2000 ANNUAL REPORT
WATER ISSUES

Water Quality Discharge Limits Debated throughout California

Water quality discharge limits became a high priority issue for WSPA in 2000. From the smallest retail outlets to the largest refineries, operators were faced with the potential imposition of unreasonable or infeasible permit limits and conditions. Throughout California, from the Bay Area to San Diego and the Pacific Northwest, Federal, State and Regional water quality regulatory agencies have made water quality improvements for impaired bodies a main regulatory focus.

The issue of discharge limitations has challenged facility operators as never before. For example, some facilities were faced with limitations on surface stormwater runoff thorough implementation of Statewide Urban Stormwater Mitigation Plans (SUSMPS). Others were faced with future permit limits on wastewater discharges via limits on Total Maximum Daily Loads (TMDLs). Both regulatory approaches call for dramatic reductions of compounds that can be released into impaired water bodies. Of particular concern is the requirement for "no net loading" (zero discharge) if agencies (such as the USEPA or the State Department of Health Services) fail to promulgate a TMDL within the next few years.

Stormwater Appeal Succeeds

In 2000, the Bay Area and South Coast Refining Committees actively worked with local agencies to better understand the problem and develop possible solutions. WSPA successfully appealed to the State Water Resources Control Board (SWRCB) which overruled the Los Angeles Regional Water Quality Control Board, and supported that Best Management Practices (BMPs) are the best way to manage stormwater runoff. Incorporation of BMPs by service station owners and operators will ensure that stormwater runoff will be handled in an environmentally safe manner.

Unfortunately, WSPA was not successful with all regional water Boards. WSPA was forced to go to court and file against both the USEPA and some of the regional water quality control boards to protest the lack of scientific justification for newly proposed permit limits. WSPA also intervened in court cases to ensure industry concerns are appropriately addressed. WSPA has consistently supported approaches that recognize the scientific and technical advances that can and will be made and that are cost effective. Unfortunately, recent agency actions point to a regulatory scheme designed to inflict maximum controls on an industry that is not responsible for the water problems that currently exist.

Throughout 2000, WSPA advocated for current scientific data to ensure permit discharge limits will result in actual reductions and real water quality improvement of impaired bodies. In 2001, many of these court cases will be decided, which will give WSPA a target for future research and technology.

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