Comments on October 31, 1996 RPM Meeting Minutes Regarding
Stormwater Runoff Monitoring Issues

February 3, 1997

Julie Roth, Exec. Director
DSCSOC
Route 2, Box 2879
Davis, CA 95616

Dear Julie:

Please find presented below my comments on the draft October 31, 1996 RPM meeting minutes.

On page 5, under "Stormwater Monitoring Program," the statement is made in the last two sentences,

"DSCSOC (Lee) stated that the bioaccumulation and fish aquatic test results will be the best indicator of a problem. If these studies do not show a problem, then we can stop monitoring, and we can conclude that the site is not contributing to the problem in the San Francisco Bay."

That statement as presented is not clear on the issues that need to be considered in reviewing it, nor does it represent my discussion of the issue. First, it should be "aquatic toxicity test," and not "fish aquatic test." The second issue is with respect to the statement, "If these studies do not show a problem, then we can stop monitoring....". That statement represents a significant abbreviation of the points I discussed which could mislead reviewers of the minutes into believing that I said there would be no need for further monitoring of any type. This is not what I said, nor is it appropriate. This issue has to be addressed in the context of stopping monitoring for the constituents in the runoff waters which are of concern because of potential bioaccumulation and aquatic life toxicity. This does not mean that there would be no need for further monitoring at the site for aquatic life toxicity and bioaccumulation. In fact, as I have discussed, a properly conducted bioaccumulation and aquatic life toxicity monitoring can be used to cut back on the routine runoff monitoring. The bioaccumulation in aquatic life toxicity monitoring will have to be done at least for a number of years after the site is stabilized once it has been remediated and a number of years of monitoring shows no problems with aquatic life toxicity and bioaccumulation. As planned now, this will likely be somewhere several years after the year 2000 if the site is, in fact, remediated in accord with current DOE plans.

I also pointed out that there may be regulatory requirements at the federal or state level that require mechanical monitoring of chemical constituents in stormwater runoff simply as a process of putting data into the file cabinets. However, some regulatory agencies are beginning to recognize that bioaccumulation and aquatic life toxicity testing, if properly done, can screen for real water quality problems and thereby eliminate the need for routine mechanical chemical constituent monitoring in runoff waters. The Water Resources Control Board's and several regional water quality control boards' stormwater runoff monitoring program requirements are being changed to recognize the fact that constituent monitoring in runoff waters is not a reliable approach for assessing water quality impacts. In the San Francisco Bay region, the NPDES stormwater dischargers are being required by the Regional Board to shift their monitoring from end-of-the-pipe/edge-of-the-pavement to receiving waters. This is the result of the fact that the past five years of data on constituent monitoring in runoff waters have provided little in the way of useful information that enables the stormwater managers and the regulatory agencies, as well as others, to assess the real impacts of stormwater runoff on receiving water quality.

The same shift in monitoring approach has been endorsed by the Santa Ana Regional Water Quality Control Board in connection with the Evaluation Monitoring program that I have developed for the evaluation of the impact of stormwater runoff on the water quality of Upper Newport Bay in Orange County. The Regional Board and the County have accepted my recommendation of focusing the monitoring resources on receiving waters through toxicity testing and bioaccumulation and have waived the requirements of mechanical monitoring of stormwater runoff for a suite of constituents that are of concern because they either have the potential to cause aquatic life toxicity or could accumulate in aquatic life tissue to excessive levels. If anyone has an interest in more information on the program that has been developed in Orange County, please contact me.

I wish to point out that I do not know if the US EPA's Superfund regulations or DTSC's regulations would allow this approach for the LEHR site. This monitoring approach will have to be evaluated by US EPA Region IX and DTSC. It would also be necessary to check with the Central Valley Regional Water Quality Control Board to be certain that they would support this approach. I know from discussing this with some of the Board staff they would be strongly supportive of it.

If there are questions on this matter, please contact me.

Sincerely yours,

G. Fred Lee, PhD, DEE
Technical Advisor, DSCSOC

GFL:oh