Gail B. Boyd Woodward-Clyde Consultants

1. Management of Storm Water Quality Gail B. Boyd Woodward-Clyde Consultants California State University Sacramento February 1998 L-1a

2. Management of Storm Water Quality Gail B. Boyd Woodward-Clyde Consultants International Erosion Control Association Reno, Nevada February 1998 L-1b

3. OVERVIEW I. Technical Aspects II. Regulatory Aspects III. Planning an Effective Compliance Program L-2

4. I. TECHNICAL ASPECTS OF STORM WATER POLLUTION L-3

5. TECHNICAL ASPECTS • Storm water related pollutants • Pollutant sources • Transport mechanisms • Water quality and habitat impacts • Relative scale of this problem L-4

6. TYPICAL POLLUTANTS IN STORM WATER • Toxic substances (e.g., heavy metals, organic chemicals) • Oil and grease • Nutrients (e.g., phosphates, nitrates) • Oxygen-demanding substances • Sediments (clean and contaminated) • Pathogens (e.g., bacteria, virus) L-5

7. MAJOR SOURCES OF POLLUTANTS • Air pollutants • Eroded soil and minerals • Construction materials (e.g., weathered paint, wood preservatives, roofing, siding) • Manufactured products (e.g., automotive products and worn parts, cleansers, solvents, fertilizers, pesticides) L-6a

8. MAJOR SOURCES OF POLLUTANTS (Continued) • Flora and fauna • Exposed outdoor storage, handling, and disposal of chemicals and other materials • Exposed process equipment • Unmanaged or improper releases or disposal (e.g., leaks, spills, illicit sewer connections, illegal dumping) L-6b

9. MAJOR “PROCESSES” AND PATHWAYS • Raindrop nucleation/formation • Atmospheric scrubbing • Contact and washoff • Direct introduction • Erosion • Transport/deposition/scour L-7

10. TYPICAL STORM WATER IMPACTS • Interference with beneficial uses: • Impacts on aquatic ecosystems (e.g., toxics, oil and grease, oxygen demand, algal nutrients, turbidity, siltation) • Impacts on water supplies (e.g., public health effects, odor, taste, turbidity) • Impacts on recreation and aesthetics (e.g., floating debris, oil and grease, turbidity, odors) • Impacts on navigation (e.g., siltation of channels and harbors) L-8a

11. TYPICAL STORM WATER IMPACTS (Continued) • Increased frequency of standard violations: • Water quality exceedances • Sediment quality exceedances • Shellfish bed closures • Increased cost of providing basic public works services: • Water supply costs • Wastewater disposal costs L-8b

12. MAJOR DETERMINANT FACTORS • Meteorology and air quality • Watershed characteristics (e.g., land uses, soil types) • Conveyance system size and type • Receiving water type and hydrography • Sensitivity of beneficial uses L-9

13. RELATIVE IMPORTANCE OF PROBLEM • Annual loadings of pollutants from urban storm water are roughly comparable to the loadings from POTW discharges. • Ninety-plus percent of spending has been on half of the problem. • We cannot meet national or state water quality goals without controlling storm water pollutants. L-10

14. NATIONWIDE URBAN RUNOFF PROGRAM (NURP) • Funded by EPA Headquarters (approx. $30 million) • Carefully designed to provide credible information on urban storm water quality via consistent field, lab and data analysis methods • Methods were optimized toward providing a “national perspective” and to maximize “transferability” • Led to the Report to Congress that was used to amend the Clean Water Act L-11

15. OVERVIEW OF NURP STUDY • Comprehensive scope: • 28 separate studies in 20 states • 81 monitoring sites • 2,300+ storm events • Wetfall/dryfall/runoff contributions • Soluble/particulate relationships • Numerous pollutants (conventional, priority, bacteria) L-12

16. KEY NURP FINDINGS: • Heavy metals (especially copper, lead and zinc) are by far the most prevalent priority pollutant constituents found in urban runoff. • End-of-pipe concentrations exceed EPA ambient water quality criteria and drinking water standards in many instances. • Some of the metals are present often enough and in high enough concentrations to be potential threats to beneficial uses. L-13a

17. KEY NURP FINDING: • Organic priority pollutants were detected less frequently and at lower concentrations than the heavy metals. L-13b

18. KEY NURP FINDING: • Coliform bacteria are present at high levels in urban runoff and typically exceed EPA water quality criteria during and immediately after storm events in many surface waters, even those providing high degrees of dilution. L-13c

19. KEY NURP FINDING: • Nutrients are generally present in urban runoff, but with a few exceptions, concentrations are not high in comparison with other discharges to receiving waters. L-13d

20. KEY NURP FINDINGS: • Oxygen demanding substances are present in urban runoff at concentrations approximating those in secondary treatment plant discharges. • If dissolved oxygen problems are present in receiving waters of interest, consideration of urban runoff controls and/or advanced waste treatment may be warranted. L-13e

21. KEY NURP FINDINGS: • Total suspended solids concentrations in urban runoff are fairly high in comparison with treatment plant discharges. • Urban runoff control is strongly indicated where water quality problems associated with TSS, including build-up of contaminated sediments, exist. L-13f

22. II. REGULATORY ASPECTS OF STORM WATER POLLUTION CONTROL L-14

23. REGULATORY ASPECTS • Historical overview of Federal water quality law and regulatory programs • Regulatory perspective and policies • Regulations that apply to municipalities, industries, construction activities, and other major sources of storm water pollutants (SWI and SWII) • Problems with the storm water regulations L-15

24. EVOLUTION OF FEDERAL REGUALTIONS The 1972 Amendments to Federal Water Pollution Control Act did the following: • Established the NPDES Permit Program to control discharge of pollutants from point sources. • Focused on industrial process wastewater and municipal sewage. • Led to programs that emphasized technology based controls. L-16a

25. REGULATORY EVOLUTION (Continued) • EPA’s regulatory focus has been directed toward controlling major wastewater discharges. • EPA has also supported active research/demonstration programs to develop a sound technical understanding of storm water pollution sources, impacts and controls. L-16b

26. REGULATORY EVOLUTION(Continued) • A large investment has already been made in wastewater treatment facilities (i.e., municipal and industrial) • We still have very significant water quality problems in some locations. L-16c

27. REGULATORY EVOLUTION(Continued) • Emphasis has been shifting toward: • control of toxic substances • control of pollutants that are discharged from storm water conveyance systems • water quality-based control strategies • watershed-scale pollution control strategies • The Federal storm water regulations reflect these changing priorities. L-16d

28. REGULATORS’ PERSPECTIVE EPA Headquarters recognizes that the following groups of people must move “way up the learning curve” before storm water quality will improve significantly: • Regulators and legislators • Storm water dischargers • Consultants and academicians • The public (at work and at home) L-17a

29. REGULATORS’ PERSPECTIVE (Continued) Dischargers (i.e., municipalities, industrial facilities, construction activities) should: • develop an understanding of storm water systems and associated water pollution problems • develop basic information needed for planning system-specific water pollution controls • begin the process of working with regulators re: storm water management L-17b

30. FEDERAL STORM WATER REGULATIONS • SWI regulations became effective in November 1990, after many years’ evolution at EPA • Draft of SWII regulations currently under public review; finalization expected next Winter • Regulations are based in Federal law (Clean Water Act), but most permits will be issued and enforced by state-level water quality agencies. L-18a

31. FEDERAL STORM WATER REGULATIONS (Continued) • Utilize EPAs existing NPDES permitting process • Apply to most significant dischargers of storm water (municipal systems, industrial systems, construction activities) • Require dischargers to develop descriptive information, prepare and submit permit applications, and implement storm water management plans and controls stipulated by permits. L-18b

32. REGULATORY REQUIREMENTS The regulations require applicants to be introspective about the following: • What is your storm water conveyance system like? • What pollutants get into your system? • Where do they come from and where do they go? • What do you presently do to minimize storm water pollution problems? • What else do you need to do? L-19a

33. REGULATORY REQUIREMENTS(Continued) The regulations do not explicitly require applicants to deal with the following issues: • What overall quantities of pollutants are discharged to the receiving waters (i.e., from all sources, combined, including point sources and non-point sources from other industries and local municipalities)? • What impacts can be rightly attributed to storm water-borne pollutants (e.g., standards violations, ecosystem impairment, health effects)? • What other factors contribute to the overall problems (e.g., poor circulation, elevated temperature, polluted sediments)? L-19b

34. REGULATORY REQUIREMENTS(Continued) The regulations do not explicitly require applicants to deal with the following issues: • To what extent should storm water-borne pollutants from your system be reduced? • What would a technically-adequate program consist of, and what would it cost? • Would the benefits be worth the costs? • How should the effectiveness of your control program be monitored, evaluated, and documented? L-19c

35. REGULATORY PROBLEM Regulators and dischargers both have a difficult time dealing with the lack of specificity in the regulations. • Who will decide what needs to be done at a given site? • What will be their basis for specifying controls? • Will they know enough to make a good decision? • What should I do to inform them adequately? • What should I do to inform myself and my managers to be sure our objectives are met? • How pro-active should we be? L-20

36. HIERARCHY • Congress • EPA/Headquarters • EPA/Regional Offices • State Water Quality Agencies • Regional Water Quality Agencies • Municipalities • Commercial/Industrial Dischargers • Construction Project Managers L-21

37. POLLUTANT SOURCES TARGETED BY REGULATIONS • Storm water runoff • Illicit connections • Illegal dumping L-22

38. STORM WATER RUNOFF Cause: Pollutants tend to be widely distributed within typical urban areas and industrial sites. These pollutants get washed off of surfaces by rainfall and get carried into and through storm drain systems during runoff events. Pollutants carried in urban runoff and industrial site runoff are generally most evident during and just following storm events. Their impacts may extend for much longer periods. Timing: L-23a

39. STORM WATER RUNOFF (Continued) Detection/Characterization: The regulations require only very limited efforts to characterize storm water. The required degree of monitoring is generally not adequate for developing meaningful insights regarding the relationships between pollutant loads, land use, or other important causative factors. Control: EPA believes that most pollution from municipal, commercial, and industrial storm runoff can be controlled by non-structural “Best Management Practices.” L-23b

40. ILLICIT CONNECTIONS Cause: Pollutants also enter storm drainage systems via “illicit connections” with sanitary sewers and/or commercial or industrial discharge lines. Some such connections reflect malice, others reflects ignorance -- all are illicit. Timing: Pollutants from illicit connections often exhibit some repetitive pattern which may reflect a diurnal pattern of work schedules or a pattern of process waste discharge. L-24a

41. ILLICIT CONNECTIONS (Continued) Detection/Characterization: The regulations require a moderate-scale effort to detect and characterize illicit connections. The efforts involve field inspections, sampling, and analyses during times of dry weather or low runoff volume to maximize the chance of detecting illicit discharges. Control: EPA assumes that pollution problems from illicit connections are significant in most areas, that they can be detected and prevented by aggressive inspection/enforcement efforts, and that such efforts are very cost effective. L-24b

42. ILLEGAL DUMPING L-25a

43. ILLEGAL DUMPING (Continued) Detection/Characterization: The regulations require field inspections, sampling, and analyses to look for evidence of illegal dumping. Because such acts typically occur randomly, it would take a great deal of field work to “catch someone in the act.” Control: EPA assumes that pollution problems from illegal dumping are serious in most areas and that they can be detected and prevented by aggressive inspection/ enforcement efforts. EPA favors programs that educate potential polluters and provide convenient alternatives for proper waste disposal. L-25b

44. III. PLANNING AN EFFECTIVE COMPLIANCE PROGRAM L-26

45. ELEMENTS OF STRATEGIC PLANNING 1. Develop a clear understanding of the regulations. 2. Determine the requirements that apply to your system. 3. Establish clear communications and open working relationships with senior and mid-level regulatory agency personnel. 4. Determine the regulatory agencies’ authorities, jurisdictions, objectives, priorities, and intended schedule. 5. Identify potential co-applicants and define basic organizational relationships and responsibilities. 6. Develop an overall strategy that covers all phases (i.e., permit application and compliance). Decide: How much is enough? L-27a

46. HOW MUCH IS ENOUGH? Strategically Pro-active Minimal Program Typical Program Disengaged Resistant L-27b

47. DISENGAGED L-27c

48. RESISTANT L-27d

49. MINIMAL PROGRAM L-27e

50. TYPICAL PROGRAM L-27f