Recently I was asked if there would be water monitoring costs to cities or counties because of upgrading our main Suwannee River Basin waters in Georgia from Fishing to Recreational, as we have requested in Georgia’s Triennial Review of Water Quality Standards. Here’s the answer, as best I could determine. And how you can help. For those who wonder why upgrade from Fishing to Recreational, please see the previous blog post.
Specifically the question was: would reclassifying rivers or swamp from Fishing to Recreational cause cities or counties to have to spend more money on water quality monitoring, specifically if a wastewater treatment plant had a spill, more money on water quality sampling afterwards?
The brief answer is: probably not.
Recently, I asked James A. Capp, Chief, Watershed Protection Branch, EPD. He said that for that case, there should be no change, because sampling after a spill is determined mostly by the number of gallons spilled.
Let me use some NPDES permits I have on hand to illustrate.
Here is the language in NPDES Permit No. GA0020222 for Valdosta’s Withlacoochee Wastewater Treatment Plant, first about number of gallons, then about the required sampling.
A “major spill” means:
- The discharge of pollutants into waters of the State by a POTW that exceeds the weekly average permitted effluent limit for biochemical oxygen demand (5-day) or total suspended solids by 50 percent or greater in one day, provided that the effluent discharge concentration is equal to or greater than 25 mg/L for biochemical oxygen demand or total suspended solids.
- Any discharge of raw sewage that 1) exceeds 10,000 gallons or 2) results in water quality violations in the waters of the State.
“Consistently exceeding effluent limitation” means a POTW exceeding the 30 day average limit for biochemical oxygen demand or total suspended solids for at least five days out of each seven day period during a total period of 180 consecutive days.
The critical limit is 10,000 gallons of raw sewage.
Yes, the permit also says “or 2) results in water quality violations in the waters of the State.” Maybe that (2) is invoked sometimes, but so far I’ve never seen it.
Yes, the permit also has the language about oxygen and suspended solids, but so far I’ve also never seen that paragraph invoked.
Here is what a permit holder has to do in case of a major spill (more than 10,000 gallons of raw sewage):
The owner of a POTW shall immediately establish a monitoring program of the receiving waters affected by a major spill or by consistently exceeding an effluent limit, with such monitoring being at the expense of the POTW for at least one year. The monitoring program shall include an upstream sampling point as well as sufficient downstream locations to accurately characterize the impact of the major spill or the consistent exceedence of effluent limitations described in the definition of “Consistently exceeding effluent limitation” above. As a minimum, the following parameters shall be monitored in the receiving stream:
- Dissolved Oxygen;
- Fecal Coliform Bacteria;
- Temperature; and
- Other parameters required by the EPD.
The monitoring and reporting frequency as well as the need to monitor additional parameters, will be determined by EPD. The results of the monitoring will be provided by the POTW owner to EPD and all downstream public agencies using the affected waters as a source of a public water supply.
Typically this monitoring also includes E. coli.
The amount of monitoring, and thus the cost, is not really determined by the limits for each parameter: there’s just a set schedule for five or six parameters for monitoring for a year.
So the main point is: major spills are usually determined by the number of gallons of raw sewage spilled, and the resultant monitoring is according to a schedule. Neither of these things, in the typical scenario, would be affected by stricter limits for Recreational vs. Fishing classification of rivers or swamp.
Could they be? Yes, I suppose, an NPDES permit could be written with some related changes. I don’t really know why EPD would do that, though.
Chief Capp also said that with stricter monitoring limits (for Recreational vs. Fishing), it might be possible that there would be more Total Maximum Daily Load (TMDL) limits exceeded, resulting in a need for less pollutants to get into a river or swamp. He didn’t provide any examples off the top of his head; he just wanted to be clear that it was not possible to say there would never be any additional monitoring required.
But if a city or county’s wastewater treatment is working, it’s not going to be the source of such pollutants anyway. NPDES permits require the same types and frequencies of sampling upstream and downstream of the site, no matter what the classification of the nearby water body.
Beyond that, for the water body, it’s not counties or cities that do TMDL monitoring: it’s the state.
Agriculture or miners or septic tanks might need to clean up their acts, if somebody can demonstrate that they’re the source of part of the problem. That would be at the owner’s cost, though, not owed by the county or city.
Lowndes County has a Land Application Site (spray field). The NPDES permit for that already requires testing groundwater monitoring wells to be sure groundwater leaving the spray field boundaries does not exceed state drinking water contaminant levels. So changing classification of nearby water bodies would not affect that. The definition of a major spill and the year-long followup monitoring program is the same for that Lowndes County spray field as for Valdosta’s wastewater treatment plant.
So, is it possible to say categorically that there would be no increased costs of water quality monitoring due to reclassifying rivers or swamps as Recreational vs. Fishing?
No, it’s not possible to say that could never happen.
Is it likely that there would be increased costs? It sure doesn’t look like it for the specific scenario of the question (monitoring after a sewage spill), and it’s a bit far-fetched for other scenarios, as well.
I hope that answers the question.
And I hope that counties and cities will consider writing letters to EPD supporting reclassification of the Okefenokee Swamp and Banks Lake and the rives from Fishing to Recreational. Such a change should promote clean waters, which should be beneficial in attracting visitors.
Back in March, Victoria Adams of GA-EPD wrote:
Currently, I am building stakeholder email groups by subject/comment; if there are stakeholders that you know of that would like to be included in the discussions on these water bodies, please let me know. For this list I already have your groups as well as Georgia River Network and Georgia Beer Company. Next, I will be looking at our current water quality data, as well as exisng permied facilies for each of these water bodies. Aer that, I will contact the email group to set up a meeng to discuss.
Cities or counties can write directly to:
Elizabeth Booth, Environmental Protection Division
Watershed Protection Branch,
Watershed Planning & Monitoring Program,
Suite 1152 East, 2 Martin Luther King, Jr., Dr., Atlanta, GA 30334
Individuals can write directly, or please fill out this form.
And you can help.
PS: Florida is also going through its Triennial Review, but in Florida all rivers are classified as Recreational by default, unless reclassified. All rivers in the Suwannee River Basin in Florida are already classified as Recreational, so there is nothing to do about that for Florida.
-jsq, John S. Quarterman, Suwannee RIVERKEEPER®
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