Notes
ACC (Airport Communities Coalition) reply memorandum in support of its motion for a stay, filed October 10, 2001, before the Pollution Control Hearings Board (PCHB). Argues that the Amended Certification sets acceptable soil contamination levels too high to protect water quality, citing DOE expert Chung Yee’s 3-phase back-calculating model showing Antimony should be limited to 5.79 mg/kg (not 16 mg/kg) and Arsenic to 2.92 mg/kg (not 20 mg/kg). References Ecology Toxics Cleanup Program senior engineer Peter Kmet declaration, Eglick Declaration Exhibit J, Lucia Declaration Exhibit B, fill dirt criteria, Selenium at 0.75 mg/kg, Silver Method 7741, and groundwater/surface water protection standards. Filed by Helsell Fetterman LLP and attorney Rachael Paschal Osborn on behalf of ACC.