EXH0222018847

PCHBPollution Control Hearings Board of the State of Washington

_ent: Friday, May 14, 1999 5:14 PMLuster, Tom; He,wig, Raymond; Ehlers, Paula; Stockdale, Erik; Bolender. Wendy ._::: Aust,n, Lisa; Glynn. John; Moore. Bill Subject: RE: Updated 401 Permit Matrix Tom: You are correct {Item _ 13) that there should be no question about the retrofittingof exisfmg storm water outfalli that are partof industrial activity basins. What nee(Is to be developed inthe NPDES permit is a compliance $cheduie on how and when this retrofittingwill occur. am becoming as frustrated as you, Tom, in the way we are continuing to talk past each other over how storm water dischargesachieve compliance with WQ Standards (Items #11 & 12). Again, the WQ approach to achieve compliance is by a step-wiseand deliberative approach {'adaptive management" for lick of a better term) of applying current technology BMPs, monitoring the effectiveness of those BMPs and then determining additional measures (i.e. additional source control,development of innovative BMPs) should monitoring indicate that storm water discharges are adversely impacting beneficialuses of the receiving water. I knowthat you want to employ the 401 Certification to require instantaneous and strict categorical compliance with the numericWQ standards for storm water discharges. I don't see how that is possible. can't make that happen with the NPDES Permit. That being the case, and if that is how you indeed want to condition the 401 Certification, I see no alternative but to deny a 401 certification for any projectwith existing storm water discharges. OriginalMesse;: From: Luster, Tom Sent: Friday, May 14, 1999 3:27 PM To: Hellwig,…
V V