PORT OF SEATTLE 
MEMORANDUM 
COMMISSION AGENDA               Item No.      7a 
STAFF BRIEFING 
Date of Meeting      June 3, 2014 
DATE:    May 16, 2014 
TO:     Tay Yoshitani, Chief Executive Officer 
FROM:    Stephanie Jones Stebbins, Director Seaport Environmental & Planning 
Marilyn Guthrie, Stormwater Program Manager 
Bob Duffner, Senior Manager, Aviation Environmental Programs 
SUBJECT:  Stormwater Overview & Issues Briefing 
SYNOPSIS 
The purpose of this briefing is to summarize elements of both the Airport and Seaport
stormwater programs and to highlight critical stormwater issues currently facing the Port,
particularly issues facing Seaport tenant and Port maritime operations. 
The Port has made significant investments in stormwater control measures for Seaport,
Airport,  and Real Estate operations in recent years. In the future, major capital
investments will be needed for repair and maintenance of these stormwater systems, as
well as compliance with future water-quality permit requirements. 
BACKGROUND 
Washington State has extremely stringent stormwater regulations.
An Individual NPDES (National Pollutant Discharge Elimination System) permit
covers the Airport. 
The Port of Seattle (excluding the Airport) is covered by the Phase I General
Municipal permit (Phase I), which requires a Port-wide stormwater program. 
Program requirements include source control, operation and maintenance of
stormwater system, stormwater monitoring and reporting  requirements, and
Port/tenant education.
Seaport/Real Estate  industrial properties are also subject to the Industrial
Stormwater General Permit (ISGP). Container facilities leased to marine terminal
operators are being required to install sophisticated and expensive treatment
systems to treat turbidity (suspended sediment), zinc, and copper concentrations
to meet required benchmarks.
The Port of Seattle and our tenants will be paying close to $4 million in 2014 to
the City of Seattle to fund Seattle Public Utility's  (SPU's)  drainage and
wastewater programs. 

Template revised May 30, 2013.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 2 of 7 
Century Agenda Goals and Green Port Principles 
Stormwater is an important piece of the overall strategy to "be the greenest and most
energy-efficient port in North America." The Century Agenda includes the following
goal: 
To meet or exceed agency requirements for stormwater leaving Port-owned or
operated facilities. 
Environmental principles developed by expert panels to guide strategy development to
meet commission Century Agenda goals include the following: 
Century Agenda Green Port Principle #2 - To allocate funds to those efforts that
will yield the greatest environmental and water-quality benefits. 
o  Increase effectiveness of the fees collected to support Port-related Water
Quality goals and the Lower Duwamish Cleanup. 
Century Agenda Green Port Principle #4 - Implement stormwater-related policies
and programs that enhance the Port's economic competitiveness. 
NPDES Permits 
The National Pollutant Discharge Elimination System (NPDES) permitting program has
resulted in tremendous improvement to the quality of this country's water resources.
Under the NPDES Program, all facilities that discharge pollutants from any point source
into waters of the United States are required to obtain an NPDES permit. 
The Department of Ecology, in partnership with the EPA, uses a variety of permitting
mechanisms to regulate stormwater discharges. Permits are a license for a facility to
discharge pollutants into a receiving water under certain conditions. General Stormwater 
permits, such as the Phase I Municipal Stormwater Permit and the Industrial General
Stormwater Permit are used for categories of dischargers having common characteristics
and when generic, standardized conditions are considered sufficient to protect aquatic
resources. Individual NPDES Waste Discharge Permits are issued for more complex
industrial facilities with specifically tailored permit conditions.  The Airport holds an
individual NPDES permit. 
Airport Individual Permit 
The Airport's permit was first issued to the Port in 1988 for discharges to Puget Sound.
The early permit focused on controlling potential impacts related to aircraft fueling
operations, which are treated by the Airport's Industrial Wastewater Treatment Plant
(IWTP). The current permit, which is renewed at least every five years, continues to
regulate IWTP discharges to Puget Sound; however, it now also regulates construction
stormwater and non-IWTP stormwater.  The Airport permit covers Port and tenant
operations. 
Upgrades at the IWTP completed over the past 18 years at a cost of over $63 million
have provided expanded containment and treatment capacity, and the ability to segregate
stormwater impacted by aircraft de-icing operations for further treatment. As a result, the

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 3 of 7 
Port is reducing over 2.0 million pounds per year of biochemical oxygen demand which
would otherwise be released to Puget Sound. 
In the mid-1990s, the Airport's NPDES permit was expanded to regulate nearly all
stormwater discharges including those from roads, runways, and taxiways. The Airport
permit became much more stringent in 2003 in association with project-specific
requirements imposed on the Third Runway (16R). These new requirements included
numeric effluent limitations for zinc and copper as well as whole effluent toxicity limits.
Ecology views the Airport's permit as one of the most comprehensive and stringent
industrial stormwater permits issued in the state. In order to comply , the Port constructed
a series of detention and water-quality treatment facilities for all runoff leaving the
Airport at a cost of over $80 million. As a result of these efforts, measurable waterquality
improvements are seen in Miller, Walker, and Des Moines Creeks.
Phase 1 Municipal General Permit (Phase I)
The Port of Seattle (excluding the Airport) is covered by the Phase I Municipal General
Permit, which applies to municipalities with populations of 100,000 or more, and to any
governmental entities located within the municipality's boundaries that own and operate
stormwater discharge pipes. The City of Seattle is likewise subject to the Phase I Permit.
The Permit requires that each municipality develop and implement a stormwater program
including requirements such as source control, O&M, reporting, monitoring and education.
The Port's Phase I permit applies to "all Permittee [Port] owned lands." 
Most property managed by the Seaport and Real Estate Divisions is leased to commercial
and industrial tenants. Approximately 65% of these properties are also covered by tenantheld
Industrial Stormwater General Permits (ISGPs). The majority of acreage under ISGP
is property leased to Marine Terminal Operators (MTOs). Generally, ISGP requirements
will govern, if lands are within the boundaries of both. 
Industrial Stormwater General Permit (ISGP) 
The ISGP requires that the permittee develop a Stormwater Pollution Prevention Plan
(SWPPP) that identifies potential sources of pollution and describes the practices that will
be used at the facility to eliminate or reduce pollution in stormwater discharges (called
"best management practices" or "BMPs"). 
In addition, the ISGP requires that the permittee conduct quarterly monitoring for certain
pollutants commonly found in stormwater. The ISGP establishes certain "benchmarks"
for these pollutants. Failure to achieve these benchmarks does not mean the permittee is
in violation of the permit or water-quality standards.  Instead, failure to achieve the
benchmarks triggers the need for the permittee to perform certain types of actions (called
"Corrective Actions"). 
The benchmarks for pollutants as established by the ISGP permit are the most stringent in
the Country. Depending on the nature of operation of the facility, it can be difficult or
impossible for a permittee to meet these benchmarks.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 4 of 7 
Parameter   Units    Washington   California   Oregon (Z) 
Zinc, Total      g/L        117         260        120 
Copper, Total    g/L        14         33.2        20 
Turbidity       NTU        25         n/a        n/a 
TSS        mg/L      n/a        100       100 
Another aspect of the ISGP that makes compliance difficult is the accelerated schedule
for meeting benchmarks. The ISGP requires that if any benchmark is exceeded in any of
the quarterly sampling events, corrective action levels are triggered as follows: 
If 1 exceedance per year:  Level 1 (Operational BMPs) 
If 2 exceedances per year: Level 2 (Structural BMPs) 
If 3 exceedances per year Level 3 (Treatment BMPs) 
In comparison, other states allow ISGP permittees much more time to ramp up and
implement corrective actions as follows: 






All of the Port's MTOs have triggered Level 3 Corrective Action.  Level 3 Corrective
Action consists of the design and construction of treatment systems to treat zinc, copper, 
and turbidity. These systems are often required to be sophisticated and are expensive. In
addition to installing treatment systems, permittees must also install or enhance site-wide
operational and structural source controls to achieve benchmarks. 
The IGSP is reissued by Ecology every 5 years; this permit was re-issued on May 7, 
2014, and is currently in the public comment stage.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 5 of 7 
MTO Stormwater Treatment Installations 
The following chart identifies the stormwater treatment systems that are either planned or
installed at the Port's MTO facilities. 
Terminal            Treatment System 
TTI/Hanjin  T-46    UpFlow System 
SSA  T-18     Modular Wetlands System with roof down
spout treatment 
T-115       Chitosan treatment system 
TTI at T-46: As part of lease commitments at T-46, the Port committed to installing
stormwater treatment on three of the four outfalls at T-46. (The fourth outfall drains
the area occupied by the WSDOT, and will be addressed once their occupancy is
ended).  The Ecology order originally required TTI to complete this work by end of
September 2014; however, they subsequently issued an extension until December
2014 for two outfalls, and until June 2015 for the third outfall. This work is required
by lease requirements, Ecology order, and legal settlement between Puget Sound
Keepers and TTI. 
SSA at T-18: Tenant has developed a proposal to install the Modular Wetlands 
treatment system on target areas (generally, where maintenance or fueling activities
occur). 
Northland at T-115 is installing a Chitosan treatment system. 
AKART 
The Port joined with other Washington State ports under WPPA sponsorship, to prepare a
joint "AKART" study (All Known, Available and Reasonable methods of prevention,
control, and Treatment Study). It was this group's intention to provide a roadmap for 
permit compliance, including predictable and reasonable required stormwater treatment
actions. This group collaborated with the Department of Ecology, PMSA, and NGOs
including Puget Sound Keeper and Washington Environmental Council to prepare the
document. The AKART was published for public review and comment on May 7, 2014,
at the same time as the draft updated ISGP. 
Stormwater Fees 
Since 1989, the City has operated a Stormwater Management (SWM) Utility, funded
through annual drainage fees, to pay for its program and stormwater management
services within the City. The Port and its tenants pay drainage fees to the City. Fees are
based on intensity of use and extent of impervious surface.
In 1997, the Port signed two interlocal agreements (ILAs) with the City that dealt with
stormwater management. In summary, these agreeme nts do the following: 
1.  Requires that Port, rather than the City, conduct stormwater code construction
review on Port construction projects.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 6 of 7 
2.  Requires substantive compliance with the City's redevelopment stormwater code 
for Port construction projects. 
3.  Provides for a fixed $100,000 reimbursement of SWM fees back to the Port for
stormwater service rendered. 
By and large, the Port's stormwater infrastructure is physically independent of and
separated from City stormwater infrastructure, with stormwater from most Port properties
discharging directly from Port-owned pipes through Port-owned outfalls into adjacent
receiving waters. 
The Port is responsible for maintaining its own stormwater infrastructure on Port owned
and operated properties. The Port manages nearly every aspect of the Stormwater
Management Program with little reliance on the City for program support. 
In 2013, the Port and its tenants collectively paid the City approximately $3.4 million in
drainage fees. However, the Port received minimal services in return for the payment of
these fees. Drainage fee rates have increased significantly and thus the total fees paid to
the city have continued to increase dramatically. Meanwhile, the Port's stormwater
program costs have also increased significantly. 
Currently the cost of the Port's SW Phase I program costs (permit compliance and
O&M costs) is close to $2 million annually. 
The 1997 ILA fixed the reimbursement at $100,000, although the costs for the Port's
stormwater responsibilities have grown substantially. 
The total drainage fees paid to the City will have increased to almost to $4 million in
2014. Rates are increasing at about 10% a year.

COMMISSION AGENDA 
Tay Yoshitani, Chief Executive Officer 
May 16, 2014 
Page 7 of 7 
For several years, the Port has discussed its concerns with the City regarding the growth
of fees and lack of benefit provided to the Port's stormwater program. Other jurisdictions
have reached amenable resolution to these concerns. For example, the Port of Tacoma
has successfully negotiated an agreement with the City of Tacoma  and  reducing
stormwater fees from approximately $480,000 to $212,000 by reclassifying certain port
parcels as "direct discharging parcels" with lower associated per acre fees. 
The monies that the Port and its tenants are currently paying to the City could be more
effectively used to clean, repair, and upgrade the Port-owned stormwater facilities. This
would improve water quality entering Puget  Sound and  would facilitate tenant
compliance with ISGP permits. This work is currently unfunded. 
FUTURE STRATEGIES 
Continue  to  discuss  stormwater  fees  with  City  of  Seattle  and  return  to
Commission in late summer with options. 
Continue compliance of our Phase I municipal permit. 
Provide comment with WPPA and industrial partners to the Department of
Ecology on the new ISGP (out for public comment now) and the AKART. 
Continue to look and demonstrate innovative and cost effective solutions, like the
Splash Boxx and plan for opportunities to support Port stormwater needs. 
ATTACHMENTS TO THIS BRIEFING 
Presentation slides. 
PREVIOUS COMMISSION ACTIONS OR BRIEFINGS 
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