SAN ANTONIO – The U.S. Army Environmental Command’s Water Management Program safeguards stormwater by meeting environmental standards designed to reduce pollutants discharged into waters of the United States.
Stormwater is water from rain or snow melt that is not absorbed into the groundwater supply and allowed to flow over impervious surfaces collecting trash and pollutants, which are then deposited into storm drains and eventually into our creeks, streams, and rivers without benefit of treatment.
USAEC’s team of water subject matter experts works diligently to help installations understand and comply with federal, state, and Department of Defense requirements.
Suzy Rohrs, a water subject matter expert in the Compliance Branch of the Environmental Quality Division, works primarily with the Environmental Performance Assessment System program. This program evaluates environmental risk and compliance points at installations, providing an external assessment of how environmental programs meet requirements of regulatory agencies.
“Our team goes in and reviews National Pollutant Discharge Elimination Systems permits and associated plans to determine if they are the right size and scope for the installation,” said Rohrs. “We make sure they are in compliance with applicable regulations and determine if their compliance footprint can be downsized.
“This centralized approach helps installations avoid compliance violations, which can be costly and time consuming to manage. Violations can reduce readiness by requiring an installation to use resources to respond to compliance issues that should have gone toward mission readiness.”
A NPDES permit allows municipalities or facilities to discharge a specified amount of pollutants into a receiving body of water as long as they meet the permit conditions. The permits fall into two primary categories: general and individual.
A Municipal Separate Storm Sewer System is an example of a general permit, whereas an individual permit is specific to an individual facility.
“We continue looking for ways to streamline the process to make it more manageable for the installations,” said Rohrs. “For instance, some installations were permitted as industrial-like facilities, but they didn’t meet the Standard Industrial Classification definition for an industrial stormwater permit.
“Industrial stormwater permits carry resource intensive requirements for inspections and analytical sampling. Our analysis indicated these facilities should have received an MS4 permit and they were already meeting those requirements.
“Negotiations with the regulators allows USAEC to ensure the installation is correctly permitted and reduces the compliance burden.”
In addition to working with installations one-on-one, USAEC works on large-scale programs such as the Chesapeake Bay Watershed Program. This watershed spans six states from New York to Virginia and encompasses over 64,000 square miles. Under the Clean Water Act, the Chesapeake Bay was designated as impaired, showing more than the total maximum daily load allowable for nitrogen, phosphorus, and total suspended solids.
In 2010, states were required to develop Watershed Implementation Plans and were given a deadline of 2025 to bring the watershed to a non-impaired status. That meant anyone discharging into the bay had to mitigate their pollutants and come into compliance. This includes nine Army installations.
Elisa Ortiz, the Northeast Division subject matter expert on water, supports the installations under the Chesapeake Bay Program and assists with EPAS assessments. For Ortiz, this means thinking outside of the box and using innovative ways to minimize sediment and reduce pollutants accumulated during runoff.
“Each site is unique, and a Best Management Practice that works in Maryland is not necessarily going to work in Virginia,” she said. “We had to evaluate each site and come up with projects that would work well based on the local site conditions.”
Some of those solutions, including building pocket sand filters, tree boxes, and bioretention ponds, remove fine solids and sediments while allowing trees, grasses, and other vegetation to absorb the nutrients. Another method uses pervious concrete, which permits water from precipitation and other sources to pass directly through the concrete, allowing groundwater to recharge.
Ortiz noted there has been a shift in the way stormwater is thought about and how it is managed.
“In years past, municipalities and facilities were concerned about the quantity of stormwater and how it affected flooding, whereas today the concern is with both quantity and quality. Instead of using large basins to manage runoff, communities are looking at site-specific, localized stormwater solutions.”
Ortiz also sits on the Water Services Steering Committee, made up of all the Armed Services, who often tackle policy and regulations that impact DoD. While she does not draft policy, she offers guidance, conducts briefings, and reviews new regulations so DoD can formally comment on topics related to water management.
Ortiz also leads a Community of Practice consisting of water managers at Army Installations.
“I act as a conduit between the military services, regulatory agencies, and installations, which allows me to effectively communicate issues up and down the chain,” she said.
USAEC’s mission is to deliver cost-effective environmental services globally to enable Army readiness. Its team of experts continue to provide solutions that focus on being proactive.
“One of our greatest challenges is educating garrison leadership that BMPs are assets and must be maintained. By looking at it in a different light to see what can be done versus what has to be done, we could reduce costs over time,” said Ortiz.
Rohrs echoed that sentiment.
“By shifting from a culture of ‘This is the way we’ve always done it,’ to investing time and resources on the front end, the program will become easier to manage and more cost-effective in the long run,” she said.”