Notes
Draft internal memo dated October 29, 1998 from Tom Luster to Gordon White, Paula Ehlers, and Tom McDonald at Washington State Department of Ecology (Exhibit 2112, AR 033725–033727). Addresses two issues arising from Ecology’s 401 certification review of Sea-Tac Airport (Port of Seattle): (1) whether WAC 173-201A-160(3) water quality standards require stormwater discharges to meet water quality criteria beyond minimum BMPs in Ecology’s Stormwater Manual, and (2) whether 401 certification review should apply stricter standards than NPDES review. Finds minimum BMPs inadequate to meet criteria for copper, zinc, lead, fecal coliform in urban stormwater runoff; bioswale plus compost filter insufficient for copper criterion. Recommends Ecology require adequate stormwater treatment for 401-certified projects in wetlands and waterbodies under Clean Water Act and state water quality standards. Discusses implications for permit denials, salmon recovery, wetland avoidance, WDOT agreements, and stormwater manual revisions.