Comments to be submitted by 24 Sept. 2001 Army Corps of Engineering Phone (206) 764-3495
To: US Army Corps of Engineers, Regulatory Branch, P O Box 3755, Seattle, WA 98124-2255
Petition commenting on Special Public Notice, WRDA 2000 dated 24 August 2001
"The preliminary intent of the Seattle District to accept and expend funds contributed by the Ports of Tacoma and Seattle, and the City of Seattle to expedite processing of their Department of the Army (DA) permit applications" is UNACCEPTABLE.
It is common knowledge that it is risky to go up against the Port of Seattle. This proposal creates temporary employees that are likely to be seeking additional employment in their field when funding expires September 2003. Even assuming you are able to find people of integrity, there will always be the perception in aggrieved communities that the Port of Seattle has an unfair advantage with this funding proposal.
The WA Dept. of Ecology's (DOE's) habit of re-assigning people, such as Lisa Zinner and Tom Luster, after they get up to speed on the complex Sea-Tac airport situation, reinforces the airport community's perception that the Port of Seattle's control of regulatory agency staffing is already too great. Newly assigned employees often take years before they can accurately weed through all the Port propaganda and semantics to find the real underlying data regarding the proposed deadly Sea-Tac third runway.
The DOE's recent 401 permit for the proposed Sea-Tac Third runway illustrates the problems of rushing evaluations. It's filled with requests to submit plans, rather than a simple approval of existing plans. The DOE didn't even wait for the release of the groundwater contamination study REQUIRED by the FAA as a condition for approval of the third runway.
King County ranks in the top 5% in the U.S. for lead and PCB air emissions but the permit doesn't test for PCB's. The permit sets the lead, arsenic, and cadmium levels at the MTCA residential toxic clean up levels even though the fill is going on Highline's drinking water aquifer and will contaminate the nearby salmon bearing creeks that flow into Puget Sound.
Taking a fast train down the wrong track is NOT progress.
We urge you to reject the funding windfall that's really a Trojan horse in disguise.
Petition Instructions and Background
Please mail petition by Sept 21 to address on top of petition so it will get there by Sept 24, 2001. . Send petition to Army Corps even if there is only one name on it.
If possible please also make a copy of all the names and either:
send to RCAA 19900 4th Ave S.W., Normandy Park, WA 98166-4043 USA
or, bring to next CASE meeting.
Please feel free to also write your own individual letter or to send letters to the press.
Regarding the items in the petition:
It was the 1997 Record of Decision where the FAA REQUIRED the groundwater study. The groundwater study is DIFFERENT than the aquifer study. The Port started on it in 1999 instead of 1997, changed the scope of it and then refused to give the data to the DOE earlier this year. The report was due June 2000. DOE now has data but there is still no final report as of Sept 4, 2001.
401 limits for fill Criteria: 3 of the 16 Substances Listed below
Hazardous Substance Permit Fill Criteria mg/kg MTCA Residential Puget Sound Hazard level Background Level
Arsenic 20 20 7
Cadmium 2 2 1
Lead 220/250 /1/ 250 24
Reference 401 Cert Aug 2001 /2/ /2/
/1/ No fill with lead concentrations greater than 220 milligrams per kilogram may be placed within six feet of the ground surface. No fill with total lead concentrations greater than 220 mg/kg may be placed within the first six feet of the embankment .
/2/ http://www.metrokc.gov/health/hazard/arsenic.htm Washington State Department of Ecology administers the Model Toxics Control Act (MTCA) regulation that establishes cleanup levels for contamination in soils. http://www.ecy.wa.gov/pubs/9406.pdf Table 740-1 lists residential and Table 745-1 lists commercial for Method A . Note page 2 definition of Method A and that it is NOT applicable for airport. Additional items controlled under MTCA are not listed in fill criteria such as PCB's & benzene. Regarding the toxics, in 2000 EPA released 1996 National Air Toxics Assessment (NATA) database info for King County WA 1996 Emission Densities (tons/yr/sq. mile) Ranking is compared to all other US counties. (extracted from http://www.epa.gov/ttn/uatw/nata/ on Sept 29, 2000)
Top 5 % for benzene, lead, Trichloroethylene, PCBs
Top 10% for Acetaldehyde, Acrolein, 1-3 Butadiene, Carbon tetrachloride, 1- 3 Dichloropropene, Ethylene oxide, Formaldehyde, Methylene chloride, Nickel, Perchloroethylene, 7-PAHs
Alerts page also has link to 401 permit