TagPollution Control Hearings Board

Subject: Approval process for stormwatar management plan for proposed 3rd runway development actions at Seattle-Tacoma International Airport. NorthwestHydraulicConsultants(nhc)hasbeenretainedon behalfoftheAirportCommunitiesCoalitiontoprovide a technical review of stormwater facilities and related streamflow impacts from the proposed 3rd runway development at SeaTac airport. By a letter dated November 24, 1999, we provided our imdal comments from our technical review of documents describing the Stormwater Management Plan (SMP) for Master Plan Update Improvements at Seattle-Tacoma International Aurport. By a letter dated May 3, 2000, we provided follow-up comments resulting from our technical review of additional materials which were not available at the date of the initial review. The purpose of this letter is to remind you that the numerous substantial comments raised by us and by others have, to our knowledge, not yet been satisfactorily addressed, and to express concern over what has become a closed-doordesignreviewprocess. IndependenttechnicalreviewsbyotherexpertsundercontracttotheDepartmentofEcologyhaveconsistently corroboratedourconcerns.A linuted-scopereviewby PacificGroundwaterGroupIfoundserious"'fundamental questions"inthehydrologicmodelingwhich,ifleftuncorrected,wouldhaveledtotheconstructionoffacilities whichwouldbegenerallyundersizedand wouldnotachievetherequiredlevelsofflowcontrol.A broader-scope reviewbyKing Countyof"techmcar'issuesidentifiednumerousspecificproblemsbeforeevenconsideringthe mssucofhydrologicmodelcalibrationwhichseemstohavesincebecome themain focusofSMP revisions. A largenumberofsubstantiveissuesand concernshavebeenraisedwhichallneedtobeaddressedifthereistobe confidencem theSMP asadesigndocumentwhichwillaccomplishtheregulatorygoalsofflowcontroland environmentalprotection.Copiesofourpreviouscomment lettersareenclosedforreference.To ourknowledge, substantiallyallofourpreviouscomments remainunresolvedatthistime. The very limited mformation which has been disclosed from the King County review oftbe SMP indicates that King County has also raised numerous additional specific concerns which, to our knowledge, are also unresolved at this time. We refer in particular to an I i-page document with draft preliminary review comments dated 4/5/2000 which is in the files of both the Corps and Ecology and which was obtained by the ACC through public information disclosurerequests.Itshouldbcnotedthatthe4/5/2000documentdoesnotdealatallwithmodel calibration,which was firstralsedbyusasa majorconcernvlaemailtoconcernedpartieson 4/4/2000.We understandfrom verbal _Sea-Tac Runway Fill Hydrologic…

"- 16300 christensenroad, suite350 vancouver |EXHIBIT NO_| seattle, washington98188-3418 edmonton I "_- 5- o-_.._ | (206)(206)439-2420241"6000--laxPh°ne seattle • M. Green W July 31, 2000 U.S. Army Corps of Engineers Regulatory Branch Post Office Box 3755 Seattle, Washington 98124-2255 ATTN: Jonathan Freedman, Project Manager Washington State Department of Ecology Permit and Coordination Unit Post Office Box 47600 Olympia, Washington 98504-7001 ATTN: Tom R. Luster, Environmental Specialist Subject: Approval process for stormwater management plan for proposed 3rd runway ..... development actions at Seattle-Tacoma International Airport. Northwest Hydraulic Consultants (nhc) has been retained on behalf of the Airport Communities Coalitionto provide a technical review of stormwater facilities and related streamflow impacts from the proposed 3rd runwaydevelopment at SeaTac airport. By a letter dated November 24, 1999, we provided our initial comments from our technical review of documents describing the Stormwater Management Plan (SMP) for Master Plan Update Improvements at Seattle-Tacoma International Airport. By a letter dated May 3, 2000, we provided follow-up comments resulting from our technical review of additionalmaterials which were not availableat the date of the initial review. The purpose of this letter is to remind you that the numerous substantial comments raised by us and by ." others have, to our knowledge, not yet been satisfactorily addressed, and to express concern over what has become a closed-door design review process. Independenttechnicalreviewsby otherexpertsundercontractto the Departmentof Ecologyhave consistentlycorroboratedour concerns. A limited-scopereview by Pacific GroundwaterCroup1 foundserious"fundamentalquestions"in thehydrologicmodelingwhich, if leftuncorrected,would haveledto theconstructionof facilitieswhich would be generallyundersizedandwould not achieve the requiredlevelsof flow control. A broader-scopereview…

Subject: Follow-up comments on stormwater management plan for proposed 3rd runway development actions at Seattle-Tacoma International Airport. Northwest Hydraulic Consultants (nhc) has been retained' on behalf of the Airport Communities Coalition to provide a technical review of stormwater facilities and related streamfiow impacts from the proposed 3rd runway development at SeaTac airport. By a letter dated November 24, 1999, we provided our initial comments from a technical review of documents describing the Stormwater Management Plan (SMP) for Master Plan Update Improvements at Seattle-Tacoma International Airport. Responses to public comments, including those submitted by nhc, were made in a document dated March 10, 2000, by or on behalf of the Port of Seattle. The purpose of this letter is to provide follow-up comments based on those responses, and on a review of recently-released hydrologic model input files which were used for the SMP. The input files at issue were the basis for hydrologic aspects of environmental impact assessments and for analyses of mitigation measures including existing and proposed regional detention facilities. Those input files were not published with the November 1999 SMP but were made available to us on March 7, 2000, at the same time as the input files were provided to King County for review. The response document dated March 10, 2000 satisfactorily addresses very few of our concerns raised previously. Instead, our concerns have been confirmed and heightened by findings of numerous, significant discrepancies and inconsistencies in the hydrologic modeling files, and by the apparent absence of a…

Subject: Follow-up comments on stormwater management plan for proposed 3rd runway development actions at Seattle-Tacoma International Airport.) Northwest Hydraulic Consultants (nhc) has been retained on behalf of the Airport Communities Coalition to provide a technical review ofstormwater facilities and related streamflow impacts from the proposed 3rd runway development at SeaTac airport. By a letter dated November 24, 1999, we provided our initial comments from a technical review of documents describing the Stormwater Management Plan (SMP) for Master Plan Update Improvements at Seattle-Tacoma International Airport. Responses to public comments, including those submitted by nh¢, were made in a document dated March I0, 2000, by or on behalf of the Port of Seattle. The purpose of this letter is to provide follow-up comments based on those responses, and on a review of recently-released hydrologic model input files which were used for the SMP. The input files at issue were the basis for hydrologic aspects of environmental impact .. assessments and for analyses of mitigation measures including existing and proposed regional detention facilities. Those input files were not published with the November 1999 SMP but were made available to us on March 7, 2000, at the same time as the input files were provided to King County for review. The response document dated March 10, 2000, satisfactorily addresses very few of our concerns raised previously. Instead, our concerns have been confirmed and heightened by findings of numerous, significant discrepancies and inconsistencies in the hydrologic modeling files, and by the apparent absence of a…

Seattle-Tacoma International Airport 0(2 Y - i 2001Master Plan Update Improvements July 2001 H_AR_/_/Ua O t:'IglC,E This document contains replacement pages developed in response to comments received _om the Washington State Department of Ecology (Ecology) on Volumes 1 through 4 of the December 2000 Comprehensive Stormwater Management Plan (SMP) for the Seattle-Tacoma International Airport Master Plan Update Improvements. A facilitated process was used to document specific revisions required by Ecology to the December 2000 SMP. Each SMP volume contains an itemized list of replacement pages, and the replacement pages are identified by a July 2001 footer. ComprehensiveStormwaterManagementPlan duly2001 STIAMasterPlanUpdateImprovements 556-2912-001(28) AR 010825 SMP VOLUME 3 JULY 2001 REPLACEMENT PAGES Preface (before pg. i) List of Volume 3 Replacement Pages APPENDIX B 1: Certificate of Engineer (before pg. B l-i) Figure B 1-2 (pg. B 1-4) Section 1.1 (pg. B1-5) Figure B 1-3 (pg. B 1-6) Figure B 1-4 (pg. B 1-7) Figure B1-5 (lag. B1-8) Figure B 1-6 (pg. B 1-9) Section 1.3 (pg. BI-10) Section 1.5.2 (pg. Bl-14) Des Moines Creek HSPF Calibration Model Input Files (21 pgs.) Des Moines Creek Calibrated Model Hydrographs: SDS3 Average and Peak Daily Flow (4 pgs.) (replaces graphs previously contained on 2 pgs) Golf Weir Average and Peak Daily Flow (4 pgs.) (replaces graphs previously contained on 2 pgs) Near Mouth March 6, 1995 through March 28, 1995 (1 pg.) SDS3 December 28, 1995 through January 18, 1996 (4 pgs.) (replaces graphs previously contained on 5 pgs.) APPENDIX B2: Certificate of Engineer (pg.…

1. I am over the age of eighteen, have personal knowledge of the facts stated in this declaration and would be competent to testify to them if necessary. 2. I have more than 18 years of stormwater engineering and planning experience, encompassing a broad range of stormwater and surface water projects. I have significant experience working with hydrologic and hydraulic modeling (HEC-1, WaterWorks, HEC-2, HEC-RAS), NPDES stormwater permits, erosion control on creeks and lake shores, comprehensive storm and surface water plans, preparation of drainage ordinances and environmental impact statements. I ,have worked extensively with the Department of Ecology's Stormwater Manuals and with King County's Surface Water Design Manual. AN 010168 DECLARATION OF PAUL S. FENDT - ! FOSTER PEPPER _ SHEFELMAN PLLC - 1111TmRI)AVENUE,SUITE3400 SEATTLE,WASmr_GTON98101-3299 ' ORIGINAL 0,_447.050278376,06 3. I have been the project manager for stormwater management and low flow mitigation for the Port of Seattle's Master Plan Update (MPU) projects for the past four years. I was the principal author of the Port of Seattle's Comprehensive Stormwater Management Plan and a principal author of the Low Flow Analysis - Flow Impact Offset Facility Proposal ("Low Flow Analysis"). I graduated from the University of North Dakota with a degree in Geological Engineering in 1981. I was licensed as a Professional Engineer (Civil) by the State of Washington in January 1991 and the State of Florida in February 1990. I have been employed by Parametrix, Inc. for the past 1lyears. A copy of my current curriculum vitae is attached to…

Appearances: PETER J. EGLICK,; KEVIN L. STOCK,; MICHAEL WITEK,; RACHAEL PASCHAL OSBORN,; RICHARD A. POULIN,; JEFF B. KRAY,; JOAN MARCHIORO,; THOMAS J. YOUNG,; GILLIS E. REAVIS,; ROGER PEARCE,; STEVEN G. JONES,; MICHAEL BAILEY, PE; NOON RECESS; CLOSING ARGUMENTS; NUMBER DESCRIPTION IDENTIFIED ADMITTED | Witnesses: MICHAEL BAILEY, PE

hearsay objection to this. This is even more egregious. This is a port-generated document. And this is not the witness to bring this in for the truth of the matter asserted. MR. PEARCE: I can lay a foundation. But it's the same type of document as 1118. MS. COTTINGHAM: This is a draft memorandum, so do you want to make your arguments? Q. (Continuing By Mr. Pearce) : Are you familiar with this document, Dr. Stubblefield? A. Yes, I have seen this document, that's correct. Q. Is this the same type of document as in 1118? MR. STOCK: Object, vague. Q. Is this a range-finding WERS study? A. This document presents the results of some range-finding toxicity tests that were conducted, that's correct. Q. Is this the data draft or -- A. No, the data are actually laboratory bench data sheets, which is the kind of things that, frankly, I would want to see, as opposed to a summary report. It is the true basis of what was generated as opposed to a report that may or may not adequately reflect all of the data that were gathered during the studies. MR. STOCK: Based upon that testimony, Your Honor, it's just getting more attenuated. It's actually AR 056666 WILLIAM STUBBLEFIELD, Ph.D./By Mr. Pearce 9-0060 now double hearsay, where attached to this port memorandum is lab results. No one is hear from the lab to cross examine. Dr. Stubblefield can't be cross examined on the lab results. He can't be cross…

Appearances: PETER J. EGLICK; KEVIN L. STOCK; MICHAEL WITEK; HELSELL FETTERMAN; RACHAEL PASCHAL OSBORN; RICHARD A. POULIN; JEFF B. KRAY; JOAN MARCHIORO; THOMAS J. YOUNG; GILLIS E. REAVIS; ROGER PEARCE; STEVEN G. JONES; MICHAEL CHEYNE; CHARLES "PONY" ELLINGSON; LINN GOULD; ELIZABETH CLARK; JOHN STRUNK; NUMBER DESCRIPTION IDENTIFIED ADMITTED | Witnesses: MICHAEL CHEYNE; CHARLES "PONY" ELLINGSON; LINN GOULD; ELIZABETH CLARK; JOHN STRUNK | Exhibits: 1023 Resume and Curriculum Vita for expert witnesses; 0045 Letter from Northwest Hydraulics Consultants to Corps of Engineers 11-26-01; 0804 Amendment to Interlocal Agreement between City of SeaTac and Port of Seattle; 1178 Pacific Groundwater Group Hydrologic Studies Report; 1305 Pacific Groundwater Group SeatTac Third Runway Embankment Fill Modeling in Support of Low Streamflow Analysis 11-27-01; 1118 Parametrix Water Effect Ratio Screening Study at STIA; 0649 Memorandum from Todd Pollard to Keith Smith 2/29/00; 0686 2001 City of Des Moines Water Quality Monitoring Program; 0005 WAC 173-201A; 0285 1998 Soil Fill Acceptance Criteria; 0286 1999 Soil Fill Acceptance Criteria; 0294 Third Runway Project Off Site Borrow Source Baseline Chemical Characterization

Appearances: KEVIN L. STOCK; MICHAEL WITEK; HELSELL FETTERMAN; RACHAEL PASCHAL OSBORN; JOAN MARCHIORO; THOMAS J. YOUNG; ROGER PEARCE; STEVEN G. JONES; KEITH SMITH; PAUL FENDT, P.E.; STEVEN SWENSON; JOSEPH BRASCHER; NUMBER DESCRIPTION IDENTIFIED ADMITTED | Witnesses: KEITH SMITH; PAUL FENDT, P.E.; STEVEN SWENSON; JOSEPH BRASCHER | Exhibits: 1247 Letter to FAA 82; 0266 Letter to FAA from NMFS 82; 1175 Excerpt from the BA 42