March-April 2010

Street Dirt

A better way of measuring BMP effectiveness

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By Gary R. Minton, Roger C. Sutherland

3 Comments

Phase I jurisdictions have spent, and will, in the near future, spend millions of dollars characterizing discharges from stormwater outfalls. Yet many presentations, articles, and reports over the past several years indicate the complexity of outfall sampling and biases and limitations of the sampling methods and laboratory analytical procedures.

A common objective stated for the sampling of stormwater discharges is to measure the effectiveness and progress of the implementation of various best management practices (BMPs), such as homeowner education on pesticide and fertilizer use, cleaning of public and private drain inlet sumps, street sweeping, use of brake drums with less copper, and pickup of dog feces.

Yet, given the variability of the quality of stormwater from storm to storm and from outfall to outfall, it is reasonable to question the validity of outfall monitoring as a means to measure progress. It is problematic that modest reductions—less than 50%—cannot be discerned statistically with outfall sampling. Furthermore, sampling protocols and analytical procedures will continue to change over time, bringing into doubt the validity of older data with which trend analysis is attempted. The high cost of sampling results in only a few outfalls being sampled, raising the question as to whether the few sampled outfalls are representative of the community. And how does the regulator or citizen discern which BMPs are having which effect if two or more BMPs are expected to affect the same pollutant?

In this article, we explore a radically different means to measure effect and progress: the chemistry of street dirt. If our BMPs are having an effect, it should be reflected in the chemistry of street dirt. Street dirt, rather than stormwater, becomes the integrator of community behavior. For example, if the use of pesticides is being reduced over time, it will be apparent in the chemistry of the street dirt. Collecting and evaluating street dirt has many advantages over collecting water at outfalls. It is cheaper per sampling station, and it requires a lower level of technical expertise, a simpler menu of equipment, and lesser constraints on sampling procedures and analytical holding times. There is no issue of detection limits, and it is arguably safer. The information can also be used to directly evaluate the cost and cost-effectiveness of the particular BMPs themselves, such as sump cleaning and street sweeping. Street dirt sampling can be complemented with dry and wet fall sampling as practiced by air-quality regulators. A particular BMP can be tied directly to the information that is collected.

Shortcomings of Outfall Discharge Monitoring
Many reasons are given for the monitoring of stormwater discharges. After 30 years of discharge monitoring, it is reasonable to question whether the incremental increase in knowledge is worth the cost. In an extensive examination of the state of urban stormwater management, the National Research Council (2008) stated, “Because of a ten-year effort to collect and analyze monitoring data from MS4s nationwide, the quality of stormwater from urbanized areas is well characterized.” The reference is to National Pollutant Discharge Elimination System (NPDES) Phase I permit monitoring programs.

With the passage of time, the complexities and, in turn, the cost of discharge monitoring have increased significantly as biases, shortfalls, and complexities have become known. Among these:

  • The highly variable range of concentrations observed from storm to storm requires many storms to be sampled to meet statistical requirements.
  • The number of storms required increases significantly if one is to discern only a modest change in community behavior.
  • The concentrations of many contaminants of interest are within a factor of 10 of their respective detection limits, making problematic the validity of any statistical statement regarding significance.
  • It is difficult to meet holding time requirements less than the length of storm.
  • Changes in analytical procedures over time make problematic the validity of comparing current results to past data.
  • The potential exists for contamination of samples.
  • It is questionable whether the true event mean concentration (EMC) is being measured.
  • The relevance of EMC is in question with respect to short-term toxic impact and exceedances of standards for toxic substances such as metals and pesticides.
  • There is potential bias associated with splitting collected stormwater into sample analysis bottles.
  • Automatic samplers have limitations with respect to the capture of larger sediments.
  • There is a need for highly skilled and experienced personnel.
  • The necessity of being active during inclement weather presents a concern for the safety of personnel.
  • Equipment is sometimes vandalized.     
  • Monitoring is constrained to a particular time of the year.
  • Outfalls are selected on the basis of physical accessibility and concerns about safety and vandalism, rather than whether they are representative of the community.
  • Sampling a few discharges in a community—a limit imposed by the high cost of monitoring per discharge—might not properly represent the community. (For example, the city of Seattle has about 950 outfalls and will be sampling three to comply with its NPDES permit.)
  • The efficacy of translating observed changes at a few discharge outfalls to across the community through the use of watershed loading models is questionable.

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Most importantly with respect to the evaluation of the effectiveness of various BMP programs, if a trend is discerned through outfall sampling, how does one determine the underlying cause? An observed increase in concentrations does not mean that particular BMP programs affecting that pollutant are not beneficial, because the reduction by the program may be masked by new sources. Similar statements can be made with respect to no change or to a reduction. If the sources of the targeted pollutant are multiple, which BMP program contributed to the change and at what unit cost?

Evaluation of the Individual BMP Source-Control Effectiveness
At the opposite end of discharge monitoring is evaluation of the individual program, commonly done by surveys (Elzufon 2000, Rowe and Schueler 2006). This approach relies upon surveys that identify the change in awareness and implementation of various source-control or nonstructural BMP programs. However, this approach does not effectively translate to quantification of the reduction that may occur because of the increased awareness. Cost surveys have been done, identifying the total cost of individual programs and the per capita cost (Currier et al. 2005), but without corresponding loading reductions, program cost-effectiveness cannot be measured. A third approach is to monitor sales of relevant products such as pesticides and fertilizers within a community or region. Next Page >

What Do You Think?

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jcollin

March 4th, 2010 7:08 AM PT

Excellent article. In addition monitoring the amount of sediments removed from the MS4 and roads is a fairly easy number for most public works agencies to track and can provide valuable information on pollution that was prevented. If it was removed it didn't get discharged.

rogers

March 3rd, 2010 10:08 AM PT

Hi Gordon Yes I was aware of the program you spoke of. It is an excellent example of what Gary and I are talking about. I've discussed the program with Dr. John Sansalone at the University of Florida and I'm looking forward to seeing its initial results. With water quality standards for TP on the horizon in Florida, I believe the program will help MS4s in the state better understand where they can focus their BMP dollars. Roger

Gordon

February 24th, 2010 4:53 PM PT

I concur with your recommendations. The Florida Stormwater Association undertook a program in 2002 to analyze hundreds of street sweeping samples for many pollutants. The results are shown at http://www.florida-stormwater.org/publications.htm . They are currently under taking another such study of street sediments for TN and TP concentrations for TMDL purposes.

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