Annual Sampling in the 2020 Washington ISGP

October 12, 2020
By Brian Schefke

A quick reminder to industrial stormwater permittees in Washington: we’re now in the fourth quarter of 2020, and the current permit requires all permittees to collect and test an “annual sample”. Section S4.B.7.c-d of the 2020 ISGP states:

The annual sample must be taken during the 4th quarter. A facility may average the annual sample with any other samples taken over the course of the 4th quarter. The annual sample does not include the first fall storm event.

A Permittee whose annual sample exceeds the benchmark during consistent attainment is no longer allowed to claim consistent attainment. The Permittee must

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EPA Proposes Changes in New MSGP

June 22, 2020
By Brian Schefke

In March, the EPA released its final proposed version of the Multi-Sector General Permit (MSGP) that will replace the 2015 version currently in force. The MSGP authorizes stormwater discharges in areas where the EPA is the permitting authority, e.g., areas not covered by a state general permit. The comment period for the proposed permit ended June 1, and the EPA will issue the final permit later this year.

In response to a National Research Council study on improving the MSGP, the EPA has proposed a number of changes to the permit in the new version. The most substantial are summarized …

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Analysis of 2019 Stormwater Notices of Intent to Sue in Washington

June 2, 2020
By Jenny Ma

Over the past several years, regulatory authorities and nonprofits have increased their watch over stormwater compliance. Freer Consulting routinely monitors records for the state of Washington from the Region 10 office of the Environmental Protection Agency for Notices of Intent (NOI) to Sue under the Clean Water Act. In 2019, the EPA received 21 NOIs for Washington businesses and individuals.

Of these 21 NOIs, the top five categories were:

  • Discharge without a permit: 11 – 52% of NOIs
  • Numeric effluent violations (e.g. facility is discharging with pH levels outside of permitted limits): 11 – 52% of NOIs
  • Failure to prepare
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King County Stormwater Violations Trend

May 8, 2020
By Jenny Ma

This year, a new permit for Industrial Stormwater General Permit (ISGP) for the state of Washington went into effect. Now is a great time to look at how permit holders in King County did over the 2015-2019 period regarding stormwater violations.

Data was collected from the Department of Ecology looking at all industrial stormwater violations reported in each year for King County during the 2015-2019 permit period.

Over the permit period, the top three violations have been benchmark exceedances, monitoring violations, and reporting violations.

  • Benchmark exceedances (e.g. a stormwater sample contained lead that was over the 64.6 µg/L limit) have
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Using ISO 14001 to Simplify GRESB Reporting

May 4, 2020
By Aaron Schlossman

Completing Global Real Estate Sustainability Benchmark (GRESB) reports is a complex, resource-intensive process for any business, whether it’s are establishing benchmarks for the first time or working towards well-specified goals. GRESB has successfully streamlined the reporting process, but data collection, management, and verification still pose obstacles during the annual reporting cycle.

GRESB complexity comes from the same source as its elegance. The thorough consolidation of external frameworks into one reporting tool, packaged into a seamless interface, takes much of the pain out of presenting data from your year. Often, we find that the remaining challenges stem from structuring operations to …

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