Port – NPDES Appeal, Final, October 2003

issued National Pollutant Discharge Elimination System Waste Discharge Permit No. 002465- (the “Permit” or “NPDES Permit”) to the Port of Seattle (“Port”). See Exhibit 1. The Permit authorizes the discharge of industrial wastewater and stormwater associated with industrial and construction activity at the Seattle-Tacoma International Airport (“STIA”) according to the Permit terms and conditions. This includes discharges from airport operation areas associated with industrial activity and from construction projects. For over a year, the Port has engaged in discussions with Ecology over the terms and conditions of the Permit. A draft version of the Permit was issued in March 2003, and was the subject of extensive comments by the Port as well as by concerned members of the public. NOTICE OF APPEAL PAGE 2 BROWN REAVIS & MANNING PLLC 1201 THIRD AVE., SUITE 320 SEATTLE, WA 98101 (206) 292-6300 Ecology responded to many of these comments either by revising draft Permit language and conditions, or by explaining in its Responsiveness Summary why proposed changes were not made. Despite the Port’s efforts to resolve these issues through the comment process, the Permit contains a number of terms and conditions that are unsupported by the law and that impose undue burdens on the Port and its STIA operations and projects without achieving any corresponding environmental benefits. This appeal is being filed to address those issues. II. BACKGROUND STIA has been subject to an individual NPDES permit for its industrial waste system since January 2, 1980. Since 1980, STIA’s NPDES Permits have been…
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