EXH0033017496

PCHBPollution Control Hearings Board of the State of Washington

• nt: Monday, September 11,2000 3:44 PM _e._ Jc.c, 1: o: Yee, Chung K. Cc: Fitzpatrick, Kevin Subject: New Method A Soil Cleanup Levels Here are a series of tables showing the calculations for the new Method A soil cleanup levels and providing a comparisonto the current Method A values. TAIBL740g.XL.S As I noted in our phone conversation, one point I didn't include in my earlier comments was ground water monitoring. I stillthink it would make sense to require that giventhe magnitude of the fill. You asked whether I thoughtthe Method A values could be used as a basis for defining clean fill. I understand there are some concerns about whether this can be done legally. Putting aside that issue for the moment, as I look at the Method A cleanup values in light of this use, several thoughts •come to mind: We believe the currentstandards are not protective for several chemicals. That is why we are proposing new values. You should require them to use the new standards (assuming we end up dopting them). One exception is arsenic. I think you need to lookcarefully at that value as the calculations indicate the current MethodA arsenic soil cleanup level may not always be protective. We plan to revisit that value in a future rule-making. In the interim, you may want to use a background value instead of Method A. The statewidestudy we had the USGS do found background in uncontaminated areas at PPM. As I re-look at this attachment inthe…
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