Continuing its vanguard approach to environmental regulation, California is poised to incorporate Total Maximum Daily Load (TMDL)-specific requirements into its industrial storm water general permit (IGP). TMDLs are pollutant- and water body-specific and establish the maximum amount of a pollutant a water body can receive while meeting water quality standards. Once effective, these new requirements will provide additional avenues of attack for the already active Clean Water Act citizen suit docket.
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Effective July 13, 2018, the California State Water Resources Control Board’s Division of Drinking Water (DDW) established drinking water notification levels of 14 ppt for PFOA and 13 ppt for PFOS, and a combined PFOA/PFOS drinking water response level of 70 ppt. Notification and response levels are non-binding, health-based advisory levels for contaminants in drinking water where maximum contaminant levels (MCLs) have not been promulgated. Establishment of notification and response levels often is the DDW’s first step toward adopting binding MCLs.
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California is considering the first-in-the-nation general industrial stormwater permit incorporating Total Maximum Daily Load-related numeric action levels and numeric effluent limitations. Touted as an effort to promote green infrastructure and water reuse, this proposal could revamp how industry manages stormwater.
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PFASs (per- and polyfluoroalkyl substances) comprise a group of highly fluorinated manmade compounds that are showing up in drinking water supplies around the country. They are resistant to heat, water and oil, as well as to chemical breakdown. Until recently, PFASs have not been widely regulated. This is changing at both the federal and state levels.
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