Industrial Stormwater Draft General Permit - Formal Comment Period

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Comment From: Anon Anonymous

7/15/24 @ 11:07 PM

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Comment From: Washington Maritime Federation (Chad See)

7/15/24 @ 8:38 PM

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Comment From: Shane Latimer

7/15/24 @ 8:31 PM

See comments in attached document. Thank you.

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Comment From: Association of Washington Busi... (Peter Godlewski)

7/15/24 @ 8:12 PM

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Comment From: Port of Grays Harbor (Kris Koski)

7/15/24 @ 6:40 PM

The Port of Grays Harbor (Port) is providing the following comments during the formal comment period for the 2025 Industrial Stormwater General Permit (ISGP) reissuance. The Port was able to participate during the Department of Ecology's listening se...↓

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Comment From: Port of Skagit County (Laura Schumacher)

7/15/24 @ 6:23 PM

Please see attached letter from Sara Young, Executive Director, Port of Skagit County. Thank you.

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Comment From: Seattle Public Utilities (Rose Propst)

7/15/24 @ 5:55 PM

Thank you for the opportunity to provide comments on the draft Industrial Stormwater General Permit. On behalf of Seattle Public Utilities, please see the comments in the attached document "FINAL_SPU comments for 2025 ISGP revision".
Thank you.

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Comment From: Washington Public Ports Associ... (Carly Michiels)

7/15/24 @ 5:54 PM

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Comment From: The Washington Aggregates & Co...

7/15/24 @ 5:52 PM

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Comment From: Pierce County (Maureen Meehan)

7/15/24 @ 5:09 PM

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Comment From: Pacific Merchant Shipping Asso... (Jordan Royer)

7/15/24 @ 5:02 PM

Comment letter uploaded

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Comment From: King County (Bob Bernhard)

7/15/24 @ 4:55 PM

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Comment From: Parberry Environment Solutions (Lisa Parberry)

7/15/24 @ 4:51 PM

TO:
Lucienne Banning
WA State Department of Ecology, via upload PO Box 47696
Olympia, WA 98504-7696

FROM:
Brian, Lisa and Erin Parberry
Parberry Environment Solutions
PO Box 669 Ferndale, WA 98248

We appreciate the extended opportunity to comment...↓ on the Draft Industrial Stormwater General Permit as many of the proposed changes directly impact our industry.

Spill Log (S3.B.4.i.)
"any liquid chemical release onsite regardless of size or flowability is considered a spill and must be logged and addressed."
Not only is this proposal impractical, but for some industries this is virtually impossible. The amount of time, manpower and effort required for this would be enormous not only for our business but for many others. Any size spot, drip, or stain noted on the ground would constitute a spill that would need to be examined, logged and remedied. We have a large number of customers, city and commercial recycling trucks, delivery drivers and contracted semis. How can we be responsible for someone else's vehicle that not only leaked all over our property but over the city, state, county and federal roads used to get to our facility. Will the state be required to monitor these roadways for spill and drips into the storm water as well? With this definition we would need a dedicated staff just to log and address "spills". It is unreasonable to suggest that any tiny stain on the pavement requires "addressing" by the Permittee. Furthermore, staining can be permanent, so will we need to reseal or redo all of our concrete/pavement to assure that we won't be flagged for being out of compliance for a stain on our concrete?
There were already requirements for spill response and logging in the previous permit. I believe these were sufficient enough, I propose all the new wording be removed from this section of the permit.
Stormwater Pollution Prevention Plan Revisions (S3.A.3.c)
Based on the proposed changes within this section of the Permit, Ecology will require Permittees to update and implement their Stormwater Pollution Prevention Plan (SWPPP) to be consistent with the 2025 Industrial Stormwater Discharge Permit (ISGP) on or before March 1, 2025. Updating SWPPP's are an expensive and time consuming endeavor. Our small business just paid a firm to update our SWPPP, this took 6+ months and cost us over $10,000. Many consulting firms are already overwhelmed and do not have the staff to keep up with current requests, I don't see how they can possibly handle the burden of a mass SWPPP update before March 2025, which is less then 3 months after the permit will be issued. Given the cost and time associated with updating the SWPPP we suggest, at the very minimum, extending this time period.
Dumpster covers: (S3.B.4.d)
This would immediately put most recycling yards, and thousands of boxes, out of compliance. Adding lids will require sizeable time and capital investments which may not result in any better protection of the stormwater. Large lids will make it harder for some customers to use bins due to size and weight, it will make loading harder and more dangerous. Furthermore, this adds a failure point to the bins which will increase repair costs. Most of the items we receive have been outside in the elements, not undercover, for long periods of time prior to be dumped at our facility. I do not believe the additional expenses are justified by the minimal, if any reduction to storm water contaminates.

Employee Training (SB.4.b.i.5) requires that in addition to fulltime employees, contractors and vendors "who have duties in areas of industrial activities subject to this permit" receive annual training. This is overly burdensome not only to the Permittee but to contractors and delivery agencies. Would a Scrap yard or garbage dump be required to train every customer who steps foot on our property? Employees and other personnel requiring annual SWPPP training should be more narrowly defined. We would need a dedicated employee to train vendors, contractor an scrap customers. The cost, time and effort required of the permitee doesn't justify the minimal impact this will have, if any, on the contaminates in the stormwater.
6PPD and 6PPD-q Report-only Quarterly Sampling (S4.B.9.)
Table 3.Additional Benchmarks and Sampling Requirements Applicable to Specific Industries Report only reporting may not be applied to consistent attainment."
Consistent Attainment (S4.B.7.a) requires eight consecutive quarterly tests, for people who have no benchmark value, this is overly burdensome to require Permittees to quarterly sample indefinitely; especially for a contaminate that doesn't have local labs that test for the contaminate. There are few labs in the United States that offer testing for this contaminate, because of this, the testing cost is extremely high. This is a "report only" requirement that "will allow Ecology to characterize 6PPD-q in stormwater discharges from these sectors, assess the effectiveness of BMPs and other permit requirements to reduce 6PPD-q, and it may also help identify certain discharges and/or sites for further investigation and/or corrective action." These efforts and research for the ecology should not be at the ongoing expense of the Permitee.
PFA Sampling
We do not manufacture PFAs or PFA containing products. I do not believe it makes sense to force our industries to sample for something that has not even been removed from the products that we, as humans, use daily in our own homes. To make the greatest reduction of PFAS not only in our waterways, but to the general public, first the manufacturers of products that contain these contaminates need to be regulated. PFA can be found in clothing, cleaning products, shampoo/body wash, and even our food. Initiatives that help PFAS industries reduce use of these chemicals are the most effective means of reducing PFAS in the waste stream. PFAs cannot be eliminated from the waste stream so long as it persists in products that enter the waste stream daily. The proposed language doesn't specify which PFA's we will be required to test, but gives the suggested testing method 1633 which covers 40 different PFA. Does that mean we will be required to test for all 40? From what I have found there are no local labs that test for PFA's I cant imagine the cost of testing for 40 different PFAs would be economical for businesses.
PFAs are known as the forever chemical because they are present decades later. How will we be able to prove if the PFA is an old contaminate (from previous tenants of the property) or if it is directly from our operations or if it is from a product we receive at the scarp yard. This could open up our industries to costly lawsuits.
Lastly and most importantly due to the vast use of PFA containing materials used in field, laboratory operations, and most consumer goods brought to a sampling site it will be hard to get a sample that is not contaminated. If the environmental professional community is still gaining an understanding of correct sampling methodology, it is unreasonable for Ecology to expect that industrial facility workers can master sampling in less then 6 months. Because of all the issues with PFA sampling and contaminates I propose that PFA sampling be removed from the storm water permit at the very least until there has been a significant reduction in PFA's that are in products everyone uses daily.
Thank you for your time and consideration of our concerns,

Brian, Lisa, and Erin Parberry
Parberry Environment Solutions

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Comment From: Northwest Seaport Alliance (Mindi Kellar)

7/15/24 @ 4:12 PM

Thank you for the opportunity to review and comment on the Draft 2025 ISGP. Attached is a comment letter from The Northwest Seaport Alliance Commission Co-Chairs regarding the Draft 2025 ISGP.

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Comment From: TSMC Washington, LLC (Sally Hurst)

7/15/24 @ 4:11 PM

Thank you for giving us the opportunity to comment on Washington Department of Ecology's draft Industrial Stormwater General Permit (ISGP).

As you may know, TSMC Washington is a semiconductor manufacturer based in Camas, WA. We are a wholly owned s...↓ubsidiary of Taiwan Semiconductor Manufacturing Company, Ltd. (TSMC). As the world's leading foundry semiconductor manufacturer, TSMC and all of its subsidiaries take Environmental Social Governance seriously. We have implemented and maintained ISO 14001 certification for our environmental management system since 2001.

TSMC Washington strongly believes that stormwater pollution is a major threat to our diverse ecosystems and sensitive marine life. With this in mind, we have the following comments regarding the draft ISGP.

1.) S3 §B.1 (f.) Requires sites to update SWPPP site maps to now include locations of all receiving water (including discharges to ground) in the immediate vicinity of the facility. To evaluate receiving waters from any ground location would require extensive analysis. The requirement would be overly burdensome and have little value as the maps would only be assumptions for where the discharges run once they enter the ground. TSMC Washington suggests removing the inclusion of discharges to ground as the determination of receiving waters is not based on recognized methods.
2.) S3 §B.4 (b.)(i.)(5))(d)) States that training logs must be kept with the SWPPP and made available upon request. Many permittees no longer maintain physical training records and have migrated to digital learning management systems (LMSs). These LMSs allow for larger companies to track training with higher accuracy and to pull reports more dynamically. These types of systems may store data offsite on servers not owned by the companies. TSMC Washington suggests that the language be updated to remove the requirement that training logs must be kept with the SWPPP but keep that they must be made available upon request. This will reduce workload on companies that use online LMSs without impacting Ecology's intent to be able to review training logs during inspections or upon request.
3.) S4 §B.4 (b.)(i.)(4)(i) States that any liquid chemical release onsite regardless of size or flowability is considered a spill and must be logged in the spill log. This definition of a spill is too broad and would require additional resources for facilities to simply maintain spill logs. Facilities would need to constantly patrol parking areas, roadways, sidewalks and other areas where spills can occur, caused by persons or vehicles outside their control. This is unnecessary for facilities that have and maintain proper BMPs, such as storm drain inserts, that prevent those spills from impacting stormwater discharges. TSMC Washington suggests that Ecology remove this definition for spills from the permit or update the definition of a spill to be any liquid or chemical release that escapes containment BMPs and impacts stormwater discharges or groundwater discharges.
4.) S4 §B.5 (f.) Requires laboratory reports to include a sampling narrative. There is no definition or description in the draft permit that clarifies what is a sampling narrative. TSMC Washington suggests Ecology remove this requirement as each facility SWPPP provides sufficient narrative in the sampling plans and laboratories providing results may not be the ones completing the sampling.
5.) S5 §D.1 (b.) Requires permittees to conduct assessments for each non-stormwater discharge, including several that are conditionally approved, and document these assessments in the SWPPP. For industries that have multiple conditionally approved non-stormwater discharges, this activity is burdensome given that they must identify, locate each source, estimate flow volumes, and characterize potential pollutants that may be present. Facilities will then be required to identify and implement source control BMPs to reduce or eliminate these discharges. Lastly, facilities will then need to evaluate compliance of the discharges. TSMC Washington agrees that identifying and locating sources of conditionally approved non-stormwater discharges is a value-added activity. We disagree that characterizing these discharges is essential as these characterizations could lead to bad information, improper identification/implementation of control BMPs, and inaccurate evaluations for compliance with quality water standards given flows and pollutants are not based on measurable data.

TSMC Washington suggest removing this section in its entirety since S3 §B.1 of the draft permit already requires facilities to identify all conditionally approved non-stormwater discharges along with our suggestions to follow. We also suggest removing the requirement to estimate flows and pollutants given their variability and the fact that they are not based on measurable data. Lastly, we suggest removing the requirements to identify and implement source control BMPs, and to evaluate compliance with state water quality standards since the data facilities will use are not quality data.

Thank you for your consideration. Please contact me if there are any follow-up questions.

Sincerely,

Sally Hurst
Manager, Environmental Health and Safety
TSMC Washington, LLC

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Comment From: Puget Soundkeeper Alliance (Emily Gonzalez )

7/15/24 @ 4:03 PM

Please see attached document for comments.

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Comment From: Trident Seafoods (Shawn Stokes)

7/15/24 @ 3:51 PM

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Comment From: U.S. Tire Manufacturers Associ... (Stephanie Schlea)

7/15/24 @ 3:31 PM

Please see the attached comments from the U.S. Tire Manufactures Association.

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Comment From: Ashworth Leininger Group (Christine Wong)

7/15/24 @ 2:53 PM

July 15, 2024

Washington State Department of Ecology
PO Box 47696
Olympia, WA 98504-7696
Submitted via online portal: https://wq.ecology.commentinput.com/?id=tx2Ba6krSR

Subject: Comments on Washington's Draft Industrial Stormwater General Permit

D...↓ear Washington Ecology:

On behalf of our clients, many of whom are commercial and industrial facilities located in Washington state and subject to or potentially subject to Washington's Industrial Stormwater General Permit (ISGP), we provide several comments and/or items for clarification with respect to the draft ISGP. Ashworth Leininger Group (ALG) has worked with industrial and commercial properties in WA for decades and we have a wealth of experience interpreting and implementing environmental regulations in air, water, waste, and sustainability disciplines. Accordingly, we have valuable perspective with respect to implementing regulatory programs at the site level that are actionable and ultimately effective. Our comments are intended to provide constructive feedback and request clarification regarding specific provisions of the draft permit.

Comment 1: PFAS Sampling Requirements
It is impractical to require PFAS sampling for facilities in Washington at this time. According to Ecology Department and EPA websites, only one lab in the state – ALS Kelso Environmental – currently performs EPA draft Method 1633, the required method specified in the permit. Although labs may provide this service in the future, there is no current indication that there will be sufficient laboratory capacity to service many facilities in multiple counties; as such, it will likely be infeasible for facilities to find analytical lab support for PFAS sampling. Therefore, Ecology should consider lab capacity by withdrawing or delaying implementation of PFAS sampling requirements until enough labs are available to perform the analysis.

In addition, the draft permit proposes sampling requirements for certain types of industrial facilities for per- and polyfluoroalkyl substances (known collectively as PFAS) but does not define specific parameters to be monitored. PFAS cover a large group of chemicals, including thousands of different parameters and there is not currently an EPA- or state-approved method for PFAS analysis (EPA's Method 1633 is still a draft protocol). As Ecology's stated purpose in its draft ISGP fact sheet for requiring PFAS sampling is to "characterize PFAS in stormwater discharges from these sectors, assess the effectiveness of BMPs and other permit requirements to reduce PFAS, and it may also help identify certain discharges and/or sites for further investigation and/or corrective action," if PFAS sampling requirements are implemented, defining the parameters to be sampled is critical to developing a useful and comparable data set.

Suggested PFAS parameters to define for monitoring should include the six PFAS parameters regulated by EPA and Washington in drinking water (established as Maximum Contaminant Levels (MCLs)) and state groundwater quality standards: PFOA, PFOS, PFHxS, PFNA, and HFPO-DA as contaminants with individual MCLs, and PFAS mixtures containing at least two or more of PFHxS, PFNA, HFPO-DA, and PFBS. We do not recommend that required parameters for monitoring be identified by analytical method (e.g., EPA Method 1633), particularly when methods have not yet been finalized, because different labs may analyze for different suites of parameters even within the same method.

Comment 2: Expanding SWPPP Training for Contractors/Vendors
The draft permit expands stormwater pollution prevention plan (SWPPP) training requirements from relevant onsite employees to include contractors/vendors that have duties in areas of industrial activities subject to the permit. This is a significant expansion of the training requirement in the current permit and potentially covers most contractors/vendors that visit a site, even for a very brief or single time, including any delivery drivers (i.e., almost all personnel making deliveries to loading docks will be covered by this requirement). The exception that contractors/vendors could be excluded from training if supervised by a trained employee is not a practical exemption, as many such vendors/contractors can visit sites during off-hours, and many sites may have few onsite employees even during business hours to perform this supervision. This is an impractical and possibly infeasible training requirement, as many contractors/vendors are only briefly onsite (i.e., would not have the time for training) and some sites are visited by a very large number of such contractors/vendors. Accordingly, we recommend that this expansion to the training provision be withdrawn in the final permit.

Should a contractor/vendor training provision be retained in the final permit, the content/extent of the required training should be specified, and the training should not be equal in scope to that required of onsite employees. In addition, the timeline and frequency of the training should be stated in the final permit; the draft permit only notes that employees must be trained annually and within 30 days of hire and is silent about the training schedule for contractors/vendors. Further, since the updated SWPPPs are required to be implemented by March 1, 2025, the permit should specify whether training for existing contractors/vendors need to be completed by that time.

We appreciate the opportunity to comment regarding the proposed ISGP. If you have any questions, please contact me at (805) 764-6019 or cwong@algcorp.com.

Sincerely,

Christine Wong
Senior Environmental Scientist
Ashworth Leininger Group

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Comment From: Michael Jaynes

7/15/24 @ 2:42 PM

Thank you for the opportunity to comment. My comments are based as an individual who performs regulatory compliance duties.

I would recommend the analytical sampling methods table be modified to state that any method from 40 CFR Part 136 that meets ...↓the appropriate quantitation level is sufficient. In many areas of the state, the exact permit listed analytical methods are simply not available. Instead, the lab will run an alternative approved method from 46 CFR Part 146. Adding the QA/QC documentation to document it meets the QL is reasonable, but the additional statement "The permittee must also upload the QA/QC documentation from the lab on the QL development" is not appropriate to a standard, recognized method. This statement would be more appropriate to a newly developed analytical method and more appropriate to the Ecology laboratory certification entity.

The required spill log should be limited to external spills that would affect stormwater. This should be narrowed or at least Ecology could clarify what type of spills they are concerned about. Is there also a de minimis amount?

I agree with the requirement of educating third parties in the facility SWPPP. Some guidance would be helpful it what is expected. Typically, larger contractors doing a lot of site work are now provided handouts and toolbox talks. If these needs to be formal classroom training with recordkeeping this could be a different situation and difficult to comply with.

It would benefit Ecology to provide more guidance and help to regulated entities under the industrial permit – we all have the goal of preventing impacts to the environment. There seems to be little guidance or assistance to industrial permit holders for everyday situations. Current guidance appears to be aimed at Ecology staff and consultants working with municipal permits. There is a wealth of information submitted by permitted entities that could be used for research, unfortunately it is locked within the PARIS system which is poorly documented and unintuitive to work with. DMR reporting for stormwater situations is also a challenge, with limited WQWebPortal documentation. Ecology staff should remember that compliance staff work on multiple priorities and projects – they have general technical knowledge and want to learn but need help. When expectations are clear, we all benefit.

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Comment From: Lautenbach Recycling (Troy Lautenbach)

7/15/24 @ 2:36 PM

One suggestion I would also make would be a presentation to the State Solid Waste Advisory Committee (SWAC). These rule changes severely impact our industry. We have a meeting this Wednesday at 9:30 and I will be speaking about it.

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Comment From: BNSF Railway (Ryan Hibbs )

7/15/24 @ 2:33 PM

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Comment From: Lisa Hendriksen (Lisa Hendriksen)

7/15/24 @ 2:07 PM

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Comment From: Port of Port Townsend (Eric Toews)

7/15/24 @ 1:50 PM

The Port of Port Townsend offers comments on the proposed changes to the ISGP (2025) as presented in our letter uploaded on July 15, 2024. Thank you for the opportunity to review and comment.

Kind regards,

Eric Toews
Deputy Director
Port of Port T...↓

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Comment From: Waste Connections (Matt Breuer)

7/15/24 @ 1:22 PM

Please see the attached letter with comments from Waste Connections. Waste Connections appreciates the opportunity to be able to provide comments for Ecology's consideration on the draft permit. Thank you.

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Comment From: Jeffrey Longsworth

7/15/24 @ 12:50 PM

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Comment From: Washington Trucking Associatio... (James Tupper)

7/15/24 @ 12:12 PM

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Comment From: Floyd|Snider (Emily Jones)

7/15/24 @ 11:28 AM

Please see the attached letter for Floyd|Snider's comments on the draft ISGP. Thank you!

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Comment From: SSA Terminals (Daniel Skurski)

7/15/24 @ 11:12 AM

Thank you for the opportunity to comment on the 2025 ISGP draft letter. Please see attached.

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Comment From: Columbia Riverkeeper (Teryn Yazdani)

7/15/24 @ 11:05 AM

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Comment From: Western States Petroleum Assoc... (Antonio Machado)

7/15/24 @ 10:59 AM

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Comment From: Northwest Seaport Alliance (Mindi Kellar)

7/15/24 @ 9:11 AM

Thank you for the opportunity to review and comment on the Draft 2025 ISGP. Comments from the Northwest Seaport Alliance are attached. Thank you.

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Comment From: Port of Anacortes (Kevin Anderson)

7/15/24 @ 9:10 AM

Please see attached letter.

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Comment From: Port of Tacoma (Mindi Kellar)

7/15/24 @ 8:23 AM

Thank you for the opportunity to review and provide comments on the 2025 Draft ISGP. Please see attached for comments from Port of Tacoma.

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Comment From: J.R. Simplot Company (Dedra Williams)

7/15/24 @ 7:17 AM

The attached comments are on behalf of the J.R. Simplot Company regarding the Washington Department of Ecology Industrial Stormwater National Pollutant Discharge Elimination System and State Waste Discharge General Permit.

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Comment From: Port of Everett (Jacob Kirschner)

7/12/24 @ 4:56 PM

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Comment From: Washington Refuse & Recycling ... (Rod Whittaker)

7/12/24 @ 12:12 PM

Comments from the Washington Refuse and Recycling Association on the draft permit language.

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Comment From: United States Bakery (Molly Alar)

7/12/24 @ 11:28 AM

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Comment From: ConGlobal Industries (Molly Alar)

7/12/24 @ 11:17 AM

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Comment From: Skagit River Steel & Recycling (Molly Alar)

7/12/24 @ 11:07 AM

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Comment From: Snohomish County (Vian Salih)

7/12/24 @ 9:05 AM

1- In regards to landfills coverage for ISGP coverage/PFAS sampling requirements, the permit language is not clear, need clarification on the following:
A. Closed landfills that are capped and stabilized are exempt from the requirement to obtain an ...↓

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Comment From: Port of Bellingham (Alice Cords)

7/12/24 @ 8:20 AM

Port of Bellingham
July 12, 2024

The purpose of this letter is to provide comments from the Port of Bellingham (Port) on the Draft Industrial Stormwater General Permit (ISGP) that was issued for public comment on May 15, 2024 by the Washin...↓

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Comment From: Solvay Chemicals, Inc (Julie Frasier)

7/11/24 @ 2:38 PM

1. ISGP Annual Gross Revenue, S11C, page 6 vs page 67. We understand the due date is in March per the submittals found in Secure Access Washington. Will the due date be changed to May for the 2024 permit or will it remain in March?

2. S5, Table 3 (p...↓

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Comment From: Port of Seattle (Jane Dewell)

7/10/24 @ 4:43 PM

Please see two attachments from the Port of Seattle: a letter and detailed comment document

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Comment From: City of Everett (Elaine Lytle)

7/10/24 @ 3:16 PM

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Comment From: U. S. Environmental Protection... (Jill Seale)

7/10/24 @ 3:14 PM

Please see attachment, thank you.

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Comment From: Thurston County (Skyler Specht)

7/09/24 @ 1:09 PM

Seeking clarification whether industrial facilities that discharge to groundwater are covered under this permit. Several incongruencies are present that allow for various interpretations of how the permit applies to industrial permittees discharging ...↓to groundwater.

S1.A. states that the permit "...applies to facilities conducting industrial activities that discharge stormwater to a surface waterbody or to a storm sewer system that drains to a surface waterbody...the Permittee is authorized to discharge stormwater and conditionally approved nonstormwater discharges to waters of the state".

Under S1.C. (Facilities Not Required to Obtain Coverage):
"Ecology does not require the types of facilities listed below to obtain coverage under this permit, unless determined to be a significant contributor of pollutants...
3. Industrial facilities that discharge stormwater only to groundwater (e.g., on-site filtration) with no discharge to surface waters of the State under any condition, provided the facility doesn't meet the requirements of S1.B.1."

Under S1.E (Discharges to Ground)
"1. For sites with a discharge point to groundwater the terms and conditions of this permit shall apply. However, permittees are not required to sample on-site discharges to ground (e.g., infiltration), unless specifically required by Ecology (Condition G12)."

Under S1.A, we interpret that the permit covers only discharges to surface waters, and Ecology authorizes these permittees to discharge to waters of the state, which includes groundwater.

Under S1.C, we interpret that coverage is not required for permittees that discharge only to groundwater unless the facility is a significant contributor of pollutants to waters of the state.

Under S1.E, we interpret that coverage is required for facilities that discharge to groundwater but are not required to sample on-site unless otherwise specified by Ecology.

It appears that S1.A, S1.C and S1.E have conflicting interpretations. S1.A leads us to believe that the permit coverage is required for discharges to surface waterbodies and not to waters of the state (including groundwater). S1.C provides clarification that facilities that discharge to only groundwater are not required to seek coverage unless they are a significant contributor of pollutants to waters of the state (including groundwater). However, S1.E conflicts this indicating that the permit does apply to sites with a discharge point to groundwater.

In our opinion there is a lack of clarity in terms of whether the permit applies to facilities discharging to surface waters of the state vs. waters of the state, and which facilities are required to seek coverage under the industrial stormwater general permit if they do only discharge to groundwater. A clear stance and language regarding groundwater discharges is required in order for municipal stormwater permittees to 1) be able to properly refer industrial facilities to Ecology when conducting source control inspections and to 2) keep Ecology accountable for covering facilities that are obligated to be covered according to the permit language.

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Comment From: Port of Vancouver (Julianna Marler)

7/09/24 @ 12:00 AM

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Comment From: John Smith

6/28/24 @ 8:34 AM

(S4. General Sampling Requirements, 5. Laboratory Documentation) Define "g. Sampling Narrative". Describe what a sampling narrative would entail.

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Comment From: Jesse McCullough

6/26/24 @ 8:34 AM

The addition of "Any Liquid chemical release onsite regardless of size or flowability is considered a spill and must be logged and addressed" in the draft ISGP is too broad and creates an overly burdensome requirement. The difficulty to meet this req...↓

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Comment From: Jesse McCullough

6/26/24 @ 8:24 AM

Bulk propane distribution facilities that do not manage any other petroleum hydrocarbons should be exempted from the requirement to monitoring for diesel fraction petroleum hydrocarbons as that is not a constituent of concern in propane. Currently, p...↓

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Comment From: Jesse McCullough

6/26/24 @ 8:21 AM

Unconnected drainage areas within a facility should be managed separately for purposes of determining applicable parameters that require monitoring. For example, consider an industrial facility only subject to the benchmarks and sampling requirement...↓

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Comment From: Jesse McCullough

6/26/24 @ 8:14 AM

Unconnected drainage areas within a facility should be managed separately for purposes of corrective action progressions. Only a second or third benchmark exceedance within a given drainage area suggests that drainage area cannot be managed adequatel...↓

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Comment From: Xiao Chi Jie (The XCJ Corp dba... (Cameron Siegele)

6/19/24 @ 8:03 AM

Section S3B5, Employee Training: The SWPPP shall include BMPs to provide SWPPP training for all employees and contractors/vendors who have duties in areas of industrial activities subject to this permit. Contractors/vendors may be excluded if the per...↓

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Comment From: Lucas Samuel

6/17/24 @ 7:32 PM

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Comment From: BURT GILLELAND

6/17/24 @ 12:13 PM

Based on a third party lawsuit to Ecology, the consent decree agreed to by Ecology was to present a clause in the permit requiring that every contractor, delivery person, etc. either be 100 percent supervised or go through storm water training. As w...↓

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Comment From: Milgard Vinyl Extrusion (Michael Hill)

6/17/24 @ 9:52 AM

Please see attached.

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Comment From: Puget Sound Coatings (Angie Glasser)

6/17/24 @ 9:48 AM

We would like to submit,
RE: S3B5 A full annual training seems more reasonable rather than doing a training with each new hire within 30 days.

Angie Glasser
Puget Sound Coatings

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Comment From: Jim Seley

6/14/24 @ 3:57 PM

Section S3B5: Training vendors who come on to our site in the ways of Storm water Management is unreasonable. We cannot train every truck driver that may show up from UPS, FedEx, etc. We are responsible for our own storm water, regardless of whether ...↓

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Comment From: Nisqually Environmental (John Allen)

5/22/24 @ 5:31 PM

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Comment From: Alice Cords

5/16/24 @ 4:12 PM

Please issue a red-line version of the Draft Permit as soon as possible. Thank you.

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Comment From: Alexander Lesher

5/16/24 @ 2:33 PM

Under S8, please make it consistent and settle on using either Level 1 or Level One. Thank you.

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