's paper "Applications of Stormwater Management Models")
Question (Donald Hey, Hydrocomp): One report that you missed in terms of
model reviews was done by the U.S. Army Corps of Engineers Waterways Experi-
ment Station, dated August 1975,. It is probably the most complete compendium
of models I have seen. It can be obtained from Jerry Brown. Concerning some
aspects of previous discussions today, I strongly recommend that 208 agencies
get together and talk about their experiences. Some agencies have already de-
signed and implemented data collection programs. East St. Louis and Collins-
ville, Illinois are cases in point. The Triangle-J Planning Commission has
already gone through a data collection program. They have encountered many
of the problems that you have discussed. I strongly recommend that interested
people get together with these agencies to learn of their experience.
Lager: Publications and summaries, such as the publication of the Waterways
Experiment Station, are very valuable for persons who are screening all the
possibilities.
Question (Joe M. Bryan, Houston-Galveston Area Council): I would like you to
comment on the possibility of a desk-top analysis, using available data, for
reproducing the output-runoff blocks of the Stormwater management model and
transferring them to the receiving water block, skipping the transport block
and storage block.
Lager: If your problem is receiving-water oriented, don't get hung-up in the
collection system hydraulics—because the water is going to get there. You
never have a specific storm identically reproducing itself. What you want is
that type of direct transfer to go immediately into receiving water impact.
The fellow that is hung up with flooding problems on a -ollection system has
an entirely different: problem. The desk-top analysis is very valid when you
1-180
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look at the costs-about $ 20 per run. That's less than we will pay an
engineer for an hour's work. This type analysis is one that we are documenting
for EPA. This simplified method may give the results of 20 years of analysis
of some pet theory that you have for approaches, such as how much treatment
you should have for a specific area, whether a primary level of treatment
should be provided at the plant versus no treatment of the storm flow, and
progressive increases in treatment of storm flow. These simplified devices
are quite cost-effective to put to use if you recognize their limitations.
1-181
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QUESTION ANT) ANSWER PERIOD
(At the conclusion of the first day of seminar)
Question(Whitey Secor, Washington C.O.O.): Mr. Condon, you mentioned that
automatic liquid samplers are the best and that grab sampling is not parti-
cularly appropriate. Will you clarify that, please?
Condon; The simple reason is that if you depend upon grab samples someone
must go out and grab them! Unfortunately, because it rains any time of day
or night, the method is unreliable. Much important data is missed.
Question; Mr. Condon, you mentioned that street sweeping studies are quite
ineffective. Would you recommend that no street sweeping studies be done
under 208 planning studies?
Condon; No. The studies are useful. For qualitative studies, street sweep-
ing studies are useful. But, in quantitative studies, one begins to hesitate
to predict what comes out at the outfall on the basis of the street surface
samples.
Question; Mr. Condon, do you ,iave any advice on collecting samples at sites
where there is no electrical service available? And if one is considering
flow-activated devices, you ha^e a problem- You always have a vandalism prob-
lem. Do you have any advice on how to cope with these tilings?
Condon; I tried to mention th = trade-offs, and all those things you mentioned
enter into the trade-offs--in the equipment you select. I'm not going to push
for any specific equipment. We do have one report available that tries to i-
dentify all the samples. I had mentioned that the site selection is just as
important as equipment. The type equipment to be used influences site select-
ion. I have a whole checklist in a report. It includes sample capacity de-
pending upon the analysis you plan, the location, the kind of samplers, the
power supply and the protection of the samples. If you want the report, write
to me and ask for the "Sampler Report".
Question; Is it possible for a 208 Agency to produce a satisfactory 208 pro-
gram report for EPA without a modeling effort? Is some modeling effort re-
1-182
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quired just to fulfill the requirements, regardless of whether the 208 Agency
feels it is worthwhile.
Athayde; The policy, as T understand it, is that modeling is to be minimized.
In some cases, you can definitely do 208 plans without modeling. Hut, in
those areas that require it, we would like you to have all the information that
EPA can provide.
Question; I was disturbed that >'r. Condon used the word "must" in specify-
ing automatic sampling. I think that you have to be concerned with cost and
what you determine you can spend.
Condon: I will stand by the word "must", and will not retreat an inch. It
is experience that makes me say this! If you are trying to find out what
your loads are, under different conditions, and the impacts, the automatic
samplers are cheaper than manpower over a period of time. Again, this is a
trade-off and must be evaluated. But, if you were doing a sampling program
for any project of mine, the word "must" would stand.
Question (Ken Pugh, Cleveland Regional Sewer District): Can you give me a
number for combined sewer overflow discharges instead of stormwater discharges7
Athayde; There are guidelines out for combined sewers now. My understanding
of the guidelines, for combined sewers, is that there is a monitoring and data
collection requirement now. I am not sure that there is any number on com-
bined sewer overflows other than receiving water quality standards for any
particular area.
Comment; We have a NPDES permit for more than 500 combined-sewer overflows.
We'll never meet it!
Condon: There is no national number. The EPA Regions were allowed to enforce
the degree of the requirements with respect to monitoring. Some Regions are
not paying any attention to it, and others are. But, there is a different
approach between combined sewers and storm sewers. It is important. In the
combined sewer permits, it was argued that we should not measure any receiv-
1-183
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ing water impact. The logic behind this is that combined sewers are discharg-
ing raw, sanitary wastes and tin? whole intent of Congress was that there should
be no raw sewage discharges. What we did need to know was the incidence — the
frequency and how much was coming out of the system. Then there was the hope-
ful idea that cities having combined sewers would diagnose their collection
transport systems. From that knowledge, they can, later, take remedial action
based on the facts. But, there is no national number assigned to combined
sewers.
1-184
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II. Approaches to the Urban Stormwater Problem
II-l
-------
Land Management Techniques for Stormwater
Centre I in Developed Urban Areas
Kathleen Adgate
Water Planning Division
U.S. EPA
1ntrcduct i on
The theme of this urban stormwater management seminar is the need
to look at a Iternative approaches to complete treatment of stormwater,
approaches of a more; cost-effective and preventative nature. This
paper addresses those alternative approaches specifically applicable
to developed urban areas. For the purposes of this paper, the term
"stormwater management" is delimited to include control of pollution
in both separate and combined sewer systems.
Alternatives available for reduction of stormwater pollution have
been categorized as (I) abatement, (2) control or (3) treatment.^
Abatement measures are those practices directed toward pre-storm
reduction of pollutants, such as fertilizer control, street cleaning
or periodic sewer flushing. Control measures are those which impact
stormwater path, flow rates or loadings, such as detention/retention
basins or roof top or parking lot storage. Treatment of stormwater
generally involves the physical, chemical and biological techniques
applicable to treatment of wastewater flows. While these three
categories—abatement, control and treatment—offer a wide range of
alternative techniques for management of stormwater pollution, »»'->»'
their real world application is limited in many developed areas by
II-2
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conflicts with existing land use and activity. Table I presents
a listing of stormwater management alternatives, and suggests the
desirability of exploring the cost-effectiveness of land management
techniques for urban stormwater control. This paper will discuss land
management techniques for developed areas, often termed "housekeeping
techniques," as applicable to control of urban stormwater pollution.
Discussion of Housekeeping Alternatives
Housekeeping techniques are land management practices directed
toward improving urban cleanliness. While these techniques have trad-
itionally been performed by public works departments for aesthetic
purposes, there is a general correlation between urban cleanliness and
improvement of water quality in urban runoff. ''^ And because these tech-
niques have held a traditional place in the urban environment, they
have a greater opportunity for public acceptance, an essential factor
in the implementation of any management plan.
To begin, let us first review the housekeeping techniques in the
order that they are presented in Table I. This discussion is drawn
primarily from the literature, and, because stormwater management in
the quality sense is a relatively new area of concern, the available
literature on these techniques is limited.
Housekeeping techniques include both abatement and control measures
that impact, respectively, on quality and quantity aspects of stormwater
II-3
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TABLE
Limitations on
Storrnwater Ms.nagement Control Alternatives
in Developed Areas
High Land
Alternative Controls Costs Conflict
Treatment X X
Land Use Planning X
Detention/Retention X
Housekeeping Techniques
street cleaning
solid waste management
catch basin cleaning
sewer f I ush i ng
deicing material control
roof leader disconnection
fl
II- ^
-------
runoff. Quality controls include street cleaning, sewer flushing,
catch basin cleaning, deicing material controls, and solid waste
management. The quantity control discussed in this paper is discon-
nection of roof leaders.
II-5
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I. Street Sweeping
Materials washed off of street surfaces have been found to contribute
significantly to pollution of receiving waters. One study on street
surface contaminants calculcited that street surface runoff pollutant loads
can exceed loads from sanitary sewage.'4 jne quantity of contaminant
material was found to depend upon the length of time since prior cleaning,
whether intentional or from rainfall. Periodic street sweeping is one
housekeeping technique which can impact positively on this contaminant
load.
Street sweeping may be performed by manual or mechanical methods.
While machine sweeping accounts for the majority of street sweeping in
this country, manual sweeping is used by many communities to supplement
mechanical operations. Its purpose is to control visible debris such as
paper and cans, and its primary impact is on those areas where parked
cars prevent the use of motorized equipment.
Motorized street sweepers loosen dirt and debris from street surfaces
and deposit them in a storage hopper. Three types of motorized equipment
are currently in operation. The pickup broom type is the most common. It
utilizes a rotating gutter broom to move materials into the area of a main
pickup broom. A wide variefy of sweepers are available within this cate-
gory, including both three- and four-wheel vehicles. The regenative air
type sweeper air blasts material from the street surface into the hopper.
A third type of equipment, which is presently in limited use within the
U.S., is the vacuum sweeper. The vacuum sweeper loosens material from
street surfaces, picks it up through a vacuum nozzle, saturates it with
II-6
-------
water and deposits it in the vacuum chamber. With a hose attachment, the
vacuum sweeper can also function as a catch basin cleaner, and can
provide for cleaning of porous pavements.
Table 2 presents a listing of commonly used street sweepers.
Operating speed of most street sweepers ranges from 4 to 8 mph.
While acceptable for street sweeping in residential and commercial areas,
this speed is not sufficient for cleaning of arterials or freeways.
Therefore, several manufacturers offer a four-wheel sweeper with auxiliary
engine to drive the brooms, at a maximum speed of 15 mph. The use of
auxiliary engines provides constant power and speed for brooms and elevators,
allowing the operator to adjust sweeper speed to street conditions.
Street surface contaminants are not uniformly distributed across a
street. Table 3 displays the solids loading intensity across a typical
street. It indicates that 78% of the loading is found within six inches
of the curb and that 97% is within 40 inches. The basic street sweeping
procedure, therefore, is to clean that area adjacent to the curb. This
results in a redistribution of debris across the street surface, but does
not significantly reduce the total amount of pollutants on the street
surface.
Removal effectiveness of street sweeping eguipment varies with
particle size distribution, mass loading, street surface type and condition,
and type of sweeper used. The literature indicates an overall
removal effectiveness of 50%, with a range from 79% for particles greater
than 2000 microns to 15$ removal for particles less than 43 microns (see
Table 4 )J4 Fifty percent of all particles on street surfaces are in the
II-7
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Table 3
Sol ids
Street Location Loading Intensity
(Distance from Curb) (% of Total)
0 - 6 in. 78
6 -12 in, 10
12 -40 in. 9
40 -96 in. I
96 to center Ii ne 2
Source:
II-9
-------
Table 4
Particle S ize
(y)
> 2000
840 - 2000
246 - 8^0
104 - 246
43 - 104
< 43
Overa 1 1
% Sweeper
Ef f ici ency
79
66
60
48
20
15
50
Source: 14
11-10
-------
range of 104-840 microns, where efficiencies vary from 20-60$. Particles
of less than 104 microns experience removal efficiencies of less than 20%,
yet contain 42% of biochemical oxygen demand, 28$ of total heavy solids and
32$ of total perticides (see Table 5). Overall effectiveness of street
sweeping can be increased to 75$ if two consecutive cleaning cycles are
conducted.'4 Subsequent passes remove less of the remaining mass;
although overall effectiveness does approach 100 percent as the number of
passes increases, the increased effort required to achieve this removal
suggests limiting sweeping to three of less consecutive passes,
"No parking" regulations must be enforced to ensure effectiveness
of a mechanized street sweeping program, as parked vehicles are pre-
sently the greatest obstacle to effective street sweeping.
Caveat: Removal efficiency figures must be evaluated with caution. There
are currently three procedures for testing sweeping efficiency: i n s i tu
street tests, controlled tests and strip tests. Street tests represent
real-world conditions. Controlled tests use an artificially applied
uniform loading. Strip tests utilize only the main broom on a narrow
path of simulant. Because strip testing is easily run, most data on street
sweeping efficiency are developed in this manner. However, since strip
testing represents almost ideal operating conditions, the effectiveness
figures are high for real-world conditions. For example, recent studies
have indicated removal efficiencies of 95$ for fine materials by the
vacuum cleaning method, but these figures are derived from controlled
and strip tests, and further data will be required to corroborate these
findings under real-world conditions. Figure I presents a comparison of
various removal effectiveness figures by type of test conducted.
11-11
-------
Table 5
% Sweeper Particle Total Solids; BOD5; % Total Heavy Total
Efficiency Size % Size Dis- Size Dis- Metals: % Pesticides:
(y) tribution tribution Size Dis-
tribution
% Size
Distri but ion
79 > 2000 24.4
66 840-2000 7.6
60 246- 840 24.6
48 104- 246 27.8
20 43- 104 9.7
15 < 43 5.9
7.4 16.3 0
20.1 17.5 16
15.7 14.9 26.5
15.2 23.5 25.8
17.3 27.8 31.7
24,3
Source:
11-12
-------
100
50 •
Z
LU
o
5
Street
Tests
Strip
Tests
Fig. | . Comparison of Results from Sweep-
ing Effectiveness Tests Conducted
Under Various Conditions: For
Dirt/Dust Fraction
Source: 14
11-13
-------
Capital costs for street sweepers vary with type of equipment
required. The range (in 1975 dollars) is from $21,000-$25,000 for
three-wheel vehicles, $32-35 thousand for four-wheel equipment, and
$35-40 thousand for vacuum cleaners.'"7 Preliminary results from an on-going
American Public Works Authority (APWA) study on street cleaning practices
in 132 cities in the U.S. and Canada indicate a median figure of $1.20 per
capita annual O&M costs ($!3.60/ton or cubic yard) for street cleaning.^
This figure supposedly includes all costs, including water used for dust
control, and depreciation. The data were derived from questionnaire
responses, however, and the diversity of accounting practices in various
municipalities has long been an obstacle in arriving at comparable data.
The APWA study, funded by the National Science Foundation, is due for publi-
cation in mid-June, 1976,
2. Sol id Waste Management
Rather than relying completely on pickup of street litter by street
cleaning equipment, convenient location of trash receptacles, increased
frequency of trash pickup, and enforcement of anti-litter laws are
additional approaches to the problem. Good solid waste management practices,
including education of the general public on the pollutional impact of
littering, provide significant aesthetic and water pollution control benefits.
These benefits, however, are difficult to measure in economic terms.
3. Catch Basin Cleaning
Catch basin cleaning is a third housekeeping technique. While the
term "catch basin" is nonspecific and covers a variety of devices, a
commonality exists in that catch basins act as simple sedimentation tanks
for the removal of coarse solids. However, they do not impact on fine or
11-14
-------
organic matter, because catch basins are limited by the parameters of
turbulence and retention time, as is any sedimentation process. These
parameters will obviously vary tremendously with basin sizing. During
periods of storm runoff, the simultaneous settling of particulate solids
into the catch basin and the resuspension of solids into water flowing from
the catch basin make difficult the collection of quantitative data on the
performance of catch basins as pollution control devices. Research indicates,
however, that "dirty" catch basins exert a significant pollutant load on
receiving waters. Basins which are cleaned frequently have a greater
capacity to operate at design efficiency and to retain solids and associated
pollutants, although, as stated earlier, a high percentage of pollutants
are associated with the fine particle sizes that are most difficult to
control. Recognizing the difficulty of control of these fine solids and
the tendency of catch basins to accumulate organic matter which then
I 4
decomposes, one research study recommended that
public works departments give serious consideration to
how necessary catch basins are in their particular systems.
When a simple stormwater inlet structure would suffice, it
is probably desirable to get rid of the catch basin (either
by replacing it or by filling it in).
Research on catch basin cleaning in TuIsa in FY 1967-68 and FY 1968-69
indicates that older catch basins are being replaced with "self-cleaning"
devices that have direct connection to the storm sewer line and no holding
capacity for solids or runoff water. Newer developments in TuIsa do not
include catch basins in the street design.
Cleaning of catch basins may be accomplished by four methods: hand,
clamshell, eductor or vacuum. The hand or manual method generally consists
11-15
-------
of bailing out the water and removing the debris with long-handled dippers.
The catch basin material is deposited on the street surface, and is then
hauled to disposal sites, The clamshell method utilizes a mechanical
bucket which, through the use of an hydraulic crane, lifts the solid
catch basin material and deposits it into a truck. The merit of this method
is its speed of operation. Disadvantages include the difficulty of
transferring nonsolid catch basin material without the occurrence of
spills and the problem of bucket passage into sma ler catch basin inlets.
The eductor method of cleaning catch basins uses a large vacuum truck
equipped with sewer jet hose to suck material into the tank compartment.
These vacuum trucks also double as street flushers. While this method
is sanitary due to limited leakage onto street surfaces, large materials
in the basin must first be rerroved manually. Catch basin cleaning
through the use of a hose attachment to a vacuum sweeper is a relatively
recent alternative that has received limited research. It suggests itself
as a cost-effective alternative because of its dual purpose capability.
Costs for catch basin cleaning in various cities are presented
in Table 6.
4. Sewer Flushing
Solids deposit in combined sewers has been shown to contribute sig-
f~\ ft
nificantly to the pollutant imoact of stormwater overflows. ' These
solids, deposited during dry weather periods, are flushed loose during
subsequent heavy rainfall. Minimizing the quantity of solids deposited
during the dry weather period will reduce the pollution caused by subse-
quent overflows from combined sewers. Periodic sewer flushing is a means
of maintaining lower levels of these deposited solids, by removing
11-16
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settled material during dry weather and hydraulically conveying it to
the treatment plant.
A 1972 study of combined sewer laterals in Detroit0 resulted in
the development of an engineering basis for periodic sewer flushing of
small combined sewer laterals (12- and 18-inch diameters). The cleansing
efficiency of periodic flush waves was concluded to be dependent on flush
volume, flush discharge rate, sewer slope, sewer length, sewage flow rate
and sewer diameter. Slight irregularities in sewer s[ope and pipe align-
ment and details of the flush device inlet to the sewer were found
insignificant in affecting cleansing efficiencies. A prototype flush
station was developed during the project which, when inserted in a manhole,
collects sewage from the sewer, retains it, and releases it as a flush wave
upon receipt of an external signal. Use of settled sewage rather than
clean water as the flushing liquid caused only minor reduction in cleansing
efficiency. Table 7 presents the estimated flushing costs and efficiencies
(in percent solids removal/day) as a function of the number of flush sta-
tions per lateraI.
A recent study of Dorchester Bay presents a cost-effective comparison
of alternative plans for reducing combined sewer overflows from two
metropolitan communities in the Boston area. Controls included periodic
sewer flushing. Daily flushing of 100 critical segments reduced total daily
predicted solids deposition in 3000 segments by 50%. Table 8 indicates
the cost-effectiveness of four programs proposed by the study as compared
with two existing proposals, for example, Program IV (including sewer
flushing) provides for water quality protection comparable to that
11-18
-------
Table 7. ESTIMATED FLUSHING COSTS
Alternate 1 2
Number of flush stations per lateral 2 4
Area per lateral - acres 9 9
Daily solids removal - percent 61 72
Installed cost of fabric flush tanks $5,556 $11,246
Cost of telemetry and controls not estimated
Monthly power cost $1.95 $4.09
Monthly maintenance cost $100 $200
Capital cost per acre $617 $1,250
Monthly maintenance and power cost/acre $11.32 $22.70
Source: 6
11-19
-------
Table 8. PROGRAM SUMMARY
Acceptable Coliform Swimming Standards At:
PROGRAM
South Boston
Beaches (3)
Dorchester
Beaches (2)
Total Present
Value Costs
(millions)
NEW PROPOSAL
Extreme Mean
Std. Std.
Extreme Mean
Std. Std.
II
Basic Remedial Program,
Sediment Removal in Dor-
chester Interceptor,
elimination of seawater
intrusion and small
control program in
South Boston.*
Same as I plus 2 MG
Storage in Dorchester
X
X
III Same as I plus 11.1 MG
storage in Dorchester
plus Dorchester
flushing program.**
IV Program I plus: 18 MG
storage in Dorchester,
Dorchester flushing
program** and chlorin-
ation of South Dorchester
overflows.
X
X
X
X 1 of 2+
25
X
X
38
EXISTING PROPOSAL
V Old Harbor Plan
(South Boston)
X
X
X
X
X
57***
100***
VI Old Harbor Plan plus
Malibu-Tenean Beaches
Plan (South Boston
and Dorchester)
South Boston beaches: Pleasure Bay, L Street, and Carson Beach.
Dorchester beaches: Malibu and Tenean.
* South Boston Program consists of 1 MG storage (4 sites) plus flushing
daily 22 critical sections.
** Dorchester flushing program: flushing daily 100 critical section of pipe.
*** Capital costs only.
4- Protection achieved at Malibu Beach.
Source: 10
11-20
-------
provided by Program VI, but at roughly 40% of the cost.
5. Deicing Material Controls
A recent study on storage and handling of deicing chemicals indicates
that approximately 9 x 10 tons of salt and other deicing chemicals are
purchased each year by highway and street departments and other organizations
in the U.S., to the tune of $140,000,000. From the time they are mined
until they reach highway maintenance yards for subsequent application to
streets, these salts pass through several rounds of handling and storage.
At any of these storage points, exposure to wind or rain will dissipate
salt into the environment. In an aree. with 40 inches of precipitation
per year, a salt pile left exposed for six months would lose 5% of its
volume, ^ not including losses to wind. A 500 ton salt pile would lose
25 tons under these conditions, an amount sufficient to pollute approxi-
mately 15 mi I I ion gal Ions of water to the 250 mi 1 I igrams per I iter chloride
maximum recommended for drinking water supply by the U.S. Public Health
Service. Special additives within most highway salts may create pollution
problems ' even more severe than chloride pollution; sodium ferrocyanide,
used to minimize salt stock caking, is water soluble and will generate
cyanide in the presence of sunlight.
While the direct cost to a highway department of losing 25 tons of
salt is only about $400-500, there are additional indirect costs due to
corrosion damage to equipment, to cars, to bridges, and to adjacent
telephone cables, water distribution lines and other utilities, in addition
to environmental degradation. These indirect costs are difficult to
assess because the effects of salt runoff are dispersed and because a
monetary value for pollution of drinking water is difficult to ascertain.
11-21
-------
To prevent these direct and indirect costs, the study'-* recommends the
use of fixed storage as a cost-effective alternative. It states that, over
a period of 10 to 40 years, the value of salt saved by protection from the
weather is sufficient to offset much of the capital cost of a storage
building. The "beehive," a structure free of posts, pillars or poles,
will store up to 5000 cu. yd. of sand-salt. Costs are reported at
approximately $5.00-$6.00/ton stored.
Reduced application of deicing materials is a second alternative for
minimizing environmental problems. Salts are sometimes applied in
anticipation of snow, based on weather forecasts. Frequently, no snow
follows application.
Frequent calibration of salt spreaders and better training of equip-
ment operators are also suggested as techniques to minimize environmental
degradation from deicing material use.
6. Disconnection of Roof Leaders
In many U.S. cities roof leaders are still connected to sanitary
and combined sewers. During heavy rainfall, the runoff from roof surfaces
enters the sewers through these leaders, and augments the flow. Discon-
nection of leaders from these sewers helps to reduce the peak loading at
treatment plants during storm events. With disconnection, runoff from
roof drains flows over lawns and sidewalks, where a portion of the flow
either ponds or is absorbed by pervious surfaces. In separate sewer areas,
the flow eventually enters the storm sewer system through curb or street
inlets. In areas served by combined sewers, runoff from disconnected roof
leaders often enters the same system from which the leaders were
11-22
-------
disconnected, but reduces peak loading through flow attenuation.
A 1969 article in the Journal of the Water Pollution Control
Federation^ ^ reports the results of a roof drain disconnection program in
Springfield, Illinois, This program, conducted from April 1966 to
April 1968, resulted in a 90% reduction in roof leader connections (see
Figure 2). Total cost of the program, including survey and inspection,
was $45,010. A breakdown of costs indicates an average of $1.67 per
building inspected and $2.50 per downspout removed. Costs to property
owners to correct downspouts varied from as little as $5 to as much
as $50 or $100 if the gutter needed to be res loped.
11-23
-------
0
O
24
22
20
18
IR
l6
X 14
O 12
5
5 10
CO
T
BUILDINGS WHICH DO COMPLY
BUILDINGS WITH DOWNSPOUTS
CONNECTED
--I-
1 it
INSPECTION INSPECTION
INSPECTIONS
NO. CONN.
% CONN.
25,527
10,279
403
10279
4,969
195
z rj
° 2
* 5
-> O.
z
(- O
VI Z
INSPECTION
4,969
2,710
106
INSPECTION
2,710
1,629
6.4
INSPECTION
1,629
1,190
47
//
OVERALL
CAMPAIGN
25,527
1,190
4.7
This bar graph shows the overall campaign results.
FIGURE 2. CUMULATIVE RESULTS OF DOWNSPOUT REMOVAL PROGRAM
Source: 12
11-24
-------
Evaluation of Housekeeping Techniques
We have briefly run through various housekeeping techniques for
urban runoff management in developed areas. Now I propose that we step
through a very simple methodology for comparative evaluation of these
techniques on socio- and cost-effective bases. We should begin with a
cautioning note thc,t it is the methodology that we are developing, not
each individual element. Therefore, the reader may quibble with matrix
entries, recognizing the subjectivity of the author in entering them.
The methodology itself, however, may be applied by the reader with his
own substituted values.
I. Define Beneficial Uses of Water
The first step in the evaluation of any set of water quality alternatives
is the determination of beneficial uses. Table 9 is a matrix of beneficial
uses and the parameters which must be controlled in order to protect these
uses. Obviously, the body of water used strictly for navigation will
require a lesser degree of controls than that which serve? as an area's
drinking water supply.
2. Define Techniques to Control Parameters
Once beneficial uses and their controlling parameters have been determined,
techniques to control these parameters may be defined. Table 10 is a
simplified matrix of housekeeping techniques and the parameters upon
which they impact. The matrix is simplified because it requires several
qualifications. While it indicates the high-sufficient-low effectiveness
of techniques on various parameters, the columns are not strictly comparable.
11-25
-------
Table 9
Beneficial Uses
Wc'ter Contact Prop. Naviga- Aesthetics
Supply Recr. of tion
Fish
demand
Suspended so I i ds
Heavy metals,
tox i cs
Pathogens
Nutrients
DebrIs
11-26
-------
Table 10
Op Sus- Heavy Patho- Nutri- Debris
demand pended metals, gens ents
sol ids toxics
treatment
(secondary)
street cleaning
broom / / / - / +
vacuum / + + - + +
catch basin / / - / +
clean!nc
sewer flushing
deicing material
control
improved trash
col Iection
roof leader
disconnection
11-27
-------
For example, while vacuum cleaning rates high in removal of solids, these
efficiencies reflect only those solids from street surfaces, not a total
land area removal, and are thus not comparable to the high solids removal
of treatment. What the matrix does indicate, however, is that, with a
definition of beneficial uses, housekeeping techniques can be applied
toward abating or reducing pollution impacting these uses. While the
exact quantities of pollutants from specific land uses which reach receiving
waters have not been defined, removal of pollutants from land surfaces will
decrease the aggregate amount of pollutants available to enter the receiving
waters.
The matrix also indicates that, for certain uses (such as water supply
or contact recreation, where pathogen control is required), complete
control of parameters to protect these uses is not achievable through the
implementation of housekeeping techniques alone. This is a relevant
point to keep in mind now and throughout any evaluation of techniques —
no one technique will be the panacea for all urban runoff problems.
3. Factor in Public Acceptance/Political Implementation as A Function of
Socio-Economic Considerations
We have now determined our beneficial uses, and we have defined techniques
to protect these uses. Now — all we require to ensure water quality is
to inform the public that we ara instituting parking regulations on all
commercial streets for optimal efficiency of our vacuuming equipment and
that they will need to park elsewhere, that we are going to scrap the
"bare pavement" policy this winter to protect our streams from chloride
runoff, and that all property owners, at their own tire and expense, must
disconnect their roof leaders,. Cost-effectiveness
11-28
-------
aside, any technique which threatens traditional perceived social benefits
will be difficult to implement because it will be fought all the way.
Table II clearly indicates that those housekeeping techniques which are
most acceptable are those which do not threaten perceived social benefits
and which have been treditionaIly practiced, regardless of cost. I
stress perceived benefits, because, as in the example of deicing material
controls, the American public expects bare pavements at the tradeoff of
corrosion to automobiles and bridges as well as negative environmental
impacts. It also perceives improved trash collection practices as
beneficial for both aesthetic and health reasons, and the benefit is
doubly perceived because, unlike chloride pollution, the impact is both
d i rect and visible.
Cone I us ion
In conclusion, then, let us combine quality and quantity controls,
social values and costs to obtain a rough composite evaluation of each
technique. Similar matrices have been developed for evaluation of stormwater
controls for the Newcastle County, Delaware 208 area.'° The pluses,
checks and minuses of Table 12 are, of course, a convenient notation,
qualified by the subjectivity of their author. Again, comparison of
column entries must be qualified; some techniques, such as street cleaning,
impact only a small percentage of total land use, and are thus not strictly
compareble with treatment efficiencies and costs. In addition, a composite
comparison of techniques (row-by-row comparison) must recognize that the
evaluative parameters are not of equal impact in selection of techniques,
so that we cannot merely average the minuses and pluses over the row to
derive a composite ranking of techniques. Any attempt to do so must
11-29
-------
Tab Ie I I
Public Perceived Tradition Costs
accep- social
tance benefit Cap. O&M
Comments
street cleaning
b room
vacuum
catch basin
cleani ng
sewer flushing
no parking
regs
deicing material
control
bare pavement
po1i cy
improved trash
col Iection
aesthetics,
hea!th
roof leader
disconnection
+ + private cost,
concept difficult
to explain
treatment
(secondary)
perceived as
essential, but
"not next to
my property"
11-30
-------
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II-31
-------
recognize the subjectivity inherent in such an approach. What Table 12
does provide, however, is a simplified overview of alternative housekeeping
techniques. It indicates cost-effectiveness and public acceptability,
and thus highlights those parameters which may stand in the way of the effec-
tive irrp I ementation of specific techniques. A first-cut analysis of
this sort can serve to eliminate (or, at least, to qualify) inoperative
techniques, and can thus aid in the selection of cost-effective alternatives
for control of stromwater runoff problems in urbanized areas.
11-12
-------
References
I. AVCO Economic Systems Corporation, A Multi-Phasic Component Study To
Predict Storm Water Pollution From Urban Areas, report to
Office of Water Resources Research, Department of Interior,
December 1970.
2. AVCO Economic Systems Corporation, Storm Water Pollution From Urban
Land Activity, report to Federal Water Quality Administration,
Department of Interior, July 1970,
3. Black, Crow & Eidness, Inc. and Jordan, Jones & Goulding, Inc.,
Non-Point Pollution Evaluation Atlanta Urban Area, report to
Savannah District Corps of Engineers, May 1975.
4. Black, Crow & Eidness, Inc. and Jordan, Jones & Goulding, Inc.,
Study and Assessment of the Capabilities and Cost of Technology
for Control of Pollutant Discharges from Urban Runoff, report
prepared for the National Commission on Water Quality, October
1975.
5. Field, Richard et. at, "Water Pollution and Associated Effects from
Street Salting," J. Env. Eng. Div., ASCE, Vol. 100, No. EE2,
April 1974.
6. FMC Corporation, A Flushing System For Combined Sewer Cleansing,
I 1020 DNO, March 1972.
7. Lager, John A., "Stormwater Treatment: Four Case Histories," Civil
Engineering - ASCE, December 1974.
8. Lager, John A. and Smith, William G., Urban Stormwater Management and
Technology: An Assessment, EPA 670/2-74-040, December 1974.
9. Murphy, William, American Public Works Association, telephone conversation
with, November 1975.
10. Pisano, William, "Cost Effective Approach For Combined and Storm Sewer
Clean-up," paper presented at EPA Urban Stormwater Management
Seminars, November-December 1975.
II. Pitt, Robert E. and Amy, Gary, Toxic Materials Analysis of Street
Surface Contaminants, EPA-R2^73-283, August 1973.
12. Poertner, Herbert G., Practices in Detention of Urban Stormwater Runoff,
Office of Water Resources Research, June 1974.
13. Richardson, David L. et. al, Manual For Deicing Chemicals; Storage
and Handl ing, EPA-670/2-74-033, July 1974.
14. Sartor, James D. and Boyd, G. B., Water Pollution Aspects of Street
Surface Contaminants, EPA-R2-72-08I, November 1972.
11-33
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15, Shubinski, Robert P., "Concepts of Urban Runoff Control," Management
of Urban Storm Runoff, ASCE, OWRR C-4048, May 1974.
16. Turner, Collier & Braden, Inc., Structural and Non-Structural Techniques
Summary for Management and Control of Stormwater Pollution, draft
report prepared for 208 Planning Agency, Newcastle County, Delaware,
November 1975.
17. Telephone conversations with various equipment manufacturers, November
1975.
11-34
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QUESTIONS AND ANSWERS
(Following paper by Kathie Adgate, "Land Management Techniques for
Stonnwater Control in Developed Urban Areas".)
Question: Will you discuss land use planning in relation to housekeeping
techniques?
Adgate: I see a difference between land use and land management planning.
Land use planning would define the uses permitted; whereas, land management
planning would be that which helps one manage those uses which are already in
place. We have a distinct dichotomy between developed and developing areas.
The land uses are already defined in a developed area, so you don't have the
alternatives for land use planning there. Our next speaker will discus.s some
of the land management practices for developing areas. This is the place
where land use planning could be important.
Question (Robert L. Braun, Idaho Dept. of Health & Welfare): I would like to
know your feelings on street-washing techniques--street-washing versus street-
sweeping.
Adgate: I believe that the literature indicates that street washing merely
redistributes the load and puts it back into the system. In Washington, D.C.,
I had an interesting conversation with an operator of street washing equipment.
I asked him "exactly what do you do?" He said "I just Wash the dirt off the
street into the Potomac River". I think that street washing has a limited
quality benefit.
Question: How do you relate Table No. 8 that you showed to cost-effectiveness?
It seems to me that it is subjective and that there is no hard data to work
with.
Adgate: That's a good point. A few studies have been done on housekeeping
techniques, but we really don't have much good data.
Comment (Andrew Waldo, EPA, Washington, D.C.): You might mention that we (EPA)
11-35
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have been working a good deal on studying the cost-effectiveness of some of
these various techniques. We have been surveying the literature to determine
the costs of various techniques and compare costs, in a cost-effective manner.
The whole point is establishing the impact on water quality. We are coming up
with some of these costs so that we can compare them and go to a level of
higher sophistication.
Comment (Michael Seaman, Snohomish County, Washington): I disagree with you
when you say that land use planning doesn't have a place in a developed area,
because that assumes that cities don't change. But cities are dynamic and we
are involved every day in making, land use planning decisions that may have im-
pacts on water quality. I had hoped that EPA would be able to give us the
same kind of guidance on developed areas that you are presenting today on de-
veloping areas.
Adgate: I think that your point is well taken for redevelopment in an urban
area.
Question (Steve Sowby, Mountairtland Assoc. of Govts., Provo, Utah): Do you
really think that we can sell these housekeeping techniques to the public in
the name of water quality? In past years, they have been sold in the name of
aesthetics and beautiful, clean :ities. My other question is—where do you
flush the sewers to when you flush them?
Adgate: In response to your first question, we can't merely propose a cost-
effective approach and expect the public to buy it. I don't necessarily think
that you can sell it on water quality benefits. You must sell a systems
approach as a package—including such things as local flood control, quality
aspects, health aspects and others. I don't think that you can sell it strictly
for water quality purposes,and It would be very difficult to implement. Al-
though there may be very low capital costs and 0 & M costs associated with some
of the techniques, people are not necessarily going to buy it just for that
11-36
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reason. You will also have to show them why. In response to your question on
sewer flushing, I believe that Dr. Pisano will answer your question today when
he presents his paper on sewer cleanup.
Comment (Douglas B. Cargo, Univ. of Texas, Dallas): I think that paying more
attention to the solid waste problem could reduce floatables considerably in
stormwater discharges. It is easier to implement and people perceive it
better in terms of aesthetics.
11-37
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Subject:
LAND MANAGEMENT TECHNIQUES FOR DEVELOPING AREAS
Introduction: TO GIVE YOU SOME BACKGROUND FOR THE CAPABILITY OF SCS TO
SPEAK ON THIS SUBJECT, I WOULD LIKE TO POINT OUT WHAT THE
SOIL CONSERVATION SERVICE (SCS)
IS,
-------
(3) Reviewing
soils map
*OUR TECHNICAL STAFF DIAGNOSES RESOURCE PROBLEMS AND PRESCRIBES
SAFE USE AND TREATMENT. THE TECHNICAL STAFF INCLUDES SOIL
SCIENTISTS; ECONOMISTS; AGRICULTURAL, IRRIGATION, HYDRAULIC,
DRAINAGE, AND CARTOGRAPHIC ENGINEERS; AND SPECIALISTS IN
AGRONOMY, BIOLOGY, FORESTRY, PLANT MATERIALS, RANGE MANAGE-
MENT, GEOLOGY, AND SEDIMENTATION.
C4) Conservationist *LAND USERS AVAIL THEMSELVES OF THESE TECHNOLOGIES THROUGH THE
with homeowners ONSITE ASSISTANCE THEY RECEIVE FRCM A SPECIALIST DEVELOPED
BY SCS--THE SOIL CONSERVATIONIST. HE IS A PROFESSIONAL SKILLED
IN APPLYING THE COMBINED METHODS OF THE PHYSICAL, BIOLOGICAL,
AND SOCIAL SCIENCES TO PRACTICAL PROBLEMS OF LAND USERS.
(5) Soil
sample
*THE SOIL CONSERVATIONIST HELPS LAND USERS TO PLAN FOR EACH LAND
UNIT AS A WHOLE, INTEGRATING ALL ASPECTS OF LAND USE AND
TREATMENT. HE WORKS ON THE PRINCIPLE THAT SOIL, WATER,
PLANT, AND ANIMAL RESOURCES CANNOT BE EFFECTIVELY USED OR
MANAGED SEPARATELY BUT ARE INTERDEPENDENT AND MUST BE DEALT
WITH AS A WHOLE.
(6) SCS symbol
and district
sign
*SCS WAS ESTABLISHED IN THE U.S. DEPARTMENT OF AGRICULTURE
(USDA) BY THE CONGRESS IN 1935 TO PLAN AND CARRY OUT A NATIONAL
PROGRAM TO CONSERVE AND DEVELOP OUR SOIL AND WATER RESOURCES.
WE DO THIS THROUGH A COOPERATIVE EFFORT WITH SOIL CONSERVATION
DISTRICTS.
11-39
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(7J District
map
*SOIL CONSERVATION DISTRICTS ARE LOCAL UNITS OF STATE GOVERN-
MENT. THEY ARE RESPONSIBLE FOR THE SOIL AND WATER AND
RELATED RESOURCE CONSERVATION PROGRAM IN THEIR AREA. IN SOME
STATES THEY GO BY DIFFERENT NAMES, SUCH AS: CONSERVATION
DISTRICTS, SOIL AND WATER CONSERVATION DISTRICTS, AND NATURAL
RESOURCE CONSERVATION DISTRICTS.
(8) District
meeting
*THESE DISTRICTS KEEP THE CONSERVATION PROGRAM RESPONSIVE TO
LOCAL NEEDS. DISTRICT SUPERVISORS ARE ELECTED OFFICIALS WHO
PLAN AND DIRECT THE CONSERVATION PROGRAM.
THROUGH COOPERATIVE AGREEMENTS, THEY CALL UPON SCS AND OTHER
FEDERAL, STATE AND LOCAL AGENCIES FOR HELP.
(9) 3,000
conservation
districts
*TRADITIONAULY, SCS HAS BEEN THE STRONGEST ALLY OF DISTRICTS
IN THEIR CONSERVATION PROGRAM. SCS ASSIGNS PERSONNEL TO WORK
WITH SOME 3,000 CONSERVATION DISTRICTS IN THE NATION.
(10J Boating
*THIS CLOSE WORKING RELATIONSHIP HAS PRODUCED SOUND RESULTS
ON THE LAND.
(11) Trees
(12) Shelterbelt
*TODAY, GREEN WOODLANDS COVER ONCE SCARRED HILLSIDES;
*NATIVE GRASSES, WINDBREAKS AND SHELTERBELTS HAVE REPLACED
A BARREN SHIFTING DUST BOWL;
(13) Contour
strips
*COLORFUL CONTOUR STRIPS ADD VARIETY TO THE LANDSCAPE;
11-40
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(14) Lake
*FARM PONDS, EROSION CONTRAOL DAMS, AND WATERSHED FLOOD
PREVENTION STRUCTURES FURTHER PROTECT OUR ENVIRONMENT FROM
EROSION AND FLOOD DAMAGE.
(.15) Urban
conservation
*THIS SAME EFFECTIVE SYSTEM OF COOPERATION
CAN BE USED TO PRODUCE WORKING CONSERVATION
SYSTEMS IN URBAN AREAS.
LET ME SHOW YOU SOME OF THE LAND MANAGEMENT PROBLEMS INVOLVED
IN URBANIZING AREAS.
(16) Erosion
*ONE OF THE MAJOR PROBLEMS IS SOIL EROSION.
(.17) Bare land
*IN A TYPICAL HOUSING DEVELOPMENT, THE DEVELOPER MAY BULL-
DOZE BARE AN ENTIRE HILLSIDE.
(18) Gullies
SIX MONTHS TO A YEAR MAY PASS BEFORE HOMES ARE BUILT AND
THE HOMEOWNER AGAIN COVERS THE SOIL. WITH THE SOIL GOES
HERBICIDE AND INSECTICIDE RESIDUES. IT INCLUDES ELEMENTS
FROM PLANT FERTILIZERS.
*SOIL EROSION ON A SQUARE MILE OF LAND CAN INCREASE FROM
2 TONS/ ACRE / YEAR ON FARMLAND TO MORE THAN 40
TONS / YEAR ON LAND BEING CONVERTED TO SUBURBAN USES.
(19) Erosion from
street runoff
*RUNOFF WATER INCREASES IN URBAN AREAS AS SOIL IS COVERED WITH
CONCRETE AND ASPHALT. AS WATER IS CONCENTRATED EROSION BECOMES
A PROBLEM.
11-41
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(20) Concrete
outlet
*AN EXAMPLE IS THIS CONCRETE OUTLET ON A TRIBUTARY OF SAND
CREEK IN COLORADO SPRINGS.
(21) Eroded
drain
*THE STORM DRAIN CONCENTRATED RUNOFF AND CAUSED SEVERE GULLYING
AT THE OUTLET.
(22) Eroded
ditch
*HEAVY RUNOFF CAN ALSO CARVE AWAY DITCH BANKS.
(23) Sandy
hilltop
*WIND EROSION CAN BE A PROBLEM IN URBAN AREAS. HERE THE
DEVELOPER BARED AN ENTIRE HILLSIDE. THE SANDY SOIL BLOWS
INTO NEIGHBORING YARDS AND HOMES.
(24) Soil blown
into drainage
*HOW DOES WIND EROSION AFFECT URBAN STORM WATERS? SEDIMENTS
CAN BE CARRIED BY WIND AS WELL AS WATER. THE RESULT IS THE
SAME, PLUGGED DRAINAGES.
(25) Sediment
*SEDIMENT, WHETHER FROM WIND OR WATER, IS A MAJOR PROBLEM
IN URBAN AREAS.
(26) Mud in
street
*SEDIMENT COVERS STREETS,
(27) Mud in
reservoir
* REDUCES THE, STORAGE CAPACITY OF CITY RESERVOIRS, INCREASES
WATER BILLS,
(28) Dredging
sediment
*AND REQUIRES TAXPAYER EXPENDITURE TO DREDGE AND CLEAN OUT
THE RESERVOIR.
11-42
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(29) Mud pumped
from reservoir
*THE COST OF REMOVING ALL THIS MUD AND RESTORING OUR LAKES AND
WATERWAYS IS STAGGERING. OVER A BILLION CUBIC YARDS OF
SEDIMENT ARE DEPOSITED IN RESERVOIRS EACH YEAR.
THE COST OF DREDGING MAY RUN AROUND $1 A CUBIC YARD, AND
OFTEN THERE IS NO PLACE TO SPOIL THE SEDIMENT. BELIEVE Mb,
IT IS MUCH CHEAPER TO PREVENT EROSION THAN TO DREDGE SEDIMENT.
(30) Flood
*OF COURSE, THE MOST VISIBLE AND OFTEN THE MOST COSTLY DAMAGE
IS FLOOD WATER DESTRUCTION. FLOODS ARE NOT ONLY HAZARDOUS
TO PROPERTY, BUT TO LIFE ITSELF.
(31) Town in
flood plain
*A MAJOR NEED IS FOR BETTER PLANNING TO AVOID DEVELOPMENT IN
THE FLOOD PLAIN.
WHETHER IT BE AN ENTIRE TOWN,
(32) Caesar's
Palace
*OR JUST A RESORT K3TEL, SUCH-AS CAESAR'S PALACE, DEVELOPMENT
IN THE FLOOD PLAIN IS COSTLY AND HAZARDOUS.
(33) Parking
lot
*A PARKING LOT IS NOT QUITE AS BAD A USE OF FLOOD PLAIN,
*BUT PARKS AND RECREATION AREAS ARE THE BEST URBAN USE OF
(34) Flooded
park
(34a) Golf Course *FLOOD AREAS, SUCH AS GOLF COURSES
(35) Attractive
homes
*NOW LET'S LOOK AT SOME OF THE CONSERVATION PROGRAMS THAT CAN
BE UTILIZED IN URBAN AREAS.
11-43
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(36) Watershed
model
*PROBABLY THE MOST IMPORTANT ONE ADMINISTERED BY SCS IN STORM
WATER MANAGEMENT IS PUBLIC LAW 566, THE WATERSHED PROTECTION
AND FLOOD PREVENTION PROGRAM.
(37J Eroded
watershed
*UNDER THIS PROGRAM SCS CAN HELP LOCAL GOVERNING BODIES PLAN
AND APPLY FLOOD PREVENTION MEASURES IN WATERSHED AREAS OF LESS
THAN 250,000 ACRES.
(.38) Protected
watershed
*ONE OF THE FEATURES WHICH MAKES THIS PROGRAM UNIQUE IS THE
TREATMENT OF THE ENTIRE WATERSHED WITH CONSERVATION MEASURES.
THE IDEA IS TO CATCH AND HOLD AS MUCH WATER AS POSSIBLE WHERE
IT FALLS. DAMS AND CHANNEL IMPROVEMENTS ARE THEN USED IN
ADDITION AS NEEDED.
(39) Swamp
(.40) Dam
*SOME PRACTICES THAT CAN BE USED TO REDUCE URBAN DAMAGE INCLUDE
THE RETENTION OF LOWLANDS OR SWAMPS FOR OPEN SPACE,
*CONSTRUCTING SMALL RETENTION DAMS WITH WATER STORAGE CAPACITY
FOR RUNOFF PERIODS,
(41) Lake
*THE ENLARGEMENT OF PONDS AND PITS,
(42) Terrace
(42a) Diversion
terrace
(43) Concrete
spillway
*AND THE BUILDING OF TERRACES,
*D1VERSIONS, GRASSED WATERWAYS, CONCRETE
*CHUTES AND OTHER DEVICES TO MOVE WATER SAFEY OVER THE LAND.
11-44
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(44) Channel
improvement
*RESERVOIR SITES ARE DIFFICULT TO FIND IN URBAN AREAS. THERE
ARE USUALLY SEVERAL HOUSES IN THE MIDDLE OF A GOOD SITE. BUT
RESERVOIRS ARE A PART OF THE P.L. 566 PROGRAM, AS ARE CHANNEL
IMPROVEMENTS.
(45) Flood
*THE FEDERAL GOVERNMENT PAYS THE COST OF FLOOD PREVENTION
MEASURES UNDER P.L. 566. IT IS THE LOCAL RESPONSIBILITY TO
OBTAIN LAND RIGHTS AND EASEMENTS.
(46) Flood
Hazard
'*ANOTHER PROGRAM SCS DEALS WITH IN URBAN AREAS IS THE FLOOD
HAZARD AND FLOOD INSURANCE STUDIES.
IF A COMMUNITY IS INTERESTED IN IDENTIFYING ITS FLOOD PLAINS,
SCS WILL ENTER INTO AN AGREEMENT TO DO A FLOOD PLAIN STUDY.
(47) Map
*WE ALSO CONDUCT RIVER BASIN STUDIES WHICH PROVIDE MUCH VALUABLE
INFORMATION FOR COMMUNITY PLANNING AS IT APPLIES TO SOIL,
WATER AND RELATED RESOURCES.
IN COLORADO, WE HAVE COMPLETED RIVER BASIN STUDIES FOR THE
WHITE, YAMPA, GUNNISON, DOLORES, SAN JUAN COLORADO TYPE IV's,
COLORADO RIVER TYPE I.
(48) General
soil map
*SOIL SURVEYS ARE ALSO USEFUL TO LAND USE PLANNERS AND ALL
COOPERATIVE
LAND USERS. WE CONDUCT A NATIONAL/SOIL SURVEY PROGRAM WHICH
IS VERY USEFUL TO PLANNERS.
11-45
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(49) Aerial photo *SOIL SCIENTISTS IDENTIFY DIFFERENT SOIL PROPERTIES AND LOCATE
map THE DIFFERENT SOILS ON AN AERIAL PHOTO MAP. SOIL SURVEYS
INDICATE AREAS THAT HAVE BEEN SUBJECT TO FLOODING.
(50) Soil
pit
*SOME OF THE SOIL PROPERTIES IDENTIFIED INCLUDE SLOPE,
ThXTURE, PERMEABILITY, SOIL DRAINAGE, FLOOD HAZARD, DEPTH TO
WATER TABLE,
(51) Seasonal
wetness
*SEASONAL WETNESS, DEPTH TO BEDROCK, ERODIBILITY, LOAD BEARING
CAPACITY,
(52) Shrink-
swell
*SHRINK-SWELL CHARACTERISTICS AND CORROSIVITY.
(53) Grass
study
*VEGETATIVE STUDIES DONE BY SCS ARE ALSO USEFUL IN HELPING
DETERMINE WHICH TYPES OF VEGETATION WILL GROW BEST TO
REVEGETATE DISTURBED LANDSCAPES.
(54) Revegetated
slope w/retaining
wall
(55) House in
trees
*SEVERAL IMPORTANT THINGS CAN BE DONE IN URBAN CONSTRUCTION
SITES TO REDUCE EROSION AND RUNOFF.
*ONE PRINCIPLE THAT NEEDS TO BE ENCOURAGED IS TO PRESERVE
VEGETATION AS MUCH AS POSSIBLE. IT IS POSSIBLE TO CARVE OUT
SPACE FOR A HOUSE WITHOUT REMOVING ALL THE TREES AND GRASS
IN THE VICINITY.
11-46
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(56) Wheatgrass,
temporary
cover
(57) Roadside
net
(58) Sod
(59)
*IF AN AREA IS LEVELED AND BARED, THE DEVELOPER SHOULD SEED
IT BACK TO A QUICK GROWING ANNUAL COVER.
*FRESHLY DISTURBED AREAS CAN BE PROTECTED WITH MULCH.
*SODDING, OF COURSE, IS A GOOD WAY HOMEOWNERS CAN REDUCE
URBAN RUNOFF,
SCS USES A NUMBER OF TECHNICAL REFERENCE DOCUMENTS, BUT I
WOULD LIKE TO DISCUSS VERY BRIEFLY TWO OF THESE -- "THE
UNIVERSAL SOIL LOSS EQUATION" - AND THE "FIELD OFFICE TECHNICAL
GUIDE." THE EQUATION IS STATED AS: A=RKLSCP .
THE UNIVERSAL SOIL LOSS EQUATION IS A PROCEDURE FOR ESTIMATING
SOIL-LOSS UNDER DIFFERENT CONDITIONS. SOIL LOSS , A, IS IN
TONS/AC/YEAR - THE CONTRIBUTING FACTORS ARE:
1) RAINFALL CHARACTERISTICS — R
2) SOIL ERODIBILITY (I SAND, SILT, CLAY): O.M.;
STRUCTURE, PERMEABILITY — K
3) SLOPE (% AND LENGTH) — S and L
4) CROPPING MANAGEMENT - FALLOW, HIGH RESIDUE, MULCHING,
GRASS, ETC. -- C
5) CONTROL PRACTICES - (HOW THE SOIL TILLED) __ P
LET ME SAY: RAINFALL IS A GIVEN FACTOR FOR A SPECIFIC LOCATION.
THERE IS NOT MUCH CAN BE DONE ABOUT SOIL ERODIBILITY CHARACTER-
ISTICS - THEREFORE MANAGEMENT IS GENERALLY AIMED AT THE LAST
THREE.
-------
(60) Bare
site
*WE'LL DISCUSS HOW THIS BARE STIE MIGHT BE TREATED
(61) Soil
Loss Table
*THE TABLE SHOWS THE PREDICTED SOIL LOSS FOR THE EXAMPLES
SHOWN:
COVER TON/AC/YR
BARE SOIL 40
RYE GRASS 4
MULCH .8
GRASS SOD .4
(62) 5 Sections
of Technical
Guides
A BRIEF WORD ABOUT "FIELD OFFICE TECHNICAL GUIDES."
THIS IS A DOCUMENT DEVELOPED TO PROVIDE A TECHNICAL
REFERENCE FOR HANDLING SOIL, WATER AND RELATED RESOURCE PROBLEMS
IN A GIVEN LOCATION. THE TECHNICAL GUIDE CONTAINS 5 SECTIONS:
SECTION I: GENERAL REFERENCE MATERIALS
GENERALLY INCLUDES HANDBOOKS AND MANUALS, GENERAL SOILS MAPS,
PUBLISHED SOIL SURVEYS, RECREATION POTENTIAL APPRAISALS, LAND
USE, LAND OWNERSHIP, PROJECT BOUNDARIES, FLOOD PLAINS, SEDIMENT
SOURCES, WILDLIFE HABITAT POTENTIAL, AND OTHER RESOURCE,
DEMOGRAPHIC, AND RELATED DATA.
11-48
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SECTION II: SOIL AND SITE INFORMATION
SOIL SURVEYS ARE INTERPRETED FOR THE MAJOR USES IN THE FIELD
OFFICE AREA. SOME CHARACTERISTICS ARE IDENTIFIED AND INTER-
PRETIVE GROUPINGS ARE MADE SUCH AS WOODLAND SUITABILITY GROUPINGS
AND RANGE SITE DESCRIPTIONS WITH RANGE CONDITIONS DESIGNATED.
THE ALMOST UNIVERSAL USE OF SCS-SOILS-5, "SOIL SURVEY INTERPRE-
TATIONS," FOR PROVIDING ALTERNATIVE USES AND TREATMENT, HELPS TO
ASSURE UNIFORMITY IN OUR TECHNICAL QUALITY.
SECTION III: RESOURCE USE AND MANAGEMENT SYSTEMS
ALTERNATIVE CONSERVATION USES AND TREATMENTS IN KEEPING WITH OUR
OBJECTIVES OF (1) QUALITY IN THE RESOURCE BASE, (2) QUALITY IN
THE STANDARD OF LIVING, AND (3) QUALITY IN THE ENVIRONMENT ARE
EXPLORED AS RELATED TO VARIOUS RESOURCE MANAGEMENT SYSTEMS. MOST
AREAS ARE SUITABLE FOR TWO OR MORE ALTERNATIVE USES AND NUMEROUS
CONSERVATION TREATMENTS, HENCE, WE DEVELOP AND PROVIDE APPROPRIATE
ALTERNATIVE COMBINATIONS TO DECISION MAKERS.
SECTION IV: PRACTICE STANDARDS AND SPECIFICATIONS
THE MINIMUM LEVEL OF ACCEPTABLE QUALITY FOR THE PRACTICES USED IS
ESTABLISHED ALONG WITH THE MINIMUM REQUIREMENTS FOR INSTALLATION
OF SUCH PRACTICES.
SECTION V: COST-RETURN INFORMATION
SUITABLE COST-RETURN INFORMATION IS GATHERED AND DOCUMENTED TO
MEET THE FIELD OFFICE NEEDS. GENERALLY THREE KINDS OF DATA ARE
11-49
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NEEDED: (1) YIELD ESTIMATES FOR CROPS GROWN UNDER VARIOUS MANAGE-
MENT LEVELS, (2) COSTS OF CONSERVATION TREATMENT, AND (3) USUAL
PRODUCTION COSTS AND RETURNS FOR A RANGE OF YIELD LEVELS.
THESE DOCUMENTS ARE UNDOUBTEDLY THE BEST REFERENCES FOR
TREATING EROSION PROBLEMS IN MOST ANY LOCATION IN THE
UNITED STATES.
IF YOU HAVE NEED FOR THIS TYPE INFORMATION, WE INVITE YOU
TO CONTACT ONE OF THE NEARLY 3,000 FIELD OFFICES ACROSS
THE COUNTRY.
THANK YOU FOR PERMITTING ME TO DISCUSS-WHO WE IN SCS ARE,
HOW WE ASSIST THE PUBLIC, SOME OF THE PRINCIPLES AND
TECHNIQUES IN MINIMIZING THE EFFECT OF URBAN STORM WATER
AND TO REFLECT ON SOME OF THE CONSERVATION REFERENCES AND HOW
THEY ARE USED.
IF YOU HAVE QUESTIONS, I WOULD BE HAPPY TO TRY TO ANSWER THEM
AT THE APPROPRIATE TIME.
11-50
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QUESTIONS AND ANSWERS
(Following Duane Bartee's paper "Land Management Techniques for Developing
Areas")
Question (Daniel Straub—Kahenkamp, Sachs, Wells and Assoc.): I believe that
most of your concepts of retaining water at the point where it falls is very
sound and practical; however, it runs counter to some of the traditional
engineering practices of collecting and transporting storm water to treatment
or disposal points. Can you point out some of your experiences and local ac-
ceptance in urban areas or developing suburban areas?
Bartee: Most of our experience is with smaller communities. The principles
are very similar; however, we usually do not think of treatment. Generally,
what's involved is transporting runoff in some safe manner that doesn't carry
solids and sediment with it.
Straub: I am more interested in your comments on retaining water on the site
where it falls as rain, and collection in swales instead of pipes.
Bartee: We encourage maintaining the natural watercourses in these developing
areas, whenever possible.
Straub: We found that local acceptance by people who must approve such on-site
retention methods is difficult to get. You must have a lot of strong backup
information. Have you found much local resistance?
Bartee: No. The principles are sound. It is a matter of getting them com-
municated.
Comment (Athayde, EPA): I would like to answer that question on public ac-
ceptance. In the Washington, D.C. area—in Fairfax County, Virginia, and
Montgomery County, Maryland—the local governments have programs for holding
the water where it falls and attenuating runoff flows. As far as public
acceptance is concerned, Fairfax County has proceeded without having an ordin-
ance. They merely adopted a policy and got the land developers and contractors
n-si
-------
to do what they wanted them to do. This is one area of the country where I
was amazed to see hay bales around construction sites (for trapping silt in
runoff). Montgomery County is trying to implement the State of Maryland law
on erosion control. They have a. program where they require developers to pro-
vide detention basins on or around the construction site to contain the run-
off. I think that Mr. Bartee's presentation points out that we have to con-
sider flood control and erosion control as well as water quality.
Question (Dennis Maroney, Karcich & Weber Engineers, Colorado Springs, CO.):
My question relates to the Universal Soil Loss Equation. In using the equation,
you generate sediment loads from a given area on an annual basis. Some work
has been done to bring that down to an individual storm occurence and relating
it to a hydrograph. Are you aware of that work?
Bartee: No. But, I wouldn't be surprised to find that the Agricultural Re-
search Service, and possibly some SCS hydrologists, and scientists, worked on
that.
Comment (Richard Field, EPA): I wish to comment on the last question. People
at the University of Florida have endeavored to use the Universal Soil Loss
Equation on a per-storm basis with some success in verification, but I wouldn't
wholly endorse it at this point.
Comment (John Promise, North Central Texas COG): In responding to that question,
OKI has been doing work and EPA is distributing information concerning their
work. They have applied the Universal Soil Loss Equation for specific events
as well as for an annual average.
Question (Michael Seaman, Snohomish County, Washington): You mentioned many
practices for conservation of water quality, but they primarily relate to site
preparation and site managing. I am sure that there are other practices, for
developing areas, that could be worked into building codes,such as flat roofs
for storage, ground infiltration of rainwater from roofs, et cetera. Do you
11-52
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know of any techniques like that or any documents that have been written?
Bartee: I don't know of any. I think all these techniques might be useful,
but I am not sure of what effect they may have, percentagewise, in controlling
the total runoff.
Comment (Herbert G. Poertner, Engineering and Research Consultant, Bolingbrook,
Illinois): A publication which 1 authored addresses your area of interest.
It covers urban stormwater detention and describes many applications of tem-
porary storage of excess runoff on roofs, parking lots, and in basins on
ground surfaces. It also gives examples of discharge of water from rooftops
of buildings into trenches filled with rock and granular material to provide
stormwater storage voids and reduce the flow rate of the excess stormwater
into the downstream drainage system. An example of this is found at the Cabin
John Tennis Club in Rockville, Maryland. The title of the final report of the
study that I made is "Practices in Detention of Urban Stormwater Runoff". I
donated my manuscript to the American Public Works Association so that they
could publish it and make it widely available. The APWA also provided assis-
tance in gathering information and reviewing the manuscript, as did many other
organizations and individuals. The study was partially financed by the Office
of Water Research and Technology, U.S. Department of the Interior.
Comment (Donald Hey, Hydrocomp): I would like to discuss the Universal Soil
Loss Equation. The EPA has done some extensive work on sediment runoff and
sediment transport. The information is available. It examines sediment trans-
port, event-by-event. This is based on research done at Stanford University
about 10 years ago. It is based on kinetic energy of transport, rather than
the empirical relationships. The person who is directing the research is
George Bailey.
Comment: I would like to bring up one point on public acceptance. There are
12 states that have sediment control laws. Most of these states require the
11-53
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local jurisdictions to provide ordinances for control. Most of these laws
do require stormwater management. They require storage—for example, from a
10-year, 24-hour storm to be released at a 2-year rate. Another point that I
wish to make relates to the care that is needed in transposing information you
get from a soil-loss equation to a construction site. For example, the soil
loss equation is based on the top six feet of agricultural soil. Consider
what happens when you go into a new construction site. You might excavate
slopes 1%:1 to 2:1 with a depth of 30 feet. You have cut through the agricul-
tural soil layer. You have a cui:-slope of dense material with, perhaps, a
bedding dipping into the slope. You take the material you cut and remold it
by putting it into a fill. The cut-slope is not characteristic of the fill-
slope. Also, any one portion of the cut-slope is not characteristic of another
portion of the same slope. So, vrhatever you do be careful! But, even if you
look at the soil-loss equation, you are saying that so much soil can escape.
If you prevent that escape, why do you provide a soil-loss equation? Most of
these approaches are based on a design concept, and most of the designs are
based on the flow of water, not the sediment runoff. We, at EPA, have done a
study on the effectiveness of erosion control structures. We found that you
get 96% effectiveness. This is good, and it will get you an "A" everywhere.
But, if you look at the fact that 10% of that 4% of material that escapes
might be 100% of the fine-grained loam, the clays and the silts, have you really
accomplished what you think you have? At the present time, we have another
study going in which we are trying to find practical measures which can be
used to control the fine-grained fraction. If we can get this accomplished,
on a practical and economic basis, I think we can control all the sediment
from a construction site. Again, you have to be careful! Every time you take
an action, you have a reaction. When that runoff water escapes from a con-
struction site, it has energy. I" uses this energy to carry a sediment load.
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If it has no load, it will erode the channel downstream. Then, you have an
additional environmental problem.
Question (Douglas B. Cargo, Univ. of Texas at Dallas): I wonder if you would
comment on the policy of the Soil Conservation Service as to stream or channel
straightening and channelizing.
Bartee: Yes. Whatever action is needed in improving the channel, it would
have to be a stable channel when the work is completed. There is a place for
channel stabilization in handling stormwater. Straightening should be done
only to the degree it is required to satisfy the need and the purpose so as
to minimize the environmental effect.
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SCS PRACTICES AS RELATED TO
SEDIMENT AND EROSION CONTROL
by August J. Dornbusch, Jr.
State Conservation Engineer
Soil Conservation Service
U.S. Department of Agriculture
Athens, Georgia
(Presented with a slide presentation)
The Soil Conservation Service is a technical agency of the Department
of Agriculture. We've been in existence since 1935. Our assistance is
furnished to individuals who have soil, water, and erosion problems. Our
technical assistance in these problem areas is backed up by research as well
as the 40 years of experience. A good deal of the research has been done by
the agricultural Research Service of the Department of Agriculture. Our tech-
nical assistance is provided through Soil and Water Conservation Districts.
These districts are a unit of state government, and the services of the Soil
Conservation Service are offered through these districts through a memorandum
of understanding. From this arrangement, we provide assistance to the indi-
vidual who has soil and water problems. He may be a landowner, farmer, or an
individual in an urban area.
Conservation Plan
I'm sure that many times during this seminar you talked about "systems".
Anytime we deal with stormwater, erosion, etc., we have to look at the"system".
Our approach to putting systems together for individuals is a plan
called the soil and water conservation plan.
We develop this plan with the individual to fit his needs. It has to
be a feasible plan, a workable plan, and technically sound.
Soils
Whatever we recommend to a landowner or provide assistance on, soils
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are the number one ingredient to be considered. We have to know the details
about soils.
The Soil Conservation Service is responsible for mapping the soils over
the United States. We put this into a manuscript or a Soil Survey Report.
(For example, in Georgia we have 53 of the 159 counties covered and 19 more
are in the publication process). We need and must have this kind of inform-
ation all over the United States in order to know how to apply the best man-
agement practice that we talk about under Section 208.
For every acre of land, we need to know what type of soil it is. Each
soil will have certain characteristics and certain capabilities and these can
be related to what we call a soil series. The soil reports give interpreta-
tions of what a soil can do and how it will function. For example, if you
were looking or studying an area to determine its suitability for septic tank
operation, the Soil Survey Report can be used. The red colored portion of
the map indicates severe condition, the yellow moderate, and green indicates
slight problems. What this is saying is that in the red and yellow areas
you must do something to these soils or manipulate them in some way to over-
come the limitation so septic tanks could be installed. In addition, there
are many other interpretations in the Soil Report, i.e., crop potential, irri-
gation requirements, suitability for road building and foundation for house
building, recreation, woodland, and any number of interpretations that may be
helpful in planning various type work.
If you're not familiar with these reports, contact your local Soil Con-
servation Service representative and he can help you.
Erosion
Now, I would like to talk about erosion. We are indebted to the
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Agricultural Research Service for the development of the Universal Soil Loss
Equation. It is a tool that helps us to estimate the soil loss which can
occur for various soil types plus other parameters which are discussed below.
The equation is: A=RKL!5CP where "A" is the computed soil lost per unit
area, "R" is the rainfall factor, "K" is the credibility factor, "L" is the
slope length, "S" is the>- slope gradient factor, "C" is the crop management
factor, and "P" is the erosion control practice factor.
Vegetation
In the development of a conservation plan, we look at a number of sys-
tems; and one of the things we consider is "vegetation". It is our number
one defense against erosion. Hydroseeders are used along highways to vegetate
steep road banks. Vegetation on strip-mine areas has been effective in re-
ducing erosion. We have worked with school districts to get vegetation cover
on their properties to keep erosion to a minmum. We also work with airports,
such as we did here in Atlanta. Through a good vegetative plan, proper appli-
cation and then proper maintenaice, vegetation can greatly reduce the erosion
problem.
Another important consideration in reducing erosion is our woodland
vegetation. In Georgia, about 70 percent of the state is covered with wood-
land. Much of the forest: floor is covered with a good layer of mulch which
breaks up the impact of the raindrops and provides essentially a sponge to
absorb some of the rainfall and thus reducing and slowing down the runoff.
This combination reduces the amount of erosion that would otherwise occur.
Erosion Control Practices
Trees and grass are very important parts of a plan, but not all land
areas can be so planted. We must have farmland to grow the food we all enjoy.
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Every crop has varying atility to cover the soil during a growing season as
well as provide a residue to cover the soil during fall and winter months.
Often, the slope length of the land must be modified to get the allowable
soil loss with tolerance for certain cropping systems. One method is to use
contour strip cropping. This consists of alternate strips of close-growing
crop (wheat) and row-crop (corn). This reduces erosion considerably. However,
often contour-strip cropping is not enough to meet the minimum soil loss and
thus making it necessary to break up the slopes with terraces.
In addition, with each of the systems discussed above, a water manage-
ment system is needed. We prescribe primarily two types, (a) a grassed water-
way with a stable outlet, or (b) a tile outlet system, or conduit, which uses
a perforated inlet pipe and underground conduit to carry the runoff safely
away. Animal wastes disposal is another problem on farms. Basically, the
three practices that we deal with are: (l) the aerobic and anerobic lagoons,
(2) the holding pond to catch runoff from feed lots, and (3) the holding tank
where all the waste is caught. In each of these practices, the effluent
must be placed back on the land and thus the need to be part of the conserva-
tion plan so adequate land can be available to spread the material. This,
again, illustrates that it is necessary to look at the whole system.
We also provide assistance on many of the ponds we see on the country
side. Ponds can be used in pastures to help distribute grazing by properly
placing them as a drinking water source. This helps to reduce erosion by
causing the animals to graze over large areas and thus reduce overgrazing of
the vegetation. The ponds also serve for recreation and for wildlife habitats.
Irrigation is on the increase in the southeast. Mechanical irrigation
systems are being used quite extensively for supplementing the lack of rain-
fall during the growing season. It is imperative that good erosion control
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and management systems be planned as part of the irrigation system to keep
erosion within tolerable limits. Irrigation is another aspect that we want
to think about in 208 planning since it is a method of applying waste effluent
to the land.
Project Type Work
We also have "project" type operations. We have two types on which
the SCS provides technical assistance. One is the Small Watersheds Program.
The other is the Resources Development Program. We, basically, have several
goals in the programs: (1) assist individuals within the watershed (hydro-
logic unit) to apply sound conservation measures; (2) floodplain management;
(3) flood control, using structures; (4) recreation;(5) water supply; and
(6) social-economics of the area.
I would like to talk about our work with counties and other governmental
units in dealing with erosion control and sedimentation problems. A number
of counties in Georgia tackled this problem of erosion and sediment control.
Our assistance, basically, has been to aid the counties through the State Soil
and Water Conservation District by reviewing plans that land developers submit.
The State of Georgia enacted a sediment control act this past spring. The
State Soil and Water Conservation Districts have been asked to take a leading
part in review of these plans. Unfortunately, one of the things that is not
in the Act is storm water management. When you look at the system, it is
almost impossible to separate storm water management and sediment and erosion
control.
There are many practices that we apply to farmlands that can also be
applied in urban situations. You must envision scaling down the size of the
project, and use imagination. If the slopes are too steep and you cannot
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solve the problems with vegetation alone, you may have to use mechanical means.
Site development plans need to provide methods of collecting sediment
and keeping it on the site. In the same light, storm water runoff should be
detained on the site and released at flow rates that will not cause problems
on adjacent lands or downstream areas. If streams are overloaded with storm
runoff, they may become unstable and result in erosion and deterioration of
the stream. We need to make certain that we handle storm water properly.
Many states have developed manuals to aid individuals in the planning
and designing of erosion and sediment control plans for areas undergoing
urbanization and development. Georgia developed two of these manuals in 1972;
one is standards and specifications and the other is a "how to do it" type
manual. The State Soil and Water Conservation Committee is now revising these
into one volume. They are also including storm water management as a section
of this publication. It will also include a section on erosion control on
mining area, as well as urban and development sites.
All people and all levels of government must pull together as a team
to lick the non-point-source water pollution problems. Going our separate
ways without coordination and direction would be a disaster and a waste of
everyone's time.
The U.S. Soil Conservation Service has just released a document that
deals with urban hydrology for small watersheds. If you want a copy, write
to the state conservationist in your state.
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COST EFFECTIVE APPROACH FOR COMBINED AND STORM SEWER CLEAN-UP
Dr. William C. Pisano*
This paper presents overview details of a study addressing the combined sewer
problems in an old congested eastern community. The study emphasizes a multi-
plicity of principally non-structural micro controls in the upstream collection
systems as well as several large downstream controls in contrast to an existing
plan dominated by a massive downstream control program. The new plan cuts costs
by more than 50%. In addition, some of the dramatic field inspection results
raise questions concerning the adequacy of present combined sewer evaluations
conducted in sec. 201, step 1 infiltration/inflow studies.
The general flavor of the approach may be interesting to 208 planning
agencies desiring to stress non-structural Best Management Practices (BMP's) in
combined sewer areas where prior 201 planning emphasized only structural solutions.
The conceptual framework of this problem-solving strategy is also appropriate for
designing 208 storm sewer planning efforts in both developed and developing areas.
Although the methods used in this study represent a practical approach for ad-
dressing combined sewer problems, prototype studies in representative sample areas
are recommended for 208 planning efforts because the level of detail and the
associated costs are high.
Overview, Significance
Of all municipal-related pollution abatement problems, the most signifi-
cant, in terms of cost and technics! complexity, is storm and combined sewerage
system overflow loadings. According to the U.S. EPA's latest survey, the costs
of implementing controls on all municipal sources are estimated to be $350
billion. Of this total, nearly 75% or $261 billion would be required to control
storm water runoff ($235 billion) and combined sewer overflows ($26 billion).
*Technical Director, Environmental Planning, Energy & Environmental Analysis, Inc.
Boston, Massachusetts.
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Quite obviously, amounts of this magnitude cannot feasibly be raised. Further-
more, costs of public works programs have never approached these figures. Even
funds for highway construction have totalled only slightly over $75 billion.
Another questionable facet of the existing program is that structurally-
oriented solutions for controlling combined sewer overflows generally imply
periods of disruption in major urban areas, particularly the older eastern
industrial cities, lasting years even decades. As such, the real social costs
of applying these approaches will certainly exceed the present survey estimates
that include only direct construction costs. The question then arises whether
this is a viable tradeoff for the attendant water quality improvements.
The answer to this dilemma is not clear. The estimated monies will pro-
bably never be available and a more realistic view would be to spend limited
dollars in maximizing the potential of existing capital outlays. The NPDES
permit program recognized that the first and most logical step in fully
utilizing our nation's municipal pollution control expenditures is to maximize
existing treatment plant performance via non-structural options such as increase
in O&M dollars, chemical additions, etc. Sewer system management can enhance
the usefulness of existing combined sewerage systems, particularly for wet
weather conditions. One aspect of sewer system management is a vigorous trouble-
shooting maintenance program utilizing conventional means to cleanse trouble-
some deposition locations. Along these same lines, labor intensive municipal
maintenance programs, heretofore considered unattractive, may become more
viable in view of continuing high unemployment rates.
Detailed Case Study
The study area extends over the two high-density residential communities
of Dorchester and South Boston in the metropolitan Boston area (see Figure 1).
The topographical relief of the 3600 acre area is moderate to hilly and is
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H-64
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served mostly by combined sewers. The concern for pollution control in the
area emphasizes reduction of fecal contamination to the five recreational
beaches which border Dorchester Bay. The existing proposal for control of
these overflows (combination of South Boston Pollution Control Program and
Water Quality Improvement Plan for Tenean and Malibu Beaches) centered on
collection and conveyance of combined and storm overflows at overflow out-
lets of the existing system, to a central pumping plant where the wastes
were to be lifted and transported under pressure through highly congested
areas to a terminal discharge location. The plan provided detention, chlorin-
ation and ultimate discharge of these wastes into Boston's Inner Harbor.
Sewer separation and chlorination of several overflows not captured by the
aforementioned system were additional components of the plan.
The estimated capital costs of the entire project exceeded $100 million
and the time of construction was estimated at five to eight years. The degree
of community disruption and the foregoing of beach recreational usage would have
been great. The route of the proposed force main cuts through the highly con-
gested residential streets of South Boston. The individual components of the
plan, taken separately, offered only marginal improvements in water quality. The
complete plan, however, would meet the 1974 water quality goals for Dorchester Bay.
The cost-effective approach described herein focused initially on maximizing
the potential usefulness and flexibility of the existing sewer system for control-
ling combined sewer overflows and then considered capital-intensive components for
further reduction of pollutant loads. The task of establishing a cost-effective
control program divided into three categories: 1) understanding and identifying
those remedial measures necessary to ensure maximum performance of the existing
system; 2) quantifying the degree and effectiveness of upstream system management
including sewer flushing and off-line system storage; and 3) determining the ex-
tent and magnitude of much larger downstream control measures such as large storage
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tanks to contain overflows, and chlorination facilities. Captured wastes were
later released without chlorination to the sewer system.
A number of programs consisting of different mixes of the latter two categories
of solutions were developed. Several extremely cost-effective remedial measures
were found. The overall costs of these programs would range up to 40% of the
existing proposal's capital costs.
The task of highlighting our control strategy can be best elucidated by
summaries of the 6 major tasks accomplished in the study. Computational details
of several new methodologies developed during the studies are not presented but
will be available on request.
(1) MAPPING ACTIVITIES A comprehensive set of sewer maps depicting the hydraulic
characteristics of interceptors, trunks and 37 collection systems was developed
in order to understand the system. Piping networks of the 37 collection systems
totaling 550,000 feet of sewers were then catalogued for hydraulic properties
as well as computerized solids deposition predictions.
A novel graphical approach was developed to represent hydraulic profiles for
each of the 37 combined sewer collection systems. Each collection system was
drawn in profile view using roughly a manhole to manhole discretized representation.
The segmented system included all combined, separate sanitary and storm sewers up
to but not including house connections. Cumulative totals for each service type
were given by a series of scales along the horizontal axis for each of the entry
points to the collection system trunk sewer. These maps provided a quick visual
informational basis for detailed field investigations, the computerized dry
weather sewage deposition and flushing predictions, and the detailed assesment
of the storage potential in collection systems.
(2) DRY WEATHER SEVJER SOLIDS DEPOSITION PREDICTIONS. An empirical model based on
shear stress considerations using literature data, was developed to predict amounts
of dry weather flow deposition in a single length of pipe. A multi-variate exten-
1.1-66
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sion of this model was developed to predict amounts of daily deposition in any
collection system network.
The model was used to predict the amounts of daily solids deposition in each
segment of the Dorchester and South Boston collection systems. A total of 3,000
segments with average lengths of 180 feet was needed to represent these collection
systems. Table I presents summary results for the 30 collection systems in Dor-
chester. Two important findings were that 10.3% of the total daily input solids
will deposit, and that 50% of these accumulations occur in 100 sections of pipe,
while 75% of these accumulations occur in 420 segments. Alternative sewer flu-
shing programs were developed for these segments.
(3) SEWER FLUSHING PREDICTIONS. An empirical model was developed for predicting
theoretical flushing volume requirements. Models were based on shear stress con-
siderations and used literature experimental flushing results as a data base. The
results are a series of simple single-term power functions that predict flushing
volumes using only the pipe section hydraulic parameters. The computational pro-
cedures are outlined in Table II. These models were used to predict the amounts
of water required per flush for each of the 420 sections of pipe determined in the
daily dry weather flow deposition analysis. These calculations also provided a
feasibility check on flushing since a number of segments had extremely flat grades.
(4) FIELD PROGRAMS. (Sewer System Diagnosis and Field Measurements)
a. Field inspections revealed that the commonly accepted view in Boston of the
Dorchester Interceptor (see Figure I) being overloaded and needing replacement was
erroneous:
i. A bricked-up side weir with ten missing bricks permitted seawater intrusion
equal to half the interceptor's dry weather flow and about equal to 3% of the aver-
age flow at Deer Island, Boston's main treatment plant. Careful chloride, temperature
and dye tracer surveys during high tide conditions uncovered this problem.
ii. The Dorchester Interceptor was found to be filled with fine granular and
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TABLE I
ASSESSMENT OF MODERATE TO HEAVY DEPOSITION LOCATIONS,
DORCHESTER COLLECTION SYSTEMS
BRANCH
Granite Avenue
Davenport Brook A
Davenport Brook B
Davenport Brook C
Rockne Street
Marsh Street
Hallet Street
Port Norfolk Street
Pierce Avenue
Coffey Street
Neponset Avenue (S)
Neponset Avenue (N)
Freeport Street
Conley Street
Popes Hill Avenue
Commercial Point
St. Marks Road
Adams Street
Centre Street
Geneva Avenue
Kimball Street
Hancock Street
Deer Street
Dorchester Avenue
Bay Street
Saven Hill Avenue
Romsey Street
Elton Street
Hart! and Street
Crescent Park
TOTAL
TOTAL
NUMBER
COMPONENTS
392
158
58
29
19
41
12
52
26
25
17
27
4
20
20
30
200
43
290
464
51
162
13
14
28
21
11
32
28
54
2361
AMOUNTS
DEPOSITION
(lb/day)
695.3
127.0
23.3
40.1
4.8
27.3
21.6
92.0
6.0
10.1
15.1
7.9
0.4
26.3
2.7
22.4
70.9
10.7
407.7
141.2
22.0
108.9
10.9
5.7
20.5
7.3
13.5
8.1
25.3
88.6
1721.3*
NUMBER COMPONENTS
MODERATE TO HEAVY
DAILY DEPOSITION
69
13
7
4
2
8
8
29
4
3
10
1
-
16
1
13
39
2
61
57
9
27
4
1
4
2
4
4
7
11
420
SUM OF
DEPOSITION
(lb/day)
438.4
93.9
13.4
31.6
2.1
18.8
21.4
86.7
3.9
6.0
12.5
3.6
-
25.1
0.9
17.5
35.0
2.1
195.8
59.3
13.9
84.0
7.1
1.2
2.2
2.1
10.5
3.5
20.8
77.4
1290.7
* Overall percentage of DWF suspended solids loadings depositing daily in Dorchester
Combined Sewerage System equalled 10.3%
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TABLE II
COMPUTATIONAL SUMMARY: FLUSHING MODEL
A) Experimental literature flushing data were used to relate
flush wave height with flush volume and rate, and pertinent
pipe hydraulic parameters.
B) Complicated open-form algorithms were developed to compute
flush volume for circular and egg shaped pipes given shear
stress requirements.
C) Simple closed-form oredictive tools relating flush volume
with pipe parameters were then developed using least squares
curve fitting methods with little loss in precision.
Circle
1 dR n 0-3 1 . 5R n no
**
13.5 L K45 D°'23
1.4
s
i.bb n n<5
* V = 28.2 L Du'uy '
h
1.34
S
where
L = Length of pipe requiring flushing (100 ft.),
S = Pipe slope (ft/lOOOft.),
D = Pipe dimensions (ft.), and
V = Flush volume (cf).
* Terminal Shear Stress = .04 PSF (Common value for separate domestic sewers)
** Terminal Shear Stress = .08 PSF (Common value for combined sewers)
Conditions Used to Develop Model (Step C)
A. Diameter: 8", 12", 18", 24", 30", and 36".
B. Length Flushed (ft.): 200, 250, 300, 350, 400, 450, 500
600, 700, 800, 900 and 1000.
C. Pipe Slope (ft./lOOO ft.): .5, 1, 1.5, 2, 2.5, 3, 4, and 5.
Note: Shear stress can be roughly related to minimum self-cleansing
velocity.
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organic sediments for nearly its entire length (13000 feet), resulting in the
interceptor's capacity being cut roughly in half.
b. An inspection of all control structures and problem points in the system gen-
erated a remedial list of 23 items which during dry weather would eliminate approx-
imately one million gallons of sewage daily from overflowing into Dorchester Bay.
c. Roughly 120 visual inspections of combined and separate sanitary sewer manholes
were performed to corroborate theoretical deposition predictions. The agreement
was remarkably good.
d. An automated wet weather samplirg station was installed at the end of a com-
bined collection system (25 acres) and operated to measure first flush phenomena
and to verify deposition predictions for this system. A mass balance was performed
during a wet event between the predicted solids accumulation and that flushed
during a storm event. The closure was within 5%.
e. A number of heavily deposited sewers were flushed using different approaches
for introducing the flush volumes. The experiments indicated that manual flush
volume introduction by water tankers as an integral part of an active maintenance
program at this point in time would be superior to any fully automated flushing
systems. Reccommendation of automated flushing systems on a large scale must a-
wait long-term field studies to docunent their effectiveness and to develop ope-
rational procedures. The estimated costs of sewer flushing programs were based
on automated equipment.
f. Water quality surveys of metropolitan beaches were performed following three
storms of varying magnitude over a tidal cycle. The Coliform death rates were ex-
tremely high. These results were used to develop the death rate parameters for the
water quality impact models.
g. The results of several marine in situ coliform death rate experiments performed
under different conditions of sunlight showed that the time for 90% reduction occurs
within 2 to 3 hours under sunlight conditions, while slight to zero rates were
noted under conditions of darkness.
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(5) ASSESSING STORAGE POTENTIAL.
a. The specialized collection system hydraulic profiles referred to earlier were
used to locate potential storage sites "upstream" in the collection systems. The
approach was to strategically locate small gravity-operated off-line storage tanks
in uncongested areas such as parks, median strips, abandoned lots, etc. Their func-
tion was to capture and later release first flushes from heavily deposited upstream
areas and also to detain potential overflows during small storms. Seventeen such
structures were proposed.
b. Storage potential for much larger downstream sites was also assessed. These
facilities would retain large overflow volumes for subs°quent pumped discharge into
the interceptor during the intervening dry periods.
(6) CONTROL AND ASSESSMENT
a. Overview: The analyses focused on water quality in terms of coliform concen-
trations. Earlier Boston Harbor studies indicated that control should emphasize
reductions of coliform bacteria to enhance harbor water for water contact recreational
use. It is fully realized that emissions of other pollutants such as organics,
nutrients and heavy metals should also be reduced to minimal levels.
During the recreational period of May through November in the Boston area, a
rainstorm of greater than .05" can be expected on the average of every four days.
Thus, the objective was to find for a given control strategy and coliform standard,
the average portion of time following a sequence of storms where the coliform levels
fall below the standard. It is assumed that water contact activities during rain-
storms would be negligible and therefore, the standards would not be applicable
during this period. This approach supports water body assimilative capacity con-
siderations.
Normally, facilities subject to random hydrologic fluctuations are designed
to handle a storm of an assumed duration and frequency. When this procedure is
applied to water quality management, it is tacitly assumed that a desired degree
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of water quality protection is equatable with a level of flood protection or urban
drainage. Such an approach may lead to a mi sal location of resources. The designs
for effective hydraulic control of extreme hydrologic events may be substantially
different from those for control of emissions from slight or moderate storms. The
selection of a design storm for water quality analysis is difficult and poorly
understood. It implies a knowledge of the benefits to the community that would
ensue. In this study, a more direct approach to this dilemma was useful.
The idea is to subject the system discharging into Dorchester Bay to a series
of hydrologic events of record, find the consequences (the overflows and their water
quality impacts) for each event, and then summarize all results in terms of an
average performance characteristic. The comparative advantages of the alternatives
can be assessed in terms of the overall performance under a great variety of
different, conditions. This approach relieves the decision maker from the burden
of connecting arbitrarily chosen frequency levels of storms with the corresponding
system performance.
b. Models:
i. A computer model of the Dorchester, South Boston, and Neponset Valley
sewerage system was developed that is roughly the equivalent of the NEC model,
"STORM", This model routed, sequentially, through the sewer system model each in-
dividual rainfall event and antecedent dry weather period that had occurred at a
local weather station during a 14-year period of record (677 events). The model
then computed for each storm event, the amounts of BOD, suspended solids and coli-
form bacteria that were discharged to the Neponset River and to Dorchester Bay.
ii. An approach using the Boston Harbor Quality Model developed by Hydro-
science, Inc. was used to compute for each storm event, the coliform bacterial
pollution, dispersion and subsequent die off with time at each of the 5 beach areas
in Dorchester Bay. Statistical analyses were then performed to assess the proba-
bilities of satisfying various leve'is of water quality standards.
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c. Alternatives Considered: The control alternatives as well as various combi-
nations of these alternatives included:
Alternatives Developed by the Study
i. Removal of existing deposits from the Dorchester Interceptor;
ii. Elimination of seawater intrusion to the Dorchester Interceptor;
iii. Remedial measures to upgrade inoperative control structures and mis-
cellaneous cleaning of plugged critical conduits;
iv. Daily flushing of critical sections of the present sewer collection system;
v. Installation of off-line storage facilities in Dorchester and South Boston;
vi. Chlorination at selected overflow points in the southerly portion of the
Dorchester sewer system.
Alternatives from the "Existing Plan"
vii. Collecting, pumping and chlorinating combined sewage overflows from
South Boston;
viii. Collecting, pumping and chlorinating combined sewage overflows from
both Dorchester and South Boston.
d. Results: The effectiveness of different control programs in reducing BOD and
suspended solids emissions from the Dorchester combined sewer system is shown
in Figures 2 and 3, respectively. The loadings are presented in terms of tons
discharged per recreational period (May-November). The removal of sediments
which presently reduce the nominal interceptor capacity by roughly 50% is considered
first. Next, three levels of sewer maintenance/flushing programs are considered
along with various levels of off-line storage. Flushing programs A, B, and C de-
note, respectively: no action, low level program-100 sections (average length
180') and nlgh-420 pipe segments. The low level flushing program (100 segments)
represents an estimated 50% reduction of total daily predicted load (in 3000 segments)
Removal of sediments from roughly a 13S000 foot section of the Dorchester
Interceptor is expected to reduce the BOD and suspended solids emissions to Dor-
11-73
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180
o
S
to
o
o>
Qi
93
V)
•o
UJ
D
O
m
160
140
'20
100
80
60
40
•Present Conditions
Clean
Dorchester
Interceptor
Sewer Flushing Programs
(A,B& C)
0 4 8 12 16
Proposed Storage (mg) - Dorchester Combined Sewer System
20
Figure 2 - Dorchester Combined Sewer BOD Emissions for
Various Control Programs.
H-74
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1000
E
O)
en
>.
CO
c
!o
Is
u c/>
O
v. 0)
c ^
U
o
to
•o
-------
Chester Bay by 65 and 200 tons per recreational period, respectively. These pol-
lutants will be treated at the Deer Island Treatment facility instead of dischar-
ging into Dorchester Bay. Sediment removal in the interceptor plus 2 MG storage in
Dorchester will reduce the median overflow (present conditions) to negligible levels.
This result underscores the fact that rainfall in Boston during the recreational
period is characterized by high frequency, low intensitv-small duration storms.
Small amounts of storage completely capture or significantly clip the overflows
from these events.
The coliform emissions during s.torm events were used as inputs into the water
quality response models. Figure 4 presents a partial summary documenting the
effectiveness of the various control programs. Response curves for the South Boston
and Dorchester beaches are presented showing the percentage of the intervening
dry periods between storms when the coliform levels were less than 1000 colonies/
100 ml. Removal of sediment from the Dorchester Interceptor significantly im-
proves the water quality at all beaches. Substantive water quality gains are
realizable with the addition of only modest control programs. Cost estimates for
each of the alternative programs associated with these curves and for mean coliform
concentration response plots (not shown) permitted identification of overall least-
cost programs.
The final results of the analysis are summarized in Table III. Program costs
and the degree of water quality protection provided by each plan are shown. The
first portion of the coliform standard limit constrains extreme event concentrations
while the second, and much more difficult to attain, limits mean concentrations.
Total present value costs include O&M over a 20 year period.
It can be seen from the table that Program I provides as much water quality
protection as Program V. In addition, Program I provides (not shown) incrementally
greater water quality improvement at the Dorchester Beaches than would Program V.
The largest source of overflows is from the Dorchester system. Removal of the
sediments in the interceptor simply reduces the magnitude of the problem.
H-76
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o
o
0> (A
> 0>
iu-£
_ o
o
o>
|o
T> .-C.
O h-
>»•
Q !
O) W>
01-5
o >
o
**•.£
"o
o
0)
I
South Boston Beachesx
I
Dorchester Beaches
Sewer Flushing Programs
04 8 12 16
Proposed Storage (mg) - Dorchester Combined Sewer System
Figure 4 - Dorchester Bay Water Quality Response
Characteristics for Various Control Programs.
11-77
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PROGRAM
TABLE III.PROGRAM SUMMARY
Acceptable Coliform Swimming Standards At:
South Boston Dorchester
Beaches (3) Beaches (2)
Total Present
Value Coata
(millions)
NEW PROPOSAL
I Basic Remedial Program,
Sediment Removal in Dor-
chester Interceptor,
elimination of seav/ater
intrusion and small
control program in
South Boston.*
II rmmo no I plus 2 MG
ctoru(;c in Dorchester
III Same as I plus 11.1 MG
storage in Dorchester
plus Dorchester
flushing program.**
IV Program I plus: 18 MG
storage in Dorchester,
Dorchester flushing
program** and chlorin-
ation of South Dorchester
overflows .
Extreme Mean
Std. Std.
Extreme Mean
Std. Std.
X
X
1 of 2*-
6
25
EXISTING PROPOSAL
V Old Harbor Plan X X 57*#*
(South Boston)
VI Old Harbor Plan plus X X X X 100***
Malihu-Tenean Beaches
Plan (South Boston
und Dorchester)
South Boston beaches: Pleasure Bay, L Street, and Carson Beach.
Dorchester beaches: I.lalibu and Tenean.
* South Boston Program consists of IMG storage (4sites) plus flushing
daily 22 critical sections.
** Dorchester flushing program: flushing daily 100 critical sections of pipe.
#x* Capital costs only.
* Protection achieved at Malibu Beach.
11-78
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Programs II and III are samples of intermediate programs and provide incremental
water quality improvements for the Dorchester beaches. Program IV provides complete
water quality protection for roughly 40% of the costs of Program VI. The control
elements of Program IV derive from a cost-effective analysis wherein different com-
binations of storage, number of flushing sites and chlorination stations were
considered, in order to meet the water quality standards. BOD and suspended solids
reductions were also the greatest for the selected plan. The analysis showed that
increased storage could be substituted for sewer flushing but would cost an
additional $6 million.
n-79
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CONCLUSION
There are several lessons to be gained from the case study. First, storm and
combined sewer systems can and must be improved and managed just like treatment
works. Computer oriented techniques coupled with thorough field and mapping
activities permitted the identification of tailor-fit solutions. The results of
this study cast doubt on whether the Federal requirements, promulgated as part
of the facilities planning program (sec. 201), mandating consideration on a
"one-time" basis correction of sewer system deficiencies via infiltration/inflow
studies, are broad enough. Their general tenor emphasizes infiltration/inflow
problems but neglects to assess remedial repair requirements to the sewer system,
and gives only a cursory look at problems caused by deptsits of solids during
dry weather conditions. While the goal of obtaining watertight systems by
reducing or eliminating infiltration/inflow is beneficial, its attainment in no
way guarantees that the system is in good working order. These inadequacies
largely stem from the fact that present studies are geared toward reduction of
the hydraulic loadings to treatment plants, and are not necessarily keyed on
ensuring proper sewer system performance during wet weather, overflow periods.
Second, many communities faced with combined and storm sewer problems must
have the cost-benefit options developed and decide on the preferred approach.
Rainfal1-caused non-point source pollution stemming from storm and combined
sewers cannot be solved by a uniform technological prescription without enormous
cost and large scale community disruptions. Because the prices of some storm and
combined sewer corrections are reasDnable and others extraordinarily high,
intelligent choices can be made only if the community benefits are weighed along-
side the costs. Section 208 and Section 201 planning, directed by PL 92-500,
requires that the alternatives be investigated before Federal funding is committed.
The analytical approach demonstrated here permits this to be accomplished ex-
plicitly and early. Benefits, in this case total coliform counts and associated
beach closings, are weighed against the cost of the control options. What price
H-80
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should we pay to swim during or after a one-in-ten-year rainfall event? What
price should we pay to swim during normal rains? This approach permits a
thorough exploration of such choices.
It should be clear that the building block approach presented herein has a
direct analogue for both developed and developing separate storm sewer areas. In
a conceptual sense, the first line of defense is obviously the imposition of
land use restrictions and controls resulting in imperviousness changes. Next,
erosion and sediment control practices can be imployed which can be constructed
to last beyond the construction period. This level of control can be coupled
with storm water management/flow attenuation concepts. The next step can be
non-structural BMP's incorporating improved methods of street cleaning, anti-
liter programs, storm sewer maintenance, i.e., catch basin cleaning, swirl
regulator configurations, small retention basins, etc. Lastly, of course, more
structurally oriented schemes of microstrainers, detention and chlorination can
be used. The building block approach is logical and was shown to be cost-
effective in the Dorchester combined sewer study.
In summary, the study clearly demonstrated that enormous advantages can be
gained by a simple but thorough approach. Savings of many millions of dollars
are anticipated because a good, hard (although admittedly difficult) look at the
old existing system was performed. Such an approach, if utilized in other areas,
can drastically reduce the national costs of combined and storm sewer cleanup.
Maximization of the existing capital investments by utilizing the sewerage system
to its fullest potential can result in tremendous cost savings.
n-81
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ABSTRACT
This paper presents an overview of a recent study assessing the cost-
effectiveness of a number of alternative plans for reducing the frequency
and magnitude of combined sewer overflows from two large, densely populated
communities in metropolitan Boston area. Controls included detailed field
sewer inspections for both dry and wet weather conveyance adequacy, sewer
flushing, upstream and downstream off-line storage and several chlorination
facilities. Field inspections yielded extremely beneficial and cost-effective
remedial measures. A generalized methodology was developed and utilized to
predict sewer solids deposition in 0.5 million feet of collection systems
covering 3000 acres. The approach was field verified. Daily flushing of
100 critical segments reduced total daily predicted solids deposition by 50%.
Off-line storage alternatives were developed in collection systems as well as
at major downstream overflow points. Coliform levels w^re monitored in
marine waters during overflow periods for a tidal cycle. In situ coliform
death experiments in marine environment were also performed. A runoff
emission methodology was couplec with the Boston Harboe water quality simulation
model to investigate over a 14 .year historical period of record, the impacts of
various combinations of control strategies in reducing fecal contamination.
Cost-effective programs for various levels of water quality achievement were
developed.
INDEX WORDS
Combined sewers, deposition, sewer flushing, sewer inspections, coliform death
rates, emission/response modelling.
H-82
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COLLECTION SYSTEM CONTROL
by
John A. Lager, Vice President
Metcalf & Eddy, Inc., Palo Alto, California
INTRODUCTION
As seen in the film, collection system control is one of the
favored methods for reducing overflows and increasing the
effective utilization of existing collection systems and
treatment facilities. In this lecture, we will review the
basic concepts, identify the components which make the system
work, list some of the problems experienced in test appli-
cations, and view the approach from a cost-effectiveness
evaluation.
Purpose
The purpose of collection system control is to utilize
in-system storage, possibly augmented by off-line retention
tanks, and flow routing to optimize the capture and treatment
of wet weather flows.
Leiser [1] identifies the main objectives of the Seattle
Metro system as:
1. To utilize the maximum storage capability of trunk
and interceptor lines within a combined sewer system
built to ultimate capacity so that overflows caused
by storm inflow are reduced or eliminated.
2. To regulate daily flows to treatment plants, thereby
aiding in the stabilization of the treatment processes
and effectively increasing the dry-weather capacity
of existing plants.
3. To select the overflow points which will cause the
least harm to receiving waters, beaches and marine
11-83
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life during intense storms when overflows cannot
be avoided.
4. To eliminate the need for or reduce the cost of total
separation of combined sewers which would be espe-
cially costly and disruptive to commercial and indus-
trial areas of the city.
5. To monitor and control mechanical equipment within
remote stations while accomplishing the above objec-
tives and,
6. To retain dry- and wet-weather flow data of component
collection systems for subsequent identification of
infiltration problems and for potential charges in
accordance with those flows.
Network Analysis
In order to make the system work, a series of integrated net-
works are required. Dispersed throughout these networks are
data collecting points which transmit information continuously
to a central processing unit. Here decisions are made whether
to store, accelerate, or reroute flows and implemented through
remotely operated gates, dams, and pumps. Success of the
technique depends upon having excess storage and treatment
available within the system and having sufficiently reliable
instrumentation and controls to make point to point corrections
during a storm.
THE CONTROL CONCEPT
The control concept developed from the knowledge that sewers,
and in particular combined and storm sewers, seldom flow at
their design hydraulic gradient which is selected on the basis
of a maximum requirement. This maximum may be based upon the
ultimate development of the area, the peak discharge expected
from a rare, say one in five years, storm or a similar re-
quirement. Thus, under normal flows only a small faction
of a sewer's cross-sectional area is under water.
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A simple example will illustrate what this volume may be
in a combined sewer laid at a uniform gradient.
Given conditions: area = 1,000 acres; population
density - 30 persons per acre; design maximum rainfall -
2-in./hr.; runoff coefficient - 60 percent, ground slope
2.5 ft/1,000 ft. Computed peak dry and wet-weather flows:
dwf = 30,000 x 100 gpcd x 2.5 pf = 7.5 mgd. wwf = 2.0 x
1,000 x .6 x .646 = 775.2 mgd. Conduit selection:
c = 100; say 12 ft. dia at s = .0025; v full = 10.0 ft/sec;
Q full = 775 mgd. Under dwf the conduit would be less
than 5% full.
By constructing an inflatable dam to 0.6 the depth of the
conduit, a storage impoundment of 0.76 million gallons is
created prior to overflow (see Figure 1).
O.fcD/A.
AREA * 7O.0'F
VOLUME* = ibh - 0-
Figure 1. COMPUTED STORAGE VOLUME
This volume is roughly equivalent to the total runoff from
a rainfall of 0.05-in over the entire area. Thus, it is seen
that, except for unusual circumstances, the storage volume
alone may not be significant unless backed up by a high rate
11-85
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of diversion to an available treatment facility. How high
the treatment rate must be to be effective can be readily
computed through simplified mathematical models as presented
in the earlier lecture.
Components
The components of a remote monitoring and control system can
be classified as either intelligence, central processing,
or control [2].
The intelligence system is used to sense and report the
minute-to-minute system status and raw data for predictions.
Examples include flow levels, quantities, and (in some
cases) characteristics at significant locations throughout
the system; current treatment rates, pumping rates, and gate
(regulator) positions; rainfall intensities; tide levels;
and receiving water quality. Quality observations and com-
parisons may assist: in determining where necessary overflows
can be discharged with the least impact.
The central processing system is used to compile, record,
and display the data. Also, on the basis of pre-recorded
data and programming, the processor (computer) may convert,
for example, flow levels and gate positions into estimates
of volumes in storage, overflowing, and intercepted and may
compute and display remaining available capacities to store,
intercept, treat, or bypass additional flows.
The control system provides the means of manipulating the
system to maximum advantage. The devices include remotely
operated gates, valves, inflatable dams, regulators, and
pumps. Reactions to actuated controls and changed conditions
(i.e., increased rainfall, pump failure, and blocked gate),
11-86
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of course, are sensed by the intelligence system, thus re-
initiating the cycle.
Operating Sequence
Before storm flow collection system control can be imple-
mented, the direction, intensity, and duration of the storm
should be known so that runoff quantities may be anticipated.
Thus, the rain gage network forms an integral part of the
system. Once the storm starts affecting the collection sys-
tem, the flow quantity and movements must be known for
decision-making, control implementation, and checking out
the system response. The advantages of knowing whether or
not an overflow is occurring are obvious, but consider the
added advantage of knowing at the same time that the feeder
line is only half full and/or that the interceptor/treatment
works are operating at less than full capacity. By initi-
ating controls, say closing a gate, the control supervisor
can force the feeder line to store flows until its capacity
is approached, or can increase diversion to the interceptor,
or both. If he guesses wrong, the next system scan affords
him the opportunity to revise his strategy accordingly.
Thus, system control or management converts the combined
sewer system from an essentially static system to a dynamic
system where the elements can be manipulated or operated as
changing conditions dictate.
Degree of Automation
Because of the frequency and repetitiveness of the sensing
and the short time span for decision-making, computers must
form the basis of the control system. The complexity of
11-87
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the hydrology and hydraulics of combined systems also dic-
tates the need for extensive pre-programming to determine
cause-effect relationships accurately and to assist in eval-
uating alternative courses of action. To be most effective,
real-time operational control must be a part of an overall
management scheme included in what is sometimes called a
"systems approach."
A block model of a complete automatic operational control
system as developed by McPherson [3] is shown in Figure 2.
This represents an ultimate system—hands off control— and
is a goal not yet achieved in major scale for management of
water resource functions. The build up for such a system
begins with remote real time monitoring. Next, the system
is supplemented by certain remote control capabilities
operated by a human processor at the control center. Finally,
through the development of confirmed logic sequences, the
controls are actuated directly by the computer with the super-
visor providing only a safety override capability.
EXAMPLES
The degree of automatic control or computer intelligence
level varies among the different cities. For example, in
Cincinnati, monitoring to detect unusual or unnecessary
overflows is applied and has been evaluated as being
successful [4]. In Minneapolis-St. Paul, the Metropolitan
Sewer Board is utilizing__a central computer that receives
telemetered data from rain gages, river level monitors,
sewer flow and level sensors, and mechanical gate diversion
points to assist a dispatcher in routing stormwater flows
to make effective use of in-line sewer storage capacity [5].
The use of rain gages, level sensors, overflow detectors,
and a central computer to control pump stations and selected
n-88
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SIGNAL PROCESSING AT CONTROL CENTER
Figure 2. AUTOMATIC CONTROL SYSTEM
11-89
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regulating gates is underway in Detroit [6] and Cleveland [7].
The City and County of San Francisco have embarked on a
system control project for which the ultimate goal is com-
plete hands-off computerized automatic control. They are cur-
rently collecting data on rainfall and combined sewer flows
to aid in the formulation of a system control scheme. Typical
regulator control devices are shown in Figure 3.
The cost-effectiveness of the system control approach and some
of the problems are evident in the following specific example.
Seattle
The Municipality of Metropolitan Seattle (METRO) incorporates
the main features of the above projects plus additional water
quality monitoring and advanced control functions [8]. First
operational in late 1971, the system presently has 15 fully
equipped regulation stations and one major pumping station.
All stations are monitored and capable of remote supervisory
operation from a central control console. The estimated
maximum safe storage in the trunk lines and interceptors,
serving the 13,120-acre combined sewer area, is 32 mg, or
roughly equivalent to 0.05 inches of runoff from the combined
and partially separated cireas. Interceptor capacity is
generally 3 times the estimated year 2000 dry-weather flow.
Through over three years of operation, the system has demon-
strated the capability to reduce overflow volumes by 50 to
60 percent under supervisory control, and in excess of 90
percent under automatic program control during a period of
unusually dry weather. Peak loadings to the receiving waters
have been reduced by 80 to 90 percent and the occurrence of
peak loadings has been shifted to higher rainfall rates which
occur less frequently. The average loading reduction for
H-90
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LOCAL CONTROL STRUCTURE
TRUNK HATER LEVEL
CONTROLS OUTFALL GATE
EXISTING TRUNK SEWER-
METRO INTERCEPTOR
OF WATER IN
INTERCEPTOR CONTROLS
REGULATOR GATE
REGULATOR SATE
(NORMALLY OPEN)
(a) SEATTLE, WASHINGTON
OUTFALL GATE
(NORMALLY CLOSED)
TIDE LEVEL SENSOR
MAY PBFVENT GATE
~&i OPENING
r'
s
RECEIVING WATER
UNDERGROUND EQUIPMENT VAULT
POVER OPERATED GATE
INFLATAILE DAM
TO RIVER
TO INTERCEPTOR
(b) MINNEAPOLIS-SI.PAUL, MINNESOTA
Figure 3. REGULATOR STATIONS
FOR IN-LINE STORAGE SYSTEMS
11-91
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8 measured pollutant factors was 68 percent. The system is
most effective in periods of light to moderate storms and
performed poorly under a few intense summer storms.
During the course of program, the river water quality improved
its dissolved oxygen content by 1 to 2 mg/L and the coliform
counts in the river estua::y fell by more than 50 percent.
The success of the computerized control management system is
attributed to:
• surveillance and early attention to potential
mechanical and control problems,
• early action and preparation for storm events,
• logical use of all available system storage to
minimize combined sewer overflows.
The total capital cost for the system improvements was
$5.3 million of which about half the cost was for the computer
controls and station control equipment. This computes out to
approximately $400 and $200 per acre respectively, which is
about one to two orders of magnitude less than comparable
master plan programs. Maintenance and operation costs average
to $5 per acre per year.
Major problems included the protection of sensors from the
hazardous environment, interfacing hardware, and the timing
of the program which did not allow incorporation of the much
advanced equipment technologies of the last few years.
CONCLUSIONS
Of all the abatement program options for large urban combined
11-92
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sewered areas, collection system control appears to be the
easiest to implement and the shortest route to direct re-
duction of overflows to receiving waters. The available
in-system storage will be widely variable between communities
based largely on topography and characteristics of the inter-
ception network. Supplemental off-line storage will be required
in most cases; however, the monitoring and control require-
ments will remain much the same.
As illustrated in the Seattle example, the initial level of
improvement will be highly cost-effective, provided increased
transport and treatment capacity is available.
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REFERENCES
1. Leiser, C.P. Automated Collection System Instrumentation
Needs. Proceedings of EPA Workshop on Research Needs for
Automation of Wastewater Treatment Systems. Clemson
University. September 1974.
2. Lager, J.A. and W.G. Smith. Urban Stormwater Management
and Technology - An Assessment. Metcalf & Eddy, Inc.
U.S. Environmental Protection Agency Report EPA 670/2-
74-040. December 1974.
3. McPherson, M.B. Feasibility of the Metropolitan Water
Intelligence System Concept (Integrated Automatic Opera-
tional Control). American Society of Civil Engineers.
December 1971.
4. Caster, A.D. and W.J. Stein. Pollution from Combined
Sewers, Cincinnati, Ohio. (Presented at ASCE National
Water Resources Engineering Meeting. Memphis. January
26-30, 1970.) Preprint. 1090.
5. Anderson, J.J. Real-Time Computer Control of Urban Run-
off. ASCE J. Hyd. Div., 96, HY-1. 1970. pp 153-164.
6. Brown, J.W. and D.T. Suhre. Sewer Monitoring and Remote
Control, Detroit. (Presented at ASCE Annual and Environ-
mental Meeting. Chicago. October 13-17, 1969.) Pre-
print 1035.
7. Pew, K.A., R.L. Gallery, A. Brandstetter, and J.J. Anderson,
The Design and Operation of a Real Time Data Acquisition
System and Combined Sewer Control in the City of Cleveland,
Ohio. (Presented at the 45th Annual Conference of the
Water Pollution Control Federation. Atlanta. October
1972.)
8. Leiser, C.P. Computer Management of a Combined Sewer
System. Municipality of Metropolitan Seattle. U.S.
Environmental Protection Agency. Report EPA-670/2-74-022.
July 1974.
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QUESTIONS AND ANSWERS
(Following John Lager's paper, "Collection System Control")
Question; In one of your slides, you indicated there was a increase of between
1 and 2 tng/1 in dissolved oxygen. Is this increase attributable totally to the
stormwater control system, and was this increase checked for cost-effective-
ness?
Lager; That increase was adjusted to represent only that improvement due to
the new control system that was in operation. It is based on more than one
year of performance. To me, it represents a good indication of the cost-ef-
fectiveness of the system. But, you can't say that 2 mg/1 divided into $5
million dollars comes to some broad dollar amount. Just how bad the stream
is depressed to begin with is important. If it is 80% saturated and you im-
prove it to 95%, it's remarkable.
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QUESTIONS AND ANSWERS
(Following John Lager's paper "Collection System Control")
Question (Michael Seaman, Snohonnish County, Washington): You showed us a very
sophisticated system which seems to have a lot of potential, but I haven't seen
much attention given by society or technologists to management of human wastes.
In particular, I would like to hear your comments on such things as: reclama-
tion; reuse of water; conservation incentives to discourage consumption of
water, thereby reducing loadings on sewage treatment plants; decentralized
systems such as units installed in buildings to recycle water in homes or
office buildings; and integration of energy recovery systems.
Lager: The first part of your question, relating to correction of urban prob-
lems, should involve entrapment of the water at the earliest opportunity. You
can see this in any study, nationwide. The major motivation of any analysis
should be the earliest possible capture of the stormwater in impoundments such
as in grassed areas of cloverleaf highway intersections and in impoundments
located in extreme upstream sections of the system. Rainwater is the primary
source of drinking water. If wa could catch it up in the air before it passes
through air pollutants, we would have the purest water obtainable. Also, when
it first hits the land, rain water is continually picking up pollutants all
along its path. As it progresses farther downstream in the system, correction
measures become more costly and land is more expensive. All of these factors
provide a great incentive to trap it as early as possible. I think that this
bears directly on your question concerning reclamation. The earlier you trap
the stormwater--the better the quality, the more water you can infiltrate into
the groundwater strata and the less cost involved in making the water reusable
for various purposes. I see little merit in individual home systems because
of the attendant operational supervision problems. Concerning your question
on energy recovery, I don't see major energy potentials in handling stormwater
H-96
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other than for hydroelectric generation. This was given consideration as one
of the components of the Chicago Tunnel and Reservoir Plan. (Editor's note:
This aspect of the plan has not been Incorporated into the project design).
We are dealing with intermittent and unpredictable circumstances. We know
that, on long term, we will get so many inches of rainfall in a year on an
average; but we can never count on a specific happening at a specific time.
Question (Cecil Ouellette, Oregon Operations Office, EPA): At Seattle Metro,
how did they gain public acceptance for the collection control system for their
sewer network? Secondly, what was the source of funding and the breakdown
of the $ 5.3 million total cost?
Lager: I think that both of those questions will be covered by one of our
speakers tomorrow. He will discuss the implementation and financing of such
programs. I feel that the Seattle Metro project had the widest public accep-
tance of any in all the areas that I visit in analyzing stormwater programs.
Comment (Rod Stroope, Seattle Metro): I can't tell you what the cost break-
down was. As far as public acceptance is concerned, it is an in-system modi-
fication. It involves changes to the collection and treatment systems. So,
there isn't really a great deal of public involvement other than for those
public facilities that are to be located above the ground. One such facility
produced public concern and, as a result of required environmental impact
statements, extraordinary controls were placed on the construction of the
facility. I urge 208 agencies that do not have - operational responsibility
to develop contact with the operational agency in your respective areas, es-
pecially where there are specific combined sewer problems or aspects to the plan
being developed. The operating agencies face, on a day-to-day basis, extremely
variable flows in the combined sewer system every time it rains. Conservation
methods and deduction of dry-weather sewage flows is a long-term thing that
208 agencies need to address from a policy standpoint. In the meantime, before
11-97
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we can reduce the flows significantly, the operators have to do something
with these flows. This is the type system we chose. It does appear to be
effective for that first light rainstorm.
Lager: I would like to add a comment on public acceptance. In contrast to
the Seattle area, let's look at the San Francisco project where, because of
the steep topography, they don't have any in-system storage capability. The
alternative that they identified is to construct off-line, upstream detention
basins. This met a great deal of public resentment because it involves long
periods, perhaps six months, when major street intersections in residential
areas will be torn up while they build these concrete stormwater vaults below
street level. After installation, everything will return to normal, but it
is that disruptive period which, carries the same stigma as sewer separation
construction procedures.
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A COST-EFFECTIVE SWIRL COMBINED
SEWER OVERFLOW REGULATOR/SOLIDS-SEPARATOR
Richard I. Field
Chief, Storm & Combined Sewer Section
(Edison, New Jersey)
Municipal Environmental Research Laboratory
U. S. Environmental Protection Agency
Cincinnati, Ohio 45268
Although this paper is on the swirl as applied to a combined sewer
area, it offers direct application for separately sewered and unsewered
flow control.
An intensive study to develop a new type of combined sewer over-
flow regulator device, called swirl, was conducted under the general
supervision of the U. S. Environmental Protection Agency's (EPA) Storm
and Combined Sewer Technology Program (Edison, New Jersey), Municipal
Environmental Research Laboratory, Cincinnati, Ohio. The background^,.
design, and operation of this device has been described previously;
however, these areas were based on hydraulic and mathematical modeling
to optimize swirl regulator/separator configuration and determine its
design basis. An overhead view of the hydraulic model in operation is
shown in Fig. 1. The object of this paper is to describe the results
of a full-scale prototype swirl unit that controlled real overflows in
the City of Syracuse, New York. This project is jointly sponsored by
EPA and Onondaga County, New York, under ongoing EPA Demonstration
Grant No. S-802400.
Fig. 1. Overhead View of Swirl Regulator/Separator In Operation,
Laboratory Hydraulic Model, LaSalle, Quebec, Canada
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COMBINED SEWER PROBLEMS
Untreated overflows from combined sewers are a substantial water
pollution source during both wet- and dry-weather periods. There are
roughly 15,000 to 18,000 combined sewer overflow points in the USA.
It has been estimated that on a national level the expenditure for com-
bined sewer overflow pollution abatement would be $30 billion.
In considering wet- and dry-weather water pollution abatement,
attention must first be directed to control of the existing combined
sewerage system and replacement or stricter maintenance of faulty regu-
lators- Consulting and municipal engineers will agree with findings
' ' ' that regulator mechanical failures and blockages persist at
the overflow or diversion points resulting in unnecessary by-passing, a
problem also occuring during dry weather. Malfunctioning overflow
structures, both of the static and dynamic varieties, are major con-
tributors to the overall water pollution problem.
The practice of designing regulators exclusively for flowrate con-
trol or diversion of combined wastewaters to the treatment plant and
overflow regulator facilities for improving overflow quality by con-
centrating wastewater solids to the sanitary interceptor and diverting7
excess storm flow to the outfall will pay significant dividends. ' ' '
A new phrase has been coined,, the "two Q's," to represent both.the
quantitative and qualitative aspects of overflow regulation. '
"Regulators and their appurtenant facilities should be recognized as
devices which have the responsibility of controlling both quantity and
quality of overflow.,to receiving waters, in the interest of more effective
pollution control."
GENERAL DESCRIPTION
The swirl flow regulator/separator is of simple annular-shaped con-
struction and requires no moving parts. An isometric view of the device
is shown in Fig. 2. It provides a dual function—regulating flow by a
central circular weir-spillway while simultaneously treating combined
wastewater by swirl action, which imparts liquid-solids separation.
Dry-weather flows (dwf) are diverted through a cunette-like channel in
the floor of the chamber into a bottom orifice located near the central
standpipe discharging to the intercepting sewer for subsequent treat-
ment at the municipal plant. During higher flow storm conditions, the
low-volume concentrate is diverted via the same orifice leading to the
interceptor, and the excess, relatively clear, high-volume supernatant
overflows the center circular weir into a downshaft for storage, treat-
ment, or discharge to the receiving stream. This device is capable of
functioning efficiently over a wide range of combined sewer overflow
rates and has the ability to separate settleable light-weight organic
matter and floatable solids at a small fraction of the detention time
required for primary separation—seconds to minutes as opposed to hours.
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Fig. 2. Isometric View of Swirl Regulator/Separator. Legend:
a. Inlet Ramp; b. Flow Deflector; c. Scum Ring; d. Over-
flow Weir and Weir Plate; e. Spoilers; f. Floatables Trap;
g. Foul Sewer Outlet; h. Floor Gutter
SYRACUSE PROTOTYPE
cA 3.6 m (12 ft) diameter swirl combined sewer overflow regulator was
installed at West Newell Street in Syracuse, New York. The overflow is
from a 54-acre, single-family residential tributary area. Since on-site
inspections confirmed full-pipe flow conditions occurred during normal
springtime overflows, design flow to the swirl was based on maximum carry-
ing capacity of the 0.6 m (2 ft) inlet combined sewer or 23.4 cu m/min
(8.9 mgd). A profile of the West Newell Street swirl prototype is shown
in Fig. 3.
- M H "B"
(4 orz_- 12- :
' — -v^ — l^v_ inv * 340
Inv • 33 39
.012- 12".:
Inv -34 66-
— -•*•
k i
Submerstble E
'
,12
ev 27
Sump Pump -
M H "C
24" Combined
Sewer Inlet — —?
i
-Mag Meter
I5MGD
-Creek Bonk
45
35
30
25
8 - Sampling ^Points
Fig. 3. Profile of.Swirl Regulator, West Newell Street, Syracuse
New York
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HYDRAULIC LIMITATIONS OF SITE
To avoid pumping, it is best that the swirl regulator fit between
the hydraulic gradients of the combined sewer inlet and the interceptor
receiving the foul outlet flow; however, this desirable condition did
not exist at West Newell Street. Owing to the limited hydraulic head
between sewers, dry-weather flow (by gravity) would have resulted in a
standing depth of 0.9 m (3 ft) in the swirl chamber. This would have
caused solids accumulation and possible anaerobisis in the interim
periods between storms. Thus, a submersible pump was installed down-
stream of the foul sewer outlet line which operated during dry weather.
OVERFLOW OPERATION
The facility was designed for immediate response to an overflow
condition. An ultrasonic flowmeter on the 0.3 m (12 in) foul sewer out-
let line measures dwf and the foul concentrate to the interceptor during
wet-weather flow. The average dwf range is approximately 1.3 to 2.0 cu
m/min (0.50 to 0.75 mgd). Since the downstream capacity of the inter-
ceptor is 3.4 cu m/min (1.3 mgd),, the flowmeter signal deactivates the
submersible pump when 3.4 cu m/min (1.3 mgd) flow is reached. Flow in
excess of 3.4 cu m/min (1.3 mgd) will be forced over the central overflow
weir, measured by an electromagnetic flowmeter, disinfected, and discharged
to the receiving stream.
When the overflow subsides, the flowmeter in the outfall pipe signals
the flowmeter in the foul outlet line, which reactivates the pump and low-
ers the water level in the swirl chamber to allow free gravity flow in
the floor gutter to prevent solids from settling until the next overflow.
Figs. 4 and 5 illustrate the dry- and wet-weather swirl operation, respectively,
Fig. 4. Swirl Regulator—Wet Weather Operation,
Syracuse, New York
West Newell Street,
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Fig. 5. Swirl Regulator—Dry-Weather Operation, West Newell Street,
Syracuse, New York
Sampling is performed at the inlet and outfall locations (depicted
in Fig. 3) at fifteen-minute intervals (later changed to five-minute
intervals) during overflow events. The samples were analyzed for sus-
pended solids (SS), settleable solids, 5-day biochemical oxygen demand
(BOD ) , total organic carbon, heavy metals (copper and zinc) and fecal
colirorm. Suspended solids and BOD are addressed on this paper.
COARSE FLOATABLES REMOVAL
The coarse floatables/scum removal mechanism has worked satisfactorily.
Visual observations during overflow events revealed floatables to be effec-
tively contained by the scum ring in the outer ring of the chamber, and
forced into the floatables trap (under the weir plate) by the swirl action
for subsequent draw-down and removal to the foul sewer during dry weather.
Fig. 6 illustrates floatables entrapment during wet-weather operation.
On occasion some floatables have been trapped between the scum ring
and the overflow weir as the water level in the chamber rises from its dwf
to overflow condition. In general such floatables have been lost to the
treated overflow.
MAINTENANCE
Initially, a double-vaned impeller type submersible pump was installed
but was subject to clogging problems due to coarse objects, e.g., bottles,
cans, rags, and bricks. This was rectified by the installation of a single-
vaned pump which reduced maintenance frequency from an average of once a week
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Fig. 6. Swirl Regulator—Floatables Entrapment During Wet-Weather
Operation, West Newell Street, Syracuse, New York
to once a month. Because of solids buildup, the longer the low dwf period
between the storms, the more frequent the maintenance required. Periodic
pump clogging also occurs from the accumulation of debris during overflow
when the pump is not operating,,
Manual hosing of the chamber walls and floor was necessary after each
overflow event. As an overflow subsided, the flow-through time in the
swirl increased from 23 sec (al: maximum flow) to 9 min (at minimum flow)
resulting in shoaling of solids on the chamber floor. Subsequent dry-weather
flow velocities were not great enough to carry accumulated solids to the
floor gutter and through the foul sewer outlet. Automatic washdown faci-
lities would eliminate the need for manual hosedown resulting in reduced
maintenance. The frequency of swirl chamber cleaning is approximately
once per month.
Estimated manpower requirements for the swirl at West Newell Street
are 48 hrs/yr (4 hrs/clogging :c 12 clogs/yr) for submersible (single-vaned
impeller) pump cleaning, and 40 hrs/yr (4 hrs/overflow x 10 overflows/yr)
for chamber cleaning, totaling 88 person-hrs/yr. Cost-wise, maintenance
amounts to $l,800/yr.
SOLIDS SEPARATION EFFICIENCIES
Hydraulic Model —
O A Q
Based on laboratory hydraulic model studies, ' ' SS removal
efficiency for the swirl should be approximately 65 percent. Particle
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removal effectiveness was determined to be a function of its effective
diameter and specific gravity (or settling velocity). For grit with
specific gravity of 2.65 greater than 0.3 mm (0.012 in), removals were
greater than 90 percent which decreased to less than 40 percent for 0.1 mm
(0.004 in) grit. For settleable solids with specific gravity of 1.20 and
larger than 1.0 mm (0.04 in), efficiency ranged from 80 to 100 percent;
and for 0.5 mm (0.02 in), particle removal efficiencies decreased to about
30 percent and less than 20 percent for 0.3 mm (0.012 in) particles. An
accurate comparison of prototype vs model removal efficiencies cannot be
made until settling column tests are performed for the West Newell Street
prototype flow.
Prototype —
Relatively good SS removal efficiencies were determined over the
entire storm-flow range for this prototype (Table 1). Total mass loading
and concentration removal efficiencies ranged from 44 to 65 percent and
18 to 55 percent, respectively, as flowrates ranged from relatively minor
flows of 0.54 cu m/min (0.2 mgd) to a high of 13.2 cu m/min (5.0 mgd).
Figs. 7 and 8 illustrate the total SS mass removals with respect to time
and storm flowrate. The shaded areas between curves indicate a trend of
higher removals at storm onset when concentrations are generally higher
and again near the end of the storm when flowrates drop.
Table 1. Suspended Solids Removal
Swirl Concentrator
Mass Loading Average SS
kg per storm, mg/1
Conventional Regulator
Mass Loading
kg
Storm No. Inf.
Eff.
Rem.
Inf. Eff.
Rem.
Inf. Underflow
Rem.
02-1974
03-1974
07-1974
10-1974
14-1974
01-1975
02-1975
06-1975
355
321
50
394
108
127
432
117
167
179
18
215
61
48
190
64
53
44
65
46
43
62
56
45
535
182
110
230
159
374
342
342
345
141
90
164
123
167
202
259
36
23
18
29
23
55
41
24
355
321
71
394
114
230
432
117
143
96
15
94
41
127
149
42
40
30
21
24
36
55
35
36
For the conventional regulator removal calculation, it is assumed that the SS
concentration of the foul underflow equals the SS concentration of the inflow.
Data reflecting negative SS removals at tail end of storms not included.
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Storm #l $/24/7$
Total Suspended Solids
o Moss Loading (Influent)
A Moss Loading (Effluent)
Flow
00 1200 ^CO HOC 1500 1600 <7OO iflOO
Fig. 7. Swirl Regulator Suspended Solids Removal,
West Newell Street, Syracuse, New York
S 3629
S
7OO 800 900 1000 IIOO I? OO U OO i4 00 I50O I6OO I7OO
Fig. 8. Swirl Regulator Suspended Solids Removal,
West Newell Street, Syracuse, New York
Fig. 9 further reveals the trend of greater SS mass loading reduction
as the SS influent concentrations increase. Suspended solids influent
concentrations greater than 250 mg/1 generally resulted in removals of
better than 50 percent of the total mass loading to the swirl.
Care must be taken in evaluating swirl solids treatability since
under dwf conditions all regulators are designed to divert the entire
flow volume and associated solids to the intercepting sewer until a pre-
determined overflow rate is reached. This diversion continues throughout
the storm. The swirl has the added advantage of concentrating solids as
well as conventionally bypassing flow during overflow events. This
concentrating effect is evidenced by removal efficiencies in terms of SS
concentrations varying from 18 to 55 percent (Table 1), as previously
stated.
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11OO
000
900
BOO
TOO
600
500
4OO
300
?00
K)0
0
, Slorm »6 6/5/75
• Swm «2 4/3/75
• Swm 411 3/24/75
40 50 60
% Moss Rfmovol
Fig. 9. Swirl Regulator Suspended Solids Influent Concentration vs
Percent Mass Loading Removal, West Newell Street, Syracuse,
New York
If a hypothetical swirl regulator was developed that did not concentrate
(as is the case for conventional flow regulators), the net mass loading re-
ductions (attributable to the SS conventionally going to intercepted under-
flow) would have ranged from 21 to 55 percent (Table 1). This may be a
better way to compare the effectiveness of the swirl to conventional com-
bined sewer overflow regulators.
For low-flow storms, approaching the maximum dry-weather capacity of
the interceptor, the advantages of swirl concentration are reduced as would
be expected based on the physical principal involved. In other words, as
the ratios of inflow to foul outlet underflow or weir overflow to foul
outlet underflow decrease, the SS removal advantage from swirl concentrating
also decreases, since the intercepted hydraulic loading to underflow becomes
more significant in the net mass loading calculation of the hypothetical
conventional regulator. This phenomenon is exemplified by the SS total
compared to SS net mass loading removals of Storm No. 1-1975 (which was of
relatively low intensity compared to the other storms) (Table 1), where
the hydraulic loadings to the swirl were low, approaching dry-weather
conditions.
Many outfalls are designed to pass 20, 100, and even 1,000 times
average dwf as opposed to West Newell Street which, at best, passes only
10 times average dwf. For these cases, the swirl concentrating effect
will exhibit greater advantages than found with the Syracuse prototype
over conventional regulators for SS mass removal.
BIOCHEMICAL OXYGEN DEMAND
Since non-biodegradable synthesized solids were used, no evaluation of
BOD5 removal was made in the laboratory swirl hydraulic model. Prototype
analyses indicated greater than 50 percent BOD- removals in terms of mass
loading and concentration (Table 2). Total mass loadings removals and
treatment efficiencies in terms of concentration ranged from 50 to 82
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percent and 29 to 79 percent, respectively. Figs. 10 and 11 indicate the
trend for BOD,, total mass loadings removal for the swirl prototype, with
Fig. 12 indicating higher removals at the higher BOD,, influent concentra-
tions.
Table 2. BOD Removal
M3SS T|D
Storm No. Influent
7-1974 26,545
1-1975 3,565
2-1975 12,329
t CO/6
5 0 IV
-------
I ion
Fig!?
Storm mt 4/J/ 75
' Storm « I 3/4/75
• Slorm • 7 6/21 /74
?O 40 60 80 iQO
Fig. 12. Swirl Regulator BOD Influent Concentrations vs
Percent Mass Loading Removal,
West Newell Street, Syracuse, New York
COSTS
Costs for the swirl prototype at West Newell Street, Syracuse, New York
(designed to remove 90% grit, without pumping) were $55,000 capital
(2,300/cu m/min ($6,100/mgd) and $2,500/ha ($l,000/acre) drainage area) and
$2,000/yr operation and maintenance. In addition $13,000 in capital costs
were incurred at Syracuse for pumping; if an automatic pipe and nozzle
washdown system were installed, it would cost an additional estimated $3,500.
Swirl cost curves (Fig. 13) were developed on the basis of capital costs
experienced at Syracuse and full-scale cost estimated for another study.
It is assumed that maintenance requirements will be similar for the swirl
regulator independent of size and that the person-hour requirements and
associated costs will be 88 hrs/yr and $l,800/yr, respectively, as previously
stated.
The West Newell Street design matching full-pipe flood conditions could
be overly safe for pollution control; especially for larger outfalls. It is
entirely possible to reduce capital costs to: $500/ha - $l,250/ha ($200/acre
$500/acre) and $380/cu m/min ($l,000/mgd); in lieu of the thousands of
dollars per acre and mgd cost figures used for the $30 billion national
estimate for controlling combined sewer overflows (cited earlier in this
paper.)
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10-
o
o
o
s 4
2 -
0-
Legend
o Reference 9
A Swirl Prototype, West Newell St.
Syrocuse, New York, USA
(As built without pumping.)
D Swirl Prototype, West Newell St
Syracuse, New York, USA
(Projected for 100% grit removal
based on reference 9)
100% Grit Removal
90% Grit Removal
852
324
1698
645
2550 3396 Design Flow Rate, cum/mm
96.9 1290 Design Flow Rate, mgd
Fig. 13. Estimated Construction Cost Curves—Swirl Regulator/
Separator, West Newell Street, Syracuse, New York
SWIRL ADAPTABILITY TO SEPARATE STORMWATER.TREATMENT
Swirl devices- also offer benefits for erosion control and separate
stormwater pollution abatement. A portable swirl has been developed for
erosion control using low-cost cattle watering tanks for the "shell."
Swirl chambers can be installed on separate storm drains before discharge
and the resultant concentrate can be stored in relatively small tanks
since concentrate flow is only a few percent of total flow. Stored con-
centrate can later be directed to the sanitary sewer for subsequent treat-
ment during low-flow or dry-weather periods, or if capacity is available
in the sanitary system the concentrate may be diverted to the sanitary
system without storage. This method of stormwater control would be
cheaper, in many instances, than building hugh holding reservoirs.
CONCLUSIONS
The dual-functioning swirl unit is the first regulator device of its
type in the USA to offer the basic advantage of simultaneously controlling
the quantity and quality of combined sewer overflow. It is a simple, low
cost, and practical facility that can effectively reduce significant portions
of grit, settleable solids, BOD,., and floatables over a wide range of varying
overflow rates.
Many combined sewer overflow regulators malfunction or do not give
adequate flow control and need replacement. As combined sewer systems are
upgraded and improved regulators are constructed to reduce the impact of
overflows on receiving water quality, the swirl concentrator must be
considered.
There is excellent potential of using the swirl concept for separate
stormwater treatment and erosion control.
In many locations additional treatment may be required.
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REFERENCES
American Public Works Association (1970) Combined Sewer Regulation
and Management-A Manual of Practice. U.S. Environmental Protection
Agency, 11022 DMU 08/70, Washington, D.C.
American Public Works Association (1970) Combined Sewer Regulator
Overflow Facilities. U.S. Environmental Protection Agency, 11022 DMU
07/70, Washington, D.C.
American Public Works Association (1972) The Swirl Concentrator As A
Combined Sewer Overflow Regulator Facility. U.S. Environmental Pro-
tection Agency, EPA-R2-72-008, Washington, D.C.
Field, R., (1974) Design Of A Combined Sewer Overflow Regulator/Con-
centrator. Jour. Water Poll. Control Fed., 4j5 1722.
Sullivan, R.H., e^ aJ. (1974) Relationship Between Diameter and Heights
for the Design of a Swirl Concentrator as a Combined Sewer Overflow
Regulator. U.S. Environmental Protection Agency, EPA-670/2-74-039,
Washington, D.C.
American Public Works Association (1967) Problems of Combined Sewer
Facilities and Overflows - 1967. U.S. Environmental Protection Agency,
11020 12/67 (WP-20-11) Washington, D.C.
Field, R., and Struzeski, E.J., Jr. (1972) Management and Control of
Combined Sewer Overflows. Jour. Water Poll. Control Fed., 44, 1393.
Field, R., (1973) The Dual Functioning Swirl Combined Sewer Overflow
Regulator/Concentrator. U.S. Environmental Protection Agency,
EPA-670/2-73-059, Washington, D.C.
Sullivan, R.H., jit al. (1975) The Helical Bend Combined Sewer Overflow
Regulator. U.S. Environmental Protection Agency, EPA Contract No.
68-03-0272, Cincinnati, Ohio. (At Press)
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A REVIEW OF EPA's URBAN RUNOFF
POLLUTION CONTROL RESEARCH PROGRAM
It's a pleasure to be here today. I have been working on
the urban runoff problem for a few years and have come to recog-
nize the severity of the problem. Without the consideration of
potential pollution from stormwater runoff in our municipal
and regional abatement plans, there is a good chance that com-
munities could upgrade their dry-weather flow pollution control
and still not attain desired water quality.
208 Planning will help to overcome a possible oversight
of stormwater pollution. I am hopeful that this seminar will
help supply you with the necessary planning tools and concepts
for the control of stormwater and combined sewer overflow pol-
lution.
Now I would like to introduce you to the EPA Urban Storm-
water Research Program and a Program film entitled, "Stormwater
Pollution Control: a New Technology".
The Storm and Combined Sewer Pollution Control Research
Development and Demonstration Program was initiated under
the U. S. Environmental Protection Agency's (EPA) predecessor,
the U. S. Public Health Service, back in 1964. In an early
report published in 1964, the nationwide significance of pol-
lution caused by storm-generated discharges was first identified.
Congress acknowledged the problem ten years ago by authorizing
funds under the Water Quality Act of 1965 for researching ways
of stormwater pollution management. The effort is being con-
tinued under PL 92-500, and is directed by the Storm and Com-
bined Sewer Technology Program located in Edison, New Jersey
and under the Municipal Environmental Research Laboratory
of Cincinnati.
Up to the present time, more than 140 projects totaling
approximately $100 million have been awarded. EPA's share is
about one-half the total, or about $50 million. The present
Fiscal Year '76 extramural program budget is approximately
$1.0 million.
The Program has two basic facets. The first is problem
definition which leads to the second facet—development of
effective control alternatives. Program results will be dis-
cussed in terms of these two facets.
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PROBLEM DEFINITION
The background of sewer construction lead to the present urban
runoff problem. Early drainage plans make no provisions for
storm flow pollutional impacts. Untreated overflows occur
from storm events giving rise to the storm flow pollution
problem.
Simply stated, the problem is: When a city takes a bath,
what do you do with the dirty water?
Three types of discharges are involved: Combined sewer over-
flow, storm drainage from separate storm systems, and over-
flow from infiltrated sanitary lines.
The problem constituents in overflows are: visible matter,
infectious bacteria, organics and solids, and , in addition,
include nutrients, heavy metals, pesticides and oils.
The average BOD concentration in combined sewer overflow is
approximately one-half the raw sanitary sewage BOD. But storm
discharges must be considered in terms of their shockloading
effect due to their magnitude. Urban runoff flowrates from an
average storm intensity of 0,i"/hour are 5 to 10 times greater
than the dry-weather flow from the same area. Likewise, a not
uncommon rainfall intensity of 1'Vhour will produce flowrates
50 to 100 times dry-weather flow. A few municipal studies can
serve to exemplify the problem. In Northampton, England, it was
found that the total mass of BOD emitted from combined sewer
overflows over a two-year period was approximately equal to the
mass of BOD emitted from the secondary plant effluent. And that
the mass emission of suspended solids in combined sewer over-
flow was three times that of the secondary effluent. In Buffalo,
a study concluded that 20 to 30% of the dry-weather flow solids
settled in the combined sewer which was subsequently flushed
and bypassed during high-velocity storm flows. In Durham, N.C.,
with a separate stormwater system, it was shown that an upgrading
program to zero discharge without stormwater treatment would
still allow 41% of the UBOD and 95% of the suspended solids to
enter the receiving water from runoff, and that runoff governs DO
levels suppressed below the standard 20% of the time. A general-
ization from 10 to 12 city studies indicates 40-80% of the total
BOD load entering streams comes from runoff and, during storm
events, the organic loading from runoff is as much as 94-99%
of the total.
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CONTROL ALTERNATIVES
The concept of constructing new sanitary sewers to replace
existing combined sewers has largely been abandoned due to
enormous costs, limited abatement effectiveness, inconvenience
to the public, and extended time for implementation.
I will present the viable control alternatives. We can con-
trol the problem at the source, e.g. at the land and streets,
in the collection system, and off-line by storage. We can re-
move pollutants by treatment and by employing complex or inte-
grated systems which combined various combinations of control
and treatment including the dual use of dry-weather facilities.
Source Control
Source control can be accomplished by employing porous pave-
ment and upstream impoundment for flow attenuation; soil
erosion preventative measures; restrictions on chemicals used
for de-icing, fertilization, and pest control; zoning and land
use regulations, and improved neighborhood sanitation practices.
Sewerage System Control
In sewerage system control, the emphasis is on optimizing the
existing collection system. Measures which can be used include:
- Dry-weather flushing to reduce dry-weather solids accumulation
and thereby relieving the overflow first flush
- Polymer feed to reduce overflows by increasing pipe-carrying
capacity
- Infiltration/Inflow prevention and correction
- Improved flow regulators or diversion devices, e.g. the swirl,
helical and fluidic types
- In-sewer or in-line storage and routing whereby the intent is
to assist a dispatcher in routing and storing storm flows to
make maximum use of existing interceptors and sewer line capacity
- And lastly, the most common approach is off-line or external
storage with concrete tanks used often. The concept is to
capture wet-weather flow and bleed it back during low-flow,
dry-weather periods.
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Treatment
The various treatment methods used for stormwater include phys-
ical and physical-chemical, biological and disinfection. These
processes or combinations of these processes, can be adjuncts to
the existing sanitary plant or serve as remote satellite facili-
ties at the outfall.
Integrated Systems
By far the most promising approach to urban stormwater manage-
ment is the integrated use of control and treatment with an
area-wide multidisciplinary perspective.
- Dual-use wet-weather storage and treatment facilities in
conjunction with dry-weather plans can be used to improve
dry-weather treatment the vast majority of the time when it
is not raining. The program has fostered various schemes
which reclaim stormwater for beneficial purposes including
the enhancement of visual aesthetics, recreation and water
supply.
- Land management and non-structural techniques are ways of
reducing cost by limiting pollutants to the potentially more
costly downstream treatment plans.
- A great deal may be saved by joining the heretofore autonomous
agencies and professions involved in flood, erosion, and pollu-
tion control. We can cut cost by integrating drainage and
reservoir design for flood control with pollution control.
Computer Assistance
Mathematic models are needed to predict complex dynamic system
responses to variable and stochastic climatological phenomena.
These models have been developed and applied at many levels of
sophistication including EPA's Storm Water Management Model
(SWMM) which is capable of representing the gamut of urban
conditions both qualitatively and quantitatively from the up-
permost catchment point to the downstream receiving water.
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EPA FILM "STOBMRATFR POLLUTION CONTROL: A NEW TECHNOLOGY"
The film^- I am about to introduce portrays a complete overview of
the U.S. EPA's involvement in developing countermeasures for pol-
lution from combined sewer overflows and stormwater discharges.
Various countermeiasures are shown by the film that are ready for
implementation by municipalities. The majority are full-scale
operations.
A couple of years ago, we felt that the time was right to make an
evaluation of previous Program efforts, and we implemented a contract
to develop the state-of-the-art and assess techniques available to
manage and treat combined sewer overflow and stormwater. A text
on this subject has been completed. Expanding on the cliche, "a
picture is worth a thousand words," we felt a film would be worth
a hundred thousand—so a film was included as part of the work.
The specific reasons fo r this film were to alert the environmental
engineering and planning community to the stormwater problem and
the immediate need to apply available technology to counteract it.
"Stormwater Pollution Control: A New Technology", U. S. Environ-
mental Protection Agency. A 16 mm sound-color film available from
the National Audivisual Center (GSA), Washington, D. C. 20409
(Prices: Purchase - $119.50, Rent - $12.50)
"Urban Stormwater Management and Technology: An Assessment",
EPA-670/2-74-040, U. S. Environmental Protection Agency.
Available from the Storm and Combined Sewer Section, Municipal
Environmental Research Laboratory, Edison, New Jersey 08817
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URBAN RUNOFF POLLUTION DATA BANK
Yesterday the need for retrieval and interstudy trans-
fer of existing data was mentioned along with the need for
208 agencies to join together for this purpose. I would
like to advise you that there is an existing EPA R&D
project* to compile a computerized urban runoff pollution
data resource and retrieval center at the University of
Florida at Gainesville under ProfessorsWayne Huber and
Jim Heaney. All data has and is being thoroughly screened
for goodness before system entry.
This system will be available to you and I recommend
its use as an expeditious focal point for entry and re-
trievel of data from 208 studies. This will require the
cooperation and effort of the 208 agencies, but its poten-
tial value should make the effort worthwhile. I will be
talking with 208 people in EPA in an attempt to develop a
uniform method for this proposal but, in the interim, you
are encouraged to contact the University of Florida on your
own not only for data retrieval, but I would also hope for
data entry as well.
"Collect and Define Availability of Test Data (Rainfall/
Runoff) for Urban Models - Data Base," EPA Contract
No. 68-03-0496.
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URBAN STORMJATER DETENTION AND FLOW ATTENUATION
FOR WATER POLLUTION CONTROL
by
Herbert G. Poertner
Engineering and Research Consultant
Bolir.gbrook, Illinois
DETENTION AND FLOW ATTENUATION
Definitions
"On-site detention" of stormwater generally refers to storage of precipi-
tation runoff excess prior to its entry into a drainage system, followed by
gradual release of the stored runoff during and after the peak of the runoff
has passed. In some applications, the runoff may first be conducted short dis-
tances by collector sewers located on or adjacent to the site of the detention
facility. On-site detention is usually differentiated from downstream deten-
tion by its proximity to the upper limits of the basin and its use of small de-
tention facilities as opposed to larger dams normally associated with downstream
detention.
Use of the terms "detention" and "retention" is often confusing. Deten-
tion generally refers to holding runoff for a short period of time and then re-
leasing it to the natural water course where it returns to the hydrologic cycle.
"Retention" involves holding some of the water contained in the storage facility
for a considerable length of time for aesthetic, agricultural, consumptive, or
other uses. Some of the water may never be discharged to a natural watercourse,
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but it may be consumed by plants, evaporation, or infiltration into the ground.
Detention facilities will not reduce the total volume of surface runoff,
but simply reduce peak flow rates by redistributing the runoff over a time period.
However, there are exceptions; e.g., the reduced surface runoff volume from land
areas that have been contour-plowed, and the reduced surface runoff from deten-
tion basins on granular soils.
A comprehensive report entitled "Practices in Detention of Urban Stormwater
Runoff" was prepared in 1974 for the Office of Water Research and Technology,
U.S. Department of the Interior. This report addresses most aspects of urban
runoff detention and presents information obtained in a nationwide study of
detention practices.
Concept and Benefits
The concept of temporarily storing, or detaining, excess stormwater runoff
and then releasing it at a regulated rate is an important fundamental principle
in stormwater management. Storage is extremely important in areas having appre-
ciable topographic relief for the purpose of attenuating peak flow rates and
the high kinetic energy of surface runoff. Such flow attenuation can reduce soil
erosion and the amounts of contaminants of various kinds that are assimilated
and/or transported by urban runoff from land, pavements and other surfaces.
While in storage, the pollutant concentrations in runoff will often be re-
duced somewhat through natural processes. Before release, the stored runoff
may be given further treatment as may be necessary or practical. Finally, by
means of controlling release flow rates, the impact of the pollutant loadings
of stored runoff on receiving water quality can be minimized, regardless of the
degree of treatment provided.
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In areas where combined sewers are utilized to transport stormwater runoff,
the use of detention facilities can relieve the peak loadings on sewers and treat-
ment plants—thereby reducing the pollution and flooding of basements, streets,
land and water bodies. Where storm sewers are used to convey runoff, a system
of properly designed detention facilities can also be effective in reducing
pollution and flooding from stormwater. In areas of flat terrain where hydraulic
gradients are small, detention of runoff can be an important factor in reducing
local flooding and in minimizing storm sewer pipe diameters.
Because stormwater detention facilities cause a distinct reduction of run-
off velocities, much of the debris and suspended solids transported by runoff
flows will settle out. This provides an opportunity to collect the sediments
before entering and causing problems in the collection sewer system, treatment
facilities or downstream channels and land areas. In some places, it is common
practice to provide detention basins; for the collection of sediment produced
from stormwater runoff.
The use of on-site detention i'acilities may be dictated by governmental
ordinances or may be chosen by a developer, at his own discretion, as a method
for reducing costs for drainage facilities. Sometimes detention ponds are
built to form the core of blue-green areas in open space developments, parks,
and other planned urban developments. Regardless of the reason for the facilities,
if they are carefully designed, built, operated and maintained, the result is
the same—"attenuation of peak runoff flow rates". Many fringe benefits, not
identified above, can result as a by-product of on-site detention.
Generally, detention storage may be provided in one or a combination of
different locations: (1) on, or near, the sites where the raindrops fall; (2)
in stornwater collection and conveyance systems; or (3) in downstream impoundments.
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The remainder of this paper deals with various means for detaining excess storm-
water runoff, both above the ground surface and underground.
STORWATER DETENTION METHODS AND APPLICATIONS
Underground Storage Versus Aboveground Storage
Underground storage of stormwater runoff usually involves transporting
the excess runoff in sewers or channels prior to storage. The storage facilities
must sometimes•be located away from the site where the runoff is generated and
collected. In this respect underground storage differs from aboveground storage
that may be provided on rooftops of buildings and parking lots, and in basins
or ponds located within land development sites or open space areas. However,
for both underground and aboveground storage, the goals are the same, generally--
to control water pollution and flooding of land and property. Corollary goals
are to protect and enhance natural resources, urban environments, public health,
and social and economic values.
The concept of attenuating peak flow rates in sewer systems and other
flowways, prior to treatment or release of wastewaters, is also the same for
both underground and aboveground storage. The principal advantage of underground
storage as compared to aboveground storage in urban areas is the better avail-
ability and lower cost of space for storing large volumes of stormwater runoff
or combined sewage. Aesthetics, health factors, environmental considerations
and economic and social objectives may also be better served by underground
storage facilities.
Aboveground storage of excess stormwater runoff presents some advantages
not inherent in underground storage systems. Foremost are the lower operating
and maintenance costs possible with aboveground storage and the greater oppor-
tunities afforded for multiple-purpose use of facilities—especially wildlife
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preserves, recreation and landscape enhancement. In some places, it may be
feasible to divert stored runoff by gravity flow for land irrigation and for
supplementing local raw water supplies. In either aboveground or underground
storage, stormwater excess may be used under favorable conditions for recharg-
ing ground water supplies.
Regardless of how, or where, stormwater runoff or combined sewage is col-
lected and detained, the important consideration is that it has been isolated
and captured! This makes feasible the best practical methods for its further
handling to minimize pollution and flooding. For example, if treatment is se-
lected, the stored runoff or combined sewage may be released to treatment facil-
ities at flow rates that are compatible with treatment plant capacities. Or, if
flooding caused by high rates of runoff into the stormwater drainage system is a
problem, the peak flow rates can b«> controlled to reduce the flooding impacts.
Basins and Ponds on Ground Surfaces;
Usually, retention ponds and detention basins constructed on ground sur-
faces are relatively large, covering several acres. The design of such facili-
ties will vary depending upon land costs, space availability, phsical and
aesthetic characteristics of the area, topography, climate, hydrologic conditions,
and other local factors. Whether or not a detention facility is to serve multi-
ple-purpose uses is a factor that may dictate size, shape, depth, landscaping
treatment and whether it will be designed to retain a minimum depth of water.
For example, a retention pond may be designed with special features to serve as
a recreation pond for boating and fishing. Such a facility would require differ-
ent design criteria than a basin which is to fulfill the single purpose of storm-
water detention. In other instance-.s, the availability of large open areas will
permit a design having gentle side slopes and extensive landscaping; while sites
where land is limited might dictate deep ponding areas, pumped discharge, and
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steep side slopes that require fencing and other security measures to minimize
safety hazards.
Detention basins are sometimes used to collect eroded soil and debris for
later removal and disposal. Sediment collection basins are frequently used dur-
ing periods when land development operations are underway. The purpose is to
intercept eroded soils, debris and their associated contaminants to preclude
their entry into sewer systems and water bodies. This technique can be an im-
portant factor in reducing blockage of flows in drainage systems and treatment
facilities and to reduce the pollutant loadings from surface runoff and storm
sewer discharges.
Both the State of Maryland and Fairfax County, Virginia have programs to
control sediment using detention ponds. The topography of these areas is steep,
and stormwater runoff can quickly cause problems of erosion and sedimentation
if suitable precautions are not taken. Ponds are used during construction per-
(2)
iods and after development. Maryland's program was started in the 1930's
In 1970, the Montgomery County Soil Conservation District adopted a resolution
to encourage and assist in the planning of stormwater drainage, utilizing the
greatest amount of detention considered feasible. In 1970, the State enacted
the Sediment Control Law which required all countries to implement the law by
March 1, 1971.
At the present time, there are over 175 permanent detention ponds in Mont-
gomery County. Acceptance of the concept is not universal, although complaints
have not been severe enough to take the matter to court. Three main objections
to the program have arisen. One is that responsibility for maintenance of
these ponds is still being debated. Another major objection is the lack of
knowledge concerning the usefulness of the detention concept. The argument is
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that the long-term effect of such storage is not known, and that corollary dis-
advantages may outweigh the gains. The third major criticism concerns the legal
status of the requirement. Although the legal counsel of the State and Mont-
gomery County have offered their opinions that such measures are legal, without
a court testing of these opinions,the legal status is actually unresolved. How-
ever, the complaints against on-sit« detention storage have not yet become so
serious as to cause a developer or "'.and owner to take the matter to the courts.
Even though there is some opposition to the on-site detention concept on a short-
term basis, the method is seem to be effective for controlling this major pol-
lution problem. Stormwater detention facilities are especially popular as a
temporary measure during construction; however, they are also useful for perman-
ent solution of erosion, sediment and pollution problems, as well as flood control.
Parking Lot Storage
Temporary storage of stormwat&r on parking lots is another means employed
to reduce runoff rates and sewer loading. Unlike ponding on rooftops, there is
no limit, from a .structural standpoint, to the depth of water that can be stored.
Another advantage is that the surface does not need to be dead-level as is true
in the case of rooftop ponding. Because of the ease of inspection and access,
the maintenance and operation of parking lot detention facilities is a low cost
item and easy to perform with mechanical street cleaning equipment.
There are two general forms of stormwater detention on parking lot surfaces.
One form involves the storage of runoff in depressions constructed at drain lo-
cations. The stored water is drained into the sewer system slowly, using restric-
tions, such as orifice plates, in the drain. Proper design of such paved areas
would restrict ponding to areas which will cause the least amount of inconveni-
ence to the users of the parking areas. For example, the parking lot of a shop-
ping center would have the ponding areas located in the least-used portions of
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the lot, allowing customers to walk to their vehicles in areas of no ponding
except when the entire lot is filled with vehicles. Drainage of ponded water
would be fairly rapid as compared to rooftop ponding to prevent customer in-
convenience. In most cases, the water would pond to a depth not to exceed 12
inches and the ponding area would most likely be drained within 30 minutes, or
less, after the rainfall.
Another type of stormwater detention on parking lots consists of using
the paved areas of the lot to channel the runoff to grassed areas or gravel-
filled seepage pits. The flow then infiltrates into the ground. Soil conditions
and the effects of siltation in reducing infiltration must be considered. As
an example of this method of detention, Miles Laboratories, Inc. has developed
parking lots utilizing a pervious median strip to handle storm drainage as
shown in Figure 1, Parking Lot Details. Designs of this type reduce construc-
tion costs of the drainage system because smaller diameter storm sewers can be
used. Such median strips are aesthetically pleasing and can be used for storage
of plowed snow in the winter. The possibility of polluting ground water should
be investigated, particularly if no confining soil strata is present.
The large area which is characteristic of many parking lots serving
shopping centers, office buildings, apartment complexes and industrial plants
is a factor that makes such parking lots extremely attractive for stormwater de-
tention. In one application at an apartment complex in Boulder, Colorado,
paved portions of the parking lot and the grass areas between buildings were
dished to store runoff for regulated, slow release through sewer inlets provided
with steel orifice plates. Large volumes of rainfall and snowmelt can be stored
in this manner with little personal inconvenience.
A parking lot drainage system incorporating detention can often be con-
structed at a cost below that for a conventional design. For example,
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•New trees and light posts
to line up with gap between
concrete bumpers.
See Landscape Guide
Existing Tree
Alternate ground
cover and stone beds
Slack concrete bumpers
Ground Covur
YCAjuga, Ivy, Eunoyinus, etc.)
X -
8' to 10'
— 8' - 10'-
Thru Ground Cover Bed
8' to 10'
Oversized washed native stone
Cross-Section
Thru Stone Topped Bed
s--Pea Gravel
details of median strip for parking lot drainage
Source: Miles Laboratories, Inc.
Building Construction Standards
FIGURE 1. PARKING LOT DETAILS
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Consolidated Freightways, Inc. used stormwater detention techniques in construc-
ting a parking area and storm sewers at its truck terminal in St. Louis, Missouri.
The $ 115,000 cost of the drainage system constructed was $ 35,000 below the
estimated $ 150,000 cost of a system without provisions for on-site detention.
If porous pavements are used extensively in the future in parking lot con-
struction, large volumes of rainfall can be made to seep into the ground instead
of being discharged into sewers or streams. This can be an important corollary
advantage of stormwater detention facilities in water-short areas. Climate,
soil conditions and the possibility of polluting ground water supplies must be
considered in the planning and design of such facilities.
Rooftop Detention
Horizontal rooftops are used in some places for stormwater detention.
Rooftops can provide storage which will not inconvenience pedestrians or motor-
ists. A rooftop detention facility is not unsightly because it is not visible,
and it is not a safety hazard to children. However, rooftop storage is not a
problem-free method as there are problems of leakage, possible structural over-
loading, maintenance for removal of debris and ice and the possiblity that heavy
rainfalls will overflow the top of the roof if drains become blocked. This
could result in serious damage to the building and its contents.
These problems can be minimized by proper design, especially if detention
is designed into the original building plans and not provided later as an after-
thought. For example, leakage problems can be reduced by adding extra layers
of roofing membrane and by taking special care in installing ^oof flashings to
make a watertight seal. Structural design should not be a problem in northern
climates, as building codes currently specify adequate strength for snow load-
ings, usually 30 to 40 pounds per square foot. With the weight of water being
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62.4 pounds per cubic foot, a properly designed roof will have the structural
strength to handle almost 6 inch€'S of water depth , an amount that is more than
sufficient for fulfilling the requirements of on-site detention of rainfall.
Maintenance is a bit more difficult and will require periodic attention,
especially in the autumn during and after the leaf-falling season. However, all
horizontal roofs in urban areas would need such maintenance and the added effort
to maintain a roof designed to detain rain water should not be unreasonable.
In many cases, the roofs will be sufficiently high or the buildings will be lo-
cated in areas where maintenance would not be a problem, because debris would
not accumulate enough to cause a blockage of the roof scuppers, gutters or rain
leaders.
The possibility of overflows is present with any roof structure, although
it is more likely when stormwater is stored on the roof. One alternative usually
required by building codes is the use of overflow drains and scuppers in the
parapet wall, usually about four inches above the roof drain. Proper maintenance
and periodic inspection will reduce the possibility and the hazards of overflows.
The recently-completed 25-story office tower constructed for the Prudential
Insurance Company in the Skyline Jrban Renewal area was designed to detain rain-
fall on its roof and in plaza areas. A specially designed rainfall ponding
ring designed by a local engineering firm was installed surrounding each roof-
drain conductor head. It is designed to operate in accordance with drainage
criteria of the Denver Urban Renewal Authority (DURA). Engineering details of
the ponding ring are given in Figure 2.
The Park Central Bank and Office Complex recently constructed in the Sky-
line area incorporates rooftop ponding and ponding in arcades. Detention pond-
ing is also being provided in the depressed parkway extending along one side of
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Notes.
Roof Drain Ring is Placed Around
Standard Roof Drain Installation.
Number of Hole Sets and Ring Diameter
to be Based on Roof Area Drained and
Runoff Criteria Minimum Spacing to be
2"c c
Height of Ring Determined by Roof
Slope
Use Brass or Stainless Steel
PLAN
Rainfall Detention Ponding Ring
fDia Hole
One Set of Holes
Vertical
Leoder-
PERSPECTIVE
SECTION
rooftop detention devices
Source: Wright-McLaughlin Engineers.
Denver, Colorado
FIGURE 2.RAINFALL DETENTION PONDING RING FOR FLAT ROOFS
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the block adjacent to the abutting street. This public park was constructed
over the roof of an underground parking garage that is privately-owned. The
operation and maintenance of the parkway and its drainage facilities are handled
by the Denver Park District.
Inquiries made of about 25 major cities and all national building code or-
ganizations in the United States uncovered no codes prohibiting the use of roof-
tops for storing rainfall. Detention usually is not mentioned in local building
codes; however, it is covered specifically in some codes such as the building
codes of New York City, Detroit and the Denver Urban Renewal Authority. The
building code of Detroit, Michigan includes special design criteria for rooftop
detention,including: a dead-lev€:l roof, provision for control of algae, mos-
quitos and other insects, the minimum number of downspouts per roof area, and
the roof drainage rate.
Abatement of Pollution from Combined Sewer Overflows
In areas having combined sewers, there is much interest' in detention stor-
age of urban runoff as a means of abating pollution of receiving streams and re-
ducing flooding caused by overflows from such sewers- For more than ten years
the city of Chicago has been studying various means that could be implemented
to prevent the periodic piollution of local waterways and Lake Michigan by over-
flows from its combined sewer system. The pollution comes from required re-
leases of combined sewage into the local waterways, and sometimes the Lake, at
times when sewers, drainageways and" treatment plants cannot handle the high flow
rates generated by runoff from intense rainstorms. The Metropolitan Sanitary
District of Greater Chicago is beginning the implementation of a system of under-
ground storage of combined sewage. The $ 1.5 billion project involves the
construction of 125 miles of large-diameter tunnels and reservoirs for temporary
storage and conveyance of combined sewage in Silurian Dolomite rock formations
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at depths of 150 to 290 feet below the surface of the waterways. Tunnel dia-
meters, ranging between 10 feet and 42 feet, will receive flows from 640 sewer
overflow points in the 375 square mile area served by the system. Figure 3
highlights the Tunnel And Reservoir Plan.
During periods when the collection sewers and interceptor sewers are over-
loaded and the capacity of the three existing treatment plants are over-taxed,
the combined sewage will be diverted from interceptor sewers through vertical
shafts to the tunnels. Later, when the sewage flows diminish below surface
sewer capacities and the treatment plants are capable of treating the flows,
the stored mixture of sewage and stormwater will be pumped to one of three new
surface reservoirs for detention and subsequent release at predetermined rates
to the wastewater treatment plants.
The primary reservoir facilities are located in the area now occupied by
the sludge lagoons of the Metropolitan Sanitary District in the McCook-Summit
area. Excavation is to be performed by the quarry method. The reservoir will
be 330 feet deep, 500 to 1200 feet wide and 2.5 miles long. It will be divided
into three basins with a total storage capacity of 57,000 acre-feet below Eleva-
tion-100, Chicago City Datum. Although the Chicago Tunnel and Reservoir plan
is not truly "on-site" detention, as previously defined, the goal and concept
is similar. The primary objective is to abate pollution of receiving waters
and real property, and reduce local flooding, by means of attenuating peak flows
in the sewers and surface drainage system.
Combined sewers serve 24,000 acres of the City and County of San Francisco,
with systems of interceptors delivering sanitary wastes to three existing sewage
treatment plants. To control the pollutants discharging to San Francisco Bay
and the Pacific Ocean, a master plan has been developed by the city and county
(4)
based upon several years' studies. The objectives of the master plan are the
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RESERVOIRS
a TREATMENT
Ti" !.... r :/'^ I)
—R I, ' -' / )A
Source: "Summary of^Technical Report s"
Flood Control Coordinating Committee
August 1972 .
FIGURE 3. CHICAGO TUNNEL AND RESERVOIR PLAN
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preservation and enhancement of the quality of the waters of the Bay and the
Pacific Ocean and the protection of these waters at all times for all beneficial
uses.
The master plan incorporates an optimum mix of transport capacity, storage,
and treatment. It retains the combined sewer system, up-grading the inadequate
sewers by restoring about one-third of them to adequacy through the judicious
selection of detention storage sites. Some of the existing sewers will be re-
placed or supplemented with relief sewers. Detention storage of stormwater and
combined sewage is planned in underground concrete tanks at shallow depths near
the shoreline, and in upstream basins and tunnels. Figure 4 presents a perspec-
tive and section through a typical shoreline detention structure. The tunnels
are designed and located to serve as both storage and transport facilities.
This will permit controlled interchange of flows and storage between sub-water-
sheds as varying storm patterns over the area overtax the facilities of some
sub-watersheds. The master plan proposes a single treatment plant (in the
southwestern corner of the City) having a capacity of 1,000 mgd and outfalls
to the Pacific Ocean. Financing and implementation schedules must yet be
arranged.
Boston, Massachusetts, is another city which has considered the use of
deep tunnels to store combined sewer overflow. The city has about 7,000 acres
served by combined sewers plus another 10,000 acres served by separate sewers
that connect to the combined sewer system. In addition, there are about 6,700
acres in neighboring communities which are also tributary to the combined sewer
system.
An engineering report prepared in 1967 proposed that, in the area of separ-
ate sewers, the stormwater should be diverted to separate outflows where feasible.
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11-134
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In the areas where this is not feasible, estimated at 3,300 acres, the stormwater
runoff should continue to flow into the combined sewers. A deep tunnel was pro-
posed for the outflows of Boston's combined sewers plus the outflow from the com-
bined sewers of four neighboring communities. Total area tributary to the deep
tunnel plan would be 17,000 acres.
The deep tunnel plan was selected over three alternative plans. Construc-
tion cost estimates based on 1967 prices, were found lower for the tunnel plan.
Although part of the decision to recommend the system was based on cost, other
factors included land requirements and adequacy of the system to perform under
severe conditions. From a cost standpoint, it is thought that the deep tunnel
plan should be more economical(percentage-wise) now than it was in 1967. The
plan has been approved by the City of Boston and the Commonwealth of Massachusetts.
Figure 5 highlights the plan.
The tunnel system will be able to handle a 15-year rainfall event of five
inches of rainfall in 24 hours without surcharging,and an 8.4-inch, 24-hour
rainfall (the maximum recorded in Boston) with surcharging of the tunnel. Rain-
falls in excess of 8.4 inches in a 24-hour period are possible, but the sewer
system in Boston is unable to carry more than this amount of rainfall.
It was proposed that 17.2 miles of 33-ft diameter tunnel be constructed
along with a pumping system capable of handling 2,400 cfs under normal con-
ditions; and 5,200 cfs under the conditions of surcharging-caused by the 8.4-
inch, 24-hour storm cited. If a short outfall is utilized, these pumps would
be able to handle larger rains than the maximum recorded. The proposed outfall
would be a 20-ft diameter pipe extending 45,000 feet out to sea, where the com-
bined sewage and stormwater would be discharged through diffuser piping giving
a minimum of 200 to 1 dilution, which was deemed adequate to meet water quality
standards. Implementation of the plan is uncertain at present.
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FIGURE 5. BOSTON DEEP TUNNEL PLAN
Source: "Improvements to the Boston Main Drainage System
Camp, Dresser & McKee, Inc, 1967
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Some cities and metropolitan areas in the United States have initiated
"in-system storage" techniques for minimizing water pollution and flooding from
combined sewer overflows. The Municipality of Metropolitan Seattle has instru-
mented the combined sewer system serving the City of Seattle. The computer-con-
trol system, known as CATAD (Computer Augmented Treatment and Disposal), regu-
lates flows through the West Point trunk sewers and interceptors. The flows of
combined sewage are regulated to take advantage of excess storage capacity avail-
able at various sections of the sewer network during heavy flows produced by
rainstorms. This prevents frequent overflows of untreated sewage into Lake
Washington, the Duwamish River and Puget Sound.
The Metropolitan Sewer Board serving the Minneapolis-St. Paul metropolitan
area of Minnesota has also implemented a computer control system for monitoring
sewage flows in its combined sewer system. The purpose is to minimize pol-
lution from sewage overflows by optimizing the storage capacity of the sewers.
Other jurisdictions have successful programs for minimizing overflows from
combined sewers, as well as separate sanitary sewers. For example, the Spring-
field Sanitary District, serving Springfield, Illinois initiated a campaign in
1960 asking citizens to remove connections of roof drains from both combined
sewers and sanitary sewers. The purpose was to relieve backups of sewage into
basements of residences and business buildings. The program, based on voluntary
citizen cooperation, was extremely successful and was accomplished at a very low
cost to the community. Ironically, this program is not an example of pollution
control by detention methods; rather, it is the reverse of detention. It is
illustrative of how pollution of citizens' property was reduced by removing the
cause of unwanted storage of wastewaters in basements. A detailed account of
the Springfield program was published in 1969 in the Journal of the Water Pol-
lution Control Federation.
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Some other cities have programs similar to Springfield's, and a few, such
as Bensenville, Illinois, in Cook County, have also required removal of connec-
tions of foundation drains to sewers.
In all of the examples given in this section, the control methods vary
but the goal and concept is the: same for each—namely, abatement or reduction
of pollution and flooding by flow attenuation in sewers and drainageways.
PLANNING AND DESIGN OF DETENTION FACILITIES
Planning and Impact Analysis
It is important that planners and designers of stormwater detention facili-
ties give careful consideration- to identifying and evaluating the probable im-
pacts of the completed facility. Such impacts can be classified broadly as
social, economic, political and physical (environmental and ecological). Both
planners and designers can influence the positive or negative aspects of these
impacts by their evaluations of available alternatives and decisions made during
the design process. It seems prudent that they give special attention to con-
sideration of the following:
(a) safety of people and wildlife,
(b) protection of real property, wildlife habitats, and natural resources,
(c) environmental enhancement of the local area,
(d) multiple-purpose use of facilities,
(e) lowest annual cost of the facility that is attainable within project
constraints and community goals, and
(f) cooperation with adjacent communities and governments to promote a
watershed approach to providing stormwater management.
Engineering Design
There are six major design determinations involved in the engineering
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design of stormwater detention facilities. These are: (1) the selection of a
"design rainfall event", (2) the volume of storage needed, (3) the maximum per-
mitted release rate, (4) pollution control requirements and opportunities,
(5) identification of practical detention methods and techniques for the specific
project, and (6) selection of method(s) and technique(s) to be adopted, in view
of effectiveness, legal requirements, costs and availability of financing. Some
of these design considerations will be discussed briefly in the following.
The design rainfall event most often used was reported in a survey made
in 1972 by the American Public Works Association (APWA) to be that having a 10-
year recurrence interval. The second most common design rainfall used was given
as the 15-year frequency. A few responses indicated the use of design rain-
falls of less than the 10-year event while others indicated use of the 100-year
frequency, or greater, for design. Many engineers stated that their choice of
design rainfall frequency for a specific project is determined solely by the re-
quirements of the local public agency having jurisdiction.
The storage volume need for the design rainfall event is given by the
maximum difference, at any time, between cumulative total inflow volume and
cumulative outflow volume, starting with the beginning of inflow. This required
storage capacity can be calculated using established principles and techniques
regularly employed by hydrologists. The survey pointed out that a wide variety
of methods are used to determine the storage volume to be provided,depending
upon local circumstances. Runoff predictions are most often based on unit hy-
drographs and the Rational Formula. The basic consideration is to provide
enough storage to prevent runoff rates from causing downstream flooding with a
goal of limiting the future runoff flow rate to the historic rate. But, com-
promises are frequently made for reasons of economy or land availability.
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Representatives of some engineering firms reported that they design deten-
tion facilities to store a specific precentage of peak runoff flow. Many firms
reported that storage volume requirements are determined from provisions of lo-
cal legislation or administrative directives. For example, the Metropolitan
Sanitary District of Greater Chicago requires that the 100-year rainfall be used
in design and has established a formula for the volume of storage required.
Some engineers have found that the practical storage volume is dictated
by the multi-purpose uses planned for the detention facility. A parking lot,
for example, could be used for storage to a water-depth of only about 8 inches
before it becomes incompatible with its primary use. Similarly, the variations
of water-depth in park ponds must often be limited to improve aesthetics, fa-
cilitate recreation uses, and provide a suitable habitat for fish.
The basic design factor used in determining the maximum release rate of
stored runoff is the ability of. the downstream sewers or stream channels to
handle the flow satisfactorily without adding to erosion, sedimentation, drainage
or flooding problems. Often, this rate is based upon consideration of the ex-
pected future runoff from the watershed after planm;d land development takes
place. Or, the maximum release' rate may be limited so as not to exceed the
natural flow rate of the receiving sewers and streams that prevailed before land
in tributary watershed areas was developed.
In many cases, the limit on release rates is specified by local ordinances
and regulations. Such laws and regulations may be based upon the flood hazard
characteristics and economic" characteristics of specific watersheds. In all
cases, the selection of the maximum release rate should be based upon control-
ling erosion, pollution and flooding downstream from the detention facility
without causing a serious problem at the facility itself. For example, a deten-
tion basin in a busy parking lot should be drained faster than a detention pond
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or basin in a park because of the greater inconvenience that the flooded parking
lot would cause for many people if it were drained slowly.
Control methods reported in use for release of the detained water include
weirs, spillways, orifices, hydraulically limited outlets and control gates, in
that order of popularity. Control gates were the least popular, It was found,
due to the need to adjust them for proper control of each rainfall event.
The prevailing viewpoint of representatives of local public agencies hav-
ing jurisdiction over stormwater management in urban areas is that detention
facilities should be designed and constructed with storage capacity sufficient
to enable limiting the rate of runoff from the developed land area to the rate
that prevailed before development. Many local jurisdictions have adopted legis-
lation requiring this in new land developments. Land availability and topog-
raphy are often limiting factors, along with economic considerations, that in-
fluence decisions regarding detention methods and techniques. In all cases,
the pollutant assimulating capacity and the ^hydraulic capacity of the receiving
drainage system below the detention facility is a factor that must be considered
in determining the amount of storage necessary.
OPERATION AND MAINTENANCE
The operation and maintenance of stormwater detention facilities is an im-
portant factor in determining the effectiveness of the facility and its accept-
ability to the public. Poor operation and maintenance not only reduces the use-
fulness of detention storage, but can cause the facility to become an eyesore,
nuisance or health hazard. When stormwater detention is weighed against other
methods of runoff control, maintenance and operation is usually viewed as the
most difficult problem and the factor most often mentioned against the use of
this method. This was revealed by the surveys made by the APWA in 1972, the
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results of which are discussed next.
The answers to inquiries made of public agencies and engineering firms
clearly underline the importance; of operation and maintenance difficulties. In
each of these surveys, a question was asked to solicit the respondent's evalua-
tion of all the various possible factors that might be considered to constitute
a problem or an adverse condition that would be viewed as a disadvantage of
stormwater detention. Table 1, Apparent Adverse Factors, includes tabulations
of the responses of representatives of the public agencies and engineering firms
which responded to this question.
TABLE 1
APPARENT ADVERSE FACTORS OF ON-SITE DETENTION
(a) As Seen by Public Agencies
Factor No. of Agencies Reporting
Aesthetics of empty ponds is poor
Mosquito breeding would increase
Algal growth would occur in shallow ponds
Operation difficulties exist
Ponds are a safety hazard to children
Other adverse effects are foreseen
(b) As Seen by Engineering Firms
Factor No. of
General maintenance and operation
Sedimentation
Safety of children
Safety and/or property loss from dam failure
Mosquito breeding
Aquatic vegetation
Other
Yes
101
107
108
81
92
18
No
61
56
48
69
54
5
Firms Responding
Yes
31
26
23
21
16
14
9
No
2
7
8
10
15
16
3
Source: 1972 Survey by the American Public Works Association
From Table la, it is noted that 54 percent of the public agency respondents
feel that operation difficulties exist in connection with on-site detention of
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runoff. About two-thirds of these respondents consider that significant problems
would be encountered with aesthetics, mosquito breeding, algal, growth, and safe-
ty hazards. Table Ib shows that most design engineers feel that significant prob-
lems would be encountered with general maintenance and operation, particularly
in the areas of safety of children, property loss from failure of dams, and sedi-
mentation. About one-half of the engineers are concerned about mosquito breed-
ing and growth of aquatic vegetation.
These tables show the concern of public officials and design engineers
for problems of maintenance and operation, but they give no indication of the
seriousness of the problems. Although the responses concerning the adverse
effects of detention might indicate that these disadvantages could make storm-
water detention an unworkable method, the successful use of detention storage
shows that these problems are not sufficient in themselves to eliminate the
method as a practical solution to problems of urban stormwater runoff management.
IMPLEMENTATION SUGGESTIONS
The following suggestions are presented to serve as a guide to public
agencies in planning, designing and implementing various types of stormwater
detention facilities and programs, and stormwater management programs in general.
1. Determine the extent of stormwater pollution, drainage and flooding
problems.
2. Estimate the future extent of these problems.
3. Determine the existing water quality, hydrologic and hydraulic features.
4. Develop a set of goals and objectives for meeting present and future
requirements imposed by federal, state and local authorities.
5. Develop a master plan for action:
This plan should consider the alternative methods of stormwater management avail-
able, future urban growth in the jurisdiction involved (and in the entire
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watershed), and possible future uses and/or treatment of stormwater runoff.
The compatibility of elements of the stormwater management plan with goals and
objectives of all water resource management agencies having jurisdiction in the
area should be investigated anc1 differences should be reconciled where possible.
6. Adopt a regional approach for solving and preventing the problems of
erosion, pollution, drainage and flooding. Otherwise, the solutions of one com-
munity can make additional problems for another community. A drainage district,
sanitary district or environmental control agency would be suitable for imple-
mentation of regional plans. State-enabling legislation may be required to set
up a regional authority.
7. Develop design criteria along with the development of a master plan
for stormwater management.
8. Develop a detailed plan utilizing the design criteria.
9. Enact legislation to carry out the goals of the chosen solutions to
meet the design criteria, and to fit into the detailed plan.
Suitable legislation might- include:
(a) Ordinances pertaining to stormwater pollution control to protect the
water quality of receiving streams,
(b) Laws requiring stormwater detention on roofs of new or existing
buildings, parking lots, and open spaces of new land developments,
(c) Laws requiring removal of connections of roof drains from the public
sewer system.
(d) Flood-plain zoning laws, and
(e) Flood-proofing regularions for buildings in flood plains.
10. Develop a financing and construction implementation strategy.
11. Prepare engineering designs.
12. Carry out the plan, allowing for future developments which may offer
or require new approaches.
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13. Update the plan at regular intervals of time.
14. Keep citizens informed of: progress being made, ways in which the
stormwater management program is benefiting people in the area, how they can
help, and future plans.
CONCLUSIONS
The major benefits that can be derived from properly operated urban
stormwater detention facilities are the reduction or abatement of water pollu-
tion and downstream flooding. Because soil erosion produced by stormwater flows
diminishes with reduced runoff rates, an important benefit attributable to de-
tention is the reduction in the pollution of receiving streams by contaminants
in suspended solids and sediment.
Public officials should enact on-going programs to help people develop a
better understanding of the necessity for man to cooperate with the forces of
nature instead of fighting them. Public officials, planners and engineers should
be made aware of the need to attenuate peak runoff flow rates by one method or
another. This usually requires the provision of storage space for the runoff
that inevitably results from most rainstorms and melting snow. People ought to
be convinced that land developments in metropolitan areas should be guided, in
part, by decisions concerning water pollution abatement, soil erosion, stormwater
drainage and flood control.
Regardless of what decision is made regarding stormwater management, there
results a "selection-of-space for the temporary storage of runoff". The signifi-
cance of this important action, or inaction, is given insufficient attention in
planning and design. If no provisions are made to transport stormwater, it may
occupy space near the place where it falls. If a storm sewer is constructed,
excess stormwater runoff will occupy space in the sewer network and at the
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downstream end of the storm sewer. Without advance planning and thoughtful
engineering, the water may occupy space and cause pollution problems in base-
ments of buildings, highway underpasses and other urban places.
ACKNOWLEDGMENTS
The work upon which this paper is based was supported in part by funds
provided by the United States Department of the Interior as authorized under
the Water Resources Research Act of 1964, Public Law 88-379, as amended.
Assistance was provided to the principal investigator, Herbert G. Poertner,
by James J. Anderson, Stifel W. Jens, John Reindl and Audrey E. Poertner.
Richard H. Sullivan, Associate Director for Technical Services of the American
Public Works Association, and the APWA Water Resources Committee provided assis-
tance with surveys and report review. Many representatives of public agencies,
engineering and law firms, land development firms and educational institutions
provided information and guidance.
EEFERENCES
1. Practices in Detention of Urban Stormwater Runoff, by Herbert G. Poertner
(for the Office of Water Research and Technology, U.S. Department of the Interior);
published by the American Public Works Association, June 1974, 231 p
2. The Beneficial Use of Stormwater, by Hittman Associates, Inc., for the U.S.
Environmental Protection Agency, Washington, D.C., January 1973, 266 p,
(reference pp 65-97)
3. Development of a Flood and Pollution Control Plan for the Chicagoland Area,
Summary of Technical Reports, by tie Flood Control Coordinating Committee,
Metropolitan Sanitary District of Greater Chicago, Chicago, Illinois, August
1972, 111 p
4. The San Francisco Master Plan for Stormwater Management, City and County
of San Francisco, San Francisco, California, 1972
5. Improvements to the Boston Main Drainage System, (Vols. I, II), Camp,
Dresser & McKee, Inc., Boston, Massachusetts, September 1967
6. Reduction of Hydraulic Sewer Loading by Downspout Removal, G. L. Peters
and A. P. Troemper, Journal of the Water Pollution Control Federation, January
1969
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QUESTIONS ANO ANSWERS
(Following Herbert Poertner's paper, "Stormwater Detention and Flow Attenuation")
Comment(VThitey Secor): In a Stormwater detention program, I think it is nec-
essary to examine where you are located in the watershed. If you are down-
stream, you must be careful so that you don't compound flooding with released
flows from upstream detention facilities.
Question(Whitey Secor): Using detention facilities, or drop structures in
stream channels, you are either reducing the velocity or increasing the dura-
tion of the flow--resulting in a longer time for bank-full conditions down-
stream. Have you evaluated the net effect of channel-bank erosion for that
situation versus an uncontrolled situation? There appears to be some conflict-
ing data on this. One source says that you let the peak flow come and you get
out-of-bank flow which constitutes less erosion potential on the stream banks.
Other people say that the increased flow duration causes greater bank erosion.
Poertner; I haven't made such a study; and, I can see that such an investiga-
tion would require a great deal of field study. Does anyone here have any in-
formation on such studies?
Comment; I am on an Interagency Personnel Assignment from the U.S. Soil Con-
servation Service. We have tried to evaluate this for Northern Virginia; but,
we have not been able to come up with an answer.
Question; You mentioned, in flow attenuation, about having steep slopes and
vegetation cover before the runoff is discharged into a drainage ditch or
stream. I am especially interested in runoff in developed areas where there
is erosion. Are there any published works that indicate the degree of re-
moval, and what effect that has on water quality—by having sheet flows dir-
ected across a vegetated buffer, located parallel to a stream?
Poertner; I don't know of any such information being available. However, I
believe that the method you described offers a good opportunity for reducing
velocities of runoff and collecting eroded soils. This should reduce the
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amount of pollutants that ordinarily enter a stream with eroded materials.
This technique could constitute a beneficial effect in preserving the water
quality of the receiving stream.
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III. Institutional/Legal Issues of Urban Stonnwater Management
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URBAN STORMtfATER MANAGEMENT
PROBLEMS AND SOLUTIONS
Overview of a Nationwide Study
by
Herbert G. Poertner
Engineering and Research Consultant
Bolingbrook, Illinois
INTRODUCTION
I am presently engaged in a field study* of institutional problems, solu-
tions and impacts of urban and metropolitan stormwater management. The purpose
of the study is to identify and analyze various typical problems that prevent
or delay the development of effective and economical stormwater management pro-
grams. Solutions to these problems that have been used, or proposed, in various
places are being investigated to see whether they have transferability for sol-
ving problems in other locations. The positive and negative impacts of ongoing
stormwater management programs are being evaluated to the extent possible.
Stormwater management, as viewed in this study, encompasses both "control"
activities and "developmental" activities. The control activities are princi-
pally those relating to regulating local flooding, pollution, erosion and sil-
tation; whereas, the developmental activities relate to providing and enhancing
social values, such as recreation and public health, arid improving the ecology,
physical environment and aesthetics of local areas.
* The study is financed in part by the United States Department of the Interior
under the Water Resources Research Act of 1964, Public Law 88-379, as amended.
A draft of the final report is now being prepared.
III-2
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Institutional problems being investigated are those that arise in creating,
supporting and operating local stormwater management organizations as well as
problems associated with technical activities such as planning, engineering,
constructing, operating and maintaining physical facilities. All of the above
problems, as a group, can be characterized generally as legislative, legal,
organizational, administrative, political, jurisdictional, social, environmental,
ecological, economic, financial, scientific and technical. Of special interest
are those problems which develop when the stormwater management arm of a local
government or public agency interacts with the private sector (land developers),
other local public agencies, and various state and federal agencies. Included
in this group are problems of overlapping jurisdiction and authority, non-uni-
form policies and regulations within a metropolitan area, disputes concerning
the intent of duly enacted legislation, problems in joint-financing of storm-
water management facilities and programs, and others.
In the process of investigating the institutional management problems
of these local organizations, efforts are being made to identify, analyze and
evaluate the "impacts" that are attributable to the implementation and operation
of stormwater management programs and facilities. These impacts may be positive
or negative and, generally, they can be considered as the secondary effects that
are imposed upon people and/or nature by virtue of the primary activities of
the management organization. They can be classified in four major groups: social,
economic, political and physical (environmental and ecological).
The study methodology is founded upon conducting personal interviews in
selected urban and metropolitan areas across the United States. Detailed case
studies are being made in the metropolitan areas of Denver and Chicago and in
Fairfax County, Virginia. Included in the groups of persons being interviewed
are elected officials, appointed officials and staff personnel of local and
III-3
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state governments and other public agencies, staff personnel of federal agencies,
planners, engineers, land developers, lawyers, educators and civic leaders.
OVERVIEW OF FINDINGS
Priorities and Attitudes
~ A
After conducting interviews for the study, it became evident that many
areas of the United States have similar problems relating to stormwater manage-
ment. The professional staff in most municipalities now give stormwater manage-
ment a much higher priority, --primarily because of the many flooding problems
and the increase in damages and inconvenience occurring in recent years. I'ost
elected officials are becoming more concerned about these problems and are giv-
ing higher priority to the control of stormwater flooding and water pollution.
However, some officials are more Interested in and responsive to broad, social-
type projects that can be seen, used and appreciated by the voters on a regular
basis, rather than stormwater projects which often directly impact only a small
percentage of the voters. Unfortunately, most citizens give stormwaLer a low
priority unless they are affected directly.
Master Plans for Stormwater Management
Very few areas have a Master Stormwater Management Plan. Most of the per-
sons interviewed feel that a plan is needed; however, many feel it would not be
a wise use of available time and funds unless it can be seen that funds are ob-
tainable for implementing the plan. Others thought a master plan is necessary
now, even though implementation funds aren't available, so that priorities, al-
ternative solutions, anticipated benefits and cost estimates can be developed.
This information could then be used to inform and educate the citizens concern-
ing stormwater management needs and develop long-range plans and schedules to
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i
solve these problems in the most cost-effective manner,
Financing
In all places visited during interviews, "money" was identified as either
the greatest impediment, or a major problem, in establisMng a timely and effec-
tive stormwater management program.
Few places in the country are satisfied with the financing methods they
are now using for stormwater management. Many remarked that adequate legisla-
tion is needed to authorize the creation of Drainage Districts, on a watershed
basis, without a vote of the citizens. Tt is felt that this should be a poli-
tical problem and that action should be taken by the elected public officials,
after conducting public hearings of affected citizens. Also, a legal basis is
needed to assess charges against property in a more realistic manner according
to benefits received. This requires new definitions of what constitutes "bene-
fits". Kost persons thought this would be an important step in solving the fi-
nancing i'/edinents to correction of historic stormwater problems in many areas.
Also, many of those interviewed thought a way should be found to fund con-
struction of stormwater drainage facilities of sufficient flow capacity to meet
future needs of an area when fully developed. It was thought that it was unfair
for the developer and, ultimately, the new home buyer, to pay for the needed o-
versizing required to serve future upstream developments. Some persons thought
this additional cost should be financed by the municipality and collected later
when the upstream area is developed.
Most agreed that a service charge, or user charge, of some type, is nec-
essary to finance effective stormwater management programs. However, most also
thought it would be difficult to obtain voter approval of a service charge or
user charge. In most areas, legislation would be required to authorize a charge
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of this type without voter approval. Many thought this should be a political
decision and should be made, if needed, --en i •- it was politically unpopular.
It was felt that hearings should be held and the citizens fully informed so
that they become aware of the need for a service or user charge. Some areas
are now collecting a service charge for stormwater management, and some prob-
lems are being encountered in citizen protests and refusal to pay.
Many persons interviewed remarked that an urban stormwater system should
be considered a "public utility" as are systems for sanitary waste collection
and disposal, water supply, electricity, gas and telephone. Development of a
utility operation for stormwater management would make "revenue bond financing"
of facilities and programs feasible. This should permit obtaining capital and
operating funds at lower interest rates than those inherent in other financing
methods. Also, tap-in or development fees could be charged. This would make
it possible to install needed facilities to serve future development.
In some areas, stormwater drainage facilities are being improved in low
income and blighted areas using federal revenue sharing funds or community de-
velopment funds. The objective is to upgrade the area and, hopefully, increase
the tax base at a future date.
Cost-sharing is being used in many areas to finance improvements needed
to correct existing stormwater-related problems. In most places where such fi-
nancing programs are used, the property owners pay for the necessary materials
and the municipalities provide the planning, engineering and field labor.
Citizen Education and Responsibility
Many persons stated that citizens must be educated to accept responsibi-
lity, including "financial" responsibility, for the operation of the stormwater
management system. Even though they may not have any direct problems, it was
felt that the citizen should understand that stormwater does flow into the drain-
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age system from their yards, roofs, driveways, patios and sidewalks. Further,
they should develop an understanding of how each piece of real estate contributes
to the problems of flooding, pollution, erosion and siltation. An analogous
situation exists in respect to some other public services. For example, all
real property owners must pay for police and fire protection, yet most persons
use these services only occasionally.
Very few areas have a good public information or community relations pro-
gram. Those that do have found it helpful in making the citizens aware of the
municipality's needs and in obtaining their support, especially for improvement
bond programs. The citizens must be given the facts, many remarked; then most
of them will support proposed programs. Many improvement bond programs have
failed in the past because of poor public relations. Public officials often
hesitate to attempt these programs now because of past failures; however, many
persons expressed the opinion that worthy programs should be proposed again.
They should be fully publicized and the citizens should be truthfully informed
of the needs and costs. Too often the officials are afraid of public reactio.:
.-.I'd do not put forth their fullest, sincere eiforts. Actually, very little
could ever be accomplished in municipal government without the support of the
citizens.
In some municipalities, neighborhood organizations have been formed and
regular meetings are held. These meetings provide a forum for the municipal
staff to present the needs of the municipality and an opportunity for the cit-
izen to be heard. Many helpful and useful ideas have come out of these meet-
ings.
In one city interviewed, a "city calendar" is published each year. This
calendar is usable all year and keeps the citizens informed concerning commun-
ity goals, needs, the previous year's accomplishments and plans for the current
year. It contains much useful information.
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Hamages and Impacts
None of the cities or counties were found to have an effective method or
system of determining the costs of stormwater damages and inconvenience to the
citizens. Many of the events producing damages may recur several times annual-
ly and may interfere with commercial and industrial activities as well as the
various emergency services provided in urban areas. Citizens are often delayed
or unable to reach work because of flooding of streets and underpasses. The
pollution produced by sewer overflows and backups together with the degradation
of receiving water bodies are serious impacts as are soil losses and silt ac-
cumulations from uncontrolled erosion. Recurring stormwater flooding can have
a serious impact on the overall economy of urban areas and reduce the market
value of real property.
All of these physical problems produce economic losses in the communities
impacted, and sometimes in areas outside those directly impacted. It is impor-
tant to develop methods and on-going programs for assessing annual damages so
that the figures can be used to compare the costs of needed improvements to
the average costs of recurring damages. This information could be very useful
to inform and educate the citizens about the true cost of delaying needed storm-
water management programs and facilities.
Maintenance
Very few areas have a planned, systematic maintenance program for storm-
water handling facilities. Maintenance is pocr-to-fair in most areas, mostly
due to the lack of programmed operating funds.
Also, the lack of right-of-way or easements along the streams and ditches
compound maintenance problems in many municipalities. Most municipalities now
(require easements along the flow ways in new land developments, even in instan-
ces where there may be no public responsibility for maintenance. The difficult
II1-8
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problem is to obtain these easements in previously developed areas. Many prop-
erty owners prefer that the streams remain in their natural states without dis-
turbances of the banks, vegetation, trees, brush, etc. They are reluctant to
grant easements to the municipality for stormwater facility maintenance.
In most areas, maintenance crews have other responsibilities and perform
stormwater maintenance only when problems occur. In some areas, the sanitary
sewer department crews and equipment are used to maintain stormwater drainage
facilities. Efforts are made to record the costs separately so that revenue
from sanitary system service charges is not used for stormwater system main-
tenance.
Public officials in most areas would like to upgrade their maintenance
programs. This would help solve many of their stormwater problems.
Ordinances and Regulations
Most urban places have adopted ordinances and regulations for stormwater
management, including flood plain management, in recent years. However, many
of these ordinances are not fully effective and amendments are planned in many
areas. The ordinances often are not written clearly and problems of interpre-
tation have developed, even within the department of the public agency that is
responsible for enforcing the regulations. As a result, plat approval is de-
layed. This creates serious problems for the land developers.
Land developers in most places are cooperative, even though they do not
like many of the new stormwater management regulations. They believe many of
these regulations are too stringent and that the regulations are producing an
adverse economic effect on the housing market. Developers are accepting these
regulations as long as they know what the regulations are and know that all
developers must observe them uniformly.
Yany public officials believe that the local ordinances and regulations
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should be realistic and conducive to flexibility of -approach in land develop-
ment. Too often a "cook-book" approach and solution is required irrespective
of the circumstances•
Regional Management
In past years, in most urban places, there has been little cooperation
and coordination between neighboring jurisdictions. Today, because of the many
problems that affect adjoining municipalities, more consideration is being giv-
en to each others problems. Some areas now have joint planning commissions
which have reduced inter-jurisdictional problems, particularly in new develop-
ment.
Many believe that some tyne of regional form of stormwater management is
needed, partly because watersheds reach into several political jurisdiction in
many urban areas. Also, many bulieve regional planning and design criteria
-should be established and that uniform regulations for stormwater drainage and
control of flooding, pollution, erosion and siltation are needed. Suggestions
were made for regional offices of federal agencies to establish planning offices
in larger urban areas to overset; and review plans that affect more than one
jurisdiction.
It was suggested that some type of regional inspection agency would be
helpful. This would make it feasible, financially, to hire well-qualified hy-
drologists and engineers to inspect stormwater drainage facilities over entire
watersheds. The costs could be shared by all the jurisdictions involve;' ac-
cording to use. Political interference could be minimized or eliminated.
Providing inspection and enforcing regulations during and after land de-
velopment activities is a problem in many areas because of an inadequate staff
of qualified engineers and technicians. This is particularly a problem in
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places having an erosion and sediment control ordinance to regulate grading
and excavation at new land developments.
Interagency Relationships
Inter-department and inter-government communication is a problem in some
places. Actually, many stormwater management problems sometimes are compounded
because of insufficient coordination and cooperation, and because too many lo-
cal departments and agencies are involved in establishing and administering
regulations.
A problem in some places is the poor cooperation between the state high-
way department and the municipalities. Some state highways are built with
undersized bridges, culverts and drainage facilities because they sometimes
use less stringent design criteria than those adopted and used by the local
governments. Also, stormwater runoff is often discharged into the local drain-
age system which may not have been designed to handle the added flows. Correct-
ive measures often cause local disruption of streets and private property and
may require unscheduled expenditures by the local governments for structural
solutions.
Many municipalities are purchasing land in the flood plain so that land
development in flood prone areas can be controlled. Most of this land is
being developed for parks, recreation, wildlife and forest preserves, bike
trails, groundwater recharge, and other public purposes. For a successful land
acquisition program, cooperation is needed from all local governments in which
a given flood plain lies. Many of these municipalities are hoping for federal
or state financial aid so that more flood plain property can be purchased.
Several persons stated that combining stormwater management projects with
other public projects and activities has been very helpful in obtaining public
support. This is particularly true for parks and recreation projects. Such
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multiple-purpose projects require a high degree of cooperation and coordination
between departments and between cities and counties. Sometimes, state enabling
legislation may be needed'to permit implementation of multiple-purpose projects
when more than one unit of government is involved.
Many municipalities have serious problems with excessive infiltration of
groundwater into sanitary and combined sewers through defective pipe joints,
ruptured pipes or manholes. Inflow of surface runoff through manhole openings
and joints into sanitary sewers also occurs. This often produces sewage back-
ups into basements and other habitable areas will often occur during wet weath-
er-causing health and safety hazards, property damages and economic losses.
Sometimes these problems -3rvelop outside the areas where the infiltration or
inflow contributions are greatest. Also, treatment plants are often by-passed
during periods of high sewer flow rates and the resulting overflows and dis-
charges produce serious pollution of the receiving water bodies, beaches and
adjacent lands. Many streams, ponds and lakes are now "dead", and some cause
serious odor and health problems. In a metropolitan area where infiltration is
significant and wastewater is collected from many separate political jurisdic-
tions for central treatment, a coordinated and cooperative approach by all juris-
dictions involved is necessary to reduce the pollution and flooding impacts from
sewer system surcharging.
In some areas, "piece-meal" solutions have been attempted to solve storm-
water problems, such as channel improvements in the middle of a watershed. As
a result, the flooding problem is often transferred or compounded in downstream
areas. Most persons agreed that channel improvements should begin at the mouth
of the stream to be fully effective. Again, this requires coordination and co-
operation between all of the local governments involved and, usually, the state
regulatory agency.
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Many of those persons interviewed would like to see the state and federal
governments become more involved in stormwater management. They feel state
stormwater programs should be developed and guidelines established. Also, many
persons feel the federal and state governments should develop financing pro-
grams to provide financial assistance for making needed capital improvements be-
fore, instead of after, problems and damages occur.
Many persons said that the federal government should reduce the time
needed to implement a federally-funded project after it is approved. Sometimes
8 to 10 years elapse from the time a project is approved until construction is
started. In the meantime, damages and inconvenience continue and land and
construction costs increase. Many are of the opinion that the federal govern-
ment is not giving enough consideration and resources to the stormwater problems
that are occurring all over the nation today.
Flood Plain Maps
In many places, hydrologic maps delineating the 100-year flood plain are
not accurate, and local officials consider this a serious problem. It is par-
ticularly bothersome in areas where minimum elevations must be established for
construction. Many urban places are now having the flood plains of local streams
delineated by the U.S. Army Corps of Engineers or the U.S. Geological Survey.
It is felt that these maps should be undated at regular intervals. A great deal
of preliminary flood plain mapping has been done under the National Flood In-
surance Program; however, a great deal more remains to be done. No doubt, many
years will be required to develop all the flood plain maps needed in urban
communities.
Engineering Design and Responsibility
Most urban communities are giving serious consideration to the use of
stormwater detention facilities for runoff control to reduce peak flow rates
HI-13
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into drainage systems. Because many storm sewers and combined sewers in older
urban areas have insufficient flow and storage capacity, detention in the up-
stream areas appears to be the most practical means available for solving this
problem. In many places, detention is being used and has been found satisfa-
tory and money-saving; however, land developers often resist such new concepts.
Some public officLais exaressed the opinion that the engineering design
of all stormwater facilities, together with careful construction inspection,
should be provided by the local municipality. This should assure the provision
of satisfactory facilities. By assuming this responsibility, the dedication
and acceptance of the completed facilities would be expedited--benefitting both
the land developer and the municipality.
CONCLUDING REMARKS
Although many of the institutional problems and alternative solutions
pertaining to stormwater management were identified in this paper, there are
many others of importance that were not addressed, or discussed only briefly.
These include: development of management policy, goals and objectives; frag-
mented authority; extent of responsibility and jurisdiction; organization and
administration; planning, to decrease the implementation time lag; problems in
developing and adopting needed legislation and administrative regulations; ap-
plication of non-structural solutions for preventing problems; legal matters
and laws pertaining to stormwater management; politics; relationships between
land developers and public agency officials; problems with property owners; de-
velopment of better public wor
-------
THE INTERGOVERNMENTAL TANGLE FACING STORMWATER CONTROL
by
Andrew B. Waldo
Rapid urban growth in this country has indelibly
marked our lives with problems, which are by nature
increasingly complex. The environmental threat posed by
stormwater runoff is among these many problems genereted in
the wake of development. Where such pollution endangers
the quality of receiving waters, it respects no political
boundary. As a result, intergovernmental cooperation
becomes a necessity in order to carry out technical solutions
effectively; yet when local government is called upon to
meet this need, it appears ill-equipped to supply areawide
answers to those matters best handled at that level. A
stormwater program must therefore address not only technical
solutions, but must also consider the means by which local
government will cooperate to implement them.
In the past, it was thought that the overriding pur-
pose of a stormwater drainage system should be fast removal
and efficient disposal. The management of these systems
was seen as an engineering problem divorced from other
urban systems and activities. In addition, sewer design
by the rational method considered neither the timing of the
flow nor the quality of the flow. As a result, those designs
111-15
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employing detention and storage were, for the most part,
arbitrarily eliminated. Although the environmental damage
caused by stormwater runoff is now recognized, a hold-over
from this past remains—the view of stormwater control as
a local problem with an engineering solution. Consequently,
our sewer systems are incapable of maintaining the quality
of our streams. Were the damage born only by those who
failed to plan effectively, the matter would lose some of
its urgency. Unfortunately, the effects of stormwater
runoff are cumulative. The neglect of one community is
paid for by another. Such being the case, piecemeal solu-
tions become inadequate. Effective intergovernmental co-
ordination is thus needed for reasons of equity as well as
for reasons of hydrology.
Past failures, however, do not constitute a sufficient
reason for intergovernmental coordination. Each community
differs in the degree to which it suffers from the ill
effects of stormwater runoff and some areas may not have
a serious problem whatsoever. In this light, the characteri-
zation of the specific problem becomes all too important.
Data must be collected and analyzed. Coordination among
local governments is then needed where common problems are
apparent, but it will only occur, most probably, where these
common problems have been demonstrated clearly.
For the present, a major obstacle to coherent adminis-
tration is the fragmentation of responsible levels of
111-16
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government. As a case in point, the stormwater programs
of two neighboring counties in Maryland—Prince Georges
and Montgomery Counties—may be contrasted. Both counties
share the same history. Until 1968, the Washington Sub-
urban Sanitary Commission was responsible for stormwater
management in both areas. After that time, Montgomery
County took over this duty from the Commission; Prince
Georges did not.
As the cornerstone to its efforts, Prince Georges County
has created a Stormwater Management Technical Review Com-
mittee which answers to the county planning board. This
group represents the Park and Planning Commission, the
Soil Conservation District, the Washington Suburban Sani-
tary Commission, and the Department of Public Works. There
are thus four agencies responsible to a planning board.
Each of the four agencies has a different responsibility
and a different interest.
To begin with, the Park and Planning Commission has
the obligation to recommend the installation of detention
facilities where they feel necessary. In turn, the Soil
Conservation District evaluates the construction specifi-
actions of the detention plan. Then, because the Sanitary
Commission must inspect and maintain the facility on com-
pletion, they have review authority as well. Finally, the
Department of Public Works has a say since their concern
involves a related issue—the public streets. All of these
111-17
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agencies advise the County Planning Board which under its
independent powers has the final authority.
Many of those involved with the stormwater program in
Prince Georges County agree that their policy is ad hoc and
haphazard. Most of all, their procedure is highly frag-
mented. Each agency has a different interest, but all have
a say in the matter; conflicting voices result. For in-
stance, the Sanitary Commission does not favor a blanket
requirement on developers for stormwater management. The
Park and Planning Commission, on the other hand, is in
favor of such a constraint. For its part, the County be-
lieves it has inadequate funding for inspection and main-
tenance of facilities once completed.
In contrast, Prince Georges' neighbor, Montgomery County,
has centralized its stormwater management program within
the Montgomery Soil Conservation District pursuant to the
Maryland Sediment Control Act of 1970 and to a 1971 opinion
of the Maryland Attorney General affirming the requirement
of stormwater management measures under the intent of
the Maryland Sediment Control Law. Montgomery County's
stormwater control policy, along with some recent altera-
tions, has thus been in effect since 1971. Within this
framework, Montgomery County has developed a far-sighted
program. Although the comparison of the two counties
simplifies a number of highly complex factors, it serves
to indicate the divergence of thes-e adjoining counties
111-18
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in their approach to stormwater management. The fragmenta-
tion of responsiblity may well impede the success of a
program.
From this perspective,the pattern of organization will
be important to the attainment of perceived goals.
Some values are served by one pattern of organi-
zation, while other values are brought to the fore
by a different pattern. The rational way to pro-
ceed, therefore, is to try to sift out the major
values or goals to be sought, and to determine
the relationship of different patterns of organi-
zation as a means to the attainment of these
goals. If a relationship of means to goals can
be objectively established, then the task becomes
one of determining in any given local gommunity
which values are to have priority. Once this
step has been accomplished, decisions as to
location and organizational form of the planning
function can be made.l
Characterization of the problem, again, is critical to
understanding the mostveffective means of administration.
In an absolute sense, the ultimate criterion for a given
organizational scheme to control stormwater runoff lies in
the measured benefits to water quality: Such a criterion,
however, remains difficult to measure in practice.
Nevertheless, the haphazard results in Prince Georges
County may, in part, be traced to the pattern of organiza-
tion taken. The planning board submits to the review
committee only those plans which the Board feels have an
inadequate consideration of the impact from runoff. If
a planning board is to gain from the technical experience
of the agencies which advise it, all development plans
111-19
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should be review by them. Some of the difficulties facing
this county thus appee.r the partial result of their institu-
tional arrangements.
While Montgomey County has centralized its program
within a soil conservation district, such special purpose
districts do not offer a general solution to the fundamental
dilemma at hand. An instance of an acute jurisdictional
morass existed in one county which included within its
borders one county-wide drain board, one county-wide park
board, three separate water management districts, two soil
conservation districts and most of one irrigation district.
To make matters even worse, that irrigation district extended
into two other counties so that coordination between the
several districts would require contact with two drain
boards-, three park boards, four water management districts,
and four soil conservation districts. This chaos is not
atypical. One survey indicated that there were 143 counties
actoss the nation which contained over 25 special districts
within their boundaries.
As an intergovernmental solution, special districts
have several failings. First, there is commonly a dupli-
cation of roles to be fulfilled by different districts.
Second, there does not often exist a mechanism for state-
wide supervision that would ensure adequate coordination
of the districts' plural and separate efforts to meet
111-20
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their overlapping responsibilities. Finally, the varia-
tions possible in jurisdictional boundaries make coopera-
tion even more difficult.
Given the dimensions of the intergovernmental problem
and in light of the variability inherent in the impact of
stormwater runoff, no one all-encompassing institutional
solution will be found. These are the realities to be
faced due to the myriad patterns of government within our
federal system. We confront a balkanized arrangement of
functions with little hope of strong regional structures
forthcoming.
For their part, theorists have pointed to many better
ways of governing ourselves in the face of regional prob-
lems. Federation, consolidation, and intergovernmental
service agreements are some of the most commonly mentioned.
Structural answers have been regional councils, regional
special districts, and metropolitan counties to name a few.
Theory offers little solace, however, because theorists
fundamentally disagree. An important point remains: We
cannot wait for radical reorganization of the political
structure. Since 1945, for example, only seven city-county
consolidation referenda have been approved in areas with
a population over 100,000.
Because structural revision appears an unlikely develop-
ment in the forseeable future, the means available to abate
111-21
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the pollution caused by stormwater runoff are constrained
to those which are nonstructural. As for the technical
solutions, estimates for treatment of stormwater discharges,
for example, have proposed astronomical costs. Precluding
structural measures as a feasible alternative, nonstructural
ones appear attractive. In a similar way, because radical
political reorganization aroundthe watershed will, most
probably, not occur, local government must look to informal
mechanisms and existing institutions. Both technically
and administratively, then, stormwater management programs
are severely limited by the practical alternatives available.
Intergovernmental cooperation may be reached, however,
in some instances without structural change. To control
sediment runoff from construction sites, local governments
can simultaneously adopt ordinances which set performance
standards for the developer. In Georgia, Dekalb County
passed such a law requiring stormwater management. As a
result, Dekalb1s neighbors followed suit and now, Clayton
and Gwinett counties have similar regulations. Another
adjacent county, Fulton, has not passed a specific
ordinance of this type yet it achieves the same effect
through an informal policy carried out by the Department
of Planning. Fulton is at the point of passing a law
of this kind, which would make stormwater managment a
requirement in a total of four neighboring counties.
111-22
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These counties evidence a common problem: they share the
same drainage areas, have similar soil types, and in all,
have identical stormwater management needs. This example
suggests that structural change through formal mechanisms
may not be a necessary condition to the success of an
areawide approach to stormwater management.
Given the depth of the problem, the ultimate question
still remains: what minimal level of intergovernmental co-
operation is necessary and what form must it take in order
for an effective stormwater management program to be
carried out? While the answer to so universal a question
defies a general anaylsis, the first step must begin with
a characterization of the problem. This effort may vary
from a simple qualitative estimation to a highly complex
time dependent analysis. It may, depending on the resources
available, either look for critical areas of impact by a
crude evaluation of related variables which affect the
pollutant loading or enter into a sophisticated modeling
process of water quality response. Since a discussion of
the methods available to determine the extent and degree
of water quality damage is considered elsewhere in this
conference, let us then suppose that at least a coarse
notion of the problem has already been obtained. At this
juncture, the area faces the difficult task of defining
an adequate program of control measures.
HI-23
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Best Management Practices have been proposed as one
means of controlling the pollution caused by runoff. As
a simple example of how these- BMP' s might work in practice,
let us assume that several.adjoining communities lie in
the same drainage agrea, and have similar runoff coeffi-
cients, soil types, and rainfall. Four control measures
may be considered: street sweeping, erosion control practices,
detention tanks, and catch basin cleaning.
From an analysis of population and traffic densities
as well as land use, zones of highest street loading
intensities may be developed for a range of pollutants after
a sampling program is completed. Again, the assumption
here is that other data concerning soil types, rainfall-
runoff relationships and slopes, for example, have already
been inspected. Next, areas of high earth disturbance can
be located. For construction sites, this effort may entail
a collection of building permits. Furthermore, depending
on the drainage characteristics of the community and from
the earlier evaluation of receiving water impacts, a de-
tention tank might be designed. If the density of catch
basin placement is known, estimates of load reductions can
follow which form a first notion of the cleaning program
to be undertaken. Such, then, are the rudimentary steps
toward a formulation of a BMF, albeit greatly simplified.
In this example, the communities have been disaggre-
gated into zones where the four techniques in question
111-24
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might be applied. Essentially, these zones constitute
areas which contribute highly to the pollutant loading of
the stormwater runoff; this example has generated areas
of high street loading intensities and those of high earth
disturbance. In addition, potential areas which might be
served by a detention tank have been defined as well as
the densities of catchment basins. Once this process of
definition has taken place, an analysis may begin to
determine the most effective, least costly, application
of the techniques and the resultant enhancement of the
receiving waters. Having identified debris laden streets
does not, however, mean that the most efficient use of the
street sweeper is to automatically cover them.
Interdependence of pollutant sources and of technique
application becomes a critical factor. If, for instance,
a construction site lies next to a roadway and it does not
have erosion control structures on it, then an enormous
loading of total solids would be measured on the roadway,
thus making that section of street an area of highest
pollutant intensity. Sweeping that avenue may not be the
answer. Rather, the solution would more likely be the
implementation of an erosion control plan on the construc-
tion site. The point is simply that a technique to control
stormwater runoff cannot be applied arbitrarily and without
consideration for the interdependence with other techniques
111-25
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and other pollutant sources. Put another way, a catch
basin cleaning program could not be designed independent of
a street sweeping program for the sweepers will reduce the
collected solids in the catch basin. A best management
scheme must therefore take into account the totality of
the system.
A Best Management Practice can be determined though
which applies these techniques with an appropriate concern
for this interdependent effect. Other factors can also
affect the program such as the lack of off-site parking or
the inability to alter the no parking ordinance to suit
the street sweeping routes. In addition, it may be im-
possible for political reasons to require the stormwater
control practices from the developer. The point remains,
however, that a planning process, taking into account the
related variables and factors at one degree of sophisti-
cation or another, can design a Best Management Practice to
control the impact of stormwater. Thi.s process will result
in alternative programs in light of the beneficial use
intended for the receiving water.
The fundamental question asked earlier can now be
addressed: what form should the intergovernmental coopera-
tion take? The answer will depend upon the areas identi-
fied as having a significant impact on the receiving water
as well as upon the best management practices generated
in the: planning process. Let us assume that the communities
HI-26
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in this example directly adjoin and that the transportation
network covers them evenly. In this case, if it is de-
termined that an area of multiple jurisdictions would
benefit from street sweeping, then an interlocal contractual
agreement may be called for which shares the capital in-
vestment in sweeping equipment and the maintenance costs
for its operation. On the other hand, if an area of growth
straddles jurisdictions, then the simultaneous adoption by
ordinance of performance standards for developers may be
a needed measure. Clearly, no one intergovernmental mea-
sure applies to every case. Each community must tailor its
Best Management Practices and its intergovernmental needs
to the specific problems it faces and to the problems shared
with other communities in the area.
The implementation of an effective stormwater manage-
ment program will hinge upon a characterization of the
problem. Even if this is accomplished, however, there w:11
be difficulties of administration for the community that
may be internal or external. Fragmentation of responsibility
will undoubtedly arise within many local government organi-
zations and political impediments will obstruct cooperative
efforts. In addition, technical problems will surround
the design of the Best Management Practice. Nevertheless,
some hope remains. The concept of BMP within a planning
process offers the possibility of identifying the ill
effects of stormwater, developing alternative strategies
111-27
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to control it, and finally, clarifying the common needs
of an area.
Even if the commitment to water quality is strong, inter-
governmental conflicts may block the best of intentions.
But we must begin at some point. A first requirement is
public awareness and participation. Only after a recogni-
tion occurs of the environmental threat posed by runoff
will there be a willingness to face intergovernmental solu-
tions. To this end, public participation becomes a necessity.
Citizen awareness will instill an incentive for local leaders
and representatives to seek cooperation. An example of
an effective program of public participation is the one
carried on by the Huron River Watershed Council in Michigan.
Through public service annoucements, public meetings, and
disseminated information, the Council has had wide response
from the public-at-large;. In particular, the public ser-
vice announcement proved an inexpensive yet effective method
to gain citizen support for the Council's activities.
Whatever the method chosen, stormwater management must be
accompanied by public awareness.
In summary, the overarching consideration in a storm-
water management scheme is the quality of the receiving
waters and the developed plan must tailor itself to the
beneficial uses intended for these waters. To protect
these uses stormwater runoff must be seen not as a local
111-28
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problem, but rather as a dilemma of areawide and regional
proportions. The approach taken cannot rely on isolated
engineering efforts to solve it, but must, instead, view
the urban system as a totality. Toward this end, a charac-
terization of the specific dimensions of the environmental
damage caused by stormwater becomes critical. Out of this
effort needs are clarified. Once these needs are under-
stood the intergovernmental mechanisms available can be
brought to bear upon the problem. Intergovernmental coopera-
tion, however, hangs on the clarity of the demonstrated
needs. As a result, the pattern of organization can suit
the goals desired. It is suggested here in a very simpli-
fied way that an effective measure of control can result if
local government approaches the problem in an integrated
manner. Surely, these problems are complex and the
institutions cumbersome, but the rudiments of an answer
are present.
111-29
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NOTES
1. Local Planning Administration (Chicago: International
City Managers' Association, 3rd ed., 1959), p. 40.
111-30
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INTERGOVERNMENTAL RELATIONSHIPS IN THE CONTROL OF STORMWATER RUNOFF
A SELECTED BIBLIOGRAPHY
The following bibliography is designed to provide references, both
general and specific, toward a better understanding of the intergovern-
mental relationships which must be addressed in any program directed
to the management of stormwater runoff. Stormwater runoff, as a
problem of local governments, clearly is linked to other services
provided by local areas such as sewerage and drainage. For this,,
reason, general references are provided.
GENERAL
Advisory Commission on Intergovernmental Relations. The Challenge
of Local Government Organization; Substate RegTonalism and
the Federal System, v. 3. Washington: U.S. Government
Printing Office, 1974. .
Advisory Commission on Intergovernmental Relations. A Handbook
for Inter!oca! Agreements and Contracts, Report M-29.
Washington: U.S. Government Printing Office, 1967.
Advisory Commission on Intergovernmental Relations. Intergovern-
mental Responsibilities for Hater Supply and Sewage Disposal
in Metropolitan Areas, Report A-13. Washington,1 U.S.
Government Printing Office, 1962.
Advisory Commission on Intergovernmental Relations. The Problem
of Special Districts in American Government, Report A-22
Washington: U.S. Government Printing Office, 1964.
Antieau, Chester James. Antieau's Local Government Law: Independent
Local Government Entities. New York: Matthew Bender, 1970.
v. 3a.
Beck, R.E. "The Law of Drainage." Water and Hater Rights.
Indianapolis: Allen Smith Co., 1972, v. 5, sees. 450-59,
pp. 475-648.
Carrell, Jeptha J. "Learning to Work Together." National Municipal
Review, v. 43, no. 10 (November 1954), pp. 526-533.
111-31
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Environments for Tomorrow, Inc. McLean Va. Management of Water
Resources for Urban Environmental Assessment. Washington:
Office of Water Research and Technology, 1974. NTIS PB
239-301.
Foster, William S. "Metropolitan Sewerage Pacts in 1960." American
City. Part I, "Inter-city Contracts," v. 75, no. 10 (October,
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1960), pp. 143-147.
Graves, W. Brooke. Interlocal Relations: The History and Background
of Intergovernmental Agreements. Information and Education
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of Counties Research Foundation, 1963.
Grosenick, Leigh. "A Comparative Analysis of Joint Exercise of
Powers Legislation in the United States." Unpublished M.A.
Thesis, University of Minnesota. Minneapolis, 1965.
Hamrnill, Anne, and Hanson, Ivan. Natural Resource Special Districts
in Appalachia ... Review of Enabling Laws. Washington, D.C.:
Economic Research Service, Department of Agriculture, 1970.
Haskell, E.H. et al. Managing the Environment: Case Studies of
Nine States . New York: Praeger, 1974.
Hillenbrand, Bernard. 'Urban Counties in 1958". Municipal Yearbook.
1959. pp. 60-66. Chicago, 111.: International City Manager's
Association.
Hines, William and Smith, Jamison. Rational Institutional
Arrangements for Water Resources Management. Ames, Iowa
and Washington, C.C.: Iowa State Research Institute; Office
of Water Resources Research, Department of the Interior,
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International City Manager's Association. The Municipal Yearbook.
Annual. Chicago, Illinois.
International City Manager's Association. Citv County Cooperation
in Providing Municipal Services. MIS Report No. 191, December
1959. Chicago, Illinois: 1959.
International City Manager's Association. Contracting for Municipal
Services. MIS Report N. 240, January 1964. Chicago, Illinois
1964.
Jarz, Emil F. "Intermunicipal Co-operation in Sewerage Disposal."
Public Management, v. 24, n. 9 (September 1942), pp. 267-72,
ni-32
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Krause, Norman P. Intergovernmental Relationships in the Administration
of Water Resources, Hater Resources Center Research Report No. 18.
Urbana, Illinois: University of Illinois, September 1968.
Lauer, I.E. "District Control of Water Resources", University of Detroit
Law Journal (October 1959), v. 37 n.l, pp. 28-75.
Maloney, Frank and Plager Sheldon. "Diffused Surface Waters—Scourge
or Bounty", Natural Resources Journal (January 1968), v. 8 n.l,
pp. 72-113.
Martin, Roscoe C. Metropolis in Transition: Local Government Adapta-
tions to Changing Urban Needs. Washington, D.C.: Housing and
HomeFinance Agency, September 1963.
National Institute of Municipal Law Officers, NIMLO Municipal Law
Review. Annual. Washington, D.C.
National Service to Regional Councils, A New Dimension in Local Govern-
ment Regionalism: Intergovernmental Relations^Washington, D.C.
1971, NTIS PB 205-326:
Norton, G.A. and MacMillan, J.A. A Framework for Economic Planning of
Watershed Drainage, Research Report No71TWinnepeg:Agassiz
Center for Water Studies, Manitoba University, 1972.
Pock, Max. Independent Districts: A Solution to Metropolitan Area
Problems. Ann Arbor: Legislative Research Center, University of
Michigan Law School, 1962.
Poertner, Herbert. Practices in Detention of Urban Stormwater Runoff.
Special Report No. 43.Chicago:American Public Works Association,
1974.
The Research Group, Inc. Comparative Analysis of Three Research
Strategies Directed Toward Multi-Government Provision of PuFlic
Services"Richmond and Washington, D.C.:Division of State
Planning and Community Affairs, Commonwealth of Virginia; Policy
Development and Research, Department of Housing and Urban Develop-
ment, 1973. NTIS PB 231-896.
Wendell and Schwan, Washington, D.C. Intergovernmental Relations in
Water Resource Activities. Washington, D.T7: T97T.NTIS PB "2TO-358.
Wilkinson, Kenneth P. and Singh, R.N. Generalized Participation of
Voluntary Leaders in Local Projects"State College, Mississippi:
Water Resources Research Institute, Mississippi State University,
1969.
Yeutter, Clayton K. Water Adminlistrati on...A Suggested Insti tuti onal
ModeT_, Department of Agricultural Economics Report No.46. Lincoln,
Nebraska: University of Nebraska.
Hi-33
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CASE STUDIES
California
Baruth and Yoder, Walnut Creek, California. Storm Drainage. NTIS PB
211-048.
Beebe, James W., and Firestone, Alan M. "How a Combination of Revenue
Bond Financing and Joint Exercise of Powers Enables the San Diego
Metropolitan Area to So'lve Its Sewage Disposal Problem." Western
City. Vol. 37, No. 4 (April 1962), pp. 27-28.
California. Legislature. Assembly Interim Committee on Municipal and
County Government. Transcript of Proceedings on the Subject of
Cooperative Metropolitan Services, November 13, 1962. (Mimeographed).
California. Legislature. Senate Fact Finding Committee on Local
Government. Report to the Legislature, 1961 Regular Session.
Sacramento, California: 1961.
Council on Intergovernmental Relations, Sacramento, California.
San Anselmo Government Structure Study Tasks 1-4. Sacramento:
NTIS PB 212-889.
Crouch, Winston W. , and Maccoby, Wendell. Sanitation Administration in
the Los Angeles Metropolitan Area— A Study in Development of Public
Policy and Administrative Organization. Los Angeles, California:
Un i vers i ty of Cal i f orn i a , Bureau of Governmental Research, 1952.
Gove, Samuel K. The Lakewood Plan. Commission Papers of the Institute
of Government and Public Affairs. Urbana, Illinois: University
of Illinois, May 1961.
Jamison, Judith Norwell and Bigger, Richard. "Metropolitan Coordination
in Los Angeles", Public Administration Review. Vol. 17, No. 3
(Summer 1957), pp. 164-169.
Kenny, James P. et al. North Richmond San Pablo Bay Area Study.
Sacramento, cnTTbrnTal Council on Intergovernmental Relations,
1971. NTIS PB 211-777.
Ketcham, Ronald M. "Intergovernmental Cooperation", Tax Digest. Vol. 19,
No. 4 (April 1941), pp. 124-125 and 134-135.
League of California Cities. Inter-Municipal Cooperation Through
Contractual Agreements. Berkeley, California, 1963. 48pp.
Warren, Robert 0. Government in Metropolitan Regions: A Reappraisal
of Fracti onatedTol i ti cal Organizati on". Davis, California, 1966.
327pp.
111-34
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Connect!cut
Kasperson, Robert E. Political Organization and the Planning of Water
Resources Development in the Farmington Valley; a Preliminary"
Profile.Storrs, Connecticut:Institute of water Resources,
University of Connecticut, October, 1967.
Delaware
Dolan, Paul. "Informal Approaches to Administration in Northern
Delaware", County Officer. Vol. 23, No. 3 (March 1958), pp. 58-59,70.
"Sewage Problems Can Be Solved Without Separate Districts: Wilmington,
Delaware", American City. Vol. 71, No. 2 (February 1956), pp. 138-139,
District of Columbia
Metropolitan District Study Commission. Report on the Metropolitan
District Commission and Government Functions Committee of the
Capital Region Planning Agency.Hartford:1965.
Florida
Maloney, Frank. "Single Purpose and Multi-Purpose Water Management
Districts" in Water Law and Administration: the Florida Experience.
Gainesville, Florida:University of Florida Press, 1968.
Thomas, Robert D. Intergovernmental Relations and Responses to Water
Problems in Florida. Gainesville, Florida:Water Resources
Research Center, University of Florida, 1972. NTIS PB 219-582.
East Central Florida Regional Planning Council. The Relationship of
Water Quality to Land Use Around Lakes. Winter Park, Florida:
June 1973.
Georgia
Burgess, James V., Jr.; Posey, G. Harold; and Bell, George A., Jr.
A Study of Intergovernmental Cooperation in Georgia: Legal Basis.
Athens, Georgia: The Institute of Community and Area Development,
The University of Georgia, 1963.
Georgia Municipal Association. "Intergovernmental Cooperation: A
Review of Cooperation Between Cities and Counties with Consideration
Given to Progress Being Made and Suggestions for Further Cooperation"
Part III. Atlanta, Georgia: 1965. 33pp. (Mimeographed).
Kates, R.C. Georgia Water Law (Administrative Structures of Water Use
and Water'Courses Regulations). Athens, Georgia: Institute of
Government, University of Georgia, 1969.
111-35
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Illinois
Mann, Fred, et al. "Water Use Regualtion and Related Functions of
State and Local Bodies" in Water Use Law in Illinois. Urbana,
Illinois and Washington, D.U71Illinois University; Economic
Research Service, 1964. pp. 143-191.
Northeastern Illinois Planning Commission. "Intergovernmental Contracts
and Agreements in Northeastern Illinois: A Preliminary Survey,
September 1963". Chicago, Illinois: 1963. 2pp. (Mimeographed).
Northeastern Illinois Planning Commission. Manual for Intercommunity
Councils. Planning Aids No. 8, Chicago, Illinois:October 1964.
Indiana
Stoner, John E. Interlocal Governmental Cooperation, With Special
Reference to Indiana. Bloomington, Indiana: Indiana University
Department of Government, 1964. 74pp. (Processed).
Iowa
Burrows, Tom G. Statutory Authorizations for Intergovernmental
Cooperation in Iowa. Iowa Municipal Information Service, No.3,
July 1964.Iowa City, Iowa: Institute of Public Affairs, Univer-
sity of Iowa, 1964, 7pp.
Otte, Robert C. Economics of Watershed Planning. Ames, Iowa: State
University Press, 1961. pp. 277-292.
"Surface Water Drainage in Iowa", Iowa Law Journal. V. 50, pp. 818-
836. (Spring 1965)
Kentucky
Owsley, Roy H. "The Kentucky Interlocal Cooperation Act", Kentucky
Law Journal. Vol. 51, No. 1 (Fall 1962), pp. 22-33.
Maryland
Vaughan, W.S., Jr., Blanchard, H.A. and Manor, Anne S. State-County
Interagency Procedures for Imposing Environmental Quality Controls
on Water Oriented Development Activities.Washington:Office of
Water Resources Research, July, 1974. NTIS PB 236-299.
Massachusetts
Dowling, Edward T. Permissive Legislation for Municipalities in
Massachusetts. Amherst, Massachusetts: Bureau of Government
Research, University of Massachusetts, May 1959. 32 pp.
111-36
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Goodwin, George, Jr. Intermunicipal Relations in Massachusetts.
Amherst, Massachusetts: Bureau of Governmental Research,
University of Massachusetts, December 1956.
Michigan
Citizens Research Council of Michigan. Staff Papers on Governmental
Organization for Metropolitan Southeast Michigan. Detroit,
Michigan: January 1965. 238pp. (Mimeographed).
Citizens Research Council of Michigan. Research Brief on Legislation
on Intergovernmental Cooperative Agreements. Detroit, Michigan:
February 1966.31pp. (Processed).
Marando, Vincent L. "Inter-local Cooperation in a Metropolitan Area:
Detroit", Urban Affairs Quarterly. Vol. 4, No. 2 (December 1968).
Minnesota
Haik, Raymond ert ctl_. Aspects of Water Resources Law in Minnesota.
Bulletin Minnesota University Water Resources Research Center,
(June 1969).
Proceedings of Conference on Water Resources Problems and Research
Needs in Northwestern Minnesota. St. Paul and Washington, D.C.:
Minnesota University, Water Resources Research Center, Office
of Water Research and Technology, Bemidji State College, Center
for Environmental Studies, 1973. NTIS PB 237-503.
Mississippi
Jones, Arthur R., and McLeskey, Howard M. Water Politics in Mississippi:
A Comparative Analysis of Two Water Resource Development Organizations.
State College, Mississippi: Water Resources Research Institute,
Mississippi State University, 1969.
Missouri
Davis, Lawrence 0. "The Law of Surface Water in Missouri", Missouri
Law Review. Vol. 24, No. 3, pp. 283-289.
The Governmental Research Institute. Services Provided to Municipalities
by the St. Louis County Government. St. Louis, Missouri: April 1964.
11 pp. (Mimeographed).
Office of the St. Louis County Supervisor. Services Available to Munici-
palities Through the St. Louis County Government. St. Louis,
Missouri"] 32 pp. (Mimeographed).
Hi-37
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Nebraska
Nebraska Soil and Water Conservation. Modernization of Resource District
Legislation. State Water Plan Publication No. 402, March 1969.
New Jersey
Burch, Phillip H., Jr. Water Pollution Control in New Jersey. New
Brunswick and Washington, D.C.: Bureau of Government Research,
Rutgers, The State Univeristy; Office of Water Research and
Technology.
Bureau of Government Research. Surface Water Control in New Jersey,
Part II: Drainage, Flood Control and Related Policies in an
Urban State. New Brunswick: Rutgers, The State University,
August 1967.
Trafford, John E. "Intermunicipal Activities and Joint Services in
New Jersey", New Jersey Municipalities. June 1965, pp. 8-11.
New Mexico
Clark, Ira G. Administration of Water Resources in New Mexico. Las,
Cruces, New Mexico: Water Resources Research Institute, June
1968. Clearinghouse PB 192-311.
New York
New York. Legislature. Joint Legislative Committee on Metropolitan
Areas Study. Municipal Cooperation: A Digest of New York State
Law. Albany, New York: February 1963. 140 pp.
New York. Legislature. Joint Legislative Committee on Metropolitan
Areas Study. Metropolitan Action: A Six-County Inventory of
Practical Programs.. Albany, New York: Janauary 1960. 141 pp.
(Mimeographed).
New York State. Office for Local Government. Local Government Cooper-
ation. Albany, New York: April 1963. 33 pp.
Southern Chatangua Regional Planning Board. Intergovernmental Cooperation
Study for the Southern Chataugua Region. Lakewood, New York: 1974,
NTIS PB 232-554.
North Carolina
The Water Facilities Function Project. Charlotte, North Carolina: USAC
Project, 1972. NTIS PB 220-099.
111-38
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North Dakota
Beck, R.E. "Drainage Law in North Dakota: An Overview", North Dakota
Law Review, Vol. 47, No. 4, pp. 471-513. (Summer
Crockett, Richard B. An Analysis of Local Water-Related Districts in
North Dakota. Fargo, North Dakota and Washington, D.C.: Water
Resources Research Institute, North Dakota State University;
Office of Water Resources Research, Department of the Interior,
1972. NTIS PB 236-814.
Ohio
Cochran, Robert D. "The Problem of Metropolitan Government in Ohio",
Western Reserve Law Review. Vol. 7, (December 1955), pp. 87-93.
Craine, Lyle E. "The Muskingum Watershed Conservancy District: A
Study of Local Control", Law and Contemporary Problems. Vol. 22,
No. 3, (1957), pp. 378-404.
The Governmental Research Institute. Authorized Intergovernmental
Cooperation at the Local Level in Ohio. Governmental Facts Number
62, December 20, 1962. Cleveland, Ohio: 1962. 5 pp. (Processed).
Hoi den, Matthew, Jr. Intergovernmental Agreements in the Cleveland
Metropolitan Area. Cleveland, Ohio: Cleveland Metropolitan
Services Commission, July 1958. 56 pp. (Mimeographed).
Ohio Department of Natural Resources. The Conservancy District Law
(Outline and Text of Ohio Convercancy District Law). Columbus,
Ohio: Division of Water.
Skinner, Calvin. Functional Integration Within a Metropolitan Area
Through Intergovernmental Contracts and Transfers. Cincinnati,
Ohio: Cincinnati Bureau of Governmental Research, June 1952.
7 pp. (Mimeographed).
Bureau of Municipal Research and Service, University of Oregon. Local
Intergovernmental Cooperation in the Tri-County Area. Information
Bulletin No. 150, November 1966. Eugene, Oregon: 1966. 55pp.
(Processed).
Hallmark, William L. "Oregon's Water Management. Districts", Oregon
Law Review (December 1967), pp. 16-70.
Pennsylvania
Blair, George S. Interjurisdictional Agreements In Southeestern
Pennsylvania. Philadelphia, Pennsylvania: Pels Institute of
Local and State Government, University of Pennsylvania, January
1960. 136 pp. (Mimeographed).
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"City and Suburbs Work Together for Sewage Disposal", Horizons for
Modern Pennsylvania Local Government. Vol. IV, No. 3 (March 1957).
"Cooperative Agreements and Arrangements—Philadelphia and Other
Governmental Jurisdictions (Formal and Informal by Function)",
Pennsylvanian. December 1965, pp. 4-6.
Kelly, J. Martin, Jr. "617 Agreements Link 1,794 Municipal Units in
Cooperative Action", Department of Internal Affairs Monthly Bulletin.
Vol. 26, No. 7 (July 1958), pp. 1-9, 28.
Seyler, William C. "Municipal Cooperation in Action in Pennsylvania",
Department of Internal Affairs Monthly Bulletin. Part 2, Vol. 29,
No. 9 (September 1961), pp. 8-15.
Williams, Oliver P. Intergovernmental Cooperation for Disposal of
Sewage: Southeastern Pennsylvania. Philadelphia, Pennsylvania:
Institute of Local and State Government, University of Pennsylvania,
1961.
Wise, Sidney, ed. Selected Areas of Intergovernmental Cooperation.
Harrisburg, Pennsylvania: Bureau of Municipal Affairs, Department
of Internal Affairs, Commonwealth of Pennsylvania, 1962. 39 pp.
Virginia
Richmond Regional Planning District Commission. Land Use—Intergovern-
mental Relations in the Richmond Metropolitan Area. NTIS PB 231-588.
Washington
Campbell, Ernest H. Existing Authority for Intergovernmental Relations
of Cities and Towns by Contract. Seattle, Washington: Bureau of
Governmental Research and Services, University of Washington, May
1964. 21 pp. (Mimeographed).
Garvey, M.D. et al. An Analysis of the Lav; Governing Six Selected
Washington Water-Oriented Special Districts, Commentary on Improving
the Flood Associated Activities of the State of Washington.
Pullman, Washington: State of Washington Water Research Center,
June 1970.
Ittner, Ruth; Webster, Donald; Campbell, Ernest H.; and others. Govern-
ment, in the Metropolitan Seattle Area. Report No. 133. Seattle,
Washington: Bureau of Governmental Research and Services, University
of Washington, October 1956. 148 pp. (Mimeographed)
Rosenow, Bervely J. A Study of Various Procedures Utilized by Selected
Water-Oriented Special Districts Which are Common to All of Them.
Seattle, Washington: School of Law, Washington University. NTIS
PB 195-828.
111-40
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Wisconsin
Intergovernmental Cooperation Committee, Milwaukee Metropolitan Study
Commission. Final Report on Intergovernmental Cooperation in
Milwaukee County. Milwaukee, Wisconsin: April 1961. 77pp.
(Mimeographed).
"Joint Municipal Services", The Municipality, League of Wisconsin
Municipalities. Vol. 50, No. 5, (May 1955), pp. 93-94, 106.
Metro Study Commission Committee on Metro Functions. Report on Sewage
Disposal in the Milwaukee Metro Area. Milwaukee: 1958.
Southeastern Wisconsin Regional Planning Commission. Water Law in
Southeastern Wisconsin (Watershed Management and Pollution Controls),
Technical Report No. 2, (1966), pp. 41-92.
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QUESTIONS AND ANSWERS
(Following Andrew Waldo's paper "Intergovernmental Tangle Facing Stormwater
Control")
Question (Doug Thompson, North Central Texas Council of Governments): You
singled-out Montgomery County, Maryland as the richest county in the United
States. You emphasized that they do not have adequate staff to enforce regu-
lations, and you indicated that Montgomery County has a more effective program
than Prince Georges County. My first question is what evidence is there that
Montgomery County's program is effective? My second question relates to
stormwater management—or ordinances and regulations for controlling non-
point sources. I am curious about voluntary compliance by land developers
who work cooperatively with either the councils of government or local govern-
ments, as opposed to regulation—which requires adequate staff, and which
Montgomery County doesn't have.
Waldo: Montgomery County does have an effective program. Representatives of
Prince Georges County told me that they do not have a coordinated program.
The difference between the two counties goes back to the Civil War. Prince
Georges County has, in many respects, been following Montgomery County. I
wanted to use these as an example of two neighboring counties that have two
completely different types of programs, leading to different results. You are
right about ordinances and regulations. There are some cases where voluntary
compliance by developers has been effective. But, I think it is necessary to
have the ability to insure maintenance, as an example, to insure that deten-
tion facilities, once built, will be maintained and operated in an effective
manner. I believe that regulation is a good way to accomplish this. The
cities that I am familiar with that have passed these ordinances seem to have
adopted a good method for assuring maintenance—by ordinance. Some of the
cities that have adopted such ordinances are: Gainesville, Florida; Naperville,
111-42
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Illinois; and Joliet, Illinois. In these cities the ordinances have provided
effective tools for solving many of the intergovernmental problems. These
institutional problems and issues are very broad.
Question (Doug Thomson): What data or information do you have that shows
that, as a result of Montgomery County's coordinated effort, they are success-
ful and their problems are lessened, and that Prince Georges County's problems
are not lessened?
Waldo: Montgomery County has entered into a study to determine the water
quality impact. I believe that they found that they had some success. The
relative merits of these methods are based on the techniques that Montgomery
County is requiring of its developers. Those techniques have certain load
reductions and, from looking at 'the areas under construction and the techniques
employed, there seems to be a reduction of erosion and sediment delivery to
the receiving water. My opinion is based on consideration of technical as-
pects, and it is not merely an arts and crafts viewpoint. The receiving
water has benefitted from Montgomery County's coordinated program.
Question (Stephen Sowby, Mountainland Association of Governments, Provo, Utah):
With all the fragmentation, duplication, overlapping, et cetera in many areas,
what do you perceive as the obligation of planners, engineers or consultants
who are involved in water quality? What obligation do we have to lead, help,
push or shove elected officials to implement the plans that we develop?
Waldo: First, the obligations come from the intent for having 208 agencies.
If you want to talk about the goals of Public Law 92-500, I think the obliga-
tion requires action, beginning with public participation and characterizing
the problem so that one can confront some of the available solutions. I
think that the obligation has to be carried forward, beginning with identifi-
cation of the problem. Does the problem lend itself to the need for coopera-
tion between various governments? Then, it is necessary to make the public
111-43
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aware of those problems and cs.rry forward a program of action.
Question (Joe Bryan, Houston-Galveston Area Council of Governments): In our
agency, we have a division of transportation planning as well as 208 planning.
Do you see any cross-linkages between the two types of physical planning—such
as in land-use management or parking lots?
Waldo: One part of EPA's Best Management Practice (BMP) will be looking at
street sweeping. This requires consideration of traffic density and traffic
routing patterns. This involves transportation planning. There must be some
rapport between the two types of planning. You must have traffic density maps
to determine some of the loading intensities on the. streets. Yes, I think
that the transportation plan has to form a part of the 208 plan because traffic
densities increase the loading on the streets.
Question (Joe Bryan): What are the 208 implications and requirements of air
quality planning?
Waldo: Perhaps John Kingscott of our EPA Washington, D.C. office may wish to
respond to this.
John Kingscott: There are no set requirements. We are just looking for con-
sistency.
Comment: The film we saw yesterday showed a Seattle Metro project in which a
facility had been designed to serve both as a wastewater pumping station and
a bus stop.
m-44
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STATE/LOCAL INTERACTION IN STORM-
WATER MANAGEMENT*
BY
EUGENE T, JENSEN**
I, APPROACHING THE PROBLEM
STORMWATER MANAGEMENT PROBLEMS COMMONPLACE THROUGHOUT THE
STATE OF VIRGINIA VARY GREATLY IN SIZE AND COMPLEXITY
DEPENDING UPON GEOGRAPHY, THE SIZE OF THE COMMUNITY, AND
DEGREE OF URBAN DEVELOPMENT, THE PUBLIC, AND PROBABLY THE
PROFESSIONAL FRATERNITY, HAVE NOT UNDERSTOOD FULLY THE
RELATIONSHIP BETWEEN DRAINAGE, FLOODING AND WATER QUALITY,
MANAGEMENT OF STORMWATER PROBLEMS IS DEPENDENT UPON A
SEQUENCE OF EVENTS IN WHICH A GIVEN PROBLEM MUST BE
IDENTIFIED AND DESCRIBED, ACCEPTED BY THE PUBLIC AS A
PROBLEM IN NEED OF SOLUTION, DEVELOPMENT OF ALTERNATIVE
SOLUTIONS TO THE IDENTIFIED PROBLEM, AND FINALLY, THE
IMPLEMENTATION OF THE TECHNICAL SOLUTION,
THE EXTENT TO WHICH THE PUBLIC ACCEPTS PRESENCE OF A
PROBLEM WILL PROBABLY BE TEMPERED BY THE DEVICE THROUGH
*Prepared for presentation at the EPA Urban Stormwater
Management Seminar, Atlanta, Georgia, November 6, 1975.
**Prepared by Eugene T. Jensen, Executive Secretary, Virginia
State Water Control Board, P.O. Box 11143, Richmond, VA 23230
111-45
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WHICH IT IS BROUGHT TO THEIR ATTENTION, EXPERIENCE IN
VIRGINIA SUGGESTS THE FOLLOWING MECHANISMS, IN ORDER OF
PRIORITY, WILL GENERATE THE PUBLIC ACCEPTANCE NECESSARY
TO REACH THE PROBLEM SOLUTION AND IMPLEMENTATION STAGES:
SEVERE FLOODING OR DRAINAGE PROBLEMS. FLOODING AND
DRAINAGE PROBLEMS MAY CAUSE SEVERE FINANCIAL AND
SOCIAL PROBLEMS FOR INDIVIDUALS AND BUSINESSES IN
THE AFFECTED LOW-LYING AREAS OR FLOODPLAINS, ADDI-
TIONALLY, SEVERE FLOODING OF ARTERIAL HIGHWAYS MAY
INTERFERE WITH TRANSPORTATION AND INCONVENIENCE THE
ORDERLY MOVEMENT OF TRAFFIC DURING PEAK HOURS, THE
FREQUENCY OF IHTERFERRENCE, THE AVAILABILITY OF
ALTERNATE ROUTES, AND THE DEGREE OF INCONVENIENCE
WILL ALL AFFECT THE NATURE OF PUBLIC RESPONSE AND
ACCEPTANCE,
WATER SUPPLY. RAPID DEGRADATION OF WATER QUALITY
REFLECTED IN TASTE, ODOR OR COLOR PROBLEMS IN
MUNICIPAL WATER SUPPLY WILL QUICKLY SOLIDIFY WIDE-
SPREAD PUBLIC SUPPORT FOR STORMWATER AND RUNOFF
MANAGEMENT PROGRAMS, UNFORTUNATELY, OR PERHAPS
FORTUNATELY, THE WATER SERVICE AREA MAY NOT BE THE
SAME AS THE WATERSHED AREA, THEREBY RAISING INTERESTING
COST AND BENEFIT RELATIONSHIP PROBLEMS, SEDIMENTATION
IN RESERVOIRS IS A MORE INSIDIOUS PROCESS WHICH MAY
EVENTUALLY GENERATE PUBLIC ACCEPTANCE AND SUPPORT
THROUGH LOSS OF RESERVOIR CAPACITY AND INTERFERRENCE
WITH WATER SUPPLY DURING PERIODS OF DROUGHT,
111-46
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DOWNSTREAM WATER QUALITY. INTERFERRENCE WITH DESIRED
DOWNSTREAM WATER USES, NOTABLY FISHING AND RECREATION,
MAY BE QUITE EFFECTIVE IN GENERATING COMMUNITY INTEREST
IN PROBLEM ACCEPTANCE AND SOLUTION, PARTICULARLY IF THE
AFFECTED POPULATION MAKES USE OF THE DOWNSTREAM FISHING
OR RECREATIONAL USES,
ADMINISTRATIVE DECLARATION. A LEGISLATIVE OR ADMINISTRA-
TIVE DETERMINATION, WHICH MAY AT TIMES SEEM TO THE PUBLIC
MORE IN THE NATURE OF A REVELATION, THAT A PROBLEM EXISTS
IS PROBABLY LEAST EFFECTIVE IN GENERATING SUPPORT, THE
PUBLIC IS INURED AGAINST SUCH BUREAUCRATIC ACTIONS AND
THEY ARE SUSPICIOUS OF THE MOTIVATION OF THE BUREAUCRATS
AND LESS THAN ANXIOUS TO COMMIT FINANCIAL RESOURCES TO
CORRECTION OF A PROBLEM WHICH MAY BE APPARENT ONLY TO
THOSE IN THE FAR-AWAY STATE OR NATIONAL CAPITAL,
ONE OF THE SEVERE CONSTRAINTS PLACED ON ALTERNATIVE SOLUTIONS
IS COST EFFECTIVENESS, ANOTHER IS ACCEPTABILITY BY LOCAL
CITIZENS, THESE TWO CONSTRAINTS ARE CLOSELY RELATED AND
BEAR ON THE SUBJECT AT HAND, VIRGINIA HAS NOT FOUND ALL
OF THE ANSWERS, PERHAPS NOT ANY, BUT WE BELIEVE WE ARE
HEADED IN THE RIGHT DIRECTION, A KEY ASPECT OF GETTING
THOSE ANSWERS IS STATE/LOCAL INTERACTION, WE ARE UNDER-
TAKING A DIVERSITY OF APPROACHES, MOST IMPORTANT, WE
HAVE LEARNED THE NEED FOR FLEXIBILITY IN OUR STATE/LOCAL
RELATIONSHIPS, RECOGNIZING THAT EACH AREA HAS UNIQUE
111-47
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PROBLEMS, STUDIES AND SOLUTIONS ARE BEING APPROACHED ON A
CASE-BY-CASE BASIS, WE TRY TO KEEP FOREMOST IN OUR
THOUGHTS THE OVERALL WELFARE OF THE PEOPLE AND THEREFORE
PLACE EMPHASIS ON LOCAL ACTION WHERE FEASIBLE.
RESPONSIVE STATE/LOCAL INTERACTION WAS FACILITATED IN
VIRGINIA BY LEGISLATIVE ACT WHICH ESTABLISHED PLANNING
COMMISSIONS COMPOSED OF LOCAL ELECTED OFFICIALS, THE
STATE IS DIVIDED INTO TWENTY-TWO MULTI-COUNTY PLANNING
DISTRICTS, EACH WITH ITS OWN COMMISSION, THE PLANNING
DISTRICT COMMISSION IS RESPONSIBLE FOR OVERALL LOCAL
PLANNING IN THEIR DISTRICT, THE STATE WATER CONTROL
BOARD IS ORGANIZED ALONG A SOMEWHAT PARALLEL STRUCTURE
OF REGIONAL OFFICES TO WORK DIRECTLY WITH LOCAL PLANNERS
AND OTHER OFFICIALS,
VIRGINIA IS A COMPLEX STATE, WITH GEOGRAPHY RANGING FROM
STEEP MOUNTAIN VALLEYS TO FLAT COASTAL PLAINS, IN URBAN
DEVELOPMENT, IT RANGES FROM THE RAPIDLY GROWING WASHINGTON
METROPOLITAN AREA TO THE SMALL COMMUNITIES WHICH HAVE
CHANGED LITTLE IN POPULATION SINCE THE REVOLUTION,
CONTROL OF POLLUTANTS FROM NON-POINT SOURCES IS A REASONABLY
STRAIGHT-FORWARD PROPOSITION, GENERALLY INVOLVING THE
CONSTRUCTION OF SEWERS AND A SEWAGE TREATMENT PLANT, HOWEVER,
THE MANAGEMENT OF 'STORMWATER, RECOGNIZING BOTH QUALITY AND
QUANTITY PROBLEMS, PRESENTS A WIDE VARIETY OF TECHNICAL AND
POLITICAL PROBLEMS,
111-48
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II, EXAMPLES OF SOME MAJOR PROGRAMS BEING CONDUCTED IN VIRGINIA
THE OCCOQUAN RESERVOIR IS LOCATED IN A RAPIDLY URBANIZING
AREA OF NORTHERN VIRGINIA AND IS THE PRIMARY WATER SUPPLY
FOR THE FAIRFAX COUNTY PORTION OF THE METROPOLITAN WASHINGTON
D,C, AREA, IT HAS A DRAINAGE AREA OF APPROXIMATELY 570
SQUARE MILES, IMPOUNDS 9,8 BILLION GALLONS OF WATER,
AND HAS AN ESTIMATED SAFE YIELD OF 65 MGD, THE STATE WATER
CONTROL BOARD RECOGNIZED A PROBLEM WITH WATER QUALITY DUE
TO POINT AND NONPOINT SOURCE POLLUTION, IN 1971 A POLICY
WAS ESTABLISHED WHICH REQUIRES ALL WASTE WATER TREATMENT
TO BE CONSOLIDATED INTO TWO REGIONAL PLANTS AND TO PROVIDE
A HIGH LEVEL OF WASTE TREATMENT, A MONITORING PROGRAM WAS
ESTABLISHED AS A JOINT STATE/LOCAL PROJECT, ALL AREAS IN
THE WATERSHED AND THE RESERVOIR OWNER SHARE THE COST OF
MONITORING, THE POLICY PREVENTS ANY NEW SEWER HOOKUPS
WITHIN THE WATERSHED UNTIL THE EFFECTIVENESS OF POLLUTION
CONTROL MEASURES HAVE BEEN ASSESSED THROUGH THE MONITORING
PROGRAM, A RECENTLY ESTABLISHED 208 AGENCY WILL ALSO
PARTICIPATE IN THE MONITORING PROGRAM, THE BOARD HAS BEEN
HEAVILY INVOLVED IN ENCOURAGING LOCAL GOVERNMENTS TO ENFORCE
SEDIMENTATION CONTROL ORDINANCES,
FAIRFAX COUNTY COMPRISES AN AREA OF APPROXIMATELY 400
SQUARE MILES IN THE SOUTH PORTION OF THE WASHINGTON
111-49
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METROPOLITAN AREA AND HAS A POPULATION OF JUST OVER ONE
HALF MILLION, THE COUNTY HAS BEEN WORKING WITH STORMWATER
DRAINAGE PROBLEMS SINCE THE LATE 1950'S, IN 1971, THE
VOTERS APPROVED AN $11 MILLION BOND ISSUE FOR STORM
DRAINAGE CONTROL. AN ENGINEERING CONSULTANT WAS HIRED
ON A FIVE-YEAR CONTRACT TO DEVELOP THE MANAGEMENT PROGRAM,
SOME OF THE OUTPUT TO DATE HAS BEEN A COMPUTERIZED STORM-
WATER MODEL FOR ASSUMPTIVE LAND USE IN THE DRAINAGE BASIN;
AN ENVIRONMENTAL BASELINE STUDY WHICH HAS WIDE APPLICATION,
ENABLING MEASUREMENT OF FUTURE ENVIRONMENTAL CHANGES RESULTING
FROM DEVELOPMENT; METHODOLOGY FOR CALCULATING SOIL LOSS BEFORE
AND AFTER DEVELOPMENT; NEW DRAINAGE CODES FOR THE COUNTY;
AND A METHOD TO QUALITATIVELY CORRELATE EFFECTIVENESS AND
COSTS OF STORMWATER CONTROLS IN VARIOUS WATERSHEDS, AN
EXCITING FEATURE AS YET NOT ADEQUATELY TESTED WILL PERMIT
DEVELOPMENT OF PERFORMANCE STANDARDS RELATED TO MAXIMUM SOIL
LOSS PERMITTED, UNDER CURRENT COUNTY REGULATIONS, DEVELOPERS
OF LESS THAN ONE SQUARE MILE AREA MUST SUBMIT STORMWATER
CALCULATIONS FOR PRIOR APPROVAL TO COUNTY ENGINEERS, THE
COUNTY HAS RIGOROUSLY RESTRICTED FLOOD PLAIN DEVELOPMENT
DURING THE PAST TWO DECADES, SINCE 1972, THE COUNTY HAS
HAD A POLICY OF SITE RETENTION WHICH LIMITS OFFSITE DRAINAGE
TO PRE-DEVELOPMENT LEVELS, THEY HAVE DEVELOPED A SITE
RETENTION DEFICIENCY INDEX WHICH ALLOWS ECONOMIC EFFECTS OF
THIS POLICY TO BE DETERMINED,
ni-so
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THE FOUR MILE RUN DRAINS A SMALL FOURTEEN AND ONE-HALF
SQUARE MILE AREA IN THE CITY OF ALEXANDRIA AND FAIRFAX
COUNTY IN THE WASHINGTON METROPOLITAN AREA, THE ENTIRE
DRAINAGE AREA, WHICH HAS BECOME COMPLETELY URBANIZED IN
RECENT YEARS IS PART OF A FEDERAL FLOOD CONTROL PROJECT,
AT THE URGING OF THE STATE, MANY MEETINGS WERE HELD BETWEEN
LOCAL, STATE AND FEDERAL OFFICIALS WHICH RESULTED IN STORM-
WATER AND SEDIMENT CONTROL BEING INCLUDED AS AN INTEGRAL
PART OF THE FLOOD CONTROL PROJECT, AS A UNIQUE "FIRST"
IN THE STATE OF VIRGINIA, AND PERHAPS IN THE NATION, LOCAL
OFFICIALS DEVELOPED A BASIN-WIDE RUNOFF CONTROL MANAGEMENT
PROGRAM, THIS PROGRAM CONTAINS UPSTREAM LAND USE CONTROLS
WHICH REQUIRE NEW DEVELOPMENTS TO INSTITUTE CONTROLS WHICH
ASSURE THAT TOTAL FUTURE RUNOFF WILL NOT EXCEED DESIGN FLOW,
THE RIVANNA RESERVOIR IS THE PRIME SOURCE OF WATER FOR
CHARLOTTESVILLE AND SURROUNDING ALBEMARLE COUNTY IN CENTRAL
VIRGINIA JUST EAST OF THE BLUE RIDGE MOUNTAINS, THIS IS
A DEVELOPING AREA AND THE SEAT OF THE UNIVERSITY OF VIRGINIA,
THE LOCAL CITIZENS WERE SHOCKED TO FIND LARGE AREAS OF
ALGAE BLOOMS DURING THE THIRD SUMMER AFTER THE RESERVOIR
WAS FILLED, THE PROBLEM HAS BECOME SO SEVERE THAT THE RESERVOIR
IS VIRTUALLY USELESS AS A WATER SUPPLY DURING THE SUMMER MONTHS
OF LOW FLOW, THE CITIZENS DID NOT WAIT FOR FEDERAL GOVERNMENT
ACTION, BUT INSTIGATED A WATERSHED STUDY ON THEIR OWN
INITIATIVE AS A COMBINED FEDERAL-STATE-LOCAL PROJECT. THE
COUNTY HAS IMPOSED A LIMITED MORATORIUM ON NEW BUILDING UNTIL
THE PROBLEMS CAN BE ASSESSED,
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LYNCHBURG AND RICHMOND HAVE COMBINED STORMWATER AND SANITARY
SEWERS WITH RESULTANT BY-PASS OF UNTREATED WASTEWATER INTO
RECEIVING WATERS OF THE JAMES RIVER DURING STORM OVERFLOW
PERIODS, LYNCHBURG IS A CITY OF SOME 55,000 POPULATION
LOCATED JUST BELOW THE UPPER THIRD OF THE 240 MILE LONG
JAMES RIVER, RICHMOND, WITH A QUARTER OF A MILLION POPULATION,
IS LOCATED AT THE UPPER ESTUARIAN REACH OF THE JAMES RIVER,
THE STATE CAPITOL AND HIGHLY INDUSTRIALIZED, 201 FUNDED
STUDIES ARE IN PROGRESS TO ASSESS THE MAGNITUDE OF THE PROBLEMS,
THE RICHMOND STUDY WILL PROVIDE INPUT TO THE 208 PLANNING
BEING CONDUCTED THERE, THE STATE HAS ESTABLISHED CONSTRUCTION
GRANT PRIORITIES FOR BOTH CITIES,
THE STATE LEGISLATURE RECENTLY PASSED A LAW WHICH ESTABLISHES
MINIMUM REQUIREMENTS FOR EROSION AND SEDIMENT CONTROL ORDINANCES
TO BE ENACTED BY ALL LOCAL POLITICAL SUBDIVISIONS OF THE STATE
BY 30 JUNE 1976, THE PURPOSE OF THE ACT WAS TO ENCOURAGE LOCAL
GOVERNMENTS TO DEVELOP THEIR OWN COMPREHENSIVE PLANNING
PROCEDURES WHICH INCORPORATE CONTROLS OF STORMWATER DRAINAGE,
WHERE LOCAL JURISDICTIONS FAIL TO ACT, THE STATE LAW WILL
PREVAIL AND WILL BE ENFORCED BY THE STATE,
IN VIRGINIA 208 AGENCIES HAVE AN ACTIVE ROLE IN EVALUATING
THE STORMWATER RUNOFF PROBLEM, FIVE INTRA-STATE AREAS HAVE
BEEN DESIGNATED: HAMPTON ROADS, RICHMOND-CRATER, ROANOKE,
FREDERICKSBURG AND SOUTHWEST VIRGINIA, TWO INTER-STATE AREAS
HAVE ALSO BEEN DESIGNATED; NOTHERN VIRGINIA WITH THE WASHINGTON
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METROPOLITAN AREA AND THE BRISTOL CITY AREA WITH THE STATE OF
TENNESSEE, THE SOUTHWEST VIRGINIA AREA WAS DESIGNATED
SPECIFICALLY FOR CONTROL OF RUNOFF FROM COAL MINE OPERATIONS,
THE STATE WAS INSTRUMENTAL IN GETTING EPA TO ACCEPT THIS
AS A UNIQUE WATER QUALITY CONTROL PROBLEM,
THE ROANOKE 208 AGENCY HAS PROGRESSED FURTHEST OF THOSE
DESIGNATED, THE CONSULTANT, MOORE-GARDNER AND ASSOCIATES, HAS
COMPLETED PRELIMINARY SAMPLING AND IS USING THE STORM COMPUTER
PROGRAM FOR ANALYSIS, THIS IS THE STORAGE, TREATMENT, OVERFLOW
AND RUNOFF MODEL, ADAPTED FROM THE ORIGINAL DEVELOPED BY
WATER RESOURCES ENGINEERS, INCORPORATED FOR EPA AND THE U,S,
ARMY CORPS OF ENGINEERS,
BRYAN PARK, A LARGE PUBLIC PARK, IS LOCATED IN NORTHERN
RICHMOND CITY AND HENRICO COUNTY, IT CONTAINS A LAKE WHICH
DRAINS APPROXIMATELY 20 SQUARE MILES OF RAPIDLY URBANIZING
AREA, IT IS ALSO SITUATED AT THE JUNCTION OF THREE INTERSTATE
HIGHWAYS; 1-95; 1-64; AND 1-195, STORM WATER is COLLECTED
IN THREE CREEKS WHICH EMPTY INTO THE LAKE, A RECENTLY BROKEN
DAM UPSTREAM IN ONE OF THE CREEKS IS ALLOWING ACCUMULATED SILT
TO WASH DOWN, BLOCKING STREAM CHANNELS THROUGH THE POND, THE
PROBLEM IS COMPLICATED BY THE FACT THAT COMBINED SEWERS BACK
UP RAW SEWAGE INTO BASEMENTS OF DWELLINGS, TO ALLEVIATE THAT
HEALTH PROBLEM, HENRICO COUNTY HAS EXERCISED THE PRACTICE OF
PUMPING OUT MAN HOLES, FECAL COLIFORM BACTERIA HAVE BEEN
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FOUND IN INCREASING AMOUNTS IN THE LAKE IN BRYAN PARK, THE
STATE WATER CONTROL BOARD IS MONITORING THESE WATERS AND
IS ENCOURAGING THE RICHMOND-CRATER 208 AGENCY TO UTILIZE
THIS AREA AS PART OF THEIR STUDY OF NON-POINT SOURCES OF
POLLUTION, LOCAL. CITIZENS HAVE ALSO FORMED A BRYAN PARK
CIVIC ASSOCIATION WHICH IS ALSO TRYING TO REMEDY THE SITUATION,
THE STATE POSITION HAS BEEN TO HELP THROUGH MONITORING AND TO
ENCOURAGE LOCAL ACTIONS TO CORRECT THE PROBLEMS,
NORFOLK IS AN OLD CITY OF SOME 308,000 POPULATION LOCATED IN
THE RAPIDLY URBANIZING AREA OF HAMPTON ROADS IN TIDEWATER
VIRGINIA, HAMPTON ROADS IS A LARGE ANCHORAGE LOCATED BETWEEN
THE MOUTH OF THE JAMES RIVER AND THE LOWER CHESAPEAKE BAY,
THE ELIZABETH RIVER, DRAINING PORTIONS OF THE DISMAL SWAMP,
FLOWS THROUGH THE CITY AND EMPTIES INTO THE HAMPTON ROADS,
NORFOLK, AS THE LONG STANDING HOME OF THE ATLANTIC FLEET
OF THE U,S, NAVY AND THE LARGEST NAVAL BASE ON THE EAST
COAST, ALSO HAS A MAJOR SHIPYARD, IT IS A GROWING COMMERCIAL
SEAPORT, AVERAGING NEARLY 50 MILLION TONS OF TRAFFIC A YEAR,
70% OF WHICH IS FOREIGN TRADE, STORM WATER DRAINAGE CREATES
SEVERE PROBLEMS IN THE CITY, INFLUENCED BY TIDAL FLUCTUATIONS,
EVEN AN AVERAGE SUMMER SHOWER CAUSES WIDESPREAD STREET FLOODING,
THE AVERAGE ELEVATION OF THIS FLAT AREA IS 10-25 FEET ABOVE
MEAN SEA LEVEL AND MINIMIZES THE EFFECTIVENESS OF GRAVITY
FLOW DRAINAGE, THE WATER QUALITY PROBLEM IS FURTHER
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COMPLICATED BY QUALITY OF WATERS FLOWING INTO THE AREA,
CONTAMINATION BY PORT ACTIVITIES AND LACK OF ADEQUATE FLUSHING
REGIME, THE STATE WATER CONTROL BOARD WAS INFLUENTIAL IN
EARLY DESIGNATION OF THIS AREA FOR 203 PLANNING, IN ADDITION,
THE VIRGINIA INSTITUTE OF MARINE SCIENCE HAS BEEN CONDUCTING
VARIOUS MONITORING AND MODELLING PROGRAMS IN THE AREA, A
MAJOR THRUST OF 208 PLANNING WILL BE THE STORM WATER MANAGEMENT,
III, SUfflARY
AS STATED IN THE BEGINNING, WE DON'T HAVE THE ANSWERS, THE
FOREGOING HAS BRIEFLY HIGHLIGHTED SOME OF OUR MAJOR PROBLEM
AREAS AND DEMONSTRATED DIFFERING APPROACHES USED, WE TRY
TO WORK DIRECTLY WITH LOCAL OFFICIALS AND JURISDICTIONS,
PROVIDING GUIDANCE AND ASSISTANCE, FLEXIBILITY IS THE KEY,
FIT THE APPROACH TO THE UNIQUENESS OF THE PROBLEM, MOST
IMPORTANT — UNDERSTAND THE PROBLEM, IF ANY, BEFORE SEEKING
PUBLIC ACCEPTANCE OR PRESCRIBING A SOLUTION!
THE ROLE OF THE FEDERAL AGENCIES IN THE STORMWATER MANAGEMENT
SYSTEM HAS NOT BEEN DISCUSSED; HOWEVER, IT MUST BE RECOGNIZED
THAT AT LEAST SIX FEDERAL AGENCIES ARE DIRECTLY INVOLVED IN
STORMWATER MANAGEMENT PROGRAMS AND THAT EACH HAS ITS OWN
LOCAL CLIENTELE, THESE FEDERAL PROGRAMS, WHICH ARE CARRIED
OUT BY THE CORPS OF ENGINEERS, THE SOIL CONSERVATION SERVICE,
THE FOREST SERVICE, THE BUREAU OF LAND MANAGEMENT, THE
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ENVIRONMENTAL PROTECTION AGENCY AND HOUSING AND URBAN
DEVELOPMENT, MAY NOT BE WELL COORDINATED WITH EACH OTHER AND
MAY COMPLICATE STATE/FEDERAL RELATIONS, THE RESPECTIVE ROLES
OF THESE AGENCIES SHOULD BE CONSIDERED VERY CAREFULLY BY
STATE AND LOCAL. OFFICIALS AS THEY ADDRESS THEMSELVES TO
THE ASSESSMENT AND RESOLUTION OF STORMWATER MANAGEMENT
PROBLEMS,
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LEGAL ASPECTS OF URBAN STORMJATER MANAGEMENT
by W. Joseph Shoemaker
Shoemaker and Wham, Attorneys
Denver, Colorado
I am here today to speak on both the legal and financing aspects of
urban stormwater management. I don't believe that you can finance stormwater
projects without a knowledge of the legal aspects involved.
There is only one thing that everyone agrees with concerning stormwater,
and that is that "stormwater runs downhill". The inter-play between govern-
ments is something that one must understand in order to make accomplishments
in stormwater management. Local governments are most independent, ranking
second only to farmers. You must let local officials know that you spent a
lot of time thinking about what their problems are in order to persuade them
concerning suggested approaches. I was the director of public works for the
City and County of Denver from 1959 to 1962 and I couldn't solve drainage, and
that is why I got interested in it. You must understand the legal background
to know why solutions to drainage are so difficult.
This is the way I look at stormwater management from a legal standpoint.
Historically, the problems of drainage belong to private property owners. They
do not belong to government. In the United States, different states take
different approaches to stormwater--civil law doctrine, common-law doctrine,
modified civil-law doctrine and the modified common-law doctrine. Simply ex-
plained, the common law doctrine says water is a common enemy and you can
do anything you wish to protect your own property. The civil law theory is
that the property owner on top of the hill has an easement to run stormwater
onto any property lying below. Most courts, certainly the Colorado Supreme
Court, and most jurisdictions have adopted a modified civil law version which
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is that the servient owner must take the water, but not to a degree which
will cast more water downhill on him than would have naturally flowed. This
is the way the Colorado Supreme Court has put it; namely, that the lower owner
must take the water, but not more water than would naturally flow without the
upper owner providing for the carrying off of that extra water. So, the ob-
vious situation in an urban area, where everyone goes out and blacktops their
lots, et cetera, is that they have changed the amount of water that flows
downhill from what flowed before.
Now, when one tries to translate that legal doctrine into financing,
the owner sitting at the top of the hill says: The hell with it, I ain't got
no problem! If anyone is dumb enough to live at the bottom of a hill, that's
his problem. I was smart enough to live uphill, so if you think I am going
to take care of that jerk, you have another guess coming."
When you get to a special assessment district, which is the traditional
method of financing a local drainage improvement, you must prove "benefit" to
the owner that you want to assess. When you come into court to assess an
upper owner, the law traditionally says that the meaning of benefit is "in-
creased value" of the property. The upper owner usually claims that his
property value has not been increased, even though a million-dollar storm
sewer may have been constructec below his property to collect his surface
drainage. This is the situation that most local officials encounter today.
But I submit to you that the law is different than this and that there
are other legal benefits that increase the value of property. I wrote an
(2)
article in the Denver Law Journal concerning "benefits". Based on that
article, I succeeded in getting the Colorado statutes changed to define
"benefits" different from the definition of the courts. We have six or seven
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different methods of defining benefits. One is the fact that somebody takes
the extra runoff resulting when an owner of upper lying property blacktops
his lot. The fact that the owner uphill discharges it downstream requires
that the runoff be handled some way. It is similar to a utility operation,
such as refuse, which somebody has an obligation to handle for health and
safety reasons.
You must understand the interplay between streets and drainage and the
latest theory that the streets are polluting the waters. I wish to tell you
that this is a "fact" question, and I have not yet seen anyone devise a
factural method for determining that; although, I have read many theoretical
articles on the subject. The Urban Drainage and Flood Control District in
Denver has hired the U.S. Geological Survey to come up with an approach on
what is the pollutant runoff from streets into our streams. This is a fact
question that is far beyond the basic legal theory that I am addressing today.
Drainage has always been a private property matter between two property
owners. So, if my house was flooded because an upper owner sent more water
downhill than would naturally flow, I could sue that upper owner. On the
other hand, if I am the uphill owner and a downstream owner dams up his
property so that the water backs up on me, I can sue the owner downhill be-
cause there is no right, in Colorado, for an owner to back water up on another
owner's property-since Colorado does not follow the common law theory.
Then, you merge this into an urban area where you have 5,000 houses in
a drainage basin. Just identifying a drainage basin is a fact question. Up
until five years ago, we hadn't done that in this area. It wasn't until
Denver realized that no jurisdiction could solve a drainage problem by itself
that we went to the State Legislature and requested a special district, or
governmental entity, to handle the drainage problems. So, the State formed
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a 1,280 square mile district which was the urban and urbanizing part of the
Greater Denver area. After six years, this District has completed more than
50 master plans identifying where flood plains are. And now, the District is
studying what pollutes the rivers from drainage.
This bi'ings me to the way lawyers work, using analogies. To get facts
across to a lay person, a good method is to give an analogy. 1 say there is
an analogy between "flood plain" management and the "pollution coming off
streets which enters streams". Let's start with what I think are two of the
best pieces of legislation that the Congress has ever enacted. Congress de-
termined that there are two national goals: one is clean, natural water by
1985; the other is that the floodplains should be unobstructed for a 100-year
storm. The latter is the flood insurance program. In one case, we have the
EPA; in the other case, we have the FLA. From a local/state standpoint, we
have problems with both of these federal agencies. However, I agree with
these two goals because I think our water should be clean and I do not think
anyone should buy or build a house in a floodplain.
That's the analogy! We have two things going down the road at the
same time, and you must back x:p and say both of these, which involve storm-
water runoff, are based on the fact that, up until a few years ago, all the
stormwater problems were simply "private property-owner" problems. If the guy
pumped sewage into the river, who gave a damn? Nobody owned the fish. If
someone was getting their drinking water from the river, they had a problem.
Or, if someone was using the river for irrigation, he may have a problem.
Similarly, for persons building, or buying property, in the floodplain,
"caveat emptor" (let the buyer beware)! It wasn't until we got 5,000 owners
in a drainage basin that people really began complaining to the local govern-
ment. They would ask for something to be done, but did not want to pay for
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the solution. Neither were the people owning property at upper elevations
agreeable to pay the costs for solutions. As a result, nothing would happen.
It wasn't until public works people and city engineers got enough complaints
that they finally got into providing solutions.
When you start researching the legal obligation of some public official
who gets into an area where he doesn't belong, you will find that any municipal
official will be held for his negligence. He will not come under the doctrine
of sovereign immunity; and he will not be able to say that he just operates as
a public official, because he doesn't have an obligation to operate as a public
official in this field. So, when he gets into a proprietary rather than a
governmental function, he had better be sure he is right. If he builds a
storm sewer that is now the right size, of if he builds something that is
faulty, he will be held for his negligence. From a public official's stand-
point, you would normally ask "why should I do anything?"
Society has changed from a "care-nothing" attitude about a neighborhood
or river to a "care-something" attitude. Three years ago, the City of Denver
had spent well over a million dollars studying what to do about the South
Platte River, but nobody did anything. I would like you to go down to the
15th Street Bridge and see what has been done in improving the South Platte
River along a one-mile stretch from Speer Boulevard to the 20th Street Viaduct.
I think that you will enjoy it. My ultimate solution to the stream pollution
problem is to build trails and get a cadre of citizens using the trails and
looking at the pollution of the streams. They will then point their finger
at the polluter and the jerk who is living in the flood plain. By public
opinion and support, something will then be done.
Following that line of action, we got the Drainage District established
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and prepared master plans for 50 drainage sub-has ins. We now know where the
floodplains are in 50 of the 300 drainage basins in this 1,280 square mile
area. We know the facts! If you don't know the facts, don't try to get a
private property owner to do something--and I include a city as a private
property owner. You, at the EPA, are coming in here telling the City and
County of Denver what they ought to do on the River. You are telling the
State of Colorado what it ought to do, because Congress said that's what you
should do. Well, you had better know what the facts are before you ask any-
thing of the State, the City and County of Denver, or Joe Smith, who likes to
float in the River, or live dawn there. From a legal standpoint, you must
know what the facts are and you must identify the problem, or how long a
solution will take, or what the ultimate cost will be, or who will pay.
Local government must monitor the pollution of local streams. Neither
the State, nor any federal agency, will ever monitor all the 300 drainage sub-
basins. Two sessions ago the State of Colorado passed a major land-use bill
(House Bill 1041), and I had something to do with that. The bill requires
local governments to identify, designate and regulate certain areas of state-
wide interest. Floodplain ha2ards are right up at the top of the list.
From a legal standpoint, you must realize that you are working in an
area of private property rights; but, if health and safety are involved, the
police power comes into effect. Government was formed for the health, safety
and well-being of its citizens. Government has forgotten that, because it
gets into everything else. When you are working on drainage, you are working
on "fundamentals", as far as I am concerned. Even though we have private
property rights in terms of surface water coming down, if you, factwise, can
prove that someone's life is a-; stake, you can regulate the floodplain. So,
when someone tells me that I am taking his property without compensation, I
say, "The hell I am! All I am doing is identifying a hazardous area. If
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you think you have a right, Mr. Developer, to sell that piece of property to
some unsuspecting person on a sunny day, you have another guess coming! And
if you think, Mr. Plant Manager, that you have a right to pump your sewage
into the river, you have another guess coming, because you don't! And, Mr.
City, if you think you have a right to do with your property what these pri-
vate property owners are doing, you don't!"
The first place to make a record is at the local government level, which
should get its house in order. It should not be polluting the river. Secondly,
city facilities should not be built in floodplains. Until government sets an
example, I don't think you will force property owners to do anything. Action
will then only come by harassment and compromise.
You should proceed with the knowledge that you are dealing with the
health and safety of people. Then, you should identify what the actual prob-
lem is. Most engineers and planners don't really know what the problem is!
They don't know what the real world is like in terms of going to court and,
on a legal basis, having some judge or jury rule in their favor. You shouldn't
start anything unless you are prepared to carry it to its ultimate conclusion,
because you are almost worse off by losing than never having started at all.
If you don't have your facts right, you will lose 999 times out of a thousand.
Once you have the facts, you need a plan. The plan involves many
things; Is it legal? How long will it take? What will it cost? Will it
actually solve the problem, or are we just wasting the taxpayers'money? If
you can't sell solutions to drainage on a cost-benefit basis, you won't be
successful. If someone can't say,"It is beneficial to have clean water",
then you won't have clean water. I think Congress has said that it is a goal
that we should have clean water. I would like to argue why I think the rivers
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ought to be clean and why people should not live in a floodplain. In both
cases, I can argue on the basis of health and safety.
Then, it is necessary to get financing, and later to maintain the
facilities. Maintenance is usually a local government function. How long
should the river be clean? For one day? Or, for 24 hours of each day from
now on, ad infinitum? Is that what the goal of Congress is? I believe that
this is the goal! The only way to assure that this goal is being met is to
provide monitoring on some basis other than by routine sampling methods. It
is also necessary to know where the floodplain is. I usually depend on engi-
neers for the latter iriformati.on, but engineers sometimes differ in their
answers concerning the location of the f loodplains..
This stormwater management area is an intermixture of everything, and
we must realize that we are dealing with various federal, state and local
agencies — such as the EPA, HEM, HUD, FIA, USGS, Corps of Engineers, the Bureau
of Outdoor Recreation, and Congress; and state agencies such as the Depart-
ment of Health, the Water Quality Control Commission, the Water Conservation
Board, and the State Legislature; and agencies of the City and County (of
Denver) such as the Wastewater Control Department, Department of Health, Urban
Drainage and Flood Control District, the Department of Public Works, and
others. Everybody is in the act and few are doing anything about the storm-
water problems. They are just thrashing around! If you don't have all the
cobwebs out, you will not end ap solving anything.
REFERENCES
1. Shoemaker, W, Joseph, "An Engineering-Legal Solution to Urban Drainage
Problems", Denver Law Journal, Vol. 45, 1968, pp 381-398
2. Shoemaker, W. Joseph, "Wha~: Constitutes Benefits for Urban Drainage
Projects", Denver Law Journal, Vol. 51, No. 4, 1974, pp 551-565
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QUESTIONS AND ANSWERS
(Following W. J. Shoemaker's talk "Legal Aspects of Urban Stormwater Management")
Question: I work in an area just north of Denver, in Weld County and Larimer
County, where we have a very complex hydrologic region and, superimposed on
that, many problems of irrigation and return flows and runoff. Lacking facts,
there is a lot of speculation as to whether or not we will ever be able to
achieve either of the two national goals you mentioned, short of tremendous
economic impacts. How does that interface with the goals that you believe
in so firmly?
Answer: I think that you are presenting the real world the way it is. You
must deal with the situation as it is. I don't believe that anyone can set
the clock back. From a governmental enforcement standpoint, most laws "grand-
father in". As I said earlier, it is necessary to identify the problems and
their sources, probably through a monitoring program. Even though Congress
established these goals, they are just that—goals and objectives. I don't
think that they will be completely enforced by 1985.
Question: Do you believe in the application of uniform water quality standards
nationwide?
Answer: First of all, you must define a navigable river. This leads to many
definitions. I don't think the same standards should apply to the Platte
River that apply to the Mississippi River. I think the standards should be
set, based on the topography and local conditions. Maybe a minimum standard
could be put in effect.
Question: (Michael Seaman, Snomish County, Washington): You said that, in
order for a 208 plan to be successful, the plan must demonstrate, very clearly,
the benefits to be derived from carrying o,ut the plan. Benefit/Cost analysis,
as we know, is a very "iffy" sort of thing, subject to different interpretation,
and it is difficult to quantify the benefits.
Answer: I don't think it is difficult to quantify the basic benefits. Perhaps
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you are talking about "indirect" benefits. I think that "direct" benefits
are not hard to quantify.
Question: When you say that a plan should have benefits, are you referring
to concise dollar amounts?
Answer: Yes! But I not only attribute benefits to increases in property
value, but to other things as well. Somebody taking my water is a benefit,
the same as someone removing and hauling trash from my house. I think a
dollar value could be placed on the potential use of the Platte River for
recreational purposes. For example, I am planning a linear park 200 feet wide
extending for 10 miles along the Platte River through Denver. This park will
have a definable area, extent, and value; and people will understand this.
In this way, I can translate to the public the need for keeping the Platte up
to a certain reasonable quality standard. Then, the taxpayer will be willing
to pay for it. I think we could assess the cost on the basis of who is
causing the problem.
Question: (Andy Andrews, Denver): What are your plans to broaden the scope
of studies made by the Urban Drainage and Flood Control District in Denver,
to include water quality investigation?
Answer: The District has contracted with the U.S. Geological Survey to identify
the extent of the urban runoff water quality problem. The due date of the
study report is about March 1976. When that information has been received and
accepted, the scope of work for engineers working for the District will be
modified to include water quality data.
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Legal Aspects of Urban Storm Water Management:
and related
Pollution Abatement
Problems
*
by Frank E. Maloney
I - Introduction
The proper management of storm water runoff is a problem of
nationwide significance which is just now beginning to be given
the attention by urban planners that it has long deserved. The
solution to this problem seems to be two-fold -- more and larger
storm sewers for the paved areas, and temporary storm water deten-
tion in higher lands to allow the storm drains to perform their
function without overflowing. These solutions in themselves
present numerous legal problems, not the least of which is find-
ing legal means to provide the funds for their accomplishment.
But another problem has been added — one that the turn of
the century planners who provided many of the now inadequate
* B.A. 1939, University of Toronto; J.D. 1942, University
of Florida; Professor of Law and Dean Emeritus, University
of Florida Law Center, Dean 1958-1970; Principal Investi-
gator, Water Resources Scientific Information Center of
Comoetence in Eastern Water Law,
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storm sewers never had to consider. That problem is the pollu-
tion created by storm water runoff, and the proscription of
such pollution in the Federal Water Pollution Act and its state
counterparts. This problem is of course exacerbated in those
urban areas where ancient storm sewers double as sanitary sewers,
with the sanitary sewer effluent by-passing the local treatment
plant whenever the storm water runoff exceeds the capacity of
the plant, normally after every hard rain.
But even without the sanitary effluent problem, the storm
waters themselves collect their own pollutants from the city
streets and other paved areas, and it would seem that the zero
population goal of the 1972 amendments to the FWPCA cannot be
achieved without somehow solving the problem of pollution in
storm water runoff.
This paper will examine these two problems separately. It
will first address the problem of providing for the disposal of
the water itself, at the same time examining the "taking" issue
inevitably associated with that problem. The second part of the
paper will attempt an analysis of some of the legal ramifications
of the associated pollution problem which it is now
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realized is equally as difficult of solution as the disposal
problem itself.
II. The Disposal Problem
Leaving aside for the moment the pollution control
problem, there are basically two approaches to storm water
disposal, though both are inescapably interrelated. The first
is to detain the storm water for a period, allowing at least
a part of it to percolate underground and join the ground
water resources of the area, while delaying the runoff of the
rest long enough so that existing drains can handle it without
becoming so overtaxed as to cause other problems. The second
approach, often necessary even if the first is also undertaken,
is to improve the carrying capacity of the drains over lower
lands to avoid flooding from the increased water flows.
A. Increasing the flow over lower lands. It may be
appropriate to examine the second procedure first. Assuming
the engineering problems involved in increasing the flow are
manageable, there still may be serious legal problems con-
cerning the right to increase the flow, whether through natural
surface drainways or by artificial pipes which eventually empty
into a natural surface drain or stream.
Two basic doctrines are employed in determining the
legality of upper owners, including municipalities, draining
their lands over those of adjoining lower owners, as contrasted
with the possible right of the lower owner to turn the
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draining surface waters back upon his neighbor. They are
the civil law rule-^- and the common enemy doctrine.^
The civil law rule is expressed in the maxim Aqua
currit et debet currere, ut currere solebat.^ ("Water runs
and should run, as it is wont to do"). The rule in its
purest form is that no man may interfere with the natural
flow of surface waters. It is usually expressed in terms
of an easement of natural drainage as between adjoining lands,
so that the lower owner must accept the surface water which
naturally drains onto his land, but the upper owner can do
nothing to increase that burden.^ The rule is a part of the
common law .of England^ and dates back to the Roman Law and
the Code Napoleon.^
The advantage of the civil law rule is that rights
thereunder are readily predictable, but strictly applied it
tends to inhibit development and improvement of land, and
courts have frequently modified it when asked to apply it
to purely urban conditions. The rule is almost universally
interpreted to allow the upper owner to enhance the drainage
of his property to some degree. The upper owner is generally
allowed to hasten the flow of water by improving the natural
drainage.8 The degree to which he is allowed to artificially
drain his upper estate has been limited by the requirement
Q
that he not act unreasonably or negligently; by a balancing
of relative benefit and ha.rm;^^ by the condition that the
111-70
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increase in flow not be substantial or material;H by a
I O
prudent regard for the welfare of his neighbor; and by
the requirement that the waters not be diverted from their
natural flow and concentrated so as to flow onto the lower
lands at a different point.13 Qn ^he other hand, the upper
owner is sometimes allowed to greatly increase the flow of
water by a simple finding that the drainage channel by which
14
the water leaves his land is a "natural watercourse".
While the lower owner is forbidden by the rule to ob-
struct the "natural" flow of surface waters, his burden may
be eased by finding that the flow obstructed is not natural,
in that it has been artificially created or enhanced by
another. Other courts have allowed the lower owner to ob-
struct surface water as long as he does not act negligently.16
As a result of these modifications, the general civil
law rule today is that the upper owner may improve and enhance
the natural drainage of his land as long as he acts reasonably
and does not divert the flow, and that the lower owner is
subject to an easement for such flow as the upper owner is
allowed to cast upon him. Any obstruction of this flow by
the lower owner or diversion by the upper owner is generally
forbidden, but may be allowed in some jurisdictions subject
to the limitation of reasonableness. On the other hand, an
upper urban proprietor is generally prohibited from concen-
trating water in artificial channels and discharging it on
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on his neighbor to his harm.17 This rule has been applied
I p
to subdividers of upper property in a number of cases. °
The common enemy rule, followed in New England1^ and
a number of the Northeastern states, 20 an(j by South Carolina
in the Southeast, -*• in its pure form would give each land-
owner the right to deal as he pleases with surface water on
his land without regard for the consequences to his neighbor.
The doctrine originated in the right of a property owner to
use his own property as he pleases,22 but has been justified
on the basis of the right to fight the "common enemy",23
and on the ground that it encourages land improvement and
cultivation.24
Taken literally, the common enemy rule means that the
upper owner may drain or divert the flow of surface waters
onto the land of his neighbor at will, and that the lower
owner is free to obstruct the water as he pleases and back
it up onto the upper owner again. The rule has the advantage
of simplicity, and since there can be no invasion of one
another's legal rights, litigation should be minimized. On
the other hand, landowners are encouraged to engage in con-
tests of hydraulic engineering in which "might makes right"
and breach of the peace is often inevitable. Fortunately,
the rigors of the common enemy rule has led the courts adopt-
ing it to affix qualifications to meet the various situations
arising.
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As in the case of the civil law rule, a number of modi-
fications have taken place in the application of the rule.
For example in Sheehan v. Flynn^5 the Minnesota Court announced
that even under the common enemy rule it is the duty of an
owner draining his land to deposit surface water in some
natural waterbody, if one is reasonably accessible. In
another case applying the common enemy rule, the Missouri
Court held a landowner was not justified in improving his
own property so as to interfere seriously with adjacent
properties. 26 ipne modern common enemy rule can be said to
give the landowner the right to obstruct or divert surface
water only so long as such obstruction or diversion is incident
to ordinary use, improvement, or protection of his land, and
is done without malice or negligence.^
The rule of reasonable use occupies the middle ground
between the common enemy and civil law rules in their extreme
forms and produces results similar to the modified versions
of both. The advantage of the rule is that it embodies tort
principles and disregards the cumbersome property notions of
servitude and absolute ownership, but since the question of
reasonableness is regarded as a mixed question of law and fact
28
for the jury, much of the predictability embodied in the other
rules is lost.
The doctrine of reasonable use was first applied in New
Hampshire, %nd has since been expressly adopted by New Jersey,3
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Minnesota, 3-*- and Alaska. 32 other states, without expressly
adopting the rule, have reached practically the same results
through modification of the traditional rules. The Maryland
courts, for example, follow the civil law rule, but Maryland's
equity courts apply the doctrine of reasonable use when it
appears that undue hardship will result from the civil law
rule.33
Although the courts have treated the doctrine of reason-
able use as a separate rale on equal footing with the civil
law and common enemy rules, it is in reality merely the general
tort principle which would decide such cases in the absence
of the application of either of the two "property" rules.
Most surface water cases involve acts of an upper owner
which cause water to flow in increased quantity or a different
manner onto the land of ~^he lower owner, to his injury. The
abundance of such cases is ready proof of the inadequacy of
the traditional rules, for under the strict common enemy rule
the lower owner would have no cause of action, while under
the strict civil law rule the upper owner would have no defense,
and with such predictable results litigation would be infre-
quent. The courts have been repeatedly called upon, however,
to determine to what extent and in what situations the various
modifications to both rules apply.
As a general rule a landowner may improve the drainage
of his property so long as he merely enhances the natural
111-74
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flow of surface waters, but he may not divert surface waters
from their natural path nor may he collect them into a body
and discharge them onto the lower land.
B. Drainage into a Natural Watercourse. The right
to drain surface water into a natural watercourse requires
further treatment. The general rule is that a riparian
owner may drain surface waters into a natural watercourse
regardless of whether the civil law or common enemy rule is
followed. This right is subject to at least three limitations
which may be applied singly or in combination in various
jurisdictions. These limitations are:^4 (1) the drainage
must be reasonable; (2) waters must not be drained into a
watercourse which would not have found their way there
naturally; and (3) the natural capacity of the stream must
not be exceeded.
C. Theories of Action and Legal Remedies. When
surface waters, including storm waters, illegally invade
another's property, liability may be based on theories of
trespass, nuisance, or negligence. At common law, every
unauthorized entry upon the soil of another is a trespass, ^5
and the trespass action is sometimes used as the theoretical
basis for relief for such invasions. However, the prepon-
derance of modern cases treat surface water interference on
the theory of private nuisance.36 Nuisance has traditionally
been defined as an unlawful act which causes injury to a
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person in the enjoyment of his estate, unaccompanied by an
actual invasion of the property itself, this latter dis-
00
tinction is frequently disregarded today. In order for
a surface water case to fit this definition, attention must
be focused on the defendant's act as the nuisance and not
the resulting overflow which actually invades the plaintiff's
property. If emphasis is placed on the overflow of the
property, then the theory of trespass may appear more appro-
priate. When defendant creates a condition which threatens
imminent overflow, the plaintiff may be successful in abating
the condition as a nuisance, while he might be required to
wait for actual injury if he; sued in trespass or negligence.
Negligence is the only theory available in some common
enemy jurisdictions where acts of interference with surface
39
water are actionable only if negligently done. A negligence
action has the advantage that it does not usually accrue, and
thus the statute of limitations does not begin to run, until
40
actual harm is done. But there is the disadvantage that
the plaintiff's action may be defeated by his own contributory
negligence.
The preferred type of relief against wrongful interfer-
ence with surface water is the injunction. This is because
injunctive'relief is preventive and can furnish relief before
rather than after a threatened violation. Moreover, an injunction
may in many cases be the only effective sanction because provable
injury may be so small that a judgment for damages would
be valuable only as a means of preventing the gaining of a
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prescriptive right by the defendant.
An injunction will ordinarily issue only if the plain-
tiff establishes facts that would entitle him to that relief
according to the traditional equity rules governing issuance
of injunctions. Thus, the plaintiff must show, not only
that the defendant's act is unlawful, but also that the
threatened injury is irreparable, or one that cannot be ade-
quately compensated by an action at law, or that an injunc-
tion is necessary to prevent a multiplicity of suits at law.41
Although these facts are undoubtedly prerequisites, in theory
at least, for an injunction against interference with surface
waters, they are rarely considered in direct terms by modern
courts. Instead, it seems clear from the cases that any
actionable interference with surface waters will give rise
to an injunction if the plaintiff can show a definite threat
42
of substantial continuous or future injury. ' The reason for
this liberal treatment of persons injured by surface waters
is the unique nature of real estate. Damages for its invasion
by surface waters will nearly always be an inadequate remedy,
and to force the person injured to give up some of his rights
or ownership in return for damages confers a power of eminent
domain on the wrongdoer. However, in cases in which the
public benefit from the continuance of the nuisance outweighs
the harm to the injured party, the injunction may be denied by
some courts as a matter of discretion under the balance of
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convenience doctrine. Tne fact that the defendant is a.
municipality or other public body is not necessarily con-
kk
trolling, but it may be an extremely important factor in
weighing the balance against injunctive relief, in which
case the court may leave the aggrieved complainant to his
remedy by way of damages. -> A municipality should not rely
on such a result, however, since it is within the power of
the court to grant the injunction, and injunctive relief has
been granted in a number of such cases.'*"
How does all of th:is apply with respect to potential
municipal liability? As a general proposition, it has been
stated that municipalities are not liable for mere failure
to provide drainage systems, a type of municipal nonfeasance.
They have likewise been excepted from negligence in planning
for disposal of storm waters on the basis that such planning
is a discretionary function.^8 As one commentator has pointed
out, this favorable treatment in negligence actions against
local government units ironically may be at the root of
municipal failure to build storm water drainage systems.49
Negligence in construction, as distinguished from design, may
be another matter. The extent to which a particular state
has waived municipal governmental immunity may be controlling
here, and in some jurisdictions the classification of the
drainage work as governmental or proprietary may be determina-
tive.50
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In any event, if the result of the municipality's acts
is to cast additional waters on the complainant's land, the
city may well be liable on the basis of the common law authori-
ties previously discussed.51 Such liability could result
not only from harm done by the waters themselves, but also
from illegal alterations in surface water courses resulting
in harm to lower riparian owners.52
What if a storm sewer which is originally adequate
becomes overtaxed as a result of additional development on
higher lands? Again, the cases are split, with a number of
courts imposing a duty on the municipality to correct the
inadequacy,53 kut others refusing to assess liability for the
inadequate performance of a governmental function.^
If drainage works or changes in established grades by
a municipality result in flooding of lower property owners,
one way in which such owners may avoid a defense of govern-
mental immunity where that defense is still available is
through theories of inverse condemnation on the theory that
the city has taken private property or at least a flood ease-
ment in such property by its action.55 Theories of nuisance
have also been applied to avoid a defense of governmental
immunity in some jurisdictions.56
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III. THE STORM WATER DETENTION. P^OBI^EM
As stated earlier, one part of the solution to
the storm water problem is temporary detention of the
water on higher lands to prevent overloading lower
drains. But if this approach is implemented through
legislation providing for flood plain zoning, manda-
tory retention of runoff, or other land use regula-
tions, certain constitutional challenges may result
in the invalidation of these regulatory measures.
Depending upon the particular piece of property in-
volved, a landowner may validly contend that a dep-
rivation of property rights has occurred as a result
of the regulation questioned.
The concept of "taking" originally referred to
the outright seizure of the land by the government.
This meaning appears to be that contemplated at the
time the concept was incorporated into our Consti-
57
tution. This original conception of the taking of
property by government appears to have given rise to
two separate rules regarding governmental powers
over land that has persisted well into this century:
government, on the one hand, had a duty to pay com-
pensation if land was seized for public use, and on
the other hand, government had a right to regulate
ni-80
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the use of land so long as the regulation was reason-
ably related to a public purpose.
The separation between a taking and mere regula-
tion had its hey-day at the end of the last century.
In 1887 the United States Supreme Court declared the
then accepted law with respect to regulation and taking:
A prohibition simply upon the use of prop-
erty for purposes that are declared by valid
legislation to be injurious to the health,
morals or safety of the community cannot in
any just sense be deemed a taking or appro-
priation of property for the public benefit.
Such legislation does not disturb the owner
in the control or use of his property for
lawful purposes nor restrict his right to
dispose of it, but it is only a declaration
by the state that its use by anyone for
certain forbidden purposes is prejudicial to
the public interest.58
About 35 years later, the Supreme Court decided
59
the case of Pennsylvania v. Mahon, which today is
seen as a landmark case in the shift of legal theory
that has now linked the once separate theories of
"taking" and "regulation."
Speaking for the court, Justice Holmes noted the
general rule "... that while property may be regulated
to a certain extent, if regulation goes too far it
will be recognized as a taking." In order to measure
the permissible scope of regulation, the court esta-
blished the "diminution of value test" stating:
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One fact for consideration in determining
such limits is the extent of the diminu-
tion. When it reaches a certain magnitude
in most if not all cases there must be an
exercise of eminent domain and compensation
to sustain the act.61
Although the magnitude of diminution necessary to
constitute a taking is not clear, if the market value
of the property is completely destroyed, one would
expect that the requisite magnitude has been reached.
However, the law has now developed so that property
owners will not be compensated for regulations that
prevent the highest and best use that one can make of
their property as long as the property can be put to
fi o
a reasonable use. Generally, the diminution of
value test has played a decreasing role in state court
decisions and is now only one of several factors to be
considered in determining the validity of a regulation.
It now appears that courts to a larger degree engage
in a balancing of the public interest, comparing the
need for the regulation with the degree of infringement
of property rights. Over the last fifty yeajrs state
courts have decided literally hundreds of cases, each
of which determines whether the value of a particular
land use regulation does or does not outweigh the loss
of property value to a particular landowner. These
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decisions are nothing short of chaotic. Numerous
tests have been established to determine whether
certain regulations are so extreme as to constitute
an unconstitutional taking. Although the courts
have an array of theories to draw from when faced
with a taking issue, a sizeable minority are shift-
ing to the "newer" approaches which allow local go-
64
vernments greater lattitude in adopting regulations.
In planning control measures such as the loca-
tion of retention basins, it is conceivable that the
only feasible location would be in such a place that
the development value of the property might be sub-
stantially reduced. This would especially be a prob-
lem with smaller intensive developments where the
amount of land required for the retention basin is
proportionally greater when compared to that actually
developed for resale. However, new engineering and
planning techniques may alleviate this problem. De-
spite such possibilities, a property owner may still
argue that the value of the land actually set aside
for the basin has been taken since it cannot be used,
particularly if it must be left in its natural state,
without obstruction or occupation. If the retention
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basin were of considerable size, its value as devel-
opment property would be greater and thus the loss to
the landowner greater also.
In some cases it may be argued that what is really
taken is the property right of naturally draining one's
property, which is arguably a taking if it goes to the
extent of seriously interfering with reasonable use of
the property.
Generally, the taking question revolves around
vague principles of law which seek to balance private
property rights against the public good. Each case
will depend upon its particular facts. Storm water
management planners should always take into consider-
ation the effect of their plans on regulation of pri-
vate property in light of the taking question. Obvi-
ously this is not to say that detention on upper lands
is always a taking. In all probability it can most
often be classed as justifiable regulation in the pub-
lic interest. Thus the city of Gainesville, Florida
has recently enacted a flood plain zoning ordinance
which while yet untested legally, is a scientifically
sound regulatory approach to the problem which is
worth further study as a model for such regula-
tion. Subdivision regulations, building and housing
III-8A
-------
codes, and reservation of low lying areas for parks
and recreational facilities are other possibilities
to help protect urban areas against flooding.
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IV. The Pollution Problem
Let us now turn to the second major problem respecting urban
storm water management — that of pollution control.
A. Common Law Development
As in the first part oE this paper it may be appropriate to
begin an analysis of the problem with a discussion of the common
law legal remedies and thei;: current status in the law of pol-
lution control today. In the past, such remedies frequently
failed to adequately protect the public interest. This failure
has been a contributing factor in legislative attempts to provide
greater environmental protection. Inadequacies of earlier pol-
lution control legislation, in turn, have led a number of courts
to reexamine and sometimes refurbish the common-law remedies.
Examining these remedies, one finds a blend of property
and tort law governing them. The first such remedy stems from
a property law concept rooted in Eastern riparian water law doc-
trine. The riparian owner, according to the older natural flow
doctrine, has no right to change the natural condition or charac-
teristics of the water in a navigable water body, and any such change
is actionable without the necessity of actual harm. This rule
remains in effect in a few Eastern jurisdictions including Georgia
f- Q
and South Carolina. In most Eastern states, however, the rea-
sonable use rule modifies the strict approach of natural flow
and grants the lower riparian only the right to have his water
6 9
kept free from unreasonable interference. A use cannot be un-
70
reasonable if there is no actual injury to other riparian owners.
ni-86
-------
Even if there is injury, the use nevertheless may be privileged
if reasonable under all the facts. Thus, in certain circum-
stances the pollution of water may be reasonable and therefore
72
lawful under the latter approach.
Reasonableness is a factual question controlled by the cir-
cumstances of each case. It cannot be determined in advance
with any certainty. In deciding how much pollution is reason-
able courts have considered these factors: the stream's character,
its volume and velocity, past uses of the stream, location and
use of the plaintiff's land, extent of plaintiff's damages, local
customs and customs of the industry involved, and comparative
public concern on the two sides of the controversy.
The switch from the natural flow to the reasonable use rule
robbed the water law property concept of much of its effective-
ness as a tool for pollution control. As a result, today the
usual theory of action in a pollution suit is private nuisance.
As is the case in the disposal problems discussed earlier, the
nuisance suit is predicated upon an unreasonable interference
with the use and enjoyment of land and accompanying water rights.
Trespass is another 'theory employed by some courts, but it is
not often relied upon since it is considered possessory in nature.
Considering the nuisance remedy in more detail, private
nuisance is an unreasonable interference with the use and enjoy-
ment of real property, and obtaining relief is dependent upon
both proof of damage and a finding that the defendant's activities
77
are "unreasonable". A public nuisance action, on the other hand,
111-87
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is available for injury to the public in the exercise of its
•7 Q
common rights. ° The activity that constitutes a public nuisance
is usually a crime, but the existence of criminal sanctions gene-
7 9
rally does not make the tort remedy unavailable. If an act
interferes both with common rights of the public and with private
use and enjoyment of land, a private as well as public nuisance
action may be available, but a private individual may not maintain
the public nuisance action in the absence of proof of special damage
to him different in kind from that suffered by the public at large.
Absent such special damage, the state, as protector of the public,
O f\
is the proper plaintiff.
The preferred relief against both public and private nuisances
is the injunction because it furnishes a remedy before rather than
after damage occurs. Moreover, in many cases injunctive relief
may be the only effective sanction because provable injury to any
one individual is so small that a judgment for damages would be
valuable only to prevent the defendant from gaining a prescriptive
right. An injunction, however, will be issued only if the plaintiff
proves that injunctive relie:: is necessary, because the threatened
injury is irreparable. This would be the case if the injury could
not be adequately compensated for by damages at law, or if a multi-
81
plicity of suits would result from failure to grant the injunction.
As pointed out in Part II of this paper, an injunction may
be refused for several reasons. In comparing the relative impor-
tance of the interests of the parties to determine whether to
grant injunctive relief, or "balancing the equities," a court may
111-88
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deny an injunction on the ground that the public interest in
permitting a particular activity to continue is of overriding
82
importance despite damage to the plaintiff. This defense is
8 3
often raised on behalf of municipal or governmental operations,
and has been relatively successful in earlier cases. Another
roadblock, at least against the prosecution of a public nuisance
action, may be a claim that the state, either by legislative
action or by constitutional amendment, has legalized a type of
pollution, thereby lifting it out of the category of a public
84
nuisance. Thus, an ordinance authorizing storm sewers arguably
could be construed as taking the pollution of streams by storm
85
water discharges out of the public nuisance category.
With respect to both public and private nuisance, until recent
years courts in general tended to overprotect the right to own and
use private property and failed to recognize the ecological conse-
86
quences of pollution. This led them, for the most part, either
to deny the existence of the nuisance altogether, or to refuse an
injunction because the economic importance of the polluter's opera-
p 7
tions caused the equities to be balanced in favor of the polluter.
In the absence of the effective statutory regulation, conser-
vationists increasingly fell back on private lawsuits during the
1960's in their attempts to protect the environment. They have
been successful in a number of recent cases in which some courts
appear to have reversed their traditional bias favoring exploiters
of the environment. Today, emphasis on the factor of danger to
public health is beginning to tip the scales in favor of injunctive
O Q
relief where balanced against economic interests. Moreover,
111-89
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where courts once considered only the interests of the immediate
parties to the lawsuit, they are now beginning to respond to
societal as well as the private issues involved. This new aware-
ness, of course, may cut both ways when injunctive relief against
a municipality is being sought, but planners of storm water drain-
age facilities need to be aware of the possibility that those
receiving polluted storm waters have a better chance today than
in the past of obtaining both damages and injunctive relief in
common law actions. It is still true, however, that generally,
common law tort liability has been an ineffective technique for
89
controlling pollution. For this, among other reasons, both
state and federal legislatures, have placed pollution control
90
primarily in the hands of administrative agencies.
B. Water Pollution Legislation
1. General Validity
Although the present environmental consciousness was slow to
bloom, anti-water pollution legislation is not a recent innovation.
For many years the courts of numerous jurisdictions have construed
and passed upon the validity of such measures. Generally the
courts have held that anti-water pollution legislation is a valid
exercise of the police power to protect the public health and
welfare. Such statutes, administrative regulations and ordinances
have been upheld against allegations that they are unreasonable,
illegally promulgated, and constitute an unconstitutional taking
of property without compensation. Very few cases have invalidated
anti-water pollution efforts, and those that have, were mostly
earlier cases (pre-1930).
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2. FWPCA Amendments 1972
(a) Goals
With the enactment of the 1972 Federal Water Pollution
Control Act Amendments (FWPCA), the federal government has
taken over a prominent role in water pollution control. Section
101 (a) of the Act makes the restoration and maintenance of the
chemical, physical, and biological integrity of the nation's
92
waters a national goal. This is to be accomplished by: (1)
eliminating the discharge of pollutants into navigable waters
by 1985; (2) attaining a degree of water quality conducive to
recreation and the protection of fish and wildlife by July 1, 1983;
(3) forbidding the discharge of toxic pollutants; (4) constructing
publicly owned treatment works through Federal financial assistance;
(5) implementing areawide waste treatment management plans; and
93
(6) initiating research to develop the necessary technology.
Water quality standards established by the 1972 FWPCA Amend-
ments do not depend upon the quality of the body of water receiving
the discharges, but emphasize treatment at the pollution sources.^1*
As one commentator put it, "This change from 'receiving water
standard's to effluent limitation standards' is new to the field
of water pollution control, and is the principal reason for the
widespread controversy about the 1972 Amendments."95 Other com-
mentators suggest that the goals may not be realized within the
statutory deadline, because of high costs involved in attaining
the zero discharge goal, and this factor is particularly true of
the treatment of storm water runoff. The Act has been criticized
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as requiring wastewater treatment beyond what is necessary to
preserve the nation's water resources, and creating costs which
greatly exceed the social benefit. Some writers suggest that
Congress must revise the statutory timetables if the Act is to
remain an effective measure. It remains to be seen whether this
suggestion will be acte'd upon, but meanwhile the zero discharge
goal appears to have set an almost impossible task for those con-
cerned with disposal of urban storm water runoff.
(b) Enforcement & Citizen Suits
The enforcement provisions of the FWPCA Act should be con-
sidered in light of the awesome task it requires. Previous
legislation rarely contained provisions for enforcement actions
against municipal polluters. Today, Section 502 (5) of the
Act indicates that the enforcement provisions apply to munici-
palities. This result is accomplished by defining person as
"... an individual, corporation, partnership, association, state,
municipality, commission, or political subdivision of a state, or
any interstate body". Because some state laws make local finan-
cing of treatment plants extremely difficult, cities may find
themselves confronted with enforcement actions involving fines
and mandatory court orders. Without the financial tools to
make compliance realistically possible, quite a dilemma exists
for some local governments.
However, it is interesting to note that Section 309 (e)
added by the 1972 Amendments requires joinder of the state as a
party in civil actions instituted by the United States against
97
a municipality. This section provides that the "...State shall
111-92
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be liable for payment of any judgment, or any expense incurred
as a result of complying with any judgment entered against the
municipality in such action to the extent that the laws of the
state prevent the municipality from raising revenues needed to
comply with such judgment." This section appears to serve as
an inducement for the states to lessen constraints on municipalities,
An important provision relevant to federal enforcement, §505,
gives citizens the right to seek court enforcement of effluent
limitations and standards. The authorization includes suits
99
against the EPA for failure to perform non-discretionary duties.
This section acquires significance in relation to enforcement
provisions which require the EPA to take action against polluters.
Further, it is interesting to observe that federal court juris-
100
diction is without regard to the amount in controversy, and
that subsequent cases have held that the PWPCA Amendments do not
abrogate the common law remedies discussed previously.
(c) Point and Nonpoint Sources
In establishing effluent discharge limitations the 1972
FWPCA Amendments distinguish point sources from nonpoint sources
of pollution. Section 502 (14) defines "point source" as
"...any discernable, confined and discrete conveyance, including
but not limited to any pipe, ditch, channel, tunnel, conduit,
well, discrete fissure, container, rolling stock, concentrated
animal feeding operation, or vessel or other floating craft,
from which pollutants are or may be discharged." In contrast
with point source, non-point source is not directly defined in
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the Act. A reading of Section 304 (c), however, indicates such
sources as run-off from fields, construction sites, and mines,
along with seepage of various sorts not flowing from "discrete
fissures" are all included in non-point sources.
Interjection of storn water management into this framework
poses some confusion, because storm water flow sometimes appears
to fall into both point and non-point categories. Thus, in one
sense, connection system flows may be considered as point
pollution sources whereas sheet-flow runoff is termed as non-point
pollution simply because it is not collected or directed in a
defined pattern and may enter the receiving water at numerous
locations. Arguably, storm water discharges may fall under the
waste water effluent standards when categorized as point sources,
and remedial action to include some form of treatment may be man-
dated under the Act. Since non-point sources and point sources
are afforded somewhat different treatment by the Act, the statutory
constraints on storm water disposal may vary with the disposal
method used. However, the Act is new and complex thus, its defini-
tions, limitations, and requirements have not, as yet, been in-
104
terpreted with the utmost of clarity.
(d) Navigable Waters
A very crucial, yet unanswered question, is the extent of
federal jurisdiction under the Act. Generally, federal power
over inland waters.has been associated with the "navigable waters"
formula, and the 1972 Amendments to the FWPCA also seem to tie
jurisdiction to navigable v/aters. However, the 1972 Act defines
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"navigable waters" as "...the waters of the United States including
the territorial seas," §502 (7). Some commentators argue that
federal jurisdiction does not extend to -all the waters of the
United States. These arguments are supported somewhat by
both the Constitution and established judicial precedent. The
Constitution does not directly empower Congress to regulate the
waters of the United States. Federal jurisdiction over waterways
has been implied from the Commerce Clause. Regulation of
navigable waters was thought to be implicit in the regulation
of Commerce.
Some critics at first felt that the term "navigable waters"
was a major loophole in the Act because discharges into non-
108
navigable waters would not be regulated. Earlier case law
had held that federal jurisdiction is limited to navigable waters,
109
but in two recent cases — U.S. v. Ashland Oil Co. and U.S. v.
Holland — FWPCA jurisdiction has been held to extend to non-
navigable waters. Administrative definitions seek to give the
term "navigable waters" its "broadest possible constitutional
interpretation." Confusion arises from the fact that while
Congress defined "navigable waters" as "waters of the United
States", it failed to define "waters of the United States", thus
leaving open to question whether federal jurisdiction under the
112
Act remains bound to "navigable waters".
An additional problem is whether the FWPCA Amendments apply
to discharge of pollutants into subsurface waters. This problem
is of great relevance in states such as Florida where underground
injection of wastes is a fairly common occurrence. Two federal
district courts, in Texas and Arizona, have spoken to this issue,
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with a resulting split of authority.
Because of the confusion over jurisdiction under the FWPCA
1972 Amendments, some commentators suggest that Congress should
avoid reliance on the Commerce Clause and exercise federal power
under the General Welfare Clause. However, under the Welfare
Clause the costs may be greater, because the courts have often
found regulation under that clause to be a compensable taking
of property, while Congress has been given greater license
114
under the Commerce Clause. Yet, with today's increased
public awareness of environmental conservation, and an increased
judicial affinity for environmental legislation, arguably federal
water pollution jurisdiction may be justified adequately under
either constitutional provision.
V. CONCLUSION
Continuing rapid urbanization in the United States has
brought the storm water runoff problem to the forefront of the
consciousness of many urban planners who have come to the reali-
zation that urban growth normally results in a radical alteration
of the natural drainage patterns of the urbanized area, and that
a properly planned storm water drainage system has become a
necessity from both a practical and legal viewpoint.
In general, municipalities today have the legislative
authority to plan for and establish such systems. Additional
legislation to provide for more adequate funding, including
possible user charges to be assessed against those from whose
land the discharges originate, may well be necessary to fully
ni-96
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implement such plans. In this connection, provisions for
regional planning and implementation should not be overlooked.
The primary disincentive is one of costs—costs not only
for acquisition of rights of way and flood easements to avoid
potential lawsuits by lower owners who are injured by increased
water flows, but also, under new state and federal anti-pollution
laws, for what could be staggering costs to attain zero pollution
in the extremely large discharges of storm water runoff into the
waters of the nation.
The problem of avoiding excessive and over-rapid discharges
can be solved in part by provision for detention and temporary
storage of more storm water on upper lands. The possibility
that requiring such detention constitutes a taking of property
rights of upper landowners for which compensation must be paid
is a disincentive to this type of planning.
However, reasonable flood plain zoning, now mandated for
many communities by a strong Federal Flood Insurance Act,
should help keep the cost of providing for such detention within
reasonable parameters, even if flood easements have to be pur-
chased or condemned by the community.
The anti-pollution problem may be more difficult of solution.
If the zero pollution goal of the FWPCA is to be applied to
storm water runoff in the same way as to pollution from sanitary
facilities, without new technological breakthroughs in treatment
methodology, massive costs will necessarily be involved. It
would seem reasonable that the federal government, which has
mandated the treatment, should bear at least a major portion
of those costs. Whether the Congress of the United States will
III-Q7
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face up to this obligation, or alternatively provide some
lesser purity requirement for storm water runoff, remains to
be seen.
Storm water detention, with resulting discharge of a part
of the polluted water into the groundwater system, will alleviate
the problem somewhat insofar as discharges into surface waters
are concerned, but if the courts agree that the waters of the
United States include groundwaters, any effort to avoid the
pollution problem through discharge into groundwater aquifers
will eventually prove non-productive. Enforcement agencies
probably will not be allowed to ignore the problem as it dis-
appears into the ground. The citizen suit provisions of the
FWPCA plus possible use of the common-law legal remedies may
well assure that the problem will be faced up to through
litigation in the courts. The ultimate solution to this problem
may prove to be a technological rather than a legal one. Absent
any amendment of the existing law, however, one can look forward
to some interesting litigation in the 1980's.
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Footnotes
1. See, e.g., Tiedeman v. Village of Middleton, 25 Wis. 2d
443, 130 N.W.2d 783 (1964); Phillips v. Chesson, 281
N.C. 566, 58 S.E.2d 343 (1950); Slatten v. Mitchell,
22 Tenn. App. 547, 124 S.W.2d 310 (1938); Note, California's
Surface Waters, 39 So. Cal. L. Rev. 128 (1966).
2- See, e.g., Turner v. Smith, 217 Ark. 441, 231 S.W.2d 110
(1950); Tide Water Oil Sales Corp. v. Shimelman, 114 Conn.
182, 158 A.229 (1932); Bennett v. Cupina, 253 N.Y. 436,
171 N.E. 698 (1930); Davis, The Law of Surface Water in
Missouri, 24 Mo. L. Rev. 137 (1959).
3. Kent, Commentaries on American Law 439 (14th ed. 1896);
Kautfman v.Griesemer,26 Fa.407, 413 (1856).
4. Gough v. Goble, 2 111. 2d 577, 119 N.E.2d 252 (1954);
see Annot., 59 A.L.R.2d 421, 429 (1958).
5. 3 Farnham, Waters & Water Rights §877 (1904); the modern
English law of drainage is largely statutory; see Coulson
& Forbes, Law of Waters, 823-37 (6th ed. 1952).
6. 3 Farnham, note 5, supra, at §889a.
7. The present provisions of the Louisiana Civil Code express
the civil law position: "It is a servitude due by the
estate situated below to receive the waters which run
naturally from the estate situated above, provided the
industry of man has not been used to create that servitude.
"The proprietor below is not at liberty to raise
any dam or to make any other work, to prevent this running
of the water.
"The proprietor above can do nothing whereby the natural
servitude due by the estate below may be rendered more burden-
some." La. Stat. Ann., Civ. Code, Art. 660 (1972).
8. E.g., La Fleur v. Kolda, 71 S.D. 162, 22 N.W.2d 741 (1946).
9. E.g., Ratcliffe, v. Indian Hill Acres, Inc., 93 Ohio App.
231, 113 N.E.2d 30 (1952); Thompson v. Andrews, 39 S.D.
477, 165 N.W. 9 (1917).
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10. E.g., Venson v. Turner, 252 Ala. 271, 40 So.2d 863 (1949);
Battisto v. Perkins, 210 Md. 542, 124 A.2d 288 (1956).
11. E.g., Cundiff v. Kopsei^er, 245 Iowa 179, 61 N.W.2d 443
(1953); Bishop v. Richard, 193 Md. 6, 65 A.2d 334 (1949).
12. E.g., Hughes v. Anderson, 68 Ala. 280 (1880).
13. E.g., Martin v. Jett, 12 La. 501 (1838).
14. See Annot., 81 A.L.R. 262 (1932).
15. See F. Maloney, S. Plager & F. Baldwin, Water Law and
Administration, Tne Florida experience §T5(1968).
16. Taylor v. Harrison Const.r. Co., 178 Pa. Super. 544, 115
A.2d 757 (1955) .
17. Kay-Noojan Dev. Co. v. Finzer, 259 Ala. 49, 65 So.2d 510
(1953) .
18> E.g., Rau v. Wilden Acres, Inc., 376 Pa. 493, 103 A.2d
422 (1954).
19. Tide Water Oil Sales Corp. v. Shimelman, 114 Conn. 182,
158 A. 229 (1932); Greely v. Maine Cent. R. Co., 53
Me. 200 (1865); Harrison v. Poli-New England Theatres,
Inc. 304 Mass. 123, 23 N.E.2d 99 (1939).
E.g.,
20. Bennett v. Cupina, 253 N.Y. 436, 171 N.E. 698 (1930); Nassau
County v. Cherry Valley Estates, Inc., 281 App. Div. 692, 117
N.Y.S.2d 616 (1952).
21. Seje Deason v. Southern R. Co., 142 S.C. 328, 140 S.E. 575 (1927)
22. Gannon v. Hargadon, 92 Mass. 106 (1865), citing the maxim
"Cujust est solum, ejus est usque ad coelum."
23. Town of Union v. Durkes, 38 N.J.L. 21 (1875).
24. E.g., Timmons v. Clayton, 222 Ark. 327, 259 S.W.2d 501 (1953);
Borkley v. Wilcop, 86 N.Y. 140 (1887); Bowlsby v. Speer, 31
N.J.L. 351 (1865) .
25. 59 Minn. 436, 61 N.Y. 462 (1894).
26. Frendenstein v. Heine, 6 Mo. App. 287 (Ct. App. 1878).
27. See Dobbins, Surface Water Drainage, 36 Notre Dame Law, 518,
523-24 (1961).
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28. Swett v. Cutts, 50 N.H. 439 (1870).
29. Franklin v. Durgee, 71 N.H. 186, 51 A. 911 (1901); Swett v.
Cutts, 50 N.H. 439 (1870).
30. Hopler v. Morris Hills Regional Dist., 45 N.J. Super. 409,
133 A.2d 336 (Super. Ct. App. Div. 1957); Armstrong v.
Francis Corp., 20 N.H. 320, 120 A.2d 4 (1956).
31. Enderson v. Kelehan, 226 Minn. 163, 32 N.W.2d 286 (1948);
Sheehan v. Flynn, 59 Minn. 436, 61 N.W. 462 (1894).
32. Weinberg v. Northern Alaska Dev. Corp., 284 P.2d 450 (Alas.
1963).
33. Whitman v. Forney, 181 Md. 652, 31 A.2d 630 (1943); see
Comment, 11 Md. L. Rev. 58 (1950)
34. These limitations are developed in more detail in the discussion
of cases in the text following.
35. See Prosser, Torts §63 (4tb ed. 1971).
36. See, e.g., Lawrence v. Eastern Air Lines, 81 So.2d 632 (Fla.
1955); Deason v. Southern R. Co., 142 S.C. 328, 140 S.E. 575
(1927); Henry v. Ohio River R. Co., 40 W. Va. 234, 21 S.E. 863
(1895) .
37. Defuniak, Handbook of Modern Equity, 5? (2d ed. 1956) .
38. See Miami Springs v. Lawrence, 102 So.2d 143 (Fla. 1958).
39. Bussell v. McClellan, 155 Neb. 875, 54 N.W.2d 81 (1952);
Timmons v. Clayton, 222 Ark. 3.?7, 259 S.W.2d 501 (1953).
40. See F. Maloney, supra note 15, §74.3.
41. Koch v. Wick, 87 So.2d 47 (Fla. 1956) (plaintiff seeking
injunction and damages against city in ground water case);
Roughton v. Thiele Kaolin Co., 209 Ga. 577, 74 S.E.2d 844
(1953); see generally 56 Am. Jur. Waters §421 (1947).
42. New Homes of Pensacola, Inc. v. Mayne, 169 So.2d 345 (1st D.C.A.
Fla. 1964); Hunt v. Smith, 238 Iowa 543, 28 N.W.2d 213 (1947);
see also Mader v. Metenbrink, 159 Neb. 118, 65 N.W.2d 334
(1954); Dixon v. City of Nashville, 29 Tenn. App. 282, 203
S.W.2d 178 (1946) .
43. Harris v. City of Lakeland, 141 Fla. 795, 193 So. 826 (1950);
City of Lakeland v. Harris, 143 Fla. 761, 197 So. 470 (1940)
(court used balance of convenience doctrine to refuse injunctive
relief against city); Maloney, The Balance of Convenience
Doctrine in the Southeastern States, Particularly as Applied
to Water, 5 S.C.L.Q. 159 (1952).
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44. Lawrence v. Eastern Air Lines, 81 So.2d 632 (Fla. 1955).
45. Lakeland v. Harris, 143 Fla. 761, 197 So. 470 (1940); see
Maloney, supra note 43, at 166.
46. See Penn v. City of Lakeland, 109 So.2d 771 (2d D.C.A.
Fla. 1959).
47. Kenworthy, Urban Drainage: Aspects of Public and Private
Liability, July-August 1962 Dicta 197, 205 "(1962).
48. Martinez v. Cohn, 56 N.M. 343, 244 P.2d 134 (1952).
49. Shoemaker, An Engineering-Legal Solution to Urban Drainage
Problems, 34 Denver L. J. 381, 385 (1968).
50. True v. Mayor of Westpoint, 196 Md. 280, 76 A.2d 135 (1950);
see also Note, Assault On The Citadel: De-immunizing
Municipal Corporations, 4 Suffolk U.~L. Rev." 832, 859-60 (1970)
51. See pp. 9-12 supra; see also Brown v. Sigourney, 164 Iowa
184, 145 N.W. 478 (1914) .
52. See pp. 9-10 supra.
53. Denver v. Mason, 88 Colo. 294, 29C Pac. 788 (1931); see
annot., 70 A.L.R. 1347 (1931).
54. Bratonja v. Milwaukee, 3 Wis. 2d 120, 87 N.W.2d 775 (1958)
(on the basis of discovery).
55. Dallas County v. Dillard, 156 Ala. 354, 47 So. 135 (1908).
Bd. of County Commrs. v. Allen, 69 Colo. 290, 194 P. 621
(1920); Nelson County v. Loving, 126 Va. 283, 101 S.E. 406
(1919).
56. City of Ada v. Cainoy, 198 Okl. 206, 177 P.2d 89 (1974); Greer
v. Lennox, 79 S.D.. 28, 107 N.W.2d 337 (1971).
57. See Bosselman, The Constitutional Rights of Landowners v.
the Need to Control Growth and Protect Our Environment.
Remarks to the Florida Young Lawyers Convention, March 9,
1974, p. 3.
58. Mugler v. Kansas, 123 U.S. 623 (1887).
59. Pennsylvania Coal v. Mahon, 260 U.S. 410 (1922).
60. Id. at 415.
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61. Id. at 413.
62. See Goldblatt v. Hempstead, 369 U.S. 590 (1962).
63. Binder, Taking Versus Reasonable Regulations, A Reappraisal
in light of Regional Planning and Wetlands, 25 U. Fla. L. Rev.
1, 5 (1972).
64. See generally, Bosselman, Callies and Banta, The Taking,
Issue, pt. 3, (U.S. GPO, 1973).
65. See, Hillsborough County Environmental Protection Commission
v. Pranderson Properties, Inc. 283 So.2d 65 (2d D.C.A. Fla.
1973).
66. Maloney, Judicial Protection of the Environment: A New
Role for Common Law Remedies, 25 Van. L. Rev. 145, 146 (1972).
67. F. Maloney, supra note 15 §112.1.
68. Raughton v. Thiele Kaoline Co., 209 Ga. 577, 74 S.E. 2d 844
(1953); Williams v. Haile, 85 S.C. 1, 66 S.E. 1057 (1910).
69. F. Maloney, s_upra note 15, §112.1.
70. Id.
71. See Parsons v. Tennessee Coal, Iron & R.R., 186 Ala. 84, 64 So. 591
(1914) .
72. In an early case involving pollution of an underground stream,
the Florida court accepted the reasonable use modification
of the natural flow doctrine, noting: "The right to the
benefit and advantage of the water flowing past one owner's
land is subject to the similar rights of all the proprietors on
the banks of the stream to the reasonable enjoyment of a natural
bounty, and it is therefore only for an unauthorized and
unreasonable use of a common benefit that one has just cause
to complain." Tampa Waterworks Co. v. Cline, 37 Fla. 586,
595, 20 So.780, 732 (1896) (emphasis added).
73. Restatement of Torts, §582, comment b (1939).
74. Powell. Tteal Property 376 (1962); Note, Purity & Utility:
Diversity of Interest in River Pollution, 84 U. Pa... L. JRev.
630, 637 (1936) .
75. Prosser, Torts 622 pd ed. 1964).
76. W. G. Duncan Coal Co. v. Jones, 254 S.W. 2d 720 (Ky. 1953).
77. Beckman v. Marshall, 85 So.2d 552 (Fla. 1956).
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78. Maier v. City of Ketchikan, 403 P.2d 34, 38 (Alas. 1965).
79. People v. Truckee Lumber Co., 116 Cal. 397, 48 P. 374 (1897).
80. See, e.g., J. H. Miles & Co. v. McLean Contracting Co., 180
F.2d 789 (4th Cir. 1950).
81. Holman v. Athens Empire Laundry Co., 149 Ga. 345, 100 S.E. 207
(1919).
814
82. Cohen v. City of Houston, 176 S.W. 809,/(Tex. Civ. App. 1915).
83. See generally, Maloney, The Balance of Convenience Doctrine in
the Southeastern States, Particularly as Applied to Water,
5 S.C.L.Q. 159 (1952).
84. See Juergensmeyer, Common Law Remedies and Protection of the
Environment, 6 V.B.C.L. Rev. 215 (1971)? 25 Texas L. Rev.
96 (1946).
85. In 1930 Florida added a section to its state constitution
providing a fifteen-year tax exemption to particular industries
as an inducement for establishing plants in Florida, in the
case of National Container Corp. v. State ex rel Stockton, 138
Fla. 32, 189 So. 4 (1939), the Florida Supreme Court held that
this exemption necessarily granted the polluter immunity from
public nuisance suits. Similar results were reached by the
Florida court in subsequent cases involving the drilling of
oil wells in tidal waters pursuant to an oil lease statute
and the operation of an airport under a municipal ordinance.
Brooks v. Patterson, 159 Fla. 263, 31 So.2d 472 (1947).
86. Richard's Appeal, 57 Pa. 105 (1868).
87. However, it should be noted that not all of the early cases
treated the environment so harshly. See Georgia v. Tennessee
Copper Co., 206 U.S. 230 (1907).
88. See, e.g., Department of Health v. Owens-Corning Fiberglass
Corp., 100 N.J. Super. 366, 242 A.2d 21 (1968).
89. Perhaps the primary weakness is that the damage remedy,
which is much easier to obtain for stream pollution than the
injunction, is not designed to prevent pollution initially
but to afford relief retrospectively to parties injured.
Pollution and its control involve complex technical problems
which courts simply are not equipped to handle effectively.
Even were a particular,court to have the necessary expertise,
it would be in no position to formulate a comprehensive
pollution control program because it is compelled to act on a
case-by-case basis. See; F. Maloney, supra note 15, §112.4.
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90. Id.
91. 32 A.L.R. 3d at 232.
92. Joelson & Fleischaker, The Water Pollution Control Act,
20 Prac. Law. 29, 30 (1974).
93. Id.
94. 10 Gonzaga L. Rev. 165, 167 (1974).
95. Id. at 168.
96. See generally, Shinn, The Federal Grant Program to Aid
Construction of Municipal Sewage Treatment PIants; A
Survey of the 1972 FWPCA Amendments, 48 Tul. L. Rev. 85, 103
(1973). .
97. Id. at 104.
98. 33 U.S.C. §1365 (supp. 1975).
99. 33 U.S.C. §1365 (a) (2) (supp. 1975).
100. 33 U.S.C. §1365 (a) (supp. 1975); see also 1973 Wis. L. Rev.
893, 902 (1973).
101. See, e.g., Illinois v. City of Milwaukee, Wis., 406 U.S. 91
(1972); United States v. United States Steel, 356 F. Supp. 556
(N.D. 111. 1973).
102. Compare 33 U.S.C. §1362 (1^) (supp. 1975), with 33 U.S.C. §1314(e)
(supp. 1975).
103. Smith, Highlights of the Federal Water Pollution Control Act
of 1972, 77 Dick. L. Rev. 459, 468 (1973).
104. Id. at 491.
105. See 19 St. Louis U. L. J. 208 (1974).
106. U.S. Const., Art. 1, §8.
107. See, e.g., United States v. Appalachian Electric Power Co.,
311 U.S. 377 (1940).
108. 19 St. Louis U. L. J. 208, 217 (1974).
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109. 504 F.2d 137 (6th Cir. 1974).
110. 373 F. Supp. 665 (M.D. Fla. 1974).
111. In considering the term, the EPA issued this statement:
"However, for the purpose of making initial administrative
determinations, at least the following waters would
appear to be 'waters of the United States':
(1) All navigable waters of the United States;
(2) Tributaries of navigable waters of the United
States;
(3) Interstate waters;
(4) Intrastate lakes, rivers, and streams which are
utilized by interstate travelers for recreational
or other purposes;
(5) Intrastate lakes, rivers and streams from which
fish or shellfish are taken and sold in interstate
commerce; and
(6) Intrastate lakes, rivers, and streams which are
utilized for industrial purposes by industries in
interstate commerce." 33 C.F.R. §209 (1975) (intro. material
at 19766).
112. 19 St. Louis U.L.J. at. 211.
113. United States v. GAF Corp., 389 F. Supp. 1379 (S.D. Tex 1972);
contra, United States v. Phelps Dodge, 391 F. Supp. 1181
(D.C. Ariz. 1975).
114. See United States v. Gerlach Live Stock Co., 339 U.S. 725
(1950).
115. 42 U.S.C. §4001 et. seq. (1973).
III-106
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By Jay Fountain
and
Dwight Cochran
FINANCING STORM, WATER .CONTROL PROTECTS
When Herb Poertner first asked me to speak on the subject of innovative
methods of financing storm water control projects, being a person attuned to
the systems approach to problems, I of course approached it in a normal, logical
manner, trying to ascertain what innovative approaches were being utilized pre-
sently by local governments and thinking that throughout the United States
certainly a lot of governmental administrators must have approached this problem
of an innovative method .
I started by talking to local governments--the City of Atlanta, DeKalb
County--and my own unit of government, Fulton County. The consensus reached
among those governments was basically that the best way of financing storm
water control projects is to ignore them; just don't do them at all if possible.
My first response to this was "Hmmm, is that exactly the way to go about some-
thing like this?" So, to endeavor to find out more information, we sent out
questionnaires to approximately 100 cities and counties throughout the United
States. We requested them to feed back information to us concerning what methods
they have used and are currently using for financing storm water control projects
and what innovative approaches they could think of and would like to see pursued.
We received 21 responses. From the 21 responses, I obtained sufficient
information on innovative methods to perhaps compose a speech of one to two
minutes. Since I did not feel like this would be satisfactory for a seminar of this
nature, I decided to take a different approach. Generally, the approach used in
addressing local government financing problems is similar regardless of the type
of problem being confronted; and, of course, being a proponent of management by
objectives, I believe in first stating and identifying the objectives to be accom-
plished. So, the objectives of my talk are basically (1) to develop criteria that
can be utilized in evaluating various proposals, both current and future, for
financing storm water improvements; and (2) following directly from one, to
develop some equitable and efficient approaches to financing storm water improve-
ments .
Many people have serious questions about the utilization of the management-
by-objectives approach, especially in a speech. I would like to relate back to an
illustration given by George Odiorne, one of the founders of the management-by-
objectives approach. He was working in the railroad transportation industry--
specifically with traffic controllers--and finding the going very difficult. He was
meeting with a particularly obstinate and difficult supervisor on the East Coast in
an effort to understand some of the problems of the industry and some of the
difficulties this person was having. During the course of the conversation, he got
around to talking about the various district supervisors--people in various areas
who were working for this person. The person related to him that he had one
particularly bad individual (for the record, we shall call him Joe) working in his
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mid-west region. He related that Joe just couldn't do anything right. He spent
his time doing things that probably were of no use, and never seemed to get
around to doing things the supervisor wished him to concentrate on. It seemed
that Joe made the wrong decisions in almost all instances, and the supervisor
just couldn't decide what to do with him. Odiorne said, "Sometimes that is a
common perception of Management. Let's do a check on it. Write down exactly
what you would like for Joe to accomplish within the next six months; and when
we get together again, we can determine if what you have been relating to me is
true." They proceeded to write the objectives that this supervisor had for Joe
over the next six months.
Several weeks later Odiorne was visiting the mid-west office and ran into
Joe. In the middle of the conversation Odiorne stated that he had seen Joe's
boss in New York; and Joe related to him,"I'm really in trouble. I just can't do
anything that pleases my boss. I'm just about to get fired. It's really terrible.
I don't know. Maybe we just thiik on different wave lengths. I just can't get
through to him."
Odiorne turned to him and said, "Well, you know, it just happens that
this subject came up when I was talking to him, and we wrote down your objec-
tives for the next six months--what your boss expects you to do and to
accomplish."
Joe looked at him and his face lit up: "You know, I'd do anything to get
my hands on that. It would probably save my job for me." "George," he says,
"let me give you $100 for that, please."
Odiorne said, "No, wait a second! Hold it! You can't bribe me. But
I'll tell you what: It's on top of the things in my briefcase. You give me a dime
and I'll go get a cup of coffee. While I'm gone, you take it out and copy it;
and I won't know anything about it."
Six months later Odiorne was back in the East Coast office talking to
Joe's boss and relating what had lappened in various areas when the subject of
Joe came up. Odiorne said, "Let's look at his objectives and see how well
he has done against those you said he should be doing and see how bad he
really is."
The boss said,"It is just amazing to me. Joe has turned around completely.
He is my best controller now. You know, everything I seemed to want him to do,
he is doing. He is ignoring those things that I dqn't think are important. He is
really concentrating his efforts in the proper directions and getting a tremendous
amount accomplished."
Odiorne cleared his throat and looked at the guy and said, "You know, I
hate to tell you this; but, I happeaed to be out there with Joe a few weeks after
you and I met, and I gave him a copy of your set of objectives for him."
LII-108
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The boss sat back with a stern look on his face and really got almost
angry about it. He said, "I knew it. That SOB cheated! "
Odiorne told him, "I think people deserve to know where they are
expected to go. Of course, it does put us on the spot and makes us toe the
line and really strive to accomplish something. I hope today we will be able
to do so."
Generally, in an overall approach to the topic, I want to briefly review
some of the traditional methods of financing storm water improvements, discuss
some of the strengths and weaknesses of these methods, and then work with
you, the audience, in developing criteria to measure the equity, efficiency and
effectiveness of various financing methods. After that is done, we will apply
these criteria to traditional methods, determine how well they rate, and try to
derive, from the criteria, some innovative methods that would provide us with
sources of revenue to fund these proposals.
In reviewing the traditional methods of financing storm water improvements,
there are: the use of current ad valorem taxes and other sources of general
revenues; the use of GO bond issues — either small annual issues or large periodic
issues; the use of special assessments based on front footage, square footage of
property, etc.; the use of private funds, mainly from developers, to fund storm
water improvements and new developments; the use of revenue sharing; the use of
water and sewer revenue bonds and renewal and extension funds; and the use of
community development act funds or other state and federal sources. How
effective have these methods been and how equitable are they in their use at the
present time?
(1) Current Ad Valorem Property Taxes
This is a good source of revenue; and large amounts of money can be
raised from it or, at least, could have been in the past. However, there is
presently a lot of pressure because of other increases, especially in educational
costs and costs of other services, to hold the line on taxes. Also, I have
questions myself with regard to the equity of funding storm water improvements
from ad valorem taxes without any other consideration being used.
(2) General Obligation Bond Issues
This, of course, tends to delay the cost of the project and allows you to
spend monies today before inflation increases these costs. You must pay it
back over a period of years; and the current interest rate on GO bonds is now up
over 6% in most municipalities and, in some areas, approaching 8%. This means
the interest rate is probably approaching your inflation rate. If so, one of the
main purposes of utilizing this source would be defeated in and of itself. Also,
it is extremely difficult at the present time to obtain voter approval for GO bonds;
and there is much competition for capital improvement money provided by small
annual issues that voters may have already approved.
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(3) Special Assessments
These are probably more equitable than most other methods because, in
this case, you are assigning the cost back to the person owning the property.
However, they are basically only suitable for a small portion of the total cost
of the storm water improvement system and, in many instances, are only charged
back to abutting property owners and not those who may be reaping benefits from
the system but are not directly in line with it or on it. Also, the source of
revenue is not great enough to find the massive improvements needed in fully
developed areas, especially where old, combined systems are causing problems,
such as the overloading of sanitary sewer plants and the bypassing of plants in
heavy rainfall times.
(4) Private Funds - Mainly from Developers
Here again, equity is very high. However, they are effective only when
you are in the beginning stages of development of an area. It is sometimes
impossible, or at least impractical, to go back and see developers after construc-
tion has been completed. This also probably results in passing on the cost to
the buyer of the property, thereby increasing that property cost and, depending
upon how the developer passes this on, could have an effect upon location
decisions of businesses and individuals.
(5) Revenue Sharing and Community Development Act Funds
Tne use of revenue sharing and community development act funds are
hard to evaluate from an equity standpoint. Because of the fungibility of these
funds, they could be considered almost like any other general fund sources of
revenues. Also, the competition for such funds is very high and the priority
decisions would have to be reviewed. It is doubtful that funds from these
sources are sufficient to make a positive impact upon storm water improvements,
even though they could probably help in many areas.
(6) Use of...Water and Sewer Revenue Bonds and Renewal and Extension Funds
Here, the cost is being borne by the user of the system. This means
that the person would pay for storm water improvements based upon his water
usage, which is questionable to me with regard to equity. However, in cases
where there are combined water and sewer systems, this can be utilized some-
what more effectively.
Now that we have discussed the traditional methods of financing storm
water improvements and briefly critiqued their strengths and weaknesses, let's
see in what direction we can loo< for developing a framework in which you can
work in the future to establish an equitable, efficient and effective means of
financing these projects.
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In this discussion I cannot take credit for all the ideas that have come
forth since this part of the speech was done on a feedback basis with complete
audience participation in the development of criteria to measure the efficiency,
equity, and effectiveness of various funding methods. However, I believe that
I can adequately summarize what took place. When looking for criteria, what
we are endeavoring to find are quantitative and objective measures that can be
applied to past or potential funding methods. The purpose of these criteria
would be to give the evaluator some legitimate, logical method of assessing the
funding method and its applicability to the given situation. Based on our feed-
back and brainstorming session, the criteria can be broken down into three basic
areas.
(1) First would be the effect of this program's expenditures upon other
programs: i.e., what priorities do stormwater management projects have vis-a-
vis other programs, and what effect would the individual funding method have
upon the ability of the programs?
(2) Second, under the general heading of equity, we had to look at the
beneficiaries of the program. This could be further subdivided into two areas--
direct and indirect beneficiaries. Direct beneficiaries include abutting property
owners, down stream property owners,motorists, construction trades and
developers. Indirect beneficiaries are politicians, environmentalists, future
generations, property owners throughout the region and down river communities.
Also, under the general topic of equity would be those things that are causing
the problems. In this area you would have motorists using streets and parking
areas; development--especially high density and along flood plains; lack of
control upstream; poor planning; rainfall; other natural factors such as type of
geography; soil density and ground cover.
(3) The third major area is efficiency. Under efficiency would be the
ability to pay, cost of collecting, effect of the financing on other programs,
the legality of the method of financing, the political feasibility, deferred versus
present cost, and the source of revenue—also, what regulations must be
complied with and whether or not the quantity of funds available Will satisfy the
needs.
In evaluating our traditional methods of financing storm water projects
by the criteria we have developed, it appears that each has varying degrees of
equity, efficiency and effectiveness; but none has qualities sufficient for us
to state that this is the best method for financing all storm water projects.
If traditional methods do not give an absolute answer, should we look
to those who contribute to the problem or benefit from its solution to assume
a reasonable portion of the cost of storm water projects? In my opinion--yes .
What are some options that might be pursued as supplements to traditional
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methods or wholly on their own merits based on our earlier criteria? Property
owners within an affected area, not just the abutting property owners, could
be assessed on some land measure (square footage, etc.) times a runoff
coefficient. The runoff coefficient is the percentage of the storm water that
will need to have drainage provided for it and is influenced by the type of
ground cover and the slope of "iie land. Another way to assess property owners
within an area is to use a tax ~evy based on land value or total property value
times the runoff coefficient. Problems or lack of problems with storm water
drainage affect land value. Part of the auto license tag fee could be placed in
a pool to be used for drainage projects. Federal highway development monies
might be tapped for some local projects. Developers could install drainage
systems at their own expense or provide these funds through a building permit
fee based on the type of development. Combinations of various funding methods
will probably be more equitable and efficient and can also be used jointly with
traditional methods, when applicable.
In conclusion, we are still unable to say that there is one method that
should be used for financing storm water projects. It appears that each
proposed project has its own set of causes and beneficiaries, and using the
same financing method for all projects would result in gross inequities. Each
project has to be examined by itself, and its financing arrangements evaluated
in a manner that will provide equity, efficiency, and effectiveness.
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FINANCING STORMJATER PROJECTS
by W. Joseph Shoemaker
Shoemaker and Wham, Attorneys
Denver, Colorado
Financing stormwater projects is a part of identifying the problem and
knowing, legally, that you or someone else has the authority to do something
about it, and determining who is going to benefit. From the knowledge concern-
ing the beneficiaries, you can take a position on who should pay.
I think that the best analogy on drainage is that it is a "utility".
It is like having clean water come to your faucet. It is like flushing your
toilet and knowing that somebody is going to take care of it. It is like know-
ing that your trash will be hauled away from your residence. Those services
are, traditionally, provided on a fee basis. Airports are provided on a fee
basis. Local government history of financing public works has been through
special assessment districts. If you build a street or sidewalk, the owner
of property that fronts on that street or sidewalk pays his share of the total
cost. A sanitary sewer is financed about the same way. However, the frontage
assessment method has never worked with drainage improvements.
I believe that we must work on a drainage basin concept. The amount
of water that goes downhill, in excess of that which would naturally exist,
can be computed. The local taxing authorities have records of each piece of
real property, with descriptions of improvements thereon. Therefore, it is
possible to determine the amounts of both pervious and impervious areas. This
makes it possible to determine who is causing the problem in a specified
drainage basin. Also, the amount and rate of stormwater runoff from each
piece of property can be computed. This is fairly standard in engineering
technology, but translating that technology into "financing" is the problem.
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The average citizen doesn't have the slightest conception of what
"urban stormwater management" is. But they worry that it may cost them some
money. I have found that, from a purely drainage standpoint, if you can in-
corporate in a planned improvement a park, recreational facilities or health
facilities with the drainage improvements, the chances of getting someone to
pay are better. First it is necessary to get the legislative body of the local
government to pass an ordinance that says "an improvement will be built".
Then, it is necessary to determine who is going to pay for the improvement,
based upon how much extra runoff or increased flows each property owner is
sending downhill.
I claim that a vacant lot should not be specially assessed because it
doesn't increase runoff flow rates above historic flow rates. If you deter-
mine the flow rates and amount of runoff that went downhill before development,
the general property tax fund would pay for handling this historic runoff
fraction.
In 1968, I wrote an article titled "An Engineering-Legal Solution To
Urban Drainage Problems". In 1974, I wrote an article titled "What Con-
(2)
stitutes Benefits for Urban Drainage Projects". The definition of benefits
for urban drainage projects is discussed in the latter reference. I searched
the Colorado State Statutes and found 32 different places where the statutes
refer to "benefits", but I did not find any definitions in the statutes of the
meaning of benefits. This is why the courts have always determined what con-
stitutes benefits. I reviewed all the court language I could find from all
jurisdictions in the United States, including references to health, public
works, street cleaning and others. Using this information, I developed a
definition of benefits and amended each of the 32 sections of the statutes
where references were made to "benefits".
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It i's necessary in a given case to prove that a benefit will result.
You must do your homework. For example, you must prove: alleged increases in
runoff volumes or flow rates; expenditures made by the local public works de-
partment over the years in cleaning the streets in the specific location in-
volved; or whether a health problem was, or will be, alievated by the improve-
ment.
The definition of "benefit" that I developed is as follows. The term
"benefit", for the purpose of assessing a particular property within a drain-
age assessment district (or special improvement district), may include any one
or more of the following:
a. Any increase in the market value of the property;
b. The provision for accepting the burden from specific property for
discharging surface water onto servient property in a manner or quantity
greater than would naturally flow because the dominant owner made some
of his property impermeable;
c.. Any adaptability of property to a superior or more profitable use;
d. Any alleviation of health and sanitation hazards accruing to partic-
ular property or of public property in the district if the provision
of health and sanitation is paid for wholly or partially out of funds
derived from taxation of property owners of the district;
e. Any reduction in the maintenance costs of particular property or
of public property in the district if the maintenance of the public
property is paid for wholly or partially out of funds derived from tax-
ation of property owners of the district;
f. Any increase in convenience or reduction in inconvenience accruing
to particular property owners, including the facilitation of access to
and travel over streets, roads and highways;
g. Recreational improvements accruing to particular property owners
as a direct result of the drainage improvement;
h. The dollar value or values of any one or more of the above ("a"
through "g") accruing to a specific parcel of property or the total
property of a taxing entity shall be determined as related to the cost
of the specific improvement.
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In terms of financing, I believe that it is necessary to be very
specific. This belief led me to develop a definition of benefit. Then, there
are many ways to finance projects. At the local level, stormwater projects
are basically a public works function. But, it is often possible to develop
multiple-purpose projects. For example, we hope to clean up the South Platte
River and to develop a linear park in conjunction with this. From a recrea-
tional standpoint, we have two 1-mile sections completed. Our criteria was
that the River must be boatable from beginning to end--for kayaks, canoes,
rafts and tubes, but not motorboats. Secondly, we required a hiker-biker
trail, full length, along one side of the River. This is being built of con-
crete, 5 inches thick, 8 feet wideband is designed to resist destruction from
floods, including the 100-year frequency flood event. The criteria also re-
quired that the linear park tie in with existing City facilities.
I included discussion of this improvement here for the purpose of illus-
trating how it is possible to sell a proposed financing arrangement by turning
somebody on, either the citizens, the politicians, or both. Although storm-
water management appears to be difficult to finance today, I believe that the
situation is favorably influenced and supported by recreational, ecologic, en-
vironmental and aesthetic goals and programs. These aids were probably never
considered in the old days in financing drainage improvements.
At the local level, in Denver, we have several methods available for
financing stormwater projects. We can use special assessments. I believe
that it will be easier to do this now because we have identified and studied
many of our drainage basins, and the definition of benefits has been made clear.
We can also use general obligation bond issues.
By planning stormwater management improvements to be aesthetically
pleasing and serve multiple-purpose uses, such as we are doing along the South
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Platte River In Denver, the local citizens will lend their support, and
financing is made easier. My solution to financing stormwater projects, for
both pollution control and flood control, is to build a citizens cadre of
"identifiers and complainers". This will come about as a result of the hiker-
biker trails that we are constructing along the natural waterways within the
floodplain. People using these trails will identify the polluters and the ob-
structors. They will help in identifying the locations of point pollution.
I promote the use of the River for recreation such as kayaking, canoeing, tubing
and rafting. This helps to create an awareness of River conditions, including
cleanliness, on the part of the River users and their families, friends and
acquaintances. I often take legislators down to the River for lunch so that
they will develop a first-hand awareness of the need to clean up the River.
Sooner or later, I will get a State appropriation of funds to help build more
trails. I will also get enough people at the State level who will monitor the
River, with the most technologically advanced equipment available, to pinpoint
the sources and extent of pollution. I do not believe that present river
monitoring techniques are good enough. I don't know of any place in the
United States where water quality is monLtored adequately. If I did, I would
try to have the same done in the Denver area.
Another problem is that the floodplains of the waterways in the Denver
area are not marked so that the laymen know where the floodplain is. The Drain-
age District plans to install a system of permanent markers along our major
waterways to identify the location of the 100-year floodplain. This may mean
painting a line on someone's building. The District is also developing maps
to be mailed to each property owner. These will inform each property owner
of the drainage basin in which his property lies, the location of his property,
and the boundaries of the 100-year floodplain. These will be recorded in the
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Recorder's Office in the various counties involved so that this information
will be available to prospective purchasers of property when a title search
is made. This is a controversial procedure, from a 'legal standpoint, because
such information could queer a sale of real property, or cloud the title. My
position is that local public officials have an obligation to do this. Sooner
or later, some citizen will sue a public official for not spreading this in-
formation on public records.
Most people, including myself, believe in and support the national
goals of clean water in our natural navigable waterways and unobstructed flow
of these waterways. But, it is necessary to develop workable financing plans
as well as engineering plans for achieving these goals. It is necessary to
prove that health and safety, as well as quality-of-life, are involved. When
you get your homework done properly and fully, there won't be any problem
getting money because there is much money available for stornwater management.
This applies at the local, state and federal levels.
The Platte ,River Development Committee, of which I am chairman, is
cleaning up the South Platte River in Denver. For financing, we have several
sources in addition to the City and County of Denver. These include the Bureau
of Outdoor Recreation, HUD's Community Development Program, the State Depart-
ment of Parks, the State Highway Commission and others. We may also have to
charge property owners, but this is the most politically controversial method.
of financing.
REFERENCES
1. Shoemaker, W. Joseph, "An Engineering-Legal Solution to Urban Drainage
Problems", Denver Law Journal, Vol. 45, 1968, pp 381-398
2. Shoemaker, W. Joseph, "What Constitutes Benefits for Urban Drainage
Projects",' Denver Law Journal, Vol. 51, No. 4, 1974, pp 551-565
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QUESTIONS AND ANSWERS
(Following W, J. Shoemaker's talk "Financing Stormwater Projects")
Question: Can you tell us about the water rights issue as it relates to
stormwater?
Answer: For Colorado, my position on water rights is that there 'is no accurate
way to "appropriate" surface runoff. In Colorado, you must identify how much
water is involved and you must prove that you can put it to some beneficial
use. Because stormwater is so erratic, in terms of when it comes, you can't
rely on it for a beneficial use. I have never had any problem with giving ad-
vice on drainage problems. My position is that you may do with drainage water
whatever you wish, so long as you don't damage someone's property, upstream
or downstream.
Question: You talked about the multiplicity of federal agencies, involving
coordination at the state level in Colorado. Please explain this.
Answer: That is in the statute. The coordinating agency is the Water Con-
servation Board, with respect to floodplain management. With respect to water
quality, the responsibility lies in the State Health Department. The Depart-
ment of Natural Resources has a big interest in both subject matters. The
ultimate answer to your question is tied in with the funds appropriations
made by the Legislature. In Colorado, the Legislature has funded the State
Department of Health adequately on water quality. We have funded the Water
Conservation Board adequately to make funds available to local governments
for identifying flood hazards. And, we have funded the Department of Natural
Resources adequately, so that its parks unit and fish-and-game unit can get
into the act.
Question: (Erik Edeen): Given the Colorado water rights laws, could water
quality management practices conflict head-on with good water resource manage-
ment practices, particularly with regard to irrigation in rural areas? Do
you envision a rewriting, or change, in Colorado water rights laws?
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Answer: Yes. This is very controversial when you put it in that context.
I wouldn't put it in terms of the Legislature changing water law. I would
put it in the context of the State Department of Health and Water Quality re-
quiring something, or the Department of Natural Resources, from a recreational
standpoint, requiring something. We succeeded in passing a statute that said
something like--"our navigable streams must have a certain average annual flow
for recreational purposes". This is a very controversial subject, because of
water appropriators downstream. When they make a demand on the river for water,
they are entitled, under Colorado water law, to get it in accordance with their
water rights. I am working this out on the Platte River in connection with
Chatfield Dam and Mt. Carbon Dam so that the State Engineer will send the water
down the River to the irrigators on Fridays, Saturdays and Sundays — instead
of Mondays, Tuesdays and Wednesdays. This will give our kayakers and canoers
100 cfs in the River on days when they most want to use the River. I think,
administratively, there is a solution to that problem.
Question: In Colorado, does a city that generates additional runoff, due to
land development, have any rights to that water?
Answer: I do not think so, for the same reason that I don't believe that any-
one who wants to appropriate runoff waters has been very successful. I have
discussed this subject with the Denver Water Board and, at one time, they
thought that they would try to file on Harvard Gulch which has 4 to 5 cfs
coming from the shopping center upstream and irrigation of lawns. But, the
Board decided that they could not appropriate that water because that surface
water has historically been in the stream and the Board had no more right to
it than did someone else. I think it would be difficult to have such a claim
stand.
Question: (Michael Seaman, Snomish County, Washington): You said that the
courts recognized natural flow. There are very few pristine streams. What
is the definition of natural flow?
-------
Answer: I think that depends on historical records. Natural flow depends on
rainfall in some locations along a stream. In other places, it depends on snow-
melt and rainfall. It may also depend upon what man-made things may have been
constructed, such as a dam or a detention reservoir. These must all be taken
into consideration in determining what the natural flow of a stream is.
Question: (Roland Gow): The State of Colorado has the ultimate authority for
monitoring the quality of waters in the state. That authority could possibly
be delegated to local health departments. Would you be willing to support
increased State funding for delegation of that authority, with pass-through
funds to the local governments for monitoring purposes?
Answer: Probably, The City and County of Denver thinks it has the ultimate
authority because it is a home rule city. But, in either unincorporated areas
or statutory cities, I think that the State has ultimate control. Because it
should be the goal of the State and Congress to have clean water, the State
should fund monitoring. The State has funded monitoring of seven personnel
positions so as to organize a system for the very thing you are talking about.
The State funds local health departments, but does not specify how the funds
will be expended. The amount of State funds allocated to local health agencies
is $ 1.10/year/capita. The local governments determine how they will use the
money. But, I think we could write into the statute that a certain amount of
this has to be used for monitoring.
Question (Robert Braun, Idaho Dep't. of Health & Welfare): Please cite the
reference on your article "What Constitutes Benefits for Urban Drainage Projects"?
Answer: Denver Law Journal, Vol. 51, No. 4, 1974, pp 551-565. Incidentally,
the State of Colorado, in the last session of the Legislature, passed a statute
which reads exactly as the conclusion of that article—minus the words "aesthetic"
and "ecological", in paragraph g.
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PLANNING TO NARROW THE IMPLEMENTATION GAP
Presented by Penelope Wilson
Special Assistant to the Executive Director
for Richard Page
Executive Director*
EPA URBAN STORMWATER MANAGEMENT SEMINAR
Denver, Colorado
December 4, 1975
Dick Page asked me to express his regrets. However, he had made
several commitments that made his schedule this week somewhat
inflexible and simply could not manage to accommodate a morning
session rather than an afternoon session.
Mr. Waldo and Senator Shoemaker did an excellent job establishing
the premise for my comments. Any discussion of intergovernmental
relationships and the legal and financial aspects of developing
management schemes for urban stormwater is usually most discouraging.
The complicated relationships involved and—in many instances—the
lack of specific financial or institutional tools make the gap
between planning and implementation seem unbridgeable at first
glance. Senator Shoemaker gave us some good advice for bridging
that gap. Perhaps you will find a discussion of the techniques
we are using in Seattle helpful as well.
In Seattle we are relying heavily on our 208 planning process to
develop the institutional arid financial mechanisms we need to deal
with urban stormwater problems which—not surprisingly—constitute
the Puget Sound area's most serious water quality problem. My
boss, Dick Page, often remarks that whenever he comes away from
an intergovernmental discussion of these issues, he finds himself
feeling very grateful for his graduate training in foreign affairs.
When he was in graduate school, he thought he would be applying
the principles involved in case studies of the international
diplomatic triangle to the foreign service. The diplomatic triangle
is simply a conceptual label for the practice we are familiar with
among Russia, China, and the United States. Two of the three
parties are forever joining forces to undermine the third. Alliances
shift from issue to issue and from day to day, however, so no one
is ever quite certain who is odd-man out. We have experienced—
and still are experiencing—a good deal of that in Seattle as the
regional planning agency, the counties, the cities, and Metro
maneuver for position and a slice of the 208 planning pie.
While no one wants to actually operate the stormwater utility,
everyone seems to see 208 planning for non-point source pollution
control as a convenient vehicle for exercising some real political
leverage. 208 has come to represent the planner's "last best hope"
for controlling land use and, as such, it could be the most powerful
planning tool still remaining to local officials. That means it
is a highly sensitive issue—presenting lots of opportunities for
* Municipality of Metropolitan Seattle; Seattle, Washington
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IMPLEMENTATION GAP
forging good inter-agency working relationships and, more impor-
tantly, for producing results—and, on the other hand, laden with
the potential for some very damaging confrontations which could
polarize relationships and delay projects for several years. That
is why it is essential that a lot of thorough analysis about
existing and potential institutional and financial arrangements
accompany the groundwork for developing stormwater management
strategies. In other words, it takes political savvy as well as
engineering and technical expertise to put together a management
plan that can be implemented.
In Seattle I think we got a big jump on narrowing that implementation
gap by winning 208 designation for Metro which is the area-wide
water pollution control agency—rather than have it assigned to
the regional planning council. Our local officials took the position
that water quality planning should be done as close to implementation
as they dared and, therefore, they petitioned the Governor to have
the 208 assignment go to Metro rather than the Council of Governments.
Speaking as I do from a vested perspective, I feel compelled to
point out that Metro had some impressive credentials to back up its
petition for 208 designation. Metro was management agency in a
basin planning effort for water and waste management which included
an urban stormwater plan funded by the Corps of Engineers. The
water quality management plan of that basin planning effort—which
was just completed last summer--involved an extensive and very
sophisticated data gathering program which included developing
computer models of the two river basins. So, we had already com-
pleted substantial portions of the data gathering and problem
identification efforts that other areas are now undertaking as
part of their 208 planning programs. The technical information and
experience gave us a head start in undertaking 208 planning.
We also had learned a great deal about intergovernmental planning
efforts during our river basin planning experience. That involved
an inter-agency advisory committee made up of about 15 bureaucrats
who met twice a month for four hours at a time--over a three-year
period--to guide the work of the consulting teams doing the river
basin plans. In addition, our Metro Council is a federation of
local governments with 36 officials--about 30 of them locally
elected--sitting on it. They formed a committee to provide policy
guidance during the river basin planning effort and that committee
met monthly during the three years. So, the river basin planning
effort had given us some political experience as well as some
technical information and expertise.
It was in that experience that we developed the conviction that
planning should be done as close to implementation as we dared.
This does not mean ignoring the comprehensive planning consider-
ations that are fundamental to the Council of Government approach
to planning. It does mean working out an understanding with the
COG as to what those considerations are--and how they can best be
addressed.
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IMPLEMENTATION GAP
We did this in preparation for our 208 designation through a
memorandum of understanding with the COG. In that memorandum we
identified comprehensive planning as the development of generalized
goals, objectives, and policies to guide the orderly growth of the
region. Functional planning was defined to mean all planning
related to the development of facilities, systems, and programs.
Functional plans had to be consistent with comprehensive plans and,
furthermore, functional plans had to rest on the same body of demo-
graphic data and projections developed in the comprehensive planning
process. With those assurances, the COG could be certain that plans
contravening regional policy would not be developed in the 208
process...that it would remain sensitive to regional policies
regarding growth, allocation of development for housing and industry,
transportation services,, etc.
Since these are the issues that are normally the source of friction
between facility planners and comprehensive planners, we believed
we had made a significant step toward reducing implementation
barriers by developing that agreement before we even began the
planning effort.
Perhaps the greatest barrier ro implementation of any plan—partic-
ularly one done in the consensus atmosphere of the regional planning
council—is the fact that no one with the power to implement it
will claim it as its own. It is like an illegitimate offspring in
that the potential parentage is impressive—but when it gets right
down to it no one will really admit to being the father. We exper-
ienced problems like this in the development of our river basin
plans for waste management—and we are doing everything we can to
avoid a repeat of that this time. We have called the technique we
are using collaborative planning, and the purpose is to develop
ownership of the plans with the local general purpose governments
who will be implementing them.
So far as anyone can predict right now, Metro will have a limited
role in implementing an urban stormwater management plan for the
area because the taxing, zoning, permitting, and other legislative
capabilities required to enact, such a plan rest with general purpose
governments. We must have a partnership role with them, however,
for two reasons: First, because the design of strictly storm
drainage systems must consider the water quality impacts on the
receiving waters, a responsibility of Metro in King County; second,
because of the nature of the combined sewer systems which were
built in Seattle and a couple of the other large suburban communities.
Metro's computer controlled sewerage system can store large quantities
of stormwater to mitigate or prevent overflows in the area's water-
ways—thus, any management plan must rely to some degree on this
very important tool.
However, most of the innovative techniques required to solve the
urban stormwater problem are of a financial or institutional
character and will require actions by local general purpose governments,
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IMPLEMENTATION GAP
Recognizing this we have developed a program which will permit the
City of Seattle to do a pilot management plan for the very critical
Lake Union basin and a creek that runs through the densely populated
north end. King County will do a pilot management plan for one of
its critical creeks. In each case, the plans will be done by local
staff under Metro's management with Metro's 208 planning funds.
Metro will develop area-wide strategies relying on the specifics
of these local basin plans to provide policy guidance to the overall
strategy development. In this way, the basin-specific implementation
plan will be the product of the implementing agencies. The inputs
from these plans to the area-wide strategies should assure owner-
ship of the master 208 plan on the part of the local planning
bureaucracies.
Lake Union is an urban lake characterized by extensive commercial
and residential development on its perimeter and polluted from
stormwater runoff which is made more serious because of the city's
old combined sewer system. We have been telling EPA for some years
now that combined sewer separation will do a great deal more to
improve the quality of water in the Seattle metropolitan area than
will imposition of a secondary treatment requirement on Metro's
large West Point plant which discharges into Puget Sound. We believe
the 208 planning process will permit us to demonstrate that pretty
effectively--but the timetable is such that we will be completing
the 208 plan in 1977--about the same time that the secondary treat-
ment requirement goes into effect. Metro's NPDES permit now gives
a waiver from that time requirement while efforts continue on
planning to meet the 1983 Best Practicable Treatment requirement.
That BPT planning effort under a 201 facilities planning grant is
continuing in parallel with our 208 planning program.
I am telling you all this only to point out that-one of the barriers
for implementation of an urban stormwater management plan—in
Seattle at least--could well be other provisions of 'Public Law
92-500 which require the assignment of high priorities to compliance
with treatment requirements—requirements which in our case, at
least, we believe to be unnecessary. -If the regulatory mandate
regarding secondary treatment remains in effect, sewer separation
would move so far down the priority scale that it is unlikely it
would ever be funded.
The fourth method I would like to suggest for narrowing the imple-
mentation gap is opening up the planning process. This is accom-
plished to some degree in the collaborative planning process that
I suggested earlier. But the method I am thinking of especially
in this fourth step is using the environmental impact assessment
process to really open up your planning efforts to a thorough and
critical analysis which would be both objective and subjective in
nature. We believe this is a very useful way of preventing the
myopia that can occur when operating agencies do their own facility
planning. We have structured.our organization in such a way that
the planning and environmental impact assessment process occur in
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different divisions, but report to the same department director.
This is important because it means that both are on the same
critical path in terms of goals and objectives—yet they have their
own staff resources to allow independent analysis and the kind of
critical, searching examination that all planning alternatives
should receive. If the environmental assessment process were out-
side of the same decision-making system as the ongoing planning
effort, delay or postponement of the project might appear to be a
viable option to those engaged in preparing the assessment. This
could lead to inter-agency bickering which is costly to the public
and which merely serves to increase mistrust of public institutions.
But when the impact assessment process is kept within the same /
decision-making system, the incorporation of other alternatives
or viewpoints in the planning effort is encouraged. And the
critical path—which is so essential if plans are to be implemented--
is maintained. We believe that this will assure the production of
implementable plans rather than wish books—and we think this is
the kind of mandate that we have from the public which has expressed
growing dissatisfaction and frustration with plans that are never
implemented. . •
The fifth strategy for narrowing the gap also involves opening up
the planning process—by designing into it the means by which
citizens can effectively participate in planning. That is a pretty
tall order--effective citizen participation—but it is one we are
committed to simply because we believe that it does assure an
implementable plan. We are designing our participating effort for
the 208 planning program to develop a citizen constituency for the
plans. And, in order to do that, we know we have to listen and
respond to what the people in the community want to do about storm-
water management.
We gained a healthy respect for the complexity of designing imple-
mentable stormwater management plans during our river basin planning
effort because the stormwater management study attracted more public
participating than did any of the other water and waste management
studies. We found that stormwater problems are the source of
considerable public frustration and cynicism. And we developed a
real empathy for the general purpose government people who must
attempt to implement manageme.it programs. It became obvious that
people in different areas of the community disagree completely about
the appropriateness of various management solutions. One entire
residential area of the county was more than content to put all the
runoff in a culvert and viewed the wetlands and streams other areas
are so anxious to preserve as nothing more than an expensive nuisance.
Yet, another area considers any impact on natural streams as the
grossest kind of violation.
It became obvious that neighborhood solutions were expected by the
community—and that those solutions had to be based upon equitable
financial plans. The concept of equity was hotly debated, and we
still are not sure quite what we heard because the people who attended
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IMPLEMENTATION GAP
the meetings on stormwater runoff were usu,ally those living at the
bottom of the hill where the most severe problems occurred. They
wanted to assess those who "caused" the problems the most with the
rate structure to be based on the amount of impervious surface, etc.
One of the suburban communities, Bellevue, was way ahead of the
rest of the county in trying to deal with the stormwater problem.
It had a very influential citizens committee which worked hard to
develop a utility approach to the drainage question. Community
meetings on the utility proposal were well attended, and there
appeared to be a concensus for the plan. After several public
hearings, the City Council approved the plan and--four months
later—hastened to abolish it after the first billing of the
utility provoked the circulation of recall petitions. Most observers
believe that Bellevue's case was not a fair test since there was a
snafu in the billing procedure and the first utility bill was for
four months rather than two months. Furthermore, Bellevue made a
mistake in billing customers long before there was any evidence of
stormwater improvements. But the lesson did point out some valuable
things to remember about narrowing that implementation gap. The
most obvious two are—don't rely completely on the citizens who
attend meetings to give you a reading of community sentiment. They
are usually atypical—particularly in their attitudes towards
improvement projects. The second is that in implementing new
service—always be sure tha.t the service precedes the bill and don't
allow your collection department to make a unilateral decision about
billing procedures.
To avoid total reliance on the elitist and participating citizen,
we have developed a mix of citizen participation techniques for
our 208 process which include random sample telephone and mail
surveys, attending meetings of existing organizations to take a
reading on their attitudes and desires, focus interviews of
representative groups, and the use of direct mail to encourage
neighborhood residents who may not be affiliated with an existing
organization to learn about the planning effort.
In addition, Metro has a water quality citizens advisory committee
which we staff and which will provide advice and counsel on the
policy issues in the planning effort. The committee is comprised
of a variety of age and income groups and represents a geographical
balance. It was appointed from lists of nominees submitted by
environmental and sportmen's organizations and from elected officials
on the Metro Council. Council members and citizens selected the
committee members, and it was one of the most hotly debated issues
before the Council—which indicates, I think, a growing recognition
on the part of elected officials that citizen participation is
important.
In addition to that committee, we will work with what we call
"constituent" citizen committees interested in one particular
water body. This is the ideal way to assure plan ownership. It
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IMPLEMENTATION GAP
simply means devising techniques to do what Senator Shoemaker
described--ways to survey the way citizens look at and take pride
in those streams, rivers, and lakes. It is very risky because
these constituent groups often have very definite ideas about what
they want to accomplish, and there is a likelihood of producing
plans that don't live up to their expectations. But we have found
that in some cases these groups of people already have organized.
It would be sheer folly to think that we could develop and implement
a plan that has not won their endorsement.
In some cases we hope to develop constituent groups of citizens by
encouraging them to participate in the planning effort with data-
gathering activities like "stream watching". That may sound a
little esoteric—but the people in our planning effort think it
has real possibilities. We; would provide interested citizens with
a basic data summary on their stream or small lake and ask them to
help us in our data collection by recording day-to-day changes in
volume, turbidity, color, temperature, wild-life habitat, and the
like. This may seem a little too fundamental to be of much help,
but our scientists tell us that the sampling methods we now use to
determine water quality are pretty crude and unsophisticated any-
way. And, if fishable and swimmable is to be the 1983 goal for
water quality, perhaps we need to think now about defining water
quality in terms that people can better understand.
At any rate, these stream watchers would begin to take the same
pride in observing differences in their neighborhood stream or
lake that bird watchers do in seeing a rare bird or discovering
a peculiar habit in their favorite old bird. This kind of activity
is expected to engender a kind of constituency for the well-being
of that water body and an interest in implementing plans for its
protection.
The real test of public participation is whether the plans so
developed are indeed implemented and that will largely depend on
the degree of commitment the public feels and transmits to its
elected representatives.
If the public finds the planning effort relevant and compelling,
you can bet the elected official will also. And the gap between
planning and implementation narrows considerably when that happens.
Now, let me quickly summarize my five general recommendations for
narrowing the implementation gap:
1. Do your planning as close to implementation as you dare because
this will assure consideration of the realities of implementation
which include cost-effectiveness, institutional arrangements, and
financial alternatives.
2. If you are an operating agency, be sure that you have worked
out a framework for planning with your regional planning agency or
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IMPLEMENTATION GAP
Council of Governments. If you are a COG, I suggest that you work
out such an arrangement with the implementing agency. This should
address subjects like development of goals, objectives, policies,
use of demographic data and projections regarding the timing and
location of growth and development.
3. Try using a collaborative approach to developing your plans
so that all those who will have a piece of the implementing action
also have a role in the planning action. This assures ownership
of the plan on the part of the bureaucrats who must implement it.
4. Keep the planning process open to critical analysis and evalu-
ation by thoroughly and religiously utilizing the environmental
impact assessment process set forth in NEPA. But try to keep that
evaluation process on the same timetable as the rest of your planning
effort. This will assure examination of alternatives and should
make the adoption of implementable plans more likely.
5. Design opportunities for the public to participate in the
planning effort. Be sure you use a mix of techniques so that you
get a reading on the sentiment of a variety of publics. Remember
that this takes staff time and money to do properly. Do not
hesitate to build a constituency for the plan in your community
and among your elected officials or it will likely end up in that
great never-never land of plans that will never be implemented.
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QUESTIONS AND ANSWERS
(Following Penelope Wilson's paper "Planning to Narrow the Implementation Gap")
Question: How big is Seattle Metro's 208 Planning Staff?
Wilson: Our 208 staff is separate from our Community Involvement Staff, and
from the Environmental Assessment Staff. Our 208 staff now numbers about five
persons. The Community Involvement Staff has an additional four persons work-
ing on the 208 planning. Metro has a community involvement staff for trans-
portation and for water quality. It works in the day-to-day operations as
well as in planning. The Environmental Assessment Staff numbers about six
persons working on 208 planning.
Comment: It sounds to me like you have about 20 persons to draw on, but not
necessarily 100 percent of the time.
Wilson: Yes. We can rely on them for various aspects.
Question (Herbert G. Poertner, Engr. & Research Consultant, Bolingbrook,
Illinois): I would like to know whether you, and also the representatives of
208 agencies who are here, feel that there are enough talented persons avail-
able to employ on present 208 agency staffs. Someone asked--"how big is
the staff"? The next question is—do you need more? And other questions
that follow are: Can you get qualified people? Are they available? Can you
afford to pay them what they demand? Have the country's educational institu-
tions developed qualified persons in past years? Is the staffing problem an
impediment to progress in closing, or narrowing, the implementation gap? Per-
haps you or others in present here may wish to respond to my questions.
Wilson: I believe that Seattle Metro has a unique situation in that the
Seattle area is a very desirable place to live. We do not have as much
trouble attracting talent as may possibly be experienced in other parts of
the country. However, we don't find the kind of experienced people we want
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and need for community development. That is something that we have all been
learning in the last six years. Much of the federal legislation has mandated
it. It is an art that has been developing in the last five or six years.
However, in most fields, we don't have much trouble in attracting people. Do
you agree with that Rod?
Comment (Rod Stroppe, Seattle Metro): Yes, I think that the question is a
very valid one. Because of Seattle Metro's local climate, implementation is
a very sensitive issue. The important consideration is not the quantity of
the 208 staff; it is the quality. I feel that every agency would like to have
someone like Senator Shoemaker, who spoke this morning, to build a constituency
and talk to people. In implementation, I think that the most important thing
is to use whatever resources are available to put-across the message to the
constituency and the bureaucrats so that the plans do not lay on the shelf.
Question: Is your question directed toward the implementation aspect or the
planning process?
Poertner: Both. This means that it is desirable to have staff people with
technical know-how and backgrounds in engineering and science. This would
help expedite completion of the plan so that it can be moved toward implemen-
tation simultaneously. I wonder if there are enough people available that
have scientific backgrounds, such as water scientists. And, are there enough
people available who can interpret the master plans being developed by 208
agencies so that the planning can be moved, concurrent with plan development,
toward implementation?
Comment (Rod Stroope): I think that there is enough technical talent avail-
able in local areas, or the services can be obtained from consulting firms.
But, it is critical, in preparing a plan and implementing it, to develop com-
munications to bridge the implementation gap.
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IMPLEMENTATION OF URBAN STORMJATER RUNOFF PLANS
by George C. Berteau
Chairman, Southeastern WLsconsin Regional Planning Commission
Waukesha, Wisconsin
It is as fundamentally unsound to extend the tenets of egalitarianism
to all problems occasioned by stormwater runoff, rural or urban, as it is to
extend them to personal capacities, and behavioral characteristics. Accord-
ingly, it is necessary here at the outset to make totally clear that these
remarks are addressed solely to the water quality problems created by urban
storm water runoff, the systems employed or conceived in alleviation of such
problems and the factors common to implementation of an adopted plan or system
designed to deal with such problem or problems.
It is recognized that previous speakers at this conference no doubt
have well defined certain terms and definitions that any areawlde water quality
planning and management program mounted within or independent of P.L. 92-500,
The Federal'Water Pollution Control Act, nonetheless, these few basic defin-
itions seem to be in order. Parenthetically, Section 101 (1) (f) of that act
provides:
"It is the national policy that to the maximum extent possible procedures
utilized for implementing this act shall encourage the drastic minimization
of paperwork and interagency decision procedures and the best use of available
manpower and funds so as to prevent needless duplication and unnecessary delays
at all levels of government."
Thereafter follows more than 86 pages, printed in small type, ranging all the
way from Citizens Suits to the Adminstrators Authority to Award Scholarships.
Now, as to the terms or definitions
CONVEYANCE FACILITIES - With respect to sanitary wastes, conveyance
facilities consist of gravity flow sewers, force mains, sewage pumping and
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lift stations, and related appurtenances used to collect and convey sewage to
sewage treatment facilities. With respect to storm water, conveyance facilities
consist of gravity flow sewers, pumping stations and defined drainage channels
and related appurtenances used to collect storm water runoff and convey it to
a point of discharge to a surface water body.
EFFLUENT LIMITATIONS - Any restriction established by any state or the
U.S. Environmental Protection Agency on the quantity, rates, and/or concen-
trations of chemical, physical, biological, and other constituents which are
or are proposed to be discharged from point sources of pollution directly or
indirectly into any surface and ground waters, including schedules of compli-
ance with discharge abatement orders. There are two general categories of
effluent limitations.
The first category consists of standard effluent limitations for in-
dustries and publicly owned and operated waste treatment facilities which are
intended to be applied uniformly on a nationwide basis. These uniform or
national effluent limitations are not related specifically to the waste assimu-
lative capacity of the receiving body of Water. The second category of efflu-
ent limitations are those additional restrictions set forth for a given waste
discharge when it is found after careful study that the body of water to which
the waste is to be discharged will not meet the applicable water quality
standards for that body of water if only uniform state'or national effluent
limitations are applied. Thus, the second category of effluent limitations
represents additional restrictions applied where necessary to waste discharges
on a case-by-case basis following waste water quality management planning
efforts.
NONPOINT SOURCES - The generalized or areawide discharge of waste water
into a body of water which cannot be ascribed to a discrete, specific source
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location. Thus, the term "non'Doint source" refers to the origin of any pol-
lutant not identifiable as a point source. Nonpoint sources most commonly
consist of urban and agricultural runoff which carry sediment and certain
chemicals which act as water pollutants. It is important to recognize in this
respect, that the distinction between point and nonpoint sources of pollution
cannot always be sharply defined. For example, urban runoff while in concept
a nonpoint source of pollution, when collected in piped storm sewerage systems
may be discharged to bodies of water at discrete sites, and thereby can be
regarded as a point source of pollution, as can separate and separate and com-
bined sewer overflow outfalls. Such urban runoff, however, when carried in
roadside ditches and numerous interrelated swales and water courses, may have
to be regarded as nonpoint source.
WATER POLLUTION - A condition in which the quality of water in a lake
or stream is adversely affected by waste discharges from human activities or
sources so that one or more ben2ficial uses of the lake or stream is impaired
or eliminated. It is recognized that water quality may, as a result of natural
causes, not meet the quality standards attendant to specified water use ob-
jectives .
WATER QUALITY - The physical, chemical, radiological, and biological
conditions of the water determined through the analysis of data and the assess-
ment of the quality and diversity of existing aquatic life. To a large extent
the quality of water determines its potential use for propagation of fish and
other wildlife, recreation, navigation, and as a source of industrial and
domestic water supply.
URBAN AREA - Lands used for residential and industrial purposes, thus,
we do not address the matters of herbicides, insecticides and plant nutrients
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in runoff and eroded soil materials from agricultural and silvicultural lands
or biochemical oxygen demand, nutrients and pathogenic organisms from intensive
animal feed lots and manure storage areas.
WASTE TREATMENT PLANNING AGENCY - An organization designated by the
Governor and approved by the U.S. Environmental Protection Agency to conduct
a section 208 Water Quality Planning and Management Program. With respect to
our region—the 2686 square miles of seven southeastern Wisconsin counties--
the Governor has designated The Southeastern Wisconsin Regional Planning Com-
mission.
Within the framework of the characteristics of the urban storm water
problem, you have heard addressed:
1. Urban development and land use as affecting water quality;
2. The impact of combined sewer overflows and storm sewer discharges
on water quality;
3. Collector system control;
4. The combined sewer approach;
5. Land use, management controls and practices;
6. Swirl concentrators;
7. Detention flow attenuation as methods, techniques or systems de-
signed to alleviate the water quality problem occasioned by urban
storm water.
We could only observe here without going into detail—as that is aside
from the basic purpose of this paper — that the problem as defined has been,
and is now being, intensified by the ongoing decentralization—the flight from
the central city, urban sprawl contained or unrestrained. The old and ongoing
method of "improved" channelization of streams to accommodate the larger and
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faster runoffs—the Underwood Creek in Metropolitan Milwaukee area (Brookfield
Suburb) has been widened and deepened four times the normal channel size—due
entirely to "urban type" development and concomitant increased runoff. This
technique only more quickly passes the contaminants--oil, gas, rubber, asbestos,
metal particles, sands and de-icing salts into the receiving stream and/or
larger body of water, wholly untreated, and while producing results satisfactory
to developments and the pocketbook of the developer, it totally ignores the
adverse effect upon water quality. It is submitted that we now need a shift
in emphasis from "discharge" to "absorption" through the infiltration process
with such accompanying building codes or zoning changes as are necessary to
give meaning to such shift in emphasis—building design, roof storage and con-
touring must be addressed as well as sediment control for construction sites.
If there is to be effective planning to narrow the implementation gap
—that is the span of time between completed plans and partial or total plan
implementation, there must be total recognition of the fact that plan imple-
mentation measures must riot only grow out of formally adopted plans, but must
also be based upon a full understanding of the findings and recommendations
contained in those plans. Thus, action policies and programs must not only
be preceded by formal plan adoption, and following such adoption, must not
only be consistent with other adopted plan elements, but should also emphasize
implementation of the most important and essential elements of both land use
and watershed or basin plans as well as those areas of action which will have
the greatest impact on guiding and shaping development in accordance with
those plan elements. A single water quality approach—such as usually is
pursued by the U.S. Corps of Engineers—"flood control and flood damage abate-
ment", is not recommended in planning to narrow the implementation gap. The
water quality problem occasioned by urban storm water runoff is but a single
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part of achieving basic watershed development objectives and can only be
effectively dealt with within the concept of a total watershed or basin plan
that addresses at least:
NATURAL RESOURCE PROTECTION - Concern for future residential and urban
development so that such development approximates the density and spatial
distribution patterns recommended in the land use element, including our con-
sideration of the assimilative capacity as well as load-bearing characteristics
of the soil; retention of undeveloped primary environmental corridor lands—
probably to be publicly acquired for conservancy, outdoor recreation and re-
lated open space purposes;
FLOOD CONTROL - Retention of undeveloped floodways and flood plains in
substantially open use—using either floodland zoning, or better, if you can
achieve it—public acquisition of these floodlands. Elimination of those
areas as existing natural valley storage through encroachment, dumping, fill-
ing and structure placement—subservient to the cliche "We need the tax base"
in the floodways and flood plains will inevitably destroy the naturally
regulated flood-flow characteristics of the stream system, and will result in
increased flooding, flood damage and the further impairment of water quality
occasioned by increased runoff accompanied by a simultaneous reduction in
the natural storage area;
WATER POLLUTION ABATEMENT,- With respect to stream water pollution
abatement and water quality control:
Overflows from both combined sewers and separate sanitary and storm
sewers must be controlled;
specified levels of secondary, tertiary and advanced waste treatment
should be provided and obtained in the municipal sewage treatment
plants servicing the watershed;
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agricultural runoff should be reduced through the institution of good
soil and water conservation measures; and
Urban storm water runoff handled in any one or a combination of one or
more of the techniques heirein before referenced.
The aforementioned precepts that must be observed if the implementation
gap is to be narrowed were hammered out on our anvil of experience that includes:
The preparation and adoption of a comprehensive plan for the Root River
(Suburban Milwaukee, Racine Courty and Racine City) watershed—the first major
comprehensive watershed plan in our state that recognized that drainage, water
quality, and flood control was an areawide problem, intensified by ongoing
urbanization, which required recognition of the fact that watersheds be recog-
nized and considered as a planning unit;
The preparation and adoption of a comprehensive plan for the Fox
(Waukesha, Burlington Urban Areas, 946 square miles) River watershed;
The preparation and adoption of a comprehensive plan for the Milwaukee
River-a surface water drainage unit, 693.8 square miles in areal extent, dis-
charging to Lake Michigan, with the City of Milwaukee, lying in 9 Wisconsin
counties — two of such counties being outside the seven Southeastern Wisconsin
County Planning Region;
A comprehensive plan for Che Menomonee River Watershed-nearing com-
pletion;
A regional sanitary sewer system plan; and
A preliminary engineering study for the abatement of pollution from
combined sewer overflow in the Milwaukee metropolitan area.
Active participation in the development of the Kenosha, Wisconsin bio-
logical adsorption system for the treatment of combined storm water and sani-
tary sewage-initiated to determine the engineering feasibility of integrating
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a high rate biological adsorption process with a conventional secondary acti-
vated sludge process to treat combined storm water and sanitary sewage during
heavy rainfall periods. These rainfall periods would cause overflows of com-
bined sewers and result in the pollution of the beaches and degradation of
Lake Michigan. This project consisted of the idea development, design, con-
struction, operation and evaluation of a 20 million gallon per day treatment
facilities at the site of the Kenosha Water Pollution Control Plant.
Active participation in the concept, design and development of "screening/
dissolved air flotation treatment" as an alternative to the separation of com-
bined sewers in Racine, Wisconsin-this as a direct result of the Commission's
technical work in connection with its comprehensive plan for the Root River-
which from its confluence with Lake Michigan in the City of Racine Harbor covers
3.7 miles upstream through an area which includes industrial, commercial,
residential and park land usage-some 900 acres containing a network of both
separate and combined sewers which have discharge and/or overflow outfalls to
the river; there being 53 outfalls-17 of which are separate storm sewer and
36 are combined sewer overflow points.
A study design for the areawide water quality planning and management
program for Southeastern Wisconsin-a region which contains 154 local units of
government, and encompasses all or parts of 12 major natural watersheds. One
of the major elements which that areawide study will address is the preparation
of an areawide nonpoint source pollution plan and recommendations for the im-
plementation of that plan. It will focus its attention on pollution attribut-
able to storm water drainage and will develop and publish an urban storm water
management guide. This guide will address all facets of the urban storm water
drainage problem in the region and will constitute a manual of engineering
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practice for the abatement of both water quality as well as water quantity
problems associated with such drainage. The guide will identify the legal,
fiscal, as well as physical, problems involved in urban storm water management:
it will review-as you have done these past two days-the state of the art of
storm water management; it will inventory regional storm water management
problems; propose storm water nanagement objectives, principles and standards;
select engineering design criteria and analytical procedures and illustrate
their application in one or more sub-areas of the region.
And now, in conclusion, to close the implementation gap
At the outset—there should be an agreed upon plan or system—an accom-
panying schedule of implementing required capital improvements--the plan
should be prepared by an agency having technical competence and areawide juris-
diction -as a part of an overall comprehensive watershed plan that addresses
storm water runoff as one facet of the comprehensive study, and such plan
should have evolved by and with the understanding, acceptance and endorsement
of the political, environmental and economic leaders and decision makers in
the political jurisdictions and area to be serviced; should be supported by
citizen input and understanding and hopefully within the constraints of ex-
isting institutional structures and legal constraints, for while progress is
difficult, change is both suspect and time consuming.
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URBAN STORMWATER MANAGEMENT INFORMATION FORM
SUMMARY OF RESPONSES
by Warren W. Cast
Research Consultant
St. Louis, Missouri
EDITOR'S NOTE; An information form was prepared by Herbert G.
Poertner and distributed by the EPA to each registrant at the
seminars in Atlanta and Denver. A summary was made of the re-
sponses submitted by 34 persons at the seminar in Atlanta. A
Copy of the information form is included following the high-
lights of the survey, as presented by Mr. Cast in Atlanta.
OBJECTIVE
The objective of the survey was to ellicit from each seminar parti-
cipant information concerning the priority needs for stormwater management
within the jurisdiction of his agency. Information was also requested con-
cerning the priority reasons for providing solutions and the institutional
problems delaying progress.
RESPONSES
The number of responses submitted was far short of our expectations.
We had hoped to receive completed forms from 100 to 150 individuals; however,
only 34 were returned. Of these, 22 were from representatives of regional
planning agencies, 10 were from representatives of state or local government,
and 2 were from representatives of private engineering firms.
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RESULTS
The questions and results, considering only the top priorities for
each question, were as follows:
Question 1. "The Priority Needs for Stormwater Management In Our Metropol-
itan Planning Area Are:"
1st Priority; Thirty (30) percent of the respondents listed
"control stormwater pollution from sources other than erosion
to make significant improvements in existing wet-weather
quality of streams, lakes, bays, etc."
2nd Priority; Twenty-four (24) percent listed "control storm-
water pollution from sources other than erosion to prevent
deterioration of wet-weather quality of streams, lakes, bays,
etc."
3rd Priority; Eighteen (18) percent listed "control soil e-
rosion to reduce the suspended solids loading in streams,
lakes, bays, etc."
Question 2. "The Priority Reasons For Providing Solutions For The
Above Needs Are":
1st Priority; Fifty-six (56) percent listed "to safeguard
human health and life."
2nd Priority; Twenty-one (21) percent listed "to maintain
and improve aesthetics of water bodies and land areas."
Question 3. "The Principal Institutional Problems Delaying Progress In
Stormwater Management Within Our Metropolitan Planning Area Are:"
1st Priority: Forty-one (41) percent answered "lack of area-
wide policy, criteria, laws and guidelines for development of
private and public stormwater management programs and facilities."
ni-142
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2nd Priority; Twenty-four (24) percent answered "lack of
needed Information and data base in our planning area (e.g.
hydrology, native biota, ecology, present wet-weather water
quality, etc.)"
3rd Priority; Eighteen (18) percent listed "unmet financial
needs."
COMMENTS
An interesting analysis of the responses showed that the priority
needs, etc., to each question were very similar for both the Regional Plan-
ning Agency representatives and the representatives of State and Local A-
gencies. The questionnaire's indicated that the top two priorities in each
of the three questions were the same for the Regional Planners and State and
Local Planners as to the needs for stormwater management, the reasons for
providing solutions and the problems delaying progress in stormwater manage-
ment .
We appreciate the effort by those who completed the questionnaires,
and we hope this information is of interest to all 208 agencies.
III-143
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URBAN STORMjATEH MANAGEMENT INFORMATION FORM
1. THE PRIORITY NEEDS FOR STORWATER MANAGEMENT IN OUR METROPOLITAN PLANNING AREA
ARE: (rate by inserting numerals--"!" for highest priority, etc.)
control "flooding" to reduce depth and areal extent of innundation in developed
areas and/or land areas otherwise suitable for development
control "soil erosion" to reduce silt accumulation in downstream drainage systems
or siltation of downstream land areas
control "soil erosion" to reduce the suspended solids loading in streams, lakes,
bays, etc-
control "stormwater pollution'1 from sources other than erosion to prevent deteriora-
tion of wet-weather quality of stiearns, lakes, bays, etc. below existing satis-
factory conditions
control "stormwater pollution" from sources other than erosion to make significant
improvements in existing wet-weather quality of streams, lakes, etc.
other (identify on back of sheet)
2. THE PRIORITY REASONS FOR PROVIDING SOLUTIONS FOR THE ABOVE NEEDS ARE: (rate by
inserting numerals)
to protect and enhance the market value of real property
to safeguard human health and life
to protect biota (flora and fauna)
to maintain and improve aesthetics of water bodies and land areas
to avoid possible fines and imprisonment associated with water-law violations
to assure that local governments and agencies qualify for funding under various
federal and state programs
other (identify on back of sheet)
3. .THE PRINCIPAL INSTITUTIONAL PROBLEMS DELAYING PROGRESS IN STORMWATER MANAGEMENT
WITHIN OUR METROPOLITAN PLANNING AREA ARE; (rate by inserting numeral's!
lack of needed information and data base in our planning area (e.g.,--hydrology,
native biota, ecology, present wet-weather water quality, etc.)
lack of areawide policy, criteria, laws and guidelines for development of private
and public stormwater management programs and facilities
unmet financing needs
legal problems that prevent or delay action
apathy on part of public offie Lais
lack of citizen action and support
inability to develop areawide approaches to stormwater management because of lack
of authority to form multi-jurisdictional districts, authorities, etc.
lack of cooperation between officials of the various local governments
lack of qualified staff personnel in local governments and public agencies
other (identify on back of sheet)
SUBMITTED BY: TITLE: PHONE:
(Area,No.)
AGENCY: EPA REGION NO.
MAILING ADDRESS:
T.II-1A4 . A ,
(Form A)
-------
GENERAL COMMENTS
Jerry G. Cleveland
Chief, Planning and Research
Tulsa City-County Health Department
Tulsa, Oklahoma
Most of you will be faced with the problem of trying to collect data
and characterize stormwater in your local area. You will go through a sampling
procedure on various watersheds. Doing it right is a big job. I recommend
that you locate various types of small watersheds in your area and try to char-
acterize those and apply some of the simplified models that are available.
In this way, you can get a first-order of magnitude look at the problem. Maps
of existing storm sewer systems are often not available. I found this to be
true in Tulsa and other smaller cities in the metropolitan area.
The work that I did for the Office of Water Resources Research was
done in the late 60's and early 70's, and the publications are out of print
now. One of these presented simple models. Land use variables were included
in the input data. I tried to verify these models by getting data from other
cities and plugging it in with what I found at Tulsa. I had a reasonable de-
*
gree of success in doing this in some areas; but, in other places, it didn't
work at all. One must be very cautious in the application of various models
obtained from various sources.
I have been trying to sell some kind of stormwater control activity
to the policy-makers of the City of Tulsa. I made many presentations and have
been very fortunate in having quite a bit of T-V coverage at various times,
in Tulsa. It has been a hard sale; but, it looks like we are finally getting
off the ground. We are trying to work this in conjunction with the more re-
cent regulations coming out of my office—the Federal Flood Insurance Program
III-145
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and others. We are trying to develop regulations to comply with all of these
federal programs, and the local governments are now starting to use stormwater
detention techniques which Herb Poertner discussed. They are also using sedi-
mentation control ordinances, landfilling ordinances and others. If you can
get to the people who work in these fields—the City Engineer, Corps of
Engineers, Soil Conservation Service, and others—you can jointly develop some
regulations. If you integrate your work into the plans that they develop for
stormwater control, you will make a lot of headways in controlling water pol-
lution. They are trying to reduce flooding; but, at the same time, a simple
change in design can accomplish a lot for pollution control. I am looking
forward to doing this in Tulsa. We have a separate system for stormwater
drainage. There are no combined sewers in Tulsa; however, we found many un-
usual results in sampling discharges from storm drains.
You should select the parameter that you need to control and see what
impact its control will have on water quality. In some cases, you may wish
to recommend to your state government, or the EPA, some changes in the water
quality standards. In Tulsa, our biggest problem at this time appears to
be solids. We hope that we have taken care of this with the sediment control
ordinances. The solids, primarily, originate from developing areas and rede-
velopment projects. At certain times of the year, we also have problems with
bacterial conditions on the Arkansas River which is classified for recreation.
If we go by the current standards, we will have to chlorinate all our storm
drainage. In a six-mile stretch of the Arkansas River below Keystone Dam ,
there are over 150 storm drains, not including creeks. So, the City of Tulsa
may have 300 or 400 permits to issue.
m-146
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QUESTIONS ANn ANSWERS
(Following the third day of the Seminar in Atlanta)
Question; Mr. Berteau, what are some of your experiences in efforts to get
implementation of your planning?
Berteau; First, we try to get citizen leaders, economic leaders and political
decision makers involved in committee work. No major planning work element
is undertaken until the Chairman of the Planning Commission obtains the ap-
proval of the involved counties. Subsequent to that, a prospectus is develr-
oped. Then, the committee goes to work with the staff and begins an inventory
process, the development of alternatives and the synthesis of an ultimate plan.
No implementation plan element is addressed without first having a strong im-
plementation plan chapter in the prospectus. This chapter spells out what is
expected of each local, State and Federal agency to bring about the implemen-
tation of the plan. A capital improvement schedule is also included in the
prospectus.
Question; Mr. Poertner, what do you think are the major problems that people
have concerning urban stormwater?
Poertner; Financing problems stand out above all others. In a few places,
this doesn't seem to be a problem. For example, in Englewood, Colorado a 37,
local sales tax is used to finance public improvements. One-third of this is
allocated for stormwater management. The funds can be used for capital im-
provements as well as maintenance and operation. To illustrate the difficulty
that is inherent in financing by formation of special assessment districts,
between 1952 and 1968 not one drainage improvement district had been formed
within the Denver Metropolitan Area. Other major problems are those that
result from intergovernmental relationships between various local units of
government in an urban, or suburban, area--particularly, in large metropoli-
tan areas. The need to solve stormwater problems on a watershed basis, or
III-147 ,
-------
regional basis, compounds the difficulty of providing solutions. For ex-
ample, the financing problems are compounded.
Cast; The lack of widespread citizen awareness of stortnwater problems and
their consequences is a major problem. Also, many areas have not developed
master plans for stortnwater management. In some instances, local jurisdict-
ions have had to forego funds that had been made available because of a lack
of satisfactory plans.
Question; How do stormwater problems rank in importance in urban areas a-
cross the country in comparison with other water-related problems?
Poertner; Very high in most places in the country. There are exceptions,
however. For example, in some semi-arid regions it is not considered a high
priority problem. This also depends upon whether or not encroachment into
the floodplains has been permitted to occur. In such cases, flooding may be
a serious problem. Some areas of the country feel that stormwater pollution
is not a significant problem.
Question; Mr. Dornbusch, what opportunities do you see for direct coordina-
tion between the 208 agencies and the local Soil Conservation Districts?
Dornbusch; I believe that Soil and Water Conservation Districtswill be in-
volved in the implementation phase and in some of the activities of 208
agencies. From a technical standpoint, I believe that we will be a part of
systems review.
Comment; In our technical and advisory committees, we have representatives
of many agencies including: the District Engineer of the Chicago District
Corps of Engineers, the Regional Administrator of Region V of the EPA, the
Soil Conservation Service, the State Department of Natural Resources, and
the Metropolitan Sewage Commissions. We have been successful in drawing
upon all the disciplines thai: are involved. This is the way to solve the
problems, because you can coalesce the efforts of all the agencies and per-
III-148
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sons involved.
Question (Goodwin, Illinois): What effort is being made at the Washington
level to try to develop coordination among the various federal agencies,
such as USOA, FHA, Economic Development Administration, and others, to as-
sure that their programs, particularly the loan and grant program for the
smaller communities, are going to be tied in to the 208 planning activity
at the proper time and as a part of the total implementation program?
Waldo; I think that some of the intergovernmental problems will have to
be solved at the local level. The interagency question that you posed is
one that I do not wish to get into. But, I would like to stress that, where-
as there may be uniform problems, there are not necessarily uniform solutions.
Question (Goodwin): Are you willing to admit that it is a problem and needs
to be looked at?
Waldo; Yes.
Jensen; We testified before the Church Committee (Senator Church) on the act
which establishes the Federal law for the U.S. Water Resources Council. Theo-
retically, the Council is supposed to provide leadership and coordination.
Most of the states have been critical of the Council, thus far, and have made
a variety of suggestions for its improvement. The Council itself, if proper-
ly constructed and operated, might be the best vehicle for coordination. The
States have also suggested collectively, that they should have a council. The
council should not be composed only of Federal agencies and should not be
headed by a Federal department head, they feel.
Question (Goodwin): Mr. Jensen, you indicated that the State Water Control
Board of Virginia expects local governments to solve their own problems.
What do you do when the local governments fail to take action and there is no
solution in sight?
Jensen; We are a regulatory agency. If communities don't want to find sol-
III-149
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utions, particularly for point-source problems, we have machinery to bring
about coordination. We accomplish this state wide with no big problems in
finding solutions. We get involved in court cases sometimes; however, we
think it is better for the engineers to try to find solutions.
Ill-ISO
-------
Appendix A
-------
-------
List of Seminar Participants
Atlanta, Georgia
NAME
Dennis Athayde
Kathleen Adgate
Carl Myers
Richard Field
Francis Condon
Andrew Waldo
Richard M. Cox
Charles A. Rnapp
Lawrence J. MacMillan
J. Douglas Smith
Stephen C. Smith
Jose M. Cintron
William Pressman
Warren Kurtz
Charles Riesse
Paul S. Babiarz
Kevin Bricke
Bob Messina
Eugene A. Mattis
Charles App
Dennis Carney
Dale Wismer
David Longmaid
H.S. Edwards, Jr.
Gary Burton
James Hipps
Lester Slocum
Edward Halley
Ron Bartchy
Dr. Richard C. Tortoriello
Andrew P. Pajak
Joseph David, Jr.
Lawrence C. Phipps
Paul E. Trammell
Ronald Flanary
Kenneth A. Bartal
Henry Fabian Fostel
Patrick E. Gallagher
Whitey Secore
Austin Librach
Roy Jeffrey
Joe Woodrick
Donald Van Sickle
Gordon Sparks
AFFILIATION
Wtr Ping Div., EPA/D.C.
ii it ii ti it
Storm Comb. Sewer Sect., EPA/NJ
ORD, EPA/D.C.
Wtr Ping Div., EPA/D.C.
Central Mass Reg. Ping. Com.
Metcalf & Eddy, Inc
EPA/Region I
Cambridge, Mass
Southeastern Reg. Ping. & Econ. Dev. Dist
Lebron, Santiorenco & Fuentes
Environ. Prot. Admin., NY City
Ping & Dev Board NY
EPA/Region II
mi ti it
EPA/Region III
II
II
II
WVA Dept of Natural Resc.
5th Ping Distric Comm., VA
Moore, Gradner, & Assoc., VA
Dept of Environ. Services, D.C.
ii ii ti it ii
Philadelphia Water Dept.
Dela. River Basin Comm., NJ
Green Int'l Inc.
ii ii ti
SW VA 208 Planning Agency, VA
Dept of Environ. Resources, PA
Regional Planning Council
Betz Environ. Engrs, Inc. PA
Metro Washington Council of Govts
Turner, Collie, Braden Consulting Engr.
-------
John Mickelson
William E. Toffey
Luis Ajamil
Ron Armstrong
Robert Barker
Michael Bell
Scott Berdine
Barry Chefer
Greg Croxton
Ken Davis
James Forbes
John Harvanek
Al Herndon
Ron Jernigan
Kenneth Jordon
Robert J. Juster
Lamar Larrimore
Alan Lumb
Robert Martin
Rick Martindale
Tim McCartha
Keith McCloud
Larry McCullough
Mike McAnelly
Jamal Nagamia
Nancy Parker
Bill Patton
Tom Pierce
Dwaine Raynor
David Reynolds
Frank Reynolds
Bob Rutter
Steve Sandier
Roland Santos
Stephen Sedgewick
Robert Sherman
John Shipp
Richard Stalker
C.C. Taylor
Joe Wanielista
Bill Whidden
Russell Wright
David Word
J.B. Jones
Richard J. Gregg
Michael Dunbar
D. Galloway
Dan Goodwin
Jim Greener
Mirza Meghji
Dela. Reg. Planning Commission
Post, Buckley, Schuh & Jernigan
Tampa Bay - St. Petersburg, FLA
Waccamaw - Georgetown, S.C.
ir if ti
EPA/Region IV
Polk County - FL
Columbia, S.C.
Leon County - Tallahassee, FL
Greenville, S.C.
EPA/Region IV
EPA/Region IV
Columbia, S.C.
Georgia - State
Birmingham, AL
Tuscaloosa, AL
Columbia, S.C.
Greenville, S.C.
Alabama - State
Alabama - State
Columbia, S.C.
Columbia, S.C.
Columbia, S.C.
Polk County - FL
Georgia - State
EPA/Region IV
Leon County - Tallahassee, FL
Pensacola, FL
Triangle J - Raleigh-Durham
Columbia, S.C.
Orlando - Winter Park, FL
EPA/REgion IV
Dade County - Miami, FL
Stanley Consultants
Georgia - State
Greenville, S.C.
Palm Beach County - FL
ii it ii ii
EPA/Reion IV
Brevard County - FL
EPA
Georgia - State
Columbia, S.C.
South & Central FL Flood Control Dist.
Michigan Area Council of Govts
SW Illinois Metro Reg. Ping Comm.
EPA/Illinois
EPA/Ohio
Ohio-KY-Ind. Council of Govts
-------
Kenneth Pew Cleveland Reg. Sewer District
James Ruff Wise. Dept of Natural Resources
Paul Russell SW ILL. Metro Reg. Ping Commission
Van Slyke W. Mich. Shoreline Reg. Planning Comm.
G.K. Small NE 111. Planning Commission
J. Smedile " "
P.J. Tyson W. Mich. Shoreline Reg. Planning Commission
-------
-------
List of Seminar Participants
Denver, Colorado
NAME
George Fink
A.S. Andrews
Cecil Ouellette
Gerald J. Gromko
John S. Griffith
George Leavesley
Emmett Haywood
Edwin H. Weber
Ben Urbonos
Gary Broetzman
Mike Miner
John Promise
Dennis Maroney
John E. Fisher
H. Eugene Nielsen
Kenneth H. Bousfield
Robert Owen
Kathleen Adgate
Dennis Athayde
John Kingscott
Keith Welch
C.H. Brewer
Michael D. Foreman
Charles W. Boyes
Ken Webb
Jon Scherschligt
Daniel Straub
John E. Gait
Donald G. Adams
George Hagevik
Stephen Sowby
H. Lee Wimmer
Erik Edeen
Duane Barter
Samuel J. Marcey
Ken Watson
Francis Condon
Wayne S. Olsen
Ross Egbert
Hugh Meindl
Al Weing
Jack Hibbert
Billy T. Black
TITLE
Metcalf & Eddy
Sr. Water Resc. Engr.
Environ. Prot. Spec.
Planning Engr.
Civil Engineer
Hydrologist
Director, Ping. Div.
Engineer
Water Resc. Engr.
208 Coordinator
Project Coordinator
Asst. Dir. of Water Resc.
Project Engr.
Civil Engineer
Consulting Engr.
Civil Engineer
Water Resc. Specialist
Environ. Planner
Sanitary Engr.
Sanitary Engr.
Water Qual. Spec.
Program Mgr.
Sanitary Engr.
Staff Biologist
Eng.
Eng.
Project Planner
Section Head
Director, Water Resc.
Asst Ping Director
Mountainland Assoc.
Eagle Co. Health Ofcr.
Deputy State Cons.
Wastewater Mgmt
Water Quality Spec.
Sanitary Engr.
Sanitary Engr.
208 Coordinator
Dire. Water Qual Prog.
208 Project Ofcr.
Water Resc. Engr.
Sanitary Engr.
AFFILIATION
Consulting Engr.
Engineering Consultants, Inc.
EPA/Oregon Oper. Ofc.
Wastewater Mgmt. Div., Denver
Merrick & Co-Engrs., Denver
U.S.G.S., Denver
U.S. Dept. H.U.D.
URS Company, Denver
Blatchley Assoc.
Colo. Dept. of Health
Weber River Ping. Co.
North Central Texas COG
Karcich & Weber
Lawson Associates
Nielsen, Maxwell & Wangsgard
lilt rr rr if
Colo. Water Cons. Board
EPA/Water Ping Div., D.C.
EPA/Water Ping Div., D.C.
EPA/D.C.
5 Co. AOG
SEUA06
Iowa CIRALG
N. Central Texas COG
C.D.H.
Colo. Dept. of Health
Rahenkamp, Sacks, Wells & Assoc.
Snohomish Cnty Ping Dept,
Everett, WA
Ark, Tex
ABAC, Berkeley, CA
Prov. UT
Eagle Co.
USDA - SCS
Denver
S.L.CO. 208 Study
OR&D, U.S. EPA
Corp of Engrs. - SF District
EPA/Region X
South East Texas
EPA/Region X
Denv. Reg. Co. of Govts.
EPA/Region VI
-------
Mick Flynn
George Clark
Herbert G. Poertner
Audrey E. Poertner
Bill Taggart
John Dumeyer
Richard Field
Roland Crow
Michael Seaman
Bryon M. Parker
Andrew Waldo
R. E. Thronson
William D. Evans
Joe M. Bryan
Tommy D. Royal
George D. Holmes
Pedrito A. Francois
Bob Sallach
Rod Stroope
Hugh G. Hannah
Everett Perrien
Douglas B. Cargo
Mike Kupko
Alan Coburn
Don A. Ostler
John Tarkong
Art Kenke
Nachsa Siren
Leonard Crowe
Milton Sharp
Ronald Schuyler
William Ruzzo
Richard D. Holland
William P. Fergus
Gordon McLean
Larry Fassett
Ronald K. Blatchley
Paul Ferraco
C.O. Bakken
James Williams
Thomas E. Neal
Peter L. Smith
Larry Sheridan
Ron Peterson
Lee Duvall
Jerry G. Cleveland
Robert L. Braun
R. W. Fritz
Donald Hay
Deborah Pile
Head, Permits & Enforc. Div.
Water Division
Engr. & Research Consu.
Research Assoc.
Associate
PE
Chief, S&CS Section
Asst. Director
Senior Planner
Admin. Flood Control
Environ. Prot. Spec.
Hydrologist
Areawide Ping Coord.
Environ. Scientist
Areawide Ping Coord.
Hydrologist
Environ. Engr.
Engineer
Mgr. Water Qual. Pin
Chief, Water Pol. Cont. Div.
Chief Planner
Asst: Prof.
Engineer
Environ. Erigr.
Engineer
Legal Counsel TEPB
Ping Mgr. Water Qual.
Exec. Officer T.TEPB
208 Coordinator
Consultant
Chief, Tech. Ser. Sect.
Senior Engr.
Planner
Director
Planner
Environ. Engr.
Wtr. Resc. Engr.
208 Coordinator
Specialist
Engineer
208 Project Coord.
Project Director
Sanitary Engr.
Planning Engr.
Engineer
Chief, Ping & Research
Environ. Engr. Spec.
Regional Engr.
Vice President
Planner
Guam Environ. Prot. Agency
EPA/Region IX
Self-employed
tt li
Wright Mclaughlin Engr.
Hydro Engineering, Pueblo
EPA
Snohomish Co. (WA)
Salt Lake Co.
EPA/Water Ping. Div., D.C.
EPA/Washington, D.C.
TWQB
Houston-Galveston Area Counc.
Texas Water Qual. Board
Corps of Engineers
V.I. Government
H.D.R.
Seattle, Metro
Ark. Dept of Pol. Cont. Ecol.
IHI HIT fill Illl
Univ. of Texas @ Dallas
NHPQ
URS Co. Seattle
Utah Bur. of Water Qual.
Trust Terr. Env. Prot. Bd.
AACOG, San Antonio, TX
Trust Terr. Env. Prot. Bd.
Washoe Coun. of Govts., NV
Sharp, Krater & Assoc. NV
Colo. Dept of Health
Hydro Triad, LTD - CO
Sante Fe, NM
EDATA, Ohio
EDATA, Ohio
South Eastern
Blatchley Assoc.
EPA/Region VIII
City & Cnty of Denver
Nevada Envir. Prot. Serv.
Mid-America Regional Coun.
Ozark Gateway RFC Missouri
EPA/Region VII
OK Dept Pollution Control
EPA/Region VII
Tulsa City Cnty Health Dept
Idaho Dept of Health & Wei.
AGOG
Hydro
MN Poll. Control Agency
-------
Tom Pitts Manager Toups Corporation
John Environ. Planner EPA/Region VIII
Max H. Dodson 208 P.O. EPA/Region VIII
John A. Lager VP Metcalf & Eddy
E.D. Driscoll Hydroscience
Sam Sanitary Engr. EPA/Region VI
Bill Honker Sanitary Engr. EPA/Region VI
Skip McKay Planning Assoc. of Bay Area
LaVere B. Merritt 208 Project Director
D.S. Pate Sen. Water Ping. Spec. CO Water Cons. Bd
Foe Foreman 208 Tech. Planner Pueblo Reg. Ping Com
Herb McCall Principal McCall
Ed Wesolowski 208 Proj. Dir. Lewis & Clark, ND
Dale Chief Control Tech Sec. EPA/Region VIII
Bob Shankland Sanitary Engineer EPA/Region VIII
Bob Mairley Biologist EPA/Region VIII
Ken Young Principal GKY 6. Assoc. VA
R.F. Goddard Planner Terma, Inc.
Daniel Law Water Resc. Engr. Denver Regional COG
-------
-------
Appendix B
-------
-------
URBAN STORMWATER MANAGEMENT SEMINAR
sponsored by
U. S. Environmental Protection Agency
Water Planning Division
Washington, D.C.
November 4,5 and 6, 1975
Sheraton - Biltmore
Atlanta, Georgia
-------
TUESDAY
NOVEMBER 4, 1975
CHARACTERIZATION OF THE URBAN STORMWATER PROBLEM
Moderator: Dennis Athayde, Water Planning Division, EPA
AM
8:15 Registration
9:00 Welcoming Remarks: John A. Little, Deputy Regional
Administrator, Region IV, EPA
9:10 Introduction to Program: James Meek, Water Planning
Division, EPA, Washington, D.C.
9:15 Best Management Practices (BMP): Dennis Athayde,
Water Planning Division, EPA, Washington, D.C.
9:35 Characterization of Urban Stormwater Problems:
Frank Condon, Office of Research and Development,
EPA, Washington, D.C.
10:05 Break
10:25 Urban Development and Land Use Affecting Water Quality:
Herbert Poertrier, Engineering $ Research Consultant
11:00 Instream Impacts of Urban Runoff: Eugene Driscoll,
Hydroscience
11:30 Impact of Combined Sewer Overflows/Storm Sewer
Discharges on Water Quality: John Lager,Metcalf §
Eddy, Inc.
PM
12:00 Lunch
1:15 Measuring Runoff and Sampling Techniques: Eugene Driscoll,
Hydroscience
2:30 Modelling: John Lager, Metcalf § Eddy, Inc.
3:30 Break
3:50 Q/A Period (Tuesday Speakers)
4 ',30 Adjournment
-------
WEDNESDAY
NOVEMBER 4, 1975
APPROACHES TO URBAN STORMWATER PROBLEMS
Moderators: Richard Field and Kathleen Adgate, EPA
AM
9:00 Stormwater Film
9:35 Collection System Control:' John Lager, Metcalf § Eddy, Inc.
10:05 Break
10:25 Combined Sewer Approach: William Pisano, Energy §
Environmental Analysis, Inc.
11:25 Housekeeping Techniques .and Construction Practices-
Land Management. Central's for Developed arid Developing
Areas: Kathleen Adgate, Water Planning Div., EPA
PM
12:00 Lunch
1:15 Detention/Flow Attenuation: Herbert Poertner,
Engineering and Research Consultant
1:45 Swirl Concentrators: Richard Field, Storm and
Combined Sewer Section, EPA, Edison, N.J.
2:05 NPS Impact and Urban Holding Capacity: Major Issues -
G. Kenneth Young, GKY § Associates
2:40 Break
3:00 Q/A Period (Wednesday Speakers)
4:00 Adjournment
-------
THURSDAY
NOVEMBER 6, 1975
INSTITUTIONAL AND LEGAL ISSUES
Moderator: Herbert Poertner, Engineering § Research Consultant
AM
9:00 Nationwide Study of Problems/Solutions to Urban
Stormwater Management: Herbert Poertner,
Engineering § Research Consultant
9:30 The Intergovernmental Tangle Facing Stormwater Control:
Andrew Waldo, Water Planning Division, EPA,
Washington, D.C.
10:10 State - Local Coordination in Virginia: Eugene Jensen,
Executive Secretary, Virginia State Water Control
Board
10:40 Break
10:50 Financing Stormwater Projects: James R. Fountain, Jr.,
Director of Finance, Fulton County, Georgia
11:40 Lunch
PM
1:00 SCS, 208 Relationships: A. J. Dornbusch, Jr., State
Conservation Engineer, SCS
1:20 Legal Aspects: Frank E. Maloney, Professor of Law,
University of Florida
2:00 Planning to Narrow the Implementation Gap: George Berteau,
Chairman, Southeastern Wisconsin Regional Planning
Commiss ion
2:45 Break
3:00 Q/A Period (Thursday Speakers)
Moderator: Warren Cast
4:00 Adjournment
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C. 20460
URBAN STORMWATER MANAGEMENT SEMINAR
sponsored by
U. S. Environmental Protection Agency
Water Planning Division
Washington, D.C.
December 2, 3 and 4, 1975
Cosmopolitan Hotel
Denver, Colorado
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TUESDAY
December 2, 1975
Characterization of the Urban Stormwater Problem
Moderator: Dennis Athayde, Water Planning Division, EPA.
AM
8:15 Registration
8:55 Announcements
9:00 Welcoming Remarks: Charles Murray, Division Director of
Water Programs, EPA, Region VIII
9:10 Introduction to Program: Dennis Athayde, Water Planning Division,
EPA, Washington, D.C.
9:35 Instream Impacts of Urban Runoff: Eugene Driscoll, Hydroscience
10:15 Break
10:30 Characterization of Urban Stormwater Problems: Frank Condon,
Office of Research and Development, EPA, Washington, D.C.
11:10 Impact of Combined Sewer Overflows/Storm Sewer Discharges on
Water Quality: John Lager, Metcalf 5 Eddy, Inc.
11:50 Lunch
PM
1:15 NPS Impact and Urban Holding Capacity: Major Issues - G. Kenneth Young,
GKY § Associates
1:55 Measuring Runoff and Sampling Techniques: Eugene Driscoll, Itydrosciencc
3:15 Break
3:30 Applications of Stormwater Management Models: John Lager, Metcalf $
Eddy, Inc.
4:10 Adj ournment
4:15 Regional Sessions
5:30 Cash Bar
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WEDNESDAY
December 3, 1975
Approaches To Urban Stormwatcr Problems
Moderator: Kathleen Adgate, Water Planning Division, EPA
AM
9:00 Introduction to Program: Dennis Athaydc, Water Planning
Division EPA, Washington, D.C.
9:15 Housekeeping Techniques: Land Management Controls for
Developed Areas - Kathleen Adgate, Water Planning Division,
EPA, Washington, D.C.
9:40 Construction Practices:• Land Management Controls for Developii
Areas - Duane Bartee, Deputy State Conservationist, Soil
Conservation Service, Denver
10:20 Break
10:40 Collect ion System Control- John Lager, Metcalf 5 Eddy, Inc.
11:20 Cost-Effective Approach For Combined and Storm Sewer Cleanup:
William Pisano, Energy and Environmental Analysis, Inc.
11:50 Lunch
PM
1:00 Stormwater Film
1:40 Swirl Concentrators: Richard Field, Storm and Combined Sewer
Section, EPA, Edison, N. Jersey
2:20 Detention/Flow Attenuation: Herbert Poertner, Engineering
and Research Consultant
2:45 Break
3:00 Discussion Groups
4:30 Adj ournment
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THURSDAY
December 4, 1975
•
Institutional and Legal Issues
Moderator: Andrew Waldo, Water Planning Division. EPA
AM
9:00 Introduction to Program: Dennis Athayde, Water Planning Division,
EPA, Washington, D.C.
9:10 The Intergovernmental Tangle Facing Stormwater Control: Andrew Waldo,
Water Planning Division, EPA, Washington, D.C.
9:40 Legal Aspects of Urban Stormwater Management: Senator Joseph Shoemaker.
Denver, Colorado
10:20 Break
10:40 Financing Stormwater Projects- Senator .Joseph Shoemaker, Denver,
Colorado
11:10 Planning To Narrow The Implementation Gap: Richard Page, Seattle Metro
11:50 Concluding Remarks: Dennis Athayde
12:00 Adj ournment
ftU.S. GOVERNMENT PRINTING OFFICE: 1976 622-698/425 1-3
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