TagEcology(797)

This December 1998 internal memorandum from Justin Kophs to Linda Logan outlines options for developing a site-specific copper translator for the Port of Seattle, summarizing EPA guidance on dissolved and total recoverable metal sampling studies. It describes recommended approaches including field partitioning studies, historical data equations, and laboratory mixing tests to measure how copper partitions between dissolved and total recoverable forms in receiving water. The memo notes that while a site-specific translator improves compliance measurement accuracy, it cannot be used to influence permit limits in the same way as a Water Effect Ratio (WER).

A 1998 internal memorandum from Washington State's Shorelands and Environmental Assistance Program recommends reclassifying employee Tom Luster from Environmental Specialist 4 to Environmental Specialist 5, citing his assumption of higher-level duties following a colleague's departure in 1997. Luster's qualifications, including a Master's degree in Geography and over 10 years of experience, along with the cost-neutral budget impact, are presented as justification for the upgrade.

Email from Steve Saunders (November 21, 1998) to Melodie Selby, Robert Barwin, John Glynn, Carl Nuechterlein, and others, recommending that Melodie Selby and Bill Moore take lead on CWA Sections 401 and 402 coordination due to stormwater and BMP manual focus. Attached is a Washington State Department of Ecology Water Quality Program summary memo analyzing

Annual Stormwater Monitoring Report for Seattle-Tacoma International Airport (STIA) covering the period June 1, 1997 through June 30, 1998, prepared by Port of Seattle, received by Washington State Department of Ecology on December 1, 1998 (AR 033384). Report covers stormwater sampling results from airport subbasins including SDN2, SDS1, SDE4, and Taxi Yard; analytes include fats/oils/grease

Email dated October 29, 1998 from Tom Luster to Lisa Zinner (Washington State Department of Ecology) requesting review of a draft 3-page memo summarizing 401/stormwater water quality issues that arose during the SeaTac airport review and a WQ Program/SEA Program meeting. Luster describes it as his ‘401-biased’ view and requests confidential review, asking Zinner not

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

In a September 28, 1998 letter from the Port of Seattle to the Washington Department of Ecology, the Port provides a status update on stormwater management efforts at Seattle-Tacoma International Airport, covering detention, treatment, copper loading, and first flush analysis. The letter outlines proposed delivery dates for required reports and explains the complexity of treating stormwater runoff, including challenges related to mandatory FAA-regulated de-icing and anti-icing chemicals used on runways. It also addresses the status of ongoing wetland delineations and water rights reviews connected to the airport's planned third runway construction.

A 1998 internal email from Washington State Department of Ecology staff raises concerns that standard stormwater Best Management Practices (BMPs) may not provide sufficient water quality treatment to meet state and federal Clean Water Act standards for projects requiring 401 Water Quality Certification. The author warns that issuing 401 certifications while knowingly allowing water quality criteria to go unmet would be legally indefensible, and calls for updated policy guidance, better technical assistance, and clearer requirements for applicants. The email proposes that projects involving waters of the state be held to stricter stormwater treatment standards than upland projects not requiring a 401 certification.

A 1998 internal email exchange between Washington State environmental officials discusses an urgent regulatory problem that arose during the SeaTac Airport project: stormwater Best Management Practices (BMPs) were found to be inadequate to meet Water Quality Standards, meaning 401 water quality permits could not legally be issued. The Attorney General's office confirmed that 401 permits cannot be granted when stormwater BMPs fail to meet standards at the discharge point, affecting most permit decisions at the time. Officials urged that the issue be added to the agenda of a September 17, 1998 Stormwater Coordination meeting to begin resolving how to handle 401 permits when stormwater concerns arise.

Letter dated September 10, 1998 from Christine O. Gregoire’s Attorney General of Washington Ecology Division (author not individually named) to J. Tayloe Washburn of Foster Pepper & Shefelman responding to an August 11, 1998 memorandum requesting clarification and minor revisions to Ecology’s 401 certification (Order No. 96-4-02325) for Sea-Tac Airport improvements including the third runway.