When Things Aren't Always What They Seem: A Stormwater Pollution Prevention / Good Housekeeping Case Study in Erie County, NY

The Environmental Protection Agency (EPA) cited the Erie County Department of Public Works (ECDPW) in November 2011, December 2011, and February 2012 for violations at the East Concord, Collins, and Angola Highway Maintenance facilities respectively. One of the primary concerns of the citations were that the stormwater collection systems at these sites, particularly trench drains in the vehicle maintenance and storage buildings onsite, connect directly to the waters of the United States without any form of pretreatment or control. As a result of the EPA citations at the three (3) highway facilities, the ECDPW proactively decided to complete pollution prevention / good housekeeping (P2/GH) investigations at all of the County facilities maintained by the ECDPW and the Erie County Department of Parks, Recreation and Forestry (Parks). The purpose of this paper is to review the basic principles of completing an environmental compliance or P2/GH site inspection related to stormwater, in addition to the observations made and lessons learned during this specific project.