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HomeMy WebLinkAbout30 Z1 Jo Patricia Earnest P.O. Box 184 Nordland, WA 98358 June 27, 2017 TO: Stephen K. Causseaux, Esq. Jefferson County Hearing Examiner 902 South 10th Street, Tacoma Washington 98405 RE: Case: MLA17-00019 Building Permit: BLD 17-00093 Parcel No: 021204015 Address: 9272 Flagler Road, Nordland WA Washington State Liquor and Cannabis Board License #412943 Dear Mr. Causseaux, It seems to me that there are a number of contradictions, causing confusion for me in the public material regarding Jefferson County's attempt to permit Austin Smith's Application for growing &processing recreational cannabis in a rural residential 1:10 property on Marrowstone Island, a septic served community. Some confusion is possibly due to the pressure of too few hands at the DCD. In his June 21, article in the PT Leader, Smith claimed, "The plants are grown in a closed hydroponic system, where the state-approved nutrients feed the plants through a drip system, and there is no runoff." From BLD 17-00093 Permit Case Summary 4/20/17 Case condition#2 "JCPH approval for the septic system connection is approved based on the growing operation using soil as the growing medium. The use of hydroponic or water based growing media IS NOT approved." Yet in the SUMMARY OF APPLICATION AND RECOMMENDATION presented by the County for the Open Hearing, the word "hydroponic" is not mentioned. Not approved, not disapproved, not addressed at all. Most of my confusion comes from the reading of that material. When contacted after the Hearing was announced, Susan Porto, at Jefferson Environmental Health, who issued Case condition#2, confirmed her findings & suggested we contact the WA State Ecology Dept. to see if a permit for hydroponics in a septic only environment had been requested. Ellie Keys at ecy.wa.gov, said not to worry, it will be covered in the SEPA review. But wait, the grower claims exemption from SEPA siting first WAC 197-11-800 (I)(b)(iii) then corrects itself to (1)(b)(iv) likening it to a school or commercial building with up to 40 parking spots allowed. I received an e-mail on 6/26, from Gary Lee, also from the WA Department of Ecology. In it he states the following: Enclosed please find a checklist listing information that Ecology is asking marijuana growing facilities to provide in order to determine if a discharge permit is required for the facilities to discharge process wastewater. The checklist also provides Ecology's recommendations for disposal of wastewater. I don't think Ecology has received the checklist from the facility at this point. Please contact Ms. Ellie Key if you have any more questions since I will be out of office next week. Thanks. Gary Lee, P.E. Environmental Engineer Water Quality Program Department of Ecology Southwest Regional Office P.O. Box 47776 Olympia, WA 98504-7775 360-407-6291 Though there may be no purposeful runoff, in hydroponic growing of cannabis, as the buds get ready for harvest, there is a recommended few day flushing as fertilizers can become toxic. This according to several articles and a quote from the book AQUAPONIC GARDENING by Sylvia Bernstein in its 10th printing,April 2015. In the checklist referenced by Mr. Lee, the Wastewater Discharge Checklist, the grower explains his/her process for removal of that toxic waste. For a septic served property, that process also requires removal from the site. With no SEPA review, it's compliance is confusing to Marrowstone residents who rely on Jefferson County oversight to protect its citizens. Another confusion comes from the claim to be hiring Jefferson County residents for this project... Perhaps the erection of the greenhouse & attached, but seemingly separate, Head House, would employ current Jefferson residents. He also claimed in the Leader article, that "multiple people from the island"volunteered to help "crop the plants, when they have matured." maintaining therefore that Islanders would be working "with us" not "for us," which makes sense as he has also claimed to only have extended family working on the site, all of whom will stay in his residence. He does not mention at that time where his immediate family will reside, however, and that is confusing in a rural residential neighborhood where the owner & the County claim that the residence is the primary focus of the land use in this case. More confusion in the SUMMARY 2.c. since Cottage Industries were permitted to allow the resident to expand the existing home business, and here it is explained that the owner "will reside" in the dwelling unit as a condition of the Cottage Industry Permit, per JCC 18.20.170 (4) a. and Staff Comments from b. yet it seems that the grow is the reason the family, I mean extended family will reside here. Another point of confusion comes from the Leader article with Smith claiming that the closest Grocery Store had a pot shop next to it, making the location a "perfect fit." However, the closest Grocery store is on Marrowstone Island, begun in 1923, and has a sail shop next to it & a goat farm behind it. No pot shop. However, in Port Hadlock, on the mainland, is a supermarket chain store, QFC, which has a pot store maybe a quarter or half a mile away. Curiously enough, Port Hadlock, according to JCC 18.18 table 3A-1, prohibits recreational marijuana grows in any of its residential designated areas. That only speaks to the in-attention the owner seems to be paying to the actual nature of the area & its residents. The items in the Summary of Application and Recommendation from 4. JCC - 18.20.170 Cottage Industries, refers to the dwelling use, the property use & the Head House section only of the proposed BLD 17-00093, from page 9 into page 12. It does not relate to the grow. 5. JCC 18.20.295 brings it back to the production side of the permit. The division in the space, the JCC rules and the housing stipulation makes it sound like there should be a request for two separate structure and attendant use permits for the property. ... It is here that the stipulations from the Permit Case Summary are missing.(BLD17-00093, Case conditions #2 and#23.) The greenhouse growing section has different "pollution" mitigation needs from the Cottage Industry processing. The Processing itself is not addressed,just its relation to owner residence. That is an omission and should perhaps be a SEPA review item as well as the hydroponics & attendant waste removal. Waste water, tool cleaning, apparatus cleaning, is not addressed. Venting of air and heat build up via the ceiling vents, shown in the architectural drawing of the structure, is not addressed. A quote from the newspaper article is that there are no "armed guards."Are there un- armed guards?Are there guard dogs?This is a family dwelling... residential in nature. If the family resides there, it's rural residential. If only extended family resides there to work at the facility, it's a bunk house. 14 (j)As Smith's extended family likely does not already live in Jefferson County, it will bring employed folks into Jefferson, but it will likely not add employment for current residents as claimed. Case condition#23 "No plumbing has been reviewed or approved for this project by Jefferson County Public Health.Additional requirements may apply if plumbing is proposed." I am mystified as to how a drip irrigation hydroponic grow of this size needs no plumbing. Thank you for your consideration in this matter. There are more questions than answers for me at this point. Respectfu s miffed, Patricia Earnest Attachments to Mr. Causseaux only cc: Patty Charnas, Director of Community Development, pcharnas@co.jefferson.wa.us Pat Hopper,Associate Planner, phopper@co.jefferson.wa.us Kate Dean, County Commissioner District 1,jeffbocc@co.jefferson.wa.us Kathleen Kler, Commissioner District 3,jeffbocc@co.jefferson.wa.us David Sullivan, Commissioner District 2,jeffbocc@co.jefferson.wa.us Philip Morley, County Administrator,pmorley@co.jefferson.wa.us aarthur@ptleader.com cmcfarl and@peninsuladailynews.corn from AQUAPONIC GARDENING by Sylvia Bernstein copyright 2011 10th Printing April 2015 New Society Publishers P.O. Box 189, Gabriola Island, BC VOR 1X0, Canada (250) 247-9737 • Bernstein was part of the original founding team of AeroGrow, the makers ofaroGarden, a counte droponic system for growing herbs & lettuces. She was there.from-2003 to 2009 & left as VP of ,eting & Product Development to pursue the symbiotic system called Aquaponics. Early in the. book she discusses hydroponics... p. xxi She refers to the ..."expensive and often unsafe chemical fertilizers in hydroponics..." ,x. p. 3. "Hydroponics requires a constant replenishment and manual balancing of the chemical nutrients, or the plants die." "...hydroponics:. you might have also heard of it because it is the favored growing method of marijuana producers." She mentions three styles of growing: 1. Flood & drain (ebb &flow) 2. Nutrient film technique (NFT) 3. Deep-water culture or Raft (DWC) p. 4. "Water in hydroponic systems need to be discharged periodically, as the salts and chemicals build up to levels that become toxic to the plants. This is both inconvenient & problematic as the disposal location of this waste water needs to be carefully considered." rrouuuer►rrocessor Wastewater Discharge Checklist DEPARTMENT OF ECOLOGY State of Washington Washington State's water pollution control law requires a permit for the discharge of industrial or commercial wastewater to"waters of the state",which includes surface and groundwater. Dischargers of wastewater must provide all known available and reasonable methods of treatment(AKART), prevention and control before discharge. The Washington State Department of Ecology (Ecology)regulates discharges of wastewater with permits to ensure AKART is provided and that public health is protected. Checklist Ecology developed this checklist to determine if a process wastewater associated with an I-502 producer/ processor will discharge to waters of the state and require a discharge permit. Please submit the completed checklist 60 days in advance of the start of producing/processing operations to allow sufficient time for review. Wastewater Discharge Options Ecology will not require a discharge permit when the completed checklist shows there will be no discharge of a pollutant into waters of the state when the I-502 applicant implements AKART. Wastewater information on this new industry is evolving. In the majority of cases to date,the volume of wastewater from I-502 producer/ processors is considered to be minimal or there is no discharge. Potential discharge options: 1. Publicly Owned Wastewater Treatment Works Discharge to a local municipal sanitary sewer system is the preferred option for 1-502 facilities that have discharges associated with cleaning,rinsing,THC extraction,hydroponic irrigation, and the manufacture of edible products. Discharges can be either direct connection to the sewer collection system, or by collecting the I-502 wastewater in a tank and transporting it to the municipal sanitary system for disposal. Written approval must be obtained from the local sewer agency prior to commencing any discharge. It is highly recommended that I-502 facilities considering this option contact the Water Quality Program's pre-treatment engineer at the appropriate regional Ecology office for guidance. 2. Septic Tank and Drain Field/French Drain Ecology does not allow commercial or industrial wastewater to be discharged to a septic tank/drain field or French drain system. Ecology does not accept that septic tanks/French drains provide AKART for commercial and industrial wastewater, unless the discharge meets the requirements of the local health department. Ecology generally considers the presence of floor drains in an I-502 producer/processor facility to be connected to a septic tank/drain field system. 3. Surface Water Discharge Ecology strongly discourages this discharge option. It would require that the operation be permitted under the federal National Pollutant Discharge Elimination System(NPDES)under the authority of the Clean Water Act. The permit would contain stringent discharge limitations and testing requirements. 4. Land Application/Spray Irrigation This option could require the 1-502 proponent to submit an engineering report to Ecology that describes AKART for the 1-502 facility and a groundwater analysis of the site. Ecology would subsequently issue • LL LtLLd VY(40(S-, ulOvllul 5, luuL LILUL VV Vulu hili lALLV 111V111LV11115 L11V VV UJw VV uwl U11,1 LL1, 51(l Ul All VY(Awl. Contact the appropriate regional Ecology regional office for guidance on this option. • Prohibited discharge options: 1. Drywells Drywells and infiltration trenches with perforated pipe are underground injection control wells and cannot be used for disposing of any industrial or commercial process wastewater. For more information see: http://www.ecy.wa.gov/programs/wq/grndwtr/uic/index.html. 2. Stormwater Collection Systems The discharge of any industrial or commercial process wastewater into a stormwater system is prohibited. Other Environmental Considerations Ecology maintains a website: http://www.ecy.wa.gov/topics/marijuana.html providing information about other environmental considerations for I-502 licensees. Questions? Ecology encourages I-502 producers/processors to contact their county's regional Water Quality Program office for assistance in completing the wastewater discharge checklist. • Southwest Regional Office (Clallam, Clark, Cowlitz, Grays Harbor,Jefferson, Mason, Lewis,Pacific, and Pierce counties): (360) 407-6300 • Northwest Regional Office (Island, King, Kitsap, San Juan, Skagit, Snohomish, and Whatcom counties): (425) 649-7000 • Central Regional Office(Benton, Chelan, Douglas, Kittitas, Klickitat, Okanogan, and Yakima counties): (509) 575-2490 • Eastern Regional Office (Adams,Asotin, Columbia, Ferry,Franklin, Garfield, Grant,Lincoln, Pend Oreille, Spokane, Stevens,Walla Walla, and Whitman counties): (509) 329-3400 To request ADA accommodation including materials in a format for the visually impaired, call the Water Quality Program at Ecology, 360-407-6600.Persons with impaired hearing may call Washington Relay Service at 711.Persons with speech disability may call TTY at 877-833-6341. YYaJIll11gWVU oIilIG LIIiUUC I.VUICVI Dual U k YY OLl.1))LIi:GIISC 1ypU k . ,'., I.ICI 1): Number: SECTION B. PRODUCTION WASTEWATER Yes Is production(growing)proposed at this location?If no,proceed to Section C. 1. Describ any differences between the Operation'. lan and the actual planned production growing) 2. What is the water source? •,' If private well,provide legal description of %S ' S S TWN the well(to the nearest'A 1/4 section, ' R township,range) If public water supply,itOvide name 3. Production type(soil,hydroponic, aeroponic) If hydroponic,list reservoir size(gallons) Frequency of water exchange(day\or weeks) Approximate volume of water exchan (gallons) '• ` 4. Estimated annual production(pounds) 5. Months of production 6. Number of harvests per year 7. Name(s)of craning products used f 8. Average volume of production wastewater produced daily(gallons) 9. Dischar '" to publicly owned sanitary Yes No wastew ter collection and treatment syste . If yqg,name of system 10. D you have written approval from the Yes No blically owned system? iy If yes,attach the approval letter If no,what i 11....._ is the proposed method of wastewater disposal(e.g.,land application, irrigation)? . I ation or.....;.1; 'i "'is proposed, provide the et ...; i �0,aptyhtition run,1LLG U 1G�,'41 LLGJGl 1FJLIVII Vl LII 743 743 3 1 W 1V application site R (to the nearest 1/41/4 section,township, range) Attach an aerial map of the acreage 12. Explain what steps or measures will be taken to minimize the amount of wastewater generated,or improve the quality of wastewater produced. vv iA'lllugtlln auate Lltiuui ILA/1111W l/uitlu vv Ll.13.1 LICCHJC type lG.g'., I IC! 1); Number: SECTION C. PROCESSING WASTEWATER Yes No Is processing proposed at this location?If no, STOP. 1. Describe any differences between the Operation Plan and the actual planned processing 2. Average volume of processing wastewater produced daily(gallons) 3. Will THC be extracted? If yes,what extraction chemicals will be used? 4. Will edible products be produced? If yes,name products 5. What is the estimated annual production (pounds)of each edible product? 6. Months of production 7. Discharge to publicly owned sanitary Yes No wastewater collection and treatment system? If yes,name of system 8. Do you have written approval? Yes No If yes,attach the approval letter If no,what is the proposed method of wastewater disposal(e.g.,land application, irrigation)? 9. If land application or irrigation is proposed, provide the number of acres used for application Provide a legal description of the '/4S '/4S S TWN application site R (to the nearest 1/4 1/4 section,township, range) Attach an aerial map of the acreage 10. Explain what steps or measures will be taken to minimize the amount of wastewater generated,or improve the quality of wastewater produced. 11. What is the water source? • 11 p11VtLG VVG11, }MUVIUG 1G ,c1.1 ucs iiptioii V1 740 /40 1. VVI' the well(to the nearest 1/4 '/4 section, _R township,range) If public water supply,provide name 12. Estimated average daily water use(gallons/ day) vvaJUIIIgWU a CQIC LIquu( <.VUICVI DVQIU Iry OLA-D) LILCU,C II mum': 1ypv t,v.gy 11v1 1); SECTION A. GENERAL INFORMATION Attach a copy of the Operation Plan submitted with the WSLCB License Application. 1. Business name 2. Owner 3. Operator 4. Primary contact 5. Business address 6. Phone 7. Email 8. Latitude/longitude in decimal degrees(NAD83/ WGS84) 9. Site size(dimensions in feet) X 10. Zoning 11. Soil type(available from NRCS at: http://websoilsurvey.nres.usda.gov/app/) 12. Nearest surface water body(stream, lake, wetland) 13. Distance from surface water body(feet) 14. Depth to groundwater(feet) 15. Average ground slope of production site(percent) 16. Nearest well(feet),well type and owner 17. Legal description of the nearest well 1/4S 1/4S S TWN R (to the nearest 1/4 1/4 section,township,range) Z1 Jo Patricia Earnest P.O. Box 184 Nordland, WA 98358 June 27, 2017 TO: Stephen K. Causseaux, Esq. Jefferson County Hearing Examiner 902 South 10th Street, Tacoma Washington 98405 RE: Case: MLA17-00019 Building Permit: BLD 17-00093 Parcel No: 021204015 Address: 9272 Flagler Road, Nordland WA Washington State Liquor and Cannabis Board License #412943 Dear Mr. Causseaux, It seems to me that there are a number of contradictions, causing confusion for me in the public material regarding Jefferson County's attempt to permit Austin Smith's Application for growing &processing recreational cannabis in a rural residential 1:10 property on Marrowstone Island, a septic served community. Some confusion is possibly due to the pressure of too few hands at the DCD. In his June 21, article in the PT Leader, Smith claimed, "The plants are grown in a closed hydroponic system, where the state-approved nutrients feed the plants through a drip system, and there is no runoff." From BLD 17-00093 Permit Case Summary 4/20/17 Case condition#2 "JCPH approval for the septic system connection is approved based on the growing operation using soil as the growing medium. The use of hydroponic or water based growing media IS NOT approved." Yet in the SUMMARY OF APPLICATION AND RECOMMENDATION presented by the County for the Open Hearing, the word "hydroponic" is not mentioned. Not approved, not disapproved, not addressed at all. Most of my confusion comes from the reading of that material. When contacted after the Hearing was announced, Susan Porto, at Jefferson Environmental Health, who issued Case condition#2, confirmed her findings & suggested we contact the WA State Ecology Dept. to see if a permit for hydroponics in a septic only environment had been requested. Ellie Keys at ecy.wa.gov, said not to worry, it will be covered in the SEPA review. But wait, the grower claims exemption from SEPA siting first WAC 197-11-800 (I)(b)(iii) then corrects itself to (1)(b)(iv) likening it to a school or commercial building with up to 40 parking spots allowed. I received an e-mail on 6/26, from Gary Lee, also from the WA Department of Ecology. In it he states the following: Enclosed please find a checklist listing information that Ecology is asking marijuana growing facilities to provide in order to determine if a discharge permit is required for the facilities to discharge process wastewater. The checklist also provides Ecology's recommendations for disposal of wastewater. I don't think Ecology has received the checklist from the facility at this point. Please contact Ms. Ellie Key if you have any more questions since I will be out of office next week. Thanks. Gary Lee, P.E. Environmental Engineer Water Quality Program Department of Ecology Southwest Regional Office P.O. Box 47776 Olympia, WA 98504-7775 360-407-6291 Though there may be no purposeful runoff, in hydroponic growing of cannabis, as the buds get ready for harvest, there is a recommended few day flushing as fertilizers can become toxic. This according to several articles and a quote from the book AQUAPONIC GARDENING by Sylvia Bernstein in its 10th printing,April 2015. In the checklist referenced by Mr. Lee, the Wastewater Discharge Checklist, the grower explains his/her process for removal of that toxic waste. For a septic served property, that process also requires removal from the site. With no SEPA review, it's compliance is confusing to Marrowstone residents who rely on Jefferson County oversight to protect its citizens. Another confusion comes from the claim to be hiring Jefferson County residents for this project... Perhaps the erection of the greenhouse & attached, but seemingly separate, Head House, would employ current Jefferson residents. He also claimed in the Leader article, that "multiple people from the island"volunteered to help "crop the plants, when they have matured." maintaining therefore that Islanders would be working "with us" not "for us," which makes sense as he has also claimed to only have extended family working on the site, all of whom will stay in his residence. He does not mention at that time where his immediate family will reside, however, and that is confusing in a rural residential neighborhood where the owner & the County claim that the residence is the primary focus of the land use in this case. More confusion in the SUMMARY 2.c. since Cottage Industries were permitted to allow the resident to expand the existing home business, and here it is explained that the owner "will reside" in the dwelling unit as a condition of the Cottage Industry Permit, per JCC 18.20.170 (4) a. and Staff Comments from b. yet it seems that the grow is the reason the family, I mean extended family will reside here. Another point of confusion comes from the Leader article with Smith claiming that the closest Grocery Store had a pot shop next to it, making the location a "perfect fit." However, the closest Grocery store is on Marrowstone Island, begun in 1923, and has a sail shop next to it & a goat farm behind it. No pot shop. However, in Port Hadlock, on the mainland, is a supermarket chain store, QFC, which has a pot store maybe a quarter or half a mile away. Curiously enough, Port Hadlock, according to JCC 18.18 table 3A-1, prohibits recreational marijuana grows in any of its residential designated areas. That only speaks to the in-attention the owner seems to be paying to the actual nature of the area & its residents. The items in the Summary of Application and Recommendation from 4. JCC - 18.20.170 Cottage Industries, refers to the dwelling use, the property use & the Head House section only of the proposed BLD 17-00093, from page 9 into page 12. It does not relate to the grow. 5. JCC 18.20.295 brings it back to the production side of the permit. The division in the space, the JCC rules and the housing stipulation makes it sound like there should be a request for two separate structure and attendant use permits for the property. ... It is here that the stipulations from the Permit Case Summary are missing.(BLD17-00093, Case conditions #2 and#23.) The greenhouse growing section has different "pollution" mitigation needs from the Cottage Industry processing. The Processing itself is not addressed,just its relation to owner residence. That is an omission and should perhaps be a SEPA review item as well as the hydroponics & attendant waste removal. Waste water, tool cleaning, apparatus cleaning, is not addressed. Venting of air and heat build up via the ceiling vents, shown in the architectural drawing of the structure, is not addressed. A quote from the newspaper article is that there are no "armed guards."Are there un- armed guards?Are there guard dogs?This is a family dwelling... residential in nature. If the family resides there, it's rural residential. If only extended family resides there to work at the facility, it's a bunk house. 14 (j)As Smith's extended family likely does not already live in Jefferson County, it will bring employed folks into Jefferson, but it will likely not add employment for current residents as claimed. Case condition#23 "No plumbing has been reviewed or approved for this project by Jefferson County Public Health.Additional requirements may apply if plumbing is proposed." I am mystified as to how a drip irrigation hydroponic grow of this size needs no plumbing. Thank you for your consideration in this matter. There are more questions than answers for me at this point. Respectfu s miffed, Patricia Earnest Attachments to Mr. Causseaux only cc: Patty Charnas, Director of Community Development, pcharnas@co.jefferson.wa.us Pat Hopper,Associate Planner, phopper@co.jefferson.wa.us Kate Dean, County Commissioner District 1,jeffbocc@co.jefferson.wa.us Kathleen Kler, Commissioner District 3,jeffbocc@co.jefferson.wa.us David Sullivan, Commissioner District 2,jeffbocc@co.jefferson.wa.us Philip Morley, County Administrator,pmorley@co.jefferson.wa.us aarthur@ptleader.com cmcfarl and@peninsuladailynews.corn from AQUAPONIC GARDENING by Sylvia Bernstein copyright 2011 10th Printing April 2015 New Society Publishers P.O. Box 189, Gabriola Island, BC VOR 1X0, Canada (250) 247-9737 • Bernstein was part of the original founding team of AeroGrow, the makers ofaroGarden, a counte droponic system for growing herbs & lettuces. She was there.from-2003 to 2009 & left as VP of ,eting & Product Development to pursue the symbiotic system called Aquaponics. Early in the. book she discusses hydroponics... p. xxi She refers to the ..."expensive and often unsafe chemical fertilizers in hydroponics..." ,x. p. 3. "Hydroponics requires a constant replenishment and manual balancing of the chemical nutrients, or the plants die." "...hydroponics:. you might have also heard of it because it is the favored growing method of marijuana producers." She mentions three styles of growing: 1. Flood & drain (ebb &flow) 2. Nutrient film technique (NFT) 3. Deep-water culture or Raft (DWC) p. 4. "Water in hydroponic systems need to be discharged periodically, as the salts and chemicals build up to levels that become toxic to the plants. This is both inconvenient & problematic as the disposal location of this waste water needs to be carefully considered." rrouuuer►rrocessor Wastewater Discharge Checklist DEPARTMENT OF ECOLOGY State of Washington Washington State's water pollution control law requires a permit for the discharge of industrial or commercial wastewater to"waters of the state",which includes surface and groundwater. Dischargers of wastewater must provide all known available and reasonable methods of treatment(AKART), prevention and control before discharge. The Washington State Department of Ecology (Ecology)regulates discharges of wastewater with permits to ensure AKART is provided and that public health is protected. Checklist Ecology developed this checklist to determine if a process wastewater associated with an I-502 producer/ processor will discharge to waters of the state and require a discharge permit. Please submit the completed checklist 60 days in advance of the start of producing/processing operations to allow sufficient time for review. Wastewater Discharge Options Ecology will not require a discharge permit when the completed checklist shows there will be no discharge of a pollutant into waters of the state when the I-502 applicant implements AKART. Wastewater information on this new industry is evolving. In the majority of cases to date,the volume of wastewater from I-502 producer/ processors is considered to be minimal or there is no discharge. Potential discharge options: 1. Publicly Owned Wastewater Treatment Works Discharge to a local municipal sanitary sewer system is the preferred option for 1-502 facilities that have discharges associated with cleaning,rinsing,THC extraction,hydroponic irrigation, and the manufacture of edible products. Discharges can be either direct connection to the sewer collection system, or by collecting the I-502 wastewater in a tank and transporting it to the municipal sanitary system for disposal. Written approval must be obtained from the local sewer agency prior to commencing any discharge. It is highly recommended that I-502 facilities considering this option contact the Water Quality Program's pre-treatment engineer at the appropriate regional Ecology office for guidance. 2. Septic Tank and Drain Field/French Drain Ecology does not allow commercial or industrial wastewater to be discharged to a septic tank/drain field or French drain system. Ecology does not accept that septic tanks/French drains provide AKART for commercial and industrial wastewater, unless the discharge meets the requirements of the local health department. Ecology generally considers the presence of floor drains in an I-502 producer/processor facility to be connected to a septic tank/drain field system. 3. Surface Water Discharge Ecology strongly discourages this discharge option. It would require that the operation be permitted under the federal National Pollutant Discharge Elimination System(NPDES)under the authority of the Clean Water Act. The permit would contain stringent discharge limitations and testing requirements. 4. Land Application/Spray Irrigation This option could require the 1-502 proponent to submit an engineering report to Ecology that describes AKART for the 1-502 facility and a groundwater analysis of the site. Ecology would subsequently issue • LL LtLLd VY(40(S-, ulOvllul 5, luuL LILUL VV Vulu hili lALLV 111V111LV11115 L11V VV UJw VV uwl U11,1 LL1, 51(l Ul All VY(Awl. Contact the appropriate regional Ecology regional office for guidance on this option. • Prohibited discharge options: 1. Drywells Drywells and infiltration trenches with perforated pipe are underground injection control wells and cannot be used for disposing of any industrial or commercial process wastewater. For more information see: http://www.ecy.wa.gov/programs/wq/grndwtr/uic/index.html. 2. Stormwater Collection Systems The discharge of any industrial or commercial process wastewater into a stormwater system is prohibited. Other Environmental Considerations Ecology maintains a website: http://www.ecy.wa.gov/topics/marijuana.html providing information about other environmental considerations for I-502 licensees. Questions? Ecology encourages I-502 producers/processors to contact their county's regional Water Quality Program office for assistance in completing the wastewater discharge checklist. • Southwest Regional Office (Clallam, Clark, Cowlitz, Grays Harbor,Jefferson, Mason, Lewis,Pacific, and Pierce counties): (360) 407-6300 • Northwest Regional Office (Island, King, Kitsap, San Juan, Skagit, Snohomish, and Whatcom counties): (425) 649-7000 • Central Regional Office(Benton, Chelan, Douglas, Kittitas, Klickitat, Okanogan, and Yakima counties): (509) 575-2490 • Eastern Regional Office (Adams,Asotin, Columbia, Ferry,Franklin, Garfield, Grant,Lincoln, Pend Oreille, Spokane, Stevens,Walla Walla, and Whitman counties): (509) 329-3400 To request ADA accommodation including materials in a format for the visually impaired, call the Water Quality Program at Ecology, 360-407-6600.Persons with impaired hearing may call Washington Relay Service at 711.Persons with speech disability may call TTY at 877-833-6341. YYaJIll11gWVU oIilIG LIIiUUC I.VUICVI Dual U k YY OLl.1))LIi:GIISC 1ypU k . ,'., I.ICI 1): Number: SECTION B. PRODUCTION WASTEWATER Yes Is production(growing)proposed at this location?If no,proceed to Section C. 1. Describ any differences between the Operation'. lan and the actual planned production growing) 2. What is the water source? •,' If private well,provide legal description of %S ' S S TWN the well(to the nearest'A 1/4 section, ' R township,range) If public water supply,itOvide name 3. Production type(soil,hydroponic, aeroponic) If hydroponic,list reservoir size(gallons) Frequency of water exchange(day\or weeks) Approximate volume of water exchan (gallons) '• ` 4. Estimated annual production(pounds) 5. Months of production 6. Number of harvests per year 7. Name(s)of craning products used f 8. Average volume of production wastewater produced daily(gallons) 9. Dischar '" to publicly owned sanitary Yes No wastew ter collection and treatment syste . If yqg,name of system 10. D you have written approval from the Yes No blically owned system? iy If yes,attach the approval letter If no,what i 11....._ is the proposed method of wastewater disposal(e.g.,land application, irrigation)? . I ation or.....;.1; 'i "'is proposed, provide the et ...; i �0,aptyhtition run,1LLG U 1G�,'41 LLGJGl 1FJLIVII Vl LII 743 743 3 1 W 1V application site R (to the nearest 1/41/4 section,township, range) Attach an aerial map of the acreage 12. Explain what steps or measures will be taken to minimize the amount of wastewater generated,or improve the quality of wastewater produced. vv iA'lllugtlln auate Lltiuui ILA/1111W l/uitlu vv Ll.13.1 LICCHJC type lG.g'., I IC! 1); Number: SECTION C. PROCESSING WASTEWATER Yes No Is processing proposed at this location?If no, STOP. 1. Describe any differences between the Operation Plan and the actual planned processing 2. Average volume of processing wastewater produced daily(gallons) 3. Will THC be extracted? If yes,what extraction chemicals will be used? 4. Will edible products be produced? If yes,name products 5. What is the estimated annual production (pounds)of each edible product? 6. Months of production 7. Discharge to publicly owned sanitary Yes No wastewater collection and treatment system? If yes,name of system 8. Do you have written approval? Yes No If yes,attach the approval letter If no,what is the proposed method of wastewater disposal(e.g.,land application, irrigation)? 9. If land application or irrigation is proposed, provide the number of acres used for application Provide a legal description of the '/4S '/4S S TWN application site R (to the nearest 1/4 1/4 section,township, range) Attach an aerial map of the acreage 10. Explain what steps or measures will be taken to minimize the amount of wastewater generated,or improve the quality of wastewater produced. 11. What is the water source? • 11 p11VtLG VVG11, }MUVIUG 1G ,c1.1 ucs iiptioii V1 740 /40 1. VVI' the well(to the nearest 1/4 '/4 section, _R township,range) If public water supply,provide name 12. Estimated average daily water use(gallons/ day) vvaJUIIIgWU a CQIC LIquu( <.VUICVI DVQIU Iry OLA-D) LILCU,C II mum': 1ypv t,v.gy 11v1 1); SECTION A. GENERAL INFORMATION Attach a copy of the Operation Plan submitted with the WSLCB License Application. 1. Business name 2. Owner 3. Operator 4. Primary contact 5. Business address 6. Phone 7. Email 8. Latitude/longitude in decimal degrees(NAD83/ WGS84) 9. Site size(dimensions in feet) X 10. Zoning 11. Soil type(available from NRCS at: http://websoilsurvey.nres.usda.gov/app/) 12. Nearest surface water body(stream, lake, wetland) 13. Distance from surface water body(feet) 14. Depth to groundwater(feet) 15. Average ground slope of production site(percent) 16. Nearest well(feet),well type and owner 17. Legal description of the nearest well 1/4S 1/4S S TWN R (to the nearest 1/4 1/4 section,township,range)