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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Suggested Citation:"Front Matter." 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: 10.17226/25355.
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Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

PREPUBLICATION COPY 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 This prepublication version of Improving the EPA Multi-Sector General Permit for Industrial Stormwater Discharges was provided to the public to facilitate timely access to the publication. Although the substance of the publication is final, editorial changes may be made throughout the text and citations will be checked prior to publication. The final publication will be available through the National Academies Press later this year, 2019. A Consensus Study Report of

THE NATIONAL ACADEMIES PRESS 500 Fifth Street, NW Washington, DC 20001 Support for this activity was provided by the Environmental Protection Agency. Any opinions, findings, 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: International Standard Book Number-10: 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; Internet, 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 PREPUBLICATION COPY

The National Academy of Sciences was established in 1863 by an Act of Congress, signed by President Lincoln, as a private, nongovernmental institution to advise the nation on issues related to science and technology. Members are elected by their peers for outstanding contributions to research. Dr. Marcia McNutt is president. The National Academy of Engineering was established in 1964 under the charter of the National Academy of Sciences to bring the practices of engineering to advising the nation. Members are elected by their peers for extraordinary contributions to engineering. Dr. C. D. Mote, Jr., is president. The National Academy of Medicine (formerly the Institute of Medicine) was established in 1970 under the charter of the National Academy of Sciences to advise the nation on medical and health issues. Members are elected by their peers for distinguished contributions to medicine and health. Dr. Victor J. Dzau is president. The three Academies work together as the National Academies of Sciences, Engineering, and Medicine to provide independent, objective analysis and advice to the nation and conduct other activities to solve complex problems and inform public policy decisions. The National Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in matters of science, engineering, and medicine. Learn more about the National Academies of Sciences, Engineering, and Medicine at www.nationalacademies.org. PREPUBLICATION COPY

Consensus Study Reports published by the National Academies of Sciences, Engineering, and Medicine document the evidence-based consensus on the study’s statement of task by an authoring committee of experts. Reports typically include findings, conclusions, and recommendations based on information gathered by the committee and committee deliberations. Each report has been subjected to a rigorous and independent peer review process and it represents 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 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 nationalacademies.org/whatwedo. PREPUBLICATION COPY

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 (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, 1 University of California, Los Angeles XAVIER SWAMIKANNU, University of California, Los Angeles; CalEPA, 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 1 See Appendix G, Disclosure of Conflict of Interest. v PREPUBLICATION COPY

vi Acknowledgments WATER SCIENCE AND TECHNOLOGY BOARD CATHERINE L. KLING, NAS, Chair, Cornell University NEWSHA K. AJAMI, Cornell University JONATHAN D. ARTHUR, Florida Geological Survey FRANCINA DOMINGUEZ, University of Illinois DAVID A. DZOMBAK, NAE, Carnegie Mellon University WENDY D. GRAHAM, University of Florida MARK W. LeCHEVALLIER, Dr. Water Consulting, LLC MARGARET A. PALMER, University of Maryland, Annapolis DAVID L. SEDLAK, NAE, University of California, Berkeley DAVID L. WEGNER, Jacobs Engineering P. KAY WHITLOCK, Christopher B. Burke Engineering, Ltd. 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 PREPUBLICATION COPY

Acknowledgments We would like to express our appreciation to the following people who provided presentations or public comment to the committee. Fredric Andes, Barnes & Thornburg William Ashton, Alaska Department of Environmental Conservation Jim Bachhuber, Brown and Caldwell June Bergquist, Idaho Department of Environmental Quality Jim Bertolacini, Wisconsin Department of Natural Resources Kevin Bromberg, Small Business Administration Seth Brown, Water Environment Federation and National Municipal Stormwater Alliance Patrick Burch, West Virginia Department of Environmental Protection Margarita Chatterton, Rhode Island Department of Environmental Management Brian D’Amico, Branch Chief, Environmental Protection Agency (EPA’s) Office of Science and Technology Sebastian Donner, West Virginia Department of Environmental Protection Phillip Flanders, EPA David Flores, Center for Progressive Reform Peter Ford, EPA William W. Funderburk, Jr., Castellón & Funderburk LLP Greg Gearheart, CalEPA, California State Water Board Jenelle Hill, EPA Paul Hlavinka, Maryland Department of the Environmental Christopher Kloss, EPA Matthew Lentz, California Stormwater Quality Association Jeffrey Longsworth, Barnes & Thornburg James Maroncelli, Washington Department of Ecology Melinda Pagliarello, Airports Council International–North America Travis Porter, Washington Department of Ecology Bryan Rittenhouse, EPA Edan Rotenberg, Super Law Group Ken Schiff, Southern California Coastal Water Research Project Brian Schweiss, Minnesota Pollution Control Agency Timothy Simpson, GSI Environmental Richard Smith, Smith and Lowney Brandon Steets, Geosyntec Eric Strecker, Geosyntec Rachel Urban, EPA vii PREPUBLICATION COPY

viii Acknowledgments Eric Van Genderen, International Zinc Association Jack Waggener, AECOM David Wagger, Institute of Scrap Recycling Industries Laurel Warddrip, CalEPA, California State Water Board Melissa Wenzel, Minnesota Pollution Control Agency Ian Wren, San Francisco Baykeeper This Consensus Study Report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the National Academies of Sciences, Engineering, and Medicine in making each published report as sound as possible and to ensure that it meets the institutional standards for quality, objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We thank the following individuals for their review of this report: Peter deFur, Environmental Stewardship Concepts, LLC Shawn Gibbs, Indiana University Michael Hanemann, University of California, Berkeley John Kosco, National Association of Home Builders Gary Liberson, Gnarus Advisors, LLC Robert Pitt, University of Alabama Arthur W. Ray, City of Rockville Kenneth Schiff, Southern California Costal Water Research Project Brandon Steets, Geosyntec Consultants Eric Strecker, Geosyntec Consultants Melissa Wenzel, Minnesota Pollution Control Agency Although the reviewers listed above provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations of this report nor did they see the final draft before its release. The review of this report was overseen by George Hornberger (NAE), Vanderbilt University and Michael Kavanaugh (NAE), Geosyntec Consultants. They were responsible for making certain that an independent examination of this report was carried out in accordance with the standards of the National Academies and that all review comments were carefully considered. Responsibility for the final content rests entirely with the authoring committee and the National Academies. PREPUBLICATION COPY

Preface Stormwater is dynamic and complex. Industrial stormwater is only a subset of the stormwater universe, yet complexity is interwoven throughout its generation and management due to the wide range of industrial classifications, the assortment of activities at specific industrial sites, the sizes of these industrial sites, and climate and weather variations. Regulation of industrial stormwater through the Multi-Sector General Permit (MSGP, EPA, 1995, 2000, 2008, 2015) provides federal guidelines that attempt to balance protection of the environment without leading to excess burden on industry. Concerns related to industrial stormwater and the MSGP were highlighted in a 2009 National Research Council (NRC, 2009) report on stormwater in the United States. In 2017, a committee was created by the National Academies of Sciences, Engineering, and Medicine through support by the Environmental Protection Agency, to address several concerns related to the stormwater monitoring in the MSGP. The committee collected information from individuals and stakeholder organizations representing various interests around the United States and heard from several state industrial stormwater permit regulatory agencies. Much has changed since the first MSGP with respect to understanding the science of stormwater and stormwater treatment, pollutant quantification, and toxicity. The committee considered these advancements and the sensitive balance of environmental protection with business burden. In this report, the committee offers recommendations to address some of the challenges of industrial stormwater, its discharge, and regulation. Allen P. Davis, Chair Committee on Improving the Next-Generation EPA Multi-Sector General Permit for Industrial Stormwater Discharges ix PREPUBLICATION COPY

Contents ACRONYMS AND ABBREVIATIONS xiii SUMMARY 1 1 INTRODUCTION 11 The Clean Water Act and Industrial Stormwater Management, 11 Industrial Stormwater Monitoring in the MSGP, 16 Context for the Study, 23 Outline of the Report, 24 2 POLLUTANT MONITORING REQUIREMENTS AND BENCHMARK THRESHOLDS 27 Assessment of Current MSGP Benchmark Monitoring, 27 Context of Recent MSGP Data, 30 Improving Pollutant Monitoring Requirements, 34 Adjusting Benchmark Threshold Levels, 40 Conclusions and Recommendations, 53 3 STORMWATER SAMPLING AND DATA COLLECTION 57 Challenges of Quantifying Stormwater Pollutant Discharge, 57 Recommended Improvements to Sampling and Analysis Protocols, 62 Tiered Approach to Monitoring, 68 Updating and Upgrading Current Methods of Data Management, 79 Conclusions and Recommendations, 82 4 CONSIDERATION OF RETENTION STANDARDS IN THE MSGP 85 Stormwater Retention, 85 Retention Standards, 86 Merits and Concerns of Retention for Industrial Stormwater, 89 Considerations for Retention at Industrial Sites, 91 Regulatory Context for Retention Standards, 97 Conclusions and Recommendations, 99 REFERENCES 101 APPENDIXES A State Industrial Stormwater Permit Benchmark Monitoring Comparison 113 x PREPUBLICATION COPY

Contents xi B Lists of Pollutants from Which Industries Self-Identified the Need for Monitoring in the 1992 Group Applications, Adapted from EPA Form 2F, 1992 117 C Monitoring Parameters Required in EPA 2015 Multi-Sector General Permit 121 D 2015 Multi-Sector General Permit Data Analysis 125 E Additional Data on Technical Achievability of Treatment Stormwater Control Measures 165 F Biographical Sketches of Committee Members and Staff 177 G Disclosure of Conflict of Interest 181 PREPUBLICATION COPY

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Acronyms and Abbreviations AD activity description AIM Additional Implementation Measure BAT best available technology BLM Biotic Ligand Model BM benchmark BMP best management practices BOD 5 biochemical oxygen demand (5 day) CCL Contaminant Candidate List CEC cation exchange capacity COD chemical oxygen demand COV coefficient of variation DMR discharge monitoring report DOC dissolved organic carbon ELG effluent limitation guideline EMC event mean concentration EPA Environmental Protection Agency HDS hydrodynamic separator IWTT Industrial Wastewater Treatment Technology Database MS4 municipal separate storm sewer system MSGP Multi-Sector General Permit NAICS North American Industrial Classification System NAL numeric action level NEL numeric effluent limitation NELAP National Environmental Laboratory Accreditation Program NetDMR Network Discharge Monitoring Report NPDES National Pollutant Discharge Elimination System xiii PREPUBLICATION COPY

xiv Acronyms and Abbreviations NURP Nationwide Urban Runoff Program PAH polycyclic aromatic hydrocarbon PCB polychlorinated biphenyl QA/QC quality assurance and quality control QISP Qualified Industrial Stormwater Practitioner SCM stormwater control measure SIC standard industrial classification SMC Stormwater Monitoring Coalition SSC suspended sediment concentration SWPPP stormwater pollution prevention plan TBEL technology-based effluent limit TMDL total maximum daily load TDS total dissolved solids TOC total organic carbon TSS total suspended solids WQBEL water-quality-based effluent limit PREPUBLICATION COPY

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Industrial stormwater is derived from precipitation and/or runoff that comes in contact with industrial manufacturing, processing, storage, or material overburden and then runs offsite and enters drainage systems or receiving waters. In 1987, Congress significantly expanded the National Pollutant Discharge Elimination System (NPDES) program through amendments to the Clean Water Act to include industrial stormwater runoff conveyed through outfalls directly to receiving waters or indirectly through municipal separate storm sewer systems.

The added regulation of stormwater in the NPDES program has been challenging. Stormwater is produced throughout a developed landscape, and its production and delivery are episodic. In 2009, the National Research Council released a comprehensive report on the Environmental Protection Agency’s Stormwater Program that covered all sectors of the program. This study builds on that report, with a focus on industrial stormwater monitoring and management.

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