New monitoring requirements are likely coming to the Washington Industrial Stormwater General Permit during the next permit cycle. What should companies be focused on?
Surprise! Another emerging contaminant to be worrying about and it is not PFAS. We hosted Washington Department of Ecology Industrial Stormwater General Permit (ISGP) lead writer, Travis Porter, on Coffee & Compliance and he shared one of the biggest changes potentially coming in the next ISGP for companies. 6PPD Quinone is likely to be regulated in the permit, due to be reissued in 2024, as the link to mortality in juvenile coho salmon was recently established. They previously saw coho salmon dying, but didn’t understand what was the toxic driver until the past year. 6PPD-Quinone is a chemical from tires that is used to stabilize rubber and prevent weathering breakdown (the tires stay flexible).
For permittees beyond industrial, such as those companies under the sand & gravel or municipal permits they may also see monitoring requirements for it. The challenge for all the dischargers is how to keep it out of the water. Likely there will need to be increased source control and treatment. However early studies have shown that treatment is not always working. Retention of stormwater doesn’t work as well, but other active treatment systems, such as filtration, don’t see it getting compounded.
For industrial permits, not sure if it will go in next permit. Due to the impact on coho salmon, the public and the tribes are pushing hard for regulations. Even at low levels it can be toxic to salmon and according to Travis they now know how to test for it. However there are still open questions as to what levels will be required for testing. Likely a technology based limit will be used to start, because a tiny bit will be toxic. They are likely to set the limit as non-detect, because there is currently an inability to test low enough. The Department of Ecology is doing a big research push this year and should see first round of data this winter and spring, which will inform the permit writing process around testing requirements and limits.
On everyone’s favorite emerging contaminant, Travis said they are not seeing a lot of PFAS and PFOA in stormwater, because it mainly is in aircraft AAA firefighting foam. All mil-spec AAA had PFAS in it and airports and air plane hangars are likely to have it. Because of the limited sources there is not likely to be general monitoring requirements for it in the next ISGP.
Monitoring data overall has been flowing to EPA via ICIS, which is a recent improvement as they had not been compatible previously. However there have been issues with the data being exposed on the EPA side as it is frequently incorrect. This causes all sorts of issues for companies and the Department of Ecology. Both are having to answer why data is wrong. Currently, most third party groups have realized that Washington’s PARIS database is the correct source of info and is the source of record for Washington facilities, This underscores the perils of increasing public data without robust systems in place and easy ways for companies to transmit, check and correct data. National companies have been employing a strategy of looking at EPA data regularly and then working to fix it with EPA and state agencies, because of the public relations and litigation risk.
To hear our full discussion with Travis, check out the webinar recording!
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