v>EPA United States Environmental Protection Agency Office of Water Washington, D.C. EPA 832-F-99-022 September 1999 Storm Water Management Fact Sheet Non-Storm Water Discharges to Storm Sewers DESCRIPTION Identifying and eliminating non-storm water discharges to storm sewers is an important and very cost-effective Best Management Practice (BMP) for improving runoff water quality. Non-storm water discharges can include discharges of process water, air conditioner condensate, non-contact cooling water, vehicle wash water, or sanitary wastes, and are typically the result of unauthorized connections of sanitary or process wastewater drains to storm sewers. These connections are common, yet often go undetected. Typically these discharges are significant sources of pollutants, and, unless regulated by an NPDES permit, they are also illegal. Environmental impact evaluations have shown that the elimination of non-storm water discharges is an effective BMP, because such discharges may contain a significant loading of pollutants. Several studies exist on the contents of non-storm water discharges. Pitt and Shawley (1982) reported that non-storm water discharges were found to contribute substantial quantities of a variety of pollutants, even though the individual concentrations of each pollutant were not high. During extended periods of base flow conditions, the lower concentration was offset, leading to a substantial loading of pollutants. Gartner, Lee and Associates, Ltd. (1983) conducted an extensive survey of non-storm water discharges in the Humber River watershed (Toronto). Out of 625 outfalls, about 10 percent were considered significant pollutant sources. Further investigations identified many industrial and sanitary non-storm water discharges into the storm drainage system. Sources found in industrial areas included liquid dripping from animal hides stored in tannery yards, and washdowns of storage yards at meat packing facilities. Therefore, it is anticipated that elimination of non-storm water discharges will be a highly effective BMP. Identifying and eliminating non-storm water discharges has rarely been done at industrial facilities. Part of the problem is education: many facility operators are unaware of what constitutes a non-storm water discharge and what the potential environmental impacts of these discharges are. Compliance with NPDES permit requirements for the presence of non-storm water discharges will greatly improve the implementation of this BMP. APPLICABILITY Almost every industrial facility that has not been tested or evaluated for the presence of potential non-storm water discharges should be so evaluated. Typically NPDES permit certification includes: • Identification of potential non-storm water discharges. Results of a site evaluation for the presence of non-storm water discharges. • The evaluation criteria or test method used. • The date of testing and/or evaluation. • The on-site drainage points that were directly observed during the test and/or evaluation. This certification must be signed in accordance for the facility's NPDES storm water permit. A sample certification form is shown in Figure 1. ------- ADVANTAGES AND DISADVANTAGES Identifying and eliminating non-storm water discharges can be an easy and cost-effective method for preventing runoff contamination and pollution of receiving water bodies. However, identifying these discharges may be problematic. Possible problems in identifying non-storm water discharges include: A non-storm water discharge may not occur on the date of the test or evaluation. • The method used to test or evaluate the discharge may not be applicable to the situation. • A lack of available data on the location of storm drains and sanitary sewers, especially in older industrial facilities, may make identifying an illicit connection difficult. KEY PROGRAM COMPONENTS Key program criteria include identifying and locating non-storm water entries into storm drainage and investigating their sources. For any effective investigation of pollution within a storm water system, all pollutant sources must be included. For many pollutants, storm water may contribute the smaller portion of the total pollutant mass discharge from a storm drainage system. In addition to conventional storm water runoff associated with rainfall, pollutant sources may include dry-weather entries occurring during both warm and cold months and snowmelt runoff. Consequently, much less pollution reduction benefit will occur if only storm water is considered in a control plan for controlling storm drainage discharges. The investigations may also identify illicit point source outfalls that do not carry storm water. Obviously, these outfalls also need to be controlled and permitted. Figure 1 can be used as a sample worksheet to report non-storm water discharges. There are four primary methods for investigating non-storm water discharges. Visual Inspection The simplest method for detecting non-storm water connections in the storm water collection system is to observe all discharge points during periods of dry weather. Key parameters to look for are the presence of stains, smudges, odors, and other abnormal conditions. Sanitary and Storm Sewer Map Review A review of a plant schematic is another simple way to determine if there are any unauthorized connections to the storm water collection system. A sanitary or storm sewer map, or plant schematic, is a map of pipes and drainage systems used to carry NON-STORM WATER DISCHARGE ASSESSMENT AND CERTIFICATION Date of Test or Evaluation Outfall Directly Observed During the Test (Identify as indicated on the site map) Method Used to Test or Evaluate Discharge Worksheet Comple Title: ted By: Date: Signature: Describe Results from Test for the Presence of Non- Storm Water Discharge Identify Potential Significant Sources Name of Person Who Conducted the Test or Evaluation Source: U. S. EPA, 1992. FIGURE 1 SAMPLE WORKSHEET FOR RECORDING NON-STORM WATER DISCHARGES ------- process wastewater, non-contact cooling water, and sanitary wastes. These maps (especially as-built plans) should be reviewed to verify that there are no unauthorized connections. However, a common problem at many sites is that they often do not have accurate or current schematics. Dye Testing Another method for detecting improper connections to the storm water collection system is dye testing. A dye test can be performed by simply releasing a dye (either pellet or powder) into either the sanitary or process wastewater system. Discharge points from the storm water collection system are then examined for color change. Sampling and Chemical Analysis Sewer mapping and visual inspection are also helpful in identifying locations for sampling. Chemical tests are needed to supplement the visual or physical inspections. Chemical tests can help quantify the approximate components of the discharge mixture at the outfall or discharge point. Samples should be collected, stored, and analyzed in accordance with standard quality assurance and quality control (QA/QC) procedures. Statistical analysis of the chemical test results can be used to estimate the relative magnitudes of the various flow sources. In most cases, non-storm water discharges are made up of many separate sources of flow, such as leaking domestic water systems, sanitary discharges, ground water infiltration, automobile washwater, etc. Key parameters that can be helpful in identifying the source of the non-storm water flows include biochemical oxygen demand (BOD), chemical oxygen demand (COD), total organic carbon (TOC), specific conductivity, temperature, fluoride, hardness, ammonia, ammonium, potassium, surfactant fluorescence, pH, total available chlorine, and toxicity screening. It may be possible to identify the source of the non-storm water discharge by examining the flow for specific chemicals. Just as high levels of pathogenic bacteria are usually associated with a discharge from a sanitary waste water source, the presence of certain chemicals is generally associated with specific industries. Table 1, includes a listing of various chemicals that may be associated with a variety of activities. IMPLEMENTATION Identification of non-storm water discharges should be part of every facility's maintenance program. Facilities should conduct annual inspections for non-storm water discharges, even if previous tests have found no such discharges. New processes, building additions, or other plant changes may have brought about unauthorized connections to the storm water conveyance system. COSTS The above methods are mostly time-intensive; therefore, the cost is dependent on the level of effort employed, and on the level of expertise. Visual inspections are the least expensive of the three. Dye testing may be more cost effective for buildings that do not have current schematics of their sanitary and storm sewer systems. The cost of disconnecting illicit discharges from the storm water system will vary depending on the type and location of the connection. The full use of all of the applicable procedures is most likely necessary to identify all pollutant sources. For example, attempting to reduce costs by examining only a certain class of outfalls, or using inappropriate testing procedures, will significantly reduce the utility of the testing program and result in inaccurate conclusions. REFERENCES 1. California Environmental Protection Agency, Draft, 1992. Staff Proposal for Modification to Water Quality Order No. 91-13D WQ Waste Discharge Requirements for Discharges of Storm Water Associated with Industrial Activities. 2. Gartner, Lee and Associates, Ltd., 1983. Toronto Area Watershed Management Strategy Study, Technical Report No. 1, Number River and Tributary Dry Weather Outfall Study. Ontario Ministry of the Environment, Toronto, Ontario. ------- TABLE 1 CHEMICALS COMMONLY FOUND IN INDUSTRIAL DISCHARGES Chemical Acetic Acid Alkalis Ammonia Arsenic Chlorine Chromium Cadmium Citric Acid Copper Cyanides Fats, Oils Fluorides Formalin Hydrocarbons Hydrogen Peroxide Lead Metcaptins Mineral Acids Nickel Nitro Compounds Organic Acids Phenols Silver Starch Sugars Sulfides Sulfites Tannic Acid Tartaric Acid Zinc Industries Acetate rayon, pickle and beetroot manufacture Cotton and straw kiering, cotton manufacture Gas and coke manufacture, chemical manufacture Sheep-dipping, felt mongering Laundries, paper mills, textile bleaching Plating, chrome tanning, aluminum anodizing Plating Soft drinks and citrus fruit processing Plating, pickling, rayon manufacture Plating, metal cleaning, case-hardening, gas manufacture Wool scouring, laundries, textiles, old refineries Gas and coke manufacture, chemical manufacture, fertilizer plants, Manufacture of synthetic resins and penicillin Petrochemical and rubber factories Textile bleaching, rocket motor testing Battery manufacture, lead mining, paint manufacture, gasoline Oil refining, pulp mills Chemical manufacture, mines, iron and copper pickling, brewing, textiles Plating Explosives and chemical works Distilleries and fermentation plants Gas and coke manufacture, synthetic resin manufacture, textiles, Plating and photography Food, textile, wallpaper manufacture Dairies, foods, sugar refining, preserves, wood process Textiles, tanneries, gas manufacture, rayon manufacture Wood process, vicose manufacture, bleaching Tanning, sawmills Dyeing, wine, leather, and chemical manufacture Galvanizing, plating, viscose manufacture, rubber process Source: Pitt et a/., 1992. ------- 7. Pitt, R. and G. Shawley, 1982. A Demonstration of Non-Point Pollution Management on Castro Valley Creek, Alameda County Flood Control District (Hayward, California) and U.S. EPA, Washington, DC. Pitt, R., D. Barbe, D. Adrian, and R. Field, 1992. Investigation of Inappropriate Pollution Entries Into Storm Drainage Systems - A Users Guide, U.S. EPA, Edison, New Jersey. Pitt, R., and R. Field, 1992. Non-Storm Water Discharges into Storm Drainage Systems. NTIS Report No. PB92-158559. U.S. EPA, 1992. Storm Water Management For Industrial Activities: Developing Pollution Prevention Plans and Best Management Practice. EPA 833-R- 92-006. Washington State Department of Ecology, February, 1992. Storm Water Management Manual for the Puget Sound Basin. Northern Virginia Planning District Commission David Bulova 7535 Little River Turnpike, Suite 100 Annandale, VA 22003 Southeastern Wisconsin Regional Planning Commission Bob Biebel 916 N. East Avenue, P.O. Box 1607 Waukesha, WI53187 The mention of trade names or commercial products does not constitute endorsement or recommendation for the use by the U.S. Environmental Protection Agency. ADDITIONAL INFORMATION Center for Watershed Protection Tom Schueler 8391 Main Street Ellicott City, MD21043 King County, Washington Dave Hancock Department of Natural Resources, Water and Land Resources Division, Drainage Services Section 700 5th Avenue, Suite 2200 Seattle, WA 98104 State of Minnesota Lou Flynn Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155 For more information contact: Municipal Technology Branch U.S. EPA Mail Code 4204 401 M St., S.W. Washington, DC, 20460 IMTB Exceience fh compliance through optftnal technical sotrtroru: MUNICIPAL TECHNOLOGY ------- |