December 8, 1998August 2, 2026

Exhibit AR-026486: Memorandum on Development of a Site-Specific Copper Translator for the Port Of Seattle

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Memorandum dated December 8, 1998 from Justin Kophs to Linda Logan (cc: Doug Henderson) summarizing options for developing a site-specific copper metals translator for the Port Of Seattle. Discusses WDOE recommendations for dissolved/total recoverable metal partitioning studies incorporating seasonal variation, WAC 173-201A, and two key EPA documents: Prothro (1993) attachment B from the Water Quality Standards Handbook, and The Metals Translator: Guidance For Calculating A Total Recoverable Permit Limit From A Dissolved Criterion (1996) (EPA 823-B-96-007). Covers minimum sample requirements (4 pairs at low flow per Prothro; 10 samples per EPA Metals Translator), TSS and K4 values from Technical Guidance Manual for Performing WLAs (1984) (EPA-440/4-84-020), laboratory WER-like studies, and the limitation that site-specific translators cannot influence permit limits like a WER but provide more accurate compliance measurement.

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As the source for federal transportation grants, the Puget Sound Regional Council was charged with developing a system to meet the growing need for commercial aviation. When the search for a second airport failed, they authorized the Port of Seattle to build the Third Runway, with a mandate to develop a noise abatement and mitigation program. In their effort to stop the Third Runway, the ACC argued over every detail of the Port's efforts--including property buyouts and sound insulation. The dispute was meant to be settled by a three member Expert Arbitration Panel. This is their final report. It finds 2-1, that the Port's program was insufficient in several respects. Despite that, funding for the Third Runway was approved by the PSRC, and the 'Port Package' program, proceeded largely unchanged. Expert Arbitration Panel's final decision finding that the Port of Seattle had not shown sufficient reduction in real on-the-ground noise impacts to satisfy noise reduction conditions required for approval of a third runway at Sea-Tac International Airport. The majority decision concluded the Port's noise abatement programs were insufficient despite being impressive in scope.

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