Notes
Exhibit 371 (AR 021357–021359). Letter dated December 19, 2000, from J. Strand of Columbia Biological Assessments, Richland WA, retained by the Airport Communities Coalition (ACC — cities of Burien, Des Moines, Federal Way, Normandy Park, Tukwila, and Highline School District), to Charles E. Findley, Acting Regional Administrator, EPA Region X, responding to EPA’s October 20, 2000 letter to Christopher Gower regarding contaminated fill at Seattle-Tacoma International Airport (STIA) Third Runway project. Argues that MTCA Model Toxics Control Act Method A Soil Cleanup Levels are not fill standards and were misapplied by Port Of Seattle to screen candidate fill materials; critiques POS Airfield Project Soil Fill Acceptance Criteria as statistically inadequate; raises concerns about Hamm Creek dredge spoils, Miller Creek, groundwater contamination, wetlands, ecological risk assessment, First Avenue Bridge fill (85,000 CY accepted from WSDOT), and absence of USEPA Ecological Risk Assessment Framework analysis.