TagPollution Control Hearings Board(1507)

Integration of HSPF Model with Hydrus and Slice Models ............................ 3 Calibration .................................................................................................................... 4 Miller Creek Low Streamflow Calibration ....................................................... 5 Walker Creek Low Streamflow Calibration ............. 6 AR 015849 PREFILED TESTIMONY OF JOSEPH BRASCHER BROWN REAVIS & MANNING PLLC 1191 SECONDAVE., SUITE2200 PAGE i SEATTLE,WA 98101 ORIGINAL (206) 292-6300 Page Low Streamflow Analysis ............................................................................................ 9 Determination of Low Streamflow Periods ...................................................... 9 Determination of Existing Summer Low Streamflows ...................................... 9 Embankment Modeling ................................................................................................. 9 HSPF Input and Runoff Calculations ............................................................. 10 Effective Recharge .......................................................................................... 11 Incorporation of Hydrus/Slice into HSPF Models ..................................................... 12 Miller Creek .................................................................................................... 12 Walker Creek .................................................................................................. 13 Results of Analysis .................................................................................................... 14 AR 015850 PREFILED TESTIMONY OF JOSEPH BRASCHER BROWN REAVIS & MANNING PLLC 1191 SECONDAVE., SUITE2200 PAGE ii SEATTLE, WA 98101 (206) 292-6300 1. I have personal knowledge of the facts stated in this testimony and would be competent to testify to those facts. BACKGROUND Current Position and Experience 2. I have been employed by AQUA TERRA Consultants for almost nine years, since May 1993. My responsibilities with the firm currently include, project management, hydrologic analysis and computer programming, in addition to management of the Olympia satellite office. Prior to beginning my employment with AQUA TERRA, I was employed by the City of Olympia Surface Water Department as temporary technician from June 1991 until April 1993. My duties included hydrologic model review and model application. From May 1992 until April 1993, I worked for the Thurston County Water and Waste Management division, where my…

1. I am over the age of eighteen, have personalknowledge of the facts stated in this declarationand wouldbe competent to testify to them if necessary. 2. ] have more than ]8 years of stormwater engineeringand planning experience, encompassinga broadrange of stormwater and surfacewater projects. I have significant experience workingwith hydrologicanti hydraulic modeling (HEC-1, WaterWorks, HEC-2, HEC-RAS), NPDES stormwaterpermits, erosion control on creeks and lake shores, comprehensive storm and surfacewater plans, preparation of drainageordinancesand environmental impact statements. I have worked extensivelywith the Departmentof Ecology's StormwaterManuals and with King County's Surface WaterDesign Manual. DECLARATION OF PAUL S. FENDT - 1 FOSTER PEPPER _ SHEFELMA.NPLLC 1111 TlizxDAvl_Nu_.,8vrr_:]400 S_Tnut, Wmi_m_'roN 98101-3299 206-447-4400 ,.,'02712M06 AF:I0"19866 3. I havebeen the projectmanager for stonnwatermanagement and low flow mitigation for thePort of Seattle's Master PlanUpdate (MPU)projectsfor the past four years. I was the principalauthorof the Port of Seattle's ComprehensiveStormwaterManagement Plan and a principalauthor of the Low Flow Analysis- Flow Impact Offset Facility Proposal ("Low Flow Analysis"). I graduated from theUniversityof North Dakota with a degree in Geological Engineeringin 1981. I was licensedas aProfessional Engineer (Civil) by the State of Washington in January1991 and the State of Floridain February 1990. I havebeen employed by Parametrix, Inc, for the past 11years. A copy of my current curriculumvitae is attached to this declarationas Exhibit A. 4. Sea-Tat InternationalAirport (STIA) lles along the drainage divide between the Miller CreekandDes Moines Creek watersheds (See Figure 6.1-1 in the Port's Natural Resources _.2 MitigationPlan). The Miller Creekwatershedcovers approximately 8.1 square miles of t3 predominantlyurban…

• From: Kmet. Peter | 1_," 1"7_0 / - Sent: Wednesday, June 27, 2001 4:01 PM • M. Green To: Fitzpatrick, Kevin Cc: Yee, Chung K. Subject: RE" Acceptable Fill Criteria Language for Draft 401 Certification DELIBERATIVE DOCUMENT CURRENTLY EXEMPT FROM PUBLIC DISCLOSURE If we are not going to restrict fill material to naturally occurring uncontaminated soils, I recommend you use the following language to address potential impacts on plants and animals. The intent of this language is to ensure the fill material used would be "clean enough" that itwouldnotbe expectedto causeadverseimpactson plantsandanimalsthatcome in contactwithit. Notethatthisdoes notaddresspotentialhumanhealthexposurepathwaysor protectionof aquatic organisms,whichwillneed to be addressedwithotherlanguage. There are severalelementsto thisrecommendation: First,isthe listof chemicalsof concern. I am recommendingwe usethe listinTable 749-3. While lengthy,thislistrepresentsthe morecommonlyoccurringcontaminantsthat have informationon potentialterrestrialecologicalimpacts. Onlythosesuspectedof beingpresentat the sitewouldhave to be testedbeyondthoseyouare alreadyspecifyingtheytest for. Second,I am recommendingwe requirethe fill materialto meetthe moststringentvalue inTable 749-3 unlessbioassaytestingis conductedthat demonstratesthe fillis nottoxicto plantsand animals. The table749-3 valuesare consideredscreeningvaluesfor ecologicallysensitivesites. Third,asa furthersafeguard,I am recommendingthatthe uppermost6 feet of fillplaced be required to be cleannaturalsoil. Thisisthe zonewhere mostsoilbiologicalactivityoccursandwillprovidea bufferzone thatpreventsmostplantandanimalcontactwithanydeepercontaminatedfill material. It shouldalsominimizethe potentialforworkercontactduringroutineconstructionand maintenance activitiesat the airport. Fourth,becausetherecanbe considerablevari_.bilityinsoilconcentrationsand it is notpossibleto testeverycubicinchof soil,I am recommendingthatthe statisticaltestmethodsspecifiedforsoilsin WAC 173-340-740be usedto analyzeany testdata anddemonstratecompliancewiththese requirements. Here ismysuggestedlanguage: The uppermost6 feet of fill materialshallconsistof cleannaturallyoccurringsoilwithnodetectable manmadeorganiccompoundsand nometalsabovenaturalbackgroundconcentrationsasdefinedin Ecologypublication#94-115 entitled"Natural BackgroundSoil Metals ConcentrationsinWashington State". All other fill material not consisting of such clean naturally occurring soil shall be subjectto the following requirements. All fill material nc.tfrom clean natural soil borrow sources shall be tested for at a minimum [insert your…

" Return to the Site Cleanup home_page DEPARTMENT OF ECOLOGY _ ,_v,.,_^ _/_.,_ Return to the PQL/MCL Index Table November 24, 1993 Implementation Memo No. 3 TO: Interested Staff FROM: Steve Robb Toxics Cleanup Program SUBJECT: PQLs as Cleanup Standards ISSUES Two issues have been raised with regard to the use of practical quantitation limits (PQLs) in setting cleanup levels: • The "legal" issue of PQLs as cleanup levels and whether or not PLPs have any long=term liability for sites cleaned up to the PQL level rather than the risk-based level. Can PLPs receive a covenant not to sue in these situations? Are they required to utilize institutional controls and conduct long-term monitoring? • When risk-based compliance values are less than PQLs, what value is used in the risk summation calculation, the risk-based value or the PQL? I. LONG-TERM LIABIL/TY The Model Toxics Control Act (MTCA) states, "Where cleanup levels are below the PQL, compliance with cleanup standards will be based upon the PQL" (WAC 173-340-700(6) Measuring compliance). Also stated in the rule, "If those situations arise and the practical quantitation limit is higher than the cleanup level for that substance, the cleanup level shall be considered to have been attained, subject to subsection (4) of this section..." (WAC 173-340-707(2) Analytical considerations). Therefore, the PQL becomes the compliance value, and PLPs who attain the PQL are eligible for a covenant not to sue. WAC 173-340-707(4) places one additional burden, however, and that is a requirement for periodic review of the…

1. Draft Fill Criteria requirements for the 401 Water Quality Certification for the SeaTac Third Runway Embankment project. Oean FillCriteria for 401 C..e... 2. Spreadsheet derivingthe surface water ciJalitycriteria needed for the three-phase model calculations for soilcleanup levels for the protectionof surface water. seate_xls 3. Spreadsheet deriving the ground water cleanup levels, the three-phase model calculationsfor soil cleanup levelsfor the protection of groundwater, and the three-phase model calculations for soil cleanup levels for the protection of surface water. Three-Phase Hodel.xL_ 4. A summarytable showing the various soil cleanup levels, natural background concentrations, and PQLs. Hazardous Subs_nces.doc The fill criteriarequirements have been developed usir,g the Amendod MTCA. I have included relevant sectionsof the regulation into the developmentof the fill criteria. Specifically, I have Jeveloped fill criteriabased on the Method A Soil Cleanup Levels (Table 740-1); derived soil cleanul:: levels using the three-phase model in WAC 173-340-747 first for the protectionof ground water and second for the protectionof surface water; reviewed soil concentrations presented in Table 749-2 ! AR 017310 u,,,I._:,_11 _._.'.,: (ecological standards), reviewed natural backgroundsoil metals concentrations:and reviewed PQL values for the metals under consideration.The listing of metals being proposed for the fill criteria is based on 40 CFR Part 122 Appendix D Table III (Other Toxics Pollutants). These are required monitoring parameters for the NPDES program. The bases for the fill criteriaare: 1. Use Method A (Table 740-1 ) values if available. 2. If not, use the lowervalue of Method B, protection of either ground water or surface water.…

v. ) NOS. 1-6TO PORT OF SFATTLE ) PORT OF SEATTLE'S OBJECTIONS STATE OF WASIIINGTON ) AND RESPONSES TI_.RETO DEPARTMENT OF ECOLOGY, and ) THE PORT OF SEATTLE, ) ) Respondents. ) The Port of Seattle ("Port"), by and through its counsel of record, submits the following objections and responses to ACC's Interrogatories Nos. 1-19 and Requests for Production Nos. 1-6 to Port of Seattle ("ACC's First Requests"). To set off the Port's objections and responses from the text of the ACC's First Requests, the Port's objections and responses wili_be set forth in bolded and single-spaced text. The Port will interpose its General Objections to ACC's First Requests prior to providing particalarized objections and responses to any individual interrogatory or request for production propounded by ACC. The fact that a particular general objection is not identified in response to a particular interrogatory should not be interpreted as a waiver of20 any general objection; furthermore, nothing set out in specific objections constitutes a waiver of any general objections. TO: PORT OF SEATTLE ("Port");23 AND TO ITS COUNSEL: Jay Manning and Gillis Reavis, Marten Brown, Inc.; Roger Pearce and Steven Jones, Foster Pepper & Shefelman; Linda Snout and Tmvi Goodwin, Port of Seattle ACC'SINTERROGATORIESANDREQUESTSFOR FOSTERPEPPER_' SHEFELMANPLIJ2 PRODUCTIONNOS.1-6TOPORTOFSEATTLEAND lZZlTRInDAv_t_ $U1_3400 PORT,SOBJECTIONSANDRESPONS_ G _ F_,,._ S_rr_ W_sms_roN,S,ez.32_2e644,44eo • " AN 019840 INSTRUCTIONS Interrogatories. Pursuant to the PCHB's October 30, 2001, Preheating Order and to Civil Rules 26 and 33, you are requested to answer the following interrogatories in writing and under oath and, aRer…

FLAC is a Suitable Tool for Use as a Check on Design ................................... 16 The Port's Analysis of Liquefaction is Consistent with Generally Accepted Engineering Practices ............................................................ 17 Subgrade Improvement Construction Plans Avoid Off-Site Wetland Impacts ................................................................................... 18 Construction Plans Have Incorporated Means to Prevent Surficial Instability ............................................................................... 19 The Embankment Underdrain Will Not Reduce Existing Baseflow or Provide a Conduit for Pollution Migration ...................... 19 Gradation of the Underdrain Protects it From Clogging ................................... 20 CONCLUSION ............................................................................................................ 21 AR 015778 PREFILED TESTIMONY OF MICHAEL BAILEY, P.E. BROWN REAVIS & MANNING PLLC PAGE ii 1191 SECONDAVE., SUITE2200 SEATTLE,WA 98101 (206) 292-6300 1. I have personal knowledge of the facts stated in this testimony and would be competent to testify to those facts. INTRODUCTION 2. I am the Project Manager for geotechnical engineering for the Port of Seattle's Third Runway Project. I am a registered Professional Engineer in Washington and a Senior Principal with the Seattle-based firm Hart Crowser, Inc., which is a sub-consultant to the lead design firm, HNTB Corporation. A copy of my curriculum vitae is attached as Exhibit A. SUMMARY OF OPINIONS 3. The purpose of this testimony is to describe the extensive design process for the Third Runway embankment and MSE walls, a process in which the Port of Seattle has relied on reputable engineering firms, a technical review board consisting of internationally recognized experts, a national building code, and independent methods of confirmatory analysis that go beyond requirements of the code. The Port's design team established…

Sent: Tuesday, June 26, 2001 1:07 PM £o: Fitzpatrick. Kevin C¢: Thompson, Craig E.; Kenny, Ann Subject: Acceptable Fill Criteria Language for Draft 401 Certification DELIBERATIVE DOCUMENT CURRENTLY EXEMPT FROM PUBLIC DISCLOSURE Attached is the draft fillcriterialanguage.I havemade majormodificationsto the initialdraft.However,I didnotchangethe soilsamplingschedulebecauseIdon't havethe properbasis.The TCP'srecommendedsamplingscheduleforpetroleum- contaminatedsoilmay tooexcessivefor thisprojectgiventhe quantityof thefill. The fillcriteriaare basedon:MethodA table,3-phasemodel protectionof ground water,3-phasemodelprotectionof surfacewater,PQL, naturalbackgroundinPuget Sound,and/orTerrestrialEcologicalEvaluationtable Pleasereviewandcomment.Afteryourcomments,I willforwardthe reviseddraftto the HQ TCP Policyfor review. Things-to-do:Iwillneedto doublecheckthe calculationsand puttogethera supportingdocumentforthe abovedraft. Pleasenote,becauseof the workload,I haveshotpassthe initial3-dayprojection. CleanRIICrKeria for401Ce... AR 017305 ! I1()l_ 8,.g, lll 11"72 t Draft E6. Borrow Sites The use of imported fill for the proposed Third Runway embankment may result in impacts to wetlands or other waters of the state, fo ensure compliance with measures designed to minimize potential impacts, the Port of Seattle shall submit borrow site clean fill certification documentation described in the following sections to the Department of Ecology for review and approval prior to fill placement. E7. Fill Source/Documentation/Fill Criteria The Port of Seattle shall adhere to the following conditions to ensure that the fill placed fortheproposedThirdRunwayembankmentdoesnotcontaintoxicmaterialsintoxic amounts. EVa. Fill Sources Fill materials for the proposed Third Runway embankment shall be limited to the following three sources: • State.certified borrow pits • Contractor-certified construction sites • Port of Seattle-owned properties. E7b. Documentation No laterthan two (2) business days priorto the acceptance of fill materials for the proposed Third Runway embankment, the Port of Seattle shall submit to the Department of Ecology's Northwest Regional Office Water Quality Program for review…

From: Yee, Chung K. [ |_ent: Tuesday, June 19, 2001 11:29 AM ro: Fitzpatrick, Kevin Co: Thompson, Craig E. Subject: RE: Acceptable Fill Criteria Language for Draft 401 Certification I'm in the processof going through the cleanup levels presented in the BiologicalOpinion. I could not come up with the same numbers. Called FWS and was told the numbers came from the Port. Can I callthe Port? If yes, can you please give me the name/phone number. Thanks ..... OriginalMessage-.... From: Fitzpatrick,Kewn Sent: Tuesday,June 19, 2001 10:16 AM To: Yee,ChungK. Subject: RE:AcceptableF'qlCriteriaLanguagefor Draft401 Cer'dfication The down-gradient grour, d water, though not currently used as a drinking water source, could be used as a drinking water source and would need to be protected as such. ---Original M____--- From: Yee,(:hungK. Sent: Tuesday,June19, 2001 9:56 To: Fitzpatrick,Kevin Subject: RE:AcceptableFillCriteriaLanguageforDraft 401 Cer'dficatlon Thanks. of the fill site being/can be/will be used as drinkingwater?Is the groundwater down-gradient ----Original Message--- From: Rtzpatrick,Kevtn Sent: Monday,June 18, 2001 10:46AM To: Yee,ChungK. Co: Kenny,Ann; Marchioro,Joan(AT(;) Subject= RE:AcceptableFillOite,;a Languagefor Draft401 CertifiCatmn Chung Yee - From discussions with Ann Kenny and AAG Joan Marchioro, I have learned that it is Ecology's intent for acceptable fill criteria in the 401 WQ Certification to "stand alone" from what US FWS issued on fill material in its Biological Opinion. US FWS is using its authority under ESA to mitigate and minimize any harmful impacts from the project to endangered or threatened species. We're trying to generate requirements in the 401 that provide reasonable assurance that…

Co: Thompson, Craig E.; Dahlgren, Curtis A.: Nord, Tim Subject: Acceptable Fill Criteria Language for Draft 401 Certificatwon DELIBERATIVEDOCUMENTCURRENTLYEXEMPTFROMPUBLICDISCLOSURE On Monday June 11, Mr. Craig Thompson had a limited discussionwith Mr. Pete Kmet of the HQ/TCP on this project. Mr. Kmet recommended MTCA should not be used for the establishment of clean-fillcriteria for the Seattle-Tacoma International Airport Third Runway project. However, if MTCA is to be used for this purpose, Mr. Kmet further recommended all other requirements of the MTCA should be applied for the establishmentof the clean fill criteria. have interpreted his MTCA requirementsat minimum as requiring: 1) a larger listingof potential contaminants for testing, 2) groundwater monitoring for compliance with the groundwater and/or surface water criteria,and 2) terrestrialecologicalevaluation. There may be other requirements that will need to be identified priorto finalizingthe "Acceptable Fill Criteria Language." Since his recommendationsare consideredas the department policywith respect to this project, therefore it would be inappropriate for me to comment on his recommendations. Please advise as to my scope-of-work. In the interim, I will proceed to review the biological opinion by US Fish and Wildlife Service on the MasterPlan Update Improvements. From your previous emails, I understand you/NWRO will be meeting with the US Fish and Wildlife Service to finalize an acceptable set of fill criteria.Per agreement, I will start my review of the Clean Fill Criteria based on the most recent draft language, i.e., post US Fish and Wildlife Service meeting. One final note, I do not know howto implement many of…