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Summary
Pages 1-8

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From page 1...
... In this report, the committee recommends requirements have come under scrutiny since the pro- updating MSGP benchmark monitoring requirements gram's inception. The 2009 National Research Council and thresholds using a periodic review process to incorreport Urban Stormwater Management in the United porate the latest science and monitoring information States stated that the industrial stormwater program has into each permit revision.
From page 2...
... By "highest priority" EPA means those facilities/subsectors for which the development of numeric effluent limitations or reasonably standardized stormwater control measures would be most scientifically defensible (based on sampling data quality, data gaps and the likelihood of filling them, and other data quantity/quality issues that may affect the calculation of numeric limitations)
From page 3...
... In this context, EPA should monitoring is needed for sectors that have the potential to release PAHs. Periodic monitoring reviews would • Develop acute aquatic life criteria for benchmarks allow EPA to assess changing industry practices that where they do not currently exist, or where substancould affect monitoring needs, new analytical tech- tial chronic risks to aquatic ecosystems exist from nology for pollutant quantification, as well as current repeated stormwater exposures, develop equations
From page 4...
... For benchmarks based on aquatic life criteria, the addi tional high-quality data collected can be used to assess Additional monitoring data collection on the the feasibility of achieving the benchmarks with current capacity of SCMs to reduce industrial storm­ ater w technology and practices. For technology-based benchpollutants is recommended to inform periodic marks, additional data could inform future benchmark reviews of the benchmark thresholds and identify revisions to reflect the state of practice, reducing total sectors for which new national effluent limits could loads to the extent practicable.
From page 5...
... EPA should allow and promote the use of com- State adoption of national laboratory accreditaposite sampling for benchmark monitoring for all tion programs for the Clean Water Act with a focus pollutants except those affected by storage time. on the stormwater matrix and inter­aboratory cali l EPA's disallowance of composite sampling and reliance bration efforts would improve data quality and reduce on grab sampling in the interest of discrete characteriza- error.
From page 6...
... Sectors that merit additional pollutant monitoring, based on the Stormwater retention for infiltration or beneficial most recent data and industry literature review, use minimizes pollutant loads to receiving waters and would conduct sector-specific benchmark moni- reduces damaging peak flows while potentially increas toring in addition to pH, TSS, and COD which ing water availability. Yet, infiltration of industrial would be collected by all facilities with chemical stormwater, which can contain hazardous pollutants in monitoring.
From page 7...
... Because of the potential effluent limits render national retention standards for risks to groundwater, industrial stormwater infiltration industrial stormwater infeasible within the existing is not recommended in states that lack the legal authorregulatory framework of the MSGP. Retention with ity to manage and enforce groundwater quality.
From page 8...
... 8 IMPROVING THE EPA MULTI-SECTOR GENERAL PERMIT the nation's waters would be best served by a progressive and continuously improving MSGP based on analysis of new data and focused data-gathering efforts, advances in industrial stormwater science and technology, and structured learning to develop and evaluate permit improvements.


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