EXH 233: NHC Letter to Ecology — NPDES Permit Modification STIA IWS Design Criteria Detention Standards

In this April 2001 letter, Northwest Hydraulic Consultants raised technical concerns on behalf of the Airport Communities Coalition regarding a proposed NPDES permit modification for Seattle-Tacoma International Airport. The firm identified two key issues: a lack of clear, enforceable design criteria for stormwater overflows from the airport's integrated wastewater system (IWS), and an inconsistency between the permit's stormwater detention standards and the stricter standards sought under Section 401 Certification for the Third Runway and Master Plan Update projects. The consultants recommended that the permit be revised and republished for public comment to address these gaps and ensure consistent, enforceable stormwater management requirements.

Notes

Exhibit 233 (AR 018943–018944). Letter dated April 30, 2001 from William A. Rozeboom, P.E., Northwest Hydraulic Consultants Inc., to Washington State Department of Ecology Water Quality Program (Kevin Fitzpatrick) and Shorelands and Environmental Assistance Program (Ann Kenny), on behalf of the Airport Communities Coalition (ACC). Comments on proposed major modification to NPDES Permit No. WA-002465-1 for the Port of Seattle, Seattle-Tacoma International Airport (Sea-Tac). Two specific issues: (1) Permit Conditions S1.E and S5.B lack enforceable IWS (Integrated Wastewater/Stormwater) system design criteria for authorized bypass overflows into the storm drain system; recommends republication for public comment with IWS performance expectations including overflow frequency and duration. (2) Permit Condition S14 (page 47 of 53) sets a stormwater detention standard referencing the Stormwater Management Manual for the Puget Sound Basin that is less stringent than SMP Section 2.1.4 ‘updated’ detention standards sought under Section 401 Certification for the Third Runway and Master Plan Update projects; recommends NPDES permit be amended to require updated standards for all new and retrofit construction. Affected waterbodies: Miller Creek and Des Moines Creek. Filed in PCHB Third Runway EIS administrative record.

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