Degree Granting Department
Environmental Science and Policy
L. Donald Duke, Ph.D.
Robert Brinkmann, Ph.D.
J. Edwin Benton, Ph.D.
urban drainage, municipal separate storm sewer system, Florida industry, environmental policy
Stormwater pollutants originating from industrial facilities can lead to degraded
water quality, even in residentially dominated regions of the country. The National
Pollutant Discharge Elimination System permit program regulates stormwater pollutants
generated at industrial sites using Multi-Sector General Permits (Generic permits) for
industrial facilities and a permit requirement for Municipal Separate Storm Sewer System
(MS4) operators. All industrial facilities within 11 broad categories of industry are
responsible for self-identifying the need to comply with the Generic permit, and
subsequently, implementing self-selected pollution prevention strategies. MS4 operators
are required to identify and inspect “high risk” industrial and commercial facilities that
may be contributing substantial pollutant loads to the MS4, in addition to other
requirements. This is partially in recognition that compliance with the Generic permit has
been poor. This dual level of regulations is designed to enhance water quality protection,
however, the reliance on local inspectors to develop a definition of “high risk” has led to
This research developed a methodology to identify industrial facilities and then
screen out facilities that may not require inspection by the MS4 operator. Phone
questionnaires were administered to 250 industrial facilities. Results were validated using
fenceline visits and on-site inspections with local inspectors. Overall compliance by
participating facilities with the Generic permit was approximately 10%.
Neither the Generic permit nor the MS4 permit has been effective because
numerous facilities have gone unregulated. Currently, the Generic permit has attempted
to regulate too many facilities, many of which may not be affecting water quality. MS4
“high risk” inspections have not improved compliance with Generic permit either
because of the prioritization of facilities. The reliance on local interpretation, which
requires MS4 operators to select a definition of “high risk” based on their desired level of
water quality protection and available resources, can potentially exclude many facilities
from inspection. Adopting a definition of intensity for regulating industry may both
improve compliance with the General permit, ensure water quality protection, and
improve resource usage.
Scholar Commons Citation
Griffen, Lindsay M., "Reducing Pollutants in Industrial Stormwater Runoff: Improved Water Quality Protection Using Prioritized Facility Regulation" (2005). Graduate Theses and Dissertations.