TagPollution Control Hearings Board(1532)

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

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

A 1998 fax from Parametrix, Inc. to the Port of Seattle discusses water quality concerns related to copper in stormwater runoff at Seattle-Tacoma International Airport. The document outlines that while standard Best Management Practices (BMPs) can remove most metals from stormwater, copper remains a persistent challenge due to its widespread presence from sources like automobile brakes and rooftops. It raises questions about compliance requirements, the cost of installing sand or compost filters (potentially up to $100 million), and how the Port and Washington State Department of Ecology can reach a workable agreement on stormwater discharge standards.

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.

Report prepared by Woodward-Clyde in association with UCLA and Psomas & Associates for the Santa Monica Cities Consortium, City of Santa Monica Engineering Department, Project No. 9653001F-6000, dated September 24, 1998. Evaluates potential catchbasin retrofits for the Santa Monica Bay Area Municipal Storm Water/Urban Runoff Pilot Project. Describes stormwater sampling at inlets to four catchbasins

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.

FAA Northwest Mountain Region letter dated September 2, 1998, from FAA to Brian R. Applebury, Chief Operations Division, Seattle District Corps of Engineers, regarding permit application 96-4-02325 for Port Of Seattle Third Runway at Seattle-Tacoma International Airport. Letter addresses compensatory wetland mitigation, bird/aircraft strike hazard, Advisory Circular AC 150/5200-33 ‘Hazardous Wildlife Attractants on or Near

King County, Washington Surface Water Design Manual, September 1998 draft, published by the King County Department of Natural Resources (DNR), Water and Land Resources Division (WLRD). Implements King County Adopted Ordinances 13189, 13190, and 13191, effective September 1, 1998. Draft rules pending approval by the King County Executive Ron Sims. Document AR031748/AR031749/AR031750. Contributors include staff