Earlier this month, ISRI addressed The National Academies’ Stormwater Committee on the difficulties confronting the recycling industry on industrial stormwater permitting.
ISRI’s presentation took place during the fourth meeting of the Stormwater Committee, which is charged by EPA with recommending improvements for the next version (expected 2020) of EPA’s Multi-Sector General Permit (MSGP). ISRI reviewed the recycling industry’s involvement in stormwater permitting in the early 1990s and development of substantial best management practices (BMPs) for the industry that became part of the Federal MSGP. ISRI noted that benchmarks values for metals are unrelated to the inherent effectiveness of BMPs and are essentially equivalent to water quality standards. The current stormwater permitting program does not recognize the essential differences between wet-weather stormwater discharges and dry-weather wastewater discharges, on which the existing stormwater permitting program is based. As a consequence, permittees generally lack certainty that making certain stormwater investments will result in stormwater discharges that meet current benchmarks. This lack of certainty has significant consequences due to potential threats of Clean Water Act third-party lawsuits. ISRI recommended a number of potential options for the next MSGP: allowing mixing zones where applicable, providing wet-weather adjustments to benchmark values; setting benchmark values consistent with BMPs’ effectiveness; allowing correction for background and run-on sources; and allowing permits with audited performance in lieu of benchmark monitoring.
For members seeking assistance with stormwater management, ISRI offers stormwater information, guidance, and tools
. For more information, please contact David Wagger
, Chief Scientist/Director of Environmental Management, at (202) 662-8533.