## 2008 MSGP Benchmark Discharge Monitoring Report Analysis and SWPPP

Compliance Review

Summary: EPA conducted an analysis of benchmark monitoring data that was available in the eNOI

system and performed a compliance review of a random sample of SWPPPs and DMR data.

Benchmark Monitoring

About half (1,200) of the covered facilities in the MSGP are required to perform benchmark monitoring

in 4 consecutive quarters. The facilities are required to submit monitoring results to EPA either

electronically or through paper format. Many facilities submitted their results through paper format

and t hese results were not accessible via the database. There were 485 facilities that did submit their

monitoring results electronically and EPA’s an alysis focused on these facilities . Note that the revised

MSGP proposes to require facilities to submit their results electronically unless they receive a waiver

from the regional office. There were 42,351 monitoring records from the 485 facilities, but many of

these records were unusable because of various reasons. For instance, there was m issing information

( e.g., parameter name was not provided , monitoring data was not associated with the benchmark

monitoring program , facilities terminated coverage , h ardness data was missing for t he 6 hardness

dependent metals ). In addition many records were not analyzed bec ause the records were not reported

within the standard reporting quarters given in the permit

. Yearly averages were computed only when

there were records from each of the 4 stand ard quarterly reporting periods . This left 183 facilities with

1,334 annual benchmark averages that could be analyzed. Note that a given facility/outfall could have

1

- 3 yearly averages for a given parameter

. The resulting data were sorted then analyzed by permit,

outfall and parameter

.

This analysis shows that compliance with the monitoring requirements is a significant issue and that

mistakes are common. The new eNOI system will provide the appropriate monitoring requirements to

permittees automatically and will also make the data accessible to Regions for better programmatic

ov ersight

. A summary of the monitoring results is provided in Attachment A.

Analysis of SWPPPs

EPA sent a request for information pursuant to Section 308 of the Clean Water Act to 25 industrial

facilities requesting a copy of their current stormwater pol lution prevention plan (SWPPP)

. The letter

specifically asked for information on corrective ac tions and benchmark exceedances

. Twenty SWP PPs

were received and reviewed

. Each SWPPP review looked at general completeness, ESA eligibility

criteria, monit oring results for both benchmark monitoring and effluent limitation monitoring (if

applicable) and corrective act ions/SWPPP modifications taken

. The review did not assess whether the

SWPPP complied with all the detailed requireme nts of Part 5 of the 2008 MSGP . T he review , instead,

focused on monitoring data and the corrective actions the facility took when problems were identified

.

EPA found that m ost facilities (89%) are developing complete SWPPPs, but there is significant

non compliance with monitoring r equirements

. Only 35% of facilities submitted complete monitoring

data and all facilities that submitted benchmark monitoring data had at least one benchmarkexceedance . Of the facilities that completed benchmark monitoring, 84% ide ntified corrective act ions.

None of the facilities reviewed had documented a clear reduction in benchmark exceedances after

implementing corrective actions; most facilities continued to have benchmark exceedances after the

corrective actions

. A summary of the SWPPP and DMR co mpliance results from the 20 facilities

reviewed is provided in Attachment B.

## Attachment A

Benchmark Monitoring Screening / Analysis

- Results Summary

Table 1 . Overall comparison of quarterly benchmark DMR data to benchmark monitoring values

Simplified Pollutant Name Number

of

Permit ee s Number of

Permit ee s

with 1 or

More Yearly

Average

Exceeding

B enchmark Number

of

Outfalls Number of

Outfalls

with 1 or

More Yearly

Average

Exceeding

B enchmark Number of

Annual

Averages

(4 samples) Number of

Annual

Averages

Exceeding

B enchmark

Aluminum 66 39 127 58 178 67

Ammonia 1 0 1 0 1 0

Arsenic 1 0 1 0 1 0

Biochemical Oxygen Demand (BOD5) 3 2 10 3 10 3

Cadmium* 1 0 1 0 1 0

Chemical Oxygen Demand (COD) 40 23 82 29 107 39

Copper* 42 34 81 64 121 93

Cyanide 1 0 1 0 1 0

Iron 114 90 205 152 312 221

Lead* 39 16 62 25 84 29

Magnesium 1 1 1 1 1 1

Mercury 2 0 2 0 2 0

Nitrate + Nitrite 33 13 58 16 71 19

pH 7 5 7 5 11 6

Phosphorus 2 0 2 0 2 0

Selenium 1 0 1 0 1 0

Silver* 1 0 1 0 1 0

Total Suspended Solids 117 43 191 60 260 67

Zinc* 60 43 118 72 169 107

*Parameters that have hardness

- specific benchmark monitoring requirements.

Aluminum . There were 66 facilities (127 outfalls) that reported sufficient data to compute yearly

averages. Of those facilities (outfalls) with yearly averages, 39 (58) had one or more yearly averages

exceeding the benchmark value. Of all the 178 yearly averages, 67 (38%) exceeded their corresponding

benchmark value.

Ammonia . There was 1 facility (1 outfall) that reported sufficient data to compute yearly averages. Its

yearly average did not exceed the benchmark value.

Arsenic . There was 1 facility (1 outfall) that reported sufficient data to compute yearly averages. Its

yearly average did not exceed the benchmark value.

Biochemical Oxygen Demand (BOD5) . There were 3 facilities (10 outfalls) that reported sufficient data

to compute yearly averages. Of those facilities (outfalls) with yearly averages, 2 (3) had one or more

yearly averag es exceeding the benchmark value. Of all the 10 yearly averages, 3 (30%) exceeded their

corresponding benchmark value.

Cadmium . There was 1 facility (1 outfall) that reported sufficient data to compute yearly averages. Its

yearly average did not exceed the benchmark value.Chemical Oxygen Demand (COD) . There were 40 facilities (82 outfalls) that reported sufficient data to

compute yearly averages. Of those facilities (outfalls) with yearly averages, 23 (29) had one or more

yearly averages exceeding the benchmark value. Of all the 107 yearly averages, 39 (36%) exceeded their

corresponding benchmark value.

Copper . There were 42 facilities (81 outfalls) that reported sufficient data to compute yearly averages.

Of those facilities (outfalls) with yearly aver ages, 34 (64) had one or more yearly averages exceeding the

benchmark value. Of all the 121 yearly averages, 93 (77%) exceeded their corresponding benchmark

value.

Cyanide . There was 1 facility (1 outfall) that reported sufficient data to compute yearly av erages. Its

yearly average did not exceed the benchmark value.

Iron . There were 114 facilities (205 outfalls) that reported sufficient data to compute yearly averages. Of

those facilities (outfalls) with yearly averages, 90 (152) had one or more yearly a verages exceeding the

benchmark value. Of all the 312 yearly averages, 221 (71%) exceeded their corresponding benchmark

value.

Lead . There were 39 facilities (62 outfalls) that reported sufficient data to compute yearly averages. Of

those facilities (outfalls) with yearly averages, 16 (25) had one or more yearly averages exceeding the

benchmark value. Of all the 84 yearly averages, 29 (35%) exceeded their corresponding benchmark

value.

Magnesium . There was 1 facility (1 outfall) that reported sufficie nt data to compute yearly averages. Its

yearly average exceeded the benchmark value.

Mercury . There were 2 facilities (2 outfalls) that reported sufficient data to compute yearly averages. Of

those facilities (outfalls) with yearly averages, 0 (0) had on e or more yearly averages exceeding the

benchmark value. Of all the 2 yearly averages, 0 (0%) exceeded their corresponding benchmark value.

Nitrate + Nitrite . There were 33 facilities (58 outfalls) that reported sufficient data to compute yearly

averages. Of those facilities (outfalls) with yearly averages, 13 (16) had one or more yearly averages

exceeding the benchmark value. Of all the 71 yearly averages, 19 (27%) exceeded their corresponding

benchmark value.

pH . There were 7 facilities (7 outfalls) that reported sufficient data to compute yearly averages. Of those

facilities (outfalls) with yearly averages, 5 (5) had one or more yearly averages exceeding the benchmark

value. Of all the 11 yearly averages, 6 (55%) exceeded their corresponding benchmark val ue.

Phosphorus . There were 2 facilities (2 outfalls) that reported sufficient data to compute yearly averages.

Of those facilities (outfalls) with yearly averages, 0 (0) had one or more yearly averages exceeding the

benchmark value. Of all the 2 yearly ave rages, 0 (0%) exceeded their corresponding benchmark value.

Selenium . There was 1 facility (1 outfall) that reported sufficient data to compute yearly averages. Its

yearly average did not exceed the benchmark value.

Silver . There was 1 facility (1 outfal l) that reported sufficient data to compute yearly averages. Its yearly

average did not exceed the benchmark value.

Total Suspended Solids . There were 117 facilities (191 outfalls) that reported sufficient data to compute

yearly averages. Of those facili ties (outfalls) with yearly averages, 43 (60) had one or more yearlyaverages exceeding the benchmark value. Of all the 260 yearly averages, 67 (26%) exceeded their

corresponding benchmark value.

Zinc . There were 60 facilities (118 outfalls) that reported sufficient data to compute yearly averages. Of

those facilities (outfalls) with yearly averages, 43 (72) had one or more yearly averages exceeding the

benchmark value. Of all the 169 yearly averages, 107 (63%) exceeded their corresponding benchmark

value.

Table 2 . Sector

- specific comparison of quarterly benchmark monitoring data to benchmark monitoring

values.

Sector Simplified Pollutant Name Number of

Permitees Number of

Permitees

with 1 or

More

Yearly

Average

Exceeding

Benchmark Nu mber

of

Outfalls Number of

Outfalls

with 1 or

More Yearly

Average

Exceeding

Benchmark Number

of

Annual

Averages

(4

samples) Number of

Annual

Averages

Exceeding

Benchmark

A Chemical Oxygen Demand (COD) 8 4 21 6 24 8

A Copper 1 1 1 1 2 2

A Total Suspended Solids 8 3 20 4 25 4

A Zinc 4 2 11 2 12 2

B Chemical Oxygen Demand (COD) 3 0 7 0 11 0

C Aluminum 4 3 15 4 26 5

C Iron 5 5 16 8 27 13

C Lead 1 0 1 0 1 0

C Nitrate + Nitrite 5 3 16 3 18 3

C Phosphorus 2 0 2 0 2 0

C Zinc 2 2 2 2 2 2

D Total Suspended Solids 14 3 18 4 28 4

E Iron 15 9 17 11 21 15

E Total Suspended Solids 18 4 20 4 26 5

F Aluminum 7 3 17 4 24 5

F Copper 8 5 19 12 38 27

F Iron 4 3 10 5 16 8

F Total Suspended Solids 4 9 0 12 0

F Zinc 11 8 27 17 50 36

J Nitrate + Nitrite 9 2 13 2 16 4

J Total Suspended Solids 25 4 32 4 48 4

K Ammonia 1 0 1 0 1 0

K Arsenic 1 0 1 0 1 0

K Cadmium 1 0 1 0 1 0

K Chemical Oxygen Demand (COD) 1 0 1 0 1 0

K Cyanide 1 0 1 0 1 0

K Lead 1 0 1 0 1 0

K Magnesium 1 1 1 1 1 1

K Mercury 1 0 1 0 1 0

K Selenium 1 0 1 0 1 0

K Silver 1 0 1 0 1 0

L Iron 5 5 17 16 22 20

L Total Suspended Solids 11 6 28 13 40 15

M Aluminum 10 3 15 4 24 6

M Iron 10 5 15 8 25 13

M Lead 10 2 15 4 23 5

M Total Suspended Solids 10 1 15 2 23 2

N Aluminum 23 18 41 27 57 30Sector Simplified Pollutant Name Number of

Permitees Number of

Permitees

with 1 or

More

Yearly

Average

Exceeding

Benchmark Nu mber

of

Outfalls Number of

Outfalls

with 1 or

More Yearly

Average

Exceeding

Benchmark Number

of

Annual

Averages

(4

samples) Number of

Annual

Averages

Exceeding

Benchmark

N Chemical Oxygen Demand (COD) 23 16 41 19 56 24

N Copper 19 16 36 30 51 38

N Iron 23 22 41 38 58 51

N Lead 19 14 36 22 50 25

N Total Suspended Solids 23 14 41 19 54 20

N Zinc 19 17 36 28 52 35

O Iron 16 13 35 28 63 42

Q Aluminum 3 2 3 2 5 2

Q Iron 4 2 4 2 6 2

Q Lead 1 1 0 3 0

Q Zinc 2 2 2 2 4 4

U Biochemical Oxygen Demand

(BOD5) 1 0 5 0 5 0

U Chemical Oxygen Demand (COD) 1 0 5 0 5 0

U Nitrate + Nitrite 1 1 5 1 5 1

U Total Suspended Solids 1 1 5 1 5 1

Y Zinc 1 0 1 0 1 0

AA Aluminum 8 5 17 7 22 8

AA Iron 9 7 19 12 26 17

AA Nitrate + Nitrite 9 4 13 5 19 5

AA Zinc 9 7 18 13 27 20

### Attachment B

Compliance Review of a Random Sample of SWPPPs and DMR Data

–

Results Summary

Activity Result Notes

Used the EPA SWPPP template 7 of 20 facilities (35%)

Submitted a complete and detailed

SWPPP 17 of 19 facilities (89%)

submitted a complete and

detailed SWPPP All facilities that used the EPA

SWPPP template had a

complete and detailed SWPPP;

1 facility did not submit SWPPP

Submitted complete monitoring

data 7 of 20 facilities (35%)

submitted complete

monitoring data 4 facilities did not submit data,

while others did not submit

data for all pollutants

Exceeded benchmark requirements 16 of 16 facilities (100%)

exceeded at least 1 bench mark

value 4 facilities did not submit

monitoring data, or did not

provide data in a usable

format.

Exceeded effluent limits 1 of 3 facilities (33%) 2 facilities did not exceeded

ELG requirements, while 4

facilities did not provide ELG

data

Identified co rrective actions 16 of 19 facilities (84%) 1 facility did not submit any

annual reports

Submitted annual reports 19 of 20 facilities (95%)