| Abstract: | ABSTRACT: Nonstorm water discharges to municipal separate storm sewer systems (MS4s) are notable for spatial and temporal variability in volume, pollutant type, pollutant concentration, and activity of origin. The objective of this paper was to determine whether current technical knowledge and existing U.S. policy support an improved regulatory approach. The proposed policy would use type of discharge as a regulatory basis, merging the concepts of allowability of de minimis discharges and type-based statewide consistent rules. Specific research objectives were to comprehensively identify discharge types, characterize their prevalence in California, analyze relevant local and regional regulatory guidelines, and systematically evaluate opinions of experts about potential water quality impacts. Results demonstrate nonstorm water discharges were widespread in at least one sector, industrial facilities subject to a state permit; one discharge for every four facilities was reported in 1995, even though the permit explicitly prohibits such discharges. Clear consensus exists for minimal water quality concern for some discharge types when considering both municipal guidelines and experts’ opinions. In particular, condensate from a wide range of equipment and discharges from fire fighting equipment testing were found to be of low concern. Discharge types with consensus high concern were largely limited to discharges prohibited under other regulations, such as wastewater and hazardous waste management controls. Some discharge types where no consensus was identified, such as landscape irrigation, nevertheless generated concern for water quality impacts and appear to be relatively widespread. Available information supports technical feasibility of the proposed policy because at least some discharge types show strong consensus for de minimis impacts among regulatory guidelines and opinions of technical experts. |
