Report: TR2008/06 

Author: Eddie Grogan

Abstract

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]