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 PRESS
Washington, DC
www.nap.edu
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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: 978-0-309-48846-4
International Standard Book Number-10: 0-309-48846-X
Digital Object Identifier: https://doi.org/10.17226/25355
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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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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.
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, SESYNC—University 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
Acknowledgments
We would like to express our appreciation to the following people who provided presentations or public comment to the committee.
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:
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.
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, 2008a, 2015d) 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
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Contents
The Clean Water Act and Industrial Stormwater Management
Industrial Stormwater Monitoring in the MSGP
2 POLLUTANT MONITORING REQUIREMENTS AND BENCHMARK THRESHOLDS
Assessment of Current MSGP Benchmark Monitoring
Improving Pollutant Monitoring Requirements
Adjusting Benchmark Threshold Levels
Conclusions and Recommendations
3 STORMWATER SAMPLING AND DATA COLLECTION
Challenges of Quantifying Stormwater Pollutant Discharge
Recommended Improvements to Sampling and Analysis Protocols
Updating and Upgrading Current Methods of Data Management
Conclusions and Recommendations
4 CONSIDERATION OF RETENTION STANDARDS IN THE MULTI-SECTOR GENERAL PERMIT
Merits of and Concerns About Retention for Industrial Stormwater
Considerations for Retention at Industrial Sites
A State Industrial Stormwater Permit Benchmark Monitoring Comparison
C Monitoring Parameters Required in Environmental Protection Agency 2015 Multi-Sector General Permit
D 2015 Multi-Sector General Permit (MSGP) Data Analysis
E Additional Data on Technical Achievability of Treatment Stormwater Control Measures
Acronyms and Abbreviations
AD | activity description |
AIM | Additional Implementation Measure |
BAT | best available technology |
BLM | Biotic Ligand Model |
BM | benchmark |
BMP | best management practice |
BOD5 | 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 |
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 |
TDS | total dissolved solids |
TMDL | total maximum daily load |
TOC | total organic carbon |
TSS | total suspended solids |
WQBEL | water quality-based effluent limit |
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