Appendix C
Summary of Responses from State Stormwater Coordinators

On February 21, 2007, on behalf of the committee, Jenny Molloy of EPA’s Office of Wastewater Management sent the following questions to a group of state stormwater program managers and received six responses (found in Tables C-1 and C-2).

  1. For industrial and/or construction: do you have information on non-filers, i.e., folks who should have submitted NOIs, but did not? If so, how old are these data, and how do they compare to overall numbers of those with permit coverage? How did you find and/or estimate the number of non-filers?

  2. Also for industrial and/or construction: do you have information on compliance rates? Yes, this is a really broad question, but something along the lines of: based on inspections (or monitoring data, or whatever metric you use), have you made any determinations on numbers of facilities out of compliance, or alternatively, in compliance? If so, define what you mean by compliance (paper violations, SWPPP/BMP inadequacies, water quality standards violations, etc.).

TABLE C-1 Nonfilers

State

Information on Industrial Non-Filers

Estimate Percent Non-Filers as of Total

Basis of Estimate

Period of Estimate

Comment

CA

Yes

50 percent of heavy industry statewide

Study—CA Water Board, 1999; Duke and Shaver, 1999.

1995–1998

 

69 percent Of industry within City of Los Angeles

Study— Swamikannu et al., 2001

1998–2000

 

MN

No

 

 

 

Study in progress

OH

No

 

 

 

Plan outreach to business

OR

No

 

 

 

Do not compile data

VT

Yes

88–90 percent of industry

Mass mailing

2006

No response from 2,400 of 3,000 mailings

WI

No

 

 

 

 



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Appendix C Summary of Responses from State Stormwater Coordinators On February 21, 2007, on behalf of the committee, Jenny Molloy of EPA’s Of- fice of Wastewater Management sent the following questions to a group of state stormwater program managers and received six responses (found in Tables C-1 and C-2). 1. For industrial and/or construction: do you have information on non-filers, i.e., folks who should have submitted NOIs, but did not? If so, how old are these data, and how do they compare to overall numbers of those with permit coverage? How did you find and/or estimate the number of non-filers? 2. Also for industrial and/or construction: do you have information on compli- ance rates? Yes, this is a really broad question, but something along the lines of: based on inspections (or monitoring data, or whatever metric you use), have you made any determinations on numbers of facilities out of compliance, or alterna- tively, in compliance? If so, define what you mean by compliance (paper viola- tions, SWPPP/BMP inadequacies, water quality standards violations, etc.). TABLE C-1 Nonfilers Information Estimate Basis of Period of on Percent State Comment Industrial Non-Filers Estimate Estimate Non-Filers as of Total 1995–1998 Study—CA Wa- CA Yes 50 percent of ter Board, 1999; heavy Duke and industry Shaver, 1999. statewide 1998–2000 Study— 69 percent Swamikannu et Of industry al., 2001 within City of Los Angeles MN No Study in progress OH No Plan outreach to business OR No Do not compile data VT Yes 88–90 Mass mailing 2006 No response percent of from 2,400 of industry 3,000 mail- ings WI No 575

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576 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-2 Compliance Estimate of Covered Period Information on Basis of of Compliance Facilities Comment State Estimate Rates Non- Estimate Compliant MS4 con- 40 percent struction audit Prioritized deficient in in Los Ange- 2002, Yes paperwork; 30 les and Ven- large CGP 2004, percent with sites for (Construction) tura counties, and 2005 inspection inadequate and large E&S controls CGP con- struction sites CA Transporta- 60 percent tion sector, poor house- plastics 2005 and keeping prac- manufacturing Yes (Industrial) 2007 tices; 40 per- inspections in cent incom- Los Angeles plete SWPPPs County Inspect in NH No response to complaints Inspect construction OH No sites as a priority Do not OR No compile data Plan to VT No inspect for compliance Monitoring 66 percent Mailed report WV Yes (Industrial) 2007 failed to sub- deficiency submittal mit report notices tracking Perform 38 percent inspections with minor and A subsample annually; no Yes 43 percent of 1 percent of 2007 WI (Construction) central with major CGP sites database violations tracking

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APPENDIX C 577 In September 2007, the NRC Committee on Reducing Stormwater Discharge Contributions to Water Pollution sent the following survey to 50 state stormwa- ter program managers. Responses were received from 18 states, including at least one from every EPA region. The blank survey is shown below, and Tables C-3 through C-9 contain the states’ responses. The NRC committee members will greatly appreciate receiving the following information from State Stormwater Coordinators. Please complete both sides of this form and return to Xavier Swamikannu, CalEPA, Los Angeles Regional Water Board, xswami- kannu@waterboards.ca.gov or Fax: (213) 576-6625. State: Name of information provider: Please summarize your State’s Stormwater Permit Program Industrial Construction Municipal Permit General Permit General Permit What are the monitor- ing requirements? How is compliance demonstrated (monitor- ing or other activity)? To whom is the SWPPP submitted? Can an MS4 perform an inspection of an indus- try within its boundary? What industries are considered "high-risk”? Do BMP manuals exist for implementation guidance? No. of dedicated staff or FTEs

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578 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES Does your State Storm Water BMP Manual contain the following, and what are they? WQ sizing criteria Recharge criteria Channel protection criteria Overbank flood criteria Extreme flows Acceptable BMP list Detailed engineering specs for BMPs Soil and erosion control requirements (unless this is left to the local government)

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580 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-3 Continued

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586 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-5 Continued

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588 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES

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590 URBAN STORMWATER MANAGEMENT IN THE UNITED STATES TABLE C-8 Continued

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