TagPollution Control Hearings Board(1507)

SR 518 LAKE _ ." / > ;i_• -J........._ USED TO AVOID - INTERCHANGE WETLAND IMPACTS IMPROVEMENTS _ :,, _', LAKE REBA i . MILLER CREEK .J _ _i!._i. _,.:" DETENTION FACILITY ....._.';,i_-:: -- (COMPLETED) LORA LAKE. _ . .. MSE RETAINING WALL USED TO MINIMIZE MSE RETAINING WALL IMPACTS TO USED TO MINIMIZE AND MILLER CREEK -_' WETLAND IMPACTS AIR CARGO RELOCATED SECTION _:_ FACILITIES.... _ RELOCATED S 154TH ST OF MILLER CREEK : '::i,."'_i._!/:.:. _.... ,. _ .. S 156TH ST LI_"::.;i_:L-S156TH ; :J _;_'!:" BRIDGE ' _r-;:_: !.T::_:_ _-...... _:''_" REPLACEMENT _:: _': r ,.h, RSAs "% MSE RETAINING WALL USED ,:i,.i:.!. AIR CARGO TO AVOID WETLANDS FACILITIES MILLER CREEK, AND TO • . NEW WATER TOWERPROVIDE MINIMUM 50-FT , BUFFER BETWEEN PERIMETER ROAD AND ;,..;:!; AIRBORNE CARGO ANDAIR TRAFFIC,J :'_...... MILLER CREEK ! /"i CONTROL TOWER ASR SITE ;_ /": j= NORTH; '- TERMINAL _=_!L',.I' "_"-'" ?'b i"_ " " NORTH ENTRY DRIVE /.:).. THIRD RUNWAY 0 . ADDITIONAL TAXlWAY , II EXITS ON 16LJ34RAND INTERCONNECTING TAXIWAYS ' " ' ! "_" "" . ,,, i _ GARAGE MSE RETAINING WALL USED .... i, '_ ; _.... TO MINIMIZE WETLAND " .... I,_ | i "' SOUTH TERMINAL IMPACTS . .'i! _ _i .. EXPANSION PROJECT SR 509 ' :'" "_ BOW LAKE TEMPORARY INTERCHANGE ! ......... i WEYERHAEUSER ' _.i. i.i _ _ SOUTH LINKHANGAR RELOCATION • ,, <. NORTHWEST ......... HANGAR IWS _. ,:. LAGOONS , i . . SASA DETENTION ..... ! '…

Dear Colonel Graves, Ms. Walker and Ms. Terzi: Re: Corps Ref:.No. 1996-4-02325; Port of Seattle Document Inconsistencies + As you know, Northwest Hydraulic Consultants has been retained on behalf of the Airport Communities Coalition (ACC) to provide a technical review of stormwater facilities and streamfiow impacts from development activities at SeaTac airport. The purpose of this letter is to identify inconsistencies in the Port's proposals for site development and stormwater management. It supplements our prior letters anddeclarations in this matter, the latest of which is our November 26, 2001, letter to you. Since our last letter, numerous additional documents relating to the airport development activities have been obtained by ACC public disclosure requests. This letter focuses on the two documents identified below. - Port of Seattle - Commission Agenda Item No. 8a for Meeting on November 13, 2001. Memorandum dated October 16, 2001 regarding Resolution No. 3469, agreements between the Port of Seattle and the City of SeaTac for use and redevelopment of borrow areas 3 and 4 on Port property within the City. A copy of that memorandum is enclosed for reference. "Natural R,esource Mitigation Plan, Seattle-Tacoma International Airport, Master Plan Update Improvements,"November 2001, prepared by Parametrix, Inc. for Port of Seattle. Please note that this letter does not reflect a detailed review of the project Natural Resource Mitigation Plan (NRMP). In particular, the November 2001 version of the NR,MP does not • adequately address or resolve our previously-expressed concerns over the water-holding capability of the relocatedMiller Creek channel,or…

-Nov-Z6-OZ 04:4b_ nor;nwes; n_araUllC consu _UO *J_ _ " northwest hydraulic consultants inc. .-. sacramento 16300 ¢hriatensenroad, suite 350 seattle, washington 98188-3418 vancouver (206) 241-6000 - phone edmonton (206) 439-2420 - fax seattlewww.nhcweb.com November 26, 2001 Colonel Ralph H. Graves Ms. Muffy Walker Ms. Gall Ter-zi U.S. Army Corps of Engineers Seattle District P. O. Box 3755 Seattle, WA 98124-3755 Dear Colonel Graves, Ms. Walker and Ms. Terzi: Re: Corps Ref. No. 1996--4-02325: Port of Seattle Low Flow Mitigation As you know, Northwest Hydraulic Consultants has been retained on behalf of the Airport Communities Coalition (ACC) to provide a teclmicai review of stormwater facilities and streamflow impacts from development activities at SeaTac airport. The main purpose of this letter is to serve as a reminder that there are numerous substantive deficiencies and uncertainties in the Port's proposed plans for low flow mitigation in Miller, Walker, and Des Moines Creeks. This letter is also intended to identify an additional serious deficiency which we have not addressed previously, but which is evident from documents recently obtained by the ACC Our previous comments in this matter are already on record and remain unresolved. The most recent of those comments are in the form of legal declarations by William Rozeboom and are cited in Peter Eglick's letter to you dated November 16, 2001. Now, as then, public comment is forced to rely on incomplete draft documents. In the case of the Port's Low Flow Analysis, the documentation of the evaluation continues to be so…

• m_txation rate s-_I/ng and monitoring to evaluate performance of the fi.I/ • establis_t of continSellcymeasureshi cue fill doesn_[ mccrperformancestandards L Operational Stormwater Requ/rements: Aooroved_Storrnwaterplan: The Comprehensive Stormwater Managcnz'nt Plan, Volumes I throu_ 4, December 2000 as revised by the July 2001 Replacement pages'is the approved SrmTnwaun-rn_nagement plan for this project. It shall be implemented in its entirety. No changes to the plan shall be n".ade wlthout prior review and approval, The Port shall provide Ecology with dr_ proposed changes to the Plan no la_ than 60 days Fcior to the date it wishes to implement a change to the plan. The Port shall ;mplement the project in accÙ_ w/th the sched_e provided il_ Table A-3 (July 2001). Any changes to the schedule must be reviewed _9,4approved in advance by Ecolop,y. The Pot'..',_.:LI provide Ecology with • dr_ revised schedule no later l_}an60 days prior to the dale it wishes ,._ i.mplcmcntthe chanSc to the schedule. The following faci]ities/pmjecu listed ia Table A-? ",uly 2001) do not have yet have smrmwatcr creaunentfacilities proposed: XXX. If the Port decides to build a:;/.Jr these facillties/project the Port must submitconcelmaaldrawings that meet the performance s:_ -_-_--",_f the CSMP to Ecology for review and approval P..cu-ofit_ingof stormwater management facd/ties at the STIA shall oc__m"at • rate cornm_surate with the construction of new impervious surface at the STIA. For evegy ten percent of new impervious sm:,_cc added at the project site, the Portumst demonstrate that au equal 10 percent of retmt_¢qng has oe_,.rred. • _-…

-- _.g co,,.w R E C E I V E D Department of Natural Resources D=recmr's Olficc ,,,_.,_.,.,c,.,,,., AUG - 2 ZOO1 201 _ =ulh.Jack._mStreet,Suite700 _.,,,,_.w._:,M,_-._s OEPT OF ECOLOG" August 3, 2001 Ann Keuny, Senior Permit Specialist Washington Departmentof Ecology NorthwestRegionalOffice 3190 - 160th Avenue Southeast Bellevue, WA 98008-54552 Dear Ms. Kenny: KingCounty is pleased to have had the opportunity to assist the Depa_taient of Ecology by making its technical review capacity and knowledge of local stormwater conditions available for the review of the Port of Seattle's Comprehensive Stormwater Management Plan (SNIP) for Master Plan Improvements at SeaTac International Airport. This effort has set an excellent example of how state and local government can work cooperatively in addressing pressing issues facing the region. As with our previous reviews ofthis project, it is importantto keep in mind the limitations of the work that we have performed. First, this review is limited to ascertaining whether the SMP attained minimum compliance with the 1998 King County Surface Water Design Manual. Compliance with the technical provisions of the Design Manual does not mitigate all potential impacts of development and may not provide sufficient information to allow for approval under other codes andregulations. Compliance with the Design Manual is, however, a good start towards mitigating the impacts of this large and complex project. It is also importantto remember that this review is limited to those development activities identified by the Portof Seattle as being Master Plan Update Improvements. While other projects of varyingmagnitude arebeing proposed…

As required by its current NPDES Permit, the Port has monitored the stormwater quality from its SDS outfalls since 1995. Overall, the data show that the concentrations of various constituents in STIA stormwater are generally less than those in runoff fi'om other residential, urban, and irdustrial areas in the region (Table 4-8). For example, the median concentrations for STIA constituents (column 3) are lower than those in urban stormwater (columns 5 and 6), with the exception of total recoverable copper. These data provide evidence for the efficacy of BMPs that have been implemented by the Pt_rt over a number of years. The following sections provide a brief description for each constituent category. Table 4-8. Seattle-Tacoma International Airport runoff quality (1994-2000) compared to regional and national urban stormwater quafity studies" (from Port of Seattle 2000b). (1) (2) (3) (4) (5) (6) (7) (8) (9) (lo) Bellevue: Bellevue: STIA: STIA: SturtevantCreek¢ BUR_ King County: NURph: Portland Freeway RW/TWb All Data (log-normal (mean, (Metro1982) (EPA 1983) NPDESi Runoff Constituent Units (median) (median) median) median) (mean) (median) (median) (mean) FOG mg/L 0.5 i.0 3.7 2.5 7.8 - - 30r TPH mg/L 0.08 0.Y 3.7 - - - 6.5 - Fecal mptV 14 42 201 980 - 1000to - - coliforrm !00ml 21000 BOD mg/L 5.0 6.0 - 6.6 - 9 20 - TSS mg/L 9 17 82.3 50 - 100 119 106s ' Turbidity mg/L 7 13 29.4 19 .... NH3d mg/L 0.03 0.1 0.58 0.17 .... Cu (TR) pg/L 26 25 i 0.4…

I. I am a Senior Engineer employed by the King County Department of Natural Resources. I have held that position since June I, 1994. My duties include the development and maintenance of an HSPF based continuous hydrologic computer model, development and implementation of stormwater regulations, basin plan implementation, development of subbasin compliance program, preparation of engineering studies of complex drainage problems, training and technical support on hydrologic/hydraulic modeling and mitigations for review engineers, designers, hydrologists, and regulators from other jurisdictions (e.g., Ecology, local cities), and lead technical staff for development of the 1998 King County Surface Water Design Manual (Manual). I also provided technical support for Ecology's 2001 stormwater manual update. I have I ] years of experience in stormwater management DECLARATIONOFKELLYWHITING l ATTORNEYGENERALOFWASHINGTON EcologyDivtsion PO Box 40117 Olymp_L WA 98504-0117 FAX (360) 586-6760 ,J,J .... AR 017535 including the review of stormwater management plans for compliance with the Manual. My educational background is a Bachelor of Science in Civil Engineering, University of Washington, 1990. I am a licensed professional civil engineer in Washington State with expertise in hydrology and surface water management. 2. Pursuant to a contract between the Department of Ecology and King County,, I reviewed the Port of Seattle's (Port) Comprehensive Stormwater Management Plan (SNIP) for Master Plan Update Improvements at SeaTac International Airport (STIA) on behalf of Ecology. I also reviewed the Port's Low Flow Impact Analysis-Low Flow Impact Offset Facility. proposal dated December 2000 and updated July 2001 on behalf of Ecology (Low Flow Plan).…

WAC AKART shall represent the most current methodology that173-201A-010 Introduction. 173-201A-020 Definitions. cat. be reasonably required for preventing, controlling, or 173-201A-030 Generalwateruseandcriteriaclasses, abating the pollutants associated with a discharge. The con- 173-201A4)40 Toxicsubstances, cept of AKART applies to both point and nonpoint sources of173.201A-050 Radioactivesubstances• 173-201A-060 Generalconsiderations, pollution. The term "best management practices." typically 173-201A-070 Antidegradation. applied to nonpoint source pollution controls is considered a !73-201A-080 Outstandingresourcewaters. I73-201A-100 Mixingzones, subset of the AKART requirement. "The Stormwater Man- 173-20lA-110 Short-termmodifications, agement/Vlanual for the Puget Sound Basin" (1992), may be 173-201A-120 Generalclassifications, used as a guideline, to the extent appropriate, for developing173-201A-130 Speciticclassifications--Freshwater. 173-201A-140 Specificclassifications--blannewater, best management practices to apply AKART for storm water 173-20iA-150 Achievementconsiderations, discharges. 173-201A-160 Implementation. [73-201A-170• Surveillance. "Background conditions" means the biological, chemi- 173-201A-180 Enforcement. cal. and physical conditions of a water body, outside the area of influence of the discharge under consideration. Back- WAC 173-201A-010 Introduction. (1) The purpose of ground sampling locations in an enforcement action would be this chapter is to establish water quality standards for surface up-gradient or outside the area of influence of the discharge, waters of the state of Washington consistent with public If several discharges to any water body exist, and enforce- health and public enjoyment thereof, and the propagation and ment action is being taken for possible violations to the stan- protection of fish, shellfish, and wildlife, pursuant to the pro- dards, background sampling would be undertaken immedi- visions of chapter 90.48 RCW and the policies and purposes ately up-gradient…

WAC 173-340-740 Unrestricted land use (vi) Concentrations that eliminate or minimize soil cleanup standards, the potential for the accumulation of vapors in (1) General considerations, buildings or other structures. (a) Presumed exposure scenario soil cleanup (d) Relationship between soil cleanup levels levels shall be based on estimates of the reason- and other cleanup standards. Soil cleanup levels able maximum exposure expected to occur under shall be established at concentrations that do not both current and future site use conditions. The directly or indirectly cause violations of ground department has determined that residential land water, surface water, sediment, or air cleanup use is generally the site use requiring the most standards established under this chapter or protective cleanup levels and that exposure to applicable state and federal laws. A property that hazardous substances under residential land use qualifies for a Method C soil cleanup level under conditions represents the reasonable maximum WAC 173-340-745 does not necessarily qualify exposure scenario. Unless a site qualifies for use for a Method C cleanup level in other media. of an industrial soil cleanup level under WAC Each medium must be evaluated separately using 173-340-745, soil cleanup levels shall use this the criteria applicable to that medium. presumed exposure scenario and be established in (2) Method A soil cleanup levels for unre- accordance with this section, stricted land use. (b) In the event of a release of a hazardous (a) Applicability. Method A soil cleanup substance to the soil at a site, a cleanup action levels…

Please title this page. (Page I) Page I of 4 _ Re_t__urn.to PQL/MCL Index Table ',5 7/ GUIDANCE FOR THE USE OF TABLES: I/-,4'r__ PRACTICAL QUANTITATION LIMITS (PQLS), METHOD DETECTION LIMIT (MDLS), AND PQL COMPARISONS TO METHOD B CLEANUP LEVELS This guidance is Pan II of four pans. They are: Part I: Implementation Memo No. 3--pQLs as Cleanup Standards Part II: Guidance For The Use of Tables (this document) Pan III: MDL, PQL, and Comparisons Tables Pan IV: Appendix--Meaning of Quantitation Limits The Model Toxics Control Act (MTCA) provides human health risk-based cleanup levels for contaminants at cleanup sites. For certain compounds the risk-based values (Method B values) are less than the lowest levels which can be routinely quantified and reported by a laboratory. These lowest levels are known as the "practical quantitation limits" (PQLs). The "method detection limit" (MDL) is used mostly by the laboratory analyst and not usually reported, but can provide useful information to the site manager. To provide a cleanup site manager with information on PQLs and the MDLs, we prepared tables of these values including a comparison to the MTCA Method B levels. The MDL and/or PQL for a substance can be useful when requesting analytical work to verify it is possible to achieve the desired analytical limit. With information in these tables about the MDLs and PQLs for different analytical methods the site manager can choose the appropriate method and avoid wasteful analytical work that does not provide the desired limit. The site manager…