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• • Review Comments for Revised Site Investigation Work Plan—June 2015 Former Helena Chemical Facility Page 2 trichloropropane (123-TCP) using Environmental Protection Agency Method 524.2 modified by the California State Laboratory(SRLB)to attain the acceptable low level detections designated as SRL 524M-TCP. Condor also obtained the list of ELAP accredited laboratories for hazardous waste. The lists were queried and laboratories eliminated using an iterative process. First, laboratories that were non-commercial were stricken from the list, including water districts and government facilities. Consultation by phone with three laboratories indicated that laboratories specialize based on matrix or substrate such as soil, water, air, rock, plants, or food which restricts their abilities and their reporting limits even if they are certified for the same analytical method. Second. websites were queried and laboratories were eliminated that indicated that their commercial focus was on rock, asbestos, air, dust, plant or food testing. Many websites included published reporting limits. Third, laboratories were eliminated that indicated that their reporting limits were higher than five nanograms per liter for 123-TCP. Twelve remaining laboratories were contacted and sent a list of analytes and minimum screening levels that were developed duringdevelopment of the previous version of the work plan, and their reporting limits were reguested. Six of the laboratories declined to participate citing that the screening levels were not achievable in a commercial laboratory, that they would not be competitive for groundwater analysis, or that they would not expend resources to respond. Reporting limits from the six laboratories that were responsive were compiled onto a spreadsheet titled Minimum Screening Levels to Compare Laboratory Reporting Limits, included in Appendix C of the Site Investigation Work Plan. The laboratories had varied lists of analytes and reporting limits reflecting individual limitations. The laboratories were evaluated based on the laboratory reporting limit and method detection limit for 123-TCP first, then for the largest number of instances where their RLs or MDLs met the minimum SLs. Based on these criterion, it was determined that BSK Laboratory in Sacramento had the lowest commercially available and achievable reporting limit for 123-TCP,BC Laboratories in Bakersfield met the largest number of SLs in ground water and soil. 123-TCP SL in Number of Number ofNumberNumber of Number of Laboratory groundwater groundwater soil SLs met soil SLs met met SLs met RL SLs met RL MDL MDL BC No 22 _ 28 29 38 BSK Yes 19 _ 24 25 32 CalTest No 20 25 22 26 McCam bell No 19 27 24 29 Test America No 18 11 18 20 Excelchem I No 16 7 18 32 It should be noted that while BSK was the only lab to have reporting limits lower than the minimum screening level for 123-TCP in groundwater. the RLs for the other fumigant pesticides were not less than or equal to the SLs but they did achieve the target of 0.005 micrograms per liter. Only McCampbell Analytical (MAI) has MDLs for 1.2-dibromo-3-chloropropane (DBCP) and ethylene dibromide(EDB)that exceed the minimum screenin 1¢ evels. The compiled RLs were queried again to hig(light the lowest RL compared with the other laboratories. It should be noted that CalTest Laboratories had the largest number of lowest reporting limits in ground water but this was because they had a more comprehensive list of analytes many of which do not have screening levels or that other laboratories did not report. CalTest also had the lowest reporting limits for the LUFT 5 metals in groundwater. BC Laboratories offers the largest number of lowest reporting limits for organo-chlorine pesticides in soil and ground water. BSK Laboratories had the largest number of lowest reporting limits for nitrogen and hydrocarbon analytes,followed closely by Excelchem. 4M %tW- +.a CONDOR