1. 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.

2. 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

3. 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.

4. 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”.

5. 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!).

6. 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.

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

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

9. eReporting and NetDMR 2016-2017 DMR – paper
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

10. 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 ))
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

11. 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

12. Michael J. Pronold Environmental Program Manager City of Portland