Notes
Exhibit 373 (AR 021382). Letter dated July 5, 2001, from John Strand of Columbia Biological Assessments to Muffy Walker (USACE Regulatory Branch), Gail Terzi (USACE), and Ann Kenny (Washington State Department of Ecology), on behalf of the Airport Communities Coalition (ACC). Documents evidence that Port Of Seattle accepted and transferred to Seattle-Tacoma International Airport (STIA) fill soil from Black River Quarry containing total petroleum hydrocarbons (TPH) as diesel and oil at concentrations of 310 and 200 mg/Kg — exceeding the MTCA Method A Soil Cleanup Level of 200 mg/Kg — and that subsequent transfers in September–October 2000 again revealed TPH exceedances of 222–270 mg/Kg. Strand argues the Port delayed reporting test results from June–July 2000 by nine to ten months (until the Beth Clark memo to Paul Agid, 4/30/2001), potentially to avoid action before the new 2000 mg/Kg TPH standard took effect August 15, 2001. Also cites elevated copper concentrations (77–110 mg/Kg), 51,849 CY (93,328 tons) of potentially contaminated fill transferred to STIA, presence of PCBs and DDT from Duwamish River dredged sediments, and possible TPH contamination from the First Avenue Bridge site. Argues Airfield Project Soil Fill Acceptance Criteria remain flawed and that CWA Sections 401 and 404 permit approval is unwarranted. References Public Notice 1996-4-02325.