Submitted by Don Russell, Lakewood.
This article recites the facts and laws that pertain to Waughop Lake’s present degraded condition and how these facts and laws are being ignored by Ecology and the Lakewood City Council.
Fact No. 1
At the present time Waughop Lake does not provide safe public beneficial recreational, aquatic life and aesthetic value uses as required by law. The lake currently experiences excessive aquatic plant growth and filamentous green algae and harmful cyanobacteria blooms. The proximate cause of all three of these beneficial use denying conditions is the existence of a layer of nutrient polluted sediment deposited on the lake’s bottom by 65 years of Western State Hospital’s discharging slaughtered animal waste, manure and human sewage followed by 40 years of Pierce College’s intermittent discharge of human sewage into Waughop Lake. Provisions of the Federal Clean Water Act, State legislatively enacted RCWs and approved WACs (laws) require that Ecology take appropriate action, or require others to take appropriate action, to restore Waughop Lake’s designated beneficial uses. Restoration of Waughop Lake’s beneficial uses will require the removal of this layer of nutrient polluted sediment. The State’s policy is that the responsible polluter is to pay for cleanup. In this case, it is the State, not the City of Lakewood ratepayers who is responsible for paying for the cleanup of Waughop Lake.
Fact No. 2
An alum treatment temporarily mitigates, i.e., lessen the adverse impact of, one of the three biological responses to the existence of Waughop Lake’s layer of nutrient polluted sediment. An alum treatment does not restore the safe beneficial recreational, aquatic life and aesthetic value uses of Waughop Lake as required by provisions of the Federal Clean Water Act, State legislatively enacted RCWs and approved WAC (laws).
Fact No. 3
The City of Lakewood Council has elected, contrary to fiscally prudent common sense, to assume the State’s responsibility for restoring the safe beneficial uses of Waughop Lake. The City will likely continue to rely on consultants to advise City staff members rather than seek input from a lake management advisory committee comprised of knowledgeable citizen stakeholders. City of Lakewood and Pierce County private property surface water management and flood control zone district ratepayers will be expected to fund Waughop Lake’s restoration even though they are not the responsible polluters of the lake.
Fact No. 4
The alum treatment prescribed by the City’s Consultant is unprecedented in both scope and cost. Typically, alum treatments involve the discharge of an average of 12 mg Al/L under provisions set forth in Ecology’s Aquatic Plant and Algae Management – National Pollution Discharge Elimination System (APAM-NPDES) general permit. The City’s Consultant has prescribed the discharge of 80 mg Al/L into Waughop Lake this year and 40 mg Al/L next year for a total of 120 mg Al/L! This amount of toxic liquid aluminum is 10 times the amount of aluminum contemplated and thus permitted by Ecology’s APAM-NPDES general permit. Furthermore, this treatment will cost City and County property owner ratepayers more than three times the 2017 cost of alum treating comparably sized Wapato Lake.
Fact No. 5
Recently both Seattle’s Green Lake (at an aluminum dosage of 8.2 mg Al/L) and Anacortes’ Heart Lake (at an aluminum dosage of 10.8 mg Al/L) experienced fish kills after being treated with alum. In both cases the alum applicator following all provisions of Ecology’s APAM-NPDES general permit. It was subsequently determined that Ecology’s APAM-NPDES general permit provisions governing alum treatments are inadequate to protect aquatic life from the adverse effects of alum treatments. One can imagine what the effect will be on Waughop Lake’s fish population when the Consultant’s prescribed 80-120 mg Al/L dosage is discharged into Waughop Lake!
Fact No. 6
The alum treatment advocating Consultant (TetraTech) that the City staff hired to advise them on Waughop Lake’s pending alum treatment is charging three times the amount paid to the Consultant (Herrera) who prescribed the alum dosage and provided oversight for Tacoma’s 2017 alum treatment of similar sized Wapato Lake. One wonders how it came to pass that City staff decided to employ the services of alum treatment advocating TetraTech as its consultant rather than a more experienced and less expensive alum treatment consultant (Herrera).
Ecology and the City of Lakewood Council claim that the City’s Consultant proposed Waughop Lake alum treatment plan complies with all provisions of Ecology’s APAM-NPDES general permit and as such will do no environmental harm to Waughop Lake’s aquatic life. Recent alum applications involving much lower quantities (one tenth the amount) of liquid aluminum sulfate and sodium aluminate than prescribed by the City’s Consultant have experienced fish kills as a result of aluminum ion toxicity.
Waughop Lake’s Ecology sanctioned alum treatment will result in the discharge of 48,826 pounds of toxic soluble aluminum and 109,730 pounds of soluble sulfate/toxic sulfide ions into an already state institution nutrient polluted Waughop Lake, all at the expense of City of Lakewood and Pierce County stormwater management and flood control zone district ratepayers.
Bottom line: The Lakewood City Council has elected to defend City staff’s actions instead of addressing the legitimate concerns expressed by many citizens about the propriety of alum treating Waughop Lake. Ecology has failed to do its job as prescribed by the provisions of the federal Clean Water Act and relevant State legislature enacted RCW’s and approved WACs (laws).