Submitted by Don Russell, Lakewood.
Nonfeasance defined – failure to act where action is required by law, willfully or in neglect.
In my first letter on this subject I stated that the City of Lakewood was not in compliance with the provisions of the Clean Water Act and State regulations regarding public involvement and participation, as well as State, County and City ordinances that require sites that pose public health risks to be cleaned up. All citizen pleas to City of Lakewood Council to comply with these regulations and ordinances have been ignored.
Further I indicated that City Council should withdraw its support for a local ratepayer funded lake-wide alum treatment. I stated that the appropriate short term action is to engage an Ecology licensed chemical application contractor to annually monitor water quality in Waughop Lake and prescribe and apply the minimum quantities of Ecology approved chemicals necessary to assure safe beneficial recreational use of the lake. This action is necessary to prevent each year’s excessive aquatic plant growth and nuisance filamentous green algae and harmful Cyanobacteria blooms. Annual chemical applications should continue until such time that adequate State funding is provided to remove the layer of nutrient rich sediment that has accumulated on the bottom of the lake as a result of two State owned institutions discharging slaughtered animal waste products and human sewage into Waughop Lake over the past 100 years.
The focus of this letter is on the unintended adverse ecological consequences of a lake-wide aluminum sulfate (alum) and sodium aluminate (buffer) application.
The liquid aluminum sulfate to be applied to Waughop Lake weighs 11.1 pounds per gallon. Each gallon of this material discharged into a lake contains 0.48 pounds of aluminum ions (the active phosphorus inactivation agent), 2.53 pounds of sulfate ions, and 8.10 pounds of water.
At the time that liquid aluminum sulfate is discharge into a lake both the aluminum and sulfate ions contained in this liquid are toxic to aquatic life. Soon after discharge the aluminum ions combine with a component of lake water (OH- ion) to form a nontoxic insoluble aluminum hydroxide flocculent material (alum). This material combines with the phosphorus (orthophosphate ions) contained in the water column and sediment to inactivate phosphorus thus denying Cyanobacteria the nutrient that enables their explosive growth to bloom proportions.
The sulfate ions do not undergo a transformation from a toxic to nontoxic form after their discharge into lake water. Instead sulfate ions undergo several ecologically harmful transformations.
Toxic sulfate ions are transformed by a series of biologically induced chemical reactions into toxic sulfite ions, sulfide ions, and elemental sulfur. Sulfate ions combine with hydrogen ions to form sulfuric acid. Sulfite ions combine with soluble iron to form insoluble iron sulfide thus removing mother nature’s preferred phosphorus inactivation agent from the water column. Sulfide ions combine with hydrogen in sediments to form toxic hydrogen sulfide gas. Elemental sulfur particles are toxic to aquatic life.
Brown & Caldwell advocated discharging 20,000 gallons of liquid aluminum sulfate weighing 222,000 pounds of which 9,600 pounds is aluminum, 50,600 pounds of sulfate, and 161,800 pounds of water!
In addition to the above Brown & Caldwell advocating simultaneously discharging 10,000 gallons of liquid sodium aluminate weighing 121,000 pounds of which 12,780 pounds is aluminum, 25,940 pounds is sodium and oxygen, and 82,280 pounds is water!
The total weight of the chemicals (ignoring the weight of the tanker trucks) that will be traveling over the road leading to and walkway surrounding Waughop Lake and discharged into Waughop Lake is 343,000 pounds of which 22,380 pounds is phosphorus inactivating aluminum, 50,600 pounds of toxic sulfate, and 270,020 pounds of water! The same phosphorus inactivation effect can be achieve by application of far less than 22,380 pounds of finely granulated (zero valent) iron powder and at significantly lower costs and adverse ecological impact.
The TetraTech belated proposal requested by City staff increased by a factor of 2.3 times the amount of chemicals (and transportation weight and cost) to be discharged into Waughop Lake!!
The legacy of implementing the Brown & Caldwell prescribed alum treatment option will be aluminum and sulfate pollution of what is now a nutrient rich sediment that has commercial value as a soil amendment. This untreated nutrient rich bottom sediment can be removed from the lake by an Ecology prescribed best management practice, i.e., lake level drawdown, followed by a combination of exposed dry and wet sediment removal. The cost to implement this recommended (by three independent studies) dredging option was estimated by Brown & Caldwell to cost $2.7 million.
There is ample reason for the City of Lakewood Council to abandon further consideration of the consultant and City staff advocated costly and environmentally damaging lake-wide alum application option in favor of embracing a far less costly and environmentally friendly option for the short term (until State funding is forthcoming) restoration of the safe beneficial recreational use of Waughop Lake.