Original Phase II MS4 regulations provided the basis for including monitoring in the MS4 Permits. Phase II MS4s should have interpreted this to mean monitoring plans associated with a TMDL within a designated watershed as a justification for storm event sampling. They did not have the knowledge six years ago to understand the ramifications of the wet weather and BMP performance monitoring included in their permit.
Draft NPDES Permit language taken from EPA Permit Improvement Guide
Phase II MS4s have developed a SMWP template that integrates performance and effectiveness measures into each BMP. This is the first criteria for the Evaluation and Assessment Plan that Phase II MS4s should consider Administrative and Environmental Indicators represent the second criteria.
Efforts to produce environmental indicators that are capable of informing program managers are much more intense than administrative indicators, but equally important. Both require some type of benchmark to drive toward. Water quality criteria is the low hanging fruit for regulators because each state maintains receiving water quality criteria. But taking such small sample sets and extrapolating them to an entire MS4 jurisdiction is an unrealistic exercise that does not use MS4 program resources wisely.
This is the task that is in front of Phase II MS4s and a question that Nebraska H2O has coordinated this workshop to answer. It is largely unrealistic, without significant funding, technical guidance, improved data coordination and sharing with regulators to expect meaningful information to come from end of pipe sampling specified in the current permit. Unlike the Papio-partnership around Omaha, these communities can not claim to share monitoring data by being a partner. Unique approaches are being considered that would address water quality considerations responsibly and in compliance with the language and intent of the Phase II MS4 regulations. Information will likely have to be a blend of shared data, simplified local techniques, and utilization of national and international data of relevance and applicability.
Wet-weather sampling is therefore only an indicator and when compared to other possible indicators, is a rather wasteful approach to MS4 compliance. Stormwater managers find themselves having to make great assumptions about the limited local data that is being collected and what it means for that point in time, let alone that point within the watershed. No framework currently being pursued to share that data and make it useful to each other.
Consider 2010 NRC report and anticipated EPA movement to require velocity control in an effort to protect habitat, flow regime to protect biotic interaction and energy sources in receiving waters. This goal would force the control of water quality parameters “in the watershed” and thereby obtain the same objective as only focusing on water quality parameters. This is the basis for EPA’s promotion of Green Infrastructure and Low Impact Development.
In other words, the Clean Water Act first addressed point-source pollutants (industries and WWTF). Now that non-point source pollutants are the primary culprit, modified monitoring methods are preferred that target biological heath status and trends would provide more value to the management of land.
This study identified the current gap in transitioning from regulating point sources with known input and treatable outputs to non-point sources that are variable, dynamic, and best prevented all together rather than treated. The ITFM Water Quality report gave the first wave of credibility to monitoring other factors for NPDES permit compliance. Movement in this promoted direction has been slow and mostly non-existent.
Indicators is another word that has become popular in NPDES circles over the last few years. It represents one factor that can be more easily measured to calculate a correlation to a water quality measurement. For the Construction industry, we will soon be grappling with discharge limits for NTUs. NTUs are an indicator, not a pollutant. Measuring NTUs from stormwater discharging from construction sites is an indicator of the level of treatment that has been provided on the regulated site. The use of indicators has also begun to make it’s way into MS4 compliance. Impervious cover has long been known to be a surrogate of impacted stream health. Recent USGS research confirmed what has been talked about for a decade. At approximately 30% direct connected impervious cover, the stream channel begins to show impacts to aquatic health. Indicators are easier to measure and more readily understandable to the possible target audience that needs to make management decisions. What makes more sense “We need to reduce nutrient loading by 40%” or “We need to reduce directly connected impervious surface cover by 40%”? You are likely to accomplish both, if the program focuses on the later rather than the former because the BMPs used to disconnect impervious cover will effectively treat the nutrient loading that was the initial target, but without the difficult storm event sampling. Indicators of macroinvertebrates include assemblage, community, population data, and lethal and sub-lethal toxicity data. Nebraska MS4 permits have been saddled with permit requirements for monitoring that steer clear of these management objectives that consider the watershed as an integrated system.
The biosurvey involves collecting, processing, and analyzing aquatic organisms to determine the health of the biological community in a stream. Macroinvertebrates are organisms that are large (macro) enough to be seen with the naked eye and lack a backbone (invertebrate). They inhabit all types of running waters, from fast-flowing mountain streams to slow-moving muddy rivers. Examples of aquatic macroinvertebrates include insects in their larval or nymph form, crayfish, clams, snails, and worms. Most live part or most of their life cycle attached to submerged rocks, logs, and vegetation.
Thus a biosurvey should be accompanied by an assessment of habitat and ambient water quality conditions in order to help explain biosurvey results. Monitoring for water quality conditions such as low dissolved oxygen, temperature, nutrients, pH and even a toxic screen can help identify which pollutants are responsible for impacts to a stream. This information can paint a more representative picture of urban stormwater runoff in relation to the entire watershed.
Xavier Swamikannu – Chief Stormwater Permitting, Los Angeles Regional Water Quality Control Board
Yoder, Chris, O., R.J. Miltner, and D. White. 1999. Assessing the Status of Aquatic Life Designated Uses in Urban and Suburban Watersheds. EPA/625/R-99/002. United States Environmental Protection Agency Reliance on chemical-only is painting an incomplete picture of urban stormwater discharge and so too would a full bioassessment approach.
Bottom-up approach gives the manager one piece of the puzzle and is asked to figure out what is depicted. Top-down approach gives the manager a reflection of the puzzle and asks manager to find the logical piece. Bioassessment based approach would likely necessitate an agreed approach and benchmark criteria with the regulatory authority.
Percent capture Overflow minimization Specific treatment level Knee of the curve
Include specific provisions that will target and address a known TMDL if one exists that is related to urban stormwater runoff.
EPA, in association with industry groups or non-profit groups, continue to produce guidance which slowly becomes the minimum expected standard of MS4s over time.
In 2010 Marty Link shared that 34 sites were sampled for stream macroinvertebrates.
NDEQ also maintains a consistent and programmed route of basin sampling.
NRDs are dissected based on watersheds, rather than political boundaries. Districts are already in the field collecting much information with field equipment and field techniques (albeit largely for groundwater) but the opportunity is incredibly within reach to partner with MS4s to collect relevant and timely data and attack stormwater quality on a watershed scale. 9 NRDs have MS4s within their jurisdictional boundaries. 7 expressed interest in this workshop. Our hope is that the dialogue could continue moving forward as joint partners in watershed protection.
GIS Based Analysis that should be available for use, education, and integrated decision making between MS4s, NRDs, USGS, NDEQ, and others.
Nebraska H2O, Papillion Creek Watershed Partnership, Douglas County, USGS, UNL and others have begun the work to mobilize for some types of monitoring. This data needs to be shared. It is recommended that UNL, if capacity exists, help promote regionally relevant data that MS4s can utilize for their Evaluation and Assessment Plans and SWMP decision making. This is based on the feedback from the April 20, 2011 Nebraska State-wide Stormwater Roundtable in Omaha.
NSQD – Version 3 - 8,602 rain events from 104 cities throughout the continental United States, and represents all 9 EPA Rain Zones and 12 land use categories. BMP Database - 800 literature sources on BMP performance reviewed USGS NAWQA Program - Monitoring data are integrated with geographic information on hydrological characteristics, land use, and other landscape features in models to extend water-quality understanding to unmonitored areas.
Volunteer Monitoring is a logical way to address public education and involvement and gain valuable data points that benefit MS4 evaluation and assessment. Some states help promote the volunteer network of stream bioassessments. QA/QC plans, promotional information, and key resources are readily available and should be used.
Other examples could include the 4-H, Boy and Girl Scouts, public schools, college institutions, local business partners, and retired veterans groups among others.
EPA STORET provides helpful information about the watershed of interest in one location although multiple sources should be considered. From this site, we can see that the Wood River is impaired by Selenium and that a TMDL is still needed. All information used to sample the Wood River should be shared with Grand Island MS4 for consideration in developing the SWMP and Evaluation and Assessment Plan approach.
Bioassessment Approach to MS4 Evaluation and Assessment
Nebraska H2O Stream Bioassessment Workshop Grand Island, Nebraska May 18-19, 2011 With Field Work in the Wood River and Application to Phase II MS4 Permits
MS4 Evaluation and Assessment <ul><li>Not everything that counts can be measured. </li></ul><ul><li>Not everything that can be measured counts. </li></ul><ul><li>Albert Einstein (1879 – 1955) </li></ul>
Comprehensive Evaluation and Assessment Program for MS4s <ul><li>“ You must evaluate program compliance, the appropriateness of identified best management practices, and progress towards achieving your identified measurable goals. </li></ul><ul><ul><li>NPDES permitting authority (NDEQ) may determine monitoring requirements for you in accordance with State/Tribal monitoring plans appropriate to your watershed. Participation in a group monitoring program is encouraged.” (64 FR 68843, Dec. 8, 1999) </li></ul></ul>
Comprehensive Evaluation and Assessment Program for MS4s <ul><li>“ The permittee must provide a comprehensive evaluation and assessment program that utilizes narrative effluent limitations requiring implementation of BMPs to satisfy permit requirements and protect water quality.” ( EPA MS4 Permit Improvement Guide 2010 ) </li></ul><ul><li>Must be designed to meet stated objectives: </li></ul>
Monitoring Program Objectives <ul><li>Assess compliance with MS4 permit; </li></ul><ul><li>Measure the effectiveness of SWMP through performance and effectiveness measures ; </li></ul><ul><li>Assess progress towards measurable goals ; and </li></ul><ul><li>Evaluate the appropriateness of identified BMPs using appropriate administrative and environmental assessment indicators . </li></ul>
SWMP Indicators <ul><li>Environmental indicators represent: </li></ul><ul><ul><li>physical and hydrologic criteria; </li></ul></ul><ul><ul><li>biological criteria; and </li></ul></ul><ul><ul><li>water quality criteria. </li></ul></ul><ul><li>Administrative indicators represent: </li></ul><ul><ul><li>social criteria; </li></ul></ul><ul><ul><li>programmatic criteria; and </li></ul></ul><ul><ul><li>site criteria. </li></ul></ul>
Water Quality Considerations That Must Be Incorporated <ul><li>Chemical, physical, and biological impacts to receiving waters from stormwater discharges; </li></ul><ul><li>Stormwater discharge characteristics; </li></ul><ul><li>Source identification of specific pollutants; and </li></ul><ul><li>Overall health and long-term trends in quality. </li></ul>
End of Pipe Sampling <ul><li>"But he has nothing at all on!" at last cried out all the people. The Emperor was vexed, for he knew that the people were right; but he thought the procession must go on now! And the lords of the bedchamber took greater pains than ever, to appear holding up a train, although, in reality, there was no train to hold.” </li></ul><ul><li>The Emperor’s New Clothes </li></ul>
Disadvantages of End of Pipe Sampling Only <ul><li>Unlike a WWTF, not all the representative discharge is actually being sampled; </li></ul><ul><li>Flow in non-sampled locations is only estimated and therefore event concentrations are only estimated; </li></ul><ul><li>Periodic sampling misses many of the “pulses” inherent in a dynamic landscape; and </li></ul><ul><li>Results unlikely to product action this decade. </li></ul>
Disadvantages of End of Pipe Sampling Only <ul><li>CWA – Mandates ecological integrity as well </li></ul><ul><ul><li>Underlying presumption that “improvements in chemical water quality would be followed by a restoration of biological integrity” has been increasingly questioned. </li></ul></ul><ul><ul><li>Factors related to habitat structure, flow regime, biotic interactions, and the available energy base are also responsible for the condition of surface water resources. </li></ul></ul>
Disadvantages of End of Pipe Sampling Only <ul><li>“ Most water-monitoring networks were designed and implemented at a time when detection and control of chemical pollutants in water was of paramount importance.” </li></ul><ul><li>“ Now, however, the need for aquatic biological information is more widely recognized.” </li></ul>
Disadvantages of End of Pipe Sampling Only <ul><li>“ Although many individual monitoring networks have been well designed to meet their own goals, data solely from these networks often will not provide a broad and comprehensive assessment of water quality at watershed scales.” </li></ul><ul><li>USEPA and USGS </li></ul><ul><li>Intergovernmental Task Force on </li></ul><ul><li>Monitoring Water Quality – 1995 http://acwi.gov/itfm.html </li></ul>
ITFM Water Quality Recommendations Included: <ul><li>Identify indicators to measure goals </li></ul><ul><li>Include ecological and biological information </li></ul><ul><ul><li>Improves ecosystem-, watershed-, and aquifer-management decisions </li></ul></ul><ul><li>Link compliance and ambient monitoring </li></ul><ul><li>Implement comparable methods </li></ul><ul><li>Identify research needs </li></ul><ul><li>Promote cost effectiveness </li></ul>
Stream Bioassessment Monitoring <ul><li>Is ditchwater dull? Naturalists with microscopes have told me that it teems with quiet fun. ~ G. K. Chesterton (1874 - 1936) </li></ul>
Aquatic Macroinvertebrates as Indicators of Stream Quality <ul><li>Affected by the physical, chemical, and biological conditions of the stream. </li></ul><ul><li>Can't escape pollution and show the effects of short-and long-term pollution events. </li></ul><ul><li>May show the cumulative impacts of pollution. </li></ul>
Aquatic Macroinvertebrates as Indicators of Stream Quality <ul><li>May show impacts from habitat loss not detected by traditional water quality assessments. </li></ul><ul><li>They are a critical part of the stream's food web. </li></ul><ul><li>Some are very intolerant of pollution. </li></ul><ul><li>Relatively easy to sample and identify. </li></ul>
Advantages and Disadvantages of Stream Bioassessment <ul><li>It is not difficult to realize that a stream full of many kinds of crawling and swimming "critters" is healthier than one without much life. </li></ul><ul><li>A stream bioassessment may not be able to definitively tell us why certain types of creatures are present or absent on its own. </li></ul>
Chemical vs. Bioassessment <ul><li>What approach provides information needed? </li></ul><ul><ul><li>Start with how will information be used! </li></ul></ul><ul><li>What approach is required? </li></ul><ul><ul><li>Permit or watershed monitoring (TMDL) plan? </li></ul></ul><ul><li>What approach is feasible? </li></ul><ul><ul><li>“ Not reasonable to expect local governments to spend public funds when outcomes are highly uncertain and some assurance of reasonable compliance is not proffered.” </li></ul></ul>
Questions to Define Feasibility <ul><li>What contaminants are important for monitoring in the selected watershed? </li></ul><ul><li>What are their sources? </li></ul><ul><li>How frequently does an area need to be sampled to address key management issues and concerns? </li></ul>
Questions to Define Feasibility <ul><li>What are the sources, transport, fate, and effects of selected contaminants in stream reaches or in the watershed as a whole? </li></ul><ul><li>Does the information collected provide a clear framework for key decision makers? </li></ul><ul><li>How do pollutant loadings affect the beneficial uses defined for the receiving waters? </li></ul>
Chemical vs. Bioassessment <ul><li>No single monitoring component is sufficient to indicate where and how ecosystem integrity is being affected, particularly where multiple stressors are impacting stream reaches. </li></ul><ul><li>Ohio EPA found 49.8% of streams assessed as “impaired” were detected by bioindicators but not by chemical indicators! </li></ul><ul><li>Chemical indicators > criteria in 2.8% of cases where biocriteria fully attained (Yoder, 1999) </li></ul>
Chemical vs. Bioassessment *Nebraska DEQ does not define biological criteria for receiving waters in the State Attribute Chemical-based Bioassessment-based Expressed in WQS as Parameter-specific criteria Biological criteria* Representation of Biointegrity Surrogate measure Direct measure Principal Focus Pollutant only Aquatic environment Breadth of Coverage Partial Complete Operative Direction Bottom-up Top-down Effect Properties Individual Cumulative Indicator Role Stressor/exposure Response Best Strength Design criteria Impact assessment criteria
Other NPDES Permit Approaches <ul><li>Municipal and Industrial Wastewater </li></ul><ul><ul><li>Single point of discharge that can be monitored </li></ul></ul><ul><ul><li>Complex treatment technology utilized </li></ul></ul><ul><ul><li>Active operation 24-hours per day </li></ul></ul><ul><li>Combined Sewer Overflow </li></ul><ul><ul><li>Expensive modeling of water quality impacts </li></ul></ul><ul><ul><li>Water quality performance goals required </li></ul></ul><ul><ul><li>Technology performance goals required </li></ul></ul><ul><ul><li>Multiple permits to presume or demonstrate quality </li></ul></ul>
Phase II MS4 Permit Approach <ul><li>Education and Involvement </li></ul><ul><li>Illicit Discharge Detection and Elimination </li></ul><ul><li>Construction Stormwater </li></ul><ul><li>Post-Construction Stormwater </li></ul><ul><li>Good Housekeeping/Pollution Prevention </li></ul><ul><li>Performance and Effectiveness Measures are to be built in to provide for a “treatment standard” </li></ul>
Sharing Information <ul><li>Leaving MS4s to collect monitoring information on their own without coordinating other data collection in the watershed is wasteful and possibly divisive between stakeholders. </li></ul><ul><li>Other sources of information are available </li></ul><ul><li>Integrated approach to watershed monitoring is encouraged and logical </li></ul>
Volunteer Monitoring <ul><li>Community, youth, land owner, planners have opportunity to become educated about local water-resources characteristics and problems, and to foster a sense of stewardship. </li></ul><ul><li>Provide data to agencies for watershed planning, assessment, and reporting and water quality management. </li></ul>
Example Watershed Groups in Grand Island Area <ul><li>Nature Conservancy - Nebraska Field Office </li></ul><ul><li>Watershed Land Trust – Nebraska </li></ul><ul><li>Platte River Whooping Crane Maintenance Trust, Inc. </li></ul><ul><li>Nebraska Wildlife Federation </li></ul><ul><li>Stewards of the Platte </li></ul><ul><li>Central Platte Natural Resource District </li></ul>
EPA STORET Data Available Wood River MP2-10200
Conclusions for MS4 Evaluation and Assessment Plan <ul><li>Content of Evaluation and Assessment Plan: </li></ul><ul><ul><li>1 st - Performance and Effectiveness Measures </li></ul></ul><ul><ul><li>2 nd - Administrative and Environmental Indicators </li></ul></ul><ul><li>Balance Environmental Indicators: </li></ul><ul><ul><li>Flexibility needed due to issues facing each MS4 </li></ul></ul><ul><ul><li>Blend of options for water quality sampling and stream bioassessments is right approach </li></ul></ul><ul><ul><li>Utilization of ALL relevant and available monitoring data collected by others. </li></ul></ul>