Kerry Graber

Washington Department of Ecology

 

Dear Ms. Graber:

 

Environmental Review, Inc. reviewed the public notice on your website and we have general comments as follows:

 

1) The public notice indicated that groundwater is contaminated with contaminants including pentachlorophenol (PCP). Since PCP is known to contain dioxins and dioxins congeners, you should require investigation for those contaminants.

 

2) Since many investigations overlook significant concentrations of dioxins due to using the low resolution method, you should require the high resolution mass spectroscopy method.

 

3) Since organic carbon suspended in the groundwater may allow sorption of dioxins that travel as "hitchhikers" on the carbon, you should add testing for total organic carbon to your analytical testing suite.

 

4) Since colloidal transport of dioxins may occur on small carbon or mineral particles,  you should require an investigation of the colloidal transport mechanism. For example depending on the aquifer characteristics, small carbon particles, for example 0.3 microns in size may migrate freely in some aquifer matrices. Since dioxins are extremely toxic, it is important to determine if the colloidal transport mechanism at this site is significant.

 

Thank you,  Tom Price-Director, Environmental Review, Inc., P.O. Box 2756, Berkeley, CA. 94702. www.envreview.org