EPA 910/9-91-022
Puget Sound Estuary Program
Bellingham Bay Action Program:

7997 Action Plan
                          •
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                       :• *
September 1991

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PTI
ENVIRONMENTAL SERVICES
15375 SE 30th Place
Suite 250
Bellevue, Washington 98007
BELLINGHAM BAY ACTION PROGRAM:

 1991 Action Plan


By
Michael A. Jacobson and Patricia A. Canterbury
Prepared for
U.S. Environmental Protection Agency
Region 10, Office of Coastal Waters
1200 Sixth Avenue
Seattle, Washington  98101
EPA Contract 68-D8-0085
PTI Contract C744-24
SeDtember 1991

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Table of Contents
      List of Figures                                                           v
      List of Tables                                                            v
      Acknowledgments                                                        ix
      Executive Summary                                                     xiii
      Introduction	1
             Bellingham Bay Action Program	3
                  Action Plan Development	5
                  Implementation of the Action Plan	6
                  Coordination with Other Areawide Plans and
                  Programs	8
                  Technical Approach for Identifying and Ranking
                  Problem Areas	9
             Overview of Bellingham Bay and Associated Contamination
             Problems	14
                  General Description of Area	14
                  Description of Priority Problem Areas	17
      1991 Action Plan for Bellingham Bay	27
             Comprehensive Plans and Programs	27
                  U.S. Environmental Protection Agency	27
                  Lummi Tribe	29
                  Nooksack Tribe	32
                  Washington Department of Ecology	33
                  Washington Department of Fisheries	39
                  Washington Department of Health	43
                  Washington State Parks and Recreation Commission	46
                  Washington Department of Wildlife	47
                  Washington Department of Natural Resources	48
                  Puget Sound Water Quality Authority	51

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Table of Contents
                  City of Bellingham Department of Planning and
                  Economic Development	54
                  City of Bellingham Department of Public Works	56
                  City of Bellingham Parks and Recreation Department	59
                  Whatcom County Conservation District	60
                  Whatcom County Council of Governments	62
                  Whatcom County Department of Public Works	63
                  Whatcom County Planning Department	65
                  Whatcom County Health Department	66
                  Port of Bellingham	67
                  Washington Sea Grant	70
                  Concerned Southside Citizens	70
                  Georgia-Pacific Corporation	71
                  Maritime Contractors, Inc	73
                  Bellingham Cold Storage	74
                  Bellingham Frozen Foods	75
            Site-Specific Action Plan	76
      Planning and Coordination, Pollution Control, and Data
      Needs	103
            Planning and Coordination Needs	103
            Pollution Control Needs	105
            Data Needs	106
      References                                                              107
      Glossary of Terms                                                       109

      APPENDIX A   Administrative Record of Agency Letters of Commitment
      APPENDIX B   Available Funding Sources:  Urban Bay Action Plan
                     Implementation
      APPENDIX C   Public Involvement Process
      APPENDIX D   EPA Technical Studies in Support  of Urban Bay Programs
                                       IV

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List of  Figures
      Figure 1.  Bellingham Bay study area                                           2

      Figure 2.  Decision points and elements of the Bellingham Bay Action
                Program                                                          4

      Figure 3.  Environmental indicators used to define problem areas of
                sediment contamination and biological effects                          10

      Figure 4.  Classification of stations in inner Bellingham Bay according to
                action criteria                                                     18

      Figure 5.  Major contaminant sources in inner Bellingham Bay                    19

      Figure 6.  Major contaminant sources in outer Bellingham Bay                    21

      Figure 7.  Classification of stations in outer Bellingham Bay according to
                action criteria                                                     22

      Figure 8.  Priority storm drains and creeks for source tracing                     24
List of  Tables	


      Table 1.  Criteria used to define problem areas                                 13

      Table 2.  Source-specific actions                                             77

      Table 3.  Planning and program development actions                            90

      Table 4.  Pollutant control actions                                            93

      Table 5.  Remedial investigations and remedial actions                          97

      Table 6.  Sampling and monitoring actions                                    98

      Table 7.  Resource protection actions                                        100

      Table 8.  Educational actions                                               101

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VI

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List  of Acronyms and  Abbreviations
      AET
      BCS
      BFF
      BMP
      CCMP
      CCWF
      CERCLA

      City Parks
      City Planning

      City Public Works
      COG
      Corps
      County Health
      County Planning
      County Public Works
      CSC
      CSO
      CWA
      DNR
      DOH
      DOT
      EAR
      Ecology
      EIS
      EPA
      FERC
      FWS
      Georgia-Pacific
      CIS
      HPA
      HPAH
      LPAH
      MCI
      MOA
      MTCA
      NEPA
apparent effects threshold
Bellingham Cold Storage Company
Bellingham Frozen Foods, Inc.
best management practice
comprehensive conservation and management plan
Centennial Clean Water Fund
Comprehensive Environmental Response, Compensation and
Liability Act
City of Bellingham Parks and Recreation Department
City of Bellingham Department of Planning and Economical
Development
City of Bellingham Department of Public Works
Whatcom County Council of Governments
U.S. Army Corps of Engineers
Whatcom County Health Department
Whatcom County Planning Department
Whatcom County Department of Public Works
Concerned Southside Citizens
combined sewer overflow
Clean Water Act
Washington Department of Natural Resources
Washington Department of Health
Washington Department of Transportation
elevation above reference
Washington Department of Ecology
environmental impact statement
U.S. Environmental Protection Agency
Federal Energy Regulatory Commission
U.S. Fish and Wildlife Service
Georgia-Pacific Corporation
geographic information system
hydraulic permit approval
high molecular weight polycyclic aromatic hydrocarbon
low molecular weight polycyclic aromatic hydrocarbon
Maritime Contractors, Inc.
Memorandum of Agreement
Model Toxics Control Act
National Environmental Policy Act
                                      VII

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List of Acronyms and Abbreviations
      NPDES
      PAH
      PCB
      PIE
      Port
      PSAMP
      PSDDA
      PSEP
      PSWQA
      PSWQMP
      RCRA
      RCW
      SARA
      SCS
      Sea Grant
      SEPA
      State Parks
      TSCA
      WAC
      WARM
      WDF
      WDW
      WRRLC
      WWTP
National Pollutant Discharge Elimination System
polycyclic aromatic hydrocarbon
polychlorinated biphenyl
Public Involvement and Education
Port of Bellingham
Puget Sound Ambient Monitoring Program
Puget Sound Dredged Disposal Analysis
Puget Sound Estuary Program
Puget Sound Water Quality Authority
Puget Sound Water Quality Management Plan
Resource Conservation and Recovery Act
Revised Code of Washington
Superfund Amendments and Reauthorization Act of 1986
Soil Conservation Service
Washington Sea Grant
State Environmental Policy Act
Washington State Parks and Recreation Commission
Toxic Substances Control Act
Washington Administrative Code
Washington Ranking Method
Washington Department of Fisheries
Washington Department of Wildlife
Waste Reduction Recycling and Litter Control
wastewater treatment plant
                                        VIII

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Acknowledgments
                         This document was prepared by PTI Environmental Services under the
                         direction of Mr. Michael Jacobson. The work was conducted for the
                         U.S. Environmental Protection Agency (EPA) Region 10, Office of
                         Coastal Waters, in partial fulfillment of Contract No. 68-D8-0085. The
                         development of this report was funded  by the National  Estuary
                         Program, under the authority of the Clean Water Act as amended in
                         1987.  Funding was approved by the EPA Office of Marine and
                         Estuarine Protection.  Mr. Michael Rylko served as the project man-
                         ager for EPA Region 10. The primary authors of this report are Mr.
                         Michael A. Jacobson and Ms. Patricia A. Canterbury of PTI Environ-
                         mental Services.  Ms. Lucille Pebles of the Washington Department of
                         Ecology and Mr. Michael Rylko of the U.S. Environmental Protection
                         Agency contributed Tables 3-8 of the site-specific action plan and
                         the Planning and Coordination, Pollution Control, and Data Needs
                         section.

                         The Bellingham Bay  Action Program has benefitted from the
                         participation of members of the Bellingham Bay Interagency and
                         Citizen Work Group. Duties of the work group include  1) review-
                         ing program documents, agency policies, and proposed  actions; 2)
                         providing data reports and other technical information to EPA; and
                         3) disseminating action program information  to constituencies or
                         interest groups.  The past and continuing efforts of the interagency
                         and citizen work group are greatly appreciated. Special thanks are
                         extended to Dr. Fran Solomon, the former Bellingham Bay Action
                         Program coordinator,  and to Ms. Lucille Pebles, the current Bel-
                         lingham Bay Action Program coordinator, for chairing the work
                         group activities. Members of the Bellingham Bay Interagency and
                         Citizen Work Group are listed below. Where two individuals are
                         listed, the second individual is an alternate or new staff member.
          Bellingham Bay Interagency and Citizen Work  Group

                                                                          Phone
      Name                           Affiliation                          Number

Jacqueline Anderson        Concerned Southside Citizens                      676-5254
Bert Brainard              Whatcom County Health Department                676-6724
MikeBrennan              Whatcom Chamber of Commerce                   734-1330
Peggy Britt/               Washington Parks and Recreation Commission       586-2283
Doug Strong
                                         IX

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Acknowledgments
     Name
             Affiliation
  Phone
 Number
Michael Clausen
Marc Crooks, P.E./
Don Kjosness
Ed Dahlgren/
John Anderson
Bruce Dierking
Don Ellis, P.E./
Jim Darling
Byron Elmendorf
Dr. Jacques Faigenblum
Lois Garlick

Jack Garner, P.E.
Bill Geyer/
Chris Spens
David Green
Diane Harper/
Sue Blake
Walt Ingram
Dr. Dave Jamison/
Betsy Striplin
Tip Johnson
Arnie Klaus/
Jackie Peyton
Ernst Limbacher
Mike MacKay
Don Melvin/
Linda Klote
Ed Melvin
Greg Mills
Jerry Mixon/John Tyler
Lucille T. Pebles, P.E.

Becky Peterson
Pat Petuchov
Bellingham Cold Storage
Washington Department of Ecology - Industrial
Section
Georgia-Pacific Corporation

Bellingham Yacht Club
Port of Bellingham

Bellingham Parks and Recreation Department
Washington Department of Ecology
Senior citizen - retired - Western Washington
University
Bellingham Department of Public Works
Bellingham Planning and Economic
Development Department
Bellingham Frozen Foods
Whatcom County Planning

Citizen
Washington Department of Natural Resources

Bellingham City Council
Puget Sounders

Retired fisherman
Lummi Fisheries
Washington Department of Health

Washington Sea Grant
North Cascades Audubon Society
Whatcom County Public Works
Washington Department of Ecology - Northwest
Regional Office
Whatcom County Council of Governments
Nooksack Fisheries
733-1640
586-0524

733-4410

733-7390
671-6411

676-6985
649-7275
676-9111

676-6961
676-6982

734-4040
676-67561
676-6724
671-9776
5S6-2653/
753-0263
676-6970
676-8094

734-6111
647-6230
586-44S4/
586-8736
676-6429
855-1694
676-6907
649-7272

676-6974
592-5176

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                                                                  A ckno wledgments
    Name
            Affiliation
 Phone
Number
Vallana Piccolo
Mike Rogers
Dale Ross
Paul Schissler
Mark Schuller
Dr. Fran Solomon

Art Stendal
Dr. Bill Summers
Chuck Timblin
Dirk Visser
Mike Walsh
Dr. Bert Webber
Brian Williams
Puget Sound Water Quality Authority                493-9300
Maritime Contractors, Inc.                         647-0080
Northwest Steelhead and Salmon Council            734-8724
Fairhaven Neighbors                              671-7300
Washington Department of Fisheries                428-1520
Washington Department of Ecology - Northwest       649-7219
Regional Office
Washington Department of Wildlife                 424-1260
Squalicum Beach Neighbors                        676-3690
Whatcom County Conservation District              354-2035
Inner Sound Crab Association                      734-1509
Puget Sound Gillnetters                            647-1764
Huxley College - Western Washington University       676-3509
Washington Department of Fisheries                339-3881
                                         XI

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XII

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Executive Summary
                          Previous studies of Bellingham Bay have revealed widespread
                          chemical contamination of sediment and marine organisms, bacte-
                          rial contamination, and low levels of dissolved oxygen in the water
                          in urban areas of the bay.  Chemical contamination and low oxygen
                          levels pose hazards to the aquatic ecosystem. Toxic contamination
                          may decrease the abundance and diversity of benthic invertebrate
                          organisms, increase the prevalence of tissue disorders such as liver
                          tumors in fish, and result in the accumulation of chemicals in fish
                          and  shellfish.  Chemical and  bacterial contamination  may pose
                          human health risks when contaminated fish and shellfish are eaten.
                          Chemical and bacterial contamination may also result in the closure
                          of commercial and recreational shellfish harvesting areas.

                          The Washington Department of Ecology and the U.S. Environmen-
                          tal Protection Agency,  working with the Washington Departments
                          of Natural Resources, Fisheries, and Health; the Puget Sound Water
                          Quality Authority; the City of Bellingham; the Port of Bellingham;
                          Whatcom County; the Lummi and Nooksack tribes; and local
                          industries and concerned citizens, developed the Bellingham Bay
                          Action Plan to address water quality problems in Bellingham Bay.

                          Bellingham Bay has been the focus of studies since 1988 under the
                          U.S. Environmental Protection Agency's Urban Bay Action Pro-
                          gram. The Urban Bay Action Program 1) identifies priority prob-
                          lem areas of contamination; 2) identifies current, historical, and
                          potential sources of contaminants; 3) establishes schedules to take
                          corrective actions to eliminate existing problems and to  investigate
                          potential problems; and 4) identifies appropriate agencies and
                          mechanisms for implementing corrective actions. Ongoing coordi-
                          nation among participating agencies and citizens will be provided
                          by the Washington Department of Ecology, which funds a full-time
                          coordinator for the Bellingham Bay Action Program. Authority for
                          implementation of the 1991 Action Plan is derived from various
                          federal,  state, and local environmental regulations and is specified
                          under the industrial and municipal discharge control element (P-13)
                          in the Puget Sound Water Quality Management Plan.

                          In 1989, the U.S. Environmental Protection Agency analyzed all
                          existing data on adverse  biological effects, chemical and bacterial
                          contamination, and eutrophication for Bellingham Bay.  Eutrophi-
                          cation is the biochemical process  that results in high levels of
                                                      XIII

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Executive Summary
                           nutrients and low levels of dissolved oxygen in water.  In the
                           Bellinghom Boy Action Program:  Data Summaries and Problem
                           Identification report, the existing data were summarized and priority
                           problem areas were identified. For example, areas received a high
                           priority ranking for action if they exhibited particularly high levels
                           of contamination or adverse biological effects  such as high mortality
                           rates of organisms in sediment toxicity tests. The regulatory and
                           management efforts of the 1991 Action Plan  focus on sources that
                           are most directly related to priority problem  areas.

                           Four problem areas for chemical contamination have been identified
                           for Bellingham Bay.  The four areas  are the mouth of Whatcom
                           Creek, the area near the Georgia-Pacific Corporation outfall dis-
                           charge, the area immediately inshore of the terminus of the Post
                           Point wastewater treatment plant outfall, and a small area off the
                           Fairhaven  shoreline. Another potential problem area has also been
                           identified.  This large area extends from the  Squalicum  Marina to
                           the Whatcom Creek Waterway, along the eastern  shoreline of
                           Bellingham Bay, and then out into the central part of the  bay.  This
                           potential problem area surrounds and includes the four smaller
                           problem areas.

                           Actions to correct problems can include remedial (cleanup) activi-
                           ties such as source control and sediment cleanup activities.  Con-
                           trolling  individual sources may be accomplished by increasing
                           controls on existing permits,  locating and investigating currently
                           unpermitted discharges, and developing specific contaminant con-
                           trol techniques such as best management practices. Source control
                           efforts include reducing concentrations or volumes of discharges to
                           prevent  further environmental  problems.   Sediment  remedial
                           actions, such as removal or capping of contaminated sediments, can
                           correct existing environmental problems.

                           The action plan specifies a broad array of actions designed to
                           improve the environmental quality of Bellingham Bay.  These
                           actions include the following:

                              •  Planning and Program Development Actions—The
                                 Urban Bay  Action Program, as outlined in  the 1991
                                 Action Plan, integrates local planning activities, ensures
                                 consistency among the various environmental programs,
                                 and provides a mechanism for public review to  ensure
                                 accountability for implementation of agency activities.
                                                       XIV

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                                           Executive Summary
   •  Pollution  Control Actions—The  Whatcom  County
      Health and Public Works departments will investigate
      onsite sewage disposal systems.

   •  Remedial  Actions—The  Washington Department of
      Ecology will conduct initial investigations of industrial
      and commercial facilities and waterways.

   •  Sampling  and Monitoring Actions—The City of Bel-
      lingham Department of Public Works will expand its
      creek monitoring program to further characterize water
      quality in the city's creeks and streams and to determine
      the sources of contaminants.

   •  Resource Protection Actions—The Washington depart-
      ments of Wildlife and Fisheries will  assist in the protec-
      tion  of  fisheries  resources and wildlife habitat  by
      reviewing  permits for construction affecting state
      waters, including wetlands.

   •  Educational Actions—The City of Bellingham Parks and
      Recreation Department will provide interpretive dis-
      plays for watersheds along trails adjacent to rivers,
      creeks, streams, and public waterfront areas.

The 1991 Action  Plan is a working document that will be refined
as new data are made available.  An interagency urban bay action
team, composed of technical and planning  staff from local, state,
tribal, and federal agencies, will meet four to six times per year to
coordinate action plan implementation, review progress made on
implementation, resolve any problems, and refine the plan to reflect
new information and activities. A Citizen's Advisory Committee
will meet four to six times per year to evaluate action plan
implementation, determine appropriate citizen activities, and pro-
vide input to the  action team.  The  Washington Department  of
Ecology's Action Program Coordinator has responsibility for the
long-term coordination of the action plan  and implementation of
source control actions.
                             xv

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Introduction
                          In response to widespread concern over the environmental health
                          of Puget Sound, several agencies with regulatory, resource manage-
                          ment, and research responsibilities initiated the Puget Sound Estuary
                          Program (PSEP) in 1985.  The primary objectives of PSEP are to
                          protect the sound and its living resources and to improve the
                          condition of contaminated areas.  As a primary element of PSEP,
                          the Urban Bay Action Program was established to address the most
                          severe contamination problems in Puget Sound, which occur in
                          embayments near urban areas.

                          The Urban Bay Action Program focuses on identifying and reducing
                          chemical and bacterial contamination and eutrophication through a
                          series of coordinated actions by government agencies and respon-
                          sible parties (e.g., owners and operators of the facilities that are
                          sources of contamination).  Contaminant control activities may
                          include improving drainage or treatment systems for storm water
                          and sewage, developing stricter permit conditions for wastewater
                          dischargers, enforcing hazardous materials regulations, and initiat-
                          ing best management practices (BMPs) or cleanup measures at sites
                          of concern. A guidance document, The Urban Bay Action Program
                          Approach: A Focused Toxics Control Strategy (PTI1990) describes
                          the overall goals and specific actions of the Urban Bay Action
                          Program in more detail.

                          Under the Urban Bay Action Program, Bellingham Bay was selected
                          in October 1988 as a priority area for problem identification and
                          corrective action planning.  Bellingham Bay is an embayment in
                          northern  Puget Sound with the city of Bellingham located at its
                          northeastern corner (see Figure 1). In August 1989, an initial data
                          summary and problem identification report (PTI 1989a) was com-
                          pleted for Belb'ngham Bay.  This report summarized data collected
                          primarily from 1980 to 1989 and identified problem areas and
                          known and potential contaminant sources. This 1991 Bellingham
                          Bay Action Plan is based on the data summary report and on
                          extensive discussions  with federal and state resource and regulatory
                          agencies, local industries, concerned citizens, city and county
                          government agencies, and tribes that have responsibility for pro-
                          tecting the environmental quality of Bellingham Bay and Puget
                          Sound as  a whole.

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PROJECT
LOCATION
                                                                              	Bellingham city limits
  Figure 1. Bellingham Bay study area.
                                                                                                    C744-24O991

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                                                 Introduction
This action plan describes the comprehensive plans and programs
that address contaminant sources and problem areas on an areawide
basis, and the individual corrective actions developed for specific
sites and sources.  Recommended corrective actions are described
for each problem area and potential contaminant source.  Problem
areas and sources were identified by PTI (1989a) and participating
agencies during the development  of the action plan.   For each
problem area and associated contaminant sources, the action plan
specifies 1) the first steps toward corrective actions, 2) the agencies
responsible for implementing those actions, 3) targeted implementa-
tion  schedules, and 4) any factors that may limit effective imple-
mentation of a given task.   The  remainder of this introduction
provides  a description of the Urban Bay Action  Program and an
overview of Bellingham Bay and its associated contamination problems.
Bellingham Bay Action Program

The Bellingham Bay Action Program was initiated by PSEP in
October 1988. PSEP consists of the U.S. Environmental Protection
Agency (EPA), the Washington Department of Ecology (Ecology),
and the Puget Sound Water Quality Authority (PSWQA).  Through
a process of interagency coordination, local government support,
and public participation, the Bellingham Bay Action Program has
focused new and continuing efforts to control contaminant sources
within the priority problem areas of the bay.  The objectives of the
action program are to:

   •   Identify specific areas  of concern based on levels of
       chemical and bacterial contamination and eutrophication
       and associated adverse biological effects and impacts to
       natural resources

   •   Identify historical and ongoing sources of contamination
       and eutrophication

   •   Rank contaminated areas and sources to set priorities for
       development of corrective actions

   •   Implement corrective  actions to reduce or eliminate
       sources of chemical and  bacterial contamination and
       eutrophication and restore contaminated areas to support
       natural resources and beneficial uses.

The major decision points and program elements of the Bellingham
Bay Action Program are presented in Figure 2.

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                            Evaluate Available
                               Information
                              Initial Problem
                               Identification
Sampling and
Analysis



,— ^
Action piart



                                Sediment
                              Management
Potential Action
 Team Activities

Source Control
Permitting
Inspections
Enforcement
Sediment Remedial
Planning
                              Environmental
                            Monitoring Program
                              Action Program
                                Evaluation
                     Major input and decision points for the interagency
                     work group and the citizen advisory committee
                |   |  Elements of the Urban Bay process
Figure 2.  Decision points and elements of the Bellingham Bay Action Program.
                                                                                    C744-24 0991

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                                                                            Introduction
                           The Bellingham Bay Action Program has followed a process in
                           which cooperative efforts by federal, tribal, state, and local offi-
                           cials; local industries; and concerned citizens have helped to define
                           problem areas, focus environmental monitoring efforts, and plan
                           and implement corrective actions.  Coordination is fostered through
                           an interagency and citizen work group.  The work group is com-
                           posed of representatives from federal, state, and local agencies; the
                           Lummi and Nooksack tribes; local industry; and concerned citizens.
                           The work group has been responsible for reviewing documents and
                           providing input to the planning process.
Action Plan               The process for development of the 1991 Bellingham Bay Action
Development             Plan  was completed  in  several stages.  First, existing  data on
                           chemical and bacterial contamination and eutrophication were col-
                           lected and analyzed to identify and prioritize problem areas (PTI
                           1989a).  Next, individual meetings were held with each agency or
                           group within the work group to determine their current or planned
                           actions to improve water quality in Bellingham Bay. Following the
                           meetings, a "contaminant-source action matrix" was developed and
                           presented to the work group.  The matrix presented the types of
                           environmental problems and associated actions that agencies were
                           implementing to address contamination problems.  In addition, the
                           matrix served to identify gaps in management programs, contami-
                           nant source control, and data collection efforts. Following presen-
                           tation of the matrix, agency representatives were again consulted to
                           cooperatively negotiate how each agency would commit resources
                           to help implement additional preventative or corrective actions or
                           gather information to fill data gaps. Ecology then sent letters to
                           confirm agency commitments.  These letters and agency replies
                           constitute the administrative record for the Bellingham Bay Action
                           Plan  and are contained in Appendix  A.  A second work group
                           meeting will be held to review and discuss the commitments of each
                           agency  and to  further enhance interagency communication and
                           coordination. The action plan will be continually reviewed as new
                           data  become available to refine the definition of environmental
                           problem areas and contaminant  sources, and as agency action
                           agendas evolve.

                           This  action plan focuses on contaminant source control to minimize
                           inputs of contaminants and serves as a blueprint for source control
                           activities, including field investigations and permit reviews.  Other
                           corrective actions may also be specified, including alternatives for
                           cleaning up contaminated sediments and environmental monitoring
                           to evaluate the  success of source control.  Examples of sediment
                           cleanup activities include capping contaminated sediments with

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Introduction
                          uncontaminated materials or removing the contaminated sediments
                          by dredging. Because these activities are most likely to be imple-
                          mented only after significant source control (to minimize the
                          probability of future recontamination and additional cleanup), sed-
                          iment cleanup is likely to be a long-term rather than short-term
                          component of the Bellingham Bay Action Program.  Monitoring is
                          also a long-term component of the action program.   Existing
                          monitoring programs will be coordinated and the data will be used
                          to evaluate the effectiveness of source control and sediment reme-
                          diation (see Figure 2).
Implementation of
the Action Plan
In 1988, EPA formally designated Puget Sound as an estuary of
national significance under the federal Clean Water Act (CWA).
Section 320 of the CWA requires the development of a comprehen-
sive conservation and management plan (CCMP) for each desig-
nated estuary. The 1991 Puget Sound Water Quality Management
Plan (PSWQMP), developed by PSWQA, meets all the require-
ments of a CCMP.  Development of the PSWQMP is conducted
under Section 90.70 of the Revised Code of Washington (RCW).
Element P-13 of the 1991 PSWQMP states that the "urban bay
approach" is an essential part of a comprehensive strategy to control
sources of toxic contamination. Implementation of the Bellingham
Bay Action Plan and other urban bay action plans is part of the
overall implementation of the PSWQMP.
Regulatory Authority
Ecology, EPA, and many other agencies have regulatory authority
to implement specific  elements of the 1991 action  plan.  This
regulatory authority stems from discharge permit programs and
inspection requirements under federal and state water  quality regu-
lations such as the CWA and the state Water Pollution  Control Act.
Additional authority is derived from hazardous substance control
regulations, such as the federal Comprehensive Environmental
Response, Compensation and Liability Act [CERCLA (also known
as Superfund)] as reauthorized  by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), federal Resource Conser-
vation and Recovery Act (RCRA), federal Toxic Substances Control
Act (TSCA), state Model Toxics Control Act (MTCA), county
regulations for solid waste and hazardous waste, and health depart-
ment regulations. Other important laws include the state combined
sewer overflow (CSO) control  regulation, the state Shoreline Man-
agement Act, the State Environmental Policy Act (SEPA), and the
National  Environmental  Policy Act  (NEPA).   In addition,  the
Washington Aquatic Lands Act provides the Washington Depart-

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                                                                           Introduction
                           ment of Natural Resources (DNR) with proprietary authority to
                           manage the state's aquatic lands in trust for the public.

                           Under several of the above regulations, Ecology is responsible for
                           issuing and revising wastewater and industrial waste discharge
                           permits, conducting site inspections, and overseeing cleanup plans
                           for contaminated sites.  Ecology also has regulatory authority over
                           storm drains that discharge to state waters.
Action Team
Development
As part of the Bellingham Bay Action Program, Ecology will
establish and  lead an interagency action team to guide the
implementation of the action plan.  The Bellingham Bay Action
Team is a subset of the interagency and citizen work group and will
include technical staff from local, state, tribal, and federal agencies.
Agencies represented may include the City of Bellingham Depart-
ment of Public Works (City Public Works), the Whatcom County
Department of Health (County Health), the Whatcom County
Department of Public Works (County Public Works), the Washing-
ton Department of Health (DOH), the Lummi and Nooksack tribes,
and EPA.

Local governments are key participants in following through on the
activities of the action plan.  City and county agencies responsible
for source control and remedial activities include City Public
Works,  County Health, and County Public Works.   These three
agencies are responsible for a wide variety of activities crucial to
the success of the action plan, such as controlling municipal and
industrial wastewater effluent and  storm water quality.   Other
agencies [e.g., the Port of Bellingham (Port) and DNR] and private
companies are responsible for contaminant prevention and control
relevant to the activities on their property. Ensuring that agencies
and companies comply with environmental regulations is an import-
ant element of the action plan.
Enforcement
Ecology can ensure implementation of the action plan through legal
enforcement procedures such as warning letters, notices of viola-
tion, penalties, and administrative orders. However, the preferred
approach to implementing the action plan is to work cooperatively
with all involved parties.  Voluntary commitment to perform the
actions in the action plan is the most efficient and cost-effective
approach to reducing point and nonpoint contaminant sources
impacting Bellingham Bay. Successful implementation of the action
plan will require the cooperation of all parties within the Bellingham
Bay watershed.

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Introduction
Funding
Successful implementation of the action plan also depends on
adequate funding.  The Washington State Legislature and  U.S.
Congress have passed major legislation designed to protect water
resources. This legislation includes the federal CWA and the state
Centennial Clean  Water Fund  (CCWF),  the  Aquatic Lands
Enhancement Account, and the Coastal Zone Management Pro-
gram.  Various grants and low-interest loans are available through
programs administered through the  above-mentioned laws.  (See
Appendix B for a more thorough discussion of potential funding
sources.)
Public Involvement
Public involvement in government decision-making is a critical
component to the success of the action plan.  The public is encour-
aged to comment on all actions  that may affect water quality in
Bellingham Bay.  The major programs that relate to water quality
include the Shoreline  Management Act,  SEPA,  MTCA,  the
National Pollutant Discharge Elimination System (NPDES), and the
Puget Sound Dredged Disposal Analysis (PSDDA). Public involve-
ment processes for these programs are described in more detail in
Appendix C.
Future Activities
After the action plan is finalized, the action team will meet four to
six times per year to advise and assist in carrying out specific
actions, solve any problems that arise, evaluate the effectiveness of
the various implementation strategies, and maximize interagency
coordination.  It is anticipated that revisions and updates to the
action plan will be produced every 4 years.

Ecology will continue to involve representatives from environmen-
tal, business, recreational, civic, educational, and neighborhood
groups through the  citizen advisory committee.  This advisory
committee will 1) identify public concerns and issues relevant to
agency actions set forth in the action plan, 2) disseminate action
plan information to  members of organizations represented on the
committee, 3) review work products and attend scoping meetings,
and 4) help  ensure that agencies perform the remedial actions or
investigations for which they are responsible.
Coordination with
Other Areawide
Plans and Programs
Coordination of the Bellingham Bay Action Program with other
planning and management programs is another component required
for timely and effective implementation.  The PSWQMP and the
watershed management planning process are areawide programs
that will be coordinated with the Bellingham Bay Action Program.
                                                       8

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                                                                           Introduction
                          PSWQA oversees  and coordinates the PSWQMP,  which  is
                          implemented by state agencies, local governments, and other par-
                          ties. Activities described in the areawide plans and programs of the
                          action plan are consistent with the PSWQMP.  Coordination  of
                          PSWQA-directed activities with the urban bay program occurs
                          through the Bellingham Bay Interagency and Citizen Work Group
                          meetings. PSWQA will actively participate as an interagency work
                          group member through work group and action team meetings.

                          In addition to the PSWQMP, other local or subject-specific plans
                          and programs that may have an impact on Bellingham Bay also
                          require  coordination with the Bellingham Bay Action Program.
                          Activities associated with these other programs will be coordinated
                          by the Bellingham Bay Action Program Coordinator and  staff
                          members of the various agencies involved.  The Bellingham Bay
                          Action Program Coordinator will attend relevant planning meetings
                          and also review and comment on  draft plans developed through
                          these programs. In addition, some agencies  will have representa-
                          tives on the Bellingham Bay Action Team. (See the Comprehensive
                          Plans and Programs section for a more detailed discussion of these
                          plans and programs.)
Technical Approach
for Identifying and
Ranking Problem
Areas
The Urban Bay Action Program relies on a "preponderance-of-evi-
dence" approach to identify and rank contaminated problem areas
and contaminant sources.  Selected chemical, biological, and toxi-
cological indices are used to compare conditions at contaminated
sites with reference conditions in relatively uncontaminated embay-
ments. The contaminated sites then receive a priority ranking. The
rankings are used to determine the order in which problem areas
will be evaluated for source control and possible remedial actions.
Study areas that exhibit high values of contamination and adverse
biological effects receive a ranking of high priority. The following
types of environmental indicators are generally used to identify and
rank problem areas (see also Figure 3):

   •   Sediment Chemistry

       -  Concentrations of metals and organic compounds
       -  Conventional sediment variables (e.g., grain size
          distribution, total organic carbon)

   •   Bioaccumulation

       -  Chemical concentrations in clams and fish

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                                 SEDIMENTS
  Chemistry

Cl        Cl
Cl        Cl
Bioaccumulation
                          Bioassays
                       Infauna
                                    WATER
        Fecal Coliform Bacteria
      Conventional Variables
                                                  JAN      Dissolved Oxygen      DEC
       Figure 3.  Environmental indicators used to define problem areas of sediment
                and water contamination and biological effects.
                                                                              C744-24 0991
                                        10

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                                                 Introduction
   •  Sediment Bioassays

      -   Amphipod mortality (10-day bioassay)
      -   Oyster larvae abnormality (48-hour bioassay)

   •  Benthic Infauna Abundance

      -   Polychaete abundance
      -   Pelecypod abundance
      -   Gastropod abundance
      -   Crustacean abundance

   •  Fish Histopathology

      -   Lesion (e.g., tumor) prevalence in livers, kidneys,
          and gills of English sole

   •  Bacterial Measurements

      -   Fecal coliform bacteria in water and shellfish

   •  Conventional Water Quality Variables

      -   Concentrations of dissolved oxygen
      -   Concentrations of nutrients (i.e., nitrogen, phosphorus).

Each of the above indicators is used to assess different environmen-
tal impacts.  Measurements of contaminant concentrations in sedi-
ments are used to characterize the degree of contamination and to
trace contaminant sources. Measurements of contaminant concen-
trations in tissues of aquatic organisms are used to identify large-
scale problem areas and potential human health risks.  Sediment
bioassays and counts of sediment-dwelling organisms are each
valuable for characterizing effects of contamination at specific
sampling locations.  In characterizing large-scale problem areas,
measurements of lesions in fish are useful.  Synoptic measurements
of sediment chemistry, bioassays, and benthic community analyses
are often used together to characterize toxic problem areas in Puget
Sound  (Chapman et al.  1985; PTI  and Tetra Tech  1988a,b).
Bacterial measurements are used to assess microbial contamination
of water and shellfish and potential human health risks.  Measure-
ments of conventional  water quality variables are used to assess
eutrophication.

Identification and prioritization of problem areas for Bellingham
Bay included calculations of elevation above reference (EAR)
values, and comparison of existing data with sediment quality
                             11

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Introduction
                           criteria [i.e., apparent effects threshold (AET)] and regulatory
                           standards.   EAR values are generated by dividing  the measured
                           value by a reference value that is representative of contaminant
                           concentrations in nonurban areas.  Puget Sound AET values were
                           also  used as sediment quality values to evaluate chemical data
                           relative to predicted biological effects.  AET values are chemical-
                           specific sediment concentrations above which a particular adverse
                           biological effect is predicted to occur with a statistical significance
                           of P < 0.05 for a given data set. Because AET values are predictive,
                           they are especially useful in interpreting historical data on sediment
                           contaminant levels where biological data are not available.  In the
                           future, sediment management standards [Chapter 173-204 of the
                           Washington Administrative Code (WAC)] recently adopted by
                           Ecology will be used to determine areas of sediment contamination.
                           Microbial and water quality parameters were evaluated and com-
                           pared with established state and federal standards to rank problem
                           areas for microbial contamination.  Criteria  that were  used  in
                           determining problem  and potential problem areas are presented in
                           Table 1.

                           All of the available indicators of eutrophication, microbial contam-
                           ination, and chemical contamination in sediments and biota were
                           integrated to identify problem areas in  Bellingham Bay.  Because
                           there were insufficient data on chemical contamination in the water
                           column, bioaccumulation, and fish histopathology, these three types
                           of indicators were not used to identify problem areas in BeUingham
                           Bay.  Other data gaps hindered identification of problem areas in
                           some portions  of the bay and prioritization of problem areas
                           throughout the bay.  For example, there was limited information
                           concerning contaminant inputs from the Nooksack River and storm
                           drains.   Numerous indicators of contamination such as  sediment
                           concentrations  of organic  compounds,  sediment  toxicity,
                           bioaccumulation, and fish pathology were lacking. Also, informa-
                           tion about the geographic extent and biological effects of contami-
                           nation was limited.  As a result of these data gaps, problem ar
                           in Bellingham Bay could not be ranked numerically, and thus w
                           designated as problem areas or potential problem areas. Numeric
                           ranking or prioritization of problem areas would be possible with
                           more data.   The results of  the problem area identification are
                           presented in the Description of Priority Problem Areas section.
                                                        12

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                 TABLE 1.  CRITERIA USED TO DEFINE PROBLEM AREAS
           Classification
                Condition Observed
 Problem station for chemical con-
 tamination
 Problem station for microbial con-
 tamination
 Problem station for eutrophication
 Potential problem station for
 chemical contamination
Chemical8 concentration > HAETb or amphipod mortal-
ity > 50 percent or benthic depression0 > 95 percent

Chemical concentration  >LAETb and amphipod  mor-
tality is significant*1, but < 50 percent

Chemical concentration > LAET and benthic depression
>80 percent, but <95 percent

Fecal  coliform  bacteria  concentration  greater  than
Washington Class A  and B water  quality  standards
(Class A standard =  14 organisms/100 mL,  Class B
standard = 100 organisms/100 mL)

Fecal coliform bacteria concentration greater than U.S.
Food and Drug  Administration tissue standard  concen-
tration (230 organisms/100 grams tissue)

Dissolved oxygen concentration less than Washington
Class A  water quality standard (6.0 mg/L)

Chemical concentration > LAET or amphipod mortality
is significant, but  <50 percent  or benthic depression
> 80 percent, but < 95 percent
a Any single metal or organic compound.

b HAET - highest apparent effects threshold for all Puget Sound indicators
  LAET - lowest apparent effects threshold for all Puget Sound indicators.

0 Any major taxon; abundance depression relative to value observed in reference area (i.e., abundance
at impacted station <5 percent of abundance at reference station).

d Significantly different (P^O.05) from mortality using reference area sediment.
                                            13

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Introduction
                          Overview of Bellingham Bay and Associated
                          Contamination Problems

                          This section describes the project area and summarizes information
                          about the contamination and eutrophication problems in Bellingham
                          Bay.  Additional detail on these topics can be found in Bellingham
                          Bay Action Program: Initial Data Summaries and Problem Identi-
                          fication (PTI 1989a).
General Description      Bellingham Bay is a relatively large embayment located in the most
of Area                  northern part of Puget Sound, approximately 24 km south of the
                          United States-Canada border (Figure 1).  For the purposes of the
                          urban bay program, the bay was defined by a line drawn from Point
                          Frances to Governors Point, and includes Chuckanut Bay and
                          Portage Bay. Bellingham  Bay is approximately 12 km long and
                          8- 9 km wide. Waters of the bay are, for the most part, less than
                          30 meters deep.  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 Nooksack River watershed
                          is the largest source of fresh water [85 m3 (-3,000 ft3/sec)] and
                          sediment (—650,000 m /yr) input to the bay, although additional
                          drainage comes from seven other small watersheds.  Bellingham
                          Bay receives drainage from an area of 1,679 km .

                          Bellingham Bay is used for many activities requiring a high level
                          of environmental quality,  including commercial and recreational
                          fishing, shellfish harvesting, aquaculture, boating,  wildlife habitat,
                          and  water contact  recreation (e.g.,  swimming).   Commercially
                          important anadromous fish resources in the study area include
                          chinook, coho, pink, sockeye, and chum salmon; cutthroat and
                          steelhead trout; Dolly Varden; and longfin smelt.   Commercially
                          important marine fishes in  Bellingham Bay include Pacific herring,
                          Pacific cod, various rockfish, lingcod, rock sole, English sole, and
                          starry flounder.  Shellfish species harvested in the bay include
                          Dungeness crab; Pacific oysters; and native littleneck, Manila,
                          horse, and butter clams.  The  total commercial catch of salmon,
                          marine fish, and shellfish from Bellingham Bay in 1983 was
                          approximately 3.1 million pounds, with a value of approximately
                          $2.75 million. At least four species of marine mammals have been
                          documented to exist in the  vicinity of the bay including harbor seal,
                          harbor porpoise, killer whale, and gray whale.  Additional species
                          that may occur in the bay on rare occasions include the California
                          sea  lion,  northern  sea lion, Dall's porpoise,  and minke whale.
                          Although Bellingham Bay  is not used extensively by large popula-
                                                       14

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                                                 Introduction
tions of waterfowl, the bay does lie 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 such as marinas, boat ramps, and
shoreline parks are located in the study area, primarily in inner
Bellingham Bay.

Most of the urban and industrial activity in watersheds affecting
Bellingham Bay is confined to the area near the city of Bellingham.
The shoreline of the city of Bellingham has been influenced by
extensive shoreline modifications (i.e., dredging and filling) to
accommodate commercial and industrial uses.  The area includes
three federally maintained waterways:  Squalicum Creek, I & J
Street, and Whatcom Creek waterways. Intertidal areas presently
occupy approximately 42 km2  of Bellingham Bay. Approximately
1.4 km2 of the original intertidal areas in inner Bellingham Bay have
been filled.

As a result of urban and industrial influences, localized areas of
Bellingham Bay are contaminated with bacteria and toxic chemicals.
The bay may also be subject to eutrophication. Studies have shown
that chemical and bacterial contamination and low oxygen levels in
Bellingham Bay have resulted  in stresses to the ecosystem and
restrictions on beneficial uses.

As discussed in Bellingham Bay Action Program:  Initial Data
Summaries and Problem Identification (PTI 1989a), several studies
on bioaccumulation  and  sediment toxicity, and surveys  of
macroinvertebrate assemblages have been conducted in Bellingham
Bay.  They were conducted throughout the study area identified in
Figure 1, and the primary media sampled were sediment, shellfish,
and macroinvertebrates.  These studies and surveys do not provide
a complete assessment of the bay because there are insufficient data
regarding contaminant sources  from  the Nooksack River system and
storm drains, organic compounds in sediment, sediment toxicity,
bioaccumulation, and fish pathology.   Recommended actions to
collect additional data include 1) conduct vertical profiles of sedi-
ment contamination at selected locations in  Bellingham Bay, 2)
conduct sampling at additional stations near potential contaminant
sources or in areas that have not been sampled previously (e.g.,
Squalicum Harbor marina, mouth  of Nooksack River, nearshore
and shallow areas), and 3) conduct sampling for a greater range of
chemicals such as pesticides, dioxin, tributyltin, and compounds
                             15

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Introduction
                          characteristic of pulp mill discharges (e.g., alkylated phenols,
                          guaiacol, and resin acids).
Chemical
Contamination
Sediment in inner Bellingham Bay, near the cities of Bellingham
and Fairhaven, exhibit significant chemical contamination.  Based
on information contained in Bellingham Bay Action Program:
Initial Data Summaries and Problem Identification (PTI 1989a),
levels of low molecular weight polycyclic aromatic hydrocarbons
(LPAHs) and high molecular weight polycyclic aromatic hydrocar-
bons (HPAHs) in sediment were significantly elevated at all Bel-
lingham Bay stations, mercury in  sediment was elevated at 78
percent of the Bellingham Bay stations, and levels of several HPAH
compounds were elevated above reference values by 100-139
times.  Numerous stations exhibited significant contamination for
polychlorinated biphenyls (PCBs) and metals such as lead, arsenic,
and zinc.   Based on the Puget Sound  marine sediment cleanup
screening levels identified in the state sediment management stan-
dards, numerous areas in Bellingham Bay may be considered as
candidate areas for sediment cleanup activities.

Other measures of chemical contamination include bioaccumula-
tion, sediment toxicity, and decreases in the numbers of benthic
organisms.  Past bioaccumulation information indicates that mer-
cury contamination in species collected from Bellingham Bay is
elevated above reference area levels and is widely distributed
throughout the bay.  Significant sediment toxicity was found at
several stations, and decreases in the numbers of benthic organisms
were noted at numerous stations.
Bacterial
Contamination
Concentrations of fecal coliform bacteria, used as an indicator of
other disease-causing organisms, have been found to exceed state
water quality standards. In addition, freshwater creeks entering the
bay are contaminated by fecal coliform bacteria. All freshwater
stations evaluated and one shellfish sample exceeded state or federal
standards for fecal coliform bacteria in water and shellfish tissue.
Eutrophication
Information on eutrophication in Bellingham Bay indicates that
dissolved oxygen levels in several locations have fallen below state
water quality standards (6.0 mg/L). Low dissolved  oxygen con-
centrations cause physiological stress to organisms living at, near,
or in the bottom of Bellingham Bay and may exacerbate stress from
toxic contamination. In areas with extremely low dissolved oxygen
concentrations, organisms can die due to anoxia.
                                                       16

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                                                                            Introduction
Description of
Priority Problem
Areas
This section provides a description of the known problem areas
associated with chemical and bacterial contamination and eutrophi-
cation and identifies potential sources of the contaminants.

Toxic chemicals are considered a problem if concentration levels
significantly exceed contamination indices, such as EAR values or
AETs. Contamination indices are generally described above in the
Technical Approach for Identifying and Ranking Problem Areas
section and in more detail in Bellingham Bay Action Program:
Initial Data Summaries and Problem Identification (PTI 1989a).
Microbial contamination is considered a problem if fecal coliform
bacteria levels exceed state water quality and shellfish standards.
Eutrophication is considered significant if dissolved oxygen levels
fall below state dissolved oxygen standards.
Problem Contaminants
and Station Locations
Based on the limited data available, polycyclic aromatic hydrocar-
bons (PAHs), PCBs, mercury, lead, silver, arsenic, zinc, copper,
and fecal coliform bacteria have been identified as problem contam-
inants for Bellingham Bay.  The 13 problem stations for chemical
contamination, grouped in  four problem areas, are shown in Fig-
ure 4. An additional 26 stations were identified as potential problem
stations for chemical contamination (see Figures 4 and 5). Eleven
stations were identified as problem areas for bacterial contamination
(see Figures 4 and 5) and three stations were identified as problem
stations for eutrophication  (see Figure 5).  Further source control
and remedial action evaluations are strongly recommended in
problem areas.  More study is recommended in potential problem
areas to define the extent and severity of existing problems.
Contaminant Sources
There are six major categories of point and nonpoint sources of
contaminants to Bellingham Bay:   wastewater  treatment plants
(WWTPs),  CSOs,  surface  water runoff,  industrial facilities,
ground water, and accidental  spills.  The cities of Bellingham,
Ferndale, Lynden, and Everson all have WWTPs that have been
issued NPDES permits for discharges to either Bellingham Bay or
the Nooksack River.  There is only one CSO in Bellingham (the
"C" Street interceptor).  Overflows from this CSO occur at  an
average rate of one overflow event per year.  There are numerous
sources of surface water runoff to Bellingham  Bay including  11
storm drains that drain directly into the bay, 64  storm drains that
drain to creeks, the Nooksack River watershed, and 8 other
watersheds that drain directly to the bay.  Additional private drains
discharge storm water to Bellingham Bay from industrial facilities
located  in  the city.   There are 18 NPDES-permitted industrial
                                                       17

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 LEGEND
            Apparently unimpacted station
            for chemical contamination

            Potential problem station for
            chemical contamination

            Problem station for
            chemical contamination

            Potential problem area for
            chemical contamination
                                                                                      Bellingham
            Problem area for
            chemical contamination
  EZD

    A

ZZ~H~  Navigation channel
            Problem station for
            microbial contamination
            Georgia-Pacific outfall
                                                      ost Point Wastewater
                                                     Treatment Plant Outfall
Note: Problem area contours should
be considered as estimates only.
                                                                                                   kilometers
             Figure 4.  Classification of stations in inner Bellingham  Bay according to
                         action criteria.
                                                                                                       C744-24099I
                                                    18

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LEGEND
         Apparently unimpacted station
         for chemical contamination

         Potential problem station for
         chemical contamination
     A

     D
                                                                                                                                 Bellingham
Potential problem area for
chemical contamination

Problem station for
microbial contamination

Problem station for
eutrophication

Note: Problem area contours should
be considered as estimates only.
                          kilometers
             Figure 5.  Classification of stations in outer Bellingham Bay according to action criteria.
                                                                                                                                             C744-24099I

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Introduction
                          discharges:  9 that discharge to the Post Point WWTP and 9 that
                          discharge to either the bay or streams that flow  into the bay.
                          Nonpoint sources of contamination to Bellingham Bay include
                          landfills, commercial and recreational marinas, the Port dock
                          facilities, and disposal sites for dredged material. Numerous spills
                          from vessels and facilities  into Bellingham Bay have been docu-
                          mented.

                          Other potential sources have been identified by the interagency and
                          citizen work group.  All known and potential point and nonpoint
                          sources identified to date are shown in Figures 6 and 7 (see Table 2
                          on page 77 for additional discussion of these sources).


Areas of Chemical         Four problem areas for chemical contamination,  made up of 13
Contamination            problem  stations, have been identified for  Bellingham Bay.  The
                          four areas are: the mouth of Whatcom Creek, the area near the
                          discharge from the Georgia-Pacific Corporation (Georgia-Pacific)
                          outfall, the  area immediately inshore of the terminus of the Post
                          Point WWTP outfall, and a small area off the Fairhaven shoreline
                          (Figure 4).   Chemical concentrations,  amphipod  mortalities, or
                          depressions in benthic abundance from these areas exceeded the
                          problem area criteria presented in Table 1.

                          An additional 26 problem stations  are grouped into one large
                          potential problem area (Figure 5). This large potential problem area
                          extends from the Squalicum Marina to the Whatcom Creek Water-
                          way, along  the eastern shoreline of Bellingham Bay, and out into
                          the central part of the bay.  This large area encompasses the four
                          smaller identified problem areas. Chemical concentrations, amphi-
                          pod mortalities, or depressions in benthic abundance from  these
                          areas exceeded the potential  problem area criteria  presented in
                          Table 1.

                          Since the data summary report was completed in  1989, several other
                          studies have been completed that evaluated baseline conditions,
                          potential sources, and bioaccumulation levels in Bellingham Bay.
                          These additional studies have been done to fill gaps in existing data.
                          They have  also been conducted as part of ongoing monitoring
                          programs and to determine baseline conditions. The information
                          from these studies has not been integrated with  the indices used to
                          determine problem areas.

                          An extensive baseline analysis of sediment chemistry, benthic
                          infauna,  bioassays, and bioaccumulation was done for the area near
                          the Bellingham Bay PSDDA open-water dredged material disposal
                                                       20

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                                                                           LEGEND
                                                                       1   WASTEWATER TREATMENT PLANTS
                                                                        a  Post Point
                                                                        b  City of Ferndale (Figure 7)
                                                                        c  City of Lynden (Figure 7)
                                                                        d  City of Everson (Figure 7)
                                                                       2   HATCHERIES
                                                                        a  Bellingham (Figure 7)
                                                                        b  Nooksack River State (Figure 7)
                                                                       3   Bellingham Cold Storage
                                                                           Bellingham Frozen Foods
                                                                           Brooks Manufacturing (Figure 7)
                                                                           Columbia Cement Corporation
                                                                           Dahl Fish Company, Inc.
                                                                           Georgia-Pacific Corporation
                                                                           Maritime Contactors Inc. (awaiting NPDES permit)
                                                                           Mt. Baker Plywood, Inc.
                                                                           The Oeser Company (Figure 7)
                                                                           Public Utility District #1 of Whatcom County (Figure 7)
                                                                           Schenk Seafood Sales
                                                                           Sea-Pac Company, Inc.
                                                                           Seawest Industries
                                                                           Shukson  Frozen Foods (Figure 7)
                                                                           OTHER POINT SOURCE
                                                                           "C" Street CSO
                                                                           EMERGENCY OVERFLOWS
                                                                        a  Edgewater (Figure 7)
                                                                        b  Flynn Street (Figure 7)
                                                                        c  Birch Street (Figure 7)
                                                                      19   City of Bellingham storm sewer system
                                            kilometers
 20   SALMON NET PENS
   a  Alaska Ferry Terminal
   b  Squalicum Harbor
   c  Taylor Dock
 21   HATCHERIES
   a  Maritime Heritage Center
   b  Skookum (Figure 7)
 22   LANDFILLS
   a  Whatcom County Courthouse vicinity
   b  City of Bellingham
   c  Shoreline vicinity
   d  Lynden (Figure 7)
   •  Cedarvilie
    f  Airport Woodwaste (Figure 7)
   g  Hilltop Farms
   h  1178 Marine Drive
    /  Y-Road
    /  Zell Road
 23   Chuckanut Bay Residential Area (Figure 7)
 24   Marine Drive (Birchwood vicinity)
 25   MARINAS
   a  Hilton Harbor
   b  Squalicum Harbor
 26   PORT OF BELLINGHAM TERMINALS
   a  Fairhaven
   b  Hilton
   e  Parkway
   d  Squalicum Harbor
   •  Whatcom International Shipping
 27   Alaska State Ferry Terminal
 20   DREDGED MATERIAL DISPOSAL SITES
   a  Site A
   b  SiteB
   c  SiteC
   d  SiteD
   •  SiteE
    r  Site F
   g  PSDDA Site (Figure 7)
•	  Stormdrains
Figure 6.  Major contaminant sources in inner Bellingham Bay.
                                                                                                           C744-24 0991
                                                   21

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                                                                                             LEGEND
                                                                                             	Bellingham city limits

                                                                                             Note: Refer to Figure 6 legend
                                                                                                  for numerical references
                                                                                                             i kilometers
Figure 7.  Major contaminant sources to Bellingham Bay.
                                                                                                                   C744-240991

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                                                 Introduction
site in 1989 (PTI 1989b). The sediment chemistry levels for five
stations exceeded PSDDA screening level criteria for mercury, one
station exceeded the screening level criteria for mercury and
4-methylphenol,  and one station exceeded the screening level
criteria for mercury, phenol, and benzoic acid.  Benthic infauna
populations were not considered depressed and bioassay responses
were close to responses to sediments from a reference area.  While
eight metals and three organic chemicals were found in bivalves
from the disposal site area, none of the levels were above PSDDA
tissue guidelines. The stations from the PSDDA baseline study with
elevated chemical concentrations are mostly within the area pre-
viously identified as a potential problem area by the Initial Data
Summaries and Problem Identification report (see Figure 5).

EPA recently completed the first phase of a study to trace contam-
inant sources from storm drains in Bellingham Bay [Drainage Basin
Source Tracing Study:  Phase 1  Technical Memorandum (PTI
1991)].  While data from the report have not yet been integrated
with the data from the initial data summaries, the new data indicate
that sediment  from  several storm drains have levels of chemical
contamination  that are associated with potential adverse biological
effects in  the  marine environment.  Based on  biological effects
criteria, stations BELL03, BELL08, BELL09, and BELL16 (Little
Squalicum Creek) were designated as high priority for additional
source tracing  activities (Figure 8).  These three storm drains and
one creek had  levels of sediment contamination that are associated
with adverse biological effects in  marine organisms.   Stations
BELL13 and BELL14 were both classified as medium priority for
further source tracing due to the number and level of sediment
contaminants and potential adverse effects on marine organisms.
Phase 2 of this  study is now underway to determine potential sources
in the drainage basins associated with the six priority stations as
well as one basin not evaluated as part of Phase 1  work (see EPA
activities in the Comprehensive Plans and Programs  section on
page 27).

Additional data on sediment contamination and toxicity have been
collected by the U.S. Army Corps of Engineers (Corps) to evaluate
disposal options for sediment from Squalicum Creek, I & J  Street,
and Whatcom waterways (U.S. COE 1991). Six of 12 samples in
Squalicum Creek Waterway, 4 of 18 samples in I & J Waterway,
and all 3 samples  in Whatcom Waterway failed PSDDA criteria for
sediment disposal in a  nondispersive disposal site.   Sediments
collected for PSDDA are collected from 4-foot sediment cores and
may represent historically contaminated sediments that are buried
beneath more  recent, less contaminated surface sediment  layers.
                             23

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Bellingham
    Bay
                                                LEGEND
                      Fairhaven
High Priority Stations
BELL03
BELL08
BELL09
BELL16

Medium Priority Stations
BELL13
BELL14

Low Priority Stations
SQAL01
Navigation Channel
                                                                                kilometers
   Figure 8.  Priority storm drains and creeks for source tracing.
                                       24
                                                                                  C744-Z409S1

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                          However, high zinc levels were found in surface sediments of the
                          Squalicum Waterway.  The sediment chemistry data from these
                          samples indicate that much of this area has sediment contamination
                          levels significantly elevated above Puget Sound marine sediment
                          cleanup screening levels (i.e., levels that indicate an area should be
                          evaluated for cleanup).

                          Several bioaccumulation studies evaluating fish and shellfish con-
                          tamination have recently  been completed.   A  study  evaluating
                          bioaccumulation of contaminants in crabs and clams was conducted
                          in 1990 by Ecology and DNR.  The results of the study are presented
                          in Bioaccumulation of Contaminants in Crabs and Clams in Bel-
                          lingham Bay (Cubbage 1991).  The study reveals that concentrations
                          of metals in crabs and clams are near reference area levels. Mercury
                          concentration levels in crabs collected near Whatcom Waterway are
                          higher than background levels. Low levels of two pesticides, DDE
                          and chlordane, and PAHs  were also found in some samples.  The
                          concentrations of contaminants were low compared with areas of
                          known sediment contamination and  were equivalent to concentra-
                          tions found at reference areas.

                          In 1989, DOH conducted sampling of English sole from Bellingham
                          Bay  under the Puget  Sound Ambient  Monitoring  Program
                          (PSAMP). While only a few  metals and organic chemicals were
                          evaluated, arsenic and copper were the only contaminants that were
                          detected at concentrations higher than detection limits.  Mercury
                          data were rejected due to poor laboratory quality control.

                          In  the spring of 1991, DOH conducted  sampling of shellfish
                          collected near the Post Point WWTP outfall, also in accordance with
                          PSAMP.   The samples were evaluated for metals and organic
                          chemicals. Four organic chemicals were found above the detection
                          limit.   Benzoic acid was  the most significantly  elevated, with
                          concentration levels between 360 and 700 /*g/kg.  The other three
                          organic chemicals were found at relatively low concentrations.
Areas of Bacterial          Four marine water stations and five freshwater stations are classified
Contamination             as problem areas in Bellingham Bay due to microbial contamination
                           (Figure 4).  In addition, levels of fecal coliform bacteria were
                           elevated in shellfish from three areas within Bellingham Bay. EAR
                           values were calculated using the  Class A marine water quality
                           criterion of 14 organisms/100 mL, Class B marine water quality
                           criterion of 100 organisms/100 mL, and the  Class A freshwater
                           quality standard  of 100 organisms/100 mL.   The  criterion  for
                           evaluating shellfish tissue was 230  organisms/100 grams of tissue,
                                                       25

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Introduction
                           based on the U.S. Food and Drug Administration guideline. There
                           is a lack of data on discharges of untreated wastewaters (e.g., via
                           storm drains and surface runoff to Bellingham Bay). This data gap
                           limits knowledge of the full extent of potential microbial contami-
                           nation problems in Bellingham Bay.


Areas of                   All three stations evaluated violated the dissolved oxygen standard
Eutrophication             for eutrophication (Figure 5).  Problem stations for eutrophication
                           were determined based on the Washington state water quality
                           standard of 6.0 mg/L for Class A marine waters.  The station near
                           the Post Point WWTP had the highest number of violations, and
                           concentrations lower than 5.0 mg/L were observed at a station near
                           Post  Point and near the former Starr Rock dredged material disposal
                           site.  Low dissolved oxygen levels in Bellingham Bay may be due
                           to  incoming seawater that is low in dissolved oxygen and high in
                           nutrients (i.e., nitrate) (Rensel and PTI1991).  The lack of data on
                           dissolved oxygen conditions in nearshore and shallow areas limits
                           knowledge of the full geographic extent of potential eutrophication
                           problems in Bellingham Bay.
                                                        26

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1991  Action  Plan  for Bellingham Bay
                         Many planned or ongoing actions to control contaminant inputs and
                         eutrophication to the project area are part of comprehensive pro-
                         grams or planning activities of federal, state, local, and tribal
                         government agencies. The first part of this section provides a brief
                         summary of these programs and the agencies involved. The second
                         part of this section, which consists of Tables 2-8 (see pages
                         77-102), presents a detailed action plan for controlling contaminant
                         discharges to problem  areas and implementing other relevant
                         actions.
                         Comprehensive Plans and Programs

                         Comprehensive plans and programs apply to a large portion of the
                         project area (e.g., basin plans or the geographic area within a local
                         government body's jurisdiction) or a category of sources or activi-
                         ties (e.g., storm water management programs or development of
                         BMPs for an industrial category).  The following programs and
                         plans are described in terms of actions that can be taken to identify
                         or control ongoing sources of  contamination in the project area.
                         The discussion is  organized by the major implementing agency,
                         local government body, and tribe.
U.S. Environmental
Protection Agency
In conjunction with Ecology and PSWQA, EPA co-manages PSEP.
EPA oversees state-delegated programs and ensures that federal
minimum standards are attained.  EPA also provides technical
support to state and local agencies in the planning and development
of environmental protection programs.  EPA has initiated several
technical studies in support of Urban Bay Action Programs in Puget
Sound. These studies are listed in Appendix D.
Storm Water
Management
In November 1990, EPA issued the final rule for permit application
requirements for storm water discharges under the NPDES program
of the federal CWA.   Under this rule, EPA will regulate both
individual industrial facilities that discharge storm water to storm
sewer systems, and municipalities serving populations greater than
100,000 that have separate municipal storm sewer systems.  Storm
water discharges  from municipalities with populations  under
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1991 Action Plan for Bellingham Bay
                          100,000 (including Bellingham) will be covered by rules that are
                          expected to be issued by October 1992.

                          Under the storm water rule, facilities discharging storm water from
                          industrial areas into storm sewer systems or state waters will be
                          required to obtain NPDES permits from EPA or Ecology.  Permits
                          will be phased in using a four-tiered system.  Under the first  tier
                          (the initial stage), general permits will be issued to cover many
                          facilities at once.  Specific permits will then be issued for water-
                          sheds, groups of industries, and individual facilities.  For storm
                          water discharges covered by the rule, industrial facilities must
                          submit a permit application to Ecology within 1 year after promul-
                          gation of the rule  (December 1991).  There are three ways for a
                          facility to become covered by a permit.  A  facility  may apply  for
                          an individual facility-specific permit, apply as part of a group (or
                          industry-wide permit), or submit a Notice of Intent to be covered
                          by an agency-issued general permit. The first two  methods (i.e.,
                          facility- and group-specific permits) are used if general or industry-
                          specific  permits have not yet been initiated  by EPA and Ecology,
                          or if the discharge(s) in question would not be adequately addressed
                          by the more general permit.

                          These regulations are in addition to rules Ecology is preparing for
                          minimum requirements for storm water management programs for
                          Puget Sound (see Washington Department of Ecology on page 33).
                          The cities of Bellingham, Ferndale, Lynden, and Everson and  the
                          surrounding unincorporated areas of Whatcom County will be
                          affected by these storm water regulations and requirements.

                          EPA  and Ecology are also conducting a drainage basin source
                          tracing study (PTI199 Ib).  The focus of this study is to determine
                          the location, characteristics, and sources of contaminants in the city
                          of Bellingham  storm drains and drainage basins that discharge to
                          Bellingham Bay.  This study is being accomplished  in two phases.
                          Phase 1, which has been completed, included sampling at or near
                          the terminal point of drainage basins.  This  sampling was done to
                          determine contaminant contributions from each major basin, iden-
                          tify potential problems, and help focus future  sampling efforts.
                          Contamination contributions of storm drains and creeks to Belling-
                          ham Bay were evaluated using chemical analyses of storm drain  and
                          stream sediments.  Drainage basins were then ranked to determine
                          which basins will receive further sampling, evaluation, and analysis.
                          Phase 2 work  includes determining drainage basin boundaries,
                          identifying sources in seven basins, and producing maps.  Comple-
                          tion of Phase 2 will occur in September 1991.
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                                                       1991 Action Plan for Bellingham Bay
Permit Review
EPA reviews and comments on all significant permits for dredging
and fill operations in navigable waters under Section 404 of the
federal CWA and Section 10 of the Rivers and Harbors Act.  While
these two programs are implemented by the Corps, modifications
suggested by EPA concerning environmental protection and wetland
impacts may be included as requirements in the final permits.
Bioaccumulation
EPA has conducted a reconnaissance survey evaluating polychlori-
nated dibenzo-p-dioxin (dioxin) and polychlorinated dibenzofuran
(furan) contamination in Puget Sound crabs (PTI 199la).  Crabs
were collected from 12 locations in Puget Sound, including one
station near the Georgia-Pacific outfall in Bellingham Bay.  The
results of a preliminary health assessment using data from one
composite sample indicate that dioxin and furan levels in crabs from
Bellingham Bay do not appear to be a health risk.
Lummi Tribe
The Lummi Tribe has usual and accustomed fishing areas in
Bellingham Bay supported by treaty rights and manages several fish
resource enhancement projects.  The tribe reviews plans and per-
mits for development projects that could affect the tribe's usual and
accustomed fishing areas.
Watershed
Management
The tribe actively participated in the development of watershed
plans for the Silver Creek, Ten-Mile Creek, and Kamm Creek
watersheds.   These three  creeks are lowland tributaries  of the
Nooksack River and were selected as early action watersheds by
Ecology in June 1987. Early action watersheds are part of Element
NP-lofthePSWQMP.

The tribe obtained a CCWF grant from Ecology for implementation
of one component of the Silver Creek Action Plan.  The tribe
completed, with assistance from the Nooksack Tribe, a stream
rehabilitation project to restore stream vegetation and limit livestock
access to streams. This project served as  an example of  stream
rehabilitation techniques that can be used in many areas of the
Nooksack River watershed. The tribe does not have the funds to
conduct other stream restoration projects but is willing to review
draft project plans, provide technical recommendations, and letters
of support for work done by other groups and agencies.
Nonpoint Source
Management
The tribe's Resource Protection Division routinely reviews all forest
practice applications for areas within the Nooksack River basin.
                                                       29

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1991 Action Plan for Bellingham Bay
                          Tribe personnel also conduct site visits and provide technical
                          recommendations to  foresters.  The tribe's goal is  to  provide
                          technical advice during the planning stage of a forestry or develop-
                          ment project to prevent activities that will increase sediment loading
                          to salmon spawning streams.

                          The tribe is also compiling an inventory of sources that cause
                          sediment loading to streams for selected watersheds. The tribe will
                          develop lists of corrective actions that can be implemented by land
                          owners to reduce the  input of  sediment to streams. This  effort is
                          intended primarily to  prevent sediment loading to salmon streams
                          and the Nooksack River.
Resource
Management
Salmonids
The tribe operates several salmon rearing ponds located approxi-
mately 1  mile upstream from the mouth of the Nooksack River on
the Lummi Reservation. The ponds are used to rear chinook and
chum salmon and steelhead. Fry (juvenile salmon) from tribal and
state hatcheries are transferred to these ponds in the spring and
released  several  months later.  Warm water temperatures in the
rearing ponds allow the fry to grow quickly which, in turn, results
in higher return rates for adult salmon.

In 1990,  the tribe constructed an artificial spawning channel on the
north fork of the Nooksack River at Maple Falls.  In  1991, the
spawning channel produced over 34,000 chum fry. The estimated
egg-to-fry survival was 21 percent. This spawning channel protects
the fry from the impacts of sedimentation (e.g., mortality due to
smothering and low dissolved oxygen levels).  Increased sedimen-
tation can also lead to stream  instability and  channel  shifting.
Channel shifting  results in  a scouring or smothering of fry located
within the redd (i.e., nest).

The tribe also operates the Skookum Creek Hatchery that is located
on the south fork of the Nooksack River.  Salmon released from
this facility migrate out of the Nooksack River and spend several
months in  the shallow margins of Bellingham Bay and nearby
waters. The Skookum Hatchery  produces about 2 million coho and
60,000 fall chinook annually,  which represents about three-quarters
of the total hatchery coho and one-third of the total hatchery chinook
leaving the Nooksack River.
Resource
Enhancement
Shellfish
Oyster and littleneck clam seed from the tribe's Lummi Bay
Shellfish Hatchery are planted in the west side of Bellingham Bay
on selected tideflats in Portage Bay.  Future activities may include
                                                       30

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                                                       1991 Action Plan for Bellingham Bay
                           habitat enhancement using gravel and predator exclusion nets to
                           increase natural production.

                           The tribe has a CCWF grant to survey the shellfish resources in
                           Whatcom County. This survey will identify shellfish resource areas
                           and examine the relationship of fecal coliform bacteria contamina-
                           tion in shellfish to upland nonpoint sources of pollution.
Monitoring Activities
The tribe has sought funding from several federal sources to support
water quality monitoring.  Present funding  levels allow only a
limited amount of monitoring.  High priorities are to determine
sediment and nutrient loading in the Nooksack River and Belling-
ham Bay and to monitor incidents of algae blooms that occur in the
late summer in the lower Nooksack River and Bellingham Bay. The
tribe will also follow the harvest certification status of the tribe's
shellfish beds and will attempt to determine  the major sources of
bacterial contamination.
Investigations and
Studies
The tribe has completed a report entitled Nooksack Delta Investiga-
tions (Cochrane 1990) which evaluated the growth rate of the
Nooksack delta. The measure of delta growth was based on the rate
of sedimentation that occurred at one location on the outer margin
of the delta. The rate of shoaling has increased by a factor of 4.7
for the period 1956-1990 when compared to the period  1888-1956
(i.e., 0.45 feet/year and 0.09 feet/year, respectively).  The report
concluded that increased sediment loading in the river has resulted
in this accelerated growth and that poor forest practices are the major
cause of increased sediment loading. The increased growth of the
delta is impairing skiff navigation, degrading adjacent shellfish
habitat, and reducing the depth of estuarine channels  used by
migrating  salmon.   Littleneck  clam beds  are at  risk from the
advancing delta. Markers placed near these beds will  be used to
monitor the advance of the delta. Corrective actions for sedimen-
tation from past forest practices were recommended in the report
as one strategy for reducing impacts to the clam beds.

Several ongoing investigations are being conducted to better under-
stand the impacts of sedimentation on salmon and trout spawning,
egg incubation, and juvenile salmon development.   Corrective
actions are being identified for specific areas  in the upper Nooksack
River watershed to reduce the effects of sedimentation within critical
spawning areas. These actions include mitigation measures such as
the creation of artificial spawning areas to improve the productive
capacity of the watershed.
                                                       31

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733 / Action Plan for Bellingham Bay
Nooksack Tribe
The Nooksack Tribe has usual and accustomed fishing rights in
Bellingham Bay and manages several fish enhancement projects.
The tribe studies aquaculture proposals and monitors environmental
conditions throughout Whatcom County.  The tribe also participates
in the Nooksack Technical Spring Chinook Group.
Watershed
Management
The tribe has participated in planning committees to develop
watershed management plans for the Silver, Ten-Mile, and Kamm
creeks.   Stream restoration projects identified in  the watershed
management plans will soon be implemented.
Resource Management
The tribe operates a small hatchery on the Rutsatz slough and plants
300,000 chum eggs in Anderson Creek each year. The hatchery
was damaged during the flooding of 1990 and rehabilitation work
is  currently in progress.  The rehabilitated hatchery may rear
steelhead fry and will include a spawning channel for chum salmon.

The tribe  has participated  in and completed  numerous fish
productivity and habitat enhancement projects along the Nooksack
River and its tributaries including 1) construction of a spawning
channel on the south fork of the Nooksack River near Skookum
Creek for overwintering chum salmon, 2) removal of a section of
falls from the middle fork of the Nooksack that serves  as a barrier
to fish passage, 3) construction of an  acclimation pond for steelhead,
4) restoration of habitat on Racehorse Creek (along the north fork
of the Nooksack River), 5) restoration of the portion of Silver Creek
that runs just outside the city limits  of Bellingham (in conjunction
with the Lummi Tribe), 6) removal of a log and mud jam in Canyon
Creek [in conjunction with the U.S. Fish and Wildlife Service
(FWS)], and 7) rehabilitation of the artificial spawning channel in
Hutchinson Creek.  Fish  productivity  and habitat enhancement
projects planned by the tribe include: 1) chum brood stoc   . Elec-
tion for eggs in the fall of 1991, 2) egg planting in the spav, ^..<Ł
channel in Hutchinson Creek in the  fall of 1991, 3) removal of the
fish barrier at Canyon Creek in the  summer of 1992 to add 5 miles
of prime fish habitat (in conjunction with FWS), and 4) removal of
garbage from Anderson Creek in the summer of 1991.

In conjunction with the Nooksack Technical Spring  Chinook Group,
the tribe was the lead agency during the construction of an acclima-
tion pond on the north fork of the Nooksack for spring chinook fry
from  the Kendall hatchery.   The committee is planning to use
Deadhorse Pond as an  acclimation pond for spring chinook (and
                                                       32

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                                                      1991 Action Plan for Bellingham Bay
                          possibly steelhead) in the spring of 1992 and may also enhance the
                          spring chinook run in the south fork of the Nooksack River.
Monitoring Activities
Approximately every 2 months, the tribe monitors Cornell, Wells,
Racehorse, Hutchinson, and Porter creeks for temperature, pH,
dissolved oxygen, and scouring.
Washington
Department of
Ecology
In addition to the Bellingham Bay Action Program, Ecology has
numerous ongoing programs and planning activities related to
chemical and bacterial contamination and eutrophication in the
project area.
National Pollutant
Discharge Elimination
System
EPA has delegated authority to Ecology to issue and enforce NPDES
permits for nonfederal facilities. Ecology generally issues NPDES
permits on a site-by-site basis, and a permit for one site may include
more than one discharge or source of contaminants. Permits for
municipal WWTPs authorize discharges throughout the plant's
service area, including CSOs.  Industrial permits may include a
storm drain component for surface runoff as well as the wastewater
discharge component.  NPDES permits may require effluent limi-
tations for toxic contaminants (concentration or total loading) and
may include provisions for instituting BMPs to reduce nonpoint
contaminant inputs.  EPA's new NPDES regulations for  storm
water require property owners and tenants  in certain industrial
categories to submit data to Ecology regarding surface water  runoff
(see U.S. Environmental Protection Agency section).

Ecology currently  maintains 16 NPDES discharge permits  in the
Bellingham Bay project area.  These permits are for the cities of
Bellingham, Ferndale, Lynden, and Everson  WWTPs; Bellingham
Cold Storage Company (BCS); Bellingham Frozen Foods, Inc.
(BFF); Sea Pac Company, Inc.; Seawest Industries, Inc.; Schenk
Seafood Sales, Inc.; Oeser Company; Brooks Manufacturing Com-
pany; Columbia Cement Corporation; Public Utility District No. 1
of Whatcom County; Bellingham Hatchery; Nooksack State Salmon
Hatchery; and Georgia-Pacific.

Ecology will continue to conduct inspections and sampling efforts,
issue permits,  enforce  NPDES regulations,  and require  the
implementation of BMPs in the Bellingham Bay project area.
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1991 Action Plan for Bellingham Bay
                          With the assistance of an advisory committee, Ecology is currently
                          developing a general permit to address concentrated animal wastes.
                          A draft permit will be issued for public review in the fall of 1991.
Watershed Planning
for Nonpoint Source
Pollution
Under the state nonpoint source pollution planning rule (Chapter
400-12 WAC), Ecology administers a grant program that enables
local agencies to develop plans for controlling nonpoint source
contamination on a watershed basis.  CCWF is one of the financial
resources available to local agencies under Ecology's grant pro-
gram.  This funding source is being used by the Conservation
District to implement the Kamm and Ten-Mile creeks early action
watershed plans and was used by the Whatcom County Council of
Governments (COG) to develop the Silver Creek early action
watershed plan.

Ecology is responsible for final approval of watershed plans devel-
oped under the nonpoint source pollution planning rule.
Monitoring
As part of its Ambient Monitoring Program, Ecology is currently
monitoring one water quality station and two sediment quality
stations in Bellingham Bay.  The water quality station is located on
the north side of Portage Island, approximately halfway between
the southern tip of the Lummi Peninsula and the southern tip of
Portage Island.  This station is sampled monthly.   One of the
sediment stations  is  located  1.4  nautical miles  northwest of
Governor's Point and is sampled annually.  The other sediment
station is located approximately 1 mile east of the Nooksack delta,
about 2 miles offshore. This station is sampled once every 3 years.
Through this ambient monitoring effort, data have been collected
on toxic contaminants in marine sediments and conventional con-
stituents in  the marine water column.

In addition to marine  monitoring, Ecology's Ambient Monitoring
Section monitors conventional parameters (e.g., nutrients and oxy-
gen) at two stations in the Nooksack River.  These stations are
located at Brennan and at north Cedarville.  The Brennan station is
sampled annually; metals and total hardness are also monitored at
this station.  The Cedarville station is  sampled once every 3 years.

Data collected through Ecology's Ambient Monitoring Program is
provided to PSAMP, which is a comprehensive program to monitor
environmental quality throughout Puget Sound.
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                                                       1991 Action Plan for Bellingham Bay
                          Ecology's Environmental Investigations and Laboratory Services
                          division has also been investigating the cause of recurrent coho
                          salmon mortality  at  the  Maritime Heritage Fish Hatchery  on
                          Whatcom Creek.  Monitoring of the creek will occur during the
                          first significant storm event in the fall of 1991 and will include
                          metals and organic chemical analyses.
Storm Water               As part of the PSWQMP, Ecology's Water Quality Program Storm-
Managemem               water Unit is developing a basic storm water program that focuses
                           on preventing increased storm water flows and contamination, and
                           a comprehensive urban storm water program that focuses on
                           controlling storm water quality and quantity. The basic storm water
                           program will apply to all counties and cities in the Puget Sound
                           watershed.  The comprehensive urban storm water program will
                           apply to the six largest cities (including Bellingham) and four other
                           urbanized areas in the Puget Sound region by November 1991.  By
                           the year 2000, it will apply to all cities and urbanized areas of the
                           Puget  Sound region.   In support of both the basic storm water
                           program and the comprehensive urban storm water program,  Ecol-
                           ogy will issue rules,  guidelines, and model ordinances for storm
                           water management programs by November 1991.

                           Ecology will also produce a technical manual for use in storm water
                           management planning.  The  manual will  include BMPs for  the
                           control of erosion and sedimentation from construction sites, design
                           operation and maintenance standards for public and private reten-
                           tion/detention facilities, and techniques for the reduction or elimi-
                           nation of contaminants in  runoff from problem land  uses.   An
                           interim review draft of the manual is currently under public review.
                           The final manual will be released concurrently with Ecology's storm
                           water rule.

                           In addition to requirements for municipal  storm water programs,
                           Ecology has worked with the Washington Department of Transpor-
                           tation (DOT) and other interested parties to draft an administrative
                           rule that requires DOT to control the quality  and quantity of highway
                           runoff in the Puget Sound basin. The rule was adopted in May 1991
                           and became effective June 21, 1991.

                           Ecology is also currently developing guidance on the disposal of
                           water and sediment derived from storm drain system maintenance
                           (e.g., catch basins).  With grants from  PSEP and under Section
                           205(j) of the federal  CWA, Ecology is collecting and analyzing
                           sediment  and discharge water associated with catch basins.  The
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1991 Action Plan for Bellingham Bay
                          information will be used to develop disposal and handling policies
                          for drainage systems within Puget Sound.
Pretreatment
Ecology's Water Quality Division is responsible for writing state
waste discharge permits for all industries that discharge wastewater
to the city of Bellingham WWTP.
Combined Sewer
Overflows
Ecology requires the development of CSO reduction plans when
overflows exceed one per year.  In 1987, the city of Bellingham
submitted a CSO study to Ecology which documented that overflow
events are limited to less than one per year.  Therefore, Ecology
does not require a CSO reduction plan from the city of Bellingham.
Toxics
Bioaccumulation Study
Ecology's Environmental Investigations and Laboratory Services
division has carried out a study requested by the Bellingham Bay
Action Program to determine concentrations of selected metals and
organic chemicals in Bellingham Bay shellfish, compare results to
concentrations found elsewhere in Puget Sound, and determine
potential public health risks. The Lummi Tribe and DNR collected
samples in August and September of 1990. Crabs were collected
from eight sites and clams were collected from four sites.  Sites
were chosen based on popular recreational harvesting locations and
where little or no bioaccumulation data exist.  Based on the final
report (Cubbage  1991), concentrations of metals in Bellingham Bay
crab and clam tissues were low and approximately the same as
reference area levels.  Pesticides and PCBs were not detected in
either crab or clam tissues.  PAHs were found at low levels in clam
tissues.
Agricultural
Enforcement
Under the Agricultural Compliance Memorandum of Agreement
(MOA) between Ecology, the Washington Conservation Commis-
sion, and the Conservation District, Ecology refers farmers with
water quality problems to the Conservation District.   If a farmer
fails to call on the Conservation District for help in developing a
conservation plan or refuses to implement an approved conservation
plan, Ecology may carry out enforcement activities based on water
quality violations.
Shellfish Protection
Ecology's Shorelands Program Shellfish Unit is co-chairing, with
DOH, an interagency committee that is producing a recreational
shellfish plan for Puget Sound. A draft of the plan will be issued
for public review in August 1991 and should be finalized by October
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                                                       1991 Action Plan for Bellingham Bay
                           1991.  The plan addresses the protection of shellfish resources and
                           human health.   The plan  identifies  146 recreational beaches
                           throughout Puget Sound and includes provisions for site-specific
                           monitoring, public notification, public involvement and education,
                           community outreach, and beach restoration actions at 40 of these
                           beaches.  Monitoring actions will be conducted by DOH and will
                           include sampling  shellfish for paralytic shellfish poisoning and fecal
                           coliform bacteria, conducting water quality sampling for fecal
                           coliform bacteria, and conducting general upland surveys to identify
                           probable contaminant sources. Intensive source investigations and
                           mitigation efforts  would fall under the jurisdiction of the local health
                           department.  Responsibilities of Ecology's Shellfish Unit include
                           1)  implementing public involvement and  education  actions,
                           2) administering grants for beach restoration and cleanup activities,
                           and 3) coordinating  with urban bay action teams on recreational
                           shellfish issues.

                           Chuckanut Bay is currently classified as  a "threatened" beach under
                           the classification  scenario presented in the draft recreational  shell-
                           fish plan (see Washington Department of Health, Human Health
                           Risk Management section).
Hazardous Waste Sites     Under MTCA, Ecology investigates hazardous waste sites and
                           negotiates cleanup actions.  As the first step in the investigation
                           process, Ecology conducts a site hazard assessment to confirm the
                           presence of hazardous substances and determine the relative risk the
                           site poses to human health and  the environment.  Based on the
                           information gathered in the site hazard assessment, the site is ranked
                           by the Washington Ranking Method (WARM) relative to other sites
                           in  the state of Washington.  The WARM  ranking incorporates
                           human health and environmental risks.

                           Sites with a WARM score of 1 or 2 usually receive first priority for
                           cleanup  through Ecology's Toxics  Cleanup program.  A site may
                           be re-evaluated and receive a new rank if new information is
                           received or additional risks are identified.  Private parties may also
                           initiate site cleanup.

                           Ecology has performed the following site hazard assessments in
                           Whatcom County:  Whatcom Creek Waterway, Boulevard  Park,
                           Little Squalicum Creek (near Oeser Cedar), Georgia-Pacific airport
                           landfill,  and Trans-Mountain's pipeline pump station on East  Smith
                           Road. These sites will be ranked in the fall of 1991.
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1991 Action Plan for Bellingham Bay
Shoreline Development
Ecology's Shorelands Division is responsible for reviewing shore-
line master programs for consistency with the state Shoreline
Management Act. They are also responsible for reviewing shore-
line permits.  For shoreline master programs which are being
modified, Ecology is strongly advising that marine sewage pumpout
facilities be provided at marinas. Ecology also administers coastal
zone management grants to enable local agencies to modify their
shoreline master programs.
Sediment Standards
Development
Ecology has been a lead agency or key participant in several efforts
to develop tools for evaluating and managing contaminated sedi-
ments in Puget Sound.  These efforts have included the Commence-
ment Bay Superfund  project, PSDDA, the Urban Bay Action
Program,  and the PSWQMP.  Ecology has developed sediment
quality standards, a process for managing sources of sediment
contamination, a sediment cleanup decision process, and criteria for
confined disposal of dredged material.  In addition, guidelines for
unconfined disposal of dredged material have been developed under
PSDDA.  These sediment standards and guidelines affect sediment
remedial actions, wastewater discharges, and dredging operations
in Bellingham Bay.
Education
Ecology is involved in a variety of educational activities regarding
MTCA and waste reduction and recycling. Activities focus on the
general public, industry, and small businesses and include the
distribution of MTCA public awareness grants, other public educa-
tion grants, and brochures and educational posters published by each
program within Ecology.

The Bellingham Bay Action Program Coordinator is available for
educational presentations on the status of water quality in Belling-
ham Bay, in addition to programs on what citizens can do to improve
water quality.  Ecology staff are also available for educational
presentations on such topics as the MTCA, Sediment Management
Standards, and storm water management rules.

Ecology's Waste Reduction Recycling and Litter Control (WRRLC)
program will be  holding  "Away-with-Waste" workshops in
Whatcom County during the 1991- 1992 school year. These work-
shops will educate teachers on how to use the "Away-with-Waste"
primary and secondary school curriculum, which focuses on waste
reduction and recycling. Staff from Ecology's WRRLC program
are available for educational presentations and workshops concern-
ing waste reduction and recycling efforts in business and industry.
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                                                       1991 Action Plan for Bellingham Bay
                           The WRRLC program has also funded, and will continue to fund,
                           a wide variety of waste reduction and recycling educational activities
                           in Whatcom County.
Enforcement and'
Complaint Response
Staff members from Ecology's Northwest Regional Office in Belle-
vue respond to water quality complaints and work with violators of
the state water pollution laws to address water quality problems.
Ecology actions include site visits, correspondence, education,
notices of violation, administrative orders, penalties, and other
enforcement actions.
North Puget Sound
National Marine
Sanctuary
Ecology, in conjunction with the National Oceanic and Atmospheric
Administration, is investigating the possibility of designating north
Puget Sound as a  national marine sanctuary.  This designation
would ensure comprehensive management and protection of north
Puget Sound's resources and beneficial uses including recreational,
ecological, and historical qualities.
Washington
Department of
Fisheries
The Washington Department of Fisheries (WDF) is primarily
responsible for maintaining and enhancing fish resources for com-
mercial and recreational use and enhancing public access to fishing
areas.
Storm Water
Management
WDF addresses storm water management issues pertaining to
development projects through the Hydraulic Project Approval
(HPA) permit process and the SEPA review process.  WDF has
developed standard storm water guidelines that apply to develop-
ments that require an HPA permit or involve more than 5,000 square
feet of impervious surface. An HPA permit is required if any part
of a storm water facility involves work below the ordinary high
water line of the waters of the  state.   Under the storm  water
guidelines, storm water should be metered into streams at near the
predevelopment rate to maintain streambank and streambed stabil-
ity. In addition, pollutants in  storm water should be treated using
BMPs to protect marine and freshwater aquatic life.
Nonpoint Source
Management
WDF, using the services of the Washington Conservation Corps,
has installed cattle crossings and fences along many streams adjacent
to agricultural areas. WDF also strongly encourages HPA appli-
cants to install fencing to prevent livestock access.
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1991 Action Plan for Bellingham Bay
Resource Management     WDF reviews and comments on SEPA and NEPA documents and
                          NPDES permits as they pertain to fish habitat.  WDF is the lead
                          agency for HPAs in areas with anadromous fish runs.  HPAs are
                          required for any construction activities in fresh and marine waters
                          under the Hydraulic Code Rules (Chapter 220-110 WAC).  WDF
                          is particularly concerned about development activities near herring
                          and surf smelt spawning areas, nearshore juvenile salmonid habitat,
                          and salmon spawning streams.  WDF will review all  proposals on
                          a case-by-case basis to adequately protect these sensitive resources.

                          WDF operates two hatcheries,  one on the Nooksack River and one
                          on Whatcom Creek.  Both the Nooksack River hatchery and the
                          Whatcom Creek hatchery raise chum, chinook, and coho salmon.
                          The Whatcom Creek hatchery  is operated in cooperation with the
                          Maritime Heritage Center, a nonprofit organization.  The coho
                          salmon raised at the Whatcom  Creek hatchery suffer high mortality
                          nearly every year.  The suspected cause of this mortality is poor
                          water quality (e.g., toxic contaminants) in Whatcom Creek.

                          WDF, in conjunction with several tribes, local agencies, and local
                          interest groups, places and operates salmon net-pens for raising
                          salmon in Bellingham Bay.  Currently, salmon net-pens are located
                          at the Taylor Dock, in Squalicum  Harbor, and at the  Alaska Ferry
                          terminal in Fairhaven.  The Taylor Dock and Squalicum Harbor
                          pens were established in 1990, and the Alaska Ferry terminal pens
                          were established in 1989.  WDF issues HPAs, evaluates  site-spe-
                          cific physical and biological data for compliance with recommended
                          siting guidelines,  and co-manages the pens once they have been
                          established.  Net-pens producing  20,000 or more pounds of fish
                          (i.e., approximately 250,000 fish) per year must have an NPDES
                          permit.  Currently, the net-pens  located in Bellingham  Bay  are
                          producing less than 20,000 pounds of fish per  year.

                          The Taylor Dock net-pen operation consists  of four pens and is
                          cooperatively managed by the Bellingham Samish Bay Enhance-
                          ment Advisory Committee and WDF.  A physical and biological
                          survey of the site was conducted under direction of WDF in August
                          1990.  The site will be surveyed again during the  fifth year of
                          operation and prior to renewal of the HPA in 1996.  The Squalicum
                           Tarbor net-pen operation consists of one pen and is cooperatively
                             •aged by the Bellingham Heritage Center, the Bellingham Sam-
                                ' Enhancement Advisory, and WDF.  The Alaska Ferry net
                                   ^tion currently consists of only one pen, and future
                          t               *ain. This pen is cooperatively managed by the
                          Be              ii Bay Enhancement Advisory and WDF.  Con-
                          tinue         A\ of both the Squalicum Harbor and Alaska Ferry
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                                                      1991 Action Plan for Bellingham Bay
                          net pens are contingent on the findings of a WDF monitoring
                          program that targets a representative sample of net pen operations
                          in Puget Sound similar in  size and function to these two net-pen
                          operations.

                          Several salmon fisheries exist in Bellingham Bay at various times
                          throughout  the year: fall  chinook are caught from late July to
                          mid-September, coho are caught from mid-September to mid-
                          November, chum are caught from early November to mid-Decem-
                          ber, and steelhead are caught from mid-December to January.  In
                          odd years, pink salmon are  caught in July.  WDF monitors salmon
                          stocks by comparing annual run size estimates for each stock and
                          species.  A  run size estimate for a particular species and stock
                          includes an  estimate of the total adult fish caught by coast-wide
                          commercial  fisheries, coast-wide sport fisheries, and spawning
                          escapement (i.e., those fish allowed to escape capture to spawn).
                          Coded wire  tags and spawning ground surveys currently provide
                          the basis for run size estimates, though other methods are being
                          explored in an effort to refine these estimates.  Bellingham Bay is
                          also used as a major nursery  and overwintering area for herring,
                          although no  herring roe fishery (i.e., collection of herring eggs on
                          kelp) exists in the bay. Pacific cod are caught by commercial fishers
                          from December to March.  Smelt are caught by recreational fishers
                          in February  and March in  Squalicum Harbor. English  sole and
                          Bellingham Bay sole (a race of English sole) are caught throughout
                          the year.

                          There are also commercial  and recreational fisheries for Dungeness
                          crab in Bellingham Bay.  Approximately 100,000-150,000 pounds
                          of Dungeness  crab are caught commercially and 50,000-75,000
                          pounds are harvested recreationally each year. WDF monitors the
                          stock size and harvest and also reviews projects (e.g., permits under
                          SEPA and the  federal CWA) that may impact the crab resource.

                          Although there is currently  no commercial shellfish harvesting other
                          than crabs in Bellingham  Bay, the Lummi Tribe harvests large
                          quantities of clams from Chuckanut Bay.
Wetlands Protection       WDF has been directed by the Governor's Executive Order on
                          Wetlands (signed April 21, 1990) to protect fish life by assuring
                          protection for the value and function of wetlands by adding condi-
                          tions to or denying HPAs to the fullest extent of WDF's authority.
                          To add conditions to or deny an HPA that will impact a wetland,
                          WDF must show that the wetland has a positive impact on fish life.
                          To protect fish life, WDF implements a policy of no-net loss of
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1991 Action Plan for Bellingham Bay
                          habitat.  Where applicable and as directed by Section 12 of the
                          Governor's Executive Order on Wetlands, WDF will implement the
                          following mitigation priorities:

                              •   Avoid wetland impacts

                              •   Minimize wetland impacts

                              •   Rectify impacts by repairing, rehabilitating, or restoring
                                 wetlands

                              •   Reduce impacts by preservation and maintenance of
                                 wetlands

                              •   Compensate for impacts by  replacing, enhancing, or
                                 substituting wetlands

                              •   Monitor impacts to wetlands and take corrective actions.

                          As a condition of an HPA, applicants must fully mitigate all negative
                          impacts to the value and function wetlands provide to fish popula-
                          tions.
Monitoring Activities       Under PSAMP, two fish monitoring stations were to be established
                          in Bellingham Bay. One station was to be sampled annually and
                          the other station was to be sampled every other year. To date, one
                          station has been established south of Post Point about 1.25 miles
                          north of Gull Harbor.  However, due to funding constraints, this
                          station will only be sampled every other  year.  This  station was
                          sampled in 1989 but not in 1990. In the 1989 sampling  event, three
                          composite samples (muscle tissue from five fish combined to make
                          each composite sample) of English sole were collected from each
                          station. The samples were tested for metals and organic chemicals.
                          Arsenic  and copper  concentrations were  at 3.80  mg/kg  and
                          0.23 mg/kg,  respectively.  Lead  concentrations were below the
                          mean detection limit at 0.04 mg/kg, and mercury data were rejected
                          due to poor  laboratory quality control.   For  the four organic
                          chemicals tested, concentrations were below the mean detection
                          limit.  Cancerous lesions were not found in any of the samples.

                          In  1991,  WDF attempted to establish a  second station north or
                          northeast of the Post Point station, but was unable to catch enough
                          fish. Another attempt will not be made in the immediate future. In
                          future sampling events, WDF  will analyze English  sole muscle
                          tissue for a wider range of toxic contaminants.  The sampling effort
                          will also include analysis of toxic chemicals in liver tissue.  In the
                          future, additional samples may be taken as part of PSAMP.
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                                                       1991 Action Plan for Bellingham Bay
Human Health Risk
Management
WDF is working with DOH to determine if the concentrations of
arsenic found in English sole pose a human health risk.
Sampling Activities
The hatchery located on Whatcom Creek that is operated in con-
junction with the Maritime Heritage Center has experienced an
annual coho salmon mortality event during the fall months for a
number of years. The mortalities appear to correspond with the
first significant rainfall and runoff event of the fall.  Ecology and
the hatchery manager have attempted to conduct water sampling to
isolate the source of the mortality events.  These efforts  will
continue until the source of the mortality events is determined.
Washington
Department of
Health
DOH, formerly part of the Department of Social and Health
Services, is responsible for regulating commercial and recreational
shellfish  harvesting and is involved in sewage disposal control.
Currently, there are no beaches certified for commercial or recre-
ational harvesting of intertidal shellfish in Bellingham Bay, and
DOH recommends that no recreational shellfish harvesting be
conducted in inner Bellingham Bay.
Watershed
Management
DOH representatives provide technical assistance to the 12 Early
Action Watershed committees.  These committees, which include
the committees for Silver, Ten-Mile, and Kamm creeks, are respon-
sible for developing plans to control nonpoint sources of pollution.
DOH's participation on these committees focuses on onsite sewage
disposal and classification of shellfish growing areas.
Nonpoint Source
Management
DOH has completed a draft revision of its onsite sewage system
regulations (Chapter 246-272 WAC).  Public workshops will be
held in the summer of 1991 to discuss the proposed changes.  The
proposed revisions address a number of issues, including operation
and maintenance, areas of special concern, certification of onsite
sewage system designers, installers, and regulators.  The regula-
tions also require that each system be built to provide adequate
sewage treatment.

A model ordinance was developed by DOH primarily to assist
marinas in  handling blackwater  (i.e., sewage)  coming  from
liveaboard boats.  However, the ordinance is considered inflexible
by marina operators and the liveaboard community.  DOH,  in
conjunction with the Washington Parks and Recreation Commis-
sion, Ecology, and PSWQA is revising the ordinance. The revised
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1991 Action Plan for Bellingham Bay
                          ordinance will provide sewage disposal options addressing the needs
                          of various types o*   rarina users.  A state agency task force has
                          recently been asse.   xi and an advisory committee will be formed
                          that will include re   sentatives of boating communities.  The task
                          force will be developing the model ordinance and drafts will be
                          reviewed by the advisory committee. Under PSWQMP,  DOH is
                          to encourage local governments to implement the ordinance within
                          6 months of its completion.  The ordinance will be accompanied by
                          a report providing information to local governments on designing
                          and installing slipside pumpouts at marinas and methods of ensuring
                          their use by liveaboard boaters. No sooner than 2 years following
                          distribution of the model ordinance, DOH shall evaluate progress
                          under the  nonmandatory program and recommend additional action
                          as necessary.


Human Health Risk        On September 13, 1989, the Washington State Board of Health
Management              approved  new  regulations  for recreational  shellfish harvesting.
                          These regulations give DOH and local health departments the
                          authority to monitor and classify  beaches for recreational shellfish
                          harvesting based  on bacterial counts, concentrations of toxic con-
                          taminants, and  surveys of bacterial contaminant sources.  Recre-
                          ational harvesting of shellfish could be prohibited on beaches that
                          have  conditions  that would  pose unacceptable  health  hazards.
                          Under that regulation, DOH and  Ecology are developing a recrea-
                          tional shellfish program and preparing a draft action plan that was
                             Dished  in July  1991  and is available for public comment.  The
                               addresses the protection of shellfish resources and human
                               a and includes  proposed water quality and shellfish tissue
                          i    coring  at  major recreation shellfish  harvesting locations
                          tf   .ghout Puget  Sound.  The draft plan identifies four classifica-
                          tii  i to rank beaches for recreational shellfish harvesting:

                              •   Low-threat—Beaches that meet health standards for safe
                                 shellfish harvest or are distant from recognized upland
                                 or  water-based sources of pollution.

                              •   Threatened—Public beaches where shellfish harvesting
                                 is  threatened or potentially threatened by increasing
                                 pollution.  Adequate shellfish resources or the potential
                                 for enhancement exists, and good public access is avail-
                                 able.

                              •   Correctable—Public beaches that do not meet standards
                                 for safe shellfish harvesting due to chronic, though
                                 reversible, nonpoint  bacterial pollution.   Abundant
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                                                        1991 Action Plan for Bellingham Bay
                                  shellfish resources or potential for enhancement exists,
                                  and good public access is available.

                              •   Long-term Harvest Restriction—Public beaches with
                                  chronic or severe bacterial water quality degradation or
                                  that are located in  the immediate vicinity of sewage
                                  treatment  plants,  contaminated sediments,  or  major
                                  sources of toxic substances that require an area with
                                  long-term corrective actions.

                           Based on completed site evaluations, most public beaches in Puget
                           Sound will be classified. Post Point is an example of a beach that
                           is likely to be classified as an area with long-term harvest restriction.

                           DOH will be developing a draft MOA with county health depart-
                           ments that addresses whether DOH or county health departments
                           bear the responsibility of posting health warning signs on beaches.
                           This draft MOA is being reviewed by several county health depart-
                           ments.
Monitoring Activities       Under PSAMP, DOH conducts quarterly sampling of bivalve
                           shellfish (e.g., clams) for fecal coliform bacteria and annual sam-
                           pling for metals, organic chemicals, and pesticides.  Samples for
                           fecal coliform bacteria testing are collected near Post Point. In May
                           1991, bivalve shellfish near Post Point were also sampled for metals
                           and chemicals.   High levels of benzoic acid were found  in the
                           bivalve shellfish.

                           As part of its Recreational Beach Program, DOH monitors water
                           quality at 19 stations located in Chuckanut Bay between Post Point
                           and Governors Point and in the Chuckanut Village Stream. Sam-
                           pling conducted in August 1989 and May 1990 indicate that fecal
                           coliform bacteria are  elevated  in the Chuckanut Village Stream.
                           DOH notified County Health  about the bacterial elevations in
                           Chuckanut Village Stream.

                           Adopt-A-Beach volunteers will sample shellfish for paralytic shell-
                           fish poisoning toxins at Post Point and Chuckanut Bay once every
                           2 weeks from April  1 through October 31 during 1991. The shell-
                           fish will be analyzed by DOH. However, monitoring of these areas
                           for  paralytic shellfish poisoning during  the  winter months  is
                           unlikely.
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1991 Action Plan for Bellingham Bay
Washington State
Parks and
Recreation
Commission

Nonpoint Source
Management
The Washington State Parks and Recreation Commission (State
Parks) has a Boater Environmental Education Program to provide
information and services to the recreational boating community.
The 1989 legislature passed a bill that allocated funds from the
Watercraft Excise Tax to fund sewage pumpouts at marinas and
environmental education efforts for boaters.  In the spring of 1991,
the law was rewritten to include the funding of portable, as well as
stationary, pumpout stations. The law allocated a total of $ 1 million
for the first biennium (fiscal years 1990 and 1991) and $1  million
annually for each of the following 4 years.

For fiscal years 1990 and 1991, $300,000 was available from State
Parks for public and private marinas to install or repair  sewage
pumpouts.  Design criteria were developed by Ecology and were
reviewed at the April 1990 meeting of State Parks. In May 1990,
State Parks sent notices to all marinas in the state regarding the
availability of pumpout station grants, but no applications were
received  from marinas  in Bellingham Bay. Notices will  be sent
again in September or October 1991 for the 1992 funding cycle.

State Parks will work on developing an enforcement strategy for
marine discharges after the completion of the  sewage pumpout
station grant program.  The strategy,  Element MB-5  of the
PSWQMP, is due to be completed by the end of 1994.
Hazardous Waste
Management
State park rangers receive training in hazardous waste management
as part  of ongoing programs.   Because rangers sometimes use
pesticides and other chemicals, they are licensed to ensure that
proper procedures are used in applying these substances.
Education
State Parks manages the Boater Environmental Education Program.
State Parks is in the process of hiring two new staff members for
boater education.  One staff person will be involved in watershed
planning and conduct outreach activities (e.g., presentations) and
one will conduct boater educational activities.  With the additional
personnel conducting outreach activities, State Parks plans to
become more active in educational activities.

A slide show about boat waste management and a video on the
environmental impacts of boating are available through State Parks
for group presentations and for distribution to middle schools in the
state.   In addition, a water quality interpretive sign and sewage
                                                       46

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                                                       1991 Action Plan for Bellingham Bay
                           pumpout  location and operating  instruction signs are available.
                           State Parks and Ecology will discuss potential locations in Belling-
                           ham Bay for these signs.

                           State Parks publishes an educational brochure titled Boater's Guide
                           to Clean Water and Good Times.  The brochure addresses boating
                           safety, trash and plastic disposal,  sewage pumpout station locations
                           throughout the state, shellfish protection, boat maintenance, envi-
                           ronmental and economic impacts of boating, ocean disposal placard
                           requirements, and other general  information.  This brochure is
                           distributed to marinas, ports, educational groups, middle schools,
                           marine retail operations, and to other individuals and groups who
                           request it.
Washington
Department of
Wildlife
The Washington Department of Wildlife (WDW) has responsibility
for managing the wildlife of the state.  WDW is also responsible
for the Bellingham hatchery.
Storm Water
Management
WDW supports WDF's draft storm water guidelines that require
storm water detention/retention and treatment for hydraulic pro-
jects. WDW is considering adopting the storm water guidelines as
official policy after the public comment period is completed and the
guidelines have been finalized.
Watershed
Management
WDW is involved in the Federal Energy Regulatory Commission
(FERC) process for licensing the construction of hydroelectric
dams.  WDW examines in-stream flows, erosion control, and other
impacts to fish and wildlife under the Fish and Wildlife Coordination
Act.  There are currently  a number of proposed hydroelectric
projects on the  Nooksack  River and its tributaries.  WDW is
developing a list of priority habitats and species that will be used to
evaluate impacts to wildlife.
Land Use Development
WDW reviews and participates in comprehensive land use plans.
Because the review and participation is usually performed by a local
biologist who covers a large geographic area (2-4 counties and a
number of municipalities), the level of participation and review
depends on other agency priorities.
Resource Management
WDW has enhancement projects for native fish such as steelhead,
Dolly Varden trout, and sea-run cutthroat trout in place in Padden
and Whatcom creeks and several streams that empty into Lake
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1991 Action Plan for Bellingham Bay
                          Whatcom.   In addition, sport fishing  regulations have  been
                          restricted to increase protection for native  species.   WDW also
                          manages the Bellingham hatchery that is located in Whatcom Falls
                          Park.
Resource Protection
WDW is the lead agency responsible for HPAs on areas upstream
from those areas of streams used by anadromous fish.  WDW's
Habitat Management Section reviews all SEPA permits and forest
practice permits as  an advisory agency.   WDW also provides
comments to Ecology regarding the issuance of water rights. In all
cases, the comments are related to potential impacts  to fish and
wildlife resources and the means to mitigate or eliminate those
impacts.
Wetlands Protection
WDW has a policy in place under which the agency may deny or
add conditions to an HPA permit for proposed projects that may
impact wetlands. No degradation of wetlands is allowed. If there
is an  impact, it must be mitigated at the rate of 2 acres of new
wetlands per 1 acre lost.  However, under SEPA and NEPA, WDW
is only permitted to place conditions on activities  rather than deny
a permit outright.  Ecology, the Corps, and local governments are
also involved in the review and any mitigation would be a result of
negotiation or consensus among all involved agencies.
Washington
Department of
Natural Resources
DNR is responsible for managing terrestrial and aquatic lands
owned by the state and for enforcing certain resource protection
laws.
Nonpoint Source
Management
Under the Washington Forest Practices Rules and Regulations
(Chapter 222, WAC), DNR approves applications for harvesting
over 5,000 board feet of timber or for any other forest operation
that would be located on unstable slopes or near the nesting or
breeding ground of threatened or endangered species.  Approved
applications are required before timber can be harvested for sale.
Conditions placed on the approved application provide for the
protection of soil integrity, reforestation, streamside habitat protec-
tion, and fishery and wildlife concerns.  Under the Timber, Fish
and Wildlife agreement among resource agencies, timber compa-
nies, tribes, and environmentalists, interdisciplinary teams may be
formed  to deal with environmental concerns.   The teams make
recommendations to the forest practices forester, who may then
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                                                       1991 Action Plan for Bellingham Bay
                           require several habitat protection conditions to the clearing appli-
                           cation.

                           DNR also enforces rules and regulations under the Surface Mining
                           Act (Chapter 78.44 RCW).  Specifically, DNR has authority to
                           oversee those operations that collectively result in more than 3 acres
                           of land being disturbed or that result in excavation walls more than
                           30 feet high and  steeper than  45 degrees.  The purpose  of the
                           Surface Mining Act is to ensure that mined lands are properly
                           rehabilitated, that surface water quality is protected, and that public
                           safety standards are adhered to.
Aquatic Lands             DNR leases state-owned aquatic lands in harbor areas of Bellingham
Management               Bay for periods ranging from 5 to 30 years and for nonharbor areas
                           for a maximum of 55 years. The aquatic lands leasing program is
                           being evaluated to incorporate procedures for addressing contami-
                           nated sediment liability  issues  including  site identification,
                           investigation, and remediation.  In addition, all new and recently
                           signed leases include provisions concerning lessee liability for
                           releases of hazardous substances.   If hazardous substances  are
                           released on properties the lessees occupy,  the lessees will be held
                           liable for response and cleanup costs, conducting investigations,  and
                           pursuing corrective actions.

                           DNR established the Sediments Management Section in the Division
                           of Aquatic Lands in January 1991. The new section will encourage
                           DNR leaseholders to investigate and remediate contaminated sedi-
                           ments on state-owned aquatic lands.  The Sediments Management
                           Section will also represent DNR when the agency is identified as a
                           potentially responsible party  for sites containing contaminated
                           sediments.

                           In spring 1990, DNR received a grant from EPA to review aquatic
                           land use authorizations in nonurban areas of Puget Sound.  In  this
                           study, DNR's use authorizations were categorized by the likelihood
                           that the general use of the site could have contaminated state-owned
                           properties.   Since then,  DNR has expanded on this  study by
                           developing an inventory and empirical ranking of all lease sites in
                           western Washington, regardless of their urban or nonurban desig-
                           nation. As part of the land use authorization audit, DNR completed
                           the Puget Sound Sediment Reconnaissance Survey, 1991 (Tetra
                           Tech 1991).   The objective of the survey was to  identify contami-
                           nated aquatic lands that are publicly owned.  Potentially contami-
                           nated areas of Puget Sound (including Bellingham Bay) with  few
                           existing data were surveyed.
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1991 Action Plan for Bellingham Bay
                          DNR is also developing a user's manual that addresses contaminated
                          sediment management and includes policies and regulations related
                          to  contaminated sediments.   A working draft is currently being
                          reviewed by Ecology.

                          DNR and the Port are developing a port management agreement.
                          This agreement will assign all management responsibilities for
                          aquatic lands abutting port properties to the Port.  The agreement
                          will require the Port to follow DNR's regulations for managing the
                          leases.   Leases entered  into by the Port and DNR for individual
                          properties  would be eliminated.  The agreement is the result of
                          legislation designed to  simplify the collection process for lease
                          revenues.

                          DNR and Ecology are developing an MOA regarding contaminated
                          sediments on state-owned aquatic lands under which DNR will carry
                          out provisions of the MTCA (e.g.,  remedial investigations and
                          cleanups).  One PSDDA disposal site is located within the Belling-
                          ham Bay project area and any sediments requiring disposal there
                          would be subject to PSDDA guidelines.

                          DNR manages the Aquatic  Lands Enhancement Account.  This
                          account has money available for funding projects to acquire land
                          for public recreational access and public education.  Account funds
                          are not available for cleaning up contaminated sediments or improv-
                          ing water quality.
Outfall Management
DNR requires use authorizations for placement of outfalls on
state-owned lands.  In some cases, DNR may charge a fee if the
outfall will result in a net loss of state-owned resources (e.g.,
geoducks).
Monitoring Activities
DNR is responsible for conducting chemical and biological moni-
toring at the Bellingham Bay PSDDA site. DNR performed base-
line biological monitoring in the summer of 1990 at the Bellingham
PSDDA site for concentrations of certain problem chemicals in the
tissues of Dungeness crab.  Crab density was also monitored. This
baseline monitoring was conducted in conjunction with Ecology's
Bellingham Bay bioaccumulation survey, and the results are incor-
porated  in Ecology's final bioaccumulation report that was released
in September  1991. The baseline monitoring survey investigated
the concentrations of arsenic, cadmium, lead, mercury, PCBs, and
various  pesticides in crab  muscle and  hepatopancreas.   Arsenic,
cadmium, and mercury were detected in every sample.   Of the
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                                                     1991 Action Plan for Bellingham Bay
                          pesticides, DDE was found in 62 percent of the samples, and
                          chlordane was found in 15 percent of the samples. Concentrations
                          of detected chemicals were generally low. DNR will conduct a crab
                          bioaccumulation study after at least 100,000 yards3 of material have
                          been disposed of at the PSDDA site.
Dredging Activities
The Bellingham Bay PSDDA open-water dredged material disposal
site is available for use from June 16 through October 31 of each
year.  DNR, EPA, the Corps, and Ecology evaluate the material
that is proposed for disposal at the PSDDA site.  DNR issues the
permits to use the site and monitors compliance with terms of the
permit.

The Corps and the Port are planning to use the PSDDA site during
the 1992 dredging season.  Sediments from Whatcom Creek, I & J
Street, and Squalicum Creek waterways were tested under the
PSDDA guidelines.  None of the Whatcom Creek Waterway sedi-
ments were approved for disposal at the PSDDA site.  Only some
of the sediments tested from the I & J and Squalicum  Creek
waterways were approved by the PSDDA  agencies.
Habitat Mapping
In support of PSAMP, DNR is involved in a project to inventory
nearshore habitat using remote sensing techniques (i.e.,  aerial
photographs and satellite images).  Habitat information has been
gathered and will be entered into a geographic information system
(GIS) by December 1991. New data will be collected every 3 years
by the EPA and will  be added to the GIS.  When the project is
complete, comprehensive habitat maps for Bellingham Bay will be
available.
Puget Sound Water
Quality Authority
PSWQA is responsible for developing the PSWQMP for water
quality protection in Puget Sound.   PSWQA oversees  all the
PSWQMP programs implemented by federal, state, and local
agencies; tribal governments; and federal facilities.
Storm Water
Management
Under the 1991 PSWQMP, a work group and a storm water
technical assistance service have been added to the storm water
program. The work group will help coordinate policy issues among
fisheries, storm water, and wetlands programs.  The storm water
technical assistance service will be provided to local governments
by Ecology.  The 1991 PSWQMP proposes that the local storm
water programs be incorporated in the comprehensive land devel-
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1991 Action Plan for Bellingham Bay
                          opment plans that will be drafted under the State Growth Manage-
                          ment Act (Substitute House Bill No. 2929).

                          Ecology has drafted a proposed rule that will set minimum storm
                          water standards for new developments.  When Ecology's proposed
                          rule is  finalized, PSWQA will adopt a rule that requires local
                          governments to adopt storm water programs that include Ecology's
                          rule.  These rules are being coordinated with the recent  federal
                          storm water NPDES regulation (see U.S. Environmental Protection
                          Agency section).  Adoption of both rules by PSWQA is expected
                          by January 1992.
Nonpoint Source
Pollution Management
PSWQA is currently revising the watershed management planning
rule (Chapter 400-12 WAC) to incorporate information from the
watershed planning efforts that have occurred to date.

Under the 1991 PSWQMP, the issue of pesticide use will be
addressed in existing nonpoint pollution, education, and household
hazardous waste programs.

Also, the 1991 PSWQMP directs DOT to develop a program to
control runoff from highways in the Puget Sound basin.  Ecology
has drafted guidelines for the program that were adopted as an
administrative rule in May 1991 and became effective on June 21,
1991.  Under this program, the department will draft and adopt a
storm water management manual, develop a vegetation management
program, and institute other measures to control the quality and
quantity of runoff from highways in the Puget Sound basin.  The
administrative rule will govern the runoff program and includes a
requirement that the department shall comply with standards iden-
tified in watershed actions plans, even if they are more stringent
than the department's manual.
Wetlands Protection
Activities
In the 1991 PSWQMP, minimum guidelines or standards for
wetland protection programs that will be implemented by local
governments are proposed. PSWQA has deferred a final decision
on the standards until summer 1991 to provide additional time for
public comment.  PSWQA is seeking public comment on whether
or not to adopt mandatory standards or guidelines, in addition to
comments on the content of the standards. The program recom-
mended by PSWQA also includes expanded roles in wetlands
protection for the Corps, EPA, and  FWS. In addition,  PSWQA
has established a wetlands restoration program.
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                                                     1991 Action Plan for Bellingham Bay
Water Quality Planning
The PSWQMP was initially developed in 1987, revised in 1989,
and finalized in 1991.  The plan was adopted in May 1991 as the
first CCMP in the nation for an estuary of national significance (as
designated under Section 320 of the federal CWA).  The CCMP
contains an action plan for various programs and establishes broad
funding and program funding priorities. Based  on legislation in
1990 that reorganized and reauthorized PSWQA, the PSWQMP
also includes  an implementation strategy for prioritizing plan ele-
ments according to constraints faced by local governments.  The
legislation also authorizes PSWQA  to create a foundation for
supporting education and research activities.
Oil Spill Prevention
The 1991 State Legislature passed an oil spill bill that mandates
implementation of most of PSWQA's spill prevention and response
program.  The spill prevention and response program includes
elements for contingency plans, spill prevention plans, spill preven-
tion education, and numerous other elements to increase spill
prevention and response.
Monitoring Activities
Staff at PSWQA provide technical and administrative support to
PSAMP. PSAMP provides a comprehensive, long-term monitor-
ing program for Puget Sound.  PSAMP was designed to:  1) assist
agencies by characterizing and interpreting spatial and temporal
trends and identifying problem areas, 2) take measurements to
support specific program elements and measure the success of the
PSWQMP, and 3) provide an ongoing assessment of the health of
Puget Sound and the risk to human health from consuming seafood
from the sound.

Three management units comprise PSAMP:  1) the PSAMP Steer-
ing Committee, 2) the Monitoring Management Committee, and 3)
PSWQA.  PSWQA will act as the chair for the PSAMP Steering
Committee and the Monitoring Management Committee and will
facilitate agency cooperation among the state agencies implementing
PSAMP. Other functions PSWQA will carry out include providing
arbitration for interagency disagreements concerning PSAMP; pro-
viding and housing staff members; managing data; and distributing
integrated, interpretive  reports of  PSAMP results.   PSAMP
received  $1 million in  funding  over the 1989- 1991 biennium.
Under PSAMP, there are stations for sampling sediment, fish,
shellfish, and the water column in Bellingham Bay. These stations
are described under the appropriate implementing agency.
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1991 Action Plan for Bellingham Bay
Public Involvement
and Education Fund
The Public Involvement and Education (PIE) Fund was created by
the Washington State Legislature in 1987 to sponsor model projects
for public involvement and education, community cleanup activi-
ties, and environmental monitoring by members of the general
public.  An initial $1  million was distributed in January  1988
(Round 1) and June 1988 (Round 2).  The 1988 legislature appro-
priated $1 million to sponsor two more rounds of funding in 1989
and 1990.  Approximately $700,000 was granted in the third round
in October 1989 and another $300,000 was distributed in the fourth
round in April 1990.  PIE contracts have been awarded to Whatcom
Community College, University of Washington Sea Grant (Sea
Grant), Puget Sounders, Friends of the San Juans, and the Nooksack
Tribe.

The next round of PIE funding began with the release of a request
for proposal for Round 5 on June 15,  1991.  Proposals will be due
August 16, 1991. Selections will be announced on October 25,
1991. Round 6 requests for proposals will be released in January
1992, with proposals due in March and awards made in May 1992.
Although funding for rounds 5 and 6 depends on budget decisions
made by the 1991 State Legislature (not available at time of
publication), $1.1 million is identified in both the House and Senate
versions of the budget.  Approximately two-thirds of the PIE fund
contract money will be awarded in  Round 5 and  one-third in
Round 6.

PSWQA is in the process of forming  the Puget Sound Foundation
and is selecting the first board members.  The board will be fully
established by the summer of 1991.  The foundation is a new
program that responds to a recognized need for an ongoing structure
to coordinate strategies and funding  for research and education.
The  primary tasks of the  foundation will  be:   1)  funding  and
coordinating research and education programs on Puget Sound, and
2) assuming  responsibility for certain elements of the research and
education program as staff and funding allow. Fund raising activ-
ities  will begin after  the board has been established.
City of Bellingham
Department of
Planning and
Economic
Development
The City of Bellingham Department of Planning and Economical
Development (City Planning) manages shoreline development and
issues shoreline permits, develops land use regulations, and reviews
projects to be conducted within the city limits for compliance with
SEPA.
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                                                       1991 Action Plan for Bellingham Bay
Nonpoint Source
Management
Under the State Growth Management Act, the city can now review
forest practices permits and require mitigation, provide additional
conditions, or recommend denial.  As a way to place additional
controls on forest practices, the city will not approve a forest
practice permit unless a development application is also submitted
to City Planning.
Shoreline Management
The city's maritime industries are concentrated in several "urban
maritime" zones.  The area near Squalicum Harbor has multiple
uses and is likely to expand in the next decade.  Water-dependent
development will be encouraged in the urban maritime shoreline
areas.  The Port is considering filing an application for a shoreline
master permit to expand the Squalicum marina.  The cruise ship
berth in Fairhaven may be expanded beyond its current use as the
Alaska ferry terminal. There are also plans to develop a pedestrian
walkway along Bellingham Bay near Taylor Street.
Land Development
The city is considering revising the threshold levels for a determi-
nation of significance under SEPA. The threshold level determines
when environmental impacts require preparation of an environmen-
tal impact statement (EIS). This project has been put on hold due
to staff shortages.

In 1979, the city of Bellingham and Whatcom County created an
Urban Growth  Boundary outside  of the city limits.  The areas
between the boundary  and the city limits are zoned "interim urban
density" until a new  comprehensive land development plan is
drafted.  This means  that the city will provide water and sewer
services to these areas under the assumption that they will ultimately
develop into "urban density" zones and be annexed into the city.
Regulation
Development
City Planning will develop a wetlands protection ordinance after
wetlands are confirmed through a wetlands survey.  The ordinance
will include a permitting system, regulations, and a goal of no net
loss of wetlands.  A  wetlands  map will be developed and will
become part of the ordinance.

City Planning is also developing a land clearing ordinance to provide
requirements for the clearing of trees, shrubs, and other vegetation.
The ordinance will address the amount of clearing that may be
performed, where the clearing may be performed, the types of
vegetation that may be removed, and erosion and sediment control.
This ordinance is aimed at addressing properties containing under
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1991 Action Plan for Bellingham Bay
                          5,000 board feet of timber because these properties are not covered
                          by the DNR forest practices permit.
City of Bellingham
Department of
Public Works

Storm Water
Management
City Public Works operates the Post Point WWTP and is responsible
for controlling storm water runoff.
In July 1990, the city established a drainage utility in order to
address storm water drainage issues.  At this time, the fees are
collected on all developments at the time development permits are
issued and are based on the amount of impervious surface created.
The fee for single-family homes is $400, and the fee for all other
developments is $400 for each 3,000 feet2 of impervious surface
created.  The collected fees are placed in  a fund that is used to
upgrade deficiencies in the drainage system, build facilities of
regional benefit,  and support drainage division staff. There is no
storm water detention requirement in the city of Bellingham, but
the impacts on water quality are assessed  for each project.  If
necessary, the developer is given the option of correcting deficien-
cies or providing storm water detention facilities that are designed
to release water to streams at predevelopment rates. Projects with
parking lots must provide outlet traps in the catch basins to trap oil
and debris.
Watershed
Management
City Public Works is working with the County Health and County
Public Works on a study of Lake Whatcom and its watershed.
Phase I of the study was completed in 1986  and resulted in a
management plan for the lake.  The plan identified several areas
that required additional attention in order to ensure protection of
the lake's existing water quality.  Under Phase II of the study,
several of the concerns identified in the management plan have been
or are currently being addressed.  County Public Works, under
contract to the city, has completed underground fuel storage tank
and storm drain inventories, and County Health has completed an
onsite sewage disposal survey.  A draft ordinance for regulating
underground fuel storage tanks within the Lake Whatcom watershed
has been proposed and should be finalized in  the summer of 1991.
County Public Works and County Health are incorporating the
information from the surveys into their capital improvement pro-
grams and are developing maintenance programs for the tanks and
storm drains within the Lake Whatcom watershed. In addition, City
Public Works has contracted with the County Health to provide a
septic system maintenance program for the entire county.   It is not
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                                                       1991 Action Plan for Bellingham Bay
                           known if additional corrective actions will be taken because the Lake
                           Whatcom Advisory Committee has been disbanded.

                           An approved temporary erosion and sedimentation control plan
                           must be prepared for all activities (e.g., clearing, development) that
                           disturb land in the Lake Whatcom watershed. Larger developments
                           are required  to have permanent erosion and sedimentation control
                           facilities.  In  areas outside the watershed, subdivisions and projects
                           that may impact the environment are also generally required to
                           provide an erosion and sediment control plan as a condition of the
                           development contract or permit.
Sewer System
Management
The C Street Interceptor is the only CSO in the city of Bellingham.
Ecology has approved a CSO control plan submitted by City Public
Works. While the plan allows one sewage overflow event per year,
the city continues to reduce storm water intrusion so that overflow
events will be reduced to less than one event per year. There is no
schedule to completely eliminate the occasional overflow events.
Point Source
Management
City Public Works has met all of the target dates for preparing the
plans, specifications, and estimates for upgrading the Post Point
plant from a primary treatment to a secondary treatment facility.
The city of Bellingham has an industrial user ordinance that applies
to approximately 20 companies.  The ordinance allows the city to
monitor effluent from industries that discharge to the treatment
plant. If industries exceed thresholds for pH and total suspended
solids, the city can require a pretreatment program and levy
discharge surcharges.

The city's NPDES permit will be revised in March 1993.   The
revised permit may include requirements for measuring effluent
toxicity using bioassay tests, effluent testing for mercury, and
sediment quality testing near the outfall.
Nonpoint Source
Management
City Public Works issues permits for development or clearing
projects within the city limits that are also in the Lake Whatcom
watershed to protect the lake from water quality degradation.  The
ordinance contains erosion and sediment control requirements.  City
Public Works has  discontinued the use of herbicides in the Lake
Whatcom watershed for roadside maintenance.
Wetlands Protection
Activities
As one element of a Floodplain Management grant from Ecology,
City Public Works has performed a wetlands  assessment  of
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1991 Action Plan for Bellingham Bay
                           Squalicum Creek. Flood control, open space, wildlife habitat, and
                           development opportunities are the other elements that will be
                           assessed. As a result of these assessments, a plan will be developed
                           to protect the wetlands.  This plan may involve rezoning.  Much of
                           the watershed is currently zoned for commercial and industrial uses.
                           A draft plan will be completed in April 1992 and the final plan will
                           be completed in June 1992.
Monitoring Activities
In January 1990, City Public Works began a monthly testing
program for all creeks within Bellingham city limits.  The testing
is done to compare existing conditions to Class A water quality
standards.  Parameters  tested are temperature, pH, turbidity, dis-
solved oxygen, and fecal coliform bacteria.
Hazardous Waste
Management
City Public Works, in conjunction with County Public Works and
County Health departments, operates a model household hazardous
waste program.  The program includes a permanent drop-off site
for household hazardous wastes.
Education
The focus of City Public Works' educational activities is the Lake
Whatcom watershed.   It  receives the highest priority for city
activities because it is the source of the city's drinking water.  With
funds received under the Interim CCWF program (Referendum 39),
City Public Works has conducted or is conducting the following
educational activities  through the Lake Whatcom Education Pro-
gram:

    •   Preparing written materials on water quality for third
       and sixth graders.

    •   Organizing sixth graders to participate  in  developing a
       conservation site within the watershed and in a poster
       contest.

    •   Organizing interpretive walks for children in middle
       schools  that are specifically targeted  at Squalicum,
       Whatcom, and  Padden creeks where water quality issues
       are discussed.

    •   Coordinating with schools and teachers to incorporate
       watershed protection themes in their curricula.   Work-
       shops have been held for teachers where kits for analyz-
       ing basic water quality parameters were prepared for the
       workshop attendees.
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                                                       1991 Action Plan for Bellingham Bay
                              •  Publishing pamphlets that are distributed to all watershed
                                 residents and all city of Bellingham utility customers.
                                 The information contained in them is applicable to any
                                 watershed.

                          City Public Works also provides educational materials and conducts
                          educational activities on garden and household hazardous wastes.
                          City Public Works presents a slide show and a public seminar and
                          publishes informational brochures on "lake-friendly" gardening.
City of Bellingham
Parks and
Recreation
Department

Storm Water
Management
The City of Bellingham Parks and Recreation Department (City
Parks) is responsible for managing city park land and providing
environmental education opportunities.
City Parks owns the storm drains that are located on the property
owned by City Parks.  City Parks removes sediment that accumu-
lates in the storm drains as needed.
Park Land
Management
A draft site management plan for Little Squalicum Park was
prepared in April 1990. The plan calls for maintaining the majority
of the site east of the Marine Drive bridge in a natural state, while
developing the west meadow portion of the site west of the Marine
Drive bridge for more intense uses (e.g.,  playfields and picnic
areas).
Wetlands Protection
Activities
City Parks completed a planning study of Padden Creek and its
associated wetlands in  June  1990.  The study assessed existing
conditions and recommended policies and actions for public access
and wildlife and landscape management. Initial recommendations
are currently being developed.  A grant from the DNR Aquatic
Lands Enhancement Account has also been secured to increase
public access and enhance wildlife habitat along the creek.  The
improvements are scheduled to begin in late summer or early fall
of 1991.
Human Health Risk
Management
Based on recommendations from the state or county health depart-
ments, City Parks is willing to post health advisory warning signs
(that are supplied by the state Department of Fisheries or Depart-
ment of Health) on appropriate beaches in Bellingham Bay.
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1991 Action Plan for Bellingham Bay
Education
City Parks currently has one person working half-time at the
Maritime Heritage Center who provides interpretive information
about environmental issues.  City Parks  would like to make this
position full-time and place more emphasis on overall environmental
issues. This position is currently funded by British Petroleum, the
Bellingham School District, and the city of Bellingham.  However,
no additional funds are available to make  the position full-time.
Additional staff teach classes on issues regarding fish rearing.

City Parks would like to increase the opportunities for environmen-
tal education associated with watershed and water quality  issues.
City Parks will request  funds in the 1992 city budget to place
watershed and water quality related interpretive signs at parks.
Whatcom County
Conservation District
The Conservation District is involved in watershed planning and
controlling nonpoint source pollution from agricultural sources.
Watershed
Management
The Conservation District is the lead agency for two watershed
planning programs:  the Kamm Creek early action watershed and
the Ten-Mile Creek early action watershed.  Implementation of the
Kamm Creek Watershed Plan began in the spring of 1990.  The
Agricultural Stabilization and Conservation Service, a division of
the Soil Conservation Service (SCS), provided $475,000 for the
Kamm Creek Watershed Plan through a Water Quality Special
Project grant.  At least 50 percent of the farm waste management
plans  detailed  in the Kamm Creek plan have been implemented.
One of the major issues addressed in the Kamm Creek plan was
controlling nonpoint pollution from agricultural sources. In addi-
tion, newsletters have been published  and a booth was established
in the summer of 1990 at the Northwest Washington Fair to
distribute educational materials on watershed management.

Implementation of the Ten-Mile Creek plan could begin in July
1991. The Conservation District applied for $200,000 CCWF grant
for implementation of the plan. Based on a draft ranking, the project
ranks 30th out of 86 projects and  was proposed to receive funding.

Farmers in the Bertrand-Fishtrap Creek watershed continue to
implement waste management plans, either voluntarily, or in
response to notification of water quality violations (as provided by
the conditions of the compliance MOA between the Conservation
District and Ecology).
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                                                       1991 Action Plan for Bellingham Bay
Nonpoint Source
Management
The Conservation District and SCS assist dairy farmers in develop-
ing farm plans.  By using BMPs, the farm plans help reduce soil
erosion and animal waste discharges. The farm plans address how
waste is collected, stored, and applied as fertilizer to fields. There
are cost-sharing opportunities through the U.S. Agricultural Stabi-
lization Service to implement the BMPs.  Cost-share assistance is
denied to farm operators who fail to respond to being notified of a
water quality violation. SCS recently placed one additional person
in the SCS Lynden field office, who spends most of their  time
following up with farmers to ensure that they are implementing their
waste management plans.

The Conservation District has an MOA with Ecology regarding the
enforcement of water quality laws on farms.  If a farm is causing
water quality problems, Ecology will refer the case to the Conserva-
tion District.  The district will then develop a farm plan with the
farmer to reduce water quality problems. If the farm plan is not
developed or implemented, Ecology may cite the farmer  for water
quality violations.
Wetlands Protection
Activities
SCS identifies and inspects wetlands to ensure that farmers are in
compliance with the federal Food Security Act of 1985.  Under the
Conservation Reserve Program, individuals who farm in wetlands
or on highly erodible land are not in compliance with the law;
therefore, they are not eligible for SCS and Department of Agricul-
ture funds.  Although there are many opportunities to work on
habitat enhancement projects, SCS is not able to pursue these
projects because funding is extremely limited.
Education
The Conservation District writes a waste management news article
that the Whatcom County Cooperative Extension publishes monthly
in the Whatcom County Dairyline.  The Conservation District will
begin publication of a quarterly newsletter in 1991.  Funding for
this program is from the State Conservation Commission sponsored
through a CCWF grant.

The Conservation District, in conjunction with the Whatcom  County
Cooperative Extension, is in the process of producing two videos
on farm animal waste management. These videos may be completed
by  June  30,  1991.  The district also publishes a  brochure that
addresses conservation practices for farmers.
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1991 Action Plan for Bellingham Bay
                          The Conservation District, in association with Georgia-Pacific,
                          sponsors a 3-day conservation camp where sixth graders are taught
                          the value of soil conservation.
Whatcom County
Council of
Governments

Watershed
Management
The COG is active in watershed planning activities.
The COG is the lead agency for development of the Silver Creek
Early Action  Watershed Plan.   Silver Creek drains  into  the
Nooksack River.  The plan  includes the following programs:
1) education, 2) monitoring, 3) agriculture, 4) pesticides, 5) solid
waste disposal, 6) forestry,  7) onsite septic systems,  8) storm
water/erosion control, and 9) household hazardous waste.   The
watershed plan was approved by Ecology in April 1990 and
implementation began in January 1991 with CCWF funds.
Non point Source
Management
Under the Silver Creek Watershed Plan, SCS and the Conservation
District have been contracted by the county to complete an inventory
of the farms in the county to determine the impacts of the farms on
water quality. The farmers will then be encouraged to develop farm
plans and implement BMPs.
Monitoring Activities
The Institute for Freshwater Studies at Western Washington Uni-
versity will conduct water quality monitoring in Silver Creek as part
of the Silver Creek Watershed Plan.   The Institute will test for
pesticides, PCBs, volatile organic compounds, and heavy metals.
The first round of sampling was scheduled to begin June 1991.
Education
Educational activities are an ongoing part of the Silver Creek
Watershed Plan. Activities include the Master Watershed Program,
the development of a contractor's manual that identifies BMPs, and
participation in the county fair. There are approximately 20 volun-
teers in the first round of the Master Watershed Program.  Training
for the first group of volunteers was completed in mid-June 1991.
Additional funding was granted to Washington State University,
Extension Service - Whatcom County, for continuing the program
beyond the funding allocated through the Silver Creek Watershed
Plan.

A manual describing BMPs for  contractors was developed by the
Association of General Contractors of Washington.  The manual
has been distributed to the Whatcom County Building and Codes
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                                                       1991 Action Plan for Bellingham Bay
                           Department and the city of Ferndale for distribution to contractors
                           when building permits are issued.

                           The Conservation District also participates in the county fair to
                           distribute educational  materials to the community on nonpoint
                           pollution and water quality issues.
Whatcom County
Department of
Public Works
County Public Works is active in storm water management.  Shore-
line, zoning, building, and clearing permits are all issued by the
County Public Works.
Storm Water
Management
County Public Works is developing storm water standards that will
be included in the Lake Whatcom Watershed Plan.  The standards
will incorporate elements of the King County Surface Water Manual
and the Ecology Stormwater Management Manual and will include
requirements for onsite retention/detention, erosion and sediment
control, and the treatment of storm water. The standards should be
completed by September 1991. The county intends to adopt these
standards for the entire county and the areas of the city of Belling-
ham that are included in the Lake Whatcom watershed.  The city
of Bellingham currently is not planning on adopting the standards.

Storm water detention ponds constructed during development pro-
jects are maintained for the first 2 years by the developers. Upon
the third year, the county assumes the maintenance responsibility,
but it is compensated by the developer for the maintenance.  Cur-
rently, maintenance of these ponds by the county is on an infrequent
basis, and the maintenance conducted by the developers is not
regulated by the county. The current standards (Chapter 70 of the
Uniform Building Code as modified by county ordinance) do not
contain provisions for scheduling maintenance by the county or for
regulating the maintenance conducted by the developers.  Currently
proposed standards do include provisions for  a maintenance sched-
ule of the ponds for the county. Sediments removed from the ponds
are deposited in fill sites throughout the county.

In 1991, County Public Works received a budget increase for the
maintenance of ditches.  Approximately 200,000  cubic yards of
material will be removed per year.  This funding will continue on
an annual basis as approved by the county council.  County Public
Works anticipates that the council will continue  to approve the
funds.  Present plans provide for maintenance of 2,000 miles of
ditches on a 15-year cleaning cycle.
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1991 Action Plan for Bellingham Bay
                           County Public Works will install oil/water separators if necessary
                           when doing routine drainage system maintenance.  Oil/water sepa-
                           rators are currently required for all newly constructed parking lots
                           in the county.

                           County Public Works supports the establishment of a county-wide
                           drainage district to generate funds for storm water management
                           activities.  However, no such district is currently planned.
Watershed
Management
As part of a city of Bellingham study of the Lake Whatcom
watershed, County Public Works has completed an inventory of
storm drains and underground fuel storage tanks located within the
watershed.  County Public Works adopted an ordinance to regulate
underground fuel storage tanks that are not currently regulated by
state laws.  Actions, including enforcement of the new ordinance,
will begin on July 1,  1991.
Nonpoint Source
Management
County Public Works has initiated a model program addressing the
use of herbicides, pesticides, and fertilizers in the county.   The
county maintains a full-time position for overseeing vegetation
management practices including herbicide application, noxious
weed control, and mowing. The county has enforcement ordinances
that limit the application of pesticides and herbicides in several
sensitive areas including the Lake Whatcom watershed, Lummi
Island, and areas where citizens have "owner will maintain" agree-
ments.  County Public Works participates on state and regional
boards to stay current with developments on this subject.
Landfill Management
County Public Works is in the process of closing all the active county
landfills. Solid waste that is not recyclable or compostable will be
incinerated.

County Public Works is preparing an environmental impact state-
ment for the proposed Georgia-Pacific Evergreen Wood Waste
landfill.
Education
County Public Works is willing to participate in a volunteer storm
drain  stencilling project.  Storm drains that discharge to streams
will be stenciled with educational  messages to prevent intentional
dumping of oil and other contaminants.
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                                                       1991 Action Plan for Bellingham Bay
Whatcom County
Planning Department
The Whatcom County Planning Department (County Planning)
participates in a variety of environmental planning efforts.
Nonpoint Source
Management
The county has an ordinance for regulating impacts from forest
clearing operations.  This ordinance requires that a clearing permit
be issued by County Planning even if the clearing operation is
regulated under the Forest Practices Act. This clearing permit may
include conditions to protect water  quality or habitat.   Forest
clearing operations for single family houses are exempt from the
ordinance.
Shoreline Management
County Planning has recently revised the Shoreline Master Plan for
Whatcom County.  This revision is the first comprehensive update
to the Shoreline Master Plan in over 6  years.  Major issues
addressed in the revision include siting moorage and community
docks, increasing public access, increasing drainage provisions, and
determining approaches to modify present development setbacks.
The revised plan was recently adopted by the county council.
 Wetlands Protection
Activities
The county has completed a wetlands inventory through an aerial
photograph survey.  An ordinance to help protect wetlands is being
developed by County Planning.
 Water Quality
 Protection Activities
County Planning and County Public Works are developing a water
and sewer plan as part of a comprehensive land development plan.
The water and sewer plan will address groundwater and surface
water protection.  Issues to be covered in the plan include jurisdic-
tional conflicts  over regulatory authority; water rights for the
Nooksack River and county groundwater supplies; and water quality
impacts from logging, agriculture, development, and waste dis-
posal.   As  part of the plan,  a Nooksack River study  will be
conducted to evaluate the pattern of groundwater and surface water
interchange.  This study will be completed by June 1992.
Hazardous Waste
Management
County Public Works, together with City Public Works and County
Health, operates a model household hazardous waste program. The
program includes a permanent drop-off site for household hazardous
wastes.

County Planning has also discontinued its use of herbicides in areas
considered environmentally sensitive, including the Lake Whatcom
watershed.
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1991 Act/on Plan for Bellingham Bay
Whatcom County
Health Department
County Health has responsibilities for environmental and human
health protection.
Nonpoint Source
Management
From January to July 1990, County Health conducted a Lake
Whatcom watershed sewage disposal survey.  The  survey was
conducted in response to the identification of onsite sewage disposal
as a concern in the Lake Whatcom Management Plan.  The results
of the survey show a failure rate of 8 percent. Onsite sewage system
failures occur when sewage is not properly distributed to the
drainfield and, therefore, receives inadequate treatment. The sur-
vey includes the following  recommendations for areas with the
highest failure rates:

   •  Conduct a more intensive survey of older seasonal
      residences during the months of June, July, and August.
      Inadequate systems should be upgraded to conform as
      closely as possible to current standards.

   •  Consider the extension of public sewer service into the
      Academy and Haggin streets and Toad Lake Road areas.

   •  Initiate a public education program to encourage proper
      septic system maintenance.  Mail brochures describing
      septic  system functions and proper maintenance to all
      residences with onsite sewage disposal systems in the
      watershed. Maintain a list of all such residences in a
      computer  database  and send septic tank pumping
      reminder notices every 3-5 years.

   •  Perform an onsite sewage disposal survey within the
      watershed at least once every 5 years.

As a result of these recommendations, the city of Bellingham now
charges a fee of 0.5 cent/gallon of sewage from onsite sewage
systems pumpouts that is deposited at the Post Point WWTP. The
money generated from this fee is dedicated to the septic tank system
maintenance and education program. There is no cap on the total
amount collected each year.  The estimated amount to be collected
in 1991 is about $18,000.  All dwellings with failing onsite sewage
systems found during the  Lake Whatcom survey have been resur-
veyed, and the necessary repairs were made to them so that all are
in compliance with sewage control regulations.  No schedule has
been set for public sewer installations or future onsite sewage system
survey work.
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                                                       1991 Action Plan for Bellingham Bay
                           County Health requires that all septic tank drainfields located within
                           the Lake Whatcom watershed have at least 4 feet vertical separation
                           (i.e.,  the vertical distance between the drainfield and groundwater)
                           and be located where the slope is not greater than  15 percent.
                           Outside the Lake Whatcom watershed, a minimum vertical separa-
                           tion of 2 feet is required. These requirements equal or exceed the
                           state's current requirements.  In addition, County Health operates
                           a training program for new inspectors that ensures that systems are
                           installed properly.
Landfill Management
County Health issues permits for landfills and is responsible for
monitoring when required.

There are over 20 closed and 5 active landfills in Whatcom County.
Ecology regulations mandate that landfills that have been closed
since 1985 must  have groundwater monitoring  systems and
implementation schedules.  Currently, of the 20 closed landfills,
Cedarville is the only facility being monitored.  Monitoring results
there show  some groundwater contamination. Active landfills must
have groundwater monitoring systems in place with approved
closure and post-closure plans. All active facilities are monitored
quarterly.  Active landfills being monitored are Recomp, Olivine,
and Intalco.  Also  being monitored are Airport Wood Waste and
Hilltop Farms Wood Waste, owned by Georgia-Pacific. Each of
these active landfills has closure and post-closure plans.
Human Health Risk
Management
County Health currently does not monitor shellfish in Bellingham
Bay. If funds were available, County Health might set up a marine
water quality monitoring program.

County Health and DOH also may negotiate an MOA that addresses
responsibility for posting warning signs  at recreational shellfish
beaches, if funding becomes available.
Hazardous Waste
Management
County Health, City Public Works, and County Public Works
jointly operate a model household hazardous waste program.  The
program includes a permanent drop-off site for household hazardous
wastes.
Port of Bellingham
The Port operates marinas and boat launches in Squalicum Harbor
and Fairhaven. The Port also operates several terminals throughout
Bellingham Bay and owns and manages properties that are located
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1991 Action Plan for Bellingham Bay
                           within the terminals that are used for commercial and industrial
                           activities.
Storm Water
Management
The Port owns some of the storm drains that are located on its
properties.   The  city of Bellingham and other parties own the
remaining storm drains located on the Port's properties. Material
accumulated in catch basins in the storm drains owned by the Port
is removed at least annually or more frequently, if needed. The
Port encourages the stenciling of information on its storm drains by
the appropriate agency to increase public awareness about dumping
of oil and other contaminants into storm drains that discharge to
creeks or Bellingham Bay.
Nonpoint Source
Management
The Port operates marinas in Squalicum Harbor and Fairhaven
Terminal. The Squalicum Harbor location has two sewage pump-
outs and a waste oil tank for commercial and recreational boats.
Shoreline Management
The Port is considering filing an application for a Shoreline Master
Permit to expand the Squalicum marina and add a hotel with piers
and overwater  access near  Boulevard Park.  The Port is also
considering placing a new marina in Fairhaven Terminal, and a
citizens committee is being  formed to review the proposal.  In
addition, the cruise ship berth in Fairhaven may be expanded beyond
its current use as the Alaska ferry terminal. The Port also plans to
develop a pedestrian walkway along Bellingham Bay near Taylor
Street.
Port Property
Management
The Port will be working with its tenants to minimize the potential
contamination of the properties. Beginning in 1992, the Port will
use a combination of educational techniques, questionnaires, and
field investigations to encourage tenants to employ business prac-
tices that will keep pollutants out of surface water and groundwater.
Copies of applicable environmental regulations will be distributed
to tenants.  The Port maintains a clause in their standard lease that
places responsibility for discharges of hazardous substances on the
tenant.
Hazardous Waste
Remediation
The Port owns property located at the intersection of 4th and Harris
streets that has been contaminated with diesel fuel. The Port has
hired a contractor to  begin  remedial activities  on this property.
Iron-laden surface water runoff from the northwest corner of the
property will soon be diverted to the sewer system.   In addition,
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                                                       1991 Action Plan for Bellingham Bay
                           onsite excavation has revealed a pool of "C"-grade oil.  A new
                           remediation plan to address the contamination is being developed.

                           The Port also owns the property upon which the Tollycraft facility
                           is located.  This property is currently in violation of state dangerous
                           waste regulations and federal land disposal restrictions for hazard-
                           ous waste  and may also be contaminated.  Tollycraft is working
                           directly with Ecology to come into compliance with the regulations
                           and restrictions.
Sampling Activities
The Port sampled sediments from Whatcom Creek, I & J Street,
and Squalicum waterways in September 1990 to determine whether
the sediments could be disposed of at the PSDDA open-water,
unconfined disposal site in Bellingham Bay.  The Bellingham Bay
PSDDA open-water dredged material disposal site has numerous
site restrictions and testing requirements to permit dredged material
disposal (PSDDA 1989).  Based on these evaluation criteria, none
of the sediments from Whatcom Waterway, and only some of the
sediments from the I & J Street and Squalicum waterways, may be
disposed of at the Bellingham Bay PSDDA site. The Port will be
considering all alternatives  for disposal of dredged sediments.
Dredging in the areas of the waterways that are eligible for disposal
at the PSDDA site could begin  in the summer of 1992.

The Port is also conducting sediment sampling at the boat repair
grid located in Squalicum  Harbor.  The sampling results will be
used to determine if boat repair activities are adversely affecting
water quality.  A report will be available in the fall of 1991.
Waste Reduction
Activities
In conjunction with Sea Grant, the Port established recycling
facilities at the Squalicum Marina for cardboard, aluminum, scrap
metal, wood, plastics, nets, and waste oil.
Education
The Port currently publishes a bimonthly newspaper entitled Port
Report. The most recent issue contained the results of a State Parks
recreational boater survey that  included information on the types of
waste disposal equipment and practices used aboard boats and the
facilities and programs  that are needed to control boat wastes.
Future issues of the Port Report will include information on sewage,
used oil and maintenance wastes, litter and plastic debris, safety,
and education.   The Port is willing to feature environmentally
oriented educational information in future issues.
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1991 Action Plan for Bellingham Bay
                          The Port participated in the development of a Sea Grant brochure
                          for boaters that explains the growing problem of marine debris and
                          contains a map of Squalicum Harbor showing the locations of the
                          oil and waste recycling facilities. In addition, the brochure provides
                          information on the proper disposal of plastic and other wastes
                          generated by commercial fishing fleets.
Washington Sea
Grant
Sea Grant provides educational and technical information about
marine resource issues.
Waste Reduction
Activities
Sea Grant worked with the Port to develop improved waste collec-
tion facilities at Squalicum Harbor.  Currently, facilities exist for
the collection of plastics, boat garbage, cardboard, aluminum, scarp
wood and metal, nets, waste oil, sewage, and hazardous materials.
Cardboard, aluminum, and scrap wood and metal are recycled.
Education
With funds received from a PEE grant, Sea Grant published three
education brochures regarding the problems with marine debris and
how recreational boaters  and commercial  fishermen can  help
address this problem. These brochures are available for $0.50 each
through Sea Grant's North Sound office in Bellingham.  Sea Grant
is currently considering reprinting these publications.

Sea Grant is also interested in planning educational efforts to
improve water quality in Bellingham Bay to the extent that Sea
Grant's resources allow.  Sea Grant may participate in education
events depending on the priorities that emerge from the action plan
process, available resources, and existing commitments.
Concerned
Southside Citizens
Concerned Southside Citizens (CSC) is a citizen group concerned
about environmental protection in Bellingham Bay.
Shoreline Management
CSC is cooperating with City Parks to enhance habitat in the
100-foot setback west of Padden Lagoon obtained through CSC's
agreement in 1989 with the Port and the city of Bellingham. CSC
has attended and actively participated in the planning meeting for
this project. The project was recently approved by the Shoreline
Committee of the city's Planning Commission.  Work will begin in
the summer of 1991, and CSC will provide funds and citizen labor.
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                                                        1991 Action Plan for Bellingham Bay
Wetlands Protection
Activities
CSC is working to protect wetlands in the Padden Creek watershed
from proposed development and participated in the scoping process
for an EIS for a proposed 1,400-unit residential development.  CSC
has also participated in workshops to refine a proposed wetlands
ordinance for the city of Bellingham.
Water Quality
Protection Activities
CSC has been involved in evaluating shoreline development projects
that will affect water quality in southern Bellingham Bay.  As a
result of CSC's efforts, the Port is taking quarterly soundings at the
Alaska Ferry Terminal to monitor scouring from ferries. To date,
the soundings reveal that little,  if any, scouring is taking place. If
the soundings continue to show little scouring, they will be discon-
tinued after 1 year.
Hazardous Waste
Remediation
CSC has been involved with the Port to ensure that the cleanup of
the contaminated site at the intersection of 4th and Harris streets
proceeds in a timely manner.
Dredging Activities
CSC is monitoring the status of possible dredging projects in the
Whatcom, Squalicum, and I & J waterways.
Education
CSC is helping to sponsor a political candidate forum on environ-
mental issues that will take place in the fall of 1991.  This forum
will give the public an opportunity to examine candidates running
for county, city, and port offices with regard to their stand on
environmental issues.
Georgia-Pacific
Corporation
Georgia-Pacific maintains an industrial facility that produces pulp
and paper on Port property at the Whatcom International Shipping
Terminal.
NPDES Source
Management
Surface water runoff from the Georgia-Pacific site is collected and
conveyed to the secondary treatment lagoon. Discharge of effluent
from the lagoon to Bellingham Bay is regulated under an NPDES
permit. Georgia-Pacific's NPDES permit was reissued on May 15,
1991.  The permit, which is valid for 5 years, has new requirements
for effluent  toxicity testing,  effluent chemistry analyses,  and
macroinvertebrate sampling near the plant outfall; however, Geor-
gia-Pacific, in conjunction with other pulp and paper industries in
Puget Sound, has contested the new  permit conditions.  The old
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733 / Action Plan for Bellingham Bay
                          permit remains in effect until litigation over the new permit is
                          resolved.
Landfill Management
Georgia-Pacific has the following historic and currently active
offsite wood waste landfills:

   •   Airport Wood Waste (12 acres) - active

   •   Hilltop Farms Wood Waste (30 acres) - active

   •   Y-Road - closed

   •   1178 Marine Drive - closed

   •   Zell Road - closed.

Primary treatment and secondary treatment solid wastes (consisting
of settleable solids, bark, sand, sodium hydroxide, and chlorinated
compounds) have been deposited at the Airport Wood Waste landfill
site.  This site has been active since 1984.  The Hilltop Farms site
has been active since 1976. Currently,  only log yard waste (con-
sisting of bark and dirt) is deposited at the Hilltop  Farms site.
Primary treatment solid waste was also deposited there in the past.
No facility records exist for the two closed sites.  The Zell Road
landfill  was  operated in  the late 1980s on agricultural land. The
landfill  was not  permitted or monitored.  In addition, Georgia-
Pacific  has proposed opening a new landfill at the headwaters of
Ten-Mile Creek.   The site will probably  be used primarily for
clarifier sludge ash and stack ash. County Public Works is prepar-
ing an environmental impact statement for the proposed landfill.
 Waste Reduction and
 Recycling Activities
Georgia-Pacific has reduced its water consumption from 59 to 35
million gallons per day through recycling and new equipment.

Approximately 10 percent of primary treatment solid waste is
currently reused by another local industry.  Other potential outlets
for waste reuse (e.g., fuel) are under consideration.

A project to burn  solid waste residue from primary treatment for
fuel is expected to begin early in 1992.  In addition, a corporate-
wide  review is underway to consider use  of recycled fiber in the
production of tissue products. Georgia-Pacific also has participated
in the Industrial Materials Exchange to find markets for its industrial
by-products.
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                                                       1991 Action Plan for Bellingham Bay
Hazardous Waste
Management
The pulp and paper process results in a variety of waste products.
Bleach pulping wastes, evaporator condensate including methanol
and acetic acid, and papermaking effluents are processed in the
company's aerated stabilization lagoon (treatment pond). Bark and
primary clarifier solids are taken to approved  solid waste  sites.
Mercury-containing brine solids are taken to an approved hazardous
waste site.

Georgia-Pacific has developed a nonchlorine pulp bleaching process
that uses caustic soda, oxygen, and hydrogen peroxide. The present
market for this pulp is primarily in Europe for tissue products.
Additional production of nonchlorine bleached pulp at Georgia-
Pacific will depend on market demand, cost of production, and
regulatory developments.

All large electrical capacitors located at the Georgia-Pacific plant
containing  PCBs have been removed.   Fourteen above-ground
petroleum storage tanks exist onsite, and no underground tanks are
in use. All solvents and waste paints are removed from the site by
a contractor.
Maritime
Contractors, Inc.
Maritime Contractors, Inc. (MCI) operates a ship repair facility that
consists of two dry docks and one marine railway.
Shoreline Management
The company is planning to build an additional pier and extend the
stub pier, owned by the Port, located on the east side of the Alaska
Ferry Terminal.  Neither of these projects will require dredging.
NPDES Source
Management
MCI has applied for an NPDES permit. While the company does
not currently have any storm water facilities, the NPDES permit is
likely to require some measures for containing storm water runoff.
The permit will  cover the entire site and contain monitoring
requirements. Ecology's Water Quality Program is currently draft-
ing the permit.
Best Management
Practices
With assistance from the U.S. Coast Guard, MCI has developed a
hazardous waste management and contingency plan. The plan calls
for containment booms to be in place when pier-side work is
performed and small sorbent booms, sorbent pads, and sorbent
material to be available for upland spill containment. AH employees
will receive training on the plan. MCI also has a spill prevention
control and counter measure plan for the shipyard.
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1991 Action Plan for Bellingham Bay
                          All sandblasting conducted on the dry docks is done with fabric
                          curtains in place.  Dry docks are cleaned of used sandblast grit
                          before they are sunk. The grit is stored in a concrete bunker onsite
                          and is hauled offsite and recycled by a contractor.

                          Oil is stored in one above-ground tank.  Used oil is removed for
                          recycling by a contractor. Commercial cleaners are responsible for
                          taking bilge water from ships that are being repaired.
Hazardous Waste
Management
MCI must follow state requirements for hazardous waste genera-
tion, storage, handling, transport, and disposal.  Hazardous wastes
handled at MCI include sandblast grit, paint residues from cleaning,
still bottoms from solvent recycling, and waste oil.
Bellingham Cold
Storage
BCS owns and operates a seafood processing plant, and has plans
to build a new dry storage plant at the main plant for BFF. They
are currently waiting for permit approval.
Storm Water
Management
The BCS drainage system discharges to Bellingham Bay at approx-
imately  10 locations. The system includes catch basins to collect
sediments but does not include oil/water separators.  The property
is owned by the Port and it is unclear if the Port or BCS is responsible
for the maintenance  of the drainage system.
NPDES Source
Management
BCS discharges noncontact cooling water to Bellingham Bay under
an NPDES permit. Water used to process seafood is discharged to
the Post Point WWTP. BCS has reapplied for a NPDES permit,
and Ecology is currently writing the draft permit.
Best Management
Practices
BCS trains all maintenance, foremen, cleanup, and most forklift
personal in cleanup procedures. BCS maintains a safety committee
which is in the process of drafting a policy that addresses discharg-
ing materials to storm drains. Currently, waste oils are stored in
two onsite waste oil containers that are emptied by a private
contractor.
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                                                        1991 Action Plan for Bellingham Bay
Waste Reduction
Activities
BCS is considering the following activities to reduce its waste
discharge:

   •   Using a closed glycol system for cooling rather than
       water in both engine rooms. BCS currently uses a closed
       glycol system in Engine Room 1.

   •   Using a  chilled  water/chlorination  system in which
       product transfer water is hydro-chilled, screened, and
       chlorinated for reuse. Solids removed through pretreat-
       ment are sent to a Tenderer.
Hazardous
Substances Control
Activities
All transformers at BCS have been changed so that they do not
contain PCBs.  Abandoned fuel tanks at a dock on the site were
removed in 1989.
Bellingham Frozen
Foods
BFF owns commercial vegetable processing operations in Belling-
ham.
Point Source
Management
BFF discharges water used in processing vegetables to the Post Point
WWTP. This discharge is monitored for total suspended solids,
chemical oxygen demand, and solids.

The company is planning to discontinue discharges to the Post Point
WWTP through the use of a land treatment facility where the wastewa-
ter  can  be  applied to the land.  An EIS  has been completed and
appropriate permits have been issued. A draft NPDES permit has gone
through the public comment period and is being finalized. Construction
on the land treatment facility has begun and should be completed in the
fall of 1991. The facility will include a 20-million gallon storage lagoon
that will be used as a retention basin for the wastewater.  Oxygen will
be supplied to the lagoon to minimize any odor. Groundwater at the
facility will be  monitored for nitrate and heavy metals.
Waste Reduction
Activities
In 1988, BFF began recirculating the water used to transport peas
through a closed loop system.  This system hydro-chills and screens
the water and then treats it with chlorine dioxide.  This system has
reduced BFF's water use by 400,000 gallons per day during the pea
season, which lasts about 60 days.  BFF has implemented similar
systems for corn and carrot processing. The system used for corn
processing will reduce water use by about 200,000 gallons per day,
and the system used for carrot processing will reduce water use by
about 120,000 gallons per day.
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1991 Action Plan for Bellingham Bay
                          Site-Specific Action Plan

                          The site-specific action plan addresses areas with known chemical
                          and bacterial contamination and eutrophication and potential con-
                          taminant  sources.  The site-specific  action plan is  intended to
                          prioritize source identification, source control, and remedial activ-
                          ities according to priority problem areas.  Source-specific actions,
                          presented in Table 2, identify specific contaminant sources and
                          source-specific control actions that will be taken to improve envi-
                          ronmental conditions in Bellingham Bay. Sources listed in Table 2
                          are those identified in Bellingham Boy Action Program: Initial Data
                          Summaries and Problem Identification (PTI 1989a) and by the
                          members of the interagency and citizen work group (see Figures 5
                          and 6).  Source characteristics and statuses were identified in the
                          data summaries  document and by work group members. Actions
                          are those activities specifically related to source control or contam-
                          inant remediation that have been agreed upon by the individual
                          agencies in  the work group.  The implementation date lists actual
                          and projected start and finish dates for each action.  Limiting factors
                          represent requirements needed by agencies to implement specific
                          actions.   Blank areas indicate gaps in knowledge of the source
                          characteristics or actions to limit or remediate contamination prob-
                          lems.  One of the ongoing tasks of the work group is  to  further
                          refine priorities and secure commitments from participating agen-
                          cies to perform additional source identification and implement
                          source control measures.

                          Tables 3-8 summarize  general programmatic actions that will be
                          taken  to  improve environmental conditions in Bellingham Bay.
                          There is some  overlap among the programmatic action tables
                          (Tables 3-8), and also between the programmatic action  tables and
                          the source-specific action table (Table 2).  Table 3 lists area-wide
                          planning and program development actions, Table 4 lists pollutant
                          control actions,  Table 5 lists remedial investigations and remedial
                          actions, Table 6 lists sampling and monitoring actions occurring in
                          the project area. Table 7 lists resource protection actions,  and Table
                          8 presents the various educational activities and programs that will
                          be implemented. Each of these tables gives a brief description of
                          the action,  lists the agencies involved, and notes the starting or
                          ending target dates when known. More detail concerning activities
                          in the action column can be found in the Comprehensive  Plans and
                          Programs section of this report.
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                                                             TABLE 2. SOURCE-SPECIFIC ACTIONS
Sources
Characteristics
Type/Name and Status
Corrective Actions
Action Agencies Involved
Target
Date
Limiting
Factors
   NATIONAL POLLUTANT DISCHARGE
   ELIMINATION SYSTEM (NPDES)
   POINT SOURCES
    Wastewater Treatment
    Plants (WWTPs)

    City of Bellingham Post
    Point WWTP
vj
>J
    City of Ferndale WWTP
Primary WWTP; average flow 9.8-11.7 million
gallons per day (mgd); per Consent Decree dated
2/5/88 limitations during food processing season
(i.e.,  July-January) include 230 mg/L  and
22,000 Ib/day  biochemical  oxygen  demand
(BOD). 85  mg/L and  7.0OO Ib/day total sus-
pended solids (TSS),  end 700 fecal  coliform
bacteria/100  mL effluent.   Limitations during
February  through June  include  110 mg/L  and
8.510 Ib/day  BOD, 55 mg/L end 6,000 Ib/day
TSS, and 700 fecal coliform bacteria/100 mL
effluent.  When secondary treatment goes on-
line in 12/93,  weekly average limitations will be
45 mg/L and  3,340 kg/day BOD, 45 mg/L  and
3,340 kg/day  TSS,  and 400 fecal coliform bac-
teria/100 mL.  Monthly average limitations  will
be 36 mg/L and 2,225 kg/day BOD, 30 mg/L and
2.225 kg/day  TSS,  and 200 fecal coliform bac-
teria/100 mL. NPDES permit  to discharge to
Bellingham  Bay expires 3/16/93.   NPDES  dis-
charges to WWTPs must have  a pH within the
range of 6.0-9.0 unless otherwise noted in per-
mit.

Secondary WWTP; average flow 0.6 mgd; limita-
tions include weekly averages of 45 mg/L BOD,
210 kg/day TSS, and 400 fecal coliform bac-
teria/100  mL  effluent.   NPDES permit to  dis-
charge to  Nooksack  River  expires  9/5/94.
NPDES discharges to WWTPs must have a pH
within the range of  6.0-9.0 unless noted in per-
mit.
Review and renew NPDES permit.
Renewed permit will include require-
ments for measuring the level of
toxic chemicals in effluent.

Upgrade WWTP  from primary to
secondary treatment

Meet  ell  requirements  of  NPDES
permit including best management
practices (BMPs)
Review and renew NPDES permit,
include toxic chemical limitations

Meet  all  requirements  of  NPDES
permit including BMPs
Washington Department of
Ecology (Ecology)
                                                                                                               City of Bellingham Public
                                                                                                               Works (City Public Works)

                                                                                                               City Public Works
3/93
                              12/93
                              Ongoing
Ecology


City of Ferndale
9/94
                                                                                                                                            Ongoing

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Target
Action Agencies Involved Date
Limiting
Factors
      City of Lynden WWTP
      City of Everson WWTP
    Hatcheries

  .    Bellingham Hatchery
00
      Nooksack River State
      Hatchery
    Industries

     Bellingham Cold Storage
     (BCS)
Secondary WWTP; average flow 1.3 mgd; limita-
tions include weekly averages of 45 mg/L BOD,
200 kg/day TSS, and 500 fecal  coliform bac-
teria/100 ml effluent.   NPDES permit to dis-
charge  to  Nooksack  River  expires  5/9/93.
NPDES discharges to WWTPs must have a  pH
within the range  of 6.0-9.0 unless noted in per-
mit.

Secondary WWTP; average flow 0.2 mgd; limita-
tions include weekly averages of 45 mg/L BOD,
22 kg/day  TSS, and 400 fecal  coliform bac-
teria/100 mL effluent.   NPDES permit to dis-
charge to  Nooksack  River  expires 4/30/94.
NPDES discharges to WWTPs must have a  pH
within the range  of 6.0-9.0 unless noted in per-
mit.
Hatchery effluent.  Effluent limitation:  679 Ib/
day TSS.  NPDES permit to discharge to What-
com Creek expires 6/30/96.
Hatchery effluent.   Effluent limitations:  27.4
mgd; 4,408 Ib/day TSS. NPDES permit to dis-
charge to Kendall Creek expires 5/17/93.
Review and  renew NPDES permit,
include toxic chemical limitations

Meet  all  requirements  of NPDES
permit including BMPs
Review and  renew NPDES permit,
include toxic chemical limitations

Meet  all  requirements  of NPDES
permit including BMPs
Review and  renew NPDES permjt,
include BOD limitations

Meet  all  requirements  of NPDES
permit including BMPs

Review and  renew NPDES permit,
include BOD limitations

Meet  all  requirements  of NPDES
permit including BMPs
Screened  wastewater  from fish  processing.   Review and renew NPDES permit
Effluent limitation:  daily maximum of  10,000
gallons per day (gpd).  NPDES  permit to dis-   Meet  all  requirements  of  NPDES
charge to Post Point WWTP expires 8/12/93.      permit including BMPs
Ecology


City of Lynden





Ecology


City of Everson
                                                                5/93
                                                                                                                                               Ongoing
4/94
                                                                                                                                               Ongoing
Ecology
Washington Department of
Wildlife

Ecology
                                                                                                                 Washington Department of
                                                                                                                 Fisheries
                                  Ecology

                                  BCS
6/96


Ongoing


5/93


Ongoing




8/93

Ongoing

-------
TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Action Agencies Involved
Target
Date
Limiting
Factors
   Bellingham Frozen Foods
   (BFF)
   Brooks Manufacturing Co.
   Columbia Cement Corp.
   Dahl Fish Co., Inc.
   Georgia-Pacific Corp.
Screened waste water from vegetable processing.
Effluent limitation: daily average of 2.0 mgd.  A
new draft NPDES permit to discharge to Post
Point WWTP is currently being reviewed.
Plant runoff; sump drainage; cooling water from
wood-treating operations.  Effluent limitations:
daily maximum of 100 mg/L total  oils and 0.1
//g/L pentachlorophenol (PCP). NPDES permit to
discharge to Whatcom Creek and Bellingham Bay
expires 6/20/94.

Process  wastewater.    Effluent   limitations:
130.000 gpd; 0.005 pound TSS per  1,000
pounds of product. NPDES permit  to discharge
to Bellingham Bay expires 3/2/93.

Screened  wastewater  from  fish  processing.
Effluent limitation: daily average of  60,000 gpd.
NPDES permit to discharge to Bellingham Bay
expires 7/22/93.

Effluent limitations include 41,300  Ib/day BOD,
62,600 Ib/day TSS, a pH range of  5.0-9.0, and
0.05 Ib/day total mercury (Hg).  NPDES  to dis-
charge to Bellingham Bay was reissued in 5/91.
Review and issue new NPDES per-   Ecology
mit,  include  toxic chemical limita-
tions

Meet all requirements  of NPDES   BFF
permit including BMPs

Construct a  land treatment facility   BFF
that will be used as a retention basin
for   the  wastewater.     Monitor
groundwater for nitrate and heavy
metals.

Review and renew NPDES permit     Ecology

Meet all requirements  of NPDES   Brooks Manufacturing
permit including BMPs
Review and renew NPDES permit

Meet  all requirements  of  NPDES
permit including BMPs

Review and renew NPDES permit

Meet  ell requirements  of  NPDES
permit including BMPs

NPDES  permit  was  reissued  on
5/15/91. The permit has new re-
quirements  for effluent bioassay
tests, effluent chemistry analyses,
and macroinvertebrate sampling near
the plant outfall; however, Georgia-
Pacific has contested the new per-
mit conditions.

Meet all  requirements of the NPDES
permit including BMPs
                                  Ecology

                                  Columbia Cement


                                  Ecology

                                  Dahl Fish Co.
                                  Ecology,
                                  Georgia-Pacific
                                                                7/93
                                                                                                                                             Fall 1991
                                                                                                                                             Ongoing
6/94

TBD'




3/2/93

TBD


7/22/93

TBD
                                                                                                               Georgia-Pacific
                                                                                                             Ongoing

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Action Agencies Involved
Target
Date
Limiting
Factors
      Maritime Contractors Inc.
      (MCI)
 Paint chips, tributyltin,  lead in surface  water
 runoff
      Mt. Baker Plywood, Inc.
      Oeser Company, The
00
O
      Public Utility District #1 of
      Whatcom County
     Schenk Seafood Sales
     Sea-Pac Co., Inc.
     Seawest Industries
 Press pit  oil/water subnatant wastewater and
 boiler blowdown.  Effluent  limitations:  daily
 average of 3,000 gpd; daily maximum of 100
 mg/L total oils and 1.0 mg/L total  phenolics.
 NPDES permit to discharge to Post Point WWTP
 expires 3/14/93.

 Sump drainage, cooling water from wood-treat-
 ing  operations;  steam condensate  and  blow-
 down.  Surface  water limitations: daily  maxi-
 mum of 100  mg/L total oils and 0.1  fjg/L PCP;
 daily average of 10 mg/L total oils. NPDES per-
 mit to discharge to Little Squalicum Creek and
 Bellingham Bay expires 6/20/94.

 Water treatment plant decant water.   Effluent
 limitations: 2.4 mgd; 0.01 mL/L settleable sol-
 ids.  NPDES  permit to discharge to  Nooksack
 River expires  6/26/92.

 Screened  wastewater  from  fish processing.
 Effluent limitation: daily maximum of 8,500 gpd.
 NPDES permit to discharge to Post Point WWTP
 expires 7/26/93.

 Screened  wastewater  from  fish processing.
 Effluent limitation: daily average of 3,000 gpd.
 NPDES permit to discharge  to Bellingham Bay
 expires 7/22/93.

Screened  wastewater  from  fish processing.
 Effluent limitation: daily average of 70,000 gpd.
 NPDES permit to discharge to Post Point WWTP
expires 3/2/93.
Review application for NPDES permit
that will require measures for treat-
ing  and  containing storm   water
runoff and monitoring

Meet all requirements of the NPDES
permit including BMPs

Review and  renew NPDES permit,
include toxic chemical limitations

Meet all requirements of the NPDES
permit including BMPs
Review and  renew NPDES permit,
include toxic chemical limitations
and storm water BMPs

Meet all requirements of the NPDES
permit including BMPs


Review and renew NPDES permit
Review and renew NPDES permit

Meet all requirements of the NPDES
permit including BMPs

Review and renew NPDES permit

Meet all requirements of the NPDES
permit including BMPs

Review and renew NPDES permit

Meet all requirements of the NPDES
permit including BMPs
Ecology




MCI


Ecology


Mt. Baker Plywood


Ecology



Oeser Company


Ecology



Ecology

Schenk Seafood Sales


Ecology

Sea-Pac Co.


Ecology

Seawest Industries
6/92




Ongoing


3/93


TBD



6/94



TBD



6/92




7/93

TBD


7/93

TBD


3/93

TBD

-------
  TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Action Agencies Involved
Target
Date
Limiting
Factors
    OTHER POINT SOURCES

     Combined Sewer Overflows
     (CSOsl/Emergency
     Overflows (EOR

     "C" Street CSO - city of
     Belling ham
     Edgemoor EOF - city of
     Bellingham

     Flynn Street EOF - city of
     Bellingham

     Birch Street EOF - city of
     Bellingham

    NONPOINT SOURCES
Untreated sewage and storm water runoff
Reduce  storm  water intrusion to   City Public Works
limit overflow events to one or less
than one per year
Untreated sewage (one overflow event due to  Installed two new electrical pumps    City Public Works
pump failure)

Untreated sewage (one overflow event due to
vandalism)

Untreated sewage (one overflow event due to  Install backup generator in case of   City Public Works
power feilure)                                power failure
                              Ongoing
                                                               Completed
                                                               TBD
2   Watersheds

     General (applicable to all
     watersheds)
Fecal coliform bacteria-laden surface water from
failing septic systems; nonpoint sources includ-
ing agriculture (dairy), urban, and logging runoff
Develop environmental elements of
comprehensive land use  plan  re-
quired by the  Growth Management
Act
                                                                               Establish county- wide onsite sewage
                                                                               disposal system maintenance pro-
                                                                               gram

                                                                               Install   oil/water   separators  as
                                                                               needed
Whatcom County Planning       Spring 1993
Department (County Planning)
and Whatcom County Depart-
ment of Public Works (County
Public Works)

Whatcom County Health De-     Ongoing
partment (County Health)
                                                                              County Public Works            Ongoing
                                                                               Develop storm water standards

                                                                               Issue and enforce clearing permits
                                                                               for developments involving > 5,000
                                                                               board feet of timber
                                                                              County Public Works

                                                                              County Public Works
                                                               11/91

                                                               Ongoing

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Target
Action Agencies Involved Date
Limiting
Factors
      Nooksack River and
      tributaries:

        - Silver Creek
        - Ten Mile Creek
        - Kamm Creek
        - Bertrand Creek
        - Fishtrap Creek
 Nonpoint  sources including agricultural (dairy),
 urban, and logging runoff; leachate from Cedar-
 villa landfill and illegal dump sites; fecal coliform
 bacteria-laden surface water from failing septic
 systems.
00
rO
Implement  the  Silver Creek  Early
Action Watershed Plan

Implement the Ten-Mile Creek Wa-
tershed Plan
                                              Implement the Kamm Creek Water-
                                              shed Plan

                                              Assist farmers in developing waste
                                              management  plans and implement-
                                              ing BMPs.   Conduct follow-up  in-
                                              spections to ensure compliance with
                                              plans and BMPs.

                                              Complete general NPDES permit  for
                                              concentrated  animal wastes.

                                              Issue and enforce  clearing  permits
                                              for developments involving > 5,000
                                              board feet of timber

                                              Compile  an inventory of  sediment
                                              sources and develop lists of correc-
                                              tive actions to reduce the input of
                                              sediment to streams
Whatcom County Council of
Government (COG)

Whatcom County Conserva-
tion District
(Conservation District)
                                                                                                                    Conservation District
                                                                                                                    Soil Conservation Service

                                                                                                                    Conservation District
Ongoing


7/91




Ongoing


Ongoing
Receipt of
Centennial
Clean Water
Fund grant
for $200,000
                                   Ecology and Interagency Advi-
                                   sory Committee.

                                   County Public Works
                                                                                                                    Lummi Tribe
                                                                                                                                                   8/92
                                                                                                                                                   Ongoing
                                                                                                                                                   Summer or
                                                                                                                                                   fall 1991
                                                                                 Conduct site visits and provide tech-
                                                                                 nical recommendations to foresters
                                                                                 Lummi Tribe
                                                                                                                Ongoing
      Squalicum Creek
Residential storm  water runoff; nonpoint urban
and  industrial  runoff;  fecal  coliform bacteria-
laden surface water from failing septic systems.
Provide technical advice during the
planning stage of a project to pre-
vent activities  that  will  increase
sediment loading to salmon spawn-
ing streams

Draft plan to protect wetlands
                                                                                                                    Lummi Tribe
City Public Works
                                                                                                                                                   Ongoing
                                                                  6/92

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Action Agencies Involved
Target
Date
Limiting
Factors
      Whatcom Creek (including
      (Lake Whatcom)
00
CO
      Padden Creek
     Salmon Net-Pens

      Alaska Ferry terminal


      Squalicum Harbor

      Taylor Dock
Residential,  commercial,  and industrial  storm
water runoff; nonpoint urban industrial and log-
ging runoff; contamination from marinas and
powerboats; fecal coliform bacteria-laden surface
water from failing septic systems; leachate from
landfills in Whatcom Creek vicinity.
Residential and commercial storm water runoff;
nonpoint urban, industrial, and commercial run-
off; fecal coliform bacteria-laden surface water
from failing septic systems.
Nutrient loading and BOD
Nutrient loading and BOD

Nutrient loading and BOD; operates under hy-
draulic project approval (HPA) permit that expires
in 1996
Revise a model ordinance for live-
aboards (i.e., boats used as primary
residences) that deals primarily with
how marinas should  handle black-
water (i.e., sewage) coming from
liveaboard boats
                                                                                 Conduct  an inventory  of  under-
                                                                                 ground fuel storage tanks and de-
                                                                                 velop ordinance regulating the tanks
Issue  and enforce clearing permits
for developments (conversions)

Apply  strict  requirements to  the
construction of septic systems

Develop  policies  regarding public
access,  wildlife,  and  landscape
management in wetlands (based on
a planning study of Padden Creek
and its  associated  wetlands  and
recommended improvements)
Identify and implement BMPs
Identify and implement BMPs
                                                                                 Site to be surveyed again during 5th
                                                                                 year of operation and  prior to  re-
                                                                                 newal of the HPA in 1996
Washington Department of
Heelth (DOH), Washington
State Parks and Recreation
Commission (State Parks),
Washington Department of
Ecology (Ecology), Puget
Sound Water Quality Authority
(Authority)

County Public Works and City
Public Works
                                                                                                                   County Public Works
                                                                                                                   County Health
City of Bellingham Parks and
Recreation Department (City
Parks)
Washington Department of
Fisheries (WDF)

WDF
Conducted a physical and biological   WDF
survey in 8/90
                                                                                                                   WDF
TBD
                                                                                                              Inventory
                                                                                                              completed/
                                                                                                              Ordinance
                                                                                                              has been
                                                                                                              proposed

                                                                                                              Ongoing
Ongoing


Fall 1991
Ongoing


Ongoing

Ongoing


1996

-------
    TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Target
Action Agencies Involved Date
Limiting
Factors
00
      Hatcheries

      Whatcom Creek Hatchery
       Skookum Creek Hatchery

      Landfills

       Airport Wood Waste
       landfill - operated by
       Georgia-Pacific (active)
      Hilltop Farms Wood Waste
      landfill - operated by
      Georgia-Pacific (active)
      Y-Road landfill - operated by
      Georgia-Pacific (closed)
      Zell Road landfill - operated
      by Georgia-Pacific (closed)
      1178 Marine Dr. - operated
      by Georgia-Pacific (closed)
      Whatcom County
      Courthouse vicinity landfill
      (closed)
 Nutrients and BOD
 Nutrients and BOD
 Potential leaching of metals and organic chemical
 contaminants
 Potential leaching of metals and organic chemical
 contaminants
Potential leaching of metals and organic chemical
contaminants
Potential leaching of metals and organic chemical
contaminants
Potential leaching of metals and organic chemical
contaminants
Potential leaching of metals and organic chemical
contaminants
                                              Monitor water quality
                                   WDF
                                                                 TBD
                                                                                  Apply for state general NPDES per-   WDF/Maritime Heritage Center    Ongoing
                                                                                  mil
                                              Identify and implement BMPs         Lummi Tribe
Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding   for  site  hazard   County Health
assessment

Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding  from Ecology  to
conduct site hazard assessment       County Health

Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding  from Ecology  to   County Health
conduct site hazard assessment

Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding  from Ecology  to
conduct site hazard assessment       County Health

Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding  from Ecology  to   County Health
conduct site hazard assessment

Determine if leachate is contaminat-   Georgia-Pacific
ing groundwater or surface water

Pursue  funding  from Ecology  to   County Health
conduct site hazard assessment
TBD



TBD


TBD


TBD



TBD




TBD


TBD



TBD

TBD


TBD


TBD


TBD
                                                                                                                                                                  No funding
                                                                                                                                                                  No funding
                                                                                                                                                                  No funding
                                                                                                                                                                  No funding
                                                                                                                                                                  No funding
                                                                                                                                                                  No funding

-------
TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources

Type/Name
City of Bellingham
landfill - Georgia-Pacific
vicinity (closed)
Shoreline vicinity landfill
(closed)


Lyndon landfill - Nooksack
drainage area (closed)


Cedarville landfill - Nooksack
00 drainage area (active)
01
Characteristics
and Status
Potential leaching of metals and organic chemical
contaminants
Potential leaching of metals and organic chemical
contaminants

Potential leaching of metals and organic chemical
contaminants

Potential leaching of metals and organic chemical
contaminants; surface water runoff
Corrective Actions
Action
Determine if leachate is contaminat-
ing groundwater or surface water
Pursue funding from Ecology to
conduct site hazard assessment
Determine if leachate is contaminat-
ing groundwater or surface water
Pursue funding from Ecology to
conduct site hazard assessment
Determine if leachate is contaminat-
ing groundwater or surface water
Pursue funding from Ecology to
conduct site hazard assessment
Determine if leachate is contaminat-
ing groundwater or surface water
Pursue funding from Ecology to
Target
Agencies Involved Date
County Health
County Health
County Health
County Health
County Health
County Health
County Health
County Health
TBD
TBD
TBD
TBD
TBD
TBD
TBD
TBD
Limiting
Factors
No funding
No funding
No funding
No funding
No funding
No funding
No funding
No funding
  Onstte Sewage Disposal
  Systems

   Chuckanut Bay residential
   area
                                                                           conduct site hazard assessment
Fecal coliform bacteria-laden surface water due  Conduct an inventory of septic tank  County Health
to septic system failures.   Direct drainage to  systems and repair the failing sys-
Bellingham Bay.                              terns

                                           County-wide onsite sewage disposal  County Health
                                           systems maintenance program

                                           Loan  program  for homeowners to  County Planning
                                           improve,  replace,  or  repair  septic
                                           system
TBD



Ongoing


Ongoing
No funding

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Target
Action Agencies Involved Date
Limiting
Factors
00
0>
      Marine Drive (Birchwood)
      vicinity
Terminals and Marinas

 Port of Bellingham terminals:

  - Fairhaven
  - Hilton
  - Parkway
  - Squalicum Harbor
  - Whatcom International
   Shipping
     Alaska State Ferry terminal
     located in Fairhaven
                              Fecal coliform bacteria-laden surface water (over   Conduct an inventory of septic tank   County Health and property
                              20,000  organisms/100 mL  in  drainage  ditch   systems and repair the failing sys-   owners
                              samples). Direct drainage to  Bellingham Bay.      terns
                                                                                terns

                                                                                County-wide onsite sewage disposal   County Health
                                                                                systems maintenance program

                                                                                Loan program for homeowners to
                                                                                improve,  replace, or  repair  septic   County Planning
                                                                                systems
                                   Potential  sources  of chemical and  biological   Determine types and levels of con-   Port and lessees
                                   contamination                                 taminants present or being released
                                                                                and follow-up actions to be taken
                                                                                Implement storm water BMPs
                                                                                                                  Port and lessees
Performed a site hazard assessment
on Whatcom Waterway to determine   Ecology
potential threat to human health and
the environment
                              Potential for contaminated water due to  resus-
                              pension  of contaminated  sediment  from pile-
                              driving; turbulence created as ferries maneuver
                              may contaminate waters in immediate and adja-
                              cent areas
Quarterly soundings for depth/sedi-
ment disturbance
Port
                                                                TBD
                                                                                                                                           Ongoing
                                                                                                                                           Ongoing
                                                                 1992
1992

Site hazard
assessment
report com-
pleted 8/91;
site will be
ranked for
cleanup 9/91

Quarterly in
1991
                                             No funding
                                                                                                                                                               Limited staff

-------
  TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corractive Actions
Action Agencies Involved
Target
Date
Limiting
Factors
     Squalicum Harbor Marina
Potential source of metals, sewage, fuel, oil, and   Administer boat sewage  pumpout   State Parks
boater waste                                  grants

                                             Determine types and levels of con-   County Health;
                                             taminants being released and follow-   Port has taken samples at the
                                             up actions to be taken               Squalicum Marina repair grid

                                             Establish oil and other waste collec-   Port
                                             tion facilities
                                                                                                              Ongoing
                                                                                                                                                Report avail-
                                                                                                                                                able fall
                                                                                                                                                1991

                                                                                                                                                Complete
                                                                                                                                                except for
                                                                                                                                                boater repair
                                                                                                                                                waste
                                                                                                                            No funding
     Hilton Marina
00
                                             Establish BMPs for small boat repair   'Port
                                             grids

Potential source of metals, sewage, fuel, oil, and   Determine types and levels of con-   Port
boater waste                                  taminants being released and follow-   County Health
                                             up actions to be taken

                                             Administer boat  sewage  pumpout   State Parks
                                             grants

                                             Establish oil and other waste collec-   Port
                                             tion facilities
                                                                               Establish BMPs for small boat repair  Port
                                                                               grids
    Dredged Material Disposal
    Sites

     Site A
     Site B
Contains contaminated wood fibers and organic
material dredged in 1969 from Whatcom Creek
Waterway.  Nature of contamination is unknown.

Contains sediment dredged in 1966 from the I &
J streets waterway. Sedimentation of this wa-
terway  was probably  due to agricultural and
logging activities upstream.
Sample  sediments  to characterize
contamination and determine what.
if any, actions should be taken
                                                                               Washington Department of
                                                                               Natural Resources (DNR)
                                             Sample  sediments  to characterize   DNR
                                             contamination and determine what,
                                             if any, actions should be taken
                                                                                                                                                TBD
                                                                                                             TBD
                                                                                                                                                Ongoing
                                                                                                             Complete
                                                                                                             except for
                                                                                                             boater repair
                                                                                                             waste

                                                                                                             TBD
                                                                                                             TBD
                                                                                                                                                TBD
                                                                                                                            No funding

-------
   TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
Sources
Characteristics
Type/Name and Status
Corrective Actions
Target
Action Agencies Involved Date
Limiting
Factors
      Site C
      Site D
     Site E
     Site P
     Puget Sound Dredged
°°   Disposal Analysis (PSDDA)
     disposal site
                                  Contains sediment from I & J streets, Squalicum
                                  Creek, and Whatcom Creek waterways
Contains sediment dredged in  1963 from the
Squalicum Creek waterway.  Sedimentation of
this waterway was probably due to agricultural
and logging activities upstream.

Contains sediments and sludges dredged in 1974
from Whatcom Creek Waterway.
Contains sediments from 1981 dredging of the
inner tidal flats of the mouth of Squalicum Creek
Will contain dredged material that passes the
PSDDA criteria for unconfined, open-water dis-
posal
Sample  sediments  to  characterize
contamination and determine what,
if any, actions should be taken

Sample  sediments  to  characterize
contamination and determine what,
if any, actions should be taken
Sample  sediments  to  characterize
contamination and determine what,
if any, actions should be taken


Sample  sediments  to  characterize
contamination and determine what,
if any, actions should be taken

Determine if dredged material passes
PSDDA criteria for unconfined, open-
water disposal

Conduct  chemical  and  biological
monitoring

Conduct physical monitoring
                                                                               DNR                           TBD
                                                                                                                 DNR                           TBD
                                                                                                                 Georgia-Pacific                 TBD
                                                                                                                 Port                           TBD
DNR, Ecology, U.S. Environ-     Ongoing
mental Protection Agency,
U.S. Army Corps of Engineers

DNR                          Ongoing
                                                                                                                 U.S. Army Corps of Engineers    Ongoing
  * TBD - to be determined.

-------
    TABLE 2.  SOURCE-SPECIFIC ACTIONS (Continued)
                                                        POTENTIAL SOURCES TO BE INVESTIGATED BY ECOLOGY
oo
to
Absorption Corp.
Advanced Combustion
Allied Transmission
Al's RV Service
Bellingham Chemical
Bellingham Chrysler/Bellingham Mitsubishi
Bellingham Collision
Bellingham Detail
Bellingham Herald
Bellingham Marine  Service
Bellingham Transmission
Bill Bailey Tires
Bob's Texaco
Bomac Machine
Bond's Texaco Service
Bucks Texaco
Capp'n Glass Boat Works
Chemical Services  Northwest
Coastline Equipment
Coca-Cola Bottling Co.
Colt Construction
Concur & Pittman
Dewey Griffin
Oiehl Ford
Ferrotek
Fishwrapper (The)
Foreign Auto Repair
German Car Repair
Grand Central Collision
Harmony Motor Works
Hawley's Boats
Heath Technica
Herb McNutt Auto Service
Higher Plane Cabinets
Hilton Harbor Marine
Hunnicutt's Truck Shop
Hydro Chem
Hydro Swirl
Import Motors
Ipero Construction
Marine Services Northwest
McClusky's Auto Body/Radiator
Mill's Auto Repair
Minute Lube
Motor Weld
Mustang Floatation
Myers Northwest
Nordan
North Cascade Machine and Fabrication
Northland Diesel
Northwest Honda
Northwest  Marine   Fabrications/ALFA
Aluminum Fabrications
Old Fairhaven Parkway Chevron
Olson Auto Body
Pacific Printing
Padden Creek Marine
Penderson Bros Inc.
Phillips Furniture
Precision Tune
Rainbow Auto & Paint
Ray's Auto Repair
RC Automotive
Rising Sun Motors
Roger Joby Motors
S&F Auto Body
SCINTILLA
Smitty's Auto
Special T Sign Co.
Strider Construction
Sunshine Printing
Timber Haulers
Tri County Engine Inc.
Trottners Mobile Auto Repair
Union Printing
V-Twin Supermarket
Weekly Construction Reporter (The)
Wafer Truck Parts
Weld Craft
West Coast Marine Services
Western Concrete Pumping
Western Roofing
Whatcom Skagit Crane Services
Whatcom Special Transport
Whatcom Tire Center
Whole Sale Auto
Wight Corp.
Wilder Construction
Woodcraft by Terry
Wright Bros./Sea Sport Boats

-------
                                           TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS
                                        Action
                                                                                Agencies Involved
                                  Target Date"
  Limiting Factors
CO
O
        Developed Puget Sound Water Quality Management Plan
        Develop Squalicum Creek watershed plan

        Develop Memorandum of Agreement (MOA) between Whatcom County Health
        Department (County Health) and Washington Department of Health (DOH) to
        sample shellfish and post signs at contaminated recreational shellfish beaches

        Administer boat sewage pumpout grants
Storm water and drainage utility  established (fees based on one-time fee for
amount of impervious surface created; erosion and sediment control plans re-
quired)

Establish county storm water district to address  water quality and  quantity
problems (including sedimentation and erosion control)


Create development standards for all port-owned or administered properties

Complete general National  Pollutant Discharge Elimination System  (NPDES)
permit for concentrated animal wastes


Adopt revisions to Whatcom County Shoreline Master Program


Complete, review, and adopt comprehensive land use plan
                                                                         Puget Sound Water Quality         Adopted 5/91
                                                                         Authority (Authority)

                                                                         To be determined (TBD)            TBD

                                                                         County Health, DOH               TBD
Washington State Parks and       Ongoing
Recreation Commission (State
Parks)

City of Bellingham Department     Ongoing
of Public Works (City Public
Works)

Whatcom County Public Works     TBD
Department (County Public
Works)

Port of Bellingham (Port)           TBD

Washington Department of Ecol-   August 1992
ogy (Ecology) and Interagency
Advisory Committee

Whatcom County Planning  De-     12/90
partment (County Planning)

City of Bellingham Planning and    TBD
Economic Development Depart-
ment (City Planning), County
Planning,  and resource agencies
                                                   No lead agency

                                                   No funding for local
                                                   participation
Awaiting public
discussion and
county approval
       Establish lead agency  (e.g., Whatcom County Public  Utility District #1) to
       address and coordinate water quality issues

       Issue land clearing permits for clearing operations  not under the Washington
       Department  of National Resources (DNR) jurisdiction

       Review shoreline master programs and shoreline permits
                                                                         Whatcom County Council


                                                                         County Public Works


                                                                         Ecology
                                 TBD


                                 Ongoing


                                 Ongoing
Limited staff and
funding

-------
TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS (Continued)
                                 Action
      Agencies Involved
                                                                                                                 Target Date*
                    Limiting Factors
 Developed highway surface water runoff rule
 Develop transboundarv pollution controls and resource protection activities
      Negotiate MOA between Ecology and DNR addressing liability and responsibility
      for investigation and cleanup of state-owned and state-leased lands
      Negotiate port management agreement to assign management responsibilities
      (including liability) of state-owned lands contained within Port operations
      Develop rules, guidelines, and model ordinances for storm water
      Develop a best management practices (BMPs) manual for storm water
      Develop storm water management requirements for cities with populations less
      than 100,000
2    Create development standards for the Lake Whatcom watershed

      Develop critical areas protection ordinance
 Review and approve local wetland protection plans
 Developed sediment quality standards, dredged disposal criteria, and remedial
 action criteria
 Conduct an inventory of underground fuel tanks in the Lake Whatcom water-
 shed and develop ordinance regulating these tanks
 Survey areas within the Bellingham  Bay watershed with known failing septic
 tank problems
 Conduct an inventory of storm drain  systems within the Lake Whatcom water-
 shed;  incorporate  this information  into capital improvement  programs and
 develop maintenance programs
Ecology and Washington De-
partment of Transportation
(DOT)
U.S. Environmental Protection
Agency (EPA), Ecology, National
Marine Sanctuary Program
DNR and Ecology
                                                                          DNR and Port

                                                                          Ecology
                                                                          Ecology
                                                                          EPA
                                                                          City Public Works and County
                                                                          Public Works
                                                                          City Planning
Authority and Ecology
Ecology

County Public Works and City
Public Works
County Health

County Public Works and City
Public Works
Adopted 5/91

Ongoing

Ongoing

Ongoing

11/91
11/91
1992
Adopt summer
of 1991
12/31/91 (end
of review per-
iod)
3/92 (interim
ordinance)
8/91
Completed

Inventory com-
pleted/ ordi-
nance has been
proposed
TBD
Ongoing
                                                  Field confirmation
                                                  of wetland inven-
                                                  tory data needed
                                                                                                                                  No funding

-------
      TABLE 3.  PLANNING AND PROGRAM DEVELOPMENT ACTIONS (Continued)
                                       Action
                                                                               Agencies Involved
                                  Target Date'
                    Limiting Factors
CO
10
Investigate the possible designation of north Puget Sound (including Bellingham
Bay) as a national marine sanctuary

Revise model ordinance for boater waste disposal
Develop and adopt land clearing ordinance that is water quality protective
Revise the thresholds for the State Environmental Policy Act (SEPA)
Develop a Squalicum Creek drainage improvement plan
Establish stream protection ordinance regarding livestock  management
Provide guidance on the disposal of materials derived from storm drain system
maintenance
Add conditions  to state  leases to prevent and/or remediate contamination of
state-owned aquatic lands
Administer watershed management plan grants
Approve watershed management plans
Renew expired state waste discharge and NPDES permits

Finalize recreational shellfish plan for Puget Sound
Complete BMPs policy
Participate in the protection  of water quality through attendance at public
meetings, reviewing pertinent documents, and involvement in field projects
Ecology and the National Oce-
anic and Atmospheric Admin-
istration
DOH and State Task Force
City Planning
City Planning
City Public Works
City Planning
Ecology

DNR and lessees

Ecology
Ecology
Ecology

Ecology and DOH
Bellingham Cold Storage
Concerned Southside Citizens
Ongoing

TBD
TBD
TBD
6/92
Fall 1991
Winter 1991

Ongoing

Ongoing
Ongoing
Ongoing

October 1991
Fall 1991
Ongoing
                                                                                                                                  No staffing
                                                                                                                                  Limit staffing and
                                                                                                                                  funding
        End date for action, except where noted.

-------
                                                       TABLE 4. POLLUTANT CONTROL ACTIONS
                                      Action
                                                                            Agencies Involved
                                    Target Date*
                          Limiting Factors
CO
(*>
        Apply strict requirements to the construction of septic systems within the
        Lake Whatcom watershed

        Conduct an inventory of and correct failing septic tanks in the Lake What-
        com watershed
        Investigate  sources  of elevated  fecal coliform  bacteria in Chuckanut
        Village stream

        Provide recycling bins at all parks
Provide permanent collection facility for household hazardous waste

Compost and reuse all organic materials collected from park maintenance


Provide permanent collection facility for household hazardous waste

Discontinue use of herbicides in Lake Whatcom watershed
       Implement water quality-sensitive vegetation control program

       Establish  oil  and other waste collection facilities for marina tenants in
       Squalicum Harbor

       Establish best management practices (BMPs) at Squalicum Harbor small
       boat repair grids

       Incorporate the use of environmentally friendly  products for park mainte-
       nance and reduce or eliminate chemical use

       Add staff to perform follow-up inspections to ensure compliance with farm
       waste management plans
                                                                      Whatcom County Health De-
                                                                      partment (County Health)

                                                                      County Health and City of Bell-
                                                                      ingham Department of Public
                                                                      Works (City Public Works)

                                                                      County Health
City of Bellingham Parks and
Recreation Department (City
Parks) and Washington Parks
and Recreation Commission
(State Parks)

County Health

State Parks and City Parks
City Public Works and County
Health

City Public Works and What-
com County Public Works
Department (County Public
Works)

County Public Works

Port of Bellingham (Port)


Port


City Parks and State Parks


Whatcom County Conservation
District (Conservation District)
Ongoing

Completed



TBD

Ongoing
Ongoing

State parks - imme-
diately
City Parks - ongoing

Ongoing
                                                                                                             Complete
                                                                                                     Ongoing

                                                                                                     Complete except for
                                                                                                     boater repair waste

                                                                                                     TBD
                                                                                                      Fall 1991


                                                                                                      Completed (1 staff
                                                                                                      person added)

-------
       TABLE 4.  POLLUTANT CONTROL ACTIONS (Continued)
                                     Action
                                                                           Agencies Involved
                                    Target Date'
                          Limiting Factors
to
-P-
       Apply storm  water management  guidelines  to  developments that are
       subject to hydraulic project approval  permit or that contain  over 5,000
       square feet of impervious surface

       Restrict livestock access to streams with fencing
Work with lessees to minimize potential contamination of their properties
and adjacent waters

Require  or assume  responsibility for construction and maintenance of oil
water separators, catch basins, and other storm water facilities on all Port-
owned or administered properties

Investigate  sources of  elevated fecal  coliform bacteria in stream near
Chuckanut Village

Establish a routine maintenance schedule for storm drain systems

Implement Ecology guidance on the disposal of sediment and decant water
derived from maintenance of storm drain  systems
       Regulate dredged material disposal in Bellingham Bay
       Dredge and dispose of sediments from:

            Squalicum Waterway



            Whatcom Waterway



            I & J Streets Waterway
Washington Department of
Fisheries (WDF)


WDF, Washington Department
of Ecology (Ecology), Conser-
vation District, and private
property owners

Port
                                                                            Port
County Health


City Parks

City Public Works, County
Public Works, City Parks, and
Port of Bellingham

U.S.  Environmental Protection
Agency, U.S. Army Corps of
Engineers (Corps), Ecology,
and Washington Department of
Natural Resources (DNR)
                                                                     Corps and Port
                                                                     Corps and Port
                                                                     Corps and Port
Ongoing



Ongoing




1992


Ongoing



TBD
To be determined
(TBD)


Ongoing
                                Fall 1992
                                TBD
                                Fall 1992
                                                                                                                            Limited funding  and
                                                                                                                            public acceptance
Development of
guidelines by Ecology
                       Half of tested sedi-
                       ments unsuitable for
                       in-water disposal

                       All tested sediments
                       unsuitable for in-
                       water disposal

                       Some tested sedi-
                       ments unsuitable for
                       in-water disposal

-------
      TABLE 4.  POLLUTANT CONTROL ACTIONS (Continued)
CO
01
Action
Under the Model Toxics Control Act (MTCA), investigate hazardous waste
sites and negotiate cleanup actions
Upgrade provisions of National Pollutant Discharge Elimination System
(NPDES) permits that involve toxics monitoring and reduction
Coordinate and implement spill prevention and response activities for
Puget Sound
Comply with provisions of NPDES permit
Comply with provisions of NPDES permit
Agencies Involved
Ecology
Ecology
Ecology
Maritime Contractors, Inc.
(MCI)
Cities of Bellingham, Lynden,
Target Date*
Ongoing
Ongoing
Ongoing
Immediately
Ongoing
Limiting Factors
Limited staff and
funding


Issuance of permit by
Ecology

      Comply with provisions of new NPDES permit
      Pursue opportunities for waste reduction and recycling
      Implement less toxic bleaching process and use recycled paper fibers
      Investigate additional steps that can be taken to prevent sandblast grit and
      other contaminants from entering Bellingham Bay (e.g., via storm drains)

      Establish a storm drain system maintenance program for building complex
      (i.e.. Icicle, BFF, BCS, Trident Seafoods, and San Juan Seafoods)

      Require or assume  responsibility for construction and maintenance  of
      retention/detention basins and oil/water separators for all  new permitted
      construction within the city of Bellingham
and Everson wastewater treat-
ment plants (WWTPs), Geor-
gia-Pacific,  Public Utility Dis-
trict No. 1 of Whatcom County

City of Ferndale WWTP, Bell-
ingham Cold Storage (BCS),
Bellingham  Frozen Foods (BFF),
Sea Pac, Seawest, Schenk
Seafood, Dahl Fish, Mt. Baker
Plywood, Oeser Company,
Brooks Manufacturing, Colum-
bia Crest, Bellingham Hatchery,
and Nooksack State Salmon
Hatchery

Georgia-Pacific,  BCS,  BFF, MCI

Georgia-Pacific
MCI
Port and businesses
City Public Works
TBD
Ongoing

TBD
TBD


Immediately


Ongoing
Issuance of new
permit by Ecology
Need for market
demand of un-
bleached products;
increased production
costs
Determination of
responsibility

Development of
guidelines  by Ecology

-------
      TABLE 4. POLLUTANT CONTROL ACTIONS (Continued)
CO
O)
Action
Construct and maintain retention/detention basins and oil/water separators
for all new municipal development
Encourage use of constructed biofiltration swales for processing storm
water runoff
Enforce conditions of general NPDES permit for concentrated animal
Agencies Involved
City Public Works
County Public Works and City
Public Works
Ecology
Target Date*
Ongoing
Ongoing
Ongoing
Limiting Factors
Development of
guidelines by Ecology
Development of gen-
       wastes


       Conduct enforcement inspections and permitting activities under Agricul-    Ecology
       tural Compliance Memorandum of Agreement

       Establish maintenance programs for all existing public and private storm    County Public Works and City
       drain systems                                                        Public Works
Fund purchase of boater sewage pumpout stations

Construct and maintain oil/water  separators,  catch  basins,  and storm
water systems in unincorporated areas
      Require or assume  responsibility for construction and maintenance for
      retention/detention basins and oil/water separators for all new permitted
      construction in unincorporated areas of Whatcom County

      Conduct an inventory of septic tank systems in other areas of the Belling-
      ham Bay Watershed known to have failing septic tanks. Correct the failing
      septic tank systems.

      Evaluate all NPDES permits to determing loading to Bellingham Bay
State Parks

County Public Works



County Public Works
                                                                     County Health and property
                                                                     owners


                                                                     Ecology
Ongoing


County Public Works
has established main-
tenance schedule for
open drainage
ditches

Annually

Ongoing
                                                                                                    Ongoing
                                TBD
                                TBD
                                                                                                                           era! permit; limited
                                                                                                                           staff and funding

                                                                                                                           Limited staff and
                                                                                                                           funding
Awaiting develop-
ment of guidelines by
Ecology

Awaiting develop-
ment of guidelines by
Ecology

Funding
                       Limited staff and
                       funding
      a End date for action, except where noted.

-------
                                         TABLE 5. REMEDIAL INVESTIGATIONS AND REMEDIAL ACTIONS
                                        Action
         Agencies Involved
 Target Date*    Limiting Factors
CO
          Conducted site hazard assessments for:
            - Whatcom Waterway
            - Little Squalicum Creek
            - Boulevard Park
            - Georgia-Pacific airport landfill
            - Trans-Mountain's pipeline pump station

          Revise 4th and Harris streets site remediation plan and begin treatment or
          containment of surface water runoff

          Comply with state dangerous waste regulations and federal  land disposal
          restrictions at Tollycraft site
Washington Department of Ecology
(Ecology)
Completed
Port of Bellingham


Tollycraft Inc., Port of Bellingham,
Ecology (Solid and Hazardous Waste
Program)
Summer 1991


Fall 1991
Prioritize inspections and conduct initial investigations, including sampling
of water, sediment, and soils, at industrial facilities
Investigate hazardous waste sites and negotiate cleanup actions as re-
quired under the MTCA
Conduct sampling to identify contaminated state-owned aquatic lands
Identify contaminated sediments requiring cleanup
Ecology
Ecology
Washington Department of Natural
Resources
Ecology
Ongoing
Ongoing
Ongoing
Ongoing

Staff


         " End date for action, except where noted.

-------
                                                 TABLE 6. SAMPLING AND MONITORING ACTIONS

-------
       TABLE 6. SAMPLING AND MONITORING ACTIONS (Continued)
                                       Action
Agencies Involved
Target Date'
Limiting Factors
        Under the Puget Sound Ambient Monitoring Program conduct:               Ecology
          - Sediment triad sampling
          - Marine water quality sampling
          - Freshwater quality sampling
        Investigate  cause(s)  of recurrent  Coho salmon mortality  at the Maritime  Ecology
        Heritage Fish Hatchery
        Determine sources of contaminants in city of Bellingham storm drain systems  Ecology
        Establish a marina water quality  monitoring program                        County Health
                        Ongoing (annually)
                        Ongoing (monthly)
                        Ongoing (annually)
                        Monitoring in fall 1991,
                        report spring 1992
                        Fall 1991
                        TBD
                   Funding
         End date for action, except where noted.
CO
CD

-------
                                                      TABLE 7.  RESOURCE PROTECTION ACTIONS
                                   Action
                                                                             Agencies Involved
                                               Target Date'
Limiting Factors
o
o
        Conduct salmon enhancement activities


        Issue hydraulic project approval permits for all construction affect-
        ing state waters, including wetlands

        Review Section 10/404 permits for dredge and fill activities in
        wetlands

        Review shoreline permits and building and rezoning permits for
        development projects
State Environmental Policy Act (SEPA) review

SEPA approval

Protect tribal shellfish beds in Bellingham Bay


Respond to and investigate fish kills
                                                               Nooksack Tribe, Lummi Tribe, Washington Depart-     Ongoing
                                                               ment of Fisheries (WDF)

                                                               WDF, Washington Department of Wildlife            Ongoing
U.S. Environmental Protection Agency                Ongoing


Whatcom County Public Works Department, City of     Ongoing
Bellingham  Planning and  Economic Development
Department  (City Planning),  City of Bellingham
Department of Public Works, Washington Depart-
ment of Ecology  (Ecology)

All agencies                                       Ongoing

City Planning and County Public Works               Ongoing

Lummi Tribe, Ecology, Washington Department of     Ongoing
Health

Ecology and WDF                                  Ongoing
       " End date for action, except where noted.

-------
                                                  TABLE 8. EDUCATIONAL ACTIONS
                              Action
     Agencies Involved
Target Date"
                         Limiting Factors
Continue public  education program to encourage  proper septic system
maintenance

Continue public education program to protect the Lake Whatcom water-
shed (e.g.,  pamphlets, school curriculum, water quality test kits)

Distribute on request the household hazardous waste education pamphlet
Expand Lake Whatcom education program regarding water quality-friendly
gardening
Provide watershed interpretive displays along trails adjacent to streams
and public waterfront areas (e.g.,  Padden Creek)

Distribute information about facilities at Squalicum Harbor for disposal of
waste oil. toxics, and other waste
Distribute boating survey summary flyers
Continue providing spill prevention and response education programs


Provide educational signs to marinas with pumpout stations

Distribute/present boater education information on boater waste manage-
ment
Develop educational  materials on shellfish contamination at recreational
beaches
Provide funding to local agencies for  public involvement and education
projects
Distribute Aquatic Land Enhancement Account grants to local agencies for
public education and interpretive projects

Hold workshops to inform agencies of available monies to  provide public
access to shorelines
Whatcom County Health
Department (County Health)

City of Bellingham Depart-
ment of Public Works (City
Public Works)

Whatcom County Public
Works  Department (County
Public Works) (Solid Waste
Division)

City Public Works


City of Bellingham Parks and
Recreation Department  (City
Parks)

Port of Bellingham
Washington State Parks and
Recreation Commission
(State Parks)

Washington Department of
Ecology (Ecology)

State Parks

State Parks and Washington
Sea Grant (Sea Grant)

Washington Department of
Health  (DOH)

Puget Sound Water Quality
Authority

Washington Department of
Natural Resources (DNR)

DNR
Ongoing

Ongoing


Ongoing
To be determined
(TBD)

Will request additional
funding in 1992 bud-
get

Summer 1991
Ongoing



Ongoing (continued
schedule TBD)

Ongoing

Ongoing


1990 (as requested)


Ongoing


Ongoing


Ongoing

-------
         TABLE 8.  EDUCATIONAL ACTIONS (Continued)
                                      Action
     Agencies Involved
    Target Date*
 Limiting Factors
O
ro
         Distribute grants for public involvement under Model Toxics Control Act
         Post recreational shellfish harvest advisory signs where appropriate

                 •
         Publish a quarterly newsletter on farm practices
         Produce and distribute videos on farm waste management (waste pond
         management and maintenance and waste use)
         Distribute funds for waste reduction and recycling educational activities
         Hold presentations or workshops  pertaining to Ecology regulations or
         programs
         Reprint and distribute marine debris educational pamphlets at no charge
         Participate in educational planning efforts and events
Ecology
County Health, DOH, City
Parks
Whatcom County Conserva-
tion District (Conservation
District)
Conservation District and
Cooperative Extension
Ecology
Ecology

Sea Grant
Sea Grant
Ongoing
TBD

12/91

Summer 1991

Ongoing
Ongoing

TBD
TBD
Finalization of
Memorandum of
Agreement
Limited staff and
funding
        " End date for action, except where noted.

-------
Planning and Coordination,  Pollution  Control, and
Data  Needs
                         The Site-Specific Action Plan tables (Tables 2-8) present a sum-
                         mary of many ongoing and needed activities to improve water
                         quality in Bellingham Bay.   Several planning and coordination,
                         pollution control, and data needs are either not addressed in the
                         action plan or are found in the action plan but have no committed
                         agency or time frame for completion.  This section summarizes
                         these additional water quality needs for Bellingham Bay, and will
                         provide a beginning framework for Action Team discussions and
                         individual agency actions. Both are needed to address further data
                         needs, and to coordinate actions for controlling contaminant inputs
                         to Bellingham Bay.
                         Planning and Coordination Needs

                         Ecology needs to work towards a geographic focus for review and
                         reissuance of NPDES permits. If all permits for Bellingham were
                         evaluated at the same time, the permit review process could be used
                         to determine the total quantity of pollutants entering the bay.  This
                         bay-wide pollutant loading information could be taken into consid-
                         eration when reissuing these permits. For NPDES permits, Ecol-
                         ogy also needs to develop and include BMPs specific to the industry
                         being permitted.

                         Ecology needs  to prioritize discharges to Bellingham Bay.  The
                         discharges should be prioritized by toxicity, type of contaminant,
                         volume, and contaminant concentration. This would help to focus
                         resources on the discharges of greatest concern.

                         Ecology and DNR are continuing to negotiate the terms of a
                         Memorandum of Understanding concerning the roles of each agency
                         when considering sediment contamination on state-owned aquatic
                         lands.  This memorandum needs to be finalized so that future
                         cleanup activities can proceed in a timely manner.

                         DNR and the Port of Bellingham are currently negotiating a Port
                         Management Agreement which  will  address liability for cleanup of
                         contaminated aquatic lands.  This agreement needs to be finalized
                         to ensure that future cleanup activities proceed in a timely manner.
                                                    103

-------
Planning and Coordination, Pollution Control, and Data Needs
                           An MOA between DOH and County Health needs to be developed
                           delineating responsibilities of the two agencies in the implementa-
                           tion of the Recreational Shellfish Rule (Chapter 248-52).  The rule
                           states that a "joint plan of operation" should be developed to outline
                           how recreational  shellfish beaches will be managed.  However,
                           Whatcom County has limited funds to take on additional responsi-
                           bilities. This issue needs to be resolved and the requirements of the
                           recreational shellfish rule carried out.

                           Enhancement of both water quality and aquatic habitats should be
                           the key elements in planning for the future development of Belling-
                           ham's urban waterfront.  As the city of Bellingham continues to
                           grow and as port activities change in response to changing economic
                           conditions, land uses along the urban shoreline will inevitably
                           change. The City of Bellingham and the Port of Bellingham need
                           to develop a common vision for the future of the  community's
                           waterfront. That vision should provide for protection and enhance-
                           ment of water quality and aquatic habitat.

                           Standards for development in the city of Bellingham  and Whatcom
                           County, and on Port of Bellingham property need to  be created.
                           These standards should address storm water quantity as well as
                           storm water quality issues. Ecology is developing rules, guidelines,
                           and model ordinances for storm water as well as a BMP manual. These
                           documents are expected to be completed by November  of 1991.

                           The City of Bellingham and Whatcom County need to develop a
                           storm and surface water utility to focus on water quantity and quality
                           issues.  The utility could be funded entirely by user  fees.  The
                           establishment of such a utility would enable the pursuit of actions such
                           as the creation of development standards and the creation  of a regular
                           maintenance program for both public and private storm drain systems.

                           City Public Works and County Health need to coordinate activities
                           regarding water quality and hazardous substances.  This is import-
                           ant because upstream activities in Whatcom County can  affect water
                           quality in the city of Bellingham.  Specifically, these two agencies
                           need to work together to identify  and mitigate the sources of elevated
                           fecal coliform bacteria found in creeks within the Bellingham city limits.

                           The City of Bellingham, Whatcom County, and the Port of Belling-
                           ham need to identify and develop BMPs for activities which could
                           be adversely affecting the environment. For example the City needs
                           to develop a water quality protective land clearing ordinance, the
                           Port guidelines for their boat repair grid at Squalicum Harbor, and
                           the County an ordinance to limit livestock access to surface waters.
                                                        104

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       Planning and Coordination, Pollution Control, and Data Needs
The educational efforts implemented by the City of Bellingham for
the Lake Whatcom watershed need to be expanded to address the
entire Bellingham Bay watershed.  Potential lead agencies include
City Public Works, County Public Works, and COG.

All agencies need to look for opportunities to implement the actions
described in this plan and any other actions which could improve
the quality of water in Bellingham Bay.  Opportunities may exist in
other plans and programs.

All agencies and the communities of Bellingham and Whatcom
County need to develop a sense of stewardship towards Bellingham
Bay.  Numerous beneficial uses of the bay provide an increased
quality of life.  By preventing further environmental degradation
and addressing problems early, agencies and citizens can ensure
protection for the bay that is both cost-effective and long term.
Pollution Control Needs

The landfills listed in Table 2 of this plan need to be prioritized for
environmental audits or site hazard assessments. These investiga-
tions will determine the potential threat the site has to human health
and the environment. The prioritization should begin immediately
and a  schedule developed for  accomplishing these assessments.
This work should be done by Georgia-Pacific and/or County Health
for the Georgia-Pacific  landfills and by County Health for the
remaining landfills.  Funds are available through Ecology for local
health departments to perform site hazard assessments.

Areas known to have failing septic systems in the Bellingham Bay
vicinity should be investigated and repaired. Sources of funds need
to be actively pursued and a civil penalty created to aid in the
achievement of this  goal.  Potential lead agencies include County
Health and County Planning.

Ecology and identified potentially liable persons need to work
towards the remediation of Whatcom Waterway, Little Squalicum
Creek, Boulevard Park, Georgia-Pacific Airport Landfill, and
Trans-Mountain's pipeline pump station.

To reduce the amount of pollution being discharged to Bellingham
Bay from storm drains, City Public Works, County Public Works,
and the Port of Bellingham need to:
                            .105

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Planning and Coordination, Pollution Control, and Data Needs
                              •  Perform drainage basin source tracing studies, which
                                 include:

                                 -  Monitoring storm drains to characterize contami-
                                    nants being discharged
                                 -  Correlating contaminants associated with particular
                                    land uses to determine potential sources

                              •  Work with dischargers identified in source tracing stud-
                                 ies to target and implement BMPs

                              •  Develop and implement a routine maintenance program
                                 for all storm water facilities (including those privately
                                 owned in the city and county).

                          The Port of Bellingham needs to clearly delineate maintenance
                          responsibility for  storm drains located on their properties.  If that
                          responsibility is  not the port's, a regular maintenance program
                          should be required of lessees.
                          Data Needs

                          Data are needed on nutrient and contaminant inputs to Bellingham
                          Bay from the Nooksack River. The river contributes a large volume
                          of freshwater to Bellingham Bay and could be a significant source
                          of contaminants. Potential lead agencies include the Lummi Tribe
                          and County Planning.

                          Sediment sampling is needed at the dredged material disposal sites
                          shown on Figure 6 (see Numbers 28a, 28b, and 28c in the legend)
                          to characterize contamination and determine what action,  if any
                          should be taken. The sampling should be done by DNR for disposal
                          Sites A through D, by Georgia-Pacific for Site E, and by the Port
                          of Bellingham for Site F.

                          Additional sediment sampling is also needed at the Post Point
                          WWTP outfall, the Georgia-Pacific  outfall, and the contaminated
                          area near the Fairhaven shoreline.  A greater range of chemicals
                          should be analyzed for in these  samples and the horizontal and
                          vertical  extent of contamination determined.    Georgia-Pacific
                          should perform  the  sampling at their outfall and  the City of
                          Bellingham at the Post Point outfall.  DNR should  perform the
                          sampling at the contaminated area near Fairhaven.
                                                      106

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References
                          Chapman, P.M., R.N. Dexter, R.M. Kocan, and E.R. Long.  1985.
                          An overview of biological effects testing in Puget Sound, Washington:
                          methods, results, and implications, pp. 344-362. In:  Aquatic Toxicol-
                          ogy, Proceedings of the Seventh Annual Symposium.  Spec. Tech. Rpt.
                          854, American Society for Testing and Materials, Philadelphia, PA.

                          Cochrane, M. 1990. Nooksack delta sedimentation investigation.
                          Lummi fisheries technical report No. 91-1. Lummi Indian Business
                          Council, Department of Fisheries, Bellingham, WA.

                          Cubbage, J.  1991. Bioaccumulation of contaminants in crabs and
                          clams in Bellingham Bay.  Prepared  for Puget Sound Estuary
                          Program, U.S. Environmental Protection Agency and Fran Solo-
                          mon and Lucy Pebles, Northwest Regional Office,  Washington
                          Department of Ecology.  Washington  Department  of Ecology,
                          Environmental Investigations and Laboratory Services, Olympia,
                          WA.

                          PSDDA. 1989. Puget Sound Dredged Disposal Analysis manage-
                          ment plan report:  unconfined open-water  disposal of dredged
                          material, Phase n (north and south Puget Sound). U.S. Army Corps
                          of Engineers, Seattle District, Seattle, WA; U.S. Environmental
                          Protection Agency, Seattle, WA; Washington Department of Nat-
                          ural Resources, Olympia, WA; Washington Department of Ecol-
                          ogy, Olympia, WA.

                          PTI. 1989a.  Bellingham Bay action program: initial data summa-
                          ries and problem identification.  Prepared for the U.S. Environmen-
                          tal Protection Agency Region  10, Office of Puget Sound.  PTI
                          Environmental Services, Bellevue, WA.

                          PTI. 1989b.  Puget Sound Dredged Disposal Analysis: baseline
                          survey  of Phase n disposal sites.  Prepared for the Washington
                          Department of Ecology.  PTI Environmental Services, Bellevue,
                          WA.

                          PTI. 1990.  The urban bay action program approach:  a focused
                          toxics control strategy. Prepared for U.S. Environmental Protec-
                          tion Agency Region 10, Office of Puget Sound. PTI Environmental
                          Services, Bellevue, WA.
                                                     107

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References
                          PTI.  199 la.  Dioxin and furan  concentrations in Puget Sound
                          crabs.   Prepared for U.S.  Environmental Protection  Agency
                          Region 10, Office of Coastal Waters. PTI Environmental Services,
                          Bellevue, WA.

                          PTI.  19915.  Drainage basin source tracing study.  Prepared for
                          U.S. Environmental Protection Agency Region 10, Office of Puget
                          Sound. PTI Environmental Services, Bellevue, WA.

                          PTI and Tetra Tech. 1988a. Elliott Bay action program: analysis
                          of toxic problem areas.   Final Report.   Prepared  for the U.S.
                          Environmental Protection Agency Region 10, Office of Puget
                          Sound. PTI Environmental Services, Bellevue, WA.

                          PTI and Tetra Tech.  1988b.  Everett Harbor  action program:
                          analysis of toxic problem areas.  Final Report.  Prepared for the
                          U.S. Environmental Protection Agency Region 10, Office of Puget
                          Sound. Tetra Tech, Inc., Bellevue, WA.

                          Rensel and PTI.  1991.  Nutrients and phytoplankton  in Puget
                          Sound.   Prepared  for  U.S.  Environmental Protection  Agency
                          Region 10,  Office of Coastal Waters.  Rensel Associates, Seattle,
                          WA and PTI Environmental Services, Bellevue, WA.

                          Tetra Tech.  1991.  Puget Sound sediment reconnaissance survey,
                          1991. Prepared for Washington Department of Natural Resources,
                          Division of Aquatic Lands. Tetra Tech, Bellevue, WA.

                          U.S. COE.  1991.  Memorandum for record:  Decision on the
                          suitability of dredged material tested under PSDDA guidelines for
                          Bellingham maintenance dredging in Whatcom Creek Waterway,
                          Squalicum Creek Waterway, and I & J Street Waterway to be
                          disposed of at the Bellingham Bay nondispersive open water dis-
                          posal site and Rosario Straits dispersive site. U.S. Army Corps of
                          Engineers, Dredged Material Management Office, Seattle, WA.
                                                      108

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Glossary of Terms
      Amphipod
      Anadromous
      Apparent effects threshold
      Benthic
      Benthic community
      Best management practice
      Bioaccumulation
      Bioassay
      Biochemical oxygen demand
      Biota
      Combined sewer overflow
Small shrimp-like crustaceans, such as sand fleas, that
are often benthic dwellers and feed on algae and
detritus.

Migrating up rivers from the sea to breed in fresh
water.  Salmon have anadromous life cycles.

Chemical-specific  sediment concentrations  above
which a particular adverse biological effect is always
found to be statistically significant (P<0.05) for a
given data set.

Pertaining to the bottom of a water body.

A group of interacting species populations found within
the benthic zone.

A method, activity, maintenance procedure, or other
management practice to reduce the amount of contam-
inants entering a water body.

The accumulation of a substance in tissues  of an
organism.  Bioaccumulation of toxic substances may
lead to disease or other health problems and may render
organisms unfit for  human consumption.

A laboratory or field test used to evaluate the toxicity
of a material (commonly sediments or water) by measur-
ing behavioral, physiological, or population response of
organisms.

A measure of the amount of oxygen consumed in the
biological processes that break down organic matter in
water.

The animal and plant life of an area.

A discharge of raw sewage and stormwater, which
occurs when the hydraulic capacity of a combined
sewer line is exceeded.
                                        109

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Glossary of Terms
       Contaminant
       Crustacean
       Diversity
       Effluent
       Elevation above reference
       Erosion
       Estuarine
       Eutrophication
       Gastropod
       Geographic information
       system
       Groundwater
A substance that is not naturally present in the environ-
ment or is present in amounts that can, in sufficient
concentration, adversely affect the environment.

A group of primarily aquatic invertebrate animals
(phyllum Arthropoda, class Crustacea)  with  a hard
exterior skeleton,  segmented body, and paired jointed
limbs, including crabs, lobsters, and amphipods.

The number of species in a community, or a mathemat-
ical index of the variety of species that also accounts
for the relative abundance of each species.

The  liquid that flows out of a facility (e.g., treated
wastewater).

An index  of toxic contamination or biological effects
that is equal to the measured value of a variable (e.g.,
chemical concentration) at a study site divided by the
measured value of the same variable at a relatively
clean reference area.  For measuring impacts on ben-
thic organisms, this index is inverted so that a depres-
sion  below reference  is measured.

Wearing away of rock or soil by the gradual detach-
ment of soil or rock fragments by water, wind, ice, and
other mechanical and chemical forces.

Pertaining to an estuary. An estuary is a semienclosed
body of water where ocean water is diluted by fresh
water.

The biochemical processes in a body of water that result
in high levels of nutrients and low levels of dissolved
oxygen.

A group of invertebrate  animals (phyllum Mollusca,
class Gastropoda) with a shell, including snails, lim-
pets, and abalone.

A computerized  database  system used to integrate
geographic or natural resource information and pro-
duce maps.

Water found in permeable rock layers underground.
                                         110

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                                                                 Glossary of Terms
Habitat
Hazardous waste
Hepatopancreas



Histopathology

Hydrocarbon


Hydraulic permit approval
Infauna

Influent


Intertidal

Invertebrates
     •
Larvae
Lesion
Loading
National Pollutant Discharge
Elimination System
The specific area or environment in which a particular
animal or plant lives.

Any solid, liquid, or gaseous substance which, because
of its source or characteristics, is classified under state
or federal law as hazardous and is subject to special
handling, shipping,  storage, and  disposal require-
ments.

A gland in crustaceans and certain other invertebrates
that combines the digestive functions of the liver and
pancreas of vertebrates.

Study of tissue lesions.

An organic compound composed of hydrogen and
carbon (e.g., petroleum compounds).

Under Washington's Hydraulic Code Rules, approval
is required from Washington Departments of Fisheries
and Wildlife for  construction and dredging activities in
state waters  that support fish life.

Animals living within the bottom sediments.

The liquid that flows into a facility (e.g., sewage into
a wastewater treatment plant).

The area between high and low water marks.

Animals without backbones.

(Singular: larva)-A juvenile stage of fish or inverte-
brates with  a body form that differs greatly from the
adult stage (e.g.,  an oyster larva is a small, free-floating
organism).

An abnormal structural change in the body due to injury
or disease (e.g.,  a liver tumor in fish).

Quantity of a substance that enters a water body during
a specified time  interval (e.g., pounds per year).

A part of the federal Clean Water Act which requires
point source dischargers to obtain discharge permits.
                                    111

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Glossary of Terms
       Nonpoint source contaminants
       Nutrients
       Organic compound
       Paralytic shellfish poisoning
       Pelecypod
       Point source contaminants
       Polychaete
       Polychlorinated biphenyls
       Polycyclic aromatic
       hydrocarbons
       Sediment
Contaminants that enter water from dispersed and often
uncontrolled  sources  (such as stormwater  runoff)
rather than through pipes.

Essential chemicals needed by plants and animals for
growth. Excessive nutrients may lead to water quality
problems by promoting excessive growth and subse-
quent decay of plants such as algae.

Chemical compounds that contain carbon (e.g., petro-
leum hydrocarbon).

An illness, sometimes fatal to humans, caused by a
neurotoxin produced by a type of plankton called
Gonyaulox.  These organisms  proliferate in  blooms
(sometimes called red tides) and can concentrate in
clams,  mussels, and other bivalves.

Also known as bivalves, pelecypods are molluscs that
have two  shells, are  generally  filter  feeders,  and
include clams, oysters, and mussels.

Contaminants from a single source such as a pipe (e.g.,
discharge from a sewage treatment plant or factory).

A large group of segmented worms found in the marine
environment (e.g., feather dusters).

A group of manufactured chemicals including 209
different but closely related chlorinated hydrocarbons.
These compounds are toxic, persistent in the environ-
ment, and are probable human carcinogens.

A class of complex organic compounds, formed by the
combustion of organic material, that are persistent and
widespread in the environment and are known  to cause
cancer. Low  molecular  weight polycyclic aromatic
hydrocarbons have up to three carbon  rings.  High
molecular weight polycyclic aromatic hydrocarbons
have greater than three  carbon rings and are more
carcinogenic than the lower weight polycyclic aromatic
hydrocarbons.

Material that settles to the bottom of a water  body or
collects on the bottom of pipes such as sewers and storm
drains.
                                         112

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                                                                Glossary of Terms
Toxic                          Poisonous,  cancer-causing, or  otherwise directly
                               harmful to life.

Toxic contamination            Presence of toxic substances, often caused by release
                               of metals or synthetic organic chemicals to the envi-
                               ronment.

Washington Ranking Method   A process  used by the Washington Department of
                               Ecology to rank hazardous waste sites and prioritize
                               these sites for cleanup activities.

Watershed                     The geographic region within which water drains into
                               a particular river, lake, or body of water.
                                   113

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        APPENDIX A

   Administrative Record of
Agency Letters of Commitment

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Appendix  A
Table  of  Contents
      Letter to Lummi Tribe                                                  A-l
      Lummi Tribe response                                                  A-4
      Letter to Nooksack Tribe                                                A-9
      Nooksack Tribe response                                               A-l 1
      Letter to Washington Department of Fisheries (Marine Habitat
      Manager)                                                            A-13
      Washington Department of Fisheries response                              A-15
      Letter to Washington Department of Fisheries (Regional Habitat
      Manager)                                                            A-19
      Washington Department of Fisheries response                              A-21
      Letter to Washington Department of Health                                A-23
      Washington Department of Health response                                A-26
      Letter to Washington State Parks and Recreation Commission                  A-33
      Washington State Parks and Recreation Commission response                 A-36a
      Letter to Washington Department of Wildlife (no response)                    A-37
      Letter to Washington Department of Natural Resources                       A-39
      Washington Department of Natural Resources response                       A-42
      Letter to Puget Sound Water Quality Authority                             A-46
      Puget Sound Water Quality Authority response                             A-50
      Letter to City of Bellingham Department of Planning and
      Economic Development (no response)                                     A-56
      Letter to City of Bellingham Department of Public Works                     A-59
      City of Bellingham Department of Public Works (Public Works
      Director) response                                                     A-63
      City of Bellingham Department of Public Works (Public Works
      Superintendent) response                                               A-66
                                      A-ii

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Letter to Bellingham Parks and Recreation Department                         A-68
Bellingham Parks and Recreation Department response                         A-71
Letter to Whatcom County Conservation District                              A-74
Whatcom County Conservation District response                              A-77
Letter to Whatcom County Council of Governments                            A-80
Whatcom County Council of Governments response                            A-82
Letter to Whatcom County Public Works Department                          A-84
Whatcom County Public Works Department response                          A-88
Letter to Whatcom County Planning Department                              A-91
Whatcom County Planning Department response                              A-95
Letter to Whatcom County Health Department                                A-96
Whatcom County Health Department response                               A-101
Letter to Port of Bellingham                                               A-103
Port of Bellingham response                                               A-107
Letter to Washington Sea Grant                                            A-110
Washington Sea Grant response                                            A-112
Letter to Concerned Southside Citizens                                      A-l 14
Concerned Southside Citizens response                                      A-l 17
Letter to Georgia-Pacific Corporation                                       A-l 19
Georgia-Pacific Corporation response                                       A-122
Letter to Maritime Contractors Inc.                                         A-125
Maritime Contractors Inc. response                                         A-127
Letter to Bellingham Cold Storage                                          A-128
Bellingham Cold Storage response                                          A-131
Letter to Bellingham Frozen Foods                                          A-132
Bellingham Frozen Foods response                                          A-134
                                  A-iii

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CHRISTINE O. GREGOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                May 22,  1991
      Mr. Michael T. MacKay
      Lummi Fisheries
      Natural Production Department
      2626 Kwina Road
      Bellingham, WA  98226

           Re:  Bellingham Bay Action Plan

      Dear

      This letter is in follow-up to the August 28,  1990 meeting  that
      Michael Jacobson (PTI Environmental Services), Jacques  Faigenblum
      (EPA),  Fran Solomon (Ecology), and I had with you and Michael
      Cochrane, regarding actions that the Lummi Tribe is  taking to
      reduce pollution in Bellingham Bay.  I have  summarized  below our
      understanding of the Lummi Tribes actions and have asked
      additional questions.  Please confirm or modify the  summary and
      address the new questions through a written  response.   This
      letter, as well as your response, will be included in the
      Bellingham Bay Draft Action Plan scheduled for release  this July.

           Fish Enhancement

           The Lummis operate the Skookum Creek Hatchery and  several
           salmon rearing ponds on the Nooksack River.

           In the summer of 1990, an artificial spawning channel was
           constructed at Maple Falls on the north fork of the Nooksack
           River.  Was this constructed in response to sedimentation
           problems?

           Net pens were being proposed, in conjunction with  the
           Washington Department of Fisheries, at  the Taylor  Street
           Dock as well as at the Alaska Ferry Terminal.   What is the
           status of the net pens?  What environmental processes are
           they subject to?  What is the Lummis role?  What other
           groups or agencies are involved in the  placing  of  net pens
           in Bellingham Bay?

           What other fish enhancement projects do the Lummis have
           planned?
                                     A-1

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Mr. Michael MacKay
May 22, 1991
Page 2
     Shellfish

     With Centennial Clean Water Funds (CCWF),  the Lummis have
     conducted an investigation addressing: the Nooksack delta
     growth rate and its effect on shellfish beds, littleneck
     clam populations along the entire Whatcom County coastline,
     and fecal coliform levels in the Nooksack River and in
     shellfish tissue.  The final report on this effort was
     scheduled to be completed in December of 1990.  What is the
     status of the final report?  Please send me a copy.  What,
     in general, were the results of the investigation?

     The Lummis also assisted the Washington Department of
     Ecology in the collection of crabs and clams for a toxic
     chemicals bioaccumulation study.

     Watershed Management Plans

     Participation by the Lummis in Early Action Watershed
     nonpoint pollution activities has assisted in the
     development of watershed management plans for Silver Creek,
     Tenmile Creek, and Kamm Creek.  These creeks are lowland
     tributaries of the Nooksack River.  What specifically was
     the Lummis role in developing watershed management plans for
     these creeks?

     Stream Restoration

     The Lummi and Nooksack tribes participated in the
     restoration of a short section of Silver Creek.   The
     restoration involved the clearing of canary grass, the
     installation of logs and the creation of a plunge pool.  Are
     there other stream restoration projects planned?

     Sedimentation

     To reduce the effects of sedimentation within critical
     spawning areas in the upper Nooksack watershed,  the Lummis
     are identifying specific corrective actions such as the
     creation of artificial spawning areas.  The Lummis also have
     several ongoing studies investigating the impacts of
     sedimentation on salmon and trout spawning, egg incubation
     and juvenile rearing.  What other projects are planned to
     reduce the impacts of sedimentation?  What is the schedule
     for these projects?  What, in general, are the results of
     your various studies?  Please send me a copy of these
     studies.
                              A-2

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Mr. Michael MacKay
May 22, 1991
Page 3


     Water Quality

     The Lummis, in conjunction with the Whatcom County Planning
     Department, applied for CCWF monies to perform a study of
     the Nooksack River.  The study would establish baseline data
     on the river and assess impacts from logging and
     agricultural practices.  The information gathered would be
     placed on a GIS computer system.  This proposal was not
     selected for funding.  Will another attempt be made to
     obtain CCWF monies, or other monies, to perform this study?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, June 7th.

I appreciate your support of this process and look forward to
your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:Ip
                               A-3

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                         LUMMI FISHERIES DEFT      TO            16497098   p. 0s
                                                 14 June 1991


MS. Lucille Pebles. P.E.
Belleingham Bay Action Program Coordinator
Department of Ecologyt Northwest Region
3190 160th Ave. S.E.
Bellevue, Washington 980008-5452

RE:  Comments to Bellingham Bay Draft Action Plan

Dear Ms, Pebles:

Thank you for this opportunity to provide comments on the Draft Action
Plan.  Included below are resposes to questions you had concerning
actions the Lummi Tribe is taking to reduce pollution to Bellingham Bay.

Q: In the summer of 1990, an artificial spawning channel was constructed
   at. Maple Falls on the north fork of the Nooksack River.  Was this
   constructed in response to sedimentation problems?

A:  Yes, the Tribe developed this project to mitigate for the impacts of
    sedimentation to fisheries in the upper Nooksack River Watershed.
    Investigations by us and others have shown that many of the once
    productive salmonid spawning areas have been impacted by a
    significant increases in sedimentation.  In most cases this has
    resulting from past poor forest practices.  Increased sediment
    loading has occured to the extent that many spawning reaches used by
    salmon become highly unstable.  Instability results in increased
    channel shifting.  This causes a scouring, dewatering, or smothering
    of salmon eggs located within the nest or "redd".  The end result is
    a marked decrease in survival during the overwinter egg incubation
    period.

    The spawning channel was constructed in a location that provides
    protection from channel shifting.  This year the spawning channel
    produced over 34.338 chum fry. The estimated egg-to-fry survival was
    20.9%.  In contrast, eggs from salmon observed spawning in nearby
    sidechannels which had been later dewatered by channel shifting,
    would be expected to have near zero egg survival.


Q:  What were the results of a Lummi Fisheries report investigating the
    growth rate of the Nooksack Delta and the effects on adjacent
    shellfish beds?

A:  The Lummi Fisheries report, "Nooksack Delta Sedimentation
    Investigations" discusses a measurement that was taken and compared
    with historic bathymentric charts of the area.  This measure of
    delta growth was based on the rate of vertical shoaling that occured
    at one location on the outer margin of the delta.  The rate of
    shoaling was found to have increased by a factor of 4.7 for the time
    period 1956-1990 when compared to the period 1888-1956 (0.43 ft./yr.
    & 0.09 ft./yr. respectively).

    This report identifies littleneck clams as one species most at risk

                                      A-4

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    JuN-i, -15'rl  0^:1.4  t->-'.j-\  i_!jf1Mi PiSHEFItD DEri      TO
    from t'he progradaticn of  the delta front  into productive clam beds
    located on the Lummi  Reservation.   Markers placed near these beds
    will be used in the future to monitor  the advance of the delta.
    Aggressive corrective actions for  past forest Practice was
    recommended as one strategx for  reducing  impacts to these shellfish
    beds.


0:  what was the Lummis'  role in developing watershed management plans
    for Silver Creek, Tenmile Creek, and Kamm Creek?

A:  These Early Action Watersheds recieved letters of support from the
    Tribe during the nomination period.  The  Silver Creek proposal was
    nominated bx the Tribe and was awarded Centenial Clean Water funds.
    The grant was administered bx the Whatcom Countx Council of
    Governments at the Tribe's request.  The  Tribe activelx participated
    during the development of watershed plans for all three watersheds.

    The Silver Creek Plan identified a demonstration project that was to
    be undertaken bx the Lummi Tribe with the help of the Nooksack
    Tribe.  This work was completed last fall and resulted in the
    demonstration of several  techniques to restore stream-side
    vegetation and to prevent livestock access.  The final report is
    available from our office.


0:  Are there other stream restoration projects planned?

A:  The Silver Creek Stream Restoration project, discussed above, was
    intended to provide an example of stream  work that is needed in manx
    areas of the Noooksack lowlands.  It was  the Tribe's expectation
    that local governments and the Washington Department of Fisheries
    would take the lead in encouraging this type of stream work for manx
    other areas requiring stream canopx and livestock fencing.  The
    Whatcom Countx Council of Governments has grant monexs available for
    some of this work.

    At present our office does not have the resources to head up stream
    restoration projects.  We would, however  be available to review
    draft project plans and to provide technical recommendations and
    letters of support for work done bx others.  The Tribes Personel
    Department has qualified personel that could be used as a labor pool
    for stream work.  The Nooksack Tribe and/or the Department of
    Fisheries Youth Conservation Corps who assisted us with the fencing
    on the Silver Creek Demo Project and would be excellent choices for
    taking the lead in future stream restoration work.


Q:  What projects are planned to reduce the impacts of sedimentation?

A:  Our Resource Protection Division routinely reviews all forest
    practice applications (FPAs) within the Nooksack Basin.  Our
    biological and geological staffs provide technical recommendations
    to foresters, often after site visits (ID Teams).  Our goal is to
    provide sound technical advise during the planning stage to prevent
    activities which will increase sediment sources, especiallx to

                                       A-5

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                         LUNMI FISHERIES L€FT      TO            16497058    -.04
    sensitive salmon spawning streams.

    We are also conducting sediment source inventories for selected
    sub^water sheds and are developing specific lists of corrective
    actions as that can be taken by land owners to reduce sedimentation
    impacts.

    Enclosed, please find a list of technical reports available from the
    our office.  Let us know which reports you would like.


Q:  Will the Tribe be pursuing other funding sources for developing
    baseline measures for establishing impact from logging *
    agricultural impacts?

A:  The Tribe has sought several federal funding sources to provide
    water quality indicators to measure progress in providing sound
    forest agricultural practices.  Present funding levels allow only a
    limited amount of water quality monitoring.

    High priorities are for determining sediment and nutrient loading in
    the Nooksack and Bellingham Bay and to monitor incidents of nusiance
    algae blooms that occur in the late summer in the lower Nooksack and
    in Bellingham Bay.  We wil also be monitoring the certification
    status of our shellfish beds and will be attempting to determine
    major sources of bacterial contamination that threaten the
    certification of shellfish growing waters.


Q:  Will the Lummi Tribe and What com County Planning Department be
    requesting CCWF funds to provide Nooksack water quality/quantity
    invest igat ions?

A:  There are no plans at present, but the Tribe is committed to provide
    its technical staff with computerized mapping tools and to conduct
    specific investigations to identify resources at risk from
    detrimental changes in water quality/quantity.


I hope this information wjill assist you in the Bellingham Bay Action
Program.  Please call me at 647-6230 if I can provide any additional
information.
                                  Sincerely,
                                  Michael MacKay, Manager
                                  Resource Protection Div.
                                  Lummi Natural Resources
                                    A-6

                                                                   TOTAL P.04

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    JUN-lT-1991  13:1"  FROM   LLM1I i-IbHEKlES DtPT
                        LUMMI NATURAL RESOURCES
                          RESOURCE PROTECTION

                            REFERENCE LIST
                           (Updated 6/17/91 )

Cochrane, Michael and Michael T. MacKax.  1989.  Lummi shellfish pro-
  tection plan.  Report #89-1.  Lummi Fisheries Oept.  Bellingham, WA.
  86p.

Cochrane, Michael.  1990.  Nooksack Delta Sedimentation Investigations.
  Report #91-1.  (from "Impacts of Nonpoint Pollution on Fisheries
  Resources").  Lummi Natural Resources Dept.  Bellingham, WA.   22p.

Cochrane, Michael.  1990.  Nuisance algae bloom investigations  in
  the lower Nooksack River.  Report #91-2.  (from "Impacts of Nonpoint
  Pollution on Fisheries Resources").  Lummi Natural Resources  Oept.
  Bellingham, WA.  18p.

Cochrane, Michael.  1990.  Investigation of fecal coliform bacteria.
  Report #91-3.  (from "Impacts of Nonpoint Pollution on Fisheries
  Resources").  Lummi Natural Resources Dept.  Bellingham, WA.   18p.

Cochrane, Michael.  1990.  Shellfish resource maps of Whatcom Countx.
  Report #91-4.  (from "Impacts of Nonpoint Pollution on Fisheries
  Resources").  Lummi Natural Resources Dept.  Bellingham, WA.   20p.

Dunphx, Gregg S.  1989.  Outmigrant fish trapping in Silver Creek,
  Whatcom Countx, Washington March-April, 1989.  Lummi Fisheries Dept.
  Be11i ngham, WA.  6p.

Dunphx, Gregg S.  1991.  November 1990 flood events: preliminarx
  anadromous salmonid impacts.  Report #91-1.  Lummi Natural  Resources
  Dept.  Bellingham, WA.  7pp.

Dunphx, Gregg S.  1991.  Maple Falls side channel progress report.
  Report #91-3.  Lummi Natural Resources Dept.  Bellingham, WA.  5p.

Dunphx, Gregg S.  1991.  Maple Falls side channel chum salmon overwinter
  survival, evaluation, and outmigration timing studx.  Report  #91-5.
  Lummi Natural Resources Dept.  Bellingham,  WA.  7pp.

MacKax, Michael T.  1983.  1982 Spring Chinook holding pool and redd
  counts from the Nooksack River South Fork.   Lummi  Fisheries.
  Bellingham, WA.  14p.

MacKax. Michael T.  1987.  Using a "Reverse Peterson" method to estimate
  the river escapement of Nooksack Spring Chinook in 1985.  Lummi
  Fisheries Dept.  Bellingham, WA.  15p.

MacKax, Michael T. and R.M. Kocan.  1990.  In situ and laboratorx
  assessment of herring embrxo survival at Cherrx Point, Washington,
  April/Max 1990.  Report #90-1.  Lummi Natural Resources Oept.
  Bellingham,  WA.  17p.

MacKax, Michael T.,  s.S.  Dunphx, and V. Johnson Jr.  1991.  Silver
  Creek Rehabilitation Demonstration Project.  Report #91-5.  Lummi
  Natural Resources Dept.  Bellingham, WA.  21p.

                                      A-7

-------
    Juf i-j. , -isri  ij^i,  ,-,-.61 i   !_url['U r.onepics ^tr ,      iu             lOHaTdSb   r.d,i
PEAK Northwest.  1986.  Nooksack River basin erosion and fisheries
  study: Lummi Tribal Fisheries Department.  Bellingham, WA.  llOp.

Schuett-Hames, J.P. and D.E.  Schuett-Hames.  1984.  Spawning gravel
  fine sediment levels and stream channel stability ratings for salmonid
  streams in the Nooksack Basin, Washington, 1982 and 1983: Lummi Tribal
  Fisheries Department.  Bellingham, WA.  26p.

Schuett-Hames, J.P. and D.E.  Schuett-Hames.  1984.  Juvenile salmonid
  survey of lowland Whatcom County streams, spring 1983.  Lummi Tribal
  Fisheries Department.  Bellingham, WA.  lOp.

Schuett-Hames, J.P. and D.E.  Schuett-Hames.  1987.  North Fork Nooksack
  Spring Chinook surveys: 1986 survey results: a historical count review;
  and habitat observations.  Lummi Tribal Fisheries Department & U.S.
  Fish & Wildlife Service Joint Report.  Bellingham/Olympia, WA.  20p.

Schuett-Hames, J.P., D.E.  Schuett-Hames, M.T.  MacKay, K. Doughty.
  and P. Wampler.  1988.  An Assessment of the Availability and Quality
  of Spring Chinook Holding and spawning habitat in the South Fork
  Nooksack River, 1986.  Lummi/Nooksack Tribal Fisheries Department i
  U.S.  Fish & Wildlife Service Joint Report.
  Bellingham/Demming/Olympia, WA.  20p.

Schuett-Hames, D.E., J.P.  Schuett-Hames and D. Mike.  1988b.  Nooksack  H.
  Basin and associated drainages: stream monitoring data - 1982 to 1987:
  Lummi Tribal Fisheries Deptartment.  Bellingham, WA.  SSp.

Thompson, John N.  1990.  November 1990 flood events: preliminary
  summary.  Report #90-2.  Lummi Natural Resources Dept.  Bellingham. WA.

Whatcom County Conservation District.  1986.  Agricultural impacts on    L.
   water resources in Tenmile Watersheds prepared for Lummi Tribal
   Fisheries Department by Whatcom Conservation District.  Lynden, WA.
   58p.

Whatcom County Conservation District.  1986.  Agricultural impacts on    M.
   water resources in Kamm Watershed: prepared for Lummi Tribal
   Fisheries Department by Whatcom Conservation District.  Lynden, WA.
   48p.

FN:  LUMREF (6/91 )
                                       A-8

                                                                    TOTAL P.03

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CHRISTINE O. CRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190- 160th Ave S.E. • Bellevue, Washington 98008-5452 • (206) 649-7000


                                  May 22, 1991
       Ms. Pat Petuchov
       Nooksack Tribe
       P.O. Box 157
       Deming, WA  98225

            Re: ~Bellingham Bay Action Plan
              /&'
       Dear Ms^Eefcuehov:

       This letter is  in  follow-up to the August 28,  1990 meeting that
       Michael Jacobson  (PTI Environmental Services),  Jacques Faigenblum
       (EPA), Fran Solomon (Ecology), and I had with you regarding
       actions that the Nooksack Tribe is taking to reduce pollution in
       Bellingham Bay.  I have summarized below our understanding of the
       Nooksacks Tribe's  actions and have asked additional questions.
       Please confirm  or  modify the summary and address the new
       questions through  a written response.  This letter, as well as
       your response,  will be included in the draft Bellingham Bay
       Action Plan scheduled for release this July.

            Fish Enhancement

            The Nooksacks have been involved in a number of fish
            productivity  and habitat enhancement projects in the
            Nooksack River and its tributaries.  In July of 1990 a
            portion of Silver Creek just outside the Bellingham city
            limits was restored; in August of 1990, in conjunction with
            the U.S. Forest Service (U.S.F.S.), a jam in Canyon Creek
            was cleared;  revisions to the artificial spawning channel in
            Hutchinson Creek were completed in August of 1990.  The
            Nooksacks  have also received funds from the U.S.F.S. to
            clean out  an  acclimation pond on Dead Horse Creek and to
            perform channel improvements.

            As part of the Nooksack Technical Spring Chinook Committee,
            the Nooksacks were also involved in the constuction of an
            acclimation pond on the north fork of the Nooksack River.
            What other projects are planned by the committee?  What
            other fish enhancement projects do the Nooksacks have
            planned?
                                      A-9

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Ms. Pat Petuchov
May 22, 1991
Page 2


     Watershed Management

     The Nooksacks participate in the Nooksack Watershed
     Cooperative which addresses region-wide concerns affecting
     the Nooksack River.  What projects are currently planned by
     the cooperative?

     What has been the Nooksacks role in recent watershed
     management plans such as Silver Creek, Kamm Creek and
     Tenmile Creek?

     Mon itor ing

     Approximately every two months, the Tribe monitors Cornell,
     Wells, Racehorse, Hutchinson, and Porter Creeks for
     temperature, pH, dissolved oxygen and scouring.  Are fecal
     coliforms or any chemicals being monitored?  Please send me
     a copy of the monitoring results.

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, June 7th.

I appreciate your support of this process and look forward to
your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
ltp:lp
                             A-10

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                                          NOOKSACK INDIAN TRIBE
                                                  P.O. Box 157
                                             Deming, Washington 98244
                                              Telephone (206) 592-5176
Lucille T. Pebles, P.E.
Department of:Ecology
Northwest Regional Office
3190 - 160th Ave S.E.
Bellevue, Washington  98008
                  June 12, 1991

                          RECEWED

                           JUH 1 * m
                           DEPT. OF ECOLOGY
- 5452
Dear Lucille:

This letter is in response to your follow-up letter of May  22,
concerning additional comments to be included in the  the draft
Bellingham Bay Action Plan.


Regarding the first paragraph under Fish Enhancement:  a mud and
log jam shonidd qualify  ..."a jam in Canyon Creek"...
Also, the U.S.F.S. completed'•• the clean out of Deadhorse acclimation
pond, not that the Nooksack Tribe received funds to do this
work.

Additional editing in the second paragraph:  please substitue
"lead agency" fbr.\.',;s, "also involved"... .and subtitue  ..."construction
of an" 	 for "construction of two".  Insert  "in 1989 and 1990"
after ..." the Nooksack  River"...

In answer to:your questions concening Fish Enhancement:

1) what other projects are planned by the committee?

   Deadhorse pond will be useed as an acclimation pond for
   spring chinook and possibly steelhead in the spring
   of 1992.  Possible enhance of the South Fork spring chinook
   run is also planned.       t*WT

2) What other fish enhancement projects do the*, Nooksacks  have
   planned?

   - Rehabilitaion work  at our hatchery at Rutsatz  slough is
     underway.  The facility was damaged during the  flood
     event of 1990. The  facility will feature a spawning  channel for
     chum salmon and possible rearing of steelhead  besides  chum.
                             A-11

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Page 2
   - Brood stock collection for chum eggs in Fall 1991

   - Fall 1991 egg planting in spawning channel of Hutchinson CReek

   - Removal of fish barrier at Canyon Creek, to open up 5+ miles
     of prime fish habitat, as a cooperative effort with USFS, in
     the summer of 1992.

   - Clean up of Anderson Creek - remove 40 years of accumulated
     dumping, in summer of 1991.


The following relates to comments/questions concerning Watershed
Management:

The Nooksack Watershed Cooperative is currently inactive.


The Nooksack's role in watershed management plans:

The Nooksacks have participated in the planning committees on
Silver, TenMIle and Kamm Creeks, and are now getting ready
to implement stream restoration actions.  A new watershed
management committee on Drayton Harbor has been formed and the
Nooksack Tribe is participating on this committee.
I hope that this letter clarifies the additions and comments
we have.  If you have any additional questions, please call
me at 592-5176.
Sincerely,
Pat Petuchov - Fisheries Biologist
                            A-12

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CHRISTINE O. GRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190 • 160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May 17,  1991
    Mr. Brian Williams
    Washington Department
    of Fisheries
    Hillcrest Plaza, Unit  7
    430 - 91st Avenue N.E.
    Everett, WA 98205

         Re:  Bellingham Bay Action Plan
           ^•7/i?'V
    Dear Ifa. Williuma;

    This letter is  in follow-up  to the September 25,  1990 conference call
    that Michael Jacobson  (PTI Environmental Services),  Fran Solomon
    (Ecology), and  I had with you regarding actions that the Washington
    Department of Fisheries  is taking to reduce pollution in Bellingham
    Bay.  I have summarized  below our understanding of the Department of
    Fisheries actions and  have asked additional questions.   Please confirm
    or modify the summary  and address the new questions  through a written
    response.  This letter,  as well as your response, will be included in
    the draft Bellingham Bay Action Plan scheduled for release this July.

         Fish Enhancement  Projects

         The Department  of Fisheries operates a hatchery on the Nooksack
         River as well as  one on Whatcom Creek,  in cooperation with the
         Maritime Heritage Center.   The Maritime Heritage Center hatchery
         has frequently  experienced high coho salmon  mortality.  Has the
         cause of this high  mortality been determined?

         What is the status  of placing net pens in Bellingham Bay?  What
         environmental processes will they be subject to?  What is the
         Department of Fisheries role?  What other groups are involved in
         the placing of  net  pens in Bellingham Bay?

         Puget Sound Ambient Monitoring Program (PSAMP)

         As part of the  PSAMP, the Department of Fisheries sampled English
         Sole in Bellingham  Bay  in May of 1989.   Muscle  tissue samples
         were analyzed for pesticides,  polychlorinated biphenols, other
         priority pollutants and hazardous substances (e.g. metals).
         Samples were also taken to determine the presence of liver
         lesions.   Bellingham Bay may be sampled again  in July of 1991,
         and dioxin could  be added to the list of constituents.  Is there
         one core station  that is sampled once a year and another rotating
         station that is sampled once in three years? Please send me the
         results of the  1989 sampling.
                                     A-13

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  Mr. Brian Williams
  May 17,  1991
  Page 2

     Permit Issuance and Review

     The Department of Fisheries requires Hydraulic Project Approval
     (HPA)  permits for projects that use, divert,  obstruct, or change
     the natural flow or bed of any of the salt or freshwaters of the
     state.  In addition, Fisheries has adopted stormwater and
     wetlands policies which are implemented through the HPA permit
     process.

     The Department of Fisheries also reviews 404  permits as well as
     SEPA documents.

     Wetlands

     What is the Department of Fisheries wetlands  policy?  Are
     developers required to meet or exceed the provisions of the
     policy as part of the HPA permit?

     Monitoring

     In Bellingham Bay the Department of Fisheries monitors crabs,
     clams and commercial fish stock sizes.  Pink  salmon runs have
     been on the decline.  Potential causes of this include:
     siltation of spawning grounds in the upper watershed, habitat
     loss,  and low productivity in the bay which leads to quick out
     migration.  How are stocks monitored?  Have you discovered any
     other declining trends?  If so, what could be the reasons for the
     decline?

The draft Action Plan will be distributed for review to each member of
the Bellingham Bay Action Program Work Group.  A full work group
meeting will be held this summer to discuss and comment on the draft
plan.  Prior to the finalization of the plan, public comments will
also be solicited.

If you would like to discuss or clarify any issues prior to sending
your response letter,  feel free to call me at 649-7272 (SCAN 354).
Please have your response letter to me by Friday,  May 31st.

I appreciate your participation in this process and look forward to
your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp


                                 A-14

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JOSEPH R BLUM
  Director
                                 STATE OF WASHINGTON

                            DEPARTMENT OF FISHERIES
        775 General Administration Building • Olympia, Washington 98504 • (206; 753-6600 •  (SCAN) 234-6600


                                 June 3, 1991

      Department of Ecology
      Attention: Lucille Pebles
      Bellingham Bay Action Program  Coordinator
      3190 - 160th Avenue  S.E.
      Bellevue, Washington 98008

      Subject:  Response To Questions  Regarding WDF Activities In
                Bellingham Bay

      Dear Lucille:
      Hopefully the following information  will clarify the Department
      of Fisheries (WDF) activities  in Bellingham Bay.

           Fish Enhancement Projects:

      I.   Question: The Maritime  Heritage Center hatchery has
      frequently experienced high  coho salmon mortality-   Has the cause
      of chis high mortality been  determined?
           Ansv.-er:  The Maritime Heritage  Center  hatchery has
      experienced an annual coho mortality event  during the fall months
      for a number of years.  The  mortalities appear to correspond with
      the first significant rainfall and run off  event of the fall.
      The Maritime Heritage Center hatchery depends upon Whatcom Creek
      for its' water source.  It has been  speculated that an upstream
      pollution source enters the  system during the run off event at a
      level that is lethal to yearling size coho.  To date, the
      hatchery manager with the  assistance of DOE have been unable to
      isolate the source of the  mortality.  Water sampling efforts to
      isolate the pollutant and  source were frustrated in 1990 by the
      absence of the anticipated coho  mortality event.   It is my
      understanding that efforts to  isolate the pollutant will
      continue.

      2.   Question:  What is the  status of placing net pens in
      Bellingham Bay?
           Answer:  The Taylor Dock  and Squalicum Harbor net pen sites
      will be on line in 1991 for  extended rearing of juvenile coho and
      Chinook salmon.  Both sites  were on  line in during 1990.  The
      Squalicum Harbor site is a one pen operation cooperatively
      managed by the Bellingham  Heritage Center,the Bellingham Samish
      Say Enhancement Advisory and WDF.  The Taylor Dock site is a 4
      pen operation cooperatively  managed  by the  Bellingham Samish Bay
      Enhancement Advisory and WDF.

      Though a single net  pen was  operational in  1989 and 1990 at the
      Alaska Ferry Terminal, operation at  this site in 1991 is
      uncertain at this time.  The Alaska  Ferry Terminal net pen is

                                       A-15

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cooperatively managed by the Bellingham Samish Bay Enhancement
Advisory and WDF.

3.   Question:  What environmental processes will the net pens be
subject to?
     Answer: (a) The Taylor Dock site was issued a Hydraulic
Project Approval by WDF, a Determination of Non Significance
issued by the City of Bellingham and a Shoreline Permit issued by
the City.  WDF contracted a physical and biological survey of the
Taylor Dock site in August, 1990.  In addition, an environmental
checklist was submitted to the City of Bellingham in compliance
with SEPA.  The Hydraulic Project Approval was developed
according to the Recommended Interim Guidelines For The
Management Of Salmon Net-Pen Culture in Puget Sound published in
December, 1986.
     Answer: (b) The Squalicum Harbor site was issued a Hydraulic
Permit Approval through WDF's Volunteer Fisheries Resource
Program and according to the Recommended Guidelines For Sizing
and Siting Delayed Release Net Pens developed by WDF in May,
1990.

     Answer: (c)  The Alaska Ferry Terminal site was issued a
Hydraulic Permit Approval by WDF in 1989 according to preliminary
Recommended Guidelines For Sizing and Siting Delayed Release Net
Pens developed by WDF and adopted in May, 1990.

     Answer: (d) The physical and biological characteristics of
each site was surveyed prior to project implementation.  The
Taylor Dock site will be surveyed again during the fifth year of
operation and prior to renewal of the Hydraulic Permit Approval
in 1996.  The Squalicum Harbor site and Alaska Ferry Terminal
site will not be monitored.  Continued operation of the Squalicum
Harbor and Alaska Ferry Terminal sites is contingent on the
findings of a WDF monitoring program targeting a representative
sample of net pen operations in the Puget Sound area similar in
size and function to these sites but not including the Alaska
Ferry Terminal and Squalicum Harbor sites.

4.   Question:  What is WDF's role and what other groups are
involved in the placing of net pen in Bellingham Bay?
     Answer:  (a)  WDF is involved in the permitting process for
net pen operations through issuance of the Hydraulic Project
Approval.  The City of Bellingham is also involved in the
permitting process through SEPA and Shoreline Management
jurisdiction.  Through the SEPA process, any and all other
interested parties can raise concerns regarding the siting and
operation of proposed net pen facilities.
     Answer: (b) WDF evaluates site specific physical and
biological data for compliance with the above referenced net pen
siting guidelines.   WDF also works cooperatively with the
Bellingham Samish Bay Enhancement Advisory and the Bellingham
Heritage Center towards the successful operation of the net pen
ooerations.
                                A-16

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          Puget  Sound Ambient Monitoring  Program (PSAMP)

1.   Question: Is there one core station that is sampled once a
year and another rotating station that is sampled once in three
years?
       Answer:  The PSAMP program originally proposed to
establish two sampling stations in Bellingham Bay.  Initially,
one station would be sampled each year and the second station
sampled every other year.  Due to funding constraints, the
frequency of sampling for the primary sampling station, located
south of Post Point, in approximately 12 fathoms of water, and
defined by latitude 48 degrees, 40.93 minutes and longitude 122
degrees, 32.92 minutes, has been reduced to every other year.  To
date, samples were successfully taken in May of 1989 and 1991.

Sampling efforts in 1991 were unable catch enough flatfish to
establish a secondary sampling station in Bellingham Bay north or
north east of the Post Point station.  WDF will not re-attempt to
establish a secondary sampling site in the immediate future.

2.   Question:  Please send me the results of the 1989 sampling.
     Answer:  Sandra O'Niel with our Marine Fish Division in
Seattle will send you the results of the 1989 sampling.


     Permit Issuance and Review:

1.   Question:  What is WDF's wetland policy?
     Answer:  WDF has been directed by the Governor's Executive
Order On Wetlands, signed April 21, 1990, to condition or deny
Hydraulic Project Approvals (HPA) to the fullest extent of our
authority to protect fish life by assuring protection of the
value and function of wetlands.  To do so, WDF must be able to
assert that the wetland has a positive impact on fish life.
To protect fish life, WDF implements a policy of no net loss of
habitat.  Where applicable and as directed by Section 12 of the
Governor's Executive Order on Wetlands, WDF will implement the
following mitigation priorities:
     1.  Avoid wetland impacts
     2.  Minimize wetland impacts
     3.  Rectify impacts by repairing, rehabilitating, or
         restoring
     4.  Reduce impacts by preservation and maintenance
     5.  Compensate impacts by replacing, enhancing or
         substituting
     6.  Monitor Impacts and take corrective action.

2.   Question: Are developers required to meet or exceed the
provisions of the policy as part of the HPA permit?
     Answer:  For all wetlands having a positive impact on fish
life, developers must fully mitigate all negative impacts to the
value and function of the wetlands utilizing the above reference
mitigation priorities as a condition of HPA issuance.
                                A-17

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     Monitoring:

1.   Question:   How are stocks monitored in Bellingham Bay?
     Answer:   Bellingham Bay salmon stocks are monitored through
a comparison of annual run size estimates for each stock and
species.  A run size estimate for a particular species and stock
includes an estimate of total adult fish contributed to coast
wide commercial fisheries, coast wide sport fisheries and
spawning escapement.  Coded wire tag data and spawning ground
surveys currently provide the data foundation for run size
estimates though other methodologies are currently being explored
in an effort to refine these estimates.
     Answer:   Bellingham Bay dungeness crab are monitored through
an annual and monthly evaluation of the  commercial harvest and a
limited volunteer recreational fishery sport catch log.


2.   Question:   Have you discovered any  other declining trends?
     Answer:   Analysis of spawning escapement data for the years
1965 to 1989 does not support that the Nooksack River pink salmon
are experiencing a declining trend.  Spawning escapement
estimates have fluctuated radically from year to year though in
general appear to be maintaining a status quo level.

     Answer:   Analysis of spawning escapement data for native
Nor-ch Fork Spring Chinook indicates that this stock is
experiencing a declining trend.

3.   Question:   If so, reasons?
Reasons for the decline are most likely  a combination of
     a. the difficulty of protecting the adults from harvest
through out their ocean migratory range  and
     b. the instability of the North Fork Nooksack River spawning
habitat.
                         Sincerely,
                         Brian Williams
                         Marine Habitat Manager
                         Habitat Management Division
                                A-18

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CHRISTINE O. CRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May 17,  1991
       Mr.  Mark Schuller
       Washington Department
       of Fisheries
       333  E. Blackburn Road
       Mt.  Vernon, WA  98273

            Re:  Bellingham Bay Action Plan
              Hwk
       Dear Mr-—Sehuller;

       This letter is in follow-up to the November 6, 1990 meeting that
       Michael Jacobson  (PTI Environmental Services), Fran Solomon
       (Ecology), and I had with you and Art Stendal of the Department
       of Wildlife, regarding actions that the Washington Department of
       Fisheries is taking to reduce pollution in Bellingham Bay.  I
       have summarized below our understanding of the Department of
       Fisheries actions and have asked additional questions.  Please
       confirm or modify the summary and address the new questions
       through a written response.  This letter, as well as your
       response, will be included in the draft Bellingham Bay Action
       Plan scheduled for release this July.

            Permits/SEPA

            The Department of Fisheries issues Hydraulic Project
            Approval permits prior to construction or other activity
            which uses, diverts, obstructs, or changes the natural flow
            or bed of any of the salt or freshwaters of the state.

            Fisheries also reviews Forest Practices permits and SEPA
            documents.   What authority does Fisheries have in their
            review of the Forest Practices permit  (e.g. permit denial)?

            stormwater Issues

            As part of the Hydraulic Project Approval permit process,
            the Department of Fisheries is requiring developments which
            exceed 5,000 square feet of impervious surface to adhere to
            Fisheries draft stormwater guidelines.

            Under the guidelines, stormwater must be treated prior to
            discharging to a surface water body and, depending on
            proximity of downstream fish and shellfish resources,
            retention and/or detention facilities must also be provided.


                                      A-19

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Mr. Mark Schuller
May 17, 1991
Page 2

     The guidelines also include requirements for erosion and
     sediment control, and regular maintenance.  Have the
     guidelines been finalized?  Were there any significant
     revisions made to the draft prior to finalization?  How have
     these guidelines been received in the Whatcom County area?

     Fish Kills

     What is the status of the Department of Fisheries assuming
     responsibility for addressing fish kills?  Does this
     responsibility only apply to the Whatcom County area?  Is
     authority delineated through a memorandum of agreement with
     the Department of Ecology?  How is authority delineated?

     Livestock Wastes

     Fisheries is continuing to work with the Washington
     Conservation Corps installing cattle crossings and fences
     along streams adjacent to agricultural areas.  Although this
     effort preserves the riparian corridor by limiting creek
     access to the crossings, it also creates a -concentrated
     point of waste input.  Fisheries suggests that livestock be
     prevented from accessing creeks and that the water be
     brought to the livestock.  Is the Department of Fisheries
     pursuing the idea of restricting access to creeks?  If so,
     through what means?

     The Department of Fisheries coordinates closely with the
     Whatcom County Conservation District and refers farmers to
     them for assistance in developing and implementing waste
     management plans.

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.

I appreciate your support of this process and look forward to
your response.
                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:Ip
                                 A-20

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                      =KHbiT LHB      TEi_ NO: 206 428 InTl       8427 P02
                          June 14, 1991
Lucille Pebles
State of Washington
Department of Ecology
Bellingham Bay Action Program
3190 160th Avenue S.E,
Bellevue, WA. 98008-5452

SUBJECT:  Belllngham Bay Action Plan; Department of Fisheries
          Involvement

Dear Ms. Pebles:

I have reviewed your letter dated May 17, 1991 and offer the
following comments:
  1.  Permlte/SEPA - We also deny some applications for Hydraulic
Project Approvals.  Our authority in reviewing Forest Practice
Approvals is limited to only that instream work which would
require an Hydraulic Project Approval, such as logging across a
stream or installing a culvert.  We cannot deny a logging plan,
even if we Know in our hearts that the clearcut is much too large
and will probably cause stream impacts.  The cumulative effects
issue is still up in the air.  We are able to go outside our
normal Hydraulic Code authority and address other concerns about
projects near creeks through the 9BPA process.
  2.  Stormwater Issues - We are still using the same guidelines.
whatcom county still does not wish to adopt our more stringent
requirements/ but when the county authorities suggest that the
applicant contact us we require our criteria to be used.  The
City of Belllngham refuses to consider our guidelines.  Perndale
is trying to follow them.  Lynden is not.  Bverson and Nooksack
are.  Sumas and Blaine are coming closer.
  3.  Fish Kills - This responslbilty Is still D.O.B.'s because
we do not have the funding.  This issue is still being discussed
in Olympia and has not been totally resolved.
  4.  Livestock wastes:  When an applicant applies for an
Hydraulic Project Approval to dredge a stream that has very
visible evidence of livestock damage we do our best to get the
applicant to sign up for fencing,  We have no direct means of
requiring * fence*  Many of the Whatcom County streams are closed
by the D.O.E. for the issuance of new water rights for surface
withdrawal.
                               A-21

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"ul i-i-l-' 3>i rri  io'^a  ID:
Ms. Pebles
June  14,  1991
Page  2

It  la  Ironic that  the  D.O.B,  is trying to clean up the water/  but
does  not  seem  to want  to bend and devise a method to divert  water
to  the  cattle  in these closed streams.  The D.O.E. feels that  a
livestock owner has  "riparian stock watering rights'* with the
land.   This  issue  is important and hopefully vill be discussed in
the future.
                            Sincerely
                            Mark  schuller
                            Regional  Habitat Manager
                            426-1520
                               A-22

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CHRISTINE O. CREGOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May  17, 1991
     Mr.  Don Melvin
     Washington Department
     of Health
     Office of Environmental
     Health Programs
     LD-11
     Olympia, WA  98504

          R«:  Bellingham Bay Action Plan
            &cr\
     Dear My. Melvin;

     This letter is in follow-up to the September 25, 1990 conference call
     that Michael Jacobson (PTI Environmental Services), Fran Solomon
     (Ecology), and I had with you regarding actions that the Washington
     Department of Health is taking to reduce pollution in Bellingham Bay.
     I have summarized below our understanding of the Department of
     Health's actions and have asked additional questions.  Please confirm
     or modify the summary and address the new questions through a written
     response.  This letter, as well as your response,  will be  included in
     the draft Bellingham Bay Action Plan scheduled for release this July.

          Puget Sound Ambient Monitoring Program (PSAMP)

          As part of the PSAMP, the Department of Health samples bivalves
          quarterly off of Post Point.  These samples are analyzed for
          total and fecal coliforms.  Priority pollutants are monitored
          annually.  What is the Department of Health's interpretation of
          the data collected at Post Point?  Please send me a copy of the
          priority pollutant data collected to date.

          Other Monitoring

          The Department of Health has begun monitoring water quality at 19
          stations between Post Point and Governors Point, and  in the
          Chuckanut Village Stream.  Six samples will be collected from
          each station per year to meet the requirement of 18 samples from
          each station within a three year period.

          Fecal coliforms monitored in August of 1989 and in May of  1990
          are elevated in the Chuckanut Village Stream  samples. What
          actions will be taken to mitigate this problem, by whom and when?
          Please describe your commercial ambient monitoring program.  Is
          this also called your regular ambient program?


                                       A-23

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Mr. Don Melvin
May 17, 1991
Page 2

   Based upon  the water  quality data,  recreational  shellfish beaches
   may  be  classified  as:  Open, Closed  or  Conditionally Closed.
   Complete  seasonal  water quality profiles will  be obtained prior
   to using  the  Conditional  classification.  Please cite  an  example
   of the  use  of the  Conditionally Closed classification.

   The  Department of  Health  has also begun monitoring  for paralytic
   shellfish poisoning.   Shellfish samples were taken  monthly during
   the  winter  and will be increased to weekly during the  summer.
   What recreational  beaches in the Bellingham Bay  area will Jbe
   sampled?  What months are included  under winter  and under summer?
   Will this be  standard operating procedure from this point
   forward?  Will any volunteer efforts be used to  assist in
   collecting  samples?

   Memorandum  of Agreement

   The  Whatcom County Health Department and the State  Department  of
   Health  are  working on a memorandum  of  agreement  (MOA)  to
   delineate responsibility  for the posting of recreational
   shellfish beaches.  What  is the status of the'MOA?   How is the
   responsibility defined?   What other issues are addressed  in the
   MOA? Please  send  me  a copy of the  completed MOA.   The Bellingham
   Parks Department has  expressed a willingness to  post signs
   provided  by the state.  Is the Parks Department  involved  in this
   process?

   Sewage  Disposal

   The  1991  Puget Sound  Water Quality  Management  Plan  calls  for the
   Department  of Health  to revise the  model ordinance  for
   liveaboards to address sewage disposal needs for all boats using
   public  and  private marinas.  What is the status  of  these
   revisions?  When will  the ordinance be implemented?

   The  Department of  Health  has revised their On-Site  Sewage System
   Regulations (Chapter  248-96 WAC).   The rules for on-site  sewage
   disposal  address operations and monitoring requirements,  and
   technical issues such as  vertical separation from groundwater  and
   alternative treatment systems.  The rules also intend  to  develop
   a standardized approach to the issue.  Were the  rules  adopted  in
   their "Revised November,  1989" form?   Is Whatcom County adopting
   local regulations  to  implement the  rules?
                                A-24

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  Mr. Don Melvin
  May 17, 1991
  Page  3


     Dairy Wastes

     The Whatcom County area contains a high concentration of dairies,
     which could be adversely affecting water quality in surface
     waters throughout the county.  The Nooksack River, as a large
     contributor of freshwater to Bellingham Bay, could be adding
     significant amounts of fecal coliform contamination to the bay.
     What plans does the Department of Health have to monitor the
     river,  or any other surface waters draining to the bay, for water
     quality parameters such as fecal coliforms?

     The City of Bellingham is currently monitoring all streams within
     their city limits once a month.  Standard water quality
     parameters are being monitored, including fecal coliforms.  The
     data collected thus far indicates some exceedances of state water
     quality standards.  What role will the Department of Health play
     in this issue?

     What is the status of the Department of Health providing funding
     to local health districts so that they can address these types of
     watershed issues?

The draft Action Plan will be distributed for review to each member of
the Bellingham Bay Action Program Work Group.  A full work group
meeting will then be held to discuss and comment on the draft plan.
Prior to the finalization of the plan, public comments will also be
solicited.

If you would like to discuss or clarify any issues prior to sending
your response letter, feel free to call me at 649-7272 (SCAN 354).
Please have your response letter to me by Friday, May 31st.

I appreciate your participation in this process and look forward to
your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                                   A-25

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KRISTINE M. CEBBIE
   Secretary
                                 STATE OF WASHINGTON
                             DEPARTMENT OF  HEALTH      .[|j|y ] A
                                Olympia, Washington 98504
                                                         °EPT. OF ECOLOGY

                                 June 13,  1991
       Lucille T. Pebles, P.E.
       Bellingham Bay Action Program  Coordinator
       Department of Ecology
       3190 160th Avenue SE
       Bellevue, Washington  98008-5452

       Dear Lucille:

       The enclosed material addresses the questions posed in your May 17,
       1991   letter  concerning   DOH  activities   in  the   Bellingham
       Bay/Chuckanut Bay areas:

       Page one, paragraph two - Puget Sound Ambient  Monitoring Program:

            The PSAMP protocols call  for  Bivalve  shellfish  to be sampled
            quarterly for fecal coliform bacteria  and annually for metals,
            organic chemicals and pesticides.  Last year four beaches were
            analyzed for chemicals:   Lincoln Park, March Pt.,  Ross Point
            and Walker Park.

            In  1990  metals  at  these  beaches  were  found  at  levels
            comparable  to  those reported in the 1988 Faigenblum study
            although the data  for  mercury had to be  qualified since the
            frozen clams had exceed holding time limits. March Point had
            the  only  organic chemical found in  levels above detection
            limits which was fluoranthene  (a by  product of  fossil fuel
            combustion) at 44 ppb.


            Post Point was not a chemistry site during 1990 but was added
            to the 1991 schedule.  This site was  dug  on May 19, 1991 and
            will be  analyzed by  the  end  of  June 1991.   The  person in
            charge of our PSAMP program is Linda Klote  (586-8736) .  I will
            ask Linda to send  you  a  copy of the  PSAMP results when they
            are available.
                                        A-26

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Lucille T. Pebles
Page Two
June 13, 1991
Page one, paragraphs three and four - Other Monitoring:

     Paragraph  three  - The  samples  collected  in  Chuckanut Bay
     between  Post Point  and  Governors  Point  are  part of our
     Recreational Beach  Program.  Derry  Suther  (664-0143)  is in
     charge of the Recreational Program.   There are no commercial
     growing  areas  in  the region.   The  Whatcom  County Health
     Department was notified  about the  Chuckanut  Village Stream
     samples.     Any  corrective   action   falls   under  county
     jurisdiction.

     Paragraph  four  - The  commercial Ambient  Program  (Regular)
     follows  guidelines  established  by the  National  Shellfish
     Sanitation  Program.    Under  this  program,   our  office is
     reguired  to  collect  a  minimum  of  18  samples  per  sampling
     station from each Approved growing  area  within a  three year
     period.   Only  areas  which are certified as Approved by DOH
     fall under this particular monitoring program.  Currently 42
     areas fall into this category.

     Water quality  data is reviewed  as  it is  received  from the
     State Health Laboratory.   Additional work may be scheduled in
     areas producing bacteria  levels  indicative of water quality
     problems.

     Ambient   water   quality   data   is   reviewed   annually.
     Determinations  regarding  the  appropriate   growing   area
     classification are made  based on the most recent set  of 18
     samples per station.

     I have  included a  copy of the NSSP  Manual  of Operations for
     your information.   Jerry Lukes (753-5991) is in charge of the
     commercial Ambient Program.

Page two, paragraph one - Other Monitoring:

     The  current   WAC  256-52  (previously  248-52)  uses  the
     classification   nomenclature    of    "open,    closed,    and
     conditionally closed" for the purposes of  regulating public
     beaches.  The recreational program has departed from the use
     of these  classifications  and  has developed a  system to rank
     the  beaches   using   the  classification   of  "low-threat,
     threatened,  correctable  and  long-term harvest restriction"
     categories.  A copy of the first  draft definitions of each of
     these categories  is  attached.   This ranking  system will be
     established  in  the  newly drafted  recreational action plan
     available soon for comments.  Beaches will be placed  in one of
     these categories based on a completed site evaluation.
                                  A-27

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Lucille T. Pebles
Page Three
June 13, 1991


     Examples of  beaches on the  "long  term harvest restriction"
     list would be Alki Point, Budd Inlet, Carkeek Point and Post
     Point.

Page two, paragraph two:

     Recreational shellfish beaches at Post Point and Chuckanut Bay
     will be sampled for PSP by Adopt-A-Beach volunteers once every
     two weeks from April 1 through October 31 during 1991.  Winter
     monitoring of  these beaches  is  unlikely.   Funding  for the
     Adopt-A-Beach PSP monitoring program has been obtained through
     1992.

     The  DOH staff does not  collect samples  from recreational
     beaches in Bellingham Bay.

     Additional monitoring of recreational shellfish beaches is at
     the  discretion  of   the  Whatcom  County Health  Department.
     Historically, the County Health Department has collected PSP
     samples from Bellingham  Bay  on  an infrequent  basis.   No PSP
     sample  collection had been  conducted by  the  County Health
     Department in 1991 in Bellingham Bay.


Page two,  paragraphs  three and four -  Memorandum  of  Agreement &
Sewage Disposal:

     Paragraph  three  -   The  recreational  WAC  was intended  to
     delineate  responsibility  between  DOH  and   local  health
     jurisdictions.   Even though  that intent is still meaningful
     and will still be attempted, to date a MOA with Whatcom County
     Health has not been finalized. A draft MOA is being reviewed
     by several health departments.

     Paragraph four - The PSWQA plan establishes the formation of
     a  state agency  task  force   which has  just   recently  been
     implemented with the formation of an advisory committee to
     follow. There is heightened interest regarding any changes in
     the  model ordinance and  any  forthcoming drafts  will  be
     reviewed and  possibly written by this advisory committee which
     will  include  members   from  the  liveaboard  and  boating
     communities.    The plan  mandates that  local  governments be
     encouraged to implement the model ordinance within six months
     after completion.
                                  A-28

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Lucille T. Pebles
Page Four
June 13, 1991
Page two, paragraph five - Sewage Disposal:

     The State Board of Health amended their on-site sewage system
     regulations (WAC 246-272)  in November  of 1989 to address "the
     repair and expansion of systems adjacent to marine waters."

     The DOH has just  completed  a draft  revision of WAC 246-272.
     Public workshops will be held in the summer of 1991 to discuss
     the proposed changes.  The proposed revisions address a number
     of  issues  including  operation  and  maintenance,  areas  of
     special concern,  certification  of designers,  installers and
     regulators, and  also require that  each  system be built to
     provide sewage treatment.

     Local  health  departments   may  adopt   local   regulations,
     providing that the local regulation is at least as stringent
     as the state regulation.

Page three, paragraphs one and two - Dairy Wastes:

     Since  there are  no  certifiable commercial or recreational
     shellfish beaches in Bellingham  Bay, this department will not
     be involved in any activities associated  with  water  quality
     problems  in the  bay or  its freshwater  systems.   If  water
     quality should decline  in areas adjacent  to Bellingham Bay
     which  are  certified  shellfish areas,  it  is conceivable that
     the  Nooksack  could  be  investigated  by  this   office  as  a
     potential source of contamination.
Page three, paragraph three:

     The  DOH requested  funds  for  local  health departments  to
     conduct a recreational shellfish program.  It was our number
     one priority but was not  approved by the Governors Office and
     O.F.M.

     Health departments are not funded to trace dairy waste.  That
     is the responsibility of  the local conservation districts and
     the Department of Ecology.  Local health departments will get
     involved in tracking waste if the source is from humans.
                                  A-29

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Lucille T. Pebles
Page Five
June 13, 1991
     Local  and  State  Health  Departments  serve  on  watershed
     committees.   State  Health representatives provide technical
     assistance to the twelve early action watershed committees.
     Our  focus  is  on-site sewage disposal  and shellfish growing
     area classification.

If you have any further questions regarding  this, you may reach me
at (206)  586-4484.

                              Sincerely,
                                        rf #  *
                                               '/
                              DON MELVIN
                              Environmentalist
                              Office of Shellfish Programs
DM:BJA
                                  A-30

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                          VII : BEACH RANKING

Beach ranking is an administrative tool used to categorize public beaches in ac-
cordance with their water quality  and their recreational value. Under Chapter
248-52 WAG, "recreational shellfish  beaches" include those that are privately
owned but havenlimited public access, such as a community LH ni^ui  beach.
However, there are officially 1 46 beaches owned and maintained by all levels of
government that are covered by the Recreational Shellfish Action Plan, .  Private
beaches that have public access may be phased into the plan in time on a case-
by-case basis.' •

Beaches are separated into four general categories to prioritize agency re-
sources:
             1 . Low Threat - minimal water quality problems
             2. Threatened - water quality needs protection
             3. Correctable - water quality pollution present though reversible
             4. Long Term
 Under this plan, beaches in the low threat or long terrrfldesad categories would
 not be targeted for action;they are either relatively pristine ortoo polluted to justify
 a recreational shellfish effort at this time. Beaches categorized as correctable or
 threatened would be targeted for cleanup.

 #1 LOW THREAT

    •   Beaches which meet Health standards for safe shellfish harvest/ o r

    •   Beaches distant from recognized upland or water-based sources of pollution.

                                 Action : None

 #2 THREATENED

    •   Public beaches vfeiefr Health has PlnTlflnfl nMpaa&tf water quality data indi-
       catŁ$sheilfish harvest is threatened or potentially threatened by increasing pol-
       lution.

    •   Adequate shellfish resource or the potential for enhancement exists.

    •   Public access is available and area is used by the public.

                              Action : Preventive
 Preventive action includes identifying and mitigating specific pollutant sources which
 are threatening the water quality of a given beach. Protection usually entails less source
 1. Questions of liability surround these de facto public beaches, were there to be any illness resulting from con-
 taminated shellfish harvested from them.

                                     A-31

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identification and correction than a restoration area, but typically places emphasis on
public eduction and preventative land-use measures. An example of this would be in-
creasing boater education at outlying beaches with several moorages, such as in the
San Juan Islands, orconducting workshops on agricultural best management practices.

#3 CORRECTABLE
                              .1  j-'ffj
    •  Public beaches Health has aljaaiiiod a. nhi i ililm  In f aila& to meet standards
      for safe shellfish harvest.

              Caused by by chronic, though reversible, nonpoint bacterial pollution/^r
    •   Abundant shellfish resource or potential for enhancement.

    •   Good public access is available.

                             Action : Restoration
 Restoration means identifying and correcting  pollutant sources. It involves character-
 izing the site by upland uses, drainages, and pollutant sources, followed by  remedial
 action. Remedial action requires cooperation between state and local agencies and
 citizens. It may include: repair of failing on-site septic systems; creating stream buffers
 to control erosion and installing fences to prevent farm animal wastes from entering up-
 land drainages; developing land use ordinances to moderate new development/ popu-
 lation densities; or  educating boaters, marinas and the general public.  The public
 needs to be involved in decisions concerning corrective actions.

 #4  LONG TERM CLOSED
                                                               (0
       Chronic or severe bacterial water quality degradation and/or
       sewage treatment plants, contaminated sediments, or major sources of toxics-K
       thn immflr4*'**0 "'™-jty require long term corrective action.

              Action : Refer to Urban Bay Action Teams for cleanup
  In <&& Ecology and Health ranked the 146 official beaches covered by the Recreational
  Shellfish Action Plan.

          5*/-^ beaches have no apparent problems and are ranked as Low Threat;

           3 Ł"& beaches are Threatened;

            J 0 "S beaches are Correctable; and,
                                                      Lon
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CHRISTINE O.CRECO1RE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190 • 160th Ave S.E. • Bellevue, Washington 98008-5452 • (206) 649-7000


                                   May 17, 1991
        Mr. Doug Strong
        Washington Parks and Recreation
        Commission
        7150 Cleanwater Lane, KY-11
        Olympia, Washington  98504-5711

             R«:  Bellingham Bay Action  Plan
               Dou.9-
        Dear Mr. SgEong;

        This letter is in follow-up  to the  September 12th conference call
        that Michael Jacobson  (PTI Environmental  Services),  Jacques
        Faigenblum (EPA), Fran  Solomon  (Ecology),  and I  had  with Peggy
        Britt regarding the Bellingham Bay  Action Plan.-  The purpose of
        the conference call was to determine actions that the Washington
        State Parks and Recreation Commission is  taking  to reduce
        pollution in Bellingham Bay.  I  have summarized  below our
        understanding of these  actions and  have asked additional
        questions.  Please confirm or modify the  summary and address the
        new questions through a written  response.   This  letter,  as well
        as your response, will  be included  in the Bellingham Bay Draft
        Action Plan scheduled for release this July.

             Legislation

             In 1989 the State  Legislature  passed a bill which allocated
             a portion of the funds  from the Watercraft  Excise Tax, to a
             boater waste disposal program  and a  boater  environmental
             education program.  The law allocated a total of $1,000,000
             for the first biennium  (fiscal years 1990 & 1991) and
             $1,000,000 annually for each of the  following four years.

             For fiscal years 1990-1991, $300,000 was available for
             public and private marinas  to  install or repair sewage
             pumpout/dumpout facilities.  Boat launches  and  boater
             destinations were  also  potentially eligible for these funds.
             All marinas in the state were  notified of their eligibility
             in the Spring of 1990,  however, no applications were
             received from marinas in Bellingham  Bay. When  were notices
             sent out this year?  Have you  received any applications from
             Bellingham Bay facilities?  Can these funds be  used for
             portable pumpout stations,  even if  a marina currently has a
             stationary facility?
                                        A-33

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Mr. Doug Strong
May 17, 1991
Page 2


     In addition to sewage pumpout/dumpout grants, one of the
     other funding provisions is for ports and local health
     departments to develop environmmental education programs.
     Education elements include information on toxic substances
     used by boaters (e.g. oil,paints) and sewage disposal.  What
     is the process for receiving funds?  Have the Port of
     Bellingham and the Whatcom County Health Department applied
     for funds?

     Boater Education

     The Parks and Recreation Commission is currently in the
     process of hiring two new staff members for boater
     education.  One staff person will be involved in watershed
     planning as well as conducting outreach activities (e.g.
     presentations).  With the addition of personnel to perform
     outreach activities, the Boater Environmental Education
     Program plans to become more pro-active.  What specific
     outreach activities have you planned?

     A slide show about boat waste management and a video on the
     environmental impacts of boating are available through the
     Parks and Recreation Commission for group presentations.  In
     addition, a water quality interpretive sign and sewage
     pumpout location and operating instruction signs are also
     available.  Parks and Ecology will discuss potential
     locations in Bellingham Bay for these types of signs.

     The Parks and Recreation Commission is revising the
     educational brochure titled "Boater's Guide to Cean Water
     and Good Times".  The brochure currently addresses: safety,
     trash, plastic, sewage pumpout stations, shellfish/oil,
     maintenance and general information.  What are the
     revisions?  When will they be completed?  How is this
     document made available to the public?

     In 1988 the Parks and Recreation Commission conducted a
     recreational boater survey to find out:  how much money
     boaters spend on a given day, what they spend it on, and
     where they spend it; what are their most frequent
     destinations; what types of waste disposal equipment and
     practices are used onboard; and what facilities and programs
     are needed to control boat wastes.  What actions have been
     or will be taken as a result of  this survey?

     Model Ordinance for Sewage Disposal at Marinas

     The Departments of Health and Ecology, the Parks and
     Recreation Commission, and the Puget Sound Water Quality
     Authority, are currently revising a previous model ordinance
     with the assistance of an advisory committee.


                               A-34

-------
Mr. Doug Strong
May 17, 1991
Page 3

     The model ordinance will provide sewage disposal options
     addressing the needs of various types of marina users.
     Local agencies governing marinas will be encouraged to adopt
     and enforce the ordinance.

     Local governments will also be encouraged to work with the
     Parks and Recreation Commission boater education program.
     The ordinance will be accompanied by a report providing
     information for local governments on designing and
     installing slipside pumpouts at marinas and methods of
     ensuring their use by liveaboard boaters.  No sooner than
     two years following distribution of the model ordinance,
     Health shall evaluate progress under the nonmandatory
     program and recommend additional action as necessary.  What
     is the status of the Model Ordinance?

     Water Quality

     Who owns and maintains storm drain systems on state park
     property?  Storm drains are a significant contributor to the
     degradation of surface waters.  Therefore, -it is important
     to keep them clean to minimize their environmental impact.
     How frequently are your systems cleaned?  How are the
     removed materials disposed of?  Is there any testing of the
     materials for toxic substances?

     Pesticides, herbicides, and fertilizers contribute to the
     degradation of water quality.  What actions are being taken
     on state park property, to reduce the impacts of these
     chemicals (e.g. reduction in use or using environmentally
     friendly products)?

     Waste Reduction

     What is being done to encourage park users to recycle?

     What is done with organic materials obtained through park
     maintenance?  Can the materials be composted?  Does the
     presence of pesticides, herbicides and fertilizers affect
     compostlblllty?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.
                                 A-35

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Mr. Doug Strong
May 17, 1991
Page 4


I appreciate your support of this process and look forward to
your response.
                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                             A-36

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JAN TVETEN
 Director

AVJ V  11.  -                                  |. WASH|NCTON
               WASHINGTON STATE PARKS  AND  RECREATION COMMISSION
                  7750 Cleanwater Lane, KY-11  •  Olympia, Washington 98504-5711  •  (206) 753-5755

                                       August  6,  1991
        Ms.  Lucille T.  Pebles,  P.E.
        Bellingham Bay  Action  Plan Coordinator
        Washington Department  of Ecology
        Northwest Regional  Office
        3190 -  160th  Avenue S.E.
        Bellevue, WA    98008-5452

        Dear Ms. Pebles:

        This letter  is  in followup to the letter sent to me on May 17,  1991  requesting
        information regarding  action  by  State  Parks that is intended for the  Bellingham
        Bay  Action Plan.

        The  questions you posed under water quality and waste reduction in state parks
        have been forwarded on  to our Operations Department, and their response will  be
        sent on to you  before  the 28th of this month.

        Under the paragraph entitled  "Legislation"  and your question about when notices
        would be sent out  this year  regarding  applications for  pumpout grants,  please
        note that application  packets will  be  sent in September or October of this year
        for   the  funding  cycle  of  1991/92.   At  this point,  we have not  received
        applications  from any  facilities in the state, and therefore  we cannot respond
        to your question  regarding whether  we  received  any from Bellingham Bay.  In the
        spring  of this year, the pumpout  WAC was rewritten to include language that would
        make it possible to fund portable  pumpout stations.   This would not prevent a
        marina  currently with  a stationary pumpout  facility from applying for money  to
        include a portable unit.

        Also under "Legislation," you ask a  question about grant money available to ports
        and  local health departments  to  develop environmental education programs. The
        status  of this  program currently is that the  WAC  has  been written,  it has not
        been approved at this  point,  and it is on hold until  it can go through all the
        governmental  processes to make it operational.  We also have  the difficulty  of
        no money being  allocated for  this program in the last legislative session, and
        we are  trying to determine where or if we can fund  the  program as  originally
        planned.  The current target date for this program is during Fiscal 1992/93. The
        intent  will be  to fund  Boater Environmental Education and Boat Waste  Management
        grants.
                                             A-36a

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Ms. Lucille T. Pebles
Page 2
August 6, 1991


Under "Boater Education," the following specific outreach activities are planned:

  1)  We will continue participating  in  boat  shows,  sportsmen's shows, county
      fairs, etc. to distribute educational materials to recreational boaters.

  2)  We will make  regular  presentations to grassroots organizations,  such as
      Bay Watchers, Water Watchers,  marina manager organizations, environmental
      education groups, etc. to make them aware of recreational boater impacts
      and solutions.

  3)  We have just completed a boater education video which will be distributed
      to  all  middle schools  in  the state.  The  video includes environmental
      sections  targeting  the recreational boater.  Through  this  video, we'll
      work  with environmental  science teachers   across  the state  to  include
      elements  of  impacts by recreational  boaters on the environment.

  4)  We will continue to provide interpretive signs, pumpout signs,  brochures,
      etc.  to marinas and launch ramp  areas for boater education purposes.

   5)  We  will  continue  to  take active  part in  interagency  committees  and
      community action groups who are  participating in water quality efforts.

 Regarding your question about the boater environmental education guide, under the
 "Boater  Education"  paragraph,  the  following revisions  were made to  the guide.
 We  have updated the information on pumpout locations  and  dump stations  that are
 provided  throughout the state.   In  the first BEE Guide publication,  only  Puget
 Sound pumpouts were listed.  We've updated information under Economic Impacts and
 Environmental Impacts related to recreational boating.  We've added a new section
 on  the  new MARPOL placard requirements  that are  now in  place, and  there  is  a
 section explaining that.  We have updated telephone numbers  and addresses  where
 appropriate.  We've refined and modified  information relating to boat and engine
 maintenance practices.   Lastly, the  section on  shellfish  has  been  updated to
 include  current information  that's  pertinent to recreational boaters.

 Regarding  distribution  of the Boater Environmental  Education Guide, as in the
 past, we distributed this brochure to all marinas and public ports in the  state
 that  we  have on our mailing  list.   It's distributed widely at boat shows and
 sportsmen's shows throughout the  state.   We make it  available upon  request,
 either  telephone  or  written.   It's  used  as  an educational  document by  Bay
 Watchers  groups,  Water Watchers groups as a part  of  their educational  process.
 It  will be  distributed with the boater educational learning packet that will be
 distributed to  middle  schools  throughout the state.  We  will make  it available
 to  environmental science teachers to include in their curricula as an information
 resource.    Lastly,  it is  distributed through  marine  retail  trade locations
 throughout  the  state.   The  BEE  Guide  has become  one  of  our most requested
 brochures  from  the recreational  boater,  and our  intent is to continue
 to  update the pumpout location  information on an annual or semiannual basis,
 depending  upon  when new pumpouts are  added throughout  the state.
                                    A-36b

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Ms. Lucille T. Pebles
Page 3
August 6, 1991


Our efforts to establish a model ordinance for sewage disposal at marinas with
the Department of Health are currently on hold.  Both the Department of Health
and  State  Parks  have  requested  funds  to  hire personnel  to  complete  this
particular  component  of the  Puget Sound Water  Quality  Plan.   To  date,  that
position has not been funded.

Your questions regarding water quality and waste reduction have  been forwarded
to our Operations Division at State Parks for their response.   I've requested an
answer prior to your deadline of August 28,  and will  forward those responses to
you just as quickly as  I receive them.

I  apologize for the delay  in  getting you this  information,  and hope  that it
arrives  in  time to  be  of some value  for your meeting.  Please understand that
State  Parks is still very  interested in participating  in  the Bellingham Bay
Action Plan.   Please continue to keep me updated on  progress with the plan and
any ways that  I can help facilitate the process of bringing the plan to a final
draft.

I  look forward to working with you in the months ahead.  Please  let me know if
there's  any additional  information that  I can  help you with prior to your next
meeting.

                              Sincerely,
                               Douglas  K.OStrong
                               Boating  Education Coordinator
DKS:sn
cc Jim  French,  Manager
     Boating  Programs
                                    A-36c

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|AN TVETEN
 Director
                                       STATE OF WASHINGTON

               WASHINGTON STATE PARKS AND RECREATION COMMISSION
                  7750 Oeanwater Lane, KY-11  •  Olympia, Washington 98504-5711  •  (206) 753-5755

                                                                     RECEIVED

                                        August 20, 1991                ^  26 1991

        u   ,    .-,,   T   n  ui     n r                                     DEPT. OF ECOLOGY
        Ms. Lucille  T.  Pebles,  P.E.
        Bellingham Bay  Action Plan  Coordinator
        Washington Department of Ecology
        Northwest Regional Office
        3190  -  IGOth Avenue  S.E.
        Bellevue, WA 98008-5452

        Dear  Ms.  Pebles:

        I have  enclosed additional comments to the letter I sent to you dated August 6,
        1991, to complete information you requested that I was not able  to answer at that
        time.   This information reflects the collective  input  from our staff  in  the
        Operations and  Resources sections.

        State Parks  does not have  any facilities on Bellingham Bay as defined  by the
        boundary map in the plan.  The  nearest State Park is Larabee State Park on Samish
        Bay,  south   of  your   study  area.   For  the  sake of  information only, we  have
        responded to your questions on water  quality and  waste reduction  using Larabee
        State Park  as  an example.    This  will  give  you an idea  of general  State Parks
        operating procedures as it  relates to  these  two  areas.

        Please  call  me  at (206) 586-2283 if you should have questions.
                                                                                    *

                                            Sincerely,
                                             DouglasHC.  Strong
                                             Boating Education Coordinator
        cc:    Cleve Pinnix,  Deputy Director
               Tom France,  Assistant Director,  Resources
               Dennis Smith,  Assistant Director,  Operations
               Jim French,  Manager, Boating Programs
                                             A-36d

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                                                                         DRAFT
                                                            August 20, 1991
                          BELLINGHAM BAY ACTION PLAN
                              Additional  Comments

WATER QUALITY:
In the Bellingham Bay area, the Washington State Parks and Recreation Commission
manages Larabee State Park.   Larabee does not have a comprehensive storm water
collection, disposal system.   There are a few collection points  in the main park
that flow into the sewer system through which the water is treated (lagoon and
chlorination) and effluent put into Launch Bay.

There is a minimal spraying program (once per year) in use at Larabee State Park.
No herbicides, pesticides or fertilizers are used except at road  edges and trails
within the campground area.  Minimizing the use of herbicides and pesticides is
the most significant  action State Parks has taken.

State Park boat launches are  sites where toxic  substances, oils and fuels, can
collect and  drain into the watershed.  Boating Programs  is  in the process of
developing a poster for use  at  boat  launch  sites to  remind boaters  of their
impacts on water  quality and  the need to take  actions to minimize or eliminate
the release of oils and fuels  or other toxic substances onto the ramp or parking
area.  The above  information  is also contained  in our  "Boater's Guide."

WASTE REDUCTION:

Presently, State  Parks  is  in  the development stages of  a recycling program for
use  at  State parks.   On a site by  site basis, State  Parks  does provide for
                                    A-36e

-------
recycling of aluminum cans.  The recycling which exists at  State Parks right now
is often  augmented by local  civic or youth  organizations  who are  given the
opportunity through their participation to benefit from funds recouped.

At all marine parks,  State Parks  has  implemented a "pack-it-out" program nearly
eliminating the need for the collection of trash.  Park users are encouraged to
recycle their wastes in addition to packing it out at the marine parks.

At our  state  parks in the Bellingham Bay  area, and  throughout  the State Park
system, there is minimal removal of organic materials.  Lawn clippings and fallen
vegetation, as much as is practical,  is left to decompose  in a natural fashion.
Branches and limbs which must be  removed  for cleanliness and safety aspects are
gathered and allowed to decompose or,  when this  is not practical, are burned on
site.
R-BellBa:jfn
                                  A-36f

-------
CHRISTINE O. GRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190 • 160th Ave S.E. • Bellevue, Washington 98008-5452 • (206) 649-7000


                                  May 17,  1991
       Mr.  Art Stendal
       Washington Department
       of Wildlife
       1405 Florence
       Mt.  Vernon, WA  98273

            R«t  Bellingham Bay Action Plan
              *faf~
       Dear Mr Stendal;

       This letter is in follow-up to the November 6, 1990 meeting that
       Michael Jacobson (PTI Environmental Services), Fran Solomon
       (Ecology), and I had with you and Mark Schuller of the Washington
       Department of Fisheries, regarding actions that the Washington
       Department of Wildlife is taking to reduce pollution in
       Bellingham Bay.  I have summarized below our understanding of the
       Department of Wildlife's actions and have asked additional
       questions.  Please confirm or modify the summary and address the
       new  questions through a written response.  This letter, as well
       as your response, will be included in the draft Bellingham Bay
       Action Plan scheduled for release this July.

            Permits/Licenses/SEPA

            The Department of Wildlife reviews Hydraulic Project
            Approval (HPA) permits, Forest Practices Permits, and SEPA
            documents.  What authority does Wildlife have in permit
            reviews?

            The Department of Wildlife also is involved in the Federal
            Energy Regulatory Commission (FERC) process for licensing
            the construction of hydroelectric dams.  As a part of their
            review of applications to construct dams, the Department of
            Wildlife examines in-stream flows, erosion control, and
            other impacts to fish and wildlife.  Although there are no
            laws in the state of Washington to protect wildlife, the
            Department of Wildlife can examine impacts to wildlife under
            the FERC process through the Fish and Wildlife Coordination
            Act.   There are currently a number of proposed hydroelectric
            projects on the Nooksack River as well as on almost all of
            its tributaries.  Are there any plans to create or amend
            laws to protect wildlife?
                                     A-37

-------
Mr. Art Stendal
May 17, 1991
Page 2


     Stormwater Issues

     The Department of Wildlife supports the Department of
     Fisheries stormwater guidelines which require stormwater
     detention/retention and treatment for HPAs.  What is the
     status of the Department of Wildlife adopting these
     guidelines as policy?

     Wetlands

     When reviewing HPAs which have potential to impact wetlands,
     the Department of Wildlife may either deny or condition the
     permit to protect wetlands.  No degradation of wetlands is
     allowed.  If there is an impact, it must be mitigated at the
     rate of two acres of new wetlands per each acre lost.  If
     the Department of Wildlife's wetlands requirements are in
     conflict with other state or local requirements, which
     requirements will rule?

     Land Use

     What role does the Department of Wildlife play in the
     development and review of comprehensive land use plans?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTPilp
                                A-38

-------
CHRISTINE O. GRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May 17, 1991
       Ms. Betsy Striplin
       Washington Department of
       Natural  Resources
       Marine Research and Development
       Center,  EX-12
       Olympia,  Washington  98504

             Res   Bellingham Bay Action Plan


       Dear

       This  letter is in follow-up to the September 12th, 1990
       conference call that Michael Jacobson (PTI Environmental
       Services), Jacques Faigenblum (EPA), Fran Solomon (Ecology), and
       I had with you regarding actions that the Washington Department
       of Natural Resources is taking to reduce pollution in Bellingham
       Bay.  I  have summarized below our understanding of the Department
       of Natural Resources' actions and have asked additional
       questions.  Please confirm or modify the summary and address the
       new questions through a written response.  This letter, as well
       as your  response, will be included in the draft Bellingham Bay
       Action Plan scheduled for release this July.

             Pucret Sound Dredged Disposal Analysis fPSDDAl

             The Bellingham Bay PSDDA open-water dredged material
             disposal site is open from June 16th through October 31st.
             The Department of Natural Resources (DNR), is responsible
             for authorizing the use of disposal sites and conducting
             chemical and biological monitoring.  DNR performed baseline
             biological monitoring in the spring of 1990 at the
             Bellingham site and will conduct a crab bioaccumulation
             study after 100,000 cubic yards of material have been
             disposed of.  No applications for disposal were received for
             the Bellingham site in 1990.  What were the results of the
             1990 baseline monitoring?  Please send me a copy of these
             results.  What disposal applications have you received for
             1991?
                                       A-39

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Ms. Betsy Striplin
May 17, 1991
Page 2
     Sediment Management

     DNR has created a new section to handle dredging and
     contaminated sediments issues.  The new Sediment Management
     section, with funding from EPA, is developing a screening
     approach for identifying leased marine lands with potential
     for sediment contamination.  Areas will eventually be ranked
     in terms of relative probability of contamination.

     In addition, a users manual is being developed for
     contaminated sediments which includes policies and
     regulations.  What is the status of these efforts?  What
     specific EPA funds were obtained?

     Ecology and DNR are developing a memorandum of understanding
     that will address:

     1)   DNR liability for dealing with contaminated sediment
          sites

     2)   DNR responsibility for site investigation and cleanup

     3)   DNR's role in the aquatic lands leasing program,
          including site identification, investigation and
          remediation.

     What is the status of the MOV?  How are these three issues
     addressed?

     Port Management Agreement

     DNR is negotiating a Port Management Agreement with the Port
     of Bellingham.  This agreement would assign all management
     responsibilities for aquatic lands abutting Port of
     Bellingham properties to the Port of Bellingham.  Existing
     individual leases then would be eliminated.   Since these
     properties would remain state owned, will the Management
     Agreement address liability for cleanup of contamination?

     Coastal Zone Management Act

     I am aware that the Coastal Zone Sediment Act was reviewed
     in December of 1990.  Was the Port of Bellingham given
     control of any DNR lands as a result of this review?  Were
     any of these properties contaminated?
                                A-40

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Ms. Betsy Striplin
May 17, 1991
Page 3

     Aquatic Lands Leasing Program

     Aquatic land leases are issued for periods ranging from 5 to
     30 years and can be opened prior to their expiration if the
     lessee desires to amend the lease or reassign property
     rights. New leases or newly opened leases are being revised
     by DNR to address liability for contaminated sediments.
     What, in general, does the new language regarding
     contaminated sediments say?

     At this time, DNR does not plan to adjust lease rates around
     wastewater treatment plant outfalls.

     Forest Practices

     The Department of Natural Resources issues Forest Practices
     permits for the clearing of properties containing over five
     thousand board-feet of timber.  Please describe this permit.
     Is the Forest Practices permit required even if the five
     thousand board-feet of timber are not going to be sold?

     Does DNR have requirements in this permit for the protection
     of adjacent surface waters?  What requirements does DNR have
     for the protection of wildlife habitat?

     Puget Sound Ambient Monitoring Program (PS AMP)

     What is DNR's, role in the PS AMP?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354) .  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
                                A-41

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                                                               RECEIVED
        WASHINGTON STATE DEPARTMENT OF                          ,,,»,«« 1001

        Natural Resources                    'JUN19'"
                                                                OEPT. OF EpflfiVfioYLE
       	Commissioner of Public Lands

                                                                  OLYMPIA, WA 98504

June 18, 1991


Ms. Lucille T.  Pebles
Washington Department of Ecology
Northwest Regional  Office
3190 160th Ave SE
Bellevue, WA  98008-5452

Subject:  Bellingham Bay Action Plan

Dear Ms. Pebles:

This letter responds to your letter of May 17, 1991 requesting  additional
information on the Department of  Natural Resource's ongoing or  planned
activities in Bellingham Bay.  For each section in your letter,  I've  provided
comments and answered your questions.

Puaet Sound Dredged Disposal  Analysis (PSDDA)

In the first sentence, note that  the disposal site is open from June  16  -
October 31 of each year, and that these dates are set by the Shoreline Permit.
In the second sentence, note that each of the four agencies with jurisdiction
in the PSDDA program (U.S. EPA, Corps of Engineers, and Washington  Departments
of Ecology and Natural Resources) approve the material that will be disposed
at the PSDDA site.   DNR issues the permit to use the site and monitors
compliance with terms of the permit.  In the third sentence, the baseline work
was conducted during the summer of 1990 rather than the spring.  Further, that
monitoring was for concentrations of certain problem chemicals  in  the tissues
of Dungeness crab,  and for crab density.  No additional biological  studies
were conducted.  This investigation was carried out in conjunction  with
Ecology's Bellingham Bay bioaccumulation survey, and our results are  to  be
incorporated into Ecology's final report.

The PSDDA bioaccumulation survey  investigated the concentrations of arsenic,
cadmium, lead,  mercury, PCBs, and various pesticides in crab muscle and
hepatopancreas.  Arsenic, cadmium, and mercury were detected in every sample.
Of the pesticides,  DDE was found  in 62 percent the samples and  Chlordane was
found in 15 percent of the samples.  Neither the other pesticides  nor PCBs
were found in any samples.  Concentrations of detected chemicals were
generally low.
                                       A-42

                   Equal Opportunity/Affirmative Action  Employer

-------
The Corps of Engineers and the Port of Bellingham are currently planning to
use the Bellingham Bay PSDDA site during the 1991 dredging season.  Sediments
from Whatcom Creek, I&J, and Squalicum Creek Waterways were tested under the
PSDDA guidelines.  None of the Whatcom Creek sediments were approved for
disposal at a PSDDA site.  Selected sediments from the other areas were
approved by the PSDDA agencies.


Sediment Management

In the first paragraph, second sentence, note that a grant was received from
U.S. EPA to initiate an inventory of aquatic leases that may contain
contaminated sediments.  That grant has been completed and all other funding
for the contaminated sediments program has been provided by the state.

In the second paragraph, first sentence, note that the user's manual will
briefly discuss regulations only to the extent that is required to educate the
users as to the regulatory authority of the state.  This manual will not
contain an exhaustive discussion of environmental regulations.  A working
draft of the manual is undergoing review by the Department of Ecology.

DNR and Ecology are continuing to negotiate the terms of a Memorandum of
Understanding concerning the respective roles of each agency when considering
sediment contamination on state-owned aquatic lands.


Port Management Agreement

DNR is presently continuing the negotiation process for the Port Management
Agreement  (PMA) with the Port of Bellingham.  The resulting PMA will address
liability  for cleanup of contaminated aquatic lands.  Final language on this
issue has  not been agreed to.


Coastal Zone Management Act

The Port of Bellingham was not given control of any state-owned lands as a
result of  the recent review of the Coastal Zone Management Act.  The Port has
no control of state-owned aquatic lands that are outside of the areas that
they currently lease from DNR.


Aquatic Lands Leasing Program

Aquatic leases contain specific restrictions on the use of environmentally
harmful substances.  Although these restrictions are summarized below,
interested parties should contact the Aquatic Lands Division (206-753-5324)
for specific lease terminology regarding harmful substances.  The following  is
a general  overview of the issues addressed in leases.
                                        A-43

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Hazardous. Toxic, or Harmful Substances.  Lessees shall not keep, use,
dispose, transport, generate and/or sell hazardous materials in violation of
any appropriate law, regulation, statute, or ordinance.  Lessees must promptly
notify the State of all spills or releases of any hazardous substance.  Lessee
shall be fully li-able to the State for any damages, expenses, suits, claims,
costs, fees, penalties, and response, cleanup costs, or remediation costs as a
result of the Lessee's control of the property.

Marine Plastics Act.  Lessees shall comply with the Marine Plastic Pollution
Research and Control Act of 1987 (Public Law 100-220).  Under this act a
lessee may be required to provide waste reception facilities, provide for US
Coast Guard inspection of these facilities, and provide for waste handling and
disposition.

Lessee to Take Corrective Action.  Lessees will take corrective action to
restore property, as nearly as possible, to its condition without the presence
of the harmful substances.  In the event that a lessee fails to do so, the
State may take the corrective actions and will be entitled to full
reimbursement of the costs  incurred.

Testing.  Lessees agree to  conduct, at their own expense, all investigations
required by the State to determine the existence, scope, or effects of
hazardous substances on the leased property or associated resources where the
State has reason to believe that hazardous substances may be present due to
ongoing or historic activities in the leased area.  If the State conducts the
investigation, then the State will be entitled to full reimbursement of the
costs incurred.

Reporting.  At the State's  request, lessees may be required to submit annual
reports that summarize and  describe all uses which have occurred upon the
leased property during the  preceding year.  Additionally, lessees may be
required to submit copies of all monitoring reports prepared in response to
state or federal requirements.


Forest Practices

Under the Washington Forest Practices Rules and Regulations (MAC 222), DNR
approves applications but does not issue permits for the clearing of
properties containing over  five thousand board-feet of timber.   (Harvesting of
less than five thousand board-feet does not require submission of a forest
practices application but is subject to the Forest Practices Rules and
Regulations).  Approved applications are required for timber harvested for
sale (see WAC 222 for definitions).  Conditions placed on the approved
application provide for the protection of soil integrity, reforestation,
streamside habitat protection, and fishery and wildlife concerns.  Under the
Timber, Fish and Wildlife (TFW) agreement, interdisciplinary teams may be
formed to deal with environmental concerns.  They make recommendations to the
Forest Practices forester who may then condition the application.
                                     A-44

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Puqet Sound Ambient  Monitoring Program (PSAMP)

DNR is conducting  an inventory of nearshore habitats  in  support of PSAMP,  and
is represented on  the PSAMP steering committee.   The  steering committee
provides guidance  on the  performance of all tasks within PSAMP.

If you have any  questions concerning these responses  to  your letter, please
contact me at 753-0263.
Sincerely,
Betsy Striplin
Division of Aquatic  Lands
                                    Reference Code:  Bellingham Bay Action Program
                                                       SEDIMENTSNbellbay.let
                                      A-45

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CHRISTINE O. GREGOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190- 160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                   May 17, 1991


        Ms. Vailana Piccolo
        Puget Sound Water
        Quality Authority
        PV-11
        Olympia, WA  98504

             Re:  Bellingham Bay Action Plan
               1/&U4SM
        Dear Mf8i PirrniQT

        This letter is in follow-up to the October 25,  1990 meeting that
        Michael Jacobson  (PTI Environmental Services),  Fran Solomon
        (Ecology), and I had with you regarding actions that the Puget
        Sound Water Quality Authority is  taking to reduce pollution in
        Bellingham Bay, via the 1991 Puget Sound Water  Quality Management
        Plan.  I have summarized below our understanding of the
        Authority's actions and have asked additional questions.  Please
        confirm or modify the summary and address the new questions
        through a written response.  This letter,  as  well as your
        response, will be included  in the draft Bellingham  Bay Action
        Plan scheduled for release  this July.

             General

             The Puget Sound Water  Quality Authority  (PSWQA) is working
             to improve water quality across Puget Sound through the
             development and implementation of the 1991 Puget Sound Water
             Quality Management Plan. This comprehensive document
             includes an action plan comprised of various programs:
             1)Estuary Management and Plan Implementation,  2)Fish and
             Wildlife Habitat Protection, 3)Spill Prevention and
             Response, 4)Monitoring, 5)Research,  6)Education and Public
             Involvement, 7)Puget Sound Foundation, 8)Household Hazardous
             Waste, 9)Nonpoint Source Pollution,  10)Shellfish Protection,
             11)Wetlands Protection, 12)Municipal and Industrial
             Discharges, 13)Contaminated  Sediments and  Dredging,
             14)Stormwater and Combined Sewer  Overflows, 15)Laboratory
             Support.

             In the 1991 Plan, the  PSWQA  has established broad funding
             priorities as well as  funding priorities by program element.
             This prioritization will help channel funds for plan
             implementation to the  most needy  areas.
                                      A-46

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Ms. Vailana Piccolo
May 17, 1991
Page 2

     The PSWQA oversees implementation of all the programs,
     including .those being carried out by other agencies.

     Monitoring

     The PSWQA coordinates the Puget Sound Ambient Monitoring
     Program (PSAMP),  which includes sampling of sediment, water,
     shellfish and bottomfish in Bellingham Bay, as well as
     monitoring of marine mammals and birds.  Near shore habitats
     are also inventoried.

     Various agencies, such as the State Department of Ecology,
     the State Department of Health, State Department of
     Fisheries and the State Department of Natural Resources
     perform the actual work.

     Education and Public Involvement

     Education and public involvement continue to be a high
     priority for the PSWQA in each of the programs.  They will
     continue to have monies available for these- activities
     through the highly successful Public Involvement and
     Education Fund (PIE-Fund).

     Washington Sea Grant was awarded a grant from this fund in
     1988 to develop an educational brochure which addresses
     marine debris at Squalicum Harbor.  Funds were also awarded
     to Whatcom Community College to develop a video and booklet
     concerning watershed protection.  What other projects in the
     Bellingham Bay area have been funded through a PIE grant?
     What is the process for obtaining a grant?  How large is
     this fund?

     Puget Sound Foundation

     The Puget Sound Foundation is a new program which responds
     to a recognized need for an ongoing structure to coordinate
     strategies and funding for research and education.  During
     the 1989-91 biennium, the Authority will establish this
     nonprofit organization whose primary tasks will be:
     1)funding and coordinating research and education programs
     on Puget Sound; and 2) assuming responsibility for certain
     elements of the research and education program as staff and
     funding allow.  What is the status of this Foundation?  What
     is the process for obtaining a grant?
                                A-47

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Ms. Vallana Piccolo
May 17, 1991
Page 3


     Wetlands Protection

     The 1989 wetlands protection program called for protection
     of significant wetlands through (1) preservation (purchase
     or other mechanisms); (2) local government regulatory
     programs that meet minimum state standards; and (3) a
     program for protecting wetlands on state-owned uplands and
     aquatic lands.  The 1991 Management Plan proposes minimum
     guidelines or standards for local government wetland
     protection programs.  The Authority is seeking public
     comment on whether to adopt mandatory standards or
     guidelines and on the content of the standards.  This
     program also includes a larger role in wetlands protection
     for the U.S. Army Corps of Engineers, the Environmental
     Protection Agency, and the U.S. Fish and wildlife Service.
     In addition, a wetlands restoration program is established.
     What is the status of the standards?

     Stormwater and Combined Sewer Overflows

     The stormwater program in 1989 included: (1) phased
     development of stormwater programs in urbanized areas of
     Puget Sound, starting with the largest cities; (2)
     requirements for all cities and counties to develop
     operation and maintenance programs, adopt ordinances for new
     development, and develop stormwater education programs; (3)
     development of stormwater controls for state highways and
     federal facilities; and  (4) requirements for all cities with
     combined sewer overflows in the Puget Sound basin to develop
     and implement plans providing for the greatest reasonable
     reduction of CSO events.

     The 1991 stormwater program adds a work group to coordinate
     policy issues among fisheries, stormwater, and wetlands
     programs and a stormwater technical assistance service for
     local governments which would be provided by the Department
     of Ecology and coordinated with local governments.  The
     program proposes that the local stormwater programs be
     incorporated into the comprehensive plans to be developed
     under the new Growth Management Act.

     Ecology will adopt a rule which sets minimum stormwater
     standards for new development, and the Authority will adopt
     a rule which requires that local governments adopt the
     stormwater programs which include standards set in Ecology's
     rule.  Have there been changes to the last two statements?
                                 A-48

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Ms. Vallana Piccolo
May 17, 1991
Page 4


The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the plan
public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.

I appreciate your support of the Bellingham Bay Action Program
and look forward to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:Ip
                                 A-49

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 NANCY McKAY
Executive Director
                                STATE OF WASHINGTON
                   PUGET SOUND WATER QUALITY AUTHORITY
            Abbot Raphael Hall • Mail Stop PV-1 5 • Olympia, Washington 98504-0900 • (206)493-9300

                                   RECEIVED
                                    Ju/v ) 2
      June  11,  1991

                                   °ŁPr. OF ECOLOGV
      Ms. Lucille T.  Peebles,  P.E.
      Bellingham Bay Action Coordinator
      Washington State Department of Ecology
      3190-160  Ave. S.E.
      Bellevue,  Washington 98008-5452

      Dear  Ms.  Peebles,

      Thank you for the opportunity  to participate in the Bellingham Bay
      Action Plan development.  Even  though we do not always have as many
      resources to devote to them as we would like,  the Authority views
      the urban bay action team (UBAT) programs as a very important part
      of protecting Puget Sound. We appreciate your  hard work and that
      of Ecology's other UBAT staff as well.

      Your  May  17,  1991 letter poses  several  clarifications and questions
      regarding the Puget Sound Plan. I will  address these issues section
      by section.

      General

      This  section accurately  summarizes the Authority's  role.  Please
      replace   the  final  sentence  with:  "   The   PSWQA  oversees
      implementation of all the programs as implemented by federal, state
      and   local  agencies, as  well   as  tribal  governments  and federal
      facilities. The  Puget Sound  Plan was adopted  in May 1991  as the
      first Comprehensive Conservation Management  Plan  (CCMP)  in the
      nation for an estuary, of national  significance under Section 320
      of the federal Clean Water Act."

      Monitoring

      To the first paragraph,  please  add  "  The PSAMP is coordinated
      through a monitoring management committee that is made up of PSWQA,
      EPA,  Tribes, local governments  and the state implementing agencies."
      In the second paragraph,  please add the Department of Wildlife to
      the   list  of implementing  agencies.  Please  note that  the PSAMP
      includes  several stations in the Bellingham Bay  area.
                                       A-50

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Education and Public Involvement

Bellingham PIE  contracts  have been awarded  to  Whatcom Community
College  (see  page 83  of  the attached  PIE  Book) ,  University of
Washington Sea Grant (page 15),  Puget Sounders (Page 129) , Friends
of the San Juans  (page 127) and the Nooksack Tribe  (page 127).

PIE contracts (technically not grants)  are awarded on a competitive
basis  two  times  each  biennium.  Requests  for  proposals  are
distributed through mass mailings  to individuals and organizations
on  PSWQA mailing  lists.  RFPs  are  also  provided  to  anyone who
requests them.

The next round of  PIE funding will begin with the release of an RFP
for Round 5 on June 15. Proposals will be due  August 16. Selections
will be announced  on October 25, 1991. Round 6 RFPs will be release
in January,  1992  with  proposals due in March and  awards  made in
May.

Although funding for Rounds 5 and 6 depends on budget deliberations
underway in  the 1991  legislature, $1.1 million  is  identified in
both the House  and Senate versions of  the  budget.  Approximately
two-thirds of the  PIE  Fund contract money  will be awarded in Round
5, one-third in Round 6.

Puaet Sound Foundation

Currently, the foundation is in its formative stages of selecting
the  first few  board  members.  Once  the  board has  been  fully
established  (summer  1991), they  will   begin their fund  raising
activities. Future grant  applications  should be directed  to the
foundation.

Wetlands

Please replace  the third  sentence with  "The Authority deferred a
final decision on  the wetlands minimum standards until summer 1991
so that additional time for public  comment  could be accommodated
for this program.  At the  time of  this writing,  the Authority was
considering a combination  of  regulatory and voluntary approaches
to wetlands protection."

Stormwater

This section  is accurate. Please add a status  section —  " The
highway Runoff Rule was adopted by Ecology on May 21, 1991. The two
parallel state stormwater  rules  for local  governments are in draft
form, and are being coordinated  with the recent federal stormwater
NPDES  regulation   (promulgated  November  1990).   Adoption of the
stormwater rules is expected by January 1992. "
                              A-51

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Sediments. Municipal and Industrial Discharges. Nonpoint etc.

Although you did not mention them in your request letter, there are
several other Puget Sound Plan programs that I feel may have direct
bearing on the condition of Bellingham Bay. I invite you to include
some of  the  summary language out of the  Plan for  these programs
plus a  brief status. An important Sediments  Standards  Rule was
adopted by Ecology  in April  1991  to implement element P-2 of the
Puget Sound Plan. These  are the first sediment protection standards
in the nation and will  likely  result in some sediment actions in
Bellingham Bay. Also note the Plan's dischargers program requires
the  systematic upgrading  of waste  discharge permits  to better
monitor and control toxics. Current, Ecology has begun to include
these requirements in  permits. While  there  has been litigation
regarding these new requirements, a joint effort by Ecology, EPA,
PSWQA, and the Tulalip  Tribes is resulting in improved monitoring
by dischargers for toxics that will eventually lead to improved
controls.

The  Nonpoint,  Shellfish,  Spill  Prevention,  and Trans  Boundary
Issues  (see  Unfinished  Agenda)  also may  warrant summary in your
action plan.  PSWQA is  currently revising the Nonpoint  Rule. The
1991  Legislature  just  passed  an  oil  spill bill that  mandates
implementation of most of our Spills Prevention Program. Also, the
recent publicity and governmental response  to  sewage  and toxics
from Canada seem  to justify some mention.

In closing, I hope that this information  is helpful in developing
your draft action plan.  If you need further information on specific
programs, I invite you  to contact individual program leads on our
staff. I have included a phone list to assist you. Again, thank you
for your  efforts on this important project.  Please  call me  (Scan
585-9173) or Ecology's Puget Sound Coordination Section, Dave Smith
(Scan 585-7078),  if you have other questions.
Sincerely,
Vailana M. Piccolo
Environmental Supervisor
cc:
Dave Peeler - Ecology
Jack Gakstatter - EPA
                               A-52

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                                                                                   Waste Management
Marine Debris Demonstration and Education Project
       Was it a coinci-
       dence that six
 months after the
 Squalicum Harbor
 recycling project began,
 the city of Bellingham
 initiated its own
 curbside recycling
 program? It wasn't
 entirely coincidental,
 according to Jim
 Humphreys. "We have a
 strong recycling ethic
 that is now institutional-
 ized here," the coordi-
 nator of the PIE-funded
 Squalicum Harbor
 project remarked.

 For one recycling
 program to inspire
 another is not uncom-
 mon. In fact, Sea
 Grant's recycling
 program was modeled
 after one at the harbor
 of Newport, Oregon.
 However, the layout of
 the Squalicum Harbor
 project was adjusted to
 the different types of
 gear that Bellingham
 fishermen use.

 At Squalicum Harbor,
 receptacles now stand at
 the head of each marina
 ramp, with additional
 receptacles near the
 commercial fishing
  Sponsors
  T University of Washing-
    ton Sea Grant Program
  T To reduce the amount of
    plastic and other debris
    that boaters dump into
    Puget Sound

  Mothodss
  T Developing a pilot
    project to collect and
    recycle plastics and
    other boat trash
T  Educating boat opera-
   tors on the problems of
   marine debris, derelict
   gear, and plastics

Materials produced:
V  Three brochures
V  A 4-color poster and
   smaller bulkhead sticker

Rosultss
T  A successful recycling
   program at Squalicum
   Harbor in Bellingham
T  Dissemination of
   information on reducing
   marine debris to
   marinas around the
   country

Targot audionco:
V  Commercial fishermen,
   recreational boaters,
   and marina operators in
   Squalicum Harbor,
   Bellingham

PII sllco:
T  $30,000
fleet's work area. Bins
hold cardboard, alumi-
num, scrap metal, scrap
wood, and nets. The
most-recycled material
is cardboard, according
to Humphreys. Local
recyclers pick up those
items that have markets,
while those without
markets are sorted into
dumpsters for later
collection as trash.

Set-up cost for this low-
budget and low-mainte-
nance recycling site was
less than $200, a feat
made possible through
clever planning and
community support.
Local fish processing
plants contributed fish
totes—four-foot square,
three-foot deep wooden
boxes—for  use as
recycling containers.
Project staff washed the
totes out, painted them
inside and out, and
added a hinged chicken
wire top to each one.

An initial lack of inter-
est from the Port of
Bellingham delayed
installation of the
modified fish totes for
nearly six months.
However, once these
new containers were in
place and boaters and
fishermen began to fill
them with trash, the
project steadily gained
momentum and wid-
ened support.

The project's second
part, the dissemination
of material about
recycling marine debris,
produced 3,000 copies
of a whimsical four-
color poster. On this
poster a familiar Puget
  Sound resident, the
  giant Pacific octopus,
  declares, "Marine
  Debris: Get a Grip on  '
  It."

  The poster is part of an
  information packet that
  the project staff devel-
  oped for other marinas.
  Also included in the
  packet are brochures:
  "Getting a Grip on
  Marine Debris at
  Squalicum Harbol?
  "Marine Debris: How
  Commercial Fishermen
  Can Help Solve a
  Growing Problem;"
  "Marine  Debris: How
  Recreational Boaters
  Can Help Solve a
  Growing Problem;" and
                                               A-53

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                                                                                          Appendices
Rainy Days in Federal Way: The Problems
of Stormwater Runoff
Sponsor: Federal Way Water And Sewer Citizen Advisory
Committee
PIE Slice: $6,500
Contact: Lois Kutscha 939-4792, 924-5711
Under the direction of the citizen advisory commit-
tee, students from Sacajawea and Kilo Junior High
School science clubs will produce a videotape and
fact sheet to inform Federal Way residents about the
damaging effects of stormwater runoff on Puget
Sound and about remedies to correct runoff prob-
lems. The project will stress the connections be-
tween runoff and wetlands, streams, lakes, and
groundwater in Federal Way.

Public Involvement in the Evaluation of the
Proposed Northern Puget Sound National
Marine Sanctuary
Sponsor: Friends of the San Juans
PIE Slice: $20,000
Contact: Nancy DeVaux 378-2319
This project will inform the public about the Na-
tional Environmental Policy Act review process to
evaluate the Northern Puget Sound National Ma-
rine Sanctuary proposal. Workshops will be held in
Friday Harbor, Mount Vernon, Bellingham. Sequim,
and Seatde. In addition to the workshops, a newslet-
ter will be used to improve communication among
user groups, conservation groups, agencies, and
officials involved. This project is based on the
Citizen Action Training School Model developed in
Round Two of the PIE-Fund by Pilchuck Audubon.

Boy Watchers
Sponsor: Greater Hansville Chamber of Commerce
PIE Slice: $15,000
Contact: Bob Lewis 692-0956
Based on the successful Sequim Bay Watchers model
developed in Round Two of the PIE-Fund, this
project will recruit, train and certify 50 Master Bay
Watchers in north Kitsap County. Using the curricu-
lum developed by the original project, the volun-
teers will learn about water quality concerns related
to septic systems, stormwater runoff, misuse of
pesticides, application of fertilizers, and boating. At
the end of the training period, the Bay Watchers will
undertake community projects to protect water
quality.

Soundbook
Sponsor: Marine Science Society of the Pacific Northwest
PIE Slice: $30,000
Contact: Jim Kolb 779-5549
A homeowner's water quality handbook with
Soundwide application will be developed, patterned
after the Chesapeake "Baybook." The handbook will
promote individual responsibility in protecting
Puget Sound, and will suggest specific activities for
people to take. A technical advisory committee,
which includes people from government, business,
industry, education, and science will assist in devel-
oping the handbook.

Tribal and Community Watershed Education
Sponsor: Nooksack Tribe Fisheries Department
PIE Slice: $9,700
Contact: Douglas Dobyns 592-5176
The Nooksack Tribe will conduct an education
project for tribal members and the general public
on the role of the tribe in watershed protection.
                                               /
Videos Puget Sesnd: Our Heritage at Risk
Sponsor: North Pacific Film and Tape
PIE Slice: $35,000
Contact: Tom Putnam 623-3151
A video will be produced based on the Puget Sound
Water Quality Authority's recent publication, Puget
Sound: Our Heritage at Risk. The video will take a
comprehensive look at Puget Sound, describe its
problems, examine the potential effects that may
result from population growth and other pressures,
and explain how individuals can become more
involved in the fight to clean up and protect this
spectacular estuary.
                                              A-54

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                                                                                          Appendices
EolgraM Ixhiblt
Sponsor: Port Townsend Marine Science Center
PIE Slice: $13,000
Contact: Anne Murphy 385-5582
The Port Townsend Marine Science Center will
construct an outdoor eelgrass exhibit composed of
an aquarium and interpretive panels. The exhibit
will be located on the dock at Fort Worden State
Park, overlooking a natural eelgrass habitat. The
panels will provide information about eelgrass, such
as its geographic distribution, its biological role as
habitat, and its link to commercially important
species offish and shellfish.

SoH-Ouidod Discovery Tours
Sponsor: Puget Sounders
PIE Slice: $9,900
Contact: Arnie Klaus 676-8094
A series of portable, weatherproof signboards will be
built to interpret various facets of the Puget Sound
ecosystem and describe human activities that harm
the system. The signboard series will include inter-
pretive information on watersheds, nonpoint pollu-
tion, habitat for migrating birds, waste stream
management, shorelines, etc.. The pilot program
will use the signboards for interpretive tours at three
sites: Vashon Island, Orcas Island, and Whatcom
County. The goal of the project is to offer a cost-
effective way to provide interpretation in places
where no permanent displays exists.

Bootor'c Prefect
Sponsor: Quartermaster Harbor Alliance
PIE Slice: $9,900
Contact: Barb Nightingale 463-3624
To reduce water column, surface, and sediment
contamination of Quartermaster Harbor on Vashon
Island, a five-part education program will be
launched. This program will include: 1) installation
of dock signage at the marina and yacht club de-
scribing the marine ecosystem and measures boaters
can take during boating and boat maintenance to
protect the ecosystem; 2) creation newsletter on
boater activities and maintenance stressing actions
to improve the harbor; 3) development of informa-
tion about improved hazardous waste containment;
4) involvement of youth in beach cleanup; and 5)
stormdrain stenciling with a "Dump No Waste.
Drains to Bay" message.

Rocroational Dlvor Education
Sponsor: Underwater Society of the Pacific Northwest
PIE Slice: $8,100
Contact: Laura Geselbracht 624-9190
The project will survey recreational scuba divers and
dive boat operators in the Puget Sound region on
favorite  diving sites, types of activities pursued, and
cumulative impacts of diving activities. The informa-
tion will be used for two purposes: to educate
recreational divers about how their activities affect
subtidal habitat and what they can do to lessen
individual impacts; and to suggest possible sites for
underwater parks, preserves and artificial reefs.

Painting Contractor Education
Sponsor: Urban Wildlife Coalition
PIE Slice: $6,600
Contact: Charles Anderson 622-5260
The project will inform painting contractors about
proper disposal and waste reduction for paint and
paint related products (such as paint thinner). A
specially designed poster and brochure and a
telephone information line will be used to commu-
nicate the information. The information will be
disseminated through local paint suppliers includ-
ing Parker Paint, Rodda, and Fuller O'Brien.

WoHand Stewards Projoct
Sponsor: Washington State University Cooperative
Extension, King County
PIE Slice: $9,900
Contact: Curt Moulton  296-3900
As part of the Cooperative Extension Land/Water
Stewardship program, a comprehensive volunteer
training curriculum will be developed on protecting
and restoring wetlands. A core of 30 volunteers will
receive 20 hours of training on general water quality
                                              A-5 5

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CHRISTINE O.CREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190- 160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                   May 17,  1991
        Mr.  Bill Geyer
        City of Bellingham
        Planning and Economic
        Development Department
        210  Lottie Avenue
        Bellingham, WA  98225

             R«:  Bellingham Bay Action Plan
               #,'//
        Dear H&» Qeyer;

        This letter is in follow-up to the October 24,  1990 meeting that
        Michael Jacobson (PTI Environmental Services),  Fran Solomon
        (Ecology), and I had with you regarding actions-that  the City of
        Bellingham Planning and Economic Development  Department  is  taking
        to reduce pollution in Bellingham Bay.  I have  summarized below
        our  understanding of the Planning Departments actions and have
        asked additional questions.  Please confirm or  modify the summary
        and  address the new questions through a written response.   This
        letter, as well as your response, will be included in the draft
        Bellingham Bay Action Plan scheduled for release this July.

             Wetlands

             The City's wetlands ordinance has been put on hold  until
             Class I and Class II wetlands can be reconfirmed through
             further field investigation.  The results  of this
             investigation will be used to develop a  wetlands map that
             will become part of the wetlands ordinance.  What is the
             status of the adoption of the ordinance?  How does  it
             compare to the Puget Sound Water Quality Authority
             recommendations?

             Land Use

             A land clearing ordinance is being formulated to provide
             requirements for the clearing of trees,  shrubs and  other
             vegetation.  The ordinance will address:

             1)   The amount of clearing that can be  performed.

             2)   Where the clearing can occur.
                                      A-56

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Mr. Bill Geyer
May 17, 1991
Page 2
     3)   The types of vegetation that can be removed.

     4)   Erosion and sediment control.

     This ordinance is aimed at addressing properties containing
     under five thousand board-feet of timber, which are not
     covered by the Department of Natural Resources forest
     practices permit.  What is the status of the land clearing
     ordinance?  How have the City's comments on forest practices
     permits been received by DNR?

     Under the Growth Management Act, the City can now review
     Forest Practices Permits and mitigate them, provide
     additional conditions, or recommend denial.  The City will
     not give positive approval of the Forest Practices Permit
     unless there is a simultaneous development application.  Has
     the requirement for a development application in conjunction
     with the Forest Practices Permit been successful?  What is
     the rationale behind this requirement?

     In 1979 the City and Whatcom County created an Urban Growth
     Boundary outside of the city limits.  The area between the
     boundary and the city limits has an interim urban density
     zoning until a new comprehensive plan is developed.  The
     City will provide water and sewer service to these areas
     under the assumption that they will ultimately build out to
     urban densities and be annexed into the City.  What is the
     status of the comprehensive plan?  Is there a written
     agreement between the City and County on providing water and
     sewer service, and future annexation?

     State Environmental Policy Act  fSEPAl

     The City was considering revising the SEPA threshold levels
     which determine when an environmental impact statement must
     be prepared.  However, due to staff shortages this task was
     put on hold.  What is the status of this effort?  What
     revisions are you proposing and why?

     Squalicum Creek Watershed

     The City of Bellingham Public Works Department is performing
     an assessment of Squalicum Creek.  The assessment includes
     wetlands, flood control, open space, wildlife habitat, and
     development opportunities.  From this effort a drainage
     improvement plan will be developed.
                               A-57

-------
Mr. Bill Geyer
May 17, 1991
Page 3


     Squalicum Creek ranked number two to receive a watershed
     management plan, and the work by the Public Works Department
     addresses drainage issues only.  Who will be developing a
     management plan for the Squalicum Creek watershed and when?

     The city Public Works Department has also been monitoring
     Squalicum Creek since January of 1990.  The fecal coliform
     counts for June and October were well above state water
     quality standards.  A potential source of these elevated
     counts could be livestock.  Does the City have any plans to
     create an ordinance to keep animals out of creeks and to
     provide measures to prevent manure runoff from entering
     streams?  If the source of these high fecals are thought to
     be outside of the city limits, what actions will be taken?


The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354) .  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.


                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                                A-58

-------
CHRISTINE O. GREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                 May 17, 1991
      Mr. Jack Garner,  P.E.
      City of Bellingham
      Department  of
      Public Works
      210 Lottie  Avenue
      Bellingham, WA.   98225

           Re:  Bellinghaa Action Plan

      Dear

      This letter is  in follow-up to the November 6, 1990 meeting that
      Michael Jacobson  (PTI  Environmental Services), Fran Solomon
      (Ecology),  and  I  had with you, Ken Thomas, and Bill McCourt,
      regarding actions that the City of Bellingham Department of
      Public Works is taking to reduce pollution in Bellingham Bay.  I
      have summarized below  our understanding of the City's actions and
      have asked  additional  questions.  Please confirm or modify the
      summary and address the new questions through a written response.
      This letter, as well as your response, will be included in the
      draft Bellingham  Bay Action Plan scheduled for release this July.

           Lake Whatcom

           The City is  the lead agency in a study (funded in part by
           Referendum 39 monies) of Lake Whatcom and its watershed.
           Phase  I of the study was completed in 1986 and resulted in a
           management plan for the lake.  The plan identified several
           areas  which  required additional attention in order to ensure
           protection of the lake's existing water quality.  Phase II
           of the study is designed to address the concerns of the
           management plan and is currently underway.  The City is
           involved in  lake  restoration efforts. The Whatcom County
           Health Department is under contract to the City for an on-
           site sewage  disposal survey, and the Whatcom County Public
           Works  Department  is under contract to the City for the
           formation  of development standards, a fuel tank inventory,
           and a  storm  drainage inventory.  What is the status of these
           various tasks? What is the next step?
                                       A-59

-------
Mr. Jack Garner, P.E.
May 17, 1991
Page 2


     A portion of the grant was earmarked for the development of
     educational materials on the protection of the Lake Whatcom
     watershed:

     1)   Written material was developed for third graders.

     2)   Sixth graders participated in a conservation site
          within the watershed and in a poster contest.  Written
          material for this age group was developed and as well
          as a slide show.

     3)   Coordination with schools and teachers has been
          initiated to incorporate watershed education in their
          curriculum.  Also, workshops have been held for
          teachers, at which kits for analyzing basic water
          quality parameters were prepared for the workshop
          attendees.

     4)   Pamphlets were developed for the general public as
          well.

     The City plans to continue educational efforts beyond the
     grant funding and develop additional educational materials.
     will this information be specific to Lake Whatcom?  What
     will be the nature of the material?  The Lake Whatcom
     watershed is especially important because it is the City's
     drinking water source.  However, all watersheds need to be
     protected.  Are there plans to increase the scope of the
     educational materials to address watershed protection In
     general?

     Squalicum Creek

     As an element of a Floodplain Management grant, the City has
     performed a wetlands assessment of Squalicum Creek. Flood
     control, open space, wildlife habitat, and development
     opportunities are the other elements that will be assessed.
     As a result of these assessments a plan will be developed to
     protect the wetlands; this could potentially involve
     rezoning.  A draft plan will be completed in November of
     1991; the final plan will be completed in April of 1992.
     What is the status of the other assessments?

     Squalicum Creek has a number two priority, behind Orayton
     Harbor, for the development of a watershed management plan.
     Who will be developing the watershed plan for Squalicum
     Creek?  When would this work begin and be completed?
                                 A-60

-------
Mr. Jack Garner, P.E.
May 17, 1991
Page 3

     The Whatcom county Council of Governments is performing the
     Drayton Harbor work, would they be a potential candidate for
     the Squalicum Creek work as well?

     Stormwater

     The City does not currently have a stormwater utility or
     comprehensive development standards to directly address
     stormwater issues.  The creation of a utility will be
     considered at the time Ecology issues rules and guidelines
     for stormwater management programs.  The City does have a
     development fee that covers impacts of new development.
     What requirements are currently in place to address erosion
     and sediment control, detention, and the treatment of
     stormwater?  How frequently are the City's drainage systems
     cleaned?  How is the removed material disposed of?  Does the
     City require oil/water separators for all new developments?
     Please describe the development fee (i.e. the amount of the
     fee, how it is assessed, and how the collected fees are used
     to offset impacts).

     Will any City owned/operated facilities require a NPDES
     permit under the new Federal storm water regulations (e.g.
     bus washing facility)?

     The Lake Whatcom Development Standards will be benefical in
     the effort to improve water quality in Lake Whatcom.  What
     are your thoughts on applying these development standards
     city- wide?

     Water Quality

     In January of 1990, the City began sampling all creeks
     within the city limits once a month.  Parameters tested are
     temperature, pH, turbidity, dissolved oxygen, and fecal
     coliforms.  What prompted the City to begin this sampling
     program?  Will actions be taken if Class A water quality
     standards are exceeded?  If water quality criteria
     exceedances are suspected to result from activities outside
     of the city limits, what coordination would occur with the
     County?

     Given that the City of Bellingham will be required to permit
     their storm drain outfalls at some time in the future, what
     plans do you currently have for monitoring storm water and
     storm drain sediments for contaminants?

     What role does Public Works play in addressing the
     contribution of dairy wastes to water quality problems?
                                A-61

-------
Mr. Jack Garner, P.E.
May 17, 1991
Page 4


     What actions are being taken to address the contribution of
     herbicides, pesticides and fertilizers to the degradation of
     surface waters  (e.g. public education, reduced use of these
     chemicals or use of alternative environmentally friendly
     products by the City and their contractors) ?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354) .  Please have your response letter to me by Friday,
May 31st.

I appreciate your cooperation in this process and look forward to
your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTPrlp
                                A-62

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                     DEPARTMENT OF PUBLIC WORKS, 210 Lottie St., Bellingham, Washington 98225
                     Telephone (206) 676-6961


                                       June  7,  1991         RECEIVED

                                                             JUN 1 0 1991

Lucille T. Pebles,  P.E.                                      0ŁPT OF ECOLOGY
Bellingham Bay Action  Program  Coordinator
Department of Ecology
Northwest Regional  Office
3190 160th Avenue SE
Bellevue WA 98008-5452

Dear Ms. Pebles:

    You requested a partial response with available information  to your letter
of May 17th.  This  letter will  answer  some  of  your questions with the  remaining
information to follow  as soon  as  it is available.  To  aid  in our response,  I
have given the questions in your  letter an  identifying number, and our
responses are keyed to those numbers.

    In Question #4  you inquire about the preparation of a  watershed plan for
Squalicum Creek.  As far as I  know, there is no  local  agency willing to sponsor
any additional watersheds given the limited financial  support offered  by the
State.

    In Question #6  you ask if  any City facilities will  require NPDES permits
under the new storm water regulations.   This is  the first  time I  have  received
anything from the State Department of  Ecology  concerning this program.   Since
the State of Washington administers the NPDES  permit system for  the Federal
Government, we have been expecting some information, direction,  training,
guidance or contact of any kind from the State on this program but this has not
occurred.  Since we have no information on  the program, I  cannot  answer your
question.

    Question #10 concerns the  role of  the City's Public Works Department in
addressing dairy wastes.  Since there  are no dairy operations in  the City  of
Bellingham and since the vast  majority of the  watershed is outside the City
limits, we have not identified any active role in dairy waste management.

    Please see the  attached memo  for responses to Questions 1, 2, 8 and 11.
Responses to Questions 3, 5, 7 and 9 will be forwarded as  soon as they are
available.

                                         ncerely,
                                      Jc
JMG:shh
060791
tin M.  Garner,  P.E.
                                       Pi >lic Works Director
Attachment
                                        A-63

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                                                               RECEIVED
                                                                 DEPT< °F ECQLOGY
                     DEPARTMENT OF PUBLIC WORKS, 210 Lottie St., Bellingham, Washington 98225
                     Telephone (206) 676-6961
                                       June 12, 1991
Lucille T. Pebles, P.E.
Bellingham Bay Action Program Coordinator
Department of Ecology
3190 160th Ave. S.E.
Bellevue WA 98008-5452

Dear Ms. Pebles:

         RE:  Bellingham Bay Action Plan

    This letter is intended to complete our response to your letter of May 17,
1991, concerning the Bellingham Bay Action Plan.

    Under the Squalicum Creek section, we would suggest the following
modifications to the summary statement.  Change "protect the wetlands" to
"manage the floodplain."  Change "November of 1991" to "April of 1992," and
"April" to "June."

    Assessments of the current status of flood control, open space, fish and
wildlife habitat, and development have been completed.  Modeling of storm water
flows will occur next, the results of which will form the basis for determining
impacts and recommended improvements.  All will be summarized in the draft plan
due out in April of 1992.

    Under the Storm water section, we would substitute the following summary:

    The City recently (July 1990) enacted a drainage utility in order to
    address current and future drainage issues and problems.  At this time, the
    fees are collected on all developments at the time permits are taken out,
    and are based on the amount of impervious surface created.  Single-family
    homes are charged $400, and everything else is charged $400 for each 3,000
    square feet of impervious surface created.  The collected fees are placed
    in a fund which is used to upgrade deficiencies in the drainage system, to
    build facilities of regional benefit, and to support increasing demands on
    drainage division staff.

    All  land-disturbing activities in the Lake Whatcom watershed must be
    accompanied by an approved temporary erosion and sedimentation control
    plan,  with permanent BMP facilities required of larger developments.
    Elsewhere, subdivisions and projects with potential environmental impacts
    are also generally required to provide an E/S plan as a condition in the
    development contract or permit.
                                        A-64

-------
Lucille Pebles, P.E.
June 12, 1991
Page 2


    There is no automatic detention requirement in Bellingham.  Downstream
    impacts of development are assessed with each project,  however, and the
    developer is given the option of correcting any deficiencies or providing
    detention to pre-development rates.  Projects with parking lots must
    provide outlet traps in the catch basins to trap oil  and debris.  Other
    water quality controls may also be required of new developments by the City
    Council.

    It is anticipated that the Lake Whatcom Development Standards for water
quality control will be employed uniformly in the City eventually.   Although
the ordinance specifies only the lake, the standards are  often employed
elsewhere through the SEPA process.

    In response to your question under the Water Quality  section concerning
monitoring, the City is aware of upcoming NPDES requirements from information
provided by trade associations, but has not embarked on a discharge sampling
program at this time.  We expect to comply with monitoring  requirements once
they are developed by the Department of Ecology.
                                       Sincerely,
                                       Jolty M.  Garner,  P.E.
                                       Pumic Works  Director
JMGrshh
061291
                                       A-65

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                    DEPARTMENT OF PUBLIC WORKS
                            MEMORANDUM
 TO:        Ken Trnpntas,  Operations  Engineer
               Ar
 FROM:      Bill McCourt,  P.W.  Superintendent  -  Operations

 DATE:      May 28,  1991

 SUBJECT:   Bellingham Bay Action Plan  Questions


     I will  attempt to answer the questions  that Lucille  Pebles
 posed in  her letter of May  17.

     Question #1 - The Whatcom County Health Department has
 completed their  task on the survey of septic systems within the
 watershed.   Corrective actions on failing systems have either
 been completed or are in progress.  The City has contracted with
 the Health Department to provide  a septic system maintenance
 program for  the  entire county.  The system will maintain  an
 inventory of all septic systems and provide  reminders to
 homeowners when  maintenance is required.  The  Whatcom County
 Public Works Department has prepared  draft development standards
 based upon Ecology's guidelines.   The standards should be
 submitted to the Council and  adopted  this summer.  The
 underground  fuel storage tank inventory has  been completed and a
 draft ordinance  regulating  tanks  has  been proposed.  I anticipate
 that these standards would  be completed this summer.  The storm
 drainage  inventory has been completed for both the city and
 county portions  of the watershed.   Both agencies are
 incorporating the  information in  their capital improvement
 programs  and developing maintenance programs for these
 facilities.

     Since the Lake Whatcom Advisory  Committee has been
 disbanded, it is unclear if any additional steps will be  taken.

     Question #2 -  The focus  of our current  education program is
 on the Lake  Whatcom Watershed.  It  is of  highest priority since
 it is the source of the  city's drinking water.  The materials on
 the watershed are sent to all watershed residents and all City of
 Bellingham utility  customers.  The  information contained  in them
 is applicable  to any watershed.  The Raindrop, Rooftop, and
Riparian watershed  walks at Shuksan, Whatcom,  and Fairhaven
Middle Schools are  specifically targeted  at  Squalicum Creek,
Whatcom Creek, and  Padden Creek.   The City has also put together
4 water quality test kits for use by schools and other interested
groups.   The  storm  drain stenciling program was targeted  at all
                                 A-66

-------
js. Thomas
May 28, 1991
Page 2


watersheds.  The City will continue to promote programs with  Lake
Whatcom being the primary focus and watersheds in general will  be
considered secondary.

     Question #8 - The City began the Creek Monitoring Program  as
an inexpensive yardstick on the health of our streams.  The City
will perform a cursory look at why streams exceed the Class A
criteria.  Fecal coliform testing will be pursued on the highest
sites, and in the future low dissolved oxygen levels will be
looked into further.  The City is currently only sampling those
streams located within the city limits and does not know of any
comparable programs within the County with which to coordinate.

     Question #11 - The City has addressed the issue of garden
and household hazardous wastes through the Lake Whatcom Education
Program.  It has included brochures f  a. sl^deshow.  and a public /
seminar on Lake Friendly gardeTTTngTThecTCy^^Jrl-so^has a program <*
for recycling and disposal qf household hazardgus—'wastes.  The  V*
Cooperative Extension Service~~±g being—proSoEed as a resource
agency to suggest more watershed friendly solutions to
The City has discontinued the use of herbicides^and the County
has also discontinued their use in areas considered
environmentally sensitive including the Lake Whatcom Watershed.
I have attached a sample of some of the brochures that have gone
out so far.  An additional one on Lake Friendly Gardening should
be coming out in June or July.

     Please let me know if you have any other questions regarding
these matters.
WPM:sk
                              A-67

-------
CHRISTINE O. CREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190- 160th Ave S.E. • Bellevue, Washington 98008-5452 • (206) 649-7000


                                   May 17, 1991
        Mr. Byron Elmendorf
        Bellingham Parks and
        Recreation Department
        3424 Meridian Street
        Bellingham, WA  98225

             R«:  Bellingham Bay Action Plan
                &**or\
        Dear Mr- Elmenelorf;

        This letter is in follow-up to the  September 26,  1990 meeting
        that Michael Jacobson  (PTI Environmental  Services),  Jacques
        Faigenblum (EPA), Fran Solomon  (Ecology),  and I had  with you and
        Tim Wahl, regarding actions that the  Bellingham- Parks and
        Recreation Department is taking to  reduce pollution  in Bellingham
        Bay.  I have summarized below our understanding of the Parks
        Departments actions and have asked  additional questions.  Please
        confirm or modify the summary and address the new questions
        through a written response.  This letter,  as well as your
        response, will be included in the draft Bellingham Bay Action
        Plan scheduled fqr release this July.

             Posting of Warning Signs

             The City Parks Department would  be willing to post health
             advisory signs provided by the State Department of Fisheries
             or the State Department of Health.   These signs would be
             posted at Bellingham beaches found to contain shellfish
             whose consumption would pose a human health  risk.

             Educational Activities

             The Parks Department currently has one person working half-
             time at the Maritime Heritage  Center who provides
             interpretive information about the fish hatchery.  The Parks
             Department would like this position  to become full-time with
             more emphasis being placed on  overall water  quality issues.
             This position is currently funded by British Petroleum and
             the Bellingham School District.  However, no additional
             funds are available to make the  position full-time.
                                     A-68

-------
Mr. Byron Elmendorf
May 17, 1991
Page 2


     Also, if funds were available, the Parks Department would
     like to provide interpretive signs along trails adjacent to
     streams.  Does the Parks Department plan to seek funding to
     expand their educational activities?

     Padden Creek Estuarv

     A planning study, providing a long range plan for the Padden
     Creek Estuary area, was completed in June of 1990.  The
     study assessed existing conditions and recommended policies
     and actions for public access and wildlife and landscape
     management.  Initial recommendations are currently being
     implemented.

     With funds from the Aquatic Lands Enhancement Account,
     primary improvements to public access as well as the
     installation of interpretive elements, were scheduled to
     begin in the fall of 1990, with final completion in the
     spring of 1992.

     What is the status of the initial work?  Will all of the
     recommendations of the study be implemented?  If so, when
     and what will be the funding source?

     Little Soualicum Park

     A draft site -management plan for Little Sgualicum Park was
     prepared in April of 1990.  The plan calls for, "maintaining
     the majority of the site east of the Marine Drive bridge in
     a natural state, while improving the west meadow portion of
     the site west of the Marine Drive bridge for more intense
     human uses involving more traditional park improvements.1'
     What is the status of this plan?

     Water Quality

     Who owns and maintains storm drain systems on Parks
     Department properties?  Storm drains are a significant
     contributor to the degradation of surface waters.
     Therefore, it is important to keep them clean to minimize
     their environmental impact.  How frequently are your systems
     cleaned?  How are the removed materials disposed of?  Is
     there any testing of the materials for toxic substances?

     Pesticides, herbicides, and fertilizers contribute to the
     degradation of waters as well,  what actions are being taken
     to reduce the impacts of these chemicals (e.g. reduction in
     use or using environmentally friendly products)?
                              A-69

-------
Mr. Byron Elmendorf
May 17, 1991
Page 3

     Waste Reduction

     What is being dona to encourage park users to recycle?

     What is done with organic materials obtained through park
     maintenance?  Can the materials be composted?  Does the
     presence of pesticides, herbicides and fertilizers affect
     its compostibility?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354) .  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                                A-70

-------
CHXIST1NE O. CRECOIRE                       12»T«H5I                 RECEIVED

                                     —™r                  MAY 2 8  1991
                                 STATE OF WASHINGTON              p^. ^ ffn^^

                           DEPARTMENT OF ECOLOGY
          \orthwest Regional Officef 3190 - 160th Ave S.f. • Bellevue, Washington 98008-5452 • (206)649-7000


                                   May 17, 1991
        Mr. Byron Elmendorf
        Bellingham Parks  and
        Recreation Department,
        3424 Meridian  Street
        Bel.liligh.iui, WA—98255"
             Re:  Bellingham Bay Action Plan
                &4*ot^
        Dear Mru. Elnendorf ;

        This letter  is  in  follow-up to the September 26, 1990 meeting
        that Michael Jacobson (PTI Environmental Services) , Jacques
        Faigenblum  (EPA) ,  Fran Solomon (Ecology) ,  and I had with you and
        Tim Wahl, regarding  actions that the Bellingham Parks and
        Recreation Department is taking to reduce pollution in Bellingham
        Bay.  I have summarized below our understanding of the Parks
        Departments  actions  and have asked additional questions.  Please
        confirm or modify  the summary and address the new questions
        through a written  response.  This letter,  as well as your
        response, will  be  included in the draft Bellingham Bay Action
        Plan scheduled  for release this July.

             Posting of Warning Sins
             The City Parks Department would be willing to post health
             advisory signs provided by the State Department of Fisheries
             or the  State Department of Health.  These signs would be
             posted  at Bellingham beaches found to contain shellfish
             whose consumption would pose a human health risk.

          „/ Educational Activities
             The Parks Department currently has one person working half-
             time  at  the Maritime Heritage Center who provides^ut^/^~irtkC
             interpretive information about the fleh hatchery.^ The Parks
             Department would like this position to jbej5jm^VvfuU.-time with
             more  emphasis being placed on overall water quality issues.
             This  position is currently funded by British Petroleum and
             the Bellingham School District.  However, no additional
             funds are available to make theposition full-time.


                                           ^-
                                      A-71

-------
        Mr. Byron Elmendorf
        May 17, 1991
        Page 2


             Also, if. funds were available, the Parks Department  would
             like to provide interpretive signs along trails adjacent  to
             streams.  Does the Parks Department plan to seek funding  to
             expand their educational activities?
             Padden Creek Estuary                            _
                                                                  o f*-^
             A planning study, providing a long range plan for the Padden
             Creek Estuary area, was completed in June of 1990.  The
             study assessed existing conditions and recommended policies
             and actions for public access and wildlife and landscape
             management.  Initial recommendations are currently being
             implemented.

             With funds from the Aquatic Lands Enhancement Account,
             primary  improvements to public access as well as the
             installation of interpretive elements, were scheduled to
             begin in the fall of 1990, with final completion in the
             spring of 1992.

   f.<  ^"^   What is  the status of the initial work?  Will all of the
^T    ^^^ recommendations of the study be implemented?  If so, when
             and what will be the funding source?

             Little Squalicum Park

             A draft  site management plan for Little Squalicum Park was
             prepared in April of 1990.  The plan calls for, "maintaining
             the majority of the site east of the Marine Drive bridge in
      ) .^   a natural state, while improving the west meadow portion of
      *•      the site west of the Marine Drive bridge for more intense
     i^-eyT^- human uses involving more traditional park improvements."
     /   ,    What is  the status of this plan?
     lao-oTL         /    ,^n*.7^   . __  / ,
             Water Quality

             Who owns and maintains storm drain systems on Parks
             Department properties?  Storm drains are a significant             Ji
             contributor to the degredation of surface waters.                ,j
    S/^i.    Therefore, it is important to keep them clean to minimize        V
     ~   '   their environmental impact.  How frequently are your  systems    ^ ^
             cleaned?  How are the removed materials disposed of?  -TS~	^f1 .f"
             there any testing of the materials for toxic substances?      ^**

             Pesticides, herbicides, and fertilizers contribute to the
             degradation of waters as well,  what actions are being  taken
             to reduce the impacts of these chemicals  (e.g. reduction in
             use or using environmentally friendly products)?
                                      A-72

-------
Mr. Byron Elmendorf
May 17, 1991
Page 3

     Waste Reduction

     What is being done to encourage park users to recycle?  
-------
CHRISTINE O. GRECOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190 - 160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                 May 17, 1991
    Mr.  Chuck Timblin
    Whatcom County
    Conservation District
    6975 Hannegan Road
    Lynden,  WA  98264
         R«:   Bellingham Bay Action Plan
           CAutk
    Dear Mi-.  Timblin;
    This letter is in follow-up to the October 31, 1990 meeting that
    Michael Jacobson (PTI Environmental Services) , Fran Solomon (Ecology) ,
    and I had with you regarding actions that the Whatcom County
    Conservation District is taking to reduce pollution* in Bellingham Bay.
    I have summarized below our understanding of the Conservation
    District's actions and have asked additional questions.  Please
    confirm or modify the summary and address the new questions through a
    written response.  This letter, as well as your response, will be
    included in the draft Bellingham Bay Action Plan scheduled for release
    this July.

         Watershed Management

         Through watershed management plans, the Conservation District is
         addressing nonpoint pollution issues in Kamm Creek and 10-Mile
         Creek, which are tributary to the Nooksack River.
         Implementation of the Kamm Creek Watershed Management Plan will
         begin soon, and includes: Inventorying and Monitoring, Education,
         Technical and Financial Assistance, and Regulation and
         Enforcement programs.  Centennial Clean Water Fund monies are
         being pursued for the implementaion of the 10-Mile Creek
         Watershed Management Plan.  What is the status of receiving funds
         for the implementation of the 10-Mile Creek Plan?

         In February of 1989, the Conservation District and the Whatcom
         County Health Department, began a one year joint water quality
         monitoring project in Bertrand-Fishtrap Creek watershed.  As a
         result of this effort, many of the farms adjacent to waters
         having the highest fecal coliform concentrations contacted the
         Conservation District for waste management planning assistance.
         What is the status of waste management in the Bertrand-Fishtrap
         watershed?   Will water quality be monitored  in the future to
         determine the effectiveness of the waste management efforts?
         What other joint efforts are planned?


                                     A-74

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Mr. Chuck Timblin
May 17, 1991
Page 2


   Farm BMPs  Program

   Under the  farm best  management  practices  program,  Ecology
   receives and investigates  complaints  and  then  sends  out a notice
   of  violation.   The notice  includes  a  recommendation  that the
   violator contact their local  Conservation District within the
   next ten days to begin work on  a water quality management plan.
   A copy of  the notice is sent  to the Conservation District.

   The violator then has 6 months  to develop a water  quality
   management plan,  with or without the  Conservation  District's
   assistance,  and 18 months  to  implement it.  If these time frames
   are not adhered to or the  violator  is non-cooperative,  the
   Conservation District can  refer the violator back  to Ecology for
   potential  enforcement action.

   The Conservation District  would like  to be able to preform more
   follow-up  inspections to ensure that  management plans are being
   complied with.   However, they have  limited staff.  What is the
   status of  hiring new personnel  to enable  more  follow-ups?

   Cost-share funds are available  from the Agricultural
   Stabilization and Conservation  Service for farmers to develop and
   implement  their management plans as long  as they are not involved
   in  an enforcement action.  Also, if the facilities installed with
   cost-share funds are not maintained,  farmers may have to return
   the cost-share monies.

   Wetlands

   The Soil Conservation Service (SCS) identifies and inspects
   wetlands to insure farmers are  in compliance with  the federal
   Farm Bill.  A new staff person  has  been added  to perform wetlands
   determinations.  What will be the boundaries within  which
   wetlands are designated?  Are there Whatcom County personnel
   performing wetlands  determinations, and if so, how will the SCS
   work overlap with the County's? What requirements will SCS
   develop to protect wetlands?

   Education

   The Conservation District  writes a  waste  management  news article
   that the Whatcom County Cooperative Extension  publishes monthly
   in  the Whatcom County Dairyline.  The District would like to have
   their own  quarterly  or bimonthly newsletter at sometime in the
   future. What is the status of  a newsletter by the District?
                               A-75

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  Mr.  Chuck  Timblin
  May  17,  1991
  Page 3


     The District has a 3-day conservation camp, in association with
     the Georgia Pacific tree farm at Lake Whatcom.  The camp teaches
     6th graders about the value of soil conservation.

     In conjunction with the Whatcom County Cooperative Extension, the
     Conservation District is developing two videos on farm animal
     waste management.  The first video will address waste pond
     management and maintanence and the second waste use.  What is the
     status of these videos?  How are they made available to the
     public?

     The Conservation District also has a brochure which addresses
     conservation practices for farmers.

     Dairy Waste Management Committee

     The Conservation District will be serving on the industry-
     sponsored Whatcom County Dairy Waste Management Committee.  What
     is the status of this committee?  What is its function? What
     authority does it have, or is it more of a cooperative and/or
     advisory committee?

     Permitting of Nonpoint Pollution

     Permitting of wastes from concentrated animal feed lots, was
     originally established in the Federal Clean Water Act, Section
     208. This idea is being revisited by a committee on which the
     Conservation District will serve.  What is the status of this
     committee?  What will be their authority, cooperative and/or
     advisory?

The draft Action Plan will be distributed for review to each member of
the Bellingham Bay Action Program Work Group.  A full work group
meeting will be held this summer to discuss and comment on the draft
plan.  Prior to the finalization of the plan, public comments will
also be solicited.

If you would like to discuss or clarify any issues prior to sending
your response letter, feel free to call me at 649-7272 (SCAN 354).
Please have your response letter to me by Friday, May 31st.

I appreciate your support of this process and look forward to your
response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp

                                    A-76

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                                                  RECEIVED


Whatcom County Conservation District	MAY 3 1  1991	
AGRICULTURAL SERVICE CENTER - 6975 HANNEGAN ROAD - LYNDEN, WASHINGTON 98264 DŁfifc|\®:(Łfi|pb8Ł&>35     FAX (206) 354-0318
                                 May 30,  1991
  To:        Lucille T. Pebles,  P.E.
            Bellingham Bay Action Program
            Coordinator
            DEPARTMENT OF ECOLOGY
            Bellevue, WA 98008-5452

  From:      Chuck Timblin/Resource Technician

  RE:        Bellingham Bay Action Plan

  Enclosed is a response to the summary and questions regarding the
  Bellingham Bay Action Project.

        Watershed Management

        Implementation of the Kamm Creek Watershed Plan began nearly a
        year ago.  Funding to get this project under way was provided by a
        Water Quality Special Project grant of $475,000 from the
        Agricultural Stabilization and Conservation Service (ASCS).
        Technical assistance was  provided by the SCS. At least 50% of the
        farm waste management plans  have already been implemented.  In
        addition, newsletters have been published and a fair booth was
        established last summer at the Northwest Washington Fair.

        Tenmile Creek Plan implementation could begin this July.  This
        project ranks 30th out  of 80 projects being considered for CCWF
        grants.

        Farmers in Bertrand-Fishtrap Creek Watershed continue to implement
        waste management plans,  either voluntarily, or in response to
        notification of water quality violations (as provided by the
        conditions of the Compliance MOA that the District and Ecology
        agreed upon).  There are  no  plans for water quality monitoring at
        this time.  Personally,  I would like to do some followup
        monitoring in portions  of this watershed where implementation has
        been fairly intense to  determine whether this effort has been
        worthwhile.  Perhaps your agency would be interested in joining
        in this effort?
Board of Supervisor*     GERALD B. DIGERNESS     BERNICE GRAVES    GARY HOUGEN    FRANK IMHOF     BASTIAN SCHOLTEN
                                      A-77

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Farm BMPs Program

The SCS recently placed one additional person in the Lynden field
office (Lee Ko started work here in September of last year).  Much
of Lee's time is spent doing followup.

ASCS funds for cost-share assistance are not denied to farm
operators who have received notification of water quality
violation, only those that fail to heed the notification.  This
policy is very important because it gives the District
considerable leverage in gaining voluntary cooperation from those
that are notified of violations.

Wetlands

No new staff person has been added by SCS to perform wetland
determinations (during our last meeting I may have had the
erroneous notion that Lee Ko would be providing this service).
The boundaries for SCS wetlands determinations are all of Whatcom
County.  At this time no Whatcom County personnel perform wetland
determinations.  The requirements SCS has developed to protect
wetlands are those mandated by the most recent Farm Bill.  In
essence this bill requires no net loss of wetlands (something you
probably already knew).

Education

The District will begin publication of a quarterly newsletter
later this year.  The funding source is a Conservation Commission
sponsored CCWF grant.

The videos are still in the production phase.  The project is now
largely in the hands of Cooperative Extension.  When completed
(hopefully by June 30, 1991), the videos will be available through
both the District and Extension.

Dairy Waste Management Committee

A coordinator has been hired for this committee.  For more
information about this committee contact:
                        Henry Bierlink
                        Nutrient Management Program Assistant
                        Courthouse Annex
                        1000 N. Forest St.
                        Bellingham, WA 98225
                        (206) 738-2531
                            A-78

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Permitting of Nonpoint Pollution

This committee basically has an advisory role.  The committee is
currently waiting for Ecology to prepare the first permit draft.
The draft should be available by August or September.
                             A-79

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CHRISTINE O. GREGOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190- 160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                 May  17,  1991
      Ms.  Becky Peterson
      Whatcom County Council
      of Governments
      1203 Cornwall, Suite 104
      Bellingham,  WA  98225

            Re:   Bellingham Bay Action Plan
              AeAc.
      Dear Ma.  Pi^Eei.jium;

      This letter  is in follow-up to the September 27, 1990 meeting
      that Michael Jacobson (PTI Environmental Services), Jacques
      Faigenblum (EPA), Fran Solomon (Ecology), and I had with you
      regarding actions that the Whatcom County Council of Governments
      is taking to reduce pollution in Bellingham Bay.  I have
      summarized below our understanding of the Council of Governments
      actions and  have asked additional questions.  Please confirm or
      modify the summary and address the new questions through a
      written response.  This letter, as well as your response, will be
      included in  the draft Bellingham Bay Action Plan scheduled for
      release this July.,

            Silver  Creek Watershed Management Plan

            The Silver Creek Watershed Management Plan was approved by
            the Department of Ecology in April of 1990.  In addition,
            Centennial Clean Water Funds have been obtained for
            implementation the management plan.

            Plan implementation was scheduled to begin in January 1991,
            and includes the following source control programs for
            Silver  Creek: Education, Monitoring, Agriculture,
            Pesticides,  Solid Waste Disposal, Forestry, On-Site Septic
            Systems, Stormwater/Erosion Control and Household Hazardous
            Waste.

            Under the education element, a "Watershed Educators" program
            would be implemented.  This program would be similar to the
            Master  Gardener program where volunteers would receive
            formal  water quality and nonpoint pollution training.  In
            exchange for the training, volunteers commit themselves to
            spending a set number of hours educating the public on water
            quality issues.
                                     A-80

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Ms. Becky Peterson
May 17, 1991
Page 2

     Monitoring will be performed by the Institute for Watershed
     Studies at Western Washington University.  Water samples
     will be taken at eleven stations over a two year period, on
     a monthly or rain event basis.  A single sediment sample
     will be taken at three locations sometime during the two
     year period.  Water samples will be analyzed for
     conventional parameters and sediment samples for priority
     pollutants.  An invertebrate survey will also be performed.

     As part of the agriculture program, the Whatcom County
     Conservation District and the U.S. Soil Conservation Service
     will perform farm inventories to determine impacts to water
     quality.  The farmers will then be encouraged to implement
     best management practices.

     The on-site septic system program includes the addition of a
     Whatcom County Health Department staff person to oversee
     water quality issues.

     What is the status of the various source control programs?

           Watershed Management Plans
     What is the possibility that the Council of Governments
     develop the watershed management plan for Squalicum Creek?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354) .  Please have your response letter to me by Friday,
May 31st.

I appreciate your support of this process and look forward to
your response.
                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:Ip
                                A-81

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                WHATCOM COUNTY
                COUNCIL OF GOVERNMENTS

                WCCOG
 01991
                                                   OF »/,,„„,,
May 29, 1991
Lucille T. Pebles, P.E.
Bellingham Bay Action Program
Department of Ecology
Northwest Regional Office
3190 - 160th Ave., S.E.
Bellevue, WA  98008-5452
Re:  Bellingham Bay Action Plan Correspondence
Dear Lucille:

This letter  is in response  to the questions  posed in your  May 17th
correspondence.  I will answer them point by point as outlined in your
letter which I have attached a copy of for easy reference.

  1.  The status of the source control programs are as follows:

  *  Plan Implementation - Implementation was scheduled to begin
     in January  of  1991.   Although  some of  the  recommended
     source control programs have seen slight delays, other work
     related to  implementing the action plan  (ie; drafting and
     negotiating   contracts)  did  begin   with  the  scheduled
     implementation date.
     Watershed Educators - The "Watershed Educators"
     been renamed  the "Master Watershed" program.
     Watershed"  program   has  begun.    The   first
     volunteers  for  the  program  is estimated  at
     Training  is scheduled to be  completed on this
     by Mid-June.  Additional funding  was sought by
     to WSU-Extension  Service -  Whatcom County  for
     the program beyond the funding allocated through
     Creek project.
program has
The "Master
  round  of
 about  20.
first round
and granted
 continuing
 the Silver
  *  Monitoring - A contract has been drafted for services to be
     performed through  the Institute  for Watershed Studies  at
     Western  Washington  University  for  monitoring  in Silver
     Creek.    The scheduled  date  of first  sampling  has been
     delayed from the  original date stated in  the Silver Creek
     plan.   It is expected that monitoring will begin the first
     part of  June 1991.  The monitoring  program still contains
     the same elements as  those identified in the Silver  Creek
     plan.
                                  A-82
  1203 CORNWALL  #104   BELLINGHAM, WA 98225  676-6974  SCAN 644-6974

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  *  Farm  Inventories  - The  SCS  through  the Whatcom  County
     Conservation  District  has  not  yet  completed  the   farm
     inventories.  This recommended action has been delayed  from
     the  scheduled  date   in  the  Silver  Creek  plan.    The
     inventories, however,  are still  considered to be  part of
     the implementation efforts and will be done during the  time
     line set for Silver Creek implementation efforts.

  *  Health Department Staff -  A temporary position was created
     at the Whatcom  County Health Department  to look at  water
     resource issues  on a county-wide  basis.  The  issues  that
     the staff  person in  this position is  addressing are  the
     same issues identified in the Silver Creek plan.

  *  Educational  Efforts -  Education  efforts are  an on-going
     part of  the Silver  Creek implementation.   A contractor's
     manual developed by the AGC of Washington, which identifies
     best  management  practices, has  been  distributed  to the
     Whatcom County  Building and Codes Department  and the  City
     of Ferndale for distribution to contractor's  when building
     permits are issued.

     Continued   participation  in   the  county   fair  is   an
     opportunity to  disseminate  educational materials  to  the
     community on nonpoint  pollution and water quality  issues.
     This dissemination of information  is a recommended  source
     control program in the Silver Creek plan.

  2.  With  regard to  your  question regarding  the possibility
      that the Council of Governments will develop the watershed
      management plan for Squalicum Creek:

     Projects  undertaken by  the  Council  of  Governments  are
     decided  upon  by  the  Council  of Governments'   Executive
     Board.   The usual procedure for consideration of a project
     is  when a formal request  is made to  the Executive Board.
     As  far as  I  am aware,   there has  not  been an  interest
     expressed by any of  the  jurisdictions within the Squalicum
     Watershed to request the   Council of Governments to develop
     a watershed management plan.

If there are  any further  questions or comments  regarding  the  above
responses,  please give me a call.
S incer
Becky Peterson, Project Manager
attachment
                                 A-83

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CHRISTINE O. GREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190 • 160th Ave S.E. • Bellevue, Washington 98008-5452 • (206) 649-7000


                                 May 17,  1991
      Mr. Jerry Mixon
      Whatcom County Public
      Works Department
      401 Grand Avenue
      Bellingham, WA  98225

           R«:  Bellingham Bay Action Plan

      Dear
      This letter is in follow-up to the October  31,  1990  meeting that
      Michael Jacobson (PTI Environmental  Services) ,  Fran  Solomon
      (Ecology) , and I had with you and John Tyler  regarding actions
      that the Whatcom County Public Works Department is taking to
      reduce pollution in Bellingham Bay.  I have summarized below our
      understanding of the Public Works Department's  actions and have
      asked additional questions.  Please  confirm or  modify the summary
      and address the new questions through a written response.  This
      letter, as well as your response, will be included in the draft
      Bellingham Bay Action Plan scheduled for release this July.
                        i
           Lake Whatcom

           The Development Standards for the Lake Whatcom  watershed
           incorporate elements of the King County  Surface Water Manual
           and the Department of Ecology Stormwater Management Manual.
           Specifically for the Lake Whatcom watershed,  the Standards
           are part of a comprehensive study of the watershed being
           performed by the Bellingham Public Works Department.  The
           Development Standards will include requirements for on-site
           detention, erosion and sediment control, and the treatment
           of stormwater.  What is the status of  the  standards?  Is
           there a separate set of standards that currently apply to
           the rest of the County as veil  as the  City?  Will the
           current standards be revised according to  the Lake Whatcom
           standards, or will the Lake Whatcom standards eventually be
           applied to the entire City and  County?  When will this
           occur?
                                      A-84

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Mr. Jerry Mixon
May 17, 1991
Page 2


     As part of the City of Bellingham study, Whatcom County
     Public Works is also inventorying storm drains and fuel
     tanks within the Whatcom County Watershed.  What is the
     status of these inventories?  What actions will be taken
     based upon the inventories, when and by whom?

     Stormwater Issues

     Regarding the maintenance of stormwater detention ponds for
     new developments, the developer is responsible for
     maintaining the ponds for the first two years and then the
     County assumes responsibility.  The developer must
     compensate the County for the maintenance of the pond.  How
     frequently does the County maintain ponds they are
     responsible for?  How are the removed sediments disposed of?
     Private property owners typically do not maintain their
     drainage systems very well.  What are your thoughts on the
     possibility of applying the pond maintenance scenario to
     private drainage systems?

     To generate funds for stormwater management activities, such
     as those discussed above, a drainage district could be
     formed.  The creation of a drainage district would involve
     public hearings and support by the County council via the
     passing of an ordinance.  What is the status of creating a
     drainage district?

     What requirements are currently in place to address erosion
     and sediment control, detention, stormwater treatment and
     system maintenance?

     For 1991, the County has received a budget increase for the
     maintenance of ditches.   It is expected that 200,000 cubic
     yards of material will be removed over the year.  Will
     funding be available on a continual basis?  How frequently
     will the ditches be cleaned?  How will the removed materials
     be disposed of?  How often are the County's enclosed
     drainage systems maintained?  How are materials removed from
     these systems disposed of?  Is there any testing of the
     materials for toxic substances?

     The County would be willing to participate in a volunteer
     storm drain stencilling project.  This type of project would
     involve the community in helping to reinforce the message
     that storm drains do connect to the surface waters they all
     enjoy.
                                A-85

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Mr. Jerry Mixon
May 17, 1991
Page 3
     Wetlands

     What is being done in the County to address wetlands issues,
     for example: inventorying, mapping, and ordinances to
     provide protection?

     Landfills

     What role does the Public Works Department play in
     landfills?  Who sites them?  What is the status of siting
     new landfills?

     Water Quality

     The City of Bellingham is monitoring streams within the city
     limits on a monthly basis.  Standard water quality
     parameters such as temperature, pH, dissolved oxygen,
     turbidity, and fecal coliforms are being analyzed.   This
     type of sampling will provide invaluable information on the
     quality of water entering Bellingham Bay as-well as provide
     a basis to potentially take corrective actions.  Could a
     monitoring program like this be implemented in the County?
     Would the County consider participating in a monitoring
     program like this if volunteer labor was available?

     The County has requirements for erosion and sediment control
     for all development activities and recently added
     requirements for land clearing operations.  The land
     clearing ordinance includes seasonal restrictions and stiff
     penalties for non-compliance.  Does this apply to the Lake
     Whatcom watershed only, or to the entire City and County?

     What is being done in the County to address the contribution
     of herbicides, pesticides and fertilizers to the degradation
     of surface waters(e.g.public education, reduced use of these
     chemicals or use of alternative environmentally friendly
     products by the City and the City's contractors)?

     What role does the Public Works Department play in
     addressing the contribution of dairy wastes to water quality
     problems?

     Squalicum Creek

     Squalicum Creek has a number two priority, behind Drayton
     Harbor, for the development of a watershed management plan.
     The Whatcom County Council of Governments is developing the
     plan for Drayton Harbor.  Who will be undertaking the
     Squalicum Creek watershed management plan and when?
                              A-8 6

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Mr. Jerry Mixon
May 17, 1991
Page 4

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,


                                          -/
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator

LTP:lp
                               A-87

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                                             Ill
 SCAN PREFIX 769
COUNTY NO. 398-1310
                                                   DEPARTMENT OF PUBLIC WORKS
ADMINISTRATION

 PAUL F. RUSHING
 DIRECTOR
 (206) 676-4692

 Brad A. Bennett. C.P.A.
 Fiscal Manager
 (206) 676-6863

 Mary Chisholm
 Admin. Serv. Mgr.
 (206) 676-6886

 316 Lottie Street
 Bellingham, WA 98225
 FAX (206) 738-2521
May  30, 1991

Lucille T.  Pebles,  Coordinator
Bellingham  Bay Action Program                          Pfpj- Q,
Department  of Ecology
NW Regional Office
3190-160th  Ave. S.E.
Bellevue, WA 98008-5452

Dear Ms. Pebles:
                                                           RECEIVED
                                                                 K tqqt
DIVISIONS

BUILDINGS & CODE

 John R. Tyler
 Deputy Director

 401 Grand Avenue
 Bellingham. WA 98225
 (206) 676-6907
 Inspections (206) 738-2520
 FAX (206) 738-2525



BUILDING MAINT.

 Jerry Gran
 Supt. of Bldgs. A Safety

 Bsmt. Public Safety Bldg.
 Bellingham. WA 98225
 (206) 676-6746
 FAX (206) 738-2521


ENGINEERING

 Edwin R. Menken. P.E.
 County Engineer

 Nasser Mansour. P.E.
 Asst. County Engineer

 Courthouse - 311 Grand Ave.
 Bellingham. WA 98225
 (206) 676*730
 FAX (206) 676-6558


EQUIP. RENTAL & MAINT.

 Warren E. Laing
 Reel Control Manager

 901 West Smith Road
 Bellingham. WA 98226
 (206) 676-6759/384-3221
 FAX (206) 384-5279


FERRIES & DOCKS

 William K. Hawley
 Captain

 316 Lottie Street
 Bellingham. WA 98225
 (206) 676-6692
 FAX (206) 738-2521


MAINT. & OPERATIONS

 Marlen Hansen
 Superintendent

 901 West Smith Road
 Bellingham. WA 98226
 (206) 676-6759/398-3221
 FAX (206) 384-5279


SOLID WASTE

 Robert Jurica. P.E.
 Solid Waste Manager

 Bellingham Medical Center
 1800 C Street. E-15
 Bellingham. WA 98225
 (206) 676-7695
 FAX (206) 738-2521
In  response to  your  letter to Jerry Mixon,  I will attempt to
answer the  questions posed in your letter.

1.    The progress  of our  Stormwater Standard has been delayed
      somewhat as  the disk with the  text of  the  water quality
      plan has been delayed in the Department of  Ecology.

2.    Currently   there    are   separate   standards   regarding
      stormwater treatment, drainage, and design for the City of
      Bellingham and Whatcom County.

3.    It is the County's intent to  adopt the standards currently
      being  prepared for the entire county  as well as areas of
      the city as they apply to the Lake Whatcom Watershed.   The
      City of Bellingham has not yet indicated their intentions
      for adopting  a set of standards.

4.    Depending upon the date of arrival of the  information from
      D.O.E.,  it   is   our  intention   to  have  the  standards
      completed and adopted by September  1991.

5.    The   inventory   for   the   stormwater  drains   and   the
      underground   fuel  storage   tanks  in  the  Lake  Whatcom
      Watershed has been completed.

6.    We intend to adopt an ordinance governing underground fuel
      storage tanks in the watershed area which fall below the
      exempt levels currently  contained  in  state regulations.
      We have followed state guidelines so as to have consistent
      enforcement practices.

7.    The standards will be available to  interested parties by
      late   June.     Actions,   including  enforcement  of   new
      regulations,  will  be in effect July 1st.

8.    Maintenance   of   stormwater   detention  ponds   is  on  an
      infrequent  basis  at present.     Part   of   the  current
      standards makes  provisions for scheduling of maintenance.
      Currently any sediment which is removed from these ponds
      is deposited  in fill sites throughout the county.
                                              A-88

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Bellingham Bay Action Plan / DOE	May 30, 1991

9.    We have not  gotten far enough into maintenance to regulate
     private drainage  systems.   Currently, the  standards  do not
     make provisions for regulating private  systems by agreement
     they  are   maintained  by  the  County two  years  after  the
     development  is  completed.   The  creation of  a county-wide
     drainage district is a matter of discussion in town meetings
     throughout the county.  Whatcom County Public Works supports
     a county-wide drainage district and will  continue to pursue
     establishing the same.

10.  Currently, sedimentation and erosion control, detention ponds,
     stormwater treatment and  systems  maintenance  are  covered in
     the existing County Development Standards and by Chapter 70 of
     the Uniform Building Code as modified by County ordinance.

11.  Funding for  an  increase  in the maintenance of ditches will
     continue on an annual basis provided that the County Council
     approves  the budget.    It is  anticipated that  they  will
     continue to approve these  allocations.  Present plans provide
     for  maintenance of  2,000 miles  of  ditches  on  a 15  year
     cleaning cycle.

12.  Plans for  siting  landfills have  been abandoned due  to  the
     nature of the soils found  in Whatcom  County.   Most proposed
     landfill  sites  contain wetlands.    Therefore, we  have been
     unsuccessful  at  addressing the  problem of  locating  new
     landfill sites.   We feel  that by  conscientious practices of
     recylcling,  composting,   and  incineration  together  with
     developing uses for  the  ash from incineration, our current
     needs can be met for disposal of solid waste without having a
     landfill site.

     I am referring your questions regarding  water quality to our
     new Water Quality Manager, Sue Blake with a request that she
     respond to your concerns.

13.  A program  is  currenly under way in Whatcom County  that  has
     been described as a model program.  We  feel we are a leader
     nationwide in vegetation management.   The County has a full-
     time  person who  oversees  vegetation management  practices
     including herbicide application, noxious  weed control, mowing,
     etc.

     We also have enforcement ordinances limiting the application
     of pesticides and herbicides by the County  which addresses the
     application  of  vegetation management  in several  sensitive
     areas including  the Lake Whatcom Watershed, Lummi Island, and
     several other areas  throughout  the  county  where  citizens
     participate  in  "owner will maintain" agreements.   We have
                                A-89

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Bellingham Bay Action Plan  / DOE	May 30,  1991

     participated on State and Regional Boards in order to maintain
     our status as leaders  in these efforts.

14.  Regarding the  animal  (dairy) waste problem, Whatcom  County
     Public  Works  is  in an advisory  position only.   There  are
     indications  that   through   Soil  Conservation,   Cooperative
     Extension,  and  the dairy farmers  themselves in  cooperation
     with DOE,  that this problem is  being adequately  addressed.
     The County  supports these  actions but we have no  regulatory
     position at this time.

I hope that I have adequately answered your questions.  Please let
me know if I can be of  further assistance.

Sincerely yours,


    JP~h^ K> /yUL^
John R. Tyler   V
Deputy Director Public  Works

JRT:dp
c:\w«fc\10mpeMa.dae
                               A-90

-------
CHRISTINE O. CREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Horthwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5432 • (206)649-7000


                                  May 17, 1991
       Ms. Diane Harper
       Whatcom County Planning
       Department
       401 Grand Street
       Bellingham, WA  98225

            Re:  Bellingham Bay Action Plan
              &/a*jt
       Dear Ms. Harper;

       This letter is in follow-up to the October 9,  1990 meeting that
       Michael Jacobson  (PTI Environmental Services),  Fran Solomon
       (Ecology), and I  had with you and Jerry Mixon regarding actions
       that the Whatcom  County Planning Department is taking to reduce
       pollution in  Bellingham Bay.  I have summarized below pur
       understanding of  the Planning Department's actions and have asked
       additional questions.  Please confirm or modify the summary and
       address the new questions through a written response.  This
       letter, as well as your response, will be included in the draft
       Bellingham Bay Action Plan scheduled for release this July.

            Shoreline Master Plan

            The Whatcom  County Planning Department has completed
            revisions to the Whatcom County Shoreline Master Plan.  The
            revisions addressed issues including sitting moorage and
            community docks, increasing public access, increasing
            drainage provisions, and determining approaches to modify
            development  setbacks.  The Plan was scheduled to go before
            the County Council in December of 1990.  What is the status
            of adoption  and Implementation of the plan?  Why vas the
            plan revised?

            Wetlands

            The County has performed a wetlands inventory through an
            aerial photo survey.  An independent community group is
            developing an ordinance to protect these sensitive areas.
            This group will submit the proposed ordinance to the County
            Council.
                                      A-91

-------
Ms. Diane Harper
May 17, 1991
Page 2


     If the council agrees to develop such an ordinance, the
     Planning Department would set up a committee to examine the
     proposed ordinance.  The planning commission would then send
     any approved ordinance to the County Council for final
     approval.  What is the status of the sensitive areas
     ordinance?

     Nooksack River

     The Planning Department, in conjunction with the Lummi Tribe
     as the lead agency, applied for Centennial Clean Water Funds
     (CCWF) to perform a study of the Nooksack River.  The study
     would establish baseline data on the river and access
     impacts from logging and agricultural practices.  The
     information gathered on the Nooksack would be placed on a
     CIS computer system.  This application was not accepted.
     Will another attempt be made to obtain CCWF monies, or other
     monies, to perform this study?

     Water and Sewer Plan

     The County is developing a water and sewer plan as part of
     their comprehensive land use plan.  The water and sewer plan
     will address both groundwater and surface water protection.
     Issues to be covered in the plan include jurisdictional
     conflicts over regulatory authority; water rights for the
     Nooksack River and county groundwater supplies; and water
     quality impacts from logging, agriculture, development, and
     waste disposal.  As part of the plan, a Nooksack groundwater
     study will evaluate the pattern of groundwater and surface
     water interchange.   What is the status of these efforts?
     How are the Issues above addressed in the plan?  Will the
     Nooksack basin study also access water quality?

     Development Standards

     The Whatcom County Public Works Department has created
     development standards for the Lake Whatcom watershed.  What
     ordinances might be developed to implement these standards?
     will they eventually apply to the entire City and County?
     If so, when?  What requirements are currently in place
     regarding erosion and sediment control, stormwater
     treatment(e.g. oil/water separators and grassy swales),
     detention, and system maintenance?

     Water Resource Issues

     The County has requested that Public Utility District #1
     become the water resource lead agency and be the lead
     coordinator for nonpoint pollution issues.
                                 A-92

-------
Ms. Diane Harper
May 17, 1991
Page 3


     The county commissioners are pursuing this approach.  What
     is the status of this effort?  What specifically would be
     their responsibility?  If this does not occur, who will be
     actively addressing water resource issues in the County?

     Sewage Disposal

     The State Department of Health has revised their On-Site
     Sewage System Regulations (Chapter 248-96 WAC).  Is Whatcom
     County adopting ordinances to implement the State
     regulations?

     The County has loan funds available for improvements to
     septic systems for qualifying home owners.  Are these loan
     funds frequently applied for?

     It is difficult for the County to pursue enforcement on
     septic tank violations because it must go through the
     prosecuting attorney.  There is a need to create a civil
     penalty to avoid the court system.  What actions are being
     taken to move in this direction?

     Squalicum Creek

     Under the County's prioritization of watershed management
     plans Squalicum Creek ranked number two, behind Drayton
     Harbor, to receive a watershed management plan.  Due to the
     fact that the bulk of this watershed falls within the
     jurisdiction of the City of Bellingham, the City would
     probably be the lead agency in the development of a
     watershed management plan.  Are you aware of any interest by
     the City or any other agency in developing a watershed
     management plan for Squalicum Creek?  The Whatcom County
     Council of Governments developed the Silver Creek Watershed
     Management Plan and is working on the Drayton Harbor Plan.
     Could the Council of Governments be a potential candidate to
     develop the Squalicum Creek plan?

     Clearing Permit

     A Washington Department of Natural Resources Forest
     Practices Permit is not required if a clearing operation
     results in less than 5000 board-feet of timber, or if the
     timber quantity is greater than 5000 board-feet and is not
     being sold.  The county now requires developers to obtain a
     clearing permit for both of these situations to prevent
     large stands of trees from being totally cleared and
     destroyed.  The clearing permit is required under amendments
     to the Whatcom County Development Standards.
                                A-93

-------
Ms. Diane Harper
May 17, 1991
Page 4


     The amendments also address buffers for streams, lakes, and
     wetlands, as well as perimeter buffers.  Violation of the
     ordinance is considered a civil offense and carries a
     penalty of 1000 dollars per day.  Has the ordinance been
     generally adhered to by developers?

     Landfills

     What role does the Planning Department play in siting new
     landfills?  Are any new sites currently being considered?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles,  P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                              A-94

-------
                   whh rluM CO. MŁHL i n
                                                          !NG: Ł06-676-7646
                                                    aSS6
WMATCOM COUNTY HEALTH DEPARTMENT

   Community Health Center - 509 Girard Street
              P.O. Box 995
        Belllngham, Washington 88227
       SCAN 738-2167 FAX 676-7846

          FRANK E. JAMES M.O.

          LuciDe*T. PeBles, P.E.
          Bellingham Bay Action Program Coordinator
          Department of Ecology
          Northwest Regional Office
          3190 160th Ave N.E.
          Bellevue, WA 98008-5452

                Re:    Bellingham Bay Action Plan

          Dear Ms. Pebles:

          The purpose of this letter is to respond to questions which you asked in your letter to Diane
          Harper on May 17,  1991.  Diane requested my assistance with two questions; the first
          related to sewage disposal and the second related to Squalicum Creek.
                I discussed  the  questions  which  you raised with  Bert Brainard, director of
                Environmental Health. Because you have sent a list of similar questions to  him
                which he is in the process of answering, I will defer to his responses in relation to
                your questions in this area.

                Squalicum Creek:
                I have discussed your questions regarding Squalicum Creek with personnel in the City
                of Bellingham and the Council of Government.  There are a number of programs
                related  to  the Creek being  carried out by the City of Bellingham.  There is not
                however, any action underway to develop a watershed management plan  for the
                Creek.  Becky Peterson at the Council of Government (COG) indicated the City of
                BeUingbam or Whatcom County would have to formally request assistance from the
                COG if they were to become involved in developing a management plan.

          If I can be of additional assistance please do not hesitate to contact me. I look forward to
          reviewing the draft Bellingham Bay Action Plan  which you indicated would be scheduled
          for release in July.

                                                             Sincerely,
                                                             Sue Blake
                                                             Water Resource Protection Manager
  AtfminMrMlve     Environmental
  Phon* 6784720
  County 384-1628
Phono 6784724
County 384-1665
AIDS Education
4 Tooting Contw
Phono 676-4593
County 384-5848
Immunliabon CNnle

  Phono 738-2508
 County 384-1338

       A-95
Phono 738-2503
Well Child Clinic

Phorw 738-2522
County 384-0674
  WIC Clinic

Phon* 738-250$
County 364.1633

-------
CHRISTINE O. CRECOIRE
     Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May  17, 1991
       Mr.  Bert Brainard
       Whatcom County Health
       Department
       509  Grand Street
       Bellingham,  WA  98227

             Re:  Bellingham Action Plan
               &*ir
       Dear Mr. Brainard!

       This letter is in follow-up to the October 9, 1990 meeting that
       Michael Jacobson (PTI Environmental Services), Fran Solomon
        (Ecology), and I had with you, Dave Bader and Paul Chudek,
       regarding actions that the Whatcom County Health Department is
       taking to reduce pollution in Bellingham Bay.  I have summarized
       below our understanding of the Health Department's actions and
       have asked additional questions.  Please confirm or modify the
       summary and address the new questions through a written response.
       This letter, as well as your response, will be included in the
       draft Bellingham Bay Action Plan scheduled for release this July.
                         «
             On-site Sewage Disposal

             In January of 1990, the Whatcom County Health Department
             began the Lake Whatcom Watershed Sewage Disposal Survey.
             The survey was conducted in response to the identification
             of on-site sewage disposal as an area of concern by the Lake
             Whatcom Management Plan.  A final report of the survey was
             completed in July 1990 and indicates an eight percent
             overall failure rate of on-site sewage systems within the
             Lake Whatcom watershed.

             The Survey has a number of recommendations addressing areas
             having the highest failure rates:

             1)    More intensive survey of older seasonal residences
                  during recreational season.  Inadequate systems should
                  then be upgraded to conform as closely as possible to
                  current standards.

             2)    Consideration of extension of public sewer service into
                  the Academy Street, Haggin Street and Toad Lake Road
                  areas.
                                      A-96

-------
Mr. Bert Brainard
May 17, 1991
Page 2

     3)   Public education program to encourage proper septic
          system maintenance.  Mail brochures describing septic
          system functioning, care and proper maintenance to all
          watershed residences having on-site sewage disposal
          systems.  Place all such residences onto a computer
          database and send septic tank pumping reminder notices
          to them every three to five years.

     4)   Perform an on-site sewage disposal survey within the
          watershed, a minimum of once every five years.

     Also within the Lake Whatcom watershed, the County has
     strict requirements concerning vertical separation and
     drainfield slope for new septic systems.

     Regarding recommendation #3 of the survey, there was some
     discussion in our meeting about a 1/2 cent per gallon
     septage fee being levied for discharges to the Post Point
     Wastewater Treatment Plant and that these funds
     ($18,000?)would be used for the education program.  What is
     the status of the septage fee plan and of the education
     program itself?  If you have not yet developed the brochure,
     the Whatcom County Conservation District has a reprint of a
     pamphlet titled "Know Your Septic System" which may be of
     some use to you.  Is the $18,000 figure a cap, that when
     attained the fee will no longer be charged?

     What is the schedule for implemention of recommendations 1,
     2 and 4 of the Lake Whatcom Watershed On-site Sewage
     Disposal Survey?  Regarding recommendation #1, please define
     recreational season.

     What are the County's requirements concerning vertical
     separation and drainfield slope for new septic systems
     within the Lake Whatcom watershed and outside of it?  Do
     they equal or exceed the Washington Department of Health's
     On-Site Sewage System Regulations?

     County-wide, to ensure that all new septic tanks are
     installed properly, the Health Department has a
     comprehensive training program for all new inspectors.
     Please describe the comprehensive training.

     Are you aware of any failing septic system problems in the
     portion of the County that is adjacent to Bellingham Bay or
     in any other areas of the County that are within the
     Bellingham Bay watershed?  What actions are being taken to
     address these problem areas?
                               A-97

-------
Mr. Bert Brainard
May 17, 1991
Page 3


     Household Hazardous Waste and Recycling

     The Whatcom County Health Department, in conjunction with
     Whatcom County and City of Bellingham Public Works
     Departments, operates a permanent household hazardous waste
     drop-off site, as well as publishes a useful household
     hazardous waste chart/pamphlet.  How is this pamphlet made
     available to the public?  Regarding the suggestion for
     disposal of antifreeze in the chart; isn't it accepted at
     the City/County drop-off site for recycling?  How frequently
     is the chart updated?

     The County also publishes an informative resource guide to
     recycling called "Whatcom County Recycles".

     How is this guide made available to the public?

     Whatcom County and the City of Bellingham have completed
     management plans for household hazardous wastes and moderate
     risk wastes.  Will the City be involved in-preparing
     educational brochures on the program and the County involved
     in the screening and collection of wastes?  What is the
     schedule for implementation of the activities outlined in
     the plan?

     Shellfish Issues
                 i
     If it was determined that the harvesting of shellfish was a
     threat to public health, the County would notify the public
     through various media: radio, newspaper, posting of signs at
     recreational shellfish areas, development of a poster for
     placement at fishing stores, marinas, and other similar
     businesses, and/or development of a brochure.  Would the
     County or the State Department of Health post signs at
     recreational shellfish areas?  This issue is part of the
     memorandum of agreement (HOA) that is being drawn up between
     the County and the State.  What is the status of the MOA?
     If it has been completed, how are the responsibilities
     defined?

     The State Department of Health's Recreational Water Quality
     Study indicated high fecal coliform counts in their May 1990
     sampling of a few stations near Chuckanut Village.  Also,
     data from the City of Bellingham's 1990 stream monitoring
     program shows some stations with high fecal coliforms.
                               A-98

-------
Mr. Bert Brainard
May 17, 1991
Page 4

     Who is responsible for investigating the cause of these high
     counts and taking corrective actions?  Does the County
     Health Department do the actual lab work for the City's
     stream monitoring program?

     Landfills

     There are over 20 closed landfills in Whatcom County-  In
     accordance with Department of Ecology regulations, landfills
     that have been closed since 1985 are adhering to
     implementation schedules and have groundwater monitoring
     systems in place.  Active landfills have groundwater
     monitoring and are required to have approved closure and
     post closure plans.  All facilities are monitored quarterly.
     Please state the facilities that are closed, but are being
     monitored, and the active facilities.  Has the data
     collected from these sites indicated ground or surface water
     contamination?  If it has, what actions were or will be
     taken?  Do all of the active facilities have approved
     closure and post closure plans, which meet the requirements
     of Chapter 173-304 WAC?  If not, what is the status of
     developing plans that meet the regulatory requirements?

     The following two landfills have been brought to my
     attention, please tell me what you know about them (e.g.
     what was disposed of, how large the site was, when materials
     were disposed of and who the current property owner is) :
     1178 Marine Drive and Georgia Pacific landfill on Y Road.

     Are any new landfill sites are being considered?

     Dairy Wastes

     Whatcom County contains a high density of dairies, which can
     potentially have a greater impact on water quality than
     failing septic tanks.  What plans does the Health Department
     have to assess this impact and to take mitigative actions?
     What is the Health Department's role in the dairy waste
     issue?

     Personnel

     The Department of Health has hired a water resource manager.
     Her duty will be to develop a water resource plan for
     Whatcom County by the spring of 1992.  The plan will focus
     on potable water supplies.
                               A-99

-------
Mr. Bert Brainard
May 17, 1991
Page 5

     The Silver Creek Watershed Management Plan recommended that
     the Health Department add staff to allow an increase in time
     spent on water quality related programs, "such as addressing
     on-site sewage disposal problems and developing and
     coordinating special field surveys."  Will the new water
     resource manager be undertaking these efforts as well?  Will
     she be undertaking any other water quality related projects?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272
(SCAN 354).  Please have your response letter to me by Friday,
May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                               A-100

-------
WHATCOM COUNTY HEALTH DEPARTMENT

   Community Health Center - 509 Girard Street
              P.O. Box 935
        Bellingham, Washington 98227
       SCAN 738-2167 FAX 676-7646

          FRANK E. JAMES M.D.
              Health Officer
          May 30, 1991
UJ
                             OEPT. OF
          Lucille T. Pebles, P.E.
          Department of Ecology
          3190 - 160th Avenue SE
          Bellevue, Washington  98008-5452

          Dear Ms. Pebles:

          This is in response to questions in your letter dated May 17,1991, regarding the Bellingham
          Action Plan.

          On-site Sewage Disposal

          The City of Bellingham is currently charging 1/2 cent per gallon of septage deposited at the
          sewage treatment plant,  this money is dedicated to a septic  tank system maintenance
          educational program.   There  is no cap on the total amount collected each year.  The
          estimated amount to be collected in 1991 is about $18,000.00.

          All dwellings with failing on-site sewage systems found during the Lake Whatcom Survey
          have been resurveyed and the necessary repairs made so that all are in compliance with the
          sewage control regulations.  No time table has been set for public sewer installation or
          future on-site sewage system survey work. Recreational season means the period of the year
          from June through August.

          In the Lake Whatcom Watershed, septic tank drainfields are required to have a vertical
          separation of at least four feet  and be located where the slope is not greater than 15
          percent.  Outside  the Lake Whatcom Watershed, a vertical separation of two  feet is
          required.  These requirements equal or exceed the State requirements.   The training
          program for new inspectors is on-the-job and occasional attendance  at workshops and
          seminars.

          There are some  problem areas of failing septic tank systems within the Bellingham Bay
          Watershed, however no action is being taken to survey these areas because of a lack of
          funding.
         Household Hazardous Waste and Recycling
         The Household Hazardous Waste pamphlet is available upon request. The chart is updated
 Administrative     Environmental     AIDS Education  Immunization Clinic
   & Nursing         Health        & Testing Canter
 Phone 676-6720    Phone 676-6724    Phone 676-4593    Phone 738-2508
 County 384-1528    County 384-1565    County 384-5848    County 384-1336
                                                  A-101
                   Communicable
                  Disease Hotline:
                  Phone 738-2503
Well Child Clinic

Phone 738-2522
County 384-0574
  WIC Clinic

Phone 738-2505
County 384-1633

-------
Lucille Pebles, P.E.
Page Two
May 30, 1991



yearly. Currently in the moderate risk waste program, the Health Department does the
screening, Whatcom County Solid Waste  Division  does  education and the City of
Bellingham operates the facility.

Shellfish

There is no MOA between the local health department and the state health department.
High fecal counts hi Bellingham Bay and adjacent streams would be the responsibility of the
health department, if the cause was thought to be failing septic tank systems.  The City of
Bellingham does their own laboratory work.

Landfills

The only closed landfill that has a water monitoring program is Cedarville. This site has
shown some ground water contaminants, probably originating from a landfill closed prior
to 1985. Active landfills being monitored are Recomp, Olivine, Intalco and Georgia Pacific.
As to the two specific landfills brought to your attention located on Marine Drive and 'Ą'
Road, we do not have  any information on them a they were closed before an operating
permit was required.  All landfills under permit have closure plans.

Dairy Waste

We do not have a role in the dairy waste issue.  We understand that the Department of
Ecology is planning on  requiring all dairies to have waste  discharge permits.

Personnel

The Water Resource Manager was hired by the Whatcom County  Executive and is  not a
staff member of the Environmental Health Section. We cannot comment on her activities.
Sincerely,
Bert Brainard, M.P.H.
Environmental Health Director

BB:dmi
                                       A-102

-------
CHRISTINE O. CRECOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May  17, 1991
       Mr. Don Ellis, P.E.
       Port of Bellingham
       P.O. Box 1737
       Bellingham, WA   98227

            Rax  Bellinghaa Bay Action Plan
       Dear **Ł. TF1 1 i °*

       This letter is  in follow-up to the October 24,  1990 meeting that
       Michael Jacobson (PTI  Environmental Services) ,  Fran Solomon
       (Ecology) ,  and  I had with you and Bill Hagar regarding actions
       that the Port of Bellingham is taking to reduce 'pollution in
       Bellingham  Bay.   I have summarized below our understanding of the
       Port's actions  and have asked additional questions.  Please
       confirm or  modify the  summary and address the new questions
       through a written response.  This letter, as well as your
       response, will  be included in the draft Bellingham Bay Action
       Plan scheduled  for release this July.

            Boater Education

            The Port currently publishes a bi-monthly newspaper entitled
            "Port  Report".  An upcoming issue will contain the results
            of Washington's 1988 Recreational Boater Survey, which
            includes information on the types of waste disposal
            equipment  and practices used aboard boats, and the
            facilities and programs that are needed to control boat
            wastes. A  future  issue of the "Port Report" will also
            include information on boater: sewage, used oil and
            maintenance wastes,  litter and plastic debris, and safety
            and education.  The Port remains open to featuring
            environmentally oriented educational information in future
            issues as  well.   In which issues will the above information
            appear? Please send me a copy of each of these issues.

            Port of Bellingham Properties-General

            The Port will be  working with their lease holders to
            minimize the potential contamination of their properties.
                                     A-103

-------
Mr. Don Ellis, P.E.
May 17, 1991
Page 2


     Beginning in 1991, the Port will use a combination of
     education, questionnaires, and field investigations to
     encourage tenants to employ business practices which will
     keep pollutants out of surface and ground waters.  As part
     of the education element, applicable environmental
     regulations will be distributed to the tenants.  What is
     your schedule for accomplishing this effort?  Will you hold
     discussions with tenants to help them understand how the
     regulations apply to them?  Do you plan on strengthening
     future leases to place some liability for contamination on
     to the tenant?

     Please send me a listing and/or a map of Port properties and
     lease holders.

     I am aware that the Coastal Zone Management Act was reviewed
     in December of 1990.  Did you gain control of any Department
     of Natural Resources lands as a result of the review?  If
     so, are any of the properties contaminated and what actions
     will the Port take to clean them up?

     Are the storm drain systems on Port properties owned and
     maintained by the Port?  Non-point pollution from storm
     drains is a significant contributor to the degradation of
     surface waters.  Therefore, system maintenance is very
     important.  How frequently are the Port's systems cleaned?
     How is the removed material disposed of?  What are the
     Port's thoughts on stencilling storm drains on Port
     properties?

     I am aware that the Bellingham Parks and Recreation
     Department has prepared a draft site management plan for
     Little Squalicum Park.  The plan calls for, "maintaining the
     majority of the site east of Marine Drive bridge in a
     natural state, while improving the west meadow portion of
     the site west of the Marine Drive bridge for more intense
     human uses involving more traditional park improvements."
     What are the Port's thoughts on this plan?

     What are the Port's plans for future marinas in Bellingham
     Bay?  Where might they be located?
                                A-104

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Mr. Don Ellis, P.E.
May 17, 1991
Page 3
     Whatcom Waterway

     In September of 1990, the Port sampled sediments in Whatcom
     Waterway, I & J Waterway, and Squalicum Harbor.  The purpose
     of the sampling was to determine if materials dredged from
     these areas could be disposed of in deep water at a
     designated Puget Sound Dredged Disposal and Analysis (PSDDA)
     site.  Whatcom Waterway samples contained concentrations of
     chemical contaminants which could prohibit deep water
     disposal if the associated biological analyses do not meet
     PSDDA requirements.  What is the status of the biological
     analyses?  Please send me a copy of these results.  If deep
     water disposal requirements are not met, will uplands
     disposal be considered?  When would dredging begin?  What is
     the status of dredging I & J and Squalicum Waterways?

     Alaska Ferrv Terminal
     What types of monitoring will occur at the Alaska Ferry
     Terminal?  When, where and how often?  Please send me a copy
     of the monitoring results.

     Repair Grids

     The Port of Bellingham has boat repair grids at Squalicum
     Harbor which potentially have an adverse effect on water
     quality.  Does the Port have other repair grids?   What
     actions will the Port take to mitigate the environmental
     problems associated with them?  Will sampling occur at these
     locations in conjunction with the Alaska Ferry Terminal
     sampling?

     4th and Harris Property

     This site was used for storage of diesel fuel tanks and has
     contaminated soils.  The Port has contracted for its
     cleanup, and work should begin soon.  What is the status of
     the cleanup?

     Tollycraft

     The Tollycraft site is listed as a suspected contaminated
     site and is in non-compliance with the Washington State
     Dangerous Waste Regulations and the Federal Land Disposal
     Restrictions.  What actions have been or will be taken to
     address these issues?
                               A-105

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Mr. Don Ellis, P.E.
May 17, 1991
Page 4


     Recycling

     The Port operates collection facilities at Squalicum Marina
     for cardboard, aluminum, scrap metal and wood, plastics and
     boat garbage, nets and waste oil.  Plastics and boat garbage
     are not currently being recycled.  Some plastics can now be
     recycled; would the Port consider plastics collection and
     recycling?

     The Squalicum Harbor collection program was initially
     developed in conjunction with Sea Grant.  Another product of
     this venture was an educational brochure which addresses the
     marine waste problem, efforts to solve it, and what
     individuals can do.  The brochure also contains a map
     showing the various waste disposal sites.  How is this
     brochure made available to the public?  Could it be included
     in the Port's billings or in the Port Report?

     Development Standards

     The Port would like to create Development Standards for
     their properties.  What requirements do you currently have
     for erosion and sediment control, detention and stormwater
     treatment?  What is the status of the Port's proposed
     Development Standards?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your cooperation in this process and look forward to
your reply.

                              Sincerely,
                              Lucille T. Pebles, P.E,
                              Bellingham Bay Action
                              Program Coordinator
LTP:lp
                                 A-106

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                             B
                PORT OF BELLINGHAM
May 28, 1991
Bellingham Bay Action  Coordinator              uifcM
Washington State Dept.  of  Ecology              ™^
Lucille Pebles, P.E.                            **'      *QQ\

                                                           ^
Northwest Regional  Office                          p-r Q? tt0
3190 160th Ave. S.E.                             °tV
Bellevue, Wa.   98008-5452


Re: Correspondence  Dated 5/17/91


Dear Ms. Pebles,

The following  responses are offered in the same order as
questions raised  in your letter referenced above.

1.   The issue of the  Port Report which has the boater
     information  has been  mailed to you under separate cover.

2.   Although  discussions  have occurred with tenants on an ad hoc
     basis,  the  overall environmental program has been delayed
     until later  this  year.  Our standard lease language reacted
     to contamination  liability is attached.

3.   A directory  of Port of Bellingham properties and tenants is
     enclosed.

4.   A new management  agreement with DNR has not been finalized.
     If any  new properties are secured and any are contaminated
     the Port  would expect the previous responsible party to
     clean it  up.

5.   Some storm drains are owned and maintained by the Port of
     Bellingham;  others are owned by the City of Bellingham
     and/or  other third parties. For Port owned facilities, catch
     basins  are cleaned annually or more often if needed. The
     Port does not  have any objection to some other agency
     stenciling our storm  drains.

6.   Part of the  Little Squalicum Park plans relate to Port owned
     property.  Any  surplusing of the property would have to be
     through the  Port  Commissioners. They have not been asked nor
     have taken any such action in regard to that proposal. Port
     staff has concerns relative to how existing and proposed
     businesses would  be impacted.
                                 A- 107

                           COMMISSIONERS
               EDWARD GRIEMSMANN KENNETH McAULAY PETER ZUANICH
                        ADMINISTRATIVE OFFICES
             625 Cornwall Avenue/P.O. Box 1737/Bellingham, Washington 98227-1737
                  (206) 676-2500/County 398-2600/FAX 206-671-6411

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7.   Because of the high demand for moorage,  the Port is always
     trying to assess future marina possibilities. There are
     about 150 more slips possible but not yet constructed
     within Squalicum Harbor. A small marina in Fairhaven is
     a possibility- A committee of citizens is being formed to
     review that location.

8.   A sample by "Chrysler Pete's" failed. The results should
     be available through the State's Site Hazard Assessment of
     the waterway.  All alternatives for disposal will be
     considered. Dredging for the areas of the I & J and
     Squalicum waterways which are suitable for deep water
     disposal will begin about September with the bid call going
     out in late May or June.

9.   No sediment testing near the Alaska Ferry is contemplated
     unless the quarterly soundings show substantial displacement
     of sediment previously tested. The next sounding will take
     place about July.

10.  There is only the repair grid at Squalicum Harbor. We are
     taking sediment samples at that location.

11.  The diversion to the sewer treatment plant of the seepage
     at the northwest corner of the site will occur shortly.
     However, on-site excavation work has revealed the presence
     of a pocket of bunker "c" oil. A new plan is being
     formulated in response to the discovery.

12.  Dane Armstrong is the lessee of the Tolley-Craft site and
     the letters from the Dept. of Ecology were directed toward
     him. It is my understanding that he has responded and the
     Port has heard nothing further from either Mr. Armstrong or
     Ecology on the matter.


I hope this adequately responds to your letter. If you have any
further questions please do not hesitate to contact me.
   W.
Director of Operations
                                 A-108

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      5.3   LIENS: Lessee agrees to keep the property described herein free and
clear of all liens and charges whatsoever.

      5.4   INDEMNIFICATION AND HOLD HARMLESS:  The Lessee agrees that
it will protect, save,  defend, hold harmless and indemnify the Lessor, its officers,
employees and agents from any and all demands, claims, judgments, or liability for
loss or damage arising as a result of accidents, injuries, or other occurrences,
occasioned by either the negligent or willful conduct of the Lessee, its agents or any
person or entity holding under the Lessee or any person or entity on the leasehold
as a result of Lessee's activity regardless of who the injured party may be.

      5.4.1  Lessee shall indemnify and hold Lessor harmless from any and all
claims, demands, judgments, orders, or damages resulting from hazardous
substances on the leasehold caused in whole or in part by the activity of the Lessee,
its agents, subtenants,  or any other person or entity on the leasehold during any
period of time that Lessee has occupied all or a portion of the leasehold during the
term of the lease.  It is the intent of the parties that Lessee shall be responsible and
shall hold Lessor  harmless from any hazardous substances that have or may occur
on the leasehold since Lessee first occupied the leasehold through this  lease or any
previous lease with  Lessee. The term "hazardous substances", as used herein, shall
mean any substance heretofore  or hereafter designated as hazardous under the
Resource Conservation and Recovery Act, 42 U.S.C.  Sec 6901 et seq.: the Federal
Water Pollution Control Act, 33 U.S.C. Sec. 1257 et sea.: the Clean Air Act, 42 U.S.C.
Sec. 2001 et sea.: the Comprehensive Environmental Response  Compensation and
Liability Act of 1980, 42 U.S.C. Sec. 9601 et seq.: or the Hazardous Waste Cleanup-
Model Toxic Control Act, RCW 70.105D all as amended and subject to all regulations
promulgated thereunder.

      5.5   LAWS AND REGULATIONS:  Lessee agrees to conform to and abide
by all lawful rules, codes, laws and regulations in connection with his use of said
premises and the construction of improvements and operation of Lessee's business
thereon  and not to permit said premises  to be used in violation of any lawful rule,
code, law, regulation or other  authority.

      5.5.1  The Lessee's obligations herein shall include, but in no way be limited
to, the obligation to comply with all State and Federal environmental laws and
regulations. The Lessee covenants and agrees that it will indemnify and  hold
harmless the Lessor from any fine, penalty, or damage which may be imposed by
any lawful authority, which may arise as a result of the Lessee's failure to comply
with the obligations  of this paragraph.
                                          A-109

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CHRISTINE O.GRECOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May  17, 1991
       Mr. Ed Melvin
       Sea Grant
       19 Harbor Mall
       Bellingham, WA   98225

            Re:  Bellingham Bay Action Plan

       Dear jtcu- Melvin;

       This letter is  in follow-up to the October 24,  1990 meeting that
       Michael  Jacobson (PTI  Environmental Services),  Jacques Faigenblum
       (Environmental  Protection Agency), Fran Solomon (Ecology), and I
       had with you regarding actions that Sea Grant is taking to reduce
       pollution in Bellingham Bay.  I have summarized 'below our
       understanding of the Sea Grant's actions and have asked
       additional questions.   Please confirm or modify the summary and
       address  the new questions through a written response.  This
       letter,  as well as your response,  will be included in the draft
       Bellingham Bay  Action  Plan scheduled for release this July.

            North Pucret Sound Marine Sanctuary

            The National Oceanic and Atmospheric Administration (NOAA)
            is  considering designating north Puget Sound as a marine
            sanctuary.   The boundaries of the sanctuary could
            potentially extend from Cape Flattery to the Canadian
            border, including Bellingham Bay.  Sea Grant will be
            involved to educate the marine fisheries user group as to
            how this designation would affect them and how to deal with
            the process.   What is the status of this designation?  How
            would it protect  water quality and fish resources in
            Bellingham Bay?

            Education/Technical Assistance

            Sea Grant  is willing to participate in educational efforts
            designed to improve water quality in Bellingham Bay, through
            involvement in planning and perhaps leading one or two
            activities.

            In  addition,  Sea  Grant is willing to provide technical
            assistance through their various resources across the
            country.
                                        A-110

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Mr. Ed Melvin
May 17, 1991
Page 2

     Waste Reduction and Recycling

     Sea Grant worked with the Port of Bellingham to develop
     improved waste collection facilities at Squalicum Harbor.
     Currently facilities exist for the collection of: plastics
     and boat garbage, cardboard, aluminum, scrap wood and metal,
     nets waste oil, sewage, and hazardous materials.  Cardboard,
     aluminum and scrap wood and metal are recycled.

     This venture also resulted in the creation of an educational
     brochure which addresses: the marine waste problem, efforts
     to solve the problem and what individuals can do.  The
     brochure also contains a map showing the various waste
     disposal sites at Squalicum Harbor.

     How is the brochure distributed?  Are there plans to reprint
     this document?

     Water Quality

     Are there any other activities which Sea Grant is involved
     in that pertain to improving water quality in Bellingham
     Bay?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the dra,ft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP:lp
                                A-111

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                    Washington Sea Grant
                    Marine Advisory Program
                    19 Harbor Mall                               (206) 676-6429
                    Bellingham, WA 98225                          SCAN 522-6429

June 5, 1991

Lucille T. Pebles
Department of Ecology
Northwest Regional Office
3190 160thAve.S.E.
Bellevue, WA 98008-5452

Dear Ms. Pebles:

      This letter is in response to your letter of May 17,1991 requesting my
comments of your summary of our meeting in October, 1990 on Sea Grant
activities that reduce pollution in Bellingham Bay. It is my understanding
that this information will be incorporated into the Bellingham Bay Action
Plan.  I will  address the specific questions you pose in your letter as well as
the summary. As we discussed I will not address your questions regarding
the proposed National Marine Sanctuary in North Sound since that
information is available within the Department of Ecology as lead state
agency for the project.

      Washington Sea Grant is committed to improving the water quality of
Puget Sound including Bellingham Bay. The North Sound office of
Washington Sea Grant has limited programmatic resources and works with a
wide variety of marine users and issues in Whatcom, Skagit, Island, San
Juan, and  north Snohomish Counties. Sea Grant is interested in participating
in planning educational efforts to improve water quality hi Bellingham Bay
to the extent that our programmatic resources allow, and may participate in
actual education events depending on the priorities that emerge from the
Action Plan  process, available resources, and existing programmatic
commitments. Access to the national network of Sea Grant institutions and
their resources may be of value to the Action Plan process.

      Washington Sea Grant does not have programs hi place that address
specifically water quality in Bellingham Bay  at this time. As you point out in
your letter, Sea Grant lead the establishment of collection and recycling
facilities in Squalicum Harbor and published three educational brochures on
problems with marine debris and how recreational boaters and commercial
fishermen can help address this serious problem. These brochures are
available for $ 0.50 each through this office and Washington Sea Grants main
                                 RECEIVED
         A cooperative project of Bellingham Vo-TecrJyHjU sfjti OJriversity of Washington

                                   OEPT. OF ECOLOGY
                                   A-112

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office in Seattle on the University of Washington campus. Sea Grant is
currently considering reprinting these publications, but no decision has been
made thus far.  This project certainly  addresses water quality in Bellingham
Bay, but the impacts of this program are likely to be broader and include
Puget Sound in general.  I have enclosed copies of the three marine debris
brochures I have mentioned for your  information.

      I hope that my comments are useful to you in your preparation of the
Bellingham Bay Action Plan. If I can be of further assistance please contact
me.

                             Sincerely,
                             Edward F. Melvin
                             North Sound Field Agent
cc: M. Spranger
                                    A-113

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CHRISTINE O. CRECOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000

                                  May 24, 1991
       TO:       citizen Work Group Member
       FROM:     Lucille T. Pebles, NWRC. .
                 Bellingham Bay Action Program Coordinator

       SUBJECT:  Bellingham Bay Action Plan


       This memo is in follow-up to the October  24,  1990 meeting that
       Michael Jacobson (PTI Environmental Services), Jo Harrison (Senior
       Environmental Corps volunteer), Fran Solomon  (Ecology),  and I  had
       with you  regarding actions  that  the citizens of  Bellingham  are
       taking to reduce pollution  in Bellingham Bay.   I have  summarized
       below our understanding of your actions and have asked  additional
       questions.  Please  confirm  or modify the summary and address  the
       new questions through  a written  response.  This memo,  as well as
       your response, will be included in the draft Bellingham Bay Action
       Plan scheduled for release this July.

            Concerned Southside Citizens

            Concerned Southside Citizens  (CSC) have been actively involved
            in  shoreline  development issues  in the  southern  area  of
            Bellingham Bay.   As  a result of their  efforts, the  Port of
            Bellingham will be taking quarterly soundings  at  the Alaska
            Ferry Terminal to track  scouring.   In  addition,  they have
            taken actions  to  ensure that the  cleanup of a contaminated
            site at  4th and  Harris proceeds  in a timely  manner.   CSC
            continue to  closely  track shoreline development  impacts to
            Bellingham Bay.  What other activities are  the  CSC currently
            involved in?

            CSC also  has been involved  in a  Padden Lagoon  enhancement
            project.   How  does this work mesh with the Bellingham Parks
            and Recreation Departments  habitat enhancement  and  public
            access project for Padden Creek?

            North Cascades Audubon Society

            The North  Cascades Audubon  Society (NCAS) is involved in
            monitoring bird populations  in Bellingham Bay to establish
            baseline information.   They  also have formed  a conservation
            committee to respond  to oil spills  and rescue oiled birds.
                                          A-114

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What types of birds are monitored, how frequently, and where?

The NCAS  has applied for  Public Involvement  and Education
funds on two occasions, but was not awarded any monies.  What
were these funds  to be  used  for?  Will you  apply for these
funds again?

Puget Sounders

The Puget Sounders are involved in a number of activities:

     1)Annual or semi-annual  garbage pickups on beaches

     2)Oiled bird rescues

     3) Stream tours to educate the public about stream ecology

     4)Low cost portable exhibits on various environmental
       issues

     5)Public forums on shoreline development issues (e.g.
       Alaska Ferry Terminal  and Fairhaven Masterplan)

     6)Volunteer program to eradicate the invasive plant
      purple loose strife from wetlands, as well as  "how to"
      brochure.

In addition, the Puget Sounders have also received funds from
the Puget Sound Water Quality  Authority (PSWQA)  to  create
standardized/regionalized  low   cost   portable  educational
exhibits.

What subjects are  addressed  in  the  portable  exhibits?  Were
the monies obtained from PSWQA from their Public Involvement
and Education fund?  Please elaborate on the standardization
and regionalization of the portable educational exhibits.

Other Community Groups

The Fairhaven Neighbors  are  very active in  the Padden Creek
enhancement effort.  Is  this part of  the City of Bellingham
Parks and Recreation Department habitat enhancement and public
access project?

The Friends of Lake Whatcom are actively educating the public
about  the  importance  of  protecting  water  quality.    What
mechanisms are used to accomplish this?

Consumers United  for Safe  Paper  are working to build demand
for recycled paper products and to discourage the use of the
chlorine bleaching process.  How is this accomplished?
                               A-115

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     The  Bellingham  Cooperative   School   is   involved  in  the
     enhancement effort  at Padden  Creek  as well as  storm drain
     stencilling.  Js  the Padden Creek enhancement work part of the
     City of  Bellingham  Parks and  Recreation  Department habitat
     enhancement  and  public  access  project?    What  area  of
     Bellingham  was stencilled  by the  school and  when?   What
     coordination  took place  with the City  of Bellingham Public
     Works Department?

     Bellingham/Samish   Bay  Salmon   Enhancement  Group-   What
     activities are they involved in?

     Western Washington University

     Are there any recent or planned studies related to pollution
     in Bellingham Bay?

     General

     What  actions  are  the  citizens  of  Bellingham  taking  as
     individuals (e.g. recycling, buying recycled products, using
     environmentally friendly products; reducing or eliminating the
     use of pesticides,  herbicides,  and  fertilizers;  composting,
     using mass transit)?

The draft Action Plan will be distributed for review to each member
of the Bellingham Bay Action Program Work Group. A full work group
meeting will  be held this  summer  to discuss and comment  on the
draft plan.  Prior  to the finalization of  the plan, public comments
will also be solicited.

If you would like to discuss or clarify any issues  prior to sending
your response, feel free  to call  me at  649-7272.   Please have your
response letter to me by Friday,  June 7th.

I appreciate your participation in this process  and look forward to
your response.
                                   A-116

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JON 0 7
    . Of ECOLOGY


-------
?             ,
  S^^
   ?              sts


-------
CHRISTINE O. GREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May 17, 1991
       Mr. John Anderson
       Environmental Control Director
       Georgia Pacific Corp.
       P.O. Box 1237
       Bellingham, WA  98227

            Re:  Bellingham Bay Action Plan

       Dear Mry Anderoon;

       This letter is in follow-up to the October  8,  1990  meeting that
       Michael Jacobson (PTI Environmental Services),  Fran Solomon
       (Ecology), Marc Crooks  (Ecology), Don  Kjosness (Ecology),  and I
       had with you and Ed Dahlgren regarding actions that Georgia
       Pacific is taking to reduce pollution  in  Bellingham Bay.   I have
       summarized below our understanding of  Georgia  Pacific's actions
       and have asked  additional questions.   Please  confirm or modify
       the summary and address the new questions through a written
       response.  This letter, as well as your response, will be
       included in the draft Bellingham Bay Action Plan scheduled for
       release this July.

            Stormwater

            Surface water runoff from the Georgia  Pacific  site is
            collected and conveyed to a secondary  treatment lagoon and
            is therefore addressed under the  NPDES permit  for the
            discharge from the lagoon.  Georgia  Pacific is also working
            to reduce releases to the storm drain  system.   What specific
            steps are being taken to reduce discharges to  the drainage
            system?  Are these steps currently being implemented  or is
            there an implementation schedule?

            NPDES Permit

            Georgia Pacific's new NPDES permit has been issued.  The
            permit can be appealed within the next 30 days
            (Approximately the middle of June, 1991)
                                        A-119

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Mr. John Anderson
May 17, 1991
Page 2


     Waste Reduction and Recycling

     Georgia Pacific has reduced its water consumption from 50
     mgd to 37 mgd through recycling and new process equipment.
     Are you planning any other conservation efforts?
     Can any of your waste products be reused by another industry
     or composted for resale as a soil enhancer?  The Industrial
     Materials Exchange might be able to connect you with
     companies that could use your wastes.  Are you aware of
     their services?  If not J would be happy to send you some
     information.  If you have contacted them, have they found
     any potentially interested parties?

     Bleaching Process/Recycled Paper Products

     Georgia Pacific has experimented with bleaching agents other
     than chlorine, and has sold the pulp around the Pacific rim
     to test its marketability.     At this point however, there
     are no plans to change to an alternative method.  What are
     the other bleaching agents you have experimented with?  What
     is the market for pulp bleached via a non-chlorine process?
     What requirements would have to met in order for an
     alternative to be permanently incorporated into your
     process?

     Paper products made from recycled paper have become quite
     common and appear to be increasing in popularity.  What role
     will recycled paper products play in Georgia Pacific's
     future?

     Landfills

     Georgia Pacific has the following historic and currently
     active off-site woodwaste landfills:

     1)   Airport Woodwaste Landfill, 12 acres, active

     2)   Hilltop Farms Woodwaste Landfill, 30 acres, active

     3)   Y-Road Landfill, closed

     4)   1178 Marine Drive, 10 acres, closed

     Is this list complete and accurate?  What types of materials
     are (have been) disposed of at these sites?  How long were
     the closed sites in operation?  How long have the active
     landfills been in service?
                                A-120

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Mr. John Anderson
May 17, 1991
Page 3


     Nonprocess Wastes

     Georgia Pacific has had all PCB-containing capacitors and
     transformers removed from the site.

     The plant has two above ground petroleum storage tanks and
     no underground tanks.  Solvents and waste paints are removed
     by a contractor.  What procedures are in place to
     contain/ cleanup a spill?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your participation in this process and look forward
to your response.


                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTPrlp
                                A-121

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                    Georgia-fecificCorporation  P.O. BOX 1236
                                            Bellingham, Washington 98227
                                            Telephone (206) 733-4410
                                            Teletype (910) 442-2370 GEOBLHM BLH
                                            Telecopy (206) 676-7217
                                             RECEIVED

                                               MAY 3 0 1991
May 29, 1991
                                               OEPT. OF ECOLOGY
Ms. Lucille T.  Pebles,  P.E.
Bellingham Bay  Action  Program Coordinator
Department of Ecology,  Northwest Regional Office
3190 - 160th Ave.  S.E.
Bellevue, Washington    98008-5452

Dear Ms. Pebles:

This letter is  written in response to your letter dated May 17,
1991.  Outlined below  are comments and responses to your
summary and questions.

     Stormwater

     Surface water run-off from the Georgia-Pacific site is
     collected  and conveyed  to the secondary treatment lagoon
     and is therefore  addressed under the NPDES permit for
     discharge  to  Bellingham Bay.  Run-off is from precipi-
     tation and constitutes  a small fraction of secondary
     treatment  influent.   There are no current plans to reduce
     flow.

     NPDES Permit

     Georgia-Pacific's  NPDES permit was reissued May 15, 1991.

     Waste Reduction and  Recycling

     Georgia-Pacific has  reduced its water consumption from 50
     mgd to 35  mgd through recycling and new process equipment.
     No further water  use reduction is anticipated in the near
     future.

     Approximately ten  percent of primary treatment solid waste
     is currently  re-used by another local industry.  Other
     potential  outlets  for re-use are under consideration.
     Georgia-Pacific has  participated in the Industrial
     Materials  Exchange.
                             A-122

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Ms. Lucille T. Pebles, P.E.                        May 29, 1991
     A project to press and burn primary treatment solid waste
     for fuel is underway with start-up anticipated early in
     1992.

     Bleaching Process/Recycled Paper Products

     Georgia-Pacific has developed a non-chlorine pulp
     bleaching process utilizing caustic soda, oxygen and
     peroxide.  The present market for this pulp is primarily
     in Europe for tissue products.  Additional production of
     non-chlorine bleached pulp at Georgia-Pacific will depend
     on market demand, cost of production and regulatory
     developments.

     Recycled fiber is not presently used in tissue products
     manufactured at the Bellingham facility.  A corporate wide
     review is underway to consider use of recycled fiber in
     Georgia-Pacific tissue products.

     Landfills

     Georgia-Pacific has the following historic and currently
     active off-site woodwaste landfills:

          1)  Airport Woodwaste Landfill, 12 acres, - active

          2)  Hilltop Farms Woodwaste, 30 acres - active

          3)  Y-Road Landfill - closed

          4)  1178 Marine Drive - closed

     Primary treatment and secondary treatment solid wastes
     have been deposited at the Airport Woodwaste Landfill
     site.  The Airport site has been active since 1984.  The
     Hilltop Farms Landfill site has been active since 1976.
     Currently, only logyard waste is deposited at the Hilltop
     Farms Landfill site.  Primary treatment solid waste was
     also deposited there for a period of time.

     No facility records currently exist for the two closed
     sites.

     Non-process Wastes

     All electrical capacitors and transformers at the
     Georgia-Pacific facility contain less than 50 ppb
     polychlorinated biphenyls (PCB's).
                          A-123

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Ms. Lucille T. Pebles, P. E.                       May 29, 1991
     The plant has 14 above ground petroleum storage tanks; no
     underground storage tanks, as defined by EPA, are in use-
     All solvents and waste paints are removed from the site by
     contractors.

     The facility has a spill prevention control and counter-
     measure plan.  On-site personnel and out-side contractors,
     as needed, would be utilized to mitigate and clean-up a
     spill .

If I can provide additional clarification or information,
please contact me at (206) 676-7208.
Sincerely,
John L. Andersen
Environmental Control Director

JLA/bbl
                              A-124

-------
CHRISTINE O. CRECOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY
          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                   May 17,  1991
        Mr.  Michael Rogers
        Maritime Contractors, Inc.
        201  Harris Avenue
        Bellingham, WA  98225

             Res  Bellingham Bay Action Plan
               S7/&J4US
        Dear Mr—-Rogers1:

        This letter is in follow-up to the September 27,  1990 meeting
        that Michael Jacobson (PTI Environmental Services), Fran  Solomon
        (Ecology), and I had with you regarding actions that Maritime
        Contractors is taking to reduce pollution  in Bellingham Bay.   I
        have summarized below our understanding of your'actions and have
        asked additional questions.  Please confirm or modify the summary
        and  address the new questions through a written response.   This
        letter, as well as your response, will be  included in the draft
        Bellingham Bay Action Plan scheduled for release  this July.

             Best Management Practices

             With assistance from the Coast Guard, Maritime Contractors,
             Inc. (MCI) has developed a hazardous  waste management and
             contingency plan.  The plan calls for containment  booms  to
             be in place when pier side work is performed and small
             sorbent booms, sorbent pads and kitty litter,  to be
             available for upland spill containment.  All employees will
             receive training on the plan.

             MCI has two dry docks and one marine  railway.  Dry dock
             sandblasting is performed with canvas curtains during windy
             conditions to contain the airborne particulates.   The dry
             docks are cleaned, prior to being sunk, by hand sweeping and
             shoveling the sandblast grit into piles.  These piles are
             then scooped up by a Bobcat, deposited into  small  bins which
             are in turn dumped into a large storage bin.  The  large
             storage bin is an old truck trailer which  is water tight on
             the bottom and sides but is open on top.   Hour is  the
             sandblast grit ultimately disposed of?
                                        A-125

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Mr. Michael Rogers
May 20, 1991
Page 2

     National Point Discharge Elimination System Permit

     MCI has applied for an NPDES permit, and it is currently
     being written by Ecology's water quality program.  The
     permit will cover the entire site and will have monitoring
     requirements.

     Dangerous Waste Regulations

     Sandblast grit, paint residues from cleaning, and still
     bottoms from solvent recycling, are all covered under the
     State's Dangerous Wastes program.  Therefore, MCI must
     follow strict State requirements for hazardous waste
     generation, storage, handling, transport and disposal.  Are
     there any other wastes which are considered Dangerous wastes
     or will be considered Dangerous wastes under the new
     Toxicity Characteristic Leaching Procedure testing
     requirement?

     New Construction

     MCI is considering the construction of an additional pier as
     well as the extension of an existing stub pier located on
     the other side of the Alaska Ferry Terminal.  What is the
     status of these projects?  What steps will be taken to
     ensure minimal environmental impact?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTPrlp
                                A-126

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                   MARITIME CONTRACTORS INC

                           2O 1  HARRIS AVENUE
                      BELLING HAM, WA 98225-7018

                            (2O6) 647-OO8O
MAY 23, 1991
LUCILLE T. PEBLES
DEPARTMENT OF ECOLOGY
3190 - 160TH AVENUE S.E.
BELLEVUE, WA  98008-5452

RE:  BELLINGHAM BAY ACTION PLAN
     YOUR LETTER DATED MAY 17, 1991

DEAR LUCY:

ACTIONS  MARITIME  CONTRACTORS  HAVE  TAKEN  TO  REDUCE  POLLUTION  IN
BELLINGHAM BAY ARE AS FOLLOWS:

BEST MANAGEMENT PRACTICES

PRESENTLY OUR  CONTINGENCY PLAN CALLS  FOR  A CONTAINMENT BOOM TO BE
READILY AVAILABLE WHEN PIER SIDE WORK  IS  IN PROGRESS.  WE ARE GOING
TO  MODIFY  IT SO THE CONTAINMENT BOOM  WILL BE  DEPLOYED DURING PIER
SIDE WORK.

ALL  DRY-DOCK  SANDBLASTING  WILL  BE  DONE  WITH  FABRIC  CURTAINS  IN
PLACE.   SANDBLAST  GRIT  WILL NOW BE STORED  IN A CONCRETE BUNKER AND
COVERED  WITH  A  TARP.    THE  GRIT  IS  REMOVED  FROM  OUR SITE  AND
RECYCLED BY A COMMERCIAL CARRIER.  (INDUSTRIAL SERVICES)

DANGEROUS WASTE REGULATIONS

WE WILL HAVE NO OTHER DANGEROUS WASTES THAT WE ARE AWARE OF.

NEW CONSTRUCTION

THE EXISTING STUB  PIER  BELONGS TO THE PORT OF BELLINGHAM.   THE MCI
PIER  EXTENSION  HAS  NOT  BEEN  APPROVED BY  THE  BELLINGHAM PLANNING
COMMITTEE AS  YET.   ALL  ISSUES  INCLUDING  ENVIRONMENTAL HAVE BEEN
ADDRESSED.   CONSTRUCTION MATERIALS WILL  BE STEEL AND CONCRETE AND
CONSTRUCTION TIME  FRAMES WILL BE  AS  DIRECTED  BY  THE DEPARTMENT OF
FISHERIES.

IF WE CAN BE ANY FURTHER SERVICE,  PLEASE  GIVE US  A CALL.

SINCERELY,
 IICHAEL 
-------
CHRISTINE O. GRECOIRE
     Director
                                 STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                  May 17,  1991
       Mr. Michael Clausen
       Bellingham Cold Storage
       P.O. Box 895
       Bellingham, WA  98227

            Res  Bellingham Bay Action Plan
              St&Łu/
       Dear Mi*. ClaUoea;

       This letter is in  follow-up to the October 3, 1990 meeting that
       Michael Jacobson (PTI Environmental Services), Jacques Faigenblum
       (EPA), Fran Solomon (Ecology), and I had with you regarding
       actions that  Bellingham Cold Storage is taking to reduce
       pollution in  Bellingham Bay.  I have summarized 'below our
       understanding of your actions and have asked additional
       questions.  Please confirm or modify the summary and address the
       new questions through a written response.  This letter, as well
       as your response,  will be included in the draft Bellingham Bay
       Action Plan scheduled for release this July.

            Permits

            Bellingham Cold Storage (BCS) has reapplied for a NPDES
            permit.   The  permit will cover non-contact cooling water as
            well as  process water.  Ecology is currently writing the
            draft.

            Waste Reduction

            The cost of discharging to the Post Point treatment plant
            will increase when the plant goes to secondary treatment in
            1993.  Therefore, to minimize this expense BCS is looking at
            several  options for reducing water consumption:

            1)   Closed Glycol Cooling System- BCS currently has a
                 closed glycol cooling system in Engine Room 1 and is
                 considering this type of system for Engine Room 2.
                                       A-128

-------
Mr. Michael Clausen
May 17, 1991
Page 2


     2)   Chilled Water/Chlorination System- Product transfer
          water is hydro-chilled, screened, and chlorinated for
          reuse.

     In addition to the above conservation measures, BCS is also
     discussing with Bellingham Frozen Foods (BFF),  the
     possibility of discharging non-contact cooling water to
     BFF's new land application system.  The implementation of
     any of these activities is contingent upon their economic
     feasibility.     What is the status of these various
     efforts?

     Stormwater Runoff

     The BCS drainage system discharges to the bay at
     approximately ten locations.  The system does have catch
     basins to collect sediments but does not have oil/water
     separators.  The property is owned by the Port of Bellingham
     and they are responsible for the drainage system.  Regarding
     the number of discharges to the bay, is this from the entire
     site including Icicle, Bellingham Frozen Foods, Trident
     Seafoods and San Juan Seafoods?  Does the Port maintain the
     drainage system? How frequently?

     Best Management Practices

     BCS does not intentionally dump materials into storm drains;
     however, there is no written policy on this.  Waste oils are
     discharged into the two on-site waste oil containers which
     are then picked up by a private contractor.  All forklifts
     on the site are electric and therefore the only oils being
     used are hydraulic and refrigeration oils.  Ammonia and
     solvents are also used on the site.  What procedures are in
     place to contain/cleanup spills?  Are employees familiar
     with these proceedures?  Are you planning to develop a
     written policy to clearly delineate good housekeeping
     practices?  Would formal training of employees be used to
     ensure implementation of such a policy?

     New Facilities

     BCS will be constructing a new dry storage facility next to
     Bellingham Frozen Foods, as well as a new processing plant
     at their Orchard Drive property.

     BCS currently has a plant on Orchard Drive and is in the
     process of obtaining permits to clear additional land.  The
     property does include wetlands and BCS is hoping to trade
     other properties for these wetlands.  What is the status of
     the Orchard Drive project?  How was the wetlands issue
     resolved?
                                 A-129

-------
Mr. Michael Clausen
May 17, 1991
Page 3


     Will the new processing plant site provide tor treatment of
     storimfater prior to discharging to the City of Belllngham's
     drainage system?   Some potential treatment methods include:
     grass-lined swales, wet ponds, settling basins, and grass-
     Crete parking areas.

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday, May 31st.

I appreciate your support of this process and look forward to
your response.


                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTPrlp
                                A-130

-------
                               RECEIVED

                                 MAY 2 8 1991

                                    OF ECOLOGY
                                                Belllngham Cold Storage Company
                                                Squalicum Waterway
                                                P.O. Box 895
                                                Bellingham, Washington 98227-0895
                                                (206) 733-1640
                                                FAX 206-671-1259
May 22,1991

Ms. Lucille T.  Pebles
Department Of Ecology
3190 160th Ave.  S.E.
Bellevue, Wa. 98008-5452

    Re: Bellingham Bay Action Plan

Dear: Lucille

In response to  your letter regarding of the summary that will
go into the Bellingham Bay Action plan draft.

(1) Permits,  B.C.S.  is still waiting for these permits.

(2) Waste Reduction,   The cost of discharging to Post Point
has already increased and will go up even more when the
Project is completed. As to the feasibility of dumping into
B.F.F. Land application system, We have no further
information at  this time.  Everything else is still pending.

(3) Stormwater  Runoff,  the number of 10 is only an estimate
and it covers the entire complex.  The port does not maintain
the drainage system and there is some question as to who is
responsible for them at this time. - B.C.S. cleans and
maintains them  at this time as needed.

(4) Best Management Practices,  At this time all Maintenance,
foremen, cleanup and most forklift personal are trained in
these cleanup procedures and a policy is being written by our
safety committee.

(5) New Facilities,  B.C.S. has plans to build a new dry
storage plant at the main plant for B.F.F., But has not been
approved at this time.  There are no plans to build a
processing plant at the orchard Drive Plant.  The wetlands
issue has not been resolved and may not be resolved for some
time.

If you need more information please call me.

Sincerely,

Bel 1 ingham_Co l
-------
CHRISTINE O.CREGOIRE
    Director
                                STATE OF WASHINGTON

                           DEPARTMENT OF ECOLOGY

          Northwest Regional Office, 3190-160th AveS.E. • Bellevue, Washington 98008-5452 • (206)649-7000


                                 May  17,  1991
      Mr.  David Green
      Bellingham Frozen Foods, Inc.
      P.O.  Box 1016
      Bellingham, WA  98227

            R«:  Bellingham Bay Action Plan
             &r*"&
      Dear M±. Giumi;

      This letter is in follow-up to the October 3, 1990 meeting that
      Michael Jacobson (PTI Environmental Services), Jacques Faigenblum
       (EPA),  Fran Solomon (Ecology), and I had with you regarding
      actions that Bellingham Frozen Foods is taking to reduce
      pollution in Bellingham Bay,  I have summarized below our
      understanding of your actions and have asked additional
      questions.  Please confirm or modify the summary and address the
      new  questions through a written response.  This letter, as well
      as your response, will be included in the draft Bellingham Bay
      Action  Plan scheduled for release this July.

            Land Treatment Facility

            Construction of Bellingham Frozen Foods (BFF) land treatment
            facility is scheduled to begin in May or June of 1991, and
            to be completed by the end of the summer.  The facility is
            expected to be operational, with the City wastewater
            treatment facility as a backup, through 1992.  In 1993, BFF
            plans to be fully operational with no City backup.  How will
            you dispose of wastewater when soils are saturated and
            cannot absorb any more liquids?   What is the current
            schedule for the project?

            The EIS for the project has been approved and finalized, and
            the necessary permits are being obtained.  A draft NPDES
            permit is currently available for public review and comment.
            The State Waste Discharge Permit is currently being written.
            What is the status of the other required permits?

            Waste Reduction

            Three years ago BFF began recirculating the water used to
            transport carrots, through a closed loop system.  This
            system hydro-chills and screens the water and then treats  it
            with chlorine dioxide.  The implementation of this process
            reduced BFF's water use by 400,000 gallons per day during
            the carrot season, which runs about 60 days.
                                       A-132

-------
Mr. David Green
May 17, 1991
Page 2


     BFF is currently looking at this system for the bean line,
     although the water savings will not be as great as for
     carrots.  What is the status of implementing the
     recirculation system for other products?

     BFF is also investigating the possibility of eliminating
     water transport for some products; a conveyor belt system
     would be used instead.  What is the status of this
     investigation?  What products would be transported via the
     conveyor system?

The draft Action Plan will be distributed for review to each
member of the Bellingham Bay Action Program Work Group.  A full
work group meeting will be held this summer to discuss and
comment on the draft plan.  Prior to the finalization of the
plan, public comments will also be solicited.

If you would like to discuss or clarify any issues prior to
sending your response letter, feel free to call me at 649-7272.
Please have your response letter to me by Friday; Hay 31st.

I appreciate your participation in this process and look forward
to your response.

                              Sincerely,
                              Lucille T. Pebles, P.E.
                              Bellingham Bay Action Program
                              Coordinator
LTP : Ip
                                  A-133

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                                        Eff
 BELLINGHAM                  o..
FROZEN FOODS                ™3
                                                                           fig*
                                                                       L
        May 29,  1991
        Lucille T.  Pebles,  P.E.
        Bellingham Bay Action Program
           Coordinator
        Department of Ecology
        3190 - 160th Avenue S.E.
        Bellevue, Washington  98008-5452

             RE:  Bellingham Bay  Action Plan

        Dear Ms. Pebles:

        This letter is in response  to your  letter of May 17, 1991,  in which you
        summarized Bellingham Frozen Foods'  (BFF) actions at reducing impacts  on
        Bellingham Bay.  I  would  like to  clarify several points as  follows:

             Land Treatment Facility

             All the necessary permits have  been obtained, and we have begun
             construction of our  land treatment system.  This system includes  a
             20 million gallon storage lagoon.  This lagoon will  allow us  to
             store wastewater when  soil conditions do not allow us  to irrigate.
             The current schedule should  see construction continuing through
             this summer with completion  in  late fall.

             Waste Reduction

             Your summary describes our hydro-chilling recirculation system.
             This system is used  for peas,  not carrots.  We have implemented  a
             system for the 1991  processing  season which will reduce water
             consumption for corn processing by approximately 200,000 gallons
             per day.  This same  system will be used during carrot processing
             and save  approximately 120,000 gallons per day.

             Future Projects

             BFF is investigating other ways to reduce water consumption in  its
             processing,  and may  see other  systems changed in the future.

        If you have any questions,  please contact me.

        Sincerelyv
        David B. Green
        Plant Manager                         A-134

p.o. box 1016                   bcllingham, Washington 98227                   (206) 734-4040

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      APPENDIX B

Available Funding Sources.
  Urban Bay Action Plan
     Implemen ta tion

-------
      AVAILABLE FUNDING SOURCES:
 URBAN BAY ACTION PLAN IMPLEMENTATION
            September 1991
       (Updated  -  Ecology,  NWRO)
Prepared for the Department of Ecology
         by Jo Anne  Harrison
                  B-1

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                        INTRODUCTION
The Washington State Department of Ecology (Ecology)
recognizes that some local governments with limited
financial resources face serious water pollution control
needs.  While the trend in solving environmental problems is
toward equal responsibility between federal, state, and
local governments, creative options in meeting local match
requirements are available to help communities take
advantage of funding sources without straining local
revenues.  Ecology stands ready to assist local governments
in exploring these options in order to solve environmental
problems in a manner that does not cause undue financial
hardship.

The local share may be funded by taxes, sales of bonds,
formation and assessment of construction permits and grants
or loans from other state or federal agencies.  The
Washington State Revolving Fund (SRF) for Water Pollution
Control can provide low interest financing of local match
for state grants.  Grants from the Centennial Clean Water
Fund  (CCWF) and loans from SRF may be combined, so
applicants need only deal with Ecology staff for complete
financing of water pollution control projects.

The Washington State Legislature and the U.S. Congress have
passed major legislation to protect water resources.  State
legislation includes the Centennial Clean Water Fund and
Aquatic Lands Enhancement Account.  Federal legislation
includes the Clean Water Act and the Coastal Zone Management
Act of 1972.  Amendments are added to the Clean Water Act as
the need arises.

Brief descriptions of possible funding sources for
implementation of urban bay action plans are presented here
for your information.  A chart listing grant and loan
programs, requirements, time lines, and contact persons is
attached.

      The Washington State Centennial Clean Water Fund

The Centennial Clean Water Fund (CCWF) is a major source of
financial assistance providing grants and loans for water
quality projects.  The CCWF is a partnership between the
state and local governments.  Created by the state
legislature in 1986, the continuation of the fund has been
authorized through the year 2021.  The CCWF helps local
communities meet water quality, health and safety
requirements.  It is dedicated to protecting the waters of
Washington State for current and future generations.
                             B-2

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Through the year 1995, 50 percent of the annual fund of $45
million is earmarked for marine water facilities, which
include secondary sewage treatment plants, reduction of
combined sewer overflows (CSOs), stormwater discharges or
other facilities which empty directly into marine waters.
Facilities receive a base 50% of the total eligible cost; an
additional grant and/or loan is possible if the local match
would cause the community financial hardship.  Most
activities receive a grant covering 75 percent of the total
eligible project costs.  Other funding categories include
nonpoint pollution control, groundwater and freshwater
projects.  Activities include planning, research, monitoring
and education.  The CCWF does not fund cleanup projects.  In
special cases, the discretionary category can provide up to
100 percent of the eligible project cost.  Strong local
support and the seriousness of the problem are rating
criteria for grant and loan awards.

Centennial grants in the Groundwater Category are providing
$5.5 million in funds for fiscal year (FY) 91.  Funding is
available for the designation of local Groundwater
Management Areas (GWMAs) and for protection of groundwater
quality and quantity.

          THE  WASHINGTON STATE  REVOLVING FUND (SRF)
                 FOR WATER POLLUTION CONTROL

The Washington State Revolving Fund  (SRF) for Water
Pollution Control provides low interest loans for high
priority water quality needs.  Congress established the SRF
as part of the Clean Water Act Amendments of 1987 as a way
to phase out federal grants and phase in state loans.  The
U.S. Environmental Agency  (EPA) will "seed" the SRF with
yearly capitalization grants, subject to Congressional
appropriation, until 1994.  The state must contribute 20
percent matching funds during this period.  After 1994,
federal and state capitalization will end.  Loan repayments,
with interest, will sustain the SRF from then on in
perpetuity.

Eighty percent of the money is earmarked for the planning,
design or construction of water pollution control
facilities.  Ten percent can go for nonpoint sources control
projects, and 10 percent of the SRF can go to conservation
and management projects for federally designated estuaries
like Puget Sound.  Projects in this category may include
purchases of wetlands, the construction of boat pumpout
facilities and other projects.  The SRF can provide
financing for the local match for state grants under certain
conditions such as financial hardship.
                             B-3

-------
The sooner the borrower repays the SRF loan, the lower the
interest rate.  For now, for a 0-5 year term, no interest
will be charged; for a 6-14 year term, the interest rate
will be 4 percent; and, for a 15-20 year term, the interest
rate will be 5 percent.  After 1992, SRF interest rates will
be 60 - 75 percent of the current market rate.  If all
federal requirements are satisfied, SRF can provide
refinancing of local funds already spent on planning and
design not covered by grants as well as financing to make up
some ineligible portions of state or federal grants.

             COASTAL ZONE MANAGEMENT 306 GRANTS

Ecology's Shorelands and Coastal Zone Management Program
administers $400,000 in 306 grant funds annually (provided
to Ecology through the federal Coastal Zone Management Act)
for local shoreline master program  (SMP) improvements and
special shoreline projects.

Preparation of SMP amendments, including public involvement,
legislative review and process necessary for local adoption,
can address such issues as: public access policies and
regulations; environment mapping and redesignations;
waterfront revitalization policies and standards; beach and
dunes management provisions; use activity provisions such as
aquaculture, marinas, etc.; site planning and design for
public access improvements, waterfront restoration and
interpretive centers; and, public information and education
programs.  The grant project must enhance the local
shoreline master program, improve management of shoreline
resources and go beyond routine shoreline management
activities.

                         205J GRANTS

Each year approximately $334,000 in grant funds is provided
to the state from the Federal Clean Water Act, subject to
Congressional appropriations.  Fifty percent of the funds go
to state agencies and 50 percent is available for pass-
through to local governments.  The grants cover water
quality planning activities only.  One of the current
priorities is the restoration and maintenance of a healthy
and productive Puget Sound.  Ecology can provide information
on what is currently available.
                            B-4

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               WASTE MANAGEMENT GRANT  PROGRAMS

Many grant programs are available to address waste
management problems.   Hazardous waste planning grants
provide financial assistance for updating local
comprehensive hazardous waste management plans.  Local
health departments can apply for solid waste enforcement
grants.  Financial assistance is available for planning and
carrying out household hazardous waste collection events.
Local governments may apply for financial assistance for
installation of groundwater monitoring wells at municipal
landfills, for the purpose of identifying potential
contamination of groundwater.  Waste reduction and recycling
grants provide funds for the design of programs that promote
Washington's solid waste management priorities.

In 1989 the Legislature authorized several new waste
reduction and recycling grants.  Projects include: tire
recycling, removal, and enforcement programs; developing
public informational materials; establishing the feasibility
of composting food and yard waste; Phases 2 and 3 - waste
reduction and recycling grants; and, hazardous waste
planning implementation grants.

Public participation grants are available to citizen groups
of three or more persons and not-for-profit public interest
groups organized for the purpose of working on environmental
issues or providing involvement services.  Citizen/Proponent
negotiations grants can be awarded to local governments
affected by the development of a dangerous waste management
facility, to establish a citizen negotiating committee that
will discuss mitigation of potential impacts on the
community with the facility proponent.

              AQUATIC  LANDS  ENHANCEMENT  ACCOUNT

In 1984 the Legislature created the Aquatic Lands
Enhancement Account (ALEA).  The ALEA was established to
provide funding for state and local projects designed to
enhance state-owned aquatic lands by providing public
access, recreation and environmental protection.  The
account is funded by lease revenue received from various
uses of state aquatic lands under the Department of Natural
Resources  (DNR).

Projects may involve acquisition of marine tidelands and/or
adjacent uplands.  Examples of eligible public
access/recreation projects are: planting shellfish for
recreational use; creating water-oriented interpretive
                           B-5

-------
displays; establishing open-water swimming areas; providing
nonmotorized boat launches and temporary moorage facilities;
and building fishing piers and reefs.  The ALEA program is
not available for source control projects.

ALEA projects in Whatcom County include the acquisition of
approximately 300 linear feet of tidelands abutting Birch
Bay State Park and expanding and improving an existing trail
system along Whatcom Creek in downtown Bellingham.  The
Whatcom Creek project includes a viewpoint and deck at the
historic location of an old mill.

           AGRICULTURAL WATER SUPPLY LOANS/GRANTS

Referendum 38,  (approved by the voters in 1980), authorizes
the State Finance Committee to issue State General
Obligation Bonds in the amount of $125 million for water
supply facilities.  Fifty million dollars of the
authorization is to be used for agricultural water supply
facilities alone or in combination with fishery,
recreational, or other beneficial uses of water.  The $50
million is to be administered by the Department of Ecology.

Ecology may use or permit the use of the bond proceeds,
subject to legislative appropriation, by direct expenditure,
and by grants or loans to public bodies.  This includes
grants to public bodies as matching funds in any case where
federal, local, or other funds are made available on a
matching basis.

                       REMEDIAL ACTION

Remedial action funds are available for investigation of
suspected hazardous waste sites and for the cleanup of
confirmed sites.  For fiscal year  (FY) 89-91, $15,902,000
was made available to applicants.  Fifty thousand dollars  is
the ceiling amount for routine cleanup and also for site
hazard assessment.  Fifty percent funding is available for
investigation and cleanup; 100 percent for routine cleanups
and site hazard assessments; and, for economically
disadvantaged communities an additional 25 percent
supplement may be awarded.
                            B-6

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                                                                   FUNPINC PROGRAMS
          PROGRAM
          Centennial
          Clean Water
          Fund ICCMTI
                                          DESCRIPTION
Financial I
technical assistance
for water pollution
control activities
and facilities
                                                                           REQUIREMENTS
Only water
quality projectn
I/I of local chare
•ust cone fro* local
source* or loam
                                                                                                     NEXT APPLICATION PERIOD


                                                                                                     Jan. - F»b.
                                                                                                                                   CONTACT*
                              Helen Breiler
                              (2061459-6096
          State
          Revolving Fund
          for Mater Pollution
          Control  ISRPI
Low interest
loans for
water pollution
control projects
Meet state
Nonpoint Plan
or Puqet Sound
Plan if relevant
                                                           June - July 6.  1991
                              Dan PI Up
                              I206I4S9-6061
          Coastal Son*
          Management
          10* Grants
Planning grants
and special projects
to implement shoreline
•aster
                                                                            Mrite  or call
                          Jan.  - Feb.  1991

                          Jsn.  - Fab.  1991
                              Steve Craig
                              12061 4S9-4J80
                              Jim Scott
                              I206MS9-67S1
          20VJ Grants
                                           Planning  for  water
                                           quality projects
                                  Planning
                                  activities only
                                                                                                     Jan. - Feb. 1991
                                                        Helen Brealer
                                                        (206)459-6096
DO
          Ground Hater
          Management
          Area Program-
For designation of
GMMAs and protection
of groundwater
quality i quantity
Hust be on
Ecology's
General Schedule
                                                                                                     Ongoing
                              Doug Rushton
                              I20«|4i*-*l20
          Household
          Haiardous Mast*
          Col lectio* Events
Planning and
carrying out
collection days
(or households
                                                                            Call for info.
                                                                                                     Call for deadline info.
                                                        Nike Drunright
                                                        (206)4i*-629?
          Public
          Participation
 Investigating  and
 remedying  haiardous
 substance  release
 Chptr.  171-J21
 MAC or  grant
                                                                                                     Feb. - March 1991
                              Laurie Davies
                              (20t|41l-7St2
          Citizen/
          Proponent
          Negotiations
Negotlationg
committee  to  neet
with  proponents of
dangerous  waste
a«nage*«nt facilities
 MAC 171-103-902
 and grant
 guideline*
                                                                                                     Ongoing
                               Laurie  Davies
                               |20»|4Jd-7S«]
          Aquatic Land*
          Enhancrn*«t
          Account
Land acquisition.
public access/
recreation projects
                                                                            Call for info.
                          June 30.  l»9l
                          Deadline
                              Robert Brando*
                              I20t|Sls-tOJ)
          Agricultural
          Mater Supply
          Loan/Grant
Agricultural
water supply
facilities
                                                                            Call (or info.
                                                                                                     Call for deadline info.
                                                        Pay Newklrk
          MrnedlaI
          Action
Investigation and
cleanup of haiardous
west* site*
          • Note:  To call Ecology stsff on the SCAN system,
           us* •isS" instead of *4»»' or -43d."
 MAC Chptr.
 171-322 and
 grant guideline*
Early su*»er 19*1
                              Julia Moods
                              l20«|4jCJ-72«)

-------
       APPENDIX C
Public Involvement Processes

-------
Public Involvement Processes
                       The information contained in this appendix has been excerpted from
                       various regulations and guidelines and are intended for general use
                       only.  More detailed information can be obtained from the following
                       Washington Department of Ecology staff members:
                       Shoreline Management Act
Peter Skowlund
                       State Environmental Policy Act   Vernice Santee
                       Model Toxics Control Act

                       National Pollutant Discharge
                       Elimination System

                       Puget Sound Dredged Disposal
                       Analysis
Dawn Hooper


Mary Kautz


Tom Gries
438-7430

459-6020

438-3013


649-7036


438-7706
                       For information on the Section 10/404 permit process, contact
                       David Fox of the U.S. Army Corps of Engineers at 764-3768.
                                     C-1

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           Shoreline Management Act
Note:   The Shoreline Master Program is addressed on pages C-4 through
       C-6. Shoreline permits are addressed on pages C-7 through C-9.
       The public notice requirements on page C-7 apply to the shore-
       line permit process.

-------
                               SHORELINE
                           MANAGEMENT
                                       IN
                           WASHINGTON
 Managing the Shorelines of
        Washington State

     The State's Shoreline Management Act of
1971 grew out of a public initiative, involving
concerned citizens and all levels of government.
It represents the goals of the people of Washing-
ton State to protect this limited and fragile re-
source while providing for appropriate uses.
This legislation makes the Washington Depart-
ment of Ecology responsible for developing a
program to manage the state's shorelines. The
act provides for local governments, and the
Department of Ecology, to prepare Shoreline
Master Programs for all shorelines of the state
within their jurisdiction, and implement these
programs through a local permit process with
state overview.

    Local Shoreline Master

            Programs

     Uses and activities along the state shore-
lines are managed  through city and  county
shoreline master programs. Each Master Pro-
gram is both a plan and a set of regulations
created specifically  for the shorelines of that
community. While Master Programs are tai-
lored to local issues and physical constraints,
theymust conform tostatewideguidelines,goals,
and policies. Local governments and the De-
partment of Ecology are jointly responsible for
developmentoflocalShoreline Master Programs
and administration of the shoreline permit pro-
gram. While issues in the Master Programs are
established primarily by local governments,
Ecology acts in a supportive and review capac-
ity with primary emphasis on insuring compli-
ance with the policies and provisions of the
Shoreline Management Act.
  ''Haw do I know if I need a permit?"

     ASK. Some projects are specifically ex-
empt from certain permit processes. However,
they still must be consistent with the Master
Program requirements. Check with your local
planning or building department for applica-
tion or exemption forms, environmental check-
lists and other information.

      "What do I need to know to
          design a project?"

     The local Master Program  gives each
stretch of shoreline a specific environmental des-
ignation which sets out the allowable uses and
regulations that must be met. The first step is to
check the master program for the location and
designation pertaining to your project.
     The Shoreline Management Act gives
preference to uses which are wateroriented. Most
waters and submerged lands are held in Public
Trust by the state. Your project may require
some form of public access, preservation of
certain views, habitat management or shore-
line rehabilitation.

    "What is involved in obtaining
         shoreline permits?"

     Local planning or building departments
supply the applications and most of the neces-
sary information. It is also at the local level that
the permits are processed. It is important to
remember that a project must also comply with
local zoning ordinances, State Environmental
Policy Act (SEPA) requirements, and other
applicable laws. For most projects the shoreline
permit will not be the only permit required.
                                       C-2

-------
         Ordinary High
         Wim Mark
         (OHWM)
      Coastal Shorelines
 MINIMUM
 SHORELINE
 JURISDICTION
             200' From OHWM or floodny and _
             all marsbe*. bogi, and iwamps in
             100 yr. floodpUin
 MAXIMUM
 SHORELINE
 JURISDICTION
             200' from OHWM and 100 yr. foodplaBi .


      River Shorelines
      Shoreline Jurisdiction

•  Lakes 20 acres or larger.

•  Streams with a mean annual flow greater
   than 20 cubic feet per second.

•  All marine waters.

•  Associated marshes, bogs, swamps and
   river deltas.

•  An area 200 feet landward from the
   water's edge.

•  Areas within 200 feet of designated flood
   ways.

•  Some or all of the 100 year floodplain
   including all associated wetlands within
   the entire floodplain.
                      C-3

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SMP Handbook - First Edition
A
                                     \
Chapter 3


Process to Amend


Shoreline Master


Programs



Introduction

Generally speaking, amending (updating) a local Shoreline Master
Program (SMP) involves a two step process (see figure 3-1):

    o    Step 1 - Preparation of amendments for review and
         adoption at the local level (WAC 173-19-060 & 061).
         Note: A "draft" of proposed amendments must be sent to
         WDOE for review and comment before local action is
         taken.

    o    Step 2 - Transmittal of the proposed amendments to
         WDOE who must then review and process the proposals
         (WAC 173-19-062(4)). Note:  All master program
         amendments must be reviewed and adopted by the
         Washington State Department of Ecology (WDOE) before
         they become effective.
               C-4

-------
 SMP Handbook - First Edition
 Figure 3-1 Process to Update Master Programs

 PROCESS TO AMEND MASTER PROGRAMS
         Form Citizens Advisory Committee
         Perform technical and public
         participation tasks necessary
         to develop SMP Amendments
 a
 4)
•<_>
C/3
Advertise public hearing
(3 consecutive weeks)
         Hold Public Hearing
         Local Government Decision
          Apply to WDOE
          (See application requirements)
GO
          WDOE Review
          Requires 3 to 5 months
         WDOE Approval
         SMP Amendments become effective
                   C-5

-------
Public Participation

Any comprehensive master program update must incorporate public
input and coordinate with public agencies. The Shoreline Management
Act states that all people should have an opportunity for involvement in
the development and implementation of SMPs and that WDOE and the
local governments shall actively encourage participation by the public
and federal, state, and local agencies (RCW 90.58.130).

WAC 173-16-040 suggests a process to comply with the SMA's public
participation requirement consisting of the following actions:

       a.     Appoint a citizen advisory committee to guide the master
             program  formulation;

       b.     Hold at least 3 public meetings during SMP development
             and environment designation process. Public notice
             should be given 7 days before each meeting and a record
             should be kept of the proceedings.  The final meeting
             should be at least 7 days prior to the required public
                rin-
       c.     Notice of the public hearing must appear in a newspaper
             of general circulation in the area in each of the three
             weeks preceding the hearing date (WAC  173-19-061(2));

       d.     Publish a newsletter to publicize the process schedule,
             meeting times and location, and purpose; and

       e.     Publicize the master program update effort through radio
             and local news media.

The procedures detailed in the WAC have been generally found to be
effective in building a consensus on shoreline management issues if
representatives from a broad spectrum of civic groups and interests are
included.  The number of meetings and public notification steps may
vary upon the size of community and complexity of issues.
                                 C-6

-------
SHORELINE PERMITS
Public Notice Requirements

The SMA gives local government discretion in structuring its permit
process.  Local administrators should follow the procedures for permit
processing described in the local master program.  Once an application
has been submitted, local government must solicit public comment on
the proposal.  At a minimum, the applicant must publish notices of the
application in a local newspaper for two consecutive weeks. An
affidavit that notice has been properly published and/or posted must be
affixed to the application. In addition, local government must provide
additional public notice such as mailing information to adjacent
property owners and community groups, posting of conspicuous notices
on the property, or other methods.  See WAC 173-14-070. Interested
members of the public are allowed 30 days to submit comments to the
local jurisdiction.
Depending on the requirements outlined in the local master program, a
public hearing may be held.  Hearings are typically required of large or
controversial projects, and for projects requiring a variance or
conditional use permit. Hearings can be used to assure that interested
citizens are appraised of the development proposal and will have
opportunity to comment on it. Options for hearings may be specified in
the shoreline master program, but could include a hearing before the city
or county council, planning commission, planning department or before
a hearings examiner.
                              C-7

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                         Admin. Manual - 1st Edition

Figure 4-1
Conditional Use Permit (CUP) or  Variance Review Process
     I
     o
     en
   Q 5
   s!
     I
     o
                   CUP or Variance Permit
                   Application Submitted
                   to Local Government (*1)
                    Notice Mailed/Posted and
                    Legal Notice Published
                    2 Consecutive Weeks
                                          Public Notice
                                          for Hearing
                                                                             in
                                                                            1
                    Technical Review
                    by Staff (Incl. SEPA)
                                          Public Hearing
                                          (Recommended)
                    Local Government
                    Permit Decision (*2)
                    Receipt of Permit by WDOE
                    WDOE Review and Decision
                    to Approve, Condition
                    or Deny
30 Day Period for Public
Local Gov't or Applicant
to Appeal WDOE Decisions
                                              •••••••••••••••••••••••••a
                    Authorization to Commence
                    Activity if not Denied
                    or Appealed
                                                             Appeals to
                                                             Shorelines Hearings
                                                             Board
Notes*
*1     SEPA checklist must be submitted with application
*2     SEPA requirements must be completed prior to local permit decisions
                                      C-8

-------
                       Admin. Manual - 1st Edition
 Figure 4-2
 Shoreline Substantial Development Permit  Review Process
                  Shoreline Permit
                  Submitted to Local
                  Government (*1)
trt
a
O
r-
•%
r^
Between
1 Notices
Notice Mailed/Posted and Legal
Notice Published 2 Consecutive Weeks
0 D
                  Technical Review by Staff
                                               If there are Substantial
                                               Questions or Public Issues
                                                            Public Hearing
                                                            (recommended)
                                        c
                                       Z
                                                                                         .c
                                                                                         3
                  Local Government (*2)
                  Permit Decision
                  Receipt of Permit by Washington
                  Department of Ecology (WDOE) -
                  Appeal Penod
j.......
                                                             Public, Local Gov't. or
                                                             Applicant May Appeal
                                                             Decision to Shorelines
                                                             Hearings Board with in
                                                             a 30 Day Appeal Penod
w
w
CO
                   WDOE Permit Authorization
                   or Appeal
           Appeals to
           Shorelines Hearings
           Board
                      Authorization to
                      Commence Activity
Notes*
*1    SEPA checklist must be submitted with application
*2    SEPA requirements must be completed prior to local permit decisions
*3    WDOE may approve or appeal substantial development permit to SHE.  WDOE
      may approve, condition, or deny a CUP or Variance application.
                                           C-9

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State Environmental Policy Act

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                              PURPOSE OF SEPA
The State Environmental Policy Act (SEPA). Chapter 43.21C RCW, is intended
to ensure that environmental values are considered (in addition to
technical and economic considerations) by state and local government
officials when making decisions.  SEPA contains specific policies and
goals which apply to actions at all levels of government within the state,
except the judiciary and state legislature.  The SEPA Rules (Chapter
197-11 WAC) were adopted to implement SEPA and to establish uniform
requirements and guidance for compliance with SEPA.

SEPA has four primary purposes as listed in Chapter 43.21C RCW:

     1.  To declare a state policy which will encourage
         productive and enjoyable harmony between people and
         their environment,

     2.  To promote efforts which will prevent or eliminate
         damage to the environment and biosphere,

     3.  To stimulate the health and welfare of people, and

     4.  To enrich the understanding of ecological systems and
         natural resources important to the state and the
         nation.

The SEPA process starts when someone submits a permit application to an
agency or when an agency proposes to take some official action.  Prior to
taking any action (issuing permits, approvals, etc.) on a nonexempt
project, agencies must follow specific procedures to assure that
appropriate consideration has been given to the environment.  The severity
of potential environmental impacts associated with a proposed project will
determine whether an environmental impact statement is required.  If an
environmental impact statement is not issued, a determination of
nonsignificance must, be issued.

After completion of the environmental impact statement or determination of
nonsignificance, agencies may act upon the permit application or other
approval required for the project.  Administrative or legal appeals and
challenges concerning SEPA compliance must be linked to a specific
governmental action (e.g., permit) and be brought in a timely manner.

Early Coordination

One of the primary purposes of SEPA is to evaluate the environmental
impacts of a proposed project and identify methods to reduce the impacts.
If there appear to be major problems with a proposal, the lead agency
                                  C-10

-------
should discuss the project with the applicant as early as possible and
explain the areas of difficulty.  If the lead agency is aware that major
changes will be required to allow a project to proceed, the applicant
should be given the opportunity to withdraw the project prior to complying
with SEPA.

A handy tool which has worked for us is the early interagency meeting with
the applicant.  This can be done either before SEPA begins, during
checklist review, or during scoping.  Applicants with whom we have worked
have responded quite positively to an early thorough discussion of issues,
options, and time frames.  Feasibility and critical issues can be
identified, discussed and, in many cases,  worked out before the process
begins.  The applicant can then make informed and reasoned choices about
how to proceed.

Public Involvement

The goal of SEPA is much more than simply procedural.  Projects are
modified, mitigation is accommodated and the public is made to feel more
comfortable in a successful SEPA process.   The latter function cannot be
achieved by performing the process in a "black box".  Indeed, public
involvement has been found to be the key to preventing public suspicion of
the process.  Repeated efforts should be made to involve the public.
Whereas scoping and DEIS review have mandated public interfaces, we have
found additional efforts very useful.  Agency/citizen committees which
meet several times with the applicant and the lead agency can give
everyone a feeling for the complexities of the issues and an opportunity
to participate in the environmental analysis.  Informal public meetings
have also proved useful.

Whatever the form, an open and fluid public involvement process is a key
to avoiding polarized positions which can lead to needless and unpleasant
conflict.

Even when there are strong conflicting differences regarding a decision,
SEPA through its public involvement process can provide (at a minimum) a
reasonably equal level of understanding of the issues and facts
surrounding a proposal.
                                  C-11

-------
                                                     SEPA Rules
   WAC 197-11-510   Public  notice. (1) When these
 rules require  notice to be given under this section, the
 lead agency must use  reasonable methods to inform the
 public and other agencies that an environmental docu-
 ment is being prepared or is available and  that public
 hearing(s), if any, will be held. The agency may use its
 existing notice procedures.
   Examples of reasonable methods to inform the public
 are:
   (a) Posting the property, for site-specific proposals;
   (b) Publishing notice in a newspaper of general circu-
 lation in the county, city, or general ana where the pro-
 posal is located;
   (c) Notifying public or private groups with known in-
 terest  in a certain proposal or in  the  type of  proposal
 being considered;
   (d) Notifying the news media;
   (e) Placing  notices  in appropriate regional, neighbor-
 hood, ethnic, or trade journals; and/or
   (0  Publishing  notice  in  agency newsletters and/or
 sending notice to agency mailing lists (either general
 lists or lists for specific proposals or subject areas).
  (2) Each agency shall specify its method of public no-
tice in  its SEPA  procedures. 197-11-904 and 197-11-
906. If an agency does  not specify its method of public
notice or does  not adopt SEPA procedures, the agency
shall use methods (a) and (b) in subsection (I).
  (3) Documents which are  required to be sent to the
department  of  ecology  under these rules will  be pub-
lished in the SEPA REGISTER, which will also consti-
tute a form of public notice. However, publication in the
SEPA REGISTER shall not, in itself, meet compliance
with this section.

  WAC  197-11-535  Public hearings and meetings. (1)
If a  public hearing on the proposal is held under some
other requirement of law, such hearing shall be  open  to
consideration of the environmental impact of the pro-
posal, together with any environmental document that is
available. This does  not require extension of the com-
ment periods for environmental documents.
  (2) In all other cases a public hearing on the environ-
mental impact  of a proposal shall be held whenever one
or more of the  following situations occur:
  (a) The lead agency determines, in its sole discretion,
that a  public hearing would assist it in meeting its  re-
sponsibility  to  implement the purposes and  policies  of
SEPA and  these rules;  or
  (b) When fifty or more  persons residing within the
jurisdiction  of  the lead  agency, or  who  would be ad-
versely affected by the  environmental impact of the pro-
posal, make written  request to  the lead agency within
thirty days of issuance  of the draft EIS; or
  (c) When two or more agencies with jurisdiction over
a proposal  make  written  request  to  the lead  agency
within thirty days of the issuance of the draft EIS.
  (3) Whenever a public hearing is held under subsec-
tion (2) of this section, it shall occur no earlier than  fif-
teen days from the date the draft EIS is issued, nor later
than fifty days from its issuance. Notice  shall  be given
under  197-11-502(6)  and  197-11-510 and  may  be
combined with  other agency notice.
  (4) If a public  hearing  is required under this chapter,
it shall be open to discussion of all  environmental docu-
ments and any written comments that have been  re-
ceived by the lead agency prior to the hearing. A copy of
the environmental document shall  be available at  the
public hearing.
                                                                                   Part Five—197-11-560
  (5) Comments at public hearings should be as specific
as possible (see 197-11-550).
  (6) Agencies and their designees  may hold  informal
public meetings or  workshops. Such  gatherings may be
more flexible than public hearings and are not subject to
the above  notice and similar requirements for  public
hearings.

  WAC  197-11-545  Effect of no comment.  (1) Con-
sulted agencies. If a consulted agency does not respond
with written comments within the time periods for com-
menting on environmental documents, the  lead agency
may assume that the consulted agency has no informa-
tion relating to the potential  impact of the proposal as it
relates to  the consulted agency's  jurisdiction or soecial
expertise.  Any consulted agency  that  Tails  to submit
substantive information to the lead agency in response to
a draft EIS is  thereafter barred  from alleging any de-
fects in the lead agency's compliance with  Part Four of
these rules.
   (2) Other agencies and the public. Lack of comment
by other agencies or members of the public on environ-
mental documents,  within the time periods specified by
these rules, shall be construed as lack of objection to the
environmental analysis, if the requirements of 197-11-
510 are met.

  WAC  197-11-550  Specificity of  comments. (I)
Comments on an EIS, DNS, scoping notice or proposal
shall be  as specific  as possible and  may address  either
the  adequacy of the  environmental document or the
merits of the alternatives discussed or both.
   (2) Commenters shall briefly describe the  nature of
any  documents referenced in their comments, indicating
the material's relevance, and should indicate where the
material  can be reviewed or  obtained.
  (3) Methodology. When  an  agency criticizes  a  lead
agency's   predictive  methodology,  the  commenting
agency should  describe,  when  possible, the alternative
methodology which it prefers and why.
  (4) Additional information. A consulted  agency shall
specify in  its comments whether  it needs additional in-
formation  to fulfill  other applicable environmental re-
views or consultation requirements and what information
it needs, to the extent permitted by the details available
on the proposal.
  (5) Mitigation measures.  When an agency with juris-
diction objects to or expresses concerns about a proposal,
it shall specify the mitigation measures,  if any  are possi-
ble, it considers necessary to allow an agency to grant or
approve applicable licenses.
  (6) Comments by other agencies.  Commenting agen-
cies  that are not consulted agencies shall specify any ad-
ditional   information  or  mitigation   measures  the
commenting  agency believes are necessary or  desirable
to satisfy its concerns.
   (7) Citizen  comments.  Recognizing their  generally
more  limited resources,  members of the  public shall
make their comments as specific as possible and are en-
couraged to comment on methodology needed,  additional
information, and mitigation measures in the manner in-
dicated in this section.
   (8) An agency  shall  consider and  may respond  to
comments as the agency deems appropriate; the require-
ments for responding in a FEIS  shall be met (197-11-
560).
                                                     C-12

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                                                     SEPA PROCESS

                         FROM SEPA  RULES,  CHAPTER  197-11; NUMBERS  LISTED  REFER  TO  WAC  SECTIONS
 INFORMATION INCOMPLETE;  RETURN
  TO APPLICANT  FOR  COMPLETION
 NOT LEAD AGENCY;  SEND  COPY  OF
   APPLICATION TO  LEAD  AGENCY
       WITH COVER  LETTER
                                             PERMIT APPLICATION  RECEIVED;
                                             PLAN OR  REGULATION  DEVELOPED
                           REVIEW  FOR COMPLETENESS
                           AND  EXEMPTION  TO  SEPA
                                                            060   305  800
                           DETERMINE  LEAD AGENCY
                                       735D  050  924
           PROJECT EXEMPT; SEPA SATISFIED
                                    LEAD  AGENCY; APPLICANT COMPLETES ENVIRONMENTAL
                                       CHECKLIST WITH/WITHOUT AGENCY ASSISTANCE
 IF RESPONSE TO "REQUEST  FOR EARLY
   NOTICE" INDICATES  SIGNIFICANT
 DETERMINATION POSSIBLE,  APPLICANT
     MAY ALTER PROPOSAL TO ADD
        MITIGATING MEASURES
                             350
                                                 EVALUATE CHECKLIST
                                                              060
                                                                  TJ50
                                                                        100  330  335
                                                IF REQUESTED, RESPOND TO
                                              TO REQUEST  FOR EARLY NOTICE
                                                                   350
                                             MAKE THRESHOLD DETERMINATION
                                                            "7J5D  BSD  3TO  330
        IF THERE ARE PROBABLE SIGNIFICANT
                 ADVERSE IMPACTS
             ISSUE DETERMINATION OF
           SIGNIFICANCE/SCOPING NOTICE
PREPARE DRAFT EIS
  CIRCULATE  DS/SCOPINC NOTICE;
I  GIVE "PUBLIC NOTICE" (ALLOW
I      21  DAYS  FOR  WRITTEN
.     COMMENT;  FOR  EXPANDED
'  SCOPING ALLOW UP TO 30 DAYS)
080  400  40Z  420-44
                                    35tJ4084TU
I        DISTRIBUTE DEIS FOR 30 DAY  COMMENT
         PERIOD; "PUBLIC NOTICE" REQUIRED

455
REVIEW, EVALUATE, RESPOND TO
DEIS COMMENTS; PREPARE FINAL EIS
                                               IF THERE ARE NO PROBABLE SIGNIFICANT
                                               ADVERSE  IMPACTS,  ISSUE DETERMINATION
                                                       OF NONSICNIFICANCE
                                                       PROPOSAL DOES NOT  INVOLVE
                                                          ANOTHER AGENCY  WITH
                                                       JURISDICTION, "MITIGATED"
                                                        DNS OR A DNS ISSUED AFTER
                                                               DS WITHDRAWN
                                                                          340
                                                           AGENCY DECISION
                                   560
                 DISTRIBUTE FEIS
                            46O
                   WAIT 7 DAYS
                            460
                [ AGENCY DECISION |
                        0703"9TP 660
                                                      RECEIVE,  EVALUATE  COMMENTS
                                          070  39O
                                            660
070  390
  660
                                                                                             (JBO
                PROPOSAL DOES INVOLVE
                 ANOTHER AGENCY WITH
               JURISDICTION, 'NITIGATED"
                 DNS,  OR A DNS ISSUED
                  AFTER DS WITHDRAWN
                                                                    (1) CIRCULATE  DNS  FOR  15  DAY
                                                                       COMMENT  PERIOD
                                                                    (2) SEND  COPY  OF DNS TO
                                                                       ECOLOGY  ENVIRONMENTAL
                                                                       REVIEW
                                                                    (3) GIVE  "PUBLIC NOTICE"  AS
                                                                       SPECIFIED  IN PROCEDURES
                                                                                                              340
                                                     C-13

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Model Toxics Control Act

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 PART  I—OVERALL  CLEANUP PROCESS

  VAC  173-340-100  PURPOSE.

  This  chapter  is promulgated  under the Model Toxics  Control  Act.   It  establishes
 administrative processes and standards to identify, investigate,  and cleanup facilities
 where  hazardous substances have  come  to be  located.   It defines  the  role of the
 department and  encourages public involvement in decision making at these  facilities.

  The goal of this chapter is to implement the  policy declared by chapter  70.1050 RCW.
 This chapter provides  a workable process to  accomplish effective  and  expeditious
 cleanups  in a manner that protects human health and the environment.   This chapter is
 primarily intended  to   address  releases of  hazardous  substances  caused  by  past
 activities although its provisions  may  be applied to potential and ongoing  releases
 of hazardous  substances from current activities.

  WAG  173-340-110  APPLICABILITY.

  (1) This chapter  shall apply to  all  facilities where there has been a release or
 threatened release  of a hazardous  substances  that may pose a threat to human health
 or the environment.  Under this  chapter, the department may require or take those
 actions necessary to investigate and remedy these releases.

  (2) Nothing herein  shall  be  construed to diminish  the department's  authority to
 address a release or  threatened  release under other applicable laws or regulations.
 The  cleanup  process and procedures under this chapter  and under other  laws may be
 combined.  The  department may  initiate  a remedial action under this chapter and may
 upon further analysis determine that another lav is more appropriate, or vice versa.

  (3) If a hazardous substance remains at a facility after actions have been completed
 under  other applicable  lavs or regulations,  the department may  apply this  chapter to
 protect human health or the environment.

 AMENDATORY  SECTION  (Amending VSR 90-08-086, filed 4/3/90, effective 5/4/90)

  WAG  173-340-120 OVERVIEW.

  (1) Purpose.  This section provides an overview of the cleanup process that typically
 will occur at a site where a release of a hazardous substance has been  discovered.
 If there are any inconsistencies  between this section and any  specifically referenced
 sections, the referenced section shall govern.

  (2) Site discovery.  Sit*  discovery  includes:

     (a)  Release reporting.   A  reporting program  is  established to help  identify
 potential hazardous vast* sites.   Owners and operators who know of or discover a
 release of a hazardous substance due to past  activities  must report the release to the
 department within ninety days of discovery,  under WAG  173-340-300.   Most  current
 releases of hazardous substances  must be reported to the department under the state's
hazardous waste underground storage tank, or water quality laws.  The term "hazardous
 substance" includes a broad rang* of substances as  defined by chapter 70.105D RCW.

     (b)  Initial investigation.    Within ninety days of  learning  of  a hazardous
 substance release,   the  department will  conduct an initial investigation  of  the site
under VAC 173-340-310.   For sites  that may need further remedial action,  an early
notice letter will be sent to the  owner and operator informing  them of the  department's
decision.

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  (3) Site priorities.  Priorities for further remedial action are set by the following
process:

     (a)  Site hazard  assessment.   Based  on the  results  of the initial investigation,
a site hazard assessment will be performed if necessary,  under WAC 173-340-320.  The
purpose of the site  hazard assessment is  to  gather  information to confirm whether a
release has occurred and to enable the department to evaluate the relative potential
hazard posed by  the  release.   If  the department decides that no  further action is
required, it will notify the public of that decision through the site register.

     (b)  Hazardous  sites list.   The  department will maintain  a list of  sites that
require further remedial action.   Sites  will be after the completion of a site hazard
assessment.  Sites placed on  the list will be ranked using  the  department's hazard
ranking method.  The  department may remove a site  from the hazardous sites list if the
cleanup action at the site has achieved the cleanup standards and all remedial actions
except confirmational monitoring have been completed.  See WAG 173-340-330.

     (c)  Biennial program  report.   Every even-numbered year,  the department  will
prepare a biennial program report for the legislature. The hazard ranking, along with
other factors,  will be used in this report to identify  the projects and expenditures
recommended for appropriation.  See VAC 173-340-340.

  (4) Detailed  site investigations and cleanup decisions.  The following steps will be
taken to ensure that the proper method of cleanup is chosen for the site.

     (a)   Remedial    investigation  and   feasibility  study.     A  state   remedial
investigation/feasibility  study  will  be  performed  at  ranked  sites  under  VAC
173-340-350.  The state remedial investigation/ feasibility study defines the extent
of the problems at the site and evaluates alternative cleanup actions.

     (b)  Selection  of  cleanup action.    The department will  evaluate the  remedial
investigation/feasibility study, establish cleanup levels and the point or points at
which they must be complied with in accordance with the procedures provided for in UAC
173-340-700 through  173-340-760 and select a cleanup action  that  will protect human
health and the  environment and meet the other requirements of VAC 173-340-360.  At some
sites, restrictions on  the use of the land and resources (institutional controls) will
be required to insure continued protection of human health and the environment.  See
VAC 173-340-440.  The cleanup  action will  be set  forth in a draft cleanup action plan
that addresses  cleanup requirements for hazardous  substances at the site.  After public
comment  on the  draft  plan,  a  final  cleanup action  plan  will  be  issued by  the
department.    (See  VAC  173-340-700  for  additional overview discussion of  these
requirements.)

  (5)  Site cleanup.   Once the  appropriate cleanup action has been selected for the
site, the actual cleanup will be performed.

     (a)  Cleanup  actions.   VAC  173-340-400 describes the  design and  construction
requirements for implementing the cleanup action plan.

     (b) Compliance monitoring and review.   The cleanup action must include compliance
monitoring  under VAC  173-340-410  and  in some  cases  periodic  review under  VAC
173-340-420 to ensure the long-term effectiveness of the cleanup action.

  (6) Interim actions.   Under  certain  conditions  it  may be appropriate to take early
actions at a site prior to completing the process  described in subsections  (2) through
(5) of this section.   VAC 173-340-430 describes when it is appropriate to take these
early or interim actions and the requirements for such actions.


                                     C-15

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  (7) Leaking  underground storage tanks.   Underground storage tank  (UST) owners  and
underground storage tank operators regulated under chapter 90,76  ROW are  required to
perform specific actions in addition to what other site owners and operators  would do
under this chapter.   Such additional actions include reporting of a confirmed release
within  twenty-four hours, follow-up investigation, free product removal and immediate
assessment of the threat to human health and the environment at  the site,  A written
report describing the site and the actions taken must be submitted within ninety days
of  release  confirmation.   Depending on  the  results of  these  actions, additional
remedial  actions may  be  required.   VAC  173-340-450 describes   these  and other
requirements for leaking underground storage tanks.

  (8) Procedures for  conducting remedial actions.

     (a)  Remedial action agreements.  The department has  authority  to  take  remedial
actions  or  to order persons  to  conduct  remedial  actions  under WAG  173-340-510  and
173-340-540.   However,  the department encourages agreements for  investigations  and
cleanups  in appropriate cases.   These  agreements can be agreed orders or  consent
degrees  reached under the procedures of VAC 173-340-520 and 173-340-530.

     (b)  Independent  remedial actions.   Persons  may decide to perform investigations
and cleanups without department approval under this chapter.  The department  will  use
the appropriate requirements contained herein in its evaluation of the adequacy of  any
independent remedial actions performed.  Nothing  in this chapter prohibits persons from
performing  such actions  before the department is  ready to act at  the site;  however,
all interim  and cleanup  actions  must  be  reported to  the department  under   VAC
173-340-300.   Furthermore,  independent  remedial actions are done  at the  potentially
liable person's own  risk and the department may take or  require  additional  remedial
actions  at  these sites  at  any time.   (See VAC 173-340-510.)

     (c)  Public participation.  The public will  receive notice and an opportunity to
comment  on most of the  steps  in  the  cleanup  process.    At many sites,   a  public
participation plan will be prepared to provide opportunities for more extensive public
involvement in the cleanup  process.
These requirements are  described in VAC 173-340-600.
 PART VI—PUBLIC PARTICIPATION

  WAG 173-340-COO   PUBLIC NOTICE AND PARTICIPATION.

  (1) Purpose.    Public  participation  is  an  integral  part  of  the  department's
 responsibilities under the Model  Toxics Control Act.   The  department's  goal is to
 provide   the   public  with  timely  information  and  meaningful  opportunities  for
 participation which are commensurate with each site.  The department will meet this
 goal through  a public participation program  that includes:   The early planning and
 development of a  site-specific  public participation plan;  the  provision of public
 notices;  a site  register; public  meetings or  hearings;  and the  participation of
 regional citizens'  advisory committees.
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 (2) Criteria.  In order  to promote effective and meaningful public participation, the
department may determine that public participation opportunities  in addition to those
specifically  required  by chapter 70.105D RCW  or this chapter,  are  appropriate and
should be provided.  In making this determination, the department may consider:  (a)
Known or potential risks to human health and the environment  that could be avoided or
reduced by providing information to the public;

     (b) Public  concerns  about the facility.

     (c)  The need  to  contact the public in order  to gather  information  about the
facility;

     (d) The extent to which the public's opportunity to affect subsequent departmental
decisions at the facility may be limited or foreclosed in the future;

     (e) The need to prevent  disclosure of confidential,  unverified,  or enforcement-
sensitive information;

     (f) The routine nature of the contemplated  remedial action;  and

     (g) Any other  factors  as determined by  the  department.

  (3)  Public notice.   Whenever public notice is required by Chapter 70.105D RCW,  the
department shall at a minimum provide or require notice as described in this section
except as specified for the biennial report in WAG 173-340-340.

     (a) Request.   Notice shall -be mailed to persons who have made a timely request.
A request for notice is timely if received prior  to or during the public comment period
for the current phase of remedial action at the facility.  However,  the receipt of a
request for notice shall  not require the  department  to extend the  comment period
associated with the notice.

     (b) Mail.   Notice shall be mailed  to persons who reside within the potentially
affected vicinity  of  the proposed action.   The potentially  affected vicinity shall
include all property  adjoining  the  site  and  any  other  area that  the  department
determines to be directly affected by the proposed action.

     (c) Newspaper  publication.   Notice of  the  proposed  action shall be published in
the newspaper of largest circulation in the  city or county of the proposed action, by
one  or  more  of the  following  methods:   Display  ad;  legal  notice;  or any other
appropriate format, as determined by the department.

     (d) Other news media.  Notice of the proposed action shall be mailed to any other
news media  which the department determines  to  be appropriate.  The department may
consider how a medium compares with  the newspaper of  largest circulation in terms of:
Audience reached; timeliness; adequacy in conveying the particular information in the
notice;  cost; or other relevant factors.

     (e) Comment periods.  All public notices shall indicate the public comment period
on the proposed action.  Unless stated otherwise,  comment periods shall be for thirty
days at a minimum.

     (f) Combining  public comment requirements.   Whenever reasonable, the department
shall consolidate public notice and opportunities for public comment under this chapter
with public notice and comment requirements under other laws and regulations.

  (4) Public meetings.  During any comment period announced by a public notice issued
under this chapter, if ten or more persons request a  public meeting on the subject of

                                    C-17

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the  public notice, the  department shall hold  a  public meeting for  the  purpose of
receiving  comments.

  (5) Additional methods.  In addition to "public  notice" required by chapter 70.105D
RCW, or this chapter, the  department  may use any  of the following methods to provide
information to  the public:

     (a) Press  releases;

     (b) Fact sheets;

     (c) Public meetings

     (d) Publications;

     (e) Personal contact by department employees;

     (f) Posting signs at the facility;

     (g) Notice in the site register;

     (h) Any other methods  as determined by  the  department.

  (6) Site register.   The  department shall regularly  publish  and maintain  a  site
register,   giving notice  of  the following:

     (a) Determinations of  no further  action under VAC 173-340-320;

     (b) Results of site  hazard rankings;

     (c) Availability of  annual and biennial reports;  (d)  Issuance  of  enforcement
orders, agreed  orders, or proposed consent decrees;

     (e) Public meetings  or hearings;

     (f)  Scoping  notice  of  department-conducted  state  remedial  investigation/
feasibility study;

     (g) Availability  of state remedial  investigation/feasibility  study reports and
draft and  final cleanup plans;

     (h) Change  in site status or  placing sites on or removing sites  from the hazardous
sites list under VAC 173-340-330;

     (i) Availability of  engineering design  reports under VAC 173-340-400;

     (J) Schedules  developed under  VAC 173-340-140;

     (k) Reports of independent cleanup actions  received under VAC  173-340-300;

     (1) Commencement of negotiations or discussions under VAC 173-340-520 and 173-340-
530;

     (m) Deadline extensions or missed deadlines under VAC  173-340-140;  and

     (n) Any other  notice that the  department deems appropriate  for inclusion.
                                       ,C-18

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  (7)  Evaluation.   As  part of  requiring or  conducting a  remedial action  at any
facility, the department  shall  evaluate  public participation needs at the facility,
including an  identification of  the  potentially affected vicinity  for  the remedial
action.

  (8)  Public participation plans.

     (a)  Scope.   The public  participation plans  required by -this section are intended
to encourage a coordinated  and effective public involvement tailored to the public's
needs at a  particular  facility.  The scope  of a plan shall be commensurate with the
nature of the proposed remedial  actions;  the  level  of public concern;  and the risks
posed by the facility.

     (b)  Early planning encouraged.   In order  to  develop an appropriate  plan,  the
department or potentially  liable person (if submitting a plan to the department) should
engage in an early planning process  to assess the public participation needs at the
facility.   This process  may  include identifying  and conferring with  individuals,
community   groups,  local   governments,   tribes,  public  agencies,   or  any  other
organizations that may have an interest in or knowledge of the facility.

     (c)  Plan development.   The  department shall develop  the  plan,  or work  with the
potentially liable  person  to  develop the  plan.    If  a plan already exists  for  a
facility, the department shall consider whether the existing plan  is still appropriate,
or whether  the plan should  be amended.   For example,  a plan originally developed to
address a state  remedial  investigation/  feasibility study may need to be amended to
address implementation phases.

     (d) Plans required.  As part of requiring  or conducting a remedial action, except
emergency action,  at  any site  that has  been  assigned a hazard ranking  score,  the
department shall ensure that a public participation plan is developed and implemented.
The department may also require the development of a  public  participation plan for
facilities which have  not been assigned  a hazard ranking score  as  part  of an agreed
order or consent decree with a potentially liable person,  (e) Plan as part of order
or decree.   A  potentially liable person will ordinarily be required to  submit  a
proposed public  participation plan as part  of its request for an agreed  order or a
consent decree.   If a plan already exists for  the  facility,  the  potentially liable
person may either submit the existing plan with any proposed amendments or submit an
entirely new proposed  plan.  The proposed plan may be revised  during  the course of
discussions or negotiations on the agreed order or consent decree.   The final public
participation plan may become part of the agreed order or consent decree.

     (f) Contents.  The public participation plan shall include the following:

       (i) Applicable public notice requirements and how these will be met, including:
When public notice will occur;  the length of  the comment  periods  accompanying each
notice; the potentially affected vicinity and any other areas to be provided notice,
to the extent known.
       (ii) Information repositories. The plan should identify at least one location
where the public  can review information about the remedial action.  Multiple locations
may be appropriate.
       (iii) Methods of identifying the public's concerns.  Such methods may include:
Interviews;   questionnaires;  meetings;   contacts  with  community  groups  or  other
organizations which have an  interest in the site; establishing citizen advisory groups
for  sites;  or obtaining  advice from the  appropriate regional citizens'  advisory
committee.
       (iv) Methods of addressing the public's concerns and conveying information to
the public.   These may include  any of the methods  listed in subsection (5) of this
section.

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        (v) Coordination of public participation requirements.  The plan should identify
any public participation requirements of other applicable federal, state or local lavs,
and address how  such  requirements can  be  coordinated.   For  example,  if  Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) applies to the proposed
action,  the plan should  explain how CERCLA and  this  chapter's public comment periods
will be  coordinated.
        (vi) Amendments to  the plan.  The plan should outline the process for amending
the plan.  Any amendments  must  be approved by the  department.
        (vii) Any other elements that the  department  determines  to be appropriate for
inclusion in the final public participation plan.

     (g)  Implementation.    The  department  shall retain approval authority over the
actions  taken by a potentially  liable  person to  implement the plan.

  (9)  Consent decrees.  In addition to any other applicable  public  participation
requirements, the following  shall be required for  consent decrees.

     (a)  A public participation  plan which meets the requirements of subsection  (8) of
this section shall be developed when required by subsection  (8)(d) of this  section.
     (b)  Notice   of  negotiations.   When  the  department  decides  to   proceed with
negotiations it  shall place a  notice  in  the  site  register  advising the public that
negotiations have commenced.  This notice shall include the name of the facility,  a
general  description of the subject of  the  order  and  the deadlines for negotiations.

     (c)  Notice  of proposed  decree.  The  department  shall provide  or require public
notice of proposed consent decree.  The  notice  may be combined with notice of other
documents under  this chapter, such as a cleanup action plan,  or under other  laws.  The
notice shall briefly:

        (i) Identify and  generally describe the  facility;
        (ii) Identify  the person(s) who are parties to  the consent decree;
        (iii) Generally describe the remedial action  proposed  in the proposed consent
decree;
        (iv) Indicate  the date,  place,  and time of  the public  hearing on the proposed
consent  decree;  and
        (v) Invite the public to comment  at the public hearing or  in writing.  The
public comment period shall run for at  least thirty days from the date of the issuance
of the notice.

     (d)  Public hearing.   The department shall hold a public hearing on the proposed
consent decree for the purpose of providing the public with an opportunity to comment.

     (e)  Revisions.    If  the  state  and  the potentially  liable  person  agree  to
substantial changes  to  the  proposed  consent decree,  the  department  shall provide
additional public notice and opportunity  to comment.

     (f)  Extensions.    The  department  shall publish in the next site  register the
extension of deadlines for designated  high priority  sites.

  (10)  Agreed orders.    In  addition to  any  other  applicable  public   participation
requirements, the following shall be required for agreed orders under VAC 173-340-530.

    (a)  Public participation plan.  A plan meeting the requirements  of subsection (8)
of this  section shall be  developed when required by subsection (8)(d) of  this section.

    (b)  Notice  of  discussions.    When   the  department  decides  to   proceed with
discussions it shall  place  a notice in  the site  register  advising the public that


                                       C-20

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discussions have  commenced.   This notice shall include  the  name of the facility,  a
general description of the subject of the order and the deadlines for discussions.

     (c) Notice of agreed orders.   Public notice shall be provided by the department
for any agreed order.   For all agreed orders, notice  shall  be mailed no later  than
three days after the issuance of the agreed order.   For agreed orders covering a state
remedial investigation/feasibility study, the comment period shall be at  least thirty
days and  shall be completed  before  the  agreed order becomes  effective.   For other
agreed orders,  the  agreed  order may  be  effective  before the comment period  is over,
unless the department determines  it is in the public interest to complete the public
comment period prior to  the  effective date  of the agreed order.  The department may
determine that it is in the  public  interest to provide public  notice  prior to the
effective date of any agreed order or to hold a public meeting or hearing on the agreed
order.  This notice shall briefly:

        (i) Identify and  generality describe  the facility;
        (ii) Identify the person(s) who are parties to the order;
        (iii) Generally describe the remedial  action proposed in  the proposed order;
and
        (iv) Invite  the public to  comment on  the proposed order.

     (d) Revisions.   If the department and the potentially liable person  agree to
substantial changes  to  the proposed order,   the department  shall provide additional
public notice  and opportunity to comment,  (e)  Extensions.    The   department shall
publish in  the next site  register the  extension of deadlines  for designated high
priority sites.

  (11)  Enforcement orders.   In addition  to any other applicable public participation
requirements,  the department  shall provide  public notice of all enforcement orders.
Except in the  case  of  emergencies,  notice shall be mailed no  later than three days
after the date of the issuance  of the order.  In emergencies, notice shall be mailed
no later than  ten days after  the  issuance of  the order.

     (a) Contents  of notice.   All  notices shall briefly:

        (i) Identify and  generally describe the facility;
        (ii) Identify the person(s) who are parties to the order;
        (iii) Generally describe the terms of  the proposed order; and


     (b) The  department may  amend the  order  on the  basis  of public comments.   The
department shall provide additional public  notice and opportunity to comment if the
order is substantially changed.

  (12)  State remedial  investigation/feasibility  study.   In  addition to  any other
applicable public participation requirements, the following shall be required during
a state remedial investigation/feasibility study.

     (a)  Scoping.    When   the department   elects  to  perform  a  state   remedial
investigation/feasibility  study,  public notice and an opportunity to comment on the
scope of the state remedial investigation/ feasibility study will be provided.

     (b) Extensions.  The  department shall  publish  in  the  next site  register the
extension of deadlines for designated high priority sites.

     (c) Report.  The  department shall  provide  or  require  public  notice  of state
remedial investigation/feasibility study  reports prepared under WAG 173-340-350.   This
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public notice may be combined with public notice of the draft cleanup action plan.  At
a minimum, public notice  shall briefly:

        (i)  Describe  the  site  and  state remedial  investigation/feasibility study
results;
        (ii) If available, identify the department's selected cleanup action and provide
an explanation for  its  selection;
        (iii)  Invite public comment on the report.   The public comment period shall
extend for at least thirty days from the date of mailing of the notice.

  (13)  Selection of cleanup  actions.    In addition  to any other  applicable public
participation requirements, the department shall:

     (a)  Provide  a notice of availability of draft or final cleanup action plans and
a brief  description of  the proposed or selected alternative in the site register;

     (b)  Provide  public  notice of  the draft cleanup action  plan.  A notice of a draft
cleanup   plan   may   be   combined    with   notice    on   the   state   remedial
investigation/feasibility study.   Notice of a  draft    cleanup  action plan  may be
combined with notice on a draft consent  decree or on an order.  At a minimum, public
notice shall briefly:

        (i) Describe the site;
        (ii)  Identify   the department's  proposed  cleanup action and  provide  an
explanation for  its selection;
        (iii)  Invite public comment  on  the draft  cleanup  action plan.   The public
comment  period shall run for at least thirty days from  the date of issuance of the
public notice.

  (14)  Cleanup action  implementation.    In addition  to any other  applicable public
participation requirements, the following shall  be required  during  cleanup action
implementation.

     (aX Public notice and opportunity to comment on any plans prepared under VAC 173-
340-400  that represent  a  substantial change from the cleanup action plan.

     (b)  When  the  department  conducts   a  cleanup  action,   public notice and  an
opportunity to comment  shall be provided on the engineering design report and notice
shall be given in the site register.

  (IS) Routine cleanup and interim actions. In addition to any  other applicable public
participation requirements, the  following will be required for  routine cleanup actions
and interim actions.

     (a)  Public notice  shall be  provided for any proposed routine cleanup or interim
actions  under VAC 173-340-130 or  173-340-430.   This public notice shall be combined
with public notice  of an  order or  settlement whenever practicable.

     (b)  At a minimum, public  notice  shall briefly:

       (i) Describe the site;
       (ii) Identify the  proposed  action;
       (iii) Identify the likely or planned schedule for the  action;
       (iv) Reference any planning documents prepared  for  the  action;
       (v) Identify department staff who  may be contacted for further information; and

       (vi) Invite  public comment  on the routine  cleanup or interim action.
                                      C-22

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The public comment period shall extend for at least thirty days from the date of the
mailing of notice.

 WAG 173-340-610   REOIOMAL  CITIZENS'  ADVISORY COMMITTEES.

 (1) The department shall establish regional  citizens' advisory committees as part of
a  public  participation  program.   The  regional citizens'  advisory committees  are
intended to promote meaningful and effective public  involvement  in the department's
remedial action program  under  chapter 70.105D  RCW.   The committees will  advise  the
department as  to the concerns of citizens locally and regionally regarding the remedial
actions within each committee's region, with emphasis  on issues that affect the region
as a whole, rather than site-specific concerns.

 (2) Location.  There shall be a regional citizens'  advisory committee representing
each geographic region of the state served by a regional  office of the  department.

 (3) Membership.   At any time, each committee shall have no fewer  than five and no
more than twelve members.  The director shall, no later than July 1, 1990, appoint five
members to each  committee  to  represent  citizens'  interests in  the region.   These
members shall serve three-year  terms that may be renewed at the director's discretion.
These members should represent citizen interests in the  region.

     (a)  The  director may  appoint  up  to  seven  additional members  to  represent
communities that may be  affected by  the  remedial actions within  each region.  These
members shall serve two-year terms that may be  renewed at the director's discretion.

     (b)  At no time  shall more  than twenty-five  percent of the membership  of  any
committee  consist of persons who are  elected or appointed public officials  or their
representatives.

     (c) The department shall  advise  the  public as  to whether any vacancies  exist on
the committees, and shall accept applications from interested citizens.

     (d) The following  persons  shall not be eligible  to serve on any committee:

        (i) Persons whom the department has found are  potentially liable  persons under
WAC 173-340-500 with regard to any facility that is currently the subject of department
investigative, remedial,  or enforcement actions, not  including compliance monitoring;
        (ii) Agents or employees  of such potentially liable persons as described in
(d)(i)  of  this subsection; and
        (iii) Agents or employees of the department.

     (e) A member shall refrain from participating in a committee matter  if that member
for any reason cannot act fairly and in the public interest with regard to that matter.


     (f) The director  may dismiss  a member for  cause  in accordance with the  terms of
the regional citizens' advisory committee charter.

 (4) Meetings.   The  committees  shall meet  at least twice  a  year at  the  regional
offices or elsewhere as  agreed upon  by a committee and the  department.  Appropriate
department staff may  attend  these meetings.  The department shall brief the committees
on the program's major planned and ongoing activities for the year.

     (a) The department and  the committees may  agree  to additional meetings.
                                      C-23

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    (b)  Each committee will  designate  one of  its  members  to serve as  chair.   The
committee chairs shall meet every year with the program manager or his/her designee.

    (c)  All  committee meetings shall be  open to the public.   The department shall
inform the public of committee meetings.

  (5) Resources  to be  allocated to  the committees.

    (a)  The  department shall  determine,  after consulting with  the  committees,  the
amount of staff time  and other department resources  that shall  be available to the
committees for  each biennium.

    (b)  The  department shall  designate  staff  to work  with the committees.

    (c)  Members  shall  be  reimbursed  for  travel  expenses  (as provided  for  in
chapter 43.03 RCW) for any meetings approved by the department.

  (6) Responsibilities.  The  committees  are directed to:

    (a)  Meet at least twice  annually;

    (b)  Inform  citizens within each region as  to the  existence of the committees and
their availability as  a resource;

    (c) Review  the department's biennial program priorities,  and advise the department
of citizen concerns regarding  the program priorities;

    (d)  Advise  the  department on a  timely  basis  of  citizen  concerns  regarding
investigative or remedial activities within each region, and where possible,  suggest
ways in which the department can address those  concerns;

    (e)  Annually prepare  a brief report to the department describing:

       (i) Major citizen concerns that have been brought to the committee's attention
during the past year;
       (ii)  Any committee proposals or  recommendations  to address  these  concerns;
       (iii)  The committee's  plans for  the coming year;  and
       (iv)  Any other information or issues which the committee believes appropriate
for inclusion.

  (7)  The committees  are  encouraged to work  with  the department  and  the  public to
develop additional committee goals or responsibilities.
                                        C-24

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      National Pollutant
Discharge Elimination System

-------
                                 Chapter  173-220 WAC
      NATIONAL  POLLUTANT  DISCHARGE ELIMINATION
                           SYSTEM PERMIT PROGRAM
  WAC 173-220-010  Purpose. The purpose of this
chapter is to establish a state permit program, applicable
to the discharge of pollutants and other wastes and ma-
terials to the surface waters of the state, operating under
state law as a part of the National Pollutant Discharge
Elimination System (NPDES) created by section 402 of
the Federal Water  Pollution Control Act  (FWPCA).
Permits issued under this chapter are designed to satisfy
the requirements for discharge permits  under both sec-
tion 402(b) of the FWPCA  and chapter 90.48 RCW.
[Statutory Authority: RCW 90.54.020 and chapter 90-
.48 RCW.  88-22-059 (Order 88-9), § 173-220-010,
filed 11/1/88;  Order DE 74-1, § 173-220-010, filed
2/15/74.]

  WAC 173-220-020  Permit required. No pollutants
shall be discharged  to any surface water of the  state
from a point source,  except as authorized by an Individ- '
ual or  general  permit issued  pursuant to this  chapter.
[Statutory Authority: RCW 90.54.020 and chapter 90-
.48 RCW.  88-22-059 (Order 88-9). f 173-220-020.
filed 11/1/88. Statutory Authority: RCW 90.48.035 and
90.48.260. 82-24-078 (Order DE 82-39). § 173-220-
020, filed  12/1/82;  Order DE 74-1, § 173-220-020.
filed 2/15/74.]
  WAC 173-220-050  Public •otke. (1) Public notice
of every draft permit determination regarding an indi-
vidual permit or general permit, and request for cover-
age by a general permit, shall be circulated in a manner
designed  to  inform interested and potentially affected
persons of the proposed discharge and of the proposed
determination to issue or deny a permit for the proposed
discharge, as follows:
  (a) For individual permits, notice shall be circulated
within the geographical area of the proposed discharge;
such circulation may include any or all of the following,
as directed by the department:
  (i) Posting by the applicant for a period of thirty days
in the post office, public library, and public places of the
municipality  nearest the premises of the applicant in
which the effluent source is located;
  (ii) Posting  by the applicant for  a  period  of thirty
days near the entrance of the applicant's premises and
nearby places;
  (iii)  Publishing by the applicant, at  his own cost
within such time as the director shall prescribe, through
a notice form provided by the department, in major local
newspapers of  general circulation serving the area  in
which the  discharge occurs: Provided, That if an appli-
cant fails to publish notice within thirty days of the time
prescribed  by the director, the  department may publish
the notice and  bill  the applicant  for  the  cost  of
publication;
  (iv)   Publishing   by  the   applicant  of   paid
advertisements;
  (v) Publishing by the  department of news releases or
newsletter  articles.
  (b) For general permits, such circulation shall include
the following:
  (i) Publishing by the department of a notice of intent
to issue a general permit in a major local newspaper of
general circulation in each affected area; and
  (ii) Potting or publishing by the applicant of a request
for coverage by a general permit in accordance with any
or all methods  listed in  (a)(i),  (ii), (iii), (iv), or (v) of
this subsection, as directed by the  department.
  (c) Notice shall be mailed to any person upon request;
and
  (d) The  department shall add the name of any person
upon request to a mailing list to receive copies of notices
within the  state or within a certain geographical area.
  (2) The  department shall provide a period of not less
than thirty days following the date of the public notice
during  which time interested persons may submit their
written views on  a draft permit determination or a re-
quest for coverage by a general permit. All written com-
ments submitted during  the thirty-day comment period
shall be retained by the department and considered in
the formulation of its final determination with respect to
the application. The period  for comment may be ex-
tended  at the discretion of the department.
  (3) The  department shall prepare the contents of the
public notice, which shall, at a minimum, summarize the
following:
  (a) Name, address, phone number of agency issuing
the public  notice;
  (b) Except when unknown in the case of general per-
mit issuance, name and address of each applicant, and if
different, of the facility or activity to be regulated;
  (c) Each applicant's activities or operations which re-
sult in a discharge (e.g.,  municipal waste treatment, steel
manufacturing, drainage from mining activities);
                                                  C-25

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   (d) Except  in  the  case  of general  permit  issuance,
 name of waterway to which each discharge is made and
 the location of each discharge on the waterway, indicat-
 ing whether  such discharge  is  a new or an  existing
 discharge;
   (e) The  tentative determination  to  issue or deny  a
 permit for the discharge;
   (0  Where coverage by a  general permit is replacing a
 current  individual permit,  notice  of termination of the
 individual permit;
   (g) The procedures  for the  formulation of final deter-
 minations, including the thirty-day  comment period re-
 quired by subsection (2) of this section  and any other
 means by which interested  persons may comment upon
 those determinations; and
   (h) Address and phone number of state premises  at
 which  interested  persons   may  obtain   further
 information.
   (4) The department shall provide copies of permit ap-
 plications, draft permit determinations, requests for cov-
 erage, and general permits upon request.
   (5) The department  shall  notify  the  applicant and
 persons  who  have submitted written comments or re-
 quested  notice of the  final  permit decision. This notifi-
 cation shall include response  to comments received and
 reference to the procedures for contesting the decision.
 [Statutory  Authority:  RCW 90.54.020 and chapter 90-
 .48 RCW. 88-22-059 (Order  88-9),  §  173-220-050,
 filed 11/1/88. Statutory Authority: RCW 90.48.035 and
 90.48.260.  82-24-078 (Order DE 82-39). § 173-220-
 050, filed 12/1/82; Order  DE 76-20, § 173-220-050.
 filed  5/19/76;   Order  74-7,  §  173-220-050,   filed
 5/1/74; Order   DE  74-1,  §  173-220-050,   filed
 2/15/74.]

  WAC  173-220-060   Fact sheets.  (1)  The  depart-
ment shall prepare a fact sheet for every draft  permit
determination  regarding  major dischargers, minor dis-
chargers, and general permits.  Such fact sheets shall, at
a minimum, summarize the following:
  (a) The type of facility or  activity which is the subject
of the application;
  (b) The location of the discharge  in the form of a
sketch or detailed description;
  (c) The type and quantity of the discharge, including
at least the following:
  (i) The rate or frequency of the proposed discharge;
  (ii) For thermal discharges,  the average summer and
winter temperatures; and
  (iii) The  average discharge  in  pounds  per day, or
other appropriate  units,  of any  pollutants which  are
present in significant quantities or  which are subject to
limitations or prohibition under RCW 90.48.010, 90.52-
.040, 90.54.020 and sections 301, 302, 306, or 307 of the
FWPCA  and regulations published thereunder;
  (d) The conditions in the proposed permit;
  (e) The legal and technical grounds for the draft per-
mit determination, including an explanation of how con-
ditions meet  both the technology-based  and water
quality-based requirements of the FWPCA and chapters
90.48. 90.52, and 90.54 RCW;
  (0 The effluent standards and limitations applied to
the proposed discharge;
  (g) The applicable water quality standards, including
identification of the uses for which receiving waters have
been classified;
  (h) How the draft permit  addresses use or disposal of
residual solids generated by wastewater treatment; and       _
                                                    Ozb
    (i) The procedures for the formulation of final deter-
 minations (in more detailed form than that given in  the
 public notice) including:
    (i) The thirty-day comment period required by WAC
 173-220-050(2);
   (ii) Procedures for requesting a public hearing and the
 nature thereof; and
   (iii) Any other procedures  by  which the public  may
 participate  in   the   formulation   of   the   final
 determinations.
   (2)  The department shall send  a  fact sheet to the ap-
 plicant and, upon request, to any other person.
   (3)  The department shall add the name of any person
 upon request to a mailing list to receive copies of fact
 sheets. [Statutory Authority: RCW  90.54.020 and chap-
 ter 90.48 RCW.  88-22-059 (Order 88-9), § 173-220-
 060,  filed  11/1/88. Statutory Authority:  Chapter 43-
 .21A RCW. 86-06-040 (Order 86-03), § 173-220-060,
 filed 3/4/86. Statutory Authority: RCW 90.48.035 and
 90.48.260. 82-24-078  (Order DE 82-39), § 173-220-
 060,  filed  12/1/82; Order  DE  74-1. § 173-220-060,
 filed 2/15/74.]

   WAC 173-220-070   Notice  to other  government
 agencies. The department shall notify other appropriate
 government agencies of each draft permit determination
 or request  for coverage and shall provide such  agencies
 an opportunity to submit their written views and recom-
 mendations. Such  notification   shall  include  the
 following:
   (1)  Unless the regional  administrator has agreed to
 waive  review, transmission of an application, fact sheet,
 and draft permit  to the regional administrator for com-
 ment or objection within thirty days  (ninety days for
 general permits),  or a longer period if requested up  to a
 maximum of ninety days.
  (2) At the time of issuance  of public notice pursuant
 to WAC 173-220-050, transmission of the public notice
 to any other states whose waters may be affected by the
 issuance of a permit.  Each affected state  shall be af-
 forded an  opportunity to submit written recommenda-
 tions  to  the  department  and   to  the  regional
 administrator which the department  may incorporate
 into the permit if issued. Should the department fail to
 incorporate any written recommendations thus received,
 it shall provide to the affected  state  or states (and to the
 regional administrator) a written explanation of its  rea-
 sons  for  failing  to  accept  any  of  the  written
 recommendations.
  (3) Unless waived by the respective agency, the public
 notice shall be sent to the  appropriate district  engineer
of the  Army Corps of Engineers, the United States Fish
and  Wildlife Service,  the  National  Marine  Fisheries
Service, the state  departments of fisheries, natural re-
sources, wildlife, and social  and health services, the ar-
chaeology and historic  preservation office, the agency
 responsible for the preparation of an approved plan  pur-
suant to section  208(b) of the FWPCA, applicable In-
dian  tribes and  any  other  applicable  government
agencies.
  (4) A copy of any written agreement between the de-
 partment and an  agency identified  in subsection (3) of
this section which waives the receipt of public notices
shall  be  forwarded  to  the  regional administrator  and
shall be made available to the public for inspection and
copying.

-------
  (5) Copies of public  notices  shall be mailed to any
other federal, state, or local agency, Indian tribe or any
affected country, upon request. Such agencies shall have
an opportunity to respond, comment, or request a public
hearing pursuant  to  WAC  173-220-090.  [Statutory
Authority:  ROW 90.54.020 and chapter 90.48 RCW.
88-22-059  (Order  88-9),   §  173-220-070.  filed
11/1/88. Statutory Authority: RCW 90.48.035 and 90-
.48.260. 82-24-078 (Order DE 82-39). § 173-220-070,
filed  12/1/82;  Order DE 74-1, §  173-220-070. filed
2/15/74.]

  WAC  173-220-080   Public  access to information.
(1) In accordance with chapter 42.17 RCW. the depart-
ment shall make  records relating  to NPDES  permits
available to the public for inspection and copying.
  (2) The department  shall protect any information
(other than information on the effluent) contained in its
NPDES permit records  as confidential upon a showing
by  any person  that such information, if made public,
would divulge methods or processes  entitled to protection
as trade secrets of such person.
  (3) Any  information  accorded  confidential status.
whether or not contained in an application form, shall be
disclosed, upon request, to the regional administrator.
  (4) The department shall provide facilities for the in-
spection of information relating to  NPDES permits and
shall  insure that employees honor requests for such in-
spection  promptly without undue  requirements  or  re-
strictions. The department shall either (a) insure that a
machine or device for the copying  of papers and docu-
ments is available for a reasonable  fee, or (b) otherwise
provide for or coordinate with copying facilities or ser-
vices such that  requests for  copies  of  nonconfidential
documents may be honored  promptly.  [Statutory Au-
thority: RCW 90.54.020 and  chapter 90.48 RCW. 88-
22-059 (Order 88-9), §  173-220-080, filed 11/1/88.
Statutory Authority:  RCW 90.48.035 and  90.48.260.
82-24-078 (Order DE  82-39), §  173-220-080, filed
12/1/82;  Order  DE  74-1,  $   173-220-080,  filed
2/15/74.]

  WAC  173-220-090   Pvblk hewtafs. The applicant.
any affected state, any  affected interstate agency, any
affected country, the regional administrator, or any in-
terested agency or person may request a public hearing
with respect to a draft permit determination or request
for coverage by a general permit. Any such request for a
public hearing shall be Tiled within the thirty-day period
prescribed in WAC 173-220-050(2) and shall indicate
the interest of the party Tiling such request and the rea-
sons why a hearing is warranted. The department shall
hold  a hearing  if it determines there is a  significant
public interest. Instances of doubt will be resolved in fa-
vor of holding the hearing. Any hearing brought pursu-
ant to this subsection shall be held at a time and place
deemed appropriate by the department.  [Statutory Au-
thority: RCW 90.54.020 and chapter 90.48 RCW. 88-
22-059 (Order 88-9), §  173-220-090, filed 11/1/88.
Statutory Authority: RCW  90.48.010,  90.48.035, and
90.58.260.  83-10-063 (Order DE  83-14), §  173-220-
   WAC 173-220-100  Public notice of public bearings.
 (1) The department shall circulate public notice of any
 hearing held pursuant to WAC  173-220-090 at least as
 widely as was  the  notice pursuant to WAC  173-220-
 050. Procedures for the circulation of public  notice  for
 hearings held under WAC 173-220-090 shall  include at
 least the following:
   (a) Notice shall be published  in at least one major lo-
 cal newspaper  of general  circulation within  the geo-
 graphical area of the discharge;
   (b) Notice shall be sent to all  persons and government
 agencies who received a copy of the notice  pursuant to
 WAC 173-220-050 or the fact sheet;
   (c) Notice shall be mailed to any person upon request;
 and
   (d) Notice shall be effected pursuant to (a) and (c) of
 this subsection  at least  thirty days in  advance of the
 hearing.
   (2) The contents  of public notice of any hearing held
 in pursuant to WAC 173-220-090 shall include at least
 the following:
   (a) Name, address, and phone number of agency
 holding  the public hearing;
   (b) A reference to the public notice issued pursuant to
 WAC  173-220-050, including  identification number
 and date of issuance;
   (c) The time  and  location for the hearing;
   (d) The purpose of the hearing;
   (e) Address and phone number of premises at which
 interested persons may obtain information;
   (0 The nature of the hearing;
   (g) The  issues raised by  the persons requesting the
 hearing, and any other appropriate issues which may be
 of interest to the public;
   (i) Except when unknown in the case of general per-
 mit determinations,  the name and address of each appli-
cant whose proposed discharge will be considered at the
 hearing;
   (ii) Except when unknown in  the case of general per-
 mit determinations, the name of waterway to which each
discharge is  made and the location of each discharge on
the waterway.  [Statutory  Authority: RCW 90.54.020
and chapter 90.48 RCW.  88-22-059  (Order 88-9), §
 173-220-100, filed 11/1/88. Statutory Authority: RCW
90.48.035 and 90.48.260. 82-24-078 (Order  DE 82-39).
 § 173-220-100, filed 12/1/82; Order DE 74-1, §  173-
220-100, Tiled 2/15/74.]
                                                   C-27

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Puget Sound Dredged
  Disposal Analysis

-------
                                    CHAPTER 1

                                 INTRODUCTION
 1.1    Puget Sound Dredged Disposal Analysis

 PSDDA is an interagency program for the management of unconfined, open-water disposal of
 dredged material into Puget Sound, Washington. The PSDDA program was developed jointly
 by the U.S. Army Corps of Engineers (Corps) Seattle District, the U.S. Environmental Protection
 Agency (EPA) Region 10, the Washington Department of Natural Resources (DNR) and  the
 Washington Department of Ecology (Ecology).  The Management Plans      for the PSDDA
 program identify disposal sites, describe dredged material evaluation procedures, and establish
 site monitoring and management practices. The plans also commit the agencies to a cooperative
 annual review process which evaluates disposal site use and conditions, dredged material testing
 results, and new scientific information, in order to determine if changes to the evaluation
 procedures and/or disposal site management practices are needed.


 1.2    PSDDA Annual Review Process

 The PSDDA annual review process currently involves preparation of various annual reports by
 the PSDDA agencies (Corps, DNR, EPA, Ecology), an annual review meeting (ARM), and a
 public notice of program changes resulting from the annual review.

 The process calls for the following annual reports to be prepared:

  •    a report by DNR summarizing the dredging activity and site use
  •    a report by the Corps summarizing dredged material sampling, testing, and application
       of disposal guidelines
  •    a report by the Corps describing the results of disposal site physical monitoring
  •    a report  by DNR describing the  results of disposal  site chemical  and biological
       monitoring
  •    a report prepared by Ecology summarizing the results of disposal site environmental
       monitoring; and
  •    a report  by Ecology summarizing  potential issues and changes  to the PSDDA
       Management Plan

 The Corps announces the ARM by letter, accompanied by Ecology's annual Management Plan
 Assessment Report and any key program issue papers. Comments on the report, issue papers
 and any changes to the PSDDA Management  Plan which the public deem appropriate are
 specifically requested.  The latter must be submitted in writing and may be briefly presented at
 the ARM.

 After the ARM, PSDDA agencies consider all of the agency and public comments, summarize
 the ARM and report on any changes to the PSDDA Management Plan. This summary is usually
 prepared and mailed to interested parties in May or June.
Note:   In addition to involvement in the PSDDA annual review process, the public can
        also participate in the permitting process for dredging and dredge disposal activities
        through the Corps of Engineers  Section 10/404 Permit.  The following figure
        illustrates public involvement opportunities in this permitting process.

                                      C-28

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                                                                   PROJECT
                                                                  APPLICANT
                        Section 1
                                                                                                           Shontnt
                                                                                                            PurmHAnttcmtor
                                                                                      tot* |
                                                                                                    Dredging S*»
                   CORPS
                                                                                                                      CITY/COUNTY
                       Pubic No**
                                                                             Shautna Pmnril to
                                                                             Ecology la Pnvtfm
                                                                                                  I  ShfPtmtH
                                                                                                  \AppHcatona, U$»
                                                                                                  I Auttorinton'
O
 I
M
CO
            ENVIRONMENTAL
              PROTECTION
                AGENCY
FISH AND
VM.OUFE
SERVICE
NATIONAL
 MARME
F (SHE RES
 SERVICE
OTHErt FEDERAL.
STATE AND LOCAL
AGENCCS; MOWN
 TRIBES: PUBLIC
 GAME/
FISHERCS
OTHER STATE
  AGENCES
ECOLOGY
 NATURAL
RESOURCES
                                                                                   AffVOMl
                                                                                                                            C2U4
                                                                   CORPS
                                                                ECOLOGY COOROMATEO STATE RESPONSE
                                                                Pit** Altaian
                                                                                                                                    I tt
                                                                                                    PtmtHAcOan
                                                                             Note:  This figure is currently being revised for clarification.
            Figure 3-1.  Dredging and unconfined, open-water disposal permitting process for non-Corps projects

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           Federal  Register / Vol. 51. No.  219 / Thursday.  November 13. 1986  /  Rules  and  Regulations   41241
 Public Notice

""[a] Central. The public notice it the
primary method of advising all
interested parties of the proposed
activity for which a permit is sought and
of soliciting comments and information
necessary to evaluate the probable
impact on the public interest The notice
must, therefore, include sufficient
information to give a clear
understanding of the nature and
magnitude of the activity to generate
meaningful comment The notice should
include the following item* of
information:
  (1) Applicable statutory authority or
authorities;
  (2) The name and address of the
applicant;
  (3) The name or title, address and
telephone number of the Corps
employee from whom additional
information concerning the application
may be obtained:
  (4) The location of the proposed
activity;
  (S) A brief description of the proposed
activity, its purpose and intended use.
so as to provide sufficient information
concerning the nature of the activity to
generate meaningful comments,
 including a description of the type of
 structures, if any, to be erected on fills
 or pile or float-supported platforms, and
 a description of the type, composition.
 and quantity of materials to be
 discharged or disposed of in the ocean:
  (0) A plan and elevation drawing
 showing the general and specific site
 location and character of all proposed
 activities, including the size relationship
 of the proposed structures to the size of
 the impacted waterway and depth  of
 water in the area;
  (7) If the proposed activity would
 occur in the territorial seas or ocean
 waters, a description of the activity's
 relationship to the baseline from which
 the territorial sea is measured;
  (8) A list of other government
 authorizations obtained or requested by
 the applicant including required
 certifications relative to water quality.
 coastal zone management or marine
 sanctuaries;
  (9) If appropriate, a statement  that the
 activity is a categorical exclusion for
 purposes of NEPA (see paragraph 7 of
 Appendix B to 33 CFR  Part 230);
  (10) A statement of the district
 engineer's current knowledge on historic
 properties;
  (11) A statement of the district
 engineer's current knowledge on
 endangered species (see } 325.2{b)(5)):
  (12) A statement(s) on evaluation
factors (see | 325.3(c));
  (13) Any other available information
which may assist interested parties in
evaluating the likely Impact of the
proposed activity, if any, on factors
affecting the public Interest;
  (14) The comment period based on
I 325.2(d)(2);
  (IS) A statement that any person may
request in writing, within the comment
period specified in the notice, that a
public hearing be held to consider the
application. Requests for public hearings
shall state, with particularity, the
reasons for holding a public hearing:
  (16) For non-federal applications in
states with an approved CZM Plan, a
statement on compliance with the
approved  Plan;  and
  (17) In addition, for section 103 (ocean
dumping) activities:
  (i) The specific location of the
proposed disposal site and its physical
boundaries;
  (ii) A statement as to whether the
proposed disposal site has been
designated for use by the Administrator,
EPA. pursuant to section 102{c) of the
Act
  (ill) If the proposed disposal site has
not been designated by the
Administrator, EPA. a description of the
characteristics of the proposed disposal
site and an explanation as to why no
previously designated disposal site is
feasible:
  (iv) A brief description of known
dredged material discharges at the
proposed disposal site;
  (v) Existence and documented effects
of other authorized disposals that have
been nude In the disposal area (e.g..
heavy metal background reading and
organic carbon content);
   (vi) An estimate of the length of time
during which disposal would continue at
the proposed site; and
   (vii) Information on the  characteristics
and composition of the dredged
material.
  (b) Public notice for general permits.
District engineers will publish a public.
notice for all proposed regional general
permits and for significant modifications
to, or reissuance of. existing regional
permits within their area of jurisdiction.
Public notices for statewide regional
permits may be issued jointly by the
affected Corps districts. The notice will
include all applicable information
necessary'to provide a cleai
understanding of the proposal. In
addition, the notice will state the
availability of information at the district
office which reveals the Corps'
provisional determination that the
proposed activities comply with the
requirements for issuance of general
permits. District engineers will publish a
public notice for nationwide permits in
accordance with 33 CFR 330.4.
  (c) Evaluation factors. A paragraph
describing the various evaluation factors
on which decisions are based shall be
included in every public notice.
  (1) Except as provided in paragraph
(c)(3) of this section, the following will
be included:
  "Die decision whether to Israe • permit
will be bated on aa evaluation of the
probable Impact Including emDnlative
impacts of me proposed activity on the public
Interest That decision will reflect the
national concern for both protection and
utilisation of important resources. The h""^flt
which reasonably may be expected to accrue
from the proposal must be balanced against
Its reasonably foreseeable detriment*. All
factors which may be relevant to the
proposal will be considered including the
cumulative effects thereof; among those are
conservation, economics, aesthetics, general
environmental concerns, wetlands, historic
properties, fish and wildlife values, flood
hazards, floodpiain values, land use.
navigation, ihoreune erosion and accretion,
recreation, water supply and conservation.
water quality, energy needs, safety, food and.
fiber production, mineral needs.
considerations of property ownership and, in
general, the needs and welfare qf the people."
   (2) If the activity would involve the
discharge of dredged or fill material into
the waten of the United States or the
transportation of dredged material for
the purpose of disposing of it in ocean
waten. the public notice ihall also
indicate that the evaluation of the inpact
of the activity on the public  interest will
include application of the guidelines
promulgated by the Administrator, EPA.
(40 CFR Part 230) or of the criteria
                                                          C-30

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41242   Federal Register  /  Vol. 51. No. 219 / Thursday,  November 13, 1986 / Rules and Regulations
                 established under authority of section
                 102(a) of the Marine Protection,
                 Research and Sanctuaries Act of 1972,
                 as amended (40 CFR Parts 220 to 229), as
                 appropriate. (See 33 CFR Parts 323 and
                 324).
                   (3) In cases involving construction of
                 artificial islands, installations and other
                 devices on outer continental shelf lands
                 which are under mineral lease from the
                 Department of the Interior, the notice
                 will contain the following statement:
                 "The decision as to whether a permit
                 will be issued will be based on an
                 evaluation of the impact of the proposed
                 work on navigation and national
                 security."
                   (d) Distribution of public notices. (1)
                 Public notices will be distributed for
                 posting in post offices or other
                 appropriate public places in the vicinity
                 of the site of the proposed work and will
                 be sent to the applicant to appropriate
                 dry and county  officials, to adjoining
                 property owners, to appropriate state
                 agencies, to appropriate Indian Tribes or
                 tribal representatives, to concerned
                 Federal agencies, to local, regional and
                 national snipping and other concerned
                 business and conservation
                 organizations, to appropriate River
                 Basin Commissions, to appropriate state
                 and areawide clearing houses as
                 prescribed by OMB Circular A-05. to
                 local news media and to any other
                 interested party. Copies of public
                 notices will be sent to all parties who
                 have specifically requested copies of
                 public notices, to thc-U.8. Senators and
                 Representatives for the area where the
                 work Is to be performed, the field
                 representative of the Secretary of the
                 Interior, the Regional Director of the
                 Fish and Wildlife Service, the Regional
                 Director of the National Park Service,
                 the Regional Administrator of the
                 Environmental Protection Agency (EPA).
                 the Regional Director of the National
                 Marine Fisheries Service of the National
                 Oceanic and Atmospheric
                 Administration  (NOAA), the head of the
                 state agency responsible for fish and
                 wildlife resources, the State Hisiork
                 Preservation Officer, and the District
                 Commander. U.S. Coast Guard.
                   (2) In addition to the general
                 distribution of public notices cited
                 above, notices will be sent to other
                 addressees in appropriate cases as
                 follows:
                   (i) If the activity would involve
                 structures or dredging along the shores
                 of the seas or Great Lakes, to the
                 Coastal Engineering Research Center,
                 Washington. DC 20016.
                   (ii) If the  activity would involve
                 construction of fixed structures or
                 artificial islands on the outer continental
                 shelf or in the territorial seas, to the
Assistant Secretary of Defense
(Manpower, Installations, and Logistics
(ASDfMiaL)). Washington. DC 20310:
the Director, Defense Mapping Agencv
(Hydrographic Center) Washington. DC
20390, Attention, Code NS12; and the
Charting and Geodetic Services, N/
CG222, National Ocean Service NOAA
Rockville. Maryland 20852, and to
affected military installations and
activities.
  (iii) If the activity involves the
construction of structures to enhance
fish propagation (e.g., fishing reefs)
along the coasts of the United States, to
the Director. Office of Marine
Recreational Fisheries, National Marine
Fisheries Service, Washington. DC
20235.
  (iv) If the activity involves the
construction of structures which may
affect aircraft operations or for purposes
associated with seaplane operations, to
the Regional Director of the Federal
Aviation Administration.
  (v) If the activity would be in
connection with a foreign-trade zone, to
the Executive Secretary, Foreign-Trade
Zones Board, Department of Commerce,
Washingtoa DC 20230 and to the
appropriate District Director of Customs
as Resident Representative, Foreign-
Trade Zones Board.
  (3) It is presumed that all interested
parties and agencies will wish to
respond to public notices; therefore, a
lack of response will be interpreted as
meaning that there is no objection to the
proposed project A copy of the public
notice with the list of the addresses to
whom the notice was sent will be
included in the record. If a question
develops with respect to an activity for
which another agency has responsibility
and that other agency has not responded
to the public notice, the district engineer
may request its comments. Whenever a
response to a public notice has been
received from a member of Congress,
either in behalf of a constitutent or
himself, the district engineer will inform
the member of Congress of the final
decision.
  (4) District engineers will update
public notice mailing lists at least once
every two years.
                                                     C-31

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         APPENDIX D

EPA Technical Studies in Support
 of Urban Bay Action Programs

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EPA  Technical Studies
                         Armstrong, J., and A. Copping (Eds.) 1990. Proceedings of the
                         Forum on Status and Trends of Puget Sound's Biological Resources.
                         EPA 910/9-90-001;  NTIS PB90-198839.  Environmental Protec-
                         tion Agency Region 10, Seattle, WA.

                         Burke, D.  1989.  Sound access search manual. Prepared by Puget
                         Sound Institute, University of Washington, as User's Guide for
                         Sound Access Computer Bibliography.

                         City of Seattle.  1986.  Lake Union and Ship Canal water  quality
                         management plan: data summary report.  City of Seattle, Office
                         for Long Range Planning, WA.

                         City of Seattle.  1987.  Lake Union and Ship Canal water  quality
                         management plan: data summary report addendum. City of Seat-
                         tle, Office for Long  Range Planning, WA.

                         City of Seattle.  1987.  Lake Union and Ship Canal water  quality
                         management  plan:  data  summary report.  EPA 910/9-89-037;
                         NTIS PB90-197906.  City of  Seattle, Office for Long  Range
                         Planning, WA.

                         City of Seattle.  1988.  Lake Union and Ship Canal water  quality
                         management plan: interim action plan. City of Seattle, Office for
                         Long Range Planning, WA.

                         Copping,  A.C., J. Dohrman, A. Grahm, et al. 1989. Handbook
                         on Puget Sound sediments. Puget Sound Water Quality Authority,
                         Seattle, WA.

                         Crecelius, E.A., T.J. Fortman, S.L. Kiesser, et al. 1989.  Survey
                         of contaminants in two Puget Sound marinas. EPA 910/9-89-014.
                         NTIS PB90-130709.  Battelle Ocean Sciences, Duxbury, MA.

                         Curl, H., E. Baker, and T. Bates, et al.  1987.  Contaminant
                         transport from Elliott Bay and Commencement Bay.  EPA 910/9-
                         88-177; NTIS PB89-143267. National Oceanic and Atmospheric
                         Administration, Pacific Marine Environmental Laboratory,  Seattle,
                         WA.
                                                    D-1

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DeWitt, T., G. Ditsworth, and R. Swartz. 1988. Effects of natural
sediment features on the phoxocephalid amphipod Rhepoxynius
abronius. Mark 0. Hatfield Marine Science Center, Newport, OR.

E.V.S. and Tetra Tech.  1985. Elliott Bay toxics action program.
Cruise Summary  Report:  Benthic Infauna and Sediment Quality
Survey, September 25 - October 16, 1985.  E.V.S. Consultants,
Seattle, WA, and Tetra Tech, Inc., Bellevue, WA.

E.V.S. and Tetra Tech.  1985. Elliott Bay toxics action program.
Cruise Summary Report:  Fish Pathology and Bioaccumulation
Survey. September 16 - October 17, 1985.  E.V.S. Consultants,
Seattle, WA, and Tetra Tech, Inc., Bellevue, WA.

Envirosphere and Cooper.  1985.  Summary of historical  Puget
Sound contaminant mass loading analysis.   EPA 910/9-88-235.
Envirosphere Company, Bellevue, WA, and Cooper Consultants,
Bellevue, WA.

Envirosphere and Cooper.   1985.   NPDES  monitoring
recommendations to improve contaminant loading data availability.
EPA 910/9-88-237. Envirosphere Company, Bellevue, WA, and
Cooper Consultants, Bellevue, WA.

Evans-Hamilton and D.R. Systems. 1987. Puget Sound environ-
mental atlas. EPA 910/9-87-171.  Evans-Hamilton, Inc., Seattle,
WA, and D. R. Systems, Inc., Nanaimo, BC, Canada.

Faigenblum, J. 1988.  Chemicals and bacteriological organisms in
recreational shellfish.  EPA 910/9-88-245;  NTIS PB90-131129.
Washington State Department of Social and Health Services, Olym-
pia, WA.

Malins, D., and  A. Jensen (Eds.).  1988.  Aquatic toxicology.
Toxic Chemicals  and Aquatic Life:  Research and Management.
Volume 11.  In:  Proceedings of symposium on Elsevier Science
Publishers, B.V.-Amsterdam.

PTL  1988. Briefing report to the EPA Science Advisory Board:
The apparent effects threshold approach. EPA 910/9-89-013;  NTIS
PB90-217913.  PTI Environmental Services, Bellevue, WA.

PTI.  1988. Sediment quality values refinement:  Vol. H:  Evalu-
ation of PSDDA sediment quality values. EPA 910/9-88-247 a &
b; NTIS PB89-229827 & PB89-229835. PTI Environmental Ser-
vices, Bellevue, WA.
                           D-2

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PIT.  1988. SEDQUAL contaminated sediments database users
manual. PTI Environmental Services, Bellevue, WA.

PTI.  1988.  Elliott Bay action program:  1988 action plan.  EPA
910/9-88-240.  PTI Environmental Services, Bellevue, WA.

PTI.  1988. Sediment quality values refinement: Volume I:  1988
update and evaluation of Puget Sound AET. EPA 910/9-88-246 a
& b;  NTIS PB89-200398 &  PB89-200406.  PTI Environmental
Services, Bellevue, WA.

PTI.  1989. Everett Harbor action program:  1989 action plan.
EPA 910/9-89-004; NTIS PB89-229819.  PTI Environmental Ser-
vices, Bellevue, WA.

PTI.  1989.  Comparison of bioassays for assessing sediment tox-
icity in Puget Sound. PTI Environmental Services, Bellevue, WA.

PTI.  1989. Bellingham Bay action program:  initial data summary
and problem identification.   EPA 910/9-89-042;  NTIS PB90-
219049. PTI Environmental Services, Bellevue, WA.

PTI.  1990. Protocol for juvenile Neanthes sediment bioassay.
EPA 910/9-90-011; NTIS PB90-232828.  PTI Environmental Ser-
vices, Bellevue, WA.
                                           i
PTI.  1990.  The "Urban Bay action program" approach:  A
focused toxics control strategy. EPA 910/9-90-002; NTIS PB90-
198847. PTI Environmental Services, Bellevue, WA.

PTI.  1990. Overview and summary recommendations; November
15-16, 1989 Seasurface Microlayer Workshop.  EPA 910/9-90-
008; NTISPB90-227331.  PTI Environmental Services, Bellevue,
WA.

PTI.  1990.  Sinclair and Dyes inlets action program: 1990 action
plan.  EPA 910/9-90-013.  PTI Environmental Services, Bellevue,
WA.

PTI.  1990. Development of a Neanthes sediment bioassay for use
in Puget Sound.  EPA 910/9-90-005; NTIS  PB90-202904. PTI
Environmental Services, Bellevue, WA.

PTI.  1991.  Bellingham  Bay action plan.  PTI Environmental
Services, Bellevue, WA.
                           D-3

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PTI. 1991. Budd Inlet action plan. PTI Environmental Services,
Bellevue, WA.

PTI. 1991. Pollutants of concern in Puget Sound. PTI Environ-
mental Services, Bellevue, WA.

PTI. 1991. Characterization of toxic chemicals in wildlife associ-
ated with Puget Sound. Report and Monitoring Recommendations.
PTI Environmental Services, Bellevue, WA.

PTI. 1991. Contaminant levels in Puget Sound harbor seals.  PTI
Environmental Services, Bellevue, WA.

PTI. 1991.  Dioxin levels in Puget Sound Dungeness crab.  PTI
Environmental Services, Bellevue, WA.

PTI.  1991.  Nutrients and phytoplankton in Puget Sound.  PTI
Environmental Services, Bellevue, WA.

PTI. 1991. A project manager's guide to requesting and evaluating
chemical analyses. PTI Environmental Services, Bellevue, WA.

PTI. 1991. Reconnaissance survey of chemical contamination and
biological effects in southern Puget Sound.  PTI Environmental
Services, Bellevue, WA.

PTIandDOH.  1991.  Chemical contaminant levels in Puget Sound
sea cucumbers.  PTI Envkonmental Services, Bellevue, WA, and
State of Washington Department of Health, Olympia, WA.

PTI and Tetra Tech.   1988. Elliott Bay action program:  analysis
of toxic problem areas. EPA 910/9-88-213;  NTIS PB90-219064.
PTI Environmental Services, Bellevue, WA, and Tetra Tech, Inc.,
Bellevue, WA.

PTI and Tetra Tech.  1988.  Everett Harbor action program:
analysis of toxic problem areas. EPA 910/9-88-241 & -24 la; NTIS
PB90-227117.  PTI Environmental Services, Bellevue, WA, and
Tetra Tech, Inc., Bellevue, WA.

PSWQA. 1988. Proceedings, first annual meeting on Puget Sound
research. Volumes land 2. Puget Sound Water Quality Authority
Seattle, WA.

PSWQA. 1988. Puget Sound ambient monitoring program. Puget
Sound Water Quality Authority, Seattle, WA.
                           D-4

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PSWQA.   1988.  Design  of Puget Sound ambient  monitoring
program central database.  Puget Sound Water Quality Authority,
Seattle, WA.

PSWQA. 1989. Evaluation of the atmospheric deposition of toxic
contaminants to Puget Sound. Final Scoping Report. Puget Sound
Water Quality Authority, Seattle, WA.

PSWQA.   1989.  Managing nonpoint pollution: an action plan
handbook for Puget Sound watersheds. Puget Sound Water Quality
Authority, Seattle, WA.

PSWQA.  1990. Puget Sound update: first annual report of the
Puget Sound ambient monitoring program.  Puget Sound  Water
Quality Authority, Seattle, WA.

PSWQA. 1991. Evaluation of the atmospheric deposition of toxic
contaminants to Puget Sound. Puget Sound Water Quality Author-
ity, Seattle, WA.

PSWQA. 1991. Puget Sound update: 1991 second annual report
of the Puget Sound ambient monitoring program.  Puget  Sound
Water Quality Authority, Seattle, WA.

PSWQA. 1991. Update of the Puget Sound environmental atlas.
Puget Sound Water Quality  Authority, Seattle, WA.

PSWQA.   1991.  Puget Sound access  1991:   A computerized
bibliography for Puget Sound. Puget Sound Water Quality Author-
ity, Seattle, WA.

Ryan, C.  1987. The urban bay toxics control program:  action
team accomplishments.  Washington Department of Ecology,
Olympia, WA.

Siddens, L., R. Hoffman, W. Seim, et al.  1986. Surf smelt and
other marine fishes appropriate for use in chronic toxicity  testing
in the Puget Sound area and on the Pacific Coast. Department of
Fisheries and Wildlife, Oregon State University, Corvallis, OR.

Simenstad, C., and C. Tanner.  1991. An estuarine habitat resto-
ration monitoring protocol for Puget Sound.  University of Wash-
ington, Fisheries Research Institute, Seattle, WA.
                           D-5

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Tetra Tech.  1985.  Sampling and analysis design for development
of Elliott Bay toxics action plan.  EPA 910/9-88-197. Tetra Tech,
Inc., Bellevue, WA.

Tetra Tech.  1985.  Elliott Bay toxics action program:  Review of
existing plans and activities. EPA 910/9-88-199. Tetra Tech, Inc.,
Bellevue, WA.

Tetra Tech.   1985.  Field report:  Elliott Bay source sampling
program.  September 23 -  October  17, 1985.  Tetra Tech, Inc.,
Bellevue, WA.

Tetra Tech. 1985. Elliott Bay toxics action program:  interim work
plan. EPA 910/9-88-198. Tetra Tech, Lie., Bellevue, WA.

Tetra Tech.  1985.  Everett Harbor action plan: initial data sum-
maries  and problem identification. Draft Report (never finalized).
EPA 910/9-88-195. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  Sampling and analysis design for development
of Everett Harbor  action program.   EPA 910/9-87-197.  Tetra
Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  Development of sediment quality  values for
Puget Sound.  EPA 910/9-88-246;  NTIS AD-A148647.  Tetra
Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  User's manual for the pollutants of concern
matrix. EPA 910/9-87-176. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1986.  Elliott Bay toxics action program: initial data
summaries and problem identification.  EPA 910/9-88-191;
NTIS PB90-197898. Tetra Tech, Inc., Bellevue, WA

Tetra Tech.  1986.  Everett Harbor toxics action program:  review
of existing plans and activities. EPA 910/9-88-192.  Tetra Tech,
Inc., Bellevue, WA.

Tetra Tech. 1986.  Guidance manual for health risk assessment of
chemically contaminated seafood. EPA 910/9-88-182; NTIS PB90-
197880. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1986. Everett Harbor toxics action program:  field
summary report, source sampling, October 15, 16, and 29, 1986.
Tetra Tech, Inc., Bellevue, WA.
                            D-6

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Tetra Tech.  1988.  Budd Inlet action program: initial data summa-
ries  and problem identification. EPA 910/9-88-230; NTISPB90-
195264.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Assessment of potential toxic problems in
non-urban areas of Puget Sound. EPA 503/3-88-002; NTISPB89-
134332.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988. Elliott Bay revised action program: data quality
assurance assessment.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988. Elliott Bay revised action program:  data set.
Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Health risk assessment of chemical contami-
nants in Puget Sound seafood. EPA 910/9-88-249; NTIS PB89-
200240.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988. Pesticides of concern in the Puget Sound basin:
A review of contemporary pesticide usage.  EPA 910/9-88-231;
NTIS PB89-143275. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Everett Harbor action program: evaluation of
potential contaminant sources. EPA 910/9-88-229; NTIS PB90-
219072.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.   1988.  Elliott Bay action program:   evaluation of
potential contaminant sources.  EPA 910/9-88-239 a through c;
NTIS PB90-198862. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Characterization of spatial and temporal trends
in water quality in Puget  Sound.  EPA  503/3-88-003;  NTIS
PB89-134290.  Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988. Elliott Bay action program:  The relationship
between source control and recovery of contaminated sediments in
two  problem areas.  EPA 910/9-88-208;  NTIS PB90-198888.
Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Elliott Bay action program:  storm drain
monitoring approach.  EPA 910/9-88-207; NTIS PB90-198896.
Tetra Tech., Inc., Bellevue, WA.
                            D-7

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Tetra Tech.  1988.  Elliott Bay action program:   guidance for
development of monitoring programs to evaluate the success of
source control within drainage basins. EPA 910/9-88-243; NTIS
PB90-198870. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech.  1988.  Sinclair and Dyes Inlets action program: initial
data summaries and problem identification.  EPA 910/9-88-244;
NTIS PB90-206533. Tetra Tech, Inc., Bellevue, WA.

Tetra Tech and E.V.S.  1986.  Everett Harbor toxics action pro-
gram:  cruise summary report, fish pathology and bioaccumulation
survey, August 25 to September 2,  1986.  Tetra Tech, Inc.,
Bellevue, WA, and E.V.S. Consultants, Seattle, WA.

Tetra Tech and E.V.S.  1986.  Everett Harbor toxics action pro-
gram:  cruise summary report, benthos, bioassay,  and sediment
chemistry survey, September 30 to October 15, 1986. Tetra Tech,
Inc., Bellevue, WA, and E.V.S. Consultants, Seattle, WA.

Weston, D.P.  1989. Pollutant bioaccumulations and community
response in the macrobenthos:  1987-1988 studies.  Puget Sound
Institute, University of Washington, Seattle, WA.
                           D-8

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Guidelines for Measuring Environmental
Variables in Puget  Sound
                       U.S. EPA. 1990. Recommended guidelines for measuring selected
                       environmental Variables in Puget Sound. U.S. Environmental
                       Protection Agency Region 10, Seattle, WA.  13 chapters:

                            General QA/QC Considerations for Collecting Environmental
                            Samples in Puget Sound (3/86).

                            Recommended Protocols for Measuring Conventional Sedi-
                            ment Variables in Puget Sound (3/86).

                            Recommended Protocols for Conducting Laboratory Bioas-
                            says on Puget Sound Sediments (5/86; in revision).

                            Recommended Protocols for Station Positioning in Puget
                            Sound  (8/86).

                            Recommended Protocols for Measuring Metals in Puget Sound
                            Water, Sediment and Tissue Samples (8/86; revised 12/89).

                            Recommended Protocols for Microbiological Studies in Puget
                            Sound  (11/86).

                            Recommended Protocols for Measuring Organic Compounds
                            in Puget Sound Sediments and Tissue Samples (12/86; revised
                            12/89).

                            Recommended Protocols for Sampling and Analyzing Subtidal
                            Benthic Macroinvertebrate Assemblages in Puget  Sound
                            (1/87).

                            Recommended Protocols for Fish Pathology Studies in Puget
                            Sound  (7/87).

                            Recommended Protocols for Measuring Conventional Water
                            Quality Variables and Metals in Fresh Waters of the Puget
                            Sound  Region (12/89).

                            Recommended Protocols for Sampling Soft-Bottom Demersal
                            Fishes  by Beach Seine and Trawl in Puget Sound (12/89).
                                                 D-9

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Recommended Protocols for Measuring Conventional Marine
Water Column Variables in Puget Sound (In preparation).

Recommended Protocols for Marine Mammal Tissue Sam-
pling and Analysis (In preparation).
                    D-10

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