Narrative Water Quality Criteria Related to Trash and Plastics

Improperly handled trash, which can include various forms of plastic, can enter our waters and pose risks to human health and the environment. Trash pollution can prevent water bodies from attaining their designated uses, such as recreation - or the protection of public water supplies. Trash consists of diverse materials, from plastic and food waste to used tires and construction debris. It also comes from a variety of sources, from illegal dumping to stormwater runoff, making it challenging to monitor and control.

To address reduce or eliminate trash in our waterways, it is important to adopt water quality criteria related to trash pollution and then identify a way to implement such criteria in an effective manner. The following are examples of both narrative criteria and implementation approaches that state and authorized tribes may want to consider when they update their water quality criteria and implementation associated with trash and plastic pollution.

Examples of both Narrative Water Quality Criteria and Implementation Approaches

California

• The Water Quality Control Plan for the Ocean Waters of California contains requirements related to trash, including the following narrative water quality objective criterion (what California calls a water quality objective):

  Trash shall not be present in ocean waters, along shorelines or adjacent areas in amounts that adversely affect beneficial uses or cause nuisance.

• The Water Quality Control Plan for Inland Surface Waters and Enclosed Bays and Estuaries contains requirements related to trash, including the following narrative water quality criterion (or, in California, water quality objective):
  Trash shall not be present in inland surface waters, enclosed bays, estuaries and along shorelines or adjacent areas in amounts that adversely affect beneficial uses or cause nuisance.
• Implementation of these trash provisions is generally accomplished through requirements for full capture systems (or equivalent) in NPDES permits issued pursuant to Clean Water Act section 402(p), i.e., stormwater permits.
  • Implementation of the trash provision for ocean waters can be found in the Ocean Plan at Chapter III Program of Implementation, L Implementation Provisions for Trash, starting at page 33.
  • Implementation of the trash provision for inland surface waters and enclosed bay and estuaries can be found in Appendix E under Final Documentation.
  • California’s Storm Water Program also has a Trash Implementation Program website.
• California’s Regional Board 4 (incorporating the Los Angeles Region) also has trash-related narrative water quality objectives in its Basin Plan, and has implemented them into a number of Total Maximum Daily Loads.

  Waters shall not contain floating materials, including solids, liquids, foams, and scum, in concentrations that cause nuisance or adversely affect beneficial uses.
  and
  Waters shall not contain suspended or settleable material in concentrations that cause nuisance or adversely affect beneficial uses.

• The California Trash Monitoring Workgroup supports trash monitoring and development of data analysis and visualization tools aimed at assessing the effectiveness of policies and practices for limiting the amounts of trash in the environment.

• The California Trash Monitoring Methods Project website contains references for those interested in learning more about the considerations for selecting a suitable trash monitoring program.

Maryland

• Maryland’s water quality standards (COMAR 26.08.02.03(B)) contain the following narrative:
  1. Substances attributable to sewage, industrial waste, or other waste that will settle to form sludge deposits that:
     1. Are unsightly, putrescent, or odorous, and create a nuisance, or
     2. Interfere directly or indirectly with designated uses;
  2. Any material, including floating debris, oil, grease, scum, sludge, and other floating materials attributable to sewage, industrial waste, or other waste in amounts sufficient to:
     1. Be unsightly;
     2. Produce taste or odor;
     3. Change the existing color to produce objectionable color for aesthetic purposes;
     4. Create a nuisance; or
     5. Interfere directly or indirectly with designated uses.

• The Maryland Department of Natural Resources developed a trash rating as part of the State’s biological stream survey program which is a program to monitor and assess water quality in non-tidal 4th order and smaller streams throughout the State of Maryland. MD DNR’s Trash Rating is an example of a semi-quantitative measure of trash at each site that requires minimal time and effort but produces valuable data that may be used for assessment.

• The state has a marine debris program for its coastal waters.