On August 26, USTMA submitted comments to the Environmental Protection Agency's (EPA) proposed National Pollutant Discharge Elimination System (NPDES) permit for Joint Base Lewis-McChord (JBLM). This was the second public comment period on the draft permit, and EPA sought comment on new and revised conditions, including the addition of 6PPD-quinone (6PPDQ) monitoring requirements. USTMA's comments recommend that EPA require JBLM to thoroughly document the monitoring activities for 6PPD and the results obtained through this permit’s requirements so that the data can be characterized and compared with similar sampling efforts.
The draft NPDES permit also provides further direction regarding stormwater retrofit projects that permittees must implement to effectively reduce or eliminate pollutants including 6PPDQ. The draft permit stresses that these projects must use practices that have been shown to be effective, such as those detailed in Washington Ecology’s 2022 Stormwater Treatment of Tire Contaminants Best Management Practices (BMP) Effectiveness Report or "other current research."
USTMA's letter provided several examples of additional research for EPA to include that would enhance the clarity and utility of the permit requirements and ensure that permittees have access to the latest and most relevant scientific data.
For more information, contact Stephanie Schlea at SSchlea@USTires.org.