Point-Source Pollution

This graphic depicts a classic illustration of point-source pollution, courtesy of Heidelberg University National Center for Water Quality Research, from their website on Lake Erie Algae ( http://lakeeriealgae.com/).

Editor’s Note: This is a column on area watersheds by Blyden Potts and guest columnists to spread awareness of the area’s tributaries and the efforts of area volunteers to keep them clean.

 

A few weeks ago, the Environmental Integrity Project and Lower Susquehanna Riverkeeper Association issued notice of intent to sue Hanover Foods “for significant and ongoing violations of federal and state clean water laws.”

The notice alleges that over the past three years, Hanover “has repeatedly discharged wastewater into Oil Creek at levels exceeding permitted limits of certain pollutants, including ammonia-nitrogen, fecal coliform, sediment, and oxygen-depleting materials;” “121,127 pounds of suspended solids” were released “into Oil Creek in 2020, which was 58 percent over its permitted limit;” the company is “routinely in noncompliance with its daily maximum temperature limits, which potentially threatens the health of fish;” and over the past five years they have “consistently failed to comply with various reporting requirements.” (The full announcement is at:

https://environmentalintegrity.org/news/environmental-groups-take-legal-action-against-pa-food-company-for-clean-water-violations/).

Pollution sources are categorized as point source and nonpoint source. Point-source pollution is the stereotypical image suggested by the Hanover allegations: a factory discharging wastewater into a local waterway. In contrast, nonpoint-source pollution originates over an extended area. The classic examples are urban and agricultural runoff. Point-source pollution tends to be more egregious than nonpoint-source pollution, but in many ways, nonpoint-source pollution is the greater challenge. Point-source pollution is easier to identify, usually easier to intercept and treat, and easier to control by permit.

The National Pollutant Discharge Elimination System (NPDES) prohibits discharge of pollutants from a point source without a permit. In practice, many point sources have permits allowing discharge of certain amounts of contaminants, or other qualities, such as elevated temperature or sediments, under legal limits. A factory or wastewater treatment facility complying with the law is not generally discharging pure water, or even water comparable to the natural water in the stream, but rather water that means permitted levels of pollution. This comes back to the concept of impairment depending on the designated uses of the waterway and on designated total maximum daily load (TMDL), i.e. the designated maximum amount of adverse impact from each factor that a waterway can bear without becoming impaired for its designated uses.

It is not uncommon to see violations of the permit limits, like the one alleged against Hanover Foods. In 2009, two fish kills drew attention to violations by the Land O’Lakes plant in Mountain Creek in Mount Holly Springs. A 2018 report by PennEnvironment Research and Policy Center cited 633 water pollution permit violations in Pennsylvania over a period of 21 months. That averages out to about one violation per day somewhere in Pennsylvania.

(see: https://pennenvironment.org/sites/environment/files/reports/PA_TroubledWaters_scrn_1.pdf, p. 15).

Probably many violations go undetected. Discharges that visibly discolor a waterway, give off a foul stench, or result in a significant fish kill, tend to get noticed, but violations are often almost invisible. They may not look or smell much different from an unaffected stream. This is where environmental watchdog groups like Lower Susquehanna Riverkeeper are so important. Violations are far more likely to be caught and suffer penalties when someone is regularly monitoring water quality. Without the risk of those penalties, it can often be economically advantageous to exceed permit limits and externalize wastewater costs onto the public.

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