To: Date: Monday, December 21, 1998 11:59 AM Subject: Your request I've attached a copy of the discussion pap..."/>

EXH0632024562

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PCHBPollution Control Hearings Board of the State of Washington

From: "O'Brien, Ed" < aobr461 @ECY.WA.GOV > To: Date: Monday, December 21, 1998 11:59 AM Subject: Your request I've attached a copy of the discussion paper that you requested. noted that the last section of the paper re Groundwater is not completed. don't think it ever was completed because it was addressed under separate guidance developed by the department. Again, the analyses and recommendations in the report are not the official position of the Dept. of Ecology. This was a paper developed by a staff person to elicit further discussion and policy decisions. Feel free to call me if you have questions, < < PTOFCMPL2.doc > > AR 024562 f AN ANALYSIS OF REGULATORY ISSUES RAISED BY APPLICATION OF THE NPDES PERMIT PROGRAM TO MUNICIPAL AND INDUSTRIAL STORMWATER DISCHARAGES December, 1995 by the Washington Department of Ecology in partial fulfillment of Grant No. X-000645-0! AR 024563 j BACKGROUND AND PURPOSE: The application of the NPDES permitting program to municipal and industrial stormwater discharges has raised a number of difficult regulatory questions. Possibly the most difficult of those issues is how to apply the requirement of the Clean Water Act that NPDES permitted discharges must not cause violations of water quality standards in waters which receive those discharges. This paper provides discussions, explores options, and offers recommendations for answers to the more detailed q_estions behind that issue. Those questions include: What are the "Waters of the State" to which the Clean Water Act and State Water Pollution Control Act requirements apply?…

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