1200Z/COLS PERMIT REVISIONS AND PATH FORWARD Michael J Pronold City of Portland February 9, 2017 Who has a permit? Who needs a permit? Draft permit was scheduled for Public Notice in January but DEQ has shared some of the proposed revisions. Had a stakeholders meeting in November. I believe most of these will be in the permit put up for public notice.

SCHEDULE 1200-COLS Permit - Expired Aug. 31, 2016 1200-COLSB Permit - Issued Nov. 3, 2016 1200-Z Permit Public Notice Tomorrow; 35 days. Public Hearing in early March Permit expires June 30, 2017 Combined permit effective July 1, 2017 Expired – administratively extended B – Can’t legally issue an expired permit Tomorrow Still on schedule for July 1

PERMIT RENEWAL SUBMITTAL No SWPCP Reviews No Public Review of Individual Sites Was/is a contentious issue with citizen groups. How can you issue a permit if you don’t know the SWPCP meets permit conditions. -No significant changes (some BMs lowered) -Would require an inspection so could delay permit renewals -Not legally obligated to.

TIER I Correction Action Response to Exceedance for Impairment Pollutants or Benchmarks. Applies even if Tier II Corrective Action was taken. Reports kept on site. No longer BER. Hopefully reduce confusion, lessen number of “reports”.

TIER II Evaluation based on second year geomean. Tier II can be triggered again. Report is part of the SWPCP. Provision for Waiver still exsits Timing of second year. If issued a permit recently that would count as your first year. (Any fraction of the year!).

PORTLAND HARBOR Not as inclusive as the slough. Was “targeted” to sites that DEQ had identified as having activities that have/could impact sediment. EPA wanted everyone to have a permit. Slough origin a lot to do with heavy construction industry.

Benchmarks Region Cu Pb Zn pH TSS O/G eColi BOD TPO4 Cascades .009 .040 .12 5.5-9.0 100 10 *406 Coastal .024 Columbia River .050 Columbia Slough .038 .060 .24 5.5-8.5 30 406ct 33 .16 Eastern Willamette Harbor .022 Willamette Valley .012

Monitoring Reinstatement of monitoring No more additional pollutants Modified impairment list eReporting

eReporting and NetDMR 2016-2017 DMR – paper 2017-2018 DMR – NetDMR (EPA Training) 2020 target date for everything else (Applications, Waivers, SWPCP, Tier I/II, etc.) Next year (17-18) all reporting will be electronic. Naming convention Training on EPA website Publically available (WA, some CA) City/DEQ coordination

OTHER ITEMS TBELs Variance Request Monitoring Waivers Notice of Termination Reporting BMs – TSS - 30 (Slough and PHarbor) based on work done by WA DOE in the Duwamish watershed. Modified benchmanrks based on GI? Cd, Cr, Ni (some sectors Hg and PCBs) – no more monitoring. No proposed BMs. Impairment - JCreek DDE, endosulfan, endrin aldehyde, lead (dissolved -0.017)) Willamette copper (0.01) lead (d), pentachlorophenol (removed) Fanno Creek (As, Cu, Fe, Pb (d), tetrachloroethylene, Th, Zn (0.04) Employee Education/MSGP Guidance on how to note no sampling, increase in GI Waivers to remain NOT conditions required to obtain a termination – past contamination. Like 1200C Reporting (Table) summarize but still throughout the permit

PATH FORWARD Permit to be Effective 07/01/17 DEQ/Agent Issue Permits with Permit Assignment Letters SWPCP Revisions If Necessary Holistic Approach Green Infra-structure Not only for the permit but for stormwater management in general. New development criteria/requirements; Stormwater as a resource; Green Infra-structure

Michael J. Pronold Environmental Program Manager City of Portland michael.pronold@portlandoregon.gov 503-823-7584