[EDITOR’S NOTE: The following is a Letter to the Editor, written by a Reader. It does not necessarily reflect the opinion of The Normandy Park Blog nor its staff:]
Dear David South,
Thank you for your help in getting the comment period for the Lora Lake Apartments Site extended until January 15th, 2014. This will help in understanding the multitude of documents that have become available. During the long period that this cleanup has been studied, we have all become aware of the much greater collective need to improve the water resources that support our historic salmon runs that are becoming imperiled. There are multitude sources of contaminates, habitat destruction and many unknowns that have created this unacceptable situation. Many stewards, volunteers and state and local agencies are increasing their efforts and funding resources being spent on the preservation and return of acceptable salmon runs throughout the entire Puget Sound region as well as the rest of the state.
Miller Creek is just one small part of this entire problem, but it is recognized as a salmon bearing creek with struggling Coho and Chum salmon runs that are but a fraction of the runs my older neighbors describe as “being able to walk across the creek on the returning fish”. Other species of fish including Bull Trout are described as having been or still are in the creek. Walker Creek which flows into Miller Creek near the estuary also has struggling salmon runs that have less stress from pre spawn mortality, perhaps due to more working wetlands and a less contaminated drainage area. Miller Creek has the potential to become a great example of a successful rehabilitation and return of healthy runs. Already the lower portion of the creek has had the habitat returned to woody debris, deep pools, tree shading and other projects by thousands of hours of steward work. What appears to be missing is control of the chemicals, contaminants and road runoff from the drainage basin. Recently with the help of a county basin steward, Burien was able to stop a commercial car washing facility that drained soaps directly to the creek. Progress is possible.
What we have at the Lora Lake Apartments Site are known and persistent contaminants from former commercial activity (barrel washing and wrecking yard) that occurred at a time when environmental concerns were less than healthy. The Port of Seattle was required by the FAA to purchase this property as part of the third runway development. While I am sure that the Port was not happy to have to purchase a known contaminated site, the fact is they did. This fact is actually a happy coincidence for the downstream communities as the Port, as the largest operator of a huge domestic and international airport, has the engineering staff and wherewithal to actually perform a complete cleanup. This site has had cleanups in the past, but now is an opportunity to remove the contaminants once and for all to keep them out of Miller Creek. There will never be a better time; and it nicely aligns with the mission of the Department of Ecology and stated goals of the State of Washington!
From some of the data recently released, I have several specific concerns:
- The proposed Cleanup Action Plan appears to have the worst of the contaminants/dioxins removed entirely from the site to an appropriate site. However the plan also contemplates removing the dioxins from 100 ppt to 11ppt from the site and inexplicably moved closer to Miller Creek where even some would be in a one hundred year flood plain. This would increase the contaminant loading already existing in the former wetland along the creek and would require continual monitoring and maintenance of any cap and barrier system in perpetuity. The likelihood of disturbance by natural forces or construction activity creates an unacceptable future threat of recontamination within the creek. The 11ppt is the current residential standard and why the much lower wetland standard does not apply to prevent actually moving contaminants into creek wetlands needs to be addressed. Even these standards appear to be under review due to human consumption of fish in these basins. The best answer would be to remove contaminants off site to an appropriate place that accepts such material. Any extra cost should be compared to the long term cost of maintaining a barrier/cap in perpetuity along with the threat of hundred year floods occurring much more often and future construction. The Port is also accepting grant funds which should help to complete a final “once and for all cleanup”.
- There has been a long standing inference that contaminants are also flowing across the site from the storm water system of a neighboring city. Most of this system was constructed when there was no thought as to flash flow and settling ponds for cleaning the flow. The Cleanup Action Plan appears to have this flow diverted around the Apartment site and connected directly to Miller Creek. This must not happen. It may violate federal and state requirements for handling storm water. The inference that this water is also contaminated with dioxins must be studied to determine the actual facts and necessary cleanup before any connection to Miller Creek is contemplated. If this storm water system is reconstructed thru the LLA site, it still needs investigation concerning dioxin being carried in its sediments and appropriate remedies applied. Some adequately sized detention and settling pond east of Des Moines Way may be required before it is allowed to flow across current or recreated wetlands as it would likely create channelization to Miller Creek without detention of flash flows. Such flows would be capable of transporting contaminated sediments.
- The proposed filling of Lora Lake itself may actually create additional problems. It is a known sink and filter for much of the dioxin that came off the Lora Lake site. Trying to recreate a wetland from the lake may require additional detention ponds to handle the flow from the apartment site and land to the east across Des Moines Way for any residual contaminants working their way toward Miller Creek.
I am submitting these comments on behalf of myself, and the city likely will be submitting its own additional comments in early January 2014. Thank you for extending the comment period. I truly believe that Miller Creek has the opportunity to become a statewide example of how salmon runs can be rehabilitated and returned; but that will not happen unless Ecology actually enforces its mandate and cleans up these known contaminates once and for all. I also know that the Port is capable of doing a complete cleanup as evidenced by the success of their detention ponds built since the construction of the third runway. Removal of the contaminated soil down to at least the residential standard to an appropriate off site location that accepts such soil may in fact be the most economical solution when all factors over long periods of time are considered. This would permanently remove one known source of dioxin contaminants as a threat to the viability of Miller Creek. This is not the Love Canal or lower Duwamish. With a bit more effort, this mess can be totally and permanently cleaned up. We have a creek with continuing salmon runs that needs our attention and can be rehabilitated, if we properly address known contaminants. Thank you.
City of Normandy Park
EDITOR’S NOTE: The email address to submit comments about Miller Creek – before Jan. 15 – is: firstname.lastname@example.org
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