Storm Water Runoff Experience

TDC Environmental, LLC provides permitting and compliance support and special studies for federal, state, and local government storm water runoff management programs.  Dr. Moran spent six years managing a local government storm water program.  She has developed innovative programs (like the Brake Pad Partnership) to address urban runoff problems.  She has participated in all storm water management program activities, including program design and planning, ordinance development, education, enforcement, monitoring and reporting.

Phytoremediation of Highway Runoff:  On behalf of Caltrans, the San Francisco Estuary Project retained TDC Environmental to conduct a two-phase project to explore the potential for use of phytoremediation (plant-based pollutant removal) to reduce pollutant levels in highway runoff.  In the first phase, TDC Environmental conducted a literature review of the storm water runoff and phytoremediation fields; used knowledge of highway runoff pollutant sources, fate, and transport process to evaluate the available information; and made specific recommendations for future activities to integrate the use of phytoremediation into Caltrans’ management of highway runoff.  The literature review considered the broad menu of possible highway runoff control technologies, highlighting those that would most likely be feasible in California highway situations.  The promising findings of the first phase lead Caltrans to request that the project’s second phase focus on development of a practical tool for highway drainage designers to use to implement phytoremediation techniques in highway runoff management.  TDC Environmental is working with WRECO (hydraulic engineers), Pacific Coast Seed (native plant experts), and Geoff Brosseau (water quality design expert) to prepare a guide with practical examples showing how to integrate permanent vegetative design features into highway drainage to minimize pollutant levels in highway runoff.  The examples in the guide include design drawings, sizing calculations, planting recommendations, cost estimates, and pollutant removal information..

Diazinon and Chlorpyrifos Risk Assessments Technical Review:  On behalf of the California Stormwater Quality Task Force (SWQTF), Dr. Moran conducted detailed technical peer reviews of the U.S. EPA risk assessments for the re-registration of diazinon and chlorpyrifos (Dursban).  Both diazinon and chlorpyrifos have been linked to toxicity in urban runoff.  She identified numerous water quality issues in each of the multi-volume risk assessments, suggesting methods and resources to incorporate water quality considerations in the re-registration risk assessment process.  The most important issue identified for both risk assessments was the need to evaluate pesticide sites of use and formulations for water quality impacts.  The review comments, which were submitted by the SWQTF to the U.S. EPA, also identified opportunities for U.S. EPA to use the re-registration process to resolve disparities between water regulatory approaches mandated by the Clean Water Act and pesticide regulatory approaches mandated by the Federal Insecticide, Fungicide, and Rodenticide Act.

Manager of Environmental Control Programs, City of Palo Alto Water Quality Program: Dr. Moran managed a combined environmental compliance and pollution prevention program for a wastewater treatment plant and storm water runoff program (Palo Alto is a member of the Santa Clara Valley Urban Runoff Pollution Prevention Program).  That program addressed metals, pesticides, and other pollutants of concern in surface water discharges.  Dr. Moran developed best management practices (BMPs), implemented educational programs to implement BMPs (some of which became regulatory requirements), and evaluated success of programs to reduce pollutant discharges from various urban sources, including mobile cleaners; swimming pool, spa, and fountain maintenance; restaurants; and facility management activities.  Working with both large and small businesses, the program achieved high compliance rates with what are probably among the nation's most strict storm water runoff requirements.  She initiated and annually conducted innovative storm water and wastewater pollution prevention program planning and evaluation process, documented in the Clean Bay Plan.  Dr. Moran received a letter of commendation from San Francisco Bay Regional Water Quality Control Board for work done at the City of Palo Alto. The Palo Alto Water Pollution Prevention Program won numerous awards under Dr. Moran's management; in 1998, it was named the Nation's Most Valuable Pollution Prevention Program (MVP2 Award) by the National Pollution Prevention Roundtable.

Brake Pad Partnership: Dr. Moran initiated development of the Brake Pad Partnership, a national work group including all major vehicle brake manufacturers, government agencies, and environmental groups (additional details on this program are available in the auto section of the City of Palo Alto's web page). Dr. Moran initiated the program in response to the finding that vehicle brakes are the source of the majority of copper in urban runoff. Elevated copper levels impair San Francisco Bay, as well as many rivers and estuaries in the United States. Dr. Moran provided technical support (regarding sources of copper in urban runoff and control measure cost and effectiveness) for the work group. In May 1999 brake manufacturers promised to conduct additional cooperative research on the environmental impacts of vehicle brakes, and to reformulate products to reduce brake-related copper problems in rivers and estuaries and to prevent future environmental problems from brakes.

Dr. Moran currently represents local governments on the Brake Pad Partnership Steering Committee (she now works under contract to the Bay Area Stormwater Management Agencies Association).  Current Steering Committee activities include overseeing brake manufacturer's implementation of a promise to report nationwide copper usage in vehicle brake pads and the Partnership’s implementation of a "research project" to develop a method for assessing the environmental impact of brake pad ingredients, beginning with developing a method for assessing the impacts of copper use in brake pads.  Based on Dr. Moran’s experience evaluating the fate, transport, and potential removal mechanisms for pollutants in street and highway runoff, she is providing technical support for the method development activities, which involve conducting research to obtain an understanding of the release, environmental fate and transport, and ultimate potential impact of the material released into the environment from brake pad wear.

Brake Pad Regulatory Analysis:  Dr. Moran directed the preparation of an analysis of the regulatory issues relating to vehicle brake pads and their releases of copper into the environment.  That analysis, conducted by Palo Alto Regional Water Quality Control Plant intern Catherine Engberg, summarized the regulation of braking safety, the regulation of brake pad composition, and the regulatory authorities available to obtain chemical composition data for brake pads.  The final result of the analysis, a report entitled The Regulation and Manufacture of Brake Pads:  The Feasibility of Reformulation to Reduce the Copper Load to the San Francisco Bay (1994), found that a voluntary partnership between industry and public agencies offered the best and most expeditious solution to the problem of copper pollution from brake pad wear.

Urban Runoff Toxicity Reduction Program: Dr. Moran was a leader of San Francisco Bay regional efforts to eliminate toxicity in creeks and San Francisco Bay from diazinon in urban runoff. She directed preparation of the 1996 report Diazinon in Urban Areas, the first analysis of sources of toxic diazinon discharges (the full report, prepared by Palo Alto intern Ashli Cooper, is available in the pesticides section of the City of Palo Alto's web page). She chaired the Regulatory Subcommittee of the San Francisco Bay Area/Central Valley Urban Pesticides Committee, a cooperative effort to develop a toxicity control strategy for urban runoff. She was a technical reviewer of a series of reports produced by Alameda County Flood Control and Water Conservation District under a U.S. EPA Section 319(h) grant, including the Strategy to Reduce Diazinon Levels in Creeks in The San Francisco Bay Area. (1996-1997), and for a regional implementation project involving local governments and independent garden and hardware stores (the Less-Toxic Home and Garden IPM partnership, 1998-1999).

Local Government Construction Runoff Controls: Dr. Moran was a technical advisor for the City of Palo Alto construction storm water pollution prevention program, involving ordinance-required best management practices (BMPs) for both project design and construction practices, permit review, permit conditions, site inspection, and enforcement (including issuance of fines). The program included education of both property owners and contractors about BMPs.

Building Plan Review Process: Dr. Moran developed criteria for pollution prevention element of building plan review for a local government. She was a technical advisor for ordinance development for design and construction requirements to prevent pollutant discharges in urban runoff. She developed a set of BMPs for building design; these are currently being converted into an educational brochure.

Vehicle Maintenance Discharge Reduction Program:  Dr. Moran oversaw an innovative, award-winning program for vehicle service facilities and car washes developed by the Palo Alto Regional Water Quality Control Plant (with the assistance of a group of consultants) that achieved a 94% compliance rate with possibly the most stringent storm water runoff pollution prevention requirements in the nation.  The program involved education of both facility owners and the general public, recognition of compliant facilities, sampling of wastewater discharges, and enforcement at non-compliant shops.

Pollutant Source Identification Studies And Pollution Prevention Plans: Dr. Moran directed development of wastewater and storm water source identification studies and pollution prevention plans for copper, diazinon, mercury, dioxins, PCBs, organochlorine pesticides and zinc (most of these studies are available in the pollution prevention section of the City of Palo Alto's web page.). She analyzed results of low-detection limit sampling studies and coordinated a local government's strategy to respond to anticipated future discharge requirements for these pollutants. She was a manager, technical reviewer, and conducted data compilation, analysis, and interpretation for sampling programs for storm water runoff, creeks, and wastewater.

Residential and Commercial Source Control Assessment: Dr. Moran was a technical advisor for a project identifying sources and evaluating effectiveness of control measures for pollutants of concern in urban storm water runoff and wastewater. The project produced a critical assessment and research needs document, published by the Water Environment Research Foundation.

Tools to Measure Source Control Program Effectiveness: Dr. Moran was a technical advisor and training workshop speaker for project that developed tools for evaluating wastewater and storm water pollution prevention program effectiveness. The Water Environment Research Foundation published draft project report in March 1999.

Saratoga Creek Lawsuit Settlement Oversight Committee: Dr. Moran was the government agency member of a committee that oversaw implementation of a Clean Water Act lawsuit settlement agreement. The primary element was an urban creek assessment project that sampled, assessed impairment, and developed limited control strategies for bacteria, sediment, and other water pollution problems in Saratoga Creek, California, 1996-1998.

Car Wash Discount Coupon Program:  For four years, Dr. Moran managed a commercial car wash discount coupon program to educate City of Palo Alto residents about pollution of creeks and San Francisco Bay resulting from storm drain discharges from car washing.  The City encourages use of commercial car washes, since their discharges are treated prior to discharge to RWQCP, minimizing pollutant releases.  Each year, three or four car washes (all of which were in compliance with discharge requirements) agreed to participate in the coupon program.  Palo Alto staff prepared and distributed 8,000 to 10,000 brightly-colored coupons offering a $2 discount on a commercial car wash.  These coupons made a significant impact in the community, generating numerous telephone calls and an amazing 10 to 15 percent return rate.  Approximately 30,000 City of Palo Alto households received simple, white coupons in their utility bills; even these had a relatively high a 4 percent return rate, demonstrating the effectiveness of the coupon as an educational mechanism.  (Additional details on this program are available in the auto section of the City of Palo Alto's web page.)

Trainer: Dr. Moran was an organizer and speaker at numerous training sessions relating to storm water runoff management. Sample topics: "Designing a Water Pollution Prevention Program," "Low Cost Program Effectiveness Measurement," "Methods for Identifying Non-Traditional Pollutant Sources." Sponsors included the California Water Environment Association, the National Pollution Prevention Roundtable, the Oregon Association of Clean Water Agencies, the Water Environment Research Foundation, Stanford University, the University of California Santa Cruz, and U.S. EPA. She gave more than 60 professional presentations from mid-1994 through mid-1999.

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