Document Puyallup_doc_2cb4e6c87d

City of Puyallup Public Works, Stormwater Management 333 S Meridian Puyallup, WA 98371 Clarks Creek Elodea Hand Pulling Pilot Project After Action Report for In-Stream Work November 18, 2011 Project Manager – Mark Palmer, P.E., City Engineer Report Author – Joy Rodriguez, Stormwater Program Assistant ---PAGE BREAK--- Contents Table of Figures i Abstract 1 Background 2 Clarks Creek Elodea 2 Hand-pulling Success 3 Developing the Pilot Project 3 Project Scope 4 Methodology 4 Results and Discussion 5 Hand-Pulling 5 Equipment 7 Efficiency of Removal 7 Water Quality 7 Recommendations 10 Post-project Assessment 10 Interim Findings: 10 Planning for full-scale operations 11 Labor 11 Accessibility 11 Improving the Process 12 Commercial Divers 12 Moving Forward 13 Citations 14 ---PAGE BREAK--- i I P a g e Table of Figures Figure 1 - Clarks Creek Elodea 2 Figure 2 - Curly leafed pond weed 4 Figure 3 - Daily Work Progress 6 Figure 4 - Comparative visual observation of turbidity – actual data listed in Table 3 8 Table 1 – Project Work Data 6 Table 2 - Gage Height Data (FT) 8 Table 3 - Turbidity Data (Reported in NTU’s) 10 ---PAGE BREAK--- 1 I P a g e Abstract Clarks Creek is a 3.5 mile long waterway with headwaters in the City of Puyallup and confluence with the Puyallup River in Pierce County. In 1991 the City, in cooperation with Pierce County, began weed cutting operations to reduce the volume of the overgrown native elodea in an effort to reduce localized flooding to stream-side properties caused by the large volume of elodea. The process currently includes an annual single cutting and removal of the weed; in past years there have been two cuttings per year. However, the process creates measurable turbidity in the creek and the cut-and-float method causes the elodea to break up and allows it to replant in the high-sediment creek bottom as it floats down the creek to the collection point, thus propagating the weed. In July 2011, the City, in cooperation with the Puyallup Tribe of Indians, initiated a pilot project to hand pull the elodea weed from a test section of Clarks Creek. The pilot project location began at the 7th Ave SW Bridge and extended 605 feet to the south. A total of 25 volunteers worked in shifts over 5 days to complete the hand pulling operation. Approximately 30 cubic yards of weed were removed throughout the project. The test section of creek will be monitored over the next year to determine the effective removal rate and rate of re-growth. If the hand-pull method proves successful, the operation could be expanded to cover the entire 3-mile weed management project area. This approach by the City could potentially reduce the impact of the weed management on the Tribe’s fish hatchery operations on the creek by entering the creek only once every 3-5 years versus the current up-to-twice-a-year mechanical cutting operations. In addition, implementation of the hand-pulling as a full-scale project may reduce annual management and contracting costs to the City, as well as reduce the flood potential of the creek due to the elodea with a long-term goal of eradicating the elodea from Clarks Creek. ---PAGE BREAK--- 2 I P a g e Background Clarks Creek Elodea The headwater of Clarks Creek is located in the City of Puyallup near Fruitland Ave E and Highway 512 and includes Maplewood Springs. Indicators suggest that flooding of the creek during the growing season has been an issue for many decades. There are indications that Pierce County dredged the creek in 1958. Due to the low gradient of the creek, dredging was most likely horizontal, not vertical. A study later completed by Parametrix confirmed this as an effective way to dredge Clarks Creek. The elodea weed has been present in excessive volumes for many years. Weed cutting began in 1991, most likely the result of the 1990 Thanksgiving Day flood events. The first contractor utilized equipment which damaged the creek bed and caused turbidity in the stream. Fish were actually being extracted from the water during this process as well. In 1994 the City purchased a custom-fabricated platform boat to access and cut the elodea weed. The material was cut, and then allowed to float to a collection point. Initially, City and County staff performed the annual cutting operation work. Beginning in 1995, the Lichty property, located at 5603 66th Avenue E, was leased to allow for better access to the creek as a launch and removal site for the boat, as well as serving as the extraction point for the cut weed material. Many complaints were received by the City in 1997/1998 from creek-side property owners that the once-per-year cutting was not sufficient to reduce the flood potential. As a result, the operation transitioned to a twice-per-season cutting project. The work was contracted out at this point since the workload became too much for staff to handle along with existing duties. Since this time, two Total Maximum Daily Loads have been developed for Clarks Creek; one to address the high levels of fecal coliform (FC), a second to address the low levels of dissolved oxygen (DO). Both site excessive vegetative growth, specifically the elodea, as a significant contributing factor to the water quality problems. Reduction in the overall amount of the elodea in the creek will contribute to improved water quality and an increase in dissolved oxygen to healthy levels. Physical removal of the weed from the creek provides an effective short-term approach to reducing the volume of elodea. Three main factors contribute to the excessive elodea growth in Clarks Creek: excessive sunlight due to lack of natural riparian cover along many reaches of Clarks Creek; excessive levels of nutrients in the stream; and large volumes of fine sediments which promote rooting of the plant.1 1 Proper riparian planting along the creek can be supportive of the long term, sustainable goal of restoring Clarks Creek. Elodea thrives on sunlight - development of a canopy cover for the creek will not only reduce the sunlight and weaken the elodea, it will reduce its ability to spread, as well as reduce the temperature in the creek – another water quality indicator. Excessive elodea growth has been identified as a contributor to depressed dissolved oxygen levels in the stream due to the increase and excessive of sediment oxygen demand loading as well as increase in carbonaceous biochemical oxygen demand (CBOD). Figure 1 - Clarks Creek Elodea ---PAGE BREAK--- 3 I P a g e Riparian buffer planting on various stretches along the creek began in 2006 through coordinated efforts with Pierce Conservation District Stream Team. The initial planting project offered free planting to private homeowners, although none agreed to participate. The plantings were thus contained to Clarks Creek Park, but where soon-after removed by Parks maintenance crew by accident. Subsequent riparian buffer planting along Clarks Creek has been done over the years through both City-lead efforts to provide creek-side property owners with free plants and installation, as well as efforts by WSU-Puyallup on property they own on the creek. A few private homeowners have taken the initiative to plant on their own, and frequently support City efforts related to improving the creek’s overall health and sustainability. In 2009, weed cutting returned to a once-per-year operation due partially to cost versus effectiveness, and partially to a shorter fish window imposed by the Puyallup Tribe. The Puyallup Tribe narrowed the fish window to more closely approximate when fish are expected in the stream. The resulting shorter time frame made a second cutting less effective since there was not a long enough period between cuttings to allow any significant growth of the Elodea. In 2010, the City again reached out to creek-side property owners and offered an educational workshop on riparian buffer planting. Only four people registered so the class was canceled. Interest and cooperation with creek-side property owners has remained limited and sparse, but the City and Pierce Conservation District Stream Team continue to offer free riparian planting for stream-side owners when opportunities arise. City efforts to address creek-side property owners’ impact on the health of the creek include a commitment to focus the Rain Garden Program in creek-side neighborhoods when possible. In addition, riparian planting is included in the program’s installation events whenever participation can be garnered. During the September 2011 rain garden installation, three property owners initially agreed to include riparian planting on their creek-side property. Regrettably, two of the homeowners backed out at the last minute during the week of installation - leaving only one home participating in the riparian planting effort. Hand-pulling Success The Chehalis River, located in Thurston County jurisdiction, served as a precedent for this pilot project as a successful project site for effective removal of invasive weeds2 Developing the Pilot Project . The final project report produced by Thurston County, Chehalis River Egeria densa Control, indicates that biomass removal in 2010 decreased 78.8% from 2009 levels. Initial hand-pulling operations began in 2006, with refinements to the pulling method applied during subsequent harvest years. During development of the Clarks Creek Pilot Project, Mark Palmer, Puyallup Stormwater Engineer at the time, discussed with the Thurston County Project Manager the success of their project. He confirmed the effective removal and reduced re-growth indicated in the report, citing a complete removal of the elodea root ball as the key to effective removal. When developing the scope of the pilot project the City contacted the Department of Fish and Wildlife to consult on the proposed project, as well as gain input and confirmation of required permit documentation required. A Hydraulic Project Approval (HPA) was issued by Fish and Wildlife, allowing the City to conduct hand pulling operations3. In addition, a SEPA checklist was completed and submitted4 An amendment to the existing Shoreline Substantial Development Permit that governs the mechanical cutting of the elodea weed (originally issued in 2007) was requested by the Stormwater Department . 56 as well as . Included in the application request materials was a Joint Aquatic Resources Permit Application (JARPA) which required the City to establish agreement with the joint property owners ---PAGE BREAK--- 4 I P a g e located within the project area7 Project Scope . Signatures were subsequently collected from the homeowners whose property was located within the pilot project area; granting the City permission to implement the work on the half of the creek located on their property. The project area was preliminarily selected as the area beginning south of the 7th Ave SW Bridge, and extending up to 950 feet south8 Based on a test pull in the creek and the observation of intertwined species of weeds among the elodea, the City, Tribe, and Fish and Wildlife agreed to remove all weeds, including the invasive curly leafed pond weed and water starwort from the project area. . The area cleared would depend upon the amount of work that could be reasonably completed during a maximum of five days. The project would be implemented at the same time as the mechanical cutting operations. The project location was selected due to the ease of access to the creek, relatively shallow depths to allow wading versus divers, as well as being upstream of the mechanical cutting operation – so as to minimize contamination from the cut material. Turbidity sampling carried out within the mechanical cutting project area would be expanded to include twice- per-day sampling 200 feet of the hand-pulling project area. This was intended to allow for a comparative analysis of the sediment disturbance created by the two different methods. The City and Puyallup Tribe proposed soliciting volunteers to perform the in-stream work to pull the weeds. Four to eight volunteers were desired for each day of work. Given the depth of water within the project area, weeds would be hand- pulled where possible, and removed with the use of pickle forks in deeper locations. As they were pulled weeds were to be placed on a floating platform located near the volunteers in the water and then transported to the shore, and transferred into a staged dump truck. Photographic documentation would be done prior, during, and after the project to visually record the amount of weed removed from the creek (see Efficiency of Removal in Results and Discussion for photographs). Methodology The first in-stream day was Monday, July 18, 2011. The Project Manager, Mark Palmer, provided a brief overview of the project and history of elodea to the observers and eleven volunteers present as well as emphasizing the need to work in pairs when in the water for safety. The City provided dry suits, neoprene water socks, and gloves for volunteers without their own equipment. Once dressed in the appropriate gear, the volunteers entered the creek just south of the 7th Ave NW Bridge. As the people walked on the creek bed, sediment was stirred up, causing reduced visibility. As a result, the teams worked in a single row across the width of the creek, so that upstream work would not affect those workers The depth of the water at the initial entry point was over three feet deep, so pickle forks were used to grab and pull the weeds up to the surface. Two inflatable tubes with mesh coverings were used to place the weed material on top of as it was pulled Figure 2 - Curly leafed pond weed ---PAGE BREAK--- 5 I P a g e from the creek. To reduce turbidity in the water, volunteers were asked to not ‘rinse’ the weeds, but instead place the entire clump, including any sediment, on the tube. When a tube became full with a pile of weeds, the tube was taken to the shore and lifted by four people at a time up the bank to a staged dump truck. The wet material was very heavy, and the tubes retained water. This made lifting the tubes the four feet up to the truck bed difficult and awkward. After the first three loads were emptied in this manner, subsequent loads were manually unloaded, picking up armfuls of the weed, and placing it in the dump truck. During the lunchtime break, a City backhoe with a front-end loader was brought to the project site. The bucket end was positioned as near the shore as possible. When the weed pulling resumed, the loaded tubes were brought to the shore and the material was manually placed in the bucket. When the bucket became full, the backhoe dumped it into the bed of the dump truck. This method was much easier than the previous porting of the tubes up the bank. The dump truck loads were emptied daily at the City Corporate Yards facility and allowed to dry before disposal as yard waste. Improper use of the dry suits on the first day caused several suits to leak, leaving some volunteers partially or completely wet underneath the suits. It was determined that the rubber seals around the neck, wrists, and ankles needed to be smooth against the skin, and away from any un-even surfaces – such as the ankle bone – to create a proper seal. Some volunteers used chest waders instead of dry suits and found them to be warmer because their feet remained completely dry and thus warmer. When wearing the chest waders, however, it was necessary to avoid leaning over too far, else water would enter the top. Also, one worker did fall over in the water (as was common occurrence due to lose footing in the soft sediment bottom) and became completely soaked because they were wearing chest waders. During the first in-stream day, eight volunteers worked in the stream, with the remaining volunteers located on the shore to ‘slop’ the weeds into the backhoe bucket. Subsequent work days had fewer volunteers, with only four volunteers total on Day 4. For in-stream day Nos. 2-5, the volunteers began at the beginning point from the previous day, and re- covered the area from the previous day, to remove any material missed on the initial pass. Results and Discussion Hand-Pulling Process Throughout the five in-streams days during the project week, 25 volunteers worked to pull weeds9 The area covered by the project began on the south side of the 7th Ave SW Bridge, and extended 605 feet to the south. The average rate of work was 4.2 linear feet/hour. Some sections of the creek were as wide as 50 feet, while the most-narrow section was only 20 feet, making a linear progression along the creek less quantitative than a volumetric measurement. The total volume removed was approximated by the capacity of the dump truck and number of loads removed: 30 cubic yards. This equates to 5.6ft3/hr. The map in Figure 3 details the daily progress of area covered and Table 1 approximates the daily progress, volume removed, and work-hours. . Some volunteers worked on multiple days, while some participated for one day. In total approximately 160 work-hours were dedicated to the weed-pulling. ---PAGE BREAK--- 6 I P a g e Figure 3 - Daily Work Progress In-Stream Day 07/18/2011 7/19/2011 7/20/2011 07/21/2011 07/22/2011 Total Total No. of volunteers 12 5 6 4 6 25 individuals Total Work- hours 45 18 24 24 34 145 hours Distance cleared (ft) 125 90 130 180 80 605 feet Volume Removed ( yards3) 5 5 5 10 5 cubic yards Table 1 – Project Work Data Some sections of the stream were too narrow to accommodate all volunteers in a straight line across. However, having a larger number of volunteers was very advantageous in the wider sections of stream, so they could cover the area move effectively without each person having to move left-and-right a great distance; again reducing the impact from disturbing the creek bed. At absolute minimum, it was determined that four workers are needed at a single time, with eight determined to be the maximum, productive group size. The average water temperature in the creek during the project week was 42 ⁰F. Accounting for the temperature, in combination with the physical effort required for the weed-pulling and hauling, it was determined that 2, 3-hour shifts was the maximum for a single volunteer in one day. Alternatively, a ---PAGE BREAK--- 7 I P a g e single 4-hour shift was also deemed appropriate. If the work to be performed by trained, specialized, or otherwise appropriately-tasked personnel, 2 ea. 4-hours shifts per day could be used. Equipment The equipment used for the project included: • pickle forks* • dry suits* • chest waders • neoprene water socks* • neoprene gloves* • inflatable, mesh-covered tubes • anchors • backhoe • dump truck *purchased equipment Goggles were purchased in anticipation of the need to go below the water surface for visibility reasons, or in deeper sections of the creek. However, due the localized turbidity created by the pulling, it was determined to be unnecessary to go under the water. The purchased equipment noted above totaled $3,282. The tubes and anchors were on-loan to the project, but would have a cost of approximately $150 per tube, and $30 per anchor. The dump truck and operator were provided by the City as part of the regular course of business. Efficiency of Removal Mechanical operations removed, on average 4.4 cubic yards of material per day during the 2011 cutting season with a total of 92 cubic yards over 21 days10 Thus, the mechanical cutting must be performed every season. Based on the Thurston County project report, the need for weed removal and management is reduced from an annual operation, to removal once every 3-5 years – diluting the overall cost of weed management. . Comparatively, the hand-pulling operations removed 6 cubic yards per day, for a total of 30 cubic yards over 5 days, utilizing 29 work-hours total. The hand-pull operations covered 605 feet of stream, for an average of 1.3 ft3 of weed removed per linear foot of stream. Comparatively, the mechanical cutting operation removed only 0.186 ft3 of weed per linear foot of stream, only 15% of the volume per linear foot removed by hand pulling. The effective removal rate of the hand pulling operation is estimated at approximately 95% over the entire project area. Implementation of a shallow-diving operation could achieve 100%. Equipment limitations prevented a 100% removal rate. In addition, the cutting operation addresses the current elodea growth that is impacting the water levels of the creek, but does not remove the elodea plant completely, and instead leaves it to begin re-growing almost immediately. It is not only inefficient at collecting all the cut weed mass, but it also generates cut material which actually spreads the weed further as the cuttings re- plant in the creek’s heavily sediment bottom. Water Quality Records of water-level readings were recorded throughout the mechanical cutting project. In addition, water quality samples were taken and analyzed for turbidity. The samples were generally taken in the morning, before cutting operations commenced and again in the afternoon, mid-way through the day’s cutting. The photos below depict the relative, visual turbidity created by the two separate processes. ---PAGE BREAK--- 8 I P a g e Figure 4 - Comparative visual observation of turbidity – actual data listed in Table 3 Sample locations were at the nearest bridge from the current cutting activity. This distance ranged up to 3,500 feet from the current cutting operations. During the hand-pulling operation, water samples were taken twice daily, approximately 200 feet of the current location of the volunteers and also analyzed for turbidity. The tables below summarize gage height data readings as well as the daily turbidity recorded (in nephelometric turbidity units, NTU’s) during the mechanical cutting process. The Location noted in the turbidity tables indicates the location (FT) of the current cutting process from the sample collection point (bridge). The five hand-pulling project days were 07/18/2011-07/22/2011. Day No. 1 2 3 4 5 6 7 Date Read 07/05/11 07/06/11 07/07/11 07/08/11 07/11/11 07/12/11 07/13/11 Tacoma Rd Bridge 20.15 20.07 20.06 20.18 20.12 20.15 20.17 12th Ave SW 23.46 23.45 23.49 23.47 23.52 23.58 23.61 Day No. 8 9 10 11 12 13 14 Date Read 07/14/11 07/15/11 07/18/11 07/19/11 07/20/11 07/21/11 07/22/11 Tacoma Rd Bridge 20.12 19.79 19.59 19.67 19.79 19.78 19.65 12th Ave SW 23.62 23.60 23.64 23.63 23.68 23.65 23.64 Day No. 15 16 17 18 19 20 21 Date Read 7/25/11 07/26/11 7/27/11 7/28/11 7/29/11 7/30/11 8/01/11 Tacoma Rd Bridge 19.83 19.76 19.7 19.67 19.66 Job done 12th Ave SW 23.98 23.68 23.65 23.65 23.65 Job done Table 2 - Gage Height Data (FT) ---PAGE BREAK--- 9 I P a g e Day No. 1 2 3 4 5 6 7 Sample Date 07/05/11 07/06/11 07/07/11 07/08/11 07/11/11 07/12/11 07/13/11 Sample Time AM 0730 0740 0830 0739 0825 0720 0720 PM 1535 1445 1340 1520 1400 1500 1500 Location (Bridge) 0’ - 56th St E 0’ - 56th St E 0’ - 56th St E 0’ - Tribal Hatchery 300’ – 60th St E 900’ – 60th St E 0’ - Stewart Ave E Trestle Turbidity Result (NTU) AM 1.9 2.2 3.6 2.7 3.5 3.0 6.4 PM 2.6 2.8 5.9 10.1 94.2 46.5 31.1 Daily Qty Weed Removed (CY) 0.25 0.25 1.0 5.0 3.0 5.0 4.0 Day No. 8 9 10 11 12 13 14 Sample Date 07/14/11 07/15/11 07/18/11 07/19/11 07/20/11 07/21/11 07/22/ 11 Mech Hand Mech Hand Mech Hand Mech Hand Sample Time AM 0730 0730 0830 1030 0745 0900 0800 0830 0730 0930 - PM 1500 1415 1340 1420 1420 1400 1345 1315 1500 1400 - Location (Bridge) 2300’ – Stewart Ave E Trestle 2500/300 0’ – Stewart Ave E Trestle 0’ – Taco ma Rd 0/25 0’ 7th Ave SW 400/12 00’ – Tacom a Rd 150/1 70’ – 7th Ave SW 1300/ 1600’ – Taco ma Rd 170/ 180’ 7th Ave SW 2000/ 2500’ – Taco ma Rd 230/35 0’ – 7th Ave SW - Turbidity Result (NTU) AM 6.4 3.4 2.3 2.0 9.0 1.9 21.6 1.1 3.4 2.9 - PM 20.9 7.8. 28.7 25.8 55.9 2.3 19.2 7.9 42.4 21.8 - Daily Qty Weed Removed (CY) 6.0 5.0 8.0 5.0 8.0 5.0 6.0 5.0 10.0 10.0 - ---PAGE BREAK--- 10 I P a g e Day No. 15 16 17 18 19 20 21 Sample Date 7/25/11 07/26/11 7/27/11 7/28/11 7/29/11 Job Done Sample Time AM 1030 0720 0735 0705 0720 Job Done PM - 1300 1500 1525 1100 Job Done Location (Bridge) 3500’ – Tacoma Rd 3500’ – Tacoma Rd 0/200’ - Pioneer Ave 200/1800’ – Pioneer Ave 1800’- Pioneer (AM) DeCoursey Park (PM) Job Done Turbidity Result (NTU) AM 9.3 3.4 2.9 2.2 8.4 Job Done PM - 26.3 16.3 25.8 2.2 Job Done Daily Qty Weed Removed (CY) 0.5 8.0 4.0 8.0 2.0 Job Done Table 3 - Turbidity Data (Reported in NTU’s) The Tribe was asked to report any noticeable increase in turbidity or floating material in the water at the hatchery location during the hand-pulling efforts. By this time, the mechanical cutting was already upstream of the hatchery, but the expected turbidity from the mechanical cutting was already known. Char Naylor provided verbal reports from hatchery staff that no noticeable change in the water quality was noticed during the hand-pulling efforts. The movement and walking of the volunteers in the creek caused localized visually noticeable- turbidity in the water. However, given a short period of time – approximately 15 minutes – the waters returned to a transparent state. Recommendations Post-project Assessment The hand-pulling operation was conducted in July 2011 during the growing season. Inspection and documentation of the pilot section of the creek will be done near the end of the growing season, in late September to mid October and again in spring. An addendum to this report will be produced to describe and discuss findings and analysis of the re-growth at that time as well as recommend further action. Interim Findings: Observations were made of the pilot project area in September. Observations were qualitative and not quantitative in nature, however, it appears: 1. Weed removal is more complete south of the 7th Ave SW bridge (pilot project area), than north of the 7th Ave SW Bridge (mechanical cutting). 2. Weed removal persistence in the pilot area varies widely. ---PAGE BREAK--- 11 I P a g e 3. There hasn’t been significant mobilization of sediment with the removal of weeds and roots to date. The variation on the persistence of removal is an issue to be addressed. Some likely contributors to the variation were likely skill of the volunteers, depth of the creek and techniques. Transport of weed material not related to the weed control effort could be contributing as well. During the observation, it was noted that significant amounts of weed material were continuously traveling without any known activity upstream. Planning for full-scale operations Labor Based on the rate of work from the pilot project which utilized volunteer labor, hand-removal of elodea over the 3-mile length of creek currently managed by the mechanical cutting method, would require 3,800 work-hours to complete using current methods. This is based on a 4.2 linear foot/hour work rate. This equates to ten 4-person volunteer crews working two 3-hours shifts for 16 days. Crews would need to be spaced about 1,500 feet apart to reduce turbidity impacts to their efficiency. Alternatively, a single, 8-person volunteer crew working similar shifts would require 79 days to complete the 3-mile project. The working window for 2011 hand-pulling was 5 days. A similar window can be expected for future operations. While the work-effort required would be substantial, the labor expense using volunteers would be zero. The volunteers were outfitted in either dry suits or chest waders. For those in dry suits, the rubber seals at the neckline allowed them to reach into the water in more shallow sections, and hand pull weeds that were more firmly rooted. However, those using chest waders were limited on hand pulling due to the open top of the waders. Therefore, the recommended equipment would be the dry suits, but with improved foot wear. The dry suits leave the feet completely exposed. The cold water temperature makes the tolerance of the volunteer’s feet to the cold a limiting factor for length of time in the water. Fully closed, sealed dive boots would be recommended to provide more protection. Procurement of this volume of volunteers for a full-scale project would require significant coordination with external groups. Such groups would be the Puyallup Tribe, Pierce Conservation District Stream Team, Puyallup River Watershed Council, Citizens for a Healthy Bay, local Boy Scout troops, other civic organizations, and individual volunteers. Initial suggestions to use inmate labor were rejected by the Washington State Corrections Department due to safety issues. Alternatively, this work could be contracted out, similar to the current mechanical operations. Assuming similar production rates, the weed pulling labor alone would exceed $152,114. Accessibility The specific pilot area was selected due to the relatively shallow waters. Nearly every section of the project area was reachable with tools used by the volunteers. However, the entire 3-mile project area that is currently managed by boat includes many areas that would not be accessible on foot, and would require shallow diving. In addition, there are many stretches of the creek that are inaccessible from shore. Crews would need to enter at one location, and be confined to the creek for several thousand feet at a time. In addition to safety, and accessibility concerns, this would create the need to develop an alternative method for transferring the weeds to shore, as opposed to the method used in the pilot project. If float tubes remained the platform of choice to place the pulled weeds on, a fleet of floats could be used. ---PAGE BREAK--- 12 I P a g e When a float was full, it could be released, and allowed to float to a collection point to be unloaded. More practically, a boat could be used to collect and transport the material to collection points. The use of boats, however, would likely be a limiting factor in the number of crews able to work the stream at one time. Also, at least one haul out location on each side of impassable bridges would be needed to eliminate transfer full boats past these obstacles (Tacoma Road “Fishing Lady” Bridge, 7th Ave SW Bridge). Current haul out sites at WSU Puyallup, Sterino Farms, and Litchy property, would be adequate for sites north of 7th Ave SW Bridge. A new site inside Clarks Creek Park near either the 12th Ave SW or 7th Ave SW bridges would work for that stretch. Improving the Process The current method to transfer the weeds from the floats to the shore is extremely labor intensive. Future efforts could employ the use of equipment to lift specially-designed transfer platforms or nets from the water to load into the dump truck. This would reduce the work-hours needed, and increase the effective productivity of the workers to remove the weeds. Another alternative transfer process could include a conveyor system that could transport the weeds from the shore to the dump truck. This process, however, would still require the double-movement of the weeds: first onto the float, then onto the conveyor belt. For the pilot project, the volunteers did not venture completely underwater to pull the weeds. Instead, weeds were hand pulled in the infrequent areas of more shallow water, where reachable, and pulled with the use of a pickle fork in a majority of the project area, where the water was three (waist-level) or more feet deep. Hand pulling was noticeably more effective, but is not practical with volunteer efforts, and with workers outfitted in only dry suits. As a result, each section was re-covered on subsequent days to create more effective removal rates, and to pull weeds that were missed on previous passes. This contributed to a slower-than-desirable rate of work. A snorkeler or diver working off the bottom with neutral buoyancy might be much more efficient at weed collection (approaching the less than 3 foot depth efficiency) in depths over 3 feet due to higher visibility. With the use of ‘surface pullers’, it would be recommended to utilized a more effective removal tool that would better “grab” and clamp down on the weed to effectively pull it and the roots. This method would also present the potential for the process to be completed by crews from within a boat, utilizing a long enough tool handle. Commercial Divers The Thurston County weed removal project utilized commercial dive teams to complete the work in this larger-scale setting. Use of commercial divers for the Clarks Creek Project would potentially allow for two, 4-hour shifts per diver, at a rate expected to be four times that of the volunteers in the pilot project. The faster work-rate would be attributed to the neutrally buoyant, horizontal orientation of the diver in the water, reducing disturbance of the creek bottom, and maintaining/increasing visibility. In addition, divers would use a vacuum tube (suction dredging machine, by name) to which they would lift the hand-pulled the weeds, versus carrying the pulled material, by hand, to the surface. This would result in the use of a 6-person crew, working two, 4-hour shifts, for 20 days. The estimated expense for labor using commercial divers would be $11k-$35k. Additional cost for shore crews and disposal equipment would be in addition, as well as initial procurement of equipment such as boats and tools. Still, comparing this to an approximate cost of $87k for a single mechanical cutting operation, there is potential for a reduction in cost for management of the elodea. Additionally, the hand-pulling is anticipated to create a need to pull the weeds only once every 3-5 years once a high level of removal is achieved, further diluting the cost of weed management. ---PAGE BREAK--- 13 I P a g e Initial equipment costs would need to be considered when analyzing the cost-savings of the hand-pulling method in the Clarks Creek Elodea management area. As discussed in the Thurston County Report, the diver-crew operations use equipment in addition to dive gear such as a pontoon boat and suction dredge equipment. Additional costs would include disposal of the weed material, storage of the dive- related equipment, and delivery/removal of the equipment to the project site. The City should meet with Thurston County to view their equipment and obtain more information about it, including estimated costs. Moving Forward It is anticipated the City will expand the hand pulling operations of the elodea for the 2012 weed management season. A budget request has been made in the 2012 budget for $45,000 for equipment related to the hand pulling for next season. This may include the purchase of equipment such as boats, and tools as well as proper equipment for laborers. Further exploration into the effectiveness of the 2011-pilot section may include the use of divers to examine the effective removal and re-growth rates up-close. Early 2012 will include planning and data gathering sessions with Thurston County for comparative-planning analysis, meetings with the Puyallup Tribe for coordination of efforts and work windows, as well as review and development of any necessary permits for the expansion of the pilot project. The results of the 2011 pilot project indicate that an additional 1800 feet of creek could reasonably be targeted for a 10-day project. In addition, the 605 feet of creek hand-pulled in 2011 could be re-visited and any removed weed would be quantified to gain a comparative effective re-growth rate from the previous year’s hand-pull operation. The need for volunteers and the level-of-effort is now more closely understood, there is more time to recruit and recruitment efforts will be able to properly address the need. Additional volunteers, however, will require additional funding to procure appropriate equipment including dry suits, footwear, tools, and other equipment as suggested above that may increase the efficiency of the process. In addition, research of the depths within an expanded project area would need to be determined prior to establishing the specific project area. Similar to this year, permits will be required including a SEPA Checklist, Shoreline Substantial Development Permit, and an HPA and JARPA, for which signature will need to be collected from all homeowners with property within the project area. Coordination with mechanical operations will include a reduction in the mechanically cut project area as well as communication to ensure that hand-pulling efforts do not interfere with the cutting. Whether proceeding with only mechanical weed cutting, or expanding the hand-pulling operations, the City will ensure continued coordination with the Puyallup Tribe to limit the interference of the management operations with the hatcheries and release windows. ---PAGE BREAK--- 14 I P a g e Citations 1 Clarks Creek Draft Allocations Memorandum. Draft TMDL allocations that address dissolved oxygen (DO) impairments in Clarks Creek. Draft date: September 28, 2011. 2 Final Project Report for Agreement Number: G0900221 – Chehalis River Egeria densa Control, October 22, 2010. 3 Hydraulic Project Approval. Control Number 124087-1. Issued date: July 7, 2011. Project Expiration date: September 30, 2013. 4 Environmental Checklist. Clarks Creek Elodea Hand Pulling Pilot Project. Prepared date: June 22, 2011. 5 Administrative Determination Use of Existing Shoreline Substantial Development Permit for Clark’s Creek Seasonal Weed Abatement – 2011 Pilot project City Case No. 07-33-001. Issued date: July 13, 2011. 6 Addendum to Previously Issued Determination of Non-Significance (DNS) for City of Puyallup Case No. #07-31- 027. Issue date: June 28, 2011. 7 2010 WA State Joint Aquatic Resources Permit Application (JARPA) Form; Clarks Creek Elodea Hand Pulling Pilot Project. Prepared date: June 22, 2011. 8 Clarks Creek Aquatic Weed Harvest Location Map including detail of pilot project area. Drawn date: June 2, 2011. 9 Summary of volunteer sign-in sheet for pilot dates: 07/18/2011-07/22/2011. 10 2011 Clarks Creek Weed Cutting Project. City of Puyallup summary report. ---PAGE BREAK--- Memorandum To: Jenny Wu Date: September 29, 2011 (revised) From: J. Butcher Subject: Clarks Creek Draft Allocations cc: Char Naylor, Cindy James Proj. No. 100-FFX-T94261 This memorandum presents draft TMDL allocations that address dissolved oxygen (DO) impairments in Clarks Creek. The DO impairments in Clarks Creek are the result of complex biological interactions driven by a variety of external factors, including  Urban runoff associated with impervious areas, which carries sediment and organic solids loads that increase sediment oxygen demand (SOD) and reduce DO in storm drainage, reducing the average DO. Urban runoff also causes increased channel erosion in the headwaters, further exacerbating sedimentation  Nutrient (phosphorus) loads in urban runoff, which helps promote elodea nuisance growth, in turn enhancing siltation, contributing to SOD and reducing reaeration. Sediment loads also promote elodea biomass accumulation, because they provide a favorable substrate for elodea growth. Excess elodea growth results in diurnal DO depression.  Lack of riparian cover increases solar radiation that promotes elodea growth and also elevates water temperature, resulting in decreased DO saturation concentrations and reduced DO. In order to consider and evaluate these complex biological interactions, a QUAL2Kw model was developed to estimate the pollutant reductions needed in Clarks Creek to achieve water quality standards for DO and dissolved gases. The following load allocations are established in the TMDL: reduction in SOD; control of elodea density; maintenance of DO concentrations in tributary inflow; and riparian shading targets. The wasteload allocations are a reduction of geomorphically significant flows, allocations for reduction in flows in stormwater conveyances and peak flows. The wasteload allocations expressed as flow are intended to be used as the basis for developing the City and County MS4 NPDES permits to the maximum extent practicable that the City and County can meet these targets. These allocations were developed using the water quality model to estimate the “DO deficit” (DOD) required to meet water quality standards throughout Clarks Creek. DO deficits are a way that loads on DO can be expressed as a daily load, which is required by EPA. The DOD is the difference between the concentration of DO at saturation (DOsat) minus the ambient DO concentration. Note that DOsat is the natural equilibrium condition for DO, so it represents the natural concentration of DO with no DO- depleting sources. The water quality standard for DO in Clarks Creek is 9.5 mg/L. Therefore, the loading capacity for DO is the allowable DOD in Clarks Creek, which is DOsat – 9.5 mg/L. This can be converted to a DOD load expressed as kg/day, consistent with TMDL regulations, by multiplying the flow and using a conversion factor. DOsat varies with water temperature (and salinity and atmospheric pressure), so the 3200 Chapel Hill-Nelson Hwy, Suite 105 • PO Box 14409 Research Triangle Park, NC 27709 Tel [PHONE REDACTED] • Fax [PHONE REDACTED] ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 2 maximum loading capacity of the stream is variable. Lower temperatures increase DOsat, and higher temperatures decrease DOsat. Therefore, with lower water temperatures, there is higher loading capacity. Ideally, ambient DO concentrations would be as close to DOsat as possible, so that the DOD would be zero, or close to zero. A positive DOD indicates a shortage of DO, while a negative DO indicates a surplus, as may occur during active by algae. Establishing DOD levels - rather than focusing on individual pollutants, such as phosphorus or temperature - is useful because it allows for the direct comparison of a variety of external sources low DO in groundwater discharge, CBOD loads) and internal sources algal macrophyte respiration, SOD). The DO deficit approach also establishes numeric “maximum daily loads” that are comparable and additive. DOD does not, however, provide a very convenient basis for allocating loads to individual upland sources, hence the development of shade and flow allocations, which will inform permitting and implementation planning. The wasteload allocations expressed as flow are intended to be used as the basis for developing the City and County MS4 NPDES permits to the maximum extent practicable that the City and County can meet these targets. In the following pages, Section 1 provides a summary of the complex factors that lead to DO impairment in Clarks Creek. Sections 2 and 3 describe the general approach to the TMDL and the specifics of developing allocations based on DO deficit in more detail. Sections 4 and 5 present the analysis of assimilative capacity for DOD under baseflow and stormflow conditions, respectively. Section 6 describes the TMDL allocations. Section 7 summarizes and load and wasteload allocations. 1 Conceptual Model of DO in Clarks Creek DO concentration in Clarks Creek is the net result of a series of complex processes, including reaeration, oxidation of carbonaceous and nitrogenous BOD in the water column, sediment oxygen demand (SOD), the DO concentration in tributary and groundwater inflows, and algal and respiration. Reaeration rate is a function of both the ambient DO concentration in water and the saturation concentration, which in turn varies with temperature (and salinity and atmospheric pressure). For this reason, it is most convenient to analyze DO problems in terms of the DO deficit (DOD), which is the difference between the saturation DO concentration and the ambient concentration. A positive DOD indicates a shortage of DO, while a negative DO indicates a surplus, as may occur during active by algae. The importance of different stressors and processes in controlling DO in the system was explored through applications of Ecology’s QUAL2Kw model to a series of individual well-monitored dates. Results of this work were reported in Clarks Creek Dissolved Oxygen TMDL and Implementation Plan, QUAL2Kw Modeling (Tetra Tech, February 3, 2011). An updated version of the previously developed conceptual model of DO in Clarks Creek is presented in Figure 1. As in previous iterations, the heavier lines represent pathways that are believed to be of greater importance to the DO impairment; these have been modified and updated based on the results of the QUAL2Kw modeling. Current understanding suggests the most significant risk pathways, interlinked with one another, are as follows:  Urban runoff associated with impervious areas carries sediment and organic solids loads that increase SOD and reduce DO in storm drainage, reducing the average DO.  Nutrient loads in urban runoff help promote elodea nuisance growth, which in turn enhances siltation, contributes to SOD and reduces reaeration. Sediment loads also promote elodea growth, because they provide a substrate for elodea to grow. Excess elodea growth results in diurnal DO depression. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 3  Increased urban runoff also causes increased channel erosion in the headwaters, further exacerbating sediment effects  Lack of riparian cover increases solar radiation that promotes elodea growth and also elevates water temperature, resulting in decreased DO saturation concentrations and reduced DO. The simplified conceptual model shown in Figure 2 summarizes these key contributors to the DO impairment. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 4 Figure 1. Updated Conceptual Model for DO Impairment in Clarks Creek Water With- drawals Increased Impervious Area Urban Runoff Hatchery Discharges Lack of Riparian Cover Elodea nuisance growth Respiration Depletion of DO Reduced Infiltration Reduced Baseflow Reduced Flow Velocity Reduced Reaeration Nutrients Solids Organic Material Siltation SOD Reduced Average DO Thermal Load Elevated Water Temperature Decreased DO Saturation Concentration Impaired DO Nutrient Regeneration Stressors Processes Impacts Increased Sunlight Spring Discharge Nitrate Load in Springs Reduced DO in Springs y Reduced DO in Storm Drainage ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 5 Figure 2. Simplified Conceptual Model for DO Impairment in Clarks Creek 2 TMDL Approach The atmosphere is the primary repository of elemental free oxygen. The concentration of dissolved oxygen (DO) in water is strongly affected by exchange processes with the atmosphere. If the water and atmosphere are allowed to come into equilibrium (that is, if the oxygen content of the water is not perturbed by other sources and demands), a fixed level of oxygen for a given temperature (and salinity and atmospheric pressure) will be reached. This level of oxygen is known as the saturation concentration or DOsat. If they DO concentration in water is less than DOsat, then a flux of oxygen will occur from the atmosphere to the water (reaeration). On the other hand, if they DO concentration in water is greater than DOsat there will be a net flux of oxygen from the water to the atmosphere (degassing). The value of DOsat declines with increasing water temperature. For instance, at 10° C (and standard atmospheric pressure at sea level with zero salinity), the value of DOsat is 11.3 mg/L, but at 20° C the value of DOsat is only 9.1 mg/L. This tells us two important things. First, in order to achieve high Elodea Nuisance Growth Stormwater Reduced Shade Solids and organic material accumulation Elevated nutrient loads Increased sunlight Bacterial oxygen consumption (SOD) Algal Respiration Reduced velocity and reaeration Increased water temperature Reduced Dissolved Oxygen Stressors Processes Impacts ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 6 concentrations of DO in water it is essential to maintain low temperatures. Second, the capacity of a waterbody to assimilate loads of pollutants that affect the oxygen balance (the assimilative capacity) varies as a function of water temperature: At 10° C it would be permissible to add pollutants that depress the DO concentration from saturation by 1.7 mg/L and still meet a DO criterion of 9.5 mg/L. However, at 15° C, the difference between DOsat and a DO criterion of 9.5 mg/L is only a little over 0.5 mg/L. Thus, the assimilative capacity for oxygen demanding pollutants (or other processes that deplete dissolved oxygen) declines with increasing temperature. Deviations from DOsat occur primarily as a result of biochemical oxidation (which depletes DO) and (which creates DO). Biochemical oxidation includes respiration for metabolism by plants, animals, bacteria, and fungi, as well as direct chemical oxidation, and occurs both in the water column (biochemical oxygen demand, or BOD) and at the sediment-water interface (sediment oxygen demand, or SOD). In natural, undisturbed streams with good shading, amounts of readily metabolizable BOD and SOD are typically small, while algal populations and are also low. Thus, exchange processes with the atmosphere are able to maintain DO concentrations near saturation. The equilibrium can be disturbed as pollutant loads increase – both directly through the addition of oxygen demanding substances and indirectly through pollutant loads that increase algal growth – and the ability of natural reaeration/degassing to keep DO at equilibrium concentrations with the atmosphere is impaired. In sum, the assimilative capacity for pollutants in a waterbody is a function of the difference between the natural concentration and the criterion concentration. For a criterion concentration of 9.5 mg/L DO, the assimilative capacity is defined as DOsat – 9.5 (or zero if the temperature rises to a point at which DOsat becomes less than 9.5). As noted above, the assimilative capacity (and thus the TMDL loading capacity, calculated as the assimilative capacity times flow) varies as a function of temperature, as summarized in Figure 3. Figure 3. Assimilative Capacity as a Function of DO Saturation The difference between DOsat and the actual DO concentration is known as the DO deficit (DOD). DOD is positive when the DO concentration is less than DOsat. Therefore, a high DOD indicates the presence of significant amounts of DO-depleting sources. It may also be negative, if DO concentration exceeds DOsat (as often happens during periods of active in dense algal mats), which indicates supersaturated conditions and may trigger the “not to exceed 110%” dissolved gasses criterion. The ideal situation is for DOD to be zero or close to zero. This would indicate the smallest deviation from the natural equilibrium level of DOsat. The different factors contributing to the DOD are, in general, additive 0 2 4 6 8 10 12 14 16 0 5 10 15 20 25 Water Temperature DO (mg/L) DO Criterion DO Saturation Assimilative Capacity ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 7 and thus provide a convenient basis for evaluating the relative importance of different factors affecting the oxygen balance. Like DO itself, DOD can be converted to a load basis by multiplying times flow: DOD (kg/d) = (DOsat – DO) x Q (cfs) x 2.447 In addition, the factors that disturb the natural DO equilibrium condition may not be easy to link to upland loading rates of specific pollutants. In particular, SOD rates arise as a function of loading and settling over time of organic material derived from the uplands and organic material produced in the stream by plant growth. DOD provides a convenient basis for a unified treatment of the different factors that alter DO in Clarks Creek. It is particularly useful for simultaneous consideration of factors that are directly translatable to upland loads BOD in stormwater) and those that have an indirect long-term relationship to upland loads SOD). DOD for individual dates can be analyzed using applications of the QUAL2Kw model, which evaluates the impact of each of the sources of DOD on the stream DO balance. Note that QUAL2Kw cannot be used to directly determine the complete relationship between upland pollutant loading rates and instream DO because it is a steady state model, whereas some of the major DOD components (SOD, elodea) depend on long-term loading and accumulation of organic solids and nutrients, much of which occurs during transient storm events. Full time series models of macrophyte growth and sediment diagenesis (including SOD) exist, but are largely experimental in nature and would require extensive data that are not currently available for Clarks Creek. 3 Developing Allocations for Clarks Creek The water quality standards for Clarks Creek allow a minimum of 9.5 mg/L DO throughout the mainstem1. Continuous monitoring shows frequent excursions of the criterion upstream of Tacoma Road, primarily in the early morning hours when elodea production is absent but elodea respiration is present. Water quality standards for Clarks Creek also contain a criterion for dissolved gasses, which shall not exceed 110 percent of saturation. Day time DO monitoring of Clarks Creek shows that the dissolved gasses limit is often exceeded due to intense production within elodea mats. A TMDL for Clarks Creek must satisfy both of these criteria. DOD levels have been developed to address both the DO criterion of 9.5 mg/L and the dissolved gasses criterion. DOD can be expressed in mass per time units kg of DO per day) and is therefore appropriate for the quantitative expression of a TMDL. Expressing the TMDL as DOD is useful because it allows direct comparison of a variety of external low DO in groundwater discharge, CBOD loads) and internal algal macrophyte respiration, SOD) sources. DOD does not, however, provide a very convenient basis for allocating loads to individual upland sources due to the complex pathways that give rise to instream conditions. Therefore, allocations have been developed in order to inform permitting and implementation planning. The general allocations that will support designated uses under both baseflow and stormflow conditions are reduction in SOD, control of elodea density, and maintenance of DO concentrations in tributary inflow. (CBOD and NBOD should also be controlled but constitute only a small fraction of the total DOD in Clarks Creek.) These factors are inter-related with one another:  SOD in the calibrated model represents bacterial respiration associated with dead organic material that may take place at the sediment interface or on material trapped within the elodea mats. Elodea contributes to SOD in both direct and indirect ways. First, high levels of elodea biomass production result in large stocks of organic material that eventually settle and decay. Second, the 1 The DO standard of Tacoma Road was previously 8 mg/L but was recently changed to also be 9.5 mg/L. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 8 overgrowth of elodea encourages the deposition to the sediment of additional organic material carried into the stream during storm events.  Elodea density is controlled by available light, substrate suitability, and nutrient supply. The available light depends on riparian canopy (in addition to self shading). Elodea prefers fine- grained organic substrates and propagates through overwintering and cuttings which attach themselves to fine sediments; thus the deposition of material that contributes to elevated SOD and the role of elodea itself in slowing flows and promoting deposition are factors that contribute to high elodea density. Finally, elodea, like all plants, requires nitrogen and phosphorus for growth. Inorganic nitrogen concentrations in Clarks Creek appear to be elevated well above levels necessary for limiting elodea growth due to long term nitrogen enrichment of ground water and control by reducing nitrogen does not appear promising. Phosphorus may be more important to limiting elodea as it tends to be associated with particles, does not have a large groundwater concentration, and is thus available in the water column only intermittently. Elodea, however, is a rooted macrophyte and is able to extract phosphorus from stream sediment. Thus the factors that contribute to fine sediment deposition and elevated SOD also contribute to a steady supply of phosphorus that supports elodea growth. The fine sediment that creates habitat suitable for elodea likely derives from both upland and channel erosion sources. However, the sediment phosphorus concentration is likely primarily associated with upland stormwater sources.  DO concentrations in tributary, stormwater, and direct drainage inflow are responsive to similar factors. Organic matter in stormwater is elevated during storm events, and reaeration is limited by piped conveyances). Both factors will reduce DO concentrations in stormwater and in post-event drainage. The greatest problems likely occur when the stormwater system contains stagnant points in which organic material accumulates and decays prior to being washed into the creek during storm events. Elevated temperatures in the inflow also reduces the DO saturation concentration. The relative importance of various processes affecting DOD varies according to flow condition. During baseflow conditions the relative influence of internal sources of DOD (SOD and elodea respiration) is greater. During storm events, the relative influence of reduced DO in storm drainage is greater. As shown in Figure 1, the pathways that appear to be of greatest importance lead back to urban stormwater (plus lack of riparian cover) as the primary stressor source. Therefore, implementation will need to have a focus on controlling urban runoff, which is best expressed through surrogate measures related to stormwater flows. The next two sections discuss the development of DOD-based allocations for baseflow and stormflow conditions. 4 DOD and Instream Condition Allocations for Baseflow Conditions Excursions of the DO criterion are documented during both summer baseflow conditions and during storm events. However, most of the detailed monitoring data available are for conditions of spring-fed baseflow or above, with less information available for high flow events. The allocations for these two types of conditions are expected to be rather different. Therefore the allocations are first developed based on DO deficit observed for flows at or below the median flow. The baseflow TMDL analyses are based on the steady-state (diurnal) QUAL2Kw models developed for four well-monitored dates in Clarks Creek with flows around 50 cfs at Tacoma Road. The development, calibration, and application of these models is described in detail in a separate memorandum (Clarks Creek QUAL2Kw Modeling, 2/14/11; Clarks Creek DO TMDL and Implementation Plan, QUAL2Kw ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 9 Modeling, 2/3/11). The model for 7/10/09 (under warm and sunny conditions prior to the start of elodea cutting) provides a good starting point for the analysis. On this date, predicted daily average DO concentrations ranged from 9.6 to 11.2 mg/L, but the early morning minimum DO predicted above Tacoma Road was 7.97 mg/L, and the minimum of Tacoma Road was 7.74 mg/L. During summer baseflow conditions, the minimum DO tends to occur around 5:45 AM and the maximum around 6 PM. At the time of the diurnal minimum on 7/10/09 the total DOD loadings (that is, the sum of those fluxes that reduce dissolved oxygen) in the whole of Clarks Creek amounted to 924 kg-O2/d. The sources of DO deficit were distributed as shown in Figure 4. Similar results apply for other baseflow days modeled. The bulk of the total deficit is supplied by SOD and inflowing water that is below saturation. The inflow deficit (the difference between saturation concentration and actual DO concentration) is associated with both defined tributary streams and additional inputs from direct runoff, springs, and ground water. As the dominant sources of DOD, both SOD and the inflow deficit need to be addressed to achieve DO criteria upstream of Tacoma Road. Figure 4. DO Deficit Components for Clarks Creek, 7/10/09, 5:45 AM QUAL2Kw was calibrated and verified to conditions on four dates representing baseflow or elevated flow conditions. Management scenarios were evaluated for each of these dates to meet both the DO and dissolved gasses criteria:  7/10/09: Represents the system at baseflow conditions before elodea cutting.  7/20/09: Represents the system at baseflow conditions when elodea cutting had proceeded only up to Tacoma Road. Baseline conditions for this date predict a minimum DO above Tacoma Road of 7.99 mg/L and a maximum DO concentration of 124.5% of saturation.  8/6/09: Represents the system at a date after full elodea cutting with baseflow conditions. Management scenarios for this date were tested under the assumption that the cutting had not occurred. The baseline conditions for this date (with elodea removed) predict a minimum DO concentration above Tacoma Road of 8.99 mg/L, with the dissolved gasses criterion met.  8/20/02: Represents the system near baseflow conditions, assuming no elodea cutting. The baseline conditions for this date predict a minimum DO concentration above Tacoma Road of 7.48 mg/L. CBOD 1.14% NBOD 0.09% Elodea Resp. 5.69% SOD 47.40% Inflow Deficit 45.69% ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 10 Across these four dates, the water quality model was used to analyze the scale of improvement necessary to achieve both the DO and the dissolved gasses criteria. The minimum instream DO is most sensitive to SOD, while the dissolved gasses percent saturation is most sensitive to elodea growth. Meeting both criteria simultaneously requires large reductions in both SOD and elodea growth. These are assigned similar percentage reductions, in part because the SOD is thought be largely a result of the elodea. Remaining adjustments to meet the DO criteria are achieved by adjusting DO concentrations in tributary and diffuse inflows upward towards the Clarks Creek instream DO criterion, as needed. The following improvements are the proposed load and wasteload allocations under baseflow conditions:  SOD upstream of Tacoma Road is reduced from 8 to 2.5 mg/m2/d. SOD of Tacoma Road is reduced from 8 to 4 mg/m2/d.  Elodea coverage is reduced to a maximum of 33 percent of pre-TMDL conditions between the State Hatchery and Tacoma Road. Elodea coverage is reduced to a maximum of 25 percent of pre-TMDL conditions between Tacoma Road and the mouth of Clarks Creek2. With this reduction, channel roughness and resistance to flow decreases, and channel hydraulics are assumed to match conditions without significant impedance by elodea mats.  Tributary and diffuse inflows to Clarks Creek upstream of Tacoma Road meet the following minimum conditions: o Maplewood Springs inflows achieve a daily average of 9.5 mg/L DO (with diurnal variability of ± 1 mg/L). o Discharges from the State Hatchery achieve a daily average of 9.5 mg/L DO (with diurnal variability of ± 1 mg/L). o Discharges from Meeker Ditch achieve a daily average of 9.0 mg/L DO (with diurnal variability of ± 2 mg/L). The mean is about 1 mg/L below saturation at typical summer water temperatures. o Discharges at Pioneer Way achieve a daily average of 9.0 mg/L DO (with diurnal variability of ± 2 mg/L). o Diffuse discharges to the stream (predominantly groundwater) upstream of Tacoma Road achieve a concentration of 9.0 mg/L.  No changes are applied to tributary and diffuse inflows of Tacoma Road, which have generally been observed to be near saturation for DO.  No changes are made to external loads of carbonaceous BOD or ammonia as these do not provide a significant direct contribution to the total DO deficit. The load and wasteload allocations are summarized in Table 5, Section 6. For all of the tributary and diffuse inflows upstream of Tacoma Road, the allocation concentrations are less than the saturation concentrations at the measured or assumed discharge temperatures. The assumed diurnal variability in tributary concentrations represents reasonable algal growth and temperature effects. Thus, concentrations for Maplewood Springs and the State Hatchery are at 8.5 mg/L at the period of lowest DO, while those for Meeker Ditch and Pioneer Way are at 7.0 mg/L. Greater diurnal variability (consistent with the model calibration results) is assumed for the latter two discharges because they represent urban storm drainages that may be expected to encourage algal and bacterial growth. No changes are imposed on calibrated model conditions for tributary and diffuse inflows of Pioneer Way. With these allocations, 2 Note: This is defined in the model as the area of the bottom available for algal growth. The relationship between area and biomass is not linear, so a 67 percent reduction in coverage area results in a less than 67 percent reduction in total biomass within a reach. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 11 all criteria are met for each of the four modeled baseflow scenarios (Table The resulting longitudinal DO profile under TMDL conditions for July 10, 2009 is compared to the observed DO results in Figure 5. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 12 Table 1. Allocation Scenario Results for Baseflow Conditions Minimum DO above Tacoma Road (mg/L) Minimum DO below Tacoma Road (mg/L) Maximum Percent Saturation Criterion ≥ 9.5 ≥ 9.5 ≤ 110% 7/10/09 9.85 9.92 109.9% 7/20/09 9.85 9.96 109.6% 8/6/09 9.86 10.01 104.4% 8/20/02 9.54 9.51 107.0% Figure 5. Longitudinal DO Profile for July 10, 2009 with TMDL Allocations, Compared to Observed DO The conditions that achieve compliance with the DO standard are most naturally expressed in terms of SOD rate, elodea coverage, and tributary DO concentration – but these are not in units of daily loads. The conditions that achieve compliance may also be converted to a uniform basis as a daily load of DOD3. 3 Note that components making up the total load of DOD depend on flow and surface area for the day (which in turn are affected by elodea reduction). In addition, the reduction in elodea coverage changes the nutrient response dynamics, causing a reduction in the release of CBOD from plant biomass to the water column but also reducing the uptake of ammonia from the water, causing an increase in the DOD exerted by NBOD. Therefore, CBOD and NBOD values change because of reductions in elodea coverage. 0 2 4 6 8 10 12 14 16 0 1 2 3 4 5 6 dissolved oxygen (mg/L) distance upstream (Km) Clarks Creek (7/10/2009) DO(mgO2/L) DO (mgO2/L) data DO(mgO2/L) Min DO(mgO2/L) Max Minimum DO-data Maximum DO-data DO sat DO Criterion ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 13 Table 2 gives an example of the relative causes of DO depletion in different areas of Clarks Creek for July 10, 2009 and the percentage reduction, expressed as daily load of DOD, needed to reduce DO depleting sources to meet water quality standards. As explained earlier, SOD and tributary and diffuse inflows represent the greatest sources of DO depletion. Overall there is need for a total reduction in DOD of 49 percent. Most of this is accomplished by an allocated reduction of 68 percent in exerted SOD and 27 percent reduction in DOD in tributary inflows an increase in DO concentration in these inflows). For the tributary inflows it should be noted that the allocation is a reduction in DOD (the difference between DOsat in the inflow and ambient concentration), with no change in flow. Alternatively, the tributary inflow allocations could be developed on the basis of existing DOD concentration with reduced flow, although the feedback effects of reduced flow on reaeration would also need to be tested. It is anticipated, however, that most management options would not result in flow reductions during baseflow conditions. For instance, stormwater options such as rain gardens will reduce total flow volume due to evapotranspiration, but also shift flow from storm event to baseflow conditions. Table 2. Existing and Allocated DO Deficits (expressed as kg/d for Clarks Creek Diurnal Minimum Conditions of 5:45 AM, July 10, 2009) CBOD NBOD Elodea Respiration SOD Tributary Inflows Total Existing DO Deficit Headwater < 0.5 < 0.5 Maplewood to Hatchery < 0.5 < 0.5 < 0.5 < 0.5 173 174 Hatchery to Meeker 1 < 0.5 3 50 187 241 Meeker to DeCoursey 2 < 0.5 8 63 21 94 DeCoursey to Pioneer 2 < 0.53 6 45 < 0.5 53 Pioneer to Woodland 4 < 0.5 11 90 15 120 Woodland to Diru 1 < 0.5 3 23 4 31 Below Diru (Tacoma Rd) 1 < 0.5 2 16 7 26 Tacoma to Rody 1 < 0.5 3 26 < 0.5 31 Rody to PTI Hatchery 2 < 0.5 5 42 4 54 PTI Hatchery to Mouth 5 < 0.5 11 84 12 111 Total 20 1 53 439 423 934 DO Deficit Allocations to Meet Water Quality Standards Headwater < 0.5 < 0.5 Maplewood to Hatchery < 0.5 < 0.5 < 0.5 < 0.5 123 123 Hatchery to Meeker 1 < 0.5 2 15 135 153 Meeker to DeCoursey 1 < 0.5 2 16 17 36 ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 14 CBOD NBOD Elodea Respiration SOD Tributary Inflows Total DeCoursey to Pioneer 1 < 0.5 1 11 < 0.5 13 Pioneer to Woodland 2 < 0.5 3 23 12 40 Woodland to Diru 1 < 0.5 1 6 < 0.5 8 Below Diru (Tacoma Rd) < 0.5 < 0.5 1 4 7 13 Tacoma to Rody 1 < 0.5 1 12 < 0.5 14 Rody to PTI Hatchery 1 < 0.5 1 18 4 24 PTI Hatchery to Mouth 2 < 0.5 2 37 12 53 Total 10 0.97 15 141 309 476 DO Deficit Allocations Expressed as Percent Reduction Headwater 0% 0% Maplewood to Hatchery 0% 100% NA -29% -29% Hatchery to Meeker -19% 22% -37% -70% -28% -37% Meeker to DeCoursey -41% 234% -73% -74% -21% -61% DeCoursey to Pioneer -44% 44% -74% -76% NA -75% Pioneer to Woodland -51% -27% -73% -75% -21% -67% Woodland to Diru --47% -31% -71% -73% NA -75% Below Diru (Tacoma Rd) -48% -35% -70% -72% 0% -52% Tacoma to Rody -49% -35% -77% -54% NA -56% Rody to PTI Hatchery -54% -38% -79% -58% 0% -56% PTI Hatchery to Mouth -55% -30% -78% -56% 0% -52% Total -48% 22% -72% -68% -27% -49% We determined the proportion of the DO deficit attributable to the State Hatchery under the allocation conditions. The model was rerun with the hatchery flow present but the BOD and nutrient loads removed (Table The difference between the allocation run and the allocation run without the hatchery represents the net DO deficit attributable to the State Hatchery (which, as a permitted point source, must be allocated separately in the TMDL). Because the DOD attributed to the State Hatchery is less than 1 percent of the total DOD under both existing and allocation conditions, no reductions are proposed for this source. The wasteload allocations for the State Hatchery is equivalent to current loading levels. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 15 Table 3. Attribution of the CBOD and NBOD Components of DO Deficit (kg/d) to the State Hatchery for Clarks Creek Diurnal Minimum Conditions of 5:45 AM, July 10, 2009 State Hatchery Stormwater CBOD NBOD CBOD NBOD Headwater Maplewood to Hatchery 0.00 0.00 0.13 0.08 Hatchery to Meeker 0.34 0.28 0.75 0.18 Meeker to DeCoursey 0.34 0.15 0.86 0.08 DeCoursey to Pioneer 0.25 0.02 0.65 0.02 Pioneer to Woodland 0.52 0.00 1.51 0.05 Woodland to Diru 0.15 0.00 0.47 0.01 Below Diru (Tacoma Rd) 0.11 0.00 0.36 0.01 Tacoma to Rody 0.17 0.00 0.55 0.01 Rody to PTI Hatchery 0.23 0.00 0.79 0.02 PTI Hatchery to Mouth 0.45 0.00 1.68 0.05 Total 2.58 0.45 7.75 0.52 5 DOD and Instream Condition Allocations for Stormflow Conditions The allocations presented above achieve both the DO and dissolved gasses criteria for models representing four days of well-monitored summer conditions, all of which are representative of dry weather conditions. DO excursions have also been noted under wetter conditions, although less detailed monitoring is available. Two calibrated QUAL2Kw model applications are also available for stormflow conditions (described in the separate memorandum). One example is the model for September 12, 2003, on which date flows were elevated about 20 percent above baseflow at Tacoma Road, significant flows entered through the storm drains at Pioneer Way as well as between Meeker and DeCoursey, and DO concentrations near Tacoma Road declined to about 6 mg/L. Applying the allocations determined for baseflow conditions in Section 4 to this date does not achieve the DO standards, resulting in a predicted DO of 8.97 mg/L at Tacoma Road. The primary remaining source of DO deficit is the tributary inflows, which become increasingly important as stormflow increases. During storm runoff conditions it is reasonable to suppose that a greater fraction of tributary flow is delivered by surface rather than groundwater pathways, and could thus achieve greater DO concentrations with less diurnal variability. The DO criteria can be met on this date by altering the following conditions for the tributary and diffuse inflows: ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 16  Discharges from Meeker Ditch and Pioneer Way achieve a daily average of 9.5 mg/L (with reduced diurnal variability of ± 0.5 mg/L).  Diffuse inflows achieve a DO concentration of 9.5 mg/L. With these changes, the resulting DO minimum is 9.74 mg/L and the dissolved gasses criterion is also met (Figure Figure 6. Longitudinal DO Profile for September 12, 2003 with Enhanced TMDL Allocations, Compared to Observed DO Analysis of the DOD components shows that the DOD associated with tributary inflows at the diurnal minimum (about 5:00 AM) goes from about 570 to 341 kg/d under these conditions – a reduction of about 40 percent, larger than in the baseflow case. Reductions in DOD associated with elodea respiration and with SOD (69 and 62 percent, respectively) are similar to the percentage reductions for the baseflow case. 0 2 4 6 8 10 12 0 1 2 3 4 5 6 dissolved oxygen (mg/L) distance upstream (Km) Clarks Creek (9/12/2003) DO(mgO2/L) DO (mgO2/L) data DO(mgO2/L) Min DO(mgO2/L) Max DO sat DO Criterion ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 17 Table 4. DO Deficit Results Expressed as kg/d for Clarks Creek Diurnal Minimum Conditions of 5:00 AM, September 12, 2003 CBOD NBOD Elodea Respiration SOD Tributary Inflows Total Existing DO Deficit Headwater < 0.5 < 0.5 Maplewood to Hatchery < 0.5 < 0.5 < 0.5 < 0.5 65 65 Hatchery to Meeker 1 < 0.5 1 28 85 116 Meeker to DeCoursey 2 < 0.5 3 40 141 185 DeCoursey to Pioneer 2 < 0.5 6 75 96 179 Pioneer to Woodland 6 < 0.5 9 114 163 293 Woodland to Diru 1 < 0.5 3 30 < 0.5 34 Below Diru (Tacoma Rd) 1 < 0.5 1 15 2 19 Tacoma to Rody 2 < 0.5 7 87 < 0.5 96 Rody to PTI Hatchery 2 < 0.5 3 35 5 44 PTI Hatchery to Mouth 3 < 0.5 6 65 13 86 Total 19 < 0.5 40 [PHONE REDACTED] DO Deficit Allocations to Meet Water Quality Standards Headwater < 0.5 < 0.5 Maplewood to Hatchery < 0.5 < 0.5 < 0.5 < 0.5 61 62 Hatchery to Meeker 1 < 0.5 1 9 85 96 Meeker to DeCoursey 1 < 0.5 1 12 70 85 DeCoursey to Pioneer 2 < 0.5 2 23 52 80 Pioneer to Woodland 4 < 0.5 3 36 52 95 Woodland to Diru 1 < 0.5 1 9 < 0.5 12 Below Diru (Tacoma Rd) 1 < 0.5 < 0.5 5 2 7 Tacoma to Rody 3 < 0.5 2 44 < 0.5 49 ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 18 CBOD NBOD Elodea Respiration SOD Tributary Inflows Total Rody to PTI Hatchery 1 < 0.5 1 17 5 24 PTI Hatchery to Mouth 2 < 0.5 1 33 13 49 Total 17 1 12 188 341 558 DO Deficit Allocations Expressed as Percent Reduction Headwater 0% 0% Maplewood to Hatchery 0% 0% 0% NA Hatchery to Meeker -17% 65% -34% -69% 0% -17% Meeker to DeCoursey -52% 101% -67% -69% -50% -54% DeCoursey to Pioneer 40% 445% -67% -69% -46% -55% Pioneer to Woodland -27% 103% -67% -69% -68% -68% Woodland to Diru 7% 158% -67% -69% NA -66% Below Diru (Tacoma Rd) -36% 5% -67% -69% 0% -60% Tacoma to Rody 82% 162% -75% -50% NA -49% Rody to PTI Hatchery -31% -16% -75% -50% 0% -46% PTI Hatchery to Mouth -31% 6% -75% -50% 0.00% -43% Total -12% 100% -69% -62% -40% -50% Severe DO depletion has also been analyzed for the extreme high flow day of October 21, 2003. On this day, low DO 5 mg/L) was primarily due to reduced DO in tributary inflows. The date was also characterized by abnormally high temperatures, with water temperature of 16 °C below the PTI Hatchery, which reduced DO saturation concentrations and exacerbated oxygen-consuming biological processes. The stormflow DOD analysis is presented above. Based on QUAL2Kw model runs, if the flow volume from Meeker Ditch, Pioneer Way storm drains, and Rody, Diru and Woodland Creeks on 10/21/2003 is reduced by 50 percent, the DO standard is predicted to be met if SOD is held to 2.5 mg/m2/d throughout Clarks Creek (instead of only upstream of Tacoma Road). Note that SOD which arises from bacterial and fungal decomposition processes is likely to be naturally reduced during high flow events when turbulent flow disturbs the biofilm at the sediment-water interface. The allocations under stormwater flow conditions are therefore a 50% reduction of flow into stormwater conveyances at Pioneer Way and Meeker Ditch (Table ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 19 Figure 7. Longitudinal DO Profile for October 21, 2003 with Enhanced TMDL Allocations for September 12, 2003, Compared to Observed DO The entire watershed is subject to MS4 permits for stormwater, held by the City of Puyallup, Pierce County, and WSDOT. The dominant processes that drive the DO impairment in Clarks Creek are closely tied to stormwater loads and erosion associated with stormwater flows, as shown in the conceptual model figures (Figure 1 and Figure although the connections are often complex and indirect SOD). Most of the stormwater impacting Clarks Creek is subject to MS4 permits, and thus should receive WLAs. However, storm flows that do not discharge through organized surface drainages (primarily washoff from properties adjacent to Clarks Creek) are not covered by the MS4 permits and should receive LAs. Responsibility for achieving the overall TMDL allocations is assigned based on the relative amount of stormwater runoff contributed by each permittee. The TMDL allocations will be apportioned based on the fraction of annual surface runoff derived from each jurisdictional area. These fractions were determined using an HSPF watershed model that is currently being developed under contract with the Puyallup Tribe of Indians. The resulting TMDL allocation fractions are presented in Table 5. Table 5. TMDL Allocation Fractions to Stormwater Sources Total Allocation WLA: City of Puyallup MS4 WLA: Pierce County MS4 WLA: WSDOT MS4 LA: Properties adjacent to creek 100 % 47% 34% 2% 17% 0 2 4 6 8 10 12 0 1 2 3 4 5 6 dissolved oxygen (mg/L) distance upstream (Km) Clarks Creek (10/21/2003) DO(mgO2/L) DO (mgO2/L) data DO(mgO2/L) Min DO(mgO2/L) Max DO sat DO Criterion ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 20 6 Additional Allocations for Peak Flow Reduction and Riparian Shading The DOD allocations are expressed as reduction in SOD rate, reduction in elodea density, control of tributary flows, and control of flows in stormwater conveyances. However, the DOD-based allocations do not fully address all the ultimate stressor sources driving these phenomena, such as channel erosion caused by urban stormwater from upland sources and the lack of riparian shading (Figures 1 and In order to address allocations to reduce elodea growth and SOD rates, the TMDL gives additional allocations for: hydrograph/flow management to control geomorphically significant flows and channel erosion, and increase in riparian shade. Hydrograph/Flow Management In addition to contributing DOD, stormwater also contributes to impairment in Clarks Creek by causing erosion in upland areas and in channels in Clarks Creek which in turn leads to deposition of fine sediment, one of the most significant causes of DO problems and beneficial use impairment in Clarks Creek. Channel erosion causes habitat degradation, and fine sediment can fill in gravel spaces which reduce salmon spawning areas. In Clarks Creek, sediment also creates a substrate for elodea to grow and where soluble reactive phosphorus can deposit, which then provides nutrients for elodea to further grow. Sedimentation also contributes to sediment oxygen demand and excessive elodea growth which then undergoes respiration, and decay, all of which cause DO impairments. To meet the SOD and elodea allocations, stormwater controls to reduce geomorphically significant flows to approximate natural conditions are necessary. In order to meet the elodea density and SOD targets, scouring flows that cause sediment loading and channel erosion must be reduced. Therefore, the reduction of geomorphically significant flows to approximate natural conditions are set as wasteload and load allocations to address sediment problems and the elodea density and SOD allocations within Clarks Creek. The Puyallup Tribe of Indians is working with the Clarks Creek Team to identify geomorphically significant flows in the watershed which dictate channel erosion and sediment generation. The PTI sediment project includes a sediment source inventory, sediment sampling, channel surveying, and GIS assessment. This is expected to be completed by the fall of 2012. Stormwater controls are needed for the drainage upstream of Maplewood Springs and the headwaters of other tributaries to reduce rates of channel erosion and sediment generation. The focus of these controls would be on hydrograph management – i.e., controlling the frequency and duration of flows greater than a threshold at which sediment erosion from stream banks occurs to approximate natural conditions. Detailed recommendations for implementing hydrograph management will result from the PTI sediment project. NPDES permittees will be required to participate in, develop, and implement a plan to manage their hydrograph, based on recommendations from the PTI sediment reduction project. Department of Ecology will work with NPDES permittees on the details and timing for participation, plan development, and implementation. Riparian Shading Increased riparian shading is needed to help achieve the load allocation for reduced elodea density in Clarks Creek. Increased riparian shading also provides benefits of reducing thermal input which in turn increases the carrying capacity for oxygen. Unfortunately, the light requirements of Elodea nuttallii in Clarks Creek are not fully understood at this time. However, sensitivity analyses with the QUAL2Kw model do suggest that elodea growth can be reduced by shading, as do qualitative observations of shaded versus unshaded reaches of Clarks Creek. Further, the needed reduction in elodea density will occur as the combined results of all implementation measures. Therefore, the TMDL sets a goal of achieving potential natural vegetation on the length of Clarks Creek of the State Hatchery. These ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 21 targets are still being determined. Conversion of managed lawns to tree canopy will also reduce direct stormwater flow and associated pollutant inputs from properties adjacent to Clarks Creek, thus helping to meet the allocations for diffuse inputs. 7 Summary of Allocations Table 6 summarizes the allocations in the TMDL. These are divided into baseflow and stormflow conditions as well as geographically, based on the analyses in the preceding sections. EPA requires that loads be expressed in mass per time, so the loading capacity will be expressed as DOD in an appendix of the TMDL with the breakdown of different sources and their contribution to the DOD. The allocations used for implementation that were derived from the QUAL2Kw model and DOD analysis are summarized below. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 22 Table 6. Summary of TMDL Load and Wasteload Allocations TMDL Allocations Above State Hatchery Allocation Stormwater Hydrograph and Shading SOD (mg/m2/d) Elodea Maximum Density Stormwater and Diffuse Inflows Baseflow Stormflow Baseflow Stormflow WLA: City of Puyallup *Reduction in geomorphically significant flows WLA: Pierce County *Reduction in geomorphically significant flows WLA: State Hatchery Existing Load of CBOD, NBOD, and nutrients Existing Load of CBOD, NBOD, and nutrients LA *Reduction in geomorphically significant flows Maplewood Springs: ≥9.5 mg/L DO Maplewood Springs: ≥9.5 mg/L DO TMDL Allocations of State Hatchery and Upstream of Tacoma Road and Tributaries Allocation Stormwater Hydrograph and Shading SOD (mg/m2/d) Elodea Maximum Density Stormwater and Diffuse Inflows Baseflow Stormflow Baseflow Stormflow WLA: City of Puyallup Reduce untreated stormwater volume by 24% in Meeker Ditch, Pioneer Way conveyances and tributaries from September, October 2003 WLA: Pierce County *Reduction in geomorphically significant flows in tributaries Reduce untreated stormwater volume by 17% in Pioneer Way conveyance and Rody, Diru, and Woodland Creek from September, October 2003 WLA: WSDOT *Reduction in geomorphically significant flows LA Reduce untreated stormwater volume by 8% from September, October 2003 Natural potential vegetation < 2.5 < 2.5 < 33% All tributaries: ≥9.0 mg/L DO All tributaries: ≥9.5 mg/L DO. ---PAGE BREAK--- Clarks Creek Draft Allocations 7/27/2011 23 TMDL Allocations of Tacoma Road Allocation Stormwater Hydrograph and Shading SOD (mg/m2/d) Elodea Maximum Density Stormwater and Diffuse Inflows Baseflow Stormflow Baseflow Stormflow LA Natural Potential Vegetation <4.0 < 2.5 < 25% All tributaries ≥9.5 mg/L DO *Based on Puyallup Tribe’s Sediment Reduction Project. Each jurisdiction’s responsibility to reduce flows will be based on the amount of the watershed within their jurisdiction covered by the MS4 NPDES permit. A separate wasteload allocation will be assigned to the State Hatchery as an NPDES permitted point source. Because this appears to be a de minimis source of DOD in Clarks Creek, no reductions are required. Instead, the TMDL allocations for this source should require maintenance of current loading rates (or better) of CBOD, NBOD, and nutrients. The wasteload allocations expressed as flow for the City of Puyallup, Pierce County, and WSDOT are 1) to reduce geomorphically significant flows above the State Hatchery and in the tributary headwaters as determined by the Puyallup Tribe’s Sediment Reduction Project and 2) to reduce untreated stormwater by 50% in Meeker Ditch and Pioneer Way stormwater conveyances and tributaries from September and October 2003 flows. The wasteload allocations were calculated by multiplying the percent flow reduction allocation by the proportion of each jurisdiction. These are as follows: City of Puyallup Pierce County WSDOT and General Load Allocation The load allocations are to increase riparian shading on Clarks Creek below the State Hatchery to natural potential vegetation and to reduce elodea density by 33% of its level in 2009 between the State Hatchery and Tacoma Road and to 25% of its level in 2009 of Tacoma Road. A TMDL consists of wasteload allocations (WLAs) assigned to permitted point sources, load allocations (LAs) assigned to nonpoint sources, and a margin of safety (MOS), which may be either explicit or implicit: TMDL = Σ WLAs + Σ LAs + MOS The MOS is intended to account for the uncertainty in the relationship between pollutant loads and the water quality response. There are two methods for incorporating a MOS in the analysis: 1) by implicitly incorporating the MOS using conservative model assumptions to develop allocations; or 2) by explicitly specifying a portion of the TMDL as the MOS and using the remainder for allocations. For the Clarks Creek TMDL an explicit MOS is incorporated into the stormwater load allocation by reducing the allocation by 10 percent for the typical summer baseflow conditions of July 10, 2009. This is equivalent to an MOS of 30.9 kg/d DOD, or 6.5 percent of the total assimilative capacity. ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 1 FINAL PROJECT REPORT FOR Agreement Number: G0900221 Chehalis River Egeria densa Control Prepared by: Thurston County Noxious Weed Control Board October 22, 2010 Total Cost of Project: $79,617.00 Grant or Loan Amount: $51,937.00 Project Start Date: April 22, 2009 End Date: October 6, 2010 __________10/22/2010 &/or (AUTHORIZED SIGNATORY) DATE (PROJECT MANAGER) DATE ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 2 PROJECT SUMMARY BACKGROUND  Brazilian elodea was found in Thurston County in July of 1999 approximately 7 river miles from the first discovery near Plummer Lake in Lewis County. These infestations of Brazilian elodea were hand pulled and sites marked for follow up monitoring  Years 2000 and 2001, additional hand pulling efforts were made in Thurston County.  In 2002, a private diver was hired to assist with removing these infestations. Even with these additional efforts more sites were being found each year.  In September 2003, an increase in the removal effort was necessary to address the rate of spread of Brazilian elodea in the river.  In October 2003, a survey of Brazilian elodea infestations was conducted near the source to the heaviest infestations in Lewis County to the project site in Thurston County. Scattered plants and patches were found throughout the main stem of the Chehalis River from point of original around River mile 67 to the Thurston County infestations at River mile 59.  In 2004, Washington Department of Natural Resources agreed to sponsor a pilot project which used (diver dredging) to remove elodea from the Chehalis River in Thurston County. A pilot project using diver dredging to remove Brazilian elodea from the most seriously infested sites was performed from July 19, 2004 through July 29, 2004. Over seven thousand pounds of elodea was removed. Unfortunately much of this biomass returned the following years as no guidance on root removal was available at the time.  In 2005, a follow up survey indicated many of the areas where biomass was removed did have significant re-growth. An expert from Portland State University was contacted for analysis and advice. Toni Pennington an ANS Research Assistant for the Environmental Science and Resources Center for Lakes & Reservoirs at PSU was consulted. Ms. Pennington observed the meticulous root removal process in 2005, her recommendations were: o Root removal must occur below the double node of the fibrous root ball for control to be achieved. This information was not available until August 2005. The 2005 project included the meticulous removal of all roots in an area of infestation in Lewis County. 1.5-2 acres of elodea was removed, 90%+ of the biomass and roots were removed in this area. No elodea has returned for nearly 5 consecutive years, in 2010 this area is free of Brazilian elodea.  During 2006 through 2010, removal in the main stem of the Chehalis River included continuing this technique of removing the roots to the point of the double node.  Also in 2006; o A Memorandum of Understanding for the Chehalis River Cooperative Weed Management Area was complete. o A Memorandum of Understanding between the Confederated Tribes and the Thurston County Noxious Weed Control Board was in effect 2006-2010. o A plan for the Chehalis River Weed Management Area was completed and accepted.  In 2007 through 2009, Thurston County Noxious Weed Control and the Confederated Tribes of the Chehalis both receive funding from several sources; the Department of Ecology, Washington State ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 3 Salmon Recovery Board through the Nature Conservancy’s project to enhance salmon bearing streams of the Chehalis River and U.S. Fish and Wildlife and Washington State Department of Natural Resources.  In 2010 Thurston County continued removal and expanded the scope of that project to 33 miles. OBJECTIVE: The objective of this project was to complete biomass removal in the un-harvested areas of the Chehalis River and to expand the survey area to River mile 33. PROJECT OVERVIEW: The Elodea Removal project began in 2009 with the purchase of supplies and equipment necessary to outfit a small pontoon boat for diver dredge operations. A photograph of the pontoon boat, and smaller dredge removal system is shown to the right. The smaller equipment was necessary due very limited access in many of the Brazilian elodea infested areas that remained after the original biomass removal projects that were performed 2005 through 2008. The earlier projects equipment could only be used in areas with good access and in slower deeper sections of the Chehalis River which occur near Fort Borst Park in Lewis County and Prather Road in Thurston County. At Prather a crane was used to lower the larger equipment into and out of the river in 2006, 07, and 08. These areas are now nearly free of Brazilian elodea. In addition to a smaller pontoon boat, a Suzuki motor was purchased by U.S. Fish and Wildlife Services and Thurston County purchased a smaller dredge system that is easily transported from site to site. With these changes in the size of equipment we were able to access all the areas that Brazilian elodea infested. Access points are 7-10 miles apart in the project area so this was an important hurdle to clear to be able to provide full removal of Egeria in all areas of the infestation. In July 2009 Washington State Fish and Wildlife provided a survey via air boat to assess safety of working in areas previously not surveyed. Three major log jams were found and locations recorded. This information was critical in keeping the dive team safe when working in very remote areas where access is difficult. The log jams are located from the confluence of Black and the Chehalis Rivers about 2 miles. ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 4 A new GPS trimble unit was purchased to accurately locate scattered plants throughout the infested areas. A pre removal survey was conducted in 2009 and 2010. A map was created for the dive team to follow on a day by day basis for planning each day’s work. During 2009 18 miles of the main stem were cleared of all known Brazilian elodea. This was the first time all known locations of Brazilian elodea had been removed in a single season. During 2010 34 miles of the main stem were cleared of all known Brazilian elodea, making the second consecutive season for total removal of the infestation. The Chehalis Tribe had similar equipment and staff the first year of this project. The following is a report from the Chehalis Tribe Biologist in 2009: The Chehalis Tribe’s Noxious Weed Program was able to remove a great deal of Brazilian Elodea during the 2009 season. They began their work with surveys to determine the extent of the Elodea and where would be the best locations to use the two different dredges that the Program owns. The surveys went from Fort Borst Park in Centralia to the mouth of the Satsop River near Keys RD in Grays Harbor County. They were happy to discover that the Elodea seems to be losing its battle against the weed warriors that have been battling it for the last several years. They anticipated there being more to remove and that there would be more concentrated areas of infestation; what they found was the opposite. There were few concentrated areas and what was left was often single or double plants tucked inside native elodea patches as well as other native aquatic plants. This required different strategies and meant that the Program’s smaller more portable dredge would become essential to eliminate the scattered sparse plants more effectively. They were still able to use the barge mounted dredge in several locations--mainly focused on the areas just above the mouth of Independence Creek in a very large slough. Even with the scattered plants and few locations to utilize the larger dredge the crews were able to pull and remove 11,693 lbs of Brazilian Elodea. We are happy to say that there just wasn’t anymore to pull in the survey area that the Program focused on. They were happy to be able to work closer to home and be able to remove any of the infestations that were located on the Chehalis Reservation. The Program and its work will continue next year and will probably consist of using the portable dredge and surveying to locate and remove any last ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 5 remaining infestations or new plants that might have been dislodged from Plummer Lake or any of the many sloughs that routinely flood and wash their contents into the Chehalis River. The following is the 2010 overview by the barge tender for this project Dan Reynoldson: Borst Park to Galvin: Most of the elodea was found in this stretch of the river along the north bank about 1/4 mile from the boat launch to the first riffle. About 1875 pounds were found on the north bank and another 30 pounds on the south bank. At the slough just upstream of the Galvin Bridge we found about another 1190 pounds. Galvin Bridge to Prather Road: We found about 210 pounds along west bank from bridge to Busek's riffle. Lincoln Creek inlet: 230 pounds was removed at the Lincoln Creek inlet. There was no Brazilian elodea on the main stem to Prather Road Bridge. Prather Road Bridge to Independence: About 48 pounds was removed at Doleman's farm or the Maple Lane outfall. Upstream from Scatter Creek: 930 pounds was removed, mostly on the north bank upstream from Scatter Creek. This volume is much reduced from 2009. Independence to Black River: Only 3 pounds were removed, mostly just below the Independence launch. Black River to Oakville: Only 3 plants were found. We then entered into never-before-surveyed areas Oakville to Porter:  About 460 pounds of elodea was found in a side slough, just below the Oakville boat launch on the south bank.  About 540 pounds found in a back slough about halfway to Porter on the south bank.  The main stem of the Chehalis River was clean. Only two areas did not show improvement from 2009.  The area just from the Borst Park boat launch was about the same as last year.  Galvin main stem was worse. All other areas were better than in the past except the new areas of Black River Largest infestation near Fort Borst boat launch 2010 ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 6 PLANT SURVEYS AND MAPS ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 7 ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 8 ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 9 Control methods: Diver dredging (suction dredging) was be used in the Chehalis River main stem, staffing requires three divers, one who is also a barge tender. Diver dredging is a method where divers use hoses attached to small dredges to vacuum plant material out of the river, after dislodging the roots. The purpose of diver dredging is to effectively remove all of the plant biomass including the roots. The divers use the suction hose to dispose of Brazilian elodea only. The water is returned back to the water column and the plant material is retained. The technique is consistent with the existing hydraulic permit for removing noxious weeds permitted by the Washington State Department of Fish and Wildlife. Diver dredging is effective against Brazilian elodea because the plant and root structures can be removed entirely from the aquatic system. This technique has been used on Brazilian elodea in the Chehalis River since 2005. ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 10 lbs of Brazilian elodea removed 7740 44910 76708 106772 47425 25963 5519 315037 0 50000 100000 150000 200000 250000 300000 [PHONE REDACTED] 2005 2006 2007 2008 2009 2010 total amount remove Acres of elodea removed 1.5 5.41 9.449.92 8.03 6.22 0 2 4 6 8 10 12 2005 2006 2007 2008 2009 2010 Monitoring: Efficacy is determined by the amount of area and biomass removed from the project area annually and comparing it to the previous years’ total, and the # of river miles surveyed. WATER QUALITY BENEFITS: In 2007 oxygen levels were measured in areas with large mats of Brazilian elodea, prior to removal. That first reading was compared to a reading taken after removal was complete. The results of the two comparisons demonstrated a 7.75% increase in dissolved oxygen after Brazilian elodea was removed from the Chehalis River. An additional attempt to measure oxygen levels was attempted in 2009 at the Lincoln Creek slough area. No conclusions were able to be made from this attempt at measuring before and after DO readings. Populations of Brazilian elodea have now been reduced to the point where readings will most likely not show any differentiation as no large canopied mats now occur anywhere in the area of the infestation. In 2009 and 2010 only small patches very near the shoreline and mostly individual plants are what we are removing. This probably does not alter DO levels. River miles surveyed 7 7 13 18 20 22 34 0 5 10 15 20 25 30 35 40 2004 2005 2006 2007 2008 2009 2010 ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 11 EDUCATION/COMMUNICATION COMPONENTS Education: A news release was written and resulted in several papers covering the progress with elodea on the Chehalis River in 2009. Several articles are pasted as they appear in local papers: Each year the Brazilian elodea project brochure is updated and posted on our web site. ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 12 ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 13 OVERALL PROJECT RESULTS: According to the statistics tracked, bio mass removal in 2009 had decreased 54% from 2008 and in 2010 78.8% from 2009 levels. In terms of acreage removed 38% less elodea was removed in 2010 from the high of 9.92 acres in 2008. PROPOSED MANAGEMENT FOR FUTURE YEARS: Additional funding is being applied for to continue to mop up the remaining Brazilian elodea in the main stem of the Chehalis River. If progress continues at this pace it may be realistic to establish an eradication goal in the future. 2006 2010 Budget Summary: Brazilian Elodea Project Hours DOE 2009 Hours 2010 Hours Chehalis River main stem-Prather Road ---PAGE BREAK---  Thurston County Noxious Weed Control Agreement #G0900221 14 Rick Johnson 69 20 Angela Celestine 3.5 Dan Reynoldson 203 125 Dive Team 426 231 US F&W Rick Johnson 22 32.00 Dan Reynoldson 124 50.00 Dive Team 208 139.25 Subtotal 1055.5 597.25 Total Hours of Project 1652.75 Description 2009 Costs Reimbursements DOE $35,928.39 $35,928.40 US F&W $14,312.59 $14,312.59 2009 TOTAL $50,240.98 $50,240.99 Description 2010 Costs Reimbursements US F&W $9,454.99 $9,454.99 DOE $19,921.22 $16,008.61 Total Project costs Total Project Reimbursements 2009 TOTAL COSTS $50,240.98 $50,240.99 2010 TOTAL COSTS $29,376.21 $25,463.60 TOTAL PROJECT COSTS $79,617.19 $75,704.59 ---PAGE BREAK--- HYDRAULIC PROJECT APPROVAL Washington Department of FISH and WILDLIFE 48 Devonshire Road Montesano, WA 98563 (360) 249-4628 Coastal RCW 77.55.021 - See appeal process at end of HPA Project Expiration Date: September 30, 2013 Control Number: FPA/Public Notice Issue Date: July 07, 2011 124087-1 N/A ATTENTION: Mark Palmer 333 S Meridian St Puyallup, WA 98371 [PHONE REDACTED] PERMITTEE AUTHORIZED AGENT OR CONTRACTOR City of Puyallup Project Name: Project Description: Clark's Creek Elodea Hand Pulling Pilot Project This HPA is for a pilot project to conduct hand pulling of elodea along 950 feet of Clark's Creek. Pulled plants will be immediately placed on a float, moved to the shoreline and disposed of off-site. A Clark's creek habitat restoration project with associated planting plan will also be conducted in an effort to improve water quality. 1. NOTIFICATION REQUIREMENT: The Area Habitat Biologist (AHB) listed below and the Puyallup Tribe ([EMAIL REDACTED]) shall receive written notification (FAX or mail) from the person to whom this Hydraulic Project Approval (HPA) is issued (permittee) or the agent/contractor prior to the start of construction activities at each location. The notification shall include the permittee's name, project location, starting date for work, and the control number for this HPA. 2. TIMING REQUIREMENT: Work below the ordinary high water line shall only occur between July 1 and September 30 of calendar years 2011 through 2013. 3. Work shall not be conducted in fish spawning areas. 4. Large woody material embedded in the bank or streambed shall be left undisturbed and intact. 5. The use of equipment below the ordinary high water line shall be limited to hand held tools only. 6. Every effort shall be made to avoid the spread of plant fragments through equipment contamination. Persons or firms using any equipment to remove or control aquatic plants shall thoroughly remove and properly dispose of all viable residual plants and viable plant parts from the equipment prior to the equipment's use in a body of water. 7. Removed materials shall be disposed of upland so it will not re-enter state waters. 8. Extreme care shall be taken to ensure that no sediments, sediment-laden water, chemicals, or any other toxic or deleterious materials are allowed to enter or leach into the stream. PROVISIONS 4 Page 1 of ---PAGE BREAK--- HYDRAULIC PROJECT APPROVAL Washington Department of FISH and WILDLIFE 48 Devonshire Road Montesano, WA 98563 (360) 249-4628 Coastal RCW 77.55.021 - See appeal process at end of HPA Project Expiration Date: September 30, 2013 Control Number: FPA/Public Notice Issue Date: July 07, 2011 124087-1 N/A 9. If high flow conditions that may cause siltation are encountered during this project, work shall stop until the flow subsides. 10. If at any time, as a result of project activities, fish are observed in distress, a fish kill occurs, or water quality problems develop (including equipment leaks or spills), immediately stop work except for efforts to control leaks or spills or prevent toxic substances from entering the water and notify the Washington Military Department's Emergency Management Division at 1-[PHONE REDACTED], and to the Area Habitat Biologist listed below. Work shall not restart on the project until approved by the Area Habitat Biologist. 11. Project activities shall not include the disturbance of restoration projects that may be within project area without prior authorization from the Area Habitat Biologist (AHB) listed below. The request shall be no less than three working days prior to the start of work. Location #1 Clarks Creek approx 950 feet WRIA: Tributary to: 1/4 SEC: Range: Section: Township: 10.0027 Puyallup River Latitude: Longitude: W 1/2 37 20 N 04 E N 47.186163 W 122.319696 Clarks Creek County: Pierce WORK START: WORK END: July 07, 2011 September 30, 2013 From SR 512 at Pioneer Ave, follow Pioneer Ave West to 18th St SW. Turn left on 18th st SW, proceed south to 7th Ave SW. Turn right, Clarks creek bridge (north boundary of project) at 7th Ave SW will be approximately 100 feet west. Waterbody: Location #1 Driving Directions PROJECT LOCATIONS APPLY TO ALL HYDRAULIC PROJECT APPROVALS This Hydraulic Project Approval pertains only to those requirements of the Washington State Hydraulic Code, specifically Chapter 77.55 RCW (formerly RCW 77.20). Additional authorization from other public agencies may be necessary for this project. The person(s) to whom this Hydraulic Project Approval is issued is responsible for applying for and obtaining any additional authorization from other public agencies (local, state and/or federal) that may be necessary for this project. This Hydraulic Project Approval shall be available on the job site at all times and all its provisions followed by the person(s) to whom this Hydraulic Project Approval is issued and operator(s) performing the work. This Hydraulic Project Approval does not authorize trespass. The person(s) to whom this Hydraulic Project Approval is issued and operator(s) performing the work may be held liable for any loss or damage to fish life or fish habitat that results from failure to comply with the provisions of this Hydraulic Project Approval. 4 Page 2 of ---PAGE BREAK--- HYDRAULIC PROJECT APPROVAL Washington Department of FISH and WILDLIFE 48 Devonshire Road Montesano, WA 98563 (360) 249-4628 Coastal RCW 77.55.021 - See appeal process at end of HPA Project Expiration Date: September 30, 2013 Control Number: FPA/Public Notice Issue Date: July 07, 2011 124087-1 N/A Failure to comply with the provisions of this Hydraulic Project Approval could result in a civil penalty of up to one hundred dollars per day and/or a gross misdemeanor charge, possibly punishable by fine and/or imprisonment. All Hydraulic Project Approvals issued under RCW 77.55.021 are subject to additional restrictions, conditions, or revocation if the Department of Fish and Wildlife determines that changed conditions require such action. The person(s) to whom this Hydraulic Project Approval is issued has the right to appeal those decisions. Procedures for filing appeals are listed below. Requests for any change to an unexpired HPA must be made in writing. Requests for new HPAs must be made by submitting a new complete application. Send your requests to the department by: mail to the Washington Department of Fish and Wildlife, Habitat Program, 600 Capitol Way North, Olympia, Washington 98501-1091; e-mail to [EMAIL REDACTED]; fax to (360) 902-2946; or hand-delivery to the Natural Resources Building, 1111 Washington St SE, Habitat Program, Fifth floor. APPEALS INFORMATION If you wish to appeal the issuance, denial, conditioning, or modification of a Hydraulic Project Approval (HPA), Washington Department of Fish and Wildlife (WDFW) recommends that you first contact the department employee who issued or denied the HPA to discuss your concerns. Such a discussion may resolve your concerns without the need for further appeal action. If you proceed with an appeal, you may request an informal or formal appeal. WDFW encourages you to take advantage of the informal appeal process before initiating a formal appeal. The informal appeal process includes a review by department management of the HPA or denial and often resolves issues faster and with less legal complexity than the formal appeal process. If the informal appeal process does not resolve your concerns, you may advance your appeal to the formal process. You may contact the HPA Appeals Coordinator at (360) 902-2260 for more information. A. INFORMAL APPEALS: WAC 220-110-340 is the rule describing how to request an informal appeal of WDFW actions taken under Chapter 77.55 RCW. Please refer to that rule for complete informal appeal procedures. The following information summarizes that rule. A person who is aggrieved by the issuance, denial, conditioning, or modification of an HPA may request an informal appeal of that action. You must send your request to WDFW by mail to the Washington Department of Fish and Wildlife HPA Appeals Coordinator, 600 Capitol Way North, Olympia, Washington 98501-1091; e-mail to [EMAIL REDACTED]; fax to (360) 902-2946; or hand-delivery to the Natural Resources Building, 1111 Washington St SE, Habitat Program, Fifth floor. WDFW must receive your request within 30 days from the date you receive notice of the decision. If you agree, and you applied for the HPA, resolution of the appeal may be facilitated through an informal conference with the WDFW employee responsible for the decision and a supervisor. If a resolution is not reached through the informal conference, or you are not the person who applied for the HPA, the HPA Appeals Coordinator or designee will conduct an informal hearing and recommend a decision to the Director or designee. If you are not satisfied with the results of the informal appeal, you may file a request for a formal appeal. B. FORMAL APPEALS: WAC 220-110-350 is the rule describing how to request a formal appeal of WDFW actions taken under Chapter 77.55 RCW. Please refer to that rule for complete formal appeal procedures. The following information summarizes that rule. A person who is aggrieved by the issuance, denial, conditioning, or modification of an HPA may request a formal appeal of that action. You must send your request for a formal appeal to the clerk of the Pollution Control Hearings Boards and serve a copy on WDFW within 30 days from the date you receive notice of the decision. You may serve WDFW by mail to the Washington Department of Fish and Wildlife HPA Appeals Coordinator, 600 Capitol Way North, Olympia, Washington 98501-1091; e-mail to [EMAIL REDACTED]; fax to (360) 902-2946; or hand-delivery to the Natural Resources Building, 1111 Washington St SE, Habitat Program, Fifth floor. The time period for requesting a formal appeal is suspended during consideration of a timely informal appeal. If there has been an informal appeal, you may request a formal appeal within 30 days from the date you receive the Director's or designee's written decision in response to the informal appeal. 4 Page 3 of ---PAGE BREAK--- HYDRAULIC PROJECT APPROVAL Washington Department of FISH and WILDLIFE 48 Devonshire Road Montesano, WA 98563 (360) 249-4628 Coastal RCW 77.55.021 - See appeal process at end of HPA Project Expiration Date: September 30, 2013 Control Number: FPA/Public Notice Issue Date: July 07, 2011 124087-1 N/A C. FAILURE TO APPEAL WITHIN THE REQUIRED TIME PERIODS: If there is no timely request for an appeal, the WDFW action shall be final and unappealable. for Director WDFW Gina Piazza [PHONE REDACTED] ENFORCEMENT: Sergeant Jackson (29) P2 Habitat Biologist CC: Russ Ladley, Puyallup Tribe 4 Page 4 of ---PAGE BREAK--- City of Puyallup Development Services 333 S. Meridian St Puyallup, WA 98371 Tel. (253) 841-5537 Fax. (253) 840-6670 ENVIRONMENTAL CHECKLIST Purpose of Checklist: The State Environmental Policy Act (SEPA), Chapter 43.21 RCW, requires all governmental agencies to consider the environmental impacts of a proposal before making decisions. An environmental impact statement (EIS) must be prepared for all proposals probable significant adverse impacts on the quality of the environment. The purpose of this checklist is to provide information to help you and the agency identify impacts from your proposal (and to reduce or avoid impacts from the proposal, if it can be done) and to help the agency whether an EIS is required. Instructions for Applicants: This environmental checklist asks you to describe some basic information about your proposal. Governmental agencies use this checklist to determine whether the environmental impacts of your proposal are significant, requiring preparation of an EIS. Answer the questions briefly, with the most precise information known, or give the best description you can. You must answer each question accurately and carefully, to the best of your knowledge. In most cases, you should be able to answer the questions from your own observations or project plans without the need to hire experts. If you really do not know the answer, or if the question does not apply to your proposal, write "do not know" or "does not apply". Complete answers to the questions now may avoid unnecessary delays later. Some questions ask about governmental regulations, such as zoning, shoreline, and landmark designations. Answer these questions if you can. If you have problems, the governmental agencies can assist you. The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers to provide additional information reasonably related to determining if there may be significant adverse impact. If you are not already submitting an 8-1/2" x 11" reduction of your project site plan to the city as part of a companion case submittal, please submit a copy as a part of this SEPA application. Please submit eight copies of the completed SEPA checklist application packet. ---PAGE BREAK--- Page 2 \data\word\ecapp.doc CHECKLIST NO: A. BACKGROUND 1. Name of proposed project: Clarks Creek Elodea Hand Pulling Pilot Project 2. Name of Applicant: City of Puyallup 3. Mailing address, phone number of applicant and contact person: 333 S. Meridian St Puyallup, WA 98371 Mark Palmer [PHONE REDACTED] 4. Date checklist prepared: June 22, 2011 5. Agency requesting checklist: City of Puyallup 6. Proposed timing or schedule (including phasing, if applicable): Project activities include a pilot project utilizing volunteers to hand pull elodea . The operating window is July 5 through August 1. 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. If the pilot project is deemed successful, we will propose expanding the effort to the entire project site of the current elodea control area, from the 56th St E Bridge to 12th Ave SW Bridge. 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. A JARPA permit will be prepared and submitted to the Department of Ecology for distribution to appropriate agencies. 9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain. No. 10. List any governmental approvals or permits that will be needed for your proposal, if known. JARPA permit ---PAGE BREAK--- Page 3 F:\Yards\Storm Water\Clarks Creek Weed Cutting\2011 Pilot Project\20110622 Pilot Project SEPA Checklist.doc 11. Give brief, complete description of your proposal, including uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information or project description). This project consists of hand pulling aquatic plants in 950 foot length of Clarks Creek located within the City of Puyallup. The pulled plants will be immediately placed on a float, moved to the shoreline and disposed of offsite. We anticipate a near 100% removal of biomass utilizing this method of elodea control. The stretch selected for the pilot project is shallow, allowing waders to perform the work safely. 12. Location of proposal. Give sufficient information for a person to understand the precise location of your proposed project, including street address, if any, and section, township, and range, if known. If the proposal would occur over a range of area, provide the range of boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. T The project area is located in the City of Puyallup, Washington. The project area extends from the 7th Ave SW bridge upstream to a point perpendicular to the south end of the tennis courts in Clarks Creek Park. See Figure 1 Site Map. B. ENVIRONMENTAL ELEMENTS 1. Earth a. General description of the site (circle one): Flat, rolling, hilly, steep, slopes, mountains, other Stream channel. b. What is the steepest slope on the site (approximate percent slope)? 0.5% c. What general types of soils are found on the site (for example: clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland. Stream sediments including sands and silts common to slow moving streams. d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. No. ---PAGE BREAK--- Page 4 \data\word\ecapp.doc e. Describe the purpose, type and approximately quantities of any filling or grading proposed. Indicate source of fill. No grading or filling will be performed on this project. f. Could erosion occur as a result of clearing, construction or use? If so, generally describe. No. g. About what percent of the site will be covered with impervious surface after project construction (for example: asphalt or buildings)? Zero percent. Impervious surfaces are not part of the project scope. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: N/A. 2. Air a. What types of emissions to the air would result from the proposal dust, automobile, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities, if known. N/A. b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. No. c. Proposed measures to reduce or control emissions or other impacts to air, if any. None for this project. 3. Water a. Surface: 1. Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream and river it flows into. The project is situated on Clarks Creek, a Category I water body. Clarks Creek flows into the Puyallup River. 2. Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. This project involves pulling nuisance aquatic growth within the Clarks Creek stream channel. ---PAGE BREAK--- Page 5 F:\Yards\Storm Water\Clarks Creek Weed Cutting\2011 Pilot Project\20110622 Pilot Project SEPA Checklist.doc Volunteers will enter the stream channel, identify elodea weeds, reach the base of the plants until the double node is identified, then pull the entire weed, root and all from the stream. The weed will be placed on a float. Filled floats will be taken to a shoreline collection point and hauled to a disposal facility. 3. Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. No fill or dredge is proposed. 4. Will the proposal requires surface water withdrawals or diversions? Give general description, purpose, and approximate quantities, if known. No. 5. Does the proposal lie within a 100-year floodplain. If so, note location on the site plan. Yes 6. Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. No. b. Ground: 1. Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known. No. 2. Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: domestic sewage; industrial, containing the following chemicals.....; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. None ---PAGE BREAK--- Page 6 \data\word\ecapp.doc c. Water Runoff (including storm water): 1. Describe the source of runoff (including storm water) the method of collection and disposal, if any (including quantities, if known). Where will this water flow? Will this flow into other waters? If so, describe. N/A. 2. Could waste materials enter ground or surface waters? If so, generally describe. No. d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any. N/A. 4. Plants a. Check or circle types of vegetation found on the site: deciduous tree: alder, maple, aspen, other evergreen tree: fir, cedar, pine, other shrubs pasture crop or grain X wet solid plants: cattail, buttercup, bullrush, skunk cabbage, other X water plants: water lily, eelgrass, milfoil, other other types of vegetation b. What kind and amount of vegetation will be removed or altered? Elodea, milfoil and other water plants. c. List threatened or endangered species known to be on or near the site. Chinook Salmon. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any. None. 5. Animals a. Circle any birds and animals which have been observed on or near the site or are known to be on or near the site: ---PAGE BREAK--- Page 7 F:\Yards\Storm Water\Clarks Creek Weed Cutting\2011 Pilot Project\20110622 Pilot Project SEPA Checklist.doc Birds: hawk, heron, eagle, songbirds, other Mammals: deer, bear, elk, beaver, other Fish: bass, salmon, trout, herring, shellfish, other: b. List any threatened or endangered species known to be on or near the site. Puget Sound Chinook Salmon and Bald Eagles. c. Is the site part of a migration route? If so, explain. Yes, Chinook, Chum, Coho salmon all move in to this stream to spawn. d. Proposed measures to preserve or enhance wildlife, if any. The project will only occur within the operating window required by the Department of Fish and Wildlife and will not coincide with fish migration. 6. Energy and Natural Resources a. What kind of energy (electric, natural gas, oil, wood, stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. N/A. b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe. No. c. What kind of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any. None. 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazard waste, that could occur as a result of this proposal? If so, describe. Mechanical failure or fuel spill could result in oils and/or fuels entering surface waters. 1. Describe special emergency services that might be required. N/A. 2. Proposed measures to reduce or control environmental health hazards, if any. ---PAGE BREAK--- Page 8 \data\word\ecapp.doc N/A. b. Noise 1. What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)? None. 2. What types and levels of noise would be created by or associated with the project on a short-term or long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. Volunteers working in the stream will create noise in the project area. Operating times are limited to between 7am and 6pm. 3. Proposed measures to reduce or control noise impacts, if any. Volunteers will be instructed to maintain low noise levels. 8. Land and Shoreline Use a. What is the current use of the site and adjacent properties? Stream corridor, residential backyards, and recreational use. b. Has the site been used for agriculture? If so, describe. N/A. c. Describe any structures on the site. Not applicable. The project limits are confined to the stream channel with the exception of the haul-out site which consists of a quarry spall pad. d. Will any structures be demolished? If so, what? No. e. What is the current zoning classification of the site? The zoning classifications vary along the length of the project/stream and consist primarily of residential categories with some public facilities designation. f. What is the current comprehensive plan designation of the site? Shoreline. g. If applicable, what is the current shoreline master program designation of the site? Category I waterbody. ---PAGE BREAK--- Page 9 F:\Yards\Storm Water\Clarks Creek Weed Cutting\2011 Pilot Project\20110622 Pilot Project SEPA Checklist.doc h. Has any part of the site been classified as an "environmentally sensitive" area. If so, specify. Yes, the entire project area is sensitive because it is a Category I stream. i. Approximately how many people would reside or work in the completed project? None. j. Approximately how many people would the completed project displace? None. k. Proposed measures to avoid or reduce displacement impacts, if any? Not Applicable. l. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any. None. 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing. Not Applicable. b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle or low-income housing. Not Applicable. c. Proposed measures to reduce or control housing impacts, if any. Not Applicable. 10. Aesthetics a. What is the tallest height of any proposed structure(s), not including antennas; what is the principle exterior building material(s) proposed? Not Applicable. b. What views in the immediate vicinity would be altered or obstructed? None. c. Proposed measures to reduce or control aesthetic impacts, if any. None. ---PAGE BREAK--- Page 10 \data\word\ecapp.doc 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? None. b. Could light or glare from the finished project be a safety hazard or interfere with views? Not Applicable. c. What existing off-site sources of light or glare may affect your proposal? None. d. Proposed measures to reduce or control light and glare impacts, if any? None. 12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity? Fishing, swimming, boating, bird watching, athletic fields. b. Would the proposed project displace any existing recreational uses? If so, describe. No. c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any. None. 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. No. b. Generally describe any landmarks or evidence of historic, archaeological, scientific, or cultural importance known to be on or next to the site. None. c. Proposed measures to reduce or control impacts, if any. None. 14. Transportation ---PAGE BREAK--- Page 11 F:\Yards\Storm Water\Clarks Creek Weed Cutting\2011 Pilot Project\20110622 Pilot Project SEPA Checklist.doc a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. Reference Figure 1. b. Is site currently serviced in public transit? If not, what is the approximate distance to the nearest transit stop? No. c. How many parking spaces would the completed project have? How many would the project eliminate? None. d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private). No. e. Will the project use (or occur in the immediate vicinity of) water, rain, or air transportation? If so, generally describe. No. f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. None. g. Proposed measures to reduce or control transportation impacts, if any. None. 15. Public Services a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe. No. b. Proposed measures to reduce or control direct impacts on public services, if any. None. 16. Utilities a. Circle utilities currently available at the site: electricity, natural gas, water, refuse service, telephone, sanitary sewer, septic system, other: None within the project limits. ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- ---PAGE BREAK--- 167 W PIONEER 72ND ST E 66TH AV E 84TH ST E NORTH LEVEE RD E W STEWART STEWART AV E WOODLAND AV E S FRUITLAND 76TH AV E FREEMAN RD E PIONEER WY E 70TH AV E N LEVEE RD 26TH ST NW 52ND ST E FRUITLAND AV E 7TH AV SW 14TH ST SW 48TH ST E 13TH ST SW 56TH ST E 4TH AV NW 5TH AV SW 18TH ST NW TACOMA RD 18TH ST SW 16TH ST SW 9TH AV SW 10TH AV NW TACOMA RD E FIRLAND DR 52ND ST E 5TH AV NW 21ST ST NW 64TH AV E 72ND AV E 23RD ST NW 86TH ST E 50TH ST E 19TH ST NW 88TH ST E 49TH ST E W MAIN 17TH ST SW 68TH AV E 45TH STCT E 66TH AV E 69TH AVCT E 15TH ST NW 16TH ST NW 78TH AV E 87TH ST E HISTORIC WY 12TH AV NW 21ST ST SW MCELROY PL 80TH ST E 10TH AV SW 23RD ST SW ROSE PL 9TH AV NW 65TH AV E 22ND ST NW 60TH ST E 56TH STCT E 4TH AV SW 29TH STPL NW 48TH STCT E 17TH ST NW 83RD ST E 82ND ST E 22ND ST SW 85TH AV E 59TH ST E 13TH AV NW 70TH AV E 8TH AV NW 70TH AVCT E 6TH AV SW 66TH AVCT E 12TH AV SW 76TH AV E 12TH ST NW 14TH AV NW 77TH AVCT E 8TH AV SW 76TH STCT E 74TH ST E 57TH ST E 71ST AV E 80TH AV E 77TH STCT E 58TH ST E 3RD AV NW 75TH ST E 12TH ST SW 23RD STPL NW 85TH ST E 15TH ST SW 20TH ST NW 77TH AV E 71ST AVCT E 81ST STCT E 28TH ST SW 17TH STPL NW 11TH AV SW 13TH ST NW PEACH PARK LN NW 16TH STPL NW 78TH STCT E CORWIN RD SW 61ST ST E 67TH AV E 79TH AV E 75TH AV E 68TH AVCT E 10TH AVCT NW 73RD AV E 83RD STCT E 13TH PL NW 12TH STCT SW 54TH ST E 21ST STPL NW 82ND STCT E RICHARDSON DR 50TH STCT E 8TH AVCT NW 46TH ST E 13TH AVCT NW 18TH ST NW 16TH ST SW 21ST ST NW 22ND ST SW 12TH AV NW 9TH AV SW 12TH ST SW 17TH ST NW 72ND AV E 13TH AV NW 12TH AV SW 86TH ST E 12TH AV NW 71ST AV E 64TH AV E 66TH AV E 8TH AV NW 20TH ST NW 23RD ST SW 78TH AV E 23RD ST NW 23RD ST NW 66TH AV E 48TH ST E 64TH AV E 49TH ST E 12TH AV NW 8TH AV SW 15TH ST NW 21ST ST SW 12TH ST NW 68TH AV E 16TH ST NW 64TH AV E 6TH AV SW 20TH ST NW The map features are approximate and are intended only to provide an indication of said feature. Additional areas that have not been mapped may be present. This is not a survey. Orthophotos and other data may not align. The County and the City of Puyallup assumes no liability for variations ascertained by actual survey. ALL DATA IS EXPRESSLY PROVIDED ‘AS IS’ AND ‘WITH ALL FAULTS’. The County and City of Puyallup makes no warranty of fitness for a particular purpose. Drawn by: Jonathan Wikander 6/2/2011 City of Puyallup Public Works File Name: jwikand/CC/clarks_creek_aquatic_weed_harvet_with_HO_Sites.mxd Clarks Creek Aquatic Weed Harvest Location Map REACH SIX REACH FIVE REACH FOUR REACH THREE REACH ONE REACH TWO 1 inch = 900 feet STATION ONE STATION TWO HAUL OUT SITE #1 CUTTING BEGINS HERE STATION THREE STATION FOUR STATION FIVE STATION SIX STATION SEVEN CUTTING ENDS HERE Clarks Creek Page 1 of 1 Puyallup River 12 St SW Bridge 7 Ave SW Bridge W Pioneer Bridge Tacoma Rd Bridge Stewert Ave Bridge 56 St Bridge HAUL OUT SITE #2 Puyallup Tribal hatchery HAUL OUT SITE #3 "WSU Pump Intake" = Proposed Haul Out Sites * Potential Pilot Project * ---PAGE BREAK--- Name Affiliation Address City Zip Phone Email 7/18 7/19 7/20 7/21 7/22 Notes Mark Palmer City of Puyallup 333 S Meridian Puyallup 98371 (253) 435-3606 [EMAIL REDACTED] x x x Joy Rodriguez City of Puyallup 333 S Meridian Puyallup 98371 (253) 841-5549 [EMAIL REDACTED] x x x Jasmine Hastings PHS, student 2119 7th Ave SW Puyallup 98371 (253) 651-7417 [EMAIL REDACTED] x S Hastings gave verbal acknowledgement of note on sign-in sheet that photos of volunteers may be used in various publications Tim Hastings 9316 212th St Ct E Graham 98338 (253) 846-3240 x S Hastings gave verbal acknowledgement of note on sign-in sheet that photos of volunteers may be used in various publications Lee Boulet creek owner 1922 5th Ave SW Puyallup 98371 (253) 845-6493 x x x Steve Hastings 2119 7th Aev Sw Puyallup 98371 (253) 604-4032 [EMAIL REDACTED] x Steve Vermillion "posse" 3103 31st Ave SE Puyallup 98374 (253) 906-2938 [EMAIL REDACTED] x Tom C. Smillie "posse 1st dis" 1901 4th Ave NW Puyallup 98371 (253) 841-0904 [EMAIL REDACTED] x Tyler J Nagata PHS, student 305 16th St NW Puyallup 98371 (253) 848-5624 [EMAIL REDACTED] x Char Naylor Puyallup Tribe 3009 E Portland Ave Puyallup Tribe 98404 (253) 405-7815 [EMAIL REDACTED] x x x CJ Benavides Jr. Puyallup Tribe 3101 57th Ave NE Puyallup Tribe 98422 (253) 302-0695 [EMAIL REDACTED] x x Elsie Wescott Puyallup Tribe 3009 E Portland Ave Puyallup Tribe 98404 (253) 680-5523 [EMAIL REDACTED] x x x Ann Coon Friends of Clarks Creek 6619 Stewart Ave E Puyallup 98371 (253) 864-6042 x MaryJo Hinojosa Student 1923 10th Street PL SW Puyallup 98371 (253) 273-7527 [EMAIL REDACTED] x Justin Paul Puyallup Tribe 6834 Pioneer Way E Puyallup 98371 (253) 306-3770 [EMAIL REDACTED] x Andrew Bega Puyallup Tribe 6834 Pioneer Way E Puyallup 98371 (253) 680-5566 [EMAIL REDACTED] x Jesse Nitz Puyallup Tribe 6834 Pioneer Way E Puyallup 98371 (253) 680-5566 [EMAIL REDACTED] x Jenny Wu EPA 1200 6th Ave Seattle 98101 (206) 553-6328 [EMAIL REDACTED] x Marchelle Robinson EPA [EMAIL REDACTED] x Laurie Larson WSU 2606 W Pioneer Puyallup 98371 [EMAIL REDACTED] x Nicole Martineau City Council Member 726 21st NW Puyallup 98371 (253) 446-7306 [EMAIL REDACTED] x Doug Hamilton EPA 1200 6th Ave Seattle 98101 (360) 620-0014 [EMAIL REDACTED] x Kim Gridley WSU 2606 W Pioneer Puyallup 98371 [EMAIL REDACTED] x Dave Wetzel PHS/WSU-P 916 19th Ave SW Puyallup 98371 (253) 691-3376 [EMAIL REDACTED] x Reed Wetzel Kalles Jr. High 916 19th Ave SW Puyallup 98371 (253) 691-1683 [EMAIL REDACTED] x 11 Dates volunteer Clarks Creek Elodea Hand Pulling Pilot Project Volunteer Summary List ---PAGE BREAK--- Table - 2 Page 1 of 4 Table 2 - Turbidity Sample Collection Summary (2 Each / Day Operation) Date Collected / Turbidity Sample No. Turbidity Sample Location D/S AM Time TS1 PM Time TS2 Date Turbidity Sample Delivered Date Bill Rec’d For Turbidity Sample #s Date Turbidity Result Rec’d For Sample #s Quantit y of Weed Remov ed 7.5.2011 (TS-1,2) U/S @ 56th St E Bridge 7:30 3:35 Letter dated 7.7.11 Rcd 7.20.11 S1 = 1.9 NTU S2 = 2.6 NTU 0.25 cy 7.6.2011 (TS-3,4) U/S @ 56th St E Bridge 7:40 2:45 7.6.2011 (3;20 pm) SAZ Letter dated 7.7.11 Rcd 7.20.11 S3 = 2.2 NTU S4 = 2.8 NTU 0.25 cy 7.7.2011 (TS-5.6) U/S @ 56th St E Bridge 8:30 1:40 Letter dated 7.9.11 Rcd 7.20.11 S5 = 3.6 NTU S6 = 5.9 NTU 1.00 cy 7.8.2011 (TS-7.8) Tribal Hatchery Bridge 7:39 3:20 7.8.2011- 3:40 pm MP Letter dated 7.9.11 Rcd 7.20.11 S7 = 2.7 NTU S8=10.1 NTU 5.00 cy 7.11.2011 (TS-9.10) 300’ D/S @ 60th St E bridge 8:25 2:00 Letter dated 7.13.11 Rcd 8.1.11 S7 = 3.5 NTU S8=94.2 NTU 3.00 cy 7.12.2011 (TS-11.12) 900’ D/S @ 60th St E bridge 7:20 3:00 7.12.2011 - 3:15 pm SZ Letter dated 7.13.11 Rcd 8.1.11 S7=3.0 NTU S8=46.5 NTU 5.00 cy 7.13.2011 (TS-13.14) U/S Trestle on Stuart Ave E 7:20 3:00 Letter dated 7.19.11 Rcd 7.29.11 S13=6.4 NTU S14=31.1NTU 4.00 cy - sent truck load-1 7.14.2011 (TS-15.16) 2300’ U/S Trestle on Stuart Ave E 7:30 3:00 7.14.11 2:35 pm - SZ Letter dated 7.19.11 Rcd 7.29.11 S15=6.4 NTU S16=20.9NTU 6.00 cy.1st Truck load (C=12y) ---PAGE BREAK--- Table - 2 Page 2 of 4 dumpe d7:3am 7.15.2011 (TS-17.18) 2500’- 3000’U/S Trestle on Stuart Ave E 7:30 2:15 7.15.11 Joy R.3:40 pm Letter dated 7.19.11 Rcd 8.2.11 S17=3.4 NTU S18=7.8 NTU 5.00 cy - Only 2 TS delivere d to Lab. Sent truck load - 2 7.18.2011 (TS-19.20) / (TS-21, 22) @ U/S side of Tacoma Rd Bridge / @ /250’ U/S of 7th Ave SW Bridge 7:30 / 10:30 1:50 / 2:20 Letter dated 7.26.11 Rcd 8.11.11 S19=2.3 NTU S20=28.7NTU S21=2.0 NTU S22=25.8NTU 8.00 cy - Hand pulling operati on in Reach -6 started today. 7.19.2011 (TS-23,24)/(TS- 25, 26) 400’ /1200’ U/S side of Tacoma Rd Bridge/ 150’ / 170’ U/S of 7th Ave SW Bridge 7:45 / 9:00 2:20 / 2:00 7.19.11 – 3:15 pm SZ Letter dated 7.00.11 Rcd 8.0.11 S23=9.0 NTU S24=55.9NTU S25=1.9 NTU S26=2.3 NTU 8.00 cy - Hand pulling was comple ted150’ U/S, yesterd ay pm.sen t truck load - 3 7.20.2011 (TS-27, 28) /(TS-29, 30) 1300’ / 1600’ U/S side of Tacoma Rd Bridge/ 170’ / 180’ U/S of 7th Ave SW Bridge 8:00 / 8:30 1:45 / 1:15 Letter dated 7.26.11 Rcd 8.11.11 S27=21.6NTU S28=19.2NTU S29=1.1 NTU S30=7.9 NTU 6.00 cy - Hand pulling Slow progre ss - Did Cleani ng sweep ---PAGE BREAK--- Table - 2 Page 3 of 4 of por comple ted. 7.21.2011 (TS-31, 32)/ (TS-33, 34) 2000’ / 2500’ U/S U/S side of Tacoma Rd Bridge/ 230’ / 350’ U/S of 7th Ave SW Bridge 7:30 / 9:30 3:00 / 2:00 7.21.11 3:22 pm SZ Letter dated 7.26.11 Rcd 8.11.11 S31=3.4 NTU S32=42.4NTU S33=2.9 NTU S34=21.8NTU 10.00 cy – 3rd Truck load -4 (C=12y) dumpe d 9:30 am 7.22.2011 Friday- Skipped Sampling Today- Ok’d by MP. N / A N / A N / A N / A N / A 8.00 cy - Hand pulling job comple ted 650’ D/S of 7th Ave SW bridge today and thus sampli ng stoppe d-truck load -5 sent. 7.25.2011 (TS-35)) 3500’ ft U/S of Tacoma Rd Bridge (1/2 hr heavy rain at 8:30 am, water turbid, no 10:30 PM Sampl e Skipp ed due to heavy rain visibili ty Letter dated 7.28.11 Rcd 8.11.11 S35=9.3 NTU 0.50 cy -Boat 600’ D/S of Pioneer Ave Bridge. Work stoppe d at noon- low ---PAGE BREAK--- Table - 2 Page 4 of 4 visibility) Visibilit y of weeds. 7.26.2011 (TS-36, 37) 3500’ ft U/S of Tacoma Rd Bridge 7:20 1:00 7.26.11 1:30 pm SZ Letter dated 7.28.11 Rcd 8.11.11 S36=3.4 NTU S37=26.3NTU 8 cy 7.27.2011 (TS-38, 39) 0’ / 200’U/S @ Pioneer Ave Bridge 7:35 3:00 JL Letter dated 7.00.11 Rcd 8.0.11 S38=2.9 NTU S39=16.3NTU 4 cy 7.28.2011 (TS-40.41) 200’/ 1800’ U/S @ Pioneer Ave Bridge 7:05 3:25 7.28.11 3:40 pm JL Letter dated 7.00.11 Rcd 8.0.11 S40=2.2 NTU S41=25.8NTU 8 CY 7.29.2011 (TS-42.43) 1800’ U/S @ Pioneer Ave Bridge / @ Decorsey Park 7:20 11:00 7.29.11 12:30 pm SZ Letter dated 7.00.11 Rcd 8.0.11 S42=8.4 NTU S43=2.2 NTU 2.0 CY - Contrac tor complet ed cutting at 7th Ave SW bridge at 10;30 am per Tom.. TOTAL CY OF WEEDS REMOVED in 2011 = Total 8 Ea Trucks = 12 cy * 8 = 96 cy Wet Volume (Per Contracto r Report) 92.00 CYs – Wet Volum e