NPC Editor's Note: This document is under construction and has not been check for accuracy with the original.

Review of the McCulley, Frick and Gilman
Air Quality Survey
For SEA-TAC Airport
And Summary of the Available Information
On Air Pollution From Jet Aircraft

D.L. DesMarais

May 1995



Table 20 Page 39
Results table 10/26/93
TPH LEVELS (Total Petroleum Hydrocarbons) 11/26/93
Tentatively Identified Compounds 12/14/93
Aldehydes results 11/26/93


On four days in 1993 during October, November and December, McCulley, Frick and Gilman, Inc. (MFG) performed an air quality survey at and near SEA-TAC Airport. An estimation of emissions analysis had been previously conducted by the Department of Ecology, completed May 1991 which used an Emissions and Dispersion modeling System (EDI4S). Some of the results of the EDI4S provoked a great deal of public concern, mainly due to the high concentrations of benzene predicted in localized hot spots in the communities surrounding SEA-TAC Airport.

The MFG survey was initially intended to be a follow-up to either validate or disprove the EDMS estimates. However, much of the sampling done by MFG did not follow specific criteria on location or scenario for sampling the worst case predictions. The sampling time of year, days of the week and weather were more conducive to best case scenario. The results, many of which are quite alarming, however, captured high levels of benzene despite the above mentioned conditions. Benzene and formaldehyde were detected at levels far above the Washington Administrative Code acceptable source levels. Since averages in the codes are based upon yearly figures, an annual amount is difficult to arrive at using only four days of 6-8 hour sampling periods. However, using a method suggested by Mr. Fred Austin of Puget Sound Air Pollution Control Agency*(PSAPCA) the yearly is in excess of allowable limits for benzene and formaldehyde, but the 8 hour average for benzene, when used as a yearly figure is 100 times over the allowable safety limit.

Unlike most industry, airports pollute 24 hours per day. Although the yearly average of benzene is only 13 times greater than the acceptable source limit, accumulations of benzene and other hydrocarbons are excessive even in the areas surrounding SEA-TAC Airport. One site in Normandy Park shows levels of benzene equal to the airport findings. This residence also shows significant levels of hydrocarbon emissions referenced to jet fuel. (See Health Issues for effects of benzene)

The Draft Environmental Impact Statement (DEIS) and the Port of Seattle documents claim that the major impact pt SEA-TAC Airport seems to be pollution from automobile traffic. And they have also stated that the air quality is similar to that of other urban areas. Strangely enough, although the claim is that cars are the major polluter at SEA-TAC, the DEIS shows relatively no pollution contribution from the nearly 1,000 truck trips per day necessary to construct the third runway plateau.3 (See Urban Areas for comparison analysis)

The foregoing summary outlines the findings of the l4FG Survey, addresses the issue of contribution factors of cars compared to jet aircraft emissions from EPA documents, analyzes the other urban studies used for comparison to SEA-TAC and potential problems with the l4FG sampling methodology.

For the supposition that SEA-TAC Airport air pollution is dominated by automobile traffic, the total petroleum hydrocarbon (TPH) figures which are referenced to jet fuel show that the airport area is severely affected by jet fuel emissions.

The comparison to other urban areas is outdated and for the few emissions used for comparison, SEA-TAC Airport is worse than all the current data, worse than all the industrial sites for most emissions of concern such as benzene and formaldehyde, and only better than studies at least five years old from areas such as Southern California urban districts-sampled during spring and summer when pollution problems are usually severe.

An estimation of cancer risk increase developed for the Midway Airport in Chicago by the EPA has been analyzed for SEA-TAC emission values of benzene, formaldehyde and the modeled rates of particulates from EDMS. This evaluation shows that SEA-TAC Airport contributes a cancer risk increase in the area and should be monitored as a source, and controlled by agencies responsible for protecting the public health from exposures to cancer causing air pollutants.

The risk increase exists for only three emissions, therefore, it should be apparent that there may be tens or even hundreds of other carcinogenic compounds and/or combinations of molecules Which could contribute far more morbidity and mortality statistics With increases in aircraft traffic. In searching the available information, there are at least eleven additional carcinogenic compounds in jet exhaust which have similar adverse affects as benzene and formaldehyde in lower values. These include polycyclic aromatic hydrocarbons, benzo(a)pyrene and 1,3-butadiene. (1,3- butadiene was found to be the major contributor to cancer risk increase in Chicago Midway study, above benzene and formaldehyde) The data also shows that the determinant factor in emissions is not the engine design but the fuel. Since fuel has not changed, it is inconsistent for the DEIS or any other source to claim that the newer engines emit less emissions. The newer engines are larger and may emit more.'

It has also become apparent that there is a lack of data, a scattering of data over decades, cities and agencies. Emissions factors and studies are few and far between and there seems to be no definitive data which encompasses all components of jet fuel, exhaust, epidemiological studies on effects of jet aircraft pollution for human populations exposed on a 24 hour per day basis to ALL pollutants as single or combination products of combustion. This lack is puzzling considering the power and authority of agencies involved in the national air transportation industry. Unfortunately for those living near airports, this lack may not be accidental.

The information gathered and used for this report, encompasses subjects related to air pollution in general and specifically, air pollution from aircraft. This represents years of gathering data by some dedicated activists at quite an expense to themselves.

Nitrogen dioxide has been included in the DEIS4 at a five minute average. Average of 0.lppm is above the NAAQS standard of 0.053 ppm. The maximum is also above the limit at 0.3 ppm. However, no standards exist for a five minute average, therefore, any sampling method of criteria pollutants which do not consider 1 hour, 3 hour, 8 hour, 24 hour or annual average allowable levels is questionable.

It appears from the modeling such as the EDMS DOE 1991 report, the other available information and monitoring that the third runway project (and even the existing airport) does not meet the local, regional and national standards on criteria pollutant levels. It would be unreasonable to expect that a third runway project would conform to the State Implementation Plan because of this reason.

Appendix A contains selected pages from the MFG report and include samples cited within this summary. Also included are the maps of site locations, their description and wind models for sampling dates.

Exhibit I is a U.S. Department of Commerce Environmental Sciences and Services Administration Weather Bureau emission plume width and orientation estimate for SEA-TAC Airport landing and take- off pattern. The greater length of the landing plume is expected due to the longer period of time -that planes reduce altitude and remain in pattern as compared to takeoff height and subsequent dispersion.

*Eight hour average converts to a 24 hour by multiplying by .3 and a yearly by .4. However, 8 hour average may represent yearly values. Yearly average must follow criteria for gathering proper mean.

1. WAC173-460-150 MFG pages 30, 31, 39
2. Forum April 1995 and DEIS page D-68, 69
3. DEIS page D-10 (..."primary emission sources includes motor vehicles...and to *lessor extent aircraft and aircraft ground support vehicles.")
*The spelling of this word has been taken directly from the DEIS. The mistake is a product of the author(s) of that document, not the present summary.


The Port of Seattle's Request for Proposals & Draft Scope of work states: "include one or more upwind sites and an arc of downwind sites in order to provide information about the width and orientation of the emissions plume."1 (See Exhibit I at end of Summary for width and orientation of plume2)

August 1992 SEA-TAC Forum called for a two-phased study, one a preliminary survey of emissions, especially benzene, to determine how a second study or phase would consist of a more comprehensive assessment. Sampling suggestions made at an Air Quality planning agency meeting to POS representative(s) included "testing remote sites off airport property in order to provide some comparative data, re: pollution levels."3 The UW Campus and Bellevue were suggested. The UW or Bellevue was not analyzed and the only comparative data in MFG is to other urban areas.4

"The POS clearly wants to do a quick pilot study in 9/92 (using badges) to gather initial data."5 "The focus is on aircraft operations as compared with background levels and other sources."6 Background levels were not included in MFG report.

The EDMS model performed by the Department of Ecology in 1991, "evoked a very concerned response from the nearby community... pollutants of concern were benzene and other VOC's."6

One of the preliminary sampling periods is summarized in the DEIS. Formaldehyde and carbon moNOxide were sampled per officers complaints of “headaches, dizziness, lightheadedness, etc."7 Although the report did not detect formaldehyde the detection limit or base used was an amount equal to 245.6 µg/m3 , an incredible amount compared to the ASIL of .077 µg/m3. In the same sample group, CO is shown in excess of local 8 hour standards at Delta Departure Gate on 11/27/92 at 10.0 ppm with a peak potential hour exceedance of 79.0 ppm. (8 hour standard = 9ppm 1 hour =35ppm)


1. Why wasn't the background information included in MFG?
a. Why was the background site of Normandy Park not isolated?
2. Why were the EDMS modeled hot spots for benzene, I.e., Seattle Christian School, not sampled in the MEG survey?
3. Why was such a high detection limit used for the formaldehyde sampling?

1. POS page 5
2. Plume data from Western Region Technical Memorandum No. 58 Salt Lake City, Utah October 1970
3. Appendix I, page 24 Air Quality Planning Meeting, suggestion made by Mr. Pade of PSAPCA, seconded by Dr. Sanders
4 . MFG page 32
5. Appendix I, page 23 .
6: STIA Air Quality RFP, page 4
7. DEIS page D-99

Upwind VS Downwind II

Page iii MFG. Canister sampling data did not indicate variations with meteorology because of several reasons. Some of the upwind vs. downwind sites were reporting similar results when averaged to obtain a mean, but some of the sites were not actually upwind or downwind sites in consideration of winds.

For instance, on page 28, site 5 and 8 are the only true upwind/downwind sites for the reason that with winds out of the north, northeast, sites 3 and 4 are away from the wind direction and therefore, cut of the direct path of the exhaust plume, while site 5 is out of place for most of the emissions from the main takeoff runway, 16L 34R. Site 9 is not an ideal comparison site since it falls into one o± the identified EDMS hot spore for several wind direction models1 and consistently registers greater values in MFG.

Site 8 is tine more ideal location for upwind, and if a comparison is made between. site 5 as downwind and site 8 as upwind for 10/25, it appears that there is a difference. However, the EDMS model showed considerable hydrocarbon emissions accumulating in the area of sites 3 and 4 with sites 5 and 6 outside the dispersion contour in the O· and 345· wind direction. In fact, of the south sites, 5 and 6 do nor fall within any of the identified EDMS contours. EDMS does not have a scenario for wind direction roughly 45-90· which comprised some of the winds for monitoring performed on 10/25 and 10/26.

Taking 11/26 for an example, during a south flow mode, all values added with respect to MFG upwind/downwind sites, downwind shows a greater overall mean average of 1.247. In south flow mode, site 9 accounted for higher values and brought the average for downwind up considerably, while throwing off north flow upwind/downwind. Site 9 should be considered a confounding factor and isolated for the specific reason of the higher values in both modes.

December 14 sampling comprised winds which varied from south 180· to west at 345·. Downwind sites ideal for wind model would be to the north and east. Site 8 is shown as downwind for MFG. This site should be dropped as it is ideally upwind. This leaves sites 2, 4, 9, 12 and 13 for downwind, sites north and east and 5 and 8 for upwind, sites furthermost west. An overall mean greater average of .244 for downwind is found in this method. However, the most significant find is that values are greater for 9 of the 13 emissions with this scenario and CO adds 10 of 13 and an overall mean greater of .76 for benzene.

Scoping criteria called for an arc of downwind sites. The arc was placed with respect to south and southwest. This is appropriate with winds out of the north, northeast, however, the EDMS showed heavy accumulations near Seattle Christian School and this may be a purely topographical consideration. Where any area showing accumulation has a high concentration in a model, it may be considered a hot spot where winds are not conducive to dispersion. No sites were placed within the south area of hot spots, nor near accumulation model for east of runway 16L 34R.2

Scoping criteria for the width of plume and orientation of emissions was not followed. This consideration has not been resolved, but reference has been made previously in a Weather Bureau Report.3 This reference shows a 12 mile dispersion of emissions during landing in a fan shaped area and 6 miles for takeoffs. The Normandy Park site, 7, would be included into this dispersion area and the TPH (total hydrocarbons referenced to jet fuel) levels show on daily summary that this property is affected by emissions from jet exhaust.

Note that the downwind position of site 4 on 10j25 has a lower value for benzene than the further downwind site 3. The hydrocarbon dispersion model for EDMS shows for the o· wind model a heavy concentration further southeast from runway 16L 34R. This is consistent with the prediction of accumulations in the model and higher values may have been noted should sites have encompassed the Seattle Christian School area.

According to provisions of the four-post plan, planes were to utilize runway 16L 34R primarily for takeoffs and runway 16R 34L for landings. This would mean that during the upwind/down- wind inventory, 10/25, 26, site 4 would capture a plume for take-offs, while site 5 would capture landing plume. Site 5 is further north of the end of runway 16L 34R, and would not be in a position similar to site 4 whatsoever. This configuration, considering the four-post plan and previous determinations from EDMS and other sources, of the differences in emissions and rates for the L/T/O cycle, is not logical. It is helpful to note the differences in reporting between sites 4 and 5 for 10/25, 26 and 8 and 9 for 11/26, 12/14:

Site 4 (downwind plume takeoff) 10/25 showed values of methyl chloride, tetrachloroethene, styrene, and 1,3,5-trimethylbenzene and site 5 did not report these compounds. There are no extra compounds reported for site 5 which did not also show values at site 4. For tentatively identified compounds, site 4 shows isopropyl alcohol, site 5 does not, and site 5 shows butyl alcohol and site 4 does not. 10/26 and11/26 landing runways 5 and 8 both show levels of hexane in tentatively identified compounds, and their counter parts for takeoff on those days, sites 4 and 9 do not.5

All dates represented show differing emissions for the two runways and it would seem reasonable with respect to the information on the L/T/O cycle that emissions would show differences in values for takeoff vs. landing.

The followwing are figures from Weather Bureau renort on emissions factors. Although the information is over 20 years old, the engine type has not changed much and the fuel estimates are similar for otIner studies more current:6

Departures Lb. Fuel*
CO NOx as NO2 Hydrocarbons Aldehydes PM
J-57 8.4 9.9 3.0 0.19 -
TF-33 8.0 5.2 12.0 1.0 3.4
Arrivals Lb. Fuel
J-57 15.2 10.7 3.8 0.25 -
TF-33 12.6 4.0 17.0 1.2 4.0

It is apparmt from this table th?at the emission factors are different ljetween tak.eoff md arrival. Also shown in this report are fuel ratios for amounc b1Jrned in turds for takeoff as ccmared to arrivals :7

Departure Lb./Hr. **
CO NOx as NO2 Hydrocarbons Aldehydes PM
J-57 17.5 53.8 1.2 0.5 -
TF-33 3.0 28.4 2.4 16.2 -
Arrivals Lb./Hr.
CO NOx as NO2 Hydrocarbons Aldehydes PM
J-57 27.6 32.1 1.1 0.2 -
TF-33 12.7 10.4 9.3 0.14 10.8

*Pounds of ml lutarz per 1,000 pounds of fuel
**Pounds of gel luta-zt per ho.Jr operation

Average fuel consumption rates in pounds per minute:8

JTBD-7 using Turbine A fuel: Approach 66 Takeoff 142

JTBD-1 using JP-4 fuel: Approach 63 Takeoff 125

Arrivals generate more emissions per pounds of fuel burned. Arrivals are responsible for greater values overall with few exceptions. Nitrogen oxides as nitrogen dioxide is greater during takeoff and this value in pounds per hour is consistent with the EDMS estimates of 1991 which show greater NOx takeoff rates.

Ideally, site 4 for north flow would be better located to the southwest end of runway 16L 34R rather than southeast. Site 8 would be more ideally located to the northeast of runway 16R 34L for south flow downwind.

Please notice in appendix B of MFG that all aldehyde samples with individual sites reasonably placed showed greater differences in values with direct respect to upwind/downwind consideration.

It is also good to note that the majority of sites fall to the east of the ADA. This is discussed further in meteorology/ mode. However, there are no corresponding sites to the west of the AOA, which may have been a determinant factor in lack of upwind/downwind differences.


1. Does the higher value at site 3 on 10/25 for benzene suggest that the tank farm is generating aromatic leaks?
2. Why does site 9 show overall greater values without regard to upwind/downwind consideration?
3. Why do none of the sites for north flow at south end of airport fall into the middle of EDMS predicted hot spots?
4. Why is site 12 used for downwind in south flow mode when there are no corresponding sites in the ADA between 5 and 8 to the west of runway 16R 34L?
5. Did the POS chose the sites, or did MFG?
6. How was the arc determined?
7. Why were there no references to preliminary studies in MFG?

1. Seattle Tacoma International Airport: Air Pollutant Contribution May 1991 Air Quality Program Department of Ecology page A5-3, 6, 9, 12, 15. Hereinafter referred to as EDMS

2. Ibid, page A5-2, 4, 5, 7, 8, 10, 11,13, 14

3. U. S. Department of Commerce Environmental Science Services Administration Weather Bureau, Weather Bureau Technical Memorandum WR-58 Air Pollution by Jet Aircraft at Seattle-Tacoma Airport Wallace R. Donaldson National Weather Service Office Seattle- Tacoma, Washington Western Region October 1970 page 13 Figure 4 (See enclosed Exhibit I for width of plume and orientation)

4. Mcculley, Frick & Gilman, Air Quality Survey, Final Report Seattle-Tacoma International Airport January 1995 Appendix A TPH Site 7. Hereinafter;.. referred to as MFG

5. Ibid Appendix A, Tentatively Identified Compounds

6. U. S. Department of Commerce, Donaldson, page 9 Table 7

7. Ibid page 17 Table 4

8. Ibid page 20 Table 8

9. EDMS pave Al-6, 7. Compare DC-10 takeoff factors NOx at 215.30 per engine with approach rate of 16.44, geomode 1 and 8.


The MFG survey concluded that concentrations of pollutants measured were comparable "...with measured concentrations within the range observed in other urban areas."1 Using an overall mean for all pollutants for industrial sites listed in MPG, SEA-TAC Airport is worse than 14 of the 20.

Of all the studies, many which cover the years 88, and 89, none are current within the past three years except for the comparison of Atlanta. TAMS is referenced for 88, 89 but the information is brought forward by Evans, et. al. dated 1992.2 The Atlanta study is dated 1993 but uses comparisons from as early as 6/1980. This would suggest that current data may not support a true comparison, but older studies, potentially indicative of higher emission factors from automobiles, especially those from urban Southern California during summer months 1988 and 1989, are the only available data that create the appearance of similarity.

Many of the industrial studies cited for reference could be considered some of the most polluted areas in the nation. Many of the comparisons for aldehydes come from Southern California during summer which should be considered a worst case scenario. These samples, much more numerous than that taken at SEA-TAC by MFG, may also represent a more accurate accounting. For example, Atlanta GA shows an overall mean of 2.9 ppb* formaldehyde as the most current sampling gathered from 217 samples, compared to SEA-TAC's 12 samples. Sampling time of year is an extremely important factor and these collected from Atlanta during July may be the highest yearly average reported. The rest of the samples represented have nothing more current than 1990 and for all formaldehyde samples, SEA-TAC values are higher for every value represented within the past five years.

The sampling data also includes averages for MFG obtained by adding all values together and dividing by the number of sites. There are occasions when site 7 (Normandy Park) did not show values or showed much lower values than the sites on and near SEA-TAC Airport.3 However, when these low or no values are averaged into the mean, the average is reduced. This seems to be in direct conflict with the original scoping data which called for an off wind site for background data.

An example of this undesirable methodology would be to average all reports for Toluene on 10/26. Site 7 did not report any value and a high of 40.0 ppb was detected at site 8. The mean value is calculated at 8.85 ppb for this data. If site 7 is dropped from the list, the mean is 9.95.4 If this value is used to average then the mean for comparison to other urban areas is 6.6 ppb rather than 5.I and the comparison begins to look much differently in that SEA-TAC's 6.6 ppb is now higher than 16 of the 19 comparison values by 2.5 ppb rather than 1.0 ppb.5 There are similarities for emissions for numerous reports and subsequent averages.6


Other cities used for coriparison are listed with their non-attainment criteria pollution problems and designation. *TAMS data shows study commenced in 1985, completed in 1986. The MFG reference is dated 1988/89. Material shows SEA-TAC, Tacoma Port District and Houston have highest national TAMS benzene values.

Non Attainmnt City Classification Pollutant
*Boston Moderate
Chicago Severe PM10
Houston Serious Ozone
Tacoma Moderate
Phoenix Moderate

It is of no assurance to citizens living near SEA-TAC Airport that the pollution levels are compared to other urban areas when those same cities have pollution problems that have neither been classified in attainment (attainment meaning a significant reduction in criteria pollutant levels which meet national and local standards) or considered healthful for those living near pollution sources. The cities used in the comparison are considered to be some of the most polluted cities in the country.


1. Is it proper to use a comparison for a comparison?

2. Are the TAMS and N/VOC data taken from earlier studies?

3. Is the Downey survey unreliable due to its age and deviations? 4. Have sampling methods improved since 1984?

5. Should sampling be conducted today in cities used for comparison would they show similar values to previous data or improvement?

6. Do the industrial sites used for comparison have multiple polluters and are they regulated as a source where SeaTac is not?

7. How close are single family residential areas to the industrial sites?
a. Schools?
b. Hospitals?
c. Retirement homes?

*ppb equals parts per billion of contaminated air per each billion of clean air in volume.

1. MFG page iii
2. Ibid page 32 .
3. "Located in Normandy Park (2 miles west of the airport) to provide background information in an off-wind direction, removed from major roadways and the airport." MFG page 8 Also see scoping criteria in summary.
4. MFG Appendix A10/26 Toluene. Also see section for ethyl benzene and all benzene ND. ND is not detected
5 . Ibid page 32
6. Ibid, compare all values divided by eight sites compared to dividing for nine for values when ND appears at site 7.

URBAN AREAS ADDENDUM (Documentation received after completion of review

The TAMS (Environmental Protection Agency Toxic Air Monitoring System) and NVOC (National Volatile Organic Compound) data have recently been received and compared to SEA-TAC Airport's McCulley, Frick and Gilman Air Quality Survey. (MFG)

As stated in the review of the survey, the TAMS and NVOC data appeared to show higher values with age of sampling, i.e., Downey, Southern California formaldehyde sampling from 2/3/84 shows 15.5 ppb compared to SEA-TAC 1993 3.0 ppb. (see page iii MFG page 40 and review pages 7-9) Most recent comparison of Atlanta, Georgia shows formaldehyde from 7/8/92 at 2.9 ppb compared to SEA-TAC 3.0 ppb. The next most recent data comes from 1990 Arizona and Southern California at 1.8, 2.8, and 1. 8 ppb. The review assumed that emissions have decreased with more current sampling data in most cases due to, possibly, better sampling methodology and/or lower rates from source control, regulation and cleaner and regulated automobile emissions.

All values were added to obtain a mean for cities used in comparison. Most data from 1989 was comparable. Mean values showed little deviation from TAMS and NVOC database. Sites are described in the 1989 report thus, "TAMS sites were selected because of the high industrial source emissions in the surrounding area."1 Cities are Boston, Chicago and Houston. There are three sites in each city, two for TAMS and one representing residential and background for NVOC. SEA-TAC shows higher values for most compounds in comparison to NVOC with the exception of Houston database.

However, for 1992 with all mean values carried from SEA-TAC and placed next to emission rates for the same three cities with the same two industrial and one residential sites, overall average of all emissions is greater for SEA-TAC for mean and high average, high by over 2.0 ppbv (parts per billion of contaminated air for parts per billion by volume) and almost 2.0 ppb for mean.2

For Toluene, the eight hour high was 40.0.ppb compared to a 24 hour next highest for Houston residential site 3 at 19.4 ppb. Benzene average of 2.I ppb is higher than all sites. The same is true for m + p-Xylene, ethylbenzene, lll-trichloroethane for average and high, and 124-tri-methyl benzene. Average of 10 sites used for comparison is 2.55 compared to SEA-TAC 8 hour mean of 5.66. (note that 24 hour average is obtained by multiplying an 8 hour by a factor of 0.3, however, since industrial 24 hour average may reflect 8 hour operation, whereas SEA-TAC values are not figured in consideration of shifts, but rather may better generally reflect continual operation, an 8 hour seems appropriate as a 24 hour value)

For detected highs the overall average of the study shows 4.44 ppb compared to SEA-TAC at 9.79 ppb. In this particular study, Houston showed greater values than the other two cities, the residential Houston had the third highest average emissions. The two highest were Houston site 1 (industrial) and Tacoma Port3 but both were below SEA-TAC average 8 hour emissions.

1. Inter-Urban Comparison of Ambient Volatile Organic Compound Concentrations in U.S. Cities, Sylvia A Edgerton, et, al,1989

2. Measurements of VOCS from the TAMS Network, Gary F. Evans, et. 1992

3. Tacoma Port added in 1992.


The MFG report noted "ratios of several key VOC'S were indicative of automobile exhaust and did not resemble the VOC profiles associated with aircraft emissions."

MFG does not name those key VOC'S. It is impossible to judge whether these are indeed key VOC'S without knowing if these are carcinogenic, such as benzene, or otherwise. There is not an indication of the values for the key VOC'S in MFG. It cannot be discerned from the survey if the levels of these key VOC'S are high levels of concern or insignificant values. Numbers of VOC'S are subjective. Are several three or four? Out of the potential hundreds of compounds referenced to jet fuel, it may be an erroneous assumption to conclude that a few are key without knowing their nature, composition or value.

Refer to the tables below for previous studies on amounts of pollutants for jet aircraft emissions compared to automobile exhaust:

Metric Tons per year vehicles2
(carbon moNOxide)
(nitrogen oxides)
(sulfur oxides)
502 37.2 23.03 0.018 0.118
Metric Tons per Year Aircraft
3121 1277 1874 162 61.44
Amount of Pollutant per 1,000 lb. fuel3 vehicles
405 71 21 - 2
Amount of Pollutant per 1,000 lb. fuel aircraft*
57.8 11.6 9.0 - 5.8

*JT8D-7 burns 470.4 lb per engine in a 6.5 minute takeoff/aircraft.

Chicago Midway Airport emissions comparison4
Benezene Aircraft = 8.9 tons/year Auto = 0.332 tons/year
Formaldehyde Aircraft = 62.86 tons/year Auto = 0.118 tons/year
PM (All Aircraft) 50.1 tons/year Auto 0.258 tons/year

A recent quote from the Port of Seattle; "The major findings were that similar to corresponding results reported in other parts of the country--air quality near the airport appears to be dominated by emissions from motor vehicles."5

This statement appears to be in direct contradiction to the information presented above from previous studies. In Frankfurt, it was estimated that aircraft CO equaled 3,528 tons/year an amount equal ..."to the CO emissions of all motor vehicles which, in the same year, were on the road in the Frankfurt area." (German daily newspaper article dated 1-20-88 "Frankfurter Allgemeine Zeitung"

"SEA-TAC Airport is a major indirect source of air pollutants. It contributes approximately 8% of the carbon moNOxide and 5% of the nitrogen oxide emissions in King County."6

MFG reports the high 8 hour average of carbon moNOxide of 7.3 ppm from site 9 on 10/25/93.7 This value is 0.5 ppm lower than the highest 8 hour average collected and reported for all of PSAPCA monitoring stations for 1993. High registered at 7.8 ppm 4:00 p.m. to midnight monitoring in February from Tacoma's Pacific Avenue area.

The overall average mean value of 4.51 (figured without site 7 included in the mean due to background considerations) is equal to the highest values reported in PSAPCA monitoring for Bellevue during 1993. Average CO, Bellevue would be a significantly lower level than six reported highs.

The addition of a third runway and accompanying vehicle traffic and ground support on AOA, along with projects involving contributions from development of airport property to the north and south of the airport will substantially increase CO in the general area of the airport unless mitigation measures are implemented.

Projected haul trips for fill to build the third runway plateau are factored at approximately 1,000 trips per day (DEIS does not state if these are one way or two way travel) with an overall contribution of CO and PM as negligible.9 An overall increase for the 'with project' for haul trips is 1.8% 8/hour, CO and well below the standard of 9ppm at 4,b ppm. According to the sampling by MFG, a conservative mean of 4.37 was obtained. This 8 hour average is nearly equal to the projected level of 4.8 total predicted. Background values were added to the determined value to arrive at the 4.8 which represent 3.5 to 5.0 ppm CO 8/hour. Using 3.5 as a basis, the projected 8 hour increase is merely 1.3 ppm from 1,000 haul truck trips in the area. On the one hand, the Port of Seattle claims that the CO levels and other pollutants represent contributions from automobile traffic while jet aircraft contribution is insignificant. On the other hand, they claim that the levels are lower than that found by MFG and the auto/truck traffic directly related to construction will have little or no contribution to air quality around the airport. There appears to be a ridiculous contradiction.

A memo to Barbara Hinkle from PSAPCA suggests using a back-ground value for CO of approximately 3.0 ppm/8 hour. This value is representative of ambient air concentration without contribution of traffic at the airport. All contributions figured using a base of 3.5 to 5.0 make the total contribution around the airport appear to be less than if a value of 3.0 is used.10

It also appears that additional taxi time mode for distance to and from the third runway was not factored into the projection in the DEIS for CO. Since taxi represents a significant amount of CO, the greater distance would represent higher values of CO than at present from the east and west existing runways.

In fact, it appears that a traditional L/T/O cycle is not clearly identified in the DEIS using EDMS 944.ll And that the number of operations may represent only take-off and not include landings. In each case, 43.9 takeoff operations per hour were estimated and this figure is well below number of actual operations in the L/T/O cycle if landings are figured.12

Worst case scenario for CO was predicted by EDMS at 20 ppm in the terminal area due almost entirely to traffic and 59 ppm at the runway. One km south of the queue the impact was 10 ppm with 9.5 near Seattle Christian School.13

Worst case scenario for ideal sampling data would include all EDMS hot spots predicted above and air stagnation periods or impaired air quality episodes preferably in January or February.

Finally, EPA states..."vehicular emissions estimated at Midway are insignificant compared to the aircraft emissions..."14


1. Why were the EDMS predicted hot spots ignored in the site selection?
2. Why was site 7 averaged into the mean?
3. Why was the scoping criteria ignored and recommendations from PSAPCA on backqround values increased? (DEIS)
4. Why does the Port of Seattle continue to insist that the CO contributions and other pollutant contributions are from automobile traffic when the literature such as EPA documents sugest otherwise?

1. MFG page iii

2 . EDMS page 16

3. Donaldson Table I, page 15

4. EPA Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago Final Summary Report. U.S. EPA Region 5 Air and Radiation Division-By: ViGYAN Inc. April 1993 page 13 Table 3 Hereinafter referred to as EPA Chicago

5. Forum April 1995 page 2 Air Quality Report Published

6. EDMS page 15

7. Pullet Sound Air Pollution Control Agency 1993 Air Quality Data Summary page 27 Hereinafter referred to as PSAPCA & MFG page 10/25/93 Results CO site 9 @ 7.3.

8. Ibid

9. Draft Environmental Impact Statement Seattle-Tacoma International Airport Landrum & Brown Inc., March 1995 Appendix D Air Quality page D-72 Hereinafter referred to as DEIS

10. PSAPCA memo to Barbara Hinkle from David S. Kircher dated November 29, 1994

11. DEIS page D-3

12. Ibid

13. EDMS page 15

14. EPA Estimation page B-33

*Part IV.9-10B DEIS shows State Implementation Plan (SIP) emissions inventory in tons/year:

1990 Aircraft Carbon moNOxide = 3,605
1990 Vehicles Carbon moNOxide = 6,999
1995 Aircraft Carbon moNOxide = 5,880
1995 Vehicles Carbon moNOxide = 10,265


"In general the canister sampling data did not indicate variations with meteorology or mode of airport operation."1 ..."average concentrations of these compounds were higher for the sampling periods when the airport was in a south flow mode of operation. The relatively higher values also occurred for the sampling periods which included the late afternoon and it is unclear whether the higher values were caused by different modes of operation or different periods of the diurnal cycle."2

These statements are in direct contradiction of each other. The correlation of higher values during south flow is likely directly related to wind speed averages recorded.3

Winds during north flow were stronger with higher averages of 6-10 knots and blowing in a direction of north by northeast to the south and southwest respectively. Since most of the sampling sites are located to the east of the runways, the averages would be lower during north flow.

Winds during south flow mode were lighter and varied in a greater number of directional patterns blowing mostly from the south and westerly which would account for the higher values to the north and east of the runways. Sites 5 and 8 and the arc of downwind sites for north flow are a total of 5. South flow sites include the two side by side sets of 1, 10, 12 and 13, and the rest are site 9, 11 and 2 totaling 7 sites in the direct path of winds most of the sampling periods comprising south flow mode. The downwind arc during north flow are out of position to capture direct plume, site 5 is in position for landings only and winds were blowing away from sites 3 and 4, with 6 in the only ideal position, but too far away to be of use for mode.

One objective of the survey was to capture conditions during an air stagnation period.4 MFG notes later in the survey analysis that a classical stagnation period was not captured.5 PSAPCA lists impaired air quality episodes for 1993 and note that the nearest date to survey is only six days after termination of testinq.6

On 10/25 MFG notes a brown haze to the north of the airport, but fail to state at what time this haze occurred. whether its presence was included into any of the sampling time or make any determination as to its source? A brown haze is indicative of a nitrogen dioxide buildup and would be appropriate to airport operations throughout the night when the airport was in a south flow mode.8 With sunshine, the nitrogen oxides produced in large quantity would with oxidation, transform to NO2.

It may also be concluded that during north flow mode, CO may show greater values near the airport due to the dispersion contribution from nearby 518 and International Blvd. This may account for the high CO rate reported at site 9 on 10/25.

PSAPCA wind models for 1993 show a greater frequency for winds out of the south/southwest with approximately 46% contribution. This is compared to a 25% frequency from north/northwest. These winds indicate that dispersion of pollutants from SEA-TAC may be most often carried to the north, northeast direction. An assumption may be based on this frequency, that the north, northeast is the most heavily polluted area of the surrounding communities for reasons that 70% takeoff to the south indicates winds are more frequently from the south, PSAPCA wind roses for 19939 support this frequency, values are higher during south flow mode and winds tend to be lighter from the south. This scenario also corresponds to the EPA finds in the Chicago study that one particular area of the surrounding community near Midway Airport were more likely to experience a large percentage of the cancer risk increases due to this greater exposure.10


1. Why did testing fail to capture an air stagnation period? 1993 Stage I "Impaired Air Quality" dates King County: December 20, 21, 26, 29. January11, 13, 15, 16, 17, 19, 31. February 03. from 1993 PSAPCA page 3
2. Why did MFG fail to summarize the wind variations in their analysis of meteorological considerations?
3. Why didn't they attempt to analyze the brown haze?
4. Why didn't they tell what time the haze occurred or exactly where north of the airport it was located?

1. MFG page iii

2. Ibid

3. Ibid page 14, 15

4. Ibid page 8

5. Ibid page 12

6. PSAPCA Impaired Air Quality dates, page 3 (see list above)

7. MFG page 12 (inversion/oxidation of NOx to N02 condition)

8. Ibid page 12 (paragraph 2, 1-hour period of south flow mentioned but no time for this mode is given)

9. PSAPCA, page 44, wind roses for Duwamish Station 1993

10. EPA Chicago Appendix B page B-30 note tower corresponding to receptor #31 and refer to page B-31 for value of 0.48% total lifetime cancer cases.


EPA estimation of cancer risk increase in Southwest Chicago shows for a population of roughly 94,000 a cancer risk increase of approximately 2 persons. The increase is directly attributable to emissions from aircraft and auto traffic on and near Midway Airport. The major contributor was 1,3-butadiene adding 1.4 cases.2 Although 1,3-butadiene is directly related to aircraft exhaust, it was not sampled by MFG in the present survey.

Modeled and monitored values of benzene, formaldehyde and particulates from EDMS and MFG have been analyzed
using the cancer risk factors. The results are shown using the mean value and again, below using all potential worst case scenario:

100,000 person population best case
Benzene average mean...... 6.7 x .0000083 risk factor = 5.561 cases
Formaldehyde avg. mean.... 3.7 x .000013 risk factor = 4.8 cases

100,000 person population worst case
Benzene detected high........ 13.40 x .0000083 risk factor =11 cases
Formaldehyde detected high... 8.47 x .000013 risk factor = 11 cases \
Particulate model ........... 800 µg/m3 x .000017 risk factor = 1,360 cases
Particulate model ........... 80 µg/m3 x .000017 risk factor = 136 cases

The two particulate model estimates are a high and low value from EDMS. Total risk factors for individual lifetime cancer cases for conservative estimates are 10 cases for 100,000 person population. Total cancer cases for the worst case estimates are 1,382. One of the spikes on the grid for Chicago held 0.48 or almost half the total cases. This is a population spike holding approximately 2,152 people of the 94,000 population figure. Of these 2,152 people, should a spike apply to SEA-TAC Airport in any manner, half the cases, or 691 people would experience cancer in their lifetime or one third of the population of a given area of greatest exposure. This amount is equal to almost 10 cases per year within an average 70 year lifetime exposure.3

Although the particulate estimates are contributing a large number of cases and have not been verified by monitoring, it is the only figure available to work with. Also, it should be apparent that the 22 cases for benzene and formaldehyde are only a minute estimate considering the tens, maybe hundreds of other carcinogenic emissions and combinations of emissions/molecules which could show far -higher estimates should monitoring be conducted. An additional runway would substantially increase all emissions, thereby, increasing cancer cases in and near the area.

The DEIS calculates cancer risk increase for the expansion project. Surprisingly, the DEIS figures pair with the Chicago study. Either the author(s) used Chicago values, or utilized estimates for benzene and formaldehyde rather than the actual monitored values.4 This should be considered a gross oversight, since the MFG report must have been readily available as it is quoted in the DEIS.

Conversion factors for ppb to µg/m3 for benzene and formaldehyde were provided by Mr. Fred Austin of PSAPCA.5

Polycyclic aromatic hydrocarbons in jet exhaust:6

DimethyInaphthalene (isomers)

Other carcinogenic compounds in jet exhaust are 1,3-butadiene and benzo (a) pyrene. Potentially, 1-nitropyrene and 1,8-dinitropyrene?7

The above are regulated in WAC and are considered extremely carcinogenic in very small quantity.

"The recognition of the potent mutagenicity of nitrated polycyclic aromatic hydrocarbons (nitro-arenes) and their widespread environmental distribution, mainly from the emissions of incomplete combustion processes, has caused concern regarding their potential health effects. This concern is heightened by the finding that some members of the group exhibit carcinogenicity in laboratory animals. The combustion products of aviation fuels are amenable to investigation and the nature and dispersion of aircraft emissions in or near airports have been studied in great detail. Since populations living near airports are accessible, it is conceivable that this situation would satisfy the basic requirements for an epidemiological study of the possible health effects of would appear that the factors required for the formation of nitroarenes are present in aircraft emissions, i.e., simultaneous presence of polycyclic aromatic hydrocarbons and oxides of nitrogen."8


1. Why did the DEIS estimates show 2 cancer case increase rather than the 10 for benzene and formaldehyde?
2. If the elderly, children and those with weakened immune systems are more prone to cancer risk and adverse health effects, what can be done to protect these people from risks associated with aircraft traffic at SEA-TAC Airport?
3. What can be done immediately to monitor these emissions and/or control these carcinogenic compounds?

1. EPA Estimation and Evaluation of Cancer Risks Attributed to Air Pollution in Southwest Chicago by ViGYAN Inc. April 1993

2. Ibid page B-33

3. Ibid page B-29

4. DEIS page IV.7-208

5. ppb x mol. wt. div by 24.45 (ideal gas law) = micrograms per meter cubed.

6. EPA Toxic Emissions from Aircraft Engines Air RISC July 1993 page 13

7. Airplane Emissions Michael A. I4cCartney et. al. Department of Environmental Health Sciences 21April 1986 page 99

8. Ibid

MIFG compares the averages for values of ASIL pollutants.1 Some are carcinogenic and would be controlled if they were generated from a source. SEA-TAC Airport is considered an indirect source of pollutants and therefore is not monitored or controlled. For community members living near SEA-TAC, this is an injustice which should be changed.

Health effects are given for the various pollutants listed. Although health effects are experienced in a range of values higher than detected at SEA-TAC Airport, mild symptoms of all effects listed may be experienced by those close to the source.

1. Dichloromethane: ASIL 0.161 Detected high 4.20
2. Carbon tetrachloride: ASIL 0.011 Detected high .22 Confirmed carcinogen with experimental carcinogenic; neoplastigenic, and tumorigenic data. A human poison by ingestion and possibly other routes. mutation data reported. An eye and skin irritant. Damages liver, kidneys and lungs.2
3. Benzene: ASIL 0.038 Detected high 4.20 Confirmed human carcinogen producing myeloid leukeraia, Hodgkin's disease, and lymphomas by inhalation. Experimental carcinogenic; neoplastigenic, and tumorigenic data. A human poison bv inhalation. Eye and moderate skin irritant. Human mutation data reported.
4. Trichloroethylene: ASIL 0.l10 Detected high 1.20 Suspected carcinogen with experimental carcinogenic and tumorigenic data. Mildly toxic to humans by ingestion and inhalation. Human systemic effects by ingestion and inhalation: eye effects, somnolence, jaundice. Human mutation data reported.
5 . Tetrachloroethene: ASIL 0.162 Detected high 0.33
6. Formaldehyde: ASIL 0.063 Detected high 6.90 Confirmed carcinogen with experimental carcinogenic, tuinorigenic, and teratogenic data. Human poison by inqestion. Experimental poison bv ingestion, skin contact, inhalation, Brain tumors suspected.
7. Acetaldehyde: ASIL 0.250 Detected high 3.89 Suspected carcinogen with experimental carcinogenic and tumorigenic data. Poison by intratracheal and intravenous routes. A human systemic irritant by inhalation. Human mutation data reported.

The above are all carcinogenic compounds found at values above the acceptable source impact levels at and near SEA-TAC Airport. These are normally regulated under Washington Administrative Code limits. The ASIL amounts above are set to protect the public health from levels unacceptable to human tolerance.

The following are compounds and their health effects which are not regulated as Class A carcinogenic compounds, however, studies are incomplete on some suspected carcinogenic compounds.

1. Acrolein:3 ASIL 0.009/24 hour Detected high 16.29 Human poison by inhalation...poison experimentally by most routes. Severe eye and skin irritant. Human systemic irritant and pulmonary system effects by inhalation include: lacrimation, delayed hypersensitivity with multiple organ involvement, and respiratory system damage. Human mutation data reported. Experimental reproductive effects. Questionable carcinogen.
2. Acetone Detected values between 7.0 to 39.0 ppb Moderately toxic by various routes. A skin and severe eye irritant. Human systemic effects by inhalation: changes in EEG, changes in carbohydrate metabolism, nasal effects, conjunctiva irritation, respiratory system effects, nausea and vomiting, and muscle weakness. Headache can occur in industry from prolonged inhalation.
3. Butane Detected values between 7.2 to 23.0 ppb Mildly toxic via inhalation. Causes drowsiness. An asphyxiant.
4. Isopropyl Alcohol Detected values between 3.8 to 51.0 ppb Moderately toxic to humans by an unspecified route. Human systemic effects by ingestion or inhalation: flushing, pulse rate decrease, mental depression, hallucinations, distorted perceptions, dyspnea, respiratory depression, nausea or vomiting, coma. Irritant of eyes, nose and throat at a concentration level of 400 ppm.


1. Ethyl Benzene Detected values between 0.62 to 1.80 ppb Mildly toxic by inhalation and skin contact. An experimental carcinogen. Human systemic effects by inhalation, eye, sleep and pulmonary changes.
2. 1,2,4-Trimethvl benzene Detected values between .58 to 2.0 Mildly toxic by ingestion. A skin and eye irritant.
3. Toluene Detected values between 4.49 to 8.85 with a 40.0 high on 10/26 at site 8. Moderately toxic by intravenous, subcutaneous, and possibly other routes. Mildly toxic by inhalation. Human systemic effects by inhalation: CNS recording changes, hallucinations or distorted perceptions, motor activity changes, antipsychotic, psycho- physiological test changes and bone marrow changes. Because of its low water solubility, toluene in the atmosphere is not appreciably removed by rain and thus it can travel long distances downwind from its source. Evidence on whether toluene causes cancer is inconclusive at present, but other types of health damage are well documented. Upon inhalation, the vapors aggravate the respiratory tract, depress the central nervous system, and damage the liver and kidneys. The early symptoms of toluene exposure can include some combination of the following fatigue, Weakness, confusion, euphoria, dizziness, headaches, dilated pupils, insomnia, extreme light sensitivity, and skin irritation.

Model glue is composed mainly of toluene, and sniffing its vapors can cause malfunctions of the nerves that control movement and irregular heart rate, in some cases leading to death.

Any action that decreases the burning or spilling of gasoline and other petroleum-derived products will decrease the public's exposure to toluene. In the urban atmosphere, toluene helps to form ozone and contributes to photochemical smog. The Resource Conservation and Recovery Act prohibits land disposal of toluene, and OSHA restricts workplace levels of the substance.


1. Since benzene compounds are so highly carcinogenic and the values reported by MFG are extremely high, what can be done immediately to alleviate this serious health threat?

2. What can be done in the future to assure the public that this will not be a more serious problem should aircraft traffic increase or a third runway be added?

3. Do our governing agencies protect the citizens from this type of exposures?

a. Who do we contact to protect our rights?
b. Who is responsible for monitoring this airport?
c. Is SEA-TAC considered a source or will it be? If not, why? If not; why are other facilities considered a source and are regulated when SEA-TAC is allowed to violate the law?

4. If airports continue to operate in the middle of single family residential neighborhoods, and families suffer ill effects; whereby said effects are found to be the direct response to air pollutants from jet aircraft, who is liable?

Governing authorities?
Air pollution control agencies?

1. MFG page 31
2. "A Guide to Commonly Encountered Toxics" "Hazardous Chemicals Desk Reference, Richard J. Lewis Sr. 2nd Edition 1991Van Nostrand Reinhold
3. MFG states that none of the ASIL 24 hour levels were exceeded. (see page 30 paragraph 3 last sentence, Appendix A) Acrolein was detected at an 8 hour average of high 16.29 site 1 12/14/93 The 24 hour level is shown on page 39 at 0.009.


Port of Seattle Request for Project requested..."Composition of residue typically reported to accumulate on surfaces under the aircraft flight track and preliminary assessment of the role of aircraft operations as the source."1

Also..."the sample program should be designed to provide information about the following issues and areas of study:... -surface deposition of airborne pollutants under flight paths in the vicinity of airports."2

"Particulate matter consists of small discrete solid or aerosol particles dispersed in the air. Particulate matter with an aerodynamic diameter of less than or equal to 10 micrometers is referred to as PM 0. Transportation, industrial activity and wood burning are major sources of particulate matter. Particulates one micrometer or less in diameter are especially associated with a variety of adverse effects on public health and welfare. The small particles can be breathed deeply into the lungs. Particulate in the respiratory tract may produce injury by itself, or it may act in conjunction with gasses to increase the effect on the body. The elderly, those suffering from respiratory illness, and young children are especially prone to the deleterious effects of particulates. Particulate matter causes welfare effects through soiling of buildings and other property and by scattering and absorbing visible light thereby reducing visibility."3

"The particulates, either liquid or solid, of concern from a a human health standpoint are those that have diameters ranging from 0.1 to 3 microns because they can enter the small passageways in the lungs and become lodged there. The chemical composition of the particulates is also a determinant factor on their effect upon human health. Some particulates, because of their composition are air toxins regulated under Title III of the 1990 CAAA. (CAAA is the Clean Air Act Amendment) Particulates with diameter less than ten microns are also criteria pollutants."4

"A 1979 FAA study' determined that the composition of particulates emitted by turbine engines is essentially carbonaceous with extremely small diameters ranging from 0.04 to 0,12 microns5for the three types of engines tested. (TF30, JTBD, and JT9D)."

The 24 hour standard for fine particulate matter PM10, is 150 micrograms per cubic meter.

New standards for PM2.5 have been implemented and are now regulated.

State Implementation Plan calls for a standard of 150 µg/m3 to not be exceeded in a 24 hour period.

Predictions from EDMS show excess of local, state and federal standards for particulate matter.

(NPC Editor’s Note: Part of this page was cut off and could not be reproduced properly. We apologize for any inconvenience this may cause)

MFG survey did not sample particulates for size, shape or content. It is essential that PM10 and …be sampled by independent agencies.

…samples were analyzed for the DEIS. Results were …matrix in all specimens was found to have a cellular …consistent with fungal species."6 Additional analysis …"The dominant black particle in all of these residential examples was attributed to a source clearly other. than jet engine exhaust... Their source was more consistent with fireplace smoke and tire wear."7

These analysis and conclusions are in complete contradiction to the EDMS model analysis conducted in 1991 where it is shown that aircraft engine exhaust contain particulate matter at quantities in excess of local, regional and national standards. And it has been concluded in previous studies that the content of particulate matter is of great concern for its toxicity and size. "A 1979 FAA study determined that the composition of particulates emitted by turbine engines is essentially carbonaceous with extremely small diameters ranging from 0.04 to 0.12 microns for the three types of engines tested (TF30, JTBD, and JT9D).8 .

A more current study, however shows a different particulate composition. "Kuhlman and Chuang (1989) have presented a chemical analysis of particulate and vapor portions of the exhaust from the F101 and Fl10 engines operated at idle, 30 percent, 63 percent, and 100 percent power settings using JP-4 fuel. Particulate-bound organics may be a small fraction of the total organic composition of a turbine engine exhaust (about 5 percent): However, these particulate-bound chemicals and aerosol components of the exhaust, which contain trace elements of heavy metals, may be a significant health consideration because their small size allows inhalation. This study focused primarily on concentration measurements of targeted polycyclic aromatic hydrocarbons (PAH) and nitro-PAH for F101 and F110 engines. The targeted compounds were selected on the basis of their mutaqenicity and/or carcinogenic potential, the identification of compounds from related studies, and on the availability of analytical standards."9

PAH are listed in WAC. These hydrocarbons are considered extremely carcinogenic in small quantity. It has been shown in the literature that content and size play a part in the adverse effects of particulates. Because the particulate composition can be absorbed into the bloodstream through inhalation into the lung, quantity of particulate matter should not be the- only sampling conducted at SEA-TAC, composition of particulate matter should be analyzed as well.

Although the DEIS claims that the contribution of pollutant levels is primarily automobile traffic in the airport area, this document shows relatively little contribution of PM10 above ambient air levels of 34.3 µg/m3 at a total of 34.7 for approximately 57 haul-truck trips per hour of 95 haul-trucks in 16 hour work days.10

Prior to the DEIS release, background levels of PM1 was suggested by Mr. David Kircher of PSAPCA at 26.6 µg/m3.10 since a level of 34.i µg/m3 was used, the haul-truck trip contribution is much less.11

In conclusion, environmental impact should always include the worst case scenario. It appears that the DEIS attempts to minimize impacts rather than project potential worse impacts. It also seems apparent that since there is such a tremendous gap between projected PM10 levels from the DOE EDMS model and the current 944 EDMS model used for the DEIS, something must be in error.

The analysis of fallout particles from the flight path is inconsistent with prior modeling and aircraft particle analysis provided in this chapter. Either the particles analyzed are not connected with aircraft exhaust, or the analysis method is flawed. Nonetheless, sulfuric, speciated and carbonaceous particles are associated with aircraft engine exhaust, at the least, and should be detected in areas which could or would experience such fallout material.


1. Were the sooty samples analyzed for their size as a criteria pollutant?
2. Why wasn't PM10 included in the MFG sampling?
3. Why are there such vast differences between the DOE EDMS model and the 944 EDMS used in the DEIS? (If the conclusion might be that the 944 is the newest and best modeling protocol, then an additional question would be, if the engines are not less polluting, why is there less pollution projection in the 944?)

1. STIA Air Quality RFP, Project Description, POS page 4

2. Ibid

3. PSAPCA page 62

4. EDMS page 3

5. Ibid page 6

6. DEIS page D-63, 91

7. Ibid page D-96

8. EDMS page 6 '.

9. EPA Toxic Emissions From Aircraft Engines July 1993

10. DEIS page D-72 - D-75

11. Memo from David Kircher to Barbara Hinkle dated November 29, 1994.



"The largest study ever conducted on the health effects of airborne particles from traffic and smokestacks has found that people in the nation's most polluted cities are 15 to 17 percent more likely to die prematurely than those in cities with the cleanest air."

..."since it has been demonstrated that particulates can carry sulfur oxides and other absorbed materials to the extremities of the lung where their toxic action may be greater than additive, this should be recognized when air pollution criteria, based on health effects for particulates are derived."2

"Special sub-groups of the human population have been identified as special groups at risk. Pulmonary response to short-term increases in particulate pollution has been induced in young children, the elderly and those with chronic obstructive lung disease. Long term exposure to high particulate concentrations has been shown to induce or accentuate heart and lung disease."3

"Dockery and coworkers have shown that particles smaller than 15 µm are also significantly associated with increased symptoms of respiratory illness in young children."4

"Watertown, Mass., which ranked fourth for inhalable particle concentrations in the study, showed a death rate from air pollution seven percent higher than Portage; Wis., which had the lowest particle level."

"Yet about 11% or 330, of the 2,995 people visiting hospital emergency rooms for asthma or asthma-like attacks had been exposed to significant levels of particulate matter the previous day."6

"'This really concerns us," "said Art Davidson, the agency's acting air pollution control officer.7 The same particles chat are harmful for visibility are also harmful for our health and our economy.
The downward trend (in visibility) is all the more perplexing because, by conventional measures such as the number of violations per year of federal standards, for carbon monoxide or particulates, Seattle's air is getting cleaner...despite that, the number of days between April and October when Mount Rainier is visible from Seattle-Tacoma International Airport has dropped by more than one third since 1986, the state Department of Ecology says."8

"Recent studies indicate the small particles that may be obscuring visibility also may be linked to the deaths of 60,000 people nationwide each year, said Harriet Ammann, a toxicologist with the State Department of Health."9

“Unfortunately, the clinical utility of air monitoring, information is often limited. Local conditions in urban areas may create pockets of polluted air that are not detected by the EPA's fixed-site testing stations...a high index of suspicion, coupled with a careful history, maybe necessary to determine if a patient's cardio-respiratory symptoms are due in part to an exposure to airborne pollutants. Patients need to be questioned about their proximity to local outdoor emission sources."10

"Other studies demonstrate a doubling in the rate of asthma symptoms in persons exposed to chronically elevated particulate levels. Finally, some experts believe that particulate air pollution may increase overall mortality and play a role in the development of cancer. However, because particulate matter varies so much in composition and by locale, it may have vastly different effects on health."11

"The article on air pollution in this month's issue summarizes our knowledge of the health effects of the most common outdoor pollutants: particulate matter, sulfur dioxide, nitrogen dioxide, carbon monoxide and ozone. The article also identifies the populations at greatest risk from air pollution: the young, the old, those with asthma, chronic obstructive lung disease and atherosclerotic heart disease, and healthy adults who exercise or who perform heavy work outdoors."12

"The study concentrated on 'fine particulate' air pollution: the kind of inhalable particles that are 2.5 microns in diameter (about a ten-thousandth of an inch) or smaller. Particles of this size can penetrate lung tissue deeply."13

"EDMS predicted localized hot-spots of particulate concentrations in the range of 800 micrograms per cubic meter, particularly in the 170 degree case illustrated in figure 22. At approximately 1 km north of the runway, the concentration has decreased to 157 micrograms per cubic meter. Measurements have shown that all of the particulate matter from aircraft exhaust can be classified as FINE, ranging in diameter from 0.03 to 0.I micrometers."14 (emphasis added)

"If he had known about the heavy blanket of pollution falling daily from the sky, he said he would have chosen a different color for his house--a dark gray perhaps. 'I don't know what it is, but it's on everything I've got. The skylights in my house are just black,' he said. It takes the paint off cars and runs like oily slime down the side of his house when it rains. He said his street lines up with the end of the east runway (SEA-TAC Airport) and looking up, he can watch planes fly just to the west. He watches as gray clouds pour out of the planes' engines. 'This cherry tree,' Mason said waving his arm, 'used to produce about three gallons. Last year I didn't even get enough to make a cherry pie. They're just all shriveled up.' 'Here in the near future, I'm going to put this house up for sale. I gotta get out of here."15


1. Is the sooty material depositing on peoples homes dangerous to breathe?
2. Should monitoring be set up in the area to better determine the sources of this large quantity of gray sooty material?
3. Should children and the elderly be living near the airport if it is found that SEA-TAC is a significant source of PM?
4. Why didn't MFG monitor for PM?
5. Why doesn't PSAPCA monitor nearer SEA-TAC for PM10?
6. Should other, independent agencies who are unaffiliated with the Port of Seattle or PSAPCA be called upon to monitor air quality near the airport, as it appears that results from these agencies always point to other sources than the airport?

1. Seattle Times NEWS Friday, March 10, 1995

2. "A Critical Review of the Health Effects of Atmospheric Particulates J. R. Withey, PH.D. Toxicology and Industrial Health 3:3, pp. 519-554

3. Ibid

4. Journal of Respiratory Diseases, VOL. 11, No. 11-November 1990 page 969

5. Seattle-Times, December 9, 1993

6. Seattle Times, May 8, 1992

7. Art Davidson Pollution Control Officer, PSAPCA

8. Seattle Times 2/3/94

9. Seattle Times, February 3, 1994

10. American Family Physician May 1, 1994 page 1403

11. Air Pollution and Your Health, Jon O. Neher, M. D. THE REPORT Fall 1994

12. American Family Physician, Volume 49, No. 6, page 1330 May 1, 1994

13. Seattle Times NEWS March 10, 1995

14. EDMS page 20 #7


Using a DC-10 as an average aircraft and engine, emissions factors from EDMS can be calculated for takeoff and climb-out modes, the major contributor to nitrogen oxides. Operation time is total of 2.9 minute and 49.78 kg/min. NO . (estimate uses 17,165 kg/min each engine) An average 330 let aircraft Operation per day received from Aviation Planning in a phone conversation arrives at a total of 16,427.4 kg/day. This amount is equal to 36,140 pounds per day of nitrogen oxides for take-off and climb-out modes. This amount is equal to 13 million pounds per year and adding a 33% increase for the third runway and a potential 100,000 additional flights per year this amount reaches 48,186 pounds per day or roughly 17 million pounds per year of NO, equal to 8 million metric tons/year.

These figures could be considered conservative if the new generation of engines are larger and burn more fuel per minute. A popular statement has been that the new engines are cleaner and emit less pollutants. However, this is in contradiction to one study of emissions using an older generational engine type as compared to a newer design:

..."report by AESO concludes that engine design does not appear to influence the contribution of each toxic constituent to the total organic concentration. However, a comparison of the data reported for the combustion of various fuels (JP-4, JP-5, and JP-8) suggests that fuel composition is the major determinant of demonstrated comparable exhaust constituents." (the two engines tested were the TF-39 representing a first generation high-thrust, high bypass ratio design, and a CFM-56, Boeing 737-300, 400, 500, representing a recent tech- nology, fuel efficient, advanced emission abatement design)2

"However, these same fuel-efficient aircraft also produce increased NOx emissions."3

"By the end of a typical day, jets at the region's five commercial airports spew tons of fumes equivalent to more than a quarter-million cars. Yet, in a city where every factory, utility, small business and motorist has already shared the pain of cleaning up the nation's worst smog, airlines remain untouched.

The airline industry has long escaped its fair share because of its clout, the complexity of its operations, safety concerns and the sluggish pace of aircraft technology and turnover."4

Nitrogen dioxide was modeled by EDMS at a high of 28 ppm worst case condition.5

"It is expected that NO will be dispersed and oxidized to NO2 over a wide area, maybe kilometers away from the point of emissions, therefore reducing the concentrations near the airport. Nevertheless, the predicted concentrations of NOx are a reason for concern."6

February 1979 Argonne Airport Vicinity Air Pollution model, (AVAP) used to predict emissions at LAX showed approximately 4.7 tons per day of NOx emissions during take-off for roughly 300,000 jet operations per year.7

Nitrogen dioxide combined with VOC'S can form a chemical reaction in the air which produces ozone (O3). Adverse health effects of ozone can be chest pain, eye-nose irritant, increase in asthmatic attacks. Ozone reduces normal functioning of healthy lungs. Human studies are inconclusive at this time, but animal studies show that ozone can produce permanent lung structure damage. "The presence of nitrogen dioxide in ambient air has been connected with a range of respiratory diseases. Further, nitrogen dioxide plays an essential role in the photochemical reactions that produce ozone."8

Ambient air quality standards for national, state and regional levels of NO2 are 0.053 ppm. The EDMS model predicted significantly higher values than this in the 1991 report, up to 28 ppm 1/hour, however, the DEIS predicts little increases in NOx with-project including increases in air traffic into the year 2020.

"The conclusion reached was that very high ground level concentrations of NO2 on the airport property resulted from aircraft operations. Also, it was concluded that aircraft operations could cause high concentrations of NO2 to be experienced in the residential and business areas surrounding the airport property."10

"It is generally known that the rate at which NO is converted to NO is dependent upon several parameters, including sunlight intensity, rare at which the NO is mixed with the surrounding air, and the presence of ozone and other photochemical oxidants in the atmosphere. During a smoggy summer day, the conversion process may be very rapid and most of the NO could be oxidized in an hour or less. However, little oxidation of NO to NO2 is expected to occur during the night hours and the rate of the conversion is thought to be considerably slower during the winter months than during the summer months.

At a major airport such as O'Hare, emissions of carbon monoxide, hydrocarbons, and nitrogen oxides from commercial aircraft can exceed several thousand tons per year. Based on this emission rate and the emission densities, there is a tendency to conclude that aircraft are a MAJOR source of air pollution and therefore should be controlled.

During the time period from May 16 to June 20, 1976, extensive air quality monitoring was performed in Mountain View, GA which is a small community located just off the approach end of the main runway at Hartsfield International Airport, '-and directly beneath the flight path (airplanes over-fly Mountain View at an altitude of 125 to 165 ft). Recorded hourly concentrations of NO2 reached 220 µg/m3 (an amount greater than twice the national, state and regional allowable safety limit of 0.053 ppm) and during the month the average NO2 was 80 µg/m3."11

"...growth in the number of passengers is projected to result in an overall increase in NOx emissions from aircraft in the future unless some form of control is implemented. This increase can range between 2 to 3 times current NOx emission
levels at the major airports. With this large increase in the projected levels of NOx, aircraft emissions may have a much larger impact on NO2 air quality, than at the present time."12

Since VOC'S and nitrogen oxides are present in jet exhaust, the necessary components for the build-up of ground level ozone above ambient air standards of 0.12 ppm 1/hour exist. Ozone and NOx must be tested at SEA-TAC Airport. Best conditions to determine if levels are in excess of air quality standards is during warm sunny conditions


1. Why were nitrogen oxides and nitrogen dioxide not sampled?
a. Criteria pollutants?

2. Why was ozone not included into some kind of sampling inventory?

3. How can the public nearby know if the ambient air levels of these two regulated criteria pollutants are within acceptable limits when all the information points to the contrary?

4. Could the build-up of ozone levels be the reason plants and trees are suffering near the flight-path and airport area?

5. Wouldn't a third runway increase this dangerous situation?
a. How can this be controlled?
b. If air traffic increases and NO is predicted to increase with new generation of larger engines, planes and capacity, will
this problem cause serious health related illness in the nearby communities?

6. Since the majority of nitrogen oxides are emitted during takeoff and climb-out, does this mean that communities as far as 6 miles from the airport are receiving thousands of pounds of NOx dispersed upon them daily?

1. EDMS pages Al-6, 7

2. EPA Toxic Emissions from Aircraft Engines: A Search of Available Literature, Air Risk Information Support Center, July 1993, pages11, 27, 28, references 5, 6 and11.

3. DEIS page D-5

4. Seattle Times NATION February 21, 1995

5. EDMS page 6

6 . Ibid page 19

7. Journal of Air Pollution, Vol 29, No. 2

8. PSAPCA page 64

9. DEIS D-14 estimates 2,008.6 NO 2020 yr. compared to D-11 1994 existing of 1,378.30 (tons year) EDMS estimated 1874 metric tons/yr in 1991 equal to 2,066 tons/year. The 1994 is less and 2020 is still less than predictions in 1991. Who is correct?

10. Emissions of Oxides of Nitrogen from Aircraft Bruce C. Jordan. Office of Air Quality Planning and Standards. U.S. EPA Anthony J. Broderick-Office of Environment and Energy U.S. EPA Feb 1979 Vol 29 No. 2 pages l19-124

11. Ibid

12. Ibid


MFG sampling days, time of year, weather and site selection may well represent best case scenario. When estimating air pollution factors in relationship to the close proximity of residences near pollution sources, it is appropriate to sample worst case scenario. This has not been accomplished.

DEIS modeling is also representative of least potential impacts. There is an unresolved conflict between the data presented on emissions rates and the DEIS predictions. This issue needs quick resolution.

The MFG findings of insignificances for meteorology/mode, upwind vs. downwind and the overestimates of automobile traffic contribution is in direct conflict with material presented in this report regarding emissions rates of aircraft vs. automobile traffic, TPH levels from MFG, previous monitoring and modeling of aircraft emissions, and engine manufacturers specifications. The MFG findings of emissions values, whether indicative of automobile exhaust or otherwise, are a great cause for concern. As benzene and formaldehyde are significant carcinogenic compounds detected at levels unsafe for human exposure and responsible for cancer risk increases in the area of SEA-TAC Airport, rather than comparisons to other polluted cities, this situation is in need of quick measures to alleviate the public health threat.

Particulates and all criteria pollutants have been determined to be a significant problem at and near the sources of air pollution. Aircraft contribute substantial quantities of NO , particulates and may also be a contributor to ground level ozone levels in excess of local, state and national standards.

The increased health threat recognized recently with regards to the toxic effects of particulate composition needs attention. Modeling has produced estimates of quantities of particulate dispersion from jet aircraft at levels predicted to contribute 1,360 cancer cases around SEA-TAC Airport. This estimate is sure to cause a great deal of public alarm unless monitoring can produce rates and content contrary to previous studies and modeling estimates.

NO2 combined with VOC'S and toluene are ozone precursors. NO2 sampling collected by Metrosonics (DEIS page D-101) show 0.1 ppm average and 0.3 ppm maximum NO2 during April 1994 at a five minute average.* Both amounts are above the standard. Should NO2 annual rates show values equal to the above, the SIP would be violated.

MFG state that the appropriate method for sampling CO was not employed due to unavailability of transport.1 If the sampling criteria dictates a more accurate method such as a fixed site monitor, this should be accomplished, especially in light of the potential impacts of expansion construction contributions.

MFG reports that the day after Thanksgiving was a high volume passenger period.2 Airport Supervisor and Aviation Planning did not confirm this conclusion. According to the Airport Supervisor, the day before Thanksgiving, Thanksgiving morning, Sunday and Monday are the peak volume days during this holiday period. This Friday was considered to be the slowest day of the period. Also, MFG did not include operational information in the survey, I.e., number of flights, runway use, queues, taxiing, etc., and this information is essential to evaluating the report. Passenger volume is irrelevant to determining any relationship of aircraft emissions in the area.

The DEIS uses a 43.9 peak aircraft departure figure.3 The 1991 DOE EDMS model used 72 operations received from the operations log for August 1989.4 This difference calls into question either the input used for the DEIS 944 model. or the 1991 report which has not yet been refuted.

SO2 has not been modeled in excess of standards. However, in Tentatively Identified Compounds on 12/14/93, SO2 is recorded at 0.017 ppm an amount equal to the Washington State annual standard of 0.02 with integer rounding.5

All suspected carcinogenic compounds presented herein should be sampled in the nearby communities. All combination molecules should be tested as gasses and particulates. All nitro and nitrous compounds should be included into a sampling inventory as well as all criteria pollutants. Sampling should include worst case scenario for all pollutants.

According to Michael Yost, University of Washington, the FTIR Spectrometer is being refined for better use on exhaust plume from aircraft. It would be beneficial to utilize this method in the future for further testing.

In conclusion, unless some form of control can be implemented, either through fuel modification or operation reduction, SEA-TAC Airport will continue to contribute greater health impacts to the communities nearby as aircraft traffic increases and/or another runway is added.

*In light of the standards, hourly, 3 hour, daily and annual, a five minute average is extremely unusual.

  1. MFG page 4-2.1.2
  2. Ibid page12
  3. DEIS page D-3
  4. EDMS page14
  5. TIC enclosed Appendix A

Exhibit I

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