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Dear Dept. of Ecology: Do right by Moxlie Creek

Department of Ecology,

I remain concerned about what is going on at the East Bay redevelopment site. Perhaps you can offer some clarification.

I am once again forwarding you a study that was published by 11 EPA scientists.

The study notes that nitrates travel 18 time farther in a pipe in a culvert than a pipe that sees daylight. The science behind this is well documented and understood. It is likely that the LOTT Clean Water Alliance will be required to reduce nutrient loading into Budd Inlet as part of this Total Maximum Daily Load process. LOTT currently employs the most advanced nitrogen (nutrient) removal processes available. Reducing LOTT’s discharge would have significant impacts for LOTT operations and future capacity. Daylighting Moxlie Creek might greatly reduce nitrates, but that decision is outside their purview. Why would the Department of Ecology not consider the long-term ecological and oceanographic effects of building such a large structure in the historic estuary?

In addition to high levels of nitrates, we are struggling with low levels of dissolved oxygen and sediments contaminated with dioxin and PCBs.

According to the comprehensive Sediment Characterization Study of 2008 (page 54): “Additional evaluation is needed at the Hardel Mutual Plywood site and the Moxlie Creek discharge to determine whether these sites are significant sources of dioxin/furan contamination through the use of PCP as a wood preservative….” The way to do this is to sample using in-line sediment traps and similar techniques. Claiming that the source is an old phone pole or woody debris does not rule out the culvert.

If the Moxlie Creek discharge is the source of dioxin entering the bay, the most plausible source of dioxin entering the pipe would be contaminated fill around the pipe entering through fissures. There has been no attempt to determine whether Moxlie Creek is the source, the preference being to piecemeal the cleanup and development concurrently. The Department of Ecology claims they “will be evaluating sources of contamination to Budd Inlet as part of the Budd Inlet Sediments work.” They don’t indicate when they might get to it.

Ecology claims that they “collected and analyzed soil samples from borings to define the vertical extent of soil contamination (and) drilled as deep as we needed to, to define the vertical extent of soil contamination.” They claim that “if DNAPLs (dense non aqueous phase liquids like dioxin containing creosote) were present, we would see related contamination somewhere in the soil, vapor, and/or groundwater.”

According the the EPA: “Although analysis of ground water provides useful information on the distribution of the soluble components of the DNAPL, the presence of other phases of the DNAPL may go unrecognized. The investigation must, therefore, be more detailed to obtain information concerning the phase distribution of the DNAPL at a site. Site characterization may require analyses on all four phases (aqueous, gaseous, solid, immiscible) to yield the appropriate information. In brief, data collected on the various phases must be compiled, evaluated and used to help identify: where the contaminant is presently located; where it has been” and so on.

The nature and extent of contamination on the port peninsula is not known. DNAPLs are heavier than water and will tend to sink to an impervious layer and migrate horizontally. We should sample to this impervious layer which on this property is about 25 feet deep.

Here’s what the port has done. Pages 69 and 71 show cross sections and sampling depths on those cross sections. Pages 159 to 180 list sample depths expressed as range or depth to bottom of the screen. None of the samples that would have targeted DNAPLs reached 25 feet, the depth of the first impervious layer. Most are within the top few feet.

The Port of Olympia claims fill on parcels 2 and 3 is clean gravel brought in from off site. 1.1 million cubic yards of contaminated dredge spoils were used as fill during the same time period. The USACE can’t specify exactly where this was placed. Port claims seem to be based on work orders and internally generated diagrams. The fill brought in from off site wasn’t sampled. DNAPLs could also have migrated from the nearby city hall site which was contaminated with coal tar down to the first impervious layer and out to the property’s edge in the direction of Parcels 2 and 3. The port claims the hot spot is an old piling or some woody debris. There are old pilings all over the bay. They generally don’t give off these concentrations of dioxin.

Do these efforts meet the Department of Ecology’s statutory obligation? Can you clarify how?

 — Harry Branch


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