(Table of Contents)

II.9 Mineral Resource Lands

Mineral Resource Land (MRL) overlay zones may allow for extraction of minerals and the accessory uses related to extraction such as washing and sorting if granted county administrative approval pursuant to WCC 20.84.235.  Activities permitted in the MRL overlay zones are in addition to the activities and uses that are permitted by the underlying zoning.

Most mining activities in the Nooksack Basin are related to sand and gravel with the exception of an olivine mining operation in the Middle Fork Nooksack Subbasin.

Mining activities can be a source of pollution to both surface and ground water.  Water quality concerns related to this activity include pH changes (either too high or too low), turbidity, total suspended solids, petroleum hydrocarbons, temperature changes from waste or process water, and total dissolved solids.

The Washington State Department of Ecology administers general permits under the NPDES process for mining activities. The general permit identifies monitoring requirements, best management practices, wastewater characteristics, standards, and stormwater controls that the applicant must follow in order to be in compliance.

II.9.1 North Fork Nooksack Subbasin

There are three designated Mineral Resource Land (MRL) overlay zones in the North Fork Nooksack Subbasin.  Figure 14, North Fork Subbasin Comprehensive Plan Designations, in Section II.2.1 identifies MRL overlay zone locations.  Table 35 identifies the geographic area of the overlay zones and the total acreage.  As previously mentioned, the MRL overlay zones are areas in which extraction of mineral resources are permitted. The designation of a MRL overlay zone is not representative of the size, number or status of mineral resource operations occurring within the overlay zone. Multiple extraction operations under different ownership may occur in a single MRL overlay zone.

TABLE 35. NORTH FORK NOOKSACK SUBBASIN MINERAL RESOURCE LAND (MRL) OVERLAYS

Source: Whatcom County Planning Department

II.9.2 Middle Fork Nooksack Subbasin 

There is one Mineral Resource Land (MRL) overlay designated in the Middle Fork Nooksack subbasin.  This overlay area, the Olivine Quarry, encompasses a total of 21.4 acres.  Figure 15, Middle Fork Subbasin Comprehensive Plan Designations, in Section II.2.2 identifies MRL overlay zone locations.  As previously mentioned, the MRL overlay zones are areas in which extraction of mineral resources are permitted. The designation of a MRL overlay zone is not representative of the size, number or status of mineral resource operations occurring within the overlay zone. Multiple extraction operations under different ownership may occur in a single MRL overlay zone.

II.9.3 South Fork Nooksack Subbasin

There are two Mineral Resource Land (MRL) overlay designations in the South Fork Nooksack subbasin encompassing a total of 118.2 acres.  Figure 16, South Fork Subbasin Comprehensive Plan Designations, in Section II.2.3 identifies MRL overlay zone locations.  Table 36 identifies the geographic area of the overlay zones and the total acreage.  As previously mentioned, the MRL overlay zones are areas in which extraction of mineral resources are permitted. The designation of a MRL overlay zone is not representative of the size, number or status of mineral resource operations occurring within the overlay zone. Multiple extraction operations under different ownership may occur in a single MRL overlay zone.

TABLE 36. SOUTH FORK NOOKSACK SUBBASIN MINERAL RESOURCE LAND (MRL) OVERLAYS

Source: Whatcom County Planning Department

[a]A portion of the Rutsatz Road MRL overlay crosses into the Lower Nooksack Subbasin.

II.9.4 Lower Nooksack Subbasin

There are seven Mineral Resource Land (MRL) overlay designations in the Lower Nooksack Subbasin encompassing a total of 1,059.7 acres.  Figure 17, Lower Nooksack Subbasin Comprehensive Plan Designations, in Section II.2.4 identifies MRL overlay zone locations.  Table 37 identifies the geographic area of the overlay zones and the total acreage.  As previously mentioned, the MRL overlay zones are areas in which extraction of mineral resources are permitted. The designation of a MRL overlay zone is not representative of the size, number or status of mineral resource operations occurring within the overlay zone. Multiple extraction operations under different ownership may occur in a single MRL overlay zone.

TABLE 37. LOWER NOOKSACK SUBBASIN MINERAL RESOURCE  LAND (MRL) OVERLAYS

Source: Whatcom County Planning Department
[a]A portion of the Rutsatz Road MRL overlay crosses into the South Fork Nooksack Subbasin.

II.10 Other Activities/Uses

II.10.1 Major Transmission Pipelines

There are four major pipelines that run through Whatcom County: Transmountain, ARCO, Olympic, and Williams (Figure 28).  All four pipelines cross through the Nooksack Basin to some extent.  Transmountain and Williams pipeline both cross the Nooksack River below the intakes of the City of Lynden and the PUD.

Transmountain Pipeline transports crude oil and condensate via a line that extends from an oil refinery at Cherry Point straight east to the Hannegan Road.  The point at which the west-east extension crosses the Nooksack River is below the PUD intake at Ferndale.  From the Hannegan Road, the Transmountain pipeline travels in a northeast direction between British Columbia to the north and Skagit County to the south.  The stretch of pipeline that goes in the northeast direction travels through sections of the Nooksack Basin and crosses the Nooksack River just below Everson.

The ARCO pipeline originates in British Columbia and transports natural gas to the refinery at Cherry Point.   The line travels southwest from British Columbia approximately 2.5 miles before traveling west approximately 14 miles.  At that point, the pipeline heads south to the refinery.  Only a small portion of the ARCO pipeline travels through the Nooksack Basin.  That area is north of the Badger Road (north of Lynden) where it crosses two of the primary tributaries of the mainstem Nooksack River: Bertrand and Fishtrap Creeks.  As previously mentioned, material transported through the pipeline is natural gas.  Petroleum products from ARCO are transported through the Olympic Pipeline, which travels south from the refinery and crosses the Nooksack below the intakes.

A natural gas pipeline, Williams, is the pipeline that travels most extensively through the Nooksack Basin.  The Williams pipeline also referred to as the Northwest Gas Pipeline, runs in a north-south direction from British Columbia to Skagit County.  From the south, the pipeline route parallels the South Fork Nooksack to approximately the point where the South Fork drains to the mainstem of the Nooksack River where the pipeline jogs to the west for approximately two and one-half miles before heading north to British Columbia.

The potential for impairment of source water quality from the pipelines depends to some extent on the nature of the product being transmitted.  As previously mentioned, two of the pipelines, ARCO and Williams transmit natural gas through the lines on the routes previously outlined.  The third pipeline, Transmountain, transmits crude oil.  Although from a risk assessment standpoint the probability of an accident is low, the potential for a catastrophic event to occur does exist.  Accidents involving two pipelines have occurred in Whatcom County within the last couple of years; with the most recent being in June 1999.  From the perspective of source water quality, the lines carrying oil products are of a much greater risk to water quality than the natural gas lines.  The PUD and City of Lynden should evaluate the emergency response plan of the pipeline companies to determine the potential impact to water treatment operations and intake facilities under a worst case scenario involving a rupture of the pipeline.

II.10.2 Sewage Treatment Plants

Effluent discharges from sewage treatment plants (STP) are regulated under the Clean Water Act.  Individual NPDES permits, issued by the Washington Department of Ecology, identify monitoring requirements and effluent standards for each of the operations.  As mentioned in the Permitted Facilities and Discharge section of the NSPP, review of specific permits is outside of the scope of this project but is identified as a recommendation for the implementation phase.  A general discussion of potential impairments to source water quality is discussed along with a brief description of the STP facilities discharging to the Nooksack River above the City of Lynden and PUD intakes.

Sewage treatment plants serve domestic, commercial, and industrial customers.  The chemical and biological composition of the waste effluent can vary among STPs based on the nature of the facility from which the waste is being accepted.  In general, the water quality concerns associated with wastewater effluent discharge from STPs include BOD concentrations, total suspended solids, chlorine residuals, metals, and microbial contaminants.  There may also be contaminants in wastewater that is unique to each facility.

The Cities of Lynden, Everson, and Ferndale all have NPDES permits for discharge of treated effluent to the Nooksack River from their sewage treatment facilities. 

The City of Everson’s sewage treatment facility serves areas within the City of Everson and the neighboring town of Nooksack. The design capacity of the facility is 440,000 gpd.  Assuming that normal I&I (infiltration and inflow) consumes approximately 10% of the design flow, close to 400,000 gpd remain for actual sewage flow.  The City’s draft comprehensive plan states that based on certain planning assumptions, design capacity of the treatment facility will be exceeded in the year 2006.[1] The City’s system includes operation of an oxidation ditch treatment facility north of the Nooksack River at the west end of town, which provides secondary sewage treatment.  An NPDES permit has been issued for the plant with discharge after treatment going to the Nooksack River at approximately RM 23; approximately 5.5 miles upriver of the City of Lynden’s water intake.

The City of Lynden operates a secondary sewage treatment facility at approximately RM 17. The discharge is approximately 8 miles upriver of the PUD’s Trigg Road intake and 12 miles upriver of the PUD intake slightly north of the Urlick Road.  Elevated fecal coliform counts were detected in sampling of the Lynden discharge during the Nooksack TMDL assessment conducted by the Department of Ecology from March 1997 to February 1998 (Joy, 1999).  The elevated counts detected during this period appear to have been effectively addressed by equipment installed in 1999 as part of the Lynden sewage treatment plant expansion.  Elevated fecal coliform counts have not been measured in samples conducted since installation of the equipment (Klimpel, 1999).  Equipment installation included an UV treatment system, which eliminates residual chlorine and fecal coliform in the wastewater effluent.  A chlorine contact system remains in place as a backup system.  The expected completion date for additional changes to the sewage treatment plant is mid-2000.

The City of Ferndale’s sewage treatment operation and NPDES permit is not discussed since it is down river of the City of Lynden and the PUD intakes.

II.10.3 Urbanization and Stormwater 

Urban areas are sources of contaminants that can impair source water quality due to the amount of impervious surface associated with these areas.  Impervious surfaces include roads and sidewalks, driveways, parking areas, and rooftops that do not allow precipitation to penetrate the soil. Urban residential, commercial, and industrial land uses have a much larger percentage of impervious surfaces than forests and pasturelands. Larger amounts of impervious surfaces in turn contribute to greater volumes of stormwater runoff. 

Stormwater runoff can transport pollutants and nutrients to streams, rivers, and lakes. The types of pollutants associated with urban stormwater are sediment, nutrients, pathogens, organic enrichment, toxic materials, and salts (Table 38).  The untreated stormwater runoff enters surface waters by moving over the land, through ditches, or directly into streams, rivers, and lakes.

TABLE 38. TYPES OF POLLUTANTS ASSOCIATED WITH URBAN STORMWATER RUNOFF

[a]Source: EPA, 1993.
[b]Trace metals most commonly found in urban stormwater (Novotny, 1995).
[c]Organics most commonly found in stormwater (City of Seattle, 1989).

While stormwater runoff occurs with all land uses, the volume of water and the amount and types of pollutants change with increased levels of impervious surfaces.  As illustrated in Table 39, different land use coverage within urban areas are associated with different percentages of impervious surfaces.

TABLE 39. THE AVERAGE PERCENTAGE OF IMPERVIOUS SURFACE ASSOCIATED WITH DIFFERENT LAND USE COVERAGES

Source: Soil Conservation Service, 1975

The differences in percentages of impervious surfaces associated with different urban coverage is significant not only because of the increased volume and velocity of stormwater runoff to surface water, but because of the increased loading potential of pollutants it represents.  Table 40 outlines loading potential of pollutants from different urban land use coverage.

TABLE 40. POLLUTANT LOADS FROM URBAN WATERSHEDS IN MILWAUKEE, WISCONSIN (EXCLUDING WINTER MONTHS DECEMBER TO MARCH)

Source: Novotny, 1995 (Adapted from Bannerman et al., 1984)

There are a variety of stormwater management approaches that can be used to control contaminants in runoff.  Methods used in some communities include but are not limited to stormwater collection systems, detention ponds, bioswales, wet ponds, and constructed wetlands.  In many cases, the collection systems and detention ponds simply offer a form of storage for the untreated stormwater, decreasing the volume of runoff entering surface waters and providing some settlement of particulate matter.  Stormwater that is collected and directed to a municipal or industrial sewer system is treated for the pollutants.  Wastewater treatment plants are regulated through NPDES permits and their pollutant discharge levels must remain below the permitted concentrations. 

Other stormwater methods, such as bioswales, biofiltration ponds, and constructed wetlands, remove some of the pollutants; primarily through the reduction of suspended sediment, which serves as the transport mechanism for many of the pollutants. The pollutant removal efficiencies for these methods are dependent upon the design and maintenance of the system.  The removal efficiencies for several stormwater control methods are outlined below (Table 41). 

TABLE 41. EFFECTIVENESS OF STORMWATER TREATMENT METHODS IN TERMS OF REMOVAL EFFICIENCIES.

Source: Horner, 1999.

Local government and the Washington State Department of Ecology provide a regulatory framework for controlling stormwater runoff through local stormwater and development ordinances and Ecology’s general stormwater permit.  Section V outlines local ordinances that address stormwater management.

Ecology’s general stormwater permits covers industrial facilities as well as short-term permits for construction sites over five acres.  General stormwater permits are required for a variety of industrial facilities discharging stormwater to surface water or into storm drainage systems that discharge to surface water.  These permits are further described in Appendix C.  In addition, the Department of Ecology has a number of guidance and permit documents that describe construction and industrial activities that require general stormwater permits, the steps for applying for a permit, and the requirements of each permit.  Facilities in the Nooksack Basin that have been issued general stormwater permits are identified by subbasin in Section II.7.

Urban areas in the Lower Nooksack Basin include the Cities of Everson, Lynden, and Ferndale. Discharges from the City of Everson are upriver of the City of Lynden’s intake and discharges from the City of Lynden are upriver of the PUD’s intake.  Depending on the location of discharges from the City of Ferndale, the discharge may be above or below the PUD intake (discharges through the STP are below the intake). 

Everson is located on both the north and south side of the river with approximately ½ mile of the city limits along the banks. In some parts of the City, primarily the north side, stormwater runs directly to ditches.  Also serving the north side of the City is a piped collection system that discharges to Johnson Creek.  Drainage from the north side of Everson is not in the Nooksack Basin.  On the south side of the City, which is in the Nooksack Basin, stormwater is discharged through a piped system: one pipe discharges directly to the Nooksack River by Riverside Park, the other discharges on the upstream side of the bridge near Lincoln Street, and the third discharges on the west side of Highway 544 into a ditch that drains to the Nooksack River.

In June 1998, the City of Everson retained a consultant to complete a Stormwater Management Program.  A schedule for completing the program has not been identified.[2]  Due to the relatively close proximity of the City of Lynden’s intake to Everson’s discharges (approximately 5 river miles), it is recommended that the City of Everson establish a timeline for completing the Stormwater Management Program.  Given the potential for Everson’s discharges to influence source water quality for the Lynden and the PUD, the City of Everson is encouraged to include Lynden and the PUD on the distribution list for reviewing early draft documents of Everson’s Stormwater Management Program.

The east-west perimeter of Lynden’s urban area runs from approximately 1 mile west of the Guide Meridian east to the Northwood Road: approximately 5 linear miles adjacent to the north bank of the Nooksack River.  Approximately 2 linear miles of this area is within ½ mile of the river’s edge and the remaining 3 miles range from ¼ to ½ mile from the river. The City of Lynden has adopted the Washington State Department of Ecology’s, Puget Sound Basin Stormwater Management Manual as their Technical Stormwater Management Manual.  The City’s Shoreline Management Program, which could also be effective in managing stormwater runoff into the Nooksack River and Fishtrap Creek, is in draft form.  Since measures outlined in the draft Shoreline Management Program could be effective in reducing stormwater contaminants, it is recommended that the City move forward with the adoption of the draft Shoreline Management Program.

The city limits of Ferndale extend across the Nooksack River from 2-¼ linear miles west and 2-¼ linear miles east of the river.  Approximately 1-linear mile of the city limits lies adjacent to the riverbank.  The PUD has an intake just below the southern boundary of the city limits from which it supplies non-potable water to the City of Ferndale for its treatment and distribution as a municipal water supply.  Due to the potential for contaminants in stormwater to impair source water quality, the City of Ferndale should review its Stormwater and Shoreline Management Programs for source controls that will minimize potential pollutant loading to the Nooksack River.

As previously mentioned, there are a number of facilities in the Nooksack Basin that have industrial general stormwater permits.  Several of these facilities are located within the city limits of Everson, Lynden and Ferndale.  These facilities are required to develop and submit a Stormwater Pollution Prevention Plan (SWPPP) to the Department of Ecology for the stormwater permit.  The SWPPP includes creating a pollution prevention team, performing a site assessment, developing a site map, developing best management practices, implementing the plan, and evaluating the progress of the plan.  Stormwater monitoring is not required by the permit, yet it is encouraged in order to evaluate the progress of the plan. 

Although the SWPPP provides an effective approach for assessing industrial facilities and establishing best management practices, there is still potential for stormwater to carry materials from the facilities to surface waters if the plans are not being implemented or if they are not being maintained.  An assessment of the individual SWPPP and their effectiveness in treatment of stormwater runoff was not within the scope of this phase of the NSPP.  Assessing the SWPPP within the 1-hour time of travel to the intakes is recommended as an implementation item.

II.10.4 Fish Rearing

The Nooksack Salmon Hatchery, operated by Washington State Department of Fish and Wildlife, is located on the North Fork Nooksack close to RM 46.  The potential for source water quality to be impaired from this operation will be evaluated as part of the NSPP implementation phase. 

The Lummi Nation operates a fish hatchery on Skookum Creek, which is a tributary to the South Fork Nooksack.  Although an NPDES general permit for fish rearing was not listed in the Washington State Department of Ecology’s database for issuance of permits, the potential for the operation to impair source water quality will be similar to those presented by the WADFW operation in the North Fork Nooksack Subbasin.  Evaluation of the potential for fish rearing to impair source water quality is a component of the NSPP implementation phase.

In addition to the state and tribal fish hatcheries, schools located within the Nooksack Basin are often involved in fish rearing and restoration programs on local streams.  Several science teachers in Whatcom County have received state and local recognition for their incorporation of salmon and water quality topics into their curriculum and classroom projects.

II.10.5 Hydroelectric Dam

Puget Sound Energy operates a small hydroelectric plant partially diverting flow around Nooksack Falls.  The facility is located near North Fork Nooksack RM 65. Information on this facility and its potential for impairing source water quality was not readily available.  Further review of this facility should be part of the 2006 NSPP update.

II.11. Subbasin Summary and Priority Ranking of Activities

The summaries below were prepared using information discussed above under the topical headings as well as information from the subbasin field survey sheets and contaminant ranking matrix.  Appendix B includes the contaminant ranking matrix, and a description of the approach used for developing the matrix.   Briefly, the contaminant ranking matrix is a compilation of activities occurring in the subbasins, potential contaminants contributed by the activity, whether the transport mechanism for the contaminant to enter the water is direct or indirect, whether the activity is found in Zone A or Zone B[3], and ranking of the activity in terms of relative risk to source water quality. 

II.11.1 North Fork Nooksack Subbasin - Summary of Activities 

Approximately 60% of the land area in the North Fork Nooksack Subbasin is within National Forest, National Park, and Wilderness boundaries.  Approximately 30% of the land area is zoned commercial forestry.  Within that 30%, the primary landowner is Washington State at approximately 53% of the ownership.  Of the remaining 10% of land area in the subbasin, the primary use is rural residential. 

Based solely on zoning, the activity that would appear to have the greatest potential to impair source water quality is commercial forestry.  The Washington State Forest Practices Act and the Watershed Analysis Program administered by the Washington State Department of Natural Resources are existing programs that address environmental impacts from commercial forest practices.  A description of the Watershed Analysis Program is included as Appendix A. 

Although not in the top 20 ranking, the Kenney Creek WAU is on the priority list for conducting a watershed analysis (Cayhill, 1999).  The watershed analysis process evaluates slope stability, erosion, riparian areas, water flow patterns, and stream channel conditions.  Additionally, the impact of these processes on water quality, fish and fish habitat, and capital improvements are evaluated.  Prescriptions for the WAU are determined from the watershed analysis and are designed to help protect and allow recovery of the public resources. 

In addition to the programs previously mentioned, county ESA and 2514 Watershed Planning programs will be addressing forestry topics.  Therefore, in terms of City of Lynden and PUD priorities for establishing source controls to protect source water quality, addressing commercial forestry activities is a low priority.

Rural residential uses account for a small percentage of the total land area in the North Fork Nooksack Subbasin.  Activities that are often associated with rural residences with potential to impair water quality include failing on-site sewage disposal systems, improper livestock management (includes waste disposal and grazing practices), and use of pesticides and fertilizers on large gardens and orchards.  Rural residences are generally on five or 10 acre parcels and are often associated with low percentages of impervious surfaces.  The low percentage of impervious surface aids in reducing stormwater runoff that transports pollutants to ditches, streams, and ultimately the Nooksack River.  Given the low density of rural residential uses in the subbasin and the fact that most of them are located in Zone B of the subbasin, rural residential uses in the North Fork Nooksack Subbasin are a low priority for purposes of identifying source control measures that the City of Lynden and PUD should pursue for source water protection.

Although rural residential on-site sewage disposal is not a priority for the City of Lynden and PUD, the potential failure of on-site sewage disposal for commercial and institutional facilities is a medium priority.  The potential for source water quality to be impaired from a failing community system is greater since the loading of microbial organisms would be higher.  In addition, businesses such as restaurants may have employees that are unaware of the vulnerability of on-site systems to certain types of products and wastes resulting of disruption or failure of the system.  Review and assessment of community and commercial on-site facilities was not within the scope of this project but is recommended, for facilities in Zone A, as an implementation item.

Another concern associated with rural-zoned areas, as it relates to source water impairment, is the number of small business establishments observed in R5 and R10 areas that have a potential to impair water quality.  The businesses observed during the survey vary in the type of activity they are involved with but include such enterprises as transmission shops and boat building.  It is currently unknown what, if any, effect these businesses may be having on source water quality.  A review and assessment of the activities associated with these businesses was not within the scope of the NSPP development phase, but is recommended as part of the implementation phase.

A significant land use in the North Fork Nooksack Subbasin that is not generally considered when reviewing zoning designations is transportation routes.  Several arterials run through the North Fork Nooksack Subbasin.  However, as discussed under the Transportation section of the NSPP, some arterials present a greater risk to source water than other arterials.  The Mt. Baker Highway, which supports the greatest traffic volume, has stretches of highway that come in close proximity to the North Fork Nooksack.  The proximity of the road in these stretches makes the river vulnerable to a chemical or fuel spill.  Identifying source control measures for emergency response to incidents on the Mt. Baker Highway is a high priority to be addressed by the City of Lynden and PUD in Section V of the NSPP.

II.11.2 Middle Fork Nooksack Subbasin - Summary of Activities 

Approximately 85% of the land area in the Middle Fork Nooksack Subbasin is within National Forest, National Wilderness and forestry designations.  Of the remaining 15% land area, 10% is zoned for rural residential, five-acre parcels.

If based strictly on percentage of use, the activity with the greatest potential to impair source water quality is forestry practices.  However, with the existing source control programs in place – Washington State Forests Practices Act and DNR Watershed Analysis (Appendix A) – potential impacts to source water from this activity has been greatly reduced. The watershed analysis process evaluates slope stability, erosion, riparian areas, water flow patterns, and stream channel conditions.  Additionally, the impact of these processes on water quality, fish and fish habitat, and capital improvements are evaluated.  Prescriptions for the WAU are determined from the watershed analysis and are designed to help protect and allow recovery of the public resources. Although not in the top 20 ranking, the Clearwater and Porter WAUs are on the priority list for conducting a watershed analysis (Cayhill, 1999).  Further reducing potential for forest practices to impair source water quality are new programs that will take place as a result of the Endangered Species Act listing of salmon such as the development of Habitat Conservation Plans.  Although these programs will emphasize habitat protection, the contaminants that impair water quality for fisheries are often the same contaminants that impair water quality for drinking water sources. For these reasons, the City of Lynden and PUD have identified commercial forest practices in the Middle Fork Nooksack Subbasin as a low priority.

Activities associated with Rural Residential uses observed in the Middle Fork Nooksack Subbasin in Zone A (>0.5 mi to M.F.) include approximately six large scrap yards.  The contents of these scrap yards is unknown therefore, the potential for this activity to impair water quality is unknown.  For the following reasons, the City of Lynden and PUD have identified noncommercial, rural residential scrap yards and auto junkyards as a high priority: 1) the potential for these types of facilities to impair source water quality exists; 2) the lack of information on what is being disposed of at the site makes it difficult to assess relative risk to source water quality; 3) the sites do not appear to fall under county or state regulations; and 4) the sites are often in close proximity to a waterbody that drains to the Nooksack River. 

Other activities associated with rural residential uses such as livestock keeping are less of a concern since a windshield survey count of hobby farms in the Middle Fork Nooksack Subbasin revealed less than 20 such facilities located throughout the subbasin.  Although there are limitations associated with a windshield survey, the results are representative of activities taking place in the area.

Also associated with a subbasin exhibiting rural characteristics is the use of on-site sewage disposal systems.  Whatcom County Health Department regulations govern the construction, installation, and operation of these waste disposal systems.  A failing system can be a source of microbial contaminants and nutrients to waterbodies.  With the low population density in the Middle Fork Nooksack Subbasin and the lack of commercial or institutional facilities requiring on-site sewage systems, failing on-site disposal systems are a low priority for the City of Lynden and PUD.

Transportation as an item to be addressed by the City of Lynden and PUD for purposes of source control measures, is a low priority.  The potential risk to source water quality is low for vehicular traffic: 260 vehicle average per day during a typical weekday on Mosquito Lake Road at the North Fork bridge.   There does not appear to be rail transportation in the Middle Fork Nooksack Subbasin.

II.11.3 South Fork Nooksack Subbasin - Summary of Activities 

Approximately 88% of the land area in the South Fork Nooksack Subbasin is within National Forest, National Wilderness and forestry designations.  Of the remaining 12% land area, 8% is zoned for agriculture.

If based strictly on percentage of use, the activity with the greatest potential to impair source water quality is forestry.  However, with the existing source control programs in place – Washington State Forests Practices Act and DNR Watershed Analysis – potential impacts to source water from this activity has been greatly reduced.  The watershed analysis process, described in Appendix A, evaluates slope stability, erosion, riparian areas, water flow patterns, and stream channel conditions.  Additionally, the impact of these processes on water quality, fish and fish habitat, and capital improvements are evaluated.  Prescriptions for the WAU are determined from the watershed analysis and are designed to help protect and allow recovery of the public resources.  In the South Fork Nooksack Subbasin, the watershed analysis process has been completed by DNR for Skookum, Hutchinson and Wanlick Creek WAUs.  In addition, the Howard Creek WAU has a number one priority ranking with the DNR regional office for purposes of undertaking a watershed analysis. The Acme WAU analysis process is underway and is being done by Crown Pacific (Cayhill, 1999).  Further reducing potential for forest practices to impair source water quality are new programs that will take place as a result of the Endangered Species Act listing of salmon such as the development of Habitat Conservation Plans.  Although these programs will emphasize habitat protection, the contaminants that impair water quality for fisheries are often the same contaminants that impair water quality for drinking water sources.  For these reasons, the City of Lynden and PUD have identified commercial forest practices in the Middle Fork Nooksack Subbasin as a low priority.

Agriculture comprises approximately 8% of the zoned area in the South Fork Nooksack Subbasin.  There were approximately twelve commercial livestock keeping operations observed in Zone A[4] in the South Fork Subbasin.  Based on the volume of waste generated by a single dairy or beef cow (Table 17 in Section 11.4), the potential risk to source water quality is estimated to be high.  However as discussed in previous sections, state and local programs are underway to improve and correct waste management practices on commercial farms.  Given the number of programs that have been initiated relative to eliminating or minimizing manure discharges to waterbodies, the City of Lynden and the PUD consider manure management activities to be a medium priority for purposes of this phase of the NSPP.

There were a number of hobby farms observed in Zone A of the South Fork Nooksack Subbasin.  The potential for this activity to impair water quality stems from the volume of waste that is generated by a single animal and the manner in which the manure is managed.  The Whatcom Conservation District has two technicians on staff whose job responsibility is to work with hobby farms to establish best management practices and farm plans that will reduce the potential for pollutants to reach waterbodies.  This source control program is identified as an action in the Portage Bay Closure Response Strategy.  Since staff is in place to address this activity, it is currently a low priority for the City of Lynden and PUD.  The status of this activity and the effectiveness of existing programs to reduce the potential for water quality to be impaired, should be revisited by the City and PUD for the 2006 NSPP update.

Another activity observed in the South Fork Nooksack Subbasin includes rural scrap yards.  The contents of these scrap yards is unknown therefore, the potential for this activity to impair water quality is unknown.  For the following reasons, the City of Lynden and PUD have identified noncommercial, rural residential scrap yards and auto junkyards as a high priority: 1) the potential for these types of facilities to impair source water quality exists; 2) the lack of information on what is being disposed of at the site makes it difficult to assess relative risk to source water quality; 3) the sites do not appear to fall under county or state regulations; and 4) the sites are often in close proximity to a waterbody that drains to the Nooksack River.

In addition to the noncommercial, rural residential scrap yards, the Nooksack Tribe operates a landfill in Zone A of the South Fork Nooksack Subbasin.  For the same reasons as those identified above, this activity is ranked as a high priority item for further evaluation.

Although rural residential on-site sewage disposal is not a priority for the City of Lynden and PUD, the potential failure of on-site sewage disposal for commercial and institutional facilities is a medium priority.  The potential for source water quality to be impaired from a multi-user system is greater since the loading of microbial organisms would be higher.  In addition, businesses such as restaurants may have employees that are unaware of the vulnerability of on-site systems to certain types of products and wastes resulting of disruption or failure of the system.  Review and assessment of community and commercial on-site facilities was not within the scope of this project but is recommended, for facilities in Zone A, as an implementation item.

Another concern associated with rural-zoned areas, as it relates to source water impairment, is the number of small business establishments observed in R5 and R10 areas that have a potential to impair water quality.  The businesses observed during the survey vary in the type of activity they are involved with but include such enterprises as transmission shops and boat building.  It is currently unknown what, if any, effect these businesses may be having on source water quality.  A review and assessment of the activities associated with these businesses was not within the scope of the NSPP development phase, but is recommended as part of the implementation phase.

Modes of transportation in the South Fork Nooksack Subbasin include both vehicular traffic and rail transport.  According to WADOT traffic counts, the South Fork Nooksack Bridge at Highway 9 supports an ADT count of 4700 vehicles. Although the Highway does not parallel the river within a close distance as it does on the Mt. Baker Highway, the traffic volume crossing over the South Fork bridge is significant representing a potential hazard to source water from an accidental spill.  In addition to vehicular traffic, the Burlington Northern rail route from Sedro Woolley travels through the South Fork Nooksack Subbasin.  The railroad parallels the South Fork until it leaves the subbasin south of Deming.  A material transport summary for a one-year period indicated that hazardous materials are transported through the subbasin.  Emergency response preparedness for purposes of responding to a vehicular or rail accident that would result in a spill of hazardous materials to the river is a high priority for the City of Lynden and PUD.

II.11.4 Lower Nooksack Subbasin - Summary and Priority Ranking of Activities 

Approximately 56% of the land area in the Lower Nooksack Subbasin is zoned Agriculture with 31% being zoned for 5 acre rural residential uses.  The remaining 13% of county-zoned land represent a mix of different land uses.  In addition to the county-zoned land, the urban areas of the Cities of Everson, Lynden and Ferndale are in the Lower Nooksack Subbasin.  When considering total acres of land in the Lower Nooksack Subbasin, the Cities of Everson, Lynden, and Ferndale comprise 0.1%, 3%, and 4% of the area, respectively.

Agriculture represents a significant portion of the activity occurring in the Lower Nooksack Subbasin and includes dairies, beef operations, poultry farms, vegetable production, apple orchards, red raspberries, strawberries, cranberries, and cottonwoods.  Potential sources of contaminants vary with each type of operation.  Generally, the greatest water quality concern resulting from livestock operations involves improper waste management resulting in microbial and nutrient contamination of waterbodies.  With crop production, the greatest water quality concern is the potential for leaching or runoff of pesticides to water resources and nutrient inputs.

Given the volume of waste generated by a single dairy or beef cow and the approximate number of commercial operations (200) in the Lower Nooksack Subbasin, the potential for source water quality to be impaired from this activity is high.  There are a number of regulatory and voluntary programs underway whose sole objective is to eliminate the discharge of animal waste to surface waters.  Increased inspections of dairies in Whatcom County have occurred as a result of recently passed legislation that requires the inspections at least every two years.  Tasks included in the Portage Bay Closure Response Strategy include providing technical and financial assistance to farms for purposes of developing and implementing manure management plans.  The TMDL program, administered by the Department of Ecology, will recommend source control programs for purposes of addressing fecal coliform and nutrient loads to surface water (Joy, 1999).  Given the number of efforts underway to address impairment of water quality from commercial farms, the City of Lynden and PUD should participate in these efforts in order to assess the need for additional source control programs.  Additional source control programs, if determined to be necessary after assessing the effectiveness of those underway, will be identified and included in the 2006 NSPP update.

Crop production can result in the use of a variety of pesticides[5].  Potential for impairment of water resources is through leaching or runoff.  As mentioned in section II.4.1, ground water contamination from agricultural chemicals has occurred in areas of the subbasin.  The Nooksack Integrated Pest Management (IPM) Program administered through the WSU Cooperative Extension, Whatcom County has been working closely with farmers to reduce applications of pesticides by using techniques such as scouting and monitoring for pest infestations to determine the point at which application of a pesticide is critical to the overall production of the crop.  The grant-funded program has been highly successful and producers are incorporating IPM into their operation.  The IPM mentoring program will not be considered as an existing source control program, however, since it is a grant-funded and has a completion date of June 30, 1999.

With regard to impairment of source water quality from pesticides, there has been very limited monitoring of the water column and sediments in the Nooksack River to determine potential impairment to water quality from these chemicals.  However, water purveyors are required under Washington State Department of Health drinking water requirements to test source water for synthetic organic compounds (SOC), which includes a wide range of pesticides.  A review of information provided by the water purveyors for source water testing for SOCs did not indicate a presence of pesticides in the source water at the time of collection.  However, a single sampling event with non-detects is not conclusive evidence that pesticides are not reaching source water.  Timing of collection efforts to coincide with the growing seasons may provide a more representative assessment of potential impairment of source water quality from pesticides.  Consideration needs to be given to the fact, however, that urban areas are often a significant source of pesticides.  In fact, a very recent report prepared by the USGS on pesticide contributions from different land uses confirms the high use of pesticides in urban areas (Table 42).   

TABLE 42. RELATIVE LEVEL OF STREAM CONTAMINATION FROM PESTICIDES

Source: Adapted from U.S. Geological Survey, 1999.

The Cities of Everson, Lynden, and Ferndale are all on the banks of the Nooksack River. Therefore, any additional assessment of pesticide presence in source water must consider loading from these urban areas in order to more effectively identify and implement source control measures.  A recommendation for a comprehensive, collaborative monitoring program that uses similar QAPP for all collection efforts in the Nooksack Basin is included as part of the NSPP and is a high priority item for the City of Lynden and PUD.  Discussion of or efforts to expand monitoring on the Nooksack River for purposes of assessing potential impairment of source water from pesticides should be considered as part of the larger Nooksack Basin monitoring program effort.

Despite the relatively small percentage of area that the three jurisdictions cover in the Lower Nooksack Subbasin, the potential for these areas to impair source water quality is significant.  In addition to potentially hazardous materials that may be stored or generated at individual facilities within the jurisdictional boundaries and the stormwater runoff associated with impervious surfaces from these urban areas, the cities themselves have a potential to contribute contaminants to source water from point sources including water and wastewater treatment facility discharges.  Point source discharges from the facilities require a NPDES permit issued by the Department of Ecology.

Several recommendations have been made that will address the potential impairment of source water quality from urban areas including:

• Review of SWPPP of facilities within a 1-hour time of travel of intakes that have been issued stormwater permits by the Department of Ecology;  
  
• Reviewing the NDPES and RCRA permits of facilities within the 1- and 2- hour time of travel to determine potential impairment of source water quality from those facilities;
  
• Measures to encourage the updating, development, or approval of Shoreline and Stormwater Management Programs for the Cities of Everson, Lynden, and Ferndale;  
  
• Incorporate public education messages related to source protection into existing city communication avenues (i.e., city newsletter or water bills) and in material developed for use in implementing NSPP recommendations (i.e., inventory of potential waste generators).

Rural 5-acre parcels comprise the second largest designated land use in the Lower Nooksack Subbasin at 31% of county-zoned acreage.  Activities associated with rural residences, such as R5 parcels, include animal keeping.  A windshield survey taken by driving all public access roads in the Lower Nooksack Subbasin identified over 300 hobby farms of varying sizes. The potential for this activity to impair water quality stems from the volume of waste that is generated by a single animal and the manner in which the manure is managed.  The Whatcom Conservation District has two technicians on staff whose job responsibility is to work with hobby farms for purposes of establishing best management practices and farm plans that reduce the potential for pollutants to reach waterbodies.  This is a source control program identified in the Portage Bay Closure Response Strategy.  Since staff is in place at the Conservation District and it is a work item in the Closure Response Strategy, addressing small farms is currently a low priority for the City of Lynden and PUD.  The status of this activity and the effectiveness of existing programs to reduce the potential for water quality to be impaired should be revisited by the City of Lynden and PUD for the 2006 NSPP update.

Another concern associated with rural-zoned areas, as it relates to source water impairment, is the number of small business establishments observed in R5 and R10 areas that have a potential to impair water quality.  The businesses observed during the survey vary in the type of activity they are involved with but include such enterprises as transmission shops and boat building.  It is currently unknown what, if any, effect these businesses may be having on source water quality.  A review and assessment of the activities associated with these businesses was not within the scope of the NSPP development phase, but is recommended as part of the implementation phase.

With the exception of the Cities of Everson, Lynden, and Ferndale and areas in the urban fringes, residences, commercial and institutional facilities in the Lower Nooksack Subbasin are served by on-site sewage disposal systems.  The potential failure of on-site sewage disposal for commercial and institutional facilities is of concern to the City of Lynden and PUD for the following reasons: 1) a failing commercial on-site system may represent a greater potential loading of microbial organisms to source water than residential systems and 2) businesses may have employees that are unaware of the vulnerability of on-site systems to certain types of products and wastes resulting in disruption or failure of the system.  Review and assessment of community and commercial on-site facilities was not within the scope of this project but is recommended, for facilities in Zone A, as an implementation item.

A significant land use in the Lower Nooksack Subbasin that is not generally considered when reviewing zoning designations is transportation routes.  Several arterials run through the Lower Nooksack Subbasin.  However, as discussed in the Transportation section, there are some aspects of the subbasin transportation corridors that present a greater risk to source water than other aspects.  There are six bridges spanning the mainstem of the Nooksack River including:  

• The Ferndale bridge supported approximately 17,900 vehicles per week day in 1996;  
  
• The I-5 bridge located at approximately RM 6.5 supported an average daily count in 1997 of approximately 31,000 vehicles; 
  
• SR 539 (Guide Meridian) supported approximately 13,000 vehicles per day in 1997;
  
• Between 1992-1996, the Hannegan Road bridge supported an average count of 7,000 vehicles per day during a typical weekday and 9,900 vehicles per day during Northwest Washington Fair week;
  
• The bridge counts for the Everson bridge in 1997 were approximately 7,300 vehicles per day; and  
  
• The bridge on SR 542 (Mt. Baker Highway) supported approximately 8,700 vehicles per day in 1997.

In addition to the bridge traffic, arterials with high traffic volumes in the Lower Nooksack Subbasin include SR 546 (Badger Road) which is a primary east-west arterial just north of the Lynden city limits.  The Badger Rd. crosses three of the primary tributaries of the Nooksack River: Bertrand, Fishtrap, and Kamm Creeks.  Traffic volume for this arterial was 6,400 vehicles per day as measured in 1997 at a post just past the junction of Depot Road. 

Another arterial that has a significant volume of daily traffic and which crosses a primary drainage of the Nooksack River is SR 544 (Pole Road).  Traffic volume on the Pole Road between the Guide Meridian and the Everson-Goshen Road was measured at an average 5750 vehicles per day during 1997.  The Pole Road crosses through the Ten-Mile Creek watershed, which is a primary drainage to the lower Nooksack River. 

The high volume of traffic traveling over the bridges and arterials listed above represent a potential risk to source water quality from an accident that may result in a spill to the river or a primary tributary.  In addition to passenger vehicles, all of the arterials identified are primary transportation routes for commercial transport vehicles.  It is virtually impossible to track all of the material that may be transported through the Lower Nooksack Subbasin via commercial vehicles.  The most feasible approach for addressing potential impairment of source water quality resulting from transportation corridors in the Lower Nooksack Subbasin is through emergency preparedness.  In Section V, the City of Lynden and PUD have identified a number of recommendations for the implementation phase that will build on current emergency response and preparedness programs.

Another activity found in the Lower Nooksack Subbasin that presents a potential risk to source water quality are the major transmission lines that travel through sections of the subbasin.  There are four major pipelines in the basin that transport different materials: Williams, ARCO, Olympic and Transmountain.  Williams and ARCO transport natural gas while Transmountain transports crude oil.  Olympic pipeline transports a variety of material through their transmission line.  Transmountain Pipeline has an extensive emergency response and preparedness plan on file with Whatcom County Emergency Management Services (EMS) and have a cooperative relationship with EMS (Clement, 1998).  The emergency response plans for all of the pipeline companies should be on file with Whatcom County Emergency Management Services and reviewed for the purpose of incorporating information from those plans into the emergency response and preparedness training recommendations identified in Section V.

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