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

-------