Dear Anon,

We got your letter regarding the discharge you have observed at the Memphis Zoo.  Dana did a file review in Nashville and found out that they do not have a National Discharge Elimination System permit. You were right!  In accordance with the Industrial Waste Survey, all of the zoo’s solid waste is taken off-site for disposal. They do have a permit for construction stormwater and we were curious to see that one of the  activities they described was “drainage structures”.  Drainage to where?

We are planning to look into this further. The next time we’re in Memphis we will ask to look at the construction permit to figure out what drainage structures they have and where they go.  If you have photos, you need to send them to us.  Digital photos are fine.

Thanks so much for thinking of us. If you want to contact me personally feel free to do so at 865.522.7007 x100.  We will keep all your information confidential.  Also, I’d happily join you for a visit to the zoo next time I’m in Memphis!

RvH

Last year EPA proposed some changes to the construction stormwater rules, referred to as effluent guidelines.  Overall, TCWN was supportive of more stringent requirements and assurances to protect our water quality.  The most discussed draft language was a numeric turbidity limit of 13 NTU.  I won’t bore you with too much explanation of what NTU means, but put simply it measures the clarity of water.  And 13 NTU is pretty clear water.  However, in the final rules issued last month, EPA upped the numeric limit to 280 NTU… quite a change.  As you can guess, 280 NTU isn’t nearly as clear as 13 NTU. 

Another big change was the application of these requirements to 20 acres and eventually 10 acres rather than larger sites, which was initially proposed.  This is good news.  There will most likely be challenges to these rules in the near future – perhaps from both sides.  For now, feel free to check out these new rules here.