Notes
Second Declaration of Dr. Patrick Lucia (exhibit stamp dated 2-26-02) filed by Airport Communities Coalition (ACC) in support of motion for stay before the Pollution Control Hearings Board (PCHB), case nos. 01-133 and 01-160, challenging Section 401 Certification No. 1996-4-02325 (Amended-1) and CZMA concurrency statement issued by Washington Department of Ecology for the Sea-Tac Airport Third Runway embankment. Lucia argues Ecology lacks reasonable assurance that fill will meet environmental criteria and that water infiltrating through the embankment will not transport hazardous substances through the drainage layer. Addresses MTCA Method A cleanup levels for arsenic (20 mg/kg vs. Puget Sound natural background of 7 mg/kg per DOE Publication #94-115), cadmium, chromium, lead, mercury, nickel, antimony, selenium, and silver. Critiques Practical Quantitation Limits (PQL) used in certification per DOE Implementation Memo No. 3, WAC 173-340-900 Table 740-1, WAC 173-340-747(4), and the Port of Seattle’s sampling protocol as arbitrary and unscientific. AR022907–AR022909.