Puget Sound Nutrient General Permit Preliminary Draft Informal Comment Period

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Comment From: Tom Weir

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and we are glad to see the Department of Ecology requiring Puget Sound utilities to transition to more prot...↓
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Comment From: David Habib

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and we are glad to see the Department of Ecology requiring Puget Sound utilities to transition to more prot...↓
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Comment From: Claudia Hevel

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and we are glad to see the Department of Ecology requiring Puget Sound utilities to transition to more prot...↓
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Comment From: Leslie Yamada

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and we are glad to see the Department of Ecology requiring Puget Sound utilities to transition to more prot...↓
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Comment From: Mark Blitzer

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and I am glad to see the Department of Ecology requiring Puget Sound utilities to transition to more protec...↓
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Comment From: Peggy Butler

7/12/21 @ 12:00 AM
Dear Ms. Ott, Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit. Clean water is important to me personally, and we are glad to see the Department of Ecology requiring Puget Sound utilities to transition to more prot...↓
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Comment From: Lewis francis

7/05/21 @ 9:52 AM
Nutrient General Permit Lead Ellie Ott,I am writing to object to Ecology’s proposal to allow sewage treatment plants to continue to discharge nitrogen and toxics to Puget Sound at current unsafe levels of pollution that are already suffocating marine...↓
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Comment From: sarah burdell

7/05/21 @ 9:41 AM
Nutrient General Permit Lead Ellie Ott,I am writing to object to Ecology’s proposal to allow sewage treatment plants to continue to discharge nitrogen and toxics to Puget Sound at current unsafe levels of pollution that are already suffocating marine...↓
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Comment From: Laura Zeffer

7/05/21 @ 12:00 AM
Nutrient�General Permit Lead Ellie Ott,Like any and all systems- the need for updating/upgrading is required. The money has to be found- we can not let our waters turn into toxic wastelands.Laura Zeffer zeffer3@gmail.com 401 NE 71st #201 Seattle...↓
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Comment From: Jonas Carson

7/05/21 @ 12:00 AM
Nutrient General Permit Lead Ellie Ott,I am writing to object to Ecology’s proposal to allow sewage treatment plants to continue to discharge nitrogen and toxics to Puget Sound at current unsafe levels of pollution that are already suffocating marine...↓
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Comment From: Toni Howard

7/04/21 @ 5:05 PM
Nutrient General Permit Lead Ellie Ott,I am writing to object to Ecology’s proposal to allow sewage treatment plants to continue to discharge nitrogen and toxics to Puget Sound at current unsafe levels of pollution that are already suffocating marine...↓
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Comment From: William Brattain

7/03/21 @ 10:50 AM
Nutrient General Permit Lead Ellie Ott,I am writing to object to Ecology’s proposal to allow sewage treatment plants to continue to discharge nitrogen and toxics to Puget Sound at current unsafe levels of pollution that are already suffocating marine...↓
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Comment From: DERT (Dave Peeler)

3/15/21 @ 10:09 PM
see uploaded comment letter
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Comment From: Gordon Holtgrieve

3/15/21 @ 8:11 PM
Dear Ms. Ott,
Please replace my earlier submitted comment for this revised comment. This revised version fixes a few minor typographical errors and changes some wording for clarity.

Thank you for your time and efforts to allow public comment on this i...↓

Gordon Holtgrieve
Attachments:

Comment From: City of Arlington (Mike Wolanek)

3/15/21 @ 6:41 PM
Please see comments summarized in the attached file.
Thank you.
Mike Wolanek
Water Resources Planner
City of Arlington Public Works
Attachments:

Comment From: City of Auburn (Lisa Tobin)

3/15/21 @ 6:20 PM
As a local public agency that contracts with King County Department of Natural Resources for wastewater treatment and disposal, the City of Auburn Public Works Department is concerned about the proposed Nutrient General Permit for the following reaso...↓
• The costs of adding nutrient removal technologies could result in a 500% increase in future sewer rates, resulting in severe affordability and social equity issues.
• There is no certainty that the expensive addition of nutrient removal technologies will result in improved dissolved oxygen in shallow areas of Puget Sound, especially considering that 80-90% of the nutrients in Puget Sound come from natural sources (Pacific Ocean), non-point sources, and climate change.
• Before regulations are proposed, more field investigations are needed to verify the modeling and determine the effectiveness and costs impacts of adding new nutrient removal technologies at the region's wastewater treatment plants. There may be other actions that can achieve improved water quality at a lower cost.
• While Chapter 173-226-050 of the Washington Administrative Code gives Ecology the statutory authority to issue a General Permit for wastewater dischargers, it requires that the dischargers have similar types of operations and similar wastes. All of the treatment plants included in the proposed regulations have significant differences in treatment processes and available space to expand that must be considered in setting discharge requirements.
• The proposed regulations fail to consider alternatives that recognize the space limitations and highly variable flows that will make it virtually impossible to add nutrient removal technologies to King County's West Point Treatment Plant. A bubble permit or water quality trading are the only way that King County's three wastewater treatment plants could comply with the new regulations.
• The public process that began in Fall 2019 has been too rushed, especially given the Covid-19 pandemic. Other permits, such as the NPDES permit process and the Chesapeake Bay nutrient permit, took several years to develop, with numerous opportunities for public and agency engagement and collaboration. Ecology should extend the schedule to gather additional scientific input, explore alternative actions, and provide opportunities to collaborate to develop a regional plan supported by all stakeholders.

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Comment From: Elected Official (Laura Belvin)

3/15/21 @ 6:18 PM
As a recently appointed water and sewer commissioner, I am newly looking into the nutrient limit discussion. In reading the proposed permit regulations (Puget Sound Nutrient General Plan, Preliminary Draft, January 2021), I have concerns that I am s...↓
The draft permit states that the nutrient discharges from wastewater treatment plants "contribute" to low dissolved oxygen (DO) levels in Puget Sound (page 1). The Salish Sea Model hasn't yet been refined enough to determine the impact from point sources entering the sound (page 7). The low DO levels in Puget Sound are generally in shallow estuaries that are a significant distance away from the major wastewater treatment plants.
It is not clear from the model or testing that the changes suggested in the draft permit will have significant impact on the problem and will come at incredible expense. I have to weigh costs to benefits for my constituents and it is my judgement that the massive cost that will be required for districts to reduce nutrient loading that may not deliver the outcome desired.
There are other ways to reduce DO in shallow estuaries that are more effective and cost less to implement than what is being proposed.
I would suggest that further testing and model calibration be completed before burdening sewer districts with more stringent permit requirements.

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Comment From: Washington Environmental Counc... (Mindy Roberts)

3/15/21 @ 5:38 PM
Attached please find comments submitted by Vickie Woo, Sean Edmison, Donald Wingard, Marco de la Rosa, Virginia Davis, Dean Fournier, Stuart Mork, Priscilla Martinez, Mark Ashley, Pamela Carlton, James Owen, Evelyn Bittner, Michael Albrecht, Emily Da...↓
Attachments:
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Comment From: City of Tacoma (Teresa Peterson)

3/15/21 @ 5:19 PM
Please see the attached comments from the City of Tacoma.
Attachments:

Comment From: Washington Environmental Counc... (Mindy Roberts)

3/15/21 @ 5:09 PM

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Comment From: City of Mount Vernon (Gary Duranceau)

3/15/21 @ 4:53 PM
Comments on the Preliminary Draft Puget Sound Nutrient General Permit.

• The proposed monitoring schedule is time consuming and costly in what you are requiring for a facility that has an average daily flow of 3.4 MGD. We are being required to monito...↓
We would like our monitoring requirements to be more reasonable and actually reflect our actual average daily flow of 3.4 MGD.
The proposed monitoring schedule will create an increase in the need of both financial and staffing requirements. It will also create additional staffing requirements on weekends to complete required monitoring. Is Ecology providing funds to offset these unexpected increases to our budget?

• DOE conducted field studies to assess water quality conditions in the Lower Skagit River. DOE subsequently completed a Total Maximum Daily Load (TMDL) study of the Lower Skagit River for DO in 1997. The studies and modeling evaluated the effect of current and projected waste loads and non-point loads on dissolved oxygen. At that time, the DO criterion for our receiving waters, 8.0 mg/l Class A Excellent, was being met.
Has there been any additional studies to counter these findings? Have the water quality standards changed since the study was performed?

• What will the permit fees be? What will the fees be based off of?

• If we are required to change our process to BNR mode to meet nutrient removal requirements our plant capacity will be reduced in half. What considerations will be given for not meeting our Order on Consent to reduce our CSO's to no more than one per year?


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Comment From: King County (Rebecca Singer)

3/15/21 @ 4:49 PM
Please see King County's attached cover letter, comments, supplementary question responses, and Nitrogen Removal Study.
Attachments:
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Comment From: City of Renton (Martin Pastucha)

3/15/21 @ 4:40 PM
RE: Department of Ecology's Puget Sound Nutrient General Permit


Dear Ms. Ott:

I am writing to share the City of Renton's concerns about the Washington State Department of Ecology's (Ecology) proposed draft Puget Sound Nutrient General Permit for munici...↓

The City of Renton owns and operates its own Wastewater Utility that collects and conveys wastewater to King County owned and operated treatment plants and associated infrastructure. The treatment and disposal of wastewater from Renton's 19,000 Wastewater Utility customers is provided by King County by agreement. Rate payers are responsible for paying King County to treat and dispose of wastewater originating from the city's Wastewater Utility service area customers. In addition to paying for wastewater treatment, Renton Wastewater Utility customers also fund the maintenance, operation, and capital improvement programs through Wastewater Utility rates. The Renton Wastewater Utility also maintains, operates, replaces, and improves the city's wastewater system that consists of 236 miles of sewer mains and 20 sanitary sewer lift stations. The funding is also used to conduct programs to reduce fats oils and grease (FOG) in wastewater and to reduce inflow and infiltration of non-wastewater into the Utility's conveyance systems. The proposed draft Puget Sound Nutrient General Permit would require a dramatic increase in treatment and disposal costs that would have to be paid by Renton Wastewater Utility customers through the King County Wastewater Treatment rates. This would restrict the City of Renton's ability to increase its Wastewater Utility rates, which would impact our ability to fund the maintenance, operation, and infrastructure replacements/improvements needed to meet future growth and serve our customers.

The King County South Wastewater Treatment Plant is located within the City of Renton. The proposed Puget Sound Nutrient General Permit would require significant wastewater treatment process improvements that could impact the residents and businesses within Renton due to odor, noise, and traffic resulting from the improvements and the new treatment process operations.

The City of Renton recognizes Ecology's responsibility to maintain compliance with water quality standards and to address dissolved oxygen (DO) impairment in sensitive areas of the Sound. The city is very concerned about the impacts of implementing new regulatory requirements in advance of verifying modeling results with sampling and data analysis, or fully exploring removal technologies' effectiveness and costs. Investments in nutrient control will have broad societal impacts on affordability, equity, energy use, and greenhouse gas emissions.

We appreciate Ecology's efforts to examine how nutrients contribute to DO reductions, and specifically anthropogenic sources of nutrient loading. There are, however, significant uncertainties and gaps in scientific information and disputed science regarding the relative impact of anthropogenic sources on DO levels. For example, there are many scientific uncertainties associated with understanding DO depletions in Puget Sound and the use of the Salish Sea Model (SSM) as the tool to support regulatory requirements. Additionally, Ecology has not fully considered the environmental trade-offs such as the increase in greenhouse gas emissions that occurs with increased nitrogen removal.

Given the significance of imposing additional regulatory requirements, our region must be assured that these investments will result in significant water quality improvements. Natural oceanic circulation Puget Sound accounts for 88 percent of the nutrient inputs. Wastewater treatment plants account for approximately only 8 percent of the total nutrient inputs to the Puget Sound. Ecology's proposed draft nutrients general permit could require investing billions of dollars to even reduce nutrient discharges from wastewater treatment facilities by 30 percent, or 2 percent of the total nutrient input. This is not the most cost-effective solution and is very unlikely to achieve our shared goal of making significant strides in improving Puget Sound water quality.

Early modeling shows it will take a combination of non-point and point source to achieve meaningful reductions in nutrients. The region's wastewater utilities are committed to working with Ecology on watershed modeling and refinement of non-point source contribution of nutrients in Puget Sound. This technical information is necessary to build regional understanding and identify potential management actions related to non-point nutrient sources. There may be other, more cost-effective solutions to meet the low dissolved oxygen levels. It is incumbent upon Ecology to evaluate all nutrient inputs to develop the best solution economically and environmentally to restore Puget Sound.

Our residents are living in an economy already experiencing severe impacts from COVID-19 and adding additional cost burdens without fully exploring the most cost-effective solutions is very problematic. Recognizing the affordability challenges both near and long term for many residents in the Puget Sound region, if Ecology proceeds with setting new standards it should include other potential compliance options such as bubble permits or a regional water quality trading program, along with new governance structures to implement such approaches, which could prove to be less costly and more effective for improving water quality.

Finally, the City of Renton recommends that Ecology extend its nutrients general permit schedule to allow sufficient time to implement the following approach for improving water quality in the Sound:
• Establish an independent panel of scientists and engineers to make recommendations on the effectiveness of alternatives and identifying solutions that would achieve the greatest water quality benefit for the investment,
• Extend the nutrients general permit schedule to enable other alternatives (e.g., water quality trading and bubble permits), and
• And collaborate with interested parties to develop a regional plan that includes feasibility and affordability.

I want to thank you in advance for your consideration of our comments. If you have any questions, please feel free to contact me anytime at Mpastucha@rentonwa.gov or by phone at 425-430-7311.

Sincerely,



Martin Pastucha
Public Works Administrator


cc: Mayor Pavone
Renton City Councilmembers
Ed VanValey, Chief Administrative Officer
Ron Straka, Utility Systems Director
Joe Stowell, Wastewater Utility Engineering Manager

Attachments:

Comment From: Scott Wilson

3/15/21 @ 4:23 PM
Burden on Small Facilities
There are many facilities that this general permit and future limits would impact which are very small. Right now, the general permit considers a small plant to be less than 3 MGD. However, there are many plants that are s...↓

STEP Systems
The Fisherman Bay WWTP and Eastsound WWTP both treat wastewater from a Septic Tank Effluent Pump (STEP) system. The BOD to TKN ratio is very low on STEP system effluent entering these WWTPs. Not only are these plants extremely small and within a hardship community, but treating STEP system effluent poses an extra challenge and expense for these facilities to denitrify effectively. These facilities are also located within hardship communities, have systems discharging less than 200,000 gallons per day, and are discharging in a significantly less problematic area of the Puget sound. I think this additional challenge should be acknowledged and these facilities should be given reduced permit limits, testing requirements, and additional time to comply with limits.

Facilities Already Under Construction or Design
There are facilities that for some reason or another are already under the design or construction on improvements to their WWTPs. These facilities have spent years planning, budgeting, and paying for improvements to their existing wastewater treatment plants. I think it should be considered that if new permit limits are implemented right after their new plant is built, this will be an unfair extra burden and result in significant extra costs to plan, design, and pay for new improvements while they are still likely paying off the improvements just made. In these situations, I think additional time should be given to plan for and implement future improvements in a reasonable timeline. It should also be considered that the AL limits have been based on data from these facilities existing plants and this data should not necessarily be used and that new data should be gathered and potentially the AL limits should be adjusted when the new plant improvements are online.

Authority of Permit Manager
Obviously, every plant is unique and brings with it unique challenges to adequately treat wastewater. I think more authority should be given to the DOE permit managers over the requirements of the systems they manage and that a blanket general permit might not be the best solution for every plant. These permit managers know their systems in detail and should be allowed to use their best judgement on what is appropriate for each facility.

Timing
Overall, I think the timing these new nutrient removal permit requirements are being implemented is too fast and that facilities should be given ample time to plan for and implement new requirements. In small hardship communities located in remote areas, it can be hard to find staffing and funds to implement new requirements. It should be understood that all facilities do not have the ability to respond as quickly as others and should be given additional time to prepare. My suggestion would be to develop what the future requirements would be, and in many cases, inform the facilities that planning would be required at the time of their next General Sewer Plan or Facilities Plan.

Thank you for considering these comments.

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Comment From: City of Langley (Randi Perry)

3/15/21 @ 3:40 PM

Attachments:

Comment From: Northwest Indian Fisheries Com... (Justin Parker)

3/15/21 @ 3:22 PM
Good afternoon,

Attached, please find a letter and attachment from NWIFC Executive Director Justin Parker to Eleanor Ott, Water Quality Permitting Specialist, Washington State Department of Ecology regarding NWIFC Comments on Draft Nutrient General Pe...↓

If you have any questions, please contact Mike Martinez, NWIFC Habitat Policy Analyst at mmartinez@nwifc.org.

Thank you.
Attachments:
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Comment From: City of Everett (John Rabenow)

3/15/21 @ 3:18 PM
1. =>

B. How does the nutrient action level work with the optimization requirement?

"...Any exceedance of either AL0 or AL1 will trigger further action as outlined in Sections V and VI of the preliminary draft proposal."

Comment: Preliminary analysis of...↓

2. =>

Text box page 9 "Do reviewers have feedback on whether the 95% UCL or 99% UCL is more appropriate for AL0? Ecology has considered both and would like additional input."

Comment: The 99th percentile statistic for the upper confidence level is preferred. The 99th percentile captures the widest variability in the bootstrap calculations of the mean loading.

3. =>

IV. Monitoring and Reporting

A. Monitoring requirements

"...Ecology proposes to require the monitoring schedules shown in Tables 1 - 3, with monitoring beginning one month after the effective date of the proposed general permit."

Comment: One month is a very short timeline to put all the necessary logistical pieces in place to meet the proposed monitoring schedules. WWTP's will face multiple challenges meeting this schedule including hiring additional staff, accreditation for new testing methods, procurement of additional sampling & analysis hardware, development/training/implementation of new testing procedures, and staffing schedules. Propose/recommend/request 3 to 6 months to implement new monitoring schedules.

4. =>

Table 5 � Monitoring schedule: Large treatment plants, > 10 MGD Maximum Month Daily Flow (MMDF)

Comment: The extensive influent nitrate/nitrate (NOx) monitoring requirements are unnecessary. The influent nitrogen loadings are dominated by ammonia-nitrogen and frequent monitoring of ammonia is the priority for characterizing influent loadings. Influent NOx monitoring 4 times per week is unnecessary.

5. =>

Table 5 � Monitoring schedule: Large treatment plants, > 10 MGD Maximum Month Daily Flow (MMDF) footnote B

Comment: 4x/week sampling on a rotating schedule excluding weekends and holidays will be logistically challenging. Propose/recommend/request including holidays and weekends in potential sampling schedules.

6. =>

Text box page 19 "Do reviewers have suggestions on what information permittees use to justify their decision making process when conducting financial and technical analyses to select (or eliminate) optimization strategies?

Comment: As ecology is noted, each facility is a unique combination of treatment processes, and each utility is a unique combination of financial circumstances. Therefore, it may not be possible and it is probably inappropriate, to try to define a universal financial reference point for utilities to all apply to the selection of optimization strategies. Puget Sound wastewater utilities are all responsible for a variety of compliance requirements, as well as sustaining the asset value of the collection systems, treatment facilities, biosolids management programs etc. and consequently all have different financial circumstances, user charge structures, financing plans, and so on. Decision-making on optimization activities is best left to individual utilities who are in the best position to address their site-specific circumstances.

7. =>

Text box page 20 "Are there any additional Tier 1 optimization actions that should be included in this document?"

Comment: The Tier 1 activities outlined in the preliminary draft provide a broad range of potential concepts for optimization that may, or may not, apply to any individual facility depending upon the existing treatment process and where utility begins to consider optimization. This list is adequate as a general outline and is not necessary to provide more specific or restrictive definitions for what constitutes Tier 1 optimization. That is better left to individual utilities to consider in light of site-specific circumstances. It is recommended that Ecology reconsider including septage handling as a consideration for optimization, since this may have the unintended consequence of discouraging the acceptance of septage and the potential to divert septage loadings to potentially inappropriate disposal that could have deleterious impacts on Puget Sound water quality. Source control, or pollutant minimization planning, may be a more appropriate approach to considering whether or not there is a potential to reduce influent nitrogen loadings. However, it is not clear that there are readily available source control techniques for nitrogen as have been found for phosphorus (e.g. laundry detergents and dishwashing detergent reformulations), although there could perhaps be some unique circumstances where there are industrial contributions of ammonia or nitrogen compounds that might be reduced.

8. =>

Text box page 21 "Are the tiers broken out appropriately?"

Comment: The question about breaking out the action by tiers suggests that there may be some priority, or serial order, for the bulleted activities listed under each heading. However, it may be inappropriate to suggest that the tiers be broken out in a greater detail because site specific circumstances will actually dictate what is practical to undertake as the Tier 2 action for any given wastewater facility.

9. =>

Text box page 22 "Ecology is soliciting input on what types of Tier 3 actions plants must take to achieve further nutrient reduction, sooner, if they exceed their second action level trigger. Should these actions vary by facility size?"

Comment: The Tier 3 planning requirements are extensive as written and attempting to parse those activities by facilities sizing may further complicate an already complex set of planning considerations. It may be well advised to allow individual utilities of each size to make their own site-specific decisions about what constitutes a practical and feasible Tier 3 action that best fits their facility.

10. =>

Text box page 22 "Do reviewers have feedback on Ecology's proposed use of a standardized form for the annual optimization report?"

Comment: There are both advantages and disadvantages to using a standardized form for the annual optimization report. A standardized format, especially for reporting numerical data on treatment plant performance and loadings, may be advantageous in structuring uniformity that supports a broader analysis of overall Puget Sound loading conditions. The disadvantage of attempting to structure the annual report uniformly is that each utility will be reporting different information depending upon a variety of factors that include their status with regard to the action levels, the tier level of optimization activities they are pursuing, and the great variety of site-specific facilities differences between each facility.

11. =>

Text box page 27 "Aside from treatment solutions, do reviewers have feedback on types of questions a regional study could answer? How could a regional study like this be used to develop and/or support a nutrient trading framework?"

Comment: There are potential advantages and disadvantages to a regional approach for treatment technology assessments. An advantage may be, as noted in the preliminary draft, the ability for multiple utilities to collaborate on the investigation of new or innovative technologies, without repeating the same investigation for each individual utility. In that way technology evaluations may be shared, and new applications more broadly applied. Regional studies could also explore unregulated compounds in the effectiveness of nutrient reduction technologies in the removal of other constituents.

12. =>

Text box page 27 "Do reviewers prefer one approach to a regional study over the other? Ecology is soliciting specific feedback on how to develop permit requirements for a regional study that advances understanding of treatment upgrades by building on existing bodies of knowledge related to nutrient treatment processes."

Comment: It is not clear what two approaches Ecology is considering? It is also not clear what constitutes a neutral third-party for a technical study of treatment technologies? It is not clear as to whether Ecology seeks a technology evaluation, or an educational process for a collaboration among diverse stakeholders. These may be two separate, or parallel efforts, that are needed to address both technology issues, and separately communication and education issues with the non-technical group of stakeholders.

13. =>

Text box page 27 "Do reviewers have feedback on whether a regional study should be limited to WWTPs < 10 MGD so that larger facilities can conduct their own evaluation? Or, should Ecology provide minimum elements that must be satisfied leaving participation up to each discharger?"

Comment: The regional study could be structured to both receive site-specific input from larger utilities in summary form, with more detail available from their individual evaluations, as well as shared information for smaller utilities to potentially utilize.

14. =>

Text box page 28 "Do reviewers have feedback on the proposed timeframes for this evaluation?"

Comment: Experience from San Francisco Bay suggests that more than 3 to 4 years may be needed to complete a regional study and for Puget Sound it may well take a full permit cycle five years.

15. =>

Text box page 28 "Is there interest in folding this type of treatment technology information sharing into an existing stakeholder process?"

Comment: The existing stakeholder process does not seem to be well suited for technical discussions on treatment technology. It may be more appropriate to share the results of treatment technology studies developed in a separate venue, with the broader stakeholder process.



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Comment From: Cory Prusha

3/15/21 @ 3:18 PM
Hello, I'm the lab person at the City of Oak Harbor.

Our current permit requires BOD (as opposed to CBOD) testing and we no longer carry CBOD accreditation. We would appreciate it if BOD testing can be used in lieu of CBOD testing, as it would be a hi...↓

With regards to Nitrate & Nitrite testing, it'd be helpful if ion selective electrode (ISE) methods could be accredited for the individual parameters. I don't think the LAU currently accepts NO2/NO3 by ISE. If allowed, these tests could be performed in-house once accredited, and thus relieve the burden of outsource test costs on plants and operators. For instance, Ammonia by ISE method is accredited here and is not too taxing of a test.

Thank you for all you can do to make this a nice transition for operators.
The Sound does appreciate your efforts to drive nutrient levels down.
Cory
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Comment From: City of Edmonds (Pamela Randolph)

3/15/21 @ 2:50 PM

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Comment From: City of Kirkland (Julie Underwood)

3/15/21 @ 2:50 PM
Please see our comment letter attached.
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Comment From: City of Lynnwood (John Ewell)

3/15/21 @ 2:05 PM
Please see attached letter dated March 15, 2021.
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Comment From: City of Bothell (Erin Leonhart)

3/15/21 @ 1:25 PM
Please see attached letter.
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Comment From: Pierce County Planning and Pub... (Cassandra Moore)

3/15/21 @ 12:47 PM

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Comment From: Squaxin Island Tribe (Erica Marbet)

3/15/21 @ 12:39 PM
Dear Ms. Ott,
Please see attached comment letter from the Squaxin Island Tribe about the Puget Sound Nutrient General Permit. Please send me a quick email to confirm that you did receive this letter.
Sincerely,
Erica Marbet
emarbet@squaxin.us
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Comment From: City of Bremerton (Tom Knuckey)

3/15/21 @ 12:15 PM

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Comment From: Joseph Lubischer

3/15/21 @ 12:11 PM
Unfortunately, the NGP is effectively an excuse for continuing damaging pollution to Puget Sound by WWTPs. Real solutions, not incremental foot-dragging, is required. Ecology needs to follow the non-degradation law and require AKART level processes, ...↓
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Comment From: LOTT Clean Water Alliance (Wendy Steffensen)

3/15/21 @ 12:08 PM
LOTT Clean Water Alliance
500 Adams St. NE
Olympia, WA 98501

March 15, 2021

Eleanor Ott, P.E.
Water Quality Program
Washington State Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600

RE: Comments on the Preliminary Puget Sound Nutrient General Permi...↓
LOTT Clean Water Alliance


Dear Ms. Ott,
LOTT has been providing nutrient removal for 26 years at the Budd Inlet Treatment Plant. We are one of the few Puget Sound plants subject to stringent discharge permit limits for nutrients. We are also subject to an active TMDL that indicates 20% of the dissolved oxygen impairment to our receiving waters is from wastewater discharges and non-point sources north of Budd Inlet. LOTT is encouraged that the proposed Puget Sound Nutrient General Permit provides a pathway to reduce a portion of this nutrient loading.
LOTT upgraded its secondary treatment plant in the early 1990s to meet nutrient removal requirements. The upgrade involved new treatment basins/tankage to provide aeration and anoxic zones and piping to recycle treated wastewater through the zones repeatedly. The upgrade cost over $30 million at the time. Once the system was built, LOTT began to optimize the process, taking advantage of some of the actions listed in Tier 1 and Tier 2. LOTT has just begun an ambitious upgrade of the nutrient removal system to further optimize the process. Construction of the current project will cost about $29 million. LOTT ratepayers' investments in nutrient removal have been substantial.
Thank you for the opportunity to provide comments on the preliminary draft nutrients permit. LOTT's comments are presented below.
1) LOTT requests treatment plants that discharge less than 10 mg/L AND that stay under the AL0 threshold be exempt from optimization requirements and from the annual optimization report requirement. The rationale/benefit of requiring optimization and an optimization report from that category of dischargers is not clear, and would be burdensome. It would also be burdensome to Ecology, who would have to spend limited resources tracking and reviewing reports for plants that are meeting expectations for nutrient reduction. It should also be noted that plants like LOTT that already have nutrient removal processes are actively optimizing 24/7 � documenting those many daily steps appears unnecessary and unproductive. An exemption would make the steps outlined in the Appendix A Action Level Flow Chart more equitable. Currently, the chart does not acknowledge a scenario in which plants that discharge less than 10 mg/L also stay under AL0. That level of performance should be recognized by reducing optimization requirements.
2) LOTT is concerned about the cost and staff time implications of the dual monitoring and reporting requirements. It would be helpful to understand how the General Permit and Individual Permit reporting requirements will be streamlined.
3) Treatment plants without existing nutrient removal processes are unlikely to have adequate tankage to support effective aeration and anoxic zones. Without the tankage, the benefit of many of the Tier 1 and 2 optimization actions is likely to be limited.
4) The methodology used to set the AL0 and AL1 thresholds seems reasonable and workable.
5) In section III D, page 11, a reference is made to design flow. Please specify to which design flow this refers (Maximum Month Design Flow (MMDF), Maximum Day Design Flow, or Peak Hourly Design Flow).
6) Please include units for AL0 and AL1 in Table 4.
7) Bioaugmentation might be a good addition to Tier 3.
8) The types, information, and triggers required for the various reports and plan are unclear. A table with this information would help illustrate the differences for each of these.
a. It seems that the annual report and the annual plan are the same thing. Are they?
b. Is the Nutrient Reduction Evaluation report supposed to be a one-time requirement, due at the end of the permit term? If this requirement will be addressed by C1, why is it listed separately?
9) In Section VI C, page 27, a reference is made to TN. Should this be TIN?
10) LOTT is in favor of a regional study, option C1, where Ecology gathers the needed data for all plants of all sizes.
11) The two options given for regional studies do not seem to be in conflict. LOTT supports both.
Thank you for your consideration.

Sincerely,
Lisa Dennis-Perez
Director of Environmental Planning & Communications



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Comment From: City of Port Angeles (Thomas Hunter)

3/15/21 @ 11:16 AM
Comments are provided in the attached document.
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Comment From: Northwest Environmental Advoca... (Nina Bell)

3/15/21 @ 11:09 AM
remainder of attachments
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Comment From: Northwest Environmental Advoca... (Nina Bell)

3/15/21 @ 11:06 AM

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Comment From: City of Anacortes WWTP (Corrin Hamburg)

3/15/21 @ 10:54 AM
See attached document.
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Comment From: Valley View Sewer District (ANDREW LARUE)

3/15/21 @ 9:40 AM
Dear Ms. Ott:
I am writing to share the Valley View Sewer District's (District) concerns about the Washington State Department of Ecology's (Ecology) proposed draft Puget Sound Nutrient General Permit for municipal wastewater treatment facilities that...↓

The District is a collection-only system and partners with three public agencies for wastewater treatment. The District is concerned its treatment providers have not been given adequate time to consider the future permit requirements and the costs associated with implementing new technology and equipment, if necessary. The District recognizes Ecology's responsibility to maintain compliance with water quality standards and to address dissolved oxygen (DO) impairment in sensitive areas of the Sound and encourages discussion with Cities and Districts that treat and discharge wastewater. While attending regional planning meetings, representatives of the District have been provided the following talking points we would like Ecology to consider.

We appreciate Ecology's efforts to examine how nutrients contribute to DO reductions and specifically anthropogenic sources of nutrient loading. There are, however, significant uncertainties and gaps in scientific information and disputed science regarding the relative impact of anthropogenic sources on DO levels. For example, there are many scientific uncertainties associated with understanding DO depletions in Puget Sound and the use of the Salish Sea Model (SSM) as the tool to support regulatory requirements. Additionally, Ecology has not fully considered the environmental trade-offs such as the increase in greenhouse gas emissions that occurs with increased nitrogen removal.

Given the significance of imposing additional regulatory requirements, our region must be assured that these investments will result in significant water quality improvements. Natural oceanic circulation Puget Sound accounts for 88 percent of the nitrogen inputs. Of the remaining 12 percent, wastewater treatment plants account for approximately 70 percent. Ecology's proposed draft nutrients general permit could require investing billions of dollars to even reduce nutrient discharges from wastewater treatment facilities by 30 percent. This is not the most cost-effective solution and is very unlikely to achieve our shared goal of making significant strides in improving Puget Sound water quality.
Early modeling shows it will take a combination of non-point and point source to achieve meaningful reductions in nutrients. The region's wastewater utilities are committed to working with Ecology on watershed modeling and refinement of non-point source contribution of nutrients in Puget Sound. This technical information is necessary to build regional understanding and identify potential management actions related to non-point nutrient sources. There may be other, more cost-effective solutions to meet the low dissolved oxygen levels, and we deserve to know what the best solutions are to restore Puget Sound.
Our residents are living in an economy already experiencing severe impacts from COVID-19, and adding additional cost burdens without fully exploring the most cost-effective solutions is very problematic. Recognizing the affordability challenges both near and long term for many residents in the Puget Sound region, if Ecology proceeds with setting new standards, it should include other potential compliance options such as bubble permits or a regional water quality trading program, along with new governance structures to implement such approaches, which could prove to be less costly and more effective for improving water quality.

Finally, the District recommends that Ecology extend its nutrients general permit schedule to allow sufficient time to implement the following approach for improving water quality in the Sound:
• Establish an independent panel of scientists and engineers to make recommendations on the effectiveness of alternatives and identifying solutions that would achieve the greatest water quality benefit for the investment,
• Extend the nutrients general permit schedule to enable other alternatives (e.g., water quality trading and bubble permits), and
• And collaborate with interested parties to develop a regional plan that includes feasibility and affordability.
I want to thank you in advance for your consideration of our comments. If you have any questions, please feel free to contact me anytime at (206) 242-3236 or andrewl@valleyviewsewer.org.

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Comment From: Gordon Holtgrieve

3/15/21 @ 9:18 AM

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Comment From: Phyllis Farrell

3/15/21 @ 9:05 AM
Puget Sound degraded water quality is affecting salmon/orca recovery, the shellfish industry and public health. DOE should require all wastewater permits to transition to nutrient removal technology under the Clean Water
Act. Jurisdictions should be ...↓
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Comment From: RE Sources (Kirsten McDade)

3/15/21 @ 8:56 AM
Please see attached letter.
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Comment From: Jamestown Tribe (Sissi Bruch)

3/15/21 @ 8:27 AM

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Comment From: Karen Bertram

3/15/21 @ 8:04 AM
As a life-long resident of Puget Sound, I've observed a lot of progress toward cleaning up our lakes, rivers, and Puget Sound, and improving our water treatment methods. But several factors continue to put pressure on our waters. These include the ev...↓
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Comment From: City of Seattle, Seattle Publi... (Andrew Lee)

3/15/21 @ 7:33 AM
Please see the attached document containing Seattle Public Utilities comments on the Puget Sound Nutrient Permit Preliminary Draft language.
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Comment From: Loren Combs

3/15/21 @ 6:54 AM
Having lived in the Puget Sound region since 1962, I have seen the great changes that state and local governments have made to try and keep Puget Sound a viable ecosystem for salmon, orcas and other native sea life; but we can and must do better. Ta...↓
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Comment From: Edwin Kellison

3/14/21 @ 4:51 PM
Now is the time to clean up our waterways. We wasted the last four years with that administration, and we need to make up for that loss. Cleaning up our waterways should have begun 20 years ago. Why do we wait until we have a problem that needs to be...↓
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Comment From: Paul Pickett

3/14/21 @ 4:50 PM
• It's wonderful that you are doing "Straight to Implementation" approach and getting permits in place. But your position is weaker without a TMDL in place for South Sound nutrients. Issuing permits is important, but also put a TMDL in place ...↓
• II.C: There is a missed opportunity to remove WWTPs up in the watershed. They should be included in the General Permit, if only to require monitoring.
• The Nutrient Action Levels are complex and one area where assessment of the methodology is needed. This look like a key part of the permit – who has to take action and who doesn't. Describe how plant size is taken into consideration. Describe how the economic base of the plant is considered.
• The tiered monitoring structure seems reasonable. Some analysis into the monitoring should be described to show whether the correct parameters are being monitoring at a reasonable frequency.
• The Optimization section seems fuzzy. It is difficult to understand exactly what it proposes. It also could benefit from a stronger engineering-based approach with firm and clear expectations and assessment metrics. An NPDES permit is not a group counseling session, it's a regulatory prescription.
• The Planning Section is even fuzzier. It appears to overlap the Optimization section, which is confusing. The idea of a "layer of onion" approach is good, but it needs to be laid out more clearly in defined components, with the interaction of components described. What you seem to be suggesting is: 1) the plant-based engineering assessment; 2) a source assessment – how to reduce nutrients with upstream strategies in the communities feeding the WWTP; 3) regional strategies for cooperation or consolidation between plants, or consistent source control strategies at a regional scale. This needs more analysis and a restructuring with revisions for clarity and focus.
• I'm not sure how Ecology can mandate any regional activities beyond what an individual plant controls. Ecology should consider rule-making for regional activities.
• The modeling is mentioned in several areas. It drives this permit in many ways, but it's also mentioned as being inadequate for some decisions. This could be explained more clearly.
• Overall the structure and benefits of the permit should be explained from a high level. The permit appears to just do a lot of paper shuffling while nutrient loads continue to climb. If this is not true, evidence should be provided about his it will effectively reduce nutrients.
o The permit should trigger actions that reduce nutrients "immediately" (i.e. in the first 5-year permit cycle). The current draft permit looks like it requires a lot of planning and paperwork, but little substantive and quantifiable results.
o Has the age of the plant been considered – older plants would be ripe for upgrade.
o Do the annual reports have teeth – are they linked to monitoring so reductions can be demonstrated?
o Permits are supposed to have effluent limits. Does it set enforceable permit limits at the beginning and end of the first 5-year permit cycle? Does it lay out a long-term target for nutrient reduction with a reasonable horizon of planning, funding, engineering, construction, and initiation of treatment operations?

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Comment From: Roche Harbor Wastewater Treatm... (Jason Miniken)

3/14/21 @ 3:04 PM
I am very concerned for our small communities ability to pay for additional costs associated with this Draft Nutrient Permit. There is a considerable increase in nutrient testing in this permit. Its not a small task to take samples to the mainland la...↓
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Comment From: Ed Boehmer

3/14/21 @ 10:07 AM
I totally agree that we have "kicked the can down the road too long". It is time for the public and the local jurisdictions to pursue financing on both local, national and state levels. New developments and construction to improve the tax base and ...↓
I think if Olympia can begin in 1984 these other counties have been ignoring the problem and now must step up. Take out bonds, have our senior Senators go after some of this infrastructure money that is being talked about. A little proactive approach helps rather than reactive which seems to be the norm!
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Comment From: Emma Song

3/13/21 @ 1:39 PM
We support a Nutrient General Permit for ALL wastewater treatment plants that discharge to the Puget Sound-not just direct dischargers!! The largest polluters MUST do more to stop their pollution.
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Comment From: Sarah Polda

3/12/21 @ 8:06 PM
Please adopt the permit to make sure out water is healthy.
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Comment From: Puget Soundkeeper (Alyssa Barton)

3/12/21 @ 7:30 PM
Please see the attached PDF letter.
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Comment From: Lake Stevens Sewer District (Mariah Low)

3/12/21 @ 6:53 PM

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Comment From: Washington Department of Healt... (Mark Toy)

3/12/21 @ 5:42 PM
Letter of support attached.
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Comment From: Fisherman Bay Sewer District (Monico Mackinnon)

3/12/21 @ 3:19 PM
Please see attached file.
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Comment From: Kitsap County Sewer Utility (Chris Sheridan)

3/12/21 @ 3:17 PM
Please see uploaded file for comments.

KITSAP COUNTY RESPONSE TO DOE's PUGET SOUND NUTRIENT GENERAL PERMIT (PSNGP) PRELIMINARY DRAFT, JANUARY 2021

General Comment:
1. Reclamation and Reuse of POTW effluent is not mentioned in the preliminary draft as a ...↓
Specific Comments:
2. Section II.C. Facilities excluded from Permit Coverage, pg 5: "Federal and tribal facilities. Ecology does not have delegated authority to write NPDES permits for these treatment plants. EPA is the responsible permitting authority for federal and tribal wastewater treatment plants in Washington State. Conditions for nutrient controls will be implemented through the 401 Water Quality Certification process."
Section II.D Facilities with current limits: "Results from the individual permit's monitoring requirements may be used to satisfy the general permit's monitoring schedule provided the timing and frequencies align. Ecology will work to streamline permit compliance between the proposed general permit and active individual permits."

Kitsap County Comment: The Suquamish Wastewater Treatment Plant's NPDES is administered by the EPA. WA State DOE has issued a 401 Water Quality Certification Letter certifying EPA's recently issued NPDES permit with conditions.
• Will the Suquamish Wastewater Treatment Plant permit monitoring requirements (timing and frequency) as described in the 401 Certification prevail or will monitoring requirements need to comply with the PSNGP?
• Will conditions for nutrient controls found in the PSNGP be included in future 401 Water Quality Certifications issued by DOE?
• If PSNGP nutrient controls are to be included in future 401 Water Quality Certifications, then will Ecology use the Nutrient Action Level Calculation Methods as described in section III.C?
Please comment or expand on future coordination efforts related to issuing 401 Water Certification letters.

3. Section III.C. Calculating the baseline, AL0 , pg 9: "Monthly or more frequent data were available for 28 facilities. Quarterly or less frequent data were available for 19 facilities. Some facilities sample different parameters on different frequencies. Ecology made the following assumptions"
Kitsap County Comment: Kitsap County believes that Ecology is making several assumptions in the bullets that follow the statement above that will affect the accuracy of the baseline AL0. This baseline is critical to the success of future optimization metrics. The County has confidence in the accuracy of the reported sample results but not that the data is representative of historical TIN discharge loads at each POTW outfall. For example; past scheduling of ammonia and nitrate-nitrogen was influenced by staff workflow and scheduling of couriers between the County plants. This resulted in no samples collected during weekend days. This oversight provides a sampling profile that does not consider the impacts of weekend loadings at the POTW.
All POTW's covered under the PSNGP will benefit from a defined sampling and monitoring plan as described in section IV of the PSNGP. However, a verified baseline for AL0 at the conclusion of permit year 2 should be the basis for Tier 2 and 3 actions.
4. Section III.D Facilities discharging less than 10 mg/L Total Inorganic Nitrogen: "Ecology proposes that facilities currently discharging 10 mg/L TIN or less do not need to complete actions beyond monitoring and annual optimization reporting during this permit cycle, provided they are able to stay below AL1. For those 13 facilities that qualify, Ecology proposes that AL1 be calculated as 10 mg/L concentration for 85% of the design flow, the capacity at which all plants are required to plan for maintaining capacity." "These facilities are not required to implement Tier 2 nutrient reduction actions if AL0 is exceeded. If AL1 is exceeded, these facilities must select and complete a Tier 3 action."
Kitsap County Comment: Kitsap County understands that the Kingston Wastewater Treatment Plant's AL1 calculation is based on the 85% design capacity for this permit cycle due to the plants historical TIN discharge of less than 10 mg/L.
• Will the AL1 calculation be revised if the TIN concentration exceeds an annual average of 10 mg/L for a calendar year during the first permit cycle?
• Will the AL1 calculation be revised if a WQBEL is developed during the first permit cycle?
• If in the second permit cycle a WQBEL is developed and included as a condition of TIN discharge limit in either a general permit or individual permit; then will POTW's with the AL1 calculation exception be provided a schedule to complete Tier 2 and/or Tier 3 actions?
Ecology needs to explain how the modification to AL1 will be carried through into the second permit cycle and/or if WQBEL's are issued. This is necessary so the County can develop capital improvement plans beyond a 5-year horizon.

5. Section III.E Calculated action load options by facility, table 4 pg 12: "Ecology's individual permit managers worked with their dischargers' data to determine the range of previously collected representative effluent data for use in the total inorganic nitrogen load limit calculation."
Footnote at bottom of table 4 for Kitsap County Central Kitsap WWTP*** reads "Insufficient TIN data for AL calculation".
Kitsap County Comment: Kitsap County disagrees that there is insufficient data to calculate the action level for the Central Kitsap Wastewater Treatment Plant. Per conversation with DOE's Facility Manager, the data source for this calculation is from PARIS. PARIS only reports data that is required by the permit and included in the DMR. If a permittee performs analysis on Ammonia and/or Nitrate-Nitrogen more frequently than the permit requirement the formatting of Web DMR / SAW does not provide a field to enter the daily data result for reporting.
Kitsap County request Ecology recalculate the Central Kitsap Wastewater Treatment Plant action level with additional data provided by the County to Ecology's Facility Manager. A copy of the .csv file is uploaded to the e-comments site provided by Ecology and has been emailed separately to the Ecology's Facility Manager.
6. Section IV.A Monitoring Requirements, Table 6 and Table 7: Monitoring requirement to analyze influent Nitrate plus Nitrite Nitrogen.
Kitsap County Comment: Kitsap County does not see the value for monitoring this parameter as frequently as proposed. Recommend influent sampling of ammonia-nitrogen only.
7. Section IV.A Monitoring Requirements, Footnote B typical of all in Table 5, 6, and 7: "1/week means one (1) time during each calendar week and on a rotational basis throughout the days of the week, except weekends and holidays".

Kitsap County Comment: Allowing an exception for weekend sampling will not account for a true representation of influent and effluent load characterization. Recommend striking "weekends" from footnote B.

8. Section IV.A Monitoring Requirements, Table 6 and Table 7:
a. The proposed monitoring schedule for medium treatment plants shown in Table 6 requires the additional analysis of CBOD5 and Total Organic Carbon. These parameters are not required in the current permit for Central Kitsap Wastewater Treatment Plant.
b. The proposed monitoring schedule for medium treatment plants shown in Table 7 requires the additional analysis of Total Organic Carbon. These parameters are not required in the current permit for the Kingston and Manchester Kitsap Wastewater Treatment Plants.
c. The proposed monitoring schedule for Total Ammonia, Nitrate plus Nitrite and Total Kjeldahl Nitrogen is an increase of 12 times the analysis per month compared to existing Central Kitsap permit monitoring requirements. This is also an increase of 6 times the analysis per month for Manchester, Suquamish and Kingston,

Kitsap County Comments: The County understands that new effluent permit requirements will re-prioritizing testing in our accredited laboratory. However, Ecology must be aware that this increased labor and the process to obtain accreditation cannot be addressed in a short time period. Also, the capacity of private sector labs may be tested in the short term with a wave of new testing. For example; most POTW labs are not accredited to analyze Total Organic Carbon therefore options are limited to either obtaining DOE accreditation or send the samples to an outside lab.

The additional frequency and the requirement to collect samples representative of an entire month for the analysis of Total Ammonia, Nitrate plus Nitrite and Total Kjeldahl Nitrogen may require labs to perform analysis of these parameters in batches. Scheduled sample collections in the last week of a month will make it difficult to for a municipal and contract lab to return results in time to report on the DMR by the 15th of every month.
• Ecology must recognize that enforcing the proposed new monitoring schedule "one month after the effective date of the proposed general permit" (pg 14) is not realistic for Kitsap County.
• Ecology should consider modifying the DMR submittal date to the 20th of each month to accommodate the proposed PSNGP sampling schedule.

9. Section V.C Tier 2 actions, pg 20: In answer to "Are there any additional Tier 2 optimization actions that should be included in this document?"
Kitsap County Comment: Recommend including "planning for effluent reclamation and reuse" to divert TIN loadings from the POTW outfall."

10. Section V.C Tier 3 actions, pg 22: In answer to "Ecology is soliciting input on what types of Tier 3 actions plants (sp) must take to achieve further nutrient reduction, sooner, if they exceed their second action level trigger. Should these actions vary by facility size?"

Kitsap County Comments: Recommend including "design for effluent reclamation and reuse" to divert TIN loadings from the POTW outfall" as a Tier 3 action.

11. Section V.D Nutrient Optimization Plan Components, item e: "Evaluate the different optimization strategies identified in C.ii to maximize nitrogen removal capabilities and select the actions your facility will implement over the next year. Provide detail on cost implications and lack of affordability for those strategies not selected due to financial reasons."
Kitsap County Comments: In the first year of the general permit the requirement to provide detail on cost implications is not realistic. It may take several years and external expertise to provide cost implications. Recommend revision "provide an estimate of cost implications..."
12. Section V.D.c.ii Nutrient Optimization Plan Components: "Identification of recommended actions to improve the facility's nitrogen removal performance"
Kitsap County Comments: Component C is unclear and requires a better description.
• If a POTW consistently maintains a concentration below 10 mg/L TIN as described in C.ii.1 then what does "then maintain or work to improve performance" mean?
• If a POTW consistently maintains a concentration below 10 mg/L then is POTW required to develop facility specific nitrogen reduction optimization strategies as described in items d, e and f?

13. Section VI Planning Requirements:
• "...each plant that is not already achieving TIN concentrations <10 mg/L will be required to conduct a nutrient reduction evaluation during this first permit cycle." pg 25
• "The above proposed Nutrient Removal (sic) Evaluation is not intended to be an engineering report. Rather it is a feasibility investigation and does not require the level of detail required in WAC 173-240-060 for an engineering report. It will, however, require the seal of a registered professional engineer given that it is a document that will be reviewed under RCW 90.48.110." pg 26
• "If a WWTP formally chooses instead to develop their own independent, facility specific nutrient reduction evaluation, it must be submitted in permit year 3." Pg 27 2nd bullet

Kitsap County Comments: Kitsap County understands the importance of the Nutrient Reduction Evaluation report. The report described in this section is comprehensive, and even though it may not be intended to be an engineering report, it will require specialized expertise to develop. The County is concerned that the engineering expertise may not be available if many POTW in the Puget Sound region are contracting for this service. Ecology should note that the proposed timeline of 5 years (first permit cycle) on page 25 conflicts with the 2nd bullet on page 27 requiring submittal in permit year 3.

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Comment From: Lakehaven Water and Sewer Dist... (John Barton)

3/12/21 @ 1:44 PM

Attachments:
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Comment From: Robert Johnson

3/12/21 @ 10:37 AM
Comments contained in the attached PDF file (Comments on General Permit_Post Point_March 2021.PDF.
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Comment From: Midway Sewer District (Marc Montieth)

3/11/21 @ 5:00 PM
See attached
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Comment From: Washington State Department of... (Valerie Smith)

3/11/21 @ 4:51 PM

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Comment From: Washington Association of Sewe... (Judi Gladstone)

3/11/21 @ 2:55 PM
The Washington Association of Sewer & Water Districts (WASWD) has a significant interest in the development of a Puget Sound Nutrient General Permit (PSNGP). Many of our members operate wastewater treatment plants sending effluent to the Sound, or co...↓

After reviewing the Preliminary Draft Permit released by Ecology on January 26, we have the following general comments:

1. Better scientific foundation: Since discussions began about the general permit, utilities have disputed the science behind the proposed regulations. Gaps in data, uncertainties, and understanding of local and regional impacts have not been explained. This has been particularly true for dissolved oxygen standards, which are over 50 years old, and have no scientific basis. Without reliable science that demonstrates how permit requirements will produce significant benefits to the Puget Sound ecosystem, major expenditures of public money to meet General Permit requirements could be wasted at the expense of more beneficial actions for Puget Sound water quality.

2. More practical approach to small treatment plants: The Draft's handling of small wastewater plants is contradictory and problematic. As was pointed out in the Advisory Committee process, the bulk of the covered treatment plants are relatively small and contribute minor amounts of nutrients to the Sound. Of the 58 plants proposed to be covered by the General Permit, the 41 plants with the smallest current flows contribute a total of 5% of total nutrients coming from the 58 facilities. The 33 smallest plants taken together contribute about 1%. Forcing these facilities to be completely rebuilt to meet new standards would be enormously expensive for their ratepayers, with insignificant reductions of nutrients.

3. Better distinction between regions of the Sound: There may be reasons to require improvements to certain small facilities, depending on their location and circumstances. However, the proposed permit treats all plants throughout the region as contributing to the Dissolved Oxygen problem based on Nitrogen concentrations and flows, and not factoring in locations. We believe this to be incorrect and not backed by the science. A facility discharging to a confined inlet with sensitive receptors is not the same as one that releases into the middle of Central Puget Sound. Ecology's maps show what appear to be highly localized areas of Dissolved Oxygen impacts, yet the General Permit treats it as a Sound-wide problem.

4. More sound basis for triggers: The draft permit relies on a statistical method� "bootstrapping"�to turn minimal amounts of data into measurements of current discharge levels. While we have not seen any report showing how many monitoring points the various plants have available for this calculation method, Ecology staff has implied that at some facilities it might be a dozen or less over three years. This is not enough to accurately characterize a facility's nutrient loading through seasonal variations, weather swings and pandemics. Since all agree that more data is needed, the monitoring program should not only support robust data acquisition for characterization, but also be designed to evaluate optimization since this will, at least initially, be the primary means by which nutrient levels are kept below action levels.

5. Better defined tiers and triggers: The proposed "tiers and triggers" are going to tip most plants into significant expenditures in the near term. Even plants that are comfortably under the 10 mg/L level are being required to carry out "optimization" programs, many of which can be costly. Very small plants will likely be kicked into Tier 3 actions�in many cases requiring significant reconstruction with new technology. In some cases, large plants have no space for expansion or reconstruction, and may need to seek to build entirely new facilities elsewhere. Since the "tiers and triggers" are what will set requirements for plants, they need to realistically take into account concerns about science, the insignificance of contributions of small facilities, and timing of required improvements.

6. More realistic timelines: The draft permit requires action on extremely aggressive schedules in several ways. Significant increases in monitoring would be required just one month after the permit's effective date. Many utilities are not able to add staff and budget in that timeframe. It is also unknown whether commercial labs (or Ecology staff) can handle the surge in new sampling and data generation. The draft permit is also unrealistic in its schedule for treatment improvements. Major facility improvements require ten or more years to plan, design, permit, construct, and put into operation. The 5% margin allowed over current levels, especially combined with the aggressive timeline for compliance, is likely insufficient to prevent moratoria on new connections with the growth faced by the region. In addition, Water Quality Base Effluent Limitations (WQBELs) are not expected to be established before 2023. Planning facilities before these limits are known could result in unnecessary or ineffective costly facilities. Having WQBELs set for each plant before major investments are required ensures better outcomes for the region and that limited funds are wisely spent. Finally, annual nutrient optimization plan submittal and review by Ecology raises real concerns about the financial and personnel needs locally and at Ecology in order to accomplish this in a timely fashion. Scientific scrutiny and discussion with the WWTPs will be something akin to a discharge permit renewal. This will take time that the nutrient permit does not seem to allow for. WASWD supports the Utility Caucus Proposal which was presented to Ecology and the Advisory Committee in October 2020, and is attached with this letter. This document advances more realistic timelines for steps in the permit.

We share the concerns of all the stakeholders of the Advisory Committee about water quality in Puget Sound. The current permit proposal, however, is based on disputed science, unrealistic timelines for compliance, and apparent disregard for costs to the public. The comments in this letter aim for permit requirements that will produce effective and affordable protection of Puget Sound water quality.

Thank you for considering these comments.

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Comment From: Lake Whatcom Water and Sewer D... (Justin Clary)

3/11/21 @ 8:36 AM
Please refer to the attached comment letter.
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Comment From: Stacey Pierro

3/10/21 @ 5:00 PM
I am deeply disappointed that Ecology is proposing to postpone taking the necessary action to address the serious problem of sewage treatment plants’ discharging nitrogen and toxics to Puget Sound. Ecology has known for more than 20 years that munici...↓
This new proposal to issue a general permit allowing 58 sewage treatment plants to continue discharging unsafe levels of pollution into Puget Sound would be a mistake. Knowingly worsening Puget Sound’s impaired water quality will only make clean-up more difficult and expensive. This proposal is contrary to the Clean Water Act and to Washington laws that require the use of modern sewage treatment to keep water quality as clean as possible.
I urge you to change course. Ecology should begin issuing discharge permits that contain pollution limits that will protect Puget Sound now and into the future.

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Comment From: Washington Resource Conservati... (Ryan Anderson)

3/09/21 @ 6:40 PM
Thank you for the opportunity to comment on the Puget Sound Nutrient General Permit Preliminary Draft.

The Washington RC&D (WRC&D) supports the permit and its goal of nutrient reduction in Puget Sound.

In particular the permit mentions in C.2., utiliz...↓

The Washington RC&D facilitate collaborative efforts like these for watershed restoration, forest health, climate resilience, and salmon recovery and we can attest to the value of 3rd party facilitation for accelerated understanding and action.

Thank you for the hard work developing the draft permit and for including collaborative capacity in the potential implementation of nutrient reduction in Puget Sound.

Please feel welcome to reach out to us with any questions about our experiences with collaboration building processes.

Sincerely,

Ryan Anderson, Executive Director
Washington Resource Conservation and Development Council
ryan@washingtonrcd.org

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Comment From: Mukilteo Water and Wastewater ... (Kendra Chapman)

3/09/21 @ 4:41 PM
Mukilteo Water and Wastewater District Board of Commissioners' comment letter attached.
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Comment From: Mukilteo Water and Wastewater ... (Jim Voetberg)

3/09/21 @ 4:40 PM
Comment letter attached.
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Comment From: Alderwood Water & Wastewater D... (Dick McKinley)

3/09/21 @ 9:32 AM
Comments are being uploaded as a file to this site.
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Comment From: BHC Consultants (Tom Giese)

3/05/21 @ 5:04 PM
Comments are provided in the attached document.
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Comment From: John Marshall

2/27/21 @ 9:46 AM
The conceptual draft nutrient, i.e., nitrogen, general permit must incorporate source control as a primary strategy to eliminate nutrient pollution, rather than expensive end-of-pipe treatment plant upgrades. Urine contributes eighty percent of the ...↓
Ref: Water Environment Research 2015 Dec 87(12) pgs 2120-2129 "Source separation of urine as an alternative solution to nutrient management in biological nutrient removal treatment plants;
Elser, J., Bennett, E. A broken biogeochemical cycle. Nature 478, 29–31 (2011);
http://www.novaquatis.eawag.ch/publikationen/final_report_E.pdf. NoMix, a new approach to urban water management.
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Comment From: Laurie Sherman

2/22/21 @ 1:19 PM
I am very much in favor of cleaning up Puget Sound Waters. Balancing the nutrients released from waste treatment plants is key to healthy ecosystem. Its past time to clean up, I only hope the changes made will be enough, soon enough. Whatever the cos...↓
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Comment From: Eastsound Sewer and Water Dist... (Christopoher Giesting)

2/16/21 @ 3:12 AM
We here at Eastsound Sewer and Water District (ESWD) have the following comments:

1) We are a septic tank effluent pump system collection system (STEP). In this process there is an unusually low carbon to nitrogen ratio due to carbon being lost in the...↓

2) Increased sampling costs for nutrient analysis is going to result in rate increases for the ESWD customer base. Is an inhouse HACH TNT/spectrophotometry method going to suffice for this sampling. Will Ecology supply WWTPs these items? Will there be grants available for analytical laboratories for systems with lack of funds?

3) ESWD is in the design phase for an upgraded WWTP. Once this plant is built and operational, will we have the same action levels (AL), or will we have to establish new levels based on additional sampling?
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Comment From: Dan O'Donnell

2/15/21 @ 6:21 AM
This comment concerns the La Conner wastewater treatment treatment plant. Since 1976 the plant has discharged to the Swinomish Channel. I believe it should discharge to the nearby Sullivan Slough.

The slough provides the necessary mixing by virtue o...↓

Dan O'Donnell

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Comment From: Larry Mccarter

2/14/21 @ 8:39 AM
thank you. Please make the changes that protect the ecology of the Puget Sound. Stop allowing City's to dump into our bay if they can do better, insist on it asap.
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Comment From: Sandra Butterfield

2/10/21 @ 7:55 AM
The science is clear on net pens in Puget Sound. They do not belong here. Removing them is the answer to increasing the health of native salmon species and saving Salish Sea resident Orca pods.
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Comment From: Joseph Hiss

1/27/21 @ 1:46 PM
Whatever you do to reduce nutrients, please consider expected population growth, increases in sewage load, sea level rise, temperature and rainfall change, and ocean acidification, all at the finest scale possible, since these data will vary somewhat...↓
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