Industrial Stormwater 101
In Washington, the Department of Ecology (Ecology) requires many businesses and municipalities to obtain permits for the treatment and control of polluted stormwater. Ecology issues stormwater permits to businesses and municipalities for a variety of reasons, including their size, their location, the pollutants they deal with, etc.
The permits in Washington implement the Clean Water Act (CWA) and are intended to limit—but not eliminate—the amount of polluted stormwater entering Puget Sound. Right now, Ecology is in the process of updating its Industrial Stormwater General Permit (ISGP), which regulates industrial facilities.
Changing the ISGP
During the September 21st listening session Ecology mentioned a few potential changes for the upcoming permit. These changes are not set in stone and are subject to change before Ecology releases its draft permit.
Some of the proposed changes would affect facilities’ Storm Water Pollution Prevention Plan (SWPPP). A SWPPP is a site-specific, written document signed by a company executive that identifies all the activities and conditions at their site that could cause water pollution, and details the steps the facility will take to prevent the discharge of any unpermitted pollution. These pollution prevention steps are referred to as Best Management Practices (BMPs). SWPPPs are required for all facilities seeking a permit.
Proposed changes included:
✓ Parameters around sampling facility stormwater could also change. Each facility is required to sample water from different points on its site. These samples provide information about whether the BMPs prevent contaminants from entering the stormwater system and connected waterways. In theory, sampling indicates if a facility needs to update its BMPs to address pollution issues.
✓ One proposed change to sampling included the creation of a waiver for sample points that are unable to be sampled due to issues like safety or inaccessibility.
Potential issues:
⌧ If Ecology moves forward with the waiver, it must only be used for truly inaccessible points
⌧ Ecology cannot allow facilities to take advantage of this waiver in order to avoid collecting samples
What changes would Soundkeeper like to see?
Soundkeeper advocates for changes that include more effective BMPs, especially regarding 6PPD, a substance commonly used in tires that reacts with ozone and/or sunlight to form 6PPD-quinone. 6PPD-quinone is acutely toxic to coho salmon and other fish species and has sub-lethal impact on other organisms. We also hope to see more opportunities for public participation and transparency, and stricter limitations on allowable discharges.
Soundkeeper pursues Clean Water Act litigation against industrial polluters when facilities fail to provide a SWPPP, consistently exceed their allowed level of discharge, or are simply operating without a permit. A strong and clear ISGP, in addition to consistent enforcement by Ecology, would minimize the need for Soundkeeper to take legal action and signal to industrial polluters that they must do their part for a clean and healthy Sound.
What you can do:
- CWA, SWPP, ISGP, oh my! Join our three-part advocacy series starting this month and get up to speed on the complex stormwater landscape.
- Sign up for Soundkeeper’s newsletter so you never miss a cleanup or an update on stormwater strategy.
- Visit the ISGP permit webpage here for updates directly from Ecology.
- Read Part I of this series.