Notes
Exhibit 364 (AR 021318–021320). Letter dated December 13, 1999 from J. Strand of Columbia Biological Assessments, Richland WA, to Tom Luster, 401 Certification Coordinator, Washington Department of Ecology, on behalf of Citizens Against Sea-Tac Expansion (CASE). Evaluates whether Ecology has a scientifically adequate basis to certify compliance under Clean Water Act Section 401 for Port Of Seattle Public Notice Nos. 1996-4-02325 and 1999-4-02325 (STIA third runway/master plan). Finds violations of toxic substances criteria for copper and zinc in Miller Creek and Des Moines Creek from STIA stormwater outfalls under NPDES Permit No. WA-002465-1; copper concentrations 4.2–82.9 ug/l vs. EPA criterion 4.4 ug/l; zinc 15–525 ug/l vs. EPA criterion 33.7 ug/l. Critiques Port Of Seattle 1997 and 1999 stormwater monitoring reports, quality assurance failures, inadequate upstream sampling, lack of WET tests during de-icing events, absence of simulation modeling for detention basin effectiveness, and failure to support WAC 173-201A compliance. Recommends additional Industrial Waste System connections.