1 December 1999 Rev A to DOE (typographical corrections only)

(29 November 1999 Original to Corps)

Wetlands and Water Comments on Revised Public Notice of Port of Seattle

File 1996-4-02325, Public Notice Date 30 September 1999

===================================================================

Buried Truth

• Increases probability of aircraft accidents

• Inevitable changes due to questionable EIS

– Increased wetlands impact

– Huge embankment redesign

– Cost overruns & Schedule Slides

– Actual traffic growth exceeds SEIS

• Pollution underestimated

– Air

– Noise

– Ground water & drinking water

• Fill source, cost and transport method still unknown

• Seismic, aquifer & health hazards underestimated

Submitted by A. Brown, 239 SW 189 Place, Seattle, WA 98166

Table of Contents

Table of Contents.............................................................................................................................. 2

Distribution........................................................................................................................................ 5

File Number Reference and Address Clarification Note...................................................................... 5

Abstract............................................................................................................................................ 6

Key Words....................................................................................................................................... 6

Definitions......................................................................................................................................... 7

Acronyms......................................................................................................................................... 8

Summary: Reject Permit and Require New Master Plan EIS............................................................... 9

Introduction..................................................................................................................................... 10

More review time needed................................................................................................................ 10

Comments on Over Capacity Hearing.............................................................................................. 10

Clarification of Revised Project Needed........................................................................................... 10

New Public Health Data Shows Area Already Has Significant Problems........................................... 12

Executive Order for Environmental Justice Applies........................................................................... 13

Health Care Access Differences Insufficient to Account for Health Disparities................................... 14

Increases to Cancer Risk Rating for Key Pollutants to be Announced............................................... 14

Runway Elevation so Low Poses Additional Health Risks................................................................. 15

Airports Injure Children................................................................................................................... 16

New Air Pollution Impacts............................................................................................................... 16

Hydrocarbon Monitoring Needed NOW......................................................................................... 17

Highway funds at Risk..................................................................................................................... 17

Barge Pollution Not Fully Considered.............................................................................................. 18

New Air Pollution Regulations Should Apply due to Schedule Slides................................................ 18

Contrails Impact on Climate More Serious then Ozone- Depletion.................................................... 19

Air Traffic and Surface Traffic Underestimated................................................................................. 19

Underestimating Traffic Pollution Results in Underestimated Water Pollution..................................... 19

Using Obsolete Land Use Assumptions Underestimates Pollution..................................................... 20

PLEASE Stop November 1999 hauling NOW................................................................................ 20

Long 1998 Haul season and Mini 1999 Haul Season Awful.............................................................. 20

New Ground Traffic Safety Data..................................................................................................... 21

Dead and Displaced Animals........................................................................................................... 21

Map wrong - Borrow Site 3 has No Till........................................................................................... 21

It’s Unsafe to Use of Borrow Pits 1, 3 and 4.................................................................................... 21

Fill Source, Transport and Impacts Still Unknown............................................................................ 22

Unknown Silicosis Threat................................................................................................................ 22

Record Setting Embankment Unsafe................................................................................................ 22

Embankment needs to be higher to reduce Pollution......................................................................... 25

Slopes too Steep............................................................................................................................. 26

Seismic Hazard Analysis Still needed............................................................................................... 26

Soil stabilization............................................................................................................................... 26

How do you Mitigate a Hazardous Man-made Waterfall.................................................................. 26

Approximate location of Huge Embankment Inadequate Information................................................. 27

Detailed Modeling in conjunction with Schedule Needed for Embankment Feasibility Study.............. 27

Shoreline Act Compliance Should be Required................................................................................ 27

Near Shore Habitat Endangered...................................................................................................... 28

Ground Water Study Makes Mockery of Public Comment Process.................................................. 28

Aquifer Impacts Still Unknown........................................................................................................ 29

Contamination from Diffusion........................................................................................................... 29

Soil transmits vibration into heart of Normandy Park........................................................................ 30

Bottomless Pit that you can stand on................................................................................................ 30

Water Main and other Potential Utility Impacts Unknown or Ignored................................................ 30

EPA Considering More Stringent Arsenic Regulations...................................................................... 30

Delegation of Authority to DOE Should be Withdrawn Unless Staff Increased.................................. 30

Use of Northwest Ponds Allowed?.................................................................................................. 31

Endangered Species Impacts Still Unknown..................................................................................... 31

Hazardous De-icers and Anti-icers in Creeks and Aquifer................................................................ 32

De-icer Pads should be Required..................................................................................................... 32

Why was enlargement of Borrow site 4 not mentioned in Permit?...................................................... 33

Permit Wetlands Mitigation Inadequate............................................................................................ 33

Oil tank Clean up should be mandatory............................................................................................ 33

Best Management Practices Inadequate per Port.............................................................................. 34

EIS Maps misleading....................................................................................................................... 34

SEIS Underestimated Noise............................................................................................................ 34

SEIS Air Traffic Safety Analysis Outdated....................................................................................... 35

New Procedures to Reduce Incursions May Result in Excessive Third Runway Delays..................... 36

SEIS Bad Weather Delays Misrepresented...................................................................................... 36

Purpose of runway Varies in Documentation.................................................................................... 36

Rejected for Second runway due to Environmental Impact. What’s different?................................... 37

Cost/Benefit Analysis Outdated....................................................................................................... 37

Funding plan needed that considers Initiative 695 Impact.................................................................. 38

Airlines’ Objections to Third Runway Increasing.............................................................................. 38

Technology Alternatives................................................................................................................... 39

Alternatives with Zero Wetland Impacts Exist................................................................................... 39

New Airport Needed Anyway......................................................................................................... 40

Constitutionality of Port Questionable............................................................................................... 40

Port Environmental Compliance and Fiscal Track Record Poor........................................................ 40

Actions if reissue Permit Application................................................................................................ 41

References and Bibliography (Partial List)........................................................................................ 43

References using letters................................................................................................................ 43

Additional References (note changes to numbers)......................................................................... 48

Appendix A: Public Health Data Identifies Significant Issues............................................................. A1

Do Socioeconomic Differences Really Account for all Health Differences?........................................

Cancer Risk by Zip Code or County

Midway Airport Major Contributor to Cancer Risk

DC Has Higher Per-Capita Cancer Risk In Its Air Than Any of the 50 States

Highline Hospital data Indicates More Unexplored Health issues

Sea-Tac Health Data Tables with Standard Deviations Shown

Appendix B: Additional Information on Risks associated Airport Pollutants...................................... B1

ACROLEIN

BENZENE

1,3-BUTADIENE

FORMALDEHYDE

METHYL CHLORIDE (CHLOROMETHANE)

Appendix C: Air Pollution............................................................................................................... C1

Appendix D: Unsafe Trucks Contrary to EIS Claims....................................................................... D1

Appendix E: Deceptive Lone Star Maury Island Mining Operations DEIS........................................ E1

Appendix F: Earth........................................................................................................................... F1

Appendix G: Water........................................................................................................................ G1

Appendix H: Best Management Practices Don’t Work per Port Letter............................................. H1

Appendix I: Noise Models Significantly Underestimate Noise............................................................ I1

Appendix J: Technology Alternatives................................................................................................ J1

Appendix K: Air Safety.................................................................................................................. K1

Appendix L: About the Author........................................................................................................ L1

Appendix M: Miscellaneous References (Supplied to Corps only)

Distribution

To: US Army Corps of Engineers,

Regulatory Branch,

PO Box 3755

Seattle, WA, 98124-2255

Attn: Project Manager Jonathan Freedman

WA State Department of Ecology

Permit Coordination Unit

PO Box 47600, Olympia WA 98504-7001

Attn: Tom Luster, Environmental Specialist

cc: CASE

DOT

FAA

EPA

RCAA

File Number Reference and Address Clarification Note

The subject notice lists two different file reference numbers. The first page identifies it as 1996-4-02325 and page 9 lists it as 1999-4-02325. This responds to both.

The notice also lists two different addresses for DOE comment submittal. I am assuming that the page 8 address is correct since that page was prepared after the page 44 address.

Abstract

Any responsible person fully acquainted with the engineering, environmental and economic challenges of the Sea-Tac International Airport Master Plan Project would DENY the section 404 permit related to wetlands and the Clean Water Certification. If you do not know that in your heart and mind to be the absolute truth, you are a propaganda victim and need to:

(a) Scrutinize the existing data and forecasts more thoroughly (see Summary herein)

(b) Wait for the completion of the aquifer, groundwater and health studies

(c) Wait for the fill source, quantity, cost and transportation mode to be determined

(d) Require a geotechnical survey to identify all seismic anomaly layers at the construction site and near the embankment that need to be excavated or stabilized in accordance with the 1997 FAA Record of Decision

(e) Identify earthquake hazards with the new record breaking tall embankment design.

You will be doing the Port of Seattle a favor to reject this extravagant project conceived long before anyone on the street had heard of GPS (Global Position Satellites) or the myriad of other technological advances available for aircraft now. It’s no wonder the Supplementary Environmental Impact Statement recommended a new update in the year 2000.

Key Words

Airport	Health	Wall
Aquifer	Incursions	Water
Asthma	NPDES	Wetlands
Cancer	Port of Seattle	Permit
Endangered Species	Respiratory illness	Salmon
Embankment	Seismic anomalies	SeaTac
Fill	Soft Soils	Sea-Tac

Definitions

“Do Nothing” Alternative 1 in Master Plan Update. EIS terminology for current two runway configuration. Also assumes no road or parking lot improvements for the area. Assumes airport will operate over theoretical capacity (as defined by NPIAS in EIS) with excessive delays. Assumes delays that are so excessive market forces would not allow them.

DEIS Refers to the 1995 Master Plan Update Draft Environmental Impact Statement (Ref. b) unless otherwise specified.

EISs Refers to the DEIS, FEIS and SEIS for Sea-Tac unless otherwise specified.

FEIS Refers to the 1996 Master Plan Update Final Environmental Impact Statement (Ref. d) unless otherwise specified.

ROD Record of Decision (ROD) refers to the 1997 FAA Record of Decision for the Master Plan Update SEIS (Ref . 40). It includes conditions such as a Groundwater Study, excavation/stabilization of soft soils and annual quantity of haul trucks.

SEIS Refers to the 1997 Master Plan Update Supplementary Environmental Impact Statement (Ref. 39) unless otherwise specified.

Soft soils A type of soil that is often described as something that liquefies in an earthquake in layman terms. Actually the water separates and becomes a thin film. The phenomena can continue to cause damage for an hour after an earthquake. It is a seismic hazard.

Acronyms

ACC Airport Communities Coalition

ADF Aircraft Deicing Fluids

AKART All Known and Reasonable Technology

ALPA Air Line Pilots Association

BMP Best Management Practices

CASE Citizens Against Sea-Tac Expansion

DEIS Draft Environmental Impact Statement

DNS Determination of Non-significance

DOE Department of Ecology

FEIS Final Environmental Impact Statement

EPA Environmental Protection Agency

HOK 1996 Burien Study funded by WA

IWS Industrial Wastewater Treatment System

IWTP Industrial Waste Treatment Plant

KC King County

LDA Directional aid technology

GAO Government Accounting Office

GPS Global Positioning Satellite technology

MSE Mechanically Stabilized Earth

NEPA National Environmental Protection Act

NPIAS National Plan for Integrated Airports System

PCF Passenger Facility Charge

POTW Publicly Owned Treatment Works

PSAPCA Puget Sound Air Pollution Control Agency (former name)

PSRC Puget Sound Regional Council

Port Port of Seattle

RCAA Regional Commission on Airport Affairs

ROD Record of Decision

Sea-Tac Seattle-Tacoma International Airport

SeaTac SeaTac, city adjacent to Sea-Tac airport

SEIS Supplemental Environmental Impact Statement

SEPA State Environmental Protection Act

SES Socioeconomic status

SIP State Implementation Plan Air Quality

TAF Terminal Air Forecast

WA State of Washington

Summary: Reject Permit and Require New Master Plan EIS

The Section 404 permit and Clean Water Act Certification should be rejected and a new Master Plan Update required.

It is a waste of your time and our time to evaluate this outrageous idea any further. The EIS process chose to ignore substantive comments from hired consultants, regulatory technical staff, and from citizens that had invested far more time evaluating the relevant documentation than those that approved the project. Most every adverse event that has happened was predictable. Examples of the inevitable include: unacceptable EIS embankment design, the North Employee Parking Lot spring that popped “out of nowhere” that resulted in the mud slide into Miller creek, fill source and transport issues and skyrocketing costs. A partial list reasons to require a new Master Plan Update follows:

· Supplementary Environmental Impact Statement (SEIS) Recommended Year 2000 Update

· SEIS Forecasts and Models Obsolete

· Current growth exceeds SEIS

· Third Runway Severely Congested or Obsolete upon opening

· Alternatives Analysis Obsolete

· Air Conformity was based on obsolete construction schedule

· Growth Violates Clean Air Act now (more than 100 tons NOx)

· Light rail impacts and Highway 509 expansion ill defined

· 8 on-site borrow sites reduced to 3 ; 2 of those now require Strip mining permits

· Fill source, transport and cost still unknown

· Port admitted Best Management Practices inadequate for just a parking lot

· Significant projects identified since EIS not addressed

· Statistically significant health problems identified for area that construction and expansion will make worse

· Maps in all EISs are missing the Third Runway safety

· Additional technical information needed

· Geotechnical survey for underground seismic anomalies detection still needed

· Bird Hazard and Seismic analysis of record setting tall embankment located on soil that liquefies in an earthquake needed

· Highline and Maury Island Aquifer Studies due June 2000

· Groundwater Study due June 2000 required by FAA Record of Decision

· Endangered species act impacts undefined

· NPDES violations unresolved

· Des Moines Water classifications complete in 2000

· Health risk analysis needed

· Higher cancer ratings of airport pollutants to be released early in 2000 or late 1999

· Increased Aircraft accident risk for operations that now exceed DEIS levels

· Costs continue to skyrocket without a complete Funding Plan

· Current funding shortfall will be even greater when mitigation costs added

· FAA did not grant all the funding requested in 1998

· 1998 Passenger User Fee application relied on ability to raise real estate taxes contradicting the draft SEIS (page F-42). Initiative 695 now requires a vote to do this.

Introduction

This supplements my previous permit comments, EIS comments and the additional comments delivered during meetings at the Corps of Engineers office subsequent to the April 9, 1998 hearing. Important points have been left out of this in order to avoid duplication per the 1999 permit application direction.

More review time needed

The review period was insufficient and not all the necessary technical supporting data was available for review. Citizens Against SeaTac Expansion (CASE) has many engineers in it and we need data. Without the storm water manual and more detailed wall concept there is no way to evaluate this completely. We do not rely on Port of Seattle propaganda or trust eloquent speaking consultants that try to portray something as conventional and safe that, in my opinion, is actually record breaking or deadly. The small extension is in adequate for people like me that work days to track down the information from government offices that are closed evenings and weekends. The documents should be made available at the local libraries, as has been done on other Master Plan Project documents during public comment periods.

Comments on Over Capacity Hearing

The side doors had signs on them “No Admittance...” so we will never know how many people attended the 3 November 1999. The side doors were used as the primary entrance by many since the main parking area was full.

People who submitted requests to talk BEFORE 7pm, the start of the hearing, did NOT have an opportunity to speak.

If the runway is really suppose to bring in so much business that it will help the hotels, why aren’t the major airlines supporting it? Don’t you think its more likely that the out-of-state hotel owners don’t have a clue about the escalating costs, soft soils and or impacts to the areas with statistically significant health problems already.

Clarification of Revised Project Needed

The permit application has too many changes compared to the SEIS project to be able to evaluate the permit. It appears to have significant technical changes without supporting analyses. Please issue a revised version explaining all the changes and also include the omissions that were identified in prior comments. Some items to consider are listed below:

· What happened to Des Moines Creek being moved?

· Are the beautiful Walker Creek headwaters still being filled in?

· Has the SASA project definition changed? Has one of the detention ponds moved?

· How can you build SASA, and accomplish the mitigation in the Tyee golf course area?

· Is there still a bridge that will cast shadows on the wetlands near SASA?

· Are shadows considered in the calculations of wetlands impacted? If not, why not?

· Reissue permit application with legible map identifying the third runway safety areas ( see discussion herein)

· Why is there no mention of warehouses in the embankment area that are now being discussed by the Port?

· Are the impacts from all the improvements outlined in the 1995 and 1998 Port Passenger Fee Charge Application documents addressed?

· Which seismic anomalies will be excavated or stabilized in accordance with the FAA Record of Decision and which will be left in place now that the footprint of the embankment is different?

· What are the results of the Ground Water study required by the FAA Record of Decision?

· Why wasn’t the enlargement of Borrow pit site 4 mentioned as a permit change?

New Public Health Data Shows Area Already Has Significant Problems

New public health data indicates the EIS assumptions regarding the health of the area are wrong. Trapped in noisy homes whose values are not appreciating at the same rate as quieter homes, the already sick population will be bombarded by construction pollution related to about 80 BILLION pounds of fill and then the additional pollution from increased ground and air traffic.

Please review the charts in the Health Appendix as well as the Georgetown (ref. 55, 56 and SeaTac (Ref. 61, 168 ) and King County (Ref. 57, 58, 59) reports . This health data supplements the Georgetown data provided at the 7 August 1998 CASE/Corps of Engineers meeting. The Department of Public Health data shows that Georgetown, South Park and SeaTac area share common health problems that will result in additional hospitalizations and death if this inconceivably huge earth-moving project is allowed. It doesn’t matter whether you believe these health problems are from socio-economic status and/or airport pollution. Either way, we are talking about making a serious life threatening problem worse.

· Statistically Significant Reduced Life Expectancy

· Statistically Significant Higher Cancer deaths

· Statistically Significant Higher Respiratory Cancer deaths

· Statistically Significant Higher Chronic Pulmonary Heart Disease deaths

· Statistically Significant Higher Asthma hospitalizations for all ages

· Statistically Significant Higher Influenza and Pneumonia hospitalizations

The serious health situation is even worse if you consider these additional points:

· The health data uses King County as the baseline. The February 1998 Public Health Data Watch states on page 1 that the King County childhood asthma hospitalizations are “significantly higher than elsewhere in Washington (WA) State”. The even larger central Seattle numbers are in the King County baseline.

· The health data also sometimes uses WA as the comparison point. The Washington data is skewed higher because of the large contribution of King County data. The February 1998 Public Health Data Watch also includes a graph that shows that the King County data contributes so much to the Washington State average, that the WA average for the 1996 childhood hospitalizations is inflated by 25 per 100,000.

· The August 1998 Public Health Data Watch indicates that the King County trend in childhood asthma hospitalizations is increasing, particularly for 1 to 4 age group. It increased 39% from 1987 to 1996.

· If the cancer data was grouped into those typically associated with airport pollutants versus those not normally associated with them, even more statistical significance might be found.

· Following traditional methodology, the SeaTac study (Ref. 61)used concentric circles to evaluate brain cancer. However, airport pollution is believed to be rectangular i.e. with the long direction being parallel to the flight path. With our four post flight path combined with the other nearby airports our situation is more complicated than a simple rectangle, however, in close proximity to the airport a rectangle is more representative than a circle. By using a circle you underestimate adverse health impacts by including the sides of the airport which are not exposed to as much pollution. If the SeaTac health data is limited to those under the flight path that claim to be subjected to strong hydrocarbon smells periodically and report a mist on their skin occasionlly, more of the brain cancer data in the 1999 February health report becomes statistically significant.

Circle includes area not under the Rectangle represents flight path

Flight path so underestimates (highest pollution exposure area?)

health problems if flight path related

Figure 1 Area Evaluated Impacts Results

In other words, the recent health studies (SeaTac, Georgetown, The Health of King County 1998)) have uncovered an asthma hot spot in King County including central Seattle, Southeast Seattle, West Seattle, White Center, and the SeaTac area. Where more detailed studies have been done, studies reveal it is not just asthma but respiratory illness in general that is statistically significantly higher than King County (KC). The other illnesses include, but are not limited to, pneumonia/influenza, and lung cancer.

Even more health concerns are raised if you review the health data on diagnoses at Highline Hospital. For instance, esophagus cancer appears high which could be related to the high formaldehyde levels. See Health Appendix A and B for additional information.

A health study that focuses on the health problems typically associated with airport pollutants is needed to help establish an acceptable level of airport pollution. Pollutant monitoring to assist in that study is also needed.

Please also see discussion on Third runway elevation which creates a situation where people will be even closer to aircraft flying overhead then they currently are due to topography differences.

Executive Order for Environmental Justice Applies

Some areas impacted most by SeaTac and Boeing Field airport expansion are high-poverty so the Executive Order regarding Environmental Justice applies to this situation (Ref. 91). The 1999 SeaTac health report (Ref. 61) noted poverty as a significant factor for the significantly high health problems. The February 1998 Public Health Data Watch on page 2 (ref. 57) indicates that King County high-poverty neighborhoods had three times the childhood asthma hospitalizations as the low-poverty neighborhoods for the 1987-1996 time period.

There have already been lawsuits initiated on the grounds of Environmental Justice regarding noise in Rainier Valley (ref. bb). Imagine the potential for lawsuits when the astronomical respiratory disease numbers for the South Park/Georgetown area plus the significantly high numbers for SeaTac are provided to lawyers. Normandy Park has the most to lose economically and their average income is about $80,000 so surely they can help out those too poor to file lawsuits.

Unloading fill from barges at the Duwamish site will adversely affect the health of residents suffering from some of the highest rates of asthma and other respiratory illnesses. The central and southeast Seattle child hood asthma rates for 1994-1996 were over TEN TIMES GREATER than those on Vashon Island (a difference of over 500 cases per 100,000) (Feb. 1998 Public Health Watch (Ref. 57)). Of course if they mine 10% of Maury Island, Vashon’s asthma numbers will climb.

Unloading the fill at Des Moines will also have Environmental Justice issues due to income levels closest to the airport and immediately south of it.

Using the remaining three of the 8 originally proposed Borrow sites (1, 3 and 4) has environmental justice issues due to the low-income area south of the airport. The area suffering is already from significantly high respiratory illness and it will make it worse.

The increase in operations at the airport, that also increase in ground traffic, have Environmental Justice ramifications in addition to the construction ones already mentioned.

Health Care Access Differences Insufficient to Account for Health Disparities

In the National Institute of Health’s “Health Disparities: Linking Biological and Behavioral Mechanisms with Social and Physical Environments (Ref. 183), it references several studies that challenge the precept that one can assume poor neighborhoods are unhealthy because of lack of access to health care.

Increases to Cancer Risk Rating for Key Pollutants to be Announced

It is well accepted that inefficient fuel burn occurs on the ground as well as during landing. This accounts for some of the reasons benzene and 1,3-butadiene are some of the chemicals monitored during airport pollution studies. People world over complain of the smell of jet fuel by airports. High rates of formaldehyde have also been measured (750% of the federal limit in a 1973 Sea-Tac study (Ref. 95)). For a list of relevant chemicals, enclosed in Misc. Appendix M is a copy of “Illinois EPA Strategy for Continued Assessment of O’Hare Airport Air Toxics Emissions Impact on Surrounding Communities” dated 28 June 1999. Also, enclosed is some Midway Airport cancer risk data from a 1993 report (Ref. 93).

The National Toxicology Program releases a “Report on Carcinogens“ every other year.

The current draft increases the cancer risk rating for chemicals such 1-3 butadiene, ethylene oxide (antifreeze) and dioxin (proprietary ingredient in some deicers?) (Ref. 82). I do not have the complete list yet to know if there are other items of interest to Sea-Tac. The impact of these increased risks need to be considered in both air and water pollution analyses and health risk assessments. See Appendix B for hazard data on some common airport pollutants.

The exposure of Normandy Park residents to hydrocarbon pollution has increased noticeably over the last few years. Both the last week in September and the last week of October, it was particularly bad. Residents reported burning eyes and a strong smell of fuel. The agency formerly known as PSABCA when called about this referred us to the FAA since the air monitors, which are not near SeaTac, indicated that we were having good quality air days so it must be a local source of pollution.

Runway Elevation so Low Poses Additional Health Risks

The proposed Third Runway is about 14 feet lower than when the EIS process began. I do not know if this was accounted for in the air pollution model. I’m certain it was not considered when health risks were assessed. The proposed Third runway, due to its lower elevation and the elevation of the land under the flight path, poses a greater health risk than the east runway it is intended to replace (flying aircraft are closer to people). The touch down elevations are different for each runway. Pollution is also different due to differences in operations. The current touch down elevations are:

Table 1 SeaTac Airport Touchdown altitudes

North end

East Short runway West Long runway (big jets)

16 R 426 ft 16L 428 ft

34L 384 ft 34R 386 ft

south end

Based on the topography map IV19-1 in FEIS Vol. 1 and touch down altitudes for each runway available on web, it appears the distance from the landing aircraft to the people, as well as the terrain, may be an important factor in understanding the areas’ health and pollution problems.

The only high area (approx. 450 feet elevation), relative to landing altitude on the

North end is where the wife and husband both had brain cancer. Now there

is an empty lot where their home stood. It’s near Riverton Heights school, now closed, which is

one of the first places where brain cancer became a concern. The rest of the north end

is relatively flat around 350 feet for the current two runways. The transition from 450 to

350 feet is gradual.

In contrast, the south end is hills and valleys between 450 and 100 feet then straight down to the Sound at 50 feet. Pacific School is about 300 feet to 350 feet. Olympic Elementary and North Hill are around 350 feet.

I'd expect the pollution to be captured in the valleys sometimes on the south end. At St. Philomena's School, Mt. Rainier and Pacific Schools you sometimes feel as if you could reach up and touch the aircraft they are so close. Also heavily loaded cargo planes take off to the south on the long runway so they will be going downhill on the runway when winds permit it.

The proposed Third runway will be departing over land that is about 400 feet elevation on the north end and 350 feet on the south end. Since the runway is lower and the land people are living is higher, the departing and arriving aircraft will be closer to people than the existing east runway situation

I also question whether these elevation differences have been fully accounted for in the noise models.

Airports Injure Children

When the airport was original built in the middle of Highline School District, the school district was the largest in the state and one of the best. It has lost both those distinctions. Its drop out rate is 34%, which is over DOUBLE that statewide average of 16.4% (Ref. 169). Note, this is new data just being released now that tracks all those that drop out between freshman year and when they should have graduated.

Table 2 Highline School Dropout Rate More than Double WA Average

Highline test scores are also abysmal. Cornell University study shows that children near airports don’t read as well as other children (Ref. 66). At least one study in Europe which monitored children after the opening of an airport is particularly convincing since the socio-economic variable was controlled. In addition to the health risks such as asthma and reduced life expectancy, children’s learning abilities are diminished. See the map in Health Appendix A for location of Highline District schools.

New Air Pollution Impacts

Due to the new data that has become available that proves the Master Plan Update EIS air conformity analysis assumptions were in error, you are requested to ask the Governor to withdraw the Clean Air Certification. Colonel Rigsby in a meeting on 15 May 1998 indicated his willingness to review Clean Air Act impacts if new data was available. See Appendix C for more details. Some key points are listed below:

· Port Commission recently referred to a “doubling of capacity” which is higher than SEIS

· 1998 Passenger User Fee Application to FAA indicates more operations planned than SEIS

· Availability of high speed rail will increase the number of operations

· Operations Growth to date significantly higher than assumed in SEIS

· Existing delays significantly lower than assumed in SEIS (overestimated Do Nothing pollution)

· Surface transportation impacts from construction significantly higher than assumed in EIS (no real surprise, a Sammamish group challenged the models in court recently and won)

· Construction schedule slide changes the ground and air traffic assumptions

· Fill transport impact on pollution unknown

· Pollution risks from diesel engines is now believed to be worse (currently key area of focus for US EPA).

· 1998-1999 SeaTac NOx was unexpectedly HIGHER than the Beacon Hill monitoring station casting more doubt on the modeling assumptions (Ref. 92, unpublished data, report available soon)

Based on Reference 38, it appears that the construction schedule was changed between the FEIS and the SEIS so as to meet air conformity requirements. Current plans to change the construction schedule should require a new air pollution analysis be done as soon as possible. The Record of Decision included a maximum number of trucks per year stipulation for the maximum construction year to comply with Air conformity analysis. This schedule is now different.

Please note, I am fully aware that air pollution modeling, particularly for SeaTac airport terrain, tends to overestimate pollutants such as CO and NOx. However, even with just some minor traffic assumption changes to the EIS model, I calculate over 300 addition tons of NOx.

This project, if modeled with anything even close to credible inputs, even assuming the model is conservative by a factor of three, TRIGGERS the CLEAN AIR ACT DE-MINIMUS LIMIT.

Hydrocarbon Monitoring Needed NOW

Excerpt from D. DesMaris review (Ref. 99) of the Mculley, Frisk & Gillman (MFG) air study (Ref. 98) follows:

"The MFG survey was initially intended to be a follow-up to either validate or disprove the EDMS estimates. However, much of the sampling done by MFG did not follow specific criteria on location or scenario for sampling the worst case predictions. The sampling time of year, days of the week and weather were more conducive to best case scenario. The results, many of which are quite alarming, however, captured high levels of benzene despite the above mentioned conditions. Benzene and formaldehyde were detected at levels far above the Washington Administrative Code acceptable source levels. Since averages in the codes are based upon yearly figures, an annual amount is difficult to arrive at using only four days of 6-8 hour sampling periods. However, using a method suggested by Mr. Fred Austin of Puget Sound Air Pollution Control Agency*(PSAPCA) the yearly is in excess of allowable limits for benzene and formaldehyde, but the 8 hour average for benzene, when used as a yearly figure is 100 times over the allowable safety limit."

Considering an earlier study by Adams (Ref. 95) found formaldehyde levels 750% more than the safe limit, the MFG study also identified high hydrocarbon levels and studies at other airports indicate high levels of hydrocarbons , monitoring is needed NOW to determine if airport operations need to be reduced to safer levels.

Highway funds at Risk

Personal note, I remember a few years ago thinking some CASE members were crazy to suggest limiting operations at Sea-Tac. However, having read over hundreds, if not thousands, of articles/reports on the subject of health and air pollution (far more than referenced in here), I’m afraid we need to make a choice between

1) manufacturing in King County

2) airport growth in King County, or

3) assume we will lose highway money because we will go out of attainment and will no longer qualify for state highway funds (Ref. 196).

Light rail alone will not solve our problems.

The NO₂ data taken in 1998/early 1999 time frame (Ref. 92) had some individual hour readings that that far exceeded (more than four times) the annual permitted limit. Between increased surface traffic and increased air traffic, and the construction traffic, it is like the straw that broke the camels back. Would King County have gone out of attainment this summer if the Port had hauled at the same rate in 1999 as they did in 1998?

Barge Pollution Not Fully Considered

According to Reference 156, “Ship engines produce some of the highest amounts of pollution of all combustion sources per ton of fuel consumed.” The article provided NOx and SOx emission parameters. It also states

” Ship emissions may contribute to pollution hundreds of kilometers inland. Emitted SOx and NO and their atmospheric oxidation products are thought to have residence times of ~1 to ~3 days, which are consistent with mean transport distances of ~ 400 to ~1200 km”.

The very real risk of barge accidents also needs to be considered (Ref. 160). Note, there were many similarities between the SeaTac Airport EISs and the Maury Island DEIS. They concluded that despite enormous increase in traffic there would be no impact to safety. In the case of SeaTac it was referring to about 1,500,000 double haul trucks. However, in reality about 100,000 trucks over three years has led to severe accidents and deaths (References jj, jjj, Apendix D). Imagine the havoc that thousands of barge trips a year in the Sound can cause as they cut across ferry routes.

New Air Pollution Regulations Should Apply due to Schedule Slides

Construction has slid so much that new regulations should apply. In the FEIS, it said the runway construction would be complete in year 2001. New regulations such as the Haze regulations that go into force in year 2002 need to be addressed. Reminder: Mount Rainier is rated as having a “visual acuity" problem under the Clean Air Act and projects such as this that increase air pollution are suppose to be coordinated with the Federal organization that oversees Mount Rainier.

Also, considering the respiratory health problems in the area, the new fine particulate regulations, even though their method of implementation is being challenged in court, should be applied to the airport construction and the expanded airport. The particulate testing conducted in 1998 during some of the hauling demonstrates the total inadequacy of current monitoring procedures. Although the particulates did seem to vary with haul construction traffic their levels were typical of Seattle urban areas and still met standards (Ref. 92). In contrast, at the time the dust was like a sandstorm some days, vehicles and homes were being buried with dust, and those with asthma couldn’t breathe normally. You could taste it, the dirt was so thick. Whenever they hauled in the rain there appeared to be an even higher incidence of sinus infections and other respiratory ailments at nearby businesses and schools.

Contrails Impact on Climate More Serious then Ozone- Depletion

Additional regulation of the airline industry is now seen as inevitable as the evidence of contrails mounts. A recent report “Aviation and The Global Atmosphere” was released by a credible team with industry represented (Ref. 158). If we don’t get started on a new international airport, we may lose our chance to do so until someone invents new technology to solve the problem. The emphasis will be shifting to ground transportation and it will be more difficult to get new airports approved.

Air Traffic and Surface Traffic Underestimated

The Port historically has underestimated air traffic operations. The EISs provide some graphs that illustrate this. Older reports show an even larger disparity in actuals compared to projections. The FAA required the SEIS since the DEIS were too low to be credible. They have already exceeded the SEIS now as well. It appears the ignored FAA Terminal Air Forecast numbers may be more realistic. In the past we have also historically exceeded those as well.

Figure 2 Port Operations forecasting Incompetent or Skirting Environmental Regulations?

By underestimating air traffic and the associated ground traffic for the Third runway, the pollution has been hidden. Considering the year 2003 forecast in the 1985 Master Plan Update (Ref. 133) was for a mere 295,000 operations, the credibility of their existing estimates should also be questioned.

Underestimating Traffic Pollution Results in Underestimated Water Pollution

As was the case with the air pollution, by using unrealistic ground traffic and air traffic assumptions (See Appendix C), the EIS underestimated the pollutants being released by vehicles and aircraft into the water and eventually the aquifer. If the “Do Nothing” operations and surface traffic are constrained to the airport’s market demand limit (severely congested) or the theoretical limit and this number is than compared to the Terminal Air Forecast projections for the airport for 2010, the Clean Water act will likely be violated. The errors are further compounded by the unrealistic traffic flow assumptions for construction traffic. Just 20, 000 trucks spread over less than four months resulted in traffic being at a dead stop and traffic delays of at least 15 minutes over a two block distance near the airport. If further model adjustments are made to reflect emissions associated with the likely age of vehicles you may find even more pollution. Bottom line is that if you do a credible model, it WILL violate the Clean Water Act.

Using Obsolete Land Use Assumptions Underestimates Pollution

The EIS did not consider zoning changes that had recently occurred despite requests by citizens to use updated information. The Water Certification issued in 1998, that was subsequently withdrawn, still relied on 1994 Land Use conditions. Considering the large industrial buildings with large amounts of impervious surface that are now allowed, both the air and water pollution models need to be updated.

Considering the following statement in the Jurisdictional Wetlands Determination page H-A-21, one has to ask how much more flooding will there be due to the North Parking Lot, Third Runway, and major industrial complexes being built adjacent to the airport:

“During the December field visits storm events were observed that flooded the site in several locations. Much of the Lake Reba complex was inundated with up to several feet of standing water on December 20, 1994.”

PLEASE Stop November 1999 hauling NOW

As mitigation, the EIS restricted hauling to the dry season. Why are they being allowed to haul from October 20, 1999 through mid- November 1999 (60,000 to 70,000 cubic yards) during the rainy season? Why aren’t they covered? Are they trying to kill the wetlands and creeks now so we won’t have anything worth saving? Citizens’ complaints of bad air in Normandy Park increased when hauling resumed this October. The air was also noticeably worse when they were hauling for a short time this summer.

Does the current hauling in the rain violate the Record of Decision mitigation to “phase construction activities to minimize the amount of area that is disturbed and exposed at any one time during wet weather conditions”?

Long 1998 Haul season and Mini 1999 Haul Season Awful

There was NO relationship between what happened during the hauling to what the EISs forecast. We had more traffic, more deaths, more illness, more pollution, etc. Some key points are below:

· EIS mitigation not implemented (See Senator Patterson letter in Appendix D)

· Trucks uncovered and continued to haul in 1998 after the rainy season set in

· Loads higher than allowed, spilling over the rails ( I know the middle can be as high as they want but sides must be six inches down from the top)

· Large number of traffic violation citations issued by King County Police

· Sometimes hauled during school bus hours despite agreement ( they would cheat and haul when they were not suppose to, we would complain to officials, officials would complain to Port, hauling would stop but then start up again so the cycle would start all over)

· Closed lanes and stopped traffic (not in EIS pollution analyses)

· Significant road damage was repaved (more traffic delays and pollution during repaving)

· Residents with allergies had coughing fits when driving by airport and new or increased asthma

· More accidents and deaths – see next paragraph

New Ground Traffic Safety Data

The Final EIS response to Comments claimed that there would be no impact to public safety on the roads. Serious accidents and multiple deaths have occurred from haul trucks since the 9 April 1998 Hearing. The mortality rate appears higher than those forecast by Hank Hopkins in his Conveyor handouts such as his June 1998 Community Newsletter. See Appendix D.

Dead and Displaced Animals

Even if you don’t see the trucks, you know by the dead animals on the road when fill is being delivered or other major earth-work is being done at the airport. The increased quantity of dead animals poses a health threat. It’s a dead give away when the trucks are dumping (pardon the pun).

Foxes do NOT belong in the QFC supermarket parking lot on 1^st Ave. South. They need a home.

Between the new warehouses and the new housing developments south of the airport, where are all the animals to go?

Map wrong - Borrow Site 3 has No Till

According to an AGI report (page Q-A-15) ‘that recent borrow studies indicate the till is not present in Area 3 despite its being mapped there on surficial geology map”.

It’s Unsafe to Use of Borrow Pits 1, 3 and 4

The use of Borrow Pits 1, 3 and 4, sometimes referred to as Areas 1,3, and 4, should be denied because:

1) the watershed can’t handle it

2) creek goes through site 1

3) too much risk of encountering soft soils

4) the already significantly high respiratory illness will get worse

5) close proximity to schools

6) the Port’s track record suggests it is incapable of doing it without construction violations

7) giant sloth was found at the north end of the airport and area could have archeological value

8) it’s probably contaminated anyway

9) Highline/Seattle drinking water is under it

10) “recharge from these borrow areas may also directly recharge the Intermediate (Qc[3]) Aquifer” ( ref. AGI page Q-A-15) refers to Area 1 and the now eliminated 5 Area.

11) removes the pollution buffer between airport pollutants and the aquifer

12) odds of getting a Strip mining permit to strip mine Des Moines (sites 1 and 3) is every low and is bound to just waste taxpayers money in a long court battle (with the Dept. of Public Health data there is NO WAY the Port could win this as long as we appeal it high enough).

Fill Source, Transport and Impacts Still Unknown

How can you identify water and wetlands impacts when you don’t know how much fill is needed, where it will come from, or how it will get here?

· A special geotechnical survey is needed to determine how much existing soil must be excavated to remove the seismic anomalies in accordance with the Record of Decision.

· Unlikely to be granted Strip mining Permit to use borrow site 1 or 3 so even more fill will need to be hauled to Sea-Tac

· The Lone Star Maury Island Mining DEIS assumes Master Plan Update had evaluated all the transportation related pollution impacts but it didn’t. See Appendix E.

· If a Des Moines conveyor and pier for barges was built, there are huge Shoreline Act impacts as well as wetlands and Clean Water Act issues. There is eel grass at the pier location to further complicate the permitting process should the courts decide to overrule Des Moines 1999 rejection of the permit. The land is so unstable and floods so often there, they couldn’t build a conveyor without destroying large amounts of wetlands.

· If barges unload at the Duwamish, the area is likely to go out of non-attainment for particulates. It would require many more trucks on Highway 509 than the SEIS assumed. In fact it would require so many to unload four barges a day, that they may not actually be able to do four barges a day. Designing a completely enclosed conveyor to travel that distance may be able to alleviate the truck problem but then other issues take their place.

· Can four barges a day, which means 8 crossings a day, really cross ferry routes without decreasing safety as well as polluting? How much does a round trip barge trip from Vancouver Island, Canada pollute?

Unknown Silicosis Threat

Alfred Munzer, M.D., past president and volunteer spokesman for the American Lung Association, described some of the most serious effects of being overexposed to silica dust. "Silicosis is an insidious, debilitating lung disease that robs people of their breath and eventually limits their mobility and makes them dependent on supplemental oxygen," said Munzer.." OPA Press Release: Labor secretary calls for an end to Silicosis [10/31/96].

Without fill transport mode and placement schedule, it is not possible to do a silicosis threat assessment. Considering the respiratory problems already in this area, that have recently been brought to light, this needs to be evaluated.

Record Setting Embankment Unsafe

The “Evaluation of Retaining Wall/Slope Alternatives to Reduce Impacts to Miller Creek, Embankment Station 174+00 to 186+00” (Ref. 114) finally confirmed what citizens have been writing in their comments for years, that the EIS embankment approach is not feasible. However, the Embankment report (reference 114) is misleading with regard to the difficulties of design and construction of the revised embankment. The DOE’s letter (Ref. 115) on 9 August 1999 commenting on the report states that a “wall of this height is rare”. The Shannon & Wilson’s peer review (Ref. 116) describes it as “a unique and challenging project”.

The Embankment report (reference 114) does not make it clear that using only four tiers (walls) for the 135 feet Mechanically Stabilized earth (MSE) retaining wall will be a record setting feat of engineering. It glosses over the extra 20 feet on top of the 135 foot wall as well as the earth under it. The model at the hearing showed less than four tiers which would represent an even higher risk structure. How many tiers are there?

Although the Shannon & Wilson peer review mentions the subject of excavating the soft soils, the embankment report itself is wholly inadequate and did not even address this issue. It appears unaware of the challenges of building on the apex of the area’s aquifer in the middle of a seismic hazard area. The 9 August 1999 DOE letter qualified their comments on the number of wetlands impacted by saying they were relying solely on the report’s statement “very dense glacially overridden soils at depths on the order of 10 to 30 feet” rather than boring logs or other data. In other words, the DOE assessment didn’t address that the embankment cuts through a seismic anomaly area as indicated in the FEIS map (IV 19-2).

The 135 foot embankment with an additional 20 feet of fill on top of it sits on top of an area the FEIS Exhibit IV.19-2 indicates is a seismic hazard. The FAA Record of Decision requires these soft soils to be excavated or stabilized. What are the wetlands impacts form this excavation of soft soils? This question applies to all the soft soils impacted, not just the area under the incredibly tall embankment. See map in Appendix A (shows schools nearby) and F (seismic hazards).

The report does not recognize that the history of SeaTac hydrology is that if you place dry fill on this aquifer, the water moves up into the dry fill. This will create an enormous corrosion hazard for the metal reinforcements in the MSE walls. Although they can size it to assume it will continuously corrode, what will the corrosion products do to the aquifer? How much corrosion products will there be? What is the added cost to oversize the steel so it can sit in water? How long before our drinking water gets contaminated from the degrading materials? The water under the airport also travels in underground springs to Puget Sound.

If polymers are used for reinforcement in the MSE walls, there is very limited data on their longevity (reference 124) and none that I’ve been able to locate so far that considers the impact of airport contaminants on them. The oldest MSE polymer reinforced wall I have been able to locate to date is under 15 years old. How old is the oldest polymer reinforced MSE wall that is over 8 feet? What height is it? What contaminants are in the area? Will the plastics ultimately contaminate the water leading to an increase in health problems such as breast cancer (ref. 78 and 149 )?

Why wasn’t the risk of contamination of the aquifer, and eventually our drinking water, from degrading embankment materials considered in the embankment report? From this perspective wouldn’t a concrete dam be safer?

What are the environmental impacts to repair the MSE walls? Will it require the closure of the Third runway to repair? What life will it be designed to?

Regardless of whether four or seven tiers are used, the wall will present a far greater bird hazard than any responsible wetlands mitigation in the area would ever do. It would provide a great nesting site.

The tiered wall also creates a navigational hazard to pilots when they use the distance to the ground as a location indicator. The only response that I’ve had from pilots on this subject so far, that hasn’t been a four letter word, is “despise it”.

How will the 2 to 1 slope fill on top of the 135-foot embankment be kept in place during heavy rains and earthquakes?

How many of the other tall walls in the world have additional fill on top of them? Are any of them actually about a 170 foot embankment like this? What are their reinforcements? What types of soils are these TALL walls built on? How close were the drinking water sources to the stabilized soils, if stabilized soils were used?

In addition to comparing the details of this wall to the walls in the embankment report, please also compare the proposed MSE wall construction to the award winning 1997 Grand County wall whose picture and description on the internet appear to be similar (Ref 188). This reinforced soil retaining wall used split-faced concrete blocks and geosynthetic reinforcements and set a world record by being 55 feet high.

Why was only 50 feet allowed as a buffer for one side of Miller Creek and 100 feet for the other? Both the proposed 30 feet and 50 feet buffers are inadequate. Aren’t you discriminating against the east bank of Miller Creek to save construction costs? Normandy Park requires a 100 feet buffer from Miller Creek to build just a deck. The buffers are too small. How does this measure up to the proposed 300 foot management area beside salmon bearing creeks in the new proposed King County Comprehensive Plan?

What are the shadow effects to the quality of the land beside Miller Creek? What are the direct and indirect effects of these massive shadows?

The October 1999 Geotechnical Journal indicates standard Geotechnical surveys will not detect all soft soils (Ref. 117). It mentions a bridge in California failing an hour after an earthquake. It is the effects of gravity on soft soil deformation, deformation that can continue long after the earthquake is over, that contribute to making soft soils such a hazard.

The October 1999 Geotechnical Journal also discusses the load of embankments on seismic anomalies, amount of increased deformation due to the presence of even a 4 mm layer of soft soil, and safety factors for various embankment slopes (see references 117-121). These articles provide the reasons for the following questions:

· What measures been taken to ensure all soft soils both on the surface and underground are identified? Have there been any geotechnical surveys that were specifically looking for soft soils been conducted?

· Will soft soils be excavated?

· If yes, when a seismic anomaly is adjacent to construction will it be excavated too?

· How many additional wetlands will be impacted by the excavation of the soft soils?

· Has the FAA Record of Decision potentially already been violated due to lack of adequate geotechnical surveys?

· Approximately how much additional earthquake damage will Highway 509, the highway overpass over 160 St., Sunnydale Elementary School, Miller Creek, the homes and businesses near the tall embankment sustain due to of the interactions of soft soil near or under the embankment?

· How will this increased earthquake hazard for the nearby highways and properties be mitigated?

· Will the Port pay for earthquake insurance or buyout the area?

· What safety factor is proposed for the various embankments? Has its selection been “cookbook” or based on a thorough understanding of the additional complications such as the aquifer and underground springs, additional storm water since the Third runway is now 14 feet lower than the other runway (ref. (aaa)), seismic anomalies, aircraft vibration, the record setting aspects of the tiered wall dimensions, impact to wetlands if the fill in the 2 to 1 slope area on top moves, possibility that the east-west earthquake fault running through Lake Washington slants under the airport, etc? Note, earthquake data was submitted previously so is not repeated. See also Reference 171.

Have more traditional tall MSE embankments with at least six or seven walls spaced at least 1.5 meters apart rather then four tall walls been considered? Of course, this would create an even greater bird hazard by creating even more wall ledges to nest on but wouldn’t it be more similar to current practices? Aren’t the risks of degradation of embankment materials and the subsequent difficulties of repairs, risk to the aquifer and risk to the creek, larger with MSE walls than an arched concrete dam? Wouldn’t a concrete dam require fewer repairs?

Why wasn’t an arched concrete dam given more serious consideration? Shouldn’t safety be more important than money considering its failure could kill multiple salmon bearing creeks as well as have many other harmful effects? Don’t we need a long term wall that has lower design risks with a longer track record?

Procedural Note The embankment report I referred to here had no date on my copy (reference 114). The DOE letter dated 9 August 1999 to Tom Luster did not indicate what version had been reviewed. The Peer report by Shannon & Wilson was dated March 27, 1999 but did not indicate a draft report date. I have no way of knowing if we all evaluated the same or different versions of the same report.

Embankment needs to be higher to reduce Pollution

The removal of the trees to date makes the aircraft noise sound as if someone added an amplifier. The new wall that runs east-west at the north end of the airport greatly increased noise even though I believe they made an effort to avoid increasing noise. The embankment could use noise suppressant features and extend at least as high as the old trees that had acted as a noise buffer. This is much higher than currently proposed but is feasible with a concrete dam. This higher wall will also eliminate the problem of the 2 to 1 embankment fill on top of the 135-foot embankment. It could also contain the storm water and de-icer runoff and divert it into the pipe they are required to install to send storm water to Metro instead of dumping untreated contaminated water into Puget Sound by Des Moines beach as they do currently. (A lawsuit was required to get for AKART to require the use of METRO. Only time will tell if they will really do it.).

Either wall design will eventually ruin Miller Creek and the watershed. If you decide to allow the Port to build this dangerous runway and wreck the watershed, at least you could force them to build a safe wall with pollution monitoring devices.

Slopes too Steep

To preserve the nearby wetlands, all slopes should be approximately 10 to 1 in accordance with the 1998 King County report guidelines (reference 113). Senator Patterson will be supplying a copy of this report with her comments. Those not impacting wetlands should be at least 3 to 1 due to the seismic hazards in the area. There appear to be even more 2 to 1 sloped embankments than the EIS had proposed. See Appendix F to convert slopes to foorprint size.

Seismic Hazard Analysis Still needed

The EISs treatment of seismic hazards was inadequate. It did not even include a map of area faults or provide an epicenter maps This is standard procedure for Army Corps of Engineers according to Army Corps Engineering Manual EM 1110-1-1804 Geotechincal Investigations. Although this standard doesn’t apply to airfields, isn’t it common sense for SeaTac to have to do this too? Considering it was the epicenter for a 1965 6.5 quake and we just had two quakes centered across from the airport by Maury Island and another one just a little further north. Prior to the second runway, the 6.5 magnitude intraslab quake below SeaTac Airport killed seven and caused $50 million in damage (Ref. 171). Imagine the damage if the third runway project proceeds – three runways and steep embankments.

A detailed seismic analysis is needed for the entire project, not just the 170 foot embankment (170 feet includes fill/land on top and bottom). The fuel lines also should be evaluated.

Soil stabilization

What materials can you use to stabilize the soft soils that will not ultimately degrade and harm the environment (creeks with salmon and our drinking water)? How can you stabilize all the soft soils loaded up by the embankment?

How do you Mitigate a Hazardous Man-made Waterfall

Deicers are very hazardous to the environment. A’ very toxic stew” according to Cancilla, an environmental chemist. He has identified toxic organic compounds, tolytriazoles, to be in the ground water near a major North American airport (Ref. 64). During the last submittal you were provided information on how a very small amount can rot the stomach of fish (reference 62 and a cassette tape on the subject (reference 11). Canada now regulates them.

Note, “Report on Carcinogens”, which will be released soon by the National Toxicology Program, will identify greater cancer risks for ingredients in deicers (reference 82). This risk is in addition to the risk they pose because they use up the oxygen in the water, mutagenic threat (ref. 63) and toxic threat (ref. 62). The Human Society in Chicago has recently been instrumental in obtaining government funding to monitor de-icers due to health concerns relating to animals such as dogs that drink contaminated water.

Particularly since the runway is 14 feet lower than originally planned, there will be large quantities of contaminated water flowing down the embankment into Miller Creek. Will it be captured and sent via sewer to Metro? The embankment report did not discuss this, or other drainage issues. Why aren’t deicers pads or infrared deicer facilities MANDATORY mitigation. Other airport expansion projects include them. Deicing occurs year round at SeaTac. See also subsequent sections herein that discuss deicers.

Approximate location of Huge Embankment Inadequate Information

The Embankment report only provides an approximate location. Considering the large error on the location of Miller Creek, shouldn’t we have a more precise location of this record breaking bird nest structure?

Detailed Modeling in conjunction with Schedule Needed for Embankment Feasibility Study

The geology, hydrology and construction issues of this situation are so unique and unusual standard engineering approach to the huge embankment wall is too risky. A geotechnical survey that identifies all the soft soils (even if only a 2 mm layer) needs to be conducted (ref. 117 Kokusho, pg. 817). The properties of the existing soils should be measured due to conflicts in boring reports (References 7 and 8) as well as some of the ramifications of another ground water report (ref. 6). With this information, then a finite element model can be used to evaluate the feasibility. Associate Professor Fox of University of California (ref. 119, page 847) discusses finite element modeling. Although I do not recommend the solution graphs in that paper for this project because of the presence of soft soils, the paper provides rationale for the finite element modeling approach. The source of the fill and its specific properties will also be needed for the model. The quality of the fill needs to be verified to ensure that the published correlation between relative density, confining pressure, and penetration resistance are applicable for this project (Ref. 118, Lee Pg. 849). Because of the long construction schedule, the change in properties due to hydration need to be considered.

This detailed analysis is even more important for the MSE walls than if a concrete dam was going to be built. One wrong parameter and we could have a large environmental disaster that our watershed can not recover from and we may kill people as well. Is Sunnydale Elemnetary School , a historic landmark, still used as a school at risk from soft soil interactions resulting from an earthqauke?

Shoreline Act Compliance Should be Required

The Port has ZERO credibility with activists of this area, is a known repeat environmental regulation offender and should NOT be allowed to deem the project ”outside the jurisdiction authority of the Shoreline Act of 1971”.

The proposed Auburn mitigation falls under the Shoreline Act. These wetland plans undo much of the area’s wetland planning that the Auduborn Society has worked for years to help develop (see their April 9, 1999 hearing comments).

Also, barging, which is inevitable if you use realistic traffic models, will fall under the Shoreline Act. The pollution from over a 1000 barge trips a year, for years, is too great to ignore. Please see Maury Island information in Appendix E. If the fill comes from Canada the total pollution will be even greater. Rumor has it the proposed Alaska fill site is unacceptable.

It is unfortunate that the Shoreline Act, according to Tom Luster of the DOE (3 November 1999) does not apply to the construction at SeaTac. If an embankment failure occurs, during or after construction, it will destroy much of our last remaining wetlands in our watershed and critical near shore habitat. Please also see my “near shore habitat” comments that follow.

Near Shore Habitat Endangered

What travels down the creeks ends up in the Puget Sound and impacts ell grass. Puget Sound is less than 10,000 feet away. Normandy Park Cove is one of the last remaining salt water marshes and needs to be protected. De-icers and contaminated sediment coming from the airport with damage the near shore habitats. Puget Sound has some of the most contaminated sediment n the country (Ref. 34). We should not make it worse for an obsolete runway that costs a fortune and is UNSAFE!

Eel grass is also present at the mouth of Des Moines Creek. The Maury Island near shore habitat issues apply to this permit as well. See Appendix E. Clean Water Act and NDES Permit Need Enforcement

Current practices at the airport are unlawful and need to be under control before any additional permits issued. Also, the Port admitted in their Auburn Wetlands mitigation response to comments that “Best Management Practices” didn’t work for North Employee Parking Lot which represents about 1 % of the Project fill requirement, so how could they ever hope to build the Third runway? Some of the issues include:

· Outfalls with pollution exceedances were renumbered and it was not admitted by the DOE until AFTER they had officially responded to NPDES comments and issued the permit.

· Ongoing NPDES violations. To be covered in detail by others.

· SEIS does not provide adequate detention facilities. The Aquifer study will hopefully identify the real quantity needed.

· Des Moines creek water classification needed. To be covered in detail by others.

Ground Water Study Makes Mockery of Public Comment Process

The FAA Record of Decision requires a ground water study to be conducted. This was in part precipitated by Seattle’s Water Department’s SEIS comments that the water be indemnified due to contamination risks. The DOE recently informed us that we would receive the DOE’s response to comments on the Ground Water study AFTER the study is completed. They were due August of 1997 and now we can expect them THREE years later than planned. Since the study will already be completed there will be NO opportunity to address our drinking water concerns. The Study was absurdly small in scope and did not even investigate the known areas of contamination. See Water Appendix for additional details.

Issuing permits prior to the completion of the study, since the study is required by the ROD (Ref. 40), would be inappropriate.

Aquifer Impacts Still Unknown

The local area residents’ perception that the water table has changed and that the area is experiencing more landslides and street “sinkings” than in the past continues. We have had two failures on First Ave. South (one related to a steep slope by Miller Creek and the other due to a pipe) and have had to do extensive landslide repair near Three Tree Point.). We must wait for the Highline Aquifer study to determine if this is a coincidence or a result of the bringing in approximately 3% of the fill to date. (Actually, I have my doubts a mere $500,000 can even come close to addressing all the aquifer impacts).

Note, the Highline Aquifer was a critical source of water during an unusual dry spell in the early 1990’s for Seattle Water Department. They use Highline aquifer water so they can use less Cedar River water. This minimizes the impact on the salmon in the Cedar River during dry months such as August. So there are now Endangered Species Act implications beyond just those associated with creeks near the airport. In normal years they generally obtained about 10% of Seattle’s water from Highline. Since construction began near their wellhead, they have not been using Highline water. Both Highline and Seattle Water District have raised utility rates to search for new water. The additional impervious surface reduces the aquifer recharge making less water available.

Note, also the court case since the April 9, 2998 that was brought against the Port by Highline Water District regarding water rights. Even if the Highline Water District settles with the Port in a closed door session, the ACC may challenge the legality in court.

It should also be noted that Federal Way drinking water is obtained from an aquifer that is connected to the aquifer under the airport. SeaTac is the appex and it flows southward to Hebelos in Federal Way as well as northwest towards Longfellow Creek. The Tacoma water supply is also connected.

The amount of water needed to keep construction dust down and our car windows clean enough to see through has not been addressed. If the summer /fall 1998 haul season, which involved 55,000 trucks, and the much shorter haul season this year are any indication, residents will need to wash their car windows and TV screens daily.

Contamination from Diffusion

Should the issues raised in Wood’s article “Intragranular diffusion: an important mechanism influencing solute transport in clastic aquifers?”(Ref. 159) be considered for our aquifer. This report indicates “that diffusion can significantly affect the transport of solutes in sand and gravel aquifers where advective velocities are high ({greater than} 0.4 m/day).” It also discusses fractures into surrounding rock. Has the most conservative approach been used to estimate contamination rate? Considering both Seattle and Highline Water departments have raised utility rates since the approval of the Third Runway, to fund their search for new drinking water sources, the importance of preserving our drinking water should be of prime importance. (See Seattle Water Department letter in SEIS comments asking for water costs to be indemnified!)

Doesn’t the seismic characteristics suggest that till fracture could, or perhaps, already has occurred, which would speed up contamination (Ref. 171)?

Also, a number of wells were closed as a result of previous airport construction. Do they provide a faster contamination route as well?

Soil transmits vibration into heart of Normandy Park

A warehouse construction project just south of the airport as well as the filling of the south runway safety area caused considerable vibration that was felt many blocks away and set off motion sensor alarms. The warehouse project was forced to discontinue Saturday morning operations due to the large number of people it was disturbing over 16 blocks away. Has all the vibration impacts been considered. Do you realize that it is like living on a waterbed the way vibration is transmitted in this area. Do you really have a clue as to what this soil is like?

Bottomless Pit that you can stand on

We have fascinating soil conditions here. There are holes in the ground that are less than a foot deep. You can pile leaves or lawn clippings onto them so that hole is filled. Later when you return, the hole will be back. It appears to be impossible to ever fill the hole permanently. I assume maybe there are underground springs carrying the material away.

Water Main and other Potential Utility Impacts Unknown or Ignored

Doesn’t the water main by 12 St. SeaTac have to removed and replaced? Are there any additional wetlands impacts associated with the replacement water main? Will the old one be excavated? What are the contamination risks associated with the water main changes?

Are sewer replacements also planned? If so, do they have wetlands impacts?

During the construction on the east side of the airport there were several utility outage problems and cost overuns to fix construction accidents.

Doesn’t the airport have to put in additional power to handle the increased capacity? Why wasn’t this change included in the project?

EPA Considering More Stringent Arsenic Regulations

According to “Arsenic in Drinking Water” (Ref. 148) “ The U.S. Environmental Protection Agency (EPA) has been considering a more stringent regulation of arsenic in water. A significant reduction in the maximum contaminant level (MCL) could increase compliance costs for water utilities. This needs to be considered if the mining of 10% of Maury Island is to be considered (See Appendix E). It could contaminate not only the sole source of drinking water for Vashon and Maury Island, but then it can be accidentally transported here and contaminate the Highline drinking water as well.

Delegation of Authority to DOE Should be Withdrawn Unless Staff Increased

The EPA needs to withdraw their delegation of authority of the Clean Water act from the DOE, unless additional DOE staff can be assigned, for the following reasons:

· DOE’s excessive delays in providing response to comments on the Groundwater Study after promising the public they would provide them (likely to be 3 years after hearing, 1 year after study initiated)

· DOE’s issuing of the Water Certification in 1998 prior to initiating the Ground Water study required by the 1997 FAA Record of Decision.

· DOE’s outfall data lacks traceability. SDN 002 (Outfall 7) was renumbered SDN 004 (Outfall 11) after a photograph of it spewing oil and grease was supplied to the DOE June 1997. Then the NPDES denied the change (NPDES Response 60C). It later admitted it AFTER photographic evidence was submitted. Outfall 010 has also been renumbered to 015. (NPDES Response 62A). This outfall also had a history of citizen initiated pollution complaints. Data used to prepare NPDES comments was in error since it was based on the wrong outfall data thereby disguising some of the problems.

· It required a citizen’s lawsuit to force the DOE to issue violations regarding retention pond liners that had been missing for 20 years. Onsite inspection by citizens gathered information on 123 violations

· It required a citizen’s lawsuit to improve the NPDES and prepare an AKART plan. (Note, it still did not select deicer pads which is best practices, due to space limitations).

· DOE has allowed ongoing NPDES violations at the airport.

· DOE has insufficient staff assigned to monitor the airport. NPDES needs a full time person.

· It appears DOE issues violations to Port only as a result of massive public pressure augmented by calls from our Senators and Representatives.

· Citizens had extensive discussions with the EPA regarding Clean Air act issues during the EIS process. The EPA hired an outside consultant who had similar concerns as the Citizens and EPA staff. Suddenly the DOE and Governor issued the Clean Air Certification even though the DOE had not commented on any of the EIS’s. There was insufficient time for the DOE staff to have evaluated the issues properly. Current operations and delay times at the airport are just one set of data that demonstrate that the EIS assumptions were ridiculous then, and still are absurd. The model assumptions were intended to circumvent the Clean Air Act. (See Appendic C).

· DOE has refused to enforce Shoreline Act regulations when requested by the City of Burien on the grounds of insufficient staff according to Kitty Milne at a fall 1999 CASE meeting.

· Letter referenced by Senator Julia Patterson at the 3 November 1999 Hearing regarding “creative” ways to approve this permit.

Use of Northwest Ponds Allowed?

Is the Port’s currrent use of the Northwest ponds legal? Others will cover this topic in detail.

Endangered Species Impacts Still Unknown

The Endangered Species impacts need to be addressed. When the DEIS was written there were several nesting bald eagles pairs in the area but the DEIS said they weren’t eagles at the airport because at a marina, in another city, the eagles were not flying towards the airport (back when they were endangered). Back when eagles were on the endangered list, when drawing the boundary of the study area for endangered species Schapiro and Associates drew a curved line rather than using a square that would have included a bald eagles nest. There were 12 bald eagles at football game by the airport fall of 1998 so you can imagine how many there are in the area. The Master Plan Update never did a credible Endangered Species Assessment. Now bald eagles are off the endangered list but other creatures are still on the list or being added to it. Coho was listed as a candidate species July 1995 yet where is the discussion in the EIS about the coho in Miller Creek, Walker Creek and Des Moines Creek? A study carried out by the State department of Fisheries suggests that the upper part of the Creek could support an annual spawning escapement of between 500 and 1,000 adult coho” (U of WA Ref. 139 referring to Ames Ref. 140).

See also “Aquifer Impacts” regarding Cedar River salmon impacts.

Isn’t Longfellow Creek in West Seattle, another salmon bearing creek, fed water from the Highline aquifer? The salmon in this creek also need to be considered.

Chris Gower submitted comments (Ref. 172)on salmon to supplement his prior comments, so I will not continue on that subject.

In one of the EIS’s response to comments is a letter from Fisheries that made it clear they were relying on the Port and FAA to identify any endangered species rather than conducting a survey. The Corps needs to act a watchdog, and require a real Endangered Species assessment of the quality they recommended for the Lone Star mining of Maury Island earlier this year. Auburn wetlands won’t help endangered frogs here.

Hazardous De-icers and Anti-icers in Creeks and Aquifer

Reports such as Reference 62 (Hartwell) fish studies concluded “

“The propylene glycol anti-icer solution was found to be more toxic than ethylene glycol de-icer solution by two orders of magnitude... Both types exhibited greater toxicity than literature values for the primary ingredients...It appears the additives are the major sources of acute toxicity rather than the glycols...The ethylene glycol solution elicited respiratory epithelial “disruption” and renal damage, and the propylene glycol solution caused proliferative inflammation and delamination of skin layers”. The irony of this situation is that the propylene glycol was supposed to be more environmentally friendly than the ethylene glycol.

The threat of de-icers is now even more significant because of the salmon. Also, an increase in the cancer risk rating for chemicals that are suspected to be in de-icers will be released in a report that is due out soon (reference 82). See also “How do you mitigate a Hazardous Man-Made waterfall” herein. Our drinking water is also being put at risk.

De-icer Pads should be Required

Other recent airport expansion plans include de-icers pads due to the serious threats de-icers pose to the environment. Canada even regulates them. Sea-Tac on the other hand ruled them out de-icer pads because they take up too much space (ref. 130, IWS). Lisa Zinner of the DOE when interviewed by Ross Simpson (Ref. 11) said:

“It doesn’t work for Sea-Tac to do what the new Denver Airport has done, which is have a dedicated de-icing area, and that would work the best, but its hard to go in and retrofit an airport to do that.

How can we fit a runway but not de-icer pads? Reviewing the cost numbers in the following table taken from the April 1998 Kennedy and Jenks Consultants Addendum to IWS engineering Report, don’t you think the real reason de-icer pads were eliminated as mitigation for the second runway, was cost?

Table 3 Comparison of Costs for AKART Alternatives to Reduce Pollution

Alternative	Construction Costs ($MM)	Annual Operating Costs ($MM)	Ref. 130, Addendum IWS,
A1	20	5.8	Summary Table on Page 4-5
A3	26	2.9
C1b	95.7	6.0
B1 Centralized Deicing Pads	95.7	6.0
B2 North deicing pads	51.5	3.3

De-icer pads should be MANDATORY mitigation of the proposed Third runway is build, particularly with the close proximity to Miller Creek, its elevation being lower than the existing runways and the manmade waterfall cliff referred to as an embankment.

Why was enlargement of Borrow site 4 not mentioned in Permit?

Why were the borrow pit site boundaries changed? Site 4 was enlarged and Site 3 reduced. In the SEIS response to comments, the Department of Natural Resources agreed that the Master Plan borrow sites did not require strip mine permits because they thought they were contiguous property. When this error was brought to the attention of the Director of Public Lands, the Department of Natural Resources conducted a field survey and reversed their SEIS comments position. Borrow sites 1, 2 and 3 all require Strip Mine Reclamation Permits in accordance with RCW 78.44 (Ref.51). The Port is well aware of this.

Why weren’t these borrow pit boundary changes identified on page 2 of the permit? Shouldn’t the wetlands permit at least mention the need for the strip mining permits?

Permit Wetlands Mitigation Inadequate

We have flooding and landslide problems already. We need in basin mitigation. We need the wetlands to function as air, water and noise pollution buffers also.

How can mitigation be done without violating the terms of the Kludt settlement (Ref. 141)? Helen Kludt will be supplying comments on this subject.

Since Highline Water District owns the water rights for water needed for mitigation, where will the Port get the water for mitigation (Nov 3 hearing Highline Water Commissioner testimony)? Will citizens allow Highline Water District to give their water away for a project that reduces the total amount of drinking water available even if NO contamination occurs?

Oil tank Clean up should be mandatory

Are the oil tanks from the second runway or the third runway buyout? The clean up of home oil tanks left behind from the second runway had not been done as of the July 1997. The permit application numbers appear low and inconsistent with numbers provided verbally by the DOE July of 1997 at the Burien Library in a special meeting with CASE if this includes the second runway cleanup. Please clarify. You may be missing hundreds of home heating oil tanks if this figure represents both the second runway and third runway tanks. If it just includes the third runway buyout, since homeowners are required to drain tanks, it shouldn’t count as mitigation.

Best Management Practices Inadequate per Port

The Port of Seattle’s 9 September 1998 response to my comments on the “ Determination of Non-Significance of the Proposed Action for the SeaTac International Airport Master Plan Improvements – Wetland Mitigation” (the Auburn wetlands proposal) Barbara Hinkle wrote:

“The Best Management Practices (BMPs) at the parking lot did not function as needed . . . Some extremely fine sediment was carried into Miller Creek . . .The Port has learned from the parking lot experience that conventional BMPs, approved and implemented at construction sites throughout the region, are inadequate to completely prevent turbid water discharge at Port projects.”

Appendix H contains a copy of the entire letter.

If they can’t build a parking lot, how can they build a record setting embankement in the middle of a seismic anomaly that requires moving a salmon bearing stream?

EIS Maps misleading

The colored version of the map on page 2 in the 404 permit application shown at the 3 November hearing indicates that the Third runway has two 500 feet by 1000 feet long runway safety areas. Since this is the FIRST map that has ever been included in reports for public comment that identifies this additional 2000 feet, it should be reformatted to make it legible in black and white and distributed to the public if the permit is amended. I learned that the EIS maps did not include the runway safety area at the Corps of Engineering hearing April 9, 1998. I then reviewed the 1998 PCF application. It says the safety areas are“500 feet in width and 1000 feet long from the end of the runway threshold each end” on page B-19 underline added for emphasis) but they appear shorter on the map. To further complicate matters, the scale on the HNTB Figure 1 map legend in 1998 PCF is wrong so I still wasn’t sure until the 3 November 299 hearing. Thank you so much for bringing the HTNB model.

The map discrepancy may seem trivial but actually the additional 2000 feet significantly increases impacts, especially noise and wetlands. Did ALL the consultants and modelers during the EIS know that ALL the maps were missing 2000 feet of pavement? I know it was new information to some veteran activists at the November 3, 1999 hearing.

SEIS Underestimated Noise

Excerpt from Reference 200 indicates that the noise impact assessments in the 1996 FEIS incorrectly assumed the homes in the area have more insulation than they really do.

The 1996 FEIS Response, R 7-35, to my question regarding the noise model assumption that we live in cold climate homes is that only 10% of the homes in this area are “cold climate” homes (brick or stone). The noise impact assessments related to health need to consider we hear much more noise than a cold climate home.

Can, or can’t they? That is the question. I’m referring to Type V aircraft. Can the Third runway fully support them? What does the noise model assume? According to the FEIS page R-126 the Third runway is too short for aircraft such as B-747, DC-10, MD-11, L-1011 or B-767 to land on. However, a pilot assures me, he does it all the time in Portland. He says that statement is true ONLY for international flights. Other portions of the EIS’s say the runway can accommodate 99% of all types of aircraft. Has the noise model underestimated this noise?

The SEIS underestimated noise. The ongoing Part 150 study has uncovered that not all aircraft were represented accurately. I believe it was the hushkitted ones that were underestimated. Ref. 184 dated April 1999 states:

“Hushkitted aircraft will soon drive airport noise contours but the FAA’s Integrated Noise Model does not yet include a representative sample of hushkitted airplanes. . .”

The aircraft noise has increased enormously with the increase in traffic at Sea-Tac. When they cut down the trees west and south of the airport (giant warehouse replaced mini forest), it was like someone hooked up an amplifier. The prime reason the EIS models showed a noise reduction is they switched to a newer version of software. Garbage in – Garbage out.

Please see comments submitted to the Part 150 study in the Noise Appendix I.

SEIS Air Traffic Safety Analysis Outdated

Why hasn’t an updated aircraft accident risk analysis been performed considering the increased Boeing Field operations and the increased operations now inevitable for Sea-Tac if the Third runway is built? Although it is true as the SEIS states there is not a direct relationship between number of operations and the number of accidents, it is best approximated with an exponential equation if you don’t have access to sophisticated probability models such as Blunder (Ref. 109, 110). Some key points are listed below:

· Runway Incursion/Accident Risk now greater than the 21 % calculated using the DEIS number of operations (FEIS page R-43). Air line Pilots Association (ALPA) indicates the increase in incursions increases exponentially with the increase in number of operations (see references 106 through 113 )

· Reduction of Runway Incursions Mandated by FAA due to large increase in accidents (Ref. 1612, 163. Also see next section)

· Boeing Field, 1^st Ave., and 24 St. Mistaken for Sea-Tac already on multiple occasion

· An aircraft crashed onto International Boulevard by the airport in 1996 (ref. iii) after scaring children at school who thought it was going to crash at the school (in the past airplane parts have fallen at children’s feet while at school so this is a normal fear for flight path schools).

· Concrete wall more dangerous to aircraft than a embankment with a gradual slope

· Boeing Field growth impacts SeaTac since they use the same airspace (ref. lll)

Considering the recent historic flight test that just occurred (Ref. 204), it appears the reality of 2500 foot spaced runways operating independently will be implemented BEFORE the Third runway could open. This means that the theoretical limit of operations is even higher. Therefore, if the water and air models are rerun, they will not pass. (Personally, I believe that some of the pushers of this project have known this all along and intentionally misled the regulatory agencies as to the number of operations. The NASA work has been ongoing for quite some time).

New Procedures to Reduce Incursions May Result in Excessive Third Runway Delays

“Runway incursions are becoming an increasingly “hot topic” in everyday operations for airline flight crews” according to Captain Duke in the article he wrote for the Air Line Pilot (ref. 117). In that article he states that “ALPA and Mitre have recommended that the FAA change FAR Part 91.129(l) to require specific clearance to cross all runways.” If this new rule is implemented to reduce the risk of incursions, how much increased delay will there be? How much additional pollution?

The 21% increase in incursion rate in the DEIS has not been updated for the increased number of operations. What is the increase in accident rate now? According to Lincoln Lonnsbury “Runway collision risk and the runway incursion rate grow exponentially as a function of the slightest increase in traffic volume”(ref. 102). The article reports a 67% increase in incursion rate for a 2.41% increase in traffic volume for towered airports.

SEIS Bad Weather Delays Misrepresented

NASA report CR-1998-207675 lists Sea-Tac as “Arrival Delay Factors: None” (Rref. 116). When weather is a factor, it is listed as a delay factor. (Old data: ref. i, Transportation expert testified at a Congressional hearing that the Third runway, may make delays worse since it requires taxing across two live runways).

It is well known within the aerospace community that Air Traffic Control (ATC) issues are the real culprit. Pilots cleared to land short refuse and instead stay in the air until they can get instructions they consider safe. Airports such as Chicago schedule more aircraft to depart at the premium times than could possibly ever get off the ground. These delays have a domino effect on the entire air traffic control system. These are just examples and are not meant to convey all the reasons for delays.

Note, sea-Tac peak operations are in the summer and the majority of the “bad weather delays” are in the winter.

Purpose of runway Varies in Documentation

Port of Seattle Commissioner Claire Nordquist was recently quoted as saying “The biggest single issue facing the port is infrastructure – building the new third runway and roadways, and terminals, doubling the airport’s capacity” (Ref. 136, Oct 11, 1999). Please note, the Port typically emphasizes capacity to the public. The 1998 PCF application also emphasizes capacity more so than bad weather. The project will violate the Clean Air Act if additional aircraft are used in the analysis. Considering the recent flight test for NASA technology that will allow fully independent operations for 2500 foot separation, increasing capacity is a more plausible reason for the expansions than “bad weather delays.

However, even with two fully independent runways. Sea-Tac can not handle future growth. In the 1993 Airtrac report (State Air Transportation Commission) wrote:

“even with a third runway, the design capacity of Seattle-Tacoma International Airport could be reached between the years 2005 and 2010.”. This report also recognized health concerns forgotten by the time the EISs were written.

In a Port of Seattle letter dated October 31 1997 Gina Marie Lindsay, the Aviation Director wrote “I do not want to mislead you, the third runway is being built for two express purposes. First, to allow the airport to function more efficiently and safely in poor weather and low visibility conditions. Second, the runway will assist in meeting projected increases in traffic into the next century”.

Compare the above statements with the 2-R response given in the Draft SEIS when they were questioned about Albuquerque’s rejection of a 8,500 foot runway due to length and fill issues similar to ours (Ref. sss):
“ Different conditions exist at SeaTac, and as a result, a different need is being satisfied. As is described in the Final EIS and Supplemental EIS, the purpose and need being satisfied at SeaTac is associated poor weather related delay arrival.”

Of course, if you are the pilot dealing with four dependent runways in the air (three SeaTac and one for Boeing Field (the other one at Boeing field is seldom used), increasing capacity doesn’t make sense. It greatly increases the risk of accidents. PLEASE RUN THE RISK ANALYSIS FOR 630,000 operations and a new higher number that considers the additional operations that technology will allow. Please consider all flows including all nearby airports. The earlier analysis neglected one Boeing Field direction assuming air traffic was minimal (Ref. 152). The proposed Third Runway will NOT increase safety and according to the Congressional testimony of a transportation expert is more likely to INCREASE delays. (Note, testimony was based on EISs which assume the usage of the runways will be as presented in EIS).

Rejected for Second runway due to Environmental Impact. What’s different?

The 12 St. runway location was rejected during the second runway siting because of environmental impacts. Now we have a much better appreciation for the health hazards, a water shortage looming on the horizon and salmon bearing creeks to consider. How could the site have been unacceptable then, but now be acceptable?

Even after the second runway was built, the September 1985 Master Plan Update (Ref. 133) states on page 2-3:

“New major runways at Sea-Tac will not be considered. . . and (c) any new runway would have a large environmental impact.”

Cost/Benefit Analysis Outdated

There are insufficient funds to build the Project safely and to mitigate it. It is not fiscally possible to do everything that needs to get done without bankrupting King County or raising per ticket user fees to at least $60 per ticket. Market forces would never support a $60 user fee. The airlines were told in writing it would be under $12.

Second runway mitigation is incomplete due to funding and it was far more practical than this one.It had the same problems. The Port greatly underestimated the number of operations. Some key cost issues are listed below:

· Only Partial FAA Funding Received (1998 Passenger User Fee Application)

· Unplanned upgrades to infrastructure such as mechanical and power systems

· SEIS provided return on investment numbers for different scenarios but the Port only quotes the rosy picture one. If you use today’s published cost estimates in the other cost scenario, King County Council would have rejected the Project. The SEIS “worst-case scenarios” lists only a 10 million net profit assuming a $587 million Third Runway (1997 SEIS, page F-43).

· The 1998 Passenger User Fee Application reveals most airlines have objections to the Third Runway based on cost and erroneous delay analysis. The Airline that supported it, was in recently at a Port meeting objecting to the costs. They are projecting a significantly larger user fee than planned.

· Fill availability and transport issues. The EIS used about $3 to $12 per cubic yard (draft SEIS page F41) but the “onsite” sources are dwindling and the distance it needs to be hauled increased

· 1998 Passenger User Fee Application Relied on Port’s ability to raise real estate taxes to be able to obtain bonds. See Initiative 695 section which follows.

Funding plan needed that considers Initiative 695 Impact

The Port still hasn’t paid its second runway mitigation bill. Ask those people waiting for noise insulation from a runway that opened over 20 years ago. How will the Port pay for the Third runway? Although the Port kept promising in speeches to the public that they would NOT use real estate levy money (Draft SEIS page F-42) taxes to fund the Master Plan Update, the 1998 PCF written record contradicts that position. The 1998 Passenger User Fee Application relied on Port’s ability to raise real estate taxes to assure the FAA that they could fund the project with bonds. The FAA did not grant the total funding requested by the Port and there was an obvious shortfall.

With the passage of Initiative 695, the Port can’t raise taxes without people voting on it. Before they were not collecting their maximum percentage that they could by law, but could have raised it without anyone’s permission. Now the new law is written in such a way that the Port is frozen at the current level we were actually paying, NOT what the Port could have been taking. Raising bond money for a project that airlines such as United have gone on written record that the return on investment calculations are nonstandard will be difficult (reference 45). How low will the business community let our bond rating fall before waking up to the costs of the Third Runway?

Airlines’ Objections to Third Runway Increasing

Alaska Airlines concerns that the Passenger Facility Charges will be approximately $20 were expressed at a 1999 Port of Seattle meeting. I am resubmitting the following quotes from the 1998 PCF application. You were supplied a complete copy by CASE in August 1998. During the PCF process, Alaska Airlines, and their subsidiary, did not go on record as the other airlines regarding costs. However, they have now become more open about their concerns (See also Alaska’a comments in ‘ Alternatives with Zero Wetlands Impacts” section herein.)

“America West questioned the amount of time delay currently experienced at Sea-Tac airport and if a third runway is needed to produce the time savings. “Or is the delay the result of factors beyond our control such as the weather or insufficient utilization of gate/aircraft operations””

“Delta expressed concerns about “the physical costs of the project which must ultimately be absorbed by the carriers and the impact on our operational costs at Sea-Tac. Our calculations indicate that our cost of operations will almost double by 2005. Offset of these cost by resultant delay savings {is} questionable... Additionally, we are concerned because it appears that the Port has not included all runway costs in its estimate....””

“United “disputes the assertion that the a third runway is necessary to eliminate a seven minute delay average delay at the airport” and asserts that “ none of that delay is attributable to the lack of the third runway, but a number of other factors.” United is of the opinion that “the airport’s estimate that a third runway will provide $60 million of operational savings is not supportable using standard business calculations.””

“TWA - in concert with Delta and United - believes that extending the Runway 16L-16R safety area, “instead of building a runway - is the best alternative to address capacity issues caused by warm weather and pacific [sic] Rim operations””

Technology Alternatives

The 3 July 1997 return on investment analysis memorandum (accompanied FAA ROD) states

”All alternatives were dismissed in the early stages of the evaluation, leaving construction of the third runway as the only viable option.”

At the May 15, 1999 meeting held at the Corps of Engineers office technology alternatives were discussed so I will not cover that information here. Appendix J provides an updated status on one technology. The Port has consistently over the entire history of the SeaTac Airport underestimated demand leading to current capacity issues. Had the forecasts been accurate, in the 1980’s we would have started the planning for a new regional airport then. Washington is losing aircraft operations to Oregon, California and Vancouver, Canada while the Port attempts to put a baby bootie on a size 13 foot that will be the most expensive runway in the world on a per passenger or per pound of cargo basis. A private business would NOT undertake this project.

Alternatives with Zero Wetland Impacts Exist

In addition to improving SeaTac with demand management, NASA software that allows multiple airlines to share the same gates and navigational technology, other airports could be used. Page 4-99 of the Flight Plan Project (Ref. 150), for instance, states‘ there are no wetlands located on or immediately adjacent to the existing airport”.

Considering the 1993 Airtrac Washington report (Ref. 135) admits the design capacity for the Third runway could be reached by “2005- 2010” and the FAA Terminal Air Forecast indicates it will be severely congested when it opens, does it really make sense to fill 18 acres of wetlands and damage well over 150 acres of foraging area used by blue herons and bald eagles?

How can you justify filling in the wetlands when the ONLY major airlines that voted FOR the project in the 1998 Passenger Facility Charge Application process is pushing the Technology alternative in the Wall Street Journal (Ref. 191). The article states:

“More than fog cutting is at stake. Alaska Air’s technology –called required navigational performance, or RNP – could bolster the case of environmentalists, homeowners and others battling San Francisco’s plan to build two new runways intended to increase capacity during foggy weather. It could do the same for Sea-Tac...”. It goes on to quote Mike Adams, Alaska Airlines technical manager for flight operations “ People say you need more runways, but perhaps because they’re difficult to build and painful to deal with, maybe we should look at more efficient uses of runways.”

It is the Army Corps of Engineers responsibility to review this Project in light of TODAY’s technology, not the technology that was evaluated back when they hoped to have the Third runway open in 1996. 2009 or 2010 are a more realistic opening time frame. The Port of Seattle is short on money, fill, and real engineering designs.

New Airport Needed Anyway

Although zero wetland impact Alternatives exist that will provide the equivalent capacity that is SAFER than the proposed Third runway, the Third runway is inadequate from a regional perspective. Personally, I have been advocating a new airport, perhaps in Tenino near I-5 and the railroad as well as close proximity to a harbor. Oregon also preferred this site to expanding their Portland airport. After the Third runway was approved, they started pursuing expansion at their own airport. A new airport would be much cheaper than expanding SeaTac. The new Denver airport continues to grow and is a success despite their original construction cost overruns. Passenger Facility Charges have always been BELOW what the airlines agreed to when they approved the project. Denver’s performance has been spectaular, literally cutting the delay hours by an order of magnitude! Unfortunately, our Third runway final bill will ulitimatley be higher than Denver’s was even though Denver had to build cargo and rental car facilities too (Refs. n, 192). The $500,000 state funded Burien HOK study that identified the need for billions in mitigation, just addressed some Burien issues (Ref. mmm) !

Constitutionality of Port Questionable

In the 1940’s emergency provisions were passed that provided power to the Port due to a war time emergency. This power has NEVER been rescinded. It is a special purpose government, in charge of general purpose assets. Others will discuss this in detail.

Port Environmental Compliance and Fiscal Track Record Poor

Port misleading statements and out right lies are too numerous to count. We were promised NO Third runway as part of the deal to allow the second runway. More recent issues include:

· Construction Violations (ref. (fff), Miller creek twice)

· Detention pond missing liner for decades. Took legal action to get agreement to fix.

· Ongoing NPDES Violations

· Misnumbered outfalls (pollution pipes) with no data traceability

· Delayed and Poor Implementation of 2^nd Runway Mitigation. The ONLY reason a large number of homes have been insulated recently is that it is a condition to get the Third runway

· Home insulation is failing and some can’t get their problems fixed (poor workmanship etc.)

· 1998-1999 Airlines’ Objections to Third Runway Ignored

· A Port Commissioner in the newspaper lied to us about property depreciation. They claimed it’s not a problem but the Port had recently settled out of court for as much as $40,000 per home for second runway depreciation. EIS is also in error.

· Regarding de-icers Port Spokesperson claimed ”We recover every drop”(Ref. 64) even though in reality it is dumped into the Sound untreated.

· Reduced the amount collected for real estate tax in 1995, a turning point for the runway approval, but this increased the long term debt to 35%. A reduction in bond rating followed.

· 1998 Passenger User Fee Application Relied on Port’s ability to raise real estate taxes despite ongoing promises to public that this will not raise taxes.

The harsh reality is the required mitigation will not get done in our lifetime.

Look at the Port’s poor mitigation and environmental compliance track record.

It is cost prohibitive if you dare to list all the reasonable costs.

Actions if reissue Permit Application

Hopefully, you will deny the permit, however, if you reissue it instead due to changes in wetlands and lack of sufficient data, some of the key items to incorporate are:

· Include a map that identifies the embankment location, third runway, all runway safety areas, the creeks and tributaries and the seismic hazards area

· Determine total number of wetlands impacted including last remaining buyout areas, soft soil excavation , fill mining and fill transport operations

· Include a detailed description of changes since the EIS with updated CUMMULATIVE pollution analyses

· Deny the use of Borrow pit sites 1, 3 and 4 due to respiratory health, water & salmon impacts

· Identify total quantity of fill, source and transport method

· Provide quantity of uncompacted fill, swell and compaction assumptions

· Provide information on the grades of fill and where they will be used.

· Sources, quality (contamination status), and permit status of potential sites

· Include meaningful mitigation

· Meaningful in-basin wetlands mitigation that will reduce flood risk and keep salmon alive

· Buyout of those with, or susceptible to respiratory illness, as well as those suffering from additional noise exposure from the removal of natural sound barriers. Buyout option should apply to all Des Moines, Burien, Normandy Park and Sea-Tac, South Park, Georgetown, and large fill mining locations if record breaking quantities proposed such as Maury Island

· Earthquake insurance for those between the runway and First Ave. South, Burien

· Provide funds for road repair and other construction impacts

· Require covered haul trucks and limit them to the dry haul season (see FEIS)

· Do not allow hauling to conflict with school bus routes (continue inter-local agreement)

· Require constant pollutant monitoring at the airport for NOx, particulates and hydrocarbons. Set a level at which construction is halted until levels are reduced.

· Require deicer pads and/or infrared facilities.

· Monitor embankment storm water for pollutants. Set limit requiring the temporary closure of the Third Runway when exceeded. Use Canadian regulations to help establish limits.

· Provide additional embankment design information

· Embankment monitoring as recommended by Shannon & Wilson (Ref. 116)

· Seismic assessment of ALL embankments including safety factor with supporting rationale

· Location

· Update purpose for runway (increases capacity, decreases safety)

· Provides mechanisms to encourage compliance

· Require one full time Corps of Engineers engineer for project oversight

· Require one full time DOE engineer for project oversight plus one full time NPDES permit coordinator

· Impose Port funded King County wide lung capacity testing at schools for at least twice a year for the next twenty years

· Require onsite permanent pollution monitoring at the airport of criteria pollutants, fine particulates and hydrocarbons posing the most serious threat

· Set pollution limits that when exceeded airport operations must be cut back (Europe actually shuts down some airports on bad air days!)

· Set emission fees as has been done in some European airports.

· Use noise monitors instead of models to determine noise insulation boundaries. Penalize hush kits.

· Require permanent FREQUENT monitoring of creek water quality

· Identify and monitor for airport specific pollutants in our drinking water that are currently not tested.

· Move the YMCA currently at the south end of the proposed third runway

· Move Kindercare currently at the south end of the proposed third runway

· Move St. Philomena, North Hill, Olympic Elementary, Pacific Middle School and Mount Rainier High School and any others directly under the flight path I’ve forgotten to list.

· Provide air cleaners and air conditioning for Highline High School, Sylvester Middle School, Kennedy High School and the Highline Hospital (west of airport)

· Don’t allow the Port to carry out its plan to shift the overrun burden entirely off the shoulders of the airlines to the taxpayers as a way of getting the airlines approval. Provide stipulations that must be in airlines leases to ensure the airlines pay for this outrageously expensive project.

· Identify funding sources

References and Bibliography (Partial List)

Sorry for the multiple formats but it allows me to find things. If I realized my first letter would develop into years of effort, I would have set up a database and used traditional formatting.

The letter identification switches to numbers.

References using letters

(a) Supplement to the State Implementation Plan for Washington State, Plan for Attaining and Maintaining National Ambient Air Quality Standards for Ozone in Central Puget Sound, January 1993, Amendments June 1994

(b) Sea-Tac Airport Master Plan Update Draft Environmental Impact Statement (DEIS), 1995

(c) Engineer's Personal Assessment of the Sea-Tac Airport Master Plan Update Draft Environmental Impact Statement (DEIS) - Proposed Third Runway, The United States' Most Expensive, Limited Capacity Runway, incorporated into FEIS response appendix.

(d) Sea-Tac Airport Master Plan Update Final Environmental Impact Statement (FEIS), 1996

(e) "State of WA Puget Sound Regional Council Final Noise Decision on Noise Issues", dated 27 March 1996 (bolded by author to emphasize legal title)

(f) Comments on the Draft General Conformity for the Sea-Tac Airport Runway and Associated Development Projects, A. M. Brown dated April 30 1996

^(g) Technical Report #8 prepared by P&D Aviation for Port of Seattle.

(h) Testimony at the Congressional Aviation Subcommittee Hearing by nationally known economist Dr. Lynn O. Michaelis, held March 18, 1996

(i) Testimony at the Congressional Aviation Subcommittee Hearing by air transportation expert, Dr. Stephen Hockaday, held March 18, 1996

(j) Study submitted to FAA by Envirometrics, Dr. Ruby, Smith Engineering & Management, Cutler & Stanfield, dated 6 June 1996

(k) Implementation of an LDA/DME Approach to Runway 16R in lieu of a Third Runway at Sea-Tac, prepared by G. Bogan & Associates, Inc. dated 26 June 1995 (presumably submitted as comment to Draft EIS)

(l) Letter To PSRC President Doug Sutherland, From Pork Patrol, Al Furney, Chair, dated 12 June 1996 - in June 3-19,1996 PSRC correspondence package

(m) "City, State Forces Wrangle over Third Chicago Airport, Aviation Week & Space Technology, 8 April 1996

(n) GAO/RCED-95-35BR (Government Accounting Office)

(o) "Finally ! It's Here (Denver International Airport Opens), Newsweek, 6 March 1995

(p) "Denver International Airport - Economic aspects", Travel Weekly, 2 February 1995 v54, n9, p4

(q) "Montreal Airport never got quite off the ground" Times 15 April 1996 - in PSRC Correspondence package dated June 21-26,1996

(r) Comments regarding adding the part time dependent runway to the MTP. To D. Sutherland PSRC, From A. Brown, dated 15 June 1996 - in PSRC Correspondence package 3-19 June 1996. Special Note the cover letter enclosed a copy of 25 pages of comments dated 11 June 1996. These comments were hand delivered to the PSRC with the CASE comments on June 11,1996 so the July 19,1996v date is incorrect with respect to the pages labeled 1/25 and so on.

(s) "Comments on Public Comment Meeting June 27,1996 - Topic: Proposed Addendum to the 1995 Metropolitan Transportation Plan (MTP) to include the Third Runway", To D. Sutherland & PSRC Executive Board, From A. Brown, dated 7 July 1996 - in PSRC Correspondence package July 10-11, 1996 (enclosure 3 in this Port Appeal letter of August 1996)

(t) Expert Noise Arbitration Panel Hearing December 1994

(u) FAA Hearing June 1995

(v) PSRC Executive Boarding Meeting and Public Testimony, June 1996

(w) Letter (Supplement to FEIS Comments, "Draft conformity analysis does not support your conclusion that the project conforms to the State Implementation Plan"), To D. Ossenkop of FAA, cc Hinkel of Port, From U.S. Environmental Protection Agency, dated 6 June 1996

(x) Letter To PSRC, From D. DesMarais, dated 8 July 1996 - in PSRC Correspondence package June 26 - July 9, 1996

(y) "Executive Board Order, dated April 25,1995", To PSRC, From Ravenna- Bryant Community Association, dated 8 May 1996 - in PSRC Correspondence package June 21-26, 1996

(z) Letter, To PSRC, From A. Brown, dated 10 April 1996 - in PSRC Correspondence package April 3-15, 1996

(aa) "Draft Amendment to MTP -- Third Sea-Tac Runway, June 10, 1996 Order", To PSRC, From North East District Council, dated 28 June 1996 - in PSRC correspondence package June 26 - July 9, 1996.

(bb) Letter, To D. Hinson of FAA, From R. Akers, dated 28 May 1996 - in PSRC correspondence package May 23-29, 1996.

(cc) ECO-088, To D. Ossenkop of FAA, From R. Parkin of U. S. EPA, dated 18 March 1996 - in PSRC correspondence package April 3-15, 1996.

(dd) Response to Requests for Supplemental Review, Addendum to the Flight Plan Project FEIS (1992) and Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport Final EIS (1996), PSRC, 10 July 1996.

(ee) Letter, To PSRC, From City of Normandy Park, dated 9 April 1996 - PSRC correspondence package April 3-15,1996.

(ff) "PSRC's Resolution (A-93-03) and it's Impact on Related Legislation", To PSRC, From H. J. Frause, dated 1 April, 1996 - in PSRC correspondence package April 3-15,1996.

(gg) City of SeaTac Public Works Permit PWD0115-96, Parcel 282304-9016, Issued 6/20/96, Expiration 12/17/96, Contractor Segale, Signed by Bruce Rayburn

(hh) "Number of Dirt Trucks Will Increase, Third Runway", by V. Nordstrom, Highline News, 10 August 1996

(ii) "Study: Bigger airport means more poor kids", Highline News, 7 August 1996, page A7

(jj) "Three Killed, 2 Hurt in SeaTac Wreck", Highline News, 7 August 1996. page A1

(kk) "Airlines Draw Battle lines o n User fee", Seattle Times, 19 June 1996, page D1

(ll) "FAA Plans to Publish Draft Addendum to 1976 Agency Noise Policy by September", Airport Noise Weekly, Volume 8, Number 11, dated 10 June 1996, page 81-82.

(mm) "Briefing Book", Environmental Conservation Division, Northwest Fisheries Science Center, National Marine Fisheries Service, NOAA, January 1994 (entire book but especially page 24)

(nn) "Programs and Accomplishments", Utilization Research Division, Northwest Fisheries Science Center, National Marine Fisheries Service, Seattle, WA, May 1995.

(oo) "Our Living Oceans, Report on the Status of U.S. Living Marine Resources", Unites States Dept. of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service, 1995

(pp) "Transfer of Land for Runway Underway", Airport Noise Report, Volume 8, Number 12, 8 July 1996, page 94.

(qq) "Dramatic Drop in our infant mortality rate", Post-Intelligencer, 2 August 1996, pages C1, C4

(rr) "ATA Questions Validity of Airport Construction Needs Study; Says Adequate Funds Exist for Necessary Airport Projects", ATA News, Air Transport Authority of America, 20 March 1996

(ss) "Rockwell has won back the Global Positioning System (GPS) satellite contract", The Composites & Adhesives Newsletter, July-September 1996, page 3.

(tt) "Notice of Decision by the Port of Seattle", Public Notices, Seattle Times, 8 August 1996

(uu) "Air Pollution, Council's report based on Epidemiological study", by R. Kassel, National Resources Department Council Urban Environmental Program Sr. Attorney, Post-Intelligencer, 16 June 1996, page E3.

(vv) "Flying Off-Course: Environmental Impact of America's Airports", National Resource Defense Council, October 1996

(ww) "Waste Clean Up, Safe and Sound?", Highline News, 23 November 1996, pages A1, A7 (additional information supplied by a participant)

(xx) "Third Runway Battle, The Big Dirt Haul", Highline News, 16 November 1996, pages A1, A2 (Shows map of potential haul routes referenced in FEIS (ref. d))

(yy) Engineering Principles of Ground Modifications, by Manfred R. Hausman, McGraw-Hill Publishing Company, New York

(zz) Soils in Construction, Third Edition, by W/. L. Schroeder Prentice Hall, New Jersey

(aaa) "Sea-Tac Third Runway to get its fill of dirt", Seattle Times 15 August 1996 pages A1, A19 (runway 14 feet below FEIS assumptions)

(bbb) Letter to FAA. D. Ossenkop, From Mary Riveland, Director WA DOE, dated 20 December 1996

(ccc) 49 U.S.C, 47101 et. seq. (formerly Airport and Airway Improvement Act, Section 509, paragraph (7) (A))

(ddd) Washington State Legislature Release, " South King County Lawmakers Question Approval of the Third Runway Plan", dated 20 December 1996.

(eee) "DOE Gives OK to Runway", Highline News, Page A7, December 21,1996

(fff) " Dust Emissions at North SeaTac Park", Puget Sound Air Pollution Control Agency Notice of Violation No. 35809, Registration No. P371603874-75, Regulation I, Section 9.15 (a) : Emission of Fugitive Dust without use of best available control technology, 8 August 1996

(ggg) Letter regarding Snow Equipment Storage Shed Environmental Checklist and Determination of Nonsignificance, From Port of Seattle, Barbara Hinkle to Debi DesMarais, 25 July 1996

(hhh) " Asbestos Delays North SeaTac Work", Highline News, 13 July 1996, page A8

(iii) "Plane Crashes at SeaTac", Highline News, 24 August 1996, page A1

(jjj) "Girl Struck, dies in I-5 Jam Detour", Highline News, 4 September 1996, page A1

(kkk) "Infant Death Rates Still Higher Here", Highline News, 6 October 1996, page A3

(lll) FAA report "Impact of Boeing Field Interactions on the Benefits of the new proposed runway." Feb. 1993

(mmm) "Draft Sea-Tac Mitigation Study", Burien - Airport Assistance and Mitigation Studies, 21 October 1996, Final to be released March 1997

(nnn) Appeal of the Adequacy of the FEIS for the Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport, Filed by City of Sea-Tac

(ooo) Appeal of the Adequacy of the FEIS for the Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport, Filed by Akers

(ppp) Appeal of the Adequacy of the FEIS for the Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport, Filed by Cities of Des Moines, Burien, Federal Way, Normandy Park and Tukwila, Highline School District 401, Airport Communities Coalition

(qqq) Lawsuit filed by Cutler & Stanfield, Filed by Cities of Des Moines, Burien, Federal Way, Normandy Park and Tukwila, Highline School District 401, Airport Communities Coalition

(rrr) Earth Pressures and Retaining Walls, Whitney Huntington, John Wiley & Sons, NY, 1957

(sss) " Different Dirt, FAA Rejects fill plan to extend airport runway in Albuquerque"< Highline News, January 29,1997, page A1

(ttt) "Environmental Assessment for Proposed Improvements to Runway 3-21, Albuquerque International Airport", prepared by Coffman Associates, Inc. June 1994

(uuu) Sea-Tac Noise Exposure Update, June 1982

(vvv) Draft Supplemental Environmental Impact Statement for the Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport (DSEIS), 1997.

(www) World Wildlife Fund Newsletter, "Focus", March/April 1997, Volume 19, Number 2

(xxx) "A Comparison of FAA Integrated Noise Model Flight Profiles with Profiles Observed at Seattle-Tacoma Airport" by George W Flathers, December 1981, Office of Environment and Energy Project 1494A, Contract DTFA01-82-C10003, Mitre: Metrek Division

Additional References (note changes to numbers)

1) Electronic mail, A. Brown, Myrtle Jones, Hydrologist, US Geological Services,April 16, 1998

2) Electronic Mail Gary Turney, Supervisory Hydrologist, US Geological Services, April 16, 1998

3) Leisch, Brice A. , Price, Charles E. and Walters, Kenneth, L, Geology and Ground-Water Resources of Northwestern King County, Washington, Washington State Division of Water Resources Water Study Bulletin No. 20, 1963

4) Luzier J.E., Geology and Ground-Water Resources of Southwestern King County, Washington, State Dept. of Water Resources Water Supply Bulletin No. 28, 1969

5) Richardson, Donald, Bingham J.W. and Maddison R. J., Water Resources of King County, Washington, U.S. Geological Survey Water-Supply Paper, 1852

6) Woodard, D. G. Packard, F. A., Dion, N.P. and Sumioka, S.S., Occurance and Quality of Ground Water in Southwestern King County, Washington, U. S. Geological Survey, Water- Resources Investigation Report 92-4098, 1995

7) AGI Project 16,116.001, Draft Groundwater Quality Impact Evaluation Proposed North Employee Parking Lot Seattle Tacoma International Airport, SeaTac Washington, AGI Technologies, 11 April 1997

8) AGI Project 16,116.001, Groundwater Quality Impact Evaluation Proposed North Employee Parking Lot Seattle Tacoma International Airport, SeaTac Washington, AGI Technologies, 13 June 1997

9) Request for Public Hearing and Comments on Port of Seattle File Number 96-4-02325”, Notice of Application for Water Quality, From A. Brown, dated 8 January 1998

10) Wetlands/Water Hearing Comments submitted by A. Brown, April 9, 1998

(includes Sea-Tac 24 hour maximum rainfall data)

11) Wetlands/Water Hearing Cassette Tape, April/May 1997 Weekend Headliner: Safe Skies, Safe Water by Ross Simpson, NBC News Extra. Submitted by Debi Wagner at Hearing April 9, 1998 (Zinner of WA DOE interview regarding de-icer pads)

12) Hillis, Clark, Martin & Peterson," Re: Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Mark Mitchell, dated 24 February 1998

13) Hillis, Clark, Martin & Peterson," Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Fred White, dated 19 February 1998.

14) Cutler & Stanfield comments on Air Conformity Determination (contains the Univ of Florida fill calculations).

15) Cutler & Stanfield comments on Passenger Facility Charges

16) Sierra Club Cascade Sound April/May 1998 newsletter

18) Hotel correspondence B. Shurling and Port of Seattle

19) Caufman Report (1.5 dB)

20) Risk of a Fatal Large Jet Transport Bird Strike, web http:/airsafe.com/birds/birdrisk.htm

21) Twenty Worst Aviation Accidents, web http://www.primenet.com/~kebab/worst.htm

22) City reshaped: up and down, (Denny Regrade), web http://www.seattletimes.com:80/education/centennial/march/reshaped.html

20) Draft NPDES, for SeaTac Airport (incomplete title), 1997

23) NPDES for SeaTac Airport (incomplete title), 1998

24) Comments on Sea-Tac Airport Draft NPDES, A. Brown, 10 December 1997.

25) NPDES Proposed Waste Discharge Permit No. WA-002465-1, Port of Seattle, Seattle-Tacoma International Airport, Response to Comments, Public Meeting Held November 3, 1997 and November 10, 1997, prepared by Lisa Zinner, P.E. 20 February 1998.

26) Conveyer Presentation to Des Moines City Council

27) Comments on Sea-Tac Airport SEIS due 31 March 1997, From A. M. Brown, To FAA, Dennis Ossenkop, 28 March 1997

28) Request for Public Hearing on “Port of Seattle File Number 96-4-02325”, Notice of Application for Water Quality Certification and For Certification of Consistency with the Coastal Zone Management Program, From A. Brown, To Corps of Engineers & DOE, 30 December 1998

29) Public comments & written submittal, Public Hearing Port of Seattle File Number 96-4-02325”, Wetlands Permit, Notice of Application for Water Quality Certification and For Certification of Consistency with the Coastal Zone Management Program From A. Brown, To Corps of Engineers & DOE, 9 April 1998

30) Third Set of Comments on “Port of Seattle File Number 96-4-02325”, Wetlands Permit, Notice of Application for Water Quality Certification and For Certification of Consistency with the Coastal Zone Management Program, From A. Brown, To Corps of Engineers & DOE, 15 April 1998

31) Addendum to Third Set of Comments on “Port of Seattle File Number 96-4-02325”, Wetlands Permit, Notice of Application for Water Quality Certification and For Certification of Consistency with the Coastal Zone Management Program, From A. Brown, To Corps of Engineers & DOE, 19 April, 1998

32) CASE comments supplied in meeting held 15 May 1998, Col. Rigsby and J. Freedman

33) Des Moines Creek Basin Plan, Des Moines Creek Basin Committee, City of Sea-Tac, City of Des Moines, Port of Seattle, and King County, November 1997

34) “Toxics: Out of Site but on our minds”, Sound & Straits Newsletter, Volume 8, Number 1, People for Puget Sound, February 1998, pg 7 [“Puget Sound...some of the most severely contaminated sediments in the country”]

35) Public Hearing on DOE and Port of Seattle Agreement on Ground Water Study at Airport, Burien Library, May 21,1997

36) Comments on DOE and Port of Seattle Agreement on Ground Water Study at Airport, To DOE, Roger Nye, From A. Brown, dated 8 June 1997

37) ”Runway Project to Start Again”, Highline News, Pg. A6, by Marc Stiles, 11 December 1996 (Runway Safety Area 1996 20,000 trucks only able to haul 350,000 of the 450,000)

38) Memorandum of Agreement or memo?, From Anita Frankel of EPA Region 10, To Lowell Johnson, FAA NW Mountain Region, Regarding requiring delay in construction of North Terminal to comply with Air Conformity, 23 August 1996

39) Supplemental Environmental Impact Statement for the Proposed Master Plan Update Development Actions at Seattle-Tacoma International Airport, 1997.

40) US Department of Transportation FAA, Northwest mountain Region, Record of Decision for the Master Plan Update development Actions, Sea-Tac International Airport, 3 July 1997

41) “1997 Air Quality Annual report for Washington State”, WA DOE Publication Number 97-208.

42) “1997 Air Quality Data Summary”, WA DOE Publication Number 98-212.

43) “Sea-Tac International Airport Proposed Third Runway Project”, To Corps of Engineers Jonathan Freedman, From Joseph A. Pobiner, AICP, Associate Principal, Director – The PGAL Planning Group. 14, April 1998 (earthen berm seismic potential, slide, storm water-run-off issues)

44) Part 150 Passenger Facility Charge Application, Port of Seattle for Seattle-Tacoma International Airport, 1995

45) Part 150 Passenger Facility Charge Application, Port of Seattle for Seattle-Tacoma International Airport, 1998

46) Meeting, Corps of Engineers (Col. Rigsby, J. Freedman), RCAA (A. Furney), CASE (A. Brown, J. Bartlemay, L. Corvari), Seattle Headquarters, 15 May 1998. (Included seismic maps, bird hazard and runway incursion data)

47) Meeting, Corps of Engineers (J. Freedman, T. Mueller (part time), G. Terzi), RCAA (A. Furney), CASE (A. Brown, L. Corvari), C. Gower, Seattle Headquarters, 7 August 1998

48) Meeting, Corps of Engineers (J. Freedman, G. Terzi), RCAA (A. Furney), CASE (L. Corvari), C. Gower, Seattle Headquarters, xx 1998

49) Seattle Citizen TV Show, Topic (not the official title) Cedar Water shed - How to save salmon, Guests Charles Raines Cascade and Director Gale of Seattle Public Utilities, 9 August 1998.

50) Letter From Dan Caldwell, Regarding use of Highline Water by Seattle during early 1990’s El nine weather, Provided to Corps of Engineers by CASE in 1998.

51) Letter, From Jennifer Belcher, Director of Public Lands, Dept. of Natural Resources, To Arlene Brown, dated 18 June 1997 (Confirms Surface Mine Land Reclamation Permit needed for borrow pit sites 1, 2 and 3)

52) Supplemental SEPA Determination and SEPA Determination of Non-Significance (DNS) of Proposed Action, Seattle-Tacoma International Airport Master Plan Improvements – Wetland Mitigation, 6 August 1998.(Auburn Wetlands, comments due Aug 21, 1998)

53) Comments on Port's Wetlands Mitigation (in Auburn) due Aug. 21. From A. Brown, To Port of Seattle, 13 August 199

54) Letter, From Port of Seattle, Barbara Hinkle, To Arlene Brown, no title (Port’s Response to A. Brown’s comments on Auburn Wetlands mitigation), dated 9 September 1998 (BMPs inadequate”)

Note: some of the data from the following 7 health references may be available at the www.metrokc.gov/health web site (Public Health, asthma)

55) Letter, From Heimann, Nita and Sullivan, Marianne of Seattle-King County of Department of Public Health, To Lorna Dove, Georgetown Crime Prevention and Community Council, (health statistics for census tracts 109 and 112 prepared June 1997), 20 June 1997

56) Letter, From Smyser, Michael of Seattle-King County of Department of Public Health, To Scully, Robert of the Seattle Neighborhood Planning Office, “ Georgetown Health Indicators”), 20 August 1997

57) “Childhood Asthma Hospitalizations King County, 1987-1996”, Public Health Data Watch, Volume 2, Number 1,Seattle-King County Department of Public Health, February 1998

58) “The Health of King County--Highlights”, Public Health Data Watch, Volume 2, Number 1, Seattle-King County Department of Public Health, August 1998

59) “The Health of King County” (full report), Seattle-King County Department of Public Health, 1998

60) “Healthy Youth in King County--Highlights”, Public Health Data Watch, Volume 2, Number 1, Seattle-King County Department of Public Health, October 1999.

61) “Addressing Community Health Concerns around SeaTac Airport Progress Report on the Work Plan Proposed in August 1998”, prepared by WA State Dept. of Public Health, 25 February 1999.

62) “Toxicity of Aircraft De-icer and Anti-icer Solutions to aquatic Organisms”, Hartwell, s. Ian, Jordahl, David M., May, Eric B., Maryland Department of Natural Resources, Tidewater Administaration, Chesapeake Bay Research and Monitoring Division, Fisheries Division, Annapolis, Maryland, May 1993.

63) “Airplane emissions: A source of mutagenic nitrated polycyclic aromatic hydrocarbons”, CASE Western University, Cleveland, Ohio, 1986. (nitroarenes)

64) De-icing Blamed for Pollution, Researcher says liquids entering ground water near airport”, Sorenson, Eric, Seattle Times, 10 January 1999 (quotes WWU Devon Cancilla “very toxic stew”)

65) “Aircraft spread deadly viruses”, London Reuter, 26 June 1997,

66) “Kids Near airports don’t read as well because they tune out speech, Cornell study finds”, Lang, Susan, Science News, 28 April 1997.

67) “Aircraft Noise, A potential Health Hazard”, Bronzaft, Arline L., Dee Ahern PhD,RN, Kathleen, Mcginn, regina, MD,FACP, January 1998.

68) Occupational Factors Associated with Astrocytomas: A Case Control Study; American Journal of Industrial Medicine

69) Air Pollution and Your Health: The Report

70) Health Effects of Outdoor Pollution; American Family Physician

71) Breathless; Natural Resources Defense Council

72) Particulate Air Pollution as a Predictor of Mortality in a Prospective Study of US Adults; Respiratory Critical Care Medicine

73) Atmospheric Reactions of Polycyclic Aromatic Hydrocarbons; University of California, Riverside

74) An Association Between Air Pollution and Mortality in Six US Cities; New England Journal of Medicine

75) A critical Review of the Health Effects of Atmospheric Particulates; Toxicology and Industrial Health

76) Health Effects of Particulate Air Pollution: Time for Reassessment?; Environmental Health Perspectives

77) Environmental Risk Factors for Primary Malignant Brain Tumors; Review; Journal of Neuro-Oncology

78) “Breast Cancer & the Environment, The Estrogen Connection”, by Batt, Sharon and Gross, Liza, Sierra, September/October 1999. pages 40-41.(“synthetic organic estrogens, such as those in some plastics, fuels, and pesticides, appear to increase risk’)

79) “Cancer County”, Sierra (magazine), September/October 1999. Page 17.

80) “Air Pollution by Jet Aircraft at Seattle-Tacoma Airport”; Donaldson, Wallace r. Of National Weather Service Office Seattle-Tacoma, WA, ESSA Technical Memorandum WBTM WR 58, US Department of Commerce, Environmental Science Services Administration, Weather Bureau, salt Lake City, Utah October 1970.

81) President Clinton issued Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority and Low-Income Populations", President Clinton, 11 February 1994.

82) “No sugar coating this report on carcinogens”, US News & World Report, 27 September 1999(National Toxicology Program year 2000 Report on carcinogens to increase risk for 1-3, butadiene, ethylene oxide (antifreeze) , dioxin & 10 others)

83) EPA Web site for some chemicals and their hazards: www.epa.ttn/uatw/hlthef/.Need to access via www.epa.gov.

84) Acrolein data on EPA site www.epa.ttn/uatw/hlthef/acrolein.html

85) Arsenic data on EPA site www.epa.ttn/uatw/hlthef/arsenic.html

86) Benzene data on EPA site www.epa.ttn/uatw/hlthef/benzene.html

87) 1,3-Butadiene data on EPA site www.epa.ttn/uatw/hlthef/butadien.html

88) Formaldehyde data on EPA site www.epa.ttn/uatw/hlthef/formalde.html

89) EPA, Integrated Risk Assessment Information System www.epa.gov/npispgm3/iris/

90) Los Angeles Air Toxicity at www.house.gov/waxman (benzene, butadiene, formaldehyde)

91) Environmental Defense Fund web site www.edf.org, link to scorecard (pollution by zip code)

92) From Frost of DOE, To A. Brown per her request, 1998-1999 air pollution data from special SeaTac study. Report to be published soon. November 1999

93) “Rock, Andrea, “Toxicville”, Ladies Home Journal, September 1999. Pg 106-109, 114-116.

94) “Atmospheric Transformation of Air toxics: Benzene, 1,3-Butadiene and Formaldehyde” available at www.epa.gov:80/ordizux/regs/toxics/airtoxla.pdf

95) SeaTac Air Quality – Final Report, ESL-ET59, (POS 20383 stamped on it), by Adams, R, Hulet, B., Ramras, D., Seidman, H. et al, ESL Incorporated, 28 June 1973 (750% formaldehyde limit) Available Health section of CAW website www.nonoise.org/quietnet/us-caw/

96) Mobile Source Hazardous Air Pollutant Emissions in the Sea-Tac Urban Area. Radian Corp, 1994.

97) Crutcher, E. R., To Moore, Shawn of AMTEST, Microlab test report 036-95, AMTEST #95-03664-03667, 2 March 1995. (clotheline, gutter, rafter) (copy in one of the EIS’s)

98) Air Quality Survey Sea-Tac International Airport. McCulley, Frick & Gillman, Inc., 1995.

99) Comments on Frick SeaTac Air report by Debi DesMarias/(now Wagner) Available Health section of CAW website www.nonoise.org/quietnet/us-caw/

100) 1996-1997 Carbon Monoxide Saturation Study Sea-Tac International Airport Area. Washington State Department of Ecology (WSDOE) ,1997.

101) Illinois EPA Strategy for Continued Assessment of O’Hare Airport Air Toxics Emissions Impact on Surrounding Communities, Skinner, Thomas Director Illinois EPA, Proposal 28 June 1999.

102) “Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago”, by Summerhays, John, US EPA, Region 5 Chicago Illinois, September 1989.

103) "Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago." ViGYAN Inc. to US-EPA Region V. 1993. p. B-33.

104) Memorandum of Agreement, Air Quality Monitoring Program Activities Relating to the Seattle-Tacoma International Airport Vicinity, EPA, DOE, PSABCA, Port of Seattle, dated 10 October 1996

105) Letter, “Lack of Enforcement of Requirements to Use State Facilities”, from Senator Julia Patterson, To Sid Morrison, Secretary Washington State Department of Transportation, dated November 19,1998 (truck hauling)

106) “Air Traffic and Operational data on Selected US Airports with Parallel Runways, by Doyle, Thomas M., McGee, Frank G, NASA /CR-1998-207675, May1998

107) “Runway incursions Affect An Airline Pilot Every Other Day”, by Capt. Tom Duke, Air Line Pilot, February 1999 (ALPA web site under Publications)

108) “Financial Commitments needed to enhance the safety of the airport and air traffic control system”, John O’Brien Director Engineering & air Safety Department ALPA, testimony before Subcommittee on Aviation US House of Representatives, 4 February 1999 (ALPA web site)

109) “Parallel runway requirement analysis study” Volume 1, NASA-CCCR-191549-VOL-1, by Ebrahimi, Yaghoob S. 1 December 1993

110) “Parallel runway requirement analysis study, Simulation manual” Volume 2, NASA-CCCR-191549-VOL-2, by Ebrahimi, Yaghoob S. 1 December 1993

111) “Reliability Modeling and Methodology for Independent Approaches on parallel Runway Safety Analysis, by Babcock, P., Shor, A. and Rosch, G. NASA CR-198-207660, April 1998.

112) “Why a Little More Traffic Makes a Lot More Runway Incursions”, by Lounsbury, Lincoln, Air Line Pilot, May 1999 (ALPA web site) (grow exponentially)

113) “Results of Monitoring King County Wetland Mitigations”, by Anna Mockler et al, King County Dept. Of Development and Environmental Services, 4 August 1998.

114) “Evaluation of Retaining Wall/Slope Alternatives to Reduce Impacts to Miller Creek, Embankment Station 174+00 to 186+00”, prepared by HNTB and/or Hart Crowser, Inc.(no reponsible person or organization listed on report), 1999.

115) Letter, To Tom Luster of DOE, From Jerald LaVassar, DOE, “Evaluation of Retaining Wall/Slope Alternatives to Reduce Impacts to Miller Creek, Embankment Station 174+00 to 186+00” dated 9 August 1999

116) Letter. To Robert T. Maruska of HNTB, From Thomas M. Gurtowski of Shannon & Wilson, dated 27 March 1999.

117) Koshusho, Takegi (Prof Chui Univ), “Water Film in Liquified Sand and Its Effect on Lateral Spread”, Journal of Geotechnical and Geoenvironmental Engineering, ISSN 1090-0241, Volume 125, Number 10, October 1999, pgs 817-831. (ongoing deformation, embankment loading)

118) Lee, K. M., Shen, C. K., Leung, D.H.K. and Mitchell, J. K., “Efffects of Placement Method on Geotechnical Behavior of Hydraulic Fill Sands”, Journal of Geotechnical and Geoenvironmental Engineering, ISSN 1090-0241, Volume 125, Number 10, October 1999. Pg 832-845 (compositional factors)

119) Fox, Patrick, “Solution Charts for Finite Strain Consolidation of Normally Consolidated clays”, Journal of Geotechnical and Geoenvironmental Engineering, ISSN 1090-0241, Volume 125, Number 10, October 1999. Pgs 847-867. (FEM, pore pressure predictions for soft soils)

120) Leshchinsky, Dov (Discussion )“Limit Analysis versus Slope Stability”, Journal of Geotechnical and Geoenvironmental Engineering, ISSN 1090-0241, Volume 125, Number 10, October 1999.pgs 914-915.

121) Yu, H. S., Salgalso, R., Sloan, S. W., and Kim, J.M. (closure )“Limit Analysis versus Slope Stability”, Journal of Geotechnical and Geoenvironmental Engineering, ISSN 1090-0241, Volume 125, Number 10, October 1999.pgs 915-918. (slope stability graphs of different angled slopes)

122) Engineering Manual EM 1110-1-1804 Geotechincal Investigations, Department of the Army, 29 February 1984 (excludes roads and airfields)

123) Whitely, Peyton, “State’s tallest noise walls going up along Highway 520”, Seattle Times Eastside bureau, 4 August 1998 (38 feet high sunk 20 feet in ground)

124) “Recent developments in Landslide Litigation Techniques (Part 2)”, www.geolith.com/publications/recent_dev/recent_devel2.htm

125) Regional Commission on Airport Affairs, Presentation to Des Moines City Council Feb.11, 1999 (costs and airlines’ concerns)

126) “Candidates for Port focus on growth, jobs”, Seattle-Post Intelligencer, 11 October 1999 (Commissioner Claire Nordquist “doubling the airport’s capacity”)

127) Clean Water Act/Wetlands Public Hearing, File 1996-4-02325, Public Notice Date 30 September 1999, Foster performing Art Center, 3 November 1999 (exceeded capacity)

128) FAA Advisory Circular 150/5200-33, “hazardous Wildlife Attractants on or Near Airports”, dated 1 May 1997.

129) Letter, Port of Seattle, To Dear Caller (multiple callers so sent form letter), regarding lost Antonov 124 Freighter, Incident 10 November 1998, wrong airport, “averaged 2000 feet”, dated 16 November 1998.

130) Addendum to IWS Engineering Report, Seattle-Tacoma International Airport, Volume 1, Kennedy/Jenks Consultants. April 1998. (AKART, de-icer pad insufficient room, too expensive)

131) Port of Seattle Memorandum Item 8a, Meeting date 10 March 1998, “Request Port of Seattle Commission Authorization for the General manager, Airfield Line of Business and the Director of Engineering Services to reject all bids, readvertise for bids and award a major construction contract for the Third runway: Embankment Construction- Phase I” 26 February 1998 (bids non-responsive or 23 to 48% over estimate)

132) Regional Airport System Plam1988-2020, Air Transportation element of the regional Transportation Plan, Puget Sound Council of Governments, September 1988. (“expansion within existing property” pg vi)

133) “Final report, Master Plan Update for Sea-Tac International Airport, PEAT MARWICK/TRA, for Port of Seattle, September 1985. (no 3^rd runway - environmental impact pg 1, underestimated operations pg 4-2)

134) Airtrac Washington, State Transportation Commission, Final report and Policy Recommendations, November 1993 (“design capacity 2005-2010”)

135) The Polluted Waters Report, Puget Soundkeeper Alliance, 1997.

136) Coho Salmon, Puget Sound/Strait of Georgia ESU, Candidate Listing, National marine Fisheries Service, Northwest Region, Protected Resources Division, July 1995

137) Stelle, William Jr., “The Pacific Salmon Challenge: Merging Concepts of Water Quality and Aquatic Health”, National Marine Fisheries Service, December 1998.

138) Hillman, T. W., Stevenson, J. R., Snyder, D. J., “Assessment of Spawning Habitat in three Puget Sound Streams, Washington”, report to Airport Communities Coalition, April 1999.

139) Miller Creek Watershed, Dept. Of Landscape Architecture, University of Washington, Class of Winter 1972 quarter under direction of Professor David Streatfield

140) Ames, James, “Miller Creek: Present Staus and Potential for Salmon Production”, Wasington department of Fisheries, 1970.

141) Haughland and Sherrow, Plaintiffs First Interrogatories to Defendant King County, Willis W. Kludt vs King County; Port of Seattle, and Washington State Highway Commission, 1972.

142) Environmental Materials Transport Community Newsletter June 1998

143) Environmental Materials Transport video 1998

144) OPA Press Release: Labor secretary calls for an end to Silicosis [10/31/96] (Munzer silicosis)

145) http://www.osha-slc.gov/OshDoc/Other_Agency_data/MEM19960502.html

146) Canning, Kathie, Harrigan, Kate, “Research Critical to Understanding Endocrine Disrupters”, Pollution Engineering, September 1999, page 3

147) Web site http://nationalacademies.org/cls/best/reports.html

148) “Arsenic in Drinking Water”, Subcommittee on Arsenic in Drinking Water, National Research Council, 1999.

149) “Hormonally Active Agents in the Environment” , Committee on Hormonally Active Agents in the Environment, National Research Council, 1999

150) Flight Plan Project, Final Programmatic EIS (pg 4-99 Moses Lake)

151) Port of Seattle letter, from Gina Marie Lindsey, Director Aviation Division, To Barbara Stuhring, dated 31 October 1997 (two express purposes)

152) Seattle-Tacoma International Airport, Capacity Enhancement Plan Update, July 1995 (also available on web)

153) SEA-Seattle-Tacoma Intl Airport, Seattle WA, Airport Information Published on 9 September 1999. AirNav Web site http;//www.airnav.com/airport/SEA (airport data including elevation, obstacles)

154) Memorandum CENPS-OP-RG, Seatac EIS, From Jack Kennedy, Corps of Engineers Regulatory Branch, 14 August 1995 (so it is referring to DEIS, wetlands mitigation, purposer)

155) “Third Runway”, Thomas, Will, The News, 2 October 1996 (church wetlands prevent house building. Subterranean fed wetlands)

156) Corbett, James J and Fischbeck, “Emissions from ships. (pollution and policy implications), Science, Electronic collection A19998018231, 31 October 1997. (highest amounts of pollution of all combustion sources per ton of fuel consumed 1-3 days residence times”)

157) Schwarz, S. E., Science 243, 753, 1989. (Nitrous oxide residence times)

158) Scott, William B, “Report Claims Aircraft Can Influence Climate”, Aviation Week, 30 August 1999, page 57.

159) Wood, Warren, Kraemer, Thomas F., and Hearn Jr., Paul P., “Intragranular diffusion:an important mechanism influencing solute transport in clastic aquifers?”, Science, v247, n4950 p1569, 30 March 1990.

160) Anderson, Eric E., Talley, Wayne K., “The oil spill size of tanker and barge accidents:determinants and policy implications”, Land Economics, v71, n2, May 1995, p216

161) McKenna, James T., “FAA Aims to revive Runway Safety Fight”, Aviation Week, 1 November 1999, page 40-41

162) “Impacts Of Deicing Fluids On Elijahs And Gunpowder Creeks”, Boone County, Kentucky, Kentucky Department for Environmental Protection, Division of Water, Frankfort, Kentucky. Available online http://water.nr.state.ky.us/dow/elijah.pdf

163) Johnson, Glen, “More Close Calls at Airports Incidents Up Despite Efforts to Reduce Near-misses on airport runways are getting more frequent”, The Associated Press, 8 August 1999. (see Appendix K)

164) "Sensitivity of Fish Embryos to Weathered Crude Oil: Part I. Low-Level Exposure During Incubation Causes Malformation, Genetic Damage, and Mortality in Larval Pacific Herring (Clupea Pallasi)" by Mark. G. Carls, Stanley D. Rice, and Jo Ellen Hose, Environmental Toxicology and Chemistry, Vol. 18., No. 3., pp.481-493, 1999

165) “Making Endangered Species Act Determinations of Effect for Individual or Grouped Action at the Watershed Scale" prepared by the National Marine Fisheries Service Environmental and Technical Services Division Habitat Conservation Branch, August 1996

166) "Sea-Tac International Airport Impact Mitigation Study, Initial Assessment and Recommendations", prepared under a grant from the State of Washington by Helmuth, Obata & Kassabaum Inc., et al., February 1997

167) Perdue, Nancy Jo, “Salmon Spotted in Creek”, The Highline Times, 17 November 1999. (Dusenbury – 200 coho salmon in Des Moines Creek)

168) Addressing Community Health Concerns Around SeaTac Airport: Second Report on the Work Plan Proposed in August 1998, WA Public Health Department, December 1999

169) “Dropout rates brutally honest”, Seattle Times, 21 November 1999. Pages B1, B2 (source Office of Superintendent of Instruction, 34% Highline, State 16.4, Seattle 10.9)

170) Harrington, Patrick, “Auditor finds Port’s books in poor shape”, Seattle Times, 6 November 1999,

171) Tacoma-Seattle area susceptible to deep, killer quake, magazine says”, The News Tribune, 29 October 199, page B2. (6.5 magnitude intraslab quake below Sea-Tac Airport in 1965 killed seven.)

172) Gower, Chris, Comments to Corps of Engineers and WA DOE, “Public Notice of Application for Permit dated September 30, 1999, Proposed Third runway at Seattle-Tacoma International Airport, dated 8 November 1999.

173) “Appeals court rules for third runway at Seattle-Tacoma International Airport”, Seattle Times, 16 November 1999.

174) “Cancer Care Report Annual Report 1991”, Highline Community Hospital.

175) “Cancer Care Report 1992”, Highline Community Hospital.

176) “Cancer Care Report, 1994 Annual Report, 1993 Statistical Review”, Highline Community Hospital, 1994.

177) “Cancer Care Report Annual Report 1995, 1994 Statistical Review”, Highline Community Hospital

178) “Cancer Care Report 1996 Annual Report, 1995 Statistical Review”, Highline Community Hospital

179) Cancer Care Report 1997 Annual Report, 1996 Statistical Review”, Highline Community Hospital

180) Cancer Care Report 1998 Annual Report, 1997 Statistical Review”, Highline Community Hospital

181) Cancer Care Report 1999 Annual Report, 1998 Statistical Review”, Highline Community Hospital, Burien Washington.

182) “Cancer Facts and Figures”. American Cancer Society. Data for years 1991-1997.

183) NIH Guide: Health Disparities: Linking Biological and Behavioral Mechanisms with Social and Physical Environments, RFA: ES-00-004, National Institute of Health (NIH), Released 4 November 1999.

184) “Special Report: Hushkits: What they are, what they do, and What’s certified for Aircraft Types”, Airport Noise Report, Volume 11, Number 6, 16 April 1999. (noise model doesn’t have hushkits)

185) Lamberton, Jack, What Causes Brain Tumors? From Well-Connected, Lycos Health Topics A-Z, September 1998. http:\\Webmd.lycos.com/topic_summary_artcle/DMK_ARTICLE_5461950

186) Technical Information and Publications, Soft Soil Stabilization, Polyfelt Geosynthetics, web site www.polyfelt.com/technica.htm. October 1999. (extensive references)

187) 02803 – Retaining Walls. Web site 4specs.com/s/02/02830.html. October 1999.

188) Project Report, Grand County sets a World Record”, Yenter Company, www.yenter.com/Projects/grandcounty.html (reinforced soil walls in 1997...world record 55 feet high)

189) Quinn, Barbara, “Finding a Better way to Manage Runoff”, Pollution Engineering (Cahners), August 1999, page 25.

190) “DOJ to Appeal Decision on Air Quality Standards”, Pollution Engineering (Cahners), August 1999, page 3.(“Browner stresses the panel did not challenge the science”)

191) Opdyke, Jeff D., Airline Seeks OK on Tool to Beat Fog, Alaska Airlines Seeks Wider Use of Navigational Aid”, Wall Street Journal Northwest, 1 September 1999.pg ?, NW4.

192) “United Plans Denver Push”, Aviation Week, 4 October 199, pg 47.

193) “Squabbles Persist over ATC delays”, Aviation Week, 4 October 1999. Pg 47.

194) Leschi News, Issue 161, May 1999.

195) Washington Air Quality Reports available at http://www.wa.gov/ecology/air/airhome.html

196) Foster, Heath, “Puget Sound area in risk of violating EPA Pollution Laws, Growing Smog means we could lose some US highway money”, Seattle Post-Intelligencer, 22 April 1999

197) Airline News 6/16/99 , Flight attendants with Alaska Airlines have reported air quality problems

198) “DC Has Higher Per-Capita Cancer Risk In Its Air Than Any of the 50 States, EPA Estimates Offer First-Ever Localized View Of Clean Air Act Health Protections” Environmental Defense Fund, 20 April 1999

199) Port of Seattle letter, from Barbara Hinkle, Health Safety &Environmental Management,, To Barbara Stuhring, dated 21 May 1996 (admits glycol not treated, ROD to include this letter)

200) A. Brown, To Expert Arbitration Board c/o Jerry Dinndorf, PSRC, 18 February 1996. (cold climate homes, R 7-35 admits models wrong)

201) Leonard, Edward C., Vinyl and Diene Monomers, Wiley-Interscience, A Division of John Wiley & Sons, New York 1971.

202) Gosselin, Robert, MD, Phd., Smith, Roger P, Phd, Hodge, Harold, PhD, D.Sc, Clinical Toxicology of Commercial Products, Williams & Wilkins, Baltimore, 1981.

203) “FAA Tests Infrared Deicers”, Aviation Week, 1 May 1995, pg 38.

204) Miller, Kay, “NASA, Honeywell test sysem to air airports with close parallel runways”, Star Tribune, 7 November 1999 (see Appendix K)

205) Kiernan, Bette, MFCC, Letter to J. Saporito regarding airline seage, Flying off Course etc., 21 July 1998

206) “Sleeping Brain is Wary”, Newsday, pp A07. (John Hopkins University, Serena Gondel, Dr. Gregory Krauss, frontal lobe very active)

207) Munoz, Lorenza, “El Toro Foes Fin Allies Fighting Worldwide” Los Angeles Times, 4 July 1998. Pg 1 (mentions SeaTac)

Note: This is only a partial list of references and does not even reflect everything I’ve referenced in the report or have copies of at home. Typically, the same information appears in multiple locations. All correspondence to the FAA, Port of Seattle, PSRC, Corps of Engineers, Dept. of Ecology, Environmental Protection Agency, Expert Panel, PSAPCA, and Dept. of Transportation on current airport operations as well as the Third runway are applicable.

Appendix A: Public Health Data Identifies Significant Issues

Do Socioeconomic Differences Really Account for all Health Differences?

Excerpts from Reference 183. Bolding added by A. Brown for emphasis

NIH Guide: HEALTH DISPARITIES: LINKING BIOLOGICAL AND BEHAVIORAL MECHANISMS

WITH SOCIAL AND PHYSICAL ENVIRONMENTS

Release Date: November 4, 1999 RFA: ES-00-004

snipped

This RFA will support research to strengthen the science base for achieving

the goals of the President's Initiative to Eliminate Racial and Ethnic

Disparities in Health (see http://raceandhealth.hhs.gov/.) The National

Institutes of Health (NIH) has identified as a special emphasis area

Research related to health disparities.

Snipped

HEALTHY PEOPLE 2000

The Public Health Service (PHS) is committed to achieving the health

promotion and disease prevention objectives of "Healthy People 2000," a PHS-led national activity for setting priority areas. This RFA, "Health

Disparities: Linking Biological and Behavioral Mechanisms with Social and

Physical Environments," is related to one or more of the priority areas.

Potential applicants may obtain a copy of "Healthy People 2000" at

http://odphp.osophs.dhhs.gov/pubs/hp2000

snipped

RESEARCH OBJECTIVES

Background

The disparity in health between socioeconomically disadvantaged individuals

and those more advantaged has existed for centuries and continues to this

day. These health disparities (HD) may be defined as differences in disease

incidence, mental illness, morbidity and mortality that exist between

specific populations. Disparities are most apparent and closely associated

among populations with varying levels of socioeconomic status (SES.)

Significant evidence has demonstrated that a gradient exists between SES and health status, with individuals of high SES having better overall health that those of low SES. The most striking health discrepancies result in shorter

life expectancy, as well as higher rates of most cancers, some birth defects,

infant mortality, asthma, diabetes, behavioral and affective disorders, and

cardiovascular disease.

Exposure to toxic environmental and occupational agents can have different

effects in different persons of differing age, SES, ethnic background, gender

and genetic composition. Some subsets of the population are inherently more

susceptible to cellular and genetic damage for a number of reasons, including

genetic susceptibility, nutritional status, other social or cultural

influences, or in the case of children, the vulnerability of developing

systems to environmental insult.

In addition, occupational exposures are known to be distributed

differentially, and workers with specific biologic and/or SES characteristics

are more likely to have increased risk of work related diseases and injuries.

Although the nature and magnitude of risks experienced by people of color

have not been thoroughly studied, data on occupational injury deaths indicate

that blacks have the highest rates per 100,000 workers compared with those of

whites and workers of other races. High-risk populations have been

underserved by the occupational safety and health research community, with

the result that important unanswered questions remain about the profile of

hazards they face, the incidence of work-related injuries and illnesses, the

mechanisms of these injuries and illnesses, and the optimal approaches to

prevention. Any or all of these factors may contribute to the health

disparities observed in socioeconomically disadvantaged and underserved

populations.

The relationships among social and physical environments, health, morbidity,

and mortality have been long and extensively documented. While the overall

relationship of SES to mortality may attenuate in older ages, socioeconomic

position continues to be linked to the prevalence of disability and chronic

and degenerative diseases, including cardiovascular disease, many cancers,

and neurodegenerative diseases. Low SES may result in poor physical and/or

mental health by operating through various psychosocial mechanisms such as

discrimination, social exclusion, prolonged and/or heightened stress, loss of

sense of control, and low self-esteem. In turn, these psychosocial

mechanisms may lead to physiological changes such as raised cortisol,

altered

blood-pressure response, and decreased immunity that place individuals at

risk for adverse health and functioning outcomes. Not only may SES affect

health, but physical and mental health may have an impact upon the various

measures of SES (e.g., education, income/wealth, and occupation) over the

life course.

While access to health care may be an important variable that interacts with

SES to influence health disparities, this will not be a primary focus of this

RFA. Studies indicate that in industrialized nations having equal access to

quality health care, an SES gradient still exists in all cause morbidity and

mortality. Countries that have universal health care systems, e.g., the

United Kingdom and Scandinavia, still demonstrate SES related health

disparities. In fact, a landmark study conducted with British civil servants

as subjects ostensibly demonstrated a health outcome gradient in four income

groups. Although all workers had access to the same high quality health care,

each group had progressively more positive health outcomes with increasing

income level and job status. What is noteworthy about this gradient is that

it exists across middle and upper income brackets of the British civil

servant occupation force. These groups, although more affluent than lower

SES groups, did not have health outcomes as good as the group in the highest

SES category.

Equally important is the notion that individual behavior and lifestyle

choices contribute to disparate health outcomes in lower SES strata. There

have been recent data that indicate when individual behavior and lifestyle

choices, such as smoking, alcohol consumption, diet and exercise, are

corrected for, disparate health outcomes are still observed in lower SES

groups. Such findings suggest that access to health care and individual

behavior and lifestyle choices are not the major determinants of SES-related

disparate health outcomes. Indeed, these results shift research emphasis

toward examination of mechanisms by which social and physical environments

may interact with SES to produce health disparities. For these reasons,

applications which limit the social environment being examined to individual

lifestyle choices or to access to and quality of health care will be

considered nonresponsive to this RFA and returned to the applicant without

review. Such variables are appropriate to this RFA only when coupled to a

broader context or array of social environmental factors. Investigators

interested in more extensive explorations of the role of individual lifestyle

choices or health care as related to health disparities are referred to more

relevant initiatives, e.g., Socioeconomic Status and Health Across the Life

course (http://grants.nih.gov/grants/guide/pa-files/PA-98-098.html)and

Understanding and Eliminating Minority Health Disparities

(http://grants.nih.gov/grants/guide/rfa-files/RFA-HS-00-003.html).

snipped

INQUIRIES

Inquiries concerning this RFA are encouraged. The opportunity to clarify

Any issues or questions from potential applicants is welcome.

Direct inquiries regarding programmatic issues to:

Frederick L. Tyson, Ph.D.

Scientific Program Administrator

Chemical Exposures and Molecular Biology Branch

Office of Program Development

Division of Extramural Research and Training

National Institute of Environmental Health Sciences

P.O. Box 12233, 111 T.W. Alexander Drive, MD EC-21

Research Triangle Park, NC 27709

Telephone: (919) 541-0176

Fax: (919) 316-4606

Email: tyson2@niehs.nih.gov

Rose Maria Li, MBA, Ph.D.

Chief, Demography and Population Epidemiology

Behavioral and Social Research Program

National Institute on Aging

7201 Wisconsin Avenue, Suite 533

Bethesda, MD 20892

Telephone: (301) 496-3138

Fax: 301-402-0051

Email: rl26b@nih.gov

Susana A. Serrate-Sztein, Ph.D.

Director, Rheumatic Diseases Branch

National Institute of Arthritis and Musculoskeletal and Skin Diseases

45 Center Drive

MSC6500

Bethesda, MD 20892

Telephone: (301) 594-5032

Fax: (301) 480-4543

Email: ss86e@nih.gov

V. Jeffery Evans Ph.D., J.D.

Demographic and Behavioral Sciences Branch

National Institute of Child Health and Human Development

6100 Executive Boulevard, Room 8B07, MSC 7510

Bethesda, MD 20892-7510

Telephone: (301) 496-1176

FAX: (301) 496-0962

E-mail: Jeff_Evans@nih.gov

Cheryl A. Boyce, Ph.D.

Developmental Psychopathology and Prevention Research Branch

Division of Mental Disorders, Behavioral Research and AIDS

National Institute of Mental Health

6001 Executive Boulevard, Room 6200

MSC 9617

Bethesda, MD 20892-9617

Telephone: (301) 443-0848

Fax: (301) 480-4415

Email: cboyce@nih.gov

Roy M. Fleming, Sc.D.

Director, Research Grants Program

National Institute for Occupational Safety and Health

1600 Clifton Road, N.E.

Building 1, Room 3053, MS D-30

Atlanta, GA 30333

Telephone: (404) 639-3343 Fax: (404) 639-4616 Email: rmf2@cdc.gov

snipped

Cancer Risk by Zip Code or County

The data available off the web (see table below) illustrates why using King County as the baseline for a heath comparison could lead to a false sense of well being.

The data is particularly interesting since Washington DC does not have major manufacturing like King County, home of Sea-Tac/Boeing Field and Cook Illinois, home of O’Hare airport. Washington DC has ground and air traffic. See the comments regarding Midway Airport, near O’Hare and the Environmental Defense Fund article on Washington DC which follow.

Table 4 Cancer Risk by County

Average Individual's Added Cancer Risk (per 1,000,000) and Rating by US Counties /1/
	King County WA	Clallam WA	Cook Illinois	District of Colombia
All Sources
Cancer Risk /2/	520	650	590	770
WA counties	2nd	1st
US top 100	51	29	35	13
Mobile
Cancer Risk /2/	290	53	350	470
WA counties	1st	15th
US top 100	31	no	10	18
Point
Cancer Risk /2/	67	1.2	86	120
WA counties	1st	24th
US top 100	No	No	73	44
Area
Cancer Risk /2/	100	470	86	110
WA counties	15th	1st
US top 100	no	4	no	no

/1/ Information extracted from www.edf.org then ”Find pollution by zip code” (www.scorecard.org/) database 1 May 1999. Environmental Defense Fund.

/2/” Average Individual's Added Cancer Risk (per 1,000,000)

The estimated individual risk of getting cancer due to a lifetime exposure to outdoor hazardous air pollutants. Because the Clean Air Act's goal is to reduce lifetime cancer risks from hazardous air pollutants to one in one million, Scorecard expresses added cancer risk in these units: an added risk of 550 per 1,000,000, for example, is 550 times higher than the Clean Air Act goal. “

Note that cancer risk estimates are calculations based on models - they are useful for

ranking purposes but are not necessarily predictive of any actual individual's risk of

getting cancer.”

Table 5 Counties in US Ranked by Average Individual's Added Cancer Risk

(per 1,000,000) Top 40 for Mobile Sources listed here – see web site for complete list

1.NEW YORK, NY: 800

2.SAN FRANCISCO, CA: 710

3.HUDSON, NJ: 600

4.PHILADELPHIA, PA: 550

5.KINGS, NY: 550

6.BALTIMORE CITY, MD: 520

7.BRONX, NY: 510

8.ESSEX, NJ: 500

9.QUEENS, NY: 490

10.DISTRICT OF COLUMBIA, DC: 470

11.LOS ANGELES, CA: 450

12.ST. LOUIS CITY, MO: 440

13.ORLEANS, LA: 430

14.ARLINGTON, VA: 400

15.ORANGE, CA: 400

16.DENVER, CO: 370

17.WAYNE, MI: 360

18.COOK, IL: 350

19.ALAMEDA, CA: 350

20.PASSAIC, NJ: 350

21.ALEXANDRIA, VA: 340

22.UNION, NJ: 320

23.BERGEN, NJ: 320

24.SUFFOLK, MA: 310

25.SANTA CLARA, CA: 310

26.RICHMOND CITY, VA: 300

27.NORFOLK, VA: 300

28.RICHMOND, NY: 300

29.FULTON, GA: 300

30.MULTNOMAH, OR: 290

31.KING, WA: 290

32.SAN DIEGO, CA: 290

33.BEXAR, TX: 280

34.SAN MATEO, CA: 280

35.JEFFERSON, LA: 280

36.DALLAS, TX: 270

37.CAMDEN, NJ: 270

38.HENNEPIN, MN: 270

39.CHITTENDEN, VT: 270

40.FRANKLIN, OH: 270

Table 6 Mobile Sources in WA Ranked by Average Individual's Added Cancer Risk

(per 1,000,000)

1.KING: 290

2.PIERCE: 210

3.KITSAP: 180

4.CLARK: 170

5.SNOHOMISH: 160

6.BENTON: 150

7.THURSTON: 140

8.YAKIMA: 140

9.COWLITZ: 130

10.SPOKANE: 120

11.WHITMAN: 120

12.ISLAND: 100

13.FRANKLIN: 99

14.DOUGLAS: 95

15.CLALLAM: 93

16.WHATCOM: 91

17.GRAYS HARBOR: 91

18.ASOTIN: 87

19.CHELAN: 78

20.SKAGIT: 77

21.WALLA WALLA: 75

22.KITTITAS: 68

23.LEWIS: 61

24.MASON: 57

25.STEVENS: 44

26.ADAMS: 28

27.GRANT: 28

28.JEFFERSON: 23

29.SKAMANIA: 16

30.WAHKIAKUM: 14

31.SAN JUAN: 14

32.PACIFIC: 11

33.LINCOLN: 9.5

34.PEND OREILLE: 9.2

35.OKANOGAN: 7.8

36.KLICKITAT: 6.0

37.GARFIELD: 3.7

38.COLUMBIA: 2.6

39.FERRY: 1.5

Midway Airport Major Contributor to Cancer Risk

jsaporito@aol.com> Note: Ground mobile sources, cars, trucks, etc., while a significant source of certain carcinogens are "insignificant compared to aircraft emissions." 99% of the total cancer cases were attributed to the aircraft operated at Midway Airport, 1990. (source: EPA. "Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago." ViGYAN Inc. to US-EPA RegionV. 1993. p. B-33.)

Also note: Airports are also a significant source for ground vehicle emissions. Approx. 175,000 cars, trucks, taxis, buses, etc. go into O'Hare Airport daily.

It is also important to note that researchers believe that airport and aircraft emissions modeling, grossly underestimates the amounts of toxic pollution emitted.

============================================================

DC Has Higher Per-Capita Cancer Risk In Its Air Than Any of the 50 States

Environmental Defense Fund, 20 April 1999

DC Has Higher Per-Capita Cancer Risk In Its Air Than Any of the 50 States

EPA Estimates Offer First-Ever Localized View Of Clean Air Act Health Protections

Government estimates of toxic chemical concentrations in local air indicate that residents of the District of Columbia face an additional cancer risk from toxic chemicals in outdoor air that is more than 700 times higher than the goal set by Congress a decade ago, the Environmental Defense Fund (EDF) announced today. DC has a higher per-capita cancer risk in its air than any of the 50 states. Maryland ranked fourth, with an air cancer risk more than 500 times Congress' goal.

The newly released government figures are based on 1990 data and represent the first-ever estimate of which toxic chemicals, in what amounts, are in local communities' air. EDF took the government figures and calculated the associated health risks for each community. The 1990-based government estimates come with official cautions about their use, and several accuracy checks showing close comparability with measurements as recent as 1997.

The District of Columbia shows a higher per-capita cancer risk in its air than any of the 50 states, despite having virtually no major industrial facilities. Car and truck traffic and the Ronald Reagan National Airport were its main sources of air toxics.

"The numbers show that cars, trucks, and small businesses tend to be responsible for much more of the air's toxicity than is generally recognized," said EDF attorney David Roe. Of the air cancer risk calculated by EDF for the District of Columbia, 67% is from mobile sources and 16% from small-business 'area' sources, with the remaining 17% from industrial 'point' sources. "Up to now, lack of information has meant lack of attention to some of the biggest causes of toxic air," Roe said.

EDF is using its widely acclaimed Scorecard web site (www.scorecard.org) to make this information on air toxics publicly available on the Internet. "For the first time since the Clean Air Act passed 30 years ago, people can now learn about toxic chemicals in their own local air, and can see how well the law has or has not been protecting them," said EDF scientist Dr. Bill Pease, Scorecard's creator and chief designer. Visitors to the web site simply type in a zip code to get the local facts.

Simultaneously, EDF has also added local information on the six so-called 'criteria' air pollutants (ozone, sulfur dioxide, particulates, etc.) to its Scorecard web site. The health implications of those pollutants are shown as well, based on 1998 measurements. Criteria pollutants are widely monitored; air toxics are not.

The unprecedented information about air toxics at the local level comes from the US Environmental Protection Agency's Cumulative Exposure Project (CEP), which made estimates of the concentrations of 148 separate chemicals in the air of every census tract in the continental US. (A census tract is a small area with 4000 to 5000 residents. The US includes over 60,000 census tracts.) EPA released the CEP results to a limited public in December 1998, after EDF and others requested it under the Freedom of Information Act. EDF then added health risk calculations and incorporated all the data into Scorecard.

EPA has cautioned that CEP results are based on modeling, rather than direct measurements, and that the modeling uses 1990 data. Comparisons with the handful of more recent, measured results for air toxics that are available from eight states, some as recent as 1997, show that CEP estimates are generally comparable, with underestimation a bigger problem than overestimation. Scorecard shows all comparisons. "The CEP estimates from EPA cast a lot of light onto what's been a very dark subject, but they aren't the ultimate word," said Dr. Pease.

The Environmental Defense Fund, a leading, national, NY-based nonprofit organization, represents 300,000 members. EDF links science, economics, and law to create innovative, equitable and economically viable solutions to today's environmental problems.

EDF Home | Free Newsletter | Donate | Search | Publications | < | ^ | > |

EDF Membership 1-800-684-3322

Contact- EDF@edf.org

© 1999 Environmental Defense Fund (www.edf.org)

257 Park Avenue South, New York, NY 10010

** NOTICE: In accordance with Title 17 U.S.C. Section 107, this material is

distributed without profit to those who have expressed a prior interest in

receiving the included information for research and educational purposes. **

Highline Hospital data Indicates More Unexplored Health issues

Analyzing the data in the annual Highline Hospital reports (References 174 through 181) raises more questions about certain types of cancer. For example, esophagus cancer rates for males and females are higher than National levels. The 1995 Highline report with the 1994 statistics (Ref. 177) specifically discusses differences in women’s rates by comparing them to the 1987 to 1989 time frame. Formaldehyde, a pollutant that when measured has exceeded safe limits around the airport, sometimes targets the esophagus.

Table 7 Highline Hospital Male Esophagus Cancer Rates Higher than National Levels

Highline Hospital Cancer Care Annual Reports Esophogus cancer diagnoses
Male	1993	1994	1995	1996	1997	1998	Averaged Years 1994 -1998	Standard Deviation
National		1.9	1.3	1.2	1.2	1.5	1.4	0.3
Highline	2.3	1.5	0.6	4.5	2.3	2.3	2.2	1.4
							0.8	Highline Higher
			58% more male cases than National

Table 8 Highline Hospital Female Esophagus Cancer Rates Higher than National Levels

Highline Hospital Cancer Care Annual Reports Esophagus cancer diagnoses
Female	1993	1994	1995	1996 /1/	1997	1998 /1/	Averaged Years 1994, 95, 97	Standard Deviation
National		0.5	0.6		0.5		0.5	0.1
Highline	0.8	1.7	1.1		0.8		1.2	0.5
							0.7	Highline Higher
			125% more female cases than National

/1/ Author does not have data but assumes it can be obtained from Highline Hospital

Sea-Tac Health Data Tables with Standard Deviations Shown

Appendix B: Additional Information on Risks associated Airport Pollutants

I have inserted portions of data sheets from some of the EPA web site (Ref. 83) listed in the references. The bolding was added by the author of these comments.

----------------------------------------------------------------------------

ACROLEIN

107-02-8

----------------------------------------------------------------------------

Hazard Summary

* Acrolein is extremely toxic to humans, with a probable oral lethal dose

of 5 to 50Êmg/kg.

* The acute (short-term) and chronic (long-term) effects of acrolein in

humans consist mainly of effects on the lung, such as upper respiratory

tract irritation and congestion and eye irritation.

* The Reference Concentration (RfC) for acrolein is 0.00002 mg/m3.a The

U.S. Environmental Protection Agency (EPA) estimates that inhalation of

this concentration or less, over a lifetime, would not likely result in

the occurrence of chronic, noncancer effects.b

* EPA has not established a Reference Dose (RfD) for acrolein. However,

EPA has calculated a provisional RfDc of 0.02 mg/kg/dd for acrolein.

* Limited data are available on the reproductive or developmental effects

of acrolein. No reproductive effects were observed in one inhalation

animal study. Birth defects were observed in other animal studies, but

only when acrolein was injected directly into the embryonic tissue.

* No human cancer data are available for acrolein. The animal cancer data

are limited, with one study reporting an increased incidence of

adrenocortical tumors in female rats exposed to acrolein in the

drinking water. EPA has classified acrolein as a Group C, possible

human carcinogen.

-------------------------

a Milligrams per cubic meter is the unit of measurement for chemicals in

air.

b The RfC is not a direct estimator of risk but rather a reference point to

gauge the potential effects. Exceedance of the RfC does not imply that an

adverse health effect would necessarily occur. As the amount and frequency

of exposures exceeding the RfC increase, the probability of adverse health

effects also increases.

c The provisional RfD is a value that has had some form of Agency review,

but it does not appear on the Integrated Risk Information System (IRIS).

d Milligrams per kilogram per day is one way to measure the amount of the

contaminant that is consumed in food.

Please Note: The main sources of information for this fact sheet are EPA's

IRIS, which contains information on inhalation chronic toxicity of acrolein

and the RfC, and the Agency for Toxic Substances and Disease Registry's

(ATSDR's) Toxicological Profile for Acrolein. Other secondary sources

include the Hazardous Substances Data Bank (HSDB), a database of summaries

of peer-reviewed literature, and the Registry of Toxic Effects of Chemical

Substances (RTECS), a database of toxic effects that are not peer reviewed.

Environmental/Occupational Exposure

* Acrolein can be formed from the breakdown of certain pollutants found

in outdoor air, from burning tobacco, or from burning gasoline. (1)

* Airborne exposure to acrolein may occur from breathing contaminated

air, from smoking tobacco or proximity to someone who is smoking, or

from being near automobiles or oil or coal power plants. In several

large cities, acrolein has been measured at 9 ppb. (1)

* Occupational exposure to acrolein could occur in industries that use

acrolein to make other chemicals. (1)

* Small amounts of acrolein may be found in some foods, such as fried

foods, cooking oils, and roasted coffee. (1)

* Acrolein has not been detected in drinking water, and is not commonly

found in surface water. (1)

Assessing Personal Exposure

* There are currently no tests available to determine personal exposure

to acrolein. (1)

Health Hazard Information

Acute Effects:

* Acute inhalation exposure to high levels (10 ppm) of acrolein in humans

may result in death. Effects on the lung, such as upper respiratory

tract irritation and congestion have been noted at acrolein levels

ranging from 0.17 ppm to 0.43 ppm. (1-3)

* Acrolein is considered to have high acute toxicity, based on short-term

animal tests such as the LC50 test in rats. (1,4)

* EPA's Office of Air Quality Planning and Standards, for a hazard

ranking under Section 112(g) of the Clean Air Act Amendments, considers

acrolein to be a "high concern" pollutant based on acute chronic

toxicity. (5)

Chronic Effects (Noncancer):

* The major effects from chronic (long-term) inhalation exposure to

acrolein in humans consist of general respiratory congestion and eye,

nose, and throat irritation. (1,2,6)

* Acrolein is a strong dermal irritant, causing skin burns in humans.

(1,2,6)

* Animal studies have reported that the respiratory system is the major

target organ for acrolein toxicity. (1,2,6)

* The RfC for acrolein is 0.00002 mg/m3 based on squamous metaplasia and

neutrophilic infiltration of nasal epithelium in rats. (3)

* EPA has high confidence in the studies on which the RfC was based

because adequate numbers of animals were used, careful attention was

paid to experimental protocol, and together they demonstrated a

consistent profile of histopathological changes in the respiratory

system; low to medium confidence in the database due to the lack of

chronic data and adequately conducted reproductive or developmental

studies; and, consequently, medium confidence in the RfC.

* EPA has not established an RfD for acrolein. (3)

* EPA has calculated a provisional RfD of 0.02 mg/kg/d for acrolein. (7)

Reproductive/Developmental Effects:

* No information is available on the reproductive or developmental

effects of acrolein in humans. (1)

* In the one available reproductive animal study, rats were exposed to

acrolein by inhalation, with no effects observed on the number of

pregnancies or the number and weights of the fetuses. (1)

* Acrolein has been reported to cause birth defects in rats when injected

directly into the embryonic tissue. (1)

Cancer Risk:

* No information is available on the carcinogenic effects of acrolein in

humans. (1,3)

* Limited animal cancer data are available; one inhalation study in rats

reported no evidence of tumors in the respiratory tract or in other

tissues and organs, while another study reported an increased incidence

of adrenocortical tumors in female rats exposed to acrolein in drinking

water. (1,3)

* EPA has classified acrolein as a Group C, possible human carcinogen,

based on limited evidence of carcinogenicity in animals, the structural

similarity of acrolein to substances possibly carcinogenic to humans,

the carcinogenic potential of one of its metabolites, and the lack of

human data. (3)

Physical Properties

* Acrolein is a water-white or yellow liquid that burns easily and is

easily volatilized. (1)

* Acrolein has a disagreeable odor and an odor threshold of 0.2 ppm.

(1,8)

* The chemical formula for acrolein is C3H4O and the molecular weight is

56.06 g/mol. (1)

* The vapor pressure for acrolein is 220 mm Hg at 20ÊC, and its log

octanol/water partition coefficient (Log Kow) is -0.01. (1)

Uses

* Acrolein is used to make other chemicals and pesticides, and is found

in some livestock feeds and pesticides. (1)

-------------------------

Conversion Factors:

To convert from ppm to mg/m3: mg/m3 = (ppm) x (molecular weight of the

compound)/(24.45).

For acrolein: 1 ppm = 2.29 mg/m3.

Health Data from Inhalation Exposure

Concentration Health numbersa Regulatory, advisory Reference

(mg/m3) numbersb

1,000.0

-- * LC50 4

-- (rats)

-- * (298

--

100.0 mg/m3)

--

--

--

--

10.0

--

--

--

--

1.0

-- * LOAEL 3

-- (rats)

-- * (0.917

-- mg/m3) * ACGIH and OSHA STEL 6

0.1 * (0.8 mg/m3)

* ACGIH TLV, OSHA

PEL, and NIOSH IDLH 6

(0.25 mg/m3)

--

--

--

--

0.01

--

--

--

--

0.001

--

--

--

--

0.0001

-- * RfC 3

-- (0.00002

-- mg/m3)

--

0.00001

ACGIH STEL--American Conference of Governmental and Industrial

Hygienists' short-term exposure limit; 15-min time-weighted-average

exposure that should not be exceeded at any time during a workday even

if the 8-h time-weighted-average is within the threshold limit value.

ACGIH TLV--American Conference of Governmental and Industrial

Hygienists' threshold limit value expressed as a time-weighted average;

the concentration of a substance to which most workers can be exposed

without adverse effects.

LC50 (Lethal Concentration50)--A calculated concentration of a chemical

in air to which exposure for a specific length of time is expected to

cause death in 50% of a defined experimental animal population.

LOAEL--Lowest-observed-adverse-effect level.

NIOSH IDLH--National Institute of Occupational Safety and Health's

immediately dangerous to life and health; NIOSH concentration

representing the maximum level of a pollutant from which an individual

could escape within 30 min without escape-impairing symptoms or

irreversible health effects.

OSHA PEL--Occupational Safety and Health Administration's permissible

exposure limit expressed as a time-weighted average; the concentration

of a substance to which most workers can be exposed without adverse

effect averaged over a normal 8-h workday or a 40-h workweek.

OSHA STEL--Occupational Safety and Health Administration's short-term

exposure limit; 15-min time-weighted-average exposure that should not

be exceeded at any time during a workday even if the 8-h

time-weighted-average is within the threshold limit value.

RfC--Reference concentration.

a Health numbers are toxicological numbers from animal testing or risk

assessment values developed by EPA.

b Regulatory numbers are values that have been incorporated in

Government regulations, while advisory numbers are nonregulatory values

provided by the Government or other groups as advice.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR).

Toxicological Profile for Acrolein. U.S. Public Health Service,

U.S. Department of Health and Human Services, Atlanta, GA. 1989.

2. U.S. Department of Health and Human Services. Hazardous Substances

Data Bank (HSDB, online database). National Toxicology Information

Program, National Library of Medicine, Bethesda, MD. 1993.

3. U.S. Environmental Protection Agency. Integrated Risk Information

System (IRIS) on Acrolein. Environmental Criteria and Assessment

Office, Office of Health and Environmental Assessment, Office of

Research and Development, Cincinnati, OH. 1993.

4. U.S. Department of Health and Human Services. Registry of Toxic

Effects of Chemical Substances (RTECS). National Toxicology

Information Program, National Library of Medicine, Bethesda, MD.

1993.

5. U.S. Environmental Protection Agency. Technical Background

Document to Support Rulemaking Pursuant to the Clean Air

Act--Section 112(g). Ranking of Pollutants with Respect to Hazard

to Human Health. EPAÐ450/3-92-010. Emissions Standards Division,

Office of Air Quality Planning and Standards, Research Triangle

Park, NC. 1994.

6. E.J. Calabrese and E.M. Kenyon. Air Toxics and Risk Assessment.

Lewis Publishers, Chelsea, MI. 1991.

7. U.S. Environmental Protection Agency. Health Effects Assessment

Summary Tables. Annual Update. Environmental Criteria and

Assessment Office, Office of Health and Environmental Assessment,

Office of Research and Development, Cincinnati, OH. 1993.

8. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety:

Odor thresholds compared with threshold limit values and

volatilities for 214 industrial chemicals in air and water

dilution. Journal of Applied Toxicology, 3(6):272-290. 1983.

-----------------------------------------------------------------------

BENZENE

71-43-2

----------------------------------------------------------------------------

Hazard Summary

* Acute (short-term) inhalation exposure to benzene may cause drowsiness,

dizziness, headaches, and unconsciousness in humans. These symptoms

stop when the exposure ceases. Death may result from exposure to very

high levels of benzene. Ingestion of large amounts of benzene may

result in vomiting, dizziness, convulsions, and death in humans.

Exposure to benzene liquid and vapor may irritate the skin, eyes, and

upper respiratory tract. Animals acutely exposed show anemia, bone

marrow cell depression, and immunologic effects from inhalation and

oral exposure.

* Chronic (long-term) inhalation exposure has caused various disorders in

the blood, including reduced numbers of red blood cells and aplastic

anemia, in occupational settings. Toxicity to the humoral and cellular

immune systems has also been seen.

* The Reference Concentration (RfC) and Reference Dose (RfD) for benzene

are under review by the U.S. Environmental Protection Agency (EPA).

* Menstrual disorders and a decreased size of ovaries have been observed

in women occupationally exposed to high levels of benzene. Adverse

effects on the fetus, including low birth weight, delayed bone

formation, and bone marrow damage, have been observed from exposure of

pregnant animals to benzene by inhalation.

* Increased incidence of leukemia (cancer of the tissues that form white

blood cells) have been observed in humans occupationally exposed to

benzene. EPA has classified benzene as a Group A, known human

carcinogen of medium carcinogenic hazard, with a 1/ED10 value of 0.27

per (mg/kg)/da and an inhalation unit risk estimate of 8.3 x 10-6

(µg/m3)-1.

-------------------------

a The 1/ED10 value is a measure of the carcinogenic potency of a chemical.

The value reported here has been proposed in the hazard ranking of hazardous

air pollutants in EPA's proposed rulemaking (Section 112(g) of the Clean Air

Act, April 1994).

Please Note: The main sources of information for this fact sheet are the

Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological

Profile for Benzene and EPA's Integrated Risk Information System (IRIS),

which contains information on the carcinogenic effects of benzene including

the unit cancer risk for inhalation exposure. Other secondary sources

include the Registry of Toxic Effects of Chemical Substances (RTECS), a

database of toxic effects that are not peer reviewed, and the Handbook of

Toxic and Hazardous Chemicals and Carcinogens.

Environmental/Occupational Exposure

* Individuals employed in industries that manufacture or use benzene may

be exposed to the highest levels of benzene. (1)

* Benzene is found in emissions from burning coal and oil, motor vehicle

exhaust, and evaporation from gasoline service stations and in

industrial solvents. These sources contribute to elevated levels of

benzene in the ambient air, which may subsequently be breathed by the

public. (1)

* Tobacco smoke contains benzene and accounts for approximately 50

percent of the public's exposure to benzene. (1)

* Individuals may also be exposed to benzene by consuming contaminated

water. (1)

Assessing Personal Exposure

* Measurement of benzene in an individual's breath or blood or the

measurement of breakdown products in the urine (phenol) can estimate

personal exposure. However, the tests must be done shortly after

exposure and are not helpful for measuring low levels of benzene. (1)

Health Hazard Information

Acute Effects:

* Coexposure to benzene with ethanol can increase benzene toxicity. (1)

* Neurological symptoms of inhalation exposure to benzene include

drowsiness, dizziness, headaches, and unconsciousness in humans. Death

may result from exposure to very high levels of benzene. Ingestion of

large amounts of benzene may result in vomiting, dizziness,

convulsions, and death in humans. (1)

* Exposure to liquid and vapor may irritate the skin, eyes, and upper

respiratory tract. Redness and blisters may result from dermal exposure

to benzene. (1,2)

* Animal studies show neurologic, immunologic, and hematologic effects

from inhalation and oral exposure to benzene. (1)

* Tests involving acute exposure of animals, such as the LC50 and LD50

tests in rats, mice, rabbits, and guinea pigs, have demonstrated

benzene to have low acute toxicity from inhalation, moderate acute

toxicity from ingestion, and low or moderate acute toxicity from dermal

exposure. (3)

Chronic Effects (Noncancer):

* Chronic (long-term) inhalation of benzene causes disorders in the blood

in humans. Benzene specifically affects bone marrow (the tissues that

produce blood cells). Aplastic anemia,(1) excessive bleeding, and

damage to the immune system (by changes in blood levels of antibodies

and loss of white blood cells) may develop. (1)

* In animals, chronic inhalation and oral exposure to benzene produces

the same effects as seen in humans. (1)

* Benzene causes both structural and numerical chromosomal aberrations in

humans. (1)

* The RfC and RfD for benzene are under review by EPA. (4)

Reproductive/Developmental Effects:

* Menstrual disorders and a decreased size of ovaries have been observed

in women occupationally exposed to high levels of benzene. (1)

* Several occupational studies suggest that benzene may impair fertility

in women exposed to high levels. However, these studies are limited due

to lack of exposure history, simultaneous exposure to other substances,

and lack of followup. (1)

* Available human data on the developmental effects of benzene are

inconclusive due to concomitant exposure to other chemicals, inadequate

sample size, and lack of quantitative exposure data. (1)

* Adverse effects on the fetus, including low birth weight, delayed bone

formation, and bone marrow damage, have been observed where pregnant

animals were exposed to benzene by inhalation. (1)

Cancer Risk:

* Increased incidence of leukemia (cancer of the tissues that form white

blood cells) has been observed in humans occupationally exposed to

benzene. (1,4)

* EPA has classified benzene as a Group A, known human carcinogen. (4)

* EPA uses mathematical models, based on human and animal studies, to

estimate the probability of a person developing cancer from breathing

air containing a specified concentration of a chemical. EPA calculated

an inhalation unit risk estimate of 8.3 x 10-6 (µg/m3)-1. EPA estimates

that, if an individual were to breathe air containing benzene at 0.1

µg/m3(2) over his or her entire lifetime, that person would

theoretically have no more than a one-in-a-million increased chance of

developing cancer as a direct result of breathing air containing this

chemical. Similarly, EPA estimates that breathing air containing 1.0

µg/m3 would result in not greater than a one-in-a-hundred thousand

increased chance of developing cancer, and air containing 10.0 µg/m3

would result in not greater than a one-in-ten thousand increased chance

of developing cancer.Ê(4)

* EPA's Office of Air Quality Planning and Standards, for a hazard

ranking under Section 112(g) of the Clean Air Act Amendments, has

ranked benzene in the nonthreshold category. The 1/ED10 value is 0.27

per (mg/kg)/d and this would place it in the medium category under

Superfund's ranking for carcinogenic hazard. (5)

Physical Properties

* The chemical formula for benzene is C6H6, and it has a molecular weight

of 78.11 g/mol.Ê(4)

* Benzene occurs as a volatile, colorless, highly flammable liquid that

dissolves easily in water. (1,6)

* Benzene has a sweet odor with an odor threshold of 1.5 ppm (5 mg/m3).

(1)

* The vapor pressure for benzene is 95.2 mm Hg at 25ÊC, and it has a log

octanol/water partition coefficient (log Kow) of 2.13. (1)

Uses

* Benzene is used as a constituent in motor fuels; as a solvent for fats,

waxes, resins, oils, inks, paints, plastics, and rubber; in the

extraction of oils from seeds and nuts; and in photogravure printing.

It is also used as a chemical intermediate. Benzene is also used in the

manufacture of detergents, explosives, pharmaceuticals, and dyestuffs.

(2,6)

-------------------------

Conversion Factors:

To convert from ppm to mg/m3: mg/m3 = (ppm) x (molecular weight of the

compound)/(24.45). For benzene: 1 ppm = 3.26 mg/m3.

To convert from µg/m3 to mg/m3: mg/m3 = (µg/m3) x (1Êmg/1,000 µg).

Health Data from Inhalation Exposure

Concentration Health numbersa Regulatory, Reference

(mg/m3) advisory

numbersb

100,000.0

-- * LC50 (rats) 4

--

-- (31,951Êmg/m3) 4

-- * LC50 (mice)

10,000.0 (31,887Êmg/m3)

--

--

--

--

1,000.0

--

--

--

--

100.0

-- * MSHA 1,4

-- standard

-- (80 mg/m3) 1,4

-- * ACGIH TLV

10.0 (32 mg/m3)

-- * OSHA PEL 1,4

-- (3.26

-- mg/m3)

--

1.0

-- * NIOSH REL 1,4

-- (0.32

-- mg/m3)

--

0.1

--

--

--

--

0.01

--

--

--

--

0.001

-- * EPA Cancer Risk Level 4

-- (1-in-a-million excess

-- lifetime risk) = 1.0 x

-- 10-4 mg/m3

0.0001

ACGIH TLV--American Conference of Governmental and Industrial Hygienists'

threshold limit value expressed as a time-weighted average; the

concentration of a substance to which most workers can be exposed without

adverse effects.

LC50 (Lethal Concentration50)--A calculated concentration of a chemical in

air to which exposure for a specific length of time is expected to cause

death in 50% of a defined experimental animal population.

MSHA--Mine Safety and Health Administration.

NIOSH REL--National Institute of Occupational Safety and Health's

recommended exposure limit; NIOSH-recommended exposure limit for an 8- or

10-h time-weighted-average exposure and/or ceiling.

OSHA PEL--Occupational Safety and Health Administration's permissible

exposure limit expressed as a time-weighted average; the concentration of a

substance to which most workers can be exposed without adverse effect

averaged over a normal 8-h workday or a 40-h workweek.

a Health numbers are toxicological numbers from animal testing or risk

assessment values developed by EPA.

b Regulatory numbers are values that have been incorporated in Government

regulations, while advisory numbers are nonregulatory values provided by the

Government or other groups as advice.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological

Profile for Benzene (Draft). U.S. Public Health Service, U.S.

Department of Health and Human Services, Atlanta, GA. 1991.

2. M. Sittig. Handbook of Toxic and Hazardous Chemicals and Carcinogens.

2nd ed. Noyes Publications, Park Ridge, NJ. 1985.

3. U.S. Department of Health and Human Services. Registry of Toxic Effects

of Chemical Substances (RTECS, online database). National Toxicology

Information Program, National Library of Medicine, Bethesda, MD. 1993.

4. U.S. Environmental Protection Agency. Integrated Risk Information

System (IRIS) on Benzene. Environmental Criteria and Assessment Office,

Office of Health and Environmental Assessment, Office of Research and

Development, Cincinnati, OH. 1993.

5. U.S. Environmental Protection Agency. Technical Background Document to

Support Rulemaking Pursuant to the Clean Air Act--Section 112(g).

Ranking of Pollutants with Respect to Hazard to Human Health.

EPAÐ450/3-92-010. Emissions Standards Division, Office of Air Quality

Planning and Standards, Research Triangle Park, NC. 1994.

6. The Merck Index. An Encyclopedia of Chemicals, Drugs, and Biologicals.

11th ed. Ed. S. Budavari. Merck and Co. Inc., Rahway, NJ. 1989.

1. *Aplastic anemia is a risk factor for developing acute nonlymphocytic

leukemia.

2. *Micrograms per cubic meter is the unit of measurement for chemicals in

air.

----------------------------------------------------------------------------

EPA Home | OAR Home | OAQPS Home | TTN Home | UATW

Home | Fact Sheet Home Contact UATW Webmaster

[United States Environmental Protection Agency Home Page]ning & Standards]

[TTNWeb][TTNWeb UATW]

----------------------------------------------------------------------------

1,3-BUTADIENE

106-99-0

----------------------------------------------------------------------------

Hazard Summary

* Acute (short-term) exposure to 1,3-butadiene by inhalation in humans

results in irritation of the eyes, nasal passages, throat, and lungs,

and causes neurological effects such as blurred vision, fatigue,

headache, and vertigo.

* Epidemiological studies have reported a possible association between

1,3-butadiene exposure and cardiovascular diseases.

* The U.S. Environmental Protection Agency (EPA) has not established a

Reference Concentration (RfC) or a Reference Dose (RfD) for

1,3-butadiene.

* No information is available on the reproductive or developmental

effects of 1,3-butadiene in humans. Animal studies have reported

developmental effects, such as skeletal abnormalities and decreased

fetal weights, and reproductive effects, including an increased

incidence of ovarian atrophy and testicular atrophy, from inhalation

exposure to 1,3-butadiene.

* Several epidemiological studies of workers in styrene-butadiene rubber

plants have shown an increased incidence of several tumor types.

However, these studies are not sufficient to determine a causal

relationship between 1,3-butadiene exposure and cancer, due to many

confounding factors. Animal studies have reported tumors at a variety

of sites from inhalation exposure to 1,3-butadiene. EPA has classified

1,3-butadiene as a Group B2, probable human carcinogen of medium

carcinogenic hazard, with a 1/ED10 value of 8.4 per (mg/kg)/da and an

inhalation unit risk estimate of 2.8 X 10-4 (µg/m3)-1.

-------------------------

a The 1/ED10 value is a measure of the carcinogenic potency of a chemical.

The value reported here has been proposed in the hazard ranking of hazardous

air pollutants in EPA's proposed rulemaking (Section 112(g) of the Clean Air

Act, April 1994).

Please Note: The main sources of information for this fact sheet are EPA's

Integrated Risk Information System (IRIS), which contains information on the

carcinogenic effects of 1,3-butadiene including the unit cancer risk for

inhalation exposure, and the Agency for Toxic Substances and Disease

Registry's (ATSDR's) Toxicological Profile for 1,3-Butadiene. Other

secondary sources include the Hazardous Substances Data Bank (HSDB), a

database of summaries of peer-reviewed literature, and the Registry of Toxic

Effects of Chemical Substances (RTECS), a database of toxic effects that are

not peer reviewed.

Environmental/Occupational Exposure

* 1,3-Butadiene has been detected in ambient air, where it is released

from motor vehicle exhaust, at an average level of 0.3 ppb (in cities

and suburban areas). (1)

* Higher levels of 1,3-butadiene may be found in highly industrialized

cities or near oil refineries, chemical manufacturing plants, and

plastic and rubber factories. (1)

* 1,3-Butadiene has been found in drinking water and in plastic or rubber

food containers, but not in food samples. (1)

* Occupational exposure to 1,3-butadiene may occur in the rubber,

plastics, and resins industries. (1)

Assessing Personal Exposure

* There is no reliable medical test available at this time to assess

personal exposure to 1,3-butadiene. (1)

Health Hazard Information

Acute Effects:

* Acute (short-term) exposure to 1,3-butadiene by inhalation in humans

results in irritation of the eyes, nasal passages, throat, and lungs.

Neurological effects, such as blurred vision, fatigue, headache, and

vertigo, have also been reported. (1-3)

* Dermal exposure to 1,3-butadiene causes a sensation of cold, followed

by a burning sensation, which may lead to frostbite. (1)

* Tests involving acute exposure of animals, such as the LC50 test in

rats and mice, have shown 1,3-butadiene to have low acute toxicity.

(1,4)

Chronic Effects (Noncancer):

* One epidemiological study reported that chronic (long-term) exposure to

1,3-butadiene via inhalation resulted in an increase in cardiovascular

diseases, such as rheumatic and arteriosclerotic heart diseases, while

other human studies have reported effects on the blood. (1)

* Animal studies have reported effects on the respiratory and

cardiovascular systems, blood, and liver from chronic, inhalation

exposure to 1,3-butadiene. (1)

* EPA has not established an RfC or an RfD for 1,3-butadiene. (5)

Reproductive/Developmental Effects:

* No information is available on the reproductive or developmental

effects of 1,3-butadiene in humans. (1)

* Animal studies have reported developmental effects, such as skeletal

abnormalities and decreased fetal weights, and reproductive effects,

including an increased incidence of ovarian atrophy and testicular

atrophy from inhalation exposure to 1,3-butadiene. (1)

Cancer Risk:

* Several epidemiological studies of workers in styrene-butadiene rubber

factories have shown an increased incidence of respiratory, bladder,

stomach, and lymphato-hematopoietic cancers. However, these studies are

not sufficient to determine a causal association between 1,3-butadiene

exposure and cancer due to possible exposure to other chemicals and

other confounding factors. (1,5,6)

* Animal studies have reported tumors at a variety of sites from

inhalation exposure to 1,3-butadiene. (1,5,6)

* EPA has classified 1,3-butadiene as a Group B2, probable human

carcinogen. (5)

* EPA uses mathematical models, based on animal studies, to estimate the

probability of a person developing cancer from breathing air containing

a specified concentration of a chemical. EPA has calculated an

inhalation unit risk estimate of 2.8 x 10-4 (µg/m3)-1. EPA estimates

that, if an individual were to breathe air containing 1,3-butadiene at

0.004 µg/m3(1) over his or her entire lifetime, that person would

theoretically have no more than a one-in-a-million increased chance of

developing cancer as a direct result of breathing air containing this

chemical. Similarly, EPA estimates that breathing air containing 0.04

µg/m3 would result in not greater than a one-in-a-hundred thousand

increased chance of developing cancer, and air containing 0.4 µg/m3

would result in not greater than a one-in-ten-thousand increased chance

of developing cancer. (5)

* EPA's Office of Air Quality Planning and Standards, for a hazard

ranking under Section 112(g) of the Clean Air Act Amendments, has

ranked 1,3-butadiene in the nonthreshold category. The 1/ED10 value is

8.4 per (mg/kg)/d and this would place it in the medium category under

Superfund's ranking for carcinogenic hazard. (6)

Physical Properties

* 1,3-Butadiene is a colorless gas with a mild gasoline-like odor. (1)

* The odor threshold for 1,3-butadiene is 1.6 ppm. (7)

* The chemical formula for 1,3-butadiene is C4H6, and the molecular

weight is 54.09 g/mol.Ê(1)

* The vapor pressure for 1,3-butadiene is 2100 mm Hg at 25ÊC, and it has

an octanol/water partition coefficient (Log Kow) of 1.99. (1)

Uses

* 1,3-Butadiene is used in the production of rubber and plastics. It is

also used in copolymers including acrylics. (1)

-------------------------

Conversion Factors:

To convert from ppm to mg/m3: mg/m3 = (ppm) x (molecular weight of the

compound)/(24.45). For 1,3-butadiene: 1 ppm = 2.21 mg/m3.

To convert from µg/m3 to mg/m3: mg/m3 = (µg/m3) x (1 mg/1,000 µg).

Health Data from Inhalation Exposure

Concentration Health numbersa Regulatory, Reference

(mg/m3) advisory numbersb

1,000,000.0

-- * LC50 (rats and mice) 1,4

-- (269,896 and 285,382

-- mg/m3)

--

100,000.0

--

--

--

--

10,000.0

-- * OSHA PEL 2

-- (2,200

-- mg/m3)

--

1,000.0

--

--

--

--

100.0

-- * ACGIH TLV 2

-- (22 mg/m3)

--

--

10.0

--

--

--

--

1.0

--

--

--

--

0.1

--

--

--

--

0.01

--

--

--

--

0.001

--

--

--

--

0.0001

--

--

--

--

0.00001

--

--

--

--

0.000001

-- * EPA Cancer Risk Level 5

-- (1-in-a-million excess

-- lifetime risk) = 4.0 x

-- 10-6 mg/m3

0.0000001

ACGIH TLV--American Conference of Governmental and Industrial Hygienists'

threshold limit value expressed as a time-weighted average; the

concentration of a substance to which most workers can be exposed without

adverse effects.

LC50 (Lethal Concentration50)--A calculated concentration of a chemical in

air to which exposure for a specific length of time is expected to cause

death in 50% of a defined experimental animal population.

OSHA PEL--Occupational Safety and Health Administration's permissible

exposure limit expressed as a time-weighted average; the concentration of a

substance to which most workers can be exposed without adverse effect

averaged over a normal 8-h workday or a 40-h workweek.

a Health numbers are toxicological numbers from animal testing or risk

assessment values developed by EPA.

b Regulatory numbers are values that have been incorporated in Government

regulations, while advisory numbers are nonregulatory values provided by the

Government or other groups as advice.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological

Profile for 1,3-Butadiene (Draft). U.S. Public Health Service, U.S.

Department of Health and Human Services, Atlanta, GA. 1992.

2. E.J. Calabrese and E.M. Kenyon. Air Toxics and Risk Assessment. Lewis

Publishers. 1991.

3. U.S. Department of Health and Human Services. Hazardous Substances Data

Bank (HSDB, online database). National Toxicology Information Program,

National Library of Medicine, Bethesda, MD. 1993.

4. U.S. Department of Health and Human Services. Registry of Toxic Effects

of Chemical Substances (RTECS, online database). National Toxicology

Information Program, National Library of Medicine, Bethesda, MD. 1993.

5. U.S. Environmental Protection Agency. Integrated Risk Information

System (IRIS) on 1,2-Butadiene. Environmental Criteria and Assessment

Office, Office of Health and Environmental Assessment, Office of

Research and Development, Cincinnati, OH. 1993.

6. U.S. Environmental Protection Agency. Technical Background Document to

Support Rulemaking Pursuant to the Clean Air Act--Section 112(g).

Ranking of Pollutants with Respect to Hazard to Human Health.

EPAÐ450/3-92-010. Emissions Standards Division, Office of Air Quality

Planning and Standards, Research Triangle Park, NC. 1994.

7. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor

thresholds compared with threshold limit values and volatilities for

214 industrial chemicals in air and water dilution. Journal of Applied

Toxicology, 3(6):272-290. 1983.

1. *Micrograms per cubic meter is the unit of measurement for chemicals in

air.

----------------------------------------------------------------------------

FORMALDEHYDE

50-00-0

------------------------------------------------------------------------

Hazard Summary

* Acute (short-term) and chronic (long-term) inhalation exposure to

formaldehyde in humans can result in eye, nose, and throat irritation

and respiratory symptoms.

* The Reference Dose (RfD) for formaldehyde is 0.2 mg/kg/d.a The U.S.

Environmental Protection Agency (EPA) estimates that consumption of

this dose or less, over a lifetime, would not likely result in the

occurrence of chronic, noncancer effects.b

* EPA has not established a Reference Concentration (RfC) for

formaldehyde.

* Reproductive effects, such as menstrual disorders and pregnancy

problems, have been reported in women workers exposed to formaldehyde.

No other reproductive or developmental effects have been reported in

humans or animals.

* Limited human studies have reported an association between

formaldehyde exposure and lung and nasopharyngeal cancer. Animal

inhalation studies have reported an increased incidence of nasal

squamous cell cancer. EPA has classified formaldehyde as a Group B1,

probable human carcinogen of medium carcinogenic hazard, with a 1/ED10

value of 3 per (mg/kg)/dc and an inhalation unit risk estimate of 1.3

× 10-5 (µg/m3)-1.

-------------------------

a Milligrams per kilogram per day is one way to measure the amount of the

contaminant that is consumed in food.

b The RfD is not a direct estimator of risk but rather a reference point to

gauge the potential effects. Exceedance of the RfD does not imply that an

adverse health effect would necessarily occur. As the amount and frequency

of exposures exceeding the RfD increase, the probability of adverse health

effects also increases.

c The 1/ED10 value is a measure of the carcinogenic potency of a chemical.

The value reported here has been proposed in the hazard ranking of

hazardous air pollutants in EPA's proposed rulemaking (Section 112(g) of

the Clean Air Act, April 1994).

Please Note: The main sources of information for this fact sheet are EPA's

Health and Environmental Effects Profile for Formaldehyde and the

Integrated Risk Information System (IRIS), which contains information on

oral chronic toxicity and the RfD, and the carcinogenic effects of

formaldehyde including the unit cancer risk for inhalation exposure. Other

secondary sources include the Hazardous Substances Data Bank (HSDB), a

database of summaries of peer-reviewed literature, and the Registry of

Toxic Effects of Chemical Substances (RTECS), a database of toxic effects

that are not peer reviewed.

Environmental/Occupational Exposure

* The highest levels of airborne formaldehyde have been detected in

indoor air, where it is released from various consumer products. One

survey reported formaldehyde levels ranging from 0.10 to 3.68 ppm in

homes. (1)

* Formaldehyde has also been detected in ambient air; the average

concentrations reported in U.S. urban areas were in the range of 11 to

20 ppb. The major sources appear to be power plants, manufacturing

facilities, incinerators, and automobile exhaust emissions. (7)

* Smoking is another important source of formaldehyde. (1)

* Formaldehyde may also be present in food, either naturally or as a

result of contamination. (1)

Assessing Personal Exposure

* Blood levels of formaldehyde can be measured. However, these

measurements only appear to be useful when exposure to relatively

large amounts of formaldehyde has occurred. (2)

Health Hazard Information

Acute Effects:

* The major toxic effects caused by acute formaldehyde exposure via

inhalation are eye, nose, and throat irritation and effects on the

nasal cavity. (1,2)

* Other effects seen from exposure to high levels of formaldehyde in

humans are coughing, wheezing, chest pains, and bronchitis. (1,2)

* Ingestion exposure to formaldehyde in humans has resulted in corrosion

of the gastrointestinal tract and inflammation and ulceration of the

mouth, esophagus, and stomach. (1,2)

* Acute (short-term) animal tests, such as the LC50 and LD50 tests in

rats and rabbits have shown formaldehyde to have high acute toxicity

from inhalation, oral, and dermal exposure. (3)

Chronic Effects (Noncancer):

* Chronic exposure to formaldehyde by inhalation in humans has been

associated with respiratory symptoms and eye, nose, and throat

irritation. (1,2,4,5)

* Repeated contact with liquid solutions of formaldehyde has resulted in

skin irritation and allergic contact dermatitis. (5)

* Animal studies have reported effects on the nasal respiratory

epithelium and lesions in the respiratory system from chronic

inhalation exposure to formaldehyde. (1,2,4,5)

* The RfD for formaldehyde is 0.2 mg/kg/d based on a decrease in

bodyweight gain and effects on the stomach in rats. (6)

* EPA has high confidence in the study on which the RfD was based since

it consisted of an adequate number of animals of both sexes, as well

as a thorough examination of toxicological and histological

parameters; medium confidence in the database as several additional

chronic bioassays and reproductive and developmental studies support

the critical effect and study; and, consequently, medium confidence in

the RfD. (6)

* EPA has not established an RfC for formaldehyde. (6)

Reproductive/Developmental Effects:

* An increased incidence of menstrual disorders and pregnancy problems

were observed in women workers using urea-formaldehyde resins.

However, possible confounding factors were not evaluated in this

study. (1,2)

* A study of hospital equipment sterilizing workers did not report an

association between formaldehyde exposure and increased spontaneous

abortions. (1,2)

* Developmental effects, such as birth defects, have not been observed

in animal studies with formaldehyde. (1,2)

Cancer Risk:

* Occupational studies have noted statistically significant associations

between exposure to formaldehyde and increased incidence of lung and

nasopharyngeal cancer. This evidence is considered to be "limited,"

rather than "sufficient," due to possible exposure to other agents

that may have contributed to the excess cancers. (1,6)

* Animal studies have reported an increased incidence of nasal squamous

cell carcinomas by inhalation exposure. (1,6)

* EPA considers formaldehyde to be a probable human carcinogen

(cancer-causing agent) and has ranked it in EPA's Group B1. (6)

* EPA uses mathematical models, based on animal studies, to estimate the

probability of a person developing cancer from breathing air

containing a specified concentration of a chemical. EPA calculated an

inhalation unit risk estimate of 1.3 × 10-5 (µg/m3)-1. EPA estimates

that, if an individual were to breathe air containing formaldehyde at

0.08 µg/m3(1) over his or her entire lifetime, that person would

theoretically have no more than a one-in-a-million increased chance of

developing cancer as a direct result of breathing air containing this

chemical. Similarly, EPA estimates that breathing air containing 0.8

µg/m3 would result in not greater than a one-in-a-hundred thousand

increased chance of developing cancer, and air containing 8.0 µg/m3

would result in not greater than a one-in-ten-thousand increased

chance of developing cancer. (6)

* EPA's Office of Air Quality Planning and Standards, for a hazard

ranking under Section 112(g) of the Clean Air Act Amendments, has

ranked formaldehyde in the nonthreshold category. The 1/ED10 value is

3 per (mg/kg)/d and this would place it in the medium category under

Superfund's ranking for carcinogenic hazard. (7)

Physical Properties

* The chemical formula for formaldehyde is CH2O and the molecular weight

is 30.03 g/mol. (1)

* The vapor pressure for formaldehyde is 10 mm Hg at -88 C, and its log

octanol/water partition coefficient (Log Kow) is -0.65. (1)

* Formaldehyde is a colorless gas with a pungent, suffocating odor at

room temperature; the odor threshold for formaldehyde is 0.83 ppm.

(1,8)

* Formaldehyde is readily soluble in water at room temperature. (1)

* Commercial formaldehyde is produced and sold as an aqueous solution

containing 37 to 50 percent formaldehyde by weight. (1)

Uses

* Formaldehyde is used predominantly as a chemical intermediate. It also

has minor uses in agriculture, as an analytical reagent, in concrete

and plaster additives, cosmetics, disinfectants, fumigants,

photography, and wood preservation. (1,2)

* Formaldehyde (as urea formaldehyde foam) was extensively used as an

insulating material until 1982 when it was banned by the U.S. Consumer

Product Safety Commission. (1,2)

-------------------------

Health Data from Inhalation Exposure –Table not copied. Please see www.epa.gov web site (search on Formaldehyde) for the data

References

1. U.S. Environmental Protection Agency. Health and Environmental Effects

Profile for Formaldehyde. EPA/600/x-85/362. Environmental Criteria and

Assessment Office, Office of Health and Environmental Assessment,

Office of Research and Development, Cincinnati, OH. 1988.

2. World Health Organization. Environmental Health Criteria for

Formaldehyde. Volume 89. World Health Organization, Geneva,

Switzerland. 1989.

3. U.S. Department of Health and Human Services. Registry of Toxic

Effects of Chemical Substances (RTECS, online database). National

Toxicology Information Program, National Library of Medicine,

Bethesda, MD. 1993.

4. E.J. Calabrese and E.M. Kenyon. Air Toxics and Risk Assessment. Lewis

Publishers, Chelsea, MI. 1991.

5. U.S. Department of Health and Human Services. Hazardous Substances

Databank (HSDB, online database). National Toxicology Information

Program, National Library of Medicine, Bethesda, MD. 1993.

6. U.S. Environmental Protection Agency. Integrated Risk Information

System (IRIS) on Formaldehyde. Environmental Criteria and Assessment

Office, Office of Health and Environmental Assessment, Office of

Research and Development, Cincinnati, OH. 1993.

7. U.S. Environmental Protection Agency. Technical Background Document to

Support Rulemaking Pursuant to the Clean Air Act--Section 112(g).

Ranking of Pollutants with Respect to Hazard to Human Health.

EPA450/3-92-010. Emissions Standards Division, Office of Air Quality

Planning and Standards, Research Triangle Park, NC. 1994.

8. J.E. Amoore and E. Hautala. Odor as an aid to chemical safety: Odor

thresholds compared with threshold limit values and volatilities for

214 industrial chemicals in air and water dilution. Journal of Applied

Toxicology, 3(6):272-290. 1983.

1. *Micrograms per cubic meter is the unit of measurement for chemicals in

air.

METHYL CHLORIDE (CHLOROMETHANE)

----------------------------------------------------------------------------

Hazard Summary

* Methyl chloride is extremely toxic; acute (short-term) exposure to high

concentrations of methyl chloride in humans has caused severe

neurological effects including convulsions, coma, and death. Methyl

chloride has also caused effects on the heart rate, blood pressure,

liver, and kidney.

* No information is available regarding the chronic (long-term) effects

of methyl chloride in humans. Chronic animal studies have shown the

liver, kidney, spleen, and brain to be target organs in mice, and the

testes to be target organs in rats and mice.

* The Reference Dose (RfD) and the Reference Concentration (RfC) for

methyl chloride are currently under review by the U.S. Environmental

Protection Agency (EPA).

* No studies were located concerning developmental or reproductive

effects of methyl chloride in humans. Delayed fetal development was

found in rats exposed to the same concentration of methyl chloride that

resulted in maternal toxicity. In addition, inhalation studies have

demonstrated that methyl chloride causes reproductive effects in male

rats, with effects such as testicular lesions.

* The only available epidemiological study did not show any increases in

the incidences of cancer in workers exposed to methyl chloride. Animal

studies have noted kidney tumors in male mice. EPA has classified

methyl chloride as a Group C, possible human carcinogen of low

carcinogenic hazard, with a 1/ED10 value of 0.052 per (mg/kg)/d.a

-------------------------

a The 1/ED10 value is a measure of the carcinogenic potency of a chemical.

The value reported here has been proposed in the hazard ranking of hazardous

air pollutants in EPA's proposed rulemaking (Section 112(g) of the Clean Air

Act, April 1994).

Please Note: The main source of information for this fact sheet is the

Agency for Toxic Substances and Disease Registry's (ATSDR's) Toxicological

Profile for Chloromethane. Other secondary sources include the Hazardous

Substances Data Bank (HSDB), a database of summaries of peer-reviewed

literature, and the Registry of Toxic Effects of Chemical Substances

(RTECS), a database of toxic effects that are not peer reviewed.

Environmental/Occupational Exposure

* Methyl chloride is formed in the oceans by natural processes; it has

been detected in air all over the world. (1)

* Methyl chloride is also present in some lakes and streams and has been

found in drinking water at very low levels. (1)

* Other sources of exposure to methyl chloride include cigarette smoke,

polystyrene insulation, and aerosol propellants; home burning of wood,

coal, or certain plastics; and the use of chlorinated swimming pools.

(1)

* Occupations that present a higher risk of exposure include building

contracting, metal industries, transportation, car dealers, and

service-station attendants. (1)

Assessing Personal Exposure

* There is no known reliable medical test to determine exposure to methyl

chloride. (1)

Health Hazard Information

Acute Effects:

* In humans, brief exposures to methyl chloride can have serious effects

on the nervous system, including convulsions, coma, and death. Other

effects include dizziness, blurred or double vision, fatigue,

personality changes, confusion, tremors, uncoordinated movements,

nausea, and vomiting. (1)

* Numerous acute inhalation exposure studies have identified the liver

and kidney as target organs in rats and mice; the spleen as a target

organ in mice; the central nervous system (CNS) as a target system in

rats, mice, and dogs; and the testes and epididymides as target organs

in dogs. (1,2)

* Animal studies have shown that species differences in susceptibility

exist; generally, animals are more susceptible to relatively low

exposures given continuously than relatively high exposures given

intermittently. (1)

* Tests involving acute exposure of animals, such as the LD50 test in

rats and LC50 tests in rats and mice have shown methyl chloride to have

moderate acute toxicity. (3)

Chronic Effects (Noncancer):

* No information is available regarding the chronic (long-term) effects

of methyl chloride in humans. (1)

* Chronic animal studies have shown that the liver, kidney, spleen, and

brain were target organs in mice and the testes were target organs in

rats and mice. Animals that breathed air containing methyl chloride

grew more slowly than animals not exposed.Ê(1)

* The RfD and RfC for methyl chloride are currently under review by EPA.

(4)

Reproductive/Developmental Effects:

* No studies were located concerning developmental or reproductive

effects of methyl chloride in humans. (1)

* Delayed fetal development was noted in rats exposed to the same

concentration of methyl chloride that resulted in maternal toxicity.

Several inhalation studies have demonstrated that methyl chloride

causes reproductive effects in male rats, with effects such as

testicular lesions. (1)

Cancer Risk:

* The carcinogenicity assessment for lifetime exposure to methyl chloride

is currently under review by EPA. (4)

* The only information regarding carcinogenicity in humans after exposure

to methyl chloride comes from an epidemiological study of butyl rubber

workers which showed no statistically significant increase in the rate

of death due to cancer in this population.Ê(1)

* In animal studies, kidney tumors were reported in male mice. (1)

* EPA considers methyl chloride to be a possible human carcinogen

(cancer-causing agent) and has ranked it in EPA's Group C. (5)

* EPA's Office of Air Quality Planning and Standards, for a hazard

ranking under Section 112(g) of the Clean Air Act Amendments, has

ranked methyl chloride in the nonthreshold category. The 1/ED10 value

is 0.052 per (mg/kg)/d and this would place it in the low category

under Superfund's ranking for carcinogenic hazard. (5)

Physical Properties

* Methyl chloride is a colorless gas with a faint sweet smell. (1)

* Methyl chloride is soluble in water. (6)

* The chemical formula for methyl chloride is CH3Cl, and it has a

molecular weight of 50.49 g/mol. (1)

* The vapor pressure for methyl chloride is 4,310 mm Hg at 25ÊC, and the

log octanol/water partition coefficient (log Kow) is 0.91. (1,7)

Uses

* Methyl chloride is used mainly in the production of silicones where it

is used to methylate silicon. It is also used in the production of

agricultural chemicals, methyl cellulose, quaternary amines, and butyl

rubber and for miscellaneous uses including tetramethyl lead. (1)

* Methyl chloride was used widely in refrigerators in the past, but

generally this use has been taken over by newer chemicals such as

Freon. (1,8)

-------------------------

Conversion Factors:

To convert from ppm to mg/m3: mg/m3 = (ppm) x (molecular weight of the

compound)/(24.45). For methyl chloride: 1 ppm = 2.1 mg/m3.

To convert from g/m3 to mg/m3: mg/m3 = (g/m3) x (1 mg/1,000 g).

Health Data from Inhalation Exposure

Concentration Health numbersa Regulatory, advisory Reference

(mg/m3) numbersb

1,000,000.0

--

--

--

--

100,000.0

--

--

--

--

10,000.0

-- * LC50 (rats) 3

-- (5,300 mg/m3)

-- 3

-- * LC50 (mice)

1,000.0 (4,543Êmg/m3)

-- * ACGIH STEL, NIOSH 1,3

-- REL, MSHA standard,

-- OSHA STEL 1,3

-- (210Êmg/m3)

100.0 * ACGIH TLV, OSHA TWA

(105 mg/m3)

ACGIH STEL--American Conference of Governmental and Industrial Hygienists'

short-term exposure limit; 15-min time-weighted-average exposure that should

not be exceeded at any time during a workday even if the 8-h

time-weighted-average is within the threshold limit value.

ACGIH TLV--American Conference of Governmental and Industrial Hygienists'

threshold limit value expressed as a time-weighted average; the

concentration of a substance to which most workers can be exposed without

adverse effects.

LC50 (Lethal Concentration50)--A calculated concentration of a chemical in

air to which exposure for a specific length of time is expected to cause

death in 50% of a defined experimental animal population.

MSHA--Mine Safety and Health Administration.

NIOSH REL--National Institute of Occupational Safety and Health recommended

exposure limit; NIOSH-recommended exposure limit for an 8- or 10-h

time-weighted-average exposure and/or ceiling.

OSHA STEL--Occupational Safety and Health Administration's short-term

exposure limit; 15-min time-weighted-average exposure that should not be

exceeded at any time during a workday even if the 8-h time-weighted-average

is within the threshold limit value.

OSHA TWA--Occupational Safety and Health Administration's time-weighted

average; OSHA allowable exposure level in workplace air averaged over a

normal 8-h workday or a 40-h workweek expressed as a time-weighted average.

a Health numbers are toxicological numbers from animal testing or risk

assessment values developed by EPA.

b Regulatory numbers are values that have been incorporated in Government

regulations, while advisory numbers are nonregulatory values provided by the

Government or other groups as advice.

References

1. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological

Profile for Chloromethane. U.S. Public Health Service, U.S. Department

of Health and Human Services, Atlanta, GA. 1990.

2. U.S. Department of Health and Human Services. Hazardous Substances Data

Bank (HSDB, online database). National Toxicology Information Program,

National Library of Medicine, Bethesda, MD. 1993.

3. U.S. Department of Health and Human Services. Registry of Toxic Effects

of Chemical Substances (RTECS, online database). National Toxicology

Information Program, National Library of Medicine, Bethesda, MD. 1993.

4. U.S. Environmental Protection Agency. Integrated Risk Information

System (IRIS) on Chloromethane. Environmental Criteria and Assessment

Office, Office of Health and Environmental Assessment, Office of

Research and Development, Cincinnati, OH. 1993.

5. U.S. Environmental Protection Agency. Technical Background Document to

Support Rulemaking Pursuant to the Clean Air Act--Section 112(g).

Ranking of Pollutants with Respect to Hazard to Human Health.

EPAÐ450/3-92-010. Emissions Standards Division, Office of Air Quality

Planning and Standards, Research Triangle Park, NC. 1994.

6. R.C. Weast and M.J. Astle, Eds. CRC Handbook of Chemistry and Physics.

CRC Press, Inc., 63rd ed., Boca Raton, FL. 1982.

7. U.S. Environmental Protection Agency. Assessment Tools for the

Evaluation of Risk (ASTER, online database). Environmental Research

Laboratory, Duluth, MN. 1993.

8. The Merck Index. An Encyclopedia of Chemicals, Drugs, and Biologicals.

11th ed. Ed. S. Budavari. Merck and Co. Inc., Rahway, NJ. 1989.

----------------------------------------------------------------------------

EPA Home | OAR Home | OAQPS Home | TTN Home | UATW

Home | Fact Sheet Home Contact UATW Webmaster

====================================================================

Appendix C: Air Pollution

Appendix D: Unsafe Trucks Contrary to EIS Claims

A copy of the following letter was received from Senator Patterson. Note slight reformatting (margins) may have occurred due to electronic transmittal.

Washington State Senate

Senator Julia Patterson

33rd Legislative District

Olympia Office:

405 John A. Cherberg Building

PO Box 40482

Olympia, WA 98504-0482

(360) 786-7664

Toll-Free Hotline: 1-800-562-6000

TTY: 1-800-635-9993

e-mail: patterso_ju@leg.wa.gov

November 19,1998

The Honorable Sid Morrison, Secretary

Washington State Department of Transportation

Post Office Box 47300

Olympia, WA 98504

Re: Lack of Enforcement of Requirements to Use State Facilities

Dear Secretary Morrison,

As part of the construction activities associated with the proposed third runway at Sea-Tac Airport, the Washington State Department of Transportation placed certain requirements on the Port of Seattle for the Port's use of state facilities to haul 17 million cubic yards of dirt to the fill site (see enclosure). These requirements are not currently being enforced.

I have inquired about the situation with the project engineers, and was disappointed and troubled to learn that these requirements are apparently not being enforced because WSDOT believes the major fill work has not yet begun. Massive hauling of dirt has begun, and I am writing to ask for your assurance that swift action will be taken to enforce these requirements now and in the future. Quite frankly, I am extremely disappointed that WSDOT appears to be ignoring the requirements that were placed on the Port of Seattle.

All year, I have personally sat in backed-up local traffic, while local city workers allow the steady uninterrupted flow of dirt-hauling trucks. These trucks converged on our community this year, and I have been flooded with constituent complaints resulting from the massive dirt hauling project that has been going full-force. I have also enclosed a copy of the most recent Sea-Tac Airport newsletter, which boasts: "We've now reached the end of the construction year with more than 1.1 million cubic yards of fill material delivered." For WSDOT to indicate that "little has happened" to enforce the agreements because the "major fill work" hasn't begun (See enclosed 10/28/98 letter) is absolutely outrageous.

Of the five requirements WSDOT placed on the Port of Seattle, the Department has done nothing on three of them, is "presuming" the Port has taken care of the fourth, and is working on but not completed the fifth (see enclosed 10/28/98 letter). This shameful performance gives me the impression that the Department is not taking this issue seriously.

I urge you to take steps to rectify this situation, and look forward to assurances that actions have been taken to begin enforcing the clear and reasonable requirements placed on the Port of Seattle nearly one year ago.

Sincerely,

Senator Julia Patterson

Senate Transportation Committee

cc: Don Griffith, WSDOT Legislative & Strategic Management Relations Director

Enclosures:

(1) Letter dated 1/21/97 from Robert A. Josephson (WSDOT) to Michael

Cheyne (Port of Seattle) outlining requirements to use state facilities.

(2) Letter dated 10/5/98 from Senator Patterson to Mr. Josephson & Jerry Shultz inquiring as to whether the Port is meeting the requirements set

forth in previous letter.

(3) Initial response dated 10/12/98 to Senator Patterson from Mr. Josephson.(4) Follow up letter dated 10/20/98 from Senator Patterson to Mr. Josephson.

(5) Second response dated 10/28/98 from Mr. Josephson to Senator Patterson

(6) Copy of portion of October/November 1998 Sea-Tac International Airport Forum, a Port of Seattle publication.

September 9, 1998

City of Normandy Park

801 SW 174th Street

Normandy Park, WA 98166-3661

Attention: Mr. Merlin MacReynold, City Manager

Dear Mr MacReynold,

Thank you for the opportunity to present the quarterly report of the Regional Commission on Airport Affairs to members of the Normandy Park City Council at their regular meeting this Tuesday. The purpose of this letter is to follow-up on several comments made by council members at the regular council meeting on September 8 concerning the issue of haul trucks on local roads and the impacts of this operation on residents of Normandy Park and other local cities.

Over the course of the last several months the RCAA has received numerous reports concerning the effects that the operation of dirt trucks transporting fill material to port of Seattle property at Sea-Tac airport. The following reports evidence the increasing number of complaints associated with the Port’s dirt hauling activities:

On June 15. KIRO Channel 7 news reporter Karen OíLeary covered a breaking story concerning a head-on collision between a double trailer haul truck and a pickup truck. The evening news showed a double trailer haul truck off on the side of the road and the remains of a truck in the middle of the intersection. The accident occurred along S.154th Street near 24th Avenue South and killed the driver of the pickup truck.

On Jun 23 we learned of a 9 or 10 car pileup involving a double trailer haul truck traveling Eastbound on SR 518 involving up to nine vehicles. The double haul trailer was reportedly jack-knifed along SR 518 east of South center and caused multiple collisions between other passenger vehicles.

Another accident was reported in the Highline Times recently where a haul truck tipped over at the turnoff onto Port property on Starling road just off S.188th Street.

We have received reports of traffic accident incidents involving broken windshields attributed to the Port's haul contractor's trucks.

We also recently received a report from a resident on August 30 reporting haul trucks were running the red light at the traffic signal located at the intersection of SR18 and SR509. (See enclosed e-mail message.)

Mr. Merlin MacReynold

City of Normandy Park

September 9, 1998

Page 2

We continue to receive increasing numbers of reports from individuals complaining of being tailgated and harassed by drivers of the large double trailer haul trucks. Many examples have been reported in letters to the editor published in the Highline Times noting incidents of harassment. (See recent letter to the Highline Times Editor from Jerry Guite, for example)

The above reports indicate the problems caused by the Port’s haul operation are already seriously threatening public safety and need to be curbed. We are concerned that this problem will continue to be exacerbated in subsequent years during the Port's proposed five year fill dirt hauling schedule. This year a Port contractor plans to haul 830,000 cubic yard of material to the airport site. During 1999 the Port has stated it anticipates hauling up to 3 million cubic yards of material to the airport site. We believe the problems associated with this quadrupled amount of haul activity will have much more than a quadrupling of impacts on public safety, traffic congestion, impacts on roads, dirt, dust, etc.

Over one and a half years ago, long before the recent complaints, Washington State's Department of Transportation (WSDOT) expressed serious concerns regarding to the Port’s proposed dirt haul activities. Enclosed is a copy of the WSDOT’s January 21, 1997 letter to the Port of Seattle. In its letter the Department included a number of observations and recommendations requesting that the Port:

‘

“Provide for some method of reducing or stopping haul during congested periods on the highways, especially the I-5/SR405 interchange area.”

“Our experience in large hauling projects on state highways indicates that costs from pavement cleaning, rock damage, water pollution and other incidentals is large over the life of a project of this size.”

“The impacts to the public for a truck haul from east of I-5 will be very significant unless handled carefully with considerable mitigation.”

“In addition the public relations should be considered in the final decision on transportation modes to use in this project.”

To the best of my knowledge to date the Port has failed to carry out any of DOT’s recommendations. The Port has not implemented steps that will suspend it haul operations during the congested periods on state freeways including the I-5/SR 405 interchange area. It has not considered or funded payment for the costs associated with pavement cleaning, rock damage, water pollution and other associated effects. It has not provided any form of mitigation for the impacts of its hauling activities on the state's road system.

Mr. Merlin MacReynold

City of Normandy Park

September 9, 1998

Page 3

Additionally, we have also received recent reports that the Port’s haul contractor has been conducting haul operation outside of the time period designated for hauling activities, especially during the morning hours when school buses are travelling on local streets. The Inter-Local Agreement (ILA) between the Port of Seattle and the city of SeaTac specifically made provisions prohibiting haul activity during these morning hours because of the acknowledged risks these activities pose to children traveling on school buses. In a letter dated July 13, 1998, Mr. Dan Leach, Media Officer, Port of Seattle stated that haul activities were prohibited before 8:30AM between the months of January through June and September through December. According to recent reports this is not occurring and haul trucks have been reported on roads as early as 6:30 AM. Ms. Rose Clark, an RCAA board member, informed me today that she is presenting this concern to members of the Highline School District at the Board's regular meeting this evening. To address the above described problems it has been suggested that the cities of Burien, Des Moines, Federal Way, Tukwila, Normandy Park and other communities review the above described problem and take steps including those described in the attached draft resolution. We believe the adoption of a consistent policy concerning this issue by local cities may be persuasive in encouraging the State Department of Transportation to be concerned and to act to address the serious risk to public safety presented by the Port's proposed dirt hauling activities. The following draft of a suggested resolution reflects several ideas our board members have developed to address this problem. It obviously needs wordsmithing but hopefully conveys the key issues. If you have any questions please call.

Sincerely,

Al Furney

President

Enclosures

Draft Resolution of the

City of [Burien] [Des Moines] [Federal Way] [Tukwila] [Normandy Park]

– Not included in Corps Comments

Appendix E: Deceptive Lone Star Maury Island Mining Operations DEIS

This appendix contains a newspaper article that provides a summary of the proposed Lone Star Maury Island mining project. It also contains one of my letters of correspondence relating to Lone Star DEIS process.

*********** BEGIN FORWARDED MESSAGE ***********

http://www.seattleweekly.com/features/9915/features-scigliano.shtml

The Pits BY ERIC SCIGLIANO

Maury Island has the gravel Sea-Tac's runway needs. It also has

arsenic-laden soil, a vulnerable aquifer, and some very worried islanders.

IF THIS STORY HAD APPEARED two weeks ago, you might have thought it an April Fool's hoax. Consider: A Japanese-owned sand-and-gravel company plans (in stages) to strip-mine 235 acres on Maury Island, Vashon's scenic Siamese sister. It will dig up to 7.5 million tons of gravel and sand a year, perhaps 85 million tons in total. It will haul this booty off in10,000-ton barges, hauling up to four of them a day over vulnerable, biologically precious eelgrass beds. It will supply up to 20 million tons of gravel to

fill the third runway being built, over hills and dales and wetlands, at

Sea-Tac Airport. The miners will dig over the aquifer that supplies all

Maury Island's water, as close as 15 feet to it, and perhaps alter the

hydrology of its recharge and filtration. To get at the gravel, they'll

scrape off the topsoil, perhaps 50 acres at a time, then restore it as

they go along. This will mean uprooting (in stages) much of what's reportedly

the region's largest, healthiest grove of madrona trees, prime heron and

raptor habitat. Thanks to decades of dusting by a now-defunct copper smelter,

this topsoil is laced with toxic arsenic. And though the gravel site is

uninhabited, desirable homes cluster along its edges.

You've gotta be kidding? Guess again. Not only is this massive exercise in

pebble moving seriously proposed, it may come to pass. Gravel is big

business, and a concomitant of growth; not only airports but highways,

homes, and stadiums are built upon gravel and concrete made with it. Gold

mining and oil drilling in the wild may present more sensational impacts.

But gravel is dug from our backyards, and is drawing mounting opposition

from ex-urbanites moving into places like North Bend, Granite Falls, and

Duvall--other picturesque communities where pits and quarries are proposed and contested.

But unlike many pit-shocked communities, Maury Island is no stranger to

gravel. This site has been mined since the 1940s; its current owner, Lone

Star Northwest, acquired it about 20 years ago and last mined it heavily

In 1978. Lone Star has since only dug 10,000 or so tons a year, for on-island use. The old pits have sprouted over (even some madronas have come back) and become favorite spots for beer blasts, target practice, four-wheeling, dumping old cars, hiking, and view gazing. "We always knew this site would be needed someday," says Ron Summers, Lone Star's general manager. And so the company banked the land, and its

1970s-vintage permit for mining most of it. Summers even insists the rusted conveyor frames that climb the slope are still usable, though they look ready to collapse: "We put all the main equipment in storage." And he says "someday" has arrived: The company's other sites--in particular, its big Steilacoom mine--are getting depleted. Demand is rising, after several

years with few major projects hereabouts. And the retreating glaciers just happen to have blessed Maury Island with an abundance of high-quality gravel: "It's a rare site," says Summers. "Looked at [from the view of the] regional environment, it's also a very clean site." And, he adds, "you always run into neighbor concerns," wherever you dig gravel.

PERHAPS, BUT THOSE CONCERNS seem especially acute here, thanks partly to the site's character and partly to its changing environs: Since the mining slowed, the communities of Gold Beach and Sandy Shores have grown--exploded, by Vashon standards--alongside. And though it's near neighbors who are, in usual fashion, spearheading the opposition, they've mustered wide support on both islands. They've also gotten several thousand dollars from the islands' county-supported Community Council. This has gone to pay for environmental consultants, who've already punctured some of Lone Star's data.

Lone Star first declared it would dig under its old permit. Then, last

summer, the county ordered a new environmental review; islanders, acting

under the moniker "Deep Impacts," have since raised many more issues,

especially with regard to that perennial Vashon anxiety, water.

The ground Lone Star would tear up is a sponge and filter for the aquifer

all the island wells draw from: How will that affect water quality and

quantity? Then there's all that arsenic (plus cadmium and lead) spewed by

the old Asarco smelter near Tacoma. Arsenic fallout ordinarily bonds to

the top few inches of soil, rather than leaching down. But will tossing and

turning that soil release it into the water column? "First, they'll change

the hydrology," says Sharon Nelson, Deep Impacts' chair. "We won't have

the filtration anymore. [Then they'll] break the arsenic's bond with the soil

and put it back over our water system." And even though no health damage

has been proven from Maury's and south Vashon's long arsenic dusting, and

state rules dictate how such contaminated soils must be handled to prevent new dusting, islanders fear that they'll get stirred up again. They claim that those heavy barges will scrape up inshore eelgrass beds that are vital (and increasingly scarce) nurseries for herring, young chinook salmon, and other fish. They warn that heavy digging could cause more landslides (another perennial terror on Vashon) like those on the property's south edge.

Lone Star manager Summers argues that mining may reduce slide danger, by removing dirt behind the shore bluff. But on most site and environmental questions he defers to the draft Environmental Impact Study due in May. "I trust the [county's] consultant, that they're going to come up with the data."

TRUST IS A STICKing POINT for the islanders. They've made hay of Lone Star's pollution record: In 1988, a US magistrate fined it for dumping cement residues into Lake Union and the Duwamish River. That was then, says Summers: "We learned from those cases, how to do our job better and be More attentive to impacts like that." Yes, but just last month an Oregon grand jury found that Lone Star had again dumped cement into a waterway, in Oregon City in 1997. "That was done without approval," says Summers, by persons unconnected to the Maury project. "When we found out we turned ourselves in. Disciplinary action was taken." Indeed, the Oregonian reports that Lone Star fired or suspended five employees involved in the incident and offered to pay fines and restitution rather than go to court. The islanders also decry the fact that Jones & Stokes, the consultant King County hired for the EIS, hired Lone Star's consultant to perform geologic and hydrological studies. County project manager Gordon Thomson says such a move is "neither usual nor unusual," and not a conflict of interest: It's just "the most effective way to get the data. The geotech people say for data collection, the technology is the same whoever does it." Nevertheless, the islanders have asked permission to double-check--to take their own groundwater samples in tandem with Lone Star's consultant. Lone Star refuses because, Summers avows, double-checking is "unnecessary": "We feel there's plenty of information already. The data's the data." Not if you judge by the dueling arsenic readings the two parties turned up. In that case, the Community Council's and Lone Star's consultants shared and tested the same samples. In eight out of 10 samples, the islanders' lab found more arsenic (sometimes much more) than the company's did. A third expert determined that the Vashonites' tester used the proper technique, screening the samples first; Lone Star's didn't. Steve Hall, Jones & Stokes' project manager for the Maury EIS, disputes "the analogy that if they hadn't done parallel testing, the data would be wrong. We would have discovered the error anyway. And the conclusion would have been the same [regardless]: The soils have elevated levels of arsenic and will have to be managed under the Model Toxic Control Act." Hall says he "doesn't care if they test the groundwater, too," but again thinks double-checking isn't necessary. Maybe not--unless the gravel miners and regulators who live off the island care to calm the worries of those who live on it. Meanwhile, the residents will ratchet up their opposition with a colorful "Hands Across Maury" event on April 25, near the site.

14 September (page breaks different in this electronic copy than the original)

Attn: Current Planning Section

King County Land Use Services Division

900 Oakesdale Ave. S.W.

Renton, WA 98055-1219

Subject: Comments on File Number E98E0503, Draft Environmental Impact Statement for Lone Star Maury Island Mining Operation

Discussion

A much larger buffer zone between the maximum mining depth and the Maury Island area aquifer are needed to reduce drinking water risk. The high arsenic content top layer should be barged off the island and sent to a hazardous materials landfill.

The proposed increase in mining rate of Maury Island is so huge that no “grandfather clauses” should be allowed to circumvent environmental regulations. The pre-Shoreline Act mining rate of 1.3 million cubic yards is about a fifth of the proposed rate. Actual repair estimates of the equipment and pier should be obtained to determine the true scope and magnitude of the needed maintenance.

The Lone Star Draft EIS is misleading regarding barge rates. The proposed barging rate can be underestimated easily by the reader. Although the underlying market force for this EIS is the need for four barges a day, every day for three years to support the Third Runway, this information is not readily apparent. Spreading the mining duration across 35 years tends to disguise the huge amount to be accomplished in the first few years. The 1998 Hank Hopkins conveyor permit requests submitted to the City of Des Moines and Corps of Engineers more clearly identified the tremendous barge rates. Neither the Hopkins permit or the Lone Star EIS address that the remaining portion of the Master Plan Update which may take a few more years of continuous barging. The Master Plan Update total quantity of 26.4 million cubic yards used a nontraditional swell/compaction figure in its calculations so the real quantity is higher than 26.4 million cubic yards. It also excluded from the calculations the on site soil that must be excavated and replaced to comply with the FAA Record of Decision.

An EIS is needed that addresses the Maury Island mining, barging, transporting (conveyor and/or trucks) and placing of fill at the Sea-Tac Airport site. Neither the Lone Star or the Master Plan Update EIS process has addressed this. Both assumed the other one would evaluate it. The Lone Star DEIS paragraph 8.2.2 is INCORRECT on this subject and needs to be revised extensively. The proposed barging level equates to an annual fill placement rate that is at least four times higher than that assumed in the Master Plan Update EIS and that was used in the airport’s Air Conformity Analysis. Since the proposed mining, transporting and construction activities all occur within King County for the SAME project, a complete cumulative pollution analysis is needed for both air and water including an air conformity analysis. If done accurately, it will definitely trigger the Clean Air Act de-minimus limits (increases pollution by more than 100 tons when combine airport and construction activity). Fuel and oil pollution from tugs and barges need to be considered in addition to construction equipment.

If the barges are unloaded at the Duwamish, then the analysis may also show that King County will go out of attainment for particulates. This concern is based on reviewing the historical data available in DOE Publication Number 98-212, “1997 Air Quality Data Summary”.

If unloaded at Des Moines, Shoreline Act and Clean Water act violations are a major concern. Building a pier that disturbs eel grass and running a conveyor along a salmon bearing creek that floods regularly both present permit challenges.

The draft EIS appeared to be a rubber stamp for the Lone Star and, consequently, the intimately related Third Runway, rather than a thorough assessment of the environmental threats. The expansion of Sea-Tac Airport is inconsistent with how other airports in heavily populated areas handle capacity increases. Since the third runway is not configured as originally planned and cost estimates have skyrocketed to over three times the original cost (and will continue to climb until a reputable engineer is allowed to disclose the real costs), the runway has lost the support of most airlines (1998 Passenger User Fee Application). Ultimately, it will cost over 100 times more than a typical runway even prior to inflation adjustments. It is negligent to risk the area’s drinking water, Puget Sound, and our coastline for a dependent part time runway that is too short for big jets and INCREASES the risk of accidents by more than 20 % (Master Plan FEIS).

Questions

Why isn’t this EIS deferred until the Maury Island aquifer study is complete in June 2000?

Why hasn’t the geological/hydrological interactions of moving 10 % of Maury Island and placing them it at Sea-Tac airport over a short period of time been evaluated?

The Geology department of University of Washington should be requested to assess impacts based on their recent test conducted in the Sound. The earthquake fault that runs east-west through Lake Washington at ground surface level may angle downwards so it is underneath the airport. The impact of moving 80 billion pounds of fill from Maury Island to Sea-Tac airport needs to be further evaluated. The added weight of 10 to 20 feet of concrete at the airport site increases the loads further, well beyond 80 BILLION pounds. Since both sites have aquifers close to the top and share the same unconfined aquifer down deeper interactions are possible.

If the Maury Island aquifer becomes contaminated, how long will it take to contaminate the unconfined regional aquifer? When answering this question, please remember that we have both lenses and possible fractures in till from earthquakes that speed up the transport of contaminants.

What earthquake design criteria would be used for the arsenic stockpile?

Would the earthquake criteria for the arsenic containment take into account the frequency that the airport/Maury Island area has been the epicenter of earthquakes including a 6.5 in the 1960’s as well as the hypothesis that the east -west fault line angles under the Sea-Tac airport?

What will the pollution impacts be to Puget Sound and the aquifer if an earthquake disturbs the proposed arsenic stockpile?

Why isn’t there a requirement that if any high arsenic soil is disturbed, that it be barged off the island and delivered to a landfill capable of handling hazardous material?

Why wasn’t the abysmal environmental record of the company officers and the corporation considered and mitigation recommended such as bonds/insurance etc.?

Why are there no provisions for an outside organization such as the Coast Guard to regularly check barge walls/bottoms for contamination considering the corporation’s abysmal environmental compliance record and hazardous things they have barged in the past?

If you put fill into a contaminated barge and then dump the fill onto an aquifer, how contaminated does the aquifer become?

What is the impact to the Sound if a barge tips over? Didn’t this happen during a Lake Union construction effort?

How much will the required additional Coast Guard staff cost to monitor the large increase in Sound traffic? Why was there no mention of the increased staffing that would be needed?

Why were no meaningful assessments made of impacts of the INEVITABLE barge accidents? They are inevitable considering (a) the high frequency for multiple years crossing three ferry routes as well as other Sound traffic and (b) 1998 conveyor permit requests indicated the intent was to barge EVERY day of the year regardless of weather.

Do you really believe the assumption that it is possible to unload barges round the clock, every day for years in all types of weather is safe (barge rate in conveyor permit requests)? How many accidents per year should we assume if they barge in all weather?

Why aren’t there mitigation clauses that would force the mining corporation to provide water in perpetuity to Vashon and Maury Island residents should the mining contaminate their sole source aquifer?

Why hasn’t the mining, barging, conveyor and/or truck transport and placement of fill been evaluated in an EIS for the Sea-Tac Airport Master Plan Project?

Why wasn’t there a cumulative pollution analysis performed?

What will the particulate count be on Vashon after two or three years of mining at an annual volume of 7.5 million tons? What will the particulate count be at the unloading site? At the using site? Will residents with asthma have to sell their homes and move?

What is the increase in probability of silicosis at the mining site? At the airport site?

What will the increased water usage be to clean windows so people can see when they drive? Judging by the fill operations to date at the Sea-Tac airport, it’s reasonable to assume people will need to wash their car windows at least once a day.

Will the fill be watered to attempt to control particulates? If so, how much water will be used annually?

What will be the impact of the numerous displaced small animals on Maury Island? Judging by the number of dead animals on the streets by the airport when they were filling in the runway safety area and the North Parking Lot, it will be a huge number. Will the feces from the dead animals contaminate the water?

What is the swell/compaction values for Maury Island fill when transported via a barge followed by a truck?

What is the swell/compaction values for Maury Island fill when transported via a barge followed by a conveyor similar to the one proposed by Hank Hopkins of Material Transport?

Where will they unload the fill? Will wetlands be impacted by conveyor belts or new piers? How many trucks per day will be needed to carry away the fill from four barges? Will they close down Highway 509 for over five years to transport fill by truck from the Duwamish to Sea-Tac Airport? How much and what type of pollution will there be? As the chart on the next page indicates the quantities are so abnormally high, it is irresponsible to assume the transport and unloading pollution are unrelated to the mining operation.

The DEIS will allow Maury Island to operate at about 550 times the normal mining rate of 10,000 cubic yards a year. It will require barging at about 5 times their previous all time record for a period of about 5 years assuming they haul 24 hours a day year round to support the Sea-Tac Airport Master Plan Update project.

/1/ Max volume prior to Shoreline Act

/2/ Max volume after the Shoreline Act (1978 Terminal/Pier 37)

To reiterate, paragraph 8.2.2 needs to be revised extensively. No EIS has evaluated the impacts from four barges a day, every day for years, delivering fill to Sea-Tac Airport via conveyor or truck. A cumulative pollution analysis is REQUIRED.

Since (1) all the critical reference material was not available to the public when the DEIS was released for comment (see Sharon Nelson correspondence), (2) the draft EIS is misleading with regard to the length of time the environment would be subjected to four barges a day, and (3) lacks a credible cumulative impact analysis, I recommend you reissue another draft EIS. Please see my prior comments listed in the references if you need additional grounds for a cumulative pollution analysis.

Thank you for sending a copy of the DEIS to the Burien Library. Unfortunately they were a few weeks late in placing it behind their reference desk.

Yours truly,

A. Brown

239 SW 189 Pl

Seattle, WA 98166

Home (206)431-8693 Cell (206)659-9161

Enclosure: References and Bibliography

file: MauryDEISv2.doc

References (partial)

Hillis, Clark, Martin & Peterson," Re:Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Mark Mitchell, dated 24 February 1998

Hillis, Clark, Martin & Peterson," Lone Star Northwest's Sand and Gravel Quarry, Maury Island", To Fred White, dated 19 February 1998.

Sea-Tac Airport Master Plan Update Draft Environmental Impact Statement (DEIS), 1995

Sea-Tac Airport Master Plan Update Final Environmental Impact Statement (FEIS), 1996

Sea-Tac Airport Master Plan Update Supplement Environmental Impact Statement (SEIS)

Supplement to the State Implementation Plan for Washington State, Plan for Attaining and Maintaining National Ambient Air Quality Standards for Ozone in Central Puget Sound, January 1993, Amendments June 1994

Bibliography (partial)

" Dust Emissions at North SeaTac Park", Puget Sound Air Pollution Control Agency Notice of Violation No. 35809, Registration No. P371603874-75, Regulation I, Section 9.15 (a) : Emission of Fugitive Dust without use of best available control technology, 8 August 1996

Fred M. White, Gordon Thomson, King County Department of Developmental & Environmental Services, Re: Comments and Request for Public Comment Period Extension for Lone Star Northwest request for permit revision, Maury Island, from A. Brown, 17 June 1998

Leisch, Brice A. , Price, Charles E. and Walters, Kenneth, L, Geology and Ground-Water Resources of Northwestern King County, Washington, Washington State Division of Water Resources Water Study Bulletin No. 20, 1963

Luzier J.E., Geology and Ground-Water Resources of Southwestern King County, Washington, State Dept. of Water Resources Water Supply Bulletin No. 28, 1969

Richardson, Donald, Bingham J.W. and Maddison R. J., Water Resources of King County, Washington, U.S. Geological Survey Water-Supply Paper, 1852

Woodard, D. G. Packard, F. A., Dion, N.P. and Sumioka, S.S. , Occurance and Quality of Ground Water in Southwestern King County, Washington, U. S. Geological Survey, Water- Resources Investigation Report 92-4098, 1995

AGI Project 16,116.001, Draft Groundwater Quality Impact Evaluation Proposed North Employee Parking Lot Seattle Tacoma International Airport, SeaTac Washington, AGI Technologies, 11 April 1997

AGI Project 16,116.001, Groundwater Quality Impact Evaluation Proposed North Employee Parking Lot Seattle Tacoma International Airport, SeaTac Washington, AGI Technologies, 13 June 1997

Appendix F: Earth

Embankments, Seismic Anomalies and Wetlands Don’t Mix

Slopes too Steep

10 to 1 slopes are recommended for preserving wetlands by King County (Ref. 113), yet just changing to 3 to 1 ratio would have a large impact. Other national level studies corroborate the King County study findings.

The translator for Slopes to footprint Size (width at bottom):

55 degrees from FEIS is exactly the same thing as saying 0.7 to 1 ratio

26 degrees is saying the exact same thing as 2 to 1 recommended in FEIS ( IV19-9) for the area that now has a MSE wall proposed

18 degrees is saying the exact same thing 3 to 1 which is the number the Corps of Engineers said was standard at our meeting. Actually I believe the official civil engineering text book value is 2.8 but 3 works for talking purposes.

Angles of Slope for Retaining Wall/Berm

Wall height 55 degrees 26 degrees 18 degrees

30 feet 21 feet 60 90

100 70 feet 200 300

165 116 feet 330 495

225 158 feet 450 675

Using the table above you can calculate how far out the fill should go for a given height. As you can see, it could be a show stopper. This means if you are at a location with a wall height of 100 feet and it extends out 70 feet using 55 degrees and the Corps or DOE decide 18 degrees would be safer , then the footprint would become 300 feet instead (230 feet more).

A map with the embankment wall drawn on it that identifies the soft soil areas referenced in the Record of Decision follows:

Appendix G: Water

More complete description of the Groundwater Study and Risks

The FAA Record of Decision requires a ground water study to be conducted. This was in part precipitated by Seattle’s Water Department’s SEIS comments that the water be indemnified due to contamination risks.

Later some of these concerns were partially alleviated by bringing in Port “high powered” consultants that painted a picture of a thick layer of intact till to Seattle Water Dept. No mention of till fracture or lenses was discussed. Their staff was intimidated. I believe a check of that data will reveal that the conductivity of the material they referred to as till did not match the textbook definition. It actually transmits contamination faster. This is one of the reasons the Highline Aquifer Study is so essential.

A Public Hearing was held 21 May 1997 (ref. 34) to comment on the proposed Groundwater Study. The DOE was completely and totally unaware of any of the deicer hazard work that had been done by the Maryland Department of Resources or that Canada had decided to regulate it at airports. One DOE representative sat in his chair with it tilted up against the wall with his eyes closed during the hearing. One other DOE representative stood at the back laughing and talking to what I believe was another regulatory agency person during my testimony.

The public submitted comments June 1997 (ref. 35). A smaller side meeting was also held by the DOE for CASE in July 1997 again at the Burien library. I submitted additional photos of an outfall spewing black semi-fluid material. ( more information on that was submitted during the last permit application process so it is not repeated here). We were led to believe the DOE Response to Comments would still be released August of 1997.

Later that fall, a CASE speaker, on behalf of the DOE, passed on a request to avoid asking DOE questions otherwise the DOE would not get the Response to Comments completed. During the spring 1998 water certification permit application process, the public commented that we still had not received the DOE’s response to public comments and that they could not issue the permit without that Groundwater Study. Instead of issuing the Response to Comments to the Groundwater Study, the DOE instead signed Memorandum of Agreement with the Port to conduct the Study and issued the 1998 Water Certification (certification was subsequently withdrawn due to unrelated issues such as the water rights dispute). The DOE informed us we would receive the DOE’s response to comments on the Groundwater study until AFTER the study is completed. In other words, the Response to Comments, at the very earliest will be THREE YEARS LATE !

The Study was absurdly small in scope and did not even investigate the known areas of contamination. For the DOE to change its mind and not issue a “Response to Comments” until it is completed is outrageous. It’s our drinking water at stake, not just some salmon.

People often share interesting tidbits of what is going on at the airport. It illustrates why we need a full time on site environmental enforcer assigned with a solid technical understanding of aquifers. There are so many opportunities for things to go wrong. This is just one example.

Subject: Port's pumping from under the fill on 12^th date: Fri, 27 Nov 1998

Hi!  Around noon today my  husband came in to say that

they were pumping up on 12th and 160th S.  We went up

there with a still camera.  They a re pumping a lot of

water from under the fill.  It is flowing out of the

fence by a fencepost.  We got a picture so it could be

seen how high the water from the hose is in relation to

the post.  We also took pictures of the drainage ditch

along the east side of 12th.  At 160th they have

sandbagged to divert the water to the east to flow under

12th along the north side of 160th.  At 9th and 160th on

the north side you can see the pipe where the water is

falling a foot or two into Miller Creek.  We tried to get still pictures of all of this.

We went to the south on 9th to try to get some pictures

of miller going through that small wetlands there.  They

have been surveying in there and have drilled a couple

of test holes to see the level of water.  The water is

to the top of  these holes.

I checked the flow on Des Moines  by the SR509

overpass.  It is high and running fast so we took more

pictures.  I am puzzled that on Ambaum and about 162nd

it does not seem to be flowing fast.  It is also not

flowing fast by 165th and Ambaum.  Neither is the beaver

pond on Des Moines Memorial Drive.  The water level is

high in those wetlands, but I am not sure it is because

of the pumping up on 12th.

We drove to the Cove where we found the water to be very high.  It is over the breakers or whatever you call it that protects the footbridge going to the beach.  But I don't know if this is important to the pumping.

Someone with a video camera should tape alont 12th and on 160th and 9th on the north side.  If you try you should be able to get the water from the pipe going into Miller Creek.

All of this wandering around reminded me that King Conservation District did a project along Des Moines Memorial Drive  and SR509 a couple of years ago. They added some rock so that spawning salmon could make it upstream easier.  I'll talk to them and see if they will provide some sort of testimony about this at the hearings.

Written by a resident and sent out as personal email so name excluded. The short review period does not provide me adequate item to contact him for permission to publish.

Appendix H: Best Management Practices Don’t Work per Port Letter

The EISs were a broken record. Their answer to everything was “Best Management Practices”. This record setting project needs engineering development for it to even have a remote chance of working. They couldn’t even build a parking lot, much less a huge embankment. Enclosed is a letter by the Port of Seattle describing the problems with the parking lot and explaining the inadequacies of BMPs.

Compare this letter with FEIS statement on page IV 10-17, which is similar to other BMP references throughout the EISs:

” use of BMPs at construction sites, such as spill containment areas, phasing of construction activities(to minimize the amount of disturbed and exposed areas), and conducting activities during the dry season (April through September), also should prevent or reduce potential impacts on surface water and ground water quality”.

Letter, From Port of Seattle, Barbara Hinkle, To Arlene Brown, no title (Port’s Response to A. Brown’s comments on Auburn Wetlands mitigation), dated 9 September 1998 (BMPs inadequate”) follows

Appendix I: Noise Models Significantly Underestimate Noise

Comments submitted to Part 150 Study 20 May 1999

Noise contours are misleading and cause people to buy homes that they would NOT buy if they knew what they were getting themselves into.

No matter how hard you tried, you could not here aircraft in my neighborhood in the 1992- 1993 time frame (exception being Sea Fair week flight diversions). Now it is not possible to get 8 hours sleep and keeping lightweight decorations on shelves is a challenge.

The A- weighed measurement technique is insufficient for the current fleet. It does not adequately reflect low frequency noise. In addition to the A-weighted methodology, C-weighted methodology should also be used. Vibrations are a health and geological hazard.

Single events also need to be addressed and those between 10 p.m. and 6 a.m. given a higher weighting. Averaging twelve hours of zero noise with twelve hours of loud noise gives the false impression that a home is reasonably quiet. Studies show that any noise that is 10 dB above ambient is a problem. It is grounds for a nuisance suit in some states if your neighbor increases noise by 10 dB.

Noise from all aircraft, regardless of what airport they use, should be considered. I’ll never forget being startled awake around 2 a.m. by the roaring engines of a low flying Alaska cargo aircraft out of Boeing Field.

Flight paths need to be selected and required for use for ALL aircraft. For example, Harbor Air C208 propeller aircraft flying at 800 feet MSL at on 25 April 1999 at 10:24 PM VISIBLY rattled my light fixture at least plus or minus 1/8 inch. This is allowed, according to Port of Seattle letter dated 18 May 1999, because altitude is not regulated during departures or arrivals. I live not only west of the noise boundary but also OUTSIDE of the general study area for the Third Runway. The Master Plan Update EIS does not even address my area!! Note other Harbor Island C208 flights such as 5/13/99 at 5:45 AM, although loud enough to wake someone, at least didn’t terrify me that my light fixture was going to fall on my head.

Side noise needs to be better regulated and monitored. Departing MD 80’s routinely waken me due to their loud side noise. MD11’s are also too loud such as WOA on April 9, 1999 at 4:19:30 am

Hush kits should be banned. They just move noise, change the frequency of noise and increase pollution.

Higher penalties are needed for noncompliant aircraft including those lost. The number of lost aircraft seems to be increasing. In addition to the publicized lost aircraft such as the two recent Russian incidents, more respected airlines also mistake Boeing Field for Sea-Tac and need to make last minute corrections.

Noise insulation is inadequate. Saint Philomena Church in Des Moines was recently insulated at a tremendous cost to the Parish due to other upgrades that were needed

because of the insulation project. The Port money didn’t even come close to covering total costs. You still need a microphone to be heard over the aircraft noise. The adjacent school does not have microphones. Nor do nearby Pacific or Rainier have microphones.

Schools need to be moved. It is too dangerous to have parts falling on school grounds while children are outside such as at Rainer High School. Or, almost crashing into them like the aircraft that crash landed near International Boulevard. The noise level at Pacific Middle School is not conducive to learning.

Noise contours need to consider REALISTIC number of operations. The Port has ALWAYS underestimated the number of operations so as to avoid having to mitigate the impacts that would come with the Terminal Air Forecast. Historically Sea-Tac meets or exceeds Terminal Air Forecast growth (ref. SEIS). Contours for two runways should recognize today’s technologies and what that means to capacity ( 600, 000 operations?). Ditto for the Third Runway configuration (800,000 operations?). Sea-Tac has already proven the SEIS NPIAS limits aren’t real and that delays are much smaller than predicted so MORE aircraft can use Sea-Tac. The current noise boundary is set on about 266,000 operations which is far less than today’s actual number of operations.

Noise contours need to consider worst case fleet mix.

Noise calculations need to consider reflections. Now that the trees have been cut down at the airport for the proposed Third Runway and the industrial area south of the airport, the noise and vibration has greatly increased. More measurements are needed in Normandy Park and Burien (Gregory Heights) now that the noise buffer forests have been removed and replaced with reflecting surfaces.

New runway safety area impacts need to be modeled. When the aircraft face in an easterly direction on the south end of the airport on the new runway safety area with engines running the noise in Normandy Park is greatly increased. You can literally taste fuel while swimming in Normandy Park Community Club right beside Marvista School. If the proposed Third runway is also considered, you need to consider the safety areas that were NOT shown on any maps in the EIS.

Buy-out area needs to expanded to all homes qualifying for noise insulation based on more stringent guidelines ( single event to be defined or A-weighted 60 db level or C-weighted specific level).

Noise insulation eligibility needs to be broadened. All homes subject to 55 dB or over between the hours of 10 pm and 6 am should be eligible for noise insulation as determined by actual testing over a three month period or based on the contours, whichever is noisier. School eligibility should be calculated based on noise during school hours. Chicago’s 55dB limit should be used.

Home noise monitoring program should be readily available. A program should be started whereby a homeowner can easily borrow a noise monitor for a three month period for free. Enough monitors should be available so the waiting list is two years at the most for testing.

Noise from certain aircraft needs to be modeled, not just engines. Some newer aircraft can make even more noise from air moving over the aircraft than the engines

Landslide hazard rerouting. During a heavy rainstorm within the last few years, I was told that aircraft were routed away from Magnolia due to landslide problems. Landslides are becoming more of an issue now on the west side of the airport. It cost over 1 million dollars to repair 1^st Ave when one lane slid down towards Miller Creek after the first 350,000 cubic yards of fill were dumped at the south end of the airport for the runway safety area. The water table appears to be shifting in the Burien and Normandy Park area, presumably due to the dumping of fill on the aquifer. The vibrations from the aircraft are often from the ground up, even outside the General study area of the EIS. The land is less stable and more subject to landslides. Prior to establishing aircraft routes, landslide hazards need to be assessed to determine impacts so realistic routes are used.

Long term health and learning studies are needed to establish realistic limits and mitigation. There are many credible studies, particularly European ones, that indicate noise is a serious threat. Could a higher teacher to student ratio help to offset the disadvantages of noise?

Noise fines should be fed back to the community to help compensate for lost real estate tax revenue due to property devaluation and to help fund long term health impact studies.

Bottom Line: We need something more credible and with meaningful mitigation than exists now. The second runway noise contour errors led to a massive degradation in the Highline School district enrollment and academic performance. The Master Plan Update Environmental Impact Statement (EIS) noise analysis was based on the wrong number of operations, fleet mix and did not consider how much noisier it is without trees and shrubs.

The way information travels on the net it is not safe for the aerospace industry to continue to ignore the environmental impacts and play modeling games to mislead the public. In the long run if we, the aerospace industry, don’t change now, we will lose in the end. Having worked 21 years in the industry so far, I still have a long way to go before I’m eligible for a pension. I need a strong aerospace industry. Don’t kill it by being short sighted and earning us the same reputation as the tobacco industry.

Thank you. I regret time did not permit me to list references for the information herein.

A. Brown

239 SW 189 PL (by 4^th Ave SW)

Normandy Park WA 98166

Messages (206)679-9161

Appendix J: Technology Alternatives

From: Al Furney <rcaa@accessone.com Subject: Re: Another boost for GPS>See the report on Johns Hopkins web site at www.jhuapl.edu/transportation/aviation/gps

The abstract from the report notes that the study was undertaken in response to a request for an impartial study of GPS technology by the FAA, the Air Transport Association (ATA) and the Aircraft Owners and Pilots Association (AOPA). The John Hopkins University Applied Physics Laboratory was selected to conduct the study.

Figure 3-4 in the Johns Hopkins report is titled "Notional Timeline for System Improvements" and identifies that improvements anticipated for GPS technology include Category I,II,and III capability in the year 2002-2006 time frame. Category III landings are landings during poor visibility conditions. Poor visibility ("bad weather") conditions are used by the Port of Seattle in the EIS for the 3rd runway as the justification of purpose and need for the project.

The report discusses Figure 3-4 and states "It is understood that dated may not be accurate, but it was judged that the system capabilities shown in the figure represent realistic combinations of possible future improvements."

At 07:19 AM 2/1/99 -0800, you wrote:

AVIATION DAILY---Current Issue---2/1/1999

Report Concludes GPS Can Provide 'Stand-Alone' Navigation

A Johns Hopkins study issued Friday concludes that the Global Positioning System can, with some improvements and augmentations, "satisfy the performance requirements to be the only navigation system installed in an aircraft and the only service provided by the FAA for operations anywhere in the National Airspace System" (DAILY, Jan. 15).

The Johns Hopkins Applied Physics Laboratory report said a 24-satellite GPS constellation with the Wide Area Augmentation System (WAAS) including four geostationary reference signals can satisfy all U.S. requirements for oceanic navigation through Category 1 precision instrument approaches. This setup, plus the Local Area Augmentation System (LAAS), can satisfy all precision approach requirements through Cat 3 with no improvement needed in GPS satellites already aloft, according to the report, which was commissioned by the Air Transport Association (ATA), Aircraft Owners and Pilots Association (AOPA) and FAA. It said that for Cat 2/3 approaches, airports would need two ground-based LAAS pseudo-satellites and other enhancements.

The report said that a GPS/LAAS configuration "based on a 30-satellite GPS constellation or one with 24 GPS satellites and four geostationary satellites can satisfy all precision approach requirements. Some airports will require ground transmitters that act like additional GPS

satellites" and/or improved GPS antennas and extra receivers to achieve the highest availability levels. "This level of performance will require no GPS satellite improvements." It said the impact of a second civil frequency announced last week by Vice President Gore (DAILY, Jan. 9) "will completely remove the requirements for ionospheric corrections for users equipped to take advantage of this feature, and it will improve the corrections provided by WAAS....Furthermore, the second civil frequency and the proposed higher signal power will mitigate interference concerns."

Risks to GPS from natural, man-made and hostile radio interference were judged manageable. The study found that planned GPS avionics are designed to recognize intentional jamming and said such threats could be managed. "Technologies are emerging that can greatly reduce vulnerability to GPS signal jamming," it said. Sunspot and atmospheric problems were judged to be either non-factors for augmented GPS or extremely limited in effect.

ATA President Carol Hallett said airlines will work to help make two more satellite transponders a "reality." Both ATA and AOPA called for rapid implementation of WAAS and two more geostationary satellites. FAA, citing technical problems, last month delayed the WAAS program by 14 months

(DAILY, Jan. 6). Congress refused to fund WAAS beyond Phase 1. ATA and AOPA also called for "greater civil control in the management of the GPS system." Hallett said, "Agreement on costs, timing and user acceptance will determine the timeline for planning out the critical implementation phase."

FAA Administrator Jane Garvey was more cautious than the user groups, saying the report identified a need for closer cooperation with the Defense Department in investigating more efficient combinations of DOD and DOT systems, "including the possibility of additional GPS satellites." Garvey also said the study found that a combination of procedural and technical measures to mitigate the effects of intentional and unintentional interference, such as sun spots, must be implemented as part of the future augmented GPS system to "ensure acceptable performance."

Garvey cautioned that a "significant amount of cooperative effort with the aviation community, including the DOD, and additional investments will be required to make the needed changes." She said the revised schedule for Phase 1 will provide additional time to make the recommended improvements for the later stages of GPS/WAAS.

Written by Aerospace manager and sent out as personal email so name excluded. The short review period does not provide me adequate item to contact him for permission to publish.

Appendix K: Air Safety

Subject: NASA, Honeywell test system to aid airports with close parallel runways

Published Sunday, November 7, 1999

NASA, Honeywell test system to aid airports with close parallel runways

Kay Miller / Star Tribune

If you were walking around Lake Harriet on Saturday afternoon and

happened to look up to see a Gulfstream jet headed straight toward a Boeing

757, your eyes weren't playing tricks on you.

The planes were on a collision course. But suddenly, the 757 banked

hard, rolling to the left.

Disaster averted.

Not to worry. This was a test -- only a test. Engineers at NASA and

Honeywell developed a nifty system that allows more planes to land in nasty

weather at airports that have closely spaced parallel runways -- such as

Minneapolis-St. Paul International.

And they just couldn't wait to try it out.

With existing technology, planes must be spaced 4,300 feet apart when

landing in overcast conditions. That means big airports with parallel runways

often have to shut down one runway -- causing lengthy delays and, sometimes,

diverting planes to other airports. That can mean headaches for passengers,

to say nothing of lost revenue for airlines.

But this system permits aircraft to remain much closer -- 2,500 feet --

as they land.

NASA calls it Airborne Information for Lateral Spacing (AILS), and

Honeywell has dubbed it Closely Spaced Parallel Approaches (CASPER). When

engineers from the two organizations get together, they call it AILS/CASPER.

It will be two or three years before the system might be available for

the Minneapolis-St. Paul, Detroit and Seattle airports -- all of which have

parallel runways. Much more remains by way of testing, development and

federal approval.

Research started in 1994 at NASA's Langley (Va.) Research Center, where

an engineer was thinking about the growing congestion at big airports with

parallel runways. If computer systems in the planes could talk with each

other digitally, they could adjust their speeds and altitudes to land safely

in closer proximity.

"That's exactly our problem in Minneapolis," thought Honeywell engineer

Bill Corwin, after reading about the NASA research. In bad weather, airplanes

must be staggered by 2* miles, Corwin said. That means 45 landings in an

hour, instead of the normal 60.

NASA and Honeywell already had a track record together, having worked

on a global positioning system a decade ago, and NASA was happy to have a

corporation that could take a great idea to the marketplace. So they joined

forces 2* years ago.

In August and September, NASA tested the system with computer

simulations, followed by a series of test runs by 16 airline pilots at a NASA

test facility at Wallops Island, Va.

But Saturday's test was the first at an actual airport, amid commercial

traffic.

Honeywell supplied the mint-condition Gulfstream, and NASA supplied the

757, a plane that normally would accommodate 180 to 200 commercial

passengers. But most of this 757's seats had been stripped away to make room

for rows of gray cases containing computer equipment. And the plane was

filled with 40 NASA test engineers and personnel, dressed in blue flight

suits.

"Look to the right," said NASA research engineer Terry Abbott.

Beyond the window, sunshine gleamed off the Gulfstream, flying on a

path 1,000 feet below the 757. Both planes were headed east toward the

parallel runways. On one of three video displays, the 757 is represented by a

triangle, the Gulfstream by a diamond.

Through a headset comes the order for the Gulfstream to intercept. The

Gulfstream climbs to 4,000, where the 757 is, and begins turning directly

into the 757's flight path. It's a collision scenario. On the radar map, the

Gulfstream diamond turns yellow. Before it turns red, pilots in both planes

get a series of alerts, warnings and orders.

'"Traffic Parallel Approach!" a shrill mechanical voice says. Twice.

That tells the Gulfstream it's off its mandated approach and threatening

another plane.

"Climb. Turn. Climb. Turn."

The big 757 banks sharply to the left. And the Gulfstream veers right.

It's exciting, but far from threatening. The planes were never closer than

1,500 feet of each other.

You'd see this situation less than once in a million or more landings,

Abbott said. "It's actually hard to hit another plane, and getting the

staging right is really hard."

If you missed Saturday's demonstration show over Lake Harriet, not to

worry. NASA and Honeywell will conduct 18 more test runs Monday, Tuesday and

Wednesday. Airport executives from across the country will sit in the 757 and

watch a computer stop a jet from running into it.

© Copyright 1999 Star Tribune. All rights reserved.

============

** NOTICE: In accordance with Title 17 U.S.C. Section 107, this material is

distributed without profit to those who have expressed a prior interest in

receiving the included information for research and educational purposes. **

Sunday, August 8, 1999

More Close Calls at Airports

Incidents Up Despite Efforts to Reduce Near-misses on airport runways are getting more frequent.

By Glen Johnson

The Associated Press

W A S H I N G T O N,   July 28 ? In early April, the pilot of a Korean Air plane carrying 362 people had to swerve during his takeoff run to avoid hitting an Air China cargo jet that had strayed onto the wrong runway at Chicago's O'Hare Airport.

     Late last month, an Icelandair jet taking off with 185 passengers aboard came within 200 feet of an Air France cargo plane that had mistakenly turned onto the active runway at Kennedy Airport in New York.

     Both near-disasters highlight the danger of ?runway incursions,? a problem that a new study finds is increasing despite Federal Aviation Administration efforts to reduce it.

Most Incidents Blamed on Pilots

In 1998, according to a report by the Transportation Department inspector general, there were 325 runway incursions across the United States, up 11 percent over the year. The largest share, some 183 incidents, were caused by pilot mistakes.

     In 1997, there were 292 runway incursions in the United States, 132 of them caused by pilot mistake.

     The report found that 65 percent of the runway incursions in 1998 were attributable to general aviation aircraft, which are noncommercial, nonmilitary airplanes and helicopters.

     Drew Steketee, spokesman for the Aircraft Owners and Pilots Association, the world's largest general aviation group, said Tuesday that the percentage of incursions is not surprising since it is roughly the same as the percentage of small aircraft operating at airports with control towers.

LAX, St. Louis Lead

The study also found that Los Angeles International Airport had the most incursions in 1998 ? 13. That same year, there were 773,729 takeoffs and landings at the airport, the nation's fourth-busiest.

     For the third consecutive year, Lambert Field in St. Louis was near the top of the list. It placed second in 1998 with eight incursions, up from seven in 1997 and 1996, when it led the list or was tied at the top.

     Last year Lambert had 503,673 takeoffs and landings, making it the 11th busiest airport in the country, according to FAA data.

     While the agency launched a program in 1995 to reduce runway incursions, it ?continues to be ineffective in reducing runway incursions,? the inspector general found.

Fending Off Tragedy

The report added: ?In our opinion, the FAA's progress in reducing runway incursions has been too slow. ... Without immediate progress in implementing its plan, it is unlikely that FAA will achieve its goal of reducing runway incursions by 15 percent by the year 2000 and mitigate the risk of a tragic runway accident.?

     The FAA concurred with the bulk of the report.

     We're working internally to accomplish the goals of the action plan, which includes improvements in runway

markings and pilot, ground-vehicle operator and controller awareness,? said agency spokesman Fraser Jones.

     FAA Administrator Jane Garvey has started monthly meetings with her associate administrators to ensure top-level supervision for all facets of the agency's response to the problem, Jones said.

     According to an agency definition, an incursion occurs any time a plane, vehicle, person or object on the ground

creates a collision hazard with an airplane that is taking off or landing at an airport under the supervision of air traffic controllers.

     Eleven such accidents dating back to 1972 have claimed 719 lives and destroyed 20 aircraft. The National Transportation Safety Board, which investigates airplane accidents, has placed reducing runway incursions on its annual “ Most Wanted” list since its inception in 1990.

Where Are the Near-Misses?

Airport Incursions Takeoffs/Landings

Los Angeles 13 773,729

Lambert-St. Louis   8 503,673

Newark, N.J.   8 461,910

Phoenix Sky Harbor  7 529,649

Cleveland-Hopkins   6 308,540

Detroit-Wayne County   6 538,153

Anchorage   5 311,590

Dallas-Fort Worth  5

929,700 Indianapolis   5 242,540

McCarran, Nev.  5 470,707

Appendix L: About the Author

Arlene M. Brown

More then 21years in aerospace industry

Boeing Associate Technical Fellow Materials and Processes Engineer

BS Materials Engineering Rensselaer Polytechnic institute, Dean’s List all semesters

MBA City University, President’s List all semesters

Relevant Assignments: Boeing Policy and/or Export Control Laws prohibit me from addressing this relevant experience in these public comments

1) Engine Hush kit proposal

2) Two bird strikes resulting in fuselage loss

3) Task manager for developing Repair damage database (primarily bird strike)

4) Modifications to aircraft to add new navigational aids

5) Fuel dumping aircraft hardware

6) On safety distribution (“Do not Site or Release” accident reports)

My comments are my personal beliefs and do not necessarily reflect that of my employer or CASE. They are based on thousands of hours of research over several years all done on a volunteer basis.

My opinions also do not necessarily reflect that of the Public Health SeaTac Area Health Study team which I was drafted for June 1999.

Contact Information:
Arlene Brown

239 SW 189 Pl

Seattle, WA 98166

Email brownadb@gte.net

Home phone (206)431-8693

Cell phone (206)679-9161

Mail box also at Normandy Park, WA CASE office

Appendix M

All submitted to Army Corps of Engineers

Alternatives

Ref 134 page 22

Soil/Aquifer

AGI page Q-A-15

Ref 117

Rainfall chart

Health

Ref. 61

Ref 57 page 1 (but rest is also relevant)

Ref 55 -56

Refs 174 – 182

Noise Chart

Air Pollution

Ref. 101

Ref 103 (not sent to DOE)

Ref 98 (not sent to DOE)

Ref 99 (not sent to DOE)

Rev A addition: Health Ref. 168 supplied to both Corps and DOE with cover letter dated 8 December 1999 that accompanied my comments to the DOE.