A Measure of Prevention
According to the year 2000 census report, 79% of the United States population now resides within urban areas. The National Pollutant Discharge Elimination System (NPDES) Phase I and Phase II permit processes, with their emphasis on controlling nonpoint-source pollution from these urban areas, represent an attempt to address the environmental effects of the current reality: It is not just the exceptional, large-scale, and industrial activities but also the everyday practices and habits of millions of individuals in their communities across the country that are gradually degrading our water resources. The NPDES program mandates that urban communities regulate and control what enters into the environment along with the flow of stormwater.The USEPA administers NPDES programs on a regional basis; however, in most instances, the states within each EPA-designated region in turn administer their respective stormwater pollution prevention programs. Under the states’ NPDES permitting authorities, each community or municipality covered is required to develop its own stormwater-quality management plan. These plans contemplate a wide range of possibilities, each appropriate to the environmental, social, and economic conditions within their respective locales. Using the 10 EPA-designated regions as a rough guide, we will explore the implementation of NPDES-related stormwater pollution prevention programs across the country. This first installment provides a brief look at four diverse communities in the southwestern area of the country, in the area the EPA designates as Region 9 and which includes the states of Arizona, California, Hawaii, and Nevada. This series of snapshots is not intended to convey the full range of possible responses to pollution control through NPDES, but only to share a range of experiences and programmatic approaches enacted locally to protect the quality of the nation’s water as a whole.A Head Start in California
Many of the smaller municipalities in California got a head start in NPDES compliance. They were issued NPDES permits during Phase I of the program in the early 1990s, a decision Phil Bobel, manager of environmental compliance for the City of Palo Alto, CA, believes was made at the state level to avoid confusion of conflicting mandates across contiguous municipalities in highly urbanized parts of the state. With the goal of pollution prevention, the EPA suggests street sweeping as one of the recommended “good housekeeping” practices associated with NPDES; Bobel believes that is a good idea. “We know for many pollutants the principal source is the automobile. There are too many cars in California; they are polluting not only the air but also the water.” However, Bobel is not entirely comfortable referring to street sweeping as a pollution prevention practice. “It’s difficult to control what goes out on the streets,” he says. “The pollution control results of the program are difficult to quantify because we don’t have good data measuring what percentage of pollutants are removed by the practice. Street sweeping is more of a cleanup after the fact of the pollutants that have been introduced. Nevertheless, it represents a big part of what we do.” Street sweeping operations had been initiated in Palo Alto many years before the implementation of NPDES, not because of laws mandating this specific practice, but initially for the care and grooming of Palo Alto’s 50,000 street trees. According to Bobel, the city began street sweeping as a beautification measure, as well as to prevent flooding by keeping the storm drains clear of leaves. Dave Aro, manager of maintenance operations for the City of Palo Alto, says, “Street sweeping is a 24-hour operation, six days a week, stopping only for “˜spare the air days.'” (These are days when smog levels run exceptionally high in the San Francisco Bay Area). The entire city is swept on a weekly basis, and heavily used downtown areas are swept almost daily. Aro says the city’s fleet of six sweepers includes both mechanical broom sweepers and some newer regenerative air sweepers. The department, he says, is moving toward the regenerative designs and has even deployed a compressed natural gas (CNG)–fueled sweeper, for which Aro is very enthusiastic. “We made the choice not to pollute the air while we clean up the streets,” he says, adding that he believes this CNG unit “runs even cleaner than diesel.”
Unintended Benefits
Though the street sweeping program in Palo Alto was initially intended to prevent localized flooding with the start of the spring rainy season, there have always been other environmental benefits. Each fall the city collects 2,400 tons of leaf debris from its streets; Bobel says this debris would otherwise end up in streams and ponds and would eventually find its way to the San Francisco Bay. In many areas of the country, he says, this mass of biological material would pose a nutrient-loading threat. “However, in our area, because San Francisco Bay is not believed to be nutrient limited, we’re less concerned about nutrient loading than we are about biological oxygen demand.” He says that if the decaying leaves were to become trapped in certain localized areas such as ponds, choked-off streams, or storm drains, they could deplete enough oxygen as they decay to have negative impacts on the ecology of the Bay. Street sweeping, he says, takes care of this problem. “The street sweeping program did not originate for that purpose, but it does address it.” He notes that as a side benefit, “80% of the leaves collected can later be used for composting.”
Steve Miller, fleet manager for nearby Mountain View, CA, which shares the San Francisco Bay watershed with Palo Alto, has a similar high regard for the efficacy of street sweeping. But he adds that the capabilities of newer, regenerative air sweepers make pollution control through street sweeping more efficient than ever. “You’re able to pick up anything from talcum powder to bricks. A mechanical sweeper will not do that. They tend to spread around the small material and throw the big material up inside the hopper, and what you’re left with is a buildup of fine material on the streets. A lot of cities, then, traditionally wash their streets down, and of course, that washes all the fine material, including the asbestos and the heavy metals from brakes and from vehicle exhaust, into the storm drain system and into the bays or rivers.” He adds, “We were one of the first in the San Francisco Bay Area to buy the regenerative sweepers, and since then almost every city in the Bay Area is buying them exclusively.”According to Miller, regenerative air sweepers move more air, over a wider head, and the machines have a greater capacity. He says, “They’ve even come out with a larger machine, the Schwarze A9000, which can collect 9 cubic yards of material.” The mechanical sweepers the city had previously used had a capacity of only 4 cubic yards. “We’ve done numerous tests, and other cities have as well, and the Schwarze always comes out on top. It carries 440 gallons of water, which is more than most of the others, so you can sweep longer without the operator having to stop to take on water. All these things are important for sweeping cycle time. How fast can you pick it up? How often do you have to stop? How often do you have to dump? And how much does it carry?“Miller says the manufacturers have been very responsive to suggestions from users in the field, and that he collaboratively had the opportunity to help develop several beneficial design features: “Schwarze incorporated many of our suggestions.” He says one of the challenges of the regenerative air technology results from the intensive compression and compacting of the material within the collection hopper. “The debris gets packed into the sweeper so tightly that it won’t dump. If you can, imagine 7 yards of leaves all packed in the back of the truck and they won’t come out. I worked with Schwarze to completely redesign the configuration of the door so when it opens it all comes out much more quickly and easily, and that was incorporated into the new A9000 unit, which most of the cities around here are buying now.”He says mastering all the capabilities of the regenerative sweepers requires significantly more training than did the older mechanical broom sweepers, but, he adds, “They perform better over a wider range of operational conditions. If you know what you’re doing you can do a pretty good job in every circumstance.”Seaside Diversions
Down the California coast in the City of Imperial Beach in the San Diego Bay area, stormwater managers face a different set of concerns. As environmental manager for Imperial Beach, a seaside community whose major attraction is its beachfront, Todd Snyder says during the months from May through September the city must monitor water quality daily at the outfalls to ensure its safety for recreational activities. In addition, the city must contract with laboratories when necessary for more in-depth analysis of its samples. Snyder says the city has installed diversion systems in its stormwater system to direct low flows, with highly concentrated pollutant loadings, away from the coastal outfalls and into the sanitary sewer system for treatment.However, like Miller and Bobel, Snyder also attributes much of his concern over urban pollution to the automobile in its various stages of operation or maintenance. He is also concerned about other commonplace sources of pollution that arise from business practices such as restaurant refuse. He says the biggest step a municipality can take to prevent pollution is public education. “The most important part is to get to a level of knowledge where your residents understand the distinction between the stormwater system and the sanitary sewer system.”From the Backyard to the World
A central component of the Imperial Beach approach to stormwater quality, Snyder says, has been the city’s inspection program. “We’re a relatively small city, so we do a lot of canvassing through the area, a lot of drive-by surveillance, and we’ll stop and talk to people who we see are engaging in activities that are contributing pollutants. We also have inspection programs that help us pinpoint when these things are going on.” Education alone can’t resolve all of the issues. Snyder says the city operates an aggressive in-house preventive maintenance program to prevent leaks from city-operated vehicles. It also has a process to ensure that city vehicles are washed in special wash bays to prevent runoff from entering the storm drain system. Although residential car washing is exempt from regulation under Imperial Beach’s permit, he says the inspector does go out to encourage individual residents to have their vehicles washed at commercial facilities, or to pull their cars onto their lawn for washing. He says that through efforts such as these, “Residents and business operators are becoming more aware of how their activities affect water quality.” However, he says Imperial Beach shares the San Diego Bay watershed with communities across the border in Mexico, giving the challenge international dimensions over which he says his program has no control. With runoff from both sides of the border mixing in waters along the coast, Snyder says, it’s even difficult to give a precise assessment of the progress of pollution control efforts in his own municipality. “Negotiations over those issues,” he says, “are going to occur on a much higher level.”Infrastructure Maintenance
Proper maintenance of infrastructure can play an important role in reducing the exposure of receiving waters. By using in-house crews and capabilities, Snyder says, Imperial Beach has set “a goal every year to clean every storm drain in the city between the summer months. That amounts to over 100 catch basins and up to 5 miles of drainpipe.” He adds that this cleaning effort is “most effective if you get in there before the first rainfall and clear out the debris.”Rick Lewis of American Hydrovac is also a proponent of routine storm drain cleaning. “The last thing you want is for storm drains to become anaerobic,” he notes.His firm sells HiVac Aquatec combination machines. “The more regularly you clean the drains, the less chance it will become hazardous,” he says. “In addition, vector studies have shown that female mosquitoes will fly 1,000 feet down a storm drain to have their young. The longer debris sits, the more likely it is to become a nesting area for mosquitoes and pests. Then during the next storm it washes out as a much more potent pollutant than when it went in there in the first place.” Lewis encourages municipalities to invest in the capability to clean storm drains on a regular basis, ideally four times a year. He says the majority of larger communities where his firm operates already have a combination truck or a small jetter that they can use for this purpose. While the cost for the combination truck is about $205,000, he says small cities have made it affordable by collaborating to arrange lease-purchase deals over the seven- to 10-year serviceable lifespan of the vehicles. However, he suggests there are also options for municipalities with tighter budget constraints. “For about $35,000, they could invest in a unit such as the XVAC, which is a vacuum trailer that has a 500-gallon capacity. That would at least give them some capacity for jetting to dislodge things, and then vacuuming for anything that came back toward the unit.”A New View“
We have a wastewater crew dedicated to waste drainage who also maintains the storm drain inlets,” says Dave Serge, utilities services manager for Mountain View. The crew of three work with a Vacon combination truck clearing storm drain inlets and pipes several times a year. But the program has also developed some innovative approaches to maintenance.For example, Serge says Mountain View has initiated a program to conduct video inspection of its storm drain system. While TV systems are commonly used to evaluate sanitary sewer systems, he says it is unusual to see them used on storm drains. “We’ve TV’d 30% to 40% of the system over the past five years. We’ve been able to detect sand buildups, root infiltration, and laterals improperly tapped into the system. This enabled us to go in and change the methodology we used for cleaning. In one case,” he says, “we had settling of a road above a storm drain. We TV’d the storm drain using sonar and found a void above the pipe. We injected the cavity with grout, and that saved us from having to excavate.” The video system he uses is equipped with GPS and the cost to contract the work is about $1.20 per foot of pipe.So far, the Mountain View stormwater program has examined about 15,000 feet of pipe using this system. But even the emerging technologies, Serge says, may eventually pose challenges for stormwater managers. In response to regulations, he says, “We’re seeing a lot of CDS units going in on private property as developers try to meet their NPDES post-construction stormwater obligations. But it’s not clear that the property owners are geared up to maintain them.” As a result, he says, “There may come a time when there may be a strong push to have the city come in and maintain them.”Getting Organized
While the larger cities and those along the coastal areas have long been active in water-quality issues, some smaller inland communities are building brand-new stormwater-quality programs. “We’ve had a stormwater department for only a few years, and right now we’re working on ordinances to be able to enforce the policies we’ve been coming up with,” says Eileen Hamlin of the Flagstaff, AZ, Stormwater Department, who says her department received its first stormwater permit under NPDES Phase II. Flagstaff, she says, is a city that “bears few comparisons to others.” Considered a gateway for tourism to the Grand Canyon, it stands isolated in high desert. It is an arid environment dotted with Ponderosa pine with few permanent streams. In fact, the waterways that do exist, referred to locally as washes, are dry most of the time. When it does rain, “It rains hard,” says Hamlin, adding that “Flagstaff can expect 7 inches of rain per year, not spread out over 12 months but typically in brief storms.” She says these brief storms, known as monsoons, are typically characterized by “microbursts where parts of the city experience a huge downpour, while other areas get no rain at all.” Nevertheless, according to Peter McCullough, environmental manager for the city, wildlife such as blue heron can “occasionally be found within a few of the largest of the washes.” He says the idea of a stormwater-quality program in a place like Flagstaff may sound like an unusual proposition. “People often think of it as really dry, but when you go for a month or two with no rain, that’s when pollutants really build up, so it’s important to keep it as clean as possible.” Diverse Issues, Common Solutions
Hamlin believes it was not leaf fall but snowfall that historically provided the rationale for Flagstaff’s street sweeping program. The city, she says, receives about 100 to 110 inches of snow each year. The snow melts very quickly, leaving the roads covered with the cinders placed there to improve traction during icy conditions; the sweepers are employed to remove the cinders. However, the sweepers continue to operate routinely throughout the year and play an important role in pollution control efforts. Hamlin says the Streets Division has four full-time mechanical Broom Bear sweepers and one backup. “They each have a quadrant of the city to keep clean. We sweep residential areas bimonthly, arterials weekly, and the downtown area is swept Mondays though Fridays.”She adds, “The same division also does drainage maintenance, signing, painting, sidewalk replacement, asphalt repair overlays–they have quite a comprehensive program.” Hamlin says programs in many city departments and divisions play a role in stormwater quality. “We have an “˜adopt a wash’ program as well as a stream team program, managed by Environmental Services. They have 40 different volunteer groups who go out to the washes and do litter cleanup projects.” She says Environmental Services and the street maintenance function within Public Works work closely with the Stormwater Department, which is officially organized separately within the Community Development Department. “Some people think we should be in Public Works since we have an operations element to our program, other people think we should be in the Utilities Department because we have a utility element to our program, and yet we do grading inspections and final drainage reviews–that’s a piece of what happens in Community Development. But there’s any number of places where you could put a stormwater program.” She says these complex relationships between the departments work smoothly, “partly because we’re a small community and everybody knows everybody else.”Money Matters
As with many public policy mandates, NPDES compliance can present a funding dilemma for municipalities. In Palo Alto a small fee is levied on all property holders, with a sliding scale for larger parcels. “Stormwater is a relative newcomer to environmental programs,” says Bobel. “We have a special fee, fairly small, which mostly covers repairs. It is not enough for pollution prevention or treatment, not enough to do all the things we’d like to do.” However, Bobel says it is often not useful to separate out the cost of stormwater programs from the city’s many other operations. He says, “Our program is built up from street sweeping and elements of other programs, some of which were ongoing and others which didn’t exist before. We have not tried to add that up to say what the total costs for stormwater would be, because that would make it appear that there was this whole new cost area for government, and that’s not the case.“Dave Serge of Mountain View says there are numerous ways to consider funding for stormwater programs. “When you first start out, as long as you have a good nexus as to why the charges are where they are, then people are pretty reasonable.” He says there are multiple benefits to consider as well, even when you look at a specialized activity such as street sweeping. “The drivers are out there, and because they’re moving slowly over the pavement they have a chance to observe things: problems with the pavement, cars that have spilled oil, graffiti, abandoned shopping carts, street lights that are out. It’s another set of eyes and ears on the street.” After three years of research, discussions, and community outreach, Flagstaff finally settled on a stormwater utility fee as a funding mechanism for its programs. Hamlin says a rate increase, enacted in June 2006, has provided the city with the opportunity to target drainage improvement projects. “The funding allows us to implement some of the stormwater action plans that we’ve been looking forward to for a long time.” McCullough agrees, adding that Flagstaff has invested in some oil and water separators for its maintenance operations and that it is considering upgrading deicing facilities at the airport. But for now, he says, “A lot of it is behavioral, like at a vehicle shop getting them not to store paint outside in order to prevent spills that eventually end up in the washes.” Phil Bobel amplifies the importance of the behavioral component; he says Palo Alto’s stormwater programs have had their greatest success through collaborative efforts, when the target group is convinced there is a worthwhile goal.“Stormwater is largely a low-tech program. It’s all about people and their practices. But,” he adds, “it’s not just telling people what not to do but always talking about what they can do. It’s changing people’s practices from one set of relatively low-tech practices to a different set of relatively low-tech practices.”The next installment in this series will explore the response to NPDES and good housekeeping practices in EPA Region 5, focusing on municipalities surrounding the Great Lakes.