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Mr. Derral Van Winkle - 3 - 03 September 2021 <br /> <br /> <br />3. General Comment #3 – Laboratory Methods and Certifications <br />Please be aware the lab certification for “SGS North America – Orlando”, starting <br />on page A-2-1, expired on 6/30/2021. Please update this certification. <br /> <br />Furthermore, please clearly identify the groundwater analytical methods that will <br />be used to complete the Work Plan, including those approved by the DOD (e.g., <br />QSM 5.3, Table B-15) and/or applicable EPA methods (e.g., EPA 537.1). Please <br />clearly identify these methods in Worksheet # 15, Attachment 3 and supporting <br />laboratory certifications. <br /> <br />Finally, Attachment 3 states on page A-3-3: <br /> <br /> “This SOP is not designed to be used to analyze drinking water by EPA <br />537 or EPA 537.1. Drinking water samples should be analyzed by SOP <br />MS017.” <br /> <br />To ensure data usability in the future (see General Comment #2), the Central <br />Valley Water Board requests a certified laboratory method that is appropriate for <br />analyzing PFAS/PFOA in drinking water. This request is made pursuant to the <br />Central Valley Water Board Basin Plans <br />(https://www.waterboards.ca.gov/centralvalley/water_issues/basin_plans/#basinp <br />lans) that state all groundwater in the Central Valley are considered suitable or <br />potentially suitable, at a minimum, for municipal and domestic water supply. <br />Therefore, all groundwater results should at least be evaluated against drinking <br />water criteria (see General Comment #1) but preferably against background <br />conditions. <br /> <br /> <br /> <br /> <br />Sincerely, <br /> <br /> <br /> <br /> <br />Carla Landrum, PhD <br />Engineering Geologist <br />Federal Facilities Unit <br /> <br /> <br /> <br /> <br /> <br />John T. Murphy, P.G. #9524, C.H.G. #1092 <br />Senior Engineering Geologist <br />Federal Facilities Unit