EXH AR024562: Analysis of Regulatory Issues — NPDES Permit Program Municipal & Industrial Stormwater Discharges

A 1995 Washington Department of Ecology staff discussion paper analyzes regulatory challenges in applying the NPDES permit program to municipal and industrial stormwater discharges, focusing on how to ensure such discharges comply with Clean Water Act water quality standards. The paper explores questions around defining 'Waters of the State,' determining compliance monitoring points, and identifying which permitted dischargers require water-quality-based effluent limitations. Note that this paper does not represent official Ecology policy and was intended to stimulate internal discussion and policy decisions.

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.

V V