EXH0457022907

v. ) PATRICK LUCIA IN SUPPORT OF ) Ace's MOTION FOR STAY STATE OF WASHINGTON, ) DEPARTMENT OF ECOLOGY; and ) (Section 401 CertificationNo. THEPORT OF SEATTLE, ) 1996-4-02325 and CZMA concurrency ) statement,issued August 10, 2001, Respondents. ) Reissued September21, 2001, underNo. ) 1996-4-02325 (Amended-l)) l0 Dr, Pmick Lucia declarea as follows: 1. I amoverthe age of 18, am competent to testify, andhave _al knowledge of the facts sm_ hercfiL 14. 2. Pantgr-aphs2 - 5 of my firstdeclaration in supportof stay descn'besmy qualifications and familiaritywith the proposed ThirdRunway and related masterplan improvements at Sea-Tac Airport. 3. I havereviewed the Port's andEcology's declarations,exhibits and sur-replymemoranda. 4. Review of the issues raised leads to a clear conclusion thatthe Departmentof Ecology does not have reasonable assurancethat the fill placed to construct the embankmentwill meet the cnvironmcntal_criteriaand subsequently thatthe water infiltratingthroughthe embankmentwill not transporthazardoussubstancesthroughthe drainagelayer and into sensitive areas below the embankment.23 DECLARATIONOFDR.PATRICKLUCIAIN HELSELLFEITERMANLLP RachaelPasch=lOsbom SUPPORTOFACC'SMOTIONFOR STAY - 1 150oPt_etSanndPlaza Attorneyatlaw (_@p_ 1325FourthAvenue Z421Wast_don Avenue Seattle, WA 98101.2509 Spokane. WA 99201 AR 022907 / 5. The seconddeclarationof C. Lin Gould states thatthe MTCA method A cleanup level for arsenic (20 milligrams per kilogram)"represents'naturalbackground' as described in WAC 173-340- 900 at Table740-1 (footnote b)." That footnote states that theMTCA method A cleanup level for arsenic is "'basedon direct contact using Equation740-2 and protectionof groundwater for drinking water use using the proceduresin WAC 173-340-747(4), adjusted fornaturalback_'ound forsoil"6 (emphasis added). a 6. The 20 milligramsper kilogram (mg/kg) of a_'nic allowed by the amended certification's s fill…

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PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]