CITIZENS FOR A HEALTHY BAY

National Pollutant Discharge Elimination System (NPDES) Permits

The Washington State Department of Ecology (DOE) issues National Pollutant Discharge Elimination System (NPDES) permits to industries and municipalities, allowing them to release a certain amount of pollutants into Washington State’s waters. The NPDES permit system was designed to set strict limits on the mass and concentration of discharged pollutants in order to protect water quality.

CHB consistently reviews new and active permits filed in South Puget Sound and submits comment letters to the WA DOE based on the following criteria:

• Historical Compliance: If a facility is consistently discharging pollutant levels beyond its permit limitations, there is a strong possibility that water quality standards will be violated at its point of discharge.
• Changes in effluent levels: The goal of the Clean Water Act was to eliminate pollutants discharging into waters of the state, thus with each new permit cycle effluent limitations for pollutants should become more stringent.
• Best Management Practices
• Mixing zones
• Point of Discharge: The water quality at the point of discharge is also reviewed. CHB determines whether any TMDLs (Total Maximum Daily Loads) have been established and/or if the waterbody has been established as a 303 (d) listed waterbody for any of the discharged pollutants.
• Discharge Monitoring Reports (DMRs): The DMRs for the facility are reviewed for compliance and violation history. These reports are located at the Southwest Regional offices for the DOE.

The State of the Sound Report, as well as the enactment of the Puget Sound Partnership sends a strong message regarding the pollutants entering Puget Sound and the effect these pollutants are having upon the aquatic environment. While the main sources of pollutants entering the Sound are generated from non-point sources, cumulative pollutant loads from point source discharge remain an ongoing threat to water quality at their point of discharge. Unlike non-point source pollution, these facilities can be strictly monitored and enforced. As the enforcing agency, the Washington Department of Ecology is mandated to send a strong message to these facilities. Commenting upon these permits is important as it provides balance to the system. The DOE is consistently given pressure by the facilities to lesson the limits placed upon them, continued interest in these permits by CHB and other citizen groups help the DOE maintain their focus for clean waters.