Regulating Industrial Stormwater: State Permits,Municipal Implementation,and a Protocol for Prioritization1

Abstract:  This research evaluated the effectiveness of regulations for stormwater pollutants originating from industrial facilities. Industrial facilities discharging stormwater are subject to General Permits implemented by state and federal agencies, which require facility operators to identify themselves and to implement pollution prevention measures. An overlying system of permits require Municipal Separate Storm Sewer System operators to identify and inspect facilities in their jurisdictions capable of discharging substantial pollutant loads into stormwater conveyances, introducing more active regulation and strategic prioritization, but with unequal implementation in different urban regions. This research evaluated the interaction between the regulations and ways in which the regulations succeed, or fail, at protecting water quality. The research evaluated potential for pollutant discharges at 136 industrial facilities in Pinellas County, Florida, using telephone interviews; off-site facility visits; and on-site facility inspections, targeting four industrial categories: wood products; stone, clay, glass, and concrete products; fabricated metal products; and electronic products. Results documented that a large proportion of facilities subject to General Permits conduct few or no activities likely to produce stormwater pollutants, indicating that the regulations’ equal treatment of all facilities may constitute overregulation. The research developed a methodology to assess facilities using intensity of industrial activities exposed to stormwater, a rational measurement that could regularize municipal agencies’ requirements and prioritize implementation toward facilities with the potential to impact receiving water quality.