Figure 7-3 The origins of point source pollution are distinct and identifiable; hence a point source also is called an end-of-the-pipe source. Photo: Barbara Tellman.

NPDES permit conditions and water quality standards are ultimately based on criteria developed by EPA. These criteria are supposed to accurately reflect the latest scientific knowledge regarding such matters as the effects of pollutants on the health and welfare of humans and wildlife; the effects of pollutants on biological communities; and biodiversity for varying types of receiving waters.

An important purpose of regulation is to protect designated uses. An established use is not easily changed to a less protective use. Such a change can be made, however, through the “use attainability analysis” process in which the applicant must prove that the existing protected use does not actually exist in the stream.

Non-point Sources

Figure 7-4 Rainfall flowing over urban surfaces picks up various constituents and forms urban runoff nonpoint source pollution.

Non-point source pollution is pollution that comes from several diffuse sources, not through a specific discharge — e.g., grazing. It is usually regulated through Best Management Practices (BMPs), which are guidelines developed through consultation between ADEQ and the affected industry. BMPs are intended to achieve a specific water quality goal, rather than mandating specific prescribed conditions. For example, Arizona has BMPs for grazing. The business or industry then is required to meet performance-based standards.

NPDES Permits.

One section of the law sets requirements on industries and local governments to abate pollution. The EPA issues NPDES permits to entities that discharge to “waters of the United States.” (This is defined very broadly.) Permit conditions are set according to federal requirements, but with specific requirements often based on local conditions. The permits are for a specified period of time, but are renewable. Sometimes the conditions are changed when the permit is renewed. An example of an entity with a NPDES permit in Pima County is Pima County Wastewater Management Department.

Stormwater Permits

Stormwater runoff from urban areas is a major non-point source of pollution in watercourses. Arizona, with its dry washes and months without rain, experiences special problems with runoff. Pollutants such as oils settle on roads, and the infrequent rains allow pollutants to accumulate. During summer storms, many streets fill with water that rapidly drains to washes and ultimately to rivers, carrying large amounts of pollutants that have collected on the streets. The daily news often contains warnings to drive carefully during the first major summer rain because of oil slicks on the streets. Also insecticides, cleaning fluids and other domestic pollutants might be present in stormwater, as well as industrial pollutants, although these are more carefully controlled than domestic pollutants.

Pollution from urban stormwater runoff is very difficult to control since it comes from thousands of sources and enters washes and rivers in many different ways. As awareness of stormwater quality problems increased, Congress directed EPA to develop regulations requiring large cities to establish programs to control urban runoff. EPA regulations considered urban population figures to determine which cities needed a NPDES permit. Both Tucson and Pima County fit the criteria for needing a permit. The county submitted a two-part permit application, with the first part submitted in 1991 and the second part in 1993. The city filed a storm water permit application with EPA in 1992 and in 1998. Both city and county permits were approved.

To obtain a NPDES permit, an applicant must address various EPA concerns. Measures must be taken to control such activities as illicit connections and illegal dumping to storm drains and to control runoff of pollutants from municipal landfills, industrial facilities and construction sites. The applicant also must inventory land uses to determine the quantity and quality of discharged water and develop a management plan for stormwater runoff. This plan involves identifying problem areas and working out strategies and practices to reduce the flow of pollutants into bodies of water. As part of the plan, the applicant must describe what already has been done to eliminate pollutants from stormwater runoff as well as what new efforts will be undertaken to further control such pollutants.

Pima County’s permit requirements include street sweeping, land development controls, a household hazardous waste program and a stormwater sampling program. The county also advises businesses and construction personnel about stormwater regulations.

The City of Tucson has an ongoing Stormwater Master Plan (TSMP) incorporated into its NPDES permit. The TSMP emphasizes the preservation of naturally vegetated watercourses to improve water quality and urges residents to harvest rainwater. Retaining stormwater on property reduces runoff flowing over streets and paved surfaces and picking up various pollutants. Other aspects of the permit include conducting site inspections of private developments on five acres or more. Also, the city will inspect industrial sites that are required to obtain NPDES permits, to ensure they are in compliance. The city also monitors stormwater quality problems in the community to anticipate and prevent problems before they occur. The city also is emphasizing public education or outreach, to make people aware they have a personal effect on stormwater quality.

TREATMENT PLANT FUNDING

Another section of the Clean Water Act provides financial assistance for constructing municipal wastewater treatment plants. The law has been more successful in controlling biological pollutants than in dealing with toxic materials. During the 1980s, Congress provided funding through EPA to build wastewater treatment systems. Most of Arizona’s large treatment plants were built at least partially with federal subsidies which helped pay the costs of growth. In the 1990s, these funding sources dried up as Congress cut back on federal spending. The program changed to a “revolving fund” which provides seed money for loans to communities for wastewater treatment. The loan payments are in turn made available to other communities as loans to continue support for building their wastewater treatment facilities.