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Industrial Stormwater Pollution Prevention Programme (ISP3) Implementation Plan

TR 2008/06

Report: TR2008/06 

Author: Eddie Grogan


This document is intended to provide the framework and strategy for a proactive Industrial Stormwater Pollution Prevention Programme (the ISP3) for the Waikato region.

High levels of contaminants in industrial stormwater runoff, such as heavy metals (zinc, copper and lead) and synthetic organics (oil and other petrochemical derivatives) are well documented in both New Zealand and overseas literature.  Environment Waikato (EW) have long been concerned about the potential mixture of chemicals that can be present in poorly managed industrial site stormwater runoff and the potential effects that they can cause on aquatic receiving waterways. 

EW like a number of regional councils wish to move from being the “ambulance at the bottom of the cliff” reacting to problems to providing the “safety net at the top of the cliff” preventing problems from even starting.  To this end the development of a collaborative ISP3 in partnership with the region’s territorial authorities (TAs) is clearly signalled in the Environment Waikato LTCCP 2006-16.  Statutory backing for a programme of this type is also contained in the provisions of the Waikato Regional Policy Statement and the Proposed Waikato Regional Plan.

EW and some of its constituent TAs have opposing views regarding the statutory responsibility for discharges to land from industrial activities that result in contaminants entering public stormwater networks.  While the pros and cons of each view are considered, the ISP3 strategy does not attempt to provide a definitive solution. ISP3 provides a menu of options for EW, either alone or in partnership with a willing and capable TA, to ensure that industrial site stormwater is being managed appropriately. Regardless of who implements the programme, the intention is that industrial site operators are held accountable for keeping their site stormwater clean.  The most efficient and effective approach is to deal with the site operator directly as they are best placed to employ appropriate site management practices to protect stormwater quality.

Ideally a cooperative approach that avoids duplication will be adopted, which ensures that the organisation best paced to formulate and implement the necessary controls takes the lead role. In any event a successful approach will involve both partners in local government, robust and complementary rules at regional and district level and will include a variety of collaborative initiatives 

In order to provide a holistic approach to pollution prevention a menu of programme components has been recommended as follows: 

  • proactive sector-based site auditing for high-risk industrial sites
  • industrial area blitzes for industry clusters and outlying townships
  • industry group projects for industrial and domestic activities that cause a significant number of problems.

Each of these approaches has the primary objective of protecting and improving land and water quality from industrial activities through proactive site audits by:

  • identifying and stopping any actual pollutant discharges to land or water
  • identifying and putting site management controls in place to avoid potential discharges
  • ensuring industrial site operators are prepared to deal with accidental discharges through the preparation of emergency spill response plans and staff training.

To be successful any proactive auditing team must be:

  • formed with a clear management framework
  • adequately resourced to achieve the programme objectives in a realistic timeframe
  • focused on proactive industrial site auditing only
  • supported by policy that is clear, robust and enforceable
  • constituted with experienced and appropriately trained personnel
  • supported by clear, concise, practical and pragmatic operational guidelines
  • appropriately equipped for auditing (hardware, H&S and IT).

Other regional councils (GWRC, ECan, ARC and others) have invested a significant amount of effort in developing resources that can be taken into the Waikato ISP3.  The tools and equipment that have been proven effective through trial and error by other regional councils have been ranked for use in the Waikato ISP3 and are discussed in detail.  A ranking process is recommended to establish a prioritised order in which the industrial sectors, industrial areas and/or industrial activities should be proactively approached first.  A process for dealing with each industry once it has been prioritised is outlined in detail. 

The number of staff resources required will be dictated by the options chosen for inclusion in the programme but as a minimum, four staff including a team leader are recommended.  With these resources all high-risk sites can be audited and brought up to a high standard within a five year timeframe.

The pros and cons of a number of different funding options are considered and the approach of using a targeted regional rate on industrial property combined with limited cost recovery is recommended.  Based on previous EW experience and proactive pollution programmes elsewhere this combination is considered the most likely to be acceptable to both industry and the community generally. Generally speaking ratepayers want to see the ‘polluter pays’ principle employed, as they are intolerant of polluters not being required to fund the full cost of their poor environmental practices being remedied.

Industrial Stormwater Pollution Prevention Programme (ISP3) Implementation Plan [PDF, 1.2 MB]

  Acknowledgement   i
  Executive summary vii
1 Introduction – ISP3 purpose and scope   1 
2 Background to pollution prevention   8 
2.1 Philosophy behind urban pollution prevention programmes   9
2.1.1 Sustainable management – It is just good business practice   9
2.1.2 Industrial site stormwater quality  14
2.1.3 Discharges to stormwater infrastructure - statutory management  15
2.1.4 Non-regulatory approaches  16
2.1.5 Community expectations  18
2.1.6 Impacts on other programmes  19
2.2 ISP3 Programme design  21
2.2.1 Create an agreed framework  22
2.2.2 Secure funding arrangements  23
2.2.3 Assuring programme capability  26
2.2.4 Build community and industry buy-in  30
2.2.5 Deploy best practicable option solutions  31
3 Pollution prevention programmes around NZ  32 
3.1 Auckland Regional Council  32
3.1.1 Proactive industrial pollution prevention programme (IP3)  33
3.1.2 Industry group projects (IGP)  35
3.1.3 Hot spot monitoring  36
3.1.4 Target catchment surveys  37
3.1.5 Industrial area blitz  38
3.1.6 HSNO compliance assessment trial  38
3.1.7 Tools  40
3.1.8 Wider community education and action programmes  40
3.2 Environment Canterbury  41
3.2.1 Pollution prevention guide  41
3.2.2 Pollution prevention posters  42
3.2.3 Action sheets  42
3.2.4 Small Spills training course  43
3.2.5 Proactive trials with ECan tenants  43
3.2.6 Staffing  43
3.3 Greater Wellington Regional Council – Take charge programme  43
3.3.1 On-line checklist  44
3.3.2 Industrial sector based audits  44
3.3.3 Industrial area based audits  44
3.3.4 Delegation of enforcement powers  44
3.3.5 Community monitoring  46
4 Programme component options analysis - pros and cons  46 
4.1 Overall staff time requirements  46
4.2 Pros and cons assessments  47
4.2.1 Target catchments  47
4.2.2 Industrial area blitz (Used by both GWRC and ARC)  48
4.2.3 Sector based IP3 (used by Ecan, GWRC and ARC)  48
4.2.4 Sector based industry group project (IGP) (used by ECan, GWRC and ARC)  49
4.2.5 Hot-spot surveys (ARC)  50
5 Prioritisation within each programme component  53 
5.1 IP3 Target industry sectors  53
5.2 Industry group projects  54
5.3 Hot-spot survey locations  54
5.4 Industrial area blitzes  55
6 Tools  55
6.1 Auditors  55
6.1.1 Standardised site audit forms  55
6.1.2 Environmental performance rating (EPR)  56
6.1.3 Database  57
6.1.4 Drainage maps  58
6.1.5 Vehicles and sampling equipment  58
6.1.6 Pollution response and H&S manual  58
6.2 Industry specifically  58
6.2.1 A pollution prevention guide (PPG)  58
6.2.2 Pollution fact sheets  59
6.2.3 Industry best practice guides and/or codes of practice  59
6.2.4 Environmental management plan guide - EMP Guide  60
6.2.5 Industry workshops and industry champions  60
6.3 Conclusion  61
7 Resource implications of ISP3  61
7.1 Proactive team resource requirements  61
7.1.1 Industrial sector based approach  61
7.1.2 Industrial area blitz  62
7.1.3 Industry group projects (IGP)  62
7.1.4 Industry specific educational resources (Tools)  63
7.1.5 New high risk industrial activities  63
7.1.6 Industrial activities requiring pollution response action  64
7.1.7 Industrial activities applying for other discharge consents  64
7.1.8 ISP3 Team resource requirements  65
7.2 Impacts on other teams  65
7.2.1 Consents and compliance group  65
7.3 Impacts on industrial site operators  66
8 ISP3 Strategy recommendations  67 
8.1 Statutory review  67
8.2 Relationship with TA’s  67
8.3 The ISP3 team  68
8.4 Proactive ISP3 initiatives  68
8.5 Programme component prioritisation (for limited resources)  69
8.6 Community education  70
8.7 ISP3 programme funding  70
  Appendix 1: Industrial activity risk rankings  71
  Appendix 2: Stormwater management roles and responsibilities  77
  Appendix 3: Waikato regional planning provisions  89
  Appendix 4: Hamilton City Proposed District Plan (HCPDP) [abridged] 100
  Appendix 5: Pollution prevention auditing data 103
  Appendix 6: Small site audit form 106
  Appendix 7: ISP3 visual/smells checklist 109
  Appendix 8: Greater Wellington Regional Council’s take charge quick checklist 112
  Appendix 9: Greater Wellington Regional Council statutory options analysis 113
  Appendix 10: Most common causes of industrial site stormwater contamination 115