Industrial storm water pollution prevention: Effectiveness and limitations of source controls in the transportation industry

Industrial activities that are sources of pollutants in storm water runoff at typical facilities of the transportation industry are identified by site investigations at five facilities. This research then evaluates pollution prevention measures implemented to reduce those pollutants, as required by storm water regulations under the U.S. Clean Water Act. Activities that potentially generate storm water pollutants, particular to facilities of this industry, include: vehicle maintenance; vehicle fueling; vehicle washing; and activities on paved access roads and vehicle storage areas. Activities common to this industry, but also found in other industries, include: storage and handling of process materials and wastes; operation of industrial equipment located outdoors or exposed to storm water; and design and operation of site drainage facilities. Most control measures cited in the compliance documents of the facilities in the case studies were not developed specifically for storm water pollution prevention, but serve to reduce storm water pollutants as part of compliance with regulations for hazardous waste, wastewater, worker safety, or other purposes. Most identified control measures were operational practices or employee procedures, rather than structural facility modifications or devices to remove pollutants. Implementation of such measures is difficult to enforce or verify by regulatory agencies, and evidence at the case study facilities suggests that measures described similarly at different facilities are unevenly implemented and unequally effective at controlling storm water pollutants.