This Technical Bulletin presents a visual method to assess the need for stormwater pollution practices, retrofits and stewardship at existing industrial, institutional, federal and municipal facilities. Tens of thousands of these facilities exist across the Chesapeake Bay watershed, each of which has the potential to be severe stormwater hotspots, which are defined as a site that generates higher loads of pollutants and toxics, and/or has a higher risk of leaks, spills or illicit discharges. Despite the impact of stormwater hotspots on the receiving waters of the Bay, they have not been effectively regulated or managed for several reasons.
While as many as 30,000 facilities in the Bay are technically regulated under EPA’s industrial or municipal stormwater permit programs, most individual permits do not contain specific monitoring requirements or numeric limits on effluent quality. Thus, at many sites, all that is needed to comply with the permit is to make sure you have a paper document known as a stormwater pollution prevention plan present on your site. The chances that a local or state regulator will inspect your site are vanishingly small (National Research Council, 2008). Even if sites are inspected, the permits do not require any site specific or quantitative measurements to determine whether runoff is dirty or reasonably clean, which makes it difficult to trigger enforcement actions.
A second key issue is that many property managers and environmental compliance officers simply don’t understand that much about stormwater, in comparison with more traditional environmental health and workplace safety issues they must deal with every day (e.g., hazardous waste storage and disposal and spill response). Few good training materials have been developed on site-based stormwater pollution prevention techniques, and even fewer tools exist to diagnose the actual stormwater pollution problems present at a site. Consequently, there is a strong need for a quantitative diagnostic tool to assess stormwater pollution problems and identify site-specific and cost-effective solutions.
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