EXH AR024560: Internal Email — Upstream Compliance Data, Miller Creek & Des Moines Creek

A 1999 internal email from Ken Ludwa to airport staff reports that upstream water quality data for Miller Creek and Des Moines Creek shows both streams exceed copper concentration standards, meaning neither is currently in compliance. The analysis suggests that applying a Water Effect Ratio (WER) adjustment of 2 or more for Des Moines Creek and 4 or more for Miller Creek could bring the streams into apparent compliance with water quality standards. The email also raises the possibility of conducting new clean sampling to potentially replace the existing non-compliant data.

Notes

Internal email dated June 1, 1999, from Ken Ludwa to Linda Logan and Paul Fendt (CC: Brian Pippin), analyzing upstream receiving stream compliance for Miller Creek and Des Moines Creek. Using Reasonable Potential Analysis methods, Ludwa calculated 90th percentile instream copper concentrations and compared them to standards based on 10th percentile hardness values. Neither stream is in compliance: Miller Creek shows 90th percentile copper of 16.4 against a standard of 4.3 (10th percentile hardness 23.0); Des Moines Creek shows 7.5 against a standard of 6.0 (hardness 33.0). Email discusses Water Effect Ratio (WER) thresholds — WER of 2 or more for Des Moines and 4 or more for Miller — needed to achieve compliance. Also references Stream Effects Study, de-icing upstream samples, King County and City of Des Moines reports as data sources. Suggests possibility of discarding prior data if clean sampling yields lower concentrations. Document AR024560 is part of PCHB Third Runway EIS administrative record.

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