Urban Subwatershed Restoration Manual Series Manual 8

Urban Subwatershed Restoration Manual Series
Pollution
81 Source
Control
Practices
Version 2.0
Februar
ebruaryy 2005
Manual 8
Urban Subwatershed Restoration Manual No. 8
POLLUTION SOURCE
CONTROL PRACTICES
Version 2.0
Prepared by:
Tom Schueler, Chris Swann, Tiffany Wright and Stephanie Sprinkle

Center for Watershed Protection
8390 Main Street, 2nd Floor
Ellicott City, MD 21043
www.cwp.org
www.stormwatercenter.net
Prepared for:
Office of Water Management

U.S. Environmental Protection Agency
Washington, D.C.
February 2005
Copyright ©2005 by the Center for Watershed Protection.

Material may be quoted provided credit is given.
Printed in the United States of America on recycled paper.
Foreword
Foreword
We all live and work in a watershed. Special thanks are extended to three external
Collectively, our daily behaviors can have a reviewers whose comments ands insights on an
profound influence on water quality. Quite earlier draft greatly improved the utility of this
simply, we are either generating pollution or manual. These experts included Charlie
preventing it, although most people may not MacPherson, Director of Watershed Services at
fully understand how. The process for educating Tetra Tech, Inc. (Fairfax, VA); Neal Shapiro,
people about subwatershed pollution sources is Administrative Analyst for the City of Santa
the main theme of this manual. The manual Monica (CA); and Kathy Shay, Water Quality
shows how each of us can prevent pollution Education Manager for the City of Austin (TX).
from our home or work place, and how these
acts of personal stewardship can improve water The Center staff team that contributed to this
quality when multiplied many times over. manual includes Ted Brown, Tiffany Wright,
Chris Swann, and Stephanie Sprinkle. We are
Source control practices are a relatively new also grateful to Tiffany Wright, Sarah
approach to restore urban watersheds. Much Weammert, Neely Law, Heather Holland, and
more needs to be learned about the best ways to Lauren Lasher for their able assistance in
control pollution sources, promote stewardship editing, proofing and otherwise helping to
in neighborhoods and adopt pollution prevention produce this manual.
practices in the workplace. This manual presents
a new framework for targeting pollution source This manual was produced under a cooperative
control at the subwatershed level. We expected agreement with US EPA Office of Water CP-
that this manual would be adjusted over time; 82981501. Thanks are extended to our EPA
therefore, we are pleased to release this manual project officer, Robert Goo, for his patience,
in Version 2.0, in response to user feedback and insights and flexibility during the two years it
new resources. And remember, watershed took to produce this manual series.
stewardship starts with you. As you read the
manual, pick a few behaviors worth practicing in
your home or workplace to reduce pollution, and Sincerely,
teach them to your friends and neighbors.
Tom Schueler
Center for Watershed Protection
Urban Subwatershed Restoration Manual 8 i

Foreword
ii Urban Subwatershed Restoration Manual 8

Foreword
About the Restoration Manual Series
This is the eighth manual in an 11 manual series that The next seven manuals provide specific guidance on
provides detailed guidance on how to repair urban how to identify, design, and construct the seven
watersheds. The entire series of manuals was written major groups of watershed restoration practices. Each
by the Center for Watershed Protection to organize of these “practice” manuals describes the range of
the enormous amount of information needed to techniques used to implement each practice, and
restore small urban watersheds into a format that can provides detailed guidance on subwatershed
easily be accessed by watershed groups, municipal assessment methods to find, evaluate and rank
staff, environmental consultants and other users. The candidate sites. In addition, each manual provides
contents of the manuals are organized as follows. extensive references and links to other useful
resources and websites to design better restoration
Manual 1: An Integrated practices. The seven manuals are organized as
follows:
Approach to Restore Small
Urban Watersheds Manual 3: Storm Water Retrofit
The first manual introduces the basic concepts and
Practices
techniques of urban watershed restoration, and sets
The third manual focuses on storm water retrofit
forth the overall framework we use to evaluate
practices that can capture and treat storm water
subwatershed restoration potential. The manual
runoff before it is delivered to the stream. The
emphasizes how past subwatershed alterations must
manual describes both off-site storage and on-site
be understood in order to set realistic expectations for
retrofit techniques that can be used to remove storm
future restoration. Toward this end, the manual
water pollutants, minimize channel erosion, and help
presents a simple subwatershed classification system
restore stream hydrology. The manual then presents
to define expected stream impacts and restoration
guidance on how to assess retrofit potential at the
potential. Next, the manual defines seven broad
subwatershed level, including methods to conduct a
groups of restoration practices, and describes where
retrofit inventory, assess candidate sites, screen for
to look in the subwatershed to implement them. The
priority projects, and evaluate their expected
manual concludes by presenting a condensed
cumulative benefit. The manual concludes by
summary of a planning approach to craft effective
offering tips on retrofit design, permitting,
subwatershed restoration plans.
construction, and maintenance considerations in a
series of 17 retrofit profile sheets.
Manual 2: Methods to Develop
Restoration Plans for Small Manual 4: Urban Stream Repair
Urban Watersheds Practices
The second manual contains detailed guidance on The fourth manual concentrates on practices used to
how to put together an effective plan to restore urban enhance the appearance, stability, structure, or
subwatersheds. The manual outlines a practical, step- function of urban streams. The manual offers
by-step approach to develop, adopt and implement a guidance on three broad approaches to urban stream
subwatershed plan in your community. Within each repair – stream cleanups, simple repairs, and more
step, the manual describes 32 different desktop sophisticated comprehensive repair applications. The
analysis, field assessment, and stakeholder manual emphasizes the powerful and relentless forces
involvement methods used to make critical at work in urban streams, which must always be
restoration management decisions. carefully evaluated in design. Next, the manual
presents guidance on how to set appropriate
restoration goals for your stream, and how to choose
the best combination of stream repair practices to
meet them.
Urban Subwatershed Restoration Manual 8 iii

Foreword
The manual also outlines methods to assess stream Manual 7: Watershed Forestry
repair potential at the subwatershed level, including
basic stream reach analysis, more detailed project Practices
investigations, and priority screenings. The manual
concludes by offering practical advice to help design, The seventh manual reviews subwatershed practices
permit, construct and maintain stream repair practices that can improve the quality of upland pervious areas,
in a series of more than 30 profile sheets. which include techniques to reclaim land, revegetate
upland areas, and restore natural area remnants.
When broadly applied, these techniques can improve
Manual 5: Riparian the capacity of these lands to absorb rainfall and
sustain healthy plant growth and cover. This brief
Management Practices manual also outlines methods to assess the potential
for these techniques at both the site and subwatershed
The fifth manual examines practices to restore the
scale.
quality of forests and wetlands within the remaining
stream corridor and/or flood plain. It begins by
describing site preparation techniques that may be Manual 8: Pollution Source
needed to make a site suitable for planting, and then Control Practices
profiles four planting techniques for the riparian
zone, based on its intended management use. The Pollution source control practices reduce or prevent
manual presents several methods to assess riparian pollution from residential neighborhoods or storm
restoration potential at the subwatershed level, water hotspots. Thus, the topic of the eighth manual
including basic stream corridor analysis, detailed site is a wide range of stewardship and pollution
investigations, and screening factors to choose prevention practices that can be employed in
priority reforestation projects. The manual concludes subwatersheds. The manual presents several methods
by reviewing effective site preparation and planting to assess subwatershed pollution sources in order to
techniques in a series of eight riparian management develop and target education and/or enforcement
profile sheets. efforts that can prevent or reduce polluting behaviors
and operations. The manual outlines more than 100
different “carrot” and “stick” options that can be used
Manual 6: Discharge Prevention for this purpose. Lastly, the manual presents profile
Practices sheets that describe 21 specific stewardship practices
for residential neighborhoods, and 15 pollution
The sixth manual covers practices used to prevent the prevention techniques for control of storm water
entry of sewage and other pollutant discharges into hotspots.
the stream from pipes and spills. The manual
describes a variety of techniques to find, fix and Manual 9: Municipal Practices
prevent these discharges that can be caused by illicit
sewage connections, illicit business connections, and Programs
failing sewage lines, or industrial/transport spills.
The manual also briefly presents desktop and field The ninth manual focuses on municipal programs
methods to assess the severity of illicit discharge that can directly support subwatershed restoration
problems in your subwatershed. Lastly, the manual efforts. The five broad areas include improved street
profiles different “forensic” methods to detect and fix and storm drain maintenance practices,
illicit discharges. Manual 6 is also known as the development/redevelopment standards, stewardship
Illicit Discharge Detection and Elimination of public land, delivery of municipal stewardship
Guidance Manual: a guidance manual for program services, and watershed education and enforcement.
development and technical assessment, and is This last “practice” manual presents guidance on how
referenced as Brown et al., 2004, throughout this municipalities can use these five programs to
manual. promote subwatershed restoration goals. The manual
also contains a series of profile sheets that
recommends specific techniques to implement
effective municipal programs.
iv Urban Subwatershed Restoration Manual 8

Foreword
The series concludes with two user manuals that Manual 11: The Unified
explain how to perform field assessments to discover
subwatershed restoration potential in the stream Subwatershed and Site
corridor and upland areas. Reconnaissance (USSR): A
User’s Manual
Manual 10: The Unified Stream
Assessment (USA): A User’s The last manual examines pollution sources and
restoration potential within upland areas of urban
Manual subwatersheds. The manual provides detailed
guidance on how to perform each of its four
The Unified Stream Assessment (USA) is a rapid
components: the Neighborhood Source Assessment
technique to locate and evaluate problems and
(NSA), Hotspot Site Investigation (HSI), Pervious
restoration opportunities within the urban stream
Area Assessment (PAA) and the analysis of Streets
corridor. The tenth manual is a user’s guide that
and Storm Drains (SSD). Together, these rapid
describes how to perform the USA, and interpret the
surveys help identify upland restoration projects and
data collected to determine the stream corridor
source control to consider when devising
restoration potential for your subwatershed.
subwatershed restoration plans.
Individual manuals in the series are scheduled for

delivery by 2006, and each will be initially available
for free downloading, after which they can be
ordered online or as hard copies from the Center for a
nominal charge. Be sure to check our website,
www.cwp.org, to find out when each manual will be
available and how it can be accessed.
Urban Subwatershed Restoration Manual 8 v

Table of Contents
vi Urban Subwatershed Restoration Manual 8

Table of Contents
Table of Contents
Foreword................................................................................................................................................... i
About the Restoration Manual Series ........................................................................................................ iii
Table of Contents...................................................................................................................................... vii
Introduction............................................................................................................................................... 1
Organization of the Manual ...................................................................................................................... 1
Chapter 1: Basics of Neighborhood Source Control ........................................................................... 3
1.1 Pollution Source Areas in the Neighborhoods .................................................................... 3

1.2 Screening for Pollutants of Concern................................................................................... 5
1.3 Neighborhood Stewardship Practices ................................................................................ 6
1.4 Carrots and Sticks to Promote Stewardship ........................................................................ 7
1.5 Municipal Storm Water Education Opportunities ............................................................... 10
Chapter 2: Basics of Storm Water Hotspots .......................................................................................... 13
2.1 Classification of Storm Water Hotspots .............................................................................. 13

2.2 Six Common Hotspot Operations........................................................................................ 15
2.3 Pollutants Generated by Hotspots ...................................................................................... 17
2.4 Hotspot Pollution Prevention Practices ............................................................................... 18
2.5 Sticks and Carrots to Implement Pollution Prevention......................................................... 20
2.6 Regulations Governing Storm Water Hotspots .................................................................... 22
Chapter 3: Finding Pollutant Sources In Your Subwatershed ................................................................ 25
3.1 The Subwatershed Context for Pollution Source Control..................................................... 25

3.2 Neighborhood Source Assessment (NSA)............................................................................ 25
3.3 Hotspot Site Investigation (HSI)............................................................................................ 27
3.4 Suspicious Discharge Investigation .................................................................................... 27
Chapter 4: Subwatershed Source Control Plans .................................................................................. 29
4.1 Basics of a Subwatershed Source Control Plan .................................................................. 29

4.2 An Example Source Control Plan for Stewardship Branch ................................................. 44
4.3 Source Controls: Apply on a Subwatershed or Community-Wide Basis? ............................ 48
Chapter 5: Neighborhood Stewardship Profile Sheets........................................................................... 49
N-1 Reduced Fertilizer Use ......................................................................................................... 51

N-2 Reduced Pesticide Use ....................................................................................................... 55
N-3 Xeriscaping......................................................................................................................... 59
N-4 Natural Landscaping .......................................................................................................... 63
N-5 Tree Planting ....................................................................................................................... 65
N-6 Yard Waste Composting ..................................................................................................... 69
N-7 Soil Reclamation ................................................................................................................. 71
N-8 Soil Erosion Repair ............................................................................................................... 73
Urban Subwatershed Restoration Manual 8 vii

Table of Contents
N-9 Septic System Maintenance ............................................................................................ 75

N-10 Safe Pool Discharges ........................................................................................................ 79
N-11 Safe Car Washing ............................................................................................................. 81
N-12 Driveway Sweeping .......................................................................................................... 83
N-13 Safe De-icer Use................................................................................................................ 85
N-14 Household Hazardous Waste Collection ........................................................................... 87
N-15 Car Fluid Recycling........................................................................................................... 89
N-16 Downspout Disconnection ................................................................................................ 91
N-17 Single Lot Controls............................................................................................................. 95
N-18 Pet Waste Pickup............................................................................................................... 97
N-19 Storm Water Practice Maintenance .................................................................................. 99
N-20 Bufferscaping.................................................................................................................... 103
N-21 Storm Drain Marking.......................................................................................................... 105
Chapter 6: Hotspot Pollution Prevention Profile Sheets ........................................................................ 109
H-1 Vehicle Maintenance and Repair..................................................................................... 111

H-2 Vehicle Fueling.................................................................................................................. 113
H-3 Vehicle Washing ............................................................................................................... 117
H-4 Vehicle Storage................................................................................................................. 121
H-5 Loading and Unloading .................................................................................................... 123
H-6 Outdoor Storage ............................................................................................................... 125
H-7 Spill Prevention and Response .......................................................................................... 129
H-8 Dumpster Management ................................................................................................... 133
H-9 Building Repair and Remodeling ...................................................................................... 137
H-10 Building Maintenance....................................................................................................... 141
H-11 Parking Lot Maintenance .................................................................................................. 143
H-12 Turf Management.............................................................................................................. 145
H-13 Landscaping/Grounds Care ............................................................................................. 149
H-14 Swimming Pool Discharges ............................................................................................... 153
H-15 Unique Hotspot Operations ............................................................................................... 155
References................................................................................................................................................ R-1
Appendix A: Stormwater Hotspots and Potential Discharge Generators ................................................... A-1
List of Tables
Table 1. Key Behaviors Within Neighborhood Source Areas................................................................ 4

Table 2. Comparison of Pollutant Contribution from Various Residential Behaviors............................. 6
Table 3. Key Neighborhood Stewardship Practices ............................................................................ 7
Table 4. Carrot and Stick Strategies for Neighborhood Source Control. ............................................. 7
Table 5. NPDES MS4 Storm Water Permit Program: What It Means....................................................... 11
Table 6. Polluting Activities Associated With Common Hotspot Operations. ........................................ 16
Table 7. Storm Water Pollutants Associated With Common Hotspot Operations.................................. 18
Table 8. Pollution Prevention Practices for Hotspot Operations. .......................................................... 19
Table 9. Stick and Carrot Strategies for Pollution Prevention. .............................................................. 20
Table 10. Industrial NPDES Storm Water Permits: What They Really Mean.............................................. 23
Table 11. NSA Factors Assessed and Corresponding Neighborhood Stewardship Practice.................. 26
Table 12. HSI Assessment Factors and Corresponding Pollution Prevention Practices........................... 28
Table 13. NSA and HSI Pollutant Indicators in a Subwatershed. ............................................................ 31
Table 14. Comparing Carrot and Stick Strategies to Promote Neighborhood Stewardship Practices ... 34
viii Urban Subwatershed Restoration Manual 8

Table of Contents
Table 15. Comparing Stick and Carrot Strategies to Promote Pollution Prevention Practices ............... 34
Table 16. Range of Outreach Techniques. ........................................................................................... 36
Table 17. 92 Tools to Promote Better Neighborhood Stewardship. ........................................................ 37
Table 18. 22 Tools to Promote Hotspot Pollution Prevention Practices. .................................................. 39
Table19. Unit Costs for Outreach Techniques....................................................................................... 40
Table 20. Unit Costs for Neighborhood Stewardship Practices. ............................................................. 40
Table 21. Unit Costs for Hotspot Pollution Prevention Practices.............................................................. 41
Table 22. Example of NSA Metrics Used to Screen Neighborhoods....................................................... 45
Table 23. Subwatershed Source Control Budget for Stewardship Branch.............................................. 47
List of Figures
Figure 1. Four Pollution Source Areas in Residential Neighborhoods..................................................... 4

Figure 2. Five Types of Storm Water Hotspots ........................................................................................ 14
Figure 3. Six Common Operations to Assess at Potential Storm Water Hotspots..................................... 16
Figure 4. Examples of Common Pollution Prevention Practices at Hotspots .......................................... 19
Figure 5. USSR Assessment Field Forms .................................................................................................. 26
Figure 6. Steps to Prepare a Source Control Plan ................................................................................. 30
Figure 7. Example of an NSA Severity Index Map to Target Source Control .......................................... 32
Figure 8. Aerial Photo of Stewardship Branch........................................................................................ 44
List of Acronyms and Abbreviations
The following list describes the many acronyms and abbreviations used in the manual to described the
methods, practices, models used to restore small urban watersheds.
DPI: Discharge Prevention Investigation

HHW: Household Hazardous Waste
HSI: Hotspot Site Investigation
IPM: Integrated Pest Management
MTBE: Methyl tertiary butyl ether – an ether oxygenate blended into gasoline
MS4: Municipal Separate Storm Sewer System
NSA: Neighborhood Source Assessment
NOI: Notice of Intent
NPDES: National Pollutant Discharge Elimination System
SARA: Superfund Amendments and Reauthorization Act
SCP: Source Control Plan
SIC: Standard Industrial Classification
STP: Stormwater Treatment Practice
SWPPP: Storm Water Pollution Prevention Plan
USSR: Unified Subwatershed and Site Reconnaissance
Urban Subwatershed Restoration Manual 8 ix

Table of Contents
x Urban Subwatershed Restoration Manual 8

Introduction
Introduction
This manual describes how pollutants can be four major pollution source areas within
reduced or minimized by controlling two neighborhoods, the specific pollutants they
primary pollution source areas in a generate, and the corresponding neighborhood
subwatershed: residential neighborhoods and stewardship practices that reduce them. The next
storm water hotspots. Neighborhoods generate part looks at strategies for neighborhood source
pollution from common residential behaviors controls, and profiles the range of carrots and
that occur within distinct source areas. Storm sticks that can influence residential behaviors.
water hotspots generate pollution during The chapter concludes by discussing recent
common operations and activities that occur at storm water education requirements of
certain commercial, industrial, institutional, municipal storm water permits that can be used
municipal or transport-related sites. Pollution as the foundation for a neighborhood source
can be prevented if neighborhood behaviors and control program.
business operations are changed to promote
greater stewardship within the subwatershed. Chapter 2 reviews the basics of storm water
hotspots, and begins by classifying
Source control is the term for the “carrots” and subwatershed hotspot operations based on land
“sticks” used to change neighborhood behaviors use and regulatory status. The next part outlines
and business operations within a subwatershed. six common operations that should be
Source control “carrots” emphasize education, investigated at every individual storm water
training, direct municipal service, subsidies, and hotspot, with an emphasis on the specific
recognition to positively reinforce stewardship pollutants they generate and the prevention
behaviors that reduce the generation of practices that can reduce them. Source control
pollutants and/or runoff. Source control “sticks” strategies that rely on both sticks and carrots to
include permits, ordinances, inspections, and manage hotspot operations are then reviewed.
enforcement to address the most severe pollution Lastly, the introduces industrial NPDES storm
sources in the subwatershed. water permit regulations, which are
indispensable for managing storm water
The nature and distribution of neighborhood hotspots.
pollution sources and storm water hotspots are
different in every subwatershed. Many pollution Chapter 3 summarizes three field methods to
sources usually exist in a subwatershed, but they discover individual pollution source areas within
are not always easy to find. Considerable a subwatershed: the Neighborhood Source
detective work is needed in the office and field Assessment (NSA), the Hotspot Site
to discover these sources in the subwatershed. Investigation (HSI) and a series of Discharge
This manual outlines a series of methods to Prevention Investigations. Each method provides
discover pollution sources in your subwatershed, a wealth of useful data to incorporate into a
and ways to devise a source control plan to source control plan.
manage them.
Chapter 4 guides you through the four steps
Organization of the Manual needed to prepare a source control plan (SCP)
for your subwatershed. Detailed guidance is
This manual is organized into six chapters. provided on how to assemble a source control
plan, prioritize outreach targets, choose effective
Chapter 1 outlines the basics of neighborhood carrots and sticks, and craft a budget and
source control and how it can prevent pollutants delivery system to implement source controls
from reaching streams. The chapter reviews the throughout a hypothetical subwatershed. The
Urban Subwatershed Restoration Manual 8 1

Introduction
chapter concludes with a discussion on deciding internet resources and references to consult.
how to apply a SCP, whether on a subwatershed
scale or community-wide. Chapter 6 presents profile sheets that describe
15 different pollution prevention practices that
Chapter 5 contains profile sheets describing 21 can be applied to storm water hotspots. The
different neighborhood stewardship practices sheets are organized by the six common hotspot
that can prevent storm water pollution or operations, and explain basic pollution
improve habitat. Each sheet explains how the prevention practices, along with key feasibility,
stewardship behavior influences water quality, implementation, and cost factors to consider.
and presents social research about its frequency Extensive resources, references and websites are
and variation. The profile sheets also also listed where you can get more information
recommend practical techniques to promote on each pollution prevention practice.
better stewardship behaviors, and provide useful
2 Urban Subwatershed Restoration Manual 8

Chapter 1: Basics of Neighborhood Source Control
Chapter 1: Basics of Neighborhood

Source Control
Residents engage in many behaviors and contribute to storm water pollution. The next
activities that can influence water quality. part of the chapter reviews the specific storm
Behaviors such as over-fertilizing, oil dumping, water pollutants generated by residential
littering, and excessive pesticide use can behaviors in each source area, and describes the
negatively impact water quality. Conversely, corresponding stewardship practice that can
positive behaviors such as tree planting, reduce pollution. Next, the diverse range of
disconnecting rooftops, and picking up pet waste “carrot” and “stick” strategies that can influence
can help improve water quality. Whether your residential behaviors are reviewed. The chapter
pollution prevention program is designed to concludes by describing how storm water
discourage negative behaviors or encourage education programs required under municipal
positive ones, neighborhood source control storm water NPDES permits can build effective
involves targeted education to deliver a specific neighborhood stewardship programs.
message that promotes behavioral changes.
Education is often supplemented by discounts, 1.1 Pollution Source Areas in the
subsidies, recognition, and provision of
convenient municipal services. In some cases, Neighborhood
enforcement measures may also be needed to
reinforce appropriate behaviors. Five primary pollution source areas should be
systematically evaluated within each individual
The neighborhood is the fundamental unit for neighborhood: the condition of the “average”
residential source control. Neighborhoods are yard and lawn, driveway/sidewalk/curb, rooftop,
operationally defined as a large group of garage, and common areas in the neighborhood
residential structures built at the same time or to (Figure 1). More than 20 different residential
the same general design standards, preferably behaviors can potentially generate pollution
with a common form of governance (e.g., within these source areas, as outlined in Table 1.
neighborhood or homeowners association). This section briefly describes each of the five
Some neighborhoods may include a mix of major neighborhood pollution source areas.
commercial land uses as well. Most
neighborhoods range from 50 to 200 acres in Yards and Lawns - Research has demonstrated
size. Techniques for delineating individual that yards can be a significant source of nutrient,
neighborhoods are described in Manual 11. pesticide, and sediment loads, which in turn can
cause water quality problems in local streams
The nature and distribution of pollution sources (CWP, 2003). Individual lawns account for
normally differ in each neighborhood, since each nearly 70% of the turf cover in most suburban
has a unique age, lot size, turf cover, tree subwatersheds, and are often intensively
canopy, drainage, street condition and degree of managed (Swann, 1999 and Law et al., 2004).
resident awareness. Consequently, pollution At least 10 behaviors in the yard can potentially
sources need to be assessed within every cause pollutants to wash off in storm water
individual neighborhood to customize an runoff or dry weather flows (Table 1). Some
effective and targeted source control plan for the important yard behaviors include improper lawn
subwatershed as a whole. This chapter explores fertilization, pesticide use, watering, and yard
the basics of neighborhood source control, waste disposal. Yard behaviors tend to be
beginning with a description of the five major homogenous within the same neighborhood,
neighborhood pollution source areas that can since individual yards are often similar in area,
age, turf management and tree canopy coverage.

Driveways,
Common Areas Sidewalks,
and Curbs
Rooftops
Yards and
Lawns
Garages
Figure 1: Four Pollution Source Areas in Residential Neighborhoods
Table 1: Key Behaviors Within Neighborhood Source Areas

Source Area Polluting Behavior
Improper Fertilization
Improper Pesticide Applications
Over-Watering
Extensive Turf Cover
Tree Clearing
Yards and Lawns
Improper Yard Waste Disposal
Soil Compaction
Soil Erosion
Failing Septic Systems
Pool Discharges
Car Wash-water Flows
Driveways/Sidewalks/
Hosing/Leaf-blowing
Curbs
Application of Salt and other De-icers
Dumping of Household Hazardous
Garages Wastes
Dumping of Oil/Antifreeze
Downspout Connections
Rooftops
Added Impervious Cover/Exposed Soils
Lack of Pet Waste Disposal
Un-maintained Storm Water Practices
Common Areas
Buffer Encroachment
Storm Drain Dumping

Teysott (1999) notes that most neighborhoods significant remodeling or redevelopment activity
tend to have similar socio-economic profiles, occurs in the neighborhood, these new rooftops
which often reinforces lawn care practices as will create more impervious cover and can
residents seek to gain social acceptance. become a significant source of sediment and
storm water pollution.
Driveways, Sidewalks, Alleys and Curbs - These
impervious surfaces are endemic to all modern Garages - These rooftop areas merit special
neighborhoods, and are usually directly consideration, since garages are where many
connected to the street and storm drain system. household hazardous wastes are stored and most
As a result, behaviors that occur on driveways car maintenance and fluid changes occur.
and sidewalks can cause pollution to wash off Garages may or may not be present in every
directly to the storm drain system. Notable neighborhood, depending on the era in which
behaviors include washing cars, hosing or they were built. Improper disposal of car fluids
blowing driveway surfaces, and using de-icing and household hazardous wastes can be a source
compounds during the winter months. These of oil, antifreeze, trace metals, pesticides, and
behaviors can potentially introduce nutrients, oil, toxins to streams if they are dumped into the
organic carbon, sediment and chlorides into the storm drain system.
storm drain system. The significance of this
pollution source area is determined by the Common Areas - Many neighborhoods built in
accumulation of sediment, organic matter and the past few decades have a considerable amount
trash on driveways, sidewalks and curbs. In of community open space devoted to stream
general, the basic geometry of driveways, buffers, protected flood plains, storm water
sidewalks and curbs tends to be identical within management practices, rights-of-way, and turf.
the same neighborhood, reflecting the design Common areas can be either pollution sources or
standards in force when they were built. Most restoration opportunities, depending on how
subwatersheds, however, contain dozens of they are managed. Pollutants can be generated
neighborhoods built in different eras under by improper pet waste disposal, buffer
different design standards, so it is important to encroachment, and storm drain dumping. On the
assess each neighborhood individually. other hand, storm water pond maintenance,
bufferscaping and reforestation within common
Rooftops - Rooftop runoff can contain pollutants areas can support restoration objectives. Often,
such as copper, zinc and organic carbon (CWP, the presence of an active and organized
2003). The key neighborhood variable is the homeowners association can make a major
proportion of rooftops that are directly difference in how common areas are managed.
connected to the storm drain system, as they
present a possible restoration opportunity. Roof 1.2 Screening for Pollutants of
downspouts can be disconnected from the storm
drain system using lawn filter strips, rain barrels Concern
and rain gardens. Rooftop retrofits can help
reduce or delay storm water runoff delivered to a Neighborhood source control starts with
stream. Stream hydrology can be improved and identifying the pollutant of greatest concern in
pollutants can be reduced if a large fraction of your subwatershed. Dozens of residential
neighborhood rooftops are disconnected. behaviors in each neighborhood can produce a
Rooftop disconnection may not always be huge number of storm water pollutants, so
practical in every neighborhood; factors such as screening is needed to target pollutants that
small lot size, basements, compacted soils and matter most. Table 2 shows how much potential
yard slopes can make disconnection difficult. each residential behavior has to generate
Another pollution source area to evaluate sediment, nutrients, metals, bacteria, trash and
involves “new rooftops” under construction in oil, and can help you identify the residential
the neighborhood, such as additions, decks, behaviors generating the pollutant of concern.
outbuildings, and residential redevelopment. If

Table 2: Comparison of Pollutant Contribution from Various Residential Behaviors

Residential Polluting Storm Water Pollutants
Behavior TSS Nutrients Metals Bacteria Trash Oil Toxins
Improper Fertilization ° z ° ° ° ° {
Excess Pesticide Use ° ° ° ° ° ° z
Over-Watering { { ° { °
Extensive Turf Cover { ° ° ° °
Tree Clearing ° ° ° ° °
Yard Waste Dumping z ° { { ° °
Soil Compaction { { ° ° °
Soil Erosion z { { ° ° °
Failing Septic Systems { z ° z ° ° {
Pool Discharges ° ° ° ° ° ° z
Car Washwater Flows z ° °
Hosing/Leaf-blowing z ° {
Use of De-icers { { ° ° °
HHW Dumping ° { z ° ° z z
Car Fluid Spills/Dumping ° ° ° ° z z
Connected Downspouts z z ° { {
Added IC and Bare Soil z { ° { {
Pet Waste Washoff ° z ° z ° ° °
Poor STP Maintenance z z z z { {
Buffer Encroachment { { { { { ° °
Storm Drain Dumping { z z z
Key °= not a pollutant source = moderate pollutant contribution
{ = minor pollutant contribution z = major pollutant contribution
For example, if sediment is the pollutant of simple, easy, and low-cost alternatives to the
concern, you may want to focus on behaviors polluting behavior in question. For example, if
such as yard erosion, driveway hosing, soil improper fertilization is discovered as a source
compaction, construction activity, and poor of nutrient pollution, the corresponding
storm water maintenance. A different group of stewardship practice might include reduced
behaviors should be targeted if nutrients are the fertilization, soil tests, grass-cycling, and
primary concern in a subwatershed -- namely, conversion of turf into natural landscaping areas.
improper fertilization, poor maintenance of
septic systems and storm water practices, In many cases, stewardship practices can save
improper yard waste disposal, pet waste wash the homeowner both time and money, and still
off, and downspout connections. Still other create an attractive lawn.
behaviors should be investigated if runoff
reduction is the restoration objective. In this Table 3 lists 21 different stewardship practices
case, factors such as the fraction of connected that can potentially be applied in neighborhoods,
rooftops, soil compaction, and tree canopy along with the corresponding profile sheet
coverage can play a role in reducing storm water number in Chapter 5 where the practice is more
runoff from the neighborhood. fully described. Each profile sheet describes how
the stewardship practice influences water quality
1.3 Neighborhood Stewardship or habitat, and estimates how frequently
residents engage in the polluting behavior. The
Practices profile sheets also describe major challenges to
changing residential behaviors, and recommend
Pollution sources can be reduced through specific carrots and sticks that work best in this
neighborhood stewardship practices, which are regard. Each profile sheet concludes with case

Table 3: Key Neighborhood Stewardship Practices
Source Area Practice Number Stewardship Practice

N-1 Reduced Fertilizer Use
N-2 Reduced Pesticide Use
N-3 Xeriscaping
N-4 Natural Landscaping
N-5 Tree Planting
Yard
N-6 Yard Waste Composting
N-7 Soil Reclamation
N-8 Soil Erosion Repairs
N-9 Septic System Maintenance
N-10 Delayed Pool Discharges
N-11 Safe Car Washing
Driveways, Sidewalks,
N-12 Driveway Sweeping
and Curbs
N-13 Safe De-icer Use
N-14 Household Hazardous Waste Collection
Garage
N-15 Car Fluid Recycling
N-16 Downspout Disconnection
Rooftop
N-17 Single Lot Controls
N-18 Pet Waste Pickup
N-19 Storm Water Practice Maintenance
Common Areas
N-20 Bufferscaping
N-21 Storm Drain Marking
studies on innovative local programs to improve neighborhood stewardship is outlined in Table 4

stewardship, along with a directory of the best and reviewed in the ensuing section.
internet resources and educational materials for
the practice. The stewardship profile sheets are a
useful building block for crafting an effective Table 4: Carrot and Stick Strategies for
neighborhood source control program. Neighborhood Source Control
Carrots
1. Passive Residential Education
1.4 Carrots and Sticks to 2. Active Consultation/Training
3. Provision of Direct Municipal Services
Promote Neighborhood 4. Subsidies and Discounts
Stewardship 5. Homeowner Recognition Programs
6. Formation of Stewardship Groups
Effective stewardship requires many people in a Sticks
neighborhood to take action and/or change their 1. Adopt Local Ordinance
behaviors. Therefore, strategies that will 2. Notification/Signs/Hotlines
persuade residents to accept and adopt desired 3. Restrictions or Bans
stewardship practices must be chosen carefully. 4. Enforcement
A combination of positive reinforcement 5. Utility Pricing
(carrots) and negative reinforcement (sticks) can
be effective at influencing behaviors within a
neighborhood. The range of carrot and stick
strategies that can be used to promote

Carrots wastes can produce significant pollutant

reductions in many subwatersheds. To be
Six carrot strategies can make residents aware of effective, a carefully targeted outreach campaign
desired stewardship practices and encourage is often needed to make residents aware of the
their voluntary adoption. Carrots rely on municipal service, as well as an efficient and
education, training, recognition, economic timely delivery system for the service itself. In
incentives, municipal services and other general, participation rates in municipal service
strategies to reinforce neighborhood programs are strongly linked to how convenient
stewardship. residents perceive them to be.
1. Passive Residential Education - The most 4. Subsidies and Discounts - This carrot relies on
common technique for encouraging better economic incentives to reward positive
stewardship is the passive distribution of stewardship behaviors, and is frequently used
educational materials to subwatershed residents. when residents need to invest time and money to
These educational materials are designed to practice the desired behavior. Examples include
make residents aware of preferred stewardship the distribution of free or discounted rain
behaviors and encourage their adoption. Many barrels, compost bins, soil compost, tree planting
different materials can be used to deliver the and erosion repair kits. Most communities offer
stewardship message, such as brochures, discounts to homeowners in order to gain wider
handbooks, posters, refrigerator magnets and acceptance of new stewardship practices. Like
other promotional items. Where budgets allow, any subsidy, economic incentives should be
local newspaper articles and radio or TV spots carefully targeted to the neighborhoods and
can be used to transmit the stewardship message. subwatersheds where stewardship practices will
The downside of passive education is that create the greatest benefit.
residents must first read or hear the message,
and then be sufficiently motivated to change 5. Homeowner Recognition Programs - This
deeply rooted behaviors. MacPherson and carrot strategy promotes neighborhood
Tonning (2003) present comprehensive guidance stewardship by recognizing residents or
on how to deliver effective stewardship neighborhood associations that are good
messages. stewards. Low-cost recognition techniques such
as awards, plaques, and signs showcase the
2. Active Consultation and Training - Many people making a real difference in the
watershed educators believe that lasting subwatershed, and can influence and educate
behavior change requires direct on-site peers and neighbors to adopt desired behaviors.
consultations with individual residents,
particularly if the public is not familiar with the 6. Formation of Stewardship Groups - The last
desired stewardship behavior (e.g., low-input carrot strategy involves establishing grassroots
lawn care). The underlying strategy for this groups to promote stewardship at the
carrot is to create informal opportunities for neighborhood or subwatershed scale. The basic
educators to give advice on stewardship through idea is to create an active group of residents to
phone assistance, point-of-sale exhibits, spread stewardship advice to their neighborhood
workshops, on-site lawn consultations, and peers. Examples of stewardship groups include
displays at homeowner meetings, garden clubs locally-sponsored programs to adopt streams or
and community fairs. storm water ponds, become a master gardener,
or plant rain gardens or backyard habitats. Local
3. Provision of Direct Municipal Services - stewardship groups are perceived as a credible
Communities can make personal stewardship as information source since members live in the
easy and convenient as possible by providing neighborhood themselves. In some cases,
municipal services to residents directly. Direct stewardship groups ultimately evolve into
municipal services such as collection of watershed organizations that can advocate for
household hazardous wastes, used oil, and yard even greater awareness and stewardship.

Sticks also establish water quality hotlines that

residents can call to make complaints or report
Carrots are not always enough to ensure violations.
widespread adoption of neighborhood
stewardship practices, so a few sticks should 3. Restrictions and Bans - A locality or utility
always be included to control polluting may elect to ban or temporarily restrict
behaviors causing the most severe water quality behaviors that cause severe water quality or
impacts. Sticks should always be judiciously quantity problems. Examples of this rarely-used
administered, since many residents may resent stick include outdoor water use restrictions in
regulation of their daily actions or personal times of drought, bans on pickup of lawn
property. Still, most communities rely on a few clippings to preserve landfill capacity, and
sticks to handle the really bad actors in the restrictions on the phosphorus content of
community. fertilizer to protect lakes. Restrictions or bans
are reserved for situations where compelling
Five basic stick strategies can be applied to water quality problems can be documented or a
regulate polluting behaviors and improve clear emergency exists in the community.
compliance. Stick strategies can include local
ordinances, signs, notification, restrictions/bans, 4. Enforcement - In many cases, the mere threat
the threat of enforcement, and utility pricing, of enforcement may be sufficient to change
each of which is described below. residential behaviors. Some discretion and
sensitivity is needed when handling potential
1. Adopt Local Ordinances - Communities violators in the neighborhood. The typical
routinely enact ordinances to protect public process for handling violators is to first send the
health and safety, set standards for civic property owner a letter describing the problem,
behavior, and protect the local environment. requesting corrective action and setting a date to
Indeed, communities with a population greater re-inspect the property. Enforcement measures
than 50,000 are required to adopt ordinances to are taken as a last resort if the property owner
prohibit dumping and illegal discharges to their fails to comply in a reasonable timeframe. Fines
storm drain system. Model water quality can be levied, permits can be revoked, or water
ordinances for this purpose can be found in service denied. Where possible, penalties should
Brown et al. (2004). be imposed administratively without having to
resort to the judicial system. The enforcement
Other common techniques for regulating system should also have a fair and timely
residential polluting behaviors include appeals process for violators who feel they were
regulations that impose fines for not picking up unfairly cited.
after pets, prohibit phosphorus content in
fertilizers, restrict tree clearing, require 5. Utility Pricing - The last and most rarely used
immediate repair of failing septic systems, and stick involves using utility pricing to penalize
require regular maintenance of storm water negative behaviors and/or reward positive
practices. behaviors. Perhaps the best example of using
utility pricing to encourage neighborhood
2. Notification/Signs/Hotlines - Simply passing stewardship is the practice of escalating water
an ordinance or regulation is seldom enough to rates for homes that consume more water for
change behaviors if residents remain ignorant of outdoor irrigation. Once a threshold level of use
the new requirements. Therefore, it is important is surpassed, the unit price for additional water
to educate residents about new requirements, increases sharply, creating a strong economic
explain why they are needed, and spell out the incentive for households to voluntarily conserve
penalties for noncompliance. Notification can be water. However, few neighborhood behaviors
done with signs, posters and brochures, although can be directly tied to water, sewer or electric
advertisements on local radio and in community billing systems, although many can be linked to
newspapers can also work. Many communities storm water utility rates, if they exist in a

community. Storm water utilities charge This trend is changing as more communities
residents a standard fee, based on the average comply with the National Pollution Discharge
impervious cover on the lot. Several Elimination System (NPDES) Municipal
communities offer customers lower rates if they Separate Storm Sewer System (MS4) permit
install storm water treatment practices or on-site program, which requires communities to meet
retrofits. six management measures to control pollutants
discharged into their municipal storm water
1.5 Municipal Storm Water system. The major components of MS4 storm
water permits and minimum management
Education Opportunities measures are summarized in Table 5. The key
implication is that most communities now have a
Until recently, most communities lacked legal responsibility to conduct storm water
programs to control neighborhood sources of education to control neighborhood sources of
pollution. The few communities that did have pollutants. In particular, three minimum
programs operated on a shoestring budget. management measures require localities to
According to Swann (1999), most local storm provide some form of storm water education to
water education programs were poorly staffed improve the following:
(0.1 to 0.5 staff years), relatively new (within the
last five years), and had minuscule annual • Public education and outreach
budgets ($2,000 to $25,000). Given such limited • Public involvement and participation
resources, most storm water education programs • Municipal pollution prevention/good
have relied on low-cost retail education housekeeping
techniques to send out their message.

Table 5: NPDES MS4 Storm Water Permit Program: What It Means

Phase I Communities Phase II Communities
Very complex designation that includes
most communities with a population of
Complex designation, but primarily more than 50,000 and a population
Who is communities that have a separated storm density greater than 1,000
covered? drain system with a population of more people/square mile. States must also
than 100,000. assess whether communities from
10,000 to 50,000 should be covered,
based on certain criteria.
The first permits were issued in the early General permits issued in December
Permit status 1990s. Extensive permit applications and 2002. Permit applications due in 2003.
annual reports. Permit cycle: 5 to 7 years. Simpler application and reporting.
• Storm water quality monitoring
Control storm water to maximum extent
• Mapping of storm drain network
practical, using six minimum
• Outfall screening
management measures:
• Removal of illicit discharges
• Source identification
What is • Public education/outreach
• Structural and source control
required? • Public participation/involvement
measures to reduce pollutants
• Illicit discharge detection
• Erosion/sediment control program
• Construction site runoff control
• Demonstration of legal authority to
• Post-construction runoff control
control storm water discharges
• Pollution prevention
• Fiscal analysis
Requires creation of programs, but does
Requires creation of programs, and not set firm benchmarks for
monitoring, but does not set firm performance. Stronger emphasis on
benchmarks for program performance. public education, involvement and
Extremely uneven administration by both pollution prevention than Phase I. No
The skinny permitting agencies and municipalities so monitoring required. While the minimum
far. Ranges from paper programs to highly control measures do not explicitly call
innovative and expansive programs, for a watershed approach, they certainly
depending on degree of local and/or state are a strong regulatory driver to improve
leadership. restoration programs for smaller
communities.
Want more information? For Phase II, consult http://cfpub.epa.gov/npdes/storm water/swfinal.cfm.

A summary of the Phase I program can be found in U.S. EPA. 1996. Overview of the Storm Water Program.
EPA833-R-96-008. Available online: http://www.epa.gov/npdes/pubs/owm0195.pdf


Chapter 2: Basics of Storm Water Hotspots

Storm water hotspots are defined as commercial, Commercial hotspots consist of a small group
industrial, institutional, municipal, or transport- of businesses associated with a specific activity
related operations that produce higher levels of or operation that generates higher pollutant loads
storm water pollutants, and/or present a higher in a subwatershed. Commercial hotspots
potential risk for spills, leaks or illicit typically have a great deal of vehicle traffic,
discharges. The nature and distribution of storm generate waste or wash water, handle fuel or
water hotspots are different in every repair vehicles, or store products outside. While
subwatershed. As a general rule, quite a few commercial hotspots are quite diverse, they are
hotspots exist, but may be hard to find since often clustered together. Most commercial
many are quite small and out of the way. hotspots are unregulated, although a few are
Consequently, a considerable amount of regulated under the NPDES industrial storm
detective work is needed to find all the storm water permit program or by local ordinance.
water hotspots in a subwatershed. Pollution Suspected commercial hotspot operations should
prevention practices at many hotspots may be always be inspected to determine whether they
legally required under local or state storm water actually represent a real pollution source or risk
permits. This chapter provides guidance on in a subwatershed.
choosing the right pollution prevention practices
to address the storm water hotspots in your Each kind of commercial hotspot generates its
subwatershed. own blend of storm water pollutants, which can
include nutrients, hydrocarbons, metals, trash
and pesticides. Typical examples of commercial
2.1 Classification of Storm hotspots include the following:
Water Hotspots • Animal care services
• Building material
Hotspots can be broadly classified based on their • Commercial car washes
regulatory status. Regulated hotspots are known • Convenience stores
sources of pollution and are subject to federal or • Laundries and dry cleaners
state regulations, whereas unregulated hotspots • Lawn care companies
are suspected pollution sources, but are not • Gas stations
currently regulated. Storm water hotspots can be • Nurseries and garden centers
found in a wide range of land uses in nearly • Petroleum wholesalers
every subwatershed (Figure 2). This section • Fast food restaurants
classifies hotspot operations based on land use; • Shopping centers
an expanded classification system can be found • Vehicle maintenance and repair
in Appendix A. • Wholesale food and beverage

Commercial Industrial Institutional
Municipal Transport-Related
Figure 2: Five Types of Storm Water Hotspots
Industrial hotspots are a major focus for training, and implementation of pollution
pollution prevention if they use, generate, handle prevention practices to reduce exposure of
or store pollutants that can potentially be washed products to rainfall or runoff. In some cases,
away in storm water runoff, spilled, or storm water treatment practices may need to be
inadvertently discharged to the storm drain installed at the site to remove pollutants from
system. Each type of industrial hotspot generates runoff. Permitted industrial hotspots should be
its own blend of storm water pollutants, but as a regularly inspected to determine if they are
group, they generally produce higher levels of complying with the pollution prevention plan, or
metals, hydrocarbons and sediment. even possess a permit. The storm drain system
should also be investigated to determine if an
Many industrial operations are regulated under industrial hotspot is generating illicit discharges
the NPDES industrial storm water permit of sewage or other pollutants. Methods to detect
program, although individual owners or and correct illicit discharges are described in
operators may be ignorant of their permit status. Brown et al., 2004.
The specific list of 11 major industries subject to
NPDES storm water permits is based on Common industrial hotspots include the
Standard Industrial Classification (SIC) codes to following:
determine permit status, and is provided in
Manual 11. An industrial operation can be • Auto recyclers
exempted from the permit program if “no • Boat building and repair facilities
exposure” is demonstrated (i.e., all of its • Recycling centers and scrap yards
operations are covered by a rooftop). • Warehouses
Industrial hotspots that are regulated under Institutional hotspots include larger, privately-
NPDES storm water permits must prepare owned facilities that have extensive parking,
pollution prevention plans and implement source landscaping, or turf cover. In addition,
control practices at the facility. These plans must institutions may contain fleet vehicles and large
include spill response and prevention, employee maintenance operations. By and large,

institutional hotspots are not regulated. The most Transport-related uses are the last category of
common pollutants generated by institutional hotspots to investigate within a subwatershed.
hotspots are nutrients and pesticides applied to Many, but not all, transport-related uses are
maintain grounds and landscaping. In addition, regulated hotspots. They tend to generate higher
large parking lots can produce storm water loads of hydrocarbons, metals, and sediment in
runoff and associated pollutants, and are natural storm water runoff, are often associated with
targets for storm water retrofitting. Institutional large areas of impervious cover, and have
landowners can be important partners in extensive private storm drain systems.
subwatershed restoration, given the importance Transport-related hotspots may not be present in
of their stewardship practices on the open lands every subwatershed, but you should always look
they maintain. Examples of common for the following operations:
institutional hotspots include the following:
• Airports
• Cemeteries • Bus depots
• Churches • Ports
• Colleges • Rental car lots
• Corporate office parks • Railroad stations and associated
• Hospitals maintenance facilities
• Private schools • State and federal highways and
• Private golf courses associated maintenance facilities
• Trucking companies and distribution
Municipal hotspots include many local centers
government operations that handle solid waste,
wastewater, road and vehicle maintenance and 2.2 Six Common Hotspot
yard waste. Most municipal operations are
defined as regulated hotspots in communities Operations
that are subject to an NPDES MS4 permit. More
details on the MS4 permit program can be found The site is the fundamental unit for evaluating
in Table 5. Municipal hotspots must prepare the potential storm water hotspots. Each site has its
same pollution prevention plans and implement own unique operations, drainage system and
source control practices like any other regulated potential pollution risk. As a result, each hotspot
hotspots. Municipal hotspots can generate the must be individually inspected to assess current
full range of storm water pollutants, including operations, spill risks, and storm water
nutrients, hydrocarbons, metals, chloride, problems. This inspection is known as a Hotspot
pesticides, bacteria, and trash. Common Site Investigation (HSI) and systematically
municipal hotspots include the following: evaluates six potential site operations that can
contribute to storm water quality problems
• Composting facilities (Figure 3):
• Fleet storage and school bus depots
• Landfills/solid waste facilities • Vehicle operations
• Local streets and storm drains • Outdoor materials
• Pesticide use in rights-of-way • Waste management
• Public golf courses • Physical plant maintenance
• Public schools • Turf/landscaping
• Public works yards • Unique hotspot operations
• Maintenance depots
• Solid waste facilities Each hotspot often has several site operations
• Wastewater treatment plants associated with activities that generate storm
water pollutants or illicit discharges (Table 6).
The next section provides more detail on each of
the six common hotspot operations.

Loading
Waste Dock
Storage
Turf Vehicle
Practices Fueling
Downspouts Parking
Lot
Figure 3: Six Common Operations to Assess

at Potential Storm Water Hotspots
Table 6: Polluting Activities Associated With Common Hotspot Operations

Hotspot Operation Polluting Activity
• Improper disposal of fluids down shop and storm drains
• Spilled fuel, leaks and drips from wrecked vehicles
Vehicle
• Hosing of outdoor work areas
Operations
• Wash water from cleaning
• Uncovered outdoor storage of liquids/oils/batteries spills
• Pollutant washoff from parking lot
• Spills at loading areas
Outdoor Materials • Hosing/washing of loading areas into shop or storm drains
• Wash-off of uncovered bulk materials and liquids stored outside
• Leaks and spills
• Spills and leaks of liquids
• Dumping into storm drains
Waste Management
• Leaking dumpsters
• Dumpster juice
• Wash-off of dumpster spillage
• Discharges from power washing and steam cleaning
Physical Plant • Wash-off of fine particles from painting/ sandblasting operations
Maintenance • Rinse water and wash water discharges during cleanup
• Temporary outdoor storage
• Runoff from degreasing and re-surfacing
• Non-target irrigation
Turf and • Runoff of nutrients and pesticides
Landscaping • Deposition and subsequent washoff of soil and organic matter on
impervious surfaces
• Improper rinsing of fertilizer/pesticide applicators
Unique Hotspot Varies but includes
Operations • Discharge of chlorinated water from pools
(Pools, Golf Courses, • Improper disposal of sewage and grease
Marinas, Construction, • Wash off of livestock manure
Restaurants, Hobby • Soil erosion
Farms) • Runoff of pesticides
Note: Street and Storm Drain practices such as street sweeping, catch basin cleaning, and road
maintenance are profiled in Manual 9

Vehicle Operations - Nearly all hotspots devote Physical Plant Practices - The fourth hotspot
some portion of the site to vehicle operations operation relates to practices used to clean,
such as maintenance, repair, recycling, fueling, maintain or repair the physical plant, which
washing or long-term parking. Vehicle includes the building, outdoor work areas and
operations can be a significant source of trace parking lots. Routine cleaning and maintenance
metals, oil, grease, and hydrocarbons, and are practices can cause runoff of sediment, nutrients,
the first operations inspected during a hotspot paints, and solvents from the site. Sanding,
source investigation. Vehicle maintenance and painting, power-washing, resealing or
repair operations often produce waste oil, fluids resurfacing roofs or parking lots always deserves
and other hazardous products, particularly if particular scrutiny, especially when performed
work areas are connected to the storm drain near storm drains.
system.
Turf and Landscaping - The fifth common
Automotive fluids and metals can also be hotspot operation involves practices used to
exposed to rainfall at operations where vehicles maintain turf or landscaping at the site. Many
are scrapped/recycled or wrecked vehicles are commercial, institutional and municipal sites
stored. These operations are always considered hire contractors to maintain turf and
major hotspots (Swammikanu, 1994). Another landscaping, apply fertilizers or pesticides, and
type of vehicle hotspot can exist in outdoor areas provide irrigation. Current landscaping practices
where fuel is dispensed, particularly if these should be thoroughly evaluated at each site to
areas are not covered. Outdoor vehicle washing determine whether they are generating runoff of
can also create a hotspot if wash water enters the nutrients, pesticides, organic carbon, or are
storm drain system. Lastly, drips and leaks from producing non-target irrigation flows.
vehicles stored at fleet and long-term parking
areas can become another pollutant source. Unique Hotspot Operations - Some operations
simply resist neat classification, and this last
Outdoor Materials - Virtually every hotspot site category includes unique hotspots known to
handles some kind of material that can create generate specific pollutants. Examples include
storm water problems if not properly handled or swimming pools, construction operations, golf
stored. The first step is to inventory the type and courses, fairgrounds/racetracks, marinas, hobby
hazard level of materials at the site. Next, it is farms, and restaurants. The special site
important to examine loading and unloading investigations and pollution prevention practices
areas to see if materials are exposed to rainfall applied at unique hotspot operations are
and/or are connected to the storm drain system. described in Chapter 6.
Third, any materials stored outdoors that could
potentially be exposed to rainfall or runoff 2.3 Pollutants Generated by
should be investigated. Stains on paved areas
usually indicate poor outdoor storage practices. Hotspots
Waste Management - Every business generates Hotspot source control should always be linked
waste as part of its daily operations, most of to the pollutant(s) of greatest concern in your
which is temporarily stored at the site pending subwatershed. A given subwatershed can
disposal. The third common hotspot operation contain dozens of storm water hotspots that
involves the way waste products are stored and generate a huge number of pollutants, so some
disposed of at the site in relation to the storm screening is needed to target the right hotspot
drain system. In some sites, simple practices operations in the subwatershed. The potential for
such as dumpster management can reduce each hotspot operation to generate sediment,
pollutants, whereas other sites may require more nutrients, metals, hydrocarbons, toxins and other
sophisticated spill prevention and response pollutants is compared in Table 7. The table can
plans. help you quickly screen hotspot operations to
find the ones generating the pollutant(s) of

concern. For example, if sediment pollution is a 2.4 Hotspot Pollution Prevention

major concern, you may want to focus on
hotspot operations such as construction, vehicle Practices
washing, outdoor storage, loading/unloading
areas, and building/parking lot maintenance. Hotspot pollution prevention practices involve
simple and low-cost changes to routine
A different group of hotspot operations is operations and practices at a site. For example,
targeted when oil and grease are the primary the pollution prevention recipe for a vehicle
concern. In this case, vehicle repair, fueling, and maintenance operation might involve the use of
storage operations might be targeted for drip pans under vehicles, tarps covering wrecked
pollution prevention, along with outdoor vehicles, dry cleanup methods for spills, proper
petroleum storage, parking lot maintenance, and disposal of used fluids, and covering and
restaurant operations. Yet another group of secondary containment for any outdoor storage
hotspot operations should be targeted if nutrient areas. Each of these practices requires regular
reduction is a subwatershed priority. Hotspot employee training and strong management
sites with intensive turf management and commitment. In most cases, hotspot pollution
landscaping should be evaluated, along with any prevention practices save time and money,
vehicle washing operations, golf courses, reduce liability and do not greatly interfere with
marinas and other unique hotspots that are normal operations. Examples of common
present. pollution prevention practices are illustrated in
Figure 4.
Table 7: Storm Water Pollutants Associated With Common Hotspot Operations
Hotspot Operation or Oil/

Sediment Nutrients Metals Toxics Others
Activity Hydrocarbons
Vehicle Repair { { z z z
Vehicle Fueling ° { z z z MTBE
Vehicle Washing z z z
Vehicle Storage { ° z { Trash
Outdoor Loading z { { Organic Matter
Outdoor Storage z
Liquid Spills { z z
Dumpsters { z
Building Repair z {
Building Maintenance z ° z {
Parking Lot Maintenance z { z
Turf Management z ° ° z Pesticides
Landscaping { z ° ° z Pesticides
Pool Discharges ° ° ° ° ° Chlorine
Golf Courses { z { ° z Pesticides
Hobby Farms/Race Bacteria
° ° °
Tracks
Construction z { { {
Marinas ° z Bacteria
Restaurants { ° z ° Grease
Key °= not a pollutant source { = minor pollutant contribution
= moderate pollutant contribution z = major pollutant contribution

The 15 basic pollution prevention practices prevention. Next, each sheet reviews important
applied at hotspot operations are listed in Table feasibility and implementation considerations,
8, which also indicates the corresponding profile and summarizes available cost data. Each profile
sheet number in Chapter 6 that more fully sheet concludes with a directory of the best
describes each practice. Each profile sheet available internet resources and training
explains how the practice influences water materials for the pollution prevention practice.
quality, and lists the type of hotspot operations The profile sheets can be used to design an
where it is normally applied. The sheets also effective pollution prevention plan for an
identify the primary people at the hotspot individual hotspot or for the subwatershed as a
operation that need to be trained in pollution whole.
Wash Water Containment Secondary Containment of Covered Loading Area

Outdoor Storage
Source: Trans-clean Corp.
Figure 4: Examples of Common Pollution Prevention Practices at Hotspots
Table 8: Pollution Prevention Practices for Hotspot Operations

Profile
Hotspot Operation Pollution Prevention Practices
Sheet
Vehicle Maintenance and Drip pans, tarps, dry clean-up methods for spills,
H-1
Repair cover outdoor storage areas, secondary
Vehicle Fueling H-2 containment, discharge washwater to sanitary
Vehicle Washing H-3 system, proper disposal of used fluids, disconnect
storm drains, automatic shutoff nozzles, signs,
Vehicle Storage H-4 employee training, spill response plans
Loading and Unloading H-5 Cover loading areas, secondary containment, storm
drain disconnection or treatment, inventory control,
Outdoor Storage H-6 dry cleaning methods, employee training
Inventory materials, employee training, spill planning,
Spill Prevention and Response H-7
spill clean up materials,
Dumpster management, disconnect from storm drain
Dumpster Management H-8
or treat. Liquid separation/containment
Building Repair and
H-9 Temporary covers/tarps, contractor training, proper
Remodeling
cleanup and disposal procedures, keep wash and
Building Maintenance H-10
rinse-water from storm drain, dry cleaning methods
Parking Lot Maintenance H-11
Turf Management H-12 Integrated pest management, reduce non-target
irrigation, careful applications, proper disposal of
Landscaping/Grounds Care H-13 landscaping waste, avoid leaf blowing and hosing to
storm drain
Swimming Pool Discharges H-14
Varies, depending on the unique hotspot operation
Other Unique Hotspots H-15

2.5 Sticks and Carrots to inspections, and enforcement (or the threat of
enforcement). Sticks are certainly warranted at
Implement Pollution hotspot operations causing severe water quality
Prevention impacts, but should always be administered to
produce environmental results rather than
Traditionally, permits and other regulatory sticks excessive paperwork. Most communities rely on
have been applied to manage hotspot operations, a combination of several stick strategies to
although many communities also offer a few promote pollution prevention practices at known
carrots to enhance compliance. You should hotspots.
carefully consider what combination of carrots
and sticks will persuade operators to accept and 1. Industrial NPDES Storm Water Permits –
adopt pollution prevention practices. The basic Industrial NPDES storm water permits are an
stick and carrot strategies to promote pollution extremely important stick at many hotspot
prevention are outlined in Table 9, and are operations. NPDES permits require operators to
described in detail in this section. prepare a pollution prevention plan for the site
and implement the practices specified in the
plan. Significant penalties can be imposed for
The choice of which sticks and carrots to non-compliance. State and federal regulators are
employ depends on the severity and regulatory still grappling with the administration of
status of the storm water hotspots found in the industrial storm water permits, and they remain
subwatershed, as well as operator awareness and an imperfect tool for several reasons. First, the
the size of hotspot businesses. For example, if permit system allows hotspot operators to
most hotspots are small, unregulated businesses submit their own pollution prevention plan,
whose owners lack awareness of their pollution which may only be a paper exercise. Second,
problems, you may initially want to use more very few trained state or federal-level inspectors
carrots than sticks. By contrast, if the hotspots are available to inspect and enforce the
are large regulated industries, you may want to thousands of industrial sites covered by the
fully utilize all permit sticks to ensure permit program. Third, although communities
compliance. usually have the best understanding of how the
local storm water network works, they lack
Sticks direct authority to inspect or enforce regulated
hotspots, although they can refer them to state
Six basic stick strategies can be applied to agencies for enforcement. All three problems
regulate polluting behaviors at storm water can be overcome if the locality works with state
hotspots. Sticks include NPDES permits, local regulatory agencies to share hotspot inspection
regulation, certification programs, compliance and enforcement responsibilities as part of their
MS4 permit. Portland (OR) recently negotiated
Table 9: Stick and Carrot Strategies for such an agreement to expand the reach of their
Pollution Prevention hotspot inspection program (Pronold, 2000).
Sticks
1. Industrial NPDES Storm Water Permits 2. Refer Permit Non-filers – To date, compliance
2. Refer Permit Non-Filers
3. Regulate Hotspots with Local Ordinances
with the industrial storm water permit program
4. Inspections has been spotty, and a significant fraction of
5. Certification Programs regulated industries have failed to file their
6. Hotspot Compliance and Enforcement required permits. According to Duke and Shaver
Carrots (1999) and Pronold (2000), only 50% of
1. Passive Business Outreach industrial sites that are required to have a permit
2. On-site Technical Assistance actually have one. The remaining sites are
3. Employee/Contractor Training termed “non-filers,” and are often small
4. Subsidies and Discounts businesses or operations that are unaware of the
5. Business Recognition Programs relatively new regulations. It is therefore quite

likely that many hotspots in your subwatershed polluting service, such as lawn care and
may not have a valid NPDES permit. These landscaping, mobile power washing, septic
operations should be educated about the system maintenance, pesticide application, and
industrial permit program, and encouraged to construction services. Certification programs
apply for a permit. Persistent non-filers should work by requiring employees to attend short
be referred for state enforcement, and may face classes where they learn proper storm water
stiff fines. pollution prevention practices related to their
profession. After passing a test, employees are
3. Regulate Hotspots with Local Ordinances – conditionally certified to perform these services.
Communities have the authority to enact If they fail to follow appropriate practices, their
ordinances under their own NPDES MS4 storm certification can be revoked, which can be an
water permit to regulate a broader range of extremely powerful incentive if certification is a
hotspots than is defined under the industrial condition of employment or municipal
NPDES storm water permit program. Indeed, contracting.
MS4 communities must adopt ordinances that
make it illegal to dump or discharge pollutants 6. Hotspot Compliance and Enforcement - As
into the storm drain system, and can specify noted earlier, state agencies are normally
certain business operations or activities where delegated authority to inspect industrial NPDES
pollution prevention will be regulated. Model storm water hotspot sites and enforce
hotspot and illicit discharge ordinances that can requirements. A formal compliance investigation
be used for this purpose can be found in Brown begins by checking whether the operation
et al. (2004). maintains a current Storm Water Pollution
Prevention Plan (SWPPP) at the site. The
4. Inspections – Permits are just a piece of paper SWPPP must include a site plan that shows how
until an inspector shows up. Consequently, storm water runoff is managed using appropriate
inspections are an important stick for improving pollution prevention and documents storm water
compliance at regulated hotspots. Inspectors treatment practices, a schedule for maintenance,
should frequently observe site operations to inspection and visual monitoring, and a record-
ensure the right mix of pollution prevention keeping process. In most cases, the mere threat
practices is routinely employed. Communities of enforcement is sufficient to prompt
with MS4 permits have authority to inspect compliance with pollution prevention practices,
storm water NPDES sites that discharge to their and enforcement actions are used as a last resort.
storm drain system, and refer any violations for However, if corrective actions are not taken in a
subsequent state or federal enforcement. timely manner, fines may be levied.
Voluntary inspections of non-regulated storm Carrots

water hotspots are a good tool for educating
owners/operators about recommended pollution Like anyone else, businesses respond better to
prevention practices. When non-regulated carrots than sticks. Five basic carrot strategies
hotspots are inspected, existing fire, building or can be used to educate operators and encourage
health inspectors should be used since they are them to adopt pollution prevention practices:
already acquainted with how to deal with small business outreach, technical assistance, training,
businesses. Communities that possess an MS4 recognition, and economic incentives.
permit have the authority to inspect non-
regulated hotspots that connect to the municipal 1. Passive Business Outreach - The most
storm drain system they operate. common method for promoting pollution
prevention is the targeted distribution of
5. Certification Programs - Another stick for educational materials to specific business sectors
promoting pollution prevention is establishing in the subwatershed. Outreach materials are
professional certification programs for certain designed to educate owners and employees
businesses that routinely provide a potentially

about polluting behaviors, recommend companies or construction contractors), or

appropriate pollution prevention practices, and offered as part of regular employee safety
notify them of any local or state regulations. meetings.
Useful outreach materials include brochures,
training manuals, posters, directories of 4. Subsidies and Discounts – Some pollution
pollution prevention vendors, and signs. Passive prevention practices require individual
business outreach works best when it is specially businesses to invest time and money in cleanup
adapted and targeted to a specific business sector materials, permanent coverings, secondary
(i.e., vehicle repair, landscaping, or restaurants) containment, and storm water treatment
and is directly presented to local business groups practices. Economic incentives can be a
and trade associations. Business outreach powerful tool for motivating operators to make
requires workers to read or hear the pollution needed investments, particularly for small
prevention message and then take active steps to businesses with limited access to capital.
change their behavior. Subsidies and discounts are commonly offered
as carrots to reduce the financial burden of
2. On-site Technical Assistance - A customized compliance. Examples can include providing
pollution prevention plan should be developed low-interest loans through small business
for each individual hotspot, but many operators programs, discounted cleanup materials, and tax
are confused about what they really need to do breaks. Another option is to provide a regulatory
to comply. This carrot strategy provides direct “safe harbor” for businesses that voluntarily
technical assistance between the local request local assistance to deal with pollution
government and the business to inspect the site problems on their premises (the safe harbor
and develop an effective pollution prevention limits the liability of these volunteer operators
plan. In other cases, pollution prevention for any water quality violations discovered when
workshops or model plans are offered to local assistance is offered).
business and trade groups that represent specific
hotspot sectors. The basic idea is that the locality 5. Business Recognition Programs – This carrot
acts as a partner to provide technical assistance strategy recognizes businesses that practice
and ongoing consultation to individual sound pollution prevention practices through
businesses to support their pollution prevention awards, plaques, seals, signs or advertising.
efforts. This carrot is particularly useful for Business recognition programs promote
small hotspots within defined business sectors, pollution prevention by showcasing the business
although it can be very staff-intensive to leaders that are making a real difference on the
implement. ground. Recognition programs are attractive to
businesses, since they advertise the company’s
3. Employee and Contractor Training – community involvement and environmental
Continuous employee training is an essential stewardship to their customers. Examples of
component of any pollution prevention plan, business recognition programs include clean
particularly at hotspots where the work force marinas, green lawn companies and certified
turns over frequently. Many businesses perceive golf courses.
time devoted to training as subtracting from their
bottom line, and may be hesitant to develop 2.6 Regulations Governing
training materials or allocate time for training.
Consequently, this carrot strategy relies on local Storm Water Hotspots
support for pollution prevention training. In
some cases, local agencies supply free or low- Extensive reference has already been made to
cost videos, posters, shop signs, or training the industrial NPDES storm water permit
brochures (often in multilingual versions). In program. A good understanding of how the
other cases, short training classes for employees industrial permit program works and who
or supervisors are scheduled for down times of exactly is covered is essential to develop an
the year (e.g., winter classes for landscaping effective hotspot source control program. This

may not be easy, since the industrial permit Perhaps the best way to become familiar with
program can be complex, confusing and industrial permits is to directly contact the
ambiguous. While a full description of industrial permit writers and inspectors at the state
storm water permitting is beyond the scope of regulatory agency responsible for administering
this manual, some key requirements are the program.
summarized in Table 10, which also lists several
websites with more detailed information.
Table 10: Industrial NPDES Storm Water Permits: What They Really Mean
These permits regulate 11 categories of industrial activities that discharge
What is an industrial
storm water to surface waters or into a municipal separate storm sewer
storm water permit?
system.
Three kinds of permits are available: group, individual and multi-sector. This
table emphasizes the 11 major industrial groups that may need individual
Who is covered? permits. An industrial site can be excluded from the permit system if the
operator can certify “No Exposure,” which means that all industrial materials
and activities are protected by a storm-resistant shelter that prevents exposure
to precipitation and/or runoff.
There are two basic requirements associated with an industrial storm water
permit. First, the applicant must file a Notice of Intent (NOI) to get a permit.
Some states charge an application fee at this point. Second, the applicant
must develop a Storm Water Pollution Prevention Plan (SWPPP) that must be
What do they really
kept on-site. The SWPPP must include a site evaluation of how and where
have to do?
pollutants may be mobilized by storm water and discharged; a site plan for
managing storm water runoff that includes appropriate structural and non-
structural controls to reduce storm water pollution; a schedule for
maintenance, inspection and visual monitoring; and a record-keeping process.
State water quality agencies that have been given permitting authority by EPA
administer the permit system, and have inspection and enforcement authority.
Who administers Local agencies have no direct role in enforcement, although they can refer a
and enforces the problem hotspot or non-filer to the state agency for enforcement. Indeed, local
permit? governments have their own municipal hotspot operations that are regulated
by the state. A few communities have engaged in a memorandum of
understanding to share the inspection, training and enforcement.
To date, few state agencies have had enough staff resources to do more than
handle the paper side of the permit program (i.e., processing and issuing
permits). On-site inspections are fairly rare, and high rates of non-filers have
The skinny
been observed, particularly among small businesses. Progress in the
permitting program may require greater coordination between local and state
agencies to fill in major inspection, training and education gaps.
Want more information? Many guidance manuals, policy documents and fact sheets can be found on EPA’s
website at www.epa.gov/npdes/stormwater.


Chapter 3: Finding Pollution Sources in Your Subwatershed
Chapter 3: Finding Pollution Sources in Your

Subwatershed
This chapter briefly describes the detective work 3.2 Neighborhood Source
needed to find pollution sources in your
subwatershed. While some pollution sources can Assessment (NSA)
be found by desktop analysis, most require
intensive field investigation. This chapter The Neighborhood Source Assessment (NSA) is
summarizes three field methods to discover a rapid field survey that quantifies potential
individual pollution source areas within pollution sources within neighborhoods, and
subwatersheds: the Neighborhood Source identifies potential stewardship and restoration
Assessment (NSA), the Hotspot Site practices. Conducting the NSA involves driving
Investigation (HSI) and the Discharge every street in the neighborhood to
Prevention Investigation (DPI). Each method systematically assess the residential behaviors
provides a wealth of useful data that can be that contribute to storm water problems by sub-
incorporated into a Source Control Plan (SCP) sampling individual lots, curbs, catch basins, and
for the subwatershed. common areas. The NSA field form evaluates
five parts of the average neighborhood:
3.1 The Subwatershed Context Neighborhood Characterization – Compiles
for Pollution Source Control basic information about the neighborhood.
Every subwatershed has its own unique mix of Yard and Lawn Conditions – Assesses
land uses. Some subwatersheds are entirely vegetative cover and management practices on
residential, whereas others include a mix of the typical lawn.
residential, commercial and industrial land uses.
As a result, the magnitude and distribution of Driveways, Sidewalks, and Curbs – Estimates
pollution sources differs in each subwatershed. pollutant accumulation and practices on
Therefore, it is important to investigate potential impervious areas of a lot.
pollution sources at each individual
neighborhood and every suspected storm water Rooftops – Quantifies how rooftop runoff is
hotspot site in the subwatershed. managed on the average residential lot.
The Unified Subwatershed and Site Common Areas – Evaluates practices in

Reconnaissance (USSR) is a useful tool for common areas of a neighborhood such as storm
discovering neighborhood pollution sources and water ponds, buffers, and flood plains.
storm water hotspots within individual
subwatersheds (Figure 5). The primary The NSA collects data on more than 30
assessment components of the USSR are the neighborhood factors linked either to pollution
Neighborhood Source Assessment (NSA) and sources or potential stewardship practices, as
the Hotspot Site Investigation (HSI). Manual 11 summarized in Table 11. The last part of the
presents a guidance manual on how to prepare NSA form identifies key residential behaviors
for the USSR, conduct field investigations, and causing pollution in the neighborhood, and
organize and interpret data back in the office. computes an index that rates the overall severity
It’s helpful to become familiar with Manual 11 of non-point source pollution for the
so you can rapidly evaluate the neighborhood neighborhood as a whole. NSA data from
pollution sources and hotspot operations that individual neighborhoods is then used to
deserve the most attention in your subwatershed. generate counts, maps, and metrics needed for
the Source Control Plan.

Figure 5: USSR Assessment Field Forms
Table 11: NSA Factors Assessed and Corresponding Neighborhood Stewardship Practice
Neighborhood
Neighborhood Factor Assessed Corresponding Stewardship Practice*
Feature
High management turf Reduced fertilizer use (N-1, N-7)
Potential pesticide use Reduced pesticide use (N-2)
Non-target irrigation Xeriscaping (N-3)
Extensive turf cover Natural landscaping (N-4)
Yards and Average forest canopy Tree planting (N-5)
Lawns Improper yard waste disposal Yard waste composting (N-6)
Soil erosion Erosion repair (N-8)
Construction activity Single lot controls (N-17)
Presence of septic systems Septic system maintenance (N-9; D-7 and -8**)
Presence of swimming pools Safe pool discharge (N-10)
Driveways, Driveway/curb flows Safe car washing (N-11)
Sidewalks Sidewalk zone conditions Pet waste pickup (N-18)
And Curbs Driveway conditions Driveway sweeping (N-12, N-13)
HHW dumping Household hazardous waste collection (N-14)
Garages
Outdoor car maintenance Car fluid recycling (N-15)
Downspout connection Downspout disconnection (N-16)
Rooftops
Index of Redevelopment/Remodeling Single lot controls (N-17)
Evidence of pet waste Pet waste pickup (N-18)
Presence of storm water ponds Storm water practice maintenance (N-19)
Common
Areas Turf cover in open space Bufferscaping (N-20), tree planting (N-5)
Condition of storm drain inlets Storm drain marking (N-21)
Evidence of dumping Prevention/removal of dumping (D-1)**
*The code in parentheses refers to the stewardship profile sheet in Chapter 6.
** These profile sheets can be found in Manual 5.

3.3 Hotspot Site Investigation storm water, including curbs and gutters, catch
basins, and any storm water treatment practices.
(HSI) The HSI collects data on more than 20 site
factors linked either to pollution sources or
The Hotspot Site Investigation (HSI) is a rapid potential pollution prevention practices (Table
survey to assess the impacts of hotspot 12). The HSI form provides a grid to sketch the
operations in urban subwatersheds. The HSI site and locate potential pollution prevention
investigates six distinct pollution sources at each practices. Photos are also taken to document site
suspected hotspot, and identifies pollution conditions. The last part of the HSI evaluates the
prevention practices to address those sources. overall pollution potential for the site and
The HSI produces a comprehensive database of designates it as either a potential, confirmed, or
confirmed hotspots for each subwatershed severe hotspot, or not a hotspot at all. The
ranked by their relative severity. The database hotspot designation dictates the type of follow-
can be used to determine what, if any, pollution up actions needed for the site. HSI data for the
prevention or discharge prevention strategies subwatershed as a whole are then entered into a
should be incorporated into the overall database or GIS system to examine both hotspot
subwatershed restoration plan. The HSI field density and severity. The resulting counts, maps,
form consists of seven parts: and metrics are then incorporated into the
Source Control Plan.
Site Data and Basic Classification – Collects
basic location and land use information about
the hotspot site, and briefly describes its actual 3.4 Suspicious Discharge
operation. Investigations
Vehicle Operations – Evaluates routine vehicle Any suspicious dry weather flow encountered
maintenance and storage practices at the site, as during field work or reported by the public
well as any vehicle fueling or washing should be immediately assessed as a potential
operations. pollutant source. These flows may be illicit
discharges of sewage or other pollutants, and
Outdoor Materials – Examines the type and can occur on a continuous, intermittent or
exposure of any outdoor materials that are stored episodic basis. The location of manholes,
at the site. channels or outfall pipes generating suspicious
flows should be referred for subsequent
Waste Management – Assesses housekeeping discharge investigations to determine the
practices for waste materials generated at the composition of the flow and trace it back to its
site. source. Brown et al.(2004) outlines different
types of discharge prevention investigations that
Physical Plant – Assesses maintenance practices can be used for this purpose:
used for cleaning, remodeling or repairing
buildings, outdoor work areas and parking lots. • Outfall Reconnaissance Investigation
• Outfall Indicator Monitoring
Turf/Landscaping Areas – Examines the • In-stream Dry Weather Sampling
practices used to maintain lawn or landscaping • In-Pipe Investigations
areas, with special emphasis on fertilizer use and • Hotlines and Citizen Reporting
non-target irrigation. • Dye, Smoke and TV Tests
• Infrared Aerial Thermography
Storm Water Infrastructure – Evaluates the • Finding Failing Septic Systems
condition of practices used to convey or treat

Table 12: HSI Assessment Factors and Corresponding Pollution Prevention Practices
Hotspot Factor Assessed Corresponding Pollution Prevention Practice*
Potential, Confirmed or Severe Hotspot Permit enforcement (M-9)
Vehicle Source Areas Vehicle pollution prevention practices (H-1 to H-4)
Outdoor Storage Source Areas Storage pollution prevention practices (H-5/6
Waste Management Source Areas Waste pollution prevention practices (H-7/8)
Physical Plant Operations Maintenance pollution prevention (H-9 to 11)
Turf/Landscaping Source Areas Landscaping pollution prevention practices (H-12/13)
Uncontrolled Storm Water Discharge Parking lot retrofit (SR-6, OS-7 through 11)
Suspected Source of Illicit Discharge Discharge investigations (M-6)
Observed Spill or Illicit Discharge Contain and cleanup (M-6 and H-7)
Unique Hotspots Special pollution prevention practices (H-14, 15)
Catch Basin Accumulation Catch basin cleanouts (M-9)
*The code in parentheses refers to the pollution prevention profile sheet number.
H- sheets can be found in Chapter 6 of this manual
SR- and OS- sheets can be found in Manual 3
M-9 = Manual 9: Municipal Practices and Programs
M-6 = Illicit Discharge Detection and Elimination Guidance Manual (Brown et al. 2004)

Chapter 4: Subwatershed Source Control Plans
Chapter 4: Subwatershed Source

Control Plans
Although source control relies on non-structural 8. What specific source control practices will
practices to prevent pollution, it should be most effectively change behaviors?
treated like any other structural restoration
practice installed in a subwatershed. Source 9. How much will the source control practices
control practices should be carefully designed, cost?
effectively targeted, and continuously
maintained. This chapter outlines a process to 10. Which partners will be responsible for
implement source controls at the subwatershed distributing the source control practices?
level to reduce pollutants.
11. How will progress made in source control
A pollution source control plan should be be evaluated?
developed for every subwatershed, since each
has its own unique pollution sources and control The SCP systematically answers these 11
opportunities. The Center has developed a questions within the context of an individual
planning framework to define the focus, targets, subwatershed. To be sure, many questions
methods and delivery of source control practices require careful analysis and rely on professional
within individual subwatersheds, known as a judgment, since hard data may be lacking. Still,
Source Control Plan (SCP). The SCP is a simple the questions provide a good framework to
desktop analysis to develop cost-effective organize your thinking about pollution sources
strategies to promote better stewardship and and control opportunities. This chapter provides
pollution prevention practices. The SCP guidance on how to design an SCP for your
evaluates subwatershed conditions to answer 11 subwatershed, and concludes with an example
basic source control questions: for the hypothetical “Stewardship Branch”
watershed.
1. What is the primary pollutant of concern in
the subwatershed? 4.1 Basics of a Subwatershed
2. Which subwatershed behaviors are most
Source Control Plan
directly linked to it?
The SCP represents the “design” of a program to
3. What specific neighborhoods and business effectively target source control practices to
sectors are generating the pollutant? reduce priority pollution source areas within a
subwatershed, along with a budget and delivery
4. Who are the specific individuals and groups system to implement the practices. The 11 steps
that should be targeted for outreach? involved in the SCP mirror the design questions
outlined above. The step-by-step process is
5. What are the most appropriate carrot and depicted in Figure 6, and each step is described
stick strategies to apply in the at greater length in the remainder of this section.
subwatershed?
6. What is the most clear and direct message to

promote desired behaviors?
7. What outreach techniques are most

effective at sending the message out?

Figure 6: Steps to Prepare a Source Control Plan
Step 1: Pick Your Pollutant of Concern Step 2: Link Pollutant to Key

Subwatershed Indicators
The first and most important step is to choose
the pollutants that will become the primary focus Once you’ve targeted a pollutant, the next step is
of the source control plan. It is important to to identify the particular behaviors or operations
restrict your initial efforts to only one or two in the subwatershed directly linked to that
pollutants from the much larger list of possible pollutant. This is done by looking at specific
storm water pollutants (e.g., nutrients, bacteria, pollutant indicator data generated from
sediment, trash, oil, pesticides). Often, the subwatershed NSA and HSI survey data. Table
pollutant of concern will have been identified 13 summarizes common behaviors and
earlier in the restoration planning process, or operations that are potential indicators of eight
may emerge from field observations with the categories of storm water pollutants.
subwatershed.
Pollutant indicators only suggest the potential
for a behavior or operation to be an actual
pollution source. NSA and HSI survey data
needs to be analyzed further to confirm that the
behavior or operation is indeed a source of

pollution. Key tests include whether the The product of this step is a short list of the most
following conditions exist: important neighborhood behaviors and/or
business operations generating the pollutant of
• Behavior or operation is directly concern.
connected to storm drain system
• Pollutant is accumulating on impervious
surfaces, curbs, or catch basins
• Pollutant is detected in the stream or
storm water runoff
Table 13: NSA and HSI Pollutant Indicators in a Subwatershed

Nutrient Pollution Indicators Sediment Pollution Indicators
• Extensive high input turf
• Extensive bare soil on lots
• High turf cover as % of lot area
• High index of redevelopment/remodeling
• Presence of septic systems
• Sediment accumulation in curbs
• Evidence of pet wastes
• Sediment accumulation in catch basins
• Organic matter accumulation in curbs and
• Improper yard waste disposal
catch basins
• Construction sites
• Evidence of car washing
• Hotspot vehicle washing
• Poor STP maintenance
• Building repair and maintenance
• Buffer encroachment
• Parking lot maintenance
• Connected commercial landscaping
• Outdoor bulk storage
• Hotspot vehicle washing
• Loading and unloading operations
• Unique hotspots (golf courses, marinas)
Bacteria Pollution Indicators Runoff Indicators
• Presence of pet waste • Percent of disconnectable rooftops
• Presence of septic systems • High impervious cover
• Organic matter accumulation in curbs • Evidence of non-target irrigation
• Poor storm water practice maintenance • Evidence of soil compaction
• Unique hotspots (marinas, hobby farms) • Poor tree canopy coverage on lot
• Transients/homeless • Curb and gutter
Trash and Debris Indicators Oil and Grease Indicators
• Car washing
• Poor neighborhood housekeeping
• Driveway or parking lot staining
• Evidence of hosing/leaf blowers
• Oil sheens in catch basins
• Trash accumulation in curbs and catch
• Restaurants
basins
• Vehicle fueling, maintenance and repair
• Lack of storm drain stencils
• Outdoor car maintenance
• Overloaded or uncovered dumpsters
• Streets and alleys
Trace Metal Indicators Pesticide Indicators
• Connected residential rooftops
• High turf cover as % of lot area
• Connected comm./industrial rooftops
• Residential non-target irrigation
• Vehicle operations
• High input turf and landscaping (hotspot)
• Building and parking lot maintenance
• Unique hotspots (golf courses, marinas)
• Storage of household hazardous wastes
• Utility right-of-way corridors
• Streets and parking lots
Note: Indicators only show potential for pollution to be generated. To be confirmed, the pollutant generating
behavior should be connected to the storm drain system; some physical evidence should be present on
streets, curbs, catch basins or streams; and it should be widely distributed or tightly clustered in the
subwatershed.

Step 3: Locate the Specific Pollutant

Source Areas in the
Subwatershed
Given limited resources, you won’t be able to

reach every neighborhood or hotspot in a
subwatershed. Therefore, it is important to
prioritize where source control practices will be
targeted. As a result, the third step involves
locating the specific pollutant source areas
generating the pollutant within the
subwatershed. The basic method is to spatially
analyze NSA and HSI data to determine the
specific neighborhoods and hotspot operations
thought to be contributing pollutants to the
subwatershed. Four methods can be used to
locate problem sites: NSA Pollution Severity
Severe/High (≥ 5)
1. NSA or HSI counts – The simplest method Moderate (< 5)
counts major NSA or HSI outputs linked to the Low (0)
pollutant of concern. For example, you may
want to count the number and distribution of the Figure 7: Example of an NSA Severity Index Map
following: to Target Source Control
• Neighborhoods with a large proportion of 4. Screening Based on Neighborhood Metrics—

high input turf “Neighborhood metrics” describes the process of
• Neighborhoods with high or low forest aggregating data from individual NSA forms to
canopy coverage get a clearer picture of what is happening at the
• Potential, confirmed, and severe hotspots neighborhood scale. An example of a
• Potential generating land uses for illicit neighborhood metric is the acreage of high input
discharges turf. This metric can be directly computed from
the NSA form by multiplying the fraction of turf
2. Mapping Neighborhood Index Data – NSA cover on the average lot by the proportion of
data can be used to derive an overall index of the high input lawns in the neighborhood. This
severity of pollution sources for individual fraction can then be multiplied by total
neighborhoods (see Manual 11). Simple maps neighborhood area to get a planning estimate of
can be generated that compare neighborhood the acreage of high input turf for the
index scores to quickly screen neighborhoods neighborhood as a whole.
with the greatest pollution potential. Figure 7
illustrates how NSA index scores are used to The high input turf metric provides insight into
identify neighborhoods for priority source the significance of lawns as a potential nutrient
control within a subwatershed. source, and can target lawn care education
efforts at the neighborhood level. Metrics have
3. Mapping Hotspot Clusters – The type and considerable value to screen or rank the source
distribution of storm water hotspots should be control potential among groups of
mapped in each subwatershed to look for hotspot neighborhoods. The basic approach is simple:
“clusters,” or high density of hotspots. Hotspot select the metrics most important to your source
clusters are natural targets for source control, control objectives, and then see how individual
particularly if they exist within the same neighborhoods rank in the process. This simple
business sector. ranking approach can identify priority

neighborhoods within a subwatershed to target population include phone surveys, focus groups,
education efforts. interviews with community leaders, and
informal conversations with individual
Detailed methods for deriving counts, maps, or homeowners or operators.
metrics of subwatershed pollution sources are
described in Manual 11. Step 5: Develop an Overall Source
Control Strategy
Step 4: Identify and Understand Priority
Outreach Targets Chapters 1 and 2 reviewed the wide range of
carrot and stick strategies available for
Once priority pollution source areas are located, subwatershed source control. Step 5 involves
the next step is to identify the specific choosing the right combination of carrots and
individuals or groups to target for outreach. The sticks to apply in your overall source control
goal is to assemble an outreach database that strategy. While the choice of which carrots and
contains up-to-date contact information for sticks to apply is fundamentally determined by
residents and businesses located with priority the attitudes and receptivity of the outreach
pollution source areas in the subwatershed. population, five effectiveness factors also come
Ideally, the database should contain names, into play:
mailing addresses, phone numbers, or e-mail
addresses for your priority outreach targets. • Hit Rate - how effective is the strategy in
Often, it is a good idea to start by consulting reaching your target audience?
“outreach multipliers” that already possess good • Adoption Rate - what proportion of the
contact information, which include civic target audience will adopt the practice after
associations, local planning agencies, the learning about it?
chamber of commerce, trade groups and local • Startup Cost - how much does it cost to
advertisers. The contact database is a key tool initially implement the strategy, including
used in subsequent steps to target outreach outreach?
efforts. • Ongoing Cost - how much will it cost to
maintain the strategy over several years?
This step is also a good time to learn more about • Expertise - how much specialized
the outreach population, and discover the knowledge or training is needed to
reasons why they engage in the particular implement the strategy?
behavior. For example, is the behavior rooted in
a lack of awareness, economics, peer pressure, Tables 14 and 15 compare how each carrot and
convenience or some other factor? Also, how stick strategy ranks based on the five factors.
willing or receptive will the outreach population The tables can be used to choose the
be to changing the behavior? A good combination of carrots and sticks with the
understanding of the outreach population is greatest potential to influence neighborhood
extremely helpful when choosing the right stewardship and hotspot pollution prevention
combination of carrots and sticks to include in practices in the subwatershed.
your overall source control strategy. Simple
techniques for learning about your outreach

Table 14: Comparing Carrot and Stick Strategies to Promote

Neighborhood Stewardship Practices
Comparative Factors
Hit Adoption Startup Ongoing
Expertise
Rate Rate Cost Cost
Carrots
Passive Education z { $$ $$ {
Active Consultation { z $ $$ z
Direct Municipal Service z $$$ $$$ {
Subsidies and Discounts $$ $$$ {
Recognition Programs { z $ $
Stewardship Groups { z $$ $$
Sticks
Local Ordinance { $$ $
Notification/Signs/Hotlines { $$ $ {
Restrictions/Bans z z $ $
Enforcement { z $ $
Utility Pricing $$ $
Key: { Low Medium z High
$ Low $$ Medium $$$ High
Table 15: Comparing Stick and Carrot Strategies to Promote

Pollution Prevention Practices
Comparative Factors
Hit Adoption Startup Ongoing Expertise
Rate Rate Cost Cost Needed
Sticks
Industrial NPDES Permits { $ $ {
ID and Refer Non-filers { $$ $
Local Hotspot Regulation $$ $$
Inspections z $$ $$$ z
Certification Programs z $$$ $$$ z
Hotspot Enforcement z z $ $$
Carrots
Passive Business Outreach { $$ $$
On-site Tech. Assistance { z $$ $$$ z
Training { z $$$ $$$ z
Subsidies and Discounts { $$ $$$
Business Recognition { $ $
Key: { Low Medium z High
$ Low $$ Medium $$$ High
Step 6: Craft a Clear and Simple the desired behavior, and explain how the
Message practice will benefit the individual resident or
business. Several tips on crafting an effective
A clear and simple educational message must be message are offered below:
crafted to attract the attention of residents and
business owners who are bombarded by dozens 1. Link your message to a recognized community
of other competing messages every day. The problem – Your message should always link the
message should clearly describe how to practice watershed behavior to the undesirable water

quality problem it causes (e.g., fish kills, beach education levels, turnover and languages spoken
closure, green lakes, flooding). by workers. For example, middle-age males with
higher incomes and education levels are often
2. The message should never presume much considered a prime outreach target, as surveys
awareness -- The average person doesn’t know indicate they engage in more potentially
much about storm water runoff, nonpoint source polluting behaviors than other sectors of the
pollution or watersheds, so remember to stress population (Swann, 1999). By contrast, if
the connection between the home, storm drains residents speak English as a second language,
and downstream waters in every message you the message should be sent in their primary
send. Pictures and simple drawings are more language.
effective than words in increasing storm water
awareness. Step 7: Select the Most Effective
Outreach Techniques
3. Keep your message uncluttered – It can be
tempting to try to change all 21 neighborhood Once you’ve crafted the perfect message, you
behaviors and 15 hotspot operations at one time. need to select the best outreach techniques to
Don’t even think about it. Most people can only deliver it to the outreach population. To do this,
absorb a few new things at a time, so confine you need to carefully define the size of the
your message to two or three key headlines. You outreach population, establish the desired
can always sprinkle in additional stewardship exposure frequency and choose the best mix of
messages later. outreach techniques to advertise source controls.
Each of these important tasks is described
4. Keep the message simple and funny – Source below.
control messages should never be preachy,
complex, ambiguous or depressing. Indeed, the 1. Define the size of the outreach population –
most effective messages are direct and The size of the outreach population can be easily
interesting with a dash of humor. The basic rule quantified from subwatershed data generated
is that your core message should be expressed in earlier in the SCP. The basic idea is to get an
a single sentence. accurate count of the following:
5. Package your message in small, slick and • Subwatershed households
durable units – It can be a real struggle to impart • Households in priority neighborhoods
detailed information to residents and businesses • Potential training/workshop population -
without losing their interest. One solution is to usually assumed to be no more than
create small, colorful and durable packets that 2 - 5% of total subwatershed population
contain the key essentials about watershed • Active neighborhood associations
stewardship, and contact information on where • Suspected or confirmed hotspot sites
to get more advice. These packets can be stuck • Subwatershed education outlets - sum of
on the refrigerator, the kitchen drawer, or the malls, libraries, schools, retails, nature
lunchroom for handy reference when the centers, municipal buildings in the
impulse for better watershed behavior strikes. subwatershed that could distribute
outreach materials
6. Understand your audience – Your message
should always be customized to reflect the 2. Estimate the exposures and timing needed for
unique demographics of your subwatershed. In your message – Exposures are defined as the
some cases, you may want to analyze census number of times the average resident or business
data to understand the demographics of priority hears or sees your educational message.
neighborhoods, such as age, income, and Marketing studies suggest anywhere from three
ethnicity. Similarly, you may want to investigate to 12 exposures are needed for an education
workforce demographics within hotspot clusters message to truly sink in. The number of
in order to craft a message that reflects the

exposures needed is also related to the resident exposed, while “high-cost” techniques
complexity, length and immediacy of your core can cost a few dollars per exposure, but may be
message. More exposures are needed if the more influential in changing behaviors.
message is long or complex, or must be Low-cost techniques are cost-effective in
sustained over a long period of time. At a increasing watershed awareness and sending
minimum, try to achieve at least three exposures messages about negative watershed behaviors.
for your target population, using different On the other hand, high-cost techniques are
outreach techniques. better at promoting more sophisticated
stewardship practices in the home, lawn and
The timing of exposures can also be critical. For workplace. It is important to remember that no
example, many residential behaviors are single outreach technique is ever recalled by
seasonal in nature, and exposures should be more than 30% of the population, so a mix of
scheduled when behavior is the highest (e.g., techniques is needed to send the message across
lawn fertilization in the spring). to enough residents to make a difference in a
subwatershed.
3. Select several outreach techniques to spread
your message – Surveys have discovered which Keep in mind that many excellent outreach
outreach techniques are most influential in resources already exist, so you don’t need to
attracting the attention of residents and invent an outreach campaign from scratch. Two
businesses (Swann, 1999). In general, messages of the best resources to consult are the Getting in
transmitted via television, radio and local Step guides produced by Tetratech, Inc. for the
newspapers are most influential, with up to 30% U.S. EPA, which can be found here:
recall rates in the subwatershed population. By http://www.epa.gov/owow/watershed/outreach/d
contrast, messages sent through meetings, ocuments/getnstep.pdf and
brochures, local cable and videos are recalled by http://www.epa.gov/owow/watershed/outreach/d
a much smaller fraction of the population. ocuments/stakeholderguide.pdf
Table 16 lists 30 different outreach techniques Step 8: Choose the Mix of Source
that can be used to communicate your message. Control Practices
These techniques are divided into two categories
based on their comparative costs: “low-cost” During this step, you choose specific source
techniques cost a few cents per subwatershed control practices to apply in the subwatershed
Table 16: Range of Outreach Techniques from more than 100 available practices. Table
Lower unit cost 17 lists 92 neighborhood stewardship practices,
• Brochures • Presentations
and Table 18 features 22 hotspot pollution
• Decals • Public displays prevention practices. More details on each
• Fact Sheets • Refrigerator practice can be found in Chapters 5 and 6.
• Flyers Magnets
• Letters • Signs At this point, selecting the right practices from
• Mailings • Utility bill inserts such a long menu is relatively easy, since you
• Newsletters • Watershed maps already know the pollutant of concern, the key
• Posters • Word-of-mouth behaviors and operations to target, and the types
Higher unit cost of carrots and sticks you plan to employ. Once
• Billboards again, it is a good idea to choose several
• Public notices different source control practices to apply in
• Classes
• Radio PSAs
• Community fairs your subwatershed, and get feedback from
• Retail exhibits
• Meetings stakeholders, residents, and businesses on how
• TV PSAs
• Newspaper ads receptive they will be to adopting them.
• Videos
• Newspaper
• Watershed
articles
Festivals
• Newspaper inserts
• Workshops
• Pollution Hotlines

Table 17: 92 Tools to Promote Better Neighborhood Stewardship

-----YARDS AND LAWNS-----
Carrots
• Create demonstration lawn and garden • Offer free septic system inspections
programs • Offer lawn and garden advice on the radio
• Create "bayscapes" program • Offer direct tree planting assistance
• Create master gardener programs • Offer assistance in lawn composting
• Create backyard habitat/butterfly gardens • Promote low-input lawn care guides
• Create homeowner stewardship recognition • Promote integrated pest management
• Distribute coupons for septic system techniques
cleanouts • Promote summer water conservation
• Distribute free or discounted • Promote grass-cycling mowers
− Compost bins • Promote garden clubs and native plant
societies
− Mulch
• Promote native plant nurseries
− Grass patch repair kits
• Provide regular yard waste pickup
− Native plant material/seeds
• Provide fall leaf pickup
− Seedlings of native trees
• Provide free or discounted soil tests
− Native tree planting guidebooks
• Provide natural landscaping guides
• Offer direct lawn care consultations
• Provide invasive species alerts
• Offer pest advice through hotlines
• Set up exhibits at lawn care and garden
• Offer non-regulatory erosion control centers, and retail outlets that sell pool
consultations chemicals
Sticks
• Adopt tree clearing ordinances and permits
• Require certification of lawn care contractors
• Adopt ordinance to prevent pool discharges
• Require certification of septic systems at sale
• Adopt erosion control and nuisance
• Require certification of septage haulers
ordinances
• Require mandatory septic system inspections
• Ban pickup of lawn clippings
• Repeal local weed ordinances
• Create septic management districts
• Restrict phosphorus content in fertilizer
• Impose mandatory outdoor water restrictions
• Set water rates to discourage outdoor water
• Require certification/licensing of pesticide
use
applicators
-----GARAGES-----
Carrots
• Provide directories of used oil collection

• Provide more frequent HHW collection days
stations
• Provide mobile and curbside pickup options
• Provide discounted used oil disposal
for HHW
containers
• Provide HHW disposal fee waivers at
• Provide fluid recycling at auto parts stores/gas
landfills
stations

Table 17: 92 Tools to Promote Better Neighborhood Stewardship

-----DRIVEWAYS/SIDEWALKS/CURBS-----
Carrots
• Distribute discounts for commercial car • Promote hose nozzles with shut-off valves
washes • Promote safe car washing products at point of
• Distribute directories of used oil collection sale
stations • Promote safe de-icer use by local TV
• Distribute used oil disposal containers weathermen
• Distribute storm drain plugs for charity car • Promote fluid recycling at auto parts
wash events stores/gas stations
Sticks
• Post signs to keep leaves out of gutters during fall leaf collection
• Train contractors on proper leaf blower use
-----ROOFTOPS-----
Carrots
• Create rain garden demonstration projects
• Distribute free or discounted rain barrels
• Offer technical assistance on design/installation
• Promote rain garden/rain barrel installation
• Subsidize disconnections through utility credits
Sticks
• Require downspout disconnection in targeted subwatersheds
• Require single lot storm water and ESC plans
• Set storm water rates based on actual impervious cover
-----COMMON AREAS-----
Carrots
• Create an “Adopt-a-storm water pond”

• Offer pondscaping assistance
program
• Offer storm water inspections/contractor
• Create an “Adopt-a-stream” program
referral
• Create designated “dog parks”
• Offer storm water maintenance classes
• Create storm water pond beautification
• Promote bufferscaping through outreach
awards
guides
• Install “pooper scooper” stations in common
• Promote pet waste pickup through education
areas
• Promote pet waste pickup using signs
• Offer community buffer walks
• Provide seedlings to reforest open space
• Offer consultations with homeowner
• Provide storm drain marking/stenciling kits
associations
Sticks
• Adopt ordinances to:
− Define and prevent unacceptable stream
• Enforce “pooper scooper” ordinances
buffer uses
• Ban dogs from beaches and public spaces
− Prevent illegal dumping
• Inspect and enforce stream buffer boundaries
− Prevent storm drain discharges
• Post stream buffer boundary signs
− Require storm water practice
maintenance

Table 18: 22 Tools to Promote Hotspot Pollution Prevention Practices

Sticks
• Adopt local ordinance to pick up non-regulated hotspots
• Certify lawn care/landscaping/power-washing contractors
• Check and review on-site storm water pollution prevention plans
• Conduct on-site illicit discharge investigations
• Conduct regular site inspections
• Identify NPDES non-filers and refer for state enforcement
• Issue fines, stop work orders, and other enforcement actions
• Review of spill response plans
Carrots
• Assemble vendor and contractor directories
• Conduct non-regulatory site inspections
• Coordinate inspections with fire, building, and food handling inspectors
• Coordinate with corporate safety and compliance officers
• Develop multilingual outreach materials
• Distribute pollution prevention training videos
• Establish business recognition programs
• Mail outreach materials to target business groups
• Make presentations to business groups
• Offer small business loans to install structural practices
• Provide discounted spill response kits, storm drain plugs, drip pans, tarps
• Provide free assistance in pollution prevention plans
• Provide free employee training on pollution prevention
• Provide pollution prevention posters and signs
Step 9: Estimate Subwatershed Source example, if a brochure is sent three times to

Control Budget 2,000 households in a subwatershed, and the
cost to produce and mail each brochure is 75
The next step involves deriving a budget to cents per copy, then the direct outreach cost
implement source control practices at the would be:
subwatershed level. Decent planning estimates
can be derived using a four-step unit cost (3) (2000) ($0.75) = $4,000.
budgeting approach, as shown below:
Unit costs for some common outreach
1. Define time frame for source control techniques are provided in Table 19.
implementation -- The first budget decision is to
choose the time horizon over which source 3. Estimate direct costs for source control
control practices will be applied. Based on our practices -- The third budgeting step involves
experience, a minimum horizon of three years is computing the annual cost to directly implement
recommended, since lasting behavior change source control practices, which is projected
usually requires multiple exposures over time. based on unit costs (e.g., cost per capita,
household, neighborhood, or hotspot). Some
2. Estimate direct outreach costs -- The second direct costs are fairly easy to estimate, such as
budget step involves estimating the direct costs the cost of an individual educational brochure,
for the outreach techniques used to advertise installation of a rain barrel, or a lawn care
source control practices. Outreach costs are consultation. A budget item should be developed
calculated as the product of the outreach for each source control practice recommended in
population, the number of exposures needed, your plan. Budgeting guidance for various
and the unit cost for each outreach exposure. For neighborhood stewardship and hotspot pollution
prevention practices is provided in Tables 20

and 21, respectively. These cost estimates were estimates. More detailed local cost analysis may
derived from communities across the country be needed to get more accurate budget estimates.
and should be viewed as planning level
Table 19: Unit Costs for Outreach Techniques
Technique Unit Estimated Cost
Overall residential outreach Per year $.14 - $1.11
Designer for material layout Per hour $100 - $150
Coloring books Per 1,000 produced $.45
Decals Per 1,000 produced $.17
Magnets Per 1,000 produced $.30
Posters (4 double-sided, color, 11x17) Per 1,000 produced $2.75
Printed materials (Flyers) Per 1,000 produced $.60-$.84
Printed materials (Tri-fold panel brochure) Per 1,000 produced $1.60 -$2.40
Stickers Per 1,000 produced $.08
Tote bags Per 1,000 produced $3.50
Billboards Per billboard/per month $550 -$1,850
Exterior bus advertisements Per bus/per month $750 - $1,450
Tabletop display Per display $500-$800
Educational video Per minute of video $1,800
Movie theatre slides Per month $150 -$1,400
Newspaper ads in small local paper Per advertisement $260 -$450
Photo displays Per display $121
Public attitude phone survey Per survey of 1,000 $15,000
Radio public service announcement * Per announcement $40-60
TV public service announcement * Per announcement $2,750 - $4,000
* Assumes free airtime
Sources: Council of State Governments, 1998; MacPherson and Tonning, 2003; National Oceanic and
Atmospheric Administration, 1988; Water Environment Research Federation, 2000; and Center for
Watershed Protection, 1998.
Table 20: Unit Costs for Neighborhood Stewardship Practices

Techniques Unit Estimated Cost
Lawn care advice Per household $1.75 – $3.20
Rain barrel Per household $20 - $45
Septic system inspections Per household $150-$260
Municipal Composting Per household $1.85 – $2.40
Soil testing Per household $8-$12
Compost bins Per household $18-$62
Curbside recycling Per household $29
Curbside leaf/yard waste pickup Per household $11.60
Household hazardous waste collection Per household $1.75 - $8.09
Adopt an ordinance Per ordinance $13,000 - $15,000
Provide stenciling materials Per neighborhood $300 -$400
Per square foot
Rain garden demonstration project Residential $3 to $4
Commercial $10 to $40
Signage Per sign $20-$50
“Pooper bag” stations Per station $250 - $300
Tree plantings Per tree $3.25 -$19
Pesticide advice hotline Per year $8,500
Non-commercial pesticide applicator licensing Per individual $15-$45
Cost derived from a survey of various communities across the country

Table 21: Unit Costs for Hotspot Pollution Prevention Practices

Technique Unit Estimated Cost
Regular site inspections Per facility $75 - $175
Commercial lawn care/landscaping/power-washing
Per individual $25 - $75
contractors
Local ordinance to pick up non-regulated Hotspots Per ordinance $13,000 - $15,000
On-site illicit discharge investigations Per facility $220 - $900
Outreach materials to target business groups Per hour $30 - $45
Presentations to business groups Per hour $40 - $60
Non-regulatory site inspections Per facility $30 - $80
Business recognition programs Per facility $40 - $75
Discounted spill response kits, storm drain
Per facility $60 - $250
plugs, drip pans, tarps
Cost derived from a survey of various communities across the country
4. Estimate program staffing costs-- The final partners who can spread the stewardship or
budgeting step involves estimating staff costs to pollution prevention message. Partners can often
plan, coordinate and administer the source offer more direct, convenient and less expensive
control program. Staffing costs can be a difficult ways to distribute source control practices to the
budget item to project, and vary depending on target population over the long run. Potential
whether staff are paid or volunteer. Some partners include community volunteers,
commitment of local agency staff or contract watershed groups, local educators, private sector
dollars is almost always needed to get the source allies, water and sewer utilities, other
control program started. For example, you government agencies and the local media. This
should plan on at least 200 to 400 hours of time step describes the strategies to recruit and
per subwatershed/year for an outreach motivate potential partners to become involved
coordinator to administer the source control in your source control plan.
program, and an equivalent amount to conduct
USSR surveys and develop the SCP. Additional 1. Community Volunteers -- Community
staff costs may be needed to oversee volunteers are an effective way to spread the
implementation of source control practices. stewardship message. The pool of potential
volunteers in a community may be greater than
Step 10: Put Together a Partnership to you think. According to Roper Surveys, one in
Distribute the Practices 10 residents can be characterized as “community
influential” (NEETF, 2003). These people take
Source control practices require an on-the- an active interest in running their community,
ground delivery system to connect with and are five times more likely to attend a
individual residents or businesses and provide community meeting than their peers. This group
them with the desired level of education, actively seeks environmental information and is
training, direct services or enforcement. This predisposed to support and adopt
step examines the best way to manage the environmentally sound stewardship practices.
distribution of source control practices in a The real trick is to find the best way to reach the
subwatershed. Often, local storm water agencies “influentials” that live or work in your
will spearhead the effort, but other partners can subwatershed. In general, this group is well
play an important role. informed, and can be reached through local
newspapers and community meetings.
A single outreach coordinator really can’t do
much alone. Indeed, the success of the SCP
depends on the number and commitment of

2. Watershed Groups-- Watershed groups should Young (1997) also found that most homeowners
always be courted as source control partners if express a high level of trust in their lawn care
they exist near the subwatershed. Watershed company. A small but growing number of lawn
groups are often credible, low-cost stewardship care companies feel that environmental
retailers directly connected to the community. advertising makes good business sense and can
Existing watershed groups should be invited to increase sales (Israel et al., 1995). If companies
play a major role in delivering a local source can be properly trained in practices to reduce
control program, and communities may want to fertilizer and pesticide inputs, their services
directly contract or out-source storm water should be actively promoted by the source
education and other source control functions to control partnership. Lawn and garden centers are
them. If no group exists, you may want to another potential source control ally. Marketing
consider forming one by investing seed money. research consistently indicates that product
labels and store attendants are the primary
3. Local Educators-- A surprisingly large source of lawn care information for the average
number of educators in the community can resident (Swann, 1999). The key strategy is to
expand your source control partnership. Many substitute watershed-friendly products and train
educators are already promoting similar store attendants to demonstrate them at the point
stewardship messages, such as the local of sale.
cooperative extension office, soil conservation
district, community forester, or state natural 5. Water and Sewer Utilities-- Utilities routinely
resource agency. Other educators can be found reach out to residents via the dreaded service
in local schools, nature centers, museums, bill, which is often accompanied by a cheerful
aquariums, and libraries. Local educators can insert. Water utilities already educate the public
contribute expertise, resources and an existing about water conservation and drinking water
distribution network to your source control quality. Indeed, most water utilities are required
program, and can be tapped to recruit volunteers. to provide annual summaries of drinking water
It is always a good idea to enlist fellow local quality under the Safe Drinking Water Act. In
educators in your source control partnership. addition, sewer utilities may need to publicize
hotlines to report sewage discharges. As a result,
4. Private Sector Allies -- Many private sector local utilities should have a common interest in
companies stand to potentially profit from your source control plan, and may be willing to
improved watershed stewardship. For example, share space in bill inserts and other educational
better stewardship can drum up more sales for products they routinely disseminate.
companies such as septic tank cleaners,
commercial car washes, and quick oil change 6. Other government agencies-- Residents and
franchises, although they may need help crafting businesses routinely intersect with local
their stewardship marketing pitch. government in many ways —not just through the
local storm water agency. Therefore, it is a good
Lawn care companies and landscaping services idea to investigate whether other agencies could
can also be helpful private sector allies. serve as a distribution outlet for source control
Nationally, lawn care companies are used by materials. Examples include city halls, building
seven to 50% of consumers, depending on permits, local inspectors, park events, and
neighborhood income and lot size. Lawn care community planning efforts. Each of these
companies exercise considerable authority over represents an opportunity for free or low-cost
the practices applied to the lawns they tend, as source control interaction. In addition, state and
long as they can still produce a sharp-looking federal enforcement agencies should always be
lawn. For example, 94% of lawn care companies consulted to make sure they are ready to wield
reported that they had authority to change lawn the permit stick when needed.
care practices, and that about 60% of their
customers were “somewhat receptive to new
ideas” according to Israel et al. (1995). De

7. Local Media -- Community newspapers, local communities can make better investment
broadcasters, and community cable access decisions. Seven different kinds of surveys or
channels can become important source control monitoring have been used to evaluate source
partners. Local media offer a direct and low-cost control programs, including the following:
way to spread a stewardship message to a large
segment of the local population, although the 1. Awareness surveys – are residents aware
message needs to be condensed and repackaged of water quality problems, and are they
to fit into the small bits of time or space receptive to change?
available (i.e., a few seconds or minutes of air 2. Practice surveys – what are the actual
time or a couple of column inches of newsprint). practices occurring in neighborhood or
Initially, the best way to utilize local media is to hotspots, and why are they being done?
have them advertise the source control practices 3. Recall surveys – have
that directly serve the community (i.e., residents/operators actually heard or
availability of free soil tests, notification of seen your source control message?
HHW pick-up days, lawn care consultations). 4. Program effort – counts of participation
Most local and community outlets are willing to rates, exposures, inspections in your
announce community events and free services. If source control program.
you want to send a more complex stewardship 5. Before/after behavior surveys—how
message, meet with local editors and producers much have behaviors/operations
to find the best format. changed in the subwatershed as a result
of your source control program?
It also helps to develop a good relationship with 6. Water quality surveys—have
your local weathercaster. Surveys indicate that measurable water quality improvements
the public regards weathercasters as the most occurred in dry weather flows, stream
trusted scientists in the community, and they can quality or pond sediments as a result of
be helpful to impart brief source control source control practices?
messages in their daily and seasonal weather 7. Sustaining stewardship—has the
stories (NEETF, 2003). Tips on training responsibility for source control shifted
weathercasters to communicate environmental from local government to private
stewardship messages can be found at stewardship groups?
www.neetf.org. In larger television markets,
weathercasters have developed websites to Many communities will need to evaluate their
provide the more detailed information about source control programs in the coming years to
stewardship that can’t fit into the few minutes comply with municipal NPDES storm water
each day they have to tell the weather story. An permits. The permits require communities to
excellent example of this approach is the develop measurable goals and implementation
www.watershed.interactive-environment.com milestones for their storm water education and
website, which gets millions of hits from pollution prevention programs. Surveys and
viewers each year. other types of monitoring will be needed to
evaluate source control implementation.
Step 11: Evaluate Progress in
Implementation Maintaining Source Controls Over
Time
The last step in the SCP involves deciding how
to evaluate the effectiveness of your source By their very nature, subwatersheds are quite
control implementation. Regrettably, the impact dynamic. People move in and out, business
of source control plans on pollutant reduction operations come and go, and new neighborhoods
has seldom been assessed. Measurable are built or redeveloped. As a result, source
performance indicators are essential to improve control programs must continually evolve to
the delivery of source control practices so that respond to population changes in the

subwatershed. Source control should never be 4.2 An Example Source Control

considered a one-shot deal, but rather an
ongoing program that is maintained and Plan for Stewardship Branch
enhanced over time. In many cases, the basic
stewardship message is gradually expanded to This section presents an example of how to
incorporate additional behaviors and pollution design and implement an effective source
sources. At the same time, the original control plan for a hypothetical subwatershed,
stewardship message must be continually known as Stewardship Branch (Figure 8). This
repeated until the desired stewardship or 10 square mile subwatershed has suburban
pollution prevention practices are widely residential land comprising 80% of the land use,
adopted by the target population. including more than 20 neighborhoods. The
Maintaining source control programs over the remaining land use in the subwatershed
long run can be a daunting challenge, given local comprises a mix of commercial, institutional and
budget cycles and competing spending priorities. light industrial.
While no firm time frame can be given, it is
doubtful whether most behaviors and operations Step 1: Pick Pollutant of Concern
can be widely adopted in less than three years.
Stewardship Branch flows to a drinking water
Communities have employed several strategies reservoir experiencing problems with nutrient
to maintain source controls over the long run. enrichment. Therefore, the design team had no
First, they have expanded their source control difficulty agreeing that nutrients would be the
partnerships to attract ongoing budget support primary pollutant of concern, but had interest in
and distribute program responsibility. Second, reducing bacteria inputs to the reservoir, as well.
they have sought to gradually “privatize” source
control functions, using watershed groups,
volunteers, local educators and private sector
allies. Lastly, they have sought to demonstrate
the effectiveness of source control practices
through water quality monitoring and attitude
surveys.
Figure 8: Aerial Photo of Stewardship Branch

Step 2: Link Pollutant to Key distributed across many neighborhoods in the

Subwatershed Indicators subwatershed, but septic systems were confined
to a very small cluster in a single neighborhood.
Based on their analysis, the design team decided
The design team then surveyed the entire to concentrate on lawn fertilization, pet waste
subwatershed using the NSA and HSI disposal and golf course management as priority
components of the USSR. After reviewing their nutrient sources in the subwatershed.
NSA data, the team discovered several potential
nutrient indicators within several Since Stewardship Branch is primarily
neighborhoods: residential, the design team wanted to determine
which of the 20 neighborhoods had the greatest
• High input turf potential to generate nutrient pollution. To do
• Accumulation of organic matter in curbs this, they developed a simple neighborhood
and catch basins screening process that focused on four
• Presence of pet waste in the sidewalk neighborhood metrics thought to be strong
zone nutrient indicators: the proportion of high input
• Presence of septic systems turf, overall turf cover, and the presence of pet
• Poor yard waste management waste and lawn clippings in the sidewalk zone.
An example of the neighborhood screening
After further checks for hydraulic connections process developed by the design team is shown
and pollutant accumulation, the team initially in Table 22. In this example, neighborhood 8
identified lawn fertilization, pet waste pickup was targeted as a priority since it scored highest
and failing septic systems as the three most for three of the four nutrient metrics. Based on
probable nutrient sources in the subwatershed. the entire screening analysis, the design team
Pet waste was also identified as a bacteria targeted 11 of the 20 neighborhoods in
source. Stewardship Branch for intensive nutrient
education, along with the golf course noted
Similar analysis of HSI data revealed three earlier.
potential indicators of nutrient pollution in the
subwatershed:
Step 4: Define Priority Outreach
• Commercial landscaping Targets
• Carwash
• Golf course The design team then assembled a contact
database for subsequent outreach for the 11
Subsequent review of HSI data for the priority neighborhoods and the golf course,
commercial landscaping and carwash operations using mailing lists obtained from active
revealed the operations were not hydraulically neighborhood associations, a local direct mailing
connected to the storm drain system, so they firm and personal contacts. The final database
were not given further consideration. The golf Table 22: Example of NSA Metrics Used to Screen
course was deemed a probable nutrient source, Neighborhoods
and was targeted for special management. %
Turf
Cover Pet Front
High
Step 3: Locate Specific Pollutant as % Waste Yard
Input
of Lot Scores Clippings
Source Areas in the Turf
Area
Subwatershed Neighborhood
65 70 Yes 15
8
The design team then examined where nutrient Neighborhood
10 35 No 12
indicators were located across the entire 9
subwatershed. Maps and metrics were prepared Neighborhood
5 35 No 17
that indicated high input turf and pet waste were 10

included contact information on the 1,200 Lakes,” that would be accompanied by

individual homeowners within Stewardship information on how residents could access a
Branch that comprised the target outreach range of free services and resources to practice
population. natural lawn care. The team also crafted a
secondary message, “Scoop Your Poop or End
The design team then consulted with up Drinking It,” to address the pet waste issue.
neighborhood association leaders and others to
get a better handle on resident attitudes toward Step 7: Select the Most Effective
lawn care and pet waste pickup. From this mini- Outreach Techniques
survey, they quickly learned that many
behaviors were deeply rooted in older The design team quickly estimated their target
neighborhoods, and peer pressure was a major outreach population, which consisted of 1,200
motivation factor for current lawn care practices. households in priority neighborhoods (out of a
total of 2,500 for the subwatershed as a whole),
Step 5: Develop an Overall Source nine active neighborhood associations, six
Control Strategy educational outlets, an estimated training
audience of 80 individuals, and a single golf
The design team then met to choose the specific course.
behaviors they wanted to focus on in their
source control strategy. The team agreed that Given that lawn care is inherently seasonal, the
low-input lawn care (N-1) and pet waste pickup design team scheduled their outreach campaign
(N-18) would be the initial priorities, although to achieve 3-4 exposures from April to July each
other lawn behaviors could be added in future year. Given a modest budget, the design team
years. Given current resident attitudes, the team elected to use lower cost outreach techniques to
felt that a carrot strategy would be most advertise the lawn care campaign, including
appropriate to promote low-input lawn care, direct mail, door hangers, exhibits at education
emphasizing passive education, active training, a outlets, presentations at neighborhood
few subsidies and discounts and the formation of associations, and articles in the community
a lawn stewardship group. By contrast, they felt newspaper. The team felt a more direct strategy
pet waste pickup would be best improved should be employed for pet waste pickup, and
through a stick strategy, beginning by notifying elected to provide continuous exposure in the
residents about the existing pooper scooper area that had the greatest dog-walking traffic
ordinance, followed by selective enforcement. (using signs).
Step 6: Craft a Clear and Simple Step 8: Choose Mix of Source Control
Message Practices
The design team thought long and hard about The design team then shifted its focus to choose
how to craft the most effective message for low- the specific source control practices to apply in
input lawn care, since the practice requires the subwatershed. After reviewing its options,
residents to learn and adopt many new the design team selected eight source control
behaviors. The basic prescription of using less practices to implement in Stewardship Branch:
fertilizer, using slow-release fertilizers in the
right season, testing soils, and using grass- • Distribute a slick packet on low-input
cycling mowers to keep clippings on the lawn is lawn care to all households in priority
fairly complex. The team initially considered a neighborhoods
direct and simple message to stop lawn • Establish a “Lawn Master” program to
fertilization and reduce turf area, but felt it train homeowners on natural lawn care
would not be well received. Instead, the team • Set up lawn care exhibits at lawn/garden
settled on a message, “Green Lawns not Green centers

• Offer free soil tests Step 11: Measure Progress in

• Offer free on-site lawn care consultation Implementation
• Establish a lawn care recognition
program The design team developed several performance
• Develop a nutrient management plan for indicators to measure progress made in
the golf course subwatershed source control, including the
• Install five pet waste “pooper scooper” following:
stations and signs
• Total number of educational exposures
Step 9: Estimate Subwatershed Source achieved in the subwatershed
Control Budget • Number of free soil tests provided
• Number of residents who actively
The design team computed a budget for the participated in the lawn masters club or
source control plan that phased in the eight requested lawn care consultations
source control practices over a three-year period. • Development and implementation of a
The budget was based on unit costs and is nutrient management plan for the golf
summarized in Table 23. Overall, the total course
budget to implement the source control plan was • Change in pet waste accumulation in
estimated to be $15 per subwatershed household common areas
per year, or roughly the cost to construct a single
off-site storage retrofit. In addition, the design team added $10,000 to
the overall budget to perform a phone survey
Step 10: Put Together Partnership to about residential lawn practices at the beginning
Deliver Outreach Practices and end of the three-year source control
program. The survey was intended to track
The design team felt that the source control plan changes in homeowner awareness and lawn care
would initially be delivered by a part-time local practices adoption rates over time.
outreach coordinator, although the soil tests and
lawn care consultations would be provided by
the local cooperative extension service office.
The ultimate goal, however, was to shift many
source control responsibilities to the volunteer
lawn masters stewardship club within three
years.
Table 23: Subwatershed Source Control Budget for Stewardship Branch

Practice Year 1 Year 2 Year 3 Total
Passive lawn care outreach $10,200 $6,800 $4,800 $21,800
Lawn masters club $4,600 $9,600 $9,600 $28,800
Lawn care exhibits $3,200 $1,600 $1,600 $6,400
Free soil tests $2,000 $3,000 $3,000 $8,000
On-site lawn consultation $5,000 $8,000 $8,000 $22,000
Green lawn care awards -0- -0- $3,000 $3,000
Pet waste signs $2,000 -0- -0- $2,000
Golf course management plan $3,000 $1,000 -0- $4,000
Total $30,000 $30,000 $30,000 $90,000

4.3 Source Controls: Apply on a Similarly, certain source control practices, such
as ordinances, permit enforcement and direct
Subwatershed or municipal services, can only be fairly and
Community-Wide Basis? equitably administered if they apply to all the
residents in a community-- not just the ones
This manual has presented a retail approach to located in targeted subwatersheds.
deliver pollution source controls at the
subwatershed scale. While a targeted approach Ideally, a community should adopt both a retail
makes sense in the context of subwatershed and wholesale strategy for source control. The
restoration, it may not be the only option for targeted retail approach applied to individual
delivering storm water education and source subwatersheds can be reinforced by a broader
control practices within a community. In some wholesale campaign for the community as a
cases, it may make sense to adopt a “wholesale” whole.
approach that broadcasts the stewardship
message across the entire community. Indeed, it
may be more cost-effective to send some
stewardship messages to the entire community,
since many outreach techniques naturally lend
themselves to a broader geographic area or
audience. For example, the influence of
television, radio, bus signs and newspapers
normally extends well beyond a single
subwatershed.

Chapter 5: Neighborhood Stewardship Profile Sheets
Chapter 5: Neighborhood Stewardship Profile

Sheets
This chapter contains profile sheets describing and variation. The profile sheets also
21 different neighborhood stewardship practices recommend practical techniques to promote
that can prevent storm water pollution or better stewardship behaviors, and provide useful
improve habitat. Each sheet explains how the internet resources and references to consult.
stewardship behavior influences water quality, Neighborhood stewardship practices profiled in
and presents social research about its frequency this chapter include:
Profile Sheet Page
N-1 Reduced Fertilizer Use................................................................................................................. 51

N-2 Reduced Pesticide Use ................................................................................................................ 55
N-3 Xeriscaping .................................................................................................................................. 59
N-4 Natural Landscaping .................................................................................................................... 63
N-5 Tree Planting ............................................................................................................................... 65
N-6 Yard Waste Composting ............................................................................................................. 69
N-7 Soil Reclamation ......................................................................................................................... 71
N-8 Soil Erosion Repair ..................................................................................................................... 73
N-9 Septic System Cleanouts ............................................................................................................. 75
N-10 Safe Pool Discharges .................................................................................................................. 79
N-11 Safe Car Washing ....................................................................................................................... 81
N-12 Driveway Sweeping .................................................................................................................... 83
N-13 Safe De-icer Use ......................................................................................................................... 85
N-14 Household Hazardous Waste Collection ..................................................................................... 87
N-15 Car Fluid Recycling .................................................................................................................... 89
N-16 Downspout Disconnection .......................................................................................................... 91
N-17 Single Lot Controls ..................................................................................................................... 95
N-18 Pet Waste Pickup ......................................................................................................................... 97
N-19 Storm Water Practice Maintenance ............................................................................................ 99
N-20 Bufferscaping ..............................................................................................................................103
N-21 Storm Drain Marking....................................................................................................................105


Neighborhood Source Area: Yard
N-1 REDUCED FERTILIZER USE
Description rooftops, driveways or parking lots (Bannerman

et al., 1993; Steuer et al., 1997; Waschbusch et
The ideal behavior is to not apply fertilizer to al., 2000; Garn, 2002).
lawns. The next best thing for homeowners who
feel they must fertilize is to practice natural lawn Percentage of People Engaging
care: using low inputs of organic or slow release in Fertilizer Use
fertilizers that are based on actual needs as
determined by a soil test. The obvious negative Lawn fertilization is among the most widespread
watershed behavior is improper fertilization, watershed behaviors in which residents engage.
whether in terms of the timing, frequency or rate A survey of lawn care practices in the
of fertilizer applications, or a combination of all Chesapeake Bay indicated that 89% of citizens
three. The other important variable to define is owned a yard, and of these, 50% applied
who is applying fertilizer in the neighborhood. fertilizer every year (Swann, 1999). The average
Nationally, about 75% of lawn fertilization is rate of fertilization in 10 other regional lawn
done by homeowners, with the remaining 25% care surveys was even higher (78%), although
applied by lawn care companies (Figure 1). This this may reflect the fact that these surveys were
split, however, tends to be highly variable within biased towards predominantly suburban
individual neighborhoods, depending on its neighborhoods and excluded non-lawn owners.
income and demographics. Several studies have measured the frequency of
lawn fertilization, and have found that lawns are
How Fertilizer Influences Water Quality fertilized about twice a year, with spring and fall
being the most common season for applications
Recent research has demonstrated that lawn (Swann, 1999).
over-fertilization produces nutrient runoff with
the potential to cause downstream eutrophication A significant fraction of homeowners can be
in streams, lakes, and estuaries (Barth, 1995a classified as “over-fertilizers” who apply
and 1995b). Scientists have also discovered that fertilizers above recommended rates. Surveys
nitrogen and phosphorus levels in lawn runoff indicate the number of over-fertilizers at 50% to
are about two to 10 times higher than any other 70% of all fertilizers (Morris and Traxler, 1996;
part of the urban landscape such as streets, Swann, 1999; Knox et al., 1995). Clearly, many
homeowners, in a quest for quick results or a
bright green lawn, are applying more nutrients to
their lawns than they actually need.
Variation in Fertilization Behavior
Many regional and neighborhood factors

influence local fertilization behavior. From a
regional standpoint, climate is a very important
factor, as it determines the length of the growing
season, type of grass, and the irrigation needed
to maintain a lawn. A detailed discussion of the
Figure 1: Lawn Care Company Truck role these factors play in fertilization can be

found in Barth (1995a). A host of factors also common interest in healthy lawns. The second
comes into play at the individual neighborhood approach is similar in that it involves direct
scale. Some of the more important variables assistance to individuals at their homes (e.g., soil
include average income, market value of houses, tests and lawn advice) or at the point of sale.
soil quality, and the age of the development
(Law et al., 2004). Higher rates of fertilization Techniques to Change Behavior
appear to be very common in new suburban
neighborhoods where residents seek to establish Most communities have primarily relied on
lawns and landscaping. Also, lawn irrigation carrots to change fertilization behaviors,
systems and fertilization are strongly associated. although sticks are occasionally used in
phosphorus-sensitive areas. The following are
Difficulty in Changing Behavior some of the most common techniques for
changing fertilization behaviors:
Changing fertilization behaviors can be hard
since the desire for green lawns is deeply rooted • Seasonal media awareness campaigns
in our culture (Jenkins, 1994; Teyssott, 1999). • Distribution of lawn care outreach materials
For example, the primary fertilizer is a man in (brochures, newsletters, posters, etc.; Figure
the 45 to 54 year age group (BHI, 1997) who 2)
feels that “a green attractive lawn is an • Direct homeowner assistance and training
important asset in a neighborhood” (De Young, • Master gardener program
1997). According to surveys, less than 10% of • Exhibits and demonstration at point-of-sale
lawn owners take the trouble to take soil tests to retail outlets
determine whether fertilization is even needed • Free or reduced cost for soil testing
(Swann, 1999; Law et al., 2004). Most lawn • Training and/or certification of lawn care
owners are ignorant of the phosphorus or professionals
nitrogen content of the fertilizer they apply • Lawn and garden shows on radio
(Morris and Traxler, 1996), and are unaware that • Local restrictions on phosphorus content in
grass-cycling can sharply reduce fertilizer needs. fertilizer
Most residents rely on commercial sources of Good Examples

information when making their fertilization
decisions. The average consumer relies on King County, Washington- Northwest Natural
product labels, store attendants, and lawn care Yard Days. This month-long program offers
companies as their primary, and often exclusive, discounts on natural yard care products and
sources of lawn care information. Consumers are educational information about natural yard care
also influenced by direct mail and word of in local stores throughout King County and
mouth when they choose a lawn care company Tacoma. Education specialists came to Saturday
(Swann, 1999 and AMR, 1997). and Sunday events at some stores and spent time
with buyers to help them make good choices and
Two approaches have shown promise in learn about natural yard care, including the use
changing fertilization behaviors within a of organic fertilizers that don’t wash off into
neighborhood, and both involve direct contact streams and lakes as easily as "quick release"
with individual homeowners. The first relies on chemical fertilizers. For more details, consult:
using neighbors to spread the message to other http://dnr.metrokc.gov/swd/ResRecy/events/natu
residents, through master gardening programs. ralyard.shtml
Individuals tend to be very receptive to advice
from their peers, particularly if it relates to a

North Carolina Department of Agriculture Free University of Rhode Island Cooperative

Residential Lawn Soil Testing. Residents can get Extension Home*A*Syst Healthy Landscapes
a free soil test to determine the exact fertilizer Program
and lime needs for their lawn, as well as for the http://www.healthylandscapes.org/
garden, landscape plants and fruit trees.
Information sheets and soil boxes are available University of Maryland Cooperative Extension -
from various government agencies, or local Home and Garden Information Center.
garden shops and other businesses. For more http://www.agnr.umd.edu/users/hgic/
information, consult:
http://www.ncagr.com/agronomi/stfaqs.htm Turf and Landscape Best Management
Practices. South Florida Water Management
Minnesota Department of Agriculture District and the Broward County Extension
Phosphorus Lawn Fertilizer Use Restrictions. Education Division
Starting in 2004, these restrictions limit the http://www.sfwmd.gov/org/exo/broward/c11bm
concentration of phosphorus in lawn care p/fertmgt.html
products and restrict its application at higher
rates to specific situations based on need. Florida Yards and Neighborhoods Handbook: A
http://www.mda.state.mn.us/appd/ace/lawncwat Guide to Environmentally Friendly Landscaping
erq.htm http://hort.ufl.edu/fyn/hand.htm
Top Resources University of Minnesota Extension Service Low-

Input Lawn Care (LILaC)
Cornell Cooperative Extension. The http://www.extension.umn.edu/distribution/horti
Homeowner’s Lawn Care Water Quality culture/DG7552.html
Almanac.
http://www.gardening.cornell.edu/lawn/almanac/ Austin TX, Stillhouse Spring Cleaning
index.html http://www.ci.austin.tx.us/growgreen/stillhouse.
htm
Figure 2: Educational Brochure on Fertilizer

Source: http://www.state.ma.us/dep/brp/wm/files/fertiliz.pdf


N-2 REDUCED PESTICIDE USE
Description study, one or more pesticides were detected in

99% of urban streams sampled (USGS, 2001).
The ideal watershed behavior is to not apply any Pesticide levels in urban streams exceeded
insecticides or herbicides to the lawn or garden. national water quality standards to protect
Many residents, however, still want to control aquatic life in one out of every five samples.
pests and weeds, so the next best behavior is a Even more troubling was the finding that 100%
natural approach that emphasizes limited use of of fish in urban streams had detectable levels of
safer chemicals, proper timing and targeted pesticide in their tissues, with 20% exceeding
application methods. The negative residential recommended guidelines for fish-eating wildlife
behavior is over-use or improper application of (such as racoons, kingfishers, ospreys and
insecticides and herbicides that are known to eagles).
have an adverse impact on aquatic life.
Percentage of People Engaging
How Pesticide Use Influences in Pesticide Use
Subwatershed Quality
About half of Chesapeake Bay residents
The leading source of pesticides to urban reported that they had applied pesticides to their
streams is homeowner applications in the lawn lawn or garden (Swann, 1999). Surveys on
and garden to kill insects and weeds. The residential pesticide use for other regions of the
pesticides of greatest concern are insecticides, country indicate that home pesticide use varies
such as diazinon and chloropyrifos, and a large greatly, ranging from a low of 17% to a high of
group of herbicides (CWP, 2003; USGS, 2001; 87% of households (Swann, 1999). According to
Schueler, 1995; Figure 1). Very low levels of EPA, the average acre of maintained suburban
these pesticides can be harmful to aquatic life. lawn receives five to seven pounds of pesticides
According to a national monitoring each year.
Variation in Pesticide Use
Many regional and neighborhood factors

influence the degree of local pesticide use. From
a regional standpoint, climate is an extremely
important factor. For example, insecticides are
applied more widely in warmer climates where
insect control is a year round problem (e.g., 50
to 90% of warm-weather residents report using
them). This can be compared to 20 to 50% of
insecticide use reported for colder regions where
hard winters help keep insects in check
(Schueler, 2000b). By contrast, herbicide
application rates tend to be higher in colder
climates in order to kill weeds that arrive with
the onset of spring (e.g., 60 to 75% of cold
Figure 1: Bag of weather residents report use).
Pesticide Granules

Many neighborhood factors can play a strong Confusion also stems from the recent growth of
role in the degree of pesticide use. These include “weed and feed” lawn care products that
lot or lawn size, presence of gardens, condition combine weed control and fertilizer in a single
of turf, presence or absence of irrigation and bag. In one Minnesota study, 63% of residents
neighborhood age. The average income and reported that they used weed and feed lawn
demographics within a neighborhood are also products, but only 24% understood that
thought to play a strong role, particularly if they were applying herbicides to their lawn
residents rely on lawn care and landscaping (Morris and Traxler, 1996).
companies to maintain their lawns.
Techniques to Change the Behavior
Difficulty in Changing the Behavior
Most communities rely on the same basic
Pesticide use is a difficult behavior to change for combination of carrots to change pesticide use as
several reasons. First, many residents want a they do for fertilizer use, since they are so
quick and effective solution to their pest interrelated. The following are some of the most
problems. Second, many residents lack common techniques to change pesticide use:
awareness about the link between their pesticide
use and stream quality. Lastly, many residents • Seasonal media awareness campaigns
rely on commercial sources of information when • Distribution of lawn care outreach materials
choosing pesticides, and lack understanding of (brochures, newsletters, posters, etc.)
safer alternatives and practices. As with • Direct homeowner assistance and training
fertilizers, product labels are the primary source • Master gardener program
of information about pesticides. Nearly 90% of • Exhibits and demonstration at point of sale
homeowners rely on them to guide their at retail outlets
pesticide use (Swann, 1999). In addition, many • Pest advice hotlines
residents are unaware of the pesticide • Training, certification and/or licensing of
application practices that their lawn care lawn care professionals and pesticide
company applies to their yard and prefer to rely applicators
on professional know-how (Knox et al., 1995). • Radio lawn and garden advice shows
Figure 2: Educational Pesticide Brochure

Source: http://www.lacity.org/SAN/wpd/index.htm

Good Examples Top Resources
Perdue Pesticide Program - Web-based program Tips for Homeowners on Hiring a Pesticide
to help comply with the State of Indiana Applicator
regulations that help homeowners use pesticides http://www.epa.gov/oppfead1/Publications/Cit_
effectively and safely. According to Indiana law Guide/citguide.pdf
and recently enacted regulations, all retail
establishments in the state that sell gardening Try Pesticide Alternatives
and pest control products and offer http://www.mda.state.md.us/pdf/Tip1.pdf
recommendations on their use must be licensed
as consultants, while their sales associates must Washington State University - Pesticide Safety
be trained to knowledgeably disseminate product Programs
information. http://pep.wsu.edu/psp/
http://www.btny.purdue.edu/PPP/
National Pesticide Information Center
Green Communities Association’s Pesticide Site - Provides objective, science-based
Free Naturally: A Campaign to Reduce information about a variety of pesticide-related
the Cosmetic Use of Pesticides - The campaign subjects, including pesticide products,
includes an Action Kit that includes pesticide- toxicology, and environmental chemistry.
free lawn signs, fact sheets on health impacts, http://npic.orst.edu/
tips on how to engage neighbors in discussions
about pesticide use, a children's activity pack, IPM Practitioners Association IPM ACCESS
and information on effective alternatives to Webpage
pesticides, including home recipes. http://www.efn.org/~ipmpa/
http://www.gca.ca/indexcms/index.php?pfn
Our Water, Our World
http://sfwater.org/detail.cfm/MC_ID/4/MSC_ID/
78/MTO_ID/NULL/C_ID/1402
Grow Green: Landscaping for Clean Water

http://www.ci.austin.tx.us/growgreen/default.htm


N-3 XERISCAPING
Description gallons of water for outdoor use each year,

mostly for lawn watering. Outdoor water use
The ideal watershed behavior is to maintain a rates are often twice as high in arid and semi-
lawn with native species that does not require arid regions of the country (Solley et al., 1998).
watering or irrigation at all (Figure 1). The next
best thing is to water the lawn sparingly so water Lawn watering has a different impact at the
does not run off to impervious areas or local subwatershed level. Generally, most of the water
waterways. The negative behavior is over- supply delivered to a household originates from
watering to the extent that water and its outside the watershed. When homeowners water
associated pollutants reach the storm drain their lawns, some fraction of this “imported”
conveyance system and enter the stream. water may reach the street and eventually return
to the stream itself. Thus, in arid and semi-arid
How Lawn Watering Influences subwatersheds, overwatering can actually
Watershed and Subwatershed Quality increase dry weather flows in streams. The
compacted nature of lawns can increase the
Lawn watering exerts different impacts at the runoff potential (Legg et al., 1996).This may not
watershed and subwatershed scale. At the necessarily be a negative impact, although it is
watershed scale, over-watering cumulatively likely that this nuisance water may carry
leads to sharp increases in river withdraws or nutrients and pesticides to the stream.
groundwater pumping that can affect regional
water supplies, as well as aquatic resources. Percentage of Homeowners
Normal daily household water demands can Engaging in Lawn Watering
double or even triple during really hot and dry
summer days, which can put a great deal of Outdoor water use is nearly universal, but there
stress on rivers, reservoirs and groundwater at a are sharp differences from household to
time when they are frequently at their lowest household in actual water use. Nationally, the
levels. According to Steiner et al. (2000), the average person uses 154 gallons of water per
average home in the Washington D.C. day, with 42% used indoors and 58% used
metropolitan area consumes about 22,700 outdoors (AWWARF, 1999). Curtailing outdoor
water use is an important theme of urban water
conservation (Figure 2).
Factors that Contribute to Variation in

Lawn Watering
As might be expected, lawn watering and

outdoor water use are greatest in arid and semi-
arid regions, although high use is noted in nearly
all urban areas during dry weather, and
particularly during times of drought. Several
neighborhood factors explain the variability in
outdoor watering, the most notable of which is
the proportion of homes that have permanent
Figure 1: Xeriscape Garden

irrigation systems installed (AWWARF, 1999). Techniques to Change the Behavior

Other key factors include lawn size, income, the
price of water, and the age of the lawn (younger A range of both carrots and sticks can be used to
lawns require more watering). influence watering behavior, including:
Difficulty in Changing Lawn Watering • Seasonal watershed conservation campaigns

Behavior (e.g., radio, TV, newspaper and billboards)
• Distribution of xeriscaping and water
Lawn watering is one behavior that residents conservation education materials (e.g. bill
show some willingness to change. Perhaps the inserts, brochures, newsletters, posters, etc.)
best example is the widespread response to • Demonstration gardens
outdoor watering restrictions in times of drought • Discounts/rebates for efficient sprinklers and
or water emergency. Sharp reductions in lawn irrigation system
watering can be achieved even without a crisis. • Differential water rates to discourage
excessive use during peak periods (pricing)
• Water bill credits for installing xeriscapes
• Voluntary or mandatory outdoor water
restrictions
Figure 2: Educational Xeriscaping Brochure

Source: http://www.sfwmd.gov/images/pdfs/splash/splxeris.pdf

Corpus Christi Texas, Xeriscape Learning Colorado Springs Utilities Xeriscape Page
Center and Design Garden. A demonstration http://www.csu.org/xeri/
garden at the entrance to the Corpus Christi
Museum of Science and History demonstrates Xeriscape Gardening
xeriscape principles to about 150,000 residents This web page contains information about
and tourists annually. xeriscape planning and design, practical turf
http://www.cctexas.com/?fuseaction=main.view areas, appropriate plant selection, soil
&page=1182 improvement, use of mulches, efficient
irrigation, and appropriate maintenance.
Metropolitan Water District of Southern http://www.xeriscape.org/
California- On-line Watering Calculator and
Watering Index California Urban Water Conservation Council -
This tool developed by the City of San Diego H2ouse Water Saver Website
estimates the right amount of water for your This website includes specific actions residents
landscape or garden every week and can take to conserve water indoors and outdoors.
demonstrates how to adjust your watering www.h2ouse.org
schedule.
http://www.mwdh20.com/mwdh2o/pages/conser American Water Work Association (AWWA) -
v/conserv01.html WaterWiser Website
WaterWiser is an interactive web site that strives
Las Vegas Valley Groundwater Management to meet the information needs of the water
Program -Conservation Incentive Program. conservation community and the drinking water
Southern Nevada Water Authority (SNWA) industry. The site provides news, information,
offers a Water Smart Landscapes Rebate research results, discussion forums, references, a
Program that gives residential property owners a calendar of events, searchable information
rebate of 40 cents per square foot when they databases, and other resources primarily targeted
upgrade some or all of their water-thirsty grass to water conservation professionals, but freely
to xeriscape, a lush yet water-efficient accessible to others in the water industry and the
landscape. general public.
http://www.lasvegasgmp.com/html/gwupdate_su http://www.awwa.org/waterwiser
mmer2002.html
EPA's Water Efficiency Program
http://www.epa.gov/owm/water-efficiency/


N-4 NATURAL LANDSCAPING
Description plants or landscape for wildlife or watershed

appears to constitute a much smaller niche market.
The ideal watershed behavior is to replace
existing turf cover with native species of annuals, Variation in Landscaping Behavior
perennials, shrub and forest cover in mulched
beds that produce less runoff and create backyard Native plant species are adapted to local
habitat. The negative watershed behavior is differences in soil, rainfall and temperature
exclusive reliance on turf cover in the yard and/or conditions. Neighborhood factors such as
use of non-native invasive species that can spread neighborhood age, lot size, income level and
from the yard into adjacent stream corridors or watershed awareness appear to influence the
natural area remnants. promotion of natural landscaping.
How Natural Landscaping Influences

Subwatershed Quality a
The cumulative effect of natural landscaping

practices on subwatershed quality are hard to
quantify, but can provide some clear benefits.
First, reduced turf area produces more natural
hydrologic conditions in the yard, since mulched
beds intercept and adsorb rainfall and can produce
less runoff (Figure 1). Natural landscaping also
creates native habitats, increases forest cover, and
creates a natural seed bank of native plant species
in subwatersheds. Natural landscaping can also
prevent the spread of invasive non-native plant b
species into the stream corridor, which is an
increasing problem in many urban subwatersheds.
English ivy, bamboo, and other fast-spreading
non-native species can quickly dominate the plant
community of the urban stream corridor.
Percentage of Homeowners
Engaging in Natural Landscaping
The proportion of homeowners that engage in

natural landscaping is poorly understood at both Figure 1: Before (a) and After (b) Natural
the national and neighborhood level. About half of Landscaping
Americans report that home gardening and
landscaping is one of their major hobbies (Figure 1),
but the proportion using native

Difficulty in Changing Landscaping Village of Long Grove, IL - Village Code. Natural

Behavior landscaping is encouraged in the city code, which
states “impervious surfaces, shall not exceed forty
While natural landscaping practices have been percent (40%) of the total lot area. The remaining
growing in recent years, there are a number of minimum sixty percent (60%) of the lot area shall
barriers to more widespread implementation. The be maintained as a ‘green area’ and shall consist
first barrier is that many homeowners are not of native wild areas, grass, trees, ponds or other
aware of which plant species are native or non- natural vegetation.” The code also does not limit
native, and they do not know the benefits of residential vegetation height, which in other
natural landscaping. Second, native plant communities can limit use of natural plant species.
materials are not always widely available at http://www.longgrove.net/
garden centers and nurseries. Third, some
communities still have weed and vegetation Top Resources
control ordinances that discourage natural
landscaping. National Wildlife Federation - Natural Back Yard
Habitat Program. The Backyard Wildlife Habitat
Techniques to Promote Natural program educates people about the benefits and
Landscaping techniques of creating and restoring natural
landscapes. Through a backyard wildlife
A range of carrots and sticks can help promote “certification” process, guided efforts of
more widespread use of natural landscaping in a homeowners and other community members to
subwatershed, including: improve wildlife habitat where they live and work
are formally acknowledged.
• Conventional outreach on natural landscaping http://www.nwf.org/backyardwildlifehabitat/
(brochures, newsletters, plant guides)
• Backyard habitat programs Alliance for the Chesapeake Bay - Bayscapes.
• Free or reduced mulch This website provides practical guidance on how
• Distribution of free or discounted native plant to design a “Bayscape,” which is a watershed
material friendly form of natural landscaping.
• Repeal of local weed ordinances with natural http://alliancechesbay.org/bayscapes.cfm
landscaping criteria
• Support of garden clubs and native plant Wild-Ones- Native Plants, Natural Landscaping
societies Publications and Model Ordinances. Website
• Demonstration gardens (e.g. Bayscapes) contains a wealth of information on natural
• Invasive species alerts landscaping, including the Wild Ones Handbook -
• Promotion of native plant nurseries a compendium of useful information for the native
• Homeowner award/recognition programs plant landscaper and wildflower gardener,
• Xeriscaping rebates appropriate for all bioregions. The site also
provides vegetation and weed control model
Good Examples municipal ordinances that encourage the use of
native plant communities as an alternative in
City of Austin, TX - WaterWise Program. Owners urban landscape design. http://www.for-wild.org/
of new and existing homes may qualify for rebates
up to $500 for Water Wise plantings of trees and
shrubs. The goal of this program is to install a
quality, low water use, low maintenance native
landscape.
http://www.ci.austin.tx.us/watercon/wwlandscape.
htm

N-5 TREE PLANTING
Description branches and leaves of the forest canopy help

intercept and slowdown rainfall. For example, a
The ideal watershed behavior is to ultimately large oak tree can intercept and retain more than
achieve a mature tree canopy that covers more 500 to 1,000 gallons of rainfall in a given year,
than 50% of residential lots within a which is roughly equivalent to a rain barrel in
neighborhood through tree planting and care terms of runoff reduction (Cappiella, 2004).
(Figure 1a). The negative watershed behavior is According to American Forests (1999), a healthy
tree clearing that reduces existing tree canopy on forest canopy can reduce storm water runoff by
a residential lot and in neighborhoods (Figure as much as 7% in a neighborhood.
1b).
A healthy residential forest canopy provides
How Tree Planting Influences many additional environmental and economic
Subwatershed Quality benefits within a neighborhood. These include
savings on home heating and cooling costs,
Forested neighborhoods have a distinctly higher property values, shading, removal of air
different hydrological profile than non-forested pollutants, and noise reduction (Cappiella,
neighborhoods. For operational purposes, 2004).
American Forests defines forested
neighborhoods as having at least 50% forest Percentage of Homeowners
canopy covering the residential lot. The Engaging in Tree Planting
Regional GIS analyses of urban areas conducted

a
by American Forests (2001) reveal that about
60% of neighborhoods have less than 50% forest
canopy cover. The actual rate of tree planting is
a poorly understood residential behavior. The
actual rate of tree planting is a poorly
understood residential behavior. A survey in the
Chesapeake Bay watershed indicated that 71%
of residents had planted a tree within the last
five years (CBP, 2002). Tree planting rates by
homeowners of around 50% were reported in
b urban metropolitan areas such as Baltimore, MD
and Washington, D.C.; however, more research
is needed to determine the frequency and impact
of tree planting in urban subwatersheds.
Figure 1: Lots with Extensive Tree Cover (a) and

Less Tree Cover (b)

Variation in Tree Planting Behavior
Trees may not be part of the native plant

community in some regions of the country, and
specific tree or prairie species will be
determined by local climate and soils. Also,
concerns about fire safety may make the 50%
forest canopy goal impractical in regions that
experience wildfires. At the neighborhood level,
several factors influence the extent of forest
canopy that can be attained. Probably the most
important factor is the neighborhood age, as
recently constructed neighborhoods generally
lack established forest cover (Figure 2). Other Figure 2: Newly Planted Trees in a New
factors include the existing forest canopy, lot Neighborhood
subsidies or rebates for energy conservation
plantings, size and soil depth.
Good Examples
Difficulty in Increasing Tree Planting Slinger, WI -Residential Tree Power Incentive

Behavior Program. The electric utility in this community
offers cash incentives for planting deciduous
Generally, tree planting is a relatively easy trees that conserve energy by providing
behavior to encourage, although it may take significant shading of an air conditioning unit or
decades to grow a mature canopy on a the south or west exposure of a home upon tree
residential lot. Perhaps the biggest barrier to maturity.
overcome is to find the best locations in the yard http://www.slinger-wi-usa.org/utilityprograms.htm
to plant trees that can grow to maturity (e.g.,
away from overhead powerlines, underground Tucson Electric Power (TEP) Tree Planting
utilities, septic systems, etc.). The second Incentives for Residents. TEP, working with the
concern is proper planting and care techniques to Trees for Tucson program, offers residents up to
ensure that trees can survive and flourish in the two five-gallon size trees at $3.00 per tree for
critical first few years after they are planted. planting on the west, east or south side of their
Third, some localities may discourage tree homes. The program has distributed more than
planting in the right-of-way due to maintenance 22,000 trees since its inception, and also
concerns and pavement cracking. provides information to homeowners,
neighborhood groups, and schools on low-water
Techniques for Increasing Residential species appropriate to the local environment, and
Forest Canopy Cover optimum placement of trees for energy and
water conservation.
A series of techniques can promote tree planting http://swenergy.org/programs/arizona/utility.htm
and discourage tree clearing:
• Distribution of outreach materials on tree

planting (brochures, newsletters, plant
guides)
• Tree clearing ordinances and permits
• Direct forestry assistance
• Free seedlings or other native tree stocks
• Native tree planting guidebooks

Banks and Buffers: A Guide to Selecting Native Treelink

Plants for Streambanks and Shorelines. http://www.treelink.org/
Produced by the Tennessee Valley Authority,
this guide includes a software application to National Tree Trust
assist in plant selection. It also contains selected http://www.nationaltreetrust.org/
characteristics and environmental tolerances of
117 native plants and over 400 color Treepeople
photographs illustrating habitat and growth http://www.treepeople.org/
form.
http://www.tva.gov/river/landandshore/stabilizat Society of Municipal Arborists
ion/index.htm http://www.urban-forestry.com/
National Arbor Day Foundation Awards Urban Forest Ecosystems Institute

This award recognition program honors the http://www.ufei.calpoly.edu/
achievements of citizens, communities, the
media, and schools whose work in the cause of USDA Forest Service, Northeastern Research
tree planting, care, and conservation have set an Station
example of excellence. Applications are http://www.fs.fed.us/ne/
submitted through the Department of Natural
Resources to the National Arbor Day USDA Forest Service, Southern Region
Foundation. Contact: DNR - Forest Service http://www.urbanforestrysouth.org/
regional office or The National Arbor Day
Foundation, 100 Arbor Avenue, Nebraska City, USDA Forest Service, Pacific Northwest
NE 68410. http://www.arborday.org/ Research Station
http://www.fs.fed.us/pnw/
Top Resources
USDA Forest Service, Pacific Southwest
American Forests - CityGreen GIS software Research Station
http://www.americanforests.org./ http://www.fs.fed.us/psw/
Center for Urban Forest Research

http://wcufre.ucdavis.edu/
Guidelines for Developing and Evaluating Tree

Ordinances
http://www.isa-
arbor.com/publications/ordinance.aspx


N-6 YARD WASTE COMPOSTING

Description off to the storm drain system, whether it consists
of grass clippings, fallen leaves or organic debris
The ideal watershed behavior is to recycle or accumulating on impervious surfaces and street
compost yard waste entirely within the yard, so gutters. The second concern is dumping yard
that it stays out of the solid waste stream and the wastes in the stream corridor itself.
storm drain system. The next best behavior is
curbside yard waste collection that keeps Percentage of Residents Engaging
organic matter from the storm drain system in Yard Waste Composting
(Figure 1). The negative behavior is to blow or
rake yard waste into the gutter and storm drain Based on municipal surveys, the average rate of
system or dump it into the stream corridor or backyard composting of yard waste ranges from
natural areas. one to 5% of households, although participation
rates as high as 10% have been observed after
How Yard Waste Influences Watershed intensive municipal education and subsidy
and Subwatershed Quality programs. Much higher rates have been reported
for recycling of grass clippings, whether by
The major benefit of managing yard waste is composting or use of grass-cycling mowers.
realized at the regional or watershed level, Surveys indicate about 40 to 70% of households
where it can preserve local landfill capacity by currently recycle grass clippings, with higher
keeping organic waste out of the trash stream. rates reported in communities that prohibit
Yard waste normally comprises about 10% of grass-clippings in regular trash pickup (Smith,
the annual waste stream during the year, but this 1996; DeYoung, 1997; Morris and Traxler,
rises to almost 70% during the fall. The impact 1996; and Knox et al., 1995). The highest
of yard waste at the subwatershed level is poorly homeowner participation rates are noted for
defined, but can be significant, at least on a curbside leaf and yard waste collection (50 to
seasonal basis. The major concern is the 70%), which is not surprising given the
potential for nutrient and organic matter to wash convenient nature of this municipal service. It is
worth noting that communities need to educate
homeowners to keep leaves out of streets and
gutters during seasonal curbside pick-up where
they can easily reach the storm drain system.
Variation in Yard Waste Behavior
Regional factors influencing the generation and

disposal of yard waste include the length of
growing season, the presence of deciduous trees,
and annual rainfall. Neighborhood factors
contributing to the generation of yard waste are
large lot size or turf area, high forest canopy,
low usage of lawn care or landscaping
companies, and older neighborhoods. The actual
Figure 1: Curbside Yard Waste Pick-up rate of participation in various yard waste

programs depends largely on their ease and participate in the curbside yard waste collection
convenience, as well as the degree of outreach, homeowners need to purchase stickers for a
notification and education employed by the nominal fee to place on yard waste bags.
municipality. Mulching is recommended as an alternative no-
cost disposal method. Free leaf pick up is
Techniques to Change the Behavior provided in the fall.
http://www.vniles.com/Pages/yard%20waste%2
To promote better management of yard wastes, 0collection.asp
communities can facilitate backyard composting
and “grass-cycling” lawnmowers, arrange City of Gresham, OR Yard Debris Exemption
seasonal curbside yard waste collection, and/or Program - Residents can receive a $3.65
prohibit yard waste from regularly scheduled reduction on their garbage bill when they agree
trash pickup. Other techniques include: to compost yard waste instead of having it
picked up by the curbside yard-debris collection
• Conventional outreach methods (bill inserts, program. The approval process requires an
brochures, newsletters, neighborhood application and a site inspection by a Master
meetings) Gardener and composting expert who inspects
• Regular yard waste collection the homeowner composting system before
• Fall leaf collection granting the exemption.
• Seasonal collection (e.g., Christmas trees) http://www.ci.gresham.or.us/departments/cao/gr
• Distribution of free or discounted compost esham_municipal_code/chapter_7/25/450.html
bins
• Ban on lawn clipping pickup Top Resources
• Promotion of grass-cycling
• Notification about keeping leaves out of USEPA- Composting Materials - Waste
gutters during fall leaf pick-up Prevention, Recycling, and Composting
Options: Lessons from 30 Communities;
Good Examples Composting, Yard Trimmings, and Municipal
Solid Waste; and Innovative Uses of Compost:
Fort Worth, TX. Division of Environmental Erosion Control, Turf Remediation, and
Management -“Don’t Bag it” Program Landscaping
The City of Fort Worth requires that, if grass http://www.epa.gov/compost/
clippings are put out for pick-up, they be
contained in paper yard bags to be sent to a Master Composter
composting facility instead of the landfill. Under http://www.mastercomposter.com/
the "Don't Bag It" program homeowners are
encouraged to leave lawn clippings on the grass Compost Guide Web Page
to allow them to work themselves back into the http://www.compostguide.com/
soil. Residents that have followed this lawn care
plan report that they mow their lawns in 38% Recycle Your Grass Clippings
less time than when they bagged their grass http://ucce.ucdavis.edu/files/filelibrary/1808/386
clippings. They also found that their lawns are 8.doc
30% better than they were before the "Don't Bag
It” campaign. "Don't Bag It" Lawn Care
http://www.fortworthgov.org/dem/dontbag.htm http://muextension.missouri.edu/xplor/agguides/
hort/g06959.htm
The Village of Niles, IL - Yard Waste Collection
The Village of Niles offers an optional yard Washington County, Minnesota, Recycling &
waste collection service to help residents comply Yard Waste
with an Illinois law that requires the separation http://www.co.washington.mn.us/info_for_resid
of yard waste from regular garbage. To ents/environment/yard_waste/


N-7 SOIL RECLAMATION
Description conditions in residential subwatersheds. In

addition, reduced runoff from reclaimed lawn
The ideal watershed behavior is to reduce soil soils may also reduce nutrient and sediment
compaction and restore hydrologic properties on loading to surface waters. It is worth noting that
residential lawns through soil amendments and lawn reclamation is still experimental, and that
conditioning. Many urban lawns have been no subwatershed has received widespread yard
highly compacted as a result of past reclamation yet.
construction, soil disturbance and ongoing
human traffic (Figure 1). This behavior seeks to Percentage of Homeowners
recover the porosity and bulk density of soils by Engaging in Soil Reclamation
incorporating soil amendments or conditioners
into the lawn, such as compost (McDonald, Since this is a new and costly behavior to
1999). Soil reclamation improves the practice, it is doubtful whether more than a small
hydrological properties of the lawn by percentage of homeowners currently engage in
promoting more storage and infiltration, and lawn reclamation.
producing less runoff.
Variation in Lawn Reclamation
How Soil Reclamation Influences
Subwatershed Quality Given that lawn reclamation is so new, little is
known about regional or neighborhood factors
Lawns are not the sponge many people think. that might lead to greater application. Two
Most lawn soils are extremely compacted, and factors, however, are likely to be important. The
recent research indicates that about half of all first is the degree of existing compaction
rain storms produce at least some runoff from through the soil profile and its effect on runoff
lawns (Schueler, 2000a). Therefore, widespread generation. Much of the pioneering work on soil
application of lawn reclamation practices may amendments has been done on glacial till soils
show promise to improve hydrological that are close to the surface. Therefore, the
porosity and hydrologic soil group of parent
soils are worth investigating.
The second key factor involved in soil

reclamation is its relatively high cost, which can
run from $2,000 to $10,000 per acre, depending
on the availability of discounted compost and
homeowner labor (Chollak and Rosenfeld,
1998). Given that soil reclamation is expensive,
time consuming, and essentially requires
complete lawn replacement, this behavior will
undoubtedly require significant subsidies,
discounts or other incentives to achieve greater
subwatershed implementation.
Figure 1: Soil Compaction During
Remodeling

Techniques to Promote Lawn Good Examples

Reclamation
City of Seattle. The City has prepared an
Several potential techniques can be used to excellent guide on lawn compost amendments.
promote lawn reclamation: Entitled How Soil Amendments and Compost
can Aid in Salmon Recovery, this detailed guide
• Conventional outreach materials (brochures, is available from
guides, etc.) http://depts.washington.edu/cuwrm/publictn/s4s.
• Free soil testing pdf
• Subsidies
• Free or discounted compost Top Resources
• Direct technical assistance (e.g.,
municipality or local cooperative extension Low Impact Development Center: Soil
office) Amendments
• Credits or rebates on storm water utility fees http://www.lid-
stormwater.net/soilamend/soilamend_home.htm
USDA Natural Resources Conservation Service

http://www.il.nrcs.usda.gov/technical/engineer/u
rban/tech_notes/technote2.html
Improve the Health of Your Soil

http://www.ci.eugene.or.us/PW/storm/Publicatio
ns/healthy soil.pdf

N-8 EROSION REPAIR
Description Percentage of Homeowners

Engaging Erosion Repair
While most yards have extensive vegetative
cover, soil erosion can occur on steep slopes, in Reliable percentages could not be developed to
bare patches, and around driveways. The ideal profile the proportion of homeowners that repair
watershed behavior is to survey the yard for any soil erosion.
patches of exposed soils and establish a fast-
growing grass or ground cover (Figure 1). The Factors that Contribute to Variation in
negative watershed behavior is to allow erosion Lawn Erosion
to continue unchecked. In most cases, existing
residential yards are exempt from local erosion Climate appears to play a major role in
and sediment control laws, which means that a residential soil erosion problems. For example, it
voluntary approach to erosion control is needed. is extremely difficult to maintain a vigorous
ground cover on yards in arid and semi-arid
climates without supplemental irrigation.
Consequently, yards in these regions tend to
have higher sediment erosion rates. Also, yards
in regions with heavy snowfall or hard winters
often require spot re-seeding in the spring.
Neighborhood factors also play a strong role.
For example, exposed soils are considered a
social anathema in neighborhoods where turf
care is widely practiced. Other factors that
contribute to the potential for yard erosion are
small lot size, heavy foot or vehicular traffic,
inadequate parking capacity, older
Figure 1: Reseeded Areas on a Lawn neighborhoods, and the absence of a strong
neighborhood or civic association.
How Lawn Erosion Influences Techniques to Address Soil Erosion
• Conventional outreach methods (bill inserts,
Source area monitoring has revealed that some brochures, newsletters, neighborhood
of the highest sediment concentrations in meetings)
residential neighborhoods are generated from the • Distribution of free or discounted mulch
yard (CWP, 2003). In many cases, erosion • Distribution of free or discounted grass
occurs in areas of the yard that are close to patch repair kits
driveways, sidewalks and roads, or are directly • Technical assistance on solving severe
in the flow path of storm water runoff. Bare erosion problems on steep slopes
patches of exposed soils can be caused by • Non-regulatory erosion and sediment control
vehicles, snowplows, plant dieback, foot traffic (ESC) consultations
and many other disturbances. • Enforcement actions under existing ESC,
water quality, or nuisance ordinances

Riparian Homeowner's Stewardship Project Erosion in Your Own Backyard (Virginia

(Ingham County, MI). County staff developed Cooperative Extension). This fact sheet
and distributed the Red Cedar River Riparian emphasizes how a properly planted landscape is
Homeowner's Handbook to more than 300 the best protection against erosion.
individual homeowners, local government http://www.ext.vt.edu/departments/envirohort/ar
officials, and other interested groups, and ticles/lawns_and_landscaping/erosion.html
conducted individual, on-site consultations with
interested homeowners on buffer strip design University of Rhode Island Cooperative
and erosion control. Extension Home*A*Syst
http://www.glc.org/basin/project?id=74 http://www.uri.edu/ce/wq/has/html/has.html
Reducing Erosion and Runoff Information

Webpage (Master Gardeners). This website
covers signs of erosion and runoff, reasons to
control runoff and erosion, using plants to
reduce erosion, handling steep slopes, ground
cover selection, and building and protecting soil.
http://www.mastergardenproducts.com/sustainab
lelandscape/erosion.htm

N-9 SEPTIC SYSTEM MAINTENANCE
Description bacteria into the stream. According to the U.S.

EPA (2002), more than half of all existing septic
While most urban subwatersheds are served by systems are more than 30 years old, which is
sewers, some still rely on septic systems for well past their design life. The same study
sewage disposal, particularly in less developed estimates that about 10% of all septic systems
subwatersheds that may lie outside of the sewer are not functioning properly at any given time,
service envelope. The ideal watershed behavior with even higher failure rates in some regions
is to regularly inspect and maintain septic and soil conditions. It is extremely important to
systems, make repairs as needed, and prevent understand resident behavior in regard to
disposal of household chemicals through the inspection, pump out and repair, particularly if
leach field. The accepted practice is to inspect septic system density in a subwatershed is high.
the tank and leach field once every two years to
make sure it is working properly, and to pump Percentage of Homeowners
out the tank (Ohrel, 1995; Figure 1). The Engaging in Septic System
negative watershed behavior is to ignore regular Maintenance
inspections and pumpouts to the point that the
septic system becomes a subwatershed pollution Until recently, homeowner awareness about
source. septic system maintenance was poorly
understood. Swann (1999) conducted one of the
How Septic Systems Influence first surveys to examine how frequently
Subwatershed Quality homeowners maintain their septic systems.
Roughly half of the owners were classified as
Failing septic systems can be a major source of “septic slackers,” since they indicated that they
bacteria, nitrogen, and phosphorus, depending had not inspected or cleaned out their systems in
on the overall density of systems present in a the past three years. A small, but significant,
subwatershed (Swann, 2001). Failure results in fraction (12%) of septic system owners had no
surface or subsurface movement of nutrients and idea where their septic system was located on
their property. In addition, only 42% of septic
system owners had ever requested advice on
how to maintain their septic system, and they
relied primarily on the private sector for advice
(e.g., pumping service, contractors, and
plumbers).
Figure 1: Septic System Inspection/Cleaning

Truck

Variation in Septic System • Discount coupons for septic system

Maintenance maintenance
• Low interest loans for septic system repairs
Septic system failure rates appear to vary • Performance certification upon property
regionally, ranging from five to 40% (Swann, transfer
2001). In most regions, failure rates are tied to • Creation of septic management districts
current or past design, construction and • Certification and training of
maintenance regulations, which are set by local operation/maintenance professionals
or state public health authorities. Failing systems • Termination of public services for failing
are often clustered together. At the systems
neighborhood level, many factors can influence
septic system problems. Key factors linked to Good Examples
failure include small lot size, aging systems,
poor soil or water table conditions, and close Swann (2001) describes a series of case studies
proximity to streams, lake fronts or ditches. In of effective local programs to improve septic
other cases, failure rates are tied to experimental system maintenance. Some additional examples
septic system technologies, and seasonal use of are provided below:
properties.
Washtenaw County, Michigan Time-Of-Sale
Difficulty in Improving Septic System Program: The County's septic system regulation
Maintenance requires the inspection of all residential septic
systems by private evaluators at the time of sale
Septic systems are a classic case of “out of sight, of a property. Evaluations must be done by a
out of mind.” Many owners take their septic certified inspector who has received a license
systems for granted, until they back up or break after training and an exam.
out on the surface of their lawn. Subsurface http://www.rougeriver.com/pdfs/illicit/OSS-
failures, which are the most common, go 02.pdf
unnoticed. In addition, inspections, pump outs,
and repair can be costly, so many homeowners Yarmouth, Maine Free Pumpouts (Septic Tank
tend to put off these expenditures until there is a Pumping Ordinance) - The town offers free
real problem. Lastly, many septic system owners septic system pump-outs to residents once every
lack basic awareness about the link between three years.
septic systems and water quality at the http://www.yarmouth.me.us/vertical/Sites/%7B1
subwatershed level. 3958773-A779-4444-B6CF-
0925DFE46122%7D/uploads/%7B363C4270-
Techniques to Increase Septic System 0879-43BC-8639-55BFA419AC12%7D.PDF
Maintenance
Cannon Township, MI Septic Inspections and
Many carrots and sticks have been developed in Testing - The township used school children to
recent years to improve resident behaviors in conduct dye tests to identify failing septic
regard to septic system maintenance, including: systems. This program doubled as an education
campaign to increase awareness of septic system
• Media campaigns to increase awareness owners.
about septic system and water quality (e.g., http://peer.tamu.edu/curriculum_modules/Water
billboards, radio, newspaper) _Quality/module_1/Kids%20Dye%20Project.ht
• Conventional outreach materials on m
maintenance (e.g., brochures, bill inserts,
newsletters)
• Free or mandatory inspections

Top Resources National Small Flows Clearinghouse

http://www.nesc.wvu.edu/nsfc/nsfc_septicnews.
Many excellent resources are available to htm
educate homeowners about septic systems and
water quality. Some of the better reference On-site Septic Systems: Educating the
websites are provided below, and many contain Homeowner
additional educational links. http://www.nesc.wvu.edu/nsfc/Articles/SFQ/SF
Qw02_web/SFQw02_Onsite Education.html
On-site Wastewater Treatment Systems Manual
http://www.epa.gov/ord/NRMRL/Pubs/625R000 University of Minnesota Onsite Sewage
08/html/625R00008.htm Treatment Program
http://septic.coafes.umn.edu/
A Homeowner’s Guide to Septic Systems
http://www.epa.gov/npdes/pubs/homeowner_gui North Carolina Coast*A*Syst
de_long.pdf http://www.soil.ncsu.edu/assist/cas/septic/index.
htm


N-10 SAFE POOL DISCHARGES
Description
Routine and end-of-season pool maintenance characterize the precise impact of pool
can cause chlorinated water or filter back flush discharges on aquatic systems, but there is
water to be discharged into the storm drain anecdotal evidence of fish kills and other
system or the stream. The ideal watershed problems. Part of the problem is the size of pool
behavior is to discharge chlorinated pool water discharges: the average in-ground pool is
to the sanitary sewer system, or hold it for a estimated to have a capacity of nearly 20,000
week or more before spreading over a suitable gallons.
pervious surface. The negative watershed
behavior is to drain pool water directly into the Percentage of Homeowners Engaging in
storm drain system or stream where it may be Pool Maintenance
toxic to aquatic life (Figure 1). Public and
community pools can also be a subwatershed The density of swimming pools in a
hotspot; details on controlling these pollution subwatershed is extremely variable, but can be
sources can be found in Profile Sheet H-14. determined through inspection of low-altitude
aerial photographs or the USSR survey (Figure 2).
How Swimming Pool Maintenance The number of in-ground or above-ground
Influences Subwatershed Water Quality swimming pools in the United States is
estimated at 7.5 million (Pool and Spa
Pool water typically contains two to four parts Marketing, 2003), or about 7% of all
per million of chlorine, as well as other households. The actual operational and
chemicals to reduce bacteria and algae, and discharge behaviors of pool owners remains
control pH. Consequently, the direct discharge poorly understood, so it is difficult to
of pool water can be toxic to aquatic life in small characterize the magnitude of the pool discharge
streams. Not much research has been done to problem.
Figure 1: Swimming Pool Discharging to Figure 2: Aerial Photo Showing High

Street and into Storm Drain Density of Swimming Pools (~30%) in a
Neighborhood

Variation in Pool Discharge Good Examples
While the greatest pool density is found in State of Maryland Pool Permit. The State has
warmer regions, the actual discharge problem developed a general permit to govern pool
may be more acute in northern regions where discharges. The general discharge permit,
pools must be drained before the onset of winter. developed by the Maryland Department of the
Key neighborhood factors include local Environment, addresses discharges from both
plumbing codes that govern how discharge swimming pools and spas. It can be found at:
water is handled, the overall density of pools in http://www.mde.state.md.us/assets/document/pe
the subwatershed, and their age. rmit/MDE-WMA-PER070-SI.pdf
Techniques to Change the Behavior Top Resources
Most pool owners understand that regular Guidelines for Swimming Pool and Spa Owners
maintenance is essential to keep a pool safe and and Operators
clean, and they probably conduct more water http://www.montgomerycountymd.gov/mc/servi
quality monitoring as a group than any other ces/dep/Enforcement/pools.htm
segment of society. Therefore, they may be more
receptive to changing discharge behaviors with Oregon Department of Environmental Quality
proper education. Some techniques include: (ODEQ). 1997. Water Quality Permit Program:
Guidance for Swimming Pool and Hot Tub
• Conventional outreach techniques on proper Discharges.
discharge (pamphlets, water bill inserts, http://www.deq.state.or.us/wq/wqpermit/swimpo
posters) ols.pdf
• Educational kiosks at the retail outlets where
they purchase pool chemicals US EPA National Menu of Best Management
• Changes in local plumbing codes to require Practices for Storm Water Phase II: Alternative
discharge to sanitary sewer systems Discharge Options for Chlorinated Water.
• Adoption of water quality ordinances that Office of Wastewater Management
allow for fines/enforcement for unsafe pool http://cfpub.epa.gov/npdes/stormwater/menuofb
discharges mps/poll_1.cfm
• Inspections (done in conjunction with
regular local health and safety inspections)

Neighborhood Source Area: Driveway
N-11 SAFE CAR WASHING
Description
easily characterize it. Car wash water can also be
The ideal watershed behavior is to wash cars a significant flow source to streams during dry
less often, wash them on grassy areas, and use weather. As an example, a typical hose flowing
phosphorus-free detergents and non-toxic at normal pressure produces between 630 and
cleaning products. Alternatively, residents can 1,020 gallons of water per hour, depending on
use commercial car washes that treat or recycle its diameter. These flows can be sharply reduced
wash water. The negative behavior is to wash if the hose is equipped with a shut-off nozzle.
cars in a manner where dirty wash water
frequently flows into the street, storm drain Percentage of Residents Engaging
system, or the stream. This behavior applies not in Car Washing
only to individuals, but to community groups
that organize outdoor car washes for charitable Car washing is one of the most common
purposes (Figure 1). watershed behaviors in which residents engage.
According to surveys, about 55 to 70% of
How Car Washing Influences homeowners wash their own cars, with the
Subwatershed Quality remainder utilizing commercial car washes
(Schueler, 2000b). Of these, 60% of
Outdoor car washing has the potential to homeowners can be classified as “chronic car-
generate high nutrient, sediment, metal, and washers,” in that they wash their car at least
hydrocarbon loads in many subwatersheds. once a month (Smith, 1996; PRG, 1998; and
Detergent-rich water used to wash the grime off Hardwick, 1997). Between 70 and 90% of
cars can flow down the driveway and into the residents reported that their car wash-water
storm drain, where it can be an episodic drained directly to the street, and presumably, to
pollution source during dry weather. Not much the nearest stream.
is currently known about the quality of car wash
water, but local water quality sampling can Variation in Car Washing
Regional and climatic factors play a strong role

in determining the frequency of residential car
washing. In colder climates, many residents
utilize commercial car washes during the winter
months, and then wash their cars themselves
during the summer. In warmer climates,
residential car washing is often a year-round
phenomenon. Neighborhood factors that
influence car washing include the number of
vehicles per household, lot size, driveway
surfaces, income and demographics. Another
key factor is the nature of the storm water
conveyance system. If a neighborhood has open
Figure 1: Poor Practices at a Charity Car Wash section roads with grass swales, the impact of
Event at a Local Gas Station car wash water will be less.

Difficulty in Changing Car Washing Good Examples

Behaviors
Puget Sound Car Wash Association - This
Residential car washing is a hard watershed charity car wash program allows qualifying
behavior to change, since the alternative of using nonprofit organizations to raise money for their
commercial car washes costs more money. In group by selling tickets that can be redeemed at
addition, many residents are not aware of the participating commercial car wash facilities.
water quality consequences of car washing, nor http://www.charitycarwash.com/
do they understand the chemical content of the
soaps and detergents they use. Lastly, many Drain Plugs and Bubble Busters (Kitsap
residents do not understand that their driveway County) – This program provides drain plugs to
is often directly connected to the storm drain contain car wash water from charitable car wash
system and the urban stream. Consequently, events, as well as “bubble busters” to pump out
many communities will need to educate and safely dispose of wash water.
homeowners about the water quality http://www.kitsapgov.com/sswm/carwash.htm
implications of car washing.
Top Resources
Techniques to Change Car Washing
Behavior RiverSafe Carwash Campaign
http://www.riversides.org/riversafe/
Several communities have developed effective
techniques to promote safer car washing, The Dirty Secret of Washing Your Car at Home
including: http://www.forester.net/sw_0106_trenches.html
• Media campaigns to increase awareness Best Management Practices for Controlling

about water quality impacts of car washing Runoff from Commercial Outdoor Car Washing
(billboards, posters, etc.) http://environment.alachua-
• Conventional outreach materials county.org/Natural_Resources/Water_Quality/D
(brochures, posters, water bill inserts) ocuments/Commercial Outdoor Car Wash.pdf
• Promote use of nozzles with shut-off valves
• Provide information on environmentally How to Run a Successful Carwash fundraiser
safe car washing products at point of sale http://www.carwashguys.com/fundraisers/LAsch
• Provide storm drain plugs and wet vacs for ools.html
charity carwash events
• Provide discounted tickets for use at Make Your Next Car Wash “Environmentally
commercial car washes Smart”
• Modify sewer bylaws or plumbing codes to http://www.ci.eugene.or.us/PW/storm/Publicatio
prevent storm drain discharges ns/Carwash fundraiser.pdf
• Storm drain marking (see N-21)

N-12 DRIVEWAY SWEEPING

Engaging in Driveway Cleaning
The ideal watershed behavior is to regularly
sweep driveways and sidewalks and dispose of Residential driveway and sidewalk cleaning
sweepings in the trash. The negative behavior is behaviors are poorly understood. Rough
to use hoses or leaf blowers to clean off estimates that show 15% of residents using
driveways and sidewalks that direct dirt and hoses and an additional 10% using leaf blowers
organic matter into the street or storm drain to clean driveways and sidewalks appear to be
system. conservative. The recent growth in the use of
motorized leaf blowers has been quite rapid. The
How Driveway Cleaning Influences Water Outdoor Power Equipment Institute (2003)
Quality reports annual sales of more than 1.5 million
units and indicates that leaf blowers are the
Source area research has indicated that fastest growing segment of the industry. To date,
driveways are a significant source of sediment, most environmental concerns about leaf blowers
nutrients and metals in urban neighborhoods have focused on noise and air quality emissions;
(CWP, 2003). Broom sweeping and disposal can their role in re-suspending pollutants is poorly
reduce wash-off of accumulated pollutants understood.
during subsequent storms. On the other hand,
hosing and blowing tend to move pollutants to Variation in Driveway Cleaning
the street and gutters, where they have a greater
chance of reaching the stream (Figure 1). Regional and climatic factors play a strong role
in determining the frequency of driveway
cleaning. Since storms occur more rarely in
regions with arid and semi-arid climates,
particles and organic matter accumulate longer
on driveway and sidewalk surfaces, which often
prompts more frequent cleaning. By contrast,
frequent storms in more humid regions often
clean off driveway and sidewalk surfaces
themselves. A number of neighborhood factors
also influence driveway cleaning behaviors,
including driveway dimensions, the nature of
driveway surfaces, forest canopy coverage, and
the nature of the storm water conveyance
system. If a neighborhood has open section
Figure 1: Power Washing of a Driveway
roads with grass swales, the impact of driveway
cleaning may be less.

Difficulty in Changing Driveway Cleaning Top Resources

Behavior
Tips on Cleaning Driveways, Decks, Sidewalks
Driveway cleaning is also a hard behavior to and Patios
change, since hosing and leaf blowing are often http://www.thinkbluesd.org/brochures/Impervio
faster and more convenient ways to get the job us_Surfaces.pdf
done. Few residents understand that their
driveway is often directly connected to street Stormwater Management for Homeowners
gutters, and eventually, the urban stream. Lastly, http://www.soil.ncsu.edu/assist/homeassist/stor
few communities have emphasized the mwater/
importance of educating residents and landscape
contractors about the water quality impacts of
driveway cleaning behaviors. Consequently,
greater effort is needed to increase residential
awareness about the water quality consequence
of hosing and leafblowing.
Techniques to Change Car Washing

Behavior
Not many communities have targeted driveway

cleaning as an important residential watershed
behavior. As a result, only a few innovative
techniques have been developed for driveway
cleaning behavior so far, including:
• Media campaigns to increase awareness

about water quality impacts of driveway
cleaning (billboards, posters, etc.)
• Conventional outreach materials
(brochures, posters, water bill inserts)
• Landscaping contractor training or
certification programs that emphasize
proper leaf blower use

Neighborhood Source Area: Sidewalk/Driveway
N-13 SAFE DE-ICER USE

Applying De-icing Compounds
The ideal watershed behavior is to avoid using
de-icing products on driveways and sidewalks No reliable data is available to characterize
by manually clearing and shoveling snow and homeowner use of de-icing compounds.
ice. The next best behavior is to purchase
environmentally friendly de-icing products, and Factors that Contribute to Variation in
apply them early but sparingly during snowfall Behavior
events. The negative watershed behavior is the
indiscriminate application of de-icing The use of de-icing compounds is directly
compounds. related to climatic factors, and actual use
depends on the severity of winter conditions.
How Use of Home De-icing Products Several neighborhood factors also influence the
Influences Water Quality use of de-icing compounds, including lot size,
driveway dimensions, the nature of driveway
De-icing compounds, such as rock salt and urea surfaces, and the storm water conveyance
fertilizers, can increase chloride and nutrient system.
levels in a neighborhood. While the vast
majority of de-icing chemicals applied in a Difficulty in Modifying De-icing
subwatershed come from municipal road salting Behaviors
operations, homeowners often apply them at a
much higher unit-area rate. During snowmelt Keeping ice and snow off driveways and
events, chloride levels in street runoff can rise to sidewalks is important for safety. The biggest
as high as 2,000 to 4,000 parts per million, challenge is to make consumers aware of how to
which can adversely affect aquatic life, turf, choose the best de-icing product for the home
landscaping, wildlife and pets (Environment and the environment. The most important
Canada, 2001). In addition, rock salt contains behavior is to read labels to compare the pros
impurities such as phosphorus, nitrogen, copper and cons of the main ingredients contained in
and even cyanide. Homeowners can also make common de-icing products. Table 1 provides
informed choices in the de-icing chemicals they some comparative data on the cost and
use, and put their sidewalk and driveway on a environmental risk of de-icing compounds.
low salt diet. In general, calcium chloride is
preferred to sodium chloride (rock salt), and When it comes to snow removal, there is no
both are superior to urea, kitty litter and ashes. substitute for muscle and elbow grease. De-icers
work best when there is only a thin layer of
snow or ice that must be melted, and they are
applied at the recommended rate.

Table 1: Comparison of De-icing Compounds

Check the Label for Works Down to Cost Environmental Risks
NaCl, Sodium Chloride About $5 for a 50 Contain cyanide
15° F
(also known as rock salt) pound bag Chloride impacts
Calcium Magnesium 20 times more than
22° to 25° F Less toxic
Acetate (CMA) rock salt
Uses lower doses
3 times more than rock
CaCl, Calcium Chloride -25° F No Cyanide
salt
Chloride impact
5 times more than rock Needless nutrients
Urea 20° to 25° F
salt Less Corrosion
About $3 for a 50 lb. Accumulates in streets and
Sand No melting effect
bag streams
Techniques to Change De-icing Behavior Slip-Sliding, Away! A review of the available

options, and their environmental, safety, and
• Conventional outreach materials (seasonal efficiency implications.
newsletters, brochures, water bill inserts) http://www.consciouschoice.com/environs/slipsl
• Broadcast advice from local TV idingaway1201.html
meteorologists during storms
• Brochures or advice at point of sale Ice Control for Roads and Walkways
http://www.swmcb.org/EPPG/9_3.asp
Good Example
Protect Concrete and Vegetation with Proper
Montgomery County Maryland De-icer Use Use of De-icers
Press Release http://snow.grounds-
http://www.montgomerycountymd.gov/apps/ne mag.com/ar/grounds_maintenance_january_3/
ws/press/DisplayInfo.cfm?ItemID=157
Winter De-icing Agents for the Homeowner
Top Resources http://www.ianr.unl.edu/pubs/horticulture/g1121
.htm
Using De-icers Correctly
http://www.saltinstitute.org/kirchner-1.html National Snow and Ice Data Center
http:// www.nsidc.org/
Melting Ice Safely
http://www.agnr.umd.edu/MCE/Publications/PD Salt Institute
Fs/FS707.pdf http://www.saltinstitute.org/

Neighborhood Source Area: Garage
N-14 HOUSEHOLD HAZARDOUS WASTE

COLLECTION
Description How It Influences Water Quality
The average garage contains many products that According to EPA, the average home/garage
are classified as hazardous waste, including accumulates as much as 100 pounds of
paints, stains, solvents, used motor oil, excess household hazardous waste per year. Nationally,
pesticides, and cleaning products. The ideal households are collectively estimated to generate
watershed behavior is to regularly participate in more than 1.6 million tons of household
household hazardous waste (HHW) collection hazardous wastes annually. The proportion of
days, and to be careful when rinsing HHW that reaches the storm drain system is not
paintbrushes, cleaning pesticide applicators and well known. Most HHW appears to be stored
fertilizer spreaders, and fueling outdoor power indefinitely, thrown out with the trash, or
equipment (Figure 1). The negative watershed flushed down the sink/toilet, which is not
behavior is continued storage, improper disposal environmentally acceptable. The key unknown
or illegal dumping of household hazardous is what fraction of HHW is illegally dumped
wastes, and poor cleaning, refueling and rinsing into the storm drain. It is probable that most
practices. HHW enters the storm drain system during
outdoor rinsing of pesticide applicators and
outdoor painting cleanup. HHW that reaches the
storm drain system can potentially be toxic to
downstream aquatic life.
Percentage of Residents Engaging in

HHW Collection
Homeowner participation in HHW collection

programs is usually quite low, with several
studies indicating participation rates of one to
5% (HGAC, 2004).
Variation in Participation
Convenience and awareness appear to be critical

factors influencing participation in household
hazardous waste collection programs.
Participation is inversely related to the distance
homeowners must travel to recycle waste,
restrictions on what can be accepted and the
number of days each year that collection events
are held.
Figure 1: Household Hazardous Waste Disposal

Guidelines
Source: http://www.duluthstreams.org/understanding/impact_oil.html

Techniques to Increase Participation Top Resources
Communities continue to experiment with EPA Household Hazardous Waste Website

improved techniques to make HHW collection http://www.epa.gov/epaoswer/non-
more convenient for residents, including: hw/muncpl/hhw.htm
• Mass media campaigns to educate residents Guide to Household Hazardous Wastes

on proper outdoor cleaning/rinsing http://www.epa.gov/grtlakes/seahome/housewast
• Conventional outreach to notify residents e/house/products.htm
about HHW collection days
• More frequent HHW collection days Household Hazardous Waste: Steps to Safe
• Providing curbside disposal options for Management
certain HHW A guide for residential homeowners that
• Establishing permanent collection facilities describes household hazardous waste and the
at solid waste facilities dangers of improper disposal.
• Providing mobile HHW pickup http://www.epa.gov/epaoswer/non-
• Waiving disposal fees at landfills hw/househld/hhw.htm
• Storm drain marking (see N-21)
Household Hazardous Waste (HHW)
Good Examples Management: A Manual for One Day
Community Collection Programs
The City of Denver Pilot Door-to-Door HHW A manual that helps communities plan for one-
Collection Program. This unique program day, drop-off HHW collection programs.
assists residents in proper disposal and recycling Provides community leaders with guidance on
of household hazardous wastes. Residents are all aspects of planning, organizing, and
permitted one HHW collection annually and publicizing a HHW collection program.
receive a collection date and an HHW Kit that http://www.epa.gov/epaoswer/non-
can hold up to 75 pounds. The program not only hw/househld/hhw/cov_toc.pdf
provides a curbside pick-up program for
household hazardous waste, but also educates Department of Defense - Household Hazardous
citizens on how to prevent the accumulation of Waste Topic Hub
chemicals in the garage. http://wrrc.p2pays.org/p2rx/toc.cfm?hub=16&su
http://www.denvergov.org/admin/template3/for bsec=7&nav=7&CFID=23448&CFTOKEN=55
ms/INSERT1.pdf 325833
King County Wastemobile. The Wastemobile is Household/Small Business Hazardous Waste: A

a traveling collection program that goes to two Manual for Sponsoring a Collection Event
sites in the county per month to accept HHW http://www.dep.state.pa.us/dep/deputate/airwast
and provide information about alternatives to e/wm/Hhw/Documents/TechMan.pdf
hazardous products. The Wastemobile is funded
through a surcharge on solid waste disposal and
wastewater discharge, and residents utilizing the
Wastemobile are not charged a fee on site.
http://www.govlink.org/hazwaste/house/disposal
/wastemobile/

N-15 CAR FLUID RECYCLING
Description improperly dispose of 192 million gallons of

used oil into the environment each year
The ideal watershed behavior is to have (University of Missouri, 1994). It remains
automotive fluids changed at a commercial unclear what fraction of the improper disposal of
operation where stringent pollution source motor oil occurs within the storm drain system.
controls and fluid recycling practices are in
place. The next best alternative is to perform car Percentage of People Engaging in
maintenance under cover within the garage, and Improper Disposal
carefully dispose of all oil, antifreeze and other
fluids at approved recycling facilities. The The number of backyard mechanics who change
negative behavior is to improperly store, dump their own oil and antifreeze has been dropping
or otherwise dispose of car fluids into the storm steadily in recent decades. With the advent of
drain system. the $20 oil change, only about 30% of car
owners still change their own oil or antifreeze
How Fluid Changing Influences (Swann, 2001). Backyard mechanics have
Water Quality traditionally been the target of community oil
recycling and storm drain marking programs.
Dumping automotive fluids down storm drains These programs appear to have been quite
can be a major water quality problem, since only effective, since more than 80% of backyard
a few quarts of oil or a few gallons of antifreeze mechanics claim to dispose of or recycle these
can have a major impact on small streams. fluids properly (Smith, 1996; PRG, 1998;
Dumping can be a major source of Assing, 1994). Most backyard mechanics were
hydrocarbons, oil/grease, metals, xylene and more prone to recycle oil than antifreeze.
other pollutants to a stream, and are potentially Backyard mechanics that indicated they had
toxic if dumped during dry-weather conditions improperly disposed of automotive fluids
when existing flow cannot dilute these reported that they dumped it into trashcans
discharges. The major culprit has been the rather than the storm drain system. Oil and
backyard mechanic who changes his or her own antifreeze dumping is considered socially
automotive fluids (Figure 1). It has been unacceptable in many communities, and,
estimated that do-it-yourself mechanics according to Swann (2001), less than 5% of
backyard mechanics report that they illegally
dump oil.
Variation in Car Fluid Disposal
Neighborhood demographic and income levels

appear to be important factors governing the
number of “do-it-yourselfers” in a given
subwatershed. As with other residential
behaviors, proper disposal of oil and anti-freeze
is primarily influenced by the ease, convenience
and costs for accepting these fluids at local
service stations or municipal collection stations.
Figure 1: Fluid Changing on Driveway

Techniques to Change Car Good Examples

Fluid Disposal
King County Kiosks (Washington). Thirty
While used oil collection has been a common interactive kiosks on oil recycling were placed in
municipal service for many years, some King County licensing offices, county buildings
communities are continuously refining their and other locations. In addition, a direct mail
programs to increase participation (Figure 2). campaign to 6,000 households and three
These techniques include: newspaper ads were used to distribute coupons
good for product or service discounts that could
• Conventional outreach materials provided at be used when dropping off oil at participating
point of sale (e.g., auto parts stores, service sites.
stations)
• Multilingual outreach materials California’s Used Oil Recycling Program
• Community oil recycling Incentive Program. Residents can receive
• Directories of used oil collection stations incentives from certified centers that recycle
• Free or discounted oil disposal containers used oil. Certified centers must accept used oil
• Storm drain marking from the public at no charge during business
hours and offer a $0.16 per gallon recycling
incentive. In turn, only certified used oil
collection centers can file a claim for recovery
of the $0.16 per gallon it pays out. Certified
centers can also claim the recycling incentive for
all used oil generated on site from their business
as an inducement to take oil from the public.
http://www.ciwmb.ca.gov/BoardInfo/ProgramRe
sp/SpecialWaste/HHW.htm - Public%20Info
Top Resources
Car Care for Do-It-Yourselfers

http://www.monterey.org/publicworks/carcare.ht
Figure 2: Frisbee Advertising Oil ml
Recycling
Car Care for Cleaner Water
http://clean-water.uwex.edu/pubs/stormie/carcare.pdf
Motor Vehicle Maintenance

http://www2.ctahr.hawaii.edu/oc/freepubs/pdf/H
H-15.pdf
How To Set Up a Local Program to Recycle

Used Oil - Explains the organization, design,
implementation, and promotion of a used oil
program, as well as administrative issues.
Includes sample brochures and letters.
http://www.epa.gov/epaoswer/non-
hw/recycle/89039a.pdf

Neighborhood Source Area: Rooftop
N-16 DOWNSPOUT DISCONNECTION
Description feet of impervious cover, dozens or hundreds are

needed to make a measurable difference at the
Downspout disconnection spreads rooftop runoff subwatershed level. Consequently, an intensive
from individual downspouts across the lawn or campaign to target education, technical
yard where it filters or infiltrates into the ground. assistance, and financial resources within a
While some disconnections are simple, most neighborhood or subwatershed to encourage
require the installation of an on-site storm water widespread adoption of disconnection is needed.
retrofit practice. These simple practices capture,
store and infiltrate storm water runoff from Percentage of Residents Engaging in
residential lots, and include rain barrels, rain Downspout Disconnection
gardens, French drains or dry wells. Rain barrels
capture runoff from rooftops and are typically Data is not currently available to estimate the
installed on individual roof leaders. Runoff rate at which homeowners voluntarily
captured in the barrel is stored for later use as disconnect downspouts. The frequency of this
supplemental irrigation. Rain gardens are behavior is thought to be extremely low in most
shallow, landscaped depressions in the yard used neighborhoods unless a community aggressively
to store and infiltrate runoff from rooftops and promotes and subsidizes disconnections. If this
other impervious surfaces on the lot. French occurs, homeowner participation rates of 20 to
drains and dry wells are shallow small stone 30% have been reported in pilot projects
trenches used to infiltrate rooftop runoff into the (Environment Canada, 2001).
ground, where soils are permeable. More details
about on-site retrofit practices can be found in
Profile Sheets 0S-15 through 0S-17 in Manual 3.
The ideal watershed behavior is to disconnect all

downspouts so individual rooftops deliver no
runoff to the storm drain system or stream. The
negative watershed behavior is to pipe
downspouts across the yard and into the curb or
street in order to promote positive drainage
(Figure 1).
How Downspout Disconnection

Influences Subwatershed Quality
Downspout disconnection reduces the amount of

impervious cover on a developed lot that can
generate stormwater runoff. In addition to
reducing the volume of runoff, downspout Figure 1: Downspout Intentionally Bypassing
disconnection promotes groundwater recharge, Landscaped Area and Draining onto Driveway
reduces storm water runoff volumes, and filters
out pollutants through the lawn soil. Since each
individual retrofit for downspout disconnection
treats only a few hundred or thousand square

Variation in Downspout Disconnection Techniques to Promote Downspout

Disconnection
The potential to disconnect downspouts is
normally evaluated as part of the Neighborhood Communities are experimenting with many
Source Assessment component of the USSR different carrots to promote disconnection
survey (see Manual 11). The most important retrofits, including:
neighborhood factor is the proportion of existing
homes directly connected to the storm drain • Conventional outreach materials (flyers,
system. Negative neighborhood factors include brochures, posters)
the presence of basements, compacted soils, and • Free or discounted rain barrel distribution
poor neighborhood awareness or involvement. • Municipal or schoolyard demonstration
Positive factors are large rooftop areas that are projects
directly connected to the storm drain system, • Credits or subsidies for disconnection
lots with extensive tree canopy, and good retrofits
neighborhood housekeeping. In general, large • Direct technical assistance
residential lots are most suitable for most • Provision of discounted mulch, piping or
disconnection retrofits (1/4 acre lots and larger), plant materials
although rain barrels can be used on lots as small • Modification of sewer and storm water
as 4,000 square feet (Figure 2). ordinances to promote disconnection
• Mandatory disconnection for targeted
To date, the impetus for most disconnection subwatersheds
retrofit programs has been to separate residential
storm water from sewer flows in older Good Examples
neighborhoods in order to minimize basement
sewer backups or combined sewer overflows. Downspout Disconnection Program (Portland,
OR). The City offers residents a credit of $53
per disconnection in the form of a check or a
one-time lump sum credit toward their sewer bill
after inspection and approval of the work. In
addition, neighborhood associations and other
civic groups (churches, schools, etc.) can earn
$13 for every downspout they disconnect.
http://www.portlandonline.com/bes/index.cfm?c
=32144
Rain Blocker Program (City of Chicago). The

Rain Blocker pilot program is specifically
designed to eliminate or greatly reduce the
amount of basement flooding caused by sewer
surcharge. The program works by restricting the
rate of storm water flow into the city sewer
system, via installing vortex restrictors within
the catch basins of city streets and through
downspout disconnection from buildings.
http://www.cityofchicago.org/WaterManagemen
Figure 2: Rain Barrel Used on t/blocker.html
a Back, Second Floor Balcony

Neighborhood Rain Gardens (Minneapolis, RainGardens.org

MN). This program works with neighborhood http://www.raingardens.org/
associations to encourage landscaping for
rainwater management. The Fulton Rain Gardens: A how-to manual for
Neighborhood Association has worked with homeowners
eight homeowners to install rain gardens, rain http://www.dnr.state.wi.us/org/water/wm/dsfm/s
barrels, gutter downspout redirection, and hore/documents/rgmanual.pdf
infiltration systems that reduce runoff delivered
from individual properties to streets, alleys and Rain Garden Applications and Simple
sidewalks. Calculations
http://www.fultonneighborhood.org/lfrwm.htm http://www.cwp.org/Community_Watersheds/R
ain_Garden.htm
Top Resources
How to Disconnect Your Downspouts (Portland How to Build and Install a Rain Barrel
Oregon) http://www.cwp.org/Community_Watersheds/br
http://www.portlandonline.com/bes/index.cfm?c ochure.pdf
=32144
Skills for Protecting Your Stream: Retrofitting
Milwaukee Downspout Disconnection Program Your Own Backyard
http://www.mmsd.com/projects/downspout.cfm http://www.cwp.org/Community_Watersheds/R
etrofitting_Backyard.pdf
Boston Water and Sewer Commission's
Downspout Disconnection Program
http://www.bwsc.org/Customer_Service/Progra
ms/downspout.htm


Neighborhood Source Area: Rooftop
N-17 SINGLE LOT CONTROLS
Description walkways, patios, terraces, swimming pools,

tennis courts, detached decks, garages, sheds,
The ideal watershed behavior is to gradually and other outbuildings).
reduce impervious cover on residential lots by
converting impervious cover to pervious cover. Factors that Contribute to Variation
Examples include converting an impervious in Adding Impervious Cover
driveway to a more pervious design, or
eliminating an old walkway, deck or The precise reasons why impervious cover is
outbuilding. In practice, however, most added or reduced within a neighborhood are
homeowners gradually add more impervious often unique, and reflect its age, housing stock,
cover to their residential lots over time, in the demographics, income levels, and average lot
form of decks, patios, walkways and home size. In many cases, the degree of
additions. Thus, the practical watershed behavior redevelopment/remodeling activity can be
is to treat storm water runoff produced by new ascertained during the neighborhood source
impervious cover, using downspout assessment of the USSR survey (see Manual
disconnection and other on-site retrofits to 11). If redevelopment activity level is high,
minimize storm water runoff (see Profile sheets serious consideration should be given to
N-16 and 0S-15 to 17 in Manual 3). residential storm water management
requirements such as those described in
How Impervious Cover Influences BASMAA (1997) and Winer (2003). In some
Subwatershed Quality communities, erosion control or storm water
treatment requirements are triggered when areas
Impervious cover plays a strong role in defining as small as 100, 250, or 500 square feet are
both subwatershed quality and stream health disturbed.
(CWP, 2003). The amount of impervious cover
in a neighborhood or a subwatershed does not Techniques to Change the Behavior
remain constant over time, but rather increases
incrementally as individual residents remodel, Most communities have been reluctant to
redevelop or otherwise improve their lots. regulate small remodeling and redevelopment
Collectively, the gradual “creep” in impervious projects on individual residential lots, but a few
cover may make it more difficult to achieve have developed simplified techniques to address
subwatershed restoration goals. the storm water impacts single lots (Figure 1).
Percentage of Residents Adding Other techniques include:

Impervious Cover
• Conventional outreach materials (brochures,
More than 18 million households (20% of all water bill inserts)
households in the U.S.) completed projects over • Contractor training and certification (see
the last decade that added impervious cover to Hotspot Profile Sheet H-9)
their residential lots (U.S. Census, 2001). This • Setting storm water utility rates based on
included three million home additions (e.g., actual impervious cover
expansions, decks, carports, attached garages, • Simplified residential storm water
porches, and other remodeling), as well as 15 management plans
million detached structures (e.g., driveways,

Good Examples City of Charlotte and Mecklenberg County, NC

Stormwater Credits - These communities created
Simplified Residential Storm Water Management a credit system for storm water fees when
Plan (Maryland Critical Area) - The regulatory property owners are able to show an effective
threshold to treat storm water runoff is triggered reduction of the impact their property has on the
at only 250 square feet, which means that many drainage system. The fee credit applies to all
decks, additions, and other residential projects properties, including single-family residential
must comply. To simplify compliance for properties with practices that reduce storm water
individual residential lots, the Critical Area runoff from their site.
Commission allows non-engineered storm water http://www.charmeck.org/Living/Environment/
plans such as compensatory tree planting, Home.htm
rooftop disconnection, and pervious driveways
and walkways.
http://www.dnr.state.md.us/criticalarea/10percen
t_rule.html
Figure 1: Repair and Remodeling Brochure

Source: http://www.lacity.org/SAN/wpd/index.htm

Neighborhood Source Area: Common Areas
N-18 PET WASTE PICKUP

Description residents for pet waste is the trash can, with
toilets coming in distant second. Dog walkers
The ideal watershed behavior is to pick up and that do not pick up after their dogs are highly
properly dispose of pet waste (Figure 1). The resistant to change; nearly half would not pick
negative watershed behavior is to leave pet up even if confronted with fines or complaints
waste in common areas and the yard, where it from neighbors (Swann, 1999). Men are also
can be washed off in storm water runoff. prone to pick up after their dogs less often than
women (Swann, 1999).
How Pet Waste Influences
Pet waste has been found to be a major source of

fecal coliform bacteria and pathogens in many
urban subwatersheds (Schueler, 1999). A typical
dog poop contains more than three billion fecal
coliform bacteria and as many as 10% of dogs
are also infected with either giardia or
salmonella, which is not surprising considering
they drink urban creek water. Fecal coliform
bacteria are frequently detected in urban streams
and rivers after storms, with levels as high 5,000
fecal coliform per tablespoon. Thus, it is not
uncommon for urban and suburban creeks to
frequently violate bacteria standards for
swimming and water contact recreation after
larger rainstorms.
Percentage of Residents that

Pick Up After Pets
Surveys indicate that about 40% of all Figure 1: Pet Waste Pickup Station
households own one or more dogs (Swann,
1999). Not all dog owners, however, are dog
walkers. Only about half of dogs are walked
regularly. About 60% of dog walkers claim to
pick up after their dog some or all of the time
(Swann, 1999; HGIC, 1998; and Hardwick,
1997). The primary disposal method reported by

Techniques to Promote Pet Waste Pick It Up - It's Your Doodie Campaign

Pickup (Gwinnett County Parks & Recreation
Department) - The county park agency provides
The key technique is to educate residents on plastic grocery bags for pet owners to use to
sanitary and convenient options for retrieving clean up after their pets as part of a pilot
and disposing of pet waste. Several communities program. The baggies are attached to a wooden
have used both carrots and sticks to get more post at a local park. Underneath a sign explains
owners to pick up after their pets, including: their purpose. Pet owners are also encouraged to
bring replacement bags when they visit the park.
• Mass media campaigns of the water quality http://www.gwinnettcitizen.com/0203/doodie.ht
impacts of pet waste ml
• Conventional outreach materials (brochures,
flyers, posters) Top Resources
• Pooper bag stations in parks, greenways and
common areas Public Open Space and Dogs: A Design and
• Educational signs in same areas Management Guide for Open Space
• “Pooper scooper” ordinances and Professionals and Government
enforcement http://www.petnet.com.au/openspace/frontis.html
• Banning dogs from beaches and waterfront
areas Considerations for the Selection and Use of Pet
• Providing designated “dog parks” Waste Collection Systems in Public Areas
http://www.ecy.wa.gov/programs/wq/nonpoint/p
Good Examples et_waste/petwaste_station.pdf
Water Quality Consortium Nonpoint Source Properly Disposing of Pet Waste

Education Materials http://www.cleanwatercampaign.com/what_can_
The Water Quality Consortium implemented an i_do/pet_waste_home.html
ad campaign focused on four themes: a man
pushing a fertilizer spreader, a car driving on Managing Pet and Wildlife Waste to Prevent
water leaking oil, a man washing his car, and Contamination of Drinking Water
man walking his dog. Each ad explains how the U.S. EPA Source Water Protection Practices
behavior leads to water pollution and provides Bulletin.
specific tips outlining what residents can do to http://www.epa.gov/safewater/protect/pdfs/petw
protect water quality. aste.pdf
http://www.psat.wa.gov/Programs/Pie_Ed/Water
_Ed_Materials.htm

N-19 STORM WATER PRACTICE

MAINTENANCE
Description
The ideal watershed behavior is to regularly

maintain storm water treatment practices, which
are normally located in common space managed
by a homeowner’s association. The negative
behavior is to ignore routine and non-routine
maintenance tasks to the extent that the ability of
the practice to remove pollutants and protect
streams is impaired. Storm water maintenance
consists of routine and non-routine tasks. Routine
tasks include on-going inspections, mowing,
vegetation management, trash and debris pickup,
and removal of any obstructions within pipes and
riser structures. Non-routine tasks include Figure 1: Wet Storm Water Pond
sediment clean-outs, structural repairs, tree
removal, fence repair, and other major tasks Variation in Storm Water Practice
performed every five to 10 years. Maintenance
How Storm Water Maintenance Influences Each state or locality has its own storm water
Subwatershed Quality history, which begins when storm water
detention or treatment practices were first
Storm water detention or treatment practices have required on new development projects. Thus,
been constructed in many subwatersheds over the some communities may have hundreds or even
last few decades. The vast majority of these thousands of storm water practices built over
practices have been dry or wet storm water decades, while others may have few practices and
ponds. These ponds were designed to detain no real history of managing storm water.
flood waters and, in some cases, remove
pollutants as well. Ongoing pond maintenance is If a community has a history of managing storm
needed to maintain pollutant removal rates, keep water, several neighborhood factors play a role in
the pond safe, and to enhance its habitat, wetland defining maintenance behaviors. The most
or landscaping value (Figure 1). critical factor is the age of the neighborhood,
since most storm water practices have only been
Percentage of People Engaging in Storm built in the last 10 to 15 years. The second key
Water Practice Maintenance neighborhood factor is the design objective of the
past storm water management practices (e.g.,
Little data is available to characterize this provide flood control, peak shaving, water
watershed behavior, although anecdotal evidence quality or recharge). The last important factor is
indicates that maintenance is the exception rather the size, sophistication and financial health of the
than the rule at many ponds. homeowners association that has maintenance
responsibility for the pond.

Figure 2: Educational Brochure for Storm Water Pond Maintenance

Source: http://h2o.enr.state.nc.us/su/PDF_Files/Land_of_Sky_factsheets/FactSheet_7.pdf
Difficulty in Improving Maintenance of Techniques to Improve Maintenance

Storm Water Practices Behavior
Improving routine and non-routine maintenance Some communities have adopted innovative
can be difficult, since many homeowner or civic techniques to improve the frequency of
associations lack adequate maintenance budgets. maintenance of storm water practices, including
They may also be ignorant of the purpose and the following:
functions of storm water practices, and not
understand basic maintenance operations. • Conventional outreach materials
Consequently, targeted education and direct (maintenance guidebooks)
technical assistance to homeowner associations is • Liaison w/homeowner and civic associations
important to improve maintenance behaviors. • Free inspections and contractor referral
• Pondscaping assistance (e.g., technical
assistance, free plant material)
• Adopt-a-pond programs
• Storm water maintenance classes and work
parties
• Pond beautification awards
• Annual maintenance reminder letters

Good Examples Northern Virginia Planning District Commission,

Maintaining Your BMP - A Guidebook for
Adopt- a-Pond Program (Baltimore County, MD). Private Owners and Operators in Northern
The County developed a pilot pond adoption Virginia. This document is designed for
program that features four different levels of individual property owners, homeowner
participation. The basic level includes inspections association leaders, and residential/commercial
and trash pickup, while the most advanced property managers. The guidebook outlines the
involves pondscaping, wildlife enhancements, basic maintenance and planning tasks to help
and simple retrofits. Another interesting feature keep practices functioning properly, and includes
of this pond adoption program is the fact that the information on general maintenance needs, who
training and administration of the program are should carry out maintenance, inspections, and
subcontracted to a local watershed organization. basic planning. The document also includes a
Contact the Center for Watershed protection for simple inspection checklist and a maintenance
information on how to access. cost planning sheet.
http://www.novaregion.org/pdf/Maintaining_BM
Adopt-a-Pond Program (Hillsborough County, Ps.pdf
FL). This Florida county has the largest and
longest running “adopt a pond” program in the Montgomery County, MD "Maintaining Urban
nation. Nearly 200 ponds have been adopted by Storm water Facilities: A Guidebook for
neighborhood groups and service clubs. The Common Ownership Communities.” This
program features signs, volunteer recognition, guidebook describes the four primary types of
newsletters and work parties to actively engage, storm water practices found in the County and
train and retain volunteers. For more details: outline some basic maintenance tasks to keep
http://www.swfwmd.state.fl.us/documents/public them functioning properly.
ations/files/adopt.htm http://www.montgomerycountymd.gov/mcgtmpl.
asp?url=/content/dep/stormwater/maintain.asp
Pond Maintenance Training and Work Parties
(Lacey, WA). This version of an adopt-a-pond City of Eugene, Oregon - Storm Water Drain
program uses a series of night-time training Maintenance on Private Property. This short
classes on the basics of storm water maintenance, guide discusses the maintenance of storm water
followed by weekend work parties to spruce up drains, street gutters, underground pipes, roadside
and landscape storm water ponds. ditches, and open drainage channels. Proper
storm water drain maintenance is crucial for
Top Resources flood control and water quality protection. This
guide explains the private property owner's
Thurston County, Washington, "How to Care for responsibility to maintain storm water drains on
Your Stormwater Pond." This web document is his or her property and some simple maintenance
an excerpt from the publication Maintaining Your procedures to meet this responsibility.
Stormwater Pond: A Step-by-Step Guide to http://www.stormwatercenter.net/
Keeping Your Stormwater Pond Happy and
Healthy. Geared toward private landowners and
homeowner associations, this document answers
basic questions on storm water pond
maintenance.
http://www.co.thurston.wa.us/wwm/stormwater
pages/maintainpond.pdf

South Carolina Department of Health and Howard County, MD – Maintaining Your

Environmental Control, Ocean and Coastal Stormwater Management Structure. This manual
Resource Management’s A Citizen's Guide to is directed at commercial property managers who
Storm Water Pond Maintenance. This booklet is own storm water management structures. The
a guide for individuals and homeowner purpose of this manual is to describe the four
associations on the proper function and types of stormwater management structures and
maintenance of storm water ponds. Instructions their maintenance requirements.
are provided on inspections, dredging, weed http://www.co.ho.md.us/DPW/DOCS/stormwater
control, herbicides, pollutants and pesticides. manual.pdf
Photos and descriptions of nuisance aquatic plant
species are provided to aid in the identification Stormwater Manager’s Resource Center.
and removal of these species from storm water This website offers information on maintenance
ponds. arrangements, agreements, costs, frequencies,
http://www.scdhec.net/ocrm/pubs/ponds.pdf and educational materials.
http://www.stormwatercenter.net
(Click on “Program Resources” then “STP
Maintenance”)

N-20 BUFFERSCAPING
Description buffers (Heraty, 1993). Studies of wetland buffer

encroachment in Washington residential areas
Many neighborhoods built in the last few found that 95% of buffers were visibly altered,
decades still have a decent stream corridor 40% to such a degree that their functional value
protected by buffers, flood plain setbacks or was eliminated (Cooke, 1991). Other studies of
wetland protection requirements. The stream Maryland buffers indicate encroachment rates of
corridor that remains is often in common or as much as 1% of area buffer per year. Clearly,
private ownership. The ideal watershed behavior residential awareness and behaviors in regard to
is to respect the boundaries of the stream the stream corridor need to be improved in many
corridor and expand it where possible through subwatersheds.
“bufferscaping” and backyard planting of native
plants and trees. The negative watershed Neighborhood Factors that Contribute to
behavior is stream corridor encroachment, Buffer Stewardship
through clearing, dumping, allowing invasive
plant species to spread from private yards, and Several factors play a role in how buffers are
erecting structures (Figure 1). managed within a neighborhood: the age of the
development, lot size, activism of homeowner
How Bufferscaping Influences association, boundary signs, and the prior
Subwatershed Quality existence of stream buffer or flood plain
regulations.
A forested stream corridor is an essential
ingredient of a healthy stream, except in certain
arid and semi-arid regions. Bufferscaping can
add to the total area of the stream corridor,
provide wildlife habitat and enhance the
structure and function of the buffer. By contrast,
encroachment activities diminish the quality,
function and attractiveness of the stream buffer.
Percentage of People Encroaching

on/Expanding the Stream Corridor
Data is not currently available to estimate the

rate at which homeowners add to the stream
corridor, but several troubling studies have
examined the degree of residential buffer
encroachment. Many residents perceive buffers
Figure 1: A New Subdivision Encroaching
as an extension of their backyard, and think little
on the Stream Buffer
of removing trees, dumping yard wastes or
erecting structures on their land. A major reason
is that nearly 60% of residents are ignorant of
the boundaries and intended purpose of stream

Techniques to Encourage Tennessee Valley Authority Banks and Buffers

Buffer Stewardship Software: A Guide to Selecting Native Plants for
Streambanks and Shorelines includes software
Protecting or expanding stream buffers requires application to help homeowners select plants for
direct education and interaction with individual bufferscaping. It also contains selected
property owners that back up to the buffer. Some characteristics and environmental tolerances of
useful techniques include: 117 plants and more than 400 color photographs
illustrating habitat and growth form.
• Bufferscaping assistance and guides http://www.tva.gov/river/landandshore/stabilizat
• Community buffer walks ion/websites.htm
• Buffer boundary inspections
• Boundary signs (Figure 2) Top Resources
• Defining unallowed uses in local stream
buffer ordinances The Architecture of Urban Stream Buffers
• Presentations to community associations http://www.stormwatercenter.net/Library/Practic
• Adopt-a-stream program e/39.pdf
• Financial incentives for bufferscaping
Chesapeake Bay Riparian Handbook: A Guide
for Establishing and Maintaining Riparian
Forest Buffers
http://www.chesapeakebay.net/pubs/subcommitt
ee/nsc/forest/riphbk.pdf
Riparian Forest Buffer Design, Establishment,

and Maintenance
http://www.agnr.umd.edu/MCE/Publications/Pu
blication.cfm?ID=13
Riparian Area Management: A Citizen's Guide

http://www.co.lake.il.us/elibrary/publications/sm
c/riparian.pdf
http://sites.state.pa.us/PA_Exec/Fish_Boat/
Figure 2: Sign Identifying a Buffer Boundary Backyard Buffers for the South Carolina
Lowcountry
Good Examples http://www.scdhec.net/ocrm/pubs/backyard.pdf
Burnett County, WI Natural Shoreline Alliance for the Chesapeake Bay – Backyard
Incentives. The county pays homeowners to Buffers
enroll in a program to maintain shorelines in http://www.acb-
their natural state. The program asks for a online.org/pubs/projects/deliverables-158-1-
voluntary commitment by placing a covenant on 2003.pdf
a homeowner’s property stating that the
shoreline will remain natural. Program members Cayuga County, NY – Green Thumbs for Blue
receive a payment of $250 after an initial Water Workshops
inspection that certifies the property meets http://www.co.cayuga.ny.us/wqma/greenthumbs
program standards, and the shoreline covenant is
recorded. Participants also receive an annual Tree-mendous Maryland
deduction from their tax statement as a thank http://www.dnr.state.md.us/forests/treemendous/
you.
http://www.burnettcounty.com/burnett/lwcd/pres
erve.html

N-21 STORM DRAIN MARKING
Description Percentage of Residents Engaging

in Storm Drain Marking
The ideal watershed behavior is to get residents
to fully understand the connection between This behavior does not require extensive
storm drains and downstream waters and avoid resident participation; only a few trained
any activity that discharges pollutants. This volunteers are needed to thoroughly mark storm
awareness is most often created by marking or drains within a neighborhood. Volunteers can
stenciling storm drain inlets with a “Don’t include scouts, service groups, high school
dump, drains to...” message (Figure 1). The students, neighborhood associations, and other
negative watershed behavior is to use storm volunteers. Normally, marking is “sanctioned”
drains as a means of disposal for trash, yard by the local public works authority or
waste and household products. environmental agency, so it is important to
coordinate closely with them (Figure 2). Table 1
How Storm Drain Marking Influences provides guidance for marking storm drains.
Water Quality
Factors to Consider in Storm Drain
Storm drain marking sends a clear message to Marking
keep trash and debris, leaf litter and organic
matter out of the storm drain system. Stencils The only significant impediment to storm drain
may also reduce residential spills and illicit marking is when a neighborhood is primarily
discharges. Marking is also a direct and local served by open channels or grassed channels,
way to increase watershed awareness and rather than enclosed storm drains.
practice neighborhood stewardship. The actual
water quality benefits of storm drain marking
have yet to be demonstrated through field
research or monitoring. Still, marking is always
a sign of good neighborhood housekeeping.
Santa Monica, CA also marks the hotline phone
number on storm drains to report water quality
problems and illegal dumping.
Figure 1: Storm Drain Marking

Figure 2: Educational Brochure on Storm Drain Marking/Stenciling

Source: http://www.sactostormwater.org/documents/stencil_brochure_03.pdf
Table 1: Storm Drain Marking Guidance

• Enlist one person to serve as the team leader, and make sure he/she knows all marking rules and
safety procedures.
• Review all safety procedures before marking.
• Marking should be performed by at least two people, so one can be on the lookout for oncoming
vehicles. Safety vests and traffic cones can be used to alert vehicles.
• Remember to wear old cloths and shoes.
• Bring paper towels or a rag to wipe up and two trash bags – one for the wet stencil (when
necessary), which is not garbage, and one to pick-up garbage along the way.
• Keep track of all storm drain stencils and turn this information over to the team leader or the
appropriate local government agency.
• Do not mark any storm drains with vehicles parked nearby.
• Record the locations of any storm drains that have leaves, grass clippings, oil, or other pollutants.
• Properly dispose of all trash at the end of the day, and return all empty paint cans and supplies to
the team leader.
Information adapted from the following sources:
http://www.deq.state.la.us/assistance/litter/stormdrain.htm
Storm Drain Stenciling: A Manual for Communities (GI-212) developed by the Texas Natural Resource Conservation
Commission

Top Resources The Ocean Conservancy’s Storm Drain Sentries

http://www.oceanconservancy.org/site/PageServ
Texas Natural Resource Conservation er?pagename=op_sentries
Commission’s Storm Drain Stenciling: A
Guide for Communities. This extensive guide South Carolina Department of Health and
includes information on how to get volunteers Environmental Control’s Water Watch
involved, guidelines and materials for marking, Campaign: Conducting a Storm Drain Tagging
reviews of five marking programs, and sample Project
recognition certificates, press releases, door http://www.scdhec.net/water/pubs/wwtag2.pdf
hangers, and public service announcements.
http://www.tnrcc.state.tx.us/exec/sbea/education. Multilingual Storm Drain Stenciling GreenSpace
html Partners worked with local watershed groups
and volunteers to stencil storm drains with
The Urban Dweller's Guide To Watersheds messages in English, Somali and Spanish.
http://www.museumca.org/creeks/umbrella.html http://www.greeninstitute.org/GSP/programs/sto
rmwater/stencils/stencils.html
University of Wisconsin-Extension Water
Resources Program Storm Drain Stenciling Web North Carolina’s Storm Drain Stenciling
Page Project This project was piloted in 1994 along
http://clean- coastal NC watersheds and has received support
water.uwex.edu/wav/stormdrain/index.htm from many state and national organizations and
has received the “Take Pride in North Carolina”
Earthwater Stencils Home Page Award.
http://www.earthwater-stencils.com/ http://www.bae.ncsu.edu/bae/programs/extensio
n/wqg/smp-18/stormdrain/
Storm Drain Stenciling Project Guidelines
http://www.epa.gov/adopt/patch/html/guidelines.
html


Chapter 6: Hotspot Pollution Prevention Practice Profile Sheets
Chapter 6: Hotspot Pollution Prevention

Practice Profile Sheets
This chapter presents profile sheets that describe implementation, and cost factors to consider.
15 different pollution prevention practices that Extensive resources, references and websites are
can be applied to storm water hotspots. The also listed where you can get more information
sheets are organized by the six common hotspot on each pollution prevention practice. The
operations, and explain basic pollution pollution prevention practices profiled in this
prevention practices, along with key feasibility, chapter include:
Profile Sheet Page

H-1 Vehicle Maintenance and Repair ................................................................................................ 111
H-2 Vehicle Fueling.......................................................................................................................... 113
H-3 Vehicle Washing........................................................................................................................ 117
H-4 Vehicle Storage.......................................................................................................................... 121
H-5 Loading and Unloading.............................................................................................................. 123
H-6 Outdoor Storage ......................................................................................................................... 125
H-7 Spill Prevention and Response................................................................................................... 127
H-8 Dumpster Management ............................................................................................................. 133
H-9 Building Repair and Remodeling............................................................................................... 137
H-10 Building Maintenance................................................................................................................ 141
H-11 Parking Lot Maintenance........................................................................................................... 143
H-12 Turf Management ...................................................................................................................... 145
H-13 Landscaping/Grounds Care........................................................................................................ 149
H-14 Swimming Pool Discharges ...................................................................................................... 153
H-15 Unique Hotspot Operations........................................................................................................ 155
www.appowerwash.com


Hotspot Source Area: Vehicles
H-1 VEHICLE MAINTENANCE AND

REPAIR
Description grease, trace metals, hydrocarbons, and other

toxic organic compounds. Table 1 summarizes a
Vehicle maintenance and repair operations can series of simple pollution prevention techniques
exert a significant impact on water quality by for vehicle maintenance and repair operations
generating toxins such as solvents, waste oil, that can prevent storm water contamination. You
antifreeze, and other fluids. Often, vehicles that are encouraged to consult the Resources section
are wrecked or awaiting repair can be a storm of this sheet to get a more comprehensive review
water hotspot if leaking fluids are exposed to of pollution prevention practices for vehicle
storm water runoff (Figure 1). Vehicle maintenance and repair operations.
maintenance and repair can generate oil and
Application
Pollution prevention practices should be applied

to any facility that maintains or repairs vehicles
in a subwatershed. Examples include car
dealerships, body shops, service stations, quick
lubes, school bus depots, trucking companies,
and fleet maintenance operations at larger
industrial, institutional, municipal or transport-
related operations. Repair facilities are often
Figure 1: Junkyard and Potential clustered together, and are a major priority for
Source of Storm Water Pollution subwatershed pollution prevention.
Table 1: Pollution Prevention Practices for Vehicle Maintenance and Repair Activities
• Avoid hosing down work or fueling areas
• Clean all spills immediately using dry cleaning techniques
• Collect used antifreeze, oil, grease, oil filters, cleaning solutions, solvents, batteries, hydraulic
and transmission fluids and recycle with appropriate agencies
• Conduct all vehicle and equipment repairs indoors or under a cover (if done outdoors)
• Connect outdoor vehicle storage areas to a separate storm water collection system with an
oil/grit separator that discharges to a dead holding tank, the sanitary sewer or a storm water
treatment practice
• Designate a specific location for outdoor maintenance activities that is designed to prevent
storm water pollution (paved, away from storm drains, and with storm water containment
measures)
• Inspect the condition of all vehicles and equipment stored outdoors frequently
• Use a tarp, ground cloth, or drip pans beneath vehicles or equipment being repaired outdoors
to capture all spills and drips
• Seal service bay concrete floors with an impervious material so cleanup can be done without
using solvents. Do not wash service bays to outdoor storm drains
• Store cracked batteries in a covered secondary containment area until they can be disposed
of properly
• Wash parts in a self-contained solvent sink rather than outdoors

Primary Training Targets California Stormwater Quality Association.

2003 California Stormwater BMP Handbook:
Owners, fleet operation managers, service Industrial and Commercial.
managers, maintenance supervisors, mechanics http://www.cabmphandbooks.com/
and other employees are key targets for training.
Coordinating Committee For Automotive Repair
Feasibility (CCAR) Source: US EPA CCAR-GreenLink®,
the National Automotive Environmental
Pollution prevention techniques for vehicle Compliance Assistance Center CCAR-
repair facilities broadly apply to all regions and GreenLink® Virtual Shop http://www.ccar-
climates. These techniques generally rely on greenlink.org/
changes to basic operating procedures, after an
initial inspection of facility operations. The Auto Body Shops Pollution Prevention Guide.
inspection relies on a standard operations Peaks to Prairies Pollution Prevention
checklist that can be completed in a few hours. Information Center.
http://peakstoprairies.org/p2bande/autobody/abg
Implementation Considerations uide/index.cfm
Employee training is essential to successfully Massachusetts Office of Technical Assistance for

implement vehicle repair pollution prevention Toxics Use Reduction (OTA). Crash Course for
practices. The connection between the storm Compliance and Pollution Prevention Toolbox
drain system and local streams should be http://www.state.ma.us/ota/pubs/toolfull.pdf
emphasized so that employees understand why
any fluids need to be properly disposed of. It is Model Urban Runoff Program: A How-To Guide
also important to understand the demographics for Developing Urban Runoff Programs for
of the work force; in some communities, it may Small Municipalities.
require a multilingual education program. http://www.swrcb.ca.gov/stormwtr/murp.html
Cost - Employee training is generally US EPA. Virtual Facility Regulatory Tour:

inexpensive, since training can be done using Vehicle Maintenance. FedSite Federal Facilities
posters, pamphlets, or videos. Structural Compliance Assistance Center.
practices can vary based on what equipment is http://permanent.access.gpo.gov/websites/epago
required. For instance, solvent sinks to clean v/www.epa.gov/fedsite/virtual.html
parts can cost from $1,500 to $15,000, while
spray cabinets may cost more than $50,000. In
addition, proper recycling/disposal of used or City of Santa Cruz. Best Management Practices for
spilled fluids usually requires outside contractors Vehicle Service Facilities (in English and Spanish).
that may increase costs. http://www.ci.santa-
cruz.ca.us/pw/pdf/vehiclebmp.pdf
Resources
City of Los Angeles Bilingual Poster of BMPs
Stormwater Management Manual for Western for Auto Repair Industry
Washington: Volume IV -- Source Control http://www.lastormwater.org/downloads/PDFs/a
BMPs. utopstr.pdf
http://www.ecy.wa.gov/biblio/9914.html

H-2 VEHICLE FUELING
Description stations, bus depots, marinas, and fleet

maintenance operations (Figure 1). In
Spills at vehicle fueling operations have the addition, these practices also apply to temporary
potential to directly contribute oil, grease, and above-ground fueling areas for construction and
gasoline to storm water, and can be a significant earthmoving equipment. Many fueling areas are
source of lead, copper and zinc, and petroleum usually present in urban subwatersheds, and they
hydrocarbons. Delivery of pollutants to the tend to be clustered along commercial and
storm drain can be sharply reduced by well- highway corridors. These hotspots are often a
designed fueling areas and improved operational priority for subwatershed source control.
procedures. The risk of spills depends on
whether the fueling area is covered and has
secondary containment. The type, condition,
and exposure of the fueling surface can also be
important. Table 1 describes common pollution
prevention practices for fueling operations.
Application
These practices can be applied to any facility

that dispenses fuel. Examples include retail gas
Figure 1: Covered Retail Gas Operation
Without Containment for Potential Spills
Table 1: Pollution Prevention Practices For Fueling Operation Areas

• Maintain an updated spill prevention and response plan on premises of all fueling facilities (see
Profile Sheet H-7)
• Cover fueling stations with a canopy or roof to prevent direct contact with rainfall
• Design fueling pads for large mobile equipment to prevent the run-on of storm water and collect
any runoff in a dead-end sump
• Retrofit underground storage tanks with spill containment and overfill prevention systems
• Keep suitable cleanup materials on the premises to promptly clean up spills
• Install slotted inlets along the perimeter of the “downhill” side of fueling stations to collect fluids and
connect the drain to a waste tank or storm water treatment practice. The collection system should
have a shutoff valve to contain a large fuel spill event
• Locate storm drain inlets away from the immediate vicinity of the fueling area
• Clean fuel-dispensing areas with dry cleanup methods. Never wash down areas before dry clean
up has been done. Ensure that wash water is collected and disposed of in the sanitary sewer
system or approved storm water treatment practice
• Pave fueling stations with concrete rather than asphalt
• Protect above ground fuel tanks using a containment berm with an impervious floor of Portland
cement. The containment berm should have enough capacity to contain 110% of the total tank
volume
• Use fuel-dispensing nozzles with automatic shutoffs, if allowed
• Consider installing a perimeter sand filter to capture and treat any runoff produced by the station

Primary Training Targets measures, ongoing maintenance costs should be

low.
Training efforts should be targeted to owners,
operators, attendants, and petroleum Resources
wholesalers.
Best Management Practice Guide – Retail
Feasibility Gasoline Outlets. Prepared by Retail Gasoline
Outlet Work Group.
Vehicle fueling pollution prevention practices http://www.swrcb.ca.gov/rwqcb4/html/programs
apply to all geographic and climatic regions. The /stormwater/la_ms4_tentative/RGO BMP
practices are relatively low-cost, except for Guide_03-97_.pdf
structural measures that are installed during new
construction or station remodeling. Stormwater Management Manual for Western
Washington: Volume IV -- Source Control
Implementation Considerations BMPs.
Fueling Area Covers - Fueling areas can be
covered by installing an overhanging roof or California Stormwater Quality Association.
canopy. Covers prevent exposure to rainfall and 2003 California Stormwater BMP Handbook:
are a desirable amenity for retail fueling station New Development and Redevelopment.
customers. The area of the fueling cover should http://www.cabmphandbooks.com/
exceed the area where fuel is dispensed. All
downspouts draining the cover or roof should be City of Los Angeles, CA Best Management
routed to prevent discharge across the fueling Practices for Gas Stations
area. If large equipment makes it difficult to http://www.lacity.org/SAN/wpd/downloads/PDF
install covers or roofs, fueling islands should be s/gasstation.pdf
designed to prevent storm water run-on through
grading, and any runoff from the fueling area City of Dana Point Stormwater Best
should be directed to a dead-end sump. Management Practices (BMPs) For Automotive
Maintenance And Car Care
Surfaces - Fuel dispensing areas should be paved http://www.danapoint.org/water/WC-
with concrete; the use of asphalt should be AUTOMOTIVE.pdf
avoided, unless the surface is sealed with an
impervious sealant. Concrete pads used in fuel Alachua County, FL Best Management Practices
dispensing areas should extend to the full length for Controlling Runoff from Gas Stations
that the hose and nozzle assembly can be pulled, http://environment.alachua-
plus an additional foot. county.org/Natural_Resources/Water_Quality/D
ocuments/Gas%20Stations.pdf
Grading - Fuel dispensing areas should be
graded with a slope that prevents ponding, and California Stormwater Regional Control Board
separated from the rest of the site by berms, Retail Gasoline Outlets: New Development
dikes or other grade breaks that prevent run-on Design Standards For Mitigation Of Storm
of urban runoff. The recommended grade for Water Impacts
fuel dispensing areas is 2 - 4% (CSWQTF, http://www.swrcb.ca.gov/rwqcb4/html/programs
1997). /stormwater/la_ms4_tentative/RGOpaper.pdf
http://www.swrcb.ca.gov/rwqcb4/html/programs
Cost - Costs to implement pollution prevention /stormwater/la_ms4_tentative/RGOPaperSupple
practices at fueling stations will vary, with many ment_12-01_.pdf
of the costs coming upfront during the design of
a new fueling facility. Once a facility has
implemented the recommended source control

Canadian Petroleum Products Institute Best

Management Practices Stormwater Runoff from
Petroleum Facilities
http://www.cppi.ca/tech/BMPstormwater.pdf
City of Monterey (CA). Posters of Gas Station

BMPs.
http://www.monterey.org/publicworks/stormedu
c.html
Pinole County, CA Typical Stormwater

Violations Observed in Auto Facilities and
Recommended Best Management Practices
(BMPs)
http://www.ci.pinole.ca.us/publicworks/downloa
ds/AutoStormwater.pdf


H-3 VEHICLE WASHING

Description Feasibility
Vehicle washing pollution prevention practices Vehicle washing practices can be applied to all
apply to many commercial, industrial, regions and climates. Vehicle washing tends to
institutional, municipal and transport-related occur more frequently in summer months and in
operations. Vehicle wash water may contain drier regions of the country. Sound vehicle
sediments, phosphorus, metals, oil and grease, washing practices are not always used at many
and other pollutants that can degrade water sites because operators are reluctant to change
quality. When vehicles are washed on traditional cleaning methods. In addition, the
impervious surfaces such as parking lots or cost of specialized equipment to manage high
industrial areas, dirty wash water can volumes of wash water can be too expensive for
contaminate storm water that ends up in streams. small businesses.
Application Improved vehicle washing practices are

relatively simple to implement and are very
Improved washing practices can be used at any effective at preventing storm water
facility that routinely washes vehicles. Examples contamination. Training is essential to get
include commercial car washes, bus depots, car owners and employees to adopt these practices,
dealerships, rental car companies, trucking and should be designed to overcome cultural and
companies, and fleet operations. In addition, social barriers to improved washing practices.
washing dump trucks and other construction
equipment can be a problem. Washing
Table 1: Pollution Prevention Practices for
operations tend to be unevenly distributed within Vehicle Washing
urban subwatersheds. Vehicle washing also • Wash vehicles at indoor car washes that
occurs in neighborhoods, and techniques to keep recycle, treat or convey wash water to the
wash water out of the storm drain system are sanitary sewer system
discussed in the car washing profile sheet (N- • Use biodegradable, phosphate-free,
11). Table 1 reviews some of the pollution water-based soaps
prevention techniques available for hotspot • Use flow-restricted hose nozzles that
vehicle washing operations. automatically turn off when left
unattended
• Wash vehicles on a permeable surface or
Primary Training Targets
a washpad that has a containment system
• Prohibit discharge of wash water into the
Owners, fleet managers, and employees of storm drain system or ground by using
operations that include car washes are the temporary berms, storm drain covers,
primary training target. drain plugs or other containment system
• Label storm drains with “No Dumping”
signs to deter disposal of wash water in
the storm drain system
• Pressure and steam clean off-site to avoid
runoff with high pollutant concentrations
• Obtain permission from sewage treatment
facilities to discharge to the sanitary
sewer

Implementation Considerations pressure washing of engines and vehicle

undercarriages must be disposed of using the
The ideal practice is to wash all vehicles at same options.
commercial car washes or indoor facilities that
are specially designed for washing operations. Discharge to pervious areas may be an option
Table 2 offers some tips for indoor car wash for washing operations that generate small
sites. When washing operations are conducted amounts of relatively clean wash water (water
outside, a designated wash area should having only - no soaps, no steam cleaning). The clean
the following characteristics: wash water should be directed as sheet flow
across a vegetated area to infiltrate or evaporate
• Paved with an impervious surface, such as before it enters the storm drain system. This
Portland cement concrete option should be exercised with caution,
• Bermed to contain wash water especially in environmentally sensitive areas or
• Sloped so that wash water is collected and protected groundwater recharge areas.
discharged to the sanitary sewer system,
holding tank or dead-end sump The best way to avoid stormwater contamination
• Operated by trained workers to confine during washing operations is to drain the wash
washing operations to the designated water to the sanitary sewer system. Operations
wash area that produce high volumes of wash water should
consider installing systems that connect to the
Outdoor vehicle washing facilities should use sewer. Other options for large and small
pressurized hoses without detergents to remove operations include containment units to capture
most dirt and grime. If detergents are used, they the wash water prior to transport away for
should be phosphate-free to reduce nutrient proper disposal (Figure 1). If vehicles must be
loading. If acids, bases, metal brighteners, or washed on an impervious surface, a storm drain
degreasing agents are used, wash water should filter should be used to capture solid
be discharged to a treatment facility, sanitary contaminants.
sewer, or a sump. In addition, waters from the
Cost - The cost of using vehicle-washing
Table 2: Tips for Indoor Car Wash Sites practices can vary greatly and depends on the
(Adapted from U.S. EPA, 2003) size of the operation (Table 3). The cost of
• Facilities should have designated areas for constructing a commercial grade system
indoor vehicle washing where no other connected to the sanitary sewer can exceed
activities are performed (e.g. fluid changes $100,000. Disposal fees and frequency of
or repair services)
washing can also influence the cost. Training
• Indoor vehicle wash areas should have
floor drains that receive only vehicle costs can be minimized by using educational
washing wastewater (not floor washdown
or spill removal wash waters) and be
connected to a holding tank with a gravity
discharge pipe, to a sump that pumps to a
holding tank, or to an oil/grit separator that
discharges to a municipal sanitary sewer
• The floor of indoor vehicle wash bays
should be completely bermed to collect
wash water
• Aromatic and chlorinated hydrocarbon
solvents should be eliminated from vehicle-
washing operations
• Vehicle-washing operations should use
vehicle rinsewater to create new wash
water through the use of recycling systems Figure 1: Containment System Preventing
that filter and remove grit. Wash Water from Entering the Storm Drain

materials available from local governments, Resources

professional associations or EPA’s National
Compliance Assistance Centers EPA FedSite Virtual Facility Regulatory Tour,
(http://www.assistancecenters.net/). Temporary, Vehicle Maintenance Facility Tour. Vehicle
portable containment systems can be shared by Washing - P2 Opportunities
several companies that cannot afford specialized http://permanent.access.gpo.gov/websites/epago
equipment independently. v/www.epa.gov/fedsite/virtual.html
Table 3: Sample Equipment Costs for Alachua County Pollution Prevention Fact
Vehicle Washing Practices Sheet: Best Management Practices for
Item Cost Controlling Runoff from Commercial Outdoor
Bubble Buster $2,000 –2,500* Car Washing. http://environment.alachua-
Catch basin insert $65* county.org/Natural_Resources/Water_Quality/D
ocuments/Commercial Outdoor Car Wash.pdf.
Containment mat $480-5,840**
Storm drain cover
(24" drain)
$120.00 ** Kitsap County Sound Car Wash Program.
Water dike/ berm http://www.kitsapgov.com/sswm/carwash.htm.
$100.00 **
(20 ft)
Pump $75-3,000** Washington Department of Ecology. 1995.
Vehicle and Equipment Wash Water Discharges:
Wastewater storage
$50-1,000+** Best Management Practices Manual. Olympia,
container
Source: *U.S. EPA, 1992 **Robinson, 2003 Washington.
http://www.ecy.wa.gov/pubs/95056.pdf
U.S. Environmental Protection Agency.

Pollution Prevention/Good Housekeeping for
Municipal Operations.
http://cfpub2.epa.gov/npdes/stormwater/menuof
bmps/poll_18.cfm
California Stormwater Quality Association.

2003 California Stormwater BMP Handbook:
Industrial and Commercial.
http://www.cabmphandbooks.com/


H-4 VEHICLE STORAGE
Description largest, most heavily used parking lots with

vehicles in the poorest condition (e.g., older cars
Parking lots and vehicle storage areas can or wrecked vehicles) should be targeted first.
introduce sediment, metals, oil and grease, and This practice is also closely related to parking
trash into storm water runoff. Simple pavement lot maintenance source controls, which are
sweeping, litter control, and storm water discussed in greater detail in profile sheet H-11.
treatment practices can minimize pollutant
export from these hotspots. Table 1 provides a Primary Training Targets
list of simple pollution prevention practices
intended to prevent or reduce the discharge of Owners, fleet operation managers, and property
pollutants from parking and vehicle storage managers that maintain parking lots are key
areas. training targets.
Application
Pollution prevention practices can be used at

larger parking lots located within a
subwatershed. Examples include regional malls,
stadium lots, big box retail, airport parking, car
dealerships, rental car companies, trucking
companies, and fleet operations (Figure 1). The
Figure 1: Retail Parking Lot
Table 1: Pollution Prevention Practices for Parking Lot and Vehicle Storage Areas
Parking Lots
• Post signs to control litter and prevent patrons from changing automobile fluids in the parking lot
(e.g., changing oil, adding transmission fluid, etc.)
• Pick up litter daily and provide trash receptacles to discourage littering
• Stencil or mark storm drain inlets with "No Dumping, Drains to ______" message
• Direct runoff to bioretention areas, vegetated swales, or sand filters
• Design landscape islands in parking areas to function as bioretention areas
• Disconnect rooftop drains that discharge to paved surfaces
• Use permeable pavement options for spillover parking (Profile sheet OS-11 in Manual 3)
• Inspect catch basins twice a year and remove accumulated sediments, as needed
• Vacuum or sweep large parking lots on a monthly basis, or more frequently
• Install parking lot retrofits such as bioretention, swales, infiltration trenches, and storm water
filters (Profile sheets OS-7 through OS-10 in Manual 3)
Vehicle Storage Areas

• Do not store wrecked vehicles on lots unless runoff containment and treatment are provided
• Use drip pans or other spill containment measures for vehicles that will be parked for extended
periods of time
• Use absorbent material to clean up automotive fluids from parking lots

Feasibility Catch basin cleanouts are also an important

practice in parking areas. Catch basins within
Sweeping can be employed for parking lots that the parking lot should be inspected at least twice
empty out on a regular basis. Mechanical a year and cleaned as necessary. Cleanouts can
sweepers can be used to remove small quantities be done manually or by vacuum truck. The
of solids. Vacuum sweepers should be used on cleanout method selected depends on the
larger parking lot storage areas, since they are number and size of the inlets present (see
superior in picking up deposited pollutants (See Manual 9).
Manual 9). Constraints for sweeping large
parking lots include high annual costs, difficulty Most communities have contractors that can be
in controlling parking, and the inability of hired to clean out catch basins and vacuum
current sweeper technology to remove oil and sweep lots. Mechanical sweeping services are
grease. Proper disposal of swept materials might available, although the cost to purchase a new
also represent a limitation. sweeper can exceed $200,000. Employee
training regarding spill prevention for parking
Implementation Considerations areas is generally low-cost and requires limited
staff time.
The design of parking lots and vehicle storage
areas can greatly influence the ability to treat Resources
storm water runoff. Many parking areas are
landscaped with small vegetative areas between California Stormwater Quality Association.
parking rows for aesthetic reasons or to create a 2003 California Stormwater BMP Handbook:
visual pattern for traffic flow. These landscaped Industrial and Commercial
areas can be modified to provide storm water http://www.cabmphandbooks.com/
treatment in the form of bioretention (Figure 2).
Stormwater Management Manual for Western
Washington: Volume IV -- Source Control
BMPs. WA Dept. of Ecology
Figure 2: Parking Lot Island Turned

Bioretention Area

Hotspot Source Area: Outdoor Materials
H-5 LOADING AND UNLOADING
Description Primary Training Targets
Outdoor loading and unloading normally takes Owners, site managers, facility engineers,
place on docks or terminals at many supervisors, and employees of operations with
commercial, industrial, institutional, and loading/unloading facilities are the primary
municipal operations. Materials spilled or leaked training target.
during this process can either be carried away in
storm water runoff or washed off when the area Feasibility
is cleaned. As a result, many different pollutants
can be introduced into the storm drain system, Loading/unloading pollution prevention
including sediment, nutrients, trash, organic practices can be applied in all geographic and
material, trace metals, and an assortment of climatic regions, and work most effectively at
other pollutants. A number of simple and preventing sediment, nutrients, toxic materials,
effective pollution prevention practices can be and oil from coming into contact with storm
used at loading/unloading areas to prevent water runoff or runon. Few impediments exist to
runoff contamination, as shown in Table 1. using this practice, except for the cost to retrofit
existing loading and unloading areas with covers
Application or secondary containment.
While nearly every commercial, industrial,

institutional, municipal and transport-related site
has a location where materials or products are
shipped or received, the risk of storm water
pollution is greatest for operations that transfer
high volumes of material or liquids, or unload
potentially hazardous materials. Some notable
examples to look for in a subwatershed include
distribution centers, grocery stores, building
supply outlets, lawn and garden centers,
petroleum wholesalers, warehouses, landfills,
ports, solid waste facilities, and maintenance Figure 1: Loading/Unloading Area of
depots (Figure 1). Attention should also be paid Warehouse
to industrial operations that process bulk
materials, and any operations regulated under
industrial storm water NPDES permits.

Table 1: Pollution Prevention Practices for Loading and Unloading Areas

• Avoid loading/unloading materials in the rain
• Close adjacent storm drains during loading/unloading operations
• Surround the loading/unloading area with berms or grading to prevent run-on or pooling of storm
water. If possible, cover the area with a canopy or roof
• Ensure that a trained employee is always present to handle and cleanup spills
• Inspect the integrity of all containers before loading/unloading
• Inspect equipment such as valves, pumps, flanges, and connections regularly for leaks, and repair
as needed
• Install an automatic shutoff valve to interrupt flow in the event of a catastrophic liquid spill
• Install a high-level alarm on storage tanks to prevent overfilling
• Pave the loading/unloading area with concrete rather than asphalt
• Place drip pans or other temporary containment devices at locations where leaks or spills may
occur, and always use pans when making and breaking connections
• Position roof downspouts to direct storm water away from loading/unloading areas and into
bioretention areas
• Prepare and implement an Emergency Spill Cleanup Plan for the facility (see Profile Sheet H-7)
• Sweep loading/unloading area surfaces frequently to remove material that could otherwise be
washed off by storm water
• Train all employees, especially fork lift operators, on basic pollution prevention practices and post
signs
• Use seals, overhangs, or door skirts on docks and terminals to prevent contact with rainwater
Implementation Considerations Resources
Loading/unloading pollution prevention California Stormwater Quality Association.

practices should be integrated into the overall 2003 California Stormwater BMP Handbook:
storm water pollution prevention plan for a Industrial and Commercial.
facility. Employee training should focus on http://www.cabmphandbooks.com/
proper techniques to transfer materials, using
informational signs at loading docks and Stormwater Management Manual for Western
material handling sites and during routine safety Washington: Volume IV -- Source Control
meetings. BMPs. WA Dept. of Ecology 99-14
Cost - Costs to implement loading/unloading
pollution prevention practices consist of one- Ventura County Flood Control District Clean
time construction costs to retrofit new or Business Program Fact Sheet
existing loading areas, but annual maintenance http://www.vcstormwater.org/sheet-
costs are relatively low thereafter. Exceptions materials.htm
include industries that elect to use expensive air
pressure or vacuum systems for Business Best Management Practices
loading/unloading facilities, which can also be Stormwater Bmp #3 -
expensive to maintain (U.S. EPA, 1992). Shipping/Receiving/Loading Docks
Ongoing costs include employee training and http://www.cleancharles.org/stormwater_bmp3.s
periodic monitoring of loading/unloading html
activities.
City of Los Angeles, CA Reference Guide For
Stormwater Best Management Practices
http://www.lastormwater.org/downloads/PDFs/b
mp_refguide.pdf

Hotspot Source Area: Outdoor Materials
H-6 OUTDOOR STORAGE
Description Application
Protecting outdoor storage areas is a simple and Many businesses store materials or products
effective pollution prevention practice for many outdoors. The risk of storm water pollution is
commercial, industrial, institutional, municipal, greatest for operations that store large quantities
and transport-related operations. The underlying of liquids or bulk materials at sites that are
concept is to prevent runoff contamination by connected to the storm drain system. Several
avoiding contact between outdoor materials and notable operations include nurseries and garden
rainfall (or runoff). Unprotected outdoor storage centers, boat building/repair, auto recyclers/body
areas can generate a wide range of storm water shops, building supply outlets, landfills, ports,
pollutants, such as sediment, nutrients, toxic recycling centers, solid waste and composting
materials, and oil and grease (Figure 1). facilities, highway maintenance depots, and
power plants. Attention should also be paid to
Materials can be protected by installing covers, industrial operations that process bulk materials,
secondary containment, and other structures to which are often regulated under industrial storm
prevent accidental release. Outdoor storage areas water NPDES permits.
can be protected on a temporary basis (tarps or
plastic sheeting) or permanently through Primary Training Targets
structural containment measures (such as roofs,
buildings, or concrete berms). Table 1 Owners, site managers, facility engineers,
summarizes pollution prevention practices supervisors, and employees of operations with
available for outdoor storage areas. loading/unloading facilities are the primary
training target.
Feasibility
Outdoor storage protection can be widely

applied in all regions and climate zones, and
requires routine monitoring by employees. Most
operations have used covering as the major
practice to handle outdoor storage protection
(U.S. EPA, 1999). The strategy is to design and
maintain outdoor material storage areas so that
they:
Figure 1: Mulch Stored Outdoors at a
Garden Center • Reduce exposure to storm water and
prevent runon
• Use secondary containment to capture
spills
• Can be regularly inspected
• Have an adequate spill response plan
and cleanup equipment

Table 1: Pollution Prevention Practices for Protecting Outdoor Storage Areas

• Emphasize employee education regarding storage area maintenance
• Keep an up-to-date inventory of materials stored outdoors, and try to minimize them
• Store liquids in designated areas on an impervious surface with secondary containment
• Inspect outdoor storage containers regularly to ensure that they are in good condition
• Minimize storm water run-on by enclosing storage areas or building a berm around them
• Slope containment areas to a drain with a positive control (lock, valve, or plug) that leads to the
sanitary sewer (if permitted) or to a holding tank
• Schedule regular pumping of holding tanks containing storm water collected from secondary
containment areas
Implementation Considerations Secondary containment can be constructed from

a variety of materials, such as concrete curbs,
Covers - The use of impermeable covers is an earthen berms, plastic tubs, or fiberglass or
effective pollution prevention practice for non- metal containers. The type of material used
hazardous materials. Covers can be as simple as depends on the substance contained and its
plastic sheeting or tarps, or more elaborate roofs resistance to weathering. In general, secondary
and canopies. Site layout, available space, containment areas should be sized to hold 110%
affordability, and compatibility with the covered of the volume of the storage tank or container
material all dictate the type of cover needed for a unless other containment sizing regulations
site. In addition, the cover should be compatible apply (e.g., fire codes).
with local fire and building codes and OSHA
workplace safety standards. Care should be If secondary containment areas are uncovered,
taken to ensure that the cover fully protects the any water that accumulates must be collected in
storage site and is firmly anchored into place. a sanitary sewer, a storm water treatment
system, or a licensed disposal facility. Water
Secondary Containment - Secondary quality monitoring may be needed to determine
containment is designed to contain possible whether the water is contaminated and dictate
spills of liquids and prevent storm water run-on the method of disposal. If the storm water is
from entering outdoor storage areas. Secondary clean, or an on-site storm water treatment
containment structures vary in design, ranging practice is used, a valve should be installed in
from berms and drum holding areas to specially- the containment dike so that excess storm water
designed solvent storage rooms (Figure 2). can be drained out of the storage area and
directed either to the storm drain (if clean) or
into the storm water treatment system (if
contaminated). The valve should always be kept
closed except when storm water is drained, so
that any spills that occur can be effectively
contained. Local sewer authorities may not
allow discharges from a large containment area
into the sewer system, and permission must be
obtained prior to discharge. If discharges to the
sanitary sewer system are prohibited,
containment should be provided, such as a
holding tank that is regularly pumped out.
Employee training on outdoor storage pollution

prevention should focus on the activities and site
Figure 2: Secondary Containment of areas with the potential to pollute storm water
Storage Drums Behind a Car Repair Shop and the proper techniques to manage material
storage areas to prevent runoff contamination.

Training can be conducted through safety Resources

meetings and the posting of on-site
informational signs. Employees should also California Stormwater Quality Association.
know the on-site person who is trained in spill 2003 California Stormwater BMP Handbook:
response. Industrial and Commercial.
Cost - Many storage protection practices are
relatively inexpensive to install (Table 2). Actual Rouge River National Wet Weather
costs depend on the size of the storage area and Demonstration Project. Wayne County, MI.
the nature of the pollution prevention practices. http://www.rougeriver.com/geninfo/rougeproj.ht
Other factors are whether practices are ml
temporary or permanent and the type of
materials used for covers and containment. Storm Water Management Fact Sheet:
Employee training can be done in connection Coverings. USEPA, Office of Water,
with other safety training to reduce program http://www.epa.gov/owm/mtb/covs.pdf.
costs. Training costs can also be reduced by
using existing educational materials from local EPA Office of Wastewater Management Storm
governments, professional associations or from Water Management Fact Sheet: Coverings
EPA’s National Compliance Assistance Centers http://www.epa.gov/owm/mtb/covs.pdf
(http://www.assistancecenters.net).
California Stormwater Quality Association
Factsheet: Outdoor Storage of Raw Materials
Table 2: Sample Equipment Costs for http://www.cabmphandbooks.com/Documents/
Outdoor Storage Protection
Municipal/SC-33.pdf
Storage
Protection Cost
Device Alameda Countywide Clean Water Program
Concrete Slab Outdoor Storage of Liquid Materials
(6”) $3.50 to $5.00 per ft2 http://www.cleanwaterprogram.com/outdoor_sto
$50 to $350 based on r_liquid_fact_sht.pdf
Containment
Pallets size and # of barrels to
be stored Washtenaw County, MI Community Partners for
Storage buildings $6 to $11 per ft2 Clean Streams Fact Sheet Series #1:
Housekeeping Practices
Tarps & Canopies $25 to $500 depending http://www.ewashtenaw.org/content/dc_drnbmp
on size of area to cover
Sources: Costs were derived from a review of 1.pdf
Ferguson et al., 1997 and numerous websites
that handle proprietary spill control or
hazardous material control products


Hotspot Source Area: Spills and Accidents
H-7 SPILL PREVENTION AND RESPONSE

Description subwatershed helps locate these potential storm
water hotspots. In addition, all industrial sites
Spill prevention and response plans describe regulated by individual or group NPDES storm
operational procedures to reduce spill risks and water permits must have an updated spill
ensure that proper controls are in place when prevention and response plan on-site. Lastly,
they do occur. Spill prevention plans standardize spill containment and response plans should be
everyday procedures and rely heavily on prepared for major highways that cross the
employee training and education. The subwatershed, since truck and tanker accidents
investment is a good one for most operations, often represent the greatest potential spill risk in
since spill prevention plans reduce potential many communities (Figure 1).
liability, fines and costs associated with spill
cleanup. Table 1 provides some simple tips to
prevent and respond to spills.
Application
A spill prevention and response plan is useful at

any storm water hotspot operation, and is
mandatory for any operation that uses,
generates, produces, or transports hazardous
materials, petroleum products or fertilizers.
These operations are known as SARA 312 sites
and are regulated by state environmental
agencies. A list of SARA 312 sites within a Figure 1: Overturned, Leaking Tractor Trailer
Table 1: Pollution Prevention Practices for Spill Prevention and Response

• Develop a Spill Prevention Plan and ensure that employees are familiar with it and proper spill
cleanup procedures
• Store and contain liquid materials to prevent the contents from entering the storm drain system,
surface waters, or groundwater (see Profile Sheet H-7 on outdoor material storage)
• Store and maintain appropriate spill cleanup materials in a readily accessible location and
strategically deploy them based on the type and quantities of chemicals present
• Schedule regular inspections for leaks and spills and replace storage containers as needed
• Label all containers according to their contents and potential hazards (e.g., solvent, gasoline)
• Clean up spills promptly and with as little water as possible; dispose of used cleanup materials
properly
• Always treat cleanup materials used for hazardous substances as a hazardous waste
• Use absorbents, gels, and foams to cleanup chemical materials
• Report spills that pose an immediate threat to human health or the environment to the appropriate
local agencies, such as the fire department

Primary Training Targets data sheet is required. The inventory should also
indicate what safeguards are currently in place to
The owner or operator, facility engineer, safety reduce the exposure of chemicals to storm water,
supervisor, and employees should receive annual provide insight as to spill risks, and help local
training on spill prevention and response. authorities in the event of an emergency
response (such as a fire).
Feasibility
3. Locations of Possible Spill Areas
Spill prevention and response plans are
recommended for storm water hotspots in every It is important to identify potential spill areas,
region and climate zone. project potential spill volume, and determine the
drainage paths in order to choose the most
Implementation Considerations appropriate prevention, containment, and spill
response practices. Areas at the site that can be
Cleanup costs for a single 55-gallon drum that most vulnerable to spills include the following:
spills and reaches the storm drain have been
estimated at 10 to 100 times its raw material • Areas for outdoor processing (H-4)
value. A spill reponse and prevention plan is • Loading and unloading sites (H-5)
used to assess how pollutants are handled at the • Outdoor storage locations (H-6)
site and the pattern of storm water movement. • Waste storage disposal (H-8)
The plan seeks to minimize the chance of
accidental spills and ensure that proper safety Also, the spill potential should be assessed for
and response measures are understood and stationary facilities, including manufacturing
applied (U.S. EPA, 1992). A good spill operations, warehouses, and service stations.
prevention and response plan includes five
major components: 4. A List of Required Spill Response Equipment
1. A Site Map and Evaluation of Past Spills and The plan should document what kind of spill
Leaks response equipment will be stored at the site,
and contain clear and concise step-by-step
A site map should provide the following instructions for their use.
information:
5. Employee Training Needs
• A general description of the facility
• Owner’s name and address Effective and repeated employee training is
• Nature of the activities at the facility essential to effectively implement this practice.
• Types of chemicals used Lack of employee motivation or training is
• Location of chemical storage areas considered the biggest weakness of most spill
• Location of the storm drains and water prevention plans. Employee training programs
bodies should be held annually to educate all personnel
• Direction of the drainage away from the on the spill prevention plan. Spill prevention
site messages can be reinforced through signage and
• Location of any structures or devices used periodic inspections. The spill response training
to prevent spills leaving the site program should include detailed information on
the following:
2. An Inventory of Materials at the Site
• The specific individuals responsible for
A material inventory list should be created implementing the plan
including the type of material, the location • Safety procedures for handling each kind
where it is stored, the type of container, its of waste
estimated volume, and whether a material safety

• Current emergency contact numbers to Resources

notify appropriate authorities
• Step-by-step procedures to contain, divert, California Stormwater Quality Association.
isolate, and clean up a spill 2003 California Stormwater BMP Handbook:
• Training in the use of spill response Industrial and Commercial.
equipment, including safety procedures www.cabmphandbooks.com
Cost - Spill prevention and response plans are a Setting Administrative Civil Liability. State Of
good investment since they reduce the liability, California Regional Water Quality Control
cleanup costs and penalties. The costs to Board, San Francisco Bay Region.
implement plans depend on the amount of www.swrcb.ca.gov/rwqcb2/OrderNum/99-
employee training and cleanup equipment 038.doc
needed (which vary depending on the size of the
facility); the containment needed; and the types Pollution Prevention Fact Sheet Sector:
of materials handled at the facility. The costs to Printers/Lithographer: Spill Prevention.
inspect the site and write a plan range from http://dep.state.ct.us/wst/p2/p2printer/spillpre.ht
$5,000 to as high as $20,000 for petroleum m
industries (IPAA, 2001). Costs to prepare plans
at most other hotspots are much lower – about EPA Office of Wastewater Management Storm
$4,000 to $7,000 (SWRCB, 1999). Annual costs Water Management Fact Sheet: Spill Prevention
to implement the plan are estimated to be less Planning
than $2,500, mostly for on-going training and http://www.epa.gov/owm/mtb/spillprv.pdf
spill response equipment. Table 2 shows some
of the equipment costs related to spill response. Developing A Spill Prevention Response Plan
http://www.dep.state.pa.us/dep/subject/pubs/wat
Table 2: Sample Equipment Costs for Spill er/wc/FS1471.doc
Prevention and Response
Storage City of Rancho Santa Margarita Spill
Protection Cost Prevention and Cleanup
Device http://www.cityofrsm.org/civica/filebank/blobdl
Absorbents $2 to $35 for 25 lb. bag oad.asp?BlobID=1697
$50 to $350, based on
Containment
size and number of barrels Land of Sky Regional Council Municipal
Pallets
to be stored Pollution Prevention Planning
$280 to $450, based on # http://h2o.enr.state.nc.us/su/PDF_Files/Land_of
Industrial Spill
of pads, booms, goggles,
Kits _Sky_factsheets/FactSheet_5.pdf
gloves, etc.
Sources: Costs were derived from a review of
numerous websites that handle proprietary spill Environmentally Responsible Best Management
control or hazardous material control products Practices Emergency Response and Spill
Cleanup Plans
http://www.cleanrivers-pdx.org/pdf/bmp04.pdf
City of Mitcham, Australia Emergency Spill

Response Factsheet
http://www.mitchamcouncil.sa.gov.au/webdata/r
esources/files/Emergency_Spil_Response_Plan1
.pdf


Hotspot Source Area: Waste Management
H-8 DUMPSTER MANAGEMENT

Description factors should be evaluated to determine whether
an individual dumpster could be a pollution
Dumpsters provide temporary storage of solid source. The first is whether the dumpster pad is
wastes at many businesses. Most dumpsters are directly connected to the storm drain system. The
unregulated hotspots that can be a significant second factor is how frequently the dumpster is
pollution source in many subwatersheds. Many emptied. Frequently emptied dumpsters usually
dumpsters are open, which allows rainfall to mix have more spillage and are open more often and
with the wastes, creating a potent brew exposed to rainfall. The last factor is the type and
affectionately known as “dumpster juice.” When moisture content of wastes thrown in the
combined with the inevitable spillage, dumpsters dumpster, which can include trash, yard waste,
can be a source of trash, oil and grease, metals, building rubble, food, or other waste products.
bacteria, organic material, nutrients, and
sediments. Poor dumpster management can make Good dumpster management is particularly
a site unsightly, create unpleasant odors, and important to reduce trash loadings to a stream.
attract rodents (Figure 1). Table 1 lists some Several kinds of hotspots deserve scrutiny if they
common pollution prevention practices for exist in a subwatershed, including dumpsters
dumpsters. serving convenience stores, fast food restaurants,
shopping centers, recycling centers, solid waste
Application collection areas and hospitals. It may useful to
target waste haulers as well, since the placement
Every business generates waste as a part of its of temporary open dumpsters for demolition,
daily operations and temporarily stores it pending remodeling and other construction purposes can
disposal by an independent contractor. Nearly be a problem in some subwatersheds.
every hotspot site has a ubiquitous dumpster
located somewhere behind the building. Several Primary Training Targets
Key education targets are the managers and

employees that use the dumpster.
Feasibility
Dumpster pollution prevention practices can be

applied in all regions and climate zones.
Figure 1: Dumpster Site with Typical Signs

of Poor Management (trash accumulation,
dumpster without lid, dumpster near storm
drain)

Table 1: Pollution Prevention Practices for Dumpsters

• Locate dumpsters on a flat concrete surface that does not slope or drain to the storm drain
system
• Install a secondary containment system such as a berm or curb around the dumpster if it is
connected to the storm drain
• Install protective covers or lids to keep rainfall from accumulating in the dumpster or secondary
containment area
• Close lids at dumpsters located at vehicle service areas, fast food restaurants, and convenience
stores
• Install an oil and grease separator or sump pit for dumpsters that receive waste with a high
moisture content
• Place clear and visible signs on dumpsters indicating what kind of waste can be accepted
• Never throw oil and grease or other liquids into a dumpster - provide alternative disposal
locations for impermissible substances
• Close and secure lids properly when the dumpster is not being loaded or unloaded
• Empty dumpsters on a frequent basis to prevent overfilling or storage outside the dumpster
• Repair leaking or damaged dumpsters immediately
• Never use bleach and soap to clean the container unless the wash water is sent to the sanitary
sewer system
• Pick up and sweep trash and litter from around the dumpster regularly
Implementation Considerations • Industrial dumpsters that produce a high

volume and variety of wastes
Dumpster pollution prevention practices can be • Dumpsters with multiple contributors, such
hard to implement. Perhaps the greatest challenge as multi-family units, and institutional
is changing the mindset of employees about facilities
proper disposal techniques. Since dumpster • Temporary dumpster locations at small
practices require additional effort, owners need to construction sites, demolition projects, and
train staff and inspect dumpsters more frequently. redevelopment projects
Lastly, dumpster practices that require liquids/oil
and grease separation or secondary containment
may be costly for many small businesses.
Target Areas for Education and Enforcement-

Education and enforcement should be targeted to
specific types of dumpsters that are known
hotspots and/or have high potential for
environmental contamination. These include:
• Foodservice dumpsters that produce waste

with high moisture content and oil and
grease that can be easily carried by storm
water runoff (Figure 2)
• Automobile service dumpsters that can
potentially produce a high volume of
wastes, such as oil and grease, cleaning Figure 2: Restaurant Waste Barrels Without
fluids, used parts, filters, and rags Secondary Containment

Routine Inspection - Dumpsters should be Resources

routinely inspected for the following problems:
California Stormwater BMP Handbook:
• Cracks or dents in the dumpster that may Industrial and Commercial
permit storm water run-on http://www.cabmphandbooks.com/
• Poorly functioning lids that cannot be
closed or secured Storm Water BMP #4. Solid Waste Containers
• Hydraulic hoses with cracks or leaks (if (Dumpsters/Compactors)
applicable) http://www.cleancharles.org/stormwater_bmp4.sh
• Presence of impermissible substances in the tml
container
• Liquid leaking from the container and/or North Central Texas Council of Governments
signs of previous leakage, which are often (NCTCOG) Building Maintenance BMP Fact
indicated by stains or deposits on ground or Sheet
storm drain inlets http://www.dfwstormwater.com/P2/PDF/p2bldg_
bmps.pdf
Working with Solid Waste Disposal Contractor -
Choosing a reliable and environmentally- San Mateo Countywide Storm Water Pollution
conscious waste disposal contractor is important Prevention Program: Storm Water Best
to prevent storm water contamination. Routine Management Practices for Supermarkets and
maintenance and emptying of the dumpster by the Grocery Stores
solid waste disposal contractor should be http://www.flowstobay.org/pdfs/bmp/Food/grocer
performed on a regular basis. If concerns about y.pdf
the condition of the dumpster or collection
process arise (e.g. dumpster put in wrong location, Harvard University Stormwater Bmp: Solid Waste
dented corners, infrequent dumping, etc.), the Container
service should be contacted immediately. http://www.uos.harvard.edu/ehs/env_sbmp4.shtml
Cost - Proper dumpster management is a California Stormwater Quality Association

relatively inexpensive storm water pollution Factsheet: Waste Handling and Disposal
prevention practice and avoids the liability for http://www.cabmphandbooks.com/Documents/Mu
spills and/or containment. Operational costs nicipal/SC-75.pdf
depend on the volume and type of waste,
frequency of maintenance (e.g., replacing City of Rancho Santa Margarita Waste Handling
damaged containers), and whether additional and Disposal
protective measures need to be installed, such as http://www.cityofrsm.org/civica/filebank/blobdloa
secondary containment systems, canopies, and d.asp?BlobID=1772
signs.
Stanford University SLAC Stormwater BMP
Operational costs are primarily related to training Factsheet: Waste Handling and Disposal
workers on proper dumpster management. http://www.slac.stanford.edu/esh/epr/Stormwater/
Frequent training is needed to maintain BMP9.html
compliance by workers, particularly in high
turnover businesses.


Hotspot Source Area: Physical Plant
H-9 BUILDING REPAIR AND REMODELING
Description Primary Training Targets
Many building repair and remodeling operations The primary targets for training in this practice
are too small to be covered under local or state are general contractors, facility operators,
erosion and sediment control permits, but they construction supervisors, construction workers,
can still generate pollution in the absence of and local erosion and sediment control
good pollution prevention practices. Excavation, inspectors.
demolition, construction and finishing
operations at a site can generate a range of Feasibility
pollutants that can be carried away by storm
water runoff, including sediment, trash, metals, Small construction sites are a challenge because
hydrocarbons and many other pollutants. Small they are temporary, mostly unregulated, and
construction sites are always somewhat messy, involve many different contractors and workers
particularly during wet weather. Table 1 that may be resistant to change. Pollution
summarizes a series of simple pollution prevention practices are required if the disturbed
prevention practices that construction area exceeds one acre under the NPDES storm
supervisors, contractors and workers can apply water permit program. (Note: Some states and
to reduce erosion at small building and municipalities have an even lower area threshold
remodeling sites. to trigger erosion and sediment control plans.)
Application
Over many decades, much of the building stock

within a subwatershed is redeveloped,
remodeled or demolished. The actual
distribution of these small construction
operations in a subwatershed is very hard to
predict and even harder to control (Figure 1).
Figure 1: Restaurant Remodeling

Table 1: Pollution Prevention Practices for Building Repair and Remodeling

• Store construction materials under cover where they are protected from rainfall and runoff
• Temporarily block off any adjacent storm water inlets with sandbags
• Lay tarps on outside of buildings to collect fallen debris and splatters
• Police the site at the end of each day to pick up litter and make sure construction materials
are properly stored
• Make sure adequate dumpster capacity is available on-site to store rubble and construction
debris and practice good dumpster management (see Profile Sheet H-8)
• Segregate hazardous materials (e.g., lights, HVAC equipment, electrical equipment,
asbestos) from construction debris and dispose of these properly
• Never clean brushes or rinse paint or drywall containers into a street, gutter, storm drain or a
stream
• Secure bags of cement after they are opened, and keep windblown cement powder away
from gutters and storm drains
• Dispose of small amounts of dry concrete, grout and mortar in the dumpster
• Remember that liquid residues of oil-based paints, thinners, solvents, glues and cleaning
fluids are considered hazardous wastes, and must be disposed of properly
• Contain, collect, and filter wash water from concrete operations. Dispose of wash water in the
sanitary system, and dispose of filtered particles in the trash
• Wash concrete mixers out in designated wash-out areas in the company yard, where wash
water can flow to containment ponds or over dirt. At construction sites, recycle washout water
by pumping it back into mixers for re-use. Recycle or properly dispose of concrete remaining
in the chute. Never dispose of washout into streets, storm drains or ditches.
• Recycle and reuse products such as paints, solvents, and building materials
• Properly dispose of hazardous waste and other material that cannot be recycled
• Train construction workers on the proper handling, storage, and disposal of construction
material
• Routinely inspect site for potential sources of storm water contamination
• Protect storm drains with barriers such as berms when runoff cannot be prevented. Label
storm drains with “No Dumping” signs to deter disposal of waste and washwater in the drain
Implementation Considerations contamination. All construction workers should

be trained on proper handling, storage and
Outdoor Storage Area Protection – Construction disposal procedures.
materials and rubble/debris are often stored
outside during building repair, remodeling or Contractor Accountability – Contractor and sub-
demolition. Since construction is temporary, contractor agreements should specifically
outdoor storage practices (H-6) are often not stipulate who will be responsible for
practical. Consequently, this practice relies on implementing and maintaining pollution
temporary housekeeping and covering prevention practices. On-site preconstruction
techniques to prevent runoff. meetings and spot inspections are often needed
to ensure that the agreements are being
Hazardous Waste Handling and Disposal – followed.
Small construction and demolition sites can
generate or accumulate a considerable volume of Cost - Building repair and remodeling practices
hazardous waste materials, including paints, are relatively inexpensive to implement
pressure-treated wood, cleaning/refinishing compared to other pollution prevention
chemicals, thermostats, lights, light switches, practices. Actual costs will vary depending on
and other products with toxic components. The the size, type, and duration of the construction
location of all hazardous material should be project. Least predictable are hazardous waste
identified prior to demolition to reduce worker disposal fees, which can vary greatly by region
health risks and prevent storm water and type of waste material. Local program costs

for training and site inspections are generally North Central Texas Council of Governments
low if they are done through existing erosion Building Maintenance BMP Fact Sheet
and sediment control or safety training http://www.dfwstormwater.com/P2/PDF/p2bldg
programs. _bmps.pdf
Resources California Stormwater Quality Association

Factsheet: Building Repair and Construction
Alameda Countywide Clean Water Program: http://www.cabmphandbooks.com/Documents/I
Building Maintenance and Remodeling ndustrial/SC-42.pdf
http://www.ci.alameda.ca.us/publicworks/pdf/bl
dgmaint.pdf Stanford University SLAC Stormwater BMP
factsheet: Building Repair, Remodeling, and
King County Storm Water Pollution Control Construction
Manual http://www.slac.stanford.edu/esh/epr/Stormwate
http://dnr.metrokc.gov/wlr/dss/spcm.htm r/BMP12.html
Santa Clara Valley Urban Runoff Pollution Pierce County, WA Construction And
Prevention Program Demolition Activities
http://www.scvurppp.org http://www.co.pierce.wa.us/pc/services/home/en
viron/water/swm/sppman/a5.htm
California Stormwater Quality Association.
Industrial and Commercial


H-10 BUILDING MAINTENANCE

www.appowerwash.co
Many routine practices used to maintain the Routine maintenance occurs at most buildings,
walls and rooftops of buildings can cause storm but is performed most frequently at high-
water pollution such as washing, power visibility retail, institutional, and industrial sites.
washing, sanding, sandblasting, painting, graffiti Since maintenance is often conducted by small
removal, and roof maintenance (Figure 1). Some contractors that use specialized mobile
building maintenance practices produce polluted equipment, the best approach is to directly
wash water that can directly enter the storm educate and train contractors rather than
drain system during dry weather, whereas others individual property owners.
deposit fine particles or liquids that can wash off
during wet weather (e.g., cleaners, paint, Primary Training Targets
solvents or sealers). In either case, maintenance
practices can cause sediment, metals, The training targets for this practice are facility
hydrocarbons, or other potentially toxic operators; maintenance crews; and washing,
pollutants to enter the storm drain system. power-washing, sandblasting, and painting
Table 1 summarizes simple pollution prevention contractors.
practices that can be used by maintenance
contractors to minimize the risk of storm water Feasibility
pollution during routine building maintenance.
Since most maintenance contractors are small
businesses, it can be hard to assemble them for
pollution prevention training.
Implementation Considerations
While these pollution prevention practices

primarily rely on simple good housekeeping,
they can be hard to implement if either the
property manager or contractor lacks awareness
about the environmental consequences of
building maintenance operations. Municipalities
and industries can help promote broader use by
Figure 1: Roof Maintenance specifying precise pollution prevention practices
when they negotiate maintenance contracts or
work orders.
Cost - Presumed to be minimal, with the

exception of storm drain covers or containment
devices.

Table 1: Pollution Prevention Practices for Building Maintenance

• Enclose painting and sanding operations, where possible or required by air quality regulations
• Lay tarps below outside work areas to collect fine particles and splatters
• Sweep up paved surfaces immediately after scraping, stripping, sanding or sandblasting
operations are completed. Do not use blowers or hoses
• Block adjacent storm drains when stripping or cleaning buildings with high-pressure water
(Figure 2), and contain and collect wash water for disposal in the sanitary sewer or other
appropriate disposal method. Filtering wash water at the storm drain inlet may be acceptable if
no soaps are used
• Direct runoff from pressure washing operations over grassy areas or to a bermed area where it
can be collected for disposal in the sanitary sewer
• Never clean paintbrushes, sprayers or containers in a manner where rinse water can reach a
curb, gutter, storm drain or stream
• When cleaning up after using water-based paints, first paint out the brushes as much as
possible, then rinse in a sink. Empty cans, brushes and rags should be disposed in the trash
• When cleaning up after using oil-based paints, paint out the brushes as much as possible, then
filter and reuse thinners and solvents. Treat excess liquids as a hazardous waste and dispose of
accordingly
• Purchase paints, sealants and finishes that have low environmental risk
• Prevent discharge of wash water to the storm drain system or ground
• Label storm drains with “No Dumping” signs to deter disposal of waste and washwater
Resources

Industrial and Commercial
http://www.cabmphandbooks.com
North Central Texas Council of Governments.

Building Maintenance Pollution Prevention
BMPs
http://www.dfwstormwater.com/P2/PDF/p2bldg
_bmps.pdf Figure 2: Storm Drain Cover Used when
Washing with Soaps
Ventura Countywide Stormwater Quality
Management Program. Clean Business Program Pierce County, WA Cleaning And Washing
Fact Sheet: Building Maintenance and Grounds Activities
Maintenance http://www.co.pierce.wa.us/pc/services/home/en
http://www.vcstormwater.org/ viron/water/swm/sppman/a1.htm#a15
Washtenaw County, MI Community Partners for City of Rancho Santa Margarita Building
Clean Streams Fact Sheet SERIES #4: Maintenance
Maintaining Buildings and Pavement http://www.cityofrsm.org/civica/filebank/blobdl
http://www.ewashtenaw.org oad.asp?BlobID=1684

H-11 PARKING LOT MAINTENANCE
Parking lots are associated with nearly every In general, power washing and steam cleaning
commercial, industrial, institutional, municipal are conducted more frequently at commercial
and transport-related operation in a and retail parking lots in high visibility
subwatershed. Each lot requires annual locations, airport runways and some industrial
maintenance, including litter pickup, sweeping, parking lots. When evaluating these operations,
pothole repair, power-washing, steam cleaning, it is helpful to interview mobile vendors about
de-greasing, re-striping, and re-surfacing. the kinds of parking lots they maintain most
Several maintenance operations have the often. Several factors help determine whether
potential to pollute storm water runoff if sensible this pollution prevention practice should be
pollution prevention practices are not employed. applied to a parking lot, including the size and
This is particularly true for power washing, usage of the lot, the pavement condition, and
which can deliver sediment, nutrients, whether it is directly connected to the storm
hydrocarbons, and other pollutants to the storm drain system.
drain system. Less is known about the storm
water impacts of parking lot re-sealing and re- Primary Training Targets
surfacing operations, but anecdotal data suggests
that they could be a significant source of Training targets include property managers;
polycyclic aromatic hydrocarbons under certain facility engineers; and sweeping, steam cleaning,
conditions. power-washing, asphalt re-surfacing, and sealing
contractors.
Table 1: Pollution Prevention Practices for Parking Lot Maintenance

• Use dry methods such as absorbents, brooms, or wire brushes to clean pavement surfaces where
possible
• Mechanically remove loose debris before washing or power washing the lot
• Pressure wash pavement only when needed, and avoid using acids, soaps, solvents and other
cleaning agents. Also, block adjacent storm drains, contain and collect wash water for disposal in
the sanitary sewer or other appropriate disposal method
• Filtering of wash water at the storm drain inlet may be acceptable if no soaps are used. Direct
runoff from pressure washing operations over a grassy area or to a bermed area where it can be
collected for disposal in the sanitary sewer system
• Cover and seal nearby storm drain inlets and manholes before applying sealant to parking lot
surfaces, and only apply sealants when no precipitation is forecast
• Conduct surface repair work during dry weather, where possible
• Post signs in parking areas to control litter and prohibit automobile maintenance or washing in the
parking lot
• Inspect and cleanout catch basins and storm water treatment practices routinely to remove
sediment and pollutants (see Manual 9)

Feasibility technologies (see Manual 9). The frequency of

parking lot sweeping should be based on usage
Parking lot maintenance practices can be applied and field observations of waste accumulation.
in all regions of the country, and sweeping and
power washing are commonly used for aesthetic Cost - Parking lot pollution prevention is
reasons in many large parking areas. Many generally a low-cost practice, focused on simple
facilities contract out their parking lot operational changes to reduce discharges to the
maintenance work to small businesses, such as storm drain system. The main cost associated
mobile washers and sweeping companies. These with this practice is employee training.
contractors should be the primary target of
training and education on parking lot pollution Resources
prevention practices.
Alameda Countywide, CA Clean Water
Changing the mindset of contractual Program: Parking Lots
maintenance employees and facility managers http://www.cleanwaterprogram.com/parking_lot
can be a challenge to implementing this practice, s_fact_sht.pdf
so some communities have included specific
language in their storm water ordinances Fort Worth, TX Mobile Commercial Cosmetic
regulating pavement cleaning to prevent Cleaning Fact Sheet for Power Washers
discharges to the storm drain. http://www.fortworthgov.org/DEM/factsheet.ht
m
Implementation Considerations
City of Carlsbad, CA Best Management
Parking lot pollution prevention focuses mainly Practices for Power Washing
on two maintenance practices: power washing http://www.ci.carlsbad.ca.us/stormwater/comsto
and sweeping. Dry cleanup of parking lots is rmpdf/mobilewashing.pdf
preferred to any wash down activity, since
washing can introduce oils and heavy metals North Central Texas Council of Governments
into the storm drain system (Figure 1). For Building Maintenance BMP Fact Sheet
small and medium-sized lots, dry cleanup can be http://www.dfwstormwater.com/P2/PDF/p2bldg
done using a broom, or a mop and a bucket of _bmps.pdf
warm water (which is disposed of in the sanitary
sewer). Larger lots can be cleaned using sweeper
Figure 1: Parking Lot Power Washing

Hotspot Source Area: Turf and Landscaping
H-12 TURF MANAGEMENT
Description educating, training and certifying workers in the

lawn care industry.
Many non-residential areas in a subwatershed
have significant areas of intensively managed Application
turf. Examples include road and utility rights-of-
way, schools, ball fields, parks, corporate office The typical distribution of turf cover in three
parks and the grounds of large institutions, each Mid-Atlantic states is shown in Table 2. As can
of which has a different turf management regime be seen, home lawns constitute 67% of the total
(Figure 1). Turf management involves mowing, turf cover. Pollution prevention practices for
fertilization, pesticide application, and residential lawns are described in profile sheets
supplemental irrigation, where needed. These N-1 through N-8. Non-residential turf comprises
services are generally performed by a lawn about a third of the total turf cover (although the
care/landscaping contractor or an in-house exact percentage will vary from subwatershed to
maintenance crew. Poor turf management subwatershed).
practices have the potential to create storm water
pollution, particularly in urban areas where soils Municipal turf accounts for about two-thirds of
are compacted. Potential pollutants generated by non-residential turf, and includes roadside rights-
poor turf management include nutrients, of-way, public open space, parks and schools.
herbicides, organic carbon and sediment. In Institutional turf, commercial turf and golf
addition, poor irrigation practices can produce courses each represent about 10% of non-
nuisance water in some subwatersheds. residential turf. With the exception of airports
and sod farms, turf cover is generally rare at most
Table 1 summarizes a series of simple pollution industrial sites.
prevention practices for turf management to
reduce this potential pollution source. Turf In terms of the intensity of turf management, golf
management practices are implemented by courses, institutions, and corporate office parks
usually receive the highest inputs of water,
fertilizer, and pesticides. Turf management on
municipal lands tends to be fairly modest, with
the exception of athletic fields at schools and
some park settings. Highway and power line
rights-of-way are seldom fertilized or irrigated,
although they are increasingly sprayed with
herbicides to limit vegetative growth in places
that cannot be safely or conveniently mowed.
Recent research has linked roadway and utility
herbicide use to the presence of atrazine and
simazine in urban streams. These herbicides were
Photo Courtesy of Harford County Department of Public Works, Water detected in streams where they were used to
Resources Engineering, 2003
control vegetation in rights-of-way, but were not
Figure 1: Extensive Turf Areas available to residential homeowners for retail sale
Commonly Found in Schoolyards (USGS, 1999).

Table 1: Pollution Prevention for Turf Management

• Evaluate whether some or all of the turf area can be managed as meadow or forest. If so, consider
watershed reforestation techniques (see Manual 7)
• Sweep any grass clippings away from paved surfaces after mowing
• Use mulching type mowers to return grass clippings to the lawn
• Never apply fertilizers or pesticides within five feet of pavement, 25 feet of a storm drain inlet, or
50 feet of a stream or water body
• Consider a low or no fertilizer approach to maintain turf
• Select a reputable lawn care or landscape service that uses organic fertilizers and natural pest
management techniques
• Perform a soil test to determine actual fertilization need and set application rates
• Calibrate fertilizer spreaders to avoid excessive application. Do not apply fertilizer just prior to
predicted rainfall events or on wet turf
• Do not prepare herbicides or pesticides for application near storm drains
• Minimize off-target application of fertilizers, and leave a no-application zone for fertilizer and
pesticides around streams and lakes
• Work fertilizers into the soil rather than just applying onto the surface
• Reduce water needs during the hot summer months by adjusting grass to an increased height
• Consider turf alternatives, such as native or low-water, cool-season turf grasses
• Select grass species that will best meet the requirements and purposes of the lawn area
• Use synthetic turf for small, lightly used and inaccessible areas that require no watering,
chemicals, or mowing
Primary Training Targets Feasibility
The training targets for this practice include Turf grass management practices vary
property managers; landscaping contractors; golf regionally, in response to different growing
course managers; and road, park, and utility seasons, rainfall amounts and soil types. As
maintenance crews and supervisors. Swann (1999) notes, arid and semi-arid areas
rely heavily on supplemental irrigation, whereas
the practice is less common in humid regions.
Table 2: Distribution of Turf Cover by Herbicide use tends to be greater in northern
Sector in Three Mid-Atlantic States regions, while outdoor insecticide use is greatest
% of Total Turf in southern regions. To reduce the quantity of
Sector
Cover products used to manage turf, consult the local
Home Lawns 67 cooperative extension service for advice on the
Roadside Rights-of-Way 10 most appropriate grass species depending on its
Municipal Open Space 7 intended use.
Parks 3.5
A second key feasibility factor is the nature of
Schools 3 the local lawn care industry. In many regions, it
Commercial/Corporate 3 tends to be a low-wage, seasonal industry that
Institutions 3 employs young workers. These workers often
Golf Courses 2.5 have limited education, may not speak English,
Airports/Sod Farms 1 and have high turnover rates. As a result,
Source: Schueler, 2003 education programs targeted toward the industry
need to be simple, multi-lingual, and frequently
repeated.

Implementation Considerations • Registration and permit requirements for

professional landscaping and lawn care
In general, healthy and attractive turf is service companies
produced by good pollution prevention • Recommended management practices and
practices. A number of factors influence turf guidelines for reducing maintained turf area
health, which can be stressed by mowing
activity. Mowing grass too short causes turf to Cost - Costs consist largely of program efforts
become less tolerant of environmental stresses, for training and education, with only small
more disease-prone and more reliant on operational costs to implement turf management
pesticides, fertilizers and irrigation. Mowing practices. It is often reasonable to assume that
only a third of the grass blade height during operational savings from reduced fertilizer and
cooler times of the day can minimize turf stress. herbicide inputs will offset any increased costs
Areas where soil is compacted may require for more intensive practices, such as manual
aeration or soil amendments in order to increase weed removal. Replacement of turf areas should
permeability. also reduce mowing costs. A study in North
Marin County, CA compared traditionally
Equipment modifications may also be necessary landscaped projects to projects that met specific
to reduce environmental impacts. Fertilizer design criteria for water conservation. The study
application equipment should be calibrated found that when costs for water, labor, fertilizer,
frequently (see the Resources section for more fuel, and herbicide were considered, annual
tips). Granular spreaders need to be calibrated savings of $75 per dwelling unit were realized
for each product, since each fertilizer requires a for the water-conserving projects (Iwata, 1994).
different spreader setting to provide the desired Water-conserving landscapes averaged 55% less
rate of fertilizer. Liquid fertilizers should be turf area; used 54% less water; and saved 25% in
applied using coarse droplet nozzles with a labor costs, 61% in fertilizer, 44% in fuel, and
close/tight spray pattern at the lowest pumping 22% in herbicides, with a overall total of 10%
pressure to avoid drift onto non-turf areas. less landscaped area.
Professional training is extremely important to Resources

successfully implement turf management
practices. Lawn care company employees can be California Stormwater BMP Handbook:
trained on the proper calibration, use, and Industrial and Commercial.
application techniques for the equipment they http://www.cabmphandbooks.com/
will use. Local governments have found that
certification classes and promotional tie-ins can Xeriscape: Winning the Turf War Over Water
promote changes in the practice of professional http://hem.dis.anl.gov/eehem/94/940711.html
landscape and lawn care companies. Examples
include training, certification, and recognition University of Florida Cooperative Extension
programs for environmentally sensitive golf How to Calibrate a Fertilizer Spreader
course management (See Profile Sheet H-15 for http://turf.ufl.edu/residential/fertspreader.htm
resources designed specifically for golf course
managers). Turf and Landscape Irrigation Best
Management Practices. Prepared by the Water
Educating lawn care professionals on turf Management Committee of The Irrigation
pollution prevention practices is an excellent Association
way to improve local water quality. Messages to http://www.irrigation.org/gov/default.aspx?r=1
highlight in any education program include: &pg=bmps.htm
• Local information on proper timing and

application rates for fertilizers and
pesticides

Health Dangers of Urban Use of Pesticides Stormwater Management Manual for Western
Working Group. Sustainable Municipal Turf Washington: Volume IV -- Source Control
Management. Region of Ottawa-Carleton, BMPs. WA Dept. of Ecology, Olympia, WA.
Ontario Canada http://www.ecy.wa.gov/biblio/9914.html
http://www.sankey.ws/ipm.html
Landscaping for Stormwater Management
US EPA. Integrated Pest Management (IPM) in http://www.dep.state.fl.us/law/Documents/Grant
Schools s/CMP/pdf/stormwatermems.pdf
http://www.epa.gov/pesticides/ipm/
St. Johns River Water Management District
Model Urban Runoff Program: A How-To Guide Florida Landscaping to Promote Water
for Developing Urban Runoff Programs for Conservation Using the Principles of Xeriscape
Small Municipalities. http://sjr.state.fl.us/programs/outreach/conservati
http://www.swrcb.ca.gov/stormwtr/murp.html on/landscape/toc.html

Hotspot Source Area: Turf and Landscaping
H-13 LANDSCAPING/GROUNDS CARE
Description A series of simple pollution prevention

practices, profiled in Table 1, can greatly reduce
Landscaping is a common feature in the potential for storm water pollution during
commercial, industrial and municipal settings, routine landscape maintenance operations. Most
and typically involves maintaining beds of trees, landscaping maintenance is performed by
shrubs, ground covers and/or flowers that are contractors or in-house maintenance crews.
intended to meet unique landscaping objectives Improved practices are generally adopted by
for a site (Figure 1). Once installed, landscaping educating, training, and certifying workers and
beds are maintained seasonally to renovate, supervisors within the landscaping and lawn
mulch, weed, and prune; pick up leaves and care industry.
trash; inspect and repair irrigation systems; and
apply fertilizers and pesticides, as needed. A Application
well-designed and maintained landscaping bed
absorbs rainfall, produces little runoff and Landscaping is a significant component of
discharges few pollutants. In some cases, commercial land use, particularly in
landscaping can serve as an attractive on-site communities that have ordinances requiring
storm water retrofit. landscaping on as much as 5-10% of commercial
sites. Institutional lands such as colleges, private
However, landscaping can be a source of storm schools, and churches may also have a high
water pollutants at many sites, particularly if it percentage of landscaping. The best pollution
drains to adjacent impervious areas. Poor prevention opportunities will be found at larger
landscaping practices can generate organic commercial and institutional sites in most
wastes; excess irrigation water, nutrients, and subwatersheds.
pesticides; organic carbon; and sediment loads
to the storm drain system. Primary Training Targets
Property managers, lawn care and landscaping

contractors, and municipal landscaping crews
are the major training targets for this practice.
These groups can be targeted for business
recognition, certification or training programs.
Since they are often responsible for turf
management (H-12), outreach efforts should be
integrated.
Figure 1: Landscaped Area at a Commercial

Development

Table 1: Pollution Prevention for Landscaping and Grounds Care

Landscape Management
• Collect landscape waste and dispose at a local municipal yard waste recycling/composting facility
• Cover exposed beds and soils with mulch to minimize erosion and runoff
• Use manual and/or mechanical methods to remove weeds rather than herbicides
• Select a reputable landscaping company that uses native plants, organic fertilizers and natural pest
management techniques
• Never apply fertilizers or pesticides within five feet of pavement, 25 feet of a storm drain inlet or 50
feet of a stream or water body
• Do not use leaf blowers to blow waste into streets, storm drains, or ditches
• Sweep up any organic matter from paved surfaces after landscaping operations
• Evaluate whether storm water can be directed into the landscaping bed to obtain further treatment.
If installing a new landscaping bed, consider designing as a bioretention area or rain garden (see
Manual 3)
Pesticides
• Develop and implement an integrated pest management plan that uses pesticides only as a last
resort
• Apply pesticides when rain is not expected and when wind speeds are low
• Use the minimum amount needed for the job, employ techniques to curtail spray drift of pesticides
and never mix or prepare pesticides within 25 feet of storm drains
• Consider a low or no pesticide approach to maintain landscaping areas
Irrigation
• Employ shutoff devices to prevent irrigation after precipitation or if a pressure drop occurs due to
broken sprinkler heads or lines
• Design irrigation systems specific to each landscaped area’s water requirements and make
irrigation plans consistent with local water conservation resolutions
• Select native plant species whenever possible and group together plants with similar water
requirements in order to reduce excess irrigation
Feasibility Implementation Considerations
Landscaping practices vary regionally, in Landscape Management - Landscape

response to different growing seasons, winter management starts with the right soil conditions
temperatures, rainfall depths and soil types. for planting. An adequate topsoil layer contains
This, in turn, influences the type and availability at least 8 - 10% organic matter to provide a
of native plant species that can be used. The growing medium. Soil amendments may be
local cooperative extension service should be needed to reduce soil compaction and improve
consulted on effective local practices for your permeability. Plant material that is adapted to
region. the local climate and soil type should be
selected, and native plants should be the first
A second key feasibility factor is the nature of choice.
the local landscaping industry, which tends to
employ younger, low-wage, seasonal workers. Integrated Pest Management (IPM) - This
Landscaping workers often have limited approach uses environmentally-friendly
education, may not speak English and change measures to control pests at an acceptable level.
jobs frequently. As a result, education programs IPM plans follow five basic steps to identify pest
targeted toward landscaping contractors need to controls with minimal environmental impacts
be simple, multilingual, and repeated every year. that maintain healthy landscaping.

The basic steps are to: per day per 1,200 ft2 of landscaped area (Meeks,
2002).
1. Identify problem pests and their life cycles.
Any pest control used should be conducted Delivery Mechanism(s) to Make
at the life stage when the pest is most Projects Happen
vulnerable
2. Establish tolerance thresholds for pests A wide range of educational materials is
3. Monitor pest problems and modify current available to promote better pollution prevention
landscaping practices to discourage pests practices in the landscaping industry. Materials
4. Use non-chemical (cultural, physical, can include brochures, posters, training courses,
mechanical, or biological) controls first; if and online homestudy courses. In addition,
pests exceed the tolerance thresholds, select several communities have designed programs to
the least toxic chemical pesticides available train and certify landscape maintenance
5. Evaluate and record the effectiveness of pest contractors. In order to be certified, landscape
controls and modify as needed to prevent contractors typically attend training classes on
recurrence efficient landscaping practices, including non-
point source pollution reduction, water
Irrigation – Over-watering can produce runoff efficiency, integrated pest management, and
that contains a variety of pollutants. An green waste reduction. Commercial contractors
efficiently watered landscape avoids unwanted use the certification as a marketing tool to attract
runoff, conserves water and saves money. The customers that want an environmental approach
amount of irrigation needed depends on the to landscape maintenance.
rooting depth of the plant species, the available
water-holding capacity of the soil, and the Cost – The costs to implement landscaping
efficiency of the irrigation system. One method pollution prevention practices primarily involve
to reduce over-watering is to conduct a water training and education. Operational costs for
audit to monitor water usage in landscaping, and changing current landscaping practices are
design the most efficient use of irrigation water. generally quite low.
A water audit evaluates three types of site data:
Resources
• Water-use history
• Information on the landscaped area (size, California Stormwater BMP Handbook:
plant species, etc.) Industrial and Commercial
• Evapotranspiration data from a local http://www.cabmphandbooks.com/
weather station to get a reasonable estimate
of the amount of water a site should be using Turf and Landscape Irrigation Best
Management Practices. Prepared by the Water
Next, the existing irrigation system is inspected Management Committee of The Irrigation
to check valve performance, pressure, flow rates, Association
and coverage patterns. This information helps http://www.irrigation.org/gov/default.aspx?r=1
design a more efficient irrigation system and &pg=bmps.htm
watering schedule for the landscaping area.
Integrated Pest Management (IPM) in Schools
Automated irrigation technology can also http://www.epa.gov/pesticides/ipm/
improve irrigation efficiency and conserve
water. For example, automated irrigation Florida Yards and Neighborhoods Program
controllers are available, which communicate http://hort.ifas.ufl.edu/fyn
directly with weather stations to get local
weather data to optimize irrigation scheduling. A
study in California found that using an
automated controller saved 37 gallons of water

Washington State Department of Ecology Water

Quality Program. Stormwater Management
Manual for Western Washington: Volume IV --
Source Control BMPs. WA Dept. of Ecology
Model Urban Runoff Program: A How-To Guide

for Developing Urban Runoff Programs for
Small Municipalities
http://www.swrcb.ca.gov/stormwtr/murp.html

Hotspot Source Area: Miscellaneous Sources
H-14 SWIMMING POOL DISCHARGES

Description department databases. If pool density appears to
be high in the subwatershed, then it may be
Routine swimming pool maintenance can cause worth checking out local plumbing codes and
chlorinated water or filter backflush water to be practices that relate to public and private
discharged to the storm drain or stream, which swimming pool discharges.
can be toxic to aquatic life. Municipal and
commercially-owned pools can be a major Primary Training Target
source of chlorinated water, as they hold as
much as 100,000 gallons of water with an initial The primary training targets are pool managers
chlorine concentration of two to four parts per that operate municipal and commercially-owned
million (Figure 1). When exposed to sunlight, pools and local pool inspectors.
chlorine levels break down over several days.
Consequently, holding water in the pool for
several days prior to proper discharge is the core
of this pollution prevention practice. Most states
and localities require that larger pools discharge
to the sanitary sewer system, and have
appropriate pre-treatment and NPDES permits.
Table 1 describes other pollution prevention
practices for swimming pool discharges.
Application
Figure 1: Large Municipal Pool
The density of swimming pools can be
ascertained by inspecting low-altitude aerial
photographs or consulting local health
Table 1: Pollution Prevention Practices for Swimming Pool Discharges

The best option for discharging chlorinated water drained from pools is the sanitary sewer (i.e., sewage
treatment plant). If discharge to a sanitary sewer is not possible, chlorinated water from pools and hot
tubs may be discharged over lawns or pervious areas when the following provisions are met:
• Shut off the chlorination system or stop adding chlorine one week before disposing of pool water
• Make sure the pH of pool discharge is between 6.5 and 8.5
• Chlorine levels should not exceed 0.01 ppm for pool water discharges
• Discharge or spread pool water where it will not flow into a stream, storm sewer, or someone
else’s property
• Pool discharges should be handled in a manner that will prevent nuisance conditions (e.g., odors
and mosquito-breeding conditions). Avoid ponding water for prolonged periods
Extra care must be taken when disposing of water resulting from backflushing of pool filters. It should
be discharged to the sanitary sewer, septic tank system, or a seepage pit.

Feasibility Resources
This practice applies to all pool owners and 2003 California Stormwater BMP Handbook:
operators. Outdoor pool density tends to be Municipal
greater in warmer regions, although the http://www.cabmphandbooks.com
discharge problem may be more severe in cooler
climates where swimming pools are drained at Water Quality Permit Program: Guidance for
the end of the season to prevent damage from Swimming Pool and Hot Tub Discharges
freezing. While this pollution prevention http://www.deq.state.or.us/wq/wqpermit/swimpo
practice is easily implemented at municipally- ols.pdf
owned pools, proper discharge of chlorinated
pool water may be harder to control at privately- National Menu of Best Management Practices
owned pools. for Storm Water Phase II: Alternative Discharge
Options for Chlorinated Water
Implementation Considerations http://cfpub2.epa.gov/npdes/stormwater/menuof
bmps/menu.cfm
This pollution prevention practice is
implemented through a combination of Stormwater Management Manual for Western
education, enforcement, and inspection. Washington: Volume IV -- Source Control
Education can be achieved through pamphlets BMPs. WA Dept. of Ecology, Olympia, WA.
and posters targeted to pool managers that http://www.ecy.wa.gov/biblio/9914.html
operate municipal, neighborhood and
commercially-owned pools. End-of-season
inspections are also helpful, and may be done in
conjunction with routine safety and health
inspections required by local authorities. The
educational message to pool owners and
commercial pool cleaners should clearly
emphasize the impact of chlorinated pool water
on aquatic life.
Cost – Swimming pool discharge pollution

prevention practices are generally low cost and
primarily involve staff time for inspections and
education of pool managers and employees.

Hotspot Source Area: Miscellaneous Sources
H-15 UNIQUE HOTSPOT OPERATIONS
Certain unique hotspot operations require Resources

customized pollution prevention practices.
Examples of unique hotspot operations include How to Inspect Construction Sites for
construction sites, marinas, hobby farms, golf Compliance With NPDES Permit
courses, fairgrounds, racetracks, and restaurants. www.epa.gov/region6/water/npdes/sw/ms4/c3/c
Each type of hotspot has its own mix of oninsp.ppt
pollution prevention practices, which are
described in the Resources sections of this sheet. Best Management Practices Manual For
Construction Sites In Honolulu
http://www.cleanwaterhonolulu.com/reports/BM
CONSTRUCTION P_manual.pdf
City of Dana Point Stormwater Best

Management Practices (BMPs) For General
Construction and Site Supervision
http://www.danapoint.org/water/WC-
CONSTRUCTION.pdf
EPA NPDES Storm Water Pollution Prevention

Plans for Construction Activities
http://cfpub1.epa.gov/npdes/stormwater/swppp.c
fm
EPA NPDES Construction Site Storm Water

Runoff Controls
Construction sites have long been recognized as http://cfpub1.epa.gov/npdes/stormwater/menuof
pollution hotspots, and pollution prevention and bmps/con_site.cfm
erosion control practices are required for sites
that disturb more than one acre. While erosion California Dept. of Transportation Construction
and sedimentation are the greatest concerns at Site Best Management Practices (BMPs)
construction sites, practices used to store and Manual
handle construction materials and maintain http://www.dot.ca.gov/hq/construc/stormwater/C
heavy equipment can be a source of many SBMPM_303_Final.pdf
pollutants including nutrients, soil additives,
pesticides, trash, heavy metals, and oil and
grease. The magnitude of storm water pollutants
depends on the size of the construction site and
climatic conditions.

MARINAS HOBBY FARMS
The proximity of marinas to surface waters Small farms and boarding facilities are
makes them a noteworthy hotspot. Many considered hotspots since livestock can generate
maintenance activities at marinas require pollutants such as bacteria, nutrients, and
pollution prevention practices because they are sediment. Many hobby farms are typically
conducted directly over waterbodies. Marinas located with direct access to streams to provide a
can generate nutrients, bacteria, lead, arsenic, watering source. Proper handling of animal
zinc, copper and tin, sediment, and wastes and maintenance of sediment controls are
hydrocarbons. Key marina maintenance important pollution prevention practices at
operations that can produce pollutants include hobby farms, which are often too small to be
the following: regulated by local or state authorities.
• Boat and ship painting, cleaning, and Resources
repair
• Boat fueling, maintenance Horse Keeping Manual and Fact Sheets on
• Fish handling Environmentally-sound Horse Keeping
• Discharge of bilge water Practices
• Discharge of marine sanitation devices http://www.baysavers.org/
Stormwater Best Management Practices
Resources (BMPs), Horse Owners & Equine Industry
Stormwater Runoff Best Management Practices http://www.ci.la.ca.us/SAN/wpd/downloads/pdf
For Marinas: A Guide for Operators s/horse.pdf
http://www.seagrant.sunysb.edu/pages/BMPsFor
Safe Environmental Habits and Procedures for:
Marinas.htm
Boarding Stables, Equestrian Centers, Small
Best Management Practices for Marinas and Farms, and Urban Horse Owners
Boatyards http://www.lacity.org/SAN/wpd/pages/horsebm
http://www.state.me.us/dep/blwq/docwatershed/ p.htm
marina/bmp.htm
Horse Keeping: A Guide To Land Management
National Management Measures to Control for Clean Water
Nonpoint Source Pollution from Marinas and http://mcstoppp.org/horses.htm
Recreational Boating
http://www.epa.gov/owow/nps/mmsp/index.html Guidelines & Best Management Practices for
Horsekeeping
Maryland Clean Marina Guidebook http://www.nhhorsecouncil.com/bestpractice.htm
http://www.dnr.state.md.us/boating/cleanmarina/
cmprogram.html

GOLF COURSES FAIRGROUNDS AND HORSE TRACKS
Golf courses can potentially generate pollutants Fairgrounds and horse tracks can become
during routine maintenance activities, such as hotspot operations when large numbers of
irrigation, mowing, fertilization, and pesticide animals are boarded and manure is not properly
application. From a pollution prevention handled. Animal operations can generate
standpoint, the greatest concern about golf pollutants, such as bacteria, nutrients, and
courses is large inputs of fertilizer, pesticides, sediment. Proper pollution prevention practices
and fungicides used to maintain trees and emphasize manure handling and containment, as
greens. Chemical application rates at golf well as continuous erosion control.
courses can rival and even exceed those used in
intensive agriculture. The actual rate of fertilizer Resources
and pesticide inputs at a particular golf course
often varies considerably, depending on the soil, Horse Keeping Manual and Fact Sheets on
climate, and management program. The golf Environmentally-sound Horse Keeping
course industry has developed a series of Practices
pollution prevention practices to sharply reduce http://www.baysavers.org/projects/equine/factsh
their pollution potential. eets.html
Resources Stormwater Best Management Practices
Florida Department of Environmental (BMPs), Horse Owners & Equine Industry
Protection Best Management Practice for Golf http://www.ci.la.ca.us/SAN/wpd/downloads/pdf
Course Maintenance Departments s/horse.pdf
http://www.dep.state.fl.us/water/nonpoint/docs/n
onpoint/golfbmp.pdf Safe Environmental Habits and Procedures for:
Boarding Stables, Equestrian Centers, Small
Golf Course Construction and Operation in New Farms, and Urban Horse Owners
Jersey http://www.cityofreno.com/pub_works/stormwat
http://www.state.nj.us/dep/watershedmgt/draft_g er/bmp/horse/
olf_bmp_manual.htm
Green Industries of Colorado Fact Sheet on Horse Keeping: A Guide To Land Management
Park, Golf Course and Other Large Landscape for Clean Water
Design and Management http://mcstoppp.org/horses.htm
http://www.greenco.org/downloadables/Parks%
20and%20Large%20Landscapes.pdf Guidelines & Best Management Practices for
Horsekeeping
US EPA Golf and the Environment Bibliography http://www.nhhorsecouncil.com/bestpractice.htm
http://www.epa.gov/owow/wetlands/initiative/go
lfbib.html

RESTAURANTS
Resources
Bay Area Pollution Prevention Group: “Avoid

Fines and Health Risks from Grease Overflows”
http://www.casaweb.org/committee/tritac/grease
/bappgfs.pdf
Michigan Department of Environmental

Protection: “Restaurant Industry Pollution
Prevention and Waste Reduction”
http://www.michigan.gov/deq
Restaurants produce grease and other wastes as a City of Longmont Colorado Pollution
byproduct of normal food preparation. If grease Prevention Tips for the Food Service Industry
is dumped or washed into sewers or storm http://www.ci.longmont.co.us/water_waste/ipp/f
drains, it can cause sanitary sewer overflows or ood_industry.htm
storm water runoff pollution. Nationally, pipe
blockages cause 43% of sewer overflows and City of Los Angeles (CA): “BMP Poster for the
grease is a major factor in most blockages (U.S. Food and Restaurant Industry
EPA, 1996). Restaurants can implement simple http://www.lastormwater.org/
and low-cost pollution prevention practices to
prevent grease discharges. Also restaurants can
train workers to properly dispose of used wastes
and maintain dumpsters.

References
References
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Stormwater Tracking Study. City of Association (BASMAA). 1997. Start At
Eugene, Oregon. Unpublished the Source: Residential Site Planning
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Stormwater Quality Protection. San
American Forests. 2001. Urban Ecosystem Francisco, CA.
Analysis for the Washington D.C. Metro
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Conditions and A Resource for Local Report: Spring Regional Advertising
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American Forests. 1999. Regional Ecosystem
Analysis: Chesapeake Bay Region and Brown, E., D. Caraco, and R. Pitt. 2004. Illicit
the Baltimore Washington Corridor: Discharge Detection and Elimination: A
Calculating the Value of Nature. Guidance Manual for Program
Washington, D.C. Development and Technical Assessment.
Center for Watershed Protection.
American Water Works Association Research Ellicott City, MD.
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Residential End Uses of Water. Denver, California Storm Water Quality Task Force
CO. (CSWQTF). 1997. Best Management
Practices Guide: Retail Gasoline
Assing, J. 1994. Survey of Public Attitudes -- Outlets. Prepared by Retail Gasoline
February and July, 1994. Russian Hill Outlet Work Group. Sacramento, CA.
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Bannerman, R., D. Owens and N. Hornewer. Forestry. Center for Watershed
1993. “Sources of Pollutants in Protection, Ellicott City, MD
Wisconsin Stormwater.” Water Science
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Barth, C. 1995a. “Toward a Low Input Lawn.” Aquatic Systems. Ellicott City, MD.
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Barth, C. 1995b. “Nutrient Movement from the Ellicott City, MD.
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Urban Subwatershed Restoration Manual 8 R-1

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Chesapeake Bay Program (CBP). 2002. A Hardwick, N. 1997. Lake Sammamish

Survey of Chesapeake Bay Watershed Watershed Water Quality Survey. King
Residents: Knowledge, Attitudes and County Water and Land Resources
Behaviors Towards Chesapeake Bay Division, Seattle, WA.
Watershed Water Quality Issues.
available online: Heraty, M. 1993. Riparian Buffer Programs: A
http://www.chesapeakebay.net Guide to Developing and Implementing
A Riparian Buffer Program As An
Chollak, T. and R. Rosenfeld. 1998. Guide for Urban Best Management Practice.
Landscaping With Compost Amended Metropolitan Washington Council of
Soils. City of Redmond (WA) Dept of Governments. Washington, DC.
Public Works.
Home and Garden Information Center (HGIC).
Cooke, S. 1991. Wetland Buffers: A Field 1998. Residential Fertilizer Use Survey.
Evaluation of Buffer Effectiveness in University of Maryland Cooperative
Puget Sound. Washington Department Extension. College Park, MD.
of Ecology. Unpublished surveys.
http://www.agnr.umd.edu/MCE/
Council of State Governments. 1998. Getting in
Step: A Guide to Effective Outreach in Houston Galveston Area Council (HGAC).
Your Community. Lexington, KY. 2004. Household Hazardous Waste.
Available online: http://www.h-gac.com
De Young, R. 1997. Healthy Lawn and Garden
Survey: Data Analysis Report. Rouge Independent Petroleum Association of America
River National Wet Weather (IPAA). 2001. Spill Prevention, Control,
Demonstration Project. Oakland County, and Countermeasure (SPCC) Plan
MI. Comments.
http://www.ipaa.org/govtrelations/comm
Duke, D. and K. Shaver. 1999. “Widespread ents/SPCC_Comments.asp
Failure to Comply With U.S.
Stormwater Regulations for Industry: Israel, G., S. Pinheiro and G. Knox. 1995.
Parts I and II” in Environmental Environmental Landscape Management
Engineering Science. 16(4) -- Assessing Practices Among
Commercial Groups. University of
Environment Canada. 2001. Priority Substance Florida. Cooperative Extension Service.
List Assessment Report: Road Salt. Bulletin 307. Monticello, FL.
Ministry of the Environment. Toronto,
Canada. Iwata, L. 1994. Xeriscape: Winning the Turf
War Over Water. Home Energy
Ferguson, T., R. Gigac, M. Stoffan, A. Ibrahim, Magazine. July/August.
and H. Aldrich. 1997. Rouge River
National Wet Weather Demonstration Jenkins, V. 1994. The Lawn: The History of An
Project. Wayne County, MI. American Obsession. Smithsonian
Institute Press.
Garn, H. 2002. Effects of Lawn Fertilizer On
Nutrient Concentrations in Runoff from
Lakeshore Lawns, Lauderdale Lakes,
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Knox, G., A. Fugate and G. Israel. 1995. National Environmental Education Training
Environmental Landscape Management Foundation (NEETF). 2003. Weather
-- Use of Practices By Florida Reporting and Public Awareness of
Consumers. University of Florida Smart Growth Issues: Designing Smart
Cooperative Extension Service. Bulletin Growth Training for Weathercasters.
307. Monticello, FL. Washington, D.C.
Law, N.,L, Band and J. Grove. 2004. “Nitrogen National Oceanic and Atmospheric
Input from Residential Lawn Care Administration (NOAA). 1988. Dealing
Practices in Suburban Watersheds in With Annex V – A Guide for Ports. U.S.
Baltimore,County, MD.” Journal of Department of Commerce, NOAA,
Environmental Management and National Marine Fisheries Service,
Planning. in press Seattle, WA. NOAA Technical
Memorandum NMFS F/NWR-23. as
Legg, A., R. Bannerman and J. Panuska. 1996. cited in Guidance Specifying
Variation in the Relation of Rainfall to Management Measures for Sources of
Runoff from Residential Lawns in Nonpoint Pollution in Coastal Waters.
Madison, Wisconsin. U.S. Geological EPA 840-B-92-002.
Survey Water Resources Investigation
Report 96-4194. Ohrel, R. 1995. “Dealing with Septic System
Impacts.” Watershed Protection
MacPherson, C. and B. Tonning. 2003. Getting Techniques. 2(1): 265-272. Center for
in Step: A Guide to Conducting Watershed Protection. Ellicott City,
Watershed Outreach Campaigns. MD.
Prepared for the US EPA Office of
Wetland, Oceans and Watersheds. EPA Outdoor Power Equipment Institute (OPEI).
841-B-03-002. 2003. Profile of the Outdoor Power
Equipment Industry: 2002.
McDonald, F. 1999. Ecologically Sound Lawn www.opei.org. Alexandria, VA.
Care for the Pacific Northwest:
Findings from the Scientific Literature Pellegrin Research Group. (PRG). 1998.
and Recommendations from Turf Stormwater/Urban Runoff Public
Professionals. City of Seattle Public Education Program: Interim
Works. Evaluation, Resident Population. Los
Angeles County Department of Public
Meeks, P. 2002. “Finding Solutions to Works.
Landscape Irrigation Runoff.” in
Stormwater. 3:6. Pool and Spa Marketing. 2003. “Market Report:
United States Swimming Pool Market”
Morris, W. and D. Traxler. 1996. Dakota County in 2003 Reference and Directory.
Subwatersheds: Residential Survey On http://www.poolspamarketing.com/
Lawn Care and Water Quality. Dakota
County, Minnesota, Decision Resources, Pronold, M. 2000. “Administering the NPDES
Ltd. Industrial Storm Water Program.” in
Proceedings: National Conference on
Tools for Urban Water Resource
Management and Protection. U.S. EPA
Office of Research and Development.
EPA/625-R-00-001

References
Robinson, C., Proprietor, “Latimat” portable State of California Regional Water Quality
wastewater containment system. Control Board (SWRCB). 1999. Order
Personal Communication June 2, 2003. No. 99-038 Setting Administrative Civil
http://www.latimat.com Liability.
www.swrcb.ca.gov/rwqcb2/OrderNum/9
Schueler, T. 2003. “The Grass Crop of the 9-038.doc
Chesapeake Bay Watershed.”
Envirocast. May 2003. National Steiner, R., E. Hagen and J. Ducnuigeen. 2000.
Environmental Education and Training Water Supply Demands and Resources
Foundation. of the Potomac River Basin. Interstate
Commission of the Potomac River
Schueler, T. 2000a. “The Compaction of Urban Basin. Rockville, MD.
Soils.” Watershed Protection
Techniques. 3(2): 661-665. Center for Steuer, J., W. Selbig, N. Hornewer and J. Prey.
Watershed Protection. Ellicott City, 1997. Sources of Contamination in An
MD. Urban Basin in Marquette, MI and An
Analysis of Concentrations, Loads and
Schueler, T. 2000b. “Understanding Watershed Data Quality. U.S. Geological Survey
Behavior.” Watershed Protection Water Resources Investigation Report
Techniques. 3(3): 671-679. Center for 97-4242.
Watershed Protection
Swammikanu, X. 1994. “Pollution Prevention
Schueler, T. 1999. “Microbes in Urban for Auto Recyclers.” Ph. D. Diss.
Watersheds.” Watershed Protection University of California, Los Angeles in
Techniques. 3(1): 551-600. Center for the Practice of Watershed Protection. T.
Watershed Protection. Ellicott City, Schueler and H. Holland, eds. Center for
MD. Watershed Protection. Ellicott City,
MD.
Schueler, T. 1995. “Urban Pesticides: From the
Lawn to the Stream.” Watershed Swann, C. 2001. “The Influence of Septic
Protection Techniques. 2(1):247-253. Systems At the Subwatershed Level.” in
Center for Watershed Protection. Watershed Protection Techniques. 3(4):
Ellicott City, MD. 821-834. Center for Watershed
Protection. Ellicott City, MD.
Scott, K.I., J.R. Simpson, E.G. McPherson.
1999. “Effects of Tree Cover On Swann, C. 2000. “Understanding Watershed
Parking Lot Microclimate and Vehicle Behavior.” Watershed Protection
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25(3): 129-141. Watershed Protection. Ellicott City,
MD.
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Pollutant Loads in Maryland.” in Swann, C. 1999. A Survey of Residential
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Estimated Water Use in the United
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References
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of Everyday Life.” in The American Streams During Rainstorms and
Lawn, G. Teyssot (ed.). Princeton Relations to Retail Sales of Pesticides in
Architectural Press, NY. King County, Washington. United States
Geological Survey FS-007-98
United States Census. 2001. Profile of National
Housing Conditions. 2000 Census Data. University of Missouri. 1994. Storm Drains and
Washington, D.C. Water Quality. Waste Management
Article WM6011. Available online:
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(U.S. EPA). 2003. FedSite, Virtual asteman/wm6011.htm.
Facility Regulatory Tour, Vehicle
Maintenance Facility Tour. Vehicle Waschbusch, R., W. Selbig and R, Bannerman.
Washing - P2 Opportunities. Available 2000. “Sources of Phosphorus in
online: Stormwater and Street Dirt from Two
http://permanent.access.gpo.gov/website Residential Basins in Madison,
s/epagov/www.epa.gov/fedsite/virtual.ht Wisconsin” in National Conference on
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Water, Oceans, and Wetlands. EPA Water Environment Research Federation. 2000.
625/R-00/008. Tools to measure Source Control
Program Effectiveness. Alexandria, VA.
U.S. EPA. 1999. Storm Water Management Fact
Sheet: “Coverings.” Office of Winer, R. 2003. Maryland Chesapeake and
Wastewater Management. Washington, Atlantic Coastal Bays Critical Area 10%
D.C. EPA 832-R-99-009. Rule Guidance Manual. Prepared for
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U.S. EPA. 1996. Overview of the Storm Water Prepared by Center for Watershed
Program. EPA833-R-96-008. Office of Protection. Ellicott City, MD.
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References

Appendix A: Storm Water Hotspots and Potential Discharge Generators
Appendix A: Storm Water Hotspots and

Potential Discharge Generators
Urban Subwatershed Restoration Manual 8 A-1

A-2 Urban Subwatershed Restoration Manual 8

Overview Inventory [TRI] facilities) that may affect air,

water, and land anywhere in the United States.
Identifying land uses that may impact water The website also provides access to
quality in local streams can be a difficult and Enviromapper, which will display the location of
time-consuming task. Research suggests that regulated facilities.
program managers might wish to preferentially
investigate certain land uses when looking for Several commercial databases can provide
the sources of possible pollutant loads. These information on regulated industries based on
land uses are all considered to be hotspot sites manufacturing or industrial Standard Industrial
where routine operations can produce higher Classification (SIC) codes. These databases are
levels of storm water pollutants, and/or present a not free, and have limitations since they are
higher potential risk for spills, leaks or illicit designed primarily for marketing.
discharges. The two basic types of hotspots are
regulated hotspots that are known sources of Phase 2. Consult State and Local
pollution and are subject to federal or state Agencies
regulations, and unregulated hotspots, which are
operations suspected to be potential pollution Most states have NPDES permit programs, and
sources and are not currently regulated. track permit application to some extent. You can
consult state or local regulatory agencies to
Identifying Potential Generating Sites obtain lists of industries that have filed a Notice
of Intent (NOI) to obtain storm water permits, as
The number and type of hotspot sites present in well as those that have filed under TRI
a subwatershed may vary greatly, and currently requirements. Other agencies that may have
there is no public database available to identify information on local generating sites include fire
all the regulated sites in a subwatershed. Instead, departments (for hazardous waste), and
multiple databases need to be queried to identify sanitation or wastewater treatment agencies.
generating sites that may be targets for source
control or illicit discharge investigations. A Phase 3. Permit Review
three-phase approach is useful for gathering as
much information as possible on suspect sites The final source for information is a review of
within a subwatershed that may qualify for more local permits. Most permit databases have SIC
intensive scrutiny. codes as one of the fields. These codes can be
matched against the SIC codes in Table B1,
Phase 1. Consult Publicly-Available which list common generating sites under major
Databases land use headings. If a local permit database
does not exist, it may be worthwhile to simply
The federal government has a number of get the local phone book and do a quick look for
databases that may help identify locations for businesses that are similar to those listed in
investigation. The Environmental Protection Table B1.
Agency (EPA) operates two such databases. The
first is the Enforcement and Compliance History Compiling the findings from the various
Online (ECHO) database. With this system, you databases will provide an initial list of potential
can look up facility compliance history and find generating sites for future investigation.
facilities based on geographic location (county However, research has found that most of these
level) or zip code: databases can miss many of the industries that
(http://www.epa.gov/echo/index.html). The are subject to regulation (Duke et al., 1999 and
other database is Envirofacts Duke and Shaver, 1999), and further
(http://www.epa.gov/enviro/). This website identification may be necessary. Field
provides access to multiple EPA databases that investigation with techniques such as the USSR
provide information about environmental (Wright et al., 2004) can assist in identifying
activities (including RCRA and Toxic Release

many of these generating sites that should If only specific SIC codes within a major group
probably be regulated by communities. qualify for this exception, they are noted in
parentheses. Municipal facilities that are subject
Reference Tables to NPDES MS4 permit requirements are
designated by “MS4.” Column four identifies
This appendix is designed to help identify the businesses that can be considered unregulated
land uses and associated generating sites in a storm water hotspots (also designated by “X”).
subwatershed where routine activities may result Column five looks at the illicit discharge
in pollution being discharged to the storm drain potential of each of the businesses listed. The
system. There are two tables provided, each of potential for a business to produce an illicit
which is described below. discharge is rated as either high (H) medium (M)
or low (L). This rating is based on the likelihood
Table A1 presents a listing of common land uses that it has a direct connection to the storm drain
that may qualify as hotspots based on regular system (direct), or that it can produce a
activities or practices. Column one describes the transitory discharge (indirect).
general industry type. Column two lists their
associated SIC codes, if known. Column three Table A2 provides a list of the SIC codes that
identifies whether an industry type is subject to are regulated by the Industrial Multi Sector
NPDES industrial storm water permit General Permit (MGSP). The list includes the
requirements (designated by “X”). Facilities four-digit SIC codes along with the official
where only certain activities or facilities at the description. This table is provided for those who
site are subject to regulation are noted (this wish to know the full description of each SIC
pertains mostly to the transport-related code regulated by NPDES industrial storm water
industries). In addition, storm water permits are permits.
required for many “light” industrial facilities
only if material handling equipment or activities,
raw materials, immediate products, final
products, waste materials, by-products, or
industrial machinery are exposed to storm water.
Industries where this applies are noted with an
asterisk.

Table A1: Common Storm Water Hotspots and their Pollution Potential
Regulated Unregulated Illicit Discharge
Industry Type/ Associated Potential
Storm Water Storm Water
General Description SIC Code(s)
Hotspot Hotspot Direct Indirect
Commercial
Animal Care Services 0742,0752 X L L
7532-7539,
Auto Repair X M M
7549
Automobile Parking 7521 L M
Building Materials 5211-5251 X L L
Campgrounds/RV parks 7033 X L M
Car Dealers 5511-5599, X M M
Car Washes 7542 X L L
Commercial Laundry/Dry
7211-7219 X L L
Cleaning
Convenience Stores 5399 X L L
Food Stores and Wholesale 5141-5149
X L M
Food and Beverage 5411-5499
Equipment Repair 7622-7699 X L L
Gasoline Stations 5541 X M M
Heavy Construction
Equipment Rental and 7353 X L H
Leasing
X
Building and Heavy 1521-1542 (For land
X L H
Construction 1611-1629 disturbing
activities)
Marinas 4493 X L M
Nurseries and garden centers 5261 X L M
Oil Change Shops 7549 X M
Restaurants 5812,5813,7011 X M L
Swimming Pools 7997, 7999 X L L
Warehouses X*
4221-4226 L L
(4221-4225)
Wholesalers of Chemical and 5162-
X L L
Petroleum 5169,5172
Industrial
2311–2399 2300 L L
Apparel and Other Fabrics X*
3131–3199 3100 H M
Auto Recyclers and Scrap
5015, 5093 X L H
Yards
Beverages and Brewing 2082-2087 X* L L
Boat Building and Repair 3731,3732 X L H
2810 H 2810 L
2820 H 2820 L
2840 H 2840 L
X* 2860 M 2860 L
Chemical Products 2812-2899
(2830, 2850) 2830 L 2830 L
2850 L 2850 L
2870 L 2870 L
2890 L 2890 L

Industrial (continued)
2010 H 2010 L
2020 H 2020 L
2030 H 2030 L
2040 H 2040 L
Food Processing 2011–2141 X* 2050 L. 2050 L.
2060 L 2060 L
2070 M 2070 L
2090 L 2090 L
2110 M 2110 L
Garbage Truck Washout
4212 X L H
Activities
Industrial or Commercial
3511–3599
Machinery, Electronic X* L L
3612–3699
Equipment
Instruments; Photographic
and Optical Goods, Watches 3812–3873
X* L L
and Clocks and other 3933-3999
Miscellaneous Manufacturing
Leather Tanners 3411 X H M
X*
2514, 2522,
(2514,2522,
Metal Production, Plating and 2542, 3312-
2542, 3411- H L
Engraving Operations 3399, 3411-
3433, 3442-
3499, 3590
3499, 3590)
2411-2499,
X*
2511, 2512, 2400 L 2400 H
(2434, 2652–
Paper and Wood Products 2517, 2519, 2500 L 2500 L
2657, 2671–
2521, 2541, 2600 H 2600 H
2679)
2611–2679
Petroleum Storage and
2911 X 2911 H H
Refining
Printing 2711–2796 X* L L
Rubber and Plastics 3011-3089 X* M L
Stone, Glass, Clay, Cement,
X*
Concrete, and Gypsum 3211-3299 L L
(3233)
Product
Textile Mills 2211–2299 X* H L
3711–3728,
Transportation Equipment X* H M
3743-3799
Institutional
Cemeteries 6553 X L L
Churches 8661 X L L
Colleges and Universities 8221-8222 X L M
Corporate Office Parks X L L
8062-8069 X L
Hospitals L
8071-8072
Private Golf Courses 7997 X L L
Private Schools 8211 X L L

Municipal
Composting Facilities 2875 X L L
Public Golf Courses 7992 X L L
Landfills and Hazardous
4953, HZ, LF X L H
Waste Material Disposal
Local Streets MS4 X L H
Maintenance Depots 4173 MS4 M H
Municipal Fleet Washing 4100 MS4 L M
Public Works Yards MS4 M H
Steam Electric Plants SE X L L
Treatment Works TW X L L
Transport-Related (NPDES regulation is for the portion of the facility dedicated to vehicle maintenance
shops, equipment-cleaning operations, and airport deicing operations)
Airports 4581 X L M
Streets and Highways
1611, 1622 X L H
Construction
Ports 4449, 4499 X L H
Railroads 4011, 4013 X L H
Rental Car Lots 7513-7519 X L M
US Postal Service 4311 X L M
Trucking Companies and 4212-4215,
X L M
Distribution Centers 4231
Petroleum Bulk Stations or
5171 X L H
Terminals

Table A2: SIC Codes for NPDES Industrial Storm Water Regulated Facilities
A. Timber Products
2411 Log Storage and Handling
2421 General Sawmills and Planning Mills
2426 Hardwood Dimension and Flooring Mills
2429 Special Product Sawmills, Not Elsewhere Classified
2431–2439 Millwork, Veneer, Plywood, and Structural Wood (except 2434)
2448, 2449 Wood Containers
2451, 2452 Wood Buildings and Mobile Homes
2491 Wood Preserving
2493 Reconstituted Wood Products
2499 Wood Products, Not Elsewhere Classified
B. Paper and Allied Products Manufacturing
2611 Pulp Mills
2621 Paper Mills
2631 Paperboard Mills
2652–2657 Paperboard Containers and Boxes
2671–2679 Converted Paper and Paperboard Products, Except Containers and Boxes
C. Chemical and Allied Products Manufacturing
2812–2819 Industrial Inorganic Chemicals
2821–2824 Plastics Materials and Synthetic Resins, Synthetic Rubber, Cellulosic and Other
Manmade Fibers Except Glass
2833–2836 Medicinal chemicals and botanical products; pharmaceutical preparations; in-vitro and in-
vivo diagnostic substances; biological products, except diagnostic substances
2841–2844 Soaps, Detergents, Cleaning Preparations; Perfumes, Cosmetics, Other Toilet
Preparations
2851 Paints, Varnishes, Lacquers, Enamels, and Allied Products
2861–2869 Industrial Organic Chemicals
2873–2879 Agricultural Chemicals, Including Facilities that Make Fertilizer Solely from Leather
Scraps and Leather Dust
2891–2899 Miscellaneous Chemical Products
3952 (limited Inks and Paints, Including China Painting Enamels, India Ink, Drawing Ink, Platinum
to list) Paints for Burnt Wood or Leather Work, Paints for China Painting, Artist’s Paints and
Watercolors
D. Asphalt Paving and Roofing Materials Manufacturers and Lubricant Manufacturers.
2951, 2952 Asphalt Paving and Roofing Materials
2992, 2999 Miscellaneous Products of Petroleum and Coal
E. Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing
3211 Flat Glass
3221, 3229 Glass and Glassware, Pressed or Blown
3231 Glass Products Made of Purchased Glass
3241 Hydraulic Cement
3251-3259 Structural Clay Products
3261-3269 Pottery and Related Products
3271-3275 Concrete, Gypsum and Plaster Products
3281 Cut Stone and Stone Products
3291–3292 Abrasive and Asbestos Products
3295 Minerals and Earth’s, Ground, or Otherwise Treated
3296 Mineral Wool
3297 Non-Clay Refractories
3299 Nonmetallic Mineral Products, Not Elsewhere Classified

F. Primary Metals
3312–3317 Steel Works, Blast Furnaces, and Rolling and Finishing Mills
3321–3325 Iron and Steel Foundries
3331–3339 Primary Smelting and Refining of Nonferrous Metals
3341 Secondary Smelting and Refining of Nonferrous Metals
3351–3357 Rolling, Drawing, and Extruding of Nonferrous Metals
3363–3369 Nonferrous Foundries (Castings)
3398, 3399 Miscellaneous Primary Metal Products
G. Metal Mining (Ore Mining and Dressing)
1011 Iron Ores
1021 Copper Ores
1031 Lead and Zinc Ores
1041, 1044 Gold and Silver Ores
1061 Ferroalloy Ores, Except Vanadium
1081 Metal Mining Services
1094, 1099 Miscellaneous Metal Ores
H. Coal Mines and Coal Mining-Related Facilities
1221–1241 Coal Mines and Coal Mining-Related Facilities Sector
I. Oil and Gas Extraction and Refining
1311 Crude Petroleum and Natural Gas
1321 Natural Gas Liquids
1381–1389 Oil and Gas Field Services
2911 Petroleum refining
J. Mineral Mining and Dressing
1411 Dimension Stone
1422–1429. Crushed and Broken Stone, Including Rip Rap
1481 Nonmetallic Minerals, Except Fuels
1442, 1446. Sand and Gravel
1455, 1459 Clay, Ceramic, and Refractory Materials
1474–1479 Chemical and Fertilizer Mineral Mining
1499 Miscellaneous Nonmetallic Minerals, Except Fuels
K. Hazardous Waste Treatment Storage or Disposal Facilities
HZ Hazardous Waste Treatment, Storage or Disposal
L. Landfills and Land Application Sites
LF Landfills, Land Application Sites and Open Dumps
M. Automobile Salvage Yards
5015 Automobile Salvage Yards
N. Scrap Recycling Facilities
5093 Scrap Recycling Facilities
O. Steam Electric Generating Facilities
SE Steam Electric Generating Facilities
P. Land Transportation
4011, 4013 Railroad Transportation
4111–4173 Local and Highway Passenger Transportation
4212–4231 Motor Freight Transportation and Warehousing
4311 United States Postal Service
5171 Petroleum Bulk Stations and Terminals
Q. Water Transportation
4412–4499 Water Transportation
R. Ship and Boat Building or Repairing Yards
3731, 3732 Ship and Boat Building or Repairing Yards
S. Air Transportation Facilities
4512–4581 Air Transportation Facilities

T. Treatment Works
TW Treatment Works
U. Food and Kindred Products
2011–2015 Meat Products
2021–2026 Dairy Products
2032 Canned, Frozen and Preserved Fruits, Vegetables and Food Specialties.
2041–2048 Grain Mill Products
2051–2053 Bakery Products
2061–2068 Sugar and Confectionery Products
2074–2079 Fats and Oils
2082–2087 Beverages
2091–2099 Miscellaneous Food Preparations and Kindred Products
2111–2141 Tobacco Products
V. Textile Mills, Apparel, and Other Fabric Product Manufacturing
2211–2299 Textile Mill Products
2311–2399 Apparel and Other Finished Products Made From Fabrics and Similar Materials
3131–3199 Leather Products (except 3111)
W. Furniture and Fixtures
2511–2599 Furniture and Fixtures
2434 Wood Kitchen Cabinets
X. Printing and Publishing
2711–2796 Printing, Publishing and Allied Industries
Y. Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries
3011 Tires and Inner Tubes
3021 Rubber and Plastics Footwear
3052, 3053 Gaskets, Packing, and Sealing Devices and Rubber and Plastics Hose and Belting.
3061, 3069 Fabricated Rubber Products, Not Elsewhere Classified
3081–3089 Miscellaneous Plastics Products
3931 Musical Instruments
3942–3949 Dolls, Toys, Games and Sporting and Athletic Goods
3951–3955 Pens, Pencils, and Other Artists’ Materials. (except 3952)
3961, 3965 Costume Jewelry and Novelties, Buttons, and Miscellaneous Notions, Except Precious
Metal
3991–3999 Miscellaneous Manufacturing Industries.
Z. Leather Tanning and Finishing
3111 Leather Tanning and Finishing.
AA. Fabricated Metal Products
3411–3499 Fabricated Metal Products, Except Machinery and Transportation Equipment and
Cutting, Engraving and Allied Services
3911–3915 Jewelry, Silverware, and Plated Ware
3479 Coating, Engraving, and Allied Services
BB. Transportation Equipment, Industrial or Commercial Machinery
3511–3599 Industrial and Commercial Machinery (except 3571–3579)
3711–3799 Transportation Equipment (except 3731, 3732)
CC. Electronic, Electrical, Photographic and Optical Goods
3612–3699 Electronic, Electrical Equipment and Components, Except Computer Equipment
3812–3873 Measuring, Analyzing and Controlling Instrument, Photographic/Optical Goods,
Watches/Clocks
3571–3579 Computer and Office Equipment
DD. Construction (based on land disturbing activities)
1521-1542 Building Construction General Contractors And Operative Builders
1611-1629 Heavy Construction Other Than Building Construction Contractors

References
Duke, D., K Patel, and B. Masek. 1999. Pitt, R. 1993. Investigation of Inappropriate
“Widespread Failure to Comply with Pollutant Entries Into Storm Drain
U.S. Storm Water Regulations for Systems. EPA, Office of Research and
Industry-Part I: Publicly Available Data Development, Washington, DC.
to Estimate Number of Potentially EPA/600/R-92/238.
Regulated Facilities.” Environmental
Engineering Science, 16(4). Wright, T., C. Swann, K. Cappiella, and T.
Schueler. 2004. Unified Subwatershed
Duke, D and K. Shaver. 1999. “Widespread and Site Reconnaissance: A User’s
Failure to Comply with U.S. Storm Manual. Center for Watershed
Water Regulations for Industry-Part II: Protection. Ellicott City, MD.
Facility-Level Evaluations to Estimate
Number of Regulated Facilities.”
Environmental Engineering Science. 16( 4).


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Urban Subwatershed Restoration Manual Series

Tom Schueler, Chris Swann, Tiffany Wright and Stephanie Sprinkle

Office of Water Management

Copyright ©2005 by the Center for Watershed Protection.

Urban Subwatershed Restoration Manual 8 i

ii Urban Subwatershed Restoration Manual 8

About the Restoration Manual Series

Urban Subwatershed Restoration Manual 8 iii

iv Urban Subwatershed Restoration Manual 8

Individual manuals in the series are scheduled for

Urban Subwatershed Restoration Manual 8 v

vi Urban Subwatershed Restoration Manual 8

About the Restoration Manual Series ........................................................................................................ iii

Table of Contents...................................................................................................................................... vii

Organization of the Manual ...................................................................................................................... 1

Chapter 1: Basics of Neighborhood Source Control ........................................................................... 3

1.1 Pollution Source Areas in the Neighborhoods .................................................................... 3

Chapter 2: Basics of Storm Water Hotspots .......................................................................................... 13

2.1 Classification of Storm Water Hotspots .............................................................................. 13

Chapter 3: Finding Pollutant Sources In Your Subwatershed ................................................................ 25

3.1 The Subwatershed Context for Pollution Source Control..................................................... 25

Chapter 4: Subwatershed Source Control Plans .................................................................................. 29

4.1 Basics of a Subwatershed Source Control Plan .................................................................. 29

Chapter 5: Neighborhood Stewardship Profile Sheets........................................................................... 49

N-1 Reduced Fertilizer Use ......................................................................................................... 51

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N-9 Septic System Maintenance ............................................................................................ 75

Chapter 6: Hotspot Pollution Prevention Profile Sheets ........................................................................ 109

H-1 Vehicle Maintenance and Repair..................................................................................... 111

Appendix A: Stormwater Hotspots and Potential Discharge Generators ................................................... A-1

Table 1. Key Behaviors Within Neighborhood Source Areas................................................................ 4

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Figure 1. Four Pollution Source Areas in Residential Neighborhoods..................................................... 4

List of Acronyms and Abbreviations

DPI: Discharge Prevention Investigation

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Chapter 1: Basics of Neighborhood

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Figure 1: Four Pollution Source Areas in Residential Neighborhoods

Table 1: Key Behaviors Within Neighborhood Source Areas

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Table 2: Comparison of Pollutant Contribution from Various Residential Behaviors

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Table 3: Key Neighborhood Stewardship Practices

Source Area Practice Number Stewardship Practice

studies on innovative local programs to improve neighborhood stewardship is outlined in Table 4

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Carrots wastes can produce significant pollutant

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Sticks also establish water quality hotlines that

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Table 5: NPDES MS4 Storm Water Permit Program: What It Means

Want more information? For Phase II, consult http://cfpub.epa.gov/npdes/storm water/swfinal.cfm.

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