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).
Conclusion
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).
Karen Duggins says
Don Russell, Have you thought about contacting our State Representatives or a legal council to act on these poorly sought actions by the The City of Lakewood Council? It would seem a prudent idea, but better if it had been done sooner than at this point, which seems too late for the fish. Sad.
This was a good post thank you for sharing.
Eric Chandler says
Karen…Don has contacted our state representatives on numerous occasions, as have I. Nothing happened.
I and 9 other people wrote WA dept of Ecology asking them to deny the City of Lakewood’s request for approval to do the alum treatment. We were ignored and Ecology’s response to our concerns was wholly inadequate.
I wrote a letter to Governor Inslee and got NO RESPONSE from him NOR his staff. All his office did was pass my letter to Ecology…the very same state agency that has mishandled this situation…even though my letter asked that the Governor intervene and make Ecology do as it is legally required to.
WA state Ecology did their duty for the Governor and sent me a letter that was nothing more than a rehash of what I had seen in previous correspondence from them.
Bottom line….
The STATE is responsible for the mess in Waughop Lake as so clearly indicated in Don’s FACT # 1.
The STATE refuses to CORRECTLY rectify the problem and is ignoring both Federal and State Ecology Laws….the Governor, Our Elected State Representatives, and Department of Ecology have done virtually nothing for the people they represent.
Thru the auspices of the STATE, the City of Lakewood will very likely kill ALL aquatic life in the lake: Fish, Turtles, Frogs, and any other amphibians after the Alum treatments. Who knows what impact there will be for wildlife….Eagles, Deer, Fox, Waterfowl, etc.
And, by the way, when this treatment goes awry, Steilacoom Park’s centerpiece has a very-good chance of becoming a toxic swamp.
If any of you out there want the FULL picture concerning this whole mess, just type in “Waughop” into the Search this Website block at the top-right corner of the Suburban Time’s web page.
Eric K Chandler says
CORRECTION…THERE WERE 14 OTHER PEOPLE who wrote WA dept of Ecology asking them to deny the City of Lakewood’s request for approval to do the alum treatment.
Ecology admitted this was an unusually high number of citizen responses.
Ecology then used that as an excuse to SUMMARIZE ALL PUBLIC COMMENTS received into SEVEN COMMENT CATEGORIES.
Why not?
Shouldn’t have to spend all of that EXTRA time with a COURTEOUS RESPONSE to each individual who took the time from their jobs/busy schedules to understand the situation entirely and then develop and submit their concerns.
What the Hell…they are only tax-paying citizens (ergo…people that pay their salaries!!!)
Am I miffed, annoyed, displeased, offended, aggrieved, piqued, riled, nettled, vexed, irked, irritated, upset, hurt, pained, put out, fed up, chagrined, disgruntled, discontented, resentful?
Damn straight! To the MAX !!!
William Elder says
Don Russell’s analysis of the deplorable actions approved by the City of Lakewood with regard to the state-created pollution at Lake Waughop is both thorough and accurate— if not well taken by the City or the Department of Ecology. One is left to ascribe motives other than good stewardship of the lake to their wrong-headed behavior. Ecology and the State apparently seek to save a buck by passing on the cost of properly fixing an ecological problem demonstrably of their own making. The City apparently wants a quick fix by quietly handing off those costs to local taxpayers, while stonewalling well-founded objections to their ill-considered actions. Responses by both entities to objections have been perfunctory, more brush-off than a real consideration of legetiment citizen concerns over mishandling of a treasured public resource.
Matt says
And who will be responsible when these 48,826 pounds of toxic soluble aluminum and 109,730 pounds of soluble sulfate/toxic sulfide ion material wind up in our drinking water or wells? We should start planning jail time for the ones responsible if this goes through.
If a private citizen was going to put this amount of chemicals into his private pond or lake anywhere in Western Washington the ecology department would be handing out at the least a severe fine or sending the person to jail to be sure!
Eric K Chandler says
Did y’all know that one of the people that wrote WA dept of Ecology asking them to deny the City of Lakewood’s request for approval to do the alum treatment is an EXPERT on proper ways to treat water?
His name is Ken Karch, and even he was ignored and Ecology’s response to his extremely detailed and well documented concerns was absolutely absent.
Following is a quick-and-dirty…no, clean summary of Ken’s background and experience…WHY ECOLOGY IGNORED HIS CONCERNS IS ABSOLUTELY BEYOND ANY SENSE OF REASONING !!!
A Quick Biography of Ken Karch:
Ken Karch is a registered professional engineer with over 35 years of experience in environmental and organizational management in local and state government, non-profit organizations, private consulting, and industry. He holds an undergraduate degree in Civil Engineering from Illinois Institute of Technology, and Masters degrees in Engineering and in Public Health from the University of Michigan. He is a graduate of the University of Chicago’s Industrial Relations Executive Program and Columbia University’s Executive Program in Business Administration. Ken has served on a variety of high-level nation-, state-, region-, and industry-wide boards, commissions, and councils, chairing many of them.
Ken’s experience has included environmental work in a County Health Department in Illinois and the Regional Planning Agency in Washington DC. He was appointed the first Executive Director of the Iowa Department of Environmental Quality and the first Director of the Missouri Division of Environment Quality. He was Washington State and national Environmental Affairs Manager with Weyerhaeuser.
He has served as manager of a 7000 acre property for the Nature Conservancy; Vice President of a Public Development Authority managing a public water system in Ocean Park, WA; President and General Manager of a 2000 member homeowners association; and facilities manager for the Tacoma Mountaineers.
Ken’s personal statement regarding eutrophication and related issues:
I have studied and prepared reports on the condition of several rivers and streams, including my Master’s Thesis at the University of Michigan on the Computer Simulation of the Dissolved Oxygen Condition in the Ouachita River in Arkansas and Louisiana, subject to varying industrial waste inputs, releases from upstream reservoirs, temperature conditions, dissolved oxygen levels and standards, and tidal effects.
I served as a member and Chairman of Seattle METRO’s Citizens’ Water Quality Advisory Committee, dealing with secondary and advanced waste treatment alternatives and sludge recycling and reuse issues.
I authored papers on the computerization of county health department inspection programs; the application of remote sensing data from the Earth Resources Technology Satellite (ERTS) system to urban planning; the literature of packinghouse wastes; wastewater reclamation and reuse; economics of pollution control and surface water diversion projects; public water supply planning; sediment control; flood control; and urbanization effects of water and sewerage planning.
I worked to reduce the eutrophic conditions of rivers, farm ponds, and reservoirs in Iowa and Missouri; and on controls for feedlots, grazing, soil conservation, fishery enhancement, and on reducing pesticide by-products in bottom feeding fish in the interstate commercial fisheries market.
William Marsh says
I was thinking the other day how can this Lake be cleaned up the right way without a legal challenge that will take forever and who pays for that? What do you guy’s think about calling in the area New’s Team’s like King 5, Kiro 7, Komo 4. You guy’s that have the knowledge, the experience, the years of boots on the ground. Bring up the people responsible, there name’s, specific, the passing the buck to the tax payer’s to pay for this seasoning of toxin’s and why is everybody that is appointed in the positions of what the law’s require not following the word of LAW! This helped so many guy’s that I worked with at the Naval Shipyard in Bremerton that were exposed to toxic chemicals for years and it is killing them right now, I was exposed myself. When this hit’s the social media, the kicking of the can down the road come’s to a fast halt. I grew up in Steilacoom and used to play up in that area and we watched them push the animal remain’s into the lake. Its time to push for the right Path for Waughop Lake, this is what adults do for there kids and grandchildren! Good luck guy’s!!
Karen Duggins says
The only way to properly clean the lake once and for all would be to dredge it completely to lift out all the contaminants put there from Washington State Hospital’s misuse of the lake as a feces and animal waste dumpsite upon when they had their slaughter house in use. That being said as mentioned before it is the WA State’s responsibility to clean this lake up the proper way, not just keep dumping more toxins into it and wasting more tax dollars with seems to be the only thing that Olympia has the ability to do with our current Governor. It is time to call it what it is.
If there is not inlet our outlet only ground water does this qualify for Wetlands for protection? I am not savvy on Wetland requirement other than the Feds get involved with the US EPA. Also I have missed all of the prior conversations about this lake and its problems and how they came to be and only learned it was the dumping site for the now called Washington State Hospital in majority as well as Pierce College Sewage overflow waste in the very minor. But the primary offender was the State.
I totally agree with Willam Marsh’s approach and put the cameras on with the new outlets to bring awareness of the lawlessness of our State in fixing this problem. My hat is off to him for bringing this up as the best solution to get it resolved, as in “Get Jesse” on it!!!
Best of luck to you pros out there!