Municipalities across the country integrate many methods to help meet NPDES requirements.

By Carol Brzozowski

This month the quality of the nation's water supply receives an extra measure of protection as Phase II of the National Pollutant Discharge Elimination System (NPDES) goes into effect. Three decades ago, the establishment of the Clean Water Act initiated actions that put a heavy dent into point-source pollution. These days, concerns also center on nonpoint-source pollution.

NPDES is the driving force behind present operations at the Port of San Diego (CA), states Richard Gilb, senior environmental specialist. "It will mean that with our construction projects, the scrutiny goes down to 1 acre. We've been living under Phase I since the beginning, and I'm going to guess we're the only port district in the country that's subject to a Phase I permit."

Most ports are contained and function primarily as industrial operations that would qualify for the industrial permit, Gilb explains. "But we actually have a lot more land-use authority. We control 2,000 acres around the entire San Diego Bay. I think we were initially named in the permit because we had a contamination problem related to a storm drain that involved the port."

To trap pollutants in runoff, the port currently uses a number of best management practices (BMPs) at its facilities: Interceptor catch basin inserts from Stormdrain Solutions, continuous deflective separation units from CDS Technologies, and Stormceptor oil and sediment separators. Sometimes, on a temporary basis, the port will use a filter fabric, Gilb says.

Because the port is located in an urban environment, the devices are not used in combination with other nonproprietary BMPs. "We do have some parks that have beaches in them and are on the bay, and those are instances where we can do some other BMPs but haven't actually gotten to those yet," Gilb says.

Crucial factors in choosing the devices are the cost and the port's ability to retrofit some of its existing systems, Gilb relates. While the devices are part of an overall stormwater pollution prevention program at the port, he says it's a bit "haphazard at this point. I wouldn't say that it's well scoped out, but we are a co-permittee to a permit that was issued to the entire county and all of the 18 municipalities in our county. The permit directs us to initiate a management program."

The first permit was issued in 1990 and was supposed to end in five years, but it took quite a bit to get it revised and was not actually drafted into a second version and adopted until February 2001, Gilb says.

"There was such a long lag between the permits," he recalls. "The first permit was written before the regulations and was based on the statutes, but without the regulations, so it was a little vague, to say the least. And so our latest permit is much more prescriptive and requires a lot more documentation and program outline."

Gilb describes the major sources of nonpoint-source pollution concerns in the area as coming from the downtown urban corridor along the bay. "Then we have four other cities that line the bay, and each one of those is a bit smaller than the city of San Diego, but they are contributors as well. There are some industrial facilities along the bay, but as far as stormwater, they are pretty heavily regulated already. We get the typical urban runoff issues - mostly roads, streets, and hard surfaces."

Presently the port is trying to outline an appropriate maintenance schedule, as some of the devices only have been in place for a year. It cleans some of the older installations on a quarterly basis, weighing the material that is found in them.

"We're trying to figure out what works best for us long term, if we'll go to a particular device that our channel services people will be maintaining," Gilb says. "Currently they're being maintained by consultants or contractors."

Noting the area's relatively sparse rainfall, he adds, "Educating the public about stormwater can be difficult when you only get 10 inches a year. Most of the rain comes down in November to February or March." That can make first flush a particularly thorny issue. The first rain after a dry period contains an especially high concentration of pollutants, which have been accumulating since the last rain. The port has no particular measures for handling that, other than to depend on the devices that are in place, Gilb says. "Everybody tries to keep up with the street sweeping, everybody tries to get all of the trash out of the system right before the rainy season starts, but that's about as much as we can do at this point."

Another concern for many regions is the development of total maximum daily loads (TMDLs) for impaired waters, which limits the amount of a particular pollutant that can be discharged to a particular body of water according to its designated uses, such swimming or fishing. There is a TMDL for the pesticide diazanon for one of the creeks that drains into the San Diego Bay. TMDLs also are being proposed for copper for a section of the bay relating to toxic hull paints for pleasure boats, Gilb points out.

The TMDL for diazanon has been the driving factor behind an environmental education and outreach program being spearheaded by the City of San Diego. "The major requirements of the TMDL action are public education," Gilb states. "Diazanon is going to be phased out for sale in 2004 if not sooner, so it's hoped that that will alleviate the problem over time." For now, the port is monitoring water quality in the areas where the BMPs are in use.

"They also are subject to the industrial permit, so we do collect two samples a year, and unfortunately we really haven't been able to do before-and-after comparisons," Gilb reports. "That's one thing we hope to do this winter with the CDS devices, but to date we've only been able to do downstream of the devices."

Rainfall Monitoring in Largo, FL

The City of Largo, FL, on the Gulf Coast, recently installed three 9-cfs CDS units on open channels, and a fourth CDS unit that will treat 19 cfs had been scheduled for installation. Mike Sepessy, Largo's stormwater program coordinator, says the municipality also is using KriStar Enterprises's Fossil Filters, catch basin inserts containing adsorbent material to capture oils, hydrocarbons, and other pollutants especially during low-flow or first-flush events.

Largo identified residential neighborhoods where the catch basins discharge directly into a water body and retrofitted some existing catch basins in those neighborhoods to pretreat the runoff. Sepessy states that the "aggressive" approach will include 160 retrofits. He notes that Largo has identified problematic water-quality and maintenance areas as projects the city should undertake to improve water quality and satisfy its NPDES permit.

"One of the CDS units is located near our public works facility, which has a fleet maintenance shop, so there's potential for hydrocarbons and other pollutants to be generated from the site," he explains. He adds that its installation enables the city to trap the hydrocarbons and pollutants before they make their way into the stormwater system and into the receiving water body. Many other municipal facilities with heavy public use, such as the parking lots near the city's library, cultural center, city hall complex, and recreational facility, generate a lot of hydrocarbons from storm events.

Additionally, trash, such as bottle caps and paper cups generated from the special events, makes its way into the stormwater system after a rain event. "The CDS unit helps trap any floatable materials at those particular installations," Sepessy reports.

He recalls that one of the first considerations in choosing a particular inlet control unit was its performance. Largo officials checked with other municipalities that had installed CDS units and were pleased with the results. Additionally, the Southwest Florida Water Management District provided cooperative funding up to 50% for the cost and installation of the CDS units, which helped in getting the city officials onboard, Sepessy notes.

He adds that the reliability and the lack of maintenance required on the CDS units are other advantages. "Once they're put into the ground, other than cleaning them, there's really no moving parts or no maintenance to them. That's another important feature."

Instead the maintenance schedule for the devices in Largo is contingent upon storm events, Sepessy says. In Florida, for example, there are two seasons: the wet hurricane season of June through November and the dry winter season. "If we don't have any rain events, generally [the units don't have to be cleaned]," he relates. "But just from our own field experience over the last two years, we've seen a need to clean them about twice a year."

Typically maintenance is scheduled before and at the end of the rainy season or after any significant rain events. "We want to monitor how much material is being captured by the units, and we also try to characterize the types of materials the units are removing," he explains.

Largo's inlet control devices are equipped with removable baskets, allowing crew members to see how much material is in the baskets, gauge the remaining capacity, and schedule cleaning based on the physical observation.

Sepessy says Largo has had a rainfall monitoring system on-line for about two years. "We are looking at putting in monitoring stations where our lift stations are located at various parts of the city, and these data [are fed] to a centralized location over at our streets and drainage section so they can look at the impact on various stormwater channels they maintain. So if we get a storm event in here, they can see if it was something that was citywide or if it was localized in certain areas."

On the other hand, during a dry spell, contaminants tend to build up, but it's during that dry period when the department does much of its maintenance. "In having an aggressive maintenance program during that dry spell, whenever we do get a storm event we are usually in pretty good shape to be able to handle any type of flows," he states.

Largo is presently in the fifth year of its five-year NPDES permit. During the first few years, the city was engaged in identifying areas and planning; two years ago it began installing the CDS units.

Sepessy says that as a result of NPDES, city officials understand the stormwater department's requests for cost needed to fulfill federal requirements. "It also helps that they understand this is a national problem, as far as stormwater being one of the leading contributors for water-quality degradation, and that these are important tools to improve stormwater quality."

Largo is using its manufactured devices in combination with other nonmanufactured water-quality BMPs, such as retention areas for onsite treatment, he notes. "We're treating a large basin area. The basin is significant in that there are a lot of sources upstream of the CDS unit that may not receive any type of pretreatments."

Construction sites are the biggest concerns in terms of nonpoint-source pollution for Largo. "We have an aggressive program to make sure construction sites implement the required BMPs prior to actually breaking ground, and we also require that an inspection be performed by our office prior to the release of a building permit or a development order," Sepessy maintains.

TMDLs haven't had an affect on Largo's program because the municipality has been aggressive in looking at ways it can improve stormwater quality, Sepessy says. "We just completed a $4.5 million alum injection facility where we are actually feeding aluminum sulfate in one of our main stormwater channels to reduce the level of nitrogen and phosphorous that gets discharged eventually to Boca Siega Bay. [It's] a project that is going to significantly reduce the level of nutrients reaching the bay. It's not something that was a requirement of either our NPDES permit or the TMDL program, but it would be something that would probably qualify for some recognition during the TMDL period."

Although Largo does not monitor water, Pinellas County - the county in which Largo is located - has a countywide water-quality monitoring program. "We are a co-permittee to the Pinellas County NPDES permit, so those data are available from the various outfall locations the county samples within our jurisdiction," Sepessy states.

New Systems in Orlando

To the northeast, in Orlando, FL, officials long have been addressing water-quality concerns, notes Kevin McCann, the city's lake enhancement coordinator. Orlando uses CDS and Stormceptor units, augmented by alum injection and baffle box-type controls. Because Orlando is so built out, space is critical.

"When we want to do a stormwater retrofit, a lot of times our options are limited because when you have a built-out area, you can't just go in and take a city block or people's houses to build a stormwater project. So you have to start looking at some of these underground systems that you can put right in-line underground with the storm line," McCann explains. "That's why we use alum injection, and now we're starting to look more at these sediment- and trash-collecting devices such as the CDS."

The maintenance schedule for the units varies with the devices, he says. "Some of these units are fairly new to us, and we're working it out by monitoring the system. You really have to physically inspect the system. We're doing that now to see when they fill up because there's no set maintenance schedule." He notes, however, that during the heavy leaf fall, the maintenance schedule increases. "During dry weather, you might be able to get away with going out every six months to maintain some of these, but during a leaf fall and wet-weather conditions, you might have to go out every two months."

In Orlando, the nonpoint-source pollution concerns include oils and grease and low levels of heavy metals from street runoff, as well as nutrients that cause algae bloom, McCann points out. Additionally, there is a lot of leaf litter due to the heavy canopy of oak trees in the Orlando area. "We've also had a lot of problems with trash, and we need to try to intercept that," he remarks.

McCann says Orlando gets an average of 48 in. of rain, though it varies greatly.

"With retrofit projects, you don't have the capability always to get the first inch of rainfall because you are limited in the space, but we try to design so that we're getting at least the first half-inch or so of runoff going through any of our devices before it will bypass and go out into the surface water. And we see that we get the vast majority of pollutants; we can even catch the half-inch of runoff, the first inch of rain."

The measures are part of Orlando's overall stormwater pollution prevention program. "In general, we try to identify problem areas and then come up with solutions based on that, but we always have money budgeted for retrofitting stormwater lines for pollution control," states McCann.

He says Orlando hasn't been affected by NPDES as much as some other cities have because it had been proactive before the mandates came into play. "We already had been active in retrofitting our stormwater systems to maintain water quality, so in that regard NPDES was pretty easy for us since we were already doing a lot of the things that it was requiring anyway." He adds that the philosophy driving the city toward a proactive stance was "to protect the water quality and surface waters since we have so many lakes here in Orlando, and it's a way of life and an important resource to the residents in Orlando to have good water quality."

TMDLs are still in a development stage in Orlando. "That's a good reason to try to implement these programs and get as many of these management practices out. Hopefully this will keep our water bodies from being impaired and being put on the TMDL list," McCann remarks.

Orlando has been monitoring water quality for more than 12 years. "We're starting to be able to run trend analyses on the lakes," McCann relates. "Our water-quality data are telling us that our management program is good because we have very few lakes that are having any significant decline in water quality." Additionally, Orlando has more lakes that are improving or at least staying the same, he reports. "But some of this technology we haven't had in the ground long enough. It really takes several years before you can really say if there's a significant improvement or not in the water quality because water quality fluctuates so much on an annual basis." None of the systems is more than four years old.

McCann would like to see more research on removal efficiencies, "good, completely unbiased data for what kind of pollutant removal we're getting," and testimonies from the different people using them - "to share some of the kinds of problems they have had and how they've corrected them."

Antilitter Campaign in Upper Marion Township

Robert Norman is the director of public works for Upper Marion Township, PA, where two Stormdrain Solutions inserts recently were installed for a testing phase. "We're finding that it's picking everything up," Norman points out. "We put one in an area where we thought we'd have a lot of litter and the other one where we didn't think we'd have a lot of litter, and actually they're both getting about the same amount, so I guess the flow into them has a lot to do with from how far away the water comes."

He says crews go through the township once a year and thoroughly clean out the outlets. Because the Interceptor frames are stainless steel, Norman anticipates there won't be much additional maintenance required on them. "So far we haven't even come close to filling them, so we don't have to do an increased maintenance on them at this time."

He says the township intended to use the devices at certain locations as part of the second phase of its stormwater management plan, which will be implemented over a five-year period when it receives its NPDES permit. The state is overseeing the federal mandate. Additionally, the township has incorporated other activities, such as street sweeping and a weekly inlet cleaning.

"We try to find trash near inlets. When we know we are going to receive heavy storms, we go out to our known target sites where flooding has occurred in the past and make sure that those are clean so they won't be a problem for us," Norman explains.

NPDES has had an immense impact on how Upper Marion Township addresses stormwater issues, he reports. The township instituted an antilitter program to educate its citizens on the impact litter has on the groundwater and streams. "We are aware that this is an issue with storm drains, and we either catch it in advance or we catch it later in the pipes. It's easier to pick [the litter] up before [it gets] in there," Norman notes. "It's another reason why we wanted to use a trap." In addition to using manufactured devices, the township is using retention basins along with incorporating wetlands and swales to improve water quality.

There hasn't been a lot of rainfall in his region over the past seven years; in fact, the area has been under severe drought restrictions, Norman points out. "To some extent, that probably affects how much is getting into the basins. The street sweeper will probably pick up a lot more [litter] before the rain comes along."

Part of the regulatory requirements includes groundwater testing, and Norman says that will have to be incorporated into the town's practices because Upper Marion Township does not do it at this time.

Volunteer Programs in Seattle

Joy Huber is the executive director of a nonprofit organization in Seattle, WA, called PlanetCPR, whose name is derived from conserve, protect, and restore. Its mission is to develop volunteer programs that benefit the environment.

Through its Grate Mate program, PlanetCPR helps volunteers install Ultra-DrainGuard products by UltraTech International, which Huber describes as polypropylene-bag or sock-type catch basin inserts. PlanetCPR uses the devices because they are easy to install and are inexpensive, making them cost-efficient for a volunteer program.

"When the kids pull the socks out, they can easily open the sock and paw through the stuff," she says. "We tested them at length and discovered they were more effective than anyone ever imagined they would be."

PlanetCPR's program is carried out in standard parking lots in such places as malls, retail shops, churches, and schools. "In settings like those, they last much longer than anyone had thought," Huber remarks. "For the most part, we've been leaving them in for a year and discovered [that] over a year's time in a setting like that, they continue to perform." Sometimes the devices are changed out after six months in heavily used parking lots, such as in front of grocery stores, or where there's a lot of traffic or there's a great deal of sediment coming in off the road. "We try to avoid situations where there is extra sediment. We just don't use them in places where we don't think they'll last a year."

Because PlanetCPR works with volunteers in its public education effort, it does not use the bags in combination with other nonmanufactured water-quality BMPs. "Sometimes we do it in collaboration with those types of projects, but whenever there are such facilities nearby, we point that out to the kids and often have property managers or municipal officials show them why what they are doing relates to something that is already there," Huber explains. For example, when PlanetCPR volunteers installed the catch basin inserts near a shopping mall, runoff from the mall lot fed into a retention pond. "It was the perfect teaching opportunity. We had someone from the city and the property manager come out and explain to the kids why they built the facility the way they did, what native grasses were in there, and what wildlife was in there. The frogs were singing, so we talked about the biology of that and then we talked about what benefit was being provided by the filters. In this case, it wasn't as crucial for us to have put the filters in that lot because there was treatment right there. But we did it anyway because we were intercepting half of [the pollution], and it meant that they thought they would have to dredge it out less often." Huber used the project as an example of a property owner who had high standards for stewardship and who was glad to pay for the filters and participate in the program.

The nonpoint-source pollution concerns in the areas that PlanetCPR addresses include heavy metals, oils, and fine sediment because of the region's salmon recovery efforts. "Sediment is an important consideration in terms of salmon habitat," Huber states. "We find the socks do a pretty good job with fine sediment. People didn't think so at first, but the pores in the fabric become occluded, and the gunk attracts the gunk. After a year, about a third of the particles are less than 100 microns in size."

According to Huber, PlanetCPR does not monitor the quality of the water in the receiving water bodies because "we discovered it was a completely ridiculous pursuit. Nobody has figured out how to effectively do it because the influent into a particular drain at any moment shifts with a car that may drive by 10 or 20 feet away. You can't even really get a sample of the influent and then effluent through the bag in a given catch basin, much less try to extrapolate what might happen in a watershed where 120 catch basins are collecting and emptying into that outflow."

Another problem, she relates, is that the systems in which the agency's volunteers are placing bags are retrofitted, so there's dirt inside the system from previous storm events. "Furthermore, the lines aren't necessarily free of cracks and other leakage - so a sampling in a receiving water body is going to be thrown off by all kinds of factors that are beyond the control of the bag at any one time." The best that can be done is to measure what the bags have caught, Huber says, adding that agency volunteers at least know what the bags prevented from going into the receiving water body, although no firm percentages of what that debris represents can be deduced. "It's an inexact science. All we can really tell is how much they've caught."

NPDES had an enormous influence on what PlanetCPR has done, remarks Huber. "When we started the program three years ago, most employees of public works departments had never even heard of the catch basin insert; they'd kind of nod their head and look blankly into space," she laughs. "The knowledge of this technology is very new, so when we first started this program three years ago, we were getting enormous resistance inside public works departments because people would raise all the possible 'horribles' that might happen without any knowledge of how they might behave in the field.

"They were sure that if [the inserts] did work, they'd only work for the first month and then you'd have to change them every month, which is actually not at all the case - they work better as they get dirtier."

She recalls that public works employees also thought the bags would flood or break loose and clog their systems or that people would start throwing trash down into the system since the bags were in there. "They were raising enormous numbers of objections, and we had to really prove the program in the field before people started listening. When our test results started coming back and we realized that these were catching a lot, even after they'd been in place for 13 months and they were really catching fine sediment as well as coarse, people began to look at the data and the word changed about this technology."

Huber says the only stumbling block to the implementation of PlanetCPR now in the state of Washington is that the state is requiring the cities to embark on a rigorous and comprehensive inspection of private drains, and "the inspectors don't like the presence of these bags because they're out there by themselves alone in the rain and everything is wet and heavy, and they have to lift the grates and lift out these bags and drag them over to the landscaping before they can measure and examine the structural integrity of the catch basin and measure the depth of the sump. We're getting resistance from the inspectors, but no longer from the engineers. So the tide has really turned in terms of acceptance of the technology."

She observes that the unique Pacific Northwest climate contributes to the effectiveness of PlanetCPR's public education program. "For instance, we don't have snow, so we don't sand our roads, so the technology works well all year long. I'm not sure that I would use them in the dead of winter in Minnesota, but here we don't have to worry about a clump of ice sitting in the bag and not melting, or about 80 pounds of sand coming into one of those bags in a one-month period. We are still experimenting with how well it might work in other areas of the country that have to deal with snow and sanding."

Storm drain grates in the Pacific Northwest tend to be small - typically 18 x 22 in. - making them easier to manage and ideal for the volunteers. PlanetCPR has expanded its program in Oregon and Vancouver. A test site has been set up in Rhode Island, and there has been interest in upstate New York, Kansas, Florida, and California. "Our organization doesn't have the resources to be very rigorous about testing it in other areas," Huber concedes. "In order for our program to work, the grates have to be light enough to physically lift them up, so there are some parts of the United States, such as Washington, DC, that would be hopeless for this program. The grates are just too huge, and oftentimes they are bolted down."

In recent months, PlanetCPR has been experimenting with filters that have a wire rim around the top because they're easier to retrieve. "They're faster to put in," she describes, "and they're easier to take out because they just sit there in the grate and they're not as likely to fall in. If they do fall into the catch basin, the wire prevents them from getting sucked into the outflow pipe. It's conceivable that the drain might flood locally, but it's not going to cause flooding somewhere else. So there are some advantages to the wire rim that we are seeing now."

Carol Brzozowski is a journalist in Coral Springs, FL.

SW - March/April 2003

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