Public Comments on Ecology’s Waste Discharge Permit for Pacific Shellfish – Quilcene
Ecology will be issuing a National Pollutant Discharge Elimination System (NPDES) permit to Pacific Shellfish (Quilcene) – we need your help!
We would greatly appreciate your immediate help in submitting your supporting comments to Ecology referencing the permit to be issued to Pacific Shellfish (formerly Coast Seafoods in Quilcene). The Clean Water Act prohibits anybody from discharging “pollutants” through a “point source” into a “water of the United States” unless they have an NPDES permit. The permit will contain limits on what a facility can discharge, monitoring and reporting requirements, and other provisions to ensure that the discharge does not hurt water quality or people’s health.
We are providing below a sample letter to Ecology to make your comments easier. You may copy/paste portions of it or the entire letter and email it to jessica.christensen@ecy.wa.gov by Friday, January 27th. Thank you so much for your help – and please feel free to share with others who care about our clean waters.
If you would like to read the Fact Sheet with tables and maps, please click here for a pdf document.
Ms. Jessica Christensen – Department of Ecology Southwest Regional Office – PO Box 47775 – Olympia, WA 98504-7775
Via electronic communication: jessica.christensen@ecy.wa.gov
Dear Ms. Christensen:
I am writing as a supporter of the Olympic Forest Coalition (“OFCO”) in response to Ecology’s request for public comment on draft NPDES and Waste Discharge Permit number WA0041114 for the Pacific Shellfish – Quilcene, LLC facility in Quilcene, Washington. Since 2002, OFCO has advocated for cleaner water and air and for the preservation of public lands and wildlife habitat on and around the Olympic Peninsula.
Thank you for working to issue a strong NPDES permit for the facility. To ensure the permit complies with the Clean Water Act and state law, and to ensure it protects the water quality and natural resources of Quilcene Bay, the small stream at the site, and Hood Canal, I urge you to strengthen Permit WA0041114 in the following ways:
– Please impose numeric effluent limits on all pollutant discharges including nutrients. Quilcene Bay has a history of nutrient-caused harmful algal blooms, meriting more extensive guidelines for nitrogen and other nutrients, and discharges of solids, heat, and other pollutants likely exacerbate those problems. Please impose strict numeric effluent limitations to reduce harms and risks to Quilcene Bay.
– Please impose an instantaneous maximum effluent limitation for maximum daily effluent limits rather than average discharge measured during a calendar day. Permit WA0041114 appears to allow for averaging multiple measurements over the course of the day, encouraging unlimited sampling to drive down the reported value. Instead, the permit should set a maximum allowable concentration for every sample collected, especially for pollutants not continuously discharged.
– Please ensure the permit requires the imposition of All Known, Available, and Reasonable methods of Treatment (“AKART”). Under Washington law, Ecology must outline AKART in every permit it issues. The permit currently fails to identify these methods, depriving the facility of clear guidelines for its compliance and preventing public review of the matter. If the permit defers an AKART determination please ensure public participation in the review and approval of AKART.
– Cap the facility’s current effluent flow levels and require it to monitor and report them. Even if the facility maintains its percentage-based limits, increasing the volume of these pollutants will harm the surrounding area.
As a supporter of OFCO, I share Ecology’s commitment to healthy waterways and hope this permit will reduce discharges of pollutants from the facility while supporting public review and transparency. Thank you for considering these issues.
Sincerely,
[Your Name]
[Contact information]