Nisqually Reach Pollution Source Identification Final Project Report

Thurston County Public Health and Social Services Department Environmental Health Division

Grant No. G0200281 December 2004

Table of Contents

Introduction ------1

Study Area and Background------2

Beneficial Uses ------3

Project Summary by Task------4

Task 1 – Project Administration/Management ------4 Task 2 – Monitoring Plan QAPP------4 Task 3 – Map McAllister Creek Drainages------4 Task 4 – Sampling for Problem Identification ------6 Task 5 – DNA typing Analysis------10 Task 6 – Septic System Evaluations------12

Appendix A------14 Appendix B------16

Introduction

In November 2000, the Washington State Department of Health downgraded 74 acres of commercial shellfish beds in the Nisqually Reach from conditionally approved to restricted, because fecal coliform bacteria levels in that area failed to meet water quality standards for commercial shellfish harvesting. That official action, taken as a direct result of degrading water quality, triggered three key water quality improvement efforts.

The initial effort was preparation of a closure response strategy by a multi-agency /stakeholder committee. The document, called “Response Strategy for Shellfish Growing Area Downgrades in Henderson Inlet and Nisqually Reach”, was completed in February 2001. The strategy outlines the problems contributing to poor water quality and assigns various tasks and responsibilities to participating agencies.

Parallel to the closure response strategy effort was the creation of a shellfish protection district. In accordance with RCW 90.72.045, Thurston County was required to form a Shellfish Protection District when part of the Nisqually Reach commercial shellfish growing area was downgraded. Through an intensive public process, an ordinance creating the Nisqually Reach Shellfish Protection District was adopted on December 17, 2001.

Thirdly, the Nisqually Reach, Nisqually River and McAllister Creek are included on the 1998 303(d) list of impaired water bodies for fecal coliform bacteria contamination. Washington Department of Ecology (WDOE) is required by the Federal Clean Water Act to conduct a total maximum daily load (TMDL) study for waterbodies on the 303(d) list. The purpose of the TMDL study is to determine how much of a pollutant a waterbody can assimilate, and allocate pollutant load limits to specific pollution sources or geographic segments of the waterbody.

This grant-funded project was designed to accomplish some of the Thurston County identified activities in the closure response strategy as well as activities in shellfish protection district work plan. It also provided funds to assist WDOE staff with the TMDL study. The grant project period was April 2002 through December 2004. The primary project goal was to identify sources of fecal coliform bacteria entering the Nisqually Reach from McAllister Creek and the lower marine shoreline area. The specific tasks in the grant contract are as follows:

Task 1 – Project Administration/Management Task 2 – Monitoring Plan QAPP Task 3 – Map McAllister Creek Drainages Task 4 – Sampling for Problem Identification Task 5 – DNA Typing Analysis Task 6 - Septic System Evaluations

This report is an accounting and summary of the work accomplished through this grant project. One stand-alone report was published for Task 5. The report is titled “Nisqually Reach Pollution Source Identification, Task 5: DNA Typing Analysis”, May 2004.

Study Area and Background

The Nisqually Reach is the marine water along the northeast portion of Thurston County. The Nisqually Reach and Nisqually River form the boundary between Thurston and Pierce Counties. The river empties into the Nisqually Reach area of southern Puget Sound forming an extensive river delta. The river's large watershed extends from Mount Rainier to Puget Sound.

McAllister Creek lies due west of the Nisqually River. McAllister Creek significantly influences the water quality along the Reach as documented in a drogue study completed by the Washington State Department of Health (Meriwether, 1999) and a water quality study done by the Nisqually tribe (1996). McAllister Springs, a municipal water supply for the City of Olympia, is the origin of the creek. The amount of withdrawal by the city influences the stream flow volume. The creek is subject to tidal influence for nearly its entire length of approximately 5.5 miles. Extensive drainage systems exist in the valley between McAllister Creek and the Nisqually River. These drainage systems were installed decades ago to drain the land sufficiently for agricultural uses. These drains discharge into McAllister Creek through tide gates, several of which no longer function to prevent water from flooding back onto the land during high tides.

The Nisqually National Wildlife Refuge is 2846 acres of preserved open space located at the mouths of the Nisqually River and McAllister Creek. Along the marine shoreline of Nisqually Reach, the density of homes, and corresponding septic systems, is approximately 24 houses per mile. There is a small commercial area at the Nisqually Valley interchange of Interstate Highway 5 that includes a restaurant, tavern, service station, RV park, and several other businesses. Most of the land use along the creek is in agriculture use and is zoned "long-term agriculture". However, there is a small residential subdivision adjacent to the creek off Steilacoom Road. There are two county road crossings, and Interstate Highway 5 crosses the creek. Stormwater drainages, associated with road runoff, discharge to the creek at each crossing.

The eastern boundary of the urban growth management area for the City of Lacey is within the McAllister Creek watershed, and is located along the top of the Nisqually Bluff to the west of the creek. Since soils along the top of the bluff are generally very permeable sand and gravel, stormwater runoff from this area has not had a major influence on the water quality of the creek. However, increasing development along the bluff has the potential to do so.

2 The types of land uses in the watershed which could be contributing to the fecal contamination include agricultural activities, on-site septic systems serving residences and businesses, stormwater runoff from roads, and wildlife.

Beneficial Uses

Along the Nisqually Reach there are several million pounds of geoduck resources owned by the State of Washington and managed by Washington Department of Natural Resources. At the southeastern edge of the Reach are approximately 350 acres of shellfish beds, harvested by two commercial shellfish companies. There are over 100 acres of tribal interest in tideland on the Reach. The National Fish and Oyster Company operates a shucking and packing plant on the lower reach shoreline that employs approximately 25 people.

There is considerable public use of the Nisqually Reach. Tolmie State Park is a day-use marine waterfront park on Nisqually Reach. The park has thousands of visitors each year, many of whom harvest shellfish. A public boat launch and the Nisqually Nature Center are located at Luhr Beach at the mouth of McAllister Creek. This public tideland is closed to recreational shellfish harvesting due to the fecal coliform contamination. The 2846-acre Nisqually Wildlife Refuge is located between and along the Nisqually River and McAllister Creek and provides important habitat for many wildlife species.

Washington Department of Fisheries’ Catalog of Washington Streams and Salmon Utilization, 1975, lists Coho and chum as salmon species using the McAllister Creek system.

McAllister Creek is designated a Class AA (extraordinary) water body as defined in the Water Quality Standards for Surface Waters of the State of Washington (WAC 173- 201A). The beneficial uses Class AA standards are designed to protect the following:

Water supplies, including domestic, industrial, and agricultural; Stock watering; Fish and shellfish, including rearing, spawning, and harvesting; Wildlife habitat; Recreation, including primary contact, fishing, boating, and aesthetic; Commerce and navigation.

The fecal coliform standard established for Class AA freshwater bodies is a geometric mean value of 50 colonies/100 milliliters (ml) and not more than 10 percent of all samples obtained for calculating the geometric mean value exceeding 100 colonies/100 ml. The marine water standard is a geometric mean value of 14 colonies/100 ml with not more than 10 percent of the samples exceeding 43 colonies/100 ml. The fecal coliform sample results obtained in this study were compared to the Class AA water quality standards described above.

3 Project Summary by Task

Task 1 – Project Administration/Management

The project duration was April 2002 through December 2004. Progress reports and budget summaries were submitted every six months throughout the project, as required.

Task 2 – Monitoring Plan QAPP

A draft QAPP was prepared and submitted to WDOE for approval on October 28, 2002. The QAPP was approved by WDOE on November 19, 2002. Some monitoring activities funded through this grant contract were covered under the QAPP, titled Quality Assurance Project Plan, Henderson and Nisqually TMDL Study, February 2003, prepared by WDOE staff for the TMDL study.

Task 3 – Map McAllister Creek Drainages

The McAllister Creek originates from McAllister Springs and several other smaller springs discharging from the Nisqually bluff. The springs are less than 10 feet above mean sea level and the creek is only 6.3 miles long. The creek stream gradient is very low and the creek is tidally influenced throughout its length. Much of the land adjacent to the creek, which had once been salt marsh and estuary habitat, was ditched and drained and converted to agricultural land. The drainages discharge to the creek through tide gates, which allow water to flow off the land into the creek but prevent the back flow of water from the creek channel onto the land. During the construction of Interstate Highway 5 through the Nisqually Valley, the original McAllister Creek stream channel between river miles 2.4 and 4.2 was re-routed and the channel riprapped.

A map of the study area was prepared for use in this project and is shown on the following page.

Task 4 – Sampling for Problem Identification

The objective of this task was to conduct water sampling for the purpose of identifying sources and locations of non-point pollution affecting McAllister Creek and the lower Nisqually Reach.

TMDL Study

One of the primary activities in this task was to assist WDOE staff with the TMDL study field work. The following is an accounting of the dates and activities

June 25 & 26, 2002 Field reconnaissance on McAllister Creek October 7, 2002 Time of travel study on McAllister Creek October 28, 2002 Assist with the public workshop about the TMDL study December 16, 2002 TMDL sampling event January 21, 2003 TMDL sampling event February 18, 2003 TMDL sampling event March 5, 2003 TMDL sampling event March 19, 2003 TMDL sampling event April 16, 2003 TMDL sampling event May 13, 2003 TMDL sampling event July 15, 2003 TMDL sampling event August 27, 2003 TMDL sampling event

Thurston County and WDOE project staff also had numerous meetings throughout the project to coordinate activities, discuss sample results and strategize next steps. WDOE will be publishing a separate report on the results and conclusions of the TMDL study.

Luhr Beach

Previous remediation efforts in the Nisqually Reach area had identified a drainage system in the Luhr Beach residential area as a potential source of fecal coliform bacteria contamination. The runoff from this neighborhood discharges directly onto the marine shoreline within the commercial shellfish harvesting area classified as restricted. The stormwater outfall from this neighborhood was sampled on the same days that the TMDL sampling events occurred as well as additional dates. The results obtained early in the project showed elevated bacteria concentrations.

Based on the sample results indicating water quality problems, County staff identified the stormwater drainage system using topography maps, field reconnaissance, local knowledge, and smoke testing. Photographs from the smoke testing done to verify the subsurface drainage portions of the system are included on the following page. A map of the area and its drainage system is shown on page 8. A table of water sample results from various locations throughout the drainage system is shown in Appendix A.

Smoke Testing/Tracing the Luhr Beach Drainage System on October 14, 2003

Appendix A

Smoke coming out of the culvert at D’Milluhr Blowing smoke up the drainage pipe from the and Glacis Streets beach.

Smoke coming out of drainage pipe at the top of Scenic Drive

8 Sampling documented bacterial contamination in this drainage system. Bacteria concentration seemed to be very high during dry weather periods when there was little or no runoff associated with recent rainfall. It was concluded, based on sampling results and findings from the DNA typing, that septic system evaluations were needed in this area, as well as informing the homeowners about the water quality problem in the neighborhood. The septic system evaluation effort and neighborhood outreach will be discussed under Task 6.

Little McAllister Creek

Three stream segment sampling events were conducted on Little McAllister Creek as a result of DNA typing results which showed the presence of E. coli bacteria of human origin. The creek has two branches, both of which originate in wetland areas above the Nisqually Bluff. The headwaters area of the south branch is used for agricultural purposes. The north branch originates in a series of constructed stormwater ponds and altered wetlands in a large residential subdivision. The two branches join in a steep ravine and flow down to the Nisqually Valley, where the creek discharges into McAllister Creek through a tide gate.

Map of Little McAllister Creek and Watershed

Flows through tidegate into McAllister Creek

Mallard Pond Outlet

@ PSE

South of Pacific Ave.

Little McAllister Creek Sampling Sample Date 2/11/04 3/3/04 3/5/04 Fecal Coliform Flow Fecal Coliform Flow Fecal Coliform Flow Sample Site (#/100ml) (cfs) (#/100ml) (cfs) (#/100ml) (cfs) Mallard Pond 10 1.9 15 / <5 1.0 40 / 20 1.2 Outlet South of 10 / <5 0.67 15 / 20 0.58 <5 / 15 0.11 Pacific Ave @ PSE -- -- 10 / <5 1.4 40 /50 1.2 Note: The fecal coliform samples shown are field duplicates taken to increase certainty of the results.

Because the bacteria results during the three sampling events were low and met water quality standards, no additional pollution investigation in the upper watershed area was deemed necessary.

Task 5 – DNA typing Analysis

The results of the DNA typing analysis are reported in detail in the document entitled “Nisqually Reach Pollution Source Identification, Task 5: DNA Typing Analysis”, May 2004, Thurston County Public Health and Social Services Department. WDOE was provided with eight copies of this final report on July 23, 2004.

The goal of the study was to identify the sources of fecal coliform and reduce the amount of fecal contamination in McAllister Creek and Nisqually Reach by using fecal coliform sampling and a DNA ribotyping methodology to identify the E. coli isolates from water samples collected at predetermined locations

Various land uses in the McAllister Creek basin prompted questions about possible bacteriological sources. Specific sampling locations were included in the study design to answer questions about what and where possible contamination sources were.

Below are the questions the study was designed to answer and the sampling sites selected for that purpose:

1. Shellfish Growing Area: What bacteria source types are found in the growing waters? 9 Sample WDOH marine stations #224 and 225in the growing area

2. Residential Land Use Impacts: Are rural residential impacts causing problems, i.e. humans, failing septic systems, domestic pets? 9 Sample the stormwater pipe in the Luhr Beach neighborhood and in Little McAllister Creek downstream of the residential area.

10 3. Wildlife refuge: Is the wildlife from the refuge a major contributor? The Nisqually Wildlife Refuge is a large area in the McAllister Creek watershed. It is home to hundreds of bird species and other wildlife. 9 Sample the water discharging from tide gate #2 out of the refuge.

4. Commercial I-5: What sources are in the stormwater from the commercial area? A small commercial area and an RV park are adjacent to the creek. 9 Sample the water behind tide gate #1 which receives stormwater from the commercial area. (NOTE: Sampling at this location was discontinued during the study because the water was stagnant with only intermittent flow.)

5. Road Runoff: How does stormwater from the interstate and Martin Way affect the water quality? The Interstate Highway 5 and the local arterial, Martin Way, bisect the basin. 9 Sample the stormwater off Martin Way and from I-5.

6. Commercial agriculture: Are livestock, animal waste management practices, or manure applications contributors of fecal pollution to the creek? The creek flows through acres of agricultural land in the valley. Drainage systems out of these lands discharge to the creek through tide gates. 9 Sample the water behind five different tide gates draining agricultural lands.

7. Tributaries: Do tributaries contribute to the pollution problem? Medicine Creek sub-basin has a mixture of land uses, including agriculture and rural residential. The creek flows into McAllister Creek through a tide gate. 9 Sample the water behind the Medicine Creek tide gate.

Summary of DNA-Typing Study Design

• 10 visits to each land use site were made • 5 water samples per land use type per visit – in some instances the land use type was represented by multiple locations • at least 2 E. coli colonies per water sample were cultured • at least 2 isolates per water sample were DNA typed

Conclusions of DNA-Typing Study • The number of isolates matched (89%) exceeded anticipated results. • Birds are the dominant source seen overall. • Cows are the second most frequent source in actively grazed agricultural fields. • After birds, canine and rodents (wildlife) are predominant at sites where there is limited human activity. • Human sources are second most frequently seen source at the residential sites and are present where hunting is leased.

11 Recommendations of DNA-Typing Study • Work with land owners to manage animal waste to keep it from entering ditches that flow to McAllister Creek. • Continue to investigate the Luhr Beach neighborhood for sources accounting for the elevated bacteria levels. • Investigate the sub-basin that feeds Little McAllister Creek.

Task 6 – Septic System Evaluations

In June 2002, a septic system adjacent to commercial shellfish beds along the lower Nisqually Reach was dye traced at the request of the homeowner. There was considerable earthquake damage to the home from the 2001 Nisqually earthquake, and the concern was that the septic system may have sustained damage as well. The dye test was negative.

Throughout the project, water quality sampling results from the Luhr Beach neighborhood drainage pipe that discharges onto the beach showed elevated fecal coliform bacteria levels, especially during the dry season (See data Appendix A and Map on page 8). The geometric mean value of seventeen samples collected from the drainage pipe is 1027 organisms per 100 ml. The results ranged from 15 per 100 ml in December 2003 to 1,090,000 per 100ml in August 2003. The DNA typing study showed that human sources of E. coli bacteria were identified in 4 out of 10 sampling events. The area is poorly suited for on-site sewage systems with fine textured silt loam soils with low permeability and high runoff potential. The land was subdivided in the 1950’s and most of the on-site sewage systems are greater than twenty years old. There are several springs throughout the area, and a system of open ditches and subsurface drains that route water directly to the marine shoreline. Based on sampling results and site conditions, it was determined that the on-site sewage systems in this neighborhood should be evaluated using the dye-tracing method.

Topographically, houses, and their associated on-site sewage systems, in the southwest part of the neighborhood are higher in elevation than those to the northeast, nearer the marine shoreline. Therefore, it was necessary to begin dye tracing those furthest ‘downstream’ in the drainage system so that one test would not interfere with another. It was also determined that some systems would need to be tested during the dry season and others during the wet season, based on observations of flow and sampling results.

During the summer 2003, department staff requested permission for septic system dye tests from the first two homeowners. Both homeowners refused to give consent for the tests. After several months of effort to obtain consent, the department requested a search warrant from the court for the first residence. The search warrant was granted on December 11, 2003 and the system was dyed on December 16, 2003. The following week, during monitoring of the test, evidence indicating that the homeowner had pumped the septic tank, including the dye from the test, was documented. The homeowner did

12 not respond to attempts by staff to discuss those observations, so the test was considered incomplete. The homeowner was notified in writing of that determination.

On July 27, 2004, a neighborhood meeting was held at the Nisqually Nature Center. WDOE staff for the TMDL project, WDOH, shellfish program staff, and Thurston County staff presented information to residents about the pollution problem in their neighborhood and requested their assistance and cooperation to address the problem. The meeting was well attended by approximately twenty-four residents. A fact sheet about the problem was distributed to residents at the meeting (See Appendix B).

Consent for septic system dye tests was given by many of the residents. However, consent was still not received from the two homeowners who had refused consent in 2003. After negotiating with the attorney representing one of those homeowners, consent was granted. It was necessary to go to court and request a search warrant to conduct the other septic system dye test. The search warrant was issued on August 23, 2004.

The dye tests for these two septic systems were done on August 24, and August 30, 2004 using two different dyes, fluorescein and rhodamine WT. Both dyes were recovered in the drainage system. A fecal coliform bacteria result of 15,500 organisms per 100ml was also obtained at the same location that the dyes were recovered. With this information both systems were confirmed to be failing, and notices of violation were sent to the owners on October 19, 2004. Department staff has begun working with a septic system designer, hired by both homeowners, to repair these failing systems.

Although the grant project has ended, Thurston County will continue to evaluate septic systems in this neighborhood through the 2004-05 wet season to reduce the bacteria loading from the drainage system serving this area.

13 Appendix A

14 15

Appendix B

Pollution Source Investigation at Luhr Beach

What is Being Done and Why?

Though the marine water quality of Nisqually Reach is usually excellent, the area is impacted by nonpoint pollution. In June 1992, the State Department of Health restricted shellfish harvesting on 1000 acres of commercial shellfish beds after rainfall greater than one inch in a 24-hour period due to water quality problems. In 2000, 74 of those acres near the mouth of McAllister Creek were further downgraded to restricted, but 20 acres to the northwest were upgraded to approved. Also in 2000, the public tidelands near Luhr Beach were closed for recreational harvesting due to water quality problems. In 2002, 960 acres of tidelands were upgraded to approved harvesting status. However, in July 2004, 40 acres of commercial shellfish beds offshore of Luhr Beach remain restricted and the public tidelands are still closed for harvesting.

As a consequence of 1992 downgrade, representatives from various state and local agencies, citizens and tribal representatives wrote a Closure Response Plan which detailed how the pollutants would be identified and what steps would be taken to correct identified problems.

From 1992 until the 2000 reclassification, various agencies and the tribe worked to identify and correct nonpoint problems. The 2000 downgrade of the 74 acres to restricted status required Thurston County to form a Shellfish Protection District. That District has been in place since December 2001. The Nisqually Reach Shellfish Protection District Stakeholder Group has been meeting since April 2002, and in July 2003 published their report and recommendations for action.

Thurston County Environmental Health Division has been working on a grant-funded Nisqually Reach pollution source identification project since early 2002. Through this and earlier water quality sampling efforts, a stormwater discharge onto the beach approximately 100 feet west of the Luhr Beach boat launch was been found to be a serious source of bacterial pollution. The drainage from most of the Luhr Beach neighborhood flows to that discharge onto the beach.

What is the Concern with Fecal Coliform Bacteria?

Fecal coliform bacteria are found in the gut of all warm-blooded animals, and are used as an indicator of fecal waste contamination in water. Though most coliform bacteria are not harmful, their presence means that the water is contaminated and could contain other harmful organisms. If fecal coliform levels are too high in freshwater, it could mean the water is not safe for swimming or wading. In the marine water, it could also affect the safety of eating shellfish. Shellfish get their food by filtering the water. As the shellfish pump water through their bodies, bacteria and viruses present in the water can be concentrated in their tissue.

17 Luhr Beach Stormwater Outfall and Other Project Sampling

Between December 2002 and June 2004, Luhr Beach, Nisqually Reach and McAllister Creek sites were sampled repeatedly under various weather conditions. The table on the next page shows the Luhr Beach sampling results from both a stormwater pipe and a drainage that comes down a small ravine and flows onto the beach at the same location. The stormwater pipe flowing onto the beach has serious fecal coliform contamination, especially during dry weather conditions.

The state water quality standards for Nisqually Reach are for freshwater entering the Reach not to exceed a geometric mean value of 50. The mean value for the Luhr Beach pipe is 1264, which significantly exceeds the standard. Individual sample results were as high as one million bacteria per 100 ml.

Thurston County Public Health and Social Services Department Luhr Beach Storm Water Sampling Results Date Fecal Coliform/100ml South Pipe North Flow Down Ravine Combined 12/16/2002 1000 1/21/2003 530 2/18/2003 43 3/5/2003 965 3/19/2003 820 45 650 4/16/2003 1100 15 900 4/24/2003 5/5/2003 6000 275 5/13/2003 270 6/26/2003 2300 7/15/2003 1200 no flow 8/27/2003 1,090,000 no flow 9/15/2003 870 10/14/2003 368 12/11/2003 490 12/16/2003 12/23/2003 15 30 2/11/2004 320 <5 3/18/2004 310, 290 360, 400 4/14/2004 360 5/27/2004 37000, 62000 6200, 4700

The State Department of Ecology is concluding a Total Maximum Daily Load (TMDL) Study for Nisqually Reach and McAllister Creek. The county’s field work has been coordinated with that effort. The following graph presents a comparison of Luhr Beach fecal coliform values to the McAllister Creek study sites.

19 Geometric Mean Values by Sampling Site

10000

1000

100

1 Fecal coliform / 100 mL Geometric Mean Values 3 5 9 er I-5 st 234 Way Ag Ag 4 Ag Ag g 13 each li reek uge A C W: in ef cAl ne: S R ne i i arine: 224 ife Luhr B M Mar ldl edic W: Mart i Little M M S W

E. Coli DNA Typing

An emerging technique, called Microbial Source Tracking (MST), is being used to identify sources of fecal pollution. How it works is… Some E. coli bacteria found in the gut of different warm-blooded animal groups, including humans, have genetic differences. By examining the DNA patterns, or genetic codes, of the E. coli bacteria found in the water and comparing them with the DNA patterns of E. coli known to exist only in certain animal groups, it is possible to determine the sources of pollution.

Samples from the Luhr Beach pipe were collected and sent to the Environmental Health Institute in Seattle for DNA typing. The outcome of that work is as follows:

• Water samples were collected 10 times from December 2002 to August 2003. • 59 E. coli isolates from Luhr Beach were DNA typed. • Human sources of E. coli bacteria were found, as well as canine/dogs, rodents, and birds.

Frequency of Source Occurrences Luhr Beach 10 samplng events

10 8 6 4 2 0 # of sampling events

ian ne og v A D age Bovi anine odent C accoon R nknown sew R U an/ um H

Luhr Beach Summary

♦ Construction of homes began in the 1960’s ♦ No plat was ever submitted ♦ Drinking water is provided by individual wells ♦ Soils throughout much of area are tight clays ♦ Well depths range from 44’ to 180’ ♦ Combination of private and county owned roads ♦ Numerous springs exist throughout neighborhood ♦ Drainage system includes both subsurface pipes as well as open ditches ♦ Most neighborhood drainage flows down to the beach at one common point ♦ Unlike most water quality problems investigated, the bacteria levels in the Luhr Beach drainage are highest during the dry, summer period, making it necessary to conduct investigations during summer months as well as the more common wet season.

Thurston County Public Health and Social Services Department Environmental Health Division, Resource Protection Section Office Address: 921 Lakeridge Dr SW, Olympia, WA 98502 Mailing Address: 2000 Lakeridge Dr SW, Olympia, WA 98502 Phone: 360-754-4111, TDD: 360-754-2933

To request this report in an alternative format, please contact Sue Davis at 360-754-4111 ext. 7316

2004 SD