December 28, 2004
To: Army Corps of Engineers,
Subject: Comments and Request for Public Hearing Northwest Aggregates Pier Permit Application 200001094.
Please require at least two public hearings for the Northwest Aggregates pier permit Application #200001094 - one on Vashon Island and one in the Seattle area. Also extend the comment time and issue no permits before the court appeal process is complete regarding the November 3, 2004 Shorelines Hearings Board reversal of King County's decision to deny Glacier / Northwest Aggregates their two dock permits.
There were thousands more barges per year for 3 years in the paperwork submitted to City of Des Moines than were apparent in the related Corps of Engineers permitting request for a conveyor belt to transfer Maury Island barged materials from Des Moines Beach to Sea-Tac Airport. As does this pier permit request, the conveyor permit request submitted to the Corps mislead some readers into believing the mining quantities would be similar to the past rather than MANY orders of magnitude larger. The pier permit requires a Clean Air Act Conformity Analysis and must address the new Haze regulation with respect to Mt Rainier to ensure it can actually be used as intended. **
This pier permit is really for about 3000 barge trips per year for years.
Considering the high accident rates for barges and poor environmental records, it greatly increases the probability of the extinction of the Puget Sound south resident orca pods that are proposed to be listed as threatened species in 2005. Eelgrass, critical to salmon, will be killed at both the source and destination piers.
In the wake of 9/11, the US Coast Guard needs to re-assess security cost and risk assuming at least 2900 barge trips per year crossing the normal shipping lanes. (including oil tankers headed for Tacoma)
For the pier to be used, it requires creating a berm (hill) of highly concentrated toxic ASARCO Superfund waste that could slide into Puget Sound in the event of a large earthquake. The location is just south of a recent quake epicenter and near the major Seattle east-west fault line.
There is also the mining risk to the sole source drinking water aquifer on the island. Worse yet though, the Maury Island aquifer is connected to the unrefined aquifer that extends from the Seattle area down to about Oregon and is connected to a significant portion of western Washington's drinking water. With the new knowledge of silent earthquakes that last for up to 2 weeks every 14 months under Seattle, the threat of water contamination is far more significant than ANY of today's model predict. Note, models also ignore glaciated till fracture and fractured till from past quakes.
Over 25 tons of toxics per barge are sanctioned using the revised 404 fill criteria for the Sea-Tac Airport "Aircraft Carrier" Runway, which now could be a precedent applied to other projects. Because the Leach test that the WA Legislature overruled the Pollution Control Board to allow underestimates some metals, the real quantity of toxics is actually higher. Metals like chrome react with the acid BEFORE the metal is detected. Imagine the impact from a spill of just one barge.
Table 1: Over 25 Tons of Toxics Allowed per Barge
Toxic - FLAG 1 Pounds
Total 50,672 Pounds
Port Commissioner's definition of "virgin fill" - Pounds of Toxics Per Barge EXCLUDING the toxics not measured (like dioxins)
The Port of Seattle still has been unable to contract for sufficient fill to do all the planned Sea-Tac airport projects including, but not limited to, the Third Runway. Ironically, it is referred to as the "Third" runway even though it increases delays unless the second runway is not used in bad weather. More accurately, it should be referred to as the "Aircraft Carrier" runway since it sits on Seattle's drinking water, salmon bearing creeks, wetlands and has cliffs on 3 of 4 sides. The Pollution Control board ruled it is NOT an essential lifeline so the 135+ foot cliff from the aircraft's perspective, huge wall from the salmon's perspective, does NOT have to be built to survive the BIG quake that Seattle is due. Risky considering it's close proximity to the Seattle fault line, the airport was the epicenter for an 1960's earthquake over a 6 magnitude and when the record tall MSE wall fails the resulting landslide may shut down Highway 509. Aircraft will land in cross winds and then taxi uphill to the terminal across 2 live runways. It's a short dependent runway that uses the same airspace as 3 other runways. By skyrocketing user fees at Sea-Tac, it's making Canada and other west coast states more attractive. Fill for this multi-billion dollar boondoggle (or to replace what it is using) should not be used as an excuse to allow the destruction of a significant portion of the Sound or threaten a sole source aquifer.
Sorry, this is longer than I planned. With decades of experience as an engineer and having spent many hours looking at aquifer maps and reading texts on the subject, it's difficult for me to be brief when ultimately the Puget Sound economy as well as environment is at stake. Economies take a nosedive when drinking water or fish are not available. Tacoma Port deliveries will be delayed. There is a tendency to blame loss of business at the airport on 9/11 when actually some of it's due to the plan to build the extravagant aircraft carrier runway despite airlines submitting it in writing to the FAA, PRIOR to 9/11, that non-standard accounting practices had been used to justify it.
Making a larger dead zone in Puget Sound will only hurt the economy in the long run. Please arrange Vashon Island and mainland public hearings with at least 60 days notice so that groups can inform their members via newsletters.
Please include me as a Party of Record and include this as well as the referenced November 2002 (copy enclosed) as formal comments.
Thank you very much.
italics added when posted on web
** For both 2003 and 2004 King County was at the maximum allowed value, 0.08 for 4th max ozone !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!