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Recap of Ecology’s ISGP Workshops

Ecology recently hosted a pair of workshops regarding the release of the draft 2025 Industrial Stormwater General Permit (ISGP). Each of these workshops began with a brief presentation on the changes proposed in the draft ISGP followed by an extensive Question and Answer Session. There were several important topics discussed during these workshops outlined below:

SWPPP needs to be updated and implemented by March 1, 2025

One emphasis made during the presentations was the need for permittees to have their SWPPP implemented and updated to comply with new permit requirements by Mach 1, 2025. When asked to clarify whether or not the implementation of those changes needed to be complete, Ecology indicated that, because most SWPPP changes were paperwork-based, March 1 was the deadline for implementation as well, but they would appreciate public comment giving examples of implementation that may require extension.

PFAS Sampling

The proposed language for airports and waste management facilities to sample for PFAS, including discharges to the ground was also a widely discussed topic at these workshops. One question asked if Ecology was looking for specific PFAS analytes or if they needed to report on all PFAS analytes. Ecology indicated that all analytes mentioned in EPA method 1633 were specified as the draft permit is currently written, but they would consider comments calling for specific analytes. Another question asked if it acceptable to sample PFAS through groundwater wells. Ecology indicated that the intention was for the discharge to be sampled before it entered the ground, but there may be a possibility to sample through monitoring wells as well, requesting public comment to clarify this language.

Fire Fighters putting out an airplane fire with foam
PFAS is often found in Aqueous Film Forming Foam (AFFF) often associated with fire fighting activities at aviation facilities.

Sampling Point Modifications

Another proposed change to the ISGP is a sampling point modification. This is a mechanism for permittees to change their sampling point when it is unsafe to access their current sample point. One great question came in asking what the timeline was for approval for these sample point modifications, and what permittees should do between the time they apply for modification and the time that Ecology has decided to grant or deny that modification. Ecology indicated that there wasn’t a specified timeline, and they advised facilities to sample from these locations until they have received a final determination on their modification request.

Spill Logging Requirements

A proposed line in the permit requiring “any liquid chemical release onsite regardless of size or flowability is considered a spill and must be logged and addressed” was a major topic of conversation. Several questions asked for clarification essentially asking if every drop or drip needs to be documented. Ecology recommended permittees to use their best judgement but emphasized that the language say’s “regardless of size or flowability”. They are also looking for public comment on a threshold on logging that would capture spills of  substances such as mercury that are very toxic in low concentrations while not causing a paperwork overload on permittees logging minuscule amounts of nontoxic substances.

Man using adsorbent socks to clean up a spill on an industrial site

Vendor/ Contractor Training Requirements

Another topic of discussion was the proposed requirement requiring all vendors and contractors working within the the industrial area of a facility to receive training on a facilities SWPPP. Many expressed concern on the number of vendors and contractors that frequent a site. Ecology indicated that the proposal of this requirement stemmed from a settlement agreement and they were looking for comment on this topic.

6PPD-Q Sampling requirement- small business threshold

The proposed permit requires sampling for 6PPD-Q for transportation facilities, this requirement is exempt for facilities that meet the 50 employee small business threshold. Both workshops had a question asking if the 50 employee threshold was for an entire company, or just for that specific facility. Ecology indicated that it was 50 employees in the entire company.

Worn car tire on the roadway to show impact of tires on 6ppd-Q concentrations
6PPD-Quinone can be discharged into stormwater from tires.

*Please note, the preceding were my personal takeaways from the workshops. Since every site is different and there is a lot of nuance within a permit like the ISGP, it is always advised to reach out to Ecology for interpretations of permit language.