EXH AR023562: ACC Comment Letter NPDES Permit Major Modification STIA

A March 2001 letter from Water Resources Consulting LLC to the Washington State Department of Ecology raises concerns about a proposed NPDES permit modification for SeaTac Airport, arguing that the draft permit gives the Port of Seattle a 'blank check' to discharge pollutants at unspecified locations into unnamed water bodies without adequate public oversight. The letter also criticizes the airport's stormwater monitoring reports for obscuring potential water quality violations by mishandling hardness data used to evaluate dissolved metals concentrations. The author urges the Department of Ecology to require specific discharge locations and proper concurrent hardness reporting before issuing the modified permit.

Notes

Letter dated March 12, 2001 from Peter Willing, Ph.D. of Water Resources Consulting L.L.C. to Chung Yee, Washington State Department of Ecology, submitted on behalf of the Airport Communities Coalition (ACC) regarding proposed draft NPDES permit no. WA-002465-1 for Sea-Tac Airport. Raises two objections: (1) the draft permit offers a blank-check approval of future discharges at unknown locations into unspecified receiving waters, depriving the State and citizens of oversight; (2) reporting requirements must be revised to include hardness data concurrent with metals samples on Discharge Monitoring Reports (DMRs), citing WAC 173-201A-040. Criticizes the Annual Stormwater Monitoring Report for July 1999–June 2000 for using a median hardness value of 56 mg/l versus a prior median of 14 mg/l, obscuring violations of copper and lead chronic toxicity standards by up to 9x and 7x respectively. Requests that the modified permit, Monitoring Requirements section S2.A, Stormwater, be amended to add hardness reporting by EDTA method or calcium/magnesium calculation. AR 023562–023563.

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