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-2- Stormwater Collection of stormwater before the collection ponds would produce variable results. The presence of CDD and CDF in stormwater would be from adherence to the soil particles. The amount of soil carried by the rainwater at any one time will depend on many factors. In addition, sediment loading from the final stormwater collection point may als6 vary from the final water discharged from the collection ponds to the SRWCF. Testing should be performed on the sediments from the ponds. Correlations on contaminant levels could be calculated from measured levels of sediments in the water. Groundwater Two of the proposed six samples will be from extraction wells A-8 and A-9 . Based on the chemical properties of CDD and CDF, the possibility of contamination of the actual groundwater is remote. To the Department's knowledge, at least several existing wells (A-8 , DSW4C) and a new well (DSW6B) have shown an organic layer in the samples collected. If CDD and CDF are being transported in the aquifer system, it is likely to be in this organic fraction. One composite sample of the organic material from all the wells that have an organic layer should be analyzed for CDD and CDF. The wells should not be purged prior to sampling. Only the organic layer in the well casing should be collected. A bailer should be used to obtain this fraction. If a pump is used, then all the water should be collected and allowed to settle from the organic layer. Track Pit and Siding Area Poles are removed from the retorts or cellon process in the track pit area, moved to other sets of tracks, and then transferred to the track siding area. These freshly treated poles are temporarily placed in the track siding area while curing or being processed before moving to storage. Past sampling in these two areas has not shown uniform contamination either vertically or horizontally. The sampling plan proposed to composite three samples from the track pit area (approximately 10, 000 sq. ft. ) with three samples from the track siding area (approximately 30, 000 sq. ft. ) . Therefore, one sample would represent approximately 40, 000 sq. ft. or one acre. A typical sampling grid used by the EPA, for CDD sampling, is 2 , 000 sq. ft. with three samples collected from over 450 locations. This would provide a representative analysis of an area. The proposed sampling approach will provide only an