Michigan DEQ Operational Memorandum 2

KAR Laboratories is fully compliant with the new testing requirements of Operational Memorandum 2 (OM2), which was implemented by the Michigan Department of Environmental Quality earlier this year. OM2, which was developed by the DEQ’s Remediation and Redevelopment Division, provides guidance for cleanups implemented under Parts 201, 211, and 213 of the Natural Resources and Environmental Protection Act (Michigan PA 451). A brief discussion of KAR’s response to the new OM2 requirements follows.

Like previous guidance documents, OM2 lists various required “Target Detection Limits” (TDLs) for the measurement of most metals in the total soil sample “as received.” However, the DEQ has recently determined that the “fine soil fraction” (comprising soil particles less than 0.25mm in size) should be isolated for lead analysis and subsequent comparison to regulatory limits related to direct human contact and inhalation criteria. Because the total lead concentration remains relevant, the “coarse” fraction (comprising soil particles greater than 0.25mm but less than 2mm) must be analyzed separately so that a total lead value may be calculated. KAR Laboratories has established its own standard operating procedure for soil fractionation which includes all major elements of DEQ SOP 213. As of July 2006, we have processed over 1300 environmental soil samples for fine/coarse fraction lead.

KAR offers sub-ppb analysis for Ethylene Dibromide (EDB) and Dibromochloropropane (DBCP) by EPA Methods 504/8011 and we can satisfy OM2 TDL requirements for all listed fuel oxygenates using full scan GC/MS. Due to KAR’s Large Volume Injection (LVI) capabilities, we are able to offer low level quantification of many semi-volatile target compounds without resorting to costly Selected Ion Monitoring (SIM) methods. This is particularly significant since the DEQ has recently stated that certain SIM results “cannot be used for regulatory purposes.” However, because certain requirements for extremely low TDLs leave no other option, we have also developed sophisticated Selected Ion Monitoring methods for various volatile compounds, including 1,4-Dioxane. All of KAR’s SIM testing procedures also employ the isotope dilution technique, which significantly improves the accuracy of the method.

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4425 Manchester Road

Kalamazoo, MI 49001

(269) 381-9666