Rulemaking - Aquatic Life Toxics Criteria, Chapter 173-201A WAC

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Comment From: Suquamish Indian Tribe of the ... (Denice Taylor)

5/07/24 @ 5:48 PM

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

5/07/24 @ 4:57 PM

Good afternoon,

Please find the attached letter and attachment from NWIFC Executive Director Justin Parker, to Marla Koberstein, Water Quality Program, Washington Department of Ecology, regarding Comments on Proposed Aquatic Life Toxics Criteria.

I...↓

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Comment From: Port of Tacoma (Mindi Kellar)

5/07/24 @ 4:28 PM

The Port of Tacoma appreciates the opportunity to provide comments on the proposed updates to the Aquatic Life Toxics Criteria, WAC 173-201A-240 (Code). As a stormwater permittee, we are very concerned about the impacts of 6PPD-q to water quality. H...↓

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Comment From: Puget Soundkeeper (Emily Gonzalez)

5/07/24 @ 4:26 PM

Please see attached comments on Rulemaking - Aquatic Life Toxics Criteria, Chapter 173-201A WAC submitted on behalf of Puget Soundkeeper.

Thank you!
Emily Gonzalez

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Comment From: Kamuron Gurol (Kamuron Gurol)

5/07/24 @ 4:16 PM

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Comment From: Squaxin Island Tribe (Erica Marbet)

5/07/24 @ 4:03 PM

Please find attached letter from the Squaxin Island Tribe and technical review memo on Rulemaking - Aquatic Life Toxics Criteria, Chapter 173-201A WAC. Sincerely, Erica Marbet

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Comment From: Port Gamble S'Klallam Tribe (Josh Carter)

5/07/24 @ 3:31 PM

Please see attached.

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Comment From: The Aluminum Association (Andrew Smith)

5/07/24 @ 3:26 PM

The Aluminum Association thanks Washington Department of Ecology for the opportunity to submit comments on their revisions to chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington. Please see the attached file fo...↓

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Comment From: Jamestown S'Klallam Tribe (Alex Scagliotti)

5/07/24 @ 2:15 PM

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Comment From: Andrew Kenefick

5/07/24 @ 1:59 PM

Please see the attached comment.

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Comment From: Kennewick Irrigation District (Seth Defoe)

5/07/24 @ 1:44 PM

Please find attached a comment letter from the Kennewick Irrigation District.

Thank you for the opportunity to comment on the proposed rule change.

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Comment From: Alkylphenols & Ethoxylates Res... (Barbara Losey)

5/07/24 @ 1:15 PM

Attached are comments of the Alkylphenols & Ethoxylates Research Council regarding the proposed rule for Aquatic Life Toxics Criteria, Chapter 173-201A WAC.

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Comment From: Lake Washington/Cedar/Sammamis... (Mary Ramirez)

5/07/24 @ 12:57 PM

On behalf of the Lake Washington/Cedar/Sammamish Watershed (WRIA 8) Salmon Recovery Council, please accept this letter of support for the Department of Ecology's proposed update to aquatic life criteria for Water Quality Standards for Surface Waters ...↓

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Comment From: U.S. Tire Manufacturers Associ... (Stephanie Schlea)

5/07/24 @ 12:55 PM

On behalf of the U.S. Tire Manufacturers Association, please see the attached comments in response to Washington Ecology's proposed revisions to chapter 173-201A WAC, Water Quality Standards for Surface Waters of the State of Washington.

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Comment From: US EPA (Lindsay Guzzo)

5/07/24 @ 11:59 AM

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Comment From: Washington Council of Trout Un... (Andrew Kenefick)

5/07/24 @ 11:40 AM

Please see the attached comments of the Washington Council of Trout Unlimited on Ecology's proposed water quality criterion for 6PPD-quinone. Thank you for considering them.

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Comment From: South Columbia Basin Irrigatio... (John O'Callaghan)

5/07/24 @ 11:13 AM

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Comment From: Puyallup Tribe (char naylor)

5/07/24 @ 11:03 AM

Please see our comments and the attached technical memo (uploaded files). Thank you for the opportunity to comment on behalf of the Puyallup Tribe.

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Comment From: Center for Biological Diversit... (Hannah Connor)

5/07/24 @ 10:00 AM

Please accept the attached comments filed on behalf of the Center for Biological Diversity. The Center's comments will be provided through three submissions to relay all relevant attachments. This is submission 3 of 3.

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Comment From: Center for Biological Diversit... (Hannah Connor)

5/07/24 @ 9:59 AM

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Comment From: Center for Biological Diversit... (Hannah Connor)

5/07/24 @ 9:53 AM

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Comment From: East Columbia Basin Irrigation... (Jamie Balliet)

5/07/24 @ 9:25 AM

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Comment From: Washington State Water Resourc... (John Stuhlmiller)

5/07/24 @ 9:08 AM

Please find our comments in the attached file.

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Comment From: Lake Sammamish Kokanee Work Gr... (Alison Agness)

5/07/24 @ 8:39 AM

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Comment From: Copper Development Association (William Adams)

5/07/24 @ 7:36 AM

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Comment From: Snohomish Basin Salmon Recover... (Norah Kates)

5/07/24 @ 7:18 AM

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Comment From: International Zinc Association (Adam Ryan)

5/07/24 @ 6:51 AM

Thank You Ecology,

The International Zinc Association (IZA) has uploaded a comment letter.

Thanks,
Adam Ryan

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Comment From: NiPERA Inc (Ellie Middleton)

5/07/24 @ 1:20 AM

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Comment From: Naches-Selah Irrigation Distri... (Justin Harter)

5/06/24 @ 4:02 PM

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Comment From: Association of Washington Busi... (Erin Herlihy)

5/06/24 @ 1:03 PM

Attached please find additional documents submitted in support of Association of Washington Business' comment letter.

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Comment From: Association of Washington Busi... (Erin Herlihy)

5/06/24 @ 12:59 PM

Attached please find additional documents submitted in support of Association of Washington Business' comment letter.

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Comment From: Association of Washington Busi... (Erin Herlihy)

5/06/24 @ 12:55 PM

Attached please find a comment letter plus additional supporting documents submitted on behalf of Association of Washington Business.

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

5/06/24 @ 10:10 AM

Marla Koberstein
Department of Ecology
Water Quality Program
PO Box 47696
Olympia, WA 98504-7696

RE: Proposed Aquatic Life Toxics Criteria

Dear Ms. Koberstein:

Thank you for the opportunity to comment on the Aquatic Life Toxics Criteria. The Washi...↓ngton Association of Sewer and Water Districts represents more than 180 public sewer and water districts in the state. These districts provide cost-effective sewer and water services to approximately 2o% of our state's population in urban and rural, and large and small communities. Clean water is a major concern to both our membership and the customers they serve.

We appreciate Ecology's efforts to harmonize toxics criteria required by EPA with the unique circumstances regarding endangered species that utilize Washington waters. Our focus will always be to keep contaminants out of waterbodies, as it is more difficult and expensive to remove them than to keep them out in the first place.

We have concerns with both the new inclusion of aluminum in the rules, and with the arsenic criteria.
Heather Kibbey, WASWD Regulatory Liaison, asked questions about aluminum and arsenic following the April 4 workshop and received some well thought out answers from Bryson Finch of Ecology staff. These clarifications are not included in the body of the rulemaking document, and we view it as essential to include them in the document. For aluminum, there is no mention of the form of aluminum that would be considered under the rule. Since aluminum is the most abundant metal in earth's crust, it would be reasonable to find it in every natural waterbody. Mr. Finch clarified that the rule is only geared at free aluminum, such as would be the result of mining. This should be inserted into the aluminum discussion starting on Page 45 of the document for clarification.

The arsenic criteria are problematic because Washington State is the land of volcanoes, which are enriched in arsenic. This was brought to light some years ago during Ecology's Puyallup River Mediation. Ecology found elevated amounts of arsenic in Puyallup River waters as part of the reallocation of dissolved oxygen in the system. Ecology stated that they were going to examine treatment plants and industries on the river to discover how the elevated arsenic was getting into the river. A number of scientists involved in the mediation stated that was a waste of time because the arsenic was coming from the volcano. Ecology studied this for a number of weeks and came back to the group to state that the arsenic was coming from the volcano. Mr. Finch stated in an email that a Use Attainability Analysis (UAA) would need to be done when naturally occurring pollutants prevent the attainment of the aquatic life use. Ecology needs to document this in the rulemaking, but also needs to rethink this for natural systems that we already know are enriched with arsenic. A UAA is expensive and difficult to do. It seems pointless when we know that volcanoes are a key source in this state as already shown for the Puyallup River system.

We appreciate the thought, work and research that has gone into developing these criteria.

Sincerely,

Judi Gladstone
Executive Director
WASWD

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Comment From: Roza-Sunnyside Board of Joint ...

5/06/24 @ 9:06 AM

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Comment From: Sunnyside Valley Irrigation Di...

5/06/24 @ 9:05 AM

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Comment From: Washington State Department of... (Elsa Pond)

5/06/24 @ 8:46 AM

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Comment From: CRADA Industry Partners (Ellie Middleton)

5/04/24 @ 1:18 PM

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Comment From: Quincy-Columbia Basin Irrigati... (Roger Sonnichsen)

5/03/24 @ 1:53 PM

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Comment From: WA Department of Fish and Wild... (Rae Eaton)

5/03/24 @ 12:03 PM

Please see the attached comment letter for our comments regarding revisions to the Aquatic Life Toxics Criteria, Chapter 173-201A WAC.

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Comment From: International Lead Association (Jasim Chowdhury)

5/03/24 @ 6:09 AM

Please find comments in the attached document. Thanks.

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Comment From: The U.S. Department of Energy ... (Alex Teimouri)

5/02/24 @ 1:24 PM

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