EXH2051031469

PCHBPollution Control Hearings Board of the State of Washington

Subj: Reviewof. Third RunwayEmbankment Fill Monitoring Plan, 401 Certification Condition E.3 Port of Seattle, November 2001 Per your request via Jeannie Summerhaysby memorandumdated January 8th, 2001, I have reviewed the Embankment Fill Monitoring Plan(EFMP) document and provide the following comments: 1. The document should provide detailed logic tree flow diagrams for the tiers and stages of samplingand action for all phases. I have provided an example logic tree flow diagram for the Groundwater Staged Screening that includes the comments provided in this memorandum (Figure 1). Similar logic tree flow diagrams shouldbe provided in the EFMPfor "tiers" sampling,Interim SeepageQuality Screening, Post Construction EmbankmentSeepageand Groundwater Monitoring, SeepageStaged Screening, and Groundwater Staged Screening. 2. Paqe4, Section 3.1, last sentence. The "appropriate statistical methods" should be described in detail in anappendix in the EFMP. The proposed statistical methods should be reviewed and approved by Ecologystaff. 3. Paqe4, Section 3.2. Ecologystaff should look at the proposed well locations in the field to gain familiarity with the site. 4. Page5, Section 3.3, first sentence. Samecommentas number 2. The statistical method(s) for establishing statistical baselineshould be described in detail in the EFMP. The proposed statistical method(s) should be reviewed and approved by Ecologystaff. AR 031469 Page1 of 4 Exhibit-2051 5. Page 6, Section 3.5, first bullet. The phrase "significantly elevated levels" needs to be defined. Ecology should consider substituting the phrase with "any elevated levels above appropriate criteria". 6. Paqe 6, Section 3.5, second bullet. Ecology should consider requesting the Port to conduct in-situ groundwater sampling along…
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