HomeMy WebLinkAboutord2000-028WHATCOM COUNTY COUNCIL AGENDA BILL NO. 2000 - 188 A
MEARANCES Date Date Received in Council Office Agenda Dale Assigned To
Ong. Dept.: County Council
06106t2000
I� 2 I � // I�
11
Illl IS G E V E
JUN 06 2000
WHATCOM COUNTY
COUNCIL
06/13/2000
Introduction
Division Head :
x-21
Dept. Head:
(0
Hm=eator.
Budget:
aeadive:
SUBJECT:
Ord. amending WCC Chapter 16.20, Whatcwm County Shellfish Protection Districts
ATTACHMENTS
SUMMARYSTATEMENT.
Related County Contract #: Should the Clerk schedule a hearing? (Y/N Requested Date:
Ordinance amending Whatcom County Code Chapter 16.20, Whatcom County Shellfish Protection Districts
RECOMMENDED MOTION (for f nal action):
COUNCIL ACTION TAKEN.,
2 2000 -188A 6/13/2000: Introduced
6/27/2000: Amended and adapted 7 .0, Ord. #2000 -028
'elated File Numbers: Ordinance or Resolution Number (this item only):
C) cRp # 2000 - o28
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Third Drayton Harbor Shellfish Ord.2000 SPONSORED BY: Consent
PROPOSED BY: Dan McShane
INTRODUCED: June 13. 2000
ORDINANCE NO.-20p0 -028
AMENDING WHATCOM COUNTY CODE 16.20, WHATCOM COUNTY
SHELLFISH PROTECTION DISTRICT
WHEREAS, on July 18, 1995, the Whatcom County Council adopted Ordinance
95 -036, creating the Drayton Harbor Shellfish Protection District, with a sunset date of
December 31, 1998; and
WHEREAS, on March 24, 1998, the Whatcom County Council amended Whatcom
County Code Chapter 16.20 to create the Portage Bay Shellfish Protection District; and
WHEREAS, on September 29, 1998, the Council adopted Ordinance 98 -069,
approving an updated version of the Recovery Plan and setting a revised sunset
date for the Shellfish Protection District of December 31, 2000; and
WHEREAS, on August 1, 1995, the Whatcom County Council approved by
resolution the Drayton Harbor Watershed Shellfish Protection district Water Quality
Recovery Plan; and
WHEREAS, the Drayton Harbor Shellfish Protection District Advisory Committee
has updated the Drayton Harbor Watershed Shellfish Protection District Water Quality
Recovery Plan to reflect the work that has been done in the District.
NOW, THEREFORE, BE IT ORDAINED by the Whatcom County Council that the
sunset date for the Drayton Harbor Shellfish Protection District and the Portage Bay
Shellfish Protection District shall be extended to December 31, 2002, as indicated in
Exhibit A to this ordinance.
BE IT FURTHER ORDAINED by the Whatcom County Council that the May 2000
version of the Drayton Harbor Watershed Shellfish Protection District Water Quality
Recovery Plan is hereby adopted as indicated in Exhibit B to this ordinance.
Page 1
1
2 BE IT FURTHER ORDAINED that coordination, review, and reporting of this plan
3 shall be the responsibility of the Whatcom County Health and Human Services
4 Department, with support from the Water Resources Division.
5
6 BE IT FINALLY ORDAINED that the Health and Human Services Department, in
7 coordination with the Water Resources Division, will submit a budget at the appropriate
8 time.
9
10 ADOPTED this 27 day of .tune , 2000.
11
12
13 ATTEST:
14
1A; 5
�Dana Brown-Davis, Cler f the Council
17
18
19 APPROVED AS TO FORM:
20
21
22 Dave "nt, Civil Deputy Prosecutor
WHATCOM COUNTY COUNCIL
�WHHAAJTCOM COUUNNTY, WASHINGTON
/VauJO�n/
Marlene Dawson, Council Chair
LOM
(X) Approved () Denied
Pete Kremer, County Executive
EXHIBIT A
Chapter 16.20
WHATCOM COUNTY SHELLFISH PROTECTION DISTRICTS
Sections
16.20.010
Establishment and authority of district.
16.20.015
Purpose.
16.20.016
Establishment of program.
16.20.020
District boundaries.
16.20.040
Revenue authority.
16.20.045
Collection of charges or rates and exemptions.
16.20.050
Sunset date and dissolution of district.
16.20.060
Relationship with other entities.
16.20.065
Advisory groups.
16.20.090
Severability.
16.20.010 Establishment and authority of district.
There is hereby established the Drayton Harbor and Portage Bay shellfish
protection districts under the authority of Chapter 90.72 RCW, Shellfish
Protection Districts. (Ord. 98 -019 Att. C; Ord. 95 -036).
16.20.015 Purpose.
The purpose of these districts is to provide services to citizens experiencing
nonpoint pollution of surface water drainages and coastal waters and to
implement those portions of the Drayton Harbor and Portage Bay closure
response strategies necessary to allow removal of the Drayton Harbor and
Portage Bay downgrades. (Ord. 98 -019 Att. C; Ord. 95 -036).
16.20.016 Establishment of program.
The Portage Bay Initial Closure Response Strategy dated February 10, 1998,
is hereby adopted as the Portage Bay shellfish protection program. (Ord. 98-
019 Att. Q.
16.20.020 District boundaries.
The Drayton Harbor shellfish protection district shall be the approximate
area included in the Drayton Harbor Watershed and contained within the
boundaries that are declared as follows:
Commencing on the forty -ninth parallel at the point dividing the American
and Canadian territory in the Gulf of Georgia; thence easterly along said
international boundary line to the intersection of Markworth Road; thence
southerly along the centerline of Markworth Road to the intersection of
Badger Road; thence easterly along the centerline of Badger Road to the
intersection of Glendale Road; thence southerly along the centerline of
Glendale Road to the intersection of Loomis Trail Road; thence westerly
along the centerline of Loomis Trail Road to the intersection of Bob Hall
Road; thence southerly along the centerline of Bob Hall Road to the
intersection of Birch Bay Lynden Road; thence westerly along the
centerline of Birch Bay Lynden Road to the intersection of Woodland
Road; thence southerly along the centerline of Woodland Road to the
intersection of Harksell Road; thence easterly along the centerline of
Harksell Road to the intersection of Enterprise Road; thence southerly
along the centerline of Enterprise Road to the intersection of Aldergrove
Road; thence westerly along the centerline of Aldergrove Road to the
intersection of Olson Road; thence northerly along the centerline of Olson
Road to the intersection of Grandview Road; thence westerly along the
centerline of Grandview Road to the intersection of Valley View Road;
thence northerly along the centerline of Valley View Road to the
intersection of Bay Road; thence westerly along the centerline of Bay
Road to the intersection of Kickerville Road; thence northerly along the
centerline of Kickerville Road to the intersection of Birch Bay Lynden
Road; thence westerly along the centerline of Birch Bay Lynden Road to
the intersection of Blaine Road; thence northerly along the centerline of
Blaine Road to the intersection of Lincoln Road; then westerly along the
centerline of Lincoln Road to where it becomes Semiahmoo Parkway;
thence following the centerline of Semiahmoo Parkway to the intersection
of Drayton Harbor Road; thence following a line running off -shore to the
point of origin in the Gulf of Georgia, plotted in such a manner as to follow
existing boundaries of land parcels.
The Portage Bay shellfish protection district shall be the approximate area
included in the Nooksack Watershed and contained within the boundaries
that are declared as follows:
Commencing on the forty -ninth parallel at the intersection of Markworth
Road; thence easterly along said international boundary line to the easterly
section line of Township 41 North, Range 3 East, Section 35; thence southerly
along said section line to the intersection of Halverstick
Road;thence westerly along the centerline of Halverstick Road to the
easterly section line of Township 40 North, Range 3 East, Section 3;
thence southerly along said section line to the northerly line of Township
40 North, Range 3 East, Section 11; thence easterly along said section
line to the easterly section line of Township 40 North, Range 3 East,
Section 11; thence southerly along siad section line to the intersection of
East Badger Road; thence easterly along the centerline of East Badger
Road to the intersection of Trap Line Road; thence southerly along the
centerline of Trap Line Road to the intersection with the City Limits of
Everson; thence proceeding easterly along the City Limits of Everson to
the intersection with the City Limits of Nooksack; thence proceeding along
the City Limits of Nooksack to the easterly section line of Township 40
North, Range 4 East, Section 31; thence southerly along said section line
to the northerly section line of Township 39 North, Range 4 East, Section
5; thence easterly along said section line to the intersection with
Nooksack Road; thence southerly along the centerline of Nooksack Road
to the intersection with Hopewell Road; thence easterly along the
centerline of Hopewell Road to the intersection with Lawrence Road;
thence southerly along the centerline of Lawrence Road to the northerly
section line of Township 39 North, Range 4 East, Section 21; thence
easterly along said section line to the westerly section line of Township 39
North, Range 4 East, Section 13; thence northerly along said section line
to the northerly section line of Township 39 North, Range 4 East, Section
1; thence easterly along said section line to the westerly section line of
Township 40 North, Range 5 East, Section 31; thence northerly along said
section line to the northerly section line of Township 40 North, Range 5
East, Section 31; thence easterly along said section to the westerly line of
Township 40 North, Range 5 East, Section 28; thence northerly along said
section line to the northerly line of Township 40 North, Range 5 East,
Section 4; thence easterly along said section line to the westerly section
line of Township 41 North, Range 5 East, Section 34; thence northerly
along said section to the 49th parallel; thence easterly along the 49th
parallel to the easterly section line of Township 41 North, Range 5 East,
Section 36; thence southerly along said section line to the northerly
section line of Township 40 North, Range 6 East, Section 6; thence
easterly along said section line to the easterly section line of Township 40
North, Range 6 East, Section 5; thence southerly along said section to the
northerly section line of Township 40 North, Range 6 East, Section 9;
thence easterly along said section line to the National Forest Boundary;
thence proceeding southerly along said National Forest Boundary to the
boundary between Whatcom County and Skagit County; thence westerly
along said County boundary to the westerly section line of Township 37
North, Range 5 East, Section 34; thence northerly along said section line
to the southerly section line of Township 37 North, Range 5 East, Section
21; thence westerly along said section line to the westerly section line of
Township 37 North, Range 5 East, Section 21; thence northerly along said
section line to the southerly section line of Township 37 North, Range 5
East, Section 17; thence westerly along said section line to the westerly
section line of Township 37 North, Range 4 East, Section 13; thence
northerly along said section line to the southerly section line of Township
37 North, Range 4 East, Section 11; thence westerly along said section
line to the westerly section line of Township 37 North, Range 4 East,
Section 11; thence northerly along said section line to the southerly
section line of Township 38 North, Range 4 East, Section 15; thence
westerly along said section line to the westerly section line of Township 38
North, Range 4 East, Section 17; thence northerly along said section line to the
southerly section line of Township 38 North, Range 4 East, Section 7; thence
westerly along said section line to the westerly section line of Township 38
North, Range 4 East, Section 7; thence northerly along said section line to the
intersection of East Smith Road; thence westerly along the centerline of East
Smith Road to the easterly section line of Township 39 North, Range 3 East,
Section 31; thence southerly along said section line to the intersection of Kelly
Road; thence westerly along the centerline of Kelly Road to the intersection of
Guide Meridian; thence southerly along the centerline of Guide Meridian to the
southerly section line of Township 38 North, Range 2 East, Section 1; thence
westerly along said section line to the easterly section line of Township 38
North, Range 2 East, Section 11; thence southerly along said section to the
southerly line of Township 38 North, Range 2 East, Section 11; thence westerly
along said section to the easterly sectionline of Township 38 North, Range 2
East, Section 16; thence southerly along said section line to the intersection with
Bellingham Bay; thence recommencing at the westerly section line of Township
38 North, Range 2 East, Section 20 in the Nooksack Delta; thence northerly
along said section line to the northerly section line of Township 38 North, Range
2 East, Section 17; thence easterly along said section line to the centerline of
the Nooksack River; thence following the centerline of the Nooksack River to the
intersection with the City Limits of Ferndale; thence westerly, proceeding along
the City Limits of Ferndale to the intersection with Mt. View Road; thence
westerly along the centerline of Mt. View Road to the intersection with the City
Limits of Ferndale; thence northerly, proceeding along the City Limits of
Ferndale to the intersection with Church Road; thence northerly along the
centerline of Church Road to the intersection of Aldergrove Road; thence
easterly along the centerline of Aldergrove Road to the intersection of Enterprise
Road; thence northerly along the centerline of Enterprise Road to the
intersection of Harksell Road; thence westerly along the centerline of Harksell
Road to the intersection of Woodland Road; thence northerly along the
centerline of Woodland Road to the intersection of Birch Bay - Lynden Road;
thence easterly along the centerline of Birch Bay - Lynden Road to the
intersection of Bob Hall Road; thence northerly along the centerline of Bob Hall
Road to the intersection of Loomis Trail Road; thence easterly along the
centerline of Loomis Trail Road to the Intersection of Glendale Road; thence
northerly along the centerline of Glendale Road to the intersection of West
Badger Road; thence westerly along the centerline of West Badger Road to the
intersection of Markworth Road; thence northerly along the centerline of
Markworth Road to the forty -ninth parallel, POB.
(Ord. 98 -019 Att. C; Ord. 95 -036)
16.20.040 Revenue authority.
The revenue authorities granted under Chapter 90.72 RCW shall be
exercised at the discretion of the board of supervisors, which shall be the
county council for the operation of these districts. (Ord. 98 -019 Att. C; Ord.
95 -036).
16.20.045 Collection of charges or rates and exemptions.
Property owners within these shellfish protection districts may be assessed
charges or rates as allowed by Chapter 90.72 RCW to finance the shellfish
protection programs. The owner of any property within a shellfish protection
district which is exempt from charges or rates because such property is
subject to the National Pollution Discharge Elimination System as specified in
RCW 90.72.070 shall demonstrate such exemption annually to the county
assessor. If evidence of exemption is not provided, the property will
automatically convert from exempt status and the property will be subject to
charges or rates. Land exempt from charges and rates as specified in RCW
90.72.070 because of its forest land classification will automatically convert
from exempt status if the land classification changes and will be subject to
charges or rates. (Ord. 98 -019 Att. Q.
16.20.050 Sunset date and dissolution of district.
The Drayton Harbor shellfish protection district shall be dissolved on
D^^�eF 31 2000 December 31, 2002, unless specifically extended by
ordinance of the county legislative authority, or upon the removal of the
downgrade. The Portage Bay shellfish protection district shall be dissolved
and this chapter repealed on D^, embef— 00 December 31, 2002,
unless specifically extended by ordinance of the county legislative authority,
or upon the removal of the downgrade. These districts may also be dissolved
by the county legislative authority by ordinance. The county legislative
authority shall review the continued need for these districts four months
prior to their sunset dates. (Ord. 98 -069; Ord. 98 -019 Att. C; Ord. 95 -036).
16.20.060 Relationship with other entities.
No program or activity proposed by the district shall replace or consolidate
existing activities performed by cities or other noncounty provided water -
related special purpose districts without their consent. In formulating new
programs, consultation and coordination shall occur with cities and other
water - related special districts. (Ord. 98 -019 Att. C; Ord. 95 -036).
16.20.065 Advisory groups.
The board of supervisors shall appoint advisory committees of not more than
nine members to advise on the overall operations of these districts. In
establishing district advisory committees, allmembers shall have a direct
interest in the district. (Ord. 98 -019 Att. C; Ord. 95 -036).
16.20.090 Severability.
If any provision of this chapter is found to be invalid, all remaining
provisions shall continue in effect. (Ord. 98 -019 Att. C; Ord. 95 -036).
EXHIBIT B
SHELLFISH PROTECTION
Drayton Harbor Shellfish Protection District Advisory
Committee
(DHSPDAQ
Status Report and Water Recovery Plan
An update to inform the community of water quality progress
and priority recommendations for shellfish restoration
May 2000
Table of Contents
ExecutiveSummary .................................. ...............................
2 -3
Introduct ion........................................... ...............................
4
Key Water Quality Updates ........................ ...............................
5 -6
Shellfish Resource Update ......................... ...............................
6
Pollution Sources .................................... ...............................
7
Status Accomplishments and Recommendations
Objective 1: Coordinated Water Quality Program . ...............................
8 -9
Objective 2: identify Pollution Sources and Monitor Water Quality ..........
9 -11
Objective 3: On Site Sewage Systems ............... ...............................
11 -13
Objective 4: Control Storm Water Sources ......... ...............................
13 -15
Objective 5: Blaine Municipal Sewage Sources ..... ...............................
15 -20
Objective 6: Agriculture ................................ ...............................
20 -25
Objective 7: Boats and Marinas ...................... ...............................
25 -28
Objective 8: General Recommendations ............ ...............................
29
Priority Recommendations as of May 2000 ........ ...............................
30 -35
APPENDIX SECTION
Executive Summary
Deteriorating water quality in Drayton Harbor resulted in the reclassification of portions of
commercial shellfish beds in January 1995 from Approved to Restricted and Prohibited As of the fill
of 1999, shellfish harvesting is now Prohibited throughout the entire harbor. Drayton Harbor is a
shallow estuarine harbor with fresh water contributions from California and Dakota Creeks. The
Watershed predominately supports agriculture, forestry, urban development, and commercial and
recreational shellfish harvesting.
Since the 1995 downgrade the Drayton Harbor Shellfish Protection District Advisory Committee
( DHSPDAC) has met monthly to communicate priorities to agencies for improving water quality. The
committee uses actions listed in the Initial Closure Response Strategy and the Drayton Harbor
Watershed Action Plan to pursue nonpomt pollution source identification and control. Tracking the
implementation of the Strategy and Action Plan has been difficult since the 1995 downgrade due to
the absence of a lead agency. However, with leadership from the Conservation District and the
Whatcom County Health Department, a Centennial grant awarded in early 1999 has provided at least
some of the finding necessary to reconvene the core group of agencies, facilitate shellfish committee
meetings, and track and support the implementation of the 1995 Closure Response Strategy. This
report is an informative overview outlining agency and committee accomplishments and current
recommendations needed for improving water quality to reclassify shellfish growing areas in the
harbor.
The City of Blaine bas made significant efforts to curtail pollution sources from their sewage
collection system. They have increased off -line storage to temporarily store sewage during overflow
events, detected and repaired most of the forty or more recently discovered illicit connections of
storm drains to sanitary sewer, installed a flow monitoring system to help them model their collection
system and focus on priority areas for reducing infiltration and inflow, and most recently established
a storm water utility district which will generate fiords for storm water management. Video inspection
of sewage pipelines along Marine Drive is scheduled for early May. This high priority project of
DHSPDAC with significant support from Blaine, the Puget Sound Restoration Fund, Trillium, the
Semiahmoo First Nation, and the Department of Ecology may shed some light on possible
correlations between pipe integrity and chronic pollution in nearby marine waters. This is a source
identification project. If breaks in the line are detected it is hoped that repairs will be made promptly
and correlated to water quality data in the Blaine Marina. Longer term concerns with the Blaine
sewage collection system include recently detected problems with cathodic protection of the
underwater force main, and the likelihood that the current treatment plant site will not be available
for use beyond a 10 year time period, necessitating major infrastructure changes to the collection
system and relocation of the treatment plant.
Another top priority at this time is fecal bacteria pollution from the seafood processors at the end
of Marine Drive. Volunteer monitoring by the processors shows that their waste stream regularly
contains high fecal coliform levels far in excess of shellfish standards.
Considerable effort has gone into continued water quality monitoring efforts conducted by
Washington State Dept. Health, The Port of Bellingham, Northwest Indian College, and the Blaine
Seafood Processors. A Coordinated Water Quality Monitoring Framework for the Drayton Harbor
Shellfish Protection District was completed by Hirsch Consulting Services in January 2000. This
document describes the efforts of all organizations currently collecting water quality data in and
around Drayton Harbor and submits strategies for developing a long term water quality monitoring
program for the Drayton Harbor watershed. The need for a long term monitoring program has been
identified in the 1998 DHSPDAC Status Report and Water Recovery Plan, the Whatcom County
Comprehensive Plan, the 1995 Drayton Harbor Watershed Action Plan, and the 1995 Closure
Response Strategy. This plan must focus on source identification and illustration of trends in water
quality throughout the watershed.
Over the past year and a half, the committee has focused on sources around the mouth of Drayton
Harbor, primarily the Blaine sewage collection and transport system and the fish processors. This
focus was clearly on target and in response to serious water quality violations in and around the
entrance to Drayton Harbor. With recent interest from other segments of the Whatcom community
and some entities north of the Canadian border, we feel that we are well positioned to realize success
in pollution identification and abatement, and hopefiilly we will see improvements in water quality.
However, we must not lose sight of the fact that Drayton Harbor is still influenced by non point
pollution from numerous sources, as the current data shows. Improvements have been made to curtail
pollution from on site septic systems and commercial livestock waste over the past few years. Storm
water runoff from existing and continuing urbanization in this watershed will likely consume much
of our time in the coming months. We anticipate the need to work more closely with landowners and
particularly non - commercial hobby farmers in the near future. Our goal is improvement of and
sustained water quality in Drayton Harbor in order to restore this harbor's APPROVED classification
for shellfish growing. This will require an ongoing commitment to consider all of the
recommendations as outlined in this report.
Introduction
In January, 1995 the Washington State Department of Health (DOI-) downgraded the classification
of commercial shellfish growing areas in Drayton Harbor. The reclassification was based on water
quality data and a survey of known and potential pollution sources in the watershed. In response to
the downgrade, state and local agencies joined with other affected interests to develop the Drayton
Harbor Closure Response Strategy, a targeted, short -term action plan aimed at controlling the
pollution sources and restoring the water quality of the harbor. The strategy was also designed to
complement the more comprehensive recommendations of the 1995 Drayton Harbor Watershed
Management Plan.
In July, 1995 the Whatcom County Council established a Shellfish Protection District for the Drayton
Harbor watershed and created a citizen advisory committee to help implement the recommended
actions. This committee is called the Drayton Harbor Shellfish Protection District Advisory
Committee, DHSPDAC.The district has not yet been used to generate funding for the water quality
program Instead, the various projects and activities have been carried out with state and federal
grants, general revenues from local agencies, and the voluntary efforts of area residents. A September
1998 report written by DHSPDAC titled: Drayton Harbor Shellfish Protection District Status Report
and Water Quality Recovery Plan was adopted by Ordinance No 98- 069.This report is an update of
the 1998 report and presents an overview of the accomplishments of this community-based effort
since the 1995 shellfish downgrade along with recommendations for improving the course of action
for restoring water quality in Drayton Harbor. (See Figure I for map of watershed)
In October, 1997, the Puget Sound Water Quality Action Team solicited input from the Whatcom
County Council of Governments Executive Board as well as a Whatcom County Forum on local
water quality priorities .I
Priority issues identified by the COG executive board included
➢ Protecting and restoring shellfish beds in Drayton Harbor and Portage Bay
➢ Better communication between the County Council and DHSPDAC
➢ Local priority setting
➢ Communication of successes
➢ Adequate and consistent funding for stormwater management and on -site septic systems
particularly in Lake Whatcom and Drayton Harbor
➢ Dairy waste handling on small and commercial farms
➢ Public education and involvement
Priority issues identified by the Wbatcom County Forum included:
➢ Funds for water quality monitoring and retrofitting stormwater and on -site sewage systems
➢ Education on non point pollution
➢ Stronger implementation and enforcement of the Clean Water Act
1 Local Priorities For The 1999 -2001 Puget Sound water Quality Work Plan, November 13, 1997
4
➢ Better control of municipal and industrial discharges — NPDES permits
➢ More projects and less process
➢ TMDL study for Drayton Harbor
Most of these priorities can be found within the recommendations in this report. Prompt action must
be taken to implement these locally derived recommendations in order to achieve restoration of the
shellfish resource and clean fresh and marine waters in the Drayton Harbor watershed.
Key Water Quality Updates
Department of Health Ambient Program
Washington State Department of Health, Office of Shellfish Programs (DOH) classifies shellfish
growing areas on the basis of comprehensive sanitary surveys. Each survey includes assessments of
water quality and pollution sources, and also takes into account meteorological and hydrogmphic
factors that may affect the presence and distribution of contaminants.
The presence of certain levels of fecal coliform bacteria is used as the primary indicator of water
quality. In classifying each shellfish growing area, DOH usually relies on the 30 most recent samples
taken from each sampling station located in and around the shellfish harvest area Using the Adverse
Pollution Condition Protocol (APC), the samples at each station must meet a two -part standard for
water quality. For example the geometric mean of the samples cannot exceed 14 fecal coliform
colonies per 100 milliliters of water (fc/100ml), and the 90'" percentile cannot exceed 43 fc/100m1.
(this second part of the standard is similar to the older one, not more than 10% samples greater than
43 fc/100 ml. It is just a different way of calculating and expressing it).
Under the National Shellfish Sanitation Program, DOH is required to sample Approved commercial
shellfish areas six times each year. In the mid- 1990's DOH started sampling Drayton Harbor on a
monthly basis and added several sampling stations in an effort to identify pollution sources. In
September, 1996 the department switched back to bimonthly sampling. This decision to reduce
frequency of sampling was based upon lack of evidence of improving water quality in the harbor, no
significant improvements on the ground, and limited resources within DOH to maintain this expanded
program in Drayton Harbor.
Shown in Figure 2 are the locations of seven stations which have been sampled by DOH on a
somewhat regular schedule since the 1995 downgrade. Table I shows the results of this ambient
monitoring program over the past 30 samples. As of February 2000, Stations 4 ,6, 8, and 18 all
exceed at least the second part of the shellfish standard. Two of these stations, 8 and 18 which are
both around the mouth of the harbor also exceed the more rigorous first part of the standard
(geometric mean). This is very significant and supports our more recent pollution identification focus
around the harbor entrance. Given the volume and speed of flow through this channel, it is surprising
that counts are so high, and points to the likelihood of a nearby concentrated source of fecal bacteria
effluent. The remaining stations inside of Drayton Harbor, 3, 5, and 12, meet the standard now but
have all been creeping up over the past few years. When WSDOH re- evaluated these stations in early
1999, station 3 exceeded the standard (90'h percentile was 61 fc/100nd), and stations 5 and 12 were
close to exceeding the standard for that period. The area represented by these stations is now
classified as PROHIBITED due partially to this trend.
Overall, samples collected since the downgrade in 1995 indicate that water quality in Drayton Harbor
is not improving. A Sanitary Survey conducted by WSDOH in June, 1999 resulted in a downgraded
shellfish classification for the entire harbor to Prohibited status. See Figure 3 for an illustration of the
trend in shellfish classification in Drayton Harbor since 1988.
Port of Bellingham Blaine Harbor Program
The Port of Bellingham has been sampling the Blaine Harbor since October of 1997 (Figure 2 shows
stations A -E in the commercial portion of the Blaine Harbor). Fecal coliform data from these five
stations in the commercial portion of the harbor along with observations at the time of sampling are
shown in Table 2. This sampling effort illustrates that there is chronic fecal pollution in the
commercial part of the marina. The data from each station has been formatted into bar charts which
are in the Appendix section Figures 4 -6. These charts representing stations A -E in the commercial
portion of the Blaine Harbor suggest a seasonal trend toward lower fecal contamination in the Blaine
marina during the early spring months of February and March. Based upon Port of Bellingham staff
observations during sampling, there is no clear correlation without statistical analysis between
activities which they monitored and water quality data. As Table 2 shows, the last three samples
from the marina are very low in fecal contamination compared to the historical data This may be due
to seasonal trends as discussed or possibly a more permanent fix along Marine Drive or within the
Blaine harbor itself; which have yet to be identified.
Deoartmem of Health — Special Restoration Monitoring
Begicmhtg in 1996, WSDOH expanded their sampling effort to include marine stations in both Blaine
Harbor and the Semiahmoo Marina breakwater as well as occasional sampling from the Sea K fish
processors waste stream sieve. These data are summarized in Table 3. Five of the sites within the
Blaine Harbor correspond to stations sampled by the Port of Bellingham, shown in this table as POB,
stations A -E. This data also shows chronic fecal pollution within the commercial portion ofthe Blaine
Harbor, elevated fecal contamination in the fish processor waste stream, and low levels of fecal
bacteria near the Semiahmoo Marina breakwater.
Shellfish Resource Update
From October 1996 through April 1997 the remaining commercially grown oyster shell stock was
relayed from the Restricted area to the Approved area, enabling re- harvest and sale of oysters. This
relay operation was completed and currently there is no active oyster growing operation in Drayton
Harbor due to the fecal colifonn pollution problem
The 1999 shellfish downgrade has now prohibited the commercial Nooksack and Lummi tribal
harvest of clams from the Western portion of Drayton Harbor, adjacent to Semiahmoo Spit.
Commercial harvest of all shellfish species is now Prohibited throughout the entirety of Drayton
Harbor.
Pollution Sources
Prior to and since the 1995 downgrade a number of reports have documented ongoing pollution
sources in the watershed These reports describe point and nonpoint sources impacting water quality
and subsequently the shellfish resource in Drayton Harbor.
The six pollution sources identified by State Department of Health (DOH) in the 1995 Sanitary
Survey include:
• Failing on -site septic systems on or near the harbor shoreline and creeks
• City of Blaine sewage treatment and bypasses
• Storm water runoff
• Blaine and Semiahmoo marinas
• Agricultural practices in California and Dakota Creek watersheds
• Fish processing wastewater
The 1999 downgrade identified additional sources including:
• Runoff contamination associated with storrnwater events
• Marine mammals
• Possible leaks from the forcemain of the Blaine STP collection system near the
commercial marina and harbor mouth
Each of these point and nonpoint sources is recognized as significant, or potentially significant. Due
to the complexity of the combined ongoing sources the advisory committee expresses the need to
work on all fronts to realize an upgrade of the shellfish beds in Drayton Harbor.
This report discusses in considerable detail the status, accomplishments and updated DHSPDAC
recommendations and comments for each of the identified pollution sources that impact Drayton
Harbor. It is organized under the eight objectives as identified in the May 1995 Closure Response
Strategy. Some new tasks have been added to this strategy. We have made every reasonable effort
to solicit and list the accomplishments of agencies through the spring of 2000. In most cases, these
accomplishments are shown for two time periods: January 1995 through September 1998 and from
September 1998 to May 2000. It is a daunting challenge to acquire this information and then to
understand it clearly so that updated recommendations can then be formed and prioritized. A five
page summary of the Committee's recommendations can be found at the end of the report beginning
on page 30.
Objective One
Establish Coordinated Water Quality Program for Drayton Harbor
Whatcom County Council, Department of Ecology, City of Blaine, Lummi Nation, Nooksack Indian
Tribe, Whatcom County Health and Human Services, Port of Bellingham, Whatcom Conservation
District, Puget Sound Water Quality Action Team, State Department of Health, Blaine Sewer Plant.
The Drayton Harbor Shellfish Protection District Advisory Committee (DHSPDAC) has been
meeting on a monthly schedule. Through this dedicated work group of volunteers, issues that present
themselves as threats to the water quality of Drayton Harbor have been first and foremost tasks. It
is through this group that recommendations are made to the implementing agencies holding them
accountable for thew responsibility to improving the water quality of Drayton Harbor. Activities and
key issues are then reported to the Natural Resource Committee on a quarterly basis.
Accomplishments up to May 2000
Task 1: Ongoing DHSPDAC meetings on a monthly basis. In January of 2000, a formal set of By
Laws was adopted and formalized by the DHSPDAC. A set of signed documents was sent to County
Council for formal adoption. Ten committee members are on board. In January of 2000, Geoff
Menzies was elected as chairman and Jan Hansen as vice chairman.
Task 2: A core group of agencies as identified in the Initial Closure Response Strategy was
reconvened in March, 1999. They have met on an approximate quarterly basis since then. Usually
at least one member of DHSPDAC is present at these meetings.
Task 3: Initial joint meetings with DHSPDAC and Agencies were felt to be too cumbersome and
unproductive. For this reason meetings are held separately, with the exception of the presence of
either the chairperson or vice-chairperson at agency meetings.
Task 4: A Centennial Grant was awarded to Whatcom County Health Department in early 1999 to
facilitate agency and citizen advisory group meetings and coordination with the County Council and
data management for both the Drayton Harbor and Portage Bay Shellfish Districts. Funding is
available under this grant through September 1999, and a request for additional funding to support
this effort through December 2000 was underway at the time of this writing.
A Public Involvement and Education grant (PIE) grant was prepared and submitted for the Shellfish
Districts to adopt the Pledge Program which would have targeted shellfish protection districts in
Whatcom County. This would have been the beginning of a great educational tool and raise
awareness of the shellfish issues in the community. With help from The Conservation District the
grant was written and submitted. Unfortunately, it was not accepted.
A grant from the Dept. of Ecology for $9,000.00 will be used for in -pipe camera survey of Blaine's
sewer system from approximately the eastern end of Marine Drive to the western terminus of Marine
Drive. Contracts are being finalized between the City of Blaine, the Dept. of Ecology, and Puget
Sound Restoration Fund. Puget Sound Restoration Fund will be administering monies for the project
due to Blaine's lack of staffing.
DHSPDAC Recommendations and Comments
Task 1: Update appointments, roles and responsibilities for Citizens Advisory Committee.
On schedule and ongoing
Task 2: Convene an implementation work group consisting primarily of agencies with
implementation responsibilities. Ongoing
Task 3: Convene joint meetings of Citizen Advisory Committee and Implementation work
group subcommittees to track progress and to resolve issues. Provide updates to council.
Regular joint meetings have been abandoned.
Task 4: Identify and pursue grants and loans for program implementation.
Based upon a Memorandum of Agreement between SDOH and DOE which outlines the
responsibilities of these agencies in response to shellfish growing area downgrades "Ecology shall
assist local government, tribal government, and other affected agencies in identify o potential funding
mechanisms to implement the Response Strategy." Ecology most continue to be proactive in this
regard as specified in the MOA.
Task 5: Secure dedicated funds for implementation using the Shellfish Protection District or
other means.
In 1999, the Whatcom County Flood fee was increased to 1993 level The state and government have
issued mandates that require the County to implement special water resource planning and programs.
While the County seeks other funding, state law allows flood funds to be used for special projects
that protect water quality. Under this umbrella, shellfish districts are included. Upon completion of
the DHSPDAC Plan scheduled for May. 2000 the committee representatives will schedule a meeting
with the Water Resources Division to discuss the Drayton Harbor Recovery Plan and fundingontions
under the Flood Tax.
Objective Two
Identify Pollution Sources and Monitor Water Quality
Department of Ecology, DHSPDAC, Whatcom County Staff
Until very recently, minimal effort has been expended in actual pollution source identification for
stomnwater and allocation of loading to Drayton Huber from the various sources as they were
identified in the 1995 downgrade. DHSPDAC and the Whatcom County Council have requested
from the local Ecology office that a Total Maximum Daily Loading (TMDL) study be conducted
in Drayton Harbor as is required under an MOA between Ecology and USEPA for federally
impaired 303d water bodies, such as Drayton Harbor. A W WU 1995 study titled: Fecal Coliform
Contamination Study of Drayton Harbor conducted by Cykler, Haggerty, and Matthews focused
on numerous drainages into Drayton Harbor and prioritized them for follow -up source
identification and remediatiion. A definitive and comprehensive follow -up of this study has not
been conducted. This classic watershed study provided estimates of average daily fecal coliform
loading from thirty non -point fresh water discharges into Drayton Harbor but has not been
evaluated for fitness to support a TMDL. This 1995 study has recently been submitted to Ecology
for technical review to determine whether it would be useful towards the development of a non
point TMDL for Drayton Harbor.
Known sources in and around the harbor mouth include fish processor waste discharge and
occasional overflows from the Blaine sewer collection system Efforts are underway to test the
integrity of the older main sanitary sewer line along Marine Drive and the lines, which serve the
processing plants and businesses adjacent to the Blaine Marina. Efforts continue to motivate the
Department of Ecology to assist Blaine Seafood Processors in conducting a Toxics Reduction
Engineering Exchange (TREE). We understand that since November, 1999, this project is among
the top statewide priorities for a TREE program inspection. Sources around the mouth of the
harbor are of particular concern because the flooding tide is now considered by DOH as the
adverse tide for fecal pollution within Drayton Harbor. The very recent finding that there may be
problems with the cathodic protection of the underwater sewer force main elevates this
component of Blaine's sewer collection system as a possible source of fecal pollution around the
harbor entrance.
Water quality monitoring and reporting, coordinated primarily by Julie Hirsch, has been ongoing
and conducted by several groups including the Port of Bellingham, Washington State Dept. of
Health Shellfish program, the Northwest Indian College, and Blaine Seafood Processors.
Accomplishments up to May 2000
1) Water quality data is available through numerous programs.
2) The Data Management Work Group (DMWG) was formed and has met four times.
3) Drayton Harbor Coordinated Water Quality Monitoring Framework was submitted to the
Whatcom County Health Department m January.
4) Improved coordination of water quality sampling among agencies
5) Progress on the Shellfish Protection District Database
6) Data management sections were developed for the Whatcom County Shellfish Protection
Districts website (www.whatcomshellfish wsu edu,).
DHSPDAC Recommendations and Comments
Task 1: Determine cost and evaluate benefits of conducting a TMDL study. Expedite this
process.
Prior to this year, the earliest Drayton Harbor was being considered for a TMDL study was
approximately 2004. This year, the Nooksack Indian Tribe is pursuing a job request to the
Department of Ecology's Washington State Environmental Assessment Program (EAP) which
may move the TMDL process up in priority. Explore with Ecology EAP team the usefidness of
the 1995 Cykler. Haggerty and Matthews study for establishing a TMDL for Drayton harbor.
W11
Task 2: Develop a coordinated water quality monitoring program to identify pollution
sources and to track changes in water quality.
The Northwest Indian College (NWIC) and State Department of Health (SDOH), continue to
monitor in Drayton Harbor and the Drayton Harbor watershed. SDOH has cut back on sampling
in Drayton Harbor from monthly sampling to every other month. A Coordinated Water Quality
Monitoring Plan has been developed for Drayton Harbor. Begmi nmg in July of 2000, the Port will
enter into their long tern water quality monitoring plan as required by the permitting agencies for
the Blaine Harbor expansion. This will add to the testing currently being done.
The Dept. of Ecology will continue to monitor Drayton Harbor as part of their ambient
monitoring plan for Puget Sound. Monitoring in the future must be linked closely with source
identification and abatement and funds must be secured to support a long -term water quality
monitoring plan All of the monitoring programs to date do not have any dedicated long-term
funding source. It is critical to identify a sustainable source of funding to coordinate and
implement a long term water quality monitoring gp_ro gram in the Drayton Harbor watershed
Task 3: Develop Memorandum of Agreement for sampling agencies based on Coordinated
Monitoring plan.
The Memorandum of Agreement (MOA) was developed in the Coordinated Monitoring plan
Implementation of the MOA is expected to be completed in Spring of 2000.
NEW TASKS ADDED TO CLOSURE RESPONSE STRATEGY
Task 4: Review Drayton Harbor watershed studies since 1973 and create an abstract
bibliography which will be available in hard copy and on the web site.
Task 5: Obtain a commitment for ongoing long -term water quality plan development and
funding.
Objective Three
On -Site Sewage Systems
Whatcom County Health and Human Services Department
Many of the existing on -site sewage systems (OSS) on or near the Drayton Harbor shoreline and
along California and Dakota Creeks, predate design and installation requirements. Fifty -four percent
(54 %) of the residences are more than 20 years old. Previous survey work in this area has revealed
that 38% of the systems evaluated did not meet current design standards. A 1997 -1998, intensive
survey of 252 OSS revealed 54 failures. This is a failure rate of 21 %. To date, all of these with the
exception of one site have been repaired. Additional failures have also been identified within the past
year and most have also been repaired as well.
Accomplishments up to September 1998
1) Distributed OSS Operation and Maintenance information packets to approximately 450
residences in the Drayton Harbor Watershed. These were completed with 1995 PIE grant
funds.
I
2) Revisited all suspect OSS from the 1995 DOH and made final determinations on all sites.
3) Obtained $154,000 through a Special On -site Shellfish Grant in 1997 to assist homeowners
in the repair of failing OSS. Seven of the repaired OSS were awarded SOS grant money.
The grant money will assist in the repair of an estimated additional 15 OSS.
4) Developed an OSS database in order to track the status of all OSS within the Drayton Harbor
Watershed.
5) Developed and implemented an OSS Enforcement Policy which requires prompt repair of
failing OSS.
6) Assisted both the City of Blaine and the Birch Bay Water and Sewer District to insure that
failing OSS within their service areas are connected to public sewer. Connection to public
sewer, upon the failure of an OSS, is required by WCC 24.05 and WAC 264 -272, On -Site
Sewage Systems.
7) Assisted the Port of Bellingham in conducting sewer line testing in the Blaine Harbor area.
8) Worked with the Birch Bay Water and Sewer District in exploring the feasibility of a sewer
extension along Drayton Harbor Road, as an alternative to OSS. All indications are that the
ULID formation is not moving forward at this time and is not probable in the near future. The
replacement of failing OSS with permitted, conforming OSS, appeared to be the only
alternative at this time.
9) Actively participated in activities related to the Drayton Harbor Shellfish Protection District
Advisory Committee.
Additional Accomplishments up to May 2000
➢ In 1999, 12 repair permits were issued for failing OSS in the Drayton Harbor Watershed.
These failures have been repaired. These were based on routine complaint investigations.
There is still one failure identified in the 1997 survey that is pending eviction/court action.
➢ Whatcom County Health Department summarizer) their on -site sewage system survey and
repair efforts in an April 2000 report titled: Drayton Harbor Watershed On -Site Sewaee
System Survey. This report is the final report on the work funded by the Special On -Site
Shellfish Grant they received in 1997. 43 of the 54 sites identified as failing (79 %) were
surface discharges, ie sewage on the ground or discharging to surface water bodies. As of
March 9, 1999 a total of $141,450 was provided by this grant to help homeowners repay
twenty one of the total fifty four failing sites that were identified. This survey also showed that
61% of the systems surveyed are more than twenty years old, which supports the need for an
ongoing operations and maintenance program.
➢ An alternative system survey was a part of an Interlocal Agreement between Whatcom
County and the City of Bellingham Six alternative OSS were surveyed in the Drayton Harbor
Watershed in 1999. All 6 systems were functioning adequately.
Regulatory changes necessary to implement OSS O &M Program approved by County Council
in November 1999.
➢ Work plan developed to pursue low interest loan program for repairing failing OSS.
Agreements with implementing agencies in process. Program implementation by end of 2v°
quarter 2000.
DHSPDAC Recommendations and Comments
Task 1: Enforce existing OSS
regulations.
The Health Department
should utilize the recently
12
adopted enforcement policy to ensure timely, permanent repair of all failures identified. As of this
date, identification of failing systems is still based upon a complaint- driven system.
Task 2: Establish a countywide Operation and Maintenance Program for all OSS by the year
2000. Sensitive areas, such as the Drayton Harbor Watershed, will be the primary focus of the
initial phase of program implementation. With regulatory changes, enabling implementation of
OSS Operation and Maintenance in place since November, 1999 this program should be
implemented in the Drayton Harbor Watershed immediately.
Task 3: Establish a permanent program for financial assistance for OSS repairs. State
Revolving Fund monies for a low interest loan program were applied for in February 1998 and a
work plan has been developed. Secure agreements with implementing_ agencies and implement by
end of June. 2000.
Task 4: Place a high priority on complaints to Whatcom County Health Department Sled in the
Drayton Harbor Watershed (OS -23 from 1995 Watershed Plan) and report to DHSPDAC annually
on complaints filed and actions taken in the watershed.
Task 5: Designate Drayton Harbor as an Area of Special Concern through the public process.
Additional requirements to reduce failure rates or minimize impacts of OSS on shellfish resources
are detailed in WCC 24.05.23, Areas of Special Concern This recommendation was identified as
high priority in the 1995 Closure Response Strategy but has not yet been initiated by the Public
Health Officer
Task 6: Require proof that a residence, served by an OSS, has a functioning OSS prior to
all real estate transactions. (based upon On Site Recommendation 29 from 1995 Watershed Plan)
Objective Four
Control Stormwater Sources
City of Blaine, Dept.of Ecology, Whatcom County Health Dept.
Stormwater runoff is a source of fecal coliform pollution. In urban areas, pet waste and other non-
agricultural sources are the primary sources. In Waal areas, stormwater can carry bacteria from
agricultural operations, non - commercial farms or on -site septic systems.
Accomplishments up to May 2000
1. In June of 1998, the City of Blaine completed a DNA storm water study to help trace the
specific contributors of fecal bacteria discharged from various storm drains, but the study was
inconclusive and a report has not been made available.
2. A July 1997 study conducted by Tom Sipsey and Beth Marcy and funded by the Coastal Zone
Management Act, attempted to identify sources of fecal bacteria in high priority drainages
around Drayton Harbor as identified by Cykler, Haggerty, and Matthews in 1995. Potential
sources in these drainages in the 1997 study included failing septics, possible
13
sewer / stormwater cross connections, agricultural practices, wild and domestic animals, urban
runoff and recent land development. In most cases, at least two sources were identified as
potential problems in each drainage and further physical surveys were often recommended.
3. Three priority storm water outfalls from East Blaine have been monitored on a somewhat
regular basis by NWIC as a component of the Coordinated monitoring program Sampling in
the past from these outfalls has shown chronic pollution coming from these storm water
sources, and they have been considered important sources of fecal pollution for Drayton
Harbor. At this tune, Blaine is not financing any of these monitoring efforts, although that was
recommended in the September 1998 report.
In 1995 the City of Blaine completed and adopted a citywide Storm Water Management Plan. The
City of Blaine is currently implementing this plan. One of the objectives of the plan is to" engage
other agencies in region -wide implementation of activities to improve water quality in Drayton
Harbor and its tributary drainages." This coordination can enhance the effort to achieve regulatory
compliance with state and federal storm water control requirements.
Stormwater Utility Start Up
Blaine adopted a series of enabling ordinances in the fall of 1999, and will send the first bills for
storm-water utility service in March 2000. The monthly residential fee of $4.00 will provide capital
reserve funding for construction of system improvements and operating funds to cover a greatly
enhanced level of maintenance including catch basin cleaning, more frequent street sweeping, ditch
cleaning, and detention pond /bio -swale inspection. The highest ranked capital project planned
includes installation of storm drainage in areas of older Blaine that presently have an underdeveloped
stormwater collection system and illicit sanitary sewer connections.
DHSPDAC Recommendations and Comments
Task 1: Investigate potential sources impacting priority storm water drainage around the
entire shoreline of Drayton Harbor. Report findings to DHSPDAC and take prompt action
to abate pollution sources when found.
This task is based upon priority/problem drainage's as identified in the W WU 1995 Fecal Coliform
Contamination Study of Drayton Harbor., by Cykler, Haggerty, and Matthews.
A comprehensive physically survey of these areas is needed to identify pollution sources and
control them when found A repeat study may be required to again prioritize current problem
drainages.
Task 2: DNA testing to evaluate fecal coliform in Drayton Harbor,
Testing in Blaine is complete but fairly inconclusive. No final report has ever been received,
although it was reported that 70% of samples could not be matched to specific sources be they
domestic animal, wild animal, livestock or human in origin. This task has been completed.
Task 3: Control pet waste within Blaine City limits with the installation of stations supplied
with plastic bags(Mutt Mitts) and garbage cans for pet waste disposal.
14
Task 4: A member of DHSPDAC should be appointed to the storm water committee to
represent shellfish issues in and around Drayton Harbor as they relate to Blaine storm
water runoff and monitoring efforts.
Objective Five
Blaine Municipal Sewage Sources
City of Blaine, Department of Ecology (DOE)
Since the 1995 shellfish downgrade Blaine has experienced thirteen combined stormwater/ sewer
overflows along Marine Drive. There were four overflow events during 1999. Storm water entering
the sewer system overloads the Blaine Sewage Treatment Plant (STP), resulting in design capacity
being exceeded as well. Unfortunately, in spite of numerous improvements to the system as outlined
below, these overflow problems have persisted. The City of Blaine and the Department of Ecology
are currently negotiating a Consent Order which will establish a schedule of improvements to the
system. This order is expected to be finalized in the late summer, 2000.
Due to the removal of ancestral remains at the existing sewer treatment plant, which occurred during
excavation to expand the treatment plant, the existing site may not be available for the long term This
renders the 1994 Blaine Sewer Plan virtually obsolete and efforts are now underway to develop 10-
year interim improvements to the collection system and the plant itself. There is also a need to
consider the longer term issue of treatment plant relocation and possible redesign of much of the
system
Commercial shellfish harvesting north of Semiahmoo Spit in Semiahmoo Bay is prohibited due to the
current location of the sewer treatment plant outfall pipe. Along with the closure of the commercial
shellfish beds within Drayton Harbor, the Department of Health has recommended to the Whatcom
County Parks Department closure of recreational shellfish harvesting in this recreational area.
Circulation studies conducted by Schwartz (1976) and recently by Menzies and Marcy (1998) show
that under certain flood tide conditions, effluent from this sewer outfall pipe is capable of reaching
the mouth of Drayton Harbor within five hours of discharge.
Effluent from the Blaine STP is chlorinated after treatment to disinfect the discharge. There have
been events when the chlorination has not proved effective, and high fecal coliform counts have been
found in the effluent. Under these conditions, the effluent carrying fecal coliform pollutants may be
contributing to the degraded water quality in the vicinity of the mouth of Drayton Harbor.
There are currently no efforts underway to redesign or relocate this outfill in spite of the possibility
that improvements might lead to at least partial reclassification of recreational shellfish harvest along
portions of the north side of Semiahmoo Spit.
DHSPDAC with financial and administrative support from the Puget Sound Restoration Fund (PSRF)
and other local entities is leading the charge in cooperation with Blaine to examine, in a phased
approach, the integrity of components of the sewer collection and conveyance system from the
15
railroad tracks along Marine Drive to the treatment plant outfall. This effort has been driven largely
by poor marine water quality (high fecal pollution) m and around the commercial portion of the Blaine
Marina.
Accomplishments up to September 1998 -City of Blaine
1) Replaced the previous 10" diameter fiberglass pipe sewer force main that crosses the mouth of
the harbor with a 14" diameter ductile iron pipe. Replacement was necessary due to pipe failure
and leakage. Project cost: ($573,550). Project completed fall of 1996
2) Improved the North Blaine sewer collection system Sewer main was replaced and new sewer
services were installed to all homes with poor service connections. These improvements will
decrease Storm water inflow into the collection system Project cost: ($668,384). Project
completed August 1997
3) Replaced main sewer line along Marine Drive with larger diameter pipe to reduce the
possibility of overflows. Project cost: ($538,000). Project completed January 1998.
4) Construction began in April, 1998 for the Peace Portal Collection System Improvements. As
with the North Blaine system, this sewer train is approximately 70 years old, failing and a
source of significant I &I into the collection system Project cost: ($835,000)
5) New sewer service was extended to Northeast Blaine where no public sewer service existed.
Project cost: ($335,000)
6) The Wastewater Treatment Plant Upgrade was in the final design phase.
7) The 1998 City of Blaine budget included a standby pump for the Marine Drive Pump Station
Accomplishments up to May 2000
The City of Blaine bas made progress toward the reduction of point and non - point -source fecal
colifarm contamination entering Drayton Harbor. Progress includes start up of the stonn -water
utility, the stepwise addition of offline storage resources, Lift Station No. 1 improvements,
collection system inflow & infiltration reduction activities, flow monitoring, collection system
modeling, and cathodic protection system evaluation for the Drayton Harbor force main crossing.
These improvements are addressed in detail below:
Offline Storage
In late January 1999, the City made piping modifications that enable the use of the adjacent
60,000 -gallon clarifier /tank. On December 15, 1999 an additional 20,000 - gallon portable storage
tank was placed at Lift Station No. 1.
A purchase order was issued March 16, 2000 for four 50,000 -gallon bladder tank storage units. The
16
City will install and test these storage units and develop an operating procedure for their use in early
May when they are installed.
Lift Station No. I improvements made in 1999 and early 2000
1) Programmable Logic Controller (PLC) improvements included:
a) Changed controller call for 100 ° /a pump power earlier during high flows. Previously, lines
would surcharge before both pumps would operate at full power.
b) Installed delay timer for power failure pump call. Prior to this installation, the controller
would call for both pumps at 100% during power failure, resulting in extreme fluctuation
of wet well level. This change also allows generator startup of pumps individually.
2) Installed pump seal Failure relays and alarm lights, providing warning of impending motor
failure.
3) Reset of warning fights and installation of transducer beam protector, enabling improved
communication and facilitating staff investigation of high level alamts and drive failures.
4) Repaired flow meter, enabling instantaneous flow monitoring and continuous data recording.
5) Installed pressure indicator on pump discharge.
Additional repairs are planned for Lift Station No. 1 later this spring including replacement of
guide rails broken at the bottom of the wet well, inspection and possible replacement of discharge
piping, and a general inspection of wet well integrity. Additional repairs may be deemed
necessary after this inspection and consultation with C112M HILL and DOE staff
In order to accomplish repairs and inspection, the lift station must be taken off -line and
wastewater must be pumped around the existing fill station to the treatment plant. In preparation
for this pump around, staff has installed piping to enable a pump around, purchased inflatable
plugs, and identified the source of a large rental pump. These preparations allow staff to pump
around if both of our existing pumps fail at once.
The City will proceed with bidding and selection of a contractor to complete this work upon
incorporation of DOE staff comments.
Continue to reduce inflow & infiltration in the Blaine Sanitary sewer system.
This spring, summer and fall, staff conducted smoke and dye testing of the older portions of the City's
wastewater collection system Based on these results, 49 letters were sent illicitly connected
addressees including homes, businesses, and schools. With staff assistance and occupant cooperation,
40 illicit connections were repaired, and three others are in progress. This program has educated
residents about preventable causes of wastewater collection system overflows.
One highlight of smoke testing was the identification and disconnection of one source contributing
almost an acre of impervious roof and parking lot runoff. This included 25,000 square feet of the
Blaine Elementary School building, 7,500 s.f of the Middle School budding, and 3,750 s.f of parking
lot.
Staff recently discovered and plugged an improperly abandoned section of sewer piping on the
17
north end of 8' Street that had been damaged during construction and was a major source of
groundwater infiltration Staff also recently replaced a defective flap valve upstream of Lift
Station No. 1. In the Dec. 15, 1999 overflow event, this then- defective flap valve allowed up to
300 gpm of reverse flow to spill into Blaine Marina
Flow Monitoring
The engineering firm CH2M Hill is assisting in the implementation of Blaine's Wastewater Overflow
Mitigation Program. The first task, wastewater collection system flow monitoring, began November
18, with 12 flowmeters and two rain gauges in place by November 25, 1999. Our first access to data
was on December 28, 1999. This data allowed staff to quantify the December 15 wastewater
overflow, and to identify the collection system reaches with the highest flow contribution during
storms and during the recovery period between storms.
We have a significant quantity of rainfall data available after some early equipment problems. For the
City Hall gauge, data is available since December 30. Rainfall data will help staff better understand
the lag between heavy rain and heavy flow and the system flow response to storms of a known
magnitude.
Public Works staff returned six of the meters March 7, 2000 per the contract agreement. To better
understand the collection system trouble areas with high flow peaks during storms, staff will move
the remaining six meters to isolate individual neighborhood drainage basins.
Collection System Modeling
On January 25, 2000, our consultant C112M HILL installed the MIKES WMM collection system
modeling software. This enabled staff to begin model creation. Model development is expected
to require two months or more for completion of wet weather calibration and until late October
for calibration to dry weather flow.
Force Main Cathodic Protection System
The December 21, 1999 Cathodic Protection System inspection report by Corrosion Control
Specialists (CCS) of Kent, Washington on the Drayton Harbor submarine crossing of the Lift Station
No. 1 force main indicates that we have a weakness in the pipe -to -soil potential. CCS recommends
that we install an additional deep anode well on the Semiahmoo side of the crossing.
In a subsequent evaluation of the CCS report on January 31, 2000, C112M HILL concludes:
1. From the data provided, we cannot determine if the lower levels of corrosion protection result
from insufficient cathodic protection current provided from the existing cathodic protection
station or from damaged joint bond wire(s).
2. The testing performed by CCS does not conclusively show that the pipelines are
electrically continuous. However, we are not aware of other practical methods to perform
this test without stringing wires across the mouth of Drayton Harbor.
Electrical continuity of the pipeline is important for a couple of reasons. The fast is that
1E
an electrically continuous pipeline is required for effective cathodic protection. Broken
bond wires will electrically `isolate" some portions of the buried pipelines from the
cathodic protection current provided by the existing station on the Blaine side of the
crossing. If more than one joint bond is damaged, it is possible that a section of the
pipeline between Semiahmoo and Blaine could be isolated from cathodic protection
current, even if an additional system is installed on the Semiatmtoo side.
3. The information provided indicates that improvements to the cathodic protection system will
be required to provide sufficient protection to the Sentiah moo side of the Drayton Harbor
crossing. However, the information provided is not sufficient to enable us to comment on the
arrangement and capacity of the proposed improvements.
The City will work with our consultants to prepare an inspection plan to complete our diagnosis of
the corrosion protection system and to develop a repair plan when we have a firm grasp on how to
proceed.
DHSPDAC Recommendations and Comments
Task 1: Complete sewage treatment improvements.
Plans for treatment plant redesign and expansion as outlined in the 1994 Sewer Plan have been
undermined due to probable loss of use of the existing treatment plant site on Semialmioo Spit.
Further planninjZ should give serious consideration to the long term restoration and viability of
commercial shellfish classification in Drayton Harbor and should consider more regional versus
merely parochial long term options.
Task 2: Investigate sewage treatment plant outfall location.
Following the Menzies circulation study, the STP outfall was discounted by DOH Shellfish Division
as as 'cant source of fecal pollution to Drayton Harbor. "Discharge from the Blaine sewage
treatment plant" is listed in the 1999 Downgrade as a otn ential pollution source to Drayton Harbor.
In a March 1998 letter from Frank Meriwether responding to Menzies' Semiahmoo Circulation
study, Meriwether states "depending upon future design flows,the existing outfall may not be able
to handle peak discharges from the upgraded STP" He goes on to state that "improvements in either
or both of these structures(STP or the outfall) could result in a reclassification of these
beaches(Semiahmoo Spit), which may benefit recreational shellfish harvesters ". Possible
improvements he suggested might include "reliability of treatment and disinfection components,
relocation or extension of the outf A or an expanded diffuser configuration."
Norm Glenn, DOE EILS Program Nov 98 (11/2/98 memo to Fricke, Abassi) subsequently suggested
that extension of outfall and addition of diffuser to redirect effluent from shoreline might result in
partial re- classification of portions of the Semiahmoo Bay shoreline.
Given this information. DHSPDAC recommends that DOE and the City of Blaine. with assistance
from DOH if needed, discuss these issues as a component of the Consent Order underway with
19
Ecoloav and provide some summary and rationale for their findings
Task 3: Video project of Marine drive old sewer line and laterals to waterfront area. This initial
phase of the Sewer Collection System Integrity study being administered by PSRF is scheduled for
early May, 2000.
Task 4: Reduce Inflow and Infiltration (I &I) from the sanitary sewer collection system. This
effort is ongoing by the city of Blaine and should be continued as is planned. Specific activities will
be identified through Consent Order between Ecology and Blaine. which is now underway.
Task 5: Enforcement by Ecology when Blaine is out of compliance with NPDES permit and
when Marine Drive overflows occur( Initial CRS) . Report violations, overflow events,
enforcement actions to DHSPDAC as they occur.
In Dec. 1998 Blaine bad a sewer overflow event along Marine Drive. Part of the enforcement
order given to Blaine following this overflow specified that more off -line storage was required.
It was agreed by both Ecology and the City of Blaine that the 60,000 gallon above ground tank
located at pump station#] should be sufficient since new telemetry for overflow notification was
also part of the enforcement. Subsequent overflows during 1999 have resulted in a monetary fine
from Ecology and the development of a Consent Order which will address I & I problems as well
as temporary treatment plant upgrades.
Task 6: Replacement of the underwater force main sewer crossing. The force main was
replaced with a new ductile iron segmented line in 1996. There is some recent problem with the
cathodic protection of this new line which elevates it as a potential source of fecal pollution. This
must be investigated and corrected ASAP. which we understand is Blaine's intent at this time. A
testing schedule should be negotiated between Blaine and Ecology as a comnonent of the Consent
Agreement which is currently underway.
Objective Six
Agriculture
Whatcom Conservation District, Whatcom County Planning Department,
EPA, DOE, NSEA
The Drayton Harbor Watershed Report (1991) by the Puget Sound Cooperative River Basin Team,
cited poor agricultural practices as a source of bacterial contamination of water resources. Some of
their conclusions are listed below:
Most commercial dairies have conservation plans, however most plans need to be updated and fully
implemented. See Figure 8 in the Appendix section for the curent status of commercial plans and
20
distribution of farms throughout the watershed. Pasture management, on many smaller farms with
cattle or horses, is inadequate to control runoff and filter contaminants. Many dairies and other
livestock farms have animals in proximity to unfenced streams or drainage ditches. Non -dairy
livestock operations often have animal densities or stocking rates that exceed the vegetation's
capacity to utilize the nutrients in animal waste.
In addition to this 1991 report, the Drayton Harbor Watershed Monitoring Project which was
completed in March 1998, had similar findings in the agricultural areas of California. and Dakota
Creeks. The March 1998 project used previous water quality studies by Dickes (1992) and Saban
and Matthews (1991). Sampling sites and parameters of the 1998 Monitoring Project coincide with
the sites tested in '91 and '92.
As of September, 1998, seven of the eighteen commercial dairies in Drayton Harbor had been sent
warning letters from the Environmental Protection Agency (EPA) siting water quality violations,
specifically fecal coliform pollution. One of these dairies had five repotted complaints between March
'95 and February '96. Two dairies were cited with applying manure to snow covered fields and one
was fined for illegal discharge into Dakota Creek. EPA inspections have documented fecal coliform
pollution to Dakota Creek from the dairy operation that received the fine.
Since September 1998, Ecology has conducted initial inspections on all 18 commercial dairies in the
watershed and follow -up inspections on 16. These inspections resulted in 4 Notices of Correction,
1 Notice of Violation (NOV), 2 NOVs pending, 2 dairies placed under NPDES permit, 2 dairy
permits pending, 1 Notice of Penalty (NOP), and finally 2 NOPs possible, pending completion of
investigations.
Significant efforts have been underway over the past two years to address potential livestock
contamination issues. The focus has been on the update of commercial and hobby firm plans by the
Whatoom Conservation District, increased enforcement actions against commercial dairies from
Ecology when violations occur, and implementation of the Whatcom County Critical Areas
Ordinance which forbids unrestricted access of hobby and commercial livestock to streams.
DHSPDAC has not focused on agricultural waste issues over the past year or so due to higher
priority marine water quality violations around the mouth of Drayton Harbor. We recognize the need
to continue to support particularly those efforts that reduce livestock waste from the numerous non-
commercial farms throughout the watershed.
Accomplishments up to September 1998 Whatcom Conservation District
1. Best Management Practices (BMPs), have been implemented on farms both large and small and
reduce the risk of water quality degradation resulting from farming activities. BMP' are based
on Natural Resources Conservation Service specifications, which are proven, through research,
to protect water quality. Farm Resource Management Plans incorporate BMPs.
2. Updated the Farm Resource Management Plans for six of the eighteen commercial dairies on the
watershed.
3. Developed Farm Resource Management Plans for fifteen noncommercial small farms.
21
4. The WCD has provided technical assistance along with informational materials on BMPs to over
100 small farms within the watershed.
5. The WCD provides information and education on environmentally friendly farming including
BMPs that protect water quality through fair booths, workshops, fine tours, newsletters, articles
and other printed materials.
6. WCD contracted with W WU Institute for Watershed Studies to perform a yearlong water quality
study at eight sites within the Dakota and California Creek drainage basins. The study provides
baseline data useful in identifying trends in water quality over time.
Project Funding:
Centennial Clean Water Fund Grant. A two -year grant which ended March 1998 provided small farms
technical assistance, small farm resource planning and water quality information and education within
the Drayton harbor Watershed. $160,000 spent.
Washington State Conservation Commission Dairy Waste Program funding. Covers farm resource
planning for Whatcom County dairies enrolled in State and Federal cost share programs. $20,000
spent.
State and Federal cost share spent on improvements to dairies to protect water quality in the Drayton
Harbor Watershed. $125,000 spent.
Accomplishments up to May 2000 - Whatcom Conservation District
(These accomplishments are organized based upon tasks as identified in the Closure Response Strategy,
CRS)
1. CRS Taskl:The Environmental Quality Incentive Program (EQIP) program funded $24,765 to
one dairy in the watershed, and the producer partially matched that with $13,208. This year,
there are approximately 4 signups for EQIP funding for farm improvements.
2. CRS Task 2:Two dairies have been certified as implemented to be compliant with standards
in Substitute Senate Bill 6161. To date there are 9 dairies with plans compliant with SSB
6161. One of these has a plan completed since September 1999. Four dairies have requested
to develop plans compliant with SSB 6161, and five dairies have plans four to five years old.
This describes all the dairies in the Drayton Harbor watershed.(See Figure 8, Appendix
section for farm location and plan status)
3. CRS Tasks 3 -5:
The WCD small farts planner has provided technical assistance to two small farm owners
in the Dakota Creek watershed, and one on an independent tributary to Drayton Harbor.
Technical assistance has consisted of advising farmers on measures to make them
compliant with Clean Water Act and the County Critical Areas Ordinance provisions, such
as prohibiting animal access to streams, manure management, stream buffers, composting,
and mud management. These farmers are raising horses and beef cattle. They have been
advised about applying for federal Environmental Quality Incentive (EQIP) money to
22
make improvements on their farm The cattle farmer has signed up for EQIP for a fence
and cattle lane improvement, and one of the farmers with horses has signed up to get
funding for improvements such as grass seed, tree seedlings, barn roof gutters and
downspouts, manure storage, and fencing. The farmer with horses is working currently
with WCD on a conservation plan, and will be planting a riparian forest buffer averaging
30 feet width along approximately 200 feet of a South Fork Dakota Creek tributary this
spring. She will also be leasing another acre to increase her land base in order to better
sustain her pastures, while maintaining the some number of horses. The other horse
farmer has an approved farm plan, but got some technical assistance on composting. The
cattle farmer will be getting an update on a previously completed plan, which will
encompass cattle exclusion from a stream, cattle lane improvement, composting, and barn
roof gutters and downspouts.
➢ A small farm planning guide is in the process of being developed. This will assist small
farm owners in working on their own plan, and help them be more involved in the process.
It is projected that this guide will speed up the time frame in which plans get completed
and implemented. A draft has been reviewed by NRCS, NSEA, DOE, WDFW, and
Whammn County.
➢ Conservation Reserve Enhancement Program (CREP) : CREP is a U.S. Department
of Agriculture program that pays landowners cost sharing and annual payments for land
which is converted to riparian habitat, through planting trees. Depending on soil type and
site potential tree height, the width of the riparian habitat will be 50 - 150 feet. Among
other benefits, this would create effective filtering for fecal coliforn bacteria, contributing
to decreases in fecal coliforn. Currently, there are two CREP projects that WCD is
working on, in the development stages in the Drayton Harbor Watershed. One project, at
a cattle farm on the North Fork of Dakota Creek, will generate 3,330 lineal feet and 21.34
acres of riparian buffer. Another project, at a hayfield on California Creek, would develop
979 lineal feet, and 2.33 acres of riparian buffer.
The WCD education coordinator worked with Alayne Blickle of Horses for Clean Water
to get a PIE grant funded. The Whatcom and Skagit CD's are partnering with her to
conduct her program in Whatcom and Skagit County. She has an excellent program
which addresses many aspects of environmentally sound horsekeeping; this will be offered
free of charge to horse owners in the two counties beginning Fall 2000. In August 1999
she gave a Manure Management for Horse Owners workshop, which WCD sponsored. A
lot of the focus was on composting, and the importance of returning nutrients to the earth,
instead of everything being a one way trip out. She made the connection between the
potential for horses to pollute water quality, and the importance of water quality to
shellfish and salmon. Twelve people attended the workshop.
A Small Farm Compost Workshop was held also in August 1999. A grant was applied for
and awarded, which funded transportation and compost guides for the attendees. Two
farms in Blaine and Custer were toured that are currently composting, a cattle farm and
horse fare. Speakers were from NRCS, WCD, and WSU Cooperative Extension, as well
as the farm owners. The farmer in Blaine became an avid composter in the course of
23
preparing for this tour. Twenty -five landowners attended.
➢ The WCD small farm technician assisted Washington Department of Health in
water quality sampling of Drayton Harbor several times.
4. CRS Task 6: An agreement was reached this past summer between all parties
regarding their respective enforcement activities. No formal, written agreement has
been reached. The agreement is verbal between Ecology and Whatcom County that
they will refer things between each other.
DHSPDAC Recommendations and Comments
Task 1: Provide financial assistance to 18 dairies to implement manure management plans.
Continue to support financial assistance for farm plan implementation using EQUIP and possibly
other funding sources.
Task 2: Provide technical assistance to 18 dairies to develop manure management plans.
Four dairies have not updated their farm plans over the past 8 to 10 years. Fami plan updates are
initiated and completed on a fast- come, first —served basis based largely upon either violations that
have been cited or requests from the farmer to update. We encourage the Conservation District to
explore options which will allow them to focus on improvements at the several dairies with the most
outdated farm plans. This may require additional staff and funding
Task 3: Provide technical assistance to small/non- commercial farmers and landowners to
develop manure management plans. It is obvious that several efforts are underway to assist
hobby farmers including workshops, individual farm visits and suggested improvements, creation
of a small farm planning guide, and increasing awareness about and implemention of CREP
projects. The recent efforts by the Conservation District small farm planner have been funded by a
Centennial Grant which will be completed in October 2000. Only 10% of this technician's time
has been dedicated to the Drayton Harbor watershed. There are still very few completed small
farm plans in the watershed and it will be difficult with the current funding and staffing to meet
even the needs of the few landowners who have requested updates to their plans. In the 1991
Puget Sound Cooperative River Basin Team (PSCRBT) land use survey of the Drayton Harbor
watershed, which is the most exhaustive survey to date, non - commercial farms were identified as
a Si 'cant source of nonpohtt pollution (Drayton Harbor Watershed Action Plan, 1995).
Funding is needed to support this task in a pro- active, focused minimum 3 -yes program to better
serve the landowners in the Drayton Harbor Watershed by improved characterization of this issue
and control of livestock waste as needed.
Task 4: Conduct farm inspection program. Refer farms to Conservation District to develop
conservation plans when required by the Critical Areas Ordinance (CAO). Refer BMP and
farm plan violations to County enforcement officer when necessary. Enforce compliance
with approved conservation plans. Enforce compliance with BMP's for small farms. One
hobby farmer is being assisted and enforced upon (Notice of Correction) by Mak- Kaufinan DOE.
According to Jam Thompson, Whatcom County CAO, there have been only two complaints of
unlimited animal access to streams in the Drayton Harbor watershed under the recent CAO
24
requirements. Both violations have been corrected. He rarely receives any complaints and this
program is largely complaint- driven, not pro - active by design. Commercial farm inspection is
ongoing, and inspections of hobby farms is primarily complaint - driven, not pro - active.
Task 5: Assist farmers to develop conservation plans consistent with CAO requirements.
Approve, condition, disapprove plans. Where violations occur for both commercial and non-
commercial fawns, landowners are referred to the Conservation District for assistance. This work
is ongoing.
Task 6: Reach a cooperative agreement between the EPA, DOE and Whatcom County. A
verbal agreement was reached this past summer between all parties regarding their respective
enforcement activities. No formal, written agreement has been reached.
NEW TASKS ADDED TO THE CLOSURE RESPONSE STRATEGY
Task 7: Report violations and enforcement actions taken to DHSPDAC on an
annual basis.
Task 8: Work with Nooksack Salmon Enhancement Association (NSEA) to
annually update stream enhancement projects that have been completed in the
watershed. (see Figure 9 for map of Nooksack Recovery Team (NRT) projects)
Objective Seven
Boats & Marinas
Port of Bellingham, Semiahmoo Marina, Department of Ecology
Blaine Seafood Processors
Two marinas operate at the entrance of Drayton Harbor. The Semiahmoo Marina Condominium
Association operates a 300 -slip marina for pleasure boats. The Semialmioo marina operates a marine
repair and fuel facility and currently has five live- aboards. The Port of Bellingham maintains Blaine
Harbor, which currently has 680 slips with the recent marina expansion. Blaine Harbor supports
commercial fishing vessels, fish processing facilities, and pleasure boats, including some live- aboards.
Due to the number and variety of vessels that actively use the Blame harbor, this marina represents
a greater potential source of pollution to Drayton Harbor (DOH Sanitary Survey 1995). As has
been reported to the DHSPDAC, the vessels owned by three (3) five- aboards were inspected as of
September, 1998. Two of these do not have any toilet facilities and the third vessel has disabled the
toilet. By using the shoreside facilities exclusively these vessels do not discharge sewage into harbor
waters. There are now eight five- aboards within the Blaine Harbor.
The State Health Department's ambient water quality data, Western Washington University's oyster
tissue sampling, and current water quality monitoring conducted by the Port of Bellingham all show
high fecal coliform levels recorded in the commercial section of Blaine Harbor as discussed earlier
in this report. This indicates that there are significant nearby sources impacting the Blaine Harbor.
25
Accomplishments up to September 1998 —Port of Bellingham
1) Followed recommendation BM -17 and BM -8 from the DHWMP and installed a portable
pump out station with a meter to monitor the number of boats using the facility. This station
serves the commercial fishing area of the marina allowing larger vessels off loading at Sea -K
Fish to utilize the facility and properly dispose of their vessel sewage. Project Cost
($229000.00)
2) Relocated the fixed pump out facility to a designated slip so that it is continuously accessible
to commercial and recreational vessels. Project Cost: ($4,500.00)
3) Since 1982, Port of Bellingham staff have worked with Washington Sea Grant to develop four
educational brochures for the boating public and special programs for commercial fishermen.
4) Installed signs at entrance to Blaine Harbor that reads: "ENTERING SENSITIVE AREA,
CONTACT HARBOR OFFICE FOR PUMP -OUT LOCATIONS." Project Cost:
($275.00)
5) Maintain informational signage encouraging all persons to help maintain the water quality of
the Drayton Harbor Watershed and its tributaries.
6) Educate lessees by the use of moorage agreements to promote environmental regulations. On
March 7, 1998 Harbor Rules and Regulations were modified to reflect Drayton Harbor as a"
zero discharge harbor" (Reference EPA non -point manual).
7) The Port of Bellingham conducted a dye test of the sanitation facilities and sewer lines at
Blaine Harbor. This test indicated all facilities are properly connected to the sanitary service
lines and that no cross connections to storm sewer exist. Project Cost: ($6,500.00)
8) Discovered several floor drains at the old Reef Fish lease site which were not connected.
New lessees have made the necessary repairs and the floor drains now flow into the sanitary
sewer.
9) The Port has developed a program to monitor the surface water within Blaine Harbor. This
is an 18 -month program attempting to identify sources of fecal coliform contamination within
Blaine Harbor. In addition to monitoring the fecal coliform levels, the program is conducting
a Fecal Strep Analysis using EPA method sm922D. The goal is to identify the fecal coliform
as being human, animal, or bird as primary sources.
10) The Port of Bellingham Marina's Division mails a "Marina Update" to all moorage customers
on a bimonthly basis. Since August 1994 more than 75% of the Marina Updates have
included articles regarding the importance of maintaining a clean harbor and have asked for
the cooperation of all vessel owners. Project Cost: ($2,000.00 annually)
11) Located and capped an open 4" sewer line at the Princess Elaina Pier, during surges of the
26
primary City of Blaine sewer line the 4" line would discharge mw sewage into the marina
basin Project Cost: ($1,100.00)
12) At the Washington Crab lease facility, the Port has identified and repaired a leak in the sewer
line. Project Cost: ($525.00)
Accomplishments up to May 2000
➢ CRS Task 1:The Port is currently monitoring a0 commercial activities, recreational boating,
seals, otters etc.. The Port is compiling data with an ongoing surface water monitoring
program The Port has increased from 12 sampling stations on a monthly basis to 16 stations
sampled bi- weekly. In addition to the 9 stations within Blaine Harbor and one inside
Semialunoo Harbor, the Port began sampling 6 stations `outside" in both Drayton Harbor (2)
and Semiahmoo Bay (4) as requested by the Whatoom County Council and DHSPDAC.
➢ CRS Task 2: Phase I moorage facilities are completed - including the installation of four state -of-
the- art portable sewage pump - out stations plus a fixed station. All stations include a dump station
as well. Phase II will add two more portable sewage pump - out stations plus a fixed station.
DRSPDAC Recommendations and Comments
Task 1: Monitor commercial activity while taking surface samples for water quality monitoring
and report to all interested parties. Ongoing as shown above.
Task 2: Report on number and types of Marine Sanitation Devices (MSD) in Blaine Harbor
and report to DHSPDAC. Improvements have been made and will continue with phase H of the
Blaine Marina expansion. Port staff have requested that each vessel owner respond to a survey
declaring the type of MSD that they have. The Port has received only a handfiil of responses.
DHSPDAC should be provided with a status report.
Task 3: Port of Bellingham, and Blaine Seafood Processors (BSP) should exchange water
quality data to help identify and control possible fecal sources. BSP has shared their sampling
results with the Port at the most recent Agency meeting in March, 2000. Ongoing.
Task 4: Department of Ecology should insure Blaine Seafood Processors are meeting their
NPDES permit requirements. Regular biennial inspections most be carried out by DOE. Permit
inspection for this facility is now 7 months overdue. TREE inspection haS been postponed with no
timeline offered. Request for complete inspection ASAP. DHSPDAC should be made a party of
record for BSP NPDES permits.
Task 5: Coordinate Port of Bellingham water quality sampling with the State Department of
Health. DOH and the Port have sampled together several times and have coordinated sampling
locations inside the Blaine commercial marina. Ongoing.
WA
Task 6: Compliance with the 401 Water Quality Certification including Enclosures 1 and COE
Permit # 97 -2- 00960. Actions include dye testing of various sewer and waste lines servicing the
Blaine Harbor fish processors, fecal coliform study of the sump pumps, inspection of all floor drains,
bird exclusion systems, investigation of sediments for fecal coliform, inspect old on -site systems, and
conduct fecal coliform testing at several locations in Semiahmoo Bay. Request that DHSPDAC be
made a party of record by the Port and Army Corps for the marina expansion p�roiect and associated
permit
Task 7: Distribute educational materials regarding water quality specific to Drayton
Harbor via "Marina Update" newsletter. (adapted from initial CRS) DHSPDAC has requested
an update of Drayton Harbor - specific educational topics that have addressed in this newsletter
since Sept 1998? Provide documentation of these educational efforts to DHSPDAC.
Task 8: Use moorage agreements to educate lessees and promote environmental regulations
(initial CRS). March 7 '98 Harbor Rules and Regs were updated showing Drayton Harbor as a
zero discharge harbor. Ongoing.
Task 9: Blaine Seafood Processors (BSP) will voluntarily sample outfall discharge and report
results to DHSPDAC. They have been doing routine sampling and reported the results to
DHSPDAC. They are currently working on elimination of fecal colifomt from the outfall waste water.
(Recommendations were made for chlorinator spray for sump and for a fecal monitoring plan.)
A TREE study to assist them with source identification and control methodology to be conducted
in cooperation with Ecology is pending. Scheduling has been difficult due to minimal activit.p �+
the processing facility.
BSP is actively working on the problem of a plugged outfafl line under the tide flats. This line
discharges fish waste. A contractor has been contacted and the plan is to clean out the line as
soon as they are able to get the work done. The access is under water at high tide and can only be
opened at low tide. As tides are not low enough during daylight hours, the project is on hold until
daytime tides are convenient. It is unknown what the condition of the outfall pipe is at this time.
BSP will be responsible for all costs incurred with this project. Voluntary samlmg is ongoing
NEW TASKS ADDED TO CLOSURE RESPONSE STRATEGY
Task 10: Review Blaine Seafood Processor (BSP) NPDES permit. It is up for renewal this
year.
Washington Administrative Code 173- 220 -080 Public access to information. "the department
shall make records relating to NPDES permits available to the public for inspection and copying."
Task 11: (Initial CRS) Provide permanent or temporary pumpouts for large boats at Sea
K. There is still no practical sewage numpout for large boats (draggers) at this facility This was
given a HIGH priority in the initial Closure Response Strategy and was assigned to BSP and the
Port of Bellingham
ig
Objective Eight
DHSPDAC General Recommendations
Task 1: Critical areas such as stream sections in need of restoration work and pristene
areas should be identified and mapped. (from p. 124 of the 1995 Drayton Harbor Watershed
Plan)
Task 2: Identify and communicate current public land acquisition programs to encourage
public acquisition, conservation easements, open space programs, and other tax incentive
programs for riparian and wetland areas. Focus on critical areas as identified in Task 1.
(GR -57 from 1995 Watershed Plan).
Task 3: Make Drayton Harbor Shellfish Protection District Advisory Committee a party of
record on all NPDES permits within the Drayton Harbor watershed.
Task 4: Conduct a circulation study of Drayton Harbor. The National Shellfish Sanitation
Proeram Manual, Section C, requires a `review of hydrographic factors that may affect
distribution of pollutants ". Because there is little if any study in this regard in Drayton Harbor.
DHSPDAC recommends that a field circulation study be conducted in Drayton Harbor by or in
coopmtion with SDOH.
Task 5: Maintain webpage and make it more user friendly, Add map /data links that are
more easily understood by community.
Task 6: Increase efforts regarding community involvement and education primarily
through newsletter, newspaper columns, and volunteer water quality monitoring efforts in
priority drainage's.
Task 7: The Boundary Bay and Georgia Basin Ecological Initiative work groups along with
the Drayton Harbor group are working on a Cross- Boundary workshop tentatively called
Shared Waters". A Cooperative Approach to Restoration of Shellfuh Growing Areas This
workshop will specifically deal with shellfish issues and downgrades involving Canada based
Boundary Bay Workgroup and Drayton Harbor, and is in the process of being developed. The
date for the workshop is slated for the middle of September. This workshop is the first in a series
that will provide an avenue for cooperative effort at solutions to potential pollution issues shared
in common between the two countries as they affect shellfish issues.
0z
Priority Recommendations as of May 2000
Objective One
Establish Coordinated Water Quality Program for Drayton Harbor
Task 4: Identify and pursue grants and loans for program implementation.
Based upon a Memorandum of Agreement between SDOH and DOE which outlines the
responsibilities of these agencies in response to shellfish rg owing area downgrades. "Ecology shall
assist local government, tribal govemment, and other affected agencies in identifying potential funding
mechanisms to implement the Response Strategy." Ongoing _support is needed to identify funding
mechanisms to implement these recommendations. ECOLOGY, LEAD AGENCY
Task 5: Secure dedicated funds for implementation using the Shellfish Protection District or
other means. DHSPDAC will schedule a meeting with the Water Resources Division or Water
Team to discuss the Drayton Harbor Recovery Plan and funding options under the Flood Tax, which
appears to be the most suitable source of sustainable funding for shellfish protection. There is a
serious need to clarify which if any Whatcom County agencies are interested in a long term lead
agency role. ECOLOGY, WATER TEAM
Objective Two
Identify Pollution Sources and Monitor Water Quality
Task I: Determine cost and evaluate benefits of conducting a TMDL study. Expedite this
process.Among other efforts, Explore with Ecology EAP team the usefulness of the 1995 Cvkler.
Haggerty and Matthews study for establishing a TMDL for Drayton Harbor. ECOLOGY
Task 2: Develop a coordinated water quality monitoring program to identify pollution
sources and to track changes in water quality. Monitoring in the future must be linked closely
with source identification and abatement and funds must be secured to support a long -term water
quality monitoring plan All of the monitoring programs to date do not have any dedicated long-
term funding source. It is critical to identify a sustainable source of funding to coordinate and
implement a long term water quality monitoring program in the Drayton Harbor watershed.
WHATCOM COUNTY, ECOLOGY,WSDOH, PORT OF BELLINGHAM, CITY OF BLAINE,
DHSPDAC.
Task 3: Develop Memorandum of Agreement for sampling agencies based on Coordinated
Monitoring plan. The Memorandum of Agreement (MOA) was developed in the Coordinated
Monitoring plan Implementation of the MOA is expected to be completed in Spring of 2000.
LEAD AGENCY AND AGENCIES IDENTIFIED IN TASK 2.
30
Task 4: Review Drayton Harbor watershed studies since 1973 and create an abstract
bibliography which will be available in hard copy and on the web site. WHATCOM
COUNTY STAFF OR CONTRACTORS
Task 5: Obtain a commitment for ongoing long -term water quality plan development and
funding. WHATCOM COUNTY, ECOLOGY,WSDOH, PORT OF BELLINGHAM, CITY OF
BLAINE, DHSPDAC
Objective Three
On -Site Sewage Systems
Task 1: Enforce existing OSS regulations. The Health Department will utilize the recently adopted
enforcement policy to ensure timely, permanent repair of all failures identified. As of this date,
identification of failing systems is still based upon a complaint- driven system WCHD
Task 2: Establish a countywide Operation and Maintenance Program for all OSS by the year
2000. Sensitive areas, such as the Drayton Harbor Watershed, will be the primary focus of the
initial phase of program implementation With regulatory changes, enabling implementation of
OSS Operation and Maintenance in place since November, 1999 this program should be
implemented in the Drayton Harbor Watershed immediately. WCHD, DHSPDAC
Task 3: Establish a permanent program for financial assistance for OSS repairs. Secure
agreements with implementing agencies and d implement by end of June 2000, WCHD
Task 4: Place a high priority on complaints to Whatwm County Health Department filed in the
Drayton Harbor Watershed. (OS -23 from 1995 Watershed Plan) and report to DHSPDAC annually
on complaints filed and actions taken in the watershed. WCHD
Task 5: Designate Drayton Harbor as an Area of Special Concern through the public process.
Additional requirements to reduce failure rates or minimize impacts of OSS on shellfish resources
are detailed in WCC 24.05.23, Areas of Special Concem This recommendation was identified as
high priority in the 1995 Closure Response Strategy but has not yet been initiated by the Pubhc
Health Officer. WCHD, DHSPDAC
Task 6: Require proof that a residence, served by an OSS, has a functioning OSS prior to
all real estate transactions. (based upon On Site Recommendation 29 from 1995 Watershed Plan)
WCHD
Objective Four
Control Stormwater Sources
Task 1: Investigate potential sources impacting priority storm water drainage around the
entire shoreline of Drayton Harbor. Report findings to DHSPDAC and take prompt action
to abate pollution sources when found. This task is based upon priority /problem drainage's as
31
identified in the W WU 1995 Fecal Coliform Contamination Study of Drayton Harbor., by Cykler,
Haggerty, and Matthews. A comprehensive physical survey of these areas is needed to identify
pollution sources and control them when found. A repeat study may be required to again
prioritize current problem drainages. WHATCOM COUNTY, ECOLOGY,WSDOH, PORT OF
BELLEQGHAM, CITY OF BLAINE, DHSPDAC, COMMUNITY PROGRAM.
Task 3: Control pet waste within Blaine City limits with the installation of stations
supplied with plastic bags(Mutt Mitts) and garbage cans for pet waste disposal. Stations
could be installed adjacent to both marinas and in community parks as well as Blaine proper.
CITY OF BLAINE, PORT OF BELLINGHAM, SEMIAHMOO MARINA.
Task 4: A member of DHSPDAC should be appointed to the storm water committee to
represent shellfish issues in and around Drayton Harbor as they relate to Blaine storm
water runoff and monitoring efforts.
Objective Five
Blaine Municipal Sewage Sources
Task 1: Complete sewage treatment improvements.
Furtherplanning for treatment plant relocatioon should give serious consideration to the tong
term restoration and viability of commercial shellfish classification in Drayton Harbor and should
consider more regional versus merely Parochial Ion term erm options. CITY OF BLAINE, WCDH,
DHSPDAC, COMMUNITY PROGRAM
Task 2: Investigate sewage treatment plant outfall location.
DOE and the City of Blaine with assistance from DOH if needed must discuss outfall issues as a
component of the Consent Order underway with Ecology and provide some summary and rationale
for their findings. CITY OF BLAINE, ECOLOGY, WSDOH, DHSPDAC
Task 3: Video project of Marine drive old sewer line and laterals to waterfront area. This initial
phase of the Sewer Collection System Integrity study being administered by PSRF is scheduled for
early May, 2000.
Task 4: Reduce Inflow and Infiltration (I &I) from the sanitary sewer collection system. Specific
activities will be identified through Consent Order between Ecology and Blaine. which is now
underway. CITY OF BLAINE, ECOLOGY
Task 5: Enforcement by Ecology when Blaine is out of compliance with NPDES permit and
when Marine Drive overflows occur( Initial CRS) . Report violations, overflow events,
enforcement actions to DHSPDAC as they occur. ECOLOGY
Task 6: Replacement of the underwater force main sewer crossing. Cathodic protection
problems with the new force main must be investigated and corrected ASAP, which we
understand is Blaine's intent at this time. A testing schedule should be negotiated between Blaine
32
and Ecology as a component of the Consent Agreement which is currently underway. CITY OF
BLAINE
Objective Six
Agriculture
Task 1: Provide financial assistance to 18 dairies to implement manure management plans.
Continue to support financial assistance for faun plan implementation using EQUIP and possibly
other funding sources. CONS DISTRICT
Task 2: Provide technical assistance to 18 dairies to develop manure management plans.
We encourage the Conservation District to explore options which will allow them to focus on
improvements at the several dairies with the most outdated farm plans This may reouire
additional staff and funding. CONS DISTRICT
Task 3: Provide technical assistance to small/non- commercial farmers and landowners to
develop manure management plans. Funding is needed to support this task in a pro - active,
focused minimum 3 -year program to better serve the landowners in the Drayton Harbor
Watershed by improved characterization of this issue and control of livestock waste as needed.
CONS DISTRICT
Task 4: Conduct farm inspection program. Refer farms to Conservation District to develop
conservation plans when required by the Critical Areas Ordinance (CAO). Refer BMP and
farm plan violations to County enforcement officer when necessary. Enforce compliance
with approved conservation plans. Enforce compliance with BMP's for small farms. Farm
inspections under the CAO for non - commercial farms are completely complaint - driven, not pro-
active by design Mechanisms should be developed to better serve hobby farms. CAO STAFF,
COMMUNITY PROGRAM.
Task 6: Reach a cooperative agreement between the EPA, DOE and Whatcom County. A
verbal agreement was reached this past summer between all parties regarding their respective
enforcement activities. No formal, written agreement has been reached. EPA, ECOLOGY,
WHATCOM COUNTY
NEW TASKS ADDED TO THE CLOSURE RESPONSE STRATEGY
Task 7: Report violations and enforcement actions taken to DHSPDAC on a
regular, annual basis. ECOLOGY, CAD STAFF
Task 8: Work with NSEA to annually update stream enhancement projects that
have been completed in the watershed. DHSPDAC, NSEA
33
Objective Seven
Boats & Marinas
Task 2: Report on number and types of Marine Sanitation Devices (MSD) in Blaine Harbor
and report to DHSPDAC. DHSPDAC should be provided with a status report. PORT OF
BELLINGHAM
Task 4: Department of Ecology should insure Blaine Seafood Processors are meeting their
NPDES permit requirements. Regular biennial inspections must be carried out by DOE. Permit
inspection for this facility is now 7 months overdue. TREE inspection has been difficult to
schedule for many reasons. Request for complete inspection ASAP. DHSPDAC should be made
a party of record for BSP NPDES Permits. ECOLOGY
Task 6: Compliance with the 401 Water Quality Certification including Enclosures 1 and COE
Permit # 97 -2- 00960. Request that DHSPDAC be made a paM of record by the Port and Armv
Corps for the marina expansion project and associated pemdts. ECOLOGY
Task 7: Distribute educational materials regarding water quality specific to Drayton
Harbor via "Marina Update" newsletter. (adapted from initial CRS) DHSPDAC has requested
an update of Drayton Harbor - specific educational topics that have addressed in this newsletter
since Sept 1998? Provide documentation of these educational efforts to DHSPDAC. PORT OF
BELLINGHAM.
NEW TASKS ADDED TO CLOSURE RESPONSE STRATEGY
Task 10: Review Blaine Seafood Processor (BSP) NPDES permit. It is up for renewal this
year. DHSPDAC, ECOLOGY
Task 11: (Initial CRS) Provide permanent or temporary pumpouts for large boats at Sea
K. There is till no practical sewage Pumpout for laree boats (draggers) at this facility. This was
OF BELLINGHAM, BSP
Objective Eight
General Recommendations
Task 1: Critical areas such as stream sections in need of restoration work and pristine areas
should be identified and mapped. (from p. 124 of the 1995 Drayton Harbor Watershed Plan)
LEAD AGENCY. COMMUNITY PROGRAM
34
Task 2: Identify and communicate current public land acquisition programs to encourage
public acquisition, conservation easements, open space programs, and other tax incentive
programs for riparian and wetland areas. Focus on critical areas as identified in Task 1.
(GR -57 from 1995 Watershed Plan). LEAD AGENCY, COMMUNITY PROGRAM
Task 3: Make Drayton Harbor Shellfish Protection District Advisory Committee a party of
record on all NPDES permits within the Drayton Harbor watershed. ECOLOGY
Task 4: Conduct a circulation study of Drayton Harbor. The National Shellfish Sanitation
Program Manual, Section C, requires a `review of hydrographic factors that may affect
distribution of pollutants ". Because there is little if any study in this regard in Drayton Harbor.
DHSPDAC recommends that a field circulation study be conducted in Drayton Harbor by or in
cooperation with SDOH. WSDOH, COMMUNITY PROGRAM
Task 5: Maintain webpage and make it more user friendly, Add map /data links that are
more easily understood by community. WHATCOM COUNTY CONTRACTORS, WSU
COOP EXT,
Task 6: Increase efforts regarding community involvement and education primarily
through newsletter and volunteer water quality monitoring efforts in priority drainage's.
COMMUNITY PROGRAM, WSU COOP EXT
Task 7: The Boundary Bay and Georgia Basin Ecological Initiative work groups along with
the Drayton Harbor group are working on a Cross- Boundary workshop tentatively called
"Shared Waters" A Cooperative Approach to Restoration of Sheffftsh Growing Areas.
Continue cooperative efforts with this group. LEAD AGENCY, DHSPDAC
35
APPENDIX SECTION
Contents
Drayton Harbor Shellfish Protection District Advisory Committee —List of Members
Figure 1: Drayton Harbor Watershed Map
Figure 2: WSDOH Ambient Monitoring Stations in Drayton Harbor and Port of
Bellingham Monitoring Stations in Blaine Commercial Marina
Table 1: WSDOH Ambient Sampling Results
Figure 3: Trends in Drayton Harbor shellfish classification, 1988 to the present
Table 2: Port of Bellingham Blaine Commercial Marina Water Quality Data
Table 3: WSDOH Sampling Results in Blaine Harbor
Figure 4: Blaine Commercial Marina data, Stations A and B
Figure 5: Blaine Commercial Marina data, Stations C and D
Figure 6: Blaine Commercial Marina data, Station E
Figure 7: Blaine Commercial Marina data, Vessel and Seagull Activity
Figure 8: Map of Commercial Dairies and Farm Plan Status
Figure 9: Map of Nooksack Recovery Team (NRT) Projects
DRAYTON HARBOR SHELLFISH PROTECTION DISTRICT ADVISORY COMMITTEE
MARTIN DELANGE
1445 BURK RD
BLAINE, WA 98230
354 -2049
Mdboys777 @cs.com
JANET HANSEN— VICE CHAIR
P.O. BOX 2147
BLAINE, WA 98231
332 -0522
JRhAaz com
GEOFF MENZIES - CHAIRMAN
988 W. LAUREL RD
FERNDALE, WA 98248
384 -9135
zmen7an.com
BJORN HRUTFIORD
P.O. BOX 922
BLAINE, WA 98231
332 -6306
ART CHOAT
PORT OF BELLINGHAM
676 -2500
AnQ( PortofBellinebam.com
RICHARD NEILY
P.O. BOX1021
BLAINE, WA
332 -5762
MARGARET KARDELL
8941 DEARBORN AV
BLAINE, WA 98230
332 -4411
Joaquinmiler@euddin1ccom
WILLIAM GOFF
P.O. BOX 506
BLAINE, WA 98231 -0506
332-6544
bgnw@earddidcnet
CHARLES HAWRINS
970 RUBY ST.
BLAINE, WA 98231
332 -8535
cmlwwldns@juno.com
BONNIE ONYON
Blaine City Council
332-4020
bonyon@oafinespathcom
2
x
m
A
O
i�
n
O_
M
C
7
N
N
O
y
A
D
N
3
3
O
N
Z
0
gg
m'
0
"g
(P
9)
mm
am0>
�fa
m
a
'�'
N
nT
nT
y
z
m
W
m
9
m
N
OOO
z
H
m30
i�
O
O
O
3
y
15
m
O
m
g
o
mi
o
_
y
G
&
sz
F
N
,'a
m
T
=
4.
m
m
O
a
myr
FL
r
z
Zo
N
m
%
@g
m&
O
O
O
O
0
0
T
G
m3
&
0
0
0
0
O
O
O
O
3
O
W
9
J
Oe$
z
0
0
0
0
0
0
�m
mn
D
3 °.
9
s
ffi
o
0
0
0
o
m
m
0
N�a
V
OIJ
Ali
�g
W
m1"N
W
0
0
oDo
mi
o
Figure 3. Trends in Drayton Harbor Shellfish Classification
pre -1988 1988 1995 1999
Source: Puget Sound Water Quality Action Team
® Prohibited
D Restricted
®Conditional
■Approved
M--I
O NO` +O i No N mm mN_ NN�m_130 N3 r3� O ;L o'
o a W J N W o
mmrommm �mm W M m��rd r3 mmmm�m�m���3m mm 3m� N
m m m m m W W W W W W W W W W W W W m W m W J J V J v V 01
fn Z -�
J d m d
N W N N + N A A+ O + 4'1 W + A+ 0 3 >•�
W+ J A N Ja d N
O
O
A N +
W T W (n
W W V N� V W J O W m W W O o did
O+ J O S A W O W N O W N O S 0 0 0 O W W J
0
m
N V N W W W W O p W N m N O A O A A+ N +$ N 0 0 0 (WT W O O m O o O 3 a
N O J O O W A O OI O O O S O O O O O W+ A O
A
ymym W ��ff _ y + fl
O m+ 0 0 0 v N O O W O 0 0 0 0 0 0 0 W W V V A A S S 0 0 OV101 O 3 d
3 3
— d
�N�ff yy N
m V N S S O OI W O O O O O S O O O O O O S W O W O O O W m O V O O
3
mmm' -mm�' NTmm -8- "mm8'- "8- 'm'- mmmmmm' -'T TT r T^'S -i8' -i m -1n
O'O'Q SO'O. F60'F60'O'O. O.Q$00'O'O'O'O'66G. 0.60.66 W N 0 W
d m
]] m
O no O O o Z Z Z Z Z Z Z {{ry Z Z Z Z p p Z Z N{N Z Z Z Z Z 'mm< d+ O
OW O o� '40 O b W� o o o o o o o� N O O O O W W O O d 0 0 0 0 0 9= N
?'m W
AN+ NN '
O OS„ WQ<W W Q�A
ZQ N W N" ""J O ZMZW 4S W 0)rnC Zfncoj U < <3 d
9
5 mm*fz WZ2: Z *O)M gggZmmmmm"'mZmmma
D
N O W W W W O m A A N N W ;j
N O O (T W W N N W m W W O A W+ m W W A W V N+ V
pr $mom
� d
O O W O O O O W O W W O W O O O O W O 0 0 0 0 W
0 on Sm OtWTOOOOON W mS fWl O W OtVI a5 OS����
O O O O O m m lWO W lWT O W (Ali O W N N N m W O W O O W D D D D Dld
0 0 0 0 0 0 ++ + o O g 0 0 0 0 0 0 0 m
zt zt -t O O N + N Q � N + � O +
S S S S S S m m W m m w w � w w m m o m W n
C
NZc
p W^ c cc
M N D j 3 a
W A W m V N m O W S m m O O O O O O O O O W S A W
N A O O O N S O O V S S m S S c o o W N 000
S Q N Q S S O S S S S p O O V G Q Q U Q Q
x
00 O O O O O O
+ O O m 0 0 0 O O O O O O O O O O O O O O
W) W
Z Q m W
ZNmmNN
mm m�
W
mNN
ZHm 0
m
m m
W
T
Y
<V V G
<$S
I
WA
e
W
r
N
Co
n
W < Z < 0 W
Co :E VE
or�A W N W V W V W V A O W A O O W H W W W N W Q
N
V m O N N N N O N O O N W S m S O N N 0
O N O N O O W SON Vt S� O S A N O� O N
A
N
O
N
f)
O
O
N
2
w
3
n
m'
R.
fit
m
m
Z
O'
w
���c
<^
n
T
w
Y D
i
D
C
o
m
m
y
y
3
9
x
y
m
m
a
r
qO�
p
n=
Ip
5L.A
m
A
m
g
o
s
6
o-
z
x
3
33p
d
o
@�
nRn�
MOK
�13j
N2N
3
em
3
u
5.
0'
m
2
m
O
NtO
AI\l�l��f
tU
tO
tO
a>Nro
ACl
tO
n
Dip
O
...
S
— gw4pwwwwg
m
Asap
_'
a
m
c
���
o
o
o
0
o
0
o�
o
o
.
m
Z
m
w
w
mg
o
m
m
m
m
3
m
m
@
m
Z'i
d
m
g
8
555558
OONmSN
V
0
q
g
o
m_
-.
G)
O
N
and
w
V
0
9
m
1
m
0
0
0
0
0
0
0
I�
-
e
�
n
M
M.
r
_
we
s
00
5
R'
a
GDS0000
A�
y
T_
N
3
G
O
O
O
o
O
CJ
o
N
d
a
O
m
3
_zmaa
9
3
0
G)
Q
N�
'S
OAP
V
wulw
pie
r
W
77
A
9
�
ONO�m
mN
r:
aaW
A
w
W
mmwo
�X
c
nw3
�
m
m
�m
�'m
t
C
3
m
D
o
5
Om���g�!
W m'a
I
�y?0'
D
m
o
w
mSm�m
m
.per
��
gm
D
W
N
W
m
O
V
n
o
w
A
H
Z
p
0
O
Ny
m
m
Q°
3
w
w
9\
y0
Q0
O
A
m
t
...,E ,
HI Hf i. i'.i hi iii! ikiF t
L I I , .;;il 11 1
ikil
Figure 6: Blaine Marina, Stations E, Port of Bellingham data
� I�
R
IIY
�
F
:'V
�
t
C
nuLm�3
lm
a
2
co
gg W W S
Z �o° v m 011
maw € @4s
mow, � � a aassa�sgs U�m E
z $
cc 2 gig HEIMUHHH.
o OT
d
q y
E$s;3x WZZ 10 VR° U }`z °gPyyf iii' =A'
&'y ° Y�__m Nry e+b'n 09ET� q�Q
�38rcF oS
no i s0oo
PI
:'V
nuLm�3
n
�
m
�
4
Po
mp
s
Po
tr
r
#
�
r
a
2
co
gg W W S
Z �o° v m 011
maw € @4s
mow, � � a aassa�sgs U�m E
z $
cc 2 gig HEIMUHHH.
o OT
d
q y
E$s;3x WZZ 10 VR° U }`z °gPyyf iii' =A'
&'y ° Y�__m Nry e+b'n 09ET� q�Q
�38rcF oS
no i s0oo
9
E
3
s
I
ads
8
w®us
m
•
5
�
Po
M
9tl wIRPo
a
Sg
8
•
m w.n.
a
�wsn
•
r.
�
�
o
EPPo
M
p
N
¢
i5
Iri
WN
'
�
wa
=
d
m
O
ry
2
2
?
y
O
0=0
a
LYO
L
C.
y
Cm
s
�
Q
v
i
�•
� V
d
g�
rc
Z =
�
5
-m
p N
U
Q
w
Q
.
O S
Y
m
m
a
Q
a 0 U
0