EXH2126033985

• Ecologyis an EqualOpportunityandAffirmative Actionemployer. If you havespecialaccommodation needs, pleasecontact Steve Robbat (206) 407-7188 (Voice)or (206) 407-6006 (TDD). DEPARTMENT OF ECOLOGY November 24, 1993 ImDlementati?n M_mo NO. :_ TO: Interested Staff FROM: Steve Robb _" Toxics Cleanup Program SUBJECT: PQLs as Cleanup Standards ISSUES Two issues have been raised with regard to the use of practical quantitation limits (PQLs) in setting cleanup levels: • The "legal" issue of PQLs as cleanup levels and whether or not PLPs have any long- term liability for sites cleaned up to the PQL level rather than the risk based level. Can PLPs receive a covenant not to sue in these situations? Are they required to utilize institutional controls and conduct long-term monitoring? • When risk based compliance values are less than PQLs, what value is used in the risk summation calculation, the risk-based value or the PQL? I. LONG-TERM LIABILITY The Model Toxics Control Act (MTCA) states "where cleanup levels are below the PQL, compliance with cleanup standards will be based upon the PQL" (WAC 173-340-700(6) Measuring compliance). Also stated in the rule, "If those situations arise and the practical quantitation limit is higher than the cleanup level for that substance, the cleanup level shall be considered to have been attained, subject to subsection (4) of this section..." (WAC 173-340-707(2) Analytical considerations). Therefore, the PQL becomes the compliance value, and PLPs whoattain the PQL are eligible for a covenant not to sue. WAC 173-340- I- 1 AR 033985 November 1993 93-100 Exhibit-2126 707(4) places…

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PSCAA Advisory Council Meeting Agenda
Add to CalendarMWednesday Mar 11, 9:00am - 11:35am
1904 3rd Avenue, Suite 105, Seattle, WA 98101
Call to order – Roll Call – Quorum Established – Land Acknowledgement We would like to acknowledge that our Agency operates in four present-day counties, which are the traditional lands of the Coast Salish people, past and present. This acknowledgement does not take the place of authentic relationships with indigenous communities in our jurisdiction and [...]