The early listening sessions have provided a great space for the public to hear the proposed changes to the ISGP, ask questions about the implications of those changes, make suggestions, and voice concerns to Ecology.
Recap of Proposed Changes
It is important to remember that these sessions are only intended to give a general idea of what Ecology is thinking and that these changes are in the early draft stages. The specifics of these changes, as well as the impacts that they will have on ISGP permit holders, will become much clearer the further into this process we get.
1. Changes for transportation facilities:
The first, and perhaps most significant proposed change is a change to the permit requirements for facilities within the transportation sector. Under the current permit, transportation facilities need coverage if they are conducting maintenance activity, equipment cleaning, or airport deicing. Ecology is proposing a change that would require permit coverage to all facilities classified as transportation, facility-wide.
Who does this impact?
This has the potential to impact all facilities within the transportation sector across the state including ports, trucking companies, small airports, and postal facilities.
What impact will this have?
This will potentially increase the footprint of stormwater-managed areas for current permittees. For some, it will increase the areas for which they will need to monitor and implement BMP, and increase the number of sampling sites in the new footprint. This also may require a large number of facilities that currently do not require permit coverage to obtain permit coverage under the ISGP.
2. Changes to Conditional No Exposure:
Ecology is planning to change language around the conditional no exposure (CNE). Currently, facilities that apply for CNE are automatically approved if they haven’t heard from Ecology in 90 days. Ecology is proposing to remove that 90-day automatic approval and change it so that a CNE is only approved if Ecology acts to approve it.
Who does this impact?
This has the potential to impact all facilities that are seeking a Conditional No Exposure.
What impact will this have?
This shouldn’t have much of an impact on most facilities but could result in delays in CNE determination if Ecology has a backlog of CNE requests.
3. Changes to staff training:
Ecology is considering changes to staff training requirements that will increase the amount and scope of stormwater/ SWPPP training a facility’s staff needs to receive.
Who does this impact?
While the exact requirements have yet to be determined, this has the potential to impact all facilities.
What impact will this have?
It is yet unclear what the exact requirements will be, but it will potentially lead to more time dedicated to educating staff on the impacts of stormwater and the facilities SWPPP. Increased education will hopefully lead to cleaner sites and a better understanding of the BMPs.
4. Changes to BMP requirements:
Ecology is considering changing BMP requirements to include more frequent sweeping for certain facilities as well as more source control BMPs.
Who does this impact?
Ecology didn’t give specifics as to which industries will be required to perform these additional BMP activities.
What impact will this have?
While Ecology didn’t give specifics as to who or how often facilities will now have to sweep, or what covering BMPs they are anticipating, facilities may expect increased cost and time dedicated to BMP implementation, maintenance, and monitoring but could benefit from a reduction of pollutant potential in certain facilities.
5. Potential to include a sampling point waiver:
Ecology is considering creating a waiver form that facilities will need to complete if they determine that a sample point is unable to be sampled due to issues such as safety or inaccessibility.
Who does this impact?
This impacts any facility that may have a sampling location that is inaccessible or unable to be sampled safely.
What impact will this have?
While it is unclear exactly what this waiver or form will look like, it potentially requires facilities that have unsafe or inaccessible sampling locations to provide additional reasoning, justification, or proof as to why that location is unable to be sampled.
6. Changes to copper effluent limit in 303(d) listed marine waters:
Ecology currently states that the copper effluent limit for listed marine waters will be “assigned at the time of permit coverage”. They are proposing to change this to a numeric effluent limit of 5.8 ug/L.
Who does this impact?
This impacts any facility that discharges to a marine water body with a 303(d) listed copper impairment.
What impact will this have?
Facilities discharging into these waterbodies will be required to keep their stormwater discharge under 5.8 ug/L for Total Copper. This likely means treatment of stormwater discharge if copper is a pollutant in their runoff.
7. Changes to better define Puget Sound Sediment Cleanup Sites:
Ecology is considering ways to better define and show areas that discharge to Puget Sound Sediment Cleanup sites.
Who does this impact?
This will impact all facilities that discharge to a Puget Sound Sediment Cleanup site.
What impact will this have?
While it is unclear what the specifics of this proposal will be, ecology seems to intend it to provide more clarity and quicker determination for facilities that discharge to a Puget Sound Sediment Cleanup Site.
8. Changes to the corrective action timelines:
Ecology is considering changing the timeline for facilities in the corrective action process. Proposed changes include an automatic 1-year extension to permittees installing engineered treatment systems, as well as changing the due dates of waiver and extension requests from May 15th to the final due date.
Who does this impact?
This may impact any facility involved in the corrective action process, especially those in need of engineered treatment systems or otherwise convoluted BMPs.
What impact will this have?
This should relieve some of the time pressures put on facilities that are undergoing the corrective action process by giving them more time to determine the BMPs that will work best for them.
Have questions about these proposals? Don’t miss the next listening session- sign up here.
Want to learn more about the permit re-issuance process? Read about it here.
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