Water Permitting Guide · Water Permitting Guide Handbook AS-554-D March 2000 Transmittal Letter 1 A. Purpose. The United States Postal Service is committed to providing its employees

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Water Permitting GuideHandbook AS-554-D March 2000

Transmittal Letter 1

A. Purpose. The United States Postal Service is committed to providing its employees andcustomers with a safe and healthy environment and complying with applicableenvironmental laws and regulations. This handbook provides guidance to Postal Serviceenvironmental professionals in assisting facility and site managers to define, establish,implement, and monitor a water permitting program that can reduce operational costs,ensure compliance with required regulations, and enhance environmental stewardship.

B. Disclaimer. Handbook AS-554-D, Water Permitting Guide, is only intended to enhancethe internal management of the Postal Service and is not intended to, nor does it, createany right, benefit, or trust responsibility, substantive or procedural, enforceable at law orequity by any party against the United States Postal Service. These are not PostalService regulations; they concern internal procedures and practices that do not affectindividual rights and obligations, and they do not create any right to judicial reviewinvolving compliance or noncompliance with the procedures established by thishandbook.

C. Contents. This handbook is a reference tool for implementing the water permittingprogram in postal facilities. The handbook provides Postal Service environmentalprofessionals with the technical tools necessary to assess the need for water-relatedpermits. It also describes specific federal permitting requirements and providesinformation essential for facility and site managers and other responsible parties toaccomplish their water permitting responsibilities.

D. Revisions. This handbook will be revised to modify water permitting policies andstrategies as needed to reflect new legislation and regulations.

E. Distribution. This handbook is being distributed on the Postal Service Intranet athttp://blue.usps.gov/environmental.

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F. Comments and Questions. If you need further clarification of the procedures outlinedin this handbook, send your request to:

MANAGERENVIRONMENTAL MANAGEMENT POLICYUNITED STATES POSTAL SERVICE475 L’ENFANT PLAZA SWWASHINGTON DC 20260-2810(202) 268-5595

G. Effective Date. These instructions are effective immediately.

William J. DowlingVice PresidentEngineering

Originally Printedon Recycled Paper

Handbook AS-554-D, Water Permitting Guide — March 2000 iii

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About This Handbook

Purpose

This handbook provides guidance to Postal Service environmentalprofessionals in assisting facility and site managers to define, establish,implement, and monitor a water permitting program that can reduceoperational costs, ensure compliance with required regulations, andenhance environmental stewardship.

Organization

Chapter 1 explains the reason for and importance of the water permittingprogram. Included is a discussion of the various water quality laws andregulations upon which the water permitting program is based. The chapterthen explains why water permitting is part of our corporate culture. It alsoexamines how the water permitting program compares with theCustomerPerfect! concept.

Chapter 2 provides general information concerning the components of asuccessful water permitting program. It describes the Postal Serviceenvironmental professionals’ (e.g., district environmental compliancecoordinators and area environmental compliance coordinators) roles andresponsibilities, compliance activities, internal communication, andcommunity outreach efforts. It also examines the resources, training, anddocumentation necessary to establish and maintain a sound and compliantwater permitting program.

The Clean Water Act provides the regulatory basis for water (surface andground) protection and thus the permit requirements for Postal Serviceactivities and operations. The following list identifies the handbook’stechnical chapters and their corresponding content:

� Chapter 3 — National Pollutant Discharge Elimination SystemPermits.

� Chapter 4 — National Municipal Pretreatment ProgramRequirements.

� Chapter 5 — Wetlands Protection Requirements.

iv

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Handbook AS-554-D, Water Permitting Guide — March 2000

� Chapter 6 — Safe Drinking Water Act Requirements.

� Chapter 7 — Groundwater Protection Requirements.

Through a series of questions and answers, technical information withinChapters 3–7 gives Postal Service environmental professionals the toolsnecessary to assess the need for water-related permits. These chaptersalso describe specific federal permitting requirements and provideinformation essential for facility managers and other responsible parties toaccomplish their water permitting responsibilities.

Key to Sidebar Information

Text is provided in the sidebars as a visual aid to draw your attention toaction items, tips, useful tools, etc. The types of information found in thesidebars of this guide are:

Summaries

Policies

Actions

Definitions

Checklists

References

Tips

Notes

Contacts

Steps

Handbook AS-554-D, Water Permitting Guide — March 2000 v

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Contents

Transmittal Letter i. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

About This Handbook iii. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Chapters

1 Why Is Water Permitting Important? 1-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2 What Are the General Questions and Answers About Water Permitting? 2-1. . . . . . .

3 What Are the NPDES Permit Requirements? 3-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 What Are the National Municipal Pretreatment Program Requirements? 4-1. . . . . . .

5 What Are the Wetlands Protection Requirements? 5-1. . . . . . . . . . . . . . . . . . . . . . . . . .

6 What Are the SDWA Requirements? 6-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7 What Are the Groundwater Protection Requirements? 7-1. . . . . . . . . . . . . . . . . . . . . .

Appendixes

A What Awareness Training and Outreach Programs Are Available? A-1. . . . . . . . . . . .

B What Stormwater Best Management Practices Are Available? B-1. . . . . . . . . . . . . . . .

C Acronyms and Abbreviations C-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

D Glossary D-1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Handbook AS-554-D, Water Permitting Guide — March 2000 1-1

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Contents

1 Why Is Water Permitting Important? 1-3. . . . . . . . . . . . . . . . . . .

1-1 What Are the Water Quality Mandates? 1-3. . . . . . . . . . . . . . . . . . . .

1-2 Why Is Clean Water Important? 1-3. . . . . . . . . . . . . . . . . . . . . . . . . . .

1-3 Why Is Water Permitting Compliance Part of OurCorporate Culture? 1-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

1-4 How Is the Water Permitting Program Managed? 1-4. . . . . . . . . . . .

1-5 What Are the Phases of Program Management? 1-5. . . . . . . . . . . .

1-6 What Postal Activities Require Water PermittingConsideration? 1-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibits

Exhibit 1-5Water Permitting Program Elements and the CustomerPerfect!Phases 1-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 1-6Activities and Water-Related Regulatory Requirements 1-8. . . . . . . . . . . . . . . . .


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1 Why Is Water Permitting

Important?

Water permitting, as used in this guide, is the process by which all activitiesaffecting water quality are identified and addressed by the appropriatepermit or regulatory requirements. Water permitting is required by law.Federal, state, and local governments require water permits because wateris a critical environmental and economic resource. By complying, thePostal Service protects the welfare of our workforce and reduces ourliabilities. Through a water permitting program, the Postal Service takesstrides toward becoming a sustainable organization.

1-1 What Are the Water Quality Mandates?

For over 25 years, federal, state, territorial, tribal, and local governmentshave worked with the public and businesses to implement a variety ofprograms to improve the quality of the nation’s water resources. Thisincludes programs established by the Clean Water Act (CWA), the CoastalZone Management Act (CZMA), the Safe Drinking Water Act (SDWA), the1990 and 1996 Farm Bills, and other federal laws. In addition, state andlocal governments have established water regulations that can be equallyas stringent as or more stringent than federal laws. Water regulations haveresulted in a dramatic reduction in water pollution and, in many cases, arebirth of the diverse environmental, recreational, and economicopportunities that can result from the presence of clean water.

1-2 Why Is Clean Water Important?

Water is one of the most precious resources on the planet. Fresh water isparticularly critical because it serves as the primary source of drinkingwater and staple of food production. The quantity and quality of water oftendetermines where we live and our quality of life. According to the WorldHealth Organization, 80 percent of all disease in developing countriesresults from people drinking and bathing in contaminated water. Cleanwater is also critical to our nation’s economy. Commercial fishing, tourism,

Water permitting

compliance is

important to the Postal

Service because:

� Permits are required

by law.

� By complying, we protect

the welfare of our

workforce and reduce our

liabilities.

� Water is a critical

economic and

environmental resource.

� Compliance fosters the

sustainable use of natural

resources.

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agriculture, and industrial and manufacturing processes all depend on anadequate clean water supply.

Unfortunately, serious water pollution problems persist throughout thecountry. Water pollution today degrades the quality of rivers, lakes, andcoastal waters. Additionally, water pollution affects quality of life byreducing recreational opportunities, undermining local economicprosperity, and threatening drinking water supplies and public health.Issuing permits for discharges into navigable waters of the United Statesis an effective method for reducing water pollution. Since health,environmental, and economic issues center around water quality,compliance with regulations and guidelines is imperative.

1-3 Why Is Water Permitting Compliance Part ofOur Corporate Culture?

The Postal Service, in our efforts to foster the sustainable use of naturalresources, is committed to doing everything we can to ensure thatresources are used wisely. The Postal Service has adopted a sustainabledevelopment approach to managing our operations and activities. Thisapproach echoes the sustainable development approach established bythe Bruntland Commission (also known as the World Commission onEnvironment and Development) which is “to meet the needs of the presentwithout compromising the ability of future generations to meet their ownneeds” (Our Common Future, 1987). This sustainable developmentapproach is widely accepted for incorporating the objectives of economicgrowth and environmental protection.

Postal Service sustainable development efforts strive to balanceeconomic, environmental, and social needs. It is a means to sustain thehealth of the world’s natural resources and people while also promotingeconomic progress. The Postal Service embraces the principles ofsustainable development and seeks every opportunity to integrate theminto our core business operations. This includes the water managementprogram.

1-4 How Is the Water Permitting ProgramManaged?

The Postal Service uses the CustomerPerfect! method to manageprograms. CustomerPerfect! emphasizes three critical ways of looking atbusiness performance (the “voices” of the customer, the employee, and thebusiness). The objectives of the water permitting program match theCustomerPerfect! voices as follows:

The Postal

Service water

permitting program is

integrated with

CustomerPerfect! as follows:

� Voice of the Business:

- Cost savings from

fewer notices of

violation.

- Compliance with

regulations.

� Voice of the Customer:

- Enhanced public

image from

compliance and

environmental

sensitivities.

- Preservation of water

as a natural resource.

� Voice of the Employee:

- Safe and healthy

working conditions.

- Enhanced drinking

water quality.

Review Establish

Implement Deploy


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� Voice of the Business (VOB) — Cost savings from fewer notices ofviolation and compliance with regulations.

� Voice of the Customer (VOC) — Enhanced public image fromcompliance and environmental sensitivities and preservation ofwater as a natural resource.

� Voice of the Employee (VOE) — Safe and healthy workingconditions and enhanced drinking water quality.

1-5 What Are the Phases of ProgramManagement?

The CustomerPerfect! concept includes four phases of programmanagement. The phases are to establish a direction, deploy, implement,and review and adjust the program as described below:

� Establish a direction — Find out (or establish) what is required andwhere you are now. Answer the key questions who, what, when,where, why, and how. Decide how, in general, to get to where youwant to be, and develop a plan that includes actions for achievingyour goals.

� Deploy — Decide how to execute the program given budgetconstraints. In the previous phase, you developed a list of actionsthat should be taken to achieve your goals. Prioritize the actions todetermine those that need to be implemented immediately andthose that can wait.

� Implement — Once the program has been deployed, implementone action at a time.

� Review and adjust — This phase consumes the most time becauseit continues throughout the life of the program. The program must bereviewed periodically to ensure that goals are being met, and it mustbe adjusted when necessary.

Exhibit 1-5 compares elements of the water permitting program with thephases of CustomerPerfect! and the Postal Service’s EnvironmentalManagement System (EMS). These program elements are addressedthroughout this guide and other related Postal Service documents.

1-6

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Exhibit 1-5Water Permitting Program Elements and the CustomerPerfect! Phases

CustomerPerfect!Phase EMS Element

FunctionalResponsibility

Major Water PermittingProgram Elements in Relationto CustomerPerfect! Phases Water Permitting Program Elements

Establish policy Policy andplanning

Headquarters Policy � Establish core business relationships� Integrate the program into business (VOB,

VOC, VOE)� Identify risks (facilities and activities)� Conduct needs assessment� Identify roles and responsibilities� Identify stakeholder interactions� Set goals and targets� Conduct benchmarking� Interface with regulators� Review regulations and policy� Develop environmental knowledge base� Develop institutional memory

Deploy program Implementationand operation

Performancecluster andarea

Communications and training � Obtain management buy-in of program� Recognize cultural changes� Conduct awareness training� Conduct regulatory outreach� Conduct technical training� Develop Environmental Management

Information System (EMIS) stormwater module� Develop systems for communicating

Resources � Determine program funding� Identify program auditors� Evaluate on-site data� Manage revenues� Arrange logistics of resources� Identify resource frequency and schedule

Technical support � Obtain district manager and performance clustersupport

� Obtain legal and Headquarters contract support� Conduct economic versus risk analysis� Enter permit information into EMIS

Implementprocedures

Checking andcorrectiveaction

Performancecluster andarea

Procedure � Create standard operating procedures andaction plans

� Set minimum and standard protocols� Conduct program planning� Conduct procedure such as agency audits� Implement document control� Implement action plan� Identify improvement opportunities� Manage corrective actions

Review program Managementreview

Headquarters,performancecluster, andarea

Managing the program � Perform verification of audits� Perform quality assurance of program� Review existing documentation� Implement report tracking� Conduct site audits and self-audits� Review performance indicators� Identify lessons learned� Conduct trend analysis


1-6 What Postal Activities Require WaterPermitting Consideration?

Although several related, but distinct, operational activities may occur at afacility, generally it is not necessary to obtain a separate permit for eachrelated activity. In most cases, the activities fall under a single regulation’sjurisdiction; therefore, they are covered under a single permit. For example,the following related operational activities can all be addressed under asingle National Pollutant Discharge Elimination System (NPDES)stormwater permit for a facility: fueling operations, exposed materials andequipment storage, grounds maintenance, and vehicle washing andmaintenance.

The Postal Service environmental professionals’ water permitting focus isto ensure that all activities affecting water quality are identified andaddressed by the appropriate permit or regulatory requirement. The districtenvironmental compliance coordinators (DECCs) are key personnel tocontact concerning permitting issues because of their specialized trainingand experience in dealing with regulatory and permitting issues. Keep inmind that other permits or requirements may be necessary for the activitieslisted above (e.g., vehicle washing and maintenance activities may havepretreatment requirements). An important point to remember is that thePostal Service is ultimately responsible for all water permittingrequirements, whether the facility is owned or leased.

Exhibit 1-6 summarizes common Postal Service activities and the generalpermit and regulatory requirements under the CWA and SDWA. The exhibitis not all-inclusive and represents only a partial list of water-relatedregulatory requirements. Numerous other federal, state, and localregulations (e.g., the Resource Conservation and Recovery Act; theFederal Insecticide, Fungicide, and Rodenticide Act; etc.) may requirepermits based on specific postal operations and activities.

The Postal

Service is

ultimately responsible

for all water permitting

requirements, whether the

facility is owned or leased.

Environmental

professionals must

ensure that all activities

affecting water quality are

identified and addressed by

the appropriate permit or

regulatory requirement.

1-8 Handbook AS-554-D, Water Permitting Guide — March 2000

Exhibit 1-6Activities and Water-Related Regulatory Requirements

If a FacilityEngages In … Then You Should Consider … Because …

Fueling operations NPDES stormwater permit(Chapter 3)

Spilled materials can wash into storm drains and sewers.

Grounds maintenance(i.e., lawn care, snowremoval)

NPDES stormwater permit andgroundwater protection requirements(Chapters 3 and 7)

Fertilizers, pesticides, and sediments may wash into stormdrains and sewers or seep into groundwater.

Equipment andmaterials storage(outside)

NPDES stormwater permit(Chapter 3)

Contaminants from the wear and corrosion of parts, leaking oilsand lubricants, and combustion by-products that are depositedon the ground can wash into storm drains and sewers. Deicingand other materials from equipment and debris can also washinto storm drains and sewers.

Boiler operations SDWA backflow prevention requirements(Chapter 6)

Backflow from faulty boiler operations could contaminatethe drinking water supply.

Water coolers andfountains

SDWA lead testing requirements(Chapter 6)

Water can leach lead from older piping systems within buildingsor lead-soldered water coolers.

Septic system Groundwater protection requirements(Chapter 7)

Leaching of untreated or partially treated wastes from septictanks and drain fields can contaminate groundwater and drinkingwater sources.

Sewage discharge (fromall buildings, rooms,etc.)

Pretreatment requirements(Chapter 4)

Discharges to publicly owned treatment works (POTWs)must be sanitary.

Vehicle washing andmaintenance

NPDES industrial point source permit,NPDES stormwater permit, pretreatmentrequirements, and groundwater protectionrequirements(Chapters 3, 4, and 7)

Wash water cannot be discharged to surface waters without apermit. It should be reclaimed or treated prior to discharge toavoid the need for a permit. Also, drips of fuel, antifreeze, orother fluids can contaminate stormwater.

Construction NPDES stormwater permit and CWA section 404dredge-fill and wetlands requirements(Chapters 3 and 5)

Soil erosion and leaks from construction and vehicles maypollute nearby surface water. Federal law also limits the effectsof construction on wetlands.

Supplying water SDWA monitoring and testing(Chapter 6)

Various chemicals are found in water supply sources. Facilitiesproviding water must ensure that the chemicals remain belowregulated levels.

Painting operations NPDES stormwater permit, pretreatmentrequirements, and groundwater protectionrequirements(Chapters 3, 4, and 7)

Paint and paint residues from painting operations may enterdrains and sewers and affect surface water and groundwater.

Operating hydraulic lifts Groundwater protection requirements(Chapter 7)

Oil leaks can contaminate groundwater and other drinking watersources.

Battery storage anddisposal

NPDES stormwater permit, pretreatmentrequirements, and groundwater protectionrequirements(Chapters 3, 4, and 7)

Acid leaks from corroded batteries in storage may affectstormwater, sewage discharge, or underground drinkingwater sources.


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Contents

2 What Are the General Questions and AnswersAbout Water Permitting? 2-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-1 What Are the Common Permit Types andTheir Requirements? 2-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-2 What Are Our Water Quality and PermittingResponsibilities? 2-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-3 What Constitutes a Successful Water Permitting Program? 2-7. . .

2-3.1 How Are Proper Mitigative and PreventiveMeasures Ensured? 2-8. . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-3.2 How Are Proper Operation and Maintenance ofControl and Treatment Systems Ensured? 2-8. . . . . . . .

2-3.3 What Information May Be Requested? 2-8. . . . . . . . . . . .

2-3.4 How Can Inspections Be Facilitated? 2-8. . . . . . . . . . . . .

2-3.5 What Is Involved in Ensuring Proper Recordkeepingof Monitoring Activities? 2-9. . . . . . . . . . . . . . . . . . . . . . . . .

2-3.6 Why Is Proper Recordkeeping Important? 2-9. . . . . . . . .

2-3.7 What Documents Must Be Maintained With ProperSignatures or Certifications? 2-11. . . . . . . . . . . . . . . . . . . . .

2-3.8 What Events Need Accurate and TimelyReporting? 2-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-3.9 Where Can Effective Awareness Training BeObtained? 2-12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2-3.10 What Resources Ensure a Successful WaterPermitting Program? 2-12. . . . . . . . . . . . . . . . . . . . . . . . . . .

2-4 What Are the Consequences of Noncompliance? 2-13. . . . . . . . . . .

Exhibits

Exhibit 2-2Water Cycles 2-5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 2-3.6Sample of DECC’s Water Management File 2-10. . . . . . . . . . . . . . . . . . . . . . . . . .


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2 What Are the General Questions

and Answers About WaterPermitting?

This chapter contains information that can assist Postal Serviceenvironmental professionals with the identification of water-relatedpermitting and regulatory requirements. Based on the activities in whicha facility engages, environmental professionals can determine whichpermits need to be obtained and what standards need to be met.Permit-specific requirements are discussed in greater detail in theircorresponding chapters.

2-1 What Are the Common Permit Types and TheirRequirements?

Each type of permit and program requirement is discussed in further detaillater in this guide. Common types of permits and a brief description ofeach are presented below. The following descriptions are the PostalService’s legal interpretation of federal CWA and SDWA regulations andpermit requirements:

� A National Pollutant Discharge Elimination System permit isrequired if a facility engages in an industrial activity and has aseparate stormwater system or a point source discharge of effluent(via a pipe, conveyance, etc.) directly into a navigable water of theUnited States. A point source is any discernible, confined, anddiscrete conveyance, such as pipes, ditches, tunnels, and wells,from which pollutants are or may be discharged. A nonpointdischarge is any source of water pollution or pollutants notassociated with a discrete conveyance. Industrial activity includestransportation facilities that have vehicle maintenance shops andequipment cleaning operations. See Chapter 3 for moreinformation.

� A Municipal Pretreatment permit may be required for facilities thatdischarge to publicly owned treatment works (POTWs). Thedischarges may be sanitary or processed wastes as a result of

Point source is

any discernible,

confined, and discrete

conveyance from which

pollutants are or may be

discharged.

Nonpoint discharge is any

source of water pollution or

pollutants not associated

with a discrete conveyance,

including runoff.

Industrial activity includes

transportation facilities that

have vehicle maintenance

shops and equipment

cleaning operations.

2-4

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industrial activities. Dischargers must comply with pretreatmentrequirements to ensure that the discharges do not contaminate thelocal POTW. See Chapter 4 for more information.

� A Wetlands permit may be required for actions, such asconstruction activities, that could alter or affect wetlands and othersensitive environments. See Chapter 5 for more information.

� Safe Drinking Water laws require that facilities with at least 15service connections, or that regularly serve 25 individuals whoreceive drinking water from a private well, or that treat the waterpeople receive from a municipal system (e.g., chlorination) providedrinking water that is free of targeted contaminants. Often,construction of a self-supply water system necessitates obtaining apermit (e.g., for well drilling). See Chapter 6 for more information.

� Groundwater protection under the SDWA requires obtainingUnderground Injection Control (UIC) permits for certain wells andtheir associated activities to protect drinking water wells and otherunderground water resources. See Chapter 7 for more information.

2-2 What Are Our Water Quality and PermittingResponsibilities?

The Postal Service is responsible for safely managing all water enteringand leaving our properties, whether owned or leased. Exhibit 2-2illustrates common Postal Service water and wastewater sources, uses,and treatment and collection systems. A generalized hydrologic cycleshowing water flow on and off a typical Postal Service property is alsoillustrated. Each component of water use and disposal requires us tobecome familiar with appropriate laws, regulations, and permits. We mustalso be able to monitor the water permit practices employed at ourfacilities and be responsible for implementing and maintaining bestmanagement practices (BMPs) when and where necessary.

DECCs play a major role in the implementation of environmentally soundand compliant permitting practices. Their roles and responsibilitiesinclude the following:

� Assisting in determining the requirements for permits anddeveloping accompanying management plans.

� Approving a facility’s revised management plans based on changesto the facility’s activities. This includes a review of the existingsampling equipment, sampling and laboratory methods, andcontainers.

DECCs should

assist facility

managers in:

� Maintaining compliance

with regulations.

� Evaluating water

permitting issues and

addressing the greatest

needs first.

� Determining negative

effects on postal

operations.

� Examining alternative

operations and activities

to reduce or eliminate

the need for water

permits.

� Working with local

regulators and POTWs

to develop and

implement alternative

permitting approaches

to achieve greater

environmental benefits.


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Exhibit 2-2Water Cycles

On-Site Water System

On-Site GroundWater Well

On-SiteSpring

PostalFacility

PostalFacility

LiftStation

Maint.Oil/WaterSeparator

On-SiteTreatment System

Septic System

Runoff

Geologic Cross Section

Confining Bed

WaterTable

Surficial Aquifer

AquiferAquifer HydraulicGradientHydraulicGradient

Stream or River

Public WaterSupply System

Examples of WaterCollection Systems

Water Sources

Publicly OwnedTreatment Works

Rain

Stormwater Drain

Water Uses at Postal Facility

OperationalUses

PersonalUses

EmergencyUses

GroundAbsorption

Evaporation

Collection

Distribution

Wastewater Treatment Systems

GreaseTrap

FacilityUses

WaterMeter

Sanitary Sewer

Sun

2-6

20


� Supporting efforts for maintenance and service of equipmentrequired for permit compliance.

Specifically with regard to the Postal Service water permitting program,DECCs are responsible for:

� Overseeing performance cluster program — DECCs implementand oversee national water management program policiesdeveloped by Environmental Management Policy (EMP),Engineering, as well as those developed by the area environmentalcompliance coordinator (AECC). DECCs also provide feedbackfrom the performance cluster to the AECC and coordinationbetween the area and the performance cluster. DECCs areresponsible for evaluating water permitting compliance activities inall performance cluster facilities.

� Evaluating facility goals — DECCs evaluate water compliancegoals for individual facilities based on actual performance andcompare results to the performance cluster’s and area’s annualgoals.

� Coordinating project funding requests — DECCs coordinate thefunding requests from the field on local projects approved by thearea.

� Tracking performance cluster performance — DECCs ensure thecompleteness and validity of water permitting data. DECCs assistfacility managers in obtaining all permits via the regulatory authoritythat has jurisdiction over the permitting region. They monitor afacility’s permit status via the permitting module of theEnvironmental Management Information System (EMIS) and notifythe facility manager when a permit is due for renewal.

� Conducting awareness training and communications — DECCs areresponsible for keeping facility and water project managers awareof program information. They provide annual briefings about new orrevised regulations to Postal Service site managers. They alsoprovide a summary of annual notification procedures to the properregulatory and postal authorities. DECCs implement a structuredawareness training program for the appropriate facility personneland update the briefings annually.

� Coordinating water permitting efforts — DECCs are responsible forcoordinating water permitting efforts with the facility manager andother facility personnel as designated and with AdministrativeSupport representatives, major facilities office (MFO)representatives, and facilities service office (FSO) representatives.DECCs are key persons for coordinating permitting issues due totheir specialized training and years of experience in dealing withregulatory issues.


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� Assisting facility managers to develop and maintain a successfulwater permitting program — DECCs assist the facility manager inobtaining a permit prior to commencing the activity that requires thepermit or if site conditions, activities, or operations change thatnecessitate obtaining a permit. DECCs also assist the facilitymanager in initiating the permit process by giving notice to theregulatory authority. When site conditions, operations, or activitieschange, the DECC may determine that the appropriate federal,state, or local agency must be contacted to identify new permitrequirements. See section 2-3 for further information.

Note that the facility manager has the ultimate responsibility for complyingwith all water permitting requirements, whether the facility is owned orleased. If occupying a rented facility, the facility manager should notexpect exemption from a requirement because he or she assumed thatit was the owner’s responsibility. If a facility manager has any questionsabout a particular environmental permitting requirement, he or she shouldalways consult the DECC.

2-3 What Constitutes a Successful WaterPermitting Program?

A successful water permitting program is one that complies with federal,state, and local regulations and internal Postal Service guidelines. Inbuilding a successful water permitting program, DECCs, theAdministrative Support unit, the FSO, the MFO, the facility manager, andother facility personnel all work together to do the following:

� Ensure that proper mitigative and preventive measures are inplace.

� Ensure proper operation and maintenance of control and treatmentsystems.

� Provide information upon request.

� Facilitate inspections.

� Ensure proper recordkeeping of monitoring activities.

� Ensure proper recordkeeping of all necessary documents.

� Maintain documents with proper signatures and/or certifications.

� Ensure accurate and timely reporting.

� Provide effective awareness training and communications.

� Ensure that appropriate resources are available to enablecompliance.

Details of how to perform these actions are described in 2-3.1 through2-3.10.

Staff who implement

a successful water

permitting program:

� Ensure that proper

mitigative and preventive

measures are in place.

� Ensure proper operation

and maintenance of

control and treatment

systems.

� Provide information upon

request.

� Facilitate inspections.

� Ensure proper

recordkeeping of

monitoring activities.

� Ensure proper

recordkeeping.

� Maintain documents with

proper signatures and/or

certifications.

� Ensure accurate and

timely reporting, as

required.

� Ensure effective

awareness training and

communications.

� Ensure that appropriate

resources are available to

maintain compliance.

2-8

22


2-3.1 How Are Proper Mitigative and Preventive MeasuresEnsured?

A facility should do all it can within reason to minimize or prevent any illegaldischarge or disposal in violation of any permit where such discharges ordisposals are likely to adversely affect human health or the environment.

2-3.2 How Are Proper Operation and Maintenance of Controland Treatment Systems Ensured?

All control and treatment systems, including BMPs, used to achievecompliance with permit conditions must be properly operated andmaintained. A preventive maintenance schedule that shows whenequipment and BMPs require maintenance and inspections helps toidentify problems.

2-3.3 What Information May Be Requested?

Permits must be provided to the appropriate federal, state, and/or localagencies, along with all requested information, within a reasonable timeframe. The specific time frames may be found within the regulations orpermits.

2-3.4 How Can Inspections Be Facilitated?

The Postal Service is subject to environmental inspections by federal orstate environmental personnel. DECCs will help the facility managers tounderstand how these inspections may be conducted.

The Postal Service facility manager must allow any federal, state, localagency, or authorized representatives (including an authorized contractoracting as a representative of the agency) the following:

� Entry onto the premises where a regulated facility is located or aregulated activity is conducted.

� Access to all records kept as part of the permit conditions.

� Inspection at reasonable times of all facilities, equipment (includingmonitoring and control equipment), practices, or operationsregulated or required by a permit. Consult the regulation or statutefor the definition of a reasonable time frame.

� Sampling or monitoring at reasonable times of all substances orparameters at all locations.

A facility manager

must allow all

federal, state, local agency,

or authorized represen�

tatives who request it to

inspect the premises and

must allow them access to

records.


23

2-3.5 What Is Involved in Ensuring Proper Recordkeeping ofMonitoring Activities?

Samples and measurements taken for the purpose of monitoring waterquality must be representative of the monitored activity. Postal Servicepolicy is to retain all monitoring data, records, and reports for at least 5years from the date of sampling or measurement. Calibration andmaintenance records for all monitoring devices must also be retained forat least 5 years. Records must be transferred to new facility managers inaccordance with Postal Service policy. The state, local, or federalauthority may have different requirements.

Generally, records of monitoring information must include the following(state or local specific regulations may contain more requirements):

� The date, location, and time of sampling or measurement.

� The individuals who performed the sampling or measurement.

� The dates the analyses were performed.

� The individuals who performed the analyses.

� The analytical techniques or methods used.

� The results of such analyses.

Monitoring tests must be conducted in accordance with the approved testprocedures. Consult 40 Code of Federal Regulations (CFR) 136,Guidelines Establishing Test Procedures for the Analysis of Pollutants, fordetails.

2-3.6 Why Is Proper Recordkeeping Important?

Facility managers must implement an effective recordkeeping andinternal reporting system that complies with federal and state regulationsand Postal Service guidelines. Failure to maintain records and permits inaccordance with federal and state regulations is, in itself, anenvironmental violation that may carry financial penalties. All water permitrecords must be maintained in accordance with the permit’s requirementsand Postal Service policy, whichever is longer.

An accurate and effective recordkeeping system helps ensure that thefacility’s plans are being followed. The facility manager must keep recordsfor sampling, monitoring, inspections, spills and leaks, maintenance, andBMPs for source and structural control. Each facility manager or designeeshould develop and maintain a consolidated water management file, withmaster copies (hard copy or diskette) of all pertinent materials filed at thedistrict. All water permitting documentation should be approved by thefacility manager and DECC before submission to regulatory agencies.

All water permit

records must be

kept in accordance with the

permit's requirements and

Postal Service policy,

whichever is longer.

Chain�of�custody

records, laboratory

results, and quality

assurance and quality

control documentation are

valuable information sources

that must be retained at the

facility and forwarded to the

DECC if requested.

2-10

24


Chain-of-custody records, laboratory results, and quality assurance andquality control documentation are valuable information sources that mustbe retained at the facility and forwarded to the DECC if requested. Exhibit2-3.6 shows an example of a DECC’s water management file.

Exhibit 2-3.6Sample of DECC’s Water Management File

Folder 4.1 – Public Water Supply Registration Formand Operator Certification

Folder 4.2 – Water Cooler Results

Folder 4.3 – Local Sewer Use FormsPermits and Forms

Folder 4.4 – Septic Systems Plans, Approvalsand Local Rules/Ordinances

Folder 4.5 – Local Wetlands/Watersheds Regulationsand Surveys, Project Approvals

Folder 4.6 – District Vehicle WashingGuidelines

Folder 4.7 – Plowing Contractor Agreements(Deicer Restrictions)

Folder 4.8 – Backflow Prevention Devices

Folder 4.9 – Stormwater BMP Inspections

Folder 4.10 – Groundwater Protection Issues

Folder 4.11 – Coastal Zone Management Program

File 4.0Water Management File

Water permits require that the following documentation be maintained:

� Inspection reports.

� Spill and leak reports.

� Equipment operations and maintenance reports.

� Waste disposal reports or manifests.

The Postal Service manages our records in accordance with the followingEMS procedure: Environmental Records, EMS Procedure 11-99. In manyinstances, the only recordkeeping responsibility of a facility manager is to


25

keep a particular record in the files. Recordkeeping responsibilities couldalso mean ensuring that the facility has a copy of a permit or an inspectionresults form, documentation that the correct people were notified of anincident, or proof that a requirement does not apply to the facility. If arecord is missing, or inaccessible, the facility could be considered out ofcompliance, even if all proper procedures were actually followed.

Additional information regarding the maintenance and disposition ofwater permitting records may be obtained through the use of threecorporate databases:

� Environmental Management Information System (EMIS) —maintained by EMP at Headquarters.

� Records and Information Management System (RIMS) —maintained by Finance at Headquarters.

� Environmental Recordkeeping Compliance System (ERCS) —maintained by EMP at Headquarters.

2-3.7 What Documents Must Be Maintained With ProperSignatures or Certifications?

All permit applications, reports, or information submitted to theappropriate state agency must be signed and certified by the facility orconstruction manager. Any person who knowingly makes any falsestatement, representation, or certification in any record or other documentrelated to the permit may be subject to monetary penalties andimprisonment.

The signature required on the permit application depends on the permittype and the service office involved with the project or activity requiring thepermit. In general, permit applications are signed by the facility manager.It is important to note that certain permits, such as NPDES, can only besigned by senior level (i.e., postal career executive service (PCES)) postalpersonnel. Regardless of who signs the permit application, a copy shouldbe maintained on-site.

2-3.8 What Events Need Accurate and Timely Reporting?

At a minimum, the following events must be reported to the permittingauthority:

� Noncompliance events that may endanger health or theenvironment (reported immediately).

� Planned changes to the facility that affect effluent discharge.

� Anticipated noncompliance.

� Planned transfer of the facility to another owner or operator.

Additional

information

regarding data

and document retention

may be found in:

� Environmental

Recordkeeping

Compliance System.

� EMS Procedure 11�99.

� EMIS Stormwater

Module.

� Administrative Support

Manual 55.

EMIS contains a

water module

that tracks permit

expiration dates and BMP

compliance.

Regardless of

who signs the

permit application, a copy

should be maintained

on�site.

Noncompliance

events that may

endanger health or the

environment must be

reported immediately.

2-12

26


2-3.9 Where Can Effective Awareness Training Be Obtained?

Awareness training and communication venues for postal employeesavailable through the National Center for Employee Development(NCED) are listed on the EMP intranet site. The specifics of awarenesstraining and communication needs will likely differ by area and district (andperhaps within a district).

An example of effective communication would be to implement astenciling program for labeling storm drains, catch basins, and otherpotential sources of water pollution. The stencils warn users fromintentionally or unintentionally dumping pollutants into storm drains aswell as increase public awareness of the pollution potential. This effortcould reduce water pollution, which in turn may lead to improvedoperations and reduced maintenance costs. See Appendix A for moreawareness training information, including a full description of NCEDwater-related courses and other training and outreach options.

2-3.10 What Resources Ensure a Successful Water PermittingProgram?

Once all of the permits that a facility needs are identified, resources mustbe allocated toward complying with the requirements. Four resources thatmust be available in order for a facility’s water permitting program to besuccessful are commitment, personnel, funds, and knowledge:

� Commitment — The Postal Service is committed to preventingwater pollution through a sound water permitting program. It is boththe law and a sound business decision. Obtaining permits andcomplying with their requirements fulfill the Postal Service’sbusiness management concept of CustomerPerfect! by minimizingbusiness liabilities and protecting customers and employees.

� Personnel — When a facility’s resource needs are determined, anaccurate estimate of the personnel needed to carry out the facility’swater permitting program must be included. Program managersmust acquire, through approved channels, the appropriate trainingto understand and address water permitting issues.

� Funds — An estimate of a facility’s funding needs should includeinformation on the number and types of projects that need to beimplemented (e.g., BMPs), fees that need to be paid (e.g.,compliance, permit, and permit renewal fees), the priority of theproject, and the amount of funding needed to fulfill a project.

� Knowledge — Accurate estimates of a facility’s water permittingresource needs depend on a facility manager’s knowledge of theregulations and their implications. Although the facility managermay be aware of water permitting regulations, the DECC andAECC must provide assistance to managers so they may keep

Resources

necessary for a

successful and compliant

permitting program are:

� Commitment.

� Personnel.

� Funds.

� Knowledge.


27

current with new regulations and their potential effect on thefacility’s water permitting program. The Postal Service offersseveral courses to assist personnel with effectively implementingwater permitting requirements (see Appendix A).

A list of water resource state agencies and Environmental ProtectionAgency (EPA) offices is located on the EMP intranet site under the waterprogram heading. Included in the listing are the official web sites for theagencies. In some cases, web sites for specific regulations are includedas well. The specific documents and resources related to each waterpermit type are located at the end of each chapter in this guide. Below isa list of additional Postal Service water permitting and technicalinformation documents and resources that should prove useful:

� Postal Bulletins.

� Maintenance management orders (MMOs).

� NCED courses.

� Management instructions (MIs).

� Environmental Resource Guide (ERG).

� EMS description and procedures.

2-4 What Are the Consequences ofNoncompliance?

Numerous federal, state, and local water permitting requirements,including Postal Service requirements, exist. Postal Service employeesare responsible for complying with these requirements and internalguidelines. If found out of compliance with any federal or authorized statewater quality law, the Postal Service and employees may be subject tocriminal sanctions.

In accordance with our guiding principles, the Postal Service is committedto meeting or exceeding all applicable environmental laws andregulations in a cost-effective manner. Failure to comply withenvironmental laws and regulations may mean that the Postal Service, orthe installation head, could be fined or penalized by authorities.Noncompliance could also result in adverse publicity, loss of marketshare, and loss of revenue.

All Postal Service facilities must be in compliance with conditionsspecified in their permits. Any permit noncompliance constitutes aviolation of the CWA and is grounds for an enforcement action such aspermit termination, permit revocation and reissuance, or modification ordenial of a permit renewal application. Enforcement action may result infacility shutdown and disruption to core business operations. Although the

The EMP site on

the intranet,

under the

heading water program,

has links to state agencies,

the EPA, and specific

regulations.

Noncompliance

can result in

criminal penalties for

individual Postal Service

employees.

2-14

28


DECC is a resource for obtaining water permits, ultimately the facilitymanager is responsible for complying with all permits and their specificconditions.

Unanticipated incidents that result in the violation of a permit conditionmay not result in penalties if the causes of the incident were identified, thefacility was being properly operated at the time of incident, and notificationis submitted to the regulatory authority within 24 hours.


29

Contents

3 What Are the NPDES Permit Requirements? 3-5. . . . . . . . . . .

3-1 How Did NPDES Originate? 3-5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-2 What Are NPDES Permits? 3-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3 What Needs to Be Known About NPDES Industrial PointSource Process Wastewater Discharge Permits? 3-6. . . . . . . . . . .

3-3.1 What Activities Are Subject to NPDES IndustrialPoint Source Process Wastewater Discharge Permitting? 3-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.2 Who Is Responsible for Obtaining a NPDESIndustrial Point Source Process WastewaterDischarge Permit? 3-8. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.3 Who Issues NPDES Industrial Point SourceProcess Wastewater Discharge Permits? 3-9. . . . . . . . . .

3-3.4 When Must a NPDES Industrial Point SourceProcess Wastewater Discharge Permit BeObtained? 3-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.5 What Are the NPDES Industrial Point SourceProcess Wastewater Discharge PermitRequirements? 3-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.6 What Are the NPDES Industrial Point SourceProcess Wastewater Discharge Permit ReportingRequirements? 3-10. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.7 Who Signs NPDES Industrial Point SourceProcess Wastewater Discharge PermitApplications and Reports? 3-10. . . . . . . . . . . . . . . . . . . . . .

3-3.8 Who Is Responsible for Complying With the NPDESIndustrial Point Source Process WastewaterDischarge Permit? 3-10. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-3.9 What Happens If a Facility Does Not Comply Withthe NPDES Industrial Point Source ProcessWastewater Discharge Permit? 3-10. . . . . . . . . . . . . . . . . .

3-3.10 How Are NPDES Industrial Point Source ProcessWastewater Discharge Permits Renewed? 3-11. . . . . . . .

3-3.11 Where Can Further Information and AssistanceBe Obtained? 3-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4 What Needs to Be Known About NPDES StormwaterDischarge Permits? 3-12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.1 What Is Stormwater? 3-12. . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.2 How Is Stormwater Discharge Regulated? 3-12. . . . . . . . .

3-2

30


3-4.3 What Activities Are Subject to NPDES StormwaterDischarge Permitting? 3-12. . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.4 Who Is Responsible for Obtaining a NPDESStormwater Discharge Permit? 3-14. . . . . . . . . . . . . . . . . . .

3-4.5 Who Issues NDPES Stormwater DischargePermits? 3-16. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.6 When Must a NPDES Stormwater DischargePermit Be Obtained? 3-16. . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.7 What Types of NPDES Stormwater DischargePermits Can Be Obtained? 3-17. . . . . . . . . . . . . . . . . . . . . .

3-4.7.1 What Are Baseline General Permits? 3-17. . . .

3-4.7.2 What Are Construction Activity BaselineGeneral Permits? 3-17. . . . . . . . . . . . . . . . . . . . .

3-4.7.3 What Are Multisector GeneralPermits? 3-17. . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.7.4 What Are NPDES Stormwater DischargeIndividual Permits? 3-17. . . . . . . . . . . . . . . . . . .

3-4.8 Which Type of Permit Should Be Chosen? 3-18. . . . . . . .

3-4.8.1 What Are the NPDES StormwaterDischarge MSGP Advantages Overthe BGP? 3-18. . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.8.2 What Are the NPDES StormwaterDischarge MSGP DisadvantagesCompared to the BGP? 3-18. . . . . . . . . . . . . . .

3-4.9 What Are the NPDES Stormwater DischargePermit Requirements? 3-19. . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.10 What Are the NPDES Stormwater DischargeReporting Requirements? 3-19. . . . . . . . . . . . . . . . . . . . . . .

3-4.11 Who Signs NPDES Stormwater Discharge PermitApplications and Reports? 3-19. . . . . . . . . . . . . . . . . . . . . .

3-4.12 Who Is Responsible for Complying With the NPDESStormwater Discharge Permit? 3-20. . . . . . . . . . . . . . . . . . .

3-4.13 What Happens If a Facility Does Not Comply Withthe NPDES Stormwater Discharge Permit? 3-20. . . . . . . .

3-4.14 How Are NPDES Stormwater Discharge PermitsRenewed? 3-20. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3-4.15 Where Can Further Information and AssistanceBe Obtained? 3-20. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


31

Exhibits

Exhibit 3-3.1Activities That May Require a NPDES Process WastewaterDischarge Permit 3-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 3-4.3aActivities That May Necessitate a NPDES StormwaterDischarge Permit 3-13. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 3-4.3bMobile Fleet Fueling, CNG Fueling, and Electric Fueling NPDES PermitRequirements 3-15. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 3-4.13Dominick Versus Daniels Case Study 3-21. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


33

3 What Are the NPDES Permit

Requirements?

This chapter outlines the general requirements of the CWA’s NPDESprogram. Why NPDES permits must be obtained, who obtains them, andthe steps required to maintain compliance with permit conditions arediscussed.

Be aware that the Postal Service may encounter situations in whichNPDES issues and requirements overlap with wetlands issues and theirassociated requirements. Contact legal counsel for clarification andadditional information.

3-1 How Did NPDES Originate?

Congress enacted the CWA in 1972. The CWA was the first comprehensivenational clean water legislation and was enacted in response to growingpublic concern about serious and widespread water pollution. The CWA isthe primary federal law that protects our nation’s groundwater and surfacewaters. The CWA protects the “waters of the United States,” which aredefined as all navigable waters including their tributaries and associatedwetlands and impoundments that are or have been used for interstate orforeign commerce (March 31, 1998, 63 Federal Register 15671). TheCWA’s primary objective is to restore and maintain the integrity of thenation’s waters, which translates into two fundamental national goals:

� Regulate the discharge of pollutants into the waters of the UnitedStates.

� Achieve water quality levels that are fishable and swimmable.

EPA delegates primary authority for enforcement of the CWA to states thatdevelop and maintain EPA-approved clean water programs. States must,at a minimum, enact the requirements set forth in the CWA; however, stateshave authority to develop more stringent standards. Primacy can berevoked if a state fails to meet water quality standards or properly enforcerequirements. States may also voluntarily relinquish primacy over theprogram. In either case, EPA becomes the primary manager, through itsregional offices, of the state’s clean water program.

Waters of the

United States are

all navigable waters

including their tributaries

and associated wetlands

and impoundments that are

or have been used for

interstate or foreign

commerce.

3-6

34


3-2 What Are NPDES Permits?

There are two types of NPDES permits, which regulate:

a. Industrial point sources that discharge process wastes into otherwastewater collection systems or that discharge directly into watersof the United States.

b. Stormwater discharges from industrial sources.

The process of obtaining and maintaining each of these permits is coveredin this chapter.

Minimizing discharge or “zero discharge” (i.e., no discharge) of processwastewater pollutants is the ultimate goal of the Postal Service waterpermitting program. The need for NPDES permits may be reduced byeliminating effluent discharges of permit-requiring activities and byimplementing ideas from Handbook AS-554-C, Vehicle WashingTechnologies, and EPA’s Sector Notebook guide located at http://es.epa.gov/oeca/sector/index.html.

3-3 What Needs to Be Known About NPDESIndustrial Point Source Process WastewaterDischarge Permits?

3-3.1 What Activities Are Subject to NPDES Industrial PointSource Process Wastewater Discharge Permitting?

Postal Service activities most likely to require NPDES process wastewaterpermits for industrial point source discharges are vehicle washing andvehicle maintenance. (See Exhibit 3-3.1 for an example of potentialNPDES-permitted activities.) EPA defines process wastewater as anywater that, during manufacturing or processing, comes into direct contactwith, or results from the production or use of, any raw material, intermediateproduct, finished product, by-product, or waste product.

Process water associated with boiler and cooling tower blowdown wastes;heating, ventilation, and air-conditioning (HVAC) equipment; and batteryrooms; and water used for domestic processes such as restrooms andkitchens or for custodial purposes are also likely to require a NPDESindustrial point source process wastewater permit. Each of thesedischarges must be permitted if they are discharged directly into waters ofthe United States. See Handbook AS-554-A, Water Management Guide forFacility Managers, for further information on process water and washwater, respectively.

Minimizing

discharge or �zero

discharge" of process

wastewater pollutants is the

ultimate goal of the Postal

Service water permitting

program.

A facility can reduce

the need for NPDES

permits by:

� Eliminating effluent

discharges of permit�

requiring activities.

� Implementing ideas from

Handbook AS�554�C and

EPA's Sector Notebook

guide located at

http://es.epa.gov/oeca/

sector/index.html.


35

Stream

Parking

Boiler

CoolingTower

UtilitySink

Trench Drains

DrinkingWater Fountain

SanitarySewer

Restroom

Shower, Sink,

Battery Room

AcidNeutralizationSump

VehicleMaintenanceArea

Cafeteria

VehicleWash

Sand & Oil/Water

Separator

Sand & Oil/WaterSeparator

Plant

VMF

Sink

CustodialCloset

Exhibit 3-3.1Activities That May Require a NPDES Process Wastewater Discharge Permit

Toilet

Area


Chiller

GreaseTrap

NPDES ProcessWastewater DischargePermit Requirements

3-8

36


The following scenarios describe washing activities where a NPDESindustrial point source process wastewater permit would not be required:

� If a “dry” wash method is used, no wastewater is generated, so thereis no discharge that would require a permit.

� If vehicle wash water is collected and recycled for reuse. Someways to collect the wash water using other methods include usingcommercially available portable inflatable devices onto which avehicle is driven and then washed; blocking the storm drains withspecialized plugs or plastic and sandbag-type devices; and using awash rack or pad that drains to a storage vault. Handbook AS-554-Ccontains further information on vehicle washing technologies andwash water disposal options.

� If wash water is collected and disposed of on-site into a sanitarysewer. In this situation, pretreatment may be required. If a contracthauler is used to collect and dispose of the sanitary sewerwastewater, there may be state or local regulations requiring thehaulers to have licenses or to obtain permits. The facility manager orvehicle maintenance facility (VMF) manager should always obtaincopies of permits and licenses from contract haulers.

� If wash water is collected and taken off-site to a public or privatewastewater treatment plant, or discharged off-site to the sanitarysewer system. The public or private wastewater treatment plantaccepting the discharge is required to have its own NPDESindustrial point source process wastewater discharge permit. Thefacility manager or VMF manager should ensure that the acceptingplant has the appropriate NPDES permit.

� If process wash water is collected and applied to the land (e.g., forirrigation) or otherwise allowed to evaporate (e.g., an evaporationpond) without being discharged. Note that applying the wash waterto land could, in certain circumstances, trigger the need for aNPDES stormwater discharge permit for the site. Some states mayhave requirements regarding the discharge of process water to land.

For further information, contact legal counsel about the applicability ofthese requirements.

3-3.2 Who Is Responsible for Obtaining a NPDES Industrial PointSource Process Wastewater Discharge Permit?

The operator of an industrial facility discharging pollutants is responsiblefor applying for an industrial point source process wastewater permitregardless of ownership. Under Postal Service policy, the facility managermust ensure that all required permits are obtained. As mentioned in section1-6, it is important to remember that the Postal Service is ultimatelyresponsible for all water permitting requirements, whether the facility isowned or leased.

Applying wash water

to the land could, in

certain circumstances,

trigger the need for a

NPDES stormwater

discharge permit for the site.


37

DECCs are available to coordinate obtaining permits with the facilitymanager, Administrative Support unit, FSO, and MFO, as necessary andappropriate. This includes assisting facility managers with conductingsurveys to identify all discharges and potential permitting requirements.DECCs are key persons for permitting issues because of their specializedtraining and experience in dealing with regulatory and permitting issues.

3-3.3 Who Issues NPDES Industrial Point Source ProcessWastewater Discharge Permits?

In most states and on tribal lands, the state environmental protection officeissues NPDES industrial point source process wastewater dischargepermits. A few states have not yet received EPA approval to issue thesepermits. In those states, the facility manager must receive this permit froman EPA regional office and may be required to obtain a state or tribal landNPDES industrial point source process wastewater discharge permit inaddition to the EPA-issued permit.

3-3.4 When Must a NPDES Industrial Point Source ProcessWastewater Discharge Permit Be Obtained?

For new discharges resulting from a process change or new operation,permit applications must be submitted at least 180 days before the date onwhich the discharge is to begin, unless EPA or the state authority hasgranted permission for a different date.

Managers of Postal Service facilities with planned construction activitymust submit applications at least 90 days before the date on whichconstruction is to begin. When feasible, applications should be submittedwell in advance of all regulatory time limits.

3-3.5 What Are the NPDES Industrial Point Source ProcessWastewater Discharge Permit Requirements?

A NPDES industrial point source process wastewater discharge permitgenerally specifies an acceptable level of a pollutant or pollutant parameterin a discharge (e.g., a specific level or range for pH in water from boilerblowdown), but the permittee may choose which technologies to use toachieve that level. The exact requirements are specific to each permit.

A Postal Service facility with a NPDES industrial point source processwastewater discharge permit must ensure that its discharges meet allapplicable limits, reporting, and monitoring requirements.

For further

information about

EPA delegation

and permitting authority,

refer to Handbook

AS�554�C.

The permit

application must

be filed before discharge

begins:

� 180 days in advance for a

process change or new

operation.

� 90 days in advance for

construction.

New construction

permit issues are

handled by the

FSO, whereby the

construction manager works

through the facility

environmental specialist.

Handbook RE�6, Facilities

Environmental Guide,

contains more information.

3-10

38


3-3.6 What Are the NPDES Industrial Point Source ProcessWastewater Discharge Permit Reporting Requirements?

Facility managers must file a notice of intent (NOI) with the appropriateregulatory agency (state, tribal land, or EPA regional office) prior tocommencing any industrial process wastewater discharge from facilityoperations. Once an industrial process discharge permit has beenobtained, the facility must report monitoring results at intervals specified inits permit. Permit holders must also report planned physical alterations oradditions to the facility; all anticipated noncompliance with permitrequirements, including incidents that exceed effluent limits; and allviolations of maximum daily discharge limits for pollutants listed in thepermit.

3-3.7 Who Signs NPDES Industrial Point Source ProcessWastewater Discharge Permit Applications and Reports?

All applications, reports, or information submitted to the appropriateregulatory agency must be signed and certified by the facility manager. Anyperson who knowingly makes any false statement, representation, orcertification in any record or other document related to the permit facessevere fines and imprisonment. Legal requirements may necessitate aPCES manager to sign a permit; a functional area or VMF manager maynot qualify under certain federal regulations. Contact legal counsel forfurther information and clarification.

3-3.8 Who Is Responsible for Complying With the NPDESIndustrial Point Source Process Wastewater DischargePermit?

Although the DECC is a resource in obtaining the industrial point sourceprocess wastewater discharge permit, ultimately the facility manager isresponsible for complying with any and all permits, regardless of whetherthe property is postal-owned or postal-leased.

3-3.9 What Happens If a Facility Does Not Comply With theNPDES Industrial Point Source Process WastewaterDischarge Permit?

Failing to comply with NPDES industrial point source process wastewaterdischarge permit requirements can result in a series of administrative, civil,and criminal penalties prescribed in the CWA. These penalties includelarge fines, closing the facility, and prison sentences.

DECCs should assist

facility managers to:

� Determine whether or not

VMFs are complying with

all required NPDES

permits.

� Contact state water

regulators to resolve

uncertainties regarding

the need for a permit.

� Ensure that all effluent

outfalls have been

surveyed to determine

permit needs.


39

3-3.10 How Are NPDES Industrial Point Source ProcessWastewater Discharge Permits Renewed?

Information concerning the procedures for permit renewal is typically foundon the permit itself. The state or local regulatory agency will notify the permitholder (e.g., facility manager) prior to the permit’s expiration date. Thepermit holder then submits the required information and the associatedpermit fee. The permit is automatically renewed when payment is received.

If the state fails to send a renewal notice, the facility manager is ultimatelyresponsible for maintaining a current NPDES permit. In this situation, afacility manager must submit another NOI form before the permit’sexpiration in order to retain continued coverage. The submittal of the NOIsatisfies the notification requirement covered under the reissued permit.

If site conditions, activities, or operations change, the permit holder mustreapply for a new permit and/or file an NOI describing the new conditions,activities, or operations that need to be permitted.

3-3.11 Where Can Further Information and Assistance BeObtained?

Additional information on NPDES industrial point source processwastewater discharge permits may be obtained from:

� Appendix A, which provides guidance on training and outreachstrategies.

� Appendix B, which describes various BMPs for stormwater.

� State and local environmental laws and regulations.

� Clean Water Act, Public Law 95–217.

� 40 CFR 110 — Discharge of Oil.

� 40 CFR 112 — Oil Pollution Prevention.

� 40 CFR 122 — EPA Administered Permit Programs: The NationalPollutant Discharge Elimination System.

� 40 CFR 125 — Criteria and Standards for the National PollutantDischarge Elimination System.

� 40 CFR 136 — Guidelines Establishing Test Procedures for theAnalysis of Pollutants.

3-12

40


3-4 What Needs to Be Known About NPDESStormwater Discharge Permits?

3-4.1 What Is Stormwater?

Stormwater includes rainwater runoff, snowmelt runoff, and surface runoffand drainage. It is discharged from a variety of point and nonpoint sources,including separate storm sewers, construction activities, waste disposal,and resource extraction activities, all of which can be major causes ofimpairing water quality.

3-4.2 How Is Stormwater Discharge Regulated?

The CWA requires EPA to control the pollution entering into the waters ofthe United States from point and nonpoint sources. Recent amendmentsto the CWA established a two-phased approach to addressing stormwaterdischarges. Phase I requires permits for:

� Separate storm sewer systems serving large- and medium-sizedcommunities (those with over 100,000 inhabitants).

� Stormwater discharges associated with industrial activity.

� Construction activity involving at least 5 acres.

Phase II, which is finalized, addresses the remaining stormwaterdischarges, including smaller storm sewer systems in urbanized areas andconstruction sites disturbing 1–5 acres in size. As with all otherenvironmental-related legislation, the Postal Service will issue guidanceonce the regulations are codified.

3-4.3 What Activities Are Subject to NPDES StormwaterDischarge Permitting?

The Postal Service’s standard industrial code (SIC) is 4311(transportation), which means that Postal Service facilities that havevehicle and equipment maintenance shops and equipment cleaningoperations engage in “industrial activity.” Thus, numerous postal activitiessuch as outdoor material and equipment storage, facility and equipmentwashing, and outdoor painting are potentially subject to NPDESstormwater discharge regulations. Postal Service facilities wherepersonnel engage in these activities must be covered by a NPDESstormwater permit regardless of whether they discharge to a separatemunicipal storm sewer system or directly to waters of the United States.See Exhibit 3-4.3a for an example of potential NPDES stormwater-permitted activities.

Sewer systems

that discharge

stormwater runoff combined

with municipal sewage are

point sources that require

NPDES permits.


41

DetentionPond

Exhibit 3-4.3aActivities That May Necessitate a NPDES Stormwater Discharge Permit

RoofDrain

StormSewer

Trench Drains Storm

DrainageWell

StormwaterCatch Basin

Manhole

StormwaterCatch Inlet

Plant

VMF

Manhole

Parking

Note: This schematic showspossible NPDES stormwaterdischarge permit requirementsassociated with a catch inletadjacent to the plant. Thisrequirement is only accurate ifstormwater flow from the VMF iscommingled with the plant’sstormwater flow. If the flow is notcommingled (i.e., the areas andflows are separate), then NPDESstormwater requirements may notbe necessary.

Sewer

RoofDrain

RoofDrain

Stream

NPDES Stormwater Requirements

NPDES StormwaterRequirements



3-14

42


Note: For facilities with fueling operations and no VMF, the state may ormay not require a NPDES stormwater discharge permit. Consult with legalcounsel for further information. Exhibit 3-4.3b provides further informationabout Postal Service mobile fleet fueling, compressed natural gas (CNG)fueling, and electrical fueling NDPES stormwater discharge requirements.

Stormwater associated with industrial activity that collects in an on-sitedetention or retention basin and then evaporates or percolates into theground is not a discharge subject to the NPDES stormwater dischargeregulation. However, if the same basin periodically discharges stormwater,such as during heavy storm events or following a spring snowmelt, theoutfall of the basin would be a point source subject to NPDES regulation.Handbook AS-554-A contains further information on stormwater collectionsystems.

Construction activities such as parking lot or building expansion that canpotentially affect stormwater may also require NPDES stormwaterdischarge permits. Handbook RE-6 contains more information concerningnew construction activities and associated regulatory requirements. Inaddition, states with NPDES stormwater discharge permitting authoritymay have additional requirements related to construction activities.

Even though a facility’s activities do not require a NPDES stormwaterdischarge permit, environmental professionals should encourage facilitymanagers to consider the activity’s potential effect on water quality to ouremployees, customers, and business operations.

Contact Postal Service legal counsel for further information andclarification on whether or not a specific activity requires a NPDESstormwater discharge permit.

3-4.4 Who Is Responsible for Obtaining a NPDES StormwaterDischarge Permit?

The operator of a facility discharging pollutants is responsible for applyingfor the NPDES stormwater discharge permits regardless of property orfacility ownership. Under Postal Service policy, facility managers mustensure that all activity operators have obtained all required permits.

DECCs should assist

facility managers to:

� Determine whether or not

VMFs are complying with

all required NPDES

permits.

� Contact state water

regulators to resolve

uncertainties regarding

the need for a permit.

� Ensure that all effluent

outfalls have been

surveyed to determine

permit needs.

Permits are

required for all

VMFs, including those

involved in washing, fueling,

or mechanical repair, unless

all stormwater from these

activities is captured and

prevented from discharging.


43

Exhibit 3-4.3bMobile Fleet Fueling, CNG Fueling, and Electric Fueling NPDES PermitRequirements

Mobile Fleet Fueling

The issue of mobile fleet fueling has recently become a point ofdiscussion within the Postal Service. Although the concept of mobilefleet fueling may be attractive, the Postal Service must be aware that thisactivity may cause a facility to fall under CWA NPDES stormwaterpermitting requirements and the associated liabilities andrecordkeeping requirements. Some states and EPA regions have takenthe position that if fueling takes place at a postal facility (i.e., atransportation facility under NPDES criteria), a NPDES stormwaterpermit is necessary according to 40 CFR 122.

If mobile fleet fueling is to be undertaken, the facility must obtain a letterfrom the state exempting it from NPDES stormwater permittingrequirements. If the state will not issue an exemption letter, the facilityshould then obtain an opinion letter from the mobile fuel supplier’s lawfirm stating that there is no requirement for the Postal Service to obtainthe permit and that the fuel supplier will be responsible for obtaining apermit and adhering to its requirements.

If the facility is able to obtain one or the other letter, then an appropriatecontract with indemnification from the major supplier (not the localsupplier) is the appropriate next step. If mobile fleet fueling isundertaken, the facility must have contingency plans and controlmeasures (including associated training) in place and current. If thefacility cannot obtain either letter, it should not enter into a mobile fleetfueling agreement. For further information and clarification on this issue,contact legal counsel.

CNG and Electric Fueling

The Postal Service’s interpretation of current federal and state NPDESstormwater discharge permit regulations is that fueling relates only totraditional liquid fuel such as gasoline or diesel. Thus, it is not necessaryat this time to obtain a federal or state NPDES stormwater dischargepermit for any CNG or electric fueling sites. The exception would be ifthe state regulates all sites with similar fueling. In any event, a VMF hasto obtain a NPDES stormwater permit regardless of any fuelingsituation. Contact legal counsel for further information and clarification.

3-16

44


For construction activity, the FSO is responsible for obtaining a NPDESconstruction stormwater discharge permit in instances where the PostalService is responsible for:

� Operational control of project plans and specifications, including theability to modify them.

� Operational control of daily activities necessary to ensurecompliance with a Stormwater Pollution Prevention Plan (SWPPP).

� Other NPDES stormwater discharge permit conditions (e.g.,authorization to direct workers at a site to carry out activitiesrequired by the SWPPP or other permits).

In many instances, the contractor has operational control and thus isresponsible for obtaining the NPDES stormwater discharge permit.However, FSOs must check with state regulators (or the EPA regionaloffice) to verify the responsibility. Further information concerningconstruction-related permitting issues can be found in Chapter 5.

For new construction projects (for new facilities, operations, or activities),permitting issues and other activities such as wetlands delineationprocesses are handled by facility environmental specialists (FESs).

DECCs should coordinate obtaining NPDES stormwater permits with thefacility manager, Administrative Support unit, FSO, and/or MFO, asnecessary and appropriate. DECCs are available to assist facilitymanagers with conducting surveys to identify all discharges and potentialpermitting requirements.

3-4.5 Who Issues NDPES Stormwater Discharge Permits?

As of March 1998, EPA authorized most states to administer the NPDESstormwater discharge program. Where permit authority has not beendelegated to the state or territory, the facility manager must apply forpermits directly from an EPA regional office.

3-4.6 When Must a NPDES Stormwater Discharge Permit BeObtained?

Generally, an application must be submitted 180 days prior to beginning theactivity for a new stormwater discharge associated with industrial activity.Consult with the appropriate agency (state or EPA region) for specificinformation.


45

3-4.7 What Types of NPDES Stormwater Discharge Permits CanBe Obtained?

There are two types of NPDES stormwater discharge permits from whichto choose: general and individual. Additionally, there are three types ofgeneral permits: baseline general permit (BGP); construction activity BGP;and multisector general permit (MSGP) for industrial activities. Each typeof NPDES stormwater discharge permit is discussed below.

3-4.7.1 What Are Baseline General Permits?

BGPs are intended to cover most dischargers throughout a given state orregion. With a BGP, all stormwater dischargers are subject to the samebasic permit conditions. The EPA Storm Water Baseline General Permitexpired in September 1997. EPA is presently reissuing the BGPapplication. Until the BGP is reissued, all general permittees who are notcurrently covered by the MSGP must file for coverage under it. The PostalService is already covered under the MSGP.

3-4.7.2 What Are Construction Activity Baseline GeneralPermits?

Construction activity BGPs authorize all discharges of stormwater fromconstruction activities and construction supporting activities for localprojects in which the facility is currently involved. This includes stagingareas and material storage areas.

Excluded from coverage are discharges occurring after constructionactivities have ceased and discharges containing a mix of stormwater andnonstormwater (e.g., wastewater).

3-4.7.3 What Are Multisector General Permits?

The NPDES stormwater discharge MSGPs cover 29 industrial sectors anda number of subsectors. These MSGP permits include general provisionsthat apply to all sectors, along with industry-specific pollution preventionand monitoring requirements. The Postal Service is in Sector P, “LandTransportation Facilities That Have Vehicle and Equipment MaintenanceShops and/or Equipment Cleaning Operations,” SIC 4311. Many statesthat have authorization to issue these permit types have adopted theapproach used by EPA in its multisector permit to issue their statestormwater discharge MSGP.

3-4.7.4 What Are NPDES Stormwater Discharge IndividualPermits?

Individual permits are issued to a specific facility for stormwater dischargesrelated to an industrial activity at specified locations. The permit is usuallytailored to meet the facility’s discharge characteristics and the specialrequirements of the receiving waters. Thus, individual permits may be more

The types of

NPDES

stormwater discharge

permits are:

� General:

- Baseline.

- Construction activity.

- Multisector.

� Individual.

The permits

described in

3�4.7.1 through 3�4.7.4 are

issued by EPA to states and

tribal regions without

NPDES stormwater

permitting authority. States

with NPDES stormwater

permitting authority usually

issue permits with similar

requirements.

3-18

46


restrictive than the NPDES stormwater BGP or MSGP. Some states lackauthority to issue general permits and therefore issue individual permitsonly. Facility managers, with assistance from the DECC, must contact theirstate or EPA regional office to determine if an individual permit is required.

3-4.8 Which Type of Permit Should Be Chosen?

Facility managers must obtain NPDES stormwater discharge permits fromthe appropriate state agency if the state has permitting authority. In statesthat lack stormwater permitting authority, facility managers will generallyhave to choose between the MSGP or a BGP obtained from an EPAregional office. Some advantages and disadvantages of the MSGP versusthe BGP are listed below. Note that these are general in nature; a specificfacility may realize different advantages and disadvantages. Contact thestate or local regulatory authority and legal counsel for further informationand clarification.

3-4.8.1 What Are the NPDES Stormwater Discharge MSGPAdvantages Over the BGP?

The following are advantages of the NPDES stormwater discharge MSGP:

� Permit conditions are industry specific, generally resulting in fewermonitoring parameters.

� It provides the ability to waive monitoring on a pollutant-by-pollutant basis (waivers under the BGP are only available on aneffluent outfall-by-effluent outfall basis).

� No special monitoring requirements exist for facilities subject to theEmergency Planning and Community Right-to-Know Act section313, Toxic Release Inventory Reporting, requirements.

� The length of time records must be kept is less — generally 3 yearsfor MSGP documents versus 6 years for BGP documents.

3-4.8.2 What Are the NPDES Stormwater Discharge MSGPDisadvantages Compared to the BGP?

The following are disadvantages of the NPDES stormwater dischargeMSGP:

� Detailed sector-specific conditions must be considered in theSWPPP.

� Most sectors are subject to three types of monitoring requirements(the BGP has one monitoring requirement).

� Benchmark values established for pollutants could be difficult tomeet.

The Postal

Service

subscribes to the

following online service

that provides information

about reportable quantities

and state and federal

environmental, health, and

safety regulations:

http://www.regsmart.com.


47

3-4.9 What Are the NPDES Stormwater Discharge PermitRequirements?

In general, all stormwater permits contain the following requirements:

� Only stormwater may be discharged. Other discharges must becovered by a separate NPDES permit.

� Stormwater discharges containing hazardous substances aresubject to reportable quantity requirements and must be minimized.During any 24-hour period, no discharge of stormwater can containa hazardous substance equal to or exceeding reportable quantities.(For a list of hazardous chemicals and amounts that constitute“reportable quantities,” see 40 CFR 117.3.)

� Each facility must have an SWPPP. Refer to the EMP intranet sitefor SWPPP requirements and statements of work. Remember,individual states may have separate and more stringent SWPPPrequirements than EPA. To assist facilities to develop an SWPPP, amodel integrated Spill Prevention Control and Countermeasures(SPCC) Plan and SWPPP can be downloaded from the EMP waterprogram intranet web site.

3-4.10 What Are the NPDES Stormwater Discharge ReportingRequirements?

An NOI must be filed with the appropriate regulatory agency (state, triballand, or EPA regional office) prior to commencing any NPDES stormwaterdischarge from a new facility operation. Once a NPDES stormwaterdischarge permit has been obtained, monitoring results, in general, mustbe documented and reported at intervals specified by the facility’s permit.Permit holders must also report planned physical alterations or additionsto the facility; all anticipated noncompliance with NPDES stormwaterdischarge permit requirements, including discharges that exceed effluentlimits; and all violations of maximum daily discharge limits for pollutantslisted in the permit.

3-4.11 Who Signs NPDES Stormwater Discharge PermitApplications and Reports?

All applications, reports, or information submitted to the appropriateregulatory agency must be signed and certified by the facility manager. Anyperson who knowingly makes any false statement, representation, orcertification in any record or other document related to the permit facessevere fines and imprisonment. Legal requirements may necessitate aPCES manager to sign a permit; a functional area or VMF manager maynot qualify under certain federal regulations. Contact legal counsel forfurther information and clarification.

DECCs should

ensure that the

facility SWPPP and SPCC

Plan are consistent and

consider integrating the two

plans. A model integrated

plan can be obtained from

the EMP intranet site.

3-20

48


3-4.12 Who Is Responsible for Complying With the NPDESStormwater Discharge Permit?

Although the DECC assists in obtaining all permits, ultimately the facilitymanager is responsible for complying with all permits, regardless ofwhether the property is postal-owned or postal-leased.

3-4.13 What Happens If a Facility Does Not Comply With theNPDES Stormwater Discharge Permit?

Failing to comply with NPDES stormwater discharge permit requirementscan result in a series of administrative, civil, and criminal penaltiesprescribed in the CWA. These penalties include large fines, closing thefacility, and prison sentences.

Exhibit 3-4.13 is a case study of a Postal Service facility that violated itsNPDES stormwater discharge permit requirements and the mitigationsteps that were necessary to avoid possible severe penalties and costlylitigation.

3-4.14 How Are NPDES Stormwater Discharge Permits Renewed?


If the state fails to send a renewal notice, the facility manager is ultimatelyresponsible for maintaining a current NPDES permit. In this situation, afacility manager must submit another NOI form before the permit’sexpiration in order to retain continued coverage. The submittal of the NOIsatisfies the notification requirement covered under the reissued permit.


3-4.15 Where Can Further Information and Assistance BeObtained?

Additional information on this subject may be obtained through thefollowing resources:


� Appendix B, which describes various BMPs for stormwater.


49

Stormwater Management ProjectDominick V. Daniels (DVD) FacilityKearny, New Jersey

As a result of a civil action case, the U.S. Postal Service is currently pursuing a settlement agreement involvingthe DVD Facility due to its violations associated with the DVD Sewage Treatment Plant NPDES Permit.

As part of the draft consent decree, the Postal Service has agreed, in principle, to provide a supplementalenvironmental project (SEP) in lieu of a portion of the civil penalties. The selected SEP includes the design,construction, and operation of a stormwater management project to treat surface runoff from the DVD Facility.The project is designed to enhance stormwater runoff quality from the processing and distribution center andVMF. It also includes an effort with the New Jersey Transit Corporation to restore and enhance the existingwetland marsh located west and adjacent to the DVD Facility.

Detention and treatment of stormwater runoff for quality enhancement will be provided by a series of siteperimeter swales that collect surface water runoff from paved surfaces and convey flows to a commondetention pond and created wetland area. Other proposed site improvements include:

� Separation of roof and parking drainage.

� Regrading of parking areas.

� Installation of oil and water separators.

� Gravel trench and employee parking modifications.

� Enhanced emphasis on SWPPP BMPs.

In addition, restoration of the existing marsh located outside of the fenced facility is also proposed. The overallrestoration objective is wetland enhancement through removal of debris and trash, manipulation of waterlevels, and reestablishment of native species. The work is intended to improve the quality of the existingmarsh, which serves as the receiving body for stormwater discharge from the DVD Facility, as well as otherareas upstream and within the watershed boundary.

The primary benefits of the project are:

� Runoff from areas producing high quality discharge will be separated from the lower quality runoff, allowingfor more effective treatment.

� Runoff from sheet flow and point source discharges, which are currently released without treatment intoDeadhorse Creek, will be eliminated.

� The proposed grass swales, detention basin, and created wetland will reduce initial and peak stormwaterdischarge rates, coinciding with a reduction in pollutants released in receiving waters and improvement ofstormwater runoff quality by allowing increased infiltration of stormwater into the subsurface soils, providingincreased detention time for settling of suspended solids, and reducing pollutant loadings through vegetativeremoval of nutrients and other pollutants.

� Removal of debris and trash from the existing marsh will improve wetland system quality and facilitateopportunities to seed and/or plant the marsh with desired vegetation.

Two years after the Postal Service completed construction of the stormwater retention system, the plaintiffsreopened the litigation, alleging that the Postal Service had failed, among others, to meet the prolongeddetention requirement established in the consent decree. The plaintiffs demanded that the system besignificantly modifed and, when the Postal Service refused, filed to reopen the case. The Postal Service hasfiled to dismiss the reopening of this litigation as untimely, believing it has fully complied with the requirementsof the consent decree. The Postal Service asserts the plaintiffs had ample opportunity, during the commentdesign phase of the stormwater control system, to comment on the proposed system. For further informationon this matter, contact Postal Service legal counsel or EMP Headquarters.

Exhibit 3-4.13Dominick Versus Daniels Case Study

3-22

50



� 40 CFR 110 — Discharge of Oil.

� 40 CFR 112 — Oil Pollution Prevention.

� 40 CFR 122 — EPA Administered Permit Programs: The NationalPollutant Discharge Elimination System.

� 40 CFR 125 — Criteria and Standards for the National PollutantDischarge Elimination System.

� 40 CFR 136 — Guidelines Establishing Test Procedures for theAnalysis of Pollutants.



51

Contents

4 What Are the National Municipal PretreatmentProgram Requirements? 4-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4-1 What Does Pretreatment Mean? 4-3. . . . . . . . . . . . . . . . . . . . . . . . . .

4-2 What Is the National Pretreatment Program? 4-3. . . . . . . . . . . . . . .

4-3 What Activities Are Subject to PretreatmentRequirements? 4-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4-4 What Are the Pretreatment Requirements? 4-4. . . . . . . . . . . . . . . . .

4-5 Who Enforces Pretreatment Standards? 4-6. . . . . . . . . . . . . . . . . . .

4-6 What Are the Reporting Requirements for PostalDischargers to POTWs? 4-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4-7 When Must a Pretreatment Permit Be Obtained? 4-7. . . . . . . . . . . .

4-8 Who Is Responsible for Obtaining a Permit? 4-8. . . . . . . . . . . . . . . .

4-9 Who Signs Permit Applications and Reports? 4-8. . . . . . . . . . . . . . .

4-10 Who Is Responsible for Complying With the Permit? 4-8. . . . . . . . .

4-11 What Happens If a Facility Does Not Comply? 4-8. . . . . . . . . . . . . .

4-12 How Are Permits Renewed? 4-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4-13 Where Can Further Information and AssistanceBe Obtained? 4-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit

Exhibit 4-3Activities That May Necessitate a Pretreatment Permit 4-5. . . . . . . . . . . . . . . . .


53

4 What Are the National Municipal

Pretreatment ProgramRequirements?

This chapter describes pretreatment requirements and how they affectthe Postal Service. The CWA serves as the authority for pretreatmentregulations to which dischargers to POTWs must adhere. To implementthese regulations, EPA established the National Pretreatment Program.

4-1 What Does Pretreatment Mean?

Pretreatment refers to pollutant control requirements for industrialsources discharging wastewater to sewer systems that are connected toPOTWs. EPA, the state, or the local authority establishes limits on theamount of pollutants allowed to be discharged. Pretreatment limits maybe met via pollution prevention (e.g., replacing a product with anenvironmentally friendly product, recycling, and reusing materials) ortreatment of the wastewater.

4-2 What Is the National Pretreatment Program?

The National Pretreatment Program is a cooperative effort of federal,state, and local regulatory environmental agencies established to protectwater quality. The program is designed to reduce the level of pollutantsdischarged by industry and other nondomestic wastewater sources intomunicipal sewer systems, thereby reducing the amount of pollutantsreleased into the environment through wastewater.

The objectives of the National Pretreatment Program are to:

� Prevent industrial facilities’ pollutant discharges from passinguntreated through municipal wastewater treatment plants.

� Protect treatment plants from the threat posed by untreatedindustrial wastewater, including explosion, fire, and interferencewith the treatment process.

Postal Service

activities that

discharge wastewater to

sewer systems connected to

POTWs may be subject to

pretreatment requirements.

Under the NPDES

program, POTWs

are required to ensure that

their effluent meets CWA

standards. To comply,

POTWs are authorized by

the National Pretreatment

Program to set limits on all

wastewater discharges

passing through their

systems.

4-4

54


� Improve the quality of effluents and sludges so that they can beused for beneficial purposes.

Although POTWs have their own treatment processes, they are generallynot designed to handle all industrial or commercial wastes. POTWs andtheir storm sewer systems, if the system is combined, collect and treatdischarges from households, businesses, and industries, as well as runofffrom city rooftops and streets, before releasing them back into localwaterways. The pretreatment processes they require are importantbecause they ensure that industrial discharges are treated to limitcontaminant levels before being discharged to the POTW and finally intothe nation’s waters.

4-3 What Activities Are Subject to PretreatmentRequirements?

Postal Service activities that discharge wastewater to sewer systemsconnected to POTWs are potentially subject to pretreatmentrequirements. Some Postal Service discharges that may be subject topretreatment standards and permits include process wastewater, boilerblowdown, cleaning processes, oil and grease, sump discharges, floordrain discharges, and stormwater runoff. Exhibit 4-3 illustrates activitiesa typical VMF or plant engages in for which a pretreatment permit may benecessary. Also see Handbook AS-554-A, Chapters 5 and 6, foradditional information about these requirements and a facility’sresponsibilities.

4-4 What Are the Pretreatment Requirements?

The National Pretreatment Program establishes two sets of standards:pretreatment categorical standards and prohibited discharges. POTWsgenerally use permits to enforce both standards.

Pretreatment categorical standards specify quantity and concentrationlimits for pollutants discharged via point sources to POTWs from specificindustries grouped into categories. The list of industry categories, foundin 40 CFR 405–471, includes hospitals, timber products processing,electroplating, and dairy products processing. Postal Service facilities,operations, and activities do not qualify for any of the industry categorieson the federal list. However, states that have authority to administer theirown pretreatment program may determine that Postal Service facilities,operations, or activities fall within an existing category or constitute aseparate category. In this case, Postal Service facilities will be requiredto adhere to categorical standards established by the state.

Activities with the

following discharges

may be subject to

pretreatment requirements:

� Process wastewater.

� Boiler blowdown.

� Cleaning processes

discharges.

� Oil and grease.

� Sump discharges.

� Floor drain discharges.

� Stormwater runoff.

Discharges into

municipal sewer

systems that are not

connected to a treatment

plant are direct discharges

subject to NPDES permit

requirements.


55

Exhibit 4-3Activities That May Necessitate a Pretreatment Permit

Parking

Boiler

CoolingTower

UtilitySink

Trench Drains

Drinking

SanitarySewer

Drinking

Restroom

Shower, Sink,

Battery Room

AcidNeutralizationSump

VehicleMaintenanceArea

Cafeteria

VehicleWash

Sand & Oil/Water

Plant

VMF

Sink

CustodialCloset

Water Fountain

Toilet

Area

PretreatmentRequirements




Separator

Chiller

GreaseTrap

Water Fountain

Stream

Sand &Oil/WaterSeparator

4-6

56


The prohibited discharges standard prohibits the disposal of wastes that:

� Create a fire or explosion hazard in the collection system ortreatment plant (e.g., disposal of flammable or ignitable liquidssuch as gasoline).

� Corrode, including any discharge with a pH less than 5.0 or greaterthan 9.0, unless the POTW is specifically designed to handle suchwastes (e.g., disposal of excess lime from landscaping activities).Check with the POTW for specific requirements on corrosivedischarges.

� Obstruct the flow in the collection system and treatment plant,resulting in interference with operations, by solid or viscouspollutants (e.g., disposal of excess paper).

� Interfere with POTW operations when discharged in significantquantities (e.g., excess amounts of concentrated cleaning solutionsor other liquids that may interfere with biological processes).

� Contain water temperatures above 104 degrees Fahrenheit (�F)when they reach the treatment plant, or are hot enough to interferewith biological processes (e.g., release or disposal of excessamounts of boiler water or water-reactive chemicals such assodium or sulfuric acid).

These general prohibited discharges apply to all industrial facilities thatdischarge pollutants into a POTW whether or not the facility is subject tocategorical standards or any national, state, or local pretreatmentrequirements (see 40 CFR 403.5 for more information). The primary wayto avoid pretreatment standards is to eliminate polluted discharges toPOTWs or to reduce the discharges’ toxicity through pollution preventionefforts.

4-5 Who Enforces Pretreatment Standards?

EPA is responsible for establishing pretreatment standards for industrialsources, which local POTWs must enforce. More than 1,500 POTWshave full authority to implement their pretreatment programs. Typically,local POTWs develop their programs by amending their existing generalsewer ordinances or by enacting a specific pretreatment ordinancethrough their local government.

Although federal guidelines do not mandate the use of permits, mostPOTWs use permits as a means of program enforcement. Many localpretreatment standards are stricter than the federal guidelines. POTWsdo this to minimize the effects of cumulative pollutant loading fromnumerous local sources.

The primary way to

avoid pretreatment

standards is to eliminate

polluted discharges to

POTWs or to reduce the

discharges' toxicity through

pollution prevention efforts.

Additional

information about

pretreatment

standards for state and

federal environmental,

health, and safety

regulations can be found at

http://www.regsmart.com.


57

4-6 What Are the Reporting Requirements forPostal Dischargers to POTWs?

Postal Service facilities that are not subject to categorical standards arestill subject to the particular reporting requirements established by theirlocal POTW.

Postal facility managers who have been informed by their state and orlocal POTW that they are subject to categorical pretreatment standardshave pretreatment reporting requirements that include:

� Information identifying the facility.

� What environmental control permits the facility has obtained.

� Description of operations.

� Measurement of waste stream flow.

� Measurement of pollutants applicable to each regulated process.

� Certification that pretreatment standards are beingconsistently met.

� Schedule for complying with additional pretreatment and/oroperations and maintenance requirements to meet pretreatmentstandards.

The facility must notify the POTW immediately (or as soon as the facilityis aware of the incident) if unexpected discharges occur that have thepotential to upset the POTW’s operation. Refer to 40 CFR 403.12,Reporting Requirements for POTWs and Industrial Users, for furtherreporting requirements information.

4-7 When Must a Pretreatment Permit BeObtained?

Some POTWs are required to meet certain effluent standards andtherefore may require pretreatment and a pretreatment permit fromanyone who discharges into the system (e.g., Postal Service facilities). Bylaw, local POTWs cannot enforce specific effluent limits without firstalerting affected dischargers who have requested notice. Thus, it is thefacility manager’s duty to request that the POTW provide such notice.

For information about categorical pretreatment standards, a facilitymanager may request that the EPA regional office provide writtencertification declaring what, if any, industrial category the facility fallsunder. Existing Postal Service facilities should not need this certification.Thus, a facility manager should not request one without first consultingwith the DECC and/or legal counsel. However, if any changes in operation

Postal Service

facilities that are

not subject to categorical

standards are still subject to

the particular reporting

requirements established by

their local POTW.

Existing Postal

Service facilities

should not need an

industrial standard

certification and should not

request one without first

consulting with the DECC

and/or legal counsel.

4-8

58


are planned that might bring the facility under a categorical pretreatmentstandard, the facility manager must obtain certification 90 days prior tocommencing such a discharge.

4-8 Who Is Responsible for Obtaining a Permit?

If the local POTW issues pretreatment effluent standard permits, theoperator of the facility (e.g., the facility manager) discharging pollutantsis responsible for obtaining a permit regardless of ownership. UnderPostal Service policy, facility managers must ensure that all activityoperators have obtained all required permits. DECCs are available tocoordinate obtaining permits with the facility manager, AdministrativeSupport unit, FSO, and MFO, as necessary and appropriate.

4-9 Who Signs Permit Applications and Reports?

All applications, reports, or information submitted to the appropriate stateand/or local agency must be signed and certified by the facility manager.Any person who knowingly makes any false statement, representation, orcertification in any record or other document related to the pretreatmentpermit faces severe monetary fines and imprisonment. Legalrequirements may necessitate a PCES manager to sign a permit; afunctional area or VMF manager may not qualify under certain federalregulations. Contact legal counsel for further information and clarification.

4-10 Who Is Responsible for Complying With thePermit?

The facility manager is responsible for ensuring that the facility complieswith all pretreatment permit conditions and requirements. However, theDECC should provide assistance if necessary.

4-11 What Happens If a Facility Does Not Comply?

Failing to comply with permit requirements can result in a series ofadministrative, civil, and criminal penalties prescribed in the CWA. Thesepenalties include large fines, closing the facility, and prison sentences.


59

4-12 How Are Permits Renewed?

Information concerning the procedures for permit renewal is typicallyfound on the permit itself. The state or local regulatory agency will notifythe permit holder (e.g., facility manager) prior to the permit’s expirationdate. The permit holder then submits the required information and theassociated permit fee. The permit is automatically renewed whenpayment is received.

If the state fails to send a renewal notice, the facility manager is ultimatelyresponsible for maintaining a current pretreatment permit. In thissituation, a facility manager must submit another NOI form before thepermit’s expiration in order to retain continued coverage. The submittal ofthe NOI satisfies the notification requirement covered under the reissuedpermit.


4-13 Where Can Further Information andAssistance Be Obtained?

Additional information on pretreatment requirements may be obtainedfrom the following resources:




� Vehicle Maintenance Bulletin V-07-95, Pollution Prevention:Alternative Cleaning Solutions in Parts Washers.

� MMO 49-93, Pollution Prevention: Postal/EPA Targeted Chemicals.

� MMO 25-85, Preparation and Maintenance of Cooling Towers.

� MMO 3-96, Pollution Prevention: Alternative Cleaning Solutions inParts Washers for Use in Postal Facilities.

� Handbook MS-1, Operation and Maintenance of Real Property.

� Handbook RE-6, Facilities Environmental Guide.


61

Contents

5 What Are the Wetlands Protection Requirements? 5-3. . . . . . .

5-1 What Are Wetlands? 5-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-2 How Are Wetlands Protected? 5-4. . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-2.1 What Are USACE’s Responsibilities? 5-4. . . . . . . . . . . . .

5-2.2 What Are EPA’s Responsibilities? 5-4. . . . . . . . . . . . . . . .

5-2.3 How Does the CWA Section 401, Water QualityCertification, Program Protect Wetlands? 5-5. . . . . . . . . .

5-3 What Is Our Floodplain and Wetlands Management Policy? 5-5. .

5-4 How Are Wetlands Determined? 5-5. . . . . . . . . . . . . . . . . . . . . . . . . .

5-4.1 How Are Vegetation Indicators Determined? 5-6. . . . . . .

5-4.2 How Are Soil Indicators Determined? 5-6. . . . . . . . . . . . .

5-4.3 How Are Hydrology Indicators Determined? 5-6. . . . . . .

5-4.4 What Are the General Indicators? 5-7. . . . . . . . . . . . . . . .

5-5 What Activities Are Subject to Wetlands Permitting? 5-8. . . . . . . . .

5-6 Who Must Obtain a Wetlands Permit? 5-8. . . . . . . . . . . . . . . . . . . . .

5-7 When Must a Wetlands Permit Be Obtained? 5-10. . . . . . . . . . . . . . .

5-8 What Must Be Done Before Applying for a WetlandsPermit? 5-10. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-9 What Types of Wetlands Permits Are Available? 5-10. . . . . . . . . . . .

5-9.1 What Are Nationwide Wetlands Permits? 5-11. . . . . . . . . .

5-9.2 What Are Regional or General Wetlands Permits? 5-12. .

5-9.3 What Are Individual Wetlands Permits? 5-12. . . . . . . . . . .

5-9.4 What Is the Process for Obtaining an IndividualWetlands Permit? 5-13. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-10 Who Signs Wetlands Permit Applications and Reports? 5-13. . . . . .

5-11 Who Is Responsible for Complying With the WetlandsPermit? 5-13. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-12 What Happens If a Facility Does Not Comply? 5-14. . . . . . . . . . . . . .

5-13 How Is a Permit Renewed? 5-14. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


5-2

62


Exhibit

Exhibit 5-5Potential Scenario That May Necessitate a Wetlands Permit 5-9. . . . . . . . . . . .


63

5 �� #� �

��%�� (�+�� !

The CWA also contains provisions regarding the protection of wetlands.This chapter describes these provisions and how they apply to the PostalService.

5-1�� #� �!

The U.S. Army Corps of Engineers (USACE) and EPA define wetlands as:

Those areas that are inundated or saturated by surface or groundwater at a frequency and duration sufficient to support, and thatunder normal circumstances do support, a prevalence of vegetationtypically adapted for life in saturated soil conditions. Wetlandsgenerally include swamps, marshes, bogs, and similar areas.

Wetlands are areas that are covered by water or have water-saturated soilsfor periods during the growing season. Some wetlands types include, butare not limited to, bottomland forests, pine savannas, bogs, wet meadows,vernal pools, potholes, and wet tundra. Plants growing in wetlands arecapable of living in saturated soil conditions for at least part of the growingseason. Vegetation types vary and may include such species as cattails,rushes, sedges, and willows.

Wetlands such as swamps and marshes are often obvious, but somewetlands are not easily recognized, often because they are dry or do nothave standing water during part of the year. It is recommended that youfamiliarize yourself with available resources pertaining to wetlands issuesincluding:

� U.S. Fish and Wildlife Service, Division of Habitat Conservation,National Wetlands Inventory web site at http://www.nwi.fws.gov.

� Association of State Wetlands Managers.

!��& ��

��

��A� ��2� �� /:

��B��

� ��

��

��C9�(�

5-4

64


� U.S. Department of Agriculture, Natural Resources ConservationService, National Resources Inventory web site at http://www.nhq.nrcs.usda.gov/NRI.

� National Wildlife Federation web site at http://www.nwf.org/wetlands.

DECCs should be aware of wetlands issues and assist facility managersto identify wetlands even if no construction is planned. One resource is thelocal planning office, which may have records that identify wetlands on oraround a property. Some local and/or state organizations may havewetlands maps prepared for particular areas. In addition, the FES may bea valuable resource for local wetlands inventory.

Wetlands issues associated with new construction projects are overseenby the FES (see Handbook RE-6). Handbook RE-6 as well as MIAS-550-96-4, National Environmental Policy Act Operational Guidance,and MI AS-510-97-6, Environmental Integration in the New ConstructionProcess, also contain further information about wetlands permitting issues.

5-2 How Are Wetlands Protected?

Wetlands are protected under Sections 401 and 404 of the CWA. In thesesections the USACE is authorized to issue permits for the discharge ofdredged or fill materials into waters of the United States for all actions thathave the potential to affect wetlands. The USACE shares wetlandsresponsibility with the EPA.

5-2.1 What Are USACE's Responsibilities?

The USACE:

� Administers the daily program.

� Decides whether or not to grant permits on an individual basis anddetermines what agency has jurisdiction in the matter.

� Develops program policy and guidance.

� Enforces Section 404 provisions.

5-2.2 What Are EPA's Responsibilities?

The EPA wetlands program engages in two principal categories ofactivities — establishing national standards and assisting others to meetthem. The EPA:

� Provides support for both regulatory and nonregulatory wetlandsprotection efforts.

� Promotes and distributes sound wetlands science as the technicalbasis for effective wetlands decision making.

DECCs should be

aware of wetlands

issues and assist facility

managers to identify

wetlands even if no

construction is planned.

Wetlands issues

associated with

new construction projects

are overseen by the FES.


65

� Serves in an advisory capacity for state and tribal wetlandsprograms and for Clean Water Act Section 404 permit decisions.

� Develops national wetlands standards and policies.

� Acts as a regulator to back up state and local partners and ensurethat national standards are lawfully applied.

5-2.3 How Does the CWA Section 401, Water Quality Certification,Program Protect Wetlands?

Section 401 of the CWA (Water Quality Certification) protects state andfederal water quality standards (40 CFR 131). The federal water qualitystandards include:

� Beneficial uses of water.

� Water quality objectives.

� State-specific antidegradation policy.

Section 401 requires that every applicant for a federal permit or license foran activity that may result in a discharge into a water body must requeststate certification that the proposed activity will not violate state and federalwater quality standards. The types of activity that require such acertification include, but are not limited to, flood control channelization,levee construction, or fill of wetlands for land development.

5-3 What Is Our Floodplain and WetlandsManagement Policy?

A summary of Postal Service procedures and requirements for floodplainand wetlands management can be found in 39 CFR 776. Postal Servicepolicy is to implement Executive Orders 11988, Floodplain Management,and 11990, Protection of Wetlands. Handbook RE-6 provides detailedguidance for implementing these executive orders. As a general rule,Postal Service policy is that construction in floodplains or wetlands may beconsidered only when there is no practicable alternative. If a facility actionrequires construction in a floodplain or wetland, contact your FSO andAdministrative Support unit for assistance.

5-4 How Are Wetlands Determined?

The USACE uses three characteristics when determining whether or notan area is a wetlands: vegetation, soil, and hydrology. Unless the area hasbeen altered or is a rare natural situation, wetlands indicators of all threecharacteristics must be present during some portion of the growing seasonfor the area to be a wetlands. Each characteristic is discussed below.

The USACE uses

three characteristics

when determining whether

or not an area is a wetlands:

vegetation, soil, and

hydrology.

5-6

66


5-4.1 How Are Vegetation Indicators Determined?

Nearly 5,000 plant types may occur in wetlands in the United States. Thus,it can be difficult to determine if vegetation at a facility is hydrophytic. Theseplants, known as hydrophytic vegetation, are listed in regional publications.If you cannot determine whether the plant types at the facility are those thatcommonly occur in wetlands, contact the local USACE district office or alocal botanist for assistance.

5-4.2 How Are Soil Indicators Determined?

There are approximately 2,000 named soils that may occur in wetlands inthe United States. Such soils, called hydric soils, have characteristics thatindicate they were developed in conditions where oxygen is limited by thepresence of water-saturated soil for long periods during the growingseason. If the soil at the facility is listed as hydric, the area might be awetlands.

If the name of the soil at the facility is not known, a visual examination ofthe soil can determine the presence of any hydric soil indicators such as:

� Soil consists predominantly of decomposed plant material (peats ormucks).

� Soil has a thick layer of decomposing plant material on the surface.

� Soil has a bluish-gray or gray color below the surface, or the majorcolor of the soil at this depth is dark (brownish-black or black) anddull.

� Soil has the odor of rotten eggs.

� Soil is sandy and has a layer of decomposing plant material on thesoil surface.

� Soil is sandy and has dark stains or dark streaks of organicmaterial in the upper layer below the soil surface. These streaksare decomposed plant material attached to the soil particles. Whensoil from these streaks is rubbed between the fingers, it leaves adark stain on the fingers.

5-4.3 How Are Hydrology Indicators Determined?

Wetlands hydrology refers to the presence of water at or above the soilsurface for a sufficient period of the year to significantly influence the planttypes and soils that occur in the area. Although the most reliable evidenceof wetlands hydrology may be provided by a gauging station orgroundwater well data, such information is limited for most areas and, whenit is available, requires analysis by trained individuals. Thus, mosthydrologic indicators are those that can be observed during fieldinspection.

Hydrophytic

vegetation is

plants adapted to living in

soils that are saturated

with water. Hydric soils are

soils that form due to the

presence of water.

If the soil at the

facility is listed as

hydric, the area might be

a wetlands.

Wetlands

hydrology refers

to the presence of water at

or above the soil surface

for a sufficient period of the

year to significantly

influence the plant types

and soils that occur in the

area.


67

The following hydrology indicators provide some evidence of the periodicpresence of flooding or soil saturation:

� Standing or flowing water is observed on the area during thegrowing season.

� Soil is waterlogged during the growing season.

� Water marks are present on trees or other erect objects. Such marksindicate that water periodically covers the area to the depth shownon the objects.

� Drift lines, which are small piles of debris oriented in the direction ofwater movement through an area, are present. These often occuralong contours and represent the approximate extent of flooding inan area.

� Debris is lodged in trees or piled against other objects.

� Thin layers of sediments are deposited on leaves or other objects.Sometimes these become consolidated with small plant parts toform a discernible crust on the soil surface.

5-4.4 What Are the General Indicators?

Some general situations indicate that an area has a strong probability ofbeing a wetlands. If any of the following situations occur, you should ask thelocal USACE office to determine whether or not the area is a wetlands:

� Area is located in a floodplain or otherwise has low spots in whichwater stands at or above the soil surface during the growing season.Caution: Most wetlands lack both standing water and waterloggedsoils during at least part of the growing season.

� Area has plant communities that commonly occur in areas havingstanding water for part of the growing season (e.g., cypress gumswamps, cordgrass marshes, cattail marshes, bulrush and tulemarshes, and sphagnum bogs).

� Area has soils that are called peats or mucks.

� Area is periodically flooded by tides, even if only by strong,wind-driven, or spring tides.

Most wetlands

lack both

standing water and

waterlogged soils during at

least part of the growing

season.

5-8

68


5-5 What Activities Are Subject to WetlandsPermitting?

Postal Service actions that may require a wetlands permit are more likelyto occur during the construction of roads and/or buildings. As a rule, almostany activity in or near surface waters or wetlands may require a wetlandspermit (Section 404). Some examples are:

� Depositing fill or dredged material.

� Having to fill a site for commercial or recreational developments.

� Constructing revetments, breakwaters, levees, dams, dikes, andweirs.

� Using riprap and road fills.

� Undertaking repair and alteration (R&A) projects and other smallmaintenance activities such as replacing a storage shed or trailer orpaving a parking area.

Exhibit 5-5 illustrates a scenario where a wetlands permit may be required.

USACE also issues wetlands permits under Section 10 of the Rivers andHarbors Act of 1899. This act requires approval before undertaking anywork that is accomplished in or over navigable waters of the United Statesor that affects the course, location, condition, or capacity of such waters.Typical activities requiring Section 10 permits are:

� Constructing piers, wharves, bulkheads, marinas, ramps, float intakestructures, and cable or pipeline crossings.

� Dredging and excavating sites.

5-6 Who Must Obtain a Wetlands Permit?

Any person, firm, or agency planning to work in navigable waters of theUnited States or dump or place dredged or fill material in waters of theUnited States must first obtain a permit from the USACE. Permits, licenses,variances, or similar authorization may also be required by other federal,state, and local statutes.

The operator of a facility is responsible for submitting a wetlands permitapplication to the USACE. DECCs should assist facility managers incontacting their regional USACE office to discuss their project and allexemptions or permits that may apply. Discussing all information beforesubmitting the application allows for more efficient application processing.

Construction is one

activity that could

require a wetlands permit.

Any person, firm,

or agency

planning to work in

navigable waters of the

United States or dump or

place dredged or fill material

in waters of the United

States must first obtain a

permit from the USACE.


69

Exhibit 5-5Potential Scenario That May Necessitate a Wetlands Permit

RoofDrain

RoofDrain

StormSewer Trench Drains

DrainageWell

StormwaterCatch Basin

DetentionPond

RoofDrain

Manhole

StormwaterCatch Inlet

Plant

VMF

Manhole

DelineatedWetlands

Proposed Parking Lot Expansion

StormSewer

Stream

PotentialWetlandsRequirements

PotentialWetlandsRequirements

5-10

70


Depending on the scope of the project (i.e., projects within facility managerauthority and those outside his or her authority), the permit will be obtainedby the facility manager, DECC, FSO, or Administrative Support unit.

5-7 When Must a Wetlands Permit Be Obtained?

Facility managers must submit a wetlands permit application to USACE fordischarges of dredged or fill material that cause the loss or substantialmodification of 1 to 3 acres of wetlands and for discharges associated withNPDES-permitted process wastewater discharges. The application shouldbe submitted at least 3 to 4 months prior to the project start date to ensurethat the permit is processed in time. States may have additionalrequirements.

DECCs or other Postal Service environmental professionals should assistfacility managers to submit the permit application to comply with USACEand/or state requirements.

5-8 What Must Be Done Before Applying for aWetlands Permit?

The basic premise of the Section 404 wetlands program is that nodischarge of dredged or fill material can be permitted if a practicablealternative exists that is less damaging to the aquatic environment or if thenation’s waters would be significantly degraded. In other words, when afacility applies for any type of wetlands permit, the facility manager mustshow that he or she has:

� Issued a written Finding of No Practicable Alternative that states thatno practicable alternative to construction in the wetland exists andthat the proposed action includes all practicable measures tominimize harm to wetlands.

� Minimized potential impacts to wetlands in the project’s plan.

� Provided compensation for any remaining, unavoidable impactsthrough activities to restore or create wetlands.

5-9 What Types of Wetlands Permits AreAvailable?

There are three major permit types for wetlands activities: nationwide,regional or general, and individual. These permits are valid only if theconditions applicable to each permit are met. For more informationabout the various wetlands permits, see the USACE web site at

Facility managers

must submit a

wetlands permit application

to USACE for discharges of

dredged or fill material that

cause the loss or substantial

modification of 1 to 3 acres

of wetlands and for

discharges associated with

NPDES�permitted process

wastewater discharges.

The three types

of wetlands

permits are:

� Nationwide.

� Regional or general.

� Individual.


71

http://www.nab.usace.army.mil/permits/index.html. The three permit typesare described in the following sections.

5-9.1 What Are Nationwide Wetlands Permits?

A nationwide wetlands permit (NWP) is a form of general wetlands permitthat authorizes categories of activities throughout the nation and mayreduce application paperwork. USACE is initiating a programmaticenvironmental impact statement (PEIS) for the entire NWP to be completedby December 2000. The overall purpose of the PEIS is to evaluate the NWPto ensure that the program authorizes only those activities with minimalindividual and cumulative adverse environmental effects on the aquaticenvironment. Further information concerning NWP changes will beprovided as it becomes available. Listed below are several of the NWPscurrently available:

� NWP#3 — covers the repair, rehabilitation, or replacement of astructure or fill that was previously authorized and is currentlyserviceable. The structure or fill must not be significantly changed.

Note: Replacing a structure (e.g., a storage shed) with a newstructure on the same footprint may not cause a permittingproblem; however, relocating an existing or new structure maycause wetlands permitting problems.

� NWP#12 — covers utility lines placed across a waterway. Dischargeof bedding and backfill material is permitted if bottom contours arenot changed.

� NWP#13 — covers bank stabilization projects less than 500 feetlong containing less than an average of 1 cubic yard of material perrunning foot. (The activity must be necessary for erosion protectionand may not exceed the minimum amount needed for erosionprotection. Fill is not to be placed in wetlands areas or in a mannerthat impairs water flow. Materials free of waste metal products andunsightly debris must be used, and the activity must be a single,complete project.)

� NWP#14 — covers minor road crossing fills (temporary orpermanent) that place less than 200 cubic yards of fill below theordinary high water mark. The crossing must be bridged or culvertedso that high water flows are not obstructed. Any fill placed in watersof the United States is limited to no more than 1/3 of an acre.

� NWP#26 — covers the discharge of dredged or fill material intorivers, streams, or lakes located above their headwaters or in closedbasins. This NWP cannot be used when 3 acres or more of watersof the United States, including wetlands, are filled, flooded,excavated, or drained as a result of the project. The USACEdistrict engineer must receive advanced written notificationprior to discharges affecting 1 to 3 acres.

A nationwide

wetlands permit

authorizes categories of

activities throughout the

nation.

Contact the

USACE, the

state or local authority, or

legal counsel for further

information and

clarification and/or for the

latest version of the

applicable NWP.

5-12

72


State wetlands permitting requirements can vary greatly. Although somestates simply adopt USACE standards, others impose stricterrequirements. For example, for NWP#26 some states wish to review anyproject affecting greater than 0.25 acres instead of the USACE standard of1 to 3 acres. Contact the USACE, state or local authority, or legal counselfor further information or clarification and for the latest version of theapplicable NWP.

5-9.2 What Are Regional or General Wetlands Permits?

Regional or general wetlands permits are issued by the USACE districtengineer for a general category of activities when activities are similar innature and cause minimal environmental impact (both individually andcumulatively). Regional permits reduce the duplication of regulatory controlby state and federal agencies.

As an example of a regional wetlands permit, in March 1995 the BaltimoreDistrict of the USACE issued the Pennsylvania State ProgrammaticGeneral Permit for activities in wetlands and waters within theCommonwealth of Pennsylvania. This general permit is administered byUSACE and the Pennsylvania Department of Environmental Protection.Contact the USACE district regulatory office in your area for informationregarding regional wetlands permits.

5-9.3 What Are Individual Wetlands Permits?

An individual wetlands permit authorizes categories of activities specific toan individual site. Individual wetlands permits are issued following a fullpublic interest review of an individual application for a USACE wetlandspermit. A public notice is distributed to all known interested persons. Afterevaluating all comments and information received, the USACE reaches afinal decision about the application.

The permit decision is generally based on the outcome of a public interestbalancing process in which the benefits of the project are balanced againstthe detriments. A wetlands permit is granted unless the proposal is foundto be contrary to the public interest.

Processing time usually takes 60 to 120 days unless a public hearing isrequired or an environmental assessment (EA) or an environmental impactstatement (EIS) must be prepared, in which case the processing time maybe longer.

A regional or

general wet�

lands permit authorizes

similar categories of

activities throughout a

region.

An individual

wetlands permit

authorizes categories of

activities specific to an

individual site.


73

5-9.4 What Is the Process for Obtaining an Individual WetlandsPermit?

After the USACE receives an application for an individual wetlands permit,the following steps occur:

1. Public notice — A public notice describes the permit application,including the proposed activity, its location, and potentialenvironmental impacts. The notice is issued by the USACE within 15days of receiving all permit information and invites comments within aspecified time.

2. Comment period — Comment periods last 15–30 days, dependingon the proposed activity. The application and comments are reviewedby the USACE and other interested federal and state agencies,organizations, and individuals. The USACE determines whether anEIS is necessary.

3. Public hearing — Citizens may request that the USACE conduct apublic hearing; however, public hearings are not routinely held.

4. Permit evaluation — The USACE evaluates the permit applicationbased on the comments received as well as its own conclusions.

5. Final decision — The USACE decides to either issue a permit ordeny the application. The final decision and reasons are available tothe public.

5-10 Who Signs Wetlands Permit Applications andReports?

All wetlands permit applications, reports, or information submitted to theappropriate USACE district office or state agency must be signed andcertified by the facility manager. Any person who knowingly makes anyfalse statement, representation, or certification in any record or otherdocument related to the permit faces severe fines and imprisonment. Legalrequirements may necessitate a PCES manager to sign a permit; afunctional area or VMF manager may not qualify under certain federalregulations. Contact legal counsel for further information and clarification.

5-11 Who Is Responsible for Complying With theWetlands Permit?

The facility manager is responsible for complying with all permit conditionsand requirements. The DECC and FES should be used as resources forassistance with complying with the permit’s conditions.

The Section 404

individual wetlands

permit process has the

folowing steps:

1. Public notice.

2. Comment period.

3. Public hearing.

4. Permit evaluation.

5. Final decision.

5-14

74


5-12 What Happens If a Facility Does Not Comply?

Failing to comply with permit requirements can result in a series ofadministrative, civil, and criminal penalties prescribed in the CWA. Theseinclude large fines, closing the facility, and prison sentences.

5-13 How Is a Permit Renewed?


If the state fails to send a renewal notice, the facility manager is ultimatelyresponsible for maintaining a current wetlands permit. In this situation, afacility manager must submit another NOI form before the permit’sexpiration in order to retain continued coverage. The submittal of the NOIsatisfies the notification requirement covered under the reissued permit.





� Appendix B, which contains BMPs that can be employed to protectwetlands.


� EPA Wetlands Information Hotline: 1-800-832-7828.

� The USACE web page provides guidance on wetlands:http://aec.army.mil, then click on “Search” and enter “wetlands.”


75

Contents

6 What Are the SDWA Requirements? 6-3. . . . . . . . . . . . . . . . . . .

6-1 What Standards Does the SDWA Enforce? 6-3. . . . . . . . . . . . . . . . .

6-2 Who Must Comply With the SDWA? 6-3. . . . . . . . . . . . . . . . . . . . . . .

6-3 What Are the Requirements for a PWS? 6-5. . . . . . . . . . . . . . . . . . .

6-3.1 What Are Maximum Contaminant Requirements? 6-5. .

6-3.2 Why Is Testing Lead in Drinking Water Important? 6-6. .

6-3.3 What Are a PWS’s Sampling and MonitoringRequirements? 6-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6-3.4 What Are a PWS’s Reporting and RecordkeepingRequirements? 6-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


Exhibit

Exhibit 6-2Water Sources: Self-Supply Systems (Wells, Springs, Cisterns)SDWA Requirements Decision Tree 6-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


77

6 What Are the SDWA

Requirements?

The Safe Drinking Water Act serves as the authority for protecting thenation’s drinking water. The SDWA requires water suppliers to meetdrinking water standards to ensure safe and reliable drinking water forpublic consumption. This chapter describes the general requirements ofthe SDWA.

6-1 What Standards Does the SDWA Enforce?

Under the SWDA, EPA has established national primary drinking waterstandards (primary standards), national secondary drinking waterstandards (secondary standards), bottled water standards, and theSole-Source Aquifer (SSA) Protection Program. The GroundwaterProtection Program, which includes SSA and watershed protection, isaddressed in Chapter 7.

Primary standards are legally enforceable standards applicable to publicwater systems. They consist of maximum contaminant levels (MCLs) thatlimit the levels of specific contaminants that can adversely affect publichealth and that are known to, or are anticipated to, occur in public watersystems. Secondary standards are nonenforceable guidelines regulatingcontaminants that may cause users to perceive water to have adverseeffects.

6-2 Who Must Comply With the SDWA?

The SDWA was primarily enacted to address water quality issues forpublic water suppliers. The term public water supply (PWS) is central todelineating the scope of many SDWA requirements and thus compliancewith these requirements. In rare instances, a Postal Service facility isconsidered a PWS. A facility can follow the decision process shown inExhibit 6-2 to determine if it is considered a PWS. A Postal Service facilityis considered a PWS and must comply with the SDWA requirements if thefacility:

A facility that

conducts the

following activities may be

subject to SDWA

requirements:

� Receives drinking water

from a private on�site

well.

� Treats water received

from a PWS.

DECCs should

assist facility

managers to:

� Determine if their facilities

are subject to drinking

water requirements.

� Confirm that monitoring

records are being

maintained.

6-4

78


Recordkeeping :� Public water supply

registration.

� Sampling results.

Laws andRegulations :� SDWA — Primary

and secondarydrinking waterregulations.

� OSHA standards.

Benefits :� Ensures safe

drinking watersupply.

� Avoids fines andpenalities.

Issues :� May require certified

operators.

� May be less reliableand thus presenthigher health andsafety risks.

� May havemaintenance costsassociated withmaintaining theself-supply system.These costs mayinclude monthlytesting, record-keeping, and othercosts.

Start

Do youhave more than 25

employees or 15 or moreservice connections

Are youconnected to a

public watersupply

Yes

No

Provide DECCwith

informationregardingpractices

Yes

Yes

No

Contact safety officerand DECC to develop

plan for registration andcompliance

Exhibit 6-2Water Sources: Self-Supply Systems (Wells, Springs, Cisterns)SDWA Requirements Decision Tree

See Exhibit2-1 in HBKAS-554-A

You are classifiedas an on-site publicwater supply andmust meet SDWA

requirements

You are not classifiedas a public water

supply; however, youmay have to meetlocal requirements

Contact DECCfor guidance

on localrequirements

Comply withmonitoring

requirements(see Chapter 6)

No

Water Issue :

Self-supply systems may be regulated under SDWA and/or federal, state,and local agencies.

Goal:Comply with regulations.

Implementation:

Is your watersupply registered

or permitted

Is itpossible to

connect to a publicwater supply

system

No

YesContact your

districtAdministrativeSupport unit to

pursue connection


79

� Receives drinking water from a private on-site well that has at least15 service connections or that regularly serves 25 individuals (thisnumber includes both employees and customers).

� Treats the water received from a PWS (e.g., with filtration orchlorination).

When a Postal Service facility is designated as a PWS, it is required to meetprimary and secondary standards (i.e., MCLs) and other requirements. TheSDWA requirements described in section 6-3 apply only to a limitednumber of Postal Service facilities that are considered PWSs. Furtherinformation regarding SDWA and its impacts on postal operations can befound in Handbook AS-554-A.

Note: Water softeners and in-line filters installed before the taps are notconsidered treatment systems. Because of the frequent and routinemaintenance involved with operating these filters, the Postal Service doesnot recommend their use unless it is necessary to benefit employees andcustomers.

6-3 What Are the Requirements for a PWS?

The major requirements for a PWS consist of:

� Ensuring that MCLs are not exceeded.

� Ensuring that lead levels are not exceeded.

� Sampling and monitoring the drinking water supply.

� Complying with the reporting and recordkeeping requirements.

Facilities designated as a PWS should use Exhibit 6-2 to determine actionsto take to maintain a safe and reliable source of drinking water.

6-3.1 What Are Maximum Contaminant Requirements?

A Postal Service facility that meets the conditions that make it a PWSmust ensure that MCLs are not exceeded for any contaminant on theNational Drinking Water Standards list. Information about MCLscan be found at http://www.epa.gov/ogwdw/wot/appa.html andhttp://www.epa.gov/safewater/mcl.html. If an MCL is exceeded, the facilitymust take immediate steps to prevent future violations. Furthermore,federal law requires the PWS to promptly notify all water users if the waterbecomes contaminated by something that can cause immediate illness.Additional actions, such as providing alternative drinking water supplies,may be required to prevent serious risks to public health. Drinking watersuppliers are required to inform customers about violations of lessimmediate concern in the first water bill, in their annual report, or by mailwithin 1 year.

Water softeners

and in�line filters

installed before the taps

are not considered

treatment systems.

Specific SDWA

requirements can

be found at the

EPA Office of Ground

Water and Drinking

Water's web site at

http://www.epa.gov/ogwdw.

6-6

80


6-3.2 Why Is Testing Lead in Drinking Water Important?

Lead poses a significant public health threat because it accumulates in thebody and can cause brain, red blood cell, and kidney damage. The EPAestimates that approximately 20 percent of lead found in humans isattributable to lead in drinking water. In most cases, drinking water frommunicipal distribution systems contains undetectable levels of lead.However, if the water sits in plumbing systems, lead can dissolve into thewater, primarily from lead-based solder, particularly when the water is hot.

The SDWA includes provisions that reduce lead contamination in drinkingwater. In 1986, the SDWA banned the use of lead solder or flux andlead-bearing pipes and fittings. The Postal Service requires that all watercoolers be tested for lead and removed or repaired if the test shows thatthe lead levels exceed the 20 parts per billion standard.

EPA developed guidance to provide maximum protection of human healthby reducing lead at consumers’ taps. To accomplish this goal, the EPArequires a PWS to lower lead concentrations to acceptable levels byimplementing various treatment techniques. When drinking water isprovided by a municipality or other outside entity, the Postal Servicevoluntarily follows EPA recommendations for reducing lead exposure at thetap.

To ensure safe drinking water for their employees, postal facilities meetingcriteria that make them PWSs must ensure that their potable water (i.e.,drinking water) meets SDWA requirements for lead. This includesevaluating the facility’s water system. This evaluation should include areview of the drinking water distribution system piping, corrosion controlefforts, and the age and types of water housing the system supplies. Basedon this information, water samples must be collected at points throughoutthe distribution system that are potentially vulnerable to leadcontamination, including regularly used restroom and cafeteria water taps.Certain treatment techniques are required if high levels of lead are found.

Further information regarding SDWA impacts and Postal Servicerequirements may be found in MMO-28-89, The 1986 Amendments to theSafe Drinking Water Act, and MMO 30-90, Water Cooler Lead LevelTesting. These documents are available through the MaintenanceTechnical Support Center in Norman, Oklahoma, web site athttp://www.mtsc.usps.gov, and the Policies and Procedures web site athttp://blue.usps.gov/cpim.

Postal facilities

meeting criteria

that make them PWSs must

ensure that their potable

water meets SDWA

requirements for lead.


81

6-3.3 What Are a PWS's Sampling and Monitoring Requirements?

A facility is required to conduct quarterly sampling and monitoring of watersources. Sampling and monitoring requirements and procedures arespecified by the SDWA. These requirements apply to the sampling andmonitoring of drinking water sources, tap water, and water coolers.Samples should be analyzed in a state-certified laboratory. After 1 year ofmonitoring and sampling, the state or EPA may reduce a facility’smonitoring and sampling requirements to once a year if the results are“reliably and consistently” below the MCLs.

State PWS requirements may vary regarding the contaminants to monitor,MCL levels, testing frequency, and conditions for exemptions andvariations. Since monitoring requirements are too voluminous to discusshere, refer to the EPA Office of Ground Water and Drinking Water’s web siteat http://www.epa.gov/ogwdw or state-specific requirements for moreinformation.

6-3.4 What Are a PWS's Reporting and RecordkeepingRequirements?

Records of the various sampling and monitoring results must bemaintained for specific periods of time. For example, records ofbacteriology analyses must be kept for at least 5 years and chemicalanalyses at least 10 years. Refer to 40 CFR 141.33 for specificrequirements. In addition, some of the sampling and monitoring resultsmust be reported to the states or EPA regional office.

All violations of MCLs or other standards must be reported to the state andall affected drinking water users. A reportable violation is defined by EPAor state guidelines. If quarterly averaging shows contaminant levels belowthe MCL or if confirmation sampling results following “spikes” or anomaliesare below MCLs, then these reporting requirements do not apply.

Postal facilities meeting the criteria that make them PWSs must developannual consumer confidence reports. The report must be provided to allcustomers and users annually and must include:

� Information on the source of drinking water.

� Brief definitions of terms.

� The MCL, the MCL goal, and the actual level of any regulatedcontaminant found through sampling and monitoring.

� Information on health effects if an MCL was violated.

� Information on levels of unregulated contaminants.

� Any violations of the SDWA requirements.

A single exceedance

of an MCL is not

necessarily a reportable

violation.

Postal facilities

that are not

PWSs and that are

connected to municipal

water systems receive an

annual consumer

confidence report from

their municipality.

6-8

82


6-4 Where Can Further Information and AssistanceBe Obtained?

Additional information about SDWA requirements may be obtained throughthe following resources:


� SDWA hotline: 800-426-4791.

� SDWA, Title XIV — Safety of Public Water Systems, Public Law93–523.

� 40 CFR 141 — National Primary Drinking Water Regulations.

� 40 CFR 143 — National Secondary Drinking Water Regulations.

� State and local drinking water laws and regulations.

� Handbook RE-6, Facilities Environmental Guide.

� Handbook MS-1, Operation and Maintenance of Real Property.


83

Contents

7 What Are the Groundwater ProtectionRequirements? 7-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-1 What Is Groundwater? 7-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-2 How Can Groundwater Become Polluted? 7-3. . . . . . . . . . . . . . . . . .

7-3 What Regulations Protect Groundwater? 7-4. . . . . . . . . . . . . . . . . . .

7-4 What Are the Major Groundwater Protection ProgramsUnder the SDWA? 7-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-4.1 What Are the Source Water Assessment andWellhead Protection Programs? 7-5. . . . . . . . . . . . . . . . . .

7-4.2 What Is the Sole-Source Aquifer ProtectionProgram? 7-5. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5 What Is the Underground Injection Control Program? 7-7. . . . . . . .

7-5.1 What Activities Are Subject to UIC ProgramPermitting? 7-7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5.2 Who Is Responsible for Obtaining a UIC ProgramPermit? 7-10. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5.3 When Must a UIC Program Permit Be Obtained? 7-10. . .

7-5.4 What Are the UIC Program Requirements? 7-10. . . . . . . .

7-5.5 What Are the UIC Program ReportingRequirements? 7-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5.6 Who Signs UIC Program Permit Applicationsand Reports? 7-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5.7 Who Is Responsible for Complying With the UICProgram Permit? 7-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-5.8 What Happens If a Facility Does Not Comply? 7-11. . . . .

7-5.9 How Are UIC Program Permits Renewed? 7-12. . . . . . . .

7-6 Where Can Further Information and Assistance BeObtained? 7-12. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7-2

84


Exhibits

Exhibit 7-4.2Activities That May Cause SSA Groundwater Requirementsto Apply 7-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit 7-5.1VMF and Plant Activities That May Cause UIC GroundwaterRequirements to Apply 7-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


85

7 What Are the Groundwater

Protection Requirements?

Groundwater is an important resource; it replenishes our streams andrivers and is a source of water for irrigation, industrial, and drinking waterfor many communities. EPA estimates that 50 percent of United Statescommunities rely on groundwater for part or all of their drinking watersupplies. This chapter describes the various programs under the SDWAthat are designed to protect groundwater.

7-1 What Is Groundwater?

Groundwater is the portion of rain and snow that soaks through the earth’ssurface and moves down through the water table. Water percolates intoaquifers where it fills the pores of rock formations. Groundwater stored inan aquifer can move laterally and vertically in response to gravity and/orto pressure differences. Water can be withdrawn from aquifers throughwells and is often used for drinking water, heating and cooling systems,and industry and agriculture.

7-2 How Can Groundwater Become Polluted?

Groundwater contamination can begin at the surface, above or below thewater table. Sources of contamination include septic tanks, surfaceimpoundments (e.g., lagoons), agricultural activities, landfills,underground storage tanks, abandoned wells, accidental or illegaldumping activities, and highway deicing. Common pollutants includesolvents, pesticides, petroleum products, and waste leachate. Soilpercolation rate, site surface conditions, and groundwater flow rate anddirection, along with contaminants, soil type, and rock and aquifercharacteristics, affect contaminant plume migration and dispersion. Insome cases, groundwater pollution can last a long time and can be difficultand costly to remedy.

Postal Service

activities that could

potentially affect

groundwater are:

� Landscape work and

fertilizer and pesticide

application.

� Vehicle maintenance.

� Septic system operation.

� Painting operations.

7-4

86


7-3 What Regulations Protect Groundwater?

Groundwater protection is mainly regulated under the SDWA. However,it is also protected to varying degrees by several federal laws including:

� Resource Conservation and Recovery Act.

� Comprehensive Environmental Response, Compensation, andLiability Act.

� Federal Insecticide, Fungicide, and Rodenticide Act.

� Toxic Substances Control Act.

� Clean Water Act.

These laws focus on strategies for controlling potential sources ofgroundwater contamination and remediation strategies. Except for theCWA, these regulations do not discuss permit requirements.

States, in cooperation with local governments, are primarily responsiblefor implementing and enforcing the programs. Under the SDWA, statesare required to complete Source Water Assessment Programs (SWAPs)for every public water supplier. States are also encouraged to adoptcomprehensive groundwater protection plans that include protectiongoals and priorities, resource and risk assessments, resource and useclassifications, standards, management activities, and program funding.

7-4 What Are the Major Groundwater ProtectionPrograms Under the SDWA?

The four Groundwater Protection Programs under the SDWA that directlyaffect Postal Service facility operations and activities are SWAP, WellheadProtection, SSA Protection, and UIC. Currently, the UIC Program is themore complex of the Groundwater Protection Programs, primarily due tothe permitting requirements used for its implementation. Consequently,section 7-5 centers on the UIC permitting process and its potential effectson postal operations and activities.

DECCs should assist facility managers with understanding therequirements associated with these groundwater programs. Facilitymanagers, with assistance from the DECC, should contact theappropriate EPA regional office, state agency, or local agency for specificrequirements.

States, in

cooperation with

local governments, are

primarily responsible for

implementing and enforcing

Groundwater Protection

Programs.

The four major

Groundwater

Protection Programs are:

� SWAP.

� Wellhead Protection.

� SSA Protection.

� UIC.

DECCs should

assist facility

managers with under�

standing the requirements

associated with groundwater

programs.


87

7-4.1 What Are the Source Water Assessment and WellheadProtection Programs?

The SDWA Amendments of 1996 require states to develop andimplement SWAPs to analyze existing and potential threats to the qualityof the public drinking water throughout the state. SWAPs requiredelineation of wellhead protection areas, identification of actual andpotential contaminant sources, and execution of protection strategies.This information is used to develop effective management strategies.

A wellhead protection area is an area that encompasses all or part of thesurface and subsurface zone surrounding a well or well field supplying apublic water system. Wellhead protection requires coordination by bothstate and local authorities to delineate the area, identify actual andpotential sources of contamination, and execute protection strategies.States may require the Postal Service, in SWAP areas that couldpotentially affect wellhead protection areas, to develop contingency plansfor spills or incidents. State regulators will notify a Postal Service facilitymanager of all requirements necessary to protect source water andwellhead areas.

7-4.2 What Is the Sole�Source Aquifer Protection Program?

EPA defines an SSA as one that supplies at least 50 percent of thedrinking water to a local community or area. Another characteristic is thatthese areas have no alternative drinking water source that couldphysically, legally, and economically supply all those who depend on theaquifer for drinking water. Federally designated SSAs can be found at website http://www.epa.gov/ogwdw/swp/sumssa.html.

All projects planned within the SSA that receive federal financialassistance must be reviewed by EPA to ensure that the project will notadversely affect the aquifer. State and local governments may alsodevelop separate requirements linked to the SSA, such as specialNPDES permit requirements and SSA protection plans.

The Postal Service’s SSA responsibilities are specific to the state, waterdistrict, or region in which a facility lies and also to the operation or activityin which the facility is engaged or wishes to engage. Exhibit 7-4.2illustrates possible activities at a typical VMF and plant that may causeSSA groundwater requirements to apply.

Federally

designated

SSAs can be

found at web site

http://www.epa.gov/

ogwdw/swp/sumssa.html.

7-6

88


Exhibit 7-4.2Activities That May Cause SSA Groundwater Requirements to Apply

Key:

Parking

Cafeteria

Backflow Prevention

Sink

Sink

Boiler

CoolingTower

UtilitySink

Drinking

Shower,

BatteryRoom

Meter

Meter

Vehicle MaintenanceArea

Vehicle WashArea

Restroom

Air GapsVacuum Breakers

x

x

x

Service Line

FeedWaterTank

Plant

VMF

DeepWell

Water Fountain


Sink, Toilet

IrrigationSystem

FireHydrant

Groundwater(SSA)Requirements

Aquifer

Chiller

IrrigationSystem

FireHydrant

Stream

WaterMain


89

7-5 What Is the Underground Injection ControlProgram?

The UIC Program was established under SDWA to regulate the use ofwells that pump fluids into the ground. The UIC Program requires stateand local governments to regulate injection wells to prevent them fromcontaminating underground drinking water resources. In states withoutapproved UIC Programs, the appropriate EPA regional office managesthe UIC Program.

The terms “well” and “injection” are fundamental to understanding UIC. Awell is a bored, drilled, or driven shaft, or dug hole, whose depth is greaterthan the largest surface dimension and whose purpose is to reachunderground water supplies or oil, or to store or bury fluids below ground.Injection is the placement of fluids, by force or gravity-draining, in that well.

7-5.1 What Activities Are Subject to UIC Program Permitting?

EPA and state programs impose minimum UIC standards for the location,construction, operation, monitoring, and closure of underground sourcesof drinking water (USDWs). This ensures that UICs do not contaminateUSDWs.

EPA has defined five classes of UIC wells according to the type of wastethey inject and where the waste is injected:

� Class I wells are technologically sophisticated wells that inject largevolumes of hazardous and nonhazardous wastes into deep,isolated rock formations that are separated from the lowermostUSDW by many layers of impermeable clay and rock.

� Class II wells inject fluids associated with oil and natural gasproduction. Most of the injected fluid is brine that is produced whenoil and gas are extracted from the earth.

� Class III wells inject superhot steam, water, or other fluids intomineral formations, which are then pumped to the surface andextracted. Generally, the fluid is treated and reinjected into thesame formation. More than 50 percent of the salt and 80 percent ofthe uranium extracted in the United States are produced this way.

� Class IV wells inject hazardous or radioactive wastes into or abovea USDW. These wells are banned under the UIC Program becausethey directly threaten the quality of a USDW.

� Class V wells use injection practices that are not included in theother classes. Some Class V wells can be technologicallyadvanced wastewater disposal systems, but most are “low-techholes in the ground.” They depend on gravity to drain or injectliquid waste into the ground above or into a USDW. Their simple

UIC Program

the program

under the SDWA that

regulates the use of wells

that pump fluids into the

ground.

USDW an

aquifer currently

being used as a source of

drinking water or that is

capable of supplying a

public water system.

7-8

90


construction provides little or no protection against possiblegroundwater contamination, so it is important to control their use.

All Class I, II, III, and V wells can be subject to permitting. The specificclass subject to permitting depends on the state. UIC wells, in general, arenot commonly used by the Postal Service. However, the Postal Servicedoes use Class V wells, and only uses the following kinds:

� Septic systems that receive vehicle or equipment wastes.

� Recharge wells used to replenish the water in an aquifer (e.g., theEdwards Aquifer in Texas).

� Drainage wells used to drain surface fluid, primarily stormwaterrunoff, into a subsurface formation (e.g., french drains).

� Air-conditioning return flow wells used to return to the supplyaquifer the water used for heating or cooling a heat pump.

� Septic systems that are used solely for the disposal of sanitarywaste and that serve more than 20 persons per day.

Exhibit 7-5.1 illustrates possible activities at a typical VMF and plant thatmay cause UIC groundwater requirements to apply.

The following aquifers and wells are not covered by the UIC Program:

� Aquifers that are identified as “exempted aquifers” qualify as aUSDW to be protected and have no real potential to be used asdrinking water sources.

� Aquifers that do not fit the definition of a USDW.

� A drainage well or infiltration basin that has wider surfacedimensions than depth.

� Individual or single-family residential waste disposal systems suchas domestic cesspools or septic systems.

� Nonresidential cesspools, septic systems, or similar waste disposalsystems that are used solely for the disposal of sanitary waste andthat do not serve more than 20 persons per day.

The above list is not exhaustive. For a complete listing of all theexceptions, consult regulation 40 CFR 144.

The greatest UIC Program concern to the Postal Service is postal facilitieswith septic systems. Although some Postal Service large-capacity septicsystems do not fit the technical definition of a well, they are considered tobe injection wells because they force or allow waste to be introduced intothe subsurface. Thus, septic systems may require a construction andoperation permit from the local health department. Additional operatingrequirements exist for septic tank systems located in ecologicallysensitive areas.

Of the wells

regulated in the

UIC Program, the Postal

Service only uses the

following kinds of Class V

wells:

� Septic systems.

� Recharge wells.

� Drainage wells.

� Return flow wells.


91

Exhibit 7-5.1VMF and Plant Activities That May Cause UIC Groundwater Requirements to Apply

Parking

FloorDrain

RoofDrain

StormSewer Trench Drains

DrainageWell

Stormwater Inlet

DetentionPond

RoofDrain

Manhole Manhole

Inlet

Plant

VMF

or Catch Basin

StormSewer

Stream

Groundwater (UIC)Requirements

7-10

92


Note: EPA has recently issued proposed regulations for thecomprehensive management of Class V wells. The proposed Class Vrule, 40 CFR 144, Subpart G, Requirements for Owners and Operatorsof Class V Injection Wells, focuses on high-risk Class V injection wells insource water protection areas that are known to pose the greatest threatto a USDW. These are:

� Motor vehicle waste disposal wells.

� Industrial waste disposal wells.

� Large-capacity cesspools.

The proposed Class V regulation would affect the owners and operatorsof these wells in source water protection areas delineated for communitywater systems. As with all other environmental-related legislation, thePostal Service will issue guidance once the regulations are codified.

7-5.2 Who Is Responsible for Obtaining a UIC Program Permit?

Under Postal Service policy, facility managers must ensure that operatorshave obtained all required state and local UIC permits. In all cases,DECCs are available to coordinate obtaining permits with the facilitymanager, Administrative Support unit, FSO, and/or MFO, as necessaryand appropriate.

7-5.3 When Must a UIC Program Permit Be Obtained?

Postal Service facility managers with an injection well that falls into theClass V category must contact the appropriate state agency or EPAregional office to determine if these wells are regulated. Permits must beobtained prior to beginning any activity (including construction) related toa new injection well.

7-5.4 What Are the UIC Program Requirements?

Postal Service facility managers may not construct, operate, maintain,convert, plug, or abandon any injection well or conduct any activity thatallows the movement of fluid containing any contaminant into a USDW.Because of this, permits are often required to legally operate someinjection wells. In such instances, the permit applicant must show that thewell and all activities involving the well will not affect a USDW.

If a drinking water supply is threatened, the owner or operator of the wellmust stop the injection practice, must close the drainage system, and mayface fines and expensive groundwater cleanup costs.

Proposed

legislation (40

CFR 144) may further affect

Postal Service facilities if

they have:

� Motor vehicle waste

disposal wells.

� Industrial waste disposal

wells.

� Large�capacity

cesspools.


93

7-5.5 What Are the UIC Program Reporting Requirements?

Postal facility managers with UIC wells must notify state and/or EPAauthorities if an event occurs that may endanger human health or theenvironment. Reports must include either of the following:

� All monitoring results or other information that indicates acontaminant may endanger a USDW.

� All noncompliance or malfunction of the injection system that maycause fluid migration into or between a USDW.

This information must be provided orally within 24 hours from the time thatthe facility becomes aware of the circumstances. In addition, a writtenreport must be provided within 5 days. The written report must includeinformation regarding the period of noncompliance, including exact datesand times; if the noncompliance has not been corrected, the anticipatedlength of time it is expected to continue; and steps taken or planned toreduce, eliminate, and prevent recurrence of the noncompliance. Statesmay have additional reporting requirements.

7-5.6 Who Signs UIC Program Permit Applications andReports?

All applications, reports, or information submitted to the appropriate stateagency must be signed and certified by the facility manager. Any personwho knowingly makes any false statement, representation, or certificationin any record or other document related to the permit faces severemonetary fines and imprisonment. Legal requirements may require aPCES manager to sign a permit; a functional area or VMF manager maynot be qualified under certain federal regulations. Legal counsel canprovide further information and clarification.

7-5.7 Who Is Responsible for Complying With the UIC ProgramPermit?

The facility manager is responsible for ensuring that the facility complieswith all UIC program permit conditions and requirements. DECCs shouldprovide assistance if necessary.

7-5.8 What Happens If a Facility Does Not Comply?

Failing to comply with permit requirements can result in a series ofadministrative, civil, and criminal penalties prescribed in the SDWA.These penalties include large fines, closing the facility, and prisonsentences.

DECCs should

develop a list of

facilities with UIC and SSA

wells and assist facility

managers to:

� Demonstrate the need for

a UIC or SSA well.

� Close all unessential UIC

or SSA wells.

� Monitor state UIC

Programs.

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7-5.9 How Are UIC Program Permits Renewed?

Information concerning the procedures for permit renewal is typicallyfound on the permit itself. The state or local regulatory agency will notifythe permit holder (e.g., facility manager) prior to the permit’s expirationdate. The permit holder then submits the required information and theassociated permit fee. The permit is automatically renewed whenpayment is received.

If the state fails to send a renewal notice, the facility manager is ultimatelyresponsible for maintaining a current UIC program permit. In this situation,a facility manager must submit another NOI form before the permit’sexpiration in order to retain continued coverage. The submittal of the NOIsatisfies the notification requirement covered under the reissued permit.






� EPA Office of Groundwater and Drinking Water’s web site athttp://www.epa.gov/ogwdw/.

� 40 CFR 147, State UIC Programs.

Handbook AS-554-D, Water Permitting Guide — March 2000 A-1

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Contents

A What Awareness Training and Outreach ProgramsAre Available? A-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

A-1 Awareness Training A-3. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

A-1.1 Training Courses for Postal Employees A-3. . . . . . . . . . .

A-1.2 Awareness Communication A-4. . . . . . . . . . . . . . . . . . . . .

A-2 Outreach A-4. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

A-2.1 Communicating With Our Audiences A-4. . . . . . . . . . . . . .

A-2.2 Educating Our Audiences A-5. . . . . . . . . . . . . . . . . . . . . . .

A-2.3 Participating in Community Activities A-5. . . . . . . . . . . . . .

A-2.4 Participating in the Chesapeake Bay WatershedOutreach Effort A-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit

A Helping Hand: Postal Service Efforts to Restore theChesapeake Bay A-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


97

A What Awareness Training andOutreach Programs AreAvailable?

A-1 Awareness Training

Water is a critical environmental and economic resource. Water permittingis the process whereby activities affecting water quality are identified andaddressed by the appropriate permit or regulatory requirements. Waterpermitting is required by federal, state, and local governments.

A-1.1 Training Courses for Postal Employees

A number of training courses are offered by the Postal Service’s NCED toaddress water permitting issues. Note that the CWA course is the onlyPostal Service-offered course that provides an in-depth coverage of waterpermitting issues. The remaining courses touch on general waterpermitting requirements. For further information on these and othercourses, visit the NCED intranet web site at http://nced.usps.gov. Eachtraining course listed may be Voice of the Employee-approved at thediscretion of each district’s manager:

� Clean Water Act, EHS04-01, 20 hours — This course coversregulatory requirements and additional technical informationnecessary to effectively manage efforts to comply with CWArequirements in Postal Service-owned or -leased facilities.

� Basic Environmental Laws and Regulations, EHS01-01,20 hours — This course is an introduction to federal environmentallaws and regulatory requirements necessary to effectively manageenvironmental concerns currently facing the Postal Service.

� Postmaster/Site Manager Environmental Orientation, EHS02-01,20 hours — This course is an introduction to regulatoryrequirements and program overview information necessary toeffectively provide management oversight of environmentalconcerns currently facing postal facilities.

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98


� Maintenance Environmental Awareness, EHS02-03, 8 hours — Thiscourse is an introduction to environmental laws and regulatoryrequirements as they apply to Postal Service maintenanceemployees and operations.

Training may also be provided by an outside contractor at the local level ifit is shown to be cost-efficient and technically adequate. Water permitting“awareness” training may be provided via stand-up talks and documentedon the standard safety talk forum.

A-1.2 Awareness Communication

Postal employees, suppliers, and vendors should be aware of theconsequences of not complying with the water permitting regulations. Thefollowing is a list of suggestions for how DECCs can communicate therequirements of the Postal Service’s water permitting program to suppliers,vendors, and employees:

� Provide a standard notification letter, “awareness” video, and/orstand-up talk to lessor or property managers, tenants and/orlessees, and Postal Service employees.

� Provide awareness signs and labels in a uniform, consistentmethod. For example, the Pacific Area has established andimplemented a storm drain stenciling program designed to minimizeillegal dumping, educate the public, improve operations, and reducemaintenance expenses.

� Develop articles for Postal Service periodicals and the PostalBulletin and create multilevel briefings, Postal Satellite TrainingNetwork (PSTN) broadcasts, brochures, and postal web pages.

� Provide and coordinate corporate training through the NCED.

A-2 Outreach

Environmental outreach consists of three major elements: communication,education, and participation. The primary audiences are the public,stakeholders, and regulators.

A-2.1 Communicating With Our Audiences

The Postal Service has taken major steps to protect the environment in thecourse of our daily operations. It is important that the community served bya postal facility is aware of these efforts in order to promote a positive PostalService image. Effective communication can be achieved in a number ofways such as placing posters around the facility, placing ads in localnewspapers, and participating in radio programs.


99

Postal Service employees should also be made aware of the environmentalgoals and efforts of the Postal Service. Employees need to know that theorganization for which they work is contributing to the common good andhow their individual actions can help enhance this contribution.

Maintaining an open and positive relationship with regulators facilitateseffective environmental management. Regulators should be made awareof all proactive environmental programs at postal facilities and ofanticipated problems. DECCs should invite representatives on facility toursand to information sessions whenever feasible.

A-2.2 Educating Our Audiences

Educational efforts are tied closely with communication. In addition toproviding information about Postal Service environmental activities,DECCs should assist facility managers to educate the public about variousenvironmental issues. Pamphlets and newsletters available to the public atpost offices may be used to address environmental issues that arepertinent to local areas.

It is important that regulators and legislators understand how postalfacilities operate. Some effective educational tools to ensure thisunderstanding are visiting the site and distributing informational packages.A better understanding of postal operations can enable regulators andlegislatures to develop requirements that are more realistic and perhapsmore effective.

A-2.3 Participating in Community Activities

Direct participation in a community is an effective outreach method. Postalfacilities should sponsor and/or participate in environmentally relatedevents, such as Earth Day, whenever feasible. Participation can vary butmay include setting up a booth at a local fair or opening a facility parkinglot for vendors or performers to use. Postal employees should beencouraged to volunteer their time.

The Postal Service should also actively participate in the regulatory andlegislative processes at the state and federal levels. This includes attendingregulatory hearings and rule-amending sessions and providing commentson proposed rules. Participation at this level shows that the Postal Serviceis an environmentally concerned and informed organization.

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A-2.4 Participating in the Chesapeake Bay Watershed OutreachEffort

The following is a discussion of a Postal Service outreach effort in theChesapeake Bay watershed. The goal of the Postal Service’s outreacheffort is to educate both employees and the public about the benefits ofincorporating beneficial landscaping techniques on postal and privateproperty. The three outreach efforts included:

� Developing a poster, in a partnership with the Alliance for theChesapeake Bay, to illustrate the benefits of natural landscaping, or“BayScaping.”

� Designing a brochure geared toward Postal Service employees thatincludes specific information on BayScaping practices.

� Creating a beneficial grounds management plan (GMP) thatprovides guidance to postal facilities on incorporating beneficialgrounds management practices.

This outreach effort has shown both postal employees and customers ourcommitment to being an environmental leader. As one of the largestbusinesses within the watershed, the Postal Service can have a majorimpact on the restoration and protection of the Chesapeake Bay. ThePostal Service continues to look for opportunities to assist with therestoration and protection of the Bay as well as inform the general publicas to how they can protect this vital natural resource.

Following is an example of the Postal Service’s Chesapeake Baycommunication and outreach efforts. This article was published inCoastlines, Issue 8.3.

A Helping Hand: Postal Service Efforts to Restore theChesapeake Bay

If you live within the Chesapeake Bay watershed, you may notice somechanges the next time you visit your local post office. Look closely, you’llsee newly planted blueberry bushes, holly trees, or rhododendrons. Thesenew plantings are part of the United States Postal Service’s efforts topromote BayScaping. BayScaping is environmentally sound landscapingthat preserves water quality and creates wildlife habitat, while saving timeand energy by reducing maintenance and water usage.

The Postal Service BayScaping projects are part of greater efforts torestore and protect the Chesapeake Bay. In 1996, the Postal Servicesigned a memorandum of understanding (MOU) with EPA’s ChesapeakeBay Program to enhance coordination between the Postal Service districtslocated within the watershed and the EPA in their efforts to protect theChesapeake Bay and its tributaries.


101

The Chesapeake Bay Program, established in 1983, is a voluntarypartnership among Virginia, Maryland, Pennsylvania, the District ofColumbia, the Chesapeake Bay Commission (a tri-state legislative body),the federal government (represented by EPA), and participating citizengroups. The mission of the program is to implement ecosystemmanagement and restoration of the Chesapeake Bay through abatementand prevention of pollution, preservation and restoration of living resourcesand habitat, enhancement of public access to the bay and its tributaries,public education, and overall health of the bay. Instead of being a regulatoryprogram, it encourages and coordinates voluntary participation.

The Chesapeake Bay drains freshwater from a 64,000-square-milewatershed that includes portions of seven states. Within the borders of theChesapeake Bay watershed, the Postal Service operates more than 2,000facilities, including processing and distribution centers, bulk mail facilities,vehicle maintenance facilities, air mail facilities, and post offices. Theyrange in size from less than 1 acre to 30 acres and are located on bothurban and rural sites.

As part of their agreement with EPA, the Postal Service developed the firstbiennial Chesapeake Bay Program Action Plan in October 1997. The planformalizes the actions needed to fulfill the agreements in the MOU, as wellas the steps necessary for the Postal Service to support the protection andrestoration of the Chesapeake Bay. The five goals of the action plan are:

� Assist the EPA in ecosystem protection that can be directlyinfluenced by action of the Postal Service.

� Partner with other federal agencies to champion the concept ofenvironmental stewardship to preserve and protect the naturalresources of the Chesapeake Bay.

� Work with municipalities on improving coordination and involvementwith bay protection and restoration efforts at the state and locallevels.

� Assist the EPA with efforts to increase public awareness of theChesapeake Bay Program and bay restoration at local postalfacilities.

� Develop an action plan for setting goals and implementing thesecommitments.

One of the first steps the Postal Service took toward accomplishing andtracking the MOU goals was to inventory all postal facilities located in thewatershed. This information is being entered into a geographic informationsystem (GIS) and will be overlaid with natural resource data. Because thewatershed crosses state, as well as Postal Service district Areas [sic], itwas important for the Postal Service to determine which facilities fall withinthe watershed’s boundaries. The Postal Service intends to use the GIS

A-8

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data when making decisions or establishing programs regarding projectssituated within the Chesapeake Bay watershed.

In another effort, the Postal Service is helping the Chesapeake BayProgram reach its goal of reducing the amount of nitrogen and phosphorusentering the bay by 40 percent by developing a beneficial GMP.Traditionally, grounds management plans emphasize landscapingtechniques—the GMP, however, is unique in that it is holistic, incorporatingBayScapes, integrated pest management, natural resource conservation,stormwater management, and exterior maintenance. The GMP alsofocuses on the grounds management activities of both postal employeesand contractors to ensure they are consistent with the overall goals andobjectives of the Postal Service and the Chesapeake Bay Program. TheGMP is based on existing Postal Service environmental policies, and newprograms and procedures will be developed where appropriate.

Handbook AS-554-D, Water Permitting Guide — March 2000 B-1

103

Contents

B-1 Stormwater BMPs for Industrial Activities B-5. . . . . . . . . . . . . . . . . . .

B-1.1 Implementing Preventive Measures B-5. . . . . . . . . . . . . .

B-1.1.1 Removing Debris From StormwaterStructures B-5. . . . . . . . . . . . . . . . . . . . . . . . . . .

B-1.1.2 Providing Training and EducationPrograms B-6. . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-1.1.3 Reducing Exposure B-6. . . . . . . . . . . . . . . . . . .

B-1.1.4 Implementing a “Pharmacy System” B-6. . . .

B-1.1.5 Maintaining and Cleaning the Site B-7. . . . . .

B-1.2 Implementing Control Measures B-7. . . . . . . . . . . . . . . . .

B-1.2.1 Diverting Runoff B-7. . . . . . . . . . . . . . . . . . . . . .

B-1.2.2 Using Secondary Containment B-8. . . . . . . . .

B-1.2.3 Using Detention and RetentionPonds B-8. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-1.2.3.1 Considering a DetentionPond B-8. . . . . . . . . . . . . . . . . . . . .

B-1.2.3.2 Considering a RetentionPond B-10. . . . . . . . . . . . . . . . . . . . .

B-1.2.4 Considering Infiltration (Exfiltration)Devices B-13. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-1.2.5 Implementing Oil-and-Grease RemovalDevices B-17. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-1.2.5.1 Considering an Oil-and-Grease Separator B-17. . . . . . . . .

B-1.2.5.2 Considering an Oil-and-Grease Trap B-18. . . . . . . . . . . . . .

B-1.2.5.3 Considering a SedimentationBasin and Skimmer Plate B-19. . .

B-1.2.6 Using Porous Pavement B-19. . . . . . . . . . . . . . .

B-1.2.7 Using Sand Filters B-21. . . . . . . . . . . . . . . . . . . .

B-1.2.8 Implementing Vegetative Practices B-22. . . . . .

B-1.2.8.1 Considering DrainageSwales B-22. . . . . . . . . . . . . . . . . . .

B-1.2.8.2 Considering Filter Strips orRaingardens B-23. . . . . . . . . . . . . .

B-1.2.8.3 Considering Grass Swales B-24. .

B-1.2.9 Considering Constructed Wetlands B-24. . . . .

B-2

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B-1.2.10 Considering Natural and RestoredWetlands B-27. . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2 Stormwater BMPs for Construction Activities B-28. . . . . . . . . . . . . . .

B-2.1 Implementing Stage 1, Source Reduction,BMPs B-28. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.1.1 Mulching B-28. . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.1.2 Temporary Seeding B-29. . . . . . . . . . . . . . . . . . .

B-2.1.3 Permanent Seeding B-29. . . . . . . . . . . . . . . . . . .

B-2.1.4 Sodding B-29. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.1.5 Adding Riprap B-29. . . . . . . . . . . . . . . . . . . . . . . .

B-2.1.6 Roughening the Surface B-29. . . . . . . . . . . . . . .

B-2.1.7 Constructing a Temporary GraveledConstruction Access B-30. . . . . . . . . . . . . . . . . .

B-2.1.8 Applying Topsoil B-30. . . . . . . . . . . . . . . . . . . . . .

B-2.2 Implementing Stage 2, Stormwater Conveyance,BMPs B-30. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.2.1 Diverting Runoff B-30. . . . . . . . . . . . . . . . . . . . . .

B-2.2.2 Building a Closed Drainage System B-31. . . . .

B-2.2.3 Using an Open Drainage System B-31. . . . . . .

B-2.2.4 Using a Catch Basin B-32. . . . . . . . . . . . . . . . . .

B-2.2.5 Considering a Drainage Inlet B-34. . . . . . . . . . .

B-2.2.6 Using a Grass-Lined Channel B-35. . . . . . . . . .

B-2.2.7 Considering a Hardened Channel B-36. . . . . . .

B-2.2.8 Using a Paved Flume B-36. . . . . . . . . . . . . . . . .

B-2.2.9 Using a Temporary Slope Drain B-36. . . . . . . .

B-2.2.10 Protecting Outlets B-36. . . . . . . . . . . . . . . . . . . .

B-2.2.11 Considering a Level Spreader B-37. . . . . . . . . .

B-2.2.12 Using an Outlet StabilizationStructure B-38. . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.3 Implementing Stage 3, Stormwater Capture,BMPs B-38. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.3.1 Using a Block-and-Gravel Inlet B-38. . . . . . . . .

B-2.3.2 Considering an Excavated Drop Inlet B-38. . . .

B-2.3.3 Considering a Fabric Drop Inlet B-38. . . . . . . . .

B-2.3.4 Using a Sediment Basin or RockDam B-39. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


105

B-2.3.5 Using a Sediment Fence and a StrawBale Barrier B-39. . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.3.6 Considering a Sediment Trap B-39. . . . . . . . . .

B-2.3.7 Considering a Sod Drop Inlet B-39. . . . . . . . . . .

B-2.3.8 Using a Vegetated Filter Strip B-39. . . . . . . . . .

B-2.4 Implementing Stage 4, Stream Protection,BMPs B-40. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-2.4.1 Stabilizing Stream Banks andStreambeds B-40. . . . . . . . . . . . . . . . . . . . . . . . .

B-2.4.2 Building a Temporary StreamCrossing B-41. . . . . . . . . . . . . . . . . . . . . . . . . . . .

B-4

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Exhibits

Exhibit B-1.2.3.1Schematic of a Detention Pond B-9. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-1.2.3.2Schematic of a Retention Pond B-11. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-1.2.4aSchematic of a Perforated Drain Stormwater Recharge Trench B-14. . . . . . . . . .

Exhibit B-1.2.4bSchematic of a Median Strip Infiltration Trench B-15. . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-1.2.4cSchematic of a Parking Lot Perimeter Infiltration Trench B-16. . . . . . . . . . . . . . . .

Exhibit B-1.2.4dSchematic of a Roof Drain Infiltration Stone Pit B-16. . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-2.2.3Schematic of Two Types of Channels in an Open Drainage System B-32. . . . . .

Exhibit B-2.2.4Schematic of a Drain Manhole B-33. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-2.2.5aSchematic of a Concrete Headwall B-34. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-2.2.5bSchematic of a Flared-End Section B-34. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-2.2.5cSchematic of an Excavated Inlet Sediment Trap B-35. . . . . . . . . . . . . . . . . . . . . . .

Exhibit B-2.2.10Diagram of an Outlet Protection B-37. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .


107

B What Stormwater BestManagement Practices AreAvailable?

This appendix describes best management practices (BMPs) that canmeet the requirements for a NPDES stormwater discharge permit and cansupplement the treatment of stormwater. The appendix is divided into twosections: one for BMPs used with industrial activities and one for BMPsused with construction activities. The section about industrial BMPs isdivided into subsections concerning preventive measures and controlmeasures. The section about construction BMPs is divided intosubsections concerning surface stabilization, runoff, sediment traps andbarriers, and stream protection.

B-1 Stormwater BMPs for Industrial Activities

In this section, two types of stormwater BMPs for industrial activities arediscussed. The first subsection describes using preventive (nonstructural)measures to mitigate stormwater pollution. The second subsectiondescribes control (structural) measures.

B-1.1 Implementing Preventive Measures

Preventive measures, or source controls, are management techniques thatreduce the exposure of materials to stormwater, which limits the amount ofpollutants picked up by stormwater. Preventive measures arenonstructural, cost-effective ways for managing stormwater runoff thatusually do not require any land area or construction and can beimplemented with moderate effort. Each measure is discussed in greaterdetail in the paragraphs that follow.

B-1.1.1 Removing Debris From Stormwater Structures

Debris must be removed frequently and regularly from stormwater controland conveyance structures for them to function properly. Litter and wastecan clog inlets, catch basins, and outlets; lead to overflows, erosion, andflooding; and make the debris-removal devices ineffective for removingstormwater pollutants. Maintenance crews should be able to clean grateson inlets and outlets easily. Where feasible, forebays can be installed in

The

Pennsylvania

Handbook of

Best Management

Practices for Developing

Areas is recommended for

further information about

the BMPs discussed in this

appendix.

B-6

108


front of entryways to ponds. Forebays are easily cleaned and separatemuch of the sediment, pollutants, debris, and floatables from thestormwater. Paving parts of the forebay allows easy access formaintenance equipment.

B-1.1.2 Providing Training and Education Programs

Spill prevention and response programs and training on these programscan prepare employees for preventing and responding to spills.Stormwater pollution can be significantly reduced by encouragingemployees to collect and recycle old or unused materials and equipmentand to use alternative chemicals and practices.

New preventive measures can be taught through education programs.Employees can learn to properly handle and store materials and disposeof industrial wastes through in-house training courses, videotapepresentations, and seminars. Local government agencies, such as theCooperative Extension Service and the Industrial Extension Service, oftenhave educational materials that can be used for training.

B-1.1.3 Reducing Exposure

One of the best and least expensive ways to reduce or eliminate pollutantsin stormwater is to limit the potential exposure of a source to rainfall orstormwater runoff. A good example of exposure reduction is storing roadsalt or sand in covered facilities. Covering prevents the salt from beingexposed to rain, which reduces the pollution of streams and groundwater.Exposure reduction methods include:

� Move or Remove — Cease certain outdoors activities or movepotential sources of stormwater pollutants indoors.

� Inventory — Inventorying items that are exposed to rain is a startingpoint for reducing their exposure. Examples of items to inventory areraw material stockpiles, stored finished products, and machinery orengines that leak fuel and oil. Chemicals, fuel, oil, or other liquidsthat spill or leak onto the ground can pollute stormwater runoff andgroundwater.

� Cover — Partially or totally enclosing stockpiled or stored material,loading and unloading areas, or processing operations are methodsthat can reduce exposure of a variety of source elements. Drainagefrom a covering may be captured and directed around potentialcontamination areas. This BMP may avoid adding pollutants, suchas metals, oil and grease, and toxic and hazardous chemicals, tostormwater.

B-1.1.4 Implementing a �Pharmacy System"

Implementing a “pharmacy system” of dispersing hazardous or toxicmaterials can minimize the amount of materials used at a facility and


109

reduce the risk of spills. Under a pharmacy system, hazardous or toxicproducts, such as paint and cleaning solutions, are distributed from onecentral location at the facility. Product users must go to the “pharmacy,”where they will receive just enough of the product to achieve their statedtask. Under this system products are used more efficiently. The processalso reduces stormwater pollution by reducing the amount of materialexposed to rainfall. Establishing a pharmacy for collecting and distributingpaint for repairing equipment or vehicles is an example of a pharmacysystem.

B-1.1.5 Maintaining and Cleaning the Site

Site maintenance includes cleaning up sorbents used to remove spills orminor leaks of fluids from vehicles or equipment. In addition, empty drumscan be recycled, and hazardous substances and wastes should beremoved as soon as possible. Old stockpile areas and bare areas also canbe graded and seeded to reduce erosion and improve the appearance ofthe site. Equipment should be maintained to reduce leaks, breakdowns,spills, and accidents. Preventive maintenance includes replacing wornseals, fittings, and other parts before they leak or break. Pollution-controldevices should be maintained in good working order.

Site cleaning is a viable way of reducing the amount of pollutants enteringthe stormwater system. Grounds should be cleaned and trash picked up,parking lots and roads swept, and old unused equipment disposed of.Regular, frequent street cleaning can reduce pollutants in runoff and keeppipes and outlets in detention structures and ponds from clogging.Disposing of street sweepings may be a problem because the waste maycontain high levels of lead, copper, zinc, and other toxic waste fromautomobile traffic. Street sweepings may need to be tested to determinethe appropriate disposal methods or alternative methods for their reuse.

B-1.2 Implementing Control Measures

Numerous control measures, or structural controls, can be used to reducepollutant levels in stormwater. Control practices can be inexpensivetechniques, such as settling, biological uptake of substances, andinfiltration for treating stormwater. The techniques will remove some of themost common pollutants. However, in areas near sensitive waters or thatcontain unusual pollutants, more sophisticated techniques may berequired to meet NPDES discharge standards or other requirements. Thissection presents common stormwater control practices.

B-1.2.1 Diverting Runoff

Structures that channel runoff away from pollutant sources include gradedsurfaces to redirect sheet flow; diversion dikes or berms, which force sheetflow around a protected area; and stormwater conveyances (swales,channels, gutters, drains, and sewers), which intercept, collect, and

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redirect runoff. Diversion features are often useful in industrial settings toprevent contamination by pollutants such as metals, oil and grease, andtoxic and hazardous chemicals.

B-1.2.2 Using Secondary Containment

Secondary containment for preventing releases into the environment isprovided by basins, dikes, berms, curbing, or retaining walls that capturematerial releases from industrial operations. Secondary containmentshould be sized to hold at least 110 percent of the volume of the largestcontainer. If the area is exposed to the atmosphere, the secondarycontainment also should be capable of retaining the volume of water froma 10-year recurrence-interval rainfall. The secondary containment shouldbe constructed of material that is sufficiently impervious in order to preventexternal seepage and that is compatible with the chemicals to becontained. Typical construction materials are concrete, asphalt, and clay.A layer of crushed limestone or clamshell over the base can help neutralizespilled acids.

Acid neutralization tanks are sometimes used in battery storage rooms.The tanks act as secondary containment vessels, which treat spilled acidicliquids before the liquids are released to a sanitary sewer or pumped outby contractors using specialized equipment.

EPA requires facilities that temporarily contain hazardous pollutants to beequipped with pumping systems for removing the liquid rather than beingequipped with drainage systems. Secondary containment is most effectiveas part of a system of BMPs that includes safety practices for minimizingthe risk of spills occurring.

B-1.2.3 Using Detention and Retention Ponds

An appreciable body of knowledge has been accumulated about the designand maintenance of detention and retention ponds or basins. As a BMP,detention and retention basins must be located properly, designed forappropriate detention times and treatment of the expected range ofstormwater volumes, and maintained according to strict procedures andschedules. The stormwater should be held for at least 24 hours to removethe maximum amount of pollutants. The soil should be permeable to allowthe water to drain from the basins between storms, and the water tableshould be more than 2 feet below the bottom of the basin (to avoid apermanent pool of water in the basin during wet weather). A forebay,separated from the main basin by a wall or dike, may be part of the designto receive incoming stormwater and help capture debris.

B-1.2.3.1 Considering a Detention Pond

A detention pond is a basin in which stormwater runoff from a specifieddrainage area is stored temporarily and released to a downstream area at


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a controlled discharge rate (see Exhibit B-1.2.3.1). The stormwater is heldor “detained” in the drainage area during, and for some time after, a stormevent. The drainage area, or ponding area, may be totally drained (drydetention) between storm events or may support an open water area orsaturated substrate below the detention outlet (wet detention).

Exhibit B-1.2.3.1Schematic of a Detention Pond

Section

Flat Basin Floor WithDense Grass Turf

Emergency Spillway

Backup Underdrain

Embankment

RiprapOutfallProtection

Inlet

Inlet

Backup Underdrain Pipe In Caseof Standing Water Problems

Riprap Settling Basinand Level Spreader

Exfiltration StorageValve

Plan

A detention pond generally consists of a large depression (basin) that maybe surrounded by earthen dikes. The surface of a dry basin is vegetated,and a wet basin is partially vegetated to the water level. A number of pipesor watercourses convey collected runoff into the detention pond. At leastone structure is required to permit water in the pond to exit the basin at acontrolled rate. An overflow spillway, protected from potential erosion, maybe constructed across the containment dike as an emergency outlet for thedetention pond. Outlet control structures, consisting of pipes, weirs,spillways, or boxes, are fixed or adjustable.

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Detention ponds are designed for a specific site. Typically, outlets must besized to control flow from a variety of storm events, up to a 100-year stormwhen required by applicable regulations. Detention ponds can serve smallto rather large areas and often are incorporated into the overall design ofa development. Water detention time, access, maintenance, public safety,proximity to contiguous residential areas, and aesthetics must beconsidered in the design. If high dikes are required for impoundment levels,geotechnical and structural criteria may apply to the design of small dams.

The effectiveness of detention ponds is rated low to moderate comparedwith other stormwater BMPs. Detention ponds reduce peak stormwaterdischarges, control flooding, and prevent downstream channel scouring.Detention ponds do not remove soluble pollutants very effectively. Also,many pollutants that settle out are resuspended during the next storm andmay be discharged along with the stormwater. However, detention pondsremove significant amounts of particulates and effectively reduce peakstorm flows.

Detention ponds can be unsightly, especially if debris accumulates in them.The appearance of some is improved by planting hardy wildflowers in thebottom; acceptance of a “wildflower basin” is much higher than of anunadorned open basin. Many detention ponds develop permanent poolsbecause runoff from previous storms either has not flowed out or infiltratedbefore another storm occurs. Because the detention ponds occupy largeareas, they are not well suited for high-density developments.

The following maintenance is necessary for detention ponds. Detentionponds should be checked monthly or immediately after heavy rainfall toensure that the outlets and inlets are not blocked by trash or debris, whichshould be removed as soon as possible. Pond slopes and dikes should bechecked for signs of erosion. Any eroded slopes should be stabilized assoon as possible. Vegetative growth in the detention pond should be cutand trimmed periodically during the growing season. Tree and brushgrowth in the basin should be monitored and, if appropriate, removed.Trees and bushes should be removed from dikes because they may affectthe slope’s stability.

Also, detention ponds must be easy to access for maintenance, which isboth essential and costly. General objectives of the maintenance are toprevent clogging, standing water, and the growth of weeds and wetlandplants. This requires frequent cleaning of the outlets and inlets. Cleaningout the sediment, which is expensive, must be done every 10 to 20 years.

B-1.2.3.2 Considering a Retention Pond

A retention pond is an area in which stormwater runoff from a drainage areais stored and dissipated through gradual infiltration into the underlying soilor by evaporation (see Exhibit B-1.2.3.2). The ponding area may be drybetween storm events or may support a year-round water body below the


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retention storage level. A retention pond generally consists of a largedepression area (basin) that is contained by an earthen dike. The basinsurface may be fully or partially vegetated (to the water surface level) foreither a dry or wet retention pond. A number of pipes or watercoursesconvey runoff into the pond. The pond should not have an outlet structurefor releasing water volume of less than a minimum design level. However,an emergency overflow spillway, protected from erosion, should be builtinto the containment dike. A structure may also be built that can be adjustedto release impounded water from the pond.

Exhibit B-1.2.3.2Schematic of a Retention Pond

Inlet

Sediment Forebay(Planted as Marsh)

Section

Plan

Weir

Vegetated AquaticBench

Permanent Pool

Safety Bench(10 Feet Wide)

Trash Hood

Anti-seep Collars

EmergencySpillway

Riprap OutfallProtection

Permanent Pool

Embankment

Embankment

Stormwater Storage

BarrelRiser

Basic considerations for installing retention ponds are location, the volumeof inflow runoff, hydraulic residence (holding) time, size of the permanentpool, and maintenance, as discussed below:

� Retention ponds can be used in most locations where enough spaceis available to accommodate the pond.

� The volumes of stormwater runoff and normal discharge availablefor the permanent pool must be calculated by trained hydrologistsbefore a retention pond is constructed.

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� Retention ponds must be sized appropriately to store the volume ofwater from given storm events, up to a 100-year storm.

� Long, narrow ponds or wedge-shaped ponds are preferred tominimize short-circuiting of storm flows. These shapes will alsolessen the effects of wind, which can stir up sediment andsediment-bound pollutants. Pond shape, depth, and surroundingfringe areas must be considered to maximize the effectiveness ofthe basin.

� Maintenance accessibility, public safety, and aesthetics must beconsidered in the design.

Retention ponds should be designed to displace the older stormwater withthe newer stormwater, which ensures that the stormwater will be held longenough to remove the pollutants and sediment. If the pond is poorlydesigned or maintained, short-circuiting can occur. Short-circuiting causesthe new stormwater to be released too soon, preventing pollutant removaland settling of sediment.

Retention ponds are one of the most effective and reliable devices forremoving pollutants from stormwater. A permanent pool of water enhancesthe removal of many pollutants. Retention ponds fill with stormwater andrelease most of it over a period of a few days, the water level slowlyreturning to its normal depth. Several mechanisms in wet ponds removepollutants, including settling of suspended particulates; biological uptake(the consumption of pollutants by plants, algae, and bacteria in the water);and decomposition of some pollutants.

Because of the permanent pool of water, wet ponds can remove moderateto high amounts of most pollutants and are more effective in removing plantnutrients than most other devices, an important characteristic for protectinglakes, rivers, and estuaries from eutrophication. Also, the large volume ofstorage in the pond helps to reduce peak stormwater discharges, which, inturn, helps control downstream flooding and reduces scouring and erosionof stream banks. The marsh plants around the pond help remove pollutantswhile also providing habitat and hiding debris. Because people findretention ponds aesthetically pleasing, retention ponds can be sited in highvisibility areas. Retention ponds can provide wildlife habitat, and they maybe a focal point for a recreation area.

There are a few disadvantages to retention ponds. One disadvantage ofthese ponds is that they may contribute to thermal pollution and causedownstream warming. This may preclude their use in areas wheresensitive aquatic species live. Another disadvantage is that retentionponds are not well suited to very small developments because of their largesize. Rotting plants, nuisance insects and odors, and algae blooms can beproblems when the ponds are not properly maintained. Plants may needto be harvested periodically to prevent their releasing nutrients into thewater and lowering dissolved oxygen levels when they die.


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To be effective, retention ponds must be regularly inspected, must have thesediment removed, must be mowed, and must have the inlets and outletscleaned and repaired. Retention ponds should be checked periodicallyduring wet seasons or after heavy rains to ensure that the retained wateris being dissipated and that water is not overflowing the containment dikes.The retention pond embankment should be stabilized so that it will noterode or create sediment in the basin. Accumulated debris and sedimentin the pond should be checked at least annually and removed when itbegins to adversely affect the retention volume of the pond. Vegetativegrowth in the pond should be monitored and maintained as needed. Treesand brushes growing on the dikes should be removed to ensure thestructural integrity of the embankment.

Mosquitoes can be controlled in retention ponds with mosquito-larvae-eating fish, such as Gambusia affinis (mosquito fish). Mosquito fishare hardy and can live in many types of habitats for several years. They arenative to freshwaters of the southeastern United States, but have beenwidely introduced in other parts of the world for controlling mosquitoes.Another control method that does not use insecticides is the monthlyapplication of briquettes containing a bacteria that causes a disease inmosquitoes. The briquettes need to be applied only during the warmermonths.

B-1.2.4 Considering Infiltration (Exfiltration) Devices

Infiltration devices effectively remove pollutants by adsorbing thepollutants onto soil particles, then biologically and chemically convertingthe pollutants in the soil. Infiltration basins with long detention times andgrass bottoms enhance pollutant removal by allowing more time forsettling. The vegetation on the bottom helps to increase the settling andadsorption of sediment and pollutants. Infiltration devices work only inareas where the soil is permeable enough that the water can exit thestorage basin and enter the soil. The water table must be at least 2 feetunder the bottom of the device.

In areas with a high percentage of impervious surfaces, infiltration is oneof the few methods of significantly recharging groundwater. Infiltrationdevices help replenish the groundwater and reduce stormwater peak flowsand volume. However, poorly installed or improperly located devices faileasily, therefore, infiltration devices must be carefully designed andmaintained to work properly.

Some infiltration devices (e.g., infiltration trenches, dry wells, and catchbasins) can be constructed under parking lots and roads, which leavesmore land for other uses. Several small infiltration devices can easily besited upstream, instead of using a large device downstream, and stillcontrol the same quantity of stormwater. Smaller infiltration devices, suchas dry wells or basins, can be located near buildings to capture the runofffrom roofs and other impervious surfaces.

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An example of an infiltration device is an infiltration trench, which is astone-filled trench used to collect surface runoff at common collectionpoints along a drainage system. The runoff is diverted into shallow trencheswhere it either leaches into the ground or is routed through perforatedunderdrain pipes to an outlet or discharge point. Exhibit B-1.2.4a is adiagram of a perforated drain stormwater recharge trench. Observationwells may be installed in the trench to monitor water levels and evaluateoperating conditions.

Infiltration trenches typically are 3-feet to 8-feet deep and are filled with 1.5-to 2.5-inch diameter clean stone. Filter fabric typically lines all sides of thetrench to prevent infiltration of fine soil particles. The design of the trenchesvaries with the size of the site, type of soil, and depths to groundwater andbedrock. Infiltration trenches can effectively mitigate potentially adversewater quality impacts and reduce peak discharge rates.

Exhibit B-1.2.4aSchematic of a Perforated Drain Stormwater Recharge Trench

Compacted Excavated(Native) Material

Filter Fabric18-Inch Minimum

Proposed Grade

PerforatedPipe

Washed StoneProvided

Minimum of2 Feet to 4 FeetAboveHigh-GroundWater Table

Overlap

Infiltration trenches typically are used in grassed areas, such as medianstrips (Exhibit B-1.2.4b), perimeters of parking lots (Exhibit B-1.2.4c), andswales. The size of a trench depends on the quantity of runoff to the trench


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and the leaching characteristics of the soil surrounding the trench. Sometrenches have perforated drains at the bottom to direct flow to an outlet.

Exhibit B-1.2.4bSchematic of a Median Strip Infiltration Trench

Screened OverflowPipe

Section

Inflow

Plan

Outflow

Trench

Grass Filter

20-Foot Grass Filter Strip

Permeable FilterFabric, 1 Foot BelowSurface, Traps Debris

Sides Lined With Permeable Filter FabricClean Washed Stone or Gravel (1.5 to 3 Inches)

6-Inch to 12-Inch Sand Filter or PermeableFilter Cloth Lines Bottom

Before perforated drains are used, a qualified professional should evaluatethe type of soil and the depth to the water table and bedrock. Undergroundinfiltration-exfiltration systems (e.g., underground reservoirs) are used insituations where other more cost-effective means are unavailable. ExhibitB-1.2.4d is a schematic of a stone pit used for roof drain infiltration.

Maintenance of infiltration devices is higher than other devices partlybecause the devices must be inspected frequently. In addition, nuisanceproblems can occur, especially insect breeding, odors, and soggy ground.Maintenance includes regularly inspecting them, cleaning the inlets,mowing, and possibly using observation wells. Sediment must be removedfrom infiltration basins and sediment removal devices regularly. If aninfiltration device becomes clogged, it may need to be completely rebuilt.

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Section

Plan

Flow

Drip Line of Tree ShouldNot Extend Over Trench

Slotted Curb Spaces

20-Foot GrassFilter Strip

Slope of Parking Lot

Cars

Berm (Grassed)

Storm Drain(If Partial Exfiltration)

Filter StripDirectly AbutsPavement

Slotted Curbs Act asa Level Spreader

Sand Filter

Washed Stone

Protective FilterCloth Layer

Exhibit B-1.2.4cSchematic of a Parking Lot Perimeter Infiltration Trench

Roof Leader

Overflow PipeSplash Block

Cap With Lock

Filter Fabric LinesTop, Bottom, andSides of Stone Pit

Section

Test Well ofPerforated PVC*Pipe, AnchoredWith Rebar

InletPipe

BuildingFoundation

10-FootMinimumSetback

12 Inches toPerforations

WashedStone Fill 1.5to 3 Inches inDiameter

*PVC=polyvinyl chloride

Exhibit B-1.2.4dSchematic of a Roof Drain Infiltration Stone Pit


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Trenches should be inspected several times during the first few monthsafter they have been installed and annually thereafter. The trenches shouldalso be inspected after major storm events. Sediment must be interceptedbefore it enters the infiltration-exfiltration system, because accumulatedsediment can reduce the effectiveness of the system to infiltrate underlyingsoil. Water that is ponding on the surface of the trenches indicates that thesystem is clogged. Water levels in the observation wells should be checkedroutinely to ensure that the system is functioning effectively. The surfacetreatment over the trench varies from stone aggregate to landscapedfeatures. The stone surfaces should be raked semiannually to removeleaves, organic debris, and litter. Grass-covered infiltration trenches shouldbe mowed regularly and the clippings, which could clog the trench,collected.

B-1.2.5 Implementing Oil�and�Grease Removal Devices

A number of devices are available that remove oil and grease fromstormwater (e.g., mechanical oil/water separators). The devices usevarious mechanisms, some of which are proprietary, to separate oil fromstormwater, which is then discharged to a treatment plant or to a receivingwater. The devices are discussed in the following sections.

B-1.2.5.1 Considering an Oil�and�Grease Separator

An oil-and-grease separator is an underground structure used in adrainage system to collect and separate oil, gas, grease, and otherpetroleum-based chemicals from the stormwater runoff. Accumulatedmaterials are retained and then removed periodically to improve the qualityof the stormwater runoff. An oil-and-grease separator typically is installedin conjunction with a closed drainage system immediately in front of itsconnection to another system or a discharge point. Flow from paved areaspasses through the separator. Some runoff is stored in the structure so thatfloating materials can separate and rise to the water surface. A control atthe structure’s outlet allows water to flow out while floating materials areretained. The structure is accessed through one or more manholes at theground surface.

A separator typically is a watertight, precast, reinforced-concrete structure.The outlet control structure may be an elbow, tee, hood, or trap. The outletcontrol should be designed to allow outflow from below the interior watersurface in the structure. The size and capacity of the structure, includinginlet and outlet pipes, should be designed to handle the expected runoff andto be in accordance with applicable regulations. Operating the separatorsmay require manufacturer support.

Oil-and-grease separators are best used where they can be properlymaintained and frequently inspected. Accumulated oil, gas, grease, andother floating materials and sediment should be removed from the structure

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annually or semiannually, depending on the volume of stormwater that isexpected to flow into the separator. A qualified licensed contractor shouldremove the accumulated material. The accumulated materials must bedisposed of in accordance with all applicable federal, state, and localregulations.

B-1.2.5.2 Considering an Oil�and�Grease Trap

Another type of oil-and-grease-removal device is the oil-and-grease trap(or catch basin). An oil-and-grease trap is an underground device used toremove oil, grease, and other floating substances and sediment fromstormwater before the pollutants enter the storm sewer system. The trapsare usually placed to catch the oil and fuel that leak from automobiles andtrucks in parking lots, service bays, and loading areas. Oil-and-greasecatch basins can reduce maintenance of infiltration systems, detentionbasins, and other stormwater devices.

A popular design for the catch basins uses three chambers: one to poolstormwater, one to allow the particulates to settle, and one to remove theoil. As water flows through the chambers, oil and grease separate either tothe surface or adsorb to the sediment and are skimmed off and held in thecatch basin. The stormwater then passes on to the storm sewer or intoanother stormwater pollution control device. Because the devices arerelatively small and inexpensive, they can be placed throughout a drainagesystem to capture coarse sediment, floating waste, and spills of hazardouswastes.

Oil-and-grease traps can be installed in most areas. Drainage areas thatare served by the catch basin must be no larger than 2 acres, and the catchbasin must be large enough to handle dry weather flows that enter thebasin. A catch basin can be installed in almost any soil or terrain, whichallows its use near or at the impervious surfaces contributing heavily to thestormwater runoff. A catch basin requires only enough area for propermaintenance. However, a catch basin can be difficult to maintain becauseof its enclosed, underground design.

For the most part, oil-and-grease traps are inexpensive and easilyinstalled. The traps can be used effectively as a first stage of treatment toremove oil and sediment from stormwater before it enters another, larger,stormwater pollution control device, such as a retention or detention pond.In addition, small catch basins can be distributed throughout a largedrainage area, which may prove more advantageous than constructing asingle large structure downstream.

To keep traps functioning properly, sediment must be removed or cleanedout frequently to prevent sediment-bound pollutants from being stirred upand washed out in subsequent storms. Removing the sediment alsoremoves the oil and grease because these pollutants eventually bind to the


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sediment. Oil-and-grease traps must be inspected and cleaned regularly,at least twice a year.

B-1.2.5.3 Considering a Sedimentation Basin and Skimmer Plate

Another device for removing oil and grease is an open sedimentation basin(or sump) with a skimmer plate extending below the water level controlelevation at the outlet. Stormwater velocities are reduced in a sump,dropping out coarse sediment and separating oil, grease, and floatables,which are retained in the basin by the skimmer as the stormwaterdischarges off the site or to a larger detention device. Sumps contain acontrol structure discharge for mounting a skimmer plate. The plate shouldextend sufficiently below the lowest discharge level to preclude the waterfrom being siphoned by the discharge.

Some advantages of sedimentation basins with skimmers are that they aresimpler and more easily maintained than a trap, tend to be larger and moreeffective, and photodegrade hydrocarbons in addition to settling pollutants.The sediment sump and skimmers are often larger than traps, have longerdetention times, and thus remove more sediment, oil, and grease. Theamount of pollutants removed varies with the basin volume, flow velocity,and the depth of baffles and elbows in the sump. One disadvantage of theskimmer is that the amount of pollutants removed is low except for oil,grease, and coarse sediment.

Sump and skimmers require periodic but less frequent sediment removalthan traps. Sediment must be removed or cleaned out frequently to preventsediment-bound pollutants from being stirred up and washed out insubsequent storms. Removing the sediment also removes the oil andgrease because these pollutants eventually bind to the sediment. Wasteremoved from sumps should be tested to determine proper disposalmethods. The waste may be hazardous; therefore, the maintenancebudget should include the cost of its disposal at a proper site.

B-1.2.6 Using Porous Pavement

Porous pavement is an alternative to conventional pavement that isintended to reduce imperviousness and consequently minimize surfacerunoff. Porous pavement allows water to infiltrate through the surface to anunderground stone reservoir. On relatively flat sites, porous pavement canbe used for parking areas or light-access roads underlain with permeablesoil. Porous pavement conveys stormwater to the other component of thedesign, the underlying aggregate chamber, which is an infiltration device.As with other infiltration devices, stormwater is treated by particulatefiltration in the chamber and adsorption, filtration, and microbialdecomposition in the subsoil surrounding the aggregate chamber.

Although more expensive than conventional pavement, porous pavementcan eliminate the need for more complex stormwater drainage,

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conveyance, and treatment systems, which is a valuable option for urbansites with little space. This BMP is recommended for lightly traffickedsatellite parking areas and access roads. Porous pavement may be mostbeneficial in watersheds with a high percentage of impervious surface anda high volume of runoff.

Two basic designs for porous pavement exist. In one, the pavement iscomposed of asphalt or concrete lacking the finer sediment found inconventional cement and is laid over a thick base of granular material. Inthe second, pavement is formed with modular, interlocking open-cellcement blocks laid over a base of coarse gravel. A geotextile fabricunderlying the gravel prevents the soil from migrating upward into thegravel bed. Both designs typically include a reservoir of coarse aggregatebeneath the pavement for storing stormwater before it exfiltrates into thesurrounding soil. For porous pavement to be useful, the soil must bepermeable with a deep water table.

Porous pavement can only be used after carefully considering existing soilconditions, bedrock locations, and groundwater levels. Porous pavementis not recommended for northern climates because of the freeze-thawcycle, which can cause the pavement structure to deteriorate. Porouspavement should not be used in areas of moderate or heavy traffic flow. Itis not advisable to use porous pavement in areas when high levels ofsediment, including chemicals and sand used for snow removal, areexpected to run off of the site. “Porous Pavement Area” signs should beposted so that heavy equipment will not be parked on these areas.

Porous pavement systems remove high amounts of sediment, nutrients,organic matter, and trace metals. The removal rates result from thereduction of mass loadings of the pollutants through their transfer togroundwater. In addition, porous pavement can divert potentially largevolumes of surface runoff to recharge the groundwater, benefiting bothwater quality and quantity. By increasing infiltration at the source (e.g.,parking lots), both the volume of runoff and the delivery of associatedpollutants to water bodies is reduced.

The major disadvantage of porous pavement is that sites have a high failurerate, which is usually caused by clogging either from improper construction,accumulated sediment and oil, or resurfacing. Excessive sedimentationwill cause the pavement to seal rapidly and become ineffective. Themodular, interlocking, open-cell concrete-block-type pavement tends toremain effective for considerably longer than asphalt or concrete porouspavement.

Porous pavement must be maintained frequently to remain functional. Theporous pavement surface should be swept with a vacuum about four timesa year, followed with a high-pressure jet hosing. The pavement should beinspected periodically to check for surface ponding, which indicates that thesystem is clogging.


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B-1.2.7 Using Sand Filters

Sand filters are used to treat stormwater runoff from large buildings, accessroads, and parking lots. The filters work by filtering stormwater throughbeds of sand. Large sand filters are self-contained sand beds installedaboveground that can treat stormwater from drainage areas as large as 5acres. Small sand filters are installed underground in trenches or precastconcrete boxes. Both aboveground and underground sand filters use someform of pretreatment to remove sediment, floating debris, and oil andgrease in order to protect the filter. After the stormwater passes through thepretreatment device, it flows onto the sand filter bed. As the stormwaterflows through the filter bed, sediment particles, and the pollutants that areadsorbed to the sediment particles, are captured in the upper few inchesof sand.

Because of the construction techniques used to build aboveground sandfilters, large filters are proportionately less expensive than small filters.Construction costs can be kept lower if lightweight equipment is used formaintenance, which reduces the structural reinforcing needed in the filter.Aboveground sand filters with a bed depth of about 18 inches can handledrainage areas as large as 5 acres. Aboveground sand filters may havegrassed filter strips, grassed swales, or large basins to pretreat theincoming stormwater to prevent clogging.

Underground sand filters fit in very well in urban areas and on sites withrestricted space. Depending on the design, the underground sand filtersare practically invisible to casual observers and generally receive fewcomplaints from residents. Underground sand filters built intwo-chambered precast concrete boxes cannot handle large drainageareas. Moderate-to-large parking lots should be the largest areas that drainto underground sand filters.

As a rule of thumb, sand filters constructed underground should havepretreatment or settling chambers that hold approximately 540 cubic feetof water for each acre of drainage area contributing stormwater to the sandfilter. In addition, for two-chambered sand filters, the volume of the filterchamber should equal the volume of the settling chamber, and the sandfilter bed should be roughly 18 inches deep. The surface area of both thesettling and filter chambers should be approximately 360 square feet foreach acre of drainage area.

The amount of pollutants that sand filters remove depends on the site andclimate. Overall removal of sediment and trace metals is better thanremoval of more soluble pollutants because the filter functions by simplystraining small particles out of the stormwater. Sand filters can effectivelyreduce the more common urban pollutants in stormwater. They also havelong lifetimes and consistently remove pollutants when properlymaintained.

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There are some disadvantages to sand filters. They are more expensiveto construct than infiltration trenches, especially if heavy equipment is to beused for maintenance. Sand filters do not detain stormwater, and theyremove a limited number of pollutants. Aboveground sand filters are oftenconsidered eyesores by residents. Thus, these sand filters should be usedwhere they cannot be seen or where hedges or other visual barriers canbe installed.

Maintenance for sand filters is simple, inexpensive, and done manually.Normal maintenance requirements include raking the sand surface anddisposing of accumulated trash. The upper few inches of dirty sand mustbe removed and replaced with clean sand when the filter clogs. Mosquitobreeding is usually not a problem, even in underground settling chambersthat hold pools of water for long periods (oil and grease in the stormwatermay form a sheen on the water, thus preventing mosquito breeding).

B-1.2.8 Implementing Vegetative Practices

Vegetation can be used to reduce the velocity of stormwater, which helpsstormwater to infiltrate into the soil and settle particulates as well as toprevent erosion. Vegetation can be planted in drainage swales, filter strips,grass swales, riparian areas, and landscaping of wet, dry, and infiltrationbasins. Vegetation is often used as part of a BMP to remove particulatesand to slow runoff before they enter another treatment device. Threefrequently used vegetative measures — drainage swales, filter strips (e.g.,raingardens), and grass swales (or biofilters) — are described in thissection.

In general, vegetative BMPs remove pollutants by encouraging infiltrationinto the ground, by reducing runoff velocity and thus allowing particles tosettle, and by absorbing some pollutants. To be effective, vegetativepractices are used in flat areas that are large in relation to the drainage areaand have deep water tables.

Vegetative BMPs have the following benefits. They are inexpensive andare generally easy to maintain with common procedures, such as mowingand trimming. For instance, filter strips and grass swales are easily sitedand constructed. Vegetative BMPs are highly effective in preventingerosion and thus controlling sediment in stormwater runoff. However,vegetative practices remove only small amounts of pollutants. In addition,this BMP does little to control peak storm flows or to reduce stormwatervolumes.

B-1.2.8.1 Considering Drainage Swales

Drainage swales are shallow watercourses (with natural or human-madefeatures) used to collect and to convey surface runoff across the groundsurface to a release or discharge point. A swale channel may be noticeable,or it may be just a slight depression along the perimeter of a paved area.


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The depth of a swale typically ranges from a few inches to 1–2 feet. Thewidth of the swale typically is less than 5 feet. Vegetated swales of sufficientlength can enhance the water quality of stormwater runoff.

Drainage swales typically are lined with earth, grass, or crushed stone.Where high water flow velocities or erosion is expected, more stablechannel linings, such as concrete, asphalt, or stone riprap, may be used.The height of grass in drainage swales can affect the pollutant removal;taller grass will slow velocities more, but short grass may take up more plantnutrients. A runoff conveyance must be considered, and swales used forimproving water quality should be designed in accordance with specificcriteria (for example, the length of the swale may be governed byregulations).

The following maintenance is necessary for drainage swales. They shouldbe checked monthly for accumulations of debris. Trash, leaves, branches,and so forth, should be removed from channel areas. Vegetation growth ina swale should be carefully maintained through normal grass-growingmaintenance activities, such as mowing and resodding, as necessary.Grass should be cut and weeds and brush removed or trimmed regularlyduring the growing season. When observed, channel erosion in swalesshould be stabilized as soon as possible. Significant accumulations of silt,sand, and sediment should be removed annually.

B-1.2.8.2 Considering Filter Strips or Raingardens

Filter strips typically are bands of close-growing vegetation plantedbetween sources of pollutants and a receiving water. They also can be usedas outlet or pretreatment devices for other stormwater control practices.Filter strips are usually grass, but can also include shrubs or woody plantsthat help to stabilize the grass strip, or can be composed entirely of treesand other natural vegetation. Filter strips are used primarily in residentialareas around streams or ponds. Filter strips do not store or infiltrate enoughrunoff to significantly reduce peak discharges or the volume of stormwaterrunoff. For this reason, filter strips should be used as only one componentin a stormwater management system. At some sites, filter strips may helpreduce the size and cost of downstream control facilities.

Filter strips function best when they are level in the direction of stormwaterflow toward the stream. This orientation creates the finest sheet flowthrough the strip, increasing the infiltration and filtering of sediment andother solids. To prevent erosion channels from forming, a level spreadershould be situated along the top edge of the strip. Level spreaders (e.g.,a shallow trench filled with crushed stone) are designed to disperseconcentrated flows evenly over a larger area. The lower edge of the levelspreader must be level if the spreader is to work properly. Filter stripsshould not be used where slopes exceed 15 percent; best performanceoccurs where the slope is 5 percent or less.

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Filter strips reduce pollutants, such as sediment, organic matter, and manytrace metals, by the filtering action of the vegetation, infiltration of pollutantcarrying water, and sediment deposition. The height of grass in filter stripscan affect the pollutant removal; taller grass will slow velocities more, butshort grass may take up more plant nutrients. Although studies indicatehighly varying effectiveness, trees in strips can be more effective thangrass strips alone because of the trees’ greater uptake and long-termretention of plant nutrients. Properly constructed forested and grassed filterstrips can be expected to remove more than 60 percent of the particulatesand perhaps as much as 40 percent of the plant nutrients in urban runoff.

Filter strips fail very easily if they are not maintained regularly. Maintenanceof filter strips includes normal grass- or shrub-growing activities, such asmowing, trimming, removing clippings, or replanting when necessary.Strips that are used for removing sediment may require periodic regradingand reseeding of their upslope edge because deposited sediment can killgrass and change the elevation of the edge so that the flow through the stripis no longer uniform.

B-1.2.8.3 Considering Grass Swales

Grass swales are earthen channels covered with a dense growth of a hardygrass, such as tall fescue or reed canary grass. Swales are used primarilyin single-family residential developments, at the outlets of road culverts,and as highway medians. Because swales have a limited capacity toconvey runoff from large or intense storms, they often lead intoconcrete-lined channels or other stable stormwater control structures.

The effectiveness of swales has been assessed as moderate to negligibledepending on many factors. Swales may reduce some stormwaterpollution by infiltrating runoff into the soil, filtering sediment or other solidparticles, and slowing the velocity and peak flow rates of runoff. A grassswale’s effectiveness depends on the quantity of flow, the slope of theswale, the density and height of the grass, and the permeability of theunderlying soil. Research on grass swales has found the various levels ofpollutant removal range from a 30–90 percent reduction in solids and a0–40 percent reduction of total phosphorus loads. Grass swaleeffectiveness can be enhanced by adding a small (4- to 10-inch high) damacross the bottom of the swale, thereby increasing detention time.

B-1.2.9 Considering Constructed Wetlands

During the last two decades, interest has steadily increased in the UnitedStates in using natural physical, biological, and chemical aquatic systemsfor treating polluted water. This interest is driven by a growing recognitionof the natural way pollution is treated by wetlands and aquatic plants, by theescalating costs of conventional treatment methods, and by a growingappreciation for the potential ancillary benefits of such systems. Aquatic


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treatment systems are categorized as natural wetlands, constructedwetlands, and aquatic plant systems. Of the three types, constructedwetlands — also called created, restored, or mitigation wetlands — havereceived the greatest attention for treating stormwater pollution.

Constructed wetlands are designed and developed specifically for treatingwater. Constructed wetlands are further defined as:

engineered systems designed to simulate natural wetlands to exploitthe water purification functional value for human use and benefits.Constructed wetlands consist of former upland environments thathave been modified to create poorly drained soils and wetlands floraand fauna for the primary purpose of contaminant or pollutantremoval from wastewaters or runoff. (Hammer, 1992)

Constructed wetlands as defined here are not intended to replace all of thefunctions of natural wetlands. Instead, constructed wetlands serve tominimize point source and nonpoint source pollution before it entersstreams, natural wetlands, and other receiving waters. Constructedwetlands are meant to provide habitat, improved water quality, andaesthetic functions.

Constructed wetlands typically call for different design considerations thanthose used solely for improving the water quality. These systems are notaddressed here. In fact, debate continues about the advisability ofintentionally combining primary pollution control and habitat functions inthe same constructed facilities. Nonetheless, constructed wetlands canfunction in many ways like a natural wetlands in improving water quality,with the advantages of being able to control its location, design, andmanagement to optimize the functions. Thus, constructed wetlands aremost effective as part of a BMP system that includes minimizing initial runoffvolumes by positioning pervious landscaping features; routing runoff tomaximize infiltration; using pervious pavement, grass swales, or filterstrips; pretreating collected runoff to minimize sediment and pollutantloads; and attenuating larger storm runoff to minimize downstreamerosion-related water quality impacts.

The use of constructed wetlands for treating stormwater is still an emergingtechnology, so no widely accepted design criteria exist. However, thefollowing general design criteria should be considered:

� The velocity of the stormwater flowing into the wetland must be keptas low as possible so that the sediment is deposited and is unlikelyto be entrained in subsequent inflows.

� The nominal hydraulic residence time should be maximized, andinflows should be distributed over the entire wetland. In addition, thedesign should not allow hydraulic short-circuiting.

� Emergent vegetation should be used. Emergent macrophyticvegetation is critical for a well-functioning wetland. Plants must be

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able to withstand the pollutant loading and the frequent fluctuation inwater depth that typifies stormwater. Consult with a wetlandsbotanist to choose the proper vegetation.

� Anaerobic sediment conditions should be created to ensurelong-term burial of organic matter and phosphorus.

� The discharge flows should be controlled. An adjustable outfall maybe desirable for fine-tuning system performance; however,regulatory agencies often require a fixed design to precludeinappropriate modifications to this key feature. The rate of dischargefrom the outfall must be controlled. Also, the outfall may be fittedwith some form of skimmer for retaining oil and grease.

Constructed wetlands can achieve or exceed the pollutant removal ratesof wet and dry detention ponds, but their pollutant removal capabilities canvary widely. Constructed wetlands can effectively remove a number ofcontaminants. Among the most important of their removal capabilities is thephysical processes of sedimentation via reduced velocities and filtration byhydrophytic vegetation. The physical processes used to removecontaminants in constructed wetlands are as follows:

� Impoundment, photodegradation, and microbial action effectivelyremove oil and grease.

� Pathogens are effectively removed through sedimentation andfiltration, natural die-off, and ultraviolet degradation.

� Dissolved constituents, such as soluble organic matter, ammonia,and orthophosphorus, tend to have lower removal rates. Solubleorganic matter is largely degraded aerobically by bacteria in thewater column, plant-attached algal and bacterial associations, andmicrobes at the sediment surface.

� Ammonia is removed largely through microbial nitrification,denitrification, plant uptake, and volatilization.

� Nitrates are removed largely through denitrification and plant uptake.

� Phosphorus is removed mainly through soil sorption, which is slowand varies in relation to soil composition, and through plantassimilation and subsequent burial in the litter compartment.Consequently, phosphorus removal rates vary and are typically lessthan those of nitrogen.

� Metals are removed largely through adsorption and complexationwith organic matter. Removal rates for metals vary, but areconsistently high for lead, which is often associated with particulatematter.

The benefit of properly constructed and maintained wetlands is that theycan remove very high levels of pollutants from stormwater. Constructedwetlands can be used to reduce peak discharges of stormwater runoff aswell as to increase water quality benefits. Constructed wetlands can serve

For both

ammonia and

nitrates, denitrification is

the primary removal

mechanism. The microbial

denitrification is relatively

slow, particularly the

anaerobic steps, and

requires longer residence

times. This factor

contributes to the more

variable performance of

constructed wetlands

systems in removing these

dissolved constituents.


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a dual role by controlling stormwater pollution and providing a pleasingnatural area. Wetlands are highly valued by employees and neighbors.Therefore, wetlands are attractive as centerpieces of developments andrecreation areas and may increase property values. Also, they canrecharge groundwater, thus lessening the effects of impervious surfaces.This recharge can also subsidize the groundwater to a surficial aquifer,which can benefit local vegetation and decrease the need for irrigation.

On the downside, constructed wetlands may contribute to thermal pollutionand cause downstream warming. For these reasons, constructed wetlandsmay not be appropriate in areas where sensitive aquatic species live. Thewetlands may not be a viable option if space is a major constraint. Also,water that is ponded may create a safety hazard for children. A lastconsideration — to avoid potential restrictions, wetlands should not beconstructed in areas reserved for future expansion of facilities. Wetlandscreated from upland habitat for mitigating the loss of other wetlands asrequired by regulatory agencies generally are subject to the samerestrictions as natural wetlands.

For a while after a wetland is constructed, the wetland must be inspectedregularly to monitor hydrologic conditions and ensure that the vegetationis establishing. To ensure that the wetland continues to function properly,the vegetation must continue to be monitored, the structures maintained,and accumulated sediment periodically removed. Initially, unwantedspecies may have to be removed if a diverse hydrophytic regime is desired.Also, operators of wetlands may need to control nuisance insects, odors,and algae.

B-1.2.10 Considering Natural and Restored Wetlands

“Although the many benefits of wetlands are widely recognized ... the useof natural wetlands as treatment systems is restricted by federal law”(Fields, 1993). Most natural wetlands are considered waters of the UnitedStates and are protected from degradation under the CWA. Using naturalor restored wetlands for improving or maintaining water quality is anacceptable practice. However, pollutants should not be intentionallydiverted as the primary means of pollutant treatment. Wetlands must bepart of an integrated landscape approach, and they cannot be expected tocompensate for using insufficient or ineffective BMPs in the upgradientcontributing area. Restored wetlands are subject to the same restrictionsas unmodified natural wetlands.

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B-2 Stormwater BMPs for Construction Activities

To successfully control erosion and sedimentation caused by constructionactivities, a system of BMPs should be used that targets each stage of thefour-stage preventive erosion process. The most efficient approach, andthe first stage, is minimizing the potential sources of sediment from theoutset and stabilizing affected areas. The approach requires minimizingthe extent and duration of land disturbance and protecting surfaces oncethey are exposed. The second stage of the BMP system is controlling theamount of runoff and its ability to carry sediment by diverting incoming flowsand impeding internally generated flows. The third stage is retainingsediment that is picked up on the project site by using sediment-capturingdevices. The fourth stage is protecting streams to which stormwater isconveyed after it is captured.

On most sites, successfully controlling erosion and sedimentation requiresa combination of structural and vegetative practices. All of the stages arebetter accomplished by using advance planning and good scheduling. Theoccurrence of land disturbing activities and installation of erosion andsedimentation control measures must be coordinated to minimize waterquality impacts.

In terms of major activities, the BMP system is typically installed in reverseorder, starting with sediment-capturing devices, followed by key runoffcontrol measures and runoff conveyances, and finally clearing the landafter the minimization and capture elements are in place. Constructionoperations that generate significant off-site sediment often have failedbecause the sequence of activities was conducted in the wrong order.

Following are descriptions of BMPs for controlling erosion and sedimentduring construction of developments. They are categorized by function andidentified by the stages of the BMP system to which they apply.

B-2.1 Implementing Stage 1, Source Reduction, BMPs

B-2.1.1 Mulching

A protective blanket of straw or other plant residue, gravel, or syntheticmaterial should be applied to the soil surface to dissipate the energy ofraindrops and thus minimize their runoff, protect vegetation that is gettingestablished, reduce evaporation, insulate the soil, and suppress weedgrowth. Mulch prevents runoff immediately.

Organic mulches, such as straw, wood chips, and shredded bark, are themost effective. Straw mulch is generally used as a matrix for spreadingplant seed. Straw typically requires some kind of tacking, such as liquidemulsions or netting. Netting may also be needed to hold mulch in placeon slopes. Also, mats made from a variety of organic and synthetic

Much of the

material in this

section was

taken from the Erosion and

Sediment Control Planning

and Design Manual by

Smolen et al. (1988).


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materials are useful in establishing grass in channels and waterways, andthey promote seedling growth. Mulching assists in both the first stage,source reduction, and second stage, conveyance, of a BMP system.

B-2.1.2 Temporary Seeding

Temporary seeding is the planting of rapid-growing annual grasses, smallgrains, or legumes to initially and temporarily control erosion from disturbedsoil that will not be brought to final grade for more than approximately 1month. Seeding is facilitated by fertilizing and roughening the surface.Broadcast seed must be covered by raking or dragging chains over thearea; hydroseed mixtures are spread in a mulch matrix.

B-2.1.3 Permanent Seeding

An established perennial vegetative cover minimizes runoff from, erosionof, and sedimentation on disturbed areas. Disturbed soils typically must bescarified and amended with lime and fertilizer. Seeding should becombined with mulching. Mixtures of seed are most effective, and speciesvary with preferences, site conditions, climate, and season.

B-2.1.4 Sodding

By laying a continuous cover of grass sod, exposed areas can bepermanently stabilized. Sod is useful for immediately covering steep criticalareas and surrounding areas unsuitable for seed, such as flowways andinlets. Sod must be rolled over after being placed to ensure sufficientcontact and then watered. Sodded waterways and steep slopes may needto be netted and pegged or stapled. Sodding assists in both the first andsecond stages of a BMP system.

B-2.1.5 Adding Riprap

Riprap is a layer of stone designed to protect and stabilize areas subjectto erosion, slopes subject to seepage, or areas with poor soil structure.Riprap is used on slopes where vegetation cannot be established, onchannel slopes and bottoms, around stormwater structure inlets andoutlets, on slope drains, along stream banks, and around shorelines.Riprap should be a well-graded mixture of stone sizes, and should beunderlain by a filter blanket of gravel, sand and gravel, or synthetic materialto prevent soil from moving into or through the riprap. Riprap can be usedin all four stages of a BMP system.

B-2.1.6 Roughening the Surface

Roughening (or scarifying) a bare, sloped soil surface with horizontalgrooves or benches running across the slope helps to establish vegetativecover, improves water infiltration, and decreases runoff velocity. Groovescan be large, such as stairstep grading with small benches or terraces, orsmall, such as those made by disks, tillers, or heavy-tracked machinery,

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which should be used only on sandy noncompressible soil. Rougheningassists in both the first stage and the second stage of a BMP system.

B-2.1.7 Constructing a Temporary Graveled Construction Access

A temporary graveled area or pad located at points where vehicles enterand leave a construction site is a buffer where mud and sediment can fallor be washed from vehicles to avoid transporting them onto public roads. In addition, the area can control erosion from surface runoff and can helpcontrol dust. This measure also assists in the third stage, pollutant capture,of a BMP system.

B-2.1.8 Applying Topsoil

Applying topsoil preserves and subsequently reuses the upper biologicallyactive layer of soil to enhance final site stabilization with vegetation. Topsoilcan act as a mulch, promote the establishment of the final vegetation,increase water infiltration, and anchor more erosive subsoil. Topsoil shouldnot be used on steep slopes. Stockpiled soil should be contained withsediment barriers and temporarily seeded for stability. Surfaces that willreceive topsoil should be roughened just before the soil is spread toimprove bonding. The spread topsoil should be lightly compacted to ensuregood contact with the subsoil. The technique assists in both the first stageand the second stage of a BMP system.

B-2.2 Implementing Stage 2, Stormwater Conveyance, BMPs

B-2.2.1 Diverting Runoff

A runoff diversion is a structure that channels upslope runoff away fromerosion source areas, diverts sediment-laden runoff to appropriate traps orstable outlets, or captures runoff before it leaves the site, diverting it tolocations where it can be used or released without causing erosion orflooding. Diversions include surfaces graded to redirect sheet flow;diversion dikes or berms that force sheet flow around a protected area; andstormwater conveyances (swales, channels, gutters, drains, and sewers)that intercept, collect, and redirect runoff.

Diversions can be either temporary or permanent. Temporary diversionsinclude excavated channels with the spoil placed in a dike on thedowngradient side of the channel, and gravel placed in a ridge below anexcavated swale. Permanent diversions are used to divide a site intospecific drainage areas, should be sized to capture and carry a specificmagnitude of a storm design, and should be constructed of permanentmaterials.

An example of a permanent diversion is a water bar. A water bar is a specifickind of runoff diversion that is constructed diagonally at intervals across alinear sloping surface, such as a road or right-of-way, that is subject to


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erosion. Water bars interrupt the accumulation of erosive volumes of waterdown a slope and divert the resulting segments of flow into adjacentundisturbed areas for dissipation.

B-2.2.2 Building a Closed Drainage System

A closed drainage system collects surface water runoff from rainfall eventsfrom a specified drainage area and then conveys the runoff through a seriesof underground structures and pipes to a release or discharge point. Thesystem normally is used to collect runoff from impervious or paved surfaceareas. System inlets (or catch basins) accept stormwater runoff fromsurface areas and direct it into the system. The water flows out of the catchbasin through a pipe; a pipe from a single catch basin connects to thedischarge point or to another drain structure. Several catch basins mayconnect to a single outlet.

Structures in a closed drainage system often are made of precastreinforced concrete, concrete block, or brick. Pipe materials consist ofreinforced concrete, corrugated metal, cast iron, or plastic. Storm drainsare circular, elliptical, or rectangular. The minimum interior pipe diameteris 12 inches. Surface inlets or access points to the system are usually madeof cast iron. A closed drainage system should be designed by a qualifiedexperienced professional.

The following maintenance is necessary for a closed drainage system.Closed drainage system structures should be inspected twice each year fordebris or silt accumulation, and the accumulated materials must beremoved. Catch basins should be inspected monthly to keep their inletsclear of debris such as trash and leaves. Once a year, silt, sediment, anddebris deposited in catch basin sumps should be removed.

B-2.2.3 Using an Open Drainage System

The open, or country, drainage system collects surface water runoff fromrainfall events from a specified drainage area and then conveys the runoffthrough a series of surface structures, open channels, and overland flowpaths to a release or discharge point. Such a system may collect runoff fromimpervious or pervious surfaces. A series of shallow ditches, swales, ordepressions convey stormwater along the ground surface to progressivelylarger and deeper watercourses. The smaller, shallower parts of thesystem generally are “dry” except during rainfall events; largerwatercourses may contain water all or part of the year.

Component watercourses of an open drainage system may be clearlydefined channels or depression areas that are apparent only when surfacewater runoff accumulates. The watercourse channel may be lined withearth, vegetation, stone, half-pipe sections, or structural materials such asconcrete, asphalt, or brick. (See the typical grass and riprap channelsdepicted in Exhibit B-2.2.3.)

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All watercourses should be sloped to allow accumulated runoff to flowtoward a discharge point or into other watercourses. Water flow velocitiesshould be minimized to prevent scouring or channel erosion. Channel liningmaterials should be appropriate for the expected water flow velocities. Anopen drainage system should be designed by an experienced professional.The professional should consider the on-site soil, topography, andexpected runoff quantities, velocities, and storm events when designing thesystem.

Welded-Wire Fabric

Existing Ground

Typical Concrete Channel

Typical Riprap Channel 8 Inches ofCrushed Stone

3-Inch-DiameterWeep HoleSuitable Subbase

Existing Ground

Stone Riprap

SuitableSubbase

Exhibit B-2.2.3Schematic of Two Types of Channels in an Open Drainage System

The following maintenance is necessary for an open drainage system tooperate effectively. The component watercourses of an open drainagesystem should be inspected monthly, particularly at pedestrian- andvehicular-crossing points. Accumulated debris, such as trash, leaves, andbranches, should be removed. Deposits of silt, sand, and sediment shouldbe removed annually. Excessive plant growth of vegetated components ofthe open system should be trimmed or cut back, and weeds or brushremoved periodically during the growing season. Erosion of watercoursechannels should be stabilized as soon as possible.

B-2.2.4 Using a Catch Basin

A catch basin is a drainage structure that intercepts and collectsstormwater runoff and then conveys the water into a drainage systemthrough a pipe. Catch basins are located at low points or along water flowpaths throughout a drainage area. The surface water enters the basinthrough a metal grate. Water falls into the basin, and the suspendedsediment settles into a sump (an extension of the basin 2–3 feet below the


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outlet pipe). Water may flow directly out of the basin through a pipe orthrough an oil-gas hood, or trap, which is designed to retain oil, gas, grease,and floatable debris in the basin. The oil-gas hood improves the quality ofthe stormwater runoff collected from paved areas. A series of catch basinsmay be interconnected, connected to a drain manhole (see ExhibitB-2.2.4), or connected directly to a discharge point.

Catch basins are made of precast reinforced concrete, concrete block, orbrick, and the inlet grates and frames are metal, typically cast iron. Gratesand outlet pipes should be sized for handling the expected volume ofstormwater runoff to the basin. The design of the grate may allow for partof the inlet openings to become clogged. The location of individual catchbasins and their integration into the overall drainage system should beundertaken by an experienced professional using standard designprocedures.

Catch basin grates should be checked regularly to ensure that the inletopenings are clean of debris; all debris should be removed from the grate.Basin sumps should be inspected semiannually and cleaned annually.Basins with oil-gas hoods should be inspected frequently for oil buildup; theoutlet must not be blocked. If significant quantities of oil and gasaccumulate, sump material should be disposed of by licensed contractorsin accordance with applicable regulations.

Exhibit B-2.2.4Schematic of a Drain Manhole

Cast Iron Frame and Cover Set on Full Bed Mortar; Adjust to GradeWith Brick and Mortar

Finished Grade

StepsEccentricConeSection

RiserSection

BaseSection

Mortared“V” Openings

12-Inch CompactedGravel Borrow

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B-2.2.5 Considering a Drainage Inlet

A drainage inlet is a structure or pipe that allows stormwater runoff to enteror flow into a component of the drainage system. Drainage inlets come invarious forms; typical examples include metal frame and grates installedover a catch basin, curb inlets, headwalls (Exhibit B-2.2.5a), and flared-endsections (Exhibit B-2.2.5b). All of the inlets are designed to collectstormwater and direct its flow to an acceptable receiving area (e.g.,detention pond or wetland resource area) or to a stormwater drainagesystem. The inlet also may be used to control the volume and velocity ofthe stormwater. Exhibit B-2.2.5c is a diagram of an excavated inletsediment trap that is constructed around a storm drain inlet to preventsediment from entering the system until construction is complete and alldisturbed areas are stabilized.

Exhibit B-2.2.5aSchematic of a Concrete Headwall

8 to 30 Inchesin Diameter

A

A

1/2-InchReinforcingRods

Section A-A

Exhibit B-2.2.5bSchematic of a Flared-End Section


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Exhibit B-2.2.5cSchematic of an Excavated Inlet Sediment Trap

Sediment-Laden RunoffDepth Below Top of Inlet(Minimum of 1 Foot and Maximum of 2 Feet)

Larger ParticlesSettle Out

Stormwater WithLarger ParticlesRemoved

Drain Inlet

As Required

Weep Holes forDewatering

Common inlets consist of catch basin grates (with or without a gutter inletor throat stone), trench grates, open pipes, or culvert inlets. Each inlet mustbe designed for its specific use, although standardized design methodsmay be used by experienced professionals. The design shouldaccommodate expected water flows, prevent clogging, provide ease ofmaintenance, and provide potential backup systems in the critical areas.

Drainage inlets should be checked regularly to ensure that their flow areasremain open, because debris clogging the inlets limits or blocks theiroperation. Depending on site conditions and the type of inlet used, thefrequency of maintenance may range from monthly to annual inspections.Cleaning should be done as needed. Inlets subject to frequent blockagesmay need to be replaced with new inlets that have higher flow capacitiesin order to reduce maintenance.

B-2.2.6 Using a Grass�Lined Channel

A grass-lined channel is a swale, vegetated with grass, that is dry exceptafter storms. A grass-lined channel conveys a known volume ofconcentrated stormwater runoff, without causing erosion, to disposallocations. Typical uses of grass-lined channels include constructingroadside swales, providing outlets for runoff diversions, routingstormwater, and draining low areas. Channels should conform to naturaldrainage patterns. Channels are not intended to collect sediment, as it willreduce their conveyance capacity. The channel must be lined withgeotextile or other material if design flows are to exceed 2 feet per second.Vegetation in a channel should become established before flows areintroduced.

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B-2.2.7 Considering a Hardened Channel

A hardened channel is lined with erosion-resistant structural material, suchas riprap or paving, and is designed for conveying and safely disposing ofexcess water without causing erosion. Hardened channels are usedinstead of grass-lined channels where conditions are unsuitable for thelatter. Examples of conditions when hardened channels should be usedinclude where:

� Slopes are too steep for other types of channels.

� The flow of water is prolonged.

� Traffic could damage an area.

� Soil is easily eroded.

� Design velocities are greater than 5 feet per second.

B-2.2.8 Using a Paved Flume

A paved flume is a small concrete-lined channel for conveying water downa relatively steep slope without causing erosion. Flumes are stable,permanent elements of a stormwater system that receive drainageconveyed by diversions, other types of channel, or natural drainagewaysfrom above a relatively steep slope. Setting the flume well into the groundis important, particularly on fill slopes. A means of dissipating the energyof the water should be provided at the outlet, and an inlet bypass routeshould be available for extreme flows.

B-2.2.9 Using a Temporary Slope Drain

A temporary slope drain consists of flexible tubing or conduit that extendsfrom the top to the bottom of a cut or fill slope for temporarily conveyingconcentrated runoff down the slope face without causing erosion. Slopedrains generally are used in conjunction with diversions to convey runoffdown a slope until permanent water disposal measures can be installed.

B-2.2.10 Protecting Outlets

Outlets at the downstream terminus of closed drainage systems should beprotected. Outlet protection significantly reduces stormwater velocities toan acceptable range for the receiving soil and, therefore, the potential forscouring can be eliminated. Outlet protection devices can movestormwater runoff from a closed drainage system to an open drainagesystem (for example, drainage swales or ditches, waterways, or otherundisturbed natural land features) and prevent erosion around the outlet.

Exhibit B-2.2.10 is a diagram of stone protection for an outlet. Examples ofoutlet protection are headwalls (Exhibit B-2.2.5a), flared-end sections(Exhibit B-2.2.5b), and lined aprons, typically lined with riprap or concrete.The structures should be sized so that they adequately reduce theanticipated exit velocities of the stormwater flow to prevent the receiving


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channel from being eroded. Energy dissipaters may need to beincorporated in the design if excessive velocities and volumes of runoffcould occur.

All outlet control structures should be inspected twice a year and cleanedto remove all accumulated sediment.

Exhibit B-2.2.10Diagram of an Outlet Protection

StoneRiprap

Outlet Pipe

Flow

B-2.2.11 Considering a Level Spreader

A level spreader is an outlet designed to convert concentrated runoff tosheet flow and disperse it uniformly across a slope without causing erosion.This type of structure directs sheet flows back to the natural drainage thatwas altered by construction. This BMP is especially useful for returningsheet flows to receiving ecosystems, such as wetlands, where dispersedflow may be important for maintaining preexisting hydrologic regimes.

The receiving area of the level spreader must be uniformly sloped and mustnot be susceptible to erosion. Particular care must be taken to construct theoutlet lip completely level in stable, undisturbed soil to prevent an outletchannel from forming and subsequently causing erosion. Erosion-resistantmatting may be necessary across the outlet lip, depending on expectedflows. Alternative designs for minimizing channeling include hardenedstructures, stiff grass hedges, and segmenting discharge flows into anumber of smaller, adjacent spreaders. The level spreader often is used asan outlet for runoff diversions.

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B-2.2.12 Using an Outlet Stabilization Structure

A structure designed for controlling erosion at the outlet of a channel orconduit by reducing flow velocity and dissipating flow energy is called anoutlet stabilization structure. An outlet stabilization structure should beused where the discharge velocity of a structure exceeds the tolerances ofthe receiving channel or area. Designs will vary depending on dischargespecifics and tailwater conditions. A riprap-lined apron is the mostcommonly used design because of its relatively low cost and ease ofinstallation. Riprap stilling basins or plunge pools should be considered inlieu of aprons if overfalls exit at the ends of pipes or high flows dictate usingan excessively long apron.

B-2.3 Implementing Stage 3, Stormwater Capture, BMPs

B-2.3.1 Using a Block�and�Gravel Inlet

A block-and-gravel inlet is a type of temporary sediment control barrier. Itis formed around a storm drain inlet by using standard concrete block andgravel. The barrier is used to temporarily filter sediment from stormwaterentering the inlet. This enables the inlet to be used for conveyingstormwater before the soil of the contributing area has been stabilized. Theheight of the barrier should allow overflow into the inlet and not let overflowbypass the inlet onto unprotected lower areas. An alternative designeliminates the blocks and uses only a gravel doughnut around the inlet.This block-and-gravel inlet design can be used in combination with othertemporary inlet protection devices, such as excavation and fabric.

B-2.3.2 Considering an Excavated Drop Inlet

An excavated drop inlet, or curb inlet, is designed to trap sediment beforestormwater is discharged into an inlet. The design allows the permanentinlet to be used early in the development, before the contributing area soilhas become stabilized. Frequent maintenance is required. This BMP canalso be used with other temporary inlet protection devices, such as fabricand block and gravel.

B-2.3.3 Considering a Fabric Drop Inlet

A temporary fabric barrier placed around a drop inlet (a fabric drop inlet)helps prevent sediment from entering storm drains during constructionwhile allowing the inlet to be used for conveying stormwater. The height ofthe barrier should allow overflow into the drop inlet and not let overflowbypass the inlet onto unprotected lower areas. This BMP can be used withother temporary inlet protection devices, such as excavation and block andgravel.


141

B-2.3.4 Using a Sediment Basin or Rock Dam

A sediment basin, or a rock dam, is an earthen or rock embankment locatedto capture sediment from runoff and retain it on the construction site.Sediment basins are used where other on-site erosion control measuresdo not adequately prevent off-site sedimentation. Sediment basins aremore permanent than sediment traps and can be designed as permanentfeatures of a development. Basins are most commonly used at the outletsof diversions, channels, slope drains, or other runoff conveyances thatdischarge sediment-laden water.

Earthen basins should use barrel-and-riser discharge structures. Rockdams can be designed to discharge over the top of the embankment, wherea crest should be constructed at the low point. Smaller-sized gravel shouldline the inside face of a rock dam.

B-2.3.5 Using a Sediment Fence and a Straw Bale Barrier

A temporary sediment barrier can consist of straw bales staked to theground or filter fabric (silt fence) buried at the bottom, stretched, andsupported or anchored by posts. This acts as a temporary sediment barrierthat keeps sediment from reaching small disturbed areas by reducing thevelocity of sheet flows. Because silt fences and straw bales can causetemporary ponding, the area must have sufficient surface water storagecapacity and the design must incorporate overflow outlets.

B-2.3.6 Considering a Sediment Trap

A sediment trap is a small, temporary ponding basin formed by anembankment or excavation to capture sediment from runoff. These trapsare most commonly used at the outlets of diversions, channels, slopedrains, or other runoff conveyances that discharge sediment-laden water.The embankment must be protected from failure caused by runoff thatexceeds the design capacity. Nonerosive emergency bypass areas mustbe planned. Traps should be designed for easy access for periodicmaintenance. The pond outlet should be a stone section designed as thelow point.

B-2.3.7 Considering a Sod Drop Inlet

A sod drop inlet is a permanent grass area around the drop inlet of a stormdrain that filters sediment once the contributing area soil is stabilized. A soddrop inlet is well-suited for lawns adjacent to large buildings.

B-2.3.8 Using a Vegetated Filter Strip

A low-gradient vegetated area that filters solids from overland sheet flow,vegetated filter strips can be natural or planted. Vegetated filter strips areoften used as buffers bordering construction areas. Level spreaders areoften used to distribute runoff evenly across a filter strip. Vegetated filter

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strips should have relatively flat slopes and should be vegetated withdensely culmed, herbaceous, and erosion-resistant plant species. Themain factors influencing the efficiency of filter strips are the vegetation typeand condition; soil infiltration rate; flow depth and travel time, which areaffected by size of contributing area; and slope and length of the strip.Channeling the flows decreases the effectiveness of the vegetated filterstrips.

B-2.4 Implementing Stage 4, Stream Protection, BMPs

B-2.4.1 Stabilizing Stream Banks and Streambeds

Stream erosion is a natural process that occurs in all fluvial systems, whichalso can be induced or exaggerated by man’s activities. Numerousanthropogenic factors can contribute to stream erosion, includingmodifying channels, constructing reservoirs, and changing land uses.Whenever possible, stream management problems should be addressedin the context of an entire watershed using a systems approach to betterunderstand and accommodate natural stream processes. A systemsapproach tries to identify and address all significant contributing factors inaddition to treating the immediate symptom, for example, bank erosion.

Streams can be protected or restored either by increasing bank or bedresistance to erosion or by decreasing the energy of the water at the pointof contact with the bank or bed, for example, by deflecting or interruptingflows. A bank or bed can be stabilized through mechanical methods,revegetation, or a combination of both. To solve specific problems, thecharacteristics of the stream system as well as the availability of materialsand the cost must be considered.

Designs should match the protective capability of the treatment to theerosion potential of each vertical stream zone. For example, riprap may beneeded at the toe of a slope to prevent the flow from undercutting thestream bank, in combination with planting tree revetments to deflect flowsand protect saplings that will develop into permanent support. Researchindicates that management techniques that emulate nature and work withnatural stream processes are more successful and economical.

Further information on BMP techniques for stream bank management, soilbioengineering, or hardened structural techniques can be found athttp://h2osparc.wq.ncsu.edu/estuary/rec/strmbnks.html. The web siteincludes technical information on the following BMPs:

� Exclusion of livestock.

� No-wake zone.

� Stream bank setbacks.


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� Blanketing or mattressing:

– Branch packing.

– Brush layering.

– Composite revetment.

– Gabions.

– Live cribwall.

– Live fascines (wattling bundles).

– Live staking.

– Tree revetment.

– Vegetative cover.

� Bank armoring:

– Cribs and gabions.

– Riprap.

� Embedded flow obstructions:

– Fences.

– Jacks and posts.

– Pile dikes.

– Spur dikes and hard points.

Further information on BMP techniques for managing streambeds can befound at http://h2osparc.wq.ncsu.edu/estuary/rec/strmbeds.html. The website contains technical information on the following BMPs:

� Check dam.

� Deflectors.

� Grade stabilization structure.

� Low-head dam (weir).

B-2.4.2 Building a Temporary Stream Crossing

Temporary stream crossings consist of a bridge, a ford, or a temporarystructure installed across a stream or watercourse for short-term use byconstruction vehicles or heavy equipment. Temporary stream crossingsare intended to keep sediment out of the stream and avoid damage to thestreambed. Building stream crossings should be avoided if possible,because they are a direct source of water pollution, they can causeflooding, and they are expensive to construct.

If a temporary stream crossing is necessary, bridges are the most preferredmethod. Bridges disturb streambeds, banks, and surrounding floodplainthe least; they obstruct flow the least; and they cause the least erosion.Culvert crossings are the most common form of crossing, but can damagethe stream environment the most and block the flow the most; therefore,

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they can cause the most erosion. Fords are created by making cuts in thebanks and placing stone over filter cloth in the stream. Fords are often usedin steep areas subject to flash flooding where normal flow is shallow (lessthan 3 inches deep) or intermittent. Fords should only be used wherecrossings are infrequent and banks are low.

Temporary crossings may be flooded during peak storm events, unlikepermanent crossings. Little or no fill should be used in the floodplain inorder to minimize the potential for erosion and avoid upstream flooding.Crossing sites where the potential for erosion is low should be chosen. Ifpossible, temporary crossings should be located where permanentcrossings will be built. Where appropriate, in-stream sediment traps shouldbe installed immediately below stream crossings to reduce downstreamsedimentation. Temporary stream crossings, and bridges in particular,should be designed by a qualified engineer.

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C Acronyms and Abbreviations

�F degrees Fahrenheit

AECC area environmental compliance coordinator

BGP baseline general permit

BMP best management practice

CFR Code of Federal Regulations

CNG compressed natural gas

CWA Clean Water Act

CZMA Coastal Zone Management Act

DECC district environmental compliance coordinator

DVD Dominick V. Daniels

EA environmental assessment

EIS environmental impact statement

EMIS Environmental Management Information System

EMP Environmental Management Policy

EMS Environmental Management System

EPA Environmental Protection Agency

ERCS Environmental Recordkeeping Compliance System

ERG Environmental Resource Guide

FES facility environmental specialist

FSO facilities service office

GIS geographic information system

GMP grounds management plan

HVAC heating, ventilation, and air-conditioning

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MCL maximum contaminant level

MFO major facilities office

MI management instruction

MMO maintenance management order

MOU memorandum of understanding

MSGP multisector general permit

NCED National Center for Employee Development

NOI notice of intent

NPDES National Pollutant Discharge Elimination System

NWP nationwide wetlands permit

PCES postal career executive service

PEIS programmatic environmental impact statement

POTW publicly owned treatment works

PSTN Postal Satellite Training Network

PWS public water system

R&A repair and alteration

RIMS Records and Information Management System

SDWA Safe Drinking Water Act

SEP supplemental environmental project

SIC standard industrial code

SPCC Spill Prevention Control and Countermeasures

SSA sole-source aquifer

SWAP Source Water Assessment Program

SWPPP Stormwater Pollution Prevention Plan

UIC Underground Injection Control

USACE U.S. Army Corps of Engineers

USDW underground source of drinking water

VMF vehicle maintenance facility

VOB Voice of the Business

VOC Voice of the Customer

VOE Voice of the Employee

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D Glossary

aquifer A water-bearing layer of rock (including gravel and sand) that yieldswater in a usable quantity to a well or spring.

best managementpractices

Schedules of activities, prohibitions of practices, maintenanceprocedures, and other management practices to prevent or reducethe pollution of waters of the United States. These practices includetreatment requirements, recycling, reduction, reuse, operatingprocedures, and practices to control facility site runoff, spillage orleaks, sludge or waste disposal, or drainage from raw materialstorage.

Clean Water Act Redesignated name for the Federal Water Pollution Control Actfollowing the 1987 amendments; the national law under whichstormwater discharge is regulated.

contaminant Any physical, chemical, biological, or radiological substance ormatter that has an adverse effect on air, water, or soil.

contractor An individual or organization performing work according to acontractual agreement at a predetermined price and onpredetermined terms and who is responsible for the performance of atask in accordance with established specifications and plans.

conveyance A channel or passage that conducts or carries water, including butnot limited to any pipe, ditch, tunnel, conduit, well, discrete fissure, orcontainer.

discharge Release of a pollutant when used without qualification.

effluent The water and the quantities, rates, and concentrations of chemical,physical, biological, and other constituents that are discharged froma point source.

exempted aquifers Underground bodies of water defined in the UIC Program as aquifersthat are potential sources of drinking water though not being used assuch, and thus, are exempt from regulations barring undergroundinjection activities near them.

groundwater Water held within the interconnected openings of saturated rockbeneath the land surface.

monitoring The measurement, sometimes continuous, of water quality.

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National Pollutant DischargeElimination System

The system of permits for point source discharges to surface watersissued by EPA or by states with EPA-approved programs.

nonpoint source Any source of water pollution or pollutants not associated with adiscrete conveyance, including runoff from fields, forest lands,mining, construction activity, and saltwater intrusion.

outfall A point source at the point where a municipal separate storm sewerdischarges into waters of the United States and does not includeopen conveyances connecting two municipal separate storm sewersor pipes, tunnels, or other conveyances that connect segments of thesame stream or other waters of the United States and are used toconvey waters of the United States.

owner or operator The owner or operator of any facility or activity subject to regulationunder the NPDES program.

permit An authorization, license, or equivalent control document issued byEPA or a delegated state to implement the requirements of theNPDES process. This includes a NPDES general permit but does notinclude any permit that has not yet been the subject of EPA finalaction, such as a draft permit or a proposed permit.

pH A unit for measuring hydrogen ion concentrations. A pH of 7 indicatesa neutral water or solution. At a pH lower than 7, a solution is acidic; ata pH higher than 7, a solution is alkaline.

point source Any discernible, confined, and discrete conveyance, including butnot limited to any pipe, ditch, channel, tunnel, conduit, well, discretefissure, container, rolling stock, concentrated animal feedingoperation, or vessel or other floating craft from which pollutants are ormay be discharged. This does not include return flows from irrigatedagriculture.

pollutant Dredged soil, solid waste, incinerator residue, filter backwash,sewage, garbage, sewage sludge, munitions, chemical wastes,biological materials, radioactive materials (except those regulatedunder the Atomic Energy Act of 1954, as amended), heat, wrecked ordischarged equipment, rock, sand, cellar dirt, and industrial,municipal, and agricultural waste discharged from water.

pollution prevention The reduction of multimedia pollutants at the source and by the use ofenvironmentally sound recycling. This prevention includes allregulated toxic and nontoxic substances.

process wastewater Any water that, during manufacturing or processing, comes intodirect contact with or results from the production or use of any rawmaterial, intermediate product, finished product, by-product, orwaste product.

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public water supplier A supplier who provides piped water for human consumption to atleast 15 service connections or to 25 individuals on a regular basis.

publicly owned treatment works Any device or system that is owned by a state or municipality used inthe treatment (including recycling and reclamation) of municipalsewage or industrial wastes of a liquid nature. This includes sewers,pipes, or other conveyances only if they convey wastewater to apublicly owned treatment works providing treatment.

receiving waters Rivers, lakes, oceans, or other water courses that receive treated oruntreated wastewaters.

Resource Conservationand Recovery Act

The federal statute that regulates the generation, treatment, storage,disposal, or recycling of solid and hazardous waste.

sewer A channel or conduit that carries wastewater and stormwater runofffrom the source to a treatment plant or receiving stream — sanitarysewers carry household, industrial, and commercial wastes; stormsewers carry runoff from rain or snow; combined sewers are used forboth purposes.

site The land or water area where any facility or activity is physicallylocated or conducted, including adjacent land used in connectionwith the facility or activity.

sludge A semisolid residue from any number of air or water treatmentprocesses. Sludge can be a hazardous waste.

solvent A substance (usually liquid) capable of dissolving or dispersing oneor more other substances. Solvents include, but are not limited to, thenonspent materials listed in EPA Waste Codes F001 through F005.

storage The temporary holding of waste pending treatment or disposal.Storage methods include containers, tanks, waste piles, and surfaceimpoundments.

stormwater Rainwater runoff, snowmelt runoff, and surface runoff and drainage.

surface water Any visible stream or body of water.

treatment Any method, technique, or process, including neutralization,designed to change the physical, chemical, or biological character orcomposition of any hazardous waste so as to neutralize such wastes,to recover energy or material resources from the waste, or to rendersuch waste nonhazardous or less hazardous; safer to transport,store, or dispose of; or amenable to recovery, storage, or reduction involume.

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Underground InjectionControl Program

The program under the SDWA that regulates the use of wells to pumpfluids into the ground.

underground sourcesof drinking water

Aquifers currently being used as sources of drinking water or that arecapable of supplying a public water system. They have a totaldissolved solids concentration of 10,000 milligrams per liter or lessand are not “exempted aquifers.”

water quality standards The regulations specifying, through a combination of usedesignations and water quality criteria to protect those uses, thequality to be achieved and maintained for each surface water in thestate, as required by Section 303 of the Clean Water Act.

waters of the United States A term that refers to the following:

a. All waters in the United States that are currently used, were usedin the past, or may be susceptible to use in interstate or foreigncommerce, including waters that are subject to the ebb and flowof the tide.

b. All interstate water, including interstate wetlands.

c. All other water, such as intrastate lakes, rivers, streams(including intermittent streams), mudflats, sandflats, wetlands,sloughs, prairie potholes, wet meadows, playa lakes, or naturalponds, the use of which would affect or could affect interstate orforeign commerce, including any such waters (1) that are orcould be used by interstate or foreign travelers for recreational orother purposes, (2) from which fish or shellfish are or could betaken and sold in interstate or foreign commerce, or (3) that areused or could be used for industrial purposes by industries ininterstate commerce.

d. All impoundments of waters otherwise defined as waters of theUnited States under this definition.

e. Tributaries of waters identified in items a through f of thisdefinition.

f. The territorial sea.

g. Wetlands adjacent to waters (other than waters that arethemselves wetlands) identified in items a through f of thisdefinition.