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Title:
Effectiveness of environmental regulations monitoring by the regulated community under clean water act industrial stormwater runoff requirements
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Book
Language:
English
Creator:
Gleaton, Kelly L
Publisher:
University of South Florida
Place of Publication:
Tampa, Fla
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Subjects

Subjects / Keywords:
Industrial pollution
Water quality monitoring
Industry compliance
Visual examination
Stormwater runoff
Dissertations, Academic -- Environmental Science and Policy -- Masters -- USF
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bibliography   ( marcgt )
theses   ( marcgt )
non-fiction   ( marcgt )

Notes

Abstract:
ABSTRACT: This research identified and evaluated possible uses of environmental monitoring data collected and reported by industrial facilities under the Clean Water Act requirements and determined whether the current regulatory system supported any of those uses. Federal policies and state-level policies in the United States, Florida, and California were evaluated in order to determine whether the current regulatory system supported any of the identified uses. Monitoring programs and currently available monitoring data were evaluated from Hillsborough County, Florida, and Los Angeles County, California, from the perspective of 1) the current implementation of the monitoring program, and 2) perfect implementation under full compliance with the monitoring program. Four possible uses for monitoring data were identified by this research: (1) identification of high polluting facilities within a given jurisdiction, (2) assessment of pollutant load to receiving waterbodies, (3) documentat ion of improvement over time in the amount of pollutants discharged from a given industrial facility, (4) self-evaluation purposes, such as identifying on-site pollutant sources, adapting pollution prevention efforts, and evaluating the monitoring protocol. The research conducted a telephone survey and evaluated industrial facilities' reported analytical monitoring data. Telephone questionnaires were administered to 63 industrial facilities, and analytical monitoring data were obtained from industrial facilities in Hillsborough County, Florida and Los Angeles County California. The representativeness, sampling frequency and variation in the industrial facilities' analytical monitoring data do not assist in the identification of high polluting facilities within a given jurisdiction nor provide for documentation of facilities' improvements. Pollutant loads to receiving watebodies can not be assessed through the use of industrial facilities' analytical monitoring data because of the sampl e measurement, variation, and sample frequency of the data. Therefore, these uses can not be supported under current implementation/current data submitted or under perfect compliance. However, the telephone survey revealed facility operators are attempting to use the results from monitoring for self evaluation purposes.
Thesis:
Thesis (M.S.)--University of South Florida, 2006.
Bibliography:
Includes bibliographical references.
System Details:
System requirements: World Wide Web browser and PDF reader.
System Details:
Mode of access: World Wide Web.
Statement of Responsibility:
by Kelly L. Gleaton.
General Note:
Title from PDF of title page.
General Note:
Document formatted into pages; contains 123 pages.

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University of South Florida
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All applicable rights reserved by the source institution and holding location.
Resource Identifier:
aleph - 001914732
oclc - 176972929
usfldc doi - E14-SFE0001762
usfldc handle - e14.1762
System ID:
SFS0026080:00001


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Effectiveness of Environmental Regulations: Monitoring by the Regulated Community under Clean Water Act Industrial Stormwater Runoff Requirements by Kelly L. Gleaton A thesis submitted in partial fulfillment of the requirements for the degree of Master of Science Department of Environmental Science and Policy College of Arts and Sciences University of South Florida Major Professor: L. Donald Duke, Ph.D. Michael Miller, Ph.D. Rick Oches, Ph.D. Date of Approval October 12, 2006 Keywords: industrial pollution, water quality monitoring, industry compliance, visual examination, stormwater runoff @ Copyright 2006, Kelly L. Gleaton

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ACKNOWLEDGEMENTS To my endearing and wonderful family, Lee, Carolyn, and Chris Gleaton, thank you for your never ending support, encouragement and love for me through this accomplishment and though life. I would not be where I am t oday with out such an outstanding family. I love you! Thank you to my dear family and friends who have been my support group through my schooling and through life. Thank you! I would like to thank Dr. L. Donald Duke for his expe rience and assistance in guiding this research in the direction it went. His knowledge of industrial facilities, stormwater and stormwater regulations wa s tremendously valuable and a key to the success of my research. I greatly appreciate his time and assistance. Special thanks to Dr. Rick Oches and Dr. Michael Miller for their en couragement, support, assistance and time. Thank you to Steven Kelly at FDEP Stor mwater Division and SAIC Consulting in assisting me in obtaining anal ytical monitoring data and prov iding insightful information regarding stormwater. Hillsborough County and Pinellas County Florida industrial facilities for their tim e and participation. A special thanks to the Golder Associ ates Tampa Office, especially Richard Zwolak and Carron Day, for their continue d support throughout my master degree experience.

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A big thanks to student D’Nara Manni ng for her assistance with my research, review of my thesis and her supportive a dvice, also, Lindsay Cross for her support and experience with stormwater and Carla Beals fo r her assistance in reviewing my thesis. Additional support was provided by the faculty and staff of the USF ESP department, especially Karen Schrader. One last additional thank you goes to Adam Hartman for his support and understanding during all my academic endeavors, especially my research.

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iv TABLE OF CONTENTS LIST OF TABLES.............................................................................................................iv LIST OF FIGURES.............................................................................................................v ABSTRACT....................................................................................................................... vi 1.0 INTRODUCTION...................................................................................................1 2.0 LITERATURE REVIEW........................................................................................5 2.1 Stormwater Pollutants.....................................................................................5 2.2 Federal Stormwater Regulations.....................................................................8 2.2.1 Regulations for Industria l Discharges: Phase I....................................9 2.2.1.1 Industrial Permit Applica tion Options under Phase I..............11 2.2.1.1.1 Option 1.................................................................11 2.2.1.1.2 Option 2.................................................................11 2.2.1.1.3 Option 3.................................................................13 2.2.2 Regulations for Industrial Discharges: Phase II.................................14 2.2.3 Permit Approaches.............................................................................14 2.2.4 Compliance.........................................................................................16 2.3 Stormwater Regulation at the State Level....................................................17 2.3.1 Florida MSGP.....................................................................................17 2.3.2 Stormwater Pollution Prevention Plan...............................................19 2.3.2.1 Best Management Practices.....................................................20 2.3.3 Monitoring Requirements under the FL MSGP.................................21 2.3.3.1 Sample Type............................................................................21 2.3.3.2 Visual Examination..................................................................21 2.3.3.3 Analytical Monitoring..............................................................22 2.3.3.4 Compliance Monitoring...........................................................23 2.3.4 Monitoring Requirements under CA MSGP......................................24 2.3.4.1 CA SWPPP..............................................................................24 2.3.4.1 CA Monitoring Program..........................................................25 3.0 METHODOLOGY................................................................................................26 3.1 Possible Uses of the Monitoring Data..........................................................26 3.1.1 Identification of High Polluting Facilities..........................................27 3.1.2 Assessment of Pollutant Loads to Receiving Waterbodies................28 3.1.3 Documentation of Improvement........................................................30 3.1.4 Self Evaluation...................................................................................31 3.2 Telephone Survey.........................................................................................33 3.3 Analytical Monitoring Data..........................................................................35

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vii 4.0 RESULTS 37 4.1 Identification of High Polluting Faci lities within a Given Jurisdiction........37 4.1.1 Identification of Potential Hi gh Polluting Industr ial Facilities in a Jurisdiction..................................................................................38 4.1.1.1 Identification of Industr ial Facilities within a Jurisdiction...............................................................................38 4.1.1.2 Industrial Facilities Requ ired to Conduct Analytical Monitoring...............................................................................45 4.1.2 Evaluation of Analytical M onitoring Data In Identifying Potential High Polluting Facilities.....................................................47 4.1.2.1 Identification of Industria l Facilities with Highest Concentrations of Pollutants in Their Discharge.....................47 4.1.2.2 Representativity of Data..........................................................50 4.1.2.3 Sampling Frequency................................................................51 4.1.2.4 Storm Variability.....................................................................53 4.2 Assessment of Pollutant Loads to Receiving Waterbodies...........................54 4.2.1 Identification of Potentia l Pollutant Contributors..............................54 4.2.1.1 Industry Sectors and SICs Required to Conduct Analytical Monitoring..............................................................54 4.2.1.2 Facilities within a Give n Jurisdiction Required to Conduct Analytical Monitoring...............................................55 4.2.1.3 Identification of Required Parameters to be Analyzed by Sectors or Subsectors/SICs.................................................55 4.2.2 Evaluation of Current Analyti cal Monitoring Results for Load Assessment.........................................................................................58 4.2.2.1 Measure of Concentration vs. Load.........................................58 4.2.2.2 Sample Frequency and Representativity..................................59 4.3 Documentation of Improvement...................................................................59 4.3.1 Monitoring Specified by MSGP.........................................................60 4.3.2 Telephone Survey...............................................................................61 4.4 Self-Evaluation.............................................................................................65 4.4.1 Visual Observations of the Facility....................................................65 4.4.2 Visual Examinations...........................................................................68 4.4.3 Analytical Monitoring........................................................................70 4.4.4 Training..............................................................................................72 4.4.5 Uses of the Data.................................................................................73 5.0 DISCUSSION........................................................................................................77 5.1 Facility Operator’s Knowledge of Stormwater Regulations.........................77 5.2 Structure of stormwater regulations..............................................................78 5.3 Limitations....................................................................................................80 5.4 Future Research............................................................................................81 5.5 Recommendations.........................................................................................82 6.0 CONCLUSIONS....................................................................................................84

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vii REFERENCES..................................................................................................................90 BIBLIOGRAPHY..............................................................................................................93 APPENDICES...................................................................................................................98 Appendix 1: List of Acronyms.............................................................................99 Appendix 2: Introductory Letter to Hillsborough County Industries.................101 Appendix 3: Telephone Questionnaire ..............................................................102

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vii LIST OF TABLES Table 2.3.3.3.1 MSGP Industry Sector/S ubsector Subject to Analytical Monitoring ....................................................................................22 Table 3.2.1 Telephone Survey Outcome...........................................................34 Table 4.1.1.1.1 NOIs Filed......................................................................................38 Table 4.1.1.1.2 Target SICs in Hillsborough County and Los Angeles County............................................................................................41 Table 4.1.1.2.1 Hillsborough County Industrial Facilities Required to Conduct Analytical Monitori ng: Targeted Industrial Sectors, SICs, and Activities..........................................................45 Table 4.1.2.1.1 SICs with the Highest Concentrations...........................................48 Table 4.1.2.1.2 Three Highest Concentrations........................................................48 Table 4.2.1.3.1 Top Five Causes of Impa irments to Waterbodies in Florida and California ................................................................................57 Table 4.2.1.3.2 Top TMDL Parameters in Florida.................................................58 Table 4.4.1.1 Visual Observation Locations........................................................66 Table 4.4.2.1 Parameters Observed Duri ng Visual Examination: Number of Facilities Observing Each Parameter.........................................70 Table 4.4.3.1 Parameters Each Facility Analyzed...............................................72 Table 4.4.4.1 Types of Training Provided...........................................................73 Table 4.4.5.1 Facilities In dicating They Use the Analytical Monitoring Results............................................................................................74 Table 4.4.5.2 Facilities Indicating They Do Not Use the Analytical Monitoring Results.........................................................................74

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vii LIST OF FIGURES Figure 4.1.2.1 Three Highest Concentrations........................................................49 Figure 4.1.2.2 Example of Concentr ation Variation Facility H4..........................50

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vii EFFECTIVENESS OF ENVIRONMENTA L REGULATIONS MONITORING BY THE REGULATED COMMUNITY UNDER CLEAN WATER ACT INDUSTRIAL STORMWATER RUNOFF REQUIRMENTS Kelly L. Gleaton ABSTRACT This research identified and evaluated possible uses of environmental monitoring data collected and reported by industria l facilities under the Clean Water Act requirements and determined whether the cu rrent regulatory system supported any of those uses. Federal policies and state-level policies in the United States, Florida, and California were evaluated in order to determ ine whether the current regulatory system supported any of the identified uses. Mon itoring programs and currently available monitoring data were evaluated from H illsborough County, Florida, and Los Angeles County, California, from the perspective of 1) the current implementation of the monitoring program, and 2) perfect impl ementation under full compliance with the monitoring program. Four possible uses for monitoring data were identified by this research: (1) identification of high polluting facilities within a given ju risdiction, (2) assessment of pollutant load to receiving waterbodies, (3 ) documentation of improvement over time in the amount of pollutants discharged from a gi ven industrial facilit y, (4) self-evaluation purposes, such as identifying on-site pollu tant sources, adapting pollution prevention efforts, and evaluating the monitoring pr otocol. The research conducted a telephone survey and evaluated industrial facilities’ reported analytical mon itoring data. Telephone

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vii questionnaires were administered to 63 industr ial facilities, and an alytical monitoring data were obtained from industrial faci lities in Hillsborough County, Florida and Los Angeles County California. The representativeness, sampling freque ncy and variation in the industrial facilities’ analytical monitoring data do not assist in the identification of high polluting facilities within a given jurisdiction nor provide for documentation of facilities’ improvements. Pollutant loads to receiving watebodies can not be assessed through the use of industrial facilities ’ analytical monitoring data because of the sample measurement, variation, and sample frequency of the data. Therefore, these uses can not be supported under current implementation/cu rrent data submitted or under perfect compliance. However, the telephone survey reve aled facility operators are attempting to use the results from monitori ng for self evaluation purposes.

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1 1.0 INTRODUCTION Storm runoff has been identified as a l eading contributor of impairments to waterbodies of the U.S. Stor m runoff conveys pollutants orig inating from urban activities such as transportation, industry, and lawn fe rtilization during rain events into local waterbodies. The pollutants carried into th e waterbodies can have harmful effects on water resources and aquatic ecosystems. Runof f from urban areas is identified as the leading source of impairments to la kes and estuaries (U.S. EPA 1992b). Since the 1980s, industrial runoff has b een included in the Clean Water Act (CWA) policies for water quality protection and is recognized as a contributor to pollutants in urban runoff (NURP 1982). Stormwater re gulations are implemented through the National Pollutant Discharge El imination System (NPDES). The NPDES includes two different permits in order to re gulate stormwater runoff: the Environmental Protection Agency Multi Sector General Pe rmit ( U.S. EPA MSGP) and the Municipal Separate Storm Sewer System (MS4) permit. The MSGP and the MS4 were created to work in conjunction with one another. Every industrial facility is required to be in compliance with the stormwater U.S. EPA MSGP. First-stage compliance under th e U.S. EPA MSGP requires industrial facilities to recognize their dut y to comply by filing a notice of intent (NOI) with the regulatory agency. The U.S. EPA MSGP approach is implemented through NPDES to regulate the pollutants in facility storm disc harges. However, the U.S. EPA MSGP does

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2 not effectively achieve a high level of comp liance, specifically first-stage compliance (Duke et al, 1999a). Certain aspects of federal and state regulations allow prioritization in certain ways. One of the requirements of the operators of the MS4 is to identify and regulate facilities which are considered to be “hi gh risk” for generating stormwater pollutants (FLS0000006, 2002). Research is beginning to show that grouping by industry type fails to segregate high-polluting fac ilities from others, and many facilities continue to be unregulated (Griffin, 2005). Agenci es can effectively use their resources by focusing the on the high-polluting facili ties contributing the highest amounts of pollutants. Majore issues facing the stormwater pe rmit approach are (1 ) the definition of industrial facilities, (2) the usefulness of monitoring data and (3) agency compliance strategies. The definition of industrial facilities the United States Environmental Protection Agency (U.S. EPA) has used in order to implement the two NPDES permits incorporates many facilities that are not subject to stormwater regulations. The definition is based on the facilities St andard Identification Code (SIC). The SIC can make it difficult for agencies to accurately identify wh ich facilities are contri buting to stormwater pollution. Facilities must report under one primary SIC code which, in theory should represent their major profit generating activit y. However, facilities may perform other activities on-site that contribute pollutants to stormwater. The second issue facing the stormwater permit approach is the usefulness of industrial facility’s monitoring da ta. The SIC of an industrial f acility will determine if the facility is required to submit analytical monitoring data to the regulatory agency. However, many facilities are only required to analyze for one parameter. In addition,

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3 there are several sources for which variability could occur when monitoring such as: the use of grab samples, untrained sampling personal and limited selection of monitored parameters (Stenstrom, 2005). The third issue facing the stormwater permit approach is agency compliance strategies. The U.S. EPA has left compliance strategies up to the discretion of the local agencies/operators of the U.S. EPA MSGP and MS4. Agencies and counties or local municipalities take various approaches to achieve compliance with the U.S. EPA MSGP and MS4 permit. For example, the approach used by the Florida Department of Environmental Protection (FDEP) is to set up a sting-type operation in a particular location where the agency know s the facilities are not complying with the U.S. EPA MSGP, even after outreach and education has been conducted by the agency (Kelly, 2006). Another example is the MS4 approach is to start at one end of an agency’s jurisdiction and work thei r way across the area conducti ng on-site inspections of industrial facilities (Griffin, 2005). However, th is approach has proven to be ineffective at reaching a large number of facilities in a years time. Another attempt at the county level has been to use the current Small Quant ity Generators list (SQG) to satisfy the MS4 requirements, which includes many facilities not subject to the st ormwater regulations (Glicksburg, 2005). This research will evaluate policies in th e U.S., Florida, and California intended to terminate pollution associated with stormwat er runoff from industrial facilities. This research will be a means of enhancing the e ffectiveness of current activities now required to be conducted by industrial facilities in order to comp ly with NPDES stormwater

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4 permits. The overall objective is to evaluate the possible uses of monitoring data and determine whether the current program is meeting any of those uses. The first specific objective was to evaluate the extent to which industrial facilities monitoring data collected under the regulations for stormwater discharges associated with industrial activities can support the goals and objectives of those regulations, and to identify ways in which the data do and do not support those goals and objectives. The research evaluated the monitoring programs from two viewpoints: firs t, whether the goals and objectives of the regulations are supported by the data as currently available, given the current implementation of the monitori ng program under the industrial stormwater regulations; and second, whether the goals and objectives of the regulations would be supported if the regulatory requirements were perfectly implemented under full compliance with the regulations as designed and intended. The second specific objective was to eval uate the extent to which industrial facilities monitoring data can support the needs or goals of related policies and regulations of the United Stat es, such as other Clean Wate r Act regulations or other policies designed to protect water quality. Th e monitoring programs were evaluated from the same two viewpoints, assessing the data as currently collect ed and evaluating the data’s potential usef ulness under the case of perfect compliance with the monitoring requirements of the regulations. The third specific objective was to assess th e attitudes of the regulated community toward the monitoring requirements and the exte nt to which they make use of the results of their required monitoring. This objective evaluates one other category of use of the monitoring requirements that has been identifi ed as a potential benef it of the regulations.

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5 2.0 LITERATURE REVIEW The USEPA defines stormwater discha rges as discharges “generated by precipitation and runoff from land, pavements, building rooftops and other impervious surfaces. Storm water runoff accumulates polluta nts such as oil and grease, chemicals, nutrients, metals, and bacteria as it travels across land. Hea vy precipitation or snowmelt can also cause sewer overflows which, in tu rn, may lead to contamination of water sources with untreated human and industrial waste, toxic materials, and other debris” (U.S. EPA, 2005). 2.1 Stormwater Pollutants During the 1960s, people were becoming concerned and began to raise awareness of stormwater issues as they realized thei r local waterbodies were beginning to become polluted (NURP, 1982). Stormwater conveys a variety of pollutants through stormwater runoff from various activities conducted out side. The pollutants conveyed by stormwater runoff can have a detrimental effect on rece iving waterbodies. Prior to the 1960s, most reports and articles gave little consideration to the level of improvement attainable for stormwater or the need to improve the qua lity of the receiving waterbodies. Since stormwater controls for water quality ha d been implemented in only a few places throughout the nation, there was not enough information known a bout stormwater runoff. The NPDES permit program was created in 1972 under the CWA to control water pollution by regulating point sources that disc harge pollutants into waters of the United States. Point sources are defi ned as discrete conveyances such as pipes or man-made

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6 ditches. Industrial, municipal, and other faci lities must obtain permit coverage if their discharges go directly into surface waters of the U.S. (U.S. EPA, 2005). When the CWA was enacted, stormwater was not originally c onsidered to be a point source. Not until the reauthorization of the CWA 1987 did stormwat er become defined as a point source. The lack of knowledge regarding the impacts of stormwater led to the development of the Nationwide Urban R unoff Program (NURP) (NURP, 1982). The overall goal of NURP was to provide information to local decision makers, states, the U.S. EPA, and other interested parties in or der to determine if urban runoff was causing water quality problems. NURP also provided a basis for postulating realistic control options and the development of water quality management plans that were consistent with local needs and that would, in turn lead to the implementation of least cost solutions (NURP, 1982). The NURP study led to the following seven conclusions: 1. Heavy metals including coppe r, lead, and zinc are the most prevalent priority pollutant constituents found in urban runoff. End-of-pipe concentrations exceed U.S. EPA ambient water quality criteria and drinking water standards in many instances. Some of the metals were not present enough and in high concentrations to be considered potential threats to beneficial us es of the waterbodies. 2. The organic priority pollutants were de tected less frequently and at lower concentrations than the heavy metals. 3. Coliform bacteria were present at high le vels in urban runoff and were expected to exceed U.S. EPA water quality criter ia during and immediately after storm events in many surface waters.

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7 4. Nutrients were generally present in urban runoff, but with a few individual site exceptions, concentrations did not appear to be high in comparison with other possible discharges to receiving water bodies. 5. Oxygen demanding substances were presen t in urban runoff at concentrations approximating those in secondary treatment plant discharges. 6. Total suspended solids concentrations in urban runoff are fairly high in comparison with treatment plant discharges. 7. A summary characterization of urban runoff has been developed and is believed to be appropriate to use in estimating ur ban runoff pollutant discharges from sites where monitoring data are scant or lacking (NURP, 1982). Effects of urban runoff on receiving wa ter quality are highly site specific and depend on the type, size, and hydrology of the water body. The effects also depend on the urban runoff quantity and quality characteristic s, the designated beneficial use, and the concentration levels of the specific pollutant s that affect that us e. Observations and conclusions were drawn by indi vidual NURP projects that ex amined the receiving waters effects in differing levels of detail and rigor. Conclusions were based on water type: rivers and streams, lakes, estuaries, and embayments, and groundwater aquifers (NURP, 1982). NURP increased knowledge of the characteri stics of urban runoff, its effects on designated uses, and performance efficiencies of selected control measures (NURP, 1982). NURP was the pioneer of stormwater resear ch and served as the catalyst to better

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8 understand urban runoff. In the 1992 Report to C ongress, states took a more active role in stormwater issues and its impacts. The National Water Quality Inventory (Inventory) provides a national assessment of surface water impacts associated with runo ff from various land uses. Section 305(b) of the CWA requires states to prepare this re port every two years summarizing their water impact findings. The Inventory 1992 Report to Congress provides a general assessment of water quality based on state reports. The reports indicate the portion of the states’ water that has been assessed are not supporting their designate d uses and identifies the sources of impairment for those waters (U.S. EPA, 1995). The Inventory 1992, states concluded that water runoff fr om a number of diffuse sour ces is the leading cause of water quality impairment. The diffuse source s of runoff include agricultural, municipal separate storm sewers, urban runoff, and atmospheric deposition (U.S. EPA, 1995). 2.2 Federal Stormwater Regulations In 1972, the CWA prohibited the discharge of any pollutant to navigable waters of the United States from a point source unle ss the discharge is authorized by a NPDES permit issued under Section 402 of the CWA. Point sources contributing to water pollution by discharging pollutants into wate rs of the U.S. are regulated under the NPDES permit program (U.S. EPA, 2005). U.S. EPA defines point sources as discrete conveyances such as pipes or man-made ditc hes (U.S. EPA, 2005). Industrial, municipal, and other facilities must obtain permit coverage if their discharges go directly to surface waters. States must receive authorization fr om the U.S. EPA in order to implement the

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9 NPDES permit program themselves. The NPDES permit program has been responsible for significant improvements to our Nati on’s water quality (U.S. EPA, 2005). Regulation of storm runoff as a separa te class under the CWA began when a series of regulations addressing discharges from separate storm sewers (March 18, 1976, 41 FR11307), concentrated animal feeding operations (CAFOs) (March 18, 1976, 41 FR 24709), and aquaculture projects (May 17, 1977, 42 FR 25478) were issued in response to a court’s decision in Natural Resource Defense Council (NRDC) v Train, U.S. EPA. Stormwater is now defined as a class of point source discharges that are subject to the NPDES permit program (U.S. EPA, 1995a). After 1987, stormwater was included under the NPDES permit program because it was ruled to be a point sour ce. In 1987, Section 402(p) was added to the CWA to address point source discharges composed entirel y of stormwater under the NPDES program. This program established a phase approach for issuing NPDES stormwater permits (U.S. EPA, 1995a). The initial permit application requirements published by U.S. EPA was for certain categories of stormwater discharges associated with industrial activity and for discharges from municipal sepa rate storm sewer systems located in municipalities with a population of 100,000 or more (Phase I source s) was effective on November 16, 1990 (55 FR 47990). The Phase II rule was promul gated August 7, 1995 (60 FR 40230, U.S. EPA, 1996). 2.2.1 Regulations for Industrial Discharges: Phase I Phase I of the NPDES permit approach addresses stormwater from industrial facilities and discharg es from municipal separate storm sewer systems serving a

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10 population of 100,000 or more. “Stormwater di scharge associated with industrial activity” has been defined by U.S. EPA in a comprehensive manner to address over 100,000 facilities (U.S. EPA, 1996). “All storm water discharges associated w ith industrial activity that discharge through municipal separate storm sewer sy stems or that discharge directly to waters of the United States are requir ed to obtain NPDES permit coverage, including those which discha rge through systems located in municipalities with a population of less than 100,000” (U.S. EPA, 1996). Phase I focuses on the largest cities and counties, which contain about one-third of all the facilities in both regulated and nonregulated categ ories (U.S. EPA, 1995a). The NPDES regulations 40 CFR 122.26(b) (4) and (7) define municipal separate storm sewer systems that serve a populati on of 100,000 or more to include: Incorporated cities with a population of 100,000 or more Counties with populations of 100,000 or more in unincorporated, urbanized areas (excluding the population of towns and townships) Municipalities designated by U.S. EPA or an authorized NPDES State as having Phase I municipal separate storm sewer systems (U.S. EPA, 1995). Municipal separate storm sewer system disc harges can also be addressed under Phase I NPDES program if they are designated as significant contributors of pollutants to waters of the United States, or if they have contributed to a viol ation of a water quality standard under Section 402(p)(2 )(E) of the CWA. Phase I stormwater discharge permits

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11 provide a mechanism for monitoring the discharge of pollutants from Phase I sources to waters of the United States and establishe s appropriate controls (U.S. EPA, 1996). 2.2.1.1 Industrial Permit Application Options under Phase I The stormwater regulations offer three pe rmit application opti ons for stormwater discharges associated with industrial activity; 1. The first option is to submit an individual application 2. The second option is to file a NOI to be covered under a general permit in accordance with the requirements of an issued general permit (U.S. EPA, 1996). 3. The third options it to submit a group application 2.2.1.1.1 Option 1 The submittal of an individual applica tion requires an extensive amount of specific information about the facility. Info rmation in the applic ation includes a site drainage map, a narrative description of the s ite identifying potential pollutant sources, and quantitative testing data. Construction activities, oil and gas operations, and mining require specific requirements (U.S. EPA, 1996) and most facilities applying for an individual application are usually addressed by another NPDES permit. This research will not be focusing on option 1 permit applications. 2.2.1.1.2 Option 2 Stormwater dischargers that submit a NOI to be covered by a general permit are not required to submit an individual perm it application. Submitting an NOI can be less burdensome than submitting an individual application because the NOI requirements for

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12 general permits usually addre ss only general information a nd typically do not require the collection of monitoring data for initial coverage (U.S. EPA, 1996). The general permit approach is used by many states in order to regulated stormwater dischargers. The general permit approach is administratively efficient by allowing an agency to quickly specify co mpliance requirements for a large number of facilities when promulgating a new regulat ion (Duke et al, 1999a). However, the disadvantages to the general permit approach are facility identification and compliance assessment (Duke et al, 1999a). Facility opera tors are required to recognize their duty to comply with the general permit by self-ide ntification through filing a NOI with the regulating agency (Duke et al, 1999a). The general permit approach is based on self identification and self regulat ion of facilities. Reliance on self-identification fails to generate a regulatory mechanism that coul d systematically identify and characterize facilities in a given geographi c region (Duke et al 1999a). Research has discovered there is a wide spread failure among industrial facilities to comply with the NPDES regulations for st ormwater (Duke et al, 1999a). A number of recent research findings demonstrate facilitie s completing first stage compliance are low in the U.S. and are likely to be similar in other states such as California (Duke et al, 2001). Filing a NOI can be considered firs t stage compliance (Duke and Beswick, 1997). The states’ experience suggests that a large proportion of the regul ated facilities have failed to regard the basic issue of self-ide ntification, considered to be first stage compliance (Duke and Augustenborg, 2006). First stage compliance requires facilities to identify themselves by filing a NOI. Clearly, compliance with the first stage does nothing in itself to reduce pollutants in

PAGE 23

13 storm water discharges, but merely serves to place the facility unde r state or U.S. EPA supervision. However, this stag e of compliance is a reasonable indicator of the number of facilities that undertake polluta nt control activities although it is difficult to have an accurate proportion of covered facili ties completing first-stage compliance (Augustenborg, 2001). In addition, the degree of compliance by i ndustrial facilities has been uncertain since the regulations were first established (D uke et al, 1999a). This is due mainly to the way the U.S. EPA MSGP defines the regulat ed community, based on their SIC code. 2.2.1.1.3 Option 3 Facilities may apply for a group appli cation when seeking coverage under the MSGP. Group permits cover dischargers within a particular industrial group or that have similar discharge characteristic s. Group applications can be comprised of as few as four entities and is designed to generate customi zed general permits within the groups. This application process is intende d to reduce the expense and administrative burden on both industry and the permitting authority by requiri ng only selected members of the group to submit quantitative da ta (Bailey, 1993). The group applications process consists of two parts; Part 1 identifies all participants, provides facility-specific in formation, and proposes a representative sampling subgroup; Part 2 consists of sampli ng data from each member of the subgroup identified in Part 1 (Bailey, 1993). This res earch will not be evaluating Option 3 of the MSGP.

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14 2.2.2 Regulations for Industrial Discharges: Phase II Phase II of the stormwater regulations include additional stormwater discharges not addressed by the Phase I re gulation. Phase II discharges may include small municipal separate storm sewers systems, commercial and institutional facili ties (U.S. EPA, 1995b). The focus of this research is on Phase I stormwater regulations. 2.2.3 Permit Approaches The U.S. EPA created a general permit under which many stormwater discharge facilities could be a ddressed. The U.S. EPA MSGP (U.S. EPA MSGP) provides facilityspecific requirements for many types of indus trial facilities within one overall permit (U.S. EPA, 2005). The U.S. EPA MSGP author izes stormwater discharges associated with industrial activities for most areas of the United States where the NPDES permit program has not been delegated (60 FR 50804) The MSGP is offered by U.S. EPA as a model for authorized states to use to imple ment their stormwater permitting activities. Most states appear to have modeled the U.S. EPA MSGP permits as a way to assure they meet U.S. EPA’s minimum standards. The U. S. EPA must approve the state permits and grant authorization to the states for imp lementation of the permits (Griffin, 2005). The U.S. EPA MSGP offers coverage to stormwater dischargers subject to effluent limitation guidelines. The U.S. EPA MSGP requires facilities to do the following: 1. Develop and implement a stormwater pollution prevention plan (SWPPPP). 2. A facility must submit a Notice of Intent (NOI) along with the application fee to be authorized by the U.S. EPA MSGP.

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15 3. A facility must submit a Notice of Termination (NOT) if the facility is currently covered by the baseline general permit a nd intends to switch to the U.S. EPA MSGP. 4. U.S. EPA MSGP applicants must certify that no endangered species are in the proximity of the stormwater discharges. 5. Facilities that discharge to a large or medium municipal separate storm sewer system must submit signed copies of th e NOT to the operator of the municipal system (U.S. EPA, 1996). Stormwater discharges ar e also regulated under the Municipal Separate Storm Sewer permit. The 1987 CWA amendments spec ified NPDES water quality regulations for municipal drainage systems known as municipal separate storm sewer systems M.S.S.S.S. (MS4). Stormwater regulations were administered under the NPDES water quality regulations, and established a comp rehensive permit program addressing MS4s. This new permit program created a new categor y of permitted dischargers subject to the NPDES program. The MS4 permit may be issued on a system -wide or jurisdiction-wide basis. The role of municipalities has been defined in a flexible manner by the U.S. EPA to allow local governments to assist in defining prior ity pollutant sources within the municipality and to develop and implement appropriate cont rols for such discharges (U.S. EPA, 1996). Within the MS4 permit program, permittees are re quired to identify facilities that have a high risk of contributing to stormwater runoff. The MSGP and MS4 are designed to work together in controlling pollutant discharge in stormwater.

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16 The 1990 regulations defined storm water di scharges associated with industrial activities to include 11 categor ies of industrial f acilities and established application requirements for such discharges (U.S. EPA, 1995a). Within the 11 categories, there are 30 sectors based on types of industries and with in the sectors are sp ecific subsectors or SICs. The Office of Management and Budget (O MB) classifies businesses into categories based on similarity of economic activity know n as the SIC system (U.S. EPA, 1995a). Some major categories of industry and co mmerce covered under SIC codes 01-97 are (U.S. EPA, 1995a): Agriculture, Forestry, and Fishing Mining Construction Manufacturing Transportation and Public Utilities Wholesale Trade Retail Trade Finance, Insurance, and Real Estate Services Public Administration 2.2.4 Compliance The SIC system is a useful framework for identifying the numbers and locations of facilities by allowing U.S. EPA to access information from many sources with detail. However, the SIC system does not capture so me types of facilities or activities that

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17 generate stormwater discharges because the SIC system is based on the primary activity in which an establishment is engaged (U.S. EPA, 1995a). A facility or business may be involved in numerous activitie s, but will be classified according to a single industrial code, which may not reflect th e activities associated with stormwater discharges. This can be problematic because the regul atory definition of industrial facilities specifies the regulations to be based on activities conducted on site rather than to the category of business. The category of business, the SIC, is what is reported to the U.S. Department of Commerce or other agencies There are no databases, public documents, or reports are available to government agencies that reliably correlate s the facility name with the types of activities defined in the U.S. EPA stormwater permits (Cross, 2005). 2.3 Stormwater Regulation at the State Level Under the 1987 amendments to the CWA, Section 402(p) was added to establish a framework for regulating indus trial stormwater discharges as point sources under the NPDES permit program. The Florida Multi-Se ctor Generic Permit, California General NPDES Storm Water Permit, and the indivi dual municipal MS4 permits all address industrial stormwater. States must receive aut horization from the U.S. EPA to administer the NPDES permit program. 2.3.1 Florida MSGP In 2000, the U.S. EPA authorized the Fl orida Department of Environmental Protection (FDEP) to implement the NPDES stormwater permitting program in the state of Florida (with the exception of Indian country lands). Florida’s NPDES programs are based on the federal NPDES permitting progr am. The state program regulates point

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18 source discharges of stormwater from certa in industrial facilities. Operators of the regulated industrial facilities must obtai n NPDES stormwater permits and implement appropriate pollution prevention techniques to reduce the contamination of stormwater runoff (Augustenborg, 2001). Florida adopted the federal stormwater general permit for industrial activities as specified in Rule 62-621.300(5)(a), F.A.C. Florida operates the Federal stormwater general permit as the state of Florida Multi-Sector Generic Permit (MSGP) for stormwater discharge associated with industr ial activity. Some indus trial facilities may have to obtain an individual permit as sp ecified in Chapter 62-620, F.A.C. (FDEP, 2000e). The MSGP has five main components: 1. Submission of application or notice of intent 2. Application fee 3. Development of a stormwater pollution prevention plan 4. Monitoring 5. Notice of termination Receiving permit coverage under the MSGP, an application containing facility specific identification information must be submitted to the regulatory agencies along with a one time application fee. This initia l submittal is considered filing a notice of intent putting the facility under regulatory control.

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19 2.3.2 Stormwater Pollution Prevention Plan The USEPA and various state permits a ll require facilities receiving MSGP permit coverage develop and implements a Stormwater Pollution Prevention Plan (SWPPP). The SWPPP is to be prepared in accordance with good engineering practices and must contain the three following criteria: (1) the plan shall identify potential sources of pollution which may reasonably be expected to affect the quality of stormwater discharges associated with industrial activities from the facility; (2) the plan shall describe and ensure the implementation of th e practices used to reduce the pollutants in stormwater and assure compliance with the terms and conditions of the MSGP permit; (3) facilities must implement the provision of the SWPPP required under the condition of the MSGP (U.S. EPA, 1992b). Stormwater Poll ution Prevention Plans allow for facility specific plans and controls as long as the three criteria are met. The intention of the SWPPP is to facilitate the process whereby facility operators evaluate potential pollution s ources on-site and select a nd implement the appropriate measures to prevent or control pollutants. The process is outlined in the Federal Register Vol. 60, No 189. The USEPA believes this appr oach to be the mo st environmentally sound and cost-effective way to control the di scharge of pollutants in stormwater runoff from industrial faci lities (F.R. Vol. 60, No. 189). Th e SWPPP provides the facility operator the opportunity to become more familiar with their facility in detail by having to identify potential sources of pollution. This is reiterated through the detailed requirements of the SWPPP.

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20 The SWPPP must describe in detail all potential pollution sources. For example, all activities, material and physical features of a facil ity must be evaluated if they contribute significant amounts of pollutants to stormwater runoff or result in a polluted discharge to storm sewers or drainage systems. This identification task of the SWPPP allows facility operators to identify and set priorities for necessary charges in material, materials management practices, or site feat ures, as well as aid in the selection of appropriate structural and nonstr uctural control techniques. In addition, a facility operator must discuss the reasons each control or pr actice was selected and how each will address the source of concern (F.R. Vol. 60, No. 189) Best management practices (BMPs) should be incorporated into the facilities operations and identified in the SWPPP. 2.3.2.1 Best Management Practices Best management practices are a combin ation of structural, nonstructural, and managerial techniques that are recognized to be the most effective and practical means to control nonpoint source polluta nts and are compatible with the productive use of the resource to which they are applied (NSC, 2006) The SWPPP encourages a facility to use BMPs when ever applicable. Best manage ment practices also include processes, procedures, schedules of activities, prohi bition on practices, and other management practices that prevent or reduce the discharg e of pollutants in stormwater runoff. Best management practices are additional ways f acilities can help c ontrol the amount of pollutants being discharged. By having a set of BMPs in place and identified in the SWPPP, a facility has the opportunity to docum ent changes that might occur as different BMPs are implemented.

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21 2.3.3 Monitoring Requirements under the FL MSGP Depending on the industry sector and sub-se ctors/SIC, the operators of industrial facilities may have to perform as many as th ree types of monitoring of their stormwater discharges: visual examination, analytical monitoring, and compliance monitoring. Under the MSGP, facilities that perform analytical or compliance monitori ng must report their results to the appropriate re gulatory agency and the sampling data collected from the monitoring must be summarized and included in the SWPPP (U.S. EPA, 1999). In lieu of having to report monitoring data, there are wa ivers or exemptions a facility may receive such as; adverse weather conditions or unstaffed and inactive sites. 2.3.3.1 Sample Type Samples taken to satisfy the MSGP m onitoring requirements are to be grab samples for all three types of monitoring. Samp les are to be collected from discharges resulting from a storm event greater than 0.1 in ches in magnitude and that occurs at least 72 hours from the previously measurable storm event (U.S. EPA 1999). 2.3.3.2 Visual Examination All facilities covered under the MSGP are requi red to perform visual examinations of their stormwater discharges on a quarterly basis throughout the duration of the five year permit. Facility operators are to examine a sample collected from a discharge location during the fi rst half hour of discharge a nd note any color, odor, clarity, floating solids, settled solids, suspended solids, foam, oil and sheen and any other indicators of possible stormwat er pollution. Visual examinati ons are intended to provide

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22 a simple and inexpensive means of obtaini ng a rough assessment of stormwater quality at the facility (U.S. EPA 1999). 2.3.3.3 Analytical Monitoring Analytical monitoring is required only by industry sectors or subs-sectors/SICs USEPA determined to have a high potential to discharge a pollutant at concentrations of concern (Table 2.3.3.3.1). Analyt ical monitoring is preforme d on a quarterly basis in years two and four of the permit and the results must be submitted to the U.S. EPA on a Discharge Monitoring Report (DMR). The samp les are required to be taken at each discharge location and analyzed for specifi c parameters at a ce rtified laboratory. Specified parameters are determined by the federal MSGP and vary depending on industry sectors and subsector s/SICs. Through research, the U.S. EPA determined what types of pollutants are typically released by various industrial activities. This allowed the MSGP to determine specified parameters to be analyzed in water samples for each sector or subsector/SIC (F.R. Vol. 60, No. 189). The average results are compared to benchmark concentrations to evaluate the effectiven ess of the facility’s SWPPP (U.S. EPA 1999). Table 2.3.3.3.1: MSGP Industry Sector/Subsecto rs Subject to Analytical Monitoring MSGP Sector Industry Subsector Required Parameters for Analytical Monitoring General Sawmills and Planni ng Mills COD, TSS, Zn Wood Preserving Facilities Arsenic, Cu Log Storage and Handling TSS A Hardwood Dimensions and Flooring Mills COD, TSS B Paperboard Mills COD Industrial Inorganic Chemicals Al, Fe, N (nitrate & nitrite) Plastics, Synthetic Resin, etc. Zn Soaps, Detergents, Cosmetics, Pe rfumes N (nitrate & nitrite), Zn C Agriculture Chemicals N (nitrate & nitrite), Pb, Fe, Zn, Phosphorus D Asphalt Paving and Roofing Materials TSS

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23 Table 2.3.3.3.1: Continued MSGP Sector Industry Subsector Required Parameters for Analytical Monitoring Clay Products Al E Concrete Products TSS, Fe Steel Works, Blast Furnaces, and Rolling and Finishing Mills Al, Zn Iron and Steel Foundries Al, TSS, Cu, Fe, Zn Non-ferrous Rolling and Drawing Cu, Zn F Non-ferrous Foundries (casting) Cu, Zn G Copper Ore Mining and Dressing COD, TSS, N (nitrate & nitrite) H Coal Mines and Coal-Mining Related Facilities TSS, Al, Fe Dimension Stone, Crushed Stone, and Nonmetallic Mineral (except fuels) TSS J Sand and Gravel Mining N (nitrate & nitrite), TSS K Hazardous Waste Treatment Storage and Di sposal Ammonia, Mg, COD, Arsenic, Ca, Cyanide, Pb, Mercury, Selenium, Ag L Landfills, Land Application Sites, and Open Dumps Fe, TSS M Automobile Salvage Yards TSS, Al, Fe, Pb N Scrap Recycling Cu, Al Fe, Pb, Zn, TSS, COD O Steam Electric Generating Facilities Fe Q Water Transportation Facilities Al, Fe, Pb, Zn S Airports with dicing activitie s BOD, COD, Ammonia, pH Grain Mill Products TSS U Fats and Oils BOD, COD, N (nitrate & nitrite), TSS Y Rubber Products Zn Fabricated Metal Products Except Coating Fe, Al, Zn, N (nitrate & nitrite) AA Fabricated Metal Coating and Engraving Zn, N (nitrate & nitrite) 2.3.3.4 Compliance Monitoring The third type of monitoring under the MSGP is compliance monitoring. Compliance monitoring provides cove rage to only very specific types of discharges that are subject to effluent guideli nes and are not already subjec t to an existing individual NPDES stormwater permit. Compliance monitori ng is to be performed on an annual basis throughout the term of the permit and the resu lts may be used to meet the quarterly

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24 analytical monitoring requirements for the sp ecified pollutants, where compatible (U.S. EPA, 1999). Evaluation of compliance monitori ng is beyond the scope of this research. 2.3.4 Monitoring Requirements under CA MSGP In California, the authority has been delegated to the California State Water Resources Control Board (CSWRCB). The CS WRCB promulgated a statewide rule for industry under the stormwater permit provi sions for the NPDES program in 1992. In 1997, the rules were amended and re-authori zed as the General NPDES Storm Water Permit for Industrial Activities excluding c onstruction activities (Duke et al, 2001). The General NPDES Storm Water Permit for Industrial Activities is designed to facilitate pollution prevention measures at indus trial facilities to re duce pollutant loading into surface water of the stat e of California. Industrial faci lities that are subject to the permit are required to apply for covera ge under the regulation by submitting a NOI, develop and implement a SWPPP and conduct monitoring (Duke, 2001). 2.3.4.1 CA SWPPP All facility operators receiving MSGP cove rage in California must prepare, retain on site and implement an SWPPP. The two majo r objectives of the SW PPP are: 1.)to help identify the sources of pollution that affect th e quality of industrial stormwater discharges and authorized non-stormwater discharges and2.) to describe and ensure the implementation of BMPs to reduce or preven t pollutants in industrial stormwater discharges and authorized non-stor mwater discharges (CRWQB, 2006). The SWPPP emphasis on BMPS provides flexibility in the choice of BMPs for different types of industrial ac tivities and pollutant sources. One of the major elements of

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25 the SWPPP is the elimination of unauthorized non-storm water discharges to the facility’s stormwater drain system (CRWQCB, 2006). 2.3.4.1 CA Monitoring Program All facilities regulated under the ge neral permit requires the development and implementation of a monitoring program. The objectives of the monitoring program are: 1.) demonstrate compliance with the General Pe rmit, 2.) aid in the implementation of the SWPPP, and 3.) measure the effectiveness of the BMPs in reducing or preventing pollutants in stormwater discharges a nd authorized non-stormwater discharges (CRWQCB, 2006). All facilities must perf orm visual observations of stormwater discharges and authorized stormwater discharges. Visual obs ervation refers to when someone inspects the facility during dry periods or during tim es when rain is running off, to look for possible stormwater pollutant problems Facilities must also collect and analyze samples of stormwater discharges. The analysis must include the following parameters: pH, total suspended solids (TSS), total organic car bon (TOC), specific conductance, toxic chemicals, and other pollutants which are likely to be present in the stormwater discharges in significant quanti ties. The first sample is to be taken during the first rain event of the season and one rain event thereafter.

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26 3.0 METHODOLOGY The present research is based on the revi ew of the federal and state regulations and the literature summarized above. This resear ch is designed to determine if the current regulations are efficiently and effectively c ontrolling stormwater runoff. This research consists of three stages: the determination and evaluation of possibl e uses of industrial facilities monitoring data; a regulatory analysis; and an analysis of existing monitoring data. 3.1 Possible Uses of the Monitoring Data The overall approach was to first id entify the range of possible uses for monitoring data envisioned in the regulati ons and assess whether the data collected succeed in meeting those uses. The possible us es of the monitoring data were derived from a review and evaluation of regulato ry language, agency guidance, studies by implementing agencies, and others. Four main categories of possible uses were identified as follows: 1. Agencies’ identificati on of high polluting faci lities within a given jurisdiction 2. Assessment of pollutant loads to receiving waterbodies 3. Documentation of facilities’ improvement in polluted discharges 4. Facility operators’ self evaluati on and identification for future improvements

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27 3.1.1 Identification of High Polluting Facilities Florida Department of Environmental Prot ection and other state agencies have the flexibility under the MSGP and MS4 to ensu re that high polluti ng facilities in their jurisdiction are implementing effective BMPs. In Florida, the permitees of the MS4 are required to identify facilities that have a hi gh risk of contributing to stormwater runoff. The design and structure of both the MSGP a nd MS4 permit, have the potential to work together in order to achieve a decrease in pollutant runoff. One of the state’s purposes for requiring monitoring was to allow municipalities to identify industrial fa cilities that might be potential sources of pollutants to stormwater runoff and focus their resources on the high po lluting facilities. The U.S. EPA intends the proper use and coordination of limited regulatory resources to be the key in developing a workable regulatory program for controlli ng pollutants in stormwater discharges associated with industrial activities. This is especially important when addressing the appropriate role of municipal operators of large and medium municipal separate storm sewer systems in the control of pollutants in stormwater associ ated with industrial activity, which discharges through municipal se parate storm sewer systems (F.R. Vol. 65, No 210). This research evaluated existing monitori ng data from industrial facilities in Hillsborough County, Florida and Los Angele s County, California in order to assess whether the current data is successful in identifying high polluting facilities. The evaluation included the following: identific ation of potential hi gh polluting industrial facilities within a jurisdiction and evaluation of analytical monitori ng data in identifying

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28 potential high polluting facilities. The resear ch reviewed the stormw ater regulations and evaluated how the regulations specifications for monitoring frequency, on-site locations, etc. could be expected to produce data suffici ent to identify whether a facility discharged pollutants with high concentrations over time. 3.1.2 Assessment of Pollutant Loads to Receiving Waterbodies The Inventory (U.S. EPA, 1995b) and NUR P (U.S. EPA, 1983) both concluded that receiving waterbodies were being degraded from various sources, one being stormwater runoff. Polluta nts conveyed by stormwater r unoff can have a detrimental effect on receiving water bodies. The U.S. EPA has developed a permitting system to control discharge of those pollutants. The U.S. EPA’s approach is a flexible four tier permitting strategy for issuing NPDES permits for discharges. The four tiers are: Tier I Baseline Permitting, Tier II Watershed Permittin g, Tier III Industry-Specific Permitting, and Tier IV Facility Specific Permitting. Tier II Watershed Permitting, includes facilities within watersheds shown to be adversely im pacted by stormwater discharges associated with industrial activity, which U.S. EPA speci fies will be targeted for individual or watershed-specific general permits (F.R. Vol. 60, No 189). The TMDL program under the CWA, require s jurisdictions to identify all sources of the target pollutants in watershed of an impaired wate rbody. States, territories, and authorized tribes are requir ed under section 303(d ) of the 1972 CWA to develop lists of impaired waters that do not meet the water quality standards set for them. This requires jurisdictions to establish prio rity ranking for impaired wate rs and to develop a TMDL. A TMDL specifies the maximum amount of a pollutant that a waterbody can receive and

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29 still meet water quality standards. Pollut ant loading is alloca ted among point and nonpoint pollutant sources located within the impaired watershed. The TMDL is considered to be the sum of all allocated loads of pollutants set at a le vel necessary to implement the applicable water quality sta ndards. This includes wastel oad allocations from point sources, non-point sources and natural back ground conditions. In addition, the TMDL maintains a margin of safety and cons iders seasonal variations (EPA, 2006). The TMDL program requires jurisdictions to identify all sources of pollutants in a impaired waterbody and watershed. Knowledge of pollutant loads in runoff from specific facilities can allow watershed decision makers to better unde rstand the total loading to watersheds and to make allocations that may require those loads to be revised. This research obtained and evaluated existing monitoring data from Hillsborough County, Florida and Los Angeles County, Califor nia in order to determine whether the data were sufficient to reliably estimate th e pollutant loads origin ating from industrial facilities. This research acquired data on the number of parameters monitored, the parameters being monitored, number of discharge locations, and the how often monitoring occurs. This will determine whethe r the current monitoring data can be used to help assess pollutant loads to receivi ng waterbodies. This research also assessed whether the current monitoring requirements can generate sufficient data in order to produce a reliable estimate of potential pollutant loads from industrial facilities in the case of perfect compliance.

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30 3.1.3 Documentation of Improvement One of the requirements of the MSGP is that each facility is to develop and implement a SWPPP. One aspect of the SW PPP is to discuss the reasons each selected control or practice is appropriate for the fac ility and how each will address one or more of the potential pollution sources identified in the plan at the facility. The plan must also include a schedule specifying the time(s) duri ng which each control or practice will be implemented. The plan incorporates how each of the controls and practices relate to one another and when taken as a whole, produce an integrated and cons istent approach for preventing or controlling potential stormwater pollution. In addition, when “minimize/reduce” are used in the SWPPP relati ve to pollution prevention plan measures, U.S. EPA means to consider and implement BMPs that will result in an improvement over the baseline conditions as it relates to the levels of pollutants identified in the stormwater discharges (F.R. Vol. 60, No. 189). The structure and design of the SWPPP require facility operators to document any changes occurring at the facility, which can be used to document improvements or any probl ems that might be taking place over time. Analytical monitoring for discharges from certain classes of indus trial facilities is required under the MSGP. Results for the analytical monitoring are quantitative and therefore can be used to compare results from discharge to discharge and to quantify the improvement in stormwater quality attributab le to the stormwater pollution prevention plan. The results from the analytical monitori ng can also be used to identify a pollutant that is not being successfully controll ed by the plan (F.R. Vol. 60, No 189). The

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31 analytical monitoring results are another mean s for the facility operator to document the facility’s improvements in po llutants being discharged. Evaluation of the literature, existing monitoring data from the two regions previously mentioned and a regulatory anal ysis was conducted. The evaluation of the existing monitoring data from industrial faciliti es was preformed in order to determine if facilities are able to document improvements, which will be dependent on the individual facilities ability to report/document occu rrences taking place on-site. The analysis consisted of comparing the second and fourth year data, the change in concentrations, frequency of the monitoring data to detect trends, and the repres entativity of on-site locations. Additional information from a telepho ne survey was used in the analysis to help determine what the facility operators we re using the results from the monitoring for. 3.1.4 Self Evaluation Pollutants in stormwater discharges from industrial facilities may be reduced by incorporating the following in to the SWPPP: eliminating po llution sources, implementing BMPs to prevent pollution, using traditional stormwater management practices, and providing end of the pipe trea tment. The SWPPP approach used in the general permit has two main focuses: (1) to identify sources of pollution potentially a ffecting the quality of stormwater discharges associate with industr ial activity from the facility; and (2) to describe and ensure implementation of prac tices to minimize and control pollutants in stormwater discharges associated with industr ial activity from the facility and to ensure compliance with terms and conditions of the permit.

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32 With these two main focuses, the SWPPP requirements are intended to facilitate the process whereby the operator of the indus trial facility thoroughl y evaluates potential pollution sources at the site and selects and implements appropriate measures designed to prevent or control the discharge of pollutants in stormwater runoff. One of the four steps involved in the SWPPP process is to periodi cally evaluate the e ffectiveness of the SWPPP to prevent stormwater contaminati on and ensuring compliance under the permit (F.R. Vol. 60, No. 189). The structure and de sign of the SWPPP re quires the facility operator to evaluate the effectiveness of the facility ability to prevent further contamination of stormwater runoff. One of the intended purposes of the monitoring requirements under the permit is that facility ope rators use the data generated to evaluate their own activities, improve their SWPPPs, evaluate and reduce pollutants that maybe discharging in stormwater runoff. The U.S. EPA and state regulatory personne l widely express the expectation that facility personnel will use the monitoring data to identify problems at the facility and make improvements to their operations (Ke lly, 2006). This research assessed facility operators’ perspectives towards the monito ring requirements and uses of the data obtained from monitoring by surveying a sa mple of facility personnel in Hillsborough County. Industrial facility operators were aske d whether they use the monitoring data for self evaluation or any other purposes. Th e research collected this information systematically through a tele phone survey, using a structur e designed from the purpose.

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33 3.2 Telephone Survey This research gathered information on the perspectives of industrial facility operators on monitoring data by a survey of selected industria l facilities. Some of the key purposes of the telephone survey were to dete rmine if industrial facility operators were incorporating the results from the monitoring data to make changes to the facilities onsite activities, or to document improvements the facilities might be making to activities in order to decrease the amount of pollution in stormwater runoff. Industrial facilities located in Hill sborough County and Pinellas County, Florida that filed a NOI with FDEP were identified and contacted. The outre ach was targeted to the manufacturing sectors, SICs 20 through 39, to produce a sample of facilities with reasonably similar industrial activities, pr oduction concerns, and compliance attitudes. Prior to administering the telephone surve y, an introductory letter was sent to each industrial facility. The purpose of the letter was to inform the facility operators about this research and inform they w ould soon be contacted requested for their participation in the telephone survey. A pre-test of the telephone survey was conducted on a sample of eleven industrial facilities in Pinellas County, Fl orida to determine the effectiv eness, structure and flow of the telephone questionnaire. All of the industrial facilities contacted in Pinellas County were required to conduct analytical monitori ng. Phone calls to Pinellas County industrial facilities were completed in J une 2006.A total of 63 industrial facilities were contacted in Hillsborough County, Florida. These industrial faci lities included all those that received

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34 MSGP permit coverage with in the targeted sectors throughout Hillsborough County. Phone calls to Hillsborough County industria l facilities were completed in July 2006. The response outcomes to the telephone su rvey are in Table 3.2.1. There was a 60 percent response rate. For the purposes of this research passive refusal referred to facilities that did not return the phone call or did not answer the phone. Facilities were labeled passive refusal after messages were left on answering machines and ten calls were attempted over a length of two to three weeks. Active refusal referred to facilities where a representative was reached and declin ed to participate in the telephone survey. The telephone survey was conducted fo r two months, June and July 2006. Table 3.2.1: Telephone Survey Outcome Number of Facilities Required to Conduct Analytical Monitoring Not Required to Conduct Analytical Monitoring Questionnaire Attempted Percent of Attempted Completed Questionnaire 22 16 60 Passive Refusal 6 8 23 Active Refusal 7 4 17 Total 35 28 100 Questionnaire Not Attempted Percent of Not Attempted Facility Closed 3 1 29 Duplicate Facility* 3 1 28 Wrong Number 1 4 36 Wrong City 0 1 7 Total 7 7 100 Total Possible 42 35 Different MSGP number but same facility The telephone questionnaire was structured into eight sections: Pre Questions, (I) Introduction and Facility Information, (II) Visu al Observation, (III) Visual Examination,

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35 (IV) Analytical Monitoring, (V ) Training, (VI) Uses of the data, and (VII) Conclusion. The section’s questions were based on Fl orida’s monitoring requirements under the MSGP. The majority of the telephone questi onnaire questions were designed so the respondent would choose yes, no or don’t know responses. Every question and response in the telephone questionnaire r eceived a number in order to tr ansfer the raw data into an electronic database. The electronic database reflects the structure of the telephone questionnaire. The telephone surveys questio ns were based on the MSGP monitoring requirements for industrial facilities and the types of activities c onducted outdoors on-site that have the potential to c ontribute pollutants to stormwater runoff. Visual observations, training, and uses of the data were also in corporated as questions into the telephone questionnaire in order to assist in the determ ination of facility operators’ perspectives of the monitoring requirements. The telephone survey was exempt from the University of South Florida Institutional Review Board (IRB) because this research did no t put human participants at any risk or harm in participating in the telephone survey and facility information was obtained through public record. 3.3 Analytical Monitoring Data This research obtained analytical m onitoring data from FDEP for industrial facilities in Hillsborough County, Florida that submitted the results from their analytical monitoring as a requirement under the MSGP. The data was accepted in the form submitted to FDEP from the indus trial facility. The results fro m the industrial facilities analytical monitoring were submitted to FDEP on Discharge Monitoring Reports (DMR).

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36 The data was gathered from the DMRs and input ted into an electronic database for each of the targeted facilities. The sample include d all facilities in the manufacturing sectors, SIC 20-39, required to conduct and submit anal ytical monitoring. All facilities that submitted data were included in the sample There were 43 facilities that submitted analytical monitoring results from years 1998-2006. Analytical monitoring data was obtaine d for the same industry sectors for industrial facilities in Los Angeles County California fr om the California Regional Water Quality Control Board, Los Angeles (CRW QCB) (CRWQCB, 2005). The analytical monitoring data results submitted by industria l facilities to CRWQCB as a requirement under the MSGP, were from 1998-1999 and we re available in electronic format (CRWQCB, 2005). The number of industrial fa cilities that submitted monitoring data in 1998-1999 was 1,709 within the target ed sectors. The date of the data from industrial facilities in Los Angeles County is sufficient fo r the goals of this research because there is not to be much change is expected to have occurred since 1998-1999. In addition, the regulations were identical in 1998-1999 and any selected time period is adequate to test the hypothesis.

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37 4.0 RESULTS The results are organized in four cate gories according to the possible uses: 1. Identification of high polluting facili ties within a given jurisdiction; 2. Assessment of pollutant loads to receiving waterbodies; 3. Documentation of improvement for f acilities’ improvement of polluted discharges; 4. Facility operators’ self evaluation an d identification of areas for future improvements. 4.1 Identification of High Polluting Facili ties within a Given Jurisdiction Facilities with a high poll utant discharge are known as high polluters. In order to single out high polluters in a ju risdiction with confidence, all industrial facili ties within a jurisdiction need to be known. To determine the degree of success of the current structure of the stormwater regulation system for th is purpose, the following was evaluated: 4.1.1 Identification of Potential High Po lluting Industrial Facilities in A Jurisdiction 4.1.1.1 Identification of Industrial Facil ities within A Jurisdiction and; 4.1.1.2 Knowledge of Which Industrial Facilities Are Requi red To Conduct Analytical Monitoring 4.1.2 Evaluation of Analytical Monitoring Da ta in Identifying Potential High Polluting Facilities 4.1.2.1 Identification of Industrial F acilities with The Highest Concentrations of Pollutants in Their Discharge;

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38 4.1.2.2 Representativity of the data; 4.1.2.3 Sampling frequency and; 4.1.2.4 Storm variability. 4.1.1 Identification of Potential High Polluting Industrial Facilities in a Jurisdiction 4.1.1.1 Identification of Industrial Faci lities within a Jurisdiction To determine which industrial facilities are high polluters it is necessary to identify all industrial facilitie s within an agency’s jurisdic tion. The federal stormwater regulations require compliance for any facility conducting acti vities typical of a given SIC. The U.S. EPA requires facilities reporti ng under certain SICs to conduct analytical monitoring. It is the facility operator’s responsib ility to determine whether or not the facility needs to be in compliance with st ormwater regulations by filing a NOI (Table 4.1.1.1.1). Table 4.1.1.1.1: NOIs Filed County NOI Filed Year Filed* Hillsborough 196 2001-2006 Los Angeles 2,718 1998-1999 Years selected for this sample Filing an NOI is considered to be the first step, or the first stage, towards compliance in receiving coverage under th e MSGP (Duke, 1999a). The number of NOI filers within a jurisdiction w ill give the total number of indus trial facilities that have identified themselves as being subject to stormwater regulations. However, since stormwater regulations are based on self identification, using the filed NOIs may not capture all of the industrial faci lities within a jurisdiction.

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39 Another method for identifying industrial f acilities comes from the U.S. Census Bureau. Facilities are required to report to th e U.S. Census Bureau in order for the bureau to provide quality data about the nation’ s people and economy to the United States government. Facilities are requi red to report under a primary SIC to the U. S. Census Bureau. For the purposes of Census, the primar y SIC is defined as the activity where the facility earns most of its income. No fac ility reports under more than one SIC to the Census. Conversely, the stormwater regulat ions require compliance by any facility conducting activities under th e specified SIC, even if that ac tually is a very small part of the facility’s income. Many more facilities are expected to be subject to the stromwater regulations in a given SIC than reports to the Census. The U.S. Census Bureau can provide an approximation of the number of industrial facilities there are within a given jurisdiction. For the purpose of this research, the 1997 U.S. Census Bureau data was used as it was the last year it had facilities reporting under the SIC system. Currently, the US Census Bureau requires facilities to report under the North American Industry Clas sification System (NAICS). However, the current stormwater regulations still use the SIC classification system. There is a large difference in the number of facilities reporting to the U.S. EPA and to the U.S. Census Bureau. For instance, out of 270 facilities who reported to the U.S. Census Bureau in Hillsborough County Fl orida in 1997, 70 facili ties had filed an NOI (2001-2006) in the target SI Cs. Differences between the numbers can be attributed to a change in industrial facilities over the ni ne years, a lack of knowledge of stormwater regulations since the regulations are fairly recent, or failure to comply. Conversely, in Los Angeles County California, 2,718 industria l facilities filed an NOI in 1998-1999 out

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40 of 2,768 facilities who reported to the U.S. Census Bureau in 1997, (Table 4.1.1.1.2). The significant difference in the number of faciliti es filing with the two agencies makes it difficult for the regulatory agency, such as the U.S.EPA, to adequately identify all industrial facilities w ithin a jurisdiction, which can result in a low confidence when trying to pinpoint potential high po lluting industrial facilities.

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41 Table 4.1.1.12 Target SICs in Hillsborough County and Los Angeles County Sector SIC Industrial Activity Hillsborough Co unty facilities Los Angeles County facilities Census (1997) 1 Filed NOI 2 Submitted Analytical Monitoring Data, 20012006 3 Census (1997) 1 Filed NOI 4 Submitted Analytical Monitoring Data, 1998-1999 5 A Timber Products 2431 Millwork 6 1 1 84 8 8 2451 Mobile Homes 4 1 1 1 1 1 2491 Wood Preserving 1 2 2 1 1 1 B Paper and Allied Products Manufacturing 2653 Corrugated and Solid Fiber Boxes 9 4 Not required 3 55 12 12 2656 Sanitary Food Containers, Except Folding 2 1 Not required 3 4 1 1 C Chemical and Allied Products Manufacturing 2813 Industrial Gas 1 2 2 14 6 6 2819 Industrial Inorganic Chemicals, Not Elsewhere Classified 1 1 1 14 9 9 2842 Specialty Cleaning, Polishing, and Sanitation Preparations 7 2 2 39 3 3 2844 Perfumes, Cosmetics, and Other Toilet Preparations 2 1 0 78 12 12 D Asphalt Paving and Roofin g Materials Manufacturers an d Lubricant Manufacturers 2951 Asphalt Paving Mixtures and Blocks 3 2 2 18 12 12 2952 Asphalt Felts and Coating 2 1 Not required 3 12 4 4 2992 Lubricating Oils and Grease 1 1 Not required 3 14 11 11 E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing 3241 Cement, Hydraulic 1 1 1 7 0 0 3271 Concrete Block and Brick 2 3 3 8 3 3 3272 Concrete Products, Except Block and Brick 10 7 5 27 5 5 3275 Gypsum Products 1 4 3 12 2 2

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42 Table 4.1.1.1.2 Continued Sector SIC Industrial Activity Hillsborough County facilities Los Angeles County facilities Census (1997) 1 Filed NOI 2 Submitted Analytical Monitoring Data, 20012006 3 Census (1997) 1 Filed NOI 4 Submitted Analytical Monitoring Data, 1998-1999 5 F Primary Metals 3312 Steel Works, Blast Furnaces, and Rolling and Finishing Mills 3 1 1 7 0 0 3354 Aluminum Extruded Products 1 1 1 12 3 3 3369 Nonferrous Foundries, Except Aluminum and Copper 2 1 1 5 9 9 R Ship and Boat Buildin g or Repairing Yards 3731 Ship Building or Repairing (establishments primarily engaged in building and repairing ships, barges, and lighters, whether self-propelled or towed by other crafts) 6 6 Not required 3 18 2 2 U Food and Kindred Products 2013 Sausages and Other Prepared Meats 3 1 Not required 3 41 5 5 2048 Prepared Feeds and Feed Ingredients for Animals and Fowls, Except Dogs and Cats 2 2 2 10 0 0 2051 Bread and other Bakery Products, Except Cookies and Crackers 10 1 Not required 3 127 7 7 2077 Animal and Marine Fats and Oils 2 1 1 3 0 0 2082 Malt Beverages 3 1 Not required 3 8 0 0 2083 Malt 0 1 Not required 3 1 1 1 2086 Bottled and Canned Soft Drinks and Carbonated Water 2 1 Not required 3 19 2 2 2091 Canned and Cured Fish and Seafoods 0 1 Not required 3 11 1 1

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43 Table 4.1.1.1.2 Continued Sector SIC Industrial Activity Hillsborough County facilities Los Angeles County facilities Census (1997) 1 Filed NOI 2 Submitted Analytical Monitoring Data, 20012006 3 Census (1997) 1 Filed NOI 4 Submitted Analytical Monitoring Data, 1998-1999 5 Y Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries 3069 Fabricated Rubber Products, Not Elsewhere Classified 5 1 1 45 6 6 3085 Plastics Bottles 2 1 Not required 3 19 2 2 W. Furniture and Fixtures 2515 Mattress, Foundations, and Convertible Beds 2 1 Not required 3 57 0 0 X Printing and Publishing 2752 Commercial Printing, Lithographic 112 1 Not required 3 1060 5 5 AA Fabricated Metals 3429 Hardware, Not Elsewhere Classified 3 1 1 69 9 9 3441 Fabricated Structural Metal 8 1 1 73 10 10 3444 Sheet Metal Work 22 2 2 193 8 8 3449 Misc. Structural Metal Work 3 1 1 16 3 3 3479 Coating, Engraving, and Allied Services, Not Elsewhere Classified 5 2 1 119 17 17 3491 Industrial Valves 1 1 1 21 4 4 3496 Misc. Fabricated Wire Products 6 2 2 52 1 1 3499 Fabricated Metal Products, Not Elsewhere Classified 3 1 1 117 23 23 AB Transportation Equipment, In dustrial or Commercial Machinery 3714 Motor Vehicle Parts and Accessories 5 1 Not required 3 178 17 17

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44 Table 4.1.1.1.2 Continued Sector SIC Industrial Activity Hillsborough County facilities Los Angeles County facilities Census (1997) 1 Filed NOI 2 Submitted Analytical Monitoring Data, 20012006 3 Census (1997) 1 Filed NOI 4 Submitted Analytical Monitoring Data, 1998-1999 5 AC Electronics, Electrical, Ph otographic and Optical Goods 3663 Radio and Television Broadcasting and Communications Equipment 5 1 Not required 3 54 0 0 3674 Semiconductors and Related Devices 1 1 Not required 3 45 7 7 Sources: 1 U.S. Census Bureau 1997: 2 Florida Department of Environm ental Protection collected 2006: 3 Florida Department of Environmental Protection MSGP facili ty monitoring data, collected 2006: 4 Los Angeles Regional Water Quality Control Board 19981999: 5 Los Angeles Regional Water Quality Control Board MSGP facility monitoring data, 1998-1999

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45 4.1.1.2 Industrial Facilities Required to Conduct Analytical Monitoring All industrial facilities th at receive coverage under the MSGP are required to conduct visual examination monitoring. Howeve r, only facilities in industry sectors like timber or chemical manufacturing reporting under specific SICs are required to conduct analytical monitoring (Table 4.1.1.2.1). There are 533 SICs available for a facility to report under to various agencies for multiple purposes. Of these, 169 SICs, or 23 %, are required to conduct analytical monitoring ac cording to the federal MSGP. However, California law requires all f acilities receiving MSGP covera ge to conduct analytical monitoring. In Hillsborough County from 2001 there we re 104 facilities required to conduct analytical monitoring based on NOIs filed with FDEP. Out of the 104 facilities, 49 were within the targeted sectors and SICs of this research (Table 4.1.1.2.1). In Los Angeles County there were 2,718 facili ties that filed an NOI. Of these, 1,709 were within the targeted sectors and SICs of this research required to conduct analytical monitoring. Table 4.1.1.2.1:Hillsborough County Industrial Faci lities Required to Conduct Analytical Monitoring Targeted Industrial Se ctors, SICs, and Activities Sector SIC Industrial Activity Represented Filed NOI A Timber Products 2431 Millwork 1 A Timber Products 2451 Mobile Homes 1 A Timber Products 2491 Wood Preserving 2 C Chemical and Allied Products Manufacturing 2813 Industrial Gas 2 C Chemical and Allied Products Manufacturing 2819 Industrial Inorganic Chemicals, Not Elsewhere Classified 2 C Chemical and Allied Products Manufacturing 2842 Specialty Cleaning, Polishing, and Sanitation Preparations 2

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46 Table 4.1.1.2.1: Continued Sector SIC Industrial Activity Represented Filed NOI C Chemical and Allied Products Manufacturing 2844 Perfumes, Cosmetics, and Other Toilet Preparations 1 D Asphalt Paving and Roofing Materials Manufacturers and Lubricant Manufacturers 2951 Asphalt Paving Mixtures and Blocks 2 E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing 3241 Cement, Hydraulic 1 E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing 3271 Concrete Block and Brick 3 E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing 3272 Concrete Products, Except Block and Brick 7 E Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturing 3275 Gypsum Products 4 F Primary Metals 3312 Steel Works, Blast Furnaces, and Rolling and Finishing Mills 1 F Primary Metals 3354 Aluminum Extruded Products 1 F Primary Metals 3369 Nonferrous Foundries, Except Aluminum and Copper 1 U Food and Kindred Products 2048 Prepared Feeds and Feed Ingredients for Animals and Fowls, Except Dogs and Cats 2

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47 Table 4.1.1.2.1: Continued Sector SIC Industrial Activity Represented NOI Filed U Food and Kindred Products 2077 Animal and Marine Fats and Oils 1 Y Rubber, Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries 3069 Fabricated Rubber Products, Not Elsewhere Classified 1 AA Fabricated Metals 3429 Hardware, Not Elsewhere Classified 1 AA Fabricated Metals 3441 Fabricated Structural Metal 1 AA Fabricated Metals 3444 Sheet Metal Work 2 AA Fabricated Metals 3449 Misc. Structural Metal Work 1 AA Fabricated Metals 3479 Coating, Engraving, and Allied Services, Not Elsewhere Classified 2 AA Fabricated Metals 3491 Industrial Valves 1 AA Fabricated Metals 3496 Misc. Fabricated Wire Products 2 AA Fabricated Metals 3499 Fabricated Metal Products, Not Elsewhere Classified 1 4.1.2 Evaluation of Analytical M onitoring Data In Identif ying Potential High Polluting Facilities 4.1.2.1 Identification of Industrial Facilities w ith Highest Concentrations of Pollutants in Their Discharge Highest pollutant concentrations from industrial facilities in Hillsborough County and Los Angeles County varied among different types of industrial activities (Table 4.1.2.1.1).

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48 Table 4.1.2.1.1: SICs with the Highest Concentrations Parameter Hillsborough County Los Angeles County TSS 3272, 3271 3271, 3714 Cu 2491, 3354, 3499 3561, 3714 Zn 3496, 3499, 3354 3471, 3463, 3714 Al 3496, 3444 3431, 3365, 3321 Fe 3444, 3496 3471, 3499, 3559 COD 2451, 2431, 3272 2834, 2621, 2076 N (nitrate & nitrite) 3499, 3491, 3496 3324, 2084, 3369 The majority of industrial facilities re quired to conduct analytical monitoring in Hillsborough and Los Angeles County reported under Sector E; Glass, Clay, Cement, Concrete, and Gypsum Product Manufacturi ng and SIC 3272; Concrete Products, Except Block and Brick. For both Hillsborough and Los Angeles County, SIC 32XX had the highest concentrations of all i ndustrial facilities in one para meter, total suspended solids (TSS). Variation in concentrations for each of the monitored parameters: TSS, copper (Cu), zinc (Zn), aluminum (Al), iron (Fe) chemical oxygen demand (COD), and nitrogen (N); were present in monito ring data for both counties. The three highest concentrations for seve n parameters for both counties are shown in Table 4.1.2.1.2. Table 4.1.2.1.2: Three Highest Concentrations Parameter Hillsborough County Los Angeles County TSS (mg/L) 610; 321; 210 20,700; 9,956; 6,640 Cu (mg/L) 148; .32; .042 8.34; 5.43; 4.1 Zn (mg/L) 8.53; 1.25; .74 742; 36.6; 33.2 Al (mg/L) 8.57; 2.5; 1.8 172; 49.8; 21.7 Fe (mg/L) 23; 17.5; 7.5 2,000; 1,010; 176 COD (mg/L) 628; 177; 1 17,900; 2,230; 2,000 N (mg/L) (nitrate & nitrite) 70; 31; 8.76 5.5; 4.79; 1.5

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49 Although many of the highest concentrations in each of the parameter were from the same facility, there was extreme varia tion in the concentrat ions for each of the parameters. The extreme variation in concentrations from one sample to another within a given facility for a given parameter makes it challenging for an agency to accurately determine whether a facility should be labele d as high risk. For example, in Hillsborough County the three highest concentr ations for zinc were from different facilities and the values were 8.53 mg/L, 1.25 mg/L and 0.74 mg/L (Figure 4.1.2.1). Three Highest Concentrations0.074 8.53 1.25 0 1 2 3 4 5 6 7 8 9 Facility 1Facility 2Facility 3Concentration of Zn mg/L Figure 4.1.2.1: Three Highest Concentrations There was a 7.79 mg/L difference betw een the highest and third highest concentration for zinc. Also, the two highe st concentrations, 8 .53 mg/L and 2.09 mg/L, were from the same facility, taken from the same discharge location four months apart. Sample result 8.53 mg/L was taken in April 2002 and 2.09 mg/L was taken in August 2002. There is a difference of 6.44 mg/L. Anothe r sample taken from the same facility five months later yielded zinc at a concen tration of 2.09 mg/L. The concentration values

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50 for zinc show how concentration variations can change over time with in a facility (Figure 4.1.2.2). Example of Concentration Variation Facility H4 0.032 0.41 0.561 1.92 2.09 8.53 2.090 1 2 3 4 5 6 7 8 9Apr-02Aug-02Feb-03Feb-04Mar-04Apr-04Jul-04 Sampling EventConcentration of Zn mg/L Figure 4.1.2.2: Example of Concentr ation Variation Facility H4 Due to the extreme variation in pollutant concentrations, it would be difficult for a regulatory agency to accurately assess an i ndustrial facility’s output to stormwater based on the results of the analytical monitoring data. Variation may be caused by multiple reasons such as untrained sa mpling personnel, change in th e activities of a facility, discharge location, and th e amount of rainfall. 4.1.2.2 Representativity of Data The representativity of the data ca n depend on the relationship of a given parameter monitored to the activities conducte d by a facility, the sampling frequency, and storm variability. Sampling frequency and storm variability will be discussed in detail below. Previous research has determined th at analytical monitori ng data in California could not be used to identify differences in discharges from differe nt types of industries

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51 (Stenstrom, 2005). The SIC a facility reports under may not repr esent the activities contributing pollutants to stormwater runo ff (Duke et al, 1999) Since stormwater analytical monitoring requirements are struct ured around SICs, this can lead to the wrong parameters being monitored, which can cause monitoring data variability. 4.1.2.3 Sampling Frequency Analytical monitoring must be conducte d on a quarterly basis in years two and four of the federal MSGP permit. The fac ility may be exempt from fourth year monitoring if the average results from the second year monitoring are below benchmark levels set by U.S. EPA. If a facility has one discharge location and was exempt from fourth year monitoring, the agency would have results from four samples to represent the facility’s activities over a five year peri od to determine whether a facility has a high potential to discharge polluta nts at high concentrations. Current regulations allow for sampling frequency to be low. At a maximum a facility with one discharge is required to take eight samples during a five year perm it cycle if not waived from fourth year analytical monitoring. The sampling frequenc y required under the MSGP regulations do not produce sufficient amount of data results in order to assist with the identification of potential high polluting facilities. In Hillsborough County, the analytical monitoring results were sparse. Out of 42 facilities required to conduc t analytical sampling, there were only 425 samples taken through out the permit cycles being issued from 2001-2005 with expiration dates from 2006-2011. In addition, there were 14 discha rge monitoring reports (DMR) submitted by facilities to the FDEP for MSGP permits i ssued in 2001-2005 that were blank and other facilities submitted incomplete DMRs. One f acility, H19, had six sample sites, sampled

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52 in the second and fourth year of the permit cycle and submitted seven blank DMRs out of the 42 samples taken. Even if regulations are followed correctly, samples taken by facilities are low and do not produce enough info rmation regarding the types of potential pollutants being discharged by a facility. Unlike Florida, the California MSGP requi res samples to be taken twice annually. The first sample is to be taken during the first storm of the wet season and one other sample is to be taken only once after. This allows a maximum of ten samples to be taken over a five year permit cycle. Ten samples are to represent the activities a facility conducts outdoors. In Los Angeles Count y from 1998-1999, there were a total of 4,474 samples taken from industrial facilities with some industrial facilities have multiple discharge locations. California has a different sampling frequency then Florida, but the amount of samples taken still does not provi de for sufficient results to assist in identifying potential high polluting facilities. In addition to requiring a small number of samples to be taken for analytical monitoring, there are sampling wa ivers available under the MSGP that allows facilities to be exempt from sampling or the sampling event is postponed. One type of sampling waiver allows for a facility not to conduct sampling if the facili ty is inactive and unstaffed thereby making sampling with the permit specifications not possible (U.S. EPA, 1999). One facility,H17 in Hillsborough C ounty submitted a letter to FDEP stating the facility was unable to conduct MSGP analyt ical monitoring for th e past two years due to a high turnover rate of staff. Facilities have many opportunities to justify to the regulatory agency why sampling might not have taken place. It is up to the discretion of the state agency whether

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53 or not to accept the reasons why sampling did not take place. If a large number of facilities are waived from analytical monitoring, it ma kes it difficult for regulatory agencies to identify high polluters. 4.1.2.4 Storm Variability Storm variability can have an immense impact on samples facilities taken for analytical monitoring. Grab samples must be collected from the discharge of a facility after a storm event that is great er than 0.1 inches in magnitude and that occurs at least 72 hours from the previously measurable stor m event. The permit allows for temporary waivers from analytical monitoring based on adverse climatic conditions. If samples cannot be collected within a specified sa mpling period due to insurmountable weather conditions, such as drought or hurricane, the facility must collect a substitute sample from a separate qualifying event in the next sampling period. The substitute sample must be taken in addition to the r outine monitoring required for that period (U.S. EPA, 1999). In order for a sample to be collected, a disc harge resulting from a storm must occur. In Hillsborough County from 2001 to present, there we re four facilities which indicated that no discharge had occurred during their samp ling period. In addition, one facility, H10, had not had a discharge in over four years. Si tuations like those for facility H10 may be contributed to low rainfall in a given year or unsuitable sampling locations. If a sampling location is at the outfalls of a retention or detention pond, then the pond must exceed its capacity before a discharge occurs. In Florida, were rainfall is frequent, sampling from a measurable storm event may not be as problem atic as it would be in Los Angeles County, where the frequency and magnitude of storm events can be variable.

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54 4.2 Assessment of Pollutant Loads to Receiving Waterbodies In order to confidently a ssess pollutant loading to re ceiving water bodies, enough facilities to form a representative sample need to be known and representativity among facilities needs to be assessable. Each fac ility in the sample also needs to monitor rigorously enough to ensure confidence that the facilities discharges are well described. The research does the following: 4.2.1 Identification of potential pollutant contributors 4.2.1.1 Industry Sectors and SICs Required To Conduct Analytical Monitoring; 4.2.1.2 Facilities within a Given Juri sdiction Required To Conduct Analytical Monitoring and; 4.2.1.3 Identification of Required Parameters to Be Analyzed By Sector Subsector/SIC. 4.2.2. Evaluation of Current Analyti cal Monitoring Results for Load Assessment 4.2.2.1 Measure of Concentration vs. Load And; 4.2.2.2 Sample Frequency and Representativity. 4.2.1 Identification of Potentia l Pollutant Contributors 4.2.1.1 Industry Sectors and SICs Required to Conduct Analytical Monitoring Industrial facilities that may be potential pollutant contributors to receiving waterbodies must first be identified to dete rmine where the potential sources of pollution may be originating. The same issues in the iden tification of industrial facilities previously discussed directly apply in determining po llutant loading to waterbodies. Identifying

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55 facilities required to conduct analytical monitoring under the MSGP is a starting point in attempting to assess pollutant loads to rece iving waterbodies. The number of facilities within an area is essential in or der to understand representativity. The identification of industrial facilities within a given juri sdiction required to conduct analytical monitoring will assist in determining potential pollutant contributors. 4.2.1.2 Facilities within a Given Jurisdicti on Required to Conduct Analytical Monitoring The process previously discussed on de termining facilities within a given jurisdiction required to conduct analytical monitoring can be applied to the approach of assessing pollutant loading to waterbodies. One of the issu es when trying to assess pollutant loading in a waterbody using analyt ical monitoring results is that facilities required to conduct analytical monitoring are only required to have selected parameters analyzed. 4.2.1.3 Identification of Required Parameters to be Analyzed by Sectors or Subsectors/SICs Through the U.S. EPA’s analysis, they dete rmined the parameters that needed to be monitored for by each sector or subsector /SIC (F.R. Vol.60, No. 189). In the analysis, the U.S. EPA identified potential pollutant(s) which may be directly related to industrial activities of the industry sector or subsector/SIC. The MSGP identifies which parameter(s) are required for analytical mon itoring. If the U.S. EPA did not identify a potential pollutant in the s ector or subsectors/SIC, then the permit does not require monitoring for that polluta nt (F.R. Vol.60, No. 189). For the majority of sectors or subsector/SI C, analytical monitoring is required for only two parameters. The majority of facilities monitor for total suspended solids (TSS).

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56 In Hillsborough County, other common parameters monitored include copper (Cu), zinc (Zn), aluminum (Al), iron (Fe), chemical oxygen demand (COD), a nd nitrogen including nitrates and nitrites (N). Each sector or subsectors/SIC is re quired to monitor for one or more of the before mentioned parameters. In Los Angeles County, all of the industrial facilities receiving coverage under the MS GP must monitor for TSS, pH, specific conductance, total organic carbon (TOC), oil and grease (O & G), and “any other parameter likely to be present in signifi cant quantities after tw o consecutive sampling events” (CA MSGP 1992). The parameters bot h counties monitor for are TSS, Cu, Zn, Al, Fe, COD, and N. The total maximum daily loads (TMD L) program under the CWA, requires jurisdictions to identify all s ources of given pollutants in a watershed of an impaired waterbody. Each jurisdiction has a list of impa ired waterbodies. The top five causes of impairments to waterbodies in Florida a nd California are iden tified in Table 4.2.1.3.1.

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57 Table 4.2.1.3.1: Top Five Causes of Impairme nts to Waterbodies in Florida and California General Impairment Name Cause of Impair ment Reported Percent of Reported Florida Oxygen Depletion 567 28 Nutrients 553 27 Pathogens 375 18 Turbidity 209 10 Metals (other than mercury) 178 9 California Pesticides 343 18 Pathogens 311 17 Metals (other than mercury) 247 13 Nutrients 147 8 Sediments 131 7 In Florida, the leading cause of impair ment to waterbodies is oxygen depletion. Under the oxygen depletion general impairment name, COD is one of the listed impairments but only one case was reported, while dissolved oxygen has the most causes reported, 492. The metals (other than mercur y) general impairment category has similar cases reported of impairments as the required monitored parameters under the stormwater regulations, such as Zn and Pb. The simila r parameters are COD, Cu, Fe, Pb, and Zn (Table 4.2.1.3.2 )

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58 Table 4.2.1.3.2: Top TMDL Parameters in Florida General Impairment Name Cause of Impa irment Reported Percent of Reported COD 1 0.2 Cu 20 11 Fe 49 28 Zn 4 2 Pb 53 30 The leading causes of impairments in Ca lifornia are pesticides Under the general impairment name for metals (other than merc ury) there were only 247 reported cases. OF these, five metals are specified for industr ial discharge monitoring, Al, Cu, Fe, Pb, and Zn. In both states, most of the parame ters required to by monitored under the stormwater regulations were not the paramete rs that contribute to the majority of impairments under the TMDL program. In order for the coordination of the two programs, stormwater and TMDL, to work successfully, both programs needs to be concerned with the same parameters when a ssessing pollutant load ing to waterbodies. 4.2.2 Evaluation of Current Analytical Mo nitoring Results for Load Assessment 4.2.2.1 Measure of Concentration vs. Load While the MSGP analytical monitoring meas ures concentrations of pollutants in runoff, other CWA programs need to know the pollutant load. Concentration in water is the mass of a substance in a given volume of water (Webster, 2006).Conversely, load is the total mass per unit of time of matter or thermal energy that is introduced into a receiving waterbody. In order to correctly a ssess the amount of a given pollutant entering

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59 a receiving waterbody, the determination of th at pollutant’s load or loading would be more accurate than measuring concentration. Knowledge of pollutant loads in runoff from facilities can assist watershed managers make better decisi ons and allocations that may require those loads to be revised. The analytical monitori ng results could assist in th e allocation of TMDLs if the pollutant loads were measured and every f acility was required to conduct analytical monitoring. However, as previously men tioned the sampling frequency required under the MSGP is low and so does not adequately capture the amount of pollutants being discharged. 4.2.2.2 Sample Frequency and Representativity As discussed in the previous section, th e sampling required by the regulations is infrequent, and in turn the da ta are not representative ove r time of the pollutants being discharged by the industrial facility. Facilities in the two counties, especially Hillsborough County, took very few samples and the concentrations of the monitored parameters varied greatly from sample to sample. The regulations in Florida and California do not require enough samples to be taken by the facilities to produce sufficient data to be representative to de termine with a high de gree of confidence the amount of loading occurring from industrial facilities into re ceiving waterbodies. 4.3 Documentation of Improvement Receiving coverage under the MSGP permit requires the permittee to develop a stormwater pollution prevention plan and im plement best management practices (BMP) to reduce pollutant loads disc harged. These are intended to reduce pollutant loads over

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60 time. One of the intents of the monitoring re quirements is for facilities to document improvements to their discharges over time This section evaluates the stormwater regulations and reported data to determine the possibility of identifying changes in pollutant loads over time. The telephone surv ey assisted in determining if facility operators are using the mon itoring results to document a ny changes occurring in their discharge. 4.3.1 Monitoring Specified by MSGP As previously mentioned, the MSGP has three types of monitoring requirements; visual examination, analytical monitoring, and compliance monitoring. For the purpose of this research, the focus is on visual examination and analytical monitoring. Visual examination and analytical monito ring has the potential to serve as a tool in documenting improvements overtime. Th e U.S.EPA believes visual examination provides a simple, low cost, and immediat e means of assessing water quality of stormwater discharge (F.R. Vol. 60, No. 189) While visual examination cannot assess the chemical properties of stormwater disc harge, it can perhaps provide meaningful results upon which a facility may act. One of the goals of visual examination is to relate the results of the examination to potential on-s ite sources of pollutant contamination (F.R. Vol. 60, No. 189). All the results from a visual examination are to be recorded and kept on file at the facility. Analytical monitoring allows the permittee to better ascertain the effectiveness of their SWPPP. This is another way for a facility to document their improvements overtime. The analytical mon itoring results are reported in quantitative concentration values for different pollutants and can easily be compared to results from other sampling

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61 events, other facilities, or to national benc hmarks. This type of monitoring allows a facility to evaluate the development and im plementation of their SWPPP (F.R. Vol. 60, No. 189) as well as detect any trends that might be occurring in their discharges. Although the MSGP requirements have specif ied various ways in which a facility has the potential to document improvements over time, the analytical monitoring requirements under perfect compliance do not provi de for sufficient data to detect trends. Under perfect compliance, analytical monitoring requires quarterly samples to be taken in years two and four of the permit cycle. A total of eight samples are taken during the duration of the five year permit cycle, assu ming the facility has one discharge location and the sampling is conducted correctl y. The sampling frequency and sample representativity of analytical monitoring is too low to detect any trends that might be occurring in the facilities discharge. The spar se and/or incomplete data results inhibit a facility’s ability to accurately document improvements over time or detect any trends. 4.3.2 Telephone Survey The telephone survey was developed to provide insights regarding visual observations, visual examinations, analytical monitoring, and the uses of the monitoring data by a facility for any purpose. The majority, 97%, of facilities who pa rticipated in the telephone survey, 44% were facilities not required to conduct analytical monitoring (NR) and 56% were facilities required to conduct analytical monitoring (R), indicated they conducted visual observations at their facility. Seventy-one pe rcent of all of the participating facilities indicated they used the information from the observation to make changes to their monitoring plans, or to update their SWPPP with 48% of the f acilities (NR) and 52% (R).

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62 However, participants indicating they use the information from the visual observations to make changes to their monitoring plan, or to update their SWPPP did not disclose what types of changes they make or have made. While visual observations are not required under the MSGP, many facilities are conduc ting these observations and using the information gathered to make management decisions. The high percentage of facilities indicating they conduct visual obs ervations can be attributed to what is considered to be visual observations. A walk through of the f acility in the morning, as one facility revealed, can be considered a type of visu al observation. Visual observation refers to when someone inspects the facility, during dry periods or during times when rain is running off, to look for possible stormwater pollutant problems. This is not to be confused with the required vi sual examination monitoring. The visual examination monitoring section of the telephone survey revealed that 82%, 57% (NR) and 43% (R), of the pa rticipating facilitie s conducted visual examinations. Out of these, 93 % were invo lved in developing their facility’s visual examination protocol. This is an indicator as to how familiar the participant is with his or her facility and the activi ties conducted on-site. The visual examination monitoring provides instant qualitative fee dback on facilities discharges while enabling a facility operator to evaluate the activities conducted on-site to determine the origin of pollutants found in the discharge. This pr ovides the facility with the opportunity to document the facilities progress in its ability to decreas e pollutants into stormwater overtime. The analytical monitoring section of the telephone questionnaire revealed only 62%, 21 participating facilities conducted analytical monitoring. Of these, 35% were waived from fourth year m onitoring of the current permit cycle, and 18% were waived

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63 from fourth year monitoring during the perv ious permit cycle. This low percent of facilities waived from fourth year monitoring is an indicator that the majority of facilities required to conduct analytical monitoring are di scharging pollutants at concentration of concern. Facilities are re quired to monitor during the fourth year of the permit only if the average concentrations in year two of th e permit exceed the benchmark concentration levels set forth by U.S. EPA. Under the MSGP monitoring regulations, a facility s hould have sufficient data from visual and analytical monitoring to not ice if there have been any improvements in the amount of pollutants being discharged into stormwater, especially since the majority of the facilities are required to monitoring during the fourth year of the permit. Under perfect compliance, a facility with one disc harge location, not waived from fourth year analytical monitoring, should have eight anal ytical monitoring sample results and 20 visual examination sample results to assist he facility operator at determining if there has been any improvement or change from sample to sample. However, the sample frequency and representativity is too low for 100 percen t confidence, but can se rve as an indicator as to whether further analysis needs to be conducted. Of the facilities who conducted analytical monitoring, the majority did not a ppear to be using the results from their monitoring to reassess the activities of a facility in order to determine if any improvements have occurred or more facili ties might be waived from fourth year monitoring. The telephone survey revealed that 48 %, 63% being (R), of the participants have not revised their monitoring plans such as adding samples or vi sual observation sites based on previous findings. However, 16 fac ilities did revise their monitoring plan but

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64 the questionnaire did not reveal what or how they revised their monitoring plan. The remaining three percent of th e facilities indicated they did not know if the monitoring plans had been revised. The three percent of f acilities indicating they did not know if the monitoring plans had been revised can be attr ibuted to some facilities indicating they outsource the stormwater monitori ng to consultants. One facil ity operator revealed he did not know anything about the stor mwater regulations or mon itoring requirements because the facility hires a consultant to do all of the work. Of these fac ilities, 59%, 50% (NR) and 50% (R) indicated they in cluded particular equipment or activities that were not previously addressed in the SWPPP. Overa ll, 38% of the respondi ng facilities did not include particular equipment or activities that were not previously addressed in the SWPPP but this indicates 62% of the partic ipants are required to conduct analytical monitoring. These participants identified problems with runoff, potential pollutants and/or located potential on-si te pollutant sources. A few facilities even indicated that monitoring results were used to maintain and uphold internal recording, to improve controls being used, to evaluate the s ite, and to correct potential problems. Even though the monitoring requirements under the MSGP have issues regarding low sampling frequency, waivers/exemptions, poor representativity, and low frequency to detect trends, many of the f acilities who conduct analytical monitoring are attempting to use the results for internal evaluations. This i ndicates the data results have the potential to be used to document improvements overtime an d detect trends. Howe ver, if a facility does not have adequate data to evaluate the pr ogress or regression of a facility, then it is impossible to document with confidence any trends or improvements that might be occurring.

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65 4.4 Self-Evaluation The fourth possible use of monitoring data is to determine if a facility operator can use the monitoring results fo r self-evaluation. The followi ng sections of the telephone questionnaire provided insight on the facility operators’ pers pective on the possibility of self evaluation: 1. Visual observations of the facility; 2. Visual examination monitoring; 3. Analytical monitoring; 4. Training; and 5. Uses of data. 4.4.1 Visual Observations of the Facility Nearly all of facilities participating in the telephone survey stated that they conducted visual observation at their facilitie s 97%. As mentioned previously, the high percentage of facilities conducting visual obser vations can be attributed to the simplicity of what is considered a visual observation. Visual observations are either performed once a quarter or whenever they f eel it is needed. The majority, 81% of the visual observations are conducted at stormwater outf alls and over half of the out falls are from retention or detention ponds. The limitation to conducting visual examin ations at retention or detention pond outfalls are the observer is una ble to link any observe d color or odor to the source of the activity because the pond is a mixture of many pollutants and is unable to determine when the pollutant release o ccurred because the pond stores pollutants over

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66 time. Outfalls are places where the stormwater leaves the facility such as a ditch or channel that leads to as offsite draina ge channel or pond. Other visual observation locations are included in Table 4.4.1.1. Table 4.4.1.1: Visual Observation Locations Responses from a total of 36 facilities Visual Observation Locations Yes No Do not have ---------------------------------------------------------------------------------------------------------------NR* R* NR* R* NR* R* ___________________________________________________________________________ Roof drainage, downspouts, or other drains were water runs off building roofs 10 6 5 12 1 2 ---------------------------------------------------------------------------------------------------------------Total 16 17 3 ___________________________________________________________________________ Roof surface, equipment on roof or the like 10 7 3 9 3 4 ---------------------------------------------------------------------------------------------------------------Total 16 12 7 ___________________________________________________________________________ Loading docks, unloading areas of the like 13 11 0 5 3 4 ---------------------------------------------------------------------------------------------------------------Total 24 5 7

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67 Table 4.4.1.1: Continued Responses from a total of 36 facilities Visual Observation Locations Yes No Do not have -----------------------------------------------------------------------------------------------------------------NR* R* NR* R* NR* R* Vehicle parking areas for service of delivery 12 15 0 4 4 1 -----------------------------------------------------------------------------------------------------------------Total 27 4 5 ___________________________________________________________________________ Vehicle maintenance areas 2 6 0 3 14 11 -----------------------------------------------------------------------------------------------------------------Total 8 3 25 ___________________________________________________________________________ Outdoor equipment 8 10 0 7 8 3 ----------------------------------------------------------------------------------------------------------------Total 18 7 11 ____________________________________________________________________________ Facility fenceline 11 12 3 9 0 1 ---------------------------------------------------------------------------------------------------------------Total 23 12 Doesn’t Know NRnot required to conduct analytical monitoring Rrequired to conduct analytical monitoring Besides retention or detention ponds, most facilities conducted visual observations around vehicle parking areas for service or delivery, loading docks, unloading areas, and/or the fenceline. Howe ver, a greater number of facilities not required to conduct analytical monitoring conduct ed visual observations at roof drainage, downspouts, or other drains were water runs off building roofs, roof surfaces, equipment on roof or the like, and loading docks, unloadi ng area of the like, while a greater number of facilities required to conduc t analytical monitoring conduct visual observations around vehicle parking areas for service of deliv ery, vehicle maintenance areas, outdoor equipment and the facility fenceline.

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68 In addition, the facilities required to conduct analytical monitoring 71% do not conduct visual observations at r oof drainage, downspouts or ot her drains were water runs off buildings roofs and 75% do not conduct visual observations on roof surfaces, equipment or the like. These locations have the potential to carry pollutants into stormwater runoff that originate from various sources such as, hear ventilating and air condition units or air compre ssors located on the roofs of the industrial facilities. However, of the facilities who performe d visual observation, 71% 48% (NR) and 52% (R), responded that they used the informati on to make changes to their monitoring plans or to update their SWPPP. 4.4.2 Visual Examinations Under the MSGP, visual examination mon itoring is required by all facilities receiving coverage under the pe rmit. Visual monitoring is wh en someone in the facility collects discharge samples for visual examina tion. Even though all f acilities are required to conduct visual examinations, six out of 34 facilities indicated that they do not. In addition, there were many facilities that in dicated they outsourced the monitoring and were not familiar with the MSGP requirements. However, out of those facilities that do conduct visual examinations, 93%, 44% (NR) and 55 (R), personally took part in developing the protocol. Taking part in the protocol is an indicator of how well the facility operator is familiar with the activ ities conducted on-site and the MSGP permit requirements. The sampling locations for the visual examinations were similar to the visual observation locations. The majority, 93%, of th e participating facilities took samples at outfalls, while 30% of facilities required to conduct analytical monitoring sampled from

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69 one or more on-site areas with industrial ac tivities, outdoor equipment, and/or material storage. Out of 25 facilities, 13 sampled at outfalls originating from retention or detention ponds, while the other 12 fac ilities sampled from other lo cations. Of the 13 facilities sampling from outfalls originating from retent ion or detention ponds, six facilities were not required to conduct analytical monito ring, while seven facili ties are required to conduct analytical monitoring. The majority of the 13 facilities sampling from retention or detention ponds sampled from retention ponds. Sampling from a retention or detenti on ponds obscures a pollutant’s origin. A retention pond is where the water is kept on-s ite until (usually) the water is absorbed into the ground. During a heavy rain event the re tention pond can overflow allowing sampling to occur. A detention pond is where the flow of the water is held back somewhat, for example to allow sediments to settle, and th en discharges into storm drains offsite, usually after every substantial rainfall. Th e ponds may contain a mixture of pollutants that may have originated from numerous activities conducted on-si te. The design and size of the retention and detention ponds can va ry. In many cases, a discharge occurs only when the capacity of the pond is exceeded ma king sampling difficult. If a discharge does not occur, sampling can not take place. This means that the polluted water can remain in the ponds for any given length of time. This can make it difficult to identify which activity is discharging a pollu tant, how often and in what concentrations. In addition, sampling from a pond complicates a facility’s evaluation because the samples will not be linked to the activities being conducted on-site and the pollutants being discharged at a given time.

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70 Facilities are required to examine sample s for specific parameters. The parameters required to be observed during visual examina tion by participating fa cilities are shown is Table 4.4.2.1. The majority of facilities observe d all of the parameters .Other parameters not required to be examined but were pr edominantly observed were TSS and floating particles. Table 4.4.2.1: Parameters Observed During Visual Examination: Number of Facilities Observing Each Parameter. Parameter Observed Not Required to Conduct Analytical Monitoring Required to Conduct Analytical Monitoring No. % No. % -----------------------------------------------------------------------------------Oily Sheen 14 52 13 48 Cloudiness 14 52 13 48 Color 14 52 13 48 Odor 14 52 13 48 Other 5 27 13 72 4.4.3 Analytical Monitoring As mentioned, analytical monitoring is required under the MSGP for specific industrial sectors and su bsectors/SICs. Out of the 34 partic ipating facilities, 21 indicated that they conducted analytical monitoring. Of the 21 facilities indicating they conduct analytical monitoring, five f acilities are not required to conduct analytical monitoring. The five facilities not required to conduct analytical monitoring but indicated they do, report under SICs 3731, 3299, 3663 and the othe r two are unknown. All three of the known SICs, 3731, 3299 and 3663, industrial activities are different and are in different sectors.

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71 The facilities particip ating in the telephone survey app eared to be either in their second year of the five year permit cycle or ju st after. Half of the facilities had conducted the second year analytical monitoring requi rements for their current permit cycle while the other half of the facilities had not and only 35%, 14% (NR) and 86% (R), of the facilities had conducted their fourth year monitoring. A greater percentage, 71% of facilities indicated they di d conduct second year analyt ical monitoring during the previous permit cycle. This is an indicator of the facilities oper ators’ knowledge of previous monitoring which can in turn assist in the next monitoring cycle and familiarity with facility. However, only half of the facilities we re aware that the facility’s fourth year monitoring can be waived, if the results of the second year monitoring show no constituents exceed the benchmark concentra tion shown in the regulations. This is an indication that not many facility operators are familiar with the MSGP permit requirements. In addition, only 18% of the part icipating facilities were waived from the fourth year analytical monitoring for its prev ious permit cycle in which only one facility waived is required to conduct analytical monito ring. This means the majority of facilities were discharging pollutants at concentrations of con cern during the second year sampling. Although, half of the f acilities indicated they woul d collect samples during the fourth year even if they are not require d, 68%. Conversely, 80% of the facilities being required to conduct analytical monitoring, indi cated they had not collected samples at additional times, other than the requir ed second and fourth year monitoring. The majority, 86%, of the participating f acilities took their samples for analytical analysis from outfalls. However, only 42% of the outfalls are from retention or detention ponds and 62% of the facilities indicated they do not sample from one or more on-site

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72 areas with industrial activities outdoor process equipment, and/or material storage. Of the 62% facilities indicated they do not samp le from one or more on-site areas with industrial activities, outdoor processes equipment, and/ or material storage, 69% are required to conduct analytical monitoring. A fe w facilities indicated they sampled from places of drainage, such as where the stormwat er drains into the city sewer or into the facility’s main drains. Other sampling locat ions were not mentioned by the facility operators. A list of common parameters that were analyzed by industrial facilities in Hillsborough County is shown in Table 4.4.3.1. The additional parameters that many facilities mentioned they anal yzed for were chemical oxyg en demand (COD) and oil and grease (O&G). Total suspended solids were the most common parameter analyzed while copper was the least. Table 4.4.3.1: Parameters Each Facility Analyze Parameter Not Required to Conduct Analytical Monitoring Required to Conduct Analytical Monitoring No. % No. % ---------------------------------------------------------------------------TSS 4 24 13 76 N (nitrate & nitrite) 3 38 5 63 Al 3 38 5 63 Fe 4 40 6 60 Zn 4 45 5 55 Cu 4 57 3 43 4.4.4 Training Participating facilities that provided training to their personnel is shown is Table 4.4.4.1. Most facilities provided training on reco gnizing evidence that pollutants may be

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73 in stormwater, such as water color or oili ness in runoff during wet weather events. A few facilities did indicate that their entire facility was trained on overall environmental issues including stormwater, while othe r facilities had just one pe rson trained or outsourced the monitoring work. The majority of the faciliti es had more than thre e trained personnel on staff. However, training on sampling or sa mple handling was not provided to personnel by any facilities. Table:4.4.4.1: Types of Training Provided Types of Training Not Required to Conduct Analytical Monitoring Required to Conduct Analytical Monitoring No. % No. % -----------------------------------------------------------------------------------Identify locations where evidence of potential stormwater pollutants may be found 12 46 14 54 Recognize evidence that pollutants may be exposed to stormwater 14 47 16 53 Overall aspects of stormwater regulations as they apply to the facility 14 52 13 48 State-wide mulitsector general permit for industrial stormwater discharges 13 57 10 43 Environmental issues in general related to stormwater 14 48 15 52 4.4.5 Uses of the Data This section of the teleph one questionnaire was designed to determine in what way facilities used the information obtained fr om monitoring. Facilities indicating they

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74 use the monitoring results Table 4.4.5.1 and f acilities indicating they do not use the monitoring results Table 4.4.5.2. Table 4.4.5.1: Facilities Indicating They Use the Analytical Monitoring Results Required to Conduct Analytical Monitoring Not Required to Conduct Analytical Monitoring Revise Monitoring Plan 50% 50% Modify SWPPP 50% 50% Identify Stormwater Runoff Issues 54% 46% Table 4.4.5.2: Facilities Indicating They Do Not Use the Analytical Monitoring Results Required to Conduct Analytical Monitoring Not Required to Conduct Analytical Monitoring Revise Monitoring Plan 63% 38% Modify SWPPP 63% 38% Identify Stormwater Runoff Issues 60% 40% The results from the telephone survey re garding the uses of monitoring results differed from those facilities not required to conduct anal ytical monitoring from those required to conduct analytical monitoring. Out of the 33 participants 16 facilities revised the monitoring plan and 16 fac ilities had not and one facility did not know. Out of the 16 facilities that had revised the monitoring plan, half were not required to conduct analytical monitoring and half were re quired to conduct analytical monitoring. Conversely, 10 out of the 16 facilities that had not revised the monitoring plan were facilities required to con duct analytical monitoring. Twenty participating facilities indicated that they used the information obtained from monitoring to modify the SWPPP to incl ude particular equipmen t or activities that were not previously addressed in the SWPPP. Some participating facilities indicated they use the results to ensure compliance, internal purposes, to correct potential problems, but

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75 not facility gave any examples of the way they specifically use the monitoring results. Half of the twenty facilities were not required to conduct analytical monitoring and the other half were required to conduct analyt ical monitoring. However, the facilities required to conduct analytical monitoring were the majority out of the 38% who has not modified the SWPPP. Some facilities indicated they use the in formation to improve the controls being used and evaluate the site, while converse ly, one facility indi cated they use the monitoring protocol from their original Phas e I & II audits from the 1960s. For example, one facility operator noticed there was sediments in the runoff from the facility and changed the groundcover in an area we re the sediment was originating. The industrial facilities SICs the U.S. EP A has indicated to released pollutants at concentrations of concerns by the nature of the industry to conduc t additional monitoring other than visual examination, in order to en sure pollutants are not being released through their discharge, are the majority of facilities not using the monitoring results to revise the monitoring plan or modify the SWPPP. The pr oportion of facilities required to monitor that use the results is smalle r that the proportion not required Thirty-eight percent of the facilities indicated they have identified problem s with runoff, potential pollutants and/or located potential on-site sources and majority of facilities will r eapply for MSGP permit coverage. Through the telephone survey, unexpected ly, industrial fac ility operators indicated they are attempting to use the m onitoring results for self-evaluation purposes including those not required a nd required to conduct analyt ical monitoring. In order for an industrial facility to adequately evaluate the facility, the operator must go beyond the

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76 monitoring protocol specified in the stormwater regulations in order to obtain sufficient monitoring result.

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77 5.0 DISCUSSION 5.1 Facility Operator’s Knowledge of Stormwater Regulations There were six potential f acilities out of 36 conducti ng analytical monitoring sampling correctly. The six potential facilities were the facilities that appeared to be conducting sampling correctly from the anal ytical monitoring results based on the discharge location, year, and month the sample was taken. The majority of the facilities appeared to be in the third year of the five year permit cycle. However, the majority of the potential facilities samples were over be nchmark concentrations. Aluminum was the most monitored parameter, which usually was over the benchmark concentration. Only two of the six facili ties participated in the tele phone survey. Three of the six were passive refusal, while one facility activ ely refused to participate in the telephone survey. Facility H33 outsourced the analytical monitoring to a consultant and relied on the consultant’s stormwater regulations and monitoring experience. Facility H33’s operator responded that he did not know if there was a four th year monitoring waiver offered to facilities and hoped the consulta nt was aware of the waiver. However, both facilities participati ng in the telephone survey reveal ed they update their SWPPP as needed but did not indicate how or what has been updated. The incorrect sampling by most facilities can be attributed to the lack of knowledge facility operators ma y have of the stormwater regulations. For instance, one facility did not know if the facility had sa mpled during the second year of the facilities current permit cycle, while another facility did not know if samples were being taken at

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78 outfalls. Two facilities did not know if additio nal samples had been taken at other times then (THAN?) the required second and fourth year and thirteen facili ties did not know if the facility was waived from fourth year m onitoring. Surprisingly, six facilities were not aware of the waiver for fourth year monito ring, while four facility operators responded that they did not know when asked if they were aware of the waiver. The lack of knowledge some facility operato rs appear to have about stormwater monitoring requirements is an indicator to th e reason there appears to be large number of facilities not complying with the stormwater regulations correctly. This supports the argument of poor compliance with the stormwater regulations among industrial facilities. 5.2 Structure of stormwater regulations The intent and goal of the stormwater re gulations is to decr ease pollutants being discharged at concentrations of concern from industrial facilities can be seen throughout the requirements. However, the requirements only lay the foundation in achieving this goal. The three tools SWPPP, BMPs, and monito ring set the stage in the attempt by the federal government at trying to reduce pollu tants being discharged into stormwater runoff. The regulations are written with tw o opposing goals of project the environment and not placing more burden on the regulated community. The monitoring regulations for stromwater, appear to attain the latt er goal better that the former goal. The requirements under the SWPPP are very detailed and require a lot of work by the facility, while stil l allowing the flexibility for facilities to choos e the BMP that best fits their activities. The faci lity is required to develop, implement, and keep onsite the SWPPP, but does not have to submit the SWPPP to the state. Ther efore, many facilities

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79 develop a SWPPP the first time the facility receives MSGP permit coverage. This SWPPP will remain the same with little ch ange through out the years and through many permit cycles. Facility operators revealed th ey use the monitoring results to update or change the SWPPP or monitoring plans, but th e analytical monitoring data submitted to the state suggests otherwise. The sparse an alytical monitoring re sults provided by the facilities do not provide sufficien t information to serve as reliable feedback. The results would not support decisions to update or cha nge the SWPPP or monitoring plan in any major way other than name changes. The structure of the monitoring requirements contributes to the inaccuracy in the monito ring results, in turn not being sufficient to incorporate into the SWPPP or monitoring protocol. The current monitoring requirements, under perfect compliance, attempt to provide enough information to determine if pollutants are being discharged in concentrations of concern. However, the sa mpling frequency and representativity as previously discussed inhibit th e use of the data to make any conclusive determinations. The benchmarks set forth by the U.S. EPA onl y are used to determine if fourth year analytical monitoring needs to take pl ace. There are no substantial regulatory repercussions for facilities analytical monitoring results to be over benchmark concentrations. In order to ach ieve the goals and intent of the stormwater regulations, analytical monitoring only one year out of the five year duration of the permit, for facilities the U.S. EPA has determined to have a high potential to discharge a pollutant at concentrations of concern doe s not assist in reducing pollu tants being discharged into stormwater runoff.

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80 Another challenge facing compliance under the stormwater regulations are facilities that were constructed before the implementation of the stormwater regulations. Through the telephone survey, facility opera tors offered information regarding new facilities verse older facilities build before there was a concern for stormwater runoff. The newer facilities are able to incorporate st ormwater drainage designs into the layout of the facility prior to construction in order to accommodate for the activities conducted onsite that might discharge pollutants. On e design that appears to be common among facilities is to have the entire facility all drai n to one point on the f acilities property were monitoring takes place. This si ngle point of drainage is usua lly a retention or detention pond. The main issue with this type of design is trying to correlate po llutants to its origin, since all the runoff accumulates at one point. In addition, some retention and detention ponds are designed to hold a la rge quantity of water. For example, one participating facility’s pond was designed to withstand the 100 year st orm. In this case, the pond would not usually overflow causing no discharg e to occur and therefore no monitoring would take place. The monitoring requirements need to be structured to produce more reliable and accurate data in order for facilities to be tter utilize the information. 5.3 Limitations This research was successful at evaluati ng four possible uses of the monitoring data obtained under the MSGP permit and obtained facility operator’s perspectives. Limitations to the findings include issues regarding the runoff data, sample size, reliability, and insurance. The monitoring data results from the di scharge monitoring reports submitted to FDEP were vary sparse. One explanation fo r the sparse data is the nature of the

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81 stormwater regulations. As demonstrated th rough this research, the number of samples industrial facilities ar e required to take during the durati on of the permit is minimal. The monitoring results did not inhibit th e objectives of this research. The sample size of industria l facilities available for pa rticipation in the telephone survey included all facilities receiving coverage under the MSGP permit in the manufacturing sectors. Hillsborough County is among the highest industrial counties in Florida and therefore was one of the reasons the county was chosen. The sample size for the purposes of this research was larg e enough not to affect the results. Another potential limitation to this research is the reliability of the participant’s responses to the telephone surv ey. When dealing directly with human participates there is always the chance of the participant’s response not to be reliable. However, steps in this research, such as sending out an introducto ry letter and insuring confidentiality were taken in order to assist in the attempt to incr ease the response rate as well as increase the reliability of the participants. Site visits to industrial f acilities would have been a wa y to insure the accuracy in the responses to the telephone survey; however, this step wa s out of the scope of this research and should be considered for future research. 5.4 Future Research This research has gained information on industrial faciliti es’ perspective of monitoring data through a tele phone survey. The telephone survey revealed that facility operators claim they conduct visual observati ons and use the data for self evaluation purposes. Future research needs to accomp any a regulatory author ity to inspect and evaluate the facilities SWPPP and their visual examination records. Th is will determine if

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82 the information provided in the telephone survey was accurate and will discover how often changes or modifications are made to the SWPPP. In addition, on-site visits would provide more detailed information regarding how facilities are attempting to comply with stormwater regulations by using the tool s the regulations offer for compliance. 5.5 Recommendations The structure of the MSGP permit requirements was a good first attempt at decreasing the discharge of pollutants into stormwater runoff. However, the compliance tools, SWPPP, BMPs and monitoring needs to be better enforced by the regulatory agency. The regulatory agencies need to be more involved with facilities in order to work more closely with them in achieving complia nce. In addition, visual observations should be required by the regulations and need to be conducted at least on a monthly basis to ensure the activities being c onducted onsite are not contribu ting to stormwater runoff. The sampling requirements for both visual exam inations and analytical monitoring need to be changed. Sampling needs to occur more of ten in order to get representative samples to determine the types of pollutants being disc harged. Facilities need to be aware of the types of pollutants that have th e potential to be discharged at their facility and have the samples analyzed for the applicable parameters All documents and/or results need to be submitted and reviewed by the regulatory agencies. This will assist in achieving a higher compliance rate if facilities knew th eir information was being reviewed. These recommendations to the stormwater regulations may cause more of a burden on the facilities. Some t ype of incentives need to be offered to those facilities complying correctly and do not have pollutant discharge issues. On incentive option is to waive or reduce the permit fees. Another incen tive is a quick permit processing time. For

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83 facilities that have continually not had polluta nt discharge issues can apply to be waived from monthly visual examinations to only quarterly examinations. These recommendations could improve monitoring requir ements so that facility monitoring data can be used to improve the agencies’ abilities to protect the water quality of stormwater through the regulations for industry.

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84 6.0 CONCLUSIONS The first specific objective of this research was to evaluated the extent to which industrial facility monitoring data collect ed under the regulati ons for stormwater discharges associated with i ndustrial activities supported the goa ls and objectives of those regulations from two viewpoints: first, whethe r the goals and objectives of the regulations are supported by the data as currently availabl e, given the current implementation of the monitoring program under the i ndustrial stormwater regula tions; and second, whether the goals and objectives of the re gulations would be supported if the regulatory requirements were perfectly implemented under full complia nce with the regulati ons as designed and intended. Under the current implementation of th e MSGP monitoring program under the industrial stormwater re gulations the monitoring results do not fully support the goals and objectives of those regulations. This research evaluated four possible uses of monitoring data and determined if the current pr ogram was meeting any of those uses. The sampling frequency, represenativity, and variation in th e monitoring results taken by the industrial facil ities does not allow for the intended protection of the receiving waterbodies. Many facilities do not take the required amount of samples necessary under the MSGP. The MSGP monitoring requirements of th e stormwater regulations under perfect compliance do not allow for the goals and objecti ves of those regulati ons to be met. The monitoring requirements, especially the anal ytical monitoring requi rements require only a

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85 minimal amount of samples to be taken. Visu al examinations, if performed correctly, have the potential to provide the most feedback to a facility as to pollutants in the discharge as well as carry out the goal and obj ectives of the stormwater regulations. This is because visual examinations required 20 sa mples to be taken duri ng the duration of the five year permit which is more than the analytical monitoring requires. Even though analytical monitoring is required only for the industry sectors or sub-sectors that were determined by the U.S.EPA to have a hi gh potential to discha rge a pollutant at concentrations of concern are only required to sample four ti mes a year if being waived from fourth year monitoring and have one di scharge location. Four samples are suppose to represent the on-site activities conducted at an indus trial facility ove r a five year period. The second objective was to evaluate the ex tent to which industrial facilities monitoring data can support the needs or goals of related poli cies and regulations of the United States, such as other Clean Water Ac t regulations or other policies designed to protect water quality. The monitoring progr ams were evaluated from the same two viewpoints, assessing the data as currently collected and ev aluating the data’s potential usefulness under the cas e of perfect compliance with the monitoring requirements of the regulations. The industrial facilities monitoring data does not support the needs or goals of related policies and regulations of the Un ited States. The MS4 required under the CWA requires permittees to identify facilities havi ng a high risk of cont ributing pollutants to stormwater runoff. The low sample frequenc y, representaivity a nd variation in the industrial facilities analy tical monitoring results can not identify with confidence

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86 potential high risk polluters. In addition even under perfect comp liance, the sample frequency required by the MSGP monitoring requirements does provide for sufficient results. The industrial facility anal ytical monitoring data does not support the goals and objectives of the CWA’s TMDL program ev en under perfect compliance. The sampling frequency, representativity and variation of the samples do not provide for sufficient data when assisting with the TMDL program. In addition, the parameters required to be analyzed for under the MSGP are not alwa ys the same causes of impairments to waterbodies listed under the TMDL program. The MSGP measures the parameters in concentrations while the TMDL program measurements are in loads. The two types of measurements are not comparable. This differe nce is an inhibitor in trying to use the industrial facilities anal ytical monitoring data to meet or assist in meeting the goals and objectives of the TMDL program. This research assessed the perspectives of the regulated community toward the monitoring requirements and the extent to whic h they make use of the results of their required monitoring. This assessment evalua ted one other category of use of the monitoring requirements that has been identified as a potential benefit of the regulations. Industrial facility operato r’s indicated from the telephone survey they use the monitoring results for self evaluation pur poses. However, not many facilities made changes to their monitoring plans or SWPP P as an outcome of the monitoring data results. Conversely, the sparse analytical monitoring results sugge st many facilities are not conducting analytical monitoring regularly or correctly. Many facili ties indicated they are conducting visual observations at their facilities on a regular bases, which might be in

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87 turn the information facility operators are using for self evaluation instead of using the analytical monitoring results.

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88 LIST OF REFERENCES Augustenborg, C.A., 2001. Effectiveness Assessment of NPDES Regulations for Storm Water Discharges Master’s Degree Report, UCLA: Los Angeles, CA. Bailey, Bob. 1993. Surviving the Stormwater Permit Process Water Environment & Technology. Duke, L.D. and C.A. Augustenborg, 2006. Effec tiveness of Self-Regulated and SelfReported Environmental Regulations for Industry: The Case of Stormwater Runoff in the U.S. Journal of Environmental Planning and Management : In Press. Duke, L.D. and P.G. Beswick, 1997. Industry Compliance with Storm Water Pollution Prevention Regulations: The Case of Tr ansportation Industry Facilities in California and the Los Angeles Region. Journal of the Amer ican Water Resources Association, 33:4, 825-838. Duke, L.D. and K.A. Shaver, 1999. Widespread Failure to Comply with U.S. Stormwater Regulations for Industry: Pa rt II: Facility-Level Evaluations to Estimate Number of Regulated Facilities. Environmental Engineering Science, 16:4, 249-263. Duke, L.D., K.A. Shaver, J.L. Burnam T.P. Todd, and C.A. Augustenborg, 2001. Industrial Storm Water Discharge Id entification and Compliance Evaluation in the City of Los Angeles. Final Report to California Regional Water Quality Control Board, July 2001. 120 pp. Duke, L.D., Xavier Swamikannu, Michael Mullin. 2001. Industrial Storm Water Discharger Identification and Complian ce Evaluation In The City Of Los Angeles Final Report. July 3, 2001. FDEP (Florida Department of Environmental Protection), 2005a. Program for Municipal Separate Storm Sewer Systems (MS4). Available at: http://www.dep.state.fl.us/wat er/stormwater/ npdes/MS4_1.htm Accessed in September, 2005. FLS000006, 2002. State of Florida Municipal Separate Storm Sewer System Permit No. FLS000006. Issued October 31, 2002.

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89 FS (Florida Statutes), 2000a. 403.0885, Establishment of Fede rally Approved State National Pollutant Discharge Elim ination System (NPDES) Program. State of Florida Title XXIX, Chapter 403, Public Health, Environmental Control. Available at: h ttp://www.dep.state.fl.us/water /stormwater/npd es/docs/403_0885.pdf Accessed in December, 2004. FS (Florida Statutes), 2000b. Generic Permits. Rule 62-621 Florida Administrative Codes. Available at: http://www.dep.state.fl.us/l egal/rules/shared/62-621.pdf Accessed in June 13, 2005. FS (Florida Statutes), 2000c. Municipal Separate Storm Sewer Systems. Rule 62-624 Florida Administrative Codes. Available at: http://www.dep.state.fl.us /legal/rules/shared/62-624.pdf Accessed in October, 2004. FS (Florida Statutes), 2000d. Permits. Rule 62-4 Florida Administrative Codes. Available at: http://www.dep.state.fl.us /legal/rules/shared/62-4.pdf Accessed in October, 2004. FS (Florida Statutes), 2000e. Regulations of Stormwater Discharge. Rule 62-25 Florida Administrative Codes. Accessed at: http://www.dep.state.fl.us/le gal/rules/surfacewater/62-25.pdf Accessed in October, 2004. General Permit NO. CAS00001. State Water Re sources Control Board. Water Quality Order NO. 97-03-DWQ. Glicksberg, D., 2005. Personal Communication with David Glicksberg, Environmental Manager, Stormwater Management, Public Works Department, Hillsborough County, Florida on February, 2005. Griffin, Lindsay M., 2005. Reducing Pollutants in Indus trial Stormwater Runoff: Improved Water Quality Protection Us ing Prioritized Facility Regulation Master’s Degree Report, University of South Florida: Department of Environmental Science and Policy, College of Arts and Sciences. Kelly, S., 2005. Personal Communication with Steve Kelly, Stormwater Section, Florida Department of Envi ronmental Protection on April, 2006. MSSSSP (Municipal Separate Storm Sewer System Permit), 2004. State of Florida Municipal Separate Storm Sewer System Permit No. FLS00006. Issued October 31, 2002. Patwell, M. Joseph. Webster’s II New Riverside Pocket Dictionary. 2002. Houghton Mifflin Company.

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90 Stenstrom, Michael K., Haejin Lee. 2005. Final Report Industrial Storm WMonitoring Program Existing Statewide Permit Utility and Proposed Modification Civil and Environmental Engi neering Department, UCLA Los Angeles, California. U.S. EPA (U.S. Environmental Protection Agency), Title 40 Protection of Environment, Chapter 1Environmental Protection Agency, Part 122 EPA Administered Permit Programs: The Nati onal Pollutant Discharge Elimination System http://www.access.gpo.gov/nara /cfr/waisidx_02/40cfr122_02.html U.S. EPA (U.S. Environmental Protection Agency), Water Planning Division, 1983. Results of the Nationwide Urban Runoff Program. U.S. EPA (U.S. Environmental Protection Agency), 1992a. Final NPDES General Permit For Storm Water Discharges Associated with Industrial Activity. Federal Register 58(222):61333-61342. U.S. EPA (U.S. Environmental Protection Agency) 1992. National Water Quality Inventory, 1992 Report to Congress. EPA Office of Water. U.S. EPA (U.S. Environmental Protecti on Agency). 1992.b NPDES Storm Water Sampling Guidance Document. July. EP A 833-8-92-001 Office of Water {EN336}. U.S. EPA (U.S. Environmental Protection Agency), 1995a. Final National Pollutant Discharge Elimination System Storm Wa ter Multi-Sector General Permit for Industrial Activities; Notice. Federal Register, Vol. 60, No. 189, Friday, September 29, 1995. U.S. EPA (U.S. Environmental Protection Agency), 1995b. Storm Water Discharges Potentially Addressed By Phase II Of The National Pollutant Discharge Elimination System Storm Wate r Program Report To Congress EPA 833-K-94002, U.S. EPA, Office of Water (4203). U.S. EPA (U.S. Environmental Protection Agency), 1999. Guidance Manual for the Monitoring and Reporting Requirements of the NPDES Mulit-Sector Storm Water General Permit. U.S. EPA (U.S. Environmental Protection Agency), 2005 National Pollution Discharge Elimination Syst em. Industrial Activity. http://cfpub.epa.gov/npd es/stormwatermonth.cfm U.S. EPA (U.S. Environmental Protection Agency), 2006 Total Maximum Daily Loads. http://www.epa.gov/owow/tmdl/intro.html#definition

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91 BIBLIOGRAPHY 33 U.S.C 1251 et seq., 2002. Federal Water Pollution Control Act As Amended through P.L. 107-303, November 27, 2002. Adler, R.W., J.C. Landman, and D.M. Cameron, 1993. The Clean Water Act: 20 Years Later Island Press: Washington D.C. Athayde, D.N., P.E. Shelley, E.D. Dr iscoll, D. Gaboury, and G. Byod, 1983. Results of the Nationwide Urban Runoff Program, Executive Summary U.S. Environmental Protection Agency, Office of Water Program Operations, Water Planning Division, Washington D.C., 30 pp. Deily, Mary E. 1991. Enforcement of Pollution Regulations in a Declining Industry Journal of Environmental Econom ics and Management 21 260-274. Duke, L.D., 1999. Storm Water General Industrial Perm it Non-Filer Iden tification and Communication Project California State Water Resource Control Board. University of California. Duke, L.D., 2005. Effluent Limitations and the NPDES Permit, In: Water Encyclopedia: Domestic, Municipal, and Industr ial Water Supply and Waste Disposal J. Lehr, J. Keeley, J.Lehr, and T.B. Kingery III (Editors). Duke, L.D., K.P. Coleman, and B. Masek, B. 1999a. Widespread Failure to Comply with U.S. Stormwater Regulations for Industry: Part I: Publicly-Available Data to Estimate Number of Potentially Regulated Facilities. Environmental Engineering Science, 16:4 229-247. Duke, L.D., K.A. Shaver, Y.J. Chung, J. Burnam, M.A. Yeager, K.P. Coleman, B. Masek, L. Ganse, N. Meck, and C.R. Jones, 1999b. Storm Water General Industrial Permit Non-file r Identification and Comm unication Project. Draft Final Report to California State Water Resources Control Board, contract no. 5-096-250-0, May 1999. FDEP (Florida Department of Environmen tal Protection), 2000a. Authorization of State of Florida to Implement NP DES Program. Section 403.0885 Florida Statutes, October 2000.

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92 FDEP (Florida Department of Environmen tal Protection), 2000c Notice of Intent To Use Multi-Sector Generic Permit for Stormwater Discharge Associated with Industrial Activity. DEP Form 62-621.300( 5)(b, F.A.C. Effective October 22, 2000. FDEP (Florida Department of Enviro nmental Protection), 2001. No Exposure Certification for Exclusion from NPDES Stormwater Permitting. DEP Form 62-620.910(17), F.A.C. Effective June 1, 2001. FDEP (Florida Department of Environmental Protection), 2002. Florida’s 303(d) List. Available at : http://www.dep.state.fl.us /water/tmdl/docs/303(d)-2.pdf Accessed in February 2005. FDEP (Florida Department of Environmental Protection), 2004. Florida’s NPDES Stormwater Program. Available at: http://www.dep.state.fl.us/wat er/stormwater/ npdes/index.htm Accessed in April, 2005. FDEP (Florida Department of Environmental Protection), 2005a. Program for Municipal Separate Storm Sewer Systems (MS4). Available at: http://www.dep.state.fl.us/wat er/stormwater/ npdes/MS4_1.htm Accessed in September, 2005. FLS000006, 2002. State of Florida Municipal Separate Storm Sewer System Permit No. FLS000006. Issued October 31, 2002. FS (Florida Statutes), 2000a. 403.0885, Establishment of Fede rally Approved State National Pollutant Discharge Elim ination System (NPDES) Program. State of Florida Title XXIX, Chapter 403, Public Health, Environmental Control. Available at: h ttp://www.dep.state.fl.us/water /stormwater/npd es/docs/403_0885.pdf Accessed in December, 2004. FS (Florida Statutes), 2000c. Municipal Separate Storm Sewer Systems. Rule 62-624 Florida Administrative Codes. Available at: http://www.dep.state.fl.us /legal/rules/shared/62-624.pdf Accessed in October, 2004. FS (Florida Statutes), 2000d. Permits. Rule 62-4 Florida Administrative Codes. Available at: http://www.dep.state.fl.us /legal/rules/shared/62-4.pdf Accessed in October, 2004. General Permit NO. CAS00001. State Water Re sources Control Board. Water Quality Order NO. 97-03-DWQ.

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93 Giddens, Nancy, 2004. Finding Your Facts – A Quick Guide to Developing a Questionnaire. File C5-26. www.extension.iastate.edu/agdm Iowa State University, University Extension. 2004. Goldberg, Rob. 1993. EPA Expands Stormwater Control Permitting Law & Government. Krehbiel, Timothy C.,2001. C haracteristics of selfre gulating environmental management systems: a survey of academic experts Int. J. Environmental Technology and Management, Vol. 1. No. . Copyright 2001 Inderscience Enterprises Ltd. Kubasek, N.K. and G.S. Silverman, 2005. Environmental Law (5th Edition). Pearson Prentice Hall: Upper Saddle River, N.J. Livernois, John and C.J. McKenna, 1999. Truth or Consequances Enforcing Pollution Standards with Self-Reporting. Journal of Public Economics 71 415440. Magat, Wesley A and W. Kip Visusi, 1990. Effectiveness of the EPA’s Regulatory Enforcement: The Case Of Industrial Effluent Standards Journal of Law & Economics., Vol. XXXIII. Copyright University of Chicago. Murphy, Sheila. 2005. General Information on Total Suspended Solids City of Bolder/USGS Water Quality Monitoring. Natural Resources Defense Council. 2005. Stormwater Strategies Community Responses to Runoff Pollution. http://www.nrdc.org/water/pollution/storm/ O’Leary, Rosemary, Durant, R obert F., Weiland Paul S., 1997. Managing for the Environment Jossey-Bass Publishers: San Francisco. OMB (Office of Management and Budget), 1987. Standard Industrial Classification Manual Executive Office of the President: Washington, D.C. OOW (U.S. Environmental Protectio n Agency Office of Water), 1999. Preliminary Data Summary of Urban Storm Water Best Management Practices. EPA-821-R 99-012. Office of Water: Washington, D.C. Plaff, S, P. Alexander and Chris William Sanchirico, 2000. Environmental Self – Auditing: Setting the Proper Incentiv es for Discovery and Correction of Environmental Harm Journal of Law, Economics & Organization, V16N1. Oxford University Press.

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94 Pitt, Robert and Melinda Lalor, 2000. The Role of Pollution Prevention in Stormwater Management. Models and A pplications to Urban Water Systems, Monograph 9. Guelph, Ontario.2000, pgs. 1 to 20. Rosenbaum, W.A., 1995. Environmental Politics and Policy (3rd Edition). CQ Press: Washington, D.C. Rosenbaum, W.A., 2005. Environmental Politics and Policy (6th Edition). CQ Press: Washington, D.C. Shaver, K., 2003. Assessment of First-Stage Compliance with California’s Industrial Storm Water Discharge Re gulations: The Role of Self-Identification and the Pollution Prevention Approach in Industrial Permitting. Draft Dissertation, UCLA: Los Angeles, CA. Speidal, David H., Ruedisili, Lon C., Agnew, Allen F., 1988. Perspectives on Water Uses and Abuses. CQ Press: New York. Swierzbinski, Joseph E. 1994. Guilty Until Proven Innocent – Regulation with Costly and Limited Enforcement Journal of Environmental Economics and Management 27. 127-146. TBRPC (Tampa Bay Regional Planning Council), 2004. Tampa Bay Regional Planning Council. Available at: http://www.tbrpc.org Accessed in August 30, 2005. U.S. EPA (U.S. Environmental Protection Agency), 1993. Training Manual for NPDES Permit Writers EPA/B-93-003. Office of Wa stewater Management. U.S. EPA (U.S. Environmental Protection Agency), 1998a. Final Modification of the National Pollutant Discharge Eliminati on System (NPDES) St orm Water MultiSector General Permit for Industrial Ac tivities; Termination of the EPA NPDES Storm Water Baseline Industrial General Permit; Notice. Federal Register, Vol. 63, No. 189, Wednesday, September 30, 1998. U.S. EPA (U.S. Environmental Protection Agency), 1998b. Storm Water Discharges Associated with I ndustrial Activity. 40 CFR 122.26(b)(14) (i)-(xi). Available at: http://www.epa.gov/region02/water/wpb/indsw.htm Accessed in October 15, 2004. U.S. EPA (U.S. Environmental Protection Agency), 1999a. 33/50 Program: The Final Record. EPA-745-R-99-004, U.S. EPA, Office of Pollution Prevention and Toxics: Washington, D.C.

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95 U.S. EPA (U.S. Environmental Protection Agency), 1999b. National Pollutant Discharge Elimination System-Regulations for R evision of the Water Pollution Control Program Addressing Storm Water Discharges; Final Rule. Report to Congress on The Phase II Storm Water Regulations; Notice. Federal Register, Vol. 64, No. 235, Wednesday, December 8, 1999. U.S. EPA (U.S. Environmental Protection Agency), 1996. Overview Of The Storm Water Program EPA 833-R-96-008, U.S. EPA, Office of Water (4203). U.S. EPA (U.S. Environmental Protection Agency), 2000. Final Reissuance of National Pollutant Elim ination System (NPDES) Storm Water Mulit-Sector General Permit for Industrial Activities; Notice Federal Register. U.S. EPA (U.S. Environmental Protection Agency), 2000a. Final Reissuance of National Pollutant Discharge Elimination System (NPDES) Storm Water Multi-Sector General Permit for Industrial Activities; Notice. Federal Register, Vol. 65, No. 210, Monday, October 30, 2000. U.S. EPA (U.S. Environmental Protection Agency), 2000b. Storm Water Phase II Compliance Assistance Guide. EPA 833-R-00-002, U.S. EPA, Office of Water: Washington, D.C. U.S. EPA (U.S. Environmental Protection Agency), 2004. Effectiveness of Effluent Guidelines Program for Reduci ng Pollution Discharges Uncertain Report No. 2004-P-00025. Water Environment Federation, 1997. The Clean Water Act Updated for 1997 25th Anniversary Edition. Zingale, Nicolas C. 2004. Self -Regulation in Environmental Policy: Fact or Chimera A Dissertation Report to the University of Akron.

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96 APPENDICES

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97 Appendix 1: List of Acronyms Al Aluminum BMP Best Management Practices CAFO Concentrated Animals Feed Operations C. F. R. Code of Federal Regulations COD Chemical Oxygen Demand Cu Copper CSWRCB California State Water Resource Control Board CWA Clean Water Act DEP Florida Department of Environmental Protection DMR Discharge Monitoring Report EPA MSGP Environmental Protection Agency Multi Sector General Perm F.A.C. Florida Administrative Code Fe Iron FDEP Florida Department of Environmental Protection ITB Institutional Review Board mg/l Milligrams Per Liter MS4 Municipal Separate Storm Sewer System N Nitrogen NAICS North American Indus try Classification System NR Not required to conduct analytical monitoring NOI Notice of Intent NOT Notice of Termination

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98 Appendix 1: Continued NPDES National Pollutant Elimination System NRDC National Resource Defense Council NURP Nationwide Urban Runoff Program O&G Oil & Grease OMB Office of Management and Budget ppm Parts Per Million R Required to conduct analytical monitoring SIC Standard Identification Code SQG Small Quantity Generator SWPPP Stormwater Pollution Prevention Plan TMDL Total Maximum Daily Load TOC Total Organic Carbon TSS Total Suspended Solids U. S. EPA United States Environmental Protection Agency Zn Zinc

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99 Appendix 2: Telephone Survey Introductory Letter Printed on USF letter head Date Individual Name (if available) Environmental Compliance Manager Facility Name Address City, FL Zip We are contacting you as part of a research project learning about industrial facilities in Hillsborough County. We are a research team at the University of South Florida, conducting independent research on industrial storm runo ff and its regulation in Florida. We would like to talk to you about your facility at (XXX XXX Address XXX ), and we plan to phone you soon to ask that you share some information about that facility. Recently, new state and county regulations were adopted regarding stormwater runoff and its effect on the environment. These regulations and their implementation requirements affect your business. Environmental protection is important to Hillsborough County citizens, contributing to their overall quality of life. However, environmental protection may also be burdensome to industry and businesses, such as yours. Our purpose in conducting this research is to learn more about the possible uses of monitoring data that is required to be conducting under the Florida Multi Sector Generic Permit. The research results will be useful for determining how effectively environmental regulations are written and how they can be improved in ways that benefit both the environment and businesses. This research may also help to decrease the regulatory burden for facilities such as yours throughout Hillsborough County and across the nation. Someone from the USF team should be contacting you by phone in the coming weeks to ask a series of questions about your facility. It is very important that we speak with the person responsible for environmental management and who is familiar with the monitoring requirements of the Florida Multi Sector Generic Permit at this particular facility. If this letter has been addressed to the wrong individual, please direct it to the correct environmental staff person or manager. The phone call should take only a few minutes of your time. Information about your facility was gathered through public record from the Florida Department of Environmental Protection. This research has been approved by the USF Institutional Review Board, with a carefully designed protocol. We look forward to speaking with you soon and we thank you in advance for your assistance. Sincerely, Kelly L. Gleaton L. Donald Duke, Ph.D., P.E. Graduate Student Researcher Associate Professor

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100 Appendix 3: Telephone Survey USF Industrial Stormwater Monito ring Questionnaire: 2006 Code: _________ INDUSTRIAL FACILITIES STORMW ATER RESEARCH: MONITORING REQUIREMENTS PRIOR TO COMPLETING THIS QUESTI ONNAIRE: FILL IN ALL AREAS HIGHLIGHTED IN GRAY, THROUGH PAGE 6, WITH INFORMATION FROM THE NOI FILES. PUT FACILITY CODE ON EVERY PAGE. 1. BUSINESS/COMPANY NAME: ________________________________________________________________________ 2. PERMIT NUMBER: ________________________________________________________________________ 3. DATE ORIGINAL PERMIT INITIALLY ISSUED: _____________________________________________ 4. DATE CURRENT PERMIT ISSU ED: 5. DATE CURRENT PERMIT EXPIRES: ________________________________________________________________________ CONTACT INFORMATION ( NOT president/responsible signer BUT person listed as “contact” ) 6. CONTACT’S NAME: _____________________________________________ 7. CONTACT’S TITLE: _____________________________________________ 8. PHONE NUMBER / EXTENSION : _____________ Calling History Call# Date: Time: Phone# Person Spoken To: Caller's Initials: #1 _______________________________________________________________

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101 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ #2 _________________________________________________________________ #3 _________________________________________________________________#4 __________________________________________________________________ #5 __________________________________________________________________ GREETING: “Hello, may I please speak with ______________________________________? ( IF NO CONTACT NAME, WRONG NAME, OR PERSON NO LONGER WORKS AT FACILITY ) “Then could you please tell me who is re sponsible for environmental compliance? I would like to speak to someone regarding stormwater runoff, and the compliance with stormwater permits.” 9. CONTACT’S NAME: ______________________________________________ “What is their correct title and extension?” 10. CONTACT’S TITLE: ______________________________________________ 11. PHONE NUMBER AND/OR EXTENSION: _________________ “Thank you. Could you please connect me to (him or her)? IF CONTACT PERSON IS NOT AVAILABLE AT THIS TIME: “What is the best day and time to reach (him or her)? Day: Time __________________________________

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102 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ AFTER WE HAVE REACHED THE PERS ON IDENTIFIED ABOVE AS THE CORRECT CONTACT PERSON: “Hello. My name is I am a student researcher at the University of South Flori da, here in Tampa. We’re doing a study on industrial facilities and stormwater runoff in Hillsborough Count y and we would like to talk with you about your facility. 12 .“Are you the person who is in charge of complying with the stormwater permit? ( IF ASKED ) “The Florida statewide Generic Pe rmit for industrial stormwater” 12. Yes 1 No 2 Don’t Know 3 Comments:_____________________________________________________________ 13 ( IF NO TO QUESTION 12 ) “Could you please tell me who that person is?” ( IF YES TO QUESTION 12, PROCEED TO QUESTION 14 ) 13. Person’s name ___________________________________________________ WHEN YOU HAVE THE CORRECT CONTACT PERSON, BEGIN THE INTERVIEW 14. “I am part of an independent, unpai d research group generating information on stormwater regulations for industries in Hillsborough County. Participation in this study is optional and you may w ithdraw at any time. We will not provide any information from these conversatio ns to any government agency, and we will not use your name or the company’s name in any publication or report. We hope to use the information to make recommendations that could make the regulations more useful and less burden some to business. The questionnaire should take no more than 10 or 15 minutes. Would you mind taking a few minutes to answer some questions for me?”

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103 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ PARTICIPANT HAS GIVEN CONSENT TO PARTICIPATE IN QUESTIONNAIRE 14. YES1 NO2 IF CONSENT GIVEN, PROCEED WITH THE INTERVIEW TO QUESTION 15 (NEXT PAGE) IF HAS QUESTIONS SEE BELOW ( IF NO ) “ Is there a better time that I could call back? ENTER DAY:________________________________________ TIME:_______________________ “Thanks. I look forward to speaking with you then.” ( IF REFUSAL ) “Ok, thank you for your time.” ( IF QUESTIONS ABOUT OVERA LL NATURE OF THE RESEARCH ) “ I am part of an independent, unpaid resear ch group generating information on industries in Hillsborough County. We are conducting a 6-month study on industrial stormwater regulations an d how they affect Hillsborough County industrial facilities. As a result of your participation, we hope to make recommendations to the State and the Co unty about the stormwater regulations, how they could be more useful, and ways they could be less burdensome to business.” ( IF QUESTIONS “WHY ME?” ) “We are phoning people from about 100 facilities in Hillsborough County that are complying with the statewide stormwater permit. We acquired your na me from the state’s list of complying facilities, in records of the Florida De partment of Environmental Protection. ( IF QUESTIONS ABOUT USE OF THE RESEARCH ) “We are not checking on compliance, and we are not working for th e state. This is independent research through the University of South Florida. The questions we have relate only to your facility’s choices of how to comply with these regulations, not to any private business informa tion or any personal opinions. To safeguard confidentiality, this research has b een approved by the USF Institutional Review Board. That is an independent body that verifies our procedures to assure protection for research participants.”

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104 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ ( IF QUESTIONS ABOUT WHO IS CALLING ) “ This research is conducted by the Department of Environmental Science an d Policy at University of South Florida, supervised by Professor Don Duke. I can give you contact information if you would like to verify that.” PROVIDE NAME AND NUMBER IF REQUESTED Professor Don Duke, (813) 974-8087, or by e-mail at ldduke@cas.usf.edu 15. ( IF YES TO PARTICIPATION ) “Great. before we get started I’d like to know if you received the letter we sent you, let ting you know we would be calling? (WAIT FOR RESPONSE.) 15. Yes 1 No 2 ( IF NO ) “Would you like to receive another copy for you to keep in your records?” 16. WOULD THE PARTICIPANT LIKE ANOTHER COPY OF LETTER 16. Yes 1 No 2 ( IF YES ) “Would you like me to mail or fax the letter to you? TAKE THE INFORMATION IF REQUESTED. ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ Section I: INTRODUCTION and FACILITY INFORMATION “First, could you please confirm the info rmation we have for this facility?

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105 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 17. “Is the correct name of the comp any that operates this facility: ________________________________________________________________________ 17. Yes 1 No 2 18. ( IF NO ) ENTER CORRECTION: ______________________________________________________________ 19. “Is the correct facility address: 19. Yes 1 No 2 ADDRESS :___________________________________________________ CITY: _____________________________ ZIP: ______________________ 20. ( IF NO ) : ENTER CORRECTION: ADDRESS :___________________________________________________ CITY: _____________________________ ZIP: ______________________ 21. “Is this where the facility is physically located?” 21. Yes 1 No 2 (NOT SIMPLY THE MAILING ADDRESS) 22. ( IF NO ) “Do you know what the physical street address is? 22. Yes 1 No 2 23. ADDRESS :___________________________________________________ CITY: _____________________________ ZIP: ______________________ 24. “Could you tell me the approximate size of the facility within th e following ranges? Is the facility”… (A) Less than acre ______1 (B) Between and 1 acre ______2 (C) Between 1 and 3 acres ______1 (D) Between 3 and 10 acres______4 (E) Larger than 10 acres ______5 25. Comments: ____________________________________________________________________

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106 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ “Our information shows the facility ’s main business activities are: DON’T READ OFF THE SICs!! FIRST, ENTER BUSINESS ACTIVITIES AND THEN FILL IN THE SIC(s) LISTED ON PERMIT: 26. Activity #1 ____________________________________________________________________ Is that correct? Yes 1 No 2 SIC / / / (27) 28. Activity #2 ____________________________________________________________________ Is that correct? Yes 1 No 2 SIC / / / (29) 30. Activity #3 ____________________________________________________________________ Is that correct? Yes 1 No 2 SIC / / / (31) 32. “Do you have any other on-site industrial activities that I have left out?” 32. Yes 1 No 2 Don’t Know 3 ( IF YES ) “Could you please describe them?” 33. Activity #1 ____________________________________________________________________ SIC / / / (34) (for the researcher to fill in later) 35. Activity #2 ____________________________________________________________________ SIC / / / (36) (for the researcher to fill in later)

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107 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ Section II: VISUAL OBSERV ATIONS OF THE FACILITY “First, I’d like to ask about the visual obser vation that may be part of your Stormwater Pollution Prevention Plan. Visual observation is where someone inspects the facility, during dry periods or during times when rain is running off, to look for possible stormwater pollutant problems.” (IF QUESTIONS:) “The purpose is to determine wher e any on-site activities might be contacted by stormwater in a way that could lead to pollutants entering the runoff after it rains.” 37. “Does your facility conduct that kind of visual observation?” 37. Yes 1 No 2 Don’t Know 3 38. ( IF YES TO QUESTION 37 ) “Approximately how often?” Once or twice in a five-year permit period_______1 Once a year______2 Once a quarter_______3 Once a month______4 Periodically, as you feel it’s needed______5 39. (IF YES TO PERIODICALLY:) “About how often would you say?” ____________________________________________________________ ________ 40. “Do you find you make use of that info rmation in any way, for example to make changes to your monitoring plans, or to update your pollution prevention plan?” 40. Yes 1 No 2 Don’t Know 3

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108 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 41. “ Which, if any, of the following kinds of areas at the facility do you or your staff observe? I have a short list”: 42. “Do your facility personnel do this ob servation for stormwater outfalls?” ( IF QUESTION ) “ Outfalls are places where the st ormwater leaves your facility, something like a ditch or channel that le ads to an offsite drainage channel or pond” Yes 1 No 2 Don’t have any channelized outfalls3 Don’t Know 4 43. “Do you conduct the observations for an y retention ponds or detention ponds?” ( IF QUESTION ) : “By that I mean, holding ponds on your facility where rainwater collects, and either later runs off or re mains there until it evaporates or seeps into the ground” Yes 1 No 2 Don’t have any 3 Don’t Know 4 ( IF QUESTION ) “Just so you know how I’m using those terms: A Retention pond is where you keep the water onsite until it (usually) all enters groundwater, but sometimes it overflows after a heavy rain, so it may be sampled only during those overflows. A DEtention pond is where the fl ow is held back somewhat, for example to allow sediments to settle, and then disc harges to storm drains offsite, usually after every rainfall of any substantial amount .” 44. “Does your facility have on-site any retention ponds or detention ponds?” No Don’t Know2 (IF YES) REtention _______3 How many ponds _______4 DEtention _______5 How many: ponds_______6 45. “Getting back to visual observations: Do your facility personnel conduct observations at places of roof drainage that is, downspouts or other drains where water runs off building roofs?” Yes 1 No 2 Don’t have any 3 Don’t Know 4

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109 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 46. “Do you go up on the roof and look at the roof surface, equipment up there, or the like?” Yes 1 No 2 Don’t have any 3 Don’t Know 4 47. “Do your facility personnel do this observation for loading docks, unloading areas, and the like?” Yes 1 No 2 Don’t have any 3 Don’t Know 4 48. “Vehicle parking areas fo r service or delivery?” Yes 1 No 2 Don’t have any 3 Don’t Know 4 49. “Do your facility personnel do this obse rvation for vehicle maintenance areas?” Yes 1 No 2 Don’t have any 3 Don’t Know 4 50. “Does your facility personnel do this observation for outdoor equipment?” Yes 1 No 2 Don’t have any 3 Don’t Know 4 51. “At your facility, would you say that you have extensive outdoor equipment, such as concrete mixing, chemical proce sses, or something similar? Or on the other hand do you have only minor outdoor equipment such as air compressors, air conditioning or air handling, and similar items? Extensive equipment______1 Minor, small items of equipment______2 Don’t know/unable to say______3Other (medium-size or other comment)______ 4

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110 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 52. “Would you say you have extensive ou tdoor materials storagebulk solid materials like sand or concrete, metal sc rap, or liquid storage tanks? Or on the other had do you have only small material s storage, such as a few dumpsters or small scrap piles?” Extensive equipment______1 Minor, small items of equipment______2 Don’t know/unable to say______3 Other (medium-size or other comment)______ 4 53. “Do your facility personnel do this obse rvation around the facility fencelines, for instance locations where wate r might leave the facility?” 53. Yes 1 No 2 Don’t Know 3 54. “Are there any other locations where you conduct observations that I have not mentioned? 54. Yes 1 No 2 Don’t Know 3 ( IF SO ) “Would you please briefl y describe them for me?” 55.__________________________________________________________________ ____________________________________________________________________ 56.__________________________________________________________________ _____________________________________________________________________ 57. __________________________________________________________________ _____________________________________________________________________ 58.__________________________________________________________________ _____________________________________________________________________

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111 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ Section III: VISUAL EXAMINATION MONITORING “Next I would like to ask about the visual examination and an alytical monitoring that is a part of the Permit requirements for stormwater discharges. Visual monitoring means someone in the company goes out and collects samples of runoff for examination. Analytical monitoring is when the samples collected from the discharge locations are sent to a certified laboratory to be analyzed, and the results are submitted to the state in your monitoring reports. Does your facility conduct one or both of these types of monitoring? 59. Visual Examination Monitoring Yes 1 No 2 Don’t Know 60. Analytical Monitoring Yes 1 No 2 Don’t Know 61.Comments:___________________________________________________________ NOTE: ALL FACILITIES ARE SU PPOSED TO CONDUCT VISUAL EXAMINATIONS BUT NOT ALL FACILI TES ARE REQUIRED TO CONDUCT ANALYTICAL MONITORING. IF NO TO VISUAL MONITORING AND YES TO ANALYTICAL THEN GO TO SECTION IV PAGE NUMBER 11 IF THE FACILITY DOES NOT CONDUCT EITHER VISUAL OR ANALYTICAL MONITORING, THEN PROCEED TO SECTION VII – PAGE NUMBER 18 “First I have a few questions regarding vi sual examination monitoring conducted at your facility.” 62. “Do you take part in developing the visual examination protocol?” 62. Yes 1 No 2 Don’t Know 3 “ How would you describe the sampling locations, I have a short list:” 63. “Are samples taken at the outfalls?” 63. Yes 1 No 2 Don’t Know 3

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112 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 64. ( IF YES TO QUESTION 63 ) “How many outfalls” ______ 65. Comments:__________________________________________________________ “Is the outfall from a retention or detention pond?” IF QUESTION: “As opposed to a surface channel on site, or drainage directly from the facility” 66. Yes, from retention/detention pond _____1 No _____ 2 Don’t Know _______3 67. Outfall from REtention _______ How many locations :_______ 68. Outfall from DEtention _______ How many locations:_______ (check if yes) 69. Comments: ___________________________________________________________ 70. “Do your facility personnel sample from one or more on-site areas with industrial activities, outdoor process eq uipment, material storage, or the like?” 70. Yes 1 No 2 Don’t Know 71. ( IF YES TO QUESTION 70 ) “If so, would you please describe the sample locations?” 72._____________________________________________________________________ ________________________________________________________________________ 73._____________________________________________________________________ ________________________________________________________________________ 74._____________________________________________________________________ _______________________________________________________________________ 75. “Are there any other locations I have no t described where you collect samples?” 75 Yes 1 No 2 Don’t Know 3

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113 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 76 ( IF YES TO QUESTION 75) “If so, would you please describe?” (also enter any other Comments): 77._____________________________________________________________________ ________________________________________________________________________ 78._____________________________________________________________________ ________________________________________________________________________ 79._____________________________________________________________________ ________________________________________________________________________ Overall comments regarding sampling locations: 80._____________________________________________________________________ _______________________________________________________________________ 81. “Does the facility take addi tional samples for visual e xamination, that is, more often than the QUARTERLY samples that ar e required during the duration of the permit?” 81. Yes 1 No 2 Don’t Know 3 82. ( If YES TO QUESTION 81 ) “Approximately how often do you take additional samples?” Once or twice in a five-year permit period1______ Once a year2______ Once a quarter3______ Once a month4______ Periodically, as you feel it’s needed or useful 5______ 83.(if yes to “periodically”): “ About how often have you done this ?” 83. _______________________________________________________________ 84. Comments: ___________________________________________________________

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114 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 85. “When samples are taken for visual exam ination, what types of parameters are observed, such as: oily sheen 86. Yes 1 No 2 Don’t Know 3 cloudiness 87. Yes 1 No 2 Don’t Know 3 color 88. Yes 1 No 2 Don’t Know 3 odor 89. Yes 1 No 2 Don’t Know 3 Are there any others? 90. Yes 1 No 2 Don’t Know 3 Others: 91._____________________________________________________________________ 92._____________________________________________________________________ 93 _____________________________________________________________________ 94. Comments: ________________________________________________________________________ Section IV ANAYLTICAL MONITORING “Now I have a few questions regarding anal ytical monitoring, that is, collecting samples of runoff and having them sent out for analysis at a certified laboratory.” ( IF QUESTIONS ) “Analytical monitoring is wh ere someone goes out and takes samples at discharge locations around the fac ility after a rainfall when stormwater is running off, and then sends the samples to a certified l aboratory to be analyzed.” 95. “Is your facility one of the ones in Flor ida that is required to conduct analytical monitoring?” 95. Yes 1 No 2 Don’t Know 3 96. Comments: ________________________________________________________________________

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115 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ IF NO TO QUESTION 29, PROCEED TO SECTION V – PAGE NUMBER 14, QUESTION 135. 97. “Has the facility conducted its 2nd year monitoring requir ement for its current permit cycle?” 97. Yes 1 No 2 Don’t Know 3 98. Comments: IF NO, “Why Not?” _________________________________________________________________ 99. “Did the facility monitor conduct its 2nd year monitoring during its previous permit cycle?” 99. Yes 1 No 2 Don’t Know 3 100. Comments: ________________________________________________________________________ IF NO TO QUESTION 97, PR OCEED TO QUESTION 104 101. “Are you aware that the facility’s required 4th year monitoring can be waived, if the results of the 2nd year monitoring show no constituents exceeded the “benchmark” concentrations shown in the regulations?” 102. Yes 1 No 2 Don’t Know 3 103. “Is the facility waived from the 4th year analytical monitoring for its current permit cycle?” 103. Yes 1 No 2 Don’t Know 3

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116 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 104. “Was the facility waived from the 4th year analytical monitoring for its pervious permit cycle?” 104. Yes 1 No 2 Don’t Know 3 105. Comments: _______________________________________________________________________ 106. “Will you collect samples during the 4th year, even if they are not required?” 106. Yes 1 No 2 Don’t Know 3 107. Comments: ________________________________________________________________________ “ How would you describe the sampling location(s)? I have a short list, and these are the same as I asked earlier for th e visual examination monitoring” 108. “Are samples taken at the outfalls?” 108. Yes 1 No 2 Don’t Know 3 109. ( IF YES TO QUESTION 108 ) “How many outfalls” ______ 110. Comments: _______________________________________________________________________ 111. “Is the outfall from a re tention or detention pond?” IF QUESTION: “As opposed to a surface channel on site, or drainage directly from the facility” 111. Yes, from retention/detention pond __1 No __2 Don’t Know _______3 112. Outfall from REtention _______ How many locations :_______ 113. Outfall from DEtention _______ How many locations:_______ (check if yes)

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117 Appendix 3 (Continued) USF Industrial Stormwater Monito ring Questionnaire: 2006 Code: _________ 114. Comments: _______________________________________________________________________ 115. “Do your facility personnel sample from on e or more on-site ar eas with industrial activities, outdoor process equipmen t, material storage, or the like?” 115. Yes 1 No 2 Don’t Know 3 116. ( IF YES TO QUESTION 105 ) “If so, would you pl ease describe the sampling locations?” 117.____________________________________________________________________ ________________________________________________________________________ 118.____________________________________________________________________ ________________________________________________________________________ 119.____________________________________________________________________ ________________________________________________________________________ 120. “Are there any other locations I have no t described where you collect samples?” 120. Yes 1 No 2 Don’t Know 3 121. ( IF YES TO QUESTION 120) “If so, would you please describe?” (also enter any other Comments): 122.____________________________________________________________________ ________________________________________________________________________ 123.____________________________________________________________________ ________________________________________________________________________ 124.____________________________________________________________________ ________________________________________________________________________ 125. Overall comments regarding sampling locations: ________________________________________________________________________ ________________________________________________________________________

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118 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 126. “Have you collected samples at additiona l times, other than the required 2nd year and 4th year monitoring?” 126. Yes 1 No 2 Don’t Know 3 127. Comments: ________________________________________________________________________ 128. ( IF YES TO QUESTION 126 ) “Approximately how often have you taken additional samples?” Once or twice in a five-year permit period1______ Once a year2______ Regularly, once a quarter3______ Every time the pond overflows 4______ Periodically, as you feel it’s needed or useful 5______ 129. (if yes to “periodically”): “ About how often have you done this ?” 129.______________________________________________________________ 130. Comments: (including, any other description of how often they’ve sampled) ________________________________________________________________________ ________________________________________________________________________ 131. “The stormwater permit requ ires the facility to have th e samples analyzed for just a few parameters. If you know offhand, can you tell me which parameters you analyze for, such as”: total suspended solids 132 Yes 1 No 2 Don’t Know 3 nitrogen (nitrate & nitrite ) 133.Yes 1 No 2 Don’t Know 3 aluminum 134. Yes 1 No 2 Don’t Know 3 iron 135. Yes 1 No 2 Don’t Know 3 zinc 136. Yes 1 No 2 Don’t Know 3 copper 137. Yes 1 No 2 Don’t Know 3

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119 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 138. “Are there any other parameters I di d not mention that you analyze for?” 138. Yes 1 No 2 Don’t Know 3 ( IF YES TO QUESTION 138 ) “What other parameters?” 139. ________________________________ 140. ________________________________ 141. ________________________________ 142. ________________________________ 143. ________________________________ 144. ________________________________ SECTION V. TRAINING NOTE Need to do this section if respondent answ ered “yes” to EITHER the analytical or the visual monitoring. If “no” to BOTH then omit this section. “What kind of training do you provide to the personnel who conduct the field sampling and sample handling? I have a short list –” 145. “Do you train them in how to identify locations at your facility where evidence of potential stormwater pollutants may be found?” 145. Yes 1 No 2 Don’t Know 3 146. “Do you train them how to recognize evidence that pollutants may be exposed to stormwater, such as observing color or oiliness in runoff during wet weather events, or similar?” 146. Yes 1 No 2 Don’t Know 3 147. “Do you train them in some of the overall aspects of stormwater regulations as they apply to your facility?” 147. Yes 1 No 2 Don’t Know 3

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120 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 148. “Do you train them in particulars of the statewide mult i-sector general permit for industrial stormwater discharges?” 148. Yes 1 No 2 Don’t Know 3 149. “Do you train them on environmen tal issues in general related to stormwater, such as potential for en vironmental harm by pollutants?” 149. Yes 1 No 2 Don’t Know 3 150. “Does your facility provide any other types of training to your monitoring personnel that I have not mentioned?” 150. Yes 1 No 2 Don’t Know 3 ( IF YES TO QUESTION 150 ) “Would you please briefly describe it?” 151.____________________________________________________________________ ________________________________________________________________________ 152.____________________________________________________________________ ________________________________________________________________________ 153.____________________________________________________________________ ________________________________________________________________________ 154. ( IF YES TO ANY OF THE ABOVE QUESTIONS ) “How many trained personnel do you have on staff?” (A) 1 ______1 (B) 2 – 3 ______2 (C) More than 3, How Many ______3 155. Comments: _______________________________________________________________________ Section VI: USES OF THE DATA NOTE Need to do this section if respondent answ ered “yes” to EITHER the analytical or the visual monitoring. If “no” to BOTH then omit this section.

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121 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ “We are almost finished. I would like to ask you just a few questions regarding the way you use the information obt ained from monitoring.” “Would you say that you or your staff have ever used anything you’ve found from your monitoring results – either the visual or th e analytical results? For example, have you used the results to:” 156. “Revise the monitoring plan, such as; adding sampling or adding visual observation sites based on previous findings?” 156. Yes 1 No 2 Don’t Know 3 157.“Has the facility ever modified the facility’s Stormwater Pollution Prevention Plan?” ( IF QUESTIONS ) “To include particular equipment or activities that were not previously addressed in the Stormwater Pollution Prevention Plan.” 157. Yes 1 No 2 Don’t Know 3 158.“Has the facility ever identified pr oblems with runoff, potential pollutants and/or located potential on-site source?” 158. Yes 1 No 2 Don’t Know 3 159. “Are there any other purposes the facilit y has used the monitoring results for?” 159. Yes 1 No 2 Don’t Know 3 ( IF YES TO QUESTION 159 ) “Could you please brie fly describe the uses?” 160.____________________________________________________________________ ________________________________________________________________________ 161.____________________________________________________________________ ________________________________________________________________________ 162.____________________________________________________________________ ________________________________________________________________________

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122 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ 163. Comments: ________________________________________________________________________ ________________________________________________________________________ 164. “Do you know if your company has ever revised or updated the Stormwater Pollution Prevention Plan for your facility?” “I mean, in any major way, more than for example changing some staff names or some actions’ dates?” ( IF QUESTIONS ) “Perhaps because your operations have changed or because some of your monitoring results have suggested some new aspects that yo u could address in the Plan.” (A) Yes, one time that I know of during the most recent permit cycle _______1 (B) Occasionally – more than once during the most recent permit cycle _______2 (C) With every new permit coverage ______3 (D) Don’t Know _______4 (E) Other ____________________________________________5 165. Comments: ________________________________________________________________________ 166 “Some facilities find they can modify thei r operations or equipm ent so they do not need to apply for coverage under the stormwat er permit. Do you expect your facility may do this? Or, alternately, do you plan to apply for coverage for this facility again when your current five-year permit expires?” 166. Yes (will reapply) _______1 No (hope not to reapply) _______2 Don’t Know _______3 167. Comments: _______________________________________________________________________ ________________________________________________________________________

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123 Appendix 3 (Continued) USF Industrial Stormwater Monitoring Questionnaire: 2006 Code: _________ SECTION VII. CONCLUSION “That concludes our questionnaire. I appr eciate your time and assistance in participating in this research. Do you have any further questions about this research effort?” ( IF HAS CONCERNS OR QUESTIONS ) “I can give you a name and number of the research director at the Un iversity of South Florida.” PROVIDE NAME AND NUMBER IF REQUESTED Professor Don Duke, (813) 974-8087, or by e-mail at ldduke@cas.usf.edu. Closing: “Thank you very much for yo ur participation in this study and have a great day!” 168. ADDITIONAL COMMENTS: ________________________________ _____________________________ ________________________________ _____________________________ ________________________________ _____________________________ ________________________________ _____________________________ ________________________________ ________________ _____________ ________________________________ _____________________________ ________________________________ _____________________________ ________________________________ _____________________________ ________________________________ _____________________________