Storm Water Pollution Prevention

January 1999 - TI#19156
Introduction
Applicable Policies, Instructions, and Regulations
Common Storm Water Pollutants
Air Force Activities That Can Pollute Storm Water
Prevention of Storm Water Pollution
The Installation Storm Water Program Management Guide
For More Information
Document References


Introduction
In open fields, forests, and wetlands, most rain is absorbed by the soil or is taken up by plants and trees. In developed areas, rain that falls on impermeable roofs, parking lots, streets, and lawns is not absorbed. Instead, it travels down roadways, settles in gutters and ditches, and flows through storm drains to finally end up in rivers, lakes, and wetlands. Rainwater that enters a surface water body, by flowing either overland or through a storm sewer system, is called storm water or storm water runoff.

Storm water runoff is one of the leading causes of pollution in rivers and lakes. In both urban and agricultural settings, it can dissolve and transport a variety of chemicals, fertilizers, pesticides, and litter picked up while traveling overland. Identifying sources of storm water pollution and keeping them from coming in contact with runoff is the best and most economical way to protect the quality of the nation's waters.

The purpose of this Fact Sheet is to describe the nature and occurrence of storm water pollution, its environmental effects, and ways to address this important water quality problem. The Fact Sheet also discusses regulations and policies applicable to Air Force activities, the Air Force Installation Storm Water Program Guide, and sources for more information.


Applicable Policies, Instructions, and Regulations
The Clean Water Act is the principal federal legislation that addresses water pollution issues. The Clean Water Act (CWA) has regulated the discharge of pollutants from "point sources," such as industrial processes and sewage treatment plants, to waters of the U.S. since 1972. These discharges are subject to permitting under the National Pollutant Discharge Elimination System (NPDES) Program section of the CWA. In 1987, amendments to the CWA directed the Environmental Protection Agency (EPA) to develop regulations specific to discharges of storm water runoff associated with industrial activities. This change in the statute came about as a result of the "National Urban Runoff Program Study" which indicated that storm water runoff from cities and industrial activities (including construction activities) carried pollutants to our nation's water bodies. Most states have been delegated the authority to administer the federal NPDES storm water permit program, including the review of applications and the issuance of permits.

Rules promulgated for the 1987 Amendments to the CWA regarding storm water discharges are found in Title 40 Code of Federal Regulations (CFR) Parts 122-124. These rules establish an application process for obtaining NPDES storm water discharge permits and categorizes storm water discharges as either "Phase I" or "Phase II." Phase I storm water discharges are those having the greatest potential to contaminate runoff and include industrial sectors such as manufacturing, transportation, landfills, certain wastewater treatment facilities, hazardous waste treatment/storage/disposal areas, large municipal separate storm sewer systems (MS4s), and large construction sites (over 5 acres). Phase II storm water discharges are those not addressed under Phase I of the program and include runoff from golf courses, housing areas, small construction sites (between 1 and 5 acres), large parking areas, gas stations, and MS4s serving populations less than 100,000. Under EPA's storm water regulations and general permits applying to Phase I discharges, Air Force installations have several industrial categories/processes that may require permitting including aircraft, plating, transportation, and solid/liquid waste stream management systems and activities. EPA published its final rule for Phase II storm water discharges in Vol-64, No. 235 of the Federal Register on 8 December 1999 (copies available from PRO-ACT) that require NPDES permits. Provisions of the final rule include "various exemptions" that allow certain sources to be excluded from the NPDES program based on their lack of impact on water quality, as well as the inclusion of sources not normally regulated based on their localized impact on water quality. Finally, EPA is conditionally excluding from the NPDES storm water program those industrial facilities whose activities pose "no exposure" to storm water. EPA hopes the final rule will be a more cost-effective approach to reducing the negative environmental impacts associated with storm water discharges. They also hope it will bring about increased utilization of general permits, a greater variety in watershed protection approaches, an increase in the use of available methods for public participation, and will be cost-effective. Permit enforcement begins in the year 2001.

Executive Order 12088, "Federal Compliance with Pollution Control Standards," 13 October 1978, requires the Air Force to take all necessary actions to prevent, control, and abate environmental pollution at all Air Force installations and to comply with applicable federal environmental regulations.

Air Force Policy Directive (AFPD) 32-70, "Environmental Quality," 20 July 1994, states "The Air Force will prevent future pollution by reducing use of hazardous materials and releases of pollutants into the environment to as near zero as feasible." The AFPD also directs that any spent waste that cannot be reused or recycled will be disposed of in an environmentally safe manner consistent with the requirements of all applicable laws.

AFI 32-7041, "Water Quality Compliance," 13 May 1994, implements the water quality requirements of AFPD 32-70. It applies to generating, collecting, treating, reusing, and discarding: domestic and industrial wastewater, storm water, non-point source runoff, sewage sludge, and water treatment residuals. The AFI states that the Clean Water Act and EPA regulations form the basis of the Water Quality Compliance Program, which requires Air Force compliance with permit standards under the National Pollutant Discharge Elimination System (NPDES) and other applicable federal, state, and local water quality regulations. To this end, the AFI explains how to assess, attain, and sustain compliance with: the Clean Water Act; other federal, state and local environmental regulations; and related Department of Defense (DoD) and Air Force directives. (NOTE: Water quality compliance requirements at installations outside the U.S. and its territories are addressed in AFI 32-7006, "Environmental Program in Foreign Countries," Chapter 4 of DoD's "Overseas Environmental Baseline Guidance Document" [OEBGD], and in country-specific Final Governing Standards [FGS]).


Common Storm Water Pollutants
Oil and Grease - Oil from vehicles, storage tanks, and machinery, as well as grease from dining hall waste can be carried by storm water into surface waters. Oil and grease float on the water's surface and block sunlight needed by underwater fish and plants. Oil and grease can also damage stream habitat and sensitive spawning areas when it settles and clings to sand and gravel particles.

Heavy Metals - Heavy metals, such as lead, zinc, and mercury, are ingredients in many commonly used products like batteries, fuels, paints, pesticides, and cleaners (e.g. algaecides). Heavy metals can also be found in industrial-strength materials like rubber. When these products are spilled or improperly discarded, or when materials containing heavy metals break down, they leave behind pollutants that can be readily transported (in dissolved or undissolved form) into streams by storm water. Heavy metals can be toxic to fish and other aquatic life in streams.

Nutrients - Nutrients like phosphorus and nitrogen are transported into streams when storm water picks up fertilizer and animal manure residues on the ground in agricultural areas. Excessive amounts of nutrient buildup in surface water bodies can disrupt the normal ecosystem.

Chemicals - Toxic chemicals, especially organic chemicals found in fuels, paints, cleaning products, and pesticides, have a wide range of toxic effects on fish and aquatic life, including causing tumors and skin lesions and disrupting reproductive functions. Chemicals can enter storm water through improper storage practices and through misapplication.

Mud and Sediment - When storm water flows across the land, and in particular construction sites and unplanted fields, it picks up loose particulate matter that is carried into streams. It can then settle to the bottom of the stream bed in a process commonly called sedimentation. When too much sediment accumulates on stream beds, it damages fish-spawning areas, alters habitats where bottom-dwelling organisms live and reproduce, and interferes with fish migration. In addition, dirt and sand often pick up oil and grease in their path, which introduces additional chemical contaminants that are toxic to fish and other aquatic organisms.

Litter - Debris that overflow from waste receptacles and litter thrown onto the ground are readily carried by storm water into streams and rivers. They can harm fish and aquatic life directly or indirectly by hindering sunlight penetration in much the same manner as oil and grease.

Abnormal pH - When storm water mixes with chemicals or chemical products that are acidic or alkaline, the pH of the water will change. Acidic or alkaline conditions in streams can harm fish, especially sensitive juvenile fish, and other aquatic plants and organisms.

Coliform Bacteria - At high levels, naturally occurring coliform bacteria from human and animal wastes can contaminate water. It is very important to prevent the accumulation of human and animal waste in areas drained by storm water collection systems; however, the majority of coliform bacteria contamination in water results from uncontrolled overflows from major wastewater treatment works.


Air Force Activities That Can Pollute Storm Water
Many routine activities occur on most Air Force installations that, if not managed properly, have the potential to cause storm water pollution. Some of these activities include:
  • Flightline operations, specifically deicing/anti-icing operations and associated runoff of spent deicers;
  • Refueling, engine repair, equipment washing, and painting activities, especially when these activities occur outdoors or when wastewater is released outside;
  • Excessive accumulation of chemicals, litter, and dirt on roads, parking lots, and other paved surfaces;
  • Outdoor vehicle, equipment, and material storage that exposes spilled, leaked, and overflowing fluids and chemicals to rain and storm water runoff;
  • Outdoor cleaning and maintenance activities like power washing, sandblasting, and car washing that produce large volumes of wastewater;
  • Construction activities that excavate land, exposing loose dirt and sand;
  • Over-application of fertilizers and pesticides to agricultural land, residential lawns, and com- mercial landscapes; and
  • Improperly managed landfills, trash storage areas, and waste handling and disposal activities.

Prevention of Storm Water Pollution
There are many approaches to the prevention and control of storm water pollution, ranging from simple measures taken on an individual basis, to larger scale plans instituted installation-wide.

Individual Efforts
Individual efforts, like those listed below, may appear simple or minor; however, when employed universally across an installation, they can have a significant impact on the prevention of storm water pollution:

  • Dispose of litter and waste properly.
  • Keep storm drains clear of debris, dirt, sand, silt, and wastes.
  • Use drip pans to catch leaks of petroleum products, fuels, and other fluids. Recycle or properly dispose of spent automotive lubricants, antifreeze, and other fluids. Participate in the installation's oil recycling program. Contact your activity's coordinator for more information on recycling vehicle fluids.
  • Wash cars or other greasy equipment at facilities, such as commercial car washes, that collect wastewater and discharge it into a sanitary sewer where detergent and oily pollutants can be removed at sewage treatment plants.
  • Reduce or eliminate chemical pesticides and fertilizers for landscaping and lawns.
  • Plant around or pave areas prone to erosion to reduce the chance that loose dirt, soil, and sand will be carried away by storm water runoff.
Standard Industrial Classification (SIC) Codes

Storm water regulations only apply to certain types of industrial activities. At a typical Air Force base, this would include activities such as:
  • Aircraft/vehicle/equipment maintenance;
  • Aircraft/vehicle/equipment fueling;
  • Aircraft/vehicle/equipment washing;
  • Corrosion control operations;
  • Maintenance of equipment in support of bulk aviation and motor vehicle fuel storage;
  • Warehousing operations if the stored material has the potential to contaminate storm water;
  • Hazardous material storage;
  • Roads and grounds maintenance; and
  • Entomology operations.
The EPA currently classifies facilities by a Standard Industrial Classification (SIC) code, which identify groups of industries according to type of activity and potential to pollute. Air Force installations have several industrial processes that may require permitting. Some of these processes and SIC codes are listed in sections 2.1.4 and 4.2.4 of the Installation Storm Water Program Management Guide, discussed in a later section of this Fact Sheet.

Administration buildings, housing areas, dormitories, and shopping areas on Air Force bases are normally excluded from storm water permitting. If activities that can affect the base storm water system regularly occur in areas such as vehicle maintenance areas and parking areas, they may have to be permitted.

Storm Water Pollution Prevention Plans (SWPPPs)
Storm water pollution can also be prevented through the implementation of an installation-wide Storm Water Pollution Prevention Plan (SWPPP). Air Force installations may contain a variety of industrial facilities/buildings, which, due to their SIC code(s), require the installation to obtain a NPDES storm water permit. Application for a NPDES storm water permit, in turn, requires the development of a SWPPP. The SWPPP is a self-implementing plan for compliance with the storm water permit. The goal of the SWPPP is to reduce or eliminate potential sources of pollution coming in to contact with the storm water runoff. The key elements of the SWPPP are:

  • Identification/evaluation of potential sources of storm water pollution and their potential impact;
  • Management of sources of potential storm water pollution through the use of Best Management Practices (BMPs);
  • A procedure to inspect the installation, including industrial activities, and review the plan annually to ensure that pollution prevention and control procedures are effective and current; and
  • Training of employees on storm water pollution prevention issues.
The typical SWPPP will include:
  • A regimen of inspections based on storm water permit requirements;
  • All inspection, sampling, and training records, as well as any other records pertinent to the installation's Storm Water Program;
  • A procedure to assure the timely submittal of all reports and notifications to regulatory agencies required by the storm water permit;
  • Details of a monitoring program designed to comply with permit requirements and measure the impact of installation activities on storm water runoff;
  • An implementation schedule for projects and activities required to comply with the permit;
  • BMPs for each identified source of potential pollution; and
  • A log documenting any changes to the SWPPP.
Additional information about the preparation of a SWPPP is contained in the Installation Storm Water Program Management Guide, discussed in the next section.

The Storm Water Program Manager should be aware of other regulations, programs, and plans that contain information pertinent to the Storm Water Program and should be reviewed when writing and updating a SWPPP. The following is a partial list (refer to the Installation Storm Water Program Management Guide for more detailed information) of other installation environmental plans and programs that will help identify sources of storm water pollution and/or appropriate BMPs:

  • Documents prepared under the National Environmental Policy Act (NEPA).
  • Spill Prevention, Control, and Counter-measures (SPCC) Plans required under the CWA.
  • Wetlands Permits containing sampling requirements to monitor for storm water contaminants.
  • Treatment, Storage, or Disposal Facility (TSDF) permits under the Resource Conservation and Recovery Act (RCRA), RCRA Facility Assessments, and RCRA Facility Inspections.
  • Facility Response Plans prepared under the Oil Pollution Act of 1990 (OPA 90).
  • Toxic Release Inventory (TRI) reports prepared under the Emergency Planning and Community Right-to-know Act (EPCRA).
  • Pollution Prevention Plans prepared as required by Executive Order 12856.
  • Polychlorinated Biphenyl (PCB) Management Plans prepared under the Toxic Substances Control Act (TSCA).
  • Water Quality Management Plans and Wellhead Protection Plans prepared under the Safe Drinking Water Act (SDWA).
  • Opportunity Assessments and Management Action Plans prepared under EO 12856.
Examples of Best Management Practices (BMPs)
BMPs are designed to remove pollutants from storm water before it reaches a waterway. There are two types of BMPs: non-structural and structural.

Non-structural BMPs, also known as good housekeeping practices, are operating procedures that prevent the generation of storm water pollution and include:

Preventive Maintenance - Pipes, pumps, storage tanks, and storm water management devices require periodic maintenance to ensure equipment and structures are in good condition and will not pollute storm water. Replace worn gaskets and valves before leaks occur, and remove trash and residue from overflowing containers and receptacles.

Routine Inspections - To ensure equipment, machinery, vehicles, and tanks are not leaking, perform routine visual inspections and integrity tests. Conduct inspections in areas prone to leaks and in material storage, processing, and waste generation areas. Routinely monitor storage tanks, trash containers, and equipment for rust and wear.

Spill Response Planning - Put in place well designed spill prevention and cleanup procedures. The plan should identify all potential spill areas and have procedures developed for avoiding and responding to spills that do occur.

Erosion Control Measures - Use sediment and erosion control practices anywhere soil has been disturbed, particularly in construction and demolition areas. Minimize erosion by maintaining planted areas and designing landscape to reduce the amount of soil and dirt exposed to storm water runoff.

Structural BMPs are engineered controls that remove pollutants from storm water and usually include specially constructed devices/systems. Traditionally, structural BMPs included storm water ponds that collect storm water runoff and used oil-grit or oil-water separators to filter out oil and sand (a.k.a. grit) from storm water runoff in parking lots. More recently, new structures that manage and reduce pollution in storm water have been designed and constructed to use innovative techniques. For example, BMPs often rely on the natural filtering capacity of the ground and the absorption capabilities of plants to help with the removal of pollutants. Some filter pollutants from storm water by using natural and man-made materials such as straw bales, semi-porous plastic filter fabric, and silt fences. Common examples are:

Retention Structures - These are pond-like storm water control structures that act like natural ponds by slowing the flow of water and storing storm water behind an embankment. They may serve the dual purpose of collecting and recirculating process water from a building. These structures filter pollutants from storm water before discharging it into a storm drain or stream. Heavier suspended matter and pollutants are allowed to settle out of the storm water. This method is less effective in removing dissolved pollutants and microorganisms.

Infiltration Structures - These storm water control structures catch storm water and help it filter into the ground. Pollutants are removed from runoff that would otherwise discharge directly into a stream. These devices may include man-made materials like filter fabric, perforated pipes, or natural elements like certain types of soil, gravel, and sand to physically remove pollutants from storm water. Unlike retention structures that store and release storm water to surface water bodies, infiltration structures direct the flow of storm water into channels and other designated areas that permit storm water to gradually soak deeper into the ground. Infiltration structures are effective in removing suspended solids, bacteria, undissolved nutrients, oil and grease, and floating wastes; however, they are less effective at removing dissolved nutrients, some toxic pollutants, and chlorides (road salts).

Vegetative Structures - These are storm water management structures that rely on natural plantings and vegetation to remove pollutants such as suspended matter, undissolved metals, and bacteria from storm water. Some plants can readily absorb certain pollutants without apparent harm. For example, sunflowers and cattails can absorb low levels of dissolved metals without toxic effects. Natural wetlands and bogs are also very effective at filtering pollution from storm water. Grassed swales and filter strips are two types of storm water control structures that rely on plants and the ground surface to remove and filter pollutants from storm water.


The Installation Storm Water Program Management Guide
The Installation Storm Water Program Management Guide was developed by the Environmental Quality Directorate, Headquarters Air Force Center for Environmental Excellence, for use by base-level personnel responsible for implementing the storm water program. The guide, dated May 1997, provides information and tools to assist installations in achieving compliance with storm water permit requirements. Included in the guide are checklists, training slides, background information, and tips organized in a step-wise question and answer format.

A general summary of the Installation Storm Water Program Management Guide, highlighting the key features of each section, is presented below:

Regulatory Background
As mentioned above, the CWA is the principal piece of federal legislation addressing water pollution. This section of the guide discusses federal and state storm water programs and the types of permits an installation can expect to become involved with. The elements of a SWPPP (required as part of the storm water permitting process) are also discussed in this section.

Storm Water Program Management
The installation environmental management organization has primary responsibility for the maintenance of the SWPPP. This section provides guidance for the division of responsibilities associated with the successful development and implementation of the SWPPP, and presents an outline of a typical SWPPP. This section also discusses funding and training issues pertaining to the execution of a successful Storm Water Pollution Prevention Program.

Technical Implementation
This section provides the technical details necessary to implement a Storm Water Pollution Prevention Program, from reviewing projects that may degrade the quality of storm water runoff, to conducting storm water-related inspections and storm water sampling activities. Every Air Force installation has industrial activities that could have an impact on storm water quality. Runoff from these activities will be regulated by the storm water permit. This section includes a table that details many of these activities grouped by SIC code. Tables are also provided that detail BMPs for industrial activities, as well as other drainage areas. Guidance for the sampling and analysis of storm water, categorized by type of facility and discharge, is also provided.

Resources
The guide concludes with a summary of resources that may be consulted for assistance by the SWPPP Program Manager. These sources include HQ AFCEE, PRO-ACT, Regional Environmental Offices (REOs), and Headquarters Air Force Civil Engineer Support Agency (HQ AFCESA).

Appendices
Of the guide's 10 appendices, those of primary interest will be Appendix C - State Regulatory Agency Contacts, Appendix F - Best Management Practices, Appendix H - EPA Multisector Permit Fact Sheet, and Appendix I - Storm Water Briefing Slides.

Copies of the Installation Storm Water Program Management Guide may be downloaded from HQ AFCEE's World Wide Web (WWW) site, http://www.afcee.brooks.af.mil/EQ/swguide.htm, or from PRO-ACT.


For More Information...
  • For more information about storm water pollution prevention and permitting, including a Storm Water P2 Video and examples of Storm Water Pollution Prevention Plans from different Air Force bases, contact PRO-ACT at DSN 240-4214, (800) 233-4356, or pro-act@hqafcee.brooks.af.mil.
  • Air Force points of contact on Storm Water Program issues include:
  • The U.S. Environmental Protection Agency's Office of Wastewater Management (OWM) oversees a range of programs contributing to the well being of our nation's waters and watersheds. Through its programs and initiatives, OWM promotes compliance with the requirements of the Clean Water Act. OWM maintains a comprehensive WWW site at http://www.epa.gov/owm/ containing links to a wide variety of regulatory and technical information sources pertinent to storm water management and permitting.

Document References
  1. "National Pollutant Discharge Elimination System - Regulations for Revision of the Water Pollution Control Program Addressing Storm Water Discharges; Final Rule," EPA, 8 December 1999, 64 FR235. This proposal would revise Title 40 CFR Parts 122 and 123.
  2. "NPDES Storm Water Phase II Fact Sheets A through H," EPA, January 1998.
  3. "Installation Storm Water Program Management Guide," May 1997, Headquarters Air Force Center for Environmental Excellence.
  4. Executive Order 12088: "Federal Compliance with Pollution Control Standards," 13 October 1978.
  5. Air Force Policy Directive (AFPD) 32-70, "Environmental Quality," 20 July 1994.
  6. Air Force Instruction (AFI) 32-7080, "Pollution Prevention Program," 12 May 1994.
  7. AFI 32-7041, "Water Quality Compliance," 13 May 1994.
  8. "Investigation of Inappropriate Pollutant Entries into Storm Drainage System: A User's Guide" 30 September 1992, EPA et al., available at http://www.epa.gov/ednnrmrl/repository/httoc.htm.