Contaminated sites and stormwater infiltration
The Construction Stormwater General Permit prohibits the use of infiltration BMPs in areas where the infiltrating stormwater will mobilize contaminants. However, stormwater infiltration BMPs may be feasible at sites with known contaminated soils or groundwater under certain conditions. This article provides an overview of the types of contaminated sites that may be encountered when considering whether or not to infiltrate stormwater. Contaminants likely to be found at these sites and regulatory information are included in the discussion.
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Types of contaminated sites and likely pollutants at contaminated sites
There are several types of contaminated sites that differ based on historical and present land use, type of contamination, and other factors. The most important types of contaminated sites are discussed below.
Brownfields
A brownfield is a property where redevelopment or reuse may be complicated by the presence (or likely presence) of contamination. Brownfields may include vacant parcels, depending on their prior use. A wide variety of contaminants may be found at a brownfield site depending on the previous use. Common types of brownfields, along with typical contaminants, include the following (U.S.EPA, 2010).
- Gasoline service stations and auto body repair shops: Typically contaminated with petroleum hydrocarbons found in underground storage tanks (USTs), metals associated with motor and hydraulic oils, and/or cleaning solvents.
- Industrial properties: Typically contaminated with asbestos, heavy metals, volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and/or polychlorinated biphenyls (PCBs).
- Commercial properties (e.g., dry cleaning operations): Typically contaminated with asbestos, VOCs, polycyclic aromatic hydrocarbons (PAHs), and/or PCBs.
- Landfills and dumps: Typically contaminated with oils, paints, solvents, corrosive cleaners, batteries, VOCs, PAHs, and/or PCBs.
Superfund Sites
A Superfund site is a site that is regulated under the Superfund program, established under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) and implemented by the U.S. EPA. These sites are abandoned, uncontrolled hazardous waste sites (U.S. EPA, 2011). A list of sites can be found on the National Priorities List. Information can also be found on the MPCA’s webpage under the Superfund Program Site Search. As with Brownfields, a wide variety of pollutants can be present. Some of the common pollutants found at Superfund sites include, but are not limited to, industrial solvents (e.g. trichloroethylene [TCE], tetrachloroethene [PCE], and trichloroethane), waste inks, caustics and acids, paints and paint thinners, VOCs, and asbestos.
RCRA sites
RCRA, or Resource Conservation and Recovery Act, sites are hazardous wastes sites but, unlike Superfund sites, are currently in use (U.S. EPA, 2011). Many of the pollutants found at Superfund sites will also be found in RCRA sites. A list of RCRA sites can be found on the MPCA’s webpage under RCRA Cleanup Site Search.
Underground or aboveground storage tank sites
Storage tank sites that are of concern are those sites which store petroleum or hazardous substances. Common pollutants stored in tanks are petroleum products (e.g., gasoline and diesel), fuel oil, and other liquid hazardous chemicals. A list of leaks/tank sites can be found on the MPCA’s webpage under Leaks/Tanks Search. The MPCA provides a search engine called What’s in My Neighborhood This online application allows a user to search for known contaminated sites in areas near or on a site proposed for a stormwater BMP.
What makes a site contaminated?
Sites that are considered to be contaminated contain one or more contaminant(s) in soil, sediment, or water that exceeds a concentration considered to represent a risk or potential risk to human and ecological receptors. Sites are evaluated through site investigations and a risk-based evaluation. Information on risk-based evaluations is found on MPCA’s website. Contaminated sites should not be confused with stormwater hotspots. Stormwater hotspots are locations where activities or practices have the potential to produce relatively high levels of stormwater pollutants. Hotspots may include contaminated sites, but also include a much broader range of sites that are not necessarily contaminated but that may have or generate relatively high concentrations of pollutants in stormwater runoff. Information on stormwater infiltration at potential and confirmed stormwater hotspots is presented elsewhere in this manual.
Rules regulating stormwater management at contaminated sites
Minnesota’s Construction Stormwater General Permit prohibits stormwater infiltration in areas where high levels of contaminants in soils or groundwater will be mobilized by the infiltrating stormwater. Groundwater rules are contained in Minnesota Rule 7060. These rules were adopted to preserve and protect the underground waters of the state by preventing any new, and abating existing, underground water pollution. These rules form the basis for groundwater protection efforts in several MPCA programs, and include
- defined uses of underground waters,
- a non-degradation policy for the MPCA to follow to ensure underground waters of the state are maintained at their natural quality, and
- standards (e.g., prohibitions) to protect the underground waters of the state.
Sensitive areas are of particular concern for contaminated sites. “Sensitive Areas” are defined in Minnesota Statues 103H.005 Subd. 13 as geographic areas defined by “natural features where there is a significant risk of groundwater degradation from activities conducted at or near the land surface.” Figure 2.8 shows the relative susceptibility of areas in Minnesota as delineated by the MPCA. Additional information about groundwater pollution sensitivity, including definitions of the five relative classes of geologic sensitivity (based on time of travel) provided by the MN DNR is available here. The index is based on the Groundwater Contamination Susceptibility model by the Minnesota Pollution Control Agency (Porcher, 1989).
The MPCA’s Brownfield Program Response Action Plans, 2013 (RAP) provides guidance for stormwater management at sites under the Petroleum Brownfields (PB) Program and the Voluntary Investigation and Cleanup (VIC) Program. While the Brownfield program does not approve stormwater plans, the MPCA does require that applicable stormwater design information be included in the RAP. This program offers the following options (MPCA, 2013).
- Locate the stormwater management to an area of the site that is not anticipated to mobilize contaminants
- Model the subsurface hydrologic setting to demonstrate that existing or residual contamination will not be adversely affected by the stormwater design feature
- Remove soil contamination so as to accommodate infiltration practices
- Consider a non-infiltration stormwater management system