Management Measures for Urban Areas - I. Introduction

A. What "Management Measures" Are

This chapter specifies management measures to protect coastal waters from urban sources of nonpoint pollution. "Management measures" are defined in section 6217 of the Coastal Zone Act Reauthorization Amendments of 1990 (CZARA) as economically achievable measures to control the addition of pollutants to our coastal waters, which reflect the greatest degree of pollutant reduction achievable through the application of the best available nonpoint pollution control practices, technologies, processes, siting criteria, operating methods, or other alternatives.

These management measures will be incorporated by States into their coastal nonpoint programs, which under CZARA are to provide for the implementation of management measures that are "in conformity" with this guidance. Under CZARA, States are subject to a number of requirements as they develop and implement their Coastal Nonpoint Pollution Control Programs in conformity with this guidance and will have some flexibility in doing so. The application of these management measures by States to activities causing nonpoint pollution is described more fully in Coastal Nonpoint Pollution Control Program: Program Development and Approval Guidance, published jointly by the U.S. Environmental Protection Agency (EPA) and the National Oceanic and Atmospheric Administration (NOAA).

B. What "Management Practices" Are

In addition to specifying management measures, this chapter also lists and describes management practices for illustrative purposes only. While State programs are required to specify management measures in conformity with this guidance, State programs need not specify or require the implementation of the particular management practices described in this document. However, as a practical matter, EPA anticipates that the management measures generally will be implemented by applying one or more management practices appropriate to the source, location, and climate. The practices listed in this document have been found by EPA to be representative of the types of practices that can be applied successfully to achieve the management measures. EPA has also used some of these practices, or appropriate combinations of these practices, as a basis for estimating the effectiveness, costs, and economic impacts of achieving the management measures. (Economic impacts of the management measures are addressed in a separate document entitled Economic Impacts of EPA Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters.)

EPA recognizes that there is often site-specific, regional, and national variability in the selection of appropriate practices, as well as in the design constraints and pollution control effectiveness of practices. The list of practices for each management measure is not all-inclusive and does not preclude States or local agencies from using other technically sound practices. In all cases, however, the practice or set of practices chosen by a State needs to achieve the management measure.

C. Scope of This Chapter

This chapter addresses six major categories of sources of urban nonpoint pollution that affect surface waters:

1. Runoff from developing areas;
2. Runoff from construction sites;
3. Runoff from existing development;
4. On-site disposal systems;
5. General sources (households, commercial, and landscaping); and
6. Roads, highways, and bridges.

Each category of sources is addressed in a separate section of this guidance. Each section contains (1) the management measure; (2) an applicability statement that describes, when appropriate, specific activities and locations for which the measure is suitable; (3) a description of the management measure's purpose; (4) the basis for the management measure's selection; (5) information on management practices that are suitable, either alone or in combination with other practices, to achieve the management measure; (6) information on the effectiveness of the management measure and/or of practices to achieve the measure; and (7) information on costs of the measure and/or practices to achieve the measure.

D. Relationship of This Chapter to Other Chapters and to Other EPA Documents

1. Chapter 1 of this document contains detailed information on the legislative background for this guidance, the process used by EPA to develop this guidance, and the technical approach used by EPA in the guidance.
   
2. Chapter 6 of this document contains information and management measures for addressing nonpoint source impacts resulting from hydromodification, which often occurs to accommodate urban development.
   
3. Chapter 7 of this document contains management measures to protect wetlands and riparian areas that provide a nonpoint source pollution abatement function. These measures apply to a broad variety of sources, including urban sources.
   
4. Chapter 8 of this document contains information on recommended monitoring techniques to (1) ensure proper implementation, operation, and maintenance of the management measures and (2) assess over time the success of the measures in reducing pollution loads and improving water quality.
   
5. EPA has separately published a document entitled Economic Impacts of EPA Guidance Specifying Management Measures for Sources of Nonpoint Pollution in Coastal Waters.
   
6. NOAA and EPA have jointly published guidance entitled Coastal Nonpoint Pollution Control Program: Program Development and Approval Guidance. This guidance contains details on how State Coastal Nonpoint Pollution Control Programs are to be developed by States and approved by NOAA and EPA. It includes guidance on:
   
   • The basis and process for EPA/NOAA approval of State Coastal Nonpoint Pollution Control Programs;
   • How NOAA and EPA expect State programs to provide for the implementation of management measures "in conformity" with this management measures guidance;
   • How States may target sources in implementing their Coastal Nonpoint Pollution Control Programs;
   • Changes in State coastal boundaries; and
   • Requirements concerning how States are to implement their Coastal Nonpoint Pollution Control Programs.

E. Overlap Between This Management Measure Guidance for Control of Coastal Nonpoint Sources and Storm Water Permit Requirements for Point Sources

Historically, overlaps and ambiguity have existed between programs designed to control urban nonpoint sources and programs designed to control urban point sources. For example, runoff that originates as a nonpoint source may ultimately may be channelized and become a point source. Potential confusion concerning coverage and implementation of these two programs has been heightened by Congressional enactment of two important pieces of legislation: section 402(p) of the Clean Water Act, which establishes permit requirements for certain municipal and industrial storm water discharges, and section 6217 of CZARA, which requires EPA to promulgate and States to provide for the implementation of management measures to control nonpoint pollution in coastal waters. The discussion below is intended to clarify the relationship between these two programs and describe the scope of the coastal nonpoint program and its applicability to storm water in coastal areas.

1. The Storm Water Permit Program

The storm water permit program is a two-phased program enacted by Congress in 1987 under section 402(p) of the Clean Water Act. Under Phase I, National Pollutant Discharge Elimination System (NPDES) permits are required to be issued for municipal separate storm sewers serving large or medium-sized populations (greater than 250,000 or 100,000 people, respectively) and for storm water discharges associated with industrial activity. Permits are also to be issued, on a case-by-case basis, if EPA or a State determines that a storm water discharge contributes to the violation of a water quality standard or is a significant contributor of pollutants to waters of the United States. EPA published a rule implementing Phase I on November 16, 1990.

Under Phase II, EPA is to prepare two reports to Congress that assess remaining storm water discharges; determine, to the maximum extent practicable, the nature and extent of pollutants in such discharges; and establish procedures and methods to control storm water discharges to the extent necessary to mitigate impacts on water quality. Then, EPA is to issue regulations that designate storm water discharges, in addition to those addressed in Phase I, to be regulated to protect water quality and is to establish a comprehensive program to regulate those designated sources. The program is required to establish (1) priorities, (2) requirements for State storm water management programs, and (3) expeditious deadlines.

These regulations were to have been issued by EPA not later than October 1, 1992. However, because of EPA's emphasis on Phase I, the Agency has not yet been able to complete and issue appropriate regulations as required under section 402(p). The completion of Phase II is now scheduled for October 1993.

2. Coastal Nonpoint Pollution Control Programs

As discussed more fully earlier, Congress enacted section 6217 of CZARA in late 1990 to require that States develop Coastal Nonpoint Pollution Control Programs that are in conformity with the management measures guidance published by EPA.

3. Scope and Coverage of This Guidance

EPA is excluding from coverage under this section 6217(g) guidance all storm water discharges that are covered by Phase I of the NPDES storm water permit program. Thus, EPA is excluding any discharge from a municipal separate storm sewer system serving a population of 100,000 or more; any discharge of storm water associated with industrial activity; any discharge that has already been permitted; and any discharge for which EPA or the State makes a determination that the storm water discharge contributes to a violation of a water quality standard or is a significant contributor of pollutants to waters of the United States. All of these activities are clearly addressed by the storm water permit program and therefore are excluded from the Coastal Nonpoint Pollution Control Programs.

EPA is adopting a different approach with respect to other (Phase II) storm water discharges. At present, EPA has not yet promulgated regulations that would designate additional storm water discharges, beyond those regulated in Phase I, that will be required to be regulated in Phase II. It is therefore not possible to determine at this point which additional storm water discharges will be regulated by the NPDES program and which will not. Furthermore, because of the great number of such discharges, it is likely that it would take many years to permit all of these discharges even if EPA allows for relatively expeditious State permitting approaches such as the use of general permits.

Therefore, to give effect to the Congressional intent that coastal waters receive special and expeditious attention from EPA, NOAA, and the States, storm water runoff that potentially may be ultimately covered by Phase II of the storm water permits program is subject to this management measures guidance and will be addressed by the States' Coastal Nonpoint Pollution Control Programs. Any storm water runoff that ultimately is regulated under an NPDES permit will no longer be subject to this guidance once the permit is issued.

In addition, it should be noted that some other activities are not presently covered by the NPDES permit requirements and thus would be subject to a State's Coastal Nonpoint Pollution Control Program. Most importantly, construction activities on sites that result in the disturbance of less than 5 acres, which are not currently covered by Phase I storm water application requirements, are covered by the Coastal Nonpoint Pollution Control Program. Similarly, runoff from wholesale, retail, service, or commercial activities, including gas stations, which are not covered by Phase I of the NPDES storm water program, would be subject instead to a State's Coastal Nonpoint Pollution Control Program. Further, onsite disposal systems (OSDS), which are generally not covered by the storm water permit program, would be subject to a State's Coastal Nonpoint Pollution Control Program.

Finally, EPA emphasizes that while different legal authorities may apply to different situations, the goals of the NPDES and CZARA programs are complementary. Many of the techniques and practices used to control storm water are equally applicable to both programs. Yet, the programs do not work identically. In the interest of consistency and comprehensiveness, States have the option to implement the CZARA section 6217(g) management measures throughout the State's 6217 management area as long as the NPDES storm water requirements continue to be met by Phase I sources in that area.

F. Background

The prevention and control of urban nonpoint source pollution in coastal areas pose a distinctive challenge to the environmental manager. Increasing water quality problems and degraded coastal resources point to the need for comprehensive solutions to protect and enhance coastal water quality. This chapter presents a framework for preventing and controlling urban nonpoint sources of pollution.

Urban runoff management requires that a number of objectives be pursued simultaneously. These objectives include the following:

• Protection and restoration of surface waters by the minimization of pollutant loadings and negative impacts resulting from urbanization;
• Protection of environmental quality and social well-being;
• Protection of natural resources, e.g., wetlands and other important aquatic and terrestrial ecosystems;
• Minimization of soil erosion and sedimentation problems;
• Maintenance of the predevelopment hydrologic conditions;
• Protection of ground-water resources;
• Control and management of runoff to reduce/prevent flooding; and
• Management of aquatic and riparian resources for active and passive recreation (APWA, 1981).

1. Urbanization and Its Impacts

Urbanization first occurred in coastal areas and this historical trend continues. Approximately 80 percent of the Nation's population lives in coastal areas. The negative impacts of urbanization on coastal and estuarine waters has been well documented in a number of sources, including the Nationwide Urban Runoff Program (NURP) and the States .305(b) and .319 reports.

During urbanization, pervious spaces, including vegetated and open forested areas, are converted to land uses that usually have increased areas of impervious surface, resulting in increased runoff volumes and pollutant loadings. While urbanization may enhance the use of property under a wide range of environmental conditions (USEPA, 1977), urbanization typically results in changes to the physical, chemical, and biological characteristics of the watershed. Vegetative cover is stripped from the land and cut-and-fill activities that enhance the development potential of the land occur. For example, natural depressions that temporarily pond water are graded to a uniform slope, increasing the volume of runoff during a storm event (Schueler, 1987). As population density increases, there is a corresponding increase in pollutant loadings generated from human activities. These pollutants typically enter surface waters via runoff without undergoing treatment.

a. Changes in Hydrology

As urbanization occurs, changes to the natural hydrology of an area are inevitable. Hydrologic and hydraulic changes occur in response to site clearing, grading, and the addition of impervious surfaces and maintained landscapes (Schueler, 1987). Most problematic are the greatly increased runoff volumes and the ensuing erosion and sediment loadings to surface waters that accompany these changes to the landscape. Uncontrolled construction site sediment loads have been reported to be on the order of 35 to 45 tons per acre per year (Novotny and Chesters, 1981; Wolman and Schick, 1967; Yorke and Herb, 1976, 1978). Loadings from undisturbed woodlands are typically less than 1 ton per year (Leopold, 1968).

Hydrological changes to the watershed are magnified after construction is completed. Impervious surfaces, such as rooftops, roads, parking lots, and sidewalks, decrease the infiltrative capacity of the ground and result in greatly increased volumes of runoff. Elevated flows also necessitate the construction of runoff conveyances or the modification of existing drainage systems to avoid erosion of streambanks and steep slopes. Changes in stream hydrology resulting from urbanization include the following (Schueler, 1987):

• Increased peak discharges compared to predevelopment levels (Leopold, 1968; Anderson, 1970);
• Increased volume of urban runoff produced by each storm in comparison to predevelopment conditions;
• Decreased time needed for runoff to reach the stream (Leopold, 1968), particularly if extensive drainage improvements are made;
• Increased frequency and severity of flooding;
• Reduced streamflow during prolonged periods of dry weather due to reduced level of infiltration in the watershed; and
• Greater runoff velocity during storms due to the combined effects of higher peak discharges, rapid time of concentration, and the smoother hydraulic surfaces that occur as a result of development.

In addition, greater runoff velocities occur during spring snowmelts and rain-on-snow events in suburban watersheds than in less impervious rural areas (Buttle and Xu, 1988). Major snowmelt events can produce peak flows as large as 20 times initial flow runoff rates for urban areas (Pitt and McLean, 1992).

Figures 4-1 and 4-2 illustrate the changes in runoff characteristics resulting from an increasing percentage of impervious areas. Other physical characteristics of aquatic systems that are affected by urbanization include the total volume of watershed runoff baseflow, flooding frequency and severity, channel erosion and sediment generation, and temperature regime (Klein, 1985).

b. Water Quality Changes

Urban development also causes an increase in pollutants. The pollutants that occur in urban areas vary widey, from common organic material to highly toxic metals. Some pollutants, such as insecticides, road salts, and fertilizers, are intentionally placed in the urban environment. Other pollutants, including lead from automobile exhaust and oil drippings from trucks and cars, are the indirect result of urban activities (USEPA, 1977).

Many researchers have linked urbanization to degradation of urban waterways (e.g., Klein, 1985, Livingston and McCarron, 1992, Schueler, 1987). The major pollutants found in runoff from urban areas include sediment, nutrients, oxygen-demanding substances, road salts, heavy metals, petroleum hydrocarbons, pathogenic bacteria, and viruses. Livingston and McCarron (1992) concluded that urban runoff was the major source of pollutants in pollutant loadings to Florida's lakes and streams. Table 4-1 illustrates examples of pollutant loadings from urban areas. Table 4-2 describes potential sources of urban runoff pollutants.

2. Nonpoint Source Pollutants and Their Impacts

The following discussion identifies the principal types of pollutants found in urban runoff and describes their potential adverse effects (USEPA, 1990).

Sediment. Suspended sediments constitute the largest mass of pollutant loadings to surface waters. Sediment has both short- and long-term impacts on surface waters. Among the immediate adverse impacts of high concentrations of sediment are increased turbidity, reduced light penetration and decreases in submerged aquatic vegetation (SAV) (Chesapeake Implementation Committee, 1988), reduced prey capture for sight-feeding predators, impaired respiration of fish and aquatic invertebrates, reduced fecundity, and impairment of commercial and recreational fishing resources. Heavy sediment deposition in low-velocity surface waters may result in smothered benthic communities/reef systems (CRS, 1991), increased sedimentation of waterways, changes in the composition of bottom substrate, and degradation of aesthetic value. The primary cause of coral reef degradation in coastal areas is attributed to land disturbances and dredging activities due to urban development (Rogers, 1990). Additional chronic effects may occur where sediments rich in organic matter or clay are present. These enriched depositional sediments may present a continued risk to aquatic and benthic life, especially where the sediments are disturbed and resuspended.

Nutrients. The problems resulting from elevated levels of phosphorus and nitrogen are well known and are discussed in detail in Chapter 2 (agriculture). Excessive nutrient loading to marine ecosystems can result in eutrophication and depressed dissolved oxygen (DO) levels due to elevated phytoplankton populations. Eutrophication-induced hypoxia and anoxia have resulted in fish kills and widespread destruction of benthic habitats (Harper and Gullient, 1989). Surface algal scum, water discoloration, and the release of toxins from sediment may also occur. Species composition and size structure for primary producers may be altered by increased nutrient levels (Hecky and Kilham, 1988; GESAMP, 1989; Thingstad and Sakshaug, 1990).

Occurrences of eutrophication have been frequent in several coastal embayments along the northeast coast (Narragansett and Barnegat Bays), the Gulf Coast (Louisiana and Texas), and the West Coast (California and Washington) (NOAA, 1991). High nitrate concentrations have also been implicated in blooms of nuisance algae in Newport Bay, California (NRC, 1990b). Nutrient loadings in Louisiana coastal waters have decreased productivity, increased hypoxic events, and decreased fisheries yields (NOAA, 1991).

Oxygen-Demanding Substances. Proper levels of DO are critical to maintaining water quality and aquatic life. Decomposition of organic matter by microorganisms may deplete DO levels and result in the impairment of the waterbody. Data have shown that urban runoff with high concentrations of decaying organic matter can severely depress DO levels after storm events (USEPA, 1983). The NURP study found that oxygen-demanding substances can be present in urban runoff at concentrations similar to secondary treatment discharges.

Pathogens. Urban runoff typically contains elevated levels of pathogenic organisms. The presence of pathogens in runoff may result in waterbody impairments such as closed beaches, contaminated drinking water sources, and shellfish bed closings. OSDS-related pathogen contamination has been implicated in a number of shellfish bed closings. Table 4-3 shows the adverse impacts of septic systems and urban runoff on shellfish beds, resulting in closure. This problem may be especially prevalent in areas with porous or sandy soils.

Road Salts. In northern climates, road salts can be a major pollutant in urban areas. Klein (1985) reported on several studies by various authors of road salt contamination in lakes and streams and cases where well contamination had been attributed to road salts in New England. Snow runoff produces high salt/chlorine concentrations at the bottom of ponds, lakes, and bays. Not only does this condition prove toxic to benthic organisms, but it also prevents crucial vertical spring mixing (Bubeck et al., 1971; Hawkins and Judd, 1972).

Hydrocarbons. Petroleum hydrocarbons are derived from oil products, and the source of most such pollutants found in urban runoff is vehiclesÄauto and truck engines that drip oil. Many do-it-yourself auto mechanics dump used oil directly into storm drains (Klein, 1985). Concentrations of petroleum-based hydrocarbons are often high enough to cause mortalities in aquatic organisms.

Oil and grease contain a wide variety of hydrocarbon compounds. Some polynuclear aromatic hydrocarbons (PAHs) are known to be toxic to aquatic life at low concentrations. Hydrocarbons have a high affinity for sediment, and they collect in bottom sediments where they may persist for long periods of time and result in adverse impacts on benthic communities. Lakes and estuaries are especially prone to this phenomenon.

Heavy Metals. Heavy metals are typically found in urban runoff. For example, Klein (1985) reported on a study in the Chesapeake Bay that designated urban runoff as the source for 6 percent of the cadmium, 1 percent of the chromium, 1 percent of the copper, 19 percent of the lead, and 2 percent of the zinc.

Heavy metals are of concern because of toxic effects on aquatic life and the potential for ground-water contamination. Copper, lead, and zinc are the most prevalent NPS pollutants found in urban runoff. High metal concentrations may bioaccumulate in fish and shellfish and impact beneficial uses of the affected waterbody.

Toxics. Many different toxic compounds (priority pollutants) have been associated with urban runoff. NURP studies (USEPA, 1983) indicated that at least 10 percent of urban runoff samples contained toxic pollutants.

a. Pollutant Loading

Nonpoint source pollution has been associated with water quality standard violations and the impairment of designated uses of surface waters (Davenport, 1990). The 1990 Report to Congress on .319 of the Clean Water Act reported that:

• Siltation and nutrients are the pollutants most responsible for nonpoint source impacts to the Nation's surface waters, and
• Wildlife and recreation, (in particular, swimming, fishing, and shellfishing) are the uses most affected by nonpoint source pollution.

The pollutants described previously can have a variety of impacts on coastal resources. Examples of waterbodies that have been adversely impacted by nonpoint source pollution are varied.

• The Miami River and Biscayne Bay in Florida have experienced loss of habitat, loss of recreational and commercial fisheries, and decrease in productivity partly as the result of urban runoff (SFWMD, 1988).
  
• Shellfish beds in Port Susan, Puget Sound, Washington, have been declared unsafe for the commercial harvest of shellfish in part because of bacterial contamination from onsite disposal systems (USEPA, 1991).
  
• Impairment due to toxic pollution from urban runoff continues to be a problem in the southern part of San Francisco Bay (USEPA, 1992).
  
• Nonpoint sources of pollution have been implicated in degradation of water quality in Westport River, Massachusetts, a tributary of Buzzards Bay. High concentrations of coliform bacteria have been observed after rainfall events, and shellfish bed closures in the river have been attributed to loadings from surface runoff and septic systems (USEPA, 1992).
  
• In Brenner Bay, St. Thomas, U.S. Virgin Islands, populations of corals and shellfish and marine habitat have been damaged due to increased nutrient and sediment loadings. After several years of rapid urban development, less than 10 percent of original grass beds remain as a result of sediment shoaling, eutrophication, and algae blooms (Nichols and Towle, 1977).
  

b. Other Impacts

Other impacts not related to a specific pollutant can also occur as a result of urbanization. Temperature changes result from increased flows, removal of vegetative cover, and increases in impervious surfaces. Impervious surfaces act as heat collectors, heating urban runoff as it passes over the impervious surface. Recent data indicate that intensive urbanization can increase stream temperature as much as 5 to 10 degrees Celsius during storm events (Galli and Dubose, 1990). Thermal loading disrupts aquatic organisms that have finely tuned temperature limits. Salinity can also be affected by urbanization.

Freshwater inflows due to increased runoff can impact estuaries, especially if they occur in pulses, disrupting the natural salinity of an area. Increased impervious surface area and the presence of storm water conveyance systems commonly result in elevated peak flows in streams during and after storm events. These rapid pulses or influxes of fresh water into the watershed may be 2 to 10 times greater than normal (ABAG, 1991) This may lead to a decrease in the number of aquatic organisms living in the receiving waters (McLusky, 1989).

The alteration of natural hydrology due to urbanization and the accompanying runoff diversion, channelization, and destruction of natural drainage systems have resulted in riparian and tidal wetland degradation or destruction. Deltaic wetlands have also been impacted by changes in historic sediment deposition rates and patterns. Hydromodification projects designed to prevent flooding may reduce sedimentation rates and decrease marsh aggradation, which would normally offset erosion and apparent changes in sea level within the delta (Cahoon et al., 1983).

3. Opportunities

This chapter was organized to parallel the development process to address the prevention and treatment of nonpoint source pollution loadings during all phases of urbanization. (NOTE: The control of nonpoint source pollution requires the use of two primary strategies: the prevention of pollutant loadings and the treatment of unavoidable loadings. The strategy in this chapter relies primarily on the watershed approach, which focuses on pollution prevention or source reduction practices. While treatment options are an integral component of this chapter, a combination of pollution prevention and treatment practices is favored because planning, design, and education practices are generally more effective, require less maintenance, and are more cost-effective in the long term.)

The major opportunities to control NPS loadings occur during the following three stages of development: the siting and design phase, the construction phase, and the postdevelopment phase. Before development occurs, land in a watershed is available for a number of pollution prevention and treatment options, such as setbacks, buffers, or open space requirements, as well as wet ponds or constructed urban runoff wetlands that can provide treatment of the inevitable runoff and associated pollutants. In addition, siting requirements/restrictions and other land use ordinances, which can be highly effective, are more easily implemented during this period. After development occurs, these options may no longer be practicable or cost-effective. Management Measures II.A through II.C address the strategies and practices that can be used during the initial phase of the urbanization process.

The control of construction-related sediment loadings is critical to maintaining water quality. The implementation of proper erosion and sediment control practices during the construction stage can significantly reduce sediment loadings to surface waters. Management Measures II.A and II.B address construction-related practices.

After development has occurred, lack of available land severely limits the implementation of cost-effective treatment options. Management Measure VI.A focuses on improving controls for existing surface water runoff through pollution prevention to mitigate nonpoint sources of pollution generated from ongoing domestic and commercial activities.

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