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Dr. James T. I en <br /> Page 2 <br /> (Tetrochlorophenol included) . <br /> Comments 45 , 20 and 21 , I believe, were resolved on September <br /> 15 , 1987 and confirmed by letter to you from Wayne Pearce, <br /> CH2M-Hill , dated September 30 , 1987 . <br /> Comment #60 requires notification on our part , which we <br /> will review and accomplish, if needed. <br /> We continue to have a good-faith disagreement pertaining to <br /> the desirability and feasibility of the second column <br /> confirmation measures requested in comments #13 and #23 . <br /> If my understanding of the issue is correct, this is QA/QC <br /> verification procedure that could increase, by 50%, our <br /> analytical requirements and significantly lengthen the <br /> time required to perform each task , while only marginally <br /> adding to the certainty already assured by our proposed <br /> analytic protocols, which comply with Title 22 , California <br /> Administrative Code requirements, and with EPA-prescribed <br /> methods . CH2M-Hill advises us that a requirement of one- <br /> hundred percent second column confirmation is not cost <br /> effective, and is not required by State of California <br /> regulations , federal regulations , or EPA Guidance Documents. <br /> Such a requirement would represent a significant and <br /> unjustified departure from broadly accepted remedial <br /> investigation practice at sites comparable to ours, including <br /> sites managed directly by the Department itself. Our <br /> Workplan does, of course, provide for confirmation of 10 <br /> percent of our samples, in accordance with standard requirements. <br /> Further, it is our position that in any event , the activities <br /> that are the subject of our disagreement , fall within the <br /> exceptions to Dr. Bob Stephens ' June 8 and July 24 , 1987 <br /> letters directing certified laboratories to perform <br /> second column confirmation. <br /> For these several reasons, we regard this technical <br /> disagreement to be an extremely important issue. <br /> Sampling and laboratory work included in Tasks 3 , 5, 6, 7 , 8 <br /> and 9 , all of which are scheduled to begin the week of <br /> October 12 , 1987 , are subject to this disagreement . We <br /> note, as well , that other subsequent tasks, dependent upon <br /> acceptable analytical results, eventually could also be <br /> impacted. <br /> We are anxious to commence the work scheduled to begin the <br />