MassDEP agrees to co-issuance of new MS4 stormwater permit with EPA

MassDEPDespite serious concerns over costs to municipalities and timing of implementation, MassDEP has agreed to co-issue the new MS4 stormwater permit with EPA. According to a March 31, 2016 letter from MassDEP Commissioner Martin Suuberg to US EPA Region 1 Administrator Curt Spalding, MassDEP agreed to co-issue the permit in spite of concerns in order to remain involved with cities and towns on permit implementation. The letter states, “MassDEP would have preferred some time for additional discussion of important issues. Nevertheless, MassDEP needs to be involved with EPA and cities and towns on how this permit is implemented. This is too important an issue for our environment, for our cities and towns and for the Commonwealth.”

The letter further stated that EPA had not addressed all comments previously submitted by MassDEP, and that the proposed permit would present significant hurdles to municipalities. The complete letter can be read here.

EPA Provides New England with over $165 Million for Water Infrastructure Projects

606px-Environmental_Protection_Agency_logo.svgThe U.S. Environmental Protection Agency (EPA) has awarded funds to all six New England states to help finance improvements to water projects that are essential to protecting public health and the environment. The funds will be primarily used to upgrade sewage plants and drinking water systems, as well as replacing aging infrastructure, throughout the state. Awards were made to the Clean Water State Revolving Fund (CWSRF) program in each state, which provides low-interest loans for water quality protection projects to make improvements to wastewater treatment systems, control pollution from stormwater runoff, and protect sensitive water bodies and estuaries; and to the Drinking Water State Revolving Fund (DWSRF) program in each state, which provides low-interest loans to finance improvements to drinking water systems, with a particular focus on providing funds to small and disadvantaged communities and to programs that encourage pollution prevention as a tool for ensuring safe drinking water.

The awards are as follows:

  • Connecticut: $26 million — $17.1 million CWSRF, $8.9 million DWSRF
  • Maine: $19.6 million — $10.8 million CWSRF, $8.8 million DWSRF
  • Massachusetts: $63.7 million — $47.4 million CWSRF, $16.3 million DWSRF
  • New Hampshire: $22.7 million — $13.9 million CWSRF, $8.8 million DWSRF
  • Rhode Island: $18.2 million — $9.4 million CWSRF, $8.8 million DWSRF
  • Vermont: $15.6 million — $6.8 million CWSRF, $8.8 million DWSRF

Since the beginning of this program, EPA has awarded approximately $4.554 billion to New England states for the construction, expansion, and upgrading of clean water infrastructure resulting in decreased pollution entering waterbodies throughout the state.

As communities develop and climate patterns shift, water infrastructure needs are expected to grow. Green infrastructure is a cost-effective and resilient approach to water infrastructure needs that provides benefits to communities across the nation.

Drugs in Drinking Water

Prescription_pills_spillingPharmaceuticals (prescription, over-the-counter, and veterinary drugs) and personal care products (products such as cleansers, fragrances, and cosmetics used for personal reasons) in drinking water have been a subject of much concern recently. Studies have shown that a myriad of pharmaceuticals including antibiotics, anabolic steroids, anti-anxiety medications, hormones, and anti-seizure medications have been found in the drinking water supplies of at least 41 million Americans in 24 major metropolitan areas, from east coast to west coast. And while these numbers alone are alarming, they represent only a very small portion of the problem.

In addition to pharmaceuticals and personal care products (PPCPs), studies have found that illicit drugs are also in our drinking water. Drugs detected include cocaine, MDMA (ecstasy), opioids, cannabinoids, and amphetamines, which have been found in sewage wastewaters, sewage sludge, surface waters, and drinking water. All of these drugs have potent pharmacological activities, and it is therefore generally believed that they have adverse effects on human health and the environment, including aquatic organisms.

How did they get there?

DrinkingWaterSupplyArea_bluesign1People take drugs, and their bodies absorb only a portion of what they ingest. The rest is excreted and flushed down the toilet, where it makes its way to wastewater treatment facilities. The wastewater undergoes a treatment process to remove nutrients and bacteria before it is discharged back into surface waters, including reservoirs, lakes, and streams, which in turn feed municipal water treatment plants for distribution. And there are no treatment processes specifically engineered to remove pharmaceuticals or drugs from wastewater. Even more alarming, many widely prescribed medications such as anti-epileptic medications, tranquilizers, and cholesterol fighters actually resist most existing treatment processes, save two. Reverse osmosis, a treatment technology which forces water through a membrane filter, successfully removes all pharmaceuticals, but is prohibitively expensive for large-scale use and wastes several gallons of polluted water for each one made drinkable. Activated charcoal, which filters organic matter and drugs from wastewater, is a better treatment option because it doesn’t waste water like reverse osmosis does. Unfortunately, it is still extremely expensive to install.

There is no way to determine the effects of drugs in drinking water because there is no regulation over the presence of most drugs, illicit or otherwise, in treated wastewater, surface water, or drinking water. Also, there are no studies that monitor the long-term effects of low-dose drugs on human health. However, given the very nature of pharmaceuticals — they are meant to be active in small doses — it is highly likely that their presence in our nation’s water supply is not without effect. “These are chemicals that are designed to have very specific effects at very low concentrations. That’s what pharmaceuticals do. So when they get out to the environment, it should not be a shock to people that they have effects,” noted zoologist John Sumpter of Brunel University in London.

The methadone problem

MethadoneThere is, however, one drug that is definitively known to be extremely problematic: methadone. Used in the treatment of our nation’s epidemic heroin problem as well as for chronic pain disorders, methadone is prescribed over four million times annually — and that number is rising. Approximately 28% of ingested methadone is not absorbed by the body but is instead excreted in urine, ending up in our wastewater. A common chemical used in water  treatment is chloramine (not to be confused with chlorine). In fact, nearly a quarter of the U.S. population drinks water treated with chloramine disinfectants. Methadone reacts with chloramine to form N-nitrosodimethylamine, or “NDMA” for short, which the World Health Organization has labeled “clearly carcinogenic” because of its ability to cause stomach, liver, and colon cancer after being ingested.

“NDMA is a very potent carcinogen,” commented environmental chemist Susan Richardson of the University of South Carolina. “It’s being commonly found in drinking water well above the health reference level for cancer, and the U.S. Environmental Protection Agency is currently deciding whether to regulate it.”

Considering half of the drinking water samples obtained by an AP study were found to contain a level of NDMA that would be considered dangerous, it is no surprise that Massachusetts and California have already implemented regulations concerning NDMA, although they are the only two states in the nation to do so. In contrast, all of Canada has regulations in place fully banning NDMA. In the U.S., the decision might not be imminently forthcoming, as drugs in drinking water presents a unique challenge. The Food and Drug Administration (FDA) oversees drugs, while the U.S. Environmental Protection Agency (EPA) oversees environmental issues, so collaboration — and agreement — between the two organizations is necessary.

In conclusion

It seems unlikely that doctors will start prescribing fewer medications or that our nation’s illicit drug problem will cease to exist. Therefore, it is imperative that research is conducted and regulations put in place to protect the public from the health hazards caused by drugs in drinking water. Of course, with these regulations will come the need for improved infrastructure to comply, which in turn will require funding for already financially strained water and wastewater utilities. There is no easy answer. But one thing is certain: drugs in drinking water is an urgent national problem that needs to be promptly addressed.

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Associated Press

EPA issues 2015 MSGP for industrial stormwater discharge

Photo by Roger Winstead
Photo by Roger Winstead

On June 4, 2015, the United States Environmental Protection Agency (EPA) issued a revised NPDES Multi-Sector General Permit (MSGP) for industrial stormwater discharges. The 2015 MSGP replaces the 2008 MSGP.

While the 2015 MSGP provisions are largely similar to the 2008 MSGP, EPA has made some changes to streamline the permit, enhance environmental protections, and improve clarity. The most significant changes are as follows:

  • Revised threatened and endangered species eligibility procedures.
  • Additional specificity for several of the technology-based effluent limits (i.e., control measures) for clarity.
  • A requirement that facilities discharging to a small number of federal Superfund sites notify their EPA regional office prior to filing their Notice of Intent (NOI).
  • Streamlining of Stormwater Pollution Prevention Plan (SWPPP) documentation (i.e., facilities do not have to expound on their compliance with certain effluent limits).
  • Public accessibility to SWPPP information, either by posting on the internet or by incorporating salient information into the NOI.
  • Electronic submission for the NOI, Notice of Termination, annual report, and monitoring.
  • Reduced requirements for inspections (i.e., facilities no longer have to conduct a separate comprehensive site inspection).
  • Specific deadlines for taking corrective actions.
  • Inclusion of saltwater benchmark values for metals.
  • Inclusion of the Airport Deicing Effluent Limitation Guideline for the air transportation sector.

EPA’s MSGP applies in areas of the country where EPA remains the NPDES permitting authority and has made the permit available for coverage, which includes the following:

  • Four states: Idaho, Massachusetts, New Hampshire and New Mexico;
  • The District of Columbia;
  • All U.S. territories except for the Virgin Islands;
  • Federally operated facilities in Colorado, Delaware, Vermont and Washington;
  • Most Indian Country lands; and
  • Various other designated activities in specific states.

For additional information on the 2015 MSGP, visit EPA’s website here.

For additional questions, or if you need assistance with the 2015 MSGP, please contact us.

EPA announces 2015 MSGP available soon, advises preparation

Photo by Roger Winstead
Photo by Roger Winstead

On May 27, 2015, the EPA announced that the new Multi-Sector General Permit (MSGP), originally proposed in 2013 and referred to as the 2015 MSGP, will be available soon for operators seeking permit coverage to discharge stormwater associated with industrial activity. Filing to renew coverage under the 2015 MSGP must be done electronically using EPA’s new NPDES eReporting Tool (NeT), and, once covered by the new permit, all monitoring data will be submitted electronically using NetDMR.

To prepare for the new 2015 MSGP, EPA recommends taking the following steps:

  1. Visit EPA’s MSGP webpage (https://water.epa.gov/polwaste/npdes/stormwater/EPA-Multi-Sector-General-Permit-MSGP.cfm) to learn about the status of the 2015 MSGP, your eligibility, NeT and NetDMR training, and to obtain guidance on complying with the new permit.
  2. Determine if your facility qualifies for a conditional “no exposure” permit exclusion.
  3. Review your Notice of Intent (“NOI”) submitted for coverge under the 2008 MSGP for information that will help you file a new NOI for the 2015 MSGP.
  4. Discuss internally who will prepare and certify the documents submitted through the NeT and NetDMR tools for your facility.
  5. Review your existing Stormwater Pollution Prevention Plan (SWPPP) to identify the revisions necessary to make it current and consistent with the 2015 MSGP requirements. Your SWPPP must be prepared and ready to implement prior to filing an NOI for the 2015 MSGP.

If you need assistance with your 2015 MSGP, please contact us at contact@tataandhoward.com or 800-366-5760.

White House finalizes Clean Water Act rule

clean water infographic
An infographic created by the EPA aims to clarify the rule

On May 27, 2015, the White House finalized the EPA’s “Waters of the United States” rule amid both praise and protest. According to the EPA, the rule is intended to strengthen the Clean Water Act by clarifying which bodies of water fall under the control of the Clean Water Act of 1972.

Gina McCarthy, Administrator of the U.S. EPA, praised the rule by saying, “The Clean Water Act has protected our health for more than 40 years – and helped our nation clean up hundreds of thousands of miles of polluted waterways…Using the latest science, this rule clears up the confusion, providing greater certainty for the first time in more than a decade about which waters are important to protect.”

And White House Senior Advisor Brian Deese, who announced the rule with EPA and Army Corps officials, had very strong words in favor of the rule: “There is a lot of misinformation about what this rule does and doesn’t do. But what becomes clear…is that the only people with reason to oppose the rule are polluters who knowingly threaten our clean water.”

However, the rule does have some strong opposition. Republicans and developers, along with the agricultural and oil industries, have vehemently opposed the ruling since its initial draft, saying that it is a massive power grab by Washington.

“The administration’s cavalier attitude toward expanding the federal government’s authority into our backyards is absolutely outrageous,” said Sen. David Vitter (R-La.) in a statement. “Not only were small businesses – who will be dramatically impacted by expanding of the definition of ‘waters of the United States’ – inappropriately excluded from the rule-making process, but the federal government shouldn’t be regulating puddles on private property in the first place.”

Although this is a final rule, there is legislation to block it that has passed the House and is waiting in the Senate.

Effective Water and Wastewater Utility Management

A water main break is a common occurrence with our nation’s failing infrastructure

As water and wastewater utilities nationwide face an increasing number of challenges, including rising costs and population, aging infrastructure, drought, increasingly stringent regulatory requirements, and a rapidly changing workforce, creative and innovative methodologies for treatment and distribution along with efficient and effective utility management have become paramount. In order to ensure a strong and viable utility for future generations, utilities must find ways to improve their products and services while increasing community support. Effective water and wastewater utility management helps utilities improve performance in critical areas while responding to current and future challenges, all with limited infrastructure dollars.

In May of 2007, six major water and wastewater associations and the U.S. Environmental Protection Agency signed an historic agreement pledging to support effective utility management collectively and individually throughout the water sector and to develop a joint strategy to identify, encourage, and recognize excellence in water and wastewater utility management. Participating organizations included the following:

  • Association of Metropolitan Water Agencies (AMWA)
  • American Public Works Association (APWA)
  • American Water Works Association (AWWA)
  • National Association of Clean Water Agencies (NACWA)
  • National Association of Water Companies (NAWC)
  • United States Environmental Protection Agency (EPA)
  • Water Environment Federation (WEF)

The result of this powerhouse collaboration was the Effective Utility Management Primer, issued in June of 2008. The Primer, designed specifically to assist water and wastewater managers in identifying and addressing their most urgent needs through a customized, incremental approach, outlines ten attributes of effectively managed utilities along with five keys to management success:

Ten Attributes of Effectively Managed Water Sector Utilities

  1. Effective Utility Management: A Primer for Water and WastewaterProduct Quality produces potable water, treated effluent, and process residuals in full compliance with regulatory and reliability requirements and consistent with customer, public health, and ecological needs.
  2. Customer Satisfaction provides reliable, responsive, and affordable services in line with explicit, customer- accepted service levels. Receives timely customer feedback to maintain responsiveness to customer needs and emergencies.
  3. Employee and Leadership Development recruits and retains a workforce that is competent, motivated, adaptive, and safe-working. Establishes a participatory, collaborative organization dedicated to continual learning and improvement. Ensures employee institutional knowledge is retained and improved upon over time. Provides a focus on and emphasizes opportunities for professional and leadership development and strives to create an integrated and well-coordinated senior leadership team.
  4. Operational Optimization ensures ongoing, timely, cost-effective, reliable, and sustainable performance improvements in all facets of its operations. Minimizes resource use, loss, and impacts from day-to-day operations. Maintains awareness of information and operational technology developments to anticipate and support timely adoption of improvements.
  5. Financial Viability understands the full life-cycle cost of the utility and establishes and maintains an effective balance between long-term debt, asset values, operations and maintenance expenditures, and operating revenues. Establishes predictable rates—consistent with community expectations and acceptability—adequate to recover costs, provide for reserves, maintain support from bond rating agencies, and plan and invest for future needs.
  6. Infrastructure Stability understands the condition of and costs associated with critical infrastructure assets. Maintains and enhances the condition of all assets over the long-term at the lowest possible life-cycle cost and acceptable risk consistent with customer, community, and regulator-supported service levels, and consistent with anticipated growth and system reliability goals. Assures asset repair, rehabilitation, and replacement efforts are coordinated within the community to minimize disruptions and other negative consequences.
  7. Operational Resiliency ensures utility leadership and staff work together to anticipate and avoid problems. Proactively identifies, assesses, establishes tolerance levels for, and effectively manages a full range of business risks (including legal, regulatory, financial, environmental, safety, security, and natural disaster-related) in a proactive way consistent with industry trends and system reliability goals.
  8. Community Sustainability is explicitly cognizant of and attentive to the impacts its decisions have on current and long-term future community and watershed health and welfare. Manages operations, infrastructure, and investments to protect, restore, and enhance the natural environment; efficiently uses water and energy resources; promotes economic vitality; and engenders overall community improvement. Explicitly considers a variety of pollution prevention, watershed, and source water protection approaches as part of an overall strategy to maintain and enhance ecological and community sustainability.
  9. Water Resource Adequacy ensures water availability consistent with current and future customer needs through long-term resource supply and demand analysis, conservation, and public education. Explicitly considers its role in water availability and manages operations to provide for long-term aquifer and surface water sustainability and replenishment.
  10. Stakeholder Understanding and Support engenders understanding and support from oversight bodies, community and watershed interests, and regulatory bodies for service levels, rate structures, operating budgets, capital improvement programs, and risk management decisions. Actively involves stakeholders in the decisions that will affect them.

Five Keys to Management Success

  1. water_utility_leadershipLeadership
    Leadership is critical to effective utility management, particularly in the context of driving and inspiring change within an organization. Leadership refers both to individuals who can be effective champions for improvement, and to teams that provide resilient, day-to-day management continuity and direction. Effective leadership ensures that the utility’s direction is understood, embraced, and followed on an ongoing basis throughout the management cycle.
  2. Strategic Business Planning
    Strategic business planning is an important tool for achieving balance and cohesion across the Attributes. A strategic plan provides a framework for decision making by assessing current conditions, strengths and weaknesses; assessing underlying causes and effects; and establishing vision, objectives, and strategies. It establishes specific implementation steps that will move a utility from its current level of performance to achieving its vision.
  3. Organizational Approaches
    There are a variety of organizational approaches that contribute to overall effective utility management and that are critical to the success of management improvement efforts, including actively engaging employees in improvement efforts; deploying an explicit change management process that anticipates and plans for change and encourages staff at all levels to embrace change; and utilizing implementation strategies that seek, identify, and celebrate victories.
  4. Measurement
    Measurement is critical to management improvement efforts and is the backbone of successful continual improvement management and strategic business planning. A measurement system serves many vital purposes, including focusing attention on key issues, clarifying expectations, facilitating decision making, and, most importantly, learning and improving.
  5. Continual Improvement Management Framework
    A continual improvement management framework can help utilities understand improvement opportunities and establish explicit service levels, guide investment and operational decisions, form the basis for ongoing measurement, and provide the ability to communicate clearly with customers and key stakeholders. This framework plays a central role in effective utility management and is critical to making progress.

OK – Now What?

business_overwhelmedSo how does a utility assess, address, and implement these changes? The primer further recommended an assessment tool with five steps, for which the instructions comprise the latter 35 pages of the Effective Utility Management Primer. Admittedly, the entire process requires dedicated time and personnel commitment from the utility. While some utility managers have had success in applying the assessment to their utility, many have found the process to require resources simply unavailable to them. Tata & Howard has developed two proprietary innovations that assist water and wastewater utilities in the identification of their most urgent needs as well as effective and efficient utility management.

Business Practice Evaluations

Business Practice Evaluations (BPEs) assess the health of a utility’s work practices by implementing a framework for a structured approach to managing, operating, and maintaining in a more business-like manner. This assessment provides the information and planning required by the Primer, specifically in the Five Keys to Management Success. A BPE’s primary focus is on effective management.

The overall goal of the assessment process is more efficient and effective work practices, and the assessment process and tools developed enable utility managers to assess the efficiency and effectiveness of the utility in comparison to generally accepted industry standards. The assessment includes documentation of current business practices, identification of opportunities for improvement, conducting interviews including a diagonal slice of the organization, and observation of work practices in the field. From this assessment we make recommendations to improve system performance, and the structured approach is fully customized and includes all functions of the utility — from administration and technical to operations and maintenance. The assessment process allows utility executives to proactively develop system specific plans, programs, and timelines to optimize the overall utility system programs.

Capital Efficiency Plans™

capitalWhere BPEs focus on management, Capital Efficiency Plans™ (CEPs) address the utility itself, combining the concepts of hydraulic modeling, system criticality, and asset management into a single comprehensive report. Each report is customized to the individual utility system and provides utilities with a database and Geographic Information System (GIS) representation for each pipe segment within their underground piping system. The CEP report also prioritizes system piping improvements and provides estimated costs for replacement and rehabilitation.

Each water and wastewater system has unique characteristics and challenges that are discussed at our CEP workshop held with knowledgeable field staff and managers for each project. The workshops provide significant value by filling in data gaps, correcting incorrect records, and identifying specific issues and critical components that are custom to the system. Our completed studies have been well received by many utilities who have found our methodology not only practical and understandable, but also defendable when justifying projects and procuring funding.

In Conclusion

Water and wastewater utilities today are finding themselves increasingly burdened with decreased revenue, excessive demand, and crumbling infrastrucure. Strict new regulations and a changing workforce have also added to the challenge, and it is imperative that water and wastewater utilities find ways to efficiently and effectively improve systems while implementing successful management strategies. Targeted assessments, strategic planning, and identification and implementation of best practices will be the foundation of all successful utilities in the future.

Groundwater Awareness and Protection

An Introduction to Groundwater

Groundwater is an abundant and renewable natural resource comprised of the water that soaks into the earth from precipitation. This water moves downward to seep into cracks, crevices, and other openings in rock beds and sand. Groundwater makes up 95% of the world\’s freshwater, with surface water (lakes, rivers, and streams) making up only three percent of all freshwater. To put it into perspective, hydrologists estimate there are currently over 33,000 trillion gallons of groundwater in reserve in the U.S. – which is 20 to 30 times greater than the total amount of water in all of the lakes, streams, and rivers of the U.S.

Why It’s Important

hydrologic cycleGroundwater is an integral part of the hydrologic cycle, which includes all the water of the Earth including the atmosphere, oceans, surface water, and groundwater. The system is cyclical in that water repeatedly moves through all of these elements. In addition, the United States Geological Survey (USGS) estimates that 25% of all U.S. rainfall becomes groundwater, and that 30% of U.S. stream flow originates from groundwater.

The U.S. uses about 80 billion gallons of fresh groundwater every day for public and private drinking water, irrigation, livestock, manufacturing, mining, and thermoelectric power. Over 40% of the nation’s population depends on groundwater for their drinking water supply, with private household wells comprising the largest percentage of all wells in the nation. Over 13 million households depend on private well water.

The Ogallala Aquifer

The largest use of groundwater in the U.S. is irrigation. Over 50 billion gallons of groundwater are used per day for agricultural purposes, up from just over 2 billion gallons per day in 1900. The nation’s largest aquifer is the Ogallala, which runs beneath 250,000 square miles stretching from Texas to South Dakota, and 90% of the water pumped from the Ogallala is used for agricultural irrigation. This massive and plentiful aquifer accounts for one-third of all U.S. irrigated agriculture, and creates about $20 billion in food and fiber annually. If the waters of the Ogallala were spread across the surface of the U.S., all 50 states would be covered with 1.5 feet of water. Yet, even though groundwater is plentiful and renewable, it still needs to be respected. Scientists estimate that if the Ogallala were fully withdrawn, it would take a whopping 6,000 years to refill it naturally. So we all need to take steps to conserve the groundwater – indeed, all water – that we have.

Best Conservation Practices

In the Home

  • Turn the faucet off when the water isn’t being used, such as while brushing your teeth or doing dishes.
  • Don’t pour fresh, unused water down the drain; use it to water plants or to fill a humidifier.
  • Install aerators with flow restrictors on household faucets.
  • When upgrading, choose water- and energy-efficient appliances, such as low-flow toilets and front-load washing machines.
  • Always repair a dripping faucet or leaking toilet; one wasted drop per second adds up to 2,700 gallons per year!
  • Only run a fully loaded dishwasher or washing machine, or set the water level to match the load size.
In an effort to save water, some golf courses, such as this one in Syracuse, NY, are allowing their signature lush green lawns to go brown. Dennis Nett/The Post-Standard/Landov
In an effort to save water, some golf courses, such as this one in Syracuse, NY, are allowing their signature lush green lawns to go brown.
Dennis Nett/The Post-Standard/Landov

In the Yard

  • Raise the mower blade to the highest level to allow your lawn to retain its moisture and to strengthen the root system.
  • Plant native, drought-resistant grasses, shrubs, and trees.
  • Don’t overwater your lawn. Heavy rain eliminates the need to water for up to two weeks, and a bright green lawn is truly overrated. As they say in California, where the drought has reached a critical state, “Brown is the New Green.” A lawn that isn’t perfectly and uniformly dark green indicates a future-minded, caring, and responsible resident.

Groundwater is clearly an extremely important natural resource, and one that deserves our care. Stay tuned later this week as we showcase a Cape Cod aquifer, its uses, safety, sustainability, and protection.

For more information on groundwater, visit https://water.epa.gov/type/groundwater/index.cfm.

For fun and educational kids’ activities, please visit https://water.epa.gov/learn/kids/drinkingwater/index.cfm

Green Changes Ahead in Stormwater Management

An enhanced tree pit helps mitigate runoff. Photo courtesy of NYC Environmental Protection.
An enhanced tree pit helps mitigate runoff. Photo courtesy of NYC Environmental Protection.

EPA looks to incorporate green infrastructure into new stormwater regulations in 2014

Spring 2014 will likely see the long-overdue proposed national stormwater regulation from the EPA. In addition to anticipated changes such as stronger reporting requirements, publicized Stormwater Pollution Prevention Plans (SWPPP), and clarified corrective action conduct, the EPA aims to integrate green practices and infrastructure into stormwater initiatives. These initiatives will have positive impact to both the environment and the economy.

Impact of Stormwater

Urban stormwater is a leading source of impairment, and its impact to water quality is growing. Currently, 800,000 acres are being developed annually, and that number is expected to grow to over one million acres by 2040. Development increases impervious cover, and even the smallest increase in impervious cover causes major impact to water reception. In addition, upstream development directly affects downstream waters, and many communities already have waterbodies that have been polluted by stormwater discharge. Clearly, innovative and effective stormwater management practices are imperative to the health of our nation’s waters.

Changing the Way We Approach Stormwater Management

Traditional stormwater management strategies involve the swift conveyance of stormwater from site to waterbody or detention ponds, and the management of peak flows and drainage to mitigate flooding and large-scale downstream erosion. The new approach to stormwater will be to manage municipal stormwater discharges on a watershed basis, particularly MS4 communities, and to integrate green infrastructure into project design during development or redevelopment. This green approach will provide the most cost-effective opportunity to manage stormwater at its source by preventing water quality degradation in healthy waters and helping to restore already impaired waters.

The EPA is considering a number of performance standards for the upcoming proposed ruling, including a retention-based standard to require that sustainable stormwater controls be incorporated into sites as they are developed and redeveloped, thereby reducing volume and velocity of discharges as well as pollutants. The EPA has made it clear that there are indeed cost-effective ways of meeting the standard, including incorporating controls in the site design by preserving vegetation and reducing impervious cover, and integrating green infrastructure practices into landscape or other common areas. The ruling will contain some flexibility, taking into consideration an area\’s climate and other location-specific characteristics as well as redevelopment site constraints and phased implementation. In addition, there may be additional incentives for smart growth and brownfields development.

A porous concrete sidewalk filters rain back into the ground instead of the sewer system. Photo courtesy of NYC Environmental Protection.
A porous concrete sidewalk filters rain back into the ground instead of the sewer system. Photo courtesy of NYC Environmental Protection.

Benefits of a Proposed Stormwater Rule

  • Improved recreational, aesthetic and non-use values
  • Lower drinking water treatment costs
  • Lower dredging costs for navigational channels
  • Reduced siltation of water storage reservoirs
  • Reduced downstream flooding damage
  • Groundwater recharge
  • Small stream erosion and water quality impacts

Vegetation

  • Improved air quality and reduced human health impacts
  • Higher off-site property values associated with green infrastructure
  • Carbon uptake by plants
  • Reduced energy use by buildings and associated air quality
  • Carbon footprint benefits

Community

  • Reduced flooding
  • More livable communities
  • Increased property values
  • Avoidance of extremely high costs of water restoration

UF winners copy

Students at the University of Florida won the EPA\’s 2012 Campus RainWorks Challenge with this green infrastructure design. Read about it in detail here.

In Conclusion

It is imperative that we protect our nation’s most precious resource, and stormwater management is a crucial facet of that goal. The expected spring 2014 EPA stormwater rulings will likely bring significant green infrastructure initiatives, and not a moment too soon. Green infrastructure will serve as an impetus for the critical and cost-effective protection of our water supply with the added benefit of enhancing the world in which we all live.

EPA Backs Away from Lead-free Hydrants Rule

MELISSA DANIELS
THE PITTSBURGH TRIBUNE-REVIEW

Facing oppoposition from fire and water officials, the EPA is backing down on the need for lead-free fire hydrants.

hydrantThe Environmental Protection Agency is backing down from an effort that urges municipalities to install lead-free fire hydrants because of opposition from fire officials, water authorities and members of Congress.

U.S. Sens. Bob Casey, D-Scranton, and Pat Toomey, R-Lehigh Valley, were among four senators working on bipartisan legislation that would exempt fire hydrants from EPA requirements restricting the use of lead in certain types of water infrastructure by Jan. 4.

Late Friday, EPA officials said they won’t pursue their plans.

“In response to the feedback received through that process, EPA concluded that fire hydrants are not widely used as a potable source of water and that the guidance should be revised to exclude fire hydrants if Congress doesn’t take action to do so before the January deadline,” EPA spokeswoman Julia Valentine said in a statement.

The fire hydrant rule, announced in October, was part of the Reduction of Lead in Drinking Water Act, a 3-year-old piece of legislation. Throughout the fall, fire departments and water authorities nationwide urged the EPA to change course. Fire hydrants, they said, contain little lead in their metal parts or paint.

Some fixtures, such as shower valves, are exempt from the regulations. The legislation passed by the House of Representatives and under consideration in the Senate would add fire hydrants to the list of exemptions.

Casey and Toomey have said the measure would be “too costly and burdensome.” The Senate was expected to pass the bill sometime before the new year, according to Toomey’s office.

The rule would apply only to hydrants installed after Jan. 4.

At West View Water Authority, project manager George Koleck said hydrants contain few lead-containing metal parts. Yet the authority would have had to replace 30 hydrants in storage, purchased for about $1,800 apiece.

“If the EPA is telling us we have to use no lead, brass or bronze parts in repairing fire hydrants, that means we have to throw out our current inventory and purchase new items,” Koleck said.

In addition, manufacturers might not have lead-free products available, meaning any repairs or retrofitted hydrants would have to be shipped to the factory to comply with regulations.

“We test for lead in our water and we’re well below the standards,” Koleck said. “We’re for safe water, and we’ll do what’s required and necessary, but sometime these regulations are a little more overboard.”

Melissa Rubin, spokeswoman for the Pittsburgh Water & Sewer Authority, said the agency has about 50 hydrants stored to replace broken ones.

If the no-lead regulation had taken place, Rubin said it would have cost the agency $132,000 to replace its stored hydrants.

Melissa Daniels is a Trib Total Media staff writer.

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