TagWater Quality(478)

Email chain (AR 033708–033710) among Washington State Department of Ecology staff Paula Ehlers, Tom Luster, and Raymond Hellwig, with ATG staff Tom McDonald and Joan Marchioro, dated June 1–13, 1999, regarding the Port Of Seattle third runway proposal and 401 water quality certification for Des Moines Creek. Discusses antidegradation requirements under Washington Water Quality Standards

This 1999 email exchange between Washington State Department of Ecology staff debates the legal basis for requiring the Port of Seattle to restore water quality in Des Moines Creek as a condition of receiving a Section 401 water quality certification for the Sea-Tac Airport third runway project. The central question is whether Ecology can require a single applicant to fix broader watershed problems that pre-exist their project, or whether mitigation can only address the applicant's direct project impacts. Staff ultimately conclude that under antidegradation requirements, no further degradation of the creek can be permitted until existing beneficial uses are restored, meaning the Port's mitigation plan must include measures such as flow augmentation and stormwater controls to bring the creek into compliance with water quality standards.

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.

These internal communication records from Parametrix, Inc. (dated around May 1999) document discussions between environmental consultants and Washington State Department of Ecology staff regarding sampling and analysis protocols for port discharge outfalls. Key topics include the need for Ecology to review a Site Assessment Plan (SAP) and Quality Assurance Project Plan (QAPP) before work commenced, the applicability of clean sampling techniques for measuring copper concentrations in discharge water, and the distribution of draft Water Effluent Regulations (WER) guidance to regional offices for review.

Exhibit 2110, AR 033718. Internal Washington State Department of Ecology email chain dated May 14, 1999, among Kevin Fitzpatrick, Tom Luster, Raymond Hellwig, Paula Ehlers, Erik Stockdale, Wendy Bolender, Lisa Austin, John Glynn, and Bill Moore regarding the 401 Certification and NPDES permit matrix for the Sea-Tac Airport Third Runway project. Key issues include stormwater

This 1999 email chain between Washington State Department of Ecology officials discusses the 401 Water Quality Certification process for a major Port of Seattle project affecting Des Moines and Miller Creek watersheds near Sea-Tac Airport. Key disputes include stormwater discharge compliance with water quality standards, required mitigation measures such as riparian buffers and stream flow augmentation, and the retrofitting of existing stormwater outfalls. Officials warn that the creeks are already hydrologically impaired, with flood and erosion conditions far exceeding pre-development levels, making it difficult to approve the project without a comprehensive and specific mitigation package.

These handwritten meeting notes dated 5/10/99 document a discussion among water quality staff including Kevin Fitzpatrick and Gary Bailey regarding permit standards and guidance. Topics covered include updating water quality standards to 'use-based' classifications, finalizing antidegradation rules, and establishing sampling protocols such as requiring at least 5 days of sampling during critical low-flow conditions. The notes also address mixing zone limits, AKART conditions for permit outfalls, and revisions to the permit writer's manual expected by June or July.

Agreed Order #97TC-N122 issued by Washington State Department of Ecology under RCW 70.105D.050(1) directed to Port Of Seattle regarding hazardous substance contamination at Seattle-Tacoma International Airport (STIA). Documents thirteen contaminated sites within the Aircraft Operations and Maintenance Area (AOMA), a 1/2 square-mile area in the southeast quadrant of the airport, contaminated with jet fuel, gasoline,

Washington State Department of Ecology Agreed Order #97TC-N122 issued to Port Of Seattle for Seattle-Tacoma International Airport (STIA), pursuant to RCW 70.105D.050(1). Documents hazardous substance releases within the Aircraft Operations and Maintenance Area (AOMA), a half-square-mile southeast quadrant of STIA operational since 1944. Contaminants identified include jet fuel (most abundant by bulk volume), gasoline, industrial

Email chain dated April 30, 1999 from Ronald Lavigne (ATG) and Ann Kenny to Washington State Department of Ecology staff including Sandra Manning, Kevin Fitzpatrick, and others, raising legal concerns about agreements reached at a Wednesday meeting regarding 401 certification and 402 permit policy. Lavigne raises issues including: the state’s one-year waiver deadline for 401