Taking out the Trash:Setting achievable trash discharge reduction goals and measuring progress...

© 2015 Contech Engineered Solutions LLC

Taking out the Trash:Setting achievable trash discharge reduction goals and measuring progress toward meeting them

StormCon 2015Austin, TX

Vaikko Allen, CPSWQ, LEED-AP

Director of Regional Regulatory Management

Contech Engineered Solutions

[email protected]

mailto:[email protected]


What is Trash?

Litter means all improperly discarded waste material, including, but not limited to, convenience food, aluminum, glass, paper, plastic, and other natural material and synthetic materials, thrown or deposited on the lands and waters of the state, but not including the properly discarded waste of the primary processing of agriculture, mining, logging, sawmilling, or manufacturing.

-California Government Code Section 68055.1

Litter is human derived trash such as paper, plastic, Styrofoam, metal and glass greater than 4.75-mm in size

-ASCE – EWRI Guidelines for Monitoring Stormwater Gross Solids


Gross Solids in Stormwater Runoff

Characteristics of Gross Solids Components

o Mass – Sediment – 30%, Vegetation – 56%, Litter – 14%o Volume – Sediment & Vegetation- 75%, Litter – 25%

Floating trash is ~80% of air dried volume and ~20% of wet mass of all trash

Percent Litter in Gross Pollutants

Land Use Mass (Air Dried Litter)

%

Volume (Air Dried Litter)

%

Mass (Wet Litter) %

Volume (Wet Litter) %

Freeway 2.6 – 3.70 23.67 – 34.30 5.9 – 13.45 14.2 – 31.15

Commercial - - 16.337.59 – 51.06

23.8410.68 - 45.90

HDSFR - - 3.772.35 – 5.90 9.64 - 51.02

Source: “Estimates of the Actual Trash Capture Effectiveness of Catch Basin Inserts Reported by the City of Los Angeles”, Roger James, February 14, 2012, Compilation of studies conducted by Caltrans, UCLA, Monash University, Los Angeles Baseline Trash Loading monitoring


Sources of Trash

Discharges from Privately and Publically Owned Storm Drains

Discharges from Small Creeks to Larger Creeks, Rivers and Flood Control Channels

Homeless Camps

Intentional Dumping Onto Banks and Into Creeks and Flood Control Channels from Private and Public Property

Wind Blown Trash from Highways and High Generation Land Uses Like Flea Markets and Sporting Events Into Channels or Creeks Adjacent to Those Land Uses

Recreational users


Nurdles and Crumbles

Styrofoam “Crumbles” Viewed as Fish Eggs by Fish and Waterfowl

“Nurdles” - Pre Production Resin Pellets Adsorb and Concentrate Toxic Chemicals



Coyote Creek - San Jose



Chesapeake Bay in Baltimore Anacostia Watershed – District of Columbia



Algalita Marine Research and Education estimates that there are 5.25 trillion pieces of trash weighing 268,940 tons circulating in the world’s oceans

Every time it rains, stormwater runoff transports more trash and debris from our urban areas into receiving waters

California alone spends $480 Million on trash control activities annually

Los Angeles River


Marine Debris Biodegradation Timeline


LA River and Ballona Creek Watersheds

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• 834 square mile watershed• 55 mile long river• 33% impervious

• 130 square mile watershed• 10 mile long river• 49% impervious


Regulatory History 1960’s Water Quality Control Plans (Basin Plans) WQO and Prohibitions Addressed Gross Pollutants EPA approved 303(d) list in 1996 with Ballona Creek and Los Angeles River impaired by trash Los Angeles River Trash TMDL

Initial TMDL adopted for Los Angeles River in September 2001, set aside in June 2006 and current TMDL adopted and incorporated in Basin Plan in August 2007 September 2016 – Compliance with “Zero” Numeric Target

Ballona Creek Trash TMDL January 2004 TMDL adopted September 2015 – Compliance with “Zero” Numeric Target

Los Angeles Region NPDES Permit Adopted December 13, 2001 and amended September 2006, August 2007 and April 2011 with Tentative Order pending Applies to 84 cities and Los Angeles Flood Control District and unincorporated areas of Los Angeles County Included Trash Effluent Limitations (Waste Load Allocations) for each entity derived from Baseline Trash Load Monitoring Program Included criteria for “Full Capture System” and for Executive Officer certification of devices Compliance with Effluent Limitations achieved if all areas served by adequately sized and maintained certified Full Capture Systems and maintenance records are available Partial capture devices (devices not certified by EO) and institutional controls (street sweeping, public education, catch basin cleaning) allowed for compliance with interim Effluent Limitations when documented by monitoring Daily Generation Rates Entities required to prioritize inlets and areas for trash generation and specified frequency of catch basin cleaning and street sweeping Detailed reporting of device installation, drainage areas, trash removed and compliance

Regulation of Trash Discharged from MS4s In Los Angeles Area


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Trash Discharge Goal: Zero

Los Angeles River Trash TMDL established that receiving waters have no assimilative capacity for trash and therefore the only defensible effluent discharge limit for trash is “zero”

“Full capture systems” established as a BMP based alternative to strict compliance with zero trash effluent limits


Full Capture Systems

Any single device or series of devices certified by the executive officer, that traps all particles retained by a 5-mm mesh screen and has a design capacity of not less than the peak flow rate Q resulting from a one-year, one-hour storm in the sub-drainage area.

The full capture system must be regularly inspected and serviced to continually maintain adequate flow through capacity.


Partial Capture and Institutional Controls

An alternative compliance pathway for those areas where full capture systems are infeasible

Primarily catch basin inlet excluders and increased street sweeping Also, product bans and substitutions, education, enforcement,

adding and covering trash receptacles, catch basin cleaning, etc. Permitees must have evidence to support any claimed reduction


2013-2014 Trash TMDL Compliance Status

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Compliance summary by method of compliance – Ballona Creek

Ballona Creek (96.7% reduction target) 3 permittees compliant 1 permittee non-compliant 7 permittees undetermined

Los Angeles River (90% reduction target) 11 permittees compliant 11 permittees non-compliant 11 permittees undetermined


Factors adding uncertainty to these estimates: Lack of uniformity in reporting metrics for partial capture and

institutional controls pathway Inadequate reporting/audit of O&M for full capture systems

Trash TMDL Compliance Status

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Self Reported TMDL Compliance Status (2013-2014)

WatershedClaimed Reduction

(%)Remaining Load (ft3)

Remaining Load (tons)*

Los Angeles River 80%11,414 48

Ballona Creek90%

1,273 5.3

*Assumes 8.4 lbs/ft3 average trash density


Receiving water monitoring not required No direct measurement of trash discharge rates has been

undertaken Indirect trash load reduction assessment is possible

o Beach cleanup recordso In-stream trash and debris removal recordso In stream samplingo Maintenance records of downstream cities

Receiving water response

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LA River Trash Cleanup

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Trash and debris removed from the Los Angeles River at the Ocean

Boulevard bridge trash boomYear Tons

2008-2009 1,090

2009-2010 9452010-2011 1,0982011-2012 1,1622012-2013 1,1252013-2014 1,200

Photos – LA River Trash Boom, Seal Beach: From LA Times 2010


Annually removes about 6,000 tons of trash and debris total including 4,500 tons from shorelines

Estimated 95% comes from the LA River

Operates a trash net downstream of the trash boom that captured 405 tons of material between 2004 and 2008

City of Long Beach


Trash and debris removed from Ballona Creek at the Lincoln Blvd bridge trash

boomYear Tons2006 382007 442008 462009 272010 212011 22012 42

Ballona Creek Trash Cleanup

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Coastal trash clean-up data near Ballona Creek Location

Total Items Collected2010 2011 2012 2013

Dockweiler State Beach at Imperial Hwy 8,943 19,676 11,192 6,120

Dockweiler State Beach at Playa Del Rey 9,552 10,980 7,991 2,044

Venice Beach at Rose Avenue 8,914 1,197 10,243 1,364

Total 27,409 31,853 29,426 9,528

Prior rain year precipitation (in) 16.36 20.2 8.7 5.93

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Full capture system operation and maintenance issues Full capture system design and deployment issues Trash entering receiving waters through alternative pathways

Factors contributing to the gap

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Photos: LA Times


Full Capture System Performance

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Direct Screening vulnerabilities• Over $100M spent on catch basin level controls in the region• Evidence mounting that “direct screening” systems are prone to clogging and bypass• Widespread catch basin insert replacement required after initial few years of service• Operation and maintenance costs can be exorbitant if done as needed in high trash

generation areas

Solution:• Adjust inspection frequency based on historic observations• Maintain on-line systems when 25% full or when screen in 25% blocked• Clean the screen at every maintenance event• Require photo documentation of inspection and maintenance


Full Capture System Sizing

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Issue: The full capture system standard requires systems to be sized to treat runoff from the 1-year, 1 hour rain event• BMPs in catchments with shorter times of concentration are undersized• BMPs in catchments with longer times of concentration are oversized

Solution:• Use the actual time of concentration of the catchment area• Reference the NOAA point precipitation data series for local rainfall intensity data


Issues: Permittees tend to focus on publicly owned catch basins Windblown trash, animal vectors are difficult to control Homeless encampments in waterways, direct dumping are

significant contributors

Solutions: Include private drains, consider end of pipe systems that can

capture all upstream inlets Perform MS4 discharge monitoring Coordinate with public service agencies to reduce residency

in waterways

Trash from “other” sources

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Issue: Receiving water monitoring has not been conducted, so there

is no direct evidence of progress

Solutions: The LA River and Ballona Creek Trash TMDLs were amended

in 2015 to include receiving water monitoring In stream surveys with trash nets and plankton nets have

been conducted in the past and can be resumed Surface Water Ambient Monitoring Protocol (SWAMP) for

“Rapid Trash Assessment” provides a quick and repeatable means of gauging progress

Receiving Water Monitoring

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More robust maintenance records should be collected and provided on request including before and after photos

Maintenance frequency should be customized based on inspection results

Compliance should only be claimed when BMPs remain in good operating condition

Partial capture system crediting should be checked with receiving water monitoring

Compliance Reporting

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Efforts in the Los Angeles area to control trash are commendable and are having a significant positive impact

The “full capture system” compliance pathway is a viable alternative to showing “zero trash” in receiving waters but could be improved

Beware of long term O&M costs and challenges Some trash sources are not controllable via stormwater

programs There is no substitute for receiving water monitoring Program longevity and funding depends in part on public

support which requires demonstration of results

Summary

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Taking out the Trash:Setting achievable trash discharge reduction goals and measuring progress...

Environment

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