Please note that this comment form is for the purpose of submitting a comment to the Washington State Department of Ecology.

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Ecology invites you to review and comment on the 2023 Periodic Review for the Panda Dry Cleaners site in Snohomish, WA. We review sites about every five years after a cleanup action when institutional controls are part of the cleanup. The purpose of the review is to make sure the controls remain effective, and the cleanup still protects human health and the environment.

A dry cleaner operated in a tenant space of the Clearview shopping center from about 1996 through at least 2006. Tetrachloroethylene (PCE), a chlorinated solvent, contaminated soil near the dry-cleaning machine. PCE was not detected in groundwater, but only one groundwater sample was collected, and that sample was likely collected upgradient of the site. Ecology issued a No Further Action (NFA) determination letter for the site in 2006. The cleanup action was a restrictive covenant that requires the property owners to keep and maintain the building and concrete floor that covers the PCE-impacted soil. There was no active cleanup work.

This periodic review concluded that the remedy may not protect human health and the environment. The periodic review findings included the following:

• It is not clear how far or how deep the remaining contaminated soil and potentially contaminated groundwater goes. More work is needed to find out how far the contamination extends in soil beneath neighboring tenant spaces and properties, and whether there is groundwater contamination.
• The covenant only prevents exposure to soil beneath the subject property. It doesn't apply to groundwater on the property, or to soil or groundwater on neighboring properties (such as the supermarket), which may be contaminated.
• Due to inconsistencies in the covenant, it isn't clear whether it includes the neighboring tenants on the property, or if it only applies to the dry cleaner unit. The covenant may not be protecting adjacent units if they are impacted.
• Solvent contamination in soil or groundwater can create human health risks in indoor air. The former dry cleaner space, adjacent tenant spaces, and nearby buildings should be assessed for vapor intrusion to make sure there is no risk from PCE and PCE breakdown products.

Based on the incomplete site characterization and the potential impacts to soil, soil vapor, and groundwater that are not covered by the covenant, Ecology will rescind the 2006 Site NFA. We will review comments we receive during the comment period. We will finalize the periodic review if there are no significant changes.