Submitted by Don Russell and Tom McClellan.
This paper describes the events that have resulted in the foretold demise of Waughop Lake as a crown jewel of Fort Steilacoom Park. Waughop Lake’s demise is the direct result of irresponsible stewardship of the lake on the part of the City of Lakewood abetted by Ecology.
The foretold demise
In a July 22, 2019 letter published in The Suburban Times bearing the caption of The Pending Demise of Waughop Lake Courtesy of Ecology and Lakewood City Council I stated:
One of these days soon Fort Steilacoom Park goers will witness the beginning of the demise of Waughop Lake as 8 large tanker trucks roll up to the shoreline of Waughop Lake, unload their toxic cargo of chemicals onto a barge that will then discharge 48,826 pounds of toxic soluble aluminum and 109,730 pounds of sulfate into the lake. The sulfate will subsequently be chemically transformed into toxic hydrogen sulfide upon exposure to Waughop Lake’s oxygen depleted bottom waters and nutrient polluted sediments.
Whereas the City council members have received numerous pleas from Lakewood and surrounding area citizens to not allow this Ecology sanctioned chemical pollution of Waughop Lake to take place, Council has instead elected to follow the advice of City staff and its hired (for $94,720) pro alum treatment consultant (Tetra Tech). The City’s hired alum applicator (HAB) will be paid $326,673 to discharge this toxic chemical brew into Waughop Lake at a total combined Waughop Lake alum treatment cost of $421,393. Ironically, the funds that will be used to pay for this alum treatment will be provided by Lakewood and Pierce County private property owner surface water management and flood control zone district ratepayers, not by the two state owned institutions (Western State Hospital and Pierce College) that caused the nutrient pollution condition of Waughop Lake’s bottom sediments.
It is interesting to note that similar size Wapato Lake was alum treated in 2017 under the supervision of a different alum treatment consultant Herrera (paid $31,544) using the same HAB applicator (paid $96,303) that the Lakewood City staff will be using for the Waughop Lake alum treatment. The total combined cost for the Wapato Lake alum treatment was $136,556.
The City of Lakewood paid Brown & Caldwell $200,000 to develop the 2017 Waughop Lake Management Plan, This Plan stated that the best management practice to restore the safe beneficial recreational, aquatic life and aesthetic enjoyment use of Waughop Lake is to remove the layer of nutrient polluted sediment laid down by 65 years of Western State Hospital’s discharge of slaughtered animal waste products, manure and human sewage and 40 years of Pierce College’s intermittent discharge of human sewage into Waughop Lake. This Plan stated that should funding for sediment removal be unavailable, then a $210,000 alum treatment could be considered to temporarily mitigate one effect (harmful cyanobacteria blooms) of the existence of this layer of nutrient polluted sediment.
City staff, without challenging the City’s two consultants’ wildly divergent cost estimates for removing the layer of State institution caused nutrient polluted sediment from Waughop Lake, advised City Council that the sediment removal best management practice option was simply unaffordable. Staff advocated and City Council approved Tetra Tech’s prescribed $421,393 alum treatment plan that has a price tag twice that of B&C’s prescribed alum treatment plan and 3 times that of the cost to implement the 2017 Wapato Lake alum treatment plan.
My appeal to the Pollution Control Hearing Board
In 2019 I filed an appeal with the State Pollution Control Board to prevent this massive discharge of toxic chemicals into Waughop Lake. The appeal was denied on narrow legal grounds, not on its merit. The appeal did however delay the TetraTech proposed alum applications until 2020.
One final plea to the City of Lakewood City Council
In a November 4, 2019 letter to City Council members published in The Suburban Times I stated:
Dear Lakewood City Council Members, the algae/aquatic plant growing season in Waughop Lake is now over. The lake has experienced its lowest surface water level in the 20 years that I have been monitoring the lake’s behavior.
The 2019 proposed $420,000 Tetra Tech prescribed alum treatment did not occur this year. Yet there was no significant harmful cyanobacteria blooms, only excessive aquatic plant growth that interfered with people fishing for bass and carp along its shoreline. This fact is significant and needs explanation.
In 2017 the City verified that Pierce College’s human sewage was intermittently being discharging into Waughop Lake. In 2007, I brought this situation to the attention of the Tacoma Pierce County Health Department and the City of Lakewood. At that time this discharge of sewage was attributed to a construction mishap on Pierce College’s campus. There was never any follow up to see if this 2007 noted sewage discharged ceased after the campus construction project was completed. These facts were unbeknownst by those who drafted the 2015 Brown & Caldwell Waughop Lake Management Plan that concluded that internal P loading from sediment (rather than external sewage P loading) was the proximate cause of the lake’s recurring harmful cyanobacteria blooms.
Human sewage is rich in nutrients, particularly in phosphorus that fuels harmful cyanobacteria blooms. Pierce College’s discharge of human sewage into Waughop Lake College finally, after 40 years, ceased in the winter of 2017. Once this external source of phosphorus loading of Waughop Lake was eliminated the lake began to transition from a turbid water toxic algae dominated state to a clear water aquatic plant dominated state. Such transformation will require an entirely different (than a in-lake alum treatment) lake water quality management strategy if the lake is to provide park goers future full beneficial uses (fishing, boating, wading, aesthetic enjoyment) of the lake.
Fortunately, Ecology’s APAM-NPDES general permit issued to the City of Lakewood does provide numerous approved chemical treatment options for managing excessive aquatic plant growth. However, lacking at this time is a City Council/staff designated Waughop Lake water quality manager whose responsibility is to (1) decide which of these many Ecology approved lake water quality management techniques is appropriate for application in aquatic plant (including invasive non-native curly leaf pond weed) infested Waughop Lake and (2) to select and provide oversight of the City’s selected applicator of the appropriate combination of these Ecology approved chemicals (e.g., algaecides, herbicides and phosphorus inactivation agents).
Lacking such a City designated Waughop Lake water quality manager, the most environmentally responsible and least expensive option for the City, park attendees, and Pierce County Surface Water Management and Flood Control Zone private property owner ratepayers is to refrain from any chemical intervention of Waughop Lake’s current transition from a turbid water harmful cyanobacteria dominated state to a clear water aquatic plant dominated state.
All three independent studies done on Waughop Lake agree that the appropriate and environmentally prudent action to restore the safe beneficial use of nutrient impaired Waughop Lake is the dry and wet removal of the layer of nutrient polluted sediment that was laid down by 65 years of Western State Hospital’s disposal of slaughtered animal waste, manure and human sewage and 40 years of Pierce College’s intermittent discharge of human sewage into Waughop Lake.
At this critical time, I urge you to take informed, wise and environmentally prudent action to assure that the restoration of Waughop Lake’s safe beneficial recreational and aesthetic enjoyment takes place commencing in 2020 and beyond.
March and July 2020 alum treatments
The City of Lakewood Council approved, Ecology permitted and the TetraTech prescribed 40 mg/L alum treatments were applied in March and July of 2020 to Waughop Lake by HAB Aquatic Solutions.
What happens in such a treatment is that aluminum sulfate (AKA alum) is applied to the lake, along with a buffering compound of sodium aluminate. The reason for the buffering compound is that aluminum sulfate has a pH of around 2.0, meaning super acidic. So the sodium aluminate (pH of 11) neutralizes that acid shortly after application, hopefully leaving the lake in a neutral state, meaning not acidic, not basic.
Aluminum sulfate has the chemical formula Al2(SO4)3. It is a molecule whose aluminum ion (Al2) is weakly bound to its sulfate ion (SO4). When it hits the water during the application, the aluminum ion gets easily attracted away to bond with something else, like the phosphorous that is in suspension in the water, or with just about any organic matter. The newly bound particles then fall to the bottom of the water body, leaving it very clear. This is why alum is used in many municipal water systems (but not in Lakewood), as it grabs onto any particles of pollutant or precipitates in the water.
But when the Al2 ion rips itself away from the aluminum sulfate molecule, it leaves the SO4 ion looking for a new dance partner. The result is that sulfate and sulfide compounds are formed in the lake sediments, making them more acidic and less amenable to aquatic plant growth. Acidic soils can also result in the released of mercury, cadmium, lead, arsenic, and other heavy metals that may be in the lake sediments. This is particularly a concern for lakes like Waughop that are in the Asarco fallout area.
The immediate result was clarification of the water in Waughop Lake. The expectation was that the native aquatic vegetation in the lake would respond with renewed growth. This did not happen and the migratory aquatic plant feeding diving duck population did not return to the lake during the 2020-2021fall and winter season.
In the spring 2021 the lake’s water clarity plummeted as it experienced an algal bloom comprised of a species of green algae (Coelastrum) that typically inhabit nutrient rich ponds. Aquatic plant growth did not occur. The frog and turtle population disappeared from the lake as did its eagle and osprey. In the late summer the lake experienced a relatively mild but noticeable harmful cyanobacteria bloom.
This spring the water clarity again plummeted as it experiencing an algal bloom comprised of a species of green algae (Chlorella) that typically inhabit sewage treatment ponds. The effect of this bloom is as noted in the below picture.
As a result of the photosynthesis activity of this Chlorella bloom the pH in the lake hovers in the vicinity of a pH of 9.3 to 9.8 which is far above Ecology’s water quality standard upper limit of 8.5 for the protection of aquatic life. At this pH the insoluble aluminum hydroxide that lies on the bottom of the lake becomes a toxic soluble form of aluminum. To compound this situation is the fact that the lake is also polluted with high concentrations of alum treatment induced sodium and sulfate ions. Their concentration has materially changed the chemical composition of Waughop Lake’s low mineral concentration to high mineral concentration water. Furthermore, the sulfate ions are being reduced in anoxic bottom water and sediment to sulfide ions forming very toxic hydrogen sulfide.
The City of Lakewood Council’s authorized, Ecology permitted, TetraTech prescribed and HAB Aquatic Solutions’ March and July 2020 40 mg Al/L alum applications (total 80 mg Al/L) has had the adverse environmental impact on Waughop Lake that was foretold by Don Russell to Paul Bucich, Lakewood City Council and Ecology back in 2019.