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HomeMy WebLinkAboutNC0004979_Storm Water Discharges_19960408- DRAFT - Permit Requirements for Stormwater Discharges from Oil & Petroleum Storage Facilities Background/ Introduction The Permits and Engineering Unit reviewed NPDES permit monitoring requirements for stormwater discharges at oil terminal facilities located in the Greensboro and Charlotte areas. This review revealed inconsistencies in monitoring, requirements. These inconsistencies were discussed with staff of the Winston-Salem and Mooresville regional offices. These discussions and a review of past information collected at these facilities form the basis for the standard monitoring requirements'contained in this Standard Operating Procedure (SOP) for Stormwater Discharges from Oil Terminal Facilities. Examples of effluent monitoring sheets are included at the end of this SOP. One sample effluent sheet is for oil terminal facilities that discharge to water supply classified waters, while the second effluent sheet is for facilities that discharge to non -water supply classified waters. Review of oil terminal facility permits also indicated that wastewater sources were not always identified, thus, the State will request that the oil terminal facilities characterize their wastewater sources. Specifically, the State will request plans delineating the oil terminal and identifying wastewater sources for each region within the oil terminal facility. This delineation will also specify different wastewater treatment methods for different wastewater sources (if appropriate). This information request will be included in the cover letter accompanying the draft permit. It is the intent that information gathered may be incorporated into the final permit. I. Minimum Requirements for ALL Oil Terminal Facilities A. Flow Measurement of flow is to be representative of a discharge event. Many oil terminal facilities have storage ponds to collect runoff and therefore, discharges may not always occur during storm events. Flow should be monitored by one of the following methods: 1) Measure flow continuously, or 2) Calculate flow based on the area draining to the outfall, the built -upon area, and the total rainfall, using the rational equation (see below), or 3) Estimate by flow measurement at 20 minute intervals during the entire discharge event, or 4) Base flow on pump logs. The rational equation: Q=KuCIA, where Q=flow (peak flow rate (cfs or m3/sec) Ku=units conversation factor = 1.008 for U.S. standard units (usually ignored because it is so close -to 1), or 0.278 for SI units C= dimensionless runoff coefficient for the watershed, loosely defined as the ratio of runoff to rainfall I=intensity of rainfall taken from the intensity -duration -frequency. curves for the specified design return period at the time of concentration tc, (in/h or mm/h) tc=time of concentration - time after the beginning of rainfall excess when all portions of the drainage basin are contributing simultaneously to flow at the outlet A=area of tributary watershed (acres or km2) is used to calculate the runoff from a region, given the runoff coefficient which accounts for infiltration and other potential losses in the region, the rainfall intensity, to the region, the time it B. Benzen--_ Daily w Bcnx--, slipp! anatv!-'i�: violwWr, recclv_,:. no WLi! REFERE TI", — Dodson, P ­ Er . Linville, R�,n. C11; USEPA. E111 April 8, 1996 Page 6 0, receiving stream under average flow conditions risk to humans consuming n'/.c n e in waters classified as water of past data, a reasonable potential potential for a water quality standard 1. 9 Clli:'/I multiplied by the dilution of the -�Jizm rl to two significant digits). If there is i i &,requirement. o !h�_" )24/6)25 series semi-annual monitoring i,,r supply classified waters. In non - 'M 1-:11111UL11 monitoring is required. !%/h: 1,hod Is Most Rational?. Civil el. --hone conversation with P. Control. , il I April 8, 1996 Page 2 takes for runoff to travel from the region's upper reaches to its outlet, and the region's drainage area. For oil terminal facilities with large storage ponds that serve to collect runoff, item no. 2 listed above and the rational equation should not be used because the calculations will determine the flow to the storage pond, rather than the flow from the pond. B. Acute Toxicity - Fathead Minnow (Pimephales promelas) 24 -hr, Episodic Monitor annually (assuming first five discrete storm events have already been monitored and showed no toxic effects) Monitoring Footnote: acute toxicity monitoring should occur during one of the two semi- annual EPA Methods 624/625 monitoring events (see item E below). Products stored at oil terminals may contain a variety of different chemicals (some of which may have harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90% waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges. Facilities that meet one or ,more of the following criteria will not qualify for annual monitoring and will be required to monitor for acute toxicity during five storm events: 1) Facilities that have never monitored for acute toxicity during a storm event, or 2) Facilities that monitored for acute toxicity during four or fewer storm events during the last permit period, or 3) Facilities that completed five acute toxicity tests during five storm events, but did not pass all five tests. Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period, and must .receive State approval for reduced monitoring. For facilities that have not yet conducted acute toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional toxicant limits should the toxicity. test indicate toxic effects. At the time of permit renewal, only annual monitoring for toxicity would be required if the facility has performed the five discrete sampling requirements with no acute toxicity. C. Total Suspended Solids Monitor monthly Daily maximum 45.0 mg/1 Historically; TSS has not been a significant problem in stormwater discharges at oil terminal facilities. An analysis of TSS data from five stormwater dischargers indicated only one event in excess of the permitted 30.0 mg/l monthly average. Should TSS monitoring data indicate any substantial problems, the Regional Office may elect to enforce the instream standard for turbidity. D. Oil and Grease Monitor monthly - No Limit Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from the water surface of a quiescent (calm water) zone. In cases when. i be require;' f'(.) potential violation, 111. Add --'1o'--- I A. Pheno!:!:1,' Phenol: 4-c 2, 2, 5 2,(,,- 3, 2, J. 2,4, 2, 3, - 2-;r, 3 - 3 - Plif.'n", -- cal is fis ph fol WC11., As po`-:si fo I. pr' at 1V c 1;' Cl-, 1, w'. be April 8, 1996 Page 5 1;61 it requirement, monthly monitoring should in he obtained and a second reasonable potential for a water quality Supp!y (WS) Waters S rr )n?.1;tor for separately) st-parateIy) for separately) -'n for separately) r for separately) s'or separately) `series, monitor for separately) --iiS series, monitor for separately) SO series, monitor for separately) � 1,t and should not be grouped in the same lvcr!cntly done in the past). Phenol ci le.niiipals, can result in tainting of M drinking water. In addition, i n water treatment facilities to 111' i,,heiiol into water supply classified q oiid their concentration in drinking water. (),tl ti�rniiiial facility discharges and the ''I -ed on a monthly basis in water F U) pg/l. There is limited toxicity data cL supplies from taste and odor r. 1 s o l.' netroleurn compounds stored !I he established (if necessary). C!, 1 or i liated phenols in water supply :red semi-annually at oil terminals that ."-Y!"S Mch,idcs phenol and some, but not r,:1 C11 0 1 Under the 624/625 series is cif "ch lor;,-atcd phenol formation in water ;:1111Uad monitoring will be required for Yc-ics) only in water supply classified it is known that they can April 8, 1996 Page 3 Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal facilities. H¢wever, it is suspected that the samples are typically collected using an inappropriate sampling method. Where possible, oil and grease samples should be skimmed from the surface of a quiescent zone closest to the discharge. This is often difficult to achieve given the nature of stormwater discharges. E. EPA Methods 624 land 625 (Base/Neutral and Acid Extractables) Monitor semi-annually (assuming no reasonable potential - see Section II) Historical data indicate that organics are not discharged at concentrations greater than water quality standards. However, because products stored at oil terminals may contain different types. of organic chemicals, there exists the potential for organics to be released at these facilities. Semi-annual monitoring is recommended to develop a database documenting the amount and types of organics potentially released from each site. More frequent monitoring would be required if the reasonable potential for a water quality standard violation is demonstrated (see Section II). F. Tank Solids, Tank Bottom Water, and Rag Layer No direct discharge of tank solids, tank bottom water, or the rag layer is permitted. There are typically four discrete layers of varying thicknesses (see diagram) within a terminal tank. At the very bottom of the tank is the solids layer which achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the solids layer is 1-6 inches of tank bottom water which results from rain water breaching the wall seal in open roof tanks. Open roof tanks are not completely open, but have a roof floating directly on the product. There is a seal between the tank walls and floating roof designed to prevent water from entering the tank. Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is removed because water entering tanker trucks must be minimized. As a result of potentially high levels of organic compounds in the three bottom layers of storage tanks, they are not to be discharged,. but instead should be transported off-site for appropriate treatment and/or disposal or treated/recovered onsite if treatment technology capabilities occur onsite. G. Hydrostatic Testing Hydrostatic testing of oil tanks normally occurs once every five or six years. Prior to the hydrostatic testing, the tank is completely drained and tank bottom materials are handled as described in the previous section. The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly clean. However, tank discharges following hydrostatic testing may contain contamination. 'Therefore, monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are greater than their respective water quality standards (see effluent pages at end of SOP for details). II. Additiepa1! , The reason!)±,',. violate ,. - determ i P' :. monito ri, . L, quality sian .- . effluentconc.­ ... Reasonable no! that has ci, r works he,, : point; maxim , ; r. for do . detenu ' . April 8, 1996 Page 4 i"I 6n Reasonable Potential .! ! cictermine the potential of a discharge to _ d on existing data. If a parameter is _i ! C I_ CI Liality standard, a limit and monthly } t I vc reasonable potential to violate a water t concentration is greater than the allowable tical analysis for each parameter of concern rci. 1 cn- eacli parameter, the statistical analysis nis (from DMRs) although the more data P! : ,tical amilysis allows one to calculate a 1'."IstiII2 data set. A step-by-step procedure n . i ted based on reasonable potential charas 4 STEP l 2 ;:I .,fc;ssional judgment should be used by the P V t1Ier will not be determined statistically, 3 �' ;'✓/i�IAI� 4 r I," used by comparing the number of 5 I ) ,y tI tc multiplication factor determined Ira Lion. 6 : c t d c, ffluent concentration) with the zl. t ir,strcam dilution and the corresponding a I ner,nitting authorities find reasonable „nc�,ntration is greater than the allowable l• ' A sprea&'­­�' 'i i.. It is titled "Toxicant Spreadsheet" and is located on ! n t, t o f the facility name and permit numbcr, t . m, fcacral water quality standard, and the MI..:' t ;!ren computes the standard deviation, mean, a : _ts. he coefficient of variation is then used `, h � - I, t h u spreadsheet) to determine the Multip l ; ! c > "Fox icant Spreadsheet to calculate the maxi If the ma..i , ,; th;tn or equal to the allowable effluent concen tri. n c, t ti t i al for a water quality standard violation;, t nd monitored on a monthly basis. The dc} ;., zt naram,,eter multiplied by the dilution of the recinogens. Average flow should be used If o f a,_ ' I i I, I'S gar o U 1, d be obtained over a five-year perm 1: r o !'(-'I ata points which will accurately charas 4 April 8, 1996 Page 4 II. Additional Site -Specific Requirements Based on Reasonable Potential The reasonable potential procedure is a method used to determine the potential of a discharge to violate a water quality standard for a given parameter based on existing data. If a parameter is determined to have reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A parameter is determined to have reasonable potential to violate a water quality standard if a calculated maximum predicted effluent concentration is greater than the allowable effluent concentration. Reasonable potential is determined by performing a statistical analysis for each parameter of concern that has either a state or federal water quality standard. For each parameter, the statistical. analysis works best with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent concentration based on the existing data set. A step-by-step procedure for determining whether or not a parameter should be limited based on reasonable potential determination follows: STEP 1 Determine the number of sample points (n) 2 Determine highest value from data set. Best professional judgment should be used by the reviewer so as not to use an outlier. Since an outlier will not be determined statistically, maximum values should rarely be discarded in this analysis. 3 Determine the coefficient of variation (CV = STD DEV/MEAN) 4 Determine the appropriate multiplication factor to be used by comparing the number of samples versus the co -efficient of variation (see Table 3-1) 5 Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to obtain the maximum predicted effluent concentration. 6 Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable effluent concentration, which is based on instream dilution and the corresponding water quality standard. EPA recommends that permitting authorities find reasonable potential when the maximum predicted effluent concentration is greater than the allowable effluent concentration. A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is located on the NPDES server. The spreadsheet requires the input of the facility name and permit number, the waste flow (QW), 7Q10 flow, pollutant name, state or federal water quality standard, and the DMR data points with appropriate units. The spreadsheet then computes the standard deviation, mean, and coefficient of variation for the entered data points. The coefficient of variation is then used along with n (the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted concentration. If the maximum predicted effluent concentration is greater than or equal to the allowable effluent concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the parameter should be limited (as a daily maximum) and monitored on a monthly basis. The daily maximum limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream under summer 7Q10 conditions for non -carcinogens. Average flow should be used for carcinogens and 30Q2 flow should be used for aesthetic standards. If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit period which is slightly more than the minimum number of data points which will accurately characterize an effluent discharge (USEPA March 1991). Historically, oll r term i!,.•,' inapp!•�)_, fro m t given E. EPA Monitor . ; April 8, 1996 Page 3 • ;i ic•4nt problem in stormwater discharges at oil t samples are typically collected using an i l and grease samples should be skimmed (h,- 111scharge. This is often difficult to achieve =r" a- .0 Acid Extractables) potcJitial - see Section II) Historical ct:)t; ! . t c isch trged at concentrations greater than water qual i t t .: c l at "I l terminals may contain different types Of (It ! .. • i,.-. s to be released at these facilities. Suri !:ff) N database documenting the amount and P.Zore frequent monitoring would be reyv :I y standard violation is demonstrated (see See i io;.. F. Tpnk ::: ,.,h5 _ ayer No dircct c1:..... • !: a an r,' or the rag layer is permitted. There ;ir- f•,,, ' !Cl<nesses (see diagram) within a terminal tan"I. ' •„ •r Which achieves a 1/2-1 inch thickness ovci, a _ 4 ::)yer is 1-6 inches of tank bottom water wh MC �ncn roof tanks. Open roof tanks are not co+ tic testing if concentrations of benzene `u" product. There is a seal between the tale. of ::: ;"rom entering the tank. Water breaching this I nttom water. The rag layer is at most 3/4 inch t' :'.: , h ! ,gym water and the product. The product is the !; -;: hottom water is removed from the tank wbcj" i:> _. ! ; roduct in the rag layer is often drawn off -:Cr trucks must be minimized. Asa result of Polo e bottom layers of storage tanks, they arc,• rtcd off-site for appropriate treatment an.":,, ,•` hnology capabilities occur onsite. G. Hyde :, - il_c every five or six years. Prior to the ' tank bottom materials are handled as l y c leaned and then coated and welded hydrostatic test. Some oil terminal fac :1 i t i r t a n ks, while others use potable city refilling with water for the hydrostatic test, ;/clrostatic test should be fairly clean. He M> Iy contain contamination. Therefore, MC he required. There shall be no direct dist,:,: tic testing if concentrations of benzene � ! T;; i t y standards (see effluent pages at end of ::: April 8, 1996 Page 5 In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be required for at least 10 months so that 10 data points can be obtained and a second reasonable potential calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring should be reduced to semi-annually. III. Additional Monitoring Requirements For Water Supply (WS) Waters A. Phenol and Chlorinated Phenols Phenol: Monitor monthly. Chlorinated Phenols: Monitor semi-annually 3 - chlorophenol (not included in 624/625 series, monitor for separately) 4 - chlorophenol (not included in 624/625 series, monitor for separately) 2, 3 - dichlorophenol (not included in 624/625 series, monitor for separately) 2, 5 - dichlorophenol (not included in 624/625 series, monitor for separately) 2, 6 - dichlorophenol (not included in 624/625 series, monitor for separately) 3, 4 - dichlorophenol (not included in 624/625 series, monitor for separately) 2, 4, 5 - trichlorophenol (included in 624/625 series) 2, 4, 6 - trichlorophenol (included in 624/625 series) 2, 3, 4, 6 - tetrachlorophenol (not included in 624/625 series, monitor for separately) 2 - methyl - 4 - chlorophenol (not included in 624/625 series, monitor for separately) 3 - methyl - 4 - chlorophenol (included in 624/625 series) 3 - methyl - 6 - chlorophenol (not included in 624/625 series, monitor for separately) Phenol and chlorinated phenols are separate and distinct and should not be grouped in the same category when determining discharge limits (as has been inadvertently done in the past). Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish tissue, and can cause taste and odor (organoleptic) problems in drinking water. In addition, phenol discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce chlorinated phenol formation and their concentration in drinking water. As a result of the expected occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation, phenol will be monitored on a monthly basis in water supply classified waters. Chlorinated phenols have a state water quality standard of 1.0 µg/1. There is limited toxicity data for chlorinated phenols, thus, the 1.0 µg/1 standard protects water supplies from taste and odor problems. It is unlikely that chlorinated phenols are components of petroleum compounds stored at terminals, however, data must first be collected before limits can be established (if necessary). Monitoring will only be required on a semi-annual basis for chlorinated phenols in water supply classified waters. The EPA Methods 624/625 monitoring series is required semi-annually at oil terminals that discharge into waterbodies of any classification. This series includes phenol and some, but not all, of the chlorinated phenols. Semi-annual monitoring for phenol under the 624/625 series is adequate in non -WS waters because the potential danger of chlorinated phenol formation in water treatment facilities does not exist. Separate semi-annual monitoring will be required for chlorinated phenols (not included as part of the 624/625 series) only in water supply classified waters because, although there is limited data on this set of compounds, it is known that they can be a problem in water treatment facilities. April 8, 1996 Page 2 takes for rtmol.I. 1n ; : t nn r reaches to its outlet, and the region's drainage area. For oil ttr "; �,oi s that serve to collect runoff, item no. 2 listed above 1:;cd Jbecause the calculations will determine the t flow to h!.: �, .Morn tl e pond. B. Acute Monitor all n,w!I\1 i: showed l ­lo Moni!or;, { anua! Prod t,ic may I,., „ surface test is events. minnow,; 1) Fay: 2) Fay': perm i, 3) Far. all I'i Faci!it;�.,; du -in _ ;l fort]�c. faci]iti,•s !i stat , c tox is req k; i ,- toxic: C. Tot, moll; 1nr r ,.. Dai!y ; Hist , : '' •. ' faci!i: exc�._ sul... D. O> MO!,t,: Monit ,. from t' promelas) 24 -hr, Episodic storm events have already been monitored and <i r,rin, shOld occur during one of the two semi- !: item E below). tierof different chemicals (some of which i� toxic chemicals are not discharged to c.. A_n acute, rather than chronic, toxicity .,,c,s are typically short-term, episodic I at � t % waste concentration using fathead n tcr discharges. ?A.�'i�-Io criteria will not qualify for annual t x i c i ty during five storm events: u ring a storm event, or u r or fewer storm events during the last r c� five storm events, but did not pass , one or more of the five storm events or conduct quarterly monitoring for the -.dj approval for reduced monitoring. For for the first five discrete storm events, a a i limits should the toxicity test indicate w ;, a al monitoring for toxicity would be ,o sampling requirements with no acute in stormwater discharges at oil terminal r dischargers indicated only one event in ould TSS monitoring data indicate any force the instream standard for turbidity. s:i mn]e for oil and grease should be skimmed I� April 8, 1996 Page 6 B. Benzene Monitor monthly Daily maximum limit - 1.19 ug/1 * dilution of the receiving stream under average flow conditions Benzene is a known carcinogen and can pose a potential health risk to humans consuming water with benzene. The water quality standard for benzene in waters classified as water supplies is 1.19 ug/l. If there is an adequate amount of past data, a reasonable potential analysis should be conducted. If there is reasonable potential for a water quality standard violation, the daily maximum limit given should be 1.19 ug/l multiplied by the dilution of the receiving stream under average flow conditions (rounded to two significant digits). If there is no reasonable potential, there will only be a monthly monitoring requirement. Monthly monitoring for benzene is in addition to the 624/625 series semi-annual monitoring (which includes benzene) but is only required in water supply classified waters. In non - water supply classified waters, only the 624/625 series semi-annual monitoring is required. REFERENCES Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering News. Linville, Ron, (Winston-Salem Regional Office) March 1996. Telephone conversation with P. Clark. USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/505/2-90-001. - DRAFT - Permit RPquirr nients for Stormw (11�it r*: Stora Background/ Introduction r Discharges from Facilities The Permits and Engineering ?Jnit reviewed NODES permit monitoring requirements for stormwater discharges at oil terminal f tcilit.ics docat: ci in the Greensborpp and Charlotte areas. This review revealed inconsistencies in monitoring rca,tircm nts. These inconsistencies were discussed with staff of the Winston-Salem and Mootesvillc rc`,;on;d offices. These discussions and a review of past information collected at these facilities fornn cite hasis l'or the standardi monitoring requirements contained in this Standard Operating Proccdtu-c (S )P) for Stur-Inwater Discharges from Oil Terminal Facilities. Examples of effluent monitoring sheets ttrc. niclud(:rl at the cnd of this SOP. One sample effluent sheet is for oil terminal facilities thaters, while the second effluent sheet is for facilities that discharge to nota -I," waterst Review of oil terra i n r 1 t': c i 1 i t y p e rrn i t s a I ,;o indica ted that wastewater sources were not always identified, I thus, the State will rc�_it,cst th tt. i1; c,il facilities characterize their wastewater sources. Specifically, the Si:tc \,'i: i , , n . '. c. ;n< the oil terminal and identifying wastewater sources for each region w i ! f} I,-, , ; c k),: P i s c f l i n esti on will also specify different wastewater treatment methods frr •1'1' `.� -- .'M1* . �s (i! appr1 priate). This information request will be included in the co\rcr'c i :.t ft ;,_ rt pit. Li is the intent that information gathered may be incorporated into I. Minimum :. "°,: _:_ .-alfacilities A. Flow Measurement: of 11.�-�r� ;i h- ± v -s,,,, !!t;ive of a discharge event. Many oil terminal facilities have storn'l_ �discharges may not always occur during storm o I' thie following methods: 1) Measure_, 2) C L,1 (_­ rainf.ii. 3) Estim:,t.: 4) Banc The rationni cgii:-1il:il: _ to (lie or 1:11crVB tfall, the built -upon area, and the total during the entire discharge event, or .< — )i• U.S. standard units (usually ignored because it ., -. C= c! ; - " . . , ;! Cor the w a I rshed, loosely defined as the ratio of l ; �',i,•nsity-duration-frequency curves for the specified c' t;ration te, (in/h or mmlh) . � � i 11 n i lig of rainfall excess when all utm g simultaneously to flow at the outlet is used to c:J::1. 1-,.1, I",I"o on given the runoff coefficient which accounts for infiltrati. n : en, the.,rainfall intensity to the region, the time it