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State of California Department of Health Services Memorandum To Jim Tjosvold, P. E. Date , April 29 , 1988 Senior Waste Management Engineer Subject: MCCORMI CK & BAXTER REVISION TO GROUNDWATER MONITC%ING From Jeff Van Slooten l Associate Hazardous Materials Specialist McCormick and Baxter has proposed (February 10, 1988) to reduce the groundwater monitoring program. Their justification is based on the data base, which has been generated since March 1984 . M&B states that no further information is required to characterize groundwater contamination for the feasibility study and remedial design activities. Therefore, frequency of monitoring should be reduced in wells where characterization is complete. M&B also contends that the suite of chemicals present in the groundwater has been adequately characterized with the "General Scan" analysis performed in August 1987 . Testing for halogenated organics, nitrosoamines, and all metals except arsenic would be dropped from the suite of analyses. The Department of Health Services finds insufficient information presented to approve the proposal. The proposal is also unsigned by a licensed professional engineer (registered civil engineer) or geologist who assumes responsibility for content. Submittal of the following information is required to provide a thorough evaluation of the M&B monitoring program proposal . Data Validation The foundation of M&B' s proposal is that significant data has been previously collected. The State has informed M&B that past methods used for pentachlorophenol and PNA were not recognized as EPA standard methods or approved by the Department. Results generated from these past methods must be validated to be used as valid data. Result comparisons between methods should be analyzed and presented to show that the past data is precise. Confirmation for all future analyses must be performed in accordance with requirements of the State Hazardous Material Laboratory. If M&B elects to use GC/MS for confirmation, then any well with positive results must be confirmed once per year. GC/MS confirmations performed on current results were to be presented as Table 1 in the proposal. Table 1 was not included in the proposal.