Following is a letter by Lakewood’s Don Russell to Jon Jennings, Aquatic Pesticide Permit Specialist for Washington State’s Department of Ecology.
City of Lakewood/HAB Aquatic Solutions has requested a permit to discharge 43,440 gallons of liquid aluminum sulfate (alum) weighing 482,184 pounds of which 21,068 pounds is aluminum and 109,730 pounds is sulfate and 21,720 gallons of liquid sodium aluminate weighing 262,812 pounds of which 27,758 pounds is aluminum into Waughop Lake this year. This paper focuses on the environmental fate of the 48,826 pounds of aluminum and 109,730 pounds of sulfate that will be discharged into Waughop Lake should Ecology issue a permit for this amount of pollutants and potentially toxic material to be discharged into the Lake. It also provides commentary on the extent to which public participation and involvement has been allowed by the City of Lakewood staff and Council in regard to their railroading intent to implement this $420,000 TetraTech prescribed and supervised alum treatment plan.
RCW 90.48.020 states any action that contaminates or alters the physical, chemical or biological properties of any waters of the state or discharges any liquid or solid substance into any waters of the state as will or likely to render such waters harmful, detrimental, injurious to public health, cause loss of beneficial use, or be harmful to fish or other aquatic life constitutes pollution of waters of the state and must be in compliance with provisions of RCW 90.48. Water Pollution Control.
The 48,826 pounds of aluminum to be discharged into Waughop Lake will contain many species of aluminum only one of which, aluminum hydroxide, is nontoxic to fish and aquatic life. Aluminum hydroxide resists dissolution in a rather narrow range of pH conditions. In the deep lakes to which alum treatments are generally applied the pH in their hypolimnion is relatively constant at a pH of 6.0 to 6.5 which is optimum for preventing dissolution of aluminum hydroxide and release of toxic species of aluminum. However, in shallow lakes that experience post alum treatment nuisance filamentous green algae blooms and excessive aquatic plant growth their photosynthetic activity will generate pH values up to 10. At this high of a pH aluminum hydroxide undergoes dissolution and releases toxic forms of aluminum that do have an adverse impact on fish and other aquatic life. This phenomenon has rendered many shallow lake alum applications problematic.
The 109,730 pounds of sulfate to be discharged into Waughop Lake will be reduced by microbial activity in Waughop Lake’s nutrient polluted (by State owned institutions) bottom sediments to toxic sulfide ions and very toxic hydrogen sulfide gas. The adverse ecological effects of this sulfate to sulfide conversion include the methylation of mercury, a herbicidal effect on aquatic plants, hasten the mineralization of organic matter which will increase nitrogen (nitrate-nitrogen, ammonia-nitrogen) and phosphorus (phosphate-phosphorus) releases from sediments that will subsequently foster nuisance filamentous green algae blooms and excessive aquatic plant growth which in turn will cause high pH conditions causing the release of toxic species of aluminum into the water column, sequester soluble iron (nature’s own phosphorus inactivation agent) as insoluble iron sulfide, and generate and release toxic hydrogen sulfide gas into the water column and upon is oxidation form sulfuric acid. In this regard I have referred you to the article titled: Sulfate as a Contaminant in Freshwater Ecosystems: Sources, Impacts and Mitigation which can be accessed at:
Clearly the discharge of 48,826 pounds of aluminum and 109,730 pounds of sulfate into Waughop Lake would constitute an act of pollution in violation of provisions of Chapter 90.48 RCW Water Pollution Control should Ecology permit such huge discharges of pollutants into Waughop Lake.
The City of Lakewood staff and Council members have consistently violated the intent of the 1988 citizens’ Initiative 97 that led to the State enacting the Model Toxic Control Act. The key principles of this Act and how they have been violated are as follows.
The polluter pays for cleanup. The polluters of Waughop Lake are two state owned institutions. The State should pay for Waughop Lake’s cleanup not Pierce County and City of Lakewood Surface Water Management and Flood Control Zone District ratepayers.
Cleanup should be as permanent as possible. The discharge of tons of liquid alum and sodium aluminate into Waughop Lake does not constitute cleanup, nor is it a permanent solution. The repeated alum applications that will follow this initial application will hasten the transformation of an aluminum, sulfide and phosphorus polluted lake into a hydrogen sulfide gas emitting swamp.
Public participation is critical. The City of Lakewood has done everything it can to discourage public participation and discredit and disenfranchise those who have attempted to participate as evidenced by over 30 articles and public comment that have appeared in The Suburban Times that oppose treating Waughop Lake with alum.
Processes should demonstrate a bias toward action, permanence, and innovation. The City of Lakewood staff and its consultants’ have advocated a very costly, experimental (in the sense that this amount of potentially toxic material can be discharged into a very shallow, aquatic plant infested, heavily phosphorus polluted lake without adversely changing is physical, chemical and biological properties) and impermanent application of liquid alum and sodium aluminate to merely suppress one symptom, i.e., harmful cyanobacteria blooms, of its nutrient polluted sediment condition for a relatively short period of time. Furthermore, City staff has refused to objectively consider other more innovative approaches to suppressing harmful cyanobacteria blooms and dredging options other than those proposed by the City’s consultants.
For all the above stated reasons the City of Lakewood/HAB Aquatic Solutions should not be issued a permit allowing the discharge of tons of polluting and potentially toxic liquid aluminum sulfate and liquid sodium aluminate into Waughop Lake this year.
Furthermore, the City staff and Council should be required by Ecology to promote rather than discourage citizen participation and involvement in identifying and implementing cost effective, permanent and innovative solutions for remediating (i.e., cleanup) Waughop Lake’s nutrient polluted sediment impaired condition.
If you’d like to comment on the City of Lakewood’s Permit Application, contact Jon Jennings, Aquatic Pesticide Permit Specialist at Jonathan.Jennings@ecy.wa.gov or 360-407-6283. Deadline for comments in April 17, 2019.