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Part of Water Quality Standards in Oakland Bay Associated with Shelton Sewage Treatment Plant

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The Problems with Water Quality Standards in Oakland Bay
associated with the Shelton Sewage Treatment Plant

by
Maryam Farahzad

A Thesis: Essay of Distinction
Submitted in partial fulfillment of the requirement for the degree
Master of Environmental Studies
The Evergreen State College
July 2009

i

This Thesis for the Master of Environmental Studies Degree
by

Maryam Farahzad

has been approved for
The Evergreen State Collage
by

_________________________
Ralph Murphy
Member of the Faculty

_____________________
Date

ii

ABSTRACT

The City of Shelton, Washington has recently produced the document Shelton Area
Water and Sewer Regional Plan (November 2002). This plan looks at a regional system
that would include the City of Shelton, the Washington Correction Center, the State
Patrol Academy, the Port of Shelton and Mason County. This plan for a regional system
may bring changes to the wastewater plant over the next few years. In this thesis, I
examine the problems associated with existing water quality standards in Oakland Bay
(fecal coliform, low dissolved oxygen, high water temperatures, and low instream flows).

I then analyze the stakeholders’ positions and the City of Shelton’s Sewage
treatment proposal for increasing the discharge into the Oakland Bay. I have evaluated
five plans to deal with the scientific, environmental, technical and economic impacts of
managing Mason County's wastewater in the future. Each plan’s solution has a summery
of possible benefits and issues. The plans further discuss how the City of Shelton's
wastewater treatment plant will be brought into regulatory compliance during winter
storms and how the region’s capacity for growth will be expanded.

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Table of Contents
Abstract............................................................................................................................. iii
List of Tables ......................................................................................................................v
List of Figures................................................................................................................... vi
1. Introduction....................................................................................................................1
1.1. The History of Oakland Bay ....................................................................................3
2. The Physical, Biological, and Human Attributes of the Oakland Bay......................7
2.1. Physical Attribute of Oakland Bay ..........................................................................8
2.2. Flushing Characteristics.........................................................................................10
2.3. Hydrology ..............................................................................................................12
2.4. Climate...................................................................................................................12
2.5. Vegetation ..............................................................................................................12
2.6. Land Use ................................................................................................................12
2.7. Biological Impact...................................................................................................13
3. The Potential Sources of Contamination in the Oakland Bay.................................13
3.1. Part One - History of High Levels of Contamination ............................................14
3.2. Water Quality Studies ............................................................................................14
3.3. Fecal Coliform20
3.4. Part Two - The Impact of Poor Water Quality on Marine Life in Oakland Bay ...21
3.5. Fish Habitat............................................................................................................23
3.6. Water Temperature ................................................................................................24
3.7. Dissolved Oxygen..................................................................................................25
3.8. Biochemical Oxygen Demand ...............................................................................26
3.9. Toxic Chemicals ....................................................................................................27
4. Shelton Waste Water Treatment Plan .......................................................................29
4.1. Sewage Treatment Plant and Process .....................................................................30
4.2. Collection System ...................................................................................................31
4.3. Stakeholders for Expanding the Shelton Waste Water Treatment Plant ................32
4.4. Port of Shelton ........................................................................................................33
4.5. Washington State Correction Center ......................................................................33
4.6. Washington State Patrol Academy .........................................................................34
4.7. Squaxin Tribe..........................................................................................................34
4.8. Shellfish Farmers ....................................................................................................35
4.9. Future Project for Shelton Waste Water Plan .........................................................36
5. Recommendations .......................................................................................................39
5.1. Increase Discharge During Summertime Months..................................................39
5.2. Demand Management ............................................................................................39
5.3. Reclamation ...........................................................................................................40
5.4. Ground Water Recharge ........................................................................................41
5.5. Conclusion .............................................................................................................42

iv

List of Tables
Table 1: Chum Escapement to Oakland Bay/Hammersley Inlet 1987 to 1998 ................23
Table 2: Regional System Wastewater Projections (2020)...............................................37

v

List of Figures
Figure 1: Oakland Bay & Hammersley Inlet........................................................................9
Figure 2: Oakland Bay Mussel Raft ...................................................................................11
Figure 3: Seasonal Impact on Oakland Bay’s Water Quality.............................................16
Figure 4: Fecal Coliform Trends in Oakland Bay ..............................................................17
Figure 5: Oakland Bay and Hammersley Inlet Study Area................................................19
Figure 6: Shelton Waste Water Treatment Plan .................................................................48

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Introduction
The Federal Clean Water Act was passed in 1972 to reduce water pollution inputs from
industrial stakeholders, sewage treatment plants and municipal sources (Title 33, Section
125). There have been significant improvements to our nation's waters because of this
act, but water quality problems remain due in part to point and nonpoint sources. Despite
this legislation, Oakland Bay in the city of Shelton WA is one of many estuaries still not
meeting Federal clean water standards.

Federal law requires states to identify sources of pollution in waters that fail to
meet state water quality standards and to develop plans to reduce the pollution. Water
cleanup plans are developed from total maximum daily load, TMDL, studies. The plans
establish limits on the amount of pollution that can be discharged to water bodies while
allowing state standards to be met. Oakland Bay is among 700 water bodies on
Washington State's current cleanup list. Since the passage of the Federal clean water act
three water quality studies show that water quality has not improved in the Oakland Bay
in the past 32 years,

The City of Shelton owns and operates a sewage treatment plant which discharges
treated waste water into Oakland Bay. As population in Shelton and surrounding Mason
counties grow, there will be an increase the amount of wastewater discharged at an
outfall that straddles two sanitary lines defining a shellfish closure zone in Oakland Bay.
Therefore, the condition of the current facility and the plan for a future sewage treatment
system is critical to local and regional water quality.

The Shelton existing waste water treatment plant is designed to serve the Shelton
area as shown in figure one. However, the city wants to expand its coverage to include
the Washington Correction Center (WCC), Washington State Patrol (WSP), and the Port
of Shelton. I focus on the existing poor water quality in the basin; the sources of the
problems, the issues with the existing sewage treatment plant, and suggestion for

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solutions. My conclusion summarizes five different options for managing the Shelton's
wastewater in the future.

The first chapter focuses on the history of Oakland Bay, Mason County and the
City of Shelton. The chapter concludes with demographic, social and economic
information on the human populations of Mason County including the indigenous First
Peoples.

Chapter two defines the boundaries of Oakland Bay and describes its flushing
characteristic. I then look at the legal framework of the Federal Clean Water Act and the
requirements that all states must meet in identifying water bodies that are water quality
limited or impaired. This chapter also addresses how land use affects water quality in the
Bay.

Chapter three addresses the sources of contamination in the Bay. Water
contamination is caused by both point and nonpoint sources. The main water quality
concerns are: fecal coliform, biochemical oxygen demand, toxic chemicals, and
temperature. I continue with a discussion of point and nonpoint sources which are
responsible for bacterial waterborne illnesses that affect fish habitat and shellfish
production. I then analyze changes associated with water quality and quantity which has a
significant impact on economic costs and benefits to landowners and to a wide range of
users.

In chapter four I identify and discuss the advocates of the regional expansion
project including the City of Shelton, Mason County, the Port of Shelton, the Washington
Correction center and the Washington State Patrol Academy, as well as the opponents
such as shellfish growers and the Squaxin Tribe.

Problems with the existing sewage treatment plant are discussed in chapter five.
My examination of the three different studies done on the sewage treatment plant is
followed with a discussion about the consequences of non compliance with National

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Pollution Discharge Elimination System Permits (NPDES), and by an evaluation of the
Regional System Wastewater Projections 2020 documents.

My last chapter is an analysis of the current paradigm and where we are going. It
also includes my recommendations for achieving the water quality goals as defined by
the 1972 Federal Clean Water Act.

1: The History of the Oakland Bay
Mason County, City of Shelton
Mason County is located in Western Washington at the southwest end of Puget
Sound. It is bordered to the north by Jefferson County, to the west and southwest by
Grays Harbor County and to the southeast by Thurston County. The populace residing in
and around the county live predominantly in twelve unincorporated townships, most of
which are platted along either Hood Canal or South Puget Sound inlets in west Mason
County. The County is also home to the Skokomish and Squaxin Island Indian tribes.
Most of the Skokomish and Squaxin live on or near the tribe's reservation which is
located at the southern end of Hood Canal. As of June 2007, seventeen percent of Mason
counties 54,600 residents live in Shelton, the county's only municipality and seat of
county government.

Shelton, meets the economic, social and recreational needs of its 9,250 residents,
in addition to the needs of 28,540 County residents. Shelton is the largest and most
important economical contributor for Mason County. Largely due to Oakland Bay's
geography and it’s proximity to the surrounding woodlands and water ways make it
critical for companies such as Simpson Timber Company and industries such as: Lumber,
Shellfish, evergreens, and Christmas tree.

Mason County and Shelton's history started when first settlers arrived in the South
Puget Sound region. They found a landscape dominated by expansive stands of old-

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growth coniferous trees. Douglas-fir, western hemlock, western red cedar, and Sitka
spruce were all present. These vast forests were the main attraction for the first settlers.

David Shelton (the namesake of the largest city in the basin) and his family
crossed the Great Plains with an ox team and covered wagon and arrived near Portland in
1847. Five years later, they moved to Olympia. The Shelton family moved to a donation
land claim of 640 acres at the present site of Shelton in 1853. They later added an
additional 171 acres from a homestead claim and purchase. By 1800, Shelton was a
member of the first legislative assembly of the Washington Territory.

During that period several mills were established. Michael Simmons opened the
first mill in Shelton near the mouth of Mill Creek. Because of large old growth (100 to
150 feet tall and 14 feet in diameter) were common in the early days, several other mills
soon followed. Joe Sherwood constructed one near the mouth of Sherwood Creek in 1854
(Deegan, 1960). Arkada’s mill (now Arcadia) was established in 1853 and Kamilche
(now Old Kamilche) in 1854.

At the time, Thurston County included what is today Mason County. Concerns
with the difficulty of traveling from the settlements in the northern portion of the county
to the county seat in Olympia led to the division of the county. In 1854, David Shelton
introduced a bill to split Thurston County thus creating Sa-heh-wamish or Sawamish
County. In 1864 the county was renamed Mason County in honor of Charles Mason, who
was first secretary of Washington Territory and often acting governor when Governor
Stevens was absent.

The Willey Mill was constructed in 1871 at the mouth of Johns Creek. In 1883,
William Kneeland built a small mill in the Shelton Valley and floated lumber down a
flume to tidewaters. Many of the trees had such a large swell at the base that loggers
employed “spring boards” to climb higher up the trunk for easier cutting. Notches were
cut with an axe and the springboard was wedged in, providing a platform for the logger to
stand on. An axe was used to cut an initial notch in the tree to control the direction of

4

falling, and then the trunk was cut with a saw (the “misery whip” of logging lore). Oxen
were used to drag the huge logs to water, limiting most of the early activity to within a
mile of water. As the logging industry grew and became more competitive new methods
were employed to increase efficiency.

In 1886, the Port Blakely Mill Company constructed a railroad that stretched from
Kamilche Point at the mouth of Little Skookum Inlet to Montesano. This railroad was
called the Blakely Road and was the shortest route from Puget Sound to Grays Harbor.
Sol Simpson later bought the Blakely railroad. Simpson also owned a railroad
(constructed in 1884) that began at Shelton and eventually terminated at Camp Grisdale
near the present site of Wynoochee Lake in the Olympic National Forest (Deegan, 1960).

In 1892, another railroad was constructed from Shelton up the Shelton Valley to
Grays Harbor. Logging along this railroad opened up land for agricultural production
(Deegan 1960). Much of the cutover lands were cleared of stumps and converted to
farmland. For example, in one year alone, farmers in the Shelton area purchased 40 tons
of stump blasting powder (Thomas, 1985).

While timber production was (and remains) the dominant industry in 1900, oyster
production was also a valuable local commodity. Oysters proved so popular that the beds
in Oyster Bay were depleted by 1887, less than ten years after harvest began. The
Oakland Bay was reseeded and production resumed. By 1902, 25,000 sacks of oysters per
year were harvested from the waters of Mason County (Deegan, 1960).

In 1923, Goldsborough Creek produced a sizable flood, inundating Shelton from
Seventh Street downstream to Oakland Bay. In response, the stream was channelized into
a straight channel with steeper banks. Land on both sides of the stream was then filled
and developed. In 1924, two mills were built on the Shelton waterfront. A wall of pilings
was driven across the bay front and the lower tidelands were dredged to fill about 30
acres on the landward side of the pilings.

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The two mills were located just south of the mouth of Goldsborough Creek. In
1926, the Rainier Pulp and Paper Company built a pulp mill next to the two lumber mills
already present on the Shelton waterfront. The pulp mill was dedicated to rayon
production. Rayon became so popular that the company name was later changed to
Rayonier, a combination of rayon and Rainier (Thomas, 1985). The pulp production
process produced a waste product called spent sulfite liquor.

Traditionally this waste was released into a nearby water body, but this plant was
located on a narrow tidal basin and people were concerned about protecting oyster
production. A pipeline five-mile long was built to the mouth of Mill Creek. Storage tanks
were constructed on-site so the waste liquor could be released only on outgoing tides. In
1930, oyster growers proved in the court that the sulfite waste liquor was harmful to
oysters. In response, a pipeline was built three-miles inland to dispose of the waste in
Goose Lake.

Eventually settling and evaporation ponds were constructed to contain the waste
and let it disperse. The company attempted to make use of the waste product by
concentrating it into thick syrup. By 1934, sulfite waste liquor was being used to settle
dust on roads as far away as New Jersey. Unfortunately, the venture didn't work out, so
the waste liquor was again pumped to the settling ponds in 1936.

Ten years later, it was found that the waste disposal ponds were seeping into
groundwater and the creek. To eliminate this problem the waste liquor was evaporated
into thick syrup and burned (Thomas, 1985), by 1951the Rayonier Company closed its
Shelton operation.

Goldsborough Creek again produced major floods in 1932 and 1935. The stream
channel was thoroughly cleaned and armored to protect the city and its residents. In the
mid-1940s, Simpson Timber Company built a bulkhead across the portion of Oakland
Bay north of Goldsborough Creek and dredged gravel from the tidelands to fill behind the
structure. A locomotive roundhouse and machine shop were then constructed on the fill.

6

In 1946, an additional building was constructed to lightly shred and cook
Douglas-fir waste. The fibers were then pressed into a thick sheet and dried to make
building tile and insulating board (Thomas, 1985).

In conclusion, the history of settlement and industrialization of the area
substantiates that human activities and the growth of industry had a significant impact,
including degradation of the shorelines and forests, on Mason County. Specifically as
timber production and timber processing byproducts of such activities impacted water
quality.

2: The Physical, Biological, and Human Attributes of the Oakland Bay
The Washington Administrative Code sets state water quality standards for
surface waters in the State of Washington. This standard was established for public
health, public enjoyment through recreation, and propagation and protection of fish,
shellfish, and wildlife. All surface waters in the state are classified according to their
beneficial uses. If state waters do not meet their intended uses, then they are classified as
limited or impaired and placed on Washington State's 303 (d) lists, as mandated by the
Clean Water Act to include all impaired waters in the state that fail to meet state water
quality standards (Chapter, 173-201).

Oakland Bay has significant water quality problems from past industrial uses and
current urban land uses and physical characteristics of the Bay. It is on Washington
State’s 303(d) lists and the near inner harbor of Oakland Bay is classified as class B.
Class B waters do not support salmonid spawning or contact recreation, but do support
limited fishing (Mason County public health, 2007).

Oakland bay is a prominent feature in the Washington State Department of
ecology and Mason County landscape. It is receiving water from two large river basins
and from the regional wastewater treatment plant. As discussed in this chapter, fresh
water inputs to Oakland Bay, particularly the waste water treatment plant and Shelton

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River and Goldsborough river system influence circulation and several water quality
parameters of the Bay

The Physical Attributes of Oakland Bay
Oakland Bay is a broad shallow estuary connected by the narrow channel of
Hammersley Inlet to outer Puget Sound. A volume of 7.9 x 107 m3 of water enters
Oakland Bay during a typical flood tide, which only has a volume of 8.7 x 107 m3
(Oakland Bay and Hammersley Inlet combined are about 14.8 x 107 m3).
Oakland Bay in Southern Puget Sound is about four miles long and three quarters of a
mile wide at its widest point. It flows into the northern end of Totten Inlet and
Hammersley Inlet.

A number of industries are situated in the inner harbor area of the Bay. Two main
streams flow into the inner harbor, Goldsborough and Shelton Creek. Goldsborough
Creek is the larger of the two and had an estimated yearly average flow of 350 cfs
(Department of Ecology, 2007).

Goldsborough Creek flows through Shelton, but is flanked on its south side by a
steep ravine and in its northern side by railroad tracks. Consequently, there is little
development close to its banks. However storm water from Shelton and the inner harbor
industrial area is discharged to the creek in a number of places. Goldsborough creek
flows into the center of the inner harbor shoreline (WRIA 14, 1998).

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Figure1: Oakland Bay & Hammersley Inlet.

Source: Oakland Bay figure map created with Arc GIS 9.2. Watershed Goldsborough
Sub-basin boundary is from Golder& Associates. Streams are from the Washington
Department of Natural Resource.

Shelton Creek originates in springs located northwest of Shelton proper, and had
an estimated flow of 16 cfs. A large tributary that originates northeast of Shelton

9

accounts for most of its volume. Shelton Creek flows through an older residential area in
Shelton and is often routed below ground. The water occasionally is used for lawn
irrigation. City and industrial storm water is also discharged to Shelton Creek. Shelton
Creek flows into Oakland Bay along the northern edge of the inner harbor (WRIA 14,
1998). Other tributaries are Johns Creek, Cranberry Creek, Deer Creek, Uncle Johns
Creek, Mill Creek, Malaney Creek, and Campbell Creek (Washington Department of
Ecology, 2003).

Flushing Characteristics
Oakland Bay is one of the more energetic estuaries in Puget Sound with two
meter tidal ranges and strong tidal current in the navigational channel. During the high
river flow portion of the year, the combination of energetic tidal mixing and fresh water
flushing of the tributary rivers prevent the accumulation of material in the system.
However, if there was an incident in the summer or early fall the lower river flow
conditions into Oakland Bay would cause any introduced material to be retained for a
long time; unfortunately, this is deemed by Department of Health the more likely time for
an upset event at the wastewater treatment plant (WWTP) to occur. Thus, in summer and
early fall, when fresh water flow is lowest, there is a higher retention of effluent in the
Bay. (Washington Department of Ecology, 2003).

A dye study, in April 2003, determined that Oakland Bay has high refluxing, low
flushing and a naturally high retention rate. In the experiment they injected dye at the
outfall of WWTP, to measure the Bay's dilution directly during this spring period (see
Figure. 2) at several fixed points. The result shows every ebb tide would remove 8% of
the dye from the east end of Hammersley Inlet, but every flood tide would return 92% of
it. The dilution factor was such that after 4 days, half of the dye still remained
(Department of Ecology, 2003).

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Figure 2: Oakland Bay Mussel Raft.

Oakland Bay Mussel Raft ISCO1
N 47o 13.820'
W 123o 03.020'

16

0.80

14

0.70

12

0.60

Tide, MLLW (ft)

0.50
8
0.40
6
0.30
4
0.20
2

Initial response
(transient, ~48h)

0

0.10

Steady-state response
(constant decay rate)

0.00

-2

-4
15-Apr

-0.10
16-Apr

17-Apr

18-Apr

19-Apr

20-Apr

21-Apr

22-Apr

Date/Time
Tide

Dye

Source: A time series of dye concentration in Oakland Bay (Washington
Department Ecology, 2003).This figure illustrates on 15 April the concentration of
effluent (bold) during the initial response phase of release is highly dependent on the
initial conditions of the tide (light). During the steady-state phase, the response exhibits
first- order (exponential) decay.

11

Dye Concentration (ppb)

10

Hydrology
Hydrology of the Oakland Bay system is typical of midsize estuaries, with high
flows in the late fall through late spring and low flows in the summer and early fall. The
surface waters in the Oakland Bay are classified as class A marine estuarine receiving
water in the vicinity of the outfall.

Climate
The region is characterized by the West Coast marine climate. Summers are
relatively dry and cool. Winters are mild, wet, and cloudy. Daily air temperatures
generally vary about 15ºF in the winter and 25 to 30ºF in the summer. Average
temperature is between 38ºF to 64ºF also, the annual precipitation is about 55 inches.

Rainfall is generally a light to moderate drizzle rather than brief heavy
downpours. Winds are generally from the southwest. Snowfall from 10 to 15 inches
occurs from November through April in the higher elevations of the Black Hills
(Thurston County Planning Department, 1989).

Vegetation
Early seral hardwood forests and mid seral conifer forests are the dominant land
covers, each occupying about 28% of Mason County. Saltwater covers about 13% of the
basin. Early seral conifer forests occupy about 9% of the basin, while mixed-early seral
forests cover about 5%. Late seral conifer forests and non-forested lands each cover about
1% of the basin (City of Shelton Land Capacity Analysis: Proposed Land Use Plan April
17, 2007; updated August 27, 2007).

Land Use
High density residential development occupies only 1.1% of the basin, primarily
in the Shelton area (City of Shelton Land Capacity Analysis: Proposed Land Use Plan
April 17, 2007; updated August 27, 2007). In 2007, the population of Mason County was
54,600 people, 9,250 of which lived in the Shelton area (Jones & Stokes 2007). Road
density for the entire water resource inventory area (WRIA) is 4.6 miles per square mile

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(Washington State Conservation Commission and Northwest Indian Fisheries
Commission, 2002).

Biological Impact
The Bay supports different types of fish that are affected by degraded water
quality for a number of reasons. According to WRIA 14 study, the rate of flow drops and
the bay tributaries rivers moves more slowly and becomes less turbulent. Oxygen enters
the Bay more slowly and mixes poorly with deeper waters. The surface water begins to
warm, which limits the amount of oxygen entering the water.

Low summer flows are a natural condition for most of the bays along the Puget
Sound. But the history of poor logging practices in the past and new developments along
Oakland Bay and its tributaries led increasing discharge of point and nonpoint into the
Bay. These pollutions along with summer conditions increase Water temperatures and
decreased dissolved oxygen for the marines' life in the Bay (Beaker et al. 1995).

In summary, long-standing water quality problems in Oakland Bay exist due to
many different issues; one of the most important being the physical characteristics of the
Bay. Seasonal changes in rainfall and stream flow further impact water quality. Due to
the poor flushing characteristics of the Bay, these pollutants - including high level of
fecal coliform(Stephanie Kenny,2007) remain in the waters for lengthy period effecting
marine conditions, thus reinforcing the State’s class B classification and limitation of
human contact of the Bay’s compromised water.

3: The Potential Sources of Contamination in the Oakland Bay
By reviewing water quality studies from 1980- 2007, this chapter examines the
levels and sources of contaminants in Oakland Bay to show why water quality has
remained poor despite water quality laws. Both point and nonpoint sources are
contributing to the poor water quality in the basin. The contaminants of concern are fecal
coliform bacteria, water temperature, dissolved oxygen, biochemical oxygen demand

13

chlorine residual, ammonia, nitrate and total suspended solid. This chapter is divided into
two parts: Part One focuses on reviews the history of high level fecal coliform
contamination in Bay and also identifies the major sources of pollutant. Part two will
discuss how poor water quality will impact on marine’s life in Oakland Bay.

Part One- History of High Levels of Contamination
As stated in Chapter two, flushing characteristics of Oakland Bay causes any
material that enter the waters to remain in the Bay for more than twenty days
(Department of Ecology Dye Study 2003). There are three major sources of
contamination in the Bay: Simpson Timber Company, the waste water treatment plant
and nonpoint discharge, all impacting water quality in the creeks and the inner bay. For
this reason Oakland Bay suffers from high level of contaminations.

Water Quality Studies
Three major water quality studies funded by the Washington State Department of
Ecology serve as benchmark indicators of poor water quality in Oakland Bay. The first
study was in 1980, by the Department of Social and Health Services (DSHS). At that
time, DSHS was responsible for evaluating the sanitary quality of commercial shellfish
growing waters in Washington State. The evaluation and approval was based on periodic
bacteriological studies of the water. DSHS conducted an intensive water quality survey in
Oakland Bay during December 1986 and January 1987 as part of their routine monitoring
program. Survey results indicated a bacterial contamination problem, and the Bay was
reclassified as "Restricted" (DSHS, 1987). In February 1987, the Department of Ecology
began to investigate sources of bacteria to the Bay. The investigation centered on the
inner harbor where bacteria levels were highest (DSHS, 1987). The primary objectives of
the study were to determine the significant sources of fecal coliform bacteria to the inner
harbor and to conclude whether the high bacteria concentrations were related to wet
weather. The Department of Ecology identified three major sources of pollutants, which
discharged into the bay.

14

•

ITT Rayonier (removed from Shelton in 1950)

•

The Shelton Waste Water Plant

•

Simpson Timber Company

The relative contribution of these sources varies with season. ITT Rayonier was
the largest loading source except during periods of high runoff when Shelton storm water
was estimated to dominate. Its pulp production process produced a waste product called
spent sulfite liquor. This substance is the liquid waste resulting from the manufacture of
cellulose pulp from wood and contains organic matter in the sulfate and chemicals in the
liquor. Discharging sulfate liquor in water will change the balance of oxygen in the water
by decreasing oxygen and increasing carbon dioxide. Low dissolved oxygen will
suffocate the marine animals and chemical waste will poison the shellfish and oysters in
nearby discharge location. In effects to offset discharge, ITT Rayonier tried to recycle the
sulfite waste liquor and use it for settling dust on roads. This remedy proved too
expensive, therefore contributing to the closure of its Shelton facility in 1950 (Thomas,
1990). After identifying ITT Rayonier, the Department of Ecology listed Shelton storm
water discharge as another significant source of contamination during wet weather. It
appeared to account for only a small portion of the loading during dry weather. During
the critical wet weather period it became the major source of bacteria in the Bay (figure
3).

15

Figure 3: Point and Nonpoint Sources of Pollutant from beginning in the Oakland Bay

Source: Water Quality Survey of Oakland Bay by Department of Health (DSHS 1986).
Comparison of Contributions from Bacteria Loading Source during Different Weather
Conditions.
16

The second study funded by Washington State Department of Health (DOH) was
to protect the health of shellfish consumers from fecal contamination. In 1991, DOH
selected Oakland Bay areas for long term Puget Sound Ambient Monitoring Program
(PSAMP). In this study, DOH used a systematic random sampling strategy to study three
different stations in Oakland Bay from 1991 through 1998. The result of seven years
ofsampling indicated the highest fecal coliform levels occurred near the discharge point
of the Shelton Sewage Treatment Plant (Tim Determan, Office of Shellfish Programs,
Washington State Department of Health, 2001). This study placed both Hammersley
Inlet and Oakland Bay to be listed on the 303(d) list of impaired and threatened water
bodies (Washington Sate Department of Health, 1991). Figure 4 illustrates the level of
fecal coliform pollution during seven years of study in three different locations in
Oakland Bay. The highest contamination of fecal coliform is at section three (station 5)
which is in Hammersley Inlet near a waste water plant discharge.
Figure 4: Fecal coliform trends in Oakland

Source: Office of Shellfish Program, Washington State Department of Health.
The graph illustrates the highest contamination of fecal coliform is in Hammersley Inlet.
17

The third study was initiated by the City of Shelton to possibly expand its Waste
Water Treatment Plant (WWTP) output without compromising the closure zones for
shellfish harvest areas (sanitary lines). Before shellfish can be grown or harvested for
commercial sale, the area must be assessed to determine that shellfish can be safely
grown or harvested. The boundaries of a wild harvest or aquaculture area are established
by considering the natural topography, sources of natural contamination, industrial
developments or human habitation, and potential for additional growing or harvesting
sites within the area. These sanitary lines are maintained by the Washington State
Department of Health (DOH) and are critical to many commercial and tribal aquaculture
interests in the area (Department of Ecology, 2004).

In April 2003, Department of Ecology determined the flushing characteristics of
Oakland Bay by conducting Rhodomine dye release study (fig.2). In this model, fecal
coliform bacteria were interchangeable with dye and injected at the critical areas of the
Waste Water Treatment Plant. As a result, they were able to measure dye dilution directly
at several fix points for a period of two months. The study indicated 46,300 fecal
coliform bacteria units per 100/ml would satisfactorily dilute to the Class A water quality
standard of (fig 5). 14 fcb crossing the sanitary lines when discharge is set at 2.6 million
gallons per day. But any additional discharge rate clearly effect Oakland Bay sanitary
lines (Department of Ecology, 2004).
.

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Figure 5: The Oakland Bay – Hammersley Inlet study area.

Source: Department of Ecology 2004.
The outfall location is indicated with a circle, the sanitary lines (Oakland Bay and
Hammersley Inlet) demarking the closure zones for shellfish harvesting are indicated as
red lines on either side of the outfall.

19

Fecal Coliform
The use of fecal-coliform (FC) bacteria as a standard was adopted in 1979 (EPA,
1979). This group of bacteria was thought to relate more directly to pathogens associated
with warm blooded animals than a measure of total coliform bacteria which was the
standard previously in use. The fecal coliform group is primarily composed of
Escherichia coli and Klebsiella. The Escherichia coli are normally an intestinal organism
associated with human fecal waste.

The presence of fecal coliform bacteria in water is commonly used for measuring
the bacteriological pollution of water. Coliform bacteria are found in great numbers in the
feces of human and other mammals. Most coliform bacteria are not harmful but the
presence of large numbers of these bacteria in water indicates contamination by untreated
feces.

As stated in chapter two, the surface waters in Oakland Bay in the vicinity of the
outfall are classified as a Class A marine estuarine. The Class A water standard for fecal
coliform is 100 colonies per 100ml (milliliters) of water. It means when water samples
are collected, not more then 10 percent of the samples collected can exceed a mean value
of 200 colonies per 100ml in Class A water (Pickett, 1994).

Three major studies and numerous sampling indicated that Oakland Bay and some
of its tributaries (see pages 8-10) have failed to meet water quality standards. Data from
Mason County Health Department recorded fecal counts ranging 30 to 220 fecal coliform
per 100 ml in Oakland Bay. High level of fecal coliform bacteria caused both
Hammersley Inlet and Oakland Bay to be listed on the 303(d) list of impaired and
threaten shellfish water bodies (Washington State Department of Ecology 2007).

Despite wastewater plant impact, there are other sources of fecal coliform
discharge in Oakland Bay. Both city and industrial stormwater sources impact water
quality in the creeks and the inner bay. This is supported by the fact that bacteria
concentrations increase with distance downstream and with the rain events. It is expected

20

these impacts would be more significant during a typical wet weather period. The 1988
study identified Shelton Creek and Goldsborough Creek as not meeting Class A water
quality standards, and both are important fecal coliform bacteria loading sources to the
inner harbor (Department of Ecology, 1988). Shelton Creek appeared to have higher
concentrations and more affected by rain events than Goldsborough Creek.

Shelton Creek and several tributaries of Oakland Bay were placed on the federal
303(d) list (1996, 1998, and proposed 2002/2004) for not meeting state water quality
standard for fecal coliform bacteria (Department of Ecology, October 19, 2005).
Therefore, in accordance with the Federal Clean Water Act, total daily maximum loads
(TMDLs) for fecal coliform bacteria were studied by Department of Ecology. The field
work identified effluent from leaking septic tanks as a significant contributor of bacteria
into Shelton Creek (Department of Ecology, 2006).

Part two- The Impact of Poor Water Quality on Marine Life in Oakland Bay
Oakland Bay is a well-developed estuary characterized by estuarine emergent
wetlands with deep pools that provide quality habitat for juvenile salmonids. About 74
acres of this area are protected within a Natural Area Preserve managed by the
Washington Department of Natural Resources (Taylor et al. 1999).

The Oakland Bay and its tributaries are important for fish such as Chinook,
Coho, Chum, Steelhead, Cutthroat Trout and different kinds of shellfish. In 1998 the state
legislative session produced a number of bills aimed at salmon recovery. Engrossed
Substitute House Bill (ESHB) 2496 (later codified to RCW 77) was a key piece of the
1998 Legislature’s salmon recovery effort, with the focus directed at salmon habitat
issues. Since 1998, several studies indicated poor water quality impacted marine life in
Oakland Bay and its tributaries.

In 2000 the Squaxin Tribe conducted numerous samplings throughout Puget
Sound. They found wild stocks of anadromous fish species are in the worst condition in
the Oakland Bay tributaries especially in Goldsborough and Shelton. Other rivers which

21

empty into Oakland Bay have been documented to have problems with low dissolved
oxygen and high temperature level in late summer and early fall (Squaxin Island Tribe
2002, unpublished work).

In 2002 North Thurston Conservation District conducted a study on Samonid
Habitat Limiting Factors in Water Resource Inventory Area 14, Kennedy-Goldsborough
Basin. This report describes the inventory of different types of salmonid in the KennedyGoldsborough and Shelton Creek Basin (Michael Kuttel, Washington State Conservation
Commission. November 2002). Table 1 illustrates the decline of salmon in Goldsborough
and Shelton creek.

In 2005 South Puget Sound Three-Year Freshwater and Near shore
Implementation Priorities conducted a study about Samonid Habitat Limiting Factors
Water Resource Inventory Area 13, 14 and 15. The region encompasses the extreme
southwest terminus of Puget Sound, including three quarters of a mile of the Malaney
Creek, forested Oakland Bay estuary, eighty acres of forest and meadow, and two
thousand feet of forested marine shoreline on Oakland Bay. This report describes the
salmon populations have been decreasing in this region, and identify specific recovery
actions for this specific geographic area.

22

Table 1: Chum Escapement to Oakland Bay/Hammersley Intel 1987 to 1998.

Year

Mill

Goldsboro

Shelton

Johns

Cranberry

Deer

Malaney

Uncle

Camp

Creek

ugh Creek

Creek

Creek

Creek

Creek

Creek

John

bell

Creek

Creek

1987

5,383

13,741

1431 7,800

4,345

629

42

0

2

1988

4,391

16,132

1,100 9,068

6,578 2,821

3

2

NS

1989

840

5,679

5,802 1,346

11

1

NS

1990

6,717

1,502

913 9,031

6,125 1,790

36

NS

NS

1991

2,200

2,708

1,085 7,823

2,296 1,091

23

NS

NS

4,490 2,512

11

NS

NS

1992

1993

1994
1995
1996

16,46
9
16,37
3
15,43
7
1,233
29,36
9

2,263

1,242

28

15,17
6

10,06
6

4,872

749 9,242

5,693 3,750

0

6

NS

1,302

101 6,282

5,609 2,544

NS

NS

NS

2,378

100 4,309

3,401 1,421

0

NS

NS

546

2 8,996

2,394 2,746

NS

NS

NS

5,115 1,036

0

NS

42

NS

NS

NS

NS

4,713 1,971

14

2

22

1997

5,811

393

44 3,077

1998

NS

NS

NS

Mean

9,475

4,683

12

527 7,574

NS

Data source: Taylor et al.2000. Note: NS = No survey data.
The highlighted numbers illustrates the enormous decline in the number of salmon.

Fish Habitat
Fish and shellfish are affected by a number of factors, which include low
dissolved oxygen, turbidity, and high water temperatures. Fish require a minimum
dissolved oxygen concentration of 5 mg/L (also read as [ppm] or parts per million) for
survival (Bjornn and Reiser, 1991). Washington State water quality standards require a
23

value of 8 mg/L of DO for protection of fish resources in Class A waters (WAC 173201A). Increasing turbidity, from flood event erode stream bank and smothers eggs.. Fish
require cold and clean water for optimal survival. Water temperature requirements vary
depending upon salmonid life stage and species, but in general, a range of 50-57°F (1014°C) is preferred. Long-term exposure to temperatures greater than 75°F (24°C) is fatal
to salmonid (Bjornn and Reiser, 1991). Therefore canopy loss over large areas can affect
water temperature, and negatively effect salmon. Total suspended solids (TSS) refer to
the weight of particles including soil, and algae suspended in a given volume of water
(Michaud, 1991) which will effect fish in different ways. To protect salmon species the
U.S. Fish and Wildlife Service recommends a maximum TSS level of 80 mg/L (Fish and
Wildlife Service, 1995). Other water quality parameters including pH, the concentration
of hydrogen ions in water, and chemical pollution can also degrade habitat quality.

Water Temperature
Warmer water temperatures affect dissolved oxygen levels by decreasing the
solubility of oxygen in the water. Warmer water causes aquatic organisms to increase
their respiration rates, which in turn consumes more oxygen. Washington state Class A
standards for water temperature in general should not exceed 18.0° C and should support
fish migration, rearing, and spawning of cold water fish. When natural conditions in a
water body exceed these limits, no temperature increases can be allowed that would raise
the receiving waters by more that 0.3º C (Pickett, 1994). Increasing temperature in
Oakland Bay is caused by a number of different sources and conditions, such as irrigation
return flow, exposed stream segments due to logging practices, loss of canopy cover to
the water body, inputs from industrial outfalls, and slow moving water.

As a point source of pollution, the Shelton Sewage Treatment Plant is one of the
given reasons for increased water temperature in Oakland Bay. According to the Plant's
National Pollutant Discharge Elimination System (NPDES) the effluent temperature from
the plant is 20ºC which is more than water Quality standards. In a whole picture the
discharge of 2.6(mgd) to 10(mgd) in the wet weather event will increase the Bay's
temperature more than 2ºC.

24

Agricultural and urban run off are major source of non-point pollution in Oakland
Bay tributaries. According to the WRIA 14 the summer water temperatures of many
rivers in the Oakland Bay basin approached or exceeded temperature limits for Class A
standard. For example Shelton Creek water temperature during August was ranging from
18.8°C to 21.5°C (65.8°F to 70.7°F). Also daily maximum water temperatures at
Goldsborough Creek exceeded 18.0°C nearly every day from July through September in
2000, 2001, 2004, and 2005; often reaching 22°C to 24°C (Squaxin Island Tribe 2005).

Dissolve Oxygen
A good indicator of water quality is the dissolved oxygen content needed to
support aquatic life. This is the amount of oxygen gas dissolved in a given quantity of
water at a given water temperature and atmospheric pressure.

When surface water is loaded with biodegradable wastes, there are explosions of
aerobic decomposers that reduce the supply of dissolved oxygen so that fish and shellfish
die of suffocation. Nutrient rich waters with high nitrogen levels also lead to elimination
of sensitive species, which are the least able to cope with adverse conditions. Sensitive
species such as sport fish decline because they cannot tolerate low dissolved oxygen
levels (Pickett, 1994).

Class A standards for dissolved oxygen should exceed 8.0 mg/l (milligram per
liter). Oakland Bay as a whole receives nitrogen from a variety of sources including
septic systems, sewage facilities, atmospheric inputs, and fertilizers used on lawns, golf
courses, and agricultural areas. The nitrogen from these sources is conveyed to the Bay
by effluent outfalls, streams and rivers, overland runoff, and groundwater that drains
from the land (Kuttel, 2002).

Department of Ecology identified sewage treatment facilities, together with the
Simpson Company, are the principal source of nitrogen entering the Bay (South Puget
Sound Three-Year Freshwater and Near shore Implementation Priorities, 2005).
Although studies conducted by the Department of Ecology have shown Oakland Bay's

25

dissolved oxygen levels currently comply with water quality standards. The population in
this area continues to increase, in turn the wastewater production from residential,
commercial, and industrial sources will increase too. These increases will raise Oakland
Bay’s nitrogen level lower dissolved oxygen levels.
For the most part, detrimental effects from the discharges of sewage treatment
facilities are localized near the sites of discharge. These effects are most acute when
the discharge occurs in poorly flushed areas.
Septic systems are also a significant source of nitrogen for Oakland Bay. Septic
systems release large amounts of nitrogen as ammonia, which is rapidly transformed to
nitrate in the presence of oxygen in groundwater. In general, nitrate in groundwater flows
great distances without attenuation (or dilution) and with little chance of uptake by plants.
In rural agricultural areas more nitrogen may be contributed by fertilizers and animal
wastes than by septic systems (Washington State Department of Ecology, 1999).

Biochemical Oxygen Demand
Microorganisms such as bacteria are responsible for decomposing organic
waste. When organic matter such as dead plants, leaves, grass clippings, manure, sewage,
or even food waste is present in a water supply, the bacteria will begin the process of
breaking down this waste. When this happens, much of the available dissolved oxygen is
consumed by aerobic bacteria, robbing other aquatic organisms of the oxygen they need
to live.

Biological Oxygen Demand (BOD) is a measure of the oxygen used by
microorganisms to decompose this waste. Nitrates and phosphates in a body of water
contribute to high BOD levels. Nitrates and phosphates are plant nutrients and can cause
plants and algae to grow quickly. When plants grow quickly, they also die quickly. This
contributes to higher levels of organic waste in the water, which is then processed by
bacteria, resulting in a high BOD level. When BOD levels are high, dissolved oxygen
levels decrease because the oxygen available in the water is being consumed by bacteria.

26

Since less dissolved oxygen is available in the water, fish and other aquatic organisms
may not survive.

A Class A standard for BOD is 30 mg/l per month. But according to the Waste
Water Treatment Plants data monthly average BOD in Oakland Bay varies in from 30
mg/l to 328 mg/l, and during an upset event it exceeded up to 450 mg/l. The Hammersley
Inlet’s BOD showed to be very vulnerable because of slow moving currents, which retard
air transfer and prevent vertical mixing (Fact Sheet for NPDES Permit, 2001).
Toxic Chemicals
The Water Pollution Control Federation's Chlorine of Wastewater (1976) states
that a properly designed and maintained wastewater treatment plant can achieve adequate
disinfection if a 0.5 mg/l chlorine residual is maintained after fifteen minutes contact
time. Thereby, state and federal governments regulate the discharges of sewage treatment
facilities through permits granted under the National Pollutant Discharge Elimination
System. If an industry tied into the system is known to produce toxic materials, or if there
has been contaminant problem identified in the past, the permit may also contain
chemical-specific limits, so that special attention can be focused on the contaminants of
concern.

The main source of toxic pollution in the Oakland Bay is the Shelton Sewage
Treatment Plant. The facility use chlorine to disinfect the wastewater. At present the
average number of bacteria in treated wastewater discharged into the bay is around
5,000 per 100 ml. it is impossible to consistently reduce the number of bacteria below an
average 5000 per 100 ml with only Using natural technique. Therefore, the facility uses
chlorine to disinfect the waste water (Department of Ecology, 2002).

Oakland Bay and its tributaries are classified on Washington State's 303(d) list
because, of past contamination and a high level of chlorine use by the Wastewater
Treatment Plant (Department of Ecology, 2007). According to treatment plant data, the
corresponding weekly average of chlorine usage is 0.75 mg/l. This exceeds water quality
limits by 0.25 mg/l.

27

Although chlorine is an efficient and cost-effective means of disinfection, there is
concern that chlorine residuals in wastewater discharged into the Oakland Bay may have
detrimental effects on the long-term viability of the ecosystem and a negative impact on
marine life and human health. According to the WIRA, the populations of salmon and
some varieties of shellfish have declined by one-fifth over the last decade in Oakland
Bay’s tributaries (Konovsky 2002, personal communication).

Research shows decrease of salmon stocks and shellfish is attributed to a long
banned class of industrials chemicals and toxins which had been use for decades by
timber companies, mills and pulp production. These chemical have penetrated into the
sediment at the base of the Bay and unfortunately do not dissipate and will stay for ever.
Tribes along with Department of Ecology are trying to figure out ways to remove these
chemicals from the food chain. Scientists believe that tiny animals that live in the
sediment are first in the food chain to be contaminated. They are then eaten by larger
animals. At each step, the eater takes in flesh contaminated with toxins. Wastes are
excreted, but the toxins remain. It seems once incorporated into the food chain, is
impossible to remove the toxin (Washington State Department of Fish and wildlife,
2006).

In summary, according to three independent studies conducted by Washington
State Department of Ecology, DSHS, and DOH Oakland Bay suffers from high level of
fecal coliform bacteria and toxics. The studies indicate a history of contamination in the
Oakland Bay. Stemming from the industrialization of timber industry and the average
growing demands of the sewage treatment plant are increasing contamination of nonpoint discharge into the creeks and the inner Bay.

Data from DSHS in 1988 indicated high concentration of fecal coliform bacteria
close to the Simpson Timber Company. In addition the facility had been discharging
industrial runoff at many points of the inner harbor, Goldsborough and Shelton Creeks
without any regulations. 2002, Department of Ecology fined Simpson Timber Company
for $16,000 because 71 gallons of soluble lube oil spilled into Oakland Bay. The plant

28

has had 13 previous spills in the past six years, four of which involved oil that spilled
inside their building and then into the bay (Washington State Department of Ecology in
April, 2002).

The Shelton sewage treatment facility has been a significant source of pollution in
Oakland Bay. Nitrogen from this facility impacts the receiving waters, especially in the
areas of slow moving currents such as Hammersley inlet. All three studies identified the
Shelton treatment facility as the top source of fecal coliform contamination in the Bay.
As population in Mason County grows, there will be a need to expand the treatment
capacity; however, as it stands, the existing facility cannot sufficiently treat more without
increasing its discharge of contaminates into Oakland Bay.

In the next chapter I will discuss problems with the existing treatment plant and
the consequences of non compliance with Federal Water Pollution Control Act. I will
also discuss issues concerning the proposal of extending coverage to additional areas
without updating the current treatment system. Advocates and opponents of this regional
project will be highlighted along with their direct concerns.

4: Shelton Waste Water Treatment Plan
All sewage facilities cause, or have the potential to cause, local declines in water
quality. In many instances, sewage treatment facilities have caused regional declines in
the health of many coastal ecosystems. The type of treatment provided, the location of the
discharge, and the types of wastes collected by sewers are critically important to the
impacts made on these costal areas.

The Federal Water Pollution Control Act of 1972 required that, by 1983 (later
adjusted to 1988), sewage treatment facilities that discharge to surface waters must
provide a secondary treatment through biological processes that remove a minimum of
85% of the organic matter.

29

The sewage treatment facility plan discharge as point sources under the National
Pollution Discharge Elimination System permit (NPDES) process. Section 402 of the
Federal Clean Water Act created a permit process where discharging is allowed by the
State of Washington and Environmental Protection Agency (Findley& Farber, 1996).

Sewage treatment Plant and Process
Sewage treatment technology exists in three incrementally more sophisticated
forms. Primary treatment simply removes solid materials form wastewater by letting
them settle. Solids settle with little of no mechanical or chemical processing. Secondary
treatment is a biological process in which bacteria are injected into the waste water.
These microorganisms consume the high nutrient solids in the sewage, producing slurrylike sludge with a low solid content. Finally, the tertiary treatment is a chemical process
in which lime, organic polymers of aluminum and iron salts are added to the sewage to
remove unwanted nutrients such as nitrates and phosphates (Environmental Protection
Agency, 1984: 3).

The City of Shelton owns and operates secondary treatment plant which is located
in the southern part of Hammersley Inlet that utilizes an activated sludge process. This
plant's preliminary treatment consists of two processes, scum removal and pumping, and
aerated grit removal and dewatering. The treatment process consists of two 1.1 million
gallon oxidation ditches. Wastewater flows from the oxidation ditches by gravity to the
secondary clarifiers which feed, peripheral overflow units. Scum is then removed by
surface scum skimmers. The effluent then overflows the peripheral weirs to a 16-inch
pipe into the chlorine contact channel.

The majority of the Shelton treatment plant was built in 1978 and has not received
any significant upgrades or expansions since that time. The City of Shelton experiences
excessive infiltration and inflow (I&I) of extraneous water into the sewers during periods
of high rainfalls. The I&I flows consume the remaining capacity at the treatment plant to
meet the water quality requirements for the treatment process (Cosmopolitan Engineering
Group, 2007). ------

30

Collection System
The waste water treatment plant is categorized as a major facility, with a design
flow of 4.02 million gallons a day (mgd) for the maximum month. Existing wastewater
collection system encompasses the majority of the current city limits. The system consist
of 4 inch through 24 inch diameter gravity sewers, three small cul-de-sac pump stations
and one main pump station and a 1.5 mile force main. According to the NPDES permit
issued on October 2, 2002 many of the treatment units are approaching the end of their
useful life. Most of the existing piping system is very old, many of the pipes in the
downtown area were built in the 1910’s; many sewer pipes in the southern part of town
were built in the 1940’s. Therefore the collection system is in generally poor condition
having experienced excessive (I&I) within the last several years. Most of I&I is
groundwater which leaks into the collection system through cracks in the underground
pipes. Other sources of I&I include surface water entering the collection system from
cracks in the pipes and drains into manholes around the city.

On December 30, 1998 the Department of Ecology issued Administrative Order
#DE 97WQ-S182 to the city to complete sewer replacement in Basin 1, Basin 2 and
Basin 3. Basin 1 was completed in 1998 and has had a positive effect on loads levels.
Basin 2 and 3 has not been completed yet, and are estimated to cost of $25,000,000 (City
of Shelton I/I Facility Plan Updated, 1997, EES). Since the city was behind schedule on
the order the Department of Ecology plans to issue a new order in conjunction with the
issuance of its last permit (City of Shelton 1997 I/I Facility Plan Update).

In 2006 City of Shelton submitted a loan application for $1,000,000 to design the
Basin 5 Sewer Rehabilitation Project from the Department of Ecology’s and State
revolving Fund (SRF). In April of 2007, the City was notified that they would receive
the resulted funding, with completion of the necessary paperwork. The money should be
utilized to pay for the design of this project. Basin 2 and 3 still requires major repairs to
the administrative order from DOE to remove the I&I from the sewer systems ( Roth Hill
Engineering partners, LLC 2007).The treatment plant has reached the capacity of its solid
waste treatment system. The City of Shelton has recently received a loan in 2002 for

31

expanding the existing solids handling capacity of their wastewater treatment facility.
The Regional Task Force has chosen to pursue Class "A" biosolids treatment facility for
the Regional System, which may also include sludge generated at Mason County
operated treatment plants. Class "A" biosolids will use for variety of agricultural
purposes (John Delton, 2002).

Stakeholders for Expanding Coverage the Shelton Waste Water Treatment Plant
As the population in the Mason County and Shelton grows, there will be a need to
expand the capacity of existing facilities or to create new ones. The existing treatment
plant is design to ultimately serve the grid area shown on figure 7.
Figure 7: Shelton Waste Water Treatment Plant

Source: Ron Robinson and Mike Price (Washington State Department of Ecology).
Captain: primary map of the waste water treatment plant.

32

With the anticipated growth, advocates propose to expand the sewer system area,
to cover the Washington Correction Center (WCC), Washington State Patrol (WSP) and
the Port of the Shelton. The advocates for the expansion project include the City of
Shelton, Mason County, the Port of Shelton, the Washington Correction Center and the
Washington State Patrol Academy, while the opponents are shellfish growers and
Squaxin Tribe.

The following agencies have participated in the planning process discussions:
•

Washington State Department of Health (DOH)

•

Washington State Department of Ecology (Water Resources and Water Quality)

•

Washington State Department of Community Development

•

City of Shelton, staff and elected officials

•

Port of Shelton, staff and elected officials

•

Washington State Department of Corrections

•

Washington State Patrol

•

Mason County Planning, Utilities, and economic Development Council, and
elected officials

Port of Shelton
Established June 4, 1957, the Port of Shelton district is a municipality of the State
of Washington. Chartered for economic development, the Port of Shelton has 9600
registered voters and almost 15,000 people living and working in the port district. In 1988
city invested $1,000,000 to improve its two premier properties and attract long-term
commercial/ industrial developments. Currently the city has problems with state building
permit moratoriums due to an inadequate sewer system. The Port uses septic tank and
drain field systems. These systems are very limited in expansion capability, and are
unable to remove nitrates -which eventually infiltrate into the water table.

Washington State Correction Center
The Washington Correction Center (WCC) operates a tertiary wastewater
treatment plant. Components of the existing facility are over 30 years old. The effluent

33

disposal spray fields were designed as an interim measure until connection to a regional
sewer system was available. The disposal method requires a very high level of treatment,
and a correspondingly high level of monitoring and operation certification. Due to
growing requirements for operating and maintaining a wastewater treatment system, it is
likely to be more cost effective for WCC in the future to operate their own treatment
facility (Gray & Osborn, Inc, 2001).

Washington State Patrol Academy
Washington State Patrol Academy located on the Dayton-Airport Road north of
Shelton, this facility sits on 190 acres of ground adjacent to Sanderson Airport. The
academy has classroom accommodations for 150 students and dormitory space for 68
students. The complex contains driving courses with vehicle skid pan, a firing range, a
gymnasium, water training tank, staff office and conference room it’s completion was
completed in 1989. The academy also operates septic tank and drain field systems. These
systems are also very limited in expansion capability, and are unable to remove nitrates,
which eventually infiltrate into the water table.

Squaxin Tribe
Prior to the arrival of European settlers, several tribes of Native Americans were
the principal inhabitants of South Puget Sound. The Squi-Aitl lived along Eld Inlet, the
Sawamish/T'Peeksin lived along Totten Inlet, the Sa-Heh-Wa-Mish lived along
Hammersley Inlet, and the Squaxin lived along Case Inlet. The waters of South Puget
Sound were very important to their cultures. Salmon and shellfish provided food, while
the numerous inlets provided travel routes via canoe. The Squaxin tribes were maritime
people who have lived and prospered along the shores of Oakland Bay for thousands of
years. Squaxin leaders signed the Medicine Creek Treaty with the U.S. Government in
1854, reserving the right to hunt, gather and fish at all usual and accustomed places,
including Oakland Bay. As a result, Tribal scientists now manage natural resources in
Oakland Bay with the State of Washington. The Federal government also maintains a
trust responsibility for Tribal interests in Oakland Bay (Squaxin Island Tribe, 2007).
Therefore, fishing has remained important to them economically and culturally. The

34

tribes are also actively engaged in shellfish harvesting in various parts of South Puget
Sound.

Shellfish Farmers
Shellfish are an integral part of the Mason County history and economy. The rich
waters of southern Puget Sound and Hood Canal have produced shellfish for centuries.
First used by local Indian tribes as an essential part of their diet, the early pioneers found
shellfish to be a highly desirable commodity.

Currently, Oakland Bay is one of the most productive commercial shellfish
growing areas in the country. Much of the nation’s manila clam harvest is grown there, as
well as high-value oysters. Approximately three million pounds of clams and 1.8 million
pounds of oysters are harvested yearly. There are 21 shellfish growers in Oakland Bay in
addition to the Squaxin Island Tribe. Some of the areas of public and private beaches
support recreational shellfish harvesting. Approximately 2000 recreational harvesting
licenses are obtained for the area each year (Environmental Health, Mason County Public
Health, 2007).

The Washington State Dept. of Health is responsible for establishing shellfish
closure zones for all existing and proposed outfalls anticipated impact the state’s shellfish
beds. Therefore any extra pollution will cause extended shellfish bed closures. The
shellfish as filter feeders may actually benefit from the nutrients in fecal matter washed
into the sea. However, people who consume the shellfish are adversely affected. Public
health agencies will declare shellfish, from such polluted waters, unsuitable for collection
and sale. Shellfish growers must wait for the appropriate government agency to
determine the source of the fecal contamination and take action to stem the flow. Weeks,
months, and years may pass before a shellfish beach is recertified as safe. In the
meantime, growers must find other locations for raising shellfish or seek supplemental
sources of income until conditions change.

35

A comprehensive study recently conducted by the Washington State Health
Department, the Federal Food and Drug Administration, Washington Department of
Ecology, and the City of Shelton shows that sufficient mixing and dilution of the existing
discharges from the Shelton Sewage Treatment Plant occurs in Hammersley Inlet to meet
an “approved” classification in this specific area. The scientific study was also supported
in part by the shellfish industry in Oakland Bay. The only approved area for shellfish
harvest is on the south shoreline of the inlet between Bay view Road and Mell Road. Due
to discharge from the treatment plant, shellfish harvest remains prohibited in the southern
portion of Oakland Bay area near Shelton (Frank Meriwether, Environmental Engineer at
the Department of Health, 2008).

In November 2007, the Washington State Department of Health restricted the
north end of Oakland Bay for shellfish harvesting. The restricted classification means that
direct harvest of shellfish is not allowed. Shellfish must be moved to an “approved” or
“conditionally approved” area to cleanse and become safe for human consumption before
it is harvested. One shellfish grower is currently affected by this restriction. While other
areas of Oakland Bay still remain in an unchanged status; this reclassification of the end
of Oakland Bay could be an indicator of widening water quality problems that may
eventually affect many other growers and citizens who use the bay.

Future Project for Shelton Waste Water Plan
In 2001, City of Shelton employed Gray & Osborn, Inc Consulting Engineering to
design a research project to identify potential long term regional solution for wastewater
treatment that accommodates growth and economic development of the area. Wastewater
production was projected for year 2020 based upon an annual growth rate of 2.0 percent,
which is the historical growth rate in Shelton.
Table 2 was completed by the engineering firm, and illustrates all capacities for the
projected regional wastewaters flows and loading (Gray & Osborn).

36

Table 2: Regional System Wastewater Projections (2020)
Maximum Month

Peak Hour

Maximum Month

Flow (mgd)

Flow (mgd)

BOD Loading
( Ibs/day)

City of Shelton (existing)

5.81

11.01

2200

City of Shelton (UGA and

0.78

1.91

1439

0.47

1.14

1360

Washington State Patrol

0.09

0.25

163

Port of Shelton

0.07

0.19

123

Total

7.22

14.49

5284

growth)
Washington Correction
Center

Sources: Gray & Osborn, Inc. Consulting Engineers, 2001
Caption: Gray & Osborn, Inc has been selected to prepare a pre-design report to assess
the condition of an existing and future sewer system capacity for the Shelton Wastewater
Treatment Plant.

In conclusion, water legislation in America started in June 20, 1938 with the
Rivers and Harbor Acts, which shows that people have been concerned about water
quality issues for years. As time progressed, so did water legislation to deal with the
changing pollutants that were being discharged (WRDAs, River and Harbor Acts, Flood
Control Acts, 2008). The Federal Clean Water Act established specific goals in 1972. It
called for all waters to be fishable and swimmable by 1983 and total elimination of waste
being discharged into navigable waters by 1983 (Title 33, Section 1251 [a]). Certain
water quality standards were set to achieve these goals with some states, such as
Washington, setting more stringent standards.
37

The city of Shelton needs to be proactive in regards to their waste water treatment
system. As population in the Mason County grows, there will be a need to expand the
capacity of sewage treatment in the area. Rather than planning additional loads to the
already maximized system, focus on the improved operation of the existing system and
plans of a future treatment facility are critically important to local and regional water
quality. The existing facility is obsolete and has not received significant upgrades or
expansions since 1978. In addition the low flushing characteristic of the bay increase the
fecal coliform and toxins that accumulates. This significantly impacts the health of the
community and often results in lost revenue to the multimillion dollars shellfish industry,
which is a staple to the regions economy.

The Clean Water Act seeks to prohibit the discharge of toxic pollutants, provide
financial assistance to construct publicly owned waste treatment works, and develop a
waste treatment management planning process to assure adequate control of pollution in
each state (Title 33, Section 1251 [a]). In this case, if the advocates are looking to
increase discharge without repairing the problems of the existing system, while regulators
(Department of Health and Department of Ecology) are looking for only the minimum
standards to be met; the long term of effect will be extremely costly for both the City of
Shelton and State of Washington. Other goals of the Clean Water Act, are aimed to
restore and maintain the physical and biological integrity of our nation's waters and
protect water quality for fish, shellfish and wildlife, and provide recreation in and on the
water (Title 33, Section 1251 [a]). The capacity and condition of Shelton’s waste water
treatment system has a tremendous impact to the regions environment, health and quality
of life for both people and marine life. These issues should be handled with balance and
foresight. The following are some options for consideration to better manage the region's
growing wastewater needs.

38

5: Recommendations
Presented here are five options being considered for increasing Shelton’s waste
water treatment capacity.
This section will identify a summery of possible benefits and issues for each.
•

Discharge More During Summer

•

Demand Management

•

Reclamation

•

Groundwater Recharge

•

Combination of Options

Increase Discharging During Summer Months
Discharging more to Hammersley Inlet during summer is currently the treatment
plans preferred alternative to meet the community's future wastewater needs. This option
also involves increasing discharge released into Oakland Bay.
Oakland Bay is an estuary, a body of water where freshwater flow joins saltwater. The
rate at which water flows and mixes within the inlet is very low, particularly during dry
weather. Building a satellite or a storage tank to stores extra treated water during winter
and discharging it in summer will change biological characteristic of the estuary, harming
fish and other aquatic life in the area. The extra discharge will increase the nutrition and
temperature, thus changing the level of dissolved oxygen, biochemical oxygen demand
and other key water quality factors. Also to include this as part of the solution for
handling increased wastewater flows, the treatment facility must renegotiate its existing
discharge permit with the Washington State Department of Ecology.

Demand Management
Through a number of measures such as implementing community education and
water conservation programs, also by diverting wastewater flows through gray water
system or by increasing the number of on site disposal system (septic tanks)the
immediate need for increasing capacity of the current treatment system would be

39

diminished. Managing demand in these ways would certainly delay the need for an
additional new wastewater treatment facility.

These options will maximize the use of current treatment facilities and reduces or
postpones the need for large scale new construction, thus delaying significant capital
investments. However, there are potential long term health impacts with septic tanks and
gray water systems. Typically, soils in the Oakland Bay area are not considered
acceptable for septic systems because of the high clay content in the southern portions of
the bay. The northern portions of the basin are limited by gravelly soils that percolate too
fast to groundwater sources. Individual property owners would be responsible for permit
compliance. Due to local soil conditions and the need for drain fields, conventional on
site disposal system are not suitable at urban densities. In addition, operating and
maintaining a new wastewater disposal system by private companies could be very costly
for home owners.

Reclamation
This option would use treated water for irrigation, non drinking water commercial
uses, and industrial purposes. Reclamation will reduce the amount of wastewater being
discharged to Oakland Bay and supplement the water supply (LOTT, 2002). However, a
reclamation project would require building a new satellite treatment plant and pipelines
which would cost an estimated $38,000,000 to construct. This is in addition to the
$25,000,000 to replace portions of the deteriorated collection system to reducing inflows
and infiltration of stormwater and groundwater that are currently entering the wastewater
system (Mason County Press Release, 2008).

There are several points to be considered; besides the enormous expenses. For
Mason County the updated treatment plant has to be capable of three times the capacity
of the existing plant and be capable of 20% additional buffering capacity for peak
demand. For example, if today's demand is 2.9 mgd and the projection for 2020 is 7.22
mgd the new or upgraded facility needs to be able to handle that capacity plus an
additional safety factor. In spite of the high cost, the reclamation plant would be highly

40

beneficial. The reclaimed water will reduce discharge of treated wastewater to the marine
environment or other surface water in sensitive winter months and would maximize the
use of wastewater as a resource in summer months. The State does however restricts and
regulates on how reclaimed water can be used. In order to comply with the State
restrictions, the plant needs to treat water to Class A Reclaimed Water standards, the
highest quality of reclaimed water as defined by the Washington State Departments of
Health and Ecology. Class A Reclaimed Water has nearly unrestricted uses, including
public contact, but is not considered suitable for consumption.

Ground Water Recharge
Groundwater recharge involves using highly treated wastewater to replenish or
"recharge" groundwater supplies for current and future needs. All of the recharge
methods require advanced levels of treatment and may require a new treatment plant.
New pipelines may also be needed to transport the treated water to a recharge area. There
are currently three methods for recharging groundwater:
•

Surface application

•

Shallow infiltration basins

•

Injection wells

The complex nature of groundwater system and high level treatment technologies
warrant starting at small scale to safeguard against groundwater contamination. There are
no current State standards for groundwater recharge yet, and the State is in the early
stages of establishing guidelines. Their efforts focus on using shallow infiltration basins
and constructed wetlands for the recharging process. This option provides an alternative
to increasing the discharge of treated wastewater into marine environments and poses low
risk of groundwater contamination. With the proposed level of treatment, however this
option would require building a new satellite treatment plant and shallow infiltration
basin which would also require large land area, potentially affecting sensitive habitat.

41

Conclusion
In order to achieve the goals of The Federal Clean Water Act, repairs to Shelton’s
existing waste water collection and treatment system need to be made. Even with the
needed repairs, the facility operates over capacity and realistically would not meet the
projected treatment demands of the near future.

In 2001 LOTT (wastewater Management Partnership) approved to build the first
satellite plant in Thurston County on Martin Way. LOTT purchased a 3.38-acre site at
6121 Martin Way to serve as the reclaimed water plant site, and 40.9 acre site along
Hogum Bay Road, between 28th and 31st Avenues. About 30 to 35 acres was needed for
the constructed wetlands polishing and storage ponds and another 5 to 10 acres for the
groundwater recharge basin. LOTT estimated $28.8 million, for building the reclaimed
water plant to handle the initial 1.0 mgd, for the Martin Way plant. Designing and
building the Shelton ponds and recharge basin to handle the ultimate 5.0 mgd will be
considerably more expensive.

It is possible that no single options can meet the growing needs of the region.
Thus, some combination of solutions may be best to meet the interim demands and a
combination program as a transition to an ultimate long term solution that focuses on a
single direction. Even though a reclamation system would incur considerable expense it
would benefit the regions economic and environmental health and vitality. Besides
improving the current waste water treatment system, it is extremely important to educate
the citizens of the community that they have a direct impact on the regions waters.
Whether individual household implemented their own water conservation effort, (such as
checking for the repairing leaks, installing low flow faucets and shower head or even not
letting the water run when brushing their teeth) or just being little more concisencious
about the products that end up going down their drain, these efforts all make a difference.
In addition the county may need to require septic system owners to have their system
inspected regularly and require failing system to be repaired or replaced in a timely

42

manner. There are certainly many things the government and individuals can do to
improve water quality for this and other areas.

By recognizing and accepting responsibility for our environment and waters we
will hopefully learn from the mistakes of our fore fathers and make decisions to correct
our path as we build the foundation for future generations.

43

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49