Stormwater pouring into our rivers, creeks and streams can pollute, erode and often render them unfit for human contact. Unfortunately, that goes for our beloved local streams as well. Also unfortunate is the fact that EPA and DC bureaucrats at times must be prodded to inform the public better and act sooner. There is something we can do about it, however, and the time to act is now.
Mary Beth Ray loves Soapstone Creek. She walks her dog on the Soapstone Valley Trail that crisscrosses the creek. She also has observed degradation of a bucolic creek and valley and fragile ecosystem in the midst of city life.
Ray, who for the last four years served as advisory neighborhood commissioner for ANC 3F03, has prodded DC government agencies to define and remedy problems so that people of all ages might safely enjoy Soapstone. In December 2016, she and ANC 3F04 Commissioner Sally Gresham drafted an ANC resolution (approved unanimously) Ray transmitted this month to the federal government.
Commissioner Ray asked the U.S. Environmental Protection Agency (EPA) to require more DC protection for Soapstone Creek.
She responded ahead of EPA’s January 17 deadline for comments on a proposed new, 5-year permit under the National Pollution Discharge Elimination System. That permit would allow and regulate discharges from 566 outfalls citywide from separate storm sewers. More than 170 of those outfalls discharge into Rock Creek directly or indirectly, and six discharge stormwater into Soapstone Creek.
One of the largest outfalls is just south of Albemarle and 32nd Streets, NW and west of Soapstone Valley Trail’s trailhead, 40 feet below the street.
ANC 3F’s disturbing observations about this outfall include:
Expressing frustration, Commissioner Ray wrote to EPA that citizens need effective, transparent monitoring, “timely solutions, holistic DC agency efforts, and prompt remediation.”
Regrettably, EPA’s bureaucracy has proposed changes in the wrong direction – proposed new permit provisions which would give local stream lovers like Ray less information and less action when they need and want more.
Retain and expand narrative annual reports for separate storm sewer system
Incredibly, EPA proposes to eliminate the requirement for a narrative annual report by DC and, in its stead, would get a perfunctory “check-the box” formulaic template. That template, appended to the proposed permit, would do little to inform the public.
A narrative annual report gives DC public servants an opportunity to explain measures taken or attempted, what seemed to work and what did not.
Consider what DC’s 2015 Annual Report reveals to the public about Soapstone Creek and the separate storm water sewer system (which serves two-thirds of our city):
There were only six monitoring stations, of which one was at Soapstone Creek, adjacent to the large outfall pipe south of Albemarle and 32nd Streets, NW. Average results for DC’s three wet weather samplings show that Soapstone Creek was highest in E. coli bacteria of these six monitoring stations.
DC had previously reported to EPA and Congress that high E. coli “impair” Soapstone Creek (that is, violate water quality standards).
Speed up the bacteria study
Under EPA’s proposed permit, DC is to undertake a detailed study of bacteria levels in Soapstone Creek and similarly impaired streams but not make it available to the public until June, 2019. (Proposed Permit page 37.) While requiring a study is welcome, it is years overdue for Soapstone Creek. Why should we have to wait at least two summers more to learn the causes and consequent risks to people who crisscross this creek while enjoying bucolic Soapstone Trail? EPA should speed up this timeline.
Improve water quality monitoring, but don’t allow end of Soapstone Creek monitoring
At least ten MS4 watersheds drain into Rock Creek alone (MS4 refers to “municipal separate storm sewer system”). But only two have been monitored in recent years: Soapstone, with a large drainage area, and Walter Reed/Fort Stevens, with a small one.
EPA anticipates that DC will adding a few more locations, including Broad Branch, a good addition, except that DC would eliminate Soapstone Creek (proposed permit page 33, Table 9). EPA should not tolerate substituting Broad Branch for the Soapstone Creek monitoring station which is adjacent to the outfall south of Albemarle and 32nd Streets NW. That would block our assessing local improvement (or lack of it).
Under EPA’s proposed permit, DC would monitor most streams during rain storms only three times a year. More frequent water quality monitoring, particularly for such key indicators as dissolved oxygen, biochemical oxygen demand and bacteria levels, could give us some early warning as to presence of gross sewage pollution (for example, due to forbidden cross-connection of sanitary sewage lines to separate storm sewers).
This article focuses on local issues. Similar issues arise all over for DC’s many MS4 outfalls. See the map below from DC’s 2015 MS4 Annual Report.
EPA should require DC’s MS4 Annual Reports to identify and map every MS4 watershed in DC. Strangely, DC’s 2015 report showed the combined sewersheds (in Figure 10 at page 69) instead of the separate sewersheds.
Moreover, Rebecca Hammer of the Natural Resources Defense Council (NRDC), tells me that she is preparing NRDC comments which will argue (among other things) that EPA’s proposal would set an overall storm water management target which is too low.
You can send your comments on or before January 17, 2017 to:
Elizabeth Ottinger (3WP41)
NPDES Permits Branch
US EPA, Region III
1650 Arch Street
Philadelphia, PA 19103
Public servants committed to protecting the sum total of DC waterways can overlook that every stream segment in each neighborhood counts to build, hold, and deepen popular support for environmental programs. Citizens need facts and DC’s alternative options and priorities, goals and timetables. Federal regulators have not yet required DC to inform citizens enough to enable wise debate.
Contact EPA about its proposed permit before January 17. Afterwards, we can also contact DC elected officials.
Marchant Wentworth and Rebecca Hammer provided valuable information and critical insights.
For more information
All the EPA documents, including the draft permit at https://www.epa.gov/dc/notice-intent-extend-public-comment-period-draft-phase-i-ms4-permit-district-columbia
DC DOEE documents, including DC’s 2015 MS4 Annual Report and 2015 Annual Report Attachments (and more) at http://doee.dc.gov/publication/ms4-discharge-monitoring-and-annual-reports
ANC 3F resolution of Dec. 20, 2016, http://anc3f.com/wp-content/uploads/2017/01/Albemarle-and-32nd-Repairs-and-Improvement-Resolution-signed.pdf