DEVELOPMENT DOCUMENT FOR FINAL 

EFFLUENT GUIDELINES AND STANDARDS FOR 

THE CONSTRUCTION & DEVELOPMENT 

CATEGORY 

NOVEMBER 2009 
U.S. Environmental Protection Agency 

Office of Water (4303T) 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 
Disclaimer 

Neither the United States government nor any of its employees, contractors, subcontractors, or 

other employees makes any warranty, expressed or implied, or assumes any legal liability or 

responsibility for any third party’s use of, or the results of such use of, any information, 

apparatus, product, or process discussed in this report, or represents that its use by such a third 

party would not infringe on privately owned rights. References to proprietary technologies are 

not intended to be an endorsement by the U.S. Environmental Protection Agency. 
iv 

Contents 

Volume I 

1. Overview................................................................................................................................ 1-1 

1.1. Introduction................................................................................................................ 1-1 

1.2. Summary and Scope of the Final Rule ...................................................................... 1-1 

2. Background............................................................................................................................ 2-1 

2.1. Legal Authority.......................................................................................................... 2-1 

2.2. Clean Water Act......................................................................................................... 2-1 

2.2.1. Best Practicable Control Technology Currently Available ................................. 2-1 

2.2.2. Best Conventional Pollutant Control Technology ............................................... 2-2 

2.2.3. Best Available Technology Economically Achievable ....................................... 2-2 

2.2.4. New Source Performance Standards.................................................................... 2-3 

2.2.5. Pretreatment Standards for Existing Sources and Pretreatment Standards for 

New Sources ........................................................................................................ 2-3 

2.2.6. Effluent Guidelines Schedule and Previous Actions Related to Construction 

and Development ................................................................................................. 2-3 

2.2.7. NPDES Phase I and II Stormwater Rules............................................................ 2-4 

2.3. Pollution Prevention Act of 1990 .............................................................................. 2-6 

2.4. State Regulations ....................................................................................................... 2-6 

3. Data Collection ...................................................................................................................... 3-1 

3.1. Introduction................................................................................................................ 3-1 

3.2. Literature Search........................................................................................................ 3-1 

3.3. Data and Information Provided in Response to the 2002 Regulatory Action and 

the 2008 Proposal....................................................................................................... 3-1 

3.4. Compilation of State Control Strategies, Criteria, and Standards ............................. 3-1 

3.5. Other Data Sources .................................................................................................... 3-2 

3.5.1. Land Use Data...................................................................................................... 3-2 

3.5.2. NPDES Permit Notice of Intent Data ................................................................ 3-11 

3.5.3. Climatic/Rainfall Data ....................................................................................... 3-11 

3.5.4. Soils Data........................................................................................................... 3-17 

3.5.5. Vendor Data for Active Treatment Systems...................................................... 3-17 

3.5.6. Rainfall and Runoff Erosivity Factor................................................................. 3-18 

3.5.7. Hydrologic Soil Groups ..................................................................................... 3-18 

3.6. References................................................................................................................ 3-21 

4. Industry Profile ...................................................................................................................... 4-1 

4.1. Introduction................................................................................................................ 4-1 

4.2. Industry Practices and Trends.................................................................................... 4-6 

4.2.1. Overview of Construction Land-Disturbing Activities........................................ 4-6 

4.2.2. Construction Site Size Categories and Estimates of Amount of Disturbed 

Land ..................................................................................................................... 4-8 

4.3. References................................................................................................................ 4-10 

5. Selection of Pollutants for Regulation ................................................................................... 5-1 

5.1. Introduction................................................................................................................ 5-1 
v 

5.2. Pollutants Associated with Construction and Land Development Stormwater 

Runoff ........................................................................................................................ 5-1 

5.2.1. Sediment .............................................................................................................. 5-1 

5.2.2. Metals................................................................................................................... 5-3 

5.2.3. PAHs, and Oil and Grease ................................................................................... 5-4 

5.2.4. Pathogens ............................................................................................................. 5-4 

5.3. Selection of Pollutants for Regulation ....................................................................... 5-4 

5.4. References.................................................................................................................. 5-5 

6. Limitations and Standards: Data Selection and Calculation.................................................. 6-1 

6.1. Introduction................................................................................................................ 6-1 

6.2. Turbidity .................................................................................................................... 6-1 

6.3. Overview of Data Review and Criteria...................................................................... 6-2 

6.4. Data Selected as Basis for Limitations ...................................................................... 6-3 

6.4.1. Cascade EcoSolutions.......................................................................................... 6-4 

6.4.2. Clear Water Compliance Services, Inc. ............................................................... 6-5 

6.4.3. Research by North Carolina State University...................................................... 6-5 

6.5. Systems Excluded as Basis for Limitation................................................................. 6-5 

6.6. Application of Criteria to Limitation Data Sets......................................................... 6-6 

6.7. Summary of Limitation Data and Data Conventions................................................. 6-9 

6.8. Data Averaging Prior to Limitation Calculations.................................................... 6-10 

6.9. Limitation Calculations............................................................................................ 6-11 

6.9.1. Statistical Percentile Basis for Limitations........................................................ 6-11 

6.9.2. Long-Term Average........................................................................................... 6-12 

6.9.3. Variability Factor............................................................................................... 6-13 

6.9.4. Calculation of the Limitation............................................................................. 6-15 

6.9.5. Limitation Includes Autocorrelation Adjustment .............................................. 6-15 

6.10. Statistical and Engineering Review of Limitation................................................... 6-17 

6.10.1. Performance Data for Model Technology Compared to Limitation.................. 6-17 

6.10.2. Performance of Other Treatment Systems Relative to Model Technology....... 6-19 

6.10.3. Performance of Model Technology for Gold Placer Mining Wastes ................ 6-21 

6.10.4. Limitation is Consistent with State Action Levels ............................................ 6-22 

6.11. Monitoring Considerations ...................................................................................... 6-22 

6.12. Compliance .............................................................................................................. 6-23 

6.13. Summary of Steps Used to Derive the Limitations ................................................. 6-25 

6.14. References................................................................................................................ 6-26 

7. Technology Assessment......................................................................................................... 7-1 

7.1. Review of Historical Approaches to Erosion and Sediment Control (ESC) ............. 7-1 

7.2. Control Techniques.................................................................................................... 7-3 

7.2.1. Erosion Control and Prevention........................................................................... 7-3 

7.2.2. Water Handling Practices .................................................................................. 7-26 

7.2.3. Sediment-Trapping Devices............................................................................... 7-44 

7.2.4. Other Control Practices...................................................................................... 7-68 

7.2.5. Advanced Treatment and Control Technologies ............................................... 7-87 

7.3. References................................................................................................................ 7-97 

8. BCT Cost-Reasonableness Assessment................................................................................. 8-1 

8.1. Background on the BCT Cost Test ............................................................................ 8-1 
vi 

8.2. Options Evaluated for BCT ....................................................................................... 8-2 

8.2.1. Option 1 ............................................................................................................... 8-2 

8.2.2. Option 2 ............................................................................................................... 8-2 

8.2.3. Option 3 ............................................................................................................... 8-2 

8.2.4. Option 4 ............................................................................................................... 8-2 

8.3. Calculation of the BCT Cost Test.............................................................................. 8-2 

8.4. References.................................................................................................................. 8-4 

9. Estimating Incremental Costs for the Final Regulation......................................................... 9-1 

9.1. Overview.................................................................................................................... 9-1 

9.2. Development of Model Construction Sites and Estimating Treatment Volumes...... 9-2 

9.2.1. Model Construction Sites..................................................................................... 9-2 

9.2.2. Estimation of Rainfall Depths and Storage Volumes .......................................... 9-3 

9.2.3. Estimation of ATS Treatment Volumes .............................................................. 9-4 

9.3. Estimation of Costs.................................................................................................. 9-19 

9.3.1. Erosion and Sediment Control Costs ................................................................. 9-19 

9.3.2. Passive Treatment Costs .................................................................................... 9-25 

9.3.3. ATS Costs .......................................................................................................... 9-33 

9.4. References................................................................................................................ 9-39 

10. Estimating Pollutant Load Reductions................................................................................. 10-1 

10.1. Overview of Approach............................................................................................. 10-1 

10.2. Model Project Analysis............................................................................................ 10-1 

10.3. Model Parameter and Loads Estimation.................................................................. 10-2 

10.3.1. LS Factor............................................................................................................ 10-6 

10.3.2. P Factor .............................................................................................................. 10-7 

10.3.3. C Factor.............................................................................................................. 10-8 

10.3.4. Runoff Volume Estimates................................................................................ 10-10 

10.4. Load Estimation..................................................................................................... 10-12 

10.5. Results.................................................................................................................... 10-13 

10.6. References.............................................................................................................. 10-21 

11. Non-Water Quality Environmental Impacts ........................................................................ 11-1 

11.1. Energy Requirements............................................................................................... 11-1 

11.1.1. Energy Requirements Attributable to the Regulatory Options.......................... 11-1 

11.1.2. Treatment Chemical Production ........................................................................ 11-3 

11.1.3. Comparison of Option Energy Requirements to Construction Industry............ 11-4 

11.2. Air Emissions Impacts ............................................................................................. 11-5 

11.3. Solid Waste Generation ........................................................................................... 11-6 

11.4. References................................................................................................................ 11-6 

Volume II-a 

Appendix A: Summary of State Construction and Development Requirements........................ A-1 

Appendix B: Literature Search Annotated Bibliography.............................................................B-1 

Appendix C: Analysis of Construction Industry Trends Using Notice of Intent Records...........C-1 

Appendix D: Precipitation Data Representative of Major U.S. Metropolitan Areas.................. D-1 

Appendix E: Determination of Development Rates in U.S. Watersheds ....................................E-1 
vii 

Volume II-b 

Appendix F: Turbidity Report Tables..........................................................................................F-1 

Appendix G: Lognormal Distribution Used for Site-Specific, Long-Term Averages and 

Variability Factors ................................................................................................................ G-1 

Appendix H: Regional Rainfall/Runoff Information Representative of Major U.S. 

Metropolitan Areas ............................................................................................................... H-1 

Appendix I: Model Project Costs for Regulatory Options............................................................I-1 

Figures 

Figure 3-1. NLCD 1992/2001 land cover change product near Seattle, Washington. ................ 3-3 

Figure 3-2. EPA Region 1: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-5 

Figure 3-3. EPA Region 2: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-6 

Figure 3-4. EPA Region 3: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-6 

Figure 3-5. EPA Region 4: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-7 

Figure 3-6. EPA Region 5: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-7 

Figure 3-7. EPA Region 6: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-8 

Figure 3-8. EPA Region 7: Percent urban change 1992–2001 by ERF1_2 Watershed............... 3-8 

Figure 3-9. EPA Region 8: Percent urban change 1992–2001 by ERF1_2 watershed................ 3-9 

Figure 3-10. EPA Region 9: Percent urban change 1992–2001 by ERF1_2 watershed.............. 3-9 

Figure 3-11. EPA Region 10: Percent urban change 1992–2001 by ERF1_2 watershed.......... 3-10 

Figure 3-12. Average annual precipitation in the CONUS from PRISM.................................. 3-16 

Figure 3-13. An example of Washington State RF1 watershed showing urban weighting 

emphasizes MUID: WA189, while area-weighting would have enhanced MUID 

WA194........................................................................................................................... 3-17 

Figure 3-14. Annual R factor values for CONUS...................................................................... 3-19 

Figure 7-1. General ATS batch-operating mode........................................................................ 7-88 

Figure 7-2. Flow-through ATS operating mode ........................................................................ 7-89 

Tables 

Table 3-1. State and national estimates of urban land from NLCD............................................. 3-4 

Table 3-2. EPA Region indicator cities ..................................................................................... 3-12 

Table 3-3. Rainfall summary data for indicator cities ............................................................... 3-14 

Table 3-4. HSGs by state ........................................................................................................... 3-20 

Table 4-1. 2007 NAICS subsectors, industry groups, and industries performing 

construction activities that might disturb land................................................................. 4-3 

Table 4-2. 1987 SIC industry groups performing construction activities that might disturb 

land................................................................................................................................... 4-5 

Table 4-3. Model project distribution ........................................................................................ 4-10 

Table 5-1. Studies of uncontrolled soil erosion as TSS from construction sites......................... 5-3 

Table 6-1. Data sources and site identification for systems using EPA’s model technology 

basis.................................................................................................................................. 6-4 

Table 6-2. Systems Excluded as Basis for Limitation ................................................................. 6-6 
viii 

Table 6-3. Summary of reported turbidity measurements (NTU) in effluent (individual 

measurements before daily average calculations)............................................................ 6-9 

Table 6-4. Summary of daily values of turbidity (NTU) in effluent ......................................... 6-11 

Table 6-5. System-specific long-term averages used in limitation calculations........................ 6-12 

Table 6-6. System-specific variability factors used in limitation calculations.......................... 6-13 

Table 6-7. TSS variability factors in recent regulations ............................................................ 6-14 

Table 6-8. Effect of autocorrelation adjustments on limitation ................................................. 6-16 

Table 6-9. Daily values greater than daily maximum limitation ............................................... 6-19 

Table 6-10. Daily value summary from systems with less than model technology .................. 6-20 

Table 6-11. Turbidity during 1986 Alaskan placer mining study.............................................. 6-21 

Table 7-1. Scheduling considerations for construction activities ................................................ 7-5 

Table 7-2. Conditions where vegetative streambank stabilization is acceptable......................... 7-8 

Table 7-3. Maximum permissible velocities for individual site conditions for grass swales.... 7-10 

Table 7-4. Typical mulching materials and application rates.................................................... 7-17 

Table 7-5. Measured reductions in soil loss for different mulch treatments ............................. 7-18 

Table 7-6. Cubic yards of topsoil required for application to various depths............................ 7-25 

Table 7-7. Grassed swale pollutant-removal efficiency data..................................................... 7-32 

Table 7-8. Average annual operation and maintenance costs for a grass swale........................ 7-34 

Table 7-9. Recommended pipe/tubing sizes for slope drains .................................................... 7-36 

Table 7-10. Slope drain characteristics...................................................................................... 7-37 

Table 7-11. Maximum slope lengths for silt fences................................................................... 7-46 

Table 7-12. Typical requirements for silt fence fabric .............................................................. 7-48 

Table 7-13. Slope lengths for super silt fences.......................................................................... 7-52 

Table 7-14. Minimum requirements for super silt fence Geotextile Class F fabric .................. 7-53 

Table 7-15. Maximum land slope and distances above a straw bale dike ................................. 7-54 

Table 7-16. Weir length for sediment traps ............................................................................... 7-57 

Table 7-17. Range of measured pollutant removal for sediment detention basins.................... 7-58 

Table 7-18. Common concerns associated with sediment traps ................................................ 7-59 

Table 7-19. Studies of TSS in sediment basin effectiveness and effluent from construction 

sites ................................................................................................................................ 7-64 

Table 7-20. Common concerns associated with sediment basins.............................................. 7-65 

Table 7-21. Riprap sizes and thicknesses .................................................................................. 7-71 

Table 7-22. Application rates for spray-on adhesives ............................................................... 7-82 

Table 7-23. Turbidity reduction values from PAM ................................................................... 7-86 

Table 7-24. ATS operating modes............................................................................................. 7-88 

Table 7-25. ATS state requirements/recommendations............................................................. 7-90 

Table 7-26. Summary of vendor costs ....................................................................................... 7-92 

Table 7-27. Summary of ATS case studies................................................................................ 7-92 

Table 7-28. Examples of some commonly available coagulants............................................... 7-93 

Table 7-29. Chitosan acetate study results................................................................................. 7-94 

Table 7-30. DADMAC acetate study results ............................................................................. 7-95 

Table 7-31. PAM study results.................................................................................................. 7-95 

Table 7-32. Aluminum-based coagulant study results............................................................... 7-96 

Table 8-1. POTW cost test results ............................................................................................... 8-3 

Table 8-2. Cost and pollutant removals for BPT ......................................................................... 8-4 

Table 8-3. Industry cost-effectiveness test results ....................................................................... 8-4 
ix 

Table 9-1. Estimated total annual social costs of regulatory options for the C&D industry ....... 9-1 

Table 9-4. Model project durations.............................................................................................. 9-2 

Table 9-2. Model project matrix .................................................................................................. 9-5 

Table 9-3. Acreage developed matrix.......................................................................................... 9-7 

Table 9-5. State runoff coefficients for 2-year, 24-hour storm events......................................... 9-9 

Table 9-6. ATS storage requirements for states......................................................................... 9-11 

Table 9-7. Monthly ATS treatment volumes (gallons).............................................................. 9-13 

Table 9-8. ATS system flowrate required (gpm)....................................................................... 9-15 

Table 9-9. ATS system flowrate selected for costing (gpm) ..................................................... 9-17 

Table 9-10. Sediment basin construction cost data.................................................................... 9-19 

Table 9-11. Baseline sediment basin size (cubic feet)............................................................... 9-20 

Table 9-12. Baseline sediment basins costs............................................................................... 9-21 

Table 9-13. Temporary cover costs ........................................................................................... 9-23 

Table 9-14. Baseline silt fence and temporary cover assumptions and costs............................ 9-23 

Table 9-15. Basin assumptions .................................................................................................. 9-23 

Table 9-16. Surface outlet cost assumptions.............................................................................. 9-24 

Table 9-17. Costs for surface outlets ......................................................................................... 9-24 

Table 9-18. Passive treatment unit costs: polymer dosing system and labor............................. 9-26 

Table 9-19. Passive treatment unit costs: filter berms............................................................... 9-26 

Table 9-20. Monthly treatment volumes for passive treatment (gallons).................................. 9-27 

Table 9-21. Monthly chemical cost for passive treatment......................................................... 9-29 

Table 9-22. Total monthly cost for passive treatment ............................................................... 9-31 

Table 9-23. ATS costs: 500-gpm system................................................................................... 9-34 

Table 9-24. One-time ATS costs model projects....................................................................... 9-35 

Table 9-25. Monthly ATS costs for model projects .................................................................. 9-37 

Table 10-1. Model project matrix .............................................................................................. 10-3 

Table 10-2. Project matrix for loads analysis ............................................................................ 10-5 

Table 10-3. Data sources used to obtain RUSLE factors........................................................... 10-5 

Table 10-4. Slope ranges from STATSGO (percent) ................................................................ 10-6 

Table 10-5. P factors for construction site practices.................................................................. 10-8 

Table 10-6. P factors used for load estimation .......................................................................... 10-8 

Table 10-7. C factors for construction site controls................................................................... 10-9 

Table 10-8. C factors used for loads estimation ...................................................................... 10-10 

Table 10-9. Allocation of states/commonwealths/territories to representative indicator city . 10-10 

Table 10-10 Estimated runoff coefficients by HSG for indicator regions............................... 10-12 

Table 10-11. Discharged loads—primary analysis case.......................................................... 10-14 

Table 10-12. Discharged loads—low sensitivity analysis case ............................................... 10-15 

Table 10-13. Discharged loads—high sensitivity analysis case .............................................. 10-16 

Table 10-14. Sediment removals—primary analysis case....................................................... 10-17 

Table 10-15. Sediment removals—low sensitivity analysis case ............................................ 10-18 

Table 10-16. Sediment removals—high sensitivity analysis case........................................... 10-19 

Table 10-17. National sediment reductions for regulatory options ......................................... 10-20 

Table 10-18. Total discharge loads and loads modeled in SPARROW .................................. 10-21 

Table 11-1. Estimated energy consumption by regulatory option............................................. 11-2 

Table 11-2. Maximum chitosan acetate required under EPA options ....................................... 11-3 

Table 11-3. U.S. acrylamide/PAMs demand ............................................................................. 11-4 
x 

Table 11-4. 2002 Energy use in NAICS Category 23 ............................................................... 11-4 

Table 11-5. Estimated incremental energy usage by regulatory option..................................... 11-4 

Table 11-6. Estimated incremental air emissions by regulatory option (pounds/year) ............. 11-5 
xi 

Acronyms and Abbreviations 

ASCE American Society of Civil Engineers 

ATS Active Treatment System 

AWWA American Water Works Association 

BAER Burned Area Emergency Response 

BAT Best Available Technology Economically Achievable 

BCT Best Conventional Pollutant Control Technology 

BMP best management practice 

BOD biochemical oxygen demand 

BPJ best professional judgment 

BPT Best Practicable Control Technology 

C&D Construction and Development 

CAA Clean Air Act 

CCI Construction Cost Index 

CFR Code of Federal Regulations 

CGP Construction General Permit 

CHIA Cumulative Hydrologic Impact Analysis 

CONUS conterminous United States 

CSTR continuously stirred tank reactor 

CTAPE Chemical Technology Assessment Protocol—Ecology 

CUD conditional use designation 

CWA Clean Water Act 

DADMAC Diallydimethyl-ammonium chloride 

DCN Document Control Number 

ECRMs erosion control and revegetation mats 

ELG Effluent Limitations Guidelines 

ENR Engineering News-Record 

EPA U.S. Environmental Protection Agency 

ERF1 Enhanced River Reach File 1.2 

ERF1_2 Enhanced River Reach File 2.0 

ESC erosion and sediment control 

GIS geographic information system 

gpm gallons per minute 

GULD general use level designation 

HDSC Hydrometeorological Design Studies Center 

HSG hydrologic soil group 

LEW Low Erosivity Waiver 

MRLC Multi-Resolution Land Characteristics Consortium 

MS4 municipal separate storm sewer system 

MUID Map Unit Identifiers 

NAICS North American Industry Classification System 
xii 

NEL numeric effluent limit 

NLCD National Land Cover Database 

NOAA National Oceanic and Atmospheric Administration 

NOI Notice of Intent 

NOT Notice of Termination 

NOx nitrogen oxides 

NPDES National Pollutant Discharge Elimination System 

NRDC Natural Resources Defense Council 

NSPS New Source Performance Standards 

NTU nephelometric turbidity units 

NWS National Weather Service 

OCPSF organic chemicals, plastics, and synthetic fibers 

PAH polycyclic aromatic hydrocarbon 

PAM polyacrylamide 

PFDS Precipitation Frequency Data Server 

POTW publicly owned treatment works 

PPA Pollution Prevention Act of 1990 

PRISM Parameter Elevation Regressions on Independent Slopes Model 

RCRA Resource Conservation and Recovery Act 

RF1 Reach File Version 1.0 

RUSLE Revised Universal Soil Loss Equation 

SC AQMD South Coast Air Quality Management District 

SCS Soil Conservation Service 

SIC Standard Industrial Classification 

SIP state implementation plan 

SMRCA Surface Mining, Reclamation, and Control Act 

SPARROW Spatially Referenced Regressions on Watersheds 

SSC suspended sediment concentration 

STATSGO State Soil Geographic Database 

SWPPP stormwater pollution prevention plan 

SWRPC Southeastern Wisconsin Regional Planning Commission 

TP total phosphorus 

TRM turf reinforcement mats 

TSS total suspended solids 

TSS total suspended solids 

USDA U.S. Department of Agriculture 

USGS U.S. Geological Survey 

USLE Universal Soil Loss Equation 

VOCs volatile organic compounds 

WDEC Washington Department of Ecology 

WSDOT Washington Department of Transportation 
Section 1: Overview 

1-1 

1. OVERVIEW 

1.1. INTRODUCTION 

This document presents technical information to support the U.S. Environmental Protection 

Agency’s (EPA’s) decision and complements the Agency’s Economic Analysis for Final Effluent 

Guidelines and Standards for the Construction and Development Category (EPA-821-R-09-

011), and the Environmental Impact and Benefits Assessment for Final Effluent Guidelines and 

Standards for the Construction and Development Category (EPA-821-R-09-0012). 

A summary of the information contained in the sections of this document is as follows: 

 Section 2 presents a summary of the legal authority for effluent guidelines and the 

existing EPA stormwater program. 

 Section 3 summarizes the data collection activities and the analytical tools and 

processes followed to support the final action. 

 Section 4 summarizes the characteristics of the construction and development 

industry, including major indicators of industry size and annual construction activity. 

 Section 5 presents a description of pollutants in stormwater runoff known to be the 

most prevalent and of greatest concern to the environment. It also presents the 

selection of pollutants for the final regulation. 

 Section 6 presents the method and data used to establish limitations and standards. 

 Section 7 presents information and data on erosion and sediment control (ESC) 

strategies used by the construction and development industry, including applicability, 

costs, and efficiencies of various technologies. 

 Section 8 presents a description of the regulatory options EPA considered when 

developing the final rule. 

 Section 9 presents a description of the approach EPA used in developing costs for the 

regulatory options. 

 Section 10 summarizes the approach EPA used to estimate the pollutant loads and 

load reductions for the regulatory options EPA considered. 

 Section 11 summarizes the non-water quality environmental impacts, including the 

energy requirements, air emissions impacts, and solid waste generation of each 

regulatory option. 

1.2. SUMMARY AND SCOPE OF THE FINAL RULE 

EPA has established effluent limitations guidelines and new source performance standards for 

stormwater discharges from the construction and development industry. The guidelines and 

standards require discharges from certain construction sites to meet a numeric turbidity limit. 

The guidelines and standards also require all construction sites that are now required to obtain a 

National Pollutant Discharge Elimination System permit to implement a variety of best 
Section 1: Overview 

1-2 

management practices designed to limit erosion and control sediment discharges from 

construction sites. EPA evaluated four options in developing the final rule. Those options are 

described below: 

 Option 1 establishes minimum requirements for implementing a variety of ESCs and 

pollution prevention measures on all construction sites that are required to obtain a 

permit. 

 Option 2 contains the same requirements as Option 1. In addition, construction sites 

of 30 or more disturbed acres would be required to meet a numeric turbidity limit in 

stormwater discharges from the site. The technology basis for the numeric limit is 

active treatment systems (ATS). The numeric turbidity standard would be applicable 

to stormwater discharges for all storm events up to the local 2-year, 24-hour event. 

 Option 3 contains the same requirements as Option 1. Option 3 also requires all sites 

with 10 or more acres of disturbed land to meet a numeric turbidity standard that is 

based on the application of ATS. The turbidity standard would apply to all 

stormwater discharges for all storm events up to the local 2-year, 24-hour event. 

 Option 4 contains the same requirements as Option 1. Option 4 also requires all sites 

with 10 or more acres of disturbed land to meet a numeric turbidity standard that is 

based on the application of passive treatment systems. The turbidity standard would 

apply to all stormwater discharges for all storm events up to the local 2-year, 24-hour 

event; although, only certain types of discharges would require monitoring. 

The costs and economic impacts of the Options are presented in the Preamble to the Final Rule 

and in the Economic Analysis. 
Section 2: Background 

2-1 

2. BACKGROUND 

2.1. LEGAL AUTHORITY 

The U.S. Environmental Protection Agency (EPA) is promulgating Effluent Limitations 

Guidelines (ELGs) for discharges associated with construction and development activities under 

the authority of the Clean Water Act (CWA) sections 301, 304, 306, 308, 402, and 501 (the 

Federal Water Pollution Control Act), Title 33 of the United States Code (U.S.C.) sections 1311, 

1314, 1316, 1318, 1342, and 1361. This Background section describes EPA’s legal authority for 

issuing the regulation, existing state regulations, and other federal regulations associated with 

construction and development activities. 

2.2. CLEAN WATER ACT 

Congress adopted the CWA to “restore and maintain the chemical, physical, and biological 

integrity of the nation’s waters” (section 101(a), 33 U.S.C. 1251(a)). To achieve this goal, the 

CWA prohibits the discharge of pollutants into navigable waters except in compliance with the 

statute. CWA section 402 requires point source discharges to obtain a permit under the National 

Pollutant Discharge Elimination System (NPDES). Those permits are issued by EPA regional 

offices or authorized state agencies. 

Following enactment of the Federal Water Pollution Control Amendments of 1972 (Pub.L. 92-

500, October 18, 1972), EPA and the states issued NPDES permits to thousands of dischargers, 

both industrial (e.g., manufacturing, energy and mining facilities) and municipal (sewage 

treatment plants). As required under Title III of the Act, EPA promulgated ELGs and standards 

for many industrial categories, and those requirements are incorporated into the permits. 

The Water Quality Act of 1987 (Pub.L. 100-4, February 4, 1987) amended the CWA. The 

NPDES program was expanded by defining municipal and industrial stormwater discharges as 

point sources. Industrial stormwater dischargers, municipal separate storm sewer systems (MS4s) 

and other stormwater dischargers designated by EPA must obtain NPDES permits pursuant to 

section 402(p) (33 U.S.C. 1342(p)). 

2.2.1. BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY 

AVAILABLE 

In guidelines for a point source category, EPA may define Best Practicable Control Technology 

(BPT) effluent limits for conventional, toxic, and nonconventional pollutants. In specifying BPT, 

EPA looks at a number of factors. EPA first considers the cost of achieving effluent reductions in 

relation to the effluent reduction benefits. The Agency also considers the age of the equipment 

and facilities, the processes employed and any required process changes, engineering aspects of 

the control technologies, non-water quality environmental impacts (including energy 

requirements), and such other factors as the Agency deems appropriate (CWA section 

304(b)(1)(B)). Traditionally, EPA establishes BPT effluent limitations on the basis of the 

average of the best performance of facilities within the category of various ages, sizes, processes 

or other common characteristics. Where existing performance is uniformly inadequate, EPA may 
Section 2: Background 

2-2 

require higher levels of control than currently in place in a category if the Agency determines 

that the technology can be practically applied. See A Legislative History of the Federal Water 

Pollution Control Act Amendments of 1972, U.S. Senate Committee of Public Works, Serial No. 

93-1, January 1973, p. 1468. 

In addition, the Act requires a cost-reasonableness assessment for BPT limitations. In 

determining the BPT limits, EPA considers the total cost of treatment technologies in relation to 

the effluent reduction benefits achieved. This inquiry does not limit EPA’s broad discretion to 

adopt BPT limitations that are achievable with available technology unless the required 

additional reductions are “wholly out of proportion to the costs of achieving such marginal level 

of reduction.” See Legislative History, op. cit., p. 170. Moreover, the inquiry does not require the 

Agency to quantify benefits in monetary terms. See, for example, American Iron and Steel 

Institute v. EPA, 526 F. 2d 1027 (3rd Cir., 1975). 

In balancing costs against the benefits of effluent reduction, EPA considers the volume and 

nature of expected discharges after application of BPT, the general environmental effects of 

pollutants, and the cost and economic impacts of the required level of pollution control. In past 

ELGs and standards, BPT cost-reasonableness removal figures have ranged from $0.21 to $33.71 

per pound removed in year 2000 dollars. In developing guidelines, the Act does not require 

consideration of water quality problems attributable to particular point sources, or water quality 

improvements in particular bodies of water. See Weyerhaeuser Company v. Costle, 590 F. 2d 

1011 (D.C. Cir. 1978). 

2.2.2. BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY 

The 1977 amendments to the CWA require EPA to identify effluent reduction levels for 

conventional pollutants associated with Best Conventional Pollutant Control Technology (BCT) 

for discharges from existing point sources. BCT is not an additional limitation but replaces Best 

Available Technology Economically Achievable (BAT) for control of conventional pollutants. In 

addition to other factors specified in section 304(b)(4)(B), the CWA requires that EPA establish 

BCT limitations after consideration of a two-part cost-reasonableness test. EPA explained its 

methodology for developing BCT limitations in July 1986 (51 Federal Register [FR] 24974). 

Section 304(a)(4) designates the following as conventional pollutants: biochemical oxygen 

demand (BOD5), total suspended solids (TSS), fecal coliform, pH, and any additional pollutants 

defined by the Administrator as conventional. The Administrator designated oil and grease as an 

additional conventional pollutant on July 30, 1979 (44 FR 44501). A primary pollutant of 

concern at construction sites, sediment, is commonly measured as TSS. 

2.2.3. BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE 

In general, BAT effluent guidelines (CWA section 304(b)(2)) represent the best existing 

economically achievable performance of direct discharging plants in the subcategory or category. 

The factors considered in assessing BAT include the cost of achieving BAT effluent reductions, 

the age of equipment and facilities involved, the processes employed, engineering aspects of the 

control technology, potential process changes, non-water quality environmental impacts 

(including energy requirements), and such factors as the Administrator deems appropriate. The 
Section 2: Background 

2-3 

Agency retains considerable discretion in assigning the weight to be accorded to these factors. 

An additional statutory factor considered in setting BAT is economic achievability. Generally, 

EPA determines the economic achievability on the basis of the total cost to the subcategory and 

the overall effect of the rule on the industry’s financial health. The Agency may base BAT 

limitations on effluent reductions attainable through changes in a facility’s processes and 

operations. As with BPT, where existing performance is uniformly inadequate, EPA may base 

BAT on technology transferred from a different subcategory or from another category. In 

addition, the Agency may base BAT on manufacturing process changes or internal controls, even 

when such technologies are not common industry practice. 

2.2.4. NEW SOURCE PERFORMANCE STANDARDS 

New Source Performance Standards (NSPS) reflect effluent reductions that are achievable on the 

basis of the best available demonstrated control technology. New facilities have the opportunity 

to install the best and most efficient production processes and wastewater treatment technologies. 

As a result, NSPS should represent the greatest degree of effluent reduction attainable through 

the application of the best available demonstrated control technology for all pollutants (i.e., 

conventional, nonconventional, and priority pollutants). In establishing NSPS, CWA section 306 

directs EPA to take into consideration the cost of achieving the effluent reduction and any nonwater quality environmental impacts and energy requirements. 

2.2.5. PRETREATMENT STANDARDS FOR EXISTING SOURCES AND 

PRETREATMENT STANDARDS FOR NEW SOURCES 

The CWA also defines standards for indirect discharges, i.e., discharges into publicly owned 

treatment works. Such standards are Pretreatment Standards for Existing Sources and 

Pretreatment Standards for New Sources under section 307(b). 

2.2.6. EFFLUENT GUIDELINES SCHEDULE AND PREVIOUS ACTIONS 

RELATED TO CONSTRUCTION AND DEVELOPMENT 

CWA section 304(m) requires EPA to publish a plan every 2 years that consists of three 

elements. First, under section 304(m)(1)(A), EPA is required to establish a schedule for the 

annual review and revision of existing effluent guidelines in accordance with section 304(b). 

Section 304(b) applies to ELGs for direct dischargers and requires EPA to revise such 

regulations as appropriate. Second, under section 304(m)(1)(B), EPA must identify categories of 

sources discharging toxic or nonconventional pollutants for which EPA has not published BAT 

ELGs under section 304(b)(2) or NSPS under section 306. Finally, under section 304(m)(1)(C), 

EPA must establish a schedule for the promulgation of BAT and NSPS for the categories 

identified under subparagraph (B) not later than 3 years after being identified in the 304(m) plan. 

Section 304(m) does not apply to pretreatment standards for indirect dischargers, which EPA 

promulgates pursuant to CWA sections 307(b) and 307(c). 

On October 30, 1989, Natural Resources Defense Council, Inc. (NRDC), and Public Citizen, 

Inc., filed an action against EPA in which they alleged, among other things, that EPA had failed 

to comply with section 304(m). Plaintiffs and EPA agreed to a settlement of that action in a 

consent decree entered on January 31, 1992 (Natural Resources Defense Council et al. v 
Section 2: Background 

2-4 

Whitman, D.D.C. Civil Action No. 89-2980). The consent decree, which has been modified 

several times, established a schedule by which EPA is to propose and take final action for 11 

point source categories identified by name in the decree and for 8 other point source categories 

identified only as new or revised rules, numbered 5 through 12. EPA selected the Construction 

and Development (C&D) category as the subject for new or revised rule #10. The decree, as 

modified, calls for the Administrator to sign a proposed ELG for the C&D category no later than 

May 15, 2002, and to take final action on that proposal no later than March 31, 2004. A 

settlement agreement between the parties, signed on June 28, 2000, requires that EPA develop 

regulatory options applicable to discharges from construction, development, and redevelopment 

covering site sizes included in the Phase I and Phase II NPDES stormwater rules (i.e., 1 acre or 

greater). EPA is required to develop options including numeric effluent limitations for 

sedimentation and turbidity; control of construction site pollutants other than sedimentation and 

turbidity (e.g., discarded building materials, concrete truck washout, trash); best management 

practices (BMPs) for controlling post-construction runoff; BMPs for construction sites; and 

requirements to design stormwater controls to maintain predevelopment runoff conditions where 

practicable. 

On June 24, 2002, EPA published a proposed rule for the C&D category that contained several 

options for the control of stormwater discharges from construction sites, including ELGs and 

NSPS. (67 FR 42644; June 24, 2002). In a final action published on April 26, 2004, EPA 

determined that national ELGs would not be the most effective way to control discharges from 

construction sites and, instead, chose to rely on the range of existing programs, regulations, and 

initiatives that already existed at the federal, state, and local level. (69 FR 22472). 

The June 28, 2000, settlement agreement also required EPA to issue guidance to MS4s and other 

permittees on maintenance of post-construction BMPs identified in the proposed ELGs. Because 

EPA’s proposal or final action does not contain requirements for post-construction BMPs, that 

guidance was considered no longer necessary and, therefore, was not fully developed. However, 

a draft of the maintenance guidance that was prepared while EPA was considering including 

options for post-construction BMPs is in the public docket for the previous rulemaking. 

On October 6, 2004, NRDC and Waterkeeper Alliance, as well as New York and Connecticut 

filed a motion against EPA alleging that EPA failed to promulgate ELGs and NSPS as required 

by the CWA. On December 1, 2006, the district court—in Natural Resources Defense Council, 

et al. v U.S. Environmental Protection Agency, et al., 437 F.Supp.2d 1137, 1139 (C.D. 

Cal.2006)—held that CWA section 304(m), read together with CWA section 304(b), imposes on 

EPA a mandatory duty to promulgate ELGs and NSPS for industrial point source categories 

named in a CWA section 304(m) plan. The court ordered EPA to publish proposed regulations in 

the FR by December 1, 2008, and to promulgate ELGs and NSPS for the C&D category as soon 

as practicable, but no later than December 1, 2009. 

2.2.7. NPDES PHASE I AND II STORMWATER RULES 

As authorized by the CWA, the NPDES permit program was established to control water 

pollution by regulating point sources that discharge pollutants into waters of the United States. 

Stormwater runoff from construction activities can have a significant effect on water quality. The 

NPDES stormwater program requires operators of construction sites to apply for either a general 
Section 2: Background 

2-5 

permit or an individual permit under the NPDES Phase I and II stormwater rules. Phase I of 

EPA’s stormwater program was promulgated in 1990 under the CWA and addresses, among 

other discharges, discharges from construction activities disturbing 5 acres or more of land. 

Phase II of the NPDES stormwater program, promulgated in 1999, expands the Phase I Rule by 

addressing stormwater discharges from small construction sites disturbing between 1 and 5 acres. 

In addition, operators of small construction sites are also required to develop and implement a 

stormwater pollution prevention plan (SWPPP), which includes implementing the appropriate 

ESC BMPs. The BMP selection and design are at the discretion of permittees (in conformance 

with applicable state or local requirements). Moreover, construction activities disturbing less 

than 1 acre are also included in Phase II of the NPDES stormwater program if they are part of a 

larger, common plan of development or sale with a planned disturbance of equal to or greater 

than 1 acre and less than 5 acres, or if they are designated by the NPDES permitting authority. 

Most states are authorized to implement the stormwater NPDES permitting program. However, 

EPA remains the permitting authority in a few states, territories, and on most Indian country 

lands. For construction (and other land disturbing activities) in areas where EPA is the permitting 

authority, operators must meet the requirements of the EPA Construction General Permit (CGP). 

The current CGP became effective on June 30, 2008 (as modified effective September 29, 2008) 

and expires on June 30, 2010. That permit contains substantially the same terms and conditions 

as the 2003 CGP. In response to comments on the proposal, EPA has reorganized the content of 

the 2003 permit to better clarify existing requirements. The 2008 CGP applies only to new 

discharges. Construction site operators with permit coverage under the 2003 CGP may continue 

to operate under the terms of conditions of that permit and need not file a new Notice of Intent 

for coverage under the 2008 CGP. Permit coverage is now available for eligible construction 

activities in New Hampshire, Oklahoma, Texas, Puerto Rico, federal facilities, and Indian 

country lands in Colorado and Montana. 

The 2003 permit expanded coverage from the 1998 CGP, which provided coverage for large 

construction sites (i.e., those disturbing greater than 5 acres) to include both small and large 

construction activities (i.e., any project disturbing greater than 1 acre). Small construction 

activity was added to the 2003 CGP in response to the promulgation of the NPDES Phase II 

Rule. 

A major provision required by the CGP is preparation of a SWPPP. The SWPPP focuses on two 

major requirements: (1) Providing a site description that identifies sources of pollution to 

stormwater discharges associated with industrial activity on-site; and (2) identifying and 

implementing appropriate measures to reduce pollutants in stormwater discharges to ensure 

compliance with the terms and conditions of the permit. All SWPPPs must be developed in 

accordance with sound engineering practices and must be developed specific to the site. For 

coverage under the permit, the SWPPP must be prepared before commencement of construction 

and then updated as appropriate. Commencement of construction activities is defined as the 

initial disturbance of soils associated with clearing, grading, or excavating activities or other 

construction-related activities (e.g., stockpiling of fill material). 

The permit also clarifies that once a definable area of the site has been finally stabilized, no 

further SWPPP requirements apply to that portion of the site as long as the SWPPP has been 
Section 2: Background 

2-6 

updated accordingly to identify that portion of the site as complete. The SWPPP must be 

implemented as written from the beginning of construction activity until final stabilization is 

complete. Stabilization practices include seeding of temporary vegetation, seeding of permanent 

vegetation, mulching, geotextiles, sod stabilization, vegetative buffer strips, preservation of trees 

and mature vegetative buffer strips, and other appropriate measures. For a detailed description of 

all permit requirements and conditions, see the CGP. 

2.3. POLLUTION PREVENTION ACT OF 1990 

The Pollution Prevention Act of 1990 (PPA) (42 U.S.C. 13101 et seq., Pub. L. 101-508, 

November 5, 1990) makes pollution prevention the national policy of the United States. The PPA 

identifies an environmental management hierarchy in which pollution “should be prevented or 

reduced whenever feasible; pollution that cannot be prevented should be recycled in an 

environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled 

should be treated in an environmentally safe manner whenever feasible; and disposal or release 

into the environment should be employed only as a last resort...” (42 U.S.C. 13103). In short, 

preventing pollution before it is created is preferable to trying to manage, treat, or dispose of it 

after it is created. According to the PPA, source reduction reduces the generation and release of 

hazardous substances, pollutants, wastes, contaminants, or residuals at the source, usually within 

a process. The term source reduction “...includes equipment or technology modifications, 

process or procedure modifications, reformulation or redesign of products, substitution of raw 

materials, and improvements in housekeeping, maintenance, training, or inventory control. The 

term source reduction does not include any practice [that] alters the physical, chemical, or 

biological characteristics or the volume of a hazardous substance, pollutant, or contaminant 

through a process or activity which itself is not integral to or necessary for the production of a 

product or the providing of a service.” In effect, source reduction means reducing the amount of 

a pollutant that enters a wastestream or that is otherwise released into the environment before 

out-of-process recycling, treatment, or disposal. 

Although the PPA does not explicitly address stormwater discharges or discharges from 

construction sites, the principles of the PPA are implicit in many of the practices used to reduce 

pollutant discharges from construction sites. These include controls that minimize the potential 

for erosion such as proper phasing of construction, retention of on-site vegetation and 

stabilization of disturbed areas as soon as practicable. Such controls and practices are described 

in Section 7 of this document. 

2.4. STATE REGULATIONS 

States and municipalities have been regulating discharges of runoff from the construction and 

land development industry to varying degrees for some time. A compilation of state CGPs and 

regulations was prepared to help establish the baseline for national and regional levels of control. 

Data were collected by reviewing state CGPs, Web sites, summary references, and state ESC or 

stormwater management guidance manuals. The state regulatory data are discussed in Sections 

3.4 and 9.2 of this document, and the complete data sheets are included in Appendix A. 
Section 3: Data Collection 

3-1 

3. DATA COLLECTION 

3.1. INTRODUCTION 

As part of the regulatory efforts to develop the proposed Construction and Development (C&D) 

regulations in 2002 and the related final action in 2004, the U.S. Environmental Protection 

Agency (EPA) gathered and evaluated an extensive amount of technical and economic data from 

various sources. EPA used much of the data collected for the previous rulemaking effort in 

support of this effort. EPA also collected additional data and information to support the technical 

analyses used in developing this final rule. This section summarizes EPA’s data collection 

efforts. 

3.2. LITERATURE SEARCH 

A literature search was performed to obtain additional information on various erosion and 

sediment control (ESC) technologies that pertain to the C&D industry. Journal articles and 

professional conference proceedings were reviewed to collect recent data and information related 

to ESC design and installation criteria, performance, and related costs. Annotated bibliographies 

for the journal articles and professional conference proceedings that EPA reviewed for possible 

use in developing this final rule are in Appendix B (costs), Document Control Number (DCN) 

44321 (sediment basin performance), and DCN 43114 (passive treatment). 

3.3. DATA AND INFORMATION PROVIDED IN RESPONSE TO THE 2002 

REGULATORY ACTION AND THE 2008 PROPOSAL 

In response to the previous rulemaking efforts for the C&D industry, EPA received numerous 

public comments on most aspects of the 2002 proposed rule. EPA considered those comments in 

developing this final rule. EPA also considered public comments received on the 2008 proposal. 

3.4. COMPILATION OF STATE CONTROL STRATEGIES, CRITERIA, AND 

STANDARDS 

EPA compiled and evaluated existing state program information for the control of construction 

site stormwater. The data were collected by reviewing state construction general permits (CGPs), 

Web sites, summary references, state regulations, and ESC design and guidance manuals. A 

summary of criteria and standards for construction site stormwater ESC that are implemented by 

states is presented in Appendix A. More information on this analysis is in Section 9.2, Analysis 

of State Equivalency. Appendix A also includes updated state information that EPA obtained in 

early 2007, state-level data sheets and information originally presented in Section 7 and 

Appendix D of the 2004 Development Document for Final Action for Effluent Guidelines and 

Standards for the Construction and Development Category (EPA-821-B-04-001), and 

information originally presented in Appendix A of the June 2002 Development Document for 

Proposed Effluent Guidelines and Standards for the Construction and Development Category

(EPA-821-R-02-007). 
Section 3: Data Collection 

3-2 

3.5. OTHER DATA SOURCES 

3.5.1. LAND USE DATA 

EPA accessed a number of sources of land cover information at a national scale for use in 

estimating the potential number of acres subject to C&D activities. 

3.5.1.1. National Land Cover Dataset 

The National Land Cover Database (NLCD) provides a national source of data on land cover 

change. The Multi-Resolution Land Characteristics Consortium (MRLC) has produced the 

NLCD data sets that created a 30-meter resolution land cover data layer over the conterminous 

United States (CONUS) from Landsat Thematic Mapper satellite imagery. NLCD data are 

publicly available for the years 1992 and 2001 (see http://www.epa.gov/mrlc/ and 

http://www.mrlc.gov/). 

Because new developments in mapping methodology, new sources of input data, and changes in 

the mapping legend for the 2001 NLCD confound direct comparison between 2001 NLCD and 

the 1992 NLCD (MRLC 1992 and 2001), the U.S. Geological Survey (USGS) prepared and 

released the NLCD 1992/2001 Retrofit Land Cover Change Product. The NLCD 1992/2001 

Retrofit Land Cover Change Product was developed to offer more accurate direct change 

analysis between the two products. 

The NLCD 1992/2001 Retrofit Land Cover Change Product uses a specially developed 

methodology to provide land cover change information at the Anderson Level I classification 

scale, relying on decision tree classification of Landsat imagery from 1992 and 2001. While 

NLCD 1992 reported on developed land in the categories of low-residential intensity, highresidential intensity, commercial/industrial/transportation, and urban/recreational grasses, NLCD 

2001 reported categories of developed low, medium, high, and open space. To compare change 

between the two data sets, the developed categories were merged into one overall urban class. 

Unchanged pixels between the two dates are coded with the NLCD 2001 Anderson Level I class 

code, while changed pixels are labeled with a from-to land cover change value. Modified 

Anderson Level 1 Classifications include the following: 

 Open water 

 Urban 

 Barren 

 Forest 

 Grassland/Shrub 

 Agriculture 

 Wetlands Ice/Snow 

The NLCD 1992/2001 Retrofit Land Cover Change Product was intended to provide a current, 

consistent, and seamless data set for the United States at medium spatial resolution for Anderson 

Level 1 classes. This land cover change map and all documents pertaining to it are considered 

provisional until a formal accuracy assessment can be conducted. 
Section 3: Data Collection 

3-3 

EPA used the NLCD to estimate the annual number of acres of land converted to urban land uses 

in the United States during the period between 1992 and 2001. At proposal, EPA used the NCLD 

results to estimate acres of construction activities subject to the national effluent guidelines 

regulations because no national database of the number and size of construction activities exists. 

For the final rule analysis, the NLCD data was not used to estimate the amount of construction 

activity occurring. EPA used economic data to estimate expected levels of construction activity 

(for more information, see the Economic Analysis). EPA used the NCLD to apportion consruction 

activity to watersheds as a basis for estimating baseline loadings and loadings reductions of the 

regulatory options. Figure 3-1 illustrates an example of the Reach File Version 1.0 (RF1)-level 

analysis of the NLCD data. EPA used the RF1 watershed cataloging system (described below) 

because the SPARROW model (which is the model EPA used to estimate water quality 

improvements) operates at the RF1 scale. 

Figure 3-1. NLCD 1992/2001 land cover change product near Seattle, Washington. 

Table 3-1 summarizes the national- and state-level estimates obtained from the NLCD analysis. 

Figures 3-2 through 3-11 graphically present the results of the NLCD land use change analysis at 

the RF1 level for each EPA Region. Results are presented as percent urban change between 1992 

and 2001. (For an index of the NLCD-related analyses conducted for the rule, see DCN 43097 in 

the Administrative Record.) 
Section 3: Data Collection 

3-4 

Table 3-1. State and national estimates of urban land from NLCD 

 

1992 Urban 

acres 

2001 Urban 

acres 

% of state 

that is 

developed 

(1992) 

% of state 

that is 

developed 

(2001) 

Annual rate of 

development, 

1992–2001 

(acres) 

Alabama 2,066,843 2,197,496 6.40% 6.80% 14,517 

Alaska NO DATA 

Arizona 1,285,258 1,408,765 1.80% 1.97% 13,723 

Arkansas 1,836,496 1,912,492 5.50% 5.73% 8,444 

California 6,278,143 6,524,815 6.20% 6.44% 27,408 

Colorado 1,609,387 1,751,902 2.40% 2.61% 15,835 

Connecticut 727,078 736,015 23.40% 23.69% 993 

Delaware 113,052 120,720 9.40% 10.04% 852 

Florida 4,526,626 4,870,084 13.00% 13.99% 38,162 

Georgia 3,026,921 3,319,772 8.20% 8.99% 32,539 

Hawaii NO DATA 

Idaho 847,520 898,118 1.60% 1.70% 5,622 

Illinois 4,014,480 4,197,711 11.30% 11.82% 20,359 

Indiana 2,238,170 2,353,388 9.90% 10.41% 12,802 

Iowa 2,527,225 2,621,239 7.10% 7.36% 10,446 

Kansas 2,463,194 2,666,459 4.70% 5.09% 22,585 

Kentucky 1,740,669 1,830,327 6.80% 7.15% 9,962 

Louisiana 1,788,423 1,903,893 6.60% 7.03% 12,830 

Maine 653,697 695,682 3.30% 3.51% 4,665 

Maryland 698,386 754,384 11.30% 12.21% 6,222 

Massachusetts 1,174,234 1,203,889 23.90% 24.50% 3,295 

Michigan 3,746,569 3,946,405 10.30% 10.85% 22,204 

Minnesota 2,648,001 2,731,809 5.20% 5.36% 9,312 

Mississippi 1,721,138 1,827,869 5.70% 6.05% 11,859 

Missouri 2,845,661 2,967,035 6.50% 6.78% 13,486 

Montana 1,187,901 1,246,068 1.30% 1.36% 6,463 

Nebraska 1,699,570 1,752,634 3.50% 3.61% 5,896 

Nevada 572,706 646,794 0.80% 0.90% 8,232 

New Hampshire 426,786 443,382 7.50% 7.79% 1,844 

New Jersey 1,124,705 1,162,613 23.70% 24.50% 4,212 

New Mexico 799,207 838,609 1.00% 1.05% 4,378 

New York 2,682,301 2,752,573 8.90% 9.13% 7,808 

North Carolina 2,816,229 2,984,988 9.10% 9.65% 18,751 

North Dakota 1,667,029 1,727,113 3.90% 4.04% 6,676 

Ohio 3,549,025 3,705,445 13.60% 14.20% 17,380 

Oklahoma 2,387,508 2,537,439 5.40% 5.74% 16,659 

Oregon 1,552,824 1,617,957 2.50% 2.60% 7,237 

Pennsylvania 3,006,384 3,149,538 10.40% 10.90% 15,906 

Rhode Island 173,764 177,085 27.00% 27.52% 369 

South Carolina 1,487,194 1,632,427 7.70% 8.45% 16,137 

South Dakota 1,315,111 1,388,776 2.70% 2.85% 8,185 

Tennessee 2,189,700 2,307,879 8.30% 8.75% 13,131 

Texas 8,229,892 8,791,816 5.00% 5.34% 62,436 

Utah 758,031 831,309 1.40% 1.54% 8,142 

Vermont 304,570 309,628 5.40% 5.49% 562 

Virginia 1,818,500 1,954,409 7.20% 7.74% 15,101 
Section 3: Data Collection 

3-5 

 

1992 Urban 

acres 

2001 Urban 

acres 

% of state 

that is 

developed 

(1992) 

% of state 

that is 

developed 

(2001) 

Annual rate of 

development, 

1992–2001 

(acres) 

Washington 2,286,574 2,402,332 5.40% 5.67% 12,862 

West Virginia 1,016,805 1,049,133 6.70% 6.91% 3,592 

Wisconsin 2,345,956 2,411,998 6.70% 6.89% 7,338 

Wyoming 491,168 516,818 0.80% 0.84% 2,850 

District of Columbia 26,381 28,865 82.80% 90.60% 276 

Nation 96,492,992 101,807,897 590,545 

Figure 3-2. EPA Region 1: Percent urban change 1992–2001 by ERF1_2 watershed. 
Section 3: Data Collection 

3-6 

Figure 3-3. EPA Region 2: Percent urban change 1992–2001 by ERF1_2 watershed. 

Figure 3-4. EPA Region 3: Percent urban change 1992–2001 by ERF1_2 watershed. 
Section 3: Data Collection 

3-7 

Figure 3-5. EPA Region 4: Percent urban change 1992–2001 by ERF1_2 watershed. 

Figure 3-6. EPA Region 5: Percent urban change 1992–2001 by ERF1_2 watershed. 
Section 3: Data Collection 

3-8 

Figure 3-7. EPA Region 6: Percent urban change 1992–2001 by ERF1_2 watershed. 

Figure 3-8. EPA Region 7: Percent urban change 1992–2001 by ERF1_2 Watershed. 
Section 3: Data Collection 

3-9 

Figure 3-9. EPA Region 8: Percent urban change 1992–2001 by ERF1_2 watershed. 

Figure 3-10. EPA Region 9: Percent urban change 1992–2001 by ERF1_2 watershed. 
Section 3: Data Collection 

3-10 

Figure 3-11. EPA Region 10: Percent urban change 1992–2001 by ERF1_2 watershed. 

Because NLCD data does not exist for Alaska, Hawaii, or the U.S. territories, EPA’s analysis 

does not consider pollutant loading reductions for those areas. Detailed definitions and 

discussion of the NLCD 1992/2001 Retrofit Product is presented in Appendix E. DCN 43097 in 

the Administrative Record provides an index to the NLCD-related analyses conducted for the 

rulemaking. 

3.5.1.2. River Reach File Data 

An option for summarizing national land cover change in drainage area units is to use EPA’s 

RF1 for the CONUS. RF1 is a vector database of approximately 700,000 miles of streams and 

open waters in the CONUS. EPA and states use it extensively, and the U.S. Fish and Wildlife 

Service and the National Weather Service (NWS) have used it for many years. EPA prepared 

RF1 in 1982 from National Oceanic and Atmospheric Administration (NOAA) aeronautical 

charts having a scale of 1:500,000. Those charts provided the best nationwide hydrographic 

coverage available on a single scale at that time. They include all hydrography shown on USGS 

maps having a scale of 1:250,000 with extensive additions, corrections, and improvements in 

detail made by NOAA from aerial photography and satellite imagery. In the 1980s, EPA used 

RF1 for performing water quality modeling on whole river basins for all the hydrologic regions 

in the CONUS. In that role, it was used to provide national assessments and overviews of water 

quality and to provide the foundation for a nationwide, stratified, sampling frame for performing 

statistical summaries of modeled and measured water quality on all surface waters of the 

CONUS. 

A consistent, national-scale watershed data set was prepared to enhance the RF1 hydrology data 

set. That watershed data set, the Enhanced River Reach File 1.2 (ERF1), was designed to be a 

digital database of river reaches capable of supporting regional and national water-quality and 

river-flow modeling and transport investigations in the water-resources community. USGS has 

used ERF1 to support interpretations of stream water-quality monitoring network data. In such 

analyses, the reach network has been used to determine flow pathways between the sources of 
Section 3: Data Collection 

3-11 

point and nonpoint pollutants and downstream water-quality monitoring locations in support of 

predictive water-quality models of stream nutrient transport. 

The Enhanced River Reach File 2.0 (ERF1_2) expands on ERF1 and includes the incremental 

and total drainage area founded on the 1-kilometer (km) elevation data for North America (Nolan 

et al. 2002). Previous estimates of the water time-of-travel were recomputed for reaches with 

water quality monitoring sites that included two reaches. The mean flow and velocity estimates 

for the split reaches are based on previous estimation methods (Alexander et al. 1999) and are 

unchanged in ERF1_2. Drainage area calculations provide data used to estimate the contribution 

of a given nutrient to the outflow. ERF1_2 contains 67,171 watersheds with a minimum size of 

247 acres (1 square km [km2]) and an average size of 30,182 acres (122 km2). 

EPA used the ERF1_2 as the foundation for summarizing land cover change and in drainage area 

units (or watersheds) and for SPARROW (Spatially Referenced Regressions [of nutrient 

transport] on Watershed) modeling. Within the context of a geographic information system 

(GIS), SPARROW estimates the proportion of watersheds in the CONUS with outflow flux of 

several nutrients, including total nitrogen and total phosphorus, (Smith et al. 1997). EPA 

modified SPARROW to model changes in sediment flux in the RF1 network to evaluate 

potential benefits of regulatory options. Sediment and nutrient flux were converted to 

concentrations using estimates of reach flow for each RF1. 

3.5.2. NPDES PERMIT NOTICE OF INTENT DATA 

EPA used CGP Notice of Intent (NOI) records to characterize construction activity by project 

type and project size for subsequent analysis of costs and pollutant loading reductions. Using 

NOI data, EPA broadly characterized the construction industry into three land use types 

(residential construction, nonresidential construction, and road/highway construction). EPA has 

NOI data for approximately 22,000 permit applications, containing data from four states for 

construction activities occurring primarily between 2003 and 2009. While the NOI data are 

useful for characterizing construction activities into different project types and project sizes, as 

well as for estimating the duration of projects, EPA did not find the NOI data useful as a national 

data set to estimate the amount of construction occurring. That is because the NOI data obtained 

by EPA are not national in coverage. EPA’s analysis of the NOI data are in Appendix C. 

3.5.3. CLIMATIC/RAINFALL DATA 

3.5.3.1. NOAA National Weather Service Precipitation Frequency Data 

Server 

Variations in rainfall depth and intensity are important factors in determining erosion rates, 

sediment discharges, pollutant load reductions, and control technology costs for construction 

sites. EPA used a combination case study approach of 11 indicator cities as well as national data 

sets for different components of the analysis. Indicator cities were used for certain components 

of the cost analysis, such as estimating design storm depths. EPA also used indicator cities in the 

loadings analysis to develop runoff coefficients. However, national data coverages were used for 

other components of the loads analysis, such as estimating average annual precipitation values 

for RF1s. 
Section 3: Data Collection 

3-12 

For the indicator city analysis, EPA selected representative areas in each of the 10 EPA Regions 

to be used as a point estimate for the entire region. EPA generally selected the urban area in each 

region with the greatest rate of development on the basis of EPA’s analysis of land use change 

from the NLCD analysis. EPA selected one metropolitan area in each of the 10 EPA Regions, 

with the exception of Region 10. In Region 10, EPA selected two indicator cities because the two 

areas with the greatest rate of development (Boise City, Idaho, and Seattle, Washington) have 

very different rainfall patterns. For each of the 11 indicator cities, EPA obtained detailed rainfall 

data and rainfall summaries. EPA also obtained detailed soils data for each of the 11 areas. The 

11 indicator cities are identified in Table 3-2. 

Table 3-2. EPA Region indicator cities 

EPA 

Region Indicator city 

1 Manchester, New Hampshire 

2 Albany, New York 

3 Washington, DC, Virginia, and Maryland 

4 Atlanta, Georgia 

5 Chicago, Illinois—Indiana 

6 Dallas, Fort Worth, and Arlington, Texas 

7 Kansas City, MIssouri and Kansas 

8 Denver and Aurora, Colorado 

9 Las Vegas, Nevada 

10 Boise City, Idaho, and Seattle, Washington 

EPA’s costing analysis used state-specific design storms for determining stormwater runoff rates 

and volumes and for determining storage volumes and treatment system sizing. EPA identified 

one major city within each state to serve as an indicator for the entire state. EPA obtained rainfall 

summary data for each of these cities for using as a basis for determining expected runoff rates 

and rainfall volumes for costing of technologies. 

Precipitation data was gathered and analyzed using the NOAA NWS Precipitation Frequency 

Data Server (PFDS). The Hydrometeorological Design Studies Center (HDSC) in the Office of 

Hydrologic Development of the NWS is in an ongoing process of updating its precipitation 

frequency estimates, which are available in NOAA Atlas 14 format. At the time of this writing, 

only a portion of the United States had been updated into this format (NWS 2008). Atlas 14 

supersedes precipitation frequency estimates contained in previous NWS publications. The 

updates are based on more recent and extended data sets, currently accepted statistical 

approaches, and improved spatial interpolation and mapping techniques. A complete list of NWS 

publications is at http://www.nws.noaa.gov/ohd/hdsc/currentpf.htm. 

NOAA Atlas 14 contains precipitation frequency estimates with associated confidence limits for 

the United States for 5-minute through 60-day durations at average recurrence intervals of 1-year 

through 1,000-year. The estimates are based on the analysis of annual maximum series and then 

converted to partial duration series results. The Atlas 14 rainfall data results used in this study 

are shown in Appendix D, Table D-3. 
Section 3: Data Collection 

3-13 

For the states not currently updated by NOAA Atlas 14, the rainfall-frequency values for 

selected durations were estimated using a series of maps presented in the older NWS 

publications. The data for the remainder of the western United States were estimated by using 

NOAA Atlas 2, Precipitation Frequency Atlas of the Western United States (NOAA 1973), 

which are generalized maps presented for 6- and 24-hour point precipitation for the return 

periods of 2, 5, 10, 25, 50, and 100 years. Atlas 2 is published in separate volumes for each of the 

states. Similarly, the maps presented in the corresponding technical paper were used for the 

remainder of the eastern United States and Hawaii. (Alaska was not included in this study 

because EPA lacked sufficient data on the annual amount of construction activities in Alaska). 

Precipitation frequency results generated by Atlas 2 or technical paper maps are presented in 

Appendix D, Table D-4. The rainfall depths were estimated by identifying the target city on the 

Atlas 2 or technical paper map and linearly approximating the rainfall value. For example, if a 

city fell between a depth of 4.5 and 5 inches, and the city was approximately 20 percent of the 

map distance from the 5-inch line, a rainfall depth of 4.9 inches was estimated. Note that the 

maps provide data for depth only. Intensity estimates were calculated by dividing the duration 

(e.g., 6- or 24-hour) by the depth. Additionally, Atlas 2 depths were converted from tenths of an 

inch to inches. 

To analyze the percent of total construction site runoff captured and treated for various 

regulatory options, EPA obtained hourly precipitation data for each indicator city. EPA obtained 

30 years of hourly rainfall data from EarthInfo Version 2.31 (www.earthinfo.com). EarthInfo 

provides National Climatic Data Center meteorological data in an easy-to-use format from which 

precipitation data can be extracted. From the 7,000 National Climatic Data Center gages 

available, EPA generally used data collected at an airport in or adjacent to each indicator city. In 

general, EPA analyzed data for the period between the mid-1970s and mid-2000s. EPA also used 

the hourly precipitation data in EarthInfo to evaluate the number and size of rainfall events that 

discharge from construction sites. Appendix H details this evaluation that focuses on the 11 

indicator cities. 

Table 3-3 summarizes the state-specific rainfall data EPA used in its analyses. 

3.5.3.2. Parameter Elevation Regressions on Independent Slopes Model 

(PRISM) 

EPA’s analyses of the regulatory options used estimates of the average annual precipitation for 

each RF1 watershed. Annual precipitation was used to estimate runoff volumes and baseline 

sediment concentrations as well as to evaluate removals under regulatory options that 

incorporated a numeric limit. For each RF1 watershed, the average annual precipitation amount 

was obtained from the 1-km resolution United States Average Monthly or Annual Precipitation 

(1971–2000) PRISM Group raster data coverage (PRISM Group 2006). RF1 watershed 

boundaries were used to summarize the PRISM Group average annual rainfall values, and each 

RF1 was assigned a value by spatially averaging contributing raster data. Figure 3-12 shows 

average annual precipitation for the CONUS from the PRISM data. Additional information on 

the PRISM data is in Appendix D. 
3-14 

Table 3-3. Rainfall summary data for indicator cities 

State City 

Average 

annual 

precipitation 

(inches) 

2-year, 

24-hour storm 

depth 

(inches) 

10-year, 

24-hour storm 

depth 

(inches) 

25-year, 

24-hour storm 

depth 

(inches) 

Alabama Montgomery 49 4.50 6.5 7.6 Arizona Phoenix 8 1.40 2.14 2.59 Arkansas Little Rock 48 4.10 6.05 7 California Sacramento 18 2.00 3 3.5 Colorado Denver 13 2.00 3 3.8 Connecticut Hartford 44 3.10 4.8 5.5 Delaware Dover 43 3.26 5.08 6.36 Florida Tallahassee 62 4.75 7.4 8.5 Georgia Atlanta 51 3.70 5.5 6.5 Hawaii Honolulu 18 4.25 7.8 8.9 Idaho Boise 11 1.20 1.8 2.2 Illinois Chicago 33 2.85 4.29 5.25 Indiana Indianapolis 40 2.95 4.13 4.83 Iowa Des Moines 32 3.25 4.7 5.5 Kansas Kansas City 37 3.50 5.2 6.1 Kentucky Frankfort 45 3.00 4.34 5.23 Louisiana Baton Rouge 59 5.25 8.2 9.1 Maine Augusta 42 2.80 4.25 4.9 Maryland Baltimore 42 3.16 4.85 6.08 Massachusetts Boston 42 3.10 4.5 5.5 Michigan Lansing 30 2.40 3.6 4.2 Minnesota St. Paul 29 2.75 4.2 4.7 Mississippi Jackson 52 4.45 6.7 7.8 Missouri Kansas City 37 3.45 5.3 6 Montana Helena 12 1.30 2.1 2.4 Nebraska Lincoln 28 3.00 4.8 5.4 Nevada Las Vegas 4 1.00 1.62 1.96 New Hampshire Manchester 40 2.80 4.3 5 New Jersey Hightstown 47 3.31 5.07 6.3 New Mexico Santa Fe 15 1.54 2.22 2.62 
3-15 

State City 

Average 

annual 

precipitation 

(inches) 

2-year, 

24-hour storm 

depth 

(inches) 

10-year, 

24-hour storm 

depth 

(inches) 

25-year, 

24-hour storm 

depth 

(inches) 

New York Albany 37 2.90 4 5.9 North Carolina Charlotte 43 3.34 4.86 5.76 North Dakota Bismarck 16 1.90 3.25 3.75 Ohio Columbus 38 2.62 3.73 4.44 Oklahoma Oklahoma City 33 3.70 5.8 6.9 Oregon Salem 41 2.50 3.5 4 Pennsylvania Philadelphia 42 3.23 4.8 5.85 Rhode Island Providence 45 3.20 4.8 5.7 South Carolina Columbia 45 3.62 5.28 6.39 South Dakota Pierre 16 2.25 3.5 4.1 Tennessee Nashville 46 3.37 4.7 5.53 Texas Fort Worth 33 3.90 6.3 7.4 Utah Salt Lake City 15 1.40 1.9 2.21 Vermont Montpelier 34 2.40 3.7 4.25 Virginia Arlington 40 3.11 4.78 5.98 Washington Seattle 35 2.00 3 3.4 West Virginia Charleston 43 2.56 3.55 4.16 Wisconsin Madison 31 2.80 4.1 4.75 Wyoming Cheyenne 15 1.60 2.4 2.8 Puerto Rico San Juan 51 4.26 6.76 8.29 District of Columbia Washington 42 3.16 4.85 6.07 
3-16 

Figure 3-12. Average annual precipitation in the CONUS from PRISM. 
Section 3: Data Collection 

3-17 

3.5.4. SOILS DATA 

The variation in soil types found in the United States is a significant factor in estimating 

sediment discharges. EPA used soil coverage data provided in the State Soil Geographic 

Database (STATSGO) (Wolock 1997; USDA 2007) and the CONUS-SOIL data layers (Miller 

and White 1998) for the loadings analysis. STATSGO component and layer tables were accessed 

through the Pennsylvania State University’s active archive 

(http://www.soilinfo.psu.edu/index.cgi?soil_data&index.html). EPA extracted data for only the 

portions of RF1 watersheds where development change has been documented by NLCD. This 

urban masking approach was implemented using a binary raster grid of NLCD 1992/2001 

Retrofit Land Cover Change Product representing urbanization to weight RF1 values for 

STATSGO data layers. EPA used the mask of urbanization change to create RF1 watershed 

parameter values. Essentially, the individual spatial units of the soil coverage—Map Unit 

Identifiers (MUIDs)—were summarized by urbanizing area weights into RF1 average values, 

instead of using proportional weight based on land area (Figure 3-13). The geographic limits of 

the soil coverage evaluated were determined by superimposing indicator city urban area 

boundaries—from the U.S. Census Bureau’s 2000 Urbanized Areas Cartographic Boundary Files 

(U.S. Census Bureau 2000)—on intersecting RF1 watersheds. The resulting list of RF1 

watersheds intersecting the rapidly developing indicator city urban areas was used to spatially 

identify underlying STATSGO soil coverage MUIDs. Last, soil data associated with the surface 

soil layer within the selected MUIDs were extracted from STATSGO to produce the suite of data 

evaluated for each indicator city. 

Figure 3-13. An example of Washington State RF1 watershed showing urban weighting 

emphasizes MUID: WA189, while area-weighting would have enhanced MUID WA194. 

3.5.5. VENDOR DATA FOR ACTIVE TREATMENT SYSTEMS 

EPA compiled and evaluated information from vendors on treatment technologies that could be 

used in setting numeric standard discharge limits for stormwater runoff from construction sites. 

EPA conducted an Internet-based search and placed telephone calls to several vendors to gather 
Section 3: Data Collection 

3-18 

data on available treatment technologies, costs, and performance (for vendor-specific 

information and fact sheets, see DCNs 43000 through 43011 and DCN 43081 in the 

Administrative Record). EPA also received unsolicited e-mails with data from vendors. After 

publishing the November 2008 proposed rule, EPA received additional data from vendors (see 

DCN 43125). 

3.5.6. RAINFALL AND RUNOFF EROSIVITY FACTOR 

EPA used a GIS data layer for the RUSLE R factor to determine average R factors for RF1 as a 

component of the loadings analysis. The R factor (USDA 1997) is an indicator of rainfall energy 

and intensity and varies seasonally across the United States. EPA uses this data for determining 

whether small construction sites can qualify for the Low Erosivity Waiver (LEW) that is in the 

NPDES Phase II stormwater regulations. EPA has an online tool that can be used to determine if 

sites qualify for the LEW (see http://cfpub.epa.gov/npdes/stormwater/lew/lewcalculator.cfm). 

Figure 3-14 shows annual R factor values for the CONUS. Again using an urban masking 

approach, EPA derived the R factor values for RF1 watersheds on the basis of averaging values 

underlying land undergoing development according to the NLCD 1992/2001 Retrofit Land 

Cover Change Product. 

3.5.7. HYDROLOGIC SOIL GROUPS 

EPA used GIS data to determine the percent of each hydrologic soil group (HSG) for each RF1 

watershed using the urban masking approach. The per RF1 HSG percentages were then used to 

estimate runoff coefficients for each RF1. As described in Section 10.3, EPA first determined the 

hydrologic response of indicator cities independently for each soil class, i.e., A soil, B soil, C 

soil, and D soil. Next, the effective per RF1 runoff coefficient was determined by prorating the 

hydrologic response of the adjacent indicator city using the RF1 HSG percentages. That resulted 

in a customized runoff coefficient for each RF1. To provide insight into the variability of the 

HSG within CONUS, Table 3-4 shows the percent of each HSG by state. 
3-19 

Figure 3-14. Annual R factor values for CONUS. 
3-20 

Table 3-4. HSGs by state 

 HSG HSG  A B C D A B C 

Alabama 8.7% 41.2% 28.8% 21.3% Nebraska 31.9% 53.6% 3.Arizona 4.7% 38.6% 17.2% 39.5% Nevada 5.6% 26.4% 17.Arkansas 0.6% 28.3% 35.9% 35.1% New Hampshire 17.1% 24.8% 41.4California 10.9% 32.2% 18.4% 38.5% New Jersey 12.5% 32.8% 25.Colorado 7.2% 46.7% 24.6% 21.4% New Mexico 5.6% 41.9% 16.Connecticut 9.1% 41.1% 35.9% 13.9% New York 9.6% 18.5% 51.Delaware 20.8% 30.9% 13.4% 34.9% North Carolina 7.9% 48.8% 16.Florida 18.1% 6.3% 8.6% 67.0% North Dakota 4.7% 56.1% 16.Georgia 6.6% 53.1% 16.9% 23.5% Ohio 0.6% 16.8% 54.Idaho 4.4% 46.8% 23.1% 25.7% Oklahoma 6.8% 44.5% 22.Illinois 1.4% 44.5% 27.0% 27.1% Oregon 5.2% 32.1% 37.Indiana 3.5% 32.6% 41.8% 22.1% Pennsylvania 6.0% 28.4% 54.Iowa 0.9% 66.0% 11.6% 21.5% Rhode Island 15.3% 35.7% 32.Kansas 3.8% 58.0% 19.5% 18.7% South Carolina 11.9% 41.8% 19.Kentucky 0.1% 42.7% 44.9% 12.3% South Dakota 2.9% 45.2% 11.Louisiana 1.7% 14.4% 28.9% 55.1% Tennessee 0.1% 53.6% 30.Maine 7.7% 12.9% 43.9% 35.5% Texas 5.1% 27.2% 24.Maryland 10.0% 38.6% 26.4% 25.0% Utah 5.3% 36.2% 16.Massachusetts 23.9% 16.6% 34.4% 25.2% Vermont 4.9% 18.0% 54.Michigan 29.0% 28.7% 12.9% 29.4% Virginia 1.7% 53.7% 32.Minnesota 8.3% 37.4% 15.4% 38.9% Washington 6.6% 53.4% 24.Mississippi 2.3% 32.3% 38.6% 26.9% West Virginia 7.3% 21.5% 54.Missouri 1.0% 40.1% 39.8% 19.0% Wisconsin 14.4% 46.8% 18.Montana 2.9% 39.5% 27.2% 30.4% Wyoming 4.5% 40.5% 19.
Section 3: Data Collection 

3-21 

3.6. REFERENCES 

Alexander, R.B., J.W. Brakebill, R.E. Brew, and R.A. Smith. 1999. Enhanced River Reach File 

1.2 (ERF1) (Online database). U.S. Department of the Interior, U.S. Geological Survey, 

Reston, VA. <http://water.usgs.gov/GIS/metadata/usgswrd/XML/erf1.xml>. 

Miller, D.A., and R.A. White. 1998. A conterminous United States multilayer soil characteristics 

data set for regional climate and hydrology modeling. Earth Interactions 2(2):1–26. 

MRLC (Multi-Resolution Land Characteristics Consortium). 1992 and 2001. National Land 

Cover Database. U.S. Department of the Interior, U.S. Geological Survey, Land Cover 

Institute. <http://www.mrlc.gov/index.asp>. Updated March 21, 2008. 

Nolan, J.V., J.W. Brakebill, R.B. Alexander, and G.E. Schwarz. 2002. Enhanced River Reach 

File 2.0 (ERF1_2) (Online database). U.S. Department of the Interior, U.S. Geological 

Survey, Reston, VA. <http://water.usgs.gov/GIS/metadata/usgswrd/XML/erf1_2.xml>. 

NOAA (National Oceanic and Atmospheric Administration). 1973. Precipitation Frequency 

Atlas of the Western United States. Vols. 1-3, 5, 9-11. U.S. Department of Commerce, 

National Weather Service. Silver Spring, MD. Precipitation Frequency Data Server (PFDS). 

<http://hdsc.nws.noaa.gov/hdsc/pfds/index.html>. Updated October 29, 2008. 

NWS (National Weather Service). 2008. Precipitation Frequency Data Server. National Oceanic 

and Atmospheric Administration, National Weather Service, Office of Hydrologic 

Development, Silver Spring, MD. <http://hdsc.nws.noaa.gov/hdsc/pfds/>. Updated March 4, 

2008. 

PRISM Group. 2006. United States Average Monthly or Annual Precipitation (1971–2000). 

Oregon State University, Corvallis, OR. <http://www.prismclimate.org>. Accessed March 

2008. 

Smith, R.A., G.E. Schwarz, and R.B. Alexander. 1997. Regional interpretation of water-quality 

monitoring data. Water Resources Research 33(12):2781–2798. 

U.S. Census Bureau. 2000. 2000 Urbanized Areas Cartographic Boundary Files. U.S. Census 

Bureau, Washington, DC. <http://www.census.gov/geo/www/cob/ua2000.html.>. Accessed 

January 2008. 

USDA (U.S. Department of Agriculture). 1997. Predicting Soil Erosion by Water: A Guide to 

Conservation Planning with the Revised Universal Soil Loss Equation (RUSLE). Agriculture 

Handbook Number 703. U.S. Department of Agriculture, Agricultural Research Service. 

January, 1997. 

USDA (U.S. Department of Agriculture). 2007. U.S. General Soil Map (STATSGO) (Database). 

U.S. Department of Agriculture, Natural Resources Conservation Service, Washington, DC. 

<http://soildatamart.nrcs.usda.gov/USDGSM.aspx>. Updated July 11, 2007. 
Section 3: Data Collection 

3-22 

 2004 Development Document for Final Action for Effluent Guidelines and Standards for the 

Construction and Development Category (EPA-821-B-04-001), and information originally 

presented in Appendix A of the June 2002 Development Document for Proposed Effluent 

Guidelines and Standards for the Construction and Development Category (EPA-821-R-02-

007). 

Wolock, D.M. 1997. STATSGO soil characteristics for the conterminous United States: 

U.S. Geological Survey Open-File Report 97-656. U.S. Geological Survey, Reston, VA. 

<http://water.usgs.gov/GIS/metadata/usgswrd/muid.html>. Accessed December 2007. 
Section 4: Industry Profile 

4-1

4. INDUSTRY PROFILE 

4.1. INTRODUCTION 

The construction industry is divided into three major subsectors: general building contractors, 

heavy construction contractors, and special trade contractors. General contractors build 

residential, industrial, commercial, and other buildings. Heavy construction contractors build 

sewers, roads, highways, bridges, and tunnels. Special trade contractors typically provide 

carpentry, painting, plumbing, and electrical services. 

Because the U.S. Environmental Protection Agency (EPA) is developing regulations to address 

water quality issues, this document focuses on the construction subsectors most closely 

associated with land-disturbing activities. General contractors and heavy construction 

establishments are, by definition, the most likely to conduct activities that could affect water 

resources. Note, however, that for individual projects, responsibility for land-disturbing activities 

and potential effects on water quality might not be obvious because general contractors often 

subcontract all or some of the actual construction work. Hence, the following subsections 

describe the subsector categories most likely to be responsible for land-disturbing activities at the 

national level. 

The construction and development (C&D) industry is classified in the 2007 North American 

Industry Classification System (NAICS) under Sector 23, Construction (U.S. Census Bureau 

2008a). NAICS is the system used for classifying industry establishments by type of economic 

activity, which replaced the U.S. Standard Industrial Classification (SIC) system. 

The construction sector comprises establishments primarily engaged in constructing buildings or 

engineering projects (e.g., highways and utility systems). Establishments primarily engaged in 

preparing sites for new construction and establishments primarily engaged in subdividing land 

for sale as building sites also are included in this sector (U.S. Census Bureau 2008a). 

Construction work done can include new work, additions, alterations, or maintenance and 

repairs. Activities of these establishments generally are managed at a fixed place of business, but 

they usually perform construction activities at multiple project sites. Establishments identified as 

construction-management firms are also included in the sector. The construction sector is divided 

into three types of activities or subsectors as described below (from U.S. Census Bureau 2008a): 

 Subsector 236—Construction of Buildings 

This subsector comprises establishments of the general contractor type and operative 

builders involved in constructing buildings. The work performed can include new 

work, additions, alterations, or maintenance and repairs. The on-site assembly of 

precut, panelized, and prefabricated buildings and construction of temporary 

buildings are included in this subsector. Part of or all the production work for which 

the establishments in this subsector have responsibility can be subcontracted to other 

construction establishments—usually specialty trade contractors. Establishments in 

this subsector are classified on the basis of the types of buildings they construct. This 

classification reflects variations in the requirements of the underlying production 

processes. 
Section 4: Industry Profile 

4-2

 Subsector 237—Heavy and Civil Engineering Construction 

This subsector comprises establishments whose primary activity is constructing entire 

engineering projects (e.g., highways and dams), and specialty trade contractors, 

whose primary activity is producing a specific component for such projects. Specialty 

trade contractors in Heavy and Civil Engineering Construction generally are 

performing activities that are specific to heavy and civil engineering construction 

projects and are not normally performed on buildings. The work performed can 

include new work, additions, alterations, or maintenance and repairs. 

Specialty trade activities are classified in this subsector if the skills and equipment 

present are specific to heavy or civil engineering construction projects. For example, 

specialized equipment is needed to paint lines on highways. That equipment is not 

normally used in building applications, so the activity is classified in this subsector. 

Traffic signal installation, while specific to highways, uses much of the same skills 

and equipment that are needed for electrical work in building projects and is therefore 

classified in Subsector 238, Specialty Trade Contractors. Establishments in this 

subsector are classified on the basis of the types of structures that they construct. This 

classification reflects variations in the requirements of the underlying production 

processes. 

 Subsector 238—Special Trade Contractors 

This subsector comprises establishments whose primary activity is performing 

specific activities (e.g., pouring concrete, site preparation, plumbing, painting, and 

electrical work) involved in building construction or other activities that are similar 

for all types of construction, but that are not responsible for the entire project. The 

work performed can include new work, additions, alterations, maintenance, and 

repairs. The production work performed by establishments in this subsector is usually 

subcontracted from establishments of the general contractor type or operative 

builders, but especially in remodeling and repair construction. Work also can be done 

directly for the owner of the property. Specialty trade contractors usually perform 

most of their work at the construction site, although they might have shops where 

they perform prefabrication and other work. Establishments primarily engaged in 

preparing sites for new construction are also included in this subsector. There are 

substantial differences in types of equipment, work force skills, and other inputs 

required by specialty trade contractors. Establishments in this subsector are classified 

on the basis of the underlying production function for the specialty trade in which 

they specialize. 

Table 4-1 provides a list of the 3-digit subsectors, 4-digit industry groups and 5-digit NAICS 

industries in the construction sector. 
Section 4: Industry Profile 

4-3

Table 4-1. 2007 NAICS subsectors, industry groups, and industries performing construction 

activities that might disturb land 

2007 NAICS Sector 23 - Construction 

236 Construction of Buildings 

2361 Residential Building Construction 

23611 

236115 

236116 

236117 

236118 

 Residential Building Construction 

 New Single-Family Housing Construction 

 New Multifamily Housing Construction 

 New Housing Operative Builders 

 Residential Remodelers 

2362 Nonresidential Building Construction 

23621 

236210 

23622 

236220 

 Industrial Building Construction 

 Industrial Building Construction 

 Commercial and Institutional Building Construction 

 Commercial and Institutional Building Construction 

237 Heavy and Civil Engineering Construction 

2371 Utility System Construction 

23711 

237110 

23712 

237120 

23713 

237130 

 Water and Sewer Line and Related Structures Construction 

 Water and Sewer Line and Related Structures Construction 

 Oil and Gas Pipeline and Related Structures Construction 

 Oil and Gas Pipeline and Related Structures Construction 

 Power and Communication Line and Related Structures Construction 

 Power and Communication Line and Related Structures Construction 

2372 Land Subdivision 

23721 

237210 

 Land Subdivision 

 Land Subdivision 

2373 Highway, Street, and Bridge Construction 

23731 

237310 

 Highway, Street, and Bridge Construction 

 Highway, Street, and Bridge Construction 

2379 Other Heavy and Civil Engineering Construction 

23799 

237990 

 Other Heavy and Civil Engineering Construction 

 Other Heavy and Civil Engineering Construction 

238 Specialty Trade Contractors 

2381 Foundation, Structure, and Building Exterior Contractors 

23811 

238110 

23812 

238120 

23813 

238130 

23814 

238140 

23815 

238150 

23816 

238160 

23817 

238170 

23819 

238190 

 Poured Concrete Foundation and Structure Contractors 

 Poured Concrete Foundation and Structure Contractors 

 Structural Steel and Precast Concrete Contractors 

 Structural Steel and Precast Concrete Contractors 

 Framing Contractors 

 Framing Contractors 

 Masonry Contractors 

 Masonry Contractors 

 Glass and Glazing Contractors 

 Glass and Glazing Contractors 

 Roofing Contractors 

 Roofing Contractors 

 Siding Contractors 

 Siding Contractors 

 Other Foundation, Structure, and Building Exterior Contractors 

 Other Foundation, Structure, and Building Exterior Contractors 
Section 4: Industry Profile 

4-4

2007 NAICS Sector 23 - Construction 

2382 Building Equipment Contractors 

23821 

238210 

23822 

238220 

23829 

238290 

 Electrical Contractors and Other Wiring Installation Contractors 

 Electrical Contractors and Other Wiring Installation Contractors 

 Plumbing, Heating, and Air-Conditioning Contractors 

 Plumbing, Heating, and Air-Conditioning Contractors 

 Other Building Equipment Contractors 

 Other Building Equipment Contractors 

2383 Building Finishing Contractors 

23831 

238310 

23832 

238320 

23833 

238330 

23834 

238340 

23835 

238350 

23839 

238390 

 Drywall and Insulation Contractors 

 Drywall and Insulation Contractors 

 Painting and Wall Covering Contractors 

 Painting and Wall Covering Contractors 

 Flooring Contractors 

 Flooring Contractors 

 Tile and Terrazzo Contractors 

 Tile and Terrazzo Contractors 

 Finish Carpentry Contractors 

 Finish Carpentry Contractors 

 Other Building Finishing Contractors 

 Other Building Finishing Contractors 

2389 Other Specialty Trade Contractors 

23891 

238910 

23899 

238990 

 Site Preparation Contractors 

 Site Preparation Contractors 

 All Other Specialty Trade Contractors 

 All Other Specialty Trade Contractors 

Source: U.S. Census Bureau 2008a 

Before NAICS was created, C&D industries were classified using the SIC system. Any data 

collected before January 1997 might still be classified under that system. SIC classifications are 

relevant to the effluent guidelines because certain U.S. Census Bureau data for the construction 

industry were collected until 1994 and, therefore, were classified under the SIC system rather 

than the NAICS. Under the SIC system, industries that might perform land-disturbing activities 

were classified under Division C–Construction, and Division H–Finance, Insurance, and Real 

Estate. Those divisions include the following SIC major groups (from U.S. Census Bureau 

2008b): 

 SIC Major Group 15–Building Construction General Contractors and Operative 

Builders 

This group includes general contractors and operative builders primarily engaged in 

constructing residential, farm, commercial, or other buildings. General building 

contractors who combine a special trade with their contracting are also included. 

 SIC Major Group 16–Heavy Construction other than Building Construction 

Contractors 

This group includes general contractors primarily engaged in heavy construction 

other than building construction, such as highways and streets, bridges, sewers, 

railroads, irrigation projects, flood control projects, and marine construction, as well 

as special trade contractors primarily engaged in activities of a type clearly 

specialized in such heavy construction and not normally performed on buildings or 

building-related projects. 
Section 4: Industry Profile 

4-5

 SIC Major Group 17–Construction Special Trade Contractors 

This group includes special trade contractors who undertake activities of a type that 

are specialized either in building construction or in both building and non-building 

projects. 

 SIC Major Group 65–Real Estate 

This group includes real estate operators and the owners and lessors of real property, 

as well as buyers, sellers, developers, agents, and brokers. 

Major groups 15 and 16 are further defined by the type of construction performed. Table 4-2 

provides a list of the more specific industry groups and industries that might perform landdisturbing activities. 

The focus of the regulation is on construction activities carried out by firms covered by NAICS 

codes 233 and 234 or SIC codes 15 and 16. (As discussed in the preamble of the final rule, 

Special Trade Contractors, NAICS 238 or SIC 17, are typically subcontractors and not identified 

as National Pollutant Discharge Elimination System permittees.) Furthermore, the residential, 

nonresidential, and heavy construction subsectors receive the greatest emphasis because they 

account for the vast majority of construction projects and are responsible for most of the land 

disturbance in the United States. 

Table 4-2. 1987 SIC industry groups performing construction activities that might disturb land 

SIC Major Group 15 

Industry Group 152: General Building Contractors - Residential 

1521 General Contractors - Single-family Houses 

1522 General Contractors - Residential Buildings, Other Than Single-family 

Industry Group 153: Operative Builders 

1531 Operative Builders 

Industry Group 154: General Building Contractors - Nonresidential 

1541 General Contractors - Industrial Buildings and Warehouses 

1542 General Contractors - Nonresidential Buildings, Other Than Industrial 

SIC Major Group 16 

Industry Group 161: Highway and Street Construction, Except Elevated Highways 

1611 Highway and Street Construction, Except Elevated Highways 

Industry Group 162: Heavy Construction, Except Highway and Street 

1622 Bridge, Tunnel, and Elevated Highway Construction 

1623 Water, Sewer, Pipeline, and Communications and Power Line 

1629 Heavy Construction Not Elsewhere Classified 

SIC Major Group 17 

Industry Group 179: Miscellaneous Special Trade Contractors 

1771 Concrete Work 

1794 Excavation Work 

SIC Major Group 65 

Industry Group 655: Land Subdividers and Developers 

6552 Land Subdividers and Developers, Except Cemeteries 

Source: U.S. Census Bureau 2008b 
Section 4: Industry Profile 

4-6

4.2. INDUSTRY PRACTICES AND TRENDS 

This section first provides a description of the types of C&D activities that result in the 

disturbance of land and are responsible for the potential discharge of pollutants of concern to 

surface waters. Then national estimates of the amount of disturbed acreage are provided. 

Additional information including detailed descriptions of industry size and revenues is in EPA’s 

Economic Analysis for Final Effluent Guidelines and Standards for the Construction and 

Development Category (USEPA 2009a). 

4.2.1. OVERVIEW OF CONSTRUCTION LAND-DISTURBING ACTIVITIES 

Constructing a building or facility involves a variety of activities, including the use of equipment 

that alters the site’s environmental conditions. Such changes include vegetation and top soil 

removal, regrading, and drainage pattern alteration. The following provides a brief description of 

typical land-disturbing activities at construction sites and the types of equipment employed. 

4.2.1.1. Construction Site Preparation 

Construction activities generally begin with the planning and engineering of the site and site 

preparation. During this stage, mobile offices, which are usually housed in trailers, are 

established on the construction site. The construction company uses such temporary structures to 

handle vital activities such as preparing and submitting applicable permits, hiring employees and 

subcontractors, and ensuring that proper environmental requirements are met. The entire 

construction yard is delineated with erosion and sediment controls (ESCs) installed and security 

measures established. The latter includes installing fences and signs to warn against trespassing 

and to mark dangerous areas. After the site is secured, equipment is brought to the site (and is 

stored there throughout the construction period). 

4.2.1.2. Clearing, Excavating, and Grading 

Construction on any size parcel of land almost always calls for a remodeling of the earth (Lynch 

and Hack 1984). Therefore, actual site construction begins with site clearing and grading. 

Organic material—in particular, roots—cannot support the weight of buildings and must be 

removed from the top layer of ground. (Some developers stockpile the organic material for use 

during the landscaping phase of construction rather than paying for it to be hauled from the site.) 

Construction contractors must ensure that earthwork activities meet local, state, and federal 

regulations for soil and erosion control, runoff, and other environmental controls. The size of the 

site, extent of water present, soil types, topography, and weather determine the kinds of 

equipment used in site clearing and grading (Peurifoy and Oberlender 1989). Material that will 

not be used on the site must be hauled away by tractor-pulled wagons, dump trucks, or 

articulated trucks (Peurifoy and Oberlender 1989). 

Equipment used for lifting excavated and cleared materials include aerial-work platforms, 

forwarders, cranes, rough-terrain forklifts, and truck-mounted cranes. In addition, track loaders 

are used for digging and dumping earth (Caterpillar 2000; Reed Business Information 2000; 

Lynch and Hack 1984; Peurifoy and Oberlender 1989). 
Section 4: Industry Profile 

4-7

Excavation and grading are performed by several different types of machines. Those tasks can 

also be done by hand, but that is generally more expensive (Lynch and Hack 1984). When 

grading a site, builders typically ensure that new grades are as close to the original as possible, to 

avoid erosion and stormwater runoff (Lynch and Hack 1984). Proper grading also ensures a flat 

surface for development and drains water away from constructed buildings. 

Excavation and grading equipment includes backhoes, bulldozers (including the versatile tracked 

bulldozer), loaders, directional drilling rigs, hydraulic excavators, motor graders, scrapers, skidsteer loaders, soil stabilizers, tool carriers, trenchers, wheel loaders, and pipeliners. Equipment 

selection depends on functions to be performed and specific site conditions (Caterpillar 2000; 

Reed Business Information 2000; Lynch and Hack 1984; Peurifoy and Oberlender 1989). 

Therefore, multiple types of equipment are used throughout the clearing and grading process. 

Self-transporting trenching machines, wheel-type trenching machines, and ladder-type trenching 

machines are also used during site excavation. Self-transporting trenching machines are used to 

create shallow trenches, such as for underground wire and cables. This type of machine has a 

bulldozer blade attached to the front, is highly maneuverable, and can be used to dig narrow, 

shallow trenches. Wheel-type trenching machines also dig narrow trenches, most often for water 

mains and gas and oil pipelines. Ladder-type trenching machines are used to dig deep trenches, 

such as for sewer pipes. These machines might have a boom mounted at the rear. Along the 

boom are cutter teeth and buckets that are attached to chains. As the machine moves, it digs dirt 

and moves it to the sides of the newly formed trench (Peurifoy and Oberlender 1989). 

Power shovels can also be used for excavating soils. They are used on all classes of earth that 

have not been loosened. For solid rock, prior loosening is required. As materials are excavated, 

they are immediately loaded onto trucks or tractor-pulled wagons and hauled from the site 

(Peurifoy and Oberlender 1989). Hydraulic excavators, with either a front or a back shovel, are 

also used to dig into the earth and to load a hauling vehicle. There are several categories of 

hydraulic excavators, including backhoes, back shovels, hoes, and pull shovels. Hydraulic 

excavators are one of the most widely used types of excavating equipment because of their ease 

of use and their ability to remove the earth that caves as it is moved. They are effective 

excavating machines, and they are easy to use in terms of loading excavated soil onto a hauling 

vehicle (Peurifoy and Oberlender 1989). 

Draglines, used to dig ditches or build levees, can transport soil within casting limits, thus 

eliminating the need for hauling equipment (Peurifoy and Oberlender 1989). Draglines have a 

bucket that hangs from a cable. The bucket is brought through the dirt and toward the operator 

(Lynch and Hack 1984). Draglines can be used on both wet and dry ground and can dig earth out 

of pits that contain water (Peurifoy and Oberlender 1989). They are most useful for making large 

cuts and channels below the level of the machine and for making valleys, mounds, slopes, and 

banks (Lynch and Hack 1984). Draglines have a lower output than power shovels and do not 

excavate rock as well as power shovels (Peurifoy and Oberlender 1989). 

Draglines can be converted to clamshells by replacing the dragline bucket with a clamshell 

bucket. A clamshell is typically used for handling sand, gravel, crushed stone, sandy loam, and 

other loose materials; it is not efficient in handling compacted earth, clay, or other dense 
Section 4: Industry Profile 

4-8

materials. A clamshell is lowered into a material, and the bucket closes on the material. It is then 

raised over a hauling vehicle and the materials are deposited (Peurifoy and Oberlender 1989). 

Scrapers, either self-powered or drawn by tractors, dig and compact materials by taking up earth 

from its underside with toothed scoops and loading it into hauling vehicles. Scrapers are useful in 

removing earth and weak or broken rock and for excavating hills and rock faces. Some scrapers 

are designed for long hauls; others with good traction are used on steep slopes (Lynch and Hack 

1984). 

A crawler tractor, which pulls a rubber-tired self-loading scraper, is often used for short-haul 

distances. The crawler tractor uses a drawbar pull to load the scraper. It has good traction and 

can operate on muddy roads. It is, however, a slower vehicle and thus is more appropriate for 

shorter hauls. 

Wheel-type, tractor-pulled scrapers—which come in two- and four-wheel drive tractors—are 

used for longer hauling distances. Unlike the crawler tractor-pulled scrapers, the wheel-type, 

tractor-pulled scrapers do not maintain good traction. Under such conditions, a helper tractor, 

such as a bulldozer, might be used (Peurifoy and Oberlender 1989). 

All these machines shape and compact the earth, a crucial site preparation step. In addition, 

earthwork activities might require that fill be brought in. In such cases, the fill must be spread in 

uniform, thick layers and compacted to a specified density with an optimum moisture content. 

Graders and bulldozers are the most common earth-spreading machines. Machines that compact 

include tractor-pulled sheep’s foot rollers, smooth-wheel rollers, pneumatic rollers, and vibrating 

rollers, among other equipment (Peurifoy and Oberlender 1989). Rollers and scarifiers are used 

either to compact or to break up the ground (Lynch and Hack 1984). 

To remove rock, it must first be loosened and broken up—usually through drilling or blasting. 

Drilling equipment includes jackhammers, wagon drills, drifters, churn rills, and rotary drills; 

each is designed to work on a specific size and type of rock. Dynamite and other explosives are 

used to loosen rock (Peurifoy and Oberlender 1989). 

After the materials have been excavated and removed and the ground cleared and graded, the site 

is ready for construction. 

4.2.2. CONSTRUCTION SITE SIZE CATEGORIES AND ESTIMATES OF 

AMOUNT OF DISTURBED LAND 

The regulatory options that EPA evaluated apply to construction sites of all types (i.e., 

residential, commercial, and industrial). Because the costs for ESC are largely driven by site size, 

EPA must estimate the distribution of construction sites by size category, land use type, and 

geographic region to estimate the total cost of the options. In addition, estimating distribution of 

sites by type allows EPA to estimate the cost to each construction sector. 
Section 4: Industry Profile 

4-9

4.2.2.1. National Estimates of New Development 

EPA used the National Land Cover Dataset (NLCD) to estimate the amount of new developed 

land occurring annually in the conterminous United States (CONUS) between 1992 and 2001 

(see Table 3-1 and Appendix E). EPA’s comparison of the 1992 and 2001 NLCD resulted in an 

estimated annual rate of development of approximately 590,000 acres per year. By overlaying 

geographic information system (GIS) layers of states and watersheds with the NLCD data, EPA 

was able to estimate the annual number of acres of new development at both the state and 

watershed level between 1992 and 2001 (For state-level annual estimates of new development, 

see Table 4-6). EPA used the Reach File Version 1.0 (RF1) stream reach network and associated 

watershed boundaries for the watershed-level estimates. EPA estimated annual development 

rates between 1992 and 2001 for approximately 44,000 RF1 watersheds where a net increase in 

urban land cover was identified. Approximately 7,800 additional RF1 watersheds showed either 

no change or a minor decrease in urban land uses between 1992 and 2001. EPA scaled the 

amount of development in each RF1 to the year 2008 using historical construction spending data. 

For additional details, see Economic Analysis for Final Effluent Guidelines and Standards for the 

Construction and Development Category (USEPA 2009a). RF1 watersheds and stream reaches 

are employed by the USGS SPARROW water quality model—the model EPA has selected to 

assess potential environmental benefits of additional regulation of the industry (USGS 2008). 

See the Environmental Impact and Benefits Assessment for Final Effluent Guidelines and 

Standards for the Construction and Development Category (EPA 2009b) for additional details 

and results of the water quality assessment performed by EPA. 

Because NLCD data does not exist for Alaska, Hawaii, and the U.S. territories, EPA’s analysis 

does not include pollutant loading reduction or environmental benefits estimates for those areas. 

However, the amount of development in those areas is expected to be low compared to the rest of 

the United States; therefore, any errors in EPA’s estimates are expected to be minor. EPA did 

estimate costs for Alaska and Hawaii using economic data as an indicator of the amount of 

construction activity occurring. 

4.2.2.2. Model Project Distribution 

EPA broadly characterized the acreage constructed annually into various future land uses and 

construction project sizes. That characterization provides a basis for developing and then using 

mathematical models that represent broad sectors of the industry to estimate compliance costs 

and pollutant loading reductions. EPA divided Notices of Intent (NOIs) into 36 groups based on 

12 site size categories and three major land-use types (residential, nonresidential, and 

transportation). Projects were further subdivided into 12 categories of different durations. 

The distribution of model projects into these categories was developed by reviewing NOIs 

submitted by permittees (see Appendix C, Analysis of Construction Industry Trends using 

Notice of Intent Records). The NOI records were individually characterized on the basis of land 

use, and the NOI records used provided site construction acreage and project duration 

information. Individually, the site project models each represent large fractions of the 

construction projects developed annually and cover the major project types in the C&D industry. 

EPA used this model project matrix as a basis for estimating costs and pollutant removals for the 
Section 4: Industry Profile 

4-10

industry. Table 4-3 shows the model project matrix developed. Table 9-2 shows the complete 

model project matrix that includes the breakout by project sizes. 

Table 4-3. Model project distribution 

 Residential Nonresidential Transportation National 

Size 

category 

(acres) 

Median 

size 

(acres) Projects Acres Projects Acres Projects Acres Projects Acres 

1–2.99 1.9 4,914 9,337 23,237 44,150 2,417 4,592 30,568 58,079 

3–4.99 3.8 3,693 14,033 12,410 47,158 1,298 4,932 17,401 66,124 

5–7.49 6.0 1,992 11,952 6,709 40,254 770 4,620 9,471 56,826 

7.5–9.99 8.5 1,680 14,280 3,579 30,422 494 4,199 5,753 48,901 

10–14.99 12.0 2,421 29,052 4,084 49,008 548 6,576 7,053 84,636 

15–19.99 17.0 1,556 26,452 2,102 35,734 272 4,624 3,930 66,810 

20–29.99 23.0 1,810 41,630 2,078 47,794 363 8,349 4,251 97,773 

30–39.99 34.0 984 33,456 865 29,410 128 4,352 1,977 67,218 

40–59.99 46.0 921 42,366 847 38,962 180 8,280 1,948 89,608 

60–79.99 69.0 373 25,737 366 25,254 52 3,588 791 54,579 

80–99.99 85.1 242 20,594 213 18,126 56 4,766 511 43,486 

100 < 145.0 344 49,880 356 51,620 118 17,110 818 118,610 

Total 20,930 318,769 56,846 457,892 6,696 75,988 84,472 852,650 

4.3. REFERENCES 

Caterpillar. 2000. Caterpillar, Inc., Peoria, IL. <www.cat.com>. 

Lynch K., and G. Hack. 1984. Site Planning. 3rd ed. The MIT Press, Cambridge, MA. 

Peurifoy, R.L., and G.D. Oberlender. 1989. Estimating Construction Costs. 4th ed. McGraw Hill 

Book Company, New York. 

Reed Business Information. 2000. Construction Equipment. Oak Brook, IL, <www.coneq.com>. 

U.S. Census Bureau. 2008a. 2007 North American Industry Classification System (NAICS). 

U.S. Department of Commerce, U.S. Census Bureau, Washington, DC. 

<http://www.census.gov/epcd/www/naics.html>. Updated March 28, 2008; accessed April 

15, 2008. 

U.S. Census Bureau. 2008b. 2007 North American Industry Classification System (NAICS). 

Concordances: 2007 NAICS to 2002 NAICS.xls and 2002 NAICS to 1987 SIC.xls. 

U.S. Department of Commerce, U.S. Census Bureau, Washington, DC. 

<http://www.census.gov/eos/www/naics/concordances/concordances.html>. Accessed 

November 7, 2008. 
Section 4: Industry Profile 

4-11

USEPA (U.S. Environmental Protection Agency). 2009a. Economic Analysis for Final Effluent 

Guidelines and Standards for the Construction and Development Category (EPA-821-R-09-

011). U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

USEPA (U.S. Environmental Protection Agency). 2009b. Environmental Impact and Benefits 

Assessment for Final Effluent Guidelines and Standards for the Construction and 

Development Category (EPA-821-R-09-012). U.S. Environmental Protection Agency, Office 

of Water, Washington, DC. 

USGS (U.S. Geological Survey). 2008. The SPARROW Surface Water-Quality Model: Theory, 

Application and User Documentation. U.S. Geological Survey Techniques and Methods, 

Book 6, Section B, Chapter 3. U.S. Geological Survey, Reston, VA. 
Section 5: Selection of Pollutants for Regulation 

5-1 

5. SELECTION OF POLLUTANTS FOR REGULATION 

5.1. INTRODUCTION 

Construction and development (C&D) activities can generate a broad range of environmental 

impacts by introducing new sources of contamination and by altering the physical characteristics 

of the affected land area. In particular, those activities can result in both short- and long-term 

adverse effects on surface water quality in streams, rivers, and lakes in the affected watershed by 

increasing the loads of various pollutants in receiving waterbodies, including sediments, metals, 

organic compounds, pathogens, and nutrients. Ground water also can be adversely affected 

through diminished recharge capacity. Other potential effects include the physical alteration of 

existing streams and rivers due to the excessive flow and velocity of stormwater runoff. 

Construction activities typically involve excavating and clearing existing vegetation. During the 

construction period, the affected land is usually stripped and the soil compacted, leading to the 

potential for increased stormwater runoff and high rates of erosion. If the denuded and exposed 

areas contain hazardous contaminants or pollutants (either naturally occurring or from previous 

land uses), they can be carried at increased rates to surrounding waterbodies by stormwater 

runoff. Although the denuded construction site is only a temporary state (usually lasting less than 

6 months), the landscape is permanently altered even after the land has been restored by 

replanting vegetation. 

Pollutants associated with C&D stormwater discharges can adversely affect the environment in a 

number of ways. Potential effects include impairment of water quality, destruction of aquatic life 

habitats, and enlargement of floodplains. The Environmental Impact and Benefits Assessment for 

Final Effluent Guidelines and Standards for the Construction and Development Category (EPA 

2009b) discusses the potential affects of C&D stormwater runoff on the environment. The 

discussion in the remainder of this section focuses on those pollutants generated at a site during 

active construction. 

5.2. POLLUTANTS ASSOCIATED WITH CONSTRUCTION AND LAND 

DEVELOPMENT STORMWATER RUNOFF 

A number of pollutants are associated with C&D stormwater runoff. The descriptions of 

pollutants in this subsection do not represent the complete suite of contaminants that can be 

found in the runoff but focus instead on those that are known to be the most prevalent and of 

greatest concern to the environment. Those pollutants include sediment, metals, polycyclic 

aromatic hydrocarbons (PAHs), oil and grease, and pathogens. A more thorough discussion of 

pollutants and pollutant sources are in the Environmental Assessment document. 

5.2.1. SEDIMENT 

Sediment is an important and ubiquitous constituent in urban stormwater runoff. Surface runoff 

and raindrops detach soil from the land surface, resulting in sediment transport into streams and 

rivers. Sediment and turbidity can affect habitat, water quality, temperature, pollutant transport, 

and can cause sedimentation in downstream receiving waters. The effects of excess sediment in 
Section 5: Selection of Pollutants for Regulation 

5-2 

the water include direct physical effects such as reducing visibility and light in the water column, 

physical abrasion of plant surfaces, clogging gill openings, and entombing eggs and fry in redds. 

Effects can also be indirect, as in changes to the chemical composition (e.g., pH, hardness) of the 

water, light penetration or turbidity, and temperature profile, which in turn affect primary 

productivity with repercussions in terms of fish behavior, and overall community profiles and 

trophic structure. 

Sediment level measurement can be divided into several distinct subgroups: 

 Total suspended solids (TSS) are a dry-weight measure of the suspended particulate 

material in water. Measuring TSS in urban stormwater allows for estimation of 

sediment transport, which can have significant effects locally and in downstream 

receiving waters. TSS is typically measured in milligrams per liter (mg/L). 

 Turbidity is a measure of the amount of solids and other materials in the water. 

Turbidity readings are somewhat dependent on particle size, shape, and color. 

Turbidity is typically measured in nephelometric turbidity units (NTUs). Turbidity 

can exhibit control over biological functions, such as the ability of submerged aquatic 

vegetation to receive light. 

 Total dissolved solids are a measure of the dissolved constituents in water and are a 

primary indication of the purity of drinking water. 

 Settleable solids, expressed as milliliters per liter (mL/L), are a measure of the solids 

that will settle to the bottom of a cone-shaped container (called an Imhoff cone) in a 

60-minute period. Settleable solids are primarily a measure of particles that can be 

removed by sedimentation. 

 Suspended sediment concentration (SSC) is a measure similar to TSS; however, there 

are differences in the two analytical methods. SSC is determined by measuring the 

dry weight of all sediment from a known volume of sample. TSS is measured by 

filtering a subsample and measuring the weight of the dried solids. SSC and TSS 

values from the same sample can vary greatly, especially as the fraction of sand-sized 

particles in a sample increases. This is primarily because of the subsampling 

procedure involved in TSS calculations where typically a pipette is used to withdraw 

a subsample from the sample container. That procedure might not capture a 

representative fraction of larger particles in the subsample. The U.S. Geological 

Survey has analyzed differences attributable to the two methods and determined that 

SSC is a more appropriate measure of the mass of solids in natural-water samples 

(Gray et al. 2000). That might also apply to stormwater discharges, especially if a 

significant fraction of sand-sized particles are present. 

Erosion from construction sites can be a significant source of sediment pollution to nearby 

streams. A number of studies have shown high concentrations of TSS in uncontrolled runoff 

from construction sites, and results from the studies are summarized in Table 5-1. One study, 

conducted in 1986, calculated that construction sites are responsible for an estimated export of 

80 million tons of sediment into receiving waters each year (Goldman et al. 1986). On a unit area 

basis, construction sites can export sediment at 20 to 1,000 times the rate of other land uses 

(Schueler 1997).
Section 5: Selection of Pollutants for Regulation 

5-3 

Table 5-1. Studies of uncontrolled soil erosion as TSS from construction sites 

Site 

Mean inflow TSS 

concentration 

(mg/L) Source 

Seattle, Washington 17,500 Horner et al. 1990 

SR 204 3,502 Horner et al. 1990 

Mercer Island 1,087 Horner et al. 1990 

RT1 359 Schueler and Lugbill 1990 

RT2 4,623 Schueler and Lugbill 1990 

SB1 625 Schueler and Lugbill 1990 

SB2 415 Schueler and Lugbill 1990 

SB2 476 Schueler and Lugbill 1990 

SB4 2,670 Schueler and Lugbill 1990 

Pennsylvania Test Basin 9,700 Jarrett 1996 

Georgia Model 3,000 Sturm and Kirby 1991 

Maryland Model 3,000 Barfield and Clar 1985 

Uncontrolled Construction Site Runoff 

(Maryland) 

4,200 York and Herb 1978 

Hamilton County, Ohio 2,950 Islam et al. 1998 

Mean TSS (mg/L) 3,860 N/A 

N/A – Not Applicable 

For summaries of studies with monitoring or modeling data and annotated bibliographies for the 

journal articles and professional conference proceedings that the U.S. Environmental Protection 

Agency (EPA) reviewed, see Document Control Numbers (DCNs) 44321 and 43114. 

5.2.2. METALS 

Many toxic metals can be found in urban stormwater, although typically only metals such as 

zinc, copper, lead, cadmium, and chromium have been identified in the literature as being of 

primary concern because of their prevalence in urban stormwater runoff and their potential for 

environmental harm. Those metals are generated by motor vehicle exhaust, weathering of 

buildings, burning fossil fuels, atmospheric deposition, and other common urban activities. 

Metals can bioaccumulate in stream environments, resulting in plant growth inhibition and 

adverse health effects on bottom-dwelling organisms (Masterson and Bannerman 1994). 

Generally the concentrations found in urban stormwater are not high enough for acute toxicity 

(Field and Pitt 1990). Rather, it is the cumulative effect of the concentration of the metals over 

time and the buildup in the sediment and animal tissue that are of greater concern. 

Construction sites are not thought to be important sources of metals contamination. Runoff from 

such sites could have high metals contents if the soil is already contaminated, or if metals are 

naturally present in site soils. Imported fill can also be a source of contamination. Construction 

activities alone do not usually result in significant metals contamination, although there is little 

data available on this subject. 
Section 5: Selection of Pollutants for Regulation 

5-4 

5.2.3. PAHS, AND OIL AND GREASE 

Petroleum-based substances such as oil and grease and PAHs are found frequently in urban 

stormwater runoff. Many constituents of PAHs and oil and grease, such as pyrene and 

benzo[b]fluoranthene, are carcinogens and toxic to downstream biota (Menzie-Cura & 

Associates 1995). Oil and grease and PAHs normally travel attached to sediment and organic 

carbon. Downstream accumulation of these pollutants in the sediments of receiving waters such 

as streams, lakes, and estuaries is of concern. 

Construction activities during site development are not believed to be major contributors of these 

contaminants to stormwater runoff. Improper operation and maintenance of construction 

equipment at construction sites, as well as poor housekeeping practices (e.g., improper storage of 

oil and gasoline products and construction materials), could lead to leakage or spillage of 

products that contain hydrocarbons. 

5.2.4. PATHOGENS 

Microbes are commonly found in urban stormwater. Although not all microbes are harmful, 

several species such as the pathogens Cryptosporidium and Giardia can directly cause diseases 

in humans. The presence of bacteria such as fecal coliform bacteria, fecal streptococci, and 

Escherichia coli (i.e., E. coli) indicates a potential health risk. High levels of these bacteria can 

result in beach closings, restrictions on shellfish harvest, and increased treatment for drinking 

water to decrease the risk of human health problems. 

Construction site activities are not believed to be major contributors to pathogen contamination 

of surface waters. The only potential known source of pathogens from construction sites are 

portable septic tanks used by construction workers. Those systems, however, are typically selfcontained; although leaks or spills could result in releases. 

5.3. SELECTION OF POLLUTANTS FOR REGULATION 

When determining which pollutants to consider for regulation, EPA applied the following 

priorities for discharges from the C&D industry: 

 Focus on pollutants directly attributable to the industry, using indicator pollutants 

where necessary 

 Focus on pollutants most commonly encountered under most settings, (i.e., not to 

preconstruction site contamination issues or accidental discharges) 

 Focus on pollutants that are most manageable given the current suite of available 

technologies 

In support of the 2002 and 2004 regulatory efforts, EPA conducted an extensive evaluation of the 

literature to identify pollutants present in stormwater discharges from C&D sites. While the 

literature contains extensive information on pollutants present in stormwater discharges from 

urban areas, there were little data available on pollutants present in stormwater discharges from 

construction sites during the active phase of construction other than for sediment, TSS, and 

turbidity. That is not surprising, because construction site stormwater management is primarily 
Section 5: Selection of Pollutants for Regulation 

5-5 

concerned with controlling solids from exposed soil areas. There is the potential for other 

pollutants to be discharged from construction sites depending on factors such as prior land uses. 

For example, if the prior land use was agriculture, the potential exists for discharge of pollutants 

such as nutrients and pesticides. Likewise, areas of redevelopment that occur on sites where 

previous land uses included industry could discharge pollutants such as organics and metals. In 

addition, pollutants such as metals and nutrients can be present in native site soils and could be 

discharged from construction sites. Also, high pH can result from stormwater being exposed to 

freshly placed concrete. However, EPA was not able to identify sufficient data in the literature to 

warrant developing controls specific to pollutants other than sediment, TSS, and turbidity in 

stormwater discharges from active construction sites. Although EPA identified other pollutants 

of concern for the industry, EPA did not develop regulatory options specifically targeted at 

controlling each of these individual pollutants. The Environmental Assessment contains a more 

thorough discussion of pollutants found in stormwater discharges from construction sites. 

Instead, EPA chose to develop regulatory options using an indicator pollutant, turbidity. While 

turbidity might not correlate well with TSS, designing management systems for controlling 

turbidity will likely result in control of other pollutants such as TSS, nutrients, and metals that 

are present in the solid-phase (attached to sediments). In addition, turbidity, unlike TSS, can be 

measured with relative ease in the field using hand-held turbidity meters or automated, in-line 

turbidity meters. An in-line turbidity meter, coupled with a data logger, can offer real-time data 

on turbidity levels in stormwater discharges. 

Particles that contribute to turbidity can be of such a fine grain that they will not be removed by 

the mechanisms whereby most best management practices operate, mainly settling and filtration. 

Hence, the options developed for the final rule focus on passive and active treatment of 

stormwater runoff using polymers to remove turbidity, as well as TSS and other pollutants. 

Section 7 discusses technologies designed to reduce and remove such fine colloidal particles. 

5.4. REFERENCES 

Barfield, B.J., and M. Clar. 1985. Development of New Design Criteria for Sediment Traps and 

Basins. Prepared for the Maryland Resource Administration, Annapolis, MD. 

Goldman, S.J., K. Jackson, and T.A. Bursztynsky. 1986. Erosion and Sediment Control 

Handbook. McGraw-Hill, New York. 

Gray, J.R., D. Glysson, L.M. Turcios, and G.E. Schwarz. 2000. Comparability of SuspendedSediment Concentration and Total Suspended Solids Data. Water-Resources Investigation 

Report 00-4191. U.S. Geological Survey, Reston, VA. 

Field. R., and R.E. Pitt. 1990. Urban Storm-Induced Discharge Impacts: U.S. Environmental 

Protection Agency Research Program Review. Water Science and Technology 22(10/11):1–7. 

Horner, R.R., J. Guedry, and M.H. Kortenhof. 1990. Improving the Cost Effectiveness of 

Highway Construction Site Erosion and Pollution Control. Washington State Transportation 

Center and the Federal Highway Administration. Seattle, WA. 
Section 5: Selection of Pollutants for Regulation 

5-6 

Islam, M.M., D. Taphorn, and H. Utrata-Halcomb. 1998. Current Performance of Sediment 

Basins & Sediment Yield Measurement of Construction Sites in Unincorporated Hamilton 

County, Ohio. Prepared for Hamilton County Soil and Water Conservation District, 

Cincinnati, OH. 

Jarrett, A. 1996. Sediment Basin Evaluation and Design Improvements. Prepared for Orange 

County Board of Commissioners, Hillsborough, NC, by Pennsylvania State University, State 

College, PA. 

Masterson, J.P., and R.T. Bannerman. 1994. Impacts of Stormwater Runoff on Urban Streams in 

Milwaukee County, Wisconsin. In Proceedings of American Water Resources Association, 

National Symposium on Water Quality, Nov. 6–10, 1994, Chicago, IL, pp. 123–133. 

Menzie-Cura & Associates. 1995. Measurements and Loadings of Polycyclic Aromatic 

Hydrocarbons (PAH) in Stormwater, Combined Sewer Overflow. MBP-95-06. Massachusetts 

Bay Program, MA. 

Schueler, T. 1997. Impact of Suspended and Deposited Sediment. Article 14 in The Practice of 

Watershed Protection, eds. T.R. Schueler and H.K. Holland, pp. 64–65. Center for 

Watershed Protection, Ellicott City, MD. 

Schueler, T., and J. Lugbill. 1990. Performance of Current Sediment Control Measures at 

Maryland Construction Sites. Metropolitan Washington Council of Governments, 

Washington, DC. 

Sturm, T.W., and R.E. Kirby. 1991. Sediment Reduction in Urban Stormwater Runoff from 

Construction Sites. Georgia Institute of Technology, Atlanta, GA. 

USEPA (U.S. Environmental Protection Agency). 2009b. Environmental Impact and Benefits 

Assessment for Final Effluent Guidelines and Standards for the Construction and 

Development Category (EPA-821-R-09-012). U.S. Environmental Protection Agency, Office 

of Water, Washington, DC. 

York T.H., and W.J. Herb. 1978. Effects of Urbanization and Streamflow on Sediment Transport 

in the Rock Creek and Anacostia River Basins. Montgomery County, MD, 1972-1974. 

U.S. Geological Survey Professional Paper No. 1003. U.S. Geological Survey, Reston, VA. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-1 

6. LIMITATIONS AND STANDARDS: DATA SELECTION AND 

CALCULATION 

6.1. INTRODUCTION 

This section describes the data selection and statistical methodology used by the 

U.S. Environmental Protection Agency (EPA) in calculating the limitations and standards for the 

Construction and Development (C&D) point source category. As is the case for most effluent 

limitation guidelines and standards, the effluent limitations and standards are based on long-term 

average effluent values and variability factors that account for variation in treatment performance 

within a particular treatment technology over time. For simplicity, the following discussion 

refers only to effluent limitations guidelines; however, the discussion also applies to new source 

standards. 

EPA is promulgating a daily maximum limitation for turbidity, and Section 6.2 briefly describes 

the pollutant parameter. Section 6.3 provides an overview of EPA’s criteria typically used to 

select data sets used as the basis for limitations. Section 6.4 describes the available discharge 

data sets that met the criteria. Section 6.5 describes the data sets that were excluded as a result of 

applying the criteria. Section 6.6 verifies that the individual values within the retained data sets 

also are appropriate as the basis of the limitation. Sections 6.7 and 6.8 provide summaries of the 

data before and after averaging to obtain daily values. Section 6.9 provides an overview of the 

limitations, percentile basis, and calculations. Section 6.10 describes the engineering review of 

the limitations. Sections 6.11 and 6.12 discuss issues related to monitoring and compliance with 

the limitation. Section 6.13 summarizes the steps used to calculate the limitations. Section 6.14 

provides references. 

In the proposed rule, EPA also was considering a limitation on pH to protect against extreme 

acidity or alkalinity. EPA has not promulgated a pH limitation for the final rule. 

6.2. TURBIDITY 

As described in Section 5 and in more detail in the Environmental Assessment, there are a 

number of pollutants associated with discharges from C&D sites. EPA is promulgating effluent 

limitations for turbidity, as an indicator of the presence of those pollutants being discharged from 

the C&D site. Turbidity is a simple measurement that requires only the use of a turbidimeter and 

can be conducted in the field. Readings are made in nephelometric turbidity units or NTUs. 

Turbidity measurement does not require any sample preparation, other than shaking the sample 

bottle well before analysis. The sample is simply poured into a glass tube and placed inside the 

calibrated instrument. The result is read directly from the instrument. There are also a variety of 

digital turbidity probes, which can be coupled with a microprocessor controlled data logger and 

combination meter/data loggers available that can be used to automatically read and log turbidity 

values in-situ. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-2 

6.3. OVERVIEW OF DATA REVIEW AND CRITERIA 

To develop a limitation, EPA generally seeks to obtain as much monitoring data as possible on 

the effectiveness of the different treatment options it evaluates, through solicitation of 

information from the public and industry. Here, EPA received data from a number of treatment 

technology vendors, but no data from the regulated industry. As described in Sections 6.4, 6.5, 

and 6.6, EPA qualitatively reviewed all the data before selecting a large subset to calculate the 

limitations. In selecting the data, EPA applied the following criteria in determining if the data 

were appropriate to use as the basis for the final rule. In its rulemakings for other industries, EPA 

has used the same or similar criteria to develop the limitations and standards. 

One criterion requires that the influents and effluents from the treatment components represent 

typical wastewater (or in the case of the C&D industry, stormwater) from the industry, with no 

significant incompatible wastewater from other sources (e.g., sanitary wastes). Application of 

this criterion results in EPA selecting only those sites where the commingled wastewaters did not 

result in substantial dilution, more concentrated wastewaters, or wastewaters with different types 

of pollutants than those generated by C&D wastewater. 

A second criterion ensures that the pollutants were present in the influent at sufficient 

concentrations to evaluate treatment effectiveness. By verifying that influent includes 

measureable solid content, EPA ensures that its limitations resulted from treatment and not 

simply the absence of turbidity in the wastestream. 

A third criterion generally requires that the system demonstrate good operation of the model 

treatment technology. EPA determines whether a system meets this criterion on the basis of 

documentation about the system installed at the site, discussions with site management, 

evaluation of site diagrams, and comparison to the performance of treatment systems at other 

sites. In addition, because control of turbidity at construction sites is a function of up-slope 

erosion and sediment controls, as well as proper application and sizing of passive treatment 

controls, EPA also evaluated whether the overall site controls (if information was available) were 

representative of BAT, and whether controls were adequately sized, operated and maintained and 

whether a particular site would represent typical site conditions. In general, EPA reviewed this 

information to determine if the system was adequately sized; properly operated and maintained; 

and whether the resulting data represent typical site conditions. As a result of these 

communications and reviews, EPA determined that some data were representative of normal 

operating conditions for the facility and that the level of treatment was adequate, and excluded 

data that reflected a technology application that did not coincide with the selected BAT and/or 

where the overall site controls were deemed to be inadequate. 

A fourth criterion typically requires that the data cannot represent periods of treatment upsets or 

shut-down periods. This criterion sometimes results in the exclusion of periods when the site first 

starts operating the equipment (start-up). Although this criterion is more applicable to 

wastewater treatment than stormwater management practices at construction sites, there are some 

similarities in this case (for example, non-optimized dosage rates). As result of this criterion, 

EPA could exclude certain time periods and other outliers in the data from an otherwise welloperated site. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-3 

EPA has not included the size of the site as a criterion, because the site size and associated runoff 

volumes determine the design and size of the management practices, rather than its performance.

6.4. DATA SELECTED AS BASIS FOR LIMITATIONS 

As a consequence of applying the four criteria, EPA selected only data that were representative 

of the model technology, which in this case is polymer-aided settling. All of the sites used by 

EPA as the basis for the limitation employed either polymer-aided settling in ponds (using either 

chitosan acetate, chitosan lactate or PAM) or polymer-aided settling/filtration using check dams. 

EPA is confident that the resulting database fully characterizes the performance of the model 

technology for all C&D sites subject to the limitation for several reasons: 

1. Theoretically, there is no reason that the technology cannot be applied everywhere. It 

is a simple technology that only requires appropriate sizing of the ponds and 

conveyances, applying the correct polymer, using the appropriate dosing schedule, 

and conducting needed maintenance activities. 

2. Different soil types and rainfall amounts are managed by sizing the ponds and 

conveyances properly, providing adequate detention time for settling, applying the 

correct polymer, and using the appropriate dosing schedule. For example, if the soil 

(e.g., clay) does not readily infiltrate rainfall, then the storage volume would need to 

be larger than one at a site with more porous soil. In another example, if the site has a 

steeper slope, then the site might contain more check dams per channel than a more 

level site. 

3. Size of the site is managed by placing the appropriate number of systems on the site 

and/or sizing the ponds and conveyances properly. 

4. The model technology, polymer aided settling, has widespread use across a wide 

range of industries (e.g., POTWs, drinking water treatment, industrial wastewater 

treatment) for solids control. In the industries which have used this technology for 

decades, it has been successful. It is less prevalent in the C&D industry because 

managing turbidity in stormwater discharges has not been required until recently. 

EPA’s database of performance data includes more than 29,000 turbidity measurements that 

were used as the basis for the limitation. The data were from 25 treatment systems at 9 sites in 

three states and covers both the Eastern and Western Unites States and a range of construction 

types. The data were provided by two commercial firms (Cascade EcoSolutions and Clear Water 

Compliance Services) and researchers at North Carolina State University. Table 6-1 identifies 

the data sources, the site name or location, and the abbreviations used to identify the systems at 

those sites. These abbreviations are used throughout Chapter 6 and the data listings in 

Appendix F. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-4 

Table 6-1. Data sources and site identification for systems using EPA’s model technology basis 

Source Site name or location Abbreviation 

Construction 

type 

Beacon Hill Reservoir Burying Project, 

Seattle, WA BHRBP Other 

Brightwater Waste Water Treatment Plant in 

King County, WA BWWTP Commercial 

Sea-Tac Airport in King County, WA SEAAIR Transportation

Cascade 

EcoSolutions 

Sound Transit Central Link Light Rail 

Tacoma/Seattle, WA STCLLR Linear 

Beacon Hill Reservoir Burying Project, 

Seattle, WA 

BHRBP2 * Linear 

Sea-Tac Airport in King County, WA KC-variations Transportation

Springville, NY highway widening NY Transportation

Clear Water 

Compliance Services, 

Inc. 

Redmond, WA residential project Red.East, 

Red.West Residential 

North Carolina mountain roadway project in 

2006-7 

NCR.1 

NCR.2 Transportation NCSU Research 

(McLaughlin, et al) North Carolina mountain roadway project in 

2008 NC.Road Transportation

* Because BHRBP2 is a more complete data set, it was used to calculate the long-term average and variability factor for this site. 

6.4.1. CASCADE ECOSOLUTIONS 

Cascade EcoSolutions is a vendor that provides the chitosan-based flocculants used by service 

providers to treat turbid stormwater. For the proposed rule, Cascade EcoSolutions provided 

influent and effluent data for the advanced treatment system (ATS) at six sites in Washington 

State. After the proposal, EPA contacted the vendor for more details about the influent data. The 

vendor confirmed that the influent to ATS for four of the sites was effluent from passive 

treatment systems, that is, the model technology for the final rule. As a result, EPA concluded 

that the data from the four sites were appropriate to use in developing the final limitation that is 

based on passive treatment systems. The four sites are all in the Seattle area in Washington: 

 Beacon Hill Reservoir Burying Project (BHRBP) 

 Brightwater Wastewater Treatment Plant (BWWTP) 

 Sea-Tac Airport (SEAAIR) 

 Sound Transit Central Link Light Rail (STCLLR) 

For three sites, BHRBP, BWWTP, and STCLLR., the vendor provided turbidity measurements 

via a ChitoVan Performance Review Data Set (Cascade EcoSolutions 2008). For SEAAIR, the 

vendor provided detailed information about the treatment and sites in an engineering report 

(Minton 2006) and a separate Engineering Report Data file (Cascade EcoSolutions 2008). The 

report identifies the SEAAIR project as supporting the construction of Sea-Tac’s third runway. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-5 

6.4.2. CLEAR WATER COMPLIANCE SERVICES, INC. 

Clear Water Compliance Services Inc. provides comprehensive water treatment services 

including the design, installation, and monitoring of treatment systems for stormwater and 

construction runoff. The company provided data for the following 20 systems using the model 

technology: 

 16 systems at the third runway at Sea-Tac airport. These data sets are identified as KC 

for King County followed by the Site number (or pond), and then system number. For 

example, KC1.1 is the first system at site 1. 

 One system at a highway widening site in Springville, New York. This data set is 

identified as “NY.” 

 Two systems at an 18-acre residential development project in Redmond, Washington. 

They installed a 250 gallons per minute (gpm) treatment system at the West Basin 

and a 500 gpm treatment system at the East Basin, both of which operated over a 2 

year period. The data sets are identified as Red.West and Red.East. 

 One system at a large infrastructure project that is part of the City of Seattle’s 

Reservoir Burying Program. The project involved demolition of an existing reservoir 

and re-building of a large vault-reservoir that was then buried below the surface and 

had a park built over the top. The site area for this site was approximately 22 acres. 

The data set is identified as BHRBP2 to distinguish it from the Cascade EcoSolutions 

data for this site. 

6.4.3. RESEARCH BY NORTH CAROLINA STATE UNIVERSITY 

Dr. Richard A. McLaughlin and others at North Carolina State University studied stormwater 

runoff from three systems for erosion and sediment control on two roadway projects in the North 

Carolina mountains. EPA determined that three of the systems were consistent with its model 

technology: 

 NC.Road is described in a paper Target Turbidity Limits for Passive Treatment 

Systems (McLaughlin No Date) that provides data for from September 2008 to 

January 2009. 

 NCR.1 and NCR.2 are described in the Journal of Soil and Water Conservation 

(McLaughlin 2009). The systems were installed as part of a university research 

project. The measurements were collected from June 2006 to October 2006 at road 

widening and paving projects in the North Carolina mountains. 

6.5. SYSTEMS EXCLUDED AS BASIS FOR LIMITATION 

EPA excluded data from all systems that did not meet the criteria described in Section 6.3. Table 

6-2 summarizes the system exclusions and EPA’s rationale for each. In all cases, the data 

represented a different technology, such ATS, than the model technology basis for the regulation. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-6 

Table 6-2. Systems Excluded as Basis for Limitation 

Source Site name or location Abbreviation Reason for exclusion 

2 

3 

4 

6 

8 

11 

BZR08 

SC05 

Clear Creek Systems, 

Inc. (proposal data) 

California, Oregon, and 

Washington 

SC08 

The effluent data are from 

ATS. Influent data is 

influent into the 

pretreatment pond. The 

vendor did not collect 

data after the 

pretreatment pond but 

before ATS filtration, and 

thus, the influent does not 

represent EPA’s model 

technology. 

WSDOT SR-522 Road 

Improvement Project (Elliot 

Road) 

ELLRD 

The effluent data 

represent ATS which is 

not EPA’s model 

technology. Cascade EcoSolutions 

(proposal data) 

Lakeside LSIDE 

The effluent data 

represent ATS. The 

influent data were not 

pretreated with EPA’s 

model technology. 

West Linn Corporate Park WLCPO Oregon Department of 

Environmental Quality 

(proposal data, Jurries 

no date)

Hoodview Estates HEO 

The effluent data 

represent ATS. The 

influent data were not 

pretreated with EPA’s 

model technology. 

Resource Planning 

Associates (41107) and 

Minton (41108) 

Six systems at a commercial 

site in Redmond, CA RED.1-RED.6 

These sites used batch 

treatment in cells, which 

is more extensive than 

EPA’s model technology. 

Clear Water 

Compliance Services 

Morrisville, NC, was a 

commercial site with a runoff 

area of 82 acres and two 

treatment systems. 

not incorporated into 

EPA’s databases 

Data were provided only 

as minimum and 

maximum values which 

could not be used to 

calculate daily averages. 

6.6. APPLICATION OF CRITERIA TO LIMITATION DATA SETS 

After excluding data sets from systems that were not representative of the model technology for 

C&D wastewaters, EPA performed a final review of the individual data points from the systems 

that it had selected as the basis of the limitations. For this review, EPA returned to the criteria 

identified in Section 6.3 and applied each one to the data sets identified in Table 6-1. 

The first criterion ensures that the wastewater contains primarily stormwater associated with 

C&D operations. EPA considered two aspects, post-paving conditions and recirculation, in 

evaluating the data for this criterion: 

 Post-paving conditions: The journal article describing NCR.1 and NCR.2 included 

data after the pavement was complete. EPA determined that post-paving conditions 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-7 

were not representative of C&D discharges, and excluded them as the basis of the 

limitation. 

 Recirculation: EPA has not excluded any data from systems that recycled effluent. 

Although some of the sites recycled water after ATS filtration to the pretreatment 

ponds, EPA determined that this practice would have little overall effect on turbidity 

within the basin because the recycle flow rate is small in comparison to the storage 

volumes contained in the ponds. In addition, other inputs into the pond from surface 

runoff would be expected. Before determining that the data of such systems should be 

included as the basis of the limitation, EPA considered the effect of recirculation on 

treatment performance. If recirculation had an impact, it would be expected to dilute 

the resulting effluent to lower concentration levels. 

To evaluate whether this was the case, EPA evaluated the SEAAIR data set, which was one data 

set that indicated when recirculation occurred. EPA evaluated the individual measurements and 

the daily averages derived from them. 

 Individual measurements: Of the 31 recirculation events (some had multiple events 

per day), 16 had increased turbidity in the subsequent reading, and 14 had less (one 

reading was the final of the day and therefore had no subsequent reading). EPA then 

considered effluent concentration reported for the reading during recirculation and the 

following measurement. The effect is more pronounced with increased turbidity for 

30 measurements and less turbidity for 18. Both evaluations indicate that the effluent 

concentrations tended to increase after circulation at this location. 

 Daily averages: On the five days when recirculation occurred, the observed daily 

averages were greater on four days and lower on one when including the recirculation 

events. In each case, the change was less than 6 percent. 

Because the effect of recirculation was the opposite from what would be expected if dilution 

were the only influence (i.e., the effluent turbidity values were generally more concentrated (i.e., 

higher) not dilute), EPA concluded that recirculation did not appear to have a significant effect 

on effluent concentrations. Instead, the higher turbidity values might be from sediment 

resuspension in the pretreatment pond due to the turbulence caused by the recycled water. In 

addition, additional inputs to the pond from surface runoff, groundwater flows, and activities 

such as dewatering operations on the site could have contributed additional volume to the ponds, 

which would also affect the effluent turbidity. Because the recirculation did not appear to 

significantly influence effluent turbidity, EPA determined that it was appropriate to retain all of 

the data, including data from time periods where recirculation was occurring, in its limitation 

data set. 

The second criterion ensures that the effluent levels are the result of treatment rather than dilute 

influent. Although most of the effluent data were not paired with the corresponding influent, 

based upon its review of the existing data and other sources that describe C&D stormwater (see 

Section 5), EPA is confident that turbidity would have been present at any site, and thus, has not 

used this criterion to exclude any data set. Influent into the passive treatment system is affected 

by many parameters. EPA examined the data in several ways. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-8 

 EPA considered whether the influents were likely to be more concentrated than the 

effluents. McLaughlin (2009) provides turbidity concentrations from a section of the 

roadway construction project with standard best management practices (BMP) for the 

NCR.1 site. Both sections of the project would be expected to have similar soil types, 

rainfall, and other characteristics. By comparing data from the two sections, EPA was 

able to obtain a lower bound of the difference between untreated stormwater and 

PAM-treated stormwater. That is, EPA would expect even more of a difference than 

the results using BMP data. Considering only the days when measurements were 

made at both sections, the BMP site removed turbidity to a level of 3669 NTU, while 

the model technology (fiber check dams with PAM) removed turbidity to a level of 

26.8 NTU for a removal of 99 percent. EPA performed a similar comparison for the 

NCR.2 data and found a removal of 97 percent. This finding demonstrates that 

influent would be substantially greater than effluent from the model technology. 

 EPA examined the literature to determine turbidity in stormwater generated at 

construction sites. EPA evaluated a variety of literature sources, and summarized 

numerous studies evaluating the effectiveness of sediment basins, which are among 

the most common management practices used at construction sites. The literature 

indicates that stormwater discharges into sediment basins had turbidity values ranging 

from tens of NTUs to tens of thousands of NTUs (see DCN 44321). Therefore, 

turbidity and sediment are clearly present in construction site stormwater.

The third criterion requires that the system demonstrate good operation of the model treatment 

technology. EPA had limited information about whether the treatment technology was well 

operated. However, because this technology is relatively simple, EPA chose to assume that most 

effluent data from the model technology represented good performance. In evaluating this 

criterion, EPA identified several areas that needed additional engineering investigation: 

 Red.East and Red.West are two systems at the same residential site. The two systems 

generally demonstrate larger turbidity values than the other systems. Because these 

basins were pretreatment basins before ATS filtration, the general goal at this site (as 

well as other ATS sites used in the calculation of the limitation) was to reduce the 

turbidity to a level that is acceptable for filtration, which is usually less than 500 

NTUs. Therefore, the dosage rate at this site was likely not optimized to reduce 

turbidity to low levels (because that was not the goal of the pretreatment basin), but 

the basin did remove significant turbidity. Because the range of data values were 

generally within the range observed by the other systems in the data set (although 

more often in the high end), EPA retained the data for both systems as the basis for 

the limitation.

 NCR.1: The discharge of 335 NTU on 7/25/06 was much greater than the other 

values observed at this site. In the engineering review, EPA contacted the author and 

EPA learned that a utility company had buried a line in the center of the treatment 

ditch after moving the wattles out of the way. Although the wattles were returned to 

the ditch, they were not stapled in which is essential to proper operation. 

Consequently, the system performed poorly even during relatively little rain (9 mm). 

Because the system was not installed properly on that day, EPA excluded the value as 

a basis for the limitation. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-9 

 NCR.2: The discharge of 533 NTU on 9/24/08 was much greater than the other 

values observed at this site. EPA contacted the author to obtain additional information 

on the data. Although the author was not able to provide any specific information on 

site activities that may have contributed to the much higher value on that day, EPA 

determined that because this data point was not consistent with other data from this 

site and from NCR.2 that this data point was likely not representative of normal 

operation. Therefore, this data point was excluded from calculation of the limitation.

The fourth criterion ensures that the data represent normal operations. EPA’s application of the 

criterion excluded all turbidity measurements with zero values and/or associated with no flow. 

6.7. SUMMARY OF LIMITATION DATA AND DATA CONVENTIONS 

In developing the limitation, EPA focused its review on the performance and operating 

conditions of sites that used systems that were consistent with EPA’s model technology. Table 

6-3 provides a summary of the reported turbidity measurements from the 25 systems with the 

model technology (Section 6.4). EPA received more than 29,000 measurements of turbidity from 

systems that met the requirements for EPA’s model technology. These data are provided in 

Listing 1 of Appendix F. (DCN 42107 provides the data in an electronic spreadsheet file.) This 

section describes EPA’s review of the data, identifies data issues, and explains the rationale for 

excluding certain data points from the limitations calculations. 

EPA excluded the data for BHRBP (from Cascade EcoSolutions), because the data for BHRBP2 

(from Clean Water) contained many of the same measurements taken at the same monitoring 

point at the same time. Although there were a few differences, overall, measurements were the 

same for sample dates summarized in both files. Because BHRBP2 provided data for a longer 

period of time, EPA retained this data set and excluded the BHRBP from its calculations and 

data listings. 

Table 6-3. Summary of reported turbidity measurements (NTU) in effluent 

(individual measurements before daily average calculations) 

System 

Number of 

values 

Average 

(NTU) 

Standard 

deviation Minimum Median Maximum 

BHRBP2 3,260 73.964 92.456 3.1 47.2 989.7 

BWWTP 104 113.579 57.366 2.7 135.25 284 

KC1.1 1,374 59.256 36.703 6 51.3 365.2 

KC1.2 1,723 61.272 40.033 6.7 50.7 388.2 

KC1.3 610 56.131 20.084 6.6 51.9 213.9 

KC1.4 127 42.649 11.79 17.3 45.3 114.3 

KC1.5 822 42.677 18.16 5.2 39.6 193 

KC2.1 1,616 90.528 49.272 8 81.6 637.5 

KC2.2 1,476 91.243 47.118 2.5 82.35 644.8 

KC2.3 1,928 70.314 41.326 4.4 63.1 574 

KC2.4 1,034 74.662 48.28 10.4 69 695.2 

KC2.5 1,178 71.082 45.01 1.8 62.45 695.7 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-10 

System 

Number of 

values 

Average 

(NTU) 

Standard 

deviation Minimum Median Maximum 

KC3.1 594 55.245 23.042 12.1 58.1 320 

KC3.2 620 55.265 34.903 8.7 56.75 486.6 

KC3.3 721 48.263 24.176 10.1 41.4 195.9 

KC3.4 622 52.792 21.799 0.4 54.6 224.6 

KC3.Pond 110 48.136 18.453 10.4 45.45 130.9 

NC.Road* 339 

NCR.1** 105 46.12 

NCR.2** 9 61.22 

NY 7,089 101.466 82.395 1.6 90.4 1,000.9 

Red.East 3,467 256.524 201.905 1.6 202.7 1,000.9 

Red.West 762 132.949 104.745 1.4 117.45 614.1 

SEAAIR 366 108.406 33.327 24.51 108.545 209.22 

STCLLR 196 66.009 46.555 4.7 57.3 293.9 

OVERALLa,b > 29,913 0.4 1,000.9

a. The data for NC.Road included the mean, standard deviation and maximum value for each of 7 days. Because the number of 

values used to calculate these statistics is not known, the only value that can be reported on this table for NC.Road is the maximum. 

b. The data from NCR.1 and NCR.2 included the mean and the number of observations for each day. Samples collected at this site 

were composites for the entire storm event. Therefore, the only values that can be reported on this table for NCR.1 and NCR.2 are 

the number of values and the mean. 

6.8. DATA AVERAGING PRIOR TO LIMITATION CALCULATIONS 

The limitations for turbidity, as presented in today’s notice, are provided as the maximum daily 

discharge limitation. Definitions provided in 40 CFR 122.2 state that the maximum daily 

discharge limitation is the highest allowable daily discharge. The definitions also state that 

“[d]aily discharge means the discharge of a pollutant measured during a calendar day or any 

24-hour period that reasonably represents the calendar day for purposes of sampling.” 

In calculating the limitations, EPA analyzed the data from each treatment system separately, 

even if the systems were located at the same site. (This is consistent with EPA’s practice for 

other industrial categories.) To be consistent with the daily discharge definition, EPA 

arithmetically averaged all measurements recorded for each day from each treatment system 

before calculating the limitations. EPA refers to this averaged value as the daily value. 

Listing 2 of Appendix F identifies the 914 daily values obtained from arithmetically averaging 

the values summarized in Table 6-3. Table 6-4 provides a summary of the daily values. From the 

25 treatment systems, EPA observed a minimum daily value of 2.5 (NY) to a maximum of 672 

NTU (Red.East). 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-11 

Table 6-4. Summary of daily values of turbidity (NTU) in effluent 

System 

Number of 

daily values 

Arithmetic 

average 

Standard 

deviation Minimum Median Maximum 

BHRBP2 116 69.02 57.57 12.00 53.05 527.75 

BWWTP 8 68.43 60.00 12.70 34.88 151.30 

KC1.1 28 54.66 18.72 21.85 51.01 103.39 

KC1.2 32 54.61 20.95 13.90 50.39 117.17 

KC1.3 10 54.63 12.52 41.76 51.26 85.66 

KC1.4 3 44.86 7.06 38.63 43.42 52.53 

KC1.5 16 41.61 10.37 32.13 38.77 75.88 

KC2.1 33 79.53 33.05 23.32 73.98 154.77 

KC2.2 30 82.00 37.70 21.12 76.14 192.14 

KC2.3 40 61.56 26.77 21.65 58.82 130.94 

KC2.4 23 60.00 33.55 23.52 51.49 152.17 

KC2.5 19 65.86 23.60 34.08 64.23 117.74 

KC3.1 13 48.27 18.58 18.30 44.34 79.02 

KC3.2 13 48.17 20.81 18.02 47.14 79.96 

KC3.3 15 40.53 21.57 14.78 35.19 79.01 

KC3.4 15 42.98 20.26 15.58 44.73 73.54 

KC3.Pond 7 43.93 13.78 25.13 42.09 63.99 

NC.Road 7 55.14 50.81 11.00 40.00 167.00 

NCR.1 12 37.75 28.98 9.00 31.00 109.00 

NCR.2 3 49.67 37.82 15.00 44.00 90.00 

NY 220 96.50 52.89 2.50 95.64 549.39 

Red.East 169 209.73 143.99 5.35 195.03 672.65 

Red.West 56 107.96 81.53 11.92 91.86 341.21 

SEAAIR 9 103.39 35.61 34.84 105.75 155.92 

STCLLR 17 61.05 34.97 11.22 56.68 161.76 

Total 914 100.49 93.08 2.50 71.43 672.65 

6.9. LIMITATION CALCULATIONS 

The limitations for turbidity, as presented in today’s notice, are provided as the maximum daily 

discharge limitation. This section describes the statistical percentile basis of the limitation 

(Section 6.9.1), the concepts and calculations for the long-term average, the variability factor, 

and the limitation (Sections 6.9.2, 6.9.3, and 6.9.4). Section 6.9.5 describes autocorrelation and 

its effect on the value of the limitation. 

6.9.1. STATISTICAL PERCENTILE BASIS FOR LIMITATIONS 

The daily maximum limitation is an estimate of the 99th percentile of the distribution of the daily 

measurements. EPA calculates the daily maximum limitation on the basis of a percentile chosen 

with the intention, on one hand, to accommodate reasonably anticipated variability within the 

control of the site and, on the other hand, to reflect a level of performance consistent with the 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-12 

Clean Water Act requirement that the BAT effluent limitation and NSPS be based on welloperated and maintained facilities. The percentile for the daily maximum limitation is estimated 

using the product of the long-term average and the variability factor derived from data that 

represent the performance of the model technology under all conditions when properly operated 

and controlled. For the rule, EPA estimated the long-term average and variability factor using a 

statistical model based on the lognormal distribution as described in Appendix G. 

6.9.2. LONG-TERM AVERAGE 

In the first of two steps in estimating the different types of limitations, EPA determines an 

average performance level (the long-term average) that systems representing well-designed and 

operated model technologies (which reflect the appropriate level of control) are capable of 

achieving. This long-term average is calculated from the data from the sites using the model 

technology. The long-term average of 64.13 NTU is the median value of 25 long-term averages 

collected from the 25 treatment systems. The long-term averages ranged from a minimum of 37 

NTU (NCR.1) to a maximum of 251 NTU (Red.East). The median is the midpoint of the 25 

values, and is the 13th largest value, which is associated with KC2.4. As a consequence of using 

the median, 12 of the system-specific averages are above the long-term average and 12 are 

below, as shown in Table 6-5. EPA expects that all sites subject to the limitations will design and 

operate their treatment systems to achieve the long-term average performance level on a 

consistent basis because sites with well-designed and operated model technologies have 

demonstrated that this can be done. 

Table 6-5. System-specific long-term averages used in limitation calculations 

System 

Number of 

daily values 

Long-term 

average (NTU) 

Rank 

(smallest=1) 

BHRBP2 116 68.96 15 

BWWTP 8 132.41 23 

KC1.1 28 55.81 10 

KC1.2 32 56.08 11 

KC1.3 10 55.77 9 

KC1.4 3 46.66 3 

KC1.5 16 42.09 1 

KC2.1 33 82.67 17 

KC2.2 30 85.96 18 

KC2.3 40 63.52 12 

KC2.4 23 64.13 13 (median) 

KC2.5 19 68.46 14 

KC3.1 13 52.53 7 

KC3.2 13 53.09 8 

KC3.3 15 44.88 2 

KC3.4 15 47.84 6 

KC3.Pond 7 47.59 5 

NC.Road 7 88.19 19 

NCR.1 12 47.11 4 

NCR.2 3 194.31 24 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-13 

System 

Number of 

daily values 

Long-term 

average (NTU) 

Rank 

(smallest=1) 

NY 220 105.20 20 

Red.East 169 251.48 25 

Red.West 56 122.70 22 

SEAAIR 9 117.79 21 

STCLLR 17 70.40 16 

Median LTA 64.13 

6.9.3. VARIABILITY FACTOR 

EPA acknowledges that variability around the long-term average results from normal operations. 

This variability means that occasionally sites can discharge at a level that is greater than the 

long-term average. This variability also means that sites can occasionally discharge at a level that 

is considerably lower than the long-term average. Consequently, in the second step of developing 

a limitation, EPA determines an allowance for the variation in pollutant concentrations when 

processed through well-designed and operated treatment systems. This allowance for variance 

incorporates all components of variability including process and wastewater generation, sample 

collection, shipping, storage, and analytical variability. This allowance is incorporated into the 

limitations through the use of the variability factors, which are calculated from the data from the 

sites using the model technology. The variability factor of 4.322 is the arithmetic average (or 

mean) of 25 variability factors collected from the 25 systems also used as the basis of the longterm average. Table 6-6 provides the 25 system-specific variability factors. The variability 

factors ranged from a minimum of 1.775 (KC1.5) to a maximum of 10.203 (BWWTP), and were 

calculated as shown in Appendix G. 

Table 6-6. System-specific variability factors used in limitation calculations 

System 

Number of daily 

values 

Daily variability factor 

(VF1) 

BHRBP2 116 3.642 

BWWTP 8 10.203 

KC1.1 28 2.283 

KC1.2 32 2.508 

KC1.3 10 1.867 

KC1.4 3 1.953 

KC1.5 16 1.775 

KC2.1 33 2.890 

KC2.2 30 3.104 

KC2.3 40 2.845 

KC2.4 23 3.646 

KC2.5 19 2.576 

KC3.1 13 3.219 

KC3.2 13 3.503 

KC3.3 15 3.878 

KC3.4 15 3.819 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-14 

System 

Number of daily 

values 

Daily variability factor 

(VF1) 

KC3.Pond 7 2.809 

NC.Road 7 8.135 

NCR.1 12 5.859 

NCR.2 3 12.968 

NY 220 4.140 

Red.East 169 6.391 

Red.West 56 5.934 

SEAAIR 9 3.586 

STCLLR 17 4.513 

Mean VF1 4.322 

In its evaluation of the daily variability factor, because it has not regulated turbidity for other 

industries, EPA compared the daily variability factor developed from the C&D data with 

variability factors developed for TSS effluent limitations guidelines and standards promulgated 

during the past 12 years for various industrial categories. Because turbidity and TSS are treated 

similarly by treatment systems, EPA would expect TSS levels and turbidity to exhibit similar 

daily variability factors. While turbidity represents the appropriate parameter to regulate for 

pollutant control in C&D discharges rather than TSS,1

 EPA looked at TSS variability factors as a 

check on its calculated turbidity daily variability factor. As shown in Table 6-7, the values for the 

variability factors are relatively close in value, ranging from 2.9 to 5.4, with an arithmetic 

average of 4.1 which is close to the variability factor of 4.322 calculated for the C&D turbidity 

limitation. EPA concluded that the value of 4.322 ensures a level of control that EPA considers 

achievable for discharges from C&D sites. 

Table 6-7. TSS variability factors in recent regulations 

Category Subcategory Option Value 

Organics 4 4.8 

Oils 9 2.9 

3 3.2 

Centralized Waste Treatment 

(USEPA 2000) 

Metals 

4 3.6 

Waste Combustors (USEPA 

1999b) 

Commercial Hazardous Waste 

Combustors 4.2 

Coke By-Products BAT1 4.6 

Iron and Steel (USEPA 2002) DRI_BPT 3.5 Other 

FORGING 4.4 

 

1

 As previously explained, turbidity is the BAT regulated pollutant parameter EPA selected as a pollutant itself and 

as an indicator of toxic and non conventional pollutants discharged from C&D sites. While the discharge of 

pollutants may be identified by a number of measures including measurement of, among others, turbidity, suspended 

solids and total suspended solids, EPA has selected turbidity as the better measure for sediment discharge rather than 

TSS for several reasons. These include the fact that discharges from sites with appreciable clay soils may exhibit 

low TSS concentration but still have high turbidity level indicative of higher pollutant content. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-15 

Category Subcategory Option Value 

Landfills (USEPA 1999a) 1) Hazardous and 

2) Non-Hazardous* 4.4 

Pulp, Paper, and 

Paperboard, Cluster Rule 

(USEPA 1997) 

bleached papergrade kraft and soda 3.11 

Transportation Equipment Barge/Chemical & Petroleum 1 4.7 

Cleaning (Science 

Applications International 

Corporation 2000) 

Food Direct 2 5.4 

* The variability factors for both subcategories were based on the same data. 

6.9.4. CALCULATION OF THE LIMITATION 

Using its standard approach for effluent guidelines, EPA calculated the value of the daily 

maximum limitation (280 NTU) using the product of the long-term average (64.13 NTU) and 

daily variability factor (4.322): 

Daily Maximum Limitation = Long-Term Average × Variability Factor 

= (64.13 NTU) × (4.322)

= 277.17 NTU

EPA rounded the value of the limitation to two significant digits (i.e., 280 NTU). 

As a consequence of using the long-term average and variability factor as the basis of the 

limitation, sites that are designed and operated to achieve long-term average levels should be 

capable of compliance with the limitations, which incorporate variability, at all times. 

6.9.5. LIMITATION INCLUDES AUTOCORRELATION ADJUSTMENT 

The limitation calculations include an adjustment for possible bias due to statistical 

autocorrelation. When data are said to be positively autocorrelated, it means that measurements 

taken at specific time intervals (such as 1 day or 2 days apart) are related. For example, positive 

autocorrelation would be present in the data if the effluent concentration was relatively high one 

day and was likely to remain at similar high values the next and possibly succeeding days. 

Because the values tend to be similar from day to day, the variance estimate may be dampened 

even within a relatively large time period. By accounting for autocorrelation, the adjusted 

variance then better reflects the underlying variability that would be present if the data were 

collected over an even longer period. To evaluate autocorrelation, generally, the statistical 

analysis requires at least a 50-day period with measurements from every day during the period.2

C&D discharge data generally do not have measurements for every day. Instead, they are 

generally associated with days with precipitation, and no discharge (or zero) for the other days. 

After determining that the data were not suitable for the statistical analysis, EPA then considered, 

from an engineering aspect, whether it was likely that treatment from one day to the next would 

 

2

 Box and Jenkins (1976), a classic textbook on time series analyses, states, “It is normally supposed that successive 

values of the time series under consideration ... are available for analysis. If possible, at least 50 and preferably 100 

observations should be used.” (page 18) 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-16 

be similar. On one hand, conditions can vary considerably from day to day which would lead 

EPA to conclude that treatment would be relatively unaffected by the previous day’s treatment. 

On the other hand, if stormwater is detained in a pond for a sufficient amount of time, the settling 

process might indicate that discharges one day apart might be similar. Because EPA’s 

engineering review was inconclusive, EPA determined that, as a conservative measure to ensure 

that the limitation was achievable, it was appropriate to incorporate a statistical adjustment for 

autocorrelation. 

As explained in Section 6.9.3, turbidity has not been regulated in other industries, and thus, EPA 

again investigated whether it could transfer autocorrelation adjustments developed for TSS 

limitations in other industries. Of the choices listed in Table 6-7 and for which the statistical 

documentation is readily available, EPA only adjusted for autocorrelation in the TSS NSPS for 

the pulp, paper, and paperboard industry. EPA determined that it was appropriate to transfer the 

autocorrelation adjustment because: 1) EPA expects turbidity and TSS to be treated similarly by 

the model technology; and 2) the model technologies for the two industries similarly detain the 

wastestreams prior to discharge. EPA also notes that the adjustment for the 1998 regulation was 

relatively large, and thus, it is unlikely that the C&D discharges would require an even larger 

adjustment. Appendix G describes the application of the 1998 adjustment to the variance of the 

C&D data. The consequence of applying this adjustment to the C&D discharges was an increase 

in the value of the limitation from 189 to 280 NTU. Table 6-8 provides the values of the systemspecific long-term averages and variability factors with and without the autocorrelation adjustment. 

Table 6-8. Effect of autocorrelation adjustments on limitation 

WITHOUT autocorrelation 

adjustment 

WITH autocorrelation adjustment

(used as basis of limitation) 

System 

Number of 

daily values Long-term 

average (NTU) 

Daily variability 

factor (VF1) 

Long-term 

average (NTU) 

Daily variability 

factor (VF1) 

BHRBP2 116.00 68.01 3.510 68.96 3.642 

BWWTP 8.00 74.32 6.007 132.41 10.203 

KC1.1 28.00 54.80 2.067 55.81 2.283 

KC1.2 32.00 54.93 2.277 56.08 2.508 

KC1.3 10.00 54.66 1.573 55.77 1.867 

KC1.4 3.00 45.04 1.417 46.66 1.953 

KC1.5 16.00 41.56 1.585 42.09 1.775 

KC2.1 33.00 80.40 2.599 82.67 2.890 

KC2.2 30.00 83.00 2.746 85.96 3.104 

KC2.3 40.00 62.09 2.606 63.52 2.845 

KC2.4 23.00 60.43 3.068 64.13 3.646 

KC2.5 19.00 66.22 2.204 68.46 2.576 

KC3.1 13.00 48.99 2.502 52.53 3.219 

KC3.2 13.00 48.91 2.682 53.09 3.503 

KC3.3 15.00 41.00 3.005 44.88 3.878 

KC3.4 15.00 43.82 2.966 47.84 3.819 

KC3.Pond 7.00 44.30 2.008 47.59 2.809 

NC.Road 7.00 57.15 4.609 88.19 8.135 

NCR.1 12.00 38.43 4.071 47.11 5.859 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-17 

WITHOUT autocorrelation 

adjustment 

WITH autocorrelation adjustment

(used as basis of limitation) 

System 

Number of 

daily values Long-term 

average (NTU) 

Daily variability 

factor (VF1) 

Long-term 

average (NTU) 

Daily variability 

factor (VF1) 

NCR.2 3.00 58.60 5.426 194.31 12.968 

NY 220.00 104.22 4.054 105.20 4.140 

Red.East 169.00 245.48 6.194 251.48 6.391 

Red.West 56.00 115.34 5.411 122.70 5.934 

SEAAIR 9.00 106.05 2.531 117.79 3.586 

STCLLR 17.00 63.20 3.515 70.40 4.513 

Median LTA 58.60 64.13 

Mean VF1 3.225 4.322 

99th Percentile 189.00 277.17 

6.10. STATISTICAL AND ENGINEERING REVIEW OF LIMITATION 

In conjunction with the statistical methods, EPA performs an engineering review to verify that 

the limitations are reasonable based on the design and expected operation of the model 

technologies and the site conditions. Data from some sites demonstrate the best available 

technology. Data from other sites could demonstrate the same technology but not the best 

demonstrated design and operating conditions for that technology. EPA recognizes that, as a 

result of the limitation, some dischargers might need to improve treatment systems, erosion and 

sediment controls, and/or treatment system operations to consistently meet the effluent 

limitation. EPA determined that this consequence is consistent with the Clean Water Act 

statutory framework, which requires that discharge limitations reflect the best available 

technology (BAT) or best available demonstrated technology (BADT). 

The following sections describe several aspects of the engineering review. Section 6.10.1 

compares the value of the limitation to the performance data used as the basis of the limitation. 

Section 6.10.2 compares the performance data for other technologies to the value of the 

limitation. Section 6.10.3 evaluates the performance data for the C&D model technology 

collected during the rulemaking for gold placer mining discharges to confirm that the data are 

consistent with the limitation. Section 6.10.4 compares the limitation to benchmarks established 

by several states. Section 6.10.5 considers other factors and performance. 

6.10.1. PERFORMANCE DATA FOR MODEL TECHNOLOGY COMPARED TO 

LIMITATION 

To evaluate the value of the limitation, EPA compared the value of the limitation to the daily 

values used to calculate the limitation. Because of the statistical models used to derive the 

limitation from their data, EPA would expect about one percent of the values to be greater than 

the limitation. From an engineering perspective, in most instances where the daily values were 

greater than the turbidity limitation, the system was not optimized appropriately and/or there was 

some other factor responsible for the higher values. Table 6-9 summarizes the results of this joint 

statistical and engineering review of the data and the performance at each system. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-18 

 21 of the 25 systems had all the daily values less than the limitation. Because the 

database contained fewer than 100 daily values for each system, EPA would expect 

only one, if any, daily values at each system would be greater than the limitation. For 

these 19 systems, EPA concluded that the finding that none of the values were greater 

than the limitation is consistent with what is expected from the 99th percentile basis of 

the statistical methodology. The finding was also consistent from an engineering 

perspective because properly operated and controlled systems are expected to operate 

below the level of the limitation. 

 BHRBP2 had 1 of 116 (or one percent) daily values greater than the limitation, which 

is consistent with what is expected from the 99th percentile basis of the statistical 

methodology. The engineering investigation revealed that the daily value of 528 NTU 

was observed on December 3, 2007 during an extreme storm event in Seattle, WA 

(http://www.climate.washington.edu/events/dec2007floods/). The Office of the 

Washington State Climatologist estimated that 6-hour and 24-hour precipitation 

amounts were near 100-year rain frequency levels. This event does not represent 

normal conditions and the rule exempts such events from complying with the 

limitation. EPA notes that data from 13 other systems in the Seattle area is also 

available during this storm event and the average turbidities for the day were all 

below the value of the limitation. Thus, even during the extreme storm event, it was 

possible to achieve turbidity control. 

 New York had two of 220 (one percent) daily values greater than the limitation, 

which also is consistent with what is statistically expected from the 99th percentile 

basis of the statistical methodology. The two values, 550 and 284 NTU, were 

observed on two consecutive days, October 2 and 3 in 2006, which were the first two 

days reported by the vendor. The engineering review concluded that they were likely 

the result of insufficient flocculant dosing during start-up operations. EPA has 

determined that they do not represent normal operations because optimization, even 

during startup operations, is relatively simple and easy to achieve as demonstrated by 

the other systems in the limitation data set. In addition, as described earlier, this pond 

was pretreatment to an ATS system, and therefore the targeted turbidity in the 

effluent was likely 500 NTUs or less. 

 Red.East had 50 of its 169 values greater than the limitation with a maximum value of 

673 NTU. Based upon its engineering review of the data, EPA concluded that it was 

likely not optimizing its system because it only needed to meet a target level of 500 

NTU (although several values were above this level). Proper dosing is necessary for 

adequate turbidity removal, and it is likely that the dosage rate of flocculant was not 

optimized for obtaining lower turbidity because the other systems evaluated and 

described here produced consistently lower turbidity values. 

 Red.West had 2 of its 56 values greater than the limitation which is slightly more than 

what is statistically expected. These values were observed on November 6 (334 NTU) 

and December 14, 2006 (341 NTU). The engineering review concluded that this 

system was likely not optimized, because it was targeting the model technology to a 

relatively high level of 500 NTU. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-19 

Table 6-9. Daily values greater than daily maximum limitation 

Daily values greater than daily 

maximum limitation of 280 NTU 

System 

Number of 

Daily Values 

Number of 

values 

Percent of total 

number 

BHRBP2 116 1 0.9% 

BWWTP 8 0 0.0% 

KC1.1 28 0 0.0% 

KC1.2 32 0 0.0% 

KC1.3 10 0 0.0% 

KC1.4 3 0 0.0% 

KC1.5 16 0 0.0% 

KC2.1 33 0 0.0% 

KC2.2 30 0 0.0% 

KC2.3 40 0 0.0% 

KC2.4 23 0 0.0% 

KC2.5 19 0 0.0% 

KC3.1 13 0 0.0% 

KC3.2 13 0 0.0% 

KC3.3 15 0 0.0% 

KC3.4 15 0 0.0% 

KC3.Pond 7 0 0.0% 

NC.Road 7 0 0.0% 

NCR.1 12 0 0.0% 

NCR.2 3 0 0.0% 

NY 220 2 0.9% 

Red.East 169 50 29.6% 

Red.West 56 2 3.6% 

SEAAIR 9 0 0.0% 

STCLLR 17 0 0.0% 

6.10.2. PERFORMANCE OF OTHER TREATMENT SYSTEMS RELATIVE TO 

MODEL TECHNOLOGY 

EPA compared the limitation to data from other treatment systems to determine if the 

performance data behaved as expected. For systems, such as ATS, that are more complex than 

the model technology, EPA expects the performance data to have lower levels of turbidity than 

the limitation data. For less sophisticated systems, such as best management practices, EPA 

expects the performance data to have higher levels of turbidity. As described below, these 

comparisons to the limitation generally confirmed EPA’s expectations. 

EPA considered treatment data from systems that were expected to perform better than the model 

technology. Of the approximately 24,000 effluent measurements from 38 systems using ATS, the 

largest measured value was 71.6 NTU. As EPA expected, in all cases, the advanced systems 

demonstrated lower levels of turbidity than required by the limitation. In addition, EPA 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-20 

considered the influent data for the system for the WSDOT SR-522 road improvement project at 

Elliot Road (ELLRD). Although EPA did not use this data in calculating the limitation, its 

average value was 42.10 NTU, which was lower than the 64 NTU long-term average basis of the 

limitation. In addition, the maximum value obtained for ELLRD was 182 NTU which is well 

below the limitation of 280 NTU. Thus, the ELLRD system performance is better than EPA’s 

model technology. 

EPA also considered data from other studies that did not use the model technology (polymeraided settling) but that used other conventional BMPs. See Chapter 5 and DCN 44321 for a 

summary of studies evaluating the performance of sediment basins. Two key studies of 

conventional BMPs are Warner and Collins-Camargo (2001) and Horner, Guedry and Kortenhof 

(1990). EPA also evaluated other studies that evaluated passive treatment, but were not used as a 

basis for calculating the limitation. See DCN 43114 for a summary of various other passive 

treatment approaches. Two key studies evaluating polymer-aided settling were prepared for the 

Auckland Regional Council (2004 and 2008). These studies evaluated TSS, not turbidity, and 

hence were not used for calculation of the limitation, but provide useful information on polymeraided settling in sediment basins. 

EPA also considered influent data that it had collected for the proposed rule to determine if the 

levels appeared to be greater than the turbidity limitation. In this comparison, EPA was verifying 

that it was establishing a limitation that would require treatment. The 1008 influent 

measurements that reflect either uncontrolled wastewater and/or runoff managed by upslope 

BMPs (i.e., relatively minor treatment) prior to the pond. As shown in Table 6-10, the average 

turbidity levels ranged from 105 to 2581 NTU, and thus, all are greater than the long-term 

average basis (64 NTU) for the limitation. In addition, the maximum values generally are larger 

than any value observed from effluent from the model technology. Thus, EPA concluded that 

treatment is likely to be necessary for sites to comply with the limitation. 

Table 6-10. Daily value summary from systems with less than model technology 

Site 

Number of 

daily values 

Arithmetic 

average (NTU) 

Standard 

deviation 

Minimum 

(NTU) 

Maximum 

(NTU) 

11 32 148.63 187.25 1.08 1,020.00 

2 23 2,581.29 1,255.08 853.00 4,816.00 

3 16 105.39 96.40 27.40 380.20 

4 18 398.86 283.98 10.20 985.00 

6 8 552.59 201.28 209.00 951.00 

8 14 610.56 329.19 204.00 1,000.00 

BZR08 9 323.63 83.90 149.00 420.00 

HEO 4 604.00 99.37 466.00 696.00 

LSIDE 76 242.45 120.62 52.25 662.89 

SC05 7 255.50 47.34 210.00 331.00 

SC08 14 848.08 143.65 625.73 1,080.00 

WLCPO 10 194.50 123.68 78.10 472.00 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-21 

6.10.3. PERFORMANCE OF MODEL TECHNOLOGY FOR GOLD PLACER 

MINING WASTES

As an additional step in the engineering review, EPA reviewed its records for its 1988 

rulemaking for the gold placer mining subcategory of the ore mining and dressing point source 

category. The placer mining regulation established a limitation for settleable solids based on 

simple settling, which is not equivalent to the model technology for C&D. However, during 

development of the placer mining regulation EPA conducted treatability studies at placer mining 

sites to evaluate the performance of simple settling and chemically aided settling in reducing 

settleable solids, TSS and turbidity. Although the mining wastes evaluated had solids content 

generally higher than expected for C&D, and that these were jar tests as opposed to basin 

influent/effluent samples, EPA found comparable performance in the treatability tests. The 1986 

Alaskan Placer Mining Study Field Testing Program Report (USEPA 1987) performed 

chemically assisted tests that determined the effect of polyelectrolytes and polyethylene oxide 

(PEO) on turbidity levels. Results, presented in Table 6-11, indicate the PEO, with and without 

polyelectrolyte, can reduce turbidity to low levels. Moreover, although the initial turbidity levels 

are generally substantially greater than the levels in C&D wastewater, the model technology was 

able to drop below 280 NTU within one hour. The only exception (mine 4998) dropped to 220 

NTU during the second hour. After 6 hours (EPA expects longer settling periods for C&D 

wastewater in ponds, which are generally designed to provide 24 to 72 hours of detention time), 

EPA would expect to see about half of the values to be greater than (and half less than) the longterm average basis of the limitation. The result, with only four values greater than the long-term 

average, is consistent, and perhaps even better, performance than EPA expects from the model 

technology. Thus, EPA concludes that the gold placer mining study demonstrates that EPA’s 

model technology can achieve the low levels required by the limitation, even in the presence of 

extremely high levels of turbidity in the influent. 

Table 6-11. Turbidity during 1986 Alaskan placer mining study 

Chemically aided settling (PEO tests) 

turbidity (NTU) 

Mine No. Test No. Initial 30 min 1 hr 2 hr 3 hr 4 hr 5 hr 6 hr 

4922 21 39,500 35,000 31 21 20 12 11 10 

4998 4 39,500 350 275 220 210 175 140 140 

4999 8 11,000 188 148 144 140 136 128 122 

5000 12 6,500 45 44 42 

5001 15 2,450 54 41 40 38 35 

5002 17 22,500 90 83 82 82 80 80 75 

5003 24 1,235 144 95 77 68 60 53 51 

5004 29 23,250 134 93 83 71 69 59 52 

Average: All Mines (PEO) 18,242 4,501 101 89 90 81 79 75 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-22 

Chemically aided settling (polyelectrolyte) 

turbidity (NTU) 

Mine No. Test No. Initial 30 min 1 hr 2 hr 3 hr 4 hr 5 hr 6 hr 

4922 19 40,000 24,250 52 26 

 20 42,500 21,250 63 50 36 33 27 27 

4998 2 18,600 58 37 30 28 28 28 27 

 3 8,500 570 54 54 

4999 6 16,250 134 97 90 90 89 89 78 

 7 22,000 84 70 67 

5000 10 1,680 37 34 23 22 18 15 15 

 11 2,050 40 30 25 

5001 14 2,000 32 29 27 26 25 

5003 23 9,000 14 13 12 12 11 11 10 

 25 11,320 41 36 37 

5004 27 23,150 41 20 10 

 28 23,500 45 23 18 11 9 6 5 

Average: All Mines 

(Polyelectrolyte) 16,965 3,584 43 36 32 30 29 27 

6.10.4. LIMITATION IS CONSISTENT WITH STATE ACTION LEVELS 

EPA also compared its long-term average basis of the limitation with action levels established by 

four states. EPA is not aware of any statistical studies that were the basis of the action levels in 

these four states; however, EPA assumes that there was a technology basis or BPJ basis that 

established that the levels were reasonable. While an action level is not an enforceable limit, it 

does indicate that the state determined that discharges greater than the action level may require 

additional optimization or treatment technology. To comply with the limitation, EPA 

recommends that operators target the system performance to the long-term average basis of the 

limitation and control discharges above that level. Because the state action levels and the longterm average both indicate a potential need for operator action, EPA compared the state action 

levels to 64 NTU, the long-term average basis of the limitation, EPA found that its long-term 

average basis is consistent with or more stringent than the state action levels: 50 NTU in 

Vermont (DCN 42108); 120 NTU in Oregon (DCN 42109) and Washington (DCN 42110); and 

250 NTU in California (DCN 42104). In addition, California has established an enforceable 

NTU limit of 500 in its current general permit for certain sites. The data from Washington 

demonstrate that the action levels have generally been effective in controlling the discharges 

with 75 percent of the daily values less than the action level of 120 NTU. 

6.11. MONITORING CONSIDERATIONS 

Effluent guidelines act as a primary mechanism to control the discharge of pollutants to waters of 

the United States. The C&D regulations will be applied to C&D sites through incorporation in 

individual National Pollutant Discharge Elimination System (NPDES) permits or a general 

permit issued by EPA or authorized states or tribes under section 402 of the Clean Water Act. In 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-23 

complying with the final rule, the number of measurements required each day would be 

determined by the permit authority. While the actual monitoring requirements will be determined 

by the permitting authority, in developing the limitation, the Agency has assumed that sites will 

report one value for every day that the discharge occurs to be consistent with permit definitions 

provided in 40 CFR 122.2 that define the maximum daily discharge limitation as the “highest 

allowable daily discharge.” 

EPA recognizes that some sites regularly monitor multiple times throughout the day to ensure 

that the treatment system is operating properly. In addition, because turbidity can be measured 

real-time, it is possible to use an automated turbidity meter in conjunction with a data logger to 

obtain data during the entire period of discharge. While EPA agrees that such monitoring is 

appropriate, EPA would, however, discourage the practice of allowing the number of monitoring 

samples to vary arbitrarily merely to allow a site to achieve a desired average concentration, i.e., 

a value below the limitation that day. EPA expects that enforcement authorities would prefer, or 

even require, monitoring samples at some regular, predetermined frequency. As explained 

below, if a site has difficulty complying with the limitation on an ongoing basis, the site should 

improve its equipment, operations, and/or maintenance. 

6.12. COMPLIANCE 

EPA promulgates limitations that sites are capable of complying with at all times by properly 

operating and maintaining their processes and treatment technologies. However, the issue of 

exceedances or excursions (values that exceed the limitations) is often raised. Comments often 

suggest that EPA include a provision that a facility is in compliance with permit limitations if its 

discharge does not exceed the specified limitations, with the exception that the discharge may 

exceed the monthly average limitations 1 month out of 20 and the daily average limitations 1 day 

out of 100. This issue was, in fact, raised in other rules, including EPA’s final Organic 

Chemicals, Plastics, and Synthetic Fibers (OCPSF) rulemaking. EPA’s general approach in that 

case for developing limitations based on percentiles was the same as this rule and was upheld in 

Chemical Manufacturers Association v. U.S. Environmental Protection Agency, 870 F.2d 177, 

230 (5th Cir. 1989). The Court determined the following: 

EPA reasonably concluded that the data points exceeding the 99th and 95th 

percentiles represent either quality-control problems or upsets because there can 

be no other explanation for these isolated and extremely high discharges. If these 

data points result from quality-control problems, the exceedances they represent 

are within the control of the plant. If, however, the data points represent 

exceedances beyond the control of the industry, the upset defense is available. 

Additionally, this issue was raised in EPA’s Phase I rule for the pulp and paper industry. In that 

rulemaking, EPA used the same general approach for developing limitations based on percentiles 

that it had used for the OCPSF rulemaking and for the proposed CAAP rule. This approach for 

the monthly average limitation was upheld in National Wildlife Federation et al. v. 

Environmental Protection Agency, 286 F.3d 554, 573 (D.C. Cir. 2002). The Court determined 

that: 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-24 

EPA’s approach to developing monthly limitations was reasonable. It established 

limitations based on percentiles achieved by facilities using well-operated and 

controlled processes and treatment systems. It is therefore reasonable for EPA to 

conclude that measurements above the limitations are due to either upset 

conditions or deficiencies in process and treatment system maintenance and 

operation. EPA has included an affirmative defense that is available to mills that 

exceed limitations due to an unforeseen event. EPA reasonably concluded that 

other exceedances would be the result of design or operational deficiencies. EPA 

rejected Industry Petitioners’ claim that facilities are expected to operate 

processes and treatment systems so as to violate the limitations at some pre-set 

rate. EPA explained that the statistical methodology was used as a framework to 

establish the limitations based on percentiles. These limitations were never 

intended to have the rigid probabilistic interpretation that Industry Petitioners 

have adopted. Therefore, we reject Industry Petitioners’ challenge to the effluent 

limitations. 

As that Court recognized, EPA’s allowance for reasonably anticipated variability in its effluent 

limitations, coupled with the availability of the upset defense, reasonably accommodates 

acceptable excursions. Any further excursion allowances would go beyond the reasonable 

accommodation of variability and would jeopardize the effective control of pollutant discharges 

on a consistent basis and/or bog down administrative and enforcement proceedings in detailed 

fact-finding exercises, contrary to congressional intent. See, for example, Rep. No. 92-414, 92d 

Congress, 2d Sess. 64, reprinted in A Legislative History of the Water Pollution Control Act 

Amendments of 1972 (at 1482); Legislative History of the Clean Water Act of 1977 (at 464-65). 

More recently, for EPA’s rule for the iron and steel industry, EPA’s selection of percentiles was 

upheld in American Coke and Coal Chemicals Institute v. Environmental Protection Agency, 

452 F.3d 930, 945 (D.C. Cir. 2006). The Court determined that 

The court will not second-guess EPA’s expertise with regard to what the 

maximum effluent limits represent. See Nat’l Wildlife, 286 F.3d at 571-73. As 

EPA explains in the Final Development Document, the daily and monthly average 

effluent limitations are not promulgated with the expectation that a plant will 

operate with an eye toward barely achieving the limitations. Final Development 

Document at § 14.6.2. Should a plant do so, it could be expected to exceed these 

limits frequently because of the foreseeable variation in treatment effectiveness. 

Rather, the effluent limitations are promulgated with the expectation that plants 

will be operated with an eye towards achieving the equivalent of the LTA for the 

BAT-1 model technology. Id. However, even operated with the goal of achieving 

the BAT-1 LTA, a plant’s actual results will vary. EPA’s maximum daily 

limitations are designed to be forgiving enough to cover the operations of a welloperated model facility 99% of the time, while its maximum monthly average 

limitations are designed to be forgiving enough to accommodate the operations of 

a well-operated model facility 95% of the time. See id. EPA’s choice of percentile 

distribution represented by its maximum effluent limitation under the CWA 

represents an expert policy judgment that is not arbitrary or capricious. 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-25 

EPA expects that sites will comply with promulgated limitations at all times. If the exceedance is 

caused by an upset condition, the site would have an affirmative defense to an enforcement 

action if the requirements of 40 CFR 122.41(n) are met. If the exceedance is caused by a design 

or operational deficiency, EPA has determined that the site’s performance does not represent the 

appropriate level of control (best available technology for existing sources; best available 

demonstrated control technology for new sources). For other promulgated limitations and 

standards, EPA has determined that such exceedances can be controlled by diligent process and 

wastewater treatment system operational practices such as frequent inspection and repair of 

equipment, use of backup systems, and operator training and performance evaluations. For this 

effluent guideline, EPA has provided reasonable relief from the effects of large storm events by 

requiring that the limitation only apply to discharges on days with precipitation less than the 

local 2-year, 24-hour storm event. 

6.13. SUMMARY OF STEPS USED TO DERIVE THE LIMITATIONS 

This section summarizes the steps used to derive the limitations for turbidity: 

Step 1 EPA calculated daily averages from the individual measurements for each treatment 

system. 

Step 2 EPA calculated the system-specific long-term averages and daily variability factors for 

each of the 25 systems that had the model technology. 

Step 3 EPA calculated the long-term average of 64.13 NTU as the median of the site longterm averages. (See Table 6-5.) EPA expects that all sites subject to the limitations will 

design and operate their treatment systems to achieve the long-term average 

performance level on a consistent basis. 

Step 4 EPA calculated the variability factor of 4.322 as the mean of the system-specific 

variability factors. (See Table 6-6.) If a site operates its treatment system to meet the 

relevant long-term average, EPA expects the site to be able to meet the limitations. The 

variability factor assures that normal fluctuations in a site’s treatment are accounted for 

in the limitation. By accounting for these reasonable excursions above the long-term 

average, EPA’s use of variability factors results in limitations that are generally well 

above the actual long-term averages. 

Step 5 EPA calculated the daily maximum limitation of 280 NTU using the product of the 

long-term average (64.13 NTU) and the daily variability factor (4.322). 

Step 6 EPA compared the daily maximum limitations to the site daily values used to develop 

the limitations. (See Table 6-9.) EPA usually performs this comparison to determine 

whether it used appropriate distributional assumptions for the data used to develop the 

limitations. This comparison considers whether the curves EPA used provide a 

reasonable fit to the actual effluent data or if there was an engineering or process reason 

for an unusual discharge. Although the fact that the Agency performs such an analysis 

before promulgating limitations might give the impression that EPA expects occasional 

exceedances of the limitations, this conclusion is incorrect. EPA promulgates 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-26 

limitations that facilities are capable of complying with at all times by properly 

operating and maintaining their treatment technologies. After performing an 

engineering evaluation of the larger values, EPA concluded that the limitation was 

reasonable. 

6.14. REFERENCES 

Auckland Regional Council. 2004. The Use of Flocculants and Coagulants to Aid the Settlement 

of Suspended Sediment in Earthworks: Trials, Methodology and Design. Technical 

Publication 227. Auckland Regional Council. (DCN 41112). 

Auckland Regional Council. 2008. Performance of a Sediment Retention Pond Receiving 

Chemical Treatment. Auckland Regional Council. (DCN 42102). 

Battelle. 2009a. Memorandum from Laura Aume to Marla Smith. C&D Analysis of ATS Data.

September 14, 2009 (DCN 42112). 

Battelle. 2009b. Memorandum from Laura Aume to Marla Smith. C&D: Final Limitations.

November 20, 2009 (DCN 42128). 

Box, G., and G. Jenkins. 1976. Time Series Analysis forecasting and control. Revised Edition.

Holden-Day, Inc., CA. 

Cascade EcoSolutions. 2008. Personal communications transmitting information and files on 

February 14, April 27, April 30, May 8, and May 13, 2008. Data sets included Engineering 

Report Data and ChitoVan Performance Review Data Set. (DCN 43002). 

Clager, Tyrone. 2009. Personal communication transmitting files and other information. (DCN 

42137). 

Clear Creek Systems, Inc. 2008. Personal communications transmitting files and other 

information. Data files included Data from Some Sites 2005-06 Season and Chitosan 

Treatment Results 2005. (DCN 43003). 

Clear Creek Systems, Inc. 2009. Data files for King County, Morrisville, Redmond, Seattle and 

Springville sites. (DCN 43125). 

Gannon, Joe. 2009. Personal communication transmitting information about ATS sites (DCN 

42130). 

Holloway, Nathan. 2009. Personal communications transmitting files and other information. 

Data files include 8LST01 History.xls and 8HUD01 FIELD DATA.xlsx. (DCNs 42133, 

42134, 42135 and 42136). 

Horner, R., J. Guedry, and M. Kortenhof. 1990. Improving the Cost Effectiveness of Highway 

Construction Site Erosion and Pollution Control. Report No. WA-RD 200.1. University of 

Washington, Washington State Transportation Center, Seattle, WA. (DCN 01350). 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-27 

Jurries, D. No date. Flocculation of Construction Site Runoff in Oregon. Oregon Department of 

Environmental Quality. <www.deq.state.or.us/wq/stormwater/docs/nwr/flocculation.pdf>. 

Accessed October 24, 2008. (DCN 43010.3). 

McLaughlin, R. No Date. Target Turbidity Limits for Passive Treatment Systems. 

McLaughlin, R. 2009. Personal communications transmitting information about passive 

treatment sites (DCNs 42131 and 42132). 

McLaughlin, R., S. King, and G. Jennings. 2009. Improving Construction Site Runoff Quality 

with Fiber Check Dams and Polyacrylamide. Journal of Soil and Water Conservation

64(2):144-154. 

Minton, G. 2006. Technical Engineering Evaluation Report (TEER) for the Chitosan-Enhanced 

Sand Filtration Technology for Flow-Through Operations. Prepared for Natural Site 

Solutions, LLC, Redmond, WA. (DCN 43002 with supporting data file at DCN 43002: 

Engineering Report Data.xls.) by Minton, Resource Planning Associates, Seattle, WA. 

Minton, G., A. Benedict, C. 1999. Polymer-Assisted Clarification of Stormwater from 

Construction Sites: Experience in the City of Redmond, Washington. Prepared for the City of 

Redmond, Washington, by Resource Planning Associates, Seattle, WA, and HoweConsult. 

(DCN 41107). 

Minton, G., and A. Benedict. 1999. Use of Polymers to Treat Construction Site Stormwater. 

Proceedings of the International Erosion Control Association (IECA), Conference 30, Pp. 

177-188. IECA, Steamboat Springs, CO. (DCN 41108). 

Office of the Washington State Climatologist. 2007 Record Flooding. 

<http://www.climate.washington.edu/events/dec2007floods/>. Accessed November 22, 2009. 

Science Applications International Corporation. 2000. Statistical Support Document for Effluent 

Limitations Guidelines and Standards for the Transportation Equipment Cleaning Category. 

(DCN 45053). 

USEPA (U.S. Environmental Protection Agency). 1987. Final Draft 1986 Alaskan Placer 

Mining Study Field Testing Program Report. (DCN 42013). 

USEPA (U.S. Environmental Protection Agency). 1997. Statistical Support Document for the 

Pulp and Paper Industry: Subpart B. (DCN 45050). 

USEPA (U.S. Environmental Protection Agency). 1999a. Statistical Support Document for 

Effluent Limitations Guidelines and Standards for the Landfills Category. EPA-821-B-99-

007. (DCN 45052). 

USEPA (U.S. Environmental Protection Agency). 1999b. Statistical Support Document for Final 

Effluent Limitations Guidelines and Standards for Commercial Hazardous Waste 

Combustors. Volume I, Volume II. EPA 821-B-99-010. (DCN 45051). 
Section 6: Limitations and Standards: Data Selection and Calculation 

6-28 

USEPA (U.S. Environmental Protection Agency). 2000. Development Document for Effluent 

Limitations Guidelines and Standards for the Centralized Waste Treatment Point Source 

Category. Volume I, Volume II. EPA 440/1-87/009. 

<www.epa.gov/guide/cwt/final/develop/index.html>. 

USEPA (U.S. Environmental Protection Agency). 2002. Development Document for Effluent 

Limitations Guidelines and Standards for the Iron and Steel Manufacturing Point Source 

Category. EPA-821-R-02-004. <www.epa.gov/guide/ironsteel/reg/tdd.htm>. 

USEPA (U.S. Environmental Protection Agency). 2009a. Passive Data Summary Spreadsheet. 

November 23, 2009 (DCN 42125). 

USEPA (U.S. Environmental Protection Agency). 2009b. Passive Zero Excluded Data 

Spreadsheet. November 23, 2009 (DCN 42126). 

USEPA (U.S. Environmental Protection Agency). 2009c. ATS Data Spreadsheet. November 23, 

2009 (DCN 42127). 

USEPA (U.S. Environmental Protection Agency). 2009d. Email from Jesse Pritts to Marla 

Smith: ATS Data Transmittal. August 12, 2009 (DCN 42129). 

Warner, R. and Collins-Camargo, F. Erosion Prevention and Sediment Control Computer 

Modeling Project. Surface Mining Institute, Lexington, KY. 2001. (DCN 430741). 
Section 7: Technology Assessment 

7-1 

7. TECHNOLOGY ASSESSMENT 

This technology assessment is intended to determine the amount and quality of data available to 

describe the performance of site runoff control practices, the ability of each practice to 

effectively control the effects of runoff, and the design criteria or standards used to size each 

practice to ensure effective control of runoff. 

7.1. REVIEW OF HISTORICAL APPROACHES TO EROSION AND SEDIMENT 

CONTROL (ESC) 

Most early sediment control was related to agriculture and was installed as a way to maintain our 

natural resource base. On-site control was the primary emphasis, attempting to prevent erosion 

rather than trap sediment. Strategies were developed to minimize exposure of bare soil to the 

erosive power of rainfall and stormwater, using aboveground cover management, residue 

management, strip cropping, and terracing to limit the length of overland flow. Effects on 

receiving streams and downstream areas had not yet been identified as an issue. In the 1960s 

concern began to be expressed about the quantities of sediment in streams and reservoirs, and 

sediment was first identified as a pollutant. Initially, the major focus of sediment control was on 

the surface mining industry with the passage of the Clean Water Act and then the Surface 

Mining, Reclamation, and Control Act (SMRCA) (PL 95-87). The first approach taken to 

sediment control was a design standard, requiring a sediment detention basin with a 24-hour 

detention time; total suspended solids (TSS) standards of 35 milligrams per liter (mg/L) average 

and 70 mg/L peak were also promulgated but were not typically enforced. The U.S. 

Environmental Protection Agency (EPA) later evaluated the TSS standard and moved to a 

settleable solids standard of 0.5 mL/L because a modeling effort showed that it was not possible 

to trap fine sediments, but that a 0.5 mL/L settleable solids standard could be met with a 

reasonably sized sediment basin (Ettinger and Lichty 1979). 

In the late 1960s and early 1970s, sediment in streams and waterways originating from urban 

construction sites became an issue, which was then addressed in the Clean Water Act. EPA 

developed a list of best management practices (BMPs) and standards for their construction 

(USEPA 1971). In general, those standards were adopted from those of other agencies and were 

not based on studies related to urban runoff. 

In 1987 the Clean Water Act was amended to include stormwater discharges from urban areas. 

The Phase I National Pollutant Discharge Elimination System (NPDES) stormwater regulations 

were published in 1990, requiring all municipalities with municipal separate storm sewer 

systems serving populations greater than 100,000, construction sites 5 acres and larger, and 

certain industrial sites to obtain a permit. The permit required the development of a stormwater 

pollution prevention plan (SWPPP) that typically included a stormwater and sediment control 

plan. In 1999 the Phase II NPDES stormwater regulations were published, extending permit 

coverage to construction sites of 1 acre or larger and municipalities with populations greater than 

50,000 (or populations greater than 10,000 where population density is more than 1,000 people 

per square mile). The regulations allow use of general permits in lieu of individual site or facility 

permits. The degree of oversight of construction varies widely among the states. 
Section 7: Technology Assessment 

7-2 

In the past two decades, increased concern at the local level has been focused on sediment 

pollution of streams and waterways, particularly originating from construction, while less 

concern has been focused on the effects of increased construction on stormwater and chemical 

production. Much of the government concern originated from the Phase I and Phase II NPDES 

stormwater regulations. A number of states and their local agencies have developed standards 

and BMPs for sediment control, most of which do not have a scientific basis but were adopted 

from other agencies. Some states, however, did conduct studies that gave their standards some 

scientific basis. For example, Maryland evaluated its BMP standards in the 1980s by using 

modeling techniques, and the state changed its sediment basin standards to account for the 

effects of surface area on the trapping efficiency in sediment ponds. On the basis of typical soils 

in the region and modeling studies, the state adopted a surface area to peak discharge ratio of 

0.01 cubic feet per second (cfs) per acre as a criterion (Barfield and Clar 1985; McBurnie et al. 

1990). Maryland was thus the first state to use a design criterion that was related to the overflow 

rate. Other states also used some of Maryland’s results (Smolen et al. 1988). 

Recent efforts have moved closer to an effluent standard approach. South Carolina conducted a 

detailed analysis and published regulations that required a trapping efficiency or settleable solids 

standard (SCDHEC 1995). In addition, results from a detailed model were used to develop 

simplified design aids (Hayes and Barfield 1995; Holbrook et al. 1998). Some municipalities are 

following suit to develop scientifically based standards of their own. For example, in 1998 

Louisville, Kentucky (Hayes et al. 2001) developed standards and design aids for stormwater and 

sediment control, following the example of South Carolina. 

There are no examples in which an integrated approach to stormwater and sediment control has 

been used on construction sites. The closest analog is the Cumulative Hydrologic Impact 

Analysis (CHIA) required in surface mining by the SMRCA. SMRCA requires each applicant 

for a surface mining permit to conduct a hydrologic impact analysis. Subsequently, the 

regulatory authority is required to conduct a CHIA for the entire watershed. Note that although a 

CHIA is required, it is seldom undertaken on a scale that is useful. 

Many of the advances in sediment control have been based on the capability to predict, a priori, 

the ability of a given design to meet a standard. For example, when the settleable solids standard 

was developed for surface mining, most regulatory authorities adopted it with the requirement 

that permit applicants would demonstrate through the use of widely accepted computer models 

that the proposed design would meet the settleable solids standard. 

Most of the early work in modeling sediment production stemmed from efforts in the 1950s to 

develop a soil loss equation that would apply to the entire nation and allow evaluation of 

alternative erosion control practices. That led to the relationship known as the Universal Soil 

Loss Equation (USLE) (Wischmeier and Smith 1965) and its subsequent derivative, the Revised 

USLE (RUSLE) (Renard et al. 1994). Those efforts focus on erosion control; thus, the 

relationships do not predict sediment yield. A flurry of efforts in the late 1970s and early 1980s 

lead to the development of sediment yield relationships such as the Modified USLE (MUSLE) 

(Williams, No Date), the CREAMS model (Knisel 1980), SEDCAD (Warner et al. 1999), and 

SEDIMOT II (Wilson et al. 1982) and its derivatives. The MUSLE and CREAMS models did 

not include methods to evaluate the impact of sediment trapping structures, but SEDIMOT II 

contained relationships developed at the University of Kentucky to predict the effect of 
Section 7: Technology Assessment 

7-3 

reservoirs (Ward et al. 1977; Wilson and Barfield 1984), check dams (Hirschi 1981), and 

vegetative filter strips (Hayes et al. 1984). The MUSLE, SEDCAD, and SEDIMOT II models 

were based on single storms, while the CREAMS model was based on continuous simulation 

modeling. Details on those models are in Haan et al. (1994). 

More recently, modeling has improved, resulting in several new relationships. The WEPP 

watershed model is one example of a continuous simulation approach. It includes computational 

procedures for a wide variety of sediment control structures (Lindley et al. 1998). Another 

example of a single storm-based model is SEDIMOT III (Barfield et al. 1996), which modifies 

the earlier SEDIMOT II model to include channel erosion routines and a wide variety of 

sediment control techniques. A significant drawback in the SEDIMOT III and WEPP models is 

that they do not have a good technique for predicting the impact of filter fence, which is the most 

common technique used today for sediment control. The authors of SEDCAD have attempted to 

provide algorithms to represent (silt) filter fence removals, although work remains before global 

acceptance in the literature. 

Concerns for changes in geomorphology resulting from flow alterations have resulted in several 

modeling approaches. Early efforts were focused on what is known as the regime theory, in 

which changes in channel property are linked, qualitatively, to changes in flow. Examples 

include models of Lane (1955) and Schumm (1977). In addition, some statistically based models 

were developed, but they are not universally applicable (Blench 1970; Simons and Albertson 

1960). More recently, models have been developed using physically based concepts to predict 

changes in geomorphology as related to changes in flow. The models of Chang (1988) are good 

examples. It is possible to predict, to a limited extent, the change in channel properties as 

affected by changes in flow. 

The impact of changes in flow and geomorphology on habitat is one major area in which 

information is lacking. Although this deficiency can be addressed qualitatively, it is not possible 

to predict quantitatively how a given change in geomorphology will affect habitat. Additional 

information is needed to develop a strategy on the basis of the integrated assessment approach. 

7.2. CONTROL TECHNIQUES 

The following section presents a discussion of the commonly used ESC practices. Information on 

applicability, design and installation criteria, maintenance considerations and effectiveness are 

presented, when available. This section does not discuss proprietary and vendor-supplied BMPs, 

many of which are variations of conventional BMPs such as sediment barriers, filters, and 

erosion control and prevention practices. 

7.2.1. EROSION CONTROL AND PREVENTION 

7.2.1.1. Planning, Staging, Scheduling 

General Description 

A construction sequence schedule is a specified work schedule that coordinates the timing of 

land-disturbing activities and installing ESC measures. The goal of a construction sequence 
Section 7: Technology Assessment 

7-4 

schedule is to reduce on-site erosion and off-site sedimentation by performing land-disturbing 

activities and installing ESC practices in accordance with a planned schedule (Smolen et al. 

1988). 

Construction site phasing involves disturbing only part of a site at a time to prevent erosion from 

dormant parts (Claytor 1997). Grading activities and construction are completed and soils are 

effectively stabilized on one part of the site before grading and construction begin at another 

part. This differs from the more traditional practice of construction site sequencing, in which 

construction occurs at only one part of the site at the time, but site grading and other sitedisturbing activities typically occur simultaneously, leaving portions of the disturbed site 

vulnerable to erosion. Construction site phasing must be incorporated into the overall site plan 

early on. Elements to consider when phasing construction activities include the following 

(Claytor 1997): 

 Managing runoff separately in each phase 

 Determining whether water and sewer connections and extensions can be 

accommodated 

 Determining the fate of already completed downhill phases 

 Providing separate construction and residential accesses to prevent conflicts between 

residents living in completed stages of the site and construction equipment working 

on later stages (USEPA 2000) 

Applicability 

Construction sequencing can be used to plan earthwork and ESC activities at sites where land 

disturbances might affect water quality in a receiving waterbody. 

Design and Installation Criteria 

Construction sequencing schedules should, at a minimum, include the following (NCDNR 1988; 

MDE 1994): 

 The ESC practices that are to be installed 

 The principal development activities 

 The measures that should be installed before other activities are started 

 The compatibility with the general contract construction schedule 

Table 7-1 summarizes other important scheduling considerations in addition to those listed 

above. 
Section 7: Technology Assessment 

7-5 

Table 7-1. Scheduling considerations for construction activities 

Construction activity Schedule consideration 

Construction survey stakeout Before initiating any construction activity, a construction survey 

stakeout should be conducted. The stakeout should identify the limits 

of disturbance and location of control structures, especially perimeter 

controls. 

Preconstruction meeting with owner, 

contractor, and regulatory agency 

The meeting should take place before any construction activity begins 

at the site. The survey stakeout is reviewed, especially the limits of 

disturbance and location of controls. 

Construction access—entrance to 

site, construction routes, areas 

designated for equipment parking 

This is the first land-disturbing activity. As soon as construction takes 

place, any bare areas should be stabilized with gravel and temporary 

vegetation. 

Clearing and grading required for 

installing controls 

In conjunction with the construction access, the clearing and grading 

required for installing ESCs should take place. 

Sediment traps and barriers—basin 

traps, silt fences, outlet protection 

After the construction site has been accessed, principal basins should 

be installed, with the addition of more traps and barriers as needed 

during grading. 

Runoff control—diversions, 

perimeter dikes, water bars, outlet 

protection 

Install key practices after installing principal sediment traps and before 

land grading. Additional runoff control measures can be installed 

during grading. 

Runoff conveyance system—

stabilize streambanks, storm drains, 

channels, inlet and outlet protection, 

slope drains 

If necessary, stabilize streambanks as soon as possible, and install 

the principal runoff conveyance system with runoff control measures. 

The remainder of the systems can be installed after grading. 

Land clearing and grading—site 

preparation (cutting, filling, and 

grading; sediment traps; barriers; 

diversions; drains; surface 

roughening) 

Implement major clearing and grading after installing principal 

sediment and key runoff control measures, and install additional 

control measures as grading continues. Clear borrow and disposal 

areas as needed and mark trees and buffer areas for preservation. 

Surface stabilization—temporary 

and permanent seeding, mulching, 

sodding, riprap 

Immediately apply temporary or permanent stabilizing measures to 

any disturbed areas where work has been either completed or 

delayed. 

Building construction—buildings, 

utilities, paving 

During construction, install any ESC measures that are needed. 

Landscaping and final stabilization—

adding topsoil, trees, and shrubs; 

permanent seeding; mulching; 

sodding; riprap 

This is the last construction phase. Stabilize all open areas, including 

borrow and spoil areas, and remove and stabilize all temporary control 

measures. 

Effectiveness 

Construction sequencing can be an effective tool for ESC because it ensures that management 

practices are installed where necessary and when appropriate. A comparison of sediment loss 

from a typical development and from a comparable phased project shows a 42 percent reduction 

in sediment export in the phased project (Claytor 1997). 

Limitations 

Weather and other unpredictable variables can affect construction sequence schedules. The 

proposed schedule and a protocol for making changes resulting from unforeseen problems should 

be plainly stated in an applicable ESC plan. 
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7-6 

Maintenance 

The construction sequence should be followed throughout the project, and the written ESC plan 

should be modified before any changes in construction activities are executed. The plan can be 

updated if a site inspection indicates the need for additional ESC as determined by contractors, 

engineers, or developers. 

Cost 

Construction sequencing is a low-cost BMP because it requires a limited amount of a 

contractor’s time to provide a written plan for coordinating construction activities and 

management practices. Additional time might be needed to update the sequencing plan if the 

current plan is not providing sufficient ESC. 

Although little research has been done to assess the costs of phasing versus conventional 

construction costs, it is known that it will be possible to implement successful phasing for a 

larger project (Claytor 1997). 

7.2.1.2. Vegetative Stabilization 

Vegetation can be used during construction to stabilize and protect soil exposed to the erosive 

forces of water, as well as post-construction to provide a filtration mechanism for stormwater 

pollutants. The following discussion refers to vegetative stabilization as a construction BMP that 

stabilizes and protects soil from erosion. 

General Description 

Vegetative stabilization measures employ plant material to protect soil exposed to the erosive 

forces of water and wind. Selected vegetation can reduce erosion by more than 90 percent 

(Fifield 1999). Natural plant communities that are adapted to the site provide a self-maintaining 

cover that is less expensive than structural alternatives. Plants provide erosion protection to 

vulnerable surfaces by the following (Heyer, No Date): 

 Protecting soil surface from the impact of raindrops 

 Holding soil particles in place 

 Maintaining the soil’s capacity to absorb water 

 Using living root systems to hold soil in place, increasing overall bank stability 

 Directing flow velocity away from the streambank 

 Acting as a buffer against abrasive transported materials 

 Causing sediment deposition, which reduces sediment load and reestablishes the 

streambank 

The designer should be aware of and respond to local conditions that could influence the 

development of vegetative stabilization measures. As with any planting design, climate, 

maintenance practices, the availability of plant material (including native species), and many 

other factors will influence such considerations as plant or seed mix selection, installation 

methods, and project scheduling. 
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7-7 

Slope Stabilization. On slopes, the goal of vegetative stabilization is not only to reduce surface 

erosion, but also to prevent slope failure. Vegetation should provide dense coverage to protect 

soils from the direct effects of precipitation and help intercept runoff. A variety of plants should 

be used to provide root systems that are distributed throughout all levels of the soil, increasing 

slope shear strength and giving plants a greater ability to remove soil moisture. Uniform mats of 

shallow rooting plants should be avoided because, while such plants might increase runoff 

infiltration, they cannot remove soil moisture beyond the surface level, leaving slopes potentially 

saturated and prone to slippage. Shallow, interlocking root systems could also increase the size 

of a soil slippage by holding together and pulling down a larger area of slope after a small 

section has given way. Large trees that have become unstable can also pull down slopes and 

should be removed. Using plants with low water requirements can reduce the potential for soil 

saturation from irrigation. 

Swale Stabilization. On swales, the goal of vegetative stabilization is to prevent erosion within 

the swale, where runoff is concentrated and flows at higher velocities. If natural stream channels 

are involved, vegetation with deep root systems should be preserved, or if absent, planted above 

the channel to help maintain the channel banks. More information is provided in the subsequent 

section dealing with grass-lined swales. 

Surface Stabilization. On large, flat areas, the goal of vegetative stabilization is to reduce the 

loss of surface soil from sheet erosion. Vegetation should provide complete coverage to reduce 

the force of precipitation, which can shift soil particles to seal openings in the soil, reducing 

infiltration and increasing runoff. Vegetation should also provide many stem penetrations to slow 

runoff and increase infiltration. Deep rooting plants are less critical for erosion control in flat 

areas than on slopes because soils are not subject to the same forces that can cause slippage on a 

slope. However, trees and shrubs can increase infiltration, lessening the buildup of runoff, and 

transpire large volumes of water, reducing soil saturation. 

In areas susceptible to wind erosion, the goal of vegetative stabilization is to establish direct 

protection of the soil. Vegetation should provide dense and continuous surface cover. Binding 

the soil deeply is generally not a requirement. The ideal vegetation for this purpose is grass, 

which forms a mat of protection. In areas where the vegetation is developed, the grass generally 

has high maintenance requirements. In less developed, open areas, unmown grass, including 

perennial native species, can be used to provide protection. Trees and shrubs also can provide 

protection from the wind. 

Shoreline Stabilization. In lakes and ponds, the goal of vegetative stabilization is to prevent 

erosion of the shoreline. Wetland plants anchor the bottom of the lake or pond adjacent to the 

shore and help dissipate the erosive energy of waves. An important consideration in planting 

along shorelines is the need to establish favorable conditions for plant establishment and growth. 

These include the proper grading of side slopes and the control of upland erosion to prevent the 

buildup of silt and associated pollutants in the water. Designers should maintain awareness of 

regulatory requirements that might influence vegetation projects in a wetland environment 

(USAF 1998). 

Vegetation used for shoreline stabilization work should be native material selected because of 

strength, resiliency, vigor, and ability to withstand periodic inundation. Woody vegetation with 
Section 7: Technology Assessment 

7-8 

short, dense, flexible tops and large root systems works well. Other important factors include 

rapid initial growth, ability to reproduce, and resistance to disease and insects. 

According to Heyer (No Date), most streambank stabilization plantings have used various 

willows, including black willow (Salix nigra), sandbar willow (S. interior), meadow willow (S. 

petiolaris), heartleaf willow (S. rigida), and Ward willow (S. caroliniana). The size used 

depends on the severity of the erosion and the type of bank to be stabilized. 

Most tree revetment projects use either eastern red cedar (Juniperus virginiana) or hardwoods 

such as northern pin oak (Quercus ellipsoidalis). Important suggestions include the following: 

 Choose trees with many limbs and branches to trap as much sediment as possible. 

 Select decay-resistant trees. 

 Use recently cut trees—dead trees are more brittle and likely to break apart. 

 The tree size-diameter of the tree crown should be about two-thirds of the height of 

the eroding bank. 

 Cut off any trunk without limbs. 

 Place the tree revetments overlapping, butt end pointing upstream. 

 Begin and end revetments at stable points along the bank. 

 Choose an anchoring system according to the bank material to be stabilized and the 

weight of the object to be anchored. 

Vegetative measures for streambank stabilization offer an alternative to structural measures and 

are becoming well known as bioengineering techniques for streambanks. Using vegetative 

material for streambank stabilization could be the first step in reestablishing the riparian forest, 

which is essential for long-term stability of the streamside and floodplain areas. Each site must 

be evaluated separately as to the feasibility of using natural material (Heyer, No Date). 

Vegetative streambank stabilization, with the goal of protecting streambanks from the erosive 

forces of flowing water, is generally applicable where bankfull flow velocity does not exceed 6 

ft/sec and soils are erosion resistant (Smolen et al. 1988). Table 7-2 includes general guidelines 

for maximum allowable velocities in streams to be protected by vegetation. 

Table 7-2. Conditions where vegetative streambank stabilization is acceptable 

Frequency of bankfull flow 

Maximum allowable velocity for 

highly erodible soil 

Maximum allowable velocity for 

erosion-resistant soil 

> 4 times/yr 4 ft/sec 5 ft/sec 

1 to 4 times/yr 5 ft/sec 6 ft/sec 

< 1 time/yr 6 ft/sec 6 ft/sec 

Source: Smolen et al. 1988 
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7-9 

Temporary Vegetative Stabilization. Temporary vegetative cover such as rapidly growing 

annuals and legumes can be used to establish a temporary vegetative cover. Such covers are 

recommended for areas that (Fifield 1999) 

 Will not be brought to final grade within 30 days or are likely to be redisturbed 

 Require seeding of cut and fill slopes under construction 

 Require stabilization of soil storage areas and stockpiles 

 Require stabilization of temporary dikes, dams, and sediment containment systems 

 Require development of cover or nursery crops to assist with establishing perennial 

grasses 

Examples of temporary vegetation include wheat, oats, barley, millet, and sudan grass. 

Temporary seeding might not be effective in arid or semi-arid regions where seasonal lack of 

moisture prevents germination. It might be necessary to use a mixture of warm and cool season 

grasses to ensure germination. Mulching and geotextiles can be used to help provide temporary 

stabilization with vegetation, particularly in situations where establishing cover could be 

difficult. 

Permanent Vegetative Stabilization. Permanent vegetative cover such as a perennial grass or a 

legume cover can be used to establish a permanent vegetative cover. Permanent vegetation is 

recommended for the following (Fifield 1999): 

 Final graded or cleared areas where permanent vegetative cover is needed to stabilize 

the soil 

 Slopes designated to be treated with erosion control blankets 

 Grass-lined channels or waterways designed to be protected with channel liners 

The following subsections discuss the various types or means of providing vegetative 

stabilization. 

Grass-lined Channels 

General Description 

Grass-lined channels, or swales, convey stormwater runoff through a stable conduit. Vegetation 

lining the channel reduces the flow velocity of concentrated runoff. Grassed channels are usually 

not designed to control peak runoff loads by themselves and are often used in combination with 

other BMPs such as subsurface drains and riprap stabilization. 

Applicability 

Grassed channels should be used in areas where erosion-resistant conveyances are needed, such 

as in areas with highly erodible soils and slopes of less than 5 percent. They should be installed 

only where space is available for a relatively large cross-section. Grassed channels have a limited 

ability to control runoff from large storms and should not be used in areas where velocity 

exceeds 5 feet per second unless they are on erosion-resistant soils with dense groundcover at the 

soil surface. 
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7-10 

Design and Installation Criteria 

Because of their ease of construction and low cost, vegetation-lined waterways are frequently 

used for diversion and collection ditches. The U.S. Department of Agriculture’s (USDA’s) Soil 

Conservation Service’s (SCS) Engineering Field Manual (1979) recommends the maximum 

permissible velocities for individual site conditions shown in Table 7-3. 

Table 7-3. Maximum permissible velocities for individual site conditions for grass swales 

Site location Velocity 

Areas where only a sparse cover can be established or maintained 

because of shale, soils, or climate 

3.00 ft/sec (0.91 m/sec) 

If the vegetation is to be established by seeding 3.00 to 4.00 ft/sec (0.91 to 1.22 m/sec) 

Areas where a dense, vigorous sod is obtained quickly or where the 

runoff can diverted out of the waterway while the vegetation is being 

established 

4.00 to 5.00 ft/sec (1.22 to 1.52 m/sec) 

Source: USDA 1979 

Grassed waterways typically begin eroding in the invert of the channel if the velocity exceeds the 

sheer strength of the vegetation soil interface. Once the erosion process has started, it will 

continue until an erosion-resistant layer is encountered. If erosion of a channel bottom is 

occurring, rock or stone should be placed in the eroded area or the design should be changed 

(UNEP 1994). 

Grassed waterways on construction land must be able to carry peak runoff events from snowmelt 

and rainstorms (in some areas limited to up to 1 cubic meter of water per second). The size of the 

waterway depends on the size of the area to be drained. A typical grassed waterway cross-section 

is parabolic with a nearly flat-bottom, a bottom width of 3 meters (m), and channel depth of at 

least 30 centimeters (cm). Side slopes usually rise about 1 m for every 10 m horizontal distance 

but could be as steep as a 1 m rise for every 2 m of horizontal distance. The waterway should 

follow the natural drainage path if possible (Vanderwel and Abday 1998). The design should be 

site-specific and be derived using well-established procedures. 

Lined channels are a means of carrying water to lower elevations along steep parts of a 

waterway. Those portions of the waterway are precisely shaped and carefully lined with heavyduty erosion control matting (a geotextile product). The lining is covered with a layer of soil and 

seeded to grass. The resulting channel is highly resistant to erosion. Lined channels are 

appropriate for waterways that only carry water occasionally and have slopes of up to 10 percent. 

Companies that sell geotextile products provide detailed information on installation of their 

products (Vanderwel and Abday 1998). The design should be site-specific and be derived using 

well-established procedures. No standard procedure is available for evaluating the effectiveness 

of geotextile liners for pollutant removal. 

Grass-lined channels should be sited in accordance with the natural drainage system and should 

not cross ridges. The channel design should not have sharp curves or significant changes in 

slope. The channel should not receive direct sedimentation from disturbed areas and should be 

sited only on the perimeter of a construction site to convey relatively clean stormwater runoff. 
Section 7: Technology Assessment 

7-11 

They should be separated from disturbed areas by a vegetated buffer or other BMP to reduce 

sediment loads. 

Although exact design criteria should be based on local conditions, basic design 

recommendations for grassed channels include the following: 

 Construction and vegetation of the channel should occur before grading and paving 

activities begin. 

 Design velocities should be less than 5 ft/sec. 

 Geotextiles can be used to stabilize vegetation until it is fully established. 

 Covering the bare soil with sod or geotextiles can provide reinforced stormwater 

conveyance immediately. 

 Triangular-shaped channels should be used with low velocities and small quantities of 

runoff; parabolic grass channels are used for larger flows and where space is 

available; trapezoidal channels are used with large flows of low velocity (low 

gradient). 

 Outlet stabilization structures might be needed if the runoff volume or velocity has 

the potential to exceed the capacity of the receiving area. 

 Channels should be designed to convey runoff from a 10-year storm without erosion. 

 The sides of the channel should be sloped less than 3:1, with V-shaped channels 

along roads sloped 6:1 or less for safety. 

 All trees, bushes, stumps, and other debris should be removed during construction. 

Effectiveness 

Grass-lined channels can effectively transport stormwater from construction areas if they are 

designed for expected flow volumes and velocities and if they do not receive sediment directly 

from disturbed areas. The primary function is to carry the flow at a higher velocity without 

eroding or overtopping the channel. 

Limitations 

Grassed channels, if improperly installed, can alter the natural flow of surface water and have 

adverse effects on downstream waters. Additionally, if the design capacity is exceeded by a large 

storm event, the vegetation might not be sufficient to prevent erosion, and the channel might be 

destroyed. Clogging with sediment and debris reduces the effectiveness of grass-lined channels 

for stormwater conveyance. 

Maintenance 

Maintenance requirements for grass channels are relatively minimal. During the vegetation 

establishment period, the channels should be inspected after every rainfall. Other maintenance 

activities that should be carried out after vegetation is established are mowing, litter removal, and 

spot vegetation replacement. The most important objective in the maintenance of grassed 

channels is the maintaining of a dense and vigorous growth of turf. Periodic cleaning of 

vegetation and soil buildup in curb cuts is required so that water flow into the channel is 
Section 7: Technology Assessment 

7-12 

unobstructed. During the growing season, channel grass should be cut no shorter than the level of 

design flow, and the cuttings should be removed promptly. 

Cost 

Costs of grassed channels range according to depth, with a 1.5-foot-deep, 10-foot-wide grassed 

channel estimated to cost between $6,395 and $17,075 per trench, while a 3-foot-deep, 21-footwide grassed channel is estimated at $12,909 to $33,404 per trench (SWRPC 1991). 

As an alternative cost approximation, grassed channel construction costs can be developed using 

unit cost values. Shallow trenching (1 to 4 feet deep) with a backhoe in areas not requiring 

dewatering can be performed for $4 to $5 per cubic yard of removed material (R.S. Means 

2000). Assuming no disposal costs (i.e., excavated material is placed on either side of the 

trench), only the cost of fine grading, soil treatment, and grassing (approximately $2 per square 

yard of earth surface area) should be added to the trenching cost to approximate the total 

construction cost. Site-specific hydrologic analysis of the construction site is necessary to 

estimate the channel conveyance requirement; however, it is not unusual to have flows on the 

order of 2 to 4 cfs per acre served. For channel velocities between 1 and 3 feet per second, the 

resulting range in the channel cross-section area can be as low as 0.67 square foot per acre 

drained to as high as 4 square feet per acre. If the average channel flow depth is 1 foot, the low 

estimate for grassed channel installation is $0.27 per square foot of channel bottom per acre 

served per foot of channel length. The high estimate is $1.63 per square foot of channel bottom 

per acre served per foot of channel length. 

Seeding 

General Description 

Permanent seeding is used to control runoff and erosion on disturbed areas by establishing 

perennial vegetative cover from seed. It is used to reduce erosion, decrease sediment yields from 

disturbed areas, and provide permanent stabilization. This practice is both economical and 

adaptable to different site conditions, and it allows selection of the most appropriate plant 

materials. Seeding is a BMP that is particularly susceptible to local conditions such as the 

climatic conditions, physical and chemical characteristics of the soil, topography, and time of 

year. 

Applicability 

Permanent seeding is well suited in areas where permanent, long-lived vegetative cover is the 

most practical or most effective method of stabilizing the soil. Permanent seeding can be used on 

roughly graded areas that will not be regraded for at least a year. Vegetation controls erosion by 

protecting bare soil surfaces from displacement by raindrop impacts and by reducing the velocity 

and quantity of overland flow. The advantages of seeding over other means of establishing plants 

include lower initial costs and labor inputs. 

Design and Installation Criteria 

Areas to be stabilized with permanent vegetation must be seeded or planted 1 to 4 months after 

the final grade is achieved unless temporary stabilization measures are in place. Successful plant 

establishment can be maximized with proper planning; considering soil characteristics; selecting 
Section 7: Technology Assessment 

7-13 

plant materials that are suitable for the site; adequate seedbed preparation, liming, and 

fertilization; timely planting; and regular maintenance. Climate, soils, and topography are major 

factors that dictate the suitability of plants for a site. The soil on a disturbed site could require 

amendments to provide sufficient nutrients for seed germination and seedling growth. The 

surface soil must be loose enough for water infiltration and root penetration. Soil pH should be 

between 6.0 and 6.5 and can be increased with liming if soils are too acidic. Seeds can be 

protected with mulch to retain moisture, regulate soil temperatures, and prevent erosion during 

seedling establishment. 

Seedbed preparation is critical in established vegetation. Spraying seeds on a scraped slope will 

generally not provide satisfactory results. Typical seedbed preparation will begin with a soil test 

to determine the amount of lime or fertilizer that should be added. In addition, tillage should be 

performed that will break up clods so that seed contact can be established. When the seed is 

applied, it should be covered and lightly compacted. Natural or synthetic mulch is recommended 

to provide surface stabilization until the vegetation is established. In addition to providing 

surface stabilization, the mulch will also retard evaporation and encourage rapid growth. A 

suitable tack to hold the mulch might be necessary if the mulch is not otherwise anchored. Mulch 

as an erosion control practice is covered in a subsequent subsection. 

Depending on the amount of use permanently seeded areas receive, they can be considered high- or 

low-maintenance areas. High-maintenance areas are mowed frequently, limed and fertilized 

regularly, and either (1) receive intense use (for example, athletic fields) or (2) require maintenance 

to an aesthetic standard (for example, home lawns). Grasses used for high-maintenance areas are 

long-lived perennials that form a tight sod and are fine-leaved. High-maintenance vegetative cover 

is used for homes, industrial parks, schools, churches, and recreational areas. 

Low-maintenance areas are mowed infrequently or not at all and do not receive lime or fertilizer 

regularly. Plants must be able to persist with minimal maintenance over long periods. Grass and 

legume mixtures are favored for these sites because legumes fix nitrogen from the atmosphere. 

Sites suitable for low-maintenance vegetation include steep slopes, streambanks or channel 

banks, some commercial properties, and utility turf areas such as road banks. 

Effectiveness 

Seeding that results in a successful stand of grass has been shown to remove between 50 and 100 

percent of TSS from stormwater runoff, with an average removal of 90 percent (USEPA 1993). 

Limitations 

The effectiveness of permanent seeding can be limited because of the high erosion potential 

during establishment, the need to reseed areas that fail to establish, limited seeding times 

depending on the season, and the need for stable soil temperature and soil moisture content 

during germination and early growth. Permanent seeding does not immediately stabilize soils—

temporary ESC measures should be in place to prevent off-site transport of pollutants from 

disturbed areas. Use of mulches or geotextiles or both could improve the likelihood of 

successfully establishing vegetation. 
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7-14 

Maintenance 

Grasses should emerge within 4 to 28 days and legumes within 5 to 28 days after seeding. A 

successful stand should exhibit the following: 

 Vigorous dark green or bluish green seedlings—not yellow 

 Uniform density, with nurse plants, legumes, and grasses well intermixed 

 Green leaves—perennials remaining throughout the summer, at least at the plant bases 

Seeded areas should be inspected for failure, and necessary repairs and reseeding should be made 

as soon as possible. If a stand has inadequate cover, the choice of plant materials and quantities 

of lime and fertilizer should be reevaluated. Depending on the condition of the stand, areas can 

be repaired by overseeding or reseeding after complete seedbed preparation. If the timing is bad, 

an annual grass seed can be overseeded to temporarily thicken the stand until a suitable time for 

seeding perennials. Consider seeding temporary, annual species if the season is not appropriate 

for permanent seeding. If vegetation fails to grow, the soil should be tested to determine whether 

low pH or nutrient imbalances are responsible. Local NRCS or county extension agents can also 

be contacted for seeding and soil testing recommendations. 

On a typical disturbed site, full plant establishment usually requires refertilization in the second 

growing season. Soil tests should be used to determine whether more fertilizer needs to be added. 

Do not fertilize cool season grasses in late May through July. Grass that looks yellow might be 

nitrogen deficient. Nitrogen fertilizer should not be used if the stand contains more than 20 

percent legumes. 

Cost 

Seeding costs range from $200 to $1,000 per acre and average $400 per acre. Maintenance costs 

range from 15 to 25 percent of initial costs and average 20 percent (USEPA 1993). R.S. Means 

(2000) indicates the cost of mechanical seeding to be approximately $900 per acre and 

demonstrates that the coverage cost varies with the seed type, seeding approach and scale (total 

acreage to be seeded). For example, hydro or water-based seeding for grass is estimated to be 

$700 per acre, but seeding of field grass species is only $540 per acre (Costs include materials, 

labor, and equipment, with profit and overhead). If surface preparation is required, the 

installation costs increase. R.S. Means suggests the cost of fine grading, soil treatment, and 

grassing is approximately $2 per square yard. 

Sodding 

General Description 

Sodding is a permanent erosion control practice that involves laying a continuous cover of grass 

sod on exposed soils. In addition to stabilizing soils, sodding can reduce the velocity of stormwater 

runoff. Sodding can provide immediate vegetative cover for critical areas and stabilize areas that 

cannot be vegetated by seed. It can also stabilize channels or swales that convey concentrated 

flows and reduce flow velocities. While sodding is not as dependent on local conditions as seeding 

is, it does depend on soil and climatic conditions to be successful. Watering immediately after 

installation and occasionally until establishment is generally beneficial. 
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7-15 

Applicability 

Sodding is appropriate for any graded or cleared area that might erode, requiring immediate 

vegetative cover. Locations particularly well suited to sod stabilization are the following: 

 Waterways and channels carrying intermittent flow 

 Areas around drop inlets that require stabilization 

 Residential or commercial lawns and golf courses where prompt use and aesthetics 

are important 

 Steeply sloped areas 

Design and Installation Criteria 

Sodding eliminates the need for seeding and mulching and produces more reliable results with 

less maintenance. Sod can be laid during times of the year when seeded grasses can fail. The sod 

must be watered frequently within the first few weeks of installation. Some seedbed preparation 

is recommended, including smoothing to provide contact between the sod and the soil surface 

and soil testing to determine liming and fertilizer application rates. Because sod provides 

instantaneous cover, mulches are not typically recommended, but anchoring might be 

appropriate on steep slopes. 

The type of sod selected should be composed of plants adapted to site conditions. Sod 

composition should reflect environmental conditions as well as the function of the area where the 

sod will be laid. The sod should be of known genetic origin and be free of noxious weeds, 

diseases, and insects. The sod should be machine cut at a uniform soil thickness of 15 to 25 mm 

at the time of establishment (this does not include top growth or thatch). Soil preparation and 

addition of lime and fertilizer could be needed—soils should be tested to determine whether 

amendments are needed. Sod should be laid in strips perpendicular to the direction of water flow 

and staggered in a brick-like pattern. The corners and middle of each strip should be stapled 

firmly. Jute or plastic netting can be pegged over the sod for further protection against washout 

during establishment. 

Areas to be sodded should be cleared of trash, debris, roots, branches, stones, and clods larger 

than 2 inches in diameter. Sod should be harvested, delivered, and installed within a period of 36 

hours. Sod not transplanted within this period should be inspected and approved before its 

installation. 

Limitations 

Compared to seed, sod is more expensive and more difficult to obtain, transport, and store. Care 

must be taken to prepare the soil and provide adequate moisture before, during, and after installation 

to ensure successful establishment. If sod is laid on poorly prepared soil or unsuitable surface, the 

grass will die quickly because it is unable to root. Sod that is not adequately irrigated after 

installation can cause root dieback because grass does not root rapidly and is subject to drying. 

Effectiveness 

Sod has been shown to remove between 98 and 99 percent of TSS in runoff (USEPA 1993). It is 

therefore a highly effective management practice for ESC. 
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7-16 

Maintenance 

Watering is very important to maintain adequate moisture in the root zone and to prevent dormancy, 

especially within the first few weeks of installation, until it is fully rooted. Mowing should not result 

in the removal of more than one-third of the shoot. Grass height should be maintained to be 2–3 

inches long. After the first growing season, sod might require fertilization or liming. 

Permanent, fine turf areas require yearly fertilization. Warm-season grass should be fertilized in 

late spring to early summer, and cool-season grass in late winter and again in early fall. 

Cost 

Average installation costs of sod average $0.20 per square foot and range from $0.10 to $1.10 

per square foot; maintenance costs are approximately 5 percent of installation costs (USEPA 

1993). R.S. Means (2000) indicates the sodding ranges between $250 and $750 per 1,000 square 

feet for 1-inch deep bluegrass sod on level ground, depending on the size of the area treated (unit 

costs value are for orders over 8,000 square feet and less than 1,000 square feet, respectively). 

Bent grass sod values range between $350 and $500 per 1,000 square feet; again, the lower value 

is more likely for most construction sites because it is for large area applications. (Costs include 

materials, labor, and equipment, with profit and overhead). 

Mulching 

General Description 

Mulching is a temporary erosion control practice in which materials such as grass, hay, wood 

chips, wood fibers, straw, or gravel are placed on exposed or recently planted soil surfaces. 

Mulching is highly recommended as a stabilization method and is most effective when anchored 

in place until vegetation is well established. In addition to stabilizing soils, mulching can reduce 

the velocity of stormwater runoff. When used in combination with seeding or planting, mulching 

can aid plant growth by holding seeds, fertilizers, and topsoil in place; by preventing birds from 

eating seeds; by retaining moisture; and by insulating plant roots against extreme temperatures. 

Mulch mattings are materials such as jute or other wood fibers that are formed into sheets and 

are more stable than loose mulch. They can also be easily unrolled during the installation process 

and are particularly useful in steeper areas or in channels. Netting can be used to stabilize soils 

while plants are growing, although netting does not retain moisture or insulate against extreme 

temperatures. Mulch binders consist of asphalt or synthetic materials that are sometimes used 

instead of netting to bind loose mulches, but they have been found to have limited usefulness. 

Applicability 

Mulching is often used in areas where temporary seeding cannot be used because of 

environmental constraints. Mulching can provide immediate, effective, and inexpensive erosion 

control. On steep slopes and critical areas such as waterways, mulch matting is used with netting 

or anchoring to hold it in place. Mulches can be used on seeded and planted areas where slopes 

are steeper than 2:1 or where sensitive seedlings require insulation from extreme temperatures. 
Section 7: Technology Assessment 

7-17 

Design and Installation Criteria 

When possible, organic mulches should be used for erosion control and plant material 

establishment. Suggested materials include loose straw, netting, wood cellulose, or agricultural 

silage. All materials should be free of seed, and loose hay or straw should be anchored by 

applying tackifier, stapling netting over the top, or crimping with a mulch crimping tool. 

Materials that are heavy enough to stay in place do not need anchoring (for example, gravel). 

Steepness of the slope will also affect the extent of anchoring the mulch. Other examples include 

hydraulic mulch products with 100 percent post-consumer paper content, yard trimming 

composts, and wood mulch from recycled stumps and tree parts. Inorganic mulches such as pea 

gravel or crushed granite can be used in unvegetated areas. 

Mulches might require a binder, netting, or tacking. All straw and loose materials must have a 

binder to hold them in place. Mulch materials that float away during storms can clog drainage 

ways and lead to flooding. The extent of binding depends on the type of mulch applied. Effective 

use of netting and matting material requires firm, continuous contact between the materials and 

the soil. If there is no contact, the material will not hold the soil, and erosion will occur 

underneath the material. Grading is not necessary before mulching. 

There must be adequate coverage, or erosion, washout, and poor plant establishment will result. 

If an appropriate tacking agent is not applied or if it is applied in an insufficient amount, mulch 

will not withstand wind and runoff. The channel grade and liner must be appropriate for the 

amount of runoff or the channel bottom will erode. Also, hydromulch should be applied in 

spring, summer, or fall to prevent deterioration of the mulch before plants can become 

established. Table 7-4 presents guidelines for installing mulches, but local conditions could 

warrant additional requirements. 

Table 7-4. Typical mulching materials and application rates 

Material Rate per acre Requirements Notes 

Organic mulches 

Straw 1–2 tons Dry, unchopped, unweathered; 

avoid weeds. 

Spread by hand or machine; must be 

tacked or tied down. 

Wood fiber or 

wood cellulose 

0.5–1 ton Use with hydroseeder; can be used to 

tack straw. Do not use in hot, dry 

weather. 

Wood chips 5–6 tons Air dry. Add fertilizer N, 12 

lb/ton. 

Apply with blower, chip handler, or by 

hand. Not for fine turf areas. 

Bark 35 yd3 Air dry, shredded or 

hammermilled, or chips. 

Apply with mulch blower, chip handler, 

or by hand. Do not use asphalt tack. 

Nets and mats 

Jute net Cover area Heavy, uniform; woven of single 

jute yarn. Used with organic 

mulch. 

Withstands water flow. 

Excelsior (wood 

fiber) mat 

Cover area 

Fiberglass 

roving 

0.5–1 ton Continuous fibers of drawn 

glass bound together with a 

nontoxic agent. 

Apply with compressed air ejector. Tack 

with emulsified asphalt at a rate of 25-

35 gal/1,000 ft2 . 
Section 7: Technology Assessment 

7-18 

Effectiveness 

Mulching effectiveness varies with the type of mulch used and local conditions such as rainfall 

and runoff amounts. Percent soil loss reduction for different mulches ranges from 53 to 99.8 

percent, and associated water velocity reductions range from 24 to 78 percent (Harding 1990). 

Table 7-5 shows soil loss and water velocity reductions for different mulch treatments. 

Table 7-5. Measured reductions in soil loss for different mulch treatments 

Mulch characteristics 

Soil loss reduction 

(%) 

Water velocity reduction (%) 

relative to bare soil 

100% wheat straw/top net 97.5% 73% 

100% wheat straw/two nets 98.6% 56% 

70% wheat straw, 30% coconut fiber 98.7% 71% 

70% wheat straw, 30% coconut fiber 99.5% 78% 

100% coconut fiber 98.4% 77% 

Nylon monofilament/two nets 99.8% 74% 

Nylon monofilament/rigid/bonded 53.0% 24% 

Vinyl monofilament/flexible/bonded 89.6% 32% 

Curled wood fibers/top net 90.4% 47% 

Curled wood fibers/two nets 93.5% 59% 

Antiwash netting (jute) 91.8% 59% 

Interwoven paper and thread 93.0% 53% 

Uncrimped wheat straw–2,242 kg/ha 84.0% 45% 

Uncrimped wheat straw–4,484 kg/ha 89.3% 59% 

Source: Harding 1990, as cited in USEPA 1993 

Limitations 

Mulching, matting, and netting might delay seed germination because the cover changes soil 

surface temperatures. The mulches themselves are subject to erosion and could be washed away 

in a large storm if not sufficiently anchored with netting or tacking. Maintenance is necessary to 

ensure that mulches provide effective erosion control. 

Maintenance 

Mulches must be anchored to resist wind displacement. Netting should be removed when 

protection is no longer needed and disposed of in a landfill or composted. Mulched areas should 

be inspected frequently to identify areas where mulch has loosened or been removed, especially 

after rain storms. Such areas should be reseeded (if necessary) and the mulch cover replaced 

immediately. Mulch binders should be applied at rates recommended by the manufacturer. If 

washout, breakage, or erosion occurs, surfaces should be repaired, reseeded, and remulched, and 

new netting should be installed. Inspections should be continued until vegetation is firmly 

established. 

Cost 

The costs for various types of mulches vary by the type of material and also whether seeding is 

incorporated. The costs of seed and mulch average $1,500 per acre and range from $800 to 
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7-19 

$3,500 per acre (USEPA 1993). Ground hydromulching applied between fiscal year 2000 and 

2003 in the southwestern United States had a cost range of $1,675 to $3,000 per acre (Napper 

2006). The California Stormwater Quality Association’s (CSQA’s) Stormwater BMP Handbook: 

Construction reports the average cost of installing wood fiber mulch as $900 per acre (CSQA 

2003). R.S. Means (2000) estimates the cost of power mulching to be $22.50 per 1,000 square 

feet, for large volume applications. 

Vegetated Buffer Strips 

General Description 

Vegetated buffers are areas of either natural or established vegetation that are maintained to 

protect the water quality of neighboring areas. Buffer zones reduce the velocity of stormwater 

runoff, provide an area for the runoff to permeate the soil, allow ground water recharge, and act 

as filters to catch sediment. The reduction in velocity also helps to prevent soil erosion. 

Applicability 

Vegetated buffers can be used in any area that is able to support vegetation, but they are most 

effective and beneficial on floodplains, near wetlands, along streambanks, and on steep, unstable 

slopes. They are also effective in separating land use areas that are not compatible and in 

protecting wetlands or waterbodies by displacing activities that could be sources of nonpoint 

source pollution. 

Design and Installation Criteria 

To establish an effective vegetative buffer, the following guidelines should be followed: 

 Soils should not be compacted. 

 Slopes should be less than 5 percent. 

 Buffer widths should be determined after careful consideration of slope, vegetation, 

soils, depth to impermeable layers, runoff sediment characteristics, type and quantity 

of stormwater pollutants, and annual rainfall. 

 Buffer widths should increase as slope increases. 

 Zones of vegetation (native vegetation in particular), including grasses, deciduous and 

evergreen shrubs, and understory and overstory trees, should be intermixed. 

 In areas where flows are concentrated and velocities are high, buffer zones should be 

combined with other structural or nonstructural BMPs as a pretreatment. 

Vegetated strips have been studied extensively, with emphasis placed on their effectiveness in 

removing sediment and other pollutants. Vegetated strips are most appropriate at sites where 

sediment loads are relatively low, because high sediment loads will cause large quantities of 

deposition along the leading edge of the vegetation. This deposition will cause the flow to divert 

around the vegetation in a concentrated flow pattern, which will cause short-circuiting and 

greatly reduce removal efficiency. Variability in vegetation density and uniformity often causes 

similar problems. Removal efficiency depends on a combination of slope, length, and width of 

the filter; density of the vegetation; sediment characteristics, hydraulics of the flow; and 

infiltration. The interaction of these variables is complex and prevents the process from being 
Section 7: Technology Assessment 

7-20 

reduced to a simple relationship except on a local basis. For site-specific local conditions, 

methods have been developed that allow trapping to be related to strip length and slope. 

Effectiveness 

Considerable data have been collected on the effectiveness of buffer strips for specific 

conditions. Numerous factors such as infiltration rate, flow depth, slope, dimensions of the 

buffer, density and type of vegetation, sediment size, and sediment density impact removal rates. 

Recent studies show that even short vegetative buffers can trap high percentages of sediment and 

certain chemicals. A significant concern is preventing flow from concentrating to maintain 

adequate the travel time through the buffer to allow the removal of pollutants. 

Several researchers have measured greater than 90 percent reductions in sediment and nitrate 

concentrations; buffer/filter strips do a reasonably good job of removing phosphorus attached to 

sediment, but they are relatively ineffective in removing dissolved phosphorus (Gillman 1994). 

However, because the hydraulics of flow through buffer strips are not well defined and can vary 

considerably by site conditions, it is difficult to consistently estimate the effectiveness of buffer 

strips. 

Limitations 

Vegetated buffers require plant growth before they can be effective, and land must be available 

on which to plant the vegetation. If land costs are very high, buffer zones might not be costeffective. Although vegetated buffers help to protect water quality, they usually do not 

effectively mitigate concentrated stormwater flows to neighboring or downstream wetlands. 

Maintenance 

Keeping the vegetation in vegetated buffers healthy requires routine maintenance, which 

(depending on species, soil types, and climatic conditions) can include weed and pest control, 

mowing, fertilizing, liming, irrigating, and pruning. Inspection and maintenance are most 

important when buffer areas are first installed. Once established, vegetated buffers do not require 

much maintenance beyond the routine procedures listed earlier and periodic inspections of the 

areas, especially after any heavy rainfall and at least once a year. Inspections should focus on 

encroachment, gully erosion, density of vegetation, evidence of concentrated flows through the 

areas, and any damage from foot or vehicular traffic. If there are more than 6 inches of sediment 

in one place, it should be removed. 

Cost 

Conceptual cost estimates for grassed buffer strips can be made on the basis of square footage 

using unit cost values. R.S. Means (2000) estimates the cost of fine grading, soil treatment, and 

grassing to be $2 per square yard. This cost estimate is based on applying traditional lawn seed. 

The cost for field seed is lower than lawn seed, reducing the coverage price. Where gently 

sloping areas need to be grassed only with acceptable species, the cost can be as low as $0.38 per 

square yard. 
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7-21 

7.2.1.3. Non-Vegetative Stabilization 

Non-vegetative practices can also be used during construction to stabilize and protect soil 

exposed to the erosive forces of water, as well as post-construction to provide a filtration 

mechanism for stormwater pollutants. Non-vegetative stabilization techniques operate on the 

same principles as vegetative stabilization; however, these practices use a variety of synthetic on 

natural materials (such as coconut fiber) to stabilize exposed soils. Non-vegetative practices are 

particularly useful as temporary stabilization measures until vegetative practices have had a 

chance to become established. The following discussion refers to non-vegetative stabilization as 

a construction BMP that stabilizes and protects soil from erosion. A variety of proprietary and 

vendor-supplied materials are in this category, which are not discussed in detail. 

Geotextiles 

General Description 

Geotextiles are porous fabrics also known as filter fabrics, road rugs, synthetic fabrics, 

construction fabrics, or simply fabrics. Geotextiles are manufactured by weaving or bonding 

fibers made from synthetic materials such as polypropylene, polyester, polyethylene, nylon, 

polyvinyl chloride, glass, and various mixtures of such materials. As a synthetic construction 

material, geotextiles are used for a variety of purposes such as separators, reinforcement, 

filtration and drainage, and erosion control (USEPA 1992). Some geotextiles are made of 

biodegradable materials such as mulch matting and netting. Mulch mattings are jute or other 

wood fibers that have been formed into sheets and are more stable than normal mulch. Netting is 

typically made from jute, wood fiber, plastic, paper, or cotton and can be used to hold the 

mulching and matting to the ground. Netting can also be used alone to stabilize soils while the 

plants are growing; however, it does not retain moisture or temperature well. 

Geotextiles can aid in plant growth by holding seeds, fertilizers, and topsoil in place. Fabrics are 

relatively inexpensive for certain applications—a wide variety of geotextiles exist to match the 

specific needs of the site. 

Applicability 

Geotextiles can be used for erosion control by using it alone. Geotextiles can be used as matting, 

which is used to stabilize the flow of channels or swales or to protect seedlings on recently 

planted slopes until they become established. Matting can be used on tidal or streambanks where 

moving water is likely to wash out new plantings. They can also be used to protect exposed soils 

immediately and temporarily, such as when active piles of soil are left overnight. 

Geotextiles are also used as separators. An example of such a use is geotextile as a separator 

between riprap and soil. This sandwiching prevents the soil from being eroded from beneath the 

riprap and maintaining the riprap’s base. 

Design and Installation Criteria 

Many types of geotextiles are available. Therefore, the selected fabric should match its purpose. 

State or local requirements, design procedures, and any other applicable requirements should be 

considered. In the field, important concerns include regular inspections to determine whether 

cracks, tears, or breaches are present in the fabric and to identify when repairs should be made. 
Section 7: Technology Assessment 

7-22 

Effective netting and matting require firm, continuous contact between the materials and the soil. 

If there is no contact, the material will not hold the soil, and erosion will occur underneath the 

material. 

Effectiveness 

A geotextile’s effectiveness depends on the strength of the fabric and proper installation. For 

example, when protecting a cut slope with a geotextile, it is important to properly anchor the 

fabric using appropriate length and spacing of wire staples. This will ensure that it will not be 

undermined by a storm event. 

Limitations 

Geotextiles (primarily synthetic types) have the potential disadvantage of being sensitive to light 

and must be protected before installation. Some geotextiles might promote increased runoff and 

can blow away if not firmly anchored. Depending on the type of material used, geotextiles might 

need to be disposed of in a landfill, making them less desirable than vegetative stabilization. If 

the fabric is not properly selected, designed, or installed, the effectiveness can be reduced 

drastically. 

Maintenance 

Regular inspections should be made to determine whether cracks, tears, or breaches have formed 

in the fabric—it should be repaired or replaced immediately. It is necessary to maintain contact 

between the ground and the geotextile at all times. 

Cost 

Costs for geotextiles range from $0.50 to $10.00 per square yard depending on the type chosen 

(SWRPC 1991). 

Erosion Control Matting 

General Description 

Erosion control mats can be either organic or made from a synthetic material. A wide variety of 

products exist to match the specific needs of the site. Organic mats are made from such materials 

as wood fiber, jute net, and coconut coir fiber. Unlike organic matter, synthetic mats are 

constructed from non-biodegradable materials and remain in place for many years. These organic 

mats are classified as turf reinforcement mats (TRMs) and erosion control and revegetation mats 

(ECRMs) (USDOT 1995). 

Erosion control matting aids in plant growth by holding seeds, fertilizers, and topsoil in place. 

Matting can be used to stabilize the flow of channels or swales or to protect seedlings on recently 

planted slopes until they become established. Matting can be used on tidal or streambanks where 

moving water is likely to wash out new plantings. It can also be used to protect exposed soils 

immediately and temporarily, such as when active piles of soil are left overnight. 

Applicability 

Mulch mattings, netting, and filter fabrics are particularly useful in steep areas and drainage 

swales where loose seed is vulnerable to being washed away or failing to survive dry soil (UNEP 
Section 7: Technology Assessment 

7-23 

1994). Erosion control mats can also be used to separate riprap and soil. That results in a 

sandwiching effect, maintaining the riprap’s base and preventing the soil beneath from being 

eroded. 

Design and Installation Criteria 

Matting is especially recommended for steep slopes and channels (UNEP 1994). Many types of 

erosion control mats are available. Therefore, the selected product should match its purpose. 

Effective netting and matting require firm, continuous contact between the materials and the soil. 

If there is no contact, the material will not hold the soil, and erosion will occur underneath the 

material. 

Wood fiber or curled wood mat consists of curled wood with fibers, 80 percent of which are 150 

mm or longer, with a consistent thickness and even distribution of fiber over the entire mat. The 

top side of the mat is covered with a biodegradable plastic mesh. The mat should be placed in the 

channel or on the slope parallel to the direction of flow and secured with staples and check slots. 

It should be applied immediately after seeding operations (USDOT 1995). 

Jute net consists of jute yarn, approximately 5 mm in diameter, woven into a net with openings 

that are approximately 10 by 20 mm (or 0.40 to 0.79 inches). The jute net should be loosely laid 

in the channel parallel to the direction of flow. The net is secured with staples and check slots at 

intervals along the channel. Placement of the jute net should be done immediately after seeding 

operations (USDOT 1995). 

Coconut blankets are constructed of biodegradable coconut fibers that resist decay for 5 to 10 

years to provide long, temporary erosion control protection. The materials are often encased in 

ultraviolet stabilized nets and sometimes have a composite, polypropylene structure to provide 

permanent turf reinforcement. These materials are best used for waterway stabilization and 

slopes that require longer periods to stabilize (USDOT 1995). 

Within the synthetic mat category are TRMs and ECRMs. TRMs are three-dimensional polymer 

nettings or monofilaments formed into a mat. They have sufficient thickness (> 13 mm or 0.5 

inch) and void space (> 90 percent) to allow for soil filling and retention. The mat acts as a 

traditional mat to protect the seed and increase germination. As the turf establishes, the mat 

remains in place as part of the root structure. That gives the established turf a higher strength and 

resistance to erosion (USDOT 1995). 

ECRMs are composed of continuous monofilaments bound by heat fusion or stitched between 

nettings. They are thinner than TRMs and do not have the void space to allow for filling of soil. 

They act as permanent mulch and allow vegetation to grow through the mat (USDOT 1995). 

Effectiveness 

The effectiveness of erosion control matting depends on the strength of the material and proper 

installation. For example, when protecting a cut slope with an erosion control mat, it is important 

to anchor the mat properly. That ensures that it will not be undermined by a storm event. 

While erosion control blankets can be effective, their performance varies. Some general trends 

are that organic materials tend to be the most effective (Harding 1990) and that thicker materials 
Section 7: Technology Assessment 

7-24 

are typically superior (Fifield 1999), but there are exceptions to both of these trends. Information 

about product testing of blankets is generally lacking. One notable exception is the Texas 

Department of Transportation, which publishes the findings of its testing program in the form of 

a list of acceptable and unacceptable materials for specific uses. 

Limitations 

Erosion control mats (primarily synthetic types) are sensitive to light and for that reason must be 

protected before installation. Some erosion control mats might cause an increase in runoff or 

blow away if not firmly anchored. Erosion control mats might need to be properly disposed of in 

a landfill, depending on the type of material. Effectiveness could be reduced if the matting is not 

properly selected, designed, or installed. 

Maintenance 

Regular inspections are necessary to determine whether cracks, tears or breaches have formed in 

the matting. Contact between the ground and erosion control mat should be maintained at all 

times and trapped sediment removed after each storm event. 

Cost 

Costs for erosion control mats range from $0.50 to $10.00 per square yard depending on the type 

chosen (SWRPC 1991). Geosynthetic TRMs are widely used for immediate erosion protection 

and long-term vegetative reinforcement, usually for steeply sloped areas or areas exposed to 

runoff flows. The Erosion Control Technology Council (ECTC—a geotextile industry support 

association) estimates that TRMs cost approximately $7.00 per square yard (installed) for 

channel protection (Lancaster et al. 2002). Channel protection is one of the most demanding of 

installations (much more demanding than general coverage of denuded area). The ECTC 

estimates the cost to install a simple soil blanket (or rolled erosion control product), seed, and 

fertilizer to be $1.00 per square yard (Honnigford 2002). 

USDA’s Burned Area Emergency Response (BAER) Treatment Catalog reports that most rolled 

erosion control products are priced by the square yard and sold in rolls with prices, without 

installation, ranging from $0.35 to $0.50 per square yard to more than $1 per square yard (Napper 

2006). CSQA’s Stormwater BMP Handbook: Construction reports material costs of $0.50 to 

$0.57 per square yard for biodegradable materials, $3.00 to $4.50 per square yard for permanent 

materials, and $0.04 to $0.05 per staple (CSQA 2003). The installation cost for jute mesh, 

100 square yards per roll, 4 inches wide, stapled is $0.49 per square yard (R.S. Means 2009). 

Topsoiling 

General Description 

Topsoiling is the placement of a surface layer of soil enriched in organic matter over a prepared 

subsoil to provide a suitable soil medium for vegetative growth on areas with poor moisture, low 

nutrient levels, undesirable pH, or the presence of other materials that would inhibit the 

establishment of vegetation. Advantages of topsoil include its high organic matter content and 

friable consistency and its water-holding capacity and nutrient content. The texture and friability 

of topsoil are usually more conducive to seedling emergence and root growth. In addition to 

being a better growth medium, topsoil is often less erodible than subsoils, and the coarser texture 
Section 7: Technology Assessment 

7-25 

of topsoil increases infiltration capacity and reduces runoff. During construction, topsoil is often 

removed from the project area and stockpiled. It is replaced on areas to be grassed or landscaped 

during the final stages of the project. 

Applicability 

Conditions where topsoiling applies include the following: 

 Where a sufficient supply of quality topsoil is available 

 Where the subsoil or areas of existing surface soil present the following problems: 

o The structure, pH, or nutrient balance of the available soil cannot be amended by 

reasonable means to provide an adequate growth medium for the desired 

vegetation 

o The soil is too shallow to provide adequate rooting depth or will not supply 

necessary moisture and nutrients for growth of desired vegetation 

o The soil contains substances toxic to the desired vegetation 

 Where high quality turf or ornamental plants are desired 

 Where slopes are 2:1 or flatter 

Design and Installation Criteria 

The topsoil should be uniformly distributed over the subsoil to a minimum compacted depth of 

50 mm (2 inches) on slopes steeper than 3:1 and 100 mm (4 inches) on flatter slopes. 

Thicknesses of 100 to 150 mm are preferred for vegetation establishment via seeding. The 

topsoil should not be placed while in a frozen or muddy condition or when the subsoil is 

excessively wet, frozen, or in a condition that is detrimental to proper grading or seedbed 

preparation. The final surface should be prepared so that any irregularities are corrected and 

depressions and water pockets do not form. If the topsoil has been treated with soil sterilants, it 

should not be placed until the toxic substances have dissipated (USDOT 1995). Table 7-6 

summarizes the cubic yards of topsoil required for application to various depths. 

Table 7-6. Cubic yards of topsoil required for 

application to various depths 

Depth 

(inches) Per 1,000 sq ft Per acre 

1 3.1 134 

2 6.2 268 

3 9.3 403 

4 12.4 536 

5 15.5 670 

6 18.6 804 

Source: Smolen et al. 1988. 

On slopes and areas that will not be mowed, the surface could be left rough after spreading 

topsoil. A disk can be used to promote bonding at the interface between the topsoil and subsoil 

(Smolen et al. 1988). 
Section 7: Technology Assessment 

7-26 

Effectiveness 

No information is available describing the effectiveness of applying topsoil as a BMP. 

Limitations 

Limitations of applying topsoil can include the following: 

 Topsoil spread when conditions are too wet, resulting in severe compaction 

 Topsoil mixed with too much unsuitable subsoil material, resulting in poor vegetation 

establishment 

 Topsoil contaminated with soil sterilants or chemicals, resulting in poor or no 

vegetation establishment 

 Topsoil not adequately incorporated or bonded with the subsoil, resulting in poor 

vegetation establishment and soil slippage on sloping areas 

 Topsoiled areas not protected, resulting in excessive erosion 

Maintenance 

Newly topsoiled areas should be inspected frequently until the vegetation is established. Eroded 

or damaged areas should be repaired and revegetated. 

Cost 

Topsoiling costs are a function of the price of topsoil, the hauling distance, and the method of 

application. R.S. Means (2000) reports unit cost values of $3 and $4 per square yard, for 4 and 6 

inches of topsoil cover, respectively. That price is for furnishing and placing of topsoil, and 

includes materials, labor, and equipment, with profit and overhead. 

7.2.2. WATER HANDLING PRACTICES 

7.2.2.1. Earth Dike 

General Description 

An earth dike is a temporary or permanent ridge of soil designed to channel water to a desired 

location. Dikes are used to divert the flow of runoff by constructing a ridge of soil that intercepts 

and directs the runoff to the desired outlet or alternative management practice, such as a pond. 

The practice serves to reduce the length of a slope for erosion control and protect downslope 

areas. An earth dike can be used to prevent runoff from going over the top of a cut and eroding 

the slope, directing runoff away from a construction site or building; to divert clean water from a 

disturbed area; or to reduce a large drainage area into a more manageable size. Dikes should be 

stabilized with vegetation after construction (NAHB, No Date). 

Applicability 

Earth dikes are applicable to all areas; the size of the dike is correlated to the size of the drainage 

area (NAHB, No Date). 
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7-27 

Design and Installation Criteria 

The location of dikes should take into consideration outlet conditions, existing land use, 

topography, length of slope, soils, and development plans. The capacity of earth dikes and 

diversions should be suitable for the area that is being protected, including adequate freeboard, or 

extra depth that is added as a safety margin. For homes, schools, and industrial buildings, the 

recommended design frequency storm is 50 years and the freeboard is 0.5 feet (NAHB, No Date). 

Earth dikes can be employed as a perimeter control. For small sites, a compacted, 2-foot-tall dike 

is usually suitable if hydroseeded. Larger dikes will actually divert runoff to another portion of 

the site, usually to a downstream sediment trap or basin. Therefore, the designer should ensure 

that they have the capacity for the 10-year storm event and that the channel created behind the 

dike is properly stabilized to prevent erosion (Brown and Schueler 1997). In addition, the 

downstream structure must be sized to handle the flow from the dike. Dikes should be designed 

using standard hydrologic and hydraulic calculations and certified by a professional hydrologist 

or engineer. Diversion dikes should be installed before the majority of the soil-disturbing 

activity. As soon as the dike form is completed, it should be machine compacted, fertilized, and 

either seeded and mulched or sodded. Excavated materials should be properly stockpiled for 

future use or disposed of properly. Dikes should have an outlet that functions with a minimum of 

erosion. Depending on site conditions and outlet structures, the runoff directed by dikes might 

need to be conveyed to a sediment-trapping device, such as a sediment basin or detention pond. 

As grades increase over 4 percent, geotextile material or sod could be required to control erosion. 

Slopes greater than 8 percent could require riprap. Dikes can be removed when the drainage area 

and outlet are stabilized (NAHB, No Date). Dike design criteria must incorporate site-specific 

conditions because dimensions depend on expected flows, soil types, and climatic conditions. All 

such inputs vary tremendously across sections of the country. 

Effectiveness 

No information has been found on the effectiveness of earth dikes used as BMPs, although 

terraces often have sediment removal rates of up to 90 percent. 

Limitations 

An erosion-resistant lining in the channel might be needed to prevent erosion in the channel 

caused by excessive grade. In addition, the channel should be deepened and the grade realigned 

if there is overtopping caused by sediment in the channel where the grade decreases or reverses. 

If overtopping occurs at low points in the ridge where the diversion crosses the shallow draw, the 

ridge should be reconstructed with a positive grade toward the outlet at all points. Finally, if 

erosion occurs at the outlet, an outlet stabilization structure should be installed; if sedimentation 

occurs at the diversion outlet, a temporary sediment trap should be installed. 

Maintenance 

An earth dike should be inspected for signs of erosion after every major rain event. Any repairs 

or revegetation should be completed promptly (NAHB, No Date). The following actions can be 

taken to properly maintain an earth dike: 

 Remove debris and sediment from the channel immediately after the storm event. 

 Repair the dike to its original height. 
Section 7: Technology Assessment 

7-28 

 Check outlets and make necessary repairs to prevent gully formation. 

 Clean out sediment traps when they are 50 percent full. 

 Once the work area has been stabilized, remove the diversion ridge, fill and compact 

the channel to blend with the surrounding area, and remove sediment traps, disposing 

of unstable sediment in a designated area. 

Cost 

The cost of an earth dike depends on the design and materials used. Small dikes can cost 

approximately $2.00 per linear foot, while larger dikes can cost approximately $2.00 per cubic 

yard. Earth dikes can cost approximately $4.50 per linear foot (NAHB, No Date). 

An alternative means to estimate conceptual costs for earthen dikes is to use unit cost values and 

a rough estimate of the quantities needed. Shallow trenching (1 to 4 feet deep) with a backhoe in 

areas not requiring dewatering can be performed for $4 to $5 per cubic yard of removed material 

(R.S. Means 2000). On the basis of that value, $2 per linear foot provides for 11 square feet of 

flow area and $4.50 per linear foot provides for 24 square feet of flow area. That suggests that 

the size of the dike is required before specifying a cost, which requires a site-specific hydrologic 

evaluation. On the basis of standards for Virginia, most small drainage areas (made up of 5 acres 

or less) require 18-inch tall diversion dikes with a 4.5-foot base. Assuming the excavation 

volume equals the volume of the dike, the resulting excavation volume is approximately 7 cubic 

feet per linear foot, which (conservatively) equates to $1.03 to $1.30 per linear foot for 

construction costs. 

If the earthen dikes are to be permanent, additional costs are incurred to vegetate the dike. R.S. 

Means (2000) estimates the cost of fine grading, soil treatment, and grassing is approximately $2 

per square yard of earth surface area. That adds approximately $6 per linear foot of dike. Where 

gently sloping areas need to be grassed only with acceptable species, the cost can be as low as 

$0.38 per square yard. 

7.2.2.2. Temporary Swale 

General Description 

The term swale (grassed channel, dry swale, wet swale, biofilter) refers to a series of vegetated, 

open-channel management practices designed specifically to treat and attenuate stormwater 

runoff for a specified water quality volume. As stormwater runoff flows through such channels, 

it is treated by filtering through the vegetation in the channel, filtering through a subsoil matrix, 

or infiltrating into the underlying soils. Variations of the grassed swale include the grassed 

channel, dry swale, and wet swale. The specific design features and methods of treatment differ 

in each of these designs, but all are improvements on the traditional drainage ditch and 

incorporate modified geometry and other features for use of the swale as a treatment and 

conveyance practice. 

Applicability 

Grassed swales can be applied in most situations with some restrictions and are very well suited 

for treating highway or residential road runoff because they are linear practices. Perimeter 
Section 7: Technology Assessment 

7-29 

dikes/swales should be limited to a drainage area of no more than 1.97 acres (0.8 hectare) and 

usually work best on gently sloping terrain. Perimeter dikes might not work well on moderate 

slopes, and they should never be established on slopes exceeding 20 percent (UNEP 1994). 

Regional Applicability. Grassed swales can be applied in most regions of the country. In arid 

and semi-arid climates, however, the value of these practices needs to be weighed against the 

water needed to irrigate them. 

Ultra-Urban Areas. Ultra-urban areas are densely developed urban areas in which little 

pervious surface exists. Grassed swales are generally not well suited to ultra-urban areas because 

they require a relatively large area of pervious surface. 

Stormwater Hot Spots. Stormwater hot spots are areas where land use or activities generate 

highly contaminated runoff, with concentrations of pollutants in excess of those commonly 

found in stormwater. A typical example is a gas station or convenience store. With the exception 

of the dry swale design, hot spot runoff should not be directed toward grassed channels. Such 

practices either infiltrate stormwater or intersect the ground water, making use of the practices 

for hot spot runoff a threat to ground water quality. 

Stormwater Retrofit. A stormwater retrofit is a stormwater management practice (usually 

structural), put into place after development has occurred, to improve water quality, protect 

downstream channels, reduce flooding, or meet other specific objectives. One retrofit 

opportunity using grassed swales modifies existing drainage ditches. Ditches have traditionally 

been designed to convey stormwater away from roads as quickly as possible. In some cases, it 

might be possible to incorporate features to enhance pollutant removal or infiltration such as 

check dams (for example, small dams along the ditch that trap sediment, slow runoff, and reduce 

the longitudinal slope). Because grassed swales cannot treat a large area, using this practice to 

retrofit an entire watershed would be expensive because of the number of practices needed to 

manage runoff from a significant amount of the watershed’s land area. 

Cold Water (Trout) Streams. Grassed channels are a good treatment option in watersheds that 

drain to cold water streams. Such practices do not retain water for a long period of time and often 

induce infiltration. As a result, standing water will not typically be subjected to warming by the 

sun. 

Design and Installation Criteria 

Temporary swales should be designed using standard hydrologic and hydraulic calculations. 

Designs should be certified by a professional hydrologist, engineer, or other appropriate 

professional. 

Perimeter dikes/swales should be established before any major soil-disturbing activity takes 

place. Dikes should be compacted with construction equipment to the design height plus 10 

percent to allow for settlement. If they are to remain in place for longer than 10 days, they should 

be stabilized using vegetation, filter fabric, or other material. Diverted water should be directed 

to a sediment trap or other sediment treatment area (UNEP 1994). 
Section 7: Technology Assessment 

7-30 

In addition to the broad applicability concerns described above, designers need to consider 

conditions at the site level. In addition, they need to incorporate design features to improve the 

longevity and performance of the practice while minimizing the maintenance burden. 

Siting Considerations 

In addition to considering the restrictions and adaptations of grassed swales to different regions 

and land uses, designers must ensure that this management practice is feasible at the site in 

question. Depending on the design option, grassed channels can be highly restricted practices 

because of site characteristics. 

Drainage Area. Grassed swales generally should treat small drainage areas of less than 5 acres. 

If the practices are used to treat larger areas, the flows and volumes through the swale become 

too large to achieve stormwater treatment through infiltration and filtration. 

Slope. Grassed swales should be used on sites with relatively flat slopes (less than 4 percent). 

Runoff velocities in the channel become too high on steeper slopes. That can cause erosion and 

does not allow for infiltration or filtration in the swale. 

Soils /Topography. Grassed swales can be used on most soils, with some restrictions on the 

most impermeable soils. In the dry swale, a fabricated soil bed replaces on-site soils to ensure 

that runoff is filtered as it travels through the soils of the swale. 

Ground Water. The depth to ground water depends on the type of swale used. In the dry swale 

and grassed channel options, designers should separate the bottom of the swale from the ground 

water by at least 2 feet to prevent a moist swale bottom or contamination of ground water. In the 

wet swale option, treatment is enhanced by a wet pool, which is maintained by intersecting the 

water table. 

Design Considerations 

Although the grass swale has different design variations, including the grassed channel, dry 

swale, and wet swale, some design considerations are common to all three. One similarity is their 

cross-sectional geometry. Swales should generally have a trapezoidal or parabolic cross-section 

with relatively flat side slopes (flatter than 3:1). Designing the channel with flat side slopes 

maximizes the wetted perimeter, which is the length along the edge of the swale’s cross-section 

where runoff flowing through the swale is in contact with the vegetated sides and bottom of the 

swale. Increasing the wetted perimeter slows runoff velocities and provides more contact with 

vegetation to encourage filtering and infiltration. Another advantage to flat side slopes is that 

runoff entering the grassed swale from the side receives some pretreatment along the side slope. 

The flat bottom of all three should be between 2 and 8 feet wide. The minimum width ensures an 

adequate filtering surface for water quality treatment, and the maximum width prevents braiding 

(the formation of small channels in the swale bottom). 

Another similarity among all three designs is the type of pretreatment needed. A small forebay 

should be used at the inflow area of the swale to trap incoming sediments. A pea gravel 

diaphragm (a small trench filled with river run gravel) should be used to pretreat runoff entering 

along the sides of the swale. 
Section 7: Technology Assessment 

7-31 

Two other features designed to enhance the treatment ability of grassed swales are a flat 

longitudinal slope (generally between 1 and 2 percent) and a dense vegetative cover in the 

channel. The flat slope helps to reduce the velocity of flow in the channel. Dense vegetation also 

helps reduce velocities, protect the channel from erosion, and act as a filter to treat stormwater 

runoff. During construction, it is important to stabilize the channel before the turf has been 

established, either with a temporary grass cover or with the use of natural or synthetic erosion 

control products. 

In addition to treating runoff for water quality, grassed swales need to convey larger storms 

safely. Typical designs allow the runoff from the 2-year storm to flow through the swale without 

causing erosion. Swales should also have the capacity to pass larger storms (typically a 10-year 

storm) safely. 

The length of the swale necessary to infiltrate runoff can be calculated by using a mass balance 

of runoff and infiltration for a triangular-shaped, cross-sectional area. 

Design Variations 

The following discussion identifies three different variations of open channel practices, including 

the grassed channel, the dry swale, and the wet swale. 

Grassed Channel. (Discussed in more length in subsection 7.2.1.2, under Grass-lined Channels) 

Of the three grassed swale designs, grassed channels are the most similar to a conventional 

drainage ditch, with the major differences being flatter side slopes and longitudinal slopes and a 

slower design velocity for water quality treatment of small storm events. Of all the grassed swale 

options, grassed channels are the least expensive, but they also provide the least reliable pollutant 

removal performance. The best application of a grassed channel is as pretreatment to other 

stormwater treatment practices. 

One major difference between the grassed channel and most of the other structural practices is the 

method used to size the practice. Most water quality practices for stormwater management are 

sized by volume. This method sets the volume available in the practice equal to the water quality 

volume, or the volume of water to be treated in the practice. The grassed channel, on the other 

hand, is a flow rate-based design. On the basis of the peak flow from the water quality storm (this 

varies from region to region, but a typical value is the 1-inch storm), the channel should be 

designed so that runoff takes, on average, 10 minutes to flow from the top to the bottom of the 

channel. A procedure for this design is in Design of Storm Water Filtering Systems (CWP 1996). 

Dry Swales. Dry swales are similar in design to bioretention areas. Such practices incorporate a 

fabricated soil bed into their design. The existing soil is replaced with a sand/soil mix that meets 

minimum permeability requirements. An underdrain system is used under the soil bed. The 

system is a gravel layer that encases a perforated pipe. Stormwater treated in the soil bed flows 

through the bottom into the underdrain, which conveys the treated stormwater to the storm drain 

system. Dry swales are a relatively new design, but studies of swales with a native soil similar to 

the man-made soil bed of dry swales suggest high pollutant removal rates. 

Wet Swales. Wet swales intersect the ground water and behave similarly to a linear wetland cell. 

Such a design variation incorporates a shallow, permanent pool and wetland vegetation to 
Section 7: Technology Assessment 

7-32 

provide stormwater treatment. The design also has potentially high pollutant removal. One 

disadvantage of the wet swale is that its use in residential or commercial settings is unpopular 

because property owners sometimes view the shallow, standing water in the swale as a nuisance. 

Regional Variations 

Cold Climates. In cold or snowy climates, swales can serve a dual purpose by acting as both a 

snow storage/treatment practice and a stormwater management practice. This dual purpose is 

particularly relevant when swales are used to treat road runoff. If used for this purpose, swales 

should incorporate salt-tolerant vegetation, such as creeping bentgrass. 

Arid Climates. In arid or semi-arid climates, swales should be designed with drought-tolerant 

vegetation, such as buffalo grass. As pointed out in the Applicability discussion, the value of 

vegetated practices for water quality needs to be weighed against the cost of water needed to 

maintain them in arid and semi-arid regions. 

Effectiveness 

Swales act to control peak discharges in two ways. First, the grass reduces runoff velocity, 

depending on the length and slope of the swale. Second, a portion of the stormwater runoff 

volume passes through the swale and infiltrates into the soil. Table 7-7 summarizes grassed 

swale pollutant removal efficiencies. 

Table 7-7. Grassed swale pollutant-removal efficiency data 

Grassed swale removal efficiencies 

Study TSS TP TN NO3 Metals Bacteria Type 

Goldberg 1993 67.8 4.5 -- 31.4 42–62 -100 Grassed channel 

Seattle Metro and 

Washington Department of 

Ecology 1992 

60 45 -- -25 2–16 -25 Grassed channel 

Seattle Metro and 

Washington Department of 

Ecology 1992 

83 29 

-- 

-25 46–73 -25 Grassed channel 

Wang et al. 1981 80 -- -- -- 70–80 -- Dry swale 

Dorman et al. 1989 98 18 -- 45 37–81 -- Dry swale 

Harper 1988 87 83 84 80 88–90 -- Dry swale 

Kercher, Landon, and 

Massarelli 1983 

99 99 99 99 99 -- Dry swale 

Harper 1988 81 17 40 52 37–69 -- Wet swale 

Koon 1995 67 39 -- 9 -35 to 6 -- Wet swale 

Yousef et al. 1985 -- 8 13 11 14–29 -- Drainage channel 

Yousef et al. 1985 -- -19.5 8 2 41–90 -- Drainage channel 

Welborn and Veenhuis 1987 0 -25 -25 -25 0 -- Drainage channel 

Yu, Barnes, and Gerde 1993 68 60 -- -- 74 -- Drainage channel 

Dorman et al. 1989 65 41 -- 11 14–55 -- Drainage channel 

Pitt and McLean 1986 0 -- 0 -- 0 0 Drainage channel 

Oakland 1983 33 -25 -- -- 20–58 0 Drainage channel 

Dorman et al. 1989 -85 12 -- -100 14–88 -- Drainage channel 
Section 7: Technology Assessment 

7-33 

Limitations 

Common problems associated with swales include excessive erosion along unlined channels 

(usually because of excessive grade), erosion or sedimentation at the outlet point, or overtopping 

of the swale at low points (UNEP 1994). 

Additional limitations of the grass swale include the following: 

 Grassed swales cannot treat a very large drainage area. 

 Swales do not appear to be effective at reducing bacteria. 

 Wet swales can become a nuisance because of mosquito breeding. 

 If designed improperly (for example, improper slope), grassed channels will have 

very little pollutant removal. 

 A thick vegetative cover is needed for the practices to function properly. 

Maintenance 

As with any BMP, swales must be maintained to continue to effectively remove pollutants. 

Maintenance can include occasional mowing, fertilizing, and liming. In addition, any areas that 

become damaged by erosion should be immediately repaired and replanted. The swales should 

be protected from concentrated flows and be checked periodically for downstream obstructions. 

Cost 

To produce a conceptual cost approximation, grassed channel construction costs can be 

developed using unit cost values. Shallow trenching (1 to 4 feet deep) with a backhoe in areas 

not requiring dewatering can be performed for $4 to $5 per cubic yard of removed material (R.S. 

Means 2000). Assuming no disposal costs (i.e., excavated material is placed on either side of the 

trench), only the cost of fine grading, soil treatment, and grassing (approximately $2 per square 

yard) should be added to the trenching cost to approximate the total construction cost. Sitespecific hydrologic analysis of the construction site is necessary to estimate the channel 

conveyance requirement and the desired retention time in the swale. It is not unusual to have 

flows on the order of 2 to 4 cfs per acre served. 

For a design channel velocity of 1 foot per second, the resulting range in the channel crosssection area can be as low as 2 but as high as 4 square feet per acre drained. If the average 

channel flow depth is 1 foot, the low estimate for grassed channel installation is $0.74 per square 

foot of channel bottom per acre served per foot of channel length. The high estimate is $1.48 per 

square foot of channel bottom per acre served per foot of channel length. 

Table 7-8 summarizes additional costs of grass swales. 
Section 7: Technology Assessment 

7-34 

Table 7-8. Average annual operation and maintenance costs for a grass swale 

Component 

Estimated 

unit cost ($) 

$ for swale size: 

0.5m deep 0.3m 

bottom width 3m 

top width 

$ for swale size: 

1m deep 1m 

bottom width 7m 

top width Comments 

Mowing 0.89/100 m2 145.0 241.0 Mow 2-3 times per year 

General grass care 8.8/100 m2 162.98 274.0 Grass maintenance area is 

(top width + 3 m) x length 

Debris/litter removal 0.51/m2 93.0 93.0 

Reseeding/ 

fertilization 

0.35/m2 5.9 10.37 Area revegetated is 1% of 

maintenance area per year 

Inspection and 

general 

administration 

0.74/m2 231.0 231.0 Inspection once per year 

TOTAL 638.0 850.0 

Source: Ellis 1998. 

7.2.2.3. Temporary Storm Drain Diversion 

General Description 

A temporary storm drain diversion is a pipe that reroutes an existing drainage system to 

discharge flow into a sediment trap or basin. Such a practice reduces the amount of sedimentladen runoff from construction sites that enters waterbodies without treatment. Temporary storm 

drain diversions can be used when a permanent stormwater drainage system has not yet been 

installed. It should be recognized that diversion channels can also be installed but are not 

considered in the following discussion. 

Applicability 

A temporary storm drain diversion should be used to temporarily redirect discharge to a 

permanent outfall and should remain in place until the area draining to the storm sewer is no 

longer disturbed. Temporary storm drain diversions can also be combined with other structures 

and used as a sediment-trapping device when the completion of a permanent outfall has been 

delayed; alternatively, a sediment trap can be placed below a permanent outfall to remove 

sediment before the final flow discharge. 

Design and Installation Criteria 

Because the diversion is only temporary, the layout of piping and the overall impact of the 

diversion’s installation on post-construction drainage patterns must be considered. Once 

construction is completed, the temporary diversion should be moved to restore the original 

system. The following activities should be done at that time: 

 The storm drain should be flushed before the sediment trap is removed. 

 The outfall should be stabilized. 

 Graded areas should be restored. 
Section 7: Technology Assessment 

7-35 

 State or local requirements should be checked for more detailed requirements and an 

appropriate professional should certify that the design meets local hydrologic and 

hydraulic requirements. 

Effectiveness 

If installed properly to capture the bulk of runoff from a construction site, temporary storm drain 

diversions can be effective in reducing the discharge of sediment-laden, untreated water to 

waterbodies. When used in combination with other ESC practices such as minimized clearing or 

vegetative and chemical stabilization, the level of pollution from a construction site can be 

substantially reduced or eliminated. 

Limitations 

Installing temporary storm drain diversion can result in the disturbance of existing storm 

drainage patterns. Care must be taken to ensure that the original system is properly restored once 

the temporary system is removed. The most common source of problems is excessive velocity at 

the outlet. Installing an outlet stabilization structure is typically required and can be constructed 

of riprap, reinforced concrete, geotextile linings, or a combination. 

Maintenance 

Once installed, temporary storm drain diversions require very little maintenance. Frequent 

inspection and maintenance of temporary storm drain systems, especially after large storms, 

should ensure that pipe clogging does not occur and that runoff from the site is being 

successfully diverted. After removing the temporary diversion, the permanent storm drain system 

should be carefully inspected to ensure that drainage patterns have not been altered by the 

temporary system. 

Cost 

Depending on the size of the construction site, a temporary storm drain diversion can be costly. 

Costs include those associated with materials needed to construct the diversion and sediment trap 

or basin (mainly piping, concrete, and gravel), and labor costs for installation and removal of the 

system, all of which could involve excavation, re-grading, and inspections. Because of the 

variety of conditions that can affect storm drain diversion designs, typical costs per installation 

are not presented here. However, site-specific cost estimates can be produced using unit cost 

values along with site-specific quantity estimates. R.S. Means (2000) indicates a range of pipe 

costs for surface placement, between $5.00 per linear foot for 4-inch diameter PVC piping, and 

$9.20 per linear foot for 10-inch diameter PVC piping. On construction sites, temporary inlets 

and outlets are usually formed by small rock-lined depressions. Assuming 4 cubic yards of 

crushed rock (1.5-inch mean diameter) per opening, an inlet and outlet combine to add 

approximately $200 per pipe installation, based on $25 per cubic yard of stone (R.S. Means 

2000). 

7.2.2.4. Pipe Slope Drain 

General Description 

Pipe slope drains are used to reduce the risk of erosion on slopes by discharging runoff to 

stabilized areas. Consisting of a metal or plastic flexible pipe if temporary, or pipes or paved 
Section 7: Technology Assessment 

7-36 

chutes if permanent, the drains carry surface runoff from the top to the bottom of a slope that has 

already been damaged by erosion or is at high risk for erosion. The drains are also used to drain 

saturated slopes that have the potential for soil slides. 

Applicability 

Temporary slope drains can be used on most disturbed slopes to eliminate gully erosion 

problems resulting from concentrated flows discharged at a diversion outlet. Slope drains should 

be used as a temporary measure for as long as the drainage area remains disturbed. They will 

need to be moved once construction is complete and a permanent storm drainage system is 

established. Appropriate restoration measures will then need to be taken, such as adjusting 

grades and flushing sediment from the pipe before it is removed (UNEP 1994). 

Design and Installation Criteria 

Pipe slope drains can be placed directly on the ground or buried under the surface. The inlet 

should be at the top of the slope and should be fitted with an apron, attached with a watertight 

connection. Filter cloth should be placed under the inlet to prevent erosion. Flexible pipes, which 

are positioned on top of the ground, should be securely anchored with grommets placed 10 feet 

on center. The outlet at the bottom of the slope should also be stabilized with riprap. The riprap 

should be placed along the bottom of a swale that leads to a sediment-trapping structure or 

another stabilized structure. 

Slope drain pipe sizes are based on drainage area and the size of the design storm. Pipes should 

be connected to a diversion ridge at the top of the slope by covering it with compacted fill 

material where it passes through the ridge. Discharge from a slope drain should be to a sediment 

trap, sediment basin, or other stabilized outlet (UNEP 1994). 

Pipe slope drains should be installed perpendicular to the contour down the slope, and the design 

should be able to handle the peak runoff for the 10-year storm. Recommendations of slope drain 

diameter are summarized in Table 7-9 (NAHB, No Date). 

Table 7-9. Recommended pipe/tubing sizes for slope drains 

Maximum drainage area 

(acres) 

Pipe/tubing diametera

(inches) 

Pipe/tubing diameterb

(inches) 

Pipe/tubing diameterc

(inches) 

0–0.5 

0.5 12 12 8 

0.75 10 

1.0 12 

1.5 18 18 Individually designed 

2.5 21 

3.5 24 24 

5.0 30 

a UNEP 1994. 

b USDOT 1995. 

c IDNR 1992. 

Recently graded slopes that do not have permanent drainage measures installed should have a 

temporary slope drain and a temporary diversion installed. A temporary slope drain used in 
Section 7: Technology Assessment 

7-37 

conjunction with a diversion conveys stormwater flows and reduces erosion until permanent 

drainage structures are installed. 

The following are design recommendations for temporary slope drains: 

 The drain should consist of heavy-duty material manufactured for the purpose and 

have grommets for anchoring at a spacing of 10 feet or less. 

 Minimum slope drain diameters should be observed for varying drainage areas. 

 The entrance to the pipe should consist of a standard flare end section of corrugated 

metal. The corrugated metal pipe should have watertight joints at the ends. The rest of 

the pipe is typically corrugated plastic or flexible tubing, although for flatter, shorter 

slopes, a polyethylene-lined channel is sometimes used. 

 The height of the diversion at the pipe should be the diameter of the pipe plus 0.5 

foot. 

 The outlet should be placed at a reinforced or erosion-resistant location. 

Temporary slope drains should be designed to adequately convey runoff for a desired frequency 

storm, typically either 2 years or 10 years depending on local regulations. Both the size and the 

spacing can be determined on the basis of the contributing drainage area. Drains are spaced at 

intervals corresponding to the specified drainage areas. For larger drainage areas and critical 

locations, the drains should be sized on an individual basis (USDOT 1995). 

Slope drains should be constructed in conjunction with diversion berms such that the berms are 

not overtopped. At the pipe inlet, the top of the berm should be a minimum of 300 mm (11.81 

inches) higher than the top of the pipe. The entrance should be constructed of a standard flared 

end section or a Tee section if designed properly. The entrance should be placed in a sump that is 

depressed 150 mm (5.90 inches) (USDOT 1995). 

The outlet of the slope drain must be protected with a riprap apron. If the slope drain is draining 

a disturbed area and sufficient right-of-way is available, the drain could empty into a sediment 

trap (USDOT 1995). Table 7-10 summarizes slope drain characteristics. 

Table 7-10. Slope drain characteristics 

Capacity 2-year frequency, 24-hour-duration storm event 

Material Strong, flexible pipe, such as heavy duty, nonperforated, corrugated plastic 

Inlet section Standard T or L flared-end section with metal toe plate 

Connection to ridge at top of 

slope 

Compacted fill over pipe with minimum dimensions, 1.5-foot depth, 4-foot top 

width, and 6 inches higher than ridge 

Outlet Pipe extends beyond toe of slope and discharges into a sediment trap or 

basin unless contributing drainage area is stable 

Source: IDNR 1992. 

Effectiveness 

There is no information on the effectiveness of pipe slope drains. 
Section 7: Technology Assessment 

7-38 

Limitations 

The area drained by a temporary slope drain should not exceed 5 acres. Physical obstructions 

substantially reduce the effectiveness of the drain. Overtopping of the inlet is a common slope 

drain problem because of an undersized or blocked pipe or erosion at the outlet point from 

insufficient protection (UNEP 1994). Other common failures caused by overtopping are from 

inadequate pipe inlet capacity and reduced diversion channel capacity and ridge height, as well 

as the following: 

 Overtopping because the drainage area might be too large. 

 Overtopping caused by improper grade of channel and ridge—A positive grade 

should be maintained. 

 Overtopping caused by poor entrance conditions and trash buildup at the pipe inlet—

Deepen and widen the channel at the pipe entrance and frequently inspect and clear 

the inlet. 

 Washout—A washout along a pipe from seepage and piping can be caused by 

inadequate compaction, insufficient fill, or installation that might be too close to the 

edge of the slope. 

 Erosion at outlet—The pipe should be extended to a stable grade or an outlet 

stabilization structure is needed. 

 Displacement or separation of pipe—The pipe should be tied down and the joints 

secured. 

Maintenance 

Pipe slope drains must be inspected after each significant runoff event for evidence of erosion 

and uncontrolled runoff. Any repairs to the drain should be made immediately. Significant 

amounts of sediment trapped at the outfall should also be removed in a timely manner and 

disposed of properly (NAHB, No Date). 

The following actions should be taken to properly maintain a pipe slope drain (IDNR 1992): 

 Inspect slope drains and supporting diversions once a week and after every storm 

event. 

 Check the inlet for sediment or trash accumulation; clear and restore to proper 

entrance condition. 

 Check the fill over the pipe for settlement, cracking, or piping holes; repair 

immediately. 

 Check for holes where the pipe emerges from the dike; repair immediately. 

 Check the conduit for evidence of leaks or inadequate anchoring; repair immediately. 

 Check the outlet for erosion or sedimentation; clean and repair, or extend if 

necessary. 

 Once slopes have been stabilized, remove the temporary diversions and slope drains, 

and stabilize all disturbed areas. 
Section 7: Technology Assessment 

7-39 

Cost 

The cost of pipe slope drains and their installation varies with the design and materials used. 

Site-specific cost estimates can be produced using unit cost values with site-specific quantity 

estimates. 

R.S. Means (2000) indicates a range of pipe costs for surface placement between $5.00 per linear 

foot for 4-inch diameter PVC piping, and $9.20 per linear foot for 10-inch diameter PVC piping. 

On construction sites, temporary inlets and outlets are usually formed by small, rock-lined 

depressions. Assuming 4 cubic yards of crushed rock (1.5-inch mean diameter) per opening, an 

inlet and outlet together add approximately $200 per pipe installation, based on $25 per cubic 

yard of stone (R.S. Means 2000). 

7.2.2.5. Check Dam 

General Description 

A check dam is a small, temporary barrier constructed across a drainage channel or swale to 

reduce the velocity of the flow. By reducing the flow velocity, the erosion potential is reduced, 

detention times are lengthened, and more sediment is able to settle out of the water column. 

Check dams can be constructed of stone, gabions, treated lumber, or logs (NAHB, No Date). 

Recent work by Dr. Richard McLaughlin involves the use of fiber check dams installed at grade 

with polyacrylamide (PAM) applied to the check dam (McLaughlin 2009) and PAM blocks on 

the downhill side of triangular silt dikes (McLaughlin, No Date b)for passive dosing to greatly 

reduce turbidity. 

Check dams are inexpensive and easy to install. They can be used permanently to settle 

sediment, reduce the velocity of runoff, and provide aeration. Check dams are often used in 

combination with other practices, such as sediment traps or basins. 

Applicability 

Check dams are commonly used (1) in channels that are degrading but where permanent 

stabilization is impractical because of their short period of usefulness and (2) in eroding channels 

where construction delays or weather conditions prevent timely installation of erosion-resistant 

linings (IDNR 1992). 

Check dams are also useful in steeply sloped swales, in small channels, in swales where adequate 

vegetative protection cannot be established, or in swales or channels that will be used for a short 

time and it is not practical to line the channel or implement other flow control practices (USEPA 

1993). In addition, check dams are appropriate where temporary seeding has been recently 

implemented but has not had time to fully develop and take root. The contributing drainage area 

should range from 2 to 10 acres. Check dams should be used only in small, open channels that 

will not be overtopped by flow once the dams are built. They should not be built in stream 

channels, either intermittent or perennial (UNEP 1994). Check dams can be effective sediment 

trapping devices when designed appropriately. 
Section 7: Technology Assessment 

7-40 

Design and Installation Criteria 

Check dams can be constructed from a number of different materials. Most commonly, they are 

made of rock, logs, sandbags, or straw bales. Rock or stone is often preferred because of its costeffectiveness and longevity. Logs and straw bales will decay with time and are not recommended 

because they can cause waterway blockage if they fail. When using rock or stone, the material 

diameter should be 2 to 15 inches. The stones should be extended 18 inches beyond the banks, 

and the side slopes should be 2:1 or flatter. Lining the upstream side of the dam with a foot of 1- 

to 2-inch gravel can improve the efficiency of the dam (NAHB, No Date). Logs should have a 

diameter of 6 to 8 inches. Regardless of the material used, careful construction of a check dam is 

necessary to ensure its effectiveness. 

The distance between rock check dams will vary depending on the slope of the ditch, with closer 

spacing when the slope is steeper. The size of stone used in the check dam should also vary with 

the expected design velocity and discharge. As velocity and discharge increase, the rock size 

should also increase. For most rock check dams, 3 inches to 12 inches is a suitable stone size. To 

improve the sediment-trapping efficiency of check dams, a filter stone can be applied to the 

upstream face. A well-graded, coarse aggregate that is less than 1 inch in size can be used as a 

filter stone. 

All check dams should have a maximum height of 3 feet. The center of the dam should be at 

least 6 inches lower than the edges. Such a design creates a weir effect that helps to channel 

flows away from the banks and prevent further erosion. Additional stability can be achieved by 

implanting the dam material approximately 6 inches into the sides and bottom of the channel 

(VDCR 1995). 

When installing more than one check dam in a channel, outlet stabilization measures should be 

installed below the final dam in the series. Because that area is likely to be vulnerable to further 

erosion, riprap or some other stabilization measure is highly recommended. 

Effectiveness 

Field experience has shown that rock check dams are more effective than silt fences or straw 

bales to stabilize wet-weather ditches (VDCR 1995). Straw bales have been shown to have very 

low trapping efficiencies and should not be used for check dams. For long channels, check dams 

are most effective when used in a series, creating multiple barriers to sediment-laden runoff. 

Dr. Richard McLaughlin reports dramatic turbidity reductions using fiber check dams with PAM, 

to levels below 200 nephelometric turbidity units (NTUs) and in some cases to below 50 NTUs. 

McLaughlin also reports reductions when PAM is added to conventional rock check dams 

(McLaughlin, No Date a). McLaughlin (2009) states that fiber check dams are much more 

effective than rock check dams, according to data presented in the study. For summaries of 

studies with monitoring data, and annotated bibliographies for the journal articles and 

professional conference proceedings that EPA reviewed, see DCN 43114. 

Limitations 

Check dams should not be used in perennial streams unless approved by an appropriate 

regulatory agency (USEPA 1992; VDCR 1995). Because the primary function of check dams is 

to slow runoff in a channel, they should not be used as a standalone substitute for other sediment-
Section 7: Technology Assessment 

7-41 

trapping devices. Also, leaves have been shown to be a significant problem because they clog 

check dams; therefore, increased inspection and maintenance might be necessary in the fall. 

Common problems with check dams include channel bypass and severe erosion when 

overtopped and ineffectiveness from accumulated sediment and debris. When designing check 

dams, because they reduce the capacity of a channel to transmit stormwater runoff and, thus, 

need to be sized appropriately should be taken into account (UNEP 1994). The check dam could 

also kill grass linings in the channel if the water level remains high after it rains or if there is 

significant sedimentation. In addition, a check dam might reduce the hydraulic capacity of the 

channel and create turbulence, which erodes the channel banks (NAHB, No Date). 

Maintenance 

Check dams should be inspected periodically to ensure that they have not been repositioned as a 

result of stormwater flow. In addition, the center of a check dam should always be lower than its 

edges. Additional stone might have to be added to maintain the correct height. Sediment should 

not be allowed to accumulate to more than half the original dam height. Any required 

maintenance should be performed immediately. When check dams are removed, take care to 

remove all dam materials to ensure proper flow within the channel. The channel should 

subsequently be seeded for stabilization (NAHB, No Date). 

Cost 

The cost of check dams varies according to the material used for construction and the width of 

the channel to be dammed. In general, it is estimated that check dams constructed of rock cost 

about $100 per dam (USEPA 1992). Brown and Schueler (1997) estimate that a rock check dam 

would cost approximately $62 per installation, including the cost for filter fabric bedding. Other 

materials, such as logs and sandbags, might be a less expensive alternative, but they could 

require higher maintenance costs. McLaughlin estimates that fiber check dams are comparable in 

cost to stone check dams, however installation costs can be much lower because fiber check 

dams can be positioned and staked in place by hand (stone check dams usually require a backhoe 

or other equipment to install) (McLaughlin, personal communication). Fiber check dams will 

likely require periodic replacement for longer-duration projects. Costs for PAM addition to 

check dams is minimal, with a new application required every few storm events. Application is 

done by hand, and a predetermined quantity of dry PAM is simply applied to the surface of the 

check dam. McLaughlin (2009) reports costs for installation and maintenance for standard BMPs 

(stone check dams with preceding excavations) and fiber check dams with and without PAM at 

two linear road projects in North Carolina. The installation cost per linear meter was $6.50 (site 

1) and $5.74 (site 2) for standard BMPs, $5.59 (site 1) for fiber check dams only, and $4.33 (site 

1) and $5.35 (site 2) for fiber check dams with PAM. The cost per maintenance action was $416 

at each site for the standard BMPs and $74 to $79 for fiber check dams with PAM. 

7.2.2.6. Lined Waterways 

General Description 

Lined channels convey stormwater runoff through a stable conduit. Vegetation lining the channel 

reduces the flow velocity of concentrated runoff. Lined channels usually are not designed to 

control peak runoff loads by themselves and are often used in combination with other BMPs 

such as subsurface drains and riprap stabilization. Where moderately steep slopes require 
Section 7: Technology Assessment 

7-42 

drainage, lined channels can include excavated depressions or check dams to enhance runoff 

storage, decrease flow rates, and enhance pollutant removal. Peak discharges can be reduced 

through temporary detention in the channel. Pollutants can be removed from stormwater by 

filtration through vegetation, by deposition, or in some cases by infiltration of soluble nutrients 

into the soil. The degree of pollutant removal in a channel depends on the residence time of the 

water in the channel and the amount of contact with vegetation and the soil surface, but pollutant 

removal is not generally the major design criterion. 

Often construction increases the velocity and volume of runoff, which causes erosion in newly 

constructed or existing urban runoff conveyance channels. If the runoff during or after 

construction would cause erosion in a channel, the channel should be lined or flow control 

practices instituted. The first choice of lining should be grass or sod because that reduces runoff 

velocity and provides water quality benefits through filtration and infiltration. If the velocity in 

the channel would erode the grass or sod, one can use riprap, concrete, or gabions (USEPA 

2000). Geotextile materials can be used in conjunction with either grass or riprap linings to 

provide additional protection at the soil-lining interface. 

Applicability 

Lined channels typically are used in residential developments, along highway medians, or as an 

alternative to curb and gutter systems. Grass-lined channels should be used to convey runoff only 

where slopes are 5 percent or less. Such channels require periodic mowing, occasional spotseeding, and weed control to ensure adequate grass cover (UNEP 1994). 

Lined channels should be used in areas where erosion-resistant conveyances are needed, such as 

in areas with highly erodible soils and slopes of less than 5 percent. They should be installed 

only where space is available for a relatively large cross-section. Grassed channels have a limited 

ability to control runoff from large storms and should be used with the recommended allowable 

velocities for the specific soil types and vegetative cover. 

Design and Installation Criteria 

The design of a lined waterway requires proper determination of the channel dimensions. It must 

ensure that (1) the velocity of the flowing water will not wash out the waterway and that (2) the 

capacity of the waterway is sufficient to carry the surface flow from the watershed without 

overtopping. 

Vegetation-Lined Channels. Grass-lined channels have been previously discussed in detail and 

are only summarized in this section. The allowable velocity of water in the waterway depends on 

the type, condition, and density of the vegetation, as well as the erosive characteristics of the soil. 

Uniformity of vegetative cover is important because the stability of the most sparsely covered 

area determines the stability of the channel. Grasses are a better vegetative cover than legumes 

because grasses resist water velocity more effectively. 

Vegetative-lined channels can have triangular, parabolic, or trapezoidal cross-sections. Side 

slopes should not exceed 3:1 to facilitate the establishment, maintenance, and mowing of 

vegetation. A dense cover of hardy, erosion-resistant grass should be established as soon as 

possible following grading. This could require using straw mulch and installing protective 

netting until the grass becomes established. If the intent is to create opportunities for runoff to 
Section 7: Technology Assessment 

7-43 

infiltrate into the soil, the channel gradient should be kept near zero, the channel bottom must be 

well above the seasonal water table, and the underlying soils should be relatively permeable 

(generally, with an infiltration rate greater than 2 centimeters [0.78 inches] per hour). 

Rock-Lined Channels. Riprap-lined channels can be installed on somewhat steeper slopes than 

grass-lined channels. They require a foundation of filter fabric or gravel under the riprap. 

Generally, side slopes should not exceed 2:1, and riprap thickness should be 1.5 times the 

maximum stone diameter. Riprap should form a dense, uniform, well-graded mass (UNEP 1994). 

Lined channels should be sited in accordance with the natural drainage system and should not 

cross ridges. The channel design should not have sharp curves or significant changes in slope. 

Channels should not receive direct sedimentation from disturbed areas and should be established 

only on the perimeter of a construction site to convey relatively clean stormwater runoff. They 

should also be separated from disturbed areas by a vegetated buffer or other BMP to reduce 

sediment loads. 

Basic design recommendations for lined channels include the following: 

 Construction and vegetation of the channel should occur before grading and paving 

activities begin. 

 Design velocities should be less than 5 feet per second. 

 Geotextiles can be used to stabilize vegetation until it is fully established. 

 Covering the bare soil with sod or geotextiles can provide reinforced stormwater 

conveyance immediately. 

 Triangular-shaped channels should be used with low velocities and small quantities of 

runoff; parabolic grass channels are used for larger flows and where space is 

available; trapezoidal channels are used with large flows of low velocity (low slope). 

 Outlet stabilization structures might be needed if the runoff volume or velocity has 

the potential to exceed the capacity of the receiving area. 

 Channels should be designed to convey runoff from a 10-year storm without erosion. 

 The sides of the channel should be sloped less than 3:1, with V-shaped channels 

along roads sloped 6:1 or less for safety. 

 All trees, bushes, stumps, and other debris should be removed during construction. 

Effectiveness 

Lined channels can effectively transport stormwater from construction areas if they are designed 

for expected flow volumes and velocities and if they do not receive sediment directly from 

disturbed areas. 

Limitations 

Lined channels, if improperly installed, can alter the natural flow of surface water and have 

adverse effects on downstream waters. Additionally, if the design capacity is exceeded by a large 

storm event, the vegetation might not be sufficient to prevent erosion, and the channel might be 
Section 7: Technology Assessment 

7-44 

destroyed. Clogging with sediment and debris reduces the effectiveness of grass-lined channels 

for stormwater conveyance. 

Common problems in lined channels include channel erosion before vegetation is fully 

established and gullying or head cutting in the channel if the grade is too steep. In addition, trees 

and brush tend to invade lined channels, causing maintenance problems. 

Riprap-lined channels can be designed to safely convey greater runoff volumes on steeper slopes. 

However, they should generally be avoided on slopes exceeding 10 percent because stone 

displacement, erosion of the foundation, or channel overflow and erosion resulting from a 

channel that is too small can occur. Thus, channels established on slopes greater than 10 percent 

will usually require protection with rock gabions, concrete, or other highly stable and protective 

surfaces (UNEP 1994). 

Maintenance 

Maintenance requirements for lined channels are relatively minimal. During the vegetation 

establishment period, the channels should be inspected after every rainfall. Other maintenance 

activities that should be carried out after vegetation is established are mowing, litter removal, and 

spot vegetation repair. The most important objective in the maintenance of lined channels is 

maintaining a dense and vigorous growth of turf. Periodic cleaning of vegetation and soil buildup 

in curb cuts is required so that water flow into the channel is unobstructed. During the growing 

season, channel grass should be cut no shorter than the level of design flow, and the cuttings 

should be removed promptly. 

Cost 

Costs of grassed channels range according to depth, with a 1.5-foot-deep, 10-foot-wide grassed 

channel estimated at $6,395 to $17,075 per trench, while a 3-foot-deep, 21-foot-wide grassed 

channel is estimated at $12,909 to $33,404 per trench (SWRPC 1991). 

EPA also refers readers to the discussion of costs for grass-lined channels, which contains many of 

the design and cost elements required for installing lined waterways. Designers have a range of 

options for lining new channels. Geosynthetic TRMs can be used for immediate erosion protection 

in channels exposed to runoff flows. The Erosion Control Technology Council (a geotextile 

industry support association) suggests that TRMs cost approximately $7.00 per square yard 

(installed) for channel protection (Lancaster et al. 2002). R.S. Means indicates that machine-placed 

riprap costs of approximately $40 per cubic yard. The riprap maximum size is typically between 6 

and 12 inches, depending on the channel design velocity. A cubic yard of riprap will cover 

between 36 and 18 square feet of channel bed for those riprap sizes (assuming depth of riprap is 

1.5 times the maximum size). Such estimates suggest that riprap lining will be between $10 and 

$20 per square foot of channel (costs include materials, labor, and equipment, with overhead and 

profit). 

7.2.3. SEDIMENT-TRAPPING DEVICES 

The devices listed under this group of BMPs trap sediment primarily through impounding water 

and allowing for settling to occur (Haan et al. 1994). Silt fence, super silt fence, straw bale dikes, 

sediment traps, and sediment basins all control flow through a porous flow control system such as 
Section 7: Technology Assessment 

7-45 

filter fabric or straw bales, or they use a dam to impound water with a pipe, open channel, or rock 

fill outlet. The filtering capacity of silt fence (filter fabric) contributes only a small amount of 

trapping, but it serves to make the fence less porous and hence increases ponding. For steady-state 

flows, the trapping that occurs behind the flow-control device can be shown to be directly 

proportional to the surface area and indirectly proportional to flow through the system (Haan et 

al. 1994). The ratio of the surface area to flow is known as the overflow rate, and trapping in 

such systems is predicted by the ratio of overflow rate to particle settling velocity. Although flows 

in nature are inherently non-steady-state and more complex than steady-state systems, studies have 

shown that the best predictor of trapping in such systems is still the ratio of settling velocity to 

overflow rate (Hayes et al. 1984). In the case of non-steady-state, the overflow rate is best defined 

by the ratio of peak discharge to surface area (Hayes et al. 1984; McBurnie et al. 1990). 

The amount of trapping in these structures depends on the size of the structure, flow rates into 

the system, hydraulics of the flow control system, the size distribution of the sediment flowing 

into the structure, and the chemistry of the sediment-water system (Haan et al. 1994). Trapping 

can be enhanced by chemical treatment of flows into the structure, but the effects have not been 

widely defined for varying mineralogy and chemistry of the sediment-water system (Haan et al. 

1994; Tapp and Barfield 1986). Recent studies have been conducted on applying PAM to 

disturbed areas for enhancing settling (Benik et al. 1998; Masters et al. 2000; Roa-Espinosa et al. 

2000), but results have not been definitive. No known studies have evaluated the effects of PAM 

application to disturbed areas on settling in sediment trapping devices. 

Sediment flowing into sediment trapping devices is composed of primary particles and 

aggregated particles. Aggregates are formed when clays, silts, and sands are cemented together 

to form larger particles that have settling velocities far greater than those of any individual 

particles alone, although the degree of aggregation depends on the amount of cementing material 

present (typically clays and organic matter). Because the aggregates have higher settling 

velocities than primary particles, the degree of aggregation that is present has a large effect on 

the trapping that occurs. Procedures are available to measure the combined size distribution of 

aggregate and primary particle size distribution (Barfield et al. 1979; Haan et al. 1994). 

Procedures are also available to predict particle size distributions of aggregates and primary 

particles (Foster et al. 1985). 

In the absence of chemical treatment, the sediment that can be captured in sediment trapping 

devices is typically the larger settleable solids. In many cases, to trap the smaller-sized clay 

particles, structures with surface areas larger than the construction site itself would have to be 

built (Barfield 2000). Chemical treatment can be used to reduce the size captured, but it has not 

been widely adopted because of the cost and complexity of the operation (Tapp et al. 1981). 

Sediment-trapping devices also provide some stormwater detention by virtue of detaining flows 

long enough to allow sediment to settle out and be deposited. However, to operate as a 

stormwater-detention structure, the design should include adequate volume for detention. 

Virtually all the available information on sediment-trapping structures, both theoretical and 

experimental, is on effects on receiving waters and not downstream effects. In a very limited 

analysis, Barfield (2000) combines the SEDIMOT II computer model with the FLUVIAL model 
Section 7: Technology Assessment 

7-46 

to theoretically evaluate the effect of sediment trapping structures on downstream 

geomorphology in a Puerto Rican watershed. 

7.2.3.1. Silt Fence and Compost Filter Berms/Socks 

General Description 

Silt fences are used as temporary sediment barriers consisting of filter fabric anchored across and 

supported by posts. Their purpose is to retain sediment from small, disturbed areas by reducing 

the velocity of sediment-laden runoff and promoting sediment deposition (Smolen et al. 1988). 

Silt fences capture sediment by ponding water and allowing for deposition, not by filtration. Silt 

fence fabric first screens silt and sand from runoff, resulting in clogging of the lower part of the 

fence. The pooling water allows sediments to settle out of the runoff. Silt fences work best in 

conjunction with temporary basins, traps, or diversions. Compost filter berms and socks can also 

be used in lieu of silt fences. A compost filter berm is a dike of compost or a compost product 

that is placed perpendicular to sheet flow runoff to control erosion in disturbed areas and retain 

sediment. A compost filter sock is a mesh or geotextile tube filled with composted material. 

Compost filter berms are commonly used as perimeter controls, and are sometimes used in 

combination with silt fence to provide redundant control of perimeter ditch. 

Applicability 

Silt fences are generally placed at the toe of fills, along the edge of waterways, and along the site 

perimeter. The fences should not be used in drainage areas with concentrated and high flows, in 

large drainage areas, or in ditches and swales where concentrated flow is present. 

The drainage area for the fence should be selected on the basis of design storms and local 

hydrologic conditions so that the silt fence is not expected to overtop. A typical design calls for 

no greater than one-quarter acre of drainage area per 100 feet of fence, but that is highly variable, 

depending on climate. The fence should be stable enough to withstand runoff from a 10-year 

peak storm. Table 7-11 lists the maximum slope length specified by the U.S. Department of 

Transportation (USDOT). The slope lengths should be based on sediment load and flow rates. 

That would mean that the values given below should be adjusted for climatic conditions instead 

of one size fits all to ensure maximum effectiveness. 

Table 7-11. Maximum slope lengths for silt fences 

Slope 

(%) 18-inch (460 mm) fence 30-inch (760 mm) fence 

≤ 2 250 ft (75 m) 500 ft (150 m) 

5 100 ft (30 m) 250 ft (75 m) 

10 50 ft (15 m) 150 ft (45 m) 

20 25 ft (8 m) 70 ft (21 m) 

25 20 m (6 ft) 55 ft (17 m) 

30 15 ft (5 m) 45 ft (14 m) 

35 15 ft (5 m) 40 ft (12 m) 

40 15 ft (5 m) 35 ft (10 m) 

45 10 ft (3 m) 30 ft (9 m) 

50 10 ft (3 m) 25 ft (8 m) 

Source: USDOT 1995. 
Section 7: Technology Assessment 

7-47 

Typical standards and specifications call for the silt fence to be on fairly level ground and follow 

the land contour, although it is recognized that a slight slope can occur along the fence in spite of 

the best installation practices. Runoff can move down the contour until a weak spot occurs in the 

buried toe and undercuts the fence. Alternatively, flow could move to a low spot where it 

accumulates and causes an overtopping. In either case, trapping by the silt fence is essentially 

zero, and flows will then have been concentrated, causing downslope erosion. 

Design and Installation Criteria 

Design criteria are of two types: 

 Hydrologic design for a required trapping of sediment and flow rate to pass the design 

storm 

 Selecting appropriate installation criteria such that the silt fence performs as designed 

Hydrologic Design 

The fence should be designed to pass the design storm without causing damage, while trapping 

the required amount of sediment. It is necessary to use either a database or some type of model to 

develop the appropriate hydrologic design. Efforts to model the sediment trapping that occurs 

through with a silt fence have resulted in models that predict the settling in the ponded area 

upstream from the fence (Barfield et al. 1996; Lindley et al. 1998). The results from model 

simulations show that trapping depends primarily on the surface area of the impounded water 

and the flow rate through the filter. The models use a clear water flow rate, typically specified by 

the manufacturer, to predict discharge. However, numerous studies have shown that sedimentladen flows cause clogging of the geotextiles used to construct the fence, depending on the 

opening size and size of the sediment (Britton et al. 2001; Wyant 1980; Barrett et al. 1995; 

Fisher and Jarrett 1984). Thus, results from model studies to date are suspect and need to be 

modified to account for the effects of clogging on flow rate. Barfield et al. (2001) developed a 

model of flow rate using conditional probability concepts, but the results have not been 

experimentally verified. 

Design aids have been developed for silt fence, using simulations from the SEDIMOT III model 

(Hayes and Barfield 1995). In the model, predictions are made about trapping efficiency using the 

ratio of settling velocity for the d15 of the eroded sediment, divided by the ratio of discharge to 

ponded surface area.3

 The design aids yield conservative estimates as compared to the SEDIMOT 

III model, but the database used for generating the design aid is based on the assumption that 

clogging does not affect flow rates. The discussion above shows that assumption to be erroneous. 

SEDCAD takes the approach of using a slurry flow rate, not a clean water flow rate, when it 

simulates fence effectiveness, reporting slurry rates ranging between 0.1 and 15 gallons per 

minute (gpm) per sqare foot. On the basis of this discussion, one can conclude that it is difficult 

to predict with accuracy the trapping efficiency of silt fence under a given set of conditions. In 

addition, the quality of installation and maintenance are important to the long-term performance 

 

3

 d15:15 percent by weight of suspended solids are smaller than those that are trapped by this device; similarly d50

indicates that 50 percent by weight of suspended solids are smaller than those trapped. 
Section 7: Technology Assessment 

7-48 

of the fence. The best available estimate of sediment trapping obtained from modeling of 

hydrologic events should be applied with care in any site design problem. 

Installation Criteria 

General installation criteria for the silt fence should incorporate the following factors: 

 The fabric must have sufficient strength to counter forces created by contained water 

and sediment (Sprague 1999). 

 The posts must have sufficient strength to counter the forces transferred to them by 

the fabric (Sprague 1999). 

 The fabric must be installed to ensure that the loads are all adequately transferred 

through the fabric to the posts or the ground without overstressing (Sprague 1999). 

 The fence must be designed according to site-specific hydrologic and soil conditions 

such that it will not overtop during design events. 

 The fence must be installed (anchored) with a buried toe of sufficient depth so that it 

does not become detached from the soil surface. 

 In general, the fence requires a metal wire backing to provide sufficient strength to 

prevent failure from the weight of trapped sediment and to prevent the toe of the 

fabric from being removed from the ground. 

 Maximum drainage area behind the fence should be determined on the basis of the 

local rainfall and the infiltration characteristics of the soil and cover. 

Silt fence material is typically synthetic filter fabric or a pervious sheet of polypropylene, nylon, 

polyester, or polyethylene yarn. The fabric should have ultraviolet ray inhibitors and stabilizers 

to provide for a minimum useful construction life of 6 months or the duration of construction, 

whichever is greater. The height of the fence fabric should not exceed 3 feet. If standard strength 

filter fabric is used, it should be reinforced with a wire fence, extending down into the trench that 

buries the toe. The wire should be of sufficient strength to support the weight of the deposited 

sediment and water. In general, a minimum 14 gauge and a maximum mesh spacing of 6 inches 

is called for (Smolen et al. 1988). Typical requirements for the silt fence physical properties, as 

specified in selected local BMP standards and specifications, are presented in Table 7-12. 

Table 7-12. Typical requirements for silt fence fabric 

Requirements 

Physical property Woven fabric Non-woven fabric 

Filtering Efficiency 85% 85% 

Tensile Strength 

at 20% (maximum) 

Elongation 

Standard Strength—30 pound/linear inch 

Extra Strength—50 pound/linear inch 

Standard Strength—50 pound/linear inch 

Extra Strength—70 pound/linear inch 

Slurry Flow Rate 0.3 gallon/square feet/minute 4.5 gallons/square feet/minute 

Water Flow Rate 15 gallons/square feet/minute 220 gallon/square feet/minute 

UV Resistance 70% 85% 

Source: NCDNR 1988; IDNR 1992. 
Section 7: Technology Assessment 

7-49 

Note that those numbers, particularly the flow rates, can vary widely depending on the local soil 

condition because of possible clogging of the filter material. 

Material for the posts used to anchor the filter fabric can be constructed of either wood or steel. 

Wooden stakes should be buried at a depth sufficient to keep the fence, when loaded with 

sediment and water, from falling over. The depth of burial should depend on post diameter and 

soil strength characteristics when saturated. Many standards and specifications set a minimum 

post length of 5 feet with 4-inch diameter for posts composed of softwood (e.g., pine) and 2-inch 

diameter for posts composed of hardwood (e.g., oak) (Smolen et al. 1988). Steel posts should 

also be designed according to local wet soil strength characteristics. Some standards and 

specifications for the posts set a minimum weight of 1.33 pounds per linear feet with a minimum 

length of 4 feet. Steel posts should also have projections to adhere filter fabric to the post 

(Smolen et al. 1988). 

A silt fence should be erected continuously from a single roll of fabric to eliminate unwanted 

gaps in the fence. If a continuous roll of fabric is not available, the fabric should overlap from 

both directions only at posts with a minimum overlap of 6 inches and be rolled together with a 

special flexible rod to keep the ends from separating. Fence posts should be spaced at a distance 

on the basis of wet soil strength characteristics and post size and strength; generally, the posts are 

spaced approximately 4 to 6 feet apart. If standard strength fabric is used in combination with 

wire mesh, the spacing can be larger. Typically, standards and specifications call for the posts to 

be no more than 10 feet apart. If extra-strength fabric is used without wire mesh reinforcement, 

some standards call for the support posts to be spaced no more than 6 feet apart (VDCR 1995). 

Again, the spacing depends on wet soil strength characteristics and post size. 

A silt fence must provide sufficient storage capacity or be stabilized over flow outlets such that 

the storage volume of water will not overtop the fence. The return period event (size of the 

rainfall event managed) used for design is typically a prerogative of the regulatory agency. For 

temporary fences, a 2-year storm event is typically used as a design standard. Fences that will be 

in place for 6 months or longer are commonly designed for a 10-year storm event (Sprague 

1999). The space behind the fence used for impoundment volume must be sufficient to 

adequately contain the sediment that will be deposited. Each storm will deposit sediment behind 

the fence, and after a time, the amount of sediment accumulated will render the fence useless. 

Frequency of fence management is a function of its sizing (i.e., whether the fence was installed 

for a 2-year or a 10-year storm event) (Sprague 1999) and the amount of erosion that occurs in 

the area draining to the fence. 

Effectiveness 

The performance of silt fences has not been well defined. Laboratory studies using carefully 

controlled conditions have shown trapping efficiencies in the range of 40 to 100 percent, 

depending on the type of fabric, overflow rate, and detention time (Barrett et al. 1995; Wyant 

1980; Wishowski et al. 1998). Field studies have been limited and quite inadequate; however, the 

results show that field-trapping efficiencies are very low. In fact, Barrett et al. (1995) obtained a 

value of zero percent trapping averaged over several samples with a standard error of 26 percent. 

Barrett et al. (1995) cite the following reasons for the field tests not showing the expected 

results: 
Section 7: Technology Assessment 

7-50 

 Inadequate fabric splices 

 Sustained failure to correct fence damage resulting from overtopping 

 Large holes in the fabric 

 Under-runs because of inadequate toe-ins

 Silt fence damaged and partially covered by the temporary placement of stockpiles of 

materials 

Silt fences are effective at removing large particle sediment, primarily aggregates, sands, and 

larger silts. Sediment is removed through impounding of water to slow velocity. It is argued that 

the silt fence will not contribute to a reduction in small particle sediment and is not effective 

against other pollutants (WYDEQ 1999). EPA (1993) reports the following effectiveness ranges 

for silt fences constructed of filter fabric: average TSS removal of 70 percent, sand removal of 

80 to 90 percent, silt-loam removal of 50 to 80 percent, and silt-clay-loam removal of 0 to 20 

percent. However, EPA numbers from the Nationwide Urban Runoff Program should not be 

considered to apply to every location. The actual trapping will vary widely for a given design 

because of differences in hydrologic regimes and soil types. 

The advantages of using silt fences include minimal labor requirement for installation, low cost, 

high efficiency in removing sediment, durability, and sometimes reuse (Sprague 1999). Silt 

fences are the most readily available and cost-effective control options where options such as 

diversion are not possible. Silt fences are also a popular choice because contractors have used 

them extensively and their familiarity makes silt fence use more likely for future construction 

activities. The visibility of a silt fence is also an advantage (i.e., the fence is advertising the use 

of ESC practices). In addition, the silt fence visibility makes site inspection easier for contractors 

and government inspectors (CWP 1996). 

EPA’s National Menu of Best Management Practices for Stormwater Phase II reports that 

compost filter socks and berms are at least as effective as other traditional ESC BMPs in 

controlling sediment; however, the results of the studies vary depending on the site conditions 

(USEPA 2008). 

Limitations 

Silt fences should not be installed along areas where rocks or other hard surfaces prevent 

uniform anchoring of fence posts and entrenching of the filter fabric. An insufficient anchor 

greatly reduces their effectiveness and might create runoff channels. In addition, open areas 

where wind velocity is high could present a maintenance challenge because high winds can 

accelerate deterioration of the filter fabric (Smolen et al. 1988). When the pores of the silt fence 

fabric become clogged with sediment, pools of water are likely to form uphill of the fence. Siting 

and design of the silt fence should account for this problem, and care should be taken to avoid 

unnecessary diversion of stormwater from the pools that might cause further erosion damage. Silt 

fences can act as a diversion if placed slightly off-contour and can control shallow, uniform 

flows from small, disturbed areas and deliver sediment-laden water to deposition areas. 

Silt fences will sag or collapse if a site is too large, if too much sediment accumulates, if the 

approach slope is too steep, or if the fence was not adequately supported. If the fence bottom is 
Section 7: Technology Assessment 

7-51 

not properly installed or the flow velocity is too fast, fence undercuts or blowouts can occur 

because of excess runoff. Erosion around the end of the fence can occur if the fence ends do not 

extend upslope to prevent flow around the fence (IDNR 1992). 

Maintenance 

Site operators should inspect silt fences after each rainfall event to ensure that they are intact and 

that there are no gaps at the fence-ground interface or tears along the length of the fence. If gaps 

or tears are found, they should be repaired or the fabric should be replaced immediately. 

Accumulated sediments should be removed from the fence base when the sediment reaches onethird to halfway up the height of the fence. Sediment removal should occur more frequently if 

accumulated sediment is creating a noticeable strain on the fabric, and there is the possibility that 

the fence could fail from a sudden storm event. 

Cost 

There is a wide range of data on installation costs for silt fences. EPA estimates the costs at 

approximately $6.00 per linear foot (USEPA 1992) while Southeastern Wisconsin Regional 

Planning Commission (SWRPC) estimates unit costs between $2.30 and $4.50 per linear foot 

(SWRPC 1991). Silt fences have an annual maintenance cost that is 100 percent of installation 

cost (Brown and Schueler 1997). Those values are significantly greater than that reported by R.S. 

Means (2000), which indicates a 3-foot-tall silt fence installation costs between $0.68 and $0.92 

per linear foot (for favorable and challenging installations). Note that the R.S. Means value 

covers only installation, without the expected costs of maintenance (e.g., removal of collected 

sediment). In addition, the type of silt fence fabric employed also affects the total installation 

costs. 

The Texas Commission on Environmental Quality reports that the cost of a 12-inch diameter 

compost filter sock ranges from $1.40 to $1.75 per linear foot when used as a perimeter control 

(McCoy 2005). The costs for an 18-inch diameter sock used as a check dam range from $2.75 to 

$4.75 per linear foot (McCoy 2005). Those costs do not include the cost of removing the 

compost filter sock and disposing of the mesh after construction ends; however, filter socks are 

often left on-site to provide slope stability and post-construction stormwater control. The cost to 

install a compost filter sock varies, depending on the availability of the required quality and 

quantity of compost and the availability of an experienced installer (USEPA 2008). 

The Texas Commission on Environmental Quality reports that compost filter berms cost $1.90 to 

$3.00 per linear foot when used as a perimeter control and $3 to $6 per linear foot when used as 

a check dam (McCoy 2005). The Oregon Department of Environmental Quality reports that 

compost filter berms cost approximately 30 percent less to install than silt fences (ODEQ 2004). 

Those costs do not include the cost of removal and disposal of the silt fence or the cost of 

dispersing the compost berm after construction ends. The cost to install a compost filter berm 

varies, depending on the availability of the required quality of compost in an area (USEPA 

2008). 
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7-52 

7.2.3.2. Super Silt Fence 

General Description 

Super silt fence is a modification of a standard silt fence. The two main differences between the 

standard silt fence and the super silt fence is that the super silt fence has a toe that is buried more 

deeply, and the backing material is chain link fence held in place by steel posts—a concept that 

originated in Maryland. The Maryland super silt fence requires a Geotextile Class F fabric over a 

chain link fence to intercept sediment-laden runoff from small drainage areas. The super silt 

fence provides a barrier that can collect and hold debris and soil more effectively than a standard 

silt fence, preventing material from entering critical areas. It is best used where installing a dike 

would destroy sensitive areas, woods, and wetlands. 

Applicability 

Super silt fences can be used in the same conditions as a silt fence. Fences should follow the 

contour of the land. Table 7-13 lists the distance a super silt fence should be from a slope to 

ensure maximum effectiveness (MDE 1994). 

Table 7-13. Slope lengths for super silt fences 

Slope Slope length 

(%) Minimum Maximum 

0–10 Unlimited Unlimited 

10–20 200 feet 1,500 feet 

20–33 100 feet 1,000 feet 

33–50 100 feet 500 feet 

50+ 50 feet 250 feet 

Design and Installation Criteria 

As with the standard silt fence, design criteria are of two types: 

 Hydrologic design for a required trapping of sediment and flow rate to pass the design 

storm 

 Selecting appropriate installation criteria such that the silt fence performs as designed. 

Hydrologic Design 

Hydrologic design criteria are the same as those for the standard silt fence. 

Installation Criteria 

The criteria used for the Maryland super silt fence indicate the following, although they have not 

been tested with field data: 

 The fence should be placed as close to the contour as possible, with no section of the 

silt fence exceeding a grade of 5 percent for a distance of more than 50 feet. 

 Fabric should be no more than 42 inches in height and should be held in place with a 

6-foot chain link fence. 
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7-53 

 Fabric should be attached to the steel pole using wire ties or staples. Fabric should be 

securely fastened to the chain link fence with ties spaced every 24 inches at the top 

and midsection. 

 Fabric should be embedded into the ground at a minimum of 8 inches. 

 Edges of fabric should overlap by 6 inches. 

Table 7-14 describes the physical properties of Geotextile Class F fabric (MDE 1994). 

Table 7-14. Minimum requirements for 

super silt fence Geotextile Class F fabric 

Physical properties Requirements 

Tension strength 50 pounds/inch 

Tensile modulus 20 pounds/inch 

Flow rate 0.3 gallon/ft2/minute 

Filtering efficiency 75% 

Effectiveness 

EPA did not identify any performance data for super silt fences. 

Limitations 

Super silt fences are not as likely to fail structurally as are standard silt fences, but they are more 

expensive than standard silt fences. 

Maintenance 

Maintenance requirements for super silt fences are generally the same as for standard silt fences. 

Cost 

The cost of the super silt fence is more than the standard silt fence because of deeper burial at the 

toe and the cost of chain linked fencing. R.S. Means (2000) indicates a rental price of $10 to $11 

per linear foot of chain linked fence for periods up to 1 year. Overall, rental is expected for most 

construction site installation because rental rates are approximately half the price of permanent 

chain link fencing. 

7.2.3.3. Straw Bale Dike 

General Description 

The straw bale dike is a temporary measure used to trap sediment from small, sloping disturbed 

areas. It is constructed of straw bales (not hay bales) wedged tightly together and placed along 

the contour downslope of disturbed areas. The bales are placed in a shallow excavation, and the 

upslope side is sealed with soil. Stakes are driven through the bales into the soil to help hold the 

bales in place. The dike works by impounding water, which allows sediment to settle out in the 

upslope area (Haan et al. 1994). Straw bale dikes are recommended for short duration application 

and are usually effective for less than 3 months because of rapid decomposition (USDOT 1995). 
Section 7: Technology Assessment 

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Applicability 

Straw bale dikes are generally placed at the toe of fills to provide for a broad shallow sediment 

pool. The dikes should not be used in drainage areas with concentrated and high flows, in large 

drainage areas, or in ditches and swales. The location of the straw bale dike should be fairly 

level, at least 10 feet from the toe, and should follow the land contour. Table 7-15 lists the 

distance a straw bale dike should be placed from a slope to ensure maximum effectiveness. 

Table 7-15. Maximum land slope and distances above a straw bale dike 

Land slope 

(%) 

Maximum distance above dam

(ft) 

Less than 2% 100 

2%–5% 75 

5%–10% 50 

10%–20% 25 

More than 20% 15 

Source: USDOT 1995. 

Design and Implementation Criteria 

Hydrologic Design 

Hydrologic design dictates the structure necessary to withstand a storm without causing damage 

while trapping the required amount of sediment. Either a database or some type of model is 

needed to find the appropriate design. Efforts to model the sediment trapping that occurs in straw 

bale dikes have resulted in models that predict the settling in the ponded area upstream from the 

dike (Barfield et al. 1996; Lindley et al. 1998). The results from model simulations show that 

trapping depends primarily on the surface area of the impounded water and flow rate through the 

filter. The models use a clear water slurry flow rate to predict discharge. It is anticipated, on the 

basis of visual observations, that sediment clogs the straw bale barrier, reducing the slurry flow 

rate. Thus, results from model studies to date are suspect and need to be modified to account for 

the effect of clogging on flow rate. 

Installation Criteria 

The USDOT’s BMP manual and the Indiana BMP manual call for bales to be 

 Anchored by driving two 36-inch long (minimum) steel rebars or 2 x 2-inch 

hardwood stakes through each bale 

 Sized according to the standard bale size of 14 inches x 18 inches x 35 inches 

 Placed in an excavated trench at least 4 inches deep, a bale’s width, and long enough 

that the end bales are somewhat upslope of the sediment pool 

 Abutted tightly against each other 

 Sized so that impounded water depth does not exceed 1.5 feet 

The USDOT BMP manual does not require that straw bale dikes be designed; however, the 

Indiana manual limits the drainage area to one-quarter acre per 100 feet of dam and the total 

drainage area draining to a straw bale dike to 2 acres. 
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Effectiveness 

The information on straw bale dikes performance is very limited. In laboratory studies of bales at 

varying orientations, Kouwen (1990) found that trapping efficiencies range from 60 to 100 

percent. While field data on trapping have not been collected, bales deteriorate rapidly and need 

to be replaced frequently. Because of such problems, using straw bale dikes as a perimeter 

control is not recommended, except in special circumstances. Only 27 percent of ESC experts 

rate the straw bale dike as an effective ESC practice, although their use is still allowed in half of 

the communities surveyed (Brown and Caraco 1997). 

Limitations 

Straw bale dikes should not be used as a diversion, in streams, in channels, or in areas with 

concentrated flow. The bales are not recommended for paved areas because of the inability to 

anchor the bales (IDNR 1992). 

Care must be taken to ensure that the bales are not installed in an area where there is a 

concentrated flow of runoff, in a drainage area that is too large, or on an excessive slope (IDNR 

1992). Under such conditions, erosion around the end of the bales, overtopping and undercutting 

of the bales, and bale collapsing and dislodging are likely to occur. Overtopping also occurs if 

the storage capacity is underestimated and where provisions are not made for safe bypass of 

storm flow (IDNR 1992). Undercutting occurs if the bales are not entrenched at least 4 inches 

and backfilled with compacted soil or are not abutted or chinked properly. Straw bale dikes are 

likely to collapse or dislodge if the bales are not adequately staked or if too much sediment is 

allowed to accumulate before cleanout (IDNR 1992). 

Maintenance 

For the straw bale dike to be most effective, it is important to replace deteriorated bales when 

appropriate. 

Cost 

The cost of straw bale dikes is relatively low, making their use attractive. R.S. Means (2000) 

indicates a staked straw bale unit cost of $2.61 per linear foot (including materials, labor, and 

equipment, with profit and overhead). 

7.2.3.4. Sediment Trap 

General Description 

A sediment trap is a temporary control device used to intercept sediment-laden runoff and to trap 

sediment to prevent or reduce off-site sedimentation. It is normally a more temporary type of 

structure than a sediment pond and is constructed to control sediment on the construction area 

during a selected phase of the construction operation. A sediment trap can be formed by 

excavation or embankments or both constructed at designated locations accessible for cleanout. 

The outlet for a sediment trap is typically a porous rock fill structure that detains the flow, but a 

pipe structure can also be used. A temporary sediment trap can placed be in a drainageway, at a 

storm drain inlet, or at other points of discharge from a disturbed area. They can be constructed 

independently or in conjunction with diversions and can be used in most drainage situations to 

prevent excessive siltation of pipe structures (USEPA 1992). 
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7-56 

Applicability 

Sediment traps can simplify the stormwater control plan design process by trapping sediment at 

specific spots at a construction site (USEPA 1992). They should be installed as early in the 

construction process as possible and are primarily effective as a short-term solution to trapping 

sediment from construction sites (WYDEQ 1999). Natural drainage patterns should be noted, 

and sites where runoff from potential erosion can be directed into the traps should be selected. 

Traps are most effective when capturing runoff from areas where 2 to 5 acres drain to one 

location. Sediment traps should not be in areas where their failure resulting from excess runoff 

can lead to further erosive damage of the landscape. Alternative diversion pathways should be 

designed to accommodate potential overflows. Traps should be accessible for clean-out and 

placed so that they do not interfere with construction activity. In addition, the traps are easily 

adaptable to most conditions. 

Design and Implementation Criteria 

Hydrologic Design 

A sediment trap should be designed to maximize surface area and sediment settling. That will 

increase the effectiveness of the trap and decrease the likeliness of backup during and after 

periods of high runoff intensity. The design of a trap includes determining the storage volume, 

surface area, dimensions of spillway or outlet, and elevations of embankment (USDOT 1995). 

Sediment traps should be designed to meet a 2-year, 24-hour storm event, but selecting a return 

period varies among regulatory agencies (IDNR 1992). 

Storage volume is created by a combination of excavation of land and construction of an 

embankment to detain runoff (USDOT 1995). Trap storage volume and length of spillway are 

determined as a function of the runoff volume and rate for the design storm. Such parameters 

will vary depending on return period rainfall and watershed hydrologic characteristics. Some 

standards specify a storage volume per acre disturbed. For example, Smolen et al. (1988) specify 

that approximate storage capacity of each trap should be at least 67 cubic yards per acre 

disturbed draining into the trap, but more recent guidelines suggest 134 cubic yards per acre of 

drainage area (VDCR 2001). Any national standard, however, should be based on runoff volume 

and peak discharge to be generally applicable. Local regulations can translate that into applicable 

volume and area standards. 

A more important criterion than storage volume relates to sediment trapping. If a trapping 

efficiency is specified, as in the case of South Carolina (SCDHEC 1995), it is necessary to 

design for trapping efficiency. If a TSS or settleable solids effluent criterion is adopted 

(SCDHEC 1995), settleable solids must be estimated. In both cases, a national standard should 

address how to estimate trapping efficiency or settleable solids. Efforts to model the sediment 

trapping that occurs in sediment traps have resulted in models that predict the settling in the 

ponded area (Barfield et al. 1996; Lindley et al. 1998). The results from model simulations show 

that trapping depends primarily on surface area of the impounded water and flow rate through 

the rock fill outlet. In fact, the ratio of peak outflow rate to surface area is the best simple 

predictor of trapping. The models use a modification of the Herrera and Felton (1991) 

relationship developed by Haan et al. (1994) to predict discharge rates. The predicted flow rates 

do not take into account clogging that can occur in rock fill. No models or procedures are 

available to estimate this clogging or its effect on flow criteria. 
Section 7: Technology Assessment 

7-57 

Design aids have also been developed for sediment traps, using simulations from the SEDIMOT 

III (Barfield et al. 2001; Hayes et al. 2001). In the model, predictions are made of trapping 

efficiency using the ratio of settling velocity for the d15 of the eroded sediment, divided by the 

ratio of discharge to ponded surface area. The design aid yields conservative estimates, but the 

database used for generating the design aid is based on the assumption that flow rates are not 

affected by clogging. That latter assumption is not likely to be a critical issue but should be 

addressed in future research. 

Installation Specifications 

USDOT standards call for the embankment to be constructed of compacted earth, at a maximum 

height of 5 feet (1.5 meters), a width of 4 to 5 feet (1.2 meters), and side slopes of 2:1or flatter. 

Those values might change as a result of local criteria and with changing soil characteristics. 

Temporary vegetation should be applied to the embankment. 

Two types of outlet structures are typically used for sediment traps, a rock outlet and a pipe 

outlet. Spillways of large stones or aggregate are the most common type of outlet designed for 

sediment traps. The crest of the spillway should be constructed 1 foot below the top of the 

embankment and the spillway depth 1.5 feet below the top of the embankment. Weir length of 

the spillway is determined on the basis of the contributing drainage area (Table 7-17) (USDOT 

1995). The outlet apron should be a minimum of 5 feet long, and placed on level ground with a 

filter fabric foundation to ensure exit velocity of drainage to receiving stream is nonerosive 

(IDNR 1992). 

The length of the rock outlet should be determined on the basis of peak discharge required and 

rock characteristics, typically rock diameter. Flow rate calculations can be made with the 

relationship of Herrera and Felton (1991) as modified by Haan et al. (1994). Alternatively, 

USDOT has specified the weir length for a given drainage area as shown in Table 7-16. 

However, the values should be adjusted for each climatologic area to account for local 

hydrologic and return period rainfall. 

Table 7-16. Weir length for sediment traps 

Contributing drainage area 

Weir length 

(ft) 

1 4 

2 5 

3 6 

4 10 

5 12 

Source: USDOT 1995. 

The pipe outlet, constructed of corrugated metal or PVC pipe riser, is an alternative to the rock 

outlet. Pipe diameter is based on the peak discharge rate required. To obtain appropriate 

freeboard, the top of pipe should be placed 1.5 feet below embankment elevation. Perforated 

pipe is sometimes used. USDOT suggests perforations of 1-inch (25 mm) diameter holes or 0.5 x 

6 inch (13 x 15 mm) slits in the upper two-thirds of the pipe; however, the discharge should be 

calculated for this pipe specification to ensure that it matches the required peak discharge. 
Section 7: Technology Assessment 

7-58 

The pipe should be placed vertically and horizontally above wet storage elevation (USDOT 

1995). Riprap should be used as an outlet protection and placed at the outlet of the barrel to 

prevent scour from occurring (USDOT 1995). A stable channel should be provided to convey 

discharge to the receiving channel (USDOT 1995). 

Effectiveness 

If it is assumed that the flow can be accurately controlled by the rock fill outlet, sediment traps 

should operate as effectively as sediment basins, with trapping efficiencies reduced as a result of 

smaller surface areas. The NURP study (USEPA 1983), Stahre and Urbonas (1990), and Haan, et 

al. (1994), reports that sediment basins effectively trap sediment and chemicals as shown in 

Table 7-17. 

Table 7-17. Range of measured pollutant removal for sediment detention basins 

Item Removable percentage 

Total suspended solids (TSS) 50%–70% 

Total phosphorus (TP) 10%–20% 

Nitrogen 10%–20% 

Organic matter 20%–40% 

Lead 75%–90% 

Zinc 30%–60% 

Hydrocarbons 50%–70% 

Bacteria 50%–90% 

Source: Stahre and Urbonas 1990. 

Information on the actual effectiveness of sediment traps is limited. The discussion should start 

first with the flow hydraulics of the rock fill outlet typically employed as a principal spillway for 

sediment traps. Procedures for estimating flow through rock fill have been developed by Herra 

and Felton (1991) to estimate flow as a function of average rock diameter, standard deviation of 

rock size, and flow length. If those parameters could be controlled in an actual situation, the flow 

could be accurately predicted. However, given that standard construction practices consist of 

end-dumping the rock fill in place, one would expect little correlation between design and 

construction, and the actual discharge and trapping efficiency would be expected to be 

dramatically different from the design. This analysis does not mean that sediment traps are 

ineffective but that a given design could not be guaranteed to meet the effluent criteria, even 

though the predictions indicate compliance. Sediment trapping efficiency is a function of surface 

area and inflow rate (Smolen et al. 1988). Those traps that provide pools with large length-towidth ratios have a greater chance of success. 

Sediment traps remove larger-sized sediment, primarily sized from silt to sands, by slowing 

water velocity and allowing for sediment settling in ponded water (Haan et al. 1994). Although 

sediment traps allow for settling of eroded soils, because of their short detention periods for 

stormwater they typically do not remove fine particles such as silts and clays without chemical 

treatment. Sediment settling ability is related to the square of the particle size; halving particle 

sizes quadruples the time needed to achieve settlement (WYDEQ 1999). To increase overall 

effectiveness, traps should be constructed in smaller areas with low slopes. Sediment traps are 
Section 7: Technology Assessment 

7-59 

typically designed to remove only sediment from surface water, but some non-sediment 

pollutants are trapped as well (Haan et al. 1994). 

Limitations 

Common concerns associated with sediment traps are included in Table 7-18. 

Table 7-18. Common concerns associated with sediment traps 

Common concern Result 

Inadequate spillway size Results in overtopping of the dam and possible failure 

of the structure 

Omitted or improperly installed geotextile fabric Results in piping under the sides or bottom of the 

stone and outlet section 

Low point in embankment caused by inadequate 

compaction and settling 

Results in overtopping and possible failure 

Stone outlet apron does not extend to stable grade Results in erosion below the dam 

Stone size too small or backslope too steep Results in stone displacement 

Inadequate vegetative protection Results in erosion of embankment 

Inadequate storage capacity Results in a less than adequate settling time (can also 

be caused by an insufficient amount of sediment being 

removed from the basin) 

Contact slope between stone spillway and earth 

embankment too steep 

Results in piping failure 

Outlet pipe installed in the vertical side of the trench Results in piping failure of embankment 

Corrugated tubing used as an outlet pipe Results in crushed pipe and inadequate outlet capacity 

Source: IDNR 1992. 

Maintenance 

The primary maintenance consideration for temporary sediment traps is removing accumulated 

sediment from the basin, which must be done periodically to ensure the continued effectiveness 

of the sediment trap. Sediments should be removed when the basin reaches approximately 50 

percent sediment capacity. 

A sediment trap should be inspected after each rainfall event to ensure that the trap is draining 

properly. Inspectors should also check the structure for damage from erosion or piping. The 

depth of the spillway should be checked and maintained at a minimum of 1.5 feet below the low 

point of the trap embankment. 

Cost 

The cost of installing temporary sediment traps ranges from $0.20 to $2.00 per cubic foot of 

storage (about $1,100 per acre of drainage). EPA estimates the following costs for sediment 

traps, which vary as a function of the volume of storage: $513 for 1,800 cubic yards, $1,670 for 

3,600 cubic yards, and $2,660 for 5,400 cubic yards (USEPA 1993). Evaluation of a series of 

more recent data sources (USEPA 2003) indicates that sediment traps have an average cost of 

$0.30 per cubic foot of storage. In addition, it has been reported that a sediment trap has an 

annual maintenance cost of 20 percent of installation cost (Brown and Schueler 1997). 
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7-60 

7.2.3.5. Sediment Basin 

General Description 

A sediment basin is a stormwater detention structure formed by constructing a dam across a 

drainageway or excavating a storage volume at other suitable locations and using it to intercept 

sediment-laden runoff. Sediment basins are generally larger and more effective in retaining 

sediment than temporary sediment traps and typically remain active throughout the construction 

period. Jurisdictions that require post-development flow to be less than or equal to 

predevelopment flow during construction could employ the designed detention facilities as a 

temporary sediment basin during construction. 

When sediment basins are designed properly, they can control sediment pollution through the 

following functions (Faircloth 1999): 

 Sediment-laden runoff is caught to form an impoundment of water and create 

conditions where sediment will settle to the bottom of the basin. 

 Treated runoff is released with less sediment concentration than when it entered the 

basin. 

 Storage is provided for accumulated sediment, and resuspension by subsequent 

storms is limited. 

Applicability 

Sediment basins should be located at a convenient concentration point for sediment-laden flows 

(NCDNR 1988). Ideal sites are areas where natural topography allows a pond to be formed by 

constructing a dam across a natural swale; such sites are preferred to those that require 

excavation (Smolen et al. 1988). 

Sediment basins are also applicable in drainage areas where it is anticipated that other erosion 

controls, such as sediment traps, will not be sufficient to prevent off-site transport of sediment. 

Choosing to construct a sediment basin with either an earthen embankment or a stone/rock dam 

will depend on the materials available, location of the basin, and desired capacity for stormwater 

runoff and settling of sediments. 

Rock dams are suitable where earthen embankments would be difficult to construct or where 

riprap is readily available. Rock structures are also desirable where the top of the dam structure 

is to be used as an emergency overflow outlet. Such riprap dams are best for drainage areas of 

less than 50 acres. Earthen damming structures are appropriate where failure of the dam will not 

result in substantial damage or loss of property or life. If properly constructed, sediment basins 

with earthen dams can handle stormwater runoff from drainage basins as large as 100 acres. 

Design and Implementation Criteria 

Hydrologic Design 

A sediment basin can be constructed by excavation or by erecting an earthen embankment across 

a low area or drainage swale. Sediment basins can be designed to drain completely during dry 

periods, or they can be constructed so that a shallow, permanent pool of water remains between 
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7-61 

storm events. Depending on the size of the basin constructed, the basin might be subject to 

additional regulation, particularly state and federal regulations related to dam safety. 

Sediment basins can be used for any size watershed, but USDOT recommends a drainage area 

range of 5 to 100 acres (USDOT 1995). Components of a sediment basin that must be considered 

in the hydrologic design include the following (Haan et al. 1994): 

 A sediment storage volume sized to contain the sediment trapped during the life of 

the structure or between cleanouts 

 A permanent pool volume (if included) above the sediment storage to protect trapped 

sediment and prevent resuspension as well as providing a first flush of discharge that 

has been subjected to an extended detention period 

 A detention volume that contains storm runoff for a period sufficient to trap the 

necessary quantity of suspended solids 

 A principal spillway that can be a drop-inlet pipe and barrel, a trickle tube, or other 

type of controlled release structure 

 An emergency spillway that is designed to handle excessive runoff from the rarer 

events and prevent overtopping 

The following recommended procedures for conducting the hydrologic design are summarized 

from Haan et al. (1994). 

Sediment Storage Volume. This volume should be sufficient to store the sediment trapped 

during the life of the structure or between cleanouts. Sediment storage volume can be calculated 

on the basis of sediment yield using relationships such as the RUSLE with an appropriate 

delivery ratio (Renard et al. 1994) or a computer model such as SEDIMOT III (Barfield et al. 

1996) or SEDCAD (Warner et al. 1999). Many design specifications, however, base the 

sediment storage volume on a volume per acre disturbed. For example, Pennsylvania specifies a 

sediment storage volume of 1,000 cubic feet per acre drained (see DCN 43050, Pennsylvania 

Erosion and Sediment Pollution Control Program Manual). This volume is highly site-specific, 

depending on rainfall distributions, soil types, and construction techniques. 

Permanent Pool Volume. Providing a first flush of discharge that has been subjected to an 

extended detention period can help to minimize degradation of water quality and justify some 

permanent pool. The recommended capacity of the permanent pool varies with the regulatory 

agency. USDOT, for example, recommends 67 cubic yards per acre (126 m3

/ha) (USDOT 1995). 

That standard has been adopted by many states as well. If an effluent criterion such as allowable 

peak TSS or peak settleable solids is used, the final design of both permanent pool and detention 

volume should be selected only after using a computer model to predict the expected peak 

effluent concentrations. 

Detention Volume. Storm runoff must be contained for a period of time sufficient to trap the 

necessary quantity of suspended solids. Because inflow is occurring simultaneously with outflow, 

the detention time for each plug of flow is different and should be considered individually. The 

size of the detention volume, as stated above, should also be developed in concert with determining 

the size of the permanent pool volume and the size of the principal spillway. When effluent TSS 
Section 7: Technology Assessment 

7-62 

and settleable solids criteria are used, the size of the detention volume and permanent pool volume 

should be determined through a computer model calculation of expected effluent concentrations 

for a given design. The return period used to size the detention volume depends on the regulatory 

agency, but a return period of 10 years is typical for sediment basins that eventually become 

stormwater detention ponds (i.e., are used to limit future flooding due to stormwater). EPA’s 

review of state construction site regulations found that the majority of states specify detention 

volume in terms of cubic feet per acre that drains to the sediment basin. State design values range 

between 1,800 and 5,400 cubic feet per acre, with 3,600 cubic feet per acre or expected runoff 

from the local 2-year, 24-hour storm event as the typical value. 

Principal Spillway. The principal spillway is a hydraulic outlet structure sized to provide the 

appropriate outflow rate to meet the effluent or trapping efficiency criteria. The principal 

spillway should have a dewatering device that slowly releases water contained in the detention 

storage over an extended period and at a rate determined to trap the required amount of sediment 

or provide for the appropriate effluent concentration in the design storm. The more common 

outlet structures are the drop-inlet structure and the trickle tube. Sizing of the principal spillway 

should follow standard design procedures with respect to hydrology and sediment considerations, 

but sizing the structure to simply pass the design storm is inappropriate and will not result in 

meeting an effluent or trapping efficiency standard. The size to be used in a given structure 

should be determined on the basis of the effluent or trapping efficiency standard being targeted 

and site-specific hydrologic and soil conditions. Appropriate design will require the use of a 

computer model such as SEDIMOT III (Barfield et al. 1996) or design aids such as those 

developed for South Carolina (Hayes and Barfield 1995). In general, the design is developed to 

maximize surface area, which will minimize peak discharge. Because failure of the dam could 

result in downstream damage, the design should be done and certified by a licensed engineer 

with expertise in hydrologic computation. 

For discussion of skimmers in lieu of rock and perforated outlets in sediment traps and basins, 

see Section 7.2.3.6. 

Emergency Spillway. Because overtopping of the dam can cause failure and downstream damage, 

an emergency spillway is necessary to handle excessive runoff from the larger, less frequent events 

and prevent overtopping. The design storm for the emergency spillway will depend on the hazard 

classification of the sediment basin. Typical return periods vary between 25 and 100 years, with 25 

years recommended by USDOT. Sizing of the emergency spillway is typically accomplished to 

simply transmit the rare event without eroding the base of the spillway. Procedures for making the 

hydrologic and hydraulic computations are summarized in Haan et al. (1994). Again, because 

failure of the dam could result in downstream damage, the design should be done and certified by a 

licensed engineer with expertise in hydrologic computation. 

Installation Criteria 

The embankment for permanent sediment basins should be designed using standard geotechnical 

construction techniques. The fill is typically constructed of earthen fill material placed and 

compacted in continuous layers over the entire length of the fill. USDOT recommends 6- to 8-

inch layers (USDOT 1995). The embankment should be stabilized with vegetation after 

construction of the basin. A cutoff trench should be excavated along the centerline of the dam to 

prevent excessive seepage beneath the dam and be sized using standard geotechnical 
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computations. USDOT recommends that a minimum depth of the cutoff trench be approximately 

2 feet (600 mm), the height should be to the riser crest elevation, the minimum bottom width 

should be 4 feet (1.2 m) or wide enough for compaction equipment, and slopes should be no 

steeper than 1:1. 

Sediment basins can also be constructed with rock dams in a design that is similar to a sediment 

basin with an earthen embankment. It is important to remember that rock fill is highly 

heterogeneous and that flow rates calculated with any available procedure are not likely to match 

those that will actually occur. Because sediment trapping is inversely proportional to flow rate, 

the trapping efficiency will be affected significantly. No data are available to determine the 

variability of rock fill in actual installations so that confidence intervals can be placed on 

predicted flow rates. Such data should be collected and the confidence intervals calculated before 

recommending the use of rock dams as outlets on any structures other than sediment traps. 

Effectiveness 

The effectiveness of a sediment basin depends primarily on the sediment particle size and the 

ratio of basin surface area to inflow rate (Smolen et al. 1988; Haan et al. 1994). Basins with a 

large surface area-to-volume ratio will be most effective. Studies by Barfield and Clar (1985) 

show that a surface area-to-peak discharge ratio of 0.01 acre per cubic foot would trap more than 

75 percent of the sediment coming from the Coastal Plain and Piedmont regions in Maryland. 

That efficiency might vary for other regions of the country and should not be used as a national 

standard. Studies by Hayes et al. (1984) and Stevens et al. (2001), however, show that similar 

relationships can be developed for other locations. 

Laboratory data collected on pilot-scale facilities are available on the trapping efficiency of 

sediment basins, effluent concentrations, dead storage and flow patterns, and the effects of 

chemical flocculants on sediment trapping (Tapp et al. 1981; Wilson and Barfield 1984; Griffin 

et al. 1985; Jarrett 1999; Ward et al. 1977, 1979). In general, the laboratory studies show that 

pilot-scale ponds can be expected to trap 70 to 90 percent of sediment, depending on the 

sediment characteristics, pond volume, and flow rate. The trapping efficiency and effluent 

concentration are, in general, related to the overflow rate and can be reasonably well predicted 

using a plug flow model (Ward et al. 1977, 1979) and a Continuously Stirred Tank Reactor 

(CSTR) model (Wilson et al. 1982; Wilson et al. 1984). Extensive field-scale data are available 

on long-term trapping efficiency in stormwater detention basins in which the annual trapping 

efficiency is related to the annual capacity inflow ratio of the basin. These structures are not 

representative of those used for sediment ponds but would be representative of those used for 

regional detention. A more limited database is available on single storm sediment trapping in the 

larger structures (Ward, et al. 1979) and on a field laboratory structure at Pennsylvania State 

University (Jarrett et al. 1999). 

For maximum trap efficiency, Smolen et al. (1988) recommend the following: 

 Allow the largest surface area possible, maximize the length-to-width ratio of the 

basin to prevent short circuiting, and ensure use of the entire design settling area. 

 Locate inlets for the basin at the maximum distance from the principal spillway 

outlet. 
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 Allow the maximum reasonable time to detain water before dewatering the basin. 

 Reduce the inflow rate into the basin and divert all sediment-free runoff. 

Jarett (1999) has shown that the smaller the depth of the basin, the more sediment is discharged. 

A 0.15-meter-deep (0.49-foot-deep) basin lost twice as much sediment as a 0.46-meter-deep 

(1.5-foot-deep) basin. Jarrett also found that the performance of a sediment basin will increase 

with the use of a skimmer in the principal spillway. The sediment discharged was 1.8 times 

greater with only a perforated riser than with a skimmer in the principal spillway. In addition, 

increasing the dewatering time, which allows for more sediment deposition, decreases the 

sediment loss from the basin (Jarrett 1999). 

Table 7-19 presents a summary of sediment basin monitoring or modeling data. Table 5-1 shows 

corresponding influent TSS data when available. For summaries of studies with monitoring or 

modeling data, and annotated bibliographies for the journal articles and professional conference 

proceedings that EPA reviewed, see DCN 44321. 

Table 7-19. Studies of TSS in sediment basin effectiveness and effluent from construction sites 

Site 

Mean effluent TSS 

concentration 

(mg/L) 

Mean TSS 

reduction 

(percent) Source 

Seattle, Washington 154 98.6% Horner et al. 1990 

SR 204 626 86.7% Horner et al. 1990 

Mercer Island 63 75.1% Horner et al. 1990 

SB1 322 54.7% Schueler and Lugbill 1990 

SB2 91 80.3% Schueler and Lugbill 1990 

SB4 875 66.8% Schueler and Lugbill 1990 

Pennsylvania Test 

Basin 

800 94.2% Jarrett 1996 

Georgia Model 600 65% Sturm and Kirby 1991 

Maryland Model 700 84% Barfield and Clar 1985 

Hamilton County, Ohio 3,507 35% Islam et al. 1998 

Johnston County, North 

Carolina SkB1 

1,042 87% Markusic and McLaughlin 2008; 

McLaughlin and Markusic 2007. 

Mean TSS (mg/L) 798 75% N/A 

N/A – Not Applicable 

Limitations 

Neither a sediment basin with an earthen embankment nor a rock dam should be used in areas of 

continuously running water (live streams). Using sediment basins is not intended for areas where 

failure of the earthen or rock dam will result in loss of life, damage to homes or other buildings, 

or interference with the use of public roads or utilities. 

Because sediment basins are usually temporary structures, they are often designed poorly and 

rarely receive adequate attention and maintenance. As a result, such basins will not achieve the 

function for which they were designed, especially when conventional outlets cannot properly 

meter outflow to create an impoundment, thus allowing rapid release of sediment-laden water 

from the bottom of the basin to escape (Faircloth 1999). 
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Common concerns associated with sediment basins are included in Table 7-20. 

Table 7-20. Common concerns associated with sediment basins 

Common concern Result 

Improper compaction, omission of anti-seep collar, 

leaking pipe joints, or use of unsuitable soil 

Results in piping failure along conduit 

Inadequate vegetation or improper grading and 

sloping 

Results in erosion of spillway or embankment slopes 

Inadequate compaction or use of unsuitable soil Results in slumping or settling of embankment 

Steep side slopes Results in bank failure due to slumping

Inadequate outlet protection Results in erosion and caving below principal spillway 

Basin not located properly for access Results in difficult, ineffective, and costly maintenance 

Sediment not properly removed Results in inadequate storage capacity and potential 

resuspension 

Lack of anti-flotation Results in the riser and barrel being blocked with debris 

Principal and emergency spillway on design plans Results in improper disposal of accumulated sediment 

Gravel clogging the dewatering system Results in safety or health hazard from pond water 

Principal spillway too small Results in frequent operation of emergency spillway 

and increased erosion potential 

Source: IDNR 1992. 

Maintenance 

Routine inspection and maintenance of sediment basins is essential to their continued 

effectiveness. Basins should be inspected after each storm event to ensure proper drainage from 

the collection pool and determine the need for structural repairs. Erosion from the earthen 

embankment or stones moved from rock dams should be repaired or replaced immediately. 

Sediment basins must be in an area that is easily accessible to maintenance crews for removal of 

accumulated sediment. Sediment should be removed from the basin when its storage capacity has 

reached approximately 50 percent. Trash and debris from around dewatering devices should be 

removed promptly after rainfall events. 

Cost 

If constructing a sediment basin with less than 50,000 cubic feet of storage space, the cost of 

installing the basin ranges from $0.20 to $1.30 per cubic foot of storage (approximately $1,100 

per acre of drainage) with an average cost of approximately $0.60 per cubic foot of storage 

(USEPA 1993). If constructing a sediment basin with more than 50,000 cubic feet of storage 

space, the cost of installing the basin ranges from $0.10 to $0.40 per cubic foot of storage 

(approximately $550 per acre of drainage) with an average cost of approximately $0.30 per cubic 

foot of storage (USEPA 1993). A review of state highway project bids and county bonding 

estimates conducted in 2003 confirms the value of $0.30 per cubic foot (USEPA 2003). Annual 

maintenance costs are 25 percent of installation costs (Brown and Schueler 1997). 

R.S. Means (2000) suggests the cost to remove the eroded sediment collected in a small basin 

during construction is approximately $4 per cubic yard (that value includes a 100 percent 

surcharge for wet excavation). Disposal of material on-site will result in an additional cost that 

can be computed only from site-specific conditions. The cheapest management of dredged 
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material is application to land areas adjacent to the basin followed with application of a 

vegetative cover. 

7.2.3.6. Faircloth Skimmer 

General Description 

 A Faircloth Skimmer® is a surface drain that floats on top of the water in a sediment basin. The 

skimmer inlet controls the rate of outflow and rises and falls as the basin fills and drains. It 

releases the cleanest water in the basin from near the surface. Although the Faircloth Skimmer is 

a proprietary device, the same concept applies to any device that withdraws water from the 

surface of the basin as opposed to dewatering through a perforated riser or stone outlet structure. 

Applicability 

A Faircloth Skimmer is used instead of the rock and perforated riser outlets in sediment traps and 

basins. 

Design and Implementation Criteria 

The Faircloth Skimmer can be attached directly to an outlet pipe that drains through the dam or 

attached to an outlet pipe through a riser. The key design parameters in sizing a Faircloth 

Skimmer is volume to drain and the length of time for the basin to drain. As the size of the 

skimmer increases, the basin drainage time decreases. Faircloth recommends 3 days in the 

absence of state specifications. North Carolina specifies 1 to 3 days and Pennsylvania 4 to 7 

days. 

Effectiveness 

The skimmer allows water to be released from the top of the basin, which is the cleanest water 

(Faircloth 1999). EPA summarizes skimmer basin performance data from an active construction 

site in Johnston County, North Carolina (see DCN 44321). 

Limitations 

There are many factors in addition to a surface drain for a basin to be efficient. For limitations of 

sediment basins, see Section 7.2.3.5. 

Maintenance 

Routine inspection and maintenance of sediment basins with or without skimmers is essential to 

their continued effectiveness. For maintenance of sediment basins, see Section 7.2.3.5. 

Cost 

EPA obtained Faircloth Skimmer equipment and shipping costs and added costs for additional 

required ancillary equipment (e.g., PVC pipe, glue), as well as labor for installation. Assuming a 

3-day drainage time, EPA developed the following cost equation: 

Total skimmer cost (2009 dollars) = 0.0138 × (basin volume in cubic feet) + 1,049. 

DCN 43113 documents the development of that cost equation. 
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7.2.3.7. Enhanced Sediment Trapping 

General Description 

Work in recent years has focused on a number of passive, PAM-based systems to enhance 

pollutant removal in sediment basins. Other chemicals used in such passive systems include 

chitosan acetate, chitosan lactate, gypsum, and alum. PAM, available in floc logs, has also seen 

increased placement in conveyance channels. Chitosan lactate gel socks have also been used in 

that application. As water flows through the channel, the chemical dissolves, and the turbulence 

in the channel aids in the flocculation process. Flocs can then settle out in sediment control 

devices, such as check dams, sediment traps or basins. PAM (and other flocculants) can also be 

added in liquid form to stormwater and is commonly used to dose sediment basins to help 

remove sediment. For discussion of fiber check dams installed at grade with PAM applied to the 

check dam for passive dosing, see Section 7.2.2.5. At least one vendor is also using a tube settler 

coupled with polymer addition before filtration to help remove sediment. 

Applicability 

Treatment chemicals can enhance sediment removal when traditional BMPs are not capable of 

meeting numeric standards (e.g., because of fine-grained, suspended sediment or colloidal 

particles, or a retention device design is not optimal because of site limitations). Auckland 

Regional Council (2004) notes that passive treatment using flock blocks requires no power and is 

less expensive and less complex than active systems. 

Design and Implementation Criteria 

For information on commonly available coagulant/flocculants and toxicity information, see 

Section 7.2.5. 

Effectiveness 

McLaughlin demonstrated the ability to meet a 50-NTU limit at a research site in North Carolina 

by adding PAM to a basin equipped with baffles and a surface skimmer (see DCN 43082, The 

Potential for Substantial Improvements in Sediment and Turbidity Control). North Carolina now 

requires skimmers on all sediment basins, and the North Carolina Department of Transportation 

has developed draft standards for the use of porous baffles in sediment basins (see DCNs 43083 

and 43045, NCDOT draft baffles standards and North Carolina Erosion and Sediment Control 

Planning and Design Manual with requirements for skimmers). Bhardwaj and McLaughlin 

(2008a) found that both active and passive-dosed PAM systems significantly reduced turbidity, 

with the active dosing being slightly more effective. Bhardwaj and McLaughlin (2008a, 2008b) 

and McLaughlin (2006) reports that basin modifications (e.g., baffles, outlet type) have minor 

effects on turbidity in comparison to PAM addition. For summaries of studies with monitoring 

data and annotated bibliographies for the journal articles and professional conference 

proceedings that EPA reviewed, see DCN 43114. 

Limitations 

McLaughlin (2006) reports that blocks that were allowed to dry were much less effective. 

McLaughlin (No Date b) notes that blocks in ditches without slope tend to become buried more 

easily than blocks placed in stepper ditches. Auckland Regional Council (2004) notes that the 
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primary disadvantage of the passive blocks is that the exact dosage is unknown, dependent on 

flow and condition of the block. 

Maintenance 

Routine inspection and maintenance of BMPs with or without passive chemical treatment is 

essential to their continued effectiveness. 

Cost 

PAM can be used in a centralized treatment system (e.g., at a sedimentation basin) to treat larger 

areas, or dispersed in granular or liquid form. In Tobiason et al. (2000), the startup costs for the 

batch treatment system at a large airport construction project amounted to $90,000, although the 

author notes that costs for some of the initial piping might have been unwarranted. Monthly 

expenses average $18,000 for operations and maintenance and $13,000 for materials and 

equipment, but the author notes that high monthly costs were driven by record rainfall and 

extremely wet weather experienced. The author states that “passive dosing systems being tested 

as a complementary BMP present considerable cost savings and may provide similar 

effectiveness.” The total costs for this phase totaled about $245,000, less than 1 percent of total 

construction costs. Auckland Regional Council (2004) reports a total cost of approximately 

$2,400 per installation for a rainfall-driven, liquid dosing system that does not require flow 

runoff measurement or a dosing pump. 

7.2.4. OTHER CONTROL PRACTICES 

7.2.4.1. Stone Outlet Structure 

Description 

A stone outlet structure is a temporary stone dike installed in conjunction with and as a part of an 

earth dike. The purpose of the stone outlet structure is to impound sediment-laden runoff, 

provide a protected outlet for an earth dike, provide for diffusion of concentrated flow, and allow 

the area behind the dike to dewater slowly. The stone outlet structure can extend across the end 

of the channel behind the dike or be placed in the dike itself. In some cases, more than one stone 

outlet structure can be placed in a dike. 

Applicability 

Stone outlet structures apply to any point of discharge where there is a need to discharge runoff 

at a protected outlet or to diffuse concentrated flow for the duration of construction. The drainage 

area to this practice is typically limited to one-half acre or less to prevent excessive flow rates. 

The stone outlet structure should be located so as to discharge onto an already stabilized area or 

into a stable watercourse. Stabilization should consist of complete vegetative cover and paving 

that are sufficiently established to be erosion resistant. 

Design and Installation Criteria 

Design criteria are of two types: hydrologic design for a required trapping of sediment or flow 

rate to pass the design storm; and selecting appropriate installation criteria such that the stone 

outlet performs as designed. 
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7-69 

Hydrologic Design 

The hydrologic design should be based on the design storm and standard hydraulic calculations. 

It should include the following considerations: 

 Design rainfall and design storm. The design storm should be specified by the 

regulatory authority. Typically a return period of 2 to 5 years is used. Runoff rates 

should be calculated with standard hydrologic procedures as allowed by the 

regulatory authority. 

 Drainage area. The drainage area to this structure is typically limited to less than half 

an acre to ensure that the flow rates are not excessive. 

 Length of crest and height of stone fill. The crest length and height of stone fill 

should be of sufficient size to transmit the design storm without overtopping. The 

volume of water stored behind the dike can be estimated but would require routing 

the storm flow in the design storm. Flow through the stone outlet can be calculated 

using the relationships of Herrera and Felton (1991) as modified by Haan et al. 

(1994). The height of the fill should be small enough to prevent excessive flow 

velocities through the stone fill and prevent undercutting. 

 Outlet stabilization. The discharge from the stone outlet should be stabilized with 

vegetated waterways or riprap until the flow reaches a stable channel. Design of the 

stabilized outlet should follow procedures presented earlier. 

Installation Criteria Specifications 

A stone outlet structure should conform to the following specifications: 

 The outlet should be composed of 2- to 3-inch stone or recycled concrete, but clean 

gravel can be used if stone is not available. 

 The crest of the stone dike should be at least 6 inches lower than the lowest elevation 

of the top of the earth dike and should be level. 

 The stone outlet structure should be embedded into the soil a minimum of 4 inches. 

 The minimum length of the crest of the stone outlet structure should be 6 feet. 

 The baffle board should extend 1 foot into the dike and 4 inches into the ground and 

be staked in place. 

 The drainage area to this structure should be less than one-half acre. 

7.2.4.2. Rock Outlet Protection 

Description 

Rock outlet structures are rocks that are placed at the outfall of channels or culverts to reduce the 

velocity of flow in the receiving channel to nonerosive rates. 
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Applicability 

This practice applies where discharge velocities and energies at the outlets of culverts are 

sufficient to erode the next downstream reach and is applicable to outlets of all types such as 

sediment basins, stormwater management ponds, and road culverts. 

Design and Installation Criteria 

Hydrologic Design 

Hydrologic design consists primarily of selecting the design runoff rate and sizing outlet 

protection. Standard hydrologic calculations should be used with an appropriate return period 

storm for the outlet being protected (typical return periods range from 2 to 10 years). 

The process for sizing outlet protection involves selecting the type and geometry of the outlet 

protection and the size of the rock lining. The outlet protection could consist of a plunge pool 

(scour hole), an apron-type arrangement, or an energy dissipation basin (Haan et al. 1994). The 

design of each differs. Plunge pools are typically used for outlet pipes that are elevated above the 

water surface. Aprons are used for other types of outlets. Plunge pool geometry is based on the 

flow rate, pipe size and slope, tailwater depth, and size of the riprap lining (Haan et al. 1994). 

Apron dimensions are determined by the ratio of the tailwater depth to pipe diameter (Haan et al. 

1994). Energy dissipation basins are used as an alternative to the plunge pool. Dimensions are a 

function of the brink depth in the pipe at the design flow, pipe diameter, and size of riprap (Haan 

et al. 1994). The size of the rock lining is a function of the discharge, pipe size, tailwater depth, 

and geometry selected. Details on sizing the rock are given in Haan et al. (1994). 

The design method presented here applies to the sizing of rock riprap and gabions to protect a 

downstream area. It does not apply to rock lining of channels or streams. The design of rock 

outlet protection depends entirely on the location. Pipe outlets at the top of cuts or on slopes 

steeper than 10 percent cannot be protected by rock aprons or riprap sections because of 

reconcentration of flows and high velocities encountered after the flow leaves the apron. 

Installation Criteria 

The following criteria should be considered: 

 Bottom grade: The outlet protection apron should be constructed with zero slope 

along its length. There should be no obstruction at the end of the apron. The elevation 

of the downstream end of the apron should be equal to the elevation of the receiving 

channel or adjacent ground. 

 Alignment: The outer protection apron should be located so that there are no beds in 

the horizontal alignment. 

 Materials: The outlet protection can be accomplished using rock riprap or gabions. 

Riprap should be composed of a well-graded mixture of stone sized so that 50 percent 

of the pieces, by weight, should be larger than the size determined using charts. The 

minimum d50 size to be used should be 9 inches. A well-graded mixture is defined as 

a mixture composed primarily of larger stone sizes but with a sufficient mixture of 

other sizes to fill the smaller voids between the stones. The diameter of the largest 

stone in such a mixture should be two times the size selected in Table 7-21 (MDE 

1994). 
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 Thickness: Riprap specification values are summarized in Table 7-21. 

Table 7-21. Riprap sizes and thicknesses 

D50

(inches) 

D100

(inches) 

Thickness 

(inches) 

Class I 9.5 15 19 

Class II 16 24 32 

Class III 23 34 46 

 Source: USDOT 1995 

 Stone Quality: Stone for riprap should consist of field stone or rough-hewn quarry 

stone. The stone should be hard and angular and of a quality that will not disintegrate 

on exposure to water or weathering. The specific gravity of the individual stones 

should be at least 2.5. Recycled concrete equivalent can be used, provided it has a 

density of at least 150 pounds per cubic foot and does not have any exposed steel or 

reinforcing bars. 

 Filters: A layer of material placed between the riprap and the underlying soil surface 

can prevent soil movement into and through the riprap to prevent piping, reduce uplift 

pressure, and collect water. Riprap should have a filter placed under it in all cases. A 

filter can be of two general forms: a gravel layer or a geotextile. 

 Gabions: Gabion baskets can be used as rock outlet protection, provided they are 

made of hexagonal, triple-twist mesh with heavily galvanized steel wire. The 

maximum lined dimension of the mesh opening should not exceed 4.5 inches. The 

area of the mesh opening should not exceed 10 square inches. Gabions should be 

fabricated in such a manner that the sides, ends, and lid can be assembled at the 

construction site into a rectangular basket of the specified sizes. 

Gabions should be of a single-unit construction and installed according to the 

manufacturer’s specifications. Foundation conditions should be the same as for 

placing rock riprap. Geotextiles should be placed under all gabions, and gabions must 

be keyed in to prevent undermining of the main gabion structure. 

 The subgrade for the filter, riprap, or gabion should be prepared to the required lines 

and grades. Any fill required in the subgrade should be compacted to a density of 

approximately that of the surrounding undisturbed material. 

 The rock or gravel should conform to the specified grading limits when installed in 

the riprap or filter, respectively. 

 Geotextiles should be protected from punching, cutting, or tearing. Any damage other 

than occasional small holes should be repaired by placing another piece of geotextile 

fabric over the damaged part or by completely replacing the geotextile fabric. All 

overlaps, whether for repairs or for joining two pieces of geotextile fabric, should be a 

minimum of 1 foot in length. 

 Stone for the riprap or gabion outlets can be placed by equipment. They should be 

constructed to the full course thickness in one operation and in such a manner as to 

avoid displacement of underlying materials. Care should be taken to ensure that the 
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stone is not placed so that rolling would cause segregation of stone by size, i.e., the 

stone for riprap or gabion outlets should be delivered and placed in a manner that will 

ensure that it is reasonably homogeneous, with smaller stones filling the voids 

between larger stones. Riprap must be placed so as to prevent damage to the filter 

blanket or geotextile fabric. Hand placement will be required to the extent necessary 

to prevent damage to the permanent works. 

 Stone should be placed so that it blends in with the existing ground and the depth to 

the stone surface is sufficient to transmit the flow without spilling over onto the 

unprotected surface. 

Effectiveness 

No information is available on the effectiveness of rock outlet structures. 

Limitations 

Common problems with rock outlet structures include the following: 

 If the foundation is not excavated deeply or wide enough, the flow cross-section 

could be restricted, resulting in erosion around the apron and scour holes at the outlet. 

Also, the riprap apron should be placed on a suitable foundation to prevent 

downstream erosion. 

 If the riprap that is installed is smaller than specified, rock displacement might result; 

selectively grouting over the rock materials could stabilize the installation. 

 If the riprap is not extended enough to reach a stable section of the channel, 

downstream erosion could result. 

 If a filter is not installed under the riprap, stone displacement and erosion of the 

foundation might result. 

Maintenance 

Once a riprap outlet has been installed, the maintenance needs are very low. It should be 

inspected after high flows to see if scour has occurred beneath the riprap, if flows have occurred 

outside the boundaries of the riprap and caused scour, or if any stones have been dislodged. 

Repairs should be made immediately. 

Cost 

R.S. Means (2000) indicates machine-placed riprap costs of approximately $40 per cubic yard. 

For a riprap maximum size between 15 and 24 inches, a cubic yard of riprap will cover between 

13.5 and 17 square feet at channel bed (assuming depth of riprap as given in Table 5-22). This 

suggests that riprap lining will be between $21 and $27 per square foot of outlet (which includes 

materials, labor, and equipment, with overhead and profit). R.S. Means (2000) provides a cost 

range for gabions ($2.80 to $9 per square foot of coverage) for stone fill depths of 6 to 36 inches, 

respectively. Those costs include all costs of materials, labor, and installation. 
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7.2.4.3. Sump Pit 

Description 

A sump pit is a temporary pit from which pumping is conducted to remove excess water while 

minimizing sedimentation. The purpose of the sump pit is to filter water being pumped to reduce 

sedimentation to receiving streams. 

Applicability 

Sump pits are constructed when water collects and must be pumped away during excavating, 

cofferdam dewatering, maintenance or removal of sediment traps and basins, or other uses as 

applicable, such as for concrete wash out. 

Design and Installation Criteria 

Hydrologic Design 

The only hydrologic calculation is determining the expected flow rate and volume to be handled. 

That should follow standard hydrologic computational procedures based on design rainfall, 

surface and soil conditions, and the size of the pump. 

Installation Criteria and Specifications 

The number of sump pits and their locations should be determined by the designer and included 

on the plans. Contractors can relocate sump pits to optimize use, but discharge location changes 

should be coordinated with inspectors. 

A perforated, vertical standpipe should be wrapped with 1/2-inch hardware cloth and geotextiles 

and then placed in the center of an excavated pit, which is then backfilled with filter material 

ranging from clean gravel to stone. Water is then pumped from the center of the standpipe to a 

suitable discharge area such as into a sediment trap, sediment basin, or stabilized area. 

A sump pit should conform to the following specifications: 

 Pit dimensions are variable, with the minimum diameter being twice the diameter of 

the standpipe. 

 The standpipe should be constructed by perforating a 12- to 36-inch diameter pipe, 

then wrapping it with 1/2-inch hardware cloth and geotextiles. The perforations 

should be 1/2-inch slits or 1-inch diameter holes placed 6 inches on center. 

 The standpipe should extend 12 to 18 inches above the lip of the pit or riser crest 

elevation (basin dewatering), and filter material should extend 3 inches minimum 

above the anticipated standing water level. 

Effectiveness 

No information is available on the effectiveness of the sump pit. 

Limitations 

The sump pit must be properly maintained and pumped regularly to avoid clogging. 
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Maintenance 

To maintain performance, sump pits must be removed and reconstructed when water can no 

longer be pumped out of the standpipe. 

Cost 

R.S. Means (2000) provides information appropriate for assessing a wide range of dewatering 

scenarios (i.e., different sump sizes, dewatering durations, and discharge conditions). In general, 

installing earthen sump pits are listed as costing approximately $1.50 per cubic foot of sump 

volume. Piping to and away from the sump ranges from $30 to $60 per linear foot. Pump rentals 

and operation range between $150 and $500 per day of pumping, depending on the rate of 

dewatering. All costs include materials, labor, and equipment, with overhead and profit. 

7.2.4.4. Sediment Tank 

Description 

A sediment tank is a compartmented container through which sediment-laden water is pumped to 

trap and retain sediment before pumping the water to drainageways, adjoining properties, and 

rights-of-way below the sediment tank site. 

Applicability 

A sediment tank should be used on sites where excavations are deep and space is limited, such as 

urban construction, where direct discharge of sediment-laden water to streams and storm 

drainage systems should be avoided. 

Design and Installation Criteria 

The location of sediment tanks should facilitate easy cleanout and disposal of the trapped 

sediment to minimize interference with construction activities and pedestrian traffic. The tank 

size should be determined according to the storage volume of the sediment tank, with 1 cubic 

foot of storage for each gallon per minute of pump discharge capacity. 

Effectiveness 

No information is available on the effectiveness of sediment tanks. 

Limitations 

The sediment tank does not provide any natural infiltration; thus, the trapped sediment and 

stormwater must be disposed of properly. 

Maintenance 

To facilitate maintenance of sediment tanks, they need to be located with easy access for regular 

pump out. The rate at which a tank is pumped depends on site-specific considerations such as 

rainfall and sediment loads to the system. Regular inspections will help to determine pump out 

frequency and prevent overloading and failure of the system. 

Cost 

No information is available on the cost of sediment tanks. 
Section 7: Technology Assessment 

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7.2.4.5. Stabilized Construction Entrance 

Description 

The purpose of stabilizing entrances to a construction site is to minimize the amount of sediment 

leaving the area as mud attached to tires. Installing a pad of gravel over filter cloth where 

construction traffic leaves a site can help stabilize a construction entrance. As a vehicle drives 

over the gravel pad, mud and other sediments are removed from the vehicle’s wheels (sometimes 

by washing) and off-site transport of sediment is reduced. The gravel pad also reduces erosion 

and rutting on the soil beneath the stabilization structure. The fabric reduces the amount of 

rutting caused by vehicle tires by spreading the vehicle’s weight over a larger soil area than just 

the tire width. The filter fabric also separates the gravel from the soil below, preventing the 

gravel from being ground into the soil. 

Applicability 

Stabilized construction entrances typically are installed at locations where construction traffic 

leaves or enters an existing paved road. However, the applicability of site entrance stabilization 

should be extended to any roadway or entrance where vehicles will access or leave the site. 

From a public relations point of view, stabilizing construction site entrances can be a worthwhile 

exercise. If the site entrance is the most publicly noticeable part of a construction site, stabilized 

entrances can improve the appearance to passersby and improve public perception of the 

construction project by reducing the amount of mud tracked onto adjacent streets. 

Design and Installation Considerations 

Hydrologic Design 

Not applicable. 

Installation Criteria and Specifications 

All entrances to a site should be stabilized before construction begins and further disturbance of 

the site area occurs. The stabilized site entrances should be long enough and wide enough so that 

the largest construction vehicle that will enter the site will fit in the entrance with room to spare. 

If many vehicles are expected to use an entrance in a day, the site entrance should be wide 

enough for the passage of two vehicles at the same time with room on either side of each vehicle. 

For optimum effectiveness, a rock construction entrance should be at least 50 feet long and at 

least 10 to 12 feet wide (USEPA 1992). If a site entrance leads to a paved road, the end of 

entrance should be flared (made wider as in the shape of a funnel) so that long vehicles do not go 

off the stabilized area when turning onto or off of the paved roadway. 

If a construction site entrance crosses a stream, swale, roadside channel, or other depression, a 

bridge or culvert should be provided to prevent erosion from unprotected banks. 

Stone and gravel used to stabilize the construction site entrance should be large enough so that 

nothing is carried off-site with vehicle traffic. In addition, sharp-edged stone should be avoided 

to reduce the possibility of puncturing vehicle tires. Stone or gravel should be installed at a depth 

of at least 6 inches for the entire length and width of the stabilized construction entrance. 
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Effectiveness 

Stabilizing construction entrances to prevent sediment transport off-site is effective only if all 

entrances to the site are stabilized and maintained. Also, stabilizing construction site entrances 

might not be very effective unless a wash rack is installed and routinely used (Corish 1995), 

although that can be problematic for sites with multiple entrances that have high vehicle traffic. 

Limitations 

Although stabilizing a construction entrance is a good way to help reduce the amount of 

sediment leaving a site, some sediment can still be deposited from vehicle tires onto paved 

surfaces. To further reduce the chance that sediments will pollute stormwater runoff, sweeping of 

the paved area adjacent to the stabilized entrance is recommended. 

For sites using wash stations, a reliable water source to wash vehicles before leaving the site 

might not be initially available. In such a case, water might have to be trucked to the site at an 

additional cost. Discharge from the wash station should be directed to an appropriate sediment 

control structure. 

Maintenance 

Stabilization of site entrances should be maintained until the remainder of the construction site 

has been fully stabilized. Stone and gravel might need to be periodically added to each stabilized 

construction site entrance to maintain its effectiveness. Soil that is tracked off-site should be 

swept up immediately and disposed of properly. 

For sites with wash racks at each site entrance, sediment traps will have to be constructed and 

maintained for the life of the project. Maintenance will entail the periodic removal of sediment 

from the traps to ensure their continued effectiveness. 

Cost 

Without a wash rack, construction site entrance stabilization costs range from $1,000 to $4,000. 

On average, the initial construction cost is approximately $2,000 per entrance. When 

maintenance costs are included, the average total annual cost for a 2-year period is 

approximately $1,500. If a wash rack is included in the construction site entrance stabilization, 

the initial construction costs range from $1,000 to $5,000, with an average initial cost of $3,000 

per entrance. Total annual cost, including maintenance for an estimated 2-year life span, is 

approximately $2,200 per year (USEPA 1993). 

7.2.4.6. Land Grading 

Description 

Land grading involves reshaping the ground surface to planned grades as determined by an 

engineering survey, evaluation, and layout. Land grading provides more suitable topography for 

buildings, facilities, and other land uses and helps to control surface runoff, soil erosion, and 

sedimentation both during and after construction. 
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Applicability 

Land grading is applicable to sites with steep topography or easily erodible soils because it 

stabilizes slopes and decreases runoff velocity. Grading activities should maintain existing 

drainage patterns as much as possible. 

Design and Installation Criteria 

Before grading activities begin, decisions should be made regarding the steepness of cut-and-fill 

slopes and how the slopes will be protected from runoff, stabilized, and maintained. A grading 

plan should be prepared that establishes which areas of the site will be graded, how drainage 

patterns will be directed, and how runoff velocities will affect receiving waters. The grading plan 

also includes information regarding when earthwork will start and stop, establishes the degree 

and length of finished slopes, and dictates where and how excess material will be disposed of (or 

where borrow materials will be obtained if needed). Berms, diversions, and other stormwater 

practices that require excavation and filling should also be incorporated into the grading plan. 

One low-impact development technique that can be incorporated into a grading plan is site 

fingerprinting. This involves clearing and grading only those areas necessary for building 

activities and equipment traffic. Adhering to strict limits of clearing and grading helps to 

maintain undisturbed temporary or permanent buffer zones in the grading operation and provides 

a low-cost sediment control measure that will help reduce runoff and off-site sedimentation. The 

lowest elevation of the site should remain undisturbed to provide a protected stormwater outlet 

before storm drains or other construction outlets are installed. 

Effectiveness 

Land grading is an effective means of reducing steep slopes and stabilizing highly erodible soils 

when implemented with stormwater management and ESC practices in mind. Land grading is not 

effective when drainage patterns are altered or when vegetated areas on the perimeter of the site 

are destroyed. 

Limitations 

Construction sites are routinely graded to prepare a site for buildings and other structures. 

Improper grading practices that disrupt natural stormwater patterns can lead to poor drainage, 

high runoff velocities, and increased peak flows during storm events. Clearing and grading of the 

entire site without vegetated buffers promotes off-site transport of sediments and other 

pollutants. Grading plans should be designed with ESC and stormwater management goals in 

mind; grading crews should be carefully supervised to ensure that the plan is implemented as 

intended. 

Maintenance 

All graded areas and supporting ESC practices should be periodically checked, especially after 

heavy rainfalls. All sediment should be promptly removed from diversions or other stormwater 

conveyances. If washouts or breaks occur, they should be repaired immediately. Prompt 

maintenance of small-scale, eroded areas is essential to prevent them from becoming significant 

gullies. 
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Cost 

Land grading is practiced at virtually all construction sites—additional site planning to 

incorporate stormwater and ESCs in grading plans can require several hours of planning by a 

certified engineer or landscape architect. Extra time might be required to excavate diversions and 

construct berms, and fill materials might be needed to build up low-lying areas or fill 

depressions. 

Where grading is performed to manage on-site stormwater, R.S. Means (2000) suggests the cost 

of fine grading, soil treatment, and grassing to be approximately $2 per square yard of earth 

surface area. Shallow excavation/trenching (1 to 4 feet deep) with a backhoe in areas not 

requiring dewatering can be performed for $4 to $5 per cubic yard of removed material. Larger 

scale grading requires a site-specific assessment of an alternative grading apparatus and a 

detailed fill/excavation material balance to retain as much soil on site as possible. 

7.2.4.7. Temporary Access Waterway Crossing 

Description 

A temporary stream crossing is a structure erected to provide a safe and stable way for 

construction vehicle traffic to cross a running watercourse. The primary purpose of such a 

structure is to provide streambank stabilization, to reduce the risk of damaging the streambed or 

channel, and to reduce the risk of sediment loading from construction traffic. A temporary stream 

crossing could be a bridge, culvert, or ford. 

Applicability 

Temporary stream crossings are applicable wherever heavy construction equipment must be 

moved from one side of a stream channel to the other or where lighter construction vehicles will 

cross the stream a number of times during the construction period. In either case, an appropriate 

method for ensuring the stability of the streambanks and preventing large-scale erosion is 

necessary. 

A bridge or culvert is the best choice for most temporary stream crossings. If properly designed, 

each can support heavy loads, and materials used to construct most bridges and culverts can be 

salvaged after they are removed. Fords are appropriate in steep areas subject to flash flooding, 

where normal flow is shallow or intermittent across a wide channel. Fords should be used only 

where stream crossings are expected to be infrequent. 

Design and Installation Criteria 

Because of the potential for stream degradation, flooding, and safety hazards, stream crossings 

should be avoided on a construction site whenever possible. Consideration should be given to 

alternative site access routes before arrangements are made to erect a temporary stream crossing. 

If it is determined that a stream crossing is necessary, an area where the potential for erosion is 

low should be selected. The stream crossing structure should be installed during a dry period if 

possible to reduce sediment transport into the stream. 

If needed, over-stream bridges are generally the preferred temporary stream crossing structure. 

The expected load and frequency of the stream crossing, however, will govern the selection of a 
Section 7: Technology Assessment 

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bridge as the correct choice for a temporary stream crossing. Temporary bridges usually cause 

minimal disturbance to a stream’s banks and cause the least obstruction to stream flow and fish 

migration. They should be constructed only under the supervision and approval of a qualified 

engineer. 

As general guidelines for constructing temporary bridges, clearing and excavation of the stream 

shores and bed should be kept to a minimum. Sufficient clearance should be provided for 

floating objects to pass under the bridge. Abutments should be parallel to the stream and be 

placed on stable banks. If the stream is less than 8 feet wide at the point where a crossing is 

needed, no additional in-stream supports should be used. If the crossing is to extend across a 

channel wider than 8 feet (as measured from the top of one bank to the other), the bridge should 

be designed with one in-water support for each 8 feet of stream width. 

A temporary bridge should be anchored by steel cable or chain on one side only to a stable 

structure on shore. Examples of anchoring structures include trees with a large diameter, large 

boulders, and steel anchors. By anchoring the bridge on one side only, there is a decreased risk of 

causing a downstream blockage or flow diversion if a bridge is washed out. 

When constructing a culvert, filter cloth should be used to cover the streambed and streambanks 

to reduce settlement and improve the stability of the culvert structure. The filter cloth should 

extend a minimum of 6 inches and a maximum of 1 foot beyond the end of the culvert and 

bedding material. The culvert piping should not exceed 40 feet in length and should be of 

sufficient diameter to allow for complete passage of flow during peak flow periods. The culvert 

pipes should be covered with a minimum of 1 foot of aggregate. If multiple culverts are used, at 

least 1 foot of aggregate should separate the pipes. 

Fords should be constructed of stabilizing material such as large rocks. 

Effectiveness 

Both temporary bridges and culverts provide an adequate path for construction traffic crossing a 

stream or watercourse. 

Limitations 

Bridges can be considered the greatest safety hazard of all temporary stream crossing structures 

if not properly designed and constructed. Bridges can also prove to be more costly in terms of 

repair costs and lost construction time if they wash out or collapse (Smolen et al. 1988). 

The construction and removal of culverts are usually very disturbing to the surrounding area, and 

erosion and downstream movement of sediments are often great. Culverts can also create 

obstructions to flow in a stream and inhibit fish migration. Depending on their size, culverts can 

be blocked by large debris and are therefore vulnerable to frequent blockage and washout. 

If given a choice between building a bridge or a culvert as a temporary stream crossing, a bridge 

is preferred because of the relative minimal disturbance to streambanks and the opportunity for 

unimpeded flow through the channel. The approaches to fords often have high erosion potential. 

In addition, excavating the streambed and approach to lay riprap or other stabilization material 
Section 7: Technology Assessment 

7-80 

causes major stream disturbance. Mud and other debris are transported directly into the stream 

unless the crossing is used only during periods of low flow. 

Maintenance 

Temporary stream crossings should be inspected at least once a week and after all significant 

rainfall events. If any structural damage is reported to a bridge or culvert, construction traffic 

should be excluded until appropriate repairs are made. Streambank erosion should be repaired 

immediately. 

Fords should be inspected closely after major storm events to ensure that stabilization materials 

remain in place. If the material has moved downstream during periods of peak flow, the lost 

material should be replaced immediately. 

Cost 

In general, temporary bridges are more expensive to design and construct than culverts. Bridges 

are also associated with higher maintenance and repair costs should they fail. Temporary 

bridging costs vary as a function of the width of the bridge span and the amount of time the 

bridge is installed. If the bridging is permanent, a mean cost of $50 per square foot for an 8-foot 

wide steel arch bridge (no foundation costs included) can be used for conceptual cost estimation 

(R.S. Means 2000). If rental bridging is employed, rates are probably on the order of 20 to 50 

percent of the bridge (permanent) cost but will vary according to the rental duration and 

mobilization distance. 

7.2.4.8. Dust Control 

General Description 

Dust control measures are practices that help reduce ground surface and air movement of dust 

from disturbed soil surfaces. Construction sites are good candidates for dust control measures 

because land disturbance from clearing and excavation generates a large amount of soil 

disturbance and open space for wind to pick up dust particles. To illustrate this point, research at 

construction sites has established an average dust emission rate of 1.2 tons/acre/month for active 

construction (WDEC 1992). These airborne particles pose a dual threat to the environment and 

human health. First, dust can be carried off-site, thereby increasing soil loss from the 

construction area and increasing the likelihood of sedimentation and water pollution. Second, 

blowing dust particles can contribute to respiratory health problems and create an inhospitable 

work environment. 

Applicability 

Dust control measures are applicable to any construction site where dust is created and there is 

the potential for air and water pollution from dust traveling across the landscape or through the 

air. Dust control measures are particularly important in arid or semiarid regions where soil can 

become extremely dry and vulnerable to transport by high winds. 

Also, dust control measures should be implemented on all construction sites where there will be 

major soil disturbances or heavy construction activity, such as clearing, excavation, demolition, 

or excessive vehicle traffic. Earthmoving activities are the major source of dust from 
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construction sites, but traffic and general disturbances can also be major contributors (WDEC 

1992). 

The specific dust control measures implemented at a site will depend on the topography, land 

cover, soil characteristics, and amount of rainfall at the site. 

Design and Installation Criteria 

When designing a dust control plan for a site, the amount of soil exposed will dictate the quantity 

of dust generation and transport. Therefore, construction sequencing and disturbing small areas 

at one time can greatly reduce problematic dust from a site. If land must be disturbed, additional 

temporary stabilization measures should be considered before disturbance. 

A number of methods can be used to control dust from a site. The following is a brief list of 

control measures and their design criteria. Not all control measures will be applicable to a site. 

The owner, operator, and contractors responsible for dust control should determine which 

practices accommodate their needs on the basis of specific site and weather conditions. 

Sprinkling/Irrigation: Sprinkling the ground surface with water until it is moist is an effective 

dust control method for haul roads and other traffic routes (Smolen et al. 1988). This practice can 

be applied to almost any site. 

Vegetative Cover: In areas not expected to handle vehicle traffic, vegetative stabilization of 

disturbed soil is often desirable. Vegetative cover provides protection to surface soils and slows 

wind velocity at the ground surface, thus reducing the potential for dust to become airborne. 

Mulch: Mulching can be a quick and effective means of dust control for a recently disturbed 

area (Smolen et al. 1988). 

Wind Breaks: Wind breaks are barriers (either natural or constructed) that reduce wind velocity 

and therefore reduce the possibility of carrying suspended particles. Wind breaks can be trees or 

shrubs left in place during site clearing or constructed barriers such as a wind fence, snow fence, 

tarp curtain, hay bale, crate wall, or sediment wall (USEPA 1992). 

Tillage: Deep tillage in large open areas brings soil clods to the surface where they rest on top of 

dust, preventing it from becoming airborne. 

Stone: Stone can be an effective dust deterrent for construction roads and entrances. 

Spray-on Chemical Soil Treatments (palliatives): Examples of chemical adhesives include 

anionic asphalt emulsion, latex emulsion, resin-water emulsions, and calcium chloride. Chemical 

palliatives should be used only on mineral soils. When considering chemical application to 

suppress dust, consideration should be taken as to whether the chemical is biodegradable or 

water-soluble and what effect its application could have on the surrounding environment, 

including waterbodies and wildlife. 
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Table 7-22 shows application rates for some common spray-on adhesives as recommended by 

Smolen et al. (1988). 

Table 7-22. Application rates for spray-on adhesives 

Spray on adhesive Water dilution Type of nozzle 

Application 

(gal/acre) 

Anionic Asphalt Emulsion 7:1 Coarse spray 1,200 

Latex Emulsion 12.5:1 Fine spray 235 

Resin in Water 4:1 Fine spray 300 

Source: Smolen et al. 1988. 

Effectiveness 

Sprinkling/Irrigation: Not available. 

Vegetative Cover: Not available. 

Mulch: Mulch can reduce wind erosion by up to 80 percent. 

Wind Breaks/Barriers: For each foot of vertical height, an 8- to 10-foot deposition zone develops 

on the leeward side of the barrier. The barrier density and spacing will change its effectiveness at 

capturing windborne sediment. 

Tillage: Roughening the soil can reduce soil losses by approximately 80 percent. 

Stone: The sizes of the stone can affect the amount of erosion that will take place. In areas of 

high wind, small stones are not as effective as 20-cm stones. 

Spray-on Chemical Soil Treatments (palliatives): Effectiveness of polymer stabilization methods 

ranges from 70 to 90 percent. 

Limitations 

In areas where evaporation rates are high, water application to exposed soils could require near 

constant attention. If water is applied in excess, runoff can result from the site and possibly 

create conditions where vehicles can track mud onto public roads. 

Chemical applications should be used sparingly and only on mineral soils (not high organic 

content soils) because their misuse can create additional surface water pollution from runoff or 

can contaminate ground water if infiltrated. Chemical applications can also present a health risk 

if excessive amounts are used. 

Maintenance 

Because dust controls are dependent on specific site conditions including the weather, inspection 

and maintenance are unique for each site. Generally, however, dust control measures involving 

application of either water or chemicals require more monitoring than structural or vegetative 

controls to remain effective. If structural controls are used, they should be inspected for 

deterioration regularly to ensure that they are still achieving their intended purpose. 
Section 7: Technology Assessment 

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Cost 

Chemical dust control measures can vary widely in cost depending on specific needs of the site 

and level of dust control desired. One manufacturer of a chloride product estimates a cost of 

$1,089 per acre for application to road surfaces but cautioned that cost estimates without a 

specific site evaluation can be inaccurate. 

7.2.4.9. Storm Drain Inlet Protection 

Description 

Storm drain inlet protection measures are controls that help prevent soil and debris from on-site 

erosion from entering storm drain inlets. Typically, such measures are temporary controls that 

are implemented before large-scale disturbance of the surrounding site. The controls are 

advantageous because their implementation allows storm drains to be used during even the early 

stages of construction activities. The early use of storm drains during project development 

significantly reduces the occurrence of future erosion problems (Smolen et al. 1988). 

Three temporary control measures to protect storm drain drop inlets are as follows: 

 Excavation around the perimeter of the drop inlet 

 Fabric barriers around inlet entrances 

 Block and gravel protection 

Excavation around a storm drain inlet creates a settling pool to remove sediments. Weep holes 

protected by gravel are used to drain the shallow pool of water that accumulates around the inlet. 

A filter fabric barrier erected around an inlet can create an effective shield to sediment while 

allowing water to flow into the storm drain. This type of barrier can slow runoff velocity while 

catching soil and other debris at the drain inlet. Block and gravel inlet protection uses standard 

concrete blocks and gravel to form a barrier to sediments while permitting water runoff through 

select blocks that are laid sideways. In addition to these materials, limited temporary stormwater 

drop inlet protection can also be achieved using straw bales or sandbags to create barriers to 

sediment. 

For permanent storm drain drop inlet protection after the surrounding area has been stabilized, 

sod can be installed as a barrier to slow stormwater entry to the inlets and capture sediments 

from erosion. This final inlet protection measure can be used as an aesthetically pleasing way to 

slow stormwater velocity near drop inlet entrances and remove sediments and other pollutants 

from runoff. 

A new technology that uses an insert trap into the inlet itself has been developed (Adams et al. 

2000). The technique shows good results on initial tests, trapping more than 50 percent of the 

incoming sediment in flows typical of those into urban storm drains. The technique is being 

further developed with a pending patent application. 

Applicability 

All temporary controls should have a drainage area no greater than 1 acre of drainage area per 

inlet. It is also important for temporary controls to be constructed before disturbing the 
Section 7: Technology Assessment 

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surrounding landscape. Excavated drop inlet protection and block and gravel inlet protection are 

applicable to areas of high flow where overflow is anticipated into the storm drain. Fabric 

barriers are recommended for smaller, relatively flat drainage areas (slopes less than 5 percent 

leading to the storm drain). 

Temporary drop inlet control measures are often used in combination with each other and with 

other stormwater control techniques. 

Design and Installation Considerations 

Hydrologic Design 

Hydrologic computations are not necessary with present technologies. A specified limitation of 

one drainage acre per inlet limits flow rates, depending on local rainfall and runoff 

considerations. 

Installation Criteria and Specifications 

The following criteria should be followed until future research establishes better techniques: 

 With the exception of sod drop inlet protection, these controls should be installed 

before any soil disturbance in the drainage area. 

 Excavation around drop inlets should be dug a minimum of 1 foot deep (2 feet 

maximum) with a minimum excavated volume of 35 cubic yards per acre disturbed. 

Side slopes leading to the inlet should be no steeper than 2:1. The shape of the 

excavated area should be designed such that the dimensions fit the area from which 

stormwater is anticipated to drain. For example, the longest side of an excavated area 

should be along the side of the inlet expected to drain the largest area. 

 Fabric inlet protection is essentially a filter fence placed around the inlet. The fabric 

should not be used as a standalone sediment control measures. To increase inlet 

protection effectiveness, these practices should be used in combination with other 

measures, such as small impoundments or sediment traps (USEPA 1992). Temporary 

storm drain inlet protection is not intended for use in drainage areas larger than 1 

acre. Generally, stormwater inlet protection measures are practical for relatively low 

sediment and low volume flows. 

 Frequent maintenance of storm drain controls is necessary to prevent clogging. If 

sediment and other debris clog the water intake, drop intake control measures can 

actually cause erosion in unprotected areas. 

Maintenance 

All temporary control measures must be checked after each storm event. To maintain the 

sediment capacity of the shallow settling pools created from these techniques, accumulated 

sediment should be removed from the area around the drop inlet (i.e., from the excavated area, 

around the fabric barrier, or around the block structure) when the sediment storage is reduced by 

approximately 50 percent. Additional debris should be removed from the shallow pools 

periodically. 
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7-85 

Weep holes in excavated areas around inlets can become clogged and prevent water from 

draining from the shallow pools that form. Should this happen, unclogging the water intake can 

be difficult and costly. 

Cost 

The cost of implementing storm drain drop inlet protection measures will vary depending on the 

control measure chosen. Generally, initial installation costs range from $50 to $150 per inlet, 

with an average cost of $100 (USEPA 1993). Maintenance costs can be high (annually, up to 100 

percent of the initial construction cost) because of frequent inspection and repair needs. The 

SWRPC has estimated that the cost of installing inlet protection devices ranges from $106 to 

$154 per inlet (SWRPC 1991). 

7.2.4.10. Polyacrylamide (PAM) 

General Description 

The term polyacrylamide (PAM) is a generic term that refers to a broad class of compounds. 

There are hundreds of specific PAM formulations, and all have unique properties that depend on 

polymer chain length and number and kinds of functional group substitutions along the chain. 

PAMs are classified according to their molecular weight and ionic charge and are available in 

solid, granular, liquid, or emulsion forms. 

The effectiveness of PAMs to prevent or reduce erosion is due to its affinity for soil particles, 

largely via coulombic and Van der Waals attraction. Such surface attractions enhance particle 

cohesion, stabilizing soil structure against shear-induced detachment and transport in runoff. In a 

soil application, PAM aggregates soil particles, increasing pore space and infiltration capacity 

and resulting in reduced runoff. The larger particle aggregates are less susceptible to raindrop 

and scour erosion, thus reducing the potential to mobilize sediments. 

Applicability 

Because of ease in application, PAM is well suited as a short-term erosion prevention BMP, 

especially for areas with limited access or steep slopes that hinder personnel from applying other 

cover materials. PAM can be used to augment other cover practice BMPs, though it can be 

effective when applied alone. Thus, the ease of application, low maintenance, and relatively low 

cost associated with PAM make it a practical solution to soil stabilization during construction. 

Application Criteria 

PAM can be applied to soil through either a dry granular powder or a liquid spray form. Optimal 

application rates to prevent erosion on construction sites are generally less than 1 kg/ha 

(approximately 1 lb/ac) (Tobiason et al. 2000). However, the concentration required can vary for 

specific soil properties and construction phases. WDOT (2002) suggests a dosage of 60 mg/L for 

roadway ESC. This is higher than the rate recommended by the University of Nebraska for an 

agricultural application (10 parts per million). To put this into context, one-half pound of PAM 

in 1,000 gallons of water results in a PAM concentration of 60 mg/L, which treats 1 acre of 

exposed soil, according to WDOT recommendations. 
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Effectiveness 

A study performed in Dane County, Wisconsin, analyzed 15-meter-square plots for runoff and 

sediment yield on a construction site. The study concludes that when a solution of PAM-mix 

with mulch/seeding is applied to dry soil and compared with the control (no PAM-mix 

application to dry soil), the PAM-mix has an average reduction of 93 percent in sediment yield. 

The lowest performance (average reduction in sediment yield of 77 percent) occurred when 

PAM-mix in solution was applied to moist soil. The application of dry PAM-mix to dry soil 

reduced sediment by 83 percent and decreased runoff by 16 percent when compared to the 

control. The results show that regardless of the application method, PAM-mix is effective in 

reducing sediment yield in the test plots (Roa-Espinosa et al. 2000). 

A second study performed in Washington analyzed the runoff from three different construction 

sites: an erosion control test facility, a highway construction site, and an airport runway. Table 

7-23 summarizes the 225 samples analyzed by Tobiason et al. (2000). 

Table 7-23. Turbidity reduction values from PAM 

 Volume 

(m3

) 

Turbidity reduction 

(%) 

Maximum 350 99.97% 

Median 285 97.6% 

Minimum 133 46% 

Limitations 

PAMs are most commonly produced as dry granules. They completely dissolve and remain 

dissolved if mixed properly. If added too quickly or if not stirred vigorously, the granules rapidly 

form nondissolvable gels on contact with water or collect in low turbulence areas as syrupy 

concentrations that dissolve slowly in an uncontrolled pattern over a period of hours or days 

(Sojka and Lentz 1994). In addition, when spilled on hard surfaces, PAM solutions are extremely 

slippery and hazardous to foot and vehicle traffic. PAM dust is highly hygroscopic and, if 

inhaled, could impair breathing. Certain neutral and cationic PAMs at very high exposure levels 

produce irritation in humans and are somewhat toxic to certain aquatic organisms; therefore, 

PAM should be used in strict compliance with state and federal label requirements. 

Cost 

The cost of PAM ranges from $1.25 per pound to $5.00 per pound (Entry and Sojka 1999). The 

cost of PAM application depends on the system employed. If dispersed through irrigation 

systems (for agriculture), the seasonal cost of PAM treatment is $9 to $15 per acre 

(Kay-Shoemake et al. 2000), where a season probably requires between 5 and 10 applications. 

For construction sites, it is more likely that PAM would be applied as an additive to the 

hydroseed mix and applied when final grade is established and cover vegetation is installed. 

Numerous suppliers provide PAM as a low-cost additive for hydroseeding, suggesting PAM 

application costs can be incorporated into that of hydroseeding ($540 to $700 per acre depending 

on which seed is applied). An additional cost would be incurred to sample site soils to customize 

the dosage and delivery mechanisms for individual sites. In addition, reapplication of PAM in 

granular or liquid form to areas with rill development (poor vegetation cover) would require 
Section 7: Technology Assessment 

7-87 

additional funds. Where reapplication of granular PAM is used, R.S. Means (2000) suggests a 

cost of approximately $5 per 1,000 square feet for spreading soil admixtures by hand. 

7.2.5. ADVANCED TREATMENT AND CONTROL TECHNOLOGIES 

7.2.5.1. Active Treatment Systems (ATS) Technologies 

EPA researched technologies available for treating construction stormwater runoff, with the 

specific goal of identifying technologies that could reliably meet a low-effluent turbidity limit. 

EPA primarily identified active treatment systems (ATS) that use coagulation/flocculation and 

filtration for treating stormwater runoff from active construction sites as the most reliable 

technology for meeting a low (i.e., less than 10 NTUs) effluent limit. Technologies used at 

construction sites to control suspended sediment and turbidity in stormwater runoff from 

discharging typically include erosion control, storage/containment, gravitational settling, 

chemical treatment (i.e., coagulation/flocculation), and filter media. For an ATS to be effective, 

many (if not all) of the abovementioned treatment technologies need to be incorporated into an 

ATS before treated effluent discharge. This section provides an ATS process description and 

costs and discusses applicability, demonstration status, and limitations. Treatment chemical 

addition and filtration are separately discussed in detail in subsequent sections. 

ATS Process Description and Costs 

EPA assumed that the key components of an ATS would include the following: 

 On-site storage by using a combination of sediment basins, tanks or other 

impoundments 

 Chemical addition (see Section 7.2.5.2 ) 

 Mix tank/clarification tank and/or basin 

 Media filtration (see Section 7.2.5.3) 

 Instrumentation (e.g., monitoring of influent and effluent) 

The ATS capital costs include purchased (or leased) equipment cost, including ancillary 

equipment (e.g., piping, valves, and controllers), delivery cost, and installation/construction cost 

(including labor and site work). The ATS annual (operation and maintenance) costs include 

treatment chemicals, operating labor and material, maintenance labor and material, energy, waste 

disposal, monitoring, and rented equipment. 

The ATS are typically equipped with automated instrumentation to monitor water quality, flow 

rate, and dosage control for both influent and effluent flows. Following the 

coagulation/flocculation process, the densified floc is settled out via gravitational settling, 

skimming, or media filtration (e.g., sand, gravel, bag filters). 

EPA determined that some vendors offer gel socks containing treatment chemical, often for 

pretreatment of stormwater runoff. For example, the StormKlear Gel-FlocTM is a fabric sock 

containing a flake form of chitosan that slowly dissolves as the influent stormwater flows over it. 

The gel sock is typically anchored within the influent pipe of the ATS. 
Section 7: Technology Assessment 

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An ATS can be in either a batch or flow-through design, as described in Table 7-24. The ATS 

design depends on factors including existing structures (e.g., detention basins, storm sewer 

systems, sump areas), influent turbidity, flow rate, and space limitations. Clear Creek Systems, 

Inc., in a comment letter to the California State Water Resources Control Board (Gannon 2007) 

regarding the draft construction general permit, stated that “Batch treatment is a relatively 

outdated and inefficient method of operations.” 

Table 7-24. ATS operating modes 

Operation mode Description 

Batch (Pump-Treat-Hold-Test 

Release) 

Stormwater runoff is collected, stored or contained in a basin or tank until 

treatment is complete before discharging. 

Flow-through or continuous 

treatment 

Involves pumping stormwater runoff from a collection, storage or 

containment basin, treating the water, and directly discharging. 

Source: ATS Industry Task Force 2007. 

Figure 7-1 presents a general ATS batch operating mode process diagram. The batch treatment 

process incorporates a period for treatment in a settling, mixing, or holding tank(s) before 

discharge. This is different from the continuous flow or flow-through treatment process in which 

treatment and discharge occurs continuously. Figure 7-2 shows an ATS using continuous mode. 

Figure 7-1. General ATS batch-operating mode 
Section 7: Technology Assessment 

7-89 

Figure 7-2. Flow-through ATS operating mode 

ATS Applicability 

The ATS is well suited as a method of runoff control when traditional BMPs are not capable of 

meeting numeric standards. ATS provides quick and efficient removal of fine-grained, 

suspended sediment or colloidal particles and can be custom tailored for site-specific 

requirements. Gravitational settling of fine or colloidal soil particles can have limited 

effectiveness and might not be completed in a timely manner. Therefore, ATS could be 

necessary to enhance small particulate solids removal and minimize project timelines and costs. 

The ATS can minimize potential adverse environmental effects on receiving water through 

automated water quality measurements. ATS generally produces very low turbidity values (often 

< 10 NTUs) in the effluent discharge. 

The vendors contacted by EPA stated that ATS were typically meeting discharge standards of 

10 NTU or less. Therefore, ATS would work well for a low-NTU standard. Vendors reported 

little cost savings in designing an ATS for higher, less stringent, NTU limits (e.g., 50, 100, 150, 

200, 250 NTU). 

Demonstration Status 

EPA determined from information obtained from vendor calls that ATS using chemical treatment 

with polymer coagulation/flocculation is prevalent in the industry. The majority of the vendors 

contacted are using the polymer chitosan in conjunction with gravitational settling and filtration 

for treating stormwater runoff. EPA did not obtain information on how many of the systems are 
Section 7: Technology Assessment 

7-90 

batch or flow-through treatment systems. The polymer Diallydimethyl-ammonium chloride 

(DADMAC) is also used frequently by vendors. Following the chemical treatment, media 

filtration is commonly used. Sand filters in combination with small-micron (e.g., 0.5) particulate 

filters appeared to be the media of choice by many of the vendors for removing the floc material 

and polishing. However, bag and cartridge filters are also being used either as a standalone 

treatment or in combination with the sand filters for treatment purposes. Many of the treatment 

technologies used are very site-specific according to the water quality (i.e., turbidity, chemical 

composition) and footprint available. 

The vendors contacted have implemented ATS primarily in the west (California, Oregon, and 

Washington). Washington State’s Department of Ecology (WDEC) has a new technology 

evaluation program in which vendors complete a Chemical Technology Assessment Protocol—

Ecology (CTAPE) for new and emerging technologies. Following a performance evaluation, 

vendors may receive a conditional use designation (CUD) or a general use level designation 

(GULD) for a particular chemical treatment technology. For construction sites, WDEC has 

approved conditional use or general use designations for Chitosan-enhanced sand filtration using 

StormKlearTM LiquiflocTM, FlocClearTM, and ChitovanTM chemical treatments. Table 7-25 shows 

known or draft state ATS requirements or recommendations at the time of this writing. 

Table 7-25. ATS state requirements/recommendations 

State ATS requirements and/or recommendations 

California The 2009-0009-DWQ Construction General Permit, effective July 1, 2010, provides specific 

requirements for dischargers who choose to use an ATS, including numeric effluent limits 

(NELs) and design to capture and treat a volume equivalent to the runoff from a 10-year, 

24-hour storm event in a 72-hour period with a runoff coefficient of 1.0. 

The NELs for discharges from an ATS include the following: 

o Turbidity less than 10 NTU (for daily flow-weighted average) and 20 NTU (for any single 

sample) 

o Residual chemical must be less than 10% of the maximum allowable threshold 

concentration for the most sensitive species of the chemical used 

Complete ATS requirements are presented in Attachment F to the permit (see DCN 43115). 

Oregon Mr. Dennis Jurries with the Oregon Department of Environmental Quality (DEQ) stated that 

ATS is not required; however, for sites with difficulty reaching water quality standards, it is 

recommended that a chitosan-enhanced sand filtration treatment be implemented. 

Water Quality Requirements 

If discharging to a 303(d) listed waterbody or a waterbody with a TMDL for sediment and 

turbidity, sampling for turbidity is required to meet a 160-NTU benchmark. If unable to meet 

benchmark, an Action Plan using a BMP such as water treatment using electro-coagulation, 

chemical flocculation or filtration must be implemented. 
Section 7: Technology Assessment 

7-91 

State ATS requirements and/or recommendations 

Washington BMP C250 Construction Storm Water Chemical Treatment states that formal, written 

approval from the Department of Ecology is required for using chemical treatment regardless 

of site size. Through the use of the Washington CTAPE, new technology evaluation program, 

the following have been accepted with use designations: 

o Construction Site Treatment Technologies 

o Chitosan-Enhanced Sand Filtration Using StormKlearTM LiquiFlocTM (GULD) 

o Chitosan-Enhanced Sand Filtration Using FlocClearTM(GULD and CUD) 

o Chitosan Enhanced Sand Filtration Using ChitoVanTM (CULD and GULD) 

o Water Tectonics Electrocoagulation Subtractive Technology (CUD) 

o GULD—General Use Level Designation 

o CUD—Conditional Use Designation 

Water Quality Requirements 

Turbidity shall be no more than 5 NTU over background (if background is 50 NTU or less), or 

no more than 10% over background (if background is 50 NTU or greater). Sites that disturb 

more than 1 acre are required to sample for turbidity. Turbidity exceeding the benchmark of 

25 NTU but less than 250 NTU requires BMP and SWPPP review, and additional treatment if 

three consecutive days exceed the benchmark. Turbidity exceeding 250 NTU requires 

notifying the Department of Ecology and additional treatment. 

ATS Limitations 

Treatment chemicals must have the proper dose and contact time to avoid potential toxicity in 

effluent discharges. Many of the polymers used in ATS precipitate only in a designated pH range 

(e.g., 6.5 to 8.5). 

ATS Costs 

EPA obtained ATS costs (i.e., chitosan-enhanced sand filtration) from three vendors. The ATS 

costs associated with treating active construction site stormwater runoff, as provided by vendors, 

is included in Table 7-26. For estimating compliance costs for the regulatory options that 

incorporate ATS, EPA determined system flowrate for the various model projects and estimated 

equipment rental costs, operating costs and other ancillary costs using the data supplied by Rain 

for Rent. EPA also added costs for providing storage for impounding runoff from the 2-year/24-

hour storm event as an approximation of the additional costs for storage that might be required 

on-site. Additional details of this analysis are in the ATS Cost Spreadsheet Model (DCN 43119). 

The costs associated with ATS vary by site-specific factors such as turbidity, available footprint 

area for basins or equipment, effluent discharge requirements, and the like. In addition to the data 

provided by vendors, EPA obtained cost data on specific projects incorporating ATS from 

several reports. Table 7-27 summarizes ATS costs for a number of case studies reflecting 

varying site sizes and different system configurations. 

For additional details on ATS and on ATS costing, see DCNs 43000 through 43011, DCNs 

41130 and 41131, and Section 9. 
Section 7: Technology Assessment 

7-92 

Table 7-26. Summary of vendor costs 

Cost type 

Cost 

(2008 dollars) Source 

Total Cost Large Site $0.005/gal 

Small Site $0.01/gal 

StormKlear 

Total Cost Large/Small $0.01–0.03/gal Clear Water 

Labor Large Site $1,250/Mgal 

Small Site $5,000/Mgal 

Chemical All Sites $1,000–$8,000/Mgal 

10-acre Site $130,000 

50-acre Site $250,000 

Equipment Rental 

(18 month rental) 

100-acre Site $500,000 

Clear Creek 

Media Filter $4,000/month 

System $4,000/month 

2 Pumps $3,300/month 

2 Tanks $2,520/month 

4 Hoses $392/month 

2 Elbows $72/month 

Generator $1,050/month 

Sand and Gravel $1,222 

Mobilization/Demobilization $2,970 

System Calibration $1,300 

Pipes, valves, and electrical $6,000 

Install pipes, valves, and 

electrical $7,500 

Misc. lab equipment and supplies $4,250 

Fuel 

500-gpm system. 

16 acres @ 24 

inches of rainfall 

during 6-month 

project period 

(10,248,192 

gallons). 

10 gallons/hour 

Rain for Rent 

Table 7-27. Summary of ATS case studies 

Project Type of ATS* 

Approximate 

treated 

volume 

Project 

duration 

(months) 

Project size 

(acres) Cost per gallon 

City of Redmond CESF 1 million 

gallons 

2.5 32 $10.22 per thousand 

gallons 

City of Redmond 

(2 sites) 

Electrocoagulation 6.2 million 

gallons 

Unknown 8 and 23 

acres 

$5.83 and $8.00 per 

thousand gallons 

Confidential 

Builder Project #1 

CESF ~ 100 million 

gallons 

Unknown > 500 $16.00 per thousand 

gallons 

Confidential 

Builder Project #2 

DADMAC ~ 15 million 

gallons 

 ~ 300 acres $36.00 per thousand 

gallons 

*CESF = Chitosan-Enhanced Sand Filtration, DADMAC = Diallyldimethyl Ammonium Chloride 

McLaughlin (2008) noted that less complex systems (e.g., introducing a polymer such as PAM 

into a pump intake followed by a sediment basin) can reduce chemical cost and might not require 

media filtration (compared to active chitosan systems). McLaughlin (2008) also noted that small 

quantities of water could be treated with polymer introduced into the pump intake and pumped 

through geotextile sediment bags. 
Section 7: Technology Assessment 

7-93 

7.2.5.2. ATS Coagulation/Flocculation 

The effective design of an ATS relies heavily on an analysis of site conditions (e.g., land use, 

soils, toxins, water chemistry, flowrate, receiving water chemistry). Coagulants and flocculants 

function as the primary treatment process used in ATS. Treatment chemical addition to influent 

stormwater runoff is to destabilize the suspended particles by various mechanisms, aggregating 

into larger particles that are easier to remove through settling or filtering. Coagulation is the 

reduction of the net electrical repulsive forces at particle surfaces by adding coagulating 

chemicals, whereas flocculation is the agglomeration of the destabilized particles by chemical 

joining and bridging. 

The coagulants/flocculants are typically added to the influent via an injection pump in a metered 

dose just upstream of the clarifier tank or basin. The treatment chemicals are allowed to mix to 

maximize the formation of a dense floc. Proper dosing of the treatment chemicals is critical to 

minimize toxicity, maximize system efficiency, and ensure proper effluent water quality. The 

optimum dose is very site-specific (e.g., varying with changing types of soils, flow rate) and 

should be based on a series of jar tests. 

Water treatment chemicals are predominately water soluble and classified as cationic (positively 

charged), anionic (negatively charged), nonionic (neutral), or amphoteric (changeable depending 

on the pH of water). Table 7-28 lists common coagulants, regulatory status, and available 

residual tests. Several of these common coagulants and toxicity information are discussed below. 

Table 7-28. Examples of some commonly available coagulants 

Coagulant Chitosan PAC DADMAC PAM PASS Alum 

Description 

Chitosan 

acetate 

based 

cationic 

biopolymer 

Polyaluminum 

chloride 

Diallyldimethylammonium 

chloride 

Polyacrylamide 

Polyaluminum 

chloride 

Silica/sulfate 

modified 

Aluminum 

sulfate 

Regulatory status Approved in 

Washington N/A N/A 

Approved in 

Florida, New 

Hampshire 

N/A Approved 

in Florida 

Approved dosage 

(or dosage where 

no toxic effects 

are observed) 

N/A N/A N/A 

Florida has no limit

New Hampshire 

has limit of onehalf of NOECb

 or 

IC25c

N/A No limit 

Residual test 

availablea

Presence/ 

absence Presence/absence and quantitative 

Method detection 

limit of residual 

0.1 mg/L 

presence/ 

absence 

< 0.5 mg/L presence/absence 

0.5 mg/L quantitative 

Source: ATS Industry Task Force 2007. 

a. Residual tests can be presence/absence tests or quantitative tests. A presence/absence test verifies that a chemical is or is not 

present at or above a method detection limit; it does not quantify (with a numerical value) how much is present above the method 

detection limit. A quantitative test yields the concentration of the chemical at or above the method detection limit; it t typically yields a 

concentration in mg/L. 

b. NOEC: No Observed Effect Concentration. Highest concentration of effluent where the effect (e.g., reproduction) is not 

significantly different from the control. 

c. IC25: 25 Percent Inhibition Concentration. Concentration causing a 25 percent reduction in the effect. 

N/A – Not Available 
Section 7: Technology Assessment 

7-94 

Chitosan acetate 

This polymer is widely used at active construction sites in ATS for stormwater runoff. 

Specifically, Washington, Oregon, and California have had numerous projects using this 

polymer. It is an approved, general-use-level designated polymer for treating construction site 

runoff in Washington State. Chitosan is derived from chitin, the major component of crustacean 

shells and is a cationic polyelecrolyte. It is a very plentiful natural polymer with supply 

stemming from shellfish wastes. Chitosan is able to coagulate/flocculate non-polar hydrocarbons 

(e.g., oil), suspended sediment, and to chelate heavy metals (Nichols 1997). 

Table 7-29 presents information from several studies regarding toxicity of chitosan acetate to 

aquatic organisms, chemical hazard information, and filter pass-through results. 

Table 7-29. Chitosan acetate study results 

Vendor/source Results 

MacPherson 2006a 

(references Nautilus 

Environmental, Redmond, 

Washington 2004) 

Toxicity. Chitosan acetate (1% solution) was reported to have an LC50 for 

Daphnia pulex of 1,370 mg/L, 642 mg/L for fathead minnow, and 168 mg/L 

for rainbow trout in clean water and 452 mg/L in 500-NTU water. 

Bullock et al. 2000 Toxicity. The toxicity of chitosan has generally been considered to be 

nontoxic; however, Chitosan when dissolved in acetic acid and added to a 

culture system at 1.0 part per million (ppm) to remove organic solids was 

found to have acute toxicity to rainbow trout, related to gill lesions, and the 

severity was dose dependent. 

ProTech GCS 2004 Toxicity. ProTech GCS in conjunction with GE Betz conducted research on 

the polymer chitosan (1% solution). The test was conducted using > 1,000 

NTU water from a Sacramento, CA, project site. Survival rates for daphnia 

magna, rainbow trout, and fathead minnow were 100% at a dose of 1,100 

ppm and 2,200 ppm. 

MacPherson 2006b Toxicity/Filter pass-through. Chitosan is trapped in the sand filter and not 

released into the receiving water. 

Blandford 2006 Filter pass-through. A study evaluating the retention of chitosan acetate in a 

mixed media filter (anthracite, sand, and garnet) was conducted by GE Betz. 

The results upon a side-by-side comparison for KlaraidTM PC 1192 

(DADMAC) with chitosan acetate demonstrated that both products pass 

through a standard mixed media filter without any retention in the layers of 

the filter. 

Hazard. This polymer is listed as Resource Conservation and Recovery Act 

(RCRA) hazardous because of the acidity (at a pH of about 4). 

Ray 2001 

Hazard. Chitosan acetate (1% solution) has a pH of 3.9 to 4.0 and is 

reported to be mildly irritating to the eyes. 
Section 7: Technology Assessment 

7-95 

Diallydimethyl-ammonium chloride (DADMAC) 

This polymer is also used in ATS for treating construction site stormwater runoff. DADMAC is 

considered to be water soluble over a wide pH range. It has a high affinity for suspended 

sediment but can have the ability to pass through treatment media to the receiving water 

(MacPherson 2006a). 

Table 7-30 presents information from several studies regarding toxicity of DADMAC to aquatic 

organics, and filter pass-through results. 

Table 7-30. DADMAC acetate study results 

Vendor/source Results 

Macpherson 2006a Toxicity. Tramfloc, Inc., reports daphnia magna, 48-hour LC50 of 0.23 mg/L 

for the Tramfloc Polydadmac 552, 553 and 557 products; however, aquatic 

toxicity is reduced by factors of 10 to 100 times in the presence of 5 to 10 

mg/L organics found in most surface waters. 

Macpherson 2006a Filter pass-through. High affinity for suspended sediment but might have the 

ability to pass through treatment media to the receiving water 

ProTech GCS, Inc., in 

conjunction with GE Betz 

Toxicity. Demonstrated that, on a dose/response basis, DADMAC reduced > 

1,000 NTU-water to 2 NTU at a dose of 25 ppm. In addition, aquatic toxicity 

testing revealed a 95%, 100%, and 100% survival rate for daphnia magna, 

rainbow trout, and fathead minnow, respectively. The ProTech and GE study 

reports that the polymer DADMAC was the most economical for its removal 

of suspended sediment and disposal costs.

Polyacrylamide (PAM) 

PAM are a broad class of compounds that include cationic (positively charged) and anionic 

(negatively charged) polyacylamides. PAMs are water soluble over a wide pH range and exhibit 

a high affinity for suspended sediment. 

Table 7-31 presents information from several studies regarding toxicity of PAMs to aquatic 

organics and hazard information. 

Table 7-31. PAM study results 

Vendor/source Results 

Toxicity. At very high doses, irritation in humans and toxicity to certain 

aquatic organisms can be observed; however, in general PAMs are 

considered to be nontoxic to aquatic organisms. 

(see Section 7.2.4.10) 

Hazard. PAM in the solid state has highly hygroscopic dust and, if inhaled, 

could impair breathing. 

MacPherson 2006a Toxicity. Anionic PAMs are not expected to be toxic to aquatic life at normal 

dose rates (LC50 for most aquatic species is greater than 100 mg/L). 

PAMs have been approved for use in Florida and New Hampshire (ATS Industry Task Force 

2007). In California, Washington, Michigan, and Oregon, cationic PAM cannot be used for 

construction site soil stabilization practices (MacPherson 2006a). McLaughlin has conducted 
Section 7: Technology Assessment 

7-96 

extensive research on the use of PAM on construction sites in North Carolina, as well as PAM 

toxicity. 

Aluminum-Based Coagulants 

The aluminum-based coagulants do not appear to be as widely used in ATS at construction sites 

for stormwater runoff. Table 7-32 presents aluminum toxicity on aquatic organisms. Note that 

aluminum floc will be in various aluminum complexes, which can become aqueous aluminum 

depending on time and site-specific physical and environmental conditions (e.g., pH, 

temperature, hardness and alkalinity, release of trapped sediment). 

Table 7-32. Aluminum-based coagulant study results 

Vendor/source Results 

Toxicity. Specifically, studies with juvenile striped bass indicate that this 

species is extremely sensitive to several forms of aqueous aluminum 

(referenced Driscoll et al. 1980; Palawski et al. 1985; Skogheim and 

Rosseland 1986; Rosselan et al. 1992). 

Toxicity. An in situ study (Hall et al. 1985) with larval striped bass found 90% 

to 99% mortality in river water with 0.48 to 4.1 mg/L aluminum and pH levels 

between 6.0 and 6.8. 

MacPherson 2006a 

Toxicity. Klauda et al. (1989) support the theory that monomeric aluminum 

(mAl), the inorganic fraction, is potentially the most toxic to early life stages of 

migratory fish. 

Sutherland 1999 (references 

Oughton 1992) 

Toxicity. Polymers created from aluminum and water collect on gills and limit 

respiration. 

ProTech GCS, Inc., in 

conjunction with GE Betz 

Toxicity. ProTech GCS and GE Betz conducted a study using the 

coagulant/flocculant Aluminum Chlorhydroxide and found that at optimum 

dose (75 ppm) survival rates for daphnia magna, rainbow trout, and fathead 

minnow were 95%, 100%, and 95%, respectively. At two times, the optimum 

dose (150 ppm) results were similar, showing no increased toxicity. 

MacPherson 2006a Hazard. These aluminum-based water treatment agents also pose a risk to 

human eyes and skin if not properly handled. 

7.2.5.3. ATS Filtration 

Filtration is a final treatment step in ATS designed to remove residual, low concentrations of 

target pollutants before discharge. Multimedia filtration (mixed-media filtration) is one of the 

oldest and most widely applied types of filtration for removing suspended solids from aqueous 

liquid streams. This form of filtration uses a bed of granular particles as the filter medium. 

Granular media filters are used to remove suspended solids from construction stormwater after 

chemical addition creates a floc to filter. The bed can consist of one type of medium (e.g., sand) 

of the same particle size, or multiple particle sizes. Different types of media (e.g., sand and 

gravel, sand and anthracite) with differing densities and different particle sizes compose the bed 

of a multimedia filter. Multimedia filters can be more efficient but more expensive and complex 

than single-media filters. For that reason, sand filters are most commonly used in construction 

ATS. The filter bed is inside a basin or tank and is supported by an underdrain system, which 

allows the filtered liquid to be drawn off while retaining the filter medium in place. As 

suspended particle-laden water passes through the bed of the filter medium, particles are trapped 
Section 7: Technology Assessment 

7-97 

on top of and within the bed. Once the pressure drop across the filter is large enough to impede 

flow, the filter is backwashed, and the backwash water is typically recirculated to the influent 

flow. 

Vendors are also marketing bag and cartridge filters that can be used as a final filtration step. 

Bag filters are available in a range of pore sizes, and cartridge filters are available with various 

media types. The filters can be used as a final polishing step before discharge. 

7.2.5.4. Other Emerging Treatment Technologies 

While EPA’s analysis was based primarily on chitosan-enhanced filtration, several other 

advanced technologies are available to treat construction site stormwater runoff. 

Electrocoagulation has been successfully used on a number of construction sites to meet turbidity 

limits. At least one vendor is using a tube settler coupled with polymer addition before filtration 

to help remove sediment. In addition, several commenters provided information to EPA about 

other advanced turbidity control technologies that are in use or in development (see DCNs 43122 

and 43123, and Docket Numbers EPA-HQ-OW-2008-0465.0525 and EPA-HQ-OW-2008-

0465.0527/0527.1). 

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Section 8: Regulatory Development and Rationale 

8-1 

8. BCT COST-REASONABLENESS ASSESSMENT 

This section presents a summary of the Best Conventional Pollutant Control Technology (BCT) 

methodology and the results of the two-part cost-reasonableness test. In considering whether to 

promulgate BCT limits more stringent than the requirements being promulgated for Best 

Practicable Control Technology (BPT), the U.S. Environmental Protection Agency (EPA) 

considered whether technologies are available that would achieve greater removals of 

conventional pollutants than the BPT effluent limitations guidelines. EPA also considered 

whether those technologies are cost-reasonable according to the BCT cost test, which compares 

the incremental removals and costs associated with BCT limitations to benchmarks associated 

with BPT and publicly owned treatment works (POTWs). 

8.1. BACKGROUND ON THE BCT COST TEST 

In 1977 Congress amended the Clean Water Act to include section 304(b)(4)(B). This provision 

specifies that, among other factors, the assessment of BCT effluent limitations must include 

consideration of 

...the reasonableness of the relationship between the costs of attaining a reduction 

in effluents and the effluent reduction benefits derived, and the comparison of the 

cost and level of reduction of such pollutants from the discharge of publicly 

owned treatment works to the cost and level of reduction of such pollutants from a 

class or category of industrial sources... 

Accordingly, EPA developed the BCT methodology to determine whether it is cost-reasonable

for an industry category or subcategory to control conventional pollutants at a level more 

stringent than would be achieved by BPT effluent limitations. 

The BCT methodology was originally published on August 29, 1979, along with the 

promulgation of BCT effluent limitations guidelines for a number of industry sectors (44 Federal 

Register [FR] 50732). The crux of the methodology was a comparison of the costs of removing 

conventional pollutants for an average-sized POTW. The Fourth Circuit of the U.S. Court of 

Appeals remanded the BCT regulation and directed EPA to develop an industry cost test in 

addition to the POTW test. EPA subsequently proposed a revised BCT methodology in 1982 that 

addressed the industry cost test (47 FR 49176; October 29, 1982). In 1984 EPA again addressed 

the BCT methodology and proposed to base the POTW benchmark on model plant costs (49 FR 

37046; September 20, 1984). The final BCT methodology was published in 1986, maintaining 

the basic approach of the 1982 proposed BCT methodology and adopting the use of the new 

model POTW data (51 FR 24974; July 9, 1986). These guidelines state that the BCT cost 

analysis “...answers the question of whether it is ‘cost reasonable’ for industry to control 

conventional pollutants at a level more stringent than BPT effluent limitations already require.” 

See 51 FR at 24974. Conventional pollutants are biochemical oxygen demand (BOD), total 

suspended solids (TSS), oil and grease, fecal coliform, and pH. 

The final BCT methodology incorporates two cost tests to establish cost reasonableness: the 

POTW test and the industry cost-effectiveness test. Each of these tests is compared with 
Section 8: Regulatory Development and Rationale 

8-2 

established benchmarks, the derivation of which is described in detail in the 1986 FR notice. The 

BCT cost methodology is described in more detail in the following section. 

8.2. OPTIONS EVALUATED FOR BCT 

8.2.1. OPTION 1 

Option 1 contains requirements for implementing a variety or erosion and sediment controls on 

all construction sites that are required to obtain a permit. 

8.2.2. OPTION 2 

Option 2 contains the same requirements as Option 1. In addition, construction sites of 30 or 

more acres of disturbed land would be required to meet a numeric turbidity limit in stormwater 

discharges from the site based on the application of ATS. 

8.2.3. OPTION 3 

Option 3 contains the same requirements as Option 1. Option 3 also requires all sites with 10 or 

more acres of disturbed land to meet a numeric turbidity standard based on the application of 

ATS. 

8.2.4. OPTION 4 

Option 4 contains the same requirements as Option 1. Option 4 also requires all sites with 10 or 

more acres of disturbed land to meet a numeric turbidity standard based on the application of 

passive treatment systems. 

8.3. CALCULATION OF THE BCT COST TEST 

POTW Test 

The first part of the BCT cost test is the POTW test. The POTW test compares the cost per 

pound of conventional pollutants removed by industrial dischargers in upgrading from BPT to 

BCT candidate technologies, to the cost per pound of removing conventional pollutants in 

upgrading POTWs from secondary treatment to advanced secondary treatment. 

To pass the POTW test, the cost per pound of conventional pollutant discharges removed in 

upgrading from BPT to the candidate BCT must be less than the POTW benchmark. The POTW 

benchmark presented in the 1986 Federal Register notice is $0.25 per pound (in 1976 dollars) for 

industries in which the cost per pound of pollutant reduction is based on long-term performance 

data. EPA used cost index data from R.S. Means Historical Cost Indices to update this POTW 

benchmark to 2008 dollars according to the following equation: 

 Index for 2008 

 × Cost in 1976$ = Cost in 2008$

 Index for 1976 
Section 8: Regulatory Development and Rationale 

8-3 

 92.0$25.0$

9.46

0.173



 

Using estimated reductions for TSS, EPA then calculated the incremental costs per pound of 

conventional pollutant removed ($/lb) for each candidate BCT technology option. If any candidate 

technology option passes the first part of the BCT cost test (i.e., is less than the inflation-adjusted 

value of $0.92 in 2008 dollars), the technology is further evaluated in the second part of the test. 

EPA used only TSS pollutant reductions for the cost test calculations, because of the limited data 

available. However, EPA expects that discharges of oil and grease and fecal coliform would be 

minimal from construction sites. EPA also expects that BOD, where present, would be removed 

along with TSS. The results of the POTW test are presented in Table 8-1. 

Table 8-1. POTW cost test results 

Total annual costs and 

conventional pollutant 

removals 

Incremental costs and conventional 

pollutant removals, relative to BPTa

BCT 

option 

Cost 

(million $) 

(2008$) 

Pollutant 

removals 

(million lbs) 

Cost 

(million $) 

(2008$) 

Pollutant 

removals 

(million lbs) 

Cost per 

pound 

($/lb) 

POTW cost 

test result 

(< $0.92/lb) 

1 176 1,743 

2 4,863 3,616 4,687 1,873 2.50 Fail 

3 9,081 4,507 8,905 2,764 3.22 Fail 

4 959 3,971 783 2,228 0.35 Pass 

a

 Option 1 is equal to the BPT effluent limitations. Therefore, all incremental values are calculated relative to Option 1. 

Industry Cost-Effectiveness Test 

The second part of the BCT cost test is the industry cost-effectiveness test, which computes the 

ratio of two incremental costs. The first of these incremental costs is the cost per pound of 

conventional pollutants removed in upgrading from BPT to the BCT candidate technology. This 

value serves as the numerator of the ratio. The second incremental cost, which serves as the 

denominator of the ratio, is the cost per pound of conventional pollutants removed by BPT 

relative to no treatment (i.e., this value compares raw wasteload to pollutant load after 

application of BPT). This ratio is compared to an industry cost benchmark, which is based on 

POTW cost and pollutant removal data. The industry cost benchmark is also a ratio of two 

incremental costs: the cost per pound to upgrade a POTW from secondary treatment to advanced 

secondary treatment, divided by the cost per pound to initially achieve secondary treatment. If 

the industry cost-effectiveness test is lower than the industry cost benchmark of 1.29 (i.e., the 

normalized cost increase must be less than 29 percent), the candidate BCT technology passes this 

part of the cost test. The calculation and results of the industry cost-effectiveness test are 

presented in Tables 8-2 and 8-3. Because Options 2, 3, and 4 fail the second part of the BCT cost 

test, BCT is set equal to BPT, which is Option 1. 
Section 8: Regulatory Development and Rationale 

8-4 

Table 8-2. Cost and pollutant removals for BPT 

Total annual costs 

(million $) 

(2008$) 

Conventional pollutant 

removals 

(million lbs) 

BPT cost per pound 

($/lb) 

Baseline 2,804 44,620 

Option 1 Incremental 176 1,743 

Total BPT 2,980 46,363 0.064 

Table 8-3. Industry cost-effectiveness test results 

BCT option 

Incremental cost per pound to 

upgrade from BPT to BCT 

($/lb) 

Calculated 

ratio 

Industry cost-effectiveness 

test result 

(< 1.29) 

1 0 0 Pass 

2 2.50 38.92 Fail 

3 3.22 50.12 Fail 

4 0.35 5.47 Fail 

8.4. REFERENCES 

R.S. Means. 2008. Building Construction Cost Data. 66th ed. R.S. Means, Co., Kingston, MA. 

Earth System Science Center. 2006. Pennsylvania State University, College of Earth and Mineral 

Sciences, Earth System Science Center, State College, PA. 

<http://www.soilinfo.psu.edu/index.cgi?index.html>. 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-1

9. ESTIMATING INCREMENTAL COSTS FOR THE FINAL 

REGULATION 

9.1. OVERVIEW 

This section presents the approach used for estimating the incremental costs associated with the 

regulatory options considered. This section also includes discussion on selecting and developing 

cost model inputs; the components of cost; and the methodology for estimating costs, including an 

overview of the C&D Cost Spreadsheet Models. The economic analyses conducted for the industry 

are described in the document Economic Analysis for Final Action for Effluent Guidelines and 

Standards for the Construction and Development Category (USEPA 2009). 

The U.S. Environmental Protection Agency’s (EPA’s) first step in estimating national costs for 

each option was developing an array of model construction sites. EPA then estimated unit 

compliance costs for the regulatory options. The most significant input parameter in estimating 

the size and cost of treatment equipment for model construction sites is the volume of rainfall 

requiring treatment. EPA estimated the amount of stormwater runoff requiring treatment using 

the drainage area of the model site, state-specific rainfall estimates, and runoff coefficients to 

estimate the volume of rainfall converted to runoff and requiring subsequent treatment. The 

model project costs were then scaled to the state and national level on the basis of the national 

project distribution described in Table 4-3. 

Costs for the U.S. territories were not estimated because EPA lacked data on the annual amount 

of new construction acreage in these areas. However, assuming a small amount of construction 

occurs in those areas, EPA expects that the values would be low in comparison to the national 

costs. 

The total costs of the options considered are presented in Table 9-1. 

Table 9-1. Estimated total annual social costs of regulatory options 

for the C&D industry 

Regulatory option 

Annual cost 

(millions 2008 dollars) 

Option 1 $176 

Option 2 $4,863 

Option 3 $9,081 

Option 4 $959 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-2

9.2. DEVELOPMENT OF MODEL CONSTRUCTION SITES AND ESTIMATING 

TREATMENT VOLUMES 

9.2.1. MODEL CONSTRUCTION SITES 

As discussed in Section 4.2.2 and in Appendix C, EPA developed a series of model projects from

an analysis of NOI data. This matrix consisted of 12 model project sizes and 12 model project 

duration, yielding a total of 144 individual model projects. By analyzing the NOI data, EPA was 

able to develop a distribution of model projects for each model project size and duration category 

for three project types (residential construction, nonresidential construction, and transportation). 

For each state and the District of Columbia, EPA was able to estimate the number of model 

projects in those site size categories. Table 9-2 shows the model project matrix. Table 9-3 shows 

the estimated number of acres developed per year for the model projects. (Tables 9-2 and 9-3 

appear later in this section grouped with other tables of similar size.) 

EPA based its costing on the size of the model site, the volume of runoff being treated, and the 

duration of land disturbance. EPA assumes, for costing purposes, that the duration of 

construction activities (and hence the duration of time needed to meet the turbidity limits) under 

Options 2, 3, and 4 for some projects are shorter than the NOI project durations. That is because 

projects are likely to transition from major land disturbing activities into the vertical construction 

phase. For the final months of a project, the majority of soil disturbance would likely be 

complete as structures are constructed. Final stabilization of remaining disturbed areas around 

the building footprint would be complete once the majority of the exterior construction work is 

complete. Final vegetation is usually one of the last steps in the construction sequence, and the 

Notice of Termination (NOT) is usually filed after final stabilization. Because the turbidity limits 

under Options 2, 3, and 4 are tied to the disturbed area of the site, EPA expects that disturbed 

land on the majority of construction sites subject to the turbidity limit would fall below the 

associated thresholds several months before the end of the project. Table 9-4 presents the 

original project durations based on NOIs and the duration used for costing purposes. For projects 

shorter than 7 months, the duration of the project for costing purposes was not changed. For 

projects longer than 7 months, the duration of the project was reduced by 1 month (for a 7-month 

project) up to 6 months (for a 36-month project). 

Table 9-4. Model project durations 

NOI Project Duration (months) 1 2 4 7 10 13 

Duration for Costing (months) 1 2 4 6 8 10 

NOI Project Duration (months) 16 19 22 27 32 36 

Duration for Costing (months) 13 15 16 21 26 30 

(Tables 9-2 and 9-3 appear later in this section grouped with other tables of similar size.) 

For costing ATS, EPA assumed that 100 percent of each construction site would be producing 

stormwater runoff that would require treatment. That is a conservative assumption, because some 

portion of sites will likely discharge through perimeter controls because diffuse runoff and would 

not require sampling and compliance with the numeric limit. EPA notes that these assumptions 

for project duration and amount of the site requiring treatment, while useful for modeling, likely 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-3

vary considerably among actual construction projects. However, because EPA lacks data on the 

typical duration of disturbed soils at construction projects and the duration that treatment would 

need to be in place, this modeling approach provides a reasonable, if somewhat conservative, 

means of estimating runoff volumes requiring treatment and incremental compliance costs of the 

options. 

9.2.2. ESTIMATION OF RAINFALL DEPTHS AND STORAGE VOLUMES 

To calculate basin sizing for storage for ATS under Options 2 and 3 and to determine runoff 

volumes for costing treatment systems, EPA evaluated several references to determine rainfall 

depths for a series of design storm return periods for one indicator city in each state (for a 

discussion of that analysis, see Section 3.5.3 and Appendix D). The storm depths for each 

indicator city were used as point estimates for rainfall depths in each respective state. Using the 

storm depths, EPA estimated runoff coefficients for each state using the process described in 

TR-55 (USDA 1986). EPA estimated a runoff curve number using the Soil Conservation Service 

runoff curve number equation: 

SIP

IP Q

a

a



  )()(

2

where 

Q = runoff (in) 

P = rainfall (in) 

S = potential maximum retention after runoff begins (in) 

Ia = initial abstraction (in) = 0.2S 

)8.0(

)2.0(

2

SP

SP Q



 

10 1000  CNS

Using the values contained in TR-55 for Curve Numbers for Developing Urban Areas (from TR55, Table 2-2a), along with the 2-year, 24-hour storm depths in Table 3-3, EPA calculated runoff 

coefficients for the four hydrologic soil groups in each state for the 2-year, 24-hour storm event 

(see Table 9-5). Using data on the prevalence of soils by hydrologic soil groups obtained from 

STATSGO for each state (see Table 3-4), EPA then calculated a weighted runoff coefficient for 

each state for the 2-year, 24-hour storm event. These results are summarized in Table 9-5 and 

were used to determine the required basin sizes for capturing runoff from the 2-year, 24-hour 

storm event in each state, which is a requirement for Options 2 and 3 (see Table 9-6). Table 9-6 

also contains baseline sediment basin sizes for states based on a review of current state permit 

requirements. The rainfall analysis data is DCN 43095, and the STATSGO soils data evaluation 

is DCN 43096 in the Administrative Record. 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-4

9.2.3. ESTIMATION OF ATS TREATMENT VOLUMES 

For estimating average runoff volumes for each model site in each state, EPA multiplied the 

average annual precipitation in each state by the site size and a runoff coefficient of 0.4. This 

value of 0.4 was chosen as a reasonable estimate of the percent of average rainfall that would be 

converted to runoff. EPA acknowledges that this approach likely overestimates runoff volumes 

(and hence, volumes requiring treatment and associated treatment costs) because many smaller 

storm events would not produce any, or very little, runoff. This approach also does not account 

for precipitation that falls as snow. It also assumes that the entire site is in a newly graded areas

state, as defined by TR-55, for the entire duration of the project. In reality, site areas during 

various states of the construction project would be in various states, ranging from bare soil, to 

temporarily stabilized with mulch, to vegetated. As a result, curve numbers could be much lower 

and associated runoff volumes could be much lower. However, this approach does allow for a 

reasonable, albeit conservative, estimate of treatment volumes for determining compliance costs. 

EPA multiplied the average annual runoff volumes for each model project by the project duration 

(in years) account for length of time stormwater would be produced. This analysis does not 

account for seasonal variations in rainfall—EPA assumed that precipitation would be evenly 

distributed over the year. So, for a project that is less than one year in duration, the treatment 

volume was based on the associated fraction of the year, irrespective of when construction would 

actually occur. 

Table 9-7 summarizes the monthly treatment volumes for each state for each of the 14 model 

project size categories. Treatment volumes for each model project were determined by 

multiplying the monthly treatment volumes by the project durations (in months). For each state 

and each model project size category, EPA determined the treatment system flowrate needed to 

treat runoff from the 2-year, 24-hour storm event within 72 hours. Table 9-8 shows the system 

flowrate required. For selecting a design flowrate for costing, if the treatment flowrate was 100 

gallons per minute (gpm) or less, a design flowrate of 100 gpm was selected. If the treatment 

flowrate was greater than 100 gpm, the design flowarate was selected by rounding up in 500-

gpm increments. Although ATS filtration systems are available in various flowrates depending 

on the vendor, 500 gpm is a typical sand filter flowrate. Table 9-9 shows the design flowrates 

selected for costing purposes. EPA notes that rounding up to 500-gpm increments is a 

conservative assumption, because a 500-gpm system could operate at a higher flowrate. So, for 

example, EPA estimated that a 46-acre site in Illinois would require 525 gpm of treatment. A 

500-gpm sand filter would likely be able to operate at 525 gpm, but EPA selected a 1,000-gpm 

system for this model project. The 500-gpm system would have a lower rental cost than the 

1,000-gpm system, but treatment times (and hence operator labor requirements) would be longer. 
9-5 

Table 9-2. Model project matrix 

RESIDENTIAL 

Project size Duration (days) (acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 913–

1.9 124 147 632 571 1,111 926 283 293 222 450 93.8 68 100 351 341 703 657 312 213 249 397 126 44 28 242 168 444 301 81 110 169 220 78.5 22 26 187 172 318 309 52 70 109 180 6

12 23 14 195 218 506 388 139 78 72 430 717 18 2 84 174 209 219 95 107 74 360 723 1 28 107 133 239 303 73 90 103 325 1034 1 -- 48 59 182 143 23 42 18 214 646 11 -- 33 84 126 114 11 24 70 155 1069 -- -- 1 38 38 54 17 19 18 60 185 -- -- -- 2 17 36 -- 7 7 43 2

145 -- -- 8 11 45 50 15 12 37 50 3

Total Residential 312 345 1,888 1,971 3,938 3,500 1,101 1,065 1,148 2,884 86

NONRESIDENTIAL 

Project size Duration (days) (acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 913–

1.9 558 1,359 4,910 5,334 4,806 3,276 940 685 442 592 183.8 219 547 1,990 2,973 2,643 1,715 910 461 199 465 146 150 206 996 1,368 1,516 1,059 513 285 240 188 88.5 55 97 578 736 616 617 165 152 144 274 4

12 77 73 493 660 950 741 347 178 162 291 417 13 82 246 261 505 419 203 60 114 131 223 38 59 166 264 542 250 215 208 135 142 234 3 27 78 164 176 126 48 72 29 101 46 -- 17 49 65 129 150 57 152 12 131 569 2 2 29 50 33 30 30 87 16 71 85 -- -- 10 1 86 22 11 21 -- 51 

145 -- 8 25 46 124 25 10 11 5 58 2

Total Nonresidential 1,115 2,477 9,570 11,922 12,126 8,430 3,449 2,372 1,498 2,495 64
9-6 

TRANSPORTATION 

Project size Duration (days) (acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 913–1

1.9 82 210 629 418 308 323 136 55 132 117 7 3.8 25 87 277 255 246 146 81 60 34 58 22 6 16 23 184 138 170 53 45 26 -- 78 15 8.5 7 15 70 73 78 78 33 89 17 7 21 

12 8 21 70 109 39 95 52 43 17 36 13 17 -- 3 63 49 13 15 21 2 8 64 6 23 5 2 31 36 6 76 40 27 14 95 16 34 -- -- 1 26 17 6 16 4 9 5 42 46 -- 1 2 19 9 25 21 15 9 24 4 69 -- -- -- -- 3 9 10 4 -- 5 21 85 -- -- 7 -- -- 3 -- -- 2 4 12 

145 -- -- -- 1 3 4 1 9 11 24 35 

Total Transportation 143 362 1,334 1,124 892 833 456 334 253 517 214 NATIONAL TOTAL 1,570 3,184 12,792 15,017 16,956 12,763 5,006 3,771 2,899 5,896 1,721 
9-7 

Table 9-3. Acreage developed matrix 

RESIDENTIAL 

Project size Duration (days) (acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 91

1.9 236 279 1,201 1,085 2,111 1,759 538 557 422 855 3.8 258 380 1,334 1,296 2,671 2,497 1,186 809 946 1,509 6 264 168 1,452 1,008 2,664 1,806 486 660 1,014 1,320 8.5 187 221 1,590 1,462 2,703 2,627 442 595 927 1,530 

12 276 168 2,340 2,616 6,072 4,656 1,668 936 864 5,160 17 306 34 1,428 2,958 3,553 3,723 1,615 1,819 1,258 6,120 123 23 644 2,461 3,059 5,497 6,969 1,679 2,070 2,369 7,475 234 34 -- 1,632 2,006 6,188 4,862 782 1,428 612 7,276 246 506 -- 1,518 3,864 5,796 5,244 506 1,104 3,220 7,130 469 -- -- 69 2,622 2,622 3,726 1,173 1,311 1,242 4,140 85 -- -- -- 170 1,447 3,064 -- 596 596 3,659 2

145 -- -- 1,160 1,595 6,525 7,250 2,175 1,740 5,365 7,250 5

Total Residential 2,090 1,894 16,184 23,741 47,849 48,182 12,249 13,625 18,834 53,424 21

NONRESIDENTIAL 

Project size Duration (days) (acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 91

1.9 1,060 2,582 9,329 10,135 9,131 6,224 1,786 1,302 840 1,125 3.8 832 2,079 7,562 11,297 10,043 6,517 3,458 1,752 756 1,767 6 900 1,236 5,976 8,208 9,096 6,354 3,078 1,710 1,440 1,128 8.5 468 825 4,913 6,256 5,236 5,245 1,403 1,292 1,224 2,329 

12 924 876 5,916 7,920 11,400 8,892 4,164 2,136 1,944 3,492 17 221 1,394 4,182 4,437 8,585 7,123 3,451 1,020 1,938 2,227 23 874 1,357 3,818 6,072 12,466 5,750 4,945 4,784 3,105 3,266 34 102 918 2,652 5,576 5,984 4,284 1,632 2,448 986 3,434 46 -- 782 2,254 2,990 5,934 6,900 2,622 6,992 552 6,026 269 138 138 2,001 3,450 2,277 2,070 2,070 6,003 1,104 4,899 85 -- -- 851 85 7,319 1,872 936 1,787 -- 4,340 

145 -- 1,160 3,625 6,670 17,980 3,625 1,450 1,595 725 8,410 4

Total Nonresidential 5,519 13,346 53,079 73,096 105,451 64,856 30,995 32,820 14,614 42,443 10
9-8 

TRANSPORTATION 

Duration (days) Project size 

(acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731– 912 913–1

1.9 156 399 1,195 794 585 614 258 105 251 222 13.8 95 331 1,053 969 935 555 308 228 129 220 86 96 138 1,104 828 1,020 318 270 156 -- 468 98.5 60 128 595 621 663 663 281 757 145 60 17

12 96 252 840 1,308 468 1,140 624 516 204 432 1517 -- 51 1,071 833 221 255 357 34 136 1,088 1023 115 46 713 828 138 1,748 920 621 322 2,185 3634 -- -- 34 884 578 204 544 136 306 170 1,4246 -- 46 92 874 414 1,150 966 690 414 1,104 1869 -- -- -- -- 207 621 690 276 -- 345 1,4485 -- -- 596 -- -- 255 -- -- 170 340 1,02

145 -- -- -- 145 435 580 145 1,305 1,595 3,480 5,07

Total Transportation 617 1,390 7,292 8,084 5,664 8,103 5,363 4,823 3,672 10,115 10,14NATIONAL TOTAL 8,226 16,631 76,556 104,921 158,964 121,141 48,607 51,268 37,120 105,981 42,32
9-9 

Table 9-5. State runoff coefficients for 2-year, 24-hour storm events 

2-year, 

24-hour 

storm depth 

(inches) 

Runoff 

coefficient 

for A soils 

Runoff 

coefficient 

for B soils 

Runoff 

coefficient 

for C soils 

Runoff 

coefficient 

for D soils 

% A 

soils 

% B 

soils 

% C 

soils 

% 

s

Alabama 4.50 0.49 0.67 0.78 0.85 8.7% 41.2% 28.8% 21Arizona 1.40 0.12 0.31 0.47 0.61 4.7% 38.6% 17.2% 39Arkansas 4.10 0.46 0.64 0.76 0.83 0.6% 28.3% 35.9% 35California 2.00 0.22 0.42 0.58 0.70 10.9% 32.2% 18.4% 38Colorado 2.00 0.22 0.42 0.58 0.70 7.2% 46.7% 24.6% 21Connecticut 3.10 0.37 0.56 0.70 0.79 9.1% 41.1% 35.9% 13Delaware 3.26 0.38 0.58 0.71 0.80 20.8% 30.9% 13.4% 34Florida 4.75 0.51 0.68 0.79 0.86 18.1% 6.3% 8.6% 67Georgia 3.70 0.43 0.62 0.74 0.82 6.6% 53.1% 16.9% 23Idaho 1.20 0.08 0.25 0.42 0.56 4.4% 46.8% 23.1% 25Illinois 2.85 0.34 0.54 0.68 0.77 1.4% 44.5% 27.0% 27Indiana 2.95 0.35 0.55 0.69 0.78 3.5% 32.6% 41.8% 22Iowa 3.25 0.38 0.58 0.71 0.80 0.9% 66.0% 11.6% 21Kansas 3.50 0.41 0.60 0.73 0.81 3.8% 58.0% 19.5% 18Kentucky 3.00 0.36 0.55 0.69 0.78 0.1% 42.7% 44.9% 12Louisiana 5.25 0.54 0.70 0.80 0.87 1.7% 14.4% 28.9% 55Maine 2.80 0.33 0.53 0.67 0.77 7.7% 12.9% 43.9% 35Maryland 3.16 0.37 0.57 0.70 0.79 10.0% 38.6% 26.4% 25Massachusetts 3.10 0.37 0.56 0.70 0.79 23.9% 16.6% 34.4% 25Michigan 2.40 0.28 0.48 0.63 0.74 29.0% 28.7% 12.9% 29Minnesota 2.75 0.33 0.53 0.67 0.77 8.3% 37.4% 15.4% 38Mississippi 4.45 0.49 0.66 0.78 0.85 2.3% 32.3% 38.6% 26Missouri 3.45 0.40 0.60 0.72 0.81 1.0% 40.1% 39.8% 19Montana 1.30 0.10 0.28 0.45 0.58 2.9% 39.5% 27.2% 30Nebraska 3.00 0.36 0.55 0.69 0.78 31.9% 53.6% 3.0% 11Nevada 1.00 0.05 0.20 0.36 0.50 5.6% 26.4% 17.7% 50New Hampshire 2.80 0.33 0.53 0.67 0.77 17.1% 24.8% 41.4% 16New Jersey 3.31 0.39 0.58 0.71 0.80 12.5% 32.8% 25.1% 29New Mexico 1.54 0.15 0.34 0.50 0.63 5.6% 41.9% 16.5% 36New York 2.90 0.35 0.54 0.68 0.78 9.6% 18.5% 51.1% 20
9-10 

2-year, 

24-hour 

storm depth 

(inches) 

Runoff 

coefficient 

for A soils 

Runoff 

coefficient 

for B soils 

Runoff 

coefficient 

for C soils 

Runoff 

coefficient 

for D soils 

% A 

soils 

% B 

soils 

% C 

soils 

% 

s

North Carolina 3.34 0.39 0.59 0.72 0.80 7.9% 48.8% 16.5% 26North Dakota 1.90 0.21 0.41 0.57 0.69 4.7% 56.1% 16.6% 22Ohio 2.62 0.31 0.51 0.66 0.76 0.6% 16.8% 54.6% 28Oklahoma 3.70 0.43 0.62 0.74 0.82 6.8% 44.5% 22.3% 26Oregon 2.50 0.30 0.50 0.64 0.75 5.2% 32.1% 37.1% 25Pennsylvania 3.23 0.38 0.58 0.71 0.80 6.0% 28.4% 54.2% 1Rhode Island 3.20 0.38 0.57 0.71 0.79 15.3% 35.7% 32.4% 16South Carolina 3.62 0.42 0.61 0.73 0.82 11.9% 41.8% 19.5% 26South Dakota 2.25 0.26 0.46 0.62 0.73 2.9% 45.2% 11.5% 40Tennessee 3.37 0.40 0.59 0.72 0.80 0.1% 53.6% 30.4% 15Texas 3.90 0.44 0.63 0.75 0.83 5.1% 27.2% 24.5% 43Utah 1.40 0.12 0.31 0.47 0.61 5.3% 36.2% 16.2% 42Vermont 2.40 0.28 0.48 0.63 0.74 4.9% 18.0% 54.3% 22Virginia 3.11 0.37 0.56 0.70 0.79 1.7% 53.7% 32.3% 12Washington 2.00 0.22 0.42 0.58 0.70 6.6% 53.4% 24.2% 15West Virginia 2.56 0.30 0.50 0.65 0.75 7.3% 21.5% 54.2% 17Wisconsin 2.80 0.33 0.53 0.67 0.77 14.4% 46.8% 18.1% 20Wyoming 1.60 0.16 0.35 0.51 0.64 4.5% 40.5% 19.5% 35District of Columbia 

3.16 0.37 0.57 0.70 0.79 10.0% 38.6% 26.4% 25
 Section 9: Estimating Incremental Costs for the Final Regulation 

9-11

Table 9-6. ATS storage requirements for states 

Baseline sediment 

basin size 

(cf/acre) 

2-year, 24-hour runoff 

basin size 

(cf/acre) 

Alabama 1,800 11,798 

Arizona 2,254 2,254 

Arkansas 3,600 11,179 

California 3,389 3,898 

Colorado 1,800 3,685 

Connecticut 3,600 7,043 

Delaware 3,600 7,487 

Florida 3,600 13,371 

Georgia 1,800 9,019 

Idaho 3,600 1,585 

Illinois 1,585 6,591 

Indiana 3,600 6,968 

Iowa 1,800 7,536 

Kansas 3,600 8,337 

Kentucky 3,600 7,004 

Louisiana 3,600 15,638 

Maine 3,600 6,744 

Maryland 3,600 7,353 

Massachusetts 3,600 6,977 

Michigan 3,600 4,530 

Minnesota 3,600 6,247 

Mississippi 3,600 12,147 

Missouri 3,600 8,574 

Montana 3,600 1,948 

Nebraska 1,800 5,680 

Nevada 1,800 1,350 

New Hampshire 1,350 6,064 

New Jersey 3,600 7,886 

New Mexico 1,800 2,570 

New York 2,570 6,776 

North Carolina 3,600 7,884 

North Dakota 1,800 3,361 

Ohio 3,361 6,261 

Oklahoma 1,800 9,184 

Oregon 3,600 5,495 

Pennsylvania 3,600 7,754 

Rhode Island 5,000 7,239 

South Carolina 1,800 8,756 

South Dakota 3,600 4,745 

Tennessee 3,600 8,095 

Texas 3,600 10,403 

Utah 3,600 2,284 

Vermont 3,099 5,345 

Virginia 1,800 7,141 
 Section 9: Estimating Incremental Costs for the Final Regulation 

9-12

Baseline sediment 

basin size 

(cf/acre) 

2-year, 24-hour runoff 

basin size 

(cf/acre) 

Washington 3,600 3,575 

West Virginia 512 5,679 

Wisconsin 3,600 5,884 

Wyoming 1,800 2,770 

District of Columbia 1,800 7,353 
9-13 

Table 9-7. Monthly ATS treatment volumes (gallons) 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 Alabama 84,331 168,662 266,308 377,270 532,617 754,540 1,020,849 1,509,081 2,041,697 3,062,546 Arizona 13,309 26,617 42,028 59,539 84,055 119,078 161,106 238,156 322,212 483,317 Arkansas 81,888 163,775 258,593 366,340 517,185 732,679 991,272 1,465,359 1,982,544 2,973,816 California 31,628 63,256 99,878 141,494 199,756 282,988 382,866 565,976 765,732 1,148,598 Colorado 22,885 45,770 72,269 102,381 144,537 204,761 277,030 409,522 554,060 831,089 Connecticut 76,378 152,755 241,193 341,690 482,385 683,379 924,572 1,366,758 1,849,143 2,773,715 Delaware 73,984 147,968 233,634 330,981 467,267 661,962 895,596 1,323,924 1,791,191 2,686,787 Florida 106,642 213,284 336,764 477,083 673,528 954,165 1,290,930 1,908,331 2,581,859 3,872,789 Georgia 87,456 174,911 276,176 391,249 552,352 782,499 1,058,674 1,564,997 2,117,349 3,176,023 Hawaii 31,452 62,905 99,323 140,708 198,647 281,417 380,740 562,833 761,480 1,142,220 Idaho 19,491 38,983 61,552 87,198 123,104 174,397 235,949 348,794 471,897 707,846 Illinois 56,824 113,648 179,444 254,213 358,888 508,425 687,869 1,016,850 1,375,739 2,063,608 Indiana 68,246 136,492 215,514 305,312 431,028 610,623 826,137 1,221,247 1,652,275 2,478,412 Iowa 54,449 108,899 171,945 243,589 343,891 487,178 659,124 974,357 1,318,248 1,977,371 Kansas 63,087 126,174 199,222 282,231 398,443 564,462 763,683 1,128,923 1,527,367 2,291,050 Kentucky 77,407 154,815 244,445 346,297 488,889 692,593 937,038 1,385,186 1,874,076 2,811,113 Louisiana 101,070 202,140 319,168 452,155 638,336 904,309 1,223,478 1,808,619 2,446,955 3,670,433 Maine 71,652 143,304 226,269 320,548 452,538 641,095 867,364 1,282,190 1,734,728 2,602,092 Maryland 72,714 145,427 229,622 325,298 459,245 650,597 880,219 1,301,193 1,760,438 2,640,657 Massachusetts 72,921 145,842 230,277 326,226 460,554 652,451 882,728 1,304,902 1,765,456 2,648,184 Michigan 52,076 104,152 164,451 232,972 328,902 465,944 630,395 931,888 1,260,789 1,891,184 Minnesota 49,451 98,902 156,161 221,228 312,322 442,456 598,617 884,912 1,197,234 1,795,850 Mississippi 90,244 180,489 284,982 403,724 569,964 807,449 1,092,431 1,614,898 2,184,862 3,277,293 Missouri 63,161 126,323 199,457 282,564 398,914 565,129 764,586 1,130,257 1,529,172 2,293,758 Montana 20,256 40,513 63,968 90,621 127,935 181,242 245,209 362,484 490,419 735,628 Nebraska 48,692 97,383 153,763 217,831 307,526 435,661 589,424 871,323 1,178,848 1,768,273 Nevada 6,567 13,134 20,738 29,378 41,475 58,757 79,495 117,514 158,989 238,484 New Hampshire 69,179 138,357 218,459 309,483 436,917 618,966 837,425 1,237,932 1,674,849 2,512,274 New Jersey 80,817 161,633 255,210 361,548 510,421 723,096 978,307 1,446,193 1,956,613 2,934,920 New Mexico 26,580 53,160 83,937 118,911 167,875 237,823 321,760 475,645 643,520 965,281 New York 63,472 126,943 200,437 283,953 400,874 567,905 768,342 1,135,810 1,536,684 2,305,027 North Carolina 74,271 148,541 234,539 332,263 469,077 664,526 899,065 1,329,052 1,798,129 2,697,194 
9-14 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 North Dakota 27,663 55,327 87,358 123,757 174,715 247,513 334,871 495,027 669,742 1,004,613 Ohio 64,983 129,967 205,211 290,715 410,421 581,430 786,641 1,162,860 1,573,282 2,359,922 Oklahoma 56,430 112,861 178,201 252,451 356,402 504,903 683,104 1,009,805 1,366,207 2,049,311 Oregon 70,026 140,052 221,135 313,274 442,270 626,549 847,684 1,253,098 1,695,368 2,543,051 Pennsylvania 71,565 143,130 225,994 320,158 451,988 640,316 866,310 1,280,633 1,732,621 2,598,931 Rhode Island 76,941 153,883 242,973 344,211 485,945 688,423 931,395 1,376,845 1,862,790 2,794,185 South Carolina 78,161 156,322 246,824 349,668 493,649 699,336 946,160 1,398,672 1,892,321 2,838,481 South Dakota 27,679 55,358 87,407 123,826 174,813 247,652 335,059 495,305 670,118 1,005,177 Tennessee 79,292 158,584 250,396 354,727 500,791 709,454 959,850 1,418,908 1,919,700 2,879,549 Texas 55,927 111,855 176,613 250,201 353,225 500,403 677,015 1,000,805 1,354,030 2,031,046 Utah 25,034 50,068 79,055 111,994 158,110 223,989 303,043 447,977 606,087 909,130 Vermont 58,475 116,950 184,657 261,598 369,315 523,196 707,854 1,046,392 1,415,707 2,123,561 Virginia 69,392 138,784 219,132 310,438 438,265 620,875 840,007 1,241,750 1,680,015 2,520,022 Washington 60,638 121,275 191,487 271,273 382,974 542,546 734,033 1,085,092 1,468,066 2,202,099 West Virginia 73,641 147,283 232,552 329,449 465,104 658,897 891,449 1,317,794 1,782,898 2,674,347 Wisconsin 54,119 108,239 170,903 242,113 341,807 484,226 655,130 968,453 1,310,260 1,965,390 Wyoming 25,340 50,679 80,020 113,361 160,040 226,723 306,743 453,446 613,485 920,228 Puerto Rico 87,290 174,579 275,651 390,506 551,302 781,012 1,056,663 1,562,023 2,113,326 3,169,988 District of Columbia 71,780 143,560 226,673 321,120 453,346 642,240 868,913 1,284,481 1,737,827 2,606,740 
9-15 

Table 9-8. ATS system flowrate required (gpm) 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 Alabama 39 78 123 174 245 347 470 695 940 1,410 Arizona 7 15 23 33 47 66 90 133 180 269 Arkansas 37 74 116 165 232 329 445 658 890 1,336 California 13 26 40 57 81 115 155 229 310 466 Colorado 12 24 38 54 77 108 147 217 294 440 Connecticut 23 46 73 104 146 207 280 415 561 841 Delaware 25 49 78 110 156 220 298 441 596 894 Florida 44 88 139 197 278 394 532 787 1,065 1,597 Georgia 30 59 94 133 187 265 359 531 718 1,078 Hawaii 42 85 134 189 267 379 512 758 1,025 1,537 Idaho 5 10 16 23 33 47 63 93 126 189 Illinois 22 43 68 97 137 194 262 388 525 787 Indiana 23 46 72 103 145 205 277 410 555 832 Iowa 25 50 78 111 157 222 300 444 600 900 Kansas 27 55 87 123 173 245 332 491 664 996 Kentucky 23 46 73 103 146 206 279 412 558 837 Louisiana 51 103 162 230 325 460 623 921 1,246 1,868 Maine 22 44 70 99 140 199 269 397 537 806 Maryland 24 48 76 108 153 216 293 433 586 878 Massachusetts 23 46 72 103 145 205 278 411 556 834 Michigan 15 30 47 67 94 133 180 267 361 541 Minnesota 21 41 65 92 130 184 249 368 498 746 Mississippi 40 80 126 179 252 358 484 715 967 1,451 Missouri 28 56 89 126 178 252 341 505 683 1,024 Montana 6 13 20 29 40 57 78 115 155 233 Nebraska 19 37 59 84 118 167 226 334 452 679 Nevada 4 9 14 20 28 40 54 79 108 161 New Hampshire 20 40 63 89 126 178 241 357 483 724 New Jersey 26 52 82 116 164 232 314 464 628 942 New Mexico 8 17 27 38 53 76 102 151 205 307 New York 22 45 70 100 141 199 270 399 540 810 North Carolina 26 52 82 116 164 232 314 464 628 942 
9-16 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 North Dakota 11 22 35 49 70 99 134 198 268 402 Ohio 21 41 65 92 130 184 249 369 499 748 Oklahoma 30 60 95 135 191 270 366 541 731 1,097 Oregon 18 36 57 81 114 162 219 323 438 656 Pennsylvania 26 51 81 114 161 228 309 456 618 926 Rhode Island 24 48 75 107 150 213 288 426 577 865 South Carolina 29 58 91 129 182 258 349 515 697 1,046 South Dakota 16 31 49 70 99 140 189 279 378 567 Tennessee 27 53 84 119 168 238 322 477 645 967 Texas 34 68 108 153 216 306 414 612 829 1,243 Utah 8 15 24 34 47 67 91 134 182 273 Vermont 18 35 56 79 111 157 213 315 426 639 Virginia 23 47 74 105 148 210 284 420 569 853 Washington 12 24 37 53 74 105 142 210 285 427 West Virginia 19 37 59 84 118 167 226 334 452 678 Wisconsin 19 39 61 87 122 173 234 346 469 703 Wyoming 9 18 29 41 58 82 110 163 221 331 Puerto Rico 37 74 116 165 233 329 446 659 891 1,337 District of Columbia 24 48 76 108 153 216 293 433 586 878 
9-17 

Table 9-9. ATS system flowrate selected for costing (gpm) 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 Alabama 100 100 500 500 500 500 500 1,000 1,000 1,500 Arizona 100 100 100 100 100 100 100 500 500 500 Arkansas 100 100 500 500 500 500 500 1,000 1,000 1,500 California 100 100 100 100 100 500 500 500 500 500 Colorado 100 100 100 100 100 500 500 500 500 500 Connecticut 100 100 100 500 500 500 500 500 1,000 1,000 Delaware 100 100 100 500 500 500 500 500 1,000 1,000 Florida 100 100 500 500 500 500 1,000 1,000 1,500 2,000 Georgia 100 100 100 500 500 500 500 1,000 1,000 1,500 Hawaii 100 100 500 500 500 500 1,000 1,000 1,500 2,000 Idaho 100 100 100 100 100 100 100 100 500 500 Illinois 100 100 100 100 500 500 500 500 1,000 1,000 Indiana 100 100 100 500 500 500 500 500 1,000 1,000 Iowa 100 100 100 500 500 500 500 500 1,000 1,000 Kansas 100 100 100 500 500 500 500 500 1,000 1,000 Kentucky 100 100 100 500 500 500 500 500 1,000 1,000 Louisiana 100 500 500 500 500 500 1,000 1,000 1,500 2,000 Maine 100 100 100 100 500 500 500 500 1,000 1,000 Maryland 100 100 100 500 500 500 500 500 1,000 1,000 Massachusetts 100 100 100 500 500 500 500 500 1,000 1,000 Michigan 100 100 100 100 100 500 500 500 500 1,000 Minnesota 100 100 100 100 500 500 500 500 500 1,000 Mississippi 100 100 500 500 500 500 500 1,000 1,000 1,500 Missouri 100 100 100 500 500 500 500 1,000 1,000 1,500 Montana 100 100 100 100 100 100 100 500 500 500 Nebraska 100 100 100 100 500 500 500 500 500 1,000 Nevada 100 100 100 100 100 100 100 100 500 500 New Hampshire 100 100 100 100 500 500 500 500 500 1,000 New Jersey 100 100 100 500 500 500 500 500 1,000 1,000 New Mexico 100 100 100 100 100 100 500 500 500 500 New York 100 100 100 100 500 500 500 500 1,000 1,000 North Carolina 100 100 100 500 500 500 500 500 1,000 1,000 
9-18 

Model site size (acres) 

State 1.9 3.8 6 8.5 12 17 23 34 46 69 North Dakota 100 100 100 100 100 100 500 500 500 500 Ohio 100 100 100 100 500 500 500 500 500 1,000 Oklahoma 100 100 100 500 500 500 500 1,000 1,000 1,500 Oregon 100 100 100 100 500 500 500 500 500 1,000 Pennsylvania 100 100 100 500 500 500 500 500 1,000 1,000 Rhode Island 100 100 100 500 500 500 500 500 1,000 1,000 South Carolina 100 100 100 500 500 500 500 1,000 1,000 1,500 South Dakota 100 100 100 100 100 500 500 500 500 1,000 Tennessee 100 100 100 500 500 500 500 500 1,000 1,000 Texas 100 100 500 500 500 500 500 1,000 1,000 1,500 Utah 100 100 100 100 100 100 100 500 500 500 Vermont 100 100 100 100 500 500 500 500 500 1,000 Virginia 100 100 100 500 500 500 500 500 1,000 1,000 Washington 100 100 100 100 100 500 500 500 500 500 West Virginia 100 100 100 100 500 500 500 500 500 1,000 Wisconsin 100 100 100 100 500 500 500 500 500 1,000 Wyoming 100 100 100 100 100 100 500 500 500 500 Puerto Rico 100 100 500 500 500 500 500 1,000 1,000 1,500 District of Columbia 100 100 100 500 500 500 500 500 1,000 1,000 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-19

9.3. ESTIMATION OF COSTS 

EPA estimated costs for the regulatory options using three categories of costs: erosion and 

sediment controls (ESCs), ATS storage and treatment costs, and passive treatment costs. The 

components of the estimated costs are discussed below. 

9.3.1. EROSION AND SEDIMENT CONTROL COSTS 

EPA estimated costs for ESCs under baseline conditions as well as incremental costs as a result 

of the regulatory options. Estimating baseline costs was necessary to conduct the BCT cost test. 

While a variety of controls are likely to be used on individual construction sites, EPA does not 

have any comprehensive data on current practices because a survey of the industry was not 

conducted. Therefore, EPA made assumptions about controls employed for each of the model 

projects as a way of estimating baseline industry costs. EPA assumes that baseline controls 

would consist of sediment basins (for sites greater than 10 acres), silt fence, and soil cover. 

For estimating basin unit costs, EPA determined existing state sediment basin sizing 

requirements on the basis of a review of state permits. Table 9-6 shows the baseline sediment 

basins sizing requirements for each state. Table 9-11 shows the corresponding baseline basin size 

for each the model projecs greater than 10 acres. Descriptions of sediment traps and basins, 

including design criteria, performance, and costs are described in detail in Section 7.2.3. 

EPA (1993) references the Southeastern Wisconsin Regional Planning Commission’s 1991 Costs 

of Urban Nonpoint Source Water Pollution Control Measures (SWRPC 1991) for estimating 

costs of temporary sediment basins. Costs include site preparation (e.g., grading, excavation, 

place and compact fill), site development (e.g., riprap, temporary basin inlet and outlet 

structures), and contingencies. Temporary basins are a generally less expensive option as 

compared to permanent basins (e.g., SWRPC assumes temporary basin inlet and outlet costs to 

be one-half of permanent detention basin inlet and outlet costs). Table 9-10 summarizes the cost 

data EPA used for estimating sediment basin costs. EPA used the average value of $0.30 per 

cubic foot of storage for calculating incremental costs for sediment basins and for storage 

volumes required for ATS. EPA adjusted all sediment basin costs from 1989 dollars to 2008 

dollars. 

Table 9-10. Sediment basin construction cost data 

Cost data source Cost 

Basin size range of 

validity Basis year

USEPA (1993), original reference is 

SWRPC (1991). Numerous sources 

reference this data. Many of these 

sources adjusted USEPA (1993) to 

other basis years. 

$0.10 to $0.40 per cubic foot of 

storage, average of $0.30. 

12,000 ft3 to 195,000 

ft3

 SWRPC (1991) 

1989 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-20

EPA (1993) estimates annual operation and maintenance costs for temporary sediment basins 

(associated with runoff from active construction sites) as 25 percent of construction costs. EPA 

used this value to estimate costs for sediment basins. 

Capital and annual cost data for basins were standardized to 2008 dollars on the basis of the 

Engineering News-Record (ENR) Construction Cost Index (CCI). The sediment basin cost 

reference used by EPA was based on a study completed in 1989. The ENR CCI in 1989 was 

4,615, and the value in February of 2008 was 8,084. EPA adjusted sediment basin costs obtained 

in 1989 dollars to 2008 dollars by increasing costs by 57 percent (8,084 / 4,615 = 1.57). All other 

data was obtained in 2008 and 2009, so no standardization was necessary to arrive at year 2008 

costs. Table 9-11 shows the baseline sediment basin size, and Table 9-12 shows the baseline 

sediment basin costs for each state and the District of Columbia for each of the model site sizes 

greater than 10 acres. 

Table 9-11. Baseline sediment basin size (cubic feet) 

Site size (acres) 

State 12 17 23 34 46 69 85 145 

Alabama 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Arizona 27,048 38,318 51,842 76,636 103,684 155,526 191,815 326,830 

Alaska 6,144 8,704 11,776 17,408 23,552 35,328 43,571 74,240 

Arkansas 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

California 40,662 57,605 77,936 115,209 155,872 233,807 288,362 491,334 

Colorado 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Connecticut 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Delaware 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Florida 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Georgia 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Hawaii 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Idaho 19,020 26,945 36,455 53,890 72,910 109,365 134,884 229,825 

Illinois 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Indiana 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Iowa 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Kansas 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Kentucky 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Louisiana 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Maine 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Maryland 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Massachusetts 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Michigan 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Minnesota 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Mississippi 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Missouri 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Montana 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Nebraska 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Nevada 16,200 22,950 31,050 45,900 62,100 93,150 114,885 195,750 

New 

Hampshire 

43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

New Jersey 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

New Mexico 30,840 43,690 59,110 87,380 118,220 177,330 218,707 372,650 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-21

Site size (acres) 

State 12 17 23 34 46 69 85 145 

New York 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

North Carolina 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

North Dakota 40,332 57,137 77,303 114,274 154,606 231,909 286,021 487,345 

Ohio 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Oklahoma 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Oregon 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Pennsylvania 60,000 85,000 115,000 170,000 230,000 345,000 425,500 725,000 

Rhode Island 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

South Carolina 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

South Dakota 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Tennessee 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Texas 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Utah 37,188 52,683 71,277 105,366 142,554 213,831 263,725 449,355 

Vermont 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Virginia 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Washington 6,144 8,704 11,776 17,408 23,552 35,328 43,571 74,240 

West Virginia 43,200 61,200 82,800 122,400 165,600 248,400 306,360 522,000 

Wisconsin 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Wyoming 21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

District of 

Columbia 

21,600 30,600 41,400 61,200 82,800 124,200 153,180 261,000 

Table 9-12. Baseline sediment basins costs 

Site size (acres) 

State 12 17 23 34 46 69 85 145 

Alabama $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Arizona $17,790 $25,202 $34,097 $50,405 $68,195 $102,292 $126,160 $214,961 

Alaska $4,041 $5,725 $7,745 $11,450 $15,491 $23,236 $28,657 $48,829 

Arkansas $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

California $26,744 $37,887 $51,260 $75,775 $102,519 $153,779 $189,660 $323,158 

Colorado $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Connecticut $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Delaware $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Florida $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Georgia $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Hawaii $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Idaho $12,510 $17,722 $23,977 $35,444 $47,954 $71,931 $88,715 $151,159 

Illinois $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Indiana $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Iowa $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Kansas $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Kentucky $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Louisiana $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Maine $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Maryland $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Massachusetts $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Michigan $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-22

Site size (acres) 

State 12 17 23 34 46 69 85 145 

Minnesota $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Mississippi $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Missouri $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Montana $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Nebraska $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Nevada $10,655 $15,095 $20,422 $30,189 $40,844 $61,266 $75,562 $128,748 

New 

Hampshire 

$28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

New Jersey $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

New Mexico $20,284 $28,736 $38,878 $57,471 $77,755 $116,633 $143,847 $245,098 

New York $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

North Carolina $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

North Dakota $26,527 $37,580 $50,843 $75,160 $101,687 $152,530 $188,120 $320,534 

Ohio $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Oklahoma $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Oregon $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Pennsylvania $39,463 $55,906 $75,637 $111,812 $151,274 $226,912 $279,858 $476,843 

Rhode Island $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

South Carolina $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

South Dakota $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Tennessee $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Texas $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Utah $24,459 $34,650 $46,880 $69,301 $93,760 $140,640 $173,456 $295,548 

Vermont $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Virginia $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Washington $4,041 $5,725 $7,745 $11,450 $15,491 $23,236 $28,657 $48,829 

West Virginia $28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Wisconsin $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

Wyoming $14,207 $20,126 $27,229 $40,252 $54,459 $81,688 $100,749 $171,664 

District of 

Columbia 

$28,413 $40,252 $54,459 $80,504 $108,918 $163,376 $201,498 $343,327 

Under baseline conditions, EPA also calculated costs for installing silt fence and costs for 

installing temporary soil cover. For silt fence, EPA assumes that silt fence would be installed 

around the entire perimeter of the site. The perimeter was calculated assuming the sites were 

square. For temporary cover, EPA assumes that a percentage of the project would require cover, 

ranging from 10 percent for the 1.9-acre model project to 20 percent for the 145-acre model 

project. Costs for silt fence and temporary cover do not vary geographically because the controls 

are only a function of site size. R.S. Means (2000) reports that a 3-foot-tall silt fence installation 

costs between $0.68 and $0.92 per linear foot (for favorable and challenging installations). EPA 

used a cost of $0.92 per linear foot for estimating baseline silt fence costs. For temporary cover, 

EPA used an average cost based on a range of several types of temporary cover (see Table 9-13). 

Table 9-14 shows the baseline costs assumptions for silt fence and temporary cover. 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-23

Table 9-13. Temporary cover costs 

Type 

Installed cost 

(per acre) 

Jute mesh $6,500 

Curled wood fiber $10,500 

Straw $8,900 

Wood fiber $8,900 

Coconut fiber $13,000 

Straw coconut fiber $10,900 

AVERAGE $9,783 

Table 9-14. Baseline silt fence and temporary cover assumptions and costs 

Site size 

(acres) % Cover Cost cover 

Length silt fence 

(ft) Cost silt fence 

1.9 10% $1,859 288 $265 

3.8 10.1% $3,767 407 $374 

6.0 10.3% $6,038 511 $470 

8.5 10.5% $8,699 608 $559 

12.0 10.7% $12,569 723 $665 

17.0 11.1% $18,387 861 $792 

23.0 11.5% $25,820 1,001 $921 

34.0 12.2% $40,727 1,217 $1,120 

46.0 13.1% $58,876 1,416 $1,303 

69.0 14.7% $99,167 1,734 $1,595 

85.1 15.8% $131,675 1,925 $1,771 

145.0 20% $283,717 2,513 $2,312 

EPA also estimated costs for installing surface outlets on basins. EPA developed these costs on 

the basis of an assumed 3-day drain time for sediment basins and assumptions about the number 

of basins contained on projects of different sizes in Table 9-15. Surface outlet costs are a 

function of the outlet size, which is a function of the flowrate needed to drain the basin in the 

specified period. Table 9-16 shows the assumptions used to develop costs for outlets of various 

size. Table 9-17 shows the per-state costs for surface outlets for the various model project sizes. 

When calculating costs for linear projects, the per-project costs in Table 9-16 were multiplied by 

3 to account for the larger number of basins that might be present on linear projects. 

Table 9-15. Basin assumptions 

Site size 

(acres) # of basins 

Site size 

(acres) # of basins 

145 4 34 2 

85.1 3 23 2 

69 3 17 1 

46 2 12 1 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-24

Table 9-16. Surface outlet cost assumptions 

Skimmer 

size 

(inches) 

Price per 

skimmer Shipping 

Ancillary 

equipment 

Installation 

labor 

Cubic feet 

drained 

per day 

Cubic feet 

drained 

over 3 

days Total cost

1.5 $435 $20 $30 $600 1,728 5,184 $1,085 

2 $535 $20 $30 $600 3,283 9,849 $1,185 

2.5 $660 $22 $30 $600 6,234 18,702 $1,312 

3 $795 $25 $30 $600 9,774 29,322 $1,450 

4 $1,135 $32 $30 $600 20,109 60,327 $1,797 

5 $1,655 $155 $30 $600 32,832 98,496 $2,440 

6 $2,470 $280 $30 $600 51,840 155,520 $3,380 

8 $3,900 $500 $30 $600 97,978 293,934 $5,030 

Notes: 

- Faircloth recommends 3 days to drain. EPA used 3 days for all states for cost estimates. 

- Ancillary costs (pipe, glue) estimated as $30 for all sizes. 

- Assumed 8 hours assembly time x $75/hour for installation. 

Table 9-17. Costs for surface outlets 

Site size (acres) 

State 12 17 23 34 46 69 85.1 145 

Alabama $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Alaska $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Arizona $1,450 $1,797 $2,900 $3,594 $3,594 $5,391 $7,320 $9,760 

Arkansas $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

California $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Colorado $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Connecticut $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Delaware $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

District of 

Columbia 

$1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Florida $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Georgia $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Hawaii $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Idaho $1,450 $1,450 $2,624 $2,900 $3,594 $5,391 $5,391 $7,188 

Illinois $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Indiana $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Iowa $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Kansas $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Kentucky $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Louisiana $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Maine $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Maryland $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Massachusetts $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Michigan $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Minnesota $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Mississippi $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Missouri $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Montana $1,450 $1,797 $2,900 $3,594 $3,594 $5,391 $5,391 $9,760 

Nebraska $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-25

Site size (acres) 

State 12 17 23 34 46 69 85.1 145 

Nevada $1,312 $1,450 $2,624 $2,900 $3,594 $5,391 $5,391 $7,188 

New Hampshire $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

New Jersey $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

New Mexico $1,797 $1,797 $2,900 $3,594 $3,594 $5,391 $7,320 $13,520 

New York $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

North Carolina $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

North Dakota $1,797 $1,797 $3,594 $3,594 $4,880 $7,320 $7,320 $13,520 

Ohio $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Oklahoma $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Oregon $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Pennsylvania $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Rhode Island $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

South Carolina $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

South Dakota $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Tennessee $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Texas $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Utah $1,450 $1,797 $2,900 $3,594 $3,594 $5,391 $7,320 $9,760 

Vermont $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Virginia $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Washington $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

West Virginia $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Wisconsin $1,797 $2,440 $3,594 $4,880 $4,880 $7,320 $7,320 $13,520 

Wyoming $1,797 $1,797 $3,594 $3,594 $4,880 $7,320 $7,320 $13,520 

9.3.2. PASSIVE TREATMENT COSTS 

EPA estimated costs for passive treatment on the basis of implementing a liquid polymer dosing 

system for sediment basins and compost filter berms. For a liquid polymer dosing system, a 

study conducted in Auckland, New Zealand, indicates that the cost for a rainfall-driven system 

ranges from $2,400 NZ to $12,000 NZ ($1,600 to $8,000 U.S.). EPA used the average of the two 

values, $4,800, as an estimate of the cost for implementing such a system at each sediment basin. 

EPA also estimated using best professional judgment (BPJ) that $500 per month, per system, 

would be required for operation and maintenance. Chemical requirements were based on an 

estimate of $1,000 per million gallons treated. EPA made various assumptions about the number 

of laborers and the hours of labor per storm event required for sampling. Those assumptions, as 

well as the costs for labor (assuming a labor rate of $30 per hour) and the polymer dosing system 

costs are presented in Table 9-18 for the various model project sizes. 

For filter berms, EPA used the same assumptions used for estimating silt fence length under 

baseline conditions (berms installed around the entire perimeter). EPA used a cost of $1.70 per 

linear foot installed. The costs assumptions for filter berms are in Table 9-19. 

Tables 9-20 through 9-22 show monthly treatment volumes and associated monthly costs for 

passive treatment. Appendix I shows the per-project costs for all options. 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-26

Table 9-18. Passive treatment unit costs: polymer dosing system and labor 

Site size 

(acres) # Basins 

Cost 

polymer 

dosing 

system 

Monthly 

O&M 

Sampling 

laborers 

# Events 

per month 

monitored 

Labor 

hours 

per 

event 

Labor 

cost 

per 

event 

Monthly 

labor cost

1.9 0 $- $- 1 2 4 $120 $240 

3.8 1 $4,800 $500 1 2 4 $120 $240 

6.0 1 $4,800 $500 1 2 4 $120 $240 

8.5 1 $4,800 $500 1 2 4 $120 $240 

12.0 1 $4,800 $500 1 2 4 $120 $240 

17.0 1 $4,800 $500 1 2 4 $120 $240 

23.0 2 $9,600 $1,000 1 2 4 $120 $240 

34.0 2 $9,600 $1,000 1 2 4 $120 $240 

46.0 2 $9,600 $1,000 2 2 4 $240 $480 

69.0 3 $14,400 $1,500 2 2 4 $240 $480 

85.1 3 $14,400 $1,500 2 2 4 $240 $480 

145.0 4 $19,200 $2,000 3 2 4 $360 $720 

Table 9-19. Passive treatment unit costs: filter berms 

Site size 

(acres) 

Project 

length 

(ft) 

Length filter 

berms 

(ft) 

Cost filter 

berms 

1.9 72 288 $490 

3.8 102 407 $692 

6.0 128 511 $869 

8.5 152 608 $1,034 

12.0 181 723 $1,229 

17.0 215 861 $1,464 

23.0 250 1,001 $1,702 

34.0 304 1,217 $2,069 

46.0 354 1,416 $2,407 

69.0 434 1,734 $2,948 

85.1 481 1,925 $3,273 

145.0 628 2,513 $4,272 
9-27 

Table 9-20. Monthly treatment volumes for passive treatment (gallons) 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 Alabama 84,331 168,662 266,308 377,270 532,617 754,540 1,020,849 1,509,081 2,041,697 3,062,546 Alaska 60,638 121,275 191,487 271,273 382,974 542,546 734,033 1,085,092 1,468,066 2,202,099 Arizona 13,309 26,617 42,028 59,539 84,055 119,078 161,106 238,156 322,212 483,317 Arkansas 81,888 163,775 258,593 366,340 517,185 732,679 991,272 1,465,359 1,982,544 2,973,816 California 31,628 63,256 99,878 141,494 199,756 282,988 382,866 565,976 765,732 1,148,598 Colorado 22,885 45,770 72,269 102,381 144,537 204,761 277,030 409,522 554,060 831,089 Connecticut 76,378 152,755 241,193 341,690 482,385 683,379 924,572 1,366,758 1,849,143 2,773,715 Delaware 73,984 147,968 233,634 330,981 467,267 661,962 895,596 1,323,924 1,791,191 2,686,787 District of Columbia 

72,714 145,427 229,622 325,298 459,245 650,597 880,219 1,301,193 1,760,438 2,640,657 

Florida 106,642 213,284 336,764 477,083 673,528 954,165 1,290,930 1,908,331 2,581,859 3,872,789 Georgia 87,456 174,911 276,176 391,249 552,352 782,499 1,058,674 1,564,997 2,117,349 3,176,023 Hawaii 31,452 62,905 99,323 140,708 198,647 281,417 380,740 562,833 761,480 1,142,220 Idaho 19,491 38,983 61,552 87,198 123,104 174,397 235,949 348,794 471,897 707,846 Illinois 56,824 113,648 179,444 254,213 358,888 508,425 687,869 1,016,850 1,375,739 2,063,608 Indiana 68,246 136,492 215,514 305,312 431,028 610,623 826,137 1,221,247 1,652,275 2,478,412 Iowa 54,449 108,899 171,945 243,589 343,891 487,178 659,124 974,357 1,318,248 1,977,371 Kansas 63,087 126,174 199,222 282,231 398,443 564,462 763,683 1,128,923 1,527,367 2,291,050 Kentucky 77,407 154,815 244,445 346,297 488,889 692,593 937,038 1,385,186 1,874,076 2,811,113 Louisiana 101,070 202,140 319,168 452,155 638,336 904,309 1,223,478 1,808,619 2,446,955 3,670,433 Maine 71,652 143,304 226,269 320,548 452,538 641,095 867,364 1,282,190 1,734,728 2,602,092 Maryland 72,714 145,427 229,622 325,298 459,245 650,597 880,219 1,301,193 1,760,438 2,640,657 Massachusetts 72,921 145,842 230,277 326,226 460,554 652,451 882,728 1,304,902 1,765,456 2,648,184 Michigan 52,076 104,152 164,451 232,972 328,902 465,944 630,395 931,888 1,260,789 1,891,184 Minnesota 49,451 98,902 156,161 221,228 312,322 442,456 598,617 884,912 1,197,234 1,795,850 Mississippi 90,244 180,489 284,982 403,724 569,964 807,449 1,092,431 1,614,898 2,184,862 3,277,293 Missouri 63,161 126,323 199,457 282,564 398,914 565,129 764,586 1,130,257 1,529,172 2,293,758 Montana 20,256 40,513 63,968 90,621 127,935 181,242 245,209 362,484 490,419 735,628 Nebraska 48,692 97,383 153,763 217,831 307,526 435,661 589,424 871,323 1,178,848 1,768,273 Nevada 6,567 13,134 20,738 29,378 41,475 58,757 79,495 117,514 158,989 238,484 New Hampshire 69,179 138,357 218,459 309,483 436,917 618,966 837,425 1,237,932 1,674,849 2,512,274 New Jersey 80,817 161,633 255,210 361,548 510,421 723,096 978,307 1,446,193 1,956,613 2,934,920 
9-28 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 New Mexico 26,580 53,160 83,937 118,911 167,875 237,823 321,760 475,645 643,520 965,281 New York 63,472 126,943 200,437 283,953 400,874 567,905 768,342 1,135,810 1,536,684 2,305,027 North Carolina 74,271 148,541 234,539 332,263 469,077 664,526 899,065 1,329,052 1,798,129 2,697,194 North Dakota 27,663 55,327 87,358 123,757 174,715 247,513 334,871 495,027 669,742 1,004,613 Ohio 64,983 129,967 205,211 290,715 410,421 581,430 786,641 1,162,860 1,573,282 2,359,922 Oklahoma 56,430 112,861 178,201 252,451 356,402 504,903 683,104 1,009,805 1,366,207 2,049,311 Oregon 70,026 140,052 221,135 313,274 442,270 626,549 847,684 1,253,098 1,695,368 2,543,051 Pennsylvania 71,565 143,130 225,994 320,158 451,988 640,316 866,310 1,280,633 1,732,621 2,598,931 Rhode Island 76,941 153,883 242,973 344,211 485,945 688,423 931,395 1,376,845 1,862,790 2,794,185 South Carolina 78,161 156,322 246,824 349,668 493,649 699,336 946,160 1,398,672 1,892,321 2,838,481 South Dakota 27,679 55,358 87,407 123,826 174,813 247,652 335,059 495,305 670,118 1,005,177 Tennessee 79,292 158,584 250,396 354,727 500,791 709,454 959,850 1,418,908 1,919,700 2,879,549 Texas 55,927 111,855 176,613 250,201 353,225 500,403 677,015 1,000,805 1,354,030 2,031,046 Utah 25,034 50,068 79,055 111,994 158,110 223,989 303,043 447,977 606,087 909,130 Vermont 58,475 116,950 184,657 261,598 369,315 523,196 707,854 1,046,392 1,415,707 2,123,561 Virginia 69,392 138,784 219,132 310,438 438,265 620,875 840,007 1,241,750 1,680,015 2,520,022 Washington 60,638 121,275 191,487 271,273 382,974 542,546 734,033 1,085,092 1,468,066 2,202,099 West Virginia 73,641 147,283 232,552 329,449 465,104 658,897 891,449 1,317,794 1,782,898 2,674,347 Wisconsin 54,119 108,239 170,903 242,113 341,807 484,226 655,130 968,453 1,310,260 1,965,390 Wyoming 25,340 50,679 80,020 113,361 160,040 226,723 306,743 453,446 613,485 920,228 
9-29 

Table 9-21. Monthly chemical cost for passive treatment 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 Alabama $84 $169 $266 $377 $533 $755 $1,021 $1,509 $2,042 $3,06Alaska $61 $121 $191 $271 $383 $543 $734 $1,085 $1,468 $2,20Arizona $13 $27 $42 $60 $84 $119 $161 $238 $322 $48Arkansas $82 $164 $259 $366 $517 $733 $991 $1,465 $1,983 $2,97California $32 $63 $100 $141 $200 $283 $383 $566 $766 $1,14Colorado $23 $46 $72 $102 $145 $205 $277 $410 $554 $83Connecticut $76 $153 $241 $342 $482 $683 $925 $1,367 $1,849 $2,77Delaware $74 $148 $234 $331 $467 $662 $896 $1,324 $1,791 $2,68District of Columbia 

$73 $145 $230 $325 $459 $651 $880 $1,301 $1,760 $2,64

Florida $107 $213 $337 $477 $674 $954 $1,291 $1,908 $2,582 $3,87Georgia $87 $175 $276 $391 $552 $782 $1,059 $1,565 $2,117 $3,17Hawaii $31 $63 $99 $141 $199 $281 $381 $563 $761 $1,14Idaho $19 $39 $62 $87 $123 $174 $236 $349 $472 $70Illinois $57 $114 $179 $254 $359 $508 $688 $1,017 $1,376 $2,06Indiana $68 $136 $216 $305 $431 $611 $826 $1,221 $1,652 $2,47Iowa $54 $109 $172 $244 $344 $487 $659 $974 $1,318 $1,97Kansas $63 $126 $199 $282 $398 $564 $764 $1,129 $1,527 $2,29Kentucky $77 $155 $244 $346 $489 $693 $937 $1,385 $1,874 $2,81Louisiana $101 $202 $319 $452 $638 $904 $1,223 $1,809 $2,447 $3,67Maine $72 $143 $226 $321 $453 $641 $867 $1,282 $1,735 $2,60Maryland $73 $145 $230 $325 $459 $651 $880 $1,301 $1,760 $2,64Massachusetts $73 $146 $230 $326 $461 $652 $883 $1,305 $1,765 $2,64Michigan $52 $104 $164 $233 $329 $466 $630 $932 $1,261 $1,89Minnesota $49 $99 $156 $221 $312 $442 $599 $885 $1,197 $1,79Mississippi $90 $180 $285 $404 $570 $807 $1,092 $1,615 $2,185 $3,27Missouri $63 $126 $199 $283 $399 $565 $765 $1,130 $1,529 $2,29Montana $20 $41 $64 $91 $128 $181 $245 $362 $490 $73Nebraska $49 $97 $154 $218 $308 $436 $589 $871 $1,179 $1,76Nevada $7 $13 $21 $29 $41 $59 $79 $118 $159 $23New Hampshire $69 $138 $218 $309 $437 $619 $837 $1,238 $1,675 $2,51New Jersey $81 $162 $255 $362 $510 $723 $978 $1,446 $1,957 $2,93New Mexico $27 $53 $84 $119 $168 $238 $322 $476 $644 $96
9-30 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 New York $63 $127 $200 $284 $401 $568 $768 $1,136 $1,537 $2,30North Carolina $74 $149 $235 $332 $469 $665 $899 $1,329 $1,798 $2,69North Dakota $28 $55 $87 $124 $175 $248 $335 $495 $670 $1,00Ohio $65 $130 $205 $291 $410 $581 $787 $1,163 $1,573 $2,36Oklahoma $56 $113 $178 $252 $356 $505 $683 $1,010 $1,366 $2,04Oregon $70 $140 $221 $313 $442 $627 $848 $1,253 $1,695 $2,54Pennsylvania $72 $143 $226 $320 $452 $640 $866 $1,281 $1,733 $2,59Rhode Island $77 $154 $243 $344 $486 $688 $931 $1,377 $1,863 $2,79South Carolina $78 $156 $247 $350 $494 $699 $946 $1,399 $1,892 $2,83South Dakota $28 $55 $87 $124 $175 $248 $335 $495 $670 $1,00Tennessee $79 $159 $250 $355 $501 $709 $960 $1,419 $1,920 $2,88Texas $56 $112 $177 $250 $353 $500 $677 $1,001 $1,354 $2,03Utah $25 $50 $79 $112 $158 $224 $303 $448 $606 $90Vermont $58 $117 $185 $262 $369 $523 $708 $1,046 $1,416 $2,12Virginia $69 $139 $219 $310 $438 $621 $840 $1,242 $1,680 $2,52Washington $61 $121 $191 $271 $383 $543 $734 $1,085 $1,468 $2,20West Virginia $74 $147 $233 $329 $465 $659 $891 $1,318 $1,783 $2,67Wisconsin $54 $108 $171 $242 $342 $484 $655 $968 $1,310 $1,96Wyoming $25 $51 $80 $113 $160 $227 $307 $453 $613 $92
9-31 

Table 9-22. Total monthly cost for passive treatment 

Site Size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 Alabama $324 $909 $1,006 $1,117 $1,273 $1,495 $2,261 $2,749 $3,522 $5,04Alaska $301 $861 $931 $1,011 $1,123 $1,283 $1,974 $2,325 $2,948 $4,18Arizona $253 $767 $782 $800 $824 $859 $1,401 $1,478 $1,802 $2,46Arkansas $322 $904 $999 $1,106 $1,257 $1,473 $2,231 $2,705 $3,463 $4,95California $272 $803 $840 $881 $940 $1,023 $1,623 $1,806 $2,246 $3,12Colorado $263 $786 $812 $842 $885 $945 $1,517 $1,650 $2,034 $2,81Connecticut $316 $893 $981 $1,082 $1,222 $1,423 $2,165 $2,607 $3,329 $4,75Delaware $314 $888 $974 $1,071 $1,207 $1,402 $2,136 $2,564 $3,271 $4,66District of Columbia 

$313 $885 $970 $1,065 $1,199 $1,391 $2,120 $2,541 $3,240 $4,62

Florida $347 $953 $1,077 $1,217 $1,414 $1,694 $2,531 $3,148 $4,062 $5,85Georgia $327 $915 $1,016 $1,131 $1,292 $1,522 $2,299 $2,805 $3,597 $5,15Hawaii $271 $803 $839 $881 $939 $1,021 $1,621 $1,803 $2,241 $3,12Idaho $259 $779 $802 $827 $863 $914 $1,476 $1,589 $1,952 $2,68Illinois $297 $854 $919 $994 $1,099 $1,248 $1,928 $2,257 $2,856 $4,04Indiana $308 $876 $956 $1,045 $1,171 $1,351 $2,066 $2,461 $3,132 $4,45Iowa $294 $849 $912 $984 $1,084 $1,227 $1,899 $2,214 $2,798 $3,95Kansas $303 $866 $939 $1,022 $1,138 $1,304 $2,004 $2,369 $3,007 $4,27Kentucky $317 $895 $984 $1,086 $1,229 $1,433 $2,177 $2,625 $3,354 $4,79Louisiana $341 $942 $1,059 $1,192 $1,378 $1,644 $2,463 $3,049 $3,927 $5,65Maine $312 $883 $966 $1,061 $1,193 $1,381 $2,107 $2,522 $3,215 $4,58Maryland $313 $885 $970 $1,065 $1,199 $1,391 $2,120 $2,541 $3,240 $4,62Massachusetts $313 $886 $970 $1,066 $1,201 $1,392 $2,123 $2,545 $3,245 $4,62Michigan $292 $844 $904 $973 $1,069 $1,206 $1,870 $2,172 $2,741 $3,87Minnesota $289 $839 $896 $961 $1,052 $1,182 $1,839 $2,125 $2,677 $3,77Mississippi $330 $920 $1,025 $1,144 $1,310 $1,547 $2,332 $2,855 $3,665 $5,25Missouri $303 $866 $939 $1,023 $1,139 $1,305 $2,005 $2,370 $3,009 $4,27Montana $260 $781 $804 $831 $868 $921 $1,485 $1,602 $1,970 $2,71Nebraska $289 $837 $894 $958 $1,048 $1,176 $1,829 $2,111 $2,659 $3,74Nevada $247 $753 $761 $769 $781 $799 $1,319 $1,358 $1,639 $2,21New Hampshire $309 $878 $958 $1,049 $1,177 $1,359 $2,077 $2,478 $3,155 $4,49New Jersey $321 $902 $995 $1,102 $1,250 $1,463 $2,218 $2,686 $3,437 $4,91New Mexico $267 $793 $824 $859 $908 $978 $1,562 $1,716 $2,124 $2,94
9-32 

Site Size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 New York $303 $867 $940 $1,024 $1,141 $1,308 $2,008 $2,376 $3,017 $4,28North Carolina $314 $889 $975 $1,072 $1,209 $1,405 $2,139 $2,569 $3,278 $4,67North Dakota $268 $795 $827 $864 $915 $988 $1,575 $1,735 $2,150 $2,98Ohio $305 $870 $945 $1,031 $1,150 $1,321 $2,027 $2,403 $3,053 $4,34Oklahoma $296 $853 $918 $992 $1,096 $1,245 $1,923 $2,250 $2,846 $4,02Oregon $310 $880 $961 $1,053 $1,182 $1,367 $2,088 $2,493 $3,175 $4,52Pennsylvania $312 $883 $966 $1,060 $1,192 $1,380 $2,106 $2,521 $3,213 $4,57Rhode Island $317 $894 $983 $1,084 $1,226 $1,428 $2,171 $2,617 $3,343 $4,77South Carolina $318 $896 $987 $1,090 $1,234 $1,439 $2,186 $2,639 $3,372 $4,81South Dakota $268 $795 $827 $864 $915 $988 $1,575 $1,735 $2,150 $2,98Tennessee $319 $899 $990 $1,095 $1,241 $1,449 $2,200 $2,659 $3,400 $4,86Texas $296 $852 $917 $990 $1,093 $1,240 $1,917 $2,241 $2,834 $4,01Utah $265 $790 $819 $852 $898 $964 $1,543 $1,688 $2,086 $2,88Vermont $298 $857 $925 $1,002 $1,109 $1,263 $1,948 $2,286 $2,896 $4,10Virginia $309 $879 $959 $1,050 $1,178 $1,361 $2,080 $2,482 $3,160 $4,50Washington $301 $861 $931 $1,011 $1,123 $1,283 $1,974 $2,325 $2,948 $4,18West Virginia $314 $887 $973 $1,069 $1,205 $1,399 $2,131 $2,558 $3,263 $4,65Wisconsin $294 $848 $911 $982 $1,082 $1,224 $1,895 $2,208 $2,790 $3,94Wyoming $265 $791 $820 $853 $900 $967 $1,547 $1,693 $2,093 $2,90
Section 9: Estimating Incremental Costs for the Final Regulation 

9-33

9.3.3. ATS COSTS 

EPA estimated costs for ATS using a combination of one-time costs, which accounts for items 

such as site preparation and installing storage, as well as recurring costs that account for items 

such as equipment rental, operator labor, and treatment chemicals. EPA estimates the size of the 

ATS system needed in each state for each model projects size on the basis of the system design 

flowrates in Table 9-9. On the basis of system flowrate, EPA estimated monthly equipment 

rental costs provided in vendor quotes (see Table 7-26) by scaling up the unit costs for a 500-

gpm system to the desired system flowrate. EPA notes that this is a conservative assumption, 

because there are economies of scale that are not captured in this approach. For example, for a 

1,000-gpm system, it might be more economical to rent one larger pump instead of two smaller 

pumps. However, the approach does provide reasonable, albeit conservative, estimates of costs. 

For labor and treatment chemical, the system run-time was estimated on the basis of the monthly 

treatment volumes (including an additional 10 percent for system startup and shutdown) and the 

associated chemical dosage rate and pump and generator fuel consumption. Operator labor was 

also included. For storage, EPA estimated basin storage volumes to impound runoff from the 2-

year, 24-hour storm. If that volume was larger than the incremental sediment basin storage 

requirements contained in existing state permits, additional costs for storage were also calculated 

using the same methodology for estimating sediment basin costs described above. Costs were 

also estimated for periodic equipment servicing and for providing a stabilized pad consisting of 

crushed stone. 

Table 9-23 shows the cost assumptions used for an ATS system for a flowrate of 500 gpm. For 

larger systems, costs were estimated as multiples of the values found in Table 9-24. For the 100-

gpm system, it was assumed that a trailer-mounted system would be used with a rental cost of 

$10,000 per month. 

Tables 9-24 and 9-25 show the one-time ATS and monthly ATS costs for the 12 model project 

sizes. Additional details of the costing approach are in the C&D Cost Spreadsheet Models. The 

ATS Cost Spreadsheet Model (DCN 43119) was used to estimate ATS treatment costs and 

storage costs, while the Unit Cost Spreadsheet Model (DCN 43120) was used to estimate ESC 

and passive treatment costs. The per-project costs under each of the regulatory options are in 

Appendix I. Model project costs were scaled to the national level using the distribution of 

projects described earlier. National compliance costs are described in the Economic Analysis for 

Final Effluent Guidelines and Standards for the Construction and Development Category

(USEPA 2009). 
Section 9: Estimating Incremental Costs for the Final Regulation 

9-34

Table 9-23. ATS costs: 500-gpm system 

Equipment rental $/month Quantity Total $/mo 

Filter $4,000 1 $4,000 

System $4,000 1 $4,000 

Pump $1,650 2 $3,300 

Hose $98 4 $392 

Elbow $36 2 $72 

Genset $1,050 1 $1,050 

Tanks $1,260 2 $2,520 

 Total Monthly Costs $15,334 

One-Time Costs 

Delivery $1,485 

Pick-up $1,485 

Stabilized pad (1600 SF @ $0.50/SF) $800 

Calibration $1,300 

Pipes, valves, electrical $6,000 

Installation $7,500 

Misc. lab equipment & supplies $4,250 

Sand and gravel $1,222 

Total One-Time Costs $24,042 

Labor, O&M and Materials 

# Laborers 1 

Labor rate ($/hr) $75 

Fuel ($/hr) $30 3 units @ 10 GPH per unit 

Total labor + fuel ($/hr) $105 

 

 $/service # units Total 

Equipment servicing (every 250 hrs) $300 3 $900 

 Chitosan ($/Mgal) $982 
9-35 

Table 9-24. One-time ATS costs model projects 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 Alabama $21,886 $34,380 $63,497 $79,937 $102,952 $135,831 $175,286 $267,412 $346,322 $517,3Alaska $13,220 $17,047 $21,479 $26,516 $33,567 $58,290 $70,377 $92,538 $116,713 $163,04Arizona $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,042 $24,04Arkansas $18,863 $28,334 $53,951 $66,413 $83,860 $108,784 $138,693 $213,318 $273,136 $407,57California $10,029 $10,665 $11,403 $12,240 $13,413 $29,739 $31,749 $35,435 $39,457 $47,16Colorado $11,748 $14,103 $16,831 $19,930 $24,270 $45,118 $52,557 $66,195 $81,072 $109,58Connecticut $13,695 $17,997 $22,979 $43,290 $51,216 $62,539 $76,126 $101,035 $148,002 $200,08Delaware $14,249 $19,107 $24,731 $45,773 $54,720 $67,503 $82,842 $110,964 $161,435 $220,23District of Columbia 

$14,082 $18,772 $24,202 $45,023 $53,663 $66,005 $80,815 $107,968 $157,381 $214,15

Florida $21,602 $33,813 $62,601 $78,668 $101,160 $133,293 $191,644 $262,336 $359,247 $526,84Georgia $18,413 $27,435 $37,880 $64,400 $81,019 $104,759 $133,247 $205,268 $262,244 $391,24Hawaii $20,974 $32,556 $60,616 $75,855 $97,190 $127,669 $184,035 $251,088 $344,028 $504,02Idaho $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,04Illinois $13,130 $16,867 $21,195 $26,113 $47,649 $57,485 $69,288 $90,928 $134,326 $179,5Indiana $15,850 $22,308 $29,786 $52,934 $64,831 $81,826 $102,221 $139,610 $200,191 $278,3Iowa $14,311 $19,229 $24,925 $46,047 $55,107 $68,051 $83,584 $112,060 $162,917 $222,45Kansas $15,312 $21,231 $28,086 $50,525 $61,429 $77,007 $95,701 $129,972 $187,151 $258,8Kentucky $13,646 $17,900 $22,825 $43,072 $50,908 $62,103 $75,536 $100,163 $146,822 $198,3Louisiana $24,435 $54,129 $71,547 $91,341 $119,053 $158,641 $225,938 $313,032 $427,834 $629,73Maine $13,321 $17,250 $21,799 $26,969 $48,856 $59,196 $71,603 $94,349 $138,955 $186,5Maryland $14,082 $18,772 $24,202 $45,023 $53,663 $66,005 $80,815 $107,968 $157,381 $214,15Massachusetts $13,612 $17,832 $22,719 $42,921 $50,695 $61,801 $75,127 $99,560 $146,005 $197,09Michigan $10,554 $11,716 $13,062 $14,591 $16,732 $34,440 $38,111 $44,839 $52,179 $86,04Minnesota $12,700 $16,008 $19,838 $24,190 $44,934 $53,639 $64,084 $83,235 $104,127 $163,96Mississippi $20,073 $30,754 $57,771 $71,825 $91,500 $119,607 $153,336 $234,965 $302,423 $451,50Missouri $15,608 $21,824 $29,021 $51,850 $63,300 $79,657 $99,286 $155,064 $194,322 $289,35Montana $9,577 $9,762 $9,976 $10,219 $10,560 $11,047 $11,631 $27,352 $28,520 $30,75Nebraska $14,241 $19,089 $24,704 $31,083 $54,665 $67,425 $82,736 $110,808 $141,431 $219,9Nevada $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,04New Hampshire 

$12,471 $15,550 $19,116 $23,167 $43,489 $51,592 $61,316 $79,143 $98,590 $155,65
9-36 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 New Jersey $16,997 $24,603 $33,409 $58,066 $72,076 $92,091 $116,108 $160,139 $227,965 $320,03New Mexico $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,042 $24,042 $24,04New York $13,361 $17,330 $21,925 $27,148 $49,109 $59,553 $72,087 $95,065 $139,924 $187,96North Carolina $16,995 $24,598 $33,401 $58,055 $72,060 $92,068 $116,077 $160,094 $227,905 $319,94North Dakota $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,042 $24,042 $24,04Ohio $14,967 $20,541 $26,996 $34,332 $59,251 $73,921 $91,526 $123,800 $159,009 $246,28Oklahoma $16,370 $23,348 $31,428 $55,260 $68,114 $86,478 $108,514 $168,705 $212,777 $317,04Oregon $11,760 $14,128 $16,870 $19,986 $38,998 $45,230 $52,709 $66,419 $81,375 $129,83Pennsylvania $12,834 $16,275 $20,260 $39,438 $45,778 $54,835 $65,703 $85,628 $127,156 $168,8Rhode Island $16,189 $22,986 $30,856 $54,449 $66,970 $84,856 $106,320 $145,671 $208,390 $290,66South Carolina $15,835 $22,278 $29,739 $52,867 $64,736 $81,692 $102,039 $159,134 $199,828 $297,6South Dakota $10,823 $12,254 $13,911 $15,793 $18,429 $36,844 $41,363 $49,647 $58,684 $95,79Tennessee $15,009 $20,626 $27,131 $49,172 $59,519 $74,301 $92,040 $124,561 $179,830 $247,82Texas $17,893 $26,395 $50,889 $62,075 $77,735 $100,107 $126,954 $195,965 $249,658 $372,36Utah $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $9,392 $24,042 $24,042 $24,04Vermont $13,822 $18,252 $23,382 $29,211 $52,021 $63,679 $77,669 $103,316 $131,296 $204,7Virginia $13,817 $18,242 $23,366 $43,838 $51,990 $63,634 $77,608 $103,227 $150,967 $204,53Washington $13,220 $17,047 $21,479 $26,516 $33,567 $58,290 $70,377 $92,538 $116,713 $163,04West Virginia $11,990 $14,588 $17,596 $21,015 $40,451 $47,288 $55,492 $70,533 $86,942 $138,18Wisconsin $14,496 $19,599 $25,509 $32,224 $56,275 $69,706 $85,822 $115,370 $147,603 $229,1Wyoming $10,604 $11,816 $13,220 $14,815 $17,048 $20,238 $38,716 $45,733 $53,389 $68,06
9-37 

Table 9-25. Monthly ATS costs for model projects 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 Alabama $11,503 $12,956 $16,594 $17,194 $17,929 $18,979 $20,315 $34,209 $36,122 $54Alaska $11,045 $12,140 $13,400 $14,775 $16,749 $17,976 $18,882 $20,619 $22,431 $26Arizona $10,229 $10,459 $10,724 $11,026 $11,498 $12,102 $12,826 $16,461 $16,934 $17Arkansas $11,461 $12,872 $16,558 $17,143 $17,856 $18,876 $20,175 $34,062 $35,923 $54California $10,545 $11,140 $11,771 $12,488 $13,542 $16,673 $17,221 $18,087 $19,032 $20Colorado $10,394 $10,789 $11,295 $11,814 $12,541 $16,303 $16,645 $17,347 $18,031 $19Connecticut $11,366 $12,682 $14,256 $17,026 $17,692 $18,643 $19,784 $21,951 $35,351 $38Delaware $11,325 $12,600 $14,126 $16,975 $17,620 $18,541 $19,647 $21,749 $35,156 $38District of Columbia 

$11,287 $12,524 $14,006 $16,929 $17,554 $18,448 $19,521 $21,562 $34,977 $38

Florida $11,888 $13,775 $17,003 $17,667 $18,596 $19,999 $33,477 $35,674 $52,728 $69Georgia $11,557 $13,064 $14,859 $17,260 $18,023 $19,112 $20,494 $34,397 $36,376 $55Hawaii $10,542 $11,134 $15,804 $16,000 $16,274 $16,666 $30,296 $30,907 $45,607 $60Idaho $10,336 $10,672 $11,061 $11,553 $12,171 $13,055 $14,166 $16,160 $17,642 $18Illinois $10,979 $12,008 $13,142 $14,481 $17,107 $17,815 $18,664 $20,296 $33,761 $36Indiana $11,226 $12,402 $13,814 $16,779 $17,449 $18,298 $19,318 $21,263 $34,690 $37Iowa $10,938 $11,927 $13,013 $16,487 $17,036 $17,714 $18,528 $20,095 $33,568 $35Kansas $11,137 $12,224 $13,533 $16,670 $17,294 $18,080 $19,023 $20,826 $34,270 $36Kentucky $11,384 $12,718 $14,312 $17,048 $17,722 $18,686 $19,843 $22,039 $35,434 $38Louisiana $11,792 $16,291 $16,919 $17,549 $18,430 $19,688 $33,250 $35,215 $52,213 $68Maine $11,285 $12,519 $13,999 $15,674 $17,550 $18,443 $19,513 $21,551 $34,966 $38Maryland $11,303 $12,556 $14,057 $16,948 $17,582 $18,488 $19,574 $21,641 $35,053 $38Massachusetts $11,307 $12,563 $14,068 $16,953 $17,588 $18,496 $19,586 $21,659 $35,070 $38Michigan $10,897 $11,845 $12,884 $14,115 $15,818 $17,614 $18,392 $19,819 $21,450 $35Minnesota $10,852 $11,754 $12,741 $13,912 $16,812 $17,503 $18,242 $19,596 $21,149 $35Mississippi $11,605 $13,160 $16,683 $17,319 $18,106 $19,230 $20,653 $34,564 $36,603 $55Missouri $11,138 $12,227 $13,537 $16,671 $17,297 $18,083 $19,027 $32,937 $34,276 $51Montana $10,349 $10,698 $11,152 $11,612 $12,255 $13,173 $14,325 $17,124 $17,730 $18Nebraska $10,839 $11,728 $12,700 $13,854 $16,789 $17,471 $18,198 $19,532 $21,062 $35Nevada $10,113 $10,226 $10,357 $10,506 $10,715 $11,012 $11,420 $12,075 $16,086 $16New Hampshire 

$11,242 $12,434 $13,864 $15,433 $17,476 $18,338 $19,372 $21,342 $23,484 $37

New Jersey $11,443 $12,835 $14,498 $17,120 $17,824 $18,831 $20,113 $22,327 $35,836 $39
9-38 

Site size (acres) 1.9 3.8 6.0 8.5 12.0 17.0 23.0 34.0 46.0 69.0 New Mexico $10,458 $10,916 $11,496 $12,099 $12,943 $14,198 $16,932 $17,660 $18,454 $20New York $11,144 $12,237 $13,554 $14,993 $17,306 $18,096 $19,045 $20,859 $34,302 $37North Carolina $11,330 $12,610 $14,142 $16,981 $17,629 $18,554 $19,663 $21,773 $35,179 $38North Dakota $10,477 $10,953 $11,555 $12,183 $13,061 $14,365 $16,994 $17,751 $18,578 $20Ohio $11,170 $12,290 $13,636 $15,110 $17,351 $18,160 $19,131 $20,987 $23,004 $37Oklahoma $10,972 $11,995 $13,121 $16,529 $17,095 $17,798 $18,641 $32,533 $33,729 $50Oregon $11,257 $12,463 $13,911 $15,548 $17,502 $18,374 $19,420 $21,414 $23,581 $37Pennsylvania $11,283 $12,516 $13,994 $16,924 $17,548 $18,439 $19,508 $21,544 $34,959 $37Rhode Island $11,376 $12,702 $14,287 $17,038 $17,708 $18,667 $19,816 $21,999 $35,396 $38South Carolina $11,397 $12,744 $14,353 $17,064 $17,745 $18,718 $19,961 $33,838 $35,621 $53South Dakota $10,477 $10,954 $11,556 $12,184 $13,062 $16,506 $16,994 $17,753 $18,580 $32Tennessee $11,416 $12,783 $14,415 $17,088 $17,779 $18,766 $20,026 $22,198 $35,712 $38Texas $10,964 $11,977 $16,170 $16,518 $17,080 $17,777 $18,613 $32,503 $33,688 $50Utah $10,431 $10,863 $11,412 $11,980 $12,775 $13,960 $15,322 $17,529 $18,277 $19Vermont $11,008 $12,065 $13,232 $14,608 $17,157 $17,885 $18,759 $20,436 $22,183 $36Virginia $11,246 $12,442 $13,876 $16,803 $17,483 $18,347 $19,384 $21,360 $34,783 $37Washington $11,045 $12,140 $13,400 $14,775 $16,749 $17,976 $18,882 $20,619 $22,431 $26West Virginia $11,319 $12,588 $14,107 $15,827 $17,610 $18,527 $19,627 $21,720 $23,996 $38Wisconsin $10,933 $11,915 $12,995 $14,272 $17,026 $17,700 $18,509 $20,067 $21,684 $35Wyoming $10,437 $10,873 $11,429 $12,003 $12,808 $14,007 $16,786 $17,555 $18,312 $19
Section 9: Estimating Incremental Costs for the Final Regulation 

9-39

9.4. REFERENCES 

CSQA (California Stormwater Quality Association). 2003. Stormwater BMP Handbook: 

Construction. California Stormwater Quality Association, Menlo Park, CA. 

<http://www.cabmphandbooks.com/Construction.asp>. 

SWRPC (Southeastern Wisconsin Regional Planning Commission). 1991. Costs of Urban 

Nonpoint Source Water Pollution Control Measures. Technical Report No. 31. Southeastern 

Wisconsin Regional Planning Commission, Waukesha, WI. 

USDA (U.S. Department of Agriculture). 1986. Urban Hydrology for Small Watersheds. 

Technical Release 55 (TR55). U.S. Department of Agriculture, Washington, DC. 

USEPA (U.S. Environmental Protection Agency). 2009. Economic Analysis for Final Effluent 

Guidelines and Standards for the Construction and Development Category (EPA-821-R-09-

011). U.S. Environmental Protection Agency, Office of Water, Washington, DC. 

USEPA (U.S. Environmental Protection Agency). 1993. Guidance Specifying Management 

Measures for Sources of Nonpoint Pollution in Coastal Waters. EPA-840-B-92-002. U.S. 

Environmental Protection Agency, Office of Water, Washington, DC. 
Section 10: Estimating Pollutant Load Reductions 

10-1 

10. ESTIMATING POLLUTANT LOAD REDUCTIONS 

10.1. OVERVIEW OF APPROACH 

Estimating the performance of the variety of erosion and sediment controls (ESCs) likely to be 

employed at construction sites, given the array of site conditions, site geometries, soil types and 

rainfall conditions nationally is an extremely complicated undertaking. Models do exist (such as 

SEDCAD and SEDIMOT III) that can be used to estimate, for a given set of site conditions and 

for a given storm event, the sediment generation, sediment transport, and sediment removals 

through BMPs. However, a significant amount of data regarding site conditions, watershed 

parameters and design features of various control structures is needed. Given the range of 

possible conditions nationally, U.S. Environmental Protection Agency (EPA) determined that 

basing a national loading reductions estimate on an input parameter-intensive model such as 

SEDCAD was not feasible for this analysis. Therefore, EPA developed a relatively 

straightforward approach to estimate loading reductions estimates for the regulatory options 

considered. 

EPA used a model site approach to estimate baseline sediment loads and to estimate loading 

reductions for the Construction and Development (C&D) industry under the regulatory options 

evaluated. EPA used the Revised Universal Soil Loss Equation (RUSLE) to estimate loads and 

load reductions at the Reach File Version 1.0 (RF1) scale. This approach consisted of the 

following steps: 

1. Developing a series of model projects of differing sizes, durations, and project types on 

the basis of analysis of Notice of Intent (NOI) data. 

2. Determining RF1-level estimates for RUSLE and hydrologic parameters using national 

geographic information system (GIS) data layers, supplemented with best professional 

judgment (BPJ) estimates for parameters for which data were not available. 

3. Estimating baseline and option-specific estimates of sediment loads for each RF1. For 

Option 1, estimates were developed according to changes in the RUSLE P- and C factors 

from baseline. For Options 2, 3, and 4, estimates were developed first using the change in 

RUSLE P- and C-factors for all sites to account for the effects of the enhanced erosion 

and sediment control requirements, and second a concentration approach for acres subject 

to turbidity limits. 

4. Summing RF1 loads to the national level. 

The following sections describe these steps in detail. 

10.2. MODEL PROJECT ANALYSIS 

EPA evaluated NOI data from four states and developed a distribution of projects by site size, 

project duration, and project type (see Appendix C). EPA categorized NOI data into three main 

project types: residential, nonresidential, and transportation. On the basis of the NOI data 

evaluation, EPA developed the distribution shown in Table 10-1. For the loads analysis, it was 

not necessary to maintain the breakout by project durations because longer duration projects are 
Section 10: Estimating Pollutant Load Reductions 

10-2 

calculated using the same methodology as shorter duration projects. Therefore, one project 

duration was calculated for each of the 12 model project sizes within each of the three project 

type categories (residential, nonresidential, and transportation), yielding a total of 36 individual 

model projects (12 site size categories times 3 project types). As with the cost analysis, it was 

assumed that the duration of land disturbance would be less than the project duration according 

to the NOIs. Therefore, the duration of each model project was determined using BPJ, and the 

duration for each of the 36 site size categories were determined by collapsing the model project 

matrix. Table 10-2 shows the collapsed distribution and the duration of both the NOIs as well as 

the calculated project duration for each of the 36 model project size categories used for the 

loading estimates. 

10.3. MODEL PARAMETER AND LOADS ESTIMATION 

Sediment loads were estimated using the RUSLE. RUSLE is an empirical relationship that can 

be used to estimate soil erosion rates from various land uses. RUSLE calculates soil loss, A (in 

tons/acre/year), on the basis of six parameters using the following relationship: 

A = R × K × L × S × C × P

The parameters in RUSLE are 

A = Average annual soil loss (tons/acre/year) 

R = rainfall-runoff erosivity factor 

K = soil erodibility factor 

L = slope length factor 

S = slope steepness factor 

C = cover-management factor 

P = support practice factor 

EPA used a combination of data sources as well as BPJ in selecting RUSLE parameters. EPA’s 

load estimation methodology calculates soil loss at the RF1 scale. Therefore, EPA used national 

databases, where available, to determine some parameters that are geographically based. Other 

parameters are site-specific. Therefore, EPA estimated the parameters by applying BPJ to 

various data sources. EPA assumed a delivery ration of 1 (i.e., all estimates by RUSLE were 

assumed to be discharged from the construction site). That assumption does not account for 

losses that could occur if, for example, sediment were to be deposited between the construction 

site and the storm drain or receiving water. This is a reasonable assumption, however, because 

discharges from construction sites (particularly larger sites that comprise the bulk of the acres 

affected) are typically discharged via a pipe or channel directly to a storm drain network or to 

receiving water. In addition, the SPARROW model accounts for some potential losses as 

sediment is delivered to the RF1 stream network. 
10-3 

Table 10-1. Model project matrix 

RESIDENTIAL 

Duration (days) Project size 

(acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731– 912 91

1,0

1.9 124 147 632 571 1,111 926 283 293 222 450 3.8 68 100 351 341 703 657 312 213 249 397 126 44 28 242 168 444 301 81 110 169 220 8.5 22 26 187 172 318 309 52 70 109 180 

12 23 14 195 218 506 388 139 78 72 430 17 18 2 84 174 209 219 95 107 74 360 23 1 28 107 133 239 303 73 90 103 325 1

3 1 -- 48 59 182 143 23 42 18 214 

46 11 -- 33 84 126 114 11 24 70 155 169 -- -- 1 38 38 54 17 19 18 60 85 -- -- -- 2 17 36 -- 7 7 43 2

145 -- -- 8 11 45 50 15 12 37 50 

Total Residential 312 345 1,888 1,971 3,938 3,500 1,101 1,065 1,148 2,884 8

NONRESIDENTIAL 

Duration (days) Project size 

(acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731– 912 91

1,0

1.9 558 1,359 4,910 5,334 4,806 3,276 940 685 442 592 13.8 219 547 1,990 2,973 2,643 1,715 910 461 199 465 146 150 206 996 1,368 1,516 1,059 513 285 240 188 8.5 55 97 578 736 616 617 165 152 144 274 4

12 77 73 493 660 950 741 347 178 162 291 417 13 82 246 261 505 419 203 60 114 131 223 38 59 166 264 542 250 215 208 135 142 

3 3 27 78 164 176 126 48 72 29 101 

46 -- 17 49 65 129 150 57 152 12 131 69 2 2 29 50 33 30 30 87 16 71 85 -- -- 10 1 86 22 11 21 -- 51 -

145 -- 8 25 46 124 25 10 11 5 58 2

Total Nonresidential 1,115 2,477 9,570 11,922 12,126 8,430 3,449 2,372 1,498 2,495 64
10-4 

TRANSPORTATION 

Duration (days) Project size 

(acres) 0–46 47–91 92–182 183–274 275–365 366–456 457–547 549–639 640–730 731–912 91

1,0

1.9 82 210 629 418 308 323 136 55 132 117 3.8 25 87 277 255 246 146 81 60 34 58 6 16 23 184 138 170 53 45 26 -- 78 8.5 7 15 70 73 78 78 33 89 17 7 

12 8 21 70 109 39 95 52 43 17 36 17 -- 3 63 49 13 15 21 2 8 64 23 5 2 31 36 6 76 40 27 14 95 

3 -- -- 1 26 17 6 16 4 9 5 

46 -- 1 2 19 9 25 21 15 9 24 69 -- -- -- -- 3 9 10 4 - 5 85 -- -- 7 -- -- 3 -- -- 2 4 

145 -- -- -- 1 3 4 1 9 11 24 

Total Transportation 143 362 1,334 1,124 892 833 456 334 253 517 2NATIONAL TOTAL 1,570 3,184 12,792 15,017 16,956 12,763 5,006 3,771 2,899 5,896 1,7
Section 10: Estimating Pollutant Load Reductions 

10-5

Table 10-2. Project matrix for loads analysis 

 Residential Nonresidential Transportation 

Project size 

(acres) 

NOI 

duration 

(months) 

Duration for 

loads 

estimation 

(months) 

NOI 

duration 

(months) 

Duration for 

loads 

estimation 

(months) 

NOI 

duration 

(months) 

Duration for 

loads 

estimation 

(months) 

1.9 13 10 9 8 9 8 

3.8 15 12 10 8 10 8 

6 15 12 11 9 11 9 

8.5 16 13 12 10 13 10 

12 17 14 12 10 14 11 

17 18 15 12 10 16 13 

23 20 16 13 11 18 14 

34 21 17 14 11 20 16 

46 22 17 17 14 22 18 

69 23 19 17 13 23 18 

85.1 28 22 17 13 29 24 

145 23 18 15 12 29 23 

Average 16 13 11 9 12 10 

Table 10-3 summarizes sources used by EPA for each RUSLE factor. As discussed in Section 

3.5.4, EPA used CONUS-SOIL soil database (Miller and White 1998) to evaluate soil and 

physical parameter values at the RF1 level. The loads analysis evaluated only RF1 watersheds 

that contained new developed land between 1992 and 2001 as indicated by the National Land 

Cover Dataset (NLCD). EPA developed a procedure (called masking) that would use only the 

parameter values for the geographic areas that were developed between 1992 and 2001. 

Table 10-3. Data sources used to obtain RUSLE factors 

RUSLE 

term Definition 

Source of 

information Method for determining RF1-level values 

C Covermanagement 

Factor 

Literature review 

and BPJ 

EPA calculated an average annual value that is based on 

assumptions about how cover, and associated C factors, 

are likely to be employed over the duration of a typical 

project. These values were determined by applying BPJ to 

various sources in the literature and did not vary 

geographically or across regulatory option. 

P Support 

Practice Factor 

Literature review 

and BPJ 

EPA assigned values on the basis of a literature review and 

BPJ. Values varied by assumptions about how practices 

were likely to change under the regulatory options. 

K Soil Erodibility 

Factor 

CONUS-SOIL 

Database 

EPA determined the spatially averaged value from soils 

data for each RF1 watershed, weighted toward areas where 

development occurred between 1992 and 2001 using NLCD 

data. 

R Rainfall-Runoff 

Erosivity Factor 

GIS layer prepared 

for the EPA LEW 

Calculator 

EPA determined the spatially averaged value from soils 

data for each RF1 watershed, weighted toward areas where 

development occurred between 1992 and 2001 using NLCD 

data. 

LS Slope Length 

Factor 

BPJ EPA assumed an average slope of 4% and a slope length 

of 80 feet across all model projects. 
Section 10: Estimating Pollutant Load Reductions 

10-6

The array of surface conditions at constructions sites varies as construction advances from 

clearing/grubbing, to earth moving/contouring, followed by the installation of structures and 

final landscaping. Given the large number of construction sites commencing annually and the 

large variation in construction sequences and construction activities occurring across the country, 

determining site-specific RUSLE parameters for C, P, L, and S is extremely challenging. 

Therefore, EPA applied BPJ to estimate values for these parameters. EPA selected values that 

are expected to be typical across the entire country and, on average, could be considered typical 

of conditions over the duration of the project. To evaluate the sensitivity of the loading estimates 

under the primary analysis (which were used to estimate national water quality changes in the 

SPARROW model and subsequent environmental benefits), EPA chose to vary the assumptions 

for one parameter, P. RF1 and national loads were estimated using three assumptions for P, with 

the middle (called average) value used for water quality modeling. The results for the other two 

scenarios (called low and high) are included in the discussion below; however, SPARROW 

model runs were not conducted for those scenarios. 

10.3.1. LS FACTOR 

As suggested by its name, the RUSLE slope length parameter is composed of a slope component 

and a length component. In combination, the two components express the influence of the path 

taken by runoff as it travels across a construction site to the point of discharge. The steeper and 

longer the pathway, the greater the amount of erosion the RUSLE predicts . 

While the LS factor is one of the most important RUSLE parameters, it is also one of the more 

difficult values to determine at the national scale. The STATSGO data used by EPA reports land 

slope only in terms of a low value and a high value. Therefore, determining a representative 

slope for specific geographic areas is not possible using that data set. While more detailed data 

sets are available, the resources required to analyze preexisting slopes at the national scale made 

the use of more detailed data sets infeasible for this analysis. 

Table 10-4 indicates per-state, spatially averaged, lowest-reported, and highest-reported slope 

data extracted from the STATSGO data. The values generated through this process are relatively 

high (e.g., greater than 5 percent). Therefore, EPA elected not to use these data for modeling 

purposes, but instead assumed a 4 percent land slope across all model sites, acknowledging that 

slopes present on actual construction sites can be much lower (such as if a corn field is converted 

to a big-box store) or much higher (such as on a highway road cut). The value of 4 percent falls 

toward the bottom of the ranges reported in Table 10-4. 

Table 10-4. Slope ranges from STATSGO (percent) 

State 

Average of lowest 

reported slopes 

Average of highest 

reported slopes State 

Average of lowest 

reported slopes 

Average of highest 

reported slopes 

AL 4.71 11.96 NC 5.37 11.53 

AR 4.71 11.91 ND 2.49 6.98 

AZ 1.66 8.24 NE 2.95 7.29 

CA 6.83 17.37 NH 6.25 14.93 

CO 1.50 11.33 NJ 2.16 6.42 

CT 5.21 11.89 NM 1.60 10.99 

DC 6.69 14.05 NV 2.14 8.99 
Section 10: Estimating Pollutant Load Reductions 

10-7

State 

Average of lowest 

reported slopes 

Average of highest 

reported slopes State 

Average of lowest 

reported slopes 

Average of highest 

reported slopes 

DE 0.93 3.66 NY 4.37 11.61 

FL 0.32 3.24 OH 3.99 9.90 

GA 4.49 10.40 OK 2.25 7.08 

IA 3.60 6.95 OR 9.82 24.08 

ID 2.88 10.83 PA 6.86 17.27 

IL 2.79 6.80 RI 3.69 10.64 

IN 2.12 5.96 SC 2.72 6.40 

KS 1.71 5.31 SD 1.99 6.83 

KY 11.04 24.63 TN 8.00 17.73 

LA 1.36 4.78 TX 0.89 5.05 

MA 4.82 12.55 UT 3.19 14.80 

MD 4.89 11.66 VA 7.51 17.13 

ME 4.04 11.48 VT 9.19 21.79 

MI 2.11 7.80 WA 8.13 21.46 

MN 2.24 6.60 WI 3.25 9.01 

MO 5.25 12.71 WV 15.79 31.27 

MS 5.15 12.52 WY 1.32 11.00 

MT 3.07 13.50 National 3.65 10.18 

EPA assumed a relatively short distance of 80 feet across all its model sites for the slope length. 

That distance is intended to represent the typical density of channels for a 4 percent slope used to 

facilitate drainage on the site before the permanent drainage network is installed, or the length 

before some sort of slope break would be provided. In general, the permanent drainage 

infrastructure is installed early in the construction process, and it is available to drain the 

construction footprint around individual structures at some point during construction. 

For its analysis of construction site erosion, EPA computed LS on the basis of a high rill-tointerrill erosion ratio. That assumption is generally considered the most appropriate assumption 

for construction site conditions (USDA 1997). 

10.3.2. P FACTOR 

To represent the influence of various ESC technologies, EPA used the RUSLE practice factor 

(P). Examination of the literature indicates that P factors for sediment controls at construction 

sites can vary from between 0.1 to 0.9 (see Table 10-5). This means that sediment controls can 

vary from between 10 percent to 90 percent effective in removing sediment. In reality, the 

performance of a given sediment control is dependent on a number of factors, including design, 

size, frequency, and duration of rainfall and runoff events; particle size distribution of sediment 

particles; the presence of particle surface charge; influent sediment concentration; the degree of 

sediment accumulation; and the extent to which maintenance has been performed. To estimate 

loads for the national estimates, EPA chose to assign a P factor of 0.4 to characterize baseline 

sediment control performance. This means that 60 percent of the sediment estimated to be 

produced at the site is removed through sediment controls such as sediment traps, sediment 

basins, silt fences, and check dams. The value is intended to be typical of the range of practices 

used at sites nationwide, recognizing that different sites employ a mix of sediment control 

practices. To evaluate the influence of the ESC requirements under Options 1 through 4, EPA 
Section 10: Estimating Pollutant Load Reductions 

10-8

reduced the P factor to 0.3. That accounts for using surface outlets on all basins, which is the 

major change to sediment controls from existing requirements contained in the nonnumeric 

effluent limitations of the regulatory options. EPA also assumed that filter berms will be used in 

place of silt fence, which has an associated improvement in sediment removal. As a sensitivity 

analysis, EPA varied the baseline P factor assumption. EPA assumed a baseline P factor of 0.3 as 

the low-value and 0.5 as the high-value in the sensitivity analysis. As with the primary case, EPA 

assumed that the regulatory options would reduce the P factor by 0.1 units. Table 10-6 

summarizes the P factor assumptions. 

Table 10-5. P factors for construction site practices 

Practice P factor 

Sediment Containment Systems 0.1–0.9 

Bale or Sandbag Barriers 0.9 

Rock Barriers at Sump Locations 0.8 

Silt Fence Barrier 0.6 

Grass Buffer Strips 

0% to 10% Slope 0.6 

11% to 24% Slope 0.8 

Table 10-6. P factors used for load estimation 

Scenario Low value Average value High value 

Baseline 0.3 0.4 0.5 

Regulatory Options 0.2 0.3 0.4 

10.3.3. C FACTOR 

EPA used the RUSLE cover factor (C) to represent various cover conditions present on the 

model sites under baseline conditions and under the regulatory options. Table 10-7 shows C 

factors for various construction site controls. Permittees are likely to implement various types of 

cover practices on the site. During clearing and grading, substantial portions of the site can be 

disturbed and bare soil can be prevalent. As portions of the site reach final grade, permittees 

usually install some sort of temporary cover, such as straw mulch or temporary seeding. As 

construction progresses, temporarily stabilized areas could be exposed again during excavation 

activities, and eventually the site is stabilized at the end of construction. However, such practices 

vary widely nationwide and even within states. 

To determine an appropriate C factor for use in the national modeling, EPA developed an 

average annual C factor for sites nationwide. The average C factor was determined by making 

assumptions about the types of cover present on construction sites during different periods of 

construction. For a 1-year duration project under baseline conditions, EPA assumed that the site 

would have bare soil that is loose for a period of 1 month during initial clearing and grading, 

followed by a 1-month period where soil is bare and compacted. Straw mulch would then be 

applied at a rate of 2 tons per acre for a period of 9 months during the vertical construction 
Section 10: Estimating Pollutant Load Reductions 

10-9

phase. The remaining 1 month would be seeded and mulched with grasses established. That 

gives an average C factor of 0.26 for the year. 

Under Options 1, 2, 3, and 4, EPA assumed that the period of compacted, bare soil would be 

reduced from 1 month to 2 weeks and that the period when the site is covered in straw mulch 

would increase from 9 months to 9.5 months. That change is intended to reflect the effect of the 

enhanced soil cover requirement of the options, meaning that permittees would install temporary 

cover on average 2 weeks earlier than under baseline conditions. That gives an average C factor 

for the year of 0.23. 

Table 10-8 shows the assumptions used under baseline conditions and under the regulatory 

options and the value of the average annual C factors. 

Table 10-7. C factors for construction site controls 

Treatment C factor value 

Bare soil conditions 

Freshly disked to 6–8 inches 1 

After one rain 0.89 

Loose to 12 inches, smooth 0.9 

Loose to 12 inches, rough 0.8 

Compacted root rake 1.2 

Compacted bulldozer scraped across slope 1.2 

Same except root raked across 0.9 

Rough irregular tracked all directions 0.9 

Seed and fertilized, fresh unprepared seedbed 0.64 

Same except after 6 months 0.54 

Seed, fertilized after 12 months 0.38 

Undisturbed except scraped 0.66-1.30 

Scarified only 0.76-1.31 

Asphalt/Concrete Pavement 0.01 

Asphalt emulsion 

1,210 gal/acre 0.01–0.019 

605 gal/acre 0.14–0.57 

Gravel (diameter = 25–50 mm) at 90 tons/acre 0.05 

Dust binder 

605 gal/acre 1.05 

1,210 gal/acre 0.29–0.78 

Other chemicals 

Aquatain 0.68 

Aerospray 70, 10% cover 0.94 

PVA 0.71–0.90 

Tera-Tack 0.66 

Straw Mulch 

1 ton/acre (slopes less than 10%) 0.2 

1.5 ton/acre (slopes less than 10%) 0.12 

Seeding 

Temporary, 0–60 days 0.4 

Temporary, after 60 days 0.05 

Permanent, 2 to 12 months 0.05 
Section 10: Estimating Pollutant Load Reductions 

10-10

Treatment C factor value 

Grass Seeding and Mulch 

20% coverage by treatment 0.20 

40% coverage by treatment 0.10 

60% coverage by treatment 0.042 

Brush 0.35 

Wischmeier and Smith 1978; URS 2008 

Table 10-8. C factors used for loads estimation 

Cover C factor 

Duration 

(months) 

C factor × fraction of 

year 

Baseline 

Bare soil, loose to 12 inches, rough 0.8 1 0.067 

Bare soil, compacted 1.2 1 0.1 

Straw mulch, 1.5 tons/acre, 1–5% slope 0.12 9 0.09 

Grass with mulch, 60% cover 0.042 1 0.0035 

Total for Year 0.26 

Options 1, 2, 3, and 4 

Bare soil, loose to 12 inches, rough 0.8 0.5 0.033 

Bare soil, compacted 1.2 1 0.1 

Straw mulch, 1.5 tons/acre, 1–5% slope 0.12 9.5 0.095 

Grass with mulch, 60% cover 0.042 1 0.0035 

Total for Year 0.23 

10.3.4. RUNOFF VOLUME ESTIMATES 

EPA estimated runoff volumes within each RF1 watershed to calculate removals for options that 

incorporated a numeric discharge standard. EPA computed runoff coefficients on the basis of the 

long-term meteorological record for 11 indicator cities. The values were then assigned to RF1 

watersheds for those states. For other states that do not contain an indicator city, values from the 

nearest state were used as an approximation. Table 10-9 lists the states/commonwealths 

represented by each of the indicator cities. Note that the loading analysis does not include 

consideration of construction activities in Hawaii and Alaska, and does not include any of the 

U.S. territories.

Table 10-9. Allocation of states/commonwealths/territories to representative indicator city 

State Indicator city State Indicator city 

Alabama Atlanta, GA New Jersey Albany, NY 

Arizona Las Vegas, NV New Mexico Dallas, TX 

Arkansas Dallas, TX New York Albany, NY 

California Las Vegas, NV North Carolina Atlanta, GA 

Colorado Denver, CO North Dakota Denver, CO 

Connecticut Manchester, NH Ohio Chicago, IL 

Delaware Washington, DC Oklahoma Dallas, TX 

Florida Atlanta, GA Oregon Seattle, WA 

Georgia Atlanta, GA Pennsylvania Washington, DC 

Idaho Boise, Id Rhode Island Manchester, NH 

Illinois Chicago, IL South Carolina Atlanta, GA 
Section 10: Estimating Pollutant Load Reductions 

10-11

State Indicator city State Indicator city 

Indiana Chicago, IL South Dakota Denver, CO 

Iowa Kansas City, KS Tennessee Atlanta, GA 

Kansas Kansas City, KS Texas Dallas, TX 

Kentucky Atlanta, GA Utah Denver, CO 

Louisiana Dallas, TX Vermont Manchester, NH 

Maine Manchester, NH Virginia Washington, DC 

Maryland Washington, DC Washington Seattle, WA 

Massachusetts Manchester, NH West Virginia Washington, DC 

Michigan Chicago, IL Wisconsin Chicago, IL 

Minnesota Chicago, IL Wyoming Denver, CO 

Mississippi Atlanta, GA Alaska Not analyzed 

Missouri Kansas City, KS Hawaii Not analyzed 

Montana Denver, CO Puerto Rico Not analyzed 

Nebraska Kansas City, KS Virgin Islands Not analyzed 

Nevada Las Vegas, NV Pacific Islands Not analyzed 

New Hampshire Manchester, NH District of Columbia Washington, DC 

EPA used the CONUS-SOIL data on hydrologic soil groups (HSG) to estimate runoff volumes 

from the model construction sites. HSG is presented in terms of the percent of land area that is 

made up of soils characterized as type A, B, C, or D. Those four soil hydrologic classifications 

are correlated to the soil Curve Number, used with the SCS Curve Number methods to convert 

inches of rainfall into inches of runoff. 

Eleven indicator cities were used to evaluate runoff coefficients, and those values were assigned 

to surrounding states using the relationships in Table 10-9. The NRCS Curve Number procedure 

(TxDOT 2009) was used to estimate runoff coefficients and associated runoff volumes, 

considering the Curve Number for each of the four HSGs and the distribution of HSGs within 

each geographic area. 

The hourly rainfall record was then evaluated for a single year’s meteorological record to 

determine runoff amounts for each hour’s precipitation, for each HSG. The rainfall year selected 

for each indicator city was judged to be typical or a year that did not contain rainfall events with 

greater than a 2-year return period. 

For simplicity, the total runoff volume from all the individual rainfall events was divided by the 

total annual rainfall amount. The result is a runoff coefficient that can be used to convert annual 

precipitation into annual runoff. Table 10-10 indicates the runoff coefficients for each HSG, for 

each indicator city. 

EPA used values in Table 10-10 to estimate the annual runoff amount for developed acres within 

each RF1 watershed. For example, if an RF1 watershed near Albany New York, has equal 

amounts of A, B, C, and D soils, its effective runoff coefficient is estimated as the sum of 25 

percent of each of the Albany HSG values. (0.25 × (0.12 + 0.23 + 0.34 + 0.45) or 0.285). 

Multiplying the total annual precipitation associated with each RF1 watershed by the customized 

per-RF1 runoff coefficient, yields the estimated annual runoff amount. Additional information on 

EPA’s processing hydrologic data and developing Table 10-10 values is in Appendix H. 
Section 10: Estimating Pollutant Load Reductions 

10-12

Appendix H also contains information on EPA’s assessment of indicator city meteorological data 

to establish the number of rainfall events expected in a construction period and the duration of 

discharge monitoring for runoff events. 

Table 10-10 Estimated runoff coefficients by HSG for indicator regions 

City EPA Region* A soil B soil C soil D soil 

Manchester, NH 1 0.15 0.26 0.36 0.46 

Albany, NY 2 0.12 0.23 0.34 0.45 

Washington, DC 3 0.15 0.27 0.39 0.49 

Atlanta, GA 4 0.17 0.30 0.41 0.52 

Chicago, IL 5 0.14 0.26 0.37 0.47 

Dallas, TX 6 0.14 0.28 0.41 0.52 

Kansas City, KS 7 0.13 0.25 0.37 0.47 

Denver, CO 8 0.04 0.10 0.18 0.27 

Las Vegas, NV 9 0.03 0.10 0.18 0.26 

Boise, ID 10a 0.01 0.04 0.09 0.16 

Seattle, WA 10b 0.13 0.22 0.32 0.42 

* EPA Region 10 was divided into two portions to help account for differences in rainfall patterns. 

To obtain annual precipitation for each RF1 watershed, EPA performed a spatial analysis using 

the 1-km resolution U.S. Average Monthly or Annual Precipitation (1971–2000) PRISM Group 

raster data coverage (PRISM Group 2006). The annual rainfall for the urbanized acres within 

each RF1 watershed boundary was averaged and used to estimate the per-RF1 annual rainfall 

value. 

10.4. LOAD ESTIMATION 

EPA estimated loads under baseline as well as under the regulatory options evaluated. All 

calculations were done at the RF1 level. Using NLCD data, EPA estimated the amount of new 

development occurring in each RF1 watershed (for a description of this analysis, see the 

proposed rule development document). That analysis indicates that approximately 590,545 acres 

per year were developed nationally over the period of 1992 to 2001. EPA then scaled these 

estimates up to account for growth in the industry since the 1992–2001 period. EPA’s revised 

estimate of national developed acreage is 852,650 acres. EPA then scaled up the RF1-level 

estimates of developed acres using the ratio between these two values. 

Using the RF1-level parameters for K and R, and the C, P, and LS assumptions described above, 

EPA calculated the baseline sediment loading for all developed acres with each RF1 watershed 

on an annual basis. There were 42,288 unique RF1 watersheds in the analysis (approximately 4 

percent of watersheds crossed state boundaries, so those RF1 watersheds were broken into 

smaller sections to conform with the RF1/state combinations and were later recombined). All 

RF1 watersheds that did not have development between 1992 and 2001 were not analyzed. The 

annual values were then used to estimate the loads for each model project category on the basis 

of the number of acres within each category and the duration of construction activity for the 

entire national model project matrix. For model construction sites with a duration of less than 1 

year, the load was calculated using the fraction of the year modeled, with no consideration for 

the actual time of year that construction occurred. Because parameters such as R vary during the 
Section 10: Estimating Pollutant Load Reductions 

10-13

year, the soil loss during any fraction of a year can be calculated if the start and end dates of the 

project are known. However, because of the large number of model projects in the analysis, it is 

simply assumed that the projects are evenly distributed over the course of the year. In addition, 

all loads from projects longer than 1 year were estimated by scaling up the annual values. For 

example, if a construction duration was 13 months, the total load from that model construction 

site would consist of the annual load from RUSLE (12 months), plus 1/12 the annual load to 

account for the 1-month incremental load. 

Options 2, 3, and 4 contain site size thresholds whereby specific requirement for meeting a 

numeric turbidity limit apply according to site size (10 acres for Options 3 and 4 and 30 acres for 

Option 2). As with Option 1, EPA applied the changes in C and P factors to determine the 

influence of the enhanced ESCs. EPA then determined if any additional removals would result 

from the turbidity limits using a concentration approach. That was done by dividing the sediment 

load by the calculated runoff volume from developed acres within each RF1 watershed. For 

Options 2 and 3, it was assumed that the average total suspended solids (TSS) concentration for 

discharges subject to the numeric limit would be 25 milligrams per liter (mg/L). For Option 4, it 

was assumed that the average TSS concentration of discharges would be 250 mg/L. For each 

RF1 watershed, the discharge load was calculated on the basis of the difference between the 

concentration after application of BMPs and either 25 mg/L (Options 2 and 3) or 250 mg/L. If 

the baseline concentration was less than either 25 mg/L or 250 mg/L, no removals were 

associated with the numeric limit for that RF1 watershed. From the distribution of site sizes and 

durations, loads were then calculated on the basis of the quantity of acres within each site size 

category and the duration of construction activity for each model project category within the 

national model project matrix, using the same procedure described above for Option 1. 

Load reductions were summed for each RF1 watershed and then summed to the state and 

national level. RF1-level estimates were used for subsequent water quality modeling using the 

SPARROW model. 

10.5. RESULTS 

Table 10-11 provides estimates of sediment discharges under baseline conditions and the 

regulatory options for the primary analysis case. Tables 10-12 and 10-13 provide estimates of 

sediment discharges for the low and high scenarios, respectively. Table 10-14 provides the 

estimated sediment removals by regulatory option for the primary analysis case. Tables 10-15 

and 10-16 provide estimated removals for the low and high scenarios, respectively. All values 

presented in these tables are after full implementation. 
Section 10: Estimating Pollutant Load Reductions 

10-14

Table 10-11. Discharged loads—primary analysis case 

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

AL 120,513 79,956 36,218 15,419 25,945 

AK -- -- -- -- -- 

AR 78,969 52,393 23,660 9,996 15,925 

AZ 10,813 7,174 3,225 1,348 1,970 

CA 24,516 16,266 7,414 3,204 5,944 

CO 12,222 8,109 3,684 1,580 2,785 

CT 2,878 1,910 886 399 925 

DC 1,403 931 422 180 311 

DE 3,459 2,295 1,049 457 884 

FL 150,699 99,983 46,575 21,177 51,377 

GA 180,561 119,795 54,635 23,648 44,336 

HI -- -- -- -- -- 

IA 39,324 26,090 11,840 5,063 8,783 

ID 1,812 1,202 547 236 427 

IL 89,672 59,494 27,040 11,606 20,640 

IN 53,875 35,744 16,293 7,044 13,109 

KS 101,100 67,076 30,325 12,849 20,906 

KY 51,628 34,253 15,639 6,786 12,925 

LA 196,969 130,682 58,732 24,518 35,571 

MA 6,258 4,152 1,965 925 2,588 

MD 29,790 19,765 8,997 3,877 7,068 

ME 7,376 4,894 2,358 1,153 3,673 

MI 31,647 20,997 9,833 4,524 11,515 

MN 17,639 11,703 5,402 2,405 5,276 

MO 86,647 57,487 25,941 10,940 17,191 

MS 145,295 96,397 43,421 18,228 27,665 

MT 3,657 2,426 1,111 486 965 

NC 92,858 61,608 28,141 12,227 23,428 

ND 8,576 5,690 2,566 1,080 1,674 

NE 14,553 9,655 4,376 1,865 3,166 

NH 3,246 2,154 1,016 476 1,303 

NJ 14,378 9,540 4,383 1,930 3,971 

NM 2,665 1,768 829 382 957 

NV 2,225 1,476 676 296 591 

NY 17,302 11,479 5,340 2,421 5,789 

OH 62,997 41,796 19,176 8,419 17,149 

OK 101,097 67,074 30,270 12,768 20,103 

OR 9,119 6,050 2,903 1,406 4,251 

PA 53,686 35,619 16,418 7,288 15,750 

RI 965 640 298 135 327 

SC 79,666 52,855 24,163 10,519 20,410 

SD 15,388 10,209 4,589 1,917 2,796 

TN 88,740 58,876 26,754 11,478 20,350 

TX 460,238 305,350 137,702 57,978 90,021 

UT 2,631 1,746 821 381 996 

VA 63,323 42,012 19,199 8,351 16,128 

VT 1,209 802 376 173 446 

WA 15,752 10,451 4,996 2,402 7,090 

WI 17,363 11,520 5,289 2,326 4,777 
Section 10: Estimating Pollutant Load Reductions 

10-15

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

WY 1,146 760 349 153 310 

WV 11,729 7,782 3,593 1,600 3,521 

NATIONAL 2,589,577 1,718,085 781,433 336,018 604,009 

Table 10-12. Discharged loads—low sensitivity analysis case 

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

AL 90,385 53,304 24,409 10,669 21,195 

AK -- -- -- -- -- 

AR 59,227 34,929 15,922 6,884 12,813 

AZ 8,109 4,783 2,166 922 1,542 

CA 18,387 10,844 5,011 2,238 4,954 

CO 9,166 5,406 2,487 1,098 2,276 

CT 2,159 1,273 604 285 812 

DC 1,052 621 285 125 256 

DE 2,594 1,530 710 320 746 

FL 113,024 66,655 31,808 15,237 44,876 

GA 135,420 79,863 36,942 16,532 37,219 

HI -- -- -- -- -- 

IA 29,493 17,393 7,987 3,513 7,233 

ID 1,359 801 370 164 355 

IL 67,254 39,662 18,253 8,072 17,105 

IN 40,406 23,829 11,015 4,921 10,986 

KS 75,825 44,717 20,419 8,864 16,921 

KY 38,721 22,836 10,580 4,752 10,890 

LA 147,727 87,121 39,432 16,755 27,806 

MA 4,694 2,768 1,352 678 2,333 

MD 22,343 13,176 6,078 2,703 5,892 

ME 5,532 3,263 1,636 862 3,153 

MI 23,735 13,998 6,732 3,277 10,127 

MN 13,229 7,802 3,673 1,710 4,562 

MO 64,986 38,325 17,451 7,525 13,776 

MS 108,971 64,265 29,184 12,501 21,939 

MT 2,743 1,618 753 342 813 

NC 69,644 41,072 19,043 8,567 19,757 

ND 6,432 3,793 1,725 742 1,336 

NE 10,915 6,437 2,950 1,292 2,593 

NH 2,434 1,436 698 348 1,174 

NJ 10,784 6,360 2,974 1,363 3,381 

NM 1,999 1,179 568 277 812 

NV 1,669 984 458 208 502 

NY 12,976 7,653 3,645 1,739 5,074 

OH 47,248 27,864 13,003 5,936 14,666 

OK 75,823 44,716 20,364 8,784 16,118 

OR 6,839 4,033 2,009 1,046 3,582 

PA 40,265 23,746 11,158 5,172 13,631 

RI 723 427 203 97 288 

SC 59,750 35,237 16,357 7,379 17,271 

SD 11,541 6,806 3,082 1,311 2,189 
Section 10: Estimating Pollutant Load Reductions 

10-16

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

TN 66,555 39,251 18,058 7,981 16,852 

TX 345,178 203,567 92,605 39,839 71,855 

UT 1,973 1,164 563 277 855 

VA 47,492 28,008 12,995 5,855 13,632 

VT 907 535 258 126 397 

WA 11,814 6,967 3,452 1,781 5,914 

WI 13,023 7,680 3,587 1,641 4,086 

WY 859 507 237 108 261 

WV 8,797 5,188 2,443 1,138 3,056 

NATIONAL 1,942,181 1,145,390 527,695 233,956 499,863 

Table 10-13. Discharged loads—high sensitivity analysis case 

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

AL 150,642 106,608 48,026 20,168 30,695 

AK -- -- -- -- -- 

AR 98,711 69,857 31,397 13,108 19,037 

AZ 13,516 9,565 4,285 1,774 2,397 

CA 30,645 21,688 9,816 4,170 6,916 

CO 15,278 10,812 4,882 2,062 3,275 

CT 3,598 2,546 1,168 512 1,039 

DC 1,754 1,241 560 236 367 

DE 4,324 3,060 1,388 593 1,021 

FL 188,374 133,311 61,341 27,116 57,339 

GA 225,701 159,727 72,327 30,765 51,453 

HI -- -- -- -- -- 

IA 49,155 34,787 15,693 6,613 10,333 

ID 2,265 1,603 725 307 499 

IL 112,090 79,325 35,826 15,141 24,175 

IN 67,343 47,658 21,572 9,167 15,232 

KS 126,376 89,435 40,232 16,834 24,890 

KY 64,536 45,671 20,697 8,821 14,959 

LA 246,212 174,242 78,032 32,281 43,335 

MA 7,823 5,536 2,578 1,171 2,835 

MD 37,238 26,353 11,916 5,051 8,244 

ME 9,220 6,525 3,081 1,443 3,967 

MI 39,559 27,996 12,934 5,771 12,786 

MN 22,048 15,603 7,130 3,100 5,973 

MO 108,309 76,649 34,431 14,355 20,606 

MS 181,618 128,530 57,657 23,954 33,391 

MT 4,571 3,235 1,470 630 1,111 

NC 116,073 82,144 37,240 15,886 27,093 

ND 10,720 7,586 3,406 1,418 2,012 

NE 18,191 12,874 5,802 2,439 3,740 

NH 4,057 2,871 1,335 604 1,431 

NJ 17,973 12,719 5,791 2,497 4,552 

NM 3,332 2,358 1,090 487 1,076 

NV 2,781 1,968 894 384 679 

NY 21,627 15,305 7,035 3,103 6,475 
Section 10: Estimating Pollutant Load Reductions 

10-17

Tons per year 

State Baseline Option 1 Option 2 Option 3 Option 4 

OH 78,746 55,728 25,348 10,902 19,632 

OK 126,372 89,432 40,176 16,753 24,087 

OR 11,398 8,067 3,796 1,765 4,683 

PA 67,108 47,492 21,679 9,404 17,866 

RI 1,206 853 392 173 365 

SC 99,583 70,474 31,969 13,658 23,550 

SD 19,235 13,612 6,097 2,524 3,402 

TN 110,926 78,501 35,449 14,976 23,847 

TX 575,297 407,134 182,798 76,117 108,163 

UT 3,289 2,328 1,079 485 1,108 

VA 79,153 56,016 25,404 10,847 18,624 

VT 1,512 1,070 495 221 494 

WA 19,690 13,934 6,539 3,023 7,817 

WI 21,704 15,360 6,990 3,010 5,462 

WY 1,432 1,014 461 199 358 

WV 14,662 10,376 4,742 2,063 3,985 

NATIONAL 3,236,971 2,290,780 1,035,172 438,079 706,378 

Table 10-14. Sediment removals—primary analysis case 

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

AL 40,557 84,295 105,094 94,568 

AK -- -- -- -- 

AR 26,576 55,309 68,973 63,044 

AZ 3,639 7,587 9,465 8,842 

CA 8,251 17,103 21,312 18,572 

CO 4,113 8,538 10,642 9,437 

CT 969 1,993 2,479 1,953 

DC 472 981 1,222 1,092 

DE 1,164 2,410 3,002 2,575 

FL 50,716 104,125 129,523 99,323 

GA 60,766 125,926 156,912 136,224 

HI -- -- -- -- 

IA 13,234 27,485 34,261 30,541 

ID 610 1,265 1,576 1,385 

IL 30,178 62,632 78,065 69,031 

IN 18,131 37,581 46,831 40,766 

KS 34,024 70,775 88,251 80,195 

KY 17,375 35,990 44,842 38,704 

LA 66,288 138,237 172,452 161,398 

MA 2,106 4,294 5,334 3,671 

MD 10,026 20,793 25,913 22,722 

ME 2,482 5,018 6,224 3,703 

MI 10,651 21,814 27,123 20,132 

MN 5,936 12,237 15,233 12,363 

MO 29,160 60,706 75,708 69,456 

MS 48,897 101,874 127,067 117,630 

MT 1,231 2,546 3,171 2,692 

NC 31,250 64,717 80,632 69,431 
Section 10: Estimating Pollutant Load Reductions 

10-18

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

ND 2,886 6,010 7,496 6,901 

NE 4,898 10,177 12,688 11,387 

NH 1,092 2,230 2,770 1,943 

NJ 4,839 9,996 12,448 10,408 

NM 897 1,837 2,283 1,709 

NV 749 1,549 1,929 1,634 

NY 5,823 11,962 14,881 11,513 

OH 21,201 43,821 54,578 45,848 

OK 34,023 70,827 88,329 80,995 

OR 3,069 6,216 7,713 4,868 

PA 18,067 37,268 46,398 37,936 

RI 325 667 829 638 

SC 26,811 55,503 69,147 59,256 

SD 5,179 10,798 13,471 12,592 

TN 29,865 61,987 77,262 68,391 

TX 154,888 322,536 402,260 370,217 

UT 886 1,811 2,251 1,635 

VA 21,311 44,123 54,971 47,195 

VT 407 833 1,036 763 

WA 5,301 10,756 13,350 8,662 

WI 5,844 12,075 15,038 12,586 

WY 386 797 992 835 

WV 3,947 8,137 10,129 8,209 

NATIONAL 871,492 1,808,143 2,253,559 1,985,567 

Table 10-15. Sediment removals—low sensitivity analysis case 

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

AL 37,081 65,975 79,716 69,190 

AK -- -- -- -- 

AR 24,298 43,305 52,343 46,414 

AZ 3,327 5,944 7,188 6,568 

CA 7,543 13,376 16,149 13,433 

CO 3,761 6,680 8,068 6,890 

CT 886 1,555 1,873 1,347 

DC 432 767 927 796 

DE 1,064 1,884 2,274 1,848 

FL 46,369 81,216 97,787 68,149 

GA 55,557 98,478 118,889 98,202 

HI -- -- -- -- 

IA 12,100 21,507 25,980 22,260 

ID 557 989 1,194 1,004 

IL 27,591 49,001 59,182 50,148 

IN 16,577 29,392 35,485 29,420 

KS 31,108 55,406 66,961 58,904 

KY 15,886 28,141 33,970 27,832 

LA 60,606 108,295 130,972 119,921 

MA 1,926 3,342 4,016 2,361 

MD 9,166 16,264 19,640 16,450 

ME 2,269 3,896 4,670 2,379 
Section 10: Estimating Pollutant Load Reductions 

10-19

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

MI 9,738 17,004 20,459 13,609 

MN 5,427 9,556 11,519 8,667 

MO 26,661 47,535 57,461 51,209 

MS 44,706 79,787 96,470 87,032 

MT 1,125 1,990 2,401 1,930 

NC 28,572 50,601 61,077 49,887 

ND 2,639 4,706 5,690 5,095 

NE 4,478 7,965 9,623 8,322 

NH 999 1,736 2,087 1,261 

NJ 4,424 7,810 9,420 7,402 

NM 820 1,431 1,722 1,187 

NV 685 1,210 1,461 1,167 

NY 5,324 9,331 11,237 7,902 

OH 19,384 34,245 41,312 32,581 

OK 31,107 55,459 67,039 59,705 

OR 2,806 4,830 5,792 3,257 

PA 16,519 29,107 35,093 26,634 

RI 297 520 626 435 

SC 24,513 43,393 52,371 42,479 

SD 4,735 8,459 10,230 9,352 

TN 27,305 48,497 58,575 49,703 

TX 141,612 252,573 305,340 273,323 

UT 810 1,410 1,696 1,118 

VA 19,484 34,497 41,637 33,860 

VT 372 650 781 511 

WA 4,847 8,362 10,033 5,900 

WI 5,343 9,435 11,381 8,936 

WY 352 622 751 598 

WV 3,609 6,354 7,659 5,741 

NATIONAL 796,791 1,414,486 1,708,225 1,442,318 

Table 10-16. Sediment removals—high sensitivity analysis case 

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

AL 44,034 102,615 130,473 119,947 

AK -- -- -- -- 

AR 28,854 67,314 85,603 79,674 

AZ 3,951 9,231 11,742 11,119 

CA 8,958 20,830 26,475 23,729 

CO 4,466 10,396 13,216 12,002 

CT 1,052 2,430 3,086 2,559 

DC 513 1,194 1,518 1,387 

DE 1,264 2,936 3,731 3,302 

FL 55,063 127,033 161,258 131,035 

GA 65,974 153,374 194,936 174,247 

HI -- -- -- -- 

IA 14,369 33,463 42,543 38,822 

ID 662 1,540 1,958 1,766 

IL 32,765 76,264 96,949 87,915 

IN 19,685 45,771 58,176 52,111 

KS 36,941 86,144 109,542 101,485 
Section 10: Estimating Pollutant Load Reductions 

10-20

Tons per year 

State Option 1 Option 2 Option 3 Option 4 

KY 18,864 43,838 55,714 49,576 

LA 71,970 168,179 213,931 202,876 

MA 2,287 5,245 6,652 4,988 

MD 10,885 25,321 32,186 28,994 

ME 2,695 6,139 7,777 5,253 

MI 11,563 26,625 33,788 26,773 

MN 6,445 14,918 18,948 16,075 

MO 31,659 73,878 93,954 87,703 

MS 53,088 123,961 157,664 148,227 

MT 1,336 3,102 3,941 3,461 

NC 33,929 78,833 100,187 88,980 

ND 3,133 7,314 9,302 8,707 

NE 5,317 12,389 15,752 14,451 

NH 1,186 2,723 3,454 2,627 

NJ 5,254 12,182 15,476 13,421 

NM 974 2,242 2,845 2,256 

NV 813 1,887 2,398 2,102 

NY 6,322 14,592 18,524 15,152 

OH 23,018 53,398 67,845 59,114 

OK 36,939 86,195 109,619 102,284 

OR 3,332 7,602 9,633 6,716 

PA 19,616 45,429 57,704 49,242 

RI 352 813 1,032 841 

SC 29,109 67,614 85,924 76,032 

SD 5,622 13,138 16,711 15,833 

TN 32,425 75,477 95,950 87,079 

TX 168,164 392,499 499,180 467,135 

UT 961 2,211 2,805 2,182 

VA 23,137 53,749 68,306 60,530 

VT 442 1,017 1,291 1,018 

WA 5,756 13,151 16,667 11,873 

WI 6,344 14,714 18,694 16,242 

WY 419 971 1,233 1,074 

WV 4,286 9,920 12,599 10,677 

NATIONAL 946,192 2,201,800 2,798,892 2,530,594 

Table 10-17 provides the reductions of sediment discharged for the nation under each regulatory 

option, the percent reduction for the primary analysis, and the sensitivity analysis, after full 

implementation. 

Table 10-17. National sediment reductions for regulatory options 

Load reduction 

(tons) 

Low-end estimate Average estimate High-end estimate 

Option 1 796,791 871,492 946,192 

Option 2 1,414,486 1,808,143 2,201,800 

Option 3 1,708,225 2,253,559 2,798,892 

Option 4 1,442,318 1,985,567 2,530,594 
Section 10: Estimating Pollutant Load Reductions 

10-21

Load reduction 

(billion pounds) 

Low-end estimate Average estimate High-end estimate 

Option 1 1.594 1.743 1.892 

Option 2 2.829 3.616 4.404 

Option 3 3.416 4.507 5.598 

Option 4 2.885 3.971 5.061 

Percent load reduction 

Low-end estimate Average estimate High-end estimate 

Option 1 41% 34% 29% 

Option 2 73% 70% 68% 

Option 3 88% 87% 86% 

Option 4 74% 77% 78% 

The RF1-level estimates of baseline discharges and discharges under the regulatory options were 

used as inputs to the SPARROW model to estimate changes in sediment flux in the nation’s RF1 

river network. EPA used, as inputs to the SPARROW model, only the set of RF1s watersheds 

that have 1 or more acres of annual development. Of the 42,288 state/RF1 combinations in the 

model, there were 40,591 individual RF1 watersheds. Of those, 33,083 had 1 or more acres of 

development. The total loads modeled in SPARROW are as shown in Table 10-18. The total 

number of acres represented in the SPARROW loads is 848,986, which represents 99.6 percent 

of the total annual acres estimated to be developed (852,650). 

Table 10-18. Total discharge loads and loads modeled in SPARROW 

All RF1s RF1s modeled in SPARROW 

Baseline 2,589,577 2,582,272 

Option 1 1,718,085 1,713,238 

Option 2 781,433 779,217 

Option 3 336,018 335,053 

Option 4 604,009 602,164 

Results of the SPARROW modeling are in The Environmental Impact and Benefits Assessment 

for Final Effluent Guidelines and Standards for the Construction and Development Category

(EPA 2009b), which discusses the results of the SPARROW modeling and the monetized 

benefits of the regulatory options. The entire loading analysis is in the C&D Load Spreadsheet 

Model (DCN 43121). 

10.6. REFERENCES 

Miller, D.A., and R.A. White. 1998. A conterminous United States multilayer soil characteristics 

data set for regional climate and hydrology modeling. Earth Interactions 2(2):1–26. 
Section 10: Estimating Pollutant Load Reductions 

10-22

TxDOT (Texas Department of Transportation). 2009. NRCS Runoff Curve Number Methods. 

Chapter 5, section 7 in Hydraulic Design Manual. Texas Department of Transportation, Austin, 

TX. <http://onlinemanuals.txdot.gov/txdotmanuals/hyd/nrcs_runoff_curve_number_ 

methods.htm>. Accessed September 27, 2009. 

PRISM Group. 2006. United States Average Monthly or Annual Precipitation (1971–2000). 

Oregon State University, Corvallis, OR. <http://www.prismclimate.org>. Accessed March 

2008. 

USEPA (U.S. Environmental Protection Agency) 2009b. Environmental Impact and Benefits 

Assessment for Final Effluent Guidelines and Standards for the Construction and 

Development Category (EPA-821-R-09-012). 

URS (URS Corporation). 2008. Analysis of Draft General Permit Risk Factors. 

<http://www.waterboards.ca.gov/water_issues/programs/stormwater/docs/constpermits/ 

comments/cbia_risk_factor.pdf>. Accessed September 27, 2009. 

USDA (U.S. Department of Agriculture). 1997. Predicting Soil Erosion by Water: A Guide to 

Conservation Planning With the Revised Universal Soil Loss Equation (RUSLE). Agriculture 

Handbook Number 703. U.S. Department of Agriculture, Washington, DC. 

Wischmeier, W.H., and D.D. Smith. 1978. Predicting Rainfall Erosion Losses - A Guide to 

Conservation Planning. AH537. U.S. Department of Agriculture, Washington, DC. 
Section 11: Non-Water Quality Environmental Impacts 

11-1

11. NON-WATER QUALITY ENVIRONMENTAL IMPACTS 

Sections 304(b) and 306(b) of the Clean Water Act require the U.S. Environmental Protection 

Agency (EPA) to consider non-water quality environmental impacts (including energy 

requirements) associated with effluent limitations guidelines and standards. In accordance with 

those requirements, EPA has considered the potential impacts of the options on energy 

consumption, solid waste generation, and air emissions. The estimates of the impacts for the 

construction and development (C&D) industry are summarized in Sections 11.1, 11.2, and 11.3. 

Additional information on the calculation of the estimates is in DCN 43111 in the Administrative 

Record. 

11.1. ENERGY REQUIREMENTS 

EPA considered the additional energy requirements attributable to the regulatory options 

(Section 11.1.1) and the production of treatment chemicals (Section 11.1.2) and compared the 

option energy requirements with the energy requirements of the C&D industry (Section 11.1.3). 

11.1.1. ENERGY REQUIREMENTS ATTRIBUTABLE TO THE REGULATORY 

OPTIONS 

EPA estimates that additional energy requirements attributable to the regulatory options being 

considered are the result of the additional sediment removed from basins, traps, and other areas 

of accumulation. In addition, Options 2 and 3, which rely on the use of active treatment systems 

(ATS), would have additional energy requirements for operating pumps and generators. EPA 

assumes that diesel powered generators and pumps would be used to operate ATS. For a 500-

gallon-per-minute (gpm) system, fuel consumption is approximately 10 gallons per hour (Rain 

for Rent 2008). Table 11-1 presents estimates of energy usage by regulatory option considered. 

Under Option 4, a small amount of energy could be required if metering pumps are used for 

introducing liquid polymer. EPA has not quantified energy usage for the pumps, but the amount 

of energy usage is expected to be minimal. The passive treatment technologies of Option 4 

generally rely on gravity, so can be configured so as to utilize gravity flow of water through 

channels and basins, so the significant use of pumps and generators is not anticipated. However, 

permittees may utilize pumping to move water around construction sites and for dewatering 

trenches and excavations, but EPA has not quantified potential energy usage for pumping as the 

need for pumping would be highly site-specific. 
11-2 

Table 11-1. Estimated energy consumption by regulatory option 

Sediment excavation On-site trucking Active treatment 

Option 

Sediment 

removal 

(tons/year) 

Equipment 

run time for 

excavation 

(hours/year) 

Excavator 

fuel 

consumption 

(gallons/year)

# of 

truckloads 

Truck fuel 

consumption 

(gallons/year)

Water volume 

treated (billion 

gallons/ year) 

Equipment 

run time 

(hours/year 

@ 500 gpm)

F

consu

(gallo

gallo

1 871,492 3,320 28,552 24,900 4,980 N/A N/A N2 1,808,143 6,888 59,238 51,661 10,332 180 5,989,567 59,83 2,253,559 8,585 73,831 64,387 12,877 273 9,090,525 90,94 1,985,567 7,564 65,051 56,730 11,346 N/A N/A N
Section 11: Non-Water Quality Environmental Impacts 

11-3

11.1.2. TREATMENT CHEMICAL PRODUCTION 

EPA considered the availability and additional energy consumption from treatment chemicals. 

Section 11.1.2.1 describes chitosan and Section 11.1.2.2 describes polyacrylamides (PAMs). 

EPA expects that under Options 2 and 3, chitosan would primarily be used. Under Option 4, 

EPA anticipates a mix of both chitosan and PAMs. Results for both 100 percent chitosan use and 

100 percent PAM use are presented for Option 4. 

11.1.2.1. Chitosan 

Chitosan is derived from chitin, the major component of crustacean shells and is a cationic 

polyelecrolyte. Chitosan (poly-D-glucosamine) is one of the most common polymers found in 

nature (USEPA 2003). Chitin is the second-most abundant natural fiber after cellulose and is 

similar to cellulose in many respects (Hennen 1996). Global Industry Analysts, Inc., estimates 

that the global chitin market will exceed 51.4 thousand metric tons (113 million pounds) by 2012 

(Global Industry Analysts, Inc. 2008). The United States could produce approximately 30 

percent of the worldwide shellfish harvest each year (Hennen 1996). Therefore, EPA estimates 

that the U.S. chitin market could approach 34 million pounds by 2012. 

Minton (2006) reports an average chitosan acetate dose rate of 2 milligrams per liter (mg/L). 

Minton (2006) notes that the Washington State Department of Ecology specifies a maximum 

dosage of 1 mg/L but that variances are granted for turbidities greater than 600 nephelometric 

turbidity units (NTUs). Minton (2006) reports chitosan acetate dosages as high as 3 mg/L. Table 

11-2 presents the amount of chitosan acetate required from applying a 2 mg/L chitosan acetate 

dosage to the stormwater volumes (from Section 11.1.1, Table 11-1) requiring treatment. Note 

that under Option 4, it is not likely that chitosan acetate would be used to treat all stormwater 

generated. Nonetheless, EPA has included estimates here. The option 4 volumes are the same as 

Option 3, because the acreage threshold (10 acres) is the same. 

Table 11-2. Maximum chitosan acetate required under EPA options 

Option 

Stormwater treated 

(billions of gallons) 

Chitosan acetate required 

(pounds) 

2 180 3,000,000 

3 273 4,560,000 

4 273 4,560,000 

The amount of chitosan acetate in Table 11-2 represents a fraction of the total chitin market. In 

addition, EPA expects the amount of chitosan would be less than the amount presented in Table 

11-2 because many construction sites would use other treatment chemical alternatives, including 

PAMs, described in Section 11.1.2.2. 

Because chitosan is manufactured from crustacean shells and not petroleum products, additional 

energy consumption from chitosan production and use is expected to be minimal. 
Section 11: Non-Water Quality Environmental Impacts 

11-4

11.1.2.2. Polyacrylamides (PAMs) 

PAMs are a broad class of compounds that include cationic (positively charged) and anionic 

(negatively charged) PAM. PAMs are water soluble over a wide pH range and exhibit a high 

affinity for suspended sediment. PAMs are derived from acrylamide, of which 94 percent is used 

as PAMs (ICIS Chemical Business 2008). U.S. demand for PAMs is presented in Table 11-3. 

Table 11-3. U.S. acrylamide/PAMs demand* 

Year 

Acrylamide demand 

(million lbs) 

PAM demand 

(million lbs) 

2007 253 238 

2011(projected) 290 273 

Source: ICIS Chemical Business 2008 

* U.S. demand equals production plus imports less exports 

Polymers such as PAMs are produced from petroleum, so additional PAMs consumption to treat 

construction site stormwater runoff would result in increased petroleum consumption. However, 

consumption on construction sites is not expected to significantly increase demand for 

acrylamide. EPA estimates that total treatment volumes under Option 4 are 273 million gallons 

per year. Assuming a PAMs dosage of 2 mg/L to all stormwater generated, incremental PAM use 

under Option 4 would be 4,560,000 pounds per year. 

11.1.3. COMPARISON OF OPTION ENERGY REQUIREMENTS TO 

CONSTRUCTION INDUSTRY 

Table 11-4 presents an estimate for construction industry fuel consumption based on the 2002 

census. 

Table 11-4. 2002 Energy use in NAICS Category 23 

Census category NAICS category 23 2002 unit cost 

NAICS category 23 energy use 

(millions of gallons) 

Gasoline and diesel fuel $10,953,670,000a $1.32/gallonb 8,300 

a

 U.S. Census Bureau 2002. 

b

 Energy Information Administration 2002. 

Table 11-5 presents estimates of energy usage by regulatory option considered, compared to the 

total annual diesel and gasoline consumption in NAICS Category 23 (Construction). 

Table 11-5. Estimated incremental energy usage by regulatory option 

Option 

Option diesel consumption 

(gallons) 

Fraction of NAICS category 23 

energy (gallons) 

Option 1 33,532 0.000004 

Option 2 59,965,244 0.007 

Option 3 90,991,961 0.011 

Option 4 76,397 0.000009 
Section 11: Non-Water Quality Environmental Impacts 

11-5

EPA does not expect any adverse effects to occur as a result of the small incremental energy 

requirements for the regulation. 

11.2. AIR EMISSIONS IMPACTS 

The Agency believes that none of the regulatory options for this rule would generate significant 

air emissions. 

According to the Construction Industry Compliance Assistance Compliance Summary Tool 

(http://www.cicacenter.org/cs.cfm) no federal Clean Air Act (CAA) requirements apply to the 

C&D industry. CAA requirements are implemented primarily by states through their State 

Implementation Plans (SIPs). Following are examples of construction-related emissions that 

might require a state permit under an SIP: 

 Nitrogen oxides (NOx) and fine particulates from construction equipment diesel 

engines 

 Dust from vehicle traffic, from loading and unloading of construction materials at 

transfer points, and from conveyor systems transporting building materials 

 Visible stack emissions from off-road equipment 

 Volatile organic compounds (VOCs) from paint and cleaning solvents 

To the extent that use of heavy construction equipments would be expected to increase from 

removing accumulated sediment, or portable generators or diesel powered pumps are used to 

power ATS, there would be an increase in fine particulate matter, VOCs, and NOx, and other 

pollutants, as well as increased CO2 emissions, as estimated below. 

EPA estimates air emissions on the basis of emission factors from diesel generators, the primary 

source of construction site air emissions, and excavators and trucks to remove accumulated 

sediment. A 135-kilowatt generator (210 horsepower [hp]) generator would consume 

approximately 10 gallons of diesel per hour (Diesel Supply and Service, No date). EPA 

multiplied the total system run times presented in Section 11.1 by the emission factors from the 

California South Coast Air Quality Management District (SC AQMD 2008)). Table 11-6 

presents the estimated incremental air emissions by regulatory option.

Table 11-6. Estimated incremental air emissions by regulatory option (pounds/year) 

Option 

Reactive 

organic 

gases 

(ROG) 

Carbon 

monoxide 

(CO) 

Nitrogen 

oxides 

(NOx) 

Sulfuric 

oxides 

(SOx) 

Particulate 

matter (PM) 

Carbon 

dioxide (CO2) 

Methane 

(CH4) 

Option 1 2,066 6,731 19,299 20 794 1,829,303 186 

Option 2 1,116,150 3,997,266 11,595,274 11,860 442,759 1,052,768,276 100,692 

Option 3 1,692,847 6,062,967 17,587,588 17,989 671,540 1,596,784,327 152,718 

Option 4 4,707 15,335 43,970 45 1,809 4,167,800 424 
Section 11: Non-Water Quality Environmental Impacts 

11-6

Because construction air emissions are primarily from fuel combustion, EPA estimates that the 

increase in air emissions relative to the construction industry air emissions would be similar to 

the estimates for the fraction of construction industry fuel consumption presented in Table 11-5. 

11.3. SOLID WASTE GENERATION 

Solid waste generated at C&D sites include treatment residuals generated as part of coagulation 

and flocculation from ATS, and sediment that accumulates in channels, basins, and traps that are 

used as part of passive treatment systems. If ATS are used, solid waste can include spent 

cartridge or bag filters, or filter media (usually sand). EPA did not quantify solid waste generated 

from spent cartridge or bag filters because it is not clear whether permittees would require 

cartridge or bag filters as a final finishing step after ATS. Sediment removed from sediment 

basins and ATS, including sediment-containing polymers, can generally be used as fill material 

on the construction site. Therefore, EPA expects that solid waste generation would be minimal 

under any of the options. 

11.4. REFERENCES 

Diesel Service and Supply, Inc. No date. Approximate Fuel Consumption Chart. 

<http://www.dieselserviceandsupply.com>. Accessed November 14, 2008. (DCN 43090) 

Energy Information Administration. 2002. Average 2002 diesel fuel cost. U.S. On-Highway 

Diesel Fuel Prices. Energy Information Administration, Washington, DC. 

<http://tonto.eia.doe.gov/oog/info/wohdp/diesel.asp>. Release Date April 21, 2008. (DCN 

43088) 

Global Industry Analysts, Inc. 2008. PRWeb Press Release Newswire. Global Chitin Market to 

Exceed 51.4 Thousand Metric Tons by 2012. (DCN 43084) 

Hennen, W.J. 1996. Chitosan. Woodland Publishing, Pleasant Grove, UT. (DCN 43085) 

ICIS Chemical Business. 2008. Chemical profile: acrylamide. 

<http://www.icis.com/Articles/Article.aspx?liArticleID=9141553>. Accessed November 6, 

2008. (DCN 43086) 

Minton, G.R. 2006. Technical Engineering Evaluation Report (TEER) for the ChitosanEnhanced Sand Filtration Technology for Flow-through Operations. Technology developed 

by Natural Site Solutions, LLC, Redmond, WA, study prepared by Resource Planning 

Associates, Seattle, WA. (DCN 43002) 

SC AQMD (South Coast Air Quality Management District). 2008. Off-road Mobile Source 

Emission Factors. California South Coast Air Quality Management District, Diamond Bar, 

CA. <http://www.aqmd.gov/ceqa/handbook/offroad/offroad.html> Accessed May 22, 2008. 

(DCN 43089) 

Rain for Rent. 2008. Chitosan-Enhanced Sand Filtration Example Quote #1 and #2 (March 

2008). Rain for Rent, Bakersfield, CA. (DCN 43007) 
Section 11: Non-Water Quality Environmental Impacts 

11-7

U.S. Census Bureau. 2002. Economic Census Construction Industry General Summary 2002. 

Issued October 2005. U.S. Census Bureau, Washington, DC. (DCN 43079) 

USEPA (U.S. Environmental Protection Agency). 2003. Chitosan: Poly-D-glucosamine 

(128930) Fact Sheet. 

<http://www.epa.gov/pesticides/biopesticides/ingredients/factsheets/factsheet_128930.htm>. 

Accessed November 14, 2008. (DCN 43087)