PTI
ENVIRONMENTAL SERVICES
BELLINGHAM BAY
ACTION PROGRAM:
Initial Data Summaries and
Problem Identification
For
U.S. Environmental Protection Agency
Region 10 - Office of Puget Sound
Seattle, Washington
August 1989
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PTI
ENVIRONMENTAL SERVICES
BELLINGHAM BAY
ACTION PROGRAM:
Initial Data Summaries and
Problem Identification
For
U.S. Environmental Protection Agency
Region 10 - Office of Puget Sound
Seattle, Washington
August 1989
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ill Environmental Services
15375 SE 30th Place
Suite 250
Bellevue, Washington 98007
BELLINGHAM BAY ACTION PROGRAM:
INITIAL DATA SUMMARIES AND
PROBLEM IDENTIFICATION
by
D.S. Becker, R. Sonnerup, and JJ. Greene
For
U.S. Environmental Protection Agency
Region 10, Office of Puget Sound
EPA Contract 68-D8-0085
PTI Contract C744-03
August 1989
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CONTENTS
LIST OF FIGURES vi
LIST OF TABLES viii
LIST OF ACRONYMS x
ACKNOWLEDGMENTS xi
EXECUTIVE SUMMARY xii
INTRODUCTION 1
DECISION-MAKING APPROACH 3
OVERVIEW OF DECISION-MAKING FRAMEWORK 3
IDENTIFICATION AND EVALUATION OF KEY POLLUTANT INDICATORS 3
Chemical Contamination 6
Microbial Contamination 6
Eutrophication 6
INDICES OF CONTAMINATION 6
Chemical Contamination 7
Microbial Contamination 9
Eutrophication 9
IDENTIFICATION OF PROBLEM STATIONS 9
PHYSICAL SETTING 12
PROJECT LOCATION 12
CLIMATE 12
SHORELINE TOPOGRAPHY 12
PHYSICAL OCEANOGRAPHY 14
SURFACE DRAINAGE/LAND USE 15
BENEFICIAL USES 16
11
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Page
DATA SUMMARY: CONTAMINANT SOURCES 20
WASTEWATER TREATMENT PLANTS 20
Post Point WWTP 20
Former Whatcom Creek Waterway WWTP 25
WWTPs in the Nooksack Drainage 25
Areas Not Served by WWTPs 27
COMBINED SEWER OVERFLOWS AND EMERGENCY OVERFLOWS 28
SURFACE WATER RUNOFF 29
City of Bellingham 29
Nooksack River Watershed 29
Little Squaiicum Creek Watershed 30
Squalicum Creek Watershed 30
Whatcom Creek Watershed 30
Padden Creek Watershed ' 31
Chuckanut Creek Watershed 31
Bellingham Bay Watershed 31
Chuckanut Bay Watershed 32
Lummi Peninsula Watershed 32
Private Drains 32
GROUNDWATER 32
INDUSTRIAL SOURCES 33
Point Sources 33
Nonpoint Sources 37
Dredged Material Disposal Sites 40
ACCIDENTAL SPILLS 42
DATA SUMMARY: CHEMICAL CONTAMINATION OF THE WATER
COLUMN, SEDIMENTS, AND BIOTA 44
CHEMICAL CONTAMINATION OF THE WATER COLUMN 44
Data Synthesis 44
CHEMICAL CONTAMINATION OF SEDIMENTS 44
Data Synthesis of Conventional Sediment Variables 44
Data Synthesis of Toxic Chemicals 55
BIOACCUMULATION 72
SEDIMENT TOXICITY 73
Study Characteristics 74
Data Synthesis 74
in
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Paee
BENTHIC MACROINVERTEB RATES 78
Benthic Studies Prior to 1979 78
Benthic Studies After 1979 80
Data Synthesis 81
HISTOPATHOLOGY 85
DATA SUMMARY: MICROBIAL CONTAMINATION 90
DATA SYNTHESIS 90
Choice of Indicators 90
Available Data and Station Locations 90
Reference Data 95
Elevation Above Reference Analysis 96
DATA SUMMARY: EUTROPHICATION 99
DATA SYNTHESIS 99
Choice of Indicators 99
Available Data and Station Locations 99
DISSOLVED OXYGEN 99
NUTRIENTS ' 102
Nitrogen 102
Phosphorus 102
IDENTIFICATION OF PROBLEM STATIONS 105
CHEMICAL CONTAMINATION 105
MICROBIAL CONTAMINATION HI
EUTROPHICATION HI
IDENTIFICATION OF DATA GAPS AND RECOMMENDATIONS 112
CONTAMINANT SOURCES 112
INDICATORS OF CONTAMINATION 112
GEOGRAPHIC LOCATIONS 113
REFERENCES CITED IN TEXT 114
GLOSSARY 121
IV
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APPENDIX A - STATION DESCRIPTIONS AND CONCENTRATIONS OF SEDIMENT
CONTAMINANTS
APPENDIX B - SUMMARY OF SPILLS REPORTED TO THE U.S. COAST GUARD:
BELLINGHAM BAY ACTION PROGRAM
APPENDIX C - BIBLIOGRAPHY: BELLINGHAM BAY ACTION PROGRAM
APPENDIX D - NPDES PERMITS FOR DISCHARGERS IN THE BELLINGHAM BAY
AREA
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LIST OF FIGURES
Figure 1. Location of Beilingham Bay study area
Figure 2. Decision-making framework for evaluation of environmental degradation 4
Figure 3. Preponderance-of-evidence approach to evaluate toxic chemical
contamination, microbial contamination, and eutrophication in
Beilingham Bay 5
Figure 4. Depth distributions in and around Beilingham Bay 13
Figure 5. Locations of major recreational facilities in Beilingham Bay 19
Figure 6. Major contaminant sources in inner Beilingham Bay 21
Figure 7. Stations sampled in inner Beilingham Bay for sediment conventional
variables and chemical contaminants 46
Figure 8. Stations sampled in outer Beilingham Bay for sediment conventional
variables and chemical contaminants 47
Figure 9. Distribution of percent fine-grained sediment in inner Beilingham Bay 50
Figure 10. Distribution of percent fine-grained sediments in outer Beilingham Bay 51
Figure 11. Distribution of percent TVS in inner Bellingham Bay 52
Figure 12. Distribution of percent TVS in outer Bellingham Bay 53
Figure 13. Distribution of percent TOC in inner Bellingham Bay 54
Figure 14. Maximum EAR for individual organic compounds in inner Bellingham Bay 65
Figure 15. Distribution of mercury EAR in inner Bellingham Bay 66
Figure 16. Distribution of mercury EAR in outer Bellingham Bay 67
Figure 17. Locations of stations sampled for sediment toxicity in inner Bellingham Bay 75
Figure 18. Distribution of EAR for amphipod mortality, in inner Bellingham Bay 77
Figure 19. Locations of stations sampled for benthic macroinvertebrates in inner
Bellingham Bay 82
Figure 20. Locations of stations sampled for benthic macroinvertebrates in outer
Bellingham Bay 83
VI
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Page
Figure 21. Distribution of significant benthic depressions in inner Bellingham Bay 87
Figure 22. Distribution of significant benthic depressions in outer Bellingham Bay 88
Figure 23. Locations of stations sampled for fecal coliform bacteria in water and
shellfish tissue from inner Bellingham Bay 93
^
Figure 24. Locations of stations sampled for fecal coliform bacteria in water and
shellfish tissue in outer Beilingham Bay 94
Figure 25. Percent of fecal coliform bacteria observations that violated the Class A
water quality standard 97
Figure 26. Locations of stations sampled for dissolved oxygen, nitrogen, and
phosphate in the water column 100
Figure 27. Monthly variation of dissolved oxygen concentrations averaged over the
period 1980-1988 ' 101
Figure 28. Monthly variation of nitrogen concentrations averaged over the period
1980-1988 103
Figure 29. Monthly variation of phosphate concentrations averaged over the period
1980-1988 104
Figure 30. Classification of stations in inner Bellingham Bay according to action-level
criteria 109
Figure 31. Classification of stations in outer Bellingham Bay according to action-level
criteria 110
vn
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LIST OF TABLES
Page
Table 1. Action-level criteria used for Beliingham Bay 11
Table 2. Summary of NPDES permit limitations for the Beliingham, Ferndale,
Lynden, and Everson wastewater treatment plants 22
Table 3. Toxic chemicals detected in wet weather and dry weather 24-hour composite
samples of the effluent from the Post Point pollution control facility 24
Table 4. NPDES-permitted discharges to the Beliingham sanitary sewer 26
Table 5. NPDES-permitted discharges to Beliingham Bay and streams that flow into
the bay 36
Table 6. Toxic chemicals detected in the leachate from the old Beliingham sanitary
landfill 38
Table 7. Beliingham harbor navigation project anticipated dredging requirements 41
Table 8. Summary of sediment grain size and volatile solids data 48
Table 9. Summary of organic compound concentrations in sediments from Puget
Sound reference areas 57
Table 10. Summary of metal concentrations in sediments from Puget Sound reference
areas 60
Table 11. Indicators of sediment chemical contamination for organic compounds in
Beliingham Bay ranked by EAR 61
Table 12.. EAR values for major detected organic compounds in Beliingham Bay 62
Table 13. Indicators of sediment chemical contamination for metals in Beliingham Bay
ranked by EAR 63
. Table 14. 1988 Puget Sound AET for selected chemicals 70
Table 15. EAR values for amphipod mortality in Beliingham Bay 76
Table 16. Characteristics of reference areas for benthic macroinvertebrate
assemblages 84
Table 17. EAR values for benthic macroinvertebrate taxa in Beliingham Bay 86
Table 18. Fecal coliform data and EAR values—Beliingham Bay and freshwater
tributaries 91
Vlll
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Page
Table 19. Station characteristics relative to problem area identification 106
Table 20. Problem stations and potential problem stations with respect to chemical
contamination in Bellingham Bay 108
IX
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LIST OF ACRONYMS
AET apparent effects threshold
BOD biochemical oxygen demand
COE U.S. Army Corps of Engineers
CSO combined sewer overflow
DSHS Washington Department of Social and Health Services
DW dry weight
EAR elevation above reference
Ecology Washington Department of Ecology
EDB ethylene dibromide
EOF emergency overflow
EPA U.S. Environmental Protection Agency
FCBI fecal coiiform bacteria index
FDA U.S. Food & Drug Administration
HAET highest apparent effects threshold
HPAH high molecular weight polycyclic aromatic hydrocarbons
LAET lowest apparent effects threshold
LPAH low molecular weight polycyclic aromatic hydrocarbons
MGD million gallons per day
MPN most probable number
NPDES National Pollutant Discharge Elimination System
PAH polycyclic aromatic hydrocarbons
PCB polychlorinated biphenyls
PCP pentachlorophenol
ppt parts per thousand
PSDDA Puget Sound Dredged Disposal Analysis
PSP paralytic shellfish poisoning
SCS suspended combustible solids
SEPA State Environmental Policy Act
TOC total organic carbon
TOX total organic halides
TPH total petroleum hydrocarbons
TS total solids
TSS total suspended solids
TVS total volatile solids
WAC Washington Administrative Code
WDF Washington Department of Fisheries
WPCC Water Pollution Control Commission
WW wet weight
WWTP wastewater treatment plant
ZID zone of initial dilution
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ACKNOWLEDGMENTS
This document was prepared by PTI Environmental Services under the direction of Dr.
Robert A. Pastorok of PTI for the U.S. Environmental Protection Agency (EPA) under Contract
No. 68-D8-0085. Mr. Michael Rylko of EPA and Dr. Lawrence McCrone of the Washington
Department of Ecology served as project monitors. Dr. Frances Solomon of the Washington
Department of Ecology was the Urban Bay Action Team Coordinator. Dr. Thomas Ginn served
as the PTI Program Manager.
The following members of the Bellingham Bay work group contributed to the development
of this report:
Jacqueline Anderson
Mike Brennan
Bert Brun
Dr. Doug Bulthuis
Michael A. Clausen
Mike Cochrane
Marc Crooks
Ed Dahlgren
Bruce Dierking
Don Ellis
Clare Folgelson
Jack Garner
Theresa Gemmer
Bill Geyer
Jim Humphreys
Walt Ingram
Tip Johnson
Arnie Klaus
Mike MacKay
Bill McCourt
Greg Mills
Mary Lou Mills
Patti Mullin
Becky Peterson
Pat Petuchov
Vallana Piccolo
Drew Sandilands
Paul Schissler
Art Stendal
Ken Thomas
Dirk Visser
Terry Ward
Mike Walsh
Bert Webber
Concerned Southside Citizens
Whatcom Chamber of Commerce
U.S. Army Corps of Engineers
Department of Ecology-Padilla Bay Research Reserve
Bellingham Cold Storage
Lummi Fisheries
Washington Department of Ecology
Georgia-Pacific
Bellingham Yacht Club
Port of Bellingham
Concerned Southside Citizens
Bellingham Public Works
Concerned Southside Citizens
Planning and Economic Development-Bellingham
Washington Sea Grant
Bellingham Parks Board
Bellingham City Council
Puget Sounders
Lummi Fisheries
Bellingham Public Works
North Cascades Audubon Society
Washington Department of Fisheries
Washington Sea Grant
Whatcom County Council of Governments
Nooksack Fisheries
Puget Sound Water Quality Authority
Inner Sound Crab Association
Fairhaven Neighbors
Washington Department of Wildlife
Bellingham Public Works
Inner Sound Crab Association
Citizen
Puget Sound Gillnetters Association
Huxley College, Western Washington University
XI
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EXECUTIVE SUMMARY
STUDY OVERVIEW
The U.S. Environmental Protection Agency and the Washington Department of Ecology are
sponsoring the Bellingham Bay Action Program. The goals of the program are to 1) protect the
Bellingham Bay ecosystem against further degradation associated with anthropogenic inputs of
pollutants, 2) identify degraded areas of the bay that are amenable to remedial actions, and 3)
protect important resources from contamination. The primary objective of this report is to support
the development of the Bellingham Bay Action Plan by assessing the severity and spatial extent of
environmental degradation in the bay, and ranking specific problem areas in terms of priority for
evaluation of remedial action.
The results of this report are based on a synthesis of information collected largely between
1980 and 1989. To achieve the objective of the report, the following four questions were addressed;
• Are parts of Bellingham Bay degraded as a result of chemical contamination,
microbial contamination, or eutrophication?
• Does any observed chemical contamination, microbial contamination, or eutrophica-
tion result in adverse biological effects?
• Does any observed chemical or microbial contamination result in potential threats
to public health or resource utilization?
• Can the sources of any observed chemical contamination, microbial contamination,
or eutrophication be identified?
DECISION-MAKING APPROACH
Information on the spatial extent and severity of environmental degradation in Bellingham Bay
was examined within a decision-making framework to prioritize areas for remedial action. The
framework allowed a large amount of detailed environmental information to be organized so that
the data can be readily used by regulatory decision-makers and easily updated. The decision-
making approach used for Bellingham Bay was similar to the approaches used earlier in action
programs for Elliott Bay, Everett Harbor, Budd Inlet, Sinclair Inlet, and Dyes Inlet.
Key environmental indicators that could be used to characterize the spatial extent of
environmental impacts were identified for each pollutant category. The various indicators were
then used to develop indices of contamination and biological effects that were based on compari-
sons with either reference conditions for Puget Sound or regulatory standards and criteria. Finally,
the values of these indices of contamination and biological effects were used to identify and rank
problem areas for potential remedial action.
Xll
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Each environmental indicator used in the decision-making framework to characterize each
pollutant category was selected for the following reasons:
• It was known to be adequately sensitive to contamination
• It has been used in other action plans in Puget Sound
• It was represented by a sufficient amount of information in Bellingham Bay.
The indicators used to evaluate sediment chemical contamination included concentrations of
selected metals (i.e., arsenic, copper, lead, mercury, silver, and zinc) and organic compounds (i.e.,
high and low molecular weight polycyclic aromatic hydrocarbons and total polychlorinated
biphenyls). Sufficient data were not available to evaluate chemical contamination of the water
column. The biological indicators used to evaluate the potential effects of sediment chemical
contamination included the amphipod mortality bioassay using Rhepoxynius abronius, and in situ
depressions in the abundances of major taxonomic groups of benthic macroinvertebrates (i.e.,
Polychaeta, Mollusca, Amphipoda, and Crustacea other than Amphipoda). Although bioaccumula-
tion and fish pathology have been used as biological indicators in other urban bay action programs,
sufficient data were not available to evaluate these indicators in Bellingham Bay.
The indicators used to evaluate microbial contamination in Bellingham Bay included concen-
trations of fecal coliform bacteria in water and shellfish tissue. Although these bacteria are not
pathogens, they are commonly used as indicators of the potential presence of pathogens from
contamination by mammalian fecal material. The indicator used to evaluate eutrophication was
concentration of dissolved oxygen. If the concentration of dissolved oxygen is substantially reduced
as a result of eutrophication, adverse biological effects can occur.
IDENTIFICATION OF PROBLEM STATIONS
Chemical Contamination
Thirteen of the total of 66 stations evaluated for sediment chemical contamination were
considered problem stations. An additional 26 stations were classified as potential problem stations.
Mercury was found to be the major problem chemical in the sediments of Bellingham Bay. Most
of the stations considered to be problem stations or potential problem stations were identified as
such on the basis of either elevated mercury concentrations or depressions in the abundances of
benthic macroinvertebrates.
The 13 problem stations can be grouped into the following four problem areas:
• The mouth of Whatcom Creek Waterway (five stations)
• The area near the terminus of the Georgia-Pacific deepwater outfall (two stations)
• The area immediately inshore of the terminus of the Post Point wastewater treatment
plant outfall (five stations)
• A small area off the Fairhaven shoreline (one station).
xin
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The first three problem areas are located near potential sources of contamination, whereas the
fourth area is not located near an obvious potential contaminant source.
Most of the 26 stations classified as potential problem stations were located in a large group
that extended from the I&J Street and Whatcom Creek waterways along the eastern shoreline of
Bellingham Bay to Post Point and into the central part of the bay. Only two stations appeared to
be separate from the large group. The large group encompassed the four problem areas.
Microbial Contamination
Problem areas with respect to microbial contamination in Bellingham Bay were identified on
the basis of violations of the Washington state water quality standards and the FDA guideline for
tissues. For marine waters, the state standard was violated at two stations near the Georgia-Pacific
deepwater outfall. However, a large fraction of the bacteria could have been comprised of
Klebsiella, which is a fecal coliform bacteria that is often associated with pulp mill discharges but
is not specific to mammalian fecal pollution. The state standard was also violated five times
between 1980 and 1987 at a station near the Starr Rock dredged material disposal area and four
times during the same time period at a station near the Post Point WWTP outfall.
For fresh waters, the state standard was violated at all five stations evaluated in this study.
All of those stations were located at the mouths of the five major sources of fresh water to
Bellingham Bay (i.e., Nooksack River, Squalicum Creek, Whatcom Creek, Padden Creek, and
Chuckanut Creek).
For bacteria in shellfish tissue, the FDA guideline was violated on the basis of geometric mean
values at one station in Portage Bay. On the basis of individual shellfish, the standard was violated
at two stations in Portage Bay and at a single station off Post Point.
Eutrophication
Problem areas with respect to eutrophication in Bellingham Bay were identified on the basis
of violations of the Washington state water quality standard of 6.0 mg/L for marine waters.
Concentrations of dissolved oxygen were evaluated for only three stations in Bellingham Bay. The
state standard was violated at least one time since 1980 at all three stations. However, the total
number of violations during that period was highest for the station near the Post Point wastewater
treatment plant outfall (16 violations), lowest for the station near Pt. Francis (3 violations), and
intermediate in magnitude at the station near the Starr Rock dredged material disposal site.
IDENTIFICATION OF DATA GAPS AND RECOMMENDATIONS
Although a relatively large amount of information was reviewed for this report, a number of
important gaps were found in the historical database. A data gap was considered important if it
substantially limited the degree to which a comprehensive evaluation of environmental degradation
in Bellingham Bay could be conducted. In most cases, additional field sampling would be required
to collect this missing information.
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Contaminant Sources
Almost no information was found on contaminant input to Bellingham Bay from the Nooksack
River and storm drains. In addition, few environmental samples were collected near either of these
potential contaminant sources. The Nooksack River should be considered for future evaluation
because it drains a large area influenced by agricultural activities and several small communities.
In addition, the river is the major source of fresh water to the bay. Storm drains should be
evaluated because surface runoff from industrial and urban areas could sometimes contain
substantial concentrations and quantities of contaminants.
Indicators of Contamination
A relatively large amount of historical information was found for metals concentrations in
sediment and the abundances of benthic macroinvertebrates in Bellingham Bay. By contrast a
relatively small amount of information was available for other important indicators of contamina-
tion such as sediment concentrations of organic compounds in sediment, sediment toxicity,
bioaccumulation, and fish pathology. Additional information on these latter indicators would allow
a more comprehensive assessment of environmental degradation in the bay.
For chemical contaminants in general, vertical profiles of contamination at selected locations
in Bellingham Bay would be useful for evaluating whether subsurface sediments could cause
environmental problems if they were exposed by natural processes or anthropogenic activities.
Vertical profiles would also be useful for evaluating historical patterns and sources of contamina-
tion, temporal variability of contaminant concentrations in the environment, and the likely recovery
periods if present contaminant sources are controlled.
For organic compounds, additional stations should be located in areas of Bellingham Bay near
potential contaminant sources, using appropriate detection limits. In addition to sampling more
stations, a greater range of chemicals should be analyzed for, such as pesticides, dioxins, tributyltin,
and compounds characteristic of pulp mill discharges (e.g., alkylated phenols, guaiacols, and resin
acids).
For sediment toxicity, additional stations should be located in areas where chemical analyses
suggest that sediment toxicity may be a problem. It would be preferable if additional bioassays
(including a long-term test to assess potential chronic toxicity) were conducted in conjunction with
the amphipod mortality test, to evaluate other species that may be responsive to different con-
taminants than the amphipods.
For bioaccumulation, concentrations of mercury and PCB in muscle tissue of Dungeness crabs
and whole body tissue of edible bivalve molluscs should be measured in the more contaminated
areas of Bellingham Bay, to evaluate the risk to human health from consumption of contaminated
seafood. If problems are found for crabs and bivalve molluscs, surveys of bioaccumulation in
commercially or recreationally important fish should be considered.
xv
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Geographic Locations
Little information was found on contamination and biological effects in many nearshore areas
of inner Bellingham Bay. Because many of these areas are influenced by surface drainage, it is
recommended that they be prioritized with respect to the likelihood of contamination and that the
areas having the highest priority be evaluated.
Very little information on contamination and biological effects was found for Chuckanut Bay
and the entire northwest shoreline of Bellingham Bay, from Portage Bay to Little Squalicum Creek.
Except for the Nooksack River, there are no major potential sources of contaminants in these areas.
However, nonpoint contaminant sources may influence these areas. Water currents may also carry
contaminants into these areas. Therefore, a limited number of stations should be sampled at
representative locations in these areas to identify any potential environmental problems.
xvi
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INTRODUCTION
The U.S. Environmental Protection Agency (EPA) and the Washington Department of Ecology
(Ecology) are sponsoring the Bellingham Bay Action Program. The goals of the program are to 1)
protect the Bellingham Bay ecosystem against further degradation associated with anthropogenic
inputs of pollutants, 2) identify degraded areas of the bay that are amenable to remedial actions,
and 3) protect important resources from contamination. Remedial actions may include source
control activities (i.e., to reduce specific discharges of contaminants) and cleanup of contaminated
sediments. The primary objective of this report is to support the Bellingham Bay Action Program
by assessing the severity and spatial extent of environmental degradation in the bay, and ranking
specific problem areas in terms of priority for remedial action. The location of the Bellingham Bay
study area is shown in Figure 1.
The results of this report, based on a synthesis of information collected largely between 1980
and 1989, represent the conditions expected to be found in Bellingham Bay at the present time.
Information collected prior to 1980 was reviewed and summarized to provide an historical
perspective of environmental degradation in the bay. To achieve the objective of the report, the
following four questions were addressed:
• Are parts of Bellingham Bay degraded as a result of chemical contamination,
microbial contamination, or eutrophication?
• Has any observed chemical contamination, microbial contamination, or eutrophica-
tion resulted in adverse biological effects?
• Has any observed chemical or microbial contamination resulted in potential threats
to public health or resource utilization?
• Can the sources of any observed chemical contamination, microbial contamination,
or eutrophication be identified?
This report is divided into eight major sections. The first section describes the approaches
used to evaluate environmental degradation within Bellingham Bay. The reasons for choosing each
of the environmental indicators used in this report (e.g., chemical, water quality, ecological,
toxicological) are also discussed. The second section describes the physical setting of the bay,
including geographic location, climate, shoreline topography, physical oceanography, surface
drainage, land use, and beneficial uses. The next four sections summarize existing information on
contaminant sources, chemical contamination and associated biological effects, microbial contamina-
tion, and eutrophication. The seventh section identifies problem stations based on the environ-
mental indicators used in this report. The final section describes gaps in the existing database and
additional information needed to provide a more detailed evaluation of environmental degradation
in the bay.
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miles
0 1/2 1
I 0 1 2
I kilometers
Bellingham
Nooksack River'-
Lumml Bay [^
Lumml
:••' Peninsula ..&
.••••' Falrhaven
"Post
I Pt.
'•'. cviiii:-. Chucktnut Crr+i
Ptinage
Island.:/Pt. Frances
Governors s
Pt.
!?:^1 Eliza Island
Figure 1. Location of Bellingham Bay study area
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DECISION-MAKING APPROACH
Information on the spatial extent and severity of environmental degradation in Bellingham Bay
was examined within a decision-making framework to prioritize areas for remedial action. The
framework allowed a large amount of detailed environmental information to be organized so that
the data can be readily used by regulatory decision-makers and easily updated (Figure 2). The
decision-making approach used for Bellingham Bay was similar to the approaches used earlier in
action programs for Elliott Bay, Everett Harbor, Budd Inlet, Sinclair Inlet, and Dyes Inlet (Tetra
Tech 1985b,c, 1988a,b). The details of the decision-making framework and its application in
Bellingham Bay are provided below.
OVERVIEW OF DECISION-MAKING FRAMEWORK
The decision-making framework developed for the Bellingham Bay Action Program was based
on a "preponderance-of-evidence" approach to identifying problem stations associated with chemical
contamination, microbial contamination, and eutrophication (Figure 3). In addition, the decision-
making process allowed data gaps to be identified. The initial stage of the approach involved a
review of information concerning the potential sources of the three major kinds of pollution. The
results were used to identify potential problem areas within the bay. In the next stage, the available
physical, chemical, and biological data for each pollutant category were then reviewed. Key
environmental indicators that could be used to characterize the spatial extent of environmental
impacts were identified for each pollutant category. The various indicators were then used to
develop indices of contamination and biological effects based on comparisons with either reference
conditions for Puget Sound or regulatory standards and criteria. Finally, the values of these indices
of contamination and biological effects were used to identify problem stations for potential remedial
action.
IDENTIFICATION AND EVALUATION OF KEY POLLUTANT INDICATORS
The "environmental indicators used in the decision-making framework to characterize each
pollutant category (see Figure 3) are briefly summarized below, and described in detail in the
section entitled "Data Summaries." The information used for each indicator was subjected to a
quality assurance/quality control review to ensure that only data of acceptable quality were used
in the study. Generally, each indicator was selected for the following reasons:
• It was known to be adequately sensitive to contamination
• It has been used in other action programs in Puget Sound
• It was represented by a sufficient amount of information in Bellingham Bay.
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Review Available
Information
1
Identify Key Indicators of
Contamination and
Biological Effects
1
Identify Reference I
Conditions I
Compare Bellingham Bay
Sites with Reference
Conditions
1
Recommend
Preliminary Action-
Level Criteria
Identify Problem
Stations and Problem
Contaminants
Identify Data Gaps
Figure 2. Decision-making framework for evaluation of environmental degradation
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Pollutant
Categories
Key
Indicators
Toxic Chemical Contamination
Microbial Contamination
Eutrophication
Sediment Concentrations
Sediment Toxicity
Benthic Macroinvertebrates
Fecal ColKorm Bacteria In:
• SaltWater
• Fresh Water
• Shellfish Tissue
Dissolved Oxygen
Nutrients
Indices of
Contamination
Sediment Quality:
• Elevation Above Reference
• Apparent Effects Threshold
Sediment Toxicity:
• Amphipod Mortality
• Elevatbn Above Reference
Benthic Microin vertebrates:
• Taxon Abundance
• Depression Below Reference
Fecal Colilorm Bacteria
vs.
Reference Conditions
(Water Quality and Shellfish
Standards)
Station
Classification
Dissolved Oxygon
vs.
Water Quality Standards
Problem Station Definition
• Action-level Criteria
Problem Station Definition
• Violation of Standards
Identification of Data Gaps
Figure 3. Preponderance-of-evidence approach to evaluate toxic chemical contamination, microbial contamination, and
eutrophication in Bellingham Bay
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Chemical Contamination
The primary kinds of information on chemical contamination that were evaluated are as
follows:
• Chemical concentrations in water and sediment
• Chemical concentrations in tissues of organisms (i.e., bioaccumulation)
• Sediment toxicity as estimated by the amphipod mortality bioassay (i.e., an acute
lethal test)
• Alterations of benthic macroinvertebrate assemblages
• Pathological conditions in organisms.
A subset of these indicators (based on data availability) was used to identify and rank problem
areas.
Microbial Contamination
The occurrence of fecal coliform bacteria in marine water, fresh water, storm drain effluent,
and shellfish tissue indicates the presence of sewage-derived material from point and nonpoint
sources. Although these bacteria are relatively harmless, they are often associated with a variety
of bacterial and viral pathogens that can pose a public health risk. For this reason, the concentra-
tion of fecal coliform bacteria at each station was used as a key indicator of microbial contamina-
tion in Bellingham Bay. Data on concentrations of microbial pathogens were not found for
Bellingham Bay.
Eutrophication
The indicators used to characterize eutrophication in Bellingham Bay were concentrations of
nitrogen, phosphorus, and dissolved oxygen. The values of these indicators at any given time are
influenced by temperature, salinity, rainfall, tidal exchange, flushing rates, and other factors. The
concentration of dissolved oxygen at each station was used as a key indicator of eutrophication in
Bellingham Bay. Concentrations of nitrogen and phosphorus were simply described, as no water
quality criteria are. available for these variables.
INDICES OF CONTAMINATION
As a method of interpreting the raw data for the environmental indicators identified above,
indices of contamination were developed for each of the key indicators in the three major pollutant
categories (i.e., chemical contamination, microbial contamination, and eutrophication). These
indices were not used in place of the original data (e.g., contaminant concentrations), but in
addition to them. The original data were used to identify and characterize detectable levels of
contaminants and their effects on the environment. The indices were used to reduce large data sets
into interpretable station-specific numbers that reflect the relative magnitudes of the variables
throughout Bellingham Bay.
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Chemical Contamination
Indices of chemical contamination and associated biological effects for Bellingham Bay were
developed for chemical concentrations in sediments, sediment toxicity, and effects on benthic
macroinvertebrate assemblages. Although other action programs have used bioaccumulation and
fish pathology as additional key indicators of adverse biological effects, a sufficient amount of
information was not available for these indicators in Bellingham Bay.
Sediment Chemistry Indices— Two kinds of indices were used to characterize chemical
concentrations in sediments: elevation above reference (EAR) and apparent effects threshold
(A-ET). Because state sediment quality criteria are not yet available, these indices were used to
evaluate the degree of chemical contamination in Bellingham Bay.
EAR values were generated by comparing the concentrations of chemical contaminants
measured in sediments from Bellingham Bay with reference values found in Carr Inlet, a nonurban
embayment used as a reference area for other urban bay action programs in Puget Sound. Carr
Inlet was considered an appropriate reference area, because it is relatively uncontaminated and has
been surveyed for chemical contaminants using relatively low detection limits.
EAR values for chemical contaminants measured in Bellingham Bay were calculated using the
expression:
where:
EAR.J -
jj = EAR for sediment concentration of chemical i at station j
Cjj = Sediment concentration of chemical i at station j
Cir = Mean concentration of chemical i at reference area r.
An EAR. value greater than 1 indicates the concentration of a particular chemical in sediments
from a particular station in Bellingham Bay exceeds the average reference concentration for that
chemical in Carr Inlet. Statistically valid comparisons between these values would require replicated
sediment chemistry data to be collected in both the study and reference areas. Because sediment
chemistry samples generally are not replicated, the significance of an EAR value for a given
chemical was determined by comparing it with Puget Sound-wide reference data. If the
concentration of a given chemical in sediments from Bellingham Bay was greater than the maximum
concentration for that chemical in all Puget Sound reference areas, the EAR value for that chemical
was judged to be significant. It is possible to have EAR values greater than 1 (i.e., concentrations
that exceed the average values in Carr Inlet) that are not deemed to be significant because they fall
within the range of all Puget Sound reference areas.
AET values were used to determine the likelihood that the observed chemical concentrations
in sediments would result in adverse biological effects. AET values have been developed for a
wide variety of chemical contaminants in sediments throughout Puget Sound (Tetra Tech 1986;
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Barrick et al. 1988). AET values represent the chemical concentration above which a particular
biological effect has always been observed. To date, AET values have been developed for
reductions in the abundances of benthic infauna and for three kinds of sediment bioassays [i.e.,
amphipod mortality test, oyster larvae abnormality test, and Microtox test (i.e., a bioassay based on
reductions in bacterial luminescence)]. Comparisons of contaminant concentrations in Bellingham
Bay sediments with their corresponding AET values were used as one method of predicting the
presence of adverse biological effects in the bay. In addition, these comparisons were used to assist
in the identification of problem stations.
Biological Effects Indices— Biological effects indices for sediment toxicity and alterations of
benthic macroinvertebrate assemblages were developed using the EAR approach described above.
The EAR analysis for toxicity of Bellingham Bay sediments was based on available data for
mortality measured in the amphipod (Rhepoxynius abronius) sediment bioassay. The EAR index
was calculated using the expression:
EARj = Mj/Mr
where:
EARj = EAR for amphipod mortality at station j
MJ = Mean mortality at station j
Mr = Mean mortality at reference area r.
The reference area used in this analysis was Sequim Bay. Significance of the EAR values was
determined by statistical comparisons of individual bioassay responses to sediments from the study
area with the response to sediment from the reference area. Statistical significance was determined
using a comparisonwise error rate of 0.05.
The analysis of EAR values for alterations of benthic assemblages in Bellingham Bay was
based on available data for abundances of major taxa [e.g., Polychaeta, Mollusca, Amphipoda, and
Crustacea other than Amphipoda (i.e., Other Crustacea)]. The EAR indices were calculated using
the expression:
where:
EAR,,
= EAR for benthic indicator i at station j
Air = Mean abundance of taxon i at reference area r
Ay = Mean abundance of taxon i at station j.
The equation for benthic EAR indices was designed so the values for adverse responses (i.e.,
depressed abundances) would be greater than 1, and thereby be consistent with the indices used for
sediment chemistry and toxicity. The reference areas used in this analysis were specific to each
benthic survey evaluated and included Samish Bay and outer Bellingham Bay. Reference areas were
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selected to be as similar as possible to test stations in terms of conventional sediment variables
(e.g., grain size organic content), to minimize the potential confounding influence of the
conventional variables on effects related to chemical toxicity. Significance of EAR values was not
determined statistically, because more than half the data set was characterized by only two replicate
measurements. That level of replication was considered inadequate for statistical comparisons.
Instead, EAR values greater than 5.0 were considered significant. This value corresponds to an
abundance depression of 80 percent relative to reference values. This critical value was chosen
because past studies in Puget Sound have found that abundance depressions of a lower magnitude
generally cannot be consistently discriminated from reference values, given the inherent level of
variability of benthic abundances.
Microbial Contamination
The index of microbial contamination was based on concentrations of fecal coliform bacteria.
The EAR index was calculated as the ratio between the geometric mean concentration at a station
in Bellingham Bay and the Washington state water quality standard for the bay. The ratio was
structured so that the value of the index increased as the elevation above the water quality standard
increased. The fecal coliform bacteria index (FCBI) is expressed as:
where:
jj = Index for medium i (i.e., marine water, fresh water, or shellfish tissue) at station j
;J = Geometric mean concentration in medium i at station j
Water quality standard for medium i.
Regulatory standards for fecal coliform bacteria concentrations vary by medium (e.g., shellfish
tissue vs. water) and state classification of local waters.
Eutrophication
Potential effects associated with eutrophication were evaluated based on direct comparisons
of dissolved oxygen concentrations at stations in Bellingham Bay with Washington state water
quality standards. Dissolved oxygen was selected to represent the effects of eutrophication because
oxygen depletion may adversely affect biota.
IDENTIFICATION OF PROBLEM STATIONS
The environmental contamination and effects indicators (i.e., EAR values) were assembled in
a matrix format to facilitate comparisons among stations. These comparisons allow the decision-
maker to address the following questions:
• In comparison to a reference area, is there a significant elevation in sediment
contamination or biological effects at any station?
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• Which indicators are significantly elevated?
• What are the relative magnitudes of the indices (i.e., which indices suggest the
highest degrees of environmental degradation)?
Matrices were not used to evaluate microbial contamination and eutrophication because single,
rather than multiple, indicators (i.e., concentrations of fecal coliform bacteria and dissolved oxygen,
respectively) were used to identify problem stations. Evaluation of these data was therefore
relatively straightforward.
Information summarized in the matrix for chemical contamination was used to classify stations
according to likely environmental degradation problems. Classifications were made using the
action-level criteria provided in Table 1. The classifications were based on the degree of
significance of each individual indicator and the total number of indicators found to be significant
at a station. For example, a station could be considered a problem station if a single indicator
exhibited an unusually high degree of significance, or if two indicators at that station showed
moderate degrees of significance. Once problem stations were identified, their spatial locations
were evaluated to determine if they could be grouped into larger problem areas.
Problem stations for microbial contamination were defined as those stations where the
concentration of fecal coliform bacteria exceeded either the Washington state water quality standard
or the U.S. Food and Drug Administration (FDA) guideline for tissue.
Although concentrations of nutrients were available for the study area, only concentrations of
dissolved oxygen were used to identify problem stations for eutrophication in Bellingham Bay.
Elevated or depressed nutrient concentrations are not necessarily environmental problems. Problem
stations for eutrophication were defined as those stations where, at least once since 1980, concen-
trations of dissolved oxygen were less than the Washington state water quality standards.
10
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TABLE 1. ACTION-LEVEL CRITERIA USED
FOR BELLINGHAM BAY
Classification
Number of
Significant Indicators
Condition Observed
Problem station
Problem station
Potential
problem station
Chemical" concentration >HAETb or
Amphipod mortality >50% or
Benthic depression13 >95%
Chemical* concentration >LAETb and
amphipod mortality is significant', but <50%
Chemical concentration >LAETb and
benthic depressiond >80%, but <95%
Chemical* concentration >LAETb or
Amphipod mortality is significant', but <50% or
Benthic depression11 >80%, but <95%
a Any single metal or organic compound.
b HAET = highest AET for all Puget Sound indicators
LAET = lowest AET for all Puget Sound indicators.
c Significantly different (P<0.05) from reference area value.
d Any major taxon; abundance depression relative to value observed in reference area.
11
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PHYSICAL SETTING
PROJECT LOCATION
Bellingham Bay is a relatively large embayment located in the most northern part of Puget
Sound, approximately 24 km from the Canadian border (Figure 1). For the purposes of the present
study, the bay was bounded by a line drawn from Point Frances to Governors Point, and included
Chuckanut Bay and Portage Bay. Bellingham Bay is approximately 12 km long and 8-9 km wide.
Depths are relatively shallow and rarely exceed 30 meters (Figure 4). A large delta is located in
the northern part of the bay at the mouth of the Nooksack River. The delta extends approximately
2 km into the bay. The bottom of Bellingham Bay exhibits a gentle slope, and is comprised
primarily of fine-grained sediment. However, coarse-grained sediments are found off Post Point,
and substantial amounts of woody debris are found in sediments near the city of Bellingham.
Most of the urban and industrial activity in Bellingham Bay is confined to its northeast
corner near the city of Bellingham. The industrialized area closest to the city has been referred
to as inner Bellingham Bay, and has been influenced by extensive shoreline modifications (i.e.,
dredging, filling, bulkheading, and riprapping) to accommodate commercial and industrial uses.
The area includes three dredged industrial waterways (i.e., Squalicum Creek, I&J Street, and
Whatcom Creek waterways).
CLIMATE
The prevailing winds over Bellingham Bay are from the south. However, northeast winds are
frequently encountered between November and January. Wind speed averages 2-6 m/sec, and is
generally highest from the southeast between November and January (Shea et al. 1981).
Precipitation averages approximately 86 cm per year, and is highest between October and
April (Shea et al. 1981). At lower elevations, most of the precipitation occurs as rain. The
Nooksack River drains mountainous areas that experience considerable snowfall. The discharge
of this river peaks twice a year, once during the period of maximum rainfall and again during
early summer when the snow melts at higher elevations.
SHORELINE TOPOGRAPHY
The shoreline and beaches of Bellingham Bay range from steep rock faces to sand and mud
flats (Webber 1977). Along the east and west shorelines of the bay, beaches generally are narrow
and steep, and consist primarily of rock outcroppings and pockets of coarse sediment (Broad et al.
1984). In the northwestern part of the bay near the mouth of the Nooksack River, the shoreline
is characterized by broad sand and mud flats. In inner Bellingham Bay, the shoreline has been
extensively modified by dirt fill, riprap, bulkheads, and artificial lagoons. In the southern part of
the bay, narrow beaches comprised of coarse sediment are found at the base of the bluffs of the
Lummi Peninsula and Portage Island. Intertidal areas presently occupy approximately 42 km2 of
12
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Bellingham
Legend
-10— Depth in meters
kilometers
Figure 4. Depth distributions in and around Bellingham Bay
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Bellingham Bay (Webber 1977). Approximately 1.4 km2 of the original intertidal areas in inner
Bellingham Bay have been converted to upland areas.
The history of shoreline development within the city limits of Bellingham was reviewed by
Hitchman (1972). In 1853, the first industry a sawmill, was located on the bay at Whatcom Creek.
By 1910, Whatcom Creek Waterway had been dredged and much of the area around the head of
the waterway had been modified for street development.
In 1920, a port commission was created to manage development of the waterfront. In the late
1920s. Squalicum Creek Waterway was dredged and wharves were built to accommodate fishing
vessels. Breakwaters were added to this area in 1934. By 1958, the boat harbor on Squalicum
Creek Waterway had been expanded to accommodate 500 vessels and nearby land had been filled
for industrial use, which included a cold storage plant. In the early 1960s, additional dredging and
filling occurred in the Whatcom Creek Waterway to attract shipping and industry.
By 1970, the Port of Bellingham owned one-quarter (i.e., 2,000 acres) of the city shoreline,
500 acres of which were available for industries. In 1974, a sanitary landfill on the western side
of Whatcom Creek Waterway was filled and a diked lagoon was added to treat effluent from the
Georgia-Pacific lumber mill located across the waterway. In addition, a log pond on the Georgia-
Pacific property was filled with sediment dredged from Whatcom Creek Waterway.
In 1981, the Squalicum Harbor marina (between the Squalicum Creek and I&J Street water-
way) was expanded by dredging and filling intertidal areas. Currently, an area near Post Point is
being dredged and a docking facility built to accommodate the Alaska State Ferry System, which
will begin using the facility by 1990.
PHYSICAL OCEANOGRAPHY
The physical oceanography of Bellingham Bay has been extensively reviewed by Shea et al.
(1981) and Broad et al. (1984). Those authors discussed the results of numerous earlier studies,
including Driggers (1964), Collias et al. (1966), Collias (1971), Schumacher and Reynolds (1975),
CH2M HILL (1976), Parker (1977), U.S. Army Corps of Engineers (COE) (1977), and Webber
(1978).
Bellingham Bay is part of a complex of interconnected embayments that exchange water with
Rosario Strait through a network of channels and passages. Most oceanic water enters Bellingham
Bay at depth through the northern end of Rosario Strait between Lummi and Vendovi islands.
The mouths of Bellingham and Samish bays are interconnected, and water is exchanged between
the two embayments. Exchange of water through Hale Passage is limited by a shallow sill (i.e.,
<5-meter depth). The residence time of water in Bellingham Bay is typically 4-5 days, but can
vary between 1 and 11 days.
The major source of freshwater input to Bellingham Bay is the Nooksack River. Other sources
of freshwater are relatively minor, and include Little Squalicum, Squalicum, and Whatcom creeks
near Bellingham, Padden Creek near Fairhaven, and Chuckanut Creek near Chuckanut Bay.
An analysis of tide and current information revealed a southward flow from the bay at all
depths. However, surface flows exhibited wind-induced fluctuations. Winds are from the south
during most of the year, causing surface water to be retained in the northern part of the bay.
14
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When winds are from the west or southwest, surface water flows to the east and down the shoreline
past Post Point. When winds are from the north or northeast, surface water flows south along the
shorelines of Lummi Peninsula, Portage Island, and Lummi Island.
The water near the bottom of Bellingham Bay is similar in character to the water of Rosario
Strait. Bottom salinities, ranging from 29 to 31 parts per thousand (ppt), are relatively stable
throughout the year. Water temperatures range from 8 to 13° C, and are warmest during late
summer and early fall and coldest during winter and spring. The concentration of dissolved oxygen
varies throughout the year, generally lowest in summer and early fall and highest in winter.
Bottom currents are relatively slow (i.e., 0.1-0.2 m/sec).
The characteristics of water in the upper 10 meters of Bellingham Bay vary with depth and
time. Most of the variability is due to freshwater input and seasonal changes in air temperature.
Salinity is generally lowest in the northern part of the bay, near the mouth of the Nooksack River.
A 2-meter layer of brackish water is commonly found throughout the bay, but may deepen with
increasing wind velocity. Surface salinities typically range from 20 to 26 ppt, but may be as low
as 10 ppt when the influence of the Nooksack River is particularly strong. The water column is
usually isothermal from surface to bottom in late fall and early spring, but may be stratified during
other times of the year as a result of surface warming or cooling. As with bottom currents, surface
currents in Bellingham Bay are relatively slow (i.e., 0.2-0.3 m/sec).
SURFACE DRAINAGE/LAND USE
Bellingham Bay is influenced by drainage from eight watersheds (Creahan 1988). The largest
is the Nooksack River Watershed, which drains an area of approximately 1,500 km2. However, all
of the flow does not reach Bellingham Bay. Part of it enters Lummi Bay by way of the Lummi
River, which branches off from the Nooksack River below Ferndale. The river is the primary
source of sediment entering Bellingham Bay, with an average discharge of 650,000 m3 of sediment
per year (Kramer, Chin and Mayo 1977). The sediment load of the Nooksack River is influenced
by both natural (e.g., glacial scour) and anthropogenic factors. Major anthropogenic factors include
agriculture in the lower reaches of the river and logging in the upper reaches.
The Squalicum Creek Watershed drains an area of 65 km2 via Squalicum Creek and some
direct runoff into Bellingham Bay. The creek originates at Squalicum Lake, and flows through the
city of Bellingham into the bay. The city, therefore, occupies part of the watershed. The creek
is influenced by channelization, vegetation removal, and stormwater runoff.
The Chuckanut Bay Watershed drains an area of 34 km2 via Chuckanut Creek and direct
runoff into Chuckanut Bay. The watershed is occupied primarily by forested land, but some
residential and commercial areas are present. The watershed is minimally impacted by anthropo-
genic activities.
The Whatcom Creek Watershed drains an area of approximately 26 km2 via Whatcom Creek.
The creek flows from Lake Whatcom through the city of Bellingham into Bellingham Bay. The
city occupies much of the watershed, and the creek is strongly influenced by residential, commer-
cial, and industrial activities. Impacts have included channelization, vegetation removal, and
stormwater runoff. Fish kills have occurred in the creek on numerous occasions.
15
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The Gooseberry Point Watershed drains an area of 23 km* via direct runoff from the Lummi
Peninsula. Almost all of the watershed is located on the Lummi Indian Reservation. Most of the
watershed is occupied by forested land, but some residential, commercial, industrial, and agricul-
tural areas are present. The watershed is minimally impacted by anthropogenic activities.
The Padden Creek Watershed drains an area of 16 km2 via Padden Creek. The creek flows
from Lake Padden through a largely residential area, and enters Bellingham Bay near Post Point.
The creek is influenced, to some degree, by urban and industrial stormwater runoff.
The North Bellingham Bay Watershed drains an area of approximately 10 km2 via direct runoff
into Bellingham Bay. The watershed is occupied by urban, residential, industrial, agricultural and
forested areas. The watershed is influenced by stormwater runoff and leaking septic tanks.
The South Bellingham Bay Watershed drains an area of approximately 5 km2 via direct runoff
into Bellingham Bay. The watershed is occupied by residential and industrial areas as well as
public parks. The watershed is influenced by stormwater runoff.
BENEFICIAL USES
The beneficial uses of Bellingham Bay are defined as those activities that depend on the
environmental quality of the bay. These uses include commercial and recreational fishing, shellfish
harvesting, aquaculture, boating, and water contact recreation.
Bellingham Bay is used extensively by both anadromous and marine fishes (Shea et al. 1981).
The major kinds of economically important anadromous fish include the following:
• Coho salmon (Oncorhyncus kisutch)
• Chum salmon (Oncorhyncus ketd)
m Chinook salmon (Oncorhyncus tschawytscha)
m Pink salmon (Oncorhyncus gorbuscha)
m Sockeye salmon (Oncorhyncus nerka)
m Steelhead trout (Oncorhyncus mykiss)
m Cutthroat trout (Oncorhyncus clarkii)
m Dolly Varden (Salvelinus malma)
• Longfin smelt (Spirinchus thaleichthys).
All of the streams flowing into Bellingham Bay are used by one or more of the anadromous species
listed above. In addition, three salmon hatcheries are located in this area. One hatchery,
maintained by the Washington Department of Fisheries (WDF), is located on a tributary of the
north fork of the Nooksack River. Another hatchery, maintained by the Lummi Tribe on Skookum
Creek, contributes a substantial number of salmon to the Nooksack River. The third hatchery,
maintained by the Maritime Heritage Center, is located at the mouth of Whatcom Creek. A salmon
16
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holding pen operated by the Maritime Heritage Association is located in the Squalicum Harbor
marina (MacKay, M., 8 August 1989, personal communication).
During the late spring and early summer, juvenile salmon leave the streams and migrate within
1 km from the shore of Bellingham Bay (Sjolseth 1970). Although many juveniles migrate along
the shoreline of inner Bellingham Bay, most have historically avoided the inner portion of Whatcom
Creek Waterway (U.S. DOI 1967). Recreational fishing for salmon occurs in all nearshore waters
from the northwestern part of Bellingham Bay to Chuckanut Bay (CH2M HILL 1984). The total
commercial catch of salmon in Bellingham Bay in 1983 was approximately 2 million pounds, with
a value of SI.8 million (CH2M HILL 1984).
The major kinds of economically important marine fishes in Bellingham Bay include the
following:
• Pacific herring (Clupea harengus pallasi)
m Pacific cod (Gadus macrocephalus)
• Various rockfishes (Scorpaenidae)
• Lingcod (Ophiodon elongatus)
• Rock sole (Lepidopsetta bilineata)
• English sole (Parophrys vetulus)
• Starry flounder (Platichthys stellatus).
Except for the northwest corner of Bellingham Bay, the entire bottom of the bay is considered part
of the recreational fishery for marine fishes (CH2M HILL 1984). Pacific herring are valuable
primarily for the sac-roe fisheries they support. Commercial fishing for marine fishes occurs
primarily in the deeper water of the central part of the bay. The total commercial catch of marine
fishes other than salmon in Bellingham Bay was 830,000 pounds in 1983, with a value of almost
5300,000 (CH2M HILL 1984).
Shellfishing in Bellingham Bay is focused primarily on Dungeness crabs (Cancer magister),
Pacific oysters (Crassostrea gigas), and several species of clams, including the native littleneck clam
(Protothaca staminea), the Manila clam (Tapes japonica), the horse clam (Tresus capax), and the
butter clam (Saxidomus giganteus). The latter two clam species are harvested primarily as part of
a subsistence fisheries by the Lummi tribe (Cochrane and MacKay 1989). The remaining species
support commercial or recreational fisheries. The total commercial catch of shellfish in the bay in
1983 was 110,000 pounds, with a value of $150,000 (CH2M HILL 1984). Tribal commercial
harvest of Manila clams on tidelands of the Lummi Reservation has grown rapidly in recent years.
In 1988, over 162,000 pounds were harvested by tribal diggers (Cochrane and MacKay 1989). The
total annual value of all shellfish resources managed for commercial harvest by the Lummi Tribe
(including locations outside the study area) exceeds $500,000. Major tribal shellfish areas are found
in and around Portage Bay and Portage Island, and along the Lummi Peninsula.
Dungeness crabs occur throughout most of Bellingham Bay (CH2M HILL 1984). Harvesting
of oysters and clams occurs primarily near the southern part of the Lummi Peninsula and around
Portage Island. The Washington Department of Social and Health Services (DSHS) recommends
against recreational shellfish harvesting throughout most of inner Bellingham Bay because of
17
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potential chemical contamination. This recommendation is made for all urban bays in Puget Sound
(Lilja, J., 4 August 1989, personal communication).
Outbreaks of paralytic shellfish poisoning (PSP) are known to occur relatively frequently in
Whatcom County (Lilja, J., 4 August 1989, personal communication). The northern part of
Bellingham Bay has experienced outbreaks of PSP since the 1950s. DSHS monitors shellfish in
Bellingham Bay for PSP outbreaks on an infrequent basis. Records are kept of these outbreaks and
periods of beach closures related to PSP.
Although limited information is available regarding the presence of marine mammals in
Bellingham Bay, at least four species have been documented to occur in the vicinity of the bay
(Shea et al. 1981). These species include the harbor seal (Phoca vitulina richardsi), harbor porpoise
(Phocoena phocoena), killer whale (Orcinus orca), and gray whale (Eschrichtius robustus). Addi-
tional species that may occur in the bay on rare occasions include the California sea lion (Zalophus
californianus), northern sea lion (Eumetopias jubatus), Dall porpoise (Phoceonoides dallii), and
minke whale (Balaenoptera acutorostrata).
Bellingham Bay is not used extensively by large populations of waterfowl (Kraege, D., 7
August 1989, personal communication). However, the bay lies on the flight path between the
Fraser River estuary and Skagit Bay and is used as a stopover point for waterfowl migrating
between these two areas. These waterfowl include brant, snow geese, mallard, widgeon, green-
winged teal, and pintail. Bellingham Bay is also used as an overwintering area for diving ducks
such as scoter and golden eye.
A variety of public and private recreational facilities are located in the study area, primarily
in inner Bellingham Bay (Figure 5) (CH2M HILL 1984). The Port of Bellingham operates the only
major marina (Squalicum Harbor marina) in the study area. It is located between the Squalicum
and I&J Street waterways. Other boating facilities include the Hilton Harbor marina, the Central
Floats moorage, the Harris Street boat ramp, and the Boulevard Park boat ramp. A variety of
parks and public access points are located along the shoreline of the bay. The largest shoreline
park in inner Bellingham Bay is Boulevard Park near Fairhaven, which is operated jointly by
Whatcom County and the city and Port of Bellingham and includes 790 meters of shoreline. Other
parks in this area include Marine Park (183 meters of shoreline), Little Squalicum Park, and the
Maritime Heritage Center. Although the latter area is located on Whatcom Creek, it has direct
access to the bay near the mouth of the creek. Shoreline parks in outer Bellingham Bay include
the Fish Point Property (534 meters of shoreline), the Marine Drive Viewpoint (427 meters of
shoreline), and Portage Island Park (12,800 meters of shoreline).
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Bellingham
Park. -
1 Marine Park
2 Boulevard Park
3 Maritime Horilage Center
4 Little Squalicum Park
5 Fish Point Property
6 Manna Drive Viewpoint
7 Portage Island Park
Boating Facilities -
8 Haws Street Ramp
9 Boulevard Park Ramp
10 Central Floats Moorage
11 Hilton Harbor Marina
12 Squalicum Harbor Manna
0 1 2
kilometers
Figure 5. Locations of major recreational facilities in Bellingham Bay
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DATA SUMMARY: CONTAMINANT SOURCES
The variables used to evaluate the degree of environmental degradation in Bellingham Bay
were toxic chemical contamination of the water column, sediments, and biota; microbial contamina-
tion; and eutrophication. Information on potential sources of pollutants that may be contributing
to these problems was compiled. Potential pollutant sources were evaluated and mapped (Figure 6).
In general, potential sources consisted of the following six major categories:
• Wastewater treatment plants (WWTPs)
• Combined sewer overflows (CSOs)
• Surface water runoff
• Groundwater
• Industrial sources
• Accidental spills.
The findings of the potential source evaluations for each of the six major categories are presented
below.
WASTEWATER TREATMENT PLANTS
The city of Bellingham's Post Point WWTP has a National Pollutant Discharge Elimination
System (NPDES) permit to discharge primary wastewater into Bellingham Bay. In addition, the
secondary WWTPs of the cities of Ferndale, Lynden, and Everson have NPDES permits to discharge
into the Nooksack River. Permit limitations for these facilities are listed in Table 2.
Post Point WWTP
The city of Bellingham's current WWTP began operations in 1974, and is located in southwest
Bellingham just east of Post Point (Figure 6). The Post Point WWTP treats domestic sewage from
approximately 80 percent of Bellingham's population of 60,000 (CH2M HILL 1984). Presently, the
Post Point WWTP collection system is mostly separated from the storm sewer system, although some
surface runoff (such as from roof drains and unauthorized hookups) still combines with the sanitary
sewer system (McCourt, W., 22 February 1989, personal communication; Melcher, S., 13 March
1989, personal communication). The WWTP treats much of this surface water runoff during storm
events. However, if flows exceed the hydraulic capacity of the system, direct discharges to
Bellingham Bay can occur (e.g., through a CSO).
The Post Point WWTP was designed to provide primary treatment for an average flow of
18 million gallons per day (MOD) from July through December [canning season (i.e., when seafood
and vegetable processors are operating)] and an average flow of 12 MOD from January through
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Bellingham
01978-1982
354,000 yds3
N
I
miles
kilometers
Note: Letters on dredged
material disposal and fill
sites relate to descriptions
in text
LEGEND
Sanitary Sewer Outfall
/ Industrial Outfall
Storm Drain Outfall
— Streams Influenced by
Storm Drains
Combined Sewer Overflow
Former Sanitary Landfill
(~\ Dredged Material
Disposal Site
A Dredged Material Fill Site
Figure 6. Major contaminant sources in inner Bellingham Bay
21
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TABLE 2. SUMMARY OF NPDES PERMIT LIMITATIONS
FOR THE BELLINGHAM, FERNDALE, LYNDEN, AND
EVERSON WASTEWATER TREATMENT PLANTS'*
BODC
Facility
City of Bellingham,
Post Point WWTP
Ciiy of Ferndalc WWTP
City of Lyndon WWTP
Ciiy of Evcrson WWTP
Weekly Average
45 mg/L
3,3-40 kg/day
•45 mg/L
85 kg/day
45 mg/L
200 kg/day
45 mg/L
22 kg/day
Monthly Average
30 mg/L
2,225 kg/day
3D mg/L
57 kg/day
30 mg/L
135 kg/day
30 mg/L
15 kg/day
TSS
Weekly Average
45 mg/L
3,340 kg/day
110 mg/L
210 kg/day
45 mg/L
200 kg/day
45 mg/L
22 kg/day
d
Monthly Average
30 mg/L
2,225 kg/day
75 mg/L
143 kg/day
30 mg/L
135 kg/day
30 mg/L
15 kg/day
Fecal Colifc
Weekly Average
400 organisms/100 mL
400 organisms/ HK) ml.
500 organisms/ UK) nil.
400 organisms/100 mL
>rm Bacteria
Monthly Average
200 organisms/ 100 mL
2(XI cirgiiniMii.'./IIH) nil.
21KI org.iiii.sins/HKI ml.
200 organism*/ HX) mL
8 Each NPDES permit is included in Appendix D.
b All discharges must have a pH within the range 6.0-9.0.
c 5-day biochemical oxygen demand.
d Total suspended solids.
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June (non-canning season) (CH2M HILL 1984). The plant is designed to reduce canning and non-
canning season biochemical oxygen demand (BOD) effluent to less than 613 mg/L and 200 mg/L,
respectively, and canning and non-canning season total suspended solids (TSS) effluent to less than
240 mg/L and 200 mg/L, respectively. The maximum hydraulic capacity of the treatment plant
is 55 MGD (i.e., to accommodate high-flow periods), although the plant has handled flows up to
63 MGD (McCourt, W., 22 February 1989, personal communication). Presently, the average
canning and non-canning season flows are estimated at 9.8 MGD and 11.7 MGD, respectively. The
primary-treated effluent is discharged into Bellingham Bay via a 1.5-meter diameter outfall, which
terminates 610 meters west of the shoreline at a water depth of 25 meters. The final 130 meters
of the outfall line is a diffuser section with thirty-five 15-cm ports (CH2M HILL 1984). The city
of Bellingham Department of Public Works is planning to upgrade the Post Point WWTP's facilities
by 1993 to comply with the State Environmental Policy Act (SEPA) of 1971 (RCW 43.21C). These
upgraded facilities will be designed to provide secondary treatment at an average flow of 10 MGD.
The maximum hydraulic capacity of the secondary treatment system will be 37 MGD. Flows in
excess of 37 MGD and up to 60 MGD will be treated by the primary process only (McCourt, W.,
22 February 1989, personal communication).
Effluent from the Post Point WWTP' was sampled for inorganic and organic chemical
contaminants (Table 3) (CH2M HILL 1984). The wet weather (November-April) effluent samples
contained two organic contaminants and six metals above their respective method detection limits.
Seven organic compounds and all nine metals were detected in the dry weather (May-October)
effluent samples.
Based on the effluent limitations specified in the NPDES permit, the weekly average BOD and
TSS loading from the Post Point discharge cannot exceed 45 mg/L and 3,340 kg/day, respectively.
The monthly and weekly average fecal coliform counts cannot exceed 200/100 mL and
400/100 mL, respectively, and pH for this discharge must be within the limits of 6.0 to 9.0. In
August 1987, Ecology conducted a Class II inspection at the Post Point WWTP (Reif 1988).
Analyses of the effluent for BOD, TSS, fecal coliform bacteria, and pH indicated the facility was
in compliance with the NPDES permit limitations for all variables. Post Point WWTP operating
records from October 1982 through September 1984 revealed average dry weather and wet weather
TSS emissions of 1,690 kg/day and 1,871 kg/day, respectively. Average dry weather and wet
weather BOD emissions were reported at 4,527 kg/day and 3,126 kg/day, respectively. Average
daily pH values for this discharge period ranged from 6.3 to 7.3. The minimum pH value reported
was 4.3 (CH2M HILL 1984).
Industrial Discharges to the Post Point WWTP—The Georgia-Pacific pulp mill diverts all of
its domestic sewage to the Post Point WWTP. All of the industrial process waste from this facility
is treated and discharged through its own secondary treatment lagoon and deep-water discharge (see
Georgia-Pacific discussion Industrial Sources).
The Post Point WWTP treats wastes from various NPDES-permitted industrial discharges,
primarily from vegetable and fish processing facilities located along the Bellingham waterfront.
Prior to 1973, these industries discharged directly into the bay, but were hooked up to the sanitary
sewer when a shoreline interceptor was installed in 1973. In 1984, the city of Bellingham
conducted a survey of industrial operations having NPDES-permitted discharges of process
wastewaters to the Bellingham sanitary sewer (CH2M HILL 1984). At the time of the survey, the
list included 11 operations. All but Mt. Baker Plywood were fish or vegetable processing
operations. Currently, there are nine NPDES-permitted industrial discharges to the Post Point
23
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TABLE 3. TOXIC CHEMICALS DETECTED IN WET WEATHER AND
DRY WEATHER 24-HOUR COMPOSITE SAMPLES OF THE EFFLUENT
FROM THE POST POINT POLLUTION CONTROL FACILITY"
Chemical
Wet Weather
Effluent
Dry Weather
Effluent
Organic compounds (^g/L)
Bis(2-ethylhexyl)phthalate
Chloroform
Tetrachloroethene
Toluene
Pentachlorophenol
Hexachlorocyclohexane
PCB-1260
12
7
<5
<5
<2
21
6
4
9
14
0.04
0.53
Metals" (mg/L)
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
0.001
<0.005
<0.02
<0.01
0.012
0.37
0.01
<0.0002
<0.04
0.002
<0.001
<0.005
0.08
<0.001
<0.005
<0.001
0.01
0.01
1.4
0.005
0.0006
0.08
<0.005
0.004
0.01
0.09
a Wet weather period = November-April; dry weather period = May-October.
b Metals analyzed by the total metals digestion method.
24
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WWTP on file with Ecology. These industries include Bellingham Cold Storage, Bellingham Frozen
Foods, Sea-Pac Company, Inc., Seawest Industries, Schenk Seafood Sales, Dahl Fish Company, Inc.,
Brooks Manufacturing Company, the Oeser Company, and Mt. Baker Plywood. All permits on file
with Ecology expired in 1988, with the exception of permits from the two wood treatment facilities:
Brooks Manufacturing and the Oeser Company. Bellingham Frozen Foods has indicated it will
withdraw from the city's sanitary sewer system once secondary treatment begins in 1993. A
summary of the NPDES permit effluent limitations for these industries is presented in Table 4.
Stormwater Discharges to the Post Point WWTP—The volume of stormwater discharge to the
Post Point WWTP has been greatly reduced in recent years (Melcher 1987). These reductions have
been a result of major storm sewer separation projects in Bellingham's central business district,
northwestern residential core, and southern residential/commercial areas. These separation projects
were completed in the fall of 1986 (Melcher 1987). It is estimated that surface water runoff
presently accounts for 1-5 percent of the total wet-weather input to the Post Point WWTP (Melcher,
S., 13 March 1989, personal communication). The majority of this stormwater inflow is believed
to be from three major sources:
• Roof drains and catch basins in the central business district that are still connected
to the sanitary sewer
• A relatively small residential area in north Bellingham where several cross-
connections remain
• Unauthorized hookups to the sanitary sewer.
These sources contribute an estimated 10.7 MOD to the sanitary sewer for a 10-year storm
(Melcher 1987). In addition, runoff from the treatment plant at Brooks Manufacturing is permitted
under NPDES for discharge to the sanitary sewer. A summary of contaminant limitations for this
runoff is presented in Table 4.
Former Whatcom Creek Waterway WWTP
In 1882, the first sewers were installed throughout the developed areas of Bellingham. Most
of these sewers discharged directly into Bellingham Bay or into the Whatcom Creek Waterway. The
first primary treatment of these wastes began in 1947 with the construction of Bellingham's first
WWTP. This plant was located near the mouth of the Whatcom Creek Waterway and provided
primary treatment of sewage and urban runoff. The plant discharged into the shallow waters of
inner Bellingham Bay. Initially, the plant's capacity was 4.5 MOD, but was expanded in 1960 to
accommodate 11 MOD. This plant was abandoned in 1974, when its waste stream was diverted to
the Post Point WWTP (CH2M HILL 1984).
WWTPs in the Nooksack Drainage
Three secondary WWTPs discharge into the Nooksack River, which eventually flows into
Bellingham Bay.
25
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TABLE 4. NPDES-PERMITTED DISCHARGES TO THE
BELLINGHAM SANITARY SEWER'
Facility
Waste Description
Effluent Limitations5
Bellingham Cold Storage
Bellingham Frozen Foods
Sea-Pac Co., Inc.
Seawest Industries
Schenk Seafood Sales
Dahl Fish Co., Inc.
Mt. Baker Plywood, Inc.
The Oeser Company
Brooks Manufacturing Co.
Screened process wastewater
from fish processing
Screened process wastewater
from vegetable processing
Screened process wastewater
from fish processing
Screened process wastewater
from fish processing
Screened process wastewater
from fish processing
Screened process wastewater
from fish processing
Press pit oil/water subnatant
wastewater and boiler blow-
down
Sump drainage, cooling
water from wood treating
operations
Steam condensate and blow-
down
Treating plant runoff
Sump drainage, cooling
water from wood treating
operations
10.000 gpdc
2.0 MGD
3,000 gpd
70,000 gpd
8,500 gpdc
60,000 gpd
3,000 gpd
100 mg/L total oilsc
1.0 mg/L total phenolics0
100 mg/L total oilc
10 mg/L total oil
/L PCPC
100 mg/L total oilc
PCPC
a Each NPDES permit is included in Appendix D.
b Effluent limitations are listed as daily averages. All discharges to the Post Point WWTP must be
pH 6.0-9.0. PCP = pentachlorophenol.
c Effluent limitation is listed as a daily maximum.
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Femdale WWTP—The Ferndale WWTP discharges an average of 0.6 MOD of secondary-
treated effluent into the Nooksack River. The NPDES permit limitations of this discharge are
summarized in Table 2. The Ferndale municipal sewer serves a population of approximately 5,000
in and around the city of Ferndale. A majority of the storm sewers in Ferndale discharge directly
into the Nooksack River, although in some town segments the surface runoff is combined with the
sanitary sewer system. There are no NPDES-permitted discharges to the Ferndale WWTP on file
with Ecology. However, leachate from the Thermal Reduction Corporation incinerator facilities
and from the nearby Cedarville landfill is reportedly discharged to the Ferndale Sanitary Sewer
(Eley, J., 27 February 1989, personal communication).
Lynden WWTP—The Lynden WWTP discharges an average of 1.3 MOD of secondary-treated
effluent to the Nooksack River. The NPDES permit discharge limitations for this facility are
presented in Table 2. The Lynden sanitary sewer serves almost all of Lynden's population of
approximately 5,000. The storm sewer system in Lynden is separated from the sanitary sewer
system. Surface water runoff is discharged untreated to the Nooksack River. Shuksan Frozen
Foods, Inc. is the only NPDES-permitted discharge to the Lynden sanitary sewer. NPDES daily
maximum limitations for this discharge are 0.5 MOD, 4,080 kg/day BOD, 1,360 kg/day TSS, and
pH within the range of 6.0-9.0. Surface water runoff from these facilities has been found to
contain no detectable levels of ethylene dibromide (EDB), although EDB contamination in
groundwater is considered a problem in this area (Klimple, T., 27 February 1989, personal
communication; McKeon 1985). Considerable sanitary and process sewage from dairy farms is also
treated at the Lynden WWTP (Klimple, T., 27 February 1989, personal communication).
Everson WWTP—The Everson WWTP discharges an average of 0.2 MGD of secondary-treated
effluent to the Nooksack River. A summary of the NPDES permit discharge limitations is
presented in Table 2. The Everson sanitary sewer system serves a population of approximately
1,100 in Everson and, as a result of a recent plant upgrade, has expanded to include a portion of
the population of Nooksack. The storm sewer system in Everson is separated from the sanitary
sewer system and discharges directly into the Nooksack River. There are no known industrial
discharges to the Everson sanitary sewer system (Bowman, S., 28 February 1989, personal
communication).
Areas Not Served by WWTPs
Two major areas in the city of Bellingham are not part of the city's municipal sewer system.
Residential areas around north Chuckanut Bay and south of the lower Birchwood neighborhood
along Marine Drive (west of Squalicum Creek) are served primarily by septic systems. In
1980-1981, the Whatcom County Department of Health conducted a septic survey of the residential
district just beyond the Bellingham city limits along Marine Drive in response to complaints of
numerous septic system failures in that area (Kloc, B., 1 March 1989, personal communication).
Surface water from this area drains to the south onto the beach and into Bellingham Bay. At one
time, three out of four septic systems were contributing to high fecal coliform bacterial counts in
the area. Reportedly, sewage from these septic system failures was seeping onto the beaches and
into Little Squalicum Creek. Fecal coliform bacterial counts from drainage ditches in this area
were recorded in excess of 20,000 organisms/100 mL on several occasions. According to the
Whatcom County Department of Health, most of these problems have been corrected (Kloc, B., 1
March 1989, personal communication).
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COMBINED SEWER OVERFLOWS AND EMERGENCY OVERFLOWS
Discharges through CSOs generally occur during heavy rainstorms, when runoff exceeds the
hydraulic capacity of the combined sanitary and storm sewer system. When capacity is exceeded,
the excess flow is discharged to adjacent surface water bodies. This excess flow is often a mixture
of stormwater and untreated sewage. NPDES permits recently issued by Ecology require permittees
to use all reasonable measures to prevent or moderate CSO discharges and to submit a plan for
reducing CSO discharges by the greatest amount reasonable in the least amount of time.
In October 1987, the city of Bellingham Public Works Department submitted a review of CSO
discharges for the Bellingham sanitary sewer system in compliance with the requirements of
Washington Administrative Code (WAC) Chapter 173-245. Historically, overflows have occurred
at four locations in Bellingham: the "C" Street interceptor, the Oak Street pump station, the lower
Cornwall pump station, and the Post Point WWTP (Figure 6). Because of major storm sewer
separation projects in the central business district and in the northwestern residential and southern
residential/commercial areas of the city, overflows have not occurred at the Post Point WWTP since
1982 and at the Oak Street and lower Cornwall pump stations since 1984. The only remaining CSO
in Bellingham is at the "C" Street interceptor. The outfall for this CSO is at the same location as
the outfall from the old Whatcom Creek Waterway WWTP (Figure 6). In early 1987, a measuring
weir and level recorder were installed at the "C" Street CSO to measure flows. No overflows had
occurred by October 1987. However, four overflows have occurred since 1987: three in 1988 and
one in 1989 (as of 16 February 1989). The most recent documented overflow at the "C" Street
CSO occurred on 23 November 1986. This overflow lasted over 5 hours, discharging approximately
1.9 million gallons of combined sewage. Samples of this flow contained an average of 53 mg/L
TSS and 30 mg/L BOD for a total discharge of approximately 390 kg TSS and approximately
220 kg BOD into Bellingham Bay. Overflows at the "C" Street CSO have occurred at an average
rate of two per year since 1984 (Melcher 1987).
The sanitary sewage that flows through the "C" Street CSO contains virtually no industrial
wastes. Industrial wastes enter the sewer collection system's main line at the Oak Street pump
station, which is downgradient from the "C" Street CSO. As a result, industrial wastes could
overflow at the "C" Street CSO in only two situations: complete failure of the Oak Street pump
station or overflow of the Champion trunk. According to the Bellingham Department of Public
Works, these situations are highly unlikely and unprecedented, as two of the total of four pumps
are always in operation at Oak Street during periods of high flow, and the maximum expected flow
rate in the Champion trunk during storm events is less than half of its capacity (Melcher 1987).
Untreated sanitary sewage can also bypass the Post Point WWTP and discharge directly to
Bellingham Bay via emergency overflows (EOF). These overflows commonly occur as a result of
pump failures or power failures at pump or lift stations and generally are not a result of excess
stormwater runoff. These overflows have occurred at the Edgemoor, Flynn Street, and Birch Street
pump stations in the past. The Edgemoor EOF event was a result of a pump failure. There are
now two pumps at this station. The Birch Street EOF event was the result of a power failure, and
the Flynn Street EOF event was the result of vandalism. Historically, there have been problems
with overflows into Padden Creek and Whatcom Creek. The sources of these discharges have since
been eliminated (McCourt, W., 22 February 1989, personal communication).
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SURFACE WATER RUNOFF
Major sources of surface water runoff into Bellingham Bay are described in this section.
City of Bellingham
Surface water runoff in the Beliingham area from Little Squaiicum Creek to Post Point is
collected by Bellingnam's storm sewer system, which is almost entirely separated from the sanitary
sewer system. In 1978, the city of Bellingham conducted a survey of surface drainage patterns in
the area. This survey mapped the locations of storm drain lines and discharges within the city, and
revealed the locations of storm sewer outfalls discharging directly into Bellingham Bay. The
locations of these outfalls are indicated in Figure 6 (City of Bellingham 1978).
In addition, these maps revealed the presence of storm drain outfalls to the four creeks flowing
through the city of Bellingham. Two storm drains discharge to Little Squaiicum Creek. One drains
the streets adjacent to the Oeser Company wood treatment facilities. Four storm drains discharge
to Squaiicum Creek. These storm sewers primarily drain residential areas in Birchwood, Columbia,
and Cornwall Park residential areas. Forty-two storm drains discharge to Whatcom Creek. These
storm sewers drain the central business district, and the Sunnyland, Roosevelt, and Alabama Hill
residential areas. Two storm drains discharge to Fever Creek (a tributary of Whatcom Creek) from
streets adjacent to the Brooks Manufacturing Company wood treating facilities. No storm drains
discharge to Lake Whatcom. Thirteen storm drains discharge to Padden Creek. These storm sewers
drain the Fairhaven central business district and the Happy Valley, South, and Samish residential
areas. Storm drains discharging to Lake Padden and Chuckanut Creek were not surveyed. The
majority of the residential neighborhoods around Chuckanut Creek are drained by shallow ditches
(McCourt, W., 22 February 1989, personal communication).
Nooksack River Watershed
The Nooksack River Watershed drains approximately 1,500 km2 of primarily forested and
agricultural lands. Major nonpoint sources of contaminants to the river include agricultural and
urban runoff, failing septic systems, illegal dumpsites, runoff from logged areas, and leachate from
the Cedarville landfill. The major point sources to the Nooksack River are the Ferndale, Lynden,
and Everson WWTPs, discussed in the Wastewater Treatment Plants section. The monthly average
flow rate of the Nooksack River between July 1972 and September 1975 ranged from 1,500 to
8,000 ftVsec. Mean low flow for the Nooksack is 2,400 ftVsec. Mean high flows from storms and
snowmelt are 5,600 and 4,800 ft3/sec, respectively (U.S. COE 1979). The average discharge of
sediment at the mouth of the Nooksack has been estimated at 850,000 yd3/yr (Kramer, Chin and
Mayo 1977). The total sediment loading from the Nooksack River is expected to increase in the
future due to increased siltation from logged areas. In 1973, mercury concentrations measured
from various stream sediment sampling locations throughout the Nooksack drainage ranged from
0.03 to 0.84 mg/kg with a mean of 0.14 mg/kg (Babcock and Kolby 1973).
Agricultural runoff into the Nooksack River is primarily from dairy and berry farming
operations. Runoff from dairy farms is expected to contribute to the nutrient loading and fecal
coliform counts in the river at points downstream. Fecal coliform bacterial counts performed at
the mouth of the Nooksack River at Marine Drive from October 1983 through September 1984
ranged from 33 to 310 organisms/100 mL with a mean of 145 organisms/100 mL (CH2M HILL
29
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1984). Runoff from berry farming in Whatcom County has historically been implicated as
contributing low levels of EDB contamination into the Nooksack River. In addition, seepage of
EDB from contaminated groundwater to the river is a potential source of contamination. In a
groundwater survey conducted from June through October 1984, five of 35 public wells in Whatcom
County exhibited EDB contamination. Use of EDB as a soil fumigant was banned in 1983
(McKeon 1985).
Little Squalicum Creek Watershed
The Little Squalicum Creek Watershed includes areas that are primarily forested and
residential, with some industrial areas near the mouth of Little Squalicum Creek. The only
documented point sources to Little Squalicum Creek are two storm drain outfalls located just
beyond the Bellingham city limits. One of these sewers drain areas immediately adjacent to the
Oeser Cedar Company's wood treatment facilities. In addition, a small unnamed seasonal creek
runs adjacent to and receives considerable groundwater seepage from the Oeser Company's property.
Water samples taken by Ecology upstream and downstream of Oeser Cedar in 1978 indicated the
facility's influence on creek water quality is minimal (Prescott 1978). The Oeser Cedar Company
has an NPDES permit for discharge of plant runoff to Little Squalicum Creek. According to the
permit limitations, concentrations of total oil cannot exceed 15 mg/L and no detectable levels of
pentachlorophenol (PCP) can be present in this discharge. Current nonpoint sources of contamina-
tion to Little Squalicum Creek include logging, residential, and industrial runoff, and frequent
septic tank failures along Marine Drive. A sample collected in 1980 from the Marine Drive storm
sewer where it enters Little Squalicum Creek revealed fecal coliform levels as high as 55,000
organisms/100 mL. A sample collected on the same day at the mouth of Little Squalicum Creek
exhibited a fecal coliform count of 5,600 organisms/100 mL. Incidences of septic tank failures in
this area have reportedly been reduced by 90 percent since 1980 (Kloc, B., 1 March 1989, personal
communication).
Squalicum Creek Watershed
The Squalicum Creek Watershed covers a total of 65 km2. These lands are primarily forested,
but contain agricultural, residential, commercial, and industrial areas near the mouth of Squalicum
Creek. The only point sources to Squalicum Creek are four storm drain outfalls located within the
city of Bellingham. These outfalls drain primarily residential areas. Current nonpoint sources to
Squalicum Creek include urban and industrial runoff and septic tank failures. Monthly water
samples taken at the head of the Squalicum Creek Waterway from October 1983 through September
1984 revealed fecal coliform counts ranging from 11 to 1,300 organisms/100 mL with a mean of
285 organisms/100 mL (CH2M HILL 1984).
Whatcom Creek Watershed
The Whatcom Creek/Lake Whatcom Watershed covers an area of approximately 293 km2.
Approximately 109 km2 of this area are forested, with the remainder in urban, residential,
commercial, and industrial development. Primary point sources to Whatcom Creek include 42 storm
drain outfalls draining residential and some commercial and industrial areas. Primary nonpoint
sources in the Whatcom Creek Watershed include urban, industrial, and logging runoff; powerboats;
marinas; septic tank failures; and runoff and leachate from several abandoned landfills near the
30
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mouth of Whatcom Creek (Creahan 1988). Surface water runoff from the Brooks Manufacturing
Company's wood treating facilities drains to storm drains discharging to Whatcom Creek and
directly into Fever Creek, a small tributary of Whatcom Creek. The Brooks Manufacturing
Company has an NPDES permit for discharge of storage area runoff directly to Whatcom Creek.
According to the permit limitations, concentrations of total oil cannot exceed 15 mg/L and no
detectable levels of PCP can be present in this discharge. Monthly water samples taken at the head
of the Whatcom Creek Waterway between October 1983 and September 1984 revealed fecal coliform
bacterial counts ranging from 11 to 2,200 organisms/100 mL with a mean of 660 organisms/100 mL
(CH2M HILL 1984).
Padden Creek Watershed
The Padden Creek Watershed occupies an area of approximately 16 km2. The area is primarily
residential, with some small commercial, agricultural, and forested areas. The only point sources
known to discharge to Padden Creek are 13 storm drain outfalls within the city of Bellingham.
These outfalls primarily drain residential and commercial areas. Current nonpoint sources to
Padden Creek include urban, industrial, and commercial runoff and septic tank failures (Creahan
1988). Monthly water samples taken from Padden Creek near the Post Point WWTP between
October 1983 and September 1984 revealed fecal coliform bacterial counts ranging from 33 to 1,300
organisms/100 mL with a mean of 471 organisms/100 mL (CH2M HILL 1984).
Chuckanut Creek Watershed
The Chuckanut Creek Watershed occupies ah area of approximately 34 km2. This area is
primarily forested, with some smaller residential and commercial areas. There are no known point
sources to Chuckanut Creek. Current nonpoint contaminant sources include runoff from logged
areas, runoff from Interstate 5, residential runoff, and septic tank failures (Creahan 1988). Monthly
water samples taken at the mouth of Chuckanut Creek from October 1983 through September 1986
revealed fecal coliform bacterial counts ranging from 17 to 3,000 organisms/100 mL with a mean
of 558 organisms/100 mL (CH2M HILL 1984).
Bellingham Bay Watershed
The Bellingham Bay Watershed consists largely of shoreline areas extending from the Nooksack
River to Little Squalicum Creek (including Bellingham International Airport), from Whatcom Creek
to Padden Creek, and from Padden Creek to Chuckanut Creek. These areas cover a total of 16'km2
of commercial, industrial, forested, and agricultural land. Point sources to Bellingham Bay from
these areas include the Georgia-Pacific and Post Point outfalls, the "C" Street CSO, and storm
drains. Current nonpoint sources of contaminants to Bellingham Bay from the watershed area
include urban and industrial runoff, railroad runoff (creosote pilings), oil leakage, septic tank
failures along the north shore area (between the Nooksack River and Little Squalicum Creek), and
runoff from a slag pile at the Taylor Avenue dock (Creahan 1988). Water samples taken in 1980
from outfalls in Bellingham Bay from the Columbia Cement Corporation and from residential storm
sewers along Marine Drive exhibited fecal coliform bacterial counts as high as 4,000 organisms/
100 mL. A standing surface water sample taken on the same date along the railroad tracks
exhibited a fecal coliform bacterial count of 9,000 organisms/100 mL. At that time, 75 percent of
31
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the septic systems in the Marine Drive area were contributing to these high coliform counts (Kloc,
B., 1 March 1989, personal communication).
Chuckanut Bay Watershed
The Chuckanut Bay Watershed covers all nearshore areas from Chuckanut Creek to Governor's
Point. These areas are primarily forested with some residential development. There are no known
point sources of contaminants to Chuckanut Bay from this area. Current nonpoint sources to
Chuckanut Bay include residential runoff and runoff from Chuckanut Drive.
Lummi Peninsula Watershed
The Lummi Peninsula Watershed to Bellingham Bay includes all nearshore areas from the
Nooksack River to Point Frances, including Portage Island. These areas are primarily forested with
some residential development. The only documented source of contaminants to Bellingham Bay
from the Lummi Peninsula and Portage Island is storm drain outfalls from the Lummi Indian
reservation. Current nonpoint sources include residential runoff and septic tank failures (Creahan
1988). Most sewage in this area is treated by the secondary system of the Lummi Tribe and
discharged to Hale Passage, outside the study area (MacKay, M., 12 July 1989, personal communi-
cation).
Private Drains
There are numerous private drains that discharge into Bellingham Bay from residential areas
and businesses located along the shoreline. These outfalls may drain parking lots, storage yards,
tank farms, and piers. All properties owned by the Port of Bellingham have private storm drain
systems discharging to the bay. Reportedly, these sewers drain port parking lots, piers, and
rooftops (Ellis, D., 22 February 1989, personal communication). No storm sewers drain the
Georgia-Pacific plant site; runoff from the site is treated in the secondary treatment lagoon prior
to discharge into the bay.
Numerous private storm drains have been observed draining onto the beach and into
Bellingham Bay along the shoreline north of the city of Bellingham. These storm sewers primarily
drain the residential areas along Marine Drive from Little Squalicum Creek to the Nooksack River.
Samples taken from these outfalls in 1980 and 1981 by the Whatcom County Department of Health
revealed fecal coliform counts up to 20,000 organisms/100 mL. Since 1980, problems with septic
tank failures in this area have been largely eliminated (Kloc, B., 1 March 1989, personal communi-
cation). Because of a lack of documentation, private discharges to Bellingham Bay from other
portions of the study area were not characterized in this study.
GROUNDWATER
No studies defining groundwater characteristics in the study area have been identified to date.
As a result, the impact of groundwater discharge on Bellingham Bay's water quality is unknown.
However, with the prevalence of fill areas containing unknown materials, sanitary landfill materials,
32
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and contaminated dredge spoils on the Bellingham waterfront, groundwater seepage from these areas
may impact water quality in the inner harbor.
INDUSTRIAL SOURCES
The industrial sources of contaminants to Bellingham Bay discussed in this section are divided
into two categories: point and nonpoint sources. Point sources in the study area consist primarily
of NPDES-permitted outfall discharges and some unpermitted storm drains from private industrial
properties along the Bellingham shoreline. Nonpoint industrial contamination results from improper
contaminant handling, treatment, storage, and disposal practices. Locations of potential contami-
nant sources in the study area are shown in Figure 6.
Point Sources
Georgia-Pacific Corporation—In 1925, Pacific Coast Paper Mills began manufacturing tissue
paper in Bellingham. In 1928, Puget Sound Pulp and Timber Company began pulping operations
in this area. The facilities were located at the entrance to the Whatcom Creek Waterway, along
what is now Burlington Northern Railroad. This location provided access to sea and land
transportation and was adjacent to a large sawmill, which provided raw materials. During World
War II, the federal government constructed a plant to produce alcohol in support of the war effort.
This plant was purchased in 1947 by Puget Sound Pulp and Timber Company, and byproduct
recovery operations were initiated. By the 1960s, the company produced ethyl alcohol, animal feed
ingredients, adhesives, pharmaceutical raw materials, building compounds, and tanning chemicals.
Approximately 50 products were produced from the process waste at that time.
In 1963, Georgia Pacific purchased Puget Sound Pulp and Timber Company, which had
previously combined tissue and pulp manufacturing. At that time, the operation included calcium-
based sulfite pulping, semi-chemical pulping (i.e., a partial pulping process that does not remove
all lignin), by-product manufacture, paperboard production, and tissue production. In 1965,
Georgia-Pacific established a chlor-alkali plant that used salt and a mercury cell system to produce
chlorine (sodium hypochlorite) and caustic soda (sodium chlorate). A sodium chlorate facility was
also established on the plant site.
Currently, the mill produces two types of pulp: calcium-base sulfite and sodium-base semi-
chemical pump. The calcium sulfite uses an acidic sulfite liquor, and the semi-chemical process
uses a neutral sulfite liquor to convert wood chips into the pulp fiber used in the paper-making
process. In addition to these products, Georgia-Pacific produces a large number of by-products
from spent pulping liquor, including alcohol and lignin products. In addition, a small sulfuric acid
plant is located on the site.
Beginning in 1944, cooling water and wastewater from the alcohol plant were discharged via
the municipal storm sewer line. This discharge configuration was retained until 1973 (Shea et al.
1981). In 1963, Georgia-Pacific discharged process wastes through a single outfall into a log pond
and through five outfalls into Whatcom Creek Waterway. In 1964, the chlor-alkali plant began
discharging into the log pond via a new outfall.
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From 1956 to 1973, Georgia-Pacific operated under the Washington state Water Pollution
Control Commission (WPCC) permits governing discharge from the sulfite and semi-chemical
pulping processes, the tissue products plant, the paperboard mill, the sulfuric acid plant, and the
chlor-alkali plant. In 1968, these permits were extended until 1973 for all discharges excluding
that of the chlor-alkali plant. This permit was the first issued to Georgia-Pacific to require the
installation of primary treatment facilities and improved liquor recovery. This permit required that
a primary treatment system be in operation by September 1970 and required improvements in
liquor collection, dredging, and chip-barge unloading procedures, and the design of an outfall (Shea
et al. 1981).
In 1975, Georgia-Pacific was issued its first NPDES discharge permit. This permit called for
progressive reductions of BOD to 14,000 kg/day by 30 June 1978. This permit was later appealed
to the Pollution Control Hearing Board, resulting in a reissuance of the permit by Ecology with
new effluent limitations and compliance dates. EPA rejected this reissued permit and Georgia-
Pacific was ordered to comply with its original permit limitations. A compliance schedule issued
by the U.S. Department of Justice required installation of secondary treatment facilities and an
improved diffuser outfall by 15 May 1979. Secondary treatment and the outfall were operative by
8 May 1979.
Georgia-Pacific's chlor-alkali plant received its first discharge permit in 1964. The original
permit limited total waste flow to 5.3 MGD and chlorine content to 5.0 ppm. The subsequent
permits contained additional permit limitations, including maximum daily mercury discharge. In
1970, the total allowable mercury discharge was 0.5 pounds/day. By 1977, this limitation was
reduced to 0.1 pounds/day averaged over a calendar month (Shea et al. 1981).
From 1966 to April 1973, monthly averages for suspended combustible solids (SCS) and total
solids (TS) averaged 31,220 pounds/day and 834,234 pounds/day, respectively. After installation
of primary treatment facilities designed to remove all floating and settleable solids, these monthly
averages decreased to 16,470 pounds/day SCS and 580,833 pounds/day TSS from May 1973 to
May 1975. During the period from 1 July 1978 to June 1979, BOD waste loads in Georgia-Pacific
effluent averaged 79,500 pounds/day. After startup of the aerated stabilization lagoon for
secondary treatment in 1979, BOD waste loads were brought within the 31,000 pounds/day effluent
limitations (Shea et al. 1981).
Since 1979, all of Georgia-Pacific's eight former outfalls have been combined and rerouted
across the Whatcom Creek Waterway into the aerated stabilization (secondary treatment) lagoon.
The discharge from the lagoon is released to inner Bellingham Bay through a deepwater outfall
(Figure 6). In August 1979, 4 months after the secondary treatment lagoon became operational,
Ecology conducted a Class II inspection at Georgia-Pacific's pulp and chlor-alkali facilities
(Yake 1979). At that time, NPDES permit limitations for BOD, TSS, and pH were
22,500 pounds/day, 35,300 pounds/day and between 5.0 and 9.0, respectively. Georgia-Pacific
facilities were well within compliance of these limitations. However, leakage was observed in the
lagoon retaining walls, particularly around the discharge line. At that time, Georgia-Pacific's daily
average mercury discharge limitation was 0.07 pounds/day. Mercury discharge from the chlor-
alkali facility was measured at 0.05 pounds/day. However, mercury loading in the total plant
effluent was measured at 0.82 pounds/day. The source of this additional mercury was assumed
to be partially a result of the use of mercury-contaminated sodium hydroxide in the pulping
process. In addition, a small unidentified discharge in the log pond area was noted during low tide.
A sample from this discharge was found to contain 71 ^g/L mercury (Yake 1979).
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Presently, Georgia-Pacific's NPDES effluent limitations for BOD, TSS, pH, and total mercury
are 41,300 pounds/day, 62,600 pounds/day, between 5.0 and 9.0, and 0.05 pounds/day, respectively.
During a March 1988 Class II inspection of Georgia-Pacific's facilities, BOD and TSS effluent
loadings were measured at 17,477 pounds/day and 45,103 pounds/day, well within permit
guidelines. The effluent pH was well within the range specified, and total mercury discharge was
measured at 0.016 pounds/day, also well in compliance (Ecology 1988).
Georgia-Pacific's chlor-alkali plant began operation in 1965, using a mercury-cell process to
produce chlorine and caustic soda from sodium chloride. Process wastewater from this plant was
contaminated with mercury from the mercury-cell process. Until March 1973, the chlor-alkali
plant discharge was not routinely monitored. A recovery and recycle system was installed in 1970
and upgraded in subsequent years. A permit issued on 16 March 1973 limited mercury discharges
to 0.2 pounds/day on a monthly average. Monitoring data demonstrated compliance with this
limitation (Dahlgren, E., 30 June 1989, personal communication). A new permit issued on 16
February 1977 limited mercury discharge to 0.1 pounds/day until 30 June 1977, when the limitation
was reduced to 0.07 pounds/day on a monthly average. From January 1976 to May 1979, only two
violations of the limitation occurred. A new permit issued on 27 June 1985 limited mercury
discharge to 0.05 pounds/day on a monthly average. No violations of that limitation have occurred
since permit issuance (Dahlgren, E., 30 June 1989, personal communication). The current
discharges average 0.01 pounds/day.
Other Discharges—A summary of NPDES-permitted discharges to Bellingham Bay and streams
that flow into the bay is presented in Table 5. In the past, a number of small industries in
Bellingham, primarily fish and food processors, have discharged untreated process wastewater
directly into inner Bellingham Bay. In 1974, a minimum of 23 industrial facilities was discharging
wastewaters to Bellingham Bay (Shea et al. 1981). By 1981, diversions of process wastes to the Post
Point WWTP and the Lynden WWTP reduced the number of industries discharging directly to
Bellingham Bay to 15 (not including Georgia-Pacific). Of these, 12 were industries related to food
processing. These discharges were primarily process wastes from the food processing operations.
From the late 1960s until hookup with the Post Point WWTP, both the vegetable- and fish-
processing industries used a 0.25-inch mesh screen for solids removal before discharging into the
bay (Shea et al. 1981).
By 1981, only five fish processors in Bellingham continued to discharge noncontact cooling
water into the bay. They include Sea-Pac Company, Inc., Dahl Fish Company, Bumble Bee,
Bernstein, and Bellingham Cold Storage. To date, only two food processors, Dahl Fish Company
and Bellingham Cold Storage, have NPDES permits on file with Ecology for discharge of noncon-
tact cooling water directly into Bellingham Bay (Shea et al. 1981).
The remaining three industrial discharges were from the R.G. Haley Company (wood
processing, now defunct), the Columbia Cement Corporation, and the Olivine Corporation. R.G.
Haley's discharges were strictly noncontact cooling water. Prior to 1975, the Oeser Company
discharged industrial wastewater containing phenol and oils up to the allowable maximum
concentration of 5 mg/L and 10 mg/L, respectively. Currently, Oeser's wastewaters are diverted
to the Post Point WWTP. From 1970 through 1975, Mount Baker Plywood discharged process
wastewater to Bellingham Bay through a lagoon and seepage pond for settling of solids and glue
wastes. Seep samples taken in 1971 opposite the dike separating the seepage pond from Bellingham
Bay exhibited total oils up to 1 mg/L phenols to 0.30 mg/L and pH up to 9.0 (Baumer 1971).
During a 1973 Ecology inspection, the pH of this effluent was measured at 10.3, with 1 mg/L total
35
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TABLE 5. NPDES-PERMITTED DISCHARGES
TO BELLINGHAM BAY AND STREAMS THAT
FLOW INTO THE BAY"
Permit Holder
Bellingham Cold Storage
Sea-Pac Co., Inc.
Dahl Fish Co., Inc."
Columbia Cement Corp.
The Oeser Companyc
Brooks Manufacturing
Cod
Public Utility District #1*
Bellingham Hatchery'1
Nooksack State Salmon
Hatchery1
Permit
Expiration Date
12 August 1988
22 July 1988
22 July 1988
2 March 1988
20 June 1989
20 June 1989
26 June 1992
30 June 1981
17 May 1988
Waste
Description
Cooling water
Cooling water
Cooling water
Process wastewater
Plant runoff
Storage area runoff
Decant water
Hatchery effluent
Tailings water
Permit
Limitations
58,000 gpd, 30' C
5,000 gpd
24,000 gpd
130,000 gpd, 0.005 Ib TSS
pH 6-9
15 mg/L total oil
pentachlorophenol undetected
15 mg/L total oil
pentachlorophenol undetected
2.4 MOD
0.01 mL/L settleable solids
pH6-9
679 Ib/day TSS
pH6-9
27.4 MOD
15 mg/L TSS or 4,408 Ib/day TSS
a Each NPDES permit is presented in Appendix D.
b Discharge is to Whatcom Creek Waterway.
c Discharge is to Little Squalicum Creek.
d Discharge is to Whatcom Creek.
c Discharge is to the Nooksack River.
f Discharge" is to Kendall Creek, a tributary to the Nooksack River.
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oils and 0.024 mg/L phenols. The effect of this highly basic discharge on the receiving water was
considerable, as elevated pH values were still found at distances greater than 40 meters from the
point of discharge (Devitt 1973). In 1976, these process wastes were diverted to the Post Point
WWTP.
Currently, four private discharges into Bellingham Bay are registered with NPDES permits:
Dahl Fish Company Inc., Sea-Pac Company, Inc., Bellingham Cold Storage, and the Columbia
Cement Corporation. The three fish processing companies discharge noncontact cooling water to
the bay. The total permitted combined flow rate from these discharges is 138,000 gallons/day.
According to the permits, the maximum temperature of these discharges cannot exceed 30° C. The
Columbia Cement Corporation discharges process wastewater to Bellingham Bay with NPDES
permit limitations of 130,000 gallons/day flow, 0.005 pounds TSS, and pH between 6.0 and 9.0.
All four NPDES permits expired in 1988.
Dahl Fish Company, Bellingham Cold Storage, and Columbia Cement Corporation have re-
applied for their NPDES permits to Ecology (Kantz, M., 4 August 1989, personal communication).
This procedure extends the coverage of the existing permit until a new permit is issued. Sea-Pac
Company has not been operating since March 1989 and may not re-open.
Nonpoint Sources
Major potential nonpoint sources of contamination to Bellingham Bay are described in this
section.
Landfills—Landfills, both active and abandoned, in the Bellingham Bay drainage can be
sources of contaminants, either through surface water runoff or through leaching into the
groundwater flow. The Whatcom County Department of Health (Bader, D., 3 April 1989, personal
communication) identified five major solid waste sites that may be historical or ongoing sources
of contamination to Bellingham Bay. Only one of these sites is still active. Three of the sites are
former sanitary landfills located within the Bellingham city limits (Figure 6).
The Whatcom County courthouse is located on top of a former sanitary landfill. Leachate
from this landfill may be entering Whatcom Creek or Bellingham Bay through groundwater flow.
A city of'Bellingham sanitary landfill was located within the Georgia-Pacific secondary treatment
lagoon at the intersection of F Street and Roeder Avenue. After this landfill was closed, Georgia-
Pacific sprinkled water on the logs stored on this site. Much of this water leached through the fill
materials. Leachate from the landfill was collected in a pipe and discharged into Bellingham Bay.
A summary of the characteristics of the leachate is presented in Table 6. Reportedly, this pipe was
later diverted to the Bellingham sanitary sewer. The third former landfill site was located along
the shoreline just south of Georgia-Pacific and north of Boulevard Park. Leachate from this site
may enter Bellingham Bay. The dates of operation of these facilities were not available (Bader, D.,
3 April 1989, personal communication).
Two sanitary landfills in the Nooksack drainage were identified as having potentially
deleterious effects on Bellingham Bay via the Nooksack River. The former Lynden sanitary landfill
may be contributing contaminants to the Nooksack River via leachate flow. The Cedarville landfill
located just south of Deming is currently active, and may be contributing contaminants to the
Nooksack River via surface water runoff or leachate entering the groundwater (Bader, D., 3 April
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TABLE 6. TOXIC CHEMICALS DETECTED IN THE LEACHATE
FROM THE OLD BELLINGHAM SANITARY LANDFILL
14 MAY 1980
Organic compounds (/ig/L)
Chloroform 10
Phenols 30
Toluene 10
Diethylphthalate 10
Methylene chloride 10
Bis(2-ethylhexyl)phthalate 38
Vinyl chloride 0.1
Metals (mg/L)
Arsenic 6.0
Cadmium 1.9
Chromium 6.0
Copper 6.0
Lead 6.0
Nickel 36
Zinc 240
Mercury 0.87
Reference: U.S. EPA (1989)
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1989, personal communication). In addition, the Whatcom County Department of Health reported
a history of indiscriminant dumping in numerous small landfills on the Lummi Peninsula. These
landfills have since closed. Dates of operation and locations of these fills were not available (Bader,
D., 3 April 1989, personal communication).
Commercial and Recreational Marinas—The locations of recreational boating facilities in
Bellingham Bay are presented in Figure 5. In addition to these recreational facilities, a commercial
facility, Maritime Contractors Incorporated, is located west of the Harris Street boat ramp on Post
Point. Although these facilities are potential sources of contaminants, little information was found
that addresses these potential sources. Chemical contaminants (e.g., copper, tributyltin) could be
released when vessels are sandblasted and painted or from spills or leakage of fuel and oil.
Microbial contamination could arise from leaking holding tanks on the vessels or from unauthorized
releases of sewage. The only wet marina in the Bellingham Bay study area is the Squalicum Harbor
marina. This is a full-service marina that provides haulout, repair, painting, and sewage pumpout
facilities. There are live-aboards (people who occupy a boat as a residence) in this marina. The
Hilton Harbor marina provides haulout facilities, and only dry storage is offered at this location.
Boat owners are allowed to conduct repairs or paint their vessels on the marina property. There
is a gasoline dock at this marina. Maritime Contractors Incorporated is a commercial facility
specializing in the repair and conversion of ships and fishing boats. There are two drydocks and
a marine raise (a type of haulout device) at this facility.
Port of Bellingham—The Port of Bellingham owns and operates two dock facilities. One is
located just south of Georgia-Pacific, and the other is located at the Port of Bellingham Marine
Park near Fairhaven.
A new terminal is being built by the port to accommodate the Alaska State Ferry System.
This terminal is located on approximately 5 acres of land immediately west of the mouth of Padden
Creek near Post Point (Figure 1). Concern has been expressed that the construction of the facility
and operation of the ferries could expose and resuspend contaminated sediment as a result of pile
driving and sediment scouring by currents created as the ferries maneuver.
To address this concern, Landau Associates (1989) evaluated chemical concentrations in the
sediments near the ferry terminal. Samples were collected on 23 March 1989 at four sites in the
immediate vicinity of the ferry terminal that have the greatest susceptibility to sediment scouring.
Sediments were also sampled at two intertidal stations near the mouth of Padden Creek, in an area
that also may be influenced by sediment disturbance. At each station near the ferry terminal, a
diver collected a 3-inch core sample to a depth of 5 feet below the sediment surface. Three core
horizons (top 6 inches, bottom 6 inches, middle 4 feet) were composited across all four stations for
chemical analysis. At the two stations near the mouth of Padden Creek, the top 6 inches of
sediment was collected using a 2.5-inch diameter soil sampler. Samples from both of these stations
were composited for chemical analysis. All sediment samples were analyzed for 13 metals and a
variety of organic compounds, including polycyclic aromatic hydrocarbons (PAH), polychlorinated
biphenyls (PCB), phenols, total petroleum hydrocarbons (TPH), and total organic halides (TOX).
Results of the chemical analyses conducted by Landau Associates (1989) showed that
contamination was generally greatest in the top 6 inches of each sediment core. To determine
whether the observed concentrations might result in adverse biological effects, the authors compared
the observed values to the lowest apparent effects threshold (LAET) for each chemical. Briefly,
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the LAET is the concentration of each chemical above which adverse biological effects have always
been found in sediment samples collected from Puget Sound (for a more detailed explanation of
LAET, see section entitled Data Summary: Chemical Contamination of the Water Column,
Sediments, and Biota). LAET were available for all chemicals except beryllium, selenium,
thallium, TPH, and TOX. Because the detection limit for PCB (400 Mg/kg) was higher than the
LAET for this chemical (130 /ig/kg), comparisons to LAET could not be made for this chemical.
None of the chemical concentrations found in any horizon exceeded its corresponding LAET. The
only chemical concentrations that approached LAET were those for copper (31-269 mg/kg vs. an
LAET of 390 mg/kg) and mercury (0.20-0.30 mg/kg vs. an LAET of 0.41 mg/kg). The authors
concluded that there was no evidence that sediment contamination at the sampling sites was high
enough to justify sediment-specific mitigation during construction or operation of the ferry
terminal.
Dredged Material Disposal Sites
Since the turn of the century, extensive dredging and filling of the Whatcom and Squalicum
Creek tidelands has occurred almost continuously. As a result, over 200 acres of land have been
created for industrial and commercial activity along the Bellingham waterfront (Webber 1977).
Although the fill materials used in many of these areas are unknown, some areas have been
documented as dredged material fills and are shown in Figure 6.
Currently, the U.S. COE Bellingham Harbor navigation project is designed to maintain the
Squalicum Creek, I&J Street, and Whatcom Creek waterways to the project depths specified in
Table 7. Periodic dredging of these areas is necessary because of continual siltation of the
waterways. Historically, the primary source of sedimentation in the Whatcom Creek Waterway was
Georgia-Pacific. The estimated dredging frequency presented in Table 7 is based on the rate of
sedimentation from Georgia-Pacific prior to the implementation of secondary treatment/diffuser
outfall facilities. As a result of Georgia-Pacific's effective cessation of discharge to Whatcom
Creek Waterway, the actual dredging frequency in this area has been reduced (Arden, H., 27
February 1989, personal communication). The U.S. COE has no plans to dredge Whatcom Creek
Waterway in the near future.
The Whatcom Creek Waterway was first dredged in 1935, when 57,000 yd3 of material were
removed. Subsequent maintenance dredging occurred in 1940, 1942, 1949, 1953, and 1957. The
total material removed in these operations ranged from 5,200 to 92,000 yd3. In 1961, a major "new
work" dredging of 157,000 yd3 of material expanded the Whatcom Creek Waterway. The waterway
was again maintenance-dredged in 1966, when 24,000 yd3 of material was removed. The disposal
sites used for these operations are not known.
The latest U.S. COE dredging of Whatcom Creek Waterway occurred in 1969. This operation
used a submerged pipe dredge and disposed of 130,042 yd3 of dredged material in disposal site A
(Figure 6). These materials contained a large proportion of wood fibers and organic material.
Because of the contaminated nature of these dredged spoils, the U.S. COE has cancelled future
dredging in the Whatcom Creek Waterway (Arden, H., 27 February 1989, personal communication).
Georgia-Pacific dredged the inner waterway in 1974. Contaminated dredge spoils from this effort
were disposed of in a diked-off area (Site E, Figure 6) of the Georgia-Pacific log pond, aerated,
and then covered with an impervious asphalt cap (Arden, H., 27 February 1989, personal communi-
cation). Due to the contaminated nature of these sediments, Georgia-Pacific is required in their
NPDES permit limitations to maintain the impervious covering.
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TABLE 7. BELLINGHAM HARBOR NAVIGATION PROJECT
ANTICIPATED DREDGING REQUIREMENTS
Average Amount of
Material Removed
Waterway Project Depth Dredging Frequency for Dredging
Whatcom Creek 30 feet MLLW 10 years 110,000yd3
I&J Street 18 feet MLLW 10 years 50,000 yd3
Squalicum Creek 26 feet MLLW 10 years 170,000 yd3
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The primary source of siltation in the I&J Street and Squalicum Creek waterways is from the
Nooksack River. The majority of the Nooksack's sediment load is believed to be related to
agricultural and logging practices. Siltation from the Nooksack River is so rapid that current
theory is the delta is advancing at a rate of 1.6 km every 50 years. As a result, the U.S. COE
anticipates that the I&J Street and Squalicum Creek waterways will need periodic maintenance
dredging every 10 years. The average amount of materials needed to be dredged from the I&J
Street and Squalicum Creek waterways is anticipated to be 38,000 mj and 130,000 m3, respectively
(U.S. COE 1979).
The I&J Street Waterway was first dredged by the U.S. COE in 1966. A total of 147,800 yd3
of material was removed via clamshell dredge (U.S. COE 1979). The disposal site used for these
materials was Site B (Figure 6). Some materials were disposed of on mudflats north of Squalicum
Creek (Arden, H., 27 February 1989, personal communication).
The U.S. COE began its maintenance dredging program in the Squalicum Creek Waterway in
1931. The only other reported dredging performed in this area was in 1963. The amount of
material removed in these operations was 113,400 yd3 and 248,700 yd3, respectively. Dredge spoils
from the 1963 operations were disposed of in Site D (Figure 6).
In 1981, the U.S. COE diverted the mouth of Squalicum Creek from the inner tidal flats area
back to its original location in the Squalicum Creek Waterway. The tidal flats area was then
dredged to form the new small boat marina. Materials from this excavation were deposited in
Site F (Figure 6) to form a parking area for the new marina facilities.
A summary of past and proposed dredged material disposal sites in Bellingham Bay is
presented in Figure 6. Site A is the disposal site from the 1969 U.S. COE Whatcom Creek
Waterway dredge. Site B is the disposal site for the 1966 I&J Street Waterway dredging. Site C
is the disposal site from various maintenance dredging activities from all three waterways. Site D
is the disposal site from the 1963 Squalicum Creek dredging. Site E is the disposal site from
Georgia-Pacific's 1974 dredging of Whatcom Creek Waterway sludges. Site F is the disposal area
from the 1981 dredging of the inner marina.
The Puget Sound Dredged Disposal Analysis (PSDDA) program is currently evaluating a new
unconfined, open-water disposal site located west of Post Point in the central portion of Bellingham
Bay. The coordinates of the midpoint of the site are 48°42'49.08" N (latitude) and 122°33'1.80" W
(longitude). If the site is approved, dredged material that passes the PSDDA criteria for uncon-
fined, open-water disposal will be deposited there.
ACCIDENTAL SPILLS
Spills from vessels and facilities into Bellingham Bay reported to the U.S. Coast Guard between
1973 and 1988 are summarized in Appendix B. Although Ecology also maintains files of spills into
Puget Sound, little information was available for Bellingham Bay.
Only one detailed account of an accidental spill was found during this study. A spill occurred
on 1 January 1981 when a 10,000-gallon storage tank failed at the Brooks Manufacturing Company.
Oil was spilled into Fever Creek, a tributary of Whatcom Creek. The oil, containing 5-10 percent
PCB, discharged to Fever Creek via a storm drain. This oil was contained within Fever Creek with
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a sorbent boom. However, lowering of the creek's water level by the city of Bellingham Depart-
ment of Public Works allowed the oil spill to escape beneath the boom. This spill was estimated
to be responsible for the loss of 210 coho salmon, 25,311 fall Chinook salmon, 421 sea-run cutthroat
trout, 18,817 juvenile steelhead, and 10 adult steelhead (Ecology 1981).
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DATA SUMMARY: CHEMICAL CONTAMINATION OF THE
WATER COLUMN, SEDIMENTS, AND BIOTA
CHEMICAL CONTAMINATION OF THE WATER COLUMN
In this section, information is presented on chemical contamination of the water column in
Bellingham Bay.
Data Synthesis
No water quality data for chemical contaminants in Bellingham Bay were available for periods
after 1979. From July 1972 through June 1975, CH2M HILL (1976) evaluated water quality at
two-week (March-November) and monthly (December-February) intervals at eight stations near
the Post Point WWTP outfall. Samples were analyzed for copper, lead, zinc, and mercury to
evaluate the effects of the outfall discharge on these variables. Concentrations of these metals in
water samples from this area were frequently below analytical detection limits. The detection limits
for copper, lead, zinc, and mercury in these samples were 5, 10, 5, and 0.5 Mg/L, respectively.
Copper, lead, and zinc concentrations generally exhibited seasonal fluctuations in surface waters,
with slight increases found in early spring and again in the summer (CH2M HILL 1976).
Although the maximum concentration of copper detected in these samples was 20
concentrations of this metal were generally less than 10 Mg/L. Lead was detected at levels up to
100 Mg/L during summer, but concentrations were less than 10 Mg/L during fall and winter. Zinc
concentrations were generally below 20 Mg/L during most of the year, but increased to as much as
90 Mg/L in spring. Mercury concentrations were generally below the detection limit throughout the
year (CH2M HILL 1976).
The Washington state acute criteria (i.e., 1-hour average concentration) for copper, lead, zinc,
and mercury are 2.9, 140, 95, and 2.1 Mg/L, respectively (WAC 173-201-047). The state chronic
criteria (i.e., 4-day average concentration) for lead, zinc, and mercury are 5.6, 86, and 0.025 Mg/L,
respectively. There is no chronic criterion for copper.
CHEMICAL CONTAMINATION OF SEDIMENTS
Sediment conventional variables and chemical contamination of sediments in Bellingham Bay
are evaluated in this section. The station names used in this report correspond to the names used
by the original investigators in Appendix A, Table A-l. Station coordinates (if available) and
depths are also presented in Table A-l.
Data Synthesis of Conventional Sediment Variables
Since 1981, three conventional sediment variables have been measured in sediment samples
from Bellingham Bay: grain size, total volatile solids (TVS), and total organic carbon (TOC)
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(Figures 7 and 8). Grain size and TVS analyses were conducted at 26 stations in July 1983
(Battelle 1986), 22 stations in October 1983 (Broad et al. 1983), and 14 stations in October 1983
(CH2M HILL 1984). TOC was evaluated at eight stations in May 1984 (Battelle 1986).
Grain-Size Composition—Sediment grain-size distribution as measured by the three 1983
studies (Table 8) is presented as percent fine-grained sediment (i.e., silt plus clay) in Figures 9
and 10. In general, percent fines in Bellingham Bay was greater than 90 percent throughout much
of the bay. Percent fines generally decreased with increasing proximity to the Nooksack River
delta. No samples were taken close to the delta in the studies evaluated for this report. However,
Sternberg (1967) and Nelson et al. (1974) described the sediments in this area as delta platform
sands. Percent fines in samples taken from the vicinity of the Post Point WWTP outfall were
generally greater than 90 percent, with the exception of those samples taken within the zone of
initial dilution (ZID). Sediments in this area exhibited values of percent fines as low as 39.8
percent, indicating that sediment scouring may be occurring as a result of the outfall discharge.
The only other area to consistently show values of percent fines less than 80 percent was in the
Whatcom Creek Waterway. Percent fines in the inner waterway was measured at 48.4 percent. The
elevated sand content decreases with distance from the mouth of Whatcom Creek, and is interpreted
as being the result of the input of sandy sediments from the creek.
Total Volatile Solids—TVS is a measure of the fraction of TS in sediments volatilized at a
temperature of 550° C for 60 minutes, and is used as an indicator of the amount of organic
material in the sediment. Typically, high values of TVS (e.g., >10 percent) can be indicative of
anoxic sediments. A summary of TVS percentages measured in the study area is presented in
Table 8 and Figures 11 and 12.
TVS values measured in Bellingham Bay sediments in 1983 ranged from 1.2 to 17.5 percent.
In general, the highest TVS values were observed in and around the mouth of Whatcom Creek
Waterway. TVS values measured in sediments in the vicinity of the Post Point WWTP diffuser
outfall were not elevated over values observed in the inner-central bay. TVS values decreased with
increasing proximity to the Nooksack River delta and, as might be expected, were generally lower
in areas with coarser-grained sediments.
Total Organic Carbon—TOC analysis is a measure of the carbon remaining in a sediment
sample after it has been stripped of carbonates by acid pretreatment. Following decarbonation, the
sample is combusted in an induction furnace. The total amount of carbon dioxide evolved in the
combustion process is measured and used to calculate percent TOC. Values of TOC are used to
indicate the amount of organic material in a sediment sample. Values in most marine sediments
are less than 5 percent.
Values of TOC at the eight stations sampled in Bellingham Bay ranged from 2.0 to 12.2
percent (Table 8; Figure 13). The highest TOC values were found at Stations BA03 (12.2 percent)
and BA04 (4.8 percent) at the mouth of Whatcom Creek Waterway. TOC in sediments at the head
of the I&J Street Waterway (Station BA12) was 3.7 percent. Sediment samples taken west of
Boulevard Park (Station BA24) and north of the Port of Bellingham south terminal (Station BA23)
exhibited TOC values of 2.1 percent and 2.0 percent, respectively.
45
-------
Bellingham
•BR09 BR06««BA06
RE02
.HOS
15 \ •CH03
CH09
•CH10
Figure 7. Stations sarrpled in inner Bellingham Bay for sediment conventional variables and
chemical contaminants (All variables were not measured at every station)
46
-------
. Frances
BR20 BR21
fSti,^ Chuckanut Bay \
Figure 8. Stations sampled in outer Beilingham Bay for sediment conventional variables and chemical
contaminants.(All variables were not measured at every station)
-------
TABLE 8. SUMMARY OF SEDIMENT GRAIN SIZE
AND VOLATILE SOLIDS DATA
Station No.
BA01
BA02
BA03
BA04
BA05
BA06
BA07
BA08
BA09
BA10
BAH
BA12
BA13
BAH
BA15
BA16
BA17
BA18
BA19
BA20
BA21
BA22
BA23
BA24
BA25
BA26
BR01
BR02
BR03
BR04
BR05
BR06
BR07 '
BROS
BR09
BRIO
BR11
BR12
BR13
BR14
BR15
BR16
BR17
BR18
BR19
BR20
BR21
BR22
Gravel
(wt %)
0.0
0.2
6.2
3.1
0.0
0.0
1.5
0.0
0.0
1.4
0.0
0.0
19.2
0.0
1.2
13.7
0.0
0.0
0.3
0.2
26.5
0.0
0.0
0.0
0.2
2.6
0.0
0.0
3.5
0.6
0.0
0.0
0.1
1.3
0.0
1.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Sand
(wt %)
1.5
3.2
26.4
18.6
3.4
2.4
12.9
16.4
7.9
38.1
1.1
9.9
24.5
2.0
1.9
3.5
1.1
98.9
37.1
8.0
35.5
7.7
26.2
5.0
6.4
49.0
1.7
2.3
18.1
5.3
3.0
2.2
7.2
23.1
5.5
23.5
32.6
2.4
2.6
6.2
5.0
1.2
3.1
1.1
0.0
0.3
4.4
2.8
Silt
(wt %)
64.5
68.7
43.5
53.2
55.3
65.3
71.3
52.8
68.8
42.6
61.4
51.7
37.4
49.4
77.7
58.0
56.4
0.3
50.6
63.5
28.2
60.4
18.6
63.5
72.5
31.7
53.6
68.9
44.3
66.8
49.8
62.9
48.4
43.6
49.1
44.5
21.7
96.4
81.4
93.2
91.3
83.4
94.3
83.3
68.4
94.6
86.7
70.1
Clay
(wt %)
34.0
28.0
23.9
25.2
41.3
32.4
14.3
30.8
23.3
17.9
37.6
38.4
18.9
48.7
19.2
24.8
42.6
0.9
12.0
28.4
9.8
31.9
55.2
31.6
20.9
16.7
44.7
28.8
34.1
27.3
47.2
34.9
44.4
32.0
45.4
31.0
45.7
1.2
16.0
0.6
3.7
15.4
2.6
15.6
31.6
5.1
8.9
27.2
Fines
(wt %)
98.5
96.7
67.4
78.4
96.0
97.7
85.6
83.6
92.1
60.5
99.0
90.1
56.3
98.1
96.9
82.8
99.0
1.2
62.6
91.9
38.0
92.3
73.8
95.1
93.4
48.4
98.3
97.7
78.4
94.1
97.0
97.8
92.8
75.6
94.5
75.5
67.4
97.6
97.4
93.8
95.0
98.8
96.9
98.9
100
99.7
95.6
97.3
TVS
(wt %)
3.7
10.7
6.0
7.1
7.5
9.9
7.1
6.0
11.8
17.5
3.2
8.7
4.2
7.2
7.8
11.5
5.9
1.2
2.8
5.6
2.6
4.3
6.4
7.8
7.2
13.2
5.9
8.7
14.8
11.9
8.1
8.7
9.8
5.6
7.6
6.4
5.5
6.2
7.1
8.0
7.8
9.4
9.0
10.0
9.5
8.2
7.8
9.3
TOC
(wt %)
ND"
ND
12.2
4.8
2.3
ND
3.2
ND
ND
ND
2.1
3.7
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.0
2.1
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
48
-------
TABLE 8. (Continued)
Station No.
CHOI
CH02
CH03
CH04
CH05
CH06
CH07
CH08
CH09
CH10
CH11
CH12
CH13
CH14
Gravel
(wt %)
0.2
*) -1
^.*-
0.2
0.0
0.1
1.5
2.4
0.1
1.9
0.4
0.1
0.0
1.0
0.3
Sand
(wt %)
25.9
58.0
2:4
2.1
1.2
42.7
35.5
1.7
0.7
16.8
0.7
1.1
0.6
0.9
Silt
(wt %)
45.6
18.3
56.2
55.4
68.8
28.3
30.6
55.4
59.1
41.9
55.9
56.5
64.2
73.6
Clay
(wt %)
28.3
21.5
41.2
42.3
29.9
27.5
31.5
42.8
38.3
40.9
43.3
42.4
34.2
25.2
Fines
(wt %)
73.9
39.8
97.4
97.9
98.7
55.8
62.1
98.2
97.4
82.8
99.2
98.9
98.4
98.8
TVS
(wt %)
7.5
4.5
9.1
8.6
8.9
5.7
6.2
8.7
8.6
7.9
8.6
8.7
8.4
8.6
TOC
(wt %)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
' ND = total organic carbon content was not determined at these stations.
49
-------
Bellingham
S3 <50
H3 >50 - 70
>70 - 90
>90 - 95
>95
Figure 9. Distribution of percent fine-grained sediment in inner Bellingham Bay
50
-------
N
miles
0 1/2 1
IO 1 2
Kilometers
Figure 10. Distribution of percent fine grained sediments in outer Bellingharn Bay
-------
Bellingham
Figure 11. Distribution of percent TVS in inner Bellingham Bay
52
-------
Ptirtage
Island .# Pt. Frances
Figure 12. Distribution of percent TVS in outer Bellingham Bay
-------
Beliingham
,.,
kilometers
Figure 13. Distribution of percent TOC in inner Beliingham Bay
54
-------
Data Synthesis of Toxic Chemicals
For the data included in this study, 13 metals and 22 organic compounds were detected in
sediments from various locations in Bellingham Bay. A summary of chemical concentrations in
sediments from the bay is presented in Appendix A, Table A-2.
Choice of Indicators—Many of the chemicals analyzed in Bellingham Bay were detected below
quantitation limits or were detected in very few sediment samples. In addition, some of these
chemicals were found to covary in their spatial relationships with other toxic substances. As a
result, a subset of indicator chemicals was selected for use in assessing the degree of sediment
contamination in Bellingham Bay. Chemical indicators used to evaluate sediment contamination
include:
• Sum of low molecular weight polycyclic aromatic hydrocarbons (LPAH)
• Sum of high molecular weight polycyclic aromatic hydrocarbons (HPAH)
• Total PCB
• Detected organic compounds
• Arsenic
• Copper
• Lead
• Mercury
• Silver
• Zinc.
The concentrations and spatial distributions of the selected indicator chemicals were found to be
reasonable surrogates for the broader range of chemicals detected. However, this does not imply
that all important contaminants have been considered in past studies. Important contaminants not
analyzed for in most past studies are identified in the section entitled Identification of Data Gaps
and Recommendations.
Available Data and Station Locations—Chemical contamination in Bellingham Bay sediments
was assessed using data from four studies: Malins et al. (1982), CH2M HILL (1984), Battelle
(1986), and Reif (1988). Data collected prior to 1980 were not included in this analysis, because
those data may not reflect changes in sediment chemistry in Bellingham Bay resulting from the
opening of the Georgia-Pacific secondary treatment system in 1979. The locations of sediment
chemistry stations in Bellingham Bay from these studies are presented in Figures 7 and 8.
In April 1981, Malins et al. (1982) sampled two stations near the Georgia-Pacific facility for
PCB, hexachlorobenzene, and four metals. All six chemicals were detected. Precise coordinates
for these sampling stations were not recorded. However, because these stations were located near
the Port of Bellingham and Georgia-Pacific facilities, their locations were depicted with reasonable
accuracy on a map. In 1983, Battelle conducted a screening survey in Bellingham Bay by sampling
55
-------
26 stations for three metals. All three metals were detected at all stations. Based on the 1983
results, eight stations were sampled again in 1984 for 26 organic compounds and 9 metals. Of
these, 18 organic compounds and all 9 metals were detected. In 1984, CH2M HILL (1984) sampled
two stations, one near the Post Point WWTP outfall and one south of the outfall. These samples
were analyzed for 13 metals and 120 organic compounds. Of these, one organic compound and all
13 metals were detected. During a Class II inspection of the Post Point WWTP, Reif (1988)
sampled two stations near the Post Point WWTP outfall. These samples were analyzed for 13 metals
and 98 organic compounds. Of these, one organic compound and six metals were detected.
Reference Area Data—EAR values were calculated relative to the average chemical concentra-
tions in Carr Inlet (Tetra Tech 1985a). Significant elevations of Bellingham Bay concentrations
were determined by comparison with all Puget Sound reference values (Tables 9 and 10). The
concentration of a specified contaminant was considered to be significantly elevated if it was
greater than the highest value found in any Puget Sound reference area (described below).
EAR Analysis—To calculate the EAR value for a selected chemical indicator, the dry-weight
concentration of that indicator at each station in Bellingham Bay was divided by the average dry-
weight concentration of that indicator in Carr Inlet. For the studies used, many organic compounds
were undetected. In those cases, the detection limits were used to calculate EAR values. In the
Battelle (1986) study, a range of detection limits for samples from all eight bays was reported for
each chemical. In this case, the highest detection limit reported was used to calculate EAR values.
The detection limit for a given compound was not used if it was found to equal or exceed the
LAET for that compound, because it was uncertain whether the actual concentration was above
or below the level at which adverse biological effects would be expected.
EAR values were also used to identify concentrations of contaminants observed in the study
area that were significantly elevated above the concentrations of that contaminant in Puget Sound
reference areas. For this purpose, threshold EAR values for each chemical indicator were
calculated as the ratio of the greatest Puget Sound reference value divided by the average Carr Inlet
reference value. Because contaminant concentrations greater than the maximum Puget Sound
reference value are considered significantly elevated, any EAR values greater than the threshold
EAR value were considered significantly elevated (Tables 11, 12, and 13).
At several stations, EAR values for the summed indicator organic compounds (i.e., LPAH,
HPAH, PCB) were influenced substantially by relatively high detection limits for undetected
chemicals. In several cases, detection limits comprised all or most of the values incorporated into
each sum. Because of the potential confounding influence of high detection limits on the summed
indicators, a separate EAR evaluation was conducted for only those organic compounds that were
detected at each station. Although EAR for metals were not influenced to the same degree by high
detection limits as organic compounds, unusually high EAR values resulted from high detection
limits in several cases. Those cases are described in the text when the spatial patterns of EAR
values for each metal are described.
LPAH: Data on LPAH concentrations in sediments were available for 12 stations in
Bellingham Bay. LPAH concentrations ranged from 640 to 2,400 A*g/kg dry weight (DW). The
mean LPAH concentration in the Carr Inlet data set was 41 /ig/kg DW, and the maximum LPAH
observed in all Puget Sound reference areas was 170 Mg/kg DW.
56
-------
TABLE 9. SUMMARY OF ORGANIC COMPOUND CONCENTRATIONS
IN SEDIMENTS FROM PUGET SOUND REFERENCE AREAS'
Chemical
Low molecular weight PAH
naphthalene
acenaphthylene
acenaphthene
fluorene
phenanthrene
anthracene
High molecular weight PAH
fluoranthene
pyrene
benz( a)anthracene
chrysene
benzo(b)fluoranthene
benzo(k)fluoranthene
benzo(a)pyrene
indeno(l,2,3-c,d)pyrene
dibenzo(a,h)anthracene
benzo(g,h,i)perylene
Total PCB
Chlorinated benzenes
1 ,4-dichlorobenzene
1 ,2,4-trichlorobenzene
Phthalate esters
dimethyl phthalate
butyl benzyl phthalate
di-n-octyl phthalate
Pesticides6
p,p'-DDE
p,p'-DDD
p,p'-DDT
aldrin
chlordane
endrin aldehyde
dieldrin
endrin
heptachlor
Range
(Mg/kg dry wt)b
4-L71
U0.5-U40
U0.1-U40
U0.1-U40
UO.1-40
4-170
U0.5-U40
34-L100
5-100
5-120
2-U40
4-U40
U5-94
E4.8-94
UO.37-40
UO.37-30
U0.4-E10
El.2-20
3.1-U504
U0.06-U40d
U0.5-U16d
U0.5-U50
U0.5-U25
U0.5-E56
U1.6-U10
U1.9-U10
U1.0-U10
U0.5-U10
U5-U50
U2.3-U10
U1-U10
U1-U10
U0.5-U10
Detection
Frequency
13/13
12/27
2/27
4/27
7/28
18/24
11/24
13/13
24/29
23/29
15/24
15/24
15/25
15/25
16/21
10/19
3/12
8/13
7/22
1/23
0/9
1/12
3/12
4/12
0/8
0/9
0/8
0/9
0/13
0/5
0/9
0/9
0/9
Reference
Sitesc
1,8,9
1,2,3,4,5,6,8,9
1,2,3,4,5,6,8,9
1,2,3,4,5,6,8,9
All
1,2,3,6,7,8,9
1,2,3,6,7,8,9
1,8,9
All
All
1,2,3,6,7,8,9
1,2,3,6,7,8,9
1,2,3,4,5,6,7,8
1,2,3,4,5,6,7,8
1,3,4,5,6,7,8,9
1,4,5,6,7,8,9
1,8,9
1,7,8,9
1,2,3,4,6,7,9
1,2,3,4,5,8,9
1,9
1,8,9
1,8,9
1,8,9
,8,9
,8,9
,8,9
,8,9
,8,9
1,8
,8,9
,8,9
,8,9
57
-------
TABLE 9. (Continued)
Range Detection Reference
Chemical (Mg/kg dry wt)b Frequency Sites'"
Phenols
phenol UO.5-62' 5/17 1,2,3,8
2-methyiphenoi U0.7-U50 0/11
4-methylphenol UO.8-290 7/11 1,8,9
2,4-dimethylphenol U1-U14 0/13 1,8,9
pentachlorophenol 0.1-U50d 1/10 1,8,9
Miscellaneous Extractables
2-methylnaphthalene
1 -methylphenanthrene*
biphenyl8
retene*
a This table includes only chemicals
T — TTip cum hac inrvirrviratwH HatA
E0.3-U22
Uh-E7.1
U"
U"-E130
that were detected
rtinn limits fnr nni» i
10/17
0/4
0/4
6/10
in the present study.
nr mnrp PAH mmnoimrk
1,4,5,6,
8
8
1,8
anri is rnn
,8,9
sirlprpri
a maximum estimate.
U= Undetected at the detection limit shown.
E = Estimated value.
c Reference sites: 1. Carr Inlet 4. Case Inlet 7. Nisqually Delta
2. Samish Bay 5. Port Madison 8. Port Susan (1985)
3. Dabob Bay 6. Port Susan 9. Port Susan (1986, this study)
Values from Port Susan Station PS-05, which were anomalously high, are not reflected in this table
for reasons discussed in PTI and Tetra Tech (1988a).
d Detection limits for this chemical or chemical group that exceeded 50 ug/kg have been excluded
for the purpose of reference area comparisons; this is consistent with treatment of reference area
data in Tetra Tech (1985a).
e Higher detection limits for single component pesticides (U25) were reported for Main Sediment
Quality Survey samples from Carr Inlet in Tetra Tech (1985a). However, these detection limits
were based on GC/MS analysis, which is less sensitive than GC/ECD and was considered undesirable
for characterizing reference areas. GC/ECD analyses for Carr Inlet samples in the Preliminary
Survey (Tetra Tech 1985a) resulted in the U10 values.
f An anomalously high phenol value of 1,800 /*g/kg dry weight was found at one Carr Inlet station
(Tetra Tech 1985a). For the purpose of reference area comparison, this value has been excluded.
Data from Site 9 were excluded because laboratory contamination of phenol was observed during
analysis of these reference area samples.
g Tentatively identified compound.
h U - This tentatively identified compound was not found during a mass spectral search of reference
sample extracts. Actual detection limits for tentatively identified compounds were not assigned
in these cases.
58
-------
TABLE 9. (Continued)
References:
(Site 1) Tetra Tech (1985a); Mowrer et al. (1977)
(Site 2) Battelle (19861
(Site 3) Battelie (1986); Prahl and Carpenter (1979)
(Site 4) Malins et al. (1980); Mowrer et al. (1977)
(Site 5) Malins et al. (1980)
(Site 6) Malins et al. (1982)
(Site 7) Barrick and Prahl (1987); Mowrer et al. (1977)
(Site 8) PTI and Tetra Tech (1988a)
(Site 9) PTI and Tetra Tech (1988b)
59
-------
TABLE 10. SUMMARY OF METAL CONCENTRATIONS IN SEDIMENTS
FROM PUGET SOUND REFERENCE AREAS
Chemical
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercurv
Nickel '
Silver
Zinc
Range
(mg/kg dry w:)a
UO 1-2 76
1 9-17
0.047-1.9
9.6-E255
5-74
UO.1-24
0.01-0.28
4-140
U002-3 3
15-E102
Detection
Frequency
19/39
41/41
31/31
45/45
35/35
28/35
45/45
33/33
31/33
33/33
Reference
Sitesb
1,2,3,4,7,8,9,10,11
1,2,3,4,7,8,9,10,11
1,2,3,4,6,9,10,11
1-11
1,2,3,4,5,6,9,10,11
1,2,3,4,5,6,9,10,11
1-11
1,2,3,4,5,9,10,11
1,2,3,4,5,9,10.11
1,2,3,4,5,9,10,11
Undetected at the method detection limit shown.
Reference sites:
1. Carr Inlet 5. Port Madison 9.
2. Samish Bay 6. Port Susan 10.
3. Dabob Bay 7. Nisqually Delta 11.
4. Case Inlet 8. Hood Canal
Sequim Bay
Port Susan (1985)
Port Susan (1986)
Values from Port Susan Station PS-05, which were anomalously high, were excluded from this table
for reasons discussed in PTI and Tetra Tech (1988a).
References:
(Site 1)
(Site 2)
(Site 3)
(Site 4)
(Site 5)
(Site 6)
(Site 7)
(She 8)
(Site 9)
(Site 10)
(Site 11)
Tetra Tech (1985a); Crecelius et al. (1975)
Battelle (1986)
Battelle (1986)
Crecelius et al. (1975); Malins et al. (1980)
Malins et al. (1980)
Malins et al. (1982)
Crecelius et al. (1975)
Crecelius et al. (1975)
Battelle (1985)
PTI and Tetra Tech (1988a)
PTI and Tetra Tech (1988b).
60
-------
TABLE 11. INDICATORS OF SEDIMENT CHEMICAL CONTAMINATION
FOR ORGANIC COMPOUNDS IN BELLINGHAM BAY RANKED BY EAR'
Station6
LPAH
CH07
CH11
BA07
BA04
BA05
BA03
BA24
RE02
BA23
RE01
BA12
BAH
HPAH
BA07
BA04
CH11
CH07
RE02
BA03
BA05
RE01
BAH
BA24
BA12
BA23
EAR^d
59*
59*
47*
40*
31*
31*
29*.
25*
25*
20*
19*
16*
57*
45*
41*
41*
26*
24*
23*
23*
17*
9.2*
8.9*
8.6*
Undetected
Ratio" Station"
7/7
7/7
1/6
1/6
4/6
4/6
4/6
6/6
4/6
6/6
2/6
1/6
0/5
1/5
7/7
7/7
8/8
1/5
2/5
8/8
1/5
4/5
1/5
3/5
PCB
MA01
BA03
BA04
BAH
BA12
BA07
BA05
BA24
BA23
CH11
CH07
EARd
17*
16*
12*
12*
12*
8.5
7.8
6.7
6.7
3.3
3.3
Undetected
Ratio"
0/1
1/2
1/2
1/2
1/2
1/2
1/2
2/2
2/2
2/2
2/2
a EAR were determined relative to the mean values found in Carr Inlet, and were based on both
detected and undetected values.
b All stations labeled with the prefix BA were sampled by Battelle (1986) in 1984.
c * = Concentration exceeds maximum value observed in Puget Sound reference areas.
d No concentration exceeded the LAET or HAET for any of the groups of organic compounds.
e Undetected ratio = ratio of undetected to detected values that comprise a sum of compound
concentrations.
61
-------
TABLE 12. EAR VALUES FOR MAJOR DETECTED
ORGANIC COMPOUNDS IN BELLINGHAM BAY"-1"
EAR bv Station
Low molecular weight PAH
Naphthalene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
High molecular weight PAH
Fluoranthene
Pvrene
Benz(a)anthracene
Chrysene
Benzofluoranthene
Phthalates
Di-n-octyl phthalate
Total PCS
MA01 BA03
39*
22*
47*
45*
42*
25*
17* 12*
BA04
65*
43*
53*
14*
93*
80*
74*
55*
9*
BA05
46*
19*
32*
28*
61*
5
BA07
51*
31*
37*
81*
37*
100*
94*
121*
139*
15*
29*
5
BAH
16*
8
16
17*
37*
28*
26*
17*
9*
9*
'BA12 BA23 BA24
18* 17* :5*
16*
16 10 21*
5
13* 13*
17* 13* 13*
14
9*
15*
9*
a EAR were not calculated for undetected and estimated values.
b * = Concentration exceeds maximum value observed in Puget Sound reference areas.
c No concentration exceeded the LAET or HAET for any individual organic compound.
62
-------
TABLE 13. INDICATORS OF SEDIMENT CHEMICAL CONTAMINATION
FOR METALS IN BELLINGHAM BAY RANKED BY EAR*
Mercury
BA04
BA07
BA03
MA02
BA26
BA04(84)
BA03(84)
BA07(84)
MA01
BA25
BAH
BA06
BA05
BA12 .
BA09
RE01
BA12(84)
BA15
BA23
BA24
BA24(84)
BA23(84)
BA11(84)
CH11
BA16
BAM
RE02
BA10
BA22
BA17
BA01
BA08
BA13
BA20
BA02
CH07
BA21
BA05(84)
BA19
BA18
61***
46**
45**
45**
42**
40**
32**
23**
20**
19**
18**
18**
17**
16**
16**
15**
15**
15**
15**
14**
14**
13**
13**
12**
11**
10**
8.9*
7.4*
7.4*
7.2*
6.6*
6.3
4.0
3.9
2.9
2.3
2.3
1.9
1.3
0.53
Lead
BA26
VtAOl
BA04
BA03(84)
BA07
BA04(84)
MA02
BA03
BA23
BA05
BA15
BA14
RE01
BA16
BA12
BA25
BA24
BAH
BA06
BA09
BA07(84)
RE02
BA22
BA17
BA20
BA08
BA01
BA02
BA11(84)
BA05(84)
CH11
BA10
BA12(84)
BA21
BA13
BA23(84)
BA24(84)
BA19
CH07
BA18
17*
10*
5.2*
5.0*
4.1*
4.0*
3.7*
3.1*
2.7*
2.6
2.6
2.5
2.4
2.3
2.3
2.3
2.3
2.3
2.2
2.2
2.0
2.0
1.8
1.8
1.7
1.6
1.5
1.4
1.4
1.4
1.3
1.3
1.2
1.2
1.1
1.1
0.87
0.73
0.35
0.29
Silver
RE02
RE01
BA26
BA04(84)
BA04
BA07
BA03
BA03(84)
BA07(84)
BA15
BA23
BA05(84)
BA16
BAH
BA05
BA24
CH11
BA12
BA14
BA06
BA25
BA09
BA22
BA17
BA23(84)
BA12(84)
BA24(84)
BA20
BA01
BA02
BA08
BA10
CH07
BA11(84)
BA13
BA21
BA19
BA18
39*
36
5.8
5.2
4.2
3.4
3.3
3.2
3.2
2.9
2.7
2.7
2.6
2.4
2.4
2.4
2.3
2.3
2.2
2.2
2.1
2.0
1.8
1.7
1.7
1.4
.4
.4
.4
.4
.3
.2
1.2
1.0
0.84
0.71
0.47
0.16
Arsenic
RE02
RE01
CH11
MA02
CH07
BA05(84)
MA01
BA1K84)
BA23(84)
BA07(84)
BA03(84)
BA24(84)
BA04(84)
BA12(84)
Copper
BA03(84)
BA11(84)
BA07(84)
BA04(84)
BA05(84)
BA24(84)
BA23(84)
BA12(84)
RF02
IXAJw^t
RFOI
iXJJVs 1
fHl 1
V«r All 1
CH07
\_-A L\J 1
Zinc
BA04(84)
RE02
RE01
BA07(84)
BA24(84)
BA23(84)
BA 11(84)
BA05(84)
CH11
BA03(84)
BA12(84)
CH07
10*
9.4*
6.4*
5.9*
4.1
3.4
3.2
3.2
3.2
2.6
2.5
2.5
2.2
2.0
63**
12*
11
11
11
11
9.7
9.6
8 6
O * \J
8 5
O • J
7.2
2.8
7.1*
6.6*
6.5*
6.2*
6.1*
6.0*
6.0*
5.8*
5.8*
5.4*
5.1
2.3
a EAR were determined relative to the mean values found in Carr Inlet.
b Stations followed by (84) were sampled by Battelle (1986) 1984; all other stations with the prefix BA
were sampled in 1983.
c * = Concentration exceeds maximum value observed in Puget Sound reference areas.
** = Concentration exceeds LAET and maximum Puget Sound reference value.
*** = Concentration exceeds HAET. LAET. and maximum Puget Sound reference value.
63
-------
All stations in Bellingham Bay had significant elevations of LPAH concentrations. The two
highest concentrations of LPAH were found near the Post Point WWTP outfall (Station CH07;
Figure 7) and south of the outfall (Station CH11). However, these elevated concentrations were a
sum of unusually high detection limits for all six LPAH. The highest LPAH concentration based
largely on detected values (1,900 MS/kg, EAR=47) was found adjacent to the southern boundary
of the Port of Bellingham facilities in the inner harbor (Station BA07). Stations with EAR values
greater than 10 with greater than 50 percent detected values in the LPAH sum were detected in the
I&J Street and Whatcom Creek waterways.
HPAH: Data on HPAH concentrations in sediments were available at 12 stations in Belling-
ham Bay. HPAH concentrations ranged from 700 to 4,500 Mg/kg DW. The mean HPAH concen-
tration in the Carr Inlet data set used as a reference was 79 Mg/kg DW, and the maximum HPAH
concentration observed in all Puget Sound reference areas was 120 Mg/kg
All stations in Bellingham Bay had significant elevations of HPAH concentrations. The
maximum concentration of HPAH (4,500 Mg/kg, EAR=57) was detected adjacent to and south of
the Port of Bellingham's inner terminal (Station BA07; Figure 7). This station also exhibited the
highest detected LPAH concentration. The second highest concentration (3,600 Mg/kg, EAR=45)
was observed at a station located at the mouth of the Whatcom Creek Waterway (Station BA04).
PCB: Data on PCB concentrations in sediments were available at 1 1 stations. PCB concentra-
tions ranged from 20 to 100 Mg/kg DW. The mean total PCB concentration from the Carr Inlet
reference area data set was 6 Mg/kg DW while the maximum Puget Sound reference area value
was 50 Mg/kg DW.
Six of the 1 1 stations in Bellingham Bay exhibited significantly elevated PCB concentrations.
The highest PCB concentration detected was located in the inner reach of the Whatcom Creek
Waterway at Station MA01 (Figure 7) (100 Mg/kg DW, EAR=17). The next highest value was
detected near the mouth of the Whatcom Creek Waterway at Station BA03 (94 Mg/kg DW, EAR=16).
PCB were not detected near the Post Point WWTP outfall.
Detected Organic Compounds: EAR values were calculated for 12 detected organic compounds
at nine stations in Bellingham Bay. EAR values were significantly higher than the maximum Puget
Sound reference value in 54 of 62 cases (87 percent). The highest EAR value observed at each
station is shown in Figure 14. The highest EAR values in the bay were found at three stations
located near the mouth of Whatcom Creek Waterway. At Station BA07 (Figure 7), the three highest
EAR values ranged from 100 to 139, and included the HPAH compounds fluoranthene, benz(a)-
anthracene, and chrysene. At Station BA04, the highest three EAR values ranged from 74 to 93
and included the LPAH compound fluorene, and the HPAH compounds pyrene and benz(a)anthra-
cene. At Station BA05, the three highest EAR values ranged from 32 to 61, and included the
LPAH compound naphthalene and the HPAH compounds fluorene and benzofluoranthene.
Mercury: Data on mercury concentrations in sediments were available for 32 stations in
Bellingham Bay, eight of which were sampled twice by Battelle (1986). Mercury concentrations
ranged from 0.023 to 2.6 mg/kg DW. The mean mercury concentration observed in the Carr Inlet
reference data set was 0.043 mg/kg DW, and the maximum mercury concentration in the Puget
Sound reference area data set was 0.28 mg/kg DW.
Thirty-one of the 40 sediment samples (78 percent) in Bellingham Bay exhibited significantly
elevated mercury concentrations (Figures 15 and 16). The highest concentrations were observed
64
-------
Bellingham
kilometers
Note: Based on Table 12: Organic compound
with the highest EAR is identified in figure
Figure 14. Maximum EAR for individual organic compounds in inner Bellingham Bay
65
-------
Bellingham
ffl 0-10
S3 >10-20
B >20 - 30
B >30 - 40
>40
kilometers
Note: EAR > 10
exceed lowest apparent
effects threshold (LAET)
Figure 15. Distribution of mercury EAR in inner Bellingham Bay
66
-------
Nook sack River
Lumml Bay I;
Bellingham
Lumml
Peninsula ..!'-
.••••• Falrhaven
'LL'- Chuckinul
Pbrtage
island::/ Pt. Frances
Chuckanut Bay \
ffi'O-10
-20
B3 >20 - 30
H >30 - 40
>40
Governors
Pt.
miles
0 1/2 1
Note. EAR > 10
exceed lowest apparunl
effects threshold (LAETj
•M Eliza Island
0 1 2
kilometers
Figure 16. Distribution of mercury EAR in outer Bellingham Bay
-------
at the mouth of the Whatcom Creek Waterway (Station BA04—2.6 mg/kg DW, EAR=61), in the
inner reach of the Whatcom Creek Waterway (Station MA02—1.9 mg/kg DW, EAR=45; Station
BA26—1.79 mg/kg DW, EAR=42), near the Port of Bellingham's inner pier (Station BA07—
1.97 mg/kg DW, EAR=46), and offshore from Georgia-Pacific's secondary treatment lagoon (Station
BA03—1.91 mg/kg DW, EAR=45). Three of the four stations sampled near the Post Point WWTP
outfall exhibited significantly elevated mercury concentrations. The lowest mercury concentrations
in the bay were found near the delta of the Nooksack River.
Mercury concentrations in sediments have declined substantially since 1970-1973, when they
were evaluated by Bothner (1973). In that study, mercury concentrations as high as 11 mg/kg DW
were found near Whatcom Creek Waterway, and a concentration of 20 mg/kg DW was found in the
log pond that received the discharge from the Georgia-Pacific chlor-alkali plant. Bothner (1973)
estimated that mercury concentrations in sediments were declining over time, and exhibited a half-
life of 1.3 years.
Lead: Data on lead concentrations in sediments were available from 32 stations in Bellingham
Bay, eight of which were sampled twice by Battelle (1986). Lead concentrations ranged from 3.2
to 154 mg/kg DW. The mean lead concentration observed in the Carr Inlet reference data set was
9.2 mg/kg DW, and the maximum lead concentration in the Puget Sound reference area data set
was 24 mg/kg DW.
Nine of the 40 samples (23 percent) from Bellingham Bay exhibited significantly elevated lead
concentrations. The highest lead concentrations were observed in the inner reach of the Whatcom
Creek Waterway at Station BA26 (Figure 7) (158 mg/kg, EAR=17) and near the mouth of the
waterway at Station MA01 (95 mg/kg DW, EAR=10). The next highest lead concentrations were
observed near the mouth of the Whatcom Creek Waterway. Three of the four sediment samples
taken near the Post Point WWTP outfall were elevated above reference but generally not above the
values reported throughout the remainder of Bellingham Bay. The lowest lead concentrations in
the bay were found near the delta of the Nooksack River.
Silver Data on silver concentrations in sediments were available for 30 stations in Bellingham
Bay, eight of which were sampled twice by Battelle (1986). Silver concentrations ranged from
0.014 to 3.5 mg/kg DW. The mean silver concentration observed in the Carr Inlet reference data
set was 0.09 mg/kg DW, and the maximum silver concentration in the Puget Sound reference area
data set was 3.3 mg/kg DW.
Only one (Station RE02; Figure 7) of the 30 stations (3 percent) sampled in Bellingham Bay
exhibited a significantly elevated EAR value (39), and that value was based on a relatively high
detection limit. The second highest EAR value (36) was observed at Station RE01 and was also
based on a high detection limit. Both of these stations are located near the Post Point WWTP
outfall. If those two stations were not considered, none of the EAR for silver was significant and
none exceeded a value of 6.0.
Arsenic: Data on arsenic concentrations in sediments were available for 14 stations in
Bellingham Bay. Arsenic concentrations ranged from 6.9 to 35 mg/kg DW. The mean arsenic
concentration observed in the Carr Inlet reference data set was 3.4 mg/kg DW. The maximum
arsenic concentration in the Puget Sound reference area data set was 17 mg/kg DW.
Four of the 14 stations (28 percent) in Bellingham Bay exhibited significantly elevated arsenic
concentrations. The two highest concentrations were observed in the immediate vicinity of the Post
68
-------
Paint WWTP outfall (Station RE02-35 mg/kg DW, EAR=10; Station RE01-32 mg/kg DW,
EAR=9.5; Figure 7), but they were both based on detection limits. The next highest concentration
was found immediately south of Post Point (Station CHI 1—21.7 mg/kg DW, EAR=6.4). The fourth
highest arsenic concentration was found near the Port of Bellingham's inner harbor pier (Station
MA01-20 mg/kg DW, EAR=5.9).
Zinc: Data on zinc concentrations in sediments were available for 12 stations in Bellingham
Bay. Zinc concentrations ranged from 43 to 135 mg/kg DW. The mean zinc concentration
observed in the Carr Inlet reference data set was 18.5 mg/kg DW. The maximum zinc concentra-
tion in the Puget Sound reference area data set was 101 mg/kg DW.
Ten of the 12 stations (92 percent) in Bellingham Bay exhibited significantly elevated zinc
concentrations. The highest concentrations were observed at the mouth of the Whatcom Creek
Waterway (Station BA04—135 mg/kg DW, EAR=7.1). Significantly elevated zinc concentrations
were observed throughout the inner harbor area, offshore of Fairhaven and near the Post Point
WWTP outfall.
Copper: Data on copper concentrations in sediments were available for 12 stations in
Bellingham Bay. Copper concentrations ranged from 18 to 400 mg/kg DW. The mean copper
concentration observed in the Carr Inlet reference area data set was 6.4 mg/kg DW, and the
maximum copper concentration in the Puget Sound reference area data set was 74 mg/kg DW.
Two of the 12 stations (17 percent) sampled in Bellingham Bay exhibited significantly elevated
copper concentrations. The highest copper concentration was observed offshore from the Georgia-
Pacific secondary treatment lagoon (Station BA03—400 mg/kg DW, EAR=63) (Figure 7). The other
significantly elevated val'ue was observed near the I&J Street Waterway (Station BA11-
79 mg/kg DW, EAR=12). Samples taken from near the Post Point WWTP outfall exhibited copper
concentrations ranging from 18 to 55 mg/kg DW (EAR=2.8-8.6).
Comparison to AET Values—AET values represent concentrations of specific sediment
contaminants above which deleterious biological effects are expected to be observed. AET values
are based on sediment chemistry data, toxicity data (amphipod, oyster larvae, and Microtox
bioassays), and benthic infaunal abundance data. Given a specific chemical contaminant and a
specific biological indicator, the AET is the concentration above which statistically significant
biological" effects occurred in all sediment samples analyzed. Contaminant concentrations in
Bellingham Bay were compared to Puget Sound AET values to predict areas where significant
biological effects would be expected to occur. The 1988 Puget Sound AET values for 56 chemicals
are shown in Table 14. Four AET values are provided for each chemical. The minimum and
maximum AET values for a given chemical are listed as the LAET and highest apparent effects
threshold (HAET), respectively. Thus, the LAET is the concentration above which the most
sensitive biological effect could occur, and as such is the most conservative prediction of potential
significant biological effects. The HAET represents the concentration above which all of the four
biological effects would be expected to occur.
An HAET was exceeded by only one chemical (mercury) at a single station (BA04) in
Bellingham Bay (Table 13). The LAET for mercury was exceeded at 26 stations (Table 13;
Figures 15 and 16), including Station BA04. Most of these stations were located in Whatcom Creek
Waterway, along the Fairhaven shoreline, and near the Post Point WWTP outfall (Figures 15
69
-------
TABLE 14. 1988 PUGET SOUND AET
FOR SELECTED CHEMICALS4*"
Chemical
Metals (mg/kg dry weight; ppm)
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercurv
Nickel
Silver
Zinc
Amphipod
AET
200
93
6.7
270
1,300
660
2.1
>140
6.1
960
Ovster
AET
— —
700
9.6
--
390
660
0.59
—
>0.56
1,600
Benthic
AET
150
57
5.1
260
530
450
2.1
>140
>6.1
410
Microtox
AET
__
700
9.6
--
390
530
0.41
--
>0.56
1,600
LAET
150
57
5.1
260
390
450
0.41
e
6.1
410
1988C
HAET
200
700
9.6
270
1,300
660
2.1
I40d
6.1
1,600
Organic Compounds (Mg/kg dry weight; ppb)
Low molecular weight PAH 24,000
5,200 13,000
5,200
5,200 24,000
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
2-Methylnaphthalene
High molecular weight PAH
Fluoranthene
Pyrene
Benz(a)anthracene
Chrysene
Benzofluoranthenes
Benzo(a-)pyrene
Indeno( 1 ,2,3-c,d)pyrene
Dibenzo(a,h)anthracene
Benzo(g,h,i)perylene
Chlorinated organic compounds
1 ,3-Dichloro benzene
1 ,4-Dichlorobenzene
1 ,2-Dichlorobenzene
1 ,2,4-Trichlorobenzene
Hexachlorobenzene (HCB)
Total PCB
2,400
1,300
2,000
3,600
6,900
13,000
1,900
69,000
30,000
16,000
5,100
9,200
7,800
3,000
1,800
540
1,400
>170
120
>110
51
130
3,100
2,100
>560
500
540
1,500
960
670
17,000
2,500
3,300
1,600
2,800
3,600
1,600
690
230
720
>170
120
50
64
230
1,100
2,700
1,300
730
1,000
5,400
4,400
670
69,000
24,000
16,000
5,100
9,200
9,900
3,600
2,600
970
2,600
>170
110
50
22
1,000
2,100
>560
500
540
1,500
960
1,900
12,000
1,700
2,600
1,300
1,400
3,200
1,600
600
230
670
>170
110
35
31
70
130
2,100
1,300
500
540
1,500
960
12,000
1,700
2,600
1,300
1,400
3,200
1,600
600
230
670
e
110
35
31
22
130
2,700
1,300
2,000
3,600
6,900
13,000
69,000
30,000
16,000
5,100
9,200
9,900
3,600
2,600
970
2,600
e
120
110d
64
230
3,100
70
-------
TABLE 14. (Continued)
Chemical
Amphipod
AET
Ovster
AET
Benthic
AET
Microtox
AET
1988C
LAET HAET
Phthalates
Dimethyl phthaJate > 1,400 160 > 1,400 71 71
Diethyl phthalate > 1,200 >73 200 >48 200
Di-n-butyl phthalate 1,400 1,400 >5,100 1,400 1,400
Butyl benzyl phthalate 900 >470 900 63 63
Bis(2-ethyl'hexyl)phthalate >3.100 1,900 1,300 1,900 1,300
Di-n-octyl phthalate >2,100 >420 6,200 — 6,200
Phenols
Phenol 1,200 420 1,200 1,200 420
2-Methylphenol 63 63 72 >72 63
4-Methylphenoi 3,600 670 1,800 670 670
2.4-Dimethyl phenol 72 29 210 29 29
Pentachlorophenoi 360 >140 690 >140 360
Miscellaneous Extractables
Benzyl alcohol 870 73 870 57 57
Benzoic acid 760 650 650 650 650
Dibenzofuran 1,700 540 700 540 540
Hexachlorobutadiene 180 270 11 120 11
N-Nitrosodiphenylamine 48 130 28 40 50
Volatile Organics
Tetrachloroethene >210 140 57 140 57
Ethylbenzene >50 37 10 33 10
Total xylenes >160 120 40 100 40
Pesticides
l,400d
i.:ood
5,100U
900
3,100a
6,200
1,200
72"
3,600
210
690
870
760
1,700
270
130
210U
50d
160d
p,p'-DDE
p,p'-DDD
p,p'-DDT
15
43
>270
__
—
>6
9
16
34
9
16
34
15
43
270d
Reference: Barrick et al. (1988)
3 ">" indicates that a defined AET could not be established because there were no "effects" stations with
chemical concentrations above the highest concentration among "no effects" stations. "--" indicates AET
data not available.
b HAET = Highest AET for a range of biological indicators; LAET = lowest AET for a range of biological
indicators; ">" indicates that for the AET and biological indicator establishing the LAET or HAET value,
there were no "effects" stations with chemical concentrations above the highest concentration among "no
effects" stations.
c 1988 LAET and HAET are the lowest and highest AET, respectively, established for four biological
indicators in a 334-station database.
J The HAET for these chemicals were established using a "greater than" value (see footnote a); such values
were only used for chemicals that had at least one defined AET.at a lower concentration than the "greater
than" value shown.
N'o defined AET are available for these chemicals (see footnote aj.
71
-------
and 16). The only other LAET exceeded in the bay was for copper at a single station (BA03) near
the mouth of Whatcom Creek Waterway.
BIOACCUMULATION
Bioaccumulation of chemical contaminants in marine organisms has been used as a key
indicator of sediment chemical contamination in most previous urban bay action programs in Puget
Sound. However, the amount of available information on bioaccumulation in Bellingham Bay since
1980 was relatively small for any particular species and was restricted to a limited number of
locations in the bay. These data were therefore not used to identify problem stations in the bay.
Instead, the available data is summarized in this section. Most of the information on bioaccumula-
tion in the bay shows that mercury concentrations were elevated relative to reference areas.
However, the highest concentrations were not always found near Whatcom Creek Waterway, the
location of the major source of mercury contamination.
The FDA action level for mercury in tissue is 1.0 mg/kg wet weight (WW). Action levels
developed by the FDA are intended to be used only for regulation of food products in interstate
commerce. An action level is the minimum concentration of a chemical in food that may be a
cause for the FDA to take enforcement action. Action levels are not designed for managing risks
to individuals who consume unusually large amounts of foods not used in interstate commerce or
foods harvested from locally contaminated areas. Quantitative risk assessments are often conducted
to evaluate site-specific risks from consuming contaminated seafood.
Rasmussen and Williams (1975) evaluated tissue concentrations of mercury in intertidal
organisms collected in 1973 at five stations located along the eastern shoreline of Bellingham Bay.
An intertidal reference station was also sampled in Birch Bay to the north of Bellingham Bay. The
species evaluated included polychaetes, molluscs, crustaceans, echinoderms, coelenterates, intertidal
fishes, and algae. Dungeness crabs were also evaluated in subtidal areas of Bellingham Bay and in
Samish Bay, a reference area located southeast of Bellingham Bay. For small organisms, the whole
body was analyzed. For larger organisms individual organs were analyzed. The individual tissues
evaluated included muscle, siphon, viscera, foot, gill, hepatopancreas, antennal gland, and heart.
Mercury concentrations in the tissues from organisms within Bellingham Bay ranged from 0.04
to 0.3 mg/kg WW. For intertidal organisms, mercury concentrations in organisms from Birch Bay
were generally an order of magnitude less than the values observed for organisms in Bellingham
Bay. The highest concentrations of mercury in intertidal organisms were found off Post Point.
Mercury concentrations in the edible muscle tissue of Dungeness crabs were over 4.5 times higher
than the values observed for crabs from Samish Bay. The corresponding tissue concentrations were
0.23 and 0.05 mg/kg WW, respectively. Mercury concentrations in other tissues of crabs from
Bellingham Bay (i.e., antennal gland, hepatopancreas, gill, and heart) were higher than the values
observed in crabs from Samish Bay by a factors of 1.5 to 2.4.
Nelson et al. (1974) evaluated tissue concentrations of mercury in small benthic macroinver-
tebrates collected in 1974 at 22 stations located throughout inner Bellingham Bay at increasing
distances from the Whatcom Creek Waterway. Organisms were collected with a Peterson grab
sampler and sieved using a 1.0-mm mesh screen. At each station, all species with biomass of at
least 0.1 grams were analyzed for mercury. No species was common to all stations. Concentrations
of mercury ranged from 0.1 to 2.6 mg/kg WW. No relationship with distance from the Whatcom
Creek Waterway was found. The highest mercury concentrations (i.e., 1.2-2.6 mg/kg WW) were
72
-------
found at three stations near Squalicum Waterway and the Squalicum Waterway marina. Concentra-
tions throughout the remainder of inner Bellingham Bay generally were less than 0.3 mg/kg WW.
Mercury concentrations ranged from 0.1-0.9 mg/kg WW in the vicinity of the Whatcom Creek
Waterway.
Roesijadi et al. (1981) collected mussels in 1978 from four locations along the eastern shoreline
of Bellingham Bay at increasing distances from the Whatcom Creek Waterway, from the mouth of
the waterway to Post Point. Mercury concentrations were determined for whole organisms, gill
tissue, and digestive glands. Results were compared with mercury concentrations in mussels
collected from Sequim Bay. All concentrations measured in mussels from Bellingham Bay were
higher (by a factor of 3-5) than values measured in organisms from Sequim Bay. Concentrations
in Bellingham Bay did not show a relationship with distance from the Whatcom Creek Waterway.
CH2M HILL (1984) collected littleneck clams, English sole and flathead sole near the Post
Point WWTP outfall in 1984, and analyzed tissues for metals and organic contaminants. Clams were
collected at three stations and their whole bodies were analyzed. Fishes were collected at two
stations and their muscle and liver tissues were analyzed. The authors concluded that none of the
chemicals analyzed for was substantially elevated in any of the organisms evaluated. However, the
maximum mercury concentration in clams was 0.28 mg/kg WW (minimum = <0.10 mg/kg WW).
Mercury concentrations in muscle tissue of the fishes were <0.10 mg/kg WW. Mercury concentra-
tions in fish liver tissue ranged from <0.10 to 0.24 mg/kg DW.
NOAA (1987) collected mussels (Mytilus edulis) from the jetty of Squalicum Harbor marina
in 1986 and analyzed whole-body tissue for metals and organic contaminants. Mussels were also
collected from Point Roberts, a relatively uncontaminated reference area located north of
Bellingham Bay. The concentrations of several contaminants were elevated in organisms from
Bellingham Bay relative to Point Roberts. Mercury concentrations in Bellingham Bay
(0.28 mg/kg WW) were 2.8 times higher than the value observed for Point Roberts
(0.10 mg/kg WW).
The information found on bioaccumulation in Bellingham Bay was not considered adequate
for conducting a quantitative risk assessment with respect to consumption of contaminated seafood
by humans. Although the maximum concentration of mercury found in recent evaluations of clams
and mussels in Bellingham Bay (i.e., 0.28 mg/kg WW) was well below the FDA action level of
1.0 mg/kg WW, it was almost 3 times higher than the concentration observed in a nearby reference
area. An elevated tissue concentration of that magnitude suggests that additional studies are
warranted, particularly with the goal of providing data appropriate for a quantitative risk
assessment.
SEDIMENT TOXICITY
Two major studies of sediment toxicity have been conducted in inner Bellingham Bay
(Chapman et al. 1984; Battelle 1986). In addition, Reif (1988) sampled two stations near the
terminus of the Post Point WWTP outfall and one sample farther offshore from the outfall. These
studies were conducted after 1979 (i.e., when the Georgia-Pacific secondary treatment system
began operation), and are therefore considered representative of present conditions in the bay. No
studies of sediment toxicity were found for the outer portions of Bellingham Bay and for time
periods prior to 1979.
73
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Study Characteristics
Of the three studies of sediment toxicity in Beilingham Bay, only subsets of the data from
Battelle (1986) and Reif (1988) were considered acceptable for use in the present report. The data
collected by Chapman et al. (1984) were not used, because sediment collection and storage
procedures did not conform to those recommended in the Puget Sound protocols (Tetra Tech 1986).
Sediments in the latter study were sampled to a depth of 10 cm (rather than 2 cm) in each grab
sample and were frozen (rather than held at 4° C) prior to laboratory analysis. Only data from one
of the three stations sampled by Reif (1988) were used in the present report. Data from one station
near the outfall were not used, because only three (rather than five) replicate measurements were
made in the laboratory. Data from the offshore station were not used, because the location of the
station was not described adequately. Only eight of the 26 stations sampled by Battelle were used
in the present report, because only a single measurement (rather than five replicates) was made at
the remaining 18 stations.
Data Synthesis
Choice of Indicators—The amphipod mortality test using Rhepoxynius abronius was used as the
key indicator of sediment toxicity in Beilingham Bay. This test was used for two reasons: 1) a
standardized protocol is available for it (Swartz et al. 1985), and 2) it has been used as an indicator
in most other urban bay action programs in Puget Sound.
Available Data—As mentioned previously, only a subset of the available information on
sediment toxicity in Beilingham Bay was used in the present report. Battelle (1986) conducted the
amphipod mortality test on sediments collected from eight stations in inner Beilingham Bay. Reif
(1988) also conducted this bioassay on sediments collected at a station off Post Point. This
information was generated using the methods recommended by Swartz et al. (1985).
Station Locations—The eight stations sampled by Battelle (1986) were located near the I&J and
Whatcom Creek waterways and along the Fairhaven shoreline (Figure 17). The single station
sampled by Reif (1988) was sampled near the terminus of the Post Point WWTP outfall (Figure 17).
Station codes are defined in Appendix A, Table A-l.
Reference Conditions—Sequim Bay was used as the reference area for the amphipod mortality
data from Beilingham Bay. This bay is relatively uncontaminated and has been used as a reference
area by other investigators. In addition, Battelle (1986) evaluated sediments from four stations in
Sequim Bay as part of the same study from which the Beilingham Bay information was obtained.
The information used in this report was taken from the station exhibiting the lowest level of
amphipod mortality in Sequim Bay (i.e., mean mortality=10 percent, standard deviation=7.9
percent).
Elevation Above Reference Analysis—EAR for amphipod mortality at Beilingham Bay stations
were calculated relative to the 10 percent value observed in Sequim Bay (Table 15; Figure 18).
74
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Bellingham
1
0
kilometers
1 1
:igure 17. Locations of stations sampled for sediment toxicity in inner Bellingham Bay
75
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TABLE 15. EAR VALUES
FOR AMPHIPOD MORTALITY
IN BELLINGHAM BAY
Station EAR"-"
BA03
BA04
BA05
BA07
BAH
BA12
BA23
BA24
0.4
1.7
3.4*
0.5
1.7
1.1
5.8*
1.1
RE01
a EAR are based on comparisons with the 10.0 percent mortality
observed at the reference station in Sequim Bay (described in text).
b * = Mortality at the test site is significantly different (P< 0.05) than
mortality at the reference station.
76
-------
Beilingham
o 1
kilometers
Figure 18. Distribution of EAR for amphipod mortality in inner Beilingham Bay
77
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Significant EAR (P<0.05) were found at three of the nine stations evaluated. The highest
significant EAR (5.8) was found at Station BA24 off the Fairhaven shoreline. The next highest
significant EAR (3.4) was located near the mouth of the Whatcom Creek Waterway. The third
highest significant EAR (2.8) was found near the Post Point WWTP outfall. EAR at all remaining
stations were less than 2.0, and were not significant (P>0.05).
BENTHIC MACROINVERTEBRATES
Six major quantitative surveys of benthic macroinvertebrate assemblages have been conducted
in Bellingham Bay. However, four of these surveys were conducted prior to the date when the
Georgia-Pacific secondary treatment system began operation (i.e, June 1979). Because the treatment
system resulted in a major reduction in the amount of contaminants entering the bay, the four early
studies were not considered representative of the conditions that have existed in the bay in recent
years. In addition, the sampling methods varied among these early studies and are inconsistent with
the methods currently used throughout Puget Sound. These methodological differences limit
quantitative interpretations of the results of the earlier studies. The four early surveys were
therefore not used in the present report to identify problem areas in Bellingham Bay. Instead, they
were only reviewed to provide an historical perspective of benthic macroinvertebrate assemblages
in the bay. Results of these studies have also been reviewed by Shea et al. (1981) and Broad et al.
(1984).
In contrast to the four earlier studies of benthic macroinvertebrates in Bellingham Bay, the
two studies conducted after 1979 were evaluated in detail to identify current problem areas in the
bay. Both of these studies used the sampling methods currently employed throughout Puget Sound
such as the use of a 0.1-m2 van Veen bottom grab sampler and a sieve mesh size of 1.0 mm.
Benthic Studies Prior to 1979
The four earlier studies of benthic macroinvertebrate assemblages in Bellingham Bay focused
primarily on conditions in inner Bellingham Bay. These studies were designed to evaluate the
effects of industrial and sewage discharges, and dredged material disposal in that area. Almost no
information exists on benthic assemblages in other parts of the bay prior to 1979. For these earlier
studies, benthic assemblages appeared to be degraded in sections of the three industrial waterways
of inner Bellingham Bay (i.e., Whatcom Creek, I&J Street, and Squalicum Creek waterways), but
did not appear to be substantially stressed in the remainder of this area. The benthic assemblages
in the inner and central sections of Whatcom Creek Waterway were severely stressed, and, in some
cases, completely absent. A brief review of each of the four studies is presented below.
1964-66 Surveys—The earliest quantitative studies of benthic macroinvertebrate assemblages
in Bellingham Bay were conducted by the U.S. Department of the Interior (U.S. DOI 1967).
Sixteen stations were sampled in August of 1964 throughout inner Bellingham Bay using a 0.25-ft3
van Veen grab sampler. An additional 12 stations were sampled in May of 1966 in the immediate
vicinity of the Whatcom Creek and I&J Street waterways using a 0.125-ft3 Ekman dredge. Sieve
mesh size was not identified for either sampling period. All organisms were identified at higher
taxonomic levels.
-------
In both surveys, benthic assemblages were dominated by polychaetes. Both the size and
composition of the assemblages were found to be related to the organic content of the sediment,
as estimated by TVS. Total number of organisms was consistently low in samples with a TVS
content greater than 15 percent. In addition, the number of different organisms in each sample
exhibited a significant (P<0.01) negative correlation with increasing values of TVS.
Areas with TVS values greater than 15 percent were confined to Whatcom Creek Waterway
and the head of the I&J Street Waterway. Values of TVS greater than 25 percent were only found
at stations at the head of the former waterway. The abundances of organisms at those stations
ranged from 0 to 12 individuals per sample. By contrast, organism abundance at the remaining
stations was as high as 2,900 individuals per sample. The authors concluded the waste solids
discharged from the Georgia-Pacific facility caused substantial damage to nearby benthic
macroinvertebrate assemblages.
1973-75 Surveys—CH2M HILL (1976) conducted quarterly surveys of benthic macroinver-
tebrate assemblages at stations near the outfall of the Post Point WWTP from September 1973 to
August 1975 to evaluate the effects of primary-treated sewage discharged from the plant. The
plant began operation in May 1974. Samples were collected using a van Veen grab sampler and
sieved using a mesh size of 2.0 mm. Organisms were identified at the species level.
The authors found no consistent seasonal or spatial variations in total numbers of individuals.
By contrast, species diversity (based on the Shannon-Wiener Index) varied seasonally, being highest
in spring and lowest in autumn. The authors concluded that neither the construction nor operation
of the WWTP appeared to substantially influence benthic assemblages. Observed changes in
assemblages were attributed largely to differences in sediment character among stations.
1974 Survey—Nelson et al. (1974) conducted a survey of benthic macroinvertebrate assemblages
throughout inner Bellingham Bay in August 1974 to evaluate the effects of mercury discharged
from the Georgia-Pacific chlor-alkali plant. Samples were collected using a Peterson grab (size not
specified) and sieved using a mesh size of 1.0 mm. Organisms were identified at the species level.
Species diversity (based on the Shannon-Wiener Index) of benthic assemblages ranged from
0 to 2.3. Stations with diversity values of 0 (i.e, only 0 or 1 species present) were located in the
immediate vicinity of Whatcom Creek Waterway. Species diversity at the remaining stations
generally increased with increasing distance from the waterway. Benthic assemblages at all of the
stations in the immediate vicinity of the waterway were dominated by the pollution-tolerant
polychaete Capitella capitata. Assemblages at the remaining stations were dominated by species
less pollution-tolerant then C. capitata. Because species diversity did not correlate significantly
(P>0.05) with the mercury content of the sediments, the authors concluded that it did not appear
to be a limiting factor for benthic assemblages. The authors attributed the alterations of assem-
blages in the vicinity of Whatcom Creek Waterway primarily to the presence of sludge deposits in
the sediment.
1978 Survey—Webber (1978) conducted four surveys of benthic macroinvertebrate assemblages
throughout inner Bellingham Bay between May 1977 and April 1978 to evaluate candidate disposal
sites for dredge spoils. Analyses were conducted on subsamples (i.e., 0.05 m2 by 15-cm cores) from
-------
the sediment collected by a 0.1-m2 van Veen grab sampler. The subsamples were sieved using a
mesh size of 1.0 mm, and organisms were identified at the species level.
Benthic assemblages at most stations were dominated numerically by polychaetes. Species
richness of assemblages was relatively high at most stations, but generally lower at the inner sections
of the Whatcom Creek, I&J Street, and Squalicum Creek waterways. Number of individuals per
station was also relatively low in the three waterways.
Benthic Studies After 1979
As mentioned previously, the two benthic studies conducted after 1979 were considered to be
representative of current conditions in Bellingham Bay, and therefore were used to identify problem
areas within the bay. Both surveys were conducted in 1983. Each of the two studies is briefly
reviewed below.
Survey 1—Broad et al. (1984) conducted surveys of benthic macroinvertebrate assemblages at
eight stations in inner Bellingham Bay in May 1983 and 12 stations in the remainder of the bay
in October 1983. Two additional stations were sampled in Samish Bay in May to represent
reference conditions. Two replicate samples were collected at each station using a 0.1-m2 van Veen
grab sampler and a sieve mesh size of 1.0 mm. Organisms were identified at the species level.
The authors found the species compositions of benthic macroinvertebrate assemblages similar
to those found in the earlier benthic surveys. However, Capitella capitata was no longer a
dominant member of any of the assemblages. In general, the abundances of organisms throughout
Bellingham Bay were higher than the values reported in earlier studies, suggesting conditions in the
bay were improving.
The authors identified four relatively discrete benthic assemblages. One assemblage was found
near the delta of the Nooksack River. It was comprised of 60 species and was dominated by the
polychaete Owenia fusiformis. A second assemblage was found in the inner harbor section of inner
Bellingham Bay. It was comprised of only 40 species, dominated by the polychaete Tharyx sp., and
characterized by low values of total abundance, total biomass, and species diversity. A third
assemblage was found in the outer section of inner Bellingham Bay. It was comprised of 56
species, dominated by Tharyx sp., and characterized by higher values of total abundance and total
biomass than the assemblage in the inner section. A fourth assemblage was found in the outer
portions of Bellingham Bay. It was dominated by the bivalve mollusc Axinopsida serricata and
characterized by more species and higher values of total abundance, total biomass, and species
diversity than the assemblages in inner Bellingham Bay.
Survey 2—CH2M HILL (1984) conducted a survey of benthic macroinvertebrate assemblages
at 14 stations near the Post Point WWTP in October 1983. Five replicate samples were collected
at each station using a 0.1-m2 van Veen grab sampler and a sieve mesh size of 1.0 mm. Organisms
were identified at the species level. The authors found no evidence that discharges from the
WWTP were substantially influencing the benthic assemblages.
-------
Data Synthesis
Choice of Indicators—Information on benthic macroinvertebrate assemblages in Bellingham
Bay was summarized in the present study using abundances of the following four major taxonomic
groups:
a Polychaeta
• Mollusca
• Ampnipoda
• Other Crustacea (i.e., excluding amphipods).
All four major taxa have been used to identify problem areas in past studies of chemical contami-
nation in Puget Sound urban embayments (e.g., Tetra Tech 1985a; PTI and Tetra Tech 1988a,b).
As a group, the four taxa typically account for greater than 90 percent of the total abundance of
benthic macroinvertebrate assemblages throughout Puget Sound. Although amphipods are
crustaceans, they were considered separately because they are a group of organisms known to be
particularly sensitive to contamination (Bellan-Santini 1980). In addition, Swartz et al. (1982)
found a close inverse relationship between amphipod abundance and sediment toxicity (determined
using the amphipod mortality bioassay) in Commencement Bay.
Available Data—As mentioned earlier, only two of the six major quantitative studies of
benthic macroinvertebrate assemblages in Bellingham Bay were conducted after 1979 (i.e., Broad
et al. 1984 and CH2M HILL 1984). The remaining four studies were not considered representative
of current conditions in the bay because they were conducted prior to 1979, when water quality
was improved through installation of a secondary treatment system at the Georgia-Pacific facility.
Therefore, only the two most recent studies were used to characterize benthic assemblages in
Bellingham Bay and to identify problem areas.
Station Locations—Broad et al. (1984) and CH2M HILL (1984) sampled 35 stations throughout
Bellingham Bay (Figures 19 and 20). Twenty-five stations were located in inner Bellingham Bay
and near -the outfall of the Post Point WWTP. No stations were located in Chuckanut Bay or the
nearshore areas of the Lummi Peninsula and Portage Island. Station codes are defined in Appen-
dix A, Table A-l.
Reference Conditions—The characteristics of benthic macroinvertebrate assemblages can vary
in relation to depth, sediment character, and season of sampling. If any of these natural variables
exhibit substantial differences between test sites and reference areas, it is uncertain whether
differences found between the benthic assemblages at the two kinds of sites are the result of these
variables or chemical toxicity. Therefore, multiple reference areas were used in this study to
ensure these natural variables were as similar as possible between each test site and its respective
reference area (Table 16).
For the Broad et al. (1984) survey, two sets of reference conditions were used for stations
sampled in May and October of 1983. A station sampled in Samish Bay, a nonurban embayment
-------
Bellingham
kilometers
•CH10
Figure 19. Locations of stations sampled for benthic macroinvertebrates
in inner Bellingham Bay
82
-------
oo
ui
miles
0 1/2 1
10 1 2
kilometers
Bellingham
Lumml Bay r-
Lumml
•^ Peninsula ..
: .--•: Chucktnul C/M
Pbnage
Jsland: 7 Pt. Frances
Chuckanut Bay V
$~*\ Eliza Island
Figure 20. Locations of stations sampled for benthic macroinvertebrates in outer Bellingham Bay
-------
TABLE 16. CHARACTERISTICS OF REFERENCE AREAS FOR
BENTIIIC MACROINVERTEBRATE ASSEMIJIACES'
Stations Sampling Period Depth (m) Percent Finesb TVSC (Percent)
Reference Test Reference Test Reference Test Reference Test Reference Test
Samish Bay BR01-BR09 May 1983 May 1983 16 5-14 91 76-98 7.9 5.6-14.8
(one station)
Bellingham Bay BR11-BR21 October 1983 October 1983 24 8-29 97 67-100 9.3 55-10.0
(BR22)
Bdlingham Bay CH01-CH09 October 1983 October 1983 23 20-28 91 40-99 8.3 4591
(OHIO, CHIl)d CH12-CH14
" Characteristics are presented separately for reference and test sites. Ranges of values are presented for test sites.
b Percent fines - percent silt + clay.
c TVS = percent volatile solids.
d Characteristics were averaged for these two stations.
-------
located immediately south of Bellingham Bay, was used as the reference area for the eight stations
sampled in Bellingham Bay in May. For the 12 stations sampled in Bellingham Bay in October, the
station located closest to Chuckanut Bay (i.e., BR22; Figure 20) was used as the reference area for
the remaining 11 stations.
For the CH2M HILL (1984) survey, a single set of reference conditions was used for the 14
stations located in Bellingham Bay. It comprised the average conditions at the two stations located
closest to Chuckanut Bay (i.e., CH10 and CH11; Figure 19). These two stations were also
designated as reference stations by CH2M HILL. Chemical analyses were conducted only at Station
CH11. Although most chemical concentrations were relatively low, the concentration of mercury
(0.5 mg/kg) was elevated above the LAET (0.41 mg/kg).
Elevation Above Reference Analysis—EAR were calculated for the abundance of each major
benthic taxon at each test site relative to the mean abundance observed at the respective reference
area (Table 17; Figures 21 and 22). Significant EAR were found primarily for amphipods and
other crustaceans (17 of 31 stations for each taxon). By contrast, significant EAR for molluscs
were found at only two stations, and none of the EAR found for polychaetes was significant. The
highest EAR for amphipods were found at the seven stations at which this taxon was absent
(Stations BR07, BR15, BR16, CHOI, CH03, CH08, and CH09). The highest EAR for other
crustaceans (86) was found at Stations BR15 and BR16. A very high EAR for this taxon (48) was
also found at Stations CH08 and CH09. These stations are located near the mouth of Whatcom
Creek Waterway, the Georgia-Pacific deepwater outfall terminus, and the Post Point WWTP outfall
terminus.
Values of EAR less than 1.0 indicate the abundance of a taxon at a test site was greater than
the abundance observed at its respective reference site. Values of EAR less than 1.0 were found
primarily for polychaetes (26 stations) and molluscs (14 stations), and less frequently for amphipods
(9 stations) and other crustaceans (3 stations). In many cases, enhanced abundances of one taxon
and depressed abundances of another taxon were found at the same stations. These different
patterns of abundance are likely the result of different species exhibiting different sensitivities to
chemical toxicity. These patterns could also be influenced by differential species response to
conventional sediment variables such as the grain-size distribution and organic content of the
sediments. However, it is unlikely that conventional sediment variables substantially influenced the
observed abundance depressions, as these variables did not differ substantially between stations
with and-without depressions. For example, the mean values (and standard deviations) of percent
fine-grained sediment at stations with and without depressions were 92 (12.2) and 88 (17.5) percent,
respectively. Mean values of percent TVS were 9 (2.0) and 8 (1.4) percent, respectively. Neither
variable differed significantly (P>0.05) between the two groups of stations.
HISTOPATHOLOGY
Tissue abnormalities in marine organisms can be used as indicators of sediment chemical
contamination. In most previous urban bay action programs in Puget Sound, the prevalence of
microscopic liver lesions in English sole has been used as a key biological indicator. However, no
information on microscopic liver lesions in fishes from Bellingham Bay was found. Malins et al.
(1982) evaluated liver lesions in English sole off Eliza Island, which is approximately 2 km south
of the study area boundary. They found no neoplasms (i.e., tumors) or preneoplasms in any of the
fish examined.
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TABLE 17. EAR VALUES FOR
BENTHIC MACROINVERTEBRATE TAXA
IN BELLINGHAM BAY
EARb'c
Station"1
Refl
BR01
BR02
BR03
BR04
BR06
BR07
BROS
BR09
Ref2
BR11
BR12
BR13
BR14
BR15
BR16
BR17
BR18
BR19
BR20
BR21
Ref3
CHOI
CH02
CH03
CH04
CH05
CH06
CH07
CH08
CH09
CH12
CH13
CH14
Polychaetes
(30/0.1 m2)
<0.1
<0.1
<0.1
<0.1
<0.1
0.2
<0.1
0.5
(30/0.1 m2)
<0.1
<0.1
<0.1
0.3
0.6
1.7
0.6
1.5
2.7
0.6
0.5
(27/0.1 m2)
1.1
0.9
0.7
0.2
0.4
0.3
0.3
0.9
1.0
0.8
0.9
0.9
Molluscs
(36/0.1 m2)
18*
0.4
0.5
2.3
0.2
14*
0.4
0.3
(59/0.1 m2)
1.1
1.0
0.4
1.5
3.2
3.0
0.4
0.6
2.6
0.4
0.5
(56/0.1 m2)
4.3
0.6
1.9
4.1
2.8
0.5
0.6
0.7
1.5
1.2
1.5
2.1
Amphipods
(45/0.1 m2)
0.1
0.2
45*
90*
2.4
U*
0.6
9.0*
(7.5/0.1 m2)
0.3
0.1
5.0
7.5*
U*
U*
1.3
1.7
5.0
0.6
0.7
(6.2/0.1 m2)
U*
0.9
U*
16*
16*
10*
0.6
U*
U*
6.2*
5.2*
7.8*
Other
Crustaceans
(100/0.1 ro2)
0.3
0.9
2.1
18*
1.3
50*
1.4
1.1
(43/0.1 m2)
14*
0.6
3.4
17*
86*
86*
1.6
14*
12*
1.2
2.3
(57/0.1 m2)
12*
5.0
14*
32*
15*
3.3
3.0
48*
48*
9.2*
9.5*
14*
a Stations denoted by the prefix "Ref" are the reference stations (described in text)
with which each group of test stations were compared.
b Values in parentheses for the reference stations are numbers of individuals per
O.lm2. All other values are EAR derived from comparisons with respective
reference stations.
c Asterisks denote significant EAR (i.e., >5.0). The qualifier U denotes an EAR was
undefined because the value of the denominator was zero. All undefined EAR were
considered significant.
86
-------
Beilingham
O No significant depressions
One or more taxa
significantly depressed
Figure 21. Distribution of significant benthic depressions in inner Beilingham Bay
87
-------
Nooksack River'
Lumml Bay
Bellingham
Peninsula ,i^
Pttftage
Jsland.-.V PI- Frances
O No significant depressions
Chuckanut Bay
»
One or more taxa
significantly depressed
Governors
Pt.
miles
0 1/2 1
!MV4 Eliza Island
0 1 2
kilometers
Figure 22. Distribution of significant benthic depressions in outer Bellingham Bay
-------
Numerous investigators have sampled fishes and large macroinvertebrate populations
throughout Bellingham Bay between 1934 and 1984 (review in CH2M HILL 1984), and none
reported high prevalences of grossly visible external abnormalities or parasites in the organisms
examined. More recently, fish populations have been sampled intensively in the central part of
Bellingham Bay as part of the PSDDA evaluation of the proposed unconfined, open-water disposal
site in the bay (Dinnel et al. 1988; Donnelly et al. 1988). No unusually high prevalences of grossly
visible abnormalities were reported in either of those two studies.
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DATA SUMMARY: MICROBIAL CONTAMINATION
Water and shellfish contaminated with enteric bacteria and viruses present a risk to public
health. Swimming in these waters or eating shellfish contaminated with these microorganisms can
result in gastroenteritis, nausea, diarrhea, typhoid fever, cholera, and hepatitis. The organisms of
primary concern are pathogenic enteric bacteria present in human and animal feces (e.g., Salmon-
ella spp., Yersinia enterocolotica, Campylobacter fetus, Vibrio parahaemoiyticus, and Vibrio choleras
(Munger et al. 1979). These microorganisms are often found in raw or inadequately treated sewage.
Washington state standards for commercial shellfish harvesting and recreational use of water
bodies are based on the concentration of fecal coliform bacteria in water and shellfish tissue
(WAC 173-201-045) (Lilja, J., 7 March 1989, personal communication). The National Shellfish
Sanitation Program standard for approved shellfish-growing waters and the Washington state fecal
coliform bacteria standard for Class A marine waters are the same (Cleland 1985). Because no
record of human illness resulting from eating commercially harvested shellfish from Washington
state waters exists, the state standards can be considered protective (Tetra Tech 1988b).
DATA SYNTHESIS
Choice of Indicators
Fecal coliform bacteria measurements have been traditionally used as a microbial indicator of
water quality. The primary reason for using these organisms is they indicate the presence of
human and animal fecal material that can contain pathogenic organisms. In addition, fecal coliform
bacteria are generally present in large numbers in fecal discharges, and are relatively inexpensive
and easy to identify and quantify (Faigenblum 1988).
The following analysis is based on available data for fecal coliform bacteria concentrations
in marine and fresh waters and concentrations in shellfish from Bellingham Bay. Little information
on discharges of untreated wastewater to Bellingham Bay (e.g., via CSOs, storm drains, and surface
runoff) exists. No data were found on other microbial indicator organisms (e.g., enterococci
bacteria) or on pathogens. Only data collected after 1979 were evaluated, because earlier data were
not considered representative of present conditions in the bay.
Available Data and Station Locations
Measurements of fecal coliform bacteria in marine waters were obtained from several sources
(Table 18). Data were collected from the three Ecology ambient water quality monitoring stations
at three locations in Bellingham Bay: the inner bay near the Starr Rock disposal area (Station
EC02), Post Point (Station EC02), and Point Francis (Figures 23 and 24). Other stations in marine
waters included seven stations sampled by DSHS in and around Portage Bay during 1984 and 1985
(Cook 1985; Cleland 1985) and seven stations sampled by CH2M HILL around the terminus of the
Post Point sewage outfall (CH2M HILL 1984) (Figures 23 and 24). Fourteen stations were sampled
90
-------
TABLE 18. FECAL COLIFORM DATA AND EAR VALUES
BELLINGHAM BAY AND FRESHWATER TRIBUTARIES
1980-1987
Fecal Coliform
.Area
Marine Stations'5
Point Francisc
Post Point""
Nun Buoy #4C
North control - surfaced
North control - middle (9 m)d
North control - bottom (20 m)d
ZID boundary, north - surface
ZID boundary, north - middle (12 m)d
ZID boundary, north - bottom (23 m)d
ZID boundary, east - surfaced
ZID boundary, east - middle (9 m)J
ZID boundary, east - bottom (18 m)d
ZID - surface^
ZID - middle (12 m)d
ZID - bottom (19 m)d
ZID boundary, 25 m south - surfaced
ZID boundary, 25 m south middled
ZID boundary, 25 m south - bottomd
ZID boundary, 200 m south - surfaced
ZID boundary, 200 m south - middled
ZID boundary, 200 m south - bottomd
South control surfaced
South control - middle (12 m)d
South control - bottom (24 m)d
W. Portage Bave
N.W. Portage Baye
N.E. Portage Bay6
E. Portage Bay6
Central Portage Baye
Inner Portage Bave
S.W. Portaee Bay^
Ecology 198018 surface
Ecology 1980^ surface
Ecology 1980Lg surface
Ecology 1980tg middle
Ecology "^SO48 surface
Ecology I98tf-s middle
Ecology 1980tg surface
Ecology IM/Oh* middle
Ecology 1980tg surface
Ecology 1980^ middle
Ecology 1980tg bottom
Ecology 1980* surface
Ecology 1980* middle
Ecology 1980* bottom
Ecology 19801 surface
Ecology 19801 middle
Ecology 19801 surface
Ecology 1980* middle
Ecology 1980* surface
Ecology 1980* middle
Ecology 19801 surface
Ecology 1980f middle
Station
Codes
EC03
EC02
EC01
CH04
CH04
CH04
CH05
CH05
CH05
CH02
CH02
CH02
CH07
CH07
CH07
CH08
CH08
CH08
CH09
CH09
CH09
CH11
CH11
CH11
CL01
CL02
CL03
CUM
CL05
CL06
CL07
ST01
ST02
ST03
ST03
ST04
ST04
ST05
ST05
ST06
ST06
ST06
ST07
ST07
ST07
ST08
ST08
ST09
ST09
ST10
ST10
ST11
ST11
No. of
Samples Minimum
41 <1
54 <1
59 <1
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1-8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
12 < 1.8
14 < 1.8
O ^ l.O
14 <1.8
5 < 1.8
14 < 1.8
14 < 1.8
13 < 1.8
1
1
1
1
1
1
1
1
1
1
1
1
1
1 — •
1
1
1
1
1
1
1
1
Maximum
28
77
300
110
13
49
79
33
23
33
21
130
22
4.5
5
33
23
2
11
79
7
33
2
2
350
240
220
33
49
240
22
-
-
-
—
-
—
—
-
-
—
—
-
—
-
-
-
-
_
—
—
—
-
Bactenad
Geometric
Mean
<1.4
<2.4
<7.6
<6.0
<2.8
<2.5
< 3.1
<3.1
<2.4
<6.1
<2.8
<2.8
<4.6
<2.1
<2.2
<3.4
<2.4
< 1.9
<4.1
<33
<2.5
<2.8
<1.9
<2.0
<3.7
<7.4
<3.9
<4.9
<2.9
<3.6
<3.6
80
68
29
17
23
2
5
1
5
< 1
< 1
< 1
9
I
1
< 1
1
3
12
< l
3
3
EAR
<0.10
<0.17
<0.54
<0.43
<0.20
<0.18
<0.22
<0.22
<0.17
<0.43
<0.20
<0.20
<0.33
<0.15
<0.16
<0.24
<0.17
<0.14
<0.29
<0.24
<0.18
<0.20
<0.14
<0.14
<0.26
<0.53
<0.28
<035
<0.21
<0.26
<0.26
0.80
0.68
0.29
0.17
0.23
0.02
036
0.07
036
<0.07
<0.07
<0.07
0.64
0.07
0.07
<0.07
0.07
0.21
0.86
<0.07
0.21
0.21
91
-------
TABLE 18. (Continued)
Area
Fecal Coliform Bactenaa
Station
Codes
No. of
Samples
Minimum Maximum
Geometric
Mean
EAR
Marine Stations (continued)
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology
Ecology
1980r surface
1980r surface
19801 middle
1980* bottom
19801 surface
1980* middle
1980* bottom
ST12
ST13
ST13
ST13
ST14
ST14
ST14
65
4
56
4
464
0.29
4.00
0.29
<0.07
0.57
0.07
Freshwater Stations'1
Chuckanut Creekd
Padden Creekd
Whatcom CreekJ
Squalicum Creeka
Nooksack RiverJ
CH15
CH16
CH17
CH18
CH19
12
12
12
12
12
17
33
11
11
33
3,000
UOO
2,200
UOO
310
263.6
331.1
291.1
120.8
115.1
2.64
3.31
2.91
1.21-
1.51
Shellfish Stations'
Portage Bay west'
Portage Bay southwest'
Portage Bay east'
Post PointJ
CO01
CO02
CO03
FA01
130
<20
330
490
207
20
790
<130
0.90
0.09
3.43
<0.57
a Concentrations for marine and freshwater samples are organisms/100 mL water. Concentrations for shellfish samples are
organisms/100 grams tissue. Values denoted as "<" reflect one or more undetected values. In calculating geometric means.
detection limits were used for undetected values. An EAR > 1.0 was considered significant (i.e., the applicable water quality
standard or tissue guideline was exceeded).
b Class A marine water quality standard: geometric mean concentration of fecal coliform shall not exceed 14 organisms/
100 mL (WAC 173-201-045). This standard applies to all stations except Stations ST01 to ST06, and was used to calculate
EAR.
L Ecology ambient monitoring program (data from EPA and Ecology); data were averaged for all measurements made
during all years between 1980 and 1987.
d CHjM Hill (1984).
e Cook (1ST85); Cleland (1985).
f Stanley (1980).
g Class B marine water quality standards: geometric mean concentration of fecal coliform shall not exceed 100 organisms/
100 mL (AVAC 173-201-045). This standard applies only to Stations ST01 to ST06 and was used to calculate EAR at those
stations.
Class A freshwater quality standard: geometric mean concentration of fecal coliform bacteria shall not exceed 100
organisms/100 mL (WAC 173-201-045).
' FDA commercial shellfish guideline: geometric mean concentration of fecal coliform bacteria shall not exceed 230
organisms/100 grams tissue.
j Faigenblum(1988).
92
-------
/,£>>'
Septic Tanks
>ST08
0 1
kilometers
EC02'
ST11»
Bellingham
•ST09
CH09
CH07
ST06
• Water samples
o Tissue samples
Figure 23. Locations of stations sampled for fecal coliform bacteria in water and
shellfish tissue from inner Bellingham Bay
93
-------
Lumml Bay I •
Bellingham
Lumml
Peninsula .f.\
i/:..CL02 .7 CL04
w • <*
CL01 v.. M.CL03
CO01°
X
CO02
Pdrtage
Jsland,-/ Pt. Frances
& CLO? •
Chuckanul Bay \
• Water samples
o Tissue samples
Governors
Pt.
miles
0 1/2 1
Eliza Island
0 1 2
kilometers
Figure 24. Locations of stations sampled for fecal coliform bacteria in water and shellfish tissue in outer Bullingham Bay
-------
for fecal coliform bacteria in Bellingham Bay and the Whatcom Creek Waterway (Figure 23) on 8
April 1980 after the Georgia-Pacific secondary treatment lagoon was installed (Stanley 1980).
Station codes are defined in Appendix A, Table A-l.
Data on bacteriological measurements in fresh waters were obtained from a survey performed
by CH2M HILL at the mouths of Chuckanut, Padden, Whatcom, and Squalicum creeks and the
Nooksack River (Figures 23 and 24). Monthly sampling for this survey occurred from October
1983 through September 1984 (CH2M HILL 1984).
Measurements of fecal coliform bacteria in shellfish tissue were obtained from two DSHS
surveys in Portage Bay (Cook 1985; Cleland 1985), and a study performed by DSHS and EPA
during 1986-1987 off Post Point (Faigenblum 1988) (Figures 23 and 24).
Two different laboratory techniques were used to generate bacteriological water quality data
for Bellingham Bay samples: multiple-tube most probable number (MPN) and membrane filtration.
Although these two methods are considered equivalent (APHA 1985), the MPN method can
sometimes result in higher values than the membrane-filtration technique. The MPN method was
used for the DSHS studies and the CH2M HILL surveys. The membrane filtration technique was
used for the remaining measurements.
Reference Data
Reference data were based on Washington state standards for fecal coliform bacteria
concentrations in water (Ecology and DSHS) and in shellfish (DSHS). Ecology standards for fecal
coliform bacteria for the waters of the Bellingham Bay study area are as follows:
• Class A Marine—"...shall not exceed a geometric mean value of 14 organisms/100 mL
with not more than 10 percent of samples exceeding 43 organisms/100 mL" [WAC
173-201-045(2)(c)(i)(B)]
• Class B Marine—"...shall not exceed a geometric mean value of 100 organisms/100
mL, with not more than 10 percent of samples exceeding 200 organisms/100 mL"
[WAC 173-201-045(3)(c)(iXB)]
• Class A Fresh—"...shall not exceed a geometric mean value of 100 organisms/100 mL,
with not more than 10 percent of samples exceeding 200 organisms/100 mL" [WAC
173-201-045(2)(c)(i)(A)].
The maximum allowable fecal coliform bacteria concentrations for commercial shellfish harvesting
areas certified by DSHS are as follows:
• Shellfish tissue—230 organisms/100 grams (FDA guideline)
• Water—A median of 14 organisms/100 mL with not more than 10 percent of the
samples exceeding 43 organisms/100 mL (note: this standard is similar to the Class
A standard for marine waters; see above).
-------
Elevation Above Reference Analysis
Geometric means for fecal coiiform bacteria concentrations were calculated from all available
information. For stations where only one value was available, that value is presented in this report.
EAR values were calculated as the quotient of the geometric mean bacteria concentration divided
by the appropriate regulatory standard (see above). Therefore, EAR values greater than 1 indicate
that the geometric mean bacterial concentration failed to meet the water quality standard, and EAR
values below 1 indicate that the geometric mean bacteria concentration met the water quality
standard. For example, the geometric mean concentration of fecal coiiform bacteria at
Station EC03 is <1.4 organisms/100 mL (see Table 18). Because the Class A marine water quality
standard is 14 organisms/100 mL, the calculated EAR value for this station is <0.10.
Note that the Class A water quality standards for fresh water and the Class B water quality
standard for marine water are both 100 organisms/100 mL, and the maximum allowable concentra-
tion of fecal coiiform bacteria in shellfish tissue is 230 organisms/100 grams. The detection limit
reported in each data source was used for the undetected values in the calculations.
Marine Waters—The Class A marine water quality standard of 14 organisms/100 mL was
exceeded at two stations from the 1980 Ecology survey. The highest EAR values were detected in
the vicinity of the Georgia-Pacific deepwater outfall. Stations ST12 and ST13 (Figure 23) had
EAR values of 4.64 and 4.00, respectively. These samples were collected on 8 April 1980.
However, these values may be the result of the presence of the fecal coiiform bacterium Klebsiella,
which is commonly found associated with pulp mill effluents and is not specific to mammalian
fecal material.
As noted previously, the second component of the Class A marine water quality standards
states that "not more than 10 percent of samples exceeding 43 organisms/100 mL" (WAC 173-201-
045). This standard was not exceeded at the Point Francis ambient monitoring station (EC03)
between 1982 and 1987 (Solomon, F., 23 March 1989, personal communication). However, this
standard was exceeded four times between 1980 and 1987 at the Post Point ambient monitoring
station (EC02) and five times between 1980 and 1987 at the Starr Rock ambient monitoring station
(EC01) (Figure 25) (U.S. EPA 1989; Solomon, F., 23 March 1989, personal communication).
Fresh Waters—The Class A freshwater standard of 100 organisms/100 mL was exceeded at all
freshwater stations evaluated (Table 18). The greatest exceedance of the freshwater standard was
at Padden Creek (EAR=3.31), followed by Whatcom Creek (EAR=2.91), Chuckanut Creek
(EAR=2.64), Nooksack River (EAR=1.51), and Squalicum Creek (EAR=1.21). No explanations
for these elevated values were provided by CH2M HILL (1984).
Storm Drains—No information was found for measurements of fecal coiiform bacteria in
storm drains in the Bellingham Bay study area.
Shellfish—Shellfish at only one station (C003) in Portage Bay exhibited fecal coiiform bacteria
concentrations in tissue greater than the FDA guideline of 230 organisms/100 grams of tissue
(EAR=3.43). Although four of the seven individual samples of Post Point (Station FA01) exceeded
-------
50
Z 40-
03
CD
CO
n
O
CD
n
Station EC01
1980 1981 1982 1983 1984 1985 1986 1987
CO
c
O 50
40-
30-
20-
10-
Station EC02
1980 1981 1982 1983 1984 1985 1986 1987
(Class A water quality standard = 10%)
Note: The standard was
not exceeded at station
EC03 during any year
(i.e., 1982-1987)
Figure 25. Percent of fecal coliform bacteria observations that violated the Class A
water quality standard
97
-------
.the FDA standard, the geometric mean for all samples collected at this location was less than 130
(Table 18).
Septic System Failures—Measurement of fecal coliform bacterial concentrations in surface
water drainage in the residential area south of Marine Drive, west of the cement plant pier, and
east of the cement plant in Bellingham indicate untreated sewage was entering Bellingham Bay in
this area (Figure 23). During a survey of drainage in this area (1980-1981), three of four
residential septic tanks were determined to be contributing to high levels of fecal coliform bacteria
in the surface water (Kloc, B., 1 March 1989, personal communication). The surface water drains
into Bellingham Bay via the beach in this area. The septic tank problem is currently about 90
percent corrected (Kloc, B., 1 March 1989, personal communication).
Kloc (1 March 1989, personal communication) described one occasion when the sanitary sewer
became plugged and raw sewage was diverted to Padden Creek. This situation was discovered
quickly and corrected within a few hours.
-------
DATA SUMMARY: EUTROPHICATION
Eutrophication in marine waters can result in large amounts of organic material (e.g.,
phytoplankton, raw sewage) decomposing in a body of water. Decomposition of organic material
consumes dissolved oxygen, and eutrophic environments generally have low dissolved oxygen
concentrations in near-bottom waters. Low dissolved oxygen concentrations cause physiological
stress to demersal, epibenthic, and benthic organisms that may exacerbate toxic stress. In extreme
cases, low dissolved oxygen concentrations can result in the mortality of these organisms. Nutrient
enrichment can increase algal biomass in environments where low nutrient concentrations limit algal
growth. In such environments, nutrient inputs can contribute indirectly to problems of low
dissolved oxygen caused by algal decomposition.
DATA SYNTHESIS
Choice of Indicators
Eutrophic conditions in Bellingham Bay were evaluated by analyzing the concentrations of
dissolved oxygen, nitrate-nitrogen, ammonia-nitrogen, and phosphate in surface, mid-water, and
near-bottom waters. Only data collected after 1979 were evaluated, because earlier information was
not considered representative of present conditions in the bay.
Available Data and Station Locations
Ecology's ambient water quality monitoring program provided the most representative
information on dissolved oxygen, nitrogen, and phosphorus for Bellingham Bay. These data were
obtained from the EPA STORET system (U.S. EPA 1989; Solomon, F., 23 March 1989, personal
communication). Water quality data were collected at the same three locations in Bellingham Bay
described previously for microbial contamination: Stations EC01, EC02, and EC03 (Figure 26).
Information collected from 1980 to 1987 was analyzed for Stations EC01 and EC02 and data
obtained from 1982 to 1988 were evaluated for Station EC03. Station codes are defined in
Appendix A, Table A-l.
DISSOLVED OXYGEN
The water quality standard for Class A marine waters in Washington specifies that "dissolved
oxygen shall not be reduced below 6.0 mg/L" [WAC 172-20 l-045(2)(c)(ii)(B)]. Monthly trends in
dissolved oxygen concentrations for the period of study at each of the ambient monitoring stations
are presented in Figure 27. Dissolved oxygen concentrations were depressed below this level
several times at each ambient monitoring station within Bellingham Bay. At Station EC01,
concentrations were below 6.0 mg/L 10 times between 1980 and 1987. All but two of these low
measurements occurred in near-bottom waters. A dissolved oxygen concentration of 4.2 mg/L was
recorded on 6 September 1983 at a depth of 10 meters below the surface. At Station EC02,
dissolved oxygen levels were below 6.0 mg/L on 16 occasions between 1980 and 1987. Ten of these
-------
o
o
& ^Portage Bam
Figure 26. Locations of stations sampled for dissolved oxygen, nitrogen, and phosphate in the water column
-------
Ration tCOl
CD
en
>
X
o
CD
_>
O
CO
CO
Q
10-1
.1
9-1-
Apr May Jun Jul Aug 3«p Oel Nov
Nation tC02
10-
9-
a •
7 •
9 •
Apr Uay Jul Aug 3
-------
occurrences took place in near-bottom waters (i.e., 30 meters below the surface). Of the remaining
occurrences, four were found at a depth of 10 meters below the surface and two were found at the
surface. The lowest measurement (4.1 mg/L) was found at the surface on 1 October 1985. Slightly
depressed dissolved oxygen measurements were found on three occasions at Station EC03 between
1982 and 1988. The lowest value of 5.6 mg/L was measured at the surface on 1 July 1987.
NUTRIENTS
Nitrogen
There are no water quality standards for nitrogen in marine waters of Washington. Nitrogen
concentrations in the water column can influence primary productivity and thus indirectly affect
dissolved oxygen concentrations. Nitrogen concentrations in the waters of Bellingham Bay are
presented in this report as the sum of nitrate and ammonia, which are forms of nitrogen readily
available for assimilation by phytoplankton.
Monthly geometric means of nitrogen concentration were calculated for various depths at
Stations EC01, EC02, and EC03 (Figure 28). Surface concentrations at Station EC01 were lowest
during July and August. At this station, concentrations were greater at the 10-meter depth than
at the surface for all months evaluated. Trends in nitrogen concentrations at Station EC03 were
similar to those at Station EC01, except the lowest concentrations extended from June, July,
August, and October. Nitrogen concentrations at this station were greater at the 10-meter depth
than at the surface for each month. At Station EC02, nitrogen concentrations increased with
increasing depth for all months except October and November. During these two months,
concentrations were greatest at the 10-meter depth. The lowest nitrogen concentrations occurred
in June, July, and August. Nitrogen concentrations at all three stations were inversely related to
amount of sunlight available for photosynthesis.
Phosphorus
There are no water quality standards for phosphorus concentrations in marine waters of
Washington. Like nitrogen, phosphorus concentrations in the water column affect primary produc-
tivity and_ thus indirectly affect dissolved oxygen concentrations. The form of phosphorus used in
this report for evaluation is orthophosphate, the form most readily taken up by phytoplankton.
Geometric mean concentrations of phosphate were calculated monthly for various depths at
Stations EC01, EC02, and EC03 (Figure 29). At Station EC03, phosphate concentrations were
greater at the 10-meter depth than at the surface. Also, concentrations decreased in the summer
months and then increased again in the fall. The highest phosphate measurements were found in
samples taken from the 10-meter depth in September. Trends in phosphate concentrations at
Station EC01 were similar to those at Station EC03. The greatest concentrations of phosphate at
this station were recorded in November for both the surface and 10-meter depths. Differences
among depths were much greater at Station EC01 than EC03. Phosphate concentrations at
Station EC02 also exhibited an increase with increasing depth for all months except November.
During November, the geometric mean concentration of phosphate was almost equal at the surface,
10-meter, and 30-meter depths. The lowest concentration of phosphate at the surface occurred in
June and August.
-------
CD
O)
o
itation cCOl
A
03 1 «\
Apr Uiy Jun Jul Aug 3«p Oct NOT
itation tC02
AW Uly Jun Jul Aug 3«p Oct Nov
Station EC03
Apr Miy Jun Jul Aug 3«o Oct Nov
• Surface
* 10 m
30 m
Figure 28. Monthly variation of nitrogen concentrations averaged over the period 1980-1988
103
-------
itation tCOl
0.15 •)
Apr Miy Jun Jul Aug 8>p Get Nov
> t a 11 o n
O}
0
"CD
JZ
CL
CO
O
<—
CL
0.15-1
Apr M«y Jun Jul Aug 3«p Oet No*
Station EC03
0.03-|
A or May Jun Jul Aug 3«D Oct Nov
• Surface
+ 10 m
* 30 m
Figure 29. Monthly variation of phosphate concentrations averaged over the
period 1980-1988
104
-------
IDENTIFICATION OF PROBLEM STATIONS
CHEMICAL CONTAMINATION
Indicators of chemical contamination and biological effects at each station in Bellingham Bay
were evaluated for problem station identification using the action-level criteria presented in
Table 1. Concentrations of organic compounds and metals were considered moderately significant
for problem area identification if they exceeded their respective LAET. Concentrations were
classified as highly significant if they exceeded their respective HAET. Values of amphipod
mortality were considered moderately significant for problem station identification if they could
be discriminated statistically from the reference value in Sequim Bay. Values were classified as
highly significant if they exceeded 50 percent. Abundances of benthic macroinvertebrate major
taxa were considered moderately significant for problem area identification if they were depressed
below reference abundances by 80 percent or more. Depressed abundances were considered highly
significant if they exceeded 95 percent.
A station was considered a problem station if any one indicator was highly significant or if
any two indicators were moderately significant. A station was considered a potential problem
station if any single indicator was moderately significant, but not' highly significant.
Of the total of 66 stations evaluated, 53 stations (80 percent) were characterized by only a
single indicator (Table 19). Six stations were characterized by two indicators, seven stations were
characterized by three indicators, and no stations were characterized by all four indicators.
Concentrations of organic compounds were not significant for any station, and therefore did not
contribute to the identification of problem stations. Concentrations of metals were highly
significant at only one station, but were moderately significant at 18 stations. In all but one
instance (i.e., copper at Station BA03), mercury was elevated above its LAET. Values of amphipod
mortality were highly significant at a single station, and moderately significant at two stations.
Depressed abundances of benthic macroinvertebrate major taxa exhibited the largest number of
highly significant values (9) of any of the four indicators. Depressed abundances were moderately
significant at 12 stations.
Thirteen stations were classified as problem stations according to the action-level criteria
(Table 20; Figures 30 and 31). These stations were grouped into the following four problem areas:
• Mouth of Whatcom Creek Waterway (five stations)
• Area near the terminus of the Georgia-Pacific outfall (two stations)
• Area immediately inshore of the terminus of the Post Point WWTP outfall (five
stations)
• A small area off the Fairhaven shoreline (one station).
The first three problem areas are located near potential sources of contamination (i.e., Whatcom
Creek Waterway and its surrounding upland areas, the Georgia-Pacific outfall, and the Post Point
WWTP outfall), whereas the fourth area is not located near an obvious potential contaminant
source.
-------
TABLE 19. STATION CHARACTERISTICS RELATIVE
TO PROBLEM AREA IDENTIFICATION*
Station
BA01
BA02
BA03
BA04
BA05
BA06
BA07
BA08
BA09
BA10
BAH
BA12
BA13
BA14
BA15
BA16
BA17
BA18
BA19
BA20
BA21
BA22
BA23
BA24
BA25
BA26
BR01
BR02
BR03
BR04
BROS
BR06
BR07
BROS
BR09
BRIO
BR11
BR12
Organic
Compounds'5
__
—
ns
ns
ns
—
ns
—
—
..
ns
ns
..
..
..
..
—
..
—
—
-.
—
ns
ns
..
--
..
..
..
..
..
..
..
..
..
..
..
--
Indicator
Metaisc Toxicityd
ns
ns
* ns
**
* *
*
ns
ns
*
ns
* ns
* ns
ns
»
*
*
ns
ns
ns
ns
ns
ns
* * *
* ns
*
*
..
«
» —
__
.. --
—
.. -•
.-
» -•
« --.
.. --
..
Benthic
Effects6
.._
—
—
—
—
—
—
.-
—
—
—
..
—
..
..
..
—
—
—
—
—
—
—
—
—
--
*
ns
**
**
—
ns
**
ns
*
.-
*
ns
106
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TABLE 19. (Continued)
Indicator
Organic
Station Compounds'5
BR13
BR14
BR15
BR16
BR17
BR18
BR19
BR20
BR21
BR22
CHOI
CH02
CH03
CH04
CH05
CH06
CH07
CH08
CH09
CH10
CH11
CH12
CH13
CH14
MA01 ns
MA02 ns
RE01
RE02
Benthic
Metals' Toxiciryd Effects'
ns
*
* *
* *
ns
*
*
ns
ns
ns
**
ns
**
*
*
*
ns -- ns
**
*»
ns
* - ns
*
*
V
*
*
* *
ns
a A dash (--) signifies that no data were available at a station for a particular indicator.
b ns = ail concentrations < LAET.
c ns = ail concentrations LAET
** = any concentration >HAET.
d ns = amphipod mortality not significant (P>0.05)
* = mortality significant (P < 0.05) and <50%
** = mortality significant (P < 0.05) and >50%.
e ns = no taxon depression >80%
* = at least one taxon depression >80%, but <95%
** = at least one taxon depression >95%.
107
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TABLE 20. PROBLEM STATIONS AND POTENTIAL PROBLEM
STATIONS WITH RESPECT TO CHEMICAL CONTAMINATION
IN BELLINGHAM BAY3
Classification Station
Problem station BA04
BA05
BA23
BR03
BR04
BR07
BR15
BR16
CHOI
CH03
CH08
CH09
RE01
Potential problem station BA03
BA06
BA07
BA09
BAH
BA12
BAH
BA15
BA16
BA23
BA24
BA25
BA26
BR09
BR11
BR14
BR18
BR19
CH04
CH05
CH06
CH12
CH13
CH14
MA01
MA02
Significant Indicator
Metals
Metals, toxicity
Metals, toxicity
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Metals, toxicity
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Metals
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Benthos
Metals
Metals
" Classifications were based on information presented in Table 19.
108
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Beliingham
Note: Contours should be
considered as estimates only
o Apparently Unimpacted Station
• Potential Problem Station
Problem Station
2 Problem Area
|~) Potential Problem Area
Figure 30. Classification of stations in inner Beliingham Bay according to action-level criteria
109
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Nooksack River
Lumml Bay
Bellmgham
H
Lumml
Peninsula
&!&& Falrhaven
P&rtage
island.:•:/ PI. Frances
miles
0 1/2 1
Chuckanut
0 1 2
kilometers
Governors
Pt.
Note: Contours should be
considered as estimates only
o Apparently Unimpacted Station
• Potential Problem Station
::: x^:':1:^. Potential Problem Area
!;1 Eliza Island
Figure 31. Classification of stations in outer Bellingham Bay according to action-level criteria
-------
Twenty-six stations were classified as potential problem stations (Table 20; Figures 30 and 31).
Most of these stations were located in a large group that extended from the I&J Street and Whatcom
Creek waterways along the eastern shoreline of Bellingham Bay to Post Point, and then into the
central part of the bay. Only two stations (BR11 and CH11) were separate from the large group.
The large group encompassed the four problem areas.
MICROBIAL CONTAMINATION
Problem stations with respect to microbial contamination in Bellingham Bay were identified
on the basis of violations of the Washington state water quality standards and the FDA guideline
for tissues. For marine waters, the state standards for geometric mean bacterial concentrations in
Class A and B waters (i.e., 14 and 100 organisms/100 mL, respectively) were violated at Stations
ST12 and STB near the Georgia-Pacific deep water outfall. However, a large fraction of the
bacteria could have been comprised of Klebsiella, which is a fecal coliform bacteria often associated
with pulp mill discharges, but not specific to mammalian fecal pollution. The second state standard
for Class A marine waters (i.e., no more than 10 percent of samples exceeding 43 organisms/100
mL) was violated five times between 1980 and 1987 at Station EC01 near the Starr Rock dredged
material disposal area, and four times during the same time period at Station EC02 near the Post
Point WWTP outfall.
For fresh waters, the state standard for Class A waters (i.e., 100 organisms/100 mL) was
violated at all five stations evaluated in this study. All of those stations were located at the mouths
of the five major sources of fresh water to Bellingham Bay (i.e., Nooksack River, Squalicum Creek,
Whatcom Creek, Padden Creek, and Chuckanut Creek). The EAR values at the two former sources
were less than or equal to 1.5, whereas the EAR values at the latter three sources were greater
than 2.5.
For shellfish tissue, the FDA guideline of 230 organisms/100 grams was violated on the basis
of geometric mean values only at Station CO03 in Portage Bay. On the basis of individual shellfish,
the standard was violated at Stations CO01 and CO03 in Portage Bay and at Station FA01 off Post
Point.
EUTROPHICATION
Problem stations with respect to eutrophication in Bellingham Bay were identified on the basis
of violations of the Washington state water quality standard of 6.0 mg/L for Class A marine waters.
Concentrations of dissolved oxygen were evaluated for only three stations in Bellingham Bay. The
state standard was violated at least one time since 1980 at all three stations. However, the total
number of violations during that period was highest for Station EC002 near the Post Point WWTP
outfall (16 violations), lowest for Station EC03 near Point Francis (3 violations), and intermediate
in magnitude at Station EC01 near the Starr Rock dredged material disposal site. Concentrations
lower than 5.0 mg/L were observed twice at Stations EC01 and EC02. Concentrations lower than
4.0 mg/L were not observed at any site.
-------
IDENTIFICATION OF DATA GAPS AND RECOMMENDATIONS
Although a large amount of information was reviewed for this report, important gaps were
found in the historical database and are identified in this section. A data gap was considered
important if it substantially limited the degree to which a comprehensive evaluation of environ-
mental degradation in Bellingham Bay could be conducted. In most cases, additional field sampling
would be required to collect this missing information.
CONTAMINANT SOURCES
Almost no information was found on contaminant input to Bellingham Bay from the Nooksack
River and storm drains. In addition, few environmental samples were collected near either of these
potential contaminant sources. The Nooksack River should be evaluated as a potential contaminant
source because it drains a large area influenced by agricultural activities and several small
communities. In addition, the river is the major source of fresh water to the bay. Storm drains
should be evaluated because many drain industrial and urban areas throughout the city of
Bellingham during storm events. This surface runoff could sometimes contain substantial quantities
and concentrations of contaminants.
INDICATORS OF CONTAMINATION
A relatively large amount of historical information was found for metals concentrations in
sediment and for abundances of benthic macroinvertebrates in Bellingham Bay. By contrast, a
small amount of information was available for other important indicators of contamination such as
organic compounds in sediment, sediment toxicity, bioaccumulation, and fish pathology. Additional
information on several of these latter indicators would be helpful in providing a more compre-
hensive assessment of environmental degradation in the bay.
For chemical contaminants in general, vertical profiles of contamination at selected locations
in Bellingham Bay would be useful for evaluating whether subsurface sediments could cause
environmental problems if they were exposed by natural processes (e.g., current scour, organism
burrowing) or anthropogenic activities (e.g., dredging). Vertical profiles would also be useful for
evaluating historical patterns and sources of contamination, temporal variability of contaminant
concentrations in the environment, and the likely recovery periods if present contaminant sources
are controlled.
For organic compounds, additional stations should be located in areas of Bellingham Bay near
potential contaminant sources or in areas that have not been sampled previously using appropriate
detection limits. Examples of such areas include the Squalicum Harbor marina, Squalicum
Waterway, the area near the Georgia-Pacific deepwater outfall, the area near the Post Point WWTP
outfall, and the mouth of the Nooksack River. In addition to sampling more stations, a greater
range of chemicals should be analyzed for, such as pesticides, dioxins, tributyltin, and compounds
characteristic of pulp mill discharges (e.g., alkylated phenols, guaiacols, and resin acids).
-------
For sediment toxicity, additional stations should be located in areas where chemical analyses
suggest that sediment toxicity may be a problem. This tiered approach would probably require
separate sampling efforts to collect sediments for chemical analyses and bioassays. It would be
preferable if one or more bioassays were conducted in conjunction with the amphipod mortality
test to evaluate other species that may be responsive to different contaminants than the amphipods.
In addition, the use of a long-term bioassay in conjunction with the amphipod mortality test would
be helpful in assessing the potential chronic toxicity of sediment contamination.
For bioaccumulation, contaminant concentrations in muscle tissue of crabs and whole body
tissue of bivalve molluscs should be evaluated in the more contaminated areas of Bellingham Bay
to evaluate the risk to human health from consumption of contaminated seafood. The target
contaminants should be PCB and mercury because both chemicals can bioaccumulate to levels that
threaten human health. In addition, studies have shown these contaminants to be elevated in
sediments in several parts of the bay. The target species should include the Dungeness crab and
a recreationally important bivalve. Dungeness crabs should be evaluated because they are harvested
throughout Bellingham Bay. Recreationally important bivalves should be evaluated because they
are relatively stationary, and therefore are highly susceptible to contamination from local sources.
If bioaccumulation of contaminants is found to be a problem for crabs or bivalves, a survey of
bioaccumulation in selected fishes (i.e., species that are commercially or economically important)
should be considered.
For fish pathology, it is not recommended that evaluations of liver pathology be given a high
priority in Bellingham Bay. Aromatic hydrocarbons are thought to be the primary causative agents
of most observed cases of pathological conditions in livers of Puget Sound fishes. Because
concentrations of these compounds are relatively low in the bay, the prevalences of liver lesions in
fishes are also expected to be relatively low.
GEOGRAPHIC LOCATIONS
Little information was found on contamination and biological effects in many nearshore areas
of inner Bellingham Bay (e.g., the Fairhaven shoreline). Because many of these areas are influenced
by surface drainage (e.g., through storm drains or creeks), it is recommended that they be
prioritized with respect to the likelihood of contamination and that the areas having the highest
priority be evaluated.
Very little information on contamination and biological effects was found for Chuckanut Bay
and the entire northwest shoreline of Bellingham Bay, from Portage Bay to little Squalicum Creek.
Except for the Nooksack River, there are no major potential sources of contaminants in these areas.
It therefore is unlikely that major environmental problems are present. However, nonpoint
contaminant sources may influence these areas. Water currents may also carry contaminants into
these areas. Therefore, a limited number of stations should be sampled at representative locations
in these areas to identify any potential environmental problems.
-------
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Webber, H.H. 1978. Studies on intertidal and subtidal benthos, fish and water quality in
Bellingham Bay. Prepared for U.S. Army Corps of Engineers. Western Washington University,
Huxley College of Environmental Sciences, Bellingham, WA. 78 pp.
Yake, W.E. 15 October 1979. Personal Communication (memo to B. Johnson and R. Stanley
concerning Georgia-Pacific, Bellingham, Class II inspection). Washington Department of Ecology,
Olympia, WA.
-------
GLOSSARY
Acute toxicity—toxic effects that result from a single exposure to a chemical or multiple exposure
occurring during a relatively short time period.
AET—acronym for "apparent effects threshold"; refers to the concentration of a particular chemical
above which adverse biological effects have always been found for a particular region (e.g.,
Puget Sound).
Amphipod—a small shrimplike crustacean belonging to the order Amphipoda; commonly referred
to as sand fleas.
Anadromous fish—species, such as salmon, which hatch in fresh water, spend a large part of their
lives in the ocean, and return to fresh water rivers and streams to reproduce.
Assemblage—a group of organisms (e.g., benthic macroinvertebrates) that occur together in the
environment.
Benthic organisms—organisms that live in or on the bottom of a body of water.
Bioaccumulation—the accumulation of chemical contaminants in animal tissue.
Bioassay—a test procedure that measures the response of living plants, animals, or tissues to
potential contaminants. For example, marine worms have been exposed to the sediments of
Puget Sound, and their responses have been used to determine areas in the sound where the
sediments may be harmful to life.
Biochemical oxygen demand (BOD)—the quantity of oxygen-demanding biological materials present
in a sample as measured by a specific test. BOD is defined as a conventional pollutant under
the Federal Clean Water Act.
Biomass—the weight of organism tissue.
Biota—the animal and plant life of a particular region.
Bivalve—a mollusc having a shell consisting of two hinged parts.
Capping—the technique of covering contaminated sediments with clean sediments in order to
contain and isolate the contaminated material.
Chronic effect—any toxic effect on an organism that results after exposure of long duration (often
l/10th of the life span or more). The end result of a chronic effect can be death, although
the usual effects are sublethal (e.g., inhibited reproduction or growth). These sublethal effects
may be reflected by changes in the productivity and population structure of the community.
-------
Coliform bacteria—a type of bacteria which includes many species. Fecal coliform bacteria are
those coliform bacteria which are found in the intestinal tracts of warm-blooded animals. The
presence of high numbers of fecal coliform bacteria in a water body can indicate the release
of untreated sewage, and/or the presence of animals, and may indicate the presence of
pathogens.
Combined sewer overflow (CSO)—a pipe that discharges untreated wastewater during storms, from
a sewer system that carries both sewage and storm water. The overflow occurs because the
system does not have the capacity to transport and treat the increased flow caused by
stormwater runoff.
Contaminant—a substance that is not naturally present in the environment or is present in amounts
that can, in sufficient concentration, adversely affect the environment.
Conventional pollutant—one of the pollutants specified under the federal Clean Water Act. The list
includes total suspended solids, coliform bacteria, BOD, COD, pH, and oil and grease.
Crustacean—an invertebrate belonging to the class Crustacea; includes amphipods, crabs, and
shrimp.
Detection limit—the minimum chemical concentration that can be reliably measured by a particular
analytical technique or instrument.
Dissolved oxygen (DO)—oxygen which is present (dissolved) in water and therefore available for
fish and other aquatic animals to use. If the amount of dissolved oxygen in the water is too
low or zero, then exposed aquatic animals will die.
Diversity—a measure of the complexity of a species assemblage based on the total number of species
and the distribution of individual organisms among the species.
Dredging—any physical digging into the bottom of a water body.
EAR—acronym for "elevation above reference"; refers to the ratio between the value of a variable
at a potentially impacted station and the value of the same variable at a reference site.
Ecosystem—an ecological assemblage together with its physical and chemical environment,
considered as an integrated unit.
Effluent—the liquid that flows out of a facility or household into a water body or sewer system
(e.g., the treated liquid discharged by a wastewater treatment plant is the plant's effluent).
Eutrophication—the condition in which minerals and organic nutrients in a body of water have
increased to the extent that concentrations of dissolved oxygen are reduced and plant life is
favored over animal life.
HAET—acronym for "highest apparent effects threshold"; refers to the highest AET value observed
for a range of biological indicators.
Hydrocarbon—an organic compound that contains carbon and hydrogen.
-------
Invertebrate—an animal that lacks a backbone (e.g., shellfish, insects, worms)
Larvae—one of the earliest stages of an animal that experiences multiple life stages before the
adult stage is reached.
LAET—acronym for "lowest apparent effects threshold"; refers to the lowest AET value observed
for a range of biological indicators.
Lesion—a wound or injury; a pathological tissue alteration.
Macroinvertebrate—an invertebrate that is retained by a sieve having a mesh size of 1.0 mm.
Microtox—a bioassay that measures light reductions in bacteria (commonly Photobacterium
phosphoreum) following exposure to a stimulus; the light reductions are indicative of altered
metabolic processes.
Microorganism—an organism of microscopic size (e.g., bacterium).
Mollusc—an invertebrate belonging to the phylum Mollusca; includes clams and snails.
National Pollutant Discharge Elimination System (NPDES)—a part of the federal Clean Water Act
that requires permits for discharge of pollutants from any point source (e.g., an industrial
outfall) into waters of the United States.
Neoplasm—an abnormal growth of new tissue; a tumor.
Nonpoint source water pollution—pollution that is not discharged through pipes. Nonpoinf sources
are related to either land or water use.
Nutrients—essential chemicals needed by plants or animals for growth. Excessive amounts of one
nutrient or several nutrients can lead to the growth of excessive numbers of particular plants
and/or degradation of water quality.
Organic chemical—a chemical that contains carbon.
Patholog-y—the anatomical or functional manifestations of disease.
Point source water pollution—pollution that is discharged through pipes.
Polychaete—an invertebrate belonging to the class Polychaeta; often referred to as marine worms.
Polychlorinated biphenyls (PCB)—a group of ubiquitous, environmentally persistent chlorinated
hydrocarbons (between 12-68 percent chlorine). PCB were formerly used in insulating fluids
in capacitors and transformers, in the plastics industry, and in hydraulic fluids and lubricants.
PCB can cause cancer. They have caused birth defects in laboratory animals and are believed
to be capable of causing birth defects in humans.
-------
Polycyclic aromatic hydrocarbons (PAH) [sometimes called poiynuclear aromatics (PNA)]—many
ringed organic chemicals containing carbon and hydrogen formed as a result of incomplete
combustion of organic materials (e.g., coal, coke, wood, tobacco). Some PAH can cause
cancer.
Pretreatment—the treatment of industrial wastewater to remove contaminants prior to discharge into
municipal sewage systems.
Primary treatment—a wastewater treatment method that uses settling, skimming, and chlorination
to remove solids, floating materials, and pathogens from wastewater. Primary treatment
typically removes about 35 percent of BOD and less than half of the metals and toxic organic
substances.
Secondary treatment—a wastewater treatment method that usually involves the addition of biological
treatment to the settling, skimming, and disinfection provided by primary treatment.
Secondary treatment may remove up to 90 percent of BOD and significantly more metals and
toxic organics than primary treatment.
Sediment—material suspended in or settling to the bottom of a liquid. As used here, it refers to
the sand and mud that make up much of the shorelines and bottom of Lake Union and the
Ship Canal.
Shellfish—an aquatic animal, such as a mollusc (clams and snails) or crustacean (crabs and shrimp),
having a shell or shell-like exoskeleton.
Storm drain—a system of gutters, pipes, or ditches used to carry storm water from surrounding
lands to streams, lakes, or Puget Sound. Often carries a variety of substances such as oil and
antifreeze which enter the system through runoff, deliberate dumping, or spills. This term
also refers to the end of the pipe where the stormwater is discharged.
Taxon—a group of organisms constituting one of the formal groups or units of taxonomic
classification.
Toxicant—a chemical that poses a risk of producing an adverse biological effect or in some way
damaging a living organism.
Tributyltin—an antifouiing agent used in boat paints which is highly toxic to aquatic life.
-------
APPENDIX A
Station Descriptions and Concentrations
of Sediment Contaminants
-------
CONTENTS
Page
Table A-l Coordinates, depths, and study area designations of stations used for
problem station identification in Bellingham Bay A-l
Table A-2 Concentrations of sediment contaminants in Bellingham Bay, as reported
by the original investigators A-4
A-i
-------
TABLE A-l. COORDINATES, DEPTHS, AND STUDY AREA DESIGNATIONS
OF STATIONS USED FOR PROBLEM STATION IDENTIFICATION
IN BELLINGHAM BAY
Study
Station3-6
BA01
BA02
BA03
BA04
BA05
BA06
BA07
BA08
BA09
BA10
BAH
BA12
BA13
BAH
BA15
BA16
BA17
BA18
BA19
BA20
BA21
BA22
BA23
BA24
BA25
BA26
BR01
BR02
BROS
BR04
BROS
BR06
BR07
BROS
BR09
BRIO
BR11
BR12
BR13
BR14
BR15
BR16
BR17
BR18
BR19
BR20
BR21
BR22
Original
Stationc
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
E01
E02
£03
E04
£05
£06
£07
£08
E09
E10
L01
L02
L03
L04
LOS
L06
L07
LOS
L09
L10
Lll
L12
Latitude
48°45'06.0"N
48°45'28.2"N
48e44'52.6"N
48°44'49.7''N
48'44'35.2"N
48°44'06.0"N
48e44'37.5"N
48°44'53.3"N
48e44'16.8"N
48°44'40.0"N
48°44'58.0"N
48°45'12.5"N
48°44'43.0"N
48e43'17.0"N
48043'07.0"N
48°43'48.0"N
48°44'44.0"N
48°45'35.5"N
48°45'38.0"N
48°44'39.0"N
48°44'36.5"N
48*44' 30.0"N
48°43'35.3"N
48°43'56.0"N
48*44' 19.0"N
48°45'02.9"N
48°45'14"N
48°45'25"N
48°44'50"N
48°44'49nN
48°44'34"N
48e44'06"N
48°44'37"N
48°44'49"N
48°44'16"N
48°44'41"N
48°45'30"N
48°44'35"N
48°44'35"N
48°43'45"N
48°44WN
48e44'20"N
48°42'46''N
48°42'46"N
48°42'55''N
48e41'30"N
48°4r30"N
48°41'30"N
Longitude
122°30'40.5nW
122°30'47.0"W
122°29t46.0"W
122°29'32.0nW
122°29'49.0''W
122°30' 15.5"W
122°29'34.1"W
122°31'22.0"W
122°30'52.0"W
122°30'39.6"W
122°30'02.rW
122°29'40.0"W
122°34'55.0"W
122°34'13.0"W
122031'31.0"W
122°32'20.0"W
122032'52.0MW
122°33'07.0"W
122e31'28.0"W
122031'42.0"W
122°31'33.0"W
122°31'35.0"W
122°30'53.1"W
122°30'12.5"W
122°29'57.0"W
122°29'09.8"W
122°30'39'
-------
TABLE A-l. (Continued)
Study
Station3-"
CHOI
CH02
CH03
CH04
CH05
CH06
CH07
CH08
CH09
CH10
CH11
CH12
CH13
CH14
CH15
CH16
CH17
CH18
CH19
MA01
MA02
RE01
RE02
EC01
EC02
EC03
CL01
CL02
CL03
CL04
CL05
CL06
CL07
'ST01
ST02
ST03
ST04
ST05
ST06
ST07
ST08
ST09
ST10
ST11
ST12
ST13
ST14
Original
Station0
A-l
A-2
A-3
B-l
B-2
B-3
B-4
B-5
B-6
B-7
B-8
C-l
C-2
C-3
Chuckanut Creek
Padden Creek
Whatcom Creek
Squaiicum Creek
Nooksack River
204199
104200
A
B
BLL009
BLL008
BLL006
10
11
12
13
14
15
16
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Latitude Longitude
48°43'17"N 122°3ri4"W
48°43'irN 122°3ri8nW
48°43'04"N 122°3r2rW
48°43'46"N 122031'10nW
48°43'18"N 12203r20nW
48°43'12"N 122°3r22HW
48°43'irN 122°3r22"W
48e43'10"N 122"3r22"W
48°43'05"N 122°3r26"W
48°42'26"N 122°31'12''W
48°41'35"N 122°30'40"W
48°43'20"N 122°3r29"W
48°43'13"N 122°31'32"W
48°43'07"N 122°3r35"W
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
48°43'11"N 122°31'19"W
48°43'12"N 12203r25nW
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
(not reported)
Depth (m)
20
20
20
20
23
23
23
23
23
23
23
27
28
28
25
25
A-2
-------
TABLE A-l. (Continued)
Study
Station"-"
C001
C002
C003
Original
Stationc
A
B
C
Latitude Longitude
(not reported)
(not reported)
(not reported)
Depth (m)
FA01 PP (not reported)
a New station names given as part of this study.
b Station prefixes relate to original studies as follows:
BA = Battelle (1986)
BR = Broad et al. (1983)
CH = CH2M HILL (1984)
RE = Reif (1988)
MA= Malins et al. (1982).
EC = U.S. EPA 1989
CL = Cleland (1985)
ST = Stanley (1980)
CO = Cook (1985)
FA = Faigenblum (1988)
c Station names given in original studies.
A-3
-------
TABLE A-2. CONCENTRATIONS OF SEDIMENT CONTAMINANTS
IN BELLINGHAM BAY, AS REPORTED BY THE ORIGINAL INVESTIGATORS'
Maims a aL
(1982)
MA01 MA02
Low Molecular Weight PAH
(Mg/kg dry weight)
Total LPAH
Naphthalene
Acenaphthylene
Acenaphthene
Fluorene
Phenanthrene
Anthracene
High Molecular Weight PAH
(itg/kg dry weight)
Total HPAH
Fluoranthene
Pyrene
Benzol a (anthracene
Quysene
Benzofluoranthenes
Benzo(ghi)pervtene
DibenzcM ajijanthracene
Indeno(1^3-cd)pyreae
Retf (1988)
RE01 RE02
U800 Ul.OOO
U310 U400
U19 U25
U110 U140
U110 U140
U160 U210
U87 U110
U1.800 U2.000"
U340 U440
U310 U400
U240 U310
U76 U98
U400 U510
U180 U230
U190 U250C
U41 U53
CH2M HILL
(1984) Battelle (1986) - 1983 Data
CH07 CH11 BA01 BA02 BA03 BA04 BAOS BA06 BA07 BA08 BA09 BA10 BAH BA12
U2.400 U2.400
U400 U400
U400 U400
U400 U400
U400 U400
U400 U400
U400 U400
113,200" U3.200"
U400 U400
U400 U400
U400 U400
U400 U400
U800 U800
U400 U400
U400' U400°
U400 U400
Phthalates (ug/kg dry wnght)
Bis(2-etnylhexyl)phtnalaie
Butyl benzyl phthalate
Di-n-ooyt phthalate
U370 U480 U400 U400
U390C USOO U400' 0400°
U310 U400 U400 U400
Acid Compounds
(jig/kg dry weight)
Phenol
Volatile* (»g/kg dry weight)
Benzene
1,1-Oichloroethytene
Ethylbcnzene
Tetrachloroethylene
Toluene
Trichloroethylene
Hezachlorobenzene 13
Acetone
Chloroform
Total PCB (ng/kg dry weight) 100
PCB1254
PCB 1260
Metals (mg/kg dry weight)
Antimony
Arsenic Ull 20
Mercury 0.87 1.9
Cadmium 13 0.93
Cooper
Lead 95 34
Zinc
Silver
Nickel
Chromium
Beryllium
Selenium
Thallium
U15
U15
U15
U15
U1S
U15
U15
91
U15
U32
U32
0.66
U1.6
54
22
120
U3.2
98
80
Ul.l
UZO
U2.0
U19
U19
U19
U19
U19
U19
U19
160
U19
U35
35
0.38
U1.8
55
18
130
U3.5
110
80
U1.2
U2.0
U10
U25
U25
U25
U25
U25
U25
U25
U25
U10
U10
0.91
14
UO.l
0.28
18
32
43
0.11
37
32
034
U
6.4
U25
U25
U25
U25
U25
U25
U25
U25
U10
U10
2
22
06
02
46
12
110
Oil
69
46
\2
l&
10
0:233 0.124 1.91 2.60 0.717 0.755 1.97 0.268 0.671 OJ17 0.755 0.679
133 13.2 28.6 47.8 23.9 203 37.6 15.0 20.2 11.8 20.8 21.4
0.125 0.125 0.295 0.382 0.217 0^00 OJ03 0.121 0.178 0.111 0719 0.203
A-4
-------
TABLE A-2. (Continued)
BatteUe (1986) - 1983 Data
Battelle-(19861 - 1984 Data
BA13 BAH BA15 BA16 BA17 BA18 BA19 BA20 BA21 BA22 BA23 BA24 BA2S BA26 BA03 BA04 BA05 BA07 BAH BA12 BA23 BA24
U1300 U1.600 UUOO U1.900 U640 U770 Ul.OOO U1.200
220
U200
U200
240
U200
370
260
J90
1UO
95
140
U200 U200 U200 U200 U200 U200 U200 U200
150 U200
210 U200
570 210
110 U200
110
150
iSO
2SO
J20
32
170
130
U200 U200 U200
66 U200 U200
170 110 230
38 U200 U200
111,900" U3.6006 Ul,800b 4300s 1.4006 U700* U680b U730*
710 1,400 480 1,500 550 200 200 U2SO
620 1,100 390 1300 380 230 180 ISO
2SO 430 UlOO 700 150 80 U100 U100
250 540 UlOO 820 170 93 UlOO UlOO
UlOO UlOO 770 190 100 UlOO UlOO UlOO
usoo" vaocf vsoif usatf uswf usoo* usoo0 usoo'
USOO' USOf USOCfi USOO' USOO' USOO' USOO' USDO*
U800* 0800* U800' U800' USOO' USOO' U800* USOO4
390 290 250 310 UUOO U1.100 UUOO U1.100
U200' U200* U200' U200' U200' U200' U200C U200'
d d d590d d300d
U200 U200 U200 U200 U200 U200 U200 U200
U12
U12
U12
U12
U12
U12
U12
U12
JS
U12
JS
JS
11
JS
U12
U12
U12
U12
U12
U12
K2
U12
U12
U12
J5
U12
U12
J5
J5
U12
U12
U12
U12
J10
U12
U12
U12
U12
Uli
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
U12
no
U12
U12
U12
U12
74
U20
54
U20
27
U20
31
U20
54
U20
53
U20
U20
U20
U20
U20
0.170 0.434 0.623 ' 0.457 0306 0.0230 0.057 0.166 0.099 0317 0.623 0.604 0.830 1.79
10.1 22.7 23.7 :ij 16.9 2.70 6.70 15.4 10.7 16.9 24.7 21.1 212 158.3
0.076 0.200 0^63 0231 0.15S 0.0140 0.0420 0.128 0.0640 0.162 0241 0212 0.190 0.522
8.5
US
0.98
400
46
102
7.9
1.69
12
72
37
13S
11.6
0.081
0.55
69
13
111
8.9
0.97
0.88
72
18
117
10.8
0.54
OJ1
79
13
113
6.9
0.64
0.5
61
11
97
73.3
68
89.6 1112 105.1
81
86
32
118
63
10.8 8.5
0.54 0-59
033 036
62 67
10 8
114 115
029 0.47 024 029 0.09 0.13 0.13 0.13
57
102
66
117
69
1 U • Undetected at the detection limit shown
•I - Estimated value.
Data were not included in the sum when the detection limit was equal to or exceeded the LAET for a chemical
c Detection limit etcredi LAET.
Undeteaed. but detection limm were not reported.
A-5
-------
APPENDIX B
Summary of Spills Reported
to the U.S. Coast Guard:
Bellingham Bay Action Program
-------
CONTENTS
Page
Summary of Spills Reported to the U.S. Coast Guard: Bellingham Bay Action Program B-1
Table B-l. All vessel spills in Bellingham Bay for years 1973-1979 B-2
Table B-2. All non-vessel spills in Bellingham Bay for years 1973-1989 B-4
Table B-3. All vessel spills in Bellingham Bay for years 1980-present B-6
Table B-4. All non-vessel spills in Bellingham Bay for years 1980-present B-8
B-i
-------
SUMMARY OF SPILLS REPORTED TO THE U.S. COAST GUARD:
BELLINGHAM BAY ACTION PROGRAM
Spills from vessels and facilities in Bellingham Bay are frequently reported to the U.S. Coast
Guard. All spills that the U.S. Coast has responded to in the study area since 1973 are summarized
in the following tables. For each spill, information is provided on the U.S. Coast Guard's Marine
Safety Information System (MSIS) case number, spill location, type and quantity of material spilled
and recovered, and the name and type of vessel or facility that spilled the material.
B-l
-------
TABLE B-1. ALL VESSEL SPILLS IN BELUNGHAM BAY FDR YEARS 1973 - 1979
PAGE 1 OF 2
N>
MSIS CASE
NUMBER
MP739121 IS
MPT3912400
MP73912879
HP73912881
MP74913615
MP74913753
MP74913787
HP74913843
MP74913975
MP74914250
MP75901069
MP75901070
MP75302348
MP75912673
MP75912890
HP76901137
MP76902101
MP77J00682
MP77900683
MP77901378
MP77902139
HP77902874
HP78901287
MP78901339
MP78901620
MP78902577
MP78903220
MP78903386
HP78913917
MP78913923
MP78913951
MP78914073
MP78914443
HP79901206
MP79901374
MP79901376
MP79901378
MP79902753
MP79913106
HP79913651
MP7991 3645
LATITUDE
<.o45.0
48-5.0
46-5.0
4645.0
4845.0
4845. 0
4845.0
4845.0
4645.0
4244.0
4845.0
4645.0
46-5.0
4345.0
46-.5.0
4645.0
4845. 0
4644.0
4845.0
46<.5.0
4344.0
46'-5.0
4646.0
49<.5.0
4645.0
4645.0
4640.0
48<* 5.0
4645.0
4645.0
4645.0
4645.0
4645.0
4845.0
4642.0
4845.0
4845.0
4645.0
4645.0
48^3.0
-e«-5. o
LONGITUDE
12230.0
12230.0
12230.0
12230.0
12230.0
12238.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12239.0
12231.0
12230.0
12230.0
12230.0
12240.0
12230.0
SPILT
IN WATER
400
5
1
10
200
15
15
250
3
15
60
10
C
1
10
1
30
10
10
5
1
5
1
1
3
1
17
250
100
30
4
1
1
1
1
4
15
1
1
200
10
RECOVERED
IN WATEP
3 36
0
1
0
0
0
0
50
40
0
Q
0
0
0
0
0
0
10
0
3
0
0
0
0
0
0
0
250
0
30
3
0
0
0
0
0
0
0
0
0
4
SPILT
OUT MATER
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
RECOVERED
OUT HATER UNITS
CARGO NAME
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.0
0
0
0
0
0
0
0
0
0
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
Dili fuel: MO. t
Caustic sod.- solution
Oil: Crude
Oil: Crude
Oil: Crude
Oil: Crude
Dili misc: Motor
Oil: Clarified
Dili fuel: No. 1-0
Oil, fuel: No. 2
Oil: Crude
Oil: Crude
Dili misc Motor
Gasoline: iuiation (4.?cg
Oil, fuel Nc. 2-0
Oil: Crud
Dili fuel No. 1-D
Oil, fuel lio. 2-0
Oil, fuel No. 1-D
Ci 1 i misc Spindl 5
Oil, mi ?c Motor
Oil: Crude
Oil: Crude
Oil: Crude
Oil : Clarified
Oil i fuel: Nc. 1-D
Oil, fuel: No. 1-D
Oil , f u<= 1 : No . 2
Oil, fuel: No. 1-0
Oil: Crude
Oil : Clarified
Oil: Crude
Oil: Clarified
Oil: Crude
Oil: Crude
Oil, misc! Turbine
Oil , fuel : No . 2
Oil: Crude
Oil, f ual : No . 1-D
Oil, fuel: No. 1-0
Oil, mi?c : Motor
Pb/gal )
-------
ALL VESSEL SPILLS IN BELLINGHAM BAY FDR YEARS 1973
PAGE 2 OF 2
- 1979
tfl
MSIS CASE
NUMBER
MP73912119
KP73912400
MP73912878
MP73912631
MP74913753
MP749137S7
MP7491 39/5
C.P74914250
MP75901069
HP75901070
MP75S02348
MP75912673
MP75912E90
MP76901187
KP76902101
MP77900682
MP77900663
MP77901378
MP77902139
MP77902874
MP78S01287
MP78901339
MP78901620
MP78902577
MP78503220
MP76903386
"P7991 3917
MP78913923
MP78913951
f.P7691407 3
MP789U463
MP7S901206
MP79901374
MP79901376
MP79901378
HP7 9902753
HP79913108
MP79913651
MP7991 36^5
SPILL
DATE
7-Jul-73
16-NOV/-73
16-Nov-73
2i-May-7A
13- Jun-7<.
2'«-Jun-7'«
14-Jul-75
l«-Jul-7J
6-Jun-75
12-4pr-75
17-flug-7;
6-Jsn-7(
ll-Qct-76
K-Jul-77
12-Jul-77
12-Msy-77
11-Dc t-77
A- Jan-77
ll-Apr-78
3-Jul-78
12-Jul-78
20-Nav-l i
3-Dec-78
12-Jun-76
20-Now-7t
17-Jul-79
13-Jun-79
10-Sep-79
5-Mar-79
23-Jan-79
REPORT
DATE
VESSEL
NAME
MILMAR 6
RICHARD FOSS
SARATOGA
SARATOGA
DENALI
SANDRA FOSS
l-Nov-79
-------
TABLE B-2. ALL NON-VESSEL SPILLS IN BELLINGHAH BAY FDR YEARS 1973 - 1979
PAGE 1 OF 2
HS1S CASE
NUMBER
MP7331 1 7 J3
MP73912771
MP73912948
MP7391 3017
MP7491 3475
MP74913518
MP74913770
MP74914245
HP75912<>87
MP75912623
MP75912644
HP75312651
HP75912769
MP75912 779
MP75912816
MP75912831
MP7591283i
MP75913036
MP75915057
MP76913320
MP76913447
MP76913459
MP76913460
MP7691 3473
MP76913-80
MP76913S03
MP7691350*,
KP76913540
MP7691 3566
MP78913655
HP7891 3660
MP78913696
MF78913749
MP78913760
MP7891 3814
HP78913871
MP78913934
MP78914007
MP789U152
MP78914178
MP78914503
MP79913040
MP79913097
MP79913221
MP79913392
LATITUDE
4E-.5.0
4945.0
434<,.0
4645.0
48-.5.U
4345.0
4645.0
4£45.0
48<.5.0
'.645.0
46-7.0
4b<.5.0
4845.0
4645.0
4645.0
4844.0
4645.0
4644.0
4645.0
4645.0
4645.0
4545.0
4E45.0
48<>4.0
46-.5.0
4840.0
42-.3.0
4c45 .0
4844.0
4a<. 5.0
4645.0
•.6-.5.0
4645.0
4645.0
4646.0
4645.0
4c44.0
4845.0
4845.0
4845.0
4845.0
4644.0
4c«,4.0
4345.0
4645.0
LCNGI TUDE
12230.0
12230.0
12230.0
12230. C
12230.0
12230.0
12236.0
12230.0
12230.0
12230.0
12240.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12233.0
12230.0
12230.0
12230.0
12230.0
12231.0
12230.0
12230.0
12230.0
12231.0
1 2230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
SPILT
IN W i T r K!
44COOO
2
1)0
50
10
t
15
1
15
;oo
10
i
-i
L
1
50
1 )0
1
20
6
2
2
1
C
1
1
1
1
1
:?
i
2C
1
1
1
?0
1
30
1
5
1
5
5
1
15
5
RECCVER6D
IN ^ C T E F
".00000
P
50
0
220
0
0
0
0
0
0
0
0
0
0
0
1
0
0
(J
0
0
0
0
0
0
0
0
1
1
10
0
0
0
0
0
30
0
0
0
0
0
0
0
3
SPILT
OUT WATER
0
0
0
0
0
0
0
0
0
0
0
o-
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
RECOVERED
OUT V.ATEP UNITS
CAkGC 'IAME
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
C-
Oi 1 : Crude
Oil: Crude
Oil, fuel: No. 2
Oil, f uel : Nc. 1-0
Oil, fuel: Nc. 6
Oil: Crude
Not elsemhere specified
Gasoline: Aviation (4. Big
Cyclopropane
Oil, fuel Nc. '
Oil, fuel Nc . 6
Creojote Cocl tar)
Ci 1 , fuel Nc . 1-P
Oil, fuel No. 2
Chroirous chloride
Not elsewhere specified
Dili misc Mineral seal
Oil, fuel No. 2
Gas oil: Cracked
Oil: Crude
Oil: Crude
Qi : Crude
Oi : Crude
Oi , fuel: No. 1-0
Oi : Crude
No elsewhere specified
Gasoline: Aviation (4.8ig
Oil, fuel
Sooium r y
Ci 1 : Crud
Dili 11 1 s c
D i 1 , (rise
3 i 1 , t ue 1
Gasoline:
Oi 1 , fuel
Oil, fuel
Dill Crud
Oil, fuel
Oil: Crtd
Oil, furl
Oil: Crud
Oil, fuel
Oi 1 , fuel
Oil, fual
No. 1-P
Iro x i d e
?
Absorption
Spindle
No. 1-3
Aviation (",.863
Mo. 2-0
No. 2
No. 2
No. 2
He. 1 - D
No. 2-D
Ho. 2-D
Oil: Crude
b/gal)
r / 3 a 1 )
-------
ALL NON-VESSEL SPILLS IN BELLINGHA* BAY FOR YEARS 1973 - 1979
PAGE 2 OF 2
U
I
MSIS CAS5
NUMBER
MP73S11773
MP73912771
MP73912943
MP73913017
MP74913475
l*P7491351e
MP74913770
MP74914245
MP75912467
MP75912623
KP75912644
MP75512451
MP 7 59 12 7.68
MP75912773
SPILL
REPORT
DATE
SOURCE
HflME
MP75912831
KP75913036
MP7!; J13057
MP76913320
MP 7691 3447
KP76913459
MP76913460
MP76913475
MP76913450
HP76913503
MP76913504
MP76U35-40
MP76 J13566
MP78513655
HP78913660
MP76913693
MP78313749
MP78913760
HP78913814
NP7891 3871
HP7891 3934
MP78914007
MP78914152
KP78914178
HP78914503
MP799 1 3040
MP79913087
MP79913221
MP79S13392
l-Dec-7 3
10-MEr- 7 4
17-Jun-74
l-Ofc-74
lS-Jjn-75
13 - P a r - 7 5
27-Mar-75
31-Mar-75
9-Jun-75
13-Jun-75
12-Jul-75
l-Jul-75
1 J-Jul-75
4-Oec-75
23-Ctc-75
2t-Jsn-7i
16-Mcr-76
22-Mar-76
22-Var-76
29-Mar-76
31-"?r-7*
7-Apr-76
7-Apr-76
19-4pr-76
29-4pr-7i
S-Jan-78
6-J?n-7 -i
17-Jsn-73
3-Feb-78
6-Feb-73
22-f eb-7d
10-Mer-78
5-Apr-78
lO-May-76
10-Jul-79
19-Jul-78
l-tec-78
3-Jsn-79
18- j£n-79
2-Mer-79
-------
TABLE B-3. ALL VESSEL SPILLS IN BELLINGHAH BAY FOR YEARS 1980 - PRESENT
PAGE 1 OF 2
MSIS CASE
NUMbER
MP80901010
MP80901T1 5
HP31900"J71
MP8ini203
MP82901462
MP83900576
MP33901',93
MP64S01184
MP84901379
MPB4911971
MP84512354
PP85002668
MP85002669
PP35900313
MP85900430
MPS6000425
MP86006639
MP86007S44
MP87001095
HP870029:2
MP87004361
MP87006091
, MP87006091
ON MP87006983
MP87008861
MP87008883
HP88000107
HP36003018
HP88003661
MP88004014
MP88004609
MP88004355
MP88006607
MP88006758
MP88038196
LATI IUDE
48-. 5 .0
4H-. > .0
4846.0
464 b.O
4c <•<• . 0
4645.0
4644.0
4643.0
4645.0
4 6 * ; . 0
4845.0
4b<.5.0
46^5.0
4 e* 5 .0
49-.S.O
4645.0
4645.0
4:44.1
4b45.0
4545.0
4645.0
4645.0
4645.0
484', .0
4644.Q
4645.0
48-.5.0
4645.0
4645.0
4E45.0
4344.1
4645.0
4644.0
4644.0
4645. 1
LuNGITUDE I
12230.0
1 2Z30.0
12230.0
1 J 2 3 0 . 0
12230.0
12230.0
12230.0
12230.0
12230.0
12130.0
12231.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.1
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12233.4
12230.0
12230.0
12230.0
12228.9
SPILT Sc
NMATtR IN
^
,-
T
.1
)
:oc
i
25
\
iO
1
11
f. f
'00
15
450
^
2
5
10
i.
10
1
20
10
10
2
3
1
1
1
1
C.
20
50
COVERED SPILT RECOVERED
WflTER OUT WATER OUT HATER UNIT
0
3
0
0
0
0
0
0
0
0
0
i.
75
0
0
400
0
0
C
0
0
8
1
0
0
1
0
0
C
0
C
0
0
0
30
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
G
G
G
G
G
G
G
G
hj
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
S
Oi 1 .
Oil,
G s s o
uil:
Oil,
Gil ,
Oil ,
Oil,
an,
Uil,
fuel Me . 2
fuel Nc . 2
CARGO NAME
-0
line: Aviation (4.'iilg P 0 / j a 1 )
Crurt o
fuel No . 2
fuel Nc. 1
fuel Nc. 2
misc Lubri
fuel No . t
fu=l No. 1
-D
-D
-D
cat i nq
-D
Gasoline: Jut omo t i v ? (4.23q Pb/gal)
Gil:
Oil:
Oil ,
oil,
Oi 1 ,
Oil ,
Gil :
Oil:
Oil ,
Oil:
Oil:
Oil ,
Oil:
Oil:
Oil ,
Oil,
Oil,
Oil,
Dil,
Oil ,
Oil,
Oil:
Oil:
Oil:
Diesel
Diesel
f uel : Nc . 1
fuel: he. 2
fuel: Nc. 2
fuel: N c . 2
Diesel
Diesel
f uel : Nc . 2
Diesel
Diesel
misc: Me tor
Diesel
Diesel
u/3 ste/lubri
uisste/lubri
misc: Lubri
uiaste/lubri
-D
-D
-0
-D
cants - possible contain
n an t
cants - possible contaminant
eating
cants - possible contaTi
uias t e/ 1 u br i can t s - possible cortsiri
uias t e/ lu br i can t s - possible contairi
uic s t e/ lubri c an t s - p o s = i S 1
-------
ALL VESSEL SPILLS IN BELLINGHAM BAY FOR YEARS 1980 - PRESENT
PAGE 2 OF 2
00
I
MSIS CASE
NUMbER
MP80901010
MP8090 1715
MP81900971
MP81S11203
MP32901452
MP83SOG576
MP83S01<,93
MP849011d-
MP8<.S01379
MP84911971
MP84912354
MP95002663
MP85002669
HP8590Q313
MP85900430
MP86000425
MP86006639
MP860075A<.
MP87001035
KP87002922
MP870080
8-4ug-fll
l£-0u?-?l
13-flug-32
21-Cec-«3
24-Mar-83
26- Jan-»<.
REPORT
DATE
VESSEL
NAME
3- Jan-e<.
28-Cec-B'i
20-Apr-P.6
1 9-Jul-95
16-Jan-36
lO-^eb-87
l-M3y-B7
23-Jun-87
22-Aug-87
22-Aug-87
1.3-Dec-87
17-Oec-87
25-Jpr-86
22-Jun-98
;-Jul-98
3 - r; c t - 3 5
4-Oct-38
2<»-Apr-86
20-Apr-86
16-Jan-86
22-Aug-86
22-Aug-86
10-F«b-87
l-Hay-B7
23-Jun-87
22-Aug-87
•22-Aug-87
1 3-C»c-87
17-D«c-87
5-Jan-88
15-May-88
25-Apr-88
22-Jun-88
8-Jul-88
28-Jul-88
3-Oct-88
4-Dct-88
9-D«c-88
PACIFIC CASTLE
PACIFIC RANGER
5.0.CO.NO. 1 7
SCOUT
SNOW MIST
LQCHINVAR
ROSHELL
UNKNCUN
UNKNOWN
UNKNOWN
AMERICAN
AMERICAN
UNKNOWN
UNKNOWN
fELISSA
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
FRANCIS
UNKNOWN
SOUPCE
SOUPCE
SOURCE
BEAUTY
SOURCE
SOURCE
CHRIS
SOURCE
SOURCE
SOURCE
SOUPCE
SOURCE
SOURCE
SOURCE
h
SOURCE
-------
TABLE B-4. ALL NON-VESSEL SPILLS IN BELLINGHAH BAY FOR YEARS 1980 - PRESENT
PAGE 1 OF 2
MSIS CASE
NUMBER LATITUDE LONGITUDE
RECOVERED
OUT HATER UNITS
CARGO NAME
MP80911 347
MP80911388
MP80911418
NP80911774
HP8C9H931
MP81910726
MP8191073S
MP81910796
MP81910815
MP81911250
MP82910612
MP82910671
MP82S10958
MP82910977
HP83912226
MP83912403
MP83912421
MP84912012
NP84912172
MP84912177
MP85907579
i MP85907594
00 HP85907603
MP86000992
MP8600U81
MP86006546
MP87004659
MP87005291
MP87007587
HP87007587
MP88002795
48-7.0
4846.0
4843.0
4845.0
4645.0
4845.0
4444.0
4645.0
4644.0
4845.0
4645.0
4645.0
4845.0
46-5.0
4E-<..0
4845. 0
4644.0
4845.0
46-5.0
4644.0
4846.0
4844.0
4846.0
4645.0
4845.0
48-5.0
4545.0
4645.0
4644.0
4844.0
4645.0
12225.0
12229.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12232.0
12230.0
12230.0
12229.0
12229.0
12229.0
12230.0
12229.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12231 .0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
12230.0
0
0
0
0
0
100
0
0
0
5
0
0
0
0
0
20
0
0
0
0
0
0
0
0
3
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
20
1
13
0
2000
5
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
13
0
2000
0
0
0
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
G
P
G
G
G
G
G
G
G
P
F
P
G
Oili misc: Motor
Oil: Crude
Oil, fuel: No. 2
Gil: Crude
Gasoline: Automotive (4.23q Pb/gal)
Not elsewhere specified
Dili misc
Oil i misc
Oil i fuel
Oil , fuel
Oi 1 : Crud
Oil, fuel
Oil , fuel
Oil, fuel
Gasoline:
Oil. fuel
Gaso 1 ine :
Oil, misc
Oil, misc
Sul f uric
Oil, fuel
Gil , misc
Lubricating
Spindle
No. 2
Nc . 6
f
No. 2-0
No. 2-0
Nc. 2-0
Aviation (4.8ig Pt/gal)
No . 4
Automotive ( 4 . 2 3 r. Pb/gal)
Motor
"o tor
c id
No. 2
Motor
Oil: Clarified
Oil: Diesel
Kerosene
Oil: Diesel
Oil, u as t e/ 1 u br i c an t s - possible contaminant
Not defined
Ferrous chloride
Chlorine
Not defined
-------
ALL NON-VESSEL SPILLS IN BELLINGHAH BAY FOR YEARS 19BO - PRESENT
PACE 2 OF 2
03
MSIS CASE
NUPbER
KP80S1 1347
Hpaosmee
MP80911418
MP80911774
MP80S11931
MP31510726
HP81910733
MP81510796
MP81910815
MP81911250
MP82S10612
MP82910871
MP82910958
MP82910977
HP83912226
MP83912403
MP83912421
MP849J2012
MP34912172
HP84912177
MP95907579
HP35907594
MP85907603
MP86C00992
MP84001181
MP86006546
MP3700465 3
MP37C05291
MP87C07587
HP87007587
SPILL
DATF
Z-Feb-80
14-Fe'b-80
2-Msr-80
if-au3-80
26-Nov-BO
1-J30-91
9-Jan-81
28-J6n-81
8-Feb-81
9-Sep-31
:3-Jan-82
4-Sep-a 2
26-Nov-82
15-Oec-82
REPORT
DATE
SOURCE
N4ME
12-Aug-83
27-Aug-83
7-Feb-84
l-Jul-84
8-Jul-B4
8-Apr-85
30-Aer-85
3-M3y-35
30-Jan-86
19-Oec-85
2-Jul-97
15-Jul-87
19-Dct-87
19-Dct-87
26-flpr-98
30-Jan-86
19-Dec-85
22-Aug-86
2-Jul-87
16-Jul-87
19-Oct-87
19-Oct-87
26-Apr-88
1984 PETERBUILT LIC.»LM6233
GEORGIA PACIFIC SflLVAGE rAR
NORTHWEST FU5L CO INC.
UNK
PUGET SOUND TRUCKING
GEORGIA PACIFIC
GEORGIA PACIFIC
GEORGIA PACIFIC CHEMICAL CC. .
-------
APPENDIX C
Bibliography: Bellingham Bay Action Program
-------
BIBLIOGRAPHY: BELLINGHAM BAY ACTION PROGRAM
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C-l
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C-2
-------
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Bay, Ship Canal; Longview Ditch System; Port Gardner/Inner Everett Harbor; Elliott Bay and
Duwamish Waterway and River; Commencement Bay and Inlet Waterways. [Prepared in partial
fulfillment of 304(1) requirements.] Washington Department of Ecology, Water Quality Program,
Olympia, WA.
* Faigenblum, J. 1988. Chemicals and bacteriological organisms in recreational shellfish.
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Control Commission, Olympia, WA. 207 pp.
C-3
-------
Glantz, D. 9 August 1974. Personal Communication [memo to J. Glynn regarding sewage treatment
plant (STP) study at Larabee State Park]. Washington Department of Ecology, Olympia, WA.
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Bellingham Harbor, Guemes Channel and Swinomish Channel water quality surveys). Washington
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Goodwin, C.L. 1972. Evaluation of the 1969 dredge spoil disposal area of Bellingham Bay.
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District, Seattle, WA and U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. 4
PP.
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Hatchery in Bellingham, WA. Washington Department of Ecology, Water Quality Investigation,
Olympia, WA. 49 pp.
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pathways, processes and transformation of Puget Sound contaminants of concern. NOAA Technical
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Landau Associates. 1989. Assessment of Alaska ferry terminal development on marine sediments,
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Loehr, L. 7 July 1989. Personal Communication (letter to R.A. Pastorok, PTI Environmental
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C-4
-------
* Malins, D.C., B.B. McCain, D.W. Brown, A.K. Sparks, H.O. Hodgins, and S.-L. Chan. 1982.
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Bellingham, WA. 55 pp. + appendices.
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C-5
-------
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C-6
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Environmental Protection Agency, Seattle, WA.
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assessment Puget Sound annual summary 1983. 81 pp.
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Bellingham Bay. Prepared for U.S. Army Corps of Engineers. Western Washington University,
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concerning Georgia Pacific, Bellingham, Class II inspection). Washington Department of Ecology,
Olympia, WA.
C-7
-------
APPENDIX D
NPDES Permits for Dischargers
in the Bellingham Bay Area
-------
CONTENTS
(Permits appear in order presented in text.)
Page
City of Bellingham D-1
City of Ferndale D-13
City of Lyden D-23
City of Everson D-35
Bellingham Cold Storage Company D-45
Bellingham Frozen Foods, Inc. D-52
Sea Pac Company, Inc. D-60
Seawest Industries, Inc. D-67
Schenk Seafood Sales, Inc. D-73
Dahl Fish Company, Inc. D-79
Mt. Baker Plywood, Inc. D-86
Oeser Company D-93
Brooks Manufacturing Company D-104
Columbia Cement Corporation D-115
Public Utility District No. 1 of Whatcom County D-123
Bellingham Hatchery D-131
Nooksack State Salmon Hatchery D-138
Georgia-Pacific Corporation D-145
D-i
-------
Page . .1 12
Permit No. WA-002374-4
Issuance Date: April 7, 1988
Expiration Date: March 16, 1993
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
The State of Washington Water Pollution Control Law, as amended
Chapter 90.48 Revised Code of Washington
and
The Federal Water Pollution Control Act
(The Clean Water Act)
Title 33 United States Code, Section 1251 et. seq.
City of Bellingham
210 Lottie Street
Bellingham, Washington 98225
Plant Location:
200 McKenzie
Bellinghan. Washington 98225
Waterwav Seement Number:
01-01-02
Receiving Water:
Bellingham Bay
Discharge Location:
Latitude: 48°3ril"N
Longitude: 122°3r22"W
is authorized to discharge in accordance with the special and general conditions
which follow.
Nancy Ellison, Regional Manager
Northwest' Regional Manager
Department of Ecology
D-l
-------
Page t. of 12
Permit No. WA-002374-4.
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS
Beginning on the issuance date of this permit and lasting through the expiration
date of this permit, the Permittee is authorized to discharge treated municipal
wastewater to Bellingham Bay at che discharge location specified on page one of
this permit subject to the following effluent limitations:
EFFLUENT LIMITATIONS
Parameter Monthly Average Weekly Average
Biochemical Oxygen Demand 30 mg/L, 2,225 kg/d** 45 mg/L, 3,340 kg/d**
(BOD.)*
Total Suspended Solids 30 mg/L, 2,225 kg/d** 45 mg/L, 3,340 kg/d**
(TSS)*
Fecal Coliform Bacteria 200/100 mL 400/100 raL
Shall be within "*° l^it- -f 6.0 - 9 n
* The monthly average percent removal for BOD, and TSS shall not be less than 85
percent except during the "wet weather" months extending from October 1st
through May 31st.
** Mass effluent loading values based on best available information at time of
permit issuance. The Department may amend these values by permit modification
based on any amended facility engineering report or design report as approved by
the Department.
*** Values outside of this range may be allowed if the Permittee demonstrates that
such excursions are not the result of inorganic chemical additions to the
treatment process or contributions from industrial sources.
The monthly and weekly average effluent limitations for BOD. and TSS are the
arithmetic mean of the samples taken during a calendar month or week. The
average effluent limitations for Fecal Coliform are the geometric mean of the
samples taken during a calendar month or week.
Total available residual chlorine shall be maintained which is sufficient to
attain the Fecal Coliform limits specified above. Chlorine concentrations in
excess of that necessary to reliably achieve these limits shall be
avoided.
D-2
-------
Page j of 12
Permit No. WA-002374-4
S2. TESTING SCHEDULE
The Permittee shall monitor influent wastewater, effluent wastewater and
plant operating parameters according to the following schedule:
Flow
Temperature
pH
DO
Samcle Point
effluent
raw sewage
incinerator
hearth*
afterburner*
Sampling
Frequency
7/week
7/week
daily operating
daily operating
Sample Type
continuous
recording
raw sewage
final effluent
clarif ier
effluent(s)
raw sewage
*4.,1 »*flU=--
clarifier
effluent(s)
raw sewage
final effluent
raw sewage
final effluent
raw sewage
final effluent
raw sewage
raw sludge
raw sludge
final effluent
final effluent
final effluent
centrifuge
centrate
cake
7 /week
7 /week
7 /week
7 /week
7 /week
7 /week
5 /week 24 hr. comp.
5 /week 24 hr. conp.
daily
daily
5/week 24 hr. comp.
5 /week 24 hr. comp.
5/week
I/week
I/week
7 /week
5/week
I/month
daily operating
daily operating
daily operating
BOD
Settleable Solids
Suspended Solids
Total Solids
Volatile Solids
Total Available
(Residual) Chlorine**
Fecal Coliform
Oil and Grease.
Percent Total Solids
S'OTE: Unless otherwise indicated, Sample Type is grab.
* Hearth - Minimum operating temperature in maximum temperature hearth.
T Afterburner - • Minimum operating cemoerature.
D-3
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Page 4 of 12
Permit No. WA-002374-4
S2. TESTING SCHEDULE (Cont.)
** Total available (residual) chlorine shall be measured and reported at the
same time that fecal coliform samples are taken.
S3. MONITORING AND REPORTING
A. Reporting
The Permittee shall monitor the parameters as specified in Condition S2. of
this permit and report the results for each calendar month. The reports
shall be submitted no later than the 15th day of the month following the
completed reporting period and shall be on forms supplied or approved by
the department. Completed forms shall be sent to the Northwest Regional
Office of the Washington State Department of Ecology, 4350-150th Avenue
N.E., Redmond, Washington 98052.
In addition, a summary report form (EPA Form 3320-1) covering each calendar
month, shall be submitted no later than the 15th day of the month following
the completed reporting period. This report is limited to the parameters
specified in Condition SI.
If .the Permi <"•«- nnr.i«"rrs any poL1'"--^.-: ----; r~rc frequently th^n required
by the permit, such results shall be recorded and reported in accordance
with these instructions.
B. Records Retention
The Permittee shall retain for a minimum of three years all records of
monitoring activities and results, including all reports of recordings from
continuous monitoring instrumentation. This period of retention shall be
extended during the course of any unresolved litigation regarding the
discharge of pollutants by the Permittee or when requested by the director
of the department.
C. Recording of Results
For each measurement or sample taken, the Permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the analyses;
(4) the analytical techniques or methods used; and (5) the results of all
analyses.
D. Representative Sampling
Samples and measurements taken to meet the requirements of this condition
shall be representative of the volume and nature of the monitored dis-
charge, including representative sampling of any unusual discharge or
discharge condition, including bypasses, upsets, and maintenance related
conditions affecting effluent quality.
D-4
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Page 5 of 12
Permit No. tfA-002374-4
S3. MONITORING AND REPORTING (Gone.)
E. Teat Procedures
All sampling and analytical methods used to meet the monitoring
requirements snecifiad in this permit shall, unless approved otherwise in
writing by the Department, conform to tae Guidelines Establishing Test
Procedures for the Analysis of Pollutants, contained in Title 40 Code Of
Federal Regulations Part 136.
F. The department may establish specific treatment plant, receiving water,
sediment and biological monitoring requirements beyond those identified in
this permit by permit modification or administrative order.
S4. PREVENTION OF FACILITY OVERLOADING
A. Design Criteria*
The design criteria for the permitted treatment facility are as follows:
Average Flow For Maximum Month: 74,200 m /d
Influent BOD Loading for Ma-gimum Month: 19,033 kg/d
Tn^U-nr TCC Loading for Maximum Mrr-h: 15,54? '.-.g/i
Design Effluent Quality for Maximum Month:
BOD. 30 mg/L
TSS 30 mg/L
Design Effluent Quality for Maximum Week:
BOD. 45 mg/L
TSSJ 45 mg/L
*Design criteria based on best available information at time of permit
issuance. The department may amend these values by permit modification
based on any amended facility engineering report or design report as
approved by the department.
3. Plans for Maintaining Adequate Capacity
When the actual flow or waste load reaches 35 percent of the design
capacity as specified in paragraph A. above, or when the projected
increases would reach design capacity within five years, whichever occurs
first, the permittee shall submit to the department, a plan and a schedule
for continuing to maintain capacity at the facility sufficient to achieve
the effluent limitations and other conditions of this permit. This plan
shall address any of the following actions or any others necessary to meet
this objective.
1. Analysis of the present design including the introduction of any
process modifications that would establish the ability of the existing
facility to achieve the effluent limits and other requirements of this
permit it specific levels in excess of the existing design criteria
specified in paragraph A. above.
2. Reduction or elimination of excessive infiltration and inflow of
uncontaminated ground and surface water into the sewer system.
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Page to of 12
Permit No. WA-002374-4
S4. PREVENTION OF FACILITY OVERLOADING (Cont.)
3. Limitation on future sewer extension or connections or additional
waste loads.
4. Modification or expansion of facilities necessary to accommodate
increased flow or waste load.
The plan shall specify any contracts, ordinances, methods for financing or
other arrangements necessary to achieve this objective.
S5. OPERATION AND MAINTENANCE OF FACILITIES
In accordance with the Washington Administrative Code, Chapter 173-230
(Certification of Operators of Wastewater Treatment Plants), the Permittee shall
provide an adequate operating staff which is qualified to carry out the
operation, maintenance and testing activities required to insure compliance with
the conditions of this permit. An operator certified for a Class III plant by
the State of Washington shall be in responsible charge of the day to day
operation of the wastewater treatment facility.
S6. PROVISION FOR POWER FAILURE
The Permittee is responsible for maintaining adequate safeguards to prevent the
discharge of untreated wastes or wastes not treated in accordance with the
requirements of this permit during power failure at the treatment facility or
sewage lift stations either by means of alternate power sources, standby
generation of power, or retention of inadequately treated wastes.
S7- COMBINED SEWER OVERFLOWS
The following is a list of combined sewer overflows and sewage pumping station
bypasses which are occasional point sources of pollutants as a result of
precipitation events. The Permittee shall employ all available and reasonable
measures to prevent or moderate such discharges. Such discharges shall not
violate water quality standards. On or before January 1, 1988, the Permittee
shall submit to the department a plan and compliance schedule for the greatest
reasonable reduction of combined sewer overflows at the earliest possible date.
The plan shall be prepared in accordance with Chapter 173-245 Washington
Administrative Code.
Discharge No. Location Receiving Water
002 200 McKenzie Bellingham Bay
(Plant)
003 "C" and Holly Street Inner Whatcom Waterway
D-6
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Page 7 of 12
Permit No. WA-002374-4
S8. RESIDUAL SOLIDS HANDLING
A. The Permittee shall handle, utilize and dispose of all residual solids in
such a manner as to prevent its entry into state ground or surface waters.
B. The Permittee shall not permit leachata from its residual 'solids co entar
state surface waters without providing ail known, available and reasonable
methods of treatment, nor permit such leachate to violate the State Water
Quality Standards, Chapter 173-201, Washington Administrative Code, or
cause any adverse effect on state ground waters. The Permittee shall apply
for a permit or permit modification as may be required for such discharges.
C. Disposal or utilization of residual solids on land shall be in accordance
with the requirements of the juris dictional health department.
D. The Department aay establish specific sludge management requirements beyond
those identified in this permit by permit modification or administrative
order.
S9. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW, BYPASS OR REDUCTION IN LEVEL OF
TREATMENT
A. The overflow, bv-oass or reduction l-n IPVP! nf fi-aa*"""""" of sewage at che
treatment facility or within the sewage collection and transmission system
tributary to the treatment facility in excess of that allowed by the
effluent limitations of this permit during construction or maintenance
shall be avoided if at all possible.
B. If an event as described in paragraph A. above is contemplated which the
Permittee could reasonably be expected to have anticipated, the Permittee
shall submit to the department not less than 90 days prior Co Che
contemplated event, a report which describes in detail any construction
work which will result in such a discharge of wastewater. The report shall
contain: (1) an analysis of all known alternatives which would eliminate,
reduce or mitigate the need for bypassing or reducing che level of
treatment; (2) a cost effective analysis of alternatives including
comparative resource damage assessment; (3) the expected duration of such
events for each alternative; (4) a recommended alternative for the bypass
or reduction in level of treatment; (5) the projected time schedule for che
event; (6) a statement of compliance with the State Environmental Policy
Act; and (7) a request for a water quality modification, as provided for in
Chapter 173-201-100(2) of the Washington Administrative Code.
C. Final authorization to discharge wastewater as described in paragraph A.
above may be granted after review of the above information, in accordance
with General Condition G5. Authorization to discharge such wastewater will
only be by administrative order.
D. If the Permittee expects a reduction in the required level of treatment
chat would exceed permit effluent limitations on a short term basis for any
reason, and such reduction cannot be avoided without resulting in che
discharge of greater quantities of pollutants in the future, and che
Permittee could not reasonably be expected to have anticipated the need for
such reductions in the level of treatment within the time required for
iustifving such- actions as required in paragraph B. above, the Permittee
D-7
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Page 8 of 12
Permit No. WA-002374-4
S9.D CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW, BYPASS OR REDUCTION IN LEVEL
TREATMENT (Cont.)
shall give written notification to the department in accordance with General
Conditions G4 and G5.
S10. INDUSTRIAL AND COMMERCIAL SOURCES (PRETREATMENT)
The Permittee shall not allow discharges to their sewer system which would
violate the general or specific prohibitions contained in Title 40, Code of
Federal Regulations Part 403.5, or categorical standards contained in Title 40
Code of Federal Regulations Subchapter N, or any applicable regulations
promulgated under Chapter 90.48 of the Revised Code of Washington.
The permittee shall assist the Department in monitoring commercial and
industrial discharges into the sewer system and ensuring that all industrial and
commercial users are in compliance with applicable pretreatment regulations.
The permittee shall submit written notice to the Department whenever any new or
altered commercial or industrial source proposes to discharge waste into its
sewer system which may interfere with the operation of the treatment facility,
or interfere with the use or disposal of municipal sludge, or which may pass
through the treatment facility causing violations of State Water OuaMty
Standards (Chapter 173-201 of the Washington Administrative Code). Neither
connection nor discharge to the sewer system shall be allowed until the
commercial or industrial source obtains a State Waste Discharge Permit or such
source is otherwise approved by the Department as provided in Chapter 90.48.160
or Chapter 90.48.200 or the Revised Code of Washington.
The permittee shall perform industrial user survey, reporting, and other local
assistance activities as specified by the Department in support of the state
pretreatment program.
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Page 9 of 12
Permit No. WA-002374-4
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent with
the terms and conditions of this permit. The discharge of any pollutant more
frequently than or at a level in excess of that authorized by this permit shall
constitute a violation of the terms and conditions of this permit.
G2. The Permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and ralatad appurtenances)
which are installed or used by the Permittee to achieve compliance with con-
ditions of this permit.
G3. The Permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of the
treatment facility until the facility is restored or an alternative method of
treatment is provided. This requirement applies in the situation where, among
other things, the primary source of power of the treatment, facility is reduced,
lost, or fails.
G4. If, for any reason, the Permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified in
the permit, the Permittee shall, at a minimum, provide the department with the
following information:
A. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
B. The period of noncomplianee, including exact dates and times and/or the
anticipated time when the Permittee will return to compliance; and
C. Steps taken or to be taken to reduce, eliminate, and prevent recurrence of
the noncompliance.
In addition, the Permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps to minimize
any adverse impacts to waters of the state and correct the problem. The
Permittee shall notify the department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the corrective
actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant effluent
standard under Section 307 (a) of the Clean Water Act, or which could constitute
a threat to human health, welfare, or the environment, 40 CFR Part 122 requires
that the information specified in items G4.a., G4.b., and G4.c., above, shall be
provided not later than 24 hours from the time the Permittee becomes aware of
the circumstances. If this information is provided orally, a written submission
covering -these points shall be provided within five days of the time the
Permittee becomes aware of the circumstances, unless the department waives or
extends this requirement of a case-by-case basis.
Compliance with these requirements does not relieve che Permittee from respon-
sibility to maintain continuous compliance with the conditions of this permit or
the resulting liability for failure to comply.
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Page 10 of 12
Permit No. WA-002374-4
G5. The intentional bypass of wastes from all or any portion of a treatment works to
the extent that permit effluent limitations cannot be met is prohibited unless
the following four conditions are met:
A. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (2) necessary to perform construction or main-
tenance related activities essential to meet the requirements of the Clean
Water Act and authorized by administrative order;
B. There are no feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, maintenance during
normal periods of equipment down time, or temporary reduction or termina-
tion of production;
C. The Permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. Where the Permittee knows or should have
known in advance of the need for a bypass, this prior notification shall be
submitted for approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the special condi-
tion) ;
D. The bypass is allowed under conditions determined to be necessary by the
department to minimize anv adverse effects. The public shall be votlfi**
and given an opportunity to comment on bypass incidents of significant
duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property, damage
to the treatment facilities which would cause them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage.does not
mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the proposed
bypass, the department will approve or deny the request. Approval of a request
to bypass will be by administrative order under RCW 90.48.120.
G6. The Permittee shall allow an authorized representative of the department, upon
the presentation of credentials and such other documents as may be required by
lav:
A. To enter upon the Permittee's premises where a discharge source is located
or where any records must be kept under the terms and conditions of the
permit;
B. To have access to and copy at reasonable times any records that must be
kept under the terms and conditions of the permit;
C. To inspect at reasonable times any monitoring equipment or method required
in the permit;
D. To inspect at reasonable times any collection, treatment, pollution manage-
ment, or discharge facilities required under the permit;
E. To sample at reasonable times any discharge of pollutants.
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Page 11 of 12
Permit No. WA-002374-.4
G7. The Permittee shall submit a new application or supplement to che previous
application where facility expansions, production increases, or process modi-
fications will (1) result in new or substantially increased discharges of
pollutants or a change in the nature of the discharge of pollutants, or (2)
violate the terms and conditions of the existing permit.
G3. After aotica and opportunity for public hearing, chis permit may be modified,
terminated, or revoked during its term for cause as follows:
A. Violation of any term or condition of the permit;
B. Failure of the Permittee to disclose fully all relevant facts or mis-
representation of any relevant facts by the Permittee in the application or
during the permit issuance process;
C. A change in any condition chat requires either a temporary or a permanent
. reduction or elimination of any discharge controlled by the permit;
D. Information indicating that the permitted discharge poses a threat to human
health or welfare;
E. A change in ownership or control of the source; or
F. Other cause listed in 40 CFR Part 122.62 and 122.63.
Permit modification, revocation and reissuance, or termination may be initiated
by the department or requested by any interested person.
G9. A Permittee who knows or has reason to believe that any activity has occurred or
will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. or 40 CFR Part 122.62 must report its plans, or
such information, to the department so that a decision can be made on whether
action to modify or revoke and reissue a permit will be required. The depart-
ment may then require submission of a new application. Submission of such
application does not relieve the discharger of the duty to comply with the
existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is established
under Section 307(a) of the Clean Water Act for a toxic pollutant and that
standard or prohibition is more stringent than any limitation upon such pol-
lutant in the permit, the department shall institute proceedings to modify or
revoke and reissue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with WAC
173-240. Facilities shall be constructed and operated in accordance with the
approved plans.
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Page lz of 12
Permit No. WA-002374-4
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
G13. Nothing in this permit shall be construed as excusing the Permittee from compli-
ance with any applicable federal, state, or local statues, ordinances, or
i-aoul •>«••! n«o
regulations.
D-12
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Page 1 of 10
'Permit Number WA-0022A5-4
Issuance Date: 9/5/84
Expiration Date: 9/5/89
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Act as amended
Public Law 95-217
CITY OF FERNDALE
P n RQX 936
Ferndale, Washington 98248
Plant Location;
Ferndale Road
Ferndale, Washington
Waterway Segment Number:
01-01-04
Receiving Water:
Nooksack River
Discharge Location:
Latitude: 47° 50' 04"
Longitude: 122° 35' 49"
is authorized to discharge in accordance wi,
and general conditions which follow.
"-&-
Qpnald Dubois
Assistant Director
Department: of Ecology
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Page 2 of 10
Permit Number WA-002245-4
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the issuance date of this permit and lasting through the expiration
date of this permit, the permittee is authorized .to discharge treated municipal
vastewater to the Nooksack River at the permitted discharge location subject to
the following limitations and monitoring requirements:
Parameter
Biochemical Oxygen Demand*
(5 day)
Suspended Solids
Fecal Coliform Bacteria
pH**
EFFLUENT LIMITATIONS
Monthly Average
30 mg/1, 57 kg/d
(125 Ibs/day)
75 mg/1, 143 kg/d
(313 Ibs/day)
200/100 ml
Weekly Average
45 mg/1. 85 kg/d
(190 Ibs/day)
110 mg/1, 210 kg/d
(460 Ibs/day)
400/100 ml
Shall not be outside the range 6.0 - 9.0
*The monthly average effluent concentrations limitations for BOD_ shall not exceed 30
mg/1 or 15 percent of the respective influent concentrations, whichever is more
stringent.
**Ef fluent values for pH shall not exceed the limits 6.0 - 9.0 where such values are
attributable to inorganic chemical addition to the treatment process or to industrial
contributions.
The monthly and weekly averages for BOD and Suspended Solids are based on the
arithmetic mean of the samples taken. The averages for Fecal Coliform are based on
the geometric mean of the samples taken.
Total available residual chlorine shall be maintained which is sufficient to attain
the Fecal Coliform limits specified a :>ve. Chlorine concentrations in excess of that
necessary to reliably achieve the lir . _s shall be avoided.
D-14
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S2. TESTING SCHEDULE
The permittee shall monitor plant
following schedule:
Page 3 ot 10
Permit Number WA-002245-4
processes and wastewater according to che
Tests
Flow
Temperature
BOD
Suspended
Solids
Settleable
Solids
Dissolved
Oxygen
Total available
residual
chlorine
Fecal Coliform
Sanrole Point
Effluent
Influent
Individual cells
Effluent
Influent
Individual calls
Effluent
Influent
Effluent
Influent
Effluent
Influent
Effluent
Influent
Individual cells
Effluent
Effluent
Samnlins Freouehcv
7/week
5/week
5/week
7/week
5/week
5/week
7/week
I/week
I/week
I/week
I/week
5/week
5/week
5/week
5/week
7/week
I/week
Sample Tyne
continuous
recording
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Note: Unless otherwise indicated, Sample type is grab.
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Page 4 of 10
Permit Number WA-002245-4
S2. MONITORING AND REPORTING
a. Reporting
A monthly report- recording each required analysis shall be submitted no
later than the 15th day of the following month. The monthly reporting form
will be supplied to the permittee or approved by the department and sent to
the Northwest Regional Office of the Washington State Department of
Ecology, 4350-150th Avenue N.E., Redmond, Washington 98052.
In addition, a summary report form (EPA Form 3320-1) covering a one month
period, shall be submitted no later than the 15th day of the following
month. This report is limited to the limitations listed in Condition SI.
Monitoring shall be started on the effective date of this permit and the
first monthly report is due 45 days thereafter.
If the permittee monitors any pollutant any more frequently than required
by the permit, he shall record and report such results.
b. Records Retention
The permittee shall retain for a minimum of three vears all records nf
monitoring activities and results, including all reports of recordings from
continuous monitoring instrumentation. This period of retention shall be
extended during the course of any unresolved litigation regarding the
discharge of pollutants by the permittee or when requested by the director.
c. Recording of Results
For each measurement or sample taken, the permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the analyses;
(4) the analytical techniques or methods used; and (5) the results of all
analyses.
d. Representative Sampling
Samples and measurements taken to meet the requirements of this condition
shall be representative of the volume and nature of the monitored dis-
charge, including representative sampling of any unusual discharge or
discharge condition, including bypasses, upsets, and maintenance related
conditions affecting effluent quality.
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Page 5 of 10
Permit Number WA-002245-A
53. MONITORING AND REPORTING (Continued)
e. Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in writing
by che Department, conform co the Guidelines Establishing lest Procedures
for the Analysis of Pollutants, contained in...40 CFR Part 136, as published
in the Federal Register on December 1, 1976, or the latest revision
thereof, which references the following publications:
1. American Public Health Association, Standard Methods for the
Examination o_f Water and Wastewaters.
2. American Society for Testing .and Materials, A.S.T.M. Standards, Part
31,. Water, Atmospheric Analysis.
3. Environmental Protection Agency, Methods for Chemical Analysis of
Water and Wastes.
f. The department may establish specific monitoring requirements beyond those
identified in this permit by permit modification or administrative order.
S4. PREVENTION OF FACILITY OVERLOADING
a. Design Criteria
The design criteria for the permitted, treatment facility are as follows:
Average flow - 0.5 MGD
Population equivalent - 3500
b. Facility Upgrade
Upon completion of the expansion to the wastewater treatment facility, this
permit shall be modified to incorporate the new design criteria and
effluent loading limits.
S5. NOTIFICATION OF SIGNIFICANT NEW OR ALTERED SOURCES
The permittee shall submit written notice to the department whenever any new or
altered commercial or industrial source proposes to discharge waste into it's
municipal sewer system which may interfere with the operation of the treatment
works including interference with the use or disposal of municipal sludge and/or
which may pass through the treatment works causing violations of the State Water
Quality Standards (Chapter 173-201 Washington Administrative Code). Connection
to the sewer system shall not be allowed until the commercial or industrial
applicant obtains a State Waste Discharge Permit as provided in the Revised Code
of Washington Chapter 90.43.160.
The permittee shall assist the department in monitoring commercial and in-
dustrial discharges into the municipal sewer system.
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Page 6 of 10
Permit Number WA-002245-A
S6. RKSIDUAL SOLIDS HANDLING
•i. The permittee shall handle, utilize and dispose of all residual solids in
such a manner as to prevent its entry into state ground or surface waters.
h.. The permittee shall not permit leachate from its residual solids to enter
state surface waters without providing all known, available and reasonable
methods of treatment, nor permit such leachate to cause any adverse effect
on state ground waters. The permittee shall apply for a permit or permit
modification as may be required for such discharges.
S7. OPERATION AND MAINTENANCE OF FACILITIES
In accordance with the Washington Administrative Code, Chapter 173-230 (Certi-
fication of Operators of Wastewater Treatment Plants), the permittee shall
provide an adequate operating staff which is qualified to carry out the opera-
tion, maintenance and testing activities required to insure compliance with the
conditions of this permit. An operator certified for a Class 1 plant by the
State of Washington shall be in responsible charge of the day to day operation
of the wastewater treatment plant.
SB. CONSTRUCTION OR MAINTENANCE RELATED REDUCTION IN LEVEL OF TREATMENT
If the permittee coiu.c.-til.n.^z.z a. reduction in cue required ievei or treatment
that would exceed permit effluent limitations on a short term basis for any
reason, and such reduction cannot be avoided, the permittee shall give written
notification to the department, if possible, 30 days prior to such activities,
detailing the reasons for, length of time of, and the potential effects of the
reduced level of treatment. If such a reduction involves a bypass, the require-
ments of Condition G5. and the "Construction or Maintenance Related Overflow or
Bypass" conditions must be met.
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Page 7 of 10
Permit Number WA-QQ2245-4
S9. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW OR BYPASS
Bypasses of untreated or partially treated sewage during construction or mainte-
nance shall be avoided if at all feasible.
If a construction or aaintananca relacad overflow or bypass is conrasplated, the
permittee shall submit to the department not less than 90 days prior to the
contemplated overflow or bypass, a report which describes in detail any con-
struction work which will result in the overflow or bypass of wastewater. The
report shall contain: (1) an analysis of all known alternatives which would
eliminate, reduce, or mitigate the need for bypassing; (2) a cost effective
analysis of alternatives including comparative resource damage assessment; (3)
the minimum and maximum duration of bypass under each alternative; (4) a rec-
o=aendation as to the preferred alternative for conducting the bypass; (5) the
projected date of bypass initiation; (6) a statement of compliance with the
State Environmental Policy Act; and (7) a request for a water quality modifica-
tion, as provided for in Chapter 173-201-100(2) of the Washington Administrative
Code. For probably construction bypasses, the need the bypass is to be iden-
tified as early in the planning process as possible. The analysis required
above shall be considered during preparation of the engineering report or
facilities plan and plans and specifications, and shall be included to the
extent practical. In cases where the. probable need to bypass is determined
;;rl", CT~ti^*^2d i~rlysis is necessary up T> *rA Deluding the construction
period in an effort to minimize or eliminate the bypass.
Final authorization to bypass may be granted after review of the above in-
formation, in accordance with Condition G5. Authorization to bypass will only
be by administrative order.
S10. PROVISION FOR ELECTRIC POWER FAILURE
The permittee is responsible for maintaining adequate safeguards to prevent the
discharge of untreated wastes or wastes not treated in accordance with the
requirements of this permit during electric power failure at the treatment plant
and/or sewage lift stations either by means of alternate power sources, standby
generator, or retention of inadequately treated wastes.
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Page 8 of 10
Permit Number WA-OQ2245-4
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent with
the terms and conditions of this permit. The discharge of any pollutant more
frequently than or at a level in excess of that authorized by this permit shall
constitute a violation of the terms and conditions of this permit.
G2. The permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of the
treatment facility until the facility is restored or an alternative method of
treatment is provided. This requirement applies in the situation where, among
other things, the primary source of power of the treatment facility is reduced,
lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified in
the permit, the permittee shall, at a minimum, provide the department with the
following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
b. The period of noncompliance, including exact dates and times and/or the
anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence of
the noncompliance.
In addition, the permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps to minimize
any adverse impacts to waters of the state and correct the problem. The
permittee shall notify the department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the corrective
actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant effluent
standard under Section 307 (a) of the Clean Water Act, or which could constitute
a threat to human health, welfare, or the environment, 40 CFR Part 122 requires
that the information specified in items G4.a., G4.b., and G4.c., above, shall be
provided not later than 24 hours from the time the permittee becomes aware of
the circumstances. If this information is provided orally, a written submission
covering these points shall be provided within five days of the time the
permittee becomes aware of the circumstances, unless the department waives or
extends this requirement of a case-by-case basis.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of this
permit or the resulting liability for failure to comply.
D-20
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Page 9 of 10
Permit Number WA-002245-4
G5. The intentional bypass of wastes from all or any portion of a treatment works to
the extent that permit effluent limitations cannot be met is prohibited unless
the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (2) accessary co perform construction or
maintenance-related activities essential to ...meet the requirements of the
Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, maintenance during
normal periods of equipment down time, or temporary reduction or termina-
tion of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. Where the permittee knows or should have
known in advance of 'the need for a bypass, this prior notification shall be
submitted for approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the special
condition);
d. The bypass is allowed under conditions determined to be necessary by the
department to minimize any adverse effects. The public shall be notified
and given an opportunity to comment on bypass incidents of significant
duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property, damage
to the treatment facilities which would cause them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not
mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the proposed
bypass, the department will approve or deny the request. Approval of a request
to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department, upon
the presentation of credentials and such other documents as may be required by
law:
a. To enter upon the permittee's premises where a discharge source is located
or where any records must be kept under the terms and conditions of the
permit;
b. To have access to and copy at reasonable times any records that must be
kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method required
in the permit;
d. To inspect at reasonable times any collection, treatment, pollution manage-
ment, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
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Page 10 of 10
Permit Number WA-002245-4
G7. The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
modifications will (1) result in new or substantially increased discharges of
pollutants or a change in the nature of the discharge of pollutants, or (2)
violate the terms and conditions of the existing permit.
G8. After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or mis-
representation of any relevant facts by the permittee in the application or
during the permit issuance process;
c. A change in any condition that requires either a temporary or a permanent
reduction or elimination of any discharge controlled by the permit;
d. Information indicating that the permitted discharge poses a threat to human
health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.62 and 122.63.
Permit modification, revocation and reissuance, or termination may be initiated
by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred or
will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. or 40 CFR Part 122.62 must report its plans, or
such information, to the department so that a decision can be made on whether
action to modify or revoke and reissue a permit will be required. The depart-
ment may then require submission of a new application. Submission of such
application does not relieve the discharger of the duty to comply with the
existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is established
under Section 307 (a) of the Clean Water Act for a toxic pollutant and that
standard or prohibition is more stringent than any limitation upon such pol-
lutant in the permit, the department shall institute proceedings to modify or
revoke and reissue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with WAC
173-240. Facilities shall be constructed and operated in accordance with the
approved plans.
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
^13. -,oLhin.g .Lit this permit snail oe conscruea as excusing che perniccee from compli-
ance with any applicable federal, state, or local statues, ordinances, or
regulations.
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Page 1 of 12
Permit No. WA-002257-8
Issuance Date: MAY 0 9 1988
Expiration Date: MAY 0 9 1993
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In Compliance with the Provisions of
The State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington
and
The Federal Water Pollution Control Act
(The Clean Water Act)
Title 33 United States Code, Section 1/51 et seq.
Qi^v nf T
327 Front Street
Lynden, Washington 98264
Plant Location; Receiving Water;
800 Soutn 6th Street NooksacK River
Lynaen, >.ashington
(Whacccc Bounty;
Waterway Segment Number: Discharge Location:
01-01-04 48°56'16"N
122°27'10"W
is authorized to discharge in accordance with the special and general conditions
which follow.
A
Xancy LlLison, regional Manager
Northwest Regional Office
Department of Ecology
D-23
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Page 2 of 12
Permit No. WA-002257-8
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the issuance date of this permit and lasting through the
expiration date of this permit, the Permittee is authorized to discharge
created municipal wastewater to the Nooksack River at the discharge
location specified on page one of this permit subject to the following
effluent limitations:
EFFLUENT LIMITATIONS
Parameter Monthly Average Weekly Average
Biochemical Oxygen
Demand* (5 day) 30 mg/L, 135 kg/d 45 mg/L, 200 kg/d
(300 Ib/d) (450 Ib/d)
*
Total Suspended Solids 30 mg/L, 135 kg/a 45 mg/L, 200 kg/d
(300 Ib/d) (450 Ib/d)
Fecal Coliform Bacteria 2.00/100 mL 400/100 mi.
**
pH Shall not be outside the range 6.0 - 9.0
* The monthly average percent removal for BOD,, and TSS shall not be less than
85 percent.
** Values outside of this range may be allowed if the Permittee demonstrates
chat such excursions are not the result of inorganic chemical additions to
che treatment process or contributions rrom industrial sources.
The monthly and weekly average effluent limitations for BOD_ and TSS are che
arithmetic mean of the samples taken during a calendar month or week. The
average effluent limitations for Fecal Coliform are the geometric mean of the
samples taken during a calendar month or week.
Total available (Residual) Chlorine shall be maintained which is sufficient
co attain the Fecal Coliform limits specified above. Chlorine concentrations
in excess of that necessary to reliably achieve the limits shall be avoided.
D-24
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Page 3 of 12
'Permit No. WA-002257-a
S2. TESTING SCHEDULE
The Permittee shall monitor influent wascewateri effluent wastewacer and
plant operating parameters according co the relieving schedule:
Sampling
Tests Sampxe Point Frequency Sample Type
Flow
BOD
TSS
Fecal Coliform
Total Available
(Residual) Chlorine
PH
DO
lemuerature
30-Minute Settle-
ability
SVI
uxygen Uptake Rate
Volatile Suspended
Solids
F/M Ratio
MCRT
effluent -
influent
effluent'
influent•
effluent
aeration basins
effluent
effluent
influent
effluent
aeration basins
digester
influent
effluent
aeration basins
digester
influent
affluent
aeration basins
digester
aeration basins
aeration basins
aeration basins
aeration basins
aeration basins
aeration basins
7/week
5/week
5/week
7/week
7/week
5/week
3/week
7/week
7/week
7/week
7/week
2/week
7/week
7/week
7/week
2/week
7/week
7/week
7/weeK
2/week
3/week
3/week
3/week
3/week
2/week
3/week
continuous
recording
24-hour composi;
24-hour composi:
24-hour composi;
24-hour composi:
D-25
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Page 4 of 12
Permit No. WA-0'02257-8
S2. TESTING SCHEDULE (Continued)
Tests
Totaj. Alkalinity
PO,-?
-4
Total Solids
Total Volatile
Solids
Sample Point
influent'
aeration basins
digester
effluent
effluent
effluent
digester
digester
Sampling
Frequency
7/week.
7/week.
2/week
3/week
3/week
3/week
2/week
2/week
Samcle Tvue
NOTE: Except where otherwise stated, sample type is grab.
* Total available (Residual) Chlorine shall be measured and reported
at the same time that Fecal Coliform samples are taken.
S3. MONITORING AND REPORTING
a. Reporting
The Permittee snail monitor the parameters as specified in Condition Si.
of this permit and report the results for each calendar month. The
reports shall be submitted no later than the i5th aay of the month
following the completed reporting period and shall be on forms supplied
or approved by the Department. Completed forms shall be sent to the
Northwest Regional Office of the Washington State Department of Ecology,
4350 - 150th Avenue NE, Redmond, Washington 98052-5301.
In addition, a summary report form (EPA Form 3320-1) covering each
calendar month shall be submitted no later than che 15th day of the
month following the completed reporting period. This report is limitea
to the parameters specified in Condition SI.
If the Permittee monitors any pollutant more frequently chan required by
this permit, such results shall be recorded ana reported in accordance
with these instructions.
b. Records Retention
The Permittee shall retain for a minimum of three vears aii records of
"onitoring activities and results, ir.ciuains ail reports c; recordings
from continuous monitoring instrumentation. This period of retention
D-26
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Page 5 of 12
Permit No. WA-002257-8
S3. MONITORING AND REPORTING (Continued)
shall be extended during che course of any unresolved litigation
regarding the discharge of pollutants by the Permittee or when requested
by che Director of :his Deparraent.
c. Recording of Results
For each measurement or sample taken, the Permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the
analyses; (4) the analytical techniques or methods used; and (5) the
results of all analyses.
d. P.aprasentative Sampling
Samples and measurements taken co meet the requirements of chis
condition shall be representative of the volume and nature of the
monitored discharge, including representative sampling of any unusual
discharge or discharge condition, such as bypasses, upsets, and
maintenance related conditions affecting effluent quality.
e. Test Procedures
All sampling and analytical methods used to meet the monitoring
requirements specified in this permit shall, unless approved otherwise
in writing by the Department, conform to the Guidelines Establishing
Test Procedures for the Analysis of Pollutants, contained in Title 40
Code of Federal Regulations Part 136.
f. Additional Monitoring
The Department may establish specific treatment plant, receiving water,
sediment and biological monitoring requirements beyond those identified
in this permit by permit modification or administrative order.
S4. PREVENTION OF FACILITY OVERLOADING
a. Design Criteria
The design criteria for the permitted .treatment facility are as follows:
Average flow for maximum month: 4540 m3/d (1.2 MGD)
Influent BOD. loading for maximum month: 4885 kg/d (10,770 Ib/d)
Design effluent quality for maximum month: BOD_ 30 mg/L (85% reduction)
TSSJ 30 mg/L (35% reduction)
Design effluent quality for maximum week: BOD. 45 mg/L
TSSJ 45 mg/L
D-27
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Page 6 of 12
Permit No. WA-002257-8
S4. PREVENTION OF FACILITY OVERLOADING (Continued)
Plans for Maintaining Adequate Capacity
When the actual flow or wasteload reaches 85 percent of the design
capacity as specified in paragraph A. above, or when the projected
increases would reach design capacity within five years, whichever
occurs first, the Permittee shall submit to the Department, a plan and a
schedule for continuing to maintain capacity at the facility sufficient
to achieve the effluent limitations and other conditions of this permit.
This plan shall address any of the following actions or any others
necessary to meet this objective.
1. Analysis of the present design including the introduction of any
process modifications that would establish the ability of the
existing facility to achieve the effluent limits and other
requirements of this permit at specific levels in excess of the
existing design criteria specified in paragraph A. above.
2. Reduction or elimination of excessive infiltration and inflow of
uncontaminated ground and surface water into the sewer system.
3. Limitation on future sewer extensions or connections or additional
wasteloads.
4. Modification or expansion of facilities necessary to accommodate
increased flow or wasteload.
The plan shall specify any contracts, ordinances, methods for financing or
other arrangements necessary to achieve this objective.
S3. OPERATION AND MAINTENANCE OF FACILITIES
In accordance with the Washington Administrative Code, Chapter 173-230
(Certification of Operators of Wastewater Treatment Plants), the Permittee
shall provide an adequate operating staff qualified to carry out the
operation, maintenance and testing activities required to ensure compliance
with the conditions of this permit. An operator certified for a Class II
plant by the State of Washington shall be in responsible charge of the day to
day operations of the wastewater treatment facility.
S6. PROVISION FOR POWER FAILURE
The Permittee is responsible for maintaining adequate safeguards to prevent
the discharge of untreated wastes or wastes not treated in accordance with
the requirements of this permit during power failure at the treatment
facility including sewage lift stations either by means of alternate power
sources, standby generation of power, or retention of inadequately treated
wastes.
D-28
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Page 7 of 12
Permit No. WA-002257-8
S7. RESIDUAL SOLIDS HANDLING
a. The Permittee shall handle, utilize and dispose oi all residual solids
in such a manner as to prevent its entry into state ground or surface
waters.
b. The Permittee shall not permit leacfaate from its residual solids to
enter state surface waters without providing all known, available and
reasonable methods of treatment, nor permit such leachate to violate the
State Water Quality Standards, Chapter 173-201, Washington
Administrative Code, or cause any adverse effect of state ground waters.
The Permittee shall apply for a permit or permit modification as may be
required for such discharges.
c. Disposal or utilization of residual solids on land shall be in
accordance with che requirements of Che jurisdictional health
Department.
a. The Department may establish specific sludge management requirements
beyond those identified in this permit by permit modification or
administrative order.
S8. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW, BYPASS OR REDUCTION IN LEVEL OF
TREATMENT
a. The overflow, bypass or reduction in level of treatment of sewage at the
treatment facility or within the sewage collection and transmission
system tributary to the treatment facility in excess of that allowed by
the effluent limitations of this permit during construction or
maintenance shall be avoided if at all possible.
b. If an event as described in paragraph A. above is contemplated which che
Permittee could reasonably be expected to have anticipated, che
Permittee shall submit to che Department not less chan 90 days prior co
che contemplated event, a report which describes in detail any
construction work which will result in such a discharge of wastewater.
The report shall contain: (1) an analysis of all known alternatives
which would eliminate, reduce or mitigate the need for bypassing or
reducing the level of treatment; (2) a cost effective analysis of
alternatives including comparative resource damage assessment; (3) the
duration of such events for each alternative; (4) a recommended
preferred alternative for the bypass or reduction in level of treatment;
(5) the projected date for the event; (6) a statement of compliance with
the State Environmental Policy Act; and (7) a request for a water
quality modification as provided for in Chapter 173-201-100(2) of the
Washington Administrative Code.
c. Final authorization co discharge wastewater as described in paragraph A.
above may be granted after review of che above information, in
accordance with Condition G5. Authorization co discharge such
wastewater will only be by administrative order.
D-29.
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Page 8 of 12
Permit No. WA-002257-8
S8. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW, BYPASS OR REDUCTION IN LEVEL OF
TREATMENT (Continued)
d. If the Permittee expects a reduction in the required level of treatment
that would exceed permit effluent limitations on a short-term basis for
any reason, and such reduction cannot be avoided without resulting in
the discharge of greater quantities of pollutants in the future, and the
Permittee could not reasonably be expected to have anticipated the need
for such reductions in the level of treatment within the time required
for justifying such actions as required in paragraph B. above, the
Permittee shall give written notification to the Department in
accordance with Conditions G4. and G5.
S9. INDUSTRIAL AND COMMERCIAL SOURCES (PRETREATMENT)
The Permittee shall not allow discharges to their sewer system which would
violate the general or specific prohibitions contained in Title 40, Code of
Federal Regulations Part 403.5, or categorical standards contained in Title
40 Code of Federal Regulations Subchapter N, or any applicable regulations
promulgated under Chapter 90.48 of the Revised Code of Washington.
The permittee shall assist the Department in monitoring commercial and
industrial discharges into the sewer system and ensuring that all industrial
and commercial users are in compliance with applicable pretreatment
regulations.
The permittee shall submit written notice to the Department whenever any new
or altered commercial or industrial source proposes to discharge waste into
its sewer system which may interrere with the operation of the treatment
facility, or interfere with the use or disposal of municipal sludge, or which
may pass through the treatment facility causing violations of State Water
Quality Standards (Chapter 173-201 of the Washington Administrative Code).
Neither connection nor discharge to the sewer system shall be allowed until
the commercial or industrial source obtains a State Waste Discharge Permit or
such source is otherwise approved by the Department as provided in Chapter
90.48.160 or Chapter 90.48.200 or the Revised Code of Washington.
The permittee shall perform industrial user survey, reporting, and other
local assistance activities as specified by the Department in support of the
state pretreatment program.
D-30
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Page 9 of 12
Permit No. WA-002257-8
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terms and conditions of this permit. The discharge of any pollutant
more frequently than or at a level 'in excess of that authorized by chis
permit' snail constitute a violation of the terms and conditions .of this
permit.
G2. The Permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the Permittee to achieve compliance with the
conditions of this permit.
G3. The Permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, tailure, or bypass of
che treatment facility until the facility is restored or an alternative
methed of treatment is provided. This requirement applies in the situation
where, among other things, the primary source of power or the treatment
facility is reduced, lost, or fails.
G4. If for any reason the Permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified in
the permit, the Permittee shall, at a minimim, provide the Department with
the following information:
A. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
B. The period of noncompliance, including exact dates ana times and/or the
anticipated time when the Permittee will return to compliance; and
C. Steps taken or to be taken to reauce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the Permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps co
minimize any adverse impacts to waters of the state and correct the problem.
The Permittee shall notify the Department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the
corrective actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant
effluent standard under Section 307 (a) of the Clean Water Act, or which
could constitute a threat to human health, welfare, or the environment, 40
CFR Fart 122 requires that the information specified in items G4.A., G4.B.,
and G4.C., above, shall be provided not later than 24 hours from the cime the
Permittee becomes aware of the circumstances. If this information is
provided orally, a written submission covering these points shall be provided
vithin five days of the time the Permittee becomes aware of the circum-
stances, unless the Department waives or extends this requirement on a
case-by-case basis.
D-31
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.Page 10 of 12
Permit No. WA-002257-8
G4. (Continued)
Compliance with these requirements does not relieve the Permittee from
responsibility to maintain continuous compliance with the conditions of this
permit or the resulting liability for failure to comply.
G5. The intentional bypass of wastes from all or any portion of a treatment works
to the extent that permit effluent limitations cannot be met is prohibited
unless the following four conditions are met:
A. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (2) necessary to perform construction or
maintenance related activities essential to meet the requirements of the
Clean Water Act and authorized by administrative order;
B. There are no feasible alternatives to bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes,
maintenance during normal periods of equipment down time, or temporary
reduction or termination of production;
C. The Permittee submits notice of an unanticipated bypass to the
Department in accordance with Condition G4. Where the Permittee knows
or should have known in advance of the need for a bypass, this prior
notification shall be submitted for approval to the Department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special condition);
D. The bypass is allowed under conditions determined to be necessary by the
Department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become in-
operable, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and.the adverse effects of the
proposed bypass, the Department will approve or deny the request. Approval
of a request to bypass will be by administrative order under RCW 90.48.120.
G6. The Permittee shall allow an authorized representative of the Department,
upon the presentation of credentials and such other documents as may be
required by law:
A. To enter upon the Permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
B. To have access to and copy at reasonable times any records that must be
kept under the terms and conditions of the permit;
D-32
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Page 11 of 12
Permit No. WA-002257-8
G6. (Continued)
C. To inspect at reasonable times any monitoring equipment or method
required in the permit; ..
D. To inspect at reasoaable cimes any collection, treatment, pollution
management, or discharge facilities required under the permit;
E. To sample at reasonable times any discharge of pollutants.
G7. The Permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
modifications will (1) result in new or substantially increased discharges of
pollutants or a. change in the nature of the discharge of pollutants, or (2)
violate the cerms and conditions of the existing permit.
G8. After notice and opportunity for public hearing, Ehis permit may be modified,
cerminated, or revoked during its term for cause as follows:
A. Violation of any term or condition of the permit;
B. Failure of the Permittee to disclose fully all relevant f^cts or mis-
representation of any relevant facts by the Permittee in the application
or during the permit issuance process;
C. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by the
permit;
D. Information indicating that the permitted discharge poses a threat to
human health or welfare;
E. A change in ownership or control of the source;" or
F. Other cause listed in 40 CFR Part 122.62 and 122.63.
Permit- modification, revocation and reissuance, or termination may be
initiated by the Department or requested by any interested person.
G9. A Permittee who knows or has reason to believe that any activity has occurred
or will occur which would constitute cause for modification or revocation and
reissuance under Condition G3. or 40 CFR Part 122.62 must report its plans,
or such information, co the Department so that a decision can be made on
whether action to modify or revoke and reissue a permit will be required.
The Department may then require submission of a new application. Submission
of such application does not relieve the discharger of the duty co comply
with the existing permit until it is modified or reissued.
G10. If any applicable coxic- effluent standard or prohibition (including any
schedule or compliance specified in such effluent standard or prohibition) is
established under Section 307(a) of the Clean Water Act for a toxic pollutant
and that standard or prohibition is more strineent than any limitation upon
sucn poi^ucant ir. tne permit, cne Department snail institute proceedings co
D-33
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Page 12 of 12
Permit No. WA-002257-8
G10. (Continued)
modify or revoke and reissue the permit to conform to the toxic effluent
standard or prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities,
detailed plans shall be submitted to the Department for approval in
accordance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
G13. Nothing in this permit shall be construed as excusing the Permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-34
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Page i of 10
Femur No. WA-002043-5 CM)
Issuance Date: •"• " : "W
Expiration Date: '.PR 3 Q 199*1
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In Compliance with the Provisions of
The State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington
and
The Federal Water Pollution Control 'Act
(The Clean Water Act)
Title 33 United States Code, Section 1251 et seq.
CITY OF EVERSON
P.O. Box 315
Everson, Washineton 98247
Plant Location:
Main Street and Park Drive
Receiving Water:
Nooksack River. Class A
'•'atervay Segment "umber:
01-01-04
Outfall
001
Outfall
002
Discharge Location:
Latitude: 48° 55' 06"
Longitude: 122° 20' 52"
Latitude: 48° 55' 10"
Longitude: 122° 21' 10"
is authorised to discharge in accordance with the special and general conditions
which follow.
.^tfohn H. Glynn ^
D-35
Acting icction Supervisor
Permits and General Water Quality
Northwest Regional Office
Denart^ent of Ecology
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Page 2 of 10
Permit Number WA-002G43-5(M)
SPECIAL CONDITIONS
51. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the issuance date of this permit and lasting through the expiration
date of this permit, the permittee is authorized to discharge treated municipal
vastewater to the Nooksack River at the permitted discharge locations (outfalls
OOL-and 002) subject to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS
Parameter Monthly Average Weekly Average
Biochemical Oxygen Demand* 30 mg/1 45 me/1.
(5 day) (77 Ibs/day) (142 Ibs/day)
Total Suspended Solids* 30 me/1 45 me/I
(58 Ib/day) (142 Ibs/day)
7ecai Coliform Bacteria 200/100 ml 400/lOOml
pH** ch?ll net be outside the range 6.0 - ?.C
*The monthly average effluent concentration limitations for BOD. and Total Suspended
Solids shall not exceed 30 mg/1 or 15 percent of the respective influent concen-
trations, whichever is more stringent.
**Effluent values for pK shall not exceed the limits 6.0 - 9.0 where such values are
attributable to inorganic chemical addition to the treatment process or to industrial
contributions.
The monthly and weekly averages for BOD. and Suspended Solids are based on the
arithmetic mean of the samoles taken.
:r.e geometric mean of the samples taken.
rithmetic mean of the samoles taken. The averages for Fecal Coliforn are based or.
Iota! -available residual chlorine shall be maintained which is sufficient to attain
rhe Fecal Coliform limits specified above. Chlorine concentrations in excess of that
necessary to reliably achieve the limits shall be avoided.
D-36
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Page 3 of 10
Permit Number WA-002043-5(M)
S2. TISTIXG SCHEDULE
The permittee shall monitor plant processes and wastewater according co che
following schedule:
.asrs
Flow
pH
Temperature
300-
Total Suspended
Solids
Dissolved
Oxygen
: amr> i £
influent
influent
effluent
aeration basins
influent
aeration basins
influent
effluent
influent
effluent
aeration basins
influent
effluent
aeration basins
Volatile Solids influent
aerobic digester
TVSS
SVT
aeration basins
aeration basins
ing Frsauer.cv
7/week
5/week
5/week
5/week
5/week
5/week
Weekly
Weekly
Weekly
Weekly
Weekly
5/week
5/week
5/week
Weekly
Weekly
Weekly
Weekly
Continuous Recordins
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Loading Index
(F/M Ratio) aeration basins
Total
available
(residual)
chlorine
Fecal
Coliform
effluent
effluent
Weekly
5/week*
3/week*
Total available (residual) chlorine shall be measured and reported at the same
time that Fecal Coliform samples are taken.
Except where otherwise indicated, sample type is grab.
D-37
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Page 4 of 10
Permit Number WA-002043-5(M)
MONITORING AND REPORTING
a. Reporting
A monthly report recording each required analysis shall be submitted nc
later than the 15th day of the following month. The monthly reporting forr
will be supplied to che permittee or approved by the department and sent tc
the Northwest Regional Office of the Washington State Department o:
Ecology, 4350-150th Avenue N.E., Redmond, Washington 98052.
Monitoring shall be started on the issuance date of this permit and the
first monthly report is due 45 days thereafter.
If the permittee monitors any pollutant any more frequently than requirec
by the permit, he shall record and report such results.
b. Records Retention
The permittee shall retain for a minimum of three years all records or
monitoring activities and results, including all reports of recordings frotr.
continuous monitoring instrumentation. This period of retention shall be
extended during the course of any unresolved litigation regarding the
discharge nf pollutants by the perdict-e •_•!. "..lien requested uy the Queerer.
c. Recording of Results
For each measurement or sample taken, the permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the analyses:
(4) the analytical techniques or methods used; and (5) the results of all
analyses.
i. Representative Sampling
Samples and measurements taken ro meet the requirements of this condition
shall be representative of the volume ana nature of the monitored dis-
charge, including representative sampling of any unusual discharge or
discharge condition, including bypasses, upsets, and maintenance related
conditions affecting effluent quality-
D-38
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Page 5 of 10
Permit Number l;A-OQ2043-5(M)
'.'.ONITORING AND REPORTING (Conrinuea)
g. Test Procedures
All sampling and analytical nethods used to ceer the T.onitorir.2 rscuirs-
-isnts specified in tnis permit snail, unless approved otherwise in wricir.:
by the Deparrnent, conform to the Guidelines Establishing Test Procedure;
for the Analysis of Pollutants, contained in 40 CFR Part 136.
:. Additional Monitoring
The department may establish specific monitoring requirements beyond those
identified in this permit by pemir modification or administrative order.
PREVENTION OF FACILITY OVERLOADING
a. Design Criteria
The design loading criteria for the permitted treatment facility are as
follows:
Flow
avera^p ^ay (C.236 MGD) 85% capacity - .Zui 'HUM
peak hour ' (1.657 MGD)
peak monthly (.378 MGD) 85% capacity » .321 MGD
Population 2,051
Biochemical Oxygen Demand (513 Ib/d) 85% capacity = 436 Ib/d
(5-day)
Total Suspended Solids '390 Ib/d) 85% capacity = 332 Ib/d
ig- removal for BOD(5) and TSS r.o less rhan 85%.
:. Plans for Maintaining Adequate Capacity
When the actual flow or waste load reaches 85 percent of the design ca-
pacity as specified in Paragraph a., or when projected increases would
reach design capacity within five years, whichever occurs first, the
permittee shall submit to the department, a plan and a schedule for con-
tinuing to maintain adequate capacity. This plan shall address any and all
of the actions necessary to neet this objective. This may include the
following items:
1. Analysis of the present design and/or process modifications that would
establish the ability of the existing facility to reliably treat flows
and/or waste loads (i.e., achieve the effluent limits and other
requirements of this permit), in excess of the existing design
criteria.
-• Elimination -:" ixcsssive ^.filtration ana inflow o: uncontaminacea
ground and surface water into the sewer system to reduce extraneous
flow.
D-39
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Page 6 of 10
Permit Number WA-OQ2043-5(M)
54. PREVENTION OF FACILITY OVERLOADING (Continued)
3. Limitation on future sewer extension or connections or additional or
waste load.
4. Modification or expansion of facilities necessary ro accommoGate
increased flow or waste load.
5. Any other actions necessary to achieve this objective. The plan shall
specify any contracts, ordinances, methods for financing or other
arrangements arrangements necessary to achieve this objective.
55. INDUSTRIAL AND COMMERCIAL SOURCES (PRETREATMENT)
The permittee shall submit written notice to the department whenever any new or
altered commercial or industrial source proposes to discharge waste into it's
municipal sewer system which may interfere with the operation of the treatment
WOTKS including interference with the use or disposal of municipal sludge and/or
which may pass through the treatment works causing violations of the State Water
Quality Standards (Chapter 173-201 Washington Administrative Code). Connection
to che sewer system shall not be allowed until the commercial or industrial
applicant obtains a State Waste Discharge Permit as provided in the Revised Code
of rt'ashineton Chant"-1- 90.48.160.
The permittee shall assist the department in monitoring commercial and in-
dustrial discharges into the municipal sewer system.
56. RESIDUAL SOLIDS HANDLING
a. The permittee shall handle, utilize and dispose of all residual solids in
such a manner as to prevent its entry into state ground or surface waters.
b. The permittee shall not permit leachate from its residual solids co er.ter
state surface waters without providing all known, available and reasonable
methods of treatment, nor permit such leachate to cause anv adverse effect-
on state ground waters. The permittee shall apply for a permit or permit
modification as may be required for such discharges.
c. All residual solids disposal shall be in accordance with the requirements
of the jurisdictional health department.
S7. OPERATION AND MAINTENANCE OF FACILITIES
In accordance with the Washington Administrative Code, Chapter 173-230 (Certi-
fication of Operators of Wastewater Treatment Plants), the permittee shall
provide an adequate operating staff which is qualified to carry out the opera-
tion, maintenance and testing activities required to insure compliance with the
conditions of this permit. An operator certified for a Class I plant by the
State of Washington shall be in responsible charge of the day ro day operation
of the wastewater treatment plant.
D-40
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Page 7 of 10
remit Number WA-002043-5(M)
23. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW, BYPASS OR REDUCTION IN LEVEL 0?
TREATMENT
If che permittee contemplates a reduction in the reauired Isvei of treatment
chat would exceed permit effluent limitations on a short term basis for any
reason, and such reduction cc.r.noc be avoided, me remittee snail sive wr-crar.
notification co che department, if possible, 30 days prior'to such activities,
detailing the reasons for, length of time of, and the potential effects of "he
reduced level of treatment. If such a reduction involves a bypass, the require-
ments of Condition G5. and the "Construction or Maintenance Related Overflow or
Bypass" conditions must be met.
S9. CONSTRUCTION OR MAINTENANCE RELATED OVERFLOW OR BYPASS
Bypasses of untreated or partially treated sewage during construction or mainte-
nance shall be avoided if ac all feasible.
If a construction or maintenance related overflow or bypass is contemplated, the
permittee shall submit to the department not less than 90 days prior co che
contemplated overflow or bypass, a report which describes in detail any con-
struction work which will result in the overflow or bypass of wastewater. The
report shall contain: (1) an analysis of all known alternatives which would
eliminate, reduce, or mitigate rho n<»ed fcr bypassir^; (2] -. zzzz effective
analysis of alternatives including comparative resource damage assessment; (3)
the minimum and maximum duration of bypass under each alternative; (4) a rec-
ommendation as to the preferred alternative for conducting the bypass; (5) che
projected date of bypass initiation; (6) a statement of compliance with the
State Environmental Policy Act; and (7) a request for a water quality modifica-
tion, as provided for in Chapter 173-201-100(2) of the Washington Administrative
Code.
For probable construction bypasses, che need to bypass is to be identified as
early in the planning process as possible. The analysis recuired above shall be
considered during preparation of the engineering report or facilities plan ar.d
plans and specifications, and shall be included co che extent practical. Ir.
cases where the probable need Co bypass is determined early, concinued analysis
is necessary up co and including che construction period in an effort co
minimize or eliminate che bypass.
Final authorization co bypass may be granted after review of the above in-
formation, in accordance with Condition G5. Authorization to bypass will only
be by administrative order.
S10. PROVISION FOR ELECTRIC POWER FAILURE
The permittee is responsible for maintaining adequate safeguards to prevent the
discharge of untreated wastes or wastes not treated in accordance with che
requirements of this permit during electric power failure ac the treatment plane
and/or sewage lift stations either by means of alternate power sources, standby
generator, or retention of inadequately treated wastes.
D-41
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Page 8 of 10
Permit Number WA-Q02043-5(K)
GENERAL CONDITIONS
C-l. Ail discharges and acciviries authorized by this permit shall be consistent
the terms and conditions of this permit. The discharge of any pollutant nore
frequently than or at a level in excess of that authorized by this permit shall
constitute a violation of the terms and conditions of this permit.
C-2. The permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances;
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of the
treatment facility until the facility is restored or an alternative method of
treatment is provided. This requirement applies in the situation where, among
other things, the primary source of power of the treatment facility is reduced,
lost, or fails.
C-4. If, for any reason, the permittee does not comply with or will be unable cc
comply with any of the discharge limitations or other conditions specified in
the permit, the permittee shall, at a minimum, provide the department with the
following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
b. The period of noncompliance, including exact dates and times and/or the
anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence of
the noncompliance.
In addition, the permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps to minimize
any adverse impacts to waters of the state and correct the problem. The
permittee shall notify the department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the corrective
actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant effluent
standard under Section 307 (a) of the Clean Water Act, or which could constitute
a threat to human health, welfare, or the environment, 40 CFR Part 122 requires
that the information specified in items G4.a., G4.b., and G4.c., above, shall be
provided not later than 24 hours from the time the permittee becomes aware of
the circumstances. If this information is provided orally, a written submission
covering these points shall be provided within five days of the time the
permittee becomes aware of the circumstances, unless the department waives or
extends this requirement of a case-by-case basis.
Compliance with these requirements does not relieve the permittee from
resijonsibilitv ro ™aintain continuous coTnt3liar.ee vith the conditions c; this
permit or the resulting liability for failure to comply.
D-42
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Page 9 of 10
Permit Number WA-Q02043-5(M)
G5. Tr.e intentional bypass of wastes from ail or any portion of a treatment works cc
rhe extent that permit effluent limitations cannot be net is prohibited unless
c'r.e following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (21 necessary TO perform construction :r
^aintenance-ceiatea activities essential to meet the requirements of che
Clean Water Act-and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, maintenance during
normal periods of equipment down time, or temporary reduction or termina-
tion of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. Where the permittee knows or should have
known in advance of the need for a bypass, this prior notification shall be
submitted for approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the special
condition);
d. The bypass is allowed under conditions determined to be necessary by the
denartment to minimize any a«iv<>r<=« <*?f*'*r?. The public shall be notifi:J
and given an opportunity to comment on bypass incidents of significant
duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property, damage
to the treatment facilities which would cause them Co become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not
mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the proposed
bypass, the department will approve or deny the request. Approval of a requesc
:~ bypass will be by administrative order under RCW 90.48.120.
C6. The permittee shall allow an authorized representative of the department, upon
che presentation of credentials and such other documents as may be required by
law:
a. To enter upon the permittee's premises 'where a discharge source is located
or where any records must be kept under the terms and conditions of che
permit;
b. To have access to and copy at reasonable times any records chat must be
kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method required
in the permit;
c. To inspect at reasonable times any collection, treatment, pollution manage-
ment . rr discharse fnciliries required under ru.e permit:
;. ~.o samuie at reasonable cimes any discharge of pollutants.
D-43
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Page 10 of 10
Permit Number WA-OQ2Q43-5(M)
G7- The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
modifications will (1) result in new or substantially increased discharges of
pollutants or a change in the nature of the discharge of pollutants, or (2)
violate the terms and conditions of the existing permit.
G8. After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or mis-
representation of any relevant facts by the permittee in the application or
during the permit issuance process;
c. A change in any condition that requires either a temporary or a permanent
reduction or elimination of any discharge controlled by the permit;
d. Information indicating that the permitted discharge poses a threat to human
health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.62 and 122.63.
Permit modification, revocation and reissuance, or termination may be initiated
by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred or
will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. or 40 CFR Part 122.62 must report its plans, or
such information, to the department so that a decision can be made on whether
action to modify or revoke and reissue a permit will be required. The depart-
ment may then require submission of a new application. Submission of such
application does not relieve the discharger of the duty ro comply with the
existing permit until it is modified or reissued.
G10. I-f any applicable toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is established
under Section 307(a) of the Clean Water Act for a toxic pollutant and that
standard or prohibition is more stringent than any limitation upon such pol-
lutant in the permit, the department shall institute proceedings to modify or
revoke and reissue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with WAC
173-240. Facilities shall be constructed and operated in accordance with the
approved plans.
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee from compli-
ance with any applicable federal, state, cr local statues, ordinances, cr
regulations. D-44
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Page 1 of
Permit Number
WA-0002T4-3
Issuance Date:
Expiration Date:"
AUG L2 1983
~AUG U
NATIONAL POLLUTANT DISQ1ARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Act as amended
Public Law 95-217
Bellingham Cold Storage Company
P.U. Box 895
Bellingham, Washington 98225
Plant Location:
Squalicum Fill
.Receiving Water:
BelHngham Bay
Industry TM3e :
Seafood, Processing § Cold Storage
Waterway Segment Number:
01-01-03 (Cooling Water)
01-01-02 (Process Wastewater)
Discharge Location:
Latitude: 001 48° 45' 47" N
002 48° 45' 34" N
Longitude:001 122° 30' 32" W
' 002 122° 30' 29" W
is authorized to discharge in accordance with the special
and general conditions which follow.
Bruce A.
Assistant Director.
Department of Ecology f I)
D-45
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Page 2 oL" 7
Permit No. WA-0002 1-1-3
SPECIAL CONDITIONS
SI.a. EF1:LUL;NT LIMITATIONS (Non Contact Cooling Water)
During the period beginning on the date of issuance of this permit and lasting until the expiration
date of this permit, the permittee is authorized to discharge non-contact cooling water to outfalls 001
and 002 to BelHngham Bay at the permitted locations subject to the following limitations:
EFFLUENT LIMITATIONS
Parameters Daily Maxunum
Flow 220 m3/d
O (58,000 gxi)
-U
°" Temperature 30° C
(85° F)
The daily maximum is defined as the greatest allowable valjc for any calendar day.
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Page 3 of /
PC nn it No. WA 0002J-l-
SPECIAL CONPITI )NS
Sl.b. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Process tastewater)
IXiring the period beginning on the date of issuance of this permit and lasting until the expiration
date of this permit, the permittee is authorized to discharge screened process wastewaters
to the Hellinghnm Sanitary Sewer System subject to the following limitations and monitoring
requirements:
EFFLUENT LIMITATIONS
Parameters Daily Maximum
D Flow 40 m3/d
I (10,000 gpd)
The daily maximum is defined as the greatest allowable value for any calendar day.
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Page 4 of 7
Permit N'o. V,'A-000214-3
S2. OPERATION AND MAINTENANCE
a. All seafood processing wastewater and washdown water shall be
screened (not greater than 40 mesh openings) and discharged to
the Bellingham sanitary sewer system.
b. Off loading of seafood on the dock shall be accomplished with a
minimum of waste discharge.
c. Contents of vessel bilges shall not be discharged into the harbor or
inner bay.
d. .All solids to be utilized in by-products shall be stored, handled
and transported in a manner which prevents its entry or the drainage
thereof into surface waters of the state.
e. All cold storage warehouse drains shall dishcharge to the Bellingham
sanitary sewer system.
f. All saniLaiy wetsms siia.ll be discharged into the Bellingham sanitary
sewer system.
S3. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material
in such a manner as to prevent its entry into state ground or
surface waters. All solid waste disposal shall be in accordance
with the requirements of the Bellingham Whatcom County Health District.
b. The permittee shall not permit leachate from its solid waste material
to enter state surface waters without providing all known, available
and reasonable methods of treatment, nor permit such leachate to
- cause any adverse effect on state ground waters. The permittee shall
apply for a permit or permit modification as may be required for
such discharges.
D-48
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5 bf 7
Permit ,\rc. V,rA-000214-3
CENTRAL CONDITION'S
"il. .Ml discharges and activities authorized by this permit shall be consistent
with the terms and conditions of tins permit. The discharge of any pollutant
more frequently than or at a level in excess of that authorized by this
permit shall constitute .1 violation of che corns and conditions of tnis
permit.
G2. The permittee shall at all times properly operate and maintain ail facilities
and systems of collection, treatment and control (and related, appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall
control production and/or all discharges upon reduction, loss, failure, or
bypass of the treatment facility until the facility is restored or an
alternative method of treatment is provided. This requirement applies in
the situation where, among other things, the primary source of power of the
treatment facility is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit rhf» nomitrce shall, nr a minimrm. nrnvidn the ^na-rtment
with the following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliancc.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take ail reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the
corrective -actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant
effluent standard under Section 307 (a) of the Clean Water Act, or which
could constitute a threat to human health, welfare, or the environment,
40 CFR Part 122 requires that the information specified in items G4.a.,
G4.b., and G4.c., above, shall be provided not later than 24 hours from the
time the permittee becomes aware of the circumstances. If this information
is provided orally, a written submission covering these points shall be
provided within five days of the time the permittee becomes aware of the
circumstances,, unless the department waives or extends this requirement on
a case-by-case basis.
compliance with these requirements docs not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
D-49
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1'agc 6 of 7
Permit No. WA-000214-3
G3. The intentional bypass of wastes from all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is
prohibited unless the following four conditions arc met:
a. Bypass is: (1] unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction or
maintenance- related activities essential to meet the requirements of
the Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, mainten-
ance during normal periods of equipment down time, or temporary reduc-
tion or termination of production;
c. The permittee submits notice of an unanticipated bypass to the depart-
ment in accordance with Condition G4. Where the permittee knows or
should have known in advance of the need for a bypass, this prior
notification shall be submitted for approval to the department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special conditions) ;
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
ty damage" means substantial physical damage tc pvc,~;c;ty,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the
proposed bypass, the department will approve or deny the request. Approval
of a request to bypass will be by administrative order under RG'<" 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
D-50
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Page ~ of 7
Permit No. WA-000214-3
-edifications will (11 result in new or substantially increased discharges
of pollutants or a change in the nature of the discharge of pollutants, or
;Z] violate the terns and conditions of the existing permit.
GS. After notice and opportunity for public hearing, this permit my be modified,
terminated, or revoked during it" "CTTT. for cause .".s follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully ail relevant tacts or
misrepresentation of any relevant facts by the permittee in the
application or during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by
the permit;
d. Information indicating that the permitted discharge poses a threat to
human health or welfare;
e. A change in ownership or control of the source; or
f. nther cause listed in 40 CItt Part 122.15 and 122.16.
Permit modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity lias
occurred or will occur which would constitute cause for modification or
revocation and reissuance under Condition C8. or 40 CFR Part 122.15 must
report its plans, or such information, to the department so that a decision
can be made on whether action to modify or revoke and reissue a permit will
be required. The department may then require submission of a new application.
Submission of such application docs not relieve the discharger of the duty
to comply with the existing permit until it is modified or reissued.
G10.- If any applicable toxic effluent standard or prohibition [including any
schedule of compliance specified in such effluent standard or prohibition)
is established under Section .307(a) of the Clean Water Act for a toxic
pollutant and that standard or prohibition is more stringent than any
limitation upon such pollutant in the permit, the department shall institute
proceedings to modify or revoke and reissue the permit to conform to the
toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wastcwater control facilities,
detailed plans shall be submitted to the department for approval in accor-
dance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR Part 122.7, 122.00, and 122.61 are in-
corporated into this permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-51
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Page I of 8
Permit Number 5166
Issuance Date: July 21. 19'
Expiration'Date: .July 21. 1.
STATE WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
BELLINGHAM FROZEN FOODS, INC.
P.O. Box 1016
Bellingham, Washington 98225
Plant Location: Receiving Water:
Squalicum Fill Bellingham Bay via Bellingham Wastewater
Treatment Plant
Industry Type: Discharge Location:
Vegetable Processing Latitude: 48° 43' 00" N
Longitude: 122° 31' 05" V,r
Waterway Segment Number:
01-01-02
is authorized to discharge in accordance with the special
and general conditions which follow.
ROBERT K. McCORMICK, Regional Manager
Department of Ecology (1)
D-52
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Page 2 of 8
Permit No. 5166
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Upon the issuance date of this permit and lasting throjgh the expiration date of this permit, the
permittee is authorized to discharge screened process vastewater to the Bellingham Sanitary Sewer
System subject to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS hDNITORING REQUIREMENTS*
Parameters Daily Average Daily Maximum Minimum Frequency Sample Type
* ,
7,500 m /d 9,500 m /d
(2,000,000 gpd) (2,500,000 pgd)
* ,
Flow 7,500 m /d 9,500 m /d Daily Calculate
The daily average is defined as the average of the measured values obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for any calendar day.
*Monitoring shall be conducted during the processing soason.
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Page 3 of 8
Permit No. 5166
52. MONITORING AND REPORTING
The permittee shall monitor the operation and efficiency of all treatment
and control facilities and the quantity and quality of the v-aste dis-
charged. A record of all such oata shall be maintained. The permittee
shall monitor the parameters as specified in Condition SI of this .permit.
a. Reporting
Monitoring results obtained during the previous three months shall
be summarized and reported on a form provided by the department, to
be submitted no later than the 15th day of the month following the
completed reporting period. The report shall be sent to the Northwest
Regional Office of the Department of Ecology, 4350 - ISOth Avenue N.E.,
Redmond, Washington .98052. Monitoring shall be started on the first
day of processing and the first report is due 3-h months later.
b. Records Retention
The permittee shall retain for a minimum of three years all records of
monitoring activities and result«. Deluding all repc^r of rs=crdi£~
from continuous monitoring instrumentation. This period of retention
shall be extended during the course of any unresolved litigation re-
garding the discharge of pollutants by the permittee or when requested
by the director.
c. Recording of Results
For each measurement or. sample taken the permittee shall record the
following information: (1) the date, exact place and time of sampling;
(2) the dates the analyses were performed; (3) who performed the analyses;
(4) the analytical techniques or methods used; and (5) the results of
all analyses.
d. 'Representative Sampling
Samples and measurements takcvi to meet the requirements of this condition
shall be representative of the volume and nature of the monitored dis-
charge.
D-54
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Page 4 of
Permit No. 5166
S2. MONITORING AND REPORTING (Continued)
e. Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in writ-
ing by the department, conform to the of the Guidelines Establishing
Test Procedures for the Analysis of Pollutants, contained in 40 CFR
136, as published in the Federal Register on December 1, 1976, or the
latest revision thereof, which currently references the following
publications:
1. .American Public Health Association, Standard Methods for the Exami-
nation of \ 'nter and Wastewaters.
2. American Society for Testing and Materials, A.S.T.M. Standards,
Part 31, Water, Atmospheric Analysis.
3. Environmental Protection Agency, Methods for Chemical Analysis
of Water and Wast.fvs
S3. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste including,
but not limited to cull materials, screenings and other solids from
washing, cutting and sorting, in such a manner as to prevent its
entry into state ground or surface waters.
b. The permittee shall not permit leachate from its solid waste,
including, but not limited to cull materials, screenings and other
solids from washing, cutting and sorting, to enter state surface
waters without providing all known, available and reasonable methods
of treatment, nor permit such leachate to cause any adverse effect
on state ground waters. The permittee shall apply for a permit or
permit modification as may be required for such discharges.
S4. OPERATION AND MAINTENANCE
a. .All process wastewater whall pass through a 40 mesh screen or its
equivalent prior to discharge to the Bellingham Sanitary Sewer System.
b. .All drainage from raw vegetable storage areas shall be screenc \ and
shall discharge to the Bellingham Sanitary Sewer System.
D-55
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Page 5 of 8
Permit No. 5166
OTHER REQUIREMENTS
If increased levels of pollutant discharges result in structural deterioration
or the sewer system or significanr reduction in pollutant removal efficiencies
at the Bellingham wastewater treatment plant, this permit may be modified
to require pretreatment, reduced levels of production or other measures
necessary to eliminate such structural deterioration or reductions in treatment
removal efficiencies.
D-56
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Page 6 of 8
Permit \'o. 5166
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terms and conditions of this v'-rmit. The discharge of any pollutant
aore frequently than or at a level in c/.cess of that authorized by this
permit shall constitute a violation of the terms and conditions of this
permit.
G2. The permittee shall at all times maintain in good working order and operate
as efficiently as possible all facilities and systems (and related appur-
tenances) for collection and treatment which are' installed or used by the
permittee for water pollution control and abatement to achieve compliance
with the terms and conditions of this permit.
G5. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of
the treatment facility until the facility is restored or an alternative
method of treatment is provided. This requirement applies in the situation
where, among other things, the primary source of power of the treatment fa-
cility is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit, the permittee shall, at a minimum, provide the department
with the following information:
a. A description oC the nature and cause of noncompliance, including the
quantity and quality of any unauthorized waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the cor-
rective actions taken to determine if additional action should be taken.
In the case of any discharge which could constitute a threat to human health,
welfare, or the environment, the information specified in items G4.a., G4.b.,
and G4.c., above, shall be provided not later than 24 hours from the time
the permittee becomes aware of the circumstances. If this information is
provided orally, a written submission covering these points shall be pro-
vided within five days of the time the permittee becomes aware of the cir-
cumstances, unless the department waives or extends this requirement on a
case-by-case basis.
D-57
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Page 7 of 8
Permit No. 5166
Coir.niiar.ee with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the- resulting liability for failure to comply -
G3. The intentional bypass of wastes fron all or any portion o£ a treatment
works to the extent that permit effluent limitations cannot be met is pro-
hibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction
or maintenance-related activities essential to meet the requirements
of the permit and authorized by administrative order;
b. There arc no feasible alternatives to bypass, such as the use of aux-
iliary treatment facilities, retention of untreated wastes, maintenance
during normal periods of equipment down time, or temporary reduction or
termination of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with. Condition G4. Where the permittee knows or should
havp lonnwn in advance of t^*» n^o^ fn-r a Kynar-c> ft?1".? prior notification
shall be submitted for approval to the department, if possible, at least
30 days before the date of bypass (or longer if specified in the special
conditions);
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the pro-
posed bypass, the department will approve or deny the request. Approval of
a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and condi-
tions of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
D-58
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Page 8 of 8
Permit No. 5166
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall apply for a new permit at least sixty days prior to the
time when facility expansions, production changes, or process modifications
will (1) result in new or substantially increased discharges of waste charac-
teristics or volume or a change in the nature of the discharge of pollutants,
or (2) violate the terms and conditions of the existing permit.
G8. A permit shall be subject to termination upon thirty days notice in writing
if the department finds:
a. That it was procured by misrepresentation of any material fact or by
lack of full disclosure in the application;
K That rho-ro v-as V-^OT, a violation of the ccnditlcr.5 thwreof;
c. That a material change in quantity and type of waste disposal exists.
In the event that a material change in the conditions of the state waters
Utilized creates a dangerous degree of pollution, the department may specify
additional conditions in the permits previously issued.
The director of the department is authorized to issue permits for waste
disposal and specify the conditions and expiration date of such permits.
Permit modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred
or will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. must report its plans, or such information, to
the department so that a decision can be made on whether action to modify or
revoke and reissue a permit will be required. The department may then require
submission of a new application. Submission of such application does not
relieve the discharger of the duty to comply with the existing permit until
it is modified or reissued.
G10. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with
WAC 173-240. Facilities shall be constructed and operated in accordance with
the approved plans.
Gil. N'othing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-59
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Page 1 of 7
Permit Number WA-0029S1-S
Issuance Date: JUL 2 2 IS83
Expiration Date: up 22 ]3i
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Act as amended
Public Law 95-217
SEA PAC COMPANY, INC.
601 West. CiiosUiUu Street
Bellingham, Washington 98225
Plant Location: Receiving Water:
iquaiicum Way Bellmgham Bay
Bellingham, WA
Industry ~vpe_ : Discharge Location: (cooling water)
Seafood Processing Latitude: 48° 45' 27" N
Longitude: 122° 30' 22" W
Waterway Secjnent Number:
01-01-02 (Process wastewater)
01-01-03 (Cooling water)
is authorized to discharge in accordance with the special
and general conditions which follow.
Bruce AJ Cameron /
Assistant Director/
Department of Ecology (I)
D-60
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Page 2 of 7
To mi it No. U'A-002981-5
SFHCTAL CONDITIONS
SI.a. LiFHAJENT LIMITATIONS (iincontmninated cooling w^tcr)
Din-ing the period beginning on the date of issuance of this permit and lasting until the
expiration date of this permit, the permittee is authorized to discharge uncontaminated
cooling water to Bellinghain Bay subject to the following limitations:
EFFLUENT LIMITATIONS
Parameters Daily Maximum
Flow 19 m3/d (5,000 gpd)
The daily maximum is defined as the greatest allowable value for any calendar day.
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Page 3 of 7
Penult No. WA-002981-5
SPHCIAL CONDITIONS
Sl.b. EFRIJENT LIMITATIONS (process wasltv/ater)
During the period beginning on the date of issinnce of this permit and lasting until the
expiration date of this permit, the permittee is authroized to discharged screened process
wastewater to the City of Bellingham Sanitary Sewer System subject to the following
limitations:
EFFLUENT LIMITATIONS
Parameters Daily Average Daily Maximum
Flow 11 m3/d (3,000 gpd) 38 n)3/d (10,000 gpd)
The daily average is defined as the average of the measured values for each operating day
obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for any calcndaiy day.
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Page 4 of 7
Permit No. WA-002981-5
S2. OPERATION AND MAINTENANCE
a. All seafood processing wastev.'ater and washdown water shall be
screened (not greater than 1/4 inch openings) and discharged to
the Bell' "_;ham sanitary sewer system.
b. Off loading of seafood on the dock shall be accomplished with a
minimum of waste discharge.
c. Contents of vessel bilges shall not be discharged into the harbor.
d. All solids to be utilized in by-products shall be stored, handled
and transported in a manner which prevents its entry or the drainage
thereof into surface waters of the state.
e. All sanitary wastes shall be discharged into the Bellingham sanitary
sewer system.
S3. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid wast.p mater-^.l
in such a manner as to prevent its entry into state ground or
surface waters. All solid waste disposal shall be in accordance with
the requirements of the Bellingham Whatcom County Health District.
b. The pertmittee shall not permit leachate from its solid waste
material to enter state surface waters without providing all
known, available and reasonable methods of treatment, nor permit
such leachate to cause any adverse effect on state ground waters.
The permittee shall apply for a permit or permit modification as
may be required for such discharges.
D-63
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Pa^e 3 of 7
Permit No. WA-002981-5
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall he consistent
with the terms and conditions of this permit. The discharge of any pollutant
r
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Page 6 of 7
Permit No. WA-002981-5
GS. The intentional bypass of wastes frcm all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is
prohibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury',
or severe property damage; or (_) necessary to perform construction or
maintenance- related activities essential to meet the requirements of
the Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, mainten-
ance during normal periods of equipment down time, or temporary reduc-
tion or termination of production;
c. The permittee submits notice of an unanticipated bypass to the depart-
ment in accordance with Condition G4. Where the permittee knows or
should have known in advance of the need for a bypass, this prior
notification shall be submitted for approval to the department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special conditions) ;
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
e property damage11 means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the
proposed bypass, the department will approve or deny the request. Approval
of a request to bypass wall be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
b. To have access to and copy at reasonable ti:. .-s any records that must
be kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect nt reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
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Page 7 of 7
Permit Nro. WA-002981-5
nodifleations v.ill fl) result in new or substantially increased discharges
of pollutants or a change in the nature of the iischarge of pollutants, or
(2) violate the terns and conditions of the existing permit.
C3. After notice and opportunity for public hearing, this permit may he modified,
terminated, jr revoked during it? "crm -or cause :is Follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or
misrepresentation of any relevant facts by the permittee in the
application or during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by
the permit;
d. Information indicating that the permitted discharge poses a threat to
human health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.15 and 122.16.
Permit modification, revocation and rcissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has
occurred or will occur which would constitute cause for modification or
revocation and. rcissuance under Condition G8. or 40 CFR Part 122.15 must
report its plans, or such informa, .on, to the department so that a decision
can be made on whether action to modify or revoke and reissue a permit will
be required. The department may then require submission of a new application.
Submission of such application docs not relieve the discharger of the duty
to comply with the existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any
schedule of compliance specified in such effluent standard or prohibition)
is established under Section 507fa) of the Clean Water Act for a toxic
pollutant and that standard or prohibition is more stringent than any
limitation upon such pollutant in the permit, the department shall institute
proceedings to modify or revoke and reissue the permit to conform to the
toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities,
detailed plans shall be submitted to the department for approval in accor-
dance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR Part 122.7, 122.60, and 122.61 are in-
corporated into this permit by reference.
* /
113. Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-66
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Page 1 of 6
Permit Number
5165
Issuance Date:
Expiration Date:
MAR
STATE WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
SEAWEST INDUSTRIES, INC.
100 Second Avenue
EJssoni:, V.'ashington 98020
Plant Location:
Squalicum Fill
P.O. Box 427
Bellingham, '.vashington 98227
Waterway Segment Number:
01-01-03
Receiving Water:
Bellingham Bay via Bellingham wastewater
treatment system
Discharge Location:
48° 43' 0" N
122° 31' 5" W
is authorized to discharge in accordance with the special
and general conditions which follow.
ROBERT K. McCORiMICK, Regional Manager
Department of Ecology ( )
D-67
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Page 2 of 6
Permit No. 51 Of)
SPECIAL CONDITIONS
SJ. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Upon permit issuance and lasting through the expiration ('ate of this permit, the permittee
is authorized to discharge screened process wastewater f- the Bellingham sanitary sewer
subject to the following limitations:
EFFLUENT LIMITATIONS
Parameter Daily Average Daily Maximum
Flow 265 m3/d S.'-O m3/d
F (70,000 gpd) C40.000 gpd)
oo
The daily average is defined as the average of the measuied values obtained over a calendar month's time.
The daily average is defined as the greatest allowable value for any calendar day.
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Page 3 or 6
Permit Xo. 5165
S2. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material
in such a manner as to prevent, its entry into state ground or surface
waters. All solid waste disposal shall be in accordance with the "
requirements of, the Bellingham Whatcom County Health District.
b. The permittee shall not permit leachate from its solid waste
material to enter state surface waters without providing all
blown, available and reasonable methods of treatment, nor permit
such leachate to cause any adverse effect on state ground waters.
The permittee shall apply for a permit or permit modification
as may be required for such discharges.
S3. OPERATION AND MAINTENANCE
a. All seafood processing wastewater including but not necessarily
limited to water originating from butchering, cutting, glazing,
Iluming and shaking si«*ll U, j-..wined (not greater thcr. i/*. inch
openings) and discharged to the Bellingham sanitary sewer system.
b. All contact cooling water shall be screened and discharged to the
Bellingham sanitary sewer system.
c. All solids to be utilized in by-products shall be stored, handled
and transported in a manner which prevents its entry or the
drainage thereof into surface waters of the state.
d. All solids to be used as fertilizer by land spreading shall be
stored, handled, transported and utilized in accordance with
the requirements of the Bellingham Whatcom County Health District.
e. All sanitary wastes shall be discharged into the Bellingham
sanitary sewer system.
D-69
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Page 4 of 6
Permit No. 5165
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terms and conditions of this permit. The discharge of any pollutant
nore frequently than or at a level in excess of that authorized by this
perntit shall constitute a violation of the terms and conditions of this
permit.
G2. The permittee shall at all times maintain in good working order and operate
as efficiently as possible all facilities and systems (and related appur-
tenances) for collection and treatment which are' installed or used by the
permittee for water pollution control and abatement to achieve compliance
with the terms and conditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of
the treatment facility until the facility is restored or an alternative
method of treatment is provided. This requirement applies in the situation
where, among other things, the primary source of power of the treatment fa-
cincy is reuuced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
' comply with any of the discharge limitations or other conditions specified
in the permit, the permittee shall, at a minimum, provide the department
with the following information:
a.
o.
A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized waste discharges;
The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. -Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the cor-
rective actions taken to determine if additional action should be taken.
In the case of any discharge which could constitute a threat to human health,
welfare, or the environment, the information specified in items G4.a., G4.b.,
and G4.c., above, shall be provided not later than 24 hours from the time
the permittee becomes aware of the circumstances. If this information is
provided orally, a written submission covering these points shall be pro-
vided within five days of the time the permittee becomes aware of the cir-
cumstances, unless the department waives or extends this requirement on a
case-bv-case basis.
D-70
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Page 5 of 6
Permit No. 5165
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
G5. The intentional bypass of wastes from all or any portion of a treatment
v.crks to the extent that permit effluent limitations cannot be met is pro-
hibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction
or maintenance-related activities essential to meet the requirements
of the permit and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of aux-
iliary treatment facilities, retention of untreated wastes, maintenance
during normal periods of equipment down time, or temporary reduction or
termination of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. \Vhere the permittee knows or should
'.wive lutUMU in advaiiv-c ol cue need Tin a. bypasb, this prior notification
shall be submitted for approval to the department, if possible, at least
30 days before' the date of bypass (or longer if specified in the special
conditions);
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the pro-
posed bypass, the- department will approve or deny the request. Approval of
a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and condi-
tions of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
D-71
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Page 6 of 6
Permit No. 5165
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall apply for a new permit at least sixty days prior to the
time when facility expansions, production changes, or process modifications
will (1) result in new or substantially increased discharges of waste charac-
teristics or volume or a change in the nature of the discharge of pollutants,
or (2) violate the terms and conditions of the existing permit.
G8. A permit shall be subject to termination upon thirty days notice in writing
if the department finds:
a. That it was procured by misrepresentation of any material fact or by
lack of full disclosure in the application;
b. That there has been a violation of the conditions thereof;
c. That a material change in quantity and type of waste disposal exists.
In the event that a material change in the conditions of the state waters
Utilized creates a dangerous degree of pollution, the department may specify
additional conditions in the permits previously issued.
The director of the department is authorized to issue permits for waste
disposal and specify the conditions and expiration date of such permits.
Permit modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred
or will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. must report its plans, or such information, to
the department so that a decision can be made on whether action to modify or
revoke and reissue a permit will be required. The department may then require
submission of a new application. Submission of such application does not
relieve the discharger of the duty to comply with the existing permit until
it is modified or reissued.
G10. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with
WAC 173-240. Facilities shall be constructed and operated in accordance with
the approved plans.
Gil. Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-72
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Page 1 of 6
Permit Number S164
Issuance Date: JUL 2 6 IS'33
Expiration Date: J|j[_ % (; ju:.'.j.
STATE WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, V,rashington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
SCHENK SEAFOOD SALES, INC.
P.O. Box 984
Bellingham, Washington 98225
Plant location:
17 Squalicum Way
Bellingham, Washington
Industn' Tvpe:
Seafood Processing
Receiving Water:
Bellingham Bay via Bellingham
Wastewater Treatment Plant
Discharge Location:
Bellingham Sanitary Sewer System
Waterway Segment Number:
01-01-02
is authorized to discharge in accordance with the special
and general conditions which follow.
ROBERT K. McCORMICK, Regional Manager
Department of Ecology (l)
D-73
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Page 2 of 6
Penult No. SI 0-1
SPECIAL CONDIIIONS
SI. EFFLUENT LIMITATIONS
During the period beginning on the date of issuance of this permit and lasting until the
expiration date of this permit, the permittee is authorized to discharge screened waste-
water to the Bcllingluim Sanitary Sewer System subject to the following limitations:
EFFLUDNT LIMITATIONS
Parameter Daily Maximum
Mow 32 m3/d (8.50C gpd)
D
•u
Tlie daily maximum is defined as the greatest allowable value for any calendar day.
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Page 5 of 6
Permit .\'o. 3164
S2. OPERATION AND MAINTENANCE
a. .-II seafooa processing v;astewater ana washcswn .vater shall be screenea
(not greater than 1/4 inch openings) and discharged to the Bellingham
sanitary sewer system.
b. Off loading of seafood on the dock shall be accomplished with a minimum
of waste discharge.
c. Contents of vessel bilges shall not be discharged into the harbor.
d. All solids to be utilized in by-products shall be stored, handled
and transported in a manner which prevents its entry or the drainage
thereof into surface waters of the state.
e. All sanitary wastes shall be discharged into the Bellingham sanitary
sewer system.
S3. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material
in such'a manner as to prevent its entry into state ground or surface
waters. All solid waste disposal shall be in accordance with the
requirements of the Bellingham Wliatcom County Health District.
b. The permittee shall not permit leachate from its solid waste material
to enter state surface waters without providing all known, available
and reasonable methods of treatment, nor permit such leachate to
cause any adverse effect on state ground waters. The permittee shall
apply for a permit or permit modification as may be required for
such discharges.
D-75
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Page 4 of 6
Permit N'o.
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the :emu-, and conditions of this permit. The discharge of any pollutant
,-ore frequently than or at a level in excess of that authorized by this
permit ?:uii constitute a violation of the terms and conditions of this
perrdt.
G2. The permit coo shall at all times maintain in good working order and operate
as cffi.cuT.tly as possible all facilities and systems (and related appur-
tenances) fe.r collection and treatment which are' installed or used by the
permittee ier water pollution control and abatement to achieve compliance
with the terms and conditions of this permit.
G3. ifie ^pcrru: fee., in order to maintain compliance with its permit, shall control
production ;md/or all discharges upon reduction, loss, failure, or bypass of
th2 treat. :-.\>nt facility until the facility is restored or an alternative
method 01 treatment is provided. This requirement applies in the situation
where, a:r.er,£ other things, the primary source of power of the treatment fa-
cility i> \vduced, lost, or fails.
G4. If, for am- reason, the permittee does not comply with or will be unable to
comply wit;-, any of the discharge limitations or other conditions specified
in the pernit, the permittee shall, at a minimum, provide the department
with the following information:
a. A ili\,v-viption of the nature and cause of noncompliancc, including the
quant;ty and quality of any unauthorized waste discharges;
b. Tne period of noncompliancc, including exact dates and times and/or
the -"ticipated time when the permittee will return to compliance; and
c. Steps taken or to be talcen to reduce, eliminate, and prevent recurrence
of t!-.e noncompliance.
In additie:-., the permittee shall take immediate action to stop, contain,
and clear-, —i ;mv unauthorized discharges and take all reasonable steps to
minimize .-.-;%• adverse impacts to waters of the state and correct the problem.
Thepermittee shall notify the department immediately by telephone so that
an invest -./.ition can be made to evaluate any resulting impacts and the cor-
rective ;u-:;ons taken to determine if additional action should be taken.
c- •• of, any discharge which could constitute a threat to human health,
welfare, e-.- the environment, the information specified in items G4.a., G4.b.,
and C4.c., ,\>ove, shall be provided not later than 24 hours from the time
the permittee becomes aware of the circumstances. If this information is
provided e-v.ily, a written submission covering these points shall be pro-
vided vk'v..-. rive days of the time the permittee becomes aware of the cir-
cumstance.-, unless the department waives or extends this requirement on a
case-by-c.;-e
D-76
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Page 5 of 6
Permit Xo.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
G5. The intentional bypass of wastes from all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is pro-
hibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction
or maintenance-related activities essential to meet the requirements
of the permit and authorized by administrative order;
b. There arc no feasible alternatives to bypass, such as the use of aux-
iliary treatment facilities, retention of untreated wastes, maintenance
during normal periods of equipment down time, or temporary reduction or
termination of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. IVhere the permittee knows or should
r-*'.ro vrv?'."ri. ir. r-dvar.ic cf the need for a bypass, Lid." prior notificaticr.
shall be submitted for approval to the department, if possible, at least
30 days before the date of bypass (or longer if specified in the special
conditions);
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the pro-
posed bypass, the department will approve or deny the request. Approval of
a request to bypass will be by administrative order under RCW 90.48.120.
GG. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required l>y law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and condi-
tions of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
D-77
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Page 6 of 6
Permit .K,'o.
c. To inspect at reasonable times any. monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall apply for a new permit at least sixty days prior to the
time when facility expansions, production changes, or process modifications
will (1) result in new or substantially increased discharges of waste charac-
teristics or volume or a change in the nature of the discharge of pollutants ,
or (2) violate the terms and conditions of the existing permit.
G8. -A permit shall he subject to termination upon thirty days notice in writing
if the department finds:
a. That it was procured by misrepresentation of any material fact or by
lack of full disclosure in the application;
L. That there hoc b<_<=ii a. vioIaLion uf cht eruditions thereof;
c. That a material change in quantity and type of waste disposal exists.
In the event that a material change in the conditions of the state waters
Utilized creates a dangerous degree of pollution, the department may specify
additional conditions in the permits previously issued.
The director of the department is authorized to issue permits for waste
disposal and specify the conditions and expiration date of such permits.
Permit modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred
or will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. must report its plans, or such information, to
the department so that a decision can be made on whether action to modify or
revoke and reissue a permit will be required. The department may then require
submission of a new application. Submission of such application does not
relieve the discharger of the duty to comply with the existing permit until
it is modified or reissued.
G10. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with
WAC 173-240. Facilities shall be constructed and operated in accordance with
the ,'inp roved plans.
Gil. N'othing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-78
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Page 1 of 7
Permit Number WA-002940-8
Issuance Date:
Expiration Date:"
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Act as amended
Public Law 95-217
DAHL FISH COMPANY, INC.
601 West Chestnut Street
Bellingliam, Washington 98225
Plant Location:
601 West Chestnut St.
Bellinghaan, WA
Industry- Type
Seafood Processing
Waterway Segment N'umber:
01-01-02 (Process wastewater)
01-01-05 (Cooling water)
Receiving Water:
Whatcom Creek Waterway and
Bellingham Bay
Discharge Location: cooling water
Latitude: 48° 45' OS" N
longitude:122° 29' 05" W
is authorized to discharge in accordance with the special
and general conditions which follow.
, ' ^_ L
Bruce A. Cameron „•'
Assistant Director
Department of Ecology (I)
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Page 2 of 7
Permit No. _WA-002940-8
SPECIAL CONDITIONS
SI.a. EFFLUENT LIMITATIONS
During the period beginning on the date of issuance of this permit and lasting until the
expiration date of this permit, the permittee is authorized to discharge uncontaminated
cooling water to Whatcom Creek Waterway at the permitted location subject to the following
limitations:
EFFLUENT LIMITATIONS
Parameters Daily Maximum
V Flow 90 m3/d (24,OC3 gpd)
o
Temperature 30°C (85°F)
The daily maximum is defined as the greatest allowable value for any calendar day.
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Page 3 oi" 7
Permit No. WA-002940-H
SPECIAL COND TIONS
Sl.b. EFFLUENT LIMITATIONS (Process wastcwater)
During the period beginning on the date of issuance of this permit and lasting unti' the
expiration date of this permit, the permittee is authorized to discharge screened j ;ucess
wastcwater to the Belli gham Sanitary Sewer System subject to the following limitations:
EFFLUENT LIMTATIONS
Parameter Daily Average Daily Maximum
Flow 230 m3/d (60,000 gpd) 28S m3/d (75,000 gpd)
The daily average is defined as the average oi: the measured values for the operating day
obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for any calendar day.
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Page 4 of 7
Permit No. WA-002940-8
S2. OPERATION AND MAINTENANCE
a. All seafood processing wastewater and washdown water shall be
screened (not greater than 40 mesh openingsj and discharged to
the Bellingham sanitary sewer system.
b. Off loading of seafood on the dock shall be accomplished with a
minimum of waste dishcarge.
c. Contents of vessel bilges shall not be discharged into the waterway.
d. All solids to be utilized in by-products shall be stored, handled
and transported in a manner which prevents its entry or the drainage
thereof into surface waters of the state.
e. All sanitary wastes shall be discharged into the Bellingham
sanitary sewer system.
S3. SOLID WASTE DISPOSAL
a. me permittee snail hancue ana dispose of all solid waste material
in such a manner as to prevent its entry into state ground or
surface waters. All solid waste disposal shall be in accordance
with the requirements of the Bellingham Whatcom County Health District,
b. The permittee shall not permit leachate from its solid waste material
to enter state surface waters without providing all known, available
and reasonable methods of treatment, nor permit such leachate to
cause any adverse effect on state ground waters. The permittee shall
apply for a permit or permit modification as may be required for
such discharges.
D-82
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Page 5 of 7
Permit N'o. WA-002940-8
GENERAL CONDITIONS
Cl. All discharges and activities authorised by this permit shall be consistent
with the terms and conditions of this permit. The' discharge of any pollutant
more frequently than or at a level in excess of that authorized by this
permit shall constitute a violation of the. terms and conditions of this
permit.
G2. The permittee shall at ail times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall
control production and/or all discharges upon reduction, loss, failure, or
bypass of the treatment facility until the facility is restored or an
alternative method of treatment is provided. This requirement applies in
the situation where, among other things, the primary source of power of the
treatment facility is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit, the nr»rmi't'tr"? shall, at a minimum nm-\Mrir» i-h« ^'ipar'f"'n°nt
with the following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the
corrective actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant
effluent standard under Section 307 fa) of the Clean Water Act, or which
could constitute a threat to human health, welfare, or the environment,
4-0 CFR Part 122 requires that the information specified in items G4.a.,
G4.b., and G4.c., above, shall be provided not later than 24 hours from the
time the permittee becomes aware of the circumstances. If this information
is provided orally, a written submission covering these points shall be
provided within five days of the time the permittee becomes aware of the
circumstances, unless the department waives or extends this requirement on
a case-by-case basis.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
D-83
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hige 6 of 7
Permit No. WA-002940-8
G5. The intentional bypass of wastes from all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is
prohibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction or
maintenance- related activities essential to meet the requirements of
the Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, mainten-
ance during normal periods of equipment down time, or temporary reduc-
tion or termination of production;
c. The permittee submits notice of an unanticipated bypass to the depart-
ment in accordance with Condition G4. Where the permittee knows or
should have known in adv.-.nce of the need for a bypass, this prior
notification shall be submitted for approval to the department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special conditions) ;
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe pronerrv damage" means substanti?1 p'^-s^ce.1 Damage to
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the
proposed bypass, the department will approve or deny the request. Approval
of a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment -or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sa-. -'.e at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the previous
application where facility expans ions , production increases, or process
D-84
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P;ii>c 7 of 7
Permit N'o. WA-002940-8
modifications will (1) result in new or substantially increased discharges
of pollutants or a change in the nature of the discharge of pollutants, or
f2) violate the terns and conditions of the existing permit.
G3. After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or
misrepresentation of any relevant facts by the permittee in the
application or during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by
the permit;
d. Information indicating that the permitted discharge poses a threat to
human health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.15 and 122.16.
Permit modification, revocation and rcissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has
occurred or will occur which would constitute cause for modification or
revocation and rcissuance under Condition G8. or 40 CFR Part 122.IS must
report its plans, or such information, to the department so that a decision
can be made CM whether action to modify or revoke and reissue a permit will
be required. The department may then require submission of a new application,
Submission of such application does not relieve the discharger of the duty
to comply with the existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any
schedule of compliance specified in such effluent standard or prohibition)
is established under Section 307fn) of the Clean Water Act for a toxic
pollutant and that standard or prohibition is more stringent than any
"limitation upon such pollutant in the permit, the department shall institute
proceedings to modify or revoke and reissue the permit to conform to the
toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wasteivater control facilities,
detailed plans shall be submitted to the department for approval in accor-
dance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR Part 122.7, 122.60, and 122.61 are in-
corporated into this permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-85
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Page 1 of 7
Permit Number
7253
Issuance Date:
Expiration Date:"
MAR 14 1983
MAR 14 1988
STATE WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
Mt. Baker Plywood, Inc.
P.O. Box 997
Bellingham, Washington 98225
Plant Location:
2929 Roeder Avenue
Bellinghan, Washington 98225
Industry Type:
Plywood Manufacturing
Receiving Water:
Bellingham Bay via Bellingham wastewater
treatment plant
Discharge Location:
48° 43' 00" N
122° 31T 00" W
Waterway Segment Number:
01-01-03
is authorized to discharge in accordance with the special
and general conditions which follow.
.ROBERT K. McCORMICK, Regional Manager
Department of Ecology ( )
D-86
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Page 2 of 7
Permit No. 7253
SPECIAL CONDITIONS
oo
-J
SI. EFFLUENT LIMITATIONS
Upon issuance of this permit and lasting through the expiration date of this permit, the permittee
is authorized to discharge press pit oil/water subnat;mt wastewater and boiler blowdown to the
Bellingham sanitary sewer system subject to the following limitations:
Parameter
Flow
Total Oils
Total Phenolics
EFFLUENT LIMITATIONS
Daily Average
11 m3/d
(3,000 gpd)
Da: ly Maximum
15 m3/d
(4,000 gpd)
100 mjj/1
1 r.g/1
Tlie daily average is defined as the average of the measured values obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for uny calendar day.
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Page 5 of 7
Permit Xo. 7253
S2. )10NITORING AND REPORTING
Test Procedures
All sampling and analytical methods used to determine compliance with the
effluent limits specified in this permit shall, unless approved otherwise
in writing by the department, conform to the Guidelines Establishing Test
Procedures for the Analysis of Pollutants , contained in 40 CFR 136, as
puolished in the Federal Register on December 1, 1976, or the latest
revision thereof, which currently references the following publications:
1. American Public Health Association, Standard Methods for the
Examination of Water and Wastewaters.
2. .American Society for Testing and Materials, A.S.T.M. Standards,
Part 23, Water, Atmospheric Analysis.
S3. SOLID WASTE DISPOSAL
a. The permittee shpn handle and Hic-noca nf ?ii cnii/j wast? r^terial
in such a manner as to prevent its entry into state ground or
surface waters.
b. The permittee shall not permit leachate from its solid waste material
to enter state surface waters without providing all known, available
and reasonable methods of treatment, nor permit such leachate to
cause any adverse effects on state ground waters. The permittee shall
apply for a permit or permit modification as may be required for such
discharges .
S4. OPERATION AND MAINTENANCE
a. There shall be no discharge of process wastewater or cooling water
into Squalicum waterway or other surface waters of the state.
b. All plant air compressor and boiler grate cooling water shall be
recycled for reuse.
c. All glue washdown water shall be recycled for reuse as glue makeup
water.
d. All water accumulated in the press pit shall pass through a
properly sized oil/water separator.
e. All dryer scrubber water shall be recycled for reuse.
f. >xO oil, leachate from sort yard debris, bark or wood chip storage
or other contaminated water shall be discharged to waters of the state.
g. .All sanitary wastewater shall be discharged to the Bellingham
sanitary sewer system. _ 00
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Page 4 of 7
Permit No. 7253
S3. OTHER REQUIREMENTS
If a toxic effluent standard or prohibition is established pursuant to the
Federal Clean Water Act as amended, or the State Water Pollution Control
Law as amended, or local pretreatment standards established in accordance
with the Clean Water Act, for a toxic pollutant which is present in the
discharge authorized herein and such standard or prohibition is more
stringent than any limitation upon such pollutant in this permit, this
permit shall be revised or modified in accordance with the toxic effluent
standard or prohibition and the permittee shall be so notified.
D-89
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Page .5 of 7
remit N'o.
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terms and conditions of this permit. The discharge of any pollutant
-ore frequently tnan or at a level in excess of that authorized by this
permit shall constitute a violation o£ the terms and conditions of this
permit.
G2. The permittee shall at all times maintain in good working order and operate
as efficiently as possible all facilities and systems (and related appur-
tenances) for collection and treatment which are'installed or used by the
permittee for water pollution control and abatement to achieve compliance
with the terms and conditions of this permito
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of
the treatment facility until the facility is restored or an alternative
method of treatment is provided. This requirement applies in the situation
where, among other things, the primary source of power of the treatment fa-
cility is reduced, lost, or fails.
G4. If, for au/ icasuri, cue permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit, the permittee shall, at a minimira, provide the department
with the following information:
a. A description of the nature and cause of noncompliancc, including the
quantity and quality of any unauthorized waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the cor-
rective actions taken to determine if additional action should be taken.
In the case of any discharge which could constitute a threat to human health,
welfare, or the environment, the information specified in items G4.a., G4.b.,
and G4.c., above, shall be provided not later than 24 hours from the time
the permittee becomes aware of the circumstances. If this information is
provided orally, u written submission covering these points shall be pro-
vided within five days of the time the permittee becomes aware of the cir-
cumstances, unless the department waives or extends this requirement on a
case-by-case basis.
D-90
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Page 6 of 7
Permit No.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
G5. The intentional bypass of wastes from all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is pro-
hibited unless the following four conditions are met:
a. Bypass is: (1] unavoidable to prevent loss of life, personal injury,
or severe property damage; or (2) necessary to perform construction
or maintenance-related activities essential to meet the requirements
of the permit and authorized by administrative order;
b. There arc no feasible alternatives to bypass, such as the use of aux-
iliary treatment facilities, retention of untreated wastes, maintenance
during normal periods of equipment down time, or temporary reduction or
termination of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. IVhere the permittee knows or should
have known in advance of the need for a bvoass. this nrior notification
shall be submitted for approval to the department, if possible, at least
30 days before the date of bypass (or longer if specified in the special
conditions);
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the pro-
posed bypass, the department will approve or deny the request. Approval of
a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and condi-
tions of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
D-91
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Page 7 of 7
Permit No.
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
i. ~o inspect at reasonable tines anv collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall apply for a new permit at least sixty days prior to the
time when facility expansions, production changes, or process modifications
will (1) result in new or substantially increased discharges of waste charac-
teristics or volume or a change in the nature of the discharge of pollutants,
or (2) violate the terms and conditions of the existing permit.
G5. A permit shall be subject to termination upon thirty days notice in writing
if the department finds:
a. That it was procured by misrepresentation of any material fact or by
lack of full disclosure in the application;
b. That there has been a violation of the conditions thereof:
c. That a material change in quantity and type of waste disposal exists.
In the event that a material change in the conditions of the state waters
Utilized creates a dangerous degree of pollution, the department may specify
additional conditions in the permits previously issued.
The director of the department is authorized to issue permits for waste
disposal and specify the conditions and expiration date of such permits.
Permit modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred
or will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. must report its plans, or such information, to
the department so that a decision can be made on whether action to modify or
revoke and reissue a permit will be required. The department may then require
submission of a new application. Submission of such application does not
relieve the discharger of the duty to comply with the existing permit until
it is modified or reissued.
G10. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with
WAC 173-240. Facilities shall be constructed and operated in accordance with
the approved plans.
Cll. Nothing in this permit shall be construed as excusing the permittee from
ccrraliance with any applicable federal, state, cr local statutes, ordinances,
or regulations.
D-92
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—^ 1 of li
Tero.it Xo. WA-OQ308 1-3 ' I)
j Uf.' 20 •: • *
Issuance Date: ^ ' "' '""''
„ fl HP n n
expiration Date: otJi' ~ u i-
-ATIO::AL POLLITA:.'! DISCHARGE ZLIMIMA: ":; SYSTEM
WASTE DISCHARGE PERMIT
State of V.'ashingtor.
DEPARTMENT OF ECOLOGY
Olyrapia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Ace as amended
Public Law 95-217
OESER COMPANY
-P.O. Box 156
Bellingham, Washington 98225
Plant Location;
730 Marine Drive
Lellinghaa, '-."ashingcon
Industry T\-oe :
Receiving Water:
Little Squalicum Drainage and
Bellingham Bay
Discharge Location:
•.cod rra
Waterway Seement Number:
01-01-02
Laticuas:
Longitude: 122° 30' 52"W
is authorized to discharge in accordance with the^special
and general conditions which follow.
' Donald P. Di-.bois
Assistant Director
Department of Ecology (I)
D-93
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-ige 2 of 11
Permit "o . '..'A-00305 l-3( I)
SPECIAL CONDITIONS
5la. INTERIM EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Process wascewacer)
During che period beginning on the issuance date of this permit and lasting
through June 30, 1986, the permittee is authorized to discharge process waste-
water to the Bellingham sanitary sewer system subject to the following
limitations and monitoring requirements:
EFFLUENT LIMITATIONS MONITORING REQUIREMENTS
Minimum
Parameter Daily Maximum Frequency Sample Type
Total oil 100 mg/1 Quarterly Grab
Process wastewater is defined as all drainage and condensate from the treating
cylinder, all drippage and bearing cooling water discharges from the pump and
valves associated with providing treating fluid to the treating cylinder or
treating tanks, all sump drainage from the treating tanks and any other oil or
fil/water m-ivrii-ro r-onrs-frn'njr ngnrarhi orophenol, creosot* o^ ^tbe^ wood
preservative substances.
The daily maximum is defined as the greatest allowable value for any calendar
day consisting of the average of at least three grab samples taken at equal
intervals during the period of discharge with the first sample taken during the
first hour of discharge.
Sib. FINAL EFFLUENT LIMITATIONS (Process wastewater)
Beginning on July 1, 1986 and lasting through the expiration date of this
permit, the permittee is authorized to discharge all process wastewater r-.s
defined in Sla. above to an evaporation system. Beginning on July 1, 1986,
there shall be no discharge of fluids containing wood preservative substances
into state grov-d, or surface waters, or the City of Bellingham sanitary sewer
system.
D-94
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-age 3 of 11
Perm] c No. '.•A-C0308 1-j. r
::-. FT7i/;r.:7 LIMITATIONS AND MONITORING REQUIREMENTS (steam condensate and
Zeeinning on the issuance dace of this permit and lasting through the expiration
date cf this permit, the permittee is authorized to discharge treated stsa:
icnaer.cacs ana slowdown .to cr.e City of Eellir.shsm sanitary sewer system snonecc
to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS MONITORING REQUIREMENTS
Minimum
Parameter Daily Average Daily Maximum Freou' '.cy Sample Tvse
Total Oils LO mg/1 15 rag/I Quarterly Grab
No visible sheen N'o visible sheen
Pentachlorophenol None detected Quarterly Grab
The daily average is defined as the average of the measured values obtained over
a calendar year's time.
The daily maximum is defined as the greatest allowable value for any calendar
day consisting of the average of at least three grab samples taken at equal
intervals durinz the period of discharae with the first sample taken during the
first hour of discharge. None detected is defined for the purposes of and for
the duration of this permit at less than 0.1 ug/1.
S3. EFFLUENT LIMITATIONS (Plant runoff)
Beginning on the issuance date of this permit and lasting through the expiration
date of this permit, the permittee is authorized to discharge treated nar.u-
facturing plant runoff to the City of Bellingham stormwater system subject to
the following limitations:
Parameters Daily Average Daily Maximum
Total oil 10 mg/1 15 mg/1
No visible sheen No visible sheen
Pentachlorophenol None detected
Manufacturing plant runoff is defined as all drainage oil and oil/water mixtures
originating within the pemittee's manufacturing and storage area exclusive of
the areas described in conditions SI and S2 above.
None detected-is defined for the purposes of and for the duration of this permit
as less than 0.1 ug/1.
The daily average is defined as the average of the measured values obtained over
a calendar year's time.
The daily r.axicum is defined as the greatest allowable value for any calendar
day.
D-95
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4 of 11
Permit Mo. WA-003081-3CD
:i. SCHEDULE OF COMPLIANCE
a. The permittee shall achieve compliance with the effluent limitations
specified for discharge in accordance with the following schedule.:
1. On or before January I, 1985, the permittee shall submit to Che
Department of Ecology for review and approval an engineering report
which proposes steps necessary for the complete elimination of pen-
tachlorophenol, or other wood preservative discharges into state
ground or surface waters including the City of Bellingham sanitary or
stormwater sewer syt::-i&s. The report shall include a geohydrological
examination of the extent of contamination of the ground by pen-
tachlorophenol or other wood preservatives due to past practices. The
report shall propose any measures necessary to contain, control,
remove or dispose of such soil to prevent migration of such pre-
servatives into state ground or surface waters.
2. On or before N'ovem: r 1, 1984 the permittee shall submit to the
Department of Ecology for review and approval a Best Management
Practices Plan. The plan shall address the items listed in Condition
S6 below.
3. On or before November 1, 1985 the Best Management Practices Plan as
approved by the Departmeiiw uf Ecology shall be ^osi^iuwci^ iiu^itii- led.
b. The permittee is expected to meet this compliance schedule. No later than
14 calendar days following a date identified above, the permittee shall
subn-i to the appropriate regional office of the department a notice of
compliance or noncompliance with the specifications required in the
schedule.
S5. MONITORING AND REPORTING
The permittee shall monitor the operations and efficiency of all treatment and
control facilities and the quantity and quality of the waste discharged. A
record of all such data shall be maintained. The permittee shall monitor the
parameters as specified in Conditions SI and S2 of this permit.
a. Reporting
Monitoring results obtained during the previous month shall be summarized
and reported on a form provided or approved by the department, to be
submitted no later than the 15th day of the month following the completed
reporting period. The report shall be sent to the Northwest Regional
Office of the Department of Ecology, 4350 - 150th Avenue N.E., Redmond,
Washington 98052. Monitoring shall be started on the issuance date of
this permit and the first report is due 45 days thereafter.
D-96
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.Jage 5 of I]
Permit No. WA-003Q8I
ND RH?ORTi:,T, .Tontinued)
.accrcs Retention
The permittee shall recain for a minimum of 3 years all recc-ds of
r.onitoring activities ar.d results , including all reports of racordir. r-^-i
continuous -.onxcorir.§ instrumentation. This period of retention s--. -.11 be
extended during che course of any unresolved litigation regarding che
discharge of pollutants by ehe permittee or when requested by the director.
c. Recording of Results
For each measurement or sample taken, the permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the analyses;
(4) the analytical techniques or methods used; and (5) the results of all
analyses.
d. Representative Sam
Samples and measurements r.ken to meet the requirements of this condition
shall be representative of the volume and nature of the monitored discharge
including representative sampling of any unusual discharge or discharge
conditions affecting effluent quality.
Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in writing
by the Department, conform to the Guidelines Establishing Test Procedures
for the Analysis of Pollutants, contained in 40 CFR Part 136, as published
in the Federal Register on December 1, 1976, or the latest revision
thereof, which .references the following publications:
1. American Public Health Association,
Examination of Water and Vastewaters.
Standard Methods for
2. American Society for Testing and Materials, A.S.T.M. Standards, Part
31, Water, Atmospheric Analysis.
3. Envir- cental Protection Agency, Methods for Chemical Analysis of_
Water and Wastes.
The laboratory providing analytical services shall provide suitable
evidence that it's procedures for pentachlorophenol analysis conform to the
best current practice as determined by the Federal Environmental Protection
Agency and that the level of precision achieved can reliably detect the
value specified in Condition S2 and S3 above.
The department nay establish specific monitoring requirements' beyond those
identified in this permit by permit modification or administrative order.
D-97
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Sage 6 of 11
Permit N'o. WA-003081-3 (I)
36. BEST !'.AN'AGEMENT PRACTICES PLAN
a. The Best tlanagement Practices Plan mentioned in Condition S4 shall be
prepared in accordance with the requirements of title 40 Code of Federal
Regulations, part 112, part 125, subpart K, and part 151 (as proposed
August 24, 1978). This plan shall establish specific objectives for the
containment, control and cleanup c" oil, toxic or hazardous material
discharges due to spillage, leaks, pi " site runoff, solid waste handling,
or other events which may cause such .: ischarges. The plan shall address as
a minimum the following areas:
1. Statement of policy
2. Spill control committee
3. Material inventory and storage and handling areas
4. Material compatibility
5. In-plant transfer areas
6. Loading and unloading areas
7. Potential of each component for release due to:
a. equipment failure
b. improper operation
c. weather events
8. Where experience indicates a reasonable potential for release from a
component, predict:
a. direction
b. rate of flow
c. total quantity
d. methods of containment, recovery and cleanup
9. Plant site runoff
10. Waste solids and liquids storage, handling and disposal
11. Employee training
12. Reporting and notification procedures
13. Inspections including the periodic examination of the structural
integrity of material storage and transfer facilities
14. Preventative maintenance
15. Housekeeping
16. Security
b. The plan may include the Solid Waste Plan as required in Condition SS and
any updated Spill Prevention Control and Counter-measure Plan.
c. Any proposed modifications to the plan shall be submitted to the Department
of Ecology for review and approval.
D-98
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Page 7 of 11
Perrr.it No. WA-00308I-3(T)
;?E?_\7 :•:•:•: AMD MAINTENANCE
Aftar July 1, 1986 chare shall be no discharge of process wastewater co
scate ground or surface waters.
July 1, .936 ail process wascewacar snaxx oe recycled for reuse or
evaporated.
c. Consistent with che specification of the product, the pretreatment and
treatment cycles in the treating cylinder shall be operated to minimize
drippage from finished stock.
d. Drippage from finished stock which is unavoidable shall drain into che
process wascewater treatment system.
e. Oil/water separators and yard traps used for oil recovery shall have solids
and oil removed at frequent enough intervals and oil sorbent material
replaced as necessary co msec che effluent limits specified in Conditions
SI, S2, and S3.
f. All spills of oil, coxic material or other substances which result in
noncompliance or rcay result in noncompliance with the terms of this permit
shall be reported immediately to the Department of Ecology in accordance
with Condition GA.
g. The use of oil dispersant chemicals in wastewater discharges is prohibited
except when explicitly approved by the Department of Ecology.
D-99
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r'age 8 of 11
Permit No. WA-003081-3U)
S8. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material in such
a manner as to prevent its entry into state ground or surface waters.
b. The permittee shall not permit leachate from its solid waste material to
enter state surface waters without providing all known, available and
reasonable methods of treatment, nor permit such leachate to cause any
adverse effect on state ground waters. The permittee shall apply for a
permit or permit modification as may be required for such discharges.
c. By November 1, 1984, the permittee shall submit to the department a plan
for the handling and disposal of all solid waste material generated at the
plan", site. All such plans shall be reviewed and approved by the depart-
ment to insure compliance with provisions a. and b. above. The permittee
shall comply with the plan as approved by the department. This plan may be
included in the Best Management Practices Plan as required in Condition S4
and described in Condition S6.
d. Accumulated waste solids in the retort, sludges in the treating fluid
tanks, evaporation units, oil/water separators, spent sorbents and any
other waste solids containing pentachlorophenol or other toxic substances
shall be stored, handled and disposed of in accordance with the State
Bazaraous wasce Disposal Act (chapter 70.105 Revised Code of Washington)
and the State Dangerous Waste Regulations (chapter 173-303 Washington
Administrative Code).
e. Any deviation from or addition to the solid waste handling plan as approved
shall first be submitted to the department for review and approval.
S9. OTHER REQUIREMENTS
a. Sanitary wastes shall be discharged to the municipal sanitary sewer system.
b. Kiln condensate, if present, shall be discharged to the municipal sanitary
sewer system.
c. This permit shall be modified to comply with any applicable effluent
limitations promulgated after the issuance of this permit by state or
federal law to control oil or toxic discharges.
D-100
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Eage 9 of 11
Permit No. WA-G0308t-3(l)
GENERAL CONTDITIC::S
Gl. All discharges and activities authorized by this permit shall be consistent with
:he terms and conditions of this permit. The discharge of any pollutant core
frequently than or at a level in excess of that authorized by this permit shall
:enscnuta a violation .:: che cerms ana conaicions of chis permit.
G2. The permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failur-", or bypass of the
treatment facility until the facility is restored or an al raative method of
treatment is provided. This requirement applies in the sitc^tion where, azong
other things, the primary source of power of the treatment facility is redu -d,
lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified in
the permit, the permittee shall, at a minimum, provide the department with the
following information:
.a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
b. The period of noncompliance, including exact dates and times and/or the
anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence of
the noncompliance.
In addition, the permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps to minimize
any adverse impacts to waters of the state and correct the problem. The
permittee shall notify the department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the corrective
actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant effluent
standard under Section 307 (a) of the Clean Water Act, or which could constitute
a threat to human health, welfare, or the environment, 40 CFR Part 122 requires
that the information specified in items G4.a., G4.b., and G4.c., above, shall be
provided not later than 24 hours from the time the permittee becomes aware of
the circumstances. If this information is provided orally, a written submission
covering these points shall be provided vithin five days of the time the
permittee becomes aware of the circumstances, unless the department waives or
extends this requirement of a case-by-case basis.
Compliance with these requirements does not relieve the permittee, from
responsibility to maintain continuous compliance with the conditions of this
permit or the resulting liability for failure to comply.
D-101
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.'age 10 of 11
Permit No. U'A-003081-3 (I)
(75. The intentional bypass of wastes from all or any portion of a treatment works to
the extent that permit effluent limitations cannot be met is prohibited unless
the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (2) necessary to perform construction or
maintenance-related .-"-civities essential to meet the requirements of the
Clean Water Act and :thorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, maintenance during
normal periods of equipment down time, or temporary reduction or termina-
tion of production;
c. The permittee submits notice of an unanticipated bypass to the department
in accordance with Condition G4. Where the permittee knows or should have
known in advance of the need for a bypass, this prior notification shall be
submitted for approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the special
condition);
d. The bypass is allowed undf conditions determined to be necessary by the
department to mi:.i.=ize any adverse effects. The public shall be notified
and given an ?7--rf?:nir7 to comme-t or. byptisr: ir.?.idcr.tc cf cignifleant
duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property, damage
to the treatment facilities which would cause them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not
nean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the proposed
bypass, the department will approve or deny the request. Approval of a request
to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department, upon
the presentation of credentials and such other documents as may be required by
law:
a. To enter upon the permittee's premises where a discharge source is located
or where any records must be kept under the terms and conditions of the
permit;
b. To have access to and copy at reasonable times any records that must be
kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method required
in the permit;
d. To inspect at reasonable times any collection, treatment, pollution manage-
ment, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
D-102
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Page LI of 11
Permit: No. U'A-003081-3(1)
G7. The permittee shall submit a new application or supplement Co che previous
application where facility expansions, production increases, or process
-odifications will (1) result in new or substantially increased discharges of
pollutants or a change in the nature of che discharge of pollutants, or (2)
violate che carss and concitions of che existing permit.
G3. After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or mis-
representation of any relevant facts by the permittee in the application or
during the permit issuance process;
c. A change in any condition that fequirss either a temporary or a permanent
reduction or elimination of any discharge controlled by the permit;
d. Information indicating that che permitted discharge poses a threat to human
health or welfare;
e. A change in ownership or control of the source; or
t. Other cause listed in 40 CFR Part 122.62 and 122.63.
Permit modification, revocation and reissuance, or termination may be initiated
by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred or
will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. or 40 CFR Part 122.62 must report its plans, or
such information, to the department so that a decision can be made on whether
action to modify or revoke and reissue a permit will be required. The depart-
ment =ay then require submission of a new application. Submission of such
application does not relieve the discharger of the duty to comply with Che
existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is established
under Section 307 (a) of the Clean Water Act for a toxic pollutant and that
standard or prohibition is more stringent than any limitation upon such pol-
lutant in the permit, the department shall institute proceedings to modify or
revoke and reissue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted co the department for approval in accordance with WAC
173-240. Facilities shall be constructed and operated in accordance with the
approved plans.
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
G13. N'othir.2 in this permit shall be construed as excusing che oerreittee from compli-
ance -,/i.th any applicable federal, state, or local statues, ordinances, or
regulations. D-103
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Page 1 of .. i
Permit No. l,TA-OQ3080-5
Issuance Date: ^oiii,'„•
Expiration Date: JUiN'2 0
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT , -
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and . _ " ;
The Clean Water Act as amended
Public Law 95-217
rft
BROOKS MANUFACTURING CO.
Brooks Lumber Division
P.O. Box 7
Bellingham, Washington 98227
Plant Location:
Iowa and Pacific
Eellingham, Washington
Industry' Type;
Wood Preserving
Waterway Segment Number:
01-01-02
Receiving Water:
Whatcora Creek Drainage and
Bellingham Bay
Discharge L'. ation;
Latitude: 48° 45v 28"
Longitude: 122° 27' 23"
is authorized to discharge in accordance with/die special
and general conditions which follow.
Donald P. Dubois
Assistant Director
Department of Ecology (I)
D-104
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Page 2 of ]1
Permit No. WA-003080-5
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS (Process wastewater)
Beginning on the issuance date of this permit and lasting through the date of
expiration, the permittee is authorized to discharge all process wastewater to a
spray evaporation system. Process wastewater is defined as all drainage and
condensate from the treating cylinder, all drippage from the pumps and valves
associated with providing treating fluid to the treating cylinder, all drippage
from the concrete pad in front of the treating cylinder and any other oil or
oil/water mixture containing pentachlorophenol or other wood preservative
substances.
52. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Treating plant runoff)
Beginning on the issuance date of this permit and lasting through the expiration
date of this permit, the permittee is authorized to discharge treated treating
plant runoff to the City of Bellingham sanitary system subject to the following
limitations and monitoring requirements.
EFFLUENT LIMITATIONS MONITORING .REQUIREMENTS
Minimum
Parameters Daily Maximum Frequency Sample Type
Total oil 100 rag/1 Quarterly Grab
Pentachlorophenol None detected Quarterly Grab
Treating plant storm water is defined as all drainage and oil and oil/water
mixtures originating within the bermed treating plant area proper exclusive of
process wastewater as defined in condition SI above.
Daily average is defined as the average of the measured values obtained over a
calendar year's time.
Daily maximum is defined as the greatest allowable value for any calendar day
consisting of the average of at least three grab samples taken at equal intervals
during the period of discharge with the first sample taken during the first hour•
of discharge. None detected is defined for the purposes of and for the duration
of this permit as less than 0.1 ug/1
D-105
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Page 3 of LI
Permit No. VA-QG3030-5
SPECIAL CONDITIONS
53. I?FLUINT LIMITATIONS (Manufacturing plane runoff)
Beginning on che issuance dace of this permit and lasting cnrougn the expiration
date of this pernit, the permittee is authorized to discharge Created
manufacturing plant runoff to the City of Bellingham stormwater system subject to
the following limitations.
EFFLUENT LIMITATIONS
Parameters Daily Average Daily Maximum
Total oil 10 mg/1 15 mg/1
Xo visible sheen No visible sheen
Pentachlorophenol None detected
Manufacturing plant runoff is defined as all drainage oil and oil/water mixtures
originating within the permittee's manufacturing and storage area exclusive of
the areas described in conditions SI and S2 above,
None detected is defined for the purposes of and for the duration of this permit
as less than 0.1 pg/1.
Daily average is defined as the average of the measured values obtained over a
calendar year's time.
Daily maximum is defined as the greatest allowable value for any calendar day. ^j/
' '"
S4. SCHEDULE OF COMPLIANCE '_..•'
. - - , , - , .: J
'"'LA
The permittee shall achieve compliance with the effluent limitations
specified for discharge in accordance with the following schedule:
1. On or before November 1, 1984 the permittee shall submit to the
Department of Ecology for review and approval a Best Management
Practices Plan. The plan shall address the items listed in condition
S6 below.
2. On or before November 1, 1985 the Best Management Practices Plan as
approved by the Department of Ecology shall be completely implemented.
The permittee is expected to meet this compliance schedule. No later than
14 calendar days following a date identified above, the permittee shall
submit to the appropriate regional office of the department a notice of
compliance or noncompliance with the specifications required in the
schedule. . , .- -
D-106
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Page 4 of 11
Permit No. WA-003080-5
S5. MONITORING AND REPORTING
The permittee shall monitor the operations and efficiency of all treatment and
control facilities and the quantity and quality of the waste discharged. A
record of all such data shall be maintained. The permittee shall monitor the
parameters as specified in Condition S2 of this permit.
'-' _ ' S~ %<-{- f~
a. Reporting ~ < -^ "-
Monitoring results obtained during the previous three months shall be
summarized and reported on a form provided or approved by the department, to
be submitted no later than the 15th day of the month following the completed
reporting period. The report shall be sent to the Northwest Regional Office
of the Department of Ecology, 4350 150th Avenue N.E., Redmond, Washington
98052. Monitoring shall be started on the issuance date of this permit and
the first report is due three and one half months thereafter.
b. Records Retention
The permittee shall retain for a minimum of 3 years all records of
monitoring activities and results, including all reports of recordings from
continuous monitoring instrumentation. This period of retention shall be
extended during the course of any unresolved litigation rer- ding the
discharge of pollutants by the permittee or when requested by the director.
c. Recording of Results
For each measurement or sample taken, the permittee shall record the
following information: (1) the date, exact place, and time of sampling; (2)
the dates the analyses were performed; (3) who - >rformed the analyses; (4)
the analytical techniques or methods used; and (5) the resu -3 of all
analyses.
D-107
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Page 5 of IL
Pernit Mo. WA-COSOSQ-S
MONITORING AND REPORTING
e. Test Procedures
All sampling and analytical inechods used to meet the monitorine require-
ments specifiea in this permit snail, ur.iess approved ocnervise in writir.g
by the Department, conform to the Guidelines Establishing Test Procedures
for ti Analysis of Pollutants, contained in 40 CFR Part 136, as published,
In~the~vaderal Register on December 1, 1976, or the latest revision thereof,
which references the following publications:
1. American Public Health Association, Standard Methods for the
Examination of_ Water and Wastewaters.
2. American Society for Testing and Materials, A.S.T.M. Standards,
Part 31, Water, Atmospheric Analysis.
3. Environmental Protection Agency, Methods for Chemical Analysis
£f_ Water and Wastes.
The laboratory providing analytical services shall provide suitable evidence
that it's procedures for pentachlorophenol analysis conform to the best
current practice as determined by the Federal Evniromental Protection Agency
and that the level of precision achieved can reliably detect the value
specified in condition S2 above.
f. The department .".ay establish specific monitoring requirements beyond those
identified in t'.is permit by permit modification or adminstrative order.
D-108
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Page 6 of ii
Permit No. l.'A-003080-5
S6. BEST MANAGEMENT PRACTICES PLAN
a. The Best Management Practices Plan mentioned in Condition S4 shall be
prepared in accordance with the requirements of Title 40 Code of Federal
Regulations, part 112, part 125, subpart K, and part 151 (as proposed August
24, 1978). This plan shall establish specific objectives for the
containment, control and cleanup of oil, toxic or hazardous material
discharges due to spillage, leaks, plant site runoff, solid waste handling,
or other ev. .its which may cause such discharges. The plan shall address as
a minimum the following areas:
1. Statement of policy
2. Spill control committee
3. Material inventory, and storage and handling areas
4. Material compatibility
5. In plant transfer areas
6. Loading and unloading areas
7. Potential of each component for release due to:
a. equipment failure
b. improper operation
c. weather events
8. Where experience indicates a reasonable potential for release frou. a
component, predict:
a. direction
b. rate of flow
c. total quantity
d. methods of containment, recovery and cleanup
9. Plant site runoff
10. Waste solids and liquids storage, handling and disposal
11. Employee training
12. Reporting and notification procedures
13. Inspections including the periodic examination of tne structural
integrity of material storage and transfer facilities
14. Preventative maintenance
15. Housekeeping
16. Security
b. The plan may include the Solid Waste Plan as required in condition S8 and
any updated Spill Prevention Control and Countermeasure Plan.
c. Any proposed modifications to the plan shall be submitted to the Department
of Ecology for review and approval.
D-109
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Page 7 ot
Permit I'o. '..'A-003080-5
CPERATICM AND MAINTLNANCE
a. ihere shall be no discharge of process wastewater to state ground or surface
waters.
b. All process wastewater shall be recycled for reuse or evaporated.
.c. Consistent with the specification of the product, the pretreatnent and
treatment cycles in the treating cyclinder shall be operated to minimize
drippage from finished stock.
d. Drippage from finished stock which is unavoidable shall drain into the
process wastewater treatment system.
e. Oil/water separators and yard traps used for oil recovery shall have solids
and oil removed at frequent enough intervals and oil sorbent material
replaced as necessary to meet the effluent limits specified in conditions
SI, S2 and S3.
f. All spills of oil, toxic material or ether substances which result in
noncompliance or may result in noncoi?.pliance with the terms of this permit
shall be reported immediately to the Department of Ecology in accordance
with condition G4.
g. The use of oil dispersant chemicals in wastewater discharges is prohibited
except when explicitly approved by the Department of Ecology.
,- v. ^ - //- l-W ^W
S8. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material in such a
manner as to prevent its entry into state ground or surface waters.
b. The permittee shall not permit leachate from its solid waste material to
enter state surface waters without providing all known, available and
reasonable, methods of treatment, nor permit such leachate to cause any
adverse effect on state ground waters. The permittee shall apply for a
permit or permit modification as may be required for such discharges.
c. By November 1, 1984, the permittee shall submit to the department a plan for
the handling and disposal of all solid waste material generated at the plant
site. All such plans shall be reviewed and approved by the department to
insure compliance with provisions a. and b. above. The permittee shall
comply with the plan as approved by the department. This plan may be
included in the Best Management Practices Plan as required in Condition S4
and described in Condtion S6.
D-110
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Page 8 of Ll
Permit No. WA-OW080-5
S8. SOLID WASTE DISPOSAL (Continued)
d. Accumulated waste solids in the retort, sludges in the treating fluid tanks,
evaporation units, oil/water separators, spent sorbents and any other waste
solids containing pentachlorophenol or other toxic substances shall be
stored, handled and disposed of in accordance with the State Hazardous Waste
Disposal Act (Chapter 70.105 Revised Code of Washington) and the State
Dangerous Waste Regulations (Chapter 173-303 Washington Administrative
Code).
e. Any deviation from or addition to the solid waste handli j plan as
approved shall first be submitted to the department for review and
approval.
S9. OTHER REQUIREMENTS
a. Sanitary wastes shall be discharged to the municipal sanitary sewer system.
b. Kiln condensate shall be discharged to the municipal sanitary sewer system.
c. Boiler blowdown shall be discharged to the municipal sanitary sewer system.
d. This permit shall be modified to comply with any applicable effluent
limitation promulgated after the issuance of this permit by state or federal
law to control oil or toxic discharges.
D-lll
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Page 9 of 11
Permit No. WA-003080-5
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent with
the terns and conditions of this permit. The discharge of any pollutant r.ore
frequently than or at a level in excess of that authorized by this Demit shal1
constitute a violation of the terms and conditions of this permit.
G2. The permittee shall at all times properly operate and maintain all facilities ar.d
systems of collection, treatment and control (and related appurtenances) which
are installed or used by the permittee to achieve compliance with conditions of
this permit.
G3. The permittee, in order to maintain compliance with its permit, shall control
production and/or all discharges upon reduction, loss, failure, or bypass of the
treatment facility until the facility is restored or an alternative method of
treatment is provided. This requirement applies in the situation where, among
other things, the primary source of power of the treatment facility is'reduced,
lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified in the
permit, the permittee shall, at a minimum, provide the department with the
following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized water discharges;
b. The period of noncompliance, including exact dates and times and/or the
anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence of
the noncompliance.
In addition, the permittee shall take immediate action to stop, contain, and
clean up any unauthorized discharges and take all reasonable steps to minimize
any adverse impacts to waters of the state and correct the problem. The
permittee shall notify the department immediately by telephone so that an
investigation can be made to evaluate any resulting impacts and the corrective
actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant effluent
standard under Section 307 (a) of the Clean Water Act, or which could constitute
a threat to human health, welfare, or the environment, 40 CFR Part 122 requires
that the information specified in items G4.a., G4.b., and G4.c., above, shall be
provided not later than 24 hours from the time the permittee becomes aware of the
circumstances. If this information is provided orally, a written submission
covering these points shall be provided within five days of the time the
permittee becomes aware of the circumstances, unless the department waives or
extends this requirement of a case-by-case basis.
Compliance with these requirements does, not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of this
permit or the resulting liability for failure to comply.
D-112
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Page 10 01 .1
Permit No. WA-003080-5
G5. The intentional bypass of wastes from all or any portion of a treatment works to
the extent that permit effluent limitations cannot he met is prohibited unless
the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal injury, or
severe property damage; or (2) necessary to perform construction or
maintenance-related activities essential to meet the requirements of the
Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of auxiliary
treatment facilities, retention of untreated wastes, maintenance during
normal periods of equipment down time, or temporary reduction or termination
of production;
c. The permittee submits notice of an unanticipated bypass to the department in
accordance with Condition G4. Where the permittee knows or should have
known in advance of the need for a bypass, this prior notification shall be
submitted for approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the special condition);
d. The bypass is allowed under conditions determined to be necessary by the
department to minimize any adverse effects. The public shall be notified
and given an opportunity to comment on bypass incidents of significant
duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property, damage to
the treatment facilities which would cause them to become inoperable, or
substantial and permanent loss of natural resources which can reasonably be
expected to occur in the absence of a bypass. Severe property damage does not
mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the proposed
bypass, the department will approve or deny the request. Approval of a request
to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department, upon
the presentation of credentials and such other documents as may be required by
law:
a. To enter upon the permittee's premises where a discharge source is located
or where any records must be kept under the terms and conditions of the
permit;
b. To have access to and copy at reasonable times any records that must be kept
under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method required
in the permit;
d. To inspect at reasonable times any collection, treatment, pollution manage-
ment, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
D-113
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Page 11 OL i
Permic Xo. •.•'A-003030-5
G7. The permittee shall submit 3. new application or supplement to the previous
application where facility expansions, production increases, or process
zodifications will (1) result in new or substantially increased discharges c:
pollutants or a change in the nature of the discharge of pollutants, or (2)
violate the terms and conditions of the existing permit.
G5. After notice and opportunity for puolic hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a.. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or mis-
representation of any relevant facts by the permittee in the application or
during the permit issuance process;
c. A change in any condition that requires either a temporary or a permanent
reduction or elimination of any discharge controlled by the permit;
d. Information indicating that the permitted discharge poses a threat to human
health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part L22.62 and 122.63.
Permit modification, revocation and reissuance, . or ter> '.nation may be initiated
by 'the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has occurred or
will occur which would constitute cause for modification or revocation and
reissuance under Condition G8. or 40 CFR Part 122.62 must report its plans, or
such information, to the department so that a decision can be made on whether
action to modify or revoke and reissue a permit will be required. The department
may then require submission of a new application. Submission of such application
does not relieve the discharger of the duty to comply with the existing permit
until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any schedule
of compliance specified in such effluent standard or prohibition) is established
under Section 307 (a) of the Clean Water Act for a toxic pollutant and that
standard or prohibition is more stringent than any limitation upon such pollutant
in the permit, the department shall institute proceedings to modify or revoke and
reissue the permit to conform to the toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities, detailed
plans shall be submitted to the department for approval in accordance with WAG
L73-240. Facilities shall be constructed and operated in accordance with the
approved plans.
C-12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated into this
permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee from compli-
ance with any applicable federal, state, or local statues, ordinances, or
regulations.
D-114
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Page 1 of 8
Permit Number WA-Q00119-8 fll
Issuance Date:
Expiration Date:"
MAR 2 1983
MAR 2 1988
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 Revised Code of Washington as amended
and
The Clean Water Act as amended
Public Law 95-217
COLUMBIA CEMENT CORPORATION
P.O. BOX 37
.Bellingham, Washington 98225
Plant Location:
Marine Drive
Bellingham, WA 93225
Industry Type :
Cement Manufacturing
Waterway Segment Number:
01-01-02
Receiving Water:
Bellingham Bay
Discharge Location;
Latitude: 48°45'58"N
Longitude:122°31'24"W
is authorized to discharge in accordance with the special
and general conditions which follow.
D-115
Bruce A. Cameron /
Assistant Director ^
Department of Ecology ( )
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Page 2 of 8
Permit No. WA-000119-8
SPECIAL CONDITIONS
Sla. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the date of issuance of this permit and lasting until the expiration date
of this permit, the permittee is authorized to discharge process wastewater to Bellingham Bay at the
permitted discharge location subject to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS MONITORING REQUIREMENTS
Parameters Daily Average Daily Maximum Minimum Frequency Sample Type
Flow 300 m3/d 500 m3/d Daily Calculated
(80,000 gpd) (130,000 gpd).
Total Suspended Solids 0.005* Weekly Composite
Temperature Not to exceed 3° C rise above Weekly Grab
inlet temperature
pH Within the range 6.0 - 9.0 Weekly Grab
The daily average is defined as the average of the measured values obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for any calendar day.
A composite sample shall be comprised of four or more sub-samples characteristic of the effluent for a
calendar day.
* The permissible loading rates ;ire expressed as kilograms of pollutant per 1,000 kilograms of product
(pounds of pollutant per 1,000 Ibs. of product.)
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Page 3 of 8
Permit No. WA-000119-9
SPECIAL CONDITIONS
Sib. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the date of issuance of this permit and lasting until the expiration date
of this permit, the permittee is authorized to discharge truck wash water to Bellingham Bay at the permitted
discharge location subject to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS
Parameters
Flow
Total Suspended Solids
PH
Daily Average
6 m3/d
(1500 gpd)
Daily Maximum
23 m3/d
(6000 gpd)
Within the range 6.0 - 9.0
MONITORING REQUIREMONTS
Minimum Frequency Sample Type
Daily Calculate
Weekly
Weekly
Composite
Grab
The daily average is defined as the average of the measured values obtained over a calendar month's time.
The daily maximum is defined as the greatest allowable value for any calendar day.
A composite sample shall be comprised of four or more sub-samples characteristic of the effluent for a
calendar day.
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Page 4 of 8
Permit No. WA-000119-8
S2. MONITORING AND REPORTING
The permittee shall monitor the operation and efficiency of all treatment and
control facilities and the quantity and quality of the waste discharged. A
record of all such data shall be maintained. The permittee shall monitor the
parameters as specified in Condition Sl(aJ and Sl(b) of this permit.
a. Reporting
Monitoring results obtained during the previous three months shall be
summarized and reported on a form provided by the department, to be
submitted no later than the 15th day of the month following the
completed reporting period.
The report shall be sent to the Northwest Regional Office of the Depart-
ment of Ecology, 4350 - 150th Avenue N.E., Redmond, Washington 98052.
Monitoring shall be started on the permit issuance date and the first
report is due 3-% months later.
b. Records Retention
The permittee shall retain for a minimum of three years all records of
monitoring activities and results, including all reports of recordings
from continuous monitoring instrumentation. This period of retention
shall be extended during the course of any unresolved litigation regard-
ing the discharge of pollutants by the permittee or when requested by
the Director.
c. Recording of Results
For each measurement or sample taken, the permittee shall record the
following information: (1) the date, exact place, and time of sampling;
(2) the dates the analyses were performed; (3) who performed the
analyses; (4) the analytical techniques or methods used; and (5) the
results of all analyses.
d. Representative Sampling
Samples and measurements taken to meet the requirements of this condition
shall be representative of the volume and nature of the monitored dis-
charge.
e. Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in writ-
ing by the Department, conform to the Guidelines Establishing Test
Procedures for the Analysis of Pollutants, contained in 4U UrK i-io,
as published~Th~TKe Federal Register on December 1, 1976, or the latest
revision thereof, which currently references the following publications:
D-118
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Page 5 of 3
Permit No. WA-000119-8
1. American Public Health Association, Standard Methods for the Exami-
nation of Water and Wastewaters.
2. American Society for Testing and Materials, A.S.T.M. Standards,
Part 31, Water, Atmospheric Analysis.
3. Environmental Protection Agency, Methods for Chemicals Analysis
of Water and Wastes.
S3. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material
in such a manner as to prevent its entry into state ground or
surface waters.
b. The permittee shall not permit leachate from its solid waste
material to enter state surface waters without providing all
known, available and reasonable methods of treatment, nor
permit such leachate to cause any adverse effect on state
ground waters. The permittee shall apply for a permit or
permit modification as may be required for such discharges.
S4. OPERATION AND MAINTENANCE
a. Wash, waste process, cooling and contaminated runoff water, except
from truck wash area, shall be collected and discharged to a series
of two or more settling basins for reuse.
b. The settling basins shall be continuously maintained to provide
adequate detention time to effectively remove fines from the
wastewater.
c. No detergents shall be used in the truck washing operations.
d. Cement transfer operations and facilities shall be properly maintained
so as to prevent any discharge of cement, directly or indirectly, to
Bellingham Bay.
S5. OTHER REQUIREMENTS
a. Sanitary wastes are to be disposed of in accordance with the regulations
of the Bellinham-Whatcom Health District.
D-119
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Page 6 of 8
Permit No.
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terms and. conditions of this permit. The discharge of any pollutant
more frequently than or at a level in excess of that authorized by this
permit shall constitute a violation of the terms and conditions of this
permit.
G2. The permittee shall at all times properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall
control production and/or all discharges upon reduction, loss, failure, or
bypass of the treatment facility until the facility is restored or an
alternative method of treatment is provided. This requirement applies in
the situation where, among other things, the primary source of power of the
treatment facility is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit, the permittee shall, at a minimum, provide the department
with the following information:
a. A description of the nature and cause of noncompliance, including the
quantity and quality of any unauthorized'waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take immediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the
corrective actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant
effluent standard under Section 307 (a) of the Clean Water Act, or which
could constitute a threat to human health, welfare, or the environment,
40 CFR Part 122 requires that the information specified in items G4.a.,
G4.b., and G4.c., above, shall be provided not later than 24 hours from the
time the permittee becomes aware of the circumstances. If this information
is provided orally, a written submission covering these points shall be
provided within five days of the time the permittee becomes aware of the
circumstances, unless the department waives or extends this requirement on
a case-by-case basis.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
D-120
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Page " of 8
Permit No.
G5. The intentional bypass of wastes from all or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is
prohibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss oi: life, personal injury,
or severe property damage; or (2) necessary to perform construction or
maintenance-related activities essential to meet the requirements of
the Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, such as the use of
auxiliary treatment facilities, retention of untreated wastes, mainten-
ance during normal periods of equipment down time, or temporary reduc-
tion or termination of production;
c. The permittee submits notice of an unanticipated bypass to the depart-
ment in accordance with Condition G4. Where the permittee knows or
should have known in advance of the need for a bypass, this prior
notification shall be submitted for approval to the department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special conditions);
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
"Severe property damage" means substantial physical damage to property,
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the
proposed bypass, the department will approve or deny the request. Approval
of a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms ind conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
D-121
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Pnjjc 8 of 8
Permit No.
modifications will (1) result in new or substantially increased discharges
of pollutants or a change in the nature of the discharge of pollutants, or
(2] violate the terms and conditions of the existing permit.
After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked during its term for cause as follows:
a. Violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or
misrepresentation of any relevant facts by the permittee in the
application or during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by
the permit;
d. Information indicating that the permitted discharge poses a threat to
human health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.15 and 122.16.
Permit modification, revocation and rcissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has
occurred or will occur which would constitute cause for modification or
revocation and rcissuance under Condition G8. or 40 CFR Part 122.15 must
report its plans, or such information, to the department so that a decision
can be made on whether action to modify or revoke and reissue a permit will
be required. The department may then require submission of a new application.
Submission of such application does not relieve the discharger of the duty
to comply with the existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including any
schedule of compliance specified in such effluent standard or prohibition)
is established under Section 307(a) of the Clean Water Act for a toxic
pollutant and that standard or prohibition is more stringent than any
limitation upon such pollutant in the permit, the department shall institute
proceedings to modify or revoke and reissue the permit to conform to the
toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities,
detailed plans shall be submitted to the department for approval in accor-
dance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR Part 122.7, 122.60, and 122.61 are in-
corporated into this permit by reference.
Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
D-122
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Page 1 of 8
Permit . WA-003041-4
Issuance Date: JUN 2 b 1987
Expiration Date:
JUN 2 6 1992
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLCGY
Olympia, Washington 98504
In Coroliance with the Provisions of
The State of Washington Water Pollution Control Law
Chapter 90.48 Revised Code of Washington
and
The Federal Water Pollution Control Act
(The Clean Water Act)
Title 33 United States Code, Section 1251 et. seq.
PUBLIC UTILITY DISTRICT NO. 1
OF
WHATCCM COUNTY
215 Mason Building
Bellingham, Washington 98225
Plant Location;
Ferndale Road
Ferndale, Washington
Industry Tvce:
Water Treatment Plant
Receivino Water:
Nooksack River
Discharge Location:
Latitude: 48° 50' 20"N
Longitude: 122° 35' 30"W
Waterway Segment Number;
01-01-04
is authorized to discharge ir. accordance with the special and general conditions
which follow.
D-123
Nancy Ellison, Regional Manager
N'orthwestl Regional Office
I*=partment of Ecciogy
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Page 2 or 8
Permit No. WA-003041-4
SPECIAL CCNDITICNS
SI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the issuance date of this permit and lasting through the ex-
piration date of this permit, the permittee is authorized to discharge
settled decant water to the Nooksack River at the discharge location
specified on page one of this permit subject to the following effluent
limitations and monitoring requirements:
EFFLUENT LIMITATIONS MONITORING REQUIREMENTS
Parameter Daily Maximum Minimum Frequency Sample Type
Flow 9000 m /d Weekly Daily Total
(2.4 MGD)
Settleable Solids 0.1 ml/1 Weekly Composite*
pH Within the range Weekly Grab
of 6.0 - 9.0
The daily maximum is defined as the greatest allowable value for any
calendar day.
* Composite sampling consists of four grab samples equally spread over
the backwash cycle. Effluent limitations are net value allowable above
that of the intake water.
32. MONITORING AND REPORTING
A. Reporting
The permittee shall monitor the parameters as specified in
Condition SI. of this permit and report the results for each
three month period. The reports shall be submitted no later
than the 15th day of the month following the completed
reporting period and shall be on forms supplied or approved by
the department and sent to the Northwest Regional Office of
the Washington State Department of Ecology, 4350 - 150th
Avenue ME, Redmond, Washington 98052.
If the permittee monitors any pollutant more frequently than
required by tinis permit sucn results shall be recorded ana
reported in accordance with tnese instructions.
D-124
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Page 3 of 8
Permit No. WA-003041-4
S2. MONITORING AND REPORTING (Cont.)
3. Records Retention
The permittee shall retain for a minimun of three years all
records of ncratormg activities and results, includina ail
reports of recordings fron continuous ncnitbrina
instnsientation. This period of retention shall he extended
during the course of any unresolved litigation regarding the
discharge of pollutants by the permittee or when requested bv
the director of the department.
C. Recording of Results
For each measurement or sample taken, the permittee shall
record the following information: (1) the 'date, exact place,
and tine of sampling; (2) the dates the analyses' were
performed; (3) who performed the analyses; (4) the analytical
techniques or methods used; and (5) the results of all
analyses .
u.
Samples and measurements taken to meet the requirements of
this condition shall be representative of the volume and
nature of the monitored discharge, including representative
sampling of any unusual discharge or discharge condition,
including bypasses, upsets, and maintenance related conditions
affecting effluent quality.
Test Procedures
All sampling and analytical methods used to meet the
monitoring requirements specified in this permit shall, unless
approved otherwise in writing by the department, conform to
the Guidelines Establishing Test Procedures for the Analysis
of Pollutants, contained in 40 CFR Part 136.
Addition Testing
The department may establish specific treatment plans,
receiving water, sediment and biological monitorino
requirements beyond those identified in this permit by permit
modification or administrative order.
D-125
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Page 4 of 8
Permit No. WA-003041-4
S3. RESIDUAL SOLIDS HANDLING
A. The permittee shall handle, utilize and dispose of all
residual solids in such a manner as to prevent its entry into
state ground or surface waters.
B. The permittee shall not permit leachate fron its residual
solids to enter state surface waters without providing all
known, available and reasonable methods of treatment, nor
permit such leachate to cause any adverse effect on state
ground waters. The permittee shall apply for a permit or
permit modification as may be required for such discharges.
D-126
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Page 5 of 8
Permit No. WA-003041-4
G2UEHAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be
consistent with the terms and conditions of this permit. The
discharge of any pollutant more frequently than or at a level in
excess of that authorized by this permit shall 'Constitute a
violation of the terms and conditions of this permit.
G2. The permittee shall at all times properly operate and maintain all
facilities and systems of collection, treatment and control (and
related appurtenances) which are installed or used by the permittee
to achieve ccnpliance with conditions of this permit.
G3. The permittee, in order to maintain compliance with its permit,
shall control production and/or all discharges upon reduction,
loss, failure, or bypass of the treatment facility until the
facility is restored or an alternative method of treatment is
provided. This requirement applies in the situation where, among
other things, the primary source of power of the treatment facility
is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be
uijaijle uj comply with any of tins aj.s*-Tj£i.ye limitations or otner
conditions specified in the permit, the permittee shall, at a
minimum, provide the department with the following information:
A. A description of the nature and cause of noncompliance,
including the quantity and quality of any unauthorized water
discharges;
B. The period of nonccmpliance , including exact dates and times
and/or the anticipated time when the permittee will return to
ccnpliance ; and
C. Steps taken or to be taken to reduce, eliminate, and prevent
recurrence of the nonccmpliance.
In addition, the permittee shall take immediate action to stop,
contain, and clean up any unauthorized discharges and take all
reasonable steps to minimize any adverse impacts to waters of the
state and correct the problem. The permittee shall notify the
department immediately by telephone so that an investigation can be
made to evaluate anv resulting impacts and the corrective actions
taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic
-^o i., 4- -,-,*. ,-,-.ci .._„*. .-^-...a..—] ,,— j — -. c— — . •--„_ im i.\ _jr "-v/^ i""1* .=.=n
fc**-*.*».A.u* i * •* *£. *_ _ _ *. «*t^i * i_ -j > *ii'ii A *n i w W*A*C.L *=*
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Page 6 of 8
Permit No. WA-003041-4
G4. (Cent.)
permittee becomes aware of the circumstances. If this information
is provided orally, a written submission covering these points
shall be provided within five days of the time the permittee
becomes aware of the circumstances, unless the department waives or
extends this requirement on a case-by-case basis.
Compliance with these requirements does not relieve the permittee
fron responsibility to maintain continuous compliance with the
conditions of this permit or the resulting liability for failure to
comply.
G5. The intentional bypass of wastes from all or any portion of a
treatment works to the extent that permit effluenr limitations
cannot be met is prohibited unless the following four conditions
are met:
A. Bypass is: (1) unavoidable to prevent loss of life, personal
injury, or severe property damage; or (2) necessary to perform
construction or maintenance related activities essential to
meet the requirements of tne Clean Water Act and authorized by
B. There are no feasible alternatives to bypass, such as the use
of auxiliary treatment facilities, retention of untreated
wastes, maintenance during normal periods of equipment down
time, or temporary reduction or termination of production;
C. The permittee submits notice of an unanticipated bypass to the
department in accordance with Condition G4. Where the
permittee knows or should have known in advance of the need
for a bypass, this prior notification shall be submitted for
approval to the department, if possible, at least 30 days
before the date of bypass (or longer if specified in the
special condition);
D. The bypass is allowed under conditions determined to be
necessary by the department to minimize any adverse effects.
The public shall be notified and given an opportunity to
comment on bypass incidents of significant duration, to the
extent feasible.
"Severe property damage" means substantial pnysical damage to
property, damage to the treatment facilities which would cause them
to become inoperable, or substantial and permanent loss of natural
resources which car. reasonably be exr^ctsd tc occur in the
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Page 7 of 8
Permit No. WA-003041-4
G6. The permittee shall allcw an authorized representative of the
department, upon the presentation of credentials and such other
documents as may be required by law:
A. To enter upon the permittr 's premises where a discharge
source is located- or where i. ~^crds must be kept under rha
terms and conditions of the p&rr_._;
3. To have access to and copy at reasonable times any records
that must be kept under the terms and conditions of the
permit;
C. To inspect at reasonable times any monitoring equipment or
method required in the permit;
D. To inspect at reasonable times any collection, treatment,
pollution management, or discharge facilities required under.
the permit;
E. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the
previous application where facility expansions, production
increases, or process modifications will (1) result in new or
substantially increased discharges of pollutants or a change in the
nature of the discharge of pollutants, or (2) violate the terms and
conditions of the existing permit.
G8. After notice and opportunity for public hearing, this permit may be
modified, terminated, or revoked during its term for cause as
follows:
A. Violation of any term or condition of the permit;
B. Failure of the permittee to disclose fully all relevant facts
or misrepresentation of any relevant facts by the permittee in
the application or during the permit issuance process;
C. A change in any condition that r-—uires either a temporary or
a permanent reduction or elimination of any discharge
controlled by the permit;
D. Information indicating that the permitted discharge poses a
threat to human health or welfare;
E. A change in ownership or control of the source; or
F. Other cause listed in 40 CFR Part 122.62 and 122.63. Permit
modification, revocation and reissuance, or termination may be
initiated by the department or requested by any interested
person.
D-129
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Page 8 of 8
Permit No. WA-003041-4
G9. A permittee who knows or has reason to believe that any activity
has occurred or will occur which would constitute cause for
modification or revocation and reissuance under Condition G8. or 40
CFR Part 122.62 must report its plans, or such information, to the
department so that a decision can be made on whether action to
modify or revoke and reissue a permit will be required. The
department may then require submission of a new application.
Submission of such application does not relieve the discharger of
the duty to comply with the existing permit until it is modified or
reissued.
G10. If any applicable toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or
prohibition) is established under Section 307 (a) of the Clean Water
Act for a toxic pollutant and that standard or prohibition is more
stringent than any limitation upon such pollutant in the permit,
the department shall institute proceedings to modify or revoke and
reissue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any wastewater control
facilities, detailed plans shall be submitted to the department for
dpjaroval in accordance wrui wflC i/3-240. taciiities siiau. oe
constructed and operated in accordance with the approved plans.
G12. All other requirements of 40 CFR 122.41 and 122.42 are incorporated
into this permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee
frctn compliance with any applicable federal, state, or local
statutes, ordinances, or regulations.
D-130
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Daae 1 of
Permit No. WA-QQ3Q2q-:S ':'
Issuance Date 2-20-75~^
Exoiration Date 6-30-51
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In Compliance with the provisions of
Chapter 90.48 RCW as amended
and
The Federal Water Pollution Control Act Amendment of 1972
Public Lav: C2-SCO
WASHINGTON STATE DEPARTMENT OF GAME
600 North Capitol Way
Olympia, Washington 98504
Hatchery Name:
Location:
Bellingnam Hatchery
Whatcom Falls Park
Bellingnam, VIA 98225
Hatchery Type: FISH CULTURE
Receivino Water:
Whatcom CreeK
Discharge Locations: T38N, R3E, S23
Waterway Segment No.: 01-01-03
is authorized to discharge in accordance with the special
and general conditions which follow.
I I
BRUCE CAMERON, Assistant Director
Department of Ecology (1)
D-131
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Daily
Average
gal/day
NA
Daily
Maximum
NA
NA
Minimum
Frequency
weekly
weekly
Sample
Type
daily total
grab
Dage 2 of ;
Permit :!o. '.-^-003029-5
SPECIAL CONDITIONS
SI. INTERIM EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the date of issuance of this permit and
lasting through June 30, 1977, the permittee is authorized to discharge
subject to the following limitations and monitoring requirements:
EFFLUENT LIMITATIONS MONITORING REQUIREMENTS
Parameter
Flow
Settleable Solids
Grab samples shall be obtained during cleaning operations.
The pounds of fish on hand and pounds of food fed shall be reported for each
month.
S2. FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
After June 30, 1977 and lasting through the expiration date of this permit,
the permittee is authorized to discharge subject-to the limitations as speci-
fied below.
Beginning on this date all known available and reasonable methods of treatment
necessary to achieve effluent levels specified herein will be required before
discnarge to state waters.
FINAL EFFLUENT LIMITATIONS
Parameter
Flow
Settleable Solids*
Suspended Solids
* Grao samoles shall be obtained during cleaning operations.
Daily
Average
3.600 mgd
0.1 ml/1
515 Ibs/day
Daily
Maximum
G.2 ml /I
679 Ibs/day
Sample
Type
daily total
grao
composite
D-132
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Page 2 of 7
Permit f!o. '.iA-003029-i
52. FINAL EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (Continued)
The caily average is defined as the average of the measured values oo-
tainea over a calendar month's £i~e.
The daily maximum is defined as the maximum value ootained during any
calendar aay.
Effluent limitations are net values allowable above that of the intake
water.
A composite samole is comprised of four or more sub-samples characteristic
of the effluent during a daytime wortcshift. When sampling two or more out-
falls, each grab sample is sized in proportion to the flow being sampled
before combining with the other samples.
The Department will establish a monitoring schedule, applying after in-
stallation of the required improvements, prior to that date. The schedule
will include all aspects of the interim schedule, and also additional test-
ing to include efficiency of the treatment facility- as determined by the
department.
S3. SCHEDULE OF COMPLIANCE
a. The permittee shall install a settling pond, or equivalent treatment,
for the cleaning wastewater, which provides for 85 percent removal of
the suspended solids, or shall install a settling basin for the total
hatchery flow. In either case, the permittee shall attain compliance
with the effluent limitations in accordance with the following schedule:
Complete construction and attain comoliance with final limitations
by June 30, 1977.
b. The permittee shall provide the appropriate regional office of the
department with written notice of compliance or noncompliance with
the interim or final requirements not later than 14 days after each
date set forth above.
D-133
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Page 4 of 7
Permit No. HA-003029-2
S4. MONITORING AND REPORTING
"he permittee shall monitor the operation of all treatment and control
facilities and the quantity and quality of the waste discharged. A record
of all such data shall be maintained. The permittee shall monitor the
parameters as specified in Condition S2 of this permit.
a. Reporting
Monitoring results obtained during the previous month shall be reported
on the Department of Ecology reporting form and submitted no later than
the 15th day of the month following the completed reporting period.
Monitoring shall be started September 1, 1975 and the first report is
due October 15, 1975.
If the permittee monitors any pollutant more frequently than required
by the permit, he shall submit the results together with the monthly
report.
b. Sampling Procedures
The permittee shall submit to the aforementioned regional office a
summary of the sampling and analysis program it will use when trans-
mitting the first monitoring report. The summary is to be a detailed
description of the sampling procedures, sample analysis techniques,
and exact location of sampling stations shown by sketch.
c. Records Retention
The permittee shall retain for a minimum of three years all records of
monitoring activities and results, including all reports of recordings
from continuous monitoring instrumentation. This period of.retention
shall be extended during the course of any unresolved litigation re-
garding the discharge of pollutants by the permittee or when requested
by the Director.
d. Recording of Results
The permittee shall record each measurement or sample taken pursuant
to the requirements of this permit for the following information:
(1) the date, exact place, and time of sampling; (2) the dates the
analysis were performed; (3) who performed the analyses; (4) the
analytical techniques or methods used; and (5) the results of all
analyses.
D-134
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Page 5 o.f 7
Permit No. VJA-003029-2
S4. MONITORING AND REPORTING (Continued)
e. Representative Sampling
Samples and measurements taken to meet the requirements of this condi-
tion shall be representative of the volume and nature of the monitored
discharge.
f. Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in
writing by the department, conform to:
American Public Health Association, Standard Methods for
the Examination ojf Water and Wastewaters, latest addition,
or_ Guidelines Establishing Test Procedures for the Analysis
of Pollutants, contained in 40 CFR Part 136, as published
in the Federal Register.
S5. UlHhR REQUIREMENTS
a. Waterborne silt, sand, and other debris deposited on the premises
shall not be deposited back into a watercourse.
b. Permittee shall handle and dispose of all solid waste materials
in such a manner as to prevent their entry into state ground or
surface water.
c. Fish mortalities and spawned fish shall not be disposed to a
watercourse.
d. After June 30, 1977, blood and wastes resulting from spawning
.operations shall not be allowed to enter a watercourse but shall
be disposed on land or by other means. Implementation shall be
according to the compliance schedule of Condition S3.
D-135
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Page 6 of 7
Permit No. ','!A-003029-5
GENERAL CONDITIONS
Gl. All discharges and activities authorized herein shall be consistent with
the terms and conditions of this permit. The discnarge of any pollutant
more frequently than or at a level in excess of that identified and author-
ized by this permit shall constitute a violation of the terms and condi-
tions of this permit.
G2. Any anticipated facility expansion, production increase or process modifi-
cation which will result in a new or increased discharge of pollutants
must be reported to the department by submission of a new application or
suoplement thereto; or, if such discharge will not violate effluent limita-
tions specified herein, by submission to the department a notice of such
new or increased discharge.
G3. "he diversion or bypass of any discharge from facilities utilized by the
permittee to maintain compliance with the terms and conditions of this
permit is prohibited, except (a) where unavoidable to prevent loss of life
or severe property damage, or (b) where excessive storm drainage or run-
c** "suld ii-.age any f uc', 1 i L i ea nev-ubbary for compliance with the terms
and conditions of this permit. The permittee shall immediately notify
the department in-writing of each such diversion or bypass in accordance
with the procedure specified in Condition G4.
G4. In the event, the permittee is unable to comply with any of the conditions
of this permit because of a breakdown of equipment or facilities, an acci-
dent caused by human error or negligence, or any other cause, such as an
act of nature, the permittee shall:
a. Immediately take action to stop, contain, and clean up the unauthor-
ized discharges and correct the problem.
b. _ Immediately notify the department so that an investigation can be
made to evaluate the impact and the corrective actions taken and
determine additional action that must be taken.
c. Submit a detailed .written report to the department describing the
breakdown, the actual quantity and quality of resulting waste dis-
charges, corrective action taken, steps taken .to prevent a recur-
rence, and any ether pertinent information.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance v:ith the conditions of
this permit or the resulting liability for failure to comply.
D-136
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Page 7 of 7
Permit No. 'iA-003029-5
G5. The oermlttee shall at all times maintain in good working order ana effi-
ciently operate all treatment or control facilities or systems installed
or 'jsed by the oemittse to acnieve compliance vntn the cerms ana conai-
cions of this permit.
Go. After notice and opportunity for a hearing, this permit may be modified,
suspended or revoked in whole or in part during its term for cause includ-
ing, but not limited to the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to disclose
fully all relevant facts;
c. A change in the condition of the receiving waters or any other condi-
tion that requires either a temporary or permanent reduction or eli-
mination of the authorized discharge.
G7. The permittee shall, at all reasonable times, allow authorized rpnroSents-
tives of the department:
a. To enter upon the permittee's premises for the purpose of inspecting
and investigating condition relating to the pollution of, or possible
pollution of, any of the waters of the state, or for the purpose of
investigating compliance with any of the terms of this permit;
b. To have access to and copy and records required to be kept under the
terms and conditions of this permit;
c. To inspect any monitoring equipment or monitoring method required by
this permit; or,
d. To sample any discharge of pollutants.
G3. If a toxic effluent standard or prohibition (including any schedule of com-
pliance specified in such effluent standard or prohibition) is established
under Section 3.07 (a) of the Federal Act for a toxic pollutant which is
present in the discharge authorized herein and such standard or prohibition
is more stringent than any limitation upon such pollutant in this permit,
this permit shall be revised or modified in accordance with the toxic ef-
fluent standard or pronibition and the permittee shall be so notified.
Section 307 (a) requires that the Adminisr-Mt: - the Environmental Pro-
tection Agency shall promulgate effluent scanaaras (or prohibition) for
toxic pollutants wnich he has listed as such.
G9. Nothing in this permit shall be construed as excusing the oermittee from
compliance with any applicable Federal, State, or local statutes, ordi-
nances, or regulations.
D-137
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Page 1 of 7
Permit Number WA-003019-8
Issuance Date: MAY 17 1983
Expiration Date: MAY 17 1988
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 RCW as amended
and
The Clean Water Act as amended
Public Law 95-217
WASHINGTON STATE DEPARTMENT OF FISHERIES
Koom 115, General Administration tsuilding
Olympia, Washington 98504
Hatchery >>ane: Receiving Water:
Xooksack State Salmon Hatchery Kendall Creek
Location: Discharge Location:
Glacier S:ar Route E T39N, R5E, Section 3,
Hatchery Type: Waterway Segment No.:
Fish Culture 01-01-05
is authorized to discharge in accordance with the special
and general conditions which follow.
Bruce A.\Cameron /
Assistant Director /^
Department of Ecology ( )
D-138
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Page 2 of 7
t-c.mit 'No. WA-003019-8
SI. FIXU EFFLUENT LIMITATIONS AND NDNITORIXG REQUIREMENTS
After issuance, and lasting until the expiration date of this permit, the
permittee is authorized to discharge treated wastewater to Kendall Creek
subject to the following limitations as specified below:
Beginning on this date, no organic solids settled out in fish culturing
facilities shall be resuspended and discharged with the tailwaters nor
otherwise discharged to surface waters as a result of discretionary manage-
ment practices without first undergoing treatment by sedimentation or its
equivalent.
a. Cleaning Wastewater Treatment Facility
The design and operation of the treatment process shall provide for
85 percent removal of the suspended solids contained in the cleaning
wastewater. Monitoring of the influent and effluent by the permittee
will be required to determine compliance.
b. Effluent Limitations
EFFLUENT LIMITATIONS NDNITORING REQUIREMENTS
Parameter
Flow
Settleable
Solids*
Suspended
Solids
Suspended
Solids
Daily
Daily
Average Maximum
18.8 mgd
0.1 ml/1
3,344 Ibs/day
(composite
27.4 mgd
0.2 ml/1
4,408 Ibs/day
sample)
15 mg/1
Minimum
Frequency
Weekly
Weekly
N/A
N/A
Samtile
Type
Daily total
Grab*
N/A
N/A
(grab sample)
*Grab samples shall be obtained during cleaning operations.
In addition, the pounds of fish on hand and pounds of food fed shall be
reported for each month.
The daily average is defined as the average of the measured values
obtained over a calendar month's time. The daily maximum is defined
as the greatest allowable value obtained during any calendar day.
Effluent limitations are net values allovrable above that of the intake
water.
A composite sample is comprised of four or more sub-samples character-
istic of the effluent during a daytime workshift. When sampling two
or more outfalls, each grab sample is sized in proportion to the flow
being sampled before combining with the other samples.
D-139
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Page 3 of 7
Permit No. WA-003019-8
52. MDNITORING AND REPORTING
The permittee shall monitor the operations and efficiency of all treatment
and control facilities and the quantity and quality of the waste discharged.
A record of all such data shall be maintained. The permittee shall monitor
the parameters as specified in Condition SI of this permit.
a. Reporting
Monitoring results obtained during the previous three months shall
be submitted no later than the 15th day of the month following the
completed reporting period. The report shall be sent to the Northwest
Regional Office of the Department of Ecology, 4350 - 150th Avenue N.E.,
Redmond, Washington 98052.
b. Records Retention
The permittee shall retain for a minimum of three years all records of
monitoring activities and results, include all reports of recordings
from continuous monitoring instrumentation. This period of retention
shall be extended during the course of any unresolved litigation re-
garding the discharge of pollutants by the permittee or when requested
by the director.
c. Recording of Results
For each measurement or sample taken, the permittee shall record
the following information: (1) the date, exact place, and time of
sampling; (2) the dates the analyses were performed; (3) who performed
the analyses; (4) the analytical techniques or methods used; and
(5) the results of all analyses.
d. Representative Sampling
Samples and measurements taken to meet the requirements of this
.condition shall be representative of the volume and nature of the
monitored discharge.
e. Test Procedures
All sampling and analytical methods used to meet the monitoring require-
ments specified in this permit shall, unless approved otherwise in writ-
ing by the department, conform to the Guidelines Establishing Test
Procedures for the Analysis of Pollutants contained in 40 CFR 156,
as puolisned in the Federal Register on December 1, 1976, or the latest
revision thereof, which currently references the following publications:
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Permit No. WA-003019-8
52. MONITORING AND REPORTING (Continued)
e. Test Procedures (Continued)
1. American Public Health Association, Standard Methods for the Exami-
nation o£ Water and Wastewaters. "'
2. American Society for Testing and Materials, A.S.T.M. StandardsT
Part 31, Water, Atmospheric Analysis.
3. Environmental Protection Agency, Methods for Chemical Analysis
of Water and Wastes.
S3. RELEASE PONDS - EFFLUENT LIMITATIONS
When a release pond is drained the flow shall be controlled such that the
settleable solids in the discharge does not exceed 3.3 ml/liter at any time.
The permittee shall monitor the discharge during draining operations by
taking daily grab samples which are representative of the discharge that
day. The samples shall be analyzed for settleable solids and the results
reported in the regular monthly report.
S4. SOLID WASTE DISPOSAL
a. The permittee shall handle and dispose of all solid waste material in
such a manner as to prevent its entry into state ground or surface
waters.
b. The permittee shall not permit leachate from its solid waste material
to enter state surface waters without providing all known, available
and reasonable methods of treatment, nor permit such leachate to cause
any adverse effect on state ground waters. The permittee shall apply
for a permit or permit modification as may be required for such dis-
charges .
S5. OTHER REQUIREMENTS
a. Waterborne silt, sand, and other debris deposited on the premises shall
not be deposited back into a watercourse.
b. Fish mortalities and spawned fish shall not be disposed to a watercourse.
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Permit N'o. WA-003019-8
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be consistent
with the terras and conditions of this permit. The discharge of any pollutant
more frequently than or at a level in excess of that authorized by this
permit shall constitute a violation of the terms and conditions of this
permit.
G2. The permittee shall at all tiroes properly operate and maintain all facilities
and systems of collection, treatment and control (and related appurtenances)
which are installed or used by the permittee to achieve compliance with con-
ditions of this permit.
G3. The permittee, in order to maintain compliance with its permit, shall
control production and/or all discharges upon reduction, loss, failure, or
bypass of the treatment facility until the facility is restored or an
alternative method of treatment is provided. This requirement applies in
the situation where, among other things, the primary source of power of the
treatment facility is reduced, lost, or fails.
G4. If, for any reason, the permittee does not comply with or will be unable to
comply with any of the discharge limitations or other conditions specified
in the permit, the permittee shall, at a minimum, provide the department
witn the following information:
a. A description of the nature and cause of nonccmpliance, including the
quantity and quality of any unauthorized waste discharges;
b. The period of noncompliance, including exact dates and times and/or
the anticipated time when the permittee will return to compliance; and
c. Steps taken or to be taken to reduce, eliminate, and prevent recurrence
of the noncompliance.
In addition, the permittee shall take imiediate action to stop, contain,
and clean up any unauthorized discharges and take all reasonable steps to
minimize any adverse impacts to waters of the state and correct the problem.
The permittee shall notify the department immediately by telephone so that
an investigation can be made to evaluate any resulting impacts and the
corrective actions taken to determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollutant
effluent standard under Section 307 (a) of the Clean Water Act, or which
could constitute a threat to human health, welfare, or the environment,
40 CFR Part 122 requires that the information specified in items G4.a.,
G4.b., and G4.c., above, shall be provided not later than 24 hours from the
time the permittee becomes aware of the circumstances. If this information
is provided orally, a written submission covering these points shall be
provided within five days of the time the permittee becomes aware of the
circumstances, unless the department waives or extends this requirement on
a case-by-case basis.
Compliance with these requirements does not relieve the permittee from
responsibility to maintain continuous compliance with the conditions of
this permit or the resulting liability for failure to comply.
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Permit No. WA-003019-8
G5. The intentional bypass of wastes fron ail or any portion of a treatment
works to the extent that permit effluent limitations cannot be met is
prohibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss oL" life, personal injury,
or severe property damage; or (2j necessary to perform construction or
maintenance- related activities essential to meet the requirements of
the Clean Water Act and authorized by administrative order;
b. There are no feasible alternatives to bypass, •such as the use of
auxiliary- treatment facilities, retention of untreated wastes, mainten-
ance during normal periods of equipment down time, or temporary reduc-
tion or termination of production;
c. The permittee submits notice of an unanticipated bypass to the depart-
ment in accordance with Condition G4. Where the permittee knows or
should have known in advance of the need for a bypass, this prior
notification shall be submitted for approval to the department, if
possible, at least 30 days before the date of bypass (or longer if
specified in the special conditions) ;
d. The bypass is allowed under conditions determined to be necessary by
the department to minimize any adverse effects. The public shall be
notified and given an opportunity to comment on bypass incidents of
significant duration, to the extent feasible.
to property;
damage to the treatment facilities which would cause them to become inoper-
able, or substantial and permanent loss of natural resources which can
reasonably be expected to occur in the absence of a bypass. Severe property
damage does not mean economic loss caused by delays in production.
After consideration of the factors above and the adverse effects of the
proposed bypass, the department will approve or deny the request. Approval
of a request to bypass will be by administrative order under RCW 90.48.120.
G6. The permittee shall allow an authorized representative of the department,
upon the presentation of credentials and such other documents as may be
required by law:
a. To enter upon the permittee's premises where a discharge source is
located or where any records must be kept under the terms and conditions
of the permit;
b. To have access to and copy at reasonable times any records that must
be kept under the terms and conditions of the permit;
c. To inspect at reasonable times any monitoring equipment or method
required in the permit;
d. To inspect at reasonable times any collection, treatment, pollution
management, or discharge facilities required under the permit;
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the previous
application where facility expansions, production increases, or process
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Permit N'o. WA-003019-8
-odifLcations will (1) result in new or substantially increased discharges
of rollutants or a change in the nature of the discliarge of pollutants, or
(2) violate the terms and conditions of the existing permit.
GS. After notice and opportunity for public hearing, this permit may be modified,
terminated, or revoked curing its term for cause as follows:
a. violation of any term or condition of the permit;
b. Failure of the permittee to disclose fully all relevant facts or
misrepresentation of any relevant facts by the permittee in the
application or during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled by
the permit;
d. Information indicating that the permitted discharge poses a threat to
human health or welfare;
e. A change in ownership or control of the source; or
f. Other cause listed in 40 CFR Part 122.15 and 122.16.
Permit modification, revocation and rcissuance, or termination may be
initiated by the department or requested by any interested person.
G9. A permittee who knows or has reason to believe that any activity has
occurred or will occur which would constitute cause for modification or
rev .-rion and rcissuance under Condition G8. or 40 CFR Part 122.15 must
repc.'~ its plans, or such information, to the department so that a decision
can be made on whether action to modify or revoke and reissue a permit will
be required. The department may then require submission of a new application.
Submission of such application docs not relieve the discharger of the duty
to comply with the existing permit until it is modified or reissued.
CIO. If any applicable toxic effluent standard or prohibition (including any
schedule of compliance specified in such effluent standard or prohibition)
is established under Section 307[a) of the Clean Water Act for a toxic
pollutant and that standard or prohibition is more stringent than any
limitation upon such pollutant in the permit, the department shall institute
proceedings to modify or revoke and reissue the permit to conform to the
toxic effluent standard or prohibition.
Gil. Prior to constructing or modifying any wastewater control facilities,
detailed plans shall be submitted to the department for approval in accor-
dance with WAC 173-240. Facilities shall be constructed and operated in
accordance with the approved plans.
G12. All other requirements of 40 CFR Part 122.7, 122.60, and 122.61 are in-
corporated into this permit by reference.
G15. Nothing in this permit shall be construed as excusing the permittee from
compliance with any applicable federal, state, or local statutes, ordinances,
or regulations.
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Page 1 of 12
Permit No. WA 000109-1
Issuance Date: June 27, -985
Expiration Date: June 27, 1990
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
WASTE DISCHARGE PERMIT
State of Washington
DEPARTMENT OF ECOLOGY
Olympia, Washington 98504
In compliance with the provisions of
Chapter 90.48 RCW as amended
and
The Clean Water Act as amended
Public Law 95-217
Georgia-Pacific Corporation
P. 0. Box 1236
Bellingham, Washington 98227
Plant Location Receiving Water
Laural St. & Cornwall Ave. Bellingham Bay
Bellingham, Washington
Discharge Location
Industry Type
Bellingham Bay
Sulfite Pulp, Paper and
Chemical Complex Waterway Segment Number
01-01-03
The above-named corporation is authorized to discharge at the location
described in accordance with the conditions contained herein.
Marc A. Morton
Assistant Director
Department of Ecology
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Permit No. WA 000109-1
BASIS OF EFFLUENT LIMITATIONS
The limitations of Condition SI are based on guidelines published November 18, 1982 under 40 CFR Part 430 by the
Environmental Protection Agency (EPA) for Best Practicable Technology (BPT) and Best Available Technology (BAT)
for sulfite pulp mills. As EPA has not published applicable guidelines for Best Conventional Technology (BCT),
these limitations are established in this permit by Best Engineering Judgment (BEJ) of the Department of Ecology
as being equal to BPT. Limitations for an unclassified pulping process, identified as Perinaciiem, are also estab-
lished by BEJ. The limitations are calculated for Condition SI by applying unit allocations, tabulated below, to
pulp production rates of 618 tons per day for sulfite pulp and 54 tons per day for Permachcm pulp for the
12-month period ending February 1985.
BOD Ibs per ton
TSS Ibs per ton
ACID SULFITE, DRUM WASH
Surface Condensers, BPT
Allocation @ 43%
Barometric Condenser, BPT
Allocation @ 57%
TOTAL SULFITE, BPT
PERMACItEM, BEJ
Daily Average
31.0
13.3
33.8
19.3
32.6
24.6
Daily Maximum
59.5
25.6
65.0
37.1
62.7
47.3
Daily Average
47.3
20.3
56.2
32.0
52.3
24.2
Dai ly Maximum
87.9
37.8
104.4
59.5
97.3
45.0
BCT and BAT limitations for chlorine plants were published by EPA on June 29, 1982. Effluent from the chlorine
plant is pumped to the aerated lagoon where it merges for discharge with pulp mill wastewater. Results of a moni-
toring study conducted under the superseded permit showed that, except for mercury, chlorine plant limitations
were satisfied by monitoring and meeting pulp mill limitations on the combined effluent. Monitoring for mercury
is conducted on the discharge from the mercury treatment facility prior to merging with other wastewater. The
mercury BAT limitations are based on a chlorine production rate of 235 tons per day and unit limitations of
0.2 Ibs of mercury per 1,000 tons of chlorine as a daily average and 0.46 Ibs of mercury per thousand tons ol
chlorine as a daily maximum.
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I'age 1 of 12
Permit No. WA 000109-1
SPECIAL CONDITIONS
SI. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
The permittee is authorized to discharge from Outfall No. 009 Subject io the following 1 inn LaLions arid moni-
toring requirements:
Parameter
Biochemical Oxygen Demand (5-day)
Total Suspended Solids
pH1
t> Total Mercury
$ Temperature, °F
Flow (mgd)
Production, tons/day
Sulfite pulp
Chemi-mechanical pulp
Notes:
EFFLUENT LIMITATIONS
Pounds per day (kg/day)
Daily Average 2
MONITORING REQUIREMENTS3
Minimum
Frequency
21,500 (9,800) 41,300 (18,800) Daily
33,600 (15,300) 62,600 (28,500) Daily
within the range of 5.0 to 9.0
0.05 (0.023) 0.11 (0.05)
Continuous
Daily
Conti nuous
Cont inuous
Sample Type
24 -hour composite4
24-hour composite
I n t,l antaneous
24-|iour composite
Inslantancous
Instantaneous
Monthly Average
Monthly Average
1 All excursions outside the 5.0 or 9.0 pll range shall be considered violations, i.e., 40 CFK 401.17 shall not
apply to this discharge.
2The daily average is defined as the average of the measured values obtained over a calendar month's time.
3 Monitoring shall be conducted on the total discharge through Outfall N<>. 009, except for mercury, which shall be
monitored at the effluent from the mercury treatment facility.
4 Composite sample ..hall be refrigerated (lining collection.
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Page 4 of 12
Permit No. WA 000109-1
32. MONITORING AND REPORTING
The permittee shall monitor the parameters as specified in Condi-
tion SI and shall comply with the following additional requirements.
a. Representative Sampling
Samples and measurements taken to meet the requirements of this
permit shall be representative of the volume and nature of the
discharge.
b. Test Procedures
All sampling and analytical methods used to meet the monitoring
requirements specified in this permit shall, unless approved
otherwise in writing by the department, conform to the guide-
lines establishing testing procedures for the analysis of
pollutants contained in 40 CFR, Part 136-, as published in the
Federal Register.
c. ' Recording of Results
The following information shall be recorded for each sampling
or measurement: (1) date, time, and place of sampling; (2) date
of analysis; (3) name of analyst; (4) analytical technique or
method used; and (5) results of analysis.
d. Records Retention
All records of monitoring including reports, analytical results,
and instrument recordings shall be retained for at least
three years. This period of retention may be extended by
request of the department.
e. Reporting
Monitoring results obtained during a month shall be summarized
on a report form provided by the department. The report shall
be mailed to the following address no later than 15 days after
the end of the month:
Department of Ecology
Industrial Section
Mail Stop PV-11
Olympia, Washington 98504
S3. OTHER REQUIREMENTS
a. Toxicity Limitation
Samples of discharge through Outfall No. 009 shall show a
salmonid survival rate of at least 80 percent in a 96-hour
bioassay of 65 percent effluent concentration. Testing shall
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Permit No. WA 000109-1
be conducted semi-annually in accordance with the Department of
Ecology Acute Toxicity Test Method (1974), or an approved
equivalent method. The department may temporarily require more
frequent testing if a bioassay shows Less than 80 percent sur-
vivial, or if process or treatment modifications cause a change
in effluent composition.
Treatment System Operating Plan
Within six months after the issue date of this permit, 2
wastewater treatment system operating plan shall be submitted
to the Department of Ecology for approval. The plan shall
describe the following operational modes:
(1) A baseline mode which describes the treatment system
operating parameters and procedures used to meet the
limitations of Conditions SI at the production levels used
to establish these limitations.
(2) A sub-baseline mode which describes the treatment system
operating parameters and procedures needed to maintain the
treatment system design efficiency at production levels
less than those identified for the baseline mode.
Following approval of the plan by the Department of Ecology the
permittee shall operate the treatment system at all times in
accordance with the approval plan.
Spill Prevention, Containment and Countermeasure Plan
Within six months after the issue date of this permit, the
permittee shall prepare and submit for the Department of
Ecology's review and approval, an updated Spill Prevention,
Containment, and Countermeasure Plan for the facilities covered
in this permit. The updated plan shall supersede the plan ap-
proved November 20, 1979 by the Department of Ecology. Such
plan shall include information and procedures relative to the
prevention of spills and unplanned discharge of oil and liquid
chemicals as follows:
(1) A description of the reporting system which will be used
to alert responsible facility management and appropriate
legal authorities.
(2) A description of preventive facilities (including overall
facility plot) which prevent, contain, or treat spills and
unplanned discharges.
(3) A list of all oil and liquid chemicals use, processed, or
stored at the facility which may be spilled into permitted
discharge and a facility plot showing the location of
storage facilities.
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Permit No. WA 000109-1
(4) A facility plot showing all surface drainage routes.
(5) For purposes of this subsection, plans and manuals
required by the following may be included:
(a) CFR Title 33, Chapter I, subchapter 0, Part 154,
dated December 21, 1972.
(b) CFR Title 40, Chapter I, subchapter D, Part 112,
dated December 11, 1973.
The permittee shall comply with the plan as approved by the
Department of Ecology. No change in the plan shall be imple-
mented by permittee without written approval by the Department
of Ecology.
d. Thermal Discharge Limitation
•Discharge by permittee shall not cause measurable temperature
increase (0.5°F) outside the dilution zone described below
' which results in water temperature in excess of that permittee
by Chapter 173-201 WAC for the applicable water quality
classification.
(1) Boundaries in the vertical plane shall be one foot below
the receiving water surface and one foot above the bottom.
(2) The lateral distance on either side of the diffuser
centerline shall be 200 feet.
(3) The longitudinal distance on either end of the diffuser
shall be 200 feet.
e. Solid Waste Control
(1) This condition applies to all solid wastes not covered by
Chapter 173-303 WAC, Dangerous Waste Regulations.
(2) All solid waste material shall be handled and disposed of
in a manner that prevents its entry into state ground or
surface water.
\ (3) The permittee shall not allow leachate from solid waste
materials to enter state ground or surface water without
providing all known, available, and reasonable methods of
treatment, nor allow such leachate to cause any adverse
effect on state ground or surface water.
(4) The solid waste control plan approved by the Department of
Ecology on June 14, 1977 shall be reviewed by permittee
for updating purposes. Within six months after the issue
date of this permit, an updated plan shall be submitted to
the Department of Ecology for approval. The updated plan
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Permit No! WA 000109-1
shall include all solid wastes except those covered by
Chapter 173-303 WAC, Dangerous Waste Regulations. No
change in the updated plan shall be implemented by permit-
tee without written approval by the Department of Ecology.
(5) The permittee shall maintain the impervious asphalt cover-
ing over the mercury contaminated sludge deposit located
on permittee's log storage property adjacent to the
chlor/alkali plant. The deposit contains about 7,000 tons
of chemfix sludge with a mercury concentration of about
0.17 percent. A plot plan of the pavement over the depos-
it is shown in permittee's Drawing No. C4546, received by
the Department of Ecology on July 29, 1977. The deposit
is located within those portions of Blocks 188, 189, 200,
and 201 of the plot of New Whatcom Tidelands and those
portions of Bay St. (vacated) and Myrtle St. (vacated)
lying within a rectangle area of 220 feet by 480 feet
described as follows: from the centerpoint of the inter-
section of Bay St. and Myrtle St. to a distance of 400 feet
southwest and 80 feet northeast along the centerline of
Bay St. , all property northwest of the Bay St. centerline
for a distance of 160 feet and all property southeast of
the Bay St. centerline for a distance of 60 feet. No
project involving excavation of the chemfix sludge deposit
shall be undertaken without written approval of the De-
partment of Ecology. The above site description and main-
tenance requirements shall be included in succeeding
discharge permits as long as the deposit exists.
f. Biocide Certification
Within 30 days after the issue date of this permit, the permit-
tee shall provide written certification to the Department of
Ecology that biocides containing chlorophenols are not used.
g. Disposal of Sanitary Sewage
All sanitary sewage shall be discharged to the treatment facil-
ities of the City of Bellingham for treatment and disposal.
h. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Federal
Water Pollution Control Act as amended.
i. Foam Control
The effluent shall not cause any significant visible foam in
the receiving water.
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Permit No. WA 000109-1
Chip Spillage
The operations of unloading, conveying, and storage of wood
chips and hog fuel shall be performed in a manner that prevents
spillage into the water of significant amounts of chips or hog
fuel.
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Permit No. WA 000109-1
GENERAL CONDITIONS
Gl. All discharges and activities authorized by this permit shall be
coosistent with the terms and conditions of this permit. The dis-
charge of any pollutant more frequently than, or at a level in ex-
cess of, that authorized by this permit shall constitute a violation
of the terms and conditions of chis permit.
G2. The permittee shall at all times properly operate and maintain all
facilities and systems of collection, treatment, and control (and
related appurtenances) which are installed or used by the permittee
to achieve compliance with the terms and conditions of this permit.
G3. The permittee, in order to maintain compliance with its permit,
shall control production and/or all discharges upon reduction, loss,
failure, or bypass of the treatment facility until the facility is
restored or an alternative method of treatment is provided. This
requirement applies in the situation where, among other things, the
primary source of power of the treatment facility is reduced. Lost,
or /fails .
G4. If, for any reason, the permittee does not comply with, or will be
unable to comply with, any of the discharge limitations or other
conditions specified in the permit, the permittee shall, at a mini-
mum, provide the department with the following information:
a. A description of the nature and cause of noncompliance, includ-
ing the quantity and quality of any unauthorized waste
discharges;
b. The period of noncompliance, including exact dates and times
and/or the anticipated time when the permittee will return to
compliance; and
c. Steps taken, or to be taken, to reduce, eliminate, and prevent
recurrence of the noncompliance.
In addition, the permittee shall take immediate action to stop,
contain, and clean up any unauthorized discharges and take all rea-
sonable steps to minimize any adverse impacts to waters of the state
and correct the problem. The permittee shall notify the department
immediately by telephone so that an investigation can be made to
evaluate any resulting impacts and the corrective actions taken to
determine if additional action should be taken.
In the case of any discharge subject to any applicable toxic pollu-
tant effluent standard under Section 307(a) of the Clean Water Act,
or which could constitute a threat to human health, welfare, or the
environment, 40 CFR Part 122 requires that the information specified
in items G4.a.. G4.b., and G4.c., above, shall be provided not later
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Permit No. WA .000109-1
than 24 hours from the time the permittee becomes aware of the cir-
cumstances . If this information is provided orally, a written sub-
mission covering these points shall be provided within five days of
the. time the permittee becomes aware of the circumstances, unless
the department waives or extends this requirement on a case-by-case
basis.
Compliance with these requirements does not relieve the permittee
from responsibility to maintain continuous compliance with the con-
ditions of this permit or the resulting liability for failure to
comply.
G5. The intentional bypass of wastes from all or any portion of a treat-
ment works to the extent that permit effluent limitations cannot be
met is prohibited unless the following four conditions are met:
a. Bypass is: (1) unavoidable to prevent loss of life, personal
injury, or severe property damage; or (2) necessary to perform
.construction or maintenance-related activities essential to
meet the requirements of the Clean Water Act and authorized by
/ administrative order;
b. There are no feasible alternatives to bypass, such as the use
of auxiliary treatment facilities, retention of untreated
wastes, maintenance during normal periods of equipment down
time, or temporary reduction or termination of production;
c. The permittee submits notice of an unanticipated bypass to the
department in accordance with Condition G4. Where the
permittee knows or should have known in advance of the need for
a bypass, this prior notification shall be submitted for ap-
proval to the department, if possible, at least 30 days before
the date of bypass (or longer if specified in the special
conditions);
d. The bypass is allowed under conditions determined to be neces-
sary by the department to minimize any adverse effects. The
public shall be notified and given an opportunity to comment on
bypass incidents of significant duration, to the extent
feasible.
"Severe property damage" means substantial physical damage to prop-
erty, damage to the treatment facilities which would cause them to
become inoperable, or substantial and permanent loss of natural
resources which can reasonably be expected to occur in the absence
of a bypass. Severe property damage does not mean economic loss
caused by delays in production.
After consideration of the factors above and the adverse effects of
the proposed bypass, the department will approve or deny the re-
quest. Approval of a request to bypass will be by administrative
order under RCW 90.48.120.
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Permit No. WA 000109-1
G6. The permittee shall allow an authorized representative of the de-
partment, upon the presentation of credentials and such other docu-
ments as may be required by law:
a. To enter upon the premises where a discharge is located or
where any records must be kept under the terms and conditions
of this permit;
b. To have access to and copy at .reasonable times any records that
must be kept under the terms of the permit;
c. To inspect at reasonable times any monitoring equipment or
method of monitoring required in the permit;
d. To inspect at reasonable times any collection, treatment, or
discharge facilities; and
e. To sample at reasonable times any discharge of pollutants.
G7. The permittee shall submit a new application or supplement to the
previous application where facility expansions, production increas-
es, or process modifications will (1) result in new or substantially
increased discharges of pollutants or a change in the nature of the
discharge of pollutants, or (2) violates the terms and conditions of
this permit.
G8. After notice and opportunity for public hearing, this permit may be
modified, terminated, or revoked during its term for cause as
follows:
a. Violation of any terras or conditions of the permit;
b. Failure of the permittee to disclose fully all relevant facts
or misrepresentations of any relevant facts by the permittee
during the permit issuance process;
c. A change in any condition that requires either a temporary or a
permanent reduction or elimination of any discharge controlled
by the permit;
d. Information indicating that the permitted discharge poses a
threat to human health or welfare;
e. A change in ownership or control of the source; or
f. Other causes listed in 40 CFR Part 122.62 and 122.63.
Permit modification, revocation and reissuance, or termination may
be initiated by the department or requested by any interested
person.
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Permit No. WA 000109-1
G9. A permittee who knows or has reason to believe that any activity has
occurred or will occur which would constitute cause for modification
or revocation and reissuance under condition G8. or 40 CFR Part
122.62 must report such plans, or such information, to the depart-
ment so that a decision can be made on whether action to modify or
revoke and reissue a permit will be required. The department may
then require submission of a new application. Submission of such
application does not relieve the discharger of the duty to comply
with the existing permit until it is modified or reissued.
G10. If any applicable toxic effluent standard or prohibition (including
any schedule of compliance specified in such effluent standard or
prohibition) is established under Section 307(a) of the Clean Water
Act for a toxic pollutant and that standard or prohibition is more
stringent than any limitation upon such pollutant in the permit, the
department shall institute proceedings to modify or revoke and reis-
sue the permit to conform to the toxic effluent standard or
prohibition.
Gil. Prior to constructing or modifying any waste water control facili-
tie's, detailed plans shall be submitted to the department for ap-
proval in accordance with Chapter 173-240 WAC. Facilities shall be
constructed and operated in accordance with the approved plan.
G12. All other requirements of 40 CFR Part 122.41 and 122.42 are incorpo-
rated into this permit by reference.
G13. Nothing in this permit shall be construed as excusing the permittee
from compliance with any applicable federal, state, or local stat-
utes, ordinances, or regulations.
G14. The department may establish specific monitoring requirements in
addition to those contained in this permit by administrative order
or permit modification.
D-156
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FACT SHEET
Regulatory Action: The Department of Ecology plans to reissue National
"ollutant Discharge Elimination System (NPDES) Dermit .'!o. ',-,'A 3Q0109-" for
;ne pulp, paper and chemical mill operated by the applicant listed below.
Applicant: Georgia-Pacific Corporation
Post Office Box 1236
Bellingham, Washington 98227
Mill Location and Operation: The mill is located in Bellingham on the water-
front of Bellingham Bay. The primary pulp and paper mill products are 620
tons per day of sulfite pulp and 250 tons per day of tissue paper. Pulp mill
byproducts and chemicals produced include ethyl alcohol, concentrated lignin
products, 50 tons per day of sulfuric acid, 220 tons per day of chlorine and
250 tons per day of caustic soda.
'.•Jastewater Treatment and Discnaroe: Mill wastewater receives primary clari-
fication and secondary biological treatment before discharging at a rate of
forty million gallons per day into the Class A water of Bellingham Bay. The
discharge is through an outfall diffuser 2,000 feet long in a water depth of
40 feet about 6,000 feet southwest of the aerated lagoon.
Effluent Limitations: Effluent limitations are proposed primarily on the
basis of guidelines published by the Environmental Protection Agency. These
limitations on an average daily basis for the Georgia-Pacific mill are as
follows:
Biochemical Oxygen Demand 21,900 Ibs. per day
Total Suspended Solids 35,100 Ibs. per day
Total Mercury 0.05 Ibs. per day
pH 5.0 to 9.0
Other Permit Conditions: Other proposed conditions include the following
requirements:
1. Routine monitoring and reporting of discharge characteristics to show
compliance with effluent limitations including a bioassay based
limitation.
2. Maintain and comply with approved plans for spill control and solid
waste control.
3. Develop operating plans for wastewater treatment facilities to show
that facilities are efficiently operated at various production
loadings.
D-157
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GEORGIA-PACIFIC CORPORATION
PULP AND PAPER MILL, BELLINGHAM
NPDES PERMIT SUMMARY
The date of public notice was January 23, 1985 and EPA approval was March 28,
1985. A concern was expressed in the EPA approval letter regarding our method
of determining effluent limitations for a chemi-mechanical pulping process
identified by G-P as Permachem pulp. EPA had agreed this process did not fit
the guideline categories and that limitations would have to be established by
Best Engineering Judgment.
Additional monitoring of Permachem wastewater was conducted by G-P and samples
were split with our lab. A BOD raw waste load was established from this study
but the method of determining treatment efficiency was questioned by EPA.
After several meetings with EPA and G-P, agreement was reached on revised
limitations for Permachem pulp.
Over 90 percent of the pulp produced and the BOD generated is from sulfite
pulping. Consequently, the contribution from Permachem has little effect
on mill total raw waste load. The BOD and TSS limitations are slightly
tighter than the expiring permit. As compliance with these limitations has
been somewhat marginal, G-P will have to continue efforts to control loading
and maintain adequate treatment efficiency.
D-158
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