Accelerate Sustainability with Environmental Management Systems
In today’s rapidly evolving world, businesses and organizations are increasingly recognizing the need to align their operations with sustainable practices. Companies are facing a barrage of requests to reduce energy consumption and greenhouse gas emissions, reduce waste generate, water consumption, and monitor and measure the environmental impact of their supply chain.
These actions are then disclosed through platforms such as CDP, EcoVadis, Supplier Assurance, and M2030 to build trust with stakeholders and verify progress towards goals. The volume and complexity of these disclosures can be a nightmare to manage, requiring more and more resources each year. In a world where sustainability can feel nebulous, complex, and overwhelming, an Environmental Management System (EMS) can be leveraged to facilitate progress toward an organization’s sustainability goals. It’s here -- at the intersection of sustainability and EMS -- where structured environmental governance meets long-term ecological and economic viability.
Understanding Environmental Management Systems
An Environmental Management System (EMS) is a structured framework that enables an organization to identify, monitor, manage, and continuously improve its environmental performance. It provides a systematic approach to compliance with regulations, pollution prevention, resource conservation, and stakeholder engagement. Standards such as ISO 14001 offer globally recognized guidelines for implementing an effective EMS, helping organizations minimize their environmental footprint while optimizing operational efficiency.
How Sustainability Enhances EMS Implementation
Sustainability principles broaden the scope of EMS beyond regulatory compliance and pollution control. By integrating sustainability into EMS, organizations can:
Adopt a Proactive Approach: Sustainability-driven EMS frameworks encourage organizations to anticipate environmental risks and opportunities rather than merely react to regulatory requirements.
Improve Resources Efficiency: A sustainability-focused EMS promotes energy conservation, waste reduction, and circular economy initiatives, reducing costs and environmental impact.
Enhance Stakeholder Engagement: Businesses that prioritize sustainability within their EMS gain credibility among consumers, investors, and communities, fostering trust and long-term partnerships.
Support Corporate Social Responsibility (CSR) Goals: By aligning EMS with sustainability, organizations ensure a positive contribution to social and environmental well-being, reinforcing their CSR initiatives.
Drive Innovation: A sustainability-oriented EMS fosters continuous improvement and encourages innovation in product design, supply chain management, and operational processes.
Best Practices for Integrating Sustainability into an Existing EMS
Conduct a Sustainability Assessment: Evaluate current environmental performance and identify opportunities for integrating sustainability goals into the EMS.
Establish Clear Sustainability Objectives: Align EMS objectives with sustainability goals, such as carbon neutrality, zero waste, or water conservation.
Enhance Employee Engagement and Training: Educate employees on sustainability principles and encourage participation in environmental initiatives.
Strengthen Supply Chain Sustainability: Work with suppliers to adopt sustainable practices and reduce environmental impacts across the value chain.
Leverage Technology and Data: Utilize digital tools and analytics to track environmental performance, identify inefficiencies, and make data-driven decisions.
Implement Life Cycle Thinking: Assess environmental impacts across the entire product or service life cycle, from raw material sourcing to disposal.
Continuous Monitoring and Reporting: Regularly review EMS performance, set new sustainability targets, and communicate progress through sustainability reports or disclosures.
Encourage Cross-Department Collaboration: Foster cooperation between departments to integrate sustainability into all business functions.
Engage External Stakeholders: Partner with government agencies, non-profits, and communities to advance broader sustainability goals.
Stay Updated with Emerging Trends and Regulations: Keep up with evolving environmental policies and industry best practices to maintain compliance and competitive advantage.
The Future of Sustainability and EMS
As sustainability becomes an integral part of business strategies, the evolution of EMS will continue to reflect this shift. Future trends may include greater integration of artificial intelligence for environmental monitoring, the rise of nature-based solutions, and an increased emphasis on social equity alongside environmental responsibility. Organizations that proactively incorporate sustainability within their EMS will be better positioned to navigate regulatory changes, consumer expectations, and global sustainability challenges.
The intersection of sustainability and Environmental Management Systems represents a powerful synergy that can drive meaningful environmental stewardship, economic resilience, and social well-being. By embedding sustainability into EMS, businesses not only comply with environmental regulations but also contribute to a more sustainable and prosperous future for all.
If you’d like support building an Environmental Management System for the first time or aligning your existing EMS with sustainability best practices, we’d love to help!
Foresight + Cornerstone Merger Tell-All
How did the merger of Cornerstone and Foresight begin? Watch Mark Miller tell all!
The Cornerstone Environmental Origin Story
Brian and Mark welcome Cindy Madrick to the MicroVlogCast to tell the origin story of Cornerstone Environmental! Hear the full story of how the business began several decades ago and how they've grown to serve hundreds of clients around the world.
Mark & Cindy Shared Their Superpowers!
It's MicroVlogCast tradition to have first time guests share their superpowers! Hear from Mark and Cindy about theirs.
Who Does Cornerstone Serve?
Cassie and Cindy share the types of companies Cornerstone serves. With over 40 years working in EHS, Cornerstone has worked with a huge portion of the marketplace across a variety of industries. Check it out!
What Services Does Cornerstone Offer?
Cassie shares her personal superpower and Jacob dishes about Cornerstone's super services! In his words, "If it's an acronym and an environmental rule, it's something we can help you with." Add in IT services, SDS software, training, audits, ISO, and more... With Cornerstone, your EHS services are covered from top to bottom.
What Makes Cornerstone Special?
This week on the MicroVlogCast, we get Jacob's superpower! Lucky for them, Jacob's clients get his superpower each and every day, and it's one of the things that makes Cornerstone special. Their customer service and dedication to hustling down the right answer for their clients is unmatched in the business. They don't just sell a widget or a software; the real value is their customer service and expert team.
A Shift in Environmental Compliance
On the MicroVlogCast this week, Cindy and Wendy talk about an exciting shift in environmental compliance they've witnessed over the last decade: Is your company following suit?
Bonus points if you can guess Wendy's original profession before stepping into sustainability!
The History of EHS & Sustainability Synergy
EHS and sustainability are becoming more intertwined every year. On the MicroVlogCast this week, Wendy and Cindy share the history of how the two disciplines came together and what they're seeing in the marketplace today.
Case Study: Supporting a PE Firm with Portfolio Companies
Curious how our collective work impacts our customers? Cindy and Wendy chat about our partnership with a private equity firm to address environmental and sustainability issues across their portfolio of companies. Hear about how we're handling everything from regulatory compliance assessments to greenhouse gas management to utility optimization, saving them costs, mitigating risks, and streamlining reporting. From the corporate level to the facility level, we've got all the EHS and sustainability support they need, all in one place.
All the EHS & Sustainability Support, All in One Place
Another great story on the MicroVlogCast! Cassie shares about an EHS client who came to her overwhelmed with the pressures to deliver on sustainability. Cassie pulls in Wendy and the Foresight team to support them with a sustainability roadmap, Scope 1 & 2 GHG emissions, and disclosure platforms such as supplier assurance and EcoVadis.
One person at a company often wears all-the-hats when it comes to EHS and sustainability work. We're here to fill in the expertise and bandwidth gaps as they arise. That's the beauty of all the EHS and sustainability support you could need, all in one place.
A Paradigm Shift in EHS & Sustainability
Companies used to believe that giving back was a product of success - now they're realizing it's a catalyst for it. We're seeing this paradigm shift across the EHS and sustainability landscape. On the final MicroVlogCast of this season, Mark shares how this makes him more excited than ever.
An Important Letter From Our President
To Our Valued Customers,
"Change is the only constant in life. One’s ability to adapt to those changes will determine your success in life.” - Benjamin Franklin
As Cornerstone is now well into our 29th year of business, constant change and adaptation in serving our customers has helped us endure. With that in mind, I’m excited to share a bit of news that will allow us to extend our growth for many more years to come. Cornerstone is merging with Foresight Management, a leading sustainability and energy management firm. This partnership expands our range of compliance services and tools by incorporating Foresight’s expertise in providing comprehensive sustainability solutions.
Headquartered in Grand Rapids, Michigan, Foresight Management is dedicated to championing energy management, accelerating sustainability, and increasing profitability for its clients. Over the years, we have had the opportunity to collaborate with Foresight, getting to know their people, their values, and their work. While we could not have predicted where things would lead, it was clear from the start that Cornerstone and Foresight were a great team. We could not have imagined a better partner.
We believe this collaboration creates a distinctive platform of services to assist our clients in addressing the market and regulatory challenges they are facing. With our background in EHS compliance and Foresight’s expertise in sustainability, clean energy, and decarbonization, we can offer a truly unique suite of tools to help tackle those pressures. For you, our clients, this means that we can support you with an extended list of services, knowledge, and experience.
Through this merger, rest assured that the qualities you love about Cornerstone will remain unchanged. Your point of contact, your favorite expert, and the professional services you rely on will remain consistent, but now we have the resources to significantly broaden the scope of work that we deliver to you and your facilities.
In this ever-changing world, we believe this merger will further reinforce our commitment to providing the highest quality service possible. We would like to thank you for your continued support and partnership and for the ongoing opportunity to be of service to your business.
Sincerely,
Mark Miller
President
Cornerstone Environmental, Health and Safety, Inc.
EPA Finalizes National Primary Drinking Water Regulation for Certain PFAS
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS.
On April 10, 2024, EPA announced the final National Primary Drinking Water Regulation (NPDWR) for six PFAS. To inform the final rule, EPA evaluated over 120,000 comments submitted by the public on the rule proposal, as well as considered input received during multiple consultations and stakeholder engagement activities held both prior to and following the proposed rule. EPA expects that over many years the final rule will prevent PFAS exposure in drinking water for approximately 100 million people, prevent thousands of deaths, and reduce tens of thousands of serious PFAS-attributable illnesses.
EPA is also making unprecedented funding available to help ensure that all people have clean and safe water. In addition to today’s final rule, $1 billion in newly available through the Bipartisan Infrastructure Law to help states and territories implement PFAS testing and treatment at public water systems and to help owners of private wells address PFAS contamination.
EPA finalized a National Primary Drinking Water Regulation (NPDWR) establishing legally enforceable levels, called Maximum Contaminant Levels (MCLs), for six PFAS in drinking water. PFOA, PFOS, PFHxS, PFNA, and HFPO-DA as contaminants with individual MCLs, and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and PFBS using a Hazard Index MCL to account for the combined and co-occurring levels of these PFAS in drinking water. EPA also finalized health-based, non-enforceable Maximum Contaminant Level Goals (MCLGs) for these PFAS.
The final rule requires:
Public water systems must monitor for these PFAS and have three years to complete initial monitoring (by 2027), followed by ongoing compliance monitoring. Water systems must also provide the public with information on the levels of these PFAS in their drinking water beginning in 2027.
Public water systems have five years (by 2029) to implement solutions that reduce these PFAS if monitoring shows that drinking water levels exceed these MCLs.
Beginning in five years (2029), public water systems that have PFAS in drinking water which violates one or more of these MCLs must take action to reduce levels of these PFAS in their drinking water and must provide notification to the public of the violation.
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News Update: SEC Adopts Rules to Enhance and Standardize Climate-Related Disclosures for Investors
UPDATE, April 5, 2024
The Securities and Exchange Commission (SEC) has delayed the implementation of its climate-related disclosure rule in response to legal challenges from two fracking companies and various business groups. This decision awaits the judgment of the U.S. Court of Appeals for the Eighth Circuit on the appeals. Despite this, the SEC continues to assert its authority to mandate public companies to disclose their climate-related risks to investors and is prepared to defend the rule's validity in court. The stay temporarily halts the rule, which would first apply to large accelerated filers for fiscal years beginning in 2025, with other companies following at least a year later. Legal experts recommend companies continue preparing for compliance, while the appeals process could extend over months or years.
Washington D.C., March 6, 2024
The Securities and Exchange Commission today adopted rules to enhance and standardize climate-related disclosures by public companies and in public offerings. The final rules reflect the Commission’s efforts to respond to investors’ demand for more consistent, comparable, and reliable information about the financial effects of climate-related risks on a registrant’s operations and how it manages those risks while balancing concerns about mitigating the associated costs of the rules.
The adopting release is published on SEC.gov and will be published in the Federal Register. The final rules will become effective 60 days following publication of the adopting release in the Federal Register, and compliance dates for the rules will be phased in for all registrants, with the compliance date dependent on the registrant’s filer status.
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EPA News Update: Proposal to Change RCRA Regulation
News Update
On January 31, 2024, the United States Environmental Protection Agency (EPA) signed a proposal to change the Resource Conservation and Recovery Act (RCRA). This change adds nine per- and polyfluoroalkyl chemicals to its existing list of hazardous constituents.
To learn more about this change, read here. To read more EPA news, visit the EPA website.
Update: Notice of this proposal was published in the Federal Register on February 8, 2024.
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Recent Changes to the SARA Title III TRI (Toxic Release Inventory)
Think you are ready to file your Toxic Release Inventory (TRI), aka Form R, reports just the same as you did last year? Hold on a minute. While you might not have an issue doing this, make sure to check the TRI Chemical List for any changes before you press submit. The Environmental Protection Agency (EPA) is making major changes to the list over the next two years.
The EPA makes changes to the TRI chemical list on a periodic basis though EPA-initiated review and the chemical petitions process.
Recent TRI Chemical List ChangesUnder the automatic listing provisions of the 2020 National Defense Authorization Act: Four PFAS were added for reporting year 2022. Reporting forms on these chemicals are due July 1, 2023, for 2022 data if TRI reporting thresholds are met. Nine PFAS were added for reporting year 2023. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met. See Addition of Certain PFAS to the TRI by the National Defense Authorization Act for more information. In November 2022, EPA added 12 chemicals in response to a petition submitted under Section 313(e) of EPCRA. Reporting forms on these chemicals are due July 1, 2024, for 2023 data if TRI reporting thresholds are met.
*from epa.gov
For the Cliff’s Notes version from our technical expert (and skip the clicking)…Or easier still…just call us to help!
For the 2022 reporting year, due by July 1, 2023, the EPA has added four Per- and Polyfluorinated Substances (PFAS) to the EPCRA Section 313 reportable chemical list:
CAS RN Chemical name
375-73-5 Perfluorobutane sulfonic acid (de minimis 0.1%)
29420-49-3 Potassium perfluorobutane sulfonate
65104-45-2 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10- heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14- pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8- tridecafluorooctyl 2-methyl-2-propenoate
203743-03-7 2- Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, γ-ω-perfluoro-C10-16-alkyl acrylate and stearyl methacrylate
Note that the de minimis value for each of these PFAS is 1% unless otherwise noted above. The manufacturing, processing, and otherwise use reporting threshold is 100 pounds for each of the PFAS listed above.
Please also note that the PFAS chemical names and CasRNs are listed on separate tables from the remainder of reportable chemicals on the List of Lists.
For the 2023 reporting year, due by July 1, 2024, the EPA automatically added in 9 PFAS to the EPCRA Section 313 reportable chemical list:
375-22-4. Perfluorobutanoic acid
2218-54-4 Sodium perfluorobutanoate
2966-54-3 Potassium heptafluorobutanoate
10495-86-0 Ammonium perfluorobutanoate
45048-62-2. Perfluorobutanoate
2728655-42-1 Alcohols, C8-16, γ-ω-perfluoro, reaction products with 1,6-diisocyanatohexane, glycidol and stearyl alc.
2738952-61-7 Acetamide, N-[3-(dimethylamino)propyl]-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs.
2742694-36-4 Acetamide, N-(2-aminoethyl)-, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., polymers with N1,N1-dimethyl-1,3-propanediamine, epichlorohydrin and ethylenediamine, oxidized
2744262-09-5 Acetic acid, 2-[(γ-ω-perfluoro-C4-20-alkyl)thio] derivs., 2-hydroxypropyl esters
The EPA has also added the following 12 chemicals to the EPCRA Section 313 list beginning reporting year 2023, in response to a petition filed by the Toxics Use Reduction Institute:
683-18-1dibutyltin dichloride
96-23-11,3-dichloro-2-propanol75-12-7formamide
1222-05-51,3,4,6,7,8-Hexahydro-4,6,6,7,8,8-hexamethylcyclopenta[g]-2-benzopyran;*111-41-1n-hydroxyethylethylenediamine
5064-31-3nitrilotriacetic acid trisodium salt140-66-9p-(1,1,3,3-Tetramethylbutyl) phenol87-61-61,2,3-trichlorobenzene
2451-62-9triglycidyl isocyanurate115-96-8tris(2-chloroethyl) phosphate13674-87-8tris(1,3-dichloro-2-propyl) phosphate
25155-23-1tris(dimethylphenol) phosphate
*classified as a Persistent Bioaccumulative, and Toxic (PBT) chemical with a 100 pound reporting threshold
Risk Assessment: The Starting Point of Health and Safety Management Systems
Starting at the Beginning
Over the past couple of years, the focus on a systematic approach to worker health and safety has never been greater. Whether due to unprecedented illness records due to the pandemic or a greater focus on how their workers’ health impacts a company’s sustainability, it is something that is gaining momentum. A key first step in creating the basis for an occupational health and safety management system is to assess the risks that a company faces. This assessment is the starting point to controlling risks and keeping workers healthy and safe.
Tackle the Most Important Things First
One of the key advantages of a risk-based approach is that the most important and risky things are worked on first. Every organization has a limit to their available resources. Allocation of these resources is critical. Traditional job hazard analysis does not provide as distinct of a list of priorities as using a risk-based approach. Hazards are simply identified for control with little or no explicit ranking of needed action. Incorporating risk analysis into job hazard analysis is the key to prioritizing controls to best utilize resources.
Take Advantage of Worker Participation
Cornerstone begins the task of evaluating worker health and safety hazards and their risks with a risk-based workplace hazard assessment. This is a cooperative practice with the workers who face the hazards. Along with HSE managers and supervisors in the work areas, each job and its tasks are assessed to determine the hazards present. The team then determines the risk of negative outcomes from each task by judging the severity and probability of the negative outcome. They assign a numerical score to each risk and the product of those gives us a risk level for each hazard.
Control the Risks
We determine an acceptable risk level with the team and anything that exceeds that level requires action. Our staff will then determine required or recommended controls for each hazard. We use the US OSHA (Occupational Safety and Health Administration) Hierarchy of Controls to guide this part of the assessment. In the end, Cornerstone Health and Safety evaluators produce a prioritized list of needed controls. Those hazards with a higher risk level demand more urgent action. This action is designed to reduce the risk level. Either through eliminating the hazard, minimizing the severity, or decreasing the probability, the list of hazards and their risk level shifts as controls are implemented. This automatically shuffles the priorities so that, again, the highest risks are controlled first.
Whether done to conform to an ISO Standard, for ESG (Environmental, Social and Governance) efforts, or simply to improve as a corporate citizen, the development of a formal occupational health and safety management system is more and more commonplace. Nearly all formal standards rely on a risk-based analysis of hazards as a starting point for the system. These analyses help organizations identify all the hazards, determine the level of risk they present, and prioritize them for action. Talk to Cornerstone more about how we can help you in your efforts to continually improve your occupational health and safety management system.
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West Virginia v EPA
On June 30, 2022, the Supreme Court’s decision in West Virginia v. Environmental Protection Agency was filed. In a 6-3 opinion, the Court ruled that Congress did not grant the Environmental Protection Agency (EPA) in the Clean Air Act (CAA) the authority to devise emission caps on carbon emissions. Headlines swept the nation ranging from disappointment to outright misinformation.
How Did We Get Here?
The Clean Air Act was passed in 1970 as a comprehensive federal law that regulates air emissions from stationary and mobile sources. The CAA covers a wide scope of air topics including the National Ambient Air Quality Standards (NAAQS), State Implementation Plans (SIPs), and lays the groundwork for Major Source thresholds (a.k.a. the Title V Program). The CAA has been used by the EPA for decades to regulate sources of air pollution and create environmental programs, even if the CAA does not expressly mention the pollutant or program.
As society advanced and technology furthered our ability to evaluate sources of air pollution, many environmental leaders and researchers began to address carbon emissions throughout the country. Did you know that coal-fired power plants are the single-largest source of carbon emissions in the United States? In 2015, as a response to the growing need for regulations to curb carbon emissions, the EPA created the Clean Power Plan (CPP) in order to address carbon dioxide emissions from existing coal and natural gas-fired power plants. The EPA cited Section 111 of the Clean Air Act as the basis for the CPP. Although Section 111 promulgates New Source Performance Standards, certain pollutants from existing sources were regulated under Section 111(d). Under this section, individual states set the actual enforceable rules surrounding an environmental program, while the EPA set the emission limit with which the entity must comply. Interestingly, this section of the CAA has only been cited a handful of times since the CAA’s enactment in 1970. The CPP set emission limits based on three different criteria, most of which encouraged a shift in energy production from high-emitting sources to low-emitting sources (i.e., a change from coal to renewable energy).
As a result of both lobbying efforts and administration changes, the CPP was stayed by the Court in 2016 and underwent a cycle of repeals and rebranding for several years. The EPA reevaluated the regulatory authority of the plan (specifically the use of Section 111(d)) and replaced the CPP with the Affordable Clean Energy (ACE) rule, based on a different Section 111 citation than before. With the promulgation of ACE, many states and industry leaders petitioned the courts on the legality of the EPA’s regulatory reach.
This issue was finally brought to the Supreme Court in West Virginia v. Environmental Protection Agency. In a 6-3 opinion, SCOTUS invoked explicitly for the first time in court history the “major questions doctrine”. The major questions doctrine requires that Congress speak clearly when authorizing agency action in certain extraordinary cases to strike down an agency rule. In summary, the court ruled that because the CAA did not explicitly address carbon emissions, the EPA could not use the CAA to do so. In the future, Congress would have to either amend the CAA to explicitly include carbon emissions or pass an entirely new act.
This leads us to June 30, 2022. The SCOTUS opinion was handed down, and the news took the public by storm. Headlines ranged from “Supreme Court Limits EPA’s Power to Curb Emissions” (Harvard School of Public Health) to “US Supreme Court Deals Blow to Climate Action” (Human Rights Watch). I saw countless posts across social media platforms claiming that SCOTUS had taken away the government’s right to regulate any air pollutants, as well as concern for the future of global warming and carbon emissions. In light of the sensationalism that surrounded this court ruling, it is important to know the facts and how they may impact the future of our legal system, as well as the EHS (Environmental, Health and Safety) industry.
What did the court do?
SCOTUS ruled that Congress must pass explicit legislation giving the EPA authority to regulate carbon emissions from coal and natural gas-fired power plants.
What did the court NOT do?
West Virginia v. EPA did not limit the EPA’s power to regulate and control criteria air pollutants (carbon monoxide, ground-level ozone, lead, nitrogen oxides, particulate matter, and sulfur dioxide) and hazardous air pollutants.
What does this mean for me?
If your organization isn't a coal or natural gas-fired power plant, this regulation does not directly affect your operations or current regulatory requirements.
What does this mean for the future of the EPA?
The court’s precedent of the major questions doctrine will put all agency regulations under a microscope of scrutiny. Any agency regulation (whether it be the EPA, DHS, DOT (Department of Transportation), FCC, etc.) that does not derive from an explicit act of Congress will most likely not receive interpretive deference from the courts.
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Stormwater "Red Flags"
Many years ago, I interned for the local County Health Department and assisted them with water quality monitoring. The department monitored the water quality from twelve points along the rivers and streams in the county. Rain or shine, I headed out every Wednesday morning to collect samples. At each location, I pulled on the hip waders and walked a few meters from the shore to measure oxygen levels and collect a sample for the lab. Every week I plated petri dishes and counted E. coli colonies. Some days the water quality of the river was excellent and other days the bacteria levels (E. coli) in the river were dangerously high. What spiked the levels of bacteria levels in a body of water that moved over 30,000 cubic feet per minute? Rainfall, or more accurately: the pollution that the rainfall carried.
I later found out that some of the sampling locations were near animal farms, hence the E. coli. Water is often called the ‘universal solvent’ because more substances dissolve in water than in any other liquid. The Clean Water Act defines the term “pollutant” broadly.
“[A pollutant] includes any type of industrial, municipal, and agricultural waste discharged into water. Some examples are dredged soil, solid waste, incinerator residue, sewage, garbage, sewage sludge, munitions, chemical wastes, biological materials, radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural waste.”
The Environmental Protection Agency and state governments work hard to protect waters through the implementation of the National Pollutant Discharge Elimination System (NPDES) permit program. Many industries obtain NPDES general stormwater permit coverage if they discharge into water of the United States. Sampling from a site’s discharge point(s) is an important part of the general NPDES permit. The data is compared with benchmark thresholds as an indicator of the effectiveness of the permit and stormwater control measures. Unlike an air permit, a stormwater sample result that exceeds one of the benchmark thresholds is often considered a “red flag” as opposed to a violation.
No one wants to have a “red flag” when they submit their stormwater results, but it may point to a problem with an exposed pollutant source at your site or a stormwater control measure that is not working correctly. Stormwater regulations protect our waters and, ultimately, protect our drinking water and health. As cliché as this sounds, our actions upstream impact our water downstream. Whether it’s general housekeeping at your facility or making sure a driver safely transfers material from your site, every action matters. Monitoring the exterior of your facility weekly is a great activity to ensure your site is not unintentionally polluting. Atypical events such as a leak or spill that was not cleaned up can be caught in time before the rainfall.
Remember that rivers, despite their size and capacity, can be significantly impacted by our actions. Let’s minimize the pollution the rain carries to keep the rivers healthy.