United States
Environmental Protection
Agency
Office of Water
(4203)
Washington, DC 20460
tPA833-R-00-001
February 2000
Report to Congress On
The Phase I Storm Water
Regulations
        U.S. EPA Headquarters Library
            Mai! code 3201
        1200 Pennsylvania Avenue NW
          Washington DC 20460

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                               ACKNOWLEDGMENTS
Technical assistance in the preparation of this report was provided by the following contractors:

       Tetra Tech, Inc., of Fairfax, Virginia, under subcontract to Northbridge Management
       Consultants, contract number 68-C-98-071

       Science Applications International Corporation (SAIC), Inc., of Reston, Virginia, under
       contract number 68-C4-0034.

The report was prepared under the direction of Daniel Weese, Patrick Ogbebor, and Ross
Brennan of EPA's Office of Wastewater Management. Thomas O'Connor, of EPA's Office of
Research and Development, and Peter Swenson, of EPA's Region 5, provided valuable
comments.

EPA also gratefully acknowledges the assistance of the cities used as case studies in this report.
                                  U.S. EPA Headquarters Library
                                         Mail code 3201
                                  1200 Pennsylvania Avenue NW
                                     Washington DC 20460

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                     TABLE OF CONTENTS
EXECUTIVE SUMMARY	ES-1

1.  INTRODUCTION	1-1
      1.1   PURPOSE OF THE REPORT	1-1
      1.2   ENVIRONMENTAL IMPACTS OF STORM WATER	1-1
           1,2.1   Early Efforts to Document Storm Water Impacts 	1-2
           1.2.2   Recent National Summary of Storm Water Discharge Impacts	1-3
      1.3   STORM WATER PROGRAM HISTORY	1-5
      1.4   PHASE I PROGRAM STATUS 	1-8
           1.4.1   Municipal	1-8
           1.4.2   Industrial  	1-9
           1.4.3   Construction	1-10
      1.5   ORGANIZATION OF REPORT	1-11

2.  APPROACH USED IN THIS REPORT	2-1
      2.1   THREE TYPES OF INDICATORS  	2-1
           2.1.1   Programmatic Indicators	2-1
           2.1.2   Loading Reductions	2-2
           2.1.3   Water Quality Improvements	2-2
      2.2   OVERVIEW OF METHODOLOGIES USED FOR THE ANALYSIS OF
           THE PHASE I PROGRAM	2-3

3.  EVALUATION OF PROGRAM FOR MUNICIPAL SEPARATE STORM SEWER
   SYSTEMS 	3-1
      3.1   STATEMENT OF PHASE I REQUIREMENTS 	3-1
           3.1.1   MS4s Regulated Under the Phase I Program	3-2
           3.1.2   Permit Application Requirements For Medium And Large MS4s ....  3-2
           3.1.3   NPDES Permit Requirements  	3-4
           3.1.4   Current Status of Phase IMS4 Program 	3-5
      3.2   ANALYTICAL APPROACH	3-6
      3.3   SPECIFIC METHODS AND RESULTS 	3-8
           3.3.1   Programmatic Indicators	3-8
           3.3.2   Loading Reductions	3-16
           3.3.3   Water Quality Indicators 	3-22
      3.4   FINDINGS OF THE REVIEW OF THE PHASE I PROGRAM FOR
           MUNICIPAL SEPARATE STORM SEWER SYSTEMS 	3-27
           3.4.1   Successful Attributes of the Phase I Program for MS4s  	3-27
           3.4.2   Components of the Phase I Program That May Need to be Addressed 3-29

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E.  PHASE I CONSTRUCTION ACTIVITY LOAD REDUCTIONS	E-l
F.  WATER QUALITY IMPROVEMENTS FROM SIMILAR CONSTRUCTION
   CONTROL PROGRAMS 	
F-l
G. STORM WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
   (EXCERPTS FROM 40 CFR 122.26(b)(14)) 	 G-l
H MSGP STORM WATER POLLUTION PREVENTION PLAN (SWPPP)
  REQUIREMENTS	
H-l
I. INDUSTRY SECTORS/SUBSECTORS SUBJECT TO ANALYTICAL MONITORING
  UNDER EPA's MULTI-SECTOR GENERAL PERMIT	 1-1

J. COMPARISON OF GROUP APPLICATION DATA AND DMR DATA FOR STORM
  WATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY	J-l

K RANKING OF MEAN REDUCTIONS IN POLLUTANT CONCENTRATIONS BY
  SUBSECTOR	 K-l
REFERENCES

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                              LIST OF ACRONYMS
ASWIPC A   Association of State and Interstate Water Pollution Control Administrators
BMP         Best management practice
CSO         Combined sewer overflow
CWA        Clean Water Act
CZARA      Coastal Zone Act Reauthorization Amendments of 1990
CZMA       Coastal Zone Management Act
GPRA       Government Performance and Results Act
LID          Low-impact development
MS4         Municipal separate storm sewer system
MSGP       Multi-Sector General Permit
NAFSMA    National Association of Flood and Stormwater Management Agencies
NOI          Notice of intent
NPDES      National Pollutant Discharge Elimination System
NRDC       Natural Resources Defense Council
NURP       Nationwide Urban Runoff Program
OWM       EPA Office of Wastewater Management
POTW       Publicly owned treatment works
SIC          Standard Industrial Classification code
SWPPP      Storm water pollution prevention plan
USAGE      U.S. Army Corps of Engineers
USEPA      U.S. Environmental Protection Agency
USGS       U.S. Geological Survey
WEF         Water Environment Federation
WQA        Water Quality Act

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                               EXECUTIVE SUMMARY

The United States Environmental Protection Agency (EPA) is submitting this Report to Congress
in accordance with section 431(b) of the Department of Veterans Affairs and Housing and Urban
Development and Independent Agencies Appropriations Act of 2000, Public Law 106-74 (1999).
The Appropriations Act directed EPA to conduct an evaluation of the Phase I Storm Water
Program as follows:

       No later than 120 days after the enactment of this Act, the Environmental
       Protection Agency shall submit to the Environment and Public Works Committee
       of the Senate and the Committee on Transportation and Infrastructure of the
       House of Representatives a report  containing a detailed explanation of the impact,
       if any, that the Phase I program has had in improving water quality in the United
       States (including a description of specific measures that have been successful and
       those that have been unsuccessful).
In response to the mandate of the Appropriations Act, EPA conducted a review of existing and
readily available information on the status and effectiveness of the Phase I storm water program.
This review has led the Agency to the following findings:

•      Although information on the water quality impacts of Phase I is unavailable at the
       national level, loading reductions and subsequent water quality impacts have been
       documented on the site-specific level.

       The fundamental approach for addressing storm water discharges under the Phase I
       program involves the use of site-specific storm water pollution prevention plans
       (SWPPPs) and best management practices (BMPs).  These measures or practices, used to
       reduce the amount of pollution entering water bodies, can be implemented cost-
       effectively.

•      The flexible nature of the program has encouraged innovation on the part of
       municipalities, construction operators, and industrial facilities and allowed them to tailor
       control programs to their own unique circumstances.

•      Further improvements can be made in both program design and implementation to
       enhance effectiveness.
In developing this Report to Congress, EPA was aware that the issue of storm water impacts to
surface waters pre-dated the Phase I program.  EPA wishes to acknowledge and applaud the
efforts of many entities to address the potential impacts on water quality associated with storm
water discharges prior to the Phase I program. These efforts include for example, various

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avoiding duplication of effort where significant progress had already been made. Through the
requirement to develop site-specific storm water management programs, EPA also acknowledged
that industrial facilities and municipalities are in the best position to determine the appropriate
combination of storm water management practices for their own circumstances.

The regulations, promulgated on November 16,1990 (55 FR 47990), require NPDES permits for
discharges from two broad categories of storm water discharges: (1) municipal separate storm
sewer systems (MS4s) serving populations of 100,000 or more and (2) discharges associated with
industrial activity (including discharges from construction activities disturbing 5 acres or greater
of total land area). A definition of each of these regulated parties, along with a short summary of
associated requirements, follows.

Municipal Separate Storm  Sewer Systems (MS4s). An MS4 is a conveyance or system of
conveyances that is owned or operated by a Federal, State, or local government entity and is
designed for collecting and conveying storm water (which is not part of a publicly owned
treatment works). The November 1990 regulations specifically identified 220 municipalities
whose MS4s were subject to the Phase I program. The municipalities were required to submit
applications that identified a  variety of site-specific pollution prevention measures, source
controls, and BMPs to control pollutants from targeted sources within the municipality.  Phase I
MS4s were to develop storm water management programs that included identifying major
outfalls and pollutant loadings; detecting and eliminating non-storm water discharges to the
storm sewer system; using pollution prevention techniques to reduce pollutants in runoff from
industrial, commercial, and residential areas; and controlling storm water discharges from new
development and redevelopment areas.

Storm Water Discharges Associated with Industrial Activities.  The Phase I program also
addresses storm water runoff from industrial facilities. Regulated facilities must develop and
implement a site-specific storm water pollution prevention plan (SWPPP) to prevent, reduce, or
control storm water pollutant sources using, among other techniques, low-cost BMPs.  Common
BMPs include good housekeeping, employee training, site inspections, spill prevention and
response, and preventive maintenance activities.

EPA and authorized States have relied on the use of general permits as the primary mechanism
for providing permit coverage for storm water discharges associated with industrial activities.
Currently, EPA's  1995 multi-sector general permit (60 FR 50804, September 29,1995) identifies
storm water control guidelines for 30 different industrial sectors. The general permit's most
significant requirement is development and implementation of a site-specific SWPPP.

Storm Water Discharges Associated with Construction Activities. Under the Phase I
program, "storm water discharge associated with  industrial activity" includes storm water
discharges from construction activities (including grading, clearing, excavation, or other
earthmoving activities) that result in the disturbance of 5 or more acres of total land area. EPA's
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EPA used three types of indicators to measure program effectiveness for this Report:

1.      Programmatic Indicators.  Programmatic indicators are measures of the effectiveness of
       administrative activities undertaken by permitting authorities and the regulated
       community.

2.      Loading Reductions.  This Report describes (1) actual or estimated reductions in
       loadings of various pollutants achieved in specific cases as a result of Phase I BMPs and
       (2) estimated national loadings of sediment averted as a result of Phase I controls.
       Although the Appropriations Act specifically requested information on water quality
       improvements that have resulted from implementing Phase I, EPA does not have this data
       readily available and could not collect it in time to meet the deadline for the report.
       Another equally significant measurement of the Phase I program's progress is the degree
       to which water quality was protected from degradation.

3.      Direct Measures of Water Quality Improvements. In this Report, EPA provides
       subjective and objective assessments on a site-specific basis and through qualitative
       surveys of the water quality benefits attributable to the Phase I program.

This Report to Congress is organized as follows:

•      Chapter 1 provides background information on the Phase I program.

•      Chapter 2 summarizes the methodology used to respond to Congress's request.

•      Chapter 3 presents EPA's evaluation of the Phase I storm water program for municipal
       separate storm sewer systems.

•      Chapter 4 presents EPA's evaluation of the Phase I storm water program for
       construction activities.

•      Chapter 5 presents EPA's evaluation of the Phase I storm water program for industrial
       activities.
FINDINGS

This Report documents a number of specific cases where the Phase I storm water control
program has contributed to water quality protection and improvement. When EPA initiated this
study, it was unclear whether the Agency would be able to attribute water quality improvements
to the program. EPA recognized that the wide variety of pollutant sources, including for
example in-place contaminated sediments, airborne deposition, and other point and nonpoint
sources, would complicate any attempt to attribute water quality improvements to a single

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Specific case studies cited in this Report also document loading reductions as a result of storm
water control programs, many of which were developed or enhanced as a result of Phase I.  Case
study findings include the following:

•      By eliminating illicit connections to their MS4, Portland, Oregon, reduced annual
       pollutant loads due to wash water discharges, accidental spills, and erosion/sedimentation
       by 1,980 pounds of total suspended solids (TSS), 330 pounds of biochemical oxygen
       demand (BOD), 40 pounds of nitrogen, 10 pounds of phosphorous, 400 pounds of diesel
       fuel, and 4 pounds of oil and grease.

       Three storm water ponds in Austin, Texas's Central Park area provide environmental,
       economic, and aesthetic benefits. By capturing 300,000 cubic feet of rainfall runoff, the
       ponds annually remove 36,400 to 50,000 pounds of sediment, 55 to 275 pounds of
       nitrate/nitrite, 55 to 2000 pounds of phosphorous, 5 to 50 pounds of lead, and 10 to 150
       pounds of zinc.  Additional downstream benefits include improved oxygenation and
       flooding and erosion control.

•       In Palo Alto, California, implementation of BMPs at vehicle service facilities
       significantly reduced concentrations of several toxic metals in storm water including
       copper (89 percent),  lead (96 percent), nickel (93 percent), and zinc (77 percent) between
       1993 and 1996.

•       In Tulsa, Oklahoma, monitoring data from an iron foundry identified elevated levels of
       TSS in storm water discharges from the facility. The facility was able to reduce
       concentrations of TSS in its storm water discharges by 90 percent compared to their pre-
       phase  I baseline through the implementation of BMPs, such as improved housekeeping,
       and the addition of a filtering system and storm water retention basin to promote settling.

•       Prince George's County, Maryland's Low-Impact Development (LID) program uses a
       wide array of simple, cost-effective BMPs that infiltrate storm water runoff from new
       developments. LID techniques decrease runoff generation by between 75 and 95 percent
       from earlier land development designs, and, on a composite basis, are estimated to reduce
       nutrient and metal pollutant loadings by over 80 percent. Prince George's County has
       been piloting the LID program since the early 1990's, and has recently incorporated the
       program into their storm water management plan.

•       Montgomery County, Maryland's structural BMPs prevented 23 percent of the potential
       sediment load (in the absence of BMPs)and 27 percent of the potential nitrogen load
       within its jurisdiction from entering streams in 1998.
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Additionally, as part of this Report, EPA conducted a statistical analysis of the relationship
between water quality and the implementation of storm water controls in Florida. That analysis
provided limited evidence of a positive relationship between the implementation of storm water
controls on construction activities and the key water quality parameter of total suspended solids.

To comply with the Appropriations Act, EPA has also identified successful and unsuccessful
measures of the Phase I program. These measures are recounted below.
Successful Measures of the Phase I Storm Water Program

The fundamental approach for addressing storm water discharges under the Phase I program
involves the use of site-specific storm water pollution prevention plans (SWPPPs) and best
management practices (BMPs).  These measures or practices, used to reduce the amount of
pollution entering water bodies, can be implemented cost-effectively.

As noted above, some of the case studies collected for this Report identify specific loading
reductions and water quality benefits.  The Phase I program is based on the use of low-cost,
common-sense  solutions that appear to be widely accepted by the regulated entities and the
public.  In implementing control measures, Phase I permittees can take advantage of a
comprehensive  "menu" of structural and nonstructural BMPs, selecting those that are most
effective on a site-specific basis.

Indeed, 75 percent of industrial respondents to the WEF survey consider BMPs such as good
housekeeping, visual inspections, employee training, spill prevention and response, and
preventive maintenance to be both applicable and moderately or highly effective. In some cases,
these "nonstructural" BMPs can also lead to economic benefits to a facility in areas such as
materials management and inventory control principles.

Municipal surveys by EPA and NAFSMA, and the industry survey by WEF, point to two
particular BMPs — illicit discharge control and public outreach and training — as being
particularly effective components of municipal and industrial storm water management
programs.  Examples of the effectiveness of these two BMPs are provided below.

Illicit Discharge Control

•      In Boston, Massachusetts, 23 illicit connections, including a discharge of 71,000 gallons
       per day  of raw sewage, were found and eliminated. The Charles River's environmental
       report card has improved from a "D" to a "B-minus" as the result of this and other wet
       weather control programs.

•      Portland, Oregon's Phase I program involves regular monitoring for pollutants at storm
       water outfalls and has effectively halted illicit pollutant discharges.

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effort, emphasizing integration of programmatic requirements so States and localities could
leverage the Phase I program to support existing programs. Case studies documented in this
Report,  including those identifying the alignment between the Phase I construction program and
soil and erosion control programs in North Carolina and Washington State, show that State and
local programs have successfully integrated and leveraged the program to improve program
administration and yield water quality benefits.

Extensive Outreach Campaign

Because the Phase I regulations affects so many entities with no prior NPDES permitting
experience, particularly in the construction sector, the program has included aggressive outreach
since its inception. EPA found that tools such as a hotline, a  full complement of guidance,
training workshops, and an Internet-based web site have been used extensively by the regulated
community. As noted in the WEF survey report, "it appears that both EPA and the States have
done an excellent job in providing the necessary assistance to prepare a storm water management
plan."

Stakeholder Support

As a result of the program's flexibility and the fact that BMPs offer real loading reductions,
many members of the regulated community support the program. When WEF asked regulated
industries whether they would implement SWPPPs even in the absence of storm water
regulations, almost 43 percent indicated they would retain SWPPPs in their entirety. Of these,
80 percent would retain SWPPPs because of the environmental benefit.  More than one-half
(52.3 percent) of the remaining respondents stated they would retain at least some of their
SWPPPs even in the absence of regulations.
Measures Identified as Unsuccessful

Further improvements can be made in both program design and implementation to enhance
effectiveness.

As noted above, a sound program framework is in place to foster cost-effective implementation
and loading reductions, and subsequent water quality protection and improvement have been
evidenced. Nevertheless,  information collected for this Report also identified measures of the
Phase I storm water program that are considered less than successful. Those measures are
discussed below, along with a summary of the Agency's response.
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Respondents to the WEF survey identified the following BMP measures as ineffective in
controlling the discharge of pollutants in storm water:

•      Record keeping and reporting
•      Raw material and product substitution
•      Site mapping.

Agency Response: While some respondents to the WEF survey did not feel the above measures
are effective in controlling the discharge of pollutants in storm water, EPA feels they are
important components of a comprehensive and effective SWPPP. Developing a facility site map,
for instance, although not directly effective in controlling the discharge of pollutants, can be a
very simple and effective exercise that provides an operator with a better understanding of the
potential sources of pollutants exposed to storm water.  The site map also provides the operator
with a better understanding of the drainage areas from their facility, which should facilitate
assessment of necessary controls. Accurate record keeping and reporting is essential to track
compliance with SWPPP implementation requirements, as well as assist in anticipating areas  of
concern for storm water contamination (e.g., tracking the types and amounts of materials stored
at the facility).  With regard to measures that address "raw material and product substitution,"
these are BMPs that facilities are to consider, and implement as appropriate and necessary.
CONCLUSIONS

EPA's analysis of the Phase I storm water program demonstrates that a flexible regulatory
framework is in place for controlling storm water discharges from municipal, construction, and
industrial sources. Many Phase I program components were found to be effective in preventing
or reducing the discharge of pollutants in storm water in specific cases. Although EPA
acknowledges that it does not currently have a system in place to measure the success of the
Phase I program on a national scale, surveys and case studies described in this Report indicate
that significant milestones are being achieved. This Report specifically provides evidence that
the Phase I program has been successful in reducing pollutant loadings in storm water discharges
and protecting and improving water quality on a site-specific basis.  The Agency has worked
with stakeholders, and will continue to do so, to identify meaningful measures for reporting the
effectiveness of the Phase I storm water program in the future.

Finally, many Phase I municipalities agree that storm water management is a key component in
multijurisdictional, multiwatershed efforts to protect receiving waters. Municipalities have
stated that there are opportunities for integrating wet weather programs (storm water Phases I and
II, combined sewer overflow, sanitary sewer overflow) to enhance efforts by municipalities and
other stakeholders to manage wet weather flows  on a watershed basis. The Agency will continue
to look for ways to support innovative approaches to watershed protection through policy,
guidance, and technical assistance.
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                                 1. INTRODUCTION

1.1  PURPOSE OF THE REPORT

EPA is submitting this Report to Congress in compliance with section 431(b) of the Department
of Veterans Affairs and Housing and Urban Development and Independent Agencies
Appropriations Act of 2000, Public Law No. 106-74 (1999) ("Appropriations Act"). The
Appropriations Act directs EPA to conduct an evaluation of the Phase I Storm Water Program as
follows:

     No later than 120 days after the enactment of this Act, the Environmental
     Protection Agency shall submit to the Environment and Public Works
     Committee of the Senate and the Committee on Transportation and
     Infrastructure of the House of Representatives a report containing a detailed
     explanation of the impact, if any, that the Phase I program has had in
     improving water quality in the United States (including a description of
     specific measures that have been successful and those that have been
     unsuccessful).

In response to the mandate of the Appropriations Act, this Report answers the following
questions:

•  Has the Phase I program contributed to efforts under the Clean Water Act (CWA) to improve
   the quality of the Nation's waters?
•  Which specific components of the Phase I program have been successful? Which have been
   unsuccessful?  What lessons  can be learned to further improve the program's effectiveness?
1.2  ENVIRONMENTAL IMPACTS OF STORM WATER

Over the years, significant research has documented the actual and potential adverse impacts of
storm water runoff. As rainfall or snowmelt moves over and through the earth's surface,
naturally occurring and man-made pollutants can be transported to rivers, streams, lakes, and
coastal waters. Once present in a water body, these pollutants can impair aquatic life or
adversely affect human health  (through consumption of contaminated water or contaminated
aquatic life).

The potential for adverse impacts from storm water runoff increases as natural vegetation is
altered by development activities (removal of vegetative cover and construction of impervious
structures such as buildings, roads and highways, parking lots, and sidewalks). The potential for
adverse impacts increases in urbanized areas, where the cumulative effect of development can
result in significant changes to natural drainage patterns, thereby increasing peak flows in urban
streams and wetlands.  Increased peak flows can result in stream bank erosion, flooding,
channelization, and alteration (or elimination) of habitat.

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pollutants, including 14 inorganic and 63 organic pollutants. The concentrations in many of the
samples exceeded various freshwater water quality criteria.
                                             In 1985, the States conducted a more comprehensive
                                             study of diffuse pollution sources under the
                                             sponsorship of the Association of State and Interstate
                                             Water Pollution Control Administrators (ASIWPCA)
                                             and EPA. The study resulted in the report America 's
                                             Clean Water-The States Nonpoint Source
                                             Assessment. 1985 (ASIWPCA, 1985), which
                                             indicated that 38 States had reported urban runoff as
                                             a major cause of beneficial use impairment. In
                                             addition, 21 States had reported construction site
                                             runoff as a major cause of use impairment.
The NURP study provides insight on what
can be considered background levels of
pollutants for urban runoff because the study
focused primarily on monitoring runoff from
residential, commercial and light industrial
areas.  Based in part on the NURP study
findings, many other studies have been
conducted by EPA, States, academia,
associations, and others to further
characterize and report on the potential
impacts of storm water from a variety of
sources (urban and nonurban) on receiving
water quality.  EPA summarized much of the research performed on storm water impacts in the
publication Environmental Impacts ofStormwater Discharges: A National Profile (USEPA,
1992a).

1.2.2 Recent National Summary of Storm Water Discharge Impacts
Section 305(b) of the CWA requires each State to conduct water quality surveys to determine a
water body's overall health, including whether designated uses are being met. States, tribes, and
other jurisdictions define appropriate uses for a water body and incorporate these uses into water
quality standards approved by EPA.  Common water body use categories include public water
supply, fish and wildlife propagation, recreation (swimming, boating, fishing, etc.), agricultural,
industrial, and navigation.  States and other jurisdictions conduct water quality surveys and
report the findings to EPA every two years. EPA then prepares a biennial report to Congress,
which represents the most complete and up-to-date snapshot of water quality conditions around
the country.

The most recent report in this series,  The National Water Quality Inventory: 1996 Report to
Congress (USEPA, 1998), provides a general assessment of water quality based on State reports.
The report indicates the fraction of the States' waters assessed, as well as the fraction of the
States' waters fully supporting their designated uses. The report also enumerates impaired
waters, defined as those waters that fail to meet designated use protection criteria. As shown in
Table 1-1,  the States reported that urban runoff/storm sewer discharges affect 13 percent of
impaired rivers and streams, 21 percent of impaired lakes, 10 percent of impaired Great Lake
shoreline. 55 percent of impaired ocean shoreline, and 46 percent of impaired estuaries.
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Table 1-2. Summary of Water Body Use Impairment Attributable to Storm Water
Associated with Industrial Activity Discharges"

Water Body
Type
River and
Streams
Lakes
Great Lakes
Shoreline
Ocean
Shoreline
Estuaries

Percent of
Total
Waters
Surveyed
19

40
94

6

72

Percent of
Surveyed
Waters
Found
Impaired
36

39
97

13

28
Percent of
Impaired
Waters
Impacted by
Industrial
Point
Sources'1
9

9
9

29

65

Percent of
Impaired
Waters
Impacted by
Land
Disposal
7

11
9

27

19

Percent of
Impaired
Waters
Impacted by
Construction'
9

11
[

17

11

Percent of
Impaired
Waters
Impacted by
Resource
Extraction
13

5
0

5

16
 1 The categories of sources include discharges of process wastewater as well as storm water discharges.
 Therefore, the percentages of impairment indicated in the table likely overstate the actual impact attributable to
 storm water discharges.
 b Includes Construction and Land Development categories.
 c Includes Industrial. Petroleum Activities, and Other Point Source categories.
 Source: USEPA. 1998.
1.3  STORM WATER PROGRAM HISTORY

The primary objective of the CWA is to restore and maintain the chemical, physical, and
biological integrity of the Nation's waters.  This objective is supported by two national goals: to
eliminate ail pollutant discharges to navigable waters by 1985, and to achieve fishable and
swimmable waters by 1983 wherever attainable. To achieve the objective and goals, the CWA
established a variety of programs to control the discharge of pollutants to receiving waters.
Section 402 of the CWA established the National Pollutant Discharge Elimination System
(NPDES) permit program to specifically control the discharge of pollutants from point source
dischargers.

Considering increases in economic activity and population, significant progress in controlling
pollution from point sources has been made, particularly with regard to industrial process
wastewater and municipal sewage. Expenditures by EPA, States, and local governments to
construct and upgrade sewage treatment facilities have substantially increased the population
served by higher levels of treatment and have significantly reduced pollutant loadings to the
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discharges listed under section 402{p)(2).  Section 402(p)(2) lists five types of storm water
discharges required to obtain a permit prior to October 1, 1992:

•   A discharge for which a permit was issued prior to February 4, 1987.
•   A discharge associated with industrial activity.
•   A discharge from a municipal separate storm sewer system serving a population of 250,000
    or more.
•   A discharge from a municipal separate storm sewer system serving a population of 100,000
    or more but less than 250,000.
•   A discharge that the Administrator or the State, as the case may be, determines contributes to
    a violation of a water quality standard or is a significant contributor of pollutants to the
    waters of the United States.

Section 402(p)(4)(A) required EPA to promulgate, no later than two years after the date of
enactment, final Phase I regulations governing storm water permit application requirements for
storm water discharges associated with industrial activity and discharges from large municipal
separate storm sewer systems (systems serving a population of 250,000 or more). Section
402(p)(4)(B) also required EPA, no later than four years after enactment, to promulgate final
regulations governing storm water permit application requirements for medium separate storm
sewer systems (systems serving a population of 100,000 or more but less than 250,000).  In
addition, section 402(p)(4) provides that permit  applications for storm water discharges
associated with industrial activity and discharges from large municipal separate storm sewer
systems "shall be filed no later than three years" after the date of enactment of the WQA (no later
than February 1990).

For Phase II, section 402(p)(5) of the WQA directed EPA, in consultation with the States, to
study additional storm water discharges not addressed by the Phase I program.  Section 402(p)(5)
specifically required a study for the purpose of

•   Identifying those storm water discharges or classes of discharges for which permits are not
    already required as part of the first phase of the NPDES storm water program.
•   Determining, to the maximum extent practicable, the nature and extent of pollutants in such
    discharges.
•   Establishing procedures and methods to control storm water discharges to the extent
    necessary to mitigate impacts on water quality.

Section 402(p)(6) of the WQA provides for EPA to issue regulations that designate additional
storm water discharges to be controlled to protect water quality under Phase II of the program
and to establish a comprehensive program to regulate such  designated sources.2
       "On December 8, 1999, EPA promulgated regulations related to the Phase II storm water program (64 FR
68722). The Phase II program addresses storm water discharges from small municipal separate storm sewer

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The Phase I regulations allow EPA and authorized States the discretion to require MS4s not
listed in the regulation to apply for an NPDES permit.4 Based on this discretion, the universe of
MS4s affected by the Phase I program has increased.  Since the issuance of the Phase I
regulations in 1990, the number of affected MS4s has grown to  more than 1,000. Most of the
additional MS4s are small cities that are co-permitted with a neighboring Phase I MS4.  A
detailed discussion of the status of the Phase I permits is included in Chapter 3 and Appendix A.

1.4.2 Industrial

EPA initially estimated that about 100,000 facilities would have storm water discharges
associated with industrial activities and would require coverage under an NPDES permit.  EPA
acknowledged in its final rule that this large number of facilities would place a correspondingly
large administrative burden on EPA and authorized States to issue NPDES permits.  As part of
the final Phase I rule, EPA introduced a strategy to address this  permitting task that provided
flexibility in the manner in which NPDES permits are issued. The strategy included a tiered
approach  to issuing permits for storm water discharges associated with industrial activity. This
tiered approach included initial baseline permitting using general permits to cover the majority of
affected facilities, followed by more targeted permitting, including the use of facility-specific
NPDES permits, to address storm water discharges with a greater likelihood of causing impacts
on water quality.

To implement EPA's permitting strategy, the November 16, 1990, Phase I storm water
regulations provided two permit application options for storm water associated with industrial
activity:

•    Submit an individual application.
•    Participate in a group application for facilities that have similar industrial operations, waste
    streams, and other characteristics.

Subsequent revisions  to the regulations provided a third option:  file a notice of intent (NOI) to be
covered under a general permit.

Under the second option, the deadline for submission of group applications was September 30,
1991. EPA received more than 1,200 group applications covering approximately 60,000
industrial  facilities with storm water discharges (USEPA, 1995).
       ""According to 40 CFR I22.26(a)(v), this discretion is provided for storm water discharges which either the
State Director or EPA Regional Administrator determines that the discharge contributes to a violation of a water
quality standard or is a significant contributor of pollutants  to waters of the United States. This designation may
include a discharge from any conveyance or system of conveyances used for collecting and conveying storm water
runoff or a system of discharges from municipal separate storm sewers.

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associated with construction activity in all States not authorized to issue NPDES permits.  Based
on data and information collected from this initial baseline general permit, as well as experience
gained from implementing the general permit, EPA revised and reissued the general permit on
February 14, 1998 (63 FR 7898).*

EPA intended the baseline construction general permit to serve as a template for general permits
to be issued  by authorized States. The baseline general permit for construction activities
establishes a variety of conditions and requirements for storm water discharges from construction
sites, the most significant of which is the requirement to develop and implement a site-specific
SWPPP that specifies erosion and sediment controls that will be used at the site.
1.5  ORGANIZATION OF REPORT

This Report to Congress is organized as follows:

•  Chapter 2 summarizes the methodology used to respond to Congress's request.

•  Chapter 3 presents EPA's evaluation of the Phase I storm water program for municipal
   separate storm sewer systems.

•  Chapter 4 presents EPA's evaluation of the Phase I storm water program for construction
   activities.

»  Chapter 5 presents EPA's evaluation of the Phase I storm water program for industrial
   activities.
                                                       U.S. EPA Headquarters Library
                                                              Mail code 3201
                                                       1200 Pennsylvania Avenue NW
                                                          Washington DC  20460
       6EPA Regions 4 and 6 reissued separate construction general permits (63 FR 15622, March 31, 1998, and
63 FR 36490, July 6, 1998, respectively) that apply only in areas where the EPA region is the NPDES permitting
authority.

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                       2. APPROACH USED IN THIS REPORT

EPA has collected preliminary information on the Phase I program that documents specific
instances where the program has resulted in better control of storm water discharges and greater
protection of water quality. EPA's response to the Appropriations Act requirements builds on
several of the Agency's ongoing efforts to track the progress of wet weather programs, including
the Phase I storm water program. When completed, these efforts will provide valuable insights
and information that will assist in establishing the future direction of storm water regulatory and
permitting efforts. Also, in the limited time since the Appropriations Act, EPA has collected and
analyzed a limited amount of additional data and information related to the Phase I storm water
program.

As noted in Chapter 1, most NPDES permitting actions attributable to the Phase I storm water
program have occurred within the past several years. EPA's programmatic design foresaw a
phased storm water program. Per this design scheme, the initial permitting cycle would establish
the mechanisms to control storm water discharges, including requiring storm water
characterization to facilitate the design of storm water controls. Subsequent NPDES permitting
cycles would increasingly focus on refinement of requirements to address pollutants and
practices of concern.
2.1  THREE TYPES OF INDICATORS

Consistent with the Agency's programmatic expectations and with congressional direction, this
Report assesses where the Phase I storm water program has been successful and unsuccessful.
Three key categorical measures are used as benchmarks to  assess the success of the Phase I
program — programmatic indicators, loading reductions, and water quality improvements. The
definition of each measure and how it relates to assessing the overall impact of the Phase I storm
water program is provided in detail below.

2.1.1 Programmatic Indicators

Programmatic indicators demonstrate the evolution of storm water controls attributable to the
Phase I storm water program through the programmatic cycles defined by EPA's permitting
strategy. As the Phase I program evolves, a steady progression toward watershed protection is
expected.

In developing the Phase I program, EPA made every effort to increase programmatic net benefits
by limiting the burden on affected facilities. The Agency took great care to develop a flexible,
efficient process whose broad blueprint could be tailored to meet site-specific needs. Because
many local and State jurisdictions had storm water control  programs in place before the
rulemaking (e.g.,  local erosion and sediment control programs), EPA had an experience base on
which to build. As a result, the Agency was able to assess  what was working and what was not
working, before the rulemaking. In addition, the Phase I program makes extensive use of general
permits, an approach that reduces the administrative costs of administrative authorities and

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regulated parties. EPA was also in the position to make use of existing technical and
programmatic expertise, thereby enabling the relatively rapid technical transfer of those skills
and capabilities through traditional training and guidance, as well as the Internet. The
effectiveness of EPA's efforts can be determined through an analysis of programmatic indicators.

2.1.2 Loading Reductions

The Phase I program was designed to achieve pollutant loading reductions as the primary means
of protecting water quality from the impacts of storm water discharges. Although the
Appropriations Act specifically requested information on water quality improvements that have
resulted from implementing Phase I, EPA believes the load reductions attributable to Phase I
must also be  included in this Report. For most circumstances, the Agency requires its permittees
to report on local pollutant load reductions and does not require Phase I permittees to document
water quality improvements in their local water bodies resulting from the Phase I program. More
importantly, load reductions is the only way to measure the pollution prevention aspect of the
Phase I program. A major aspect of the Phase I program is helping to prevent further loss of
water quality by minimizing the pollutants in storm water discharges. Consequently, this Report
describes actual or estimated pollutant load reductions resulting from the storm water controls
required by the Phase I program (e.g., best management practices).  These reductions are
relatively easy to report because they are based on actual performance data collected as part of
NPDES permit requirements.

2.1.3 Water Quality Improvements

Pollutants contained in storm water discharges can affect receiving water quality independently
or in combination with pollutants discharged from other point and nonpoint sources. As a result,
pollutant levels can exceed applicable water quality standards designed to protect aquatic life and
human health.

Often, EPA and the States do not have the resources to sufficiently monitor water quality
impacts. Moreover, in many cases monitoring of water bodies would not show the full benefits
of Storm water control because storm water controls are designed to protect water bodies from
degradation as well as to improve already impaired waters. Indeed, one of the goals of the Phase
I program is to foster achievement of water quality standards, including protection of designated
uses.  In these cases, a demonstration of the effectiveness of storm water controls (e.g., pollutant
loading reductions) is strong evidence of Phase I program success. This Report includes such
information and analyses, as well as specific studies of cases where water quality improvements
have been evidenced.

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                                   "Monitoring of several urban streams in Milwaukee County
                                   showed that the urban streams are highly degraded. Storm water
                                   discharges are blamed for high concenlrations of pollutants in the
                                   water and bottom sediments, flashy flows, poor habitat, low
                                   diversity of aquatic organisms, and accumulation of pollutants in
                                   fish and crayfish tissue." (Bannerman, 1996)
In this Report, EPA describes
many specific efforts that have
been initiated by Phase I regulated
entities and have resulted in water
quality benefits. Although the
Phase I program has resulted in
many efforts to better manage
storm water discharges and
protect water quality, EPA also acknowledges that the Phase I program has not been the only
incentive for addressing the impacts of storm water. In some cases storm water impacts have
independently encouraged many States, local governments, and academics to determine the
extent of impacts and to identify effective and efficient management options. For this Report to
Congress, EPA has tried,  to the extent possible, to identify benefits that are directly attributable
to the Phase I program. However, efforts may include programs or program components that
were not necessarily adopted in response to Phase I specifically.  In  many cases, it may not be
possible to determine the exact extent to which program elements resulted from the Phase I rule
and what extent they represent part of an existing or parallel effort.
2.2  OVERVIEW OF METHODOLOGIES USED FOR THE ANALYSIS OF THE
     PHASE I PROGRAM

EPA is reporting on the effectiveness of the Phase I storm water program using three measures:
programmatic indicators, loading reductions, and water quality improvements.  EPA used several
techniques to derive the measures for each major component of the Phase I program (MS4s,
construction activities, and industrial activities).  A general description of the techniques is
provided below. More detailed descriptions of the techniques  and data sources used to assess the
effectiveness of each major component of the Phase I program are provided in Chapters 3,4, and
5.

Case studies are used throughout this Report to specifically document efforts, programs, and
initiatives used  by permittees to comply with Phase I storm water program requirements.  The
case studies mainly provide detailed information related to how the Phase I program is being
developed and implemented by individual permittees.  EPA has used the information provided in
the case studies to demonstrate how effective the Phase I program has been in protecting water
quality from storm water discharges. For this Report, EPA identified case  study candidates from
a number of sources. For example, the recent NRDC publication Stormwater Strategies:
Community Responses to Runoff Pollution (NRDC, 1999) was used as a source of case study
candidates. In addition, EPA performed searches of literature, periodicals, and the Internet to
identify other potential case studies. Case studies were selected based on their direct
applicability to  the Phase I program.
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Because of the relatively short time penod provided to prepare this Report to Congress, EPA was
not able to collect an extensive amount of new data and information to assist in assessing the
Phase I storm water program.  However, as described throughout this Report, EPA has used and
built on the results of several other survey and data collection efforts to report on the Phase I
program.  Some of the efforts were undertaken by EPA for other purposes (e.g., for use in
analyses not related  to this Report), including several initiatives  undertaken to comply with the
Government Performance and Results Act (GPRA). EPA also has built on several ongoing
efforts related to defining and tracking indicators to measure progress toward Phase I program
goals. Finally, the Agency has used data and information collected for use in promulgating the
Phase II storm water regulations, including, for example, the Report to Congress on the Phase II
Storm Water Regulations (USE?A, 1999a).

EPA also collected and analyzed the results of other efforts outside the Agency that were made
available for use in this Report. For example, the National Association of Flood and Stormwater
Management Agencies (NAFSMA) conducted a survey of its members to solicit input related to
the effectiveness of the Phase I storm water program. EPA also  used the results of a study
performed by the Water Environment Federation (WEF) to assess the effectiveness of the
industrial storm water general permitting program.
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  3. EVALUATION OF PROGRAM FOR MUNICIPAL SEPARATE STORM SEWER
                                     SYSTEMS

This chapter evaluates the impact of the municipal separate storm, sewer system (MS4) portion of
the Phase I storm water management program.  In preparing this Report to Congress, EPA
considered a number of special characteristics of the program:

•  The Phase I program provides municipalities with the flexibility to develop storm water
   management programs that address local needs and priorities.

•  Implementation of the Phase I program continues to mature, shifting in  focus from discharges
   to prevention and minimization of water quality impacts.

•  A significant component of the Phase I program philosophy is problem  avoidance. For many
   municipalities, storm water management means minimizing the impacts of future
   urbanization by managing residential, commercial, and industrial development activities in
   ways that are less destructive to water quality.

*  Storm water monitoring performed under the Phase I program helps municipalities identify
   where storm water is and is not causing water quality impairment, thereby helping
   municipalities focus their storm water management efforts.

Section 3.1 of this chapter describes the Phase I requirements for MS4s. Section 3.2 presents a
description of the general methodology and primary data sources.  Section 3.3 presents the
specific methods used to determine the impacts and the results of these analyses. Section 3.4
presents the overall findings, including a discussion of program elements considered successful
and those considered unsuccessful.
3.1   STATEMENT OF PHASE I REQUIREMENTS

The Storm Water Phase I Rule (55 FR 47990; November 16,1990) requires all operators of
medium and large MS4s to:

•  Obtain a National Pollutant Discharge Elimination System (NPDES) permit for discharges
   from the MS4 to waters of the United States.

•  Develop a storm water management program that minimizes the pollutant discharges of
   MS4s into local water bodies whether the pollutants originate from storm water runoff or
   originate from direct dumping into the MS4.

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3.1.1 MS4s Regulated Under the Phase I Program

As defined in the final Phase I regulations and as codified at 40 CFR 122.26(b), an MS4 is:

•   A medium MS4 if the system serves, or is located in an area with, a population between
    100,000 and 249,999.
•   A large MS4 if the system serves, or is located in an area with, a population of 250,000 or
    more.

In addition, municipalities with populations under 100,000 may be designated on a case-by-case
basis by an NPDES permitting authority (due in part to their interconnectedness with either a
medium or large MS4).

The Phase I rule lists the incorporated places and counties that meet the population thresholds for
medium and large MS4s. These lists were recently updated to reflect 1990 Census figures as part
of the Storm Water Phase II rulemaking effort (64 FR 68722; December 8, 1999). All MS4s
listed are automatically designated by the Phase I rule as medium and large MS4s, and their
operators are required to comply with the storm water permit application requirements of 40 CFR
122.22(d) to obtain an NPDES individual permit.7

Some municipalities listed in the rule as operators of medium or large MS4s have combined
sewer systems where sanitary wastewater and storm water runoff are conveyed through a single
set of pipes to a publicly owned treatment works (POTW).  Since the Phase I program for MS4s
applies only to separate storm sewer systems, an MS4 is regulated by Phase I only if there is a
separated portion of the system that serves more than 100,000 people.8

3.1.2 Permit Application Requirements For Medium And Large MS4s

EPA's approach for controlling discharges from MS4s focuses on development and
implementation of a local, site-specific storm water management program. The resulting permit
application requirements (found at 40 CFR 122.26(d)) reflect this approach and solicit
information from the Phase I municipality related to the establishment of such a locally based
program. The specific application requirements are divided into two parts. A Part 1 application
contains several components:

   General information (name, address, etc.);
       'The final storm water Phase H rule freezes the definition of medium and large MS4s at those that qualify
based on populations from the 1990 Census. In other words, the list of MS4s affected by the Phase I program
requirements, will not change to reflect newer Census data in the future.

       * Combined sewer systems are addressed in EPA's National Combined Sewer Overflow (CSO) Control
Policy, issued on April 19. 1994 (59 FR 18688).

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                                               EPA requirements for an MS4 storm water
                                               management program include the development of
                                               measures that will:
                                               •   Identify major outfalls and pollutant loadings
                                               •   Detect and eliminate non-storm water discharges
                                                  to the storm sewer system
                                               •   Reduce pollutants in runoff from industrial,
                                                  commercial and residential areas
                                               •   Control storm water discharges from new
                                                  development and redevelopment areas
                                               •   Meet the standard of "reducing pollutants to the
                                                  Maximum Extent Practicable (MEP)."
•   Description of existing legal authority to
    control discharges to the MS4 and any
    additional authorities needed (e.g.,
    interagency agreements for joint
    applicants).
•   Source identification information,
    including a topographic map, a
    description of historic use of ordinances
    or other controls that limited the non-
    storm water discharges to the MS4, the
    location of MS4 outfalls, the projected
    growth, the location of structural controls,
    and the location of waste disposal
    facilities.
*   Discharge and representative outfall characterization (including mean monthly rain and snow
    fall estimates, field screening analysis for illicit connections, etc.) to assess the volume and
    quality of the storm water discharges), and identification of known water quality impacts
    associated with  storm water discharges.
•   Description of existing storm water management programs that prevent pollutants from
    entering the MS4 and identify non-storm water (illicit) connections to the system.
•   Description of fiscal resources, including budget and resources for implementing storm water
    programs and for completing the Part 2  application.
•   Characterization plan for further MS4 sampling under Part 2.

The components of the Part 2 application for MS4s include:
•  Demonstration of adequate legal authority to control discharges, prohibit illicit discharges,
   require compliance, and carry out inspections.
•  Source identification indicating the location of any major outfalls and identifying facilities
   that discharge storm water associated with industrial activity through the MS4.
•  Discharge characterization data from representative locations in approved sampling plans.
   Description of the proposed storm water management program, including structural and
   source control measures, illicit discharge detection and removal, and construction site and
   industrial facility runoff monitoring and control.
•  Measures to assess the effectiveness of the proposed storm water management program
   (including estimates of reduction in loadings of pollutants to the MS4 discharges).
•  Fiscal analysis of necessary capital and operation and maintenance expenditures.

Medium MS4s were to submit their Part 1 applications to the NPDES permitting authority by
May 18,  1992; applications for  large MS4s were due November 11, 1991. Part 2  applications
were to be submitted to the NPDES permitting authority within I year after submission of the
Part 1 application (i.e.. May 17, 1993, for medium MS4s and November 16, 1992, for large
MS4s).
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3.1.3 NPDES Permit Requirements

Once the NPDES permitting authority receives an MS4's Part 2 application, it issues an
individual NPDES permit that incorporates the MS4's proposed storm water management plan.
This permit requires implementation of the plan and may include other specific requirements
necessary to ensure proper program management (e.g., conduct analytical monitoring and visual
examinations).  In addition, the Phase I rule specifically requires MS4s to submit annual reports
that reflect the development of their local control programs.  As stated in 40 CFR 122.42, the
specific requirements for annual reports include.

•  Status report on implementing the components of the local management program (as
   established in the NPDES permit).
•  Proposed changes to the storm water management program and revisions, as necessary, to the
   assessment of controls and fiscal analysis reported in the Part 2 application.
•  Summary of all data, including monitoring data, collected during the previous year.
•  Annual expenditures and budget for the coming year.
   Summary of enforcement actions, inspections, and public education programs.
•  Identification of water quality improvements or degradation.

The Phase I program acknowledges the inherent difficulty of regulating naturally occurring,
episodic events  and endeavors to provide the greatest degree of water quality protection with the
least amount of regulatory burden.  The requirement for MS4s to develop site-specrfic storm
water management programs reflects that discharges from MS4s vary in their nature and impact
on receiving water quality.

EPA expects that implementation of storm water management programs for Phase I MS4s will
occur on a phased, iterative basis. On August 26,  1996, EPA published (61 FR 43761) a policy
outlining an interim approach for incorporating water quality-based effluent limitations into
NPDES permits. It allows the use of BMPs in the first round of storm water permits, followed
by tailored BMPs as necessary in subsequent permits, to provide for attainment of water quality
standards.

A recent U.S. 9th Circuit Court Decision (Defenders of Wildlife et al.  v. Browner, 191 F.3d 1159
(9th Cir. 1999), as amended, 197 F.3d 1035) supports EPA's phased approach to regulating
discharges from MS4s under the Phase I program. In summary, the permitting actions for
several MS4s were challenged because the NPDES permits did not contain provisions requiring
numeric limitations to ensure compliance with State water quality standards.  Specifically, the
decision stated that "EPA has adopted an interim  approach, which uses best management
practices (BMPs) in first-round storm water permits.. .to provide for the attainment of water
quality standards."
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3.1.4 Current Status of Phase I MS4 Program

As shown in Figure 3-1,1,059 municipal operators comprise the "universe" of permitted or
potentially permitted Phase I MS4s. Of these, 1,017 MS4s have been issued, or are in the final
stages of being issued, a Phase IMS4 permit. Appendix A lists these MS4s. Of the remaining
42, 9 MS4s are nonparticipants and 33 were exempted from the program upon finding that they
operated both combined and separate storm sewer systems and that the population served solely
by the separate storm sewer system was less than 100,000.

Of the 1,017 MS4s participating in the program, 216 were originally part of the Phase I rule (i.e.,
those municipalities that were listed in Appendices F, G, H, and I of the regulation as operators
of medium or large MS4s). The remaining 801 (79 percent) permitted MS4s were designated
into the program.  Of these, 670 were co-permitted with a larger MS4 or specifically designated
by the NPDES permitting authority. In addition to these municipal MS4s, 131 special districts
are permitted under the Phase I program. These special districts include flood control districts,
port authorities, departments of transportation (highways) and recreation (parks), and
universities.
Total Number of Permitted or Potentially Permitted MS4s under the Phase I
Storm Water Program:
1,059
1 l
Number of MS4s Designated by the 1990
Phase I Report to Congress:
252
1 1
Number of MS4s
Participating in the
Phase I Program:
216
Number of MS4s Not
Participating in the
Phase I Program:
36
CSO Exemptions: 33
Nonparticipants: 3
Number of Additional MS4s Identified Under
Phase I:
807
1 1
Number of Additional
MS4s:
675
Phase I Participants: 670
Nonparticipants: 5
Number of Special
District MS4s:
132
Phase I Participants: 13 J
Nonparticipants: 1
 Figure 3-1.  Summary of Large and Medium MS4s Regulated under the Phase I Storm
 Water Program
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3.2  ANALYTICAL APPROACH

This section describes the processes used to evaluate the municipal component of the Phase I
storm water program. As described in Section 2.1 of this Report, EPA measured the success of
the Phase I program by looking at three measures: programmatic indicators, loading reductions,
and water quality improvements.  In evaluating the Phase I program for MS4s in accordance with
these three measures, EPA used case studies and survey data.

The case studies described throughout this chapter provide snapshots of lessons learned,
efficiencies gained, and positive public reactions attributable to the Phase I storm water program.
Many of the MS4 case studies were identified in the Natural Resources Defense Council report
Stormwater Strategies:  Community Responses to Runoff Pollution (NRDC, 1999).  In addition,
EPA performed extensive literature, periodical, and Internet searches to identify other MS4 case
study candidates.

For the past year, EPA has been investigating ways to measure success under the municipal
component of the Phase I storm water program. The Agency expanded on these ongoing efforts
as a way to provide more specific MS4 storm water management program data and information
for use in this Report to Congress.  The MS4 indicators project involved a two-step process:

1.   First, EPA identified a suite of environmental and program indicators that could be used to
    measure the effectiveness of municipal storm water programs. The indicators were to
    communicate information about the environment and about human activities, drawing
    attention to emerging problems and the effectiveness of current policies. EPA developed the
    proposed indicators based on interviews with knowledgeable local  staff at 11 MS4
    communities.

2.   Second, EPA used the indicators identified to actually measure conditions before and after
    the Phase I permitting process was initiated.  In this process, the Agency made every effort to
    isolate those influences attributable to the Phase I storm water permitting program,
    subtracting out wherever possible the influences of other environmental programs.
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For this Report to Congress, EPA re-interviewed nine of the 11 Phase I municipalities to measure
and report on actual progress under the storm water program using the indicators developed. The
indicator survey therefore assesses conditions for approximately 3 percent of the current MS4
permits.0 Although the sample is small, it provides a starting point for assessing the attitudes of
the regulated community related to:

•  Identifying components of municipal storm water management programs considered
   successful and yielding the highest environmental benefit.
•  Identifying components considered unsuccessful or not expected to yield a benefit to
   municipal storm water management programs.
•  What environmental protection has been added because of storm water permit requirements.

EPA collected two different types of information from the nine MS4s:

1.  Information designed to assist with measuring of programmatic improvements and estimated
   water quality improvements based on the best professional judgment of the MS4s operators;
   and

2.  Data on load reductions, past and present, attributable to municipal Storm water management
   programs.  The difference in annual pollutant reductions before and after implementation of
   the Phase I permit program serves as an indicator of loading reductions attributable to Phase
   I.

Appendix B describes the type of information collected from each of the nine MS4s.

In support of EPA's efforts to evaluate the effectiveness of the Phase I storm water program, the
National Association of Flood and Stormwater Management Agencies (NAFSMA) conducted a
survey of local government agencies affected by the Phase I program.  The survey specifically
solicited input related to the effectiveness of MS4 programs in improving water quality. A copy
of the Phase I NAFSMA survey form is provided in Appendix C.
       °The small sample size is necessitated by the short time frame established for this Report to Congress
(which does not aliow for a broader, more detailed survey requiring Office of Management and Budget approval
under the Paperwork Reduction Act).

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3.3  SPECIFIC METHODS AND RESULTS

This section describes the methods used for the analyses and presents the results.

3.3.1 Programmatic Indicators

In this section, EPA summarizes case studies to demonstrate how specific permittees are
innovatively meeting permit requirements and how permittees are learning and improving upon
their early efforts. Then the Agency presents results of two limited surveys of Phase IMS4
permittees to illustrate that the permit requirements have resulted in new environmental
protection efforts and have improved on efforts predating the Phase I rule.

3.3.1.1 Case Studies

This section discusses case studies that stress activities of maturing storm water programs or
those that have demonstrated innovation early in their programs.  The program features
highlighted are:

•  Public support for new storm water programs.
•  Planning to avoid or minimize environmental problems.
•  Targeting pollutants of concern.

Table 3-1 summarizes each case study. Appendix D contains all of the case studies used for this
Report, including those used in other sections.
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Table 3-1. Summary of Program Improvement Case Studies Related to Storm Water
Management
Case Study Location
San Francisco, CA
City of Charlotte and
Mecklenburg County, NC
Portland, OR
Montgomery County, MD
Prince George's County, MD
Los Angeles, CA
Sacramento, CA
Features)
Tracking pollutants back to the sources has required iterative sampling and
good detective work.
Permit requirements led to a new program to protect surface waters. The
public supports a strong storm water management effort.
Dry-weather pollutant sources once unknown have been identified and
addressed. City's survey of public indicates increased understanding of
storm water quality and willingness to change behavior.
Investigation of the quality of natural resources helps in setting management
priorities.
Changing land use patterns through zoning and development design
minimizes environmental impacts.
Distinguishing between storm water pollutants that do and do not contribute
to water quality problems helps set local priorities
Constituent of Concern Reduction Program identifies and prioritizes specific
parameters causing impairment
Public Support for New Storm Water Programs

Grass-roots community investment in storm water protection is a measure of community
commitment and recognition of public need. Three case studies illustrate where new efforts by
Phase I permittees have received public support and are being effective in  controlling storm
water pollutants.

In Portland, Oregon, businesses and citizens increasingly understand storm water quality issues
and have shown a willingness to change their behavior to protect water quality.  More than 500
property owners have voluntarily disconnected the downspouts from their roof drains to divert
the water onto lawns instead of to storm drains. With 60 percent voter approval, Portland has
established a $135.6 million bond measure to acquire up to 6,000 acres of land area to better
manage sensitive watersheds and ensure better protection of urban waterways.

In Monterey, California, community grass-roots efforts have assisted in identifying and
implementing the necessary storm water management controls to protect the Monterey Bay
National Marine Sanctuary, one of the most diverse marine environments in the United States.
Volunteers contribute, on average, an estimated 1,500 annual hours to monitor for unacceptable
dry weather discharges to the MS4. These efforts are reducing the amount of pollutants entering
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the ocean.  Although Monterey is a Phase II community, its successful efforts demonstrate how
similar Phase I requirements can successfully protect sensitive water bodies.

The City of Charlotte, North Carolina (Phase I permittee) and Mecklenburg, County, North
Carolina (Phase II permittee) have created a multifaceted program to protect their local water
bodies. The program has gained wide public support. These entities have emphasized the
importance of a coordinated watershed management approach and the sharing of technical
expertise to protect water quality. Local opinion surveys indicate 55 percent of respondents felt
more money should be spent to maintain or restore the quality and usability of local water
bodies. Furthermore, private citizens have volunteered to adopt more than 40 miles of streams for
cleanup and to stencil hundreds of storm drains to discourage dumping.

Planning to Avoid or Minimize Environmental Problems

Many MS4s are seeking to avoid new environmental problems by shaping where and how new
development occurs on their urban fringe. Storm water problem prevention focuses on
minimizing directly connected impervious areas and integrating runoff treatment features into
development designs.  By sustaining the pre-development hydrology to the maximum extent
possible, both the volume of runoff and the pollutant load can be minimized without affecting the
ultimate utility of the property.

As a Phase I permittee, Prince George's County, Maryland, has evolved into a leader in using
information management/analysis as a way to provide better storm water management. Its multi-
faceted program uses advanced geographic information systems (GIS) and pollutant load models
to better estimate pollutant loads, target watersheds for restoration, and provide support for
restoration efforts. The county's multi-year assessment of storm water runoff is leading it to
improve upon common land development techniques, creating a new site design process—Low-
Impact Development (LID)—to control storm water runoff. The principal goal of LID is to
provide the maximum protection to the existing stream ecology by maintaining the watershed's
pre-developed hydrologic regime.  LID allows the site planner/developer to use a wide array of
simple, cost-effective techniques that focus on site-level hydrologic control.  Several other
Phase I permittees (e.g., Portland, Oregon) are actively following the development of LID
techniques to help shape their future storm water management efforts.

Another Phase I permittee, Montgomery County, Maryland, is also seeking to prevent new
storm water-related problems by changing zoning/development requirements to protect high
quality habitat identified through an innovative biomonitoring effort.  The County is using
information from a baseline inventory of ecological conditions to establish local management
priorities.  The County has committed $20 million over six years to  restore stream habitat
degraded by past development, demonstrating that it understands the economic advantages of
problem avoidance.  At this time three Special Protection Areas (SPAs) designated in 1996 will
receive additional protection from storm water impacts.  All new development planned within
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SPAs must measure water quality and stream conditions before, during, and after construction,
providing information on the effectiveness of BMPs in these areas.

Targeting of Pollutants of Concern

For San Francisco, California, multiple years of study with other communities neighboring San
Francisco Bay have yielded a clear understanding of where pesticides detected in the bay
originate. Iterative water quality monitoring that started with large-scale sampling of ambient
concentrations and ended with end-of-street storm water sampling has confirmed the connection
between storm water originating from urban areas and pesticide concentrations in the Bay.
Based on the findings of the sampling, San Francisco is focusing its outreach efforts to educate
the public at large about pesticide use.

Before Phase I sampling of storm water outlets, communities were generally unaware of the
pollutant constituents in their storm water. With Phase I permitting, communities performed
sampling of these outfalls, characterizing their local storm water loads and establishing a baseline
for subsequent management.  With the maturing of individual programs (generally after the first
five years under a permit), some Phase I permittees are starting to scale back their storm water
sampling once they have confidently demonstrated which pollutants are important. One example
of this effort to streamline monitoring efforts is in Los Angeles, California, where local current
data are being used to limit future sampling and focus on its high priority pollutants.

Sacramento, California's Phase I program has meant assessing multiple pollutant sources and
evaluating the impacts of storm water on a regional basis.  To judge the effectiveness of the
program, the city uses a storm water Effectiveness Evaluation Plan (EEP). As part of the EEP,
the Constituent of Concern (COC) Reduction Program identifies and addresses specific storm
water constituents shown to cause or have the potential to cause environmental problems.  The
city has prioritized its COCs: the Tier 1 (highest priority) constituents are chlorpyrifos, diazinon,
fecal coliform, lead, and copper.

3.3.1.2 Survey of Permittees

As described in Section 3.2, EPA conducted a limited survey of approximately 3 percent of the
current Phase I MS4 permits  to assess pre-Phase 1 and current storm water management.
Although the sample set is small, EPA believes its survey provides a starting point for assessing
the effectiveness of municipal storm water management programs established under Phase  I. To
help investigate the influence of the Phase I requirements, MS4 survey participants were asked
the question "Did the Phase I permit requirements either cause new or significantly refine
activities under this element?" for the following 16 program elements:

 (1)   Construction planning process and construction inspections for erosion and sediment
      control
 (2)   Spill response to reported questionable discharges

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 (3)  Public maintenance/inspection of structural storm water BMP controls
 (4)  Implementation of planning/zoning procedures for storm water management
 (5)  Storm water inspections of municipal facilities and industries
 (6)  Retrofit of flood management facilities for water quality benefits
 (7)  Collection of oil/household wastes
 (8)  Roadway maintenance to protect storm water (e.g., street sweeping, modified deicing
      activities!
 (9)  Field screening/inspection of storm sewers for illicit and other discharges
(10)  General public storm water outreach/education activities
(11)  Managing municipal use of pesticides, herbicides, and fertilizers to improve storm water
      quality
(12)  Inventorying/mapping storm water systems and identification of pollutant sources (e.g.,
      outfall and BMP mapping, source areas identification)
(13)  Estimating/tracking storm water load generated within permitted area
(14)  Chemical monitoring of MS4 storm water outfalls
(15)  In-stream chemical monitoring for assessing storm water impacts
(16)  Geomorphologic and biological monitoring of storm water.

This question helps  identify where the Phase I program is responsible for additional
environmental protection, as compared to protection already provided by existing programs or
conditions where the influence of Phase I is unclear. Additional environmental protection can
occur from either (1) communities implementing new storm water management elements, or (2)
increased quality of individual storm water elements employed by MS4s.

The results of EPA's limited survey indicate that the Phase I program has had a positive effect on
storm water management. Most MS4s reported that the Phase I program has led to the
development or refinement of most of the  16 storm water elements described above.

It is important to note the strong influence of the Phase I program on two key program
elements—

(1)   Field screening/inspection of storm sewers for illicit and other discharges and
(2)   General public storm water outreach/education activities.

The Phase I program's influence on illicit discharge control has been strongly correlated to
improvements in dry-weather environmental quality (identifying ambient water quality
improvements during dry-weather periods is easier and less expensive than identifying wet-
weather improvements). All of the MS4s surveyed by EPA indicated they have created a new or
upgraded effort to manage illicit discharges and dry-weather environmental quality as a result of
the Phase I program.

The Phase I program's influence on public outreach has been correlated with positive changes in
public behavior and water quality improvements in small-scale studies (discussed in greater

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detail in Section 3.3.1.1). A high percentage of MS4 permittees interviewed stressed that public
outreach to prevent pollution at the source is the "way of the future." EPA's survey of MS4s
about the influence of Phase I on MS4 outreach indicated that 86 percent of the communities had
created new public outreach programs aimed at improving water quality or had significantly
refined their public outreach efforts as a result of program requirements.

3.3.1.3 NAFSMA Survey Results

In support of EPA's efforts to evaluate the effectiveness of the Phase I storm water program,
NAPSM A conducted a voluntary survey of local government agencies affected by the Phase I
program. The survey specifically solicited input related to the effectiveness of municipal storm
water programs in improving water quality.  Appendix C provides a copy of the survey
questionnaire NAFSMA used. Table 3-2 summarizes the responses.  There were a total often
respondents to the NAFSMA survey.
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Table 3-2.  Summary of Responses from the NAFSMA Phase I Survey-
           Survey Question'
        Summary of Responses (Number of Respondents)11
  i) How would you rate the overall
 effectiveness of 'he Phase I Storm
 Water Program in improving the
 quality and quantity of storm water
 discharges and protecting water quality
 in your jurisdiction?
Successful (5)
Too early to tell (4)
No comment (1)
Additional Comments:
Program has provided means to control illicit discharges (3)
Program has increased public awareness (2)
Quantitative water quality data have not shown degradation with
increased population (1)
Program provides justification to increase program funding (1)
 2a) Please describe those specific
 components of your municipal
 stormwater program that have been
 effective in reducing the discharge of
 pollutants from your municipal storm
 sewer system or in improving water
 quality, and why you feel they have
 been effective.
Public outreach and education (6)
Program for locating and eliminating illicit discharges (4)
Inspection and enforcement (2)
Storm sewer system mapping (1)
Storm drain stenciling (1)
Construction site management program (1)
Urban retrofit (incl. use of low-impact development techniques) (1)
Water quality models for planning (1)
Additional Comments:
Partnerships established that provide for efficient networking and
collaboration (1)
Organization and participation with watershed partners (1)
 2b) Please describe the components
 that have not been effective
Monitoring program (5)
Too early to tell (2)
BMPs in redevelopment and residential areas (1)
Illegal/illicit discharge program (1)
Additional Comments:
Monitoring data not useful for program management (2)
Monitoring requirements do not account for geographical differences
among municipalities (1)
Illegal/illicit discharge program as required does not achieve desired'
results; need modification of procedures (I)
 3) How would you rate the overall effectiveness of the Phase I Storm Water Program in improving the quality
 and quantity of storm water discharges and protecting water quality in your jurisdiction?

 In your opinion, did implementing the Phase I program in your jurisdiction result in protecting or restoring your
 watershed's physical, chemical, and/or biological quality?
 3a) The Phase I control program
 assisted in protecting the quality of my
 jurisdiction's watershed?
Yes (5)
Uncertain (4)
No comment (1)
Additional Comments:
Protection provided through illicit discharge elimination and BMP
implementation (1)
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          Survey Question*
        Summary of Responses (Number of Respondents)1*
 3b) The Phase I control program
 assisted in restoring the quality of my
 jurisdiction's watershed?
Yes(l)
No (2)
Uncertain (6)
Additional Comments:
Protection provided through illicit discharge elimination and BMP
implementation (1)
Restoration is possible if program flexibility is provided (1)
 4) Can you suggest any potential
 changes EPA may want to make to
 improve the program's effectiveness or
 streamline its approach?
Integrate with EPA watershed approach and watershed permitting,
including requiring co-permits on a watershed basis (3)
Provide program with sufficient funds and resources; additional funds
will assist in developing scientific basis for decision-making (3)
Fund and promote research to identify new storm water control
technologies and to determine BMP effectiveness (3)
Integrate with other wet weather control and CWA programs (1)
Require performance measures so program effectiveness can be
tracked (1)
Allow use of stream health assessments (bioassessments) (1)
Revamp sampling parameters to parallel multi-sector general permit
monitoring requirements (1)
Provide examples of successful monitoring programs (1)
Consider climatological and geographical locations of MS4s prior to
producing costly regulations (1)
 5) If you would like to share any other
 information relevant to the Phase I
 program, please feel free to use this
 space.
MS4 permits will assist in improving water quality; however, results
will not be seen until we have completed our move from planning
under the first permit to implementation under the second permit (I)
The use of bioassessments to monitor biological communities should
be advocated in lieu of chemical monitoring (1)
Preserve the BMP approach as opposed to use of effluent limits (1)
 a The questions provided in this table represent only those related to the effectiveness of the local Phase I
 program. The NAFSMA survey also included several additional questions on program implementation costs.
 b Ten entities responded to the NAFSMA Phase I survey. The number of responses indicated in this table may
 exceed 10 because of the possibility for multiple answers to a question by one entity.
Overall, the limited NAFSMA survey independently confirms some conclusions from EPA's
survey.  In summary, NAFSMA respondents indicate the following:

•     Either the Phase I program has been successful in improving local water quality or it is too
      early to determine the influence of the Phase I program.
      The most effective program elements were illicit discharge location/elimination and public
      outreach.
      Monitoring the constituents of Storm water discharges, while initially useful to characterize
      Storm water in the development of municipal programs, may not be the most effective use
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     of resources in the future. Standardized monitoring methods that help characterize
     receiving water quality (e.g., bioassessments) should be further explored.
     EPA needs to streamline its approach to support integrated watershed management that
     combines all pollutant sources and cuts across political boundaries.

The number of N'AFSMA respondents indicating "too early to tell" about effects on water quality
reinforces EPA's conclusion that the Phase I MS4 program is continuing to mature.

3.3.2  Loading Reductions

One of the key surrogate indicators of water quality benefits attributable to the Phase I program
is the amount of pollutant prevented from reaching the environment. A water quality
improvement occurs when a Phase I municipality uses storm water BMPs with a proven
capability to minimize or trap pollutants that could otherwise be conveyed through the MS4 to
receiving waters.

This section uses case studies and the results of MS4 surveys to describe how the Phase I
program has contributed to pollutant load reductions.

3.3.2.1 Case Studies

This section summarizes case studies that illustrate where specific Phase I MS4s are innovatively
meeting permit requirements and improving on earlier, pre-Phase I efforts. The case studies
include  examples of nonstructural BMPs (which prevent contamination of storm water through
measures such as better urban planning, good housekeeping, and household waste recycling) and
structural BMPs (which intercept and remove pollutants in storm water runoff from new
developments).

Table 3-3 summarizes the case studies used in this section and describes their relevance. (AH of
the case studies for this Report are in Appendix D.)
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Table 3-3. Summary of Loading Reduction Case Studies
Case Study Location
Montgomery County, MD
Fort Worth, TX
Portland, OR
Boston. MA (Charles River)
Austin, TX
Feature(s)
Nutrient reductions from structural BMPs help meet regional reduction
goal.
An effective household waste collection program can safely dispose of
large quantities of pollutants
An aggressive inspection program results in significant amounts of
pollutants being prevented from entering the environment.
Phase I dry-weather inspections identify sources discharging thousands of
pounds of pollutants.
Installation of BMP protects the Colorado River.
Loading Reductions with Nonstructural BMPs

The influence of nonstructural BMPs often cannot be established through monitoring of ambient
water quality. For example, public education that prevents illicit dumping into storm drains,
household waste collections, and zoning changes that affect future development prevent a rise in
ambient pollutant levels as well as lowering them in some cases. However, their influence can
be difficult to identify because successful monitoring would require long-term, costly, and
extensive networks to note decreases in intermittent pollutant discharges. In addition, if a
pollutant is never discharged as a result of prevention efforts, monitoring would only establish
the lack of change in ambient conditions.

Three case studies help illustrate how nonstructural BMPs affect pollutant loadings in storm
water.

The case study of the Charles River in Massachusetts demonstrates how storm sewer
inspections and dry-weather monitoring (nonstructural BMPs) yield a reduction in pollutant
discharge through the storm sewer system. Boston, a Phase I permittee, is a major participant in
a multi-jurisdictional effort to improve water quality in the Charles River. As required by its
Phase I MS4 storm water permit, Boston is inspecting its storm sewer system for cross-
connections (i.e., points where sanitary sewers inappropriately discharge into storm water
sewers).  Boston has identified and eliminated a number of cross-connections, the largest of
which discharged an average of 70,000 gallons per day of raw sewage into the storm drain
system. Because of Boston's efforts and the efforts of other upstream municipalities, dry-
weather water quality has improved, as has the opportunity for secondary-contact recreation.

In Portland, Oregon, regular monitoring has prevented a variety of wastes  and waste types from
reaching receiving waters. In an effort unusual for most MS4s, Portland estimated the pollutant
load prevented from reaching the environment in a single year due to the illicit discharge
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 monitoring program. Although many MS4s inspect for and remove illicit discharges, the vast
 majority do not collect and record data on the resulting pollutant load reduction.  Portland
 estimated that in 1996 alone its inspection efforts prevented the discharge of 250 pounds each of
 TSS and BOD, 40 pounds of total nitrogen, and 10 pounds of phosphorus from its MS4.

 Within each MS4 the types of wastes illicitly discharged to the storm sewer vary. They can
 include washwater discharges, industrial wastes, and fluids washed from accident/spill areas.
 Again, Portland estimated load reductions attributed to its Phase I program for these types of
 discharges. Portland estimates in 1996 that the effects of a 400-pound diesel fuel spill were
 averted.  With respect to washwater, 100 pounds of TSS, 80 pounds of BOD, 4 pounds of oil and
 grease, and less than 1 pound of copper, lead, and zinc were prevented from entering the MS4.

 The Fort Worth, Texas, case study illustrates the effectiveness of the pollution prevention
 elements encouraged under the Phase I storm water program.  Identifying household waste as one
 of the local priorities in its storm water management program, Fort Worth now annually destroys
 or recycles 50,000 gallons of toxic liquid waste and keeps it out of the environment. A recent
 behavior study indicates environmentally unacceptable disposal practices are used by 5 to 39
 percent of surveyed homeowners, depending on the type of waste (Sacramento,  1999). As a
 result, EPA believes Fort Worth's new household waste collection prevents a significant amount
 of pollutants from affecting the water bodies around Fort Worth. After only 2 years of operation,
 3 percent of area households are now using the regional household waste drop-off center
 operated by Fort Worth and surrounding communities. This is a significant increase compared to
 the city's earlier efforts.

 Loading Reduction with Structural BMPs

 Structural BMPs typically provide for detention or infiltration of storm water runoff and have
 been evaluated widely as a means to reduce pollutant loadings.  The actual load reduction varies
 as a function of the type of pollutant measured, but it is common to see pollutant reductions
 reported in literature of between 20 and 80 percent for the area served. Pollutants are removed in
 one of two ways: (1) by natural processes that degrade or recycle pollutants; or (2) by physical
 removal through BMP maintenance efforts (e.g., removal of accumulated sediment/sludge).

 Two case studies are presented here that illustrate pollutant load reductions for Phase I
 communities using structural BMPs. The first (Austin, TX) examines a single BMP installation
 and the second (Montgomery County, Maryland) illustrates pollutant reductions on a
jurisdiction-wide basis.

 In Austin, Texas, a joint  public/private enterprise between the State of Texas and a private
 developer is installing storm water detention ponds to minimize the impacts   a mixed-use
 development while providing aesthetic and economic benefits. The resulting pollutant load
 reduction for the detention ponds has been estimated based on local rainfall patterns, design
 parameters used in the pond, and removal efficiencies typical of detention ponds. Compared to

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an unmanaged condition, the ponds will reduce the sediment discharged annually from the site
by several tons and will reduce nutrients discharged by between 44 and 65 percent.  By capturing
300,000 cubic feet of rainfall runoff, the ponds annually remove 36,400 to 50,000 pounds per
year of sediment, 55 to 275 pounds of nitrate/nitrite, 55 to 2000 pounds of phosphorus, 5 to 50
pounds of lead, and 10 to 150 pounds of zinc. Additional downstream benefits include improved
oxygenation (from constructed waterfalls  in the park) and flooding and erosion control (due to
the slow release of captured runoff).

As a regular part of the annual reporting for its Phase I permit, Montgomery County,
Maryland, estimates the number of pounds of pollutant removed using structural BMPs. The
county estimated in 1998 that structural BMPs prevented 23 percent of the sediment load and
27 percent of the nitrogen load from the area within its jurisdiction from entering streams.  These
countywide load reductions are particularly impressive given that extensive portions of the
county were developed before the storm water requirements. Reductions in sediment load are
important because Montgomery County is now paying millions of dollars annually to restore
streams affected by urbanization and the resulting excessive in-stream sediment loads.
Reductions in nutrient loads are also important because Montgomery County is a party to a
multi-jurisdictional effort to minimize nutrient loadings into the Chesapeake Bay. Several
municipalities in Montgomery County (e.g., Rockville and Gaithersburg) have developed public
service announcements highlighting storm water management activities. These have been shown
on the dedicated city government channels on the local TV cable system.

3.3.2.2. National Storm Water BMP  Database

Recently, a national storm water BMP database was produced under a cooperative agreement
between the American Society of Civil  Engineers (ASCE) and EPA.  The purpose of this project
was to provide a mechanism for sharing consistent and transferable information on storm water
BMPs. The database (summarized in Appendix D) contains load reduction information from
60 studies contributed by 30 municipalities in 11 States. For each of these studies, the permittee
established a test location, monitored the water quality upstream and downstream of the BMP,
and assessed the pollutant load reduction.

The ASCE/EPA BMP database reports how various BMP technologies reduce pollutants, details
individual BMP installations, and describes limitations of each  BMP technology. Monitoring
summaries of individual BMP installations demonstrate a wide range of storm water pollutants
are reduced by properly designed and installed structural BMPs including oil and grease, TSS,
nitrogen, phosphorus, pathogens, lead, copper, zinc, and other metals. While the actual pollutant
removals vary with the BMP, the pollutant, and the size of the rainfall event, the BMP database
reports pollutant reductions generally fall  in the range between  15 and 65 percent.
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3.3.2.3 Survey of Loadings Averted

As described in Section 3.2, EPA performed a limited survey of approximately 3 percent of
current Phase I permits distributed throughout the United States. One of the purposes of the
survey was to collect information on changes in storm water pollutant loadings attributable to
Phase I program requirements. A change in loadings was generally defined as the difference in
pollutants collected or captured through a storm water management element. For example, a
5,000-pound load reduction would occur if a permittee reported that annual street sweeping
removed 10,000 pounds in 1989 and 15,000 pounds in 1999.  It should be noted that EPA
counted load reduction only if MS4 permittees indicated Phase I permit requirements were
responsible for their upgraded storm water control efforts.

Current-data on annual load reductions are usually provided in the annual reports produced by
permittees as required in the Phase I regulations. However, retrospective data (baseline load
reductions before the rulemaking) are not always available  for all permittees for all BMPs of
interest.  To help produce a fair comparison of pre- and post-rulemaking conditions,  EPA asked
all respondents to estimate pre-Phase I load reduction. Appendix B contains the form used to
collect data on load reductions, past and present, from the respondents.  Six of nine MS4s
returned surveys with information on load reduction histories.

It should be noted that not all information provided by surveyed MS4s is expressed in terms of
pounds of pollutant prevented from reaching the environment. Based on earlier investigation,
ET \ determined that for some program elements MS4s seldom collect and report load
reductions, but instead use a surrogate measure (e.g., numbers of illicit discharges corrected).
Where load reduction data are unavailable, EPA has collected information  on surrogate measures
to help demonstrate the potential increase in load reductions.  Often several surrogate measures
are available to demonstrate the positive influence of the Phase I program.

Table 3-4 provides two sets of values calculated by totaling all responses of the surveyed MS4s.
Most values in Table 3-4 are presented in terms of annual pounds of pollutant managed: (1)
before; and (2)  as of 1999.

As demonstrated in Palo Alto, California, pollution prevention planning and engineering can
result in a decrease in pollutant concentrations originating from vehicle service facilities.
Concentrations of metals in storm water runoff decrease significantly with  use of BMPs as
demonstrated through several years of regular monitoring.  From 1993 to 1996 the quality of
storm water discharges from vehicle service facilities improved: concentrations of copper
dropped 89'percent; lead, 96 percent; nickel, 93 percent;  and zinc, 77 percent.

As demonstrated in Prince George's County, Maryland, developers can select from among a
suite of storm water control BMPs.  Integrating the BMPs produces increased storm  water
protection and greater reduction in pollutant concentrations where storm water leaves the urban
area. Actual pollutant removals measured at test installations indicate that  storm water pollutant

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concentrations decrease as a result of structural BMPs by 20 and 80 percent for nutrients and 40
to 99 percent for metals.

Table 3-4.  Total Reported Load Reductions Attributed to Phase I Permitting as Reported
bv Surveyed Permittees
Load Reduction Element
Pre-Phase I
Values
Values Reported as of
1999
Fort-Wor^TX: Household-Waste Collection Efforts < -->"•> r • ci.*,^"-'
. ** .-»**
Actual Number of Drop-offs at Collection Facilities
Households with the Option to Drop-off HHW
Volume of Paint Collected Annually (Gal.)
Volume of Auto-fluids Collected Annually (Gal.)
Volume of Pesticides/ Herbicides (Gal.)
Volume of Other Liquids Collected Annually (Gal.) (Gal.)
1,498
349,624
27,487
12,527
0
13,064
Mfiiiiln'1 nF-TSIrwvJ Pi r vpntiruvTac i1ttt'*>< Trmv'rtwt-smrl iMnHrfi«1 iirvifSain Wjrtrr (
••. • . '-• .. • . •' . •••••.•- .- : ,••£,:'_•; a... ~- • •• 'V
Annual Inspections
Total Modifications
442
1
27,664
1,105,314
184,250
111,647
6,257
28,816
jiijuit^^ntt?iy^VCToBBiBBB^B
1,500
30
Acreage Served by Ketrofitte&Elood Preventioiif acflitiesSs^f-fec-year iRe^bitad^S1; -:|g?;^^^^^
Acres Now with Some Water Quality Protection
801
153,223
Estimated Annual Reductiotism the Year-ReportedDue1o New:PoKcies fogPublic-^Agn^^^^^^^^
feVbiades; and Fertilizers Use; - " ; ' ' : -: : ? r.—";;' •.••«>•;. ••''• '^^^PS^j^^p
Pounds of Herbicides
Pounds of Pesticides
Pounds of Fertilizers
0
0
0
0
996
196
FcfitnatTfl Annual Vr'it'*-'--- '*^-'Vl^^l~ "tt&Af.^*,^i,.>J'Pm*'4^Vri^^

Gallons Captured
Pounds Captured
8,842
70,762
21,795
90,95 1
Number of Illicit Discharge Investigations and Discharges Addressed ! :- , ^Ji'^SlS^^^
Investigations Performed Annually
Illicit Discharges Addressed Annually
2,521
1.046
15,329
1,663
Pounds of Trash/Sediment Removed from Roadways in the Year Reported ..-•:•. ..-•..: .' • 5.;^8^i
Pounds of Trash/Sediment Collected
34,179,545
49,254,560
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The values in Table 3-4 indicate that, for the surveyed MS4S, Phase I requirements resulted in a
significant increase in pollution prevention activities and the amount of pollutant loadings
averted.  This is particularly notable for the spill management and street maintenance elements of
the program. Most program elements in Table 3-4 entail nonstructural BMPs and involve
activities that are dispersed and difficult to track.  As a result, EPA believes the actual pollutant
load reduction generally is under-reported in the MS4 community, and multiple examples can be
found in the MS4 case studies in Appendix D.

As one example, EPA has already described (see Section 3.3.1) that MS4 permittees identifying
and remediating illicit discharges in their sewer systems rarely report on the frequency, nature, or
volume of illicit discharges they manage.  Because of the lack of this information, EPA used the
number of illicit discharge investigations and the number of illicit discharges stopped as
surrogate measures to demonstrate the benefits of the Phase I program.

Another example of the difficulty of reporting pollutant load reductions is the use of pesticides
by public agencies. Survey respondents indicate that public management of pesticides,
herbicides, and fertilizer appears to be one of the areas least affected by the Phase I requirements.
In part this might be the case because pesticide use under a single permit is typically distributed
throughout multiple public agencies, leading to decentralized record keeping and variations in
annual use on an agency-to-agency basis.  Furthermore, a single permit might include 10 co-
permittees, each of which has four organizations that individually use a spectrum of chemicals.
So, most respondents' programs appear to focus on training staff to correctly apply these
chemicals and do not track the amount or location of chemical application. However, certain
major municipalities (e.g., Fort Worth, Texas; King County, Washington; and San Francisco,
California) are aggressively exploring a no-use or limited use pesticide policy, which might
result in future load reductions.

In summary, the limited MS4 survey results indicate that the Phase I program has resulted in
pollutant load reductions from a wide variety of storm water management program elements.
For those elements where actual pollutant reductions cannot be reported, surrogate measures
clearly indicate management improvements since the promulgation of the Phase I rule.  In
addition, MS4 load reductions reported by permittees are not as high as they will eventually be
because most permittees report that their programs are not yet fully implemented.

3.3.3 Water Quality Indicators

This section describes the water quality benefits attributable to the Phase I program.

3.3.3.1 Case Studies

Table 3-5 summarizes the case  studies that indicate water quality improvements.  The examples
from Phase I MS4S are augmented with other case studies (e.g., those from Phase IIMS4

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communities or professional literature) where they exemplify the benefits of storm water controls
similar to those required under Phase I.
The case studies listed in Table 3-5 illustrate some of the water quality and environmental
benefits that have resulted from the Phase I permitting program. The case studies selected stress
different features, including MS4 efforts to prevent environmental problems and to reduce
pollutant concentrations.

Table 3-5. Summary of Water Quality Improvement Case Studies
Case Study Location
Boston, MA
Dover, NH (Pending Phase II
City)
Minneapolis, MN (Pending Phase
I City)
Prince George's County, MD
Feature(s)
Phase I dry-weather inspections lead to additional recreational water use
and higher water quality.
Dry-weather inspections lead to higher water quality.
Public education diminishes concentrations of pesticides; linked to general
household uses.
Nutrient reductions from structural BMPs help meet regional reduction
goal.
Some of the case studies indicate potential water quality benefits expected as new management
efforts are created to address the storm water pollutants/problems just now being identified by
Phase I permittees.  Isolating water quality improvements related to Phase IMS4 permitting is
often complicated by overlapping efforts with other regulatory efforts, including the Coastal
Zone Management Act, Clean Lakes Program, National Estuary Program, and Endangered
Species Act.  Point and nonpoint source pollutant discharges, natural variation in rainfall
patterns, phasing-in of storm water BMPs, and limits on science and funding all complicate
reporting of the direct water quality benefits of the Phase I program.  However, storm water
quality improvements related to structural and  nonstructural BMPs are demonstrated through
local monitoring and reporting from both Phase I and non-Phase I communities. The following
subsections discuss how case studies demonstrate the effectiveness of Phase I permit elements.

Public and Business Outreach Efforts

Public outreach covers a range of elements including mass media information on household
waste collection, marking of storm drains, and industry-specific education.  Correlating outreach
with improvements in water quality is difficult because outreach primarily affects the behavior of
persons who pollute in a dispersed or intermittent manner (e.g., dumping of used oil down a
storm sewer).  This behavior typically is difficult to detect on a regular basis or analyze with
traditional water quality models.  Nevertheless, two case studies help illustrate how outreach has
affected water quality.

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 As illustrated in the Minneapolis, Minnesota, case study, outreach efforts can be correlated to
 reductions in pollutants; specifically, pesticide concentrations in storm water can be reduced
 through public outreach efforts.  Concentrations of various pesticides in a Minneapolis lake
 dropped by between 59 and 86 percent due to an outreach effort. These results are
 commensurate with the outreach efforts of other Phase I cities (e.g., San Francisco) that
 recognize the benefit of public education in protecting storm water quality.  Although the
 effectiveness of public outreach typically can be measured only in terms of changes in public
 awareness and behavior, the Minneapolis case study demonstrates that water quality
 improvement can occur as a result of public outreach efforts.10

 Outreach/education efforts by Phase I cities also focus on businesses such as auto yards or carpet
 cleaners that produce high volumes of liquid wastes with the potential to pollute storm water.
 Sacramento, California, has introduced an innovative program to reduce wash water discharges
 from carpet cleaning businesses. Through a "Clean Business" certification program, businesses
 get credit for correct disposal of wash water,  homeowners have a chance to win prizes through a
 lottery, and wash water is treated fully at the  wastewater treatment plant. Although thousands of
 gallons of wash water are now successfully treated, monitoring to measure the water quality
 impact has not been funded.

 Water Quality Improvements from Structural Storm Water BMPs

 It is not possible to quantify, nationally, the improvement in ambient water quality resulting from
 structural storm water BMPs installed as a result of the Phase I storm water program.  Many
 MS4s are still investigating BMP applicability and phasing the installation of BMP networks.
 Phase I communities are at the forefront of developing/employing structural BMPs to protect
water quality and to meet their local environmental protection objectives.  Case studies identified
by EPA illustrate the water quality improvements possible with installation and implementation
of various BMPs.

Illicit Connections/System Inspection

Under the Phase I regulations, municipal permittees are required to develop storm water
management plans that, among other things, provide for detection and control of illicit discharges
to their MS4s. In many cases, it is technically simple to detect dry-weather flow problems,
although controlling the source can require extensive and expensive rehabilitation.

The case studies of Boston, Massachusetts, and Dover, New Hampshire, illustrate how
sanitary sewer cross-connections to the storm sewer system affect water quality.  In Boston, the
contributions of the Phase I-required sewer inspection program are being discussed  in the context
of a large-scale, multi-year,  multi-community effort to restore designated uses  to the Lower
       to
        As indicated previously, Minneapolis has not yet been issued its Phase I permit.

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Charles River. Although Dover is not a Phase I community, its case study indicates, on a smaller
scale, what happens to pollutant concentrations in a single storm sewer pipe when cross-
connections to the storm sewer are removed. Once the cross-connection had been identified and
repaired, the water quality of discharges from the single storm sewer near beaches and shellfish
beds improved by over 99 percent based on measured enterococci bacteria.
Monitoring Efforts

As stressed in Section 3.3.1, most Phase I communities are still defining the general ambient
water quality of their water bodies, identifying the storm water pollutants-of-concem (POCs) for
their Jocal settings, and quantifying sources of POCs. Given the relatively short time period of
record, it is generally not possible to demonstrate through direct measure/statistical analysis of
ambient water quality levels the changes due to the Phase I program.  However, EPA anticipates
that the expanding pool of ambient data and ongoing characterization of storm water quality will
yield a more comprehensive water quality assessment in future years. At this time, EPA expects
that a minimum often years of monitoring of both ambient and storm water discharges is
necessary for each MS4 to be characterized (the time required to account for natural variation
and to characterize other pollutant sources).

The following two case studies are intended to show different aspects of ongoing storm water
monitoring.  The Los Angeles, California, case study indicates how the results of end-of-pipe
monitoring can  help communities refine their storm water monitoring efforts. With successive
years of storm water monitoring, it is possible to separate POCs from non-POCs for local
waterways. Los Angeles, a Phase I permittee, is currently identifying locations where certain
storm water pollutants need no longer be monitored because the pollutant is not frequently found
within storm water.  Sufficient data exist to indicate where storm water is not contributing to
impairments.  The main pollutants found to cause water quality impairments are certain heavy
metals, coliform bacteria, enteric viruses, pesticides, nutrients, polycyclic aromatic
hydrocarbons, trash, debris, algae, scum, sediments, and odor. With this understanding, Los
Angeles County is now proposing to discontinue monitoring where these pollutants have not
been found to pose a threat.

In Sacramento, California, storm water monitoring results are combined with environmental
data to demonstrate what fraction of the pollutant load in  key water bodies originates from storm
water.  By demonstrating through area wide monitoring that the bulk of the pollutant load
originates from  upstream sources, Sacramento can better understand the impacts of its storm
water discharge.

Demonstrating Avoidance of Future Water Quality Problems

It is likely that much of the benefit associated with the Phase I MS4 permitting program will be
measured in terms of problem avoidance rather than an actual decrease in pollutant

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concentrations in a \\ ater body.  In the case of Prince George's Couoty, Maryland, zoning
changes that decrease percent imperviousness combined with BMPs that infiltrate storm water
runoff from new developments will mean local streams will retain their current natural condition.
The county's use of low-impact development (LID) techniques will decrease runoff generation
by between 75 and 95 percent from current land development designs. Use of LID will yield a
pollutant load reduction simply because less runoff will occur.  The estimated pollutant load
reduction from BMPs that are integrated to create a LID design is over 80 percent for nutrient
and metal pollutants.

Under LID, the bulk of the runoff generated infiltrates into the ground and becomes baseflow for
local streams. As demonstrated by the case study for Montgomery County, Maryland, the
benefit of zoning/design-based BMPs that maintain the pre-development hydrology will stem
from dollars not spent restoring habitat adversely affected by unmanaged runoff. Extensive
stream restoration is being used to repair and stabilize urban streams that are poor supporters of
aquatic life.

3.3.3.2 Survey of MS4s for Water Quality Improvements

EPA used the survey data from a limited number of MS4 permittees to evaluate the water quality
benefits associated with the storm water management elements under the Phase I program. The
survey requested that MS4s indicate the degree to which the development and implementation of
each storm  water management element is beneficial to protection of water quality.

MS4s were asked separately about water quality benefits realized to date and those expected
from continued use. As described in Section 3.3.1.2, many MS4s report that they have not yet
fully implemented their programs, so future benefits may be significantly greater than past
benefits.  Table 3-6 summarizes the overall response  for past and future benefits of the Phase I
MS4 program.
Table 3-6.  Summary of MS4 Water Quality Grades for Storm Water Management
Clements
Grade
General Benefit Observed
Beneficial In Some Places
Probably Beneficial, Not Documented
Benefit Unlikely
nconclusive Benefit
^o Response
Benefits Realized Since
First Permitted
(Percent)*
10
17
51
6
14
2
Expected Future Benefit
From Continued Use
(Percent) a
33
28
27
5
6
2
 Percentages based on 107 total numeric grades received for ail program eiements evaluated plus 5 "No Response" grades
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As Table 3-6 shows, 78 percent of the MS4s surveyed responded that Phase I requirements had
been "Probably Beneficial," "Beneficial in Some Places," or "Generally Beneficial" for their
management areas since program initiation. When asked to grade future environmental benefits,
the total grade for these responses increased to 88 percent.
3.4    FINDINGS OF THE REVIEW OF THE PHASE I PROGRAM FOR MUNICIPAL
       SEPARATE STORM SEWER SYSTEMS

This section summarizes EPA's review and analysis of the Phase I program for MS4s, It first
describes successful components of the Phase I program and then discusses program components
that EPA might need to address to improve the effectiveness part of future storm management
programs.

3.4.1   Successful Attributes of the Phase I Program for MS4s

In this section EPA describes specific MS4 program elements that have been effective in
controlling storm water discharges from MS4s and protecting water quality.

Development of Effective Storm Water Management

EPA's limited survey of MS4 communities indicates that the Phase I program has increased the
number of communities implementing storm water management elements and the number of
communities whose programs have evolved to full implementation. For example, the number of
surveyed communities  now served with erosion and sediment controls has doubled since the
rulemaking, and the number of communities with household waste collection programs has
increased by 50 percent. EPA notes, however, that these results are based on a small sample.

NAFSMA survey respondents indicated that public outreach and training has been the most
effective component of municipal storm water programs in reducing the discharge of pollutants
or improving water quality. Increasing the awareness of public agencies, businesses, and
individuals of their role in pollution prevention has led to reductions of pollutants in storm water
runoff from residential  and commercial areas.

Characterizing Storm Water Pollutants and Impacts

Water quality monitoring over several years by San Francisco and other Bay-area communities
has confirmed the connection between storm water originating from urban areas and pesticide
concentrations in the bay. Based on the findings of the sampling, San Francisco is focusing its
outreach efforts on educating the public at large about pesticide use. It also is reconsidering the
use of pesticides by its  public agencies.
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Monitoring of dry-weather discharges in storm water systems has indicated the presence of
pollutants of concern for many Phase I permittees. Fort Worth, Texas, for example, is
developing management activities to meet a 20 percent reduction goal in detection of soapy wash
water. Portland, Oregon's dry-weather monitoring led to a local program that has prevented the
discharge of hundreds of pounds of pollutants and is helping to prevent new pollutant discharges.

The ongoing Constituent of Concern Reduction Program  employed in Sacramento, California,
addresses specific constituents found in storm water that have been shown to cause or have the
potential to cause pollution in creeks and rivers. Although the program's impacts on the
beneficial uses of the rivers and creeks are not yet known, Sacramento is shaping current
management efforts based on the monitoring data available.

Illicit Discharge Detection and Control

Independent surveys o; MS4 communities by NAFSMA and EPA both highlight the
effectiveness of illicit discharge control programs in protecting storm water quality.

•   As a result of Phase I requirements, Boston has identified and corrected a number of cross-
    connections, the largest of which discharged raw sewage into the storm drain system at an
    average rate of 70,000 gallons per day.

•   Fort Worth's household waste collection program now annually destroys or recycles 50,000
    gallons of toxic liquid waste, thus keeping it out of the environment.

•   Portland, Oregon's Phase I program has reduced pollutant loads from illicit connections,
    wash water discharges, accidental spills, and erosion/sedimentation by 1,980 pounds of TSS,
    330 pounds of BOD, 40 pounds of nitrogen, 10 pounds of phosphorus, 400 pounds of diese!
    fuel, 4 pounds of oil and grease, and less than a pound of the more toxic metals copper, lead,
    and zinc.

•   BMPs at vehicle service facilities in Palo Alto, California, have reduced copper
    concentrations in storm water by  89 percent; lead, 96 percent; nickel, 93 percent, and zinc, 77
    percent.

•   Prince George's County, Maryland's low-impact development (LID) program uses a wide
    array of simple, cost-effective BMPs that infiltrate storm water runoff from new
    developments.  LID techniques decrease runoff generation by between 75 and 95 percent
    from current land development designs, and, on a composite basis, are estimated to reduce
    nutrient and metal pollutant loadings by over 80 percent.

•   Montgomery County, Maryland's structural BMPs prevented an estimated 23 percent of the
    sediment load and 27 percent of the nitrogen load in the permit area from entering streams in
    1998.
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   Three storm water ponds in Austin, Texas's Central Park area provide environmental,
   economic, and aesthetic benefits. By capturing 300,000 cubic feet of rainfall runoff, the
   ponds annually remove 36,400 to 50,000 pounds per year of sediment, 55 to 275 pounds of
   nitrate/nitrite, 55 to 2000 pounds of phosphorus, 5 to 50 pounds of lead, and 10 to 150
   pounds of zinc. Additional downstream benefits include improved oxygenation (from
   constructed waterfalls in the park) and flooding and erosion control (due to the slow release
   of captured runoff).
3.4.2   Components of the Phase I Program That May Need to be Addressed

While collecting and analyzing information for this Report EPA identified several components of
the Phase I program that might not be effective in the form in which they are required. The
results described in this section were based primarily on input received directly from MS4s
through the EPA and NAFSMA surveys. (See related discussion in Section 3.2.)

Monitoring

•  There are no mechanisms in place to directly demonstrate the effectiveness of the Phase I
   MS4 program on improving water quality at a national level.

*  Currently, it appears in some communities that the Phase I monitoring requirements have
   resulted in a significant expenditure of resources without a commensurate return from the
   resource investment (return in terms of storm water management program or direct water
   quality benefits). These inefficiencies were particularly noted in areas where the standard
   Phase I end-of-pipe monitoring was considered inappropriate for the specific geographic and
   climatological locations of some MS4s (e.g.,  areas that experience infrequent rainfall events).
   Several communities noted that the Phase I monitoring requirements should also provide
   more flexibility to acknowledge the site-specific nature of storm water quality as well as local
   priorities.

   Currently, the data gathered to meet Phase I monitoring requirements might not adequately
   characterize the potential impacts of storm water discharges on ambient water quality.
   Several MS4s suggested that storm water impacts might be better measured using
   bioassessment techniques instead of pollutant-specific monitoring.
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Setting Performance Standards for Storm Water BMPs

•   Whether discussing structural or nonstructural BMPs, there are no minimum performance
    standards currently set for permitted entities. One of the NAFSMA survey respondents
    requested that performance measures be developed so that program effectiveness can be
    tracked.  Without such measures, it is difficult to report on a regional or national level what
    the benefits of Phase I program elements actually are. This is a significant problem when one
    of the major techniques used to assess program effectiveness is the pounds of pollutant
    prevented from reaching the environment.

Better Watershed Management/Integration

•   One significant finding of the NAFSMA survey was the need for better integration of wet-
    weather controls on a watershed basis.

•   As shown in the case studies researched for this Report, storm water management is a key
    component in multi-jurisdictional,  multi-watershed efforts to protect high-profile streams,
    rivers, lakes, and estuaries (e.g., Monterey Bay). However, several MS4s expressed concern
    about the general lack of integration of the Phase I program with EPA's watershed protection
    approach, including watershed permitting.  This was particularly the case where watersheds
    are impacted by non-Phase I discharges (e.g., industrial and Phase II storm water permittees).
    EPA also noted a past concern among some Phase I permittees was the absence of storm
    water management requirements in neighboring non-Phase I communities. Phase I
    communities were initially at a disadvantage because (1) development in adjacent
    unpermitted communities affected  water quality within the Phase I boundaries, and
    (2) development opportunities for the Phase I community were lost because developers
    elected to build in nearby unregulated communities.

Need for Additional Technical Research and Outreach

•   When interviewed and surveyed, several Phase I MS4 permittees indicated additional EPA
    support is needed on storm water control technology research and development. Active
    Federal coordination is desired to minimize redundant research among MS4s and to
    standardize reporting of effectiveness. In addition, EPA cofunding of milestone research is
    desired to offset the cost to MS4s of trying to develop innovative solutions.
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        4.  EVALUATION OF PROGRAM FOR CONSTRUCTION ACTIVITIES

This chapter evaluates the impact of the construction activities segment of the Phase I storm
water program. Several studies reveal that storm water runoff from construction sites can include
a variety of pollutants, such as sediment, bacteria, organic nutrients, hydrocarbons, zinc, copper,
cadmium, mercury, iron, nickel, and oil and grease (Barret et al., 1996). In addition, the National
Water Quality Inventory: 1996 Report to Congress, found construction activities (e.g., land
development, road construction) to have a significant impact on lakes and wetlands (USEPA,
1998).

During storms, construction sites can be the source of sediment-laden runoff, which can
overwhelm a small stream channel's hydraulic carrying capacity, resulting in streambed scour,
streambank erosion, stream "blow out," and destruction of near-stream vegetative cover. As the
flow velocity decreases, sediment from construction site runoff settles out, blanketing stream
beds, burying macroinvertebrates, and eliminating the natural stream substrate.  Streams that are
overwhelmed by runoff can become wider. Consequently, they exhibit shallower base flow, lose
their natural riffle-run morphology, lose the vegetative cover that shades the stream and mitigates
temperature swings, and lose their value as habitat for aquatic species. The recurrence of high
storm water flows maintains these degraded conditions, ultimately resulting in water quality and
habitat degradation. The prevention of sediment and flow runoff from construction sites
mitigates this degradation (USEPA, 1999b).

Although small streams are frequently the first water bodies with which storm water comes into
contact, these streams subsequently drain into larger streams, rivers, ponds, lakes, wetlands,
bays, estuaries, or oceans. Thus, stream reaches affected by construction activities often extend
well downstream of the construction site.  For example, between 3.0 and 3.5 miles of stream
below construction sites in the Patuxent River watershed were observed to be impaired by
sediment inputs (Klein, 1979). It is near these downstream water bodies that a large share of the
population lives or participates in water-dependent recreation. When small-stream habitat and
water quality degrade, the downstream systems also are affected, resulting in poor water quality
and decreased  upstream habitat for aquatic species.  When small-stream habitat and water quality
improve, downstream water bodies also realize water quality and habitat improvements, resulting
in benefits  for the population living nearby or using the resource for recreation, as described
below.

Construction fundamentally alters natural landscapes (Toy and Hadley, 1987).  During
construction, earth is compacted, excavated and displaced,  and vegetation is removed. These
activities increase runoff and erosion, thereby increasing the amount of sediment transported to
receiving waters. Siltation has been identified as the leading process affecting rivers and streams
in the Nation (USEPA, 1998). Although agriculture produces the largest sediment load,
construction results in the most concentrated form of erosion, and the rate of erosion from
construction sites can exceed that from agricultural land by 10 to 20 times (WEF and ASCE,
1992). Although erosion and sedimentation are natural processes, when land is disturbed by
construction activities,  surface erosion increases up to 10 times on sites formerly used for crop
agriculture, up to 200 times on sites formerly under pasture, and up to 2,000 times on sites
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formerly forested (Toy and Hadley, 1987).  In addition to sediment, construction activities also
yield pollutants such as pesticides, petroleum products, construction chemicals, solvents.
asphalts, and acids, which can contaminate storm water runoff (Marsh, 1993).

Numerous studies have examined the increases in sediment loads resulting from storm water
runoff.  For example, Daniel et al. (1979) monitored three residential construction sites in
southeastern Wisconsin and determined that annual sediment yields were more than 19 times
greater than yields from agricultural areas.  Yorke and Herb (1978) studied nine sub-basins in the
Maryland portion of the Anacostia River watershed for more than a decade to determine the
impacts of changing land use and land cover on runoff and sediment. Average annual suspended
sediment yields from construction sites ranged from 7 to 100 tons per acre, as compared to yields
from cultivated land and forest/grassland, ranging from 0.65 to 4.3  tons per acre and 0.07 to 0.45
tons per acre, respectively. A 1970 study conducted by the National Association of Counties'
Research Foundation found the potential impacts of urban and suburban development to be even
more dramatic. The Foundation concluded that sediment yields from construction areas could be
as much as 500 times the levels detected in rural areas (National Association of Counties
Research Foundation, 1970).

The remainder of this chapter describes EPA's analysis of the storm water program for
discharges from construction activities.  Section 4.1 of this chapter describes the Phase I
requirements for construction activities. Section 4.2 discusses the general methodology and
primary data sources. Section 4.3 presents the specific methods used to determine the impacts
and the results of these analyses. Section 4.4 presents the overall findings, including a discussion
of program elements considered successful and those considered unsuccessful.

4.1    STATEMENT OF PHASE I REQUIREMENTS

Construction site runoff is addressed by the Phase I program through two major mechanisms.
First, as noted in Chapter 3, Phase I municipalities (MS4S) address construction site runoff
within their jurisdiction.  Second, as described below, sites of similar size outside these
jurisdictions are covered under the program by NPDES permits.  This chapter identifies the
programmatic, pollutant loading, and water quality improvements associated with both of these
regulatory mechanisms for runoff from construction activities.

The Phase I storm water regulations (55 FR 47990; November 16,1990) requires operators of
construction activity that will disturb 5 or more acres of land to:

•   Obtain a National Pollutant Discharge Elimination System (NPDES) permit for discharges of
    storm water from construction activities to either an MS4 or waters of the United States.

•   Develop a storm water pollution prevention plan (SWPPP) to control erosion and sediments,
    litter and construction debris, and construction chemicals on construction sites.

In developing a permitting approach for storm water discharges associated with construction
activities regulated under the Phase I program, EPA acknowledged the administrative burden on
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EPA and States authorized to implement the NPDES program to provide permit coverage for a
large number of sites. Consequently, EPA and authorized States have primarily relied on the use
of general permits to provide permit coverage.  The primary permit condition to address the
discharge of pollutants from construction sites is the requirement to develop an SWPPP that
addresses the following items:

•  A description of potential pollutant sources and other information such as a description of the
   nature of the construction activity.

•  A description of the intended sequence of major activities that disturb soils on major portions
   of the site.

•  Estimates of the total area of the site that is expected to be disturbed.

•  An estimate of the runoff coefficient of the site for both the preconstruction and post
   construction conditions, and data describing the soil or the quality of any discharge from the
   site.

•  A general location map, as well as a site map indicating drainage patterns, approximate
   slopes after grading, areas of soil disturbance, locations of major structural and nonstructural
   controls, locations where stabilization practices are expected to occur, and locations of off-
   site material.

•  Waste, borrow, or equipment storage areas.

•  Surface waters, including wetlands.

•  Locations where storm water discharges to a surface water.

•  The location and description of any discharge associated with industrial activity other than
   construction.

*  The name of the receiving water(s) and the areal extent and description of wetlands or other
   special aquatic sites at or near the site that will receive discharges from areas disturbed by the
   project.

•  Information on whether listed endangered or threatened species, or critical habitat, are found
   in the proximity and whether such species might be affected by the applicant's storm water
   discharges or storm water discharge-related activities.
Each SWPPP must include a description of appropriate control measures (i.e., best management
practices) that will be implemented to control pollutants in storm water runoff. In the case of
construction activities, control measures include the following:
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*   Erosion and sediment controls designed to retain sediment on site.

•   Controls that prevent construction debris and construction materials from becoming a
    pollutant.

•   Interim and permanent stabilization practices to preserve existing vegetation; establishment
    of temporary vegetation and other techniques to minimize the exposure of soils to erosion;

•   Structural practices to divert flows from exposed soils or otherwise limit runoff and the
    discharge of pollutants from exposed areas.

•   Measures to be installed that will control pollutants in storm water runoff in the post
    construction period.

4.1.1   Current Status of Construction Activities Covered under the Phase I Program

One factor necessary in evaluating the success of the Phase I program is the number of
construction starts regulated under the program. EPA searched its Notice of Intent (NOI)
database and surveyed the EPA regions to estimate the number of construction starts nationwide.
The NOI database tracks permit applications for construction starts in States where EPA is the
permitting authority. The EPA regions provided the total number of construction starts in
authorized States. These efforts identified 111,291 construction starts that have applied for
permit coverage since 1994.' For 1999 the data searches and information requests identified
17,292 construction starts nationwide.  To provide an estimate of the number of permitted starts
in 1999 for States that did not provide data, an average of the reported data over the years of the
program was developed. For 1999 the estimate of the number of permitted construction starts is
19,856 nationwide.

Using the  methodology from the Economic Analysis developed for the Phase II Storm Water
Rule (USEPA, 1999b), EPA estimates that Phase I storm water program applies to roughly
62,755 construction starts annually. This approach to estimate the number of construction starts
is also used for the load reduction analysis (Section 4.3.2).

4.2 ANALYTICAL APPROACH

This analysis provides an understanding of improvements associated with implementing BMPs
and activities associated with the Phase I storm water construction program. The analysis does
not differentiate between the efforts of Phase I municipalities to address construction activities,
those permitted under an applicable NPDES general permit, or regulated under other state and
local sediment and erosion control programs.  The analysis characterizes key program elements
used to achieve the load reductions and water quality improvements.  Where possible, the
analysis projects national trends.
       1 Of the 54 States and territories, only 45 provided construction start data.

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As discussed in Chapter 2, three indicators are used to identity program success:

•  Programmatic indicators show the degree to which communities have implemented
   construction storm water management programs responsive to local needs.

•  Loading reductions are estimates of pollutants averted due to installation, operation and
   maintenance of structural and non-structural BMPs.

•  Water quality improvements are estimates of reductions in pollutant concentration levels
   related to storm water controls.

4.3 SPECIFIC METHODS AND RESULTS

This section provides the specific methods and presents the results of EPA's analysis of the
Phase I program for storm water discharges from construction activities.

43.1   Programmatic Indicators

Case studies collected for the purposes of this Report provide specific examples of how the
flexibility in the Phase I storm water program for construction activities has helped communities.
As noted in Section 4.1, the program was specifically constructed to be as flexible as possible,
allowing local and State jurisdictions to be as innovative as possible in achieving desired results.
Survey results and case studies indicate that the Phase I program has fostered significant
innovation, often in combination with other Federal, State, and local erosion and control
programs. Innovations are demonstrated by the fact that surveys and case studies illustrate that
the program has:

•  Enabled State and local jurisdictions to both integrate and leverage the Phase I program with
   other programs.
•  Promoted cost efficiencies in program development and administration.

4.3.1.2 Case Studies

EPA acknowledges the limited nature of this survey. Consequently, for purposes of this Report,
EPA was able to collect five case studies that demonstrate various aspects of programmatic
success.  These case studies provide some illustration of the flexibility of the program and how
municipalities and States have used existing erosion and sediment control programs to meet and
exceed Phase I requirements.  The case studies include examples of where leveraging Phase I
with other related programs provides water quality benefits, promotes cost effective programs,
and delivers overall economic benefits to the developer and community. Complete copies of the
case studies are provided in Appendix D.
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North Carolina Leverages the Phase I Program with Other Soil and Erosion-Control Programs
to Yield Water Quality Benefits

The State of North Carolina's Sedimentation Control Program has been in place since 1973.
Under this program, the State requires effective sediment erosion controls to prevent inhibition of
aquatic plant growth, disruption offish nests, and the introduction of toxins into the water. The
North Carolina Sedimentation Control Program regulates construction activities equal to or
greater than 1 acre.  The North Carolina program is thus more stringent than the Phase I program,
which limits its jurisdiction to sites equal to or greater than 5 acres.

Within the North Carolina Department of Environment and Natural Resources (NCDENR), the
Division of Land Resources (DLR) is responsible for administering the Sedimentation Control
Program-and the Division of Water Quality (DWQ) is responsible for administering the Phase I
storm water program.  Although NCDENR staff state that integrating  the two programs is not
always easy, they believe having the Phase I program in conjunction with the State
Sedimentation Control Program is ultimately beneficial. The Phase I  program has helped to open
the lines of communication between DWQ and DLR.

The two departments recently joined forces to stop poorly managed construction activities in a
portion of Brunswick County, North Carolina. Ditching activities had resulted in the improper
drainage of nearly 1,500 acres of wetlands. Through inspections, DLR and DWQ determined
that the developers had not prevented off-site sedimentation from the ditching activities. The
activities not only had resulted in a loss of wetlands but also had caused exceedances of the
turbidity standard in Beaverdam Creek, a primary nursery area and high-quality water.  A
settlement reached between DWQ, DLR, and the developers  included the restoration of the
drained wetlands and $213,000 in fines and enforcement costs.
                                             "Historically, the Departments of Water Quality and
                                             Land Resources have had limited interaction, despite
                                             the fact the departments have similar goals regarding
                                             construction site runoff control.  The construction
                                             general permit required under the Phase I program
                                             has been a mechanism to bring different
                                             environmental programs together."
The Brunswick County situation in North
Carolina illustrates how the Phase I program
is an important component of an overall suite
of water quality protection programs. "The
construction general permits we issue under
the Phase I construction program are an
important piece to a comprehensive
construction storm water control program,"
stated Bradley Bennett, the supervisor of the
storm water unit within DWQ. "The Sedimentation Control Program focuses on the primary
pollutant from construction sites, but does not address the other possible pollutants that could
originate from construction equipment and other activities on site. Under the provisions of the
construction general permit, construction site operators must also think about good housekeeping
practices to prevent contaminating runoff with fuels, lubricants, pesticides, and other related
materials."
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New Castle County, Delaware Expands Its Cost-Effective Approach to Program Implementation

The Sediment and Storm Water Program of the Delaware Department of Natural Resource and
Environmental Control (DNREC) illustrates how an aggressive inspection program built on
privately employed inspectors can ensure construction control compliance. The result is a win-
win situation where the environment is protected.  To obtain the mandated construction
inspection, developers can hire one of the hundreds of private inspectors licensed under the
State's Certified Construction Reviewer (CCR) program, first implemented in 1992.
                                                        Officials estimate that the increased
                                                        compliance as a result of the CCR
                                                        program inspections prevents 84
                                                        percent of the sediment that would
                                                        otherwise reach Delaware's waters.
In New Castle County, the CCR program has been a
successful component of the County's overall storm water
management program. New Castle County enjoys a healthy
economic growth rate, as indicated by the  approximately
400 construction sites per year that require development
and implementation of a detailed Sediment and Storm
Water Plan. Because of the incorporation  of CCRs, county
staff time once spent on construction site inspections can
now be more cost-effectively spent overseeing the private CCR inspection process. Through the
CCRs program, New Castle County reports an improved compliance rate while at the same time
saving approximately SI00,000 annually.  Studies have shown that erosion and sedimentation
controls in New Castle County reduce the  sediment in runoff an average of 84 percent, which
equates to an estimated 600,000 tons annually of sediment retained from the 400 construction
starts in the County.

California Demonstrates That Phase I Can Accommodate Alternative, Less Burdensome
Permitting Approaches
The nature of Phase I storm water regulations and the Department of Transportation (DOT) MS4
systems resulted in DOT's holding MS4 permits in multiple Phase I cities.  The different permits
created confusion that resulted in unnecessary delays in highway construction. In 1996, to
ensure a more uniform storm water program, California's Department of Transportation
(Caltrans) requested that the California NPDES permitting authority, the State Water Resources
Control Board (SWRCB), consider adopting a single NPDES permit for all storm water
discharges from Caltrans properties, projects, and activities. Caltrans, EPA Region 9 and the
SWRCB worked together to develop the required permit language, and on July 15,1999, the
SWRCB approved the final Caltrans statewide NPDES permit. The permit covers the
Construction General Permit (CGP)  and MS4 permit requirements as well.  Prior to this
cooperative action, nine different MS4 permits had been held by  various Caltrans Districts, and
there had been no statewide, standard procedure for CGP compliance.

Caltrans is confident that it can meet the challenges of its new permit through the implementation
of its new statewide comprehensive  Storm Water Management Program (SWMP).  The SWMP
requires consideration of the most advanced BMPs, design/construction techniques and
maintenance procedures for all Caltrans properties. This creates  uniformity in site plans
throughout the State.  To ensure maximum protection of State waters, Caltrans is conducting
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research and monitoring studies to identify the most efficient erosion control and vegetation
management BMPs available. The resulting information will be available to other DOTs and
permittees. Caltrans also is developing a geographic information system (GlS)-based database to
provide information on all watersheds, water bodies, and the associated water quality standards.
The database will assist in the new watershed-level highway construction project planning
process outlined in the SWMP. This planning mechanism also will encourage cooperative
partnering between regulators, local community groups, municipalities and transportation
entities.

Emphasis on Education in Garland, Texas, Results in Improved Compliance

The city of Garland, Texas,  started its erosion and sediment control program in 1993 in response
to NPDES permit requirements. One of the first steps was the publication of a construction BMP
manual. The most prominent developers in the area were included in the development of the
handbook and program, and that approach seems to have contributed to acceptance of the
handbook and program by the community, according  to Philip Welsch, Garland's Storm Water
Coordinator. Garland's erosion and sediment control program requires BMPs on sites as small as
5,000 square feet and detailed site plans for all sites of 1 acre or larger. "Implementation of
BMPs has definitely improved as a result of this program," said Welsch. "Erosion control on
construction sites was basically nonexistent before that time."

Garland, in conjunction with seven other Dallas/Fort Worth area Phase Tcities and the North
Central Texas Council of Governments, also developed a training curriculum on the construction
general permit requirements and local erosion and sediment control techniques.

Chattanooga, Tennessee, Establishes Strong Compliance Education Programs

The erosion control program in Chattanooga Tennessee, is relatively young and has drawn from
other municipal storm water management programs in developing three components: erosion
control requirements, contractor education and enforcement. Anticipating the proposed Phase II
rule, the city sets no lower limit for its program and requires erosion and sediment control
measures to be functional before activity begins and to be maintained throughout construction.
When work is completed, the owner must make sure that the site is as erosion-free as practicable,
establishing permanent vegetative cover where no other permanent stabilization technique has
been used. Permanent certificates of occupancy are not granted until either the site is stabilized
or a letter is received from the developer specifically detailing stabilization plans and time
frames.

The city's public works staff discovered that achieving contractor compliance with these
measures would be difficult. Chattanooga first developed education programs and attempted on-
site training sessions. When the sessions did not produce significant improvement, the city, with
initial assistance from the Chattanooga Home Builders' Association, established the Erosion
Control School.  In a free, 4-hour session, developers learn the city's requirements, as well as
cost-effective ways to achieve compliance. Tests before and after the course measure students'
understanding and information retention levels. Those who  pass the second test receive a
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certification card.  In 5 years, the school has certified nearly 300 people associated with all
aspects of development. The city has received very positive responses not only from builders
who have attended the class but also from local officials who wish to develop similar programs
in their municipalities.

4.3.2  Loading Reductions

This section presents the results of a modeling analysis that projects loading reductions from
implementation of the construction component of the Phase I program.  The Phase I rule
regulates construction starts disturbing 5 or more acres of land, requiring construction site
owners or operators to plan and implement appropriate erosion and sediment control BMPs.
Thus, the construction requirements prevent the degradation of water quality due to runoff and
deposition of sediments released from construction sites.
To develop an estimate of sediment loadings from Phase I
construction sites (i.e., disturbing 5 acres or more) and the
loads averted by the implementation of BMPs, EPA
estimated the total number of Phase I construction starts
for the year 1999. Then, to approximate per-start sediment
loads, EPA used an earlier analysis performed by the U.S.
Army Corps of Engineers (USAGE) for Phase II
construction starts entitled Analysis of Best Management
Practices for Small Construction Sites (USAGE, 1998).
The methodology followed is consistent with the
Economic Analysis for the Final Phase II Storm Water
             , 1999b).
                                                         Phase I program implementation
                                                         prevents an estimated 3 million tons
                                                         of sediment from reaching our
                                                         Nation's waters.

                                                         This loading reduction equates to
                                                         more than 264,000 standard dump
                                                         trucks of soil being kept out of the
                                                         Nation's waters.
EPA used building permit information from the U.S. Bureau of the Census and construction start
data from 14 municipalities around the country to estimate the number of 1999 construction
starts greater than 5 acres.2 Estimates from these 14 municipalities of disturbed area per
construction start were then extrapolated to the universe of national construction starts based on
data obtained from the U.S. Bureau of the Census on national building permits. The Census data
provides building permit data for approximately 96 percent of the counties in the United States.
Data files were obtained for the years 1980 to 1995. EPA anticipates that this estimate accounts
for Phase I reported sites and sites  that have not complied with Phase I reporting requirements.
Note that some of the latter may still be  implementing sediment and erosion control measures
through local programs.

To eliminate double counting of programmatic results with other parallel programs (e.g., the
Coastal Zone Act Reauthorization  Amendments of 1990, or CZARA), EPA eliminated some
       2 The 14 localities that provided construction start data were Austin, Texas; Baltimore County, Maryland;
 Gary, North Carolina; Fort Collins. Colorado; Lacey, Washington; Loudoun County, Virginia; New Britain,
 Connecticut; Olympia, Washington; Prince George County, Maryland; Raleigh, North Carolina; South Bend,
 Indiana; Tallahassee, Florida; Tucson. Arizona; and Waukesha, Wisconsin.
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localities that were required to have erosion and sediment control programs similar to the Phase I
program.  For example, no data for load estimates were generated for the ciimate zone
represented by Hawaii in the analysis because the entire State is covered by CZARA. There are
other equivalent programs in addition to those mandated under the Coastal Nonpoint Pollution
Control Program. EPA identified state programs with similar requirements for sites that disturb 5
or more acres, and they were also removed from the analysis.

Pollutant loading reductions from Phase I construction starts were estimated with and without
Phase I controls (USAGE, 1998). Sediment delivery loads were estimated for 18 climatic
regions under several scenarios: two site sizes (5-10 and >10 acres), three soil credibility levels
(low, medium, and high), three slopes (3, 7, and 12 percent). The 18 climatic regions were used
in an effort to represent the various climatic conditions throughout the United States. To adapt
the USAGE analysis to the Phase I universe, EPA modified the length-slope factor to reflect the
larger construction sites regulated under Phase I and used the same parameters for the remaining
model assumptions.3

Using EPA guidance on storm water management for construction activities (USEPA, 1992b),
combinations of BMPs for the model sites were developed to mimic commonly accepted erosion
and sediment control practices. Additionally, BMPs were selected based on guidance contained
in Brown and Caraco (1997).

Average sediment load per climatic region for Phase I construction sites with moderately
erodible soil were determined. Then, the average loads per climatic region were multiplied by
the ratio of total Phase I construction starts in each climatic zone to the total Phase I construction
starts nationwide to obtain a national weighted average sediment load per site. This
methodology was used to calculate sediment loads from construction starts with and without
Phase I controls. These values are presented in Table 4-1.

The  annual average soil loss per site without the Phase I program was 63.4 tons
(3,977,518 tons/62,755 starts), and the potential reduction in annual average soil loss could be up
to 46.4 tons per site with Phase I BMPs (2,911,523 tons/62,755 starts). The analysis concluded
that  73 percent of the sediment that would otherwise be delivered into the Nation's waters is
retained on construction sites due to controls implemented pursuant to Phase I requirements.
       3 The estimated amount of disturbed area for the 5-10 acre category was 7.5 acres; for the 10 acre and
above category, 13.9 acres.

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Table 4-1. Sediment Load Averted by Phase I BMP Implementation by Climatic Zone
Representative
City
Portland
Boise
Fresno
Las Vegas
Denver
Bismark
Helena
Amarillo
San Antonio
Duluth
Des Moines
Nashville
Atlanta
Hartford
Charleston
Hawaii
Alaska
Atlantic Islands

Climate
Zone
A
B
C
D
E
F
G
H
I
K
M
NPDES
. P
R
T
V
W,X, Y
z
TOTAL
Starts/
Year
655
1,211
0
6.034
2,963
807
1,691
3,998
1,098
4,047
12,943
11,676
8,715
3,877
2,308
0
155
578
62,755
Potential Load
(Tons/Year)
15,383
4,679
0
13,987
41,436
14,027
7,804
151,975
110,993
139,603
808,733
1,053,803
1,037,969
191,866
385,260
0
0
0
3,977,518
BMP Reduced
Load (Tons/Year)
3,076
853
0
761
8,879
2,892
1,435
40,458
33,111
29,883
217,207
292,870
284,643
44,950
104,978
0
0
0
1,065,995
Load Averted
(Tons/Year)
12,307
3,826
0
13,226
32,558
11,135
6,369
111,517
77,882
109,721
591,526
760,932
753,327
146,916
280,281
0
0
0
2,911,523
Percent Load
Averted
80.0
81.8
0.0
94.6
78.6
79.4
81.6
73.4
70.2
78.6
73.1
72.2
72.6
76.6
72.8
0.0
0.0
0.0
73.2
To evaluate the Phase I programs's success in sediment load reduction for construction starts that
have met reporting requirements, the NOI construction start data were also used in the load
reduction analysis. Using the average sediment load reduction per site (46.4 tons per site) and
estimates of the number of permitted construction starts in 1999 developed from the NOI
database (19,856 sites), this analysis indicates that Phase I program has prevented up to 882,000
tons of sediment from entering the Nation's waters. Using the number of reported 1999 NOIs as
a lower bound estimate and the total estimated number of potential Phase I construction starts as
an upper bound estimate, the total amount of sediment prevented from eroding into the nations
waters is 1999 was between 882,000 and 3  million tons.

4.3.3   Water Quality Improvements

Implementation of construction site BMPs is directed toward protecting and improving the water
quality and physical condition of both small streams and larger water bodies.  Runoff from
construction sites may be particularly damaging to small streams because of the streams'
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typically small flow volume and channel size, which lessen the stream's ability to accommodate
high flows and large sediment loads (US EPA, 1999b).  EPA estimates that over one percent of
all water bodies suffer major impairments from construction activities and has identified siltation
as the leading pollutant or process degrading rivers and streams in the Nation (USEPA, 1998).

Water quality benefits that can result from construction control programs range from reduced
pollutant loadings to increased habitat preservation to increased navigational benefits from
reduced dredging of sediments. Currently, these benefits can only be estimated demonstrated by
case studies and by statistical analyses.

First, a  case study of how the State of Washington is using the Phase I program to protect water
quality  is provided.  Then a statistical analysis is provided that looks at the relationship between
construction starts, storm water controls, and receiving water quality. In the absence of sufficient
data regarding water quality conditions before and after the Phase I program, the analysis uses
Florida's CZARA program as a surrogate for Phase I to study the relationship between erosion
control  and water quality. A comparison of water quality and construction start data indicates
that there is a positive relationship between implementation of construction erosion and sediment
controls and reduction of total suspended sediment monitoring.

4.3.3.1  Case Studies
Ensuring Responsible Development in Grays Harbor County, Washington Results in Water
Quality Protection

The siting and development of the Stafford Creek Corrections Center in Grays Harbor County,
Washington, did not occur without controversy.  The mixed emotions of county residents
stemmed from a conflict between the desire for economic development and concerns about
degrading the Grays Harbor Estuary, a water body currently listed as impaired on EPA's section
303(d) list of impaired waters.  Construction of the facility requires disturbing approximately 210
acres along Stafford Creek, a tributary of the Grays Harbor Estuary that drains 1,100 acres and
contains valuable salmon and oyster habitat as well as wetland resources.  Although local
supporters of the facility
recognized the potential adverse
impacts on the aquaculture
industry, they understood the
importance of bringing at least 650
additional jobs into the area.
Federal, State, and local
stakeholders involved in the
Stafford Creek Corrections Center
proposal worked together to see
that both economic development
and environmental protection in
Grays Harbor County would be
The State of Washington Uses Phase I to Protect Its Waters
Washington's Department of Ecology has found the Phase I
program to be instrumental in addressing discharges to
valuable ecological and drinking water resources. For
example, the Phase I program was used to address several
affected areas:
• Murky runoff draining from Issaquah Heights, a 3,250-
 home construction project, into Issaquah Creek and
 threatening the local water supply.
• Damage to Valley Creek caused by a torrent of mud that
 washed off a Washington State Department of
 Transportation construction site.
• Turbid water draining into Salmon Creek, an important
 habitat for endangered steelhead trout, from the Battle
 Ground Market Center construction site.
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possible. The storm water construction permit, as required by the Phase I program, provided a
mechanism to ensure that the development of the facility would not threaten the nearby wetlands
and salmon habitat of Stafford Creek and other surrounding water bodies. The most important
requirement of this permit was the development and implementation of an SWPPP. Although
the Washington Department of Ecology (WDEC) does not typically review and approve
SWPPPs, it can review SWPPPs for projects that may pose a significant water quality concern.
The Department of Ecology worked with the Washington Department of Corrections (DOC) to
develop a SWPPP that would, when implemented, successfully control sediment-laden runoff
from the construction site. Under the Phase I program, development and implementation of a
SWPPP are enforceable permit conditions.

Construction of the Stafford Creek Corrections Center began in June 1998, and storm water
runoff problems started with Washington's rainy season in the fall.  Beginning in October 1998,
the DOC reported exceedances of the turbidity water quality standard. Inspections conducted by
WDEC between November 1998 and February 1999 revealed that the DOC was not fully
implementing its SWPPP. For example, although the SWPPP required construction to stop
during the winter rainy season, construction activities continued beyond October and into the
winter to meet the scheduled opening date of the facility. Some of the BMPs described in the
SWPPP were either not in place on-site or were not  receiving proper maintenance. As a result of
improper storm  water control activities, a slope failure occurred that covered 0.2 acres of a
nearby wetland. Monitoring and reporting during this period, conducted by both the DOC and
local college students, documented the frequency and magnitude of violations. By February
1999, the DOC had reported 62 violations.
The DOC invested
significant time and
money in addressing
problems on its site and
implementing its
SWPPP. According to
monitoring and reporting
data, that investment
paid off in improved
storm water quality. As
shown in the adjacent
text box, DOC reported
more than 10
exceedances of turbidity
standards each month
between November 1998
and February 1999. In
contrast, DOC did not
report any exceedances
between March and
Monthly Exceedances of the Water Quality Standard for Turbidity
Reported to the Washington Department of Ecology by the
Washington Department of Corrections
Month
(1998 — 1999)
November
December
January
February
March
(SWPPP fully implemented and
turbidity problems addressed)
April
Number of Exceedances Reported
14
15
11
22
0
0

Source: Washington Department of Ecology
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April 1999, after construction workers had fully implemented the SWPPP and addressed the
problems on-site.

4.3.3.2 Statistical Analysis of Water Quality Improvements

To assess potential water quality improvements that could be associated with Phase I
construction controls, EPA sought to identity jurisdictions that (1) experience a high rate of
construction activity and (2) are located within a watershed that has been monitored for changes
in water quality indicators. The water quality data used for this analysis came from the U.S.
Geological Survey's National Stream Water Quality Monitoring Network (WQN). The
construction data were U.S. Census Bureau building permit data.

Most of the currently available WQN data covers only the period from 1993 through 1995. On
the other hand, Phase I construction controls were not put in-place until October 1992.
Consequently, there were insufficient pre- and post-implementation WQN data to produce trend
analysis with meaningful results.

Therefore, EPA conducted a surrogate analysis.  This surrogate analysis is summarized here; a
more detailed explanation is provided in Appendix F.  The analysis required a high-growth area
that had put erosion and sediment control provisions into place before the Phase I program and
had requirements that were at least as rigorous as those required under the Phase I program. As a
result of the screening analysis, the State of Florida was chosen to be profiled.  In 1994 Florida
had 24 high-growth counties, as defined in this analysis. Numerous U.S. Geological Survey
(USGS) monitoring stations are located within the State, and the State had implemented the
Coastal Zone Management Act (CZMA) in September 1981. The State of Florida, as a result of
the unique biogeographic conditions found in Florida, included the entire State in the coastal
zone. Furthermore, in 1986 Florida adopted a comprehensive beach management program under
which all coastal counties were required to implement erosion and sediment control provisions
for construction activities. The period from 1980 to 1986 represents the pre-erosion and sediment
control conditions and the period from 1987 to 1994 represents the post-erosion and sediment
control conditions.

To find evidence of reduction in sediment loads  that can potentially be attributed to the
implementation of erosion and sediment control provisions, annual sediment loads from each
watershed had to be derived using WQN data and then compared to annual construction levels
for the counties in the watershed.

Implementation of erosion and sediment controls at construction sites should reduce the total
sediment load leaving the site and ultimately reaching nearby waterways. Consequently, the
analysis is complicated by the fact that the average annual level of construction is not "fixed"
between the before and after periods. Because construction levels are not constant, evaluation of
whether erosion and sediment controls are reducing sediment loads cannot be based on total load
reductions but instead must be based on the rate of change in sediment loadings (in relation to
rate of change in construction). For example, if the construction rate decreased, the loading rate
would be expected to have a greater rate of decrease, and if the construction rate increased, the
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loading rate should have a lesser rate of increase. For this analysis, this is referred to as
"changing in tandem."

Table 4-2 shows the percentage increase or decrease between the first and second period for both
sediment loadings and construction. When each watershed is analyzed separately, the results
show a "change in tandem" for 5 of the 11 watersheds. In the final row of Table 4-2, the
sediment loads and then the construction permits are summed over all watersheds. The result
demonstrates that, in aggregate, both total sediment loadings and construction decreased.
Although average annual construction decreased by only 5 percent, however, the average annual
sediment load decreased by 31  percent. The rate of decrease for aggregate sediment loads is six
times greater than the rate of decrease for aggregate construction. This is supporting evidence for
the hypothesis that erosion and sediment controls are reducing construction site sediment loads in
Florida watersheds.
Table 4-2.  Comparison of Sediment Change and Construction Change for Each Watershed
Watershed
Jpper St. Johns
Daytona
dssimmee
Western
Dkeechobee
Daloosahatchee
Peace
Mafia
Santa Fe
fellow
Perdido
Escambia
Total
Average Annual Sediment
(Tons/Inch of Rain)
1980-
1986
313
24
77
14
254
1,871
257
52
534
210
4.609
8,215
1987-
1994
491
4
100
20
113
187
73
83
519
243
4.449
6,282
Change
36%
-483%
23%
27%
-124%
-901%
-253%
37%
-3%
13%
-4%
-31%
Average Annual Number of
Construction Permits From
Corresponding Counties
1980-
1986
67,063
18,961
43,495
3,287
19,270
32,004
28,717
4,027
2,671
5,467
5,467
230,429
1987-
1994
65,384
19,043
45,577
3,055
18,317
27,465
24,409
3,669
3,163
4,641
4,641
219364
Change
-3%
0%
5%
-8%
-5%
-17%
-18%
-10%
16%
-18%
-18%
-5%
Change
in
Tamden
-
+
.
-
+
+
+
-
+
_
-
+
Note: From Table 4-2, the column heading "average number of construction permits" should not be confused with , or equated to the actual
number of construction starts. Multiple permits may have been issued per construction start.
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The aggregate results suggest that for each comparison it might be useful to look at the
magnitude of the change in sediment loads and not just the direction of the change. For example,
when sediment rates fell or rose in relation to the construction rates, was the magnitude greater
than it was for those instances when they did not change in tandem? EPA used a Wilcoxon
signed-rank test to compare the rates of sediment load increase or decrease and ranked the
changes to determine if the magnitude was significant ('Newmark, 1992). The results of the test
were positive, providing additional evidence suggesting erosion and sediment controls have had
a positive impact on water quality protection when the magnitude of the rainfall and
corresponding sediment loads are considered. For a more detailed explanation of the Wicoxon
signed-rank test and the results, refer to Appendix F.

4.4    FINDINGS OF THE REVIEW OF THE PHASE I PROGRAM FOR STORM
       WATER DISCHARGES ASSOCIATED WITH CONSTRUCTION ACTIVITIES

This section summarizes the analyses conducted for erosion and sediment controls for
construction activities under the Phase I program. The successful elements of the Phase I
program are identified.  Additionally, Phase I program components that have been less successful
and might need to be restructured are also discussed.

4.4.1   Successful Measures of the Phase I Program for Construction Activities

Successful elements of the Phase I storm water program for construction activities, and
improvements in water quality associated with program implementation are discussed in this
section. Although this analysis focused on controlling erosion and sediment at construction sites
disturbing 5 or more acres, construction activities regulated under an MS4 permit, or similar state
or local sediment and erosion control program may be subject to requirements specific to that
jurisdiction.  Many jurisdictions require erosion and sediment controls on construction sites
smaller than 5 acres.  Therefore, the actual water quality protection achieved from all required
erosion and sediment controls is larger than  the portion addressed in this analysis of the Phase I
program.-

Phase I Program Flexibility

EPA recognizes the Phase I program's relationship to other federal, state, and local storm water
control programs. Indeed, in designing the program EPA focused on integration of
programmatic requirements so states and localities could leverage the Phase I program to support
existing programs. The following case studies show  that state and local programs have
successfully integrated and leveraged the program to  improve program administration and yield
water quality benefits.

•   The State of Delaware's inspection certification program increased compliance at
    construction sites while reducing the costs of program administration.  Studies have shown
    that erosion and sedimentation control practices implemented in New Castle County have
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   reduced sediment in runoff an average of 84 percent (up to 600,000 tons of sediment retained
   from the 400 construction starts in the county).

•  Within the North Carolina Department of Environment and Natural Resources, the Division
   of Land Resources (administering the Sedimentation Control Program) and the Division of
   Water Quality (administering the NPDES storm water program) have successfully integrated
   their functions to develop a comprehensive construction storm water program.  Beaverdam
   Creek, a primary nursery area and high-quality water, had experienced turbidity exceedances
   due to poorly managed construction activities. Successful program integration enabled North
   Carolina to curb poor management practices at construction sites in Brunswick County,
   North Carolina.

Loads Averted

•  A modeling analysis conducted for this report estimates that Phase I BMPs applicable to
   construction sites keep 73 percent of the sediments generated during construction from
   reaching surface water bodies.  Using an average sediment load reduction per site (46.4 tons
   per site) and estimates of the number of permitted construction starts in 1999 (19,856 sites),
   the Phase  I Program has prevented up to 882,000 tons of sediment from entering the Nation's
   waters.

Water Quality Protection

   EPA conducted an analysis to assess the correlation between the onset of similar statewide
   CZMA erosion and sediment control programs in Florida and water quality conditions. That
   analysis provided limited evidence of a positive relationship between the implementation of
   storm water controls on construction activities and the key water quality parameter of total
   suspended solids.
•   A Phase I storm water construction permit in Grays Harbor County, Washington provided the
    mechanism to ensure that the development of a major Department of Corrections (DOC)
    facility would not threaten the nearby wetlands and salmon habitat of Stafford Creek and
    other surrounding water bodies.  Before full implementation of the SWPPP, water quality
    exceedances were noted.  After SWPPP implementation, there were no water quality
    exceedances.

4.4.2  Components of the Phase I Program That May Need to Be Addressed

The Phase I program has documented success stories.  There are, however, limitations on EPA's
ability to document program results on a national scale.
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Few Mechanisms Exist to Identify Successful Program Elements

The Phase I Program is one of the many tools used to protect and improve the quality of the
Nation's waters. It can therefore be very difficult to develop analyses that identify the specific
contributions this program provides to water quality. There is insufficient post-implementation
data collected for construction activities disturbing 5 or more acres. As a result, EPA is not able
to conduct a pre/post analysis of national water quality improvements as a result of the
implementation of BMPs at construction sites.
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          5. EVALUATION OF PROGRAM FOR INDUSTRIAL ACTIVITIES

This chapter evaluates the impacts of the industrial portion of the Phase I storm water program.
As demonstrated in this chapter, the industrial program has advanced Clean Water Act (CWA)
water quality protection and improvement efforts by

•  Providing facilities with the necessary flexibility to implement structural and nonstructural
   storm water controls tailored to site-specific conditions.

•  Fostering pollution prevention procedures, many of which can be implemented at a relatively
   low cost.

The remainder of this chapter describes the Phase I requirements for storm water discharges
associated with industrial activity (Section 5.1), the analytical approach used to evaluate the
program (Section 5.2),  the specific methodology used for determining program impacts
(Section 5.3), and the overall findings (Section 5.4).
5.1    STATEMENT OF PHASE I REQUIREMENTS

The Storm Water Phase I Rule (55 FR 47990; November 16,1990) specifies NPDES permit
requirements for eleven categories of facilities with storm water discharges associated with
industrial activity that discharge to waters of the United States or to municipal separate storm
sewer systems (MS4s).

5.1.1   Industrial Facilities Regulated Under the Phase I Program

The definition at 40 CFR 122.26(b)(14) specifically identifies 11 categories of facilities
(identified as "I" through "xi") considered to be engaging in "industrial activity" for purposes of
the Phase I storm water regulations.1  Ten of these eleven categories are discussed in this chapter;
category "x," construction activities is addressed in Chapter 4. As described in Appendix G of
this Report, the Federal regulations define "industrial activities" based on either Standard
Industrial Classification (SIC) codes or facility-specific activities. The industrial activity
categories apply to all types of facilities, including Federal, State, and municipally owned or
operated facilities, with a few exceptions (e.g., the Intermodal Surface Transportation Efficiency
Act of 1991 delayed certain program requirements for municipalities with a population less than
100,000 that perform industrial activities).

For the categories of industries identified in (I) through (ix) of the definition, storm water
discharges associated with industrial activity include, but are not limited to, storm water
discharges from industrial plant yards; immediate access roads and rail lines used or traveled by
carriers of raw materials, manufactured products, waste material, or by-products used or created
by the facility; material handling sites; refuse sites; sites used for the application or disposal of
       1  Covered industrial facilities also include those facilities with storm water discharges associated with
industrial activity where the permitting authority determines that the discharge contributes to a violation of a water
quality standard or is a significant contributor of pollutants to waters of the United States.

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process waste waters (as defined at 40 CFR Part 401); sites used for the storage and maintenance
of material handling equipment; sites used for residual treatment, storage, or disposal; shipping
and receiving areas; manufacturing buildings; storage areas (including tank farms) for raw
materials, and intermediate and finished products; and areas where industrial activity has taken
place in the past and significant materials
remain and  are exposed to storm water.
                                             Significant Materials - 40 CFR 122.26(b)(12)
~ .      /  -V  r*i.  j r-  •«•    jj             Include, but are not limited to, raw materials; fuels;
Category (xi) of the definition addresses
storm water discharges from all the areas
(except access roads and rail lines) listed in
the previous sentence where material
handling equipment or activities, raw
products, waste materials, by-products, or
industrial machinery are exposed to storm
water. This differs from the requirement
for categories (I) through (ix), to which the
requirements apply whether or not exposure has been identified.
materials such as solvents, detergents, and plastic
pellets; finished materials such as metallic products;
raw materials used in food processing or production;
hazardous substances designated under section 101(14)
of CERCLA; any chemical the facility is required to
      . .   .  „      ,.       ,   .   ,-  ,         report pursuant to section 313 of title III of SARA;
materials, intermediate products, final         f ^       ^  A    A    *    A       ,.    u
         '             v                      fertilizers; pesticides; and waste products such as ashes,
slag and sludge that have the potential to be released
with storm water discharges.
                 2
The term "storm water discharges associated with industrial activity" excludes areas located on
plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with
storm water drained from the above described areas.

5.1.2  NPDES Storm Water Permit Requirements for Industrial Activities

Facilities that meet the definition of "storm water discharge associated with industrial activity"
were required to apply for an NPDES permit by October 1992.  In developing a permitting
approach for industrial facilities regulated under the Phase I storm water program, EPA
acknowledged the administrative burden on EPA and States authorized to provide permit
coverage for a large number of sites.  Consequently, EPA and authorized States have primarily
relied on the use of general permits to provide permit coverage for storm water discharges from
industrial facilities.

Each facility covered under EPA's general storm water permit is required to develop and
implement a storm water pollution prevention plan (SWPPP).  As the primary method used to
control storm water discharges, the SWPPP encompasses two main objectives: (1) to identify
sources of pollution potentially affecting the quality of storm water discharges associated with
industrial activity from the facility and (2) to describe and ensure implementation of practices to
minimize and control pollutants in storm water discharges associated with industrial activity
       2 The Phase II storm water regulations (64 FR 68722, December 8, 1999) revise this "no exposure"
provision to apply to all industrial activities identified in categories (i) through (ix) and (xi). However, although
past "no exposure" determinations allowed facilities to opt out of all storm water requirements, the Phase II rule
requires that these "no exposure" facilities must notify the permitting authority in writing of this determination.

                                             5-2

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from the facility. Implementation of a SWPPP provides facilities
with a flexible, relatively inexpensive approach for reducing
pollutant loadings from storm water. An overview of the SWPPP
requirements is provided in Appendix H. Examples of the types
of best management practices (BMPs) in an industrial facility's
SWPPP include the following:

•   Good housekeeping
•   Employee training
•   Site inspections
    Spill prevention and response
    Preventative maintenance activities.

5.1.3   Current Status of Phase I Program for Industrial
        Activities

As  shown in Table 5-1, more than 75,000 facilities are currently
permitted nationwide for discharges of storm water associated
with industrial activity. Table 5-1 lists the number of facilities by
State, grouped into EPA Regions.

The number of facilities listed in each State varies because of
several factors. The amount and type of industrial activity to be
found  in the State is obviously one of the factors that determines
the number of facilities required to be covered under a general
permit. California and Texas list 9,192 and 7,285  facilities,
respectively, or 12 percent and 10 percent of the total.  Other
States  having  large numbers of industrial facilities covered by the
program include Michigan with 4,900 (7 percent), Illinois with
4,172 (6 percent), and Wisconsin with 3,899 (5 percent). These
five States total 29,448 facilities, or almost 40 percent of the total
number of facilities covered in the country.

Information related to the number of facilities within each of the
10 industrial categories is not available for the Nation. However,
EPA has information related to the number of facilities in each of
the 10 categories that are covered by the Agency's multi-sector
general permit (MSGP).  Evaluation of this information provides
an indication of the potential relative distribution of facilities
across categories. Figure 5-1 details the industrial facilities
covered under EPA's MSGP, organized by facility type. EPA's
.general permit applies to facilities in nine States, the District of
Columbia, and Puerto Rico (i.e., those States and territories in
which EPA is the permitting authority).
Table 5-1. Industrial Facilities
Covered by Storm Water
General Permits by State
EPA
Slate Total
CT
MA
ME

NH
Rl
VT
NJ
NY

PR
VI
DC
DE
MD
VA
WV
AL
PL
GA
KY

MS
NC
SC
TN
IL
IN
Ml

MN
OH
W)
AR
LA
NM
OK
TX
IA
KS

MO
ME
CO
MT
ND

SD
UT
WY
AZ
CA
GU
HI
NV
AK
ID

OR
WA
1.261
1,163
468
1
347
142
N/A
1.799
1.821
2
471
1
44
N/A
3 N/A
N/A
N/A
2.764
2.422
2,508
1 856
4
2.415
3.671
2,235
2.254
4,172
1,535
- 4,900
5
2,121
3,282
3.899
N/A
708
6 595
693
7.285
1.249
13
7
2,300
4O2
1.440
220
480
8
560
435
701
727
9,192
9 4
198
534
366
278
10
1.076
1,200
Total: 75,879
N-'A - nol available
                                           5-3

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                1.600
                1.400
              « 1.200
                1.000
                  800
                  600
                 400
                 200
I
                                   I
I
IL^
                                                                        I-  3  > >  x  >-
                                                                      S
                                                      lndu»try Typ«
        A - Timber Products
        B - Paper and Allied Products
        C - Chemical and Allied Products
        D - Asphalt Paving and Roofing Materials and
        Lubricants
        E - Glass. Clay, Cement, Concrete, and Gypsum
        Products
        F - Primary Metals
        G - Metal Mining (Ore Mining and Dressing)
        H - Coal Mines and Coal Mining-related Activities
        ! - Oil and Gas Extraction
        J - Mineral Mining and Dressing
        K - Hazardous Waste Treatment, Storage, or Disposal
        L - Landfills, Land Application Sites, and Open Dumps
        M - Automobile Salvage Yards
        N - Scrap Recycling Facilities
        O - Steam Electric Generating Facilities
        P - Land Transportation and Warehousing
                              R - Shtp and Boat Building or Repairing Yards
                            S - Air Transportation
                            T - Treatment Works
                            U - Food and Kindred Products
                            V - Textile Mills, Apparel, and Other Fabric Product
                            Manufacturing, Leather and Leather Products
                            W - Furniture and Fixtures
                            X - Printing and Publishing
                            Y - Rubber, Miscellaneous Plastic Products, and Miscellaneous
                            Manufacturing Industries
                            Z - Leather Tanning and Finishing
                            AA • Fabricated Metal Products
                            AB - Transportation Equipment, Industrial or Commercial
                            Machinery
                            AC - Electronic, Electrical, Photographic, and Optical Goods
Figure 5-1. Industrial Facilities Covered by the EPA Multi-Sector General Permit  by
Industrial Category

Although Figure 5-1 demonstrates the types of activities covered under EPA's MSGP, it does not
indicate the number of facilities nationwide that actually meet the definition of the individual
sectors. The number of facilities defined by each sector highlights the fact that only a percentage
of any given sector will be covered by a storm water general permit.  Other facilities meeting the
definition might not necessarily require permit coverage.  For example, any facility that
discharges storm water to a publicly owned treatment works (POTW) or to a combined sewer
(i.e., a single sewer conveying domestic wastewater and storm water) is not covered by the Phase
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I regulations. Also, a number of heavy industrial facilities have storm water discharges covered
under an existing individual NPDES permit that includes both process wastewater and storm
water controls.  EPA does not track these individual NPDES permits that contain storm water
provisions, and therefore they are excluded from the count of covered facilities in the Notice Of
Intent (NOI) database. Additionally, light industry (i.e., those facilities defined at 40 CFR
122.26(b)(14)(xi)) are required to obtain permit coverage only if the industrial activity is exposed
to storm water.  Therefore, a much smaller percentage of light industrial facilities are expected to
be covered under the Phase I program.
5.2    ANALYTICAL APPROACH

EPA's analysis of the industrial facilities provides an understanding of improvements associated
with implementing SWPPPs and activities associated with the Phase I program. The analysis
characterizes key program elements used to achieve pollutant load reductions and water quality
improvements. Where possible, the analysis projects national trends.

As discussed in Chapter 2, three indicators are used to identify program success:

•  Programmatic indicators show how permitting authorities have been able to communicate
   program requirements to permittees since promulgation of the Phase I regulations and how
   permittees have been able to effectively implement these requirements, quite often using low-
   cost solutions.

*  Loading reductions indicators show how reductions in pollutant concentrations are
   occurring in a variety of industrial sectors and how permittees are beginning to recognize the
   contributions of these permitting solutions to reductions in pollutant loadings to waters of the
   United States.

•  Water quality improvement indicators anecdotally show how the Phase I regulations can
   improve water quality and how the regulated community believes that the Phase I program
   can have positive influences on water quality.

In responding to Congress's directive to develop this Report, EPA used in-house information,
including the results of a general permit effectiveness survey performed by the Water
Environment Federation (WEF) in 1996 to characterize the program and document how the
Phase I program has been successful in establishing a framework for reducing pollutant loadings
to receiving waters.
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5.3    SPECIFIC METHODS AND RESULTS

One of the biggest challenges for EPA is to ensure that all facilities with storm water discharges
associated with industrial activity are covered by an NPDES permit. Unlike the situation for
municipalities, in which the regulations identify the MS4S that require permit coverage, either
the facility or the permitting authority (EPA or an NPDES-delegated State) must identify the
need for an NPDES permit for storm water discharges associated with an industrial activity. It is
unreasonable to expect permitting authorities to make these determinations for the more than
75,000 sites nationwide. Consequently, EPA has undertaken an extensive outreach program to
communicate the requirements of the Phase I storm water program.  Based on findings from a
recent study, this outreach effort seems to be effective.

This secfton describes the specific methods used to analyze the effectiveness of the Phase I
program for industrial activities. It also presents the results of the analyses, focusing on the three
programmatic indicators described in Chapter 2 and highlighted in Section 5.2.

5.3.1   Programmatic Indicators

This section reports on Phase I programmatic improvements based on permitting authority
information, results of a storm water general permit effectiveness survey, and case studies. This
section first provides an overview of the outreach efforts performed by EPA and NPDES-
authorized States since promulgation of the Phase I regulations. This outreach effort promotes
cost-effective and timely implementation of the regulation. This section describes how
permitting authorities have used the information gained to tailor specific requirements,
maximizing the benefits of efforts expended by permittees. Next, results of a 1996 storm water
survey are discussed, highlighting the effectiveness and acceptance of the storm water general
permitting approach based on responses from the permittees. Finally, several case studies are
presented that highlight specific efforts undertaken in response to the Phase I program.

5.3.1.1 Outreach Efforts

To assist industrial facilities in meeting the intent of the Phase I regulations, EPA has developed
and implemented a number of different outreach activities to promote compliance with program
requirements. These activities include maintaining an Internet web site specific to the storm
water program, presenting training workshops, operating an active telephone hotline, and
producing guidance documents for distribution to regulated facilities.

EPA's Office of Wastewater Management (OWM) Internet web site
(www.epa.gov/owm/sw/industrv/index.htm) provides specific storm water information for
program stakeholders. The web site guides users through the process of determining applicable
requirements of the Phase I program for industrial activities. The web site's design incorporates
all the programmatic resources necessary for a facility with storm water discharges associated
with industrial activity to identify applicable regulations and take the steps necessary to comply
with those regulations. As an example, EPA maintains a list of all threatened and endangered
species, by county, that permit applicants can access to determine if discharges from the site have
                                           5-6

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the potential to affect any of these species. Without this web site, each applicant would have to
perform an independent assessment to identify the threatened and endangered species present in
the immediate vicinity of the storm water discharge, a task that could be quite burdensome given
the number of permitted discharges.

Since 1992 EPA has conducted 28 workshops to communicate the regulatory requirements of the
Phase I storm water program. Approximately 4,000 representatives from industrial facilities, the
construction industry, and municipalities attended the workshops.

EPA's Storm Water Hotline (800-245-6510) has also played a vital role in making information
readily available to the regulated community. Since promulgation of the Phase I rule in 1990,
EPA has received and responded to well over 150,000 calls on the hotline. In the 2 years after
promulgation of the Phase I rule, EPA distributed more than 2,500 documents a month based
solely on hotline requests. To this day, the hotline continues to average more than 500 calls a
month.

5.3.1.2 Water Environment Federation  General Permit Effectiveness Survey

Arguably, one of the best ways to assess the effectiveness of an environmental program is to seek
feedback directly from the regulated community regarding the value of the requirements in
protecting the environment. Where compliance costs are high with little noticeable
environmental improvement, it is reasonable to assume that many, if not most, companies will
argue that the regulations are unnecessary, burdensome, inefficient, and so forth. Conversely,
low-cost alternatives that provide noticeable improvements to the environment are likely to be
more readily accepted by the regulated community.

Consistent with the approach described above, WEF3 published a report in October 1996 entitled
Effectiveness of Industrial Storm Water General Permitting Program (WEF, 1996).  This report,
funded through an EPA cooperative agreement, provides a summary  of industrial storm water
permittee's responses to a variety of questions related to the Phase I storm water program. The
following discussion draws from information contained in that report and demonstrates that

•  SWPPPs have been developed by industry.
   SWPPPs are not redundant requirements.
   EPA outreach materials have assisted affected facilities.
   BMPs have resulted in water quality improvements.

It was EPA's objective to increase stakeholder involvement in setting priorities for the Phase I
program by working with WEF and industry to obtain input on the effectiveness of the industrial
portion of the program. The report built on an initial project performed under the WEF/EPA
         WEF is an international not-for-profit educational and technical organization of more than 40,000 water
quality experts. Members include environmental, civil, and chemical engineers, biologists, chemists, government
officials, students, treatment plant managers and operators, laboratory analysts, and equipment manufacturers and
distributors.

                                           5-7

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cooperative agreement. The project was an avenue for Phase I industrial facilities (in States
where EPA was the permitting authority) to report to EPA on the effectiveness of SWPPPs and
to provide feedback to EPA on the program's success. The objective was expanded in 1995 to
address all  States, evaluate the Phase I program beyond the SWPPP requirements, and provide an
evaluation for the need for a "no exposure" exemption.

Data were collected through a survey instrument designed to elicit industrial permittee's
perceptions of the storm water program. The survey was prepared by a diverse work group
consisting of industrial representatives as well as State and EPA staff.  Using EPA and State
databases of facilities, WEF identified a total of 76,286 facilities covered by storm water general
permits.4 WEF determined that mailing the questionnaire to  10 percent of these facilities would
provide statistically useful results even if only 5 percent of the surveys were returned.  With that
in mind,^WEF distributed 7,500 questionnaires to  a stratified random sample of facilities.

The questionnaires were mailed in January 1996 with responses due back to WEF in February
Table 5-2.  Makeup of WEF Survey  Respondents
 Types of Industries
     44.4% heavy industry (categories (i) through (ix) in 40 CFR 122.26{bX14))
     31.5% light industry (category (xi) facilities)
     1 0. 1 % miscellaneous (SIC codes that are not in any of the categories identified in 40 CFR 1 22.26(bX 1 4))
     14.0% that WEF could not differentiate (no SIC code specified in the response)

 Facility Size Designation
     36.3% small business
     5 1 .8% not a small business
     1 1 .9% uncertain

 Ranee of the Number of Employees at Facilities
     0 employees (1.7%)
     1-25 employees (36.6%)
     26-100 employees (27.8%)
     > 1 00 employees (33. 9%)

 Size of Facilities
     <1 acre (3. 8%)
     I -5 acres (32.2%)
     5-25 acres (34.4%)
     >26 acres (29.6%)

 Annual Average Rainfall
     0- 10 inches (14.4%)
     11 -20 inches (26. 8%)
     2 1 -20 inches (21. 4%)
     >40 inches f 16.9%)

 Source: WEF, 1996.
       4 No data were available for Vermont and West Virginia; two other States, Minnesota and Kansas, chose
not to participate.

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1996.  WEF received 584 completed responses (an 8.2 percent response rate with a confidence
level of ±4.04 percent). Responses were from industries representing 237 different four-digit
SIC codes.  A breakdown of the respondents is provided in Table 5-2.3  One of the key
indicators of facility makeup was to differentiate between small and large businesses as a way to
evaluate  the differential burden of program compliance. The discussion that follows highlights
any meaningful differences (or similarities) for small and large facilities.

Implementation Status

WEF assessed the degrees of program implementation based on a number of survey questions.
One of the most important questions asked whether the facility had  developed a SWPPP.
Presumably, facilities that had developed a SWPPP would be better able to assess the
effectiveness of the program as well as the costs associated with implementation of program
requirements. Of the total respondents, 17.4 percent stated that a SWPPP had not been
developed, with another 3.9 percent uncertain if the facility had a SWPPP. Small business
respondents were less likely to have prepared a SWPPP (23 percent) or to know if they had a
plan (7.2 percent).6 The WEF report surmises that small businesses tend not to understand the
regulatory requirements as well as larger businesses.

WEF found that most firms that failed to prepare SWPPPs, irrespective of size, were confused by
the program requirements.

The remainder of the analysis focused on facilities that had prepared a SWPPP.  Of these
industrial respondents, the vast majority (67 percent) indicated that  the Phase I rule was the first
regulation that affected storm water discharge from their facility.

To reduce program development costs, EPA has made significant efforts to provide permittees
with as much guidance as possible. Therefore, one issue of concern was whether these outreach
efforts had proven successful. The analysis found that approximately 70 percent of the facilities
were able to  prepare the SWPPP using internal resources; that is, only 30 percent used an
external consultant to prepare the plan.  For facilities that prepared their own SWPPP, 71.3
percent used government  guidance only (EPA and/or State). Costs for plan preparation varied,
with an overall average cost of $7,606 and a small business average cost of $4,341.
       5WEF did not attempt to identify why certain facilities had submitted NOIs for coverage (and had returned
the WEF questionnaire) even though the facility's SIC code was not in one of the covered sectors. Rather, the
assumption was made that for one reason or another, since these facilities had submitted an NOI, they were covered
under the Phase I program and would have valuable information to contribute. Therefore, all responses were
retained and evaluated.
       6The Phase I storm water regulations require all facilities submitting an NOI to have a SWPPP in place
prior to submission of the NOL Under the Phase I rule, certain classes of industrial activities can eliminate coverage
under the storm water program by eliminating storm water discharges associated with industrial activities (i.e.,
eliminating exposure).

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                                       BMP Effectiveness
                                        Best Management Practice
                             I Highly Effeclive • Modtratcly EffeclM DNol Effective q Not Applicable |
Figure 5-2. Rating of BMP Effectiveness as Reported in the WEF Survey
SWPPP Components Found to Be Effective in Controlling Storm Water

As discussed in Section 5.1.2, one of the key components of facility SWPPPs is BMPs. The
WEF survey sought to assess the level of effectiveness of different combinations of BMPs.
Permittees were asked to label each BMP as highly effective, moderately effective, not effective,
or not applicable. The list of BMPs provided in the survey questionnaire matched the SWPPP
requirements identified in the Phase I rule.  A histogram showing how permittees evaluated each
BMP is provided in Figure 5-2.
As shown in Figure 5-2, the BMPs considered by at least 75 percent of the respondents to be
applicable and highly or moderately effective are

•   Good housekeeping
•   Visual inspections
•   Employee training
•   Spill prevention and response
.•   Preventative maintenance.
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Other BMPs considered to be highly or moderately effective by at least 50 percent of the
respondents included the annual site compliance evaluation, site mapping, and sediment and
erosion control.

Not all BMPs were found to be applicable to any given site. For example, elimination of
industrial source discharges was found to be highly or moderately effective by fewer than 50
percent of the respondents, but of the respondents that found the technique to be applicable to
their site, more than 85 percent found it to be a highly or moderately effective technique.
Similarly, sediment and erosion control and physical facility modifications were found to be
highly or moderately effective for a majority of facilities for which these BMPs were applicable.

BMPs found not to be effective included raw material and product substitution and record
keeping and reporting.  As indicated in the WEF report,  "clearly the one perceived to be the least
effective was record keeping and reporting." In fact, more than 53 percent of the respondents
who identified this as an applicable BMP found it not to be effective.

Cost of Complying with the Regulations

The WEF survey sought to establish costs for complying with the provisions of the storm water
program. The survey identified three major cost components: SWPPP development, capital
improvements, and annual operation. WEF designed its survey to collect costs in stated ranges.

SWPPP costs ranged from less than $1,000 to more than $100,000, with the average cost being
about $7,500.  More than 67 percent of the facilities spent less than $5,000 on plan development;
81 percent spent less than $10,000 developing the plan.

WEF found that approximately 39 percent of facilities had to expend resources for capital
improvements to meet the regulatory requirements. The primary capital improvements identified
were covered structures/improved storage (23.1 percent); ponds and other containment structures
(19.3  percent); improved drainage, grading, and erosion control (18.5 percent); and berms, dikes,
and diversion runoff (14.7 percent). WEF reported a trimodal distribution of costs with 33.7
percent of the facilities spending less than $5,000,45.4 percent spending between $5,000 and
$50,000, and 20.7 percent spending more than $50,000.  Even though 80 percent of the facilities
spent less than $50,000, the average cost was $89,030, which was heavily influenced by a
number of facilities that had spent more than $100,000 on capital improvements (with an average
cost of that group of more than $600,000 per facility). The median cost of capital improvements
was just over $10,000 per facility.

For annual operating expenses, the average cost is $4,105, although the majority (69.5 percent)
incurred annual costs of less than 52,500. The median annual cost was slightly more than
SI,000.

To more fully  understand the cost-effectiveness, WEF requested respondents to identify the three
most cost-effective activities the facility had implemented and the three least cost effective
measures. The two most common responses for most effective were good housekeeping and
                                          5-11

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employee training, which were selected over 50 percent more frequently than the next two
responses. The next two responses were structural controls, consisting of ponds and other
containment structures, and improvement of storage, including installation of covered storage
facilities.

By far, the least cost-effective measure reported was monitoring or sampling and analysis. Based
on responses, WEF surmised that the costs associated with monitoring might be considered too
high or the data generated from monitoring are considered of little value in effectively reducing
storm water pollution. Not one respondent identified monitoring or sampling and analysis as one
of the top three most effective measures. The next two most common least cost-effective
measures, record keeping and reporting and plans/mapping, also were not identified as one of the
three most effective measures by any respondent.

WEF asked respondents to identify those aspects of the SWPPP the facility would continue to
implement even if the storm water regulations  no longer existed.  Almost 43 percent of the
respondents indicated that they would retain the plan in it entirety, with 52.3 percent saying that
they would retain some of it.  Less than 5 percent indicated that they would not retain any aspect
of the SWPPP in the absence of regulatory requirements.  Similar to the question on
effectiveness of specific BMPs, when asked which components of the SWPPP would be retained,
the three overwhelmingly most common answers were good housekeeping, training, and
inspections. Spill prevention and response, and preventative maintenance were the next two
most common responses.  Again, not one facility identified monitoring, or sampling and analysis
as one of the measures that would be continued.
Finally, WEF asked respondents to identify the reasons that the facility would continue to
implement the SWPPP even if the
regulations did not exist. Approximately 80
percent of the respondents indicated that
they would retain the plan requirements
because of the environmental benefit, 59
percent because it was a corporate policy,
46 percent because it was required by other
regulations, 24 percent because of the
economic benefits,  and 2.2. percent because
of the public relations benefit.
         WEF Study Conclusions

Most respondents believe that BMP implementation
has led to water quality improvement.

More than 95 percent of the respondents determined
that good housekeeping was effective.
The WEF study indicates that industrial
facilities generally acknowledge the
benefits associated with SWPPPs and
BMPs. Indeed, as noted above, almost 43
percent of respondents reported they would
.retain the SWPPP in its entirety in the
absence of regulatory requirements.  Certain
actions, particularly low-cost actions that
could be characterized as good business
Preventative maintenance, elimination of sources,
visual inspections, sediment and erosion control,
spill prevention and response, and employee training
were also rated as successful.
More than 60 percent of the respondents felt that the
potential improvements in water quality might be
worth the corresponding expenditures.

More than 90 percent of the respondents indicated
that they would continue to implement at least some
parts  of their SWPPP even if the Phase I
requirements were removed.
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practices, were well received. Other requirements, particularly monitoring and record
keeping/reporting, were not highly valued by the respondents.

5.3.1.3 Case Studies

A number of case studies are presented here that describe the types of programmatic activities
one State and several industrial facilities have undertaken to comply with the Phase I program.
The case studies illustrate how some facilities in different industrial sectors have taken advantage
of the flexibility of the program by using a variety of approaches to comply. Complete case
studies are provided in Appendix D.

Connecticut's Use of Phase I Monitoring Data Assists in Program Implementation

The Connecticut Department of Environmental Protection (DEP) currently regulates
approximately 1,200 facilities under its General Permit for the Discharge of Stormwater from
Industrial Facilities.  Part of the general permit requirements include annual monitoring for 11
water quality parameters, including whole effluent toxicity.  As described below, the State has
found the Phase I storm water monitoring data to be essential to the efficient operation of the
State's program.

The State general permit establishes performance  criteria that represents the 80* percentile of
statewide storm water quality from industrial facilities for each monitored parameter (derived
from storm water discharge data collected from the first general permit issued by the State).
These criteria are not enforceable limitations, but are used as a means of identifying storm water
discharges that are significantly more contaminated than that discharged by most facilities
regulated under the general permit. The performance criteria are specifically used by the State to
provide flexibility for regulated facilities. Facilities that meet the criteria for all monitoring
parameters for two consecutive years are exempt from monitoring for the remainder of the permit
term.

The State has been collecting and analyzing storm water data for the past four years (1996-99).
DEP prepares and distributes annual reports for the regulated facilities that summarizes all the
monitoring data submitted to the State. According to DEP, the annual summary  allows each
facility to see where they stand in comparison to others, and many facilities have been found to
improve storm water quality without prodding from DEP. DEP also uses the collected storm
water data to more focus compliance activities. In particular, DEP lists those facilities that report
highly contaminated storm water.  By focusing on those with the greatest potential to impact
water quality, DEP feels that the return on its limited resources is maximized and a higher rate of
overall compliance is ultimately achieved.

DEP has also used the storm water monitoring data to  assess technical assistance and research
needs related to storm water controls.  For example, the State discovered that marinas are much
more likely to discharge storm water that is toxic to aquatic life than other types  of facilities in
the transportation category. As a result,  DEP designated marinas as a priority problem, which is
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being addressed through a cooperative agreement with the Connecticut Marine Trades
Association to perform research to identify the cause of the degraded storm water quality.

Ciba Specialty Chemicals, Newport, Delaware, Saves Money by Capturing and Reusing Storm
Water

This case study shows how one industrial facility used the program's flexibility to arrive at an
innovative solution to control its contaminated storm water discharge. Ciba Specialty Chemicals
is a specialty chemical manufacturer that was identified as having a zinc-laden toxic dry weather
discharge to the receiving water as the result of infiltration at the site.  Also, high levels of
suspended  solids were found to run off the site during storm events. Before the Phase I
regulations, the facility collected contaminated ground water and pumped the water to the
municipality for treatment. Storm water ran off the site directly to the river. Through
installation of an on-site storm water collection network, Ciba Specialty Chemicals has been able
to meet the SWPPP requirements of the Phase I program while at the same time eliminating the
toxicity and reducing levels of suspended solids in the discharge.  The facility's solution was to
collect the  first flush of storm water from the site and use the water for on-site cooling. In
addition to the control of storm water discharges, Ciba's stonn water collection system also
captures spills, preventing discharge to the river. As a result, analytical testing of storm water
discharges  now shows zero percent mortality of aquatic species.  In addition, the facility has
saved money both from the reduction in the purchase of cooling water and from reduction in
annual maintenance costs associated with the previously contaminated ground water.

Doggett Auto Parts, Bryan, Texas, Receives National Recognition for Aggressively Implementing
Its Best Management Practices

This case study is an example of the positive effect that compliance with the Phase I program can
have on a business. Doggett Auto Parts is a full-service auto recycling facility that stores 1,000
cars on-site arid dismantles about 20 vehicles a month. In response to the Phase I regulations, the
facility developed a SWPPP in 1994 and, through aggressive implementation, was approved as a
Certified: Automotive Recycler by the Automotive Recyclers Associations, becoming one of the
first facilities in the Nation to achieve this status. (Doggett was also one of the first facilities in
the country to achieve Gold Seal Quality Program status, a distinguished recognition for facilities
with honest, reputable,  quality business practices throughout the automotive recycling  industry
for the direct benefit of customers.) Employing fewer than 10 employees, Doggett trained its
entire staff on the requirements of the Phase I program and then worked to identify solutions to
eliminate storm water contamination from its facility.  Some of the simple solutions incorporated
into the facility's SWPPP included draining of all fluids from vehicles and reusing the fluids
where possible, providing secondary containment around storage tanks, storing parts that had
previously contained any automotive fluids indoors  to prevent contact with storm water, and
storing vehicles off the ground on wheel stands to allow for easy inspection of possible leaks
.under the cars. As a result of Doggett's aggressive plan for complying with the Phase  I program,
each of its  employees is now aware of the environmental benefit of the program.
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5.3.2   Loading Reductions

As noted previously, one of the key indicators of water quality benefits attributable to the Phase I
program is preventing pollutants from being released to the environment.  Water quality
improvement occurs when industrial facilities employ practices that prevent or minimize contact
of storm water with industrial activities and hence minimize the amount of pollutants carried off
the site with the runoff and into receiving waters. This section describes how the Phase I
program has reduced loadings of pollutants, highlighting this accomplishment through the use of
storm water monitoring data, BMP effectiveness summaries, and case studies.

5.3.2.1 Storm Water Monitoring Data

The analysis of monitoring data from industrial sources presented below does not attempt to
quantify nationwide estimates of loading reductions.  Data on quantities of industrial pollutant
discharges are insufficient to perform that type of analysis. Most notably, few data exist on the
volume of storm water runoff from the diverse universe of industrial sources.  Rather, the focus
of this analysis will be on the reductions in concentrations (i.e., removal efficiency) that can be
achieved at individual facilities, comparing storm water monitoring data submitted prior to Phase
I permit requirements (i.e., group application monitoring data from 1991-92) with data submitted
subsequent to Phase I permit requirements (i.e., discharge monitoring report data from
1994-present). The analysis suggests that, by and large, industry sectors experienced significant
reductions in pollutant mean concentrations.

Use of Group Applications to Derive Pre~Phase I Program Pollutant Concentrations

The Phase I regulations originally established a two-part group application procedure to obtain
coverage under the Phase I program.  More than 1,200 groups and  60,000 member facilities
(from all 50 States,  Washington, DC, and many of the U.S. Territories) submitted part 1
applications.  Of these applicants, EPA approved 700 groups and 44,000 members.7

The Phase I regulations required a set percentage of the group members to submit monitoring
data in the part 2 applications (see Table 5-3). In addition to certain site-specific pollutants, all
facilities submitting data were required to monitor for eight conventional pollutants: pH, 5-day
biochemical oxygen demand, chemical oxygen demand, total suspended solids, oil and grease,
total phosphorus, total Kjeldahl nitrogen, and nitrate plus nitrite nitrogen. Part 2 applications
were a one-time option available for storm water discharges associated with industrial activity
and were due to EPA by October 1,1992. These data therefore represent the nature of storm
water discharges before regulatory permit controls. EPA has compiled summaries of these part 2
group application monitoring data in several documents, most notably in the 1995 MSGP (60 FR
50804, September 29, 1995) and in the March 1995 Storm Water Discharges Potentially
       7 EPA also issued a Baseline Industrial General Permit that provided another permitting option, although
since that time EPA has merged the group and General Permit applications into a single permitting option, the
Multi-Sector General Permit.

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                                            Table 5-3. Part 2 Group Application Requirements
                                            (40 CFR 122.26(c)(2)(I)(D))
                                              Size of Group


                                              > 1,000 members

                                              100-999 members

                                              21-99 members

                                              4-20 members
No. Required to
Monitor

si00 members

i 10% of members

a 10 members

s50% of members
Addressed by Phase II of the National
Pollutant Discharge Elimination System
Storm Water Program (USEPA, 1995).  In
both of those documents, EPA presented
the data on a sector-specific basis. The
sector approach has been used because, as
has been discussed, the framework of
EPA's current Phase I program is that the
regulations are uniformly applied on a
sector-specific basis (i.e., the MSGP).

A brief summary of the group applications
and the intent of the data collection effort
highlights the significance of the group
application monitoring data. The Phase I
group application option enabled EPA to
gather the information necessary for
issuing permits for certain classes of storm
water discharges  associated with industrial
activities. At the same time, this approach
reduced the costs and administrative
burdens associated with preparing permit    	
applications and developing permits.8

The group application regulations required that monitoring data must be (1) representative of the
members' discharges, (2) from a storm event greater than 0.1 inch, and (3) taken from a storm
event that occurred at least 72 hours after a previously measurable storm event.  Also, grab
samples were to be collected during the first 30 minutes of the discharge.  The regulations
provided that when a facility had two or more substantially identical effluents,9 the permittee had
to sample only one of these outfalls and report that the data apply to the other outfalls.

Use of Discharge Monitoring Reports to  Derive Post-Phase I Pollutant Concentrations

The NPDES  regulations, at 40 CFR 122.41(i)(4), specify monitoring report requirements that
must be included in all NPDES permits.  This section specifies that monitoring results are to be
reported on a Discharge Monitoring Report (DMR).  EPA and many NPDES-authorized States
have developed and implemented DMR forms to be used by permittees for reporting analytical
monitoring results. The storm water MSGP does not require all covered facilities to submit
                                            For groups with >10 members: at least two dischargers
                                            must monitor from each of the nine precipitation zones
                                            nationwide for any zone with at least 10 members or one
                                            discharger from each zone with fewer than 10 members.*
                                            For groups with £ 10 members: at least one discharger
                                            must monitor from each of the nine precipitation zones
                                            nationwide.*

                                            * Applies to each precipitation zone represented by the
                                            group.
       8 EPA recommended that NPDES-authorized States adopt the permits prepared by the Agency. Many
States have, in fact, adopted EPA's MSGP or a permit similar in intent, form, and content, with specific State
concerns added as appropriate.

       9 EPA defined the term "substantially identical effluents" in NPDES Storm Water Sampling Guidance
Document (EPA 800/B-92-001).
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DMRs. Appendix I contains a list of the
19 industrial sectors (and appropriate
subsectors) with analytical monitoring
requirements under the MSGP.  EPA set
monitoring requirements for these sectors
based on an analysis of group application
data and the  identification of sectors and
subsectors that were shown to have the
potential to discharge pollutants above
EPA-established benchmark
concentrations.10 Sectors and subsectors
required to monitor must submit DMRs
to the permitting authority.  As indicated
in Appendix I, the parameters to be
monitored vary for each sector and
subsector but are limited to the nine
pollutants referenced in Figure 5-3.  As in
the group application process, grab
samples are to be collected during the
first 30 minutes of discharge.

As noted previously, EPA is the
permitting authority for seven States and
all territories (except the Virgin Islands).
In developing the MSGP, EPA
recommended that NPDES-authorized
States adopt a permit similar to EPA's. To date, all of the authorized States have adopted some
type of general permit program for storm water discharges associated with industrial activity,
with a significant number of the States having implemented a Multi-Sector permit similar or
identical to that issued by EPA. As a result, the monitoring requirements highlighted above are
similar across the country.  With that in mind, and given the short time frame for preparing this
Report, EPA opted to use DMR data from States for which EPA is the permitting authority and
not attempt to collect data from other States.

For this Report, EPA compiled DMRs for 399 facilities from eight States and two territories,
representing 24 of the 30 industrial sectors and five of the nine precipitation zones nationwide.11
 * BOD and phosphorus monitoring is required of two subsectors  '••
   each and magnesium, cadmium, cyanide, mercury, selenium,   ;
   silver, manganese and pH monitoring is required of one        ,
   subsector each.                                     |

Figure 5-3. Parameters Required to Be Monitored in the
MSGP and the Number of Subsectors Required to Monitor
for Each Parameter*
        IOEPA established benchmark concentrations that represent levels at which storm water discharge could
potentially impair or could contribute to impairing water quality, or could affect human health from ingestion of
water or fish. Facilities with less than benchmark concentrations are considered to have little potential for water
quality impacts. Benchmark concentrations are not effluent limits, and EPA has instructed NPDES-authorized
States that the benchmarks should not be interpreted or adopted as such.

        1' DMRs collected for Arizona, Florida, Johnston Atoll (Federal facilities only), Hawaii (Federal facilities
only), Maine, Massachusetts, New Hampshire, New Mexico, Puerto Rico, and Texas. Florida and Texas have since
received NPDES program authorization.
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 These data represent monitoring performed from 1993 to 1999, with 90 percent of the monitoring
 performed between 1996 and 1998. Of the six sectors not represented, five do not have
 analytical monitoring requirements in the MSGP and the sixth, sector K, Hazardous Waste
 Treatment and Disposal, is the one category with monitoring requirements for which EPA did
 not have DMR data available for this Report.

 Group Application/DMR Comparative Analysis

 As described above, EPA has collected a significant amount of effluent quality data for facilities
 with storm water discharges associated with industrial activity. For both the group application
 process and DMR requirements, similar sampling criteria and analytical monitoring techniques
 were used, making data from these two sources comparable. Although the best-case scenario
 would involve comparing data for identical facilities before Phase I regulation (i.e., group
 applications) and after Phase I implementation (i.e., DMRs), the short time frame allotted for
 preparation of this Report prevented the more detailed data collection effort needed for such an
 analysis. Rather, as had been done for the group applications, DMR data were grouped by
 parameter and subsector for comparison. Also, the analysis that follows is not intended to
 provide a definitive statistical analysis of data, but rather to provide indications of the trends of
 program implementation.  As shown below, trends emerge.

 As presented in the fact sheet of the MSGP, group application data were compiled and simple
 statistics performed on the data. Specifically, for each subsector, statistics included means,
 medians, maximums, minimums, and 95th and 99* percentiles. For this Report, EPA focused on
 the two most common approaches for evaluating environmental data—means and medians. EPA
 used mean and median concentrations of data submitted in group applications and compared
 those to mean and median concentrations of data submitted in DMRs. The analysis was
 performed on a subsector basis for each of the 33 sector/subsector combinations (see Appendix I)
 that are required to perform analytical monitoring as a condition of the MSGP.  Of these 33
 combinations, EPA analyzed data for  16 of the subsectors, those being the subsectors for which
 EPA had ample DMR data to compare. The criteria used to designate "ample data" were (1) any
 subsectors for which EPA had at least three facilities with DMR and three facilities with group
 application data for at least one pollutant, and (2) those subsectors with DMRs for two facilities
 where the MSGP had data for five or fewer facilities. A compilation of all the
 subsector/pollutant combinations with ample data is provided in Appendix J.  For each of these
 combinations (a total of 35 combinations), Appendix J identifies the pollutant, the number of
 facilities with group application and with DMR monitoring data, the number of grab samples
 collected for both group application and DMR monitoring data, the mean and median
 concentrations, and the percent change in mean and median concentrations from the group
 application data to the DMR data.

 Appendix K provides a ranking of the mean differences in pollutant concentrations for each of
.the subsector/pollutant  combinations.  As presented, 24 of the 35 combinations had at least 50
 percent lower mean concentrations in  the DMR data than in the group application data.
 Similarly, as noted in Appendix K, 24 of the 35 combinations had at least 50 percent lower
 median concentrations, with 18 of the combinations over 75 percent lower. For analyses such as
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this, median concentrations are better indicators since they are less vulnerable to the impact of
outliers or extraneous data points. With the evaluation focusing on comparing data for industry
subsectors rather than comparing data for the same facility, median concentrations also minimize
the influence that extremely high or low concentrations may have on the analytical results.
In addition to the analysis of each
subsector/pollutant combination,
EPA analyzed the differences in
concentrations of each pollutant (see
Appendix!). A summary of that
analysis is presented in Figure 5-4.
As can be seen, differences in
pollutant concentrations ranged from
13 to 95 percent, with five of seven
pollutants showing a DMR
concentration greater than 50
percent lower than the pre-program
group application data. Again, even
though this analysis represents
sector-based comparisons and is not
comparing pre- and post-regulation
data for the same facilities,  the
difference in concentrations suggests
that loading reductions are
occurring.  Although influences
other than the Phase I regulation
may be partly responsible for these
reductions, no other environmental legislation or regulation enacted or promulgated since 1992 at
the Federal level has established such direct requirements for storm water associated with
industrial activities.

5.3.2.2 Case Studies on BMP Effectiveness

This section provides several examples of facilities that have demonstrated the reduction of
pollutant loadings to receiving water through implementation of storm water controls in response
to the Phase I regulations. As noted throughout this Report, EPA has minimal data that
demonstrate clear improvements in water quality as a result of the Phase I program. However,
EPA does have examples illustrating where the Phase I program is reducing the contribution of
pollutants to waters of the United States.  The following case studies demonstrate a few of these
instances.  Complete case studies are provided in Appendix D.

.Empire Castings. Tulsa, Oklahoma, Reduces Solids Loadings by 90 Percent

This case study illustrates the pollutant reductions that can be obtained from compliance with the
Phase  I regulation.  Empire Castings is an iron foundry that uses sand molds for its castings.
Figure 5-4. Median Reductions in Pollutant Concentrations by
Pollutant
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Empire Castings worked with EPA Region 6 and the Oklahoma Department of Environmental
Quality (DEQ) to participate in an innovative and voluntary program designed to help foundries
comply with State and Federal regulations. Although the effort focused on all environmental
regulations, storm water discharges was one of the areas evaluated. Effluent sampling data,
collected in October 1992 as a requirement of the Phase I regulation, identified elevated levels
(i.e., 1,800 mg/L) of total suspended solids (TSS) in Empire Castings' storm water discharge.  In
consultation with local foundries, EPA, and DEQ, the facility identified and implemented several
BMPs to minimize the discharge of pollutants.  Some of the simple measures identified included
improved housekeeping such as vacuuming up residual sand more frequently, addition of a
filtering system (mesh-covered hay bales), and addition of a storm water retention basin to allow
solids to settle from the storm water prior to discharge. These and other similar measures have
reduced concentrations of TSS in the storm water discharge by 90 percent.

When asked about the cost-effectiveness of these measures, facility management indicated that it
is difficult to put a price on environmental benefits, but they believe the program has been cost-
effective  in terms of direct benefits (reduced pollutants in storm water discharges) and indirect
benefits (increased production rates due to housekeeping changes) achieved.

Pratt Auto Salvage and Sales, Hoxie, Arkansas. Implements Measures to Eliminate All
Pollutants in Storm Water Discharges

This case study demonstrates the ability of a facility to totally eliminate storm water
contaminants without a negative impact on business operations. Although one of the goals of the
CWA is "zero discharge of pollutants," the efforts of facilities to completely eliminate process
wastewater discharges can require expensive control technologies and process modifications.
Storm water discharges, however, are not a necessary element of process operations, and in many
instances they can be totally eliminated. Pratt Auto Salvage and Sales of Hoxie, Arkansas, has
shown that industries can implement measures under the Phase I program to achieve the goals of
the CWA.  The facility engages  in the wholesale distribution of motor vehicle supplies in
addition to processing 100 used  or damaged vehicles each month. It is located on a 20-acre site
adjacent to an elementary school and an apartment complex.

To comply with its storm water  discharge permit, issued pursuant to the Phase I regulations, Pratt
Auto Salvage implemented a number of management practices to eliminate any contact of storm
water with contaminated automotive fluids. One of the significant steps taken was to drain all
fluids from vehicles in a covered building with a  cement floor and recover the fluids for off-site
recycling or disposal. Vehicles  are then dismantled, with saleable parts removed and the rest of
the vehicles placed outside in the yard for crushing. The  15-acre yard is covered with rocks and
gravel and shows no signs of the oil or rust stains typically expected from salvage yards.

Hoechst Celanese, Coventry. Rhode Island, Addresses Significant Storm Water Issues as a Result
of the Phase I Program

A January, 1995 inspection by the Rhode Island Department of Environmental Management
(DEM) of Hoechst Celanese (HC) located in Coventry, Rhode Island found that the facility had
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numerous unsecured barrels located adjacent to the river, barrels actually floating in the river,
and visual evidence of spills around the barrels and elsewhere on the facility property.
Additionally, the inspector noted broken sandbags along the riverbank, litter in the channelized
brook on the site, and eroded point source discharge points.  At the time of the inspection, HC
was operating under an administratively extended permit that did not include any of the Phase I
requirements.  In response to this inspection, DEM compiled a list of activities for HC to
undertake as part of the facility's application for permit reissuance.  As a result of a letter from
DEM to the facility in April 1995, HC developed and submitted a SWPPP to DEM in July 1995
to address the State's concerns.  Although HC is  not required by law to implement its SWPPP
until it has been incorporated into the NPDES permit, the facility realized the importance of
minimizing pollutant contamination of storm  water discharges and began to implement the plan
before the permit was reissued.  In fact, the majority of the facility has since been sold to a new
manufacturer and indications from current facility management are that the SWPPP is being
implemented.

Measures undertaken by HC to address DEM's concerns included a number of good
housekeeping practices such as improved pallet management techniques and loading/unloading
techniques to prevent future spills/staining and to prevent any barrels from reaching the river.
Also, HC developed an employee training program that, consistent with the Phase I
requirements, addressed housekeeping, material handling, spill prevention and response, and
routine inspections.

5.3.3   Water Quality Indicators
                                                   Only 6.3 percent of WEF survey respondents
                                                   with SWPPPs who performed water quality
                                                   monitoring did not think that the SWPPP
                                                   implementation had improved water quality.
Although the Phase I program has resulted in
loading reductions on a facility-specific basis, as
demonstrated above, the Agency does not possess
firm quantitative data indicating how such
reductions have resulted in water quality
improvements. The WEF survey,  however,
provides evidence that implementation of the Phase I program has benefitted water quality — at
least in the opinion of survey respondents.

The survey asked respondents whether water quality monitoring and analysis had been
performed on the storm water runoff from the facility and, if so, in the opinion of the survey
respondent, were the BMPs incorporated into the SWPPP successful? More than half of the
respondents (56.7 percent) indicated that water quality monitoring had been performed, with 56.9
percent of those respondents believing that BMPs were successful in improving water quality.
Only 6.3 percent stated that BMPs were not successful (36.9 percent stated that data were
inconclusive or not enough data had been collected to make the determination).

.WEF also tried to assess just how  much survey respondents felt that SWPPPs and improved
water quality or reduced storm water contaminants.  Figure 5-5 provides a summary of those
responses.  The responses to this question can be interpreted in two different ways: 68 percent
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believe that there is at least some improvement in water quality or 65.8 percent believe that there
is little or no improvement.
The WEF report refined this analysis by
assessing the opinions of those facilities
that had collected the data to reinforce
their impressions of water quality
improvements. In this instance, 74.4
percent of the facilities responded that
there had been at least some improvement
in water quality or reduction in pollutant
loadings.
                                                                     Source: WEF, 1996.
When asked whether the improvement or
potential improvements in water quality
were worth the corresponding
expenditures, the amount of money       ^	 -~ •_	^  j-^,™^	^rr~I—^—7^T~
      .  ,    .           u j r.*i  •     f Figure 5-5. Impact of SWPPPs on Water Quality
expended on the program had little impact   *           r                        ^     J
on the respondents' answers.  The  number
of respondents that reported that water quality improvements were worth the costs was almost
identical to the number of respondents reporting that water quality improvements were not worth
the cost.

5.4    FINDINGS OF THE REVIEW OF THE PHASE I PROGRAM FOR STORM
       WATER ASSOCIATED  WITH INDUSTRIAL ACTIVITIES
This section summarizes findings from EPA's
review and analysis of the Phase I program for
discharges of storm water associated with
industrial activities. First, successful components
of the Phase I program are identified, particularly
as they relate to the protection of water quality.	
Second, the components of the Phase I program
that may need to be addressed by EPA are discussed to ensure they are an effective part of future
storm water management programs.
                                               The three WEF survey respondents with the
                                               highest expenditures on the program (each in
                                               excess of S1 million) all felt that the
                                               improvement in water quality was worth the
                                               expenditure.
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5.4.1   Successful Attributes of the Phase I Program for Industrial Activities

This section describes the specific storm water management components that have been effective
in controlling storm water discharges and protecting water quality.

The Phase I Program Provides a Sensible. Flexible, Low-Cost Approach to Storm Water
Control

As documented in the WEF report, more than 95 percent of permittees said they would retain at
least some of the required SWPPP even if the storm water regulations did not exist, with almost
43 percent saying that they would retain the plan in its entirety. Seventy-five percent of the WEF
survey respondents indicated the following BMPs as being either highly or moderately effective:

•  Good housekeeping
•  Visual inspections
•  Employee training
*  Spill prevention and response
•  Preventative maintenance.

Consistent with this finding, the general permitting option provides flexibility to the permittees
on how to comply with the regulations, with the focus on low-cost pollution prevention
techniques rather than more costly treatment alternatives. Similarly, EPA provides permittees
with the option of using existing management plans developed- for other environmental programs
to supplement  its storm water management plan or in lieu of developing a redundant plan for
storm water control.

Loading Reductions Result From Phase I Permitting of Industrial Storm Water Discharges

In 1992 analytical data collected from Empire Castings, an iron foundry in Tulsa, Oklahoma,
identified elevated levels of total suspended solids (TSS) in storm water discharges from the
facility. In response, Empire Castings implemented several BMPs to minimize the discharge of
pollutants, such as improved housekeeping, addition of a filtering system, and construction of a
storm water retention basin to promote settling. As a result, the facility has reduced
concentrations of total suspended solids in storm water discharges by 90 percent.

Water Quality Improvements Have Been Realized as a Result of Phase I Implementation

Based on findings from WEF survey respondents, 74 percent of industrial operators who had
collected data as part of their SWPPP implementation indicated that there has been at least some
improvement in water quality. Approximately half of the respondents to the WEF survey believe
that the water quality improvements were worth the cost of the program. In fact, the three survey
respondents with the highest expenditures on the program (each in excess of $1 million) all felt
that the improvements to water quality were worth the expenditures.
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EPA Outreach Has Facilitated Compliance

As indicated by the WEF survey respondents, more than 71 percent of the permittees prepared
storm water pollution prevention plans using government-developed guidance materials. EPA
has distributed guidance through an active outreach program incorporating a storm water hotline,
training courses, guidance manuals, and the Internet. As noted in the WEF report, "it appears
that both EPA and the States have done an excellent job in providing the necessary assistance to
prepare a storm water management plan." As shown in the report, permittees using government-
developed guidance were able to prepare these management plans at a lower cost than facilities
that used other guidance materials.

"No-Exposure" Pot-Out Has Provided Flexibility

Additionally, as originally promulgated, the Phase I program provides light industry with an
opportunity to opt out of program requirements altogether by eliminating exposure of industrial
activity to storm water, thereby attaining the ultimate goal of the CWA of "zero discharge of
pollutants" for those facilities selecting that option. The Phase II program expands upon this
successful measure by providing heavy industry with a similar opportunity to opt out of the
program by successfully eliminating exposure of industrial activity to storm water.

5.4.2  Components of the Phase I Program That May Need to Be Addressed

While collecting and analyzing information related to the effects of the Phase I program, EPA
identified several components that might not be effective as currently established and
implemented. Key aspects of the industrial storm water program that may need additional
refinement include the following:

•  The requirements of EPA's general permit for industrial facilities specify analytical
   monitoring for certain industrial sectors. The purpose of the monitoring is to provide facility
   operators with the necessary information to determine the effectiveness of their SWPPPs in
   controlling the discharge of pollutants in storm water. EPA has received feedback from
   industry representatives that the costs associated with analytical monitoring are too high, and
   that the data generated are not useful in determining the effectiveness of their SWPPPs.

   Agency Response: EPA is considering alternatives to the analytical monitoring requirements
   in EPA's general permit for storm water discharges associated with industrial activity, and
   will request public comment on alternatives to analytical monitoring requirements during
   proposal. The Federal Register notice for the proposed MSGP is expected in February 2000.

•  Respondents to the WEF survey identified the following BMP measures as ineffective in
   controlling the discharge of pollutants in storm water:

   •   Record keeping and reporting
   •   Raw material and product substitution
   •   Site mapping.
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Agency Response: While some respondents to the WEF survey did not feel the above
measures are effective in controlling the discharge of pollutants in storm water, EPA feels
they are important components of a comprehensive and effective SWPPP. Developing a
facility site map, for instance, although not directly effective in controlling the discharge of
pollutants, can be a very simple and effective exercise that provides an operator with a better
understanding of the potential sources of pollutants exposed to storm water. The site map
also provides the operator with a better understanding of the drainage areas from their
facility, which should facilitate assessment of necessary controls.  Accurate record keeping
and reporting is essential to track compliance with SWPPP implementation requirements, as
well as assist in anticipating areas of concern for storm water contamination (e.g., tracking
the types and amounts of materials stored at the facility).  However, EPA will explore ways
to streamline record keeping and reporting regulations to the extent practicable. With regard
to measures that address "raw material and product substitution," these are BMPs that
facilities are to consider, and implement as appropriate and necessary.
                                       5-25

-------

-------
                             APPENDIX A
  UNIVERSE OF MEDIUM AND LARGE MUNICIPAL SEPARATE STORM SEWER
SYSTEMS POTENTIALLY SUBJECT TO THE PHASE I STORM WATER PROGRAM
                              Table of Contents


Table A-l. Participating Phase I MS4s as Designated by 1990 Report to Congress	 A-2

Table A-2. Additional MS4s Participating in Phase IMS4 Program	 A-4

Table A-3. Special Districts Participating in Phase I MS4 Program 	 A-9

Table A-4. 1990 Designated MS4s Not Currently Participating in Phase IMS4 Program .  A-l 1

Table A-5. Additional MS4s Not Currently Participating in Phase IMS4 Program	  A-12

Table A-6. Special Districts Not Currently Participating in Phase IMS4 Program	  A-13
                                    A-l

-------
Table A-l. Participating Phase I MS4s as Designated by 1990 Report to Congress
Source: US EPA Office of Wastewater Management
ALASKA
Anchorage

ALABAMA
Birmingham
Huntsville
Jefferson County
Mobile
Montgomery

ARKANSAS
Little Rock

ARIZONA
Mesa
Phoenix
Pima County
Tempe
Tucson

CALIFORNIA
Alameda County
Anaheim
Bakersfield
Berkeley
Chula Vista
Concord
Contra Costa County
El Monte
Escondido
Fremont
Fresno
Fullerton
Garden Grove
Glendale
Hayward
Huntington Beach
Ingiewood
Irvine
Kern County
Long Beach
Los Angeles
Los Angeles County
Modesto
Moreno Valley
Oakland
Oceanside
Ontario
Orange
Orange County
Oxnard
Pasadena
Pomona
Rancho Cucamonga
Riverside
Riverside County
Sacramento
Sacramento County
Salinas
San Bernardino
San Bernardino County
San Diego
San Diego County
San Jose
Santa Ana
Santa Clahta
Simi Valley
Stockton
Sunnyvale
Thousand Oaks
Torrance
Vallejo

COLORADO
Arapahoe County
Aurora
Colorado Springs
Denver
Lakewood

CONNECTICUT
Stamford

DISTRICT OF COLUMBIA
Washington

DELAWARE
New Castle County

FLORIDA
Broward County
Dade County
Escambia County
Fort Lauderdale
Hialeah
Hillsborough County
Hollywood
Jacksonville
Lee County
Manatee County
Miami
Orange County
Orlando
Palm Beach County
Pasco County
Pinellas County
Polk County
Sarasota County
Seminole County
St. Petersburg
Tallahassee
Tampa

GEORGIA
Atlanta
Clayton County
Cobb County
Columbus
De Kalb County
Fulton County
Gwinnett County
Macon
Richmond County
Savannah

HAWAII
Honolulu County

IOWA
Cedar Rapids
Davenport
Des Moines
Boise City

ILLINOIS
Rockford

INDIANA
Indianapolis

KANSAS
Kansas City
Topeka
Wichita

KENTUCKY
Jefferson County
Lexington-Fayette
                                              A-2

-------
Louisville

MICHIGAN
Baton Rouge
East Baton Rouge County
Jefferson County
New Orleans
Shreveport

MASSACHUSETTS
Boston
Worcester

MARYLAND
Anne Amndel County
Baltimore
Baltimore County
Howard County
Montgomery County
Prince George's County

MICHIGAN
Ann Arbor
Flint
Grand Rapids
Sterling Heights
Warren

MINNESOTA
Minneapolis
St. Paul

MISSOURI
Independence
Kansas City
Springfield

MISSISSIPPI
Jackson

NORTH CAROLINA
Charlotte
Cumberland County
Durham
Greensboro
Raleigh
Winston-Salem

NEBRASKA
Lincoln
Omaha

NEW MEXICO
Albuquerque
NEVADA
Clark County
Las Vegas
Reno

NEW YORK
Bronx
Brooklyn
Manhattan
Queens
Staten Island

OHIO
Akron
Columbus
Dayton
Toledo

OKLAHOMA
Oklahoma City
Tulsa

OREGON
Eugene
Multnomah County
Portland
Washington County

PENNSYLVANIA
Allentown
Philadelphia

SOUTH CAROLINA
Greenville County
Richland County

TENNESSEE
Chattanooga
Knoxville
Memphis
Nashville/Davidson

TEXAS
Abilene
Amanllo
Arlington
Austin
Beaumont
Corpus Christi
Dallas
El Paso
Fort Worth
Garland
Harris County
Houston
Irving
Laredo
Lubbock
Mesquite
Pasadena
Piano
San Antonio
Waco

UTAH
Salt Lake City
Salt Lake County

VIRGINIA
Arlington County
Chesapeake
Chesterfield County
Fairfax County
Hampton
Hennco County
Newport News
Norfolk
Portsmouth
Prince William County
Virginia Beach

WASHINGTON
King County
Pierce County
Seattle
Snohomish County
Spokane
Tacoma

WISCONSIN
Madison
Milwaukee
                                             A-3

-------
             Table A-2. Additional MS4s Participating in Phase I MS4 Program

 Source: EPA Office of Wastewater Management
 ALABAMA
 Adamsvtlle
 Alabaster
 Baldwin County
 Bessemer
 Brighton
 Brookside
 Chicksaw
 Creola
 Daphne
 Fairfield
 Fairhope
 Fultondale
 Gardendale
 Graysville
 Helena
 Homewood
 Hoover
 Hueytown
 Indian Springs
 Irondale
 Leeds
 Lipscomb
 Madison
 Maytown
 Midfield
 Mobile
 Moody
 Mountain Brook
 Mulga
 Peiham
 Pleasant Grove
 Prichard
Saraland
Satsuma
 Shelby County
 St. Clair County
 Tanam
Trussville
 Vestavia Hills
Glendale
Scottsdale

CALIFORNIA
Agoura Hills
Alameda
Albany
Alhambra
 Antioch
 Arcadia
 Artesia
 Atherton
 Azusa
 Baldwui Park
 Banning
 Beil
 Bell Gardens
 Bellflower
 Belmont
 Beverly Hills
 Big Bear Lake
 Bradbury
 Brea
 Brisbane
 Buena Park
 Burbank
 Burlingame
 Callamesa
 Camarillo
 Campbell
 Canyon Lake
 Carlsbad
 Carson
 Cathedral City
 Cerritos
 Chino
Claremont
 Clayton
 Clovis
Coachella
 Colma
 Coiton
Commerce
Contra Costa - SF
Corona
Coronado
Costa Mesa
Covina
 Cudahy
Culver City
Cupertino
Cypress
Daly City
 Dana Point
Danville
Del Mar
 Desert Hot Springs
 Diamond Bar
Downey
Duarte
Dublin
East Palo Alto
El Cajon
El Cerrito
El Dorado
El Segundo
Emeryville
Encinitas
Fairfield-Suisun
Fillmore
Folsom
Fontana
Foster City
Fountain Valley
Fresno
Gait
Gardena
Glendora
Grand Terrace
Half Moon Bay
Hawaiian Gardens
Hawthorne
Hemet
Hercules
Hermosa Beach
Hidden Hills
Highland
Hillsborough
Huntington Park
Imperial Beach
Indian Wells
Indio
Industry
Irwindale
La Canada Flintridge
La Habra
La Habra  Heights
La Mesa
LaMirada
LaPalma
La Puente
LaQuinta
La Veme
Lafayette
Laguna Beach
Laguna Niguel
Lake Elsinore
Lake Forest
                                               A-4

-------
Lawndale
Lemon Grove
Livermore
Loma Linda
Lomita
Los Alamitos
Los Altos
Los Altos Hills
Los Gatos
Lynwood
Manhattan Beach
Martinez
Maywood
Menlo Park
Millbrae
Milpitas
Mission Viejo
Monrovia
Montclair
Monte Sereno
Montebello
Monterey Park
Moorpark
Moraga
Mountain View
Murrieta
National City
Newark
Newport Beach
Norco
Norwalk
Ojai
Orange - SD
Orinda
Pacifica
Palm Desert
Palm Springs
Palo Alto
Palos  Verdes Estates
Paramount
Penis
Pico Rivera
Pinole
Pittsburg
Placentia
Placer
Pleasant Hill
Pleasanton
Port Hueneme
Portola Valley
Poway
Rancho Mirage
Rancho Palo Verdes
Redlands
Redondo Beach
Redwood City
Rialto
Richmond
Riverside - SA
Riverside - SD
Rolling Hills
Rolling Hills Estates
Rosemead
San Bruno
San Carlos
San Clemente
San Dimas
San Fernando
San Gabriel
San Jacinto
San Juan Capistrano
San Leandro
San Marcos
San Marino
San Mateo
San Mateo County
San Pablo
San Ramon
Santa Clara
Santa Clara County
Santa Fe Springs
Santa Monica
Santa Paula
Santa Rosa
Santee
Saratoga
Seal Beach
Sierra Madre
Signal Hill
Solana  Beach
South El Monte
South Gate
South Lake Tahoe
South Pasadena
South San Francisco
Stanton
Temecula
Temple City
Thousand Oaks
Tustin
Union City
Upland
Ventura County
Vemon
Vista
Walnut
Walnut Creek
West Covina
 West Hollywood
 Westlake Village
 Westminster
 Whittier
 Woodside
 Yorba Linda
 Yucaipa

 DELAWARE
 Arden
 Ardencroft
 Ardentown
 Bellefonte
 City of New Castle
 Elsmere
 Middletown
 Newport
 Odessa
 Townsend
 Wilmington

 FLORIDA
Adventura
Altamonte Springs
Anna Maria
Apopka
Atlantic Beach
Atlantis
Aubumdale
Bal Harbour Village
Bartow
Bay Harbor Islands
Belle Glade
Belle Isle
Belleair
Belleair Beach
Belieair Bluffs
Boca Raton
Boynton Beach
Bradenton
Bradenton Beach
Briny Breezes
Cape Coral
Casselberry
Century
Clearwater
Cloud Lake
Coconut Creek
Cooper City
Coral Gables
Coral Springs
Dade City
Dania
 Davenport
                                                A-5

-------
Davie
Deerfield Beach
Delray Beach
Dundee
Dunedin
Eagle Lake
Eatonville
Edgewood
El Portal
Fort Meade
Fort Myers
Frostproof
Glen Ridge
Golden Beach
Golf
Golfview
Greenacres
Gulf Stream
Gulfport
Haines City
Hallandale
Haverhill
Hialeah Gardens
Highland Beach
Hillcrest Heights
Holmes Beach
Homestead
Hypoluxo
Indian Creek Village
Indian Rocks Beach
Jacksonville Beach
Juno Beach
Jupiter
Jupiter Inlet Colony
Kenneth City
Key Biscayne
Lake Alfred
Lake Clarke Shores
Lake Hamilton
Lake Mary
Lake Park
Lake Wales
Lake Worth
Lakeland
Lantana
Largo
Lauderdale by the Sea
Lauderdale Lakes
Lauderhill
Leon County
Lighthouse Point
Longboat Key
Longwood
Madeira Beach
Maitland
Manalapan
Mangonia Park
Margate
Medley
Miami Beach
Miami Shores
Miami Springs
Miramar Point
Mulberry
Neptune Beach
New Port Richey
North Bay Village
North Lauderdale
North Miami
North Miami Beach
North Palm Beach
North Port
North Redington Beach
Oakland Park
Ocean Ridge
Ocoee
Oldsmar
Opa Locka
Oviedo
Pahokee
Palm Beach
Palm Beach Gardens
Palm Beach Shores
Palm Springs Village
Palmetto
Parkland
Pembroke Park
Pembroke Pines
Pensacola
Pinecrest
Pinellas  Park
Plant City
Plantation
Polk City
Pompano Beach
Port Richey
Redington Beach
Redington Shores
Riveria Beach
Royal Palm Beach
Safety Harbor
Saint Leo
San Antonio
Sanford
Sambel
Sarasota
Sea Ranch Lakes
Semmole
South Bay
South Miami
South Palm Beach
South Pasadena
St. Pete Beach
Sunny Isles Beach
Sunrise
Surfside
Tamarac
Tarpon Springs
Temple Terrace
Tequesta
Treasure Island
Venice
Village of Highland Park
West Miami
West Palm Beach
Wilton Manors
Winter Garden
Winter Haven
Winter Park
Winter Springs
Zephyrhiils

GEORGIA
Acworth
Alpharetta
Austell
Avondale Estates
Berkeley Lake
Bibb County
Bloomingdale
Buford
Chamblee
Chatham County
Clarkston
College Park
Dacula
Decatur
Doraville
Duluth
East Point
Fairburn
Forest Park
Garden City
Grayson
Hapeville
Jonesboro
Kennesaw
Lake City
Lawrenceville
Lilburn
Lithonia
Lovejoy
                                                 A-6

-------
 Marietta
 Morrow
 Norcross
 Palmetto
 Pine Lake
 Pooler
 Port Wentworth
 Powder Spnngs
 Riverdale
 Roswell
 Smyrna
 Snellville
 Stone Mountain
 Sugar Hill
 Suwanee
 Thunderbolt
 Tybee Island
 Union City

 IDAHO
 Garden  City

 KANSAS
 Overland Park

 KENTUCKY
 Anchorage
 Audobon Park
 Bancroft
 Barbourmeade
 Beechwood Village
 Bellemeade
 Bellewood
 Blue Ridge Manor
 Briarwood
 Broad Fields
 Broeck Pointe
 Brownsboro Farm
 Brownsboro village
 Cambridge
 Cherrywood Village
 Cold Stream
 Creekside
 Crossgate
 Douglass Hills
 Druid Hills
 Fairmeade
 Forest Hills
 Glenview
 Glenview Hills
Glenview Manor
Goose Creek
Graymoor-Devondale
Green Spring
 Hickory Hill
 Hills and Dales
 Hollow Creek
 Hollyvilla
 Houston Acres
 Hurstboume
 Hurstbourne Acres
 Indian Hills
 Indian Hills Cherokee Section
 Jefferson
 Keeneland
 Kingsley
 Langdon Place
 Lincolnshire
 Lyndon
 Lynnview
 Manor Creek
 Maryhill Estates
 Meadow Vale
 Meadowbrook Farm
 Meadowview Estates
 Middletown
 Minor Lane Heights
 Mockingbird Valley
 Moorland
 Murray Hill
 Norbourne Estates
 Northfield
 Norwood
 Old Brownsboro Place
 Parkway Village
 Plantation
 Plymouth Village
 Poplar Hills
 Prospect
 Richlawn
 Riverwood
 Robinswood
 Rolling Fields
 Rolling Hills
 Seneca Gardens
 Shively
 South Park View
 Spring Mill
 Spring Valley
 Springlee
 St. Matthews
 St. Regis Park
 Strathmoor Gardens
 Strathmoor Manor
 Strathmoor Village
 Sycamore
 Ten Broeck
Thornhill
 Watterson Park
 Wellington
 West Buechel
 Westwood
 Whipps Millgate
 Wildwood
 Winding Falls
 Wmdy Hills
 Woodland Hills
 Woodlawn Park
 Worthington

 LOUISIANA
 Gretna
 Harahan
 Kenner
 Westwego

 MARYLAND
 Carroll County
 Charles
 Frederick
 Harford County
 Washington County

 MICHIGAN
 [Voluntary Small]

 MINNESOTA
 Columbia Heights
 Edine
 Richfield
 St. Louis  Park

 NORTH  CAROLINA
 Fayetteville

NEVADA
Henderson
North Las Vegas
Sparks
Washoe County

OREGON
Banks
Beaverton
Clackamas County
Cornelius
Fairview
Forest Grove
Gaston
Gladstone
Gresham
Happy Valley
                                               A-7

-------
Hillsborough
Johnson City
Lake Oswego
Milwaukee
North Plains
Oregon City
River Grove
Salem
Sherwood
Tigard
West Linn
Wilsonville

PENNSYLVANIA
Hanover
Salisbury
South White Hall
White Hall

SOUTH CAROLINA
Fountain Inn
Greenville
Greer
Mauldin
Simpsonville
Travelers Rest
View
Glendale
Grafton, Town of
Grafton, Village of
Greenfield
Kohler
Menomonee Falls
Mequon
Oak Creek
Racine
River Hills
Sheboygan
Sheboygan Falls
Shorewood
South Milwaukee
St. Francis
Thiensville
Waukesha
Wauwatosa
West Allis
West Milwaukee
Whitefish Bay
Wilson
SOUTH DAKOTA
Sioux Falls

TENNESSEE
Bellemeade
Berryhill
Forest Hills
GoooUettsville
Lakewood
Oakhill
Ridgetop

WASHINGTON
Clark County
Spokane

WISCONSIN
Bayside
Brookfield
Brown Deer
Butler
Cedarburg
Cudahy
Etai Grove
Fox Point
Gerrnantown
                                              A-8

-------
             Table A-3. Special Districts Participating in Phase I MS4 Program

Source: EPA Office of Wastewater Management
ALASKA
AKDOT
Port of Anchorage
U. of Alaska

ALABAMA
ALDOT
AL State Parks Division

ARKANSAS
ARDOT

ARIZONA
AZ DOT

CALIFORNIA
ACFD Zone 7
Alameda Cty  Flood Dist
CalTrans Central Coast
CalTrans Central Valley
CalTrans Coachella Valley
CalTrans LA
CalTrans S. Lake Tahoe
CalTrans San Diego
CalTrans Santa Ana
CalTrans Santa Rosa
CalTrans SF
Coachella Valley Water District
Contra Costa FCD
Contra Costa Flood District
CSU-Fresno
Fresno Metro Flood District
LA Cty Public Works
Lake Tahoe Basin
Orange Cty Flood Disrict
Orange Cty Flood District
Riverside Cty Flood Distr
Riverside Flood & Water
District
Riverside Flood Control District
Riverside-Colorado River Basin
San Diego Unified Port District
Santa Clara Valley FCD
Sonoma Cty Public Works
Sonoma Cty Water Agency
Vallejo San & Fl Con District
Ventura Cry Flood District
COLORADO
Arapahoe Co. Waste Water
CO DOT
E. Cherry Creek Valley WS
Inverness W/S

DELAWARE
DEDOT
New Castle DPW

FLORIDA
Acme Improvement District
Bay Creek Community Dev.
Bayside Comm. Dev. Dist.
East Cty Water Ctrl Distr
East Mullock Drainage Dis
FLDOT
Gateway Services Dist.
Indian Trail WCD
No. Palm Beach Co Imp District
No. Palm Beach Heights WC
Palm Beach Cty DERM
Reedy Creek Imp. Dist.
San Carlos Estates Dist.
South Indian River WCD
Valencia Drainage District

HAWAII
HI DOT

IDAHO
Ada Co. Hwy. Dist.
Boise State U.
ID DOT
Water District 3

KANSAS
Fairfax Drainage District
Kaw Valley Drain. Dist.

KENTUCKY
Metro Sewer District

LOUISIANA
Caddo Levee District
LA DOT & Development
Louisiana State Univ.
Orleans Levee District
Port of New Orleans
Southern Univ.
Swr&WtrBdofN.O.

MARYLAND
State Highway Admin.

MICHIGAN
MI DOT
U. of Michigan

MINNESOTA
Hennepin Co. Pub. Works
Minneapolis Parks & Rec.
MNDOT
University of MN

MISSOURI
MO Hwy/Trans. Dept.

NORTH CAROLINA
NCDOT

NEW MEXICO
Albuquerque Fid Ctl Auth
MM DOT
UNM at Albuquerque

NEVADA
Clark Cry Flood Dist.
NVDOT

OKLAHOMA
OK DOT
OK. Turnpike Auth.

OREGON
Clackamas Sewer District
Multnomah Cty Drain. Dist
Oak Lodge Sanitation Dist
OR DOT
Peninsula Drain. Dist #1
Peninsula Drain. Dist #2
Port of Portland
Wash Cty Dept of Land Use

SOUTH DAKOTA
SDDOT
                                              A-9

-------
TEXAS
Dallas Co. FCDS1
Dallas Co. Util. & Reel.
Del Mar Jr. College
Harris Co. Fl. Ctrl. Dist
Irving FCD Sect. 1 & 2
Jefferson Co. Drain. Dist
Laredo Community College
Port of Corpus Chnsti
San Antonio Water System
Tarrant Co. WCID #1
Texas Tech U.
TX A&M - Corpus Christi
TXDOT
TX DOT - Abilene
TX DOT - Arlington
TX DOT - Austin
TX DOT - Beaumont
TX DOT - Dallas
TX DOT - Houston
TX DOT - Laredo
TX DOT - San Antonio
TX DOT - Waco
TX DOT- Amarillo
TX Turnpike Auth
U. of TX - Arlington
U. of TX-Austin

UTAH
UDOT

WASHINGTON
METRO
WADOT

WISCONSIN
SE WI Pro Baseball Pk Dist.
U. of Wise.
WI DOT
Wisconsin State Fair Park
                                            A-10

-------
  Table A-4. 1990 Designated MS4s Not Currently Participating in Phase I MS4 Program
                               (* denotes CSO exemption)

Source: EPA Office of Wastewater Management
CALIFORNIA
San Francisco*

COLORADO
Pueblo

CONNECTICUT
Bridgeport*
Hartford*
New Haven*
Waterbury*

ILLINOIS
Chicago*
Peoria*

INDIANA
Evansville*
Fort Wayne*
Gary*
South Bend*

MASSACHUSETTS
Springfield*

MICHIGAN
Detroit*
Lansing*
Livonia*

MISSOURI
St. Louis*

NEW JERSEY
Elizabeth*
Jersey City*
Newark*
Paterson*

NEW YORK
Albany*
Buffalo*
Rochester*
Syracuse*
Yonkers*

OHIO
Cincinnati*
Cleveland*
Youngstown

PENNSYLVANIA
Erie*
Pittsburgh*

RHODE ISLAND
Providence*

SOUTH CAROLINA
Columbia

VIRGINIA
Alexandria*
Richmond*
Roanoke*
                                          A-ll

-------
     Table A-5. Additional MS4s Not Currently Participating in Phase I MS4 Program

Source: EPA Office of Wastewater Management

COLORADO
Englewood     Englewood voluntarily submitted Part I of the Phase I application but does not appear to be
              pursuing coverage under the program.

ILLINOIS
Springfield     No information.

MASSACHUSETTS
Lowell         No information.

PUERTO RICO
Carolina       Under administrative review by EPA Region 2.
San Juan
                                           A-12

-------
     Table A-6.  Special Districts Not Currently Participating in Phase I MS4 Program

Source: EPA Office of Wastewater Management
SOUTH CAROLINA
Harbor of Charleston
Although South Carolina used an Administrative Order to include the Harbor of
Charleston in the storm water program and established a deadline for its application, the
Harbor of Charleston is no longer participating.
                                               A-13

-------

-------
                   APPENDIX B

EPA SURVEY FORMS FOR INVENTORYING PROGRAMMATIC AND LOAD
   REDUCTIONS UNDER THE PHASE I MS4 PERMITTING PROGRAM
                         B-I

-------
NPDES NUMBER
Contact Name
Contact Phone Number
Program Effectiveness Indicators for Phase I MS4 Permits
NPDES Permit Storm
Water Management
Elements
A. Construction Planning Process and Construction
Inspections for Erosion & Sediment Control
B. Spill Response to Protect Loca! Waterbodies/
Responding to Public Reporting of Questionable
Discharges
C. Public Maintenance/Inspection of Structural Storm
Water BMP Controls
D. Implementation of Planning/Zoning Procedures for
Storm Water Management
E. Storm Water Inspections of Municipal Facilities
and Industries
F. Retrofit of Flood Management Facilities for Water
Quality Benefits
G. Collection of Oil/Household Wastes
H. Roadway Maintenance to Protect Storm Water
(e.g.. Street Sweeping, modified deicing activities)
I. Field Screening/Inspection of Storm Sewers for
Illicit and other Discharges
J. General Public Storm Water Outreach/ Education
Activities
K. Managing Municipal Use of Pesticides, Herbicides,
and Fertilizers to Improve Storm Water Quality
L. Inventorying/Mapping Storm Water Systems and
Identification of Pollutant Sources (e.g.. Outfall and
BMP mapping, Source Area Identification)
M. Estimating/Tracking Storm Water Load Generated
within Permitted Area
N. Chemical Monitoring at MS4 Storm Water Outfalls
O. In-stream Chemical Monitoring for Assessing
Storm Water Impacts
P. Geomorphologic and Biological Monitoring
Activities Related to Storm Water
Did the Phase ! permit
requirements either
cause new or
significantly refine
activities under this
element (Yes, No,
Uncertain)
















Enter two dates: l)The
approximate date when this
element was first tested in the
permitted area and 2) The date
when this management element
was (or will be) applied to a
Maximum Extent Practicable
(MEP) in the permitted area.
















Rank the environmental
benefits of this
management element
(First, the benefit
realized since first
permit and then
expected future benefit
from continued use)*
















 Ratings: 1 - Genera! observed benefit to the environment tor the permitted and adjacent area; 2 - Environmentally beneficial but only to select
portions of permittee's area; A - Probably beneficial to the environment and its management, but the effects have not been documented to date; 4 •
I nlikely to produce em ironmenul benefits; and 5 • Inconclusive em ironmeital hcn«:"ti on this element.
                                                  B-2

-------
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-------

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                APPENDIX C
NAFSMA SURVEY QUESTIONS FOR MS4 MEMBERS PERMITTED
                 UNDER PHASE I
                     C-l

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   Survey on Phase 1NPDES Municipal Stormwater
                                                          Programs
At the request of Congress the U.S. Environmental Protection Agency (EPA) is preparing a report on
the effectiveness of the Phase I Stormwater Program. NAFSMA has an opportunity to provide input
to the report. We believe that NAFSMA members have a wealth of experience in developing and
running municipal Stormwater programs and will contribute valuable insights on effective
components of the program. To facilitate this, we are asking Phase I local governments to provide us
with information outlined in the survey below. We will evaluate the responses and pass along
findings to EPA as appropriate. Please feel free to provide any additional backup information you
feel would be helpful in analyzing your response.

To maximize the usefulness of the information and provide as much flexibility as possible, we would
like to have the option of sharing your entire response with EPA. For this reason, please let us know
whether you would be willing to have your entire response shared with the agency. If you do not
want us to release your responses to EPA, we will not do so. Instead, we will report those results to
EPA in an aggregated format with no reference to your community.

	NAFSMA is permitted to transmit my responses as provided to U.S. EPA
	Do not release my responses as provided to U.S. EPA
Please return your responses by mail, fax (202) 842-0621, or e-mail to bill@nafsma.org, by Monday
December 20, 1999. Please call Bill Morrissey at (202) 218-4122 with any questions.
Name of Respondent
Title
Address
City/State/Zip,

Phone	
Fax
Your E-mail Address
Web Address for your Program (if available)
                                        C-2

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Has your agency been issued an NPDES stormwater permit? Y N

If No, is there an application pending? Y N

If Yes, are you:	_(a) a single permittee or	(b) a co-permitee

NPDES Phase I Stormwater Permit issued	(Date Issued)

Population served by municipal storm sewer system:	
IN GENERAL

1) How would you rate the overall effectiveness of the Phase I Storm Water Program in improving
the quality and quantity of storm water discharges and protecting water quality in your jurisdiction?
a. Very Successful
b. Successful
c. Unsuccessful
d. Too early to tell

Please use this space to provide examples to support your response:

2) Please describe those specific components of your municipal stormwater program that have been
effective in reducing the discharge of pollutants from your municipal storm sewer system or in
improving water quality,  and why you feel they have been effective.

COMPONENT EXPLANATION

Please describe the components that have not been effective.

COMPONENT EXPLANATION

Please provide any documentation such as reports or data, that contain any quantitative information
on the effectiveness of specific control practices.

3) In your opinion, did implementing the Phase I program in your jurisdiction result in protecting or
restoring your watershed's physical, chemical, and/or biological quality?

The Phase I control program assisted in protecting the quality of my jurisdiction's watershed?
Yes	
No	
Uncertain
The Phase I control program assisted in restoring the quality of my jurisdiction's watershed?
Yes	
No	
Uncertain	
                                           C-3

-------
 If you have any existing information demonstrating the relationship of Phase I controls and
 watershed protection, and/or restoration, please attach that information. Reports providing
 quantitative information on specific waterbodies are of particular value.

 4) Can you suggest any potential changes the EPA may want to make to improve the program's
 effectiveness or streamline its approach?

 5) If you would like to share any other information relevant to the Phase I program, please feel free
 to use this space.

 6) Please estimate (a) your agency's cost of activities from before the Phase I regulation that you now
 include as part of your phase I permit (b) your agency's new activities that you are now required to
do as part of the phase I permit that you were not doing previously

(a)$	
7) Does your community have a stormwater utility in place? Y N

8) If no, are you in the process of establishing a.utility? Y N

9) Are you considering the possibility of establishing a stormwater utility? Y N

10) If you do have a utility in place, please answer the  following questions.

a) What is the annual stormwater fee for typical household	?

§ Does your utility include incentives, such as a decreased user fee, for businesses or industries that
implement stormwater quality controls? Y N

b) What are the annual revenues generated? $	
c) What percentage of funds are used for maintenance?
d) What percentage of funds are used for stormwater quality?
For questions concerning the survey please contact Bill Morrissey in NAFSMA's Washington
Office.
Phone: (202)218-4122 E-Mail: bill@nafsma.org

Please return the survey to Bill Morrissey via mail or either fax number:

Bill Morrissey
NAFSMA
1299 Pennsylvania Ave, Eighth Floor West
Washington, DC 20004

Fax : (202)842-0621 or (202)785-5277
                                            C-4

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                        APPENDIX D

CASE STUDIES ON THE BENEFITS OF THE PHASE I STORM WATER PERMIT
                         PROGRAM
                            D-l

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                                        Table of Contents



Municipal Case Studies




ASCE/EPA National Storm Water BMP Practices Database  	  D-3



Austin, Texas   	      0_4



Caltrans, California  	  $,5



Boston, Massachusetts  	  D-6



Chattanooga, Tennessee  	  D-7



New Castle County, Delaware  	  D-8



Dover, New Hampshire	  D-9



Fort Worth, Texas 	  D-10



Garland,Texas  	  D-ll



King County, Washington	  D-12



Los Angeles County, California  	  D-13



Minneapolis, Minnesota	  D-15



Montgomery County, Maryland	:	  D-16



Monterey Bay, California	  D-18



Brunswick County, North Carolina	  D-19



Palo Alto County, California	  D-21



Grays Harbor County, Washington 	  D-22



Prince George's County, Maryland	  D-24



Portland, Oregon 	  D-26



Sacramento, California	  D-27



San Francisco Bay, California	  D-28



State of Maryland  	  D-29



Industrial case studies:



Ciba Specialty Chemicals, Newport, Delaware	  D-31



Hoechst Celanese, Coventry,  Rhode Island	  D-32



Doggett Auto Parts, Bryan, Texas 	  D-33



Empire Castings, Tulsa, Oklahoma 	  D-34



Pratt Auto Salvage. Hoxie, Arkansas	  D-35
                                                D-2

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National Storm Water Database:  A Case Study of a National Incentive
  Successful Elements Related to Phase I Program:
  • Both Phase I and Phase II communities contribute case studies to the National Storm Water database so other
    municipalities can learn about the effectiveness of BMP implementation.

  • The storm water database allows for municipalities from all over the country to compare and contrast study
    results to further enhance the protection of the environment through experience and education.
What is the purpose of the National Storm Water Database?
This project is being conducted under a cooperative agreement between the American Society of Civil Engineers
(ASCE) and the U.S. Environmental Protection Agency. The purpose of the project is to improve water quality
nationwide by sharing consistent and transferable information on storm water best management practices. The
database will help water quality professionals across the United States to learn about successful BMPs and apply
proven methods to local water quality projects. By adding individual BMP study findings to the database, users can
enrich its usefulness for a national audience.
  Location:
  Nationwide

  Area:
  II States

  Affected
  waters:
  Waters of the
  U.S.
What information is considered?
Representative information provided for BMPs includes test site location, researcher contact
data, watershed characteristics, regional climate statistics, BMP design parameters, monitoring
equipment types, and monitoring data such as precipitation, flow, and water quality.
What are the benefits?
• Provides access to BMP performance information for comparison to local studies.
• Allows individual investigators to develop project-specific BMP performance databases.
• Promotes technical design improvements in storm water runoff management methods.
• Offers a simple  way to share findings with the water quality community.
• Serves planners, engineers, scientists, officials, and citizens involved in water quality
  projects.
• Easy to understand and use.
Who has contributed to the database?
Communities distributed among 11 States have contributed BMP effectiveness information for the database. To
date, 73 percent of the case studies submitted are from Phase I communities (18 communities in all). Phase II
contributors make up the remaining percentage of case studies submitted, with a total of 12 cities participating in the
project
BMP designers, owners, and operators are invited to submit their BMP study data for incorporation into the storm
water database. This is an ongoing invitation to further enhance the range and applicability of the national storm
                                                              water BMP database.
         Contributions of Storm Water Case Studies for
                   National Database by State
                                   NC  OH  TX VA WA
                               States
                                                                        Contact:
                                                                        Jane Clary, Project Manager
                                                                        Wright Water Engineers, Inc.
                                                                        2490 West 26th Avenue, Suite 100A
                                                                        Denver, CO 80211-4208
                                                                        Phone 303-480-1700
                                                                        E-mail: clary@wrightwater.com
      iPhase
                                                  D-3

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Austin, Texas: A Stormwater Runoff Abatement Project Within an Existing Urban
Watershed
   Successful Elements Related to Phase I Program:
   •   Retrofit projects remove pollutants from the urban watershed, and can enhance wildlife habitat, neighborhood
      aesthetics, and recreational opportunities.
   *   Hie Central Park retrofit project provides 44 percent to 79 percent removal of key pollutants.
      Faced with a rapidly growing population, urban development, and rising concerns over nonpoint sources of pollution,
      city managers in Austin, Texas, require all new development to implement storm water best management practices
      (BMPs). Older existing urban watersheds, however, still need water quality controls. The City of Austin Urban
      Watershed Retrofit program was created to evaluate existing urban watersheds to determine appropriate storm water
controls that reduce pollutants through settling, filtration, flotation, absorption, and/or biological processes. Since the mid-
1990s, the city has undertaken numerous retrofit storm water abatement projects that provide storm water management in
areas where once there was no management, including some areas that correspond with urban redevelopment efforts. The
city initiated an optional urban watershed ordinance fee policy, under which private developers can opt to contribute to a
                    city-run fund instead of installing on-site water quality controls. These developer fees are used in
                    addition to a portion of the city's monthly drainage fees to fund storm water projects, including those
                    that retrofit older urban areas.
Location:
Austin, TX
Population:
613,458
Area:
225.4 square
miles
Affected
Waters:
Austin-Travis
Lakes Watershed,
Colorado River,
Town Lake
                    One recent example of an Austin retrofit project is the Central Park area. Central Park is a joint
                    public/private enterprise between the State of Texas and a private developer. The project covers a total
                    of 164 acres and incorporates 39 acres of mixed-use development, including houses, shops,
                    businesses, and 10 acres of park and public spaces with hike and bike trails and picnic areas.
                    Integrated into the project are three storm water quality ponds designed to provide environmental,
                    aesthetic, and economic benefits. Fifty-four percent of die area draining to the ponds is covered by
                    impervious surfaces. Rainwater that falls on the land area drains to the wet ponds, carrying trash,
                    litter, and pollutants with it. During storms, approximately 300,000 cubic feet of rainfall runoff is
                    stored in the ponds and released slowly to reduce flooding  and erosion downstream in Waller Creek.
                    Two waterfalls between the ponds increase oxygen in the water for fish and other aquatic life. The
                    best pollutant removal occurs when runoff remains in the ponds for a duration of 2 weeks or more.
                    Sediment and other pollutants settle out of the water and are not discharged to Waller Creek or Town
Lake. Periodically, the pollutants that have settled to the bottom of the pond, in the "muck," are removed by dredging. The
treated water is then released from the ponds to flow to the Hemphill branch of the Waller Creek and eventually to Town
                                                      Lake. The estimated pollutant removal is provided in the
                                                      adjacent text box.
Water Quality
Parameter
Total suspended solids
Nitrate/nitrite as N
Total Phosphorus
Lead
Zinc
Removal Efficiency
(measured*)
79%
65%
44%
97%
65%
Pounds
Prevented
(est.) per year
36.400 to
50.000
55 to 275
55 to 2,000
5 to 50
10 to 150
In addtion. the wet water ponds remove 57% of the total
petroleum hydrocarbons, 70% of the copper, 71% of the DDTs,
57% of the chemical oxygen demand, and 68% of the PAHs.
* Removal efficiency was calculated based on water quality
measured at one of several inflows and at the outflow. The
other inflows were accounted for in water quality models used
to estimate loads captured.
                                                      The construction of the wet ponds was funded by the city of
                                                      Austin, the developer, and the U.S. Environmental Protection
                                                      Agency through a matching section 319 grant for monitoring
                                                      the ponds and installing educational signs. The total cost of the
                                                      project was $584,000.

                                                      The city of Austin continues to evaluate and implement projects
                                                      in developed urban areas to limit erosion and flooding and to
                                                      protect or improve water quality.
                                                                   Contact:
                                                                   Leila Gosselink
                                                                   512499-1869
                                                                   leila.gosselink@ci.austm.tx.us
                                                      D-4

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Caltrans' General Permit: Flexibility ofNPDES Program Promotes a Comprehensive
Statewide Storm  Water Management Approach
  Successful Elements Related to Phase I Program:
  •   Streamlines permit administration for department of transportation permittee.
      Improves watershed-level transportation planning.
      Encourages partnerships with local, State, and regional regulators.
T
      he flexibility of the Phase I construction program and NPDES regulations resulted in the State of California
      developing a highway construction general permit. This newly promulgated permit is specific to the requirements for
      transportation construction and was developed to standardize highway construction permitting to foster quicker and
      more cost-effective compliance.
  Location:
  State of California

  Affected area:
  155,973.2 sq mi

  Population:
  32,666,550
  (May I, 1998 U.S.
  Census)
                        Under the Phase I rule, departments of transportation (DOTs) are considered municipal separate
                        storm sewer system (MS4) operators and must obtain the required permits. Because of the nature
                        of the regulations and DOT MS4 systems, many State DOTs held numerous MS4 permits in
                        various Phase I cities. In 1996, to implement a more uniform storm water program, Caltrans
                        requested that the California State NPDES permitting authority, the State Water Resources
                        Control Board (S WRCB), consider adopting a single NPDES permit for all storm water
                        discharges from Caltrans properties, projects, and activities.  Over the next 3 years, Caltrans,
                        EPA Region 9, and the SWRCB worked together to develop the required permit language. On
                        July 15, 1999, the SWRCB approved the final Caltrans statewide NPDES permit. This permit
                        covers the Construction General Permit (CGP) and MS4 permit requirements as well. Prior to
                        that time, Caltrans had held nine different MS4 permits and there had been no statewide, standard
                        procedure for CGP compliance.

                        Caltrans is confident that it can meet the challenges of its new permit through the implementation
                        of its new statewide comprehensive Storm Water Management Program (SWMP). The SWMP
requires that the most advanced best management practices, design/construction techniques, and maintenance procedures be
used on all Caltrans properties. This creates uniformity in site plans throughout the State.  To use the most efficient erosion
and sediment control and vegetation management BMPs available, Caltrans is conducting  research and monitoring studies.
The resulting information will be available to other  DOTs and permittees. Caltrans also is developing a GIS-based database
to provide information on any potentially impacted  watersheds, water bodies, and associated water quality standards.  The
program will assist in the new watershed-level highway construction project planning process outlined in the SWMP and
encourage coordination between regulators, local community groups, municipalities, and transportation entities.  Caltrans is
developing a comprehensive education and awareness program for its personnel. This program includes guidebooks for staff
and contractors. A Storm Water Compliance Review Task Force also has been established to conduct in-house compliance
reviews on highway construction sites and other Caltrans facilities.

By using the flexibility of the NPDES regulations and working with the permitting authority, Caltrans was able to develop a
standardized, statewide permit without the standard requirements that do not apply to a DOT. This approach will improve
the overall efficiency of the program, better ensure compliance, and protect water quality in California.
  Caltrans' SWMP Components:
     Standardized watershed planning and use of
     construction BMPs
     Research projects
  •   CIS planning tools
     Guidebooks for staff and contractors
  •   Education and awareness program
     Internal compliance task force
                                                            Contact
                                                            J. Steven Borroum. Chief, Environmental Engineering
                                                            California Department of Transportation, 916 653-7396
                                                            steve_borroum@dot. ca.gov

                                                            Sources:
                                                            www.dot.ca.gov/ng/environrnental/storrnwater
                                                            U.S. Census Bureau,< www.census.gov>
                                                     D-5

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Charles River: Discovering and Removing illicit Connections
   Successful Elements Related to Phase I Program:
   • Removal of illicit connections has eliminated discharge of about 1 million gallons of contaminated flow per day.
   • In 1999, the Lower Charles River met its designated use during dry-weather periods for swimming 94 percent of the
     time, and the boating use is safe virtually all of the time.
      The Charles River, which flows 80 miles from Hopkinton to Boston Harbor, is one of the busiest recreational rivers in
      the world. Unfortunately, by the early 1990s the quality and quantity of safe swimming and boating opportunities had
      been reduced by multiple pollutant sources, including storm water runoff and dry-weather illicit connections. To meet
      the goal of restoring the Charles River to fishable and swimmable status by Earth Day 2005, EPA is working closely
with several Federal, State, and local agencies through a number of regulatory programs.

One of the major water quality problems on the lower Charles River comes from high bacteria levels during non-rainfall
periods in and around Boston. Boston is the only community along the Charles River that is subject to Phase I storm water
regulations. Its Phase I storm water permit requires Boston to investigate and eliminate all illicit discharges over the permit's
5-year term. In a recent investigation effort, Boston's dry-weather monitoring found a sanitary sewer discharging 72,000
gallons per day of sewage into a storm drain (one of three open connections between sanitary sewers and storm drains), 22
other illicit connections, and one broken sanitary sewer drain. As of spring 1999, repairs had been completed to remove
those pollutant sources.
  Location:
  Boston,
  Massachusetts

  Area:
  48 square miles

  Affected
  Waters:
  Lower Charles
  River
Since the beginning of the Charles. River initiative, a regional initiative that entails better storm water,
sanitary, and combined sewer management for communities along the river, there has been a steady
increase in EPA's environmental report card for the river—from a D to a B- rating over a three-year
period. The report card is based on a summary of the city's annual monthly water quality monitoring
results. Improvements in the river's dry-weather water quality since the inception of the initiative has
been measured and includes a doubling of the days on which swimming standards for bacteria are
being met.  Additionally, the water quality standards for boating were met 100 percent of the time in
1999 during dry-weather periods. The trend since the implementation of illicit connection
management has been a steady improvement of the dry-weather water quality of the Charles River.

Boston's action to inspect city storm drains and pipes is being embraced by future Phase II storm
water cities discharging to the Charles River.  Many of these have largely completed their illicit
connection investigations and are now evaluating or implementing programs to rehabilitate illicit
                          connections.  According to EPA's Bill Walsh-Rogalski, illicit
                       ~ connection management by Boston and the other communities on the
                          lower 10 miles of the Charles has stopped more than I million gallons
                          of raw sewage from discharging daily into the river.
       Percentage of Time Meeting Water
         Quality Standards for Primary
         Contact Recreation During Dry
               Weather Periods
      100
  S.
                           Because the water quality of the Charles River is a regional concern,
                           Boston and the surrounding cities have developed a storm water
                           workshop for the area's municipalities, including four State agencies
                           that discharge storm water into the Charles River. Boston is also
                           developing and conducting a demonstration project to examine the
                           effectiveness of certain best management practices and to determine
                           which ones are useful for protecting water quality during wet-weather
                           periods, which includes CSO management.
              1996      1997       1998

                  Trend Over Time
                                                Contact-
                                                Bill Walsh-Rogalski, USEPA,
                                                617 918-1035
                                                
                                                      D-6

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Controlling Construction Site Runoff in Chattanooga, Tennessee
   Successful Elements Related to Phase I Program:
   •    Programmatic improvements have fostered contractor awareness of and compliance with the city's regulations. The
       city program is being used as a model for a similar statewide program.
   •    The city's free Erosion Control School has received a positive response from builders and has inspired other
       Tennessee cities to begin developing similar classes.
      The city's response to Phase I requirements resulted in a model program that is being used as the foundation for the
      development of a statewide program by Tennessee's Department of Natural Resources. Chattanooga's local
      geography creates a basin into which storm water flows from other nearby jurisdictions and neighboring States.  Prior
      to the program, changes in bed load of Mackey Creek "have been as high as 14 feet," according to Doug Fritz of the
city's Storm Water Management Program.  Chattanooga's erosion control program has three components: the erosion control
requirements, contractor education, and enforcement. Aside from some exceptions for home gardening and landscaping and
construction of stand-alone, single-family homes, people engaged in land-disturbing activities on sites of any size must
obtain a city land disturbance permit and provide an erosion control plan before beginning work. Even those engaged in the
excepted activities must follow the requirements of the ordinance although they do not need to obtain a permit or file a plan.

                       Exceeding current Federal regulations and anticipating the proposed Phase II rule, the city sets no
                       lower limit for its program and requires erosion and sediment control measures to be functional
                       before activity begins and to be maintained throughout construction.  Clearing and grubbing must
                       be kept to the minimum necessary for grading and equipment operation. Any disturbed area that is
                       planned to remain idle for more than 30 days must be stabilized within 7 days of disturbance.
                       When work is completed, the owner must make sure that the site is as erosion-free as practicable,
                       establishing permanent vegetative cover where no other permanent stabilization technique has been
                       used.  Permanent certificates of occupancy are not granted until either the site is stabilized or a
                       letter is received from the developer specifically  detailing stabilization plans and time frames.
Location:
Chattanooga,
Tennessee

Number of People
Served by Permit:
152,466


Affected Area:
127.1 square rrnies
                       The city's public works staff discovered that achieving contractor compliance with these measures
                       would be difficult.  Chattanooga first developed education programs and attempted on-site training
                       sessions. When these sessions did not produce significant improvement, the city, with initial
                       assistance from the Chattanooga Home Builders' Association, established the Erosion Control
School. In a free, 4-hour session, developers learn the city's requirements, as well as cost-effective ways to achieve
compliance. Tests before and after the course measure learning, and those who pass the second test receive a certification
card.  In 5 years the school has certified nearly 300 people associated with all aspects of development in five years.  The City
has received positive responses not only from builders who have  attended the class, but also from local officials who wish to
develop similar programs in their municipalities.

Chattanooga also has a strong enforcement program.  In the 1996-97 fiscal year the city conducted 2,211 site inspections
while issuing 388 land disturbance permits.  Fines of up to $500 per day can be imposed by the city's environmental court,
and civil penalties of up to $5,000 per day can be imposed by the storm water manager. The city largely prefers to work with
developers to show them how to achieve compliance and takes only repeat offenders to court.  The possibility of punishment
creates a strong incentive for those involved  in land-clearing activities to attend the Erosion Control School.
To better demonstrate the benefits of the storm water management
program, the city has completed an initial sampling and analysis
program to track the water quality improvement from continuing
development in the headwaters of area streams. Sampling is
conducted for water quality and biological parameters. This baseline
sampling will be available to assess new development in streams that
bioassessment protocols rate  as "good" biological communities. The
city anticipates comparative results as early as next year.
                                                                 Contact-
                                                                 Douglas Fritz, Water Quality Supervisor, Chattanooga
                                                                 Department of Public Works. 423 757-0013.

                                                                 Sources:
                                                                 Natural Resources Defense Council, 1999
                                                                 Telephone conversation with Douglas Fritz, 12/1/1999
                                                       D-7

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Improving Construction Inspection Cost-Effectively
   Successful Elements Related to Phase I Program:
   •   New Castle County's erosion and sediment controls reduce sediment in runoff on average of 84 percent.
      Delaware's Certified Construction Reviewer (CCR) program provides for more efficient inspections.
       Because of the flexibility built into the Phase IMS4 storm water permit program, many local communities are
       developing innovative solutions to control storm water discharges. The Delaware Department of Natural Resource
       and Environmental Control (DNREC) Sediment and Storm Water Program illustrates how an aggressive inspection
       program built on privately employed inspectors can limit the water quality impacts of construction. The result is a
win-win situation where the environment is protected, developers have less downtime, DNREC's workload is reasonable,
and local jobs are created. To obtain the mandated construction inspection, developers can hire one of the hundreds of
private inspectors licensed under the State's Certified Construction Reviewer (CCR) program,  first implemented in 1992.
 Location:
 New Castle
 County, Delaware

 Affected Area:
 454.9 square miles
                        In New Castle County, a Phase I permitted county, the CCR program has been a successful
                        component of their overall storm water management program.  The County is currently enjoying
                        economic growth and related commercial and residential development. Approximately 400
                        construction sites per year require development and implementation of a detailed Sediment and
                        Storm Water Plan. Though limited to only three county government inspectors, the county has
                        used the CCR program to leverage greater inspection coverage and increase compliance with
                        Federal, State, and local construction requirements. Of the 400 construction starts, more than 75
                        percent are being inspected by CCRs for at least a portion of the site development. The CCRs
                        inspect active sites weekly and submit a report to the developer/contractor and to the county. By
incorporating CCRs, county staff time once spent on construction site inspections can now be spent on overseeing the private
CCR inspection process.  Through the CCR program, New Castle County is saving approximately $100,000 annually and the
compliance rate with Delaware's Sediment and Storm Water Program requirements has increased.

Studies have shown that E&S construction controls in New Castle County reduce the sediment in runoff an average of 84
percent. For the 400 active construction sites in the county, the 84 percent efficiency equates to 600,000 tons of sediment not
discharged into streams, lakes, and wetlands over the course of these projects. If this captured sediment were placed onto an
area the size of a football field, it would bury the field completely under 400 feet of sediment.

At this time, DNREC is continuing to expand its evolving  CCR program throughout the State. DNREC wants to create a
means by which CCRs can log onto a web site and download their information directly into a DNREC database. Ultimately,
this will enable the State to keep track of the work performed by the CCRs and also will provide a GIS data layer of State
construction sites and inspection locations. The continued goal of the program is to improve the implementation of Sediment
and Storm Water Plan compliance without relying on enforcement penalties to achieve program goals.
                                                            Contact
                                                            Frank Piorko, Environmental Program Manager, Sediment and
                                                            Storm Water Program, State of Delaware, 302 739-4411
                                                            fpiork@dnrec.state.de.us

                                                            Sources.1
                                                            Natural Resource Defense Council, 1999
                                                            
                                                      D-8

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Storm Drain/Sewer Separation:  A Case Study in Small Town Initiative
  Successful Storm Water Control Elements Similar to Those Applied by Phase I Permittees:
  « Eliminating sanitary cross-connections drastically reduces storm water sewer pollutant concentrations.
T
      he city of Dover, New Hampshire, population 26,500, is one of the most urbanized municipalities in the New
      Hampshire coastal region. Although it is not a Phase I permittee, its experience with storm sewer management is
      typical of many Phase I communities.
  Location:
  Dover, NH

  Area:
  28.87 sq mi

  Affected
  Waters:
  Bellamy,
  Chocheco, and
  Piscataqua
  Rivers
                  Dover is adjacent to New Hampshire's Great Bay Estuary and has numerous rivers, including the
                  Bellamy, Chocheco, and Piscataqua rivers. A 1997 report published by the New Hampshire Department
                  of Environmental Services (An Investigation of Water Quality in New Hampshire Estuaries) revealed that
                  bacteria originating from storm drain/sanitary sewer cross-connections in downtown Dover were
                  affecting the bay's  water quality. Faced with this conclusion, the city of Dover took action to eliminate
                  bacteria loads to the city's rivers through storm drain/sewer separation.

                  In a partnership with the New Hampshire Estuaries Project and the NHDES, Dover Community Services
                  Department staff have worked to identify and eliminate storm drain/sanitary sewer cross-connections,
                  focusing on the area that encompasses the downtown center of Dover and the Cochecho River.  Begun in
                  1997, this ongoing  project has involved water quality sampling, smoke testing, and other means to
                  identify cross connections. Frequently, the best indicator of a cross-connection is elevated bacteria levels
                  in dry-weather flows as illustrated in the monitoring results for a single sewer outfall (note the elevated
                  bacteria levels between August and October, 1997 in the graph below).  Dover discovered several storm
                  drain outfalls with high levels of E. coli bacteria, which indicated a direct sewage discharge into the
storm drain system.

Where needed, Dover Community Services has extended its work to investigate individual homes suspected of having a
sewer connection to the storm drainage system. The city on average spends about $3,000 to eliminate a cross connection.
Although the costs of eliminating cross-connections would be the responsibility of the property owner, to obtain timely and
efficient resolution, the city of Dover has absorbed some of the management costs to ensure that the problem is addressed.

Dover's effort is preventing raw wastewater discharges from the storm sewer system that once flowed into the Cochecho
River and eventually into the Great Bay Estuary. To date, monitoring results show declining bacteria counts in the river,
although bay levels are still elevated. However, the magnitude of the post-management reduction at a storm drain outfall is
demonstrated in the 99 percent decline in bacteria counts shown in the graph (as shown by bacteria levels after December,
1997). Other urban areas in the Great Bay watersheds have either documented or suspect cross-connections are their primary
source for high levels of bacteria.  By studying its storm water system and developing a storm water management plan, the
city of Dover has shown itself to be a good a role model for other coastal New Hampshire communities.
         Bacterial Concentrations in Storm Water Drain
                 CRT 1015, Downtown Dover


* - . ~"\

t
inn . .,, . , . 	

— — •» — • Fecal Cfllif orm
• •»- •Biterocpcei


V^^^-rrTTl
           10  	
                                                                            Contact:
                                                                            Dean Pescbel, Environmental Projects Manager 603
                                                                            743-6094
                                                                            Source:
                                                                            1999 National NPDES Program for Storm Water
                                                                            Control Excellence Awards Application
                    10/1197   12/1/97    2/V98
                           Sample Dates
                                                 6J1/9S
                                                      D-9

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 Fort Worth, Texas: Preventing Pollution by Managing Hazardous Household Wastes
   Successful Elements Related to Phase I Program:
   • Annually, 50,000 gallons of toxic liquid wastes are destroyed or recycled and kept out of the environment.
   • Per year household waste drop-offs have increased 54 percent, and after only 2 years of collection center operation 3
     percent of households have used the waste drop-off option.
  Location:
  Fort Worth,
  Texas and
  adjacent
  communities

  Affected Area:
  312,500
  households
  (125,000 in Fort
  Worth)
      To meet the requirements of its Phase I storm water permit, the city of Fort Worth, Texas, has
      moved aggressively to create convenient household waste disposal facilities and to remind its
      residents regularly of the opportunity for disposal and recycling. Working with other nearby
      communities, the Fort Worth Department of Environmental Management started by sponsoring
a series of collection events. The first comprehensive household hazardous waste collection event in
north-central Texas was held in Fort Worth on May 15 and 16,  1993. By the end of the event, more
than 1,500 households had participated, dropping off thousands of pounds of waste. Encouraged by the
response to the first event, Fort Worth continued to hold household waste drop off events for several
years, noting a sustained level of public participation in such events. To better serve its citizens and to
meet its Phase I permit obligations, Ft.  Worth initiated an expanded household waste program, one that
included a permanent and convenient drop off location.
                    The Environmental Collection Center (ECC) opened December 11,1997.  It is the largest drive-
                    through household chemical waste drop-off center in Texas and the first in north-central Texas to be
open year-round. The facility is located on 4 acres in eastern Fort Worth, close to neighboring cities. The city of Fort Worth
uses a regional approach in preventing the improper disposal of household hazardous waste into the storm water system. The
city has negotiated inter-local agreements with 19 customer cities, representing Tarrant, Dallas, and Erath counties. Many of
the participating communities are not subject to the Phase I storm water regulations but will be regulated under the Phase II
program. In total, approximately 1.25 million people (about 312,500 households) reside in the participating cities, and all are
welcome to dispose of their household waste at the ECC.
As shown in the table at right
and the figure below, both the
household participation and
waste collected have increased
dramatically since the start of
the household waste collection
program in 1993. Hundreds of
thousands of pounds of waste,
much of it in liquid form, is
now collected and destroyed.
The Phase I storm water
permit program started Fort
Worth's pollution prevention
efforts, which have kept tons
of waste out of the city's
storm water, landfills, and
wastewater treatment plant.
                Household Waste Collected by Environmental Collection Center (ECC)
Year
1993
1997
1998
Total
Number of
Households
Serviced
1,559
6.011
9.249
Waste Collected
from All Participating
Communities
(Pounds)
180,105
222,000
266,558
Fort Worth
Households
Serviced
1,539
(Unknown)
4,190
Fort Worth
Waste
Collected
(Pounds)
180,105
158,000
185.172
                                                                       Contact/Source:
                                                                       Brian Boemer, City of Fort Worth, Texas
                                                                       BoemeB@ci .fort-worth, tx.us
                                                     D-10

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Information Availability, Education, and Enforcement—Successful Program Elements
  Successful elements Related to Phase I Program:
  •  An effective education and awareness program for both permittees and the public.
  •  Incorporation of erosion and sediment control into the development site planning process.
T
      he city of Garland, Texas, started its erosion and sediment control program in 1993 in response to National Pollutant
      Discharge Elimination System permit requirements. One of the first steps was the publication of a construction best
      management practice (BMP) manual.  Garland's erosion and sediment control (ESC) program requires BMPs on sites
      as small as 5,000 square feet and detailed site plans for all sites of 1 acre or larger. "Implementation of BMPs has
                      definitely improved as a result of this program," says Philip Welsch, Garland's Storm Water
                      Coordinator. "Erosion control on construction sites was basically nonexistent before that time."
                      Eight to ten of the most prominent developers in the area were included in the development of the
                      handbook and program, and this approach seems to have contributed to its acceptance in the
                      community, according to Welsch.
 Location:
 Garland, Texas
 Affected Area:
 57 square
 miles miles
                      Garland, in conjunction with seven other Dallas/Fort Worth area Phase I cities and the North Central
                      Texas Council of Governments, also developed a training curriculum on the Construction General
                      Permit requirements and local erosion and sediment control techniques.  The city then turned the
                      training responsibility over to Texas A & M University, and for a small fee developers and
                      contractors can attend the training. Although Garland does not offer any type of formal incentive
program, developers have discovered it is beneficial when trying to develop approvable site plans or to avoid stop-work
orders. The training continues to be well attended.

Garland also has developed a comprehensive program to monitor developers and contractors and educate them about the
ESC program.  For all sites that will disturb more than 1 acre of land, the city requires a pre-construction meeting before
development may begin. All erosion control requirements and resulting noncompliance enforcement measures are outlined
at that time.  In addition, all city inspectors are trained in erosion and sediment control. For single family homes, the site
must pass an ESC inspection prior to being cleared for any other type of inspection, e.g. electrical, plumbing, framing, etc.
Each commercial site is inspected once a month and the entire project can be stopped for an ESC violation. Although the
enforcement component of the inspection program is critical, each inspection also represents contact between the inspection
staff and a contractor. This therefore serves  as an additional method to heighten awareness of the ESC program in the
development community.

The city of Garland also committed to the addition of a full-time storm water public information specialist in its MS4
NPDES permit, and Welsch attributes much of the storm water program's success to the resulting public awareness and
education program. Approximately 3,000-4,000 schoolchildren are taught about storm water and nonpoint source pollution
each year. Welsch says, he has noticed an increase in calls to Garland's environmental hotline from children reporting their
parents for noncompliance with the storm water regulations.
                                                              Contact:
                                                              Philip Welsch, Storm Water Coordinator, City of Garland.
                                                              Texas, 972 205-2189; pwelsch@ci.garland.tx.us

                                                              Source:
                                                              National Resources Defense Council. 1999
                                                     D-ll

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Urban Runoff Threatens Salmon Fishery; A Case Study in Management Initiatives
  Important Elements:
  • King County has documented the adverse effects of storm water runoff on salmon populations, and millions of
    dollars will be spent to restore habitat lost in urban areas.
  • Storm water management measures are being developed to offset problems caused by existing urbanization and
    prevent problems from new development.
Ki
 Location:
 King
 County,
 WA
       ing County, Washington, a Phase I community, is one of the most populated counties in Washington State and is
       home to the cities of Seattle and Bellevue. For the county, the local environmental impacts of urbanization, related
       to greater storm water runoff and pollutants, were documented in the 1980s.  In a 1984 study comparing the water
       quality of two creeks, the urban Kelsey Creek and the rural Bear Creek, the urban salmon population was found to be
               in significantly poorer health. The study found that high runoff flows originating from developed areas in
               the county scour and alter the shape of the stream channel, causing a reduction in habitat quality and
               dissolved oxygen levels. In addition, urban storm water discharge contains priority pollutants, orgamcs, and
               heavy metals—pollutants that can be traced back to dirt and grime washed from streets during rainfall. The
               impacts of unmanaged storm waters on habitat and salmon populations is of increased importance since two
               of the region's native fish (bull trout and chinook salmon) were placed on the Federal list of threatened
               species in 1999.
 Ana:
 2164.6 sq
 mi

 Affected
 Waters:
 Puget
 Sound
 and its
 tributaries
               In 1995 King County received its NPDES Storm Water Permit. The Phase I program provided the county a
               template to address the multitude of issues surrounding storm water control. As the county's storm water
               program evolves, it is integrating with other environmental efforts focused on preventing new damage to
               stream habitat and restoring streams damaged by storm water. For example, King County has several
               public-oriented programs to change the behavior of homeowners and its all-vohinteer "Stream Team" helps
               with stream protection. As a means of broadening public participation, the county has created a web site
               where citizens can log on and suggest ways to improve storm water quality.

               Additionally, the county is now creating a forest cover requirement that requires a 65 percent retention for
               all new development. Retaining natural cover is an increasingly common BMP for minimizing runoff
               generation, and it is only one of several BMPs that will be standardized in King County to meet this
objective. Within the priority Bear Creek watershed, where urban impacts on salmon were first documented in King County,
the 65 percent forest retention requirement is already employed to help protect the salmon habitat and population. The intent
is to prevent future problems such as those that have led to expensive stream restoration efforts (described below) intended to
return stream habitat lost within King County.

In another effort to prevent pollutants that could affect water quality, in October 1999 the city of Seattle (located in King
County) and King County announced a program to eliminate most of its hazardous pesticide use by June 2000. The goal is to
reduce overall pesticide use on public  lands managed by the city and county. According to King County Executive Ron
Sims, "King County has made a concerted effort to reduce our use of pesticides. We've reduced our use to protect people,
but now we will take the next step and be certain that we're protecting salmon and other species as well. This new policy
will ensure that the parks, roadways, and open spaces that we maintain will be salmon-friendly. We will make the policies
and guidelines  available to other government agencies throughout our region."

King County recognizes the impacts of past urbanization and storm water runoff on stream habitat and the threatened fish
population. As a result, an initiative is under way to create a $2.3 million fund for fish habitat restoration. Plans for specific
projects are currently in development, but the basic  plan is to restore stream habitat along 700 miles of urbanized streams, a
major fraction of the county's 3,000 miles of streams.

King County's future focus is to continue developing management measures
protective of its aquatic habitats and its threatened fisheries. Storm water management
BMPs and program elements will be a major component of this effort, minimizing the
occurrence of new water quality problems and helping to offset problems created
through earlier urbanization. King County can draw on the storm water management
experience/examples offered by numerous other Phase I permittees now establishing
programs to restore and protect local waterways.
                                                                                Contact:
                                                                                James Schroeder, 206296-8381
                                                                                Program Analyst, King County

                                                                                Sources:
                                                                                
                                                                                USER A, 1992
                                                     D-12

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Los Angeles County: Streamlining Monitoring in a Maturing Storm Water Program
  Successful Elements Related to Phase I Program:
  •  As storm water pollutants are identified, a maturing program is streamlining its storm water monitoring to reduce
    costs and optimize program efficiency.
  •  A reduction in point-of-discharge monitoring is anticipated at locations where pollutants have been detected
    infrequently.
P
base I storm water monitoring helps indicate where pollutants contribute to a problem and what pollutants are of
concern.  Storm water quality varies with location because different upstream land areas contribute different types and
amounts of pollutants. With many possible monitoring locations, it is important to streamline monitoring efforts to
learn where and how storm water might affect receiving waterbodies.
 Location;
 Los Angeles
 County,
 California

 Area:
 3,100 square
 miles

 Population:
 9,757,500

 Affected
 Wafers.
 Ballona Creek,
 Malibu Creek,
 Los Angeles
 River, Coyote
 Creek, and San
 Gabriel
             Los Angeles County is currently streamlining its Phase I storm water monitoring to reduce costs and
             optimize fund usage. When its storm water monitoring demonstrates a pollutant is not present at a
             particular location, Los Angeles intends to stop monitoring for that particular pollutant at mat location.
             Having concluded that an anticipated storm water pollutant is, in fact, not present at levels of concern,
             Los Angeles will spend its monitoring dollars on other locations where storm water might be of poorer
             quality.

             The storm water monitoring efforts demonstrate the characteristics common to Phase I permit holders.
             As a monitoring program matures, it evolves from the initial storm water quality characterization to
             assessment of best management practice (BMP) effectiveness. Then it focuses on specific water quality
             problems caused by storm water (Table 1). The Water Quality Assessment for Los Angeles County
             (1996) states that the main pollutants found to cause water quality impairments are certain heavy metals,
             coliform, enteric viruses, pesticides, nutrients, polycyclic aromatic hydrocarbons, trash, debris, algae,
             scum, sediments, and odor. With this understanding, Los Angeles County is now proposing to
             discontinue monitoring where these  pollutants have not been found to pose a threat,  using the time and
             money to monitor elsewhere. As the monitoring program matures, sufficient data will be available to
             focus on where and which storm water pollutants are causing water quality problems. Table 2 shows Los
             Angeles monitoring locations and indicates which specific storm water pollutants are sufficiently
             characterized to allow discontinuation of monitoring at that location.
    Table 1. Phase I Storm Water Monitoring Overview
Period
1990-
1995
1996-
Current
Future
Storm Water Monitoring Objectives
Characterize the storm water quality and
quantity in various locations and for various
land use types
Expand the monitoring program to incorporate
evaluation of BMPs through pilot studies
Streamline and optimize monitoring to
estimate mass loadings and characterize
impacts
                                                                  U.S. EPA Headquarters Library
                                                                         Mat! code 3201
                                                                 1200 Pennsylvania Avenue NW
                                                                     Washington DC  20460
                                                                          Contact-
                                                                          Bill DePoto, L.A. County Public Works Storm
                                                                          Water Quality Section
                                                                          626 458-3537


                                                                          Source:
                                                                          < www.888cleanla.com>.
                                                     0-13

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Notes:
x = constituent that meets
the criterion of less than
25% detection in 10
consecutive samples

d and t = dissolved and total

d only = dissolved only

empty cell = not enough
data to analyze
Table 2. Station-Constituent Combinations Recommended for
              Discontinuation of Monitoring
Station
Analyte
Conventional
Cyanide
TPH
Total Phenols
Metals
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Chromium +6
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Thallium
Pesffc/des
All Pesticides
Chloradane
N-Pesticides
Ballona
Creek
Malibu
Creek

X

X
X
X
X
Los
Angeles
River
Coyote
Creek


X




San
Gabriel



X


dandt
dandt
dandt
dandt
dandt
dandt

dandt
dandt
dandt
dandt
dandt
dand t
dandt
d only
dandt
dandt
dandt
dandt
dandt
dandt
dandt
dandt
d and t
dandt
dandt
dandt
dandt
dandt

dandt
dandt



dandt



d and t

dandt
dandt
dandt


X
X
X
X
X
X
X
X

dandt
dandt
dandt
dandt
dandt
dandt

d and t
d only
dandt
dandt
dandt
dandt
dandt

dandt
dandt
dandt
dandt
dandt
dandt

dandt
d only
dandt
dandt
dandt
dandt
dandt

X
X
X
X
X
X
                                             D-14

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Lake Harriet:  A Public Outreach Success Story
  Successful Elements Similar to Those in the Phase I Program:
  • The city of Minneapolis created the widely supported Lawn Care Program to address water quality problems from
    storm water.
  • Lake Harriet has undergone a reduction in pesticide pollutant levels by 60 percent since the Lawn Care Program
    started.
  « The environmental benefits are enjoyed by the estimated 2.4 million people who visit Lake Harriet each year.
  Location:
  Minneapolis,
  Minnesota

  Affected
  Area:
  Lake Harriet

  Number of
  People
  Served by
  Permit:
  368,384
T   <
J—/2
                          ake Harriet is located within the city limits of Minneapolis, a city whose Phase I storm water
                          program is under development.  The lake covers 300 acres and is fed by a watershed containing
                         f about 6,000 homeowners. In the early 1990s the poor water quality in Lake Harriet was obvious
                          to both visitors and the residents of the watershed. Minneapolis began a comprehensive study of
                    Lake Harriet to identify the pollutants entering the lake. Storm water monitoring helped to identify that
                    the majority of the pollutants came from local homeowners' lawn care practices. As a result of the
                    study's conclusions, an intensive outreach program was started.  The Minnesota Pollution Control
                    Agency contributed two grants to support storm water program development. The project goals were
                    (1) to increase public awareness of the connection between lawn care practices and the protection of
                    water quality and (2) to encourage lawn care practices protective of lake water quality.

                    Leading the outreach program were the Minneapolis Parks & Recreation Board, the Minnesota
                    Department of Agriculture, and the Hennepin County branch of the University of Minnesota Extension
                    Service. These organizations  developed a hands-on outreach program using master gardeners, direct
                    mailing of information packets, and newspaper publications. The master gardeners contributed more
than 1,200 hours of volunteer time in training, water quality data collection, distribution of information packages, and
general project assistance during the life of the Lake Harriet project.

As a result of outreach efforts, a 30 percent change in lawn-care behavior was recorded. By 1995 this change in behavior,
surveyed over time, had also resulted in a significant 50 percent reduction of pesticide.  During the 1995 growing season,
only 22.3 grams (less than 1 ounce) of lawn weed pesticides entered Lake Harriet via the monitored storm sewer. The
outreach program has decreased pesticide inputs into Lake Harriet by an average of 60 percent (see table). According to
Gene Hugoson of the Minnesota Department of Agriculture, "Lake Harriet homeowners are to be commended for their
efforts to improve water quality." Building on the success, the city of Minneapolis has chosen to expand the outreach effort
to the other watersheds within the city limits.

Minneapolis's Phase I permit process is under way.  As its storm water control efforts expand under Phase I, Minneapolis can
build on the success of the Lawn Care Program to help ensure its storm water is not adversely affecting its waterways.
     Water Quality Monitoring Results, Showing Pesticide
                       Reductions
Pesticide
Dicamba
2.4-D
MCPP
MCPA
Annual Event Mean Concentration

                                                                        Natural Resources Defense Council. 1999
Source: NRDC, 1999
                                                      D-15

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 Montgomery County: Biomonitoring Helps Measure Storm Water Management Success
  Successful Elements Related to Phase I Program:
  • A 5-year commitment to biomonitoring is already providing crucial storm water management information
  • Three designated Special Protection Areas have been established to protect high priority streams.
  • BMPs have kept a significant portion of sediment and nitrogen from entering streams. The County has estimated
    that in 1998 23 percent of the sediment load and 27 percent of the nitrogen load was prevented from entering
    streams because of stormwater BMPs.
M
         kontgomery County, in the Washington, DC, area has experienced rapid growth and development, accommodating
         a surge in population that started in the 1940s. In the past, extensive clearing of forests and conversion of
                            agricultural land to residential and commercial development led to excessive soil erosion,
                            nutrient loading, and hydraulic alteration of streams.  Montgomery County recognized early
                            that biomonitoring under its Phase I storm water permit could serve as a true indicator of
                            water quality conditions. The quantity and species diversity of insects and fish in streams,
                            along with habitat conditions, indicate the overall health of the streams more throughly than
                            chemical quality measurements alone.  Accordingly, Montgomery County is serving as a
                            national example of how to design and conduct comprehensive biological monitoring to
                            measure and track stream conditions.  In 2001 die County will complete a 5-year biological
                            monitoring plan that will measure biological conditions in all 1,500 stream miles in the
                            County.
  Location:
  Montgomery County. MD

  Area:
  497 square miles
  1,500 stream miles
  Population: 846.000

  Affected Waters:
  Potomac River
  Patuxent River
  Anacostia River
  Monocacy River
                            Biological monitoring in conjunction with a state-of-the-art geographic information system
                            (CIS) has helped the County map, assess, and rank each of the 22 subwatershcds in the
                            County.  The land use assessment and maps are presented in the Countywide Stream
                            Protection Strategy, which is provided on the County's web site at
                            http://wwwxo.mo.md.us/dep/Watersheds/csps/csps.htrnl.  This interactive report helps to
                            explain the County's monitoring effort and program results. Stream erosion and
                            sedimentation were the dominant impacts on habitat conditions and aquatic life found in
Montgomery County's streams. These impacts originate primarily from uncontrolled or inadequately controlled storm water
from developed areas, which significantly altered natural stream flows. In addition, inadequate control of sediment from
construction sites has also caused problem "hot spots." The monitoring and CIS have helped the County develop a set of
                                                                management tools to address the stream conditions
                                                                and levels of development anticipated. The
                                                                management categories and tools provide a basis
                                                                for targeting interagency resources to address
                                                                stream quality problems, using a focused,
                                                                watershed-based approach.

                                                                The County has estimated mat in 1998 23 percent
                                                                of the sediment load and 27 percent of the nitrogen
                                                                load  was prevented from entering streams because
                                                                of stormwater BMPs.  Annual assessments show
                                                                that total delivered loads increased slightly between
                                                                1997 and 1998 because no BMP can totally control
                                                                the increase of pollutants associated with the
                                                                increased imperviousness as an area is developed.
                                                                However, based on the successes reported in the
                                                                Countywide Stream Protection Strategy, the County
                                                                has increased its 6-year budget for building storm
                                                                water BMPs and restoring stream habitats from  $15
million to $20 million. In addition, the County has committed more than $13  million since 1996 to purchase 350 areas of
stream buffers to protect stream conditions.  Approximately $17 million will be expended to purchase stream buffers.

Three designated Special Protection Areas (SPAs) in the County receive additional protection from storm water impacts.
These areas were selected because of the high-quality stream conditions.  New development planned within each of these
areas is required to measure pre-development water quality and stream conditions as well as to  monitor during and after
                                                     D-16

-------
construction. New County regulations protecting streams tn these SPAs from construction and storm water impacts were
implemented in 1996. Additional monitoring over time will be needed to evaluate the effectiveness of the BMPs in these
SPAs.
                                                               Contact-
                                                               Cameron Wiegand, Chief,
                                                               Watershed Management Division
                                                               240 777-7736
                                                               
                                                       D-17

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Monterey Bay: An Effective Small City Monitoring Program
   Successful Elements Relate to Phase I Program:
   • Phase I serves as a template for effective storm water monitoring for small communities.
   • Outreach focusing on restaurant owners has reduced pollution in storm water.
   * Volunteers contribute to crucial water monitoring efforts.
T
      he Monterey Bay National Marine Sanctuary in California is one of the most diverse marine environments in the
      United States.  The sanctuary is a popular destination for divers, and the coastline continues to attract residential and
      light industrial development. Because of the impending NPDES Phase II storm water program and increased
                      impervious surface area throughout the Monterey Bay region, the city of Monterey created an
                      approach similar to the NPDES Phase I program to address its storm water issues. The city of
                      Monterey is currently working with the city of Santa Cruz, Monterey Bay National Marine
                      Sanctuary, California Coastal Commission, Association of Monterey Bay  Governments, and a
                      consulting firm to develop a Model Urban Runoff Program designed for small municipalities (under
                      100,000 in population). This program is funded by grants from the Clean Water Act Section 319(h)
                      program. The program uses the "Urban Watch" monitoring method associated with the Phase I dry-
                      weather sampling program of Fort Worth, Texas.  The program also incorporates the six minimum
                      control measures for the NPDES Phase II storm water program to form a comprehensive, consistent
                      program. One of the six control measures under the Phase II  storm water  permit program is
                      detection and elimination of illicit discharges.
   Location:
   Monterey,
   California

   Area:
   7.6 square miles
   Affected Area:
   Monterey Bay
   National Marine
   Sanctuary
                      The program incorporates nine trained volunteers for the collection of dry-weather water samples at
                      four priority storm water outfalls. The dry-weather monitoring period is from June through October.
                      The volunteers contribute, on average, an estimated  1,500 hours a year to monitor for dry-weather
discharges. The volunteers work on a 12-  to 14-day schedule, collecting two samples from a site within a 24-hour period
(NRDC, 1999). The monitoring information gathered by the volunteers can help to pinpoint areas of environmental threats.

An example of the successful volunteer monitoring program is related to data that showed an increased amount of detergents,
oily sheens, odors, trash, and surface scum coming from the area's local restaurants. These pollutants were determined to be
entering the city's storm drains when restaurant staff washed off kitchen mats and other kitchen items. This information
provided city officials an area on which to focus their outreach efforts. As a result, there was a recorded change in restaurant
staff behavior that produced a reduction in the amount of pollutants entering the water.  In conjunction with this
environmental benefit, the volunteer monitoring program has saved the city of Monterey a considerable amount of money
(see box).
      Savings Realized Irani Urban Watch Program

 The city of Monterey has saved an estimated $30,000 to
 $40,000 in monitoring costs by relying on voJunteeis.

 The cost of volunteer training, monitoring and analysis, data
 analysis, presentations, and program administration is
 around $8,000 plus an additional $500 for startup
 equipment.
                                                                       Contact
                                                                       Sus Danner. Coastal Watershed Council
                                                                       831426-9012

                                                                       Jennifer Hays, Assistant Civil Engineer, Monterey,
                                                                       (831)646-3920

                                                                       Sources:
                                                                       Natural Resource Defense Council, 1999
                                                                       <\vww.rnonterey.org/water/wtrmgrnt.html>
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Enhancing North Carolina's Existing Sediment and Erosion Control  Programs Through
NPDES Construction Storm Water Program
  Successful Elements:
  • Enforcement and compliance tools to strengthen existing State sediment and erosion control program.
  • Leveraged with other water quality protection programs, provides more comprehensive environmental protection.
  • Goes beyond control of sediment in storm water runoff at construction sites.
  « Enhances use of low cost pollution prevention activities.
S
ediment and erosion control have been under way in North Carolina at the State and local levels since long before the
advent of the Phase I NPDES Storm Water Construction program. So isn't the Phase I Program an unnecessary layer
of construction storm water requirements? Not according to the North Carolina Department of Environment and
Natural Resources (NCDENR), which has had a sediment control program in place since 1973. Recent enforcement
                  actions against developers in North Carolina illustrate how the Phase I program enhances the
                  State's existing Sediment  Control Program to create a comprehensive and effective water quality
                  protection program.
  Location:
  Brunswick County,
  North Carolina

  Area:
  856 square miles

  Waters
  Affected:
  Cape Fear River
                  In North Carolina, sedimentation is the largest water pollutant by volume. The State requires
                  effective erosion and sediment controls to prevent inhibition of plant growth, disruption offish
                  nests, and the introduction of toxic substances into the water. An NCDENR report entitled
                  Crabtree Creek Watershed Earth Day Initiative for Sedimentation Control, May, 1998 highlights
                  the rationale for and importance of controlling storm water runoff from construction sites. Points
                  raised in this report are provided in the box below.

                  Within NCDENR, the Division of Land Resources (DLR) is responsible for administering the
                  Sedimentation Control Program and the Division of Water Quality (DWQ) is responsible for
                  administering the NPDES Construction Storm Water Program. The North Carolina Sedimentation
                  Control Program regulates construction activities equal to or greater than 1 acre, more restrictive
                  than the Phase I program which addresses only sites equal to or greater than 5 acres. Under the
                                                       Sedimentation Control Program, construction site
                                                       operators must develop and submit an erosion control
                                                       plan and submit it to the DLR. When DLR approves
                                                       erosion control plans  for construction sites greater than
                                                       5 acres, it sends the construction site operator a copy of
                                                       North Carolina's NPDES construction general permit
                                                       in addition to an approval letter.
  Points Raised in the Crabtree Creek Watershed Report
      As a community grows, development begins to encroach
      on the more environmentally sensitive or critical areas
      once the more desirable sites are occupied. Increased
      property values that usually accompany such growth tend
      to encourage overbuilding, resulting in tougher erosion
      and sedimentation problems and a potential for serious
      damage.
  •   When sedimentation damage occurs, it fills streams and
      lakes,  increasing the potential for and frequency of
      flooding, the costs associated with water treatment and
      power generation, and the destruction of wildlife habitats.
      Harmful chemicals and other pollutants are often
      transported to waters in the soils deposited as a result of
      accelerated erosion and sedimentation.
      Erosion and sedimentation damage impacts land resources
      and quality of life, removing productive topsoil  that
      cannot be replaced for generations and ultimately
      reducing property values. It also reduces the attractiveness
      of North Carolina for its citizens and visitors.
  • '  Erosion often increases the cost of construction  by
      requiring regrading of gullies and unplugging of storm
      drains.
                                                       Although NCDENR staff admit that coordinating the
                                                       two programs isn't always easy, they acknowledge that
                                                       having the Phase I program in conjunction with the
                                                       State Sedimentation Control Program is ultimately
                                                       beneficial. The Phase I program has helped to open
                                                       the lines of communication between DWQ and DLR.
                                                       According to Joanne Steenhuis of DWQ, "Historically
                                                       the Departments of Water Quality and Land Resources
                                                       have had limited interaction, despite the fact the
                                                       departments have similar goals regarding construction
                                                       site runoff control. The construction general permit
                                                       required under the Phase I program has been a
                                                       mechanism to bring different environmental programs
                                                       together."

                                                       In addition to improving communications within the
                                                       NCDENR, the Phase I Construction Storm Water
                                                       Program also provides a stronger incentive for
                                                       compliance with both programs. Penalties assessed
                                                       under the Sedimentation Control Program are $5.000
                                                    D-19

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 per violation per day. whereas penalties under Phase I can be as high as $25.000 per violation per day. The two departments
 recently joined forces to stop poorly managed construction activities in a portion of Brunswick County, North Carolina.
 Ditching activities had resulted in the  improper drainage of nearly 1,500 acres of wetlands.  Through inspections, DLR and
 DWA determined that the developers  had not prevented off-site sedimentation from ditching activities.  As a result, the
 ditching activities not only had resulted in a loss of wetlands but also had caused exceedances of the turbidity standard in
 Beaverdam Creek, a designated primary nursery area classified as high quality waters. A settlement reached between DWQ,
 DLR, and the developers included the restoration of the drained wetlands and 5213,000 in fines and enforcement costs.

 The Brunswick County situation in North Carolina illustrates how the Phase I program is an important component of an
 overall suite of water quality protection programs. In this situation,  the Phase I requirements not only played a key role in
 controlling sediment-laden runoff, but also assisted in the restoration and protection of valuable wetland resources. "The
 construction general permits we issue  under the Phase I construction program are an important piece to a comprehensive
 construction storm water control program," states Bradley Bennett, the supervisor of the storm water unit within DWQ.  "The
 Sedimentation Control Program focuses on the primary pollutant from construction sites, but does not address the other
 possible pollutants that could originate from construction equipment and other activities on  site.  Under the provisions of the
 construction general permit, construction site  operators must also think about good housekeeping practices to prevent
 contaminating runoff with fuels, lubricants, pesticides, and other related materials."

North Carolina is committed to effectively addressing its water quality problems related to sedimentation and erosion. In
 1997 Governor Hunt proposed 52.1  million for inspectors as a way to expand and enhance the State sediment control
program requirements, increase technical training and assistance, and strengthen enforcement practices. Due to the
interconnectedness of the State sediment control program, the effectiveness of the Phase I program is likely to increase.
                                                         Contact'
                                                         Bradley Bennett
                                                         Storm Water Unit. NPDES Unit
                                                         North Carolina Department of Environment and Natural Resources
                                                         919733-5083

                                                         Sources:
                                                         Sedimentation Sweep Uncovers 79 Problem Sites, NCDENR, May 1998
                                                         Brunswick County Developers Agree to Restore 1,500 seres. Pay 1213,000
                                                         in Fines and Enforcement Costs, NCDENR, December, 28,1999
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Detecting and Eliminating Improper or Illegal Connections and Discharges
in Palo Alto, California
  Successful Elements for the Phase I Program:
  • Positive incentives, regular inspections, and helpful outreach are the key elements of Palo Alto's efforts to reduce
    storm water contaminant loadings from vehicle service facilities.
  • From 1993 to 1996 storm water discharge quality improved: average copper concentrations dropped 89 percent,
    average lead concentrations dropped 96 percent, average nickel concentrations decreased by 93 percent, and average
    zinc levels dropped 77 percent.
A
       s part of the effort to reduce pollution from vehicle service facilities, Palo Alto's Regional Water Quality Control
       Plant (RWQCP) developed a Clean Bay Business Program to recognize vehicle service facilities that proactively
       reduce the discharge of pollutants to sewers and storm drains. The sewer-use ordinance applicable to the plant's
                           service area prescribes 15 best management practices (BMPs) to control flow into the plant's
                           wastewater and storm water systems. Some of the required storm water BMPs include
                           eliminating discharges or disposal to storm drains, performing oil changes and other vehicle
                           fluid removal over secondary containment, immediate cleanup of spills using non-water-using
                           procedures,  containment of leaking fluids, containment of wastewater from vehicle washing,
                           annual employee training, and stenciling of storm drains.
   Location:
   Palo Alto, California
   Number of People
   Served by Permit:
   236,000 (service area)
   Affected Area:
   24 square miles (city)
                          The combination of ordinance requirements and annual inspection visits has resulted in
                          dramatic behavioral changes at vehicle service facilities, hi 1992 only 4 percent of the 318
                          facilities inspected complied with all 15 requirements. In 1998 inspectors found 94 percent of
                          289 facilities to be in compliance after the first or follow-up inspection.  Facilities eliminated 78
                          direct discharges to storm drains by ceasing or modifying vehicle washing activities, ending
parking lot cleaning and outdoor wet standing of vehicles, and making other changes. Violations of requirements that protect
storm drains fell by 90 percent from 1992 through 1995.

Since 1992 average metal concentrations in storm water discharges from vehicle service facilities have dropped considerably.
Average copper concentrations are down 89 percent to 0.32 mg/L (compared to a local limit of 2.00 mg/L established by
Palo Alto under EPA pretreatment regulations).  Lead levels are down 96 percent to 0.14 mg/L (local limit of 0.50 mg/L).
Nickel concentrations have decreased by 93 percent to 0.07 mg/L (local limit of 0.50 mg/L). And zinc levek are down 77
percent from the high in 1993 to 1.55 mg/L and are below the local limit (2.00 mg/L).  In 1996 average discharge
concentrations from permitted facilities were a fraction of the local limits for all heavy metals, except zinc. Zinc
concentrations increased in 1995 and 1996 as a result of more auto body shops and fleet operations receiving permits for
vehicle washing activities. The sample results revealed two facilities with significant discharges of zinc (an order of
magnitude above the local limit).
Average Metal Concentrations from Permitted
Vehicle Service Facilities
Parameter
Copper
Lead
Nickel
Zinc
1993
(mg/L)
2.98
3.74
1.07
6.69
1994
(mg/L)
0.36
0.29
0.08
0.9)
1995
(mg/L)
0.57
0.32
0.12
1.27
1996
(mg/L)
0.32
0.14
0.07
1.55
Local
Limit
(mg/L)
2.00
0.50
0.50
2.00
Source: City of Palo Alto web page:
hrtp:'/w\vw.city.pa!o-alto.ca.us/cleanbay/autoprog.pdf
                                                                 The significant decrease recorded from 1993 to 1996
                                                                 is a direct result of Palo Alto's pollution prevention
                                                                 efforts and increased maintenance of treatment
                                                                 systems. The city's continued storm water
                                                                 management efforts have received national
                                                                 recognition through six storm water awards since
                                                                 1996.
                                                      D-21

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Preserving A Community's Quality of Life Using the NPDES Construction
Storm Water Program
  Successful Elements:
  •  Minimizes threat to economically important wetlands and fish habitat by ensuring responsible development practices.
  •  Successful implementation of the construction storm water pollution prevention plan reduces violations of water
    quality standard for turbidity.
T
he siting and development of the Stafford Creek Corrections Center in Grays Harbor County, Washington, did not
come about without controversy.  The mixed emotions from County residents stemmed of conflict between the desire
              for economic development and the concerns about degrading the Grays Harbor Estuary, a waterbody
              currently listed as impaired on EPA's 303(d) list of impaired waters.  Construction of the facility
              requires disturbing approximately 210 acres along Stafford Creek, a tributary of the Grays Harbor
              Estuary that drains 1,100 acres and contains valuable salmon and oyster habitat as well as wetland
              resources. Although local supporters of the facility recognized the potential negative impacts on the
              aquaculture industry derived from the Grays Harbor Estuary, they felt it was important to find a way to
              bring at least 650 additional jobs into the area.
  Location:
  Grays Harbor
  County,
  Washington
  Area:
  1918 square
  miles

  Affected
  Waters:
  Stafford Creek
  and other
  tributaries of the
  Grays Harbor
             Federal, State, and local stakeholders involved in the Stafford Creek Corrections Center proposal
             worked together to see that both economic development and environmental protection in Grays Harbor
             County would be possible. The storm water construction permit, as required by the Phase I program,
             provided a mechanism to ensure that the development of the facility would not threaten the nearby
             wetlands and salmon habitat of Stafford Creek and other surrounding water bodies. The most
             important requirement of this permit is the development and implementation of a storm water pollution
             prevention plan (SWPPP). Although the Washington Department of Ecology does not typically review
             and approve SWPPPs, it can request to review a SWPPP for projects that may pose a significant water
             quality concern. The Department of Ecology worked with the Department of Corrections (DOC) for
             nearly 18 months to  develop a SWPPP that would, when implemented, successfully control sediment-
             laden runoff from the construction site.
                    A SWPPP for construction activities, according to the Guidance Document for Applying for Ecology's
General Permit to Discharge Stormwater Associated with Construction Activity, must be implemented when soil-disturbing
activity commences and must be updated and maintained throughout the entire life of the construction project. Components
of an SWPPP include an erosion and sediment control (ESC) plan and a spill prevention and emergency cleanup plan. The
ESC plan is the focus of the SWPPP.  It must describe stabilization best management practices (BMPs) and structural BMPs
intended to divert flows from exposed soils, store flows, or otherwise limit runoff and pollutants from exposed areas of the
site. The Department of Ecology finally issued DOC a construction storm water permit based on the strength of the SWPPP,
which contained additional protective measures, including the following:

    Terminate all construction activities for the winter by October, in accordance with the Puget Sound Storm Water
    Manual.
    Conduct daily sampling and monitoring around the site to determine if there are exceedances of the turbidity water
    quality standard (5 Ntu).
    Provide the Department of Ecology with a written report
    documenting exceedances within 5 days of detection.
    Stop work if an exceedance is detected,and do not resume work
    until the problem has been identified and corrected.
Without implementation, an SWPPP is nothing but a document. It is
effective only if properly implemented, continually assessed, and
appropriately modified to improve BMP performance. Under the
Phase I program, development and implementation of an SWPPP are
enforceable permit conditions. In the case of DOC, it demonstrated
partial compliance with its permit by developing an SWPPP.
However, DOC violated its permit, thereby breaking its commitment
to the protection of Grays Harbor Estuary, when it failed to implement all of the conditions contained in its SWPPP.
                                                           Contact:
                                                           Ken Torke, Associate Engineer. Regional Water Quality
                                                           Control Plant, 650-329-2421
                                                           Sources:
                                                           Natural Resources Defense Council, 1999
                                                           City of Palo Alto web page:
                                                           http://www.city.pa1o-alto.ca.us/cleanbay/publications.htm
                                                     D-22

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Construction of the Stafford Creek Corrections Center began in June  1998. and storm water runoff problems started with
Washington's rainy season in the fall.  Beginning in October 1998, DOC reported exceedances of the turbidity water quality
standard.  Inspections conducted by the Department of Ecology between November 1998 and February 1999 revealed that
DOC was not fuHy implementing its SWPPP.  Construction activities had continued beyond October and into the winter to
meet the scheduled opening date of the facility. Some of the BMPs described in the SWPPP either were not in place on-site
or were not receiving proper maintenance. As a result of improper storm water control activities, a slope failure occurred
that covered 0.2 of an acre of nearby wetlands. Monitoring and reporting during this period, conducted by both DOC and
local college students, illustrated both the frequency and magnitude of violations. By February 1999, DOC had reported 62
violations in varying degrees. Subsequently, the Department of Ecology issued an order and penalty due to permit violation
                                                                           and State water quality standards.
Monthly Exceedances of the Water Quality Standard for Turbidity
Reported to the Washington Department of Ecology by the
Washington Department of Corrections
Month
(1998 - 1999)
November
December
January
February
March
(SWPPP fully implemented and
turbidity problems addressed)
April
Number of Exceedances Reported
14
15
11
22
0
0

                                                                            DOC invested a significant amount of
                                                                            time and money into addressing problems
                                                                            on its site and implementing its SWPPP.
                                                                            "DOC claims to have invested
                                                                            approximately $850,000 into cleaning up
                                                                            the site and implementing their BMPs.
                                                                            Although I can't say for sure, DOC may
                                                                            not have had to spend that amount on
                                                                            storm water controls and site cleanup if
                                                                            they had implemented their SWPPP at the
                                                                            outset of the construction project," stated
                                                                            Janet Boyd, the Department of Ecology
                                                                            enforcement officer and inspector
                                                                            working on the Stafford Creek
                                                                            Corrections Facility site. According to
                                                                            monitoring and reporting data, DOC's
                                                                            investment paid off in improved storm
                                                                            water quality.  As shown in the table at
                                                                            left, DOC reported more than 10
                                                                            exceedances each month to the
                                                                            Department of Ecology between  •
                                                                            November 1998 and February  1999.
DOC did not report any exceedances between March and April, 1999, once construction workers had fully implemented the
SWPPP and addressed problems on-site.

Ecology fined DOC $44,000 for violations of its storm water permit. "The Stafford Creek Corrections Facility has been a
challenge, and the local creeks have probably suffered as a result of the lack of adequate sediment and erosion controls at this
site," admits Janet Boyd.  "But I would hate to think what the site might have been like if DOC did not take responsibility for
their actions, or if Ecology didn't have the ability through the NPDES Storm Water Program to inspect the site, provide
technical assistance, and exact fines to bring DOC into compliance."
  Contact:
  Janet Boyd
  Washington Department of Ecology
  Southwest Regional Office
  300 Desmond Drive, SE
  Olympia, WA 98504-7775
  Phone 360 407-6300
  Fax: 360 407-6305


  Sources:
  Janet Boyd. personal conversations 1/4/00 and 1/10/00.
  Wilkins. David. Environmental Battle Over Prison Heats up Again. The Daily World Archives, May 1, 1999.
  FOGH Grays Harbor Estuary Legislative Priorities. .
  Washington Department of Ecology. 1999. Department of Corrections fined for stormwater runoff from Stafford Cntek Prison.  Washington
  Department of Ecology News Release. April 30, 1999. .
  Guidance Document for Applying for Ecology's General Permit to Discharge Storrrmater Associated with Construction Activity. Washington
                                                       D-23

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Prince George's County: GIS Helps Evaluate Load Reductions and LID Promises
Problem Avoidance
  Successful Elements:
  *  GIS helps to target watersheds for restoration and provide support for restoration efforts.
  *  Modeling tools developed under Phase I storm water permit provide better estimates of pollutant loads.
  •  Low-Impact Development techniques provide localized, tailored BMPs to control storm water runoff.
P
     rince George's County, Maryland, is located in the Washington, DC, metropolitan area and shares the Anacostia River
     with the District. The Anacostia is a mature, highly urbanized river with many of the problems typical of
                   urbanization—pollution, economic stagnation, and long-term degradation. This river has often been
                   considered the Washington, DC, metropolitan area's "forgotten" river. The Anacostia River watershed
 Location:        has become the site of one of the first large-scale watershed restoration activities in the Nation.
 Prince George's     Communities and organizations all along the river have become engaged in efforts to enhance its
 County, MD        environmental quality, rebuild its economic vitality, and reconnect the people to the river.
  Area:
  488 square miles

  Population:
  792,030

  Affected
  Waters:
  Potomac River
  Patuxent River
                   Prince George's County has been recognized as a leader nationally in watershed management. Key
                   factors to the success in the past have been the commitment of County staff and the development and
                   delivery of assessment tools including, GIS data, models, and technical support Prince George's
                   County has developed a GIS primarily under the Stormwater Phase I program that not only supports
                   the County's planning and management activities but also is designed for use by the public in
                   conducting daily business with the County. The GIS and related models have received national awards
                   such as the 1993 Public Technology, Inc., Special Mention Award in the Environmental Services
                   category; the 1995 Urban and Regional Information Systems Association Exemplary System in
                   Government Award; and the 1996 National Association of Counties Achievement Award in the
                   Information Technology category.

                   GIS applications that have been developed under the stormwater program include the following:

*   Geo-Storm: CIS-Based Hydrology and Hydraulic Analysis. Using this model users can compute runoff from
    watershed units, route through reach and reservoir networks, and analyze river hydraulics.

•   Watershed Planning System (WPS): A  GIS-based water quality modeling system,  WPS was developed to support the
    County's initiatives in evaluating water quality conditions, perform preliminary prioritization and targeting of
    watersheds, and develop planning-level  watershed management plans by integrating the EPA-supported Storm Water
    Management Model (SWMM) with the County GIS. The Commercial and Industrial module includes several utilities
    designed to assist in management of storm water from commercial and industrial facilities; to retrieve and display
    facilities based on their location, SIC code, address, and watershed; and thereby to develop targeted pollution prevention
    plans.

•   Hydrological Simulation Program-Fortran (HSPF): The County's water quality module simulates continuously the
    hydrology and associated water quality pollutant loadings.

    On-Site Septic CIS-Based System Assessment: SEPTIC is  a software package that includes a pollutant fate and
    transport model integrated with the GIS to evaluate the long-term impacts of nitrogen loading from septic systems in
    non-sewered areas of the County. The system allows users to easily set up a management scenario and view the impact
    on surface water as derived by the model.

    Public Storm-Drain The Storm Drain Inventory offers enhanced visual capabilities to locate any public storm drain
    pipe in Prince George's County. The inventory of pipes, inlets, and manholes is  depicted geographically for the public
    to query by location and/or permit number. This inventory  is a valuable tool for developers, engineers, and the members
    of the public who have the need to know the location of existing infrastructure for possible extension of new lines or
    Connection to existing ones.

 Prince George's County has recognized that traditional storm water management has its limitations. The traditional approach
 results in the creation of an extremely efficient storm water runoff conveyance system.  Every feature of a development site
 is carefully designed to quickly convey runoff to a centrally located management device.  As a result, the magnitude of
 hydrologic changes is amplified as natural storage is lost, the amount of impervious surface is increased, and runoff travel
                                                     D-24

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times arc decreased.  Prince George's County has led in the development of a new site design process to control storm water
runoff, Low-Impact Development (LID).  The principal goal of LID is to ensure maximum protection of the ecological
integrity of the streams by maintaining the watershed's hydrologic regime. LID allows the site planner/developer to use a
wide array of simple, cost-effective techniques that focus on site-level hydrologic control. With support from EPA, the
County has developed a national LID manual to help explain the concepts and applications to other areas of the country so
that storm water impacts can be minimized.
                           TbOOf
                                               • Limit of Dtsturtoincc
       Grand cow
       or mulch taytf

                                ShMtflM
                                Hsu viw (not to tcali)
                  0.2 feet Inxti
                  ponding otptn
          Gnu filter  «•«••• ««P»i (Sue*.
  SpwHtow  52**x   to plant soil torture) :
     Limit of
     pavement
                                            Groimd co«w
                                            or muldi layw
                                                           - 5' min.
                             -Planting soil-
                                                         SrOQ«
                            - Branuntion area -
                            IN-SItU Mattnal
                          - SaturrtedPtrmubilrty	
                                Section A-A (not to scale)
                                                                      Contact:
                                                                      Larry Coffman, Director, Planning and Programs Division,
                                                                      Dept. of Environmental Resources
                                                                      301 883-5839
                                                           D-25

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Portland, Oregon: Redirecting a Storm Water Policy
   Successful Elements Related to Phase I Program:
   • Compliance with storm water pollution control plans has more than doubled from 41 percent to 87 percent.
   Portland has estimated reductions in pollution discharges due to its Phase I program for four source
   categories—illicit connections, washwater discharges, accidental spills, and erosion/sedimentation problems.
      Portland's Phase I storm water permit resulted in a significant change in the city's storm water program, once focused
      only on flood prevention. Responding to the Phase I requirements, Portland redirected its storm water policy to
      emphasize citizen involvement, water quality partnerships, and environmental leadership. A key component of its
      program is identifying and eliminating illicit connections and discharges. Portland's Illicit Discharge Elimination
Program (IDEP) currently monitors between 90 and 100 storm water priority outfalls for illicit dry-weather discharges. The
more sensitive the receiving water or the greater the potential for polluted discharge, the more frequent the monitoring. When
an illicit discharge is detected, additional monitoring and tracking are performed to pinpoint the source. Information on
sources identified is forwarded to experts in the city, who then work with the dischargers to end the illicit discharges to the
storm sewer system.
  Location:
  Portland,
  Oregon

  Ana:
  3,743 square
  miles

  Population:
  1,700,000
                  Through its Industrial Education and Permitting Program (IEPP), Portland has also established internal
                  and regional pollution prevention outreach teams to provide technical assistance to the city's permitted
                  industries, as well as an incentive program to reward environmental achievements by industries.
                  Portland's efforts have greatly increased performance: industrial compliance with storm water
                  requirements has jumped from 41 to 87 percent and violations are now found in 23 percent of
                  inspections, down from 30 percent. The city of Portland has also sought to prevent improper discharges
                  from all of its bureaus (e.g., Water and Fire Departments, Park Bureau). Guided by the Bureau of
                  Environmental Services, the city has implemented BMPs at the Fire Department's training facilities to
                  prevent pollutant generation and migration. The city's Park Bureau has developed dechiorination
                  procedures for maintenance operations at the city's public pools. The chlorinated water of public pools is
                  often a source of dry-weather discharge pollution, and dechlonnating the water eliminates a potential
                  threat to storm water quality and local fisheries. Portland has estimated reductions in pollution
                  discharges due to its Phase I program for four source categories—illicit connections, washwater
discharges, accidental spills, and erosion/sedimentation problems.

A survey of businesses and citizens in the city indicates an increasing understanding and knowledge of storm water quality
and a willingness to change behavior to protect water quality. Additional accomplishments since the start of the Phase  I
program include the planting of more than 22,000 trees within the city limits. More than 500 property owners have
voluntarily disconnected their downspouts from their roof drains to divert the water onto the lawns instead of to storm drains.
                                                                      With 60 percent voter approval, Portland has
        Estimated Annual Loads Removed by IDEP (for the Year 1996)         established a $ 135.6 million bond measure to
                                                                      acquire up to 6,000 acres of land to better
                                                                      manage  sensitive watersheds and protect urban
                                                                      waterways. In addition, Portland has adopted
                                                                      more stringent regulations on development
                                                                      aimed at protecting floodplains and
                                                                      establishing erosion and sediment controls for
                                                                      all development

                                                                      Portland maintains that it is difficult to fully
                                                                      quantify a pollutant reduction from the IDEP
                                                                      and IEPP and to assess water quality
                                                                      improvements. But it believes it is on the right
                                                                      path toward making  a difference in the area's
                                                                      water quality.
Illicit Sanitary
Connections
Total Suspended
Solids - 250 Ib
Biological Oxygen
Demand -
250 Ib
Total Nitrogen - 40
Ib
Total Phosphorus -
10 ib

Washwater
Discharges
TSS - 100 Ib
BOD - 80 Ib
Total oil and
grease - 4 Ib
Copper -0.04 Ib
Lead- 0.01 Ib
Zinc- 0.14 Ib
Accidental
Spills
Diesel Fuel
400 Ib

Erosion/
Sediment Control
TSS-1,630lb

                                                      D-26

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Case Study of Phase I  Management Options
  Successful Elements of Phase I Program:
  • Phase I monitoring helps identify and target management options.
  • Judging storm water management effectiveness through qualitative and quantitative methods is an important part
    of the Phase I program.
 s
acrarnento, California's Storm Water Management Program has been in existence since receiving its NPDES Storm
Water Permit in 1990.  The permit requires the city of Sacramento and three co-permittees (Sacramento County and die
cities of Folsom and Gait) to implement a storm water management program.
 Location:
 Sacramento, California

 Affected Waters:
 American and
 Sacramento Rivers
                     Two rivers, the American and the Sacramento, flow through the city. They are vital elements of
                     the life of the city and are linked closely to the history, economy, and ecology of the area.
                     Recognizing the importance of these two natural resources was a fundamental concept when
                     Sacramento implemented its storm water program.  By judging the effectiveness of the program
                     from both a qualitative and quantitative perspective, Sacramento's storm water Effectiveness
                     Evaluation Plan (EEP) expands on the concept of two major components of the city's Storm
                     Water Management program. These two components, the Core Program and the Constituent of
                     Concern Reduction Program, reflect the main functions of the Storm Water Management
                     Program and are explained below:
    Core Program
    The Core Program broadly addresses non-storm water and storm water
    discharges regardless of the level of impact such discharges may have on
    receiving waters. The Core. Program establishes the foundation of the Storm
    Water Management Program and provides the structure for addressing more
    specific types of discharges and pollutants. This foundation includes
    development of legal mechanisms, public awareness of the anatomy and
    function of the storm drain system, and prevention of non-storm water
    discharges. Although the Core Program undoubtedly reduces dry-weather
    discharges, it does not necessarily produce results that can routinely be
    measured as improvements to water quality in the receiving waters.

•   Constituent of Concern (Pollutant) Reduction Program

    The Constituent of Concern Reduction Program (COC Reduction Program)
    identifies and addresses specific constituents found in storm water that have
    been shown to cause or have the potential to  cause pollution in creeks and
    rivers.  The COC Reduction Program should eventually result in measurable
    improvements to water quality. This component will become a more central
    focus of the Storm Water Management Program as implementation of some of
    the Core Program functions become more routine and control strategies for
    specific pollutants and sources are identified  through the ongoing efforts of the
    monitoring program.

Although the impacts of storm water on the beneficial uses of the rivers and creeks in Sacramento and the constituents that
cause those impacts are still not fully understood, the permittees are using chemical concentrations that appear to be of the
most concern.  A ranking of the COCs was conducted in 1995-96. The list of prioritized COCs is shown on the adjacent
table.
Priority Constituents of Concern
Constituent
Chlorpyntbs
Diazinon
Fecal coliform
Lead
Copper
Zinc
Cadmium
Chromium
PAH compounds
Arsenic
Mercury
Cyanide
Fluoranthene
Pentachlorophenol
Malathion
Diuron
Priority
Tier 1
Tier 2
Further evaluation
as COC needed.
Constituent not
prioritized due to
insufficient data
at this time.
                                                                    Contact:
                                                                    Larry F. Nash. P.E.. Senior Engineer. 916 264-1434
                                                                    mash@ge.sacto.org
                                                     D-27

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San Francisco Bay Region: Diazinon Detective Work
  Successful Elements Related to Phase I Program:
  •  The Phase I program provides a framework for a joint-municipality effort to protect a common environment.
  •  Storm water monitoring focuses management plans to control an environmental threat.
T
      he San Francisco Bay and Delta combine to form the west coast's largest estuary. The estuary is host to a rich
      diversity of aquatic life. The California Regional Water Quality Control Board, San Francisco Bay Region (Regional
      Board), in collaboration with bay area municipalities, has detected harmful amounts of the insecticide diazinon in
                   storm water runoff to the bay. Diazinon is a widely applied insecticide used by homeowners and pest
                   control professionals. lexicologists have found that diazinon causes mortality in the water flea, a
                   common bioassay organism, at the extremely small exposure level of 0.3 nanogram per liter (ng/L or
                   parts per billion). Diazinon's high toxicity and the fact that it is transported by water makes it an
                   environmental threat to the bay and its tributaries.
  Location:
  San Francisco
  Bay Region
  Area:
  1,600 square
  miles

  Affected
  Waters:
  San Francisco
  Estuary
                   Based on toxicity tests in its waterways, the Regional Board and Bay-area municipalities saw the need to
                   assemble a research team to trace possible locations of diazinon. By checking statistics on diazinon retail
                   sales, the research team started with a region-wide assessment of diazinon usage. Following the review
                   of retail sales records, the team began a prioritized diazinon sampling process throughout the San
                   Francisco Bay to identify the areas with the highest concentrations of diazinon. They found the highest
                   concentrations in small catchment areas feeding urban streams, and both runoff and dry-weather flows
                   contained troubling amounts of the insecticide. Researchers also discovered that despite similarities in
                   catchment size, diazinon loads could not be predicted on the basis of general land cover variables
                   (Watershed Protection Techniques, 1999).

Through subsequent study, the researchers determined that harmful diazinon levels could be produced in urban streams by
the actions of only a handful of individual homes. Furthermore, diazinon levels fluctuated greatly among the different
outfalls along the same stretch of street (see figure).  Even if diazinon was applied in accordance with the instructions for
proper application, it was discovered in runoff 3 weeks and even 7 weeks after application.  The monitored diazinon
concentrations in runoff were frequently more than 1,000 times higher than the 0.3-ng/L level needed to kill water fleas.

San Francisco and associated Phase I communities around the bay are actively seeking to decrease the load of diazinon
entering the bay. Efforts include sensitizing residents about the undesired impacts of the pesticide through focused public
                                                              outreach efforts. In addition, San Francisco is
                                                              considering a resolution to cease use of all current
                                                              pesticides until it can identify "reduced-risk'1
                                                              alternatives. The bay municipalities are interested in
                                                              EPA's ongoing review of diazinon under the 1988
                                                              Federal pesticide regulations and want the Agency to
                                                              propose stringent rules regarding its use.

                                                              In summary, because of the NPDES Phase I program,
                                                              environmental impacts related to storm water have been
                                                              identified in the San Francisco Bay region and BMPs
                                                              are being used to minimize environmentally threatening
                                                              pollutants.
                                                                      Contact-
                                                                      Tom Mumly, California Regional Water Quality Control
                                                                      Board. 510 622-2395

                                                                      Source:
                                                                      Watershed Protection Techniques, Vol. 3, No. 1, April
                                                                      1999.
                                                      D-28

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Maryland's Management of Dry-Weather Illicit Discharges
  Successful Elements Related to Phase I Program:
  •  Phase I has added illicit discharge control to existing storm water control measures used in Maryland.
  *  Through a combination of inspection, enforcement, and education, Maryland's MS4s are monitoring and better
    managing hundreds of storm water outfalls.
M
  Location:
aryland has a long history of managing its storm water to protect the Chesapeake Bay and its tributaries, including
the Maryland Erosion and Sediment Control Law (1970) which controls runoff from construction sites; the 1982
Stormwater Management Act requiring best management practices (BMPs) for postdevelopment controls; and the
           Chesapeake Bay Program, which established a watershed-wide 40 percent nutrient reduction goal.
           Even though Maryland's State programs have helped local jurisdictions manage their storm water, the
           MS4 Phase I program has resulted in additional control measures that are further reducing pollutant
           loadings.
  Facility
  Type:
  Affected
  Waters:
           For example, as a result of the NPDES requirements, dry-weather discharges from MS4s are being
           characterized and managed. A total often MS4s participate in Maryland's municipal NPDES storm
           water program, including Baltimore City and the counties of Anne Amndel, Baltimore, Harford,
           Howard, Montgomery, Prince George's, Carroll, Charles, and Frederick. For each of these MS4s,
           Phase I NPDES requirements have led to field screening of major storm drain system outfalls during
           dry weather periods and local pollution prevention efforts that have stopped a range of illicit
           discharges.

           Storm drain systems are built ostensibly to convey storm water runoff.  However, discharges from
           storm drain outfalls are not always the result of precipitation. For example, a Sacramento, California,
           study (Montoya, 1987) indicated that
slightly more than half the volume of water discharged from a
storm drain system occurred during periods without
precipitation. These dry-weather flows originate from a range
of sources, some of which do not impose a significant
environmental risk (e.g.. water line flushing, fire fighting
runoff, diverted stream flows, rising ground water infiltration).
However, other sources of dry-weather flow are a significant
hazard to receiving water quality, including discharges from
illegal activities, untreated industrial discharges, and
discharges from sanitary sewer pipe cross-connections to the
storm sewer system. For example, a study of Allen Creek in
Ann Arbor, Michigan (Schmidt and Spencer, 1988) indicated
60 percent of facilities known to use petroleum products or
other hazardous materials (e.g., photo processing labs, dry
cleaners, and utility companies) discharged inappropriately to
the storm sewer system. The wide array of features that must
be checked for during dry-weather inspections is shown in
Table 1.

Maryland's effort to help its MS4 permittees characterize illicit discharges, inventory their outfalls, and prevent illicit
discharges is progressing, as shown by the highlights in Table 2.  These highlights illustrate numerous ways Maryland's
MS4s are managing their storm water systems. As shown by the highlights for suburban MS4s (all except Baltimore City).
illicit discharges that affect quality during dry-weather periods are not limited to highly urbanized areas. For Maryland, the
ongoing characterization of dry-weather discharges based on land use and industry is helping to set monitoring and
management priorities.  Annual reporting of MS4s to the Maryland Department of the Environment provides the data needed
to assess the progress of ongoing management efforts and provides a framework for sharing information on what approaches
are the most effective.
Table 1. Features Used to Identify Dry-Weather
Illicit Discharges
Floatables
tan scum
brown scum
detergent
trash
sediment
oil
toilet paper
suds
Deposits
Oil
sewage
orange
rusty
red algae
metallic scum
copper
white milky
Odor
feces
musty
stale
plastic
chlorine
cleaning agents
food process
detergent
Color
pink
black
metallic
blue
red
orange
tan

                                                     D-29

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Table 2. State of Maryland Management Highlights for MS4 Illicit Discharge
MS4 Name
Baltimore City
Prince George's
County
Carroll County
Frederick
County
Highlights for the 1997 Management Year
The city has focused recently on identifying suspicious connections for pipes 48inches or larger and found that a third of 142
outfalls sampled in priority areas contained high fecal coll form counts indicating potential sanitary leaks to the storm sewer
system. Also, the city has developed an automated sampling effort for 67 of the worst outfalls with a history of problems.
In residential areas, six outfalls had high detergent levels and two had elevated levels of phenols. The phenol problems appeared
to be the result of oil dumping and inadequate car maintenance practices. Investigation of these areas showed evidence of oil
sheen in the discharges, and surrounding areas exhibited oil stains on paved surfaces. Educational efforts were employed here to
rectify these problems. The county has addressed 485 water quality complaints since 1 993. The majority of these complaints
involved problems associated with dumping trash and debris, sewage, sediment and erosion, vehicle washing, chemical spills,
automotive fluids, and general non-stormwater discharges.
Current efforts include a Water Resources Management Program that requires new businesses to propose and implement pollution
prevention plans for chemical storage to ensure that illicit discharges do not occur. Educational activities will be a pan of the
illicit connection program; field screening activities during the permit term will include organized stream walks with citizens and
environrrental professionals
The county's illicit connection detection and enforcement program stresses proactive detection and a business-oriented database
which will help identify critical industrial and residential outfalls to be monitored at least once every 3 years.
Contact*
William Page (bpage@mde.state.md.us)
Water Management Administration
Maryland Department of the Environment
410631-3543

Sources:
Dry Weather Flow and Illicit Discharges in Maryland Storm Drain Systems, Maryland
Department of the Environment Water Management Administration, October 1997
Montoya, B.I. 1987. Urban Runoff Discharges from Sacramento, CA.  CVRWQCB
Report Number 87-tSPSS
Schmidt, S. D. and D. R. Spencer. The Magnitude of Improper Waste Discharges in
an Urban Stormwater System Journal WPCF. July 1986
       D-30

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Ciba Specialty Chemicals: Compliance with Permit Requirements Results
in Cost Savings
  Successful Elements:
  • Collection of storm water first flush eliminates pollutant loading to the Christina River, Delaware.
  • Collected runoff is reused as cooling water in industrial operations, thereby saving money and resources by reducing
    the purchase of water.
       Ciba Specialty Chemicals designed an innovative system to meet NPDES Storm Water Phase I permit requirements for
       the discharge of storm water to the Christina River in Delaware. The system provides the benefits of reuse of
       pollutant-laden water that would otherwise be discharged straight to the river. The water is used to cool machinery.
       This approach, developed as part of a site upgrade, makes the control of pollutants in storm water runoff an integral
part of overall site management.
Location:
Ciba Specialty Chemicals,
Newport, DE.

Industry Type:
Chemical Manufacturing
Facility
Affected Waters:
Christina River, DE
Before this approach was taken, infiltration created a zinc-laden dry-weather flow to the river,
which exhibited toxicity as a result. In addition, high levels of total suspended solids (TSS), a
common pollutant found in the first runoff resulting from a storm, were found in the site
discharge. After a site assessment, it was decided that both these pollutants could be controlled
through design and implementation of a collection system at the site. The collection system
eliminates the need to pump ground water to the sanitary sewer or the river, and it provides for
the collection of the first flush of storm water runoff.

In addition, the water can be reused and containment of contaminated runoff resulting from an
accidental spill or fire is provided, emphasizing the integrated nature of the solution.
The company expects savings in maintenance costs, purchase of water for cooling purposes, and environmental sampling and
reporting requirements:

    Annual maintenance savings of $85,000.

    $30,000 annual savings from reduction in purchase of cooling water, expected to increase with expansion of system.

    Number of storm water outfalls reduced from nine to two, giving a large savings in analytical monitoring costs.

•   Zero percent mortality (of aquatic organisms) achieved due to containment of zinc-laden discharge.
                                                   Three small accidental spills entirely contained by the system,  -
                                                   resulting in no discharge of pollutant.
                                                              Contact:
                                                              Malthew Watson, Director EH&S, Ciba Specialty
                                                              Chemicals, (302) 992-5726
                                                              Source:
                                                              1999 National NPDES Program for Storm Water Control
                                                              Excellence Awards Application for Ciba Specialty
                                                              Chemicals Newport Facility
                                                      D-31

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Hoechst Celanese Corporation Coventry Plant: Good Housekeeping Is Good Business
  Successful Elements:
  • Continuous progression of Storm Water Pollution Prevention Plan and best management practices.
  • Programmatic progress.
  • Treatment did not generate hazardous waste.
T
he Hoechst Celanese Corporation (HCC) Coventry Plant is composed of three operating divisions, Specialty Chemical
Division, Pharmaceutical Products, and Specialty Group Research Division.  These divisions produce organic
                chemicals, pigments, dyes, and bulk pharmaceutical products. With the promulgation of die Phase I
                industrial program and NPDES regulations, the facility has been regulated under the Rhode Island
                Pollutant Discharge Elimination  System (RIPDES) since March 1992.
  Location:
  Coventry, RI

  Industry Type:
  Chemical
  Manufacturing
  Facility

  Affected
  Waters:
  South Branch
  Pawtuxet River, RI
                The regulatory requirements of the RIPDES permit consists of five subsections: Best Management
                Practices (BMPs); Handling of Significant Matehals; Herbicide, Pesticide and Fertilizer Usage;
                Non-stormwater Discharge Certification; and Significant Leaks or Spills.  Each of these subsections
                is used in a specific manner to reduce or prevent pollution in storm water. BMPs are used to address
                good housekeeping measures, such as properly storing material and posting signs reminding
                employees of the procedures.  Additional procedures and measures are detailed in the Storm Water
                Pollution Prevention Plan (SWPPP). Handling of Significant Materials provides the location and
                description of significant materials and uses structural controls to contain materials on site.  Since
                HCC employs a local landscaping company to maintain the grounds, the chemicals used are
                documented and listed as Herbicide, Pesticide, and Fertilizer Usage. The Non-stormwater Discharge
                Certification requires HCC to certify that there are no known non-stormwater discharges. HCC is
                also required to prepare a list of Significant Leaks and Spills and to maintain die list at the facility.
Since obtaining its RIPDES permit, the facility has experienced difficulties with compliance issues as well as additional
reissuance requirements. The key issues faced by the facility included the following:

    Continuing to delineate all the subcatchment areas associated with industrial activities. Neither new construction nor
    cessation of operations was identified or updated in the SWPPP.
    Barrels and pallets were not covered and dye stains on the ground were identified, indicating potential sources of
    pollution.
    During an inspection, barrels from the facility were viewed in the Pawtuxet River.

Although HCC continues to develop and maintain compliance with the RIPDES industrial storm water program, the
company has been able to improve the overall industrial storm water program at the facility. The following are examples of
improvements:

    Maintaining a List of Significant Leaks  and Spills showed that within 3 years the list more than tripled.  It is unlikely
    that the number of spills increased; it  is  more likely that the diligence in recording these spill has improved.
    Good housekeeping practices and inspections have increased employee awareness, issues are discussed at shift meetings,
    and public signs are posted.
                                                                  Source:
                                                                  July 1995 NPDES Permit Application for Hoechst Celanese,
                                                                  Coventry Plant
                                                     D-32

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Doggett Auto  Parts: BMP Implementation Results in Awards
  Successful Elements:
  •  Aggressive implementation of BMPs.
  •  Continuous evaluations for opportunities to improve.
  •  Preventing releases and exposure.
D
       oggett Auto Parts is a full-service auto recycling facility in Bryan Texas.  It stores 1,000 cars in its yard and
       dismantles about 20 cars a month. Since 1994 the facility has implemented a storm water pollution prevention plan
                   (SWPPP). The plan was revised in October of 1997 to implement new best management practices
                   (BMPs) for vehicle storage and dismantling operations at the 5-acre site. Each of the seven employees
                   is trained to implement the requirements of the NPDES storm water program.
  Location:
  Bryan, TX

  Industry
  Type:
  Salvage yard

  Affected
  Entity:
  Carters Creek
                   In 1997 Doggett moved from the Baseline Permit to the Multi-Sector General Permit.  As a result the
                   company continues to implement site-specific BMPs.  The following 10 practices illustrate the variety
                   of BMPs Doggett has used as part of the SWPPP:
                   (1)  Use of drain tables to collect extracted fluids, which minimizes fluid contact with the ground.
                        This practice also reduces the amount of waste fluid contact with storm water discharges.
                   (2)  Recycling and reuse of antifreeze from alJ vehicles.
                   (3)  Evacuation and recycling of R12 and R134a Freon. This eliminates any possible release to the
                        environment.
                   (4)  Use of a "gas  buggy" to remove gasoline from each vehicle for use in company vehicles and
                        equipment. The use of the gas buggy eliminates any possibility of leakage or spillage.
(5)   Secondary containment for the outside oil storage tank and storage of waste oil drums on a concrete pad and under
     cover.
(6)   Inside storage of removed motors, transmissions, radiators, tires, batteries, etc.
(7)   Use of wheel stands for stored, unprocessed vehicles to facilitate site inspection for fluid leaks.
(8)   Location of parts washing in a dedicated wash bay. Settling of solids in the wastewater occurs before discharge to the
     local POTW.
(9)   Annual employee SWPPP training,  including emergency response and BMP implementation.
(10) Tasking employees with observing, reporting, and initiating corrective action.

As result of BMP implementation and dedication to good environmental practices Doggett Auto  Parts has been recognized
for its efforts:
    Automotive Recyclers Association (ARA) approved Doggett as
    a Certified Automotive Recycler.
    Awarded Gold Seal Quality Program status .
    Nominated for the 1998 National Storm Water Control Program
    Excellence Award for an industrial program.
                                                                 Contact:
                                                                 D.J. Rufino
                                                                 409 778-7536
                                                                 Source:
                                                                 1998 National NPDES Program for Storm Water Control
                                                                 Excellence Awards, application for Doggett Auto Parts
                                                     D-33

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Empire Castings: Total Suspended Solids Reduced by 90 Percent
  Successful Elements
  • TSS runoff has been reduced by 90 percent.
  • Affordable, durable, and effective best management practices.
I
   In cooperation with EPA Region 6 and the Oklahoma Department of Environmental Quality (OK-DEQ), Empire Castings
   worked with other local foundries to identify effective and economically feasible multimedia solutions for achieving
                   compliance with environmental regulations applicable to the foundry sector. For its work, Empire
                   Castings was awarded second place in the industrial category for the 1996 National Storm Water
                   Control Excellence Awards.
 Location:
 Tulsa, OK
 Industry
 Type:
 Ductile/Gray
 Iron Foundry

 Affected
 Entity:
 City of Tulsa,
 OK Storm
 Sewer System
                   Prior to this initiative, an examination of Empire Castings, a sand-mold foundry, revealed TSS in storm
                   water to be a major concern, with storm water sampling indicating TSS levels in excess of 1800 mg/L
                   (October 1992). New operating procedures incorporating best management practices were
                   implemented. These procedures included routine dry sweeping to prevent sand drag-out to exposed site
                   areas. Gutters were installed, and berms were constructed to divert potentially contaminated storm
                   water for treatment. Preliminary studies for this site revealed that straw bales were ineffective at
                   reducing TSS levels in storm water and were not durable over the long term. However, a filter system
                   consisting of railroad ties and a woven fabric mesh at the outlet of the retention ponds proved durable
                   and effective at reducing TSS discharge levels to less than 150 mg/L (October 1995). Empire Castings
                   incurred an initial labor and materials cost of $8,455 to achieve this initial reduction in TSS, with an
                   annual cost anticipated at $ 16,462 to
                   employ a dedicated worker to dry sweep
                   high-traffic areas, remove settled solids                      Empire Casting,
from the retention ponds, and maintain the filter system.                TSS Stormwater Concentrations {mg/L)

To further reduce TSS levels, Empire Castings conducted a         ^"
major cleanup of the foundry floor at a cost of 700 man-hours
($5,355).  Installation of additional lighting aided workers in
minimizing routine sand drag-out and maintaining clean
conditions. Empire Castings believed these housekeeping
measures, in addition to diverting and filtering roof runoff
would be sufficient to achieve the additional reduction
necessary to achieve compliance with the September 29,1995,
standard of 100 mg/L.

Benefits from the implementation of the storm water program
include the following:
•   A dramatic reduction in site visits by the city of Tulsa
    required to clean local storm drain sites.
    Higher productivity rates and training for staff on storm
    water controls.
    A 90 percent drop in TSS concentration levels.
                                                             1930
                                                                   10082     KTT&t     42W6     53885     10595

                                                                 Bill Ruth
                                                                 918587-3327

                                                                 Source:
                                                                 1996 National NPDES Program for Storm Water Control
                                                                 Excellence Awards, application for Empire Castings
                                                     D-34

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Pratt Auto Salvage & Sales, Inc.: Storm Water Pollution Plan Makes Salvage
Yard a Good Neighbor
  Successful Elements
  • Facility has obtained a 100 percent removal rate.
  * Discharge drainage ditch from site contains minnows and other aquatic life.
  • Partnered with Arkansas Automotive Dismantles Recyclers Association and Automotive Recyclers Association.
T
he 20 acre Pratt Auto Salvage & Sales Inc. site located near downtown Hoxie, Arkansas, engages in the wholesale
distribution of motor vehicle supplies, accessories, and tools and new motor vehicle parts. In addition, the facility
processes 70 to 80 aging and damaged cars each month.  The site is located next to a school and an apartment
complex.
  Location:
  Hoxie, AR

  Facility
  Type:
  Salvage yard

  Affected
  Waters:
  Turkey Creek,
  Black River
from automobiles.
standards and EPA
             Because of the types of vehicles brought to salvage yards, leaked fluids and exposed parts can
             contaminate storm water and potentially ground water.  To prevent such contamination from occurring
             and to comply with the storm water permit issued by the Arkansas Department of Pollution Control and
             Ecology in 1993 as part of the Phase 1 regulations, Pratt developed a storm water pollution prevention
             plan (SWPPP) with the guidance of the Arkansas Automotive Dismantlers Recyclers Association and
             the Automotive Recyclers Association.  The goal of the plan is to recycle  100 percent of the vehicles
             while averting contamination of the environment. The plan consists of six parts: Pollution Prevention
             Team, Identification of Potential Pollutants, Practices for Elimination or Reduction of Pollutants in
             Dismantling Process, Facility Maintenance, Equipment Maintenance, and Employee Training

             The  facility was able to obtain a 100 percent pollutant removal rate. The Pratt facility drains vehicles
             of all fluids in a covered buildings with a cement floor. Fluid drained from the vehicles is removed
             from the site by an independent contractor. The vehicles are then either dismantled and sold for scrap
             or relocated to the storage areas outdoors. During the years the facility has been operational and
             maintaining an SWPPP, the salvage yard area has been free of oil, rust or waste associated with fluids
            Based on storm water sampling conducted, Pratt's SWPPP is effective in complying with industry
           targets.
In recognition of the BMPs, in 1995 Pratt received first place in the Improvement-Beautification Contest from the
Automotive Dismantlers and Recyclers Association and earned the highest level of auto recycling designation (Gold Seal
Certified Automotive Recycler) In 1998 Pratt received the first award presented to industry by the Arkansas Department of
Environmental Quality. Finally, Pratt is honored by receiving children on field trips from the neighboring school.  They
come to observe Pratts operations and view the drainage ditch in the salvage yard, which is home to minnows and other
aquatic life.
                                                                  Contact:
                                                                  Robert Pratt
                                                                  870 886-7830
                                                                  Source:
                                                                  1999 National NPDES Program For Storm Water Control
                                                                  Excellence Awards, application for Pratt Auto Salvage and
                                                                  Sales
                                                      D-35

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                                   APPENDIX E
          Phase I Construction Activity Load Reductions
Phase I Construction Activity Load Reductions

The Phase I rule regulates construction starts disturbing five or more acres of land, requiring
construction site owners or operators to plan and implement appropriate erosion and sediment
control BMPs.  It is important to understand that the intent of construction requirements is to prevent
a degradation of water quality due to run off and sediments escaping from the construction site. The
prevention of water quality degradation as a result of implementing Phase I BMPs is comparable to
seeing water quality improvement from the worst case scenario.  That is to say the water quality is
improved because the worst case scenario was averted.

The load reduction analysis projects that Phase I construction BMP compliance prevents 73.2
percent of the sediments generated during construction from reaching the nation's streams, rivers and
lakes. An average of 63.4 tons of sediment may be eroded from each of the 62,755 construction sites
regulated by Phase I in 1999. This reduction equates to 2,911,523 tons of sediment or (264,000
dump trucks of soil) being kept out of our nations waters.

To develop an estimate of sediment  loadings from Phase I construction sites and the loads averted by
complying with the Phase I requirements, EPA estimated the total number of Phase I construction
starts for the year 1999. To approximate per-start sediment loads, EPA revised an earlier analysis
performed by the US Army Corps of Engineers (USAGE) for Phase II  construction starts entitled
"Analysis of Best Management Practices for Small Construction Sites. " The methodology followed
is consistent with the Economic Analysis for the Final Phase II Storm  Water Rule (US EPA, 1999b).
A brief description of the steps taken to develop these estimates follows.

Determining the Phase I Universe of Construction Starts

EPA used building permit information from the US Bureau of the Census and construction start data
from fourteen municipalities around the country to estimate the number of 1999 construction starts
greater than five acres.' In determining the universe of construction starts, a correlation was made
            The 14 localities providing construction start data were: Austin. Texas: Baltimore County, Maryland; Gary, North
   Carolina: Ft. Collins. Colorado: Lacey. Washington: Loudoun County, Virginia; New Britain. Connecticut; Olympta.
   Washington: Prince George County, Maryland, Raleigh. North Carolina; South Bend, Indiana; Tallahassee, Florida; Tucson,
   Arizona, and Waukesha. Wisconsin.

                                            E-l

-------
between the information obtained from the 14 municipalities on construction starts and data obtained
from the national building permits.

EPA obtained data files from the US Bureau of the Census indicating the number of building permits
issued in the United States. The data files cover approximately 96% of the counties within the
United States  for the years 1980-1995.  The Census Bureau stopped collecting nonresidential
building permit information in 1995, which precluded the use of 1995 data in this analysis. EPA
grouped building permits into similar types of buildings and activities.  The following equivalents
were developed based on commonly used zoning code descriptions and activities using common
zoning code descriptions and the Census Bureau's definition of building categories.
                                  Census Bureau's definition of building categories:
                                  4.
                                  5.
                                  6.
code 101 represents single-family detached homes;
codes 103, 104, and 105 represent "attached" homes
(e.g., apartments, townhouses, condominiums);
codes 213, 214, 318, 321, 322, 324,327, and 328
represent commercial establishments;
code 320 represents industrial or manufacturing facilities;
codes 319, 323, 325, and 326 represent all institutional
buildings (e.g., schools, hospitals, churches, government
buildings);
code 329 represents parks and recreational facilities.
The number of construction starts
from 1994 to 1999 was escalated
using an average annual growth
rate of 1.013%, which reflects the
average increase in permits
during prior years.2

EPA developed ratios to estimate
the number of building permits
issued by construction type
(residential, commercial,
industrial, etc.) for two size
categories (5-10 acres and >10
acres).  The size category is
equivalent to the land area
disturbed by an individual development.

Based on a review of erosion and sediment control provisions as mandated under Coastal Zone Act
Reauthorization Amendments of 1990 (CZARA), EPA identified localities that have erosion and
sediment control requirements for sites that disturb five or more acres. Those starts were eliminated
from the analysis because they already have sediment and erosion control requirements similar to
Phase I. There are other equivalent programs besides those mandated under the Coastal Nonpoint
Pollution Control Program.

Determining the Sediment Load per Start

To estimate pollutant loading reductions from Phase I construction starts, the USAGE developed a
model of 18 construction sites to estimate sediment loads from construction starts with and without
Phase I controls (USAGE, 1998). The USAGE model uses the Revised Universal Soil Loss
Equation (RUSLE) to generate edge-of-construction site sediment delivery loads for 15 climatic
regions with each of the following variations: two site sizes (5-10 and >10 acres), three soil
erodibihty levels (low, medium, and high), and three slopes (3%, 7%, and 12%). The 15 climatic
regions were used in an effort to represent the various climatic conditions throughout the United
          * Based on data collected from the US Bureau of the Census the average annual growth rate for the number of
   building permits issued from 1980 to 1994 was  1.013% per year However, EPA recognizes the growth rate for construction
   starts fluctuates yearly and does not necessarily  increase each year.
                                            E-2

-------
States. To adapt the USAGE analysis to the Phase I universe, EPA modified the length-slope factor
to reflect the larger construction sites regulated under Phase I3 and used the same parameters as those
for the remaining mode! assumptions.

The 1999 construction start data was then separated into the 15 climatic regions based upon the
proportion of each State which falls into each climate zone. In this way an average per start load for
each climate region could then be multiplied by the total number of starts in each climate zone.
Consistent with the approach taken in the Phase II economic analysis, average loadings for each
climate zone were determined using an average of the slope categories 3%, 7%, and 12%, assuming
all were equally as likely, and assuming medium credibility for the soil. Table E-l provides the
number of construction starts, sediment loads per construction start, and the load in tons per year.
  Table £-1. Estimate of Sediment Loads from Construction Starts
Representative
Climate
Citv Zone
Portland
Boise
Fresno
Las Vegas
Denver
Bismark
Helena
Amarillo
San Antonio
Duluth
Des Moines
Nashville
Atlanta
Hartford
Charleston. SC
Hawaii
Aiaska
Atlantic Islands

A
B
C
D
E
F
G
H
I
K
M
N
P
R
T
V
W.X,Y
2
Total
Number
of Starts
5-10 Acres
278
511
0
2,478
1,239
348
716
1,691
459
1,739
5,506
4,965
3,676
1,671
974
0
65
239
26,554
Number of
Starts
>10 Acres
377
700
0
3,556
1.724
458
975
2,307
639
2,308
7,436
6,711
5,038
2,206
1335
0
90
339
36,201
5-10 Acre
Load per Start
(Tons/Year)
21
4
3
2
13
16
4
35
92
31
57
82
109
45
152
NA
NA
NA

>10 Acre
Load per Start
Tons/Year
25
4
4
2
15
19
5
40
108
37
67
96
127
53
178
NA
NA
NA

5-10 Acre
Loading
(Tons/Year)
5,952
1,802
—
5,229
15,787
5,533
3,014
58,612
42,256
54,755
313,919
408,819
399,299
75,514
148,152



1,538,642
>10 Acre
Loading
(Tons/Year)
9,431
2,878
—
8,759
25,650
8,494
4,790
93,363
68,737
84,848
494,814
644,984
638,670
116,352
237,107



2,438,875
t'sing EPA guidance on storm water management for construction activities (USEPA1992b),
combinations of BMPs for the model sites were developed to mimic commonly accepted erosion and
            The estimated amount of disturbed area for the 5-10 category was 7.5 acres, and 13.9 acres for the 10 and above
    category.
                                            E-3

-------
sediment control practices.  Additionally. BMPs were selected based on guidance contained in
Brown and Caraco (1997).  The types of BMPs placed on each site varied based on the unique
conditions of the site. For example, for sites with shallow slopes and low erosivity, few BMPs are
required.  In contrast, on larger, steeper, and more erosive sites, more BMPs are needed. Table E-2
shows the mix of BMPs selected for the various model sites.  In developing the mix for each model
site, EPA assumed that entities would select the most cost effective mix of BMPs.

 Table E-2 BMPs Used for the Model Sites
Site Size (acres)
>5
Soil Erodibility
low
med
high
Slope
3%
a,c,d,e
a,c,d.e
c,d,e,f,g
7%
c,d,e,f,g
c,d,e,f,g
c,d,e,f,g
12%
c,d,e,f,g
c,d,e,f,g
c,d,e,f,g
a = silt fence
b = mulch
c = seed and mulch
d = stabilized construction entrance
e = stone check dam
f = earthen dike directing runoff to sediment trap
g = sediment trap (9,000 ft3)
To determine the average sediment load from Phase I construction sites, the sediment loads were
developed by:
       •      estimating the average climatic sediment load per site assuming moderate credibility;
       •      developing a national weighted average sediment load per site; and
       •      developing the potential sediment load released from Phase I sites with and without
              erosion and soil control BMPs.

Average climatic sediment loads were developed using the RUSLE for sites between 5-10 acres, and
sites larger than 10 acre sites assuming medium soil erodibility (USEPA 1999b).

To develop the national weighted average sediment load per site, the average climatic load per site
was multiplied by the number of construction starts disturbing between 5-10 acres and more than 10
acres in each climatic zone. The total loadings were summed and then multiplied by the ratio of
construction starts in each size category to the total number of each construction sites for each
climatic zone.

The average loads per climatic region were multiplied by the ratio of total Phase I construction starts
in each climatic zone to the total Phase I construction starts nationwide to obtain a national weighted
average sediment load per site.  This methodology was used to calculate sediment loads from
construction starts with and without Phase I controls. The USAGE model was also used to derive an
estimate of potential sediment load reductions attributable to soil erosion controls. These values, as
presented in Table E-3, indicate that the average soil  loss per start without Phase I BMPs, was 63.4
tons and the average annual potential reduction in soil loss could be as high as 46.4 tons per start
with Phase I BMPs.  The sediment loss calculation used in the analysis is based on a version that was
                                            E-4

-------
developed to mode! construction sites. Actual soil loss may vary from site to site due to the pattern
and extent of soil disturbance as well as the placement of building materials and the buildings on the
site.  The analysis indicates that 73.2 percent of the sediment that would otherwise be delivered into
our nation's waters is retained on constructions sites due to the Phase I BMPs.
                   Table E-3. Estimate of Potential Sediment Load Reductions
Representative Climate
City
Portland
Boise
Fresno
Las Vegas
Denver
Bismark
Helena
Amarillo
San Antonio
Duluth
Des Moines
S'ashville
Atlanta
Hartford
Charleston, SC
Hawaii
Alaska
Atlantic Islands

Zone
A
B
C
D
E
F
G
H
I
K
M
N
P
R
T
V
W.X.Y
Z
Total
Number of
Starts
5-10 Acres
278
511
0
2,478
1,239
348
716
1,691
459
1,739
5,506
4,965
3,676
1,671
974
0
65
239
26,554
Number of
Starts
>10 Acres
377
700
0
3,556
1,724
458
975
2,307
639
2,308
7,436
6,711
5.038
2,206
1.335
0
90
339
36,201
BMP Load per Start
Tons/Year
5-10 Acre
4
1
0
0
3
3 .
1
9
27
7
15
23
30
11
41
NA
NA
NA

>10 Acre
5
1
1
0
3
4
1
11
32
8
18
27
35
12
48
NA
NA
NA

BMP Total Load
Tons/Year
5-10 Acre
1,190
329
—
284
3,383
1,141
554
15,603
12,606
11,721
84,311
113,618
109,500
17,691
40,369



412,300
>10 Acre
1,886
525
—
476
5,496
1,751
881
24,855
20,505
18,162
132,896
179,252
175.143
27,259
64,609



653,695
                                             E-5

-------

-------
                                   APPENDIX F

         Water Quality Improvements from Similar Construction Control Programs
To assess potential water quality improvements that could be associated with Phase I construction
controls, EPA sought to identify jurisdictions that (1) experience a high rate of construction activity
and (2)  are located within a watershed that has been monitored for changes in water quality
indicators. The water quality data used for this analysis came from the U.S. Geological Survey's
National Stream Water Quality Monitoring Networks (WQN). The construction data came from the
U.S. Census Bureau's Building Permit Database.

The monitoring data currently available from the WQN cover the period from 1973 until
approximately 1994.  The construction permit data from the Census Bureau are for the period
between 1980 and 1994.  On the other hand, Phase I construction controls were not put in place until
October 1992.  Consequently, there were insufficient WQN data for a meaningful comparison
between before and after conditions.  Therefore, it was necessary to look for high-growth areas that
had put erosion and sediment control provisions into place prior to Phase I and that had requirements
that were at least as rigorous as those required under Phase I. These areas offer a surrogate means
for assessing the potential for improvements as a result of Phase I construction controls.

Approach

Under the Coastal Zone Management Act of 1972, coastal states were required to develop a coastal
zone management program to protect coastal resources from the impact of human activity. As part
of this program, many states implemented erosion and sediment control provisions in their coastal
areas. EPA conducted a screening analysis to assess each coastal state for the number of "high
growth counties" which fell under the jurisdiction of their coastal zone management program.  High
growth counties were defined as those counties that experienced a minimum of 600 estimated
construction starts during the year 1994.

As a result of the screening analysis,  the state of Florida was chosen to be profiled. In 1994, Florida
had 24 high growth counties as defined in this analysis. There are also numerous USGS monitoring
stations located within the state.  In addition in September 1981, the State of Florida, as a result of
"the unique biogeographic conditions found in Florida," included the entire state in the coastal zone.4
Furthermore, in 1986 Florida adopted a comprehensive beach management program under which all
coastal counties were required to implement erosion and sediment control provisions for construction
activities.  This provided a suitable before and after time period for the analysis. The period from
1980 to 1986 represents the pre-erosion and sediment control conditions and the period of 1987 until
          "'Florida Department of Environmental Protection. Intergovernmental Programs Manual,
   www.dep.state.fl.us. legts'igovprg/manual.htm. Accessed 1 '8''2000.

                                            F-l

-------
 1094 represents the post-erosion and sediment control conditions.

The WQN data provide daily flow sample values, as well as total suspended sediment (TSS) samples
taken periodically throughout the year. However, the completeness of the data varies between
stations and from year to year. Therefore, monitoring stations with gaps of a year or more in their
data set were not considered for the analysis. A total of 11 Florida monitoring stations were
eventually considered for the study. The WQN monitoring data from these stations were used to
derive annual sediment load estimates for their corresponding watersheds.

For there to be evidence of water quality improvements that could potentially be attributable to the
implementation of erosion and sediment controls, sediment from development within the watershed
must be a significant source of sediment entering the waterway.  However, two issues may
complicate this relationship:

(1)    There are many potential sources of sediment to the watershed other than construction sites.
       Agricultural activities can be a major source of sedimentation in waterways.  In heavily
       urbanized areas, large pulses of storm water runoff can cause in-stream erosion, which can
       affect sediment levels within the waterway.
(2)    Many watersheds are down stream from other watersheds. TSS loadings within the
       waterway are derived from sediment entering the waterway from its own watershed and also
       from upstream reaches.

These factors can obscure the potential impact of construction site erosion on sediment loads to
waterways. However, since an effort was made to find monitoring stations in high-growth areas, the
effects of the first issue might have been attenuated.

Sediment loads within a watershed are also highly dependent upon rainfall events. Fluctuations in
rainfall and storm intensity both  are major contributors to annual sediment loadings. To lessen the
influence of fluctuations in precipitation, average annual rainfall data for the entire state of Florida
was used to normalize the sediment load data.

To find evidence of reduction in sediment loads that can potentially be attributed to the
implementation of erosion and sediment control provisions, annual sediment loads from each
watershed had to be compared to annual construction levels for the counties that correspond to the
watershed. Watersheds were grouped with counties based upon the watershed's USGS hydrologic
unit code (HUC). For each watershed the construction permit data for the counties that are
completely or partially located within the watershed were summed.  Table F-l shows a list of the 16
high-growth counties considered, and Table F-2 shows how they correspond to one or more of the
watersheds.

Since the variability of weather in many cases can obscure potential underlying year to year trends in
sediment loads, long time periods need to be used to find trends in sediment loadings. There was
insufficient long term data to produce actual year to year trends in sediment loads for each
watershed. Instead, the mean annual sediment loading value for the period 1980-1986 was compared
to the 1987-1994 mean for each watershed. The same comparison could then be made for the
average annual number of construction permits for each watershed's corresponding counties.
                                            F-2

-------
Results

Table F-3 shows the results of the comparisons. The relative increase or decrease in sediment loads
is compared to the relative increase or decrease in construction starts. To suggest that erosion and
sediment controls reduce sediment loads, the average annual sediment loads would need to either
decrease or at least increase by a lower percentage when average annual construction levels increase.
Conversely, if no relationship exists and the statistics are independent, construction decreases would
result in corresponding decreases in sediment loading rates.  The plus and minus symbols in the last
column of Table F-3 shows how often this did or did not occur. As shown it occurred for only 5 out
of the 11 watersheds.  When both the sediment loads and construction permits are summed over the
watersheds the table shows that  in aggregate both  total sediment loadings and construction
decreased. Sediment loading decreased by 31 percent while construction starts essentially remained
the same.
                                            F-3

-------








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   The totals from Table F-3 suggest that for each comparison it may be useful to look at the
   magnitude of the change in sediment loads and not just the direction of the change.  For example,
   when sediment rates fell or rose in relation to the construction rates was the magnitude greater
   than it was for those instances when they did not change in tandem? The Wilcoxon signed-rank
   test was used to compare the rates of sediment load increase or decrease and ranked to determine
   if the magnitude of the change was significant.5 Table F-4 shows the percentage increase or
   decrease between the first and second period for both sediment loadings and construction and the
   results of the Wilcoxon signed-rank test. The positive result of the summed rankings provides
   additional evidence suggesting that sediment and erosion controls have had a positive impact on
   water quality protection when the magnitude of the rainfall and corresponding sediment loads are
   considered.

   In conclusion, the results suggest that the sediment load is reduced by the implementation of
   construction erosion and sediment controls. Although this analysis was performed on selected
   watersheds within the state of Florida, EPA believes the results to be applicable to other high
   growth watersheds in the United States.
Table F-4  Wicoxon Signed-Rank Test for Comparison of Changes
Watersheds
(HUCs)
3080101
3080201
3090101
3090103
3090205
3100101
3100204
3110206
3140103
3140106
3140305
Sediment
% Change
36%
-483%
23%
27%
-124%
-901%
-253%
37%
-3%
13%
-4%
Construction
% Change
-3%
0%
5%
-8%
-5%
-17%
-18%
-10%
16%
-18%
-18%
Difference
in Change
34%
-482%
18%
19%
-119%
-884%
-235%
27%
13%
-4%
14%
Absolute
Value of
Difference
34%
482%
18%
19%
119%
884%
235%
27%
13%
4%
14%
Rank of
Difference
7
10
4
5
8
11
9
6
2
1
3
Change
in Tandem
-
+
-
-
+
+
+
-
+
-
-
Signed
Rank
-7
10
-4
-5
8
11
9
-6
2
-1
-3
          ''Newmark, Joseph. 1992. Statistics and Probability in Modern Life. 5* edition. Saunders
   College Publishing, New York, NY.
                                             F-7

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                                      APPENDIX G

                   Storm Water Discharges Associated with Industrial Activity
                              (excerpts from 40 CFR 122.26(b)(14))
The following categories of facilities are considered to be engaging in "industrial activity" for purposes
of this subsection:

  (i) Facilities subject to storm water effluent limitations guidelines, new source performance standards,
or toxic pollutant effluent standards under 40 CFR Subchapter N (except facilities with toxic pollutant
effluent standards which are exempted under category (xi) in paragraph (b)(14) of this section);

  (ii) Facilities classified as Standard Industrial Classifications 24 (except 2434), 26 (except 265 and
267), 28 (except 283), 29, 311, 32 (except 323), 33, 3441, 373;

  (iii) Facilities classified as Standard Industrial Classifications 10 through 14 (mineral industry)
including active or inactive mining operations (except for areas of coal mining operations no longer
meeting the definition of a reclamation area under 40 CFR 434.11 (1) because the performance bond
issued to the facility by the  appropriate SMCRA authority has been released, or except for areas of
non-coal mining operations which have been released from applicable State or Federal reclamation
requirements after December  17, 1990) and oil and gas exploration, production, processing, or treatment
operations, or transmission  facilities that discharge storm water contaminated by contact with or that has
come into contact with, any overburden, raw material, intermediate products,  finished products,
byproducts or waste products  located on the site of such operations; (inactive  mining operations are
mining sites that are not being actively mined, but which have an identifiable  owner/operator; inactive
mining sites do not  include  sites where mining claims are being maintained prior to disturbances
associated with the extraction, beneficiation, or processing of mined materials, nor sites where minimal
activities are undertaken for the sole purpose of maintaining a mining claim);

  (iv) Hazardous waste treatment, storage, or disposal facilities, including those that are operating under
interim status or a permit under subtitle C of RCRA;

  (v) Landfills, land application sites, and open dumps that receive or have received any industrial
wastes (waste that is received from any of the facilities described under this subsection) including those
that are  subject to regulation under subtitle D of RCRA;

  (vi) Facilities  involved in the recycling of materials, including metal scrapyards, battery reclaimers,
salvage  yards,  and automobile junkyards, including but limited to those classified as Standard Industrial
Classification 5015  and 5093;

  (vii) Steam electric power generating facilities, including coal handling sites;
                                              G-l

-------
   (viii) Transportation facilities classified as Standard Industrial Classifications 40, 41, 42 (except
4221-25), 43, 44. 45, and 5171 which have vehicle maintenance shops, equipment cleaning operations.
or airport deicing operations. Only those portions of the facility that are either involved in vehicle
maintenance (including vehicle rehabilitation, mechanical repairs, painting, fueling, and lubrication),
equipment cleaning operations, airport deicing operations, or which are otherwise identified under
paragraphs (b)(14) (i)-(vii) or (ix)-(xi) of this section are associated with industrial activity;

   (ix) Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment
device or system, used in the storage treatment, recycling, and reclamation of municipal or domestic
sewage, including land dedicated to  the disposal of sewage sludge that are located within the confines of
the facility, with a design flow of 1.0 mgd or more, or required to have an approved pretreatment
program under 40 CFR part 403. Not included are farm  lands, domestic gardens or lands used for sludge
management where sludge is beneficially reused and which are not physically located in the confines of
the facility, or areas that are in compliance with section  405 of the CWA;

   (x) Construction activity including clearing, grading and excavation activities except: operations that
result in the  disturbance of less than five acres of total land area which are not part of a larger common
plan of development or sale;

   (xi) Facilities under Standard Industrial Classifications 20,21, 22,23, 2434, 25,265, 267, 27, 283,
285, 30, 31 (except 311), 323,  34 (except 3441), 35, 36, 37 (except 373), 38, 39,4221-25, (and which
are not otherwise included within categories (ii)-(x)).
                                               G-2

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                                     APPENDIX H
             MSGP Storm Water Pollution Prevention Plan (SWPPP) Requirements
The process for a facility to be covered under the MSGP to develop and implement a storm water
pollution prevention plan (SWPPP) consists of the following four steps:

(I)    Formation of a team of qualified plant personnel who will be responsible for preparing the
       SWPPP and assisting the plant manager in its implementation.

       This step requires the permittee to identify the team of individuals responsible for plan
       development and implementation, including a description of the responsibilities of each team
       member.

(2)    Assessment of potential storm water sources.  -

       This step requires that the plan describe activities, materials, and physical features of the facility
       that may contribute significant amounts of pollutants to storm water runoff. In general, each plan
       must include site drainage patterns and outfalls, an inventory of exposed materials, a list of any
       recent significant spills and leaks of toxic or hazardous pollutants, a certification statement that
       discharges from the site have been tested or evaluated for the presence of non-storm water
       discharges (including identification of non-storm water sources), a description of any existing
       sampling data on the quality or quantity of storm water discharges from the site, and a summary
       of potential pollutant sources.

(3)    Selection and implementation of appropriate management practices and controls.

       Following the assessment of potential storm water sources, the permittee must evaluate, select,
       and describe the pollution prevention measures, BMPs, and other controls that will be
       implemented at the facility. The plan must address good housekeeping, preventative
       maintenance, spill prevention and response procedures, inspections, employee training, record
       keeping and internal reporting procedures, sediment and erosion control,  and management of
       runoff.

(4)    Periodic evaluation of the effectiveness of the plan to prevent storm water contamination and
       comply with the terms and conditions of the MSGP.

       The SWPPP must also describe the scope and content of the comprehensive site evaluations that
       qualified personnel will perform to confirm source identification, evaluate plan effectiveness, and
       assess compliance with the terms and conditions of the permit. The results of each site
       evaluation must be documented and signed by an authorized company official. Based on the
       results of the evaluation, the SWPPP must be revised as appropriate within 2 weeks after the
       evaluation with changes in non-structural controls required within 12 weeks and changes in
       structural controls required within 3 years.
                                              H-l

-------

-------
                                   APPENDIX I

                Industry Sectors/Subsectors Subject to Analytical Monitoring
                         Under EPA's Multi-Sector General Permit
MSGP Sector*
A
B
C
D
E
F
G
H
J
K
L
M
N
O
Q
s
T
L1
Y
A A
Industry' Subsector
General Sawmills and Planning Milis
Wood Preserving Facilities
Log Storage and Handling
Hardwood Dimension and Flooring Milis
Paperboard Milis
Industrial Inorganic Chemicals
Plastics, Synthetic Resins, etc.
Soaps, Detergents, Cosmetics, Perfumes
Agricultural Chemicals
Asphalt Paving and Roofing Materials
Clav Products
Concrete Products
Steel Works, Blast Furnaces, and Rolling
Iron and Steel Foundries
Non-Ferrous Rolling and Drawing
Non-Ferrous Foundries (Castings)
Copper Ore Mining and Dressing
Coal Mines and Coal-Mining Related
Dimension Stone, Crushed Stone, and
Sand and Gravel Mining
Hazardous Waste Treatment Storage or
Disposal
Landfills, Land Application Sites, and
Automobile Salvage Yards
Scrap Recycling
Steam Electric Generating Facilities
Water Transportation Facilities
Airports with Deicing Activities
Treatment Works
Grain Mill Products
Fats and Oils
Rubber Products
Fabricated Metal Products Except Coating
Fabricated Metal Coating and Engraving
Required Parameters for Analytical Monitoring
COD, TSS. Zinc
Arsenic, Copper
TSS
COD, TSS
COD
Aluminum, Iron, Nitrate + Nitrite N
Zinc
Nitrate + Nitrite N, Zinc
Nitrate + Nitrite N, Lead, Iron, Zinc, Phosphorus
TSS
Aluminum
TSS, Iron
Aluminum, Zinc
Aluminum, TSS, Copper, Iron, Zinc
Copper, Zinc
Copper, Zinc
COD, TSS, Nitrate + Nitrite N
TSS, Aluminum. Iron
TSS
Nitrate - Nitrite N. TSS
Ammonia, Magnesium, COD, Arsenic, Cadmium
Cyanide, Lead, Mercury, Selenium, Silver
Iron, TSS
TSS, Aluminum, Iron, Lead
Copper, Aluminum, Iron, Lead, Zinc, TSS, COD
Iron
Aluminum. Iron, Lead, Zinc
BOD, TSS. Ammonia, pH
Phosphorus, Nitrate *• Nitrite N, Ammonia, Copper, Iron,
Manganese, Zinc
TSS
BOD, COD. Nitrate - Nitrite N, TSS
Zinc
Iron. Aluminum, Zinc, Nitrate - Nitrite N
7inc Nitrate - Nitrite N
"Sectors I. P. R, T, V. XV. X. Z, AB, AC, and AD have no analytical monitoring requirements under EPA's MSGP.
                                           1-1

-------

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-------

-------
APPENDIX 1C  Ranking of Mean Reductions in Pollutant Concentrations by Subsector
Sector
J
Q
AA
H
A
E
A
A
C
Q
M
Y
M
L
H
C
M
A
Q
A
J
H
D
E
A
AA
Q
AA
C
M
O
AA
AA
L
AA
Subsector Name
Sand and Gravel Mining
Water Transportation
Metal Fab, exc. Coat/Eng.
Coal Mining
Other, non-Wood Preserving
Concrete Products
Log Storage and Handling
General Sawmills and Planing Mills
Soaps, Detergents, Perfumes, etc.
Water Transportation
Automobile Salvage Yards
Rubber Products
Automobile Salvage Yards
Landfills, Land Application, etc
Coal Mining
Soaps, Detergents, Perfumes, etc.
Automobile Salvage Yards
Other, non-Wood Preserving
Water Transportation
General Sawmills and Planing Mills
Sand and Gravel Mining
Coal Mining
Asphalt Paving and Roofing
Concrete Products
General Sawmills and Planing Mills
Metal Fab, exc. Coat/Eng.
Water Transportation
Metal Fab, exc. Coat/Eng.
Plastics, Synthetic Resins
Automobile Salvage Yards
Steam Electric Generating Facilities
Coating and Engraving
Metal Fab, exc. Coat/Eng.
Landfills, Land Application, etc
Coating and Engraving
Pollutant
Nitrate/Nitrite N
Lead
Aluminum
Iron
TSS
TSS
TSS
TSS
Zinc
Iron
TSS
Zinc
Aluminum
TSS
Aluminum
Nitrate/Nitrite N
Iron
COD
Zinc
Zinc
TSS
TSS
TSS
fron
COD
Zinc
Aluminum
iron
Zinc
Lead
Iron
Nitrate/Nitrite N
Nitrate/Nitrite N
Iron
Zinc
Mean
Change
100%
100%
97%
88%
81%
80%
78%
76%
72%
72%
70%
69%
67%
65%
65%
61%
60%
59%
56%
55%
55%
53%
52%
50%
41%
9%
7%
-4%
-9%
-12%
-46%
-92%
-196%
-430%
-2677%
         Median Mean Concentration Reduction
59%
                                         K-l

-------
Sector*
Q
J
M
M
A
0
M
M
A
E
L
E
H
A
H
Q
Q
A
L
J
C
AA
C
AA
A
A
Q
AA
Y
O
AA
AA
C
H
AA
Subsector Name
Water Transportation
Sand and Gravel Mining
Automobile Salvage Yards
Automobile Salvage Yards
Log Storage and Handling
Asphalt Paving and Roofing
Automobile Salvage Yards
Automobile Salvage Yards
General Sawmills and Planing Mills
Concrete Products
Landfills, Land Application, etc
Concrete Products
Coal Mining
General Sawmills and Planing Mills
Coa! Mining
Water Transportation
Water Transportation
Other, non-Wood Preserving
Landfills, Land Application, etc
Sand and Gravel Mining
Soaps, Detergents, Perfumes, etc.
Metal Fab, exc. Coat/Eng.
Soaps, Detergents, Perfumes, etc.
Metal Fab, exc. Coat/Eng.
Other, non-Wood Preserving
General Sawmills and Planing Mills
Water Transportation
Metal Fab, exc. Coat/Eng.
Rubber Products
Steam Electric Generating Facilities
Metal Fab, exc. Coat/Eng.
Coating and Engraving
Plastics, Synthetic Resins
Coal Mining
Coating and Engraving
Pollutant
Lead
Nitrate/Nitrite N
Aluminum
Iron
TSS
TSS
Lead
TSS
TSS
TSS
TSS
tron
Iron
Zinc
Aluminum
Aluminum
Iron
TSS
Iron
TSS
Nitrate/Nitrite N
Zinc
Zinc
Nitrate/Nitrite N
COD
COD
Zinc
Aluminum
Zinc
Iron
Iron
Nitrate/Nitrite N
Zinc
TSS
Zinc
Median
Change
100%
100%
95%
95%
94%
91%
90%
89%
88%
84%
84%
83%
83%
79%
78%
78%
78%
78%
65%
60%
59%
57%
56%
50%
39%
29%
13%
9%
2%
2%
-15%
-44%
-86%
-171%
-1003%
Median Median Concentration Reduction
78%
                             K-2

-------
Sector* Subsector Name
Pollutant
Median  Median by
Change  Pollutant
M
H
Q
AA
A
A
M
E
H
Q
L
O
AA
Q
M
J
C
AA
AA
A
D
M
A
E
L
A
J
H
A
AA
C
Q
Y
C
AA
Automobile Salvage Yards
Coal Mining
Water Transportation
Metal Fab, exc. Coat/Eng.
Other, non-Wood Preserving
Genera! Sawmills and Planing Mills
Automobile Salvage Yards
Concrete Products
Coal Mining
Water Transportation
Landfills, Land Application, etc
Steam Electric Generating Facilities
Metal Fab, exc. Coat/Eng.
Water Transportation
Automobile Salvage Yards
Sand and Gravel Mining
Soaps, Detergents, Perfumes, etc.
Metal Fab, exc. Coat/Eng.
Coating and Engraving
Log Storage and Handling
Asphalt Paving and Roofing
Automobile Salvage Yards
General Sawmills and Planing Mills
Concrete Products
Landfills, Land Application, etc
Other, non-Wood Preserving
Sand and Gravel Mining
Coal Mining
General Sawmills and Planing Mills
Metal Fab, exc. Coat/Eng.
Soaps, Detergents, Perfumes, etc.
Water Transportation
Rubber Products
Plastics, Synthetic Resins
Coating and Engraving
Aluminum
Aluminum
Aluminum
Aluminum
COD
COD
iron
Iron
Iron
Iron
Iron
Iron
Iron
Lead
Lead
Nitrate/Nitrite N
Nitrate/Nitrite N
Nitrate/Nitrite N
Nitrate/Nitrite N
TSS
TSS
TSS
TSS
TSS
TSS
TSS
TSS
TSS
Zinc
Zinc
Zinc
Zinc
Zinc
Zinc
Zinc
95%
78%
78%
9%
39%
29%
95%
83%
83%
78%
65%
2%
-15%
100%
90%
100%
59%
50%
-44%
94%
91%
89%
88%
84%
84%
78%
60%
-171%
79%
57%
56%
13%
2%
-86%
-1003%

78%


34%




78%



95%


55%






84%







13%



Median Median Concentration Reduction
               78%
                                    K-3

-------

-------
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ASIWPCA. 1985. America's Clean Water: The State's Nonpoint Source Assessment.
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Barret, M. E.. J.F. Malina, and R.J. Charbeneau. 1996. Effects of Highway Construction and
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Daniel T.C., P.E. Mcquire, D. Stoffei, and B. Miller.  1979. Sediment and Nutrient Yield From
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Marsh, J. M. 1993. Assessment of Nonpoint Source Pollution in Stormwater Runoff in
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National Association of Counties Research Foundation. 1970.  Urban Soil and Erosion and
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Newmark, J. 1992. Statistics and Probability in Modern Life. 5th ed. Saunders College
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NRDC. 1999. Stormwater Strategies: Community Responses to Runoff Pollution. Natural
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                                         R-l

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Sacramento. 1999.  City of Sacramento Stormwater Pollution Tracking Survey. Prepared by
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Toy, TJ. and R.F. Hadley. 1987. Geomorphology and Reclamation of Disturbed Lands.
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USEPA. 1983. Results of the Nationwide Urban Runoff Program, Volume 1: Final Report. U.S.
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USEPA. 1992b. Storm Water Management for Construction Activities: Developing Pollution
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USEPA. 1993. Urban Runoff Pollution Prevention and Control Planning. EPA-A -625-004. U.S.
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USEPA. 1995. Storm Water Discharges Potentially Addressed by Phase II of the National
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USEPA. 1997. EPA Interim Guidance for Implementing the Small Business Regulatory
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USEPA. 1998. National Water Quality Inventory: 1996 Report to Congress.  EPA841-R-97-008.
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USEPA. 1999a. Report to Congress on the Phase II Storm Water Regulations. EPA 833-R-99-
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                                        R-2

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