United States        Office of Research and    EPA/600/R-92/238
            Environmental Protection    Development        January! 993
            Agency          Washington, DC 20460
&EPA     Investigation of
           Inappropriate
           Pollutant
           Entries into Storm
           Drainage Systems

           A User's Guide

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                                                           EPA/600/R-92/238
                                                           January 1993
                          INVESTIGATION OF INAPPROPRIATE
                 POLLUTANT ENTRIES INTO STORM DRAINAGE SYSTEMS

                                    A User's Guide

                                         by
     Robert Pitt and Melinda Lalor
    Department of Civil Engineering
The University of Alabama at Birmingham
     Birmingham, Alabama  35294
         Donald Dean Adrian
      Civil Engineering Department
       Louisiana State University
    Baton Rouge, Louisiana 70803
           Richard Field
 Storm and Combined Sewer Program
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
    Edison, New Jersey  08837

          Donald Barbe'
   Department of Civil Engineering
   The University of New Orleans
   New Orleans, Louisiana 70148
         Contract Number 68-C9-0033 and Cooperative Agreement Number CR-816862
                                    Project Officer

                                  Richard Field, Chief
                       Storm and Combined Sewer Control Program
                          Risk Reduction Engineering Laboratory
                              Edison, New Jersey  08837
                     This report was conducted in cooperation with the
                       Center of Environmental Research Information
                          U.S. Environmental Protection Agency
                                Cincinnati, Ohio  45268
                                         and
                    The Urban Waste  Management and Research Center
                              The University of New Orleans
                             New  Orleans, Louisiana 70148
                      RISK REDUCTION ENGINEERING LABORATORY
                        OFFICE OF RESEARCH AND DEVELOPMENT
                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                               CINCINNATI, OHIO 45268
                                                                Printed on Recycled Paper

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                                         NOTICE
       The information in this document has been funded wholly or in  part by the United States
Environmental Protection Agency under contracts 68-03-3255 and 68-C9-0033 for Foster-Wheeler
Enviresponse, Inc. and under cooperative agreement CR-816862 for  the Urban Waste Management
and Research Center of the University of New Orleans. Although it has  been subjected to the Agency's
peer and administrative review and has been approved for publication as an EPA document, it does not
necessarily reflect the views of the Agency and no official endorsement should be inferred. Also, the
mention of trade names or commercial products does not imply endorsement by the United States
government.

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                                         FOREWORD
       Today's rapidly developing and changing technologies and industrial  products and  practices
frequently carry with them the increased generation of materials that, if improperly dealt with,  can
threaten both public health and the environment. The U.S. Environmental Protection Agency is charged
by Congress with protecting the Nation's land, air, and water resources. Under a mandate of national
environmental laws, the Agency strives to formulate and implement actions leading to a compatible
balance between human activities and the ability of natural systems to support and nurture life. These
laws direct the EPA to perform research to define our environmental problems, measure the impacts,
and search for solutions.

       The Risk  Reduction  Engineering Laboratory is responsible  for planning, implementing,  and
managing research, development, and demonstration programs to provide an authoritative, defensive
engineering basis in support of the policies, programs, and regulations of the  EPA with respect to
drinking  water,   wastewater,   pesticides,  toxic  substances,  solid  and  hazardous  wastes,  and
Superfund-related activities. This publication is one of the products of that research and provides a vital
communication link between the researcher and the user community.

       The purpose of  this User's Guide  is to provide guidance to  municipalities  for investigating
non-stormwater entries into storm drainage systems. Contaminated non-stormwater entries into storm
drainage  systems have been shown to contribute substantial levels of contaminants to the Nation's
waterways. These entries may originate from  many diverse sources including sanitary wastewaters
from leaky or directly connected sanitary sewerage and  from poorly operating  septic tank systems,
washwaters from laundries and vehicle service facilities, and many types of industrial wastewaters that
are discharged to floor drains  leading  to  the  storm drainage or from direct industrial wastewater
connections to the storm drainage system. Conventional pollution control programs may be ineffective
if these pollutant  sources are not identified and corrected.

       This User's Guide will be useful  to municipalities in conducting required studies as part of their
stormwater discharge permit activities, in  addition to other interested users. It will enable users to
identify the type and to estimate the magnitude of non-stormwater pollutant entries into storm drainage
systems  and to design needed  pollution control activities. An associated demonstration project (Pitt
and Lalor publication pending)  describes the development and testing of the procedures presented in
this User's Guide.
                                                  E. Timothy Oppelt, Director
                                                  Risk Reduction Engineering Laboratory

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                                        ABSTRACT
       This User's Guide  is the result of a series of EPA sponsored research tasks to develop a
procedure to investigate non-stormwater entries into storm drainage systems. A  number of past
projects have found that dry-weather flows discharging from storm drainage systems can contribute
significant  pollutant  loadings to receiving waters.  If these loadings are  ignored (e.g.,  by only
considering wet-weather stormwater runoff), little improvement in receiving water conditions may
occur with many stormwater control programs. These dry-weather flows may originate from many
sources, the most important sources may include sanitary wastewater or industrial and commercial
pollutant entries, failing septic tank systems,  and vehicle maintenance activities. After identification
of the outfalls that contain polluted dry-weather flows, additional survey activities are needed to locate
and correct the non-stormwater entries into the storm drainage systems.

       This User's Guide contains information to allow the design and conduct of local investigations
to identify the types and to estimate the magnitudes of these non-stormwater entries.

       This report was submitted  in partial  fulfillment of contracts numbered 68-03-3255  and
68-C9-0033 and cooperative agreement CR-816862 under the sponsorship of the U.S. Environmental
Protection Agency. This report covers a  period from October 1, 1990 to September 30, 1992, and
work was  completed as of September  30, 1992. This report  was prepared under subcontract to
Foster-Wheeler Enviresponse, Inc. of Edison, New Jersey, and  the Urban Waste Management and
Research Center of the University of New Orleans.
                                            (iv)

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                                         CONTENTS
Foreword   	 iii
Abstract 	iv
Figures	vii
Tables  	'	  viii
Acknowledgment	ix
       1.      Introduction	  1
                     Role of dry-weather flows in urban stormwater runoff analyses  	  1
                     Current legislation   	  2

       2.      Overview	  4
                     Potential dry-weather discharge sources	  4
                            Residential and commercial sources	  4
                            Industrial sources  	  6
                            Intermittent sources	  6
                            Direct connections to storm drains	  7
                            Infiltration to storm drains  	  7
                     Investigative methodology	  8
                     Recommendations  	  11
       3.     Mapping and Preliminary Watershed Evaluation	   12
                     Purpose  	   12
                     Mapping	   12
                            Receiving waters and storm sewer outfalls	   12
                            Drainage area for each  outfall	   13
                            Land uses for each outfall drainage area	   13
                            Other relevant information and features  	   16
                     Preliminary watershed evaluation	16

       4.     Selection of tracer parameters   	   18
                     Introduction	   18
                     Candidate parameters	   19
                            Physical inspection   	   19
                            Chemical parameters	   21
                            Toxicity screening tests	   25
                     Tracer characteristics of source flows	   25
                            Determining number of observations needed	   28
                     Selection of analytical methods  	   30
                            Detection limit requirements	   30
                            Required sample analytical precision  	   35
                            Recommended analytical methodology	   37
                                             (v)

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       5.      Initial Field Screening Sampling Activities	  41
                     Sampling strategy   	  41
                     Field data collection  	  41
                            Outfall locations  	  43
                            Field survey  	  43
                            Irregular flows	  50

       6.      Data Analysis to Identify Problem Outfalls and Flow Components	  51
                     Indicators of contamination	  52
                     Simple checklist for major flow component Identification	  53
                            Treated potable water 	  53
                            Sanitary wastewaters  	  58
                     Flow-weighted  mixing calculations	  59
                            Example calculations  	  59
                     Matrix algebra solution of simultaneous equations  	  64
                     Matrix algebra considering probability distributions of library data	  65

       7.      Watershed Surveys to Confirm and Locate Inappropriate
              Pollutant Entries to the Storm Drainage System   	  66
                     Using tracer parameters in the drainage system	  66
                            Review industrial user surveys or reports 	  66
                            Follow-up drainage area and on-site investigations	  66
                     Flow mass balances, dye studies, and smoke tests	  67
                            Locating an industrial source	  67

       8.      Corrective Techniques	  74
                     Public education	  74
                     Commercial and industrial disconnections of non-stormwater sources .  .  76
                     Failing septic tank systems  	  76
                     Direct sanitary  sewerage connections	  78
                     Rehabilitating storm or sanitary sewers to abate contaminated
                     water infiltration   	  78
                     Zoning and ordinances  	  79
                     Widespread sanitary sewerage failure	  80

Glossary	  81

References  	  86
                                             (vi)

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                                         FIGURES

Number                                                                              Page

       1      Outline of major topics presented in this User's Guide	  9

       2      Flow chart for investigative procedures 	  10

       3      Required  number of samples for allowable error and COV	  29

       4      Required  detection limits for low COV mixture components
              having means differing by 1.3 times  	  33

       5      Required  detection limits for low COV mixture components
              having means differing by 5 times	."	  33

       6      Required  detection limits for low COV mixture components
              having means differing by 20 times	  34

       7      Required  detection limits for low COV mixture components
              having means differing by 75 times	  34

       8      Analysis precision needed for detection of one percent
              contamination at ninety percent confidence  	  36

       9      Outfall characteristics for Birmingham, Alabama,
              demonstration project  	  42

       10     Flow chart to identify residential area non-stormwater
              flow sources  	  57

       11     Industrial inventory field  sheet  	  68

       12     Flowsheet for industrial case example 1	  70

       13     Flowsheet for industrial case example 2	  71

       14     Flowsheet for industrial case example  	  73
                                            (vii)

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                                          TABLES

Number                                                                                Page

1      Potential inappropriate entries into storm drainage systems	  5

2      Sources of industrial non-stormwater pollutant entries into
       storm drainage systems 	  14

3      Significant chemicals in industrial wastewaters  	  24

4      Field survey parameters and associated non-stormwater
       flow sources categories 	  26

5      Tracer concentrations found in Birmingham, Alabama, waters	  27

6      Detection limit requirements for tracer concentrations found in
       Birmingham, Alabama waters   	  32

7      Sample analyses lab sheet  	  38

8      Field equipment list 	  44

9      Sample evaluation sheet	  47

10    Interpretations of physical  observation parameters and
       likely associated flow sources	  48

11     Chemical and physical  properties of industrial non-stormwater
       entries into storm drainage systems	  54

12    Assumed source flow quality   	  60

13    Characteristics of source groupings	  61

14    Mixture calculations to identify source flow components  	  62
                                            (viii)

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                                    ACKNOWLEDGMENT
       This User's Guide contains information that has been developed and tested in a number of
separate  research reports investigating  inappropriate pollutant entries into storm drainage systems.
Many case studies were reviewed during early parts of this research to identify the most appropriate
methods  of investigation. Information that was obtained from these cities is gratefully acknowledged.

       Valuable technical assistance concerning industrial dry-weather discharges was provided by
Mark Miller and Tom Meinholtz (Triad Engineering, Inc.)  who were supported by Kevin Weiss of the
NPDES Branch, Permits Division, Office of Water, of the EPA through the Cadmus Group, Inc. Early
report guidance was also provided by Gene Driscoll (Woodward Clyde Consultants), also supported by
the Permits Division,  Office of Water, of the EPA. Dan  Murray, of the  Center of Environmental
Research Information, Cincinnati, Ohio,  EPA, also provided support for the  publication of this Guide.

       Richard Field, Chief  of the Storm and Combined  Sewer Pollution Control Program, EPA, was
the Project Officer for this project and provided much valued direction during this research.  Michael
Brown and Marie O'Shea of his staff, along with Ramjee Raghavan at Foster Wheeler Enviresponse,
Inc., also provided  important  project  assistance. Darwin Wright of the Office of Research  and
Development,  EPA is gratefully acknowledged  for his suggestion to work with the University of New
Orleans,  Urban  Waste Management and  Research  Center to conduct EPA  stormwater research
activities. Helpful comments from the report reviewers are also gratefully acknowledged.
                                             (ix)

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                                         SECTION 1

                                       INTRODUCTION
    Current interest in illicit or inappropriate connections to storm drainage systems is an outgrowth
of investigations into the larger problem of determining the role urban stormwater runoff plays as a
contributor to receiving water quality problems. Urban stormwater runoff is traditionally defined as that
portion of precipitation which drains from city  surfaces exposed to precipitation and flows via natural
or man-made drainage systems into receiving waters.  An urban stormwater drainage system also
conveys waters and wastes from many other sources. For example, Montoya (1987) found that slightly
less than half the water discharged from Sacramento's stormwater drainage system was not directly
attributable to precipitation. Sources of some of this water can be identified and accounted for  by
examining  current  NPDES (National Pollutant  Discharge  Elimination  System)  permit records, for
permitted industrial wastewaters that can be discharged to the storm drainage system. However, most
of the water comes from other sources, including illicit and/or inappropriate entries  to the storm
drainage  system. These entries can account for a significant amount of the pollutants discharged from
storm drainage systems (Pitt and McLean 1986).

    The  U. S. Environmental Protection Agency's (EPA's) Office of Research and Development's Storm
and Combined Sewer Pollution Control Program and the Office of Water's NPDES Program Branch have
supported the development of this User's Guide for the investigation of inappropriate entries to storm
drainage  systems. This User's Guide is designed to provide information and guidance to local agencies
by meeting the following objectives of:

    1. Identifying and describing the most significant pronounced sources of non-stormwater pollutant
       entries into  storm drainage systems.

    2. Describing  an  investigative  procedure  that  will allow for the determination of whether
       significant non-stormwater entries are  present in a storm drainage system, and then to identify
       the particular source, as an aid to the  ultimate location of the source.

    The  background study prepared in conjunction with this User's Guide (Pitt and Lalor publication
pending)  examined three categories  of non-stormwater  outfall discharges:  pathogenic/toxicant,
nuisance  and  aquatic  life  threatening,  and  clean water.  The  most  important  category  is outfall
discharges containing pathogenic or toxic  pollutants. The most likely sources for this category are
sanitary  or industrial wastewaters. The  outfall analysis  procedure described in this User's Guide has
a high probability of identifying all of the outfalls in this most critical category. High probabilities of
detection of other  contaminated  outfalls are also  likely  when using  these  procedures.  After
identification of  the contaminated outfalls, their associated drainage areas are then subjected to a
detailed source identification investigation.  The  identified pollutant sources are then corrected.
ROLE OF DRY-WEATHER FLOWS IN URBAN STORMWATER RUNOFF ANALYSES

     The EPA's Nationwide Urban Runoff  Program (NURP) highlighted the significance of pollutants
from illicit entries into urban storm drainage (EPA 1983). Such entries may be evidenced by flow from

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storm drain outfalls following and during substantial dry periods. Such flow, frequently referred to as
"baseflow" or "dry-weather flow", could be the result of direct "illicit connections" as mentioned in
the NURP final report (EPA  1983), or could  result from  indirect connections  (e.g., leaky sanitary
sewerage contributions through infiltration).  Many of these dry-weather flows are  continuous  and
would  therefore also occur during rain induced  runoff periods. Pollutant  contributions  from  the
dry-weather flows in some storm drains have been shown to be high enough to significantly degrade
water quality  because  of their substantial contributions to the annual mass pollutant  loadings to
receiving waters.

    Dry-weather flows and  wet-weather flows have been monitored during several urban  runoff
studies. These studies have found that discharges observed at  outfalls  during dry weather were
significantly different from wet-weather discharges.  Data collected  during the 1984 Toronto Area
Watershed Management Strategy Study (TAWMSS) monitored and characterized both stormwater and
baseflows (Pitt and  McLean 1986). This project involved intensive monitoring in two  test areas (one
a mixed residential and commercial area, and the other an  industrial area) during both warm and cold
weather and during both wet and dry weather. The annual mass discharges of many pollutants were
found to be dominated  by dry-weather processes.

    During the mid-1980s, several individual municipalities and urban counties initiated studies to
identify and correct illicit  connections to their storm drain systems.  This action was usually taken in
response to receiving water  quality problems or information noted  during individual  NURP projects.
Data from these studies indicate the magnitude of the cross-connection problem in many urban areas.
From  1984 to 1986, Washtenaw County, Michigan dye-tested 160 businesses in an  effort to locate
direct illicit connections to the County stormwater drainage. Of the businesses tested, 61 (38 percent)
were  found  to have improper  storm drain connections (Schmidt  and Spencer 1986). In 1987, the
Huron River Pollution Abatement  Program dye-tested  1067 commercial,  industrial, and  tax exempt
businesses and buildings. A total  of 154  (14 percent) were found to have improper  connections to
storm  drainage (Washtenaw  Co.  1988). Commercial car  washes and  other  automobile  related
businesses were responsible for the majority of the illicit connections in both studies. Discharges from
commercial  laundries were also noted. An investigation of outfalls from the separate  storm drain
system in Toronto, Canada revealed 59 percent with dry-weather flows. Of these, 84 (14 percent of
the total outfalls) were identified as grossly polluted based on the results of a battery of chemical tests
(GLA  1983). In 1987,  an inspection of the 90 urban stormwater outfalls draining into  Inner Grays
Harbor in Washington revealed 29 (32 percent) flowing during dry  weather (Pelletier and  Determan
1988). A total of 19 outfalls  (21  percent) were described as suspect based on visual  observation
and/or anomalous pollutant levels as compared to those expected in typical urban stormwater runoff
characterized by the EPA 1983 NURP  report.
CURRENT LEGISLATION

     With additional data now available, the Clean Water Act of 1987 contained provisions specifically
addressing discharges from storm drainage systems. Section 402 (p) (3) (B) provides that permits for
such discharges:

     i.      May be issued on a system or jurisdiction-wide basis.

     ii.     Shall  include a requirement to  effectively prohibit non-stormwater discharges into the
           storm drains, and

     iii.     Shall  require controls to  reduce  the  discharge of  pollutants  to the maximum extent
           practicable, including management practices, control techniques and system design and

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           engineering  methods,  and  such other provisions  as the Administrator or the State
           determines appropriate for the control of such pollutants.

    In response to these provisions, the EPA issued a final rule to begin implementation of section
402(p) of the Clean Water Act on November 16, 1990 (40 CFR  parts 122, 123, and 124 National
Pollutant  Discharge Elimination  System Permit Regulations  for  Storm Water  Discharges,  Federal
Register, Vol. 55, No. 222). A screening  approach which includes chemical testing of outfalls or storm
drainage with  dry-weather flow (defined  by a  72-hour antecedent dry period), was adopted.  The
parameters to be tested  are a combination of several pollutants of concern and "tracers" that may be
used to help identify contaminated outfalls and  predict the source of illicit discharges.

    Section 122.26 (d) (1) (iv) (D)  of  the  rule applies specifically to this User's Guide. The  EPA
requires an initial screening program to provide a means of detecting high levels of pollutants in storm
sewerage. The protocol  of this User's Guide seeks to determine whether or not non-stormwater flows
are causing problems (e.g. pathogenic, toxic,  aquatic  life threatening, nuisance),  and  to  provide
additional detail  with respect to the source. It accomplishes this by outlining an effective screening
methodology to identify storm drainage system  outfalls contaminated by  illicit or inappropriate
discharges and to determine specifically how the likely  sources  can  be identified. This  protocol is
supported  by  a research  report (Pitt and  Lalor publication  pending) containing  the results  of a
demonstration project using these procedures and much more detailed information.

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                                         SECTION 2

                                         OVERVIEW


POTENTIAL DRY-WEATHER DISCHARGE SOURCES

    This User's Guide is directed to the identification and location of non-stormwater entries into storm
drainage systems. It is important to note that for any effective  investigation of pollution within a
stormwater system, all pollutant sources must be included. Prior research has shown, that for many
pollutants,  stormwater may contribute the smaller portion of the total pollutant mass discharged from
a storm drainage system. Significant pollutant  sources may include dry-weather entries occurring
during both warm and cold months and snowmelt runoff,  in  addition  to conventional stormwater
associated  with rainfall.  Consequently,  much  less pollution  reduction benefit  will occur  if  only
stormwater is considered  in a control plan for controlling storm drainage discharges. This User's Guide
contains a  protocol to identify  sources of inappropriate entries  to  storm  drainage systems.  The
investigations presented in this User's Guide may also identify illicit point source outfalls that do not
carry stormwater. Obviously, these  outfalls also need to be controlled and permitted.

    Table  1 summarizes  the potential sources of contaminated entries into storm drainage systems,
along with  their likely  flow characteristics. The following subsections summarize these sources.

Residential and Commercial Sources

    The most common potential non-stormwater entries,  which have been identified by a review of
documented case studies for commercial and  residential areas are:

     • Sanitary wastewater sources:
       - sanitary wastewater (usually untreated) from improper sewerage connections, exfiltration, or
         leakage
       - effluent from improperly operating, or improperly designed, nearby septic tanks

     • Automobile maintenance and operation sources:
       - car wash wastewaters
       - radiator flushing wastewater
       - engine de-greasing wastes
       - improper oil disposal
       - leaky underground storage tanks

     • Irrigation sources:
       - lawn runoff from over-watering
       - direct spraying of impervious surfaces

     • Relatively clean sources:
       - infiltrating groundwater
       - water routed from pre-existing  springs  or streams
       - infiltrating potable water from leaking water mains

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TABLE 1.  POTENTIAL INAPPROPRIATE ENTRIES INTO STORM DRAINAGE SYSTEMS
Potential
Source:
Residential Areas:
Sanitary Wastewater
Septic tank effluent
Household chemicals
Laundry wastewater
Excess landscaping
watering
Leaking potable water
pipes
Commercial Areas:
Gasoline filling station
Vehicle
maintenance/repair
Laundry wastewater
Construction site
de-watering
Sanitary wastewater
Industrial Areas:
Leaking tanks and pipes
Miscellaneous process
waters111
Storm Drain
Entry
Direct Indirect

X x
X
x X
X
X
X

X x
X x
X
X
X x

x X
X x
Flow
Characteristics
Conti- Inter-
nous mittent

X x
X x
X
X
X
X

X
X
X x
X x
X

X x
X x
Contamination Category
Patho- Nu
genie/ an
Toxic

is- Clear
ce

X x
X x
X

X
x x X


X
X
X



x X
X
X

X



X x x
 Note:   X: most likely condition
        x: may occur
        blank: not very likely
   see Table 2 for industrial examples

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    • Other sources:
       - laundry wastewaters
       - non-contact cooling water
       - metal plating baths
       - dewatering of construction sites
       - washing of concrete ready-mix trucks
       - sump pump discharges
       - improper disposal of household toxic substances
       - spills from roadway and other accidents
       - chemical, hazardous materials, garbage, sanitary sludge landfills and disposal sites

    From  the above  list, sanitary wastewater is the most significant source of bacteria and oxygen
demanding substances, while automobile maintenance  and plating baths are the most significant
sources of toxicants. Waste discharges associated with the improper  disposal of  oil and household
toxicants  tend  to be intermittent and low volume. These wastes may therefore not reach  the
stormwater outfalls unless carried by higher flows from another source,  or by stormwater during rains.

Industrial Sources

    There are several types of industrial dry-weather entries to storm drainage systems. Common
examples include the discharge of cooling water, rinse water, other process wastewater, and  sanitary
wastewater. Industrial  pollutant sources tend to be related to the raw materials used, final product,
and the waste or byproducts created. Guidance on typical discharge characteristics associated with
common industries is given in Sections 4, 5, and 6.

    There is also a high potential for unauthorized connections within older industries. One reason for
this is that at the time of an industry's development, sanitary sewers may not have  been  in existence,
since early storm drains preceded the development of many sanitary sewer systems. Also a lack of
accurate maps of sanitary and storm drain lines may lead  to confusion as to their proper identification.
In addition, when the activities within an industry change or expand, there is a possibility for illicit or
inadvertent connections, e.g., floor  drains and other storm drain connections receiving industrial
discharges which should be treated before disposal.  Finally, industries processing large volumes of
water may find sanitary sewer flow-carrying capacity inadequate or sanitary sewers located too far
away, leading to improper removal of excess water through the storm  drain system.

    Continuous processes, e.g., industrial manufacturing, are important potential sources because any
waste streams produced are likely to be constantly flowing. Detection of dry-weather discharges from
these sources is therefore made easier, because the continuous and probably undiluted nature  of these
discharges is more discernable, e.g., odors produced will be stronger and colors more  intense along
with their tracer constituents being more concentrated and more readily detected by sampling.

Intermittent Sources

    The presence of regular, but intermittent, flows will usually be a good indication of contaminated
entries to the storm drains, and  can usually be distinguished from groundwater infiltration flows.
However,  as drainage areas increase in  size,  many intermittent  flows will combine to  create  a
continuous composite flow. Examples of possible situations or activities that can produce intermittent
dry-weather flows are:

     • Wash-up operations at the end of a work shift, or job activity.
     • Wash-down following irregular accidents and  spills.
     • Disposal of process batches or rinse water baths.

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     • Over-irrigation of lawns.
     • Vehicle maintenance, e.g., washing, radiator flushing, and engine de-greasing.

    Industries that operate on a seasonal basis, e.g., fruit canning and tourism can be a source of
longer duration intermittent discharges.

Direct Connections to Storm Drains

    Direct connections are defined in this Guide as physical connections of sanitary, commercial, or
industrial piping (or channels) carrying untreated or partially treated wastewaters to a separate storm
drainage system. These  connections  are usually unauthorized.  They may be intentional or may be
accidental due to mistaken identification of sanitary sewerlines. They  represent the  most common
source of entries to storm drains by industry.

    Direct connections can result in continual or intermittent dry-weather entries of contaminants into
the storm drain. Some common situations are:

     • Sanitary sewerlines that tie into a storm drain.
     • Foundation drains or residential sump-pump discharges that are frequently connected to storm
       drains.  While  this practice may be quite appropriate in many cases, it can be a source of
       contamination when the local groundwater  is contaminated,  as for example  by septic tank
       failures.
     • Commercial laundries and car wash establishments that may route process wastewaters to
       storm drains rather than sanitary sewers.

Infiltration to Storm Drains

    Infiltration into  storm  drains most commonly  occurs through leaking pipe joints  and poor
connections to catch  basins and manhole  chimneys but can also be due to  other causes, such as
damaged  pipes and subsidence.

    Storm drains, as well as natural drainage channels, can therefore intercept and convey subsurface
groundwater and percolating waters.  In many cases, these waters will  be  uncontaminated and have
variable flows due to  fluctuations in the level of the  water table and percolation from  rainfall events.

    Underground potable water main  breaks are another potential clean  water  source to storm drains.
While such occurrences are not a direct pollution source, they should obviously be corrected.

    Groundwater may be contaminated, either in localized  areas or on a relatively widespread basis.
In cases where infiltration into the storm drains occurs, it can be a source of  excessive contaminant
levels in the storm drains. Potential sources of groundwater contamination include, but are not limited
to:

        Failing or nearby septic tank systems.
        Exfiltration from sanitary sewers in poor repair.
        Leaking underground (and above-ground) storage tanks  (LUST) and pipes.
        Landfill seepage.
        Hazardous waste disposal  sites.
        Naturally occurring toxicants  and pollutants  due to  surrounding  geological or  natural
        environment.

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    Leaks from underground and above-ground storage tanks and pipes are a common source of soil
and groundwater pollution and may lead to continuously contaminated dry-weather entries. These
situations are usually found in commercial operations such as gasoline service stations, or industries
involving the piped transfer of process liquids over long distances and the storage of large quantities
of fuel, e.g., petroleum refineries.
INVESTIGATION METHODOLOGY

    Applying the methodology presented in this User's Guide will determine if a storm drain outfall
(and drainage system) is  affected  by pronounced non-stormwater entries.  In many  cases,  the
information to be collected by using this methodology will also result in a description of the most likely
sources of these discharges.

    Several aspects of this methodology were derived from the experience of many municipalities that
have previously investigated inappropriate entries into storm drainage systems.

    The methodology establishes priorities to identify the areas with the highest potential for causing
problems. The  investigative procedures  then  separate the storm  drain outfalls into three general
categories (with a known level of confidence)  to identify which  outfalls (and drainage areas) need
further analyses and investigations. These categories are outfalls affected by non-stormwater entries
from: (1) pathogenic or toxic  pollutant sources, (2) nuisance and aquatic  life  threatening pollutant
sources, and (3) unpolluted water sources.

    The pathogenic and toxic pollutant source category should be considered the most severe because
it can cause illness upon water contact or consumption and significant water treatment problems for
downstream consumers, especially if the pollutants are soluble metal and  organic toxicants. These
pollutants may originate from sanitary, commercial, and industrial wastewater non-stormwater entries.
Other residential area sources (besides sanitary wastewater), e.g.,  inappropriate  household toxicant
disposal, automobile engine de-greasing, and excessive use of chemicals (fertilizers and pesticides) may
also be considered in this most critical category.

    Nuisance and aquatic  life threatening pollutant sources can originate from residential areas  and
aside from  raw sanitary wastewaters may include laundry wastewaters,  lawn irrigation  runoff,
automobile  washwaters, construction site dewatering, and washing of  concrete ready-mix  trucks.
These pollutants can cause excessive dissolved oxygen depletions, and algal growths, tastes and odors
in downstream water supplies, offensive coarse solids and floatables, and noticeably colored, turbid
or odorous waters.

    Clean water discharged through stormwater outfalls can originate from natural springs feeding
urban  creeks that have  been converted to storm  drains,  infiltrating groundwater,  infiltration from
potable waterline leaks, etc.

    Figure  1 is an outline of the major  topics presented in this  User's Guide, and  Figure 2  is a
simplified flow chart for the detailed methodology. The initial phase of the investigative protocol
includes the initial mapping and field  surveys. These activities require minimal effort and result in little
chance of missing a seriously contaminated outfall. The initial activities are followed by more detailed
watershed surveys to  locate and correct the sources of the contamination  in  the identified problem
areas. After corrective  action has been taken, repeated  outfall field surveys are required to ensure that
the outfalls  remain  uncontaminated.  Receiving water monitoring should also be conducted to analyze
water quality improvements. If expected  improvements  are not noted,  then additional  contaminant
sources are likely present and additional outfall and watershed surveys are  needed.

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  MAPPING & PRELIMINARY WATERSHED EVALUATION (SECTION 3)

        1)  Identify receiving waters.
        2)  Locate all outfalls and associated drainage areas.
        3)  Compile data on land uses within drainage areas.
         SELECTION OF TRACER PARAMETERS (SECTION 4)

        1) Select physical and chemical parameters to measure.
        2) Determine suitable analysis techniques and number of samples
          required.
        3) Develop library of potential local source flow characteristics.
     INITIAL FIELD SCREENING SAMPLING ACTIVITIES (SECTION 5)

        1) Conduct outfall screening survey for intermittent and continuous
          flows.
         DATA ANALYSIS TO IDENTIFY PROBLEM OUTFALLS
               AND FLOW COMPONENTS (SECTION 6)

        1)  Simple procedures using checklists for typical major flow
           components.
        2)  More detailed analyses utilizing library of data on potential source
           flows will quantify flow components.
  WATERSHED SURVEYS TO CONFIRM AND LOCATE INAPPROPRIATE
 POLLUTANT ENTRIES TO THE STORM DRAINAGE SYSTEM (SECTION 7)

        1)  Conduct drainage surveys using tracer parameters  in critical
           watersheds.
        2)  Use flow mass balances, dye studies, smoke tests, and T.V. surveys
           in isolated drainage areas.
               CORRECTIVE TECHNIQUES (SECTION 8)

        1)  Educate public/industry and enforce with ordinances, zoning, etc.
        2)  Disconnect illicit direct connections.
        3)  Wide spread entries may require regional solutions or designation of
           storm drainage system as a CSO.
Figure 1. Outline of major topics presented in this User's Guide
                                9

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    /
       Prepare A/ea Map.
    /             \
   -/   Prioritize Areas:   y
Figure 2. Flow chart for investigation procedures.
                        10

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RECOMMENDATIONS

    This User's Guide should be used as part of a comprehensive stormwater management plan which
addresses all sources of stormwater pollution. Correction of pollutant entries identified by use of only
this User's  Guide is unlikely to  achieve  a significant  improvement in the  quality of stormwater
discharges or receiving waters.

    A municipality will  need to plan their investigation  of inappropriate entries to a storm drainage
system to suit local conditions. This User's Guide describes the issues in sufficient depth and provides
examples to  enable  the design  of  a local  investigation.  Greater detail  and the  results of  a
comprehensive demonstration of these procedures will be given in a supporting research report by Pitt
and Lalor (publication pending).

    The full use of all of the applicable procedures described in this User's Guide is likely to be required
for successful identification of pollutant sources. Attempting to reduce costs, for example by only
examining a certain class of outfalls, or using inappropriate testing procedures, will significantly reduce
the utility of the testing program and result in inaccurate data. Also cursory data analyses is likely to
result in  inaccurate conclusions.

    During investigations of non-stormwater entries to storm drainage systems, consideration should
be given to  any economic and practical advantages  of designating the storm drainage system as a
combined sewer systems and applying end-of-pipe combined sewer overflow (CSO) control-treatment.

    It is also recommended that the methodology  (appropriately modified)  be applied to other types
of sewerage  systems,   such as  combined and separate  sanitary sewerage systems,  to locate
inappropriate entries, e.g., untreated or toxic industrial wastewaters/wastes or infiltration/inflow (I/I)
in separate sanitary sewers.

    It is recommended that  this  User's Guide  be  updated and refined by incorporating experience
gained in its application. Incorporation of information from a wide variety of test locations (e.g., lake
and large river receiving waters,  tidal receiving waters, areas experiencing long dry periods, areas
having short summers, areas having unusual groundwater characteristics, etc.)  will improve the testing
and data analyses protocols described.
                                              11

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                                         SECTION 3

                   MAPPING AND PRELIMINARY WATERSHED EVALUATION
PURPOSE

    An investigation of non-stormwater entries into a storm drainage system needs to proceed along
a systematic path of action, which investigates areas from high to low potential for causing problems,
and focuses in from general outfall screening to  pin-pointing pollutant sources.

    A mapping and evaluation methodology, as detailed in this section, is required to identify the areas
to investigate and to provide a basis to prioritize the areas by potential to contribute non-stormwater
entries into the storm drainage system.

    The  data collected in this phase is important as it forms the basis for the rest of the more detailed
investigations, described  in the subsequent sections of this User's Guide.
MAPPING

    To make this exercise as economical and productive as possible, full advantage should be taken
of any existing and  available  information. Data  gained from  existing  sources will  need to be
supplemented with information obtained by  field  investigations. The following  summarizes  the
information required, likely data sources, and how to obtain the information.

Receiving Waters and Storm Sewer Outfalls

    The receiving waters and stormwater drainage outfalls must be identified and accurately located
on appropriate maps.  However records of all outfalls are hard to locate, and even for those that can
be found, the locations of the outfalls may  not be accurate.  It is therefore important that the field
survey described in Section  5 be used to supplement the data collected during this initial stage. As
noted in  Section 5,  it  can take three visits to a drainage area to find all (or almost all) outfalls.

    Possible sources  of documented information include:

       City records, drainage maps, and storm drain maps.
       Previous surveys,  e.g.,  sanitary sewer infiltration/inflow (I/I) and sewer system evaluation
       survey (SSES) studies.
       Topographic maps.
       Existing GIS (Geographic Information System) data.
       Pre-development stream  locations.
       Drainage department personnel having  knowledge of the area.
       Aerial surveys.
                                             12

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Drainage Area for Each Outfall

    The drainage area for each outfall must be determined and marked on the map. This will enable
known potential pollutant source  locations to  be assigned to the  correct outfall. Sources for this
information are storm drain maps and topographical maps. These should be at least 1" = 200' scale and
have no greater than 5 ft contour intervals (depending on the steepness of the area).

Land Uses for Each Outfall  Drainage Area

    Local planning departments should have detailed zoning maps of the area.  These maps should
designate residential, commercial, and industrial  land uses in  each of the outfall drainage areas. In
addition, local revenue departments should have lists of business licenses for the entire municipality,
but they may not be usefully sorted. The public health department  should know where septic tanks
are used. Aerial photographs can provide useful information to  identify and/or confirm land use areas.
Historical land uses, especially landfills and industrial areas, should also be noted.

    An effective way to obtain this information is to examine  the municipality's  zoning maps and to
drive to the critical areas to conduct inspections. The land uses of most interest are all  industrial,  most
commercial,  and some municipal activities. The activities in the commercial areas of most concern
include vehicle related activities (sales, parts, service, or repair), laundry or dry cleaning (including
hospitals and hotels), and restaurants. The municipal activities of  most concern include  but are not
limited to: landfills, bus barns, airports, and sanitary wastewater treatment facilities.

    Table 2 can be used to identify the local industries in each drainage area most likely to contribute
non-stormwater entries into the storm drainage system. The categories considered in this table include
loading and unloading of dry bulk or liquid materials, outdoor  storage or processing, water usage
(cooling  and process waters),  dust or particulate generating processes,  and  illicit or  inadvertent
industrial connections. The  likelihood of an industry producing dry-weather or wet-weather discharges
in each of these categories was  rated on the basis of high, moderate, or low potential  and not
applicable if there  was no relationship evident.

    The industrial categories listed in Table 2 were defined according to the 1987 Standard Industrial
Classification Manual codes (SIC code). The industries were classified according to six main categories.
The category for "Primary Industries" includes facilities involved in the production of food products and
other basic  goods. The category  of  "Material Manufacturing"  includes those industries producing
materials such as lumber, paper, glass, and leather.  Similarly, the "Chemical Manufacturing" category
includes those industries making products such as plastics, paints, detergents, fertilizers, pesticides,
and other related substances. "Transportation and Construction" primarily concerns the discharge of
contaminants from building or  other types of outdoor development. The  "Retail" category includes
establishments engaged in the selling of merchandise or offering merchandise related services. Finally,
all other industries which did not fit into any of the above classifications were placed into a "General"
category. Those industries which are not specifically listed should have characteristics resembling the
industries of the major groups with which they are classified by SIC code.

     Investigators should take care to include any area where the land use has a potential to contribute
pollutant sources to a storm drainage system. As stated above,  these land uses  may not be covered
by Table 2.  Some  common examples of land use areas to be included are given below:

     • Landfill areas can be a source of leachate and polluted runoff.
     • Airports have a high potential for fuel spillage. Aircraft  deicing agents, and other maintenance
        operations, produce wastewaters that may be discharged into the storm  drainage system.
                                              13

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TABLE 2. SOURCES OF INDUSTRIAL NON-STORMWATER ENTRIES INTO STORM DRAINAGE SYSTEMS


Industrial Categories
Major Classifications
SIC Group Numbers
Loading/Unloading
Dry Bulk Liquids
Outdoor
Storage/
Processing
Water Usage
Cooling Process
Particle Illicit/
Generating Inadvertent
Process Connections
Primary Industries
20
201
202
203

204
205
206
207
208
21
22
23


Food & Kindred Products
Meat Products
Dairy Products Processing Industry
Canned & Preserved Fruits
& Vegetables
Grain Mill Products
Bakary Products
Sugar & Confectionary Products
Fats & Oils
Beverages
Tobacco Manufactures
Textile Mill Products
Apparel & Other Finished Products
Made from Fabrics
& Similar Materials

H
H
H

H
H
H
H
H
H
H
H



L
H
H

H
M
M
H
H
M
L
L



H
NA
H

L
NA
NA
NA
NA
NA
NA
NA



H
H
H

H
NA
L
M
H
NA
H
NA



H
H
H

H
H
M
H
H
M
H
M



L
NA
M

H
M
H
NA
M
H
M
M



H
H
H

H
L
L
M
L
M
H
L


Material Manufacture
24
25
26
27
31
32

33
34
37

Lumber & Food Products
Furniture & Fixtures
Paper & Allied Products
Printing, Publishing, & Allied Industries
Leather & Leather Products
Stone, Clay, Glass, &
Concrete Products
Primary Metal Industries
Fabricated Metal Products
Transporation Equipment

H
H
H
H
H
H

H
H
L

L
M
H
M
H
M

M
H
H

H
NA
H
NA
L
H

H
L
L

NA
NA
H
NA
L
L

H
H
H

M
L
H
M
H
H

H
H
H

H
M
H
H
H
H

H
H
L
(continued)
L
L
H
L
H
L

H
H
H


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                                                        TABLE 2.  (continued)


Industrial Categories
Major Classifications
SIC Group Numbers
Outdoor
Loading/Unloading Storage/
Dry Bulk Liquids Processing
Particle
Water Usage Generating
Cooling Process Process
Illicit/
Inadvertent
Connections
Chemical Manufacture
28 Chemicals & Allied Products
281
282
283
284

285

286
287
Industrial Inorganic Chemicals
Plastic Materials & Synthetics
Drugs
Soap, Detergents, & Cleaning
Preparations
Paints, Varnishes, Lacquers
Enamels & Allied Products
Industrial Organic Chemicals
Agricultural Chemicals
H
H
L
H

H

H
L
H
H
L
H

H

H
L
NA
L
NA
NA

NA

NA
NA
H
H
H
H

L

H
H
H
M
M
H

H

H
L
H
L
L
H

H

H
L
H
H
L
H

L

M
L
29 Petroleum Refining & Related Industries
291
296
30
Transportation
16
16
Retail
62


63
64
55

66
67

58
Other


NOTE:
Petroleum Refining
Paving & Roofing Materials
Rubber & Misc. Plastic Products
& Construction
Building Construction
Heavy Construction

Building Materials, Hardware
Garden Supply, &
Mobile Home Dealers
General Merchandise Stores
Food Stores
Automotive Dealers &
Gasoline Service Stations
Apparel & Accessory Stores
Home Furniture, Furnishings
and Equipment Stores
Eating & Drinking Places

Coal Steam Electric Power
Nuclear Steam Electric Power
H: High potential M
L
H
H

M
M

H


H
H
H

H
H

H

H
NA
Medium potential
H
H
H

L
L

L


M
H
H

L
L

M

L
L
L
H
H
NA

H
H

H


L
NA
H

NA
L

NA

H
NA
Low potential
H
NA
H

NA
NA

NA


NA
NA
NA

NA
NA

NA

H
H
NA:
L
M
H

L
L

L


L
M
M

L
L

M

L
L
Not applicable
NA
M
H

H
H

NA


NA
L
L

NA
NA

NA

H
NA

H
L
M

L
L

L


L
L
M

L
L

M

L
NA

CJI

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     • Government facilities, such as military bases, may store or use polluting materials and have
       large vehicle maintenance facilities.
     • Agricultural impacts are likely to be greater for wet-weather flows, but practices such as
       irrigation and drainage tiles may also produce dry-weather flows.

    Finally, it is necessary to identify and locate existing permitted discharges to streams and storm
drainage. The National Pollutant Discharge Elimination System (NPDES) permits, administered by most
states or, if not, by the EPA Regional Offices, contain this information for the facilities currently having
discharge permits. Only a small fraction of all industries have NPDES permits, as most have no direct
wastewater discharges to waters of the United States.  Pretreatment programs for municipal sewage
treatment plants would also contain additional industrial information.

Other Relevant Information and Features

    It is important that investigators be aware of any relevant features or information which may be
specific to  their drainage area and not included specifically in the above subsections of this User's
Guide. Examples of some items that need to be included are discussed in this subsection.

    Information on pre-development streams and springs, which may have been routed into the storm
drainage system, will aid in the  identification of natural uncontaminated or contaminated dry-weather
flows.

    Information regarding depth to the water table  will be helpful.  If the water table is well below the
storm drain invert at all times, then groundwater infiltration may be  less important as a potential source
of dry-weather flow. However, the accumulation of percolating shallow groundwater will still occur in
storm drainage fill material and be a potential source of some infiltration water. Groundwater conditions
for the  study  area may be available  from special studies conducted by the USGS (U.S. Geological
Survey), the  state water agency, or other sources. Utility construction and repair crews and  earth
moving companies should know of areas having shallow groundwater.  Local  I/I and SSES  studies also
include information concerning  shallow groundwater. Well log data collected during drilling of water
supply wells, and information from geotechnical investigations, may also be useful.

    Areas  serviced by sanitary sewerage and areas serviced by septic tanks should be determined in
order to identify the areas most likely to have direct connections and infiltration sources, respectively.
Either  local health,  sewerage,  utility, environmental, or public works departments should  have
information on the location of these areas.

    Older residential areas with failing infrastructure (especially sanitary sewerage in poor condition),
and high density residential areas with septic tanks,  should be designated as areas with a high potential
for pollutant entries into the storm drainage system.
PRELIMINARY WATERSHED EVALUATION

     The above  activities should produce maps with complete descriptions of the drainage areas,
including outfall locations, NPDES permittees, critical land uses, drainage boundaries for each outfall,
city limits, major streets, streams, etc.  The investigators  need to classify  drainage areas by their
potential for causing non-stormwater entries. This mapping information, together with the information
to be obtained as described in Sections 4 and 5 and analyzed as described in Section 6, will form the
basis to rank the drainage areas  in order of priority for further detailed drainage area investigations
(Sections 7 and 8).
                                              16

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    The investigation of non-stormwater entries will have a cost associated with it, which will increase
with the drainage system size and complexity, and with the number of sources being investigated. All
pollutant sources, including both wet- and dry-weather pollutant entries, will need to be controlled to
have an effective improvement in the quality of the stormwater system  discharge. Pitt and McLean
(1986) noted that even with the removal of directly connected non-stormwater entries,  stormwater
originating  from industrial and commercial land uses has a high  probability of having unacceptable
pollutant loads. It would therefore be prudent, at an early stage in the investigation,  to review the
costs of the investigation and corrective action versus the cost for treatment of the stormwater system
discharge.  The classification  of the storm drainage system  as a combined sewer, and  subsequent
treatment of the flow,  may prove to be a more economical and practical alternative. An appropriate
time for such  a review would be after the mapping and field screening activities to avoid complex,
costly, and time consuming drainage system investigations into inappropriate non-stormwater entries,
and instead direct resources to pollution control.
                                              17

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                                         SECTION 4

                            SELECTION OF TRACER PARAMETERS
INTRODUCTION

    The detection and identification of inappropriate entries requires the quantification of specific
characteristics  of the observed outfall baseflow. The  characteristics of most  interest  should be
relatively unique for each potential flow source. This will enable the presence of each flow source to
be  noted,  based on the presence  (or  absence) of these  unique characteristics.  The  selected
characteristics are termed tracers, because they have been selected to enable the identification of the
sources of these waters.

    One approach presented in this User's Guide is based on the identification and quantification of
clean  baseflow and contaminated components. If the relative amounts of potential components are
known, then the importance of the baseflow can be determined.  As an example, if a baseflow  is
mostly uncontaminated groundwater, but contains 5 percent raw sanitary wastewater, it would  be a
likely important source of  pathogenic bacteria. Typical raw sanitary wastewater parameters (e.g., BOD6
or suspended solids) would  be in low concentrations and the sanitary wastewater source would be
difficult to detect. Fecal coliform bacteria  measurements  would not help much because they originate
from many possible sources. Expensive specific pathogen measurements  would be needed to detect
the problem directly.

    The ideal tracer should  have the following characteristics:

     •  Significant difference in concentrations between  possible pollutant sources;
     •  Small variations in concentrations within each likely pollutant source category; •
     •  A conservative behavior (i.e., no  significant concentration change due  to physical, chemical
        or biological processes);  and,
     •  Ease of measurement with adequate detection limits, good sensitivity, and repeatability.

    In  order  to identify tracers meeting  the above  criteria, literature characterizing  potential
inappropriate entries into  storm drainage systems was examined. Several case studies which identified
procedures used by individual municipalities or regional agencies were also examined. Though most
of the investigations resorted  to expensive  and time consuming  smoke or dye testing to locate
individual illicit pollutant entries, a few provided information regarding test parameters or tracers. These
screening tests  were proven useful in  identifying drainage systems with problems before the smoke
and dye tests were  used. The  case  studies also revealed the types of illicit pollutant entries most
commonly found in  storm drainage systems.

    This list of potential illicit sources (see Section 2) led to a search for information regarding the
chemical and physical characteristics of these specific flows. This search yielded  typical characteristics
for sanitary  wastewater,  septic tank effluent, coin-operated laundries and car wash effluents as well
as potable  water and "natural  waters". This information, along with specifics obtained from case
studies, provided the basis for selecting parameters for further study. Specific analyses will be needed
to identify the characteristics  of local potential  inappropriate  entries  and uncontaminated water

                                              18

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sources, as described in this section.
CANDIDATE PARAMETERS

    Many different candidate parameters were evaluated before the suggested list was developed (Pitt
and Lalor publication pending). It is recommended that the initial field screening effort (in the absence
of known commercial and industrial activities in the watershed)  include at least:

     • Placement of outfall identification number.
     • Outfall discharge flow estimate.
     • Floatables, coarse solids, color, turbidity, oil sheen, and odor characteristics of discharge and/or
       receiving nearfield water.
     • Other outfall area characteristics, e.g., stains, debris, damage to concrete, corrosion, unusual
       plant growth,  or absence of plants.
     • Water temperature.
     • Specific conductivity.
     • Fluoride and/or hardness concentrations.
     • Ammonia and/or potassium concentrations.
     • Surfactant concentration and/or fluorescence.
     • Chlorine concentration and pH.

If commercial or industrial activities occur in the drainage area,  then it  is important to add additional
parameters  (e.g., a toxicity screening procedure and specific  metallic and organic toxicant analyses)
to the above list.

    Most of the screening effort items listed  above can be obtained at  the outfall  location using field
procedures. It is much easier, more cost-effective, and much more accurate to  collect samples in the
field for later laboratory analyses.  Analyzing multiple samples for the same parameter is much more
efficient than trying to analyze a single sample for  many parameters, especially under adverse field
conditions.

    The selection of  the analysis  procedures and equipment will depend on many conditions, most
notably the expected  concentrations in the  uncontaminated baseflows  and in the  potential
non-stormwater discharge flows, along with the needed probabilities  of detection  at the minimum
contamination level. A description of the  techniques  developed as part of this study to help in the
selection of the analytical procedures is given later  in  this section. Other factors affecting  procedure
selection include ease of use, analytical interferences, cost of equipment, training requirements, and
time requirements to  conduct the analyses.

Physical Inspection

    Estimates of outfall flow rates, and noting the  presence  of oil sheens, floatables, coarse solids,
color, odors, etc. will  probably be the most useful indicators of outfall problems. Physical observations
of outfall conditions have been  noted in case  studies to be very  useful in determining the significance
of contaminated dry-weather flows. There has been a good correlation between storm drains judged
contaminated after physical inspection and those judged contaminated after chemical tests at several
case studies (e.g., Inner Grays Harbor, Washington, Beyer, et  al. 1979 and Pelletier and Determan
1988; Fort Worth, Texas, Falkenbury 1987 and 1988 and Moore and Hoffpauir 1988; and Toronto,
Ontario, GLA 1983).
                                              19

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Odor-
    The odor  of  a discharge can  vary widely  and sometimes  directly  reflects  the source  of
contamination.  Industrial dry-weather discharges  will  often cause the flow to smell like a particular
spoiled product, oil, gasoline, specific chemical, or solvent. As an example, for many industries, the
decomposition of organic wastes in the discharge will release sulfide compounds into the air above the
flow in the sewer, creating  an intense smell  of rotten eggs. In particular, industries involved in the
production of meats, dairy products, and the preservation of vegetables or fruits, are commonly found
to discharge organic materials into storm drains. As these organic materials spoil and decay, the sulfide
production creates this  highly apparent and  unpleasant smell.  Significant sanitary  wastewater
contributions to a dry-weather flow will also cause pronounced and distinctive odors.

Color--
    Color is another important indicator of inappropriate discharges, especially from industrial sources.
Industrial dry-weather discharges can have various colors. Dark colors, such as brown, gray, or black,
are most common. For instance, the color contributed  by meat processing industries is usually a deep
reddish-brown. Paper mill wastes are also brown.  In contrast, textile wastes are varied. Other intense
colors, such as plating-mill  wastes, are often yellow. Washing of work areas in cement and stone
working  plants  can  cause cloudy dry-weather discharges. Potential dry-weather sources  causing
various colored contaminated waters from industrial areas include process waters (slug or continuous
discharges), equipment and work area cleaning water discharged to floor drains, and  spills during
loading operations (and subsequent washing of the  material into the storm drains).

Turbidity--
    Turbidity of water is often affected by the degree of gross contamination.  Dry-weather industrial
flows with moderate turbidity can be cloudy,  while  highly turbid flows can be opaque. High turbidity
is often a characteristic  of undiluted dry-weather industrial discharges,  such as those  coming from
some continual flow sources, or some intermittent spills. Sanitary wastewater is also often cloudy in
nature.

Temperature-
    Temperature  measurements  may be  useful in situations where the  screening activities  are
conducted during cold  months, or in areas having industrial activity. It may be possible to identify  an
outfall that is grossly contaminated with sanitary wastewater or cooling water during cold weather and
possibly to conduct  a rough  heat  balance.  Both sanitary wastewater  and  cooling   water could
substantially increase outfall discharge temperatures.  Elevated baseflow temperatures (compared to
baseflows at other outfalls being screened) could be an indicator of substantial contamination by these
warmer source flows.

Floatable  Matter-
    A contaminated flow may also contain floatables (floating solids or liquids). Evaluation of floatables
often leads  to the identity of the source of industrial or sanitary wastewater pollution, since these
substances are usually direct products or byproducts  of the manufacturing process, or distinctive of
sanitary wastewater. Floatables of industrial origin may include substances such as animal fats, spoiled
food  products,  oils, plant  parts,  solvents, sawdust, foams, packing materials, or fuel;  whereas
floatables in sanitary wastewater include fecal matter, sanitary napkins, and condoms.

Deposits and Stains--
    Deposits and  stains  (residue) refer to any type  of coating which remains after a non-stormwater
discharge has ceased. They will cover the area surrounding the outfall and are usually of a dark color.
Deposits and stains often will contain fragments of  floatable substances and, at times, take the form
of a crystalline or amorphous powder. These situations are illustrated by the grayish-black deposits that
contain fragments of animal flesh and hair which often are produced by leather tanneries, or the white
                                              20

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crystalline powder which commonly coats sewer outfalls due to nitrogenous fertilizer wastes.

Vegetation--
    Vegetation surrounding an outfall may show the effects of intermittent or random non-stormwater
discharges. Industrial pollutants will often cause a substantial alteration in the chemical composition
and  pH  of  the discharge.  This  alteration  will affect  plant  growth, even  when the  source of
contamination is  intermittent. For example, decaying organic  materials coming from various food
product wastes could cause  an increase in plant life. In contrast, the discharge of chemical dyes and
inorganic pigments from textile mills could noticeably  stunt  plant growth,  as these dry-weather
discharges are often acidic. In either case, when the industrial pollution constituent in the flow ceases,
the vegetation surrounding the outfall will continue to show the effects of the contamination.

    In order to accurately judge if the vegetation surrounding an outfall is normal, the observer must
take into account the  current weather  conditions, as well as the time of year in the area.  Thus,
flourishing or inhibited plant  growth, as well as dead and decaying plant life, are all signs of pollution
or scouring flows when the  condition of the vegetation  beyond the outfall contrasts with the plant
conditions near the outfall.  It is important not to confuse the adverse  effects  of high storm-induced
flows on vegetation with highly toxic dry-weather intermittent flows. Poor plant  growth could be
associated with scouring flows occurring during storms.

Damage to Sewerage/Outfall Structure--
    Sewerage structural damage is another readily visible indication of both continual and intermittent
industrial dry-weather discharge contamination. Cracking, deterioration, and spading of concrete or
peeling of  surface paint, occurring at  an  outfall are  usually caused by severely  contaminated
discharges, usually of industrial origin. These contaminants are usually very acidic or basic in nature.
For instance, primary metal industries have a strong potential for causing sewerage structural damage
because their batch dumps are highly acidic. However confusion is possible due to the effects poor
construction, hydraulic scour, and old age may have  had on the condition of the outfall structure or
sewerage system.

Chemical Parameters

    Chemical tests are needed to supplement the above described physical inspection parameters.
Chemical tests are needed to quantify the approximate components of a mixture at the outfall. In most
cases, dry-weather discharges are made up of many separate source flows (e.g., potable  water,
groundwaters, sanitary wastewater, and automobile washwaters). Statistical analyses of the chemical
test results can be used to estimate the relative magnitudes of the various flow sources (as described
in Section 6 of this Guide).

Specific Conductivity-
    Specific conductivity can be used  as an indicator of  dissolved solids. Specific conductivity
measurements  can be conducted with relative ease in the field, while dissolved solids measurements
must be made in  a laboratory.

    The literature indicates  that variation in specific conductivity measurements between water and
wastewater sources could be substantial enough to  indicate the source of dry-weather flow  in the
storm drainage system. Specific conductance was judged to be a reliable and  quick field indicator of
general outfall  contamination  in  Toronto (GLA  1983). Observed levels ranged from 25 to 100,000
fjS/cm (microSiemens per cm). Specific conductivity levels less than 1000 /jS/cm indicated significant
levels of rainwater in the drainage. Specific conductivity can be measured quickly, easily and cheaply.
For these reasons, it was selected as a parameter for further study.
                                              21

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Fluoride--
    Fluoride concentration should be a reliable indicator of potable water where fluoride levels in the
raw water supply are adjusted to consistent levels and where groundwater has low to non-measurable
natural fluoride levels. It is common practice for communities to add fluoride to municipal waters to
improve dental  health. Concentrations of total fluoride  in fluoride treated potable waters are usually
in the range of  1.0 to 2.5 mg/L.

    Fluoride measurements have often been used to distinguish treated waters from natural waters.
During the Allen Creek drainage study (Schmidt and Spencer 1986), the fluoride concentrations of
dry-weather flows at outfalls were undetectable after  most of  the  known improper connections to
storm drains were eliminated. Very few of these improper connections were of sanitary wastewater
to the storm drainage. Apparently, most of the non-stormwater discharges were treated potable water.

Hardness--
    Hardness may also be useful in distinguishing between natural and treated waters (like fluoride),
as well as between  clean treated waters and waters that have been subjected to domestic use.

    The hardness of waters varies considerably from place to place, with groundwaters generally being
harder than surface waters.  Natural sources of hardness are  limestones  which are dissolved  by
percolating rainwater made acid  by dissolved  carbon dioxide.  Information regarding  the average
hardness of potable water as well as local groundwater  and surface waters should be readily available
wherever  a public water supply system  exists.

Ammonia/Ammonium--
    As part of the nitrogen cycle,  ammonia is produced by the decay of organic nitrogen compounds.
Ammonia  may then be broken down,  forming nitrites and nitrates.  The  presence  or absence of
ammonia  (NH3), or ammonium ion  (NH4 + ), has been commonly  used as  a  chemical  indicator for
prioritizing sanitary wastewater cross-connection drainage problems.  Correlations between elimination
of improper sanitary wastewater cross-connections into storm drainage and reduced numbers of storm
drainage outfalls with ammonia present were noted in Fort Worth (Falkenbury 1987 and 1988; Moore
and Hoffpauir 1988). During studies in Toronto  (GLA 1983), more "problem" storm drain outfalls had
high ammonia concentrations (>1 mg/L)  than  any other single parameter,  except TKN. During the
Huron River (Michigan) study (Washtenaw Co. 1987 and  1988;  Murray 1985), ammonia levels were
found to be greater at all "problem" storm drain outfalls than at control locations.  However, the Allen
Creek (Michigan)  Drainage study (Schmidt and Spencer 1986) reported that with 92 percent of the
improper  non-stormwater entries  to storm  drains eliminated, the ammonia concentrations did not
change significantly (all  were about 0.44 mg/L). However, very  few of these cross-connection
eliminations were for sanitary wastewater. Ammonia should be useful in identifying sanitary wastes
and distinguishing them from commercial water usage.

Potassium--
    Large increases of potassium  concentrations have  been noted for sanitary wastewater compared
to potable water during studies in California (Evans 1968), Virginia (Hypes, et al. 1975), and Brussels,
Belgium (Verbanck, et al. 1990). These potassium increases following domestic water usage suggest
its potential as a tracer parameter.

Surfactants and Fluorescence-
    Surfactants are discharged from household and industrial laundering and other cleaning operations.
In the  United  States, anionic surfactants are commonly  used   in  detergents and  account for
approximately two thirds of the total surfactants used. Anionic  surfactants  are commonly  measured
as Methylene  Blue Active Substances (MBAS). In raw sanitary wastewaters, surfactants generally
range from 1 to 20 mg/L, while natural waters usually have surfactant concentrations below  0.1 mg/L.
                                             22

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    Large concentrations of surfactants are found in sanitary wastewater,  but some researchers
(Alhajjar, et al.  1989) have reported that they are not found in septic tank effluent. Surfactants can
be totally degraded in the septic tanks. During the Allen Creek drainage study (Schmidt and Spencer
1986; Washtenaw County Drain Commissioner 1984; and Washtenaw County Statutory Drainage
Board 1987), surfactants (as MBAS) decreased significantly after most of the improper non-stormwater
entries  to storm  drains were  eliminated. Surfactants can be used to  identify sanitary or  laundry
wastewater cross-contamination in storm drainage systems. They may also be of use in distinguishing
between infiltrating septic tank  effluent and other washwaters from domestic or commercial cleaning
operations.

    Water fluorescence is also  an indicator of detergent residue in waters. Most detergents  contain
fabric whiteners which  cause substantial fluorescence. Fluorescent indicators remain after sanitary
wastewater   treatment  in  septic  tanks.  Fluorescence in contrast to  MBAS  may be  useful  in
distinguishing between sanitary wastewater contamination and septic tank effluent.

pH-
    The pH  of most uncontaminated baseflows, as well as sanitary wastewater, is usually quite close
to neutral (pH of 7). Therefore, Ph will probably not serve as an indicator of sanitary cross connections.
However, pH values may be extreme in certain inappropriate commercial and industrial flows or where
groundwaters contain dissolved minerals. If unusual pH values are observed, then the drainage system
needs to be carefully evaluated. Very few of the stormwater outfalls tested during dry-weather in Fort
Worth (Falkenbury 1987 and 1988; Moore and Hoffpauir 1988) had pH values either below 6 or above
9. None of the  Toronto  (GLA 1983) "problem" outfalls were reported to have extreme pH values.

    Chemicals (acidic and alkaline) released  into storm drains by chemically-oriented industries are
frequently the cause of  pH fluctuations which can range from 3 to 12.

    Industries  that commonly  release low pH (acidic) dry-weather discharges include (but  are  not
limited to) textile mills, pharmaceutical  manufacturers, metal finishers/fabricators, as well as companies
producing resins, fertilizers and  pesticides. Wastes containing  sulfuric, hydrochloric, or nitric acids are
common industrial sources of low pH  discharges.

    Many industrial wastes contain high  pH  (alkaline) chemicals such as cyanide, sodium sulfide, and
sodium  hydroxide. High concentrations  of these contaminants are found in discharges from soap
manufacturers, textile mills, metal plating industries, steel mills, and producers of rubber or plastic.

Total  Available Chlorine--
    Chlorine can  be  present in water as free available chlorine and as  combined available chlorine
(usually as chloramines). Both types can exist in the same water and be determined together as the
total  available  chlorine. Chlorine is  not stable  in  water,  especially  in  the presence  of  organic
compounds.  Tests of clean potable water during the demonstration project (Pitt and Lalor publication
pending) found that total available chlorine only decreased by about 25 percent in 24-hours during an
aerated bench-scale test. However, the chlorine demand of contaminated water can be very large, with
chlorine concentrations  decreasing to  very small values after short periods of time. Chlorine therefore
cannot  be used to quantify flow sources because of its instability, but the presence of chlorine in
baseflow waters (very unlikely) could  indicate a significant and very close potable water flow source.

Other Chemicals Indicative of Manufacturing Industrial Activities-
    Table 3 is a listing of various chemicals that may  be  associated with  a  variety of different
industrial activities. If the industrial activities in an outfall watershed are known, it may be possible to
examine the non-stormwater outfall flow for specific chemicals (e.g.,  listed in Table 3) to  identify
which industrial activities may  be responsible for the dry-weather flow.


                                              23

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         TABLE 3. SIGNIFICANT CHEMICALS IN INDUSTRIAL WASTEWATERS
Chemical:
Acetic acid
Alkalies

Ammonia
Arsenic
Chlorine
Chromium
Cadmium
Citric acid
Copper
Cyanides

Fats,  oils
Fluorides
Formalin
Hydrocarbons
Hydrogen peroxide
Lead

Mercaptans
Mineral acids

Nickel
Nitro  compounds
Organic acids
Phenols
Silver
Starch
Sugars
Sulfides

Sulfites
Tannic acid
Tartaric acid
Zinc
Industry.
Acetate rayon, pickle and beetroot manufacture.
Cotton and straw kiering, cotton manufacture, mercerizing,
wool scouring, and laundries.
Gas, coke, and chemical  manufacture.
Sheep-dipping, and felt mongering.
Laundries, paper mills, and textile bleaching.
Plating, chrome tanning,  and aluminum anodizing.
Plating.
Soft drinks and citrus fruit processing.
Plating, pickling, and rayon manufacture.
Plating, metal cleaning, case-hardening, and gas
manufacture.
Wool scouring, laundries, textiles,and oil refineries.
Gas, coke, and chemical  manufacture,  fertilizer plants,
transistor manufacture, metal refining,  ceramic plants, and
glass etching.
Manufacture of synthetic resins and penicillin.
Petrochemical  and rubber factories.
Textile bleaching, and rocket motor testing.
Battery manufacture, lead mining, paint manufacture, and
gasoline manufacture.
Oil refining, and  pulp mills.
Chemical manufacture, mines, Fe and Cu pickling, brewing,
textiles, photo-engraving, and battery manufacture.
Plating.
Explosives and chemical  works.
Distilleries and fermentation plants.
Gas and coke manufacture, synthetic resin manufacture,
textiles, tanneries, tar, chemical, and dye manufacture and
sheep-dipping.
Plating, and photography.
Food, textile, and wallpaper manufacture.
Dairies, foods, sugar refining, and preserves.
Textiles, tanneries, gas manufacture, and rayon
manufacture.
Wood process, viscose manufacture, and bleaching.
Tanning, and sawmills.
Dyeing, wine, leather, and chemical manufacture.
Galvanizing, plating,  viscose manufacture, and rubber
process.
Source:  Van der Leeden, et al. 1990.
                                        24

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Toxicitv Screening Tests

    In addition to the  parameters  described above,  relative toxicity can be  an important outfall
screening parameter.  Short-term  toxicity tests, such  as the Microtox™ test  (from Microbics)  are
valuable for quickly and cheaply assessing the relative toxicity (to a selected test organism) of different
storm drain baseflows.  These tests can be used to identify  outfalls that contain flows in the most
serious (toxic) category and that require immediate investigation. These tests are also very useful in
identifying likely sources of toxicants to the drainage system by utilizing a toxicity reduction evaluation
(TRE) procedure in the drainage system. If an outfall contains a highly toxic flow,  then specific metallic
and organic toxicants  can be  analyzed to support source identification.
TRACER CHARACTERISTICS OF SOURCE FLOWS

    Table 4 summarizes the relative concentrations of tracer parameters in source flows. The unique
"fingerprints" of each flow category shown can be used to identify the flow components, as shown
in Section 6. This table also contains redundancies, (e.g., potassium and ammonia) to help identify
sanitary  wastewater and  septic tank effluent. Fluoride and  hardness are similarly used to identify
treated  potable water and surfactant (MBAS) and fluorescent  measurements are used to identify
washwaters.

    Table 5 is a summary of the tracer parameter concentrations found in Birmingham, Alabama, from
April  1991 to September  1992. This table is a summary of the "library" that describes the tracer
conditions for each potential source category. The important information shown on this table includes
the median  and coefficient of variation  (COV) values for  each tracer parameter for each  source
category. The COV is the  ratio of the standard deviation  to the  mean. A low COV value indicates a
smaller spread of data compared to a data set having a large COV value. It is apparent that some of
the abstracted and generalized relationships shown on Table 4 did not exist during the demonstration
project. This stresses the need for obtaining local data describing likely source flows.

    The fluorescence  values shown  on Table 5 are direct measurements from the Turner™  (Model
111)  fluorometer having general purpose filters and lamps and at the least sensitive setting (number
1 aperture). The toxicity screening test results are expressed as the toxicity response noted after 25
minutes  of exposure. The  Microtox™ unit measures the light output from phosphorescent algae. The
I2B value  is the percentage  light output decrease observed after 25 minutes of exposure to the sample.
If an outfall sample has a very high light reduction value, it is typically subjected to  additional organic
and metallic toxicant tests. Fresh potable water has a relatively high response because of the chlorine
levels present. Aged,  or dechlorinated, potable water has much smaller toxicity responses.

    Appropriate tracers are  characterized  by  having significantly different concentrations in flow
source categories requiring identification. In addition, effective tracers also need low COV values within
each  flow category. Table 4 indicates the expected changes  in concentrations per category and Table
5 indicates how these expectations compared with the results of an extensive local sampling effort.
The study indicated  that the COV values were quite low for each category,  with the exception of
chlorine, which had  much greater COV values. The high chlorine COV  values  reinforce what was
previously  indicated  (under  Total Available Chlorine),  that chlorine  is not recommended as  a
quantitative tracer to estimate the flow components. Similar data must be collected in each community
where these procedures are to be used. The following  subsection  discusses how the number of
samples needed per category can be estimated.
                                             25

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                TABLE 4. FIELD SURVEY PARAMETERS AND ASSOCIATED NON-STORMWATER FLOW SOURCE CATEGORIES
Parameter
Fluorides
Hardness Change
Surfactants
Fluorescence
Potassium
Ammonia
Odor
Color
Clarity
Floatables
Deposits/Stains
Vegetation Change
Structural Damage
Conductivity
Temperature Change
pH
Natural
Water
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Potable
Water
+
+ /-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Sanitary
Wastewater
+
+
+
+
+
+
+
-
+
+
+
+
-
+
+ /-
-
Septic
Tank
Effluent
+
+
-
+
+
+
+
-
+
-
-
+
-
+
-
-
Indus.
Water
+ /-
+ /-
-
-
-
-
+
+
+
+
+
+
+
+
+
+
Wash-
Water
+
+
+
+
-
-
+ /-
-
+
+ /-
+ /-
+ /-
-
+ /-
+ /-
-
Rinse
Water
+
+
-
-
-
-
-
-
+ /-
+ /-
+ /-
-
-
+
+ /-
-
Irrig.
Water

+
-
-
-
-
-
-
-
-
-
+
-
+
-
-
0)
         NOTE:
              implies relatively low concentration
           +   implies relatively high concentration
           + /-  implies variable conditions

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TABLE 5. TRACER CONCENTRATION FOUND IN BIRMINGHAM, ALABAMA WATERS
    (MEAN, STANDARD DEVIATION AND COEFFICIENT OF VARIATION. COV)



Fluorescence
(% scale)

Potassium
(mg/L)

Ammonia
(mg/L)

Fluoride
(mg/L)

Toxicity
(% light
decrease
after 25 min.,
I25)
Surfactants
(mg/L as
MBAS)
Hardness
(mg/L)

PH
(pH units)

Color
(color units)

Chlorine
(mg/L)

Spec.
Conduct.
(jjS/cm)
Number of
Samples
Spring
Water

6.8
2.9
0.43
0.73
0.070
0.10
0.009
0.016
1.7
0.031
0.027
0.87
<5
n/a
n/a


<0.5
n/a
n/a
240
7.8
0.03
7.0
0.05
0.01
<1
n/a
n/a
0.003
0.005
1.6
300
12
0.04
10

Treated
Potable
Water
4.6
0.35
0.08
1.6
0.059
0.04
0.028
0.006
0.23
0.97
0.014
0.02
47
20
0.44


<0.5
n/a
n/a
49
1.4
0.03
6.9
0.29
0.04
<1
n/a
n/a
0.88
0.60
0.68
110
1.1
0.01
10

Laundry
Waste-
water
1020
125
0.12
3.5
0.38
0.11
0.82
0.12
0.14
33
13
0.38
99.9
<1
n/a


27
6.7
0.25
14
8.0
0.57
9.1
0.35
0.04
47
12
0.27
0.40
0.10
0.26
560
120
0.21
10

Sanitary
Waste-
water
250
50
0.20
6.0
1.4
0.23
10
3.3
0.34
0.77
0.17
0.23
43
26
0.59


1.5
1.2
0.82
140
15
0.11
7.1
0.13
0.02
38
21
0.55
0.014
0.020
1.4
420
55
0.13
36

Septic
Tank
Effl.
430
100
0.23
20
9.5
0.47
90
40
0.44
0.99
0.33
0.33
99.9
<1
n/a


3.1
4.8
1.5
235
150
0.64
6.8
0.34
0.05
59
25
0.41
0.013
0.013
1.0
430
311
0.72
9

Car
Wash-
water
1200
130
0.11
43
16
0.37
0.24
0.066
0.28
12
2.4
0.20
99.9
<1
n/a


49
5.1
0.11
160
9.2
0.06
6.7
0.22
0.03
220
78
0.35
0.070
0.080
1.1
485
29
0.06
10

Radiator
Flush
Water
22,000
950
0.04
2800
375
0.13
0.03
0.01
0.3
150
24
0.16
99.9
<1
n/a


15
1.6
0.11
50
1.5
0.03
7.0
0.39
0.06
3000
44
0.02
0.03
0.016
0.52
3300
700
0.22
10

                              27

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Determining Number of Observations Needed

    It is very important to determine the number of observations needed for each tracer parameter for
each source  category  in order to build a useful  data  library for analyzing the  outfall data. This
determination is a function of the tolerable error level in the data means and the standard deviations.
The following paragraphs briefly describe a method that can be used to estimate the sampling effort
needed to develop a useful library of source characteristic data.

Estimating Errors--
    One equation that can  be used to calculate  the number of analyses needed, based  on the
allowable error is  (Cochran 1963):

Number of samples  = 4(standard deviation)2/(allowable error)2

With a 95 percent level of confidence, this relationship determines the number of samples needed to
obtain a value within the range of the sample mean, plus and minus the error. Similarly, this equation
can be used  to predict  the 95 percent confidence interval, based on the measured (or estimated)
standard deviation and number of samples obtained:

       Error  =  2(standard deviation)/(number of samples)0 5

where the confidence interval is the mean plus and minus the calculated error value.

Example of Log10  Transformation-
    These equations  assume a normal distribution of the data. However,  most water quality data
needs to be log 10 transformed before a normal distribution is obtained. As an example, consider a tracer
having a COV of 0.23 and a median value of 0.14.  The resulting Iog10 transformed standard deviation
would  be  about 0.12. For ten samples, the resulting 95 percent confidence range of the  median
observation (0.14 mg/L) is:

    Error  = 2(0.12)/(10)05 =  0.076 in Iog10 space

The confidence  interval is therefore loglo(0.14)  +/- 0.076, which is -0.778 to -0.930 in Iog10 space.
This results in a  conventional 95 percent confidence range of 10~°-930 (= 0.12) to 10~°-778 (= 0.17). The
error in the estimate of the median value is therefore between 14 and 21 % for ten samples. If the
original untransformed data were used, the error associated with 10 samples is 15%, within the range
of the estimate after log transformations. These results are close because of the low COV value (0.23).
If the COV value  is large, the need for log transformations increases. Figure 3 (Pitt 1979) shows the
approximate sample size needed to obtain different allowable errors for different COV values (using
nontransformed data).

    The COV value in the above example (0.23)  was close to the  median COV value for all of the
source categories and tracer parameters shown on Table 5. Therefore, about 10 samples per source
flow category should generally result in less than a 25 percent error for the median values obtained.

    As shown  in a later section,  narrow confidence intervals are needed in order to estimate the
relative mixes of the non-stormwater sources as measured at the outfall. Therefore, much care needs
to be taken in order to estimate the characteristics of the potential non-stormwater  flow sources,
especially the COV values and medians.
                                             28

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             10.0
         CO

        1
        .0
        .2
        CO
        t)

        o
        is
        0)
        i
        0)
        8.

        I
              0.1
                                        0.05
                                        (5%)
 0.1

(10%)
0.25
(25%)
                               Allowable error as a fraction of the mean
                Figure 3. Required number of samples for allowable error and COV


Source: Pitt 1979
                                              29

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    Understanding the mechanisms affecting the non-stormwater sources (e.g., time of day, season,
area of town, type and magnitude of land use activities, etc.) and obtaining a relatively large data base
library for the source flow tracer concentrations is very important and should be a significant portion
of a dry-weather flow source identification project.
SELECTION OF ANALYTICAL METHODS

    The selection of the analytical procedure to be used is dependent on a number of factors, including
(in order of importance):

       appropriate detection limits
       freedom from interferences
       good analytical precision (repeatability)
       low cost and good durability
       minimal operator training required

The  following sub-sections discuss these requirements and present the recommended  analytical
procedures. Tracer characteristics in potential local source flows affect most of these requirements.
Therefore, the suggested analytical procedures may not be the most cost-effective for all areas.

Detection Limit Requirements

     In order to identify potential non-stormwater sources, it is necessary to have a basic knowledge
about each potential source flow. As shown earlier, a significant sampling and analysis effort is needed
to develop  a  library  of  source  flow tracer concentrations. The  COVs and  means of the tracer
concentrations are needed to estimate the detection limits required by the analytical procedures.

     There are a number of different  types  of detection  limits  defined for laboratory use.  Most
instrument manufactures present a minimum readable value as the instrument detection  limit (IDL) in
their specifications for simple test kits. The usual definition of IDL, however, is a concentration that
produces  a signal to noise ratio of five. The method detection limit (MDL) is a more conservative value
and is established for the complete preparation and analysis procedure. The practical quantification limit
(PQL)  is higher yet and  is defined as  a routinely achievable detection  limit with a  relatively good
certainty that any reported value is reliable. Standard Methods (APHA, et al. 1989)  estimates that the
relationship between these detection limits is approximately: IDL:MDL:PQL =  1:4:20. Therefore, the
detection  limit shown in much of the manufacturer's literature is much less than what would be used
by most analytical laboratories.

     Because of the screening nature of the outfall field surveys, the instrument detection capabilities
are appropriate for the methodology described in this Users' Guide. The larger uncontrollable errors
associated  with  obtaining  representative outfall  samples  and  in  the  variations of the  tracer
concentrations in the potential source  flows  would  tend  to  diminish the  significance  of errors
associated with reading concentration values from the instrument that are lower than the PQL.

     A quick (and conservative) estimate of the needed detection limit can be made by only knowing
the median concentration and the concentration variation of the tracer in the least contaminated
component flow. Any amount of another component having a greater tracer concentration  will increase
the tracer concentration of the mixture. By ignoring this increase, minimum detection limits can be
estimated based on the numerous probability calculations presented in the background demonstration
project report (Pitt and Lalor publication pending):
                                              30

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       COV value:           Multiplier for detection limit:

       <0.5 (low)                  0.8
       0.5 to 1.25 (medium)        0.23
       >1.25 (high)                0.12

As an example, if the baseflow tracer has a low COV «0.5), then the estimated required detection
limit is about 0.8 times the median tracer concentration.

     More than 80 percent of the library categories (source flows and tracers) examined in Birmingham,
Alabama during the demonstration of these procedures (shown on Table 5) had low COV values. About
15 percent had medium COV values, and about 5 percent had high COV values. Free available chlorine
had medium or high COV values for almost all source categories. This is a major reason why chlorine
is not used quantitatively to identify source flow components in  outfall samples. Chlorine is used in a
similar manner as an aesthetic parameter (e.g.,  turbidity or odor). If high chlorine concentrations are
found at the outfall (greater  than  about 0.5 mg/L), then  a major treated potable water leak is likely
associated  with the dry-weather flow.

     Table 6 lists the detection limit requirements for the tracer parameter concentrations found during
the Birmingham, Alabama, demonstration project. The recommended analytical methods satisfy most
of the required detection limits, except for ammonia and  surfactants in spring water  and surfactants
in potable water. The spring water ammonia  concentrations were about equal to the detection limit,
but because the variation in the ammonia concentrations  were so large, a much lower detection limit
would be preferable.

     Figures 4 through 7 are probability plots  showing  the required analytical detection limits for
mixtures of two source area flows both having low COV values (similar to the majority of expected
conditions). Pitt and Lalor (publication  pending) present similar plots for all possible  combinations of
COV values. These figures show four curves corresponding to four mixtures.  PER100 is for a 100
percent solution of the flow having the higher tracer concentration,  PER50 is for a solution having 50
percent each of two components, PER15 is for a solution of 15 percent of the component having the
higher tracer concentration and 85 percent of the component having the lower tracer concentration,
while PERO is a solution only made of the component having the lower tracer concentration.  Figure 4
is for two components that have mean concentrations differing by 1.33 times, Figure 5 is for a mixture
where the component mean  concentrations differ by five  times,  Figure 6 is for two components with
mean concentrations  differing  by 20 times,  and Figure 7  is for two components with  mean
concentrations differing by 75 times. Each figure shows the detection limits, relative to the lower base
concentrations, for different  probability of detection values. The detection limits required are reduced
significantly as the means of the tracer components differ  by greater amounts, especially for low
probabilities of detection.

     For example, if the two tracer mean concentrations vary by about five times (e.g., treated potable
water and sanitary wastewater potassium concentrations from Table 5) and a mixture of 15 percent
sanitary wastewater and 85 percent potable water needs to be identified with  a 90 percent probability
of detection, the required detection limit would be about:

       1.4 [factor from Fig.5] x 1.6mg/l  [potassium in treated potable water  Table 5] = 2.2 mg/L

The more conservative approach stated above would result in a minimum detection limit of:

       0.8 [factor for COV < 0.5] x 1.6mg/l =  1.2 mg/L.
                                             31

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TABLE 6.  DETECTION LIMIT REQUIREMENTS FOR TRACER CONCENTRATIONS FOUND IN
                      BIRMINGHAM, ALABAMA WATERS
Tracer Parameter
and
Units
Fluorescence
% of full scale
Potassium
mg/L
Ammonia
mg/L
Fluoride
mg/L
Surfactants
mg/L as MBAS
Hardness
mg/L as CaC03
Color
HACH™ color
units
Specific
Conductivity
/vS/crn
Median Cone. (mg/L) of Least
Contaminated
Sources: median (COV)
Potable water: 4.6 (0.08)
Spring water: 6.8 (0.43)
Spring water: 0.73 (0.10)
Potable water: 1 .6 (0.04)
Spring water: 0.01 (1.7)
Potable and Radiator water:
0.03 (0.23)
Spring water: 0.031 (0.87)
Sanitary wastewater: 0.77
(0.23)
Spring and potable water: < 1
Sanitary wastewater: 1.5
(0.82)
Laundry water: 14 (0.57)
Potable and radiator water:
49 (0.03)
Spring and potable water: < 1
Sanitary wastewater: 38
(0.55)
Potable water: 110 (0.01)
Spring water: 300 (0.04)
Required
Detection Limit
3.7
5.4
0.58
1.3
0.001
0.024
0.01
0.62
0.35
3.2
39
8.7
88
240
Available
Detection
limit111
0.1
0.01
0.01
0.01
0.01
1
1
10
(1) From anlaytical methods discussed under: "Recommended Analytical Methodology"
                                    32

-------
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       Figure 4. Required detection limits for low COV mixture

          components having means differing by 1.3 times.
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         Figure 5. Required detection limits for low COV mixture

            components having means differing by 5 times.
100
                                33

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      Figure 6. Required detection limits for low COV mixture

         components having means differing by 20 times.
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40
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       Figure 7. Required detection limits for low COV mixture

          components having means differing by 75 times.
                               34

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    Even with the above analytical requirements satisfied, it may still be difficult to precisely estimate
the degree  of contamination, especially for low contamination levels and for high COVs. The ratio of
the tracer concentration in the contaminating source flow to the tracer concentration in the cleaner
baseflow must increase as the desire to detect smaller contaminating source flows is required. Listed
below, for  90  percent confidence levels and low COV values, are percentages of source flow in the
baseflow and  the corresponding minimum  concentration ratios  (source to clean  baseflow tracer
concentrations) required for the detection of the source flow contamination  of the baseflow.

    Percent of Source Flow                        Required concentration ratios
  Contamination in Baseflow:                       (low COV values):

               1%                                        50
               5%                                        10
               10%                                        7
               25%                                        3
               35%                                        1.5
               50%                                        1.2

     As an example, the median tracer concentration in the contaminating source flow must be about
 10 times greater than the median tracer concentration in the cleaner baseflow to  detect a five percent
 source flow contamination  of the baseflow.  If the tracer COV values are "medium" or "high", then the
 required concentration differences are much greater (up to 250 times difference in concentrations may
 be required).

     Therefore, the differences in tracer concentrations must be quite large, and the COVs quite small,
 in order to have confident estimates of low levels (percentages) of contaminating source flows. Few
 tracers exhibit such a wide  range in characteristics between source flow and baseflow categories. This
 is the main reason why the use of multiple tracers for source flow identification is  important. Some
 tracers may not uniformly  produce good estimates of contaminating source flow levels, but the use
 of redundant tracers  for  the same decision (e.g., ammonia  and potassium  to  identify  sanitary
 wastewater; fluorides and hardness to identify treated potable water; and surfactants and fluorescence
 to identify wash waters) and good estimates of local contaminant characteristics, will minimize these
 errors.

     The actual minimum level of contaminating source flow that will be detectable will be dependent
 on the  analytical precision, as discussed next.

 Required Sample Analytical Precision

     The repeatability of the analytical method is an important consideration in its selection. Precision,
 as defined in Standard Methods (APHA, et al. 1989), is a measure of the closeness with which multiple
 analyses of a given sample agree with each other. It is determined by repeated analyses of a stable
 standard,  conducting replicate analyses on the samples, or by analyzing known standard additions to
 samples. Precision is  expressed  as the standard deviation of the multiple analysis results.

     Figure 8 is  a summary of  the  probability plots from  Pitt and Lalor (publication  pending)  and
 indicates the needed analytical precision (repeatability) as a fraction of the median tracer concentration
 (i.e., the  flow with the lower tracer  concentration) to  resolve one  percent contamination of the
 baseflow  by the source flow, at a  90  percent confidence level. This figure was developed for COV
 values of  the tracer parameters in the contaminating flows ranging from 0.16 to 1.67.
                                              35

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                        Figure 8. Analysis precision needed for detection of one percent contamination
                                            at ninety percent confidence.

-------
    If the available analytical precision is worse than these required values, then small contaminating
flow levels may not be detected.  Therefore, even with adequate analytical detection  limits, poor
analytical precision may not allow adequate identification of low levels of contaminating flow. In many
cases, it is expected that a contaminating flow level of just a few percent can cause significant toxic
and pathogenic  problems.  Examples  include gasoline  spills, direct  connections of raw  sanitary
wastewater, and metal plating bath wastewaters.

    If the tracer concentrations of the flow components are close in value and the variation of the
concentrations are high, then it will be  very difficult to adequately discern flow  components. In
contrast, if the tracer concentrations of the  flow  components  are  widely different and have  low
variabilities, then much smaller levels of contaminating flows could be detected. As an example, if the
median  contaminant tracer concentrations differ by a factor of 10 in two flow components, but have
high concentration variations (high COV values), a precision of between 0.015 to 0.03 of the lower
baseflow median tracer  concentration is needed, for each percent of contaminating flow that needs
to be detected.  If the  median tracer  concentration in the cleaner baseflow is  0.15 mg/L (with a
corresponding tracer median concentration of 10 times this amount, or 1.5 mg/L, in the contaminating
source flow), then the required analytical precision  is about 0.015 x 0.15 =  0.002 mg/L to 0.03 x
0.15 = 0.005 mg/L per one percent of contaminating flow to be detected. If  at least five percent of
contaminating flow is needed to be detected, then the minimum precision would have to be 5 x 0.002
= 0.01 mg/L.

    The conservative  method noted  previously can  be  used   to  estimate the  detection limit
requirements for the above example:

    low COV in the cleaner baseflow:  0.8 x 0.15 mg/L  =  0.12 mg/L
    medium  COV in the cleaner baseflow: 0.23 x 0.15 mg/L = 0.035 mg/L
    high COV in the cleaner baseflow: 0.12  x 0.15 mg/L = 0.018 mg/L.

The required analytical  precision  would  therefore  be about one-half  of the  lowest detection limit
needed, and about 1/12 of the largest estimated required detection limit.

Recommended Analytical Methodology

    An important part of the development of these investigation procedures  and the demonstration
project  (Pitt and Lalor publication pending) was the laboratory and field testing of alternative analytical
methods.  Dry-weather outfall samples were  subjected to different  tests which compared several
analytical  methods for each of the major tracer parameters of interest.  Tests were conducted to enable
comparison of the results of alternative tests with standard procedures and to identify which methods
had suitable detection limits, based on real samples. In addition, representative samples were further
examined using standard addition methods (known amounts of standards added  to the sample and
results compared to unaltered samples) in order to identify matrix interferences. Matrix interferences
are generally caused by contaminants in the samples interfering with the analysis of interest. Many of
the analysis  methods were also tested against a series of standard  solutions to identify analytical
precision  (repeatability), linearity, and  detection  limits. The following  paragraphs (and Table 7)
summarize the recommended analytical procedures.

    Most of the recommended analyses are conducted using small "field-type" instruments. However,
despite their portability, the  use of these  instruments in  the  field can introduce many errors.
Temperature and specific conductivity are the only analyses that are recommended for field analyses.
For the other analyses,  samples are collected at the site, iced, and taken back to the laboratory for
analyses.  The recommended analytical procedures can be easily conducted in a temporary laboratory;
all that is needed is a work space and adequate ventilation. Access to power and water  would be


                                             37

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        TABLE 7.  SAMPLE ANALYSES LAB SHEET
Sample number:.




Date:	
Location:
Outfall #:_
Specific conductivity YSI™  SCT meter (field).




Temperature YSI™  SCT meter (field)	




pH  pH meter (lab)	
Ammonia Direct Nesslerization (lab)_




Color HACH™  color kit  (lab)	
Fluoride HACH DR/2000™ spect. with AccuVacs™ (lab).




Hardness HACH™ field titration kit (lab)	
Surfactants HACH™ detergent field kit (lab).




Fluorescence Turner™ fluorometer (lab)	
Potassium HACH DR/2000™ spect. (lab).




Turbidity HACH™ Nephelometer (lab)	
Chlorine HACH DR/2000™ spect. with AccuVacs™ (lab).




Toxicitv Microtox™ 100% sample screen (lab)	
                               38

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helpful,  but all of the equipment can be operated with batteries. At each outfall, a (2  L) sample of
dry-weather discharge needs to be collected and stored in a polyethylene container. Another (500 mL)
sample can also be collected in  a glass container having a Teflon-lined lid for toxicity screening and
selected toxicant analyses. All samples must be analyzed (or extracted)  within accepted time limits.

    Descriptions of the procedures and parameters recommended for the analysis and  identification
of dry-weather outfall samples are:

Water color-
    Determine in the laboratory using a simple comparative colormetric (color wheel) field test kit from
the HACH Company. Apparent color (unfiltered samples), expressed in HACH color units.

pH-
    pH  is measured in  the laboratory using a standard laboratory pH meter after accurate calibration
using at least two buffer solutions bracketing the expected sample pH value. (pH measurements using
pH test  paper have been found to be generally within one unit of the laboratory meter. However, this
difference is too large and is not recommended. Small  "pen" pH meters most suitable for field use can
easily be off by a 0.5 pH unit and are relatively hard to calibrate. They accordingly  must  be used with
care.)

Specific conductivity and temperature-
    These parameters  are quickly and easily measured in the field using a multi-parameter SCT meter
from YSI model 33. Both specific conductivity and temperature  must be calibrated against  standard
specific conductivity solutions  and  a standard  thermometer. Specific conductivity should also be
corrected to standard values obtained at 25°C (APHA, et al. 1989):

    K  = (KmC)/[1 +0.0191(1-25)]

       where K = specific conductivity at 25°C

              Km  = measured  specific conductivity at temperature t°C

       and    C = cell constant

The cell constant is a correction factor determined by measuring a 0.01 M KCI solution at  25°C, after
three rinses,  compared to  1413 //S/cm, the expected  value. This  equation  results in about a 2%
change in specific conductivity for every degree in temperature difference from 25°C. The International
System of Units (Systeme International d' Unites, SI) specific  conductivity unit of measurement is the
fjS/cm which is numerically equivalent to the U.S. Customary unit, ^mhos/cm.

Fluoride-
    Easily analyzed in the laboratory using  a field spectrophotometer  and evacuated reagent and
sample  vessels  (HACH  DR/2000™ and  AccuVac™  ampules  using  SPADNS reagent,  without
distillation). The AccuVac™ procedure works well for  sample concentrations less than 2.5 mg/L;
however, in rare instances of higher concentrations, sample dilution  is required because of non-linear
instrument responses. The  samples should be filtered through a  0.45 jj  membrane  filter (e.g.,
Millipore™ filter) before analysis to minimize  color interference.  (Specific-ion  probes were  also
evaluated, but  the technique proved to be  too inconsistent, especially for  personnel having little
training.)
                                             39

-------
Ammonia--
    Easily measured in the laboratory using a direct Nesslerization procedure and spectrophotometer
(HACH DR/2000™ Nessler method, but without sample distillation). The samples  should be filtered
through a 0.45 fj membrane filter before analysis to minimize color interference. (The use of various
indicator test papers and simple field test kits  for  ammonia  determination  gave poor  results.
Specific-ion probes were also tested.  Typical problems encountered for these procedures, (except for
the direct Nesslerization procedure), were color interferences, long analysis times, inconsistent results,
and poor performance when standard solutions were analyzed.)

Potassium--
    Measured in the laboratory either  using a spectrophotometer (HACH DR/2000™ Tetraphenylborate
method), or a flame atomic absorption spectrophotometer (if available). The samples should be filtered
through a 0.45 fj membrane filter before spectrophotometric analysis to minimize color interference.
(Specific-ion probes were  also evaluated and indicated the same poor results found for fluorides and
ammonia.)

Surfactants--
    Measured in the laboratory using  a simple comparative colormetric (color wheel) method (from the
HACH Company). The samples should be filtered through a 0.45 p membrane filter before analysis to
minimize color interference.  This procedure should be carried out  under  a laboratory fume  hood.
(Specific-ion probe titrations for surfactants were not successful because of poor detection limits.)

Fluorescence--
    Analyzed using a laboratory fluorometer (Turner model 111). The fluorometer had general purpose
filters and lamps and was operated at the  most sensitive setting (number one aperture).

Hardness--
    Determined in the laboratory using a field-titrimetric kit (HACH Digital Titrator Model  16900). The
samples should be  filtered  through  a 0.45 fj membrane filter  before analysis to minimize  color
interference.  (A number of simple field test kits were tested but the direct reading titration method
proved  most convenient  and accurate. However, hardness test paper can be used to estimate the
titration end point.)

Turbidity-
naity-
Determined using a HACH Nephelometer in the laboratory.
Chlorine-
     Total available chlorine was determined with the DPD (N, N-diethyl-p-phenylenediamine) method
using a HACH DR/2000™ spectrometer with AccuVac™ ampules.

Toxicity-screening-
     Toxicity screening tests have been found to be very useful as indicators of contamination of storm
drains. The Microtox™ (from Microbics) toxicity screening test can be used for relative toxicity values.
The 100  percent  screening test was most commonly used. If the light output decrease after 25
minutes (the I25 value) was greater than 50 percent, then the standard Microtox test was used to
determine the sample dilution required for a 50 percent light decrease (the EC50 value).  If a sample
results  in a large  toxic response, then specific toxicant analyses (organics and metals) could  be
performed to better identify the toxicant source. In general, the Microtox™ screening test was found
to be an efficient  method for toxicity analysis, particularly for identifying samples requiring further
analyses.  (A number of simple test kits were used for specific heavy metal analyses, but with very poor
results. High-detection limits and interferences make these methods impractical,  unless an outfall  is
grossly contaminated  with a concentrated source, such as raw plating bath wastewater.)


                                             40

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                                         SECTION 5

                       INITIAL FIELD SCREENING SAMPLING ACTIVITIES
SAMPLING STRATEGY

    The importance of sampling all outfalls, regardless of size, should be stressed. Figure 9 shows the
distribution of outfalls for the Birmingham, Alabama area surveyed for the city's stormwater discharge
permit application. The median equivalent diameter of the 566 outfalls that had drainage area estimates
available was 36 in. About 20 percent of the outfalls were greater than 60 in. in diameter and about
20 percent were less than 20 in. in diameter. Most of the  largest outfalls were  actually  drainage
ditches. There was an average  of about 70  acres draining to each outfall, but  the drainage areas
ranged from much less than one  acre to over 1500  acres. About 40 percent  of the outfalls were
affected by either commercial or industrial land uses and would therefore be considered as critical
drainage areas for both dry-weather flows and stormwater runoff.

    The Birmingham, Alabama demonstration project that tested this protocol covered a residential
and commercial drainage area having approx.  70 outfalls. The  median outfall size of the outfalls in this
study area was 16 in., and more than 75 percent of the outfalls were less than 36 in. in diameter.
Examination of the outfalls during seven separate sampling occasions found that while some of the
dry-weather flows  occurred intermittently, most were continuous.  About 25  percent of the outfalls
were  found to be consistently flowing during dry weather, with about two-thirds of the flows
discharging from pipes that were less than  36 in. in diameter. About five percent of the outfalls
exhibited dry-weather flows which were extremely toxic or were raw, undiluted, sanitary wastewater.
Each of these contaminated outfalls were 20  in., or less, in diameter. Some of the worst dry-weather
flow discharge problems were associated with very small (4  in.  diameter)  pipes draining automobile
service areas adjacent to the receiving water.  It was found that small outfalls can contribute significant
pollutant loads to receiving waters and should  not be neglected  if receiving water improvement is a
serious goal.

FIELD DATA COLLECTION

    Before the field data  can be collected,  preliminary mapping and land  use evaluation work is
needed. Section 3 described the preliminary work and the likely data sources for the information that
is needed before the field investigations can begin. The most important preliminary information required
is:

     • outfall locations,
     • outfall drainage areas,
     • commercial and industrial activities in each drainage area, and
     • locations of septic  tanks in the individual drainage areas.
                                             41

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                                   42

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Outfall Locations

    Frequently,  city maps of known outfall locations are inadequate. Many outfalls are not located on
city drainage maps because of infrequent or improper updating, or unauthorized installations. Because
it is very difficult for communities to maintain up-to-date maps of drainage facilities, actual stream
surveys are needed to verify and update existing information. Illicit outfalls will not usually be shown
on maps, and field surveys will be required to detect these as well.  Most newer developments do have
accurate drainage and outfall maps, but the  outfall locations  may not have been transferred to an
overall city map. A  few cities have Geographic Information Systems (GIS) in place and are including
the storm drainage systems on appropriate data overlays. It is important to identify all outfalls because
present data indicates  no relationship between the  most significant sources of  non-stormwater
discharges and the  largest drainage areas, or  the largest diameter  outfalls.

    Because of the likelihood  of poor data concerning  the  outfall  locations, it will probably be
necessary to "walk" the creeks and actively look for outfalls. In most cases, it requires several trips
(about three) to  locate all outfalls. The initial outfall surveys should be conducted  during times when
riparian vegetation is minimal. Whenever an outfall is located, it needs to be marked  (coded using spray
paint  or by other means).

    If the receiving water is a small creek, it can  be waded in a downstream direction. If the receiving
water body cannot  be waded, a small boat or canoe can be used to look for outfalls above the water.
Submerged outfalls are more difficult to find and require more careful inspections for storm drain
manholes along the  shore. In flood or estuary tidal areas, surveys should be conducted during low tides
when more outfalls are likely to be exposed.  In many cities, streets parallel the banks of creeks or
drainage canals  that contain outfalls. It may be possible to carefully search the opposite bank from a
moving automobile. It may also be cost-effective to use  light aircraft (including helicopters) to search
for outfalls. Submerged outfalls could be easier to identify from the air than from  the water in cases
where discharge plumes are visible.

    Obviously,  outfall characterizations should be conducted during these surveys,  if possible. In all
cases, at least two people are needed to look for outfalls, especially if wading a creek. Another person
can drive a shuttle car to a convenient downstream location for crew rotation.

Field Survey

    The main elements of the field sampling plan are  the  collection of necessary information and
equipment, and  preliminary screening of outfalls.

Collect necessary information and equipment-

    Maps-Maps are  the  most important part of the  field equipment. Adequate  field  maps can be
prepared by enlarging standard USGS 7-1/2 minute quadrangle maps to appropriate  scales. In addition,
detailed street maps are also needed to locate specific  street crossings and to identify locations of
outfalls in the field.

    Field sampling and analysis  equipment-Table 8  lists the equipment that is  needed  for a field
survey. In  no case should personnel conduct the field surveys alone, wade streams without wearing
waders, or be in boats without wearing life preservers.  Heavy duty waders (heavy Cordura™ nylon)
are preferred.  Urban streams contain appreciable debris  (broken bottles, etc.). In addition, urban
                                              43

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                     TABLE 8.  FIELD  EQUIPMENT LIST
Temperature and specific conductivity meter.

Field notebook containing maps and non-stormwater flow evaluation field sheets.

Waterproof marker/pen.

Camera and film.

Spray paint.

Tape measures (both 3m and 30m).

Flashlight.

Watch (with second hand).

Glass sample containers with waterproof labels (500 ml).

Plastic sample containers with waterproof labels (1 to 2 L).

Ice boxes with ice (left in vehicle).

Backpack.

Grab water sampler (dipper on long pole).

Hand operated vacuum pump sampler for shallow flows.

Waders and walking stick.

First aid kit and pocket knife.

Self protection pepper spray.

Two-way radios for communication between field crew and van driver.

Hand held GPS (global  positioning satellite) system  receiver  (only capable of locating
positions within about 100 to 350 feet).
                                       44

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streams are isolated wildlife areas which tend to concentrate certain wildlife species that live in close
proximity to man (including cottonmouths, water moccasins, copperheads, and rattlesnakes), plus
contain lush growths of poison ivy or oak. The self protection pepper spray may be especially handy
in case of harassing dogs.

    This equipment would supplement needed boating equipment, if boats are used. Some of this
equipment  (ice coolers and ice, along with extra bottles) would be kept in the vehicle. In  most cases,
the vehicle should be  moved  in about 1/2 mile increments. This length would typically contain up to
ten outfalls, with relatively few flowing outfalls to sample. The collected samples would  therefore be
iced within about 1/2  hour of collection. It is possible that the vehicle driver could conduct critical
analyses (chlorine, pH and ammonia) while waiting. It is suggested that a three person  crew rotate,
with a new driver at each new shuttle location.

    Arrange for lab testing and other support equipment-Before the field crew  goes into the field to
collect samples, the laboratory needs to be notified and ready to analyze the  samples soon  after they
are available.  As shown in the next section, the laboratory testing procedures for the  basic  tracer
parameters are all simple and can be conducted in an unsophisticated  laboratory. It may be feasible
for the field crew to conduct the sample analyses  in the afternoon of the day  when they are collected.

Preliminary screening  of outfalls-

     Location of outfalls-Outfall locations need to be transferred to field maps and the daily activities
planned. The number of outfalls that can be  visited and sampled in a  single  day is highly dependent
on  outfall accessibility and mobility along the receiving water. The initial survey requires the longest
time, after which repeated surveys require much less effort. In a small  creek having  shallow and slow
water with numerous  road crossings, about three miles of creek can be walked (with about 40 outfalls
visited and ten outfall samples obtained) in  a half-day of field activity with  a crew of three people.
Most other conditions would  require additional labor for the same sampling effort. In all cases, careful
planning, especially having an idea of where  the outfalls are located, would  greatly reduce the labor
involved.

     Scheduling field  surveys-It is important to schedule the field surveys  during low  water  levels
(during low tides or low flows) because outfalls could be submerged and concealed  during high  water
conditions. It is also best not to conduct  the field surveys during periods of high flow in the receiving
waters because of safety concerns.

     Field surveys which are timed  (diurnally, or  seasonally) to coincide with periods with a greater
potential for non-stormwater entries, are likely to reveal more dry-weather discharges. As  examples,
morning periods  (or in areas of tourism, during the tourist season) usually  experience  the greatest
sanitary wastewater flows. Scheduling sampling during these morning hours would be most successful
in identifying  sanitary wastewater contamination of the storm drainage system. Many inappropriate
industrial entries to the storm drainage system also occur on a scheduled basis, e.g., cleaning up work
areas between work shifts, or increased wastewater flows during periods of the year when the specific
industry is especially  busy. Again, investigating potentially affected storm drain outfalls  during these
critical periods would result in better data.

     The field  survey  schedule will need to be flexible to avoid sampling during and immediately after
a  storm event,  to ensure  only dry-weather  flows are recorded.  In most urban areas storm  runoff
drainage flows will cease within 12 hours following the storm event, but this will need to be reviewed
for each watershed area. The time to flow through the upstream drainage system and any detention
and subsequent release of the storm water could extend this 12 hour period.  This subject is discussed


                                              45

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further under Section 5, Irregular Flows.

    Sampling techniques-After an outfall is located, it is labeled with paint or marked by other means
and the form shown on Table 9 is completed in the field. Table 10 describes the physical observation
choices, previously discussed  in Section 4. The use of field sheets  and laboratory record keeping is
very important because of the large number of outfalls that will likely be surveyed in each municipality.

    Table 9 is a field sheet that can be used to record the observations and analytical results for the
outfall survey. The top of the sheet includes basic outfall descriptive and weather information, a flow
rate estimate, and an indication  if industrial or commercial activities are known to occur in the area.
The physical observation data section requires simple circling of the most appropriate value, or writing
in another response. Samples should be obtained of floatable  and staining  materials  for  further
laboratory microscopic analyses. If unusual vegetative conditions or damage to structures are found,
then the extent and appearance of the damage should be described.  In all cases, several photographs
need to be taken of outfall conditions for each site visit. The analyses results are written on the form,
along with a short descriptions of the equipment used.

    Flows are estimated and visually characterized for each outfall  visit.  Field temperature and specific
conductivity  measurements are made in  the  field, and dry-weather discharge water samples are
collected for later (same day)  laboratory analyses. A single water sample (1 to 2 L) is sufficient for
almost  all analyses that  may be conducted  on the sample.  This sample can be  collected in  a
polyethylene collapsible container. In addition, another (500 mL)  sample can be collected in  a glass
bottle (having a Teflon lined lid) if a toxicity screening procedure (like  Microtox™) and selected organic
tracers are to be analyzed. Specific sample volume requirements need to be determined in conjunction
with the laboratory personnel. Excess samples should be placed in  smaller polyethylene bottles and
frozen for potential future analyses (e.g., heavy metals and major ions).

    Sample preservation-Usually icing of samples after collection and  same-day laboratory analyses
is adequate. Ammonia, chlorine, and pH are susceptible to change with  time and special tests may be
needed to determine the tolerable delay before laboratory analyses. As noted previously, it is not
efficient to analyze the samples  in the field, especially after each sample is collected.

    Field  tests-The only tests recommended for field  analyses are temperature and  specific
conductivity.  If a  multi-purpose  temperature/specific  conductivity meter  is  being used  for  the
temperature analyses, then both can be easily determined in the field.

    Record keeping, sample preservation,  and analyses-As noted  above, the collected water samples
need to be analyzed soon after collection. A central laboratory is much more effective than trying to
analyze each sample in the field as it is collected. Section 4 presents the recommended laboratory
procedures.

Data analyses-

    Identification of contaminated outfalls-Section 6 describes several methods to identify the likely
components  in each flowing  outfall. This information  is  then  used to identify the contaminated
dry-weather flows.

    Isolation and correction of contaminating flow sources-After the problem  outfalls are identified,
drainage system surveys are used to find the sources of the contaminating flows. These procedures
are briefly discussed later in this User's Guide.
                                              46

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                 TABLE 9. SAMPLE EVALUATION SHEET
Outfall #	  Photograph #	  Date:

Location:	
Weather: air temp.:	°C   rain:  Y  N   sunny    cloudy

Outfall flow rate estimate:	L/sec

Known industrial or commercial uses in drainage area?  Y   N
describe:	


PHYSICAL OBSERVATIONS:

Odor:   none   sewage   sulfide   oil   gas    rancid-sour   other:.

Color:   none  yellow    brown   green    red    gray    other:	

Turbidity: none    cloudy   opaque
Floatables:   none  petroleum sheen  sewage  other:	(collect sample)

Deposits/stains:  none  sediment oily  describe:	(collect sample)

Vegetation conditions:  normal   excessive growth   inhibited growth
       extent:	

Damage to outfall structures:
       identify structure:	
       damage:  none / concrete cracking / concrete spelling / peeling paint / metal
       corrosion
       other damage:	
       extent:	
ANALYSES:                                     EQUIPMENT USED:

Specific conductivity:        	/vS/cm           	
Temperature:               	°C               	
Fluoride:                   	mg/L            	
Hardness:                  	mg/L            	
Surfactants:                	mg/L            	
Florescence:                	% of scale        	
Potassium:                 	mg/L            	
Ammonia:                  	mg/L as N        	
pH:                        	                 	
                                     47

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TABLE 10.  INTERPRETATIONS OF PHYSICAL OBSERVATION  PARAMETERS
                    AND LIKELY ASSOCIATED  FLOW SOURCES
   Odor - Most strong odors, especially gasoline, oils, and solvents, are likely associated with high
   responses to the toxicity screening test. Typical obvious odors include: gasoline, oil, sanitary
   wastewater, industrial chemicals, decomposing organic wastes, etc.

       sewage: smell associated with stale sanitary wastewater, especially in pools near outfall.
       sulfide  ("rotten eggs"): industries, e.g., meat packers, canneries, dairies, etc; and
               stale sanitary wastewater.
       oil and  gas: petroleum  refineries  or facilities associated with vehicle maintenance and
               operation or petroleum product storage.
       rancid-sour: food preparation facilities (restaurants, hotels, etc.).
   Color - Important indicator of inappropriate industrial sources. Industrial dry-weather discharges
   may be of various colors, but  dark colors, such as brown, gray,  or black, are most common.

       yellow: chemical, textile, and tanning plants.
       brown: meat packers,  printing plants, metal works, stone and concrete works, fertilizer
              application,  and petroleum refining facilities.
       green: chemical plants, and textile facilities.
       red: meat packers.
       gray: dairies.
   Turbidity -  Often affected by the degree of gross contamination. Dry-weather industrial flows
   with moderate turbidity can be cloudy, while highly turbid flows can be opaque. High turbidity is
   often a characteristic of undiluted  dry-weather industrial discharges.

       cloudy: sanitary wastewater, concrete or stone operations, fertilizer facilities, and
              automotive  dealers.
       opaque: food processors, lumber mills, metal operations, and pigment plants.
   Floatable Matter - A contaminated flow may contain floating solids or liquids directly related to
   industrial or sanitary wastewater pollution. Floatables of industrial origin may include animal fats,
   spoiled food, oils, solvents, sawdust, foams,  packing materials, or fuel.

       oil sheen: petroleum refineries or storage facilities and vehicle service facilities.
       sewage: sanitary wastewater.
                                                                         (continued)
                                              48

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                                TABLE 10. (continued)
Deposits and Stains - Refer to any type of coating near the outfall and are usually of a dark
color. Deposits and stains  often will contain fragments of floatable substances. These situations
are illustrated by the grayish-black deposits that contain fragments of animal flesh and hair
which often are produced by leather tanneries, or the white crystalline powder which commonly
coats outfalls due to nitrogenous fertilizer wastes.

    sediment: construction  site erosion.
    oily: petroleum refineries or storage facilities and vehicle service facilities.
Vegetation - Vegetation surrounding an outfall may show the effects of industrial pollutants.
Decaying organic materials coming from various food product wastes would cause an increase in
plant life, while the discharge of chemical dyes and  inorganic pigments from textile mills could
noticeably  decrease vegetation. It is important not to confuse the adverse scouring  effects of
high stormwater flows on vegetation with highly toxic dry-weather intermittent flows.

    excessive growth: food product facilities.
   inhibited growth:  high stormwater flows, beverage facilities, printing plants, metal product
                    facilities, drug manufacturing, petroleum facilities, vehicle service  facilities
                    and automobile dealers.
Damage to Outfall Structures - Another readily visible indication of industrial contamination.
Cracking, deterioration, and  spalling of concrete  or peeling of surface paint, occurring at an
outfall are usually caused by severely contaminated discharges, usually of industrial origin. These
contaminants are usually  very acidic  or basic in nature. Primary metal industries have a strong
potential for  causing outfall structural damage because their batch dumps are  highly acidic. Poor
construction,  hydraulic scour, and old age may also adversely affect the condition of the outfall
structure which are not indications of upstream contaminating entries.

    concrete cracking:  industrial flows
    concrete spalling:  industrial flows
    peeling paint: industrial flows
    metal corrosion: industrial flows
                                            49

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Irregular Flows

    Irregular flows pose a special problem during the field surveys. Outfall apparent "dry-weather"
flows can be intermittent in nature, only flowing soon after rains and then remaining dry, or may flow
when inappropriate water sources enter the storm drainage system. If irregular flows are associated
with rains, outfall surveys should be postponed until sufficient time has lapsed since the last major rain.
For most urban areas, storm runoff drainage ends several hours (but usually less than 12) after the rain
stops. Extended, but decreasing flows,  after rains  could be associated with  high  groundwater or
percolating rain water infiltrating  into the drainage system.  In this case, most outfall surveys should
be further delayed. However,  some pollutant sources may be associated with these  after storm flows,
especially contaminated groundwaters (septic tank problems, leaky underground storage tanks, etc.).
Therefore, it may be important  to  sample these  flows, especially if  these  contaminant  sources
potentially exist.

    Basic field indicators, such as the presence of residual stains or deposits, oil sheens, coarse solids,
floatables, color,  odors,  etc., in the absence  of  a flow, indicate  the likelihood of intermittent
dry-weather flows. These observations will be enhanced by installing simple "tell-tale" devices, e.g.,
a terry-cloth  (strain the  discharge) or small caulk  dam in the drain.  Outfalls exhibiting these signs of
non-continuous discharges should be visited several  times to increase the probability of observing and
sampling a dry-weather  discharge. Analyzing pooled water immediately below the outfall or collected
between visits in small, constructed dams within the storm drain can greatly assist in identifying
non-continuous discharges. Coarse solids and/or  floatables can be  captured through the erection of
coarse screens and/or booms at a manhole site,  the mouth of the outfall, or in  the receiving stream.
It may be necessary to visit suspect outfalls frequently.  However, it is virtually impossible to capture
an  isolated  short-term intermittent flow (e.g., from the illegal dumping  of wastes into  the  storm
drainage system) from outfall visits.

    Simple  outfall area  characteristics, noted above, are the most reliable indicator of a potential
intermittent source at an outfall.  In addition to using a  dam,  or other indicator device (e.g., a small
screen  to capture particulate debris), it may be desirable to use an automatic  water sampler at
especially important outfalls. Automatic samplers would be unreasonable and expensive to use at many
outfalls in an area and  test  locations would need to be carefully selected. A  sampler located in a
close-by manhole and set to sample every fifteen minutes (with four samples placed  in each bottle) can
monitor for intermittent  flows for a  period of 24 hours. Automatic samplers can also be used to
characterize variable quality flows. This information can be valuable in identifying possible discharge
sources.
                                              50

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                                         SECTION 6

                      DATA ANALYSIS TO IDENTIFY  PROBLEM OUTFALLS
                                  AND FLOW COMPONENTS
    The field screening surveys are to be used as an initial effort to identify the outfalls needing more
detailed drainage area investigations which  would identify specific pollutant sources and control
options. These field screening surveys, discussed in Sections 4 and 5, include physical, chemical, and
relative toxicity evaluations of outfall and/or discharge conditions.

    The purpose of the procedures presented in this User's Guide is to separate storm drain outfalls
into general categories (with a known level of  confidence) and  to identify which outfalls (and drainage
areas) need further analyses and investigations. The categories used in this Guide are outfalls affected
by non-stormwater entries from: (1)  pathogenic or toxic pollutant sources, (2) nuisance and aquatic
life threatening pollutant sources, and (3) unpolluted water sources.

    The pathogenic and toxic pollutant source category should be considered the most severe because
it could cause disease upon water contact or consumption and cause significant impacts on receiving
water  organisms.  They may also cause  significant water  treatment problems for downstream
consumers, especially if they contain soluble metal  and organic toxicants.  These  pollutants may
originate from sanitary, commercial, and industrial wastewater non-stormwater entries. Other important
residential  area activities that may also be considered  in this most critical category (in addition to
sanitary wastewater) include inappropriate household toxicant disposal, automobile engine de-greasing,
vehicle accident clean-up,  and  irrigation runoff  from landscaped  areas  excessively treated with
chemicals (fertilizers and pesticides).

    Nuisance and  aquatic life threatening pollutant sources can originate from residential  areas and
can include laundry wastewater, landscaped area  irrigation runoff, automobile washing, construction
site dewatering, and washing of concrete mixing trucks. These pollutants can cause excessive algal
growths, depressed dissolved oxygen concentrations, tastes and odors in downstream water supplies,
offensive coarse solids and floatables, and highly colored, turbid or odorous waters.

    Relatively clean or  unpolluted water discharged through  stormwater outfalls  can originate from
natural springs feeding urban creeks that have  been converted to storm drains, infiltrating groundwater,
and infiltrating potable water from water line  leaks.

     A method must be used to compare data  from individual outfall dry-weather samples to  the library
of dry-weather  source  flow data to identify which  outfalls belong in which  general category of
contamination listed above. This comparison should result, at the very least, in  the identification of the
outfalls that are considered as major pollutant sources for immediate remediation. The degree of detail
which  can  be identified for an outfall will depend on the extent of the local data collected to describe
the likely source flows.

     The  procedures that can be used to  identify outfall flow components may  begin with simple
yes/no checks.  For example, if  no  surfactants are measured in an outfall  sample, then sanitary
wastewater is unlikely to be a contributor to the outfall flow.  If no fluoride is measured, then fluoride

                                              51

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treated  potable water sources could be ruled  out as  contributors. The probability that remaining
contenders are present alone or in a mixture may be determined using a combination of matrix algebra
and the selecting of random values from within specified ranges using a Monte Carlo process and many
iterations.

    Most contaminated outfalls will require correction before the receiving water quality recovers to
acceptable levels. However, ranking the outfalls allows the most serious outfalls to be recognized and
enables corrective action to be initially concentrated in the most cost-effective manner. In some of the
case studies investigated, correcting only problems at the most critical outfalls resulted in insufficient
receiving water quality improvements. It may be important to eventually correct all non-stormwater
discharge problems throughout a city, not just the most severe problems. The field screening program
should therefore be considered as an initial  effort  that needs to be followed-up with more detailed
watershed drainage surveys in most  of the areas having observed dry-weather flows. The follow-up
watershed surveys are to identify and  correct inappropriate pollutant  entries into  storm  drainage
systems, as discussed in Sections  7 and 8.

    The identification of flow components of the  dry-weather storm  drain flow  can be used  to
determine which outfalls have the greatest pollution potential. As an example, if an outfall  contains
sanitary wastewater,  it could  be a significant source of pathogenic microorganisms. Similarly, if an
outfall contains plating bath water from a metal finisher, it could be a significant source of toxicants.
These outfalls would  be grouped into the most critical category of toxicants/pathogens. If an outfall
contains washwaters  from a commercial laundry or  car wash, the wastewater could be a major source
of nutrients and foaming material.  These outfalls would be grouped into an intermediate category of
nuisance and  aquatic life threatening. Finally,  if an outfall only contains unpolluted groundwater or
water from leaky potable water mains,  the  water  would be  non-polluting and the outfall would  be
grouped into the last  category of unpolluted water  sources.

    The five methods of data analyses presented in  the following discussions present a hierarchy of
methods, ranging from relatively simple reviews of the outfall characteristics to more sophisticated
methods requiring computer modeling for evaluation. It is suggested that as many of the procedures
be used as possible in evaluating the data, as each  method  provides some unique insights into the
problems. Pitt and Lalor (publication pending)  contains a more  through  discussion of these analysis
procedures, including evaluation of the Birmingham, Alabama, demonstration project data.
INDICATORS OF CONTAMINATION

     Indicators of contamination (negative indicators) are clearly apparent visual or physical parameters
indicating obvious  problems and  are  readily  observable  at  the  outfall  during the  field  screening
activities. These observations are very important during the field survey because they are the simplest
method of identifying grossly contaminated dry-weather outfall flows. The direct examination of outfall
characteristics  for  unusual conditions  of flow, odor, color,  turbidity, floatables, deposits/stains,
vegetation conditions, and damage  to  drainage structures is therefore an important part of these
investigations. Table 10 in Section 5 presented a summary of these indicators, along with  narratives
of the descriptors to be selected in the field.

     This method does not allow quantifiable estimates of the flow components and if used alone will
likely  result  in  many incorrect  determinations  (missing  outfalls  that  have  important  levels  of
contamination). These simple characteristics, discussed further below, are most useful for identifying
gross  contamination.  Only the  most  significant outfalls and drainage  areas would therefore  be
recognized from this method. The  other methods, requiring chemical determinations, can be  used to


                                              52

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quantify the flow contributions and to identify the less obviously contaminated outfalls.

    Indications of intermittent flows (especially stains or damage to the structure of the outfall) could
indicate serious illegal toxic pollutant entries into the storm drainage system that will be very difficult
to detect and correct. Highly irregular dry-weather outfall flow rates or chemical characteristics could
indicate industrial or commercial inappropriate entries into the storm drain system.

    During the demonstration  phase of this research project (Pitt and Lalor publication pending), odors
and high turbidity were found to be the most useful physical indicators of severely contaminated outfall
flows. High turbidity correlated well with high levels of surfactants and toxicity. Noticeable odors also
correlated well with elevated toxicity. Color was not a very useful indicator of gross contamination and
elevated toxicity, unless the color exceed 65 HACH color units.

    Gross industrial wastewater  contamination  may  be indicated by the presence and nature of
floatable material and deposits near the outfall. Table 11  summarizes  possible chemical and physical
characteristics of non-stormwater discharges which could  come from various industries. The properties
considered are pH,  total dissolved solids, odor, color, turbidity, floatable materials,  vegetation, and
damage to outfall structure.  The  descriptions in  each of these categories contain the  most likely
conditions for a non-stormwater discharge coming from a particular industry.  It should be noted that
outfalls are  likely to be affected  by several industrial sources  simultaneously, especially if draining
industrial  parks.  The initial watershed  analysis, discussed  previously, which  needs to describe the
industrial  and commercial facilities that are operating in each  outfall's watershed,  will  be  of great
assistance in identifying which industries may be contributing dry-weather entries into the  storm
drainage system.
SIMPLE CHECKLIST FOR MAJOR FLOW COMPONENT IDENTIFICATION

     Figure 10 is a flow chart describing the analysis strategy to identify the major non-stormwater
discharge sources in residential areas. The first indicator is the presence or absence of flow. If no
dry-weather flow exists at  an  outfall, then indications of intermittent  flows must be investigated.
Specifically, stains, deposits, odors, unusual stream-side vegetation conditions, and damage to outfall
structures can all indicate intermittent non-stormwater flows. However, frequent visits to outfalls over
long time periods are needed to confirm that only stormwater flows occur. The other points  on the
flow chart (Figure  10) serve to  indicate if major contaminating sources are present, or if the water is
uncontaminated water. The other methods discussed later are needed to quantify the component
contributions.

Treated Potable Water

     A number of tracer parameters may be useful for distinguishing treated potable water from natural
waters:
     • Major ions or other chemical/physical  characteristics of the  flow components  can vary
        substantially depending upon whether the water supply sources are groundwater or surface
        water, and whether the sources are treated or not. Specific conductance may also serve as a
        rough indicator of the major water source.

     • Fluoride can often be used to separate treated potable water from untreated water  sources.
        Untreated  water sources can include  local springs, groundwater, regional surface  flows or
        non-potable industrial waters. If the treated water has no fluoride added, or if the natural water
        has fluoride concentrations close to potable water fluoride concentrations, then fluoride may


                                              53

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  TABLE 11. CHEMICAL AND PHYSICAL PROPERTIES OF INDUSTRIAL NON-STORMWATER ENTRIES INTO STORM DRAINAGE SYSTEMS

Industrial Categories
Major Classifications
SIC Group Numbers
Odor
Color
Turbidity
Floatables
Debris &
Stains
Damage to
Outfall
Structures
Vegetation
pH
Total
Dissolved
Solids
Primary Industries
20
201


202

203


204

205

206

207

208


21


22

23

Food and Kindred Products
Meat Products


Dairy Products

Canned & Preserved
Fruits & Vegetables

Grain Mill Products

Bakery Products

Sugar and
Confectionery Products
Fats and Oils

Beverages


Tobacco Manufactures


Textile Mill Products

Apparel and Other Finished
Products

Spoiled Meats
Rotten Eggs and Flesh

Spoiled Milk
Rancid Butter
Decaying Products
Compost Pile

Slightly Sweet & Musty
Grainy
Sweet and or Spoiled

NA

Spoiled Meats,
Lard or Grease
Rat Soda, Beer or
Wine, Alcohol, Yeast

Dried Tobacco,
Cigars, Cigarettes

Wet Burlap, Bleach,
Soap, Detergents
NA


Brown to
Reddish Brown

Gray to White

Various


Brown to
Reddish Brown
Brown to Black

NA

Brown to Black

Various


Brown to Black


Various

Various


High


High

High


High

High

Low

High

Moderate


Low


High

Low


Animal Fats, Byproducts
Pieces of Processed
Meats
Animal FatB
Spoiled Milk Products
Vegetable Waxes,
Seeds,
Skins, Cores, Leaves
Grain Hulls and Skins
Straw & Plant Fragments
Cooking Oils, Lard,
Flour, Sugar
Low Potential

Animal Fats, Lard

Grains & Hops, Broken
Glass, Discarded
Canning Items
Tobacco Stems &
Leaves
Papers and Fillers
Fibers, Oils, Grease

Some Fabric Particles


Brown to
Black

Gray to
Light Brown
Brown


Light Brown

Gray to Light
Brown
White Crystals

Gray to Light
Brown
Light Brown


Brown


Gray to Black

NA


High


High

Low


Low

Low

Low

Low

High


Low


Low

Low


Flourish


Flourish

Normal


Normal

Normal

Normal

Normal

Inhibited


Normal


Inhibited

Normal


Normal


Acidic

Wide
Range

Normal

Normal

Normal

Normal

Wide
Range

Normal


Basic

Normal


High


High

High


High

High

High

High

High


Low


High

Low

Material Manufacture
24
25
26

27

31

33

34

32


Lumber & Wood Products
Furniture & Fixtures
Paper & Allied Products

Printing, Publishing, and
Allied Industries
Leather & Leather Products

Primary Metal Industries

Fabricated Metal Products

Stone, Clay, Glass, and
Concrete Products

NA
Various
Bleach, Various Chemicals

Ink, Solvents

Leather, Bleach
Rotten Eggs or Flesh
Various

Detergents,
Rotten Eggs
Wet Clay, Mud
Detergents

NA
Various
Various

Brown to Black

Various

Brown to Black

Brown to Black

Brown to
Reddish-Brown

Low
Low
Moderate

Moderate

High

Moderate

High

Moderate


Some Sawdust
Some Sawdust, Solvents
Sawdust, Pulp Paper
Waxas, Oils
Paper Dust, Solvents

Animal Flash & Hair
Oils & Grease
Ore, Coke, Limestone
Millscale, Oils
Dirt, Grease. Oils
Sand, Clay Dust
Glass Particles
Dust from Clay or Stone

Light Brown
Light Brown
Light Brown

Gray to
Light Brown
Gray to Black
Salt Crystals
Gray to Black

Gray to Black

Gray to
Light Brown

Low
Low
Low

Low

High

High

Low

Low


Normal
Normal
Normal

Inhibited

Highly
Inhibited
Inhibited

Inhibited

Normal


Normal
Normal
Wide
Range
Normal

Wide
Range
Acidic

Wide
Range
Basic

(continued)
Low
Low
Low

High

High

High

High

Low


01

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TABLE 11. (continued)




















en
en





















Industrial Categories
Major Classifications
SIC Group Numbers
Odor
Color
Turbidity
Floatables
Debris &
Stains
Damage to
Outfall
Structures Vegetation
PH
Total
Dissolved
Solids
Chemical Manufacture
28
281
2

281
6
282


283

284

285



286
286
1
286
5

287
287
3

287
4

287
6

29

291

30


Chemicals & Allied Products
Alkalis and Chlorine


Inorganic Pigments

Plastic Materials and
Synthetics

Drugs

Soap, Detergents, &
Cleaning Preparations
Paints, Varnishes, Lacquers,
Enamels and Allied Products
(SB-Solvent Base)

Industrial Organic Chemicals
Gum and Wood Chemicals

Cyclic Crude), & Cyclic
Intermediates, Dyes, &
Organic Pigments
Agricultural Chemicals
Nitrogenous Fertilizers


Ptiosphatlc Fertilizers


Fertilizers, Mixing Only


Petroleux Refining and
Related Industries
Petroleum Refining

Rubber & Miscellaneous
Plastic Products


Strong Halogen or
Chlorine
Pungent, Burning
NA

Pungent, Fishy


NA

Sweet or Flowery

Latex- Ammonia
SB-Dependent upon Solvent
(Paint Thinner, Mineral Spirits)


Pine Spirits

Sweet Organic Smell



NA


Pungent Sweet


Various




Rotten Eggs
Kerosene, Gasoline
Rotten Eggs
Chlorine, Peroxide


Alkalis - NA
Chlorine - Yellow
to Green
Various

Various


Various

Various

Various




Brown to Black

NA



NA


Milky White


Brown to Black




Brown to Black

Brown to Black



Moderate


High

High


High

High

High




High

Low



Low


High


High




High

Moderate



Glass Particles
Dust from Clay or Stone

Low Potential

Plastic Fragments,
Pieces of Synthetic
Products
Gelatin Byproducts for
Capsulatlng Drugs
Oils, Grease

Latex - NA
SB-All Solvents



Rosins and Pine Tars

Translucent Sheen



NA


NA


Pelletlzed Fertilizers




Any Crude or Processed
Fuel
Shredded Rubber
Pieces of Fabric or Metal


Gray to
Light Brown

Various

Various


Various

Gray to Black

Gray to Black




Gray to Black

NA



White
Crystalline
Powder
White
Emorphous
Powder
Brown
Emorphous
Powder


Black
Salt Crystals
Gray to Black



Highly Normal
Inhibited

Low Highly
Inhibited
Low Inhibited


Low Highly
Inhibited
Low Inhibited

Low Inhibited




Low Inhibited

Low Highly
Inhibited


High Inhibited


High Inhibited


Low Normal




Low Inhibited

Low Inhibited



Basic


Wide
Range
Wide
Range

Normal

Basic

Latex-
Basic
SB-
Normal

Acidic

Normal



Acidic


Acidic


Normal




Wide
Range
Wide
Range


Low


High

High


High

High

High




High

Low



High


High


High




High

High

(continued)

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                                                     TABLE 11.  (continued)
Industrial Categories
Major Classifications
SIC Group Numbers Odor
Transportation & Construction
1 5 Building Construction Various
1 6 Haavy Construction Various


Re rail
52 Building Materials, NA
Hardware, Garden Supply,
and
Mobile Home Dealers
53 Gen. Merchandise Stores NA
54 Food Stores Spoiled Produce
Rancid, Sour
65 Automotive Dealers & Oil or Gasoline
Gasoline Service Stations
56 Apparel & Accessory Stores NA
57 Home Furniture, Furnishings, NA
& Equipment Stores
58 Eating & Drinking Places Spoiled Foods
Oil & Grease
Coal Steam Electric Power NA


Nuclear steam Electric Power NA
Debris &
Color Turbldrty Floatable* Stains

Brown to Black High Oils, Grease, Fuels Gray to Black
Brown to Black High Oils, Grease, Fuels Gray to Black
Diluted Asphalt or
Cement

Brown to Black Low Some Seeds, Plant Parts, Light Brown
Dirt, Sawdust, or Oil


NA NA NA NA
Various Low Fragments of Food Light Brown
Decaying Produce
Brown to Black Moderate Oil or Gasoline Brown

NA Low NA NA
NA Low NA NA

Brown to Black Low Spoiled or Leftover Brown
Foods
Brown to Black High Coal Dust Black
Emorphous
Powder
Light Brown Low Oils, Lubricants Light Brown
Damage to Total
Outfall Dissolved
Structures Vegetation pH Solids

Low Normal Normal High
Low Normal Normal High
•


Low Normal Normal Low



Low Normal Normal Low
Low Flourish Normal Low

Low Inhibited Normal Low

Low Normal Normal Low
Low Normal Normal Low

Low Normal Normal Low

Low Normal Slightl Low
y
Acidic
Low Normal Normal Low
Ul
en

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(Jl
-vl
                                                                                                                     igh potassiunv^ Yes
                                                                                                                    or ammonia?


Untrealod natural
water.
                                                                                          Probably not a
                                                                                           contaminated
                                                                                         Tion-stormwater source.
\        \  Likely washwater  \
A         \   •»«*     \
                                     Figure 10.  Flow chart to identify residential area non-stormwater flow sources.

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       not be an appropriate indicator.

     • Hardness can also be used as an indicator if the potable water source and the baseflow are
       from different water sources. An example would be if the baseflow is from hard groundwater,
       and the potable water is from softer surface supplies.

     • If the concentration of chlorine is high, then a major leak of disinfected potable water is likely
       to be close to the outfall. Because of the rapid dissipation of chlorine in water (especially if
       some organic contamination is present) it is not a good parameter for quantifying  the amount
       of treated potable water observed at the outfall.

Water from potable water supplies (that test positive  for fluorides, or other suitable tracers) can be
relatively uncontaminated, e.g., potable waterline leakage or irrigation runoff, or heavily contaminated,
e.g., sanitary wastewater.

Sanitary Wastewaters

     In areas containing no industrial or commercial sources, sanitary wastewater is probably the most
severe dry-weather contaminating source of storm drain flows. The following parameters  can be used
for quantifying the sanitary wastewater components of the treated potable  water portion:

     • Surfactant analyses may be useful in  determining the presence of  sanitary wastewaters.
       However, surfactants present in water originating from potable water sources could indicate
       sanitary wastewaters, laundry wastewaters, car  washing wastewater,  or  any other waters
       containing surfactants. If surfactants (or fluorescence) are not present, then  the potable water
       could be relatively uncontaminated (potable waterline leaks or irrigation runoff).

     • The  presence of  fabric whiteners  (as measured by fluorescence using  a fluorometer in the
       laboratory or in the field) can  also be used in distinguishing laundry and sanitary wastewaters.

     • Sanitary wastewaters often exhibit predictable trends during the day in flow and quality.  In
       order to maximize the ability  to detect direct sanitary wastewater connections into the storm
       drainage system,  it would be best to survey  the outfalls during periods of highest sanitary
       wastewater flows (mid  to late morning hours).

     • The ratio of surfactants to ammonio or potassium concentrations may be an effective indicator
       of  the  presence of sanitary   wastewaters  or  septic  tank   effluents.  If  the surfactant
       concentrations are high, but the ammonia and potassium concentrations are low,  then the
       contaminated source may be laundry wastewaters. Conversely, if ammonia, potassium, and
       surfactant concentrations are all high, then sanitary wastewater is the likely source. Some
       researchers have  reported low surfactants in septic tank effluents. Therefore, if surfactants are
       low, but potassium and ammonia are both high, septic tank effluent may be present. However,
       Pitt and Lalor (publication pending) found high surfactant concentrations in septic tank effluent
       during the Birmingham, Alabama demonstration  project.  This  further stresses the  need  to
       obtain local site specific characterization data  for  potential contaminating sources.

     • Obviously, odor and other physical characteristics,  e.g., turbidity, coarse and floating "tell-tale"
       solids, foaming, color, and temperature would also be very useful  in distinguishing sanitary
       wastewater from wash water or laundry wastewater sources. However, these indicators may
       not be very obvious for small levels of sanitary wastewater contamination.
                                              58

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FLOW-WEIGHTED MIXING CALCULATIONS

    Before any flow-weighted  mixing  calculations can  be made,  the  characteristics of potential
contaminating sources must be  identified. Table 12 summarizes hypothetical concentration medians
and COVs for tracers that have been recommended to be used in the investigation of non-stormwater
entries into storm  drainage  systems in residential areas. This method  is an  extension  of  the
checklistmethod described above and attempts to quantify the likely source flow components at the
outfall during dry weather.

    Two general groupings of flow sources can usually be recognized for each of these tracers, a high
concentration group and a low concentration group. Table 13 describes these groups, along with their
composite tracer concentration ranges, variations, and medians. The  outfall flow can be split between
the two general groupings by simple algebra. This method can result in substantial errors if the tracer
concentrations cannot be separated into distinct source groupings. The next two methods, using matrix
algebra to solve simultaneous equations, do not require this simplifying assumption.

Example Calculations

    The drainage area for a sampled outfall had no septic tanks or commercial and industrial land uses.
The likely flow sources had source flow characteristics as described in Table  12. The required detection
limits and precision for outfall characterizations must be determined, as previously described, for these
source  flow  characteristics  and  desired  study  results.  This outfall had the  following tracer
concentrations in a dry-weather sample:

    Fluoride: 0.6 mg/L

    Hardness: 200 mg/L as CaC03

    Surfactants: 0.6 mg/L as MBAS

    Potassium: 3 mg/L

    Ammonia: 3 mg/L

The water had a slight septic odor, with some floatables of apparent sanitary wastewater origin. In
addition, dry-weather flow was observed at the outfall during all visits.

     It is apparent that this outfall has a direct connection(s) of raw sanitary wastewater. This method
can determine the  approximate mix of sanitary wastewater in  the outfall flow and identify the other
flow components. Table 14 summarizes the example calculations used in this analysis.  The list below
indicates the approximate expected source components at this outfall from this  analysis:

        Raw sanitary wastewater: 5%

        Laundry wastewater: 5%

        Groundwater: 70%

        Remainder (most likely potable water, but may also contain  irrigation water): 20%

     This analysis did not consider the potential ranges in observed tracer concentrations and the


                                             59

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TABLE 12.  ASSUMED SOURCE FLOW QUALITY
            (All Cone, in mg/L)
Source
Surface median
Waters COV
Ground- median
waters COV
Septic Tank median
Effluent COV
Raw median
Sanitary COV
Wastewater
Laundry median
Wastewater COV
Irrigation median
Water COV
Fluoride
0.14
0.23
0.29
0.23
1.3
0.14
1.3
0.14
1.3
0.14
1.3
0.14
Hardness
(as Ca Co3)
39
0.20
250
0.14
39
0.20
39
0.20
39
0.20
39
0.20
Surfactants
(as MBAS)
0.35
0.13
0.05
0.13
0.05
0.13
4.6
2.2
4.6
2.2
0.35
0.13
Potassium
0.72
0.23
1.7
0.40
21
0.91
21
0.91
5.3
0.57
0.72
0.23
Ammonia
(N as NH3)
0.76
1.1
0.22
0.63
47
1.5
22
0.63
0.31
0.91
0.38
1.1
                  60

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        TABLE  13.  CHARACTERISTICS OF SOURCE GROUPINGS
Fluorides
surface & groundwaters
       overall range:
       COV:
       median:
Concentration ratio
of medians:
0.1-0.4 mg/L
0.54
0.20 mg/L

6.5
all other categories
1-1.5 mg/L
0.14
1.3 mg/L
Hardness
groundwaters
       overall range:
       COV:
       median:
Concentration ratio
of medians:
200-300 mg/L
0.14
250 mg/L

6.4
all other categories
30-50 mg/L
0.20
39 mg/L
Surfactants
raw sanitary wastewater
& laundry wastewater
       overall range:
       COV:
       median:
Concentration ratio
of medians:
0.2-100 mg/L
2.2
4.6 mg/L

33
all other categories

0.04-0.4 mg/L
0.83
0.14 mg/L
Potassium
septic tank effluent &
raw sanitary wastewater
       overall range:
       COV:
       median:
Concentration ratio
of medians:
10-100 mg/L
0.91
21 mg/L

9.1
all other categories

0.5-11 mg/L
1.2
2.3 mg/L
Ammonia
septic tank effluent &
raw sanitary wastewater
       overall range:
       COV:
       median:
Concentration ratio
of medians:
6-380 mg/L
1.5
47 mg/L

107
all other categories

0.1-3 mg/L
1.3
0.44 mg/L
                                     61

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TABLE 14.  MIXTURE CALCULATIONS TO IDENTIFY SOURCE FLOW COMPONENTS
   Fluorides:               0.6 mg/L observed at outfall

          x = fraction of surface & groundwater
                  with concentration of 0.2  mg/L
          y = fraction of treated water (all other  sources)
                  with concentration of 1.3  mg/L
          (x & y fraction concentrations taken from Table 13)

          x(0.2) + yd.3)  =  0.6         (for a unit volume of outfall water)
          x + y = 1                    (for no other  sources of fluorides)

                          x  = 0.63 (surface & groundwater)
                          y  = 0.37 (all other sources)
   Hardness               200 mg/L as CaCO3 observed at outfall

           x  = fraction of groundwater
                  with concentration  of 250 mg/L as CaC03
           y  = fraction of all other sources
                  with concentration  of 39 mg/L as CaC03

                          x(250) + y(39) =  200

                          x  = 0.76 (groundwater)
                          y  = 0.24 (all other sources)

   From Fluorides and Hardness Data:

           Groundwater & Surface water =  0.63
           Groundwater alone  =            0.76
           Surface water alone =         -0.13-»0

           Therefore:
                  Groundwater fraction = (0.63 + 0.761/2 = 0.7
   Surfactants:    0.6 mg/L as MBAS observed at outfall

           x = fraction of sanitary & laundry wastewater
                  with a concentration of 4.6 mg/L as MBAS
           y = fraction of all other sources
                  with a concentration of 0.14 mg/L as MBAS

                          x(4.6) +  y(0.14) = 0.6

                          x  = 0.10 (sanitary & laundry wastewater)
                          y  = 0.90 (all other sources)
                                             62

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                               TABLE 14. (continued)
Potassium:             3 mg/L observed at outfall

        x = fraction of sanitary wastewater
               with a concentration of 21  mg/L
        y = fraction of all other sources
               with a concentration of 2.3 mg/L

                       x(21) + y(2.3)  =  3

                       x = 0.04 (sanitary wastewater)
                       y = 0.96 (all other sources)
Ammonia:              3 mg/L observed at outfall

        x = fraction of sanitary wastewater
                with a concentration of 47 mg/L
        y = fraction of all other sources
                with a concentration of 0.44 mg/L

                       x(47) + y(0.44) = 3

                       x = 0.06 (sanitary wastewater)
                       y = 0.94 (all other sources)

From Surfactants, Potassium, and Ammonia Data:

                Sanitary wastewater = (0.04 + 0.06)/2  = 0.05

                Laundry wastewater = 0.1  - 0.05 = 0.05
                                           63

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resulting errors that may be associated with the above mixture portions. The following procedures are
better suited for error analyses.

MATRIX ALGEBRA SOLUTION OF SIMULTANEOUS EQUATIONS

    It  is possible to estimate the outfall source flow components using a set of  simultaneous
equations. The number of unknowns should equal the number of equations available,  resulting in a
square matrix.  If there are  eleven likely source  categories, then  there should be  eleven  tracer
parameters used. If there are only four possible sources, then only four tracer parameters should be
used.

    Further statistical analyses  may therefore be needed to rank the  usefulness of the tracers for
distinguishing different flow sources. Pitt and Lalor (publication pending) show examples of how cluster
and principal component analyses can be used to identify redundancy and other problems in the data
library. As an example,  chlorine is not useful for these analyses because the concentration variability
within  many source categories is high (it is also not a conservative parameter). Chlorine may still be
a useful parameter, but only to identify possible large potable waterline leaks. It cannot be used to
quantify the flow components. Another  parameter having problems for most situations is pH. The
variation of pH between sources is very low (they are all very similar).  However, pH may still be useful
to identify industrial wastewater problems, but it cannot be used to quantify flow components. pH is
also not linearly affected by mass balance mixtures (a solution of  50 percent/50  percent  of two
components would not result in a pH value that is the average of the two individual  pH values).

    These equations are structured on a mass balance basis, like the previous procedure, but they can
be used to distinguish  all source categories simultaneously. A  simplified example  is  shown in the
following discussion considering just four possible flow components  and four tracer  parameters (P1,
P2, P3, P4). This would result in the following set of equations for each outfall sample:
    tracer
    parameter:
possible sources:

 2             3
outfall
quality
       P1:      (A1MC11)   +   (A2)(C21)   +  (A3HC31)  +  (A4)(C41)  = ml

       P2:      (A1)(C12)   +   (A2)(C22)   +  (A3HC32)  +  (A4)(C42) =  m2

       P3:      (A1MC13)   +   (A2)(C23)   +  (A3HC33)  +  (A4)(C43)  = m3

       P4:      (A1HC14)   +   (A2)(C24)   +  (A3)(C34)  +  (A4)(C44)  = m4
     A1 through A4 represent the fraction of flow contributed from each possible flow source. The "C"
     terms  represent concentrations from the source flow library for each particular  parameter (P)
     within each flow source(1-4). The "m" terms represent the concentration of P actually measured
     in the  outfall  sample.
                                            64

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    The following is an example for an outfall dry-weather sample:

                            possible sources:

tracer         potable        ground            sanitary              laundry           outfall
parameter:     water         water             wastewater          wastewater        quality

fluoride:    (A1H0.97 mg/L) + (A2M0.031 mg/L) + (A3H0.77 mg/L) + (A4)(33 mg/L)  = 3.8 mg/L
hardness:   (A1)(49mg/L)  + (A2)(240 mg/L)   + (A3)(140 mg/L)   + (A4)(14 mg/L)   =126 mg/L
surfactants:(A1)(0 mg/L)    + (A2)(0 mg/L)    +  (A3M1.5 mg/L)   +  (A4H27 mg/L)   = 3.0 mg/L
potassium:  (A1)(1.6 mg/L) + (A2K0.73 mg/L)  + (A3M6.0 mg/L)   + (A4)(3.5 mg/L)  = 2.2 mg/L

    This simple 4x4 matrix can be solved using available  scientific calculators or math programs for
    personal computers, or by hand. For this example, the following  are the approximate flow
    components (rounded to the nearest 5 percent):

    • treated potable water (A1): 30%
    • groundwater (A2): 35%
    • sanitary wastewater (A3): 20%
    • laundry wastewater (A4): 10%

These component contributions do not all add up to 100 percent. A number of errors, especially
variations in source area characteristics and other  sources present that were not considered, tend to
result in component sums that are not 100 percent.  The  following  method is similar, but considers
uncertainty in source area characteristics and results  in a range of likely component contributions.


MATRIX ALGEBRA CONSIDERING PROBABILITY DISTRIBUTIONS OF LIBRARY DATA

    A stochastic version of the above procedure enables the variation  in the library values to  be
considered. The matrix is set up in the same way,  but instead of using a single value representing the
parameter concentration for each likely source flow,  a Monte Carlo simulation is  used  to randomly
select values. A large number of analyses (from a few  hundred to many thousands) are conducted and
the percentage  contributions for each component source are presented as a probability distribution
instead of a single value.

    It is therefore necessary to describe the distribution of source flow characteristics. In most cases,
the tracer parameters can be represented using log-normal distributions. Some parameters, however,
are adequately described with normal distributions. Again, local source flow monitoring  is necessary
to obtain this information. Pitt and Lalor (publication  pending) contains examples using this  method,
including the code for the necessary computer program.
                                            65

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                                         SECTION 7

        WATERSHED SURVEYS TO CONFIRM AND LOCATE INAPPROPRIATE POLLUTANT
                        ENTRIES TO THE STORM DRAINAGE SYSTEM
    After initial outfall surveys have indicated the presence of contamination, further detailed analyses
are needed to identify and  locate the  specific contaminant source(s)  (e.g., residential, commercial,
and/or industrial) in  the drainage area.  For  source identification  and location, upstream  survey
techniques should be used in conjunction with an  in-depth watershed evaluation.  Information on
watershed  activities can be obtained from aerial photography and/or zoning  maps, while upstream
survey techniques will include the analysis of the dry-weather flow at several manhole points along the
storm drainage system to narrow the location of the contaminating source; tests for specific pollutants
or ions associated with  known activities within the outfall catchment  area; and the measurement of
water flow rate and temperature,  visual and T.V. inspections, and smoke and dye tests.
USING TRACER PARAMETERS IN THE DRAINAGE SYSTEM

    In order to identify the specific contaminant sources in the drainage system, further detailed
watershed analyses are needed. These may include:

     • drainage system surveys (tests for specific  pollutants,  visual inspections, T.V. drainage pipe
       inspections, and smoke and  dye tests),
     • in-depth watershed evaluation (including aerial photographs), and
     • industrial and commercial site studies.

Review Industrial  User Surveys or Reports

    This will require the submission of a questionnaire to industries to determine which industries or
commercial  locations are discharging to a storm drainage system. However site inspections will still
be  required because  questionnaires may  not  be  returned  or may give incorrect details  (either
deliberately  or unknowingly).

Follow-up Drainage Area and On-Site Investigations.

    Further drainage area  investigations upstream of identified  problem outfalls would be conducted
after the  outfall studies have indicated dry-weather  discharge problems. In order to be cost-effective,
only a  sub-sample  of  manholes  located  in  a  drainage area  identified  as having  significant
non-stormwater sources should be tested for the tracers. As an example, the  main storm drain trunk
sewer could be divided into tenths and the manholes closest to these subdivisions would be sampled.
This would identify the upper limit of the drainage area above which the major sources are not located.
A location may also be identified where the downstream manhole tracer mass yields (concentration
times flow rate) are the same. This would mark the downstream limit of the contributing area for  the
tracers of  concern. After the  main trunk drainage reach  is identified that contains the  major
non-stormwater sources,  the branch storm drain lines  can be similarly  subdivided (but into fewer
sections  each, perhaps about three) and evaluated. Depending on the drainage area and complexity

                                             66

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of the storm drainage system, this scheme could be suitably modified to enable the identification of
relatively small areas responsible for the non-stormwater pollutant entries into the  storm drainage
system. These small areas would then be subject to the more  intensive on-site investigations by smoke
tests, dye studies, and T.V. inspections.

    The above drainage system analysis procedure may find that the drainage system is contaminated
by widespread sanitary wastewater entries, possibly due to sanitary and storm drainage systems in
extremely poor condition. This situation may require that the drainage system undergo extensive and
costly repairs.  It may be more appropriate to consider the storm drainage system as a combined sewer
and examine control  alternatives that have been developed for combined sewer systems. This would
also save further detailed drainage system analyses costs.

    These drainage  system  surveys  would  be followed   by industrial  and commercial on-site
investigations  (e.g.,  dye and  smoke  studies and  T.V.  inspections) to  locate specific  sources  of
non-stormwater pollutant entries into the drainage system. Additionally, aerial photography can be very
useful  during  later phases of  non-stormwater discharge control projects. As  an example,  aerial
photography can help identify areas having failing septic systems located in residential areas served
by storm drainage systems. Aerial photography can also be used to identify continuous discharges to
surface drainage  systems,  such as sump discharges,  and  to identify  storage areas that may  be
contributing significant amounts of pollutants during  rains.  For example,  the  Tennessee  Valley
Authority (TVA), among other agencies, has extensively used aerial photography (stereo color infrared)
to identify pollution sources,  especially from failing septic tanks (Perchalski and Higgins  1988). The
TVA's flights are made in early spring when investigating septic tank failures, to  be  able to identify
unusual grass  conditions, with minimal interference from trees. The flights are made at 6,000 feet,
with resulting  image  scales of 1 inch to 1,000 feet. Their photography costs have  been about  $40 to
$150 per square mile.
FLOW MASS BALANCES, DYE STUDIES, AND SMOKE TESTS

     Industrial areas are known to contribute significantly polluted wet-weather stormwater discharges,
along with contaminated dry-weather entries into the storm drainage system. Additional industrial site
investigations are therefore needed to identify activities that apparently contribute these contaminants
to the storm drainage system. Figure 11 is an industrial site survey form prepared by the Non-Point
Source and  Land Management Section  of the Wisconsin  Department of Natural  Resources (R.
Bannerman, personal communication). This form has been used to help identify industrial activities that
contribute significantly polluted, indirectly connected dry- and wet-weather non-stormwater entries into
the storm drainage system.

     This form only considers outside sources that would affect the storm drainage system by entering
through inlets or through sheetflow runoff into drainage channels. It does not include any information
concerning indoor activities, or direct plumbing connections to the storm drainage system. However,
the  information  included on this form  can be very  helpful in  devising runoff control programs for
industrial  areas.  This  information most  likely affects  wet-weather  discharges much  more  than
dry-weather discharges. Obvious dry-weather leaching or spillage problems are also noted on the form.

Locating An Industrial Source

     Hypothetical examples  have been  created  to demonstrate how dry-weather discharges can be
characterized  so that their  likely industrial sources can  be identified. These examples show how
observations of outfall conditions and simple chemical analyses, combined with a basic knowledge of
wastewater characteristics of  industrial and commercial operations located  in the drainage area, can
                                             67

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City:	'Industry Name:_
Site Number:	Photo #	
Street Address:	Roll
Type of industry:.
Instructions:  Fill in blanks or circle best answer in following:

Material/waste Storage Areas
1.  Type of material/waste:
2.  Method of storage:   pile   tank   dumpster   other
3.  Area occupied by material/waste (acres):
4.  Type of surface under material/waste:  paved    unpaved
5.  Material/waste is disturbed: often   sometimes    never   unsure
6.  Description of spills (material, quantity & frequency):     	
7.  Nearest drainage (feet) and drainage type:    	
8.  Control practice: berm   tarp    buffer   none   other
9.  Tributary drainage area, including roofs (acres)    	
 10. Does storage area drain to parking lot:  yes    no   unsure

 Heavy equipment storage
 1.  Type of equipment:	
 2.   Area covered by equipment (acres):   	
 3.   Type of surface under equipment:  paved   unpaved
 4.  . Nearest drainage (feet) and drainage type:    	
 5.   Control practice: berm   tarp   buffer    none   other
 6.   Tributary drainage area, including roofs (acres)     	
 7.   Does storage area drain to parking lot: yes    no   unsure

 Air pollution
 1.   Description of setteable air pollutants (types & quantities):
 2.   Description of particulate air pollutant controls;    	
 Railroad yard
 1.   Size of yard (number of tracks):
 2.   General condition of yard:   	
 3.   Description of spills in yard (material, quantity & frequency):
 4.   Type of surface in yard:   paved    unpaved
 5.   Nearest drainage (feet) and drainage type:    	
 6.   Type of control practice:  berm    buffer   other
 7.   Does yard drain to parking lot:  yes   no    unsure
 8.   Tributary drainage area, including roofs (acres):
 Loading Docks
 1.   Number of truck bays: 	
 2.   Type of surface:  paved   unpaved
 3.   Description of spills in yard (material, quantity & frequency):
 4.   Nearest drainage (feet) and drainage type:   	
 5.   Type of control practice:  berm   buffer   other      	
 6.   Does loading area drain to parking lot:  yes   no    unsure
 7.   Tributary drainage area, including roofs (acres):     	
 Source: From Wisconsin Dept. of Natural Resources (R. Bannerman, Personal communication)


            Figure 11. Industrial Inventory Field Sheet. (Use other sheets for multiple
                                       areas on same site)
                                               68

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be used to identify the possible pollutant sources. The initial activities include pollutant analyses of
outfalls  being investigated. This requires the  characterization of the non-stormwater flows, the
identification of the likely industries responsible for the observed discharges, and finally, locating the
possible specific sources in the watershed.

Hypothetical Conditions-
    The hypothetical industries which were identified as being located in a stormwater drainage area
(from the watershed analysis) included a vegetable cannery, general food store, fast food restaurant,
cheese factory,  used car dealer, cardboard  box producer,  and a wood  treatment  company. The
methods used to  determine the most  likely industrial  source of the  dry-weather  discharges are
considered for three hypothetical situations of outfall contamination.

    Case Example One--The hypothetical results of the pollutant analysis for the first  situation found
constant dry-weather flow at the outfall. The measurements indicated a normal pH (6) and low total
dissolved  solids  concentrations (300 mg/L). Other outfall characteristics included a  strong odor of
bleach, no distinguishing color, moderate turbidity, sawdust floatables,  a  small amount of structural
corrosion, and normal vegetation.

    The significant characteristic  in this situation is the sawdust floatables  (see Figure 12). The
industries which could produce  sawdust and have dry-weather flow drainage to this pipe are the
cardboard box company and the wood treatment company. According to SIC code, the cardboard box
company  would fall under the category of "Paper Products" (SIC#  26)  while the wood treatment
company  would be under that of  "Lumber and Wood"  products  (SIC# 24). Looking up these two
industries by their corresponding SIC group numbers in Table 11 and comparing the listed properties,
indicates that the paper industry has a strong potential for the odor of bleach. Wood products does
not indicate any particular smell.

     Based upon this data, the most likely industrial source of the industrial non-stormwater discharge
would be the cardboard box company. Table 2  under SIC# 26 indicates that there is a high potential
for direct connections in paper industries under the categories of water usage and illicit or inadvertent
connections. At this point, further testing should be conducted at the cardboard box company to find
if the constant source of contamination is coming from cooling waters, process waters, or direct piping
connections (process waters are the most likely source given the bleach and sawdust characteristics).

     Case Example  2-The results of the pollutant  analysis for the second situation found intermittent
dry-weather discharges at the outfall. The test measurements  indicated a low pH (3) and high total
dissolved  solids  concentrations (approximately   6,000 mg/L).  Other  characteristics included  a
rancid-sour odor, grayish color, high turbidity,  gray  deposits containing  white gelatin-like floatable
material, structural damage in the  form  of spelling concrete, and an unusually large amount of plant
life.

     The rancid-sour smell and the presence of floatable substances at this outfall indicates that some
type of food product is probably spoiling. This narrows the possible suspect industries  to the fast food
restaurant, cheese factory, vegetable cannery, and food  store (see Figure 13). The corresponding SIC
categories for each of these industries are "Eating and Drinking Places" (SIC# 58), "Dairy Products"
(SIC# 202),  "Canned and Preserved Fruits arid Vegetables" (SIC# 203), and "Food Stores" (SIC# 54).
Comparison of the properties listed in Table 11 for these SIC numbers  indicates that elevated plant life
is common to industrial wastes for the "Dairy Products"  and "Food Stores" categories. However, the
deciding factor is the low pH, which is  only listed for "Dairy Products". Thus, the white gelatin-like
floatables  are most likely spoiled  cheese byproducts  which  are also  the probable cause of the
sour-rancid smell.
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    (1)
POLLUTANT
 ANALYSIS
    OF
 SUSPECT
 OUTFALL
    (2)

FLOATABLES

 SAWDUST
                    Table 11
        CARDBOARD
           BOX
         COMPANY
         SIC # 26
              WOOD
            TREATMENT
            COMPANY
             SIC # 24
     (1) Characterization of non-stormwater discharge.
     (2) Identification of industry.
     (3) Possible sources.
    (2)

  ODOR

 BLEACH
                                  Table 11
CARDBOARD
   BOX
COMPANY
   (3)
            1
DISCHARGE
                                                     CONTINUAL
                     Table 2
                                                                          DIRECT
                                                    WATER USAGE
                                                       AND
                                                  \     PIPING
                                                  \  CONNECTIONS
                        Figure 12. Flowsheet for Industrial Case 1.

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1
(1)
POLLUTANT






(2)
ODOR


(2)
FLOATABLES






(2)
VEGETATION






(2)
£H






(3)
DISCHARGE

i


ANALYSIS
   OF
SUSPECT
OUTFALL
RANCID-
 SOUR
  WHITE
GRANULES
                          Table 11
                FAST FOOD
               RESTAURANT
                 SIC # 58
                 CHEESE
                FACTORY
                SIC # 202
                VEGETABLE
                CANNERY
                SIC # 203
                  FOOD
                 STORE
                 SIC # 54
ELEVATED
                                  Table 11
                  CHEESE
                 FACTORY
                  FOOD
                  STORE
             (1) Characterization of non-stormwater discharge.
             (2) Identification of industry.
             (3) Possible sources.
ACIDIC
\     DRY/
I INTERMITTENT
                                  Table 11
                                  Table 2
                 CHEESE
                FACTORY
            I               l
            I    INDIRECT    !
            I	I
                                                                                   LOADING/   |   j
                                                                                  UNLOADING
                                                  DIRECT
                                                                WATER USAGE
                                                                    AND
                                                                   PIPING
                                                                CONNECTIONS
                          Figure 13. Flowsheet for Industrial Case Example 2.

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    Since the dry-weather entry to the storm drainage system occurs intermittently, the flow could
be caused by either a direct or indirect connection. To  locate the ultimate source of this discharge
coming from the cheese factory, both direct and indirect  industrial situations are considered under the
category of "Dairy Products" in Table 2. Thus, further examination of the loading dock procedures,
water usage, and direct piping connections should be conducted since these categories all exhibit high
potential for pollution in dairy production.

    Case Example 3- The results of the test measurements for the final situation found a normal pH
(6) and low total dissolved solids (about 500 mg/L). Signs of contaminated discharges were found at
the outfall only during and immediately following rainfalls. Other outfall properties observed included
an odor of oil, deep brown to black color, a floating oil film,  no structural damage, and inhibited plant
growth (see Figure 14).

    According to Table  11, the fast food restaurant and the  used car dealer are the only two industrial
sources in this area with high potential for causing oily discharges. Their respective SIC categories are
"Eating and Drinking Places"  (SIC# 58) and  "Automotive  Dealers"  (SIC# 55).  Comparison of the
properties shown on Table 11  indicates inhibited vegetation only for the second  category. Thus, the
most  likely source  of the discharge  is the used car dealer.

    Furthermore, the source of contamination must likely be indirect, since the discharge occurs only
during wet weather. Reference to Table 2, under the category of "Automotive Dealers", indicates a
high potential for contamination due to  outdoor storage. This fact,  plus the knowledge that most used
cars are displayed outdoors, makes it fairly clear that  surface runoff is probably carrying spilled car oil
into the storm drain during rains.
                                              72

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GO
i
i i i !
! (1) | (2) (2) ' (2)
POLLUTANT ODOR FLOATABLES VEGETATION
| ANALYSIS jg>g> j
OF OIL OILY i | INHIBITED
SUSPECT FILM \
OUTFALL j


i

|
Table 1 1 Table 1 1
i i
i

FAST FOOD USED CAR USED CAR
(3)
DISCHARGE
WET
WEATHER
FLOW

Table 2

INDIRECT
RESTAURANT DEALER DEALER
SIC # 58 SIC # 55
i

(1) Characterization of non-stormwater discharge.
(2) Identification of industry.
(3) Possible sources.
OUTDOOR
STORAGE

                                        Figure 14.  Flowsheet for Industrial Case Example 3.

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                                         SECTION 8

                                 CORRECTIVE TECHNIQUES
    In addition to identifying problems of unauthorized or inappropriate entries to stormwater systems,
it is even more important to prevent problems from developing at all, and to provide an environment
in which future problems will be avoided. Thus, a combined  approach of identifying and correcting
existing problems and avoiding future problems has considerable merit. In this section, the focus is on
discussing ways in which future problems can be avoided. However it should be noted that this is not
an in  depth review,  but has  been included  to provide the reader with  suggestions that could  be
incorporated into a pollution prevention program.

    There are also situations in which the sanitary system is so connected to the stormwater system
that good intentions, vigilance,  and reasonable remedial actions will  not be sufficient to  solve the
problems. In an extreme case, it may be that while it was thought that a community had a separate
sanitary sewer system and a separate storm drainage system, in  reality the storm drainage system is
acting as a combined sewer system. When recognized for  what it really is, the alternatives for the
future become clearer: undertake the considerable investment and commitment to rebuild the system
as a truly separate system,  or recognize the system as a combined sewer system,  and operate it as
such,  without the disillusionment  that it is a problem-plagued storm drainage system which can  be
rehabilitated.

    Less extreme than designating a polluted stormwater drainage system a combined sewer system,
is the action of focusing on pollution prevention by:

     • public education,
     • an organized systematic program of disconnecting commercial and industrial non-stormwater
       entries into the storm drainage system,
     • tackling the problem of widespread septic system failure,
     • disconnecting direct sanitary sewerage connections,
     • rehabilitating  storm  or sanitary sewers to abate contaminated water infiltration, and
     • developing zoning and ordinances.

In this section, the above items will be discussed, together with a section on treatment of wide spread
sanitary sewerage failure.
PUBLIC EDUCATION

    One can argue that an ill informed and apathetic public has condoned the past actions of private
citizens, commercial entities, industrial concerns, and public officials which led to some of the past and
present problems with unauthorized entries to storm drainage systems. One also knows the power of
an aroused, concerned public in altering behavior at all levels. Thus, public education has a role to play.
It can be effective in altering the behavior of an individual who had assumed that the inlet on the curb
was the place to discharge used crankcase oil. It can be effective when organized groups lobby for the
return of a stream or a reservoir to a clean and attractive condition.

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    Public education carries with it the implicit assumption that an educated  public will make  the
"right" decisions, the educated public will  be concerned about the  "right"  problems,  and it  will
encourage private and public organizations to develop solutions to the "right" problems. Fortunately,
most  of the problems, issues, and corrective measures are  clear cut  with respect to unauthorized
entries to the stormwater system. Public education is a communication art associated with significant
changes when successful, and imperceptible change when unsuccessful. As with all education, it does
not end, but is a continuing process. The following paragraphs describe some of the ways in which
public officials can help to educate the public. The "public" has been subdivided into categories which
are representative of the problem areas  with respect to unauthorized entries to  storm drainage
systems. The subcategories of the public are:

       •  industrial
       •  commercial
       •  residential
       •  governmental

    Industrial decision makers can be educated by public officials through direct contact when they
seek information, by education of the consultants from whom industry seeks advice, and by education
of trade  associations. Indirect  educational opportunities are provided by speaking  to meetings of
professional organizations and by writing  in professional newsletters and journals. Industrial decision
makers are a small group which is likely to respond as they recognize that they have to address  the
problem of unauthorized entries to the stormwater system.

    Commercial storm drainage system users are a larger group to educate. The educational process
will have to focus on both proprietors and their employees. It will have to recognize the state of both
groups, new businesses opening; existing businesses moving, expanding, and closing; and employees
entering the work force and changing jobs. Education will have to be focused in the local community.
The role of trade and professional associations will be less than was the case with industrial groups.
News announcements in the local press will play a role as well as mailed news items. Individual contact
between a public official and the proprietor of a commercial establishment will  play a larger role. Follow
up and repeated contact  may be necessary to answer questions and cope with employee turnover.
Public education can also benefit from failures. For example, certain violations of discharge practices
may be so serious, or flagrant, that a citation or fine results. The local press, if informed, may find such
an incident newsworthy. The  general public, or  other potential offenders,  may  benefit from  this
educational procedure.

    An informed public willing to act on their convictions is the product sought from public education.
The public educator focuses on large groups,  as one-on-one contact is unlikely to be either time or cost
effective.  Long range educational goals may be tackled through school programs, while shorter range
educational goals may focus  on community  groups. Public education will have to focus on broader
environmental issues than inappropriate entries to storm drains. Subgroups in the community may play
important roles in public education.  For  example,  scouts may undertake community improvement
projects including placing signs on curbside storm drains informing the public that  the drain is for
stormwater only, and not for discharge of wastes. Thus, public education must take advantage of
opportunities presented by groups looking for community improvement projects, the opportunities that
are available in working with the school system, and opportunities arising from the news media being
supplied with newsworthy items.

    The final group that public officials should address in public education is other public officials  and
governmental institutions. Some small governmental units may not know about precautions to be taken
with  discharges to storm drainage systems unless they are properly informed. Such  subgroups may
include road departments, sanitation workers, and workers at public institutions such as hospitals  and


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prisons. A multilevel, multitarget public education program can help to avoid problems.
COMMERCIAL AND INDUSTRIAL SITE DISCONNECTIONS OF NON-STORMWATER SOURCES

    Out  of  convenience and  out  of ignorance, commercial and industrial  sites may impose  an
increasing load  on the storm drainage system. This may be through direct discharges to the storm
drainage  system,  or it may be through diffuse and indirect sources in which the site grounds are
contaminated by spills and discharges which are then  washed off by storm runoff to the storm drain
during rainfall events or by washwater during wash-down operations. The problem is compounded by
the vast array of sizes of commercial and industrial enterprises. A single person  enterprise has little
opportunity to build expertise on the subject of stormwater pollution, while a large  industrial enterprise
may have an environmental division. To the uninformed person, any curb opening may be thought to
be part of a  comprehensive sanitary wastewater treatment system and the proper entrance point for
polluted water discharges or other debris.

    Corrective  measures for improper uses of storm drains have to be developed recognizing the
differences in knowledge and sophistication of the client.  Industrial users are relatively few in number
but are expected to have the most complex problems. If industrial users are aware, or made aware,
of existing and  or new federal, state, or local regulations  to prevent pollution of stormwater drainage
systems, they will usually comply with the regulation. If  not, these regulations provide the authority
and communication means to instigate corrective action.

    Commercial groups are heterogeneous.  An appropriate way of working  with them to institute
changes  in their use of  storm drainage systems, may be to work with  one category of commercial
groups at a time.  For example, consider gasoline filling stations as a single category. It is possible to
focus on correcting similar problems at many facilities that exist in this  category. The flushing of
radiators may be  seasonally common. A typical practice is to let radiator flushing waters (including
coolants) to drain to an inlet to the storm drainage system. Education followed by assurance that there
will be strict enforcement of discharge regulations or ordinances may be effective. However, a group
such  as  gasoline  filling  stations cannot be expected  to have  a  long institutional memory as new
operators take  over and others drop out. Thus, vigilance and follow-up are important to insure that
there  is not  a gradual diminution of appropriate practices.

    For both small commercial and large industrial enterprises, willful and knowledgeable violation of
the regulations  limiting entries to storm drainage systems have to be dealt with  firmly and promptly
or the enforcement program runs the chance of becoming  ineffective.  Thus the governmental  unit
undertaking responsibility for improving the practices regarding entries to storm drainage systems must
have  an enforcement plan ready.
FAILING SEPTIC TANK SYSTEMS

     Failing septic tank systems can have an impact on an otherwise well functioning storm drainage
system.  Before discussing corrective measures, it is important to identify the relationship that may
develop between a septic tank system and a storm drainage system.

     A septic tank system consists of two  major components: a septic tank and a leaching field  (a
waste spreading or soil absorption system).  In addition, of course, there is piping associated with the
system. Sanitary wastewaters are piped directly to the septic tank. The septic tank typically is made
of concrete, is rectangular in shape, is usually divided into two compartments, and has a capacity  of
one to several  thousand gallons. The septic tank serves as an anaerobic  digestion,  floatation and


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settling unit in which biological action converts the biodegradable liquid and solid waste particles into
stable  end  products.  Gravity   separates  a  significant  portion  of  both   biodegradable  and
non-biodegradable particulate matter to the tank bottom or top (depending on whether the particles
sink or rise, respectively). Some of the products of this partial  treatment process are carbon dioxide,
methane,  hydrogen sulfide and other odor producing gases, digested and refractory or  relatively
non-biodegradable sludge, and floating scum. Because the septic tank remains full, it must discharge
a volume of wastewater each time a volume of wastewater is discharged into it. This discharged water
enters a leaching field where some additional treatment occurs and the final effluent is discharged to
the ground.

    A septic  tank may be a low maintenance treatment unit, but it is not entirely maintenance free.
As the septic tank continues to be loaded, the scum and sludge layers build up so that the remaining
volume available for treatment is reduced. Thus, some of the partially digested  or undigested solids,
scum, and sludge may be carried from the septic tank to the leaching field where the soil void space
may become  clogged. As the soil voids become clogged, the ability of the leaching field to handle the
liquid portion  of the waste is reduced,  and surface ponding of the wastewater may result. Of course,
ponding could have been prevented by having the septic tank serviced; that is, by having the septic
tank pumped. Pumping removes the sludge, scum, and other  contents of the septic tank so that its
storage and treatment capacity is  restored. Pumping frequency varies depending on the size of the
septic tank and its loading  rate. Residential septic tanks may  need to be pumped every two to five
years. Commercial and institutional septic tanks may need more frequent pumping.

    Failed septic tank systems have the potential to pollute stormwater because the leaching field will
saturate the ground, and possibly form ponded water on the ground surface. The ponded water may
run off and enter a storm drain inlet or drainage ditch, or infiltrate the ground in another area which
is intercepted by a storm drain through infiltration. When it rains, any remaining ponded water may be
washed off with the runoff to the storm drainage system. Depending on the severity of the septic tank
failure, the ponded water can have the characteristics of partially treated sanitary wastewater or nearly
untreated sanitary wastewater. Thus,  septic tank failures can contaminate the  stormwater drainage
system during both  wet and dry weather.

    Septic tank systems may fail even with good maintenance practices. Such failure can result when
the soil is simply not permeable enough  for the leaching field, or when the soil absorbance capacity
is exceeded  through  long use. A tight clay soil may  have  such low permeability that the leaching
capacity  is very limited. If a number of homes are built in close proximity, their septic tank leaching
fields may collectively exceed the soil's  capacity,  leading to  a  stormwater pollution problem. Even
properly operating septic tank systems are a potential pollutant source. Because the basic function of
the leaching field is to discharge partially treated effluent to  the  ground, this septic tank effluent can
infiltrate  into  nearby stormwater drainage systems.

    Various  corrective methods exist  for failing septic tank systems that pollute stormwater. These
methods  include: improve  maintenance,  institute  preventative measures to  avoid problems,  and
abandon the septic tank system with connections made to a sanitary sewerage system. In some cases,
improved maintenance may be the answer. Some persons will  not do any maintenance to their septic
tank system  until it fails (they note ponded water  in the leaching field area). Then they call for the
septic tank to be pumped. In  many cases, this is not sufficient to correct the problem:  it may be too
little action too late. The preventative action of having the septic tank pumped should have taken place
prior to failure of the system.  Education  may provide part of the remedy. The  septic tank user may
respond to exhortations to  have the septic tank pumped on a regular basis, before failure. Coercion
through ordinances may be another answer. Ordinances may require that the septic tank be pumped
at a specified frequency, with a public body monitoring the  program to ensure that maintenance has
been carried  out.
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    It sometimes happens that soil conditions  and population density rule out both voluntary  or
involuntary maintenance. In this case, it may be necessary to consider abandoning the septic tank
system and installing a system consisting of sanitary sewers leading to a treatment plant. Another
option consists of abandoning the septic tank treatment method in favor of small package treatment
units that provide aerobic treatment of the sanitary wastewater which is then discharged to a regional
leaching field.  This option may succeed where the septic tank system has failed, because wastes
treated in an aerobic  unit may not have the leaching field clogging potential of wastes treated in  an
anaerobic septic  tank. However, experience has shown that these advantages are only obtained with
proper control  and maintenance. Aerobic systems are more sensitive than conventional septic tank
systems to improper maintenance and may therefore not offer any real benefits.
DIRECT SANITARY SEWERAGE CONNECTIONS

    Due to indifference, ignorance, poor enforcement of ordinances, or other reasons, a stormwater
drainage system may have sanitary wastewater sewerage direct connections. Obviously, the sanitary
wastewater entering the storm drain will not receive any treatment and will pollute a large flow of
stormwater, in addition to the receiving water. If the storm drain has a low dry-weather flow rate, the
presence of sanitary  wastewater may be obvious due to toilet paper, feces, and odors.  In cases of
high dry-weather flows, it may be more difficult to obviously detect raw sanitary wastewaters due to
the low percentage of sanitary wastewater  in the mixture.  Even though the sanitary wastewater
fraction may be low, the previously  discussed field testing  procedures (e.g., testing for surfactants,
ammonia,  potassium,  and fluorides) will assist in  the detection and  quantification  of sanitary
wastewater contamination in the storm drainage system. Flow monitoring may show the variations in
the flow rate that are typical of sanitary  wastewater.

    Dye testing can be effective in finding specific sanitary wastewater connections between a house
and a  storm drainage system. Dye, such as diluted rhodamine or fluorescein, is flushed down the toilet
of a house and the storm drain is monitored to determine whether the dye appears. Care has to be
exercised  when using this method, as these dyes may stain fixtures that are being tested, and any
spillage in the house causes stains that are very difficult to  remove.

    Monitoring of the storm drainage system with television  cameras can show the locations of breaks
in the storm drain where  a  sanitary wastewater sewer or house lateral  was attached. Television
cameras may also  show discharges  taking place at these locations, demonstrating that the lines are
in active use.

    Corrective  measures  involve  undertaking  a program  of disconnecting the  sanitary sewer
connections to  the storm drainage system and reconnecting  them to a proper sanitary wastewater
sewerage  system.  The storm drainage system then  has to  be repaired so that the holes left by the
disconnected sanitary sewer entrances do not become a location for dirt and groundwater to  enter.
REHABILITATING STORM OR SANITARY SEWERS TO ABATE CONTAMINATED
WATER INFILTRATION

     Infiltration of contaminated water into  a  stormwater drainage system can  cause substantial
pollution of the system. This could occur where a sanitary sewer overlies and crosses (or parallels) a
storm drain, with sanitary wastewater exfiltrating from the sanitary sewer and percolating the storm
drain. Other instances would be in areas of polluted groundwater, where the storm drainage is below
the water table or intercepts infiltrating  groundwater, or in areas  having septic  tank systems,  as
discussed previously.


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    It would be best to correct the sanitary sewer if only one drainage system can be corrected. This
would have the  dual advantage of preventing  infiltration  of  high or percolating groundwaters and
preventing pollution of stormwater with exfiltrating sanitary wastewater. Rehabilitation of the drainage
systems  by use  of inserted liners, or otherwise patching leaking  areas,  are  possible corrective
measures. It is important that all drains with infiltration problems be corrected for this corrective action
to be effective. This would also include repairing house lateral sanitary wastewater  lines, as well as
the main drainage runs. However, these corrective measures are more likely to be cost effective when
only a relatively small part of the complete  drainage systems require rehabilitation.
ZONING AND ORDINANCES

     Land use controls achieved by zoning have the potential to exacerbate problems or diminish them.
For example, in an area with soils that are ill suited for septic tanks and leaching fields, the potential
for future problems is increased if zoning allows small lots for single family residential development and
allows septic tank systems. As the area  develops, septic tank failures will become common, resulting
in increased pollution of stormwater and groundwater. On the other hand, in areas having poor soils,
zoning can require correspondingly larger lot sizes and larger leaching fields, resulting in fewer future
problems. Ordinances may specify the results that have to be achieved by infiltration tests used to size
leaching fields. Also,  ordinances can require  that a responsible public official be present when the
infiltration test is run to decrease the likelihood of false or  spurious results being reported. Certified
septic tank installers, also checked by public official inspectors, should also be required to increase the
likelihood of the system being installed correctly.

     Zoning can also have a role to play in avoiding development of land that is subject to frequent
flooding. In such land, flooding and high groundwater conditions can result in the sanitary sewerage
system being gradually overloaded by infiltration so that cross flow to the storm drainage system can
occur.

     Ordinances can help to control  problems by putting the force of law  and public policy behind
desirable practices. For  example,  ordinances can make mandatory practices  such as septic tank
maintenance that otherwise would be voluntary. By making the practice mandatory, desirable practices
are  performed on a  regular schedule  so  that large problems  have less  opportunity  to develop.
Ordinances can also regulate the persons doing the pumping of septic tanks so that they discharge the
septage to wastewater treatment plants  where it can be properly treated  rather than  it  being
discharged improperly where the pollution problem is just transferred from one location to another.

     Ordinances can also help prevent and or control pollution from many other sources by restrictions
on: disposal of household toxic substances to storm drains, storage of chemicals by  industry, disposal
of industrial wash down water, etc.

     Zoning and ordinances represent important means for  governing  bodies to anticipate problems,
to avoid problems, and to manage problems, so that desirable ends are achieved and undesirable
consequences are avoided.  Enactment  of zoning and ordinances occurs in the public arena where
interested  persons  can participate and  express  their views and concerns. The public can become
educated  in this process, but zoning  and ordinances have the  desirable characteristic of  being
remembered and remaining  enforceable long after an individual forgets, becomes  disinterested,  or
becomes recalcitrant.

     Another important step that municipalities can take is the development of policies and procedures
for the management of spills from transportation (including  both roadway  and  rail) and  pipeline
accidents.  Spills should not be merely washed into the storm drainage system, but should be collected


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for proper treatment and disposal.
WIDESPREAD SANITARY SEWERAGE FAILURE

    Connections (whether directly  by piping or indirectly  by exfiltration or infiltration) of sanitary
sewers to the storm drainage system may be so widespread that the storm drainage system has to be
recognized as a combined sewer system. This could also be the case when the prevalence of septic
tank failures leads to widespread sanitary wastewater runoff to the storm drainage system. One usually
thinks of a combined sewer system as having all of the sanitary sewer connections to the same sewers
that carry stormwater, but the previous discussion suggests that there are degrees of a storm drainage
system becoming a combined sewer system. Previously, the recommendations have been made that
widespread failure of septic tank systems might necessitate the construction of a sanitary sewer to
replace the  septic tanks. Also recommended  was a program of identifying and disconnecting sanitary
sewers from the storm drainage system.

    Prior to these  actions taking place,  the storm drainage system operates to some degree as a
combined sewer system. It may be that the sanitary sewerage system is not capable of handling the
load that would be  imposed on it if a complete sewer separation program were undertaken. Or, in an
extreme case, no sanitary sewer system may  exist. By recognizing that a combined sewer system does
in fact exist may help to focus attention  on  appropriate remedial measures.  The resources may also
not be available to undertake construction of a separate sanitary wastewater drainage system.

    One should then focus on  how to manage  the combined sewer system  that is in place.
Management may require that end-of-pipe storage/treatment be investigated. Also, the combined sewer
system may be tied into other combined  sewers so that more centralized treatment and storage can
be applied.  Operation of a combined sewer system  may be preferable to having the stormwater and
the large number of sanitary entries receive no treatment.

    An early identification and decision to  designate  a storm drainage system a combined sewer
system, will prevent abortive time and costs being spent on further investigations. These resources can
then be more effectively used to treat the newly designated combined sewer system.

    In essence, recognition of a system  as being a combined  sewer system  provides a focus in the
regulatory community so that it may be possible to operate the system so as to minimize the damage
to the environment.
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                                         GLOSSARY
Accuracy  - The combination of bias  and precision of an analytical procedure which  reflects  the
closeness of a measured value to a true value.

Baseflow - The dry-weather flow occurring in a drainage system, with no apparent source. Likely to
be  mostly infiltrating  groundwaters  in a  sanitary or storm  drainage  system,  but  can also  be
contaminated with illicit wastewaters. See constant (or continual) dry-weather flow.

Batch dump - The disposal of a large volume of waste material during a short period of time. Usually
an industrial waste.

Bias - A consistent deviation of measured values from the true value, caused by systematic errors in
a procedure.

Coefficient of Variation (COV) - A measure of the spread of data (ratio of the standard deviation to the
mean).

Combined Sewer - A sewer designed  for receiving surface (dry- and wet-weather) runoff, municipal
(sanitary and industrial) wastewater, and subsurface waters from infiltration. During dry weather, it
acts as a sanitary sewer, but it also carries stormwater from wet-weather runoff.

Combined sewer overflow  (CSO) - Flow from an outfall  (discharge conduit) of a combined sewer
collection system, in excess of the interceptor capacity or due to a malfunctioning or improperly set
flow  regulator, that  is discharged  into  a  receiving water  and/or  an  auxiliary CSO  control
storage-treatment system.

Constant  (or continual) dry-weather flow  - Uninterrupted flow  in a storm sewer  or drainage ditch
occurring in the absence of rain. See baseflow.

Deposits and stains -  Any type of coating or discoloration that remains at an outfall  as result of
dry-weather discharges.

Detection limit  - A number of different detection limits have been defined: IDL (instrument detection
limit), is the constituent concentration  that produces a signal greater than five times the signal to noise
ratio of the  instrument; MDL  (method detection limit) is the  constituent concentration that,  when
processed through  a complete method, produces a signal with a  99 percent probability that it is
different from  a blank; PQL (practical quantification limit) is  the lowest constituent concentration
achievable among laboratories within  specified limits during routine  laboratory operations.  The  ratios
of these limits are approximately: IDL:MDL:PQL =  1:4:20 (APHA, et al. 1989).

Direct (dry-weather) entries  into the storm  drainage system - Sources which enter a storm drainage
system directly, usually by direct piping connections between the wastewater conduit and the  storm
drain.

Domestic sanitary wastewater - Sewage derived principally from human sources.

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Drainage area - The area of land from which a storm drainage system collects precipitation and storm
runoff and then delivers the resulting stormwater to a specific  point.

Dry-weather flow - Flow in a storm sewer or drainage ditch occurring in the absence of storm flow.
But it is also a constituent of wet-weather flow. See baseflow.

Entries to storm drainage - Water (relatively clean or polluted) discharged into a stormwater drain from
sources such as, but not limited to, direct industrial or sanitary  wastewater connections, roof leaders,
yard and area drains, cooling  water connections, manhole covers, groundwater or subterraneous
stormwater infiltration, etc.

Floatables - Floating materials, (plastic containers, condoms, sanitary napkins, tissues, corks,  paper
containers, wood, leaves, oil films, slimes, scum,  etc.), that are either part of the inappropriate waste
streams discharged to a stormwater system, or collected by flows which enter a stormwater drainage
system.

Geographic Information System (GIS) - Computer software that maps land areas and produces images
and information relating to the  land area, e.g., topography, drainage, public utilities, roads, buildings,
industry, land use, and demography.

Groundwater infiltration - Seepage of below water table groundwater and  subterraneous stormwater
into stormwater, sanitary wastewater, or combined sewer drainage systems, through such means as
defective pipes, pipe joints, connections, or manhole walls.

Hardness - Caused by the presence  of the divalent cations (principally calcium  and magnesium) in
water.  Causes an increased amount of soap usage before producing a lather and scale to form  in hot
water pipes, boiler vessels, condensate return lines, cooling systems, kettles, etc.

House  Lateral - A pipe connecting  a house to a lateral or other sewerline.  Also called a service
connection.

Indirect dry-weather entries into the storm drainage system - Non-stormwater sources which enter a
storm drainage system indirectly, usually by floor, areaway, and yard drains or inlets; and spills and
dumping.

Industrial dry-weather entries into the storm drainage system - Any solid or liquid waste coming from
industrial sources which enter  storm  drainage systems during  periods of dry weather.

Infiltration - The process whereby water enters a drainage system underground through such means
as defective pipes, pipe joints,  connections, manhole walls, etc.

Inflow  -  The process whereby water enters a sanitary  wastewater drainage system  from surface
locations, (e.g., through depressed manhole covers, yard and  areaway  inlets, roof leader setc.).

Intercepted stormwater/groundwater - The  portion of surface runoff or groundwater moving through
the soil that enters a storm drainage, combined sewer, or sanitary sewer system.

Interceptor - A sewer  that receives flows from a number of wastewater trunk lines.

Intermittent dry-weather flow - Irregular  flow in a storm drainage system occurring in the absence of
storm flow.
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Lateral - A drain or sewer that has no other drains or sewers discharging into it, except for service
connections, or house laterals.

Leaching field - A system which facilitates the infiltration of a septic tank effluent into the soil. This
is typically done by a pipe and infiltrating trench system which takes the effluent from a septic tank
and distributes  it through the leaching field, where additional treatment of the effluent occurs as it
percolates through the ground or soil column.

Monte Carlo probabilistic simulation - A statistical modeling approach used to determine the expected
frequency and magnitude of an output by running repetitive simulations using statistically selected
inputs for the model parameters.

Municipal sewage/wastewater - Sewage/wastewater  from a community which may be composed of
domestic sewage/wastewater, industrial wastewater and/or  commercial wastewater, together with
subsurface infiltration.

National  Pollution Discharge Elimination System  (NPDES) - A national system  of permits issued to
industrial, commercial,  and municipal dischargers to limit the amount of pollutants  that can  be
discharged to waters of the USA.

Non-contact cooling water - Water that decreases the temperature of an object, without ever physically
contacting the object.

Nonpoint pollution source-  Any unconfined and nondiscrete  conveyance from  which pollutants are
discharged, or  an  urban drainage system not under the NPDES.  These sources are  usually from
agricultural, silvicultural, and rural land areas..

Outfall -  In this User's  Guide, an outfall refers to a  point at which a stormwater drainage system
discharges to a receiving water. There  is sometimes a concrete structure or retaining wall at this
location to protect the end  of the  discharge pipe and  prevent erosion of the receiving water bank.

Pathogen -A disease-causing microorganism.

Point source -Any discernible, confined, and discrete conveyance from which pollutants are, or may
be, discharged.  Under the NPDES  it is an outfall discharge, or overflow of  treated  or untreated
sanitary, industrial, combined sewage, or stormwater (from  a municipality greater than 100,000 in
population).

Pollutant - Any  material  in water or wastewater interfering with designated beneficial uses.

Potable  water - Water  that has been treated,  or  is naturally fit for drinking, i.e., the  water has no
harmful  contents to make it unsuitable for human consumption.

Precision - The  measure of the  degree of agreement among  replicate  analyses of a sample, usually
expressed as the standard deviation.

Pretreatment - The removal of material such as, gross solids, grit, grease, metals, toxicants, etc. or
treatment such  as aeration, pH  adjustment,  etc. to improve the quality of a wastewater prior to
discharge to a municipal wastewater system. This is usually done by the industrial user of the water,
but can  also refer to the initial treatment processes of a sewage treatment plant.

Process line discharge -The disposal of anything used in, or resulting from, a manufacturing process.


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Process water - Water used in industry to  perform a variety of functions, or as an actual product
ingredient.

Receiving waters - Natural or man-made water systems into which stormwaters, or wastewaters, are
discharged.

Rinse water - Water that cleans or reduces the temperature of an object through  actual physical
contact with the object.

Sanitary sewer  - A sanitary  wastewater  drainage system intended to carry wastewaters from
residences, commercial buildings, industrial  plants, and institutions together with minor quantities of
groundwater, stormwater and surface water that are not admitted intentionally [40 CFR 35.2005 (b)
(37)].

Sanitary wastewater - Wastewater of human origin.

Service Connection  - See house lateral

Septic tank - A tank which receives sanitary wastewater direct from its source, (usually residential),
and  permits settling of the heavy solids and floatation of greases and fats  along  with  anaerobic
digestion. Septic tanks, typically need to meet minimum regulatory standards, e.g., minimum volume
and detention time.

Sewage - In this text the term "sewage" refers to sanitary wastewater or wastewaters generated from
commercial or industrial operations, it does  not include stormwater.

Sewer -A pipe, conduit or drain generally closed, but normally not flowing full, for carrying sanitary,
industrial and  commercial wastewater  and  storm-induced (combined wastewater and stormwater)
flows.

Sewerage -  System  of piping  and  appurtenances, with and without control-treatment facilities for
collecting and conveying wastewaters with  or without pollution abatement from source to discharge.

Specific Conductivity - Expressed in microSiemens/cm (or micromhos/cm). It is an indication of the
dissolved solids (charged) concentration in a liquid.

Storm drainage discharge - Flow from a storm drain that is discharged to a receiving water.

Storm drain - A  pipe, or natural  or man-made channel, or ditch,  that is  designed to carry  only
stormwater, surface runoff, street  washwaters, and drainage from source to point of discharge [40
CFR 35.2005 (b) (47)].

Stormwater  -  Water   resulting  from  precipitation  which  either  infiltrates   into the ground,
impounds/puddles, and/or runs freely from the surface, or  is captured by storm drainage, a  combined
sewer, and to a limited degree, by  sanitary  sewer facilities.  See urban runoff and urban stormwater
runoff.

Surfactants - Surface-active agents and common components in detergents which affect the surface
tension of water and can cause foaming.

SIC - Standard Industrial Classification,  a code used to describe an industry.
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Total  solids - The entire  quantity of solids in the liquid flow  or volume including the dissolved and
paniculate  (suspended, floatable, and settleable) fractions.

Toxicity - The degree to which a pollutant causes physiological harm to the health of an organism.

Tracer -  In this User's Guide,  a tracer is  a  distinct  component,  or  combination of components
("fingerprint"), of a  polluting source which is identified in order to confirm the entry of the polluting
source to a storm drainage system.

Trace Metals - Metals present in small concentrations. From a regulatory standpoint, this usually refers
to metal  concentrations that can cause toxicity at trace concentrations.

Turbidity - The  lack of clarity in the water usually caused  by suspended particulate  matter and
measured by interference to light penetration.

Urban runoff - Any runoff stormwater from an urban drainage area that reaches a receiving water body
or subsurface. During dry weather, it may be comprised of many baseflow components, both relatively
uncontaminated and contaminated.  See stormwater and urban stormwater runoff.

Urban stormwater runoff - Stormwater from an urban  drainage area that reaches a receiving water
body  or subsurface caused by weather precipitation (rain,  snow, etc.). See stormwater and urban
runoff.

Watershed - A geographic region (area of land)  within which precipitation drains into a particular river,
drainage system or  body of water that has one specific delivery point.

Wet-weather flow - Any flow  resulting from  precipitation (rain, snow, etc.)  which may introduce
contaminants into storm  drainage combined  sewerage, or sanitary sewerage systems.
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                                       REFERENCES
Alhajjar, Bashar J., John M. Harkin, and Gordon Chesters. "Detergent Formula and Characteristics of
Wastewater in Septic Tanks". Journal Water Pollution Control Federation, Volume 61, Number 5. May
1989.

APHA (American Public Health Association), American Water Works Association, and Water Pollution
Control Federation.   Standard Methods for the Examination  of Water and Wastewater,  17th edition.
American Public Health Association. Washington, D.C. 1989.

Beyer, D.L., P.A. Kingsbury, and J.E. Butts. History and Current Status of Water Quality and Aquatic
Ecology Studies in the Lower Chehalis River and Grays Harbor, Washington. Prepared for Washington
Public Power Supply System. 1979.

Cochran, William G. Sampling Techniques. Second edition. John Wiley and Sons, Inc. New York. 1 963.

Evans, R.L. "Addition of Common Ions from Domestic Use of Water."  Journal American  Water Works
Assn. Volume 60, No.3. p 315. 1968.

EPA (U.S. Environmental Protection Agency). Results of the Nationwide Urban Runoff Program, Water
Planning Division, NTIS number PB 84-185552, Washington, D.C., December 1983.

Falkenbury, John. Water Quality Standard Operating Procedures. City of Fort Worth  Public Health
Department, 1800 University Drive, Fort Worth, Texas  76107. 1987.

Falkenbury, John. City Of Fort Worth Water Pollution Control Program Overview. Fort  Worth Public
Health Department,  1800 University Drive, Fort Worth,  Texas 76107.  1988.

GLA (Gartner Lee and Associates, Ltd.). Toronto  Area Watershed Management Strategy Study,
Technical Report #1, Humber River and Tributary Dry-weather Outfall Study. Ontario Ministry of the
Environment.  Toronto, Ontario,  November 1983.

Hypes, W.D., C.E. Batten, J.R.  Wilkins.  Processing of Combined Domestic Bath and  Laundry Waste
Waters  for Reuse  as  Commode  Flushing Water. Technical  Report NASA TN D-7937.  National
Aeronautics and Space Administration. October, 1975.

Montoya, Barry L. Urban Runoff Discharges From Sacramento, California. Prepared for  the California
Regional Water Quality Control  Board, Central  Valley Region, CVRWQCB Report Number 87-1 SPSS.
1987.

Moore, A.H. and Dena Hoffpauir. Biotoxicitv Testing. Fort Worth Health Department, 1800 University
Drive, Fort Worth, Texas  76107. 1988.

Murray,  James  E.,  Washtenaw  County Drain Commissioner.  Statement   To  The  Board  Of
Commissioners. December 1985.

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Pelletier,  G.J. and  T.A.  Determan.  Urban Storm Drain Inventory Inner Gray Harbor.  Prepared for
Washington State Department of Ecology, Water Quality Investigations Section, Olympia, Washington.
1988.

Pitt, Robert and Melinda Lalor. Birmingham, Alabama, Draft Final Report: Demonstration Project for the
Investigation of Inappropriate  Pollutant  Entries  into  Storm Drainage Systems. U.S. Environmental
Protection Agency. Storm and Combined Sewer  Pollution Control  Program. Edison,  New Jersey.
Contract  No: 68-C9-0033. Publication pending.

Pitt, Robert and James McLean. Toronto  Area Watershed Management Strategy Studv: Number River
Pilot Watershed Project.  Final  Report. The Ontario Ministry Of The  Environment. Toronto, Ontario.
1986.

Schmidt,  Stacy D. and Douglas R. Spencer. "The Magnitude of Improper Waste Discharges in an Urban
Stormwater System", Journal Water Pollution Control Federation, Volume 58, Number 7. July  1986.

van der Leeden,  Frits, Fred L. Troise and David Keith Todd. The Water Encyclopedia. Lewis Publishers.
Chelsea,  Michigan. 1990.

Verbanck, Michel, Jean-Pierre Vanderborght, Roland Wollast. "Major Ion Content of Urban Wastewater:
Assessment of Per Capita Loading." Journal Water Pollution Control Federation. Volume 62, Number
1. January, 1990.

Washtenaw County Drain Commissioner and Washtenaw County Health Department. Allen Creek Drain
Water  Quality Survey - Status Report. September 1984.

Washtenaw County Statutory Drainage Board. Huron River Pollution Abatement Program. September
1987.

Washtenaw County Drain Commissioner. Huron  River Pollution Abatement Project, Summary.  1988.

Washtenaw County Statutory Drainage Board. Huron River Pollution Abatement Program. September
1987.
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