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IMPROVING THE EPA MULTI-SECTOR GENERAL PERMIT FOR INDUSTRIAL STORMWATER DISCHARGES Committee on Improving the Next-Generation EPA Multi-Sector General Permit for Industrial Stormwater Discharges Water Science and Technology Board Division on Earth and Life Studies A Consensus Study Report of
THE NATIONAL ACADEMIES PRESSâ 500 Fifth Street, NWâ Washington, DC 20001 Support for this activity was provided by the Environmental Protection Agency. Any opinions, fi Â ndings, conclusions, or recommendations expressed in this publication do not necessarily reflect the views of any organization or agency that provided support for the project. International Standard Book Number-13: 978-0-309-48846-4 International Standard Book Number-10: 0-309-48846-X Digital Object Identifier: https://doi.org/10.17226/25355 Additional copies of this publication are available from the National Academies Press, 500 Fifth Street, NW, Keck 360, Washington, DC 20001; (800) 624-6242 or (202) 334-3313; http://www. nap.edu. Copyright 2019 by the National Academy of Sciences. All rights reserved. Printed in the United States of America Suggested citation: National Academies of Sciences, Engineering, and Medicine. 2019. Improving the EPA Multi-Sector General Permit for Industrial Stormwater Discharges. Washington, DC: The National Academies Press. doi: https://doi.org/10.17226/25355.
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Consensus Study Reports published by the National Academies of Sciences, E Â ngineering, and Medicine document the evidence-based consensus on the studyâs statement of task by an authoring committee of experts. Reports typi- cally include findings, conclusions, and recommendations based on information g Â athered by the committee and the committeeâs deliberations. Each report has been subjected to a rigorous and independent peer-review process and it repre- sents the position of the National Academies on the statement of task. Proceedings published by the National Academies of Sciences, Engineering, and Medicine chronicle the presentations and discussions at a workshop, symposium, or other event convened by the National Academies. The statements and opinions contained in proceedings are those of the participants and are not endorsed by other participants, the planning committee, or the National Academies. For information about other products and activities of the National Academies, please visit www.nationalacademies.org/about/whatwedo.
COMMITTEE ON IMPROVING THE NEXT-GENERATION EPA MULTI-SECTOR GENERAL PERMIT FOR INDUSTRIAL STORMWATER DISCHARGES ALLEN P. DAVIS, Chair, University of Maryland, College Park ROGER T. BANNERMAN, Wisconsin Department of Natural Resources, Madison (Retired) SHIRLEY E. CLARK, Penn State Harrisburg L. DONALD DUKE, Florida Gulf Coast University, Fort Myers JANET S. KIELER, Denver International Airport, Colorado JOHN D. STARK, Washington State University, Puyallup MICHAEL K. STENSTROM, University of California, Los Angeles XAVIER SWAMIKANNU, University of California, Los Angeles; California Environmental Protection Agency, California Water Board, Los Angeles Region (Retired) National Academies of Sciences, Engineering, and Medicine Staff STEPHANIE E. JOHNSON, Study Director, Water Science and Technology Board CARLY BRODY, Senior Program Assistant, Water Science and Technology Board NOTE: See Appendix G, Disclosure of Conflict of Interest. v
WATER SCIENCE AND TECHNOLOGY BOARD CATHERINE L. KLING (NAS), Chair, Cornell University, Ithaca, NY NEWSHA K. AJAMI, Stanford University, Palo Alto, CA JONATHAN D. ARTHUR, Florida Geological Survey, Tallahassee DAVID A. DZOMBAK (NAE), Carnegie Mellon University, Pittsburgh, PA WENDY D. GRAHAM, University of Florida, Gainesville MARK W. LeCHEVALLIER, Dr. Water Consulting, LLC, Morrison, CO MARGARET A. PALMER, SESYNCâUniversity of Maryland, Annapolis DAVID L. SEDLAK (NAE), University of California, Berkeley DAVID L. WEGNER, Woolpert Engineering, Tucson, AZ P. KAY WHITLOCK, Christopher B. Burke Engineering, Ltd., Rosemont, IL National Academies of Sciences, Engineering, and Medicine Staff ELIZABETH EIDE, Director LAURA J. EHLERS, Senior Program Officer STEPHANIE E. JOHNSON, Senior Program Officer M. JEANNE AQUILINO, Financial/Administrative Associate COURTNEY R. DEVANE, Administrative Coordinator BRENDAN R. McGOVERN, Research Assistant CARLY BRODY, Senior Program Assistant vi
Acknowledgments We would like to express our appreciation to the Jenelle Hill, EPA following people who provided presentations or public Paul Hlavinka, Maryland Department of the comment to the committee. Environment Christopher Kloss, EPA Fredric Andes, Barnes & Thornburg Matthew Lentz, California Stormwater Quality William Ashton, Alaska Department of Association Environmental Conservation Jeffrey Longsworth, Barnes & Thornburg Jim Bachhuber, Brown and Caldwell James Maroncelli, Washington Department of June Bergquist, Idaho Department of Environmental Ecology Quality Melinda Pagliarello, Airports Council Internationalâ Jim Bertolacini, Wisconsin Department of Natural North America Resources Travis Porter, Washington Department of Ecology Kevin Bromberg, Small Business Administration Bryan Rittenhouse, EPA Seth Brown, Water Environment Federation and Edan Rotenberg, Super Law Group National Municipal Stormwater Alliance Kenneth Schiff, Southern California Coastal Water Patrick Burch, West Virginia Department of Research Project Environmental Protection Brian Schweiss, Minnesota Pollution Control Agency Margarita Chatterton, Rhode Island Department of Timothy Simpson, GSI Environmental Environmental Management Richard Smith, Smith and Lowney Brian DâAmico, Branch Chief, Environmental Brandon Steets, Geosyntec Consultants Protection Agency (EPA) Office of Science and Eric Strecker, Geosyntec Consultants Technology Rachel Urban, EPA Sebastian Donner, West Virginia Department of Eric Van Genderen, International Zinc Association Environmental Protection Jack Waggener, AECOM Phillip Flanders, EPA David Wagger, Institute of Scrap Recycling David Flores, Center for Progressive Reform Industries Peter Ford, EPA Laurel Warddrip, CalEPA, California State Water William W. Funderburk, Jr., CastellÃ³n & Funderburk Board LLP Melissa Wenzel, Minnesota Pollution Control Greg Gearheart, California Environmental Agency Protection Agency (CalEPA), California State Ian Wren, San Francisco Baykeeper Water Board vii
viii ACKNOWLEDGMENTS This Consensus Study Report was reviewed in Arthur W. Ray, City of Rockville draft form by individuals chosen for their diverse per- Kenneth Schiff, Southern California Coastal Water spectives and technical expertise. The purpose of this Research Project independent review is to provide candid and critical Brandon Steets, Geosyntec Consultants comments that will assist the National Academies of Eric Strecker, Geosyntec Consultants Sciences, Engineering, and Medicine in making each Melissa Wenzel, Minnesota Pollution Control Agency published report as sound as possible and to ensure that it meets the institutional standards for quality, objectiv- Although the reviewers listed above provided many ity, evidence, and responsiveness to the study charge. constructive comments and suggestions, they were not The review comments and draft manuscript remain asked to endorse the conclusions or recommendations confidential to protect the integrity of the deliberative of this report nor did they see the final draft before process. its release. The review of this report was overseen by We thank the following individuals for their review George Hornberger (NAE), Vanderbilt University, of this report: and Michael Kavanaugh (NAE), Geosyntec Consul- tants. They were responsible for making certain that Peter deFur, Environmental Stewardship Concepts, an independent examination of this report was carried LLC out in accordance with the standards of the National Shawn Gibbs, Indiana University Academies and that all review comments were care- Michael Hanemann, University of California, Berkeley fully considered. Responsibility for the final content John Kosco, National Association of Home Builders rests entirely with the authoring committee and the Gary Liberson, Gnarus Advisors, LLC National Academies. Robert Pitt, University of Alabama
Preface Stormwater is dynamic and complex. Industrial stormwater monitoring in the MSGP. The committee stormwater is only a subset of the stormwater universe, collected information from individuals and stakeholder yet complexity is interwoven throughout its generation organizations representing various interests around the and management due to the wide range of industrial United States and heard from several state industrial classifications, the assortment of activities at specific stormwater permit regulatory agencies. Much has industrial sites, the sizes of these industrial sites, and changed since the first MSGP with respect to under- climate and weather variations. Regulation of industrial standing the science of stormwater and stormwater stormwater through the Multi-Sector General Permit treatment, pollutant quantification, and toxicity. The (MSGP) (EPA, 1995, 2000, 2008a, 2015d) provides committee considered these advancements and the federal guidelines that attempt to balance protection sensitive balance of environmental protection with of the environment without leading to excess burden business burden. In this report, the committee offers on industry. Concerns related to industrial stormwater recommendations to address some of the challenges and the MSGP were highlighted in a 2009 National of industrial stormwater, its discharge, and regulation. Research Council (NRC, 2009) report on stormwater in the United States. In 2017, a committee was created by the National Allen P. Davis, Chair Academies of Sciences, Engineering, and Medicine Committee on Improving the Next-Generation through support by the Environmental Protection EPA Multi-Sector General Permit for Industrial Agency to address several concerns related to the Stormwater Discharges ix
Contents ACRONYMS AND ABBREVIATIONS xiii SUMMARY 1 1 INTRODUCTION 9 The Clean Water Act and Industrial Stormwater Management, 9 Industrial Stormwater Monitoring in the MSGP, 11 Context for the Study, 18 Outline of the Report, 19 2 POLLUTANT MONITORING REQUIREMENTS AND BENCHMARK THRESHOLDS 21 Assessment of Current MSGP Benchmark Monitoring, 21 Context of Recent MSGP Data, 22 Improving Pollutant Monitoring Requirements, 26 Adjusting Benchmark Threshold Levels, 31 Conclusions and Recommendations, 42 3 STORMWATER SAMPLING AND DATA COLLECTION 45 Challenges of Quantifying Stormwater Pollutant Discharge, 45 Recommended Improvements to Sampling and Analysis Protocols, 49 Tiered Approach to Monitoring, 53 Updating and Upgrading Current Methods of Data Management, 62 Conclusions and Recommendations, 64 4 CONSIDERATION OF RETENTION STANDARDS IN THE MULTI-SECTOR GENERAL PERMIT 67 Stormwater Retention, 67 Retention Standards, 68 Merits of and Concerns About Retention for Industrial Stormwater, 69 Considerations for Retention at Industrial Sites, 72 Regulatory Context for Retention Standards, 77 Conclusions and Recommendations, 78 xi
xii CONTENTS REFERENCES 81 APPENDIXES A State Industrial Stormwater Permit Benchmark Monitoring Comparison 89 B Lists of Pollutants from Which Industries Self-Identified the Need for Monitoring in the 1992 Group Applications, Adapted from EPA Form 2F, 1992 93 C Monitoring Parameters Required in Environmental Protection Agency 2015 Multi-Sector General Permit 97 D 2015 Multi-Sector General Permit (MSGP) Data Analysis 101 E Additional Data on Technical Achievability of Treatment Stormwater Control Measures 137 F Biographical Sketches of Committee Members and Staff 149 G Disclosure of Conflict of Interest 153
Acronyms and Abbreviations AD activity description NAL numeric action level AIM Additional Implementation Measure NEL numeric effluent limitation NELAP National Environmental Laboratory BAT best available technology Accreditation Program BLM Biotic Ligand Model NetDMR Network Discharge Monitoring Report BM benchmark NPDES National Pollutant Discharge BMP best management practice Elimination System BOD5 biochemical oxygen demand (5 day) NURP Nationwide Urban Runoff Program CCL Contaminant Candidate List PAH polycyclic aromatic hydrocarbon CEC cation exchange capacity PCB polychlorinated biphenyl COD chemical oxygen demand COV coefficient of variation QA/QC quality assurance and quality control QISP Qualified Industrial Stormwater DMR discharge monitoring report Practitioner DOC dissolved organic carbon SCM stormwater control measure ELG effluent limitation guideline SIC standard industrial classification EMC event mean concentration SMC Stormwater Monitoring Coalition EPA Environmental Protection Agency SSC suspended sediment concentration SWPPP stormwater pollution prevention plan HDS hydrodynamic separator TBEL technology-based effluent limit IWTT Industrial Wastewater Treatment TDS total dissolved solids Technology Database TMDL total maximum daily load TOC total organic carbon MS4 municipal separate storm sewer system TSS total suspended solids MSGP Multi-Sector General Permit WQBEL water quality-based effluent limit NAICS North American Industrial Classification System xiii