Stormwater Programs and Permit Compliance at Washington Ports

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1 Stormwater Programs and Permit Compliance at Washington Ports Matt Graves, LG Port of Vancouver Jason Jordan, Port of Tacoma Paul Fendt, PE David Evans and Associates WPPA September 26, 2013

2 NPDES Permit Requirements Port of Tacoma and Port of Seattle Marine Facilities Municipal Phase 1 Secondary Permit Stormwater Programs Port of Vancouver Marine Facilities Municipal Phase II Secondary Permit and Industrial Permit Stormwater Programs Marine Port Tenants Industrial General Permit - Monitoring and Meeting Benchmarks Other WA Ports MS4 Co-Permitee, Industrial Permits, None - Programs, Monitoring, Other? Port of Seattle Seattle-Tacoma International Airport Individual Permit Site-Specific Standards and Technology Limits

3 Port of Vancouver Adapting to Changing Permit Needs

4 Port of Vancouver Adapting to Changing Permit Needs Municipal Permit Program Stormwater Master Plan (SWMP and SWPPP) Tenant Programs Illicit Discharge Detection and Elimination (IDDE) Municipal and ISGP Permit Program Updates Gap Analysis Need 2.5 stormwater staff (formerly 1.5 staff member) Mapping Protocols Planning to Plan Need a capital program and budget Compliance approach Stormwater characterization and BMP Selection Computerized Maintenance Management Program

5 Port of Tacoma Adapting to Changing Permit Needs

6 Port of Tacoma Adapting to Changing Permit Needs Municipal Permit Program Stormwater Master Plan (SWMP and SWPPP) Tenant Programs Illicit Discharge Detection and Elimination (IDDE) Municipal Permit Program Updates Gap Analysis Need 3.5 stormwater staff (existing about 1.5) Mapping Protocols Planning to Plan Need a capital program and budget Compliance approach Stormwater characterization and BMP Selection New review manual

7 Different Standards and Consequences at West Coast Ports Benchmarks Port State Responsible Party (Industrial Permit) Zinc (ppb) Copper (ppb) Sample Frequency EPA 260 TBD Corrective Actions Seattle / Tacoma WA Tenants /Q Level 1: Operation BMPs Level 2: Structural BMPs Level 3: Treatment BMPs Oakland CA Tenants 260 (33) Annual Average Level 1: Additional BMPs Level 2: Additional BMPs (Level 3: Benchmarks become a numeric effluent limit) Long Beach CA Port 260 (33) Annual Average Level 1: Additional BMPs Level 2: Additional BMPs (Level 3: Benchmarks become a numeric effluent limit) Houston TX Tenants /6 mo TBD

8 Port of Tacoma Stormwater Characterization Compliance/treatment need comparison 92% 78% 70% 35% 20% 10%

9 Port of Tacoma Stormwater Characterization Compliance/treatment need comparison 90% 50% 53% 20% 14% 4%

10 Port of Seattle Changing Responsibilities and Tenant Coordination

11 Port of Seattle Changing Responsibilities and Tenant Coordination 670 acres under the ISGP are in Level 3 actions One 80 Acre Site - $30 million Tenant engineer evaluated over 30 approaches Preferred a single-point operated treatment system (electrocoagulation) High anticipated performance Minimal operational responsibilities for tenant Reconsidering performance assumptions and look at other options Tenants are asking Port to step in Institutional constraints (no budgets or infrastructure capital planning, can t transfer public funds) Different risk models Coordinating source controls and operations (tenant responsibility)

12 Port of Seattle Performance and BMP selection Terminal Stormwater Characterization

13 Port of Seattle Performance and BMP selection Terminal 46 Stormwater Characterization 40% 12% 14%

14 Port of Seattle Performance and BMP selection Another approach: Different risk evaluation 80% 53% 12%

15 Port of Seattle Performance and BMP selection Tenant Source Control 90% 87% 36% 12%

16 Conclusion Success Stories Biofiltration System Meeting Industrial Permit Benchmarks

17 Conclusion Success Stories Grattix Step by Step Instructions Reduce zinc in your roof runoff 90-95% reduction removal rate

18 Conclusions Challenging Work Technical Finding the right solution for the right problem Financial Political No one size fits all approach Funding sources Port and/or Tenant Public or Private dollars Lack of grant funding Leases Flexibility Re-openers Clarity around port/tenant roles and responsibilities Board/Commission buy-in Competitive disadvantage Lack of certainty

19 Conclusions Continued: Success Stories: Port/City of Tacoma Stormwater ILA Clarifies roles and responsibilities Permitting and/or courtesy reviews Opens up both port and city services Clarified storm water utility fees Treatment Technologies: West Hylebos Log Yard Treatment under construction State of the art bio-retention treatment facility Up Flow filtration systems Modular wetlands wetland in a box Jelly Fish - filtration system Roof downspout treatment systems pioneered by POV

20 Next Steps: Puget Sound Ports - AKART Study Goals Develop a playbook Work with MTO s, Ecology and Environmental Community Define best available operational, structural, and infrastructure practices BMP s Permit certainty Work with MTO s, Ecology and Environmental Community Influence the next industrial stormwater permit cycle Seek broad external support Discuss process off-ramps

21 Discussion