As all industrial facilities in Washington State are aware, the State of Washington Department of Ecology Industrial Stormwater General Permit (ISGP) is one of the most stringent stormwater discharge permits in the United States. Port-related facilities in particular have had a difficult time achieving its pollutant benchmark values for metals and turbidity. Washington State law requires permit holders to implement All Known, Available, and Reasonable methods of prevention, control, and Treatment (AKART), similar to “Best Available Technology Economically Achievable (BAT)” under federal law. AKART has been difficult to define for stormwater discharges at industrial facilities.
The Washington Public Ports Association (WPPA) hired the Kennedy/Jenks Consultants team to develop a guidance document that would help Washington Ports and their marine terminal operators to maintain ISGP compliance and achieve AKART, while leaving permit holders the option of taking a site–specific approach. The “Washington State Marine Terminal AKART and ISGP Corrective Action Guidance Manual” was developed in consultation with Ecology, the Pacific Merchant Shipping Association, and multiple local environmental organizations and it will be finalized prior to the effective date of the re-issuance of the ISGP, on 1 January 2015.
While the guidance applies to marine terminal operations that discharge to marine waters in Washington, the information presented has relevance to all industrial stormwater dischargers facing the challenges of permit compliance, particularly corrective action requirements. Currently available stormwater treatment options have been assembled, and listed based on expected pollutant removal efficiency at varying influent concentrations. The decision-making process and site-specific evaluation presented in the guidance could be used as a model for other industries and in other locations and should be shared throughout the firm.
The draft Guidance Manual is available for download at the Washington State Department of Ecology Industrial Stormwater General Permit website.
Please also see the Focus Sheet and accompanying Presentation recently given by Ross Dunning, Kennedy/Jenks Consultants Stormwater Practice Leader, at the seminar, Stormwater Law and Regulation in Washington State: Update on Ecology’s ISGP and Construction General Permit – June 25, 2014.