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Stop of California D"rtmont of Hoc" Sorvic�s <br /> Memorandum <br /> To Jim Tiosvold, P.E. Dct` September 21 , 1987 <br /> Senior Waste Management Engineer subject: <br /> RESPONSE TO <br /> McCORMICK AND <br /> BAXTER LETTER <br /> JULY 31, 1987 <br /> From Jeff Van Slooten <br /> Associate Hazardous Materials Specialist <br /> McCormick and Baxter resubmitted their Workplan dated <br /> July 1987 based on comments from Department of Health Services <br /> (Department) and Regional Water Quality Control Board (Board) , <br /> dated July 3 , 1987 . In addition to the revised Workplan, <br /> McCormick and Baxter has submitted their discussion <br /> (July 31, 1987) to our comments. <br /> Of the State'-s 60 technical comments, 46 of them were <br /> incorporated into the revised Workplan. The Workplan has been <br /> reviewed to determine if those comments were properly <br /> incorporated. A few of the comments were either overlooked or <br /> inadequately addressed the State's concerns. McCormick and <br /> Baxter is in disagreement with the remaining 14 comments. <br /> These 14 comments have been re-evaluated along with McCormick <br /> and Baxter's rebuttal. Each of these comments will be <br /> addressed. <br /> Amended Comments <br /> Corrections from the 46 incorporated comments, which must be <br /> made to the amended workplan, are as follows: <br /> Comment 14 <br /> The State has requested information on equivalency testing for <br /> methods GC/FID and CPAR. Equivalency testing is a standard <br /> procedure from the State Laboratory Certification Program. <br /> These proposed methods are not EPA approved and were not the <br /> methods presented to the State when applying for <br /> certification. Data from duplicates, spike recovery <br /> calibration curves, detection levels, and confirmation testing <br /> which have been performed by the CH2M Hill Redding Laboratory <br /> must be provided to the State's Hazardous Material Laboratory <br /> (FML) for analysis . Gui_deli-ies fc-kr the CrCR method (also c;:n <br /> be used for GC/FID) equivalency testing are attached. 1-IML has <br /> been notified that CH2M Hill's Redding Laboratory is using <br /> methods which were not certified by the State. <br /> McCormick and Baxter's contract laboratory has only submitted <br /> the procedures for the analyses. This does not show <br /> competency of either the method nor the laboratory performing <br /> the methods. The CH2M Hill laboratory has been using these <br /> methods since 1984 . Questionable data, such as the presence <br />