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.. .. <br /> Ms. Donna Heran, REHS September 3, 1993 <br /> San Joaquin County Public Health Services Page 2 <br /> Mr. Boggs indicated the Central Valley Region expects a 0.5 ppb detection limit because it is <br /> their opinion that the limit is commonly achievable by laboratories. He agreed that the Tri- <br /> Regional document is a set of recommendations and not regulations and further stated that the <br /> document recognizes that 0.5 ppb may not be achievable by all laboratories. He also stated that <br /> the document suggests that if the Practical Quantitation Limits (PQLs) are not achievable, an <br /> explanation should be submitted with the laboratory report. Mr. Boggs indicated that <br /> WESTON's position on PQL and Method Detection Limits (MDL) was consistent with <br /> laboratory practices and felt that should a higher detection limit be achieved, it would be <br /> sufficient to provide an explanation in the report. The practical result of these discussions as <br /> related to the San Joaquin project is that in future groundwater monitoring reports, WESTON <br /> will either meet the Tri-Regional recommended detection limit of 0.5 ppb for BTEX if possible <br /> or provide a statement of explanation to support reporting a higher detection limit. <br /> Concentrations Below Detection Limits <br /> Regarding the presence of constituents in groundwater at concentrations below the analytical <br /> detection limit, the analytical detection limit for TPH-G and TPH-D was reported as 50 ppb as <br /> shown in the analytical reports presented in Appendix B of the Quarterly Groundwater <br /> Monitoring Report, Second Quarter 1993. The detection limits are also shown at the top of the <br /> columns in Table 2 of that report. As noted by the EHD, the detection limit for TPH-G was <br /> incorrectly shown in the table. WESTON regrets this typographical error, however, this error <br /> in no way effects the data presented in the table, the body of the report, or the appendix. <br /> The EHD's letter, however, is incorrect in stating that in Table 2, ND indicates that no <br /> contaminants are detected. The nomenclature used in the table is clearly defined in four specific <br /> notes beneath the table which are keyed to superscripts in the table. As stated in the first note <br /> beneath the table, ND is defined as "non-detectable at the detection limit shown at top of column <br /> or in subscript". Hence, the symbol ND indicates that a chemical constituent is non-detectable <br /> at or above the limit of quantification. It is, of course, common that a constituent can be "seen" <br /> by the instrument below the detection limit and a concentration estimated. However, for site <br /> evaluation purposes, estimates at extremely low concentrations have relatively little practical <br /> value. In the recent site data, TPH-G and TPH-D may be present in wells MW-6 and MW-7 <br /> at extremely low estimated quantities, but they were reported in the summary table as ND due <br /> to the lack of quantification at the instrument detection limit. <br /> The WESTON analytical laboratory typically reports estimated chemical concentrations with a <br /> "J" symbol when chemicals are detected at concentrations below the detection limit. In such <br /> cases, it is WESTON's practice to report the concentration as ND, as defined above, in the body <br /> of the report, with the complete analytical report presented in an attached appendix. If in the <br /> event that for some practical reason the concentrations below the detection limits should be <br /> Sf MSMERA .WP <br />