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Comment
Period Extended for Sea-Tac
Pollution
Permit Renewal; Commenters
At
Hearing Say, “Good, Could Be Better”
The
comment period for the renewal of Sea-Tac Airport’s water-pollution
permit has been extended to close of day, Monday, 21 April.
Comments may be submitted by e-mail or FAX to Ed Abbasi,
Northwest Regional Office, Department of Ecology. Mr Abbasi’s
FAX number is 425.649.7098, & his e-mail address is
<eabb461@ecy.wa.gov>. Hard copies should also be
mailed to Mr Abbasi at
3190
- 160th Ave. SE
Bellevue,
WA 98008-5452
At
the public hearing on the draft permit, held on 31 March,
the general tone of public comments was that the draft permit
is a considerable improvement over the existing one, but
that there are problem areas where the permit could be made
even better.
Concerns
that included the following:
- There
are good things in the draft permit to address stormwater
issues, but the timetable for implementation is too slow.
The Port should be held to the 30 June 2004 deadline for
implementation of so-called “AKART” (state-of-the-art
treatment) that is stated in the current permit. Relaxing
the deadline, as proposed in the draft permit, would result
in the discharge of an additional several hundred million
gallons of inadequately treated industrial wastewater
to Puget Sound.
- The
draft permit doesn't require the Port to do enough to
treat contaminated stormwater. Major studies have shown
that the local streams are not meeting water quality standards
for copper and zinc, which are very harmful to fish. Ecology
should require the Port, in this permit cycle, to put
into place “best management practices” which are known
to be effective at removing dissolved metals from stormwater.
They exist, they work, they should be used at the earliest
opportunity.
- As
CASE President Brett Fish pointed out in a recent article
in the Seattle Post-Intelligencer, run-off
from the Airport has been killing fish for 50 years, while
the Airport has been denying the existence of fishkills,
or at least the existence of evidence that it is the Port’s
pollution that does the harm. But dead fish tell their
own story. The back-up evidence would come from appropriate
sampling of polluted water where it leaves the Port’s
control—the “end of the pipe”. The existing permit
and the draft renewal are both too weak in this respect.
- The
permit should require "first flush" sampling
of all stormwater discharges within the first thirty minutes
of storm events. It is well known that the "first
flush" of stormwater contains the highest levels
contaminants. But the draft permit only requires sampling
of flow-weighted composites, which do not reveal the highest
levels of stormwater pollution. The highest levels do
the most harm, of course.
- The
draft permit doesn't require the Port to do enough to
identify and to address the impacts of the deicers and
anti-icers used on aircraft, runways and taxiways. The
deicing/anti-icing chemicals degrade water quality by
consuming oxygen as they decompose. The permit should
impose effluent limits that prevent harm from these substances,
and the Port should be required to sample and to report
accordingly.
- The
draft permit does not address the toxicity of additives
used in deicing/anti-icing products. Recent studies show
that these additives—typically, corrosion inhibitors
and flame retardants containing chemicals called triazoles—may
cause adverse aquatic toxic effects. The permit should
require testing of lethal toxicity and sublethal toxicity
of actual stormwater discharged during a deicing event
at Sea-Tac. In addition, the Port should sample its discharges
for the presence of these harmful additives.
- The
"Comprehensive Receiving Water and Stormwater Runoff
Study" (Permit Part II, Condition S6) is not well
designed, according to one local expert, and should be
strengthened. Among other things, the Study should specifically
require sampling of stormwater discharges from Outfall
SDS3—the most significant airfield stormwater outfall.
The Study should also include an assessment of the Index
of Biological Integrity (IBI) for Des Moines Creek—the
only creek excluded from that requirement in the draft
permit. Des Moines Creek receives more stormwater from
Sea-Tac Airport than any other creek—why exclude
it?
- The
permit should require the Port to sample and to report
effluent constituents and volumes of untreated overflows
from the industrial wastewater system. The draft permit
acknowledges that overflows may occur at Lagoon 3, and
at the outfalls from the North and Central Snowmelt facilities
(SDN2 and SDE4).
-
The draft permit authorizes a mixing zone for discharges
of industrial wastewater into the Puget Sound, but the
fact sheet does not provide any data showing that the
discharges will not result in damage to the ecosystem.
This is a problem because the Midway sewage treatment
plant discharges through the same outfall.
- The
draft permit allows the Port to chemically treat its discharges
of construction wastewater, without imposing any safeguards.
The permit should place limits on the types and quantities
of chemicals that can be used, and should require the
Port to sample its construction stormwater for any chemicals
used.
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