It's not always easy getting answers on EPA rules and regulations. So, when we had questions about effluent monitoring provisions included in the Phase II NPDES Storm Water Permit Program, we went right to the source: Illinois EPA permit writer Chuck Fellman, Manager of the Auxilliary Point Source Unit in the permit section of the Division of Water Pollution Control. His group has been responsible for implementing both Phase I and Phase II of the Illinois EPA's efforts at storm water pollution prevention.
ColeParmer.com: Under Phase II of the National Pollutant Discharge Elimination System (NPDES) storm water program, who is effected?
Chuck Fellman (Illinois EPA): Phase I, which was implemented in 1992, was primarily aimed at large industry. Phase II, which must be implemented by March 2003, primarily addresses small municipalities with municipal separate storm sewer systems (MS4s), and construction sites where more than one acre of land is being disturbed. Right now it looks like Phase II will effect somewhere in the range of 700 municipalities in the state of Illinois alone—plus a handful of other entities including universities, hospitals and military installations.
ColeParmer.com: Are these municipalities mostly the new-growth suburbs surrounding Chicago?
Fellman: No, this effects communities across the state. The city of Rockford was the only municipality in the state of Illinois that was covered under Phase I. Under Phase II it is all communities in a metropolitan area with a population greater than 50,000, including communities under 50,000 that have a population density of at least 1,000 people per square mile.
ColeParmer.com: And these are the municipalities with an MS4 storm water system which must now apply for an NPDES permit covering their storm water discharge?
Fellman: Yes. They all must now apply for a general permit—the same permit will cover every municipality in the state. Except for Rockford.
ColeParmer.com: You authored this permit, correct?
Fellman: Yes.
ColeParmer.com: What did you base it on? Were there EPA guidelines?
Fellman: Absolutely. The USEPA designed a model permit for the states to use. We basically followed that permit and the accompanying regulations—as did all other states—and put ours together from that.
ColeParmer.com: One question many of us seem to have is, when you apply for a permit, is testing required? It's not very clear in the EPA literature. Is there required monitoring?
Fellman: Not when you file for the permit, no.
ColeParmer.com: Then, when?
Fellman: The Storm Water Management Program is based on the use of Best Management Practices (BMP)—which are designed to help you keep pollutants from getting into the system to begin with. And that's where your testing comes in.
ColeParmer.com: Can you explain that, please?
Fellman: BMPs are things like public education and public participation requirements, where the municipalities are supposed to be sending out brochures telling people don't pour oil in the storm sewers, don't dump your used antifreeze in the storm sewer, etc. And there's a Good Housekeeping provision requiring municipalities to watch after their public works facilities—maybe they've got a wastewater treatment plant or a city garage or what have you...they need to have Storm Water Pollution Prevention Plans (SWPPPs) and have Best Management Practices and Pollution Prevention for those facilities.
Where your testing comes in is with the Illicit Discharge Detection and Elimination provision. It requires municipalities to look for and eliminate illicit discharges into the storm sewers—such as improperly treated industrial waste or sanitary waste that should not be present in the storm water. That would require dry weather sampling to identify it and to help trace it.
ColeParmer.com: Dry weather sampling?
Fellman: Yes. You go around and check the outfalls in your system when it is supposed to be empty. That way you can determine if anything is infiltrating the storm sewers at a time when they should be dry.
ColeParmer.com: How is that performed?
Fellman: The first thing the municipality needs to do is generate an accurate sewer map. Most storm sewer maps are accurate to some degree but in older towns they are usually pretty bad. So you need to get a decent map. Then you do dry weather sight testing to see if there is any water present and you sample that water to see if it is just ground water leaking into the storm sewer or if there is sewage or industrial waste present. You can tell a lot by just looking at it in most cases.
ColeParmer.com: Then what...you trace it back?
Fellman: Yes. You track it back and get it off the system. You start popping manholes and if you find out it's coming from all over it's probably groundwater infiltration. Whereas if you've got a flow and you go up and start lifting manhole lids and up the line suddenly it disappears, then you know something is entering the system between those two manhole lids. That's the kind of thing they'll need to do.
Most cases, when these kinds of things happen, you've got older homes or older industry sites and there was a connection put in 50 years ago by someone who didn't know what he was doing—and nobody's even aware of the problem. We've got a lot of rural towns in Illinois, for example, with older homes that have septic tanks that feed into what we call a wildcat storm sewer system. Some of them will have two or three lines that go out from the house and only one goes to the septic tank—that sort of thing. And the city comes along and puts in sewers and picks up the line that went to the septic tank without knowing about the other two lines. And of course that happens in industries, too. It's usually something that someone goofed up.
ColeParmer.com: I'm still unclear about wet weather testing. What if someone dumped illegally during a storm?
Fellman: You mean if someone waited for a storm and dumped waste into the system? It would be pretty hard to catch them. We had a company in the East St. Louis area that did almost exactly that. Only they were doing it in a creek. And we finally did catch them. We got millions of dollars in fines from them. A person would have to be crazy to do that.
ColeParmer.com: But wouldn't that mandate wet weather testing?
Fellman: There is nothing to stop a city from doing wet weather monitoring. I think it depends totally on the situation. A lot of these small towns are bedroom communities with no industry. The houses are fairly new so there's not a lot of old plumbing. There is probably no reason to monitor those systems. But in areas where there's a lot of industry, somebody might want to do that testing, absolutely.
ColeParmer.com: Why doesn't the government require wet weather monitoring?
Fellman: Monitoring storm water is actually an extremely difficult thing to do. We did require it of Rockford in their permit. And they spent a bundle of money on automatic sampling equipment and getting power to that equipment and building structures to facilitate sampling at many of their outfalls. But they had so many problems....with equipment getting flooded, and vandals. More importantly, a lot of the sampling was questionable because they didn't know exactly what they'd gotten—the equipment takes one-ounce samples at prescribed intervals and you know how long it rains so you know how many one-ounce samples you should have. But sometimes they had one-third too few samples and other times too many! That's why the EPA specifically said for the first two permit rounds they really don't want to see monitoring requirements in the permit.
ColeParmer.com: But dry weather sampling is mandatory in every round, correct?
Fellman: If there is dry weather flow, and the town has reason to suspect it might be contaminated, yes. The problem is, what do you test for? Fecal coliform—bacterial contamination—is a good indicator of sewage leaks, but that also comes from birds and dogs and deer and other animals. So, you might test for chlorine; tap water is required by state law to have chlorine residual in it, so if you've got water with chlorine coming out of your storm sewer, it's very likely that came out of your water supply. Another thing that's often checked for is caffeine, because humans are about the only animals that consume caffeine.
ColeParmer.com: You might also want to test for industrial waste?
Fellman: Absolutely; if you have industry in your town you can run those tests.
ColeParmer.com: What part of the permit program establishes these monitoring requirements? To be honest I could not find mention of them anywhere....
Fellman: The NPDES II permit requires that each municipality develop a Storm Water Management Plan, and I'm going to guess that most of them will have provisions for sampling in certain situations.
ColeParmer.com: If the public doesn't understand something, can they come to the EPA for guidance?
Fellman: Certainly. We just spent 2 1/2 years putting on workshops all over the state on this program. The EPA did this in conjunction with the National Resource Conservation Service (NRCS), USEPA, the University of Illinois and the local soil and water conservation districts. We put on two rounds of workshops trying to educate people. Most of the counties in the Chicago area, they know what's going on. They're up to speed. But some of the smaller towns are just now starting to wake up about it.
ColeParmer.com: It is a complex project.
Fellman: And I'll be honest with you, we're really feeling our way along on this thing. Something like this has never been tried before. So I think a lot of the towns will be changing their programs as they go along. The Illinois EPA may be changing our way of going about this thing. I'm sure it's going to be a learning experience for all involved. Hey, the Wright brothers didn't invent a 747 on the first try...
ColeParmer.com: Perhaps that's why people are confused.
Fellman: Some of this I'm not even clear on and I've been in this business 32 years!
| NOTE: This interview is designed to provide a general understanding of the conditions and requirements for water testing by municipalities under the National Pollution Discharge Elimination System (NPDES) General Permit for Discharges from Small Municipal Separate Storm Sewer Systems (MS4s). Each state generates its own permit proceedures and permit requirements; any entity filing for an NPDES II storm water discharge permit should contact thie local EPA for specific conditions and requirements mandated by their local agency. |
