EXH0248019091

PCHBPollution Control Hearings Board of the State of Washington

Dear Colonel Graves, Ms. Walker and Ms. Tezzi: Re: Corps Ref. No. 1996-4-02325; Port of Seattle Low Streamflow Analysis Northwest Hydraulic Consultants, Inc., (nh¢) has been retained on behalf of the Airport Communities Coalition (ACC) to provide a technical review of stormwater facilities and streamflow impacts from development activities at SeaTac airport. The purpose of this letter is to comment on the December 2001 "Low Streamflow Analysis and Summer Low Flow Impact Offset Facility Proposal" prepared by Parametrix, Inc., for the Port of Seattle. The December 2001 Low Streamflow Analysis has numerous flaws, including, but not limited to, being largely unresponsive to concerns we have raised previously. For exmnple, while the report now acknowledges poor upper-gage low flow calibration of the hydrologic models used for the analysis, there does not appear to have been any attempt to improve that calibration or to address the resultant uncertainty in the interpretation of model results. Low-flow impacts of Industrial Wastewater System (IWS) improvements and borrow area developments continue to be ignored. The report fails to provide the digital data f-des(as were provided with previous documents) which would give reviewers the opportunity to independently interpret the Port's simulation results and to assess the significance of apparent modeling errors. Also, there appear to be serious fundamental problems in the methodology and assumptions for the third runway embankment seepage analyses and in the integration of that seepage analysis with the HSPF modeling used to predict impacts. Each of the three streams considered by the Low Streamflow…
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