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• <br /> information on that method is included in Appendix B - the amendment to the <br /> quality assurance project plan (QAPP). PAHs, as well as some dioxins and furans, <br /> may be present at burn pits. Method 8270 provides inadequate detection limits in <br /> groundwater for risk assessment purposes. (All of these analytes were detected <br /> during the August 1991 excavation of some apparent burn pits prior to building the <br /> Subsistence Warehouse at the southern end of DDRW-Tracy, including solid waste <br /> management unit (SWMU) No. 13.) <br /> • Please correct this oversight. <br /> 57. Table B-13A lists only EPA Method 8280 for dioxins and furans in the soil matrix, <br /> although EPA Method 8290 is also to be used in soils. <br /> • Please list detection limits for dioxins and furans in the soil matrix utilizing <br /> EPA Method 8290. <br /> 58. Page B-13, Section B.8.2.0 <br /> The Work Plan does not contain any description of the calibration procedures to be <br /> followed for the various methods in Table B-B-2A other than a reference to the fact <br /> that either the EPA method will be followed or that the laboratory quality assurance <br /> plan will be followed, which ever is more stringent. The Work Plan should define <br /> calibration requirements for the different methods, since the EPA methods often are <br /> interpreted differently by different laboratories, and a consistent comparable <br /> approach is important to the generation of quality data. This lack of uniformity <br /> may even apply to two laboratories in different locations within the same <br /> organization. It is recommended that, at a minimum, the quality control <br /> requirements and especially acceptance criteria for calibration for each method be <br /> summarized (for example in a table) for each of the methods which will be used in <br /> the project. This will help ensure a more uniform product and guard against <br /> problems which might occur if the laboratory is changed during the course of the <br /> study. <br /> 59. Amendment to Field Sampling Approach, Table 3.3-9, Specified Analytical Methods <br /> for Soil and Groundwater; Amendment to Quality Assurance Project Plan, Table 13- <br /> 2A, Analytical Method References for DDRW-Tracy; Table B-15A, Method <br /> Reporting Limits Miscellaneous Parameters <br /> Regional guidance requires that where modifications to EPA methods will be used, <br /> or where methods which will be used are not readily available, that copies of these <br /> methods or a laboratory standard operating procedure (SOP) be provided for review. <br /> Several of the analyses in this table fall in this category. Specifically, both EPA <br /> Methods 632 and 300.0 are water methods which must be modified for the analysis of <br /> solid material. The most current version of EPA Method 300.0 is August, 1991. The <br /> reference in the table is incorrect and should be changed. EPA Method 8015 is to be <br /> modified using a laboratory approach for the analysis of ethylene glycol and total <br /> petroleum hydrocarbons. State of California.methods, such as those cited for <br /> USEPA/R9 12 Apr 93 12/19 <br />