Publication 9240.1-05
                                               PB94-963501
                                             EPA540/R-94/012
                                               February 1994
USEPA CONTRACT LABORATORY PROGRAM
   NATIONAL FUNCTIONAL GUIDELINES
                     FOR
          ORGANIC DATA REVIEW
        Office of Emergency and Remedial Response
          U.S. Environmental Protection Agency
                Washington, DC 20460

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                                  NOTICE
  The polices and procedures set forth here are intended as guidance to the Agency
  and other governmental employees. They do not constitute rulemaking by the
  agency, and may not be relied on to create a substantive or procedural right
  enforceable by any other person. The Government may take action that is at
  variance with the policies and procedures in this manual.	
Additional copies of this document can be obtained from:

National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4650
Document Number PB 94-963502

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                                 TABLE OF CONTENTS

                                                                                     Page
INTRODUCTION	  1
PRELIMINARY REVIEW                                                                 2
DATA QUALIFIER DEFINITIONS                                                         4
VOLATILE DATA REVIEW  	  5

I.      Holding Times	  6
II.     GC/MS Instrument Performance Check	  9
III.     Initial Calibration 	  12
IV.     Continuing Calibration	  17
V.     Blanks	  20
VI.     System Monitoring Compounds	26
VII.    Matrix Spikes/Matrix Spike Duplicates	  30
VIII.   Laboratory Control Samples	  32
IX.     Region Quality Assurance and Control 	  34
X.     Internal Standards	  35
XI.     Target Compound Identification	  37
XII.    Compound Quantitation and Reported Contract Required Quantitation Limits	  39
XIII.   Tentatively Identified Compounds	41
XIV.   System Performance	45
XV.    Overall Assessment	47

SEMIVOLATILE DATA REVIEW 	48
I.      Holding Times	49
II.     GC/MS Instrument Performance Check	  51
III.     Initial Calibration 	  55
                                           in

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IV.     Continuing Calibration	  59
V.      Blanks	  62
VI.     Surrogate Spikes	  66
VII.     Matrix Spikes/Matrix Spike Duplicates	  69
VIII.    Laboratory Control Samples	  71
IX.     Region Quality Assurance and Control  	  73
X.      Internal Standards	  74
XI.     Target Compound Identification	  76
XII.     Compound Quantitation and Reported Contract Required Quantitation Limits	  78
XIII.    Tentatively Identified Compounds	  80
XIV.    System Performance	  84
XV.     Overall Assessment	  86

PESTICIDE/AROCLOR DATA REVIEW                                                      87
I.       Holding Times	  88
II.      GC/ECD Instrument  Performance Check	  90
III.     Initial Calibration  	  96
IV.     Calibration Verification 	  100
V.      Blanks	  103
VI.     Surrogate Spikes	  108
VII.     Matrix Spikes/Matrix Spike Duplicates	  Ill
VIII.    Laboratory Control Samples	  113
IX.     Region Quality Assurance and Control  	  115
X.      Pesticide Cleanup Checks	  116
XI.     Target Compound Identification	  119
XII.     Compound Quantitation and Reported Contract Required Quantitation Limits	  122
XIII.    Overall Assessment  	  124
                                               IV

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                                         INTRODUCTION
        This document is designed to offer guidance on EPA Contract Laboratory Program (CLP) organic
analytical data evaluation and review. In some applications it may be used as a Standard Operating
Procedure (SOP). In other, more subjective areas, only general guidance is offered due to the complexities
and uniqueness of data relative to specific samples.  For example, areas where the application of specific
SOPs are possible are primarily those in which definitive performance criteria are established. These criteria
are concerned with specifications that are not sample dependent; they specify performance requirements that
should fully be under a laboratory's control. These specific areas include blanks, calibration standards,
performance evaluation standard materials, and instrument performance checks (tuning).

        These guidelines include the requirements for the Organic Analysis Multi-Media Multi-
Concentration method, and for the Low Concentration Water Organic Analysis method.  To ensure that the
data review guidelines that are unique to the Low Concentration Water Samples are easily identified, these
requirements and procedures are presented in italics and contained within brackets  ([ ]) throughout the document.

        This document is intended to assist in the technical review of analytical data generated through the
CLP.  Determining contract compliance is not the intended objective of these guidelines. The data review
process provides information on analytical limitations of data based on specific quality control (QC) criteria.
In order to provide more specific usability statements, the reviewer must have a complete understanding of
the intended use of the data.  For this reason, it is recommended that whenever possible the reviewer obtain
usability issues from the user prior to reviewing the  data. When this is not possible, the user should be
encouraged to communicate any questions of the reviewer.

        At times, there may be a need to use data which does not meet all contract requirements and technical
criteria. Use of these data does not constitute either a new requirement standard or full acceptance of the
data. Any decision to utilize data for which performance criteria have not been met is strictly to facilitate the
progress of projects requiring the availability of the  data. A contract laboratory submitting data which are out
of specification may be required to rerun samples or resubmit data, even if the previously submitted data have
been utilized due to program needs. Data which do not meet specified requirements are never fully
acceptable.  The only exception to this condition is in the area of the requirements for individual sample
analysis; if the nature of the sample itself inhibits the attainment of specifications, appropriate allowances
must be made.

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                                    PRELIMINARY REVIEW
        In order to use this document effectively, the reviewer should have a general overview of the sample
delivery group (SDG) or sample case at hand. The exact number of samples, their assigned numbers, their
matrix and the number of laboratories involved in their analysis are essential information. Background
information on the site is helpful but often this information may be difficult to locate. The site manager is the
best source for answers to questions or further direction.

        Sample cases (SDGs) routinely have unique samples which require special attention by the reviewer.
These include field blanks, field duplicates, and performance audit samples which need to be identified. The
sampling records should identify:

               1. The Project Officer for site.

               2. The Complete list of samples with information on:

                       a. sample matrix,
                       b. field blanks,
                       c. field duplicates,
                       d. field spikes,
                       e. QC audit samples,
                       f. shipping dates,
                       g. preservatives, and
                       h. laboratories involved.
        The chain-of-custody record includes sample descriptions and date(s) of sampling. The reviewer
must take into account lag times between sampling and start of analysis when assessing technical sample
holding times.

        The laboratory's SDG Narrative is another source of general information.  Notable problems with
matrices, insufficient sample volume for analysis or reanalysis, samples received in broken containers,
preservation, and unusual events should be found in the SDG Narrative.

        The SDG Narrative for the sample data package must include a Laboratory Certification Statement
(exactly as written in the method), signed by the laboratory manager or his designee. This statement
authorizes the validation and release of the sample data results. In addition, the laboratory must also provide
comments in the SDG narrative describing in detail any problems encountered in processing the samples in
the data package.

        For every data package, the reviewer must verify that the laboratory certification statement is present,
exactly stated as in the method (i.e., verbatim to the  statement in the method), and signed by the Laboratory
Manager or designee. The reviewer must further verify that the data package is consistent with the
laboratory's certified narrative. Also, the reviewer should check the comments provided in the narrative to
determine if they are sufficient to describe and explain any associated problem(s).

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        The data review should include comments that clearly identify the problems associated with a Case
or Sample Delivery Group and to state the limitations of the data.  Documentation should include the sample
number, analytical method, extent of the problem, and assigned qualifiers.

        A data review narrative generally accompanies the laboratory data forwarded to the intended data
recipient (client) or user to promote communications.  A copy of the data review narrative should be
submitted to the Regional CLP Technical Project Officer (TPO) assigned oversight responsibility for the
laboratory producing the data.

        It is a responsibility to notify the appropriate Regional CLP TPO concerning problems and
deficiencies with regard to laboratory data. If there is an urgent requirement, the TPO may be contacted by
telephone to expedite corrective action. It is recommended that all items for TPO action be presented at one
time.

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                              DATA QUALIFIER DEFINITIONS
       The following definitions provide brief explanations of the national qualifiers assigned to results in
the data review process.  If the Regions choose to use additional qualifiers, a complete explanation of those
qualifiers should accompany the data review.
U     -       The analyte was analyzed for, but was not detected above the reported sample
               quantitation limit.

J      -       The analyte was positively identified; the associated numerical value is the
               approximate concentration of the analyte in the sample.

N     -       The analysis indicates the present of an analyte for which there is presumptive
               evidence to make a "tentative identification."

NJ    -       The analysis indicates the presence of an analyte that has been "tentatively identified"
               and the associated numerical value represents its approximate concentration.

UJ    -       The analyte was not detected above the reported sample quantitation limit.  However,
               the reported quantitation limit is approximate and may or may not represent the
               actual limit of quantitation necessary to accurately and precisely measure the analyte
               in the sample.

R     -       The sample results are rejected due to serious deficiencies in the ability to analyze the
               sample and meet quality control criteria. The presence or absence of the analyte
               cannot be verified.

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                                  VOLATILE DATA REVIEW


*** Data review guidelines that are unique to data generated through the Low Concentration Water Method are
contained within brackets ([]) and written in italics. ***


The volatile data requirements to be checked are listed below:

       I.      Holding Times (Method Holding Times)

       II.     GC/MS Instrument Performance Check

       III.    Initial Calibration

       IV.    Continuing Calibration

       V.     Blanks

       VI.    System Monitoring Compounds

       VII.   Matrix Spikes/Matrix Spike Duplicates

       VIII.   Laboratory Control Samples

       IX.    Regional Quality Assurance and Quality Control

       X.     Internal Standards

       XI.    Target Compound Identification

       XII.   Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs)

       XIII.   Tentatively Identified Compounds

       XIV.   System Performance

       XV.   Overall Assessment of Data

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                                       I.   Holding Times
A.     Review Items:  Form IVOA [Form ILCV], EPA Sample Traffic Report and/or chain-of-custody,
       raw data, and SDG Narrative.

B.     Objective:

       The objective is to ascertain the validity of the analytical results based on the holding time of the
       sample from the time of collection to the time of analysis.

C.     Criteria:

       Technical requirements for sample holding times have only been established for water matrices.

       The technical holding time criteria for water samples are as follows:

               For non-aromatic volatile compounds in cooled (@ 4°C) water samples, the
               maximum holding time is 14 days from sample collection.

               Maximum holding times for purgeable aromatic hydrocarbons in cooled (@ 4°C +
               2°C), acid-preserved (with HC1 to pH 2 or below) water samples is 14 days from
               sample collection.

               Water samples that have not been maintained at 4 °C (+ 2 °C) and preserved to a pH
               of 2 or below should be analyzed within 7 days from sample collection.  If
               insufficient ice is used to ship samples, the laboratory may receive samples with no
               ice left in the cooler. Under these circumstances, the temperature of the samples
               may exceed 4°C.

       NOTE: It is further recommended that volatile compounds in properly preserved (4°C + 2°C) non-
       aqueous samples be analyzed within 14 days of sample collection.
       The method maximum holding times, which differ from the technical maximum holding times, state
       that water and soil samples are to be analyzed within 10 days from the validated time of sample
       receipt (VTSR) at the laboratory.

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D.
Evaluation:
        Technical holding times are established by comparing the sampling dates on the EPA Sample Traffic
        Report with dates of analysis on Form I VOA [Form ILCV] and the raw data. Information contained
        in the complete SDG file should also be considered in the determination of holding times. Verify that
        the analysis dates on the Form Is and the raw data/SDG file are identical. Review the SDG narrative
        to determine if samples were preserved.  If there is no indication in the SDG narrative or the sample
        records that there was a problem with the samples (e.g., samples not maintained @ 4°C or
        containing headspace in the samples), then the integrity of samples can be assumed to be good.  If it
        is indicated that there were problems with the samples, then the  integrity of the sample may have
        been compromised and professional judgement should be used to evaluate the effect of the problem
        on the sample results.
E.
Action:
               If technical holding times are exceeded, document in the data review narrative that holding
               times were exceeded and qualify the sample results as follows (also see Table 1):

               a.      If there is no evidence that the samples were properly preserved and the technical
                      holding times exceeded 7 days, qualify positive results for aromatic compounds with
                      "J" and sample quantitation limits with "UJ". Use professional judgement to
                      determine if and how non-aromatic volatile compounds should also be  qualified.

               b.      If the samples were properly preserved but the technical holding times exceeded 14
                      days, qualify positive results with "J" and sample quantitation limits with "UJ".

              Table 1. Qualification of Volatile Analytes Based on Technical Holding Times
MATRIX
Water

Non-aqueous
PRESERVED
No
Yes
No/Yes
> 7 DAYS
All Aromatics*
None
Professional
Judgement
> 14 DAYS
All Compounds
All Compounds
Professional
Judgement
                      Reviewer should use professional judgement to determine if data for
                      additional compounds require qualification.
       2.      If technical holding times are grossly exceeded (e.g., by greater than two times the required
               time for volatiles) either on the first analysis or upon re-analysis, the reviewer must use
               professional judgement to determine the reliability of the data and the effects of additional

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               storage on the sample results. Should the reviewer determine that qualification is necessary,
               non-detected volatile target compounds may be qualified unusable (R). Positive results are
               considered approximates and are qualified with "J".

        3.      Due to limited information concerning holding times for non-aqueous samples, it is left to
               the discretion of the data reviewer to apply water holding times or other information that is
               available.

        4.      Whenever possible, the reviewer should comment on the effect of the holding time
               exceedance on the resulting data in the data review narrative.

        5.      When method and/or technical holding times are grossly exceeded, this should be noted for
               TPO action.

        6.      The reviewer should also be aware of the scenario in which the laboratory has exceeded the
               technical holding times, but met method holding times. In this case, the data reviewer should
               notify the Regional TPO (where samples were collected) and/or RSCC that shipment delays
               have occurred so that the field problem can be corrected. The reviewer may pass this
               information on to the laboratory's TPO, but should explain that the laboratory met the
               requirements in the method.

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                          II. GC/MS Instrument Performance Check


A.     Review Items: Form V VOA [Form VLCV], BFB mass spectra and mass listing.

B.     Objective:

       Gas chromatograph/mass spectrometer (GC/MS) instrument performance checks are performed to
       ensure mass resolution, identification, and to some degree, sensitivity. These criteria are not sample
       specific. Conformance is determined using standard materials, therefore, these criteria should be met
       in all circumstances.

C.     Criteria:

       The analysis of the instrument performance check solution must be performed at the beginning of
       each 12-hour period during which samples or standards are analyzed.  The instrument performance
       check, bromofluorobenzene (BFB) for volatile analysis, must meet the ion abundance criteria given
       below.
                     Bromofluorobenzene (BFB)
                     m/z           ION ABUNDANCE CRITERIA

                     50            8.0 - 40.0% of m/z 95
                     75            30.0 - 66.0% of m/z 95
                     95            Base peak, 100% relative abundance
                     96            5.0 - 9.0% of m/z 95
                     173           Less than 2.0% of m/z 174
                     174           50.0 - 120.0% of m/z 95
                     175           4.0 - 9.0% of mass 174
                     176           93.0-101.0% of m/z 174
                     177           5.0 - 9.0% of m/z 176
       NOTE: All ion abundances must be normalized to m/z 95, the nominal base peak, even though the
              ion abundance of m/z 174 may be up to 120 percent that of m/z 95.

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D.     Evaluation:
        1.      Compare the data presented for each Instrument Performance Check (Form V VOA [Form V
               LCVJ) with each mass listing submitted to ensure the following:

               a.      Form V VOA [Form VLCV] is present and completed for each 12-hour period
                      during which samples were analyzed.

               b.      The laboratory has not made transcription errors between the data and the form. If
                      there are major differences between the mass listing and the Form Vs, a more in-
                      depth review of the data is required. This may include obtaining and reviewing
                      additional information from the laboratory.

               c.      The appropriate number of significant figures has been reported (number of
                      significant figures given for each ion in the ion abundance criteria column) and that
                      rounding is correct.

               d.      The laboratory has not made calculation errors.

        2.      Verify from the raw data (mass spectral listing) that the mass assignment  is correct and that
               the mass listing is normalized to m/z 95.

        3.      Verify that the ion abundance criteria was met.  The criteria for m/z 173,  175, 176, and 177
               are calculated by normalizing to the specified m/z.

        4.      If possible, verify that spectra were generated using appropriate background subtraction
               techniques. Since the BFB spectrum is obtained from chromatographic peaks that should be
               free from coelution problems, background subtraction should be done in accordance with the
               following procedure.  Three scans (the  peak apex scan and the scans immediately preceding
               and following the apex) are acquired and averaged. Background subtraction is required, and
               must be accomplished using a single scan no more than 20 scans prior to the elution of BFB.
               Do not subtract as part of the background the BFB peak.
       NOTE: All instrument conditions must be identical to those used during the sample analysis.
               Background subtraction actions resulting in spectral distortions for the sole purpose of
               meeting the method specifications are contrary to the quality assurance objectives and are
               therefore unacceptable.
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E.      Action:
        1.      If the laboratory has made minor transcription errors which do not significantly affect the
               data, the data reviewer should make the necessary corrections on a copy of the form.

        2.      If the laboratory has failed to provide the correct forms or has made significant transcription
               or calculation errors, the Region's designated representative should contact the laboratory
               and request corrected data. If the information is not available, then the reviewer must use
               professional judgement to assess the data. The laboratory's TPO should be notified.

        3.      If mass assignment is in error (such as m/z 96 is indicated as the base peak rather than m/z
               95), classify all associated data as unusable (R).

        4.      If ion abundance criteria are not met, professional judgement may be applied to determine to
               what extent the data may be utilized. Guidelines to aid in the application of professional
               judgement to this topic are discussed as follows:

               The most important factors to consider are the empirical results that are relatively insensitive
               to location on the chromatographic profile and the type of instrumentation. Therefore, the
               critical ion abundance criteria for BFB are the m/z 95/96, 174/175, 74/176, and 176/177
               ratios. The relative abundances of m/z 50 and 75 are of lower importance.

        5.      Decisions to use analytical data associated with BFB instrument performance checks not
               meeting contract requirements should be clearly noted on the data review narrative.

        6.      If the reviewer has reason to believe that instrument performance check criteria were
               achieved using techniques other than those described in II.D.4, then additional information
               on the instrument performance checks should be obtained. If the techniques employed are
               found to be at variance with the  contract requirements, the performance and procedures of
               the laboratory may merit evaluation. Concerns or questions regarding laboratory
               performance should be noted for TPO action. For example, if the reviewer has reason to
               believe that an inappropriate technique was used to obtain background subtraction (such as
               background subtracting from the solvent front or from another region of the chromatogram
               rather than the BFB peak), then this should be noted for TPO action.
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                                      III. Initial Calibration


A.      Review Items:  Form VIVOA [Form VILCV], quantitation reports, and chromatograms.

B.      Objective:

        Compliance requirements for satisfactory instrument calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data for compounds on the
        volatile target compound list (TCL).  Initial calibration demonstrates that the instrument is capable of
        acceptable performance in the beginning of the analytical run and of producing a linear calibration
        curve.

C.      Criteria:

        1.      Initial calibration standards containing both volatile target compounds and system
               monitoring compounds are analyzed at concentrations of 10, 20, 50, 100, and 200 ug/L at
               the beginning of each analytical sequence or as necessary if the continuing calibration
               acceptance criteria are not met. The initial calibration (and any associated samples and
               blanks) must be analyzed within 12 hours of the associated instrument performance check.

               [For data generated through the Low Concentration Water Method: Initial calibration standards
               containing both volatile target compounds and system monitoring compounds are analyzed at
               concentrations ofl, 2, 5, 10, and 25 ug/L for non-ketones and 5, 10, 25, 50, and 125 ug/L for
               ketones at the beginning of each analytical sequence or as necessary if the continuing calibration
               acceptance criteria are not met.

        2.      Separate initial calibrations must be performed for water samples (or medium level soil
               samples) and for low level soil samples.  The calibration for water samples and medium
               level soil samples is performed with an unheated purge and the calibration for low level soil
               samples is performed with a heated purge.

        3.      Initial calibration standard Relative Response Factors (RRFs) for all volatile target
               compounds and system monitoring compounds must be greater than or equal to 0.05.
               (Contractual initial calibration RRF criteria are listed in the appropriate Method.,)

        4.      The Percent Relative Standard Deviation (%RSD) from the initial calibration must be  less
               than or equal to 30.0% for all compounds.
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D.      Evaluation:
        1.      Verify that the correct concentration of standards were used for the initial calibration (i.e.,
               10, 20, 50, 100, and 200 ug/L for water).

               [Verify that the correct concentration of standards were used for the initial calibration (i.e., 1, 2, 5,
               10, and 25 ug/L for non-ke tones and 5, 10, 25, 50, and 125 ug/L for ketones).]

        2.      Verify that the correct initial calibration was used for water and medium level soil samples
               (i.e., unheated purge)  and for low level soil samples (i.e., heated purge).

        3.      If any sample results were calculated using an initial calibration, verify that the correct
               standard (i.e., the 50 ug/L standard) was used for calculating sample results and that the
               samples were analyzed within 12 hours of the associated instrument performance check.

               [If any sample results were calculated using an initial calibration, verify that the correct standard
               (i.e., the 5 ug/L for non-ketones and 25 ug/L for ketones) was used for calculating sample results
               and that the samples  were analyzed within 12 hours of the associated instrument performance
               check.]
               Evaluate the initial calibration RRFs and RRF for all volatile target compounds and system
               monitoring compounds:
               a.      Check and recalculate the RRFs and RRF for at least one volatile target compound
                       associated with each internal standard; verify that the recalculated value(s) agrees
                       with the laboratory reported value(s).

               b.      Verify that for all volatile target compounds and system monitoring compounds, the
                       initial calibration RRFs are greater than or equal to 0.05.

        NOTE: The criteria employed for technical data review purposes are different from those used in the
               method. The laboratory must meet a minimum RRF criterion of 0.01, however, for data
               review purposes, the "greater than or equal to 0.05" criterion is applied to all volatile
               compounds.
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                    Table 2. Volatile Target Compounds Exhibiting Poor Response
                      Acetone                               1,2-Dichloropropane
                      2-Butanone                            2-Hexanone
                      Carbon disulfide                       Methylene chloride
                      Chloroethane                          4-Methyl-2-pentanone
                      Chloromethane                        Toluene-d81
                      1,2-Dichloroethene (total)t             l,2-Dichloroethane-d4t
                      trans-l,2-Dichloroethene f               l,2-Dibromo-3-chloropropane £
                      cis-1,2-Dichloroethene f

                      | Multi-media, Multi-concentration only
                      / Low Concentration Water only
       5.      Evaluate the %RSD for all volatile target compounds and system monitoring compounds:

               a.      Check and recalculate the %RSD for one or more volatile target compound(s);
                      verify that the recalculated value(s) agrees with the laboratory reported value(s).

               b.      Verify that all volatile target compounds have a %RSD of less than or equal to
                      30.0%. The method criteria for an acceptable initial calibration specifies that up to
                      any 2 volatile target compounds may fail to meet minimum RRF or maximum
                      %RSD as long as they have RRFs that are greater than or equal to 0.010, and
                      %RSD of less  than or equal to 40.0%.  For data review purposes, however, all
                      compounds must be considered for qualification when the %RSD exceeds the +
                      30.0% criterion.

               c.      If the %RSD is greater than 30.0%, then the reviewer should use professional
                      judgement to determine the need to check the points on the curve for the cause of the
                      non-linearity.  This is checked by eliminating either the high point or the low point
                      and recalculating the %RSD.

       6.      If errors are detected in the calculations of either the RRFs or the %RSD, perform a more
               comprehensive recalculation.
E.     Action:
                                               14

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1.       All volatile target compounds, including the 12 "poor performers" will be qualified using the
        following criteria:

        a.      If the %RSD is greater than 30.0% and all initial calibration RRFs greater than or
               equal to 0.05, qualify positive results with "J", and non-detected volatile target
               compounds using professional judgement.

        b.      If any initial calibration RRF is less than 0.05, qualify positive results that have
               acceptable mass spectral identification with "J", using professional judgement, and
               non-detected analytes as unusable (R).

2.       At the reviewer's discretion, a more in-depth review to minimize the qualification of data can
        be accomplished by considering the following:

        a.      If any of the required volatile compounds have a %RSD greater than 30.0%, and if
               eliminating either the high or the low point of the curve does not restore the %RSD
               to less than or equal to 30.0%:

               i.       Qualify positive results for that compound(s) with "J".

               ii.       Qualify non-detected volatile target compounds based on professional
                       judgement.

        b.      If the high point of the curve is outside of the linearity criteria (e.g. due to
               saturation):

               i.      No qualifiers are required for positive results in the linear portion of the
                        curve.

               ii.       Qualify positive results outside of the linear portion of the curve with a "J".

               iii.      No qualifiers are needed volatile target compounds that were not detected.

        c.      If the low end of the curve is outside of the linearity criteria:

               i.      No qualifiers are required for positive results in the linear portion of the
                        curve.

               ii.       Qualify low level positive results in the area of non-linearity with "J".

               iii.       Qualify non-detected volatile target compounds based on professional
                       judgement.
3.       If the laboratory has failed to provide adequate calibration information, the designated
        representative should contact the laboratory and request the necessary information. If the
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               information is not available, the reviewer must use professional judgement to assess the
               data.

               Whenever possible, the potential effects on the data due to calibration criteria exceedance
               should be noted in the data review narrative.

               If calibration criteria are grossly exceeded, this should be noted for TPO action.
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                                    IV.  Continuing Calibration


A.      Review Items:  Form VIIVOA [Form VIILCV], quantitation reports, and chromatograms.

B.      Objective:

        Compliance requirements for satisfactory instrument calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data.  Continuing
        calibration establishes the 12-hour relative response factors on which the quantitations are based and
        checks satisfactory performance of the instrument on a day-to-day basis.

C.      Criteria:

        1.      Continuing calibration standards containing both target compounds and system monitoring
               compounds are analyzed at the beginning of each 12-hour analysis period following the
               analysis of the instrument performance check and prior to the analysis of the method blank
               and samples.

        2.      The continuing calibration RRF for volatile target compounds and system monitoring
               compounds must be greater than or equal to 0.05.
        3.      The percent difference (%D) between the initial calibration RRF and the continuing
               calibration RRF must be within + 25.0%.

               [For data generated through the Low Concentration Water Method: The percent difference (%D)
               between the initial calibration RRF and the continuing calibration RRF must be within j_30.0%.]
D.      Evaluation:
        1.      Verify that the continuing calibration was run at the required frequency and that the
               continuing calibration was compared to the correct initial calibration.

        2.      Evaluate the continuing calibration RRF for all volatile target compounds and system
               monitoring compounds:

               a.      Check and recalculate the continuing calibration RRF for at least one volatile target
                       compounds associated with each internal standard; verify that the recalculated
                       value(s) agrees with the laboratory reported value(s).

               b.      Verify that all volatile target compounds and system monitoring compounds meet
                       the RRF specifications.
                                                17

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VGA
       NOTE:         The criteria employed for data review purposes are different from those defined in
                       the method. The compounds listed in Table 2 (VOA Section III.D.4) have no
                       method maximum %D criteria. The laboratory must meet a minimum RRF criterion
                       of 0.01, however, for data review purposes, the "greater than or equal to 0.05"
                       criterion is applied to all volatile compounds.
        3.      Evaluate the %D between initial calibration RRF and continuing calibration RRF for one or
               more compound(s).

               a.       Check and recalculate the %D for one or more volatile target compound(s)
                       associated with each internal standard; verify that the recalculated value(s) agrees
                       with the laboratory reported value(s).

               b.       Verify that the %D is within + 25.0% for all volatile target compounds and system
                       monitoring compounds. Note those compounds which have a %D outside the +
                       25.0% criterion. The method criteria for an acceptable continuing calibration
                       specifies that up to any 2 volatile target compounds may fail to meet minimum RRF
                       or maximum %D as long as they have RRFs that are greater than or equal to 0.010,
                       and %D of less than or equal to 40.0%. For data review purposes, however, all
                       compounds must be considered for qualification when the %D exceeds the + 25.0%
                       criterion.

        4.      If errors are detected in the calculations of either the continuing calibration RRF or the %D,
               perform a more comprehensive recalculation.
E.     Action:
        1.      The reviewer should use professional judgement to determine if it is necessary to qualify the
               data for any volatile target compound.  If qualification of data is required, it should be
               performed using the following guidelines:

               a.      If the %D is outside the + 25.0% criterion and the continuing calibration RRF is
                      greater than or equal to 0.05, qualify positive results with "J".

               b.      If the %D is outside the + 25.0% criterion and the continuing calibration RRF is
                      greater than or equal to 0.05, qualify non-detected volatile target compounds with
                      "UJ".

               c.      If the continuing calibration RRF is less than 0.05, qualify positive results that have
                      acceptable mass spectral identifications with "J" or use professional judgement.
                                                18

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                                                                                        VGA
        d.       If the continuing calibration RRF is less than 0.05, qualify non-detected volatile
                target compounds as unusable (R).

2.       If the laboratory has failed to provide adequate calibration information, the designated
        representative should contact the laboratory and request the necessary information. If the
        information is not available, the reviewer must use professional judgement to assess the
        data.

3.       Whenever possible, the potential effects on the data due to calibration criteria exceedance
        should be noted in the data review narrative.

4.       If calibration criteria are grossly exceeded, this should be noted for TPO action.
                                          19

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VGA
                                           V.  Blanks
A.      Review Items: Form IVOA [Form ILCV], Form IV VOA [Form IVLCV], chromatograms, and
        quantitation reports.

B.      Objective:

        The purpose of laboratory (or field) blank analysis is to determine the existence and magnitude of
        contamination resulting from laboratory (or field) activities.  The criteria for evaluation of blanks
        apply to any blank associated with the samples (e.g., method blanks, instrument blanks, trip blanks,
        and equipment blanks). If problems with any blank exist, all associated data must be carefully
        evaluated to determine whether or not there is an inherent variability in the data, or if the problem is
        an isolated occurrence not affecting other data.

C.      Criteria:

        1.      No  contaminants should be found in the blanks.

        2.      A method blank analysis must be performed after the calibration standards and once for
               every 12-hour time period beginning with the injection of BFB.

        3.      The method blank must be analyzed on each GC/MS system used to analyze samples for
               each type of analysis, i.e., unheated purge (water and medium level soil) and heated purge
               (low level soil).

        4.      A storage blank must be prepared upon receipt of the first samples from an SDG, and stored
               with samples until analysis. The storage blank must be analyzed once per SDG.

        5.      An  instrument blank must be analyzed after any sample that has saturated ions from a given
               compound to check that the blank is free of interference and the system is not contaminated.

D.      Evaluation:

        1.      Review the results of all associated blanks on the forms and raw data (chromatograms and
               quantitation reports) to evaluate the presence of target and non-target compounds in the
               blanks.

        2.      Verify that a method blank analysis has been reported per matrix, per concentration level, for
               each 12-hour time period on each GC/MS system used to analyze volatile samples. The
               reviewer can use the Method Blank Summary (Form IV VOA [Form IVLCV]) to identify the
               samples associated with each method blank.
                                                20

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                                                                                             VGA

        3.      Verify that a storage blank has been analyzed and included with each SDG and that the
               storage blanks are free of contamination.

        4.      Verify that the instrument blank analysis has been performed following any sample analysis
               where a target analyte(s) is/are reported at high concentration(s).
E.     Action:
        If the appropriate blanks were not analyzed with the frequency described in Criteria 2, 3, and 4, and 5
        then the data reviewer should use professional judgement to determine if the associated sample data
        should be qualified. The reviewer may need to obtain additional information from the laboratory.
        The situation should be noted for TPO action.

        Action regarding unsuitable blank results depends on the circumstances and origin of the blank.
        Positive sample results should be reported unless the concentration of the compound in the sample is
        less than or equal to 10 times (lOx) the amount in any blank for the common volatile laboratory
        contaminants (methylene chloride, acetone, and 2-butanone ), or 5 times (5x) the amount for other
        volatile target compounds. In instances where more than one blank is associated with a given
        sample, qualification should be based upon a comparison with the associated blank having the
        highest concentration of a contaminant.  The results must not be corrected by subtracting any blank
        value.
        Specific actions are as follows:

        1.      If a volatile compound is found in a blank but not found in the sample, no action is taken.  If
               the contaminants found are volatile target compounds (or interfering non-target compounds)
               at significant concentrations above the CRQL, then this should be noted for TPO action.

        2.      Any volatile compound detected in the sample (other than the common volatile laboratory
               contaminants), that was also detected in any associated blank, is qualified if the sample
               concentration is less than five times (5x) the blank concentration. The quantitation limit
               may also be elevated. Typically, the sample CRQL is elevated  to the concentration found in
               the sample. The reviewer should use professional judgement to determine if further
               elevation of the CRQL is required. For the common volatile laboratory contaminants, the
               results are qualified by elevating the quantitation limit to the concentration found in the
               sample when the sample concentration is less than 10 times (lOx) the blank concentration.

               The reviewer should note that blanks may not involve the same weights, volumes, or dilution
               factors as the associated samples.  These factors must be taken  into consideration when
               applying the "5x" and "lOx" criteria, such that a comparison of the total  amount of
               contamination is actually made.
                                                21

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VGA
               Additionally, there may be instances where little or no contamination was present in the
               associated blanks, but qualification of the sample is deemed necessary.  If the reviewer
               determines that the contamination is from a source other than the sample, he/she should
               qualify the data.  Contamination introduced through dilution water is one example.
               Although it is not always possible to determine, instances of this occurring can be detected
               when contaminants are found in the diluted sample result, but are absent in the undiluted
               sample result.  Since both results are not routinely reported, it may be impossible to verify
               this source of contamination. In this case, the "5x" or "lOx" rules may not apply; the target
               compound should be reported as not detected, and an explanation of the data qualification
               should be provided in the data review narrative.

        3.      If gross contamination exists (i.e., saturated peaks by GC/MS), all affected compounds in
               the associated samples should be qualified as unusable (R) due to interference.  This should
               be noted  for TPO action if the contamination is suspected of having an effect on the sample
               results.

        4.      If inordinate numbers of other target compounds are found at low levels in the blank(s), it
               may be indicative of a problem and should be noted for TPO action.

        5.      The same consideration given to the target compounds should also be given  to Tentatively
               Identified Compounds (TICs), which are found in both the sample and associated blank(s).
               (See VGA Section XII for TIC guidance.)

        6.      If contaminants are found in the storage blanks, the following action is recommended.

               a.     The associated method blank data should be reviewed to determine  if the
                      contaminant(s) was also present in the method blank. If the analyte was present at a
                      comparable level in the method blank, then the source of the contamination may be
                      in the analytical system and the action recommended for the method blank would
                      apply.

                      If the analyte was not present in the method blank, then the source of contamination
                      may be in the storage and all associated samples should be considered for possible
                      cross-contamination.

               b.     If the storage blank contains a volatile TCL compound(s) at a concentration greater
                      than the CRQL, then all positive results for that compounds(s)  should be qualified
                      with "J".  If the concentration level in the blank is significantly  high, then positive
                      sample results may require  rejection and be qualified with "R".  Non-detected
                      volatile target compounds should not require qualification unless the contamination
                      is so high that it interferes with the analysis of the non-detect compounds.
                                                22

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                                                                              VGA

If an instrument blank was not analyzed following a sample analysis which contained an
analyte(s) at high concentration(s), sample analysis results after the high concentration
sample must be evaluated for carryover. Professional judgement should be used to
determine if instrument cross-contamination has affected any positive compound
identification(s). If instrument cross-contamination is suggested, then this should be noted
for TPO action if the cross-contamination is suspected of having an effect on the sample
results.
                                 23

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VGA
       The following are examples of applying the blank qualification guidelines. Certain circumstances
       may warrant deviations from these guidelines.
               Example 1:
               Example 2:
Sample result is greater than the Contract Required Quantitation Limit
(CRQL), but is less than the 5x or lOx multiple of the blank result.
                             Blank Result
                             CRQL
                             Sample Result
                             Final Sample Result
                                     Rule
                                     lOx

                                      7
                                      5
                                      60
                                      60U
5x

7
5
30
SOU
                             In the example for the " lOx" rule, sample results less than 70 (or 10 x 7)
                             would be qualified as not detected. In the case of the "5x" rule, sample
                             results less than 35 (or 5x7) would be qualified as not detected.
Sample result is less than the CRQL, and is also less than the 5x or lOx
multiple of the blank result.
                                                                         Rule
                             Blank Result
                             CRQL
                             Sample Result
                             Final Sample Result
                                     lOx

                                      6
                                      5
                                      4J
                                      5U
5x

6
5
4J
5U
                             Note that data are not reported as 4U, as this would be reported as a
                             detection limit below the CRQL.
                                              24

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                                                                            VGA
Example 3:     Sample result is greater than the 5x or lOx multiple of the blank result.

                                                        Rule
                                                    lOx           5x
               Blank Result                          10            10
               CRQL                                 5            5
               Sample Result                         120           60
               Final Sample Result                    120           60

               For both the "lOx" and "5x" rules, sample results exceeded the adjusted
               blank results of 100 (or 10x10) and 50 (or 5x10), respectively, and
               therefore are not qualified.
                                25

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VGA
                               VI.  System Monitoring Compounds


A.      Review Items: Form IIVOA [Form IILCV], quantitation reports, and chromatograms.

B.      Objective:

        Laboratory performance on individual samples is established by means of spiking activities. All
        samples are spiked with system monitoring compounds, SMC, (formerly referred to as surrogates)
        just prior to sample purging.  The evaluation of the results of these system monitoring compounds is
        not necessarily straightforward.  The sample itself may produce effects due to such  factors as
        interferences and high concentrations of analytes. Since the effects of the sample matrix are
        frequently outside the control of the laboratory  and may present relatively unique problems, the
        evaluation and review of data based on specific sample results is frequently subjective and demands
        analytical experience and professional judgement. Accordingly, this section consists primarily of
        guidelines, in some cases with several optional  approaches suggested.

C.      Criteria:

        1.      Three system monitoring compounds (l,2-dichloroethane-d4, bromofluorobenzene, and
               toluene-d8) are added to all samples and blanks to measure their recovery in environmental
               samples in sample and blank matrices.

               [For data generated through the Low Concentration Water Method: A single system monitoring
               compound, bromofluorobenzene, is added to all samples and blanks to measure the recovery in
               sample and blank matrices.]

        2.      Recoveries for system monitoring compounds in volatile samples and blanks must be within
               the limits specified in the Method.

D.      Evaluation:

        1.      Check raw data (e.g., chromatograms and quantitation reports) to verify the recoveries on the
               System Monitoring Compound Recovery Form - Form II VOA [Form IILCV]. Check for
               any calculation or transcription errors.

        2.      Check that the system monitoring compound recoveries were calculated correctly. The
               equation can be found in the Method.

        3.      The following should be determined from the System Monitoring Compound Recovery
               form(s):
                                               26

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                                                                                            VGA
               a.      If any system monitoring compound(s) in the volatile fraction is out of specification,
                      there should be a reanalysis to confirm that the non-compliance is due to sample
                      matrix effects rather than laboratory deficiencies.

       NOTE:        When there are unacceptable system monitoring compound recoveries followed by
                      acceptable re-analyses, the laboratories are required to report only the successful
                      run.
               b.      The laboratory failed to perform acceptably if system monitoring compounds are
                      outside criteria with no evidence of re-analysis. Medium soils must first be re-
                      extracted prior to re-analysis when this occurs.

               c.      Verify that no blanks have system monitoring compounds outside the criteria.

       4.      Any time there are two or more analyses for a particular sample, the reviewer must
               determine which are the best data to  report. Considerations should include but are not
               limited to:

               a.      System monitoring compound recovery (marginal versus gross deviation).

               b.      Technical holding times.

               c.      Comparison of the values of the target compounds reported in each sample analysis.

               d.      Other QC information, such as performance of internal standards.

E.     Action:

       Data are qualified based on system monitoring compounds results if the recovery of any volatile
       system monitoring compound is out of specification. For system monitoring compound recoveries
       out of specification, the following approaches are suggested based on a review of all data from  the
       package, especially considering the apparent  complexity of the sample matrix.


       1.      If a system monitoring compound in the volatile sample has a recovery greater than the
               upper acceptance limit (UL):

               a.      Detected volatile target compounds are qualified "J.".

               b.      Results for non-detected volatile target compounds should not be qualified.
                                               27

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VGA
       2.      If a system monitoring compound in the volatile sample has a recovery greater than or equal
               to 10% but less than the lower acceptance limit (LL):

               a.      Detected volatile target compounds are qualified "J."

               b.      For non-detected volatile target compounds, the sample quantitation limit is
                      qualified as approximated (UJ).
       3.      If a system monitoring compound in a volatile sample shows less than 10% recovery:

               a.      Detected volatile target compounds are qualified "J".

               b.      Non-detected volatile target compounds may be qualified as unusable (R).
                                               28

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                                                                              VGA
          Table 3. Qualification of Volatile Analytes Based on
               System Monitoring Compound Recoveries


Detected analytes
Non-detected analytes
SMC Recovery
> UL 10% to LL < 10%
J
No
Qualification
J
UJ
J
R
In the special case of a blank analysis with system monitoring compounds out of
specification, the reviewer must give special consideration to the validity of associated
sample data. The basic concern is whether the blank problems represent an isolated problem
with the blank alone, or whether there is a fundamental problem with the analytical process.
For example, if one or more samples in the batch show acceptable system monitoring
compound recoveries, the reviewer may choose to consider the blank problem to be an
isolated occurrence.  However, even if this judgment allows some use of the affected data,
analytical problems should be noted for TPO action. Also note if there are potential
contractual problems associated with the lack of reanalysis of samples that were out of
specification.

Whenever possible, potential effects of the data resulting from system monitoring recoveries
not meeting the advisory limits should be noted in the data review narrative.
                                 29

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VGA
                           VII. Matrix Spikes/Matrix Spike Duplicates
                         (Not Required for Low Concentration Water Data)
A.     Review Items:  Form III VOA-1 and VOA-2, chromatograms, and quantitation reports.

B.     Objective:

       Data for matrix spike/matrix spike duplicates (MS/MSD) are generated to determine long-term
       precision and accuracy of the analytical method on various matrices and to demonstrate acceptable
       compound recovery by the laboratory at the time of sample analysis. These data alone cannot be
       used to evaluate the precision and accuracy of individual samples.  However, when exercising
       professional judgement, this data should be used in conjunction with other available QC information.

C.     Criteria:

       1.      Matrix spikes (MS) and matrix spike duplicate (MSD) samples are analyzed at frequency of
               one MS and MSD per 20 samples of similar matrix.

       2.      Spike recoveries should be within the advisory limits provided on Form III VOA-1 and 2.

       3.      Relative percent difference (RPD) between MS and MSD recoveries must be within the
               advisory limits provided on Form III VOA-1 and VOA-2.

D.     Evaluation:

       1.      Verify that MS and MSD samples were analyzed at the required frequency and that results
               are provided for each sample matrix.

       2.      Inspect results for the MS/MSD Recovery on Form III VOA-1 and VOA-2 and verify that
               the results  for recovery and RPD are within the advisory limits.

       3.      Verify transcriptions from raw data  and verify calculations.

       4.      Check that the matrix spike recoveries and RPD were calculated correctly.

       5.      Compare %RSD results of non-spiked compounds between the original result, MS, and
               MSD.
                                               30

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                                                                                           VGA

E.     Action:

       1.       No action is taken on MS/MSD data alone. However, using informed professional judgment
               the data reviewer may use the MS and MSD results in conjunction with other QC criteria and
               determine the need for some qualification of the data.
       2.      The data reviewer should first try to determine to what extent the results of the MS/MSD
               affect the associated data. This determination should be made with regard to the MS/MSD
               sample itself as well as specific analytes for all samples associated with the MS/MSD.

       3.      In those instances where it can be determined that the results of the MS/MSD affect only the
               sample spiked, then qualification should be limited to this sample alone. However, it may be
               determined through the MS/MSD results that a laboratory is having a systematic problem in
               the analysis of one or more analytes, which affects all associated samples.

       4.      The reviewer must use professional judgement to determine the need for qualification of
               positive results of non-spiked compounds.

       NOTE:        If a field blank was used for the MS/MSD, the TPO must be notified.
                                               31

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VGA
                                  VIII.  Laboratory Control Samples
                                         (Low Concentration Water)
[A.     Review Items: Form IIILCV-1, LCS chromatograms and quantitation reports.

B.      Objective:

        Data for laboratory control samples (LCS) are generated to provide information on the accuracy of the
        analytical method and on the laboratory performance.

C.      Criteria:

        1.      A laboratory control sample (LCS) must be analyzed once per SDG and concurrently with the
                samples in the SDG.

        2.      The LCS contains the following volatile compounds, in addition to the required SMC
                (Bromofluorobenzene):

                         Vinyl chloride                    Benzene
                         1,2-Dichloroethane              cis-l,3-Dichloropropene
                        Carbon tetrachloride             Bromoform
                         1,2-Dichloropropane             Tetrachloroethene
                        Trichloroethene                  1,2-Dibromoethane
                         1,1,2-Trichloroethane            1,4-Dichlorobenzene

        3.      The percent recoveries for the LCS compounds must be within the QC limits. The LCS must meet
                this recovery criteria for the sample data to be accepted.

        4.      The criteria for system monitoring compound  recovery and internal standard performance also
                apply.

D.      Evaluation:

        1.      Verify that LCS samples were analyzed at the re quired frequency and that results are provided for
                each SDG.

        2.      Inspect results for the LCS Recovery on Form  III LCV-1 and verify that the results for recovery are
                within the QC limits.

        3.      Verify transcriptions from raw data and verify calculations.

        4.      Check that the LCS recovery was calculated correctly by using the correct equation.

E.      Action:

        If the LCS criteria are not met, then the laboratory performance and method accuracy are in question.
        Professional judgement should be used to determine if the data should be qualified or rejected. The
        following guidance is suggested for qualifying sample data for which the associated LCS does not meet the
        required criteria.


                                                   32

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                                                                                           VGA
1.       Action on the LCS recovery should be based on both the number of compounds that are outside of
        the recovery criteria and the magnitude of the exceedance of the criteria.

2.       If the LCS recovery criteria are not met, then the LCS results should be used to qualify sample data
        for the specific compounds that are included in the LCS solution. Professional judgement should
        be used to qualify data for compounds other than those compounds that are included in the LCS.
        Professional judgement to qualify non-LCS compounds should take into account the compound
        class,  compound recovery efficiency, analytical problems associated with each compound, and
        comparability in performance of the LCS compound to the non-LCS compound.

3.       If the LCS recovery is greater than the upper control limit, then positive sample results for the
        affected compound(s) should be qualified with a "J".

4.       If the mass spectral criteria are met but the LCS recovery is less than the lower control limit, then
        the associated detected target compounds should be qualified "J" and the associated non-detected
        target compounds should be qualified "R ".

5.       If more than half of the compounds in the LCS are not within the required recovery criteria, then all
        of the  associated detected target compounds should be qualified "J" and all associated non-
        detected target compounds should be qualified "R. "

6.       Action on non-compliant system monitoring compound recovery and internal standard
        performance should follow the procedures provided in VI.E andX.E, respectively. Professional
        judgement should be used to evaluate the impact that non-compliance for system monitoring
        compound recovery and internal standard performance in the LCS has on the associated sample
        data.

7.       It should be noted for TPO action if a laboratory fails to analyze an LCS with each SDG, or if a
        laboratory consistently fails to generate acceptable  LCS recoveries.]
                                           33

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VGA
                       IX. Regional Quality Assurance and Quality Control


A.     Review Items:  Form IVOA [Form ILCV], chromatograms, and quantitation reports.

B.     Objective:

       Regional Quality Assurance and Quality Control (QA/QC) refer to any QA and/or QC samples
       initiated by the Region, including field duplicates, Performance Evaluation (PE) samples, blind
       spikes, and blind blanks. (It is highly recommended that Regions adopt the use of these QA/QC
       samples.)

C.     Criteria:

       Criteria are determined by each Region.

       1.      Performance evaluation sample frequency may vary.

               [For data generated through the Low Concentration Water Method: A performance evaluation
               (PE) sample can be included as frequently as once per SDG.J

       2.      The analytes present in the PE sample must be correctly identified and quantified.

D.     Evaluation:

       Evaluation procedures must follow the Region's SOP for data review. Each Region will handle the
       evaluation of PE samples on an individual basis. Results for PE samples should be compared to the
       acceptance criteria for the specific PE samples, if available.

E.     Action:

       Any action must be in accordance with Regional specifications and the criteria for acceptable PE
       sample results. Unacceptable results for PE samples should be noted for TPO action.
                                               34

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                                                                                              VGA
                                      X. Internal Standards


A.      Review Items:  Form VIIIVOA [Form VIIILCV], quantitation reports, and chromatograms.

B.      Objective:

        Internal Standards (IS) performance criteria ensures that GC/MS sensitivity and response are stable
        during each analysis.

C.      Criteria:

        1.      Internal standard area counts must not vary by more than a factor of two (-50% to +100%)
               from the associated 12hr calibration standard.

               [For data generated through the Low Concentration Water Method: Internal standard area counts
               must not vary by more than a factor of± 40.0% from  the associated calibration standard.]

        2.      The retention time of the internal standard must not vary more than +30 seconds from the
               retention time of the associated 12hr calibration standard.

               [For data generated through the Low Concentration Water Method: The retention time of the
               internal standard must not vary more than +_ 20.0 seconds from the retention time of the associated
               12hr calibration standard.]

D.      Evaluation:

        1.      Check raw data (e.g., chromatograms and quantitation lists) to verify the internal standard
               retention times and areas reported on the Internal Standard Area Summary (Form VIII VOA
               [Form  VIIILCV]).

        2.      Verify that all retention times and IS areas are within criteria.

        3.      If there are two analyses for a particular fraction, the reviewer must determine which are the
               best data to report. Considerations should include:

               a.      Magnitude and direction of the IS area shift.

               b.      Magnitude and direction of the IS retention time shift.

               c.      Technical holding times.

               d.      Comparison of the values of the target compounds reported in each fraction.

               e.      Other QC.
                                                 35

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VGA

E.      Action:
        1.       If an IS area count for a sample or blank is outside -50% or +100% of the area for associated
                standard:

                a.      Positive results for compounds quantitated using that IS should be qualified with
                       "J".

                b.      Non-detected compounds quantitated using an IS area count greater than 100%
                       should not be qualified.

                c.      Non-detected compounds quantitated using an IS area count less than 50% are
                       reported as the associated sample quantitation limit and qualified with "UJ".

                d.      If extremely low area counts are reported, or if performance exhibits a major abrupt
                       drop-off, then a  severe loss of sensitivity is indicated.  Non-detected target
                       compounds should then be qualified as unusable (R).
                [If an IS area count for a sample or blank is outside ± 40.0% of the area for associated standard:

                a.      Positive results for compounds quantitated using that IS should be qualified with "J".

                b.      Non-detected compounds quantitated using an IS area count greater than 40% should not
                       be qualified.

                c.      Non-detected compounds quantitated using an IS area count less than 40% are reported
                       as the associated sample quantitation limit and qualified with "UJ".

                d.      If extremely low area counts are reported, or if performance exhibits a major abrupt drop-
                       off, then a severe loss of sensitivity is indicated. Non-detected target compounds should
                       then be qualified as unusable (R).]

        2.       If an IS retention time varies by more than 30 seconds:

                [If an IS retention time varies by more than 20.0 seconds:]

                The chromatographic profile for that sample must be examined to determine if any false
                positives or negatives exist. For shifts of a large magnitude, the reviewer may consider
                partial or total rejection of the data for that sample fraction. Positive results should not need
                to be qualified as "R" if the mass spectral  criteria are met.

        3.       If the internal standards performance criteria are grossly exceeded, then this should be noted
                for TPO action. Potential effects on the data resulting from unacceptable internal standard
                performance should be noted in the data review narrative.
                                                 36

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                                                                                             VGA

                               XL  Target Compound Identification


A.      Review Items: Form IVOA [Form ILCV], quantitation reports, mass spectra, and chromatograms.

B.      Objective:

        The objective of the criteria for GC/MS qualitative analysis is to minimize the number of erroneous
        identifications of compounds. An erroneous identification can either be a false positive (reporting a
        compound present when it is not) or a false negative (not reporting a compound that is present).

        The identification criteria can be applied more easily in detecting false positives than false negatives.
        More information is available for false positives due to the requirement for submittal of data
        supporting positive identifications.  Negatives, or non-detected compounds, on the other hand
        represent an absence of data and are, therefore, more difficult to assess. One example of detecting
        false negatives is the not reporting of a Target Compound that is reported as a TIC.

C.      Criteria:

        1.      The relative retention times (RRTs) must be within +0.06 RRT units of the standard RRT.

        2.      Mass spectra of the sample compound and a current laboratory-generated standard (i.e., the
               mass spectrum from the associated calibration standard) must match according to the
               following criteria:

               a.      All ions present in the standard mass spectrum at a relative intensity greater than
                      10% must be present in the sample spectrum.

                      [For data generated through the Low Concentration Water Method: All ions present in the
                      standard mass spectrum at a relative intensity greater than 25% must be present in the
                      sample spectrum.]

               b.      The relative intensities of these ions must agree within + 20% between the standard
                      and sample spectra. (Example:  For an ion with an abundance of 50% in the
                      standard spectrum, the corresponding sample ion abundance must be between 30%
                      and 70%.)

               c.      Ions present at greater than 10% in the sample mass spectrum but not present in the
                      standard spectrum must be considered and accounted for.

                      [For data generated through the Low Concentration Water Method: Ions present at
                      greater than 25% in the sample mass spectrum but not present in the standard spectrum
                      must be considered and accounted for.]


D.      Evaluation:
                                                37

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VGA
        1.      Check that the RRT of reported compounds is within + 0.06 RRT units of the standard
               RRT.

        2.      Check the sample compound spectra against the laboratory standard spectra to see that it
               meets the specified criteria.

        3.      The reviewer should be aware of situations (e.g., high concentration samples preceding low
               concentration samples) when sample carryover is a possibility and should use judgment to
               determine if instrument cross-contamination has affected any positive compound
               identification.  The Method specifies that an instrument blank must be run after samples in
               which a target analyte ion(s) saturates the detector.

               [The reviewer should be aware of situations when sample carryover is a possibility and should use
               judgment to determine if instrument cross-contamination has affected any positive compound
               identification. The Method specifies that an instrument blank must be run after samples which
               contain target compounds at levels exceeding the initial calibration range (25 ug/Lfor non-ketones,
               125 ug/Lfor ketones) or non-target compounds at concentrations greater than 100 ug/L or
               saturated ions from a compound (excluding the compound peaks in the solvent front).]

        4.      Check the chromatogram to verify that peaks are accounted for,  i.e., major peaks are either
               identified as target compounds, TICs, system monitoring compounds, or internal standards.
E.      Action:
        1.      The application of qualitative criteria for GC/MS analysis of target compounds requires
               professional judgement. It is up to the reviewer's discretion to obtain additional information
               from the laboratory. If it is determined that incorrect identifications were made, all such data
               should be qualified as not detected (U) or unusable (R).

        2.      Professional judgement must be used to qualify the data if it is determined that cross-
               contamination has occurred.

        3.      Any changes made to  the reported compounds or concerns regarding target compound
               identifications should be clearly indicated in the data review narrative.  The necessity for
               numerous or  significant changes should be noted for TPO action.
                                                 38

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                                                                                            VGA
                       XII.  Compound Ouantitation and Reported CRQLs
A.     Review Items: Form IVOA [Form ILCV], sample preparation sheets, SDG narrative, quantitation
       reports, and chromatograms.

B.     Objective:

       The objective is to ensure that the reported quantitation results and Contract Required Quantitation
       Limits (CRQLs) are accurate.

C.     Criteria:

       1.      Compound quantitation, as well as the adjustment of the CRQLs, must be calculated
               according to the correct equation.

       2.      Compound RRFs must be calculated based on the internal standard (IS) associated with that
               compound, as listed in  the method.  Quantitation must be based on the quantitation ion (m/z)
               specified in the Method for both the IS and target analytes.  The compound quantitation
               must be based on the RRF from the appropriate daily standard.

D.     Evaluation:

       1.      For all fractions, raw data should be examined to verify the correct calculation of all sample
               results reported by the laboratory.  Quantitation lists and chromatograms should be
               compared to the reported positive sample results and quantitation limits. Check the reported
               values.

       2.      Verify that the correct internal standard, quantitation ion, and RRF were used to quantitate
               the compound. Verify  that the same internal standard, quantitation ion, and RRF are used
               consistently throughout, in both the calibration as well as the quantitation process.

       3.      Verify that the CRQLs have been adjusted to reflect all sample dilutions and dry weight
               factors that are not accounted for by the method.
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E.      Action:
        1.      If any discrepancies are found, the laboratory may be contacted by the designated
               representative to obtain additional information that could resolve any differences. If a
               discrepancy remains unresolved, the reviewer must use professional judgement to decide
               which value is the best value.  Under these circumstances, the reviewer may determine
               qualification of data is warranted.  A description of the reasons for data qualification and the
               qualification that is applied to the data should be documented in the data review narrative.

        2.      Numerous or significant failures to accurately quantify the target compound or to properly
               evaluate and adjust CRQLs should be noted for TPO action.
                                                40

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                                                                                               VGA
                              XIII.  Tentatively Identified Compounds
A.      Review Items:  Form I VOA-TIC [Form ILCV-TIC], chromatograms, and library search printouts
        and spectra for the TIC candidates.

B.      Objective:

        Chromatographic peaks in volatile fraction analyses that are not target analytes, system monitoring
        compounds, or internal standards are potential tentatively identified compounds (TICs). TICs must
        be qualitatively identified via a forward search of the NIST/EPA/NIH and/or Wiley Mass Spectral
        Library, and the identifications assessed by the data reviewer.

C.      Criteria:

        For each sample, the laboratory must conduct a mass spectral search of the NIST library and report
        the possible identity for the appropriate number of the largest volatile fraction peaks which are not
        system monitoring compound, internal standard,  or target compounds, but which have area or height
        greater than 10 percent of the area or height of the nearest internal standard.  TIC results are reported
        for each sample on the Organic Analyses Data Sheet (Form I VOA-TIC).

        [For data generated through the Low Concentration Water Method: For each sample, the laboratory must
        conduct a mass spectral search of the NIST/EPA/NIH and/or Wiley mass spectral library and report the
        possible identity for the appropriate number of the largest volatile fraction peaks which are not system
        monitoring compounds, internal standards, or TCL compounds, but which have area greater than or equal
        to 40 percent of the area of the nearest internal standard. Estimated concentrations for TICs are calculated
        similarly to the TCL compounds, using total ion areas for the TIC and the internal standard, and assuming a
        relative response factor of 1.0.  TIC results are reported for each sample on the Organic Analyses Data
        Sheet (Form ILCV-TIC).]

        NOTE:        Since the Method revision of October 1986, the CLP does not allow the laboratory
                       to report as tentatively identified compounds any target compound which is properly
                       reported  in another fraction.  For example, late eluting volatile target compounds
                       should not be reported as semivolatile TICs.

D.      Evaluation:

        1.       Guidelines for tentative identification are as follows:

                a.      Major ions (greater than 10% relative intensity) in the reference spectrum should be
                       present in the sample spectrum.

                       [Major ions (greater than 25% relative intensity) in the reference spectrum should be
                       present in the sample spectrum.]
                                                 41

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VGA
               b.      The relative intensities of the major ions should agree within ±20% between the
                       sample and the reference spectra.

               c.      Molecular ions present in the reference spectrum should be present in the sample
                       spectrum.

               d.      Ions present in the sample spectrum but not in the reference spectrum should be
                       reviewed for possible background contamination, interference, or coelution of
                       additional  TIC or target compounds.

               e.      When the above criteria are not met, but in the technical judgement of the data
                       reviewer or mass spectral interpretation specialist the identification is correct, the
                       data reviewer may report the identification.

               f.       If in the data reviewer's judgement the identification is uncertain or there are
                       extenuating factors affecting compound identifications, the TIC result may be
                       reported as "unknown".

        2.      Check the raw data to verify that the laboratory has generated a library search for all
               required peaks in the chromatograms for samples and blanks.

        3.      Blank chromatograms should be examined to verify that TIC peaks present in samples are
               not found in blanks. When a low-level non-target compound that is a common artifact or
               laboratory contaminant is detected in a sample, a thorough check of blank chromatograms
               may require looking for peaks which are less than 10 percent of the internal standard height,
               but present in the blank chromatogram at similar relative retention time.

               [Blank chromatograms should be examined to verify that TIC peaks present in samples are not
               found in blanks.  When a low-level non-TCL compound that is a common artifact or laboratory
               contaminant is detected in a sample, a thorough check of blank chromatograms may require
               looking for peaks which are less than 40 percent of the internal standard area but present in the
               blank chromatogram at similar relative retention time.]

        4.      All mass spectra for every sample and blank must be examined.

        5.      Since TIC library searches often yield several candidate compounds having a close matching
               score, all reasonable choices must be considered.

        6.      The reviewer should be aware of common laboratory artifacts/contaminants and their
               sources (e.g., aldol condensation products, solvent preservatives, and reagent contaminants).
               These may be present in blanks and not reported as sample TICs.
                                                42

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                                                                                               VGA

               Examples:

               a.      Common laboratory contaminants:  CO2 (m/z 44), siloxanes (m/z 73), diethyl ether,
                       hexane, certain freons (l,l,2-trichloro-l,2,2-trifluoroethane or fluoro-
                       trichloromethane), and phthalates at levels less than 100 ug/L or 4000 ug/Kg.

               b.      Solvent preservatives such as cyclohexene which is a methylene chloride preser-
                       vative. Related by-products include cyclohexanone, cyclohexenone, cyclohexanol,
                       cyclohexenol, chlorocyclohexene, and chlorocyclohexanol.

               c.      Aldol condensation reaction products of acetone include:  4-hydroxy-4-methyl-2-
                       pentanone, 4-methyl-2-penten-2-one, and 5,5-dimethyl-2(5H)-furanone.

        7.      Occasionally, a target compound may be identified in the proper analytical fraction by non-
               target library search procedures, even though it was not found on the quantitation list. If the
               total area quantitation method was used, the reviewer should request that the laboratory
               recalculate the result using the proper quantitation ion. In addition, the reviewer should
               evaluate other sample chromatograms and check library reference retention times on
               quantitation lists to determine whether the false negative result is an isolated occurrence or
               whether additional data may be affected.

        8.      Target compounds could be identified in more than one fraction. Verify that quantitation is
               made from the proper fraction.

        9.      Library searches should not be performed on internal standards or system monitoring
               compounds.

        10.     TIC concentration should be estimated assuming a RRF of 1.0.

E.      Action:

        1.      All TIC results should be qualified "NJ", tentatively identified, with approximated
               concentrations.

        2.      General actions related to the review of TIC results  are as follows:

               a.      If it is determined that a tentative identification of a non-target compound is  not
                       acceptable, the tentative identification should be changed to "unknown" or an
                       appropriate identification.

               b.      If all contractually required peaks were not library searched and quantitated,  the
                       designated representative could request these data from the laboratory.
                                                 43

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       3.      TIC results which are not sufficiently above lOx the level in the blank should not be
               reported. (Dilutions and sample size must be taken into account when comparing the
               amounts present in blanks and samples.)

       4.      When a compound is not found in any blanks, but is a suspected artifact of common
               laboratory contaminant, the result may be qualified as unusable (R).

       5.      In deciding whether a library search result for a TIC represents a reasonable identification,
               professional judgment must be exercised.  If there is more than one possible match, the
               result may be reported as "either compound X or compound Y." If there is a lack of isomer
               specificity, the TIC  result may be changed to a non-specific isomer result (e.g., 1,3,5-
               trimethyl benzene to trimethyl benzene isomer) or to a compound class (e.g., 2-methyl, 3-
               ethyl benzene to substituted aromatic compound).

       6.      The reviewer may elect to report all similar compounds as a total,  (e.g., All alkanes may be
               summarized  and reported as total hydrocarbons.)

       7.      Other case factors may influence TIC judgements.  If a sample TIC match is poor but other
               samples have a TIC with a good library match, similar relative retention time, and the same
               ions, identification information may be inferred from the other sample TIC results.

       8.      Physical constants, such as boiling point, may be factored into professional judgement of
               TIC results.

       9.      Any changes made to the reported data or any concerns regarding TIC identifications should
               be indicated in the data review narrative.

       10.     Failure to properly evaluate and report TICs should be noted for TPO action.
                                               44

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                                                                                               VGA
                                     XIV.  System Performance
A.      Review Items:  Form VIII VGA [Form VIIILCV], Form III VOA-1 and VOA-2 [Form IIILCV-1],
        and chromatograms.

B.      Objective:

        During the period following Instrument Performance QC checks (e.g. blanks, tuning, calibration),
        changes may occur in the system that degrade the quality of the data. While this degradation would
        not be directly shown by QC checks until the next required series of analytical QC runs, a thorough
        review of the ongoing data acquisition can yield indicators of instrument performance.

C.      Criteria:

        There are no specific criteria for system performance. Professional judgement should be applied to
        assess the system performance.

D.      Evaluation:

        1.      Abrupt, discrete shifts in the reconstructed ion chromatogram (RIC) baseline may indicate a
               change in the instrument's sensitivity or the zero setting.  A baseline "shift" could indicate a
               decrease in sensitivity in the instrument or an increase in the instrument zero, possibly
               causing target compounds, at or near the detection limit, to miss detection.  A baseline "rise"
               could indicate problems such as a change in the instrument zero, a leak, or degradation of the
               column.

        2.      Poor chromatographic performance affects both qualitative and quantitative results.
               Indications of substandard performance include:

               a.      High RIC background levels or shifts in absolute retention times of internal
                       standards.

               b.      Excessive baseline rise at elevated temperature.

               c.      Extraneous peaks.

               d.      Loss of resolution.

               e.      Peak tailing or peak splitting that may result in inaccurate quantitation.

        [3.     A drift in instrument sensitivity may occur during the 12-hour time period. This could be discerned
               by examination of the IS area on Form VIII LCV for trends such as a continuous or near-
               continuous increase or decrease  in the IS area over time.
                                                 45

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        4.      The results of the LCS analysis (Form III LCSV) may also be used to assess instrument
               performance.]
E.     Action:
        Professional judgement must be used to qualify the data if it is determined that system performance
        has degraded during sample analyses. Any degradation of system performance which significantly
        affected the data should be documented for TPO action.
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                                                                                               VGA
                                  XV.  Overall Assessment of Data
A.      Review Items:  Entire data package, data review results, and (if available) Quality Assurance Project
        Plan (QAPjP), and Sampling and Analysis Plan (SAP).

B.      Objective:

        The overall assessment of a data package is a brief narrative in which the data reviewer expresses
        concerns and comments on the quality and, if possible, the useability of the data.

C.      Criteria:

        Assess the overall quality of the  data.

        Review all available materials to assess the overall quality of the data, keeping in mind the additive
        nature of analytical problems.

D.      Evaluation:

        1.      Evaluate any technical problems which have not been previously addressed.

        2.      If appropriate information is available, the reviewer may assess the useability of the data to
               assist the data user in avoiding inappropriate use of the data. Review all available
               information, including the QAPjP (specifically the Data Quality Objectives), SAP, and
               communication with data user that concerns the intended use and desired quality of these
               data.

E.      Action:

        1.      Use professional judgement to determine if there is any need to qualify data which were not
               qualified based on the QC criteria previously discussed.

        2.      Write a brief narrative to give the user an indication of the analytical limitations of the data.
               Any inconsistency of the data with the SDG narrative should be noted for TPO action. If
               sufficient information on the intended use and required quality of the data are available, the
               reviewer should include his/her assessment of the useability of the data within the given
               context.
                                                 47

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                               SEMIVOLATILE DATA REVIEW


*** Data review guidelines that are unique to data generated through the Low Concentration Water Method are
contained within brackets ([]) and written in italics. ***


The semivolatile data requirements to be checked are listed below:

        I.       Holding Times (Method Holding Times)

        II.      GC/MS Instrument Performance Check

        III.     Initial Calibration

        IV.     Continuing Calibration

        V.      Blanks

        VI.     Surrogate Spikes

        VII.    Matrix Spikes/Matrix Spike Duplicates

        VIII.    Laboratory Control Samples

        IX.     Regional Quality Assurance and Quality Control

        X.      Internal Standards

        XI.     Target Compound Identification

        XII.    Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs)

        XIII.    Tentatively Identified Compounds

        XIV.    System Performance

        XV.    Overall Assessment of Data
                                               48

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                                                                                               sv
                                        I. Holding Times


A.      Review Items: Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2], EPA Sample Traffic Report
        and/or chain-of-custody, raw data, and sample extraction sheets.

B.      Objective:

        The objective is to ascertain the validity of results based on the holding time of the sample from time
        of collection to time of sample extraction and analysis.

C.      Criteria:

        Technical requirements for sample holding times have only been established for water matrices.


        The technical holding time criteria for water samples, are as follows:
               For semivolatile compounds in cooled (@ 4°C) water samples, the maximum
               holding time is 7 days from sample collection to extraction and 40 days from sample
               extraction to analysis.
        It is recommended that semivolatile compounds in soil samples be extracted within 14 days of
        sample collection.
        The method holding times, which differ from the technical holding times, state that water samples are
        to be extracted within 5 days from the validated time of sample receipt (VTSR) at the laboratory, and
        soil samples are to be extracted within 10 days from the VTSR.  Also, contractually both water and
        soil sample extracts must be analyzed within 40 days of sample extraction.
       [For data generated through the Low Concentration Method: The method holding times requirements are
       that the extraction of all samples must be started within 5 days of the VTSR, and the extracts must be
       analyzed within 40 days of VTSR.
                                                49

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D.     Evaluation:
        Technical holding times for sample extraction are established by comparing the sampling date on the
        EPA Sample Traffic Report with the dates of extraction on Form I SV-1 and SV-2 [Form ILCSV-1
        andLCSV-2] and the sample extraction sheets. To determine if the samples were analyzed within the
        holding time after extraction, compare the dates of extraction on the sample extraction sheets with
        the dates of analysis on Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2].

        Verify that the traffic report indicates that the samples were received intact and iced. If the samples
        were not iced or there were any problems with the samples upon receipt, then discrepancies in the
        sample condition could affect the data.
E.     Action:
        1.      If technical holding times are exceeded, flag all positive results as estimated "J", and sample
               quantitation limits as estimated "UJ" and document that holding times were exceeded.

        2.      If technical holding times are grossly exceeded, either on the first analysis or upon re-
               analysis, the reviewer must use professional judgement to determine the reliability of the
               data and the effect of additional storage on the sample results.  The reviewer may determine
               that positive results or the associated quantitation limits are approximates and should be
               qualified with "J" or "UJ", respectively. The reviewer may determine that non-detect data
               are unusable (R).

        3.      Due to limited information concerning holding times for soil samples, it is left to the
               discretion of the data reviewer to apply water holding time criteria to soil samples.
               Professional judgement is required to evaluate holding times for soil samples.

        4.      Whenever possible, the reviewer should comment on the effect of the holding time
               exceedance on the resulting data in the data review narrative.

        5.      When method and/or technical holding times are exceeded, this should be noted as an action
               item for the TPO.

        6.      The reviewer should also be  aware of the scenario in which the laboratory has exceeded the
               technical holding times, but met method holding times.  In this case, the data reviewer should
               notify the Regional TPO (where samples were collected) and/or RSCC that shipment delays
               have occurred so that the field problem can be corrected. The reviewer may pass this
               information on to the laboratory's TPO, but should explain that the laboratory met the
               requirements in the method.
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                           II. GC/MS Instrument Performance Check


A.     Review Items: Form V SV [Form VLCSV], and DFTPP mass spectra and mass listing.

B.     Objective:

       Gas chromatograph/mass spectrometer (GC/MS) instrument performance checks (formerly referred
       to as tuning) are performed to ensure mass resolution, identification and, to some degree, sensitivity.
       These criteria are not sample specific. Conformance is determined using standard materials,
       therefore, these criteria should be met in all circumstances.

C.     Criteria:

       The analysis of the instrument performance check solution must be performed at the beginning of
       each 12-hour period during which samples or standards are analyzed. The instrument performance
       check, decafluorotriphenylphosphine (DFTPP) for semi-volatile analysis, must meet the ion
       abundance criteria given below.

                             Decafluorotriphenylphosphine (DFTPP)

                             m/z           ION ABUNDANCE CRITERIA

                             51            30.0 - 80.0% of m/z 198
                             68            Less than 2.0% of m/z 69
                             69            Present
                             70            Less than 2.0% of m/z 69
                             127           25.0 - 75.0% of m/z 198
                             197           Less than 1.0% of m/z 198
                             198           Base peak, 100% relative abundance
                             199           5.0 - 9.0% of m/z 198
                             275           10.0 - 30.0% of m/z 198
                             365           Greater than 0.75% of m/z 198
                             441           Present, but less than m/z 443
                             442           40.0-110.0% of m/z 198
                             443           15.0-24.0% of m/z 442

       NOTE:       All ion abundances must be normalized to m/z 198, the nominal base peak, even
                     though the ion abundances of m/z 442 may be up to 110 percent that of m/z 198.
                                              51

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D.     Evaluation:
        1.      Compare the data presented on each GC/MS Instrument Performance Check (Form V SV
               [Form VLCSV] with each mass listing submitted and ensure the following:

               a.      Form V SV [Form VLCSV] is present and completed for each 12-hour period during
                      which samples were analyzed.

               b.      The laboratory has not made  any transcription errors between the data and the form.
                      If there are major differences between the mass listing and the Form Vs, a more in-
                      depth review of the data is required. This may include obtaining and reviewing
                      additional information from the laboratory.

               c.      The appropriate number of significant figures has been reported (number of
                      significant figures given for each ion in the ion abundance criteria column) and that
                      rounding is correct.

               d.      The laboratory has not made  any calculation errors.

        2.      Verify from the raw data (mass spectral listing) that the mass assignment is correct and that
               the mass is normalized to m/z 198.

        3.      Verify that the ion abundance criteria was met.  The criteria for m/z 68, 70, 441, and 443 are
               calculated by normalizing to the specified m/z.

        4.      If possible, verify that spectra were generated using appropriate background subtraction
               techniques.  Since the DFTPP spectrum is obtained from chromatographic peaks that should
               be free from coelution problems, background subtraction should be done in accordance with
               the following procedure.  Three scans (the peak apex scan and the scans immediately
               preceding and following the apex) are acquired and averaged. Background subtraction is
               required,  and must be accomplished using a single scan acquired no more than 20 scans
               prior to the elution of DFTPP.  Do not subtract as part of the background the DFTPP peak.

        NOTE:        All instrument conditions must be identical to those used during the sample
                      analysis. Background subtraction actions resulting in spectral distortions for the
                      sole purpose of meeting the contract specifications are contrary to the quality
                      assurance objectives and are therefore unacceptable.
                                               52

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                                                                                                sv
E.      Action:
        1.      If the laboratory has made minor transcription errors which do not significantly affect the
               data, the data reviewer should make the necessary corrections on a copy of the form.

        2.      If the laboratory has failed to provide the correct forms or has made significant transcription
               or calculation errors, the Region's designated representative should contact the laboratory
               and request corrected data. If the information is not available, then the reviewer must use
               professional judgement to assess the data. The laboratory's TPO should be notified.

        3.      If mass assignment is in error (such as m/z 199 is indicated as the base peak rather than m/z
               198), classify all associated data as unusable (R).

        4.      If ion abundance criteria are not met, professional judgement may be applied to determine to
               what extent the data may be utilized. Guidelines to aid in the application of professional
               judgement in evaluating ion abundance criteria are discussed as follows:

               a.      Some of the most critical factors in the DFTPP criteria are the non-instrument
                       specific requirements that are also not unduly affected by the location of the
                       spectrum on the chromatographic profile.  The m/z ratios for 198/199 and 442/443
                       are critical. These ratios are based on the natural abundances of carbon 12 and
                       carbon 13 and should always be met. Similarly, the relative abundances for m/z 68,
                       70, 197, and 441 indicate the condition of the instrument and the suitability of the
                       resolution adjustment and are very important. Note that all of the foregoing
                       abundances relate to adjacent ions; they are relatively insensitive to differences in
                       instrument design and position of the spectrum on the chromatographic profile.

               b.      For the ions at m/z 51, 127, and 275, the actual relative abundance is not as critical.
                       For instance, if m/z 275 has 40% relative abundance (criteria: 10.0-30.0%) and
                       other criteria are met, then the  deficiency is minor.

               c.      The relative abundance of m/z 365 is an indicator of suitable instrument zero
                       adjustment. If relative abundance for m/z 365 is zero, minimum detection limits
                       may  be affected. On the other hand, if m/z 365 is present, but less than the 0.75%
                       minimum abundance criteria, the  deficiency is not as serious.

        5.      Decisions to use analytical data associated with DFTPP instrument performance checks not
               meeting method requirements should be clearly noted in the data review narrative.
        6.      If the reviewer has reason to believe that instrument performance check criteria were
               achieved using techniques other than those specified in the method and Section II.D.4 above,
                                                53

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               additional information on the DFTPP instrument performance checks should be obtained. If
               the techniques employed are found to be at variance with contract requirements, the
               procedures of the laboratory may merit evaluation. Concerns or questions regarding
               laboratory performance should be noted for TPO action. For example, if the reviewer has
               reason to believe that an inappropriate technique was used to obtain background subtraction
               (such as background subtracting from the solvent front or from another region of the
               chromatogram rather than the DFTPP peak), then this should be noted for TPO action.
                                               54

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                                       III.  Initial Calibration
A.      Review Items:  Form VI SV-1 and SV-2 [Form VILCSV-1 andLCSV-2], quantitation reports, and
        chromatograms.

B.      Objective:

        Compliance requirements for satisfactory instrument calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data for compounds on the
        semivolatile Target Compound List (TCL). Initial calibration demonstrates that the instrument is
        capable of acceptable performance in the beginning of the analytical run and of producing a linear
        calibration curve.

C.      Criteria:

        1.      Initial calibration standards containing both semivolatile target compounds and surrogates
               are analyzed at concentrations of 20, 50, 80, 120, and 160 ng/2uL at the beginning of each
               analytical sequence or as necessary if the continuing calibration acceptance criteria are not
               met. The initial calibration (and any associated samples and blanks) must be analyzed
               within 12 hours of the associated instrument performance check.

               [For data generated through the Low Concentration Method: Initial calibration standards
               containing both semivolatile TCL compounds and surrogates are analyzed at concentrations of 5,
               10, 20, 50, and 80 ng/2uL at the beginning of each analytical sequence or as necessary if the
               continuing calibration acceptance criteria are not met.  The initial calibration (and any associated
               samples and blanks) must be analyzed within 12 hours of the associated instrument performance
               check. The following nine compounds require initial calibration at 20, 50, 80, 100, and 120
               ng/2uL:  2,4-dinitrophenol,  2,4,5-trichlorophenol, 2-nitroaniline, 3, nitroaniline, 4-nitroaniline, 4-
               nitrophenol, 4,6-dinitro-2-methylphenol, pentachlorophenol, and 2,4,6-tribromophenol
               (surrogate).]

        2.      Minimum Relative Response Factor (RRF) criteria must be greater than or equal to 0.05.
               (Initial RRF criteria are listed in the appropriate method.)

        3.      The Percent Relative Standard Deviations (%RSD) for the RRFs in the initial calibration
               must be less than or equal to 30%.

D.      Evaluation:

        1.      Verify that the correct concentration of standards were used for the initial calibration (i.e.,
               20, 50, 80, 120, and 160 ng/2uL).  For the eight compounds with higher CRQLs, only a
               four-point initial calibration is required (i.e., 50, 80, 120, and 160 ng/2uL).
                                                 55

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               [Verify that the correct concentration of standards were used for the initial calibration (i.e., 5, 10,
               20, 50, and 80 ng).  For the nine compounds listed in SV Section III.C. 1. with higher CRQLs, verify
               that a five point initial calibration at 20, 50, 80, 100, and 120 ng was performed.]

        2.      If any sample results were calculated using an initial calibration, verify that the correct
               standard (i.e., the 50 ng standard) was used for calculating sample results and that the
               samples were analyzed within 12 hours of the associated instrument performance check.

               [If any sample results were calculated using an initial calibration, verify that the correct standard
               (i.e., the 20 ng standard or 80 ngfor the compounds listed in III.C. 1.) was used for calculating
               sample results and that the samples were analyzed within 12 hours of the associated DFTPP
               tuning/instrument performance check.]

        3.      Evaluate the RRFs for all semivolatile target compounds and surrogates:
                a.      Check and recalculate the RRF and RRF for at least one semivolatile target
                       compound associated with each internal standard.  Verify that the recalculated
                       value(s) agrees with the laboratory reported value(s).

                b.      Verify that all semivolatile target compounds and surrogates have RRFs that are
                       greater than or equal to 0.05.

        NOTE:        The criteria used for data review purposes are different from those used for
                       contractual purposes.  The laboratory must meet a minimum RRF criteria of 0.01,
                       however, for data review purposes, the "greater than or equal to 0.05"
                       criterion is applied to all semivolatile compounds.

                   Table 4. Semivolatile Target Compounds Exhibiting Poor Response

                       2,2'-oxybis( 1 -Chloropropane)           Diethylphthalate
                       4-Chloroaniline                        4-Nitroaniline
                       Hexachlorobutadiene                   4,6-Dinitro-2-methylphenol
                       Hexachlorocyclopentadiene              N-Nitrosodiphenylamine
                       2-Nitroaniline                          Di-n-butylphthalate
                       Dimethylphthalate                      Butylbenzylphthalate
                       3-Nitroaniline                          3-3'-Dichlorobenzidine
                       2,4-Dinitrophenol                      bis(2-Ethylhexyl)phthalate
                       4-Nitrophenol                          Di-n-octylphthalate
                       Carbazolet                            2,4,6-Tribromophenol (surr)£
                       Nitrobenzene-d^ (surr)$
                       | Multi-media, Multi-concentration only
                       / Low Concentration Water only

               Evaluate the %RSD for all semivolatile target compounds and surrogates:




                                                 56

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               a.       Check and recalculate the %RSD for one or more semivolatile target compound(s);
                       verify that the recalculated value(s) agrees with the laboratory reported value(s).

               b.       Verify that all semivolatile target compounds have a %RSD of less than 30%. The
                       method criteria for an acceptable initial calibration specifies that up to any 4
                       semivolatile target compounds may fail to meet minimum RRF or maximum %RSD
                       as long as they have RRFs that are greater than or equal to 0.010, and %RSD of less
                       than or equal to 40.0%. For data review purposes, however, all compounds must be
                       considered for qualification when the %RSD exceeds the <30.0% criterion.

               c.       If the %RSD is greater than 30.0%, then the reviewer should use professional
                       judgement to determine the need to check the points on the curve for the cause of the
                       non-linearity.  This is checked by eliminating either the high point or the low point
                       and recalculating the %RSD.
        5.      If errors are detected in the calculations of either the RRF or the %RSD, perform a more
               comprehensive recalculation.
E.     Action:
        1.      All semivolatile target compounds, including the 19 "poor performers" will be qualified
               using the following criteria:

               a.       If the %RSD is greater than 30.0% and the RRF is greater than 0.05, qualify
                       positive results with "J", and non-detected semivolatile target compounds using
                       professional judgement.

               b.       If the RRF is less than 0.05, qualify positive results that have acceptable mass
                       spectral identification with "J" using professional judgement, and non-detects as
                       unusable (R).

        2.      At the reviewer's discretion, a more in-depth review to minimize the qualification of data can
               be accomplished by considering the following:

               a.       If any of the required semivolatile compounds have a %RSD greater than 30.0%,
                       and if eliminating either the high or the low point of the curve does not restore the
                       %RSD to less than or equal to 30.0%:

                       i.      Qualify positive results for that compound(s) with "J".

                       ii.      Qualify non-detected semivolatile target compounds based on professional
                              judgement.
               b.       If the high point of the curve is outside of the linearity criteria (e.g. due to
                       saturation):
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                       i.       No qualifiers are required for positive results in the linear portion of the
                               curve.

                       ii.      Qualify positive results outside of the linear portion of the curve with "J".

                       iii.     No qualifiers are needed for non-detected target compounds.

                c.      If the low end of the curve is outside of the linearity criteria:

                       i.       No qualifiers are required for positive results in the linear portion of the
                               curve.

                       ii.      Qualify low level positive results in the area of non-linearity with "J".

                       iii.     Qualify non-detected semivolatile target compounds using professional
                               judgement.

        3.       If the laboratory has failed to provide adequate calibration information, the designated
                representative should contact the laboratory and request the necessary information. If the
                information is not available, the reviewer must use professional judgement to assess the
                data.

        4.       Whenever possible, the potential effects on the data due to calibration criteria exceedance
                should be noted in the data review narrative.

        5.       If calibration criteria are exceeded, this  should be noted for TPO action.
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                                    IV. Continuing Calibration
A.      Review Items: Form VII SV-1 and SV-2 [Form VIILCSV-1 andLCSV-2], quantitation reports, and
        chromatograms.

B.      Objective:

        Compliance requirements for satisfactory instrument calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data for semivolatile target
        compounds.  Continuing calibration establishes the 12-hour relative response factors on which the
        quantitations are based and checks satisfactory performance of the instrument on a day-to-day basis.

C.      Criteria:

        1.      Continuing calibration standards containing both target compounds and surrogates are
               analyzed at the beginning of each 12-hour analysis period following the analysis of the
               instrument performance check and prior to the analysis of blanks and samples.

        2.      The minimum Relative Response Factors (RRF) for semivolatile target compounds and
               surrogates must be greater than or equal to 0.05.
        3.      The percent difference (%D) between the initial calibration RRF and the continuing
               calibration RRF must be within + 25.0% for all target compounds.
D.      Evaluation:
        1.      Verify that the continuing calibration was run at the required frequency and that the
               continuing calibration was compared to the correct initial calibration.

        2.      Evaluate the continuing calibration RRF for all semivolatile target compounds and
               surrogates.

               a.       Check and recalculate the continuing calibration RRF for at least one semivolatile
                       target compound for each internal standard; verify that the recalculated value(s)
                       agrees with the laboratory reported value(s).

               b.       Verify that all semivolatile target compounds and surrogates have RRFs within
                       specifications.
        NOTE:         The criteria employed for the data review purposes are different from those used for
                       contractual purposes.  The laboratory must meet a minimum RRF criterion of 0.01,
                       however, for data review purposes, the "greater than or equal to 0.05"
                       criterion is applied to all semivolatile compounds.
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        3.      Evaluate the %D between initial calibration RRF and continuing calibration RRF for one or
               more semivolatile compounds.

               a.       Check and recalculate the %D for at least one semivolatile target compound for each
                       internal standard; verify that the recalculated value agrees with the laboratory
                       reported value(s).

               b.       Verify that the %D is within the + 25.0% criterion, for all semivolatile target
                       compounds and surrogates. Note those compounds which have a %D outside the +
                       25.0% criterion. The method criteria for an acceptable continuing calibration
                       specifies that up to any 4 semivolatile target compounds may fail to meet minimum
                       RRF or maximum %D as long as they have RRFs that are greater than or equal to
                       0.010, and %D of less than or equal to 40.0%. For data review purposes, however,
                       all compounds must be considered for qualification when the %D exceeds the +
                       25.0% criterion.

        4.      If errors are detected in the calculations of either the continuing calibration RRF or the %D,
               perform a more comprehensive recalculation.
E.      Action:
        1.      The reviewer should use professional judgement to determine if it is necessary to qualify the
               data for any semivolatile target compound.  If qualification of data is required, it should be
               performed using the following guidelines:

               a.       If the %D is outside the + 25.0% criterion and the continuing calibration RRF is
                       greater than or equal to 0.05, qualify positive results "J".

               b.       If the %D is outside the + 25.0% criterion and the continuing calibration RRF is
                       greater than or equal to 0.05, qualify non-detected semivolatile target compounds
                       "UJ".

               c.       If the continuing calibration RRF is less than 0.05, qualify positive results that have
                       acceptable mass spectral identification with "J" or use professional judgement.

               d.       If the continuing calibration RRF is less than 0.05, qualify non-detected semivolatile
                       target compounds as unusable (R).
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2.      If the laboratory has failed to provide adequate calibration information, the designated
        representative should contact the laboratory and request the necessary information.  If the
        information is not available, the reviewer must use professional judgement to assess the
        data.

3.      Whenever possible, the potential effects on the data due to calibration criteria exceedance
        should be noted in the data review narrative.

4.      If calibration criteria are grossly exceeded, this should be noted for TPO action.
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                                            V.  Blanks
A.      Review Items: Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2], Form IV SV [Form IVLCSV],
        chromatograms, and quantitation reports.

B.      Objective:

        The purpose of laboratory (or field) blank analyses is to determine the existence and magnitude of
        contamination problems resulting from laboratory (or field) activities. The criteria for evaluation of
        blanks apply to any blank associated with the samples (e.g., method blanks, instrument blanks, trip
        blanks, and equipment blanks). If problems with any blank exist, all associated data must be
        carefully evaluated to determine whether or not there is an inherent variability in the data, or if the
        problem is an isolated occurrence not affecting other data.

C.      Criteria:

        1.      No contaminants should be found in the blanks.

        2.      The method blank must be analyzed on each GC/MS system used to analyze that specific
               group or set of samples.

D.      Evaluation:

        1.      Review the results of all associated blank, Form I SV-1 and SV-2, and raw data
               (chromatograms and quantitation reports) to evaluate the presence of target and non-target
               compounds in the blanks.

        2.      Verify that a method blank analysis has been reported per matrix, per concentration level, for
               each extraction batch and for each GC/MS system used to analyze semivolatile samples.
               The reviewer can use the method blank summary (Form IV SV) to assist in identifying
               samples associated with each method blank.

E.      Action:

        If the appropriate blanks were not analyzed with the frequency described above, then the data
        reviewer should use professional judgement to determine if the associated sample data should be
        qualified.  The reviewer may need to obtain additional information from the  laboratory. The
        situation should be noted for TPO action.
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Action in the case of unsuitable blank results depends on the circumstances and origin of the blank.
Positive sample results should be reported unless the concentration of the compound in the sample is
less than or equal to 10 times (lOx) the amount in any blank for the common phthalate
contaminants, or 5 times the amount for other compounds. In instances where more than one blank
is associated with a given sample, qualification should be based upon a comparison with the
associated blank having the highest concentration of a contaminant. The results must not be
corrected by subtracting any blank value.

Specific actions are as follows:

1.       If a semivolatile compound is found in a blank but not found in the sample, no action is
        taken.  If the contaminants found are volatile target compounds (or interfering non-target
        compounds) at significant concentrations above the CRQL, then this should be noted for
        TPO action.

2.       Any semivolatile compound detected in the sample (other than the common phthalate
        contaminants), that was also detected in any associated blank, is qualified if the sample
        concentration is less than five times (5x) the blank concentration.  The quantitation limit
        may also be elevated. Typically, the sample CRQL is elevated to the concentration found in
        the sample.  The reviewer should use professional judgement to determine if further
        elevation of the CRQL is required.  For phthalate contaminants, the results are qualified "U"
        by elevating the sample quantitation limit to the sample concentration when the sample
        result is less than lOx the blank concentration.

        The reviewer should note that blanks may not involve the same weights, volumes, or dilution
        factors as the associated samples. These factors must be taken into consideration when
        applying the "5x" and "lOx" criteria, such that a comparison of the total amount of
        contamination is actually made.

        Additionally, there may be instances where little or no contamination was present in the
        associated blanks, but qualification of the sample was deemed necessary. Contamination
        introduced through dilution is one example. Although it is not always possible to determine,
        instances of this occurring can be detected when contaminants are found in the diluted
        sample result, but are absent in the undiluted sample result. Since both results are not
        routinely reported, it may be impossible to verify this source of contamination. However, if
        the reviewer determines that the contamination is from a source other than the sample,
        he/she should qualify the data. In this case, the "5x" or "lOx" rules may not apply; the
        sample value should be reported as a non-detect. An explanation of the rationale used  for
        this determination should be provided in the narrative accompanying the Regional Data
        Assessment Summary.

3.       If gross contamination exists (i.e., saturated peaks by GC/MS), all affected compounds in
        the associated samples should be qualified as unusable (R), due to interference. This should
        be noted for TPO action if the contamination is suspected of having an effect on the sample
        results.
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               If inordinate amounts of other target compounds are found at low levels in the blank(s), it
               may be indicative of a problem and should be noted for TPO action.

               The same consideration given to the target compounds should also be given to Tentatively
               Identified Compounds (TICs) which are found in both the sample and associated blank(s).
               (See SV Section XIII for TIC guidance.)
       The following are examples of applying the blank qualification guidelines. Certain circumstances
       may warrant deviations from these guidelines.
               Example 1:     Sample result is greater than the Contract Required Quantitation Limit
                             (CRQL), but is less than the 5x or lOx multiple of the blank result.

                                                                            Rule
                                                                         lOx    5x

                                    Blank Result                          12     12
                                    CRQL                                10     10
                                    Sample Result                         50     40
                                    Qualified Sample Result                SOU   40U
                             In the example for the " lOx" rule, sample results less than 120 (or 10 x 12)
                             would be qualified as non-detects. In the case of the "5x" rule, sample
                             results less than 60 (or 5 x 12) would be qualified as non-detects.
               Example 2:     Sample result is less than CRQL, and is also less than the 5x or lOx
                             multiple of the blank result.
                                                                            Rule
                                                                          lOx    5x

                                    Blank Result                          12     12
                                    CRQL                               10     10
                                    Sample Result                         8J     8J
                                    Qualified Sample Result                10U   10U
                             Note that data are not reported as 8U, as this would be reported as a
                             detection limit below the CRQL.
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Example 3:     Sample result is greater than the 5x or lOx multiple of the blank result.

                                                             Rule
                                                            lOx    5x

                      Blank Result                          15    15
                      CRQL                                10    10
                      Sample Result                         160    80
                      Qualified Sample Result                160    80
               For both the "lOx" and "5x" rules, sample results exceeded the adjusted
               blank results of 150 (or 10x15) and 75 (or 5x15), respectively, and
               therefore are not qualified.
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                                       VI. Surrogate Spikes


A.      Review Items:  Form II SV-1 and SV-2 [Form IILCSV], chromatograms, and quantitation reports.

B.      Objective:

        Laboratory performance on individual samples is established by means of spiking activities. All
        samples are spiked with surrogate compounds prior to sample preparation. The evaluation of the
        results of these surrogate spikes is not necessarily straightforward. The sample itself may produce
        effects due to such factors as interferences and high concentrations of analytes.  Since the effects of
        the sample matrix are frequently outside the control of the laboratory and may present relatively
        unique problems, the evaluation and review of data based on specific sample results is frequently
        subjective and demands analytical experience and professional judgment.  Accordingly, this section
        consists primarily of guidelines, in some cases with several optional approaches suggested.

C.      Criteria:

        1.      Surrogate spikes, 4 acid compounds (3 required and 1 advisory) and 4 base/neutral
               compounds (3 required and 1 advisory) are added to all samples and blanks to measure their
               recovery in sample and blank matrices.

               [For data generated through the Low Concentration Method: Surrogate spikes, 3 acid compounds
               and 3 base/neutral compounds, are added to all samples and blanks to measure their recovery in
               sample and blank matrices.]

        2.      Surrogate spike recoveries for semivolatile samples and blanks must be within the limits
               specified on in the SOW and on Form II SV-1 and SV-2.

               [For data generated through the Low Concentration Method: Surrogate spike recoveries for
               semivolatile samples and blanks must be within the limits specified in the method and on Form II
               LCSV.J

D.      Evaluation:

        1.      Check raw data (e.g., chromatograms and quantitation reports) to verify the surrogate spike
               recoveries on the Surrogate Recovery Form II SV-1 and  SV-2 [Form IILCSV]. Check for
               any transcription or calculation errors.

        2.      Check that the surrogate spike recoveries were calculated correctly. The equation can be
               found in the method
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        3.      The following should be determined from the Surrogate Recovery form(s):

               a.      If any two base/neutral or acid surrogates are out of specification, or if any one
                       base/neutral or acid extractable surrogate has a recovery of less than 10%, then
                       there should be a reanalysis to confirm that the non-compliance is due to sample
                       matrix effects rather than laboratory deficiencies.

        NOTE:        When there are unacceptable surrogate recoveries followed by successful re-
                       analyses, the laboratories are required to report only the acceptable run.

               b.      The laboratory has failed to perform satisfactorily if surrogate recoveries are out of
                       specification and there is no evidence of reinjection of the extract, or reextraction
                       and reanalysis (if reinjection fails to resolve the problem).

               c.      Verify that no  blanks have surrogate recoveries outside the criteria.

        4.      Any time there are two or more analyses for a particular fraction the reviewer must
               determine which are the best data to report. Considerations should include but are not
               limited to:

               a.      Surrogate recovery (marginal versus gross deviation).

               b.      Technical holding times.

               c.      Comparison of the values of the target compounds reported in each fraction.

               d.      Other QC information, such as performance of internal standards.

E.      Action:

        Data are not qualified with respect to surrogate recovery unless two or more semivolatile surrogates,
        within the same fraction (base/neutral or acid fraction), are out of specification. For surrogate spike
        recoveries out of specification, the following approaches are suggested based on a review of all data
        from the case, especially considering the apparent complexity  of the sample matrix.

        1.      If two or more surrogates in either semivolatile fraction (base/neutral or acid fraction) have a
               recovery greater than the upper acceptance limit (UL):

               a.      Specify the fraction that is being qualified, i.e. acid, base/neutral, or both.

               b.      Detected semivolatile target compounds are qualified "J."

               c.      Results for non-detected semivolatile target compounds should not be qualified.
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        2.      If two or more surrogates in either semivolatile fraction have a recovery greater than or equal
               to 10% but less than the lower acceptance limit (LL):

               a.      Specify the fraction that is being qualified, i.e. acid, base/neutral, or both.

               b.      Detected semivolatile target compounds are qualified "J."

               c.      For non-detected semivolatile target compounds, the sample quantitation limit is
                       qualified as approximated (UJ).

        3.      In the case where two or more surrogates are out in either semi-volatile fraction; one with a
               recovery greater than the upper acceptance limit and one with a recovery greater than or
               equal to 10% but less than the lower acceptance limit, qualify as described in SV Section
               VI.E.2 a., b., & c. above.

        4.      If any surrogate in either semivolatile fraction show less than 10% recovery:

               a.      Specify the fraction that is being qualified, i.e. acid, base/neutral, or both.

               b.      Detected semivolatile target compounds are qualified "J".

               c.      Non-detected semivolatile target compounds may be qualified as unusable (R).
        5.      In the special case of a blank analysis with surrogates out of specification, the reviewer must
               give special consideration to the validity of associated sample data. The basic concern is
               whether the blank problems represent an isolated problem with the blank alone, or whether
               there is a fundamental problem with the analytical process.  For example, if one or more
               samples in the batch show acceptable surrogate recoveries, the reviewer may choose to
               consider the blank problem to be an isolated occurrence.

        6.      Whenever possible, the potential effects of the data resulting from surrogate recoveries not
               meeting the advisory limits should be noted in the data review narrative. Additionally, the
               lack of reanalysis of samples that were out of specification should be noted for TPO action.
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                           VII.  Matrix Spikes/Matrix Spike Duplicates
                         (Not Required for Low Concentration Water Data)
A.     Review Items: Form III SV-1 and SV-2, chromatograms, and quantitation reports.

B.     Objective:

       Data for matrix spikes/matrix spike duplicates (MS/MSD) are generated to determine long-term
       precision and accuracy of the analytical method on various matrices and to demonstrate acceptable
       compound recovery by the laboratory at the time of sample analysis. These data alone cannot be
       used to evaluate the precision and accuracy of individual samples. However, when exercising
       professional judgement, this data should be used in conjunction with other available QC information.

C.     Criteria:

       1.      A matrix spike and matrix spike duplicate are extracted and analyzed for every 20 field
               samples of similar matrix in an SDG, whenever samples are extracted by the same
               procedure.

       2.      Matrix spike and matrix spike duplicate recoveries should be within the advisory limits
               established on Form III SV-1 and SV-2.

       3.      The Relative Percent Differences (RPDs) between matrix spike and matrix spike duplicate
               recoveries should be within the advisory limits listed on Form III SV-1 and SV-2.

D.     Evaluation:

       1.      Verify that MS and MSD samples were analyzed at the required frequency and that results
               are provided for each sample matrix.

       2.      Inspect results for the MS/MSD Recovery on Form III SV-1 and SV-2 and verify that the
               results for recovery and RPD are within the advisory limits.

       3.      Verify transcriptions from raw data and verify calculations.

       4.      Check that the recoveries and RPD were calculated correctly.

       5.      Compare results (%RSD) of non-spiked compounds between the original result, MS, and
               MSD.
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E.     Action:
        1.      No action is taken on MS/MSD data alone.  However, using informed professional judgment
               the data reviewer may use the matrix spike and matrix spike duplicate results in conjunction
               with other QC criteria and determine the need for some qualification of the data.

        2.      The data reviewer should first try to determine to what extent the results of the MS/MSD
               effect the associated data. This determination should be made with regard to the MS/MSD
               sample itself as well as specific analytes for all samples associated with the MS/MSD.

        3.      In those instances where it can be determined that the results of the MS/MSD effect only the
               sample spiked, then qualification should be limited to this sample alone. However, it may be
               determined through the MS/MSD results that a laboratory is having a systematic problem in
               the analysis of one or more analytes, which affects all associated samples.

        4.      The reviewer must use professional judgement to determine the need for qualification of
               positive results of non-spiked compounds.
       NOTE:        If a field blank was used for the MS/MSD, the TPO must be notified.
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                                  VIII.  Laboratory Control Samples
                                        (Low Concentration Water)
[A.     Review Items: Form III LCSV, LCS chromatograms and quantitation reports.

B.      Objective:

        Data for Laboratory Control Samples (LCS) are generated to provide information on the accuracy of the
        analytical method and the laboratory performance.

C.      Criteria:

        1.       Laboratory control samples are prepared, extracted, analyzed, and reported once per SDG. The
                LCS must be extracted and analyzed concurrently with the samples in the SDG, using the same
                instrumentation as the samples in the SDG.

        2.       LCS percent recoveries must be within the QC limits provided on Form III LCSV. The LCS must
                meet the recovery criteria for the sample data to be accepted.

        3.       The LCS contains the following semivolatile target compounds, in addition to the required
                surrogates:
                        Phenol                                   1,2,4-Trichlorobenzene
                        2-Chlorophenol                           Naphthalene
                        4-Chloroaniline                           2,4-Dinitrotoluene
                        2,4,6-Trichlorophenol                     Diethylphthalate
                        bis(2-Chloroethyl)ether                    N-Nitrosodiphenylamine
                        N-Nitroso-di-n-propylamine                Hexachlorobenzene
                        Hexachloroethane                         Benzo(a)pyrene
                        Isophorone
        4.       The criteria for surrogate recovery and internal standard performance also apply.

D.      Evaluation:

        1.       Verify that LCS samples were analyzed at the re quired frequency.

        2.       Inspect the results for LCS Recovery on Form III LCSV and verify that the results for recovery are
                within the QC limits.

        3.       Verify transcriptions from raw data and verify calculations.

        4.       Check that the recoveries were calculated correctly.
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E.      Action:
        If the LCS criteria are not met, then the laboratory performance and method accuracy are in question.
        Professional judgement should be used to determine if the data should be qualified or rejected. The
        following guidance is suggested for qualifying sample data for which the associated LCS does not meet the
        required criteria.

        1.      Action on the LCS recovery should be based on both the number of compounds that are outside of
                the recovery criteria and the magnitude of the exceedance of the criteria.

        2.      If the LCS recovery criteria are not met, then the LCS results should be used to qualify sample data
                for the specific compounds that are included in the LCS solution. Professional judgement should
                be used to qualify data for compounds other than those compounds that are included in the LCS.
                Professional judgement to qualify non-LCS compounds should take into account the compound
                class, compound recovery efficiency, analytical problems associated with each compound, and
                comparability in performance of the LCS compound to the non-LCS compound.

        3.      If the LCS recovery is greater than the upper acceptance limit, then positive sample results for the
                affected compound(s) should be qualified with a "J".

        4.      If the mass spectral criteria are met but the LCS recovery is less than the lower acceptance limit,
                then the associated detected target compounds should be qualified "J" and the associated non-
                detected target compounds should be qualified "R ".

        5.      If more than half of the compounds in the LCS are not within the recovery criteria, then all of the
                associated detected target compounds should be qualified "J" and all associated non-detected
                target compounds should be qualified "R. "

        6.      Action on non-compliant surrogate recovery and internal standard performance should follow the
                procedures provided in SV Section VI.E andX.E, respectively. Professional judgement should be
                used to evaluate the impact that non-compliance for surrogate recovery and internal standard
                performance in the LCS has on the associated sample data.

        7.      It should be noted for TPO action if a laboratory fails to analyze an LCS with each SDG, or if a
                laboratory consistently fails to generate acceptable LCS recoveries.]
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                       IX. Regional Quality Assurance and Quality Control


A.     Review Items:  Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2], chromatograms, quantitation
       report, traffic report and raw data for Regional QC samples.

B.     Objective:

       Regional Quality Assurance and Quality Control (QA/QC) refer to any QA and/or QC initiated by
       the Region, including field duplicates, Regional Performance Evaluation (PE) samples, blind spikes,
       and blind blanks.  (It is highly recommended that Regions adopt the use of these QA/QC samples.)

C.     Criteria:

       Criteria are determined by each Region.

       1.      Performance evaluation sample frequency may vary.

               [For data generated through the Low Concentration Method: A performance evaluation (PE)
               sample can be included as frequently as once per SDG.J

       2.      The analytes present in the PE sample must be correctly identified and quantified.

D.     Evaluation:

       Evaluation procedures must follow the Region's SOP for data review. Each Region will handle the
       evaluation of PE samples on an individual basis. Results for PE samples should be compared to the
       acceptance criteria for the specific PE samples, if available.

E.     Action:

       Any action must be in accordance with Regional specifications and the criteria for acceptable PE
       sample results. Unacceptable results for PE samples should be noted for TPO action.
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                                      X.  Internal Standards
A.      Review Items: Form VIII SV-1 and SV-2 [Form VIIILCSV-1 andLCSV-2], quantitation reports, and
        chromatograms.
B.      Objective:

        Internal Standards (IS) performance criteria ensure that GC/MS sensitivity and response are stable
        during every analytical run.
C.      Criteria:

        1.      Internal standard area counts for samples and blanks must not vary by more than a factor of
               two (- 50% to + 100%) from the associated 12hr calibration standard.

        2.      The retention time of the internal standards in samples and blanks must not vary by more
               than + 30 seconds from the retention time of the associated 12hr calibration standard.

               [For data generated through the Low Concentration Method: The retention time of the internal
               standards in samples and blanks must not vary by more than ±20.0 seconds from the retention time
               of the associated calibration standard.]
D.      Evaluation:

        1.      Check raw data (e.g., chromatograms and quantitation lists) for samples and blanks to verify
               the internal standard retention times and areas reported on the Internal Standard Area
               Summary (Forms VIII SV-1, VIII SV-2 [Form VIIILCSV-1 andLCSV-2]).

        2.      Verify that all retention times and IS areas are within the required criteria.

        3.      If there are two analyses for a particular fraction, the reviewer must determine which are the
               best data to report.  Considerations should include:

               a.      Magnitude and direction of the IS area shift.

               b.      Magnitude and direction of the IS retention time shift.

               c.      Technical holding times.

               d.      Comparison of the values of the target compounds reported in each fraction.
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E.      Action:
        1.      If an IS area count for a sample or blank is outside - 50% or + 100% of the area for the
               associated standard:

               a.      Positive results for compounds quantitated using that IS should be qualified with
                       "J".

               b.      Non-detected compounds quantitated using an IS area count greater than 100%
                       should not be qualified.

               c.      Non-detected compounds quantitated using an IS area count less than 50% are
                       reported as the associated sample quantitation limit and qualified with "UJ".

               d.      If extremely low area counts are reported, or if performance exhibits a major abrupt
                       drop-off, then a severe loss of sensitivity is indicated. Non-detected target
                       compounds should then be qualified as unusable (R).
        2.      If an IS retention time varies by more than 30 seconds:

               [If an IS retention time varies by more than 20.0 seconds:]

               The chromatographic profile for that sample must be examined to determine if any false
               positives or negatives exist. For shifts of a large magnitude, the reviewer may consider
               partial or total rejection (R) of the data for that sample fraction.  Positive results should not
               need to be qualified with "R" if the mass spectral criteria are met.

        3.      If the internal standards performance criteria are grossly exceeded, then this should be noted
               for TPO action. Potential effects on the data resulting from unacceptable internal standard
               performance should be noted in the data review narrative.
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                               XL  Target Compound Identification
A.      Review Items: Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2], quantitation reports, mass
        spectra, and chromatograms.

B.      Objective:

        Qualitative criteria for compound identification have been established to minimize the number of
        erroneous identifications of compounds. An erroneous identification can either be a false positive
        (reporting a compound present when it is not) or a false negative (not reporting a compound that is
        present).

        The identification criteria can be applied much more easily in detecting false positives than false
        negatives. More information is available due to the requirement for submittal of data supporting
        positive identifications. Negatives, or non-detected compounds, on the other hand represent an
        absence of data and are, therefore, much more difficult to assess. One example of detecting false
        negatives is the reporting of a Target Compound as a TIC.

C.      Criteria:

        1.      Compound must be within + 0.06 relative retention time (RRT) units of the standard RRT.

        2.      Mass spectra of the sample compound and a current laboratory-generated standard must
               match according  to the following criteria:

               a.      All ions  present in the standard mass spectrum at a relative intensity greater than
                       10% must be present in the sample spectrum

                      [For data generated through the Low Concentration Method: All ions present in the
                      standard mass spectrum at a relative intensity greater than 25% must be present in the
                      sample spectrum.]

               b.      The relative intensities of these ions must agree within +20% between the standard
                      and sample spectra. (Example: For an ion with an abundance of 50% in the
                      standard spectrum, the corresponding sample ion  abundance must be between 30%
                      and 70%.)

               c.      Ions present at greater than 10% in the sample mass spectrum but not present in the
                      standard spectrum must be considered and accounted for.

                      [For data generated through the Low Concentration Method: Ions present at greater than
                      25% in the sample mass spectrum but not present in the standard mass spectrum must be
                      considered and accounted for.]
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D.      Evaluation:
        1.      Check that the RRT of reported compounds is within + 0.06 RRT units of the standard
               relative retention time.

        2.      Check the sample compound spectra against the laboratory standard spectra to verify that its
               meets the specified criteria.

        3.      The reviewer should be aware of situations (e.g., high concentration samples preceding low
               concentration samples) when sample carryover is a possibility and should use judgment to
               determine if instrument cross-contamination has affected any positive compound
               identification.

        4.      Check the chromatogram to verify that peaks are accounted for, i.e., major peaks are either
               identified as target compounds, TICs, surrogates, or internal standards.
E.     Action:
        1.      The application of qualitative criteria for GC/MS analysis of target compounds requires
               professional judgement.  It is up to the reviewer's discretion to obtain additional information
               from the laboratory. If it is determined that incorrect identifications were made, all such data
               should be qualified as not detected (U) or unusable (R).

        2.      Professional judgement must be used to qualify the data if it is determined that cross-
               contamination has occurred.

        3.      Any changes made to the reported compounds or concerns regarding target compound
               identifications should be clearly indicated in the data review narrative.  The necessity for
               numerous or significant changes should be noted for TPO action.
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                       XII.  Compound Ouantitation and Reported CRQLS
A.      Review Items: Form I SV-1 and SV-2 [Form ILCSV-1 andLCSV-2], sample preparation sheets, case
        narrative, sample clean-up sheets, quantitation reports, and chromatograms.

B.      Objective:

        The objective is to ensure that the reported quantitation results and Contract Required Quantitation
        Limits (CRQLs) for semivolatile target compounds are accurate.

C.      Criteria:

        1.      Compound quantitation, as well as the adjustment of the CRQL, must be calculated
               according to the correct equation.

        2.      Compound area responses must be calculated based on the internal standard (IS) associated
               with that compound, as listed in the method.  Quantitation must be based on the quantitation
               ion (m/z) specified in the method for both the IS and target analytes. The compound
               quantitation must be based on the RRF from the appropriate daily calibration standard.

D.      Evaluation:

        1.      For all fractions, raw data should be examined to verify the correct calculation of all sample
               results reported by the laboratory. Quantitation lists, chromatograms, and sample
               preparation log sheets should be compared to the reported positive sample results and
               quantitation limits. Check the reported values.

        2.      Verify that the correct internal standard, quantitation ion, and RRF were used to quantitate
               the compound. Verify that the same internal standard, quantitation ion, and RRF are used
               consistently throughout the calibration and quantitation processes.

        3.      Verify that the CRQLs have been adjusted to reflect all sample dilutions, concentrations,
               splits, clean-up activities, and dry weight factors that are not accounted for by the method.
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E.      Action:
        1.      If there are any discrepancies found, the laboratory may be contacted by the designated
               representative to obtain additional information that could resolve any differences.  If a
               discrepancy remains unresolved, the reviewer must use professional judgement to decide
               which value is the best value.  Under these circumstances, the reviewer may determine
               qualification of data is warranted. Decisions made on data quality should be included in the
               data review narrative. A description of the reasons for data qualification and the
               qualification that is applied to the data should be documented in the data review narrative.

        2.      Numerous or significant failures to accurately quantify the target compound or to properly
               evaluate and adjust CRQLs should be noted for TPO action.
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                              XIII.  Tentatively Identified Compounds
A.      Review Items:  Form I SV-TIC [Form ILCSV-TIC], chromatograms, and library search printouts
        with spectra for the TIC candidates.

B.      Objective:

        Chromatographic peaks in semivolatile fraction analyses that are not target analytes, surrogates, or
        internal standards are potential tentatively identified compounds (TICs). TICs must be qualitatively
        identified by a National Institute of Standards and Technology (NIST) mass spectral library search
        and the identifications assessed by the data reviewer.

C.      Criteria:

        For each sample, the laboratory must conduct a mass spectral search of the NIST library and report
        the possible identity for the appropriate number of the largest semivolatile fraction peaks which are
        not surrogate, internal standard, or target compounds, but which have area or height greater than 10
        percent of the area or height of the nearest internal standard. Peaks that are suspected to be part of
        an alkane series shall be library searched and reported, as the alkane series (e.g., C5-C9), as a single
        entry along with the estimate for the total concentration of the series. TIC results are reported for
        each sample on the Organic Analyses Data Sheet (Form I SV-TIC).

        [For data generated through the Low Concentration Method: For each sample, the laboratory must conduct
        a mass spectral search of the NIST library and report the possible identity for the appropriate number of the
        largest semivolatile fraction peaks which are not surrogates, internal standards, or TCL compounds, but
        which have an area greater than 50 percent of the area of the nearest internal standard.  Estimated
        concentrations for TICs are calculated similarly to the TCL compounds, using total ion areas for the TIC
        and the internal standard, and assuming a relative response factor of 1.0. Peaks that are suspected to be
        part of an alkane series shall be library searched and reported, as the alkane series (e.g., C5-C9j, as a single
        entry along with the estimate for the total concentration of the series. TIC results are reported for each
        sample  on the Organic Analyses Data Sheet (Form ILCSV-TIC).]
        NOTE:        Since the method revision of October 1986, the CLP does not allow the laboratory
                       to report as tentatively identified compounds any target compound which is properly
                       reported in another fraction. For example, late eluting volatile target compounds
                       should not be reported as semivolatile TICs.
D.      Evaluation:

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1.       Guidelines for tentative identification are as follows:

        a.      Major ions (greater than 10% relative intensity) in the reference spectrum should be
               present in the sample spectrum.

               [Major ions (greater than 25% relative intensity) in the reference spectrum should be
               present in the sample spectrum.]

        b.      The relative intensities of the major ions should agree within ±20% between the
               sample and the reference spectra.

        c.      Molecular ions present in the reference spectrum should be present in the sample
               spectrum.

        d.      Ions present in the sample spectrum but not in the reference spectrum should be
               reviewed for possible background contamination, interference, or coelution of
               additional TIC or target compounds.

        e.      When the above criteria are not met, but in the technical judgment of the data
               reviewer or mass spectral interpretation specialist the identification is correct, the
               data reviewer may report the identification.

        f.      If in the data reviewer's judgment the identification is uncertain or there are
               extenuating factors affecting compound identifications, the TIC result may be
               reported as "unknown".

2.       Check the raw data to verify that the laboratory has generated a library search for all
        required peaks in the chromatograms for samples and blanks.

        [Check the raw data to verify that the laboratory has generated a library search for all required
        peaks in the chromatograms for samples and blanks with areas greater than or equal to 50 percent
        of the area of the nearest internal standard.]

3.       Blank chromatograms  should be examined to verify that TIC peaks present in samples are
        not found in blanks.  When a low-level non-target compound that is a common artifact or
        laboratory contaminant is detected in a sample, a thorough check of blank chromatograms
        may require looking for peaks which are less than 10 percent of the internal standard height,
        but present in the blank chromatogram at a similar relative retention time.

        [Blank chromatograms should be examined to verify that TIC peaks present in samples are not
        found in blanks. When a low-level non-TCL compound that is a common artifact or laboratory
        contaminant is detected in a sample, a thorough check of blank chromatograms may require
        looking for peaks which  have areas less than 50 percent of the internal standard area, but present
        in the blank chromatogram  at a similar relative retention time.]
        All mass spectra for each sample and blank must be examined.
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        5.      Since TIC library searches often yield several candidate compounds having a close matching
               score, all reasonable choices should be considered.

        6.      Check the raw data to verify that the laboratory has properly identified and assigned
               peaks to the alkane series.

        7.      The reviewer should be aware of common laboratory artifacts/contaminants and their
               sources (e.g., aldol condensation products, solvent preservatives, and reagent contaminants).
               These may be present in blanks and not reported as sample TICs.

               Examples:

               a.      Common laboratory contaminants:  CO2 (m/z 44), siloxanes (m/z 73), diethyl ether,
                       hexane, certain freons (l,l,2-trichloro-l,2,2-trifluoroethane  or fluoro-
                       trichloromethane), and phthalates at levels less than 100 ug/L or 4000 ug/Kg.

               b.      Solvent preservatives, such as cyclohexene which is a methylene chloride preser-
                       vative.  Related by-products include cyclohexanone, cyclohexenone, cyclohexanol,
                       cyclohexenol, chlorocyclohexene, and chlorocyclohexanol.

               c.      Aldol reaction products of acetone include: 4-hydroxy-4-methyl-2-pentanone, 4-
                       methyl-2-penten-2-one, and 5,5-dimethyl-2(5H)-furanone.

        8.      Occasionally, a target compound may be identified as a TIC in the proper analytical fraction
               by non-target library search procedures, even though it was not found on the quantitation
               list.  If the total area quantitation method was used, the reviewer should request that the
               laboratory recalculate the result using the proper quantitation ion.  In addition, the reviewer
               should evaluate other sample chromatograms and check library reference retention times on
               quantitation lists to determine whether the false negative result is an  isolated occurrence or
               whether additional data may be affected.

        9.      Target compounds may be identified in more than one fraction.  Verify that quantitation is
               made from the proper fraction.

        10.     Library searches should not be performed on internal standards or surrogates.

        11.     TIC concentration should be estimated assuming a RRF of 1.0.

E.      Action:

        1.      All TIC results  should be qualified "NJ", tentatively identified, with  approximated
               concentrations.
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2.       General actions related to the review of TIC results are as follows:

        a.      If it is determined that a tentative identification of a non-target compound is not
               acceptable, the tentative identification should be changed to "unknown" or an
               appropriate identification.

        b.      If all contractually required peaks were not library searched and quantitated, the
               designated representative could request these data from the laboratory.

3.       TIC results which are not sufficiently above the level in the blank should not be reported.
        (Dilutions and sample size must be taken into account when comparing the amounts present
        in blanks  and samples.)

4.       When a compound is not found in any blanks, but is a suspected artifact of common
        laboratory contamination, the result may be qualified as unusable (R).

5.       In deciding whether a library search result for a TIC represents a reasonable identification,
        professional judgment must be exercised.  If there is more than one possible match, the
        result may be reported as "either compound X or compound Y." If there is a lack of isomer
        specificity, the TIC result may be changed to a non-specific  isomer result (e.g., 1,3,5-
        trimethyl  benzene to trimethyl benzene isomer) or to a compound class (e.g., 2-methyl, 3-
        ethyl benzene to substituted aromatic compound).

6.       The reviewer may  elect to report all similar isomers as a total.  All alkanes may be
        summarized and reported as  total hydrocarbons (e.g., alkane series C5-C9). Reporting an
        alkane series counts only as one of the 30 most intense non-target semi-volatile compounds.

7.       Other case factors may influence  TIC judgments. If a sample TIC match is poor but other
        samples have a TIC with a good library match, similar relative retention time, and the  same
        ions, identification information may be inferred from the other sample TIC results.

8.       Physical constants, such as boiling point, may be factored into professional judgment of TIC
        results.

9.       Any changes made to the reported data or any concerns regarding TIC identifications should
        be indicated in the  data review narrative.

10.     Failure to properly evaluate and report TICs should be noted for TPO action.
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                                    XIV.  System Performance
A.      Review Items:  Form III SV-1 and SV-2 [Form IIILCSV], Form VIII SV-1 and SV-2 [Form VIII
        LCSV-1 and LCSV-2J, and chromatograms.

B.      Objective:

        During the period following Instrument Performance QC checks (e.g. blanks, tuning, calibration),
        changes may occur in the system that degrade the quality of the data. While this degradation would
        not be directly shown by QC checks until the next required series of analytical QC runs, a through
        review of the ongoing data acquisition can yield indicators of instrument performance.

C.      Criteria:

        There are no specific criteria for system performance. Professional judgement should be used to
        assess the system performance.

D.      Evaluation:

        1.      Abrupt, discrete shifts in the reconstructed ion chromatogram (RIC) baseline  may indicate a
               change in the instrument's sensitivity or the zero setting. A baseline shift could indicate a
               decrease in sensitivity in the instrument or an increase in the instrument zero, possibly
               causing target compounds at or near the detection limit to be non-detects.  A baseline "rise"
               could indicate problems such as a change  in the instrument zero, a leak, or degradation of the
               column.

        2.      Poor chromatographic performance affects both qualitative and quantitative results.
               Indications of substandard performance include:

               a.      High RIC background levels or shifts in absolute retention times of internal
                       standards.

               b.      Excessive baseline rise at elevated temperature.

               c.      Extraneous peaks.

               d.      Loss of resolution as suggested between by factors such as non-resolution of 2,4-
                       and 2,5- dinitrotoluene.

               e.      Peak tailing or peak splitting that may result in inaccurate quantitation.

        [3.     A drift in instrument sensitivity may occur during the 12-hour time period. This could be discerned
               by examination of the IS area on Form VIII LCSV-1 and LCSV-2for trends such as a continuous or
               near-continuous increase or decrease in the IS area over time.
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        4.      The results of the LCS analysis (Form III LCSV) may also be used to assess instrument
               performance.]
E.      Action:
        Professional judgement must be used to qualify the data if it is determined that system performance
        has degraded during sample analyses. Any degradation of system performance which significantly
        affected the data should be documented for TPO action.
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                                  XV.  Overall Assessment of Data


A.      Review Items:  Entire data package, data review results, and (if available) Quality Assurance Project
        Plan (QAPjP), and Sampling and Analysis Plan (SAP).

B.      Objective:

        The overall assessment of a data package is a brief narrative in which the data reviewer expresses
        concerns and comments on the quality and, if possible, the useability of the data.

C.      Criteria:

        Assess the overall quality of the data.


D.      Evaluation:

        1.      Evaluate any technical problems which have not been previously addressed.

        2.      Review all available materials to assess the overall quality of the data, keeping in mind the
               additive nature of analytical problems.

        3.      If appropriate information is available, the reviewer may assess the useability of the data to
               assist the data user in avoiding inappropriate use of the data. Review all available
               information, including the QAPjP (specifically the Data Quality Objectives), SAP, and
               communication with data user that concerns the intended use and desired quality of the data.

E.      Action:

        1.      Use professional judgement to determine if there is any need to qualify data which were not
               qualified based on the QC criteria previously discussed.

        2.      Write a brief narrative to give the user an indication of the analytical limitations of the data.
               Any inconsistency of that data with the SDG Narrative should be noted for TPO action. If
               sufficient information on the intended use and required quality of the data are available, the
               reviewer should include his/her assessment of the useability of the data within the given
               context.
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                            PESTICIDE/AROCLOR DATA REVIEW


***[Data review guidelines that are unique to data generated through the Low Concentration Water Method are
contained within brackets ([]) and written in italics.]***


The pesticide/Aroclor data requirements to be checked are listed below.

       I.       Holding Times (Method Holding Times)

       II.      GC/ECD Instrument Performance Check

       III.     Initial Calibration

       IV.     Calibration Verification

       V.      Blanks

       VI.     Surrogate Spikes

       VII.    Matrix Spikes/Matrix Spike Duplicates

       VIII.    Laboratory Control Samples

       IX.     Regional Quality Assurance and Quality Control

       X.      Pesticide Cleanup Checks

       XI.     Target Compound Identification

       XII.    Compound Quantitation and Reported Contract Required Quantitation Limits (CRQLs)

       XIII.    Overall Assessment of Data
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PEST
                                        I.  Holding Times


A.      Review Items: Form I PEST [Form ILCP], EPA Sample Traffic Report, and/or chain-of-custody,
        raw data, sample extraction sheets, and SDG Narrative.

B.      Objective:

        The objective is to ascertain the validity of results based on the holding time of the sample from time
        of collection to time of sample extraction and analysis.

C.      Criteria:

        Technical requirements for sample holding times have only been established for water matrices.


        The technical holding time criteria for water samples, are as follows:
               For pesticides and Aroclors in cooled (@ 4°C) water samples, 7 days from sample collection
               to time of extraction and then 40 days from sample extraction to analysis.
        It is recommended that pesticides and Aroclors in soil samples be extracted within 14 days of sample
        collection.
        The method holding times, which differ from the technical holding times, state that extraction of
        water samples by separatory funnel must be completed within 5 days of validated time of sample
        receipt (VTSR), extraction of water samples by continuous liquid-liquid extraction procedures must
        be started within 5 days of VTSR, and soil/sediment samples are to be extracted within 10 days of
        VTSR. Also, contractually  both water and soil sample extracts must be analyzed within 40 days of
        sample extraction.

        [For data generated through the Low Concentration Method: The holding times requirements are that the
        extraction of all samples must be started within 5 days of the VTSR, and the  extracts must be analyzed within
        40 days of VTSR.]
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D.     Evaluation:
        Technical holding times for sample extraction are established by comparing the sample collection
        date on the EPA Sample Traffic Report with the dates of extraction on Form I PEST [Form ILCP]
        and the sample extraction sheets. To determine if the samples were analyzed within the holding time
        after extraction, compare the dates of extraction on the sample extraction sheets with the dates of
        analysis on Form I PEST [Form ILCP].

        Verify that the traffic report indicates that the samples were received intact and  iced. If the samples
        were not iced or there were any problems with the  samples upon receipt, then discrepancies in the
        sample condition could effect the data.
E.     Action:
        1.      If technical holding times are exceeded, qualify all detected compound results as estimated
               "J" and sample quantitation limits as estimated "UJ," and document in the data review
               narrative that holding times were exceeded.

        2.      If technical holding times are grossly exceeded, either on the first analysis or upon re-
               analysis, the reviewer must use professional judgement to determine the reliability of the
               data and the  effect of additional storage on the sample results.  The reviewer may determine
               that detected compound results or the associated quantitation limits are approximates and
               should be qualified with "J" or "UJ", respectively. The reviewer may determine that non-
               detected target compound data are unusable (R).

        3.      Due to limited information concerning holding times for soil samples, it is left to the
               discretion of the data reviewer to apply water holding time criteria to soil samples.
               Professional judgement is required to evaluate holding times for soil samples.

        4.      Whenever possible, the reviewer should comment on the effect of exceeding the holding time
               on the resulting data in the data review narrative.

        5.      When method and/or technical holding times are exceeded, this should be noted as an action
               item for the TPO.

        6.      The reviewer should also be aware of the scenario in which the laboratory has exceeded the
               technical holding times, but met contractual holding times. In this case, the data reviewer
               should notify the Regional TPO (where samples were collected) and/or RSCC that shipment
               delays have occurred so that the field problem can be corrected. The reviewer may pass this
               information on to the laboratory's TPO, but should explain that contractually the laboratory
               met the requirements.
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PEST
                           II.  GC/ECD Instrument Performance Check
A.     Review Items:  Form VI PEST-4,-5 [Form VILCP-4,-5], Form VII PEST-1 [Form VIILCP-1], Form
       VIII PEST [Form VIIILCP], chromatograms, and data system printouts.

B.     Objective:

       Performance checks on the gas chromatograph with electron capture detector (GC/ECD) system are
       performed to ensure adequate resolution and instrument sensitivity.  These criteria are not sample
       specific. Conformance is determined using standard materials, therefore, these criteria should be met
       in all circumstances.

C.     Criteria:

       1.      Resolution Check Mixture

               a.       The Resolution Check Mixture must be analyzed at the  beginning of every initial
                       calibration sequence, on each GC column and instrument used for analysis.  The
                       Resolution Check Mixture contains the following pesticides and surrogates:

                              gamma-Chlordane              Endrin ketone
                              Endosulfan I                   Methoxychlor
                              4,4'-DDE                      Tetrachloro-m-xylene
                              Dieldrin                       Decachlorobiphenyl
                              Endosulfan sulfate

               b.       The depth of the valley between two adjacent peaks in the Resolution Check
                       Mixture must be greater than or equal to 60.0 percent of the height of the  shorter
                       peak.

       2.      Performance Evaluation Mixtures

               a.       The Performance Evaluation Mixture (PEM) must be analyzed at the beginning
                       (following the resolution check mixture) and at the end  of the initial calibration
                       sequence.  The PEM must also be analyzed at the beginning of every other 12-hour
                       analytical period.  The PEM contains the following pesticides and surrogates:

                              gamma-BHC           Endrin
                              alpha-BHC            Methoxychlor
                              4,4'-DDT              Tetrachloro-m-xylene
                              beta-BHC             Decachlorobiphenyl
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               b.      All peaks in the Performance Evaluation Mixture injections must be greater than or
                      equal to 90 percent resolved on each GC column.  This applies to both initial and
                      continuing calibrations.

               c.      The absolute retention times of each of the single component pesticides and
                      surrogates in all PEM analyses must be within the specific retention time windows
                      centered around the mean retention times determined from the three-point initial
                      calibration using the Individual Standard Mixtures.

                      For example, for a given pesticide the mean retention time is first determined from
                      the initial calibration and found to be 12.69 minutes. The retention time window for
                      this pesticide is ± 0.05 minutes.  Therefore, the calculated retention time window
                      would range from 12.64 to  12.74 minutes.

               d.      The percent difference between the calculated amount (amount found) and the
                      nominal amount (amount added) for each of the single component pesticides and
                      surrogates in both of the PEM analyses on each GC column must be greater than or
                      equal to -25.0 percent, AND less than or equal to 25.0 percent using the equation as
                      specified in the method.

               e.      The percent breakdown is the amount of decomposition that 4,4'-DDT and Endrin
                      undergo when analyzed on the GC column. For Endrin, the percent breakdown is
                      determined by the presence of Endrin aldehyde and/or Endrin ketone in the GC
                      chromatogram. For 4,4'-DDT, the percent breakdown is determined from the
                      presence of 4,4'-DDD and/or 4,4'-DDE in the GC chromatogram.

                      I.       The percent breakdown for both 4,4'-DDT and Endrin in each PEM must be
                              less than or equal to 20.0 percent for both GC columns.

                      ii.      The combined percent breakdown for 4,4'-DDT and Endrin in each PEM
                              must be less than or equal to 30.0 percent for both GC columns.
D.     Evaluation:

       1.       Resolution Check Mixture
               a.      Verify from the Form VIII PEST [Form VIIILCP] that the resolution check mixture
                      was analyzed at the beginning of the initial calibration sequence on each GC column
                      and instrument used for analysis.

               b.      Check the resolution check mixture data and Form VI PEST-4 [Form VILCP-4] to
                      verify that the resolution criterion between two adjacent peaks for the required
                      compounds is greater than or equal to 60%.
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       2.      Performance Evaluation Mixture

               a.      Verify from the Form VIII PEST [Form VIIILCP] that the Performance Evaluation
                      Mixture (PEM) was analyzed at the proper frequency and position sequence.

               b.      Check the PEM data from Form VI PEST-5, and the initial and continuing
                      calibrations to verify that the resolution between adjacent peaks is greater than or
                      equal to 90 percent on both GC columns.

               c.      Check the PEM data from the initial and continuing calibrations and Form VII
                      PEST-1 to verify that the absolute retention times for the pesticides in each analysis
                      are within the calculated retention time windows based on the mean retention time
                      from the three-point initial calibration.

               d.      Verify that the percent difference between the calculated amount (amount found)
                      and the nominal amount (amount added) for each of the single component pesticides
                      and surrogates in both of the  PEM analyses on each GC column must be greater
                      than or equal to -25.0 percent, AND less than or equal to 25.0 percent.

               e.      Verify that the individual breakdowns for 4,4'-DDT and Endrin are less than or
                      equal to 20.0 percent, and that the combined breakdown is less than or equal to 30.0
                      percent.

E.     Action:

       1.      Resolution Check Mixture

               a.      If the Resolution Check Mixture was not analyzed with the frequency described in
                      PEST Section II. C. 1, then the data reviewer should use professional judgement to
                      determine if the associated sample data should be qualified. The reviewer may need
                      to obtain additional information from the laboratory.  This situation should be
                      brought to the attention of the TPO.

               b.      If resolution criteria are not met, the quantitative results may not be accurate due to
                      inadequate resolution. Detected target compounds that were not adequately
                      resolved should be qualified with "J." Qualitative identifications may also be
                      questionable if coelution exists.  Non-detects with retention times in the region of
                      co-elution may not be valid, depending on the extent of the problem.  Professional
                      judgement should be used to determine the need to qualify data as unusable (R).
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2.       Performance Evaluation Mixture Frequency:

        If the Performance Evaluation Mixture was not analyzed with the frequency described in
        PEST Section II. C. 2, then the data reviewer should use professional judgement to
        determine if the associated sample data should be qualified. The reviewer may need to
        obtain additional information from the laboratory.  This situation should be brought to the
        attention of the TPO.

3.       Performance Evaluation Mixture Resolution:

        If PEM resolution criteria are not met, then the quantitative results may not be accurate due
        to inadequate resolution.  Positive sample results for compounds that were not adequately
        resolved should be qualified with "J".  Qualitative identifications may be questionable if co-
        elution exists. Non-detected target compounds that elute in the region of coelution may not
        be valid depending on the extent of the coelution problem. Professional judgement should
        be used to qualify data as unusable (R).

4.       Performance Evaluation Mixture Retention Times:

        Retention time windows  are used in qualitative identification. If the retention times of the
        pesticides in the PEM do not fall within the retention time windows, the associated sample
        results should be carefully evaluated.  All samples injected after the last in-control standard
        are potentially affected. It should be noted for TPO action if the PEM retention time criteria
        are grossly exceeded.

        a.      For the affected samples, check to see if the sample chromatograms contain any
               peaks that are close to the expected retention time window of the pesticide of
               interest. If no peaks are present either within or close to the retention time window
               of the deviant target pesticide compound, then there is usually no effect on the data
               (i.e., non-detected values can be considered valid).  Sample data that are potentially
               affected by standards not meeting the retention time windows should be noted in the
               data review narrative.

        b.      If the affected sample chromatograms contain peaks which may be of concern (i.e.,
               above the CRQL and either close to or within the expected retention time window of
               the analyte of interest), then the reviewer should determine the extent of the effect
               on the data and may choose to qualify detected target compounds "NJ" and non-
               detected target compounds "UJ". In some cases, additional effort by the reviewer
               may be necessary to determine if sample peaks represent the compounds of interest,
               for example:
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                       I.       The reviewer can examine the data package for the presence of three or
                               more standards containing the pesticide of interest that were run within a
                               72-hour period during which the sample was analyzed.

                       ii.       If three or more such standards are present, the mean and standard deviation
                               of the retention time window can be re-evaluated by using the mean
                               retention times of the standards.

                       iii.      If all standards and matrix spikes fall within the revised window, the valid
                               positive or negative sample results can be determined using this window.

                       iv.      The narrative should identify the additional efforts taken by the reviewer
                               and the resultant impact on data usability. In addition, the support
                               documentation should contain all calculations  and comparisons generated
                               by the reviewer.

               c.      If the reviewer cannot do anything with the data to resolve the problem of concern,
                       all positive results and quantitation limits should be qualified "R."

        5.      If percent difference  criteria are not met, qualify all associated positive results generated
               during the analytical sequence with "J" and the sample quantitation limits for non-detected
               target compounds with "UJ."

        6.      4,4'-DDT/Endrin Breakdown:

               a.      If 4,4'-DDT  breakdown is greater than 20.0 percent:

                       I.       Qualify all positive results for DDT with "J".  If DDT was not detected, but
                               ODD and DDE are detected, then qualify the quantitation limit for DDT as
                               unusable (R).

                       ii.       Qualify positive results for ODD and/or DDE as presumptively present at
                               an approximated quantity (NJ).

               b.      If Endrin breakdown is greater than 20.0 percent:

                       I.       Qualify all positive results for Endrin with "J". If Endrin was not detected,
                               but Endrin aldehyde and Endrin ketone are detected, then qualify the
                               quantitation limit for Endrin as unusable (R).

                       ii.       Qualify positive results for Endrin Aldehyde and Endrin ketone as
                               presumptively present  at an approximated quantity (NJ).
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c.      If the combined 4,4'-DDT and Endrin breakdown is greater than 30.0 percent:

       I.       The reviewer should consider the degree of individual breakdown of DDT
               and Endrin and apply qualifiers as described above.

Potential effects on the sample data resulting from the instrument performance check criteria
should be noted in the data review narrative. If the data reviewer has knowledge that the
laboratory has repeatedly failed to comply with the requirements for frequency, linearity,
retention time, resolution, or DDT/Endrin breakdown, the data reviewer should notify the
TPO.
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                                      III.  Initial Calibration
A.      Review Items: Form VI PEST-1, 2, 3, and 4 [Form VILCP-1, 2, 3, and 4], Form VII PEST-1 [Form
        VIILCP-1], Form VIII PEST [Form VIIILCP], chromatograms, and data system printouts.

B.      Objective:

        Compliance requirements for satisfactory initial calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data for pesticide and
        Aroclor compounds on the Target Compound List (TCL). Initial calibration demonstrates that the
        instrument is capable of acceptable performance at the beginning of the analytical sequence and of
        producing a linear calibration curve.

C.      Criteria:

        1.      Individual Standard Mixtures

               a.      Individual Standard Mixtures A and B (containing all of the single component
                       pesticides and surrogates) must be analyzed at low, midpoint, and high levels during
                       the initial calibration, on each GC column and instrument used for analysis.

               b.      The resolution between any two adjacent peaks  in the midpoint concentration of
                       Individual Standard Mixtures A and B in the initial calibration must be greater than
                       or equal to 90.0 percent on each column.

               c.      The absolute retention times of each of the single component pesticides and
                       surrogates are determined from three-point initial calibration using the Individual
                       Standard Mixtures. The retention time window  for each single component
                       compound can be found in the appropriate method. An example for determining
                       retention time windows is given in PEST Section II. C. 2. c above.

               d.      At least one chromatogram from each of the Individual Standard Mixtures A and B
                       must yield peaks that give recorder deflections between 50  to 100 percent of full
                       scale.
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       e.      The concentrations of the low, medium, and high level standards containing all of
               the single component pesticides and surrogates (Individual Standard Mixtures A and
               B) are as follows:

               The low point corresponds to the CRQL for each analyte. The midpoint
               concentration must be 4 times the low point. The high point must be at least 16
               times the low point, but a higher concentration may be chosen.

       f.      The Percent Relative Standard Deviation (%RSD) of the calibration factors for each
               of the single component pesticides and surrogates in the initial calibration on both
               columns for Individual Standard Mixtures A and B must be less than or equal to
               20.0 percent, except as stated below. For the two surrogates, the %RSD must be
               less than or equal to 30.0 percent.  Up to two single component target pesticides
               (other than the surrogates) per column may exceed the 20.0 percent limit but the
               %RSD must be less than or equal to 30.0 percent.

       Note:   Either peak area or peak height may be used to calculate the calibration factors that
               are, in turn, used to calculate %RSD. However, the type of peak measurement used
               to calculate each calibration factor for a given compound must be consistent. For
               example, if peak area is used to calculate the low point calibration factor for endrin,
               then the mid and high point calibration factors for endrin must also be calculated
               using peak area.

2.      Multi-component Target Compounds

       a.      The multi-component target compounds (the 7 Aroclors and Toxaphene) must each
               be analyzed separately at a single concentration level during the initial calibration
               sequence.  The analysis of the multi-component target compounds must also contain
               the pesticide surrogates.

       b.      For each multi-component analyte, the retention times are determined for three to
               five peaks.  A retention time window of + 0.07 minutes is used to determine
               retention time windows for all multi-component analyte peaks, as stated in the
               appropriate method.

       c.      Calibration factor data must be determined for each peak selected from the multi-
               component analytes.
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D.     Evaluation:

       1.      Individual Standard Mixtures

               a.      Verify from the Form VIII PEST [Form VIIILCP] that the Individual Standard
                      Mixtures A and B were analyzed at the proper frequency on each GC column and
                      instrument used for analysis. Check the raw data (chromatograms and data system
                      print outs) for each standard to verify that each of the standards was analyzed at the
                      required concentration levels.

               b.      Check Forms VII PEST-6,-7 with the raw data, and determine that the midpoint
                      standard concentration is 4 times the concentration of the low point standard
                      concentration and verify that resolution is greater than 90%.

               c.      Check the Individual Standard Mixtures A and B data and Form VIPEST-1 [Form
                      VI LCP-1] and review the calculated retention time windows for calculation and
                      transcription errors.

               d.      Check the chromatograms and verify that at least one chromatogram from each of
                      the Individual Standard mixtures A and B yields peaks registering recorder/printer
                      deflections between 50 and 100 percent of full scale.

               e.      Verify that the concentrations  of the low,  medium and high level standards of
                      Individual Mixtures A and B meet the criteria in PEST Section III. C.  1. above.

               f.      Check the Individual Standard Mixtures A and B data and Form VIPEST-2 [Form
                      VI LCP-2] to verify that the %RSD for the calibration factors in each of the single
                      component pesticides and surrogates in the initial calibration analyses on both
                      columns are in compliance with the criteria in PEST  Section III. C above.  Check
                      and recalculate the calibration factors and %RSD for one or more pesticides; verify
                      that the recalculated values agree with the reported values. If errors are detected,
                      more comprehensive recalculation  and review should be performed.

       2.      Multi-component  Target Compounds

               a.      Verify from the Form VIII PEST [Form VIII LCP] that each of the multi-component
                      target compounds were analyzed at the required frequency.  Check the raw data for
                      the standards to verify that the multi-component analytes were analyzed at the
                      required concentration.

               b.      Check the data for the multi-component target compounds and Form PEST VI-3
                      [Form VI LCP-3] to verify that at least three peaks were used for calibration and that
                      retention time windows were calculated as required.
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                       Check the data to verify that calibration factors have been determined for each
                       selected peak.
E.      Action:
        1.      If the initial calibration sequence was not followed as required, then professional judgement
               must be used to evaluate the effect of the non-compliance on the sample data.  If the
               requirements for the initial calibration sequence were not met, then this should be noted for
               TPO action.  If the non-compliance has a potential effect on the data, then the  data should be
               qualified according to the professional judgement of the reviewer and this should be noted in
               the data review narrative.

        2.      If resolution criteria are not met, then the quantitative results may not be accurate due to
               peak overlap and lack of adequate resolution.  Positive sample results for compounds that
               were not adequately resolved should be qualified with "J".  Qualitative identifications may
               be questionable if coelution exists.  Non-detected target compounds that elute  in the region
               of coelution may not be valid, depending on the extent of the coelution problem.
               Professional judgement should be used to qualify data as unusable (R).

        3.      If retention time windows, are not calculated correctly, recalculate the windows and use the
               corrected values for all evaluations.

        4.      If the chromatogram display (recorder deflection) criteria are not met, use professional
               judgement to evaluate the effect on the data. If the data reviewer has  knowledge that the
               laboratory has repeatedly failed to comply with this requirement, the data reviewer should
               notify the TPO.

        5.      If the sample concentration exceeds the linearity of the calibration curve, and the sample is
               not properly diluted and re-analyzed, flag the positive results "J".

        6.      If the standard concentration criteria are not met, use professional judgement to evaluate the
               affect on the data and notify the TPO.  This is especially critical for the low level standards
               and non-detects.

        7.      If the %RSD linearity criteria are not met for the compound(s) being  quantified, qualify all
               associated positive quantitative results with "J" and the sample quantitation limits for non-
               detected target compounds with "UJ".

        8.      Potential effects on the sample data due to problems with calibration  should be noted in the
               data review narrative. If the data reviewer has knowledge that the laboratory has repeatedly
               failed to comply with the requirements for frequency, linearity, retention time, or resolution,
               the data reviewer should notify the TPO.
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                                   IV.  Calibration Verification
A.      Review Items: Form VI PEST-6 and 7, Form VII PEST-1 and 2 [Form VIILCP-1 and 2], Form VIII
        PEST [Form VIIILCP], chromatograms, and data system printouts.

B.      Objective:

        Compliance requirements for satisfactory instrument calibration are established to ensure that the
        instrument is capable of producing acceptable qualitative and quantitative data. Calibration
        verification checks and documents satisfactory performance of the instrument over specific time
        periods during sample analysis.  To confirm the calibration and evaluate instrument performance,
        calibration verification is performed, consisting of the analyses of instrument blanks, the PEM, and
        the midpoint concentration of Individual Standard Mixtures A and B.

C.      Criteria:

        1.      An instrument blank and the PEM must bracket one end of a 12-hour period during which
               samples are analyzed, and a second instrument blank and the midpoint concentration of
               Individual Standard Mixtures A and B must bracket the other end of the 12-hour period.

        2.      The resolution between any two adjacent peaks in the midpoint concentration of Individual
               Standard Mixtures A and B must be greater than or equal to 90.0 percent.

        3.      The absolute retention time for each single component pesticide and surrogate in the
               midpoint concentration of Individual Standard Mixtures A and B must be within the
               retention time windows determined from the initial calibration.

        4.      The percent difference between the calculated amount and the true amount for each of the
               pesticides and surrogates in the  midpoint concentration of the Individual Standard Mixtures
               A and B must not exceed + 25.0 percent.

D.      Evaluation:

        1.      Check the Form VIII PEST [Form VIIILCP] to verify that the instrument blanks, PEMs, and
               Individual Standard Mixtures were analyzed at the proper frequency and that no more than
               12:00 hours was elapsed between continuing calibration brackets in an ongoing analytical
               sequence.

        2.      Check Forms VI-6  and 7, and the data for the midpoint concentration of Individual Standard
               Mixtures A and B to verify that the resolution between any two adjacent peaks is greater
               than or equal to 90.0 percent.
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        3.      Check the data for each of the single component pesticides and surrogates in the midpoint
               concentration of Individual Standard Mixtures A and B and Form VII PEST-2 [Form VII
               LCP-2] to verify that the absolute retention times are within the appropriate retention time
               windows.

        4.      Check the data from the midpoint concentration of Individual Standard Mixtures A and B
               and Form VII PEST-2 [Form VIILCP-2] to verify that the percent difference between the
               calculated amount and the true amount for each of the pesticides and surrogates (must be
               within + 25).
E.      Action:
        1.      If the continuing calibration sequence was not followed as required, then professional
               judgement must be used to evaluate the effect of the non-compliance on the sample data. If
               the requirements for the continuing calibration sequence were not met, then this should be
               noted for TPO action. If the non-compliance has a potential effect on the data, then the data
               should be qualified according to the professional judgement of the reviewer and this should
               be noted in the data review narrative.

        2.      If resolution criteria are not met, then the quantitative results may not be accurate due to
               inadequate resolution. Positive sample results for compounds that were not adequately
               resolved should be qualified with "J".  Qualitative identifications may be questionable if
               coelution exists.  Non-detected target compounds that elute in the region of coelution may
               not be valid depending on the extent of the coelution problem. Professional judgement
               should be used to qualify data as unusable (R).

        3.      Retention time windows are used in qualitative identification. If the standards do not fall
               within the retention time windows, the associated sample results should be carefully
               evaluated. All samples injected after the last in-control standard are potentially affected.

               a.      For the affected samples, check to see if the sample chromatograms contain any
                       peaks that are close to the expected retention time window of the pesticide of
                       interest. If no peaks are present either within or close to the retention time window
                       of the deviant target pesticide compound, then non-detected values can be
                       considered valid. Sample data that is potentially affected by the standards not
                       meeting the retention time windows should be noted in the data review narrative.  If
                       the retention time window criteria are grossly exceeded, then this should be noted
                       for TPO action.

               b.      If the affected sample chromatograms contain peaks which may be of concern (i.e.,
                       above the CRQL and either close to or within the expected retention time window of
                       the pesticide of interest), then the reviewer should follow the guidelines provided in
                       Pesticide Section III. E. 3 to determine the extent of the effect on the data.
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        4.       If the percent difference is greater than 25% for the compound(s) being quantified, qualify
                all associated positive quantitative results with "J" and the sample quantitation limits for
                non-detects with "UJ".

        5.       Potential effects on the sample data due to problems with calibration should be noted in the
                data review narrative.
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                                            V.  Blanks
A.      Review Items: Form I PEST [Form ILCP], Form IV PEST [Form IVLCP], chromatograms, and
        data system printouts.

B.      Objective:

        The purpose of laboratory (or field) blank analyses is to determine the existence and magnitude of
        contamination problems resulting from laboratory (or field) activities. The criteria for evaluation of
        laboratory blanks apply to any blank associated with the samples (e.g., method blanks, instrument
        blanks, and sulfur cleanup blanks).  If problems with any blank exist, all associated data must be
        carefully evaluated to determine whether or not there is an inherent variability in the data, or if the
        problem is an isolated occurrence not affecting other data.

C.      Criteria:

        1.      No contaminants should be present in the blanks.

        2.      Method Blanks

               a.     A method blank analysis must be performed for each 20 samples of similar matrix
                      in each sample delivery group (SDG) or whenever a sample extraction procedure is
                      performed.  The method blank should be analyzed on each GC system used to
                      analyze that set of associated samples.

        3.      Instrument Blanks

               a.     An acceptable instrument blank must be run at least once every 12 hours and
                      immediately prior to the analysis of either the performance evaluation mixture or
                      Individual Standard Mixtures A and B, depending on the position in the analytical
                      sequence.

        4.      Sulfur Cleanup Blanks

               a.     A sulfur cleanup blank must be analyzed whenever part of a set of samples
                      extracted together requires sulfur cleanup. If the entire  set of samples associated
                      with a method blank requires sulfur cleanup, then the method blank also serves the
                      purpose of a sulfur blank and no separate sulfur blank is required. The sulfur
                      cleanup blank should be analyzed on each GC system used to analyze the associated
                      samples.
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D.     Evaluation:
        1.      Review the results of all associated blanks, Form I PEST [Form ILCP] and Form IV PEST
               [Form IVLCP], and raw data (chromatograms and data system printouts) to evaluate
               presence of target or non-target analytes in the blanks.

        2.      Verify that method blank analysis has been reported per SDG, per matrix, per concentration
               level, for each GC system used to analyze samples, and for each extraction batch.  The
               reviewer can use Form IV PEST [Form IVLCP] to assist in identifying samples associated
               with each blank.

        3.      Verify that the method blank analysis(es) contains less than the Contract Required
               Quantitation Limit (CRQL) of any target pesticide or Aroclor/Toxaphene or any interfering
               peak.

        4.      Verify that the instrument blank analysis has been performed every 12 hours as the first
               analysis of the continuing calibration sequence.  All acceptable sample analysis are to be
               bracketed by acceptable instrument blanks. Additionally, the instrument blank must follow
               sample analysis which contain an analyte at high concentration. Evaluate the results from
               the various instrument blanks to verify that they do not contain any target analytes above
               one-half the CRQL values for water samples (assuming a 1-L extraction of a water sample).

        5.      Verify that the sulfur cleanup blanks were analyzed at the required frequency and that
               (assuming a  1-L extraction of a water sample) the sulfur blanks do not contain any target
               compound above the CRQL.  If a separate sulfur cleanup blank was prepared, one version of
               Form IV PEST [Form IVLCP] should be completed associating all the samples with the
               method blank, and a second version of Form IV PEST [Form IVLCP] should be completed
               listing only those samples associated with the separate sulfur cleanup blank.
E.     Action:
       If the appropriate blanks were not analyzed with the frequency described in the previous PEST
       Section V. C., then the data reviewer should use professional judgement to determine if the
       associated sample data should be qualified.  The reviewer may need to obtain additional information
       from the laboratory. The situation should be brought to the attention of the TPO.

       Action in the case of unsuitable blank results depends on the circumstances and the origin of the
       blank. Detected compounds should be reported unless the concentration of the compound in the
       sample is less than or equal to 5 times (5x) the amount in any blank.  In instances where more than
       one blank is associated with a given sample, qualification should be based upon a comparison with
       the associated blank having the highest concentration of a contaminant.  The results must not be
       corrected by subtracting the blank value.
        Specific actions are as follows:
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1.       If a target pesticide or Aroclor/Toxaphene is found in the blank but not found in the
        sample(s), no qualification is required. If the contaminants found are at levels significantly
        greater than the CRQL, then this should be noted in for TPO action.

2.       Any pesticide or Aroclor/Toxaphene detected in the sample, that was also detected in any
        associated blank, is qualified if the sample concentration is less than five times (5x) the
        blank concentration.  The quantitation limit may also be elevated. Typically, the sample
        CRQL is elevated to the concentration found in the sample.  The reviewer should use
        professional judgement to determine if further elevation of the CRQL is required.

        The reviewer should note that analyte concentrations calculated for method, sulfur, or
        instrument blanks may not involve the same weights, volumes or dilution factors as the
        associated samples. These factors must be taken into consideration when applying the "5x"
        criteria, such that a comparison of the total amount of contamination is actually made.

        Additionally, there may be instances when little or no contamination was present in the
        associated blanks, but qualification of the sample was deemed necessary.  Contamination
        introduced through dilution is one example.  Although it is not always possible to determine,
        instances of this occurring can be detected when contaminants are found in the diluted
        sample result, but absent in the undiluted sample result.  Since both results are not routinely
        reported, it may be impossible to verify this source of contamination. However, if the
        reviewer determines that the contamination is from a source other than the sample, he/she
        should qualify the data.  In this case, the  "5x" rule does not apply; the sample value should
        be reported as a non-detected target compound, "U". An explanation of the rationale for this
        determination should be provided in the narrative.

3.       If gross contamination exists (e.g., saturated peaks, "hump-o-grams", "junk" peaks), all
        affected  compounds in the associated samples should be qualified as unusable (R), due to
        interference. This  should be noted in the data review narrative, and as a TPO action item if
        the contamination is suspected of having an effect on the sample results.

4.       If inordinate amounts of target pesticides, Aroclors/Toxaphene, or other interfering non-
        target compounds are found at low levels in the blank(s), it may be indicative of a problem at
        the laboratory and  should be noted for TPO action.
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        5.      If an instrument blank was not analyzed following a sample analysis which contained an
               analyte(s) at high concentration(s), sample analysis results after the high concentration
               sample must be evaluated for carryover. Professional judgement should be used to
               determine if instrument cross-contamination has affected any positive compound
               identification(s), and if so, detected compound results should be qualified.  If instrument
               cross-contamination is suggested, then this should be noted in the data review narrative, and
               for TPO action, if the cross-contamination is suspected of having an affect on the sample
               results.

        The following are examples of applying the blank qualification guidelines.

               Example 1:     Sample result is greater than the CRQL, but is less than the 5x multiple of
                              the blank result.

                                                                    5x

                                     Blank Result                  1.0
                                     CRQL                        0.5
                                     Sample Result                 4.0
                                     Qualified Sample Result        4.0U

                                     In this case, sample results less than 5.0 (or 5x1.0) would be
                                     qualified as non-detected target compounds.
               Example 2:     Sample result is less than the CRQL, and is also less than the 5x multiple of
                              the blank result.

                                                                   5x

                                     Blank Result                  1.0
                                     CRQL                        0.5
                                     Sample Result                 0.4J
                                     Final Sample Result            0.5U
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Example 3:     Sample result is greater than the 5x multiple of the blank result.

                                                    5x

                      Blank Result                   1.0
                      CRQL                         0.5
                      Sample Result                 10.0
                      Qualified Sample Result        10.0

                      In this case, the sample result exceeded the adjusted blank result (5
                      x 1.0) and the sample result is not qualified.
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                                       VI.  Surrogate Spikes
A.      Review Items: Form II PEST [Form IILCP], Form VIII PEST [Form VIIILCP], chromatograms,
        and data system printouts.

B.      Objective:

        Laboratory performance on individual samples is established by means of spiking samples prior to
        extraction and analysis to determine surrogate spike recoveries. All samples are spiked with
        surrogate compounds prior to sample extraction. The evaluation of the recovery results of these
        surrogate spikes is not necessarily straightforward. The sample itself may produce effects due to
        such factors as interferences and high concentrations of target and/or non-target analytes. Since the
        effects of the sample matrix are frequently outside the control of the laboratory and may present
        relatively unique problems, the evaluation and review of data based on specific sample results is
        frequently subjective and demands analytical experience and professional judgment.  Accordingly,
        this section consists primarily of guidelines, in some cases with several optional approaches
        suggested.

C.      Criteria:

        1.      Two surrogate spikes, tetrachloro-m-xylene and decachlorobiphenyl, are added to all
               samples, Individual Standard Mixtures, PEMs, blanks, and matrix spikes to measure their
               recovery in sample and blank matrices.

        2.      The limits for recovery of the surrogates tetrachloro-m-xylene (TCX) and
               decachlorobiphenyl (DCB) are 30-150 percent for both water and soil samples.

        3.      The retention times of both of the surrogates in the PEM, Individual Standard Mixtures, and
               samples must be within the calculated retention time windows. TCX must be within + 0.05
               minutes, and DCB must be within + 0.10 minutes of the mean retention time determined
               from the initial calibration .

D.      Evaluation:
        1.      Check the raw data (e.g., chromatograms and data system printouts) to verify that the
               recoveries on the Surrogate Recovery Form II PEST [Form IILCP] are calculated and
               transcribed correctly.

        2.      If recoveries are not within limits, check the raw data for possible interferences which may
               have affected surrogate recoveries. If low surrogate recoveries are observed, the reviewer
               should investigate whether the low recoveries were a result of sample dilution.
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        3.      Check the raw data (e.g., chromatograms and data system printouts) to verify that the
               retention times on Form VIII PEST [Form VIIILCP] are accurate and within retention time
               windows.

        4.      If retention times were not met, check the raw data for possible mis-identification of GC
               peaks. Non-recovery of surrogates may also be due to shifts in retention times.
E.      Action:
        1.      If either surrogate spike recovery is outside of advisory limits, the following guidance is
               suggested. Professional judgement must be used in applying these criteria, as
               surrogate recovery problems may not directly apply to target analytes.

               a.      If low recoveries (i.e., between 10 and 30 percent) are obtained, associated detected
                       compounds should be qualified "J" and quantitation limits  "UJ".

               b.      If high recoveries (i.e., greater than 150%) are  obtained, this may be an indication of
                       a high bias due to co-eluting interferences. Using professional judgement, qualify
                       associated detected compound data with "J", non-detected analytes do not require
                       qualification.

               c.      If either pesticide surrogate recovery is reported as between 0% and 10%, the
                       reviewer should examine the sample chromatogram to assess the qualitative validity
                       of the analysis. If low surrogate recoveries are found to be due to sample dilution,
                       then professional judgement should be used to determine if the resulting data should
                       be qualified. If sample dilution is not a factor,  then detected target compounds may
                       be qualified "J" and non-detected target compound results should be qualified
                       unusable (R).

               d.      If zero pesticide surrogate recovery is reported, the reviewer should examine the
                       sample chromatogram to determine if the surrogate may be present, but slightly
                       outside its retention time window. If this is the case, in addition to assessing
                       surrogate recovery  for quantitative bias, the overriding consideration is to
                       investigate the qualitative validity of the analysis. If the surrogate is not present,
                       qualify all nondetected target compounds as unusable (R).

        2.      If surrogate retention times  in PEMs, individual standards, samples, and blanks are outside
               of the retention time limits,  qualification of the data is left up to the professional judgement
               of the reviewer.  Refer to Pesticide Section II. E.2 for more guidance.
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        3.      In the special case of a blank analysis with surrogates out of specification, the reviewer must
               give special consideration to the validity of associated sample data. The basic concern is
               whether the blank problems represent an isolated problem with the blank alone, or whether
               there is a fundamental problem with the analytical process.  For example, if one or more
               samples in the batch show acceptable surrogate recoveries, the reviewer may choose to
               consider the blank problem to be an isolated occurrence.  Data is qualified on the
               professional judgement of the reviewer.

        4.      Extreme or repeated analytical problems with surrogate recoveries should be noted for TPO
               action.

        5.      If possible, the impact on the data resulting from surrogate recoveries not meeting the
               advisory limits, should be noted in the data review narrative.
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                           VII.  Matrix Spikes/Matrix Spike Duplicates
                         (Not Required for Low Concentration Water Data)
A.     Review Items:  Form III PEST-1 and PEST-2, chromatograms, and data system printouts.

B.     Objective:

       Data for matrix spikes (MS) and matrix spike duplicates (MSD) are generated to determine long-
       term precision and accuracy of the analytical method on various matrices. These data alone cannot
       be used to evaluate the precision and accuracy of individual samples. However, when exercising
       professional judgement, MS/MSD data should be used in conjunction with information on other
       deficiencies.

C.     Criteria:

       1.      Matrix spikes (MS) and matrix spike duplicate (MSD) samples are analyzed at a frequency
               of at least one MS and MSD per 20 samples of each matrix.

       2.      Matrix spike recoveries should be within the advisory limits provided on Form III PEST-1
               and PEST-2.

       3.      Relative percent difference (RPD) between MS and MSD recoveries should be within the
               advisory limits provided on Form III PEST-1 and PEST-2.

D.     Evaluation:

       1.      Verify that MS  and MSD samples were analyzed at the required frequency and that results
               are provided for each sample matrix.

       2.      Check the raw data and Forms III PEST-1 and PEST-2 to verify that the results for matrix
               spike recoveries were calculated and transcribed correctly.

       3.      Check the raw data and Forms III PEST-1 and PEST-2 to verify that the matrix spike
               Relative Percent Difference (RPD) was calculated and transcribed correctly.

       4.      Compare %RSD results of non-spiked compounds between the original result, MS, and
               MSD.

E.     Action:

       1.      No action is taken on MS/MSD data alone. However, using informed professional judgment
               the data reviewer may use the MS and MSD results in conjunction with other QC criteria and
               determine the need for some qualification of the data.
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       2.      The data reviewer should first try to determine to what extent the results of the MS/MSD
               affect the associated sample data. This determination should be made with regard to the
               MS/MSD sample itself, as well as specific analytes for all samples associated with the
               MS/MSD.

       3.      In those instances where it can be determined that the results of the MS/MSD affect only the
               sample spiked, then qualification should be limited to this sample alone. However, it may be
               determined through the MS/MSD results that a laboratory is having a systematic problem  in
               the analysis of one or more analytes, which affects all associated samples. For example, if
               the recoveries for MS and MSD are consistently low for both water and soil samples, this
               could be indicative of a systematic problem in the laboratory and recoveries should be
               examined in all associated samples.

       4.      The reviewer must use professional judgement to determine the need for qualification of
               positive results of non-spiked compounds.
       NOTE:        If a field blank was used for the MS/MSD, unless designated as such by the Region,
                      the TPO must be notified.
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                                  VIII.  Laboratory Control Samples
                                        (Low Concentration Water)
[A.     Review Items: Form ILCP, Form III LCP, LCS chromatograms and data system printouts.

B.      Objective:

        Data for laboratory control samples (LCS) are generated to provide information on the accuracy of the
        analytical method and the laboratory performance.

C.      Criteria:

        1.       Laboratory control samples are analyzed at a frequency of once per SDG.

        2.       The LCS contains the following pesticides: gamma-BHC, heptachlor epoxide, dieldrin, 4,4j-DDE,
                endrin, endosulfan sulfate, and gamma-chlordane, in addition to the two required surrogates.

        3.       The percent recoveries for the LCS compounds must be within the QC limits provided on Form III
                LCP. The LCS must meet the recovery criteria for the sample data to be accepted.

        4.       The criteria for surrogate recovery and target compound identification also apply.

D.      Evaluation:

        1.       Verify that LCS samples were analyzed at the re quired frequency.

        2.       Verify that the LCS recoveries reported on Form III LCP are within the QC limits.

        3.       Check that the LCS recoveries were calculated correctly.

        4.       Verify transcriptions from raw data to Forms I and III LCP.

E.      Action:

        If the LCS criteria are not met, then the laboratory performance and method accuracy are in question.
        Professional judgement should be used to determine if the data should be qualified or rejected. The
        following guidance is suggested for qualifying sample data for which the associated LCS does not meet the
        required criteria.

        1.       Action on the LCS recovery should be based on both the number of compounds that are outside of
                the recovery criteria and the magnitude of the noncompliance.
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        2.       If the LCS recovery criteria are not met, then the LCS results should be used to qualify sample data
                for the specific compounds that are included in the LCS solution. If the LCS recovery exceeds the
                upper acceptance limit, detected target compounds may be qualified "J". If the LCS recovery
                exceeds the lower acceptance limit, detected target compounds may be qualified "J" and non-
                detects may be qualified unusable (R).  Professional judgement should be used to qualify data for
                compounds other than those compounds that are included in the LCS.  Professional judgement to
                qualify non-LCS compounds should take into account the compound class,  compound recovery
                efficiency, analytical problems associated with each compound, and comparability in performance
                of the LCS compound to the non-LCS compound.

        3.       If more than half of the compounds in the LCS are not within the recovery criteria, then all of the
                associated detected target compounds may be qualified "J" and all associated non-detected target
                compounds may be qualified unusable (R).

        4.       It should be noted for TPO action if a laboratory fails to analyze an LCS with each SDG, or if the
                reviewer has knowledge that a laboratory consistently fails to generate acceptable LCS recoveries.]
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                       IX.  Regional Quality Assurance and Quality Control


A.     Review Items:  Form I PEST [Form ILCP], chromatograms, data system printouts, traffic reports
       and raw data for Regional QC samples.

B.     Objective:

       Regional Quality Assurance and Quality Control (QA/QC) refers to any QA and/or QC initiated by
       the Region, including field duplicates, Regional Performance Evaluation (PE) samples, blind spikes,
       and blind blanks.  (It is highly recommended that Regions adopt the use of these QA/QC samples.)

C.     Criteria:

       Criteria are determined by each Region.

       1.      Performance evaluation sample frequency may vary.

               [For data generated through the Low Concentration method: A performance evaluation (PE)
               sample can be included as frequently as once per SDG.J

       2.      The analytes present in the PE sample must be correctly identified and quantified.

D.     Evaluation:

       Evaluation procedures must follow the Region's SOP for data review. Each Region will handle the
       evaluation of PE samples on an individual basis. Results for PE samples should be compared to the
       acceptance criteria for the specific PE samples, if available.

E.     Action:

       Any action must be in accordance with Regional specifications and the criteria for acceptable PE
       sample results.  Unacceptable results for PE samples  should be noted for TPO action.
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                                   X.  Pesticide Cleanup Checks
A.      Review Items:  Form IX PEST-1 and 2 [Form IXLCPJ,  GPC/Florisil raw data, chromatograms, and
        data system printouts.

B.      Objective:

        Pesticide cleanup procedures are utilized to remove matrix interferences from sample extracts prior
        to analysis.  The use of the Florisil cartridge cleanup procedure significantly reduces matrix
        interferences caused by polar compounds. Gel permeation chromatography (GPC) is used to remove
        high molecular weight contaminants that can interfere with the analysis of target analytes. Pesticide
        cleanup procedures are checked by spiking the cleanup columns and cartridges, and verifying the
        recovery of pesticides through the cleanup procedure.

C.      Criteria:

        1.      Florisil Cartridge Cleanup

               a.       Florisil cartridges must be used for the cleanup of all sample extracts.

               b.       Every lot number of Florisil cartridges used for sample cleanup must be checked by
                       spiking with 2,4,5-trichlorophenol and the midpoint concentration of Individual
                       Standard Mixture A.

               c.       The lot of Florisil cartridges is acceptable if the recoveries for all of the pesticides
                       and surrogates in Individual Standard Mixture A are within 80 to 120 percent, if the
                       recovery of 2,4,5-trichlorophenol is less than 5 percent, and if no peaks interfering
                       with the target analytes are detected.

        2.      Gel Permeation Chromatography (GPC)

               a.       GPC is used for the cleanup of all soil sample extracts and for water sample extracts
                       that contain high molecular weight components that interfere with the analysis of the
                       target analytes.

               b.       At least once every 7 days, the calibration of the GPC unit must be checked by
                       spiking with two check mixtures: the matrix spiking solution and a mixture of
                       Aroclors 1016 and  1260.

               c.       The GPC calibration is acceptable if the recovery of the pesticides in the matrix
                       spiking solution are within 80 to 110 percent, and the Aroclor patterns should match
                       those generated for previously run standards.
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               d.      A GPC blank must be analyzed after each GPC calibration and is acceptable if the
                      blank does not exceed one-half the CRQL for any target analytes.

D.     Evaluation:

       1.      Florisil Cartridge Check

               Check the data from the Florisil cartridge solution analyses and the Form IX PEST-1 [Form
               IXLCP].  Recalculate some of the percent recoveries to verify that the percent recoveries of
               the pesticides and surrogates in Individual Standard Mixture A are within 80-120%, the
               recovery  of 2,4,5-trichlorophenol is less than 5%, and no interfering peaks are present.
               Compare the raw data to the reported results and verify that no calculation or transcription
               errors have occurred.

       2.      Gel Permeation Chromatography (GPC)

               Check the data from the GPC calibration check analyses and the Form IX PEST-2 and
               recalculate some of the percent recoveries to verify that the percent recoveries of the
               pesticides in the matrix spike solution are within 80-110%  and that the Aroclor patterns are
               similar to those of previous standards.  Aroclor pattern comparison within a laboratory can
               be checked if more than one GPC calibration was performed in for that SDG. The Region
               may devise other means to compare this information. Check to make sure that no
               transcription errors have occurred.

E.     Action:

       1.      If Florisil Cartridge Check criteria are not met, the raw data should be examined for the
               presence  of polar interferences and professional judgement should be used in qualifying the
               data. If a laboratory analyzes samples under an unacceptable Florisil Cartridge Check, then
               the TPO should be notified.

       2.      If Gel Permeation Criteria are not met, the raw data should  be examined for the presence of
               high molecular weight contaminants, subsequent sample data should be examined for
               unusual peaks, and professional judgement should be used  in qualifying the data. If a
               laboratory chooses to analyze samples under unacceptable Gel Permeation Criteria, then the
               TPO should be notified.

       3.      If zero recovery was obtained for the pesticide compounds  and surrogates during either
               check, then the non-detected target compounds may be suspect and the data may be qualified
               unusable  (R).
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               If high recoveries (i.e., greater than 120%) were obtained for the pesticides and surrogates
               during either check, use professional judgement to qualify detected target compounds. Non-
               detected target compounds do not require qualification.

               Potential effects on the sample data resulting from the pesticide cleanup analyses not
               yielding acceptable results should be noted in the data review narrative.
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                              XL  Target Compound Identification
A.     Review Items:  Form I PEST [Form ILCP], Form X PEST-1 and PEST-2 [Form XLCP-1] and LCP-
       2], chromatograms, and data system printouts.

B.     Objective:

       Qualitative criteria for compound identification have been established to minimize the number of
       false positives (reporting a compound present when it is not) and false negatives (not reporting a
       compound that is present).

C.     Criteria:

       1.      The retention times of both of the surrogates, matrix spikes, and reported compounds in each
               sample must be within the calculated retention time windows on both columns.  TCX must
               be within ± 0.05 minutes of the mean retention time determined from the initial calibration
               and DCB must be within ±0.10 minutes of the mean retention time determined from the
               initial calibration.

       2.      GC/MS confirmation is required if the concentration of a compound exceeds 10 ng/uL in the
               final sample extract. Pesticides that are confirmed by GC/MS should be identified with a
               "C" in the Q column on Form I PEST [Form ILCP].

       3.      When no analytes are identified in a sample, the chromatograms from the analyses of the
               sample extract must use the same scaling factor as was used for the low point standard of the
               initial calibration associated with those analyses.

       4.      Chromatograms must display single component pesticides detected in the sample and the
               largest peak of any multicomponent analyte detected in the sample at less than full scale.

       5.      If an extract must be diluted, chromatograms must display single component pesticides
               between 10 and  100 percent of full scale, and multicomponent analytes between 25 and 100
               percent of full scale.

       6.      For any sample, the baseline of the chromatogram must return to below 50 percent of full
               scale before the elution time of alpha-BHC, and also return to below 25 percent of full scale
               after the elution time of alpha-BHC and before the elution time of decachlorobiphenyl.

       7.      If a chromatogram is replotted electronically to meet these requirements, the scaling factor
               used must be displayed on the chromatogram, and both the initial chromatogram and the
               replotted chromatogram must be submitted in the data package.
D.     Evaluation:
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        1.      Review Form I PEST [Form ILCPJ, the associated raw data (chromatograms and data
               system printouts) and Form X PEST-1 and PEST-2 [FormXLCP-1 andLCP-2].  Confirm
               reported detected analytes by  comparing the sample chromatograms to the tabulated results
               and verifying peak measurements and retention times.  Confirm reported non-detected
               analytes by a review of the sample chromatograms. Check the associated blank data for
               potential interferences (to evaluate sample data for false positives) and check the calibration
               data for adequate retention time windows (to evaluate sample data for false positives and
               false negatives).

        2.      For multi-component target compounds (Toxaphene and Aroclors), the retention times and
               relative peak height ratios of major component peaks should be compared against the
               appropriate standard chromatograms.

        3.      Verify that GC/MS confirmation was performed for pesticide concentrations in the final
               sample extract which exceeded 10 ng/uL.
E.     Action:
        1.      If the qualitative criteria for both columns were not met, all target compounds that are
               reported detected should be considered non-detected.  The reviewer may need to use the
               qualifiers that are specific to pesticides. The reviewer should use professional judgement to
               assign an appropriate quantitation limit using the following guidance:

               a.      If the misidentified peak was sufficiently outside the target pesticide retention time
                      window, then the reported values may be a false positive and should be replaced
                      with the sample CRQL value.

               b.      If the misidentified peak poses an interference with potential detection of a target
                      peak, then the reported value should be considered and qualified as unusable (R).

        2.      If the data reviewer identifies a peak in both GC column analyses that falls within the
               appropriate retention time windows, but was reported as a non-detect, then the compound
               may be a false negative. Professional judgement should be used to decide if the compound
               should be included. All conclusions made regarding target compound identification should
               be included in the data review narrative.
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3.       If multi-component target compounds exhibit marginal pattern-matching quality,
        professional judgement should be used to establish whether the differences are due to
        environmental "weathering" (i.e., degradation of the earlier eluting peaks relative to the later
        eluting peaks).  If the presence of a multi-component pesticide is strongly suggested, results
        should be reported as presumptively present (N).

        If an observed pattern closely matches more than one Aroclor, professional judgement
        should be used to decide whether the neighboring Aroclor is a better match, or if multiple
        Aroclors are present.

4.       If GC/MS confirmation was required but not performed, the reviewer should report this for
        TPO action.
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                       XII.  Compound Ouantitation and Reported CRQLS
A.      Review Items: Form I PEST [Form ILCPJ, Form X PEST-1 and PEST-2 [Form XLCP-1 andLCP-
        2], sample preparation log sheets, chromatograms, case narrative, and data system printouts.

B.      Objective:

        The objective is to ensure that the reported quantitative results and contract required quantitation
        limits (CRQLs) are accurate.

C.      Criteria:

        Compound quantitation, as well as the adjustment of the CRQL, must be calculated according to the
        equations provided in Section D/Pest of the Statement of Work.

D.      Evaluation:

        1.      Raw data should be examined to verify the correct calculation of all sample results reported
               by the laboratory.  Data system printouts, chromatograms, and sample preparation log sheets
               should be compared to the reported positive sample results and quantitation limits. Verify
               that the sample values are reported correctly.

        2.      Verify that the CRQLs have been adjusted to reflect all sample dilutions, concentrations,
               splits, clean-up activities, and dry weight factors that are not accounted for by the method.

E.      Action:

        1.      Quantitation limits affected by large, off-scale peaks should be qualified as unusable (R).  If
               the interference is on-scale, the reviewer can provide an approximated quantitation limit (UJ)
               for each affected compound.
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NOTE:        Single-peak pesticide results are checked for rough agreement between quantitative
               results obtained on the two GC columns. The potential for co-elution should be
               considered and the reviewer should use professional judgment to decide whether a
               much larger concentration obtained on one column versus the other indicates the
               presence of an interfering compound.  If an interfering compound is indicated,
               professional judgement must be used to determine how best to report, and if
               necessary, qualify the data.  Contractually the lower of the two values is reported.

2.       If there are any discrepancies found, the laboratory may be contacted by the designated
        representative to obtain additional information that could resolve any differences. If a
        discrepancy remains unresolved, the reviewer must decide which value is the best value.
        Under these circumstances, the reviewer may determine if qualification of the data is
        warranted. A description of the reasons for data qualification and the qualification that is
        applied to the data should be documented in the data review narrative.
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                                     XIII.  Overall Assessment
A.      Review Items:  Entire data package, data review results, and (if available) Quality Assurance Project
        Plan (QAPjP), and Sampling and Analysis Plan (SAP).
B.      Objective:

        The overall assessment of a data package is a brief narrative in which the data reviewer expresses
        concerns and comments on the quality and, if possible, the useability of the data.
C.      Criteria:

        Assess the overall quality of the data.

        Review all available materials to assess the overall quality of the data, keeping in mind the additive
        nature of analytical problems.


D.      Evaluation:

        1.      Evaluate any technical problems which have not been previously addressed.

        2.      If appropriate information is available, the reviewer may assess the useability of the data to
               assist the data user in avoiding inappropriate use of the data. Review all available
               information, including the QAPjP (specifically the Data Quality Objectives), SAP, and
               communication with data user that concerns the intended use and desired quality of the data.


E.      Action:

        1.      Use professional judgement to determine if there is any need to qualify data which were not
               qualified based on the QC criteria previously discussed.

        2.      Write a brief narrative to give the user an indication of the analytical limitations of the data.
               Any inconsistency of that data with the SDG Narrative should be noted for TPO action. If
               sufficient information on the intended use and required quality of the data are available, the
               reviewer should include his/her assessment of the useability of the data within the given
               context.
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