Add It Up - A Review of Pollutant Loading in the North Sound and Straits

Lauren Mulroy is a graduate of Huxley College and served as a RE Sources intern. Robyn du Pré served as the North Sound Baykeeper and coordinated water programs at RE Sources for eight years. She currently teaches field-based environmental studies for the Audubon Expedition Institute.

Part Seven

Editor’s Note: This is the seventh in a multipart series on the health of northern Puget Sound and Georgia Strait. It was first published under the title, “State of the North Sound and Straits,” by RE Sources and the North Sound Baykeeper in October 2002.

At RE Sources, we are often asked questions about particular industrial facilities that discharge pollutants into area waters. A common question runs something like this: “So, how much (insert your favorite pollutant) do they release, anyway?” Usually, we can’t answer that question, even if we have the discharge permit at hand. This is because the permits do not give absolute totals. Rather, they limit pollutant concentrations—usually expressed in milligrams per liter (mg/L) or micrograms per liter (ug/L), and/or mass amounts—usually expressed in pounds per day, week or month. Sounds simple enough, one might say.

Thinking this would be a relatively simple endeavor, the North Sound Baykeeper and a volunteer set out to determine how much of a set of key pollutants is discharged into area waters each year. To keep this exercise simple, we opted to search only for toxic compounds such as heavy metals, persistent bioaccumulative chemicals, some organic compounds, and oil and grease.

It’s impossible to know who is dumping pollutants into storm sewers and ditches, and how much pollution enters area waterways in stormwater runoff from parking lots, roads and landscapes. While non-point pollution such as this is deemed by the Environmental Protection Agency to be the majority of pollution entering our water, it’s very difficult to ascertain just how much non-point pollution there really is.

We opted to focus only on permitted dischargers in Whatcom and Skagit Counties. We found 223 National Pollutant Discharge Elimination System (NPDES) or state waste discharge permits in the two counties. Of these, 84 were for sand and gravel mining operations, many of which no longer operate. Sand and gravel permits only regulate suspended solids leaving the area, so they were not included in our search for toxic compounds. There are also 17 dairies on the list. While dairies are of concern for their potential to release high amounts of fecal coliform, they do not have permit limits for toxicants. Again, we discounted them from our search.

We had reduced the list of facilities that could potentially discharge toxicants to 122. This list represents a wide variety of facilities, such as four oil refineries, an aluminum smelter, a tissue mill, wood treatment facilities, fiberglass fabricators, boatyards, food processors and sewage treatment plants.

The first step in our process was to request the discharge permits for each of these facilities. This is done by filing a public disclosure request to the state Department of Ecology. The agency usually responds within a few weeks. Sometimes, though, Ecology staff would call to say that the permit had been misplaced. Generally, the permits were found and sent along, accompanied by a hefty bill for photocopying (the state dings citizens a whopping 15 cents per page when they ask for public documents).

Then the fun began. Our dedicated volunteer Eileen began to review the permits. She quickly found that many facilities discharge a host of pollutants for which they have no limit. This is because the Department of Ecology has determined that, under normal conditions, the facility effluent will not exceed the state standard for that particular pollutant.

For example, say facility X discharges 6 mg/L of lead into a marine waterbody. The Department of Ecology may determine that this facility needs no limit for lead because they do not believe that the facility shows a “reasonable potential to exceed” the state water quality criteria for lead. This facility could discharge a small amount of a bioaccumulative neurotoxin every day for years without ever receiving a limit for this pollutant. So, pollution permits are not representative of all pollutants discharged by a facility.

As well, permit limits are often expressed in terms of maximum daily and average monthly limits. Refinery Y may be given a limit for phenolic compounds expressed as 4.94 pounds maximum per day (a mass limit), with a monthly average not to exceed 2.2 pounds per day. So, how much do they discharge?

Another challenge was uncovering how much wastewater is discharged by a given facility. This is necessary information when permit limits are expressed as concentrations, as total flow is needed to translate concentrations to mass amounts. But facilities are not given limits for flow. Some facilities are required to report their average flows, others are not, so it’s difficult to obtain consistent information.

As well, when facilities are experiencing extremely high flows, during a storm event for example, their treatment capacity may be diminished. Yet, the facilities have differing monitoring frequencies required for different pollutants. So, if a high flow event does not occur on a regularly scheduled monitoring day, the pollutant loading for that high flow day is not recorded.

Assessing the impacts of stormwater flowing from facilities is another problem. Only the very largest facilities, such as refineries, are required to measure the volume of stormwater that flows from their parking lots and process areas. Oil and grease are generally the pollutants found in the highest quantities in industrial stormwater.

Facilities tend to be limited to 10 or 15 milligrams per liter, with the facility required to test a sample monthly. But because no one knows how much storm runoff issues from most facilities, it’s impossible to figure the total amount of oil and grease leaving these facilities and entering our waters. We might know the concentration of oil and grease in a particular sample, but that’s all we know.

One might easily suppose that these amounts would be small and thereby insignificant. But 10 milligrams per liter (mg/L) in a runoff volume of 500,000 gallons per day, which could be expected for a medium-sized facility, yields nearly 42 pounds per day, or 15,330 pounds per year, of oil and grease discharged into our local waterway. Say there are five facilities each discharging a similar volume to that waterway. That’s over 76,000 pounds of oil and grease a year! Clearly, even a relatively small concentration can add up quickly.

An additional obstacle was that some facilities do not treat their waste but send it to a local sewage treatment plant for treatment and discharge as part of the larger municipal flow. For example, there are several facilities in Skagit County that discharge mercury as part of their wastewater. This wastewater is sent to a municipal treatment plant where it receives treatment as municipal sewage and is then discharged. Neither the treatment plant operators nor the industry that discharged it can say how effective the treatment plant is in removing this pollutant. It’s anyone’s guess how much of the permitted amount of a given pollutant from a given facility ends up in Puget Sound.

To be accurate, it must be noted that in most cases actual discharges are far below permitted levels, as reported by the facilities, and most facilities are very conscientious about their testing and reporting. As well, while we might like to assume that everyone is conscientious, we know that some facilities aren’t. There are bad actors that often seem to go out of their way not to comply. And, perhaps most important of all, we just don’t know what volumes of what materials are actually discharged into area waters, because no one has ever added it up.

We tried, and here present limited results with lots of caveats. The sad truth is that the Washington State Department of Ecology, whose job it is to monitor pollution and implement the Clean Water Act in our state, has never done this either. When writing discharge permits, agency staff do not consider the impacts of other similar discharges in the area, nor do they even total up the amount discharged by a given facility. Our regulators have no idea how much of these pollutants are discharged into our waterways each year. §

Next Month — Part Eight

The Policy Piece—Who Regulates What and How It Works