Finding the Needle in the Haystack! Lessons Learned from Implementing the Industrial Permit and Recommendations for Source Identification Improvement
The recent adoption and implementation of the new Industrial General Permit presents significant challenges to stormwater stakeholders, including both existing and new industrial permittees, municipalities, and the State Water Board and Regional Water Quality Control Board’s staff. Industrial Permittees are required to assess their potential pollutants and assess their discharge contributions to receiving waters. Additionally, Industrial Permittees need to determine whether they discharge to a Clean Water Act Section 303(d) Impaired waterbody and determine if additional constituents for sampling and analysis are required. During the implementation of Storm Water Pollution Prevention Plans (SWPPPs), it was evident there are significant gaps in the resources available to Industrial Permittees. There is a clear nexus between the Municipality and the Industrial Permittee in that Municipalities are often faced with the charge of implementing Total Maximum Daily Loads (TMDLs) and are often looking upstream to identify potential pollutant sources and needed pollutant reductions. With TMDLs still to be addressed in the Industrial Permit, there is an opportunity to refine the Industrial Permit to enhance the effectiveness of Permit implementation. Industrial Permittees are required to identify their discharge locations, assess potential pollutants from industrial activities, and collect, analyze, and report on discharge water quality.
A Geographic Information System (GIS) is an example of an important tool used for assessing the discharge points and determining flow pathways to receiving waters. While many Phase I Permits require municipalities to develop a GIS of their MS4 system, accessibility to these features by Industrial Permittees and the general public varies by municipality from being widely accessible to non-existent. Additionally, the Industrial Permit does not clarify the extent of the receiving waters applicability. SRWCB staff have verbally indicated that the HUC10 watershed is the applicable extent to which a discharger should be concerned with and they have indicated they will be developing a tool through the SMARTS on-line system to help identify the Industrial Permittees responsibilities.
This presentation is applicable to Industrial Permittees, Municipalities, and State Water Board staff. The presentation demonstrates the importance of accurate data when developing site maps for analyzing site discharge characteristics and potential confounding factors within a site drainage area (e.g., run-on areas, potential cross-connections, co-mingled flows, and routes to receiving waters). Municipalities can benefit from providing access to their GIS layers to Industrial Permittees, helping them understand where their discharge goes, and also benefiting the Municipality by receiving updated information for their GIS. Many GIS layers observed require updated information. A demonstration of QGIS, a free open source software tool will be presented showing why Municipal GIS data are needed, how effective it can be, and the benefits for updating the municipality’s storm drain layers and Industrial Permittee site maps. As Industrial Permittees begin to evaluate their discharges in comparison to Numeric Action Levels, understanding potential sources will also be important for determining whether best management practices are effective or whether potential confounding factors exist during implementation of future Exceedance Response Actions. A review of potential sources beyond the industrial activities will be discussed through an interactive session including review of common and not so common pollutant sources such as architectural products, natural background sources, aerial deposition, run-on, and even the BMPs themselves and how GIS can support these evaluations.