LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
1
Appendix
E
Watershed
Control
Best
Management
Practices
(
BMPs)

This
appendix
provides
a
list
of
programmatic
resources
and
guidance
available
to
assist
systems
in
building
partnerships
and
implementing
watershed
protection
activities.
Examples
of
partnerships
and
possible
control
measures
for
different
sources
are
summarized
in
chapter
2,
section
2.4.2;
this
appendix
provides
further
detail
to
the
control
measures
described
in
chapter
2.

E.
1
Regulatory
and
Other
Management
Strategies
For
systems
in
watersheds
where
most
of
the
land
is
privately
owned,
land
use
regulations
may
be
the
best
way
to
control
pollution,
especially
in
heavily
developed
or
growing
areas.
Examples
of
possible
regulations
include
septic
system
requirements,
zoning
ordinances
specifying
minimum
lot
sizes
or
low­
impact
development,
limits
on
discharge
from
wastewater
treatment
plants
and
other
facilities,
pet
waste
cleanup
ordinances,
and
requirements
for
permits
for
certain
land
uses.
Your
ability
to
regulate
land
use
will
depend
on
the
authority
granted
to
your
municipality
by
the
state,
the
ownership
of
your
system
(
public
or
private),
and
the
support
of
your
local
government
and
the
public.
Regulatory
authority,
steps
for
designing
a
regulation
that
can
withstand
lawsuits,
and
types
of
land
use
regulations
are
described
in
the
paragraphs
below.

E.
1.1
Determining
Authority
to
Regulate
Where
a
water
system
is
privately
owned,
it
may
be
necessary
to
ask
the
cooperation
of
the
local
government
to
get
source
water
regulations
passed.
For
a
municipal
water
system
whose
watershed
is
located
entirely
within
the
municipality,
issuing
zoning
or
land
use
ordinances
should
be
less
of
a
hurdle.
The
ability
of
a
municipality
to
pass
a
land
use
ordinance
or
other
law
to
help
reduce
contamination
may
depend
on
the
authority
the
state
grants
to
the
local
government
in
the
state
constitution
or
through
legislation,
although
states
normally
do
not
interfere
with
the
actual
land
use
and
zoning
rules
(
AWWARF
1991).
States
generally
permit
zoning
for
the
purposes
of
protecting
public
health
or
general
welfare.
However,
some
states
may
prevent
local
governments
from
passing
laws
that
are
more
stringent
than
state
law
or
that
conflict
with
state
laws.
State
laws
in
other
states
may
prevent
municipal
governments
from
passing
certain
local
laws
that
are
not
expressly
permitted
elsewhere
in
state
law.

If
the
watershed
or
the
area
of
influence
on
water
quality
extends
throughout
several
municipalities,
it
can
be
difficult
to
standardize
watershed
control
practices
throughout
the
watershed.
The
legal
framework
used
will
depend
on
who
has
jurisdiction
over
land
use
in
the
watershed
and
on
the
authority
of
the
water
system
(
AWWARF
1991).
New
York
State
law,
for
instance,
authorizes
municipalities
to
draft
watershed
regulations,
which
are
then
approved
and
adopted
by
the
state.
This
gives
the
municipalities
the
authority
to
enforce
the
watershed
rules
within
their
watersheds
even
if
the
watershed
is
outside
municipal
boundaries.
For
instance,
New
York
City
sets
water
quality
standards,
land
use
restrictions,
and
approves
wastewater
treatment
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
2
plant
designs
in
its
watersheds
in
upstate
New
York.
The
City
of
Syracuse
conducts
watershed
inspections
on
Skaneateles
Lake,
its
source
of
supply,
several
miles
outside
of
Syracuse.
Both
of
these
systems
are
filtration
avoidance
systems,
so
it
is
especially
important
that
they
have
some
control
over
areas
outside
their
jurisdictions.

The
Metropolitan
District
Commission,
although
not
a
PWS,
was
created
by
the
State
of
Massachusetts
and
is
authorized
to
promulgate
and
enforce
watershed
protection
regulations
in
watersheds
used
by
the
Massachusetts
Water
Resources
Authority
to
provide
water
to
the
Boston
metropolitan
area.
Some
watersheds
which
extend
across
state
boundaries
have
governing
bodies
authorized
by
Congress.
The
formation
of
the
Tahoe
Regional
Planning
Agency
was
the
result
of
a
compact
between
the
States
of
California
and
Nevada
and
was
approved
by
Congress.
The
agency
is
authorized
to
pass
ordinances,
including
source
water
protection
rules,
that
regulate
land
use
in
the
area
around
Lake
Tahoe.

County
governments
in
some
states
may
have
some
zoning
authority
and
may
be
able
to
assist
with
enforcement
of
some
regulations
affecting
source
water
(
e.
g.,
septic
systems).
In
most
cases
where
watersheds
cross
jurisdictions,
however,
PWSs
will
not
have
regulatory
or
enforcement
authority.
PWSs
in
this
situation
should
work
with
other
local
governments'
PWSs
and
agencies
in
their
watersheds
to
sign
memoranda
of
agreement
or
understanding,
in
which
each
entity
agrees
to
meet
certain
standards
or
implement
certain
practices.

The
City
of
New
York
signed
a
memorandum
of
agreement
in
1997
with
the
State
of
New
York,
EPA,
and
79
municipalities
within
its
watersheds.
The
agreement
calls
for
the
creation
of
local
and
regional
watershed
protection
programs
and,
for
New
York
City,
funding
for
water
quality
and
infrastructure
improvement
projects
in
upstate
New
York.
Other
cities,
such
as
Salem
and
The
Dalles,
both
in
Oregon,
have
signed
memoranda
of
understanding
with
the
U.
S.
Forest
Service,
which
owns
most
of
the
land
in
the
cities'
watersheds.
These
memoranda
define
the
management
responsibilities
of
each
PWS
and
the
Forest
Service.

E.
1.2
Zoning
This
section
describes
the
steps
you
should
follow
to
make
sure
a
zoning
law
can
withstand
a
legal
challenge.
Basically,
it
is
important
to
make
sure
the
appropriate
procedures
are
followed
and
that
the
law
has
sufficient
scientific
basis
(
AWWA
1999).
First,
be
sure
you
have
the
authority
to
regulate,
especially
if
you
are
proposing
something
besides
a
simple
zoning
law.
Make
sure
the
rule
is
specific
enough;
if
a
map
of
an
overlay
district
is
not
drawn
to
a
small
enough
scale,
it
may
be
difficult
to
tell
which
properties
are
affected.
Comply
with
all
administrative
procedure
requirements,
such
as
notifying
the
public
of
the
proposed
changes
and
holding
a
public
hearing;
failure
to
do
so
is
the
most
common
reason
for
rules
being
revoked.
Follow
substantive
due
process,
which
means
that
the
regulation
should
promote
the
municipality's
public
health
goals.
In
practice,
this
means
the
ordinance
should
conform
to
the
objectives
of
the
watershed
control
program
plan.
The
plan
should
contain
enough
data
to
illustrate
how
the
ordinance
will
affect
water
quality.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
3
Ordinances
should
also
be
designed
to
withstand
a
takings
lawsuit
(
AWWA
1999).
The
fifth
amendment
to
the
U.
S.
Constitution
states
that
private
property
may
not
be
taken
for
public
use
without
just
compensation.
Any
physical
invasion
without
consent
is
always
considered
a
taking,
even
if
the
landowner
retains
ownership
of
the
land.
Installation
of
a
monitoring
well
or
stream
gauge
without
consent
is
an
example
of
a
taking.

In
addition,
ordinances
that
"
fail
to
advance
a
legitimate
government
interest"
or
"
deny
a
landowner
economically
viable
use
of
his
land"
can
be
viewed
as
takings,
even
if
the
landowner
retains
full
ownership
(
AWWA
1999).
The
first
criterion
means
that
there
should
be
a
need
for
the
ordinance;
for
example,
if
a
planned
development's
storm
sewers
and
wastewater
treatment
plant
will
discharge
into
an
area
outside
a
municipality's
wellhead
protection
area,
the
municipality
cannot
cite
impacts
on
the
drinking
water
as
a
factor
in
the
decision
to
restrict
development
without
compensating
landowners.
Under
the
second
criterion,
if
property
values
decrease
but
still
retain
some
value
(
e.
g.,
due
to
a
decrease
in
permitted
building
density),
the
ordinance
does
not
result
in
a
taking.
A
regulation
that
restricts
all
development
would
probably
be
considered
a
taking.
In
keeping
with
these
two
criteria,
the
effect
of
an
ordinance
should
be
proportional
to
the
predicted
impact
of
development.
Thus,
if
a
municipality
determines
that
half­
acre
zoning
is
sufficient
to
protect
a
drinking
water
source,
it
may
not
zone
for
five
acres.

To
prevent
takings
claims,
the
municipality
should
show
the
need
for
the
regulation
and
a
connection
between
the
ordinance
and
the
expected
result
(
AWWA
1999).
This
proof
should
be
based
on
a
scientific
analysis
beginning
with
an
accurate
delineation
of
the
watershed
or
wellhead
protection
area/
recharge
area.
A
zoning
district
based
on
an
arbitrary
fixed
radius
around
a
well
or
lake
would
probably
be
considered
insufficient
in
court
unless
it
is
characterized
as
an
interim
boundary.
A
court
challenge
could
claim
that
such
a
district
protects
an
area
that
does
not
contribute
to
the
watershed
or
that
land
that
is
part
of
the
watershed
is
not
being
protected
(
failing
to
advance
the
government's
interests).

Following
the
delineation,
determine
the
impact
the
regulation
will
have
by
mapping
current
and
projected
residential,
commercial,
and
industrial
development
under
current
zoning
requirements.
Then
map
current
and
projected
development
for
existing
regulations
and
for
the
proposed
ordinance,
and
determine
the
potential
pollutant
load
under
each
scenario
(
AWWA
1999).
You
may
not
be
able
to
determine
Cryptosporidium
loading
if
you
have
not
monitored,
but
there
may
be
data
available
on
fecal
coliform
bacteria
from
different
sources
in
your
watershed
(
e.
g.,
agriculture,
septic
system
failure,
pets
and
wildlife).
If
your
PWS
has
not
collected
such
data,
other
local
agencies,
such
as
sewer
authorities,
non­
profit
groups,
universities,
or
planning
commissions,
as
well
as
the
U.
S.
Geological
Survey,
may
have
water
quality
data.
Water
quality
models
can
help
you
determine
pollutant
loading.
This
"
buildout
analysis"
will
help
you
show
how
your
proposed
ordinance
advances
a
legitimate
government
interest
and
how
the
effect
of
the
ordinance
is
proportional
to
the
impact
of
land
use
in
your
watershed.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
4
Types
of
Ordinances
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
5
Watershed
ordinances
usually
apply
within
an
"
overlay
district,"
which
may
be
the
area
of
influence
you
determined
for
your
watershed
control
plan.
All
existing
zoning
or
land
use
regulations
apply
within
that
area,
but
additional
requirements
apply
within
the
overlay
district.
Following
are
some
land
use
ordinances
you
may
wish
to
consider:


Large­
lot
or
low­
density
zoning.
Unless
lots
are
very
large
(
such
lots
can
use
septic
systems
and
wells),
large­
lot
zoning
may
be
inefficient,
as
it
increases
costs
for
sewer,
water,
and
road
development.
This
type
of
zoning
also
may
go
against
affordable
housing
requirements.
However,
it
may
be
useful
in
agricultural
areas
for
preserving
rural
character
and
preventing
subdivision
of
farms.


Limits
on
certain
types
of
land
use
except
by
special
permit.
Such
ordinances
should
specify
criteria
for
granting
special
permits
and
designate
an
authority
that
may
grant
permits.
The
authority
should
present
findings
that
back
up
its
decision
to
grant
the
permit.
Special
permits
are
granted
for
a
particular
lot,
not
for
the
owner
of
that
lot.


Impact
fees.
The
regulating
authority
must
be
sure
it
has
authority
to
impose
such
fees.
Impact
fees
collected
can
be
used
to
pay
for
mitigation
of
pollution
caused
by
development,
e.
g.,
for
preventing
runoff
or
buying
land
elsewhere
in
the
watershed.
Fees
should
be
proportional
to
the
impact
and
the
cost
of
mitigation,
and
the
purpose
of
the
fees
should
be
specified
in
the
regulation.
A
disadvantage
to
impact
fees
is
that
they
may
in
some
cases
be
considered
taxes,
and
local
governments'
authority
to
impose
taxes
may
be
limited.
Fees
are
more
likely
to
withstand
challenge
if
they
are
framed
as
optional
services
provided
to
the
developer
(
i.
e.,
the
developer
can
choose
not
to
develop)
and
if
the
fees
are
set
aside
for
the
PWS
or
stormwater
utility
rather
than
put
into
general
funds.


Submission
and
approval
of
a
watershed
protection
plan
or
impact
study
as
a
condition
for
development
of
a
subdivision
or
apartment
complex.
This
type
of
ordinance
requires
that
watershed
protection
plan
or
stormwater
control
be
implemented
before
a
building
certificate
of
compliance
is
issued.
Plans
should
be
required
to
designate
the
party
responsible
for
maintaining
stormwater
facilities
after
construction
is
complete.


Performance
standards.
A
performance
standard
permits
development
but
limits
impact
of
the
development.
For
example,
the
regulation
could
specify
that
permits
require
that
the
pollutant
loading
rate
of
the
development
is
no
more
than
a
certain
percentage
of
the
pre­
development
loading
rate
of
the
area.
This
would
require
enforcement
or
monitoring
to
make
sure
the
development
continues
to
comply.
In
its
permit
application,
the
developer
would
also
be
required
to
list
mitigation
steps
it
would
take
if
it
exceeded
the
pollutant
loading
requirements.

Most
zoning
ordinances
have
grandfather
clauses
that
allow
nonconforming
land
uses
to
continue.
Ordinances
may
also
allow
the
zoning
authority
to
grant
variances
if
the
topography
or
size
of
a
lot
make
it
difficult
to
comply
with
a
zoning
requirement.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
6
Examples
of
source
water
protection
ordinances
can
be
found
at
http://
www.
epa.
gov/
owow/
nps/
ordinance/
osm7.
htm.

E.
1.3
Land
Acquisition
and
Conservation
Easements
Acquisition
of
watershed
land
by
the
utility
or
its
affiliated
jurisdiction
is
often
the
most
effective
approach
to
protecting
the
water
source.
Landowners
usually
consider
acquisition
as
fair,
since
it
compensates
them
for
their
property
while
protecting
the
watercourses
nearby.
Land
conservation
has
also
been
found
to
provide
multiple
benefits
aside
from
controlling
pathogen
contamination,
such
as
flood
control,
limited
recreational
use,
and
the
protection
of
historic
and
environmental
resources.
EPA's
Drinking
Water
State
Revolving
Fund
allows
a
percentage
of
the
fund
to
be
set
aside
for
land
acquisition
associated
with
watershed
protection.

Several
organizations
exist
that
can
help
systems
purchase
watershed
land
to
protect
drinking
water
quality,
especially
when
government
agencies
are
unable
to
move
quickly
enough
to
buy
land
when
it
becomes
available.
The
Trust
for
Public
Land
(
http://
www.
tpl.
org)
and
small
local
land
trusts
and
conservancies
can
facilitate
the
land
acquisition
process.
Trusts
can
buy
and
hold
land
from
multiple
landowners
on
behalf
of
a
water
system
until
the
system
can
assemble
funding
to
purchase
it
from
the
trust.
Trusts
may
also
maintain
land
ownership
themselves.
The
Trust
for
Public
Land
also
can
assist
with
development
of
financing
strategies
for
land
purchases.

Trusts
also
can
work
with
landowners
to
buy
or
have
landowners
donate
conservation
easements.
An
easement
is
a
legal
document
that
permanently
limits
the
development
of
a
piece
of
land,
even
after
the
land
is
sold
or
otherwise
changes
ownership.
The
landowner
selling
or
donating
the
easement
specifies
the
development
restrictions
to
apply
to
the
land.
The
law
varies
from
state
to
state,
but
the
owner
of
the
easement
(
the
government
agency
or
land
trust)
has
the
authority
to
determine
if
the
requirements
of
the
easement
are
being
followed.
If
not,
the
owner
of
the
easement
make
take
legal
action.
Easements
donated
to
government
agencies
or
to
land
trusts
may
be
eligible
for
tax
deductions.
See
http://
www.
landtrust.
org/
ProtectingLand/
EasementInfo.
htm
for
frequently
asked
questions
about
easements
and
for
an
example
of
a
model
easement
for
use
in
the
State
of
Michigan.
The
Land
Trust
Alliance
(
http://
www.
lta.
org),
a
trade
organization
for
land
trusts,
has
published
handbooks
on
designing
and
managing
conservation
easement
programs.

Other
government
agencies,
such
as
the
U.
S.
Forest
Service
or
state
natural
resource
departments,
may
be
able
to
buy
parcels
in
your
watershed
if
you
are
unable
to
afford
to
purchase
all
the
land
that
needs
to
be
protected.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
7
E.
2
Addressing
Point
Sources
E.
2.1
Concentrated
Animal
Feeding
Operations
Some
animal
feeding
operations
(
AFOs)
may
be
considered
concentrated
animal
feeding
operations
(
CAFOs)
if
they
have
more
than
a
specified
number
of
animals
and/
or
if
they
discharge
pollutants
into
navigable
waters
through
a
manmade
ditch
or
other
device
or
if
they
discharge
directly
into
waters
of
the
United
States.
Possible
sources
of
pollutants
at
CAFOs
include
runoff
that
flows
through
feedlots;
failure
of
pumps,
pipes,
or
retaining
walls
of
manure
storage
lagoons;
runoff
from
areas
where
manure
is
applied
to
the
soil;
and
direct
contact
of
animals
with
surface
water.
CAFOs
are
located
primarily
in
the
South
and
Midwest,
but
the
number
of
such
facilities
is
increasing
as
farms
consolidate
their
operations.

EPA
recently
issued
a
rule
that
changed
the
requirements
on
CAFOs
that
must
apply
for
National
(
or
State)
Pollutant
Discharge
Elimination
System
(
NPDES)
permits
(
U.
S.
EPA
2003).
All
CAFOs
are
regulated
as
point
sources
in
the
NPDES
program.
Previously,
CAFOs
could
be
exempt
from
permitting
if
they
could
show
that
they
did
not
discharge
during
25­
year
24­
hour
storms.
The
new
rules
eliminate
this
exemption,
unless
a
facility
can
show
that
it
does
not
discharge
at
all.
NPDES
permits
for
CAFOs
generally
allow
zero
discharge
of
pollutants
and
may
also
require
the
use
of
certain
technologies.
CAFOs
are
required
to
report
to
the
state
within
24
hours
of
exceeding
effluent
limits
(
U.
S.
EPA
2001a).

Many
CAFOs
do
not
currently
have
permits
due
to
limited
state
resources
for
compliance
(
medium
and
small
AFOs
may
be
designated
as
CAFOs
only
by
state
or
regional
staff
after
onsite
inspection).
For
CAFOs
(
and
other
NPDES
permittees)
that
do
have
individual
permits,
you
may
want
to
attend
the
public
hearing
required
as
part
of
the
permit
renewal
process,
especially
if
you
have
any
concerns
about
the
adequacy
of
the
existing
permit
requirements
to
prevent
Cryptosporidium
or
other
drinking
water
contamination.
If
a
CAFO
in
your
area
of
influence
does
not
have
a
permit,
consider
encouraging
its
managers
to
apply
for
one
or
working
with
them
to
implement
a
nutrient
management
plan
or
other
BMPs.

E.
2.2
Wastewater
Treatment
Plants
All
wastewater
treatment
plants
in
the
United
States
are
required
to
provide
secondary
treatment
(
primary
treatment
consists
of
sedimentation,
while
in
secondary
treatment,
aeration
provides
oxygen
to
bacteria
that
take
in
nutrients
and
digest
organic
material)
(
U.
S.
EPA
2001b).
Most
plants
are
also
required
to
disinfect
their
effluent
before
discharging.
However,
conventional
chlorine
disinfection
may
be
ineffective
against
Cryptosporidium.

Some
wastewater
treatment
facilities
are
beginning
to
implement
treatment
similar
to
that
used
for
drinking
water
treatment.
The
Robbins
Plant
of
the
Upper
Occoquan
Sewerage
Authority
in
Centreville,
Virginia,
discharges
into
a
stream
that
feeds
into
a
reservoir
in
northern
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
8
Virginia.
Following
secondary
treatment
using
activated
sludge,
the
facility
provides
other
treatment,
including
clarification,
multimedia
filtration,
and
disinfection
(
U.
S.
EPA
2000a).
The
Cole
Pollution
Control
Plant
in
Fairfax
County,
Virginia,
which
discharges
into
a
creek
flowing
into
the
Potomac
River,
also
uses
advanced
treatment,
including
chlorine
disinfection,
filtration,
and
dechlorination
(
Fairfax
County
2001).

PWSs
should
identify
all
wastewater
treatment
plants
in
their
watersheds
and
determine
what
their
permit
effluent
limits
are
and
whether
the
limits
are
being
met.
Some
of
this
information
may
already
be
available
through
the
source
water
assessment
program.
PWSs
may
wish
to
work
with
the
wastewater
utilities
and
appropriate
government
agencies
to
get
them
to
voluntarily
upgrade
the
treatment
provided.
PWSs
with
the
appropriate
legal
authority
may
wish
to
require
wastewater
plants
to
use
certain
technologies.
An
example
might
be
switching
from
chlorine
to
ozone
or
ultraviolet
radiation
disinfection
before
discharging.

E.
2.3
Combined
Sewer
Overflows
Combined
sewer
overflows
(
CSOs)
are
most
common
in
older
cities
in
the
northeastern
and
midwestern
United
States
and
can
be
a
significant
contributor
of
Cryptosporidium
to
urban
watersheds.

There
are
three
major
structural
solutions
to
the
problem
of
CSOs.
The
first
is
to
separate
combined
sewers
into
sanitary
and
storm
sewers,
where
sanitary
sewers
flow
to
the
wastewater
treatment
plant
and
storm
sewers
release
to
surface
water.
This
separation
may
cause
the
unwanted
side
effect
of
increasing
overall
contamination
due
to
the
fact
that
storm
water
is
no
longer
being
treated.
For
example,
separating
sewers
resulted
in
only
an
estimated
45­
percent
reduction
in
fecal
coliform
removal
in
a
bay
in
Boston
(
Metcalf
and
Eddy
1994,
cited
in
U.
S.
EPA
1999c).
Separating
sewers
is
also
very
expensive
and
often
impractical.
The
second
option
is
to
increase
the
capacity
of
the
wastewater
treatment
plant
so
that
it
is
able
to
treat
combined
sewage
from
most
storms.
The
third,
very
expensive
solution
is
to
build
aboveground
open
or
covered
retention
basins
or
to
construct
underground
storage
facilities
for
combined
sewage
to
hold
the
sewage
until
the
storm
has
passed
and
can
be
treated
without
overloading
the
plant.
The
Metropolitan
Water
Reclamation
District
in
Cook
County,
Illinois,
chose
the
third
option,
building
109
miles
of
tunnel
up
to
35
feet
wide
and
several
underground
reservoirs
underneath
Chicago
and
its
suburbs,
with
most
funding
from
EPA
(
MWRD
1999).
In
addition
to
reducing
CSOs,
the
tunnels
eliminated
flooding
that
had
previously
affected
the
area
due
to
its
flat
topography.
The
project
also
eliminated
the
need
for
individual
municipalities
to
implement
their
own
CSO
programs.

CSOs
are
not
regulated
directly
under
their
own
program,
but
EPA
has
a
CSO
control
policy
(
U.
S.
EPA
1994)
which
encourages
minor
improvements
to
optimize
CSO
operation,
and
CSO
management
may
be
written
into
NPDES
or
SPDES
permits.
The
CSO
policy
also
encourages
development
of
long
term
control
plans
for
each
CSO
system;
such
plans
would
require
significant
construction,
and
few
utilities
have
drafted
or
implemented
them
yet.
Planned
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
9
construction
projects
can
be
included
as
control
measures
in
watershed
control
plans.
PWSs
should
determine
the
extent
of
the
CSO
programs
in
place
in
municipalities
within
their
watersheds.
They
may
be
able
to
work
with
other
utilities
to
address
overflow
sites
of
particular
concern.
Many
municipalities
with
CSOs
made
major
structural
changes
to
their
systems
in
the
1980s
and
1990s;
current
improvements
are
more
likely
to
involve
streamlining
operation
and
management.

Many
large
cities
have
already
addressed
a
significant
portion
of
their
CSOs,
but
there
are
additional
smaller
steps
they
can
take
to
reduce
the
amount
of
sewage
released
during
a
wet
weather
event.
These
include
maximizing
in­
line
storage
(
storage
available
in
the
sewer
pipes
themselves)
through
regular
inspection
and
removal
of
obstructions
and
sediment,
installation
and
maintenance
of
flow
regulators,
upgrading
pumping
capacity
(
assuming
the
treatment
plant
can
handle
the
increased
volume);
raising
weirs
at
CSO
outfalls;
and
installing
computerized
sensors
to
control
flow
during
storms.

Additionally,
reducing
inflow
(
entry
of
storm
water
into
the
combined
sewers)
and
infiltration
(
entry
of
storm
water
through
cracks
and
manholes)
is
important.
Inflow
can
be
reduced
by
disconnecting
roof
drains
and
sump
pumps
from
sewers,
restricting
flow
into
storm
drains,
and
constructing
storm
water
detention
ponds
and
infiltration
devices.
If
overflow
events
can
be
reduced,
it
may
be
possible
to
eliminate
some
outfalls.
Some
sewer
systems
also
have
installed
some
treatment
of
CSOs
including
disinfection
and
screening;
this
treatment
may
be
required
as
part
of
a
NPDES
permit.

E.
2.4
Sanitary
Sewer
Overflows
Sanitary
sewer
systems
normally
feed
into
wastewater
treatment
plants
but
can
still
cause
water
quality
problems.
Sanitary
sewer
overflows
(
SSOs)
occur
when
untreated
and
mostly
undiluted
sewage
backs
up
into
basements,
streets,
and
surface
water.
SSOs
discharging
to
surface
water
are
prohibited
under
the
Clean
Water
Act.
Insufficient
maintenance
and
capacity
and
illegal
connections
are
some
of
the
primary
causes
of
SSOs.
Many
sanitary
sewers
are
subject
to
inflow
and
infiltration,
just
as
combined
sewers
are,
caused
by
cracks
in
pipes
or
bad
connections
to
service
lines.
They
may
receive
water
they
were
not
designed
to
receive,
such
as
storm
water
from
roof
drains
that
should
be
connected
to
storm
sewers,
or
wastewater
from
new
developments
that
did
not
exist
when
the
wastewater
treatment
plant
was
designed.
SSOs
can
be
reduced
by
cleaning
and
maintaining
the
sewer
system;
reducing
inflow
and
infiltration
by
repairing
leaking
or
broken
service
lines;
increasing
sewer,
pumping,
and/
or
wastewater
treatment
plant
capacity;
and
constructing
storage
for
excess
wastewater
(
U.
S.
EPA
2001c).
EPA
is
proposing
a
rule
that
will
require
sewer
systems
to
implement
capacity
assurance,
management,
operation,
and
maintenance
programs
and
will
require
public
notification
of
overflow
events.
This
information
will
assist
PWSs
in
addressing
SSO
point
sources.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
10
E.
2.5
Municipal
Separate
Storm
Sewer
Systems
Municipal
separate
storm
sewer
systems
(
MS4s)
in
areas
with
populations
of
more
than
100,000
are
also
required
to
obtain
NPDES
permits.
Information
on
storm
sewer
outfall
locations,
volume
discharged,
conventional
pollutant
loads,
and
existence
of
illicit
discharges
is
submitted
as
part
of
the
permit
application
process
(
U.
S.
EPA
1996).
In
addition,
these
MS4s
must
develop
management
plans
addressing
items
such
as
outfall
monitoring,
structural
and
nonstructural
BMPs
to
be
implemented,
and
identification
and
elimination
of
illicit
discharges.
Illicit
discharges
to
MS4s
include
any
non­
stormwater
discharges,
such
as
discharges
that
should
be
connected
to
sanitary
sewers
(
e.
g.,
water
from
sinks,
floor
drains,
and
occasionally
toilets),
illegal
dumping
of
sewage
from
recreational
vehicles,
sanitary
sewer
overflow
backing
up
through
manhole
covers
into
storm
drains,
effluent
from
failing
septic
systems,
water
from
sump
pumps,
etc.

Small
MS4s
(
serving
areas
with
populations
of
less
than
100,000)
are
subject
to
NPDES
permit
requirements
if
they
are
located
in
"
urbanized
areas"
as
determined
by
the
Bureau
of
the
Census.
Some
small
MS4s
in
urbanized
areas
may
be
eligible
for
waivers
from
the
NPDES
requirement.
Those
MS4s
subject
to
NPDES
permits
must
implement
"
control
measures"
in
six
areas,
including
a
plan
for
eliminating
illicit
discharges
(
U.
S.
EPA
2000b).

PWSs
should
work
with
all
MS4
utilities
in
the
area
of
influence
to
gather
existing
information
about
storm
water
contamination.
MS4
utilities
may
need
to
install
or
retrofit
structural
BMPs,
such
as
retention
ponds,
to
reduce
contamination.
Most
studies
of
structural
stormwater
BMPs
focus
on
nutrient
or
sediment
removal,
so
almost
no
information
is
available
on
Cryptosporidium
removal,
and
limited
information
is
available
on
bacterial
removal.
However,
a
few
studies
of
bacteria
in
structural
BMPs
show
that
bacteria
survive
for
weeks
to
months
in
retention
pond
sediments
and
natural
lake
environments.
In
addition,
other
studies
showed
higher
bacteria
levels
in
retention
pond
effluent
than
in
influent.
This
suggests
that
stormwater
pond
sediments
resuspended
during
storms
can
be
a
source
of
pathogens
(
Schueler
1999).

E.
3
What
BMPs
Can
Help
Alleviate
Nonpoint
Sources?

The
following
sections
describe
BMPs
for
agricultural,
forestry,
and
urban
sources
of
Cryptosporidium.
Your
watershed
control
program
plan
must
discuss
how
these
or
any
other
BMPs
you
choose
will
be
implemented
in
the
area
of
influence.
EPA
Section
319
grants
and
Clean
Water
State
Revolving
Fund
loans
can
be
used
for
nonpoint
sources
and
watershed
management
purposes.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
11
E.
3.1
Agricultural
BMPs
E.
3.1.1
Management
Programs
The
U.
S.
Department
of
Agriculture
(
USDA)
(
2000)
recommends
a
multiple­
barrier
approach
to
controlling
pathogen
transport
and
proliferation
on
farms
and
in
agricultural
watersheds.
It
recommends
the
following
"
control
points:"

°
Preventing
initial
infection
by
controlling
pathogen
import
to
the
farm
°
Controlling
the
reproduction
and
spread
of
the
pathogen
throughout
the
farm
°
Managing
waste
°
Controlling
pathogen
export
from
the
farm
These
control
points
should
not
be
treated
separately.
For
example,
waste
management
affects
reproduction
and
spread
of
the
pathogen
if
feed
becomes
contaminated
with
waste.
Waste
management
is
also
related
to
pathogen
export;
composting
can
kill
Cryptosporidium
oocysts
before
they
leave
the
farm.

BMPs
that
can
reduce
pathogen
loading
include
composting,
waste
management
(
manure
storage
and
land
application),
grazing
management,
feedlot
runoff
diversion,
and
buffer
or
filter
strips.
PWSs
should
work
with
their
local
soil
and
water
conservation
districts
and
agricultural
or
cooperative
extensions,
which
can
help
farmers
design
and
implement
pollution
management
plans
and
BMPs.
Details
about
these
conservation
practices
are
provided
in
the
USDA
Natural
Resources
Conservation
Service's
(
NRCS)
National
Handbook
of
Conservation
Practices
(
NRCS
1999)
at
http://
www.
ftw.
nrcs.
usda.
gov/
nhcp_
2.
html.

Management
strategies
designed
to
minimize
direct
livestock
contamination
of
surface
water
with
Cryptosporidium
should
focus
primarily
on
young
animals
(
those
less
than
3
months
old)
and
their
waste,
since
calves
are
more
likely
to
shed
Cryptosporidium.
Efforts
should
also
focus
on
cow
herds
as
a
whole
when
calves
are
present.

Several
NRCS
programs
provide
technical
assistance
to
farmers
and
subsidize
the
cost
of
implementing
BMPs.
These
include
Agricultural
Management
Assistance,
the
Environmental
Quality
Incentives
Program,
the
Conservation
Reserve
Program,
and
the
Conservation
Reserve
Enhancement
Program
(
see
www.
nrcs.
usda.
gov/
programs).
The
last
two
programs
also
pay
farmers
rent
on
erodible
cropland
taken
out
of
production.
More
information
is
available
at
http://
www.
fsa.
usda.
gov/
dafp/
cepd/
crpinfo.
htm.
The
2002
Farm
Bill
increased
funding
for
these
programs
and
created
new
ones
as
well.
For
example,
the
new
Conservation
Security
Program
will
recognize
and
reward
farmers
who
are
leaders
in
environmental
management.

E.
3.1.2
Composting
Composting
can
effectively
reduce
pathogen
concentrations.
Temperatures
greater
than
55
degrees
Celsius
(
131

F)
can
be
easily
attained
and
maintained
long
enough
to
inactivate
most
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
12
oocysts
(
Blewett
1989).
To
reliably
achieve
Cryptosporidium
inactivation,
however,
the
entire
waste
mass
should
be
uniformly
treated
and
there
should
be
no
cold
spots.
Intense
management
may
be
needed
to
completely
mix
the
composted
material.

E.
3.1.3
Buffer
Strips
Buffer
strips,
or
filter
strips,
provide
a
buffer
between
the
area
of
manure
application
or
grazing
and
adjacent
streams
or
lakes.
Filter
strips
have
been
studied
primarily
with
regard
to
their
effectiveness
at
sediment
and
nutrient
removal.
Nutrient
removal
has
been
shown
to
be
extremely
variable,
while
agricultural
grass
filter
strips
consistently
remove
65
percent
or
more
of
sediment
(
Ohio
State
University
Extension
undated).
How
sediment
removal
relates
to
Cryptosporidium
removal
is
not
known.
Cryptosporidium
often
adsorbs
to
suspended
material
the
size
of
clay
and
silt
particles,
which
is
the
type
of
sediment
that
is
likely
to
pass
through
the
filter
strip,
especially
at
high
flow
velocities.

Few
studies
have
evaluated
the
ability
of
buffer
strips
to
remove
Cryptosporidium.
However,
one
study
found
that
grass
filter
strips
with
slopes
of
20
percent
or
less
and
widths
of
at
least
3
meters
resulted
in
removal
of
1
to
3
log
(
90
to
99.9
percent)
during
mild
to
moderate
precipitation
(
Atwill
et
al.
2002).
More
data
are
available
on
removal
of
bacteria.
Moore
et
al.
(
1988)
reviewed
the
work
of
several
investigators
and
concluded
that
vegetative
filters
are
most
reliable
at
removing
bacteria
at
high
concentrations
from
waste
effluent.
Bacterial
populations
in
runoff
from
buffer
areas
seem
to
equilibrate
at
approximately
104
to
105
organisms
per
100
milliliters,
regardless
of
experimental
conditions.
For
this
reason,
USDA
(
2000)
recommends
that
buffers
and
filter
strips
be
considered
secondary
practices
for
pathogen
control
and
be
used
in
conjunction
with
other
source,
proliferation,
and
waste
treatment
and
control
measures
to
form
an
integrated,
comprehensive
pathogen
management
system.

The
NRCS
encourages
the
use
of
riparian
forest
buffers
of
at
least
35
to
100
feet
(
depending
on
floodplain
width)
for
stream
restoration
purposes
but
recommends
additional
width
in
high
sediment
and
animal
waste
application
areas.
Grass
filter
strips
may
be
added
upgradient
of
the
forest
buffers
or
may
be
used
alone.
The
NRCS
(
1999)
recommends
grass
filter
strip
widths
of
at
least
20
feet,
but
width
should
be
determined
based
on
the
slopes
of
the
strip
and
the
field
being
drained,
the
area
being
drained,
the
erosion
rate,
sediment
grain
size
distribution,
runoff
volume,
and
the
vegetation
in
the
strip.
Filter
strips
should
follow
contours
as
much
as
possible
to
promote
sheet
flow.
The
area
being
drained
should
have
a
slope
of
less
than
10
percent.
Grazing
should
not
generally
be
permitted
within
the
filter
strip.
Maintenance
activities
should
include
mowing
to
prevent
woody
growth,
inspection
after
storm
events,
repair
of
any
gullies,
reseeding
of
disturbed
areas,
and
any
other
steps
needed
to
maintain
overland
sheet
flow.

E.
3.1.4
Grazing
Management
Managed
grazing
can
be
cheaper
and
less
environmentally
damaging
than
confined
feeding
and
unmanaged
grazing.
It
decreases
feed,
herbicide,
equipment,
and
fertilizer
costs,
while
reducing
erosion
and
increasing
runoff
infiltration
and
manure
decomposition
rates
(
Ohio
State
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
13
University
Extension,
undated).
In
managed,
or
rotational,
grazing,
a
sustainable
number
of
cattle
or
other
livestock
graze
for
a
limited
time
(
usually
2­
3
days)
on
each
pasture
before
being
rotated
to
the
next
pasture.
This
allows
vegetation
regrowth
and
prevents
overgrazing,
which
can
contribute
to
erosion
and
runoff,
and
helps
distribute
manure
evenly
over
the
grazed
area.
It
also
prevents
soil
compaction,
thereby
increasing
infiltration.
One
of
the
best
ways
to
prevent
surface
water
contamination
during
rotational
grazing
is
to
prevent
grazing
along
streams
(
through
fencing
and
use
of
a
buffer
strip)
and
to
provide
alternative
water
sources
for
livestock.
Providing
water
in
each
paddock
can
increase
the
number
of
cattle
the
pasture
is
able
to
support.
Even
where
rotational
grazing
is
not
used,
surface
water
contamination
can
be
reduced
by
keeping
cattle,
especially
calves,
out
of
streams.

E.
3.1.5
Manure
Storage
Manure
storage
facilities
allow
farmers
to
wait
until
field
conditions
are
more
suitable
for
land
application.
Without
manure
storage
facilities,
farmers
must
distribute
manure
on
adjacent
fields
daily.
However,
weather
conditions
are
not
always
appropriate
for
manure
application.
During
the
winter,
for
example,
frozen
soil
conditions
allow
Cryptosporidium
oocysts
to
be
washed
into
watercourses,
and
oocysts
survive
longer
at
cold
temperatures.

Manure
storage
facilities
should
be
designed
to
prevent
discharge
through
leaching
or
runoff.
They
should
be
lined
and,
if
possible,
covered.
Facilities
that
are
not
covered
should
be
designed
to
contain
precipitation
and
runoff
from
a
25­
year
24­
hour
storm.
Storage
areas
should
have
embankments
to
prevent
overflow
and
collapse
of
the
storage
facility
and
to
divert
runoff
from
outside
the
facility
from
contamination.
Facilities
should
be
sited
outside
of
flood
plains.
Manure
should
be
stored
for
a
time
period
sufficient
for
microorganisms
to
die
off.

E.
3.1.6
Land
Application
of
Manure
Several
precautions
taken
in
manure
application
can
prevent
runoff
from
entering
surface
water,
reducing
the
likelihood
of
Cryptosporidium
contamination.
Buffer
strips
should
be
situated
between
the
water
body
and
area
of
manure
application.
Manure
should
not
be
applied
to
frozen
ground
or
before
predicted
rainfall.
Manure
should
not
be
applied
near
tile
drains
or
dry
wells
or
to
land
subject
to
flooding.
If
soil
is
dry
and
cracked,
fields
should
be
tilled
before
application.
Soil
and
manure
should
be
tested
for
nutrient
levels,
and
the
application
rate
should
be
tailored
to
the
soil
and
specific
crop
needs.
To
minimize
runoff,
waste
should
be
injected
(
injection
creates
holes
6­
14
inches
deep
and
does
not
turn
soil
over)
or
applied
to
the
surface
and
then
plowed
under.
Applying
manure
to
land
with
crop
residue
or
new
crops
rather
than
bare
soil
also
minimizes
erosion.
Surface
application
without
plowing
under
may
be
acceptable
if
conditions
are
warm
and
dry
 
this
enables
significant
pathogen
die­
off
(
Vendrall
et
al.
1997)
by
exposure
to
UV
light
and
desiccation.
The
Agricultural
Waste
Management
Field
Handbook
(
NRCS
1992),
Chapter
5,
Table
5­
3
contains
a
detailed
review
of
restricting
features
that
should
be
considered
during
manure
spreading.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
14
For
pastures
to
be
used
for
grazing,
waste
should
be
stored
for
at
least
60
days
and
then
applied
at
least
30
days
before
the
scheduled
grazing
period,
to
avoid
infection
of
the
animals.
Use
of
these
areas
for
grazing
should
be
limited
to
mature
animals.
Manure
spreading
on
pastures
used
for
grazing
or
on
hayfields
should
take
place
when
minimal
amounts
of
vegetation
are
present,
just
after
harvesting
or
grazing.
This
allows
sunlight
and
desiccation
to
destroy
the
most
pathogens
and
reduces
the
chance
of
pathogen
adherence
to
the
forage.

Critical
source
areas
are
defined
as
saturated
areas
that
can
expand
and
contract
rapidly,
based
on
soil,
hydrological,
and
slope
characteristics
(
Gburek
and
Poinke
1995).
These
areas
are
dominated
by
saturated
overland
flow
and
rapidly
respond
to
subsurface
flow.
Therefore,
watershed
managers
should
identify
the
boundaries
of
potential
saturated
areas
and
ensure
that
waste
is
only
applied
outside
of
those
boundaries
to
minimize
Cryptosporidium
oocyst
runoff.
Some
tools
have
been
developed
to
delineate
critical
source
areas
(
e.
g.,
Cornell
Soil
Moisture
Routing
Model;
Frankenberger
1999).
Less
detailed
delineations
can
also
be
made
using
information
such
as
soil
drainage
class,
flooding
frequency,
wetland
mapping,
areas
of
concentrated
flow,
and
aerial
photo
interpretations.

E.
3.1.7
Feedlot
Runoff
Diversion
Clean
roof
and
surface
water
can
be
diverted
away
from
feedlots
to
a
drainage
system
that
is
independent
of
a
farm's
waste
management
system
(
Ohio
State
University
Extension
1992).
All
roofs
that
could
contribute
to
feedlot
runoff
should
have
gutters,
downspouts,
and
outlets
that
discharge
away
from
the
feedlot.
Berms
around
the
feedlot
can
divert
surface
runoff.
Diverting
clean
water
before
it
drains
into
the
feedlot
can
significantly
reduce
the
amount
of
wastewater
that
needs
to
be
managed.
Runoff
within
the
feedlot
should
be
contained
and
treated
in
the
waste
management
system
for
the
lot.

E.
3.2
Forestry
BMPs
Forestry
practices
are
not
likely
to
significantly
contribute
to
Cryptosporidium
sources,
since
wildlife
levels
decrease
or,
at
most,
remain
constant
after
logging.
However,
logging
can
cause
increased
erosion,
leading
to
increased
runoff
and
making
it
more
likely
that
Cryptosporidium
present
in
wildlife
will
reach
the
source
water.
In
addition,
logging
can
cause
elevated
sediment
levels,
resulting
in
high
turbidity,
which
affects
water
treatment
efficiency.

Filter
strips,
where
ground
cover
is
maintained
around
lakes,
permanent
and
intermittent
streams,
and
wetlands,
help
trap
sediment.
Filter
strip
width
should
increase
with
slope
of
the
area
being
logged.
Streamside
or
riparian
management
zones
are
intended
to
stabilize
stream
banks
and
maintain
shade
over
streams
to
minimize
water
temperature
fluctuations.
Streamside
management
zones
and
filter
strips
often
overlap,
but
limited
logging
is
often
permitted
within
streamside
management
zones
(
NRCS
1999).
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
15
Logging
roads
should
be
constructed
to
minimize
runoff
through
proper
grading
and
drainage.
Road
runoff
should
be
diverted
away
from
streams
and
prevented
from
channelizing.
Loggers
should
minimize
soil
disturbance
and
compaction
on
skid
trails,
the
trails
used
to
drag
logs
to
trucks
for
loading
(
U.
S.
EPA
2002a).

E.
3.3
Urban/
Suburban
BMPs
See
http://
www.
epa.
gov/
owm/
mtb/
mtbfact.
htm
for
fact
sheets
on
technologies
and
BMPs
municipalities
can
use
to
reduce
contamination
from
wastewater
and
stormwater.

E.
3.3.1
Buffer
Zones
For
watersheds
in
urban
areas,
buffer
zones
help
to
protect
development
on
the
floodplain
from
being
damaged
when
the
water
is
high,
as
well
as
protect
the
stream
from
the
effects
of
the
development.

The
utility,
municipality,
or
cooperating
jurisdictions
may
acquire
land
bordering
the
reservoir
and/
or
its
tributaries.
Alternatively,
buffers
can
be
required
by
zoning
ordinances,
conservation
easements,
or
subdivision
regulations.
Buffer
zones
can
be
fixed
width
or
variable
width.
In
a
fixed­
width
zone,
the
buffer
zone
encompasses
a
certain
distance
from
the
stream
bank
or
some
other
hydrological
reference
point
(
e.
g.,
the
high
water
mark
of
a
stream).
The
widths
of
fixed
buffer
zones
vary
considerably
among
water
sources,
frequently
ranging
from
50
feet
to
250
feet
of
buffer
from
the
stream
edge.
Another
form
of
buffer
zone,
the
variablewidth
buffer,
can
vary
in
width
depending
on
the
hydrological
sensitivity,
stream
size,
and
character
of
the
land
adjacent
to
the
watercourse.

Considerations
for
developing
local
buffer
requirements
are
the
size
and
location
of
the
stream,
the
nature
of
existing
or
potential
development,
and
the
financial
and
political
feasibility
of
establishing
protected
zones
around
the
streams
and
reservoir
of
the
watershed.
Although
buffer
zones
have
been
found
to
trap
fecal
waste
(
Coyne
and
Blevins
1995;
Young
et
al.
1980),
the
extent
to
which
they
reduce
Cryptosporidium
loading
is
not
well
understood.
For
this
reason,
buffer
zones
should
be
used
to
augment,
rather
than
replace,
other
watershed
management
practices
to
help
protect
overall
source
water
quality.

Buffer
zones
should
be
routinely
inspected
to
ensure
that
sources
of
contamination
have
not
been
introduced
to
the
area
and
that
the
buffer
is
being
maintained
(
e.
g.,
that
buffers
are
kept
unmowed).
Watershed
managers
should
also
be
aware
of
storm
sewers
and
culverts
that
may
be
draining
into
the
waterways
and
bypassing
the
buffer
zones
altogether.

E.
3.3.2
Dry
Detention
Basins
Dry
detention
basins
temporarily
store
stormwater
runoff
and
release
the
water
slowly
to
allow
for
settling
of
particulates
and
the
reduction
of
peak
flows.
These
structures
hold
a
certain
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
16
amount
of
water
from
a
storm
and
release
the
water
through
a
controlled
outlet
over
a
specified
time
period
based
on
design
criteria.
Most
basins
dry
out
completely
between
storm
events.
The
major
failure
of
these
basins
is
that
some
are
not
designed
or
maintained
properly,
resulting
in
too
slow
a
release
of
water
to
empty
the
basin
before
the
next
storm.
If
the
basin
remains
partially
full,
only
a
portion
of
the
design
runoff
volume
from
the
next
storm
will
be
retained.
With
inadequate
detention,
pollutants
are
not
removed
from
the
runoff.
Dry
detention
basins
also
risk
the
possibility
of
resuspension
of
pathogens
from
the
basin
sediments
if
hydraulic
retention
times
are
compromised
by
poor
design
or
failure
to
keep
the
outlets
open.

E.
3.3.3
Infiltration
Devices
Infiltration
devices
remove
pathogens
and
particles
by
adsorption
onto
soil
particles
and
filtration
as
the
water
moves
through
the
soil
to
the
ground
water.
Infiltration
devices
include
infiltration
basins,
infiltration
trenches,
and
dry
wells
(
NALMS
2000).
Properly
designed
devices
can
reproduce
hydrological
conditions
that
existed
before
urban
development,
and
provide
ground
water
recharge
and
control
of
peak
storm
water
flows.
In
order
for
them
to
function
effectively,
infiltration
devices
must
be
used
only
where
the
soil
is
porous
and
can
readily
absorb
storm
water
at
an
adequate
rate.
An
advantage
of
infiltration
devices
over
many
other
urban
BMPs
is
that
they
provide
significant
ground
water
recharge
in
areas
with
a
high
percentage
of
impervious
surface.

E.
3.3.4
Sand
Filters
Sand
filters
can
be
used
to
treat
storm
water
runoff
from
large
buildings
and
parking
lots.
As
the
name
implies,
storm
water
is
filtered
through
beds
of
sand,
which
may
be
located
above
ground
in
self­
contained
beds,
or
can
be
installed
underground
in
trenches
or
concrete
boxes.
Underground
sand
filters
can
be
installed
in
urban
settings
where
space
is
restricted
and
the
filters
are
not
visible.
Pathogens
and
particles
are
removed
by
filtering
storm
water
through
approximately
18
inches
of
sand.
Above­
ground
filters
may
be
preceded
by
grassed
filter
strips
or
swales
to
pre­
treat
the
incoming
storm
water
and
prevent
the
sand
filters
from
clogging.

Sand
filters
are
often
more
expensive
to
construct
than
infiltration
trenches
(
NALMS
2000).
They
do
not
provide
a
significant
amount
of
storm
water
detention,
and
their
ability
to
remove
pathogens
is
limited.
They
require
little
maintenance;
the
sand
surface
should
be
raked
and
a
few
inches
of
dirty
sand
on
the
filter
surface
should
be
removed
and
replaced
periodically,
so
that
the
filters
do
not
clog.

E.
3.3.5
Wet
Retention
Ponds
Wet
retention
ponds
maintain
a
permanent
pool
of
water
that
is
augmented
by
storm
water
runoff.
The
ponds
fill
with
storm
water,
which
they
slowly
release
over
several
days
until
the
pond
returns
to
its
normal
depth.
Ponds
can
effectively
reduce
suspended
particles
and,
presumably,
some
pathogens,
by
settling
and
biological
decomposition.
There
is
concern,
however,
that
ponds
attract
wildlife
that
may
contribute
additional
fecal
pollution
to
the
water,
rather
than
reducing
contamination.
Bacteria
may
also
survive
in
pond
sediment.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
17
Many
people
find
wet
ponds
aesthetically
pleasing,
and
welcome
their
use
for
storm
water
control.
Some
maintenance
of
the
ponds
is
required
in
order
for
them
to
continue
to
function
effectively
and
to
avoid
nuisance
odors
and
insect
problems.
Wetland
plants
should
be
periodically
harvested,
and
the
pond
inlets
and
outlets
should
be
kept
clear
so
that
flow
is
not
impeded.
Wet
ponds
can
be
an
appealing
play
area
for
children,
so
safety
measures
should
also
be
taken
to
restrict
access..

E.
3.3.6
Constructed
Wetlands
Constructed
subsurface
flow
wetlands
(
where
wetland
plants
are
not
submerged)
can
reduce
Cryptosporidium
and
bacteria
concentrations
in
wastewater
(
Thurston
et
al.
2001).
Subsurface
flow
prevents
the
public
from
coming
into
contact
with
wastewater
and
prevents
mosquitos
problems.
Wetlands
may
also
be
useful
for
treating
storm
water
or
other
polluted
water.
However,
the
matrix
material
of
a
constructed
subsurface
flow
wetland
(
gravel
is
often
used)
may
provide
an
environment
for
bacterial
growth,
and
animals
living
in
the
wetlands
may
contribute
microbes
to
the
effluent
(
Thurston
et
al.
2001).
Animals
are
probably
less
significant
than
they
would
be
in
a
free
water
surface
wetland.
The
growth
of
bacteria
in
the
wetland
medium
is
both
positive
and
negative
 
bacteria
that
help
break
down
materials
in
wastewater
are
more
plentiful,
but
fecal
coliform
also
can
survive
in
such
environments.
Constructed
wetlands
are
relatively
inexpensive
often
used
on
small
scales
to
treat
water
at
small
facilities
such
as
schools,
apartment
complexes,
and
parks
(
U.
S.
EPA
2000c).

E.
3.3.7
Runoff
Diversion
As
with
feedlot
runoff
diversion,
structures
can
be
installed
in
more
urban
settings
to
divert
clean
water
flow
before
it
reaches
a
contamination
source.
Structures
that
channel
runoff
away
from
contamination
sources
include
stormwater
conveyances
such
as
swales,
gutters,
channels,
drains,
and
sewers.
Graded
surfaces
can
also
be
used
to
re­
direct
sheet
flow,
and
diversion
dikes
or
berms
can
be
installed
to
route
sheet
flow
around
areas
that
are
being
protected
from
runoff.

E.
3.3.8
Pet
Waste
Management
Municipalities
can
implement
pet
waste
management
programs
to
encourage
pet
owners
to
properly
collect
and
dispose
of
their
animals'
waste.
Many
communities
have
pet
waste
ordinances
that
require
pet
owners
to
clean
up
after
their
pets
on
public
property
or
anywhere
outside
their
own
yards;
however,
compliance
is
limited,
and
enforcement
is
usually
not
a
priority.
In
addition,
most
ordinances
do
not
require
pet
owners
to
clean
up
pet
waste
in
their
own
yards
(
this
problem
can
usually
be
addressed,
though
only
reactively,
through
nuisance
or
pet
neglect
laws).
Some
communities
have
ordinances
that
govern
the
cleanup
process
by
requiring
disposal
of
pet
waste
with
regular
trash,
burial,
or
flushing
it
down
the
toilet.
Enforcement
of
these
ordinances
with
fines
for
noncompliance
is
probably
the
best
way
to
increase
compliance.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
18
To
increase
public
awareness
about
pet
waste,
you
can
distribute
educational
materials
through
emails,
letters,
public
service
announcements,
and
signs.
Posting
is
the
most
common
outreach
strategy
for
managing
pet
waste.
Pet
waste
stations
containing
waste
receptacles
for
public
use
are
another
popular
solution.
Public
works
departments
have
also
formed
voluntary
commitment
and
partnership
programs
with
pet
owners
and
local
pet
stores
in
the
community
to
promote
good
pet
waste
management.

E.
3.3.9
Water
Conservation
Water
conservation
is
usually
presented
as
a
practice
that
can
help
preserve
the
amount
of
water
available
for
use,
especially
in
times
of
drought.
However,
water
conservation
can
also
decrease
the
amount
of
wastewater
and
stormwater
generated,
thereby
protecting
the
quality
of
the
water
supply
(
U.
S.
EPA
2002b).
Use
of
low­
flow
toilets
and
showerheads,
for
example,
can
allow
wastewater
treatment
plants
to
treat
wastewater
from
more
customers
without
having
to
increase
capacity,
reducing
the
occurrence
of
combined
or
sanitary
sewer
overflows.
The
reduced
load
on
wastewater
treatment
plants
can
also
decrease
the
need
for
rate
increases.
Reducing
lawn
watering
decreases
the
amount
of
runoff
entering
storm
sewers,
combined
sewers,
and
surface
water.

E.
3.3.10
Low
Impact
Development
Low
impact
development,
or
better
site
design,
is
a
watershed
practice
that
reduces
pollutant
loads,
conserves
natural
areas,
saves
money,
and
increases
property
values
(
Center
for
Watershed
Protection
1999).
A
fundamentally
different
approach
to
residential
and
commercial
development,
site
design
tries
to
reduce
the
amount
of
impervious
cover,
increase
natural
lands
set
aside
for
conservation,
and
use
pervious
areas
for
more
effective
stormwater
treatment.
Low
impact
development
involves
changing
traditional
practices
for
residential
street
and
parking
lot
design,
lot
development,
and
conservation
of
natural
areas.
Some
specific
steps
for
better
site
design
include
the
following
(
Center
for
Watershed
Protection
1999):

°
Design
residential
streets
based
on
the
minimum
width
needed
to
support
travel
lanes,
on­
street
parking,
and
emergency
and
maintenance
vehicle
access.
For
example,
a
street
with
single
family
houses
with
driveways
does
not
need
two
lanes
for
parking.
Construct
sidewalks
on
only
one
side
of
the
street.
°
Minimize
the
number
of
cul­
de­
sacs.
Where
cul­
de­
sacs
are
built,
place
landscaped
islands
to
reduce
their
impervious
cover.
°
Advocate
open
space
or
cluster
design
subdivisions
on
smaller
lots.
°
Reduce
imperviousness
by
promoting
alternative
driveway
surfaces
and
shared
driveways
that
connect
two
or
more
homes
together.
Reduce
driveway
length
by
allowing
decreased
front
setbacks.
°
Direct
rooftop
runoff
to
pervious
areas
such
as
yards,
open
channels,
or
vegetated
areas
rather
than
the
roadway
and
stormwater
sewers.
Better
yet,
install
open
vegetated
channels
instead
of
storm
sewers.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
19
°
Reduce
the
imperviousness
and
size
of
parking
lots
by
minimizing
stall
dimensions,
incorporating
efficient
parking
lanes,
and
using
pervious
materials
in
the
spillover
parking
areas
where
possible.
Use
lower
parking
ratios
where
possible
(
e.
g.,
where
mass
transit
is
available
and
codes
permit).
°
Provide
stormwater
treatment
for
parking
lot
runoff
using
bioretention
areas,
filter
strips,
and/
or
other
practices.
°
Create
a
naturally
vegetated
buffer
system
along
all
perennial
streams
that
encompasses
critical
environmental
features
such
as
the
100­
year
floodplain,
steep
slopes,
and
wetlands.
°
Clearing
and
grading
of
forests
and
native
vegetation
at
a
site
should
be
limited
to
the
minimum
amount
needed
to
build
lots,
allow
access,
and
provide
fire
protection.
Specify
a
party
legally
responsible
for
maintaining
the
vegetated
area.

Some
aspects
of
low
impact
development
may
be
prohibited
outright
under
traditional
zoning
and
development
regulations,
so
low
impact
development
practices
may
need
to
be
codified.
Where
such
practices
remain
voluntary
or
require
exemptions
from
existing
regulations,
water
systems
should
work
with
local
planners
to
encourage
the
switch
to
better
site
design.

E.
3.3.11
Septic
Systems
Failing
septic
systems
can
be
a
major
source
of
microbial
contamination
in
a
watershed.
Poor
placement
of
leachfields
can
feed
partially
treated
waste
directly
into
a
drinking
water
source.
Poorly
constructed
percolation
systems
may
allow
wastewater
to
escape
before
it
has
been
properly
treated.
Failing
systems
can
result
in
clogging
and
overflow
of
waste
onto
land
or
into
surface
water.

Most
septic
system
regulations
require
construction
permits
and
an
inspection
before
the
system
begins
operating,
but
few
require
any
follow­
up.
Where
failing
systems
are
a
serious
problem
or
are
close
to
a
drinking
water
source,
however,
some
municipalities
have
maintenance
or
inspection
requirements.
For
example,
the
Portland
(
Maine)
Water
District
requires
permits
for
all
septic
systems
within
200
feet
of
Sebago
Lake,
its
primary
source
(
U.
S.
EPA
1999a).
These
septic
systems
are
subject
to
regular
inspection
and
may
face
stricter
design
requirements
than
systems
outside
the
boundary.
Portland
also
has
the
authority
to
inspect
systems
within
1,000
feet
of
Sebago
Lake
tributaries.
Similarly,
the
Onondaga
County
Water
Authority
in
New
York
visually
inspects
every
septic
system
in
the
water
system
annually.
Every
three
years
each
septic
system
is
subject
to
a
dye
tracer
test.
Enforcement
cases
are
referred
to
the
county
health
department
(
U.
S.
EPA
1999a).

Although
water
systems
rarely
have
enforcement
authority
over
septic
systems,
they
should
work
closely
with
the
local
regulatory
authority
to
ensure
that
septic
system
codes
are
being
properly
enforced
and
to
strengthen
codes
where
necessary.
Utilities
should
also
encourage
residents
with
septic
systems
in
the
watershed
to
understand
their
systems
and
the
proper
maintenance
that
their
systems
require.
Home*
A*
Syst
programs
run
by
many
state
cooperative
extensions
provide
educational
material
and
checklists
for
septic
system
owners
about
proper
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
20
siting
and
maintenance.
Utilities
may
also
want
to
encourage
residents
to
hook
up
to
a
sanitary
sewer
system
where
feasible.
Clean
Water
State
Revolving
Fund
loans,
USDA
Rural
Utilities
Service
funds,
and
Department
of
Housing
and
Urban
Development
Community
Development
Block
Grants
are
available
for
septic
system
rehabilitation
or
replacement.
Individual
homeowners
may
be
eligible
for
some
of
these
loans
(
U.
S.
EPA
1999b).
Some
of
these
funds
may
also
be
used
to
build
centralized
wastewater
treatment.

E.
3.3.12
Wildlife
BMPs
Steps
taken
to
prevent
wildlife
from
contaminating
source
water
vary
with
the
source
and
type
of
wildlife.
Some
reservoirs
and
lakes
employ
boats
with
noisemakers
to
scare
seagulls
and
geese
away.
Many
systems
with
control
of
the
land
around
their
reservoirs
place
fences
on
the
water's
edge
to
keep
out
larger
land
animals
and
humans.
To
keep
geese
from
feeding
along
the
river
bank
just
upstream
from
one
of
its
intakes,
the
Philadelphia
Water
Department
planted
a
riparian
buffer
and
wildflower
meadow
and
conducted
a
public
education
program
to
prevent
people
from
feeding
the
geese
(
Philadelphia
Water
Department
2003).
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
21
References
Atwill,
E.
R.,
L.
Hou,
B.
M.
Karle,
T.
Harter,
K.
W.
Tate,
and
R.
A.
Dahlgren.
2002.
Transport
of
Cryptosporidium
parvum
oocysts
through
vegetated
buffer
strips
and
estimated
filtration
efficiency.
Appl.
Environ.
Microbiol.
68(
11):
5517­
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AWWARF.
1991.
Effective
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Robbins,
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L.
Glicker,
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and
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Gburek,
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and
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B.
Pionke.
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strategies
for
land­
based
disposal
of
animal
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pp.
313­
323.
In
K.
Steele
(
ed.),
Animal
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and
the
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77­
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Lewis
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CRC
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Metcalf
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Moore,
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et
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waste
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Special
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817.
Agricultural
Experimental
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Oregon
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and
the
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S.
D.
A.,
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Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
22
MWRD.
1999.
Tunnel
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il.
us/
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Last
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6,
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Best
Management
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NRCS.
1999.
National
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Natural
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http://
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gov/
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NRCS.
1992.
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Ohio
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Ohio
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edu/
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March
2003.

Ohio
State
University
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No
date.
Vegetation
Filter
Strips:
Application,
Installation,
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AEX­
467­
94.
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edu/
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2003.

Ohio
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date.
Getting
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Edited
by
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http://
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Philadelphia
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2003.
Philadelphia
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htm#
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Schueler,
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Thurston,
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S.
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Waterborne
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U.
S.
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National
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Elimination
System
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12.

U.
S.
EPA
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Source
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Managing
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Source
Pollution
from
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EPA
841­
F­
96­
004H.
Office
of
Wetlands,
Oceans,
and
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
23
Watersheds.
www.
epa.
gov/
owow/
nps/
facts/
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htm.
Last
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August
28,
2002.
Website
accessed
March
2003.

U.
S.
EPA.
2002b.
Public
Education
and
Outreach
on
Storm
Water
Impacts:
Water
Conservation
Practices
for
Homeowners.
http://
cfpub.
epa.
gov/
npdes/
stormwater/
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edu_
13.
cfm.
Last
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November
25,
2002.
Downloaded
December
10,
2002.

U.
S.
EPA.
2001a.
Proposed
Revisions
to
CAFO
Regulations
(
January
12,
2001;
66
FR
2960):
Frequently
Asked
Questions.
http://
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epa.
gov/
npdes/
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faq.
pdf.
Downloaded
February,
2002.

U.
S.
EPA.
2001b.
Secondary
Treatment
Standards.
http://
cfpub.
epa.
gov/
npdes/
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cfm?
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15.
Last
updated
February
21,
2001.
Downloaded
January
22,
2002.

U.
S.
EPA
2001c.
Sanitary
Sewer
Overflows
Frequently
Asked
Questions.
Office
of
Wastewater
Management.
Web
page
updated
March
20,
2001.
http://
cfpub.
epa.
gov/
npdes/
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cfm?
program_
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4.
Website
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January
2002.

U.
S.
EPA.
2000a.
Wastewater
Technology
Fact
Sheet:
Granular
Activated
Carbon
Adsorption
and
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Office
of
Water.
EPA
832­
F­
00­
017.
September.
http://
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epa.
gov/
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pdf.

U.
S.
EPA
2000b.
Storm
Water
Phase
II
Final
Rule:
Small
MS4
Storm
Water
Program
Overview.
Fact
Sheet
2.0.
Office
of
Water.
EPA
833­
F­
00­
002.
www.
epa.
gov/
npdes/
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0.
pdf
Website
accessed
March
2003.

U.
S.
EPA
2000c.
Wastewater
Technology
Fact
Sheet.
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Office
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http://
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gov/
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pdf.
Website
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2003.

U.
S.
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Protecting
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Office
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gov/
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pdf.
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December
10,
2002.

U.
S.
EPA
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Funding
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the
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EPA
832­
F­
99­
001.
4
pages.
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2003.

U.
S.
EPA
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Sewer
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Separation.
Office
of
Water.
EPA
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F­
99­
041.
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http://
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gov/
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Website
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March
2003.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
24
U.
S.
EPA.
1996.
Overview
of
the
Storm
Water
Program.
Office
of
Water.
EPA
833­
R­
96­
008.
June.
42
pp.
www.
epa.
gov/
npdes/
pubs/
owm0195.
pdf.
Website
accessed
March
2003.

U.
S.
EPA.
1994.
Combined
Sewer
Overflow
(
CSO)
Policy;
Notice.
Federal
Register
59(
75):
18688­
18698.
April
19.

Vendrall,
P.
F.,
K.
A.
Teague,
and
D.
W.
Wolf.
1997.
Pathogen
indicator
organism
die­
off
in
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ASA
Annual
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Anaheim,
CA.

Young,
R.
A.
et
al.
1980.
Effectiveness
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in
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from
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487.
Appendix
E
­
Watershed
Control
Best
Management
Practices
LT2ESWTR
Toolbox
Guidance
Manual
Proposal
Draft
June
2003
E­
25
E.
1
Regulatory
and
Other
Management
Strategies
.
.
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.
E­
1
E.
1.1
Determining
Authority
to
Regulate
.
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E­
1
E.
1.2
Zoning
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E­
2
E.
1.3
Land
Acquisition
and
Conservation
Easements
.
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E­
5
E.
2
Addressing
Point
Sources
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E­
6
E.
2.1
Concentrated
Animal
Feeding
Operations
.
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E­
6
E.
2.2
Wastewater
Treatment
Plants
.
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.
E­
6
E.
2.3
Combined
Sewer
Overflows
.
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E­
7
E.
2.4
Sanitary
Sewer
Overflows
.
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E­
8
E.
2.5
Municipal
Separate
Storm
Sewer
Systems
.
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E­
9
E.
3
What
BMPs
Can
Help
Alleviate
Nonpoint
Sources?
.
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E­
9
E.
3.1
Agricultural
BMPs
.
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E­
10
E.
3.1.1
Management
Programs
.
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E­
10
E.
3.1.2
Composting
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E­
11
E.
3.1.3
Buffer
Strips
.
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E­
11
E.
3.1.4
Grazing
Management
.
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E­
12
E.
3.1.5
Manure
Storage
.
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E­
12
E.
3.1.6
Land
Application
of
Manure
.
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E­
12
E.
3.1.7
Feedlot
Runoff
Diversion
.
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E­
13
E.
3.2
Forestry
BMPs
.
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E­
13
E.
3.3
Urban/
Suburban
BMPs
.
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E­
14
E.
3.3.1
Buffer
Zones
.
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E­
14
E.
3.3.2
Dry
Detention
Basins
.
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E­
15
E.
3.3.3
Infiltration
Devices
.
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E­
15
E.
3.3.4
Sand
Filters
.
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E­
15
E.
3.3.5
Wet
Retention
Ponds
.
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E­
16
E.
3.3.6
Constructed
Wetlands
.
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E­
16
E.
3.3.7
Runoff
Diversion
.
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E­
16
E.
3.3.8
Pet
Waste
Management
.
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.
E­
17
E.
3.3.9
Water
Conservation
.
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E­
17
E.
3.3.10
Low
Impact
Development
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E­
17
E.
3.3.11
Septic
Systems
.
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.
E­
18
E.
3.3.12
Wildlife
BMPs
.
.
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E­
19
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