Notes
Second declaration of Dr. Patrick Lucia filed by Airport Communities Coalition (ACC) in support of motion for stay before the Pollution Control Hearings Board (PCHB), case nos. 01-133 and 01-160, opposing Section 401 Certification No. 1996-4-02325 (Amended-1) and CZMA concurrency statement issued by Washington Department of Ecology for Port Of Seattle Third Runway embankment at Sea-Tac Airport. Dr. Lucia argues Ecology lacks reasonable assurance that fill material meets environmental criteria and that water infiltrating through the embankment will not transport hazardous substances through the drainage layer. Key issues include: MTCA Method A cleanup level for arsenic (20 mg/kg) being approximately three times the Puget Sound natural background level (7 mg/kg) per DOE Publication #94-115; soil concentrations for cadmium, chromium, lead, mercury, nickel, antimony, selenium, and silver all exceeding Puget Sound background levels or Practical Quantitation Limits (PQL); critique of Port’s arbitrary and unscientific sampling protocol; WAC 173-340-900, WAC 173-340-747(4), DOE Implementation Memo No. 3, Table II, Method 6010. Filed by Helsell Fetterman LLP and attorney Rachael Paschal Osborn.