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Water Quality Compliance Is About To Get Even Tougher In California - The Nutrient Numeric Endpoint (NNE) Process And Its Impact On You
by Jeremy N. Jungreis

Discharging water in California, for any purpose, is already very tough.  California water quality standards are currently some of the most stringent in the nation, and it's about to get a whole lot tougher for regulated industry.  EPA and the State Water Resources Control Board (SWRCB) have developed a new process, the NNE, for determining whether "nutrients" in the water (primarily nitrogen and phosphorous) are causing violations of federal and state law.

 

Nutrients are very common causes of water pollution.  The reason:  nutrients are everywhere around us.  Our atmosphere is loaded with nitrogen, and both nitrogen and phosphorous are extensively used in agriculture and landscaping (commercial, residential and park).  Many groundwater aquifers also contain substantial nutrient concentrations that are naturally occurring or result from historical land use.  Similarly, while municipal sewage treatment plants remove the vast majority of nutrients from wastewater return flows, residual nitrogen often remains after conclusion of the reclamation process.  In excess quantities, nutrients can cause water bodies to fill up with algae and stagnate.

 

The NNE process, which is described in great detail at http://rd.tetratech.com/epa/, seeks to identify the numeric concentration of nutrients that is "too much" for a stream to handle without adversely affecting its beneficial uses.  To make this determination, the NNE utilizes secondary "endpoints" that may indicate nutrient problems in a water body (such as algal density, chlorophyll prevalence, the biological health of stream bottoms and dissolved oxygen levels).  Though the approach itself is not unreasonable, the problem is in the way that the approach has been applied-building one conservative assumption about a water body's  natural condition, and capacity to use and assimilate nutrients, upon the next.  Then, the most conservative indicator "endpoints" are chosen so that water bodies are regulated by the strictest available measures. 


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