Draft Birch Bay Water and Sewer District NPDES permit WA0029556

The City of Tacoma Environmental Services thanks Ecology for the opportunity to comment on this draft permit. Please see the attached two documents, "Birch Bay and Big Lake NPDES Permit Review Comments on Optimization" and "City of Tacoma Birch Bay D...↓raft Permit Comments_7-14-2020".

Washington Association of Sewer & Water District Comments on draft wastewater permit for Birch Bay Water and Sewer District Wastewater Treatment Plant (Permit No. WA0029556))

Thank you for this opportunity to provide comment on the draft wastewater pe...↓rmit for (jurisdiction). The Washington Association of Sewer and Water Districts (WASWD) represents more than 180 public sewer and water districts in the state, serving nearly 20% of our state's population. These districts provide cost-effective sewer and water services�ranging from the state's largest population centers, to the smallest rural communities. Clean water is a major concern to both our membership and the clients they serve.

Our members have expressed concern regarding the issuance of wastewater permits during a time when Ecology is leading an effort to develop a general permit for nutrient discharges to Puget Sound. These reissuances of permits include caps on nutrient discharges, which Ecology personnel have stated will be subject to change once the general permit is issued. Changes to permits that have already been issued is not a fast or an easy process, necessitating additional public hearings and comment periods, followed by analysis by Ecology. This will be a large additional expense in terms of time and money in an era where state budgets will be impacted by loss of revenues due to COVID-19 shutdowns. These permits could easily be administratively extended into next year until after the general permit is issued. Extension would also allow for meaningful discussion about the appropriateness of caps with regard to the Growth Management Act (GMA), and the extensive planning and construction that has already occurred at many communities and approved by Ecology in order to meet growth requirements and adequate sewer capacity for that growth.

An additional concern in the draft permit for Birch Bay Water and Sewer District Wastewater Treatment Plant is the optimization study requirement. It is fully recognized that such studies are necessary to explore the ways different treatment facilities can alter processes to improve nutrient removal. The concern again lies with the timeline for development of the nutrient general permit. Putting these requirements in reissued permits this year short circuits the process by which the Advisory Committee is examining the type of requirements to put into the nutrient general permit. If Ecology already knows what it wants from optimization studies at individual facilities, then why is the Advisory committee meeting to discuss this at the same time it is being put into permits? As stated above, it would make more sense to extend current permits until after the general permit is issued. This would give each permit holder more certainty when contracting this work out, thus preventing expensive change orders if the requirements are altered later.

We would also like to suggest nutrient targets as an alternative to nutrient caps. These would be utilized the same way as action limits in other state regulations, such as human health related limits in the Department of Health. As soon as a jurisdiction reached the target, it would trigger an optimization study that could use parameters vetted by the Advisory Committee to look at ways to lower nutrient outputs. This would allow time for the General Permit discussions and issuance to take place, and outstanding issues to be resolved. It would save funding for Ecology by not having to immediately modify permits on issuance of the General Permit, and permittees would have certainty in knowing there was a process in place that would allow time to work toward a goal that was in sync with planning processes of many types that are already well established.

Thank you again for the opportunity to submit comments on this permit.

Sincerely,

Judi Gladstone

Executive Director

Comment on Draft NPDES Permit WA0029556_2ndDraftPermit_2020-06-10_BirchBayWWTP.pdf

Table 7: Effluent Characterization � Final Wastewater Effluent

Reference calculation "C" below the table indicates flow as "CFS" for the TIN calculation. It appears t...↓his flow unit should be in the units of "mgd" to make this formula work properly.

Comment on Fact Sheet WA0029556_2ndDraftFS_2020-06-10_BirchBayWWTP .pdf

Table 4: Wastewater Effluent Characterization

The "Ammonia" and "Nitrate/Nitrite" parameter does not specify the value as nitrogen or show the method. Could you please clarify if this value is reported as "N".

Thank you,

On page 40 of 47, Table 1 please include other methods for BOD and Soluble BOD. Include the ability to use newer technology such as optical D.O. meters. These methods would include:

In-Situ 1003-8-2009 for BOD.

ASTM D88-09C for Dissolved Oxygen.

It is o...↓nly changing a probe to a more efficient kind. It currently takes the accreditation division of Ecology way too long to approve any method changes. Please just include EPA approved alternative methods now to save time and resources moving forward with all new permits.