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NRC\'s Urban Stormwater Management in the United States: Implications for MS4 Permi Holders

Michael F. Bloom PE, ENV SP, CFM, BCEE
Michael F. Bloom PE, ENV SP, CFM, BCEE

Reviews the key findings of the National Research Council\'s new report. Highlights possible implications for municipal separate storm sewer system (MS4) permit holders.

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11th Annual EPA Region 6 MS4 Operators Conference, Houston, TX June 25, 2009 The National Research Councils Urban Stormwater Management in the United States: Implications for MS4 Permit Holders Presented by MICHAEL F. BLOOM, P.E., CFM Senior Associate TOPICS National Research Council Why was the Report prepared? Who prepared the Report? What does the Report say? What do others think about it? What is EPA doing in response? What impacts are likely? What should I do now? 1
NATIONAL RESEARCH COUNCIL National Academy of Sciences created in 1863 Private, nonprofit, society of scholars Dedicated to further use of science and technology for general welfare NRC organized in 1916 NRC furthers knowledge and advises the federal government Governed jointly by Institute of Medicine and NAS See www.national-academies.org WHY WAS REPORT PREPARED? [EPA Requested It] Clarify the mechanisms by which pollutants in stormwater discharges affect ambient water quality criteria and define the elements of a protocol to link pollutants in stormwater discharges to ambient water quality criteria. Consider how useful monitoring is for both determining the potential of a discharge to contribute to a water quality standards violation and for determining the adequacy of stormwater pollution prevention plans. What specific parameters should be monitored and when and where? What effluent limits and benchmarks are needed to ensure that the discharge does not cause or contribute to a water quality standards violation? Assess and evaluate the relationship between different levels of stormwater pollution prevention plan implementation and in-stream water quality, considering a broad suite of stormwater control measures (SCMs). 2
WHY WAS REPORT PREPARED? [EPA Requested It] Make recommendations for how to best stipulate provisions in stormwater permits to ensure that discharges will not cause or contribute to exceedances of water quality standards. This should be done in the context of general permits. As a part of this task, the committee will consider currently available information on permit and program compliance. Assess the design of the stormwater permitting program implemented under the Clean Water Act. AUTHORS 3
OVERSIGHT BOARD INPUT RECEIVED FROM STAKEHOLDERS & REVIEWERS City of Austin Heal the Bay King County, WA California Stormwater Quality City of Seattle Association Irvine Ranch Water District Southern California Coastal City of Philadelphia Water Research Project Vermont Department of Southern California Monitoring Environmental Conservation Coalition University of Texas Natural Resources Defense UNC Institute of Marine Council Sciences Geosyntec UCLA Clean Water Services, OR University of Washington Florida Gulf Coast University California Water Board University of Florida City of Los Angeles University of Georgia Michigan State University Minnesota Pollution Control CH2M Hill Agency University of Maryland 4
REPORT TABLE OF CONTENTS REPORT TABLE OF CONTENTS 5
REPORT TABLE OF CONTENTS REPORT HIGHLIGHTS: Challenges Regulatory history Administrative and financial burdens 6
REPORT HIGHLIGHTS: Stormwater Impacts Urbanization is bad for aquatic life REPORT HIGHLIGHTS: Literature Review Excellent references Important conclusions reported and summarized Includes information about: Hydrology MS4 representative monitoring Atmospheric deposition Building materials as a source Urbanization impacts Land use changes Geomorphology Biological responses to urbanization 7
REPORT HIGHLIGHTS: Stormwater Impacts Urbanization leads to habitat loss 8
REPORT HIGHLIGHTS: Monitoring Stormwater MS4 runoff well characterized (see Pitts National Stormwater Quality Database) Industrial monitoring should be risk-based and improved Use continuous, flow-weighted sampling rather than grab sampling Obtain flow and rainfall data Use biological monitoring Obtain statistically valid number of samples REPORT HIGHLIGHTS: Management Approaches BMPs renamed: Stormwater Control Measures (SCMs) Summary of SCMs Impervious cover reductions Rainwater harvesting Swales Silt fences Bio-infiltration 9
REPORT HIGHLIGHTS: Management Approaches Use watershed-based permitting for all sources (wastewater and stormwater) Issue integrated permits by watershed Create lead permittee in each watershed (delegation) Use residual designation authority to bring more urbanized areas into the permitting program Establish biological end points for management Improve monitoring for Phase I MS4s Add monitoring for Phase II MS4s REPORT HIGHLIGHTS: Management Approaches Establish numeric municipal action levels (MEP as a number) Regulate product sale and usage Use effluent limits (loads or concentrations) Impose imperviousness limits Impose turbidity limit for construction sites Issue guidance on identifying high-risk industrial facilities Provide more resources and funding Expand use of TMDLs (non-impaired waters) Regulate flow 10
REPORT HIGHLIGHTS: Key Conclusion in its current configuration, EPAs approach seems inadequate to overcome the unique challenges of stormwater and therefore runs the risk of being only partly effective in meeting its goals. 11
Fox, Andrea. 2009. Water Environment & Technology, Water Environment Federation, Alexandria, Virginia, February. NATIONAL ASSOCIATION OF FLOODPLAIN AND STORMWATER MANAGEMENT AGENCIES Developing formal response comments to NRC and EPA Draft document is 36 pages long Includes Supported Items Increased funding and guidance and support WQBELs not appropriate for stormwater Origins of MEP TMDL program is a poor tool Tiered uses Stormwater management is challenging National source control and product regulation Items of Concern Missed Opportunities 12
NATIONAL ASSOCIATION OF FLOODPLAIN AND STORMWATER MANAGEMENT AGENCIES Developing formal response comments to NRC and EPA Draft document is 36 pages long Includes discussion of: Supported items Items of concern Missed items Key concerns: No MS4 operators on author panel Legality of flow and impervious cover regulation Program costs and no recognition of competing programs Replacement of MEP with numeric concepts Ignores political realities while calling for watershed cooperation Integrated permits unworkable (wastewater and stormwater) Monitoring costs EPA RESPONSE EPA identified key report recommendations for response action: Permitting approaches Flow rate (volume) controls Expressions of maximum extent practicable standard Monitoring methods and requirements Industrial permitting Pollutant source reduction (product regulation) Process: Office of Water Action Plan Review report Form cross-office team of reviewers and proposals Get stakeholder input Request comments in Federal Register Develop action plan for stormwater permitting 13
POTENTIAL IMPACTS TO PERMIT HOLDERS IF EPA IMPLEMENTS RECOMMENDATIONS Combined wastewater and stormwater permits issued Larger MS4s coordinate and manage smaller MS4s Smaller MS4s follow lead permittee instructions Additional MS4s added Biological end points (and monitoring) added Numeric municipal action levels added Imperviousness limits and flow regulation added for new development Turbidity limits added construction sites Identifying high-risk industrial facilities added Received more resources and funding TMDLs expanded to non-impaired waters WHAT SHOULD I DO NOW? Buy the book Read the book Obtain industry group comments (if available) NAFSMA, WEF, APWA, NLC, etc. Prepare comments on the report Submit formally in response to EPAs Federal Register request (when it is published) Assess specific impacts to your MS4 Talk to your neighbors about watershed permitting Talk to your state to find out what they think Hold on tight 14
SUMMARY National Research Council Why was the Report prepared? Who prepared the Report? What does the Report say? What do others think about it? What is EPA doing in response? What impacts are likely? What should I do now? ORDERING INFORMATION ORDER ON-LINE FROM NATIONAL ACADEMIES PRESS: http://www.nap.edu/catalog.php?record_id=12465 Paperback: $47.70 PDF Download: $5.60 Both: $62.50 Michael F. Bloom, PE, CFM, BCEE Senior Associate 1250 Wood Branch Park Drive, Suite 300 Houston, TX 77079 281-529-4202 mfbloom@pbsj.com 15

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NRC\'s Urban Stormwater Management in the United States: Implications for MS4 Permi Holders

  • 1. 11th Annual EPA Region 6 MS4 Operators Conference, Houston, TX June 25, 2009 The National Research Councils Urban Stormwater Management in the United States: Implications for MS4 Permit Holders Presented by MICHAEL F. BLOOM, P.E., CFM Senior Associate TOPICS National Research Council Why was the Report prepared? Who prepared the Report? What does the Report say? What do others think about it? What is EPA doing in response? What impacts are likely? What should I do now? 1
  • 2. NATIONAL RESEARCH COUNCIL National Academy of Sciences created in 1863 Private, nonprofit, society of scholars Dedicated to further use of science and technology for general welfare NRC organized in 1916 NRC furthers knowledge and advises the federal government Governed jointly by Institute of Medicine and NAS See www.national-academies.org WHY WAS REPORT PREPARED? [EPA Requested It] Clarify the mechanisms by which pollutants in stormwater discharges affect ambient water quality criteria and define the elements of a protocol to link pollutants in stormwater discharges to ambient water quality criteria. Consider how useful monitoring is for both determining the potential of a discharge to contribute to a water quality standards violation and for determining the adequacy of stormwater pollution prevention plans. What specific parameters should be monitored and when and where? What effluent limits and benchmarks are needed to ensure that the discharge does not cause or contribute to a water quality standards violation? Assess and evaluate the relationship between different levels of stormwater pollution prevention plan implementation and in-stream water quality, considering a broad suite of stormwater control measures (SCMs). 2
  • 3. WHY WAS REPORT PREPARED? [EPA Requested It] Make recommendations for how to best stipulate provisions in stormwater permits to ensure that discharges will not cause or contribute to exceedances of water quality standards. This should be done in the context of general permits. As a part of this task, the committee will consider currently available information on permit and program compliance. Assess the design of the stormwater permitting program implemented under the Clean Water Act. AUTHORS 3
  • 4. OVERSIGHT BOARD INPUT RECEIVED FROM STAKEHOLDERS & REVIEWERS City of Austin Heal the Bay King County, WA California Stormwater Quality City of Seattle Association Irvine Ranch Water District Southern California Coastal City of Philadelphia Water Research Project Vermont Department of Southern California Monitoring Environmental Conservation Coalition University of Texas Natural Resources Defense UNC Institute of Marine Council Sciences Geosyntec UCLA Clean Water Services, OR University of Washington Florida Gulf Coast University California Water Board University of Florida City of Los Angeles University of Georgia Michigan State University Minnesota Pollution Control CH2M Hill Agency University of Maryland 4
  • 5. REPORT TABLE OF CONTENTS REPORT TABLE OF CONTENTS 5
  • 6. REPORT TABLE OF CONTENTS REPORT HIGHLIGHTS: Challenges Regulatory history Administrative and financial burdens 6
  • 7. REPORT HIGHLIGHTS: Stormwater Impacts Urbanization is bad for aquatic life REPORT HIGHLIGHTS: Literature Review Excellent references Important conclusions reported and summarized Includes information about: Hydrology MS4 representative monitoring Atmospheric deposition Building materials as a source Urbanization impacts Land use changes Geomorphology Biological responses to urbanization 7
  • 8. REPORT HIGHLIGHTS: Stormwater Impacts Urbanization leads to habitat loss 8
  • 9. REPORT HIGHLIGHTS: Monitoring Stormwater MS4 runoff well characterized (see Pitts National Stormwater Quality Database) Industrial monitoring should be risk-based and improved Use continuous, flow-weighted sampling rather than grab sampling Obtain flow and rainfall data Use biological monitoring Obtain statistically valid number of samples REPORT HIGHLIGHTS: Management Approaches BMPs renamed: Stormwater Control Measures (SCMs) Summary of SCMs Impervious cover reductions Rainwater harvesting Swales Silt fences Bio-infiltration 9
  • 10. REPORT HIGHLIGHTS: Management Approaches Use watershed-based permitting for all sources (wastewater and stormwater) Issue integrated permits by watershed Create lead permittee in each watershed (delegation) Use residual designation authority to bring more urbanized areas into the permitting program Establish biological end points for management Improve monitoring for Phase I MS4s Add monitoring for Phase II MS4s REPORT HIGHLIGHTS: Management Approaches Establish numeric municipal action levels (MEP as a number) Regulate product sale and usage Use effluent limits (loads or concentrations) Impose imperviousness limits Impose turbidity limit for construction sites Issue guidance on identifying high-risk industrial facilities Provide more resources and funding Expand use of TMDLs (non-impaired waters) Regulate flow 10
  • 11. REPORT HIGHLIGHTS: Key Conclusion in its current configuration, EPAs approach seems inadequate to overcome the unique challenges of stormwater and therefore runs the risk of being only partly effective in meeting its goals. 11
  • 12. Fox, Andrea. 2009. Water Environment & Technology, Water Environment Federation, Alexandria, Virginia, February. NATIONAL ASSOCIATION OF FLOODPLAIN AND STORMWATER MANAGEMENT AGENCIES Developing formal response comments to NRC and EPA Draft document is 36 pages long Includes Supported Items Increased funding and guidance and support WQBELs not appropriate for stormwater Origins of MEP TMDL program is a poor tool Tiered uses Stormwater management is challenging National source control and product regulation Items of Concern Missed Opportunities 12
  • 13. NATIONAL ASSOCIATION OF FLOODPLAIN AND STORMWATER MANAGEMENT AGENCIES Developing formal response comments to NRC and EPA Draft document is 36 pages long Includes discussion of: Supported items Items of concern Missed items Key concerns: No MS4 operators on author panel Legality of flow and impervious cover regulation Program costs and no recognition of competing programs Replacement of MEP with numeric concepts Ignores political realities while calling for watershed cooperation Integrated permits unworkable (wastewater and stormwater) Monitoring costs EPA RESPONSE EPA identified key report recommendations for response action: Permitting approaches Flow rate (volume) controls Expressions of maximum extent practicable standard Monitoring methods and requirements Industrial permitting Pollutant source reduction (product regulation) Process: Office of Water Action Plan Review report Form cross-office team of reviewers and proposals Get stakeholder input Request comments in Federal Register Develop action plan for stormwater permitting 13
  • 14. POTENTIAL IMPACTS TO PERMIT HOLDERS IF EPA IMPLEMENTS RECOMMENDATIONS Combined wastewater and stormwater permits issued Larger MS4s coordinate and manage smaller MS4s Smaller MS4s follow lead permittee instructions Additional MS4s added Biological end points (and monitoring) added Numeric municipal action levels added Imperviousness limits and flow regulation added for new development Turbidity limits added construction sites Identifying high-risk industrial facilities added Received more resources and funding TMDLs expanded to non-impaired waters WHAT SHOULD I DO NOW? Buy the book Read the book Obtain industry group comments (if available) NAFSMA, WEF, APWA, NLC, etc. Prepare comments on the report Submit formally in response to EPAs Federal Register request (when it is published) Assess specific impacts to your MS4 Talk to your neighbors about watershed permitting Talk to your state to find out what they think Hold on tight 14
  • 15. SUMMARY National Research Council Why was the Report prepared? Who prepared the Report? What does the Report say? What do others think about it? What is EPA doing in response? What impacts are likely? What should I do now? ORDERING INFORMATION ORDER ON-LINE FROM NATIONAL ACADEMIES PRESS: http://www.nap.edu/catalog.php?record_id=12465 Paperback: $47.70 PDF Download: $5.60 Both: $62.50 Michael F. Bloom, PE, CFM, BCEE Senior Associate 1250 Wood Branch Park Drive, Suite 300 Houston, TX 77079 281-529-4202 mfbloom@pbsj.com 15