I was at the ADEM conference in Montgomery, Alabama (a great event with good information and located in a great venue), and I overheard someone referring to my industry as a bunch of guys with “black boxes” using “voodoo” science for performance claims.  As a member of SWEMA (StormWater Equipment Manufacturer’s Association), and one who practices good science, the remark was hurtful.  SWEMA has worked hard to educate everyone about how well vetted and tested our products are, and about what should be expected from a reputable manufacturer.  I wanted to refute what the speaker had said, but it was not the time and place to challenge him in front of his peers.  I will get my chance soon to show him how the responsible people in my industry present their products and what they can do.  At that time, I thought that the days of the “black box” and outlandish claims were behind us for the most part. 

Just a few days later, I saw a project in a major southeast city that had a manufactured device in the storm drain system.  The contractor was a company that often uses our product, but we were not on the plans for that project, nor had we been asked to bid.  We asked about the omission and were told that none of our products could handle the large flow from the system.  In truth, we could have used two of our largest devices to meet the specification, but he did not know that.  However, when we looked closely at the project, we saw that only one of our competitor’s devices was used on the project, and it was much smaller than our proposed solution.  When we looked at the claimed treatment capacity of the smaller system, we could not believe it.

The system in question had been tested by a nationally recognized agency and found to be able to process about 9 cubic feet per second (cfs) and to remove about 65% of the solids.  So, the salesman on this job claimed that the device could run FIVE times as fast, and still remove 80% of the solids.  An image of flaming trousers flashed through my mind.  (Chant here.)  Now, this type of outright exaggeration is easy to counter, but at what cost?  Once I inform the engineer and the regulator of the truth, my industry will once again have been painted (by me) to be using voodoo science and magic black boxes.  In the eyes of the jurisdiction, the engineer, and the contractor, am I any different? Am I guilty by association?  If you recall, the gentleman at theAlabamaconference said we were, “All the same.” 

 I know that times are tough, and that sales are few and far between, but it is time for good men to stand up and call for a stop to outlandish claims.  SWEMA worked very hard to develop a fair and accurate laboratory testing protocol.  There was lots of “discussion” as one company or another worked to defend its own turf, but in the end we all agreed to compromise on what was best for the industry as a whole, and what would work best to protect the watersheds that we are asked to protect.  It is disappointing after that mutual effort, to see one of our peers disregarding the entire process.  Perhaps it is time that our industry started issuing the “Flaming Knickers” award to the company that makes the most exaggerated claims of performance.  It will be hard to find anyone with the … er, guts to claim more than five times their tested performance, but I bet there may be someone out there who will do it. Of course, they will be hiding as best they can.  Do I hear six??

or,  Don’t over-analyze your water quality samples because you might not like the answer.

Someone get me my blood pressure meds.

What set me off today?  It was one more program specifying the EPA 160.2 (TSS) analysis method (now designated as SM-2540-D) and questioning the use of ASTM D-3977-97 (SSC).  This is just a symptom of the problems with many jurisdictional protocols in the USA.  The underlying problem is that scientists have typically not been in charge of water quality in this country.  People tend to hide behind the advisory
guidance of the Environmental Protection Agency (EPA) which is really very well founded if you take the time to read it.  The EPA guidance on water quality says that suspended solids are simply a surrogate for numerous other pollutants, and that if you reduce solids, you can assume that you are reducing other constituents.  While this is not science, it is a nice simple solution, and it takes a leap of faith to believe that it is actually true. Still, it is the law, so to speak.  If you have not read, “Management Measure 5” from the EPA, it would probably be a good idea for you to read the guidance for yourself.  It flatly states that particulates “include suspended, settleable, and bedload solids”, goes on to say that one study showed “that the greatest mass of contaminants in highway runoff is found on particles in the 425 to 850 micron (μm) range”.  While this seem abundantly clear, the guidance goes on to foster some confusion by stating that “Generally, individual particles found in a TSS sample are 62 μm (0.062 mm) or less in diameter and classified as either silts or clays.” If you are involved at any level in permitting water quality structures, you should actually read this management measure.  It can be found here:

(http://www.epa.gov/owow/nps/urbanmm/index.html)

The guidance also explains why the ASTM analysis method (SSC or ASTM D-3977-97) is the preferred method for determining the true concentration of solids in water samples with any mix of particle sizes (not EPA 160.2 TSS).

As a matter of fact, the EPA 160.2 TSS analysis method is not only inaccurate, it is not repeatable and should not be trusted.  It typically cannot meet the QA/QC standards for testing, because it gives answers all over the map for aliquots drawn from the same sample. Essentially TSS is a partial sample analysis, where a portion of the sample is drawn out with a pipette (or poured out), and then analyzed.  The result of the partial sample is deemed to be representative of the whole sample, and it is multiplied by some factor to adjust it back up, as if it represented the whole sample.  If one tenth of the sample was used for the analysis, the result is multiplied by 10 (and any error is also increased by 10).  Of course, larger particles tend to settle more quickly, so are not likely to be collected in the subsample, but it is interesting to note that TSS can over-estimate concentrations if the lab practitioner tries to adjust for settling effects by taking a sample low in the water column.  With the subsample, the lab worker has to accurately read the amount of water withdrawn also.  SSC on the other hand uses the entire sample and pours it through a filter to get all of the solids, and measures all of the liquid.   It is both accurate and repeatable.

To rely on TSS data challenges the intellect.  First, you have to believe that all the pollution lies in small particles. I once asked for people to share studies to confirm this, and one nice engineer brought forward a report that cited 5 such studies with fractional analysis.  Fractional analysis is a technique where particles are sorted by size, and then the concentrations of various pollutants are reported for each particle size range.  The very credible report even stated that pollutants tended to attach to smaller particles.  Trouble is, that is not what the data in the studies showed.  I plotted the data to get a good visual look at it.  The data in the studies indicated that the highest concentrations were, in general, in the 75 to 150 micron ranges.  One study did show a peak in the 2 to 6 micron range (probably from clay adsorption of metals), but that same study showed another peak in the 75 to 150 micron range.  I am still looking for studies that demonstrate the small particle effect in real stormwater sediments (not laboratory clay samples).  To be sure, it is very expensive to do fractional analysis, and so, such studies are rare.  If you have one, or know of one, please let me know about it.

You do not have to be an expert, however, to understand how man’s influence on the impervious surfaces we drive and walk upon tend to link pollutants to things larger than a speck on a gnat’s hair.  (The blogger introduces a rusty alkaline battery, a lump of asphalt, and a roadway enterline reflective paint chip into evidence.)

If you believe that small particles are the problem, and you want to rely on EPA 160.2 TSS, you have to believe that it is not necessary to get the right answer to concentrations also.  If you had a thermometer that you relied on, and it read 25 degrees one minute, and 45 the next, you would not believe it.  Well, you might believe it, but if you were depending on it to keep your pipes from freezing, you would not rely on it.  Somehow, people have deluded themselves into using an analysis method (EPA 160.2 TSS) that is neither accurate nor reliable.  Why would anybody do this?  Well, because it agrees with what they believe. You can believe it is 45 degrees outside as much as you want to, but if it is really 25 degrees outside, your car radiator and your pipes will freeze if not protected.  If your watersheds are at stake (and they are), we better start relying on good science and people who have actually proven what they can (and cannot) do.

My ETV testing is a case in point, but I could point out the testing of others just as well.  Every credible test of a structural BMP shows results for solids concentrations using SSC analysis are always higher than TSS analysis.  Regulators tend to want to believe the TSS numbers because…  well…, just because.  It does line up quite nicely with what “Mr. Manual” says, and how they “feel” about things.  Feeling concerned about protecting the environment is a good thing, but you should toss out feeling and rely on real science to actually accomplish environmental protection.

It should be noted that the inaccuracy of the TSS analysis method can cut both ways.  If the effluent concentration is under-reported by TSS analysis, a BMP could appear to be more efficient than it actually is.   There is no defense for using a bad method to analyze perfectly good samples. Let’s take my reported numbers from the ETV test, and look at the actual samples, which they dried, weighed, and split into sand / fines fractions. My SSC removal number was reported at 89% (It was 90% if you care to do the math), and my TSS at 21%.  When they took the sand and silt splits and did the “Sum of Loads” (SOL) calculations in “Table 5-7 Particle Size Distribution Results” of my report, they determined that we had 1,400 pounds of sand in the inlet and only 24 pounds in the outlet for a sand removal rate of 98%.  The table also showed 200 pounds of fines in the inlet and 133 pounds in the outlet, for a removal rate of 34%.  Ok, let’s assume for the sake of argument that the sand, flotables, organics, trash, debris (nothing but the sand was actually measured) are completely clean and carry no pollution at all including no nutrients.  (That should boggle your mind.)  We will take a zero for the sand, pretending that it weighed nothing and contained nothing. We still removed 34% of the silt and clay by weight, which is much different than the reported 21% for the sands and fines combined.  As an analysis method for real stormwater, TSS is simply inaccurate.

Lest you think I protest too much, you should know that we have an excellent study in Highlands, NC, that used TSS as the analysis method. The study evaluated nutrients, metals, fecal coliform and many other constituents.  Of course, we did not get 89% removal efficiency with TSS analysis instead of SSC.  In reality, we got a 96% removal rating in that study when TSS analysis was used.  This really sounds good, and it silences the critics who believe that our SSC data is somehow tainted, but I would trust the 89% SSC efficiency rating before I trusted the 96% from TSS simply because the TSS analysis is not reliable.

(The blogger climbs up on his soapbox now.) The same folks that believe in using inaccurate analysis methods promote automatic acceptance at an assumed removal rate for their BMPs of choice. They have a water quality manual that is the gospel, and it clearly states that their preferred BMPs remove 80% (or whatever number someone told them was good) of all pollutants.  “In the manual = Approved”; next case. They truly believe that all bad things move in tiny storms, and are attached to small particles.  Amen. They developed these firmly held beliefs at seminars presented by “Credible.org”, and have certificates of completion to prove it. Selah.

Armed with this “data” they confront people who have actually done verification work at a certified laboratory, or been evaluated in a strictly regimented field testing program and label those people “unclean, for they resideth not in the hallowed manual.”  No matter that their manual-sanctioned practices have not been able to achieve the magic number when actually field tested (or have not been tested at all), or that their accepted methods have been proven inaccurate and outdated.  No, thou art in our house now, and thou shalt do as we say. (Climbing down off of the soapbox.)

I guess I would be ok with this if I did not get to look at the material that comes out of the devices we clean.  It is not clean, washed builder’s sand.  It is nasty.  It is full of pollution.  It also has more than 21% fines in it, but that is another story.  You can believe in voodoo science if you want to, but I would challenge you to go with good sampling, accurate analysis, and to get about the task of protecting our waterways.  It is ironic that my industry is accused of proffering “black box”, unproven solutions, when in reality; it is “Mr. Manual” and his crowd who are offering unproven “snake oil” remedies.

A new independent study has shown once again that the basic CrystalStream water quality vault leads all competitors in performance.  In June of 2010 a CST Model 2056 was installed in the Town of Highlands, North Carolina, which is 4,118 feet above sea level.  While this may have been a high point in elevation above sea level, it also set a high point in performance for this type of manufactured BMP.  The study started out with lofty goals.  The intention was to remove 85% of the total suspended solids and 35% of the phosphorus.

Highlands is a beautiful community that sits atop the Eastern Continental Divide in the Blue Ridge Mountains. The town lies within one of only two rainforests in the United States with over 80 inches of annual rainfall, and enjoys an almost ideal average temperature of 78 degrees Fahrenheit in the summer “heat” of July.  The town has many shops, restaurants, and unique lodging opportunities, so it is no surprise that it is a favorite tourist destination and the home of many people who have come to appreciate the breathtaking scenery and temperate climate.  Of course, with development comes pressure on the environment, and that is what prompted the Town to look for ways to protect its pristine lakes and streams.

The plan was to install a CST hydrodynamic separator and an underground storage facility on a portion of a stream that had been piped through a part of the Town long ago.  The natural stream had been relocated into a small drainage ditch that ran between shops and a bed and breakfast adjacent to the project site. The area had been subject to frequent flooding in the past.  The goal was to clean up the water with the separator prior to it entering the storage facility, and to supplement the quality of the water coming out of the CST device by further treatment as it was slowed down passing through the storage.  The basin that drains through the system is 14.6 acres and could produce very high flows in excess of the 25 cubic feet per second (cfs) capacity of the CST separator, so an external weir bypass was incorporated to direct the first 25 cfs of the flow through both the separator and the storage facility.  Excess flows can bypass the entire system through an overflow pipe.  There was a very small standing flow in the basin, so a small weir in an upstream manhole diverted this low flow into the existing ditch, bypassing the entire project. This was all paid for by the Town through a Clean Water Management Trust Fund grant and matching local funds.

The system has worked very well at helping to control flooding with the added underground capacity and new pipe systems.  The system has far exceeded expectations in the water quality department.  Water entering the CST water quality vault had an average TSS concentration of 283.8 mg/L, while the water exiting the vault had an average TSS concentration of 11.9 mg/L.  This is an astonishing 96% removal rate!  Total phosphorus removal by the vault was at 74%, as was total nitrogen.  These are not composite estimates, but are grab samples taken live in the field during the 20 studied storm events.

Samples were taken above the CST vault and below the vault at a point just above the underground storage.  More samples were taken concurrently just below the underground storage system.  While the samples match quite nicely for the vault (at 5 cfs it has a 20 second resident time), the high capacity of the underground storage system makes matching sample times more problematic.  Nevertheless, the underground system did further improve the TSS removal as the concentration in was 11.9 mg/L and out was 5.5 mg/L.  This was a 54% removal rate for the underground storage itself. There was a slight rise in total phosphorus and nitrogen coming out of the underground storage system, and the TSS removal was not very good, but this can easily be explained in that the concentrations coming out of the CST device were already very low, and practically irreducible.  As a whole, the CST device and the underground storage removed 98% of the TSS from the stormwater runoff.   The effluent concentration of 5.5 mg/L was lower than the effluent TSS concentration for many wastewater treatment plants.

There is more interesting data in the study that is of interest to scientists and regulators.  Over 10,000 pounds of sediment was removed from the CST vault. It was analyzed for particle size distribution and found to be 57% sand, 35.5% silt, and 7.5% clay.  In addition, the trash screen collected over 1,000 pounds of organic debris.  When the sediments were analyzed for nutrients and metals, the results were impressive.  Twenty-seven pounds of total nitrogen and ten pounds of phosphorus were removed. There were 4.1 pounds of Zinc, 1.7 pounds of copper, 1.7 pounds of barium, and lesser amounts of mercury, arsenic, cadmium, chromium, lead, selenium and silver. Added to these totals was material trapped on the coconut fiber filter.  The filter targets dissolved pollutants.  The test plan called for swatches of fresh fiber to be tested, and for swatches of used fiber to be similarly tested.  The filters were changed four times during the test.  Each quarter the fiber filter collected 14.9 grams of total nitrogen, 3.4 grams of total phosphorus, 6 grams of zinc, 1.7 grams of copper and lesser amounts of other dissolved metals.  The overall data indicate that while most pollutants are attached to the sediments, there are significant levels of dissolved pollutants that can be removed by filter media.

Summary

This is a true third party study conducted and paid for by others.  It clearly demonstrates that the CST vault by itself exceeded the NCDENR (North Carolina Department of Environment and Natural Resources) requirements.  This was a bit surprising in that the basin is a mixture of natural steep slopes and highly developed “downtown” area, and is subject to a lot of rainfall and high energy storm flows.  Furthermore, the
analysis method used was the TSS method, which is not friendly to hydrodynamic systems.  That analysis method is highly small particle biased, so it always shows lower removal results than the more accurate and dependable SSC analysis method when used to evaluate these types of devices.  Finally, the device is in a large basin that can push it to its hydraulic capacity more often, as a weir diverts the first 25 cfs to the system.
The result is the system runs faster and longer than it would on a smaller basin.  The built in design of the CST devices to avoid re-suspension obviously works well when you assess the data from this test.

What does this mean?  Well, the numbers are nice and it is always good to get one more “passing grade” on a field test, but there is more here that just meeting an arbitrary removal rate standard.  This is significant in that the Town of Highlands set out to clean up a stream, and to protect a mountain lake.  They also wanted to protect their businesses from flooding and stormwater damage.  To that end, they hired an excellent  engineering team, McGill Associates (Ashville, NC, www.mcgillengineers.com) to come up with a good plan that fit into the existing drainage  system, and was compatible with the unique character of the region.  The Town went one step further, and was determined to get a system that could be cleaned and maintained on a regular basis.  They anticipated what might happen with an underground storage facility if it was unprotected, and took steps to make sure it would work well into the future.  Most importantly, they committed to the cost of cleaning and maintaining the system. No one has to guess whether or not the system is working.  Literally tons of material, bound for their lakes and streams has been removed and disposed of properly.  These are results you can see and touch.  A short walk downhill to the manhole at the end of the system that returns the flow to the natural stream bed tells the story.  The water is gin clear and the structure is clean and free of debris.  The contrast to the manholes above the system is immediately obvious.  This is as it should be.

1. New webinars

2. Product Updates

3. New Test Results

4. New Products or demonstration videos.

5. New stormwater facts

6. Latest Papers

This is just to name a  few. We look forward to seeing you become part of our growing family.

Don Billingsley of CST teaching 4th Graders stormwater management

ELIZABETHTON —CrystalStream Technologies was proud to contribute time to the education of some 500 4th Graders at this years Elizabethton/Carter County Conservation Camp this week. Instead of stuffy classrooms, the students had the spacious outdoors of Sycamore Shoals State Historic Area to learn about nature and how to keep the environment clean.

“It’s a good camp,” Hannah Whitson, a student from Harold McCormick Elementary School said. “We learned about recycling and we learned how to help Monarch butterflies by planting the right flowers.” One of the great things about the camp is there are so many things to do and to learn the children hardly have time to be bored. The park is divided into 12 stations and the students move from one station to the next.

For instance, County Agricultural Extension Agent Keith Hart taught the students about the various plants found in the forest which are good to eat, both for animals and for people. There also were stations where the children learned about soil erosion by actually getting to play in the dirt. While Don Billingsley with CrystalStream Technologies took time each day to teach the students about stormwater management and how important it is to keep our natural waterways clean.

Gary Barriger and Kathy Landy had a station right on the bank of the Watauga River where they taught stream ecology with fish, snails, crayfish and insect larvae they had caught that morning in the river. The children appeared to love the up-close look at nature.

The camp is sponsored by the Elizabethton/Carter County Chamber of Commerce. Chamber Director Felicia English said the camps had been held several years ago, but they had been discontinued. “I think these kids are learning a lot about the environment during this camp and I think they are interested in leaving it in as good or better condition than we passed it on to them.”

Among the organizations providing speakers for the stations were the Tennessee Department of Environment and Conservation, U.S. Department of Agriculture, CrystalStream Technologies,  National Resource and Conservation Service, University of Tennessee Extension Service, Appalachian Resource Conservation and Development Service, Boone Watershed Partnership, city of Elizabethton, Winged Deer Park and the Tennessee Department of Agriculture.

Crystalstream 2011 Stormcon Cruise Giveaway Winner

This year at Stormcon Crystalstream Technologies gave the visitors of their booth a chance to win a cruise for two to the Bahama’s including $100 in onboard ship credit. Everyone at CST was very excited about this opportunity and thought what better way to reward thier visitors at a conference focused on protecting our natural resources than 3 days at sea.
Please be sure to visit us next year at Stormcon in Colorado for your chance to win even more great prizes.

We just did our latest internal report on how all of our devices are performing, and one part of that report is a total of all the pounds we have hauled away to disposal facilities over the past 11+ years.  The total does not count all the material we have removed during the construction phase on those sites, as this total would be much higher.  The total of 12,094,840 pounds on our report is only that material that was washed off of sites in the post construction phase of their existence.  The first device we sold is still under maintenance and has had over 26,000 pounds of material removed over the past eleven years or so.  Do we sound proud of these facts?  Well, we are.

How can we envision the 12 million pounds of trash, debris, vegetation, oil and sediment that never made it to our lakes, rivers and streams?  If we loaded the material in ten pound bags, we would have 1,209,484 bags of the nasty stuff.  While you are reading this, we will have someone start piling up bags like they were sandbags used to protect from a flood.  If they place one bag every 10 seconds, it will take a mere 201,581 minutes to pile up all those bags (read slowly please).  This is equal to about 3,360 hours or 140 days.  In a short 4 and one half months, they will be finished piling up the bags.  If they put them in a 10 x 10 bag grid (100 bags per layer), and the bags are 6 inches thick, the pile will be over a mile high at 6,047 feet tall.   

I had the sad duty of speaking at the funeral of my partner and co-inventor, Clark Joseph Use` last fall.  The church was full of people who wanted a good way to remember him and his accomplishments.  I used the example of a bag being placed every ten seconds in a procession to honor what he had helped accomplish for our environment.  The idea of a four month long procession seemed to get across to them what Clark had helped achieve.  It brought home to many of them the enormity of what is at stake in water quality, and Clark’s contribution to clean water.  The best part is that the 12 million pounds is not the end of the story.  Every day, these devices continue to collect pollutants from stormwater, and the total will continue to grow.

We truly believe that there is no “removal rate” for any BMP, until someone shows up and removes the material that it has collected.  We believe that our products are good, but they are only as good as the organization that stands behind them.  Can you say that about your BMP?