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As we continue our approach to the March 10, 2003, filing deadline for USEPA's National Pollutant Discharge Elimination System (NPDES) Phase II stormwater rule, planners are grappling with what mix of best management practices (BMPs) will be needed to meet permitting authorities' compliance requirements. In many applications, the use of proprietary technologies such as separators and filtration devices will be needed. However, a wide variety of technologies is emerging, and a reasonable method of verifying the claims of these technologies is going to be necessary. On November 14, 2001, EPA and NSF International held the annual Wet Weather Flow Technologies Stakeholder Advisory meeting in Salt Lake City, UT. EPA has developed protocols for testing and verifying stormwater technologies through its Environmental Technologies Verification Program (ETV). The goal of ETV is to verify performance characteristics of commercial-ready technology through the evaluation of objective and quality-assured data to provide potential purchasers and permitters an independent and credible assessment of what they are buying and permitting. Under ETV, two pilot programs have emerged that are evaluating stormwater-related treatment technologies. These programs are the Wet Weather Flow Technologies and Source Water Protection Technologies pilots. Both of these pilot programs are being managed by NSF International, and protocols for testing treatment devices have been completed. As we have learned over the past couple of years, the art of developing uniform testing procedures for verifying the claims of divergent technologies is a difficult process. Complicating the development of an effective protocol for testing are the wide variances in wet-weather events as well as differences in local conditions across the country. The Storm Water Treatment Device section of the Wet Weather Flow Technologies pilot will provide verification utilizing data generated from field studies that will evaluate vender claims over a period of at least 15 wet-weather events. This process will provide data points from a variety of conditions in order to show how various technologies will function under different types of events. Many of the stormwater treatment devices on the market today are participating in this program. The Source Water Protection Program is evaluating claims for in-drain treatment devices utilizing stormwater flow rates and contaminant loadings in a laboratory setting to duplicate, to some degree, field conditions, as well as floor drains and other human-generated flows discharged into receiving waters. While some adjustments might still need to be made in the next few months, many technologies will begin testing soon, and EPA is hopeful that some verifications will be completed by late 2002 for use by planners in the Phase II process. EPA will be posting completed verifications on its ETV Web site for easy access by planners. For more information on ETV, go to www.epa.gov/etv. David A. Woelkers is director of regulatory compliance with Hydro Compliance Management Inc. in Whitmore Lake, MI.
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