Notes
Exhibit AR024562. Email from Ed O’Brien (ECY.WA.GOV) transmitting discussion paper ‘An Analysis of Regulatory Issues Raised by Application of the NPDES Permit Program to Municipal and Industrial Stormwater Discharges’ (December 1995, Grant No. X-000645-01), Washington Department of Ecology. Paper addresses Waters of the State, point of compliance for stormwater discharges, water quality standards violations, monitoring requirements, and water-quality based effluent limitations under the Clean Water Act and State Water Pollution Control Act. O’Brien notes the Groundwater section was never completed and that the paper represents a staff discussion draft, not official Ecology policy. Filed in PCHB Third Runway EIS administrative record.
