I have a bin behind my desk where my magazines collect when I don't have time to read them. Last week the bin was overflowing so I took the time to see if there was anything interesting in any of them. In a magazine called www.stormh2o.com I found an article entitled "The Role Street Sweeping Must Play in Achieving Numeric Pollution Limits" by Robert C. Sutherland, P.E. Sure enough this title seemed interesting so I started reading. As we all know, cities and land disturbance sites are being asked (or more rightly told) they have to achieve specific numeric pollution limits in their stormwater permits. Many entities either don't know how to achieve these limits or can't afford them. The article states that in November 2010, EPA's Office of Water issued a memorandum entitled "Revisions to the November 22, 2002, Memorandum Establishing Total Maximum Daily Loads (TMDLs) Waste Load Allocations (WLAs) for Stormwater Sources and NPDES Permit Requirements Based on those WLAs". The 2010 memorandum addressed the use of water-quality-based effluent limits in stormwater permits, including the use of surrogates such as flow or impervious cover. Many stakeholders were concerned that the 2010 memorandum seemed to imply that the National Pollutant Discharge Elimination System (NPDES) permitting authorities should impose end-of-pipe limitations on each individual outfall in every municipal separate storm sewer system (MS4).

View of downtown Springfield, MO clearly showing amount of impervious surfaces such as streets and parking lots.

Clearly, these regulatory actions will have a financial impact on municipal and industrial NPDES permit holders. But perhaps the greatest financial impact will ultimately result from a March 10, 2011, federal court ruling. This very recent opinion has broad implications for the capital and operational budgets of all MS4s. The Federal Court of Appeals for the Ninth Circuit has reaffirmed that the Clean Water Act (CWA) requires that stormwater discharge points (e.g., pipes releasing stormwater into rivers, wetlands, and lakes) must have an NPDES permit because such discharge points are "point sources." More importantly, the court ruled that it does not matter who is responsible for the contaminants that the stormwater picks up; the CWA puts the onus of responsibility for remediating the stormwater before it is discharged on the entity operating the stormwater system, which in many cases is a MS4 (NRDC v. County of Los Angeles, 2011 U.S. App. LEXIS 4647 3/10/11). The court went on to state that the pre-discharge remedial standards for stormwater will need to be laid out in the NPDES permit. These treatment requirements must be met before the stormwater can be released or discharged. The court also pointed out that states operating these types of programs under the CWA have the authority to impose more stringent requirements that those imposed by EPA.

Mr. Sutherland also says that a cities first line of defense against urban stormwater pollution should be street sweeping. He cites studies that show street sweeping to be a more economical method of reducing storm water pollution than LID and other more expensive methods. 

• Pollutant washoff from paved surfaces like streets and parking lots is the greatest single source of urban stormwater pollution
• Dirt accumulated on these surfaces is the greatest contributor to pollutants that are washed off by rainfall transformed to stormwater runoff
• Sweepers are more effective at dirt pick-up than ever before
• Operational characteristics of sweeping like forward speed, broom settings, broom maintenance, and fugitive dust controls will have a great effect on dirt or sediment pick-up results
• Sweeping improves stormwater quality because it removes accumulated contaminated material and reduces stormwater pollutant loadings discharges from the site
• Costs of removing stormwater pollutants by pavements sweeping are an order of magnitude lower when compared to those for structural stormwater treatment BMPs

I found this whole concept interesting as I had never before encountered sweeping as part of the stormwater pollution solution. Numeric pollution limits have arrived and street sweeping can be a tool in the tool box to achieve them.

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Volunteers needed to test water in Table Rock Lake

 The Lakes of Missouri Volunteers Program  is looking for volunteers to test water in the Kings River arm of Table Rock Lake. This LINK will bring up a Google map of the test site locations. Volunteers will test water annually every 3 weeks from May to September. If you are interesting in becoming a LMVP volunteer, contact Tony Thorpe at 800-895-2260 or tony@lmvp.org

Quote of the Week

Wild rivers are earth's renegades, defying gravity, dancing to their own tunes, resisting the authority of humans, always chipping away, and eventually always winning.

- Richard Bangs

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Current News Articles

For more information and to read more, Click  HERE.

Commission Proceeds with Pretreatment Project 

The Warren County Commission last Thursday voted to proceed with implementing sewer pretreatment improvements, ending a more than two-week delay after project bids were first reviewed.

Commissioners accepted the lowest bid from Warrenton-based Heggemann Inc. for $55,353 to install a bar screen system to catch clothes, trash and other items before they enter the city's sewer system. The items will then be removed by a county maintenance employee.

As part of the bid package, the design provided for a grinder - the city's preferred pretreatment system - to be installed in the future if needed.

In addition to Heggemann's winning bid and the alternate design it proposed, three other bids ranging from $57,116 to $118,600 were also received by the county.

For more information, click HERE.

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