xvEPA
              United States
              Environmental Protection
              Agency
              Office of
              Research and Development
              Washington DC 20460
EPA 540 P-91 002
January 1991
              Superfund
User's Guide to the
Contract Laboratory
Program

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                                              9240.0-01 D
                                          EPA/540/P-91/002
                                             January 1991
User's Guide to the Contract  Laboratory
                     Program
            Office of Emergency and Remedial Response
               U.S. Environmental Protection Agency
                   Washington, DC 20460
                                        Printed on Recycled Paper

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Additional copies of this document can be  obtained
from:
         USEPA Sample Management Office
                  P.O. Box 818
               Alexandria, VA 22313
NOTICE: The policies and procedures set forth here are
intended as guidance to Agency and other government
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.
                        11

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                             TABLE OF CONTENTS
FOREWORD	vii

CHAPTER 1	1
   A.  CLP Objective and Orientation	1
   B.  CLP Structure	1

CHAPTER II	6
   A.  Organic Routine Analytical Services	8
   B.  Inorganic Routine Analytical Services	8
   C.  Dioxin/Furan Routine Analytical Services	8
   D.  Special Analytical Services	8
   E.  Analytical Methodology Improvement/Development	18

CHAPTER III	,19
   A.  Analysis Request Procedures	19
   B.  Regional Organic/Inorganic Allocation System	23
   C.  Sample Documentation	23
   D.  Sample Packaging and Shipment	25
   E.  Procedures for Problem Resolution	26

CHAPTER IV	28
   A.  Shipment Management Program	28
   B.  Information Services	28
   C.  Enforcement  Support	29
   D.  Cost Recovery Substantiation	31
   E.  Contract Compliance Screening (CCS)	31
   F.  Data Review Services	31

CHAPTER V	33
   A.  Laboratory  Selection Process	33
   B.  Laboratory Startup Process	34
   C.  Laboratory  Performance  Evaluation	35
                                         in

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 CHAPTER  VI	•	36
    A. Laboratory Quality Control Criteria	36
    B. Analytical Data  Review	39
    C. Laboratory Evaluation Samples	•	40
    D. GC/MS Tape Audits	41
    E. On-Site Laboratory Evaluations	41
    F. Quality Assurance and Data Trend Analysis	42
    G. Data Management	43

 APPENDIX A	45

 APPENDIX  B	47
    National Program Office	47
    Sample  Management  Office	49
    USEPA Region I	50
    USEPA Region II	51
    USEPA  Region III	52
    USEPA  Region IV	53
    USEPA Region V	54
    USEPA  Region VI	..55
    USEPA Region VII	56
    USEPA Region VIII	57
    USEPA Region IX	58
    USEPA Region X	59
    Miscellaneous Information	60
    Regional Sample Control Centers	61
    Regional Technical Project Officers	62

 APPENDIX   C	63
    Analytical References	63
    Quality Assurance References	64
    Safety References	65
    Sampling References	65
    Shipping References	65

INDEX	67
                                            IV

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                                  LIST  OF FIGURES
Figure 1.   Relationship of CLP Principals	2
Figure 2.   Relationship of Other CLP Offices	2
Figure 3.   Routine Analytical Services	6
Figure 4.   Special Analytical Services	7
FigureS.   Organic Routine Analytical Services, Multi-Media, Multi-Concentration	9
Figure 6.   Organic Routine Analytical Services, Low Concentration Water	10
Figure 7.   Organic Routine Analytical Services, Low Concentration Water - Volatiles Only....11
FigureS.   Organic Routine Analytical Services, Multi-Media, High Concentration	12
Figure 9.   Inorganic Routine Analytical Services, Multi-Media, Multi-Concentration	13
Figure 10.  Inorganic Routine Analytical Services, Low Concentration Water	14
Figure 11.  Inorganic Routine Analytical Services, Multi-Media, High Concentration	15
Figure 12.  Dioxin/Furan Routine  Analytical Services	16
Figure 13.  RAS Analysis Request Procedures - User Information Required	20
Figure 13.  SAS Analysis Request Procedures - User Information Required	21
Figure 15.  Sample  Tag	24
Figure 16.  Additional CLP Enforcement Support	30
Figure 17.  Cost Recovery Substantiation	17
Figure 18.  Data Review Services	18
Figure 19.  The CLP  Laboratory Selection Process	33

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                                     FOREWORD
    This document has been prepared by the Contract Laboratory Program (CLP) Sample Management
Office (SMO) specifically for the guidance and direction of program clients.  The CLP User's Guide is
designed to clarify procedures for CLP analysis. The CLP User's Guide acts as a reference for the
Regions and laboratory contractors to promote consistency in procedures throughout the Regions and
ensure the proper adherence to CLP requirements. This document along with the CLP Sampler's Guide
provides a thorough overview of the CLP.
   Fifth Printing


   Issued: January 1991
                                          Vll

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                                     CHAPTER I

                    BACKGROUND AND INTRODUCTION
  In this chapter...
  CLP Objective and Orientation
  CLP Structure
    Clients/Users
    Regional Program Support
    Analytical and Support Services Contractors
A. CLP Objective and Orientation
    The Contract Laboratory Program (CLP) is
made up of contractor laboratories and supports
the Environmental Protection Agency's  (EPA)
Superfund effort.  It was begun under the 1980
Comprehensive  Environmental  Response,
Compensation, and Liability Act (CERCLA) and
continues under the 1986 Superfund Amendments
and Reauthorization Act  (SARA).  The CLP
provides  a range of state-of-the-art chemical
analytical services of known quality on a high
volume, cost effective basis. The CLP is structured
to provide legally  defensible analytical results
for use in supporting Agency enforcement actions.
The CLP can also meet other requirements of the
user community.  Quality assurance procedures and
documentation designed for the intended purposes
of the data are part of all program activities.
    Client orientation is a key factor in the design
and application of all CLP services and responses.
The CLP  supplies  analytical services in  direct
response to requests from the EPA Regions, the
primary users  of the program. States and other
Agency programs are also part of the CLP user
community.
    The CLP objective is to develop, manage and
improve its analytical programs in support of all
Superfund requirements. This is accomplished by
increasing analytical capacity and improving
analytical  program requirements  and related
support services.
B.  CLP Structure
    CLP  services  involve  numerous  Agency
programs, contractors and other groups throughout
the country. These organizations  are identified
and their role in the program described in the
following sections. Figures 1 and 2, "Relationship
of CLP Principals," and "Relationship of Other
CLP Offices," illustrate the interaction of these
groups in CLP operation. In addition, a directory
listing addresses and telephone numbers of key
program personnel is located in Appendix B.
1.  Clients/Users
a.  EPA Regions
    The ten EPA Regions are the primary clients
of the CLP.   Each Region has established  a
Regional Sample Control Center (RSCC)  that
schedules all Regional CLP analysis requests. The
RSCC balances Regional sampling with allocated
numbers of CLP sample analyses available  each
month and prioritizes the Region's  analytical
workload when conflicts occur. RSCC personnel
coordinate closely with the Sample Management
Office  (SMO) throughout  Regional  sampling
events, assisting in tracking sample shipments to
the laboratory and resolving any problems that
arise.   The  RSCC also processes  analytical
requests from state or other program users that are
located in the  Region's geographical area.
b.  States
    Any   state  undertaking   initial   site
investigations and  entering into  cooperative
agreements [under the Resource Conservation and
Recovery  Act (RCRA)- CERCLA Cooperative
Agreements] with the Government for clean up of
local waste sites can use CLP services. States  must
access CLP analytical services through the RSCC.
Data packages are also distributed  to states
through the RSCC.
c.  Non-Super fund Clients
    Program services  are available to support
Non-Superfund clients. Non-Superfund analyses
and  other support  are  provided by the  CLP
through transfer of funds from the Non-Superfund
program.  Non-Superfund clients currently include
other government agencies  and EPA  programs,
such as the Office of Acid Deposition, the Office
of Solid Waste, the Office of Water, and RCRA.

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   CLP User's Guide
FIGURE 1.  RELATIONSHIP OF CLP PRINCIPALS
                                                CLP Clients/Users
                                          I
                                                     RSCC
                                           Analyses Scheduling and Prioritlzatlon
                                                   National
                                                   Program
                                                     Office/
                                                    Sample
                                                 Management
                                                     Office
                                                    Scheduling
                                                    SAS
                                                    Contracts
                                                    Contract
                                                    Compliance
                                                    Screening
                                                    Audit
                                                    Reports
                                                    Data
                                                    Invoicing
                                              Contract  Laboratories
FIGURE 2. RELATIONSHIP OF OTHER CLP OFFICES
                            Regional
                             TPOs
                          • Problem
                           Resolution
                          1 Contract
                           Monitoring
                      Management Reportin
                     Program Admin. Support
                     SAS Work Assignments
                           Contract Status
                              RTP
                           Contracts
                           Contract
                           Procurement
                           Contract
                           Modifications
                         V.	J
  National
  Program
   Office/
   Sample
Management
   Office
                       EMSULV  ^
                      QA/QC
                      Protocol
                      Development
                      Standards
                      QA Database
Audit Reports
Lab/Method Performance Reports
                      Evidence
                      Audit Team
                     • Document
                      Audit
                      Contractor

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                                                       Chapter I - Background and Introduction
2.  Program Management

a.  National Program Office

    The CLP is directed by the National Program
Office (NPO), in EPA Headquarters Analytical
Operations Branch  (AOB),  Hazardous  Site
Evaluation Division (HSED),  Office  of  Solid
Waste  and Emergency  Response  (OSWER),
located  in  Washington, DC.   The  NPO  is
comprised of the AOB Branch Chief and Deputy
Branch   Chief,  the  Analytical   Methods
Implementation  Section (AMIS) Chief who also
serves as the National Program Manager, the
National Organics  Program  Manager  and
National Inorganics Program Manager, the
Regional Operations Section Chief, the Quality
Assurance Coordinator,  the  Data  Integrity
Specialist, the  SMO Project Officer, and the ADP
Officer.

    NPO responsibilities include:
    •  overall management of the CLP in terms of
       program objectives;
    •  expansion and interface with clients and
       other groups;
    •  policy and budget formation and
       implementation;
    •  development and administration of CLP
       analytical and support services contracts;
    -  development and technical review of
       analytical protocols;
    •  review of Special Analytical Services
       subcontracts;
    •  review of CLP-generated laboratory data;
    •  monitoring and formal evaluation of
       analytical and support contractors; and
    •  direction of CLP quality assurance in
       coordination with overall OSWER
       quality assurance activities.
    The  National Program Manager  (NPM)
assisted by the National Organics and Inorganics
Program Managers, in addition to directing the
AMIS section  staff, is  responsible  for the
formulation of CLP policies and  direction.  By
communicating  with Regional  and  Agency
communities on a continuing basis, the NPM keeps
all  parties apprised of  program  activities and
receives input on program effectiveness.  The NPM
and Organics and Inorganics Project Managers also
directs annual  technical caucuses for the purpose
of reporting initiatives and progress of the past
year. AMIS is also responsible for development of
sample  bottle specifications and  data  review
guidelines for all analytical services.
    The Regional Operations  Chief directs a staff
responsible for the Sample Management Office
contract, the Environmental  Services Assistance
Teams contracts, and the Shipment Management
contract.  In addition, the Regional Operations
Section  tracks  the supply and demand between
CLP capacity  and client needs, and provides
budget support and administration.  (Note: AMIS
manages this using information from ROS.)
    The Quality Assurance Coordinator manages
all aspects of program quality assurance needed to
provide information to the Branch  Chief and
Section Chiefs  to determine if management's QA
expectations/needs are being  met.  The  QA
Coordinator works closely  with  the Office of
Research  and  Development's  Environmental
Monitoring Systems Laboratory in Las Vegas
(ORD EMSL/LV) in administering and improving
the QA  program.  The QA Coordinator interacts
with  the APOs in  refining  and updating
analytical method QA. The QA Coordinator also
communicates with the Regions and other program
users to resolve QA issues related to analytical
data. For purposes of QA procedures review and
guidance  development,  the QA coordinator
conducts volunteer workgroups throughout the
year.

    The APOs  are responsible for administrative
and technical program decisions, contract
monitoring and contractor performance evaluation.
On a daily basis, the APOs work closely with the
Regional Technical Project Officers and contract
laboratories to resolve technical issues. The APOs
also direct the  continuing  effort to improve
contract language and to  develop analytical
methodologies.  For the purposes of CLP protocol
review,  method development, and QC  criteria
development,   the  APOs  conduct  volunteer
workgroups throughout the year.

    The Data Integrity Specialist is responsible
for implementing Good Automated Laboratory
Practices  into analytical services, developing
policy to protect the Government  from  alleged
fraud in the laboratory community, and heading
projects/workgroups focussing on the integrity of
Superfund analytical data.

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CLP User's Guide
b.  Sample Management Office
    The  contractor-operated  SMO  provides
management, operations  and  administrative
support to the CLP. The primary objective of SMO
is to maintain optimal use of program analytical
resources.  SMO activities fall into the following
areas:
    •  sample scheduling and tracking;
    •  Contract Compliance Screening;
    •  Special Analytical  Services
       subcontracting;
    •  laboratory invoice processing;
    •  maintenance of CLP records and
       management reporting;
    •  procurement/IFB support and statement of
       work production;
    •  coordinating CLP meetings and
       conferences; and
    •  NPO management, technical, and
       administrative support.
    SMO routinely receives Regional analytical
requests, coordinates  and schedules  sample
analyses, tracks  sample shipment and analyses,
receives  and  checks  data for completeness and
compliance, processes  laboratory invoices, and
maintains a repository of sampling records and
program data. In response to client requests for
specialized analyses,  SMO  subcontracts  for
Special Analytical  Services (SAS),  scheduling
and tracking  for SAS efforts as outlined above.
SMO maintains a comprehensive database of CLP
services,  performance and utilization  in order to
generate a variety  of  management  and  user
reports.

c.  Office of Research and Development,
    Environmental Monitoring Systems
    Laboratory/Las  Vegas (EMSL/LV)

    ORD provides program QA  support through
EMSL/LV. EMSL/LV assists in the following
functions:

    •  performing preaward and postaward on-
       site laboratory evaluations;
    •  preparing performance evaluation (PE)
       samples for preaward and postaward
       laboratory performance evaluations;
    •   evaluating preaward and postaward PE
       sample data;
    •  performing QA audits on CLP-generated
       data including mass spectrometer data
       tapes; and
    •  assisting in the evaluation and
       development of CLP analytical methods
       and protocols.
    EMSL/LV also operates  the program's QA
database to conduct program and laboratory trend
analyses used in developing and updating contract
quality control  criteria.

d.  National Enforcement Investigations Center

    The National  Enforcement Investigations
Center (NEIC) advises the  NPO in defining and
applying  program enforcement requirements.
NEIC-developed sample  custody  procedures,
chain-of-custody  records,  sample  tags, and
custody seals are used to maintain the integrity of
sample  analyses  for  supporting  Agency
enforcement actions.  NEIC  routinely performs
evidence  audits of contract laboratories and
generates  sample  profiles  used  in  Agency
enforcement litigation.   A description  of the
enforcement support provided by NEIC appears in
Chapter W, Section D.

3.  Regional Program Support

    The Regions play an integral role in program
activities, both as the primary CLP user and as a
key part of analytical program management. The
decentralization of program responsibilities to
the Regions is  an  effective means  of directing
program  operations nationwide.    Extended
Regional participation in the program has and
will  continue  to  increase  the   program's
responsiveness to Superfund requirements.

a.  Regional Technical Project Officers

    In 1984, Regional Administrators appointed a
CLP Technical  Project Officer  (TPO) for  each
Regional office.  Under the guidance of the NPO,
the  Regional  TPO  monitors  the  contract
laboratories located in  the Region.  The  TPO
works closely with the APO in responding to
identified problems in laboratory operations and
participating in on-site evaluations.  The TPO is
the first line of contact for  the laboratory for all
technical problem resolution and only  reverts
technical problems to the  NPO that appear to
have program implications.

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                                                       Chapter I - Background and Introduction
b.  Regional Sample Control Centers (RSCC)

   In 1984, each Region established an RSCC to
centralize scheduling of CLP sample  analyses
within the Region.  The RSCC is comprised of one
or more individuals.  One individual is named as
the primary RSCC.  The RSCC is responsible for
coordinating the  level of Regional  sampling
activities to  correspond  with  the  monthly
projected demand for analytical services.  When
conflicts occur, the primary RSCC makes the final
determination of  Regional  analysis priorities.
The RSCC routinely places all Regional requests
for CLP analyses, coordinates with SMO during
sampling and sample shipment, and resolves any
problems concerning the samples. The RSCC also
serves as the central point of contact for questions
concerning Regional sampling efforts.

c.  Regional/Laboratory Communication System

   In 1983, the NPO established a system by
which the Regions and contract laboratories can
communicate in the most timely and direct manner
possible.   Regional  communication  contacts
routinely call laboratory communication contacts
to resolve technical questions concerning program
data.  This communication link also benefits  the
laboratory by providing  direct feedback  on its
data product.
4.  Analytical and Support Services Contractors
a. Analytical  Contract Laboratories
   The CLP's analysis contractors come from the
nationwide  community of chemical analytical
laboratory facilities. To become part of the CLP,
laboratories must meet stringent requirements and
standards for equipment, personnel, laboratory
practices, and  analytical  and  quality  control
operations.   Firm,  fixed-price contracts are
awarded to the lowest responsive, responsible
bidders through the Government's Invitation for
Bid (IFB) process. Before a contract is awarded,
low priced bidders  must successfully analyze
performance evaluation  samples  and  pass  a
preaward laboratory audit.  After contract award,
laboratories are closely  monitored to  ensure
compliance with the terms and conditions of the
contract.  Details of preaward and postaward
evaluations are addressed in Chapter V.

b.  Shipment Management Program
   The Shipment Management program  was
created by the NPO in 1988 to provide a consistent
means  of tracking the various shipping accounts
established for  CLP  use.    The  Shipment
Management contractor establishes, maintains
and monitors  the shipping  accounts for the
transportation  of  sample  containers, sample
coolers, contract compliance screening results and
other  items requested  by  the  NPO.   Further
information  on  the Shipment Management
program is provided in Chapter IV, Section B.

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                                     CHAPTER II

               DESCRIPTION  OF ANALYTICAL SERVICES
  In this chapter...
  Organic Routine Analytical Services
  Inorganic Routine Analytical Services
  Dioxin/Furan Routine Analytical Services
  Special Analytical Services
   RAS Plus SAS
   All SAS
   Contract Delivery and Quality Control
     Requirements
  Analytical Methodology Improvement/
   Development
   Protocol Standardization and Improvement
   Method Development
   The CLP provides routine and specialized
analytical  services to  support a variety  of
Superfund  sampling activities.  These activities
range from those associated  with  the smallest
preliminary site investigation to those of large
scale,  complex  remedial,  monitoring  and
enforcement actions. In response to the increasing
analytical demands of Regional clients, the CLP
has  continually expanded  its  capacity  for
standardized analyses  through frequent contract
solicitations.  On the average, the CLP provides
over 6,000 sample analyses per month through its
routine and  specialized  analytical  services
programs.   The CLP will continue to  adjust
analytical capabilities  and capacity in response
to client needs.

   The CLP operates the following analytical
programs:
    •  Organic Routine Analytical Services
       (RAS),
    •  Inorganic RAS,
    Ğ  High Concentration Organics
    •  High Concentration Inorganics
    •  Organics Low Concentration (Drinking
       Water)
    •  Inorganics Low Concentration (Drinking
       Water)
    •  Volatile  Organics Low Concentration
       (Drinking Water)
    •  Dioxins/Furans
    •  Special  Analytical Services (SAS).
    In the future, many other analytical programs
will be included under RAS:
    •  Fast Turnaround GC Screen Organics
    •  Air Toxics
    •  Geotechnical
    •  Water and Soil Characterization
    •  Mixed Waste
    Laboratories operating under firm, fixed-price
contracts with  the  EPA provide  Routine
Analytical Services to Superfund clients.  Non-
Superfund clients can also access RAS programs
once special funding arrangements have been
made.
    Figure 3  summarizes  RAS  services.   For
detailed analytical  information,  users  are
instructed to consult the Region's Master Copy
FIGURE 3. ROUTINE ANAL YTICAL SER VICES
      Concentration
      Matrices
      Fractions
Organic

Multi-Media,
Multi-
Concentratlon

Low, Medium
Water,
Soil/Sediment
• Volatlles
(VOAs)

• Seml-
volatlles
(SVs)
• Pesticide/
Aroclors
Routine Analytical Services
Low
Concentration
Water

Low
Water

• VOAs

• SVs
• Pesticide/
Aroclors


Low
Concentration
Water, VOA
Only
Low
Water

• VOAs






High
Concentration


High
Water,
Soil/Sediment
• VOAs

• Eitractables
• Aroclors/
Toxaphenes


Inorganic
Routine Analytical Service*
Multi-Media,
Multi-
Concentration

Low, Medium
Water,
Soil/Sediment
• Total Metals

• Dissolved
Metals
• Cyanide


Lew
Concentration
Water

Low
Water

• Total Metals ,

• Cyanide
• Total
Nitrogen
• Fluoride

High
Concentration


High
Water,
Soil/Sediment
• Metals

• Cyanide
• PH
• Conduc-
tivity

Dloxin/
Furan RAS



Low, Medium










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                                                  Chapter II - Description of Analytical Services
Statements  of Work  under  which CLP RAS
laboratory contractors operate.

    Routine  Analytical  Services  apply to the
analysis of water and soil/sediment samples.
Samples for analysis should be single-phase and
homogeneous with  the exception of  high
concentration  analysis  which  may be multi-
phase.   Sample  matrices other than water  or
soil/sediment  are processed through the  SAS
program.

    Organic  and inorganic  low  and medium
concentration RAS contract methods are  used to
analyze low to medium sample concentrations for
organic target  compounds and  inorganic target
analytes, respectively.  The  sampler identifies
low and medium levels of concentration in the
field to determine sample collection volume and
packaging and shipment procedures. Low level
samples are considered to be those collected off-
site in  areas where hazards  are thought to  be
significantly reduced  by normal environmental
processes.    Medium  level  samples, where a
compound or element may comprise as much as
fifteen percent of the total sample, are most often
those  collected on-site in areas  of  moderate
dilution by normal environmental processes.  The
contract laboratory  performs  preliminary
characterizations to determine  the appropriate
analytical protocol (low or medium) to be used.

    Organic  high concentration  RAS contract
methods are used to analyze  high  concentration
samples for organic  target compounds.  High
concentration samples  are considered to be those
collected directly from drums, pits, ponds, lagoons
or areas where no dilution of waste is evident.

    Required sample volume and container types
used for sample collection for RAS analyses are
detailed in the CLP Sampler's Guide. Contractors
should  acquire sample bottles which meet EPA
quality assurance standards.  These containers
may  also   be utilized  in   SAS  projects  as
appropriate.
    Contract delivery requirements for each RAS
program are specified in the following sections.
The contract laboratory is required to deliver all
analytical results and  quality control (QC) data
for each Sample  Delivery Group (SDG) in one
data package.  An SDG is defined by one of the
following, whichever occurs first:

    •   each case of field samples; or
    •   each twenty field samples within a case;
       or
    •   each fourteen calendar day (seven days
       for low concentration inorganic) period
       during which field samples in a Case are
       received, beginning with the receipt of
       the first sample in the SDG.
    Laboratories are subject to liquidated damages
for late delivery and incentives for early delivery
of the data package.
    The  SAS  program provides  specialized
analytical  services to Superfund  and  Non-
Superfund clients for organics, inorganics, dioxin
and other compounds in a variety of matrices.
SAS services  are offered  to meet specific
analytical requirements which do not fall  under
RAS  programs  and  are  solicited  through
individual fixed-price subcontracts awarded to
qualified laboratories.
    Figure 4 outlines the services available under
the CLP's SAS programs.  The client should
carefully consider  the provisions of each CLP
analytical program during the planning stages of
a sampling event to determine the applicability
of the analysis to user needs.

FIGURE 4. SPECIAL ANALYTICAL SERVICES
 RAS Plus SAS Examples
 •  Fast Turnaround Analysis by RAS Organic or Inorganic IFB
   Protocol
 •  RAS Organic Analysis with Additions/Adjustments to IFB Protocol
 •  RAS Inorganic Analysis with Additions/Adjustments to IFB Protocol
 •  RAS High Concentration Analysis with Additiona/Adjustments to
   IFB Protocol
 All SAS Examples
 •  Organic Analysis Per Non-RAS Protocols, Matrices, Compounds
 •  Inorganic Analysis Per Non-RAS Protocols, Matrices, Compounds
 •  Dioxin Analysis
 •  Special Topics Analysis (As Requested)	
    NOTE:    The client is  responsible for
designating IFB method adjustments for "RAS Plus
SAS"  requests  and  for supplying  suitable
analytical  protocols  for "All SAS"  requests.
Additionally,  the  client must provide quality
assurance/quality control procedures and criteria,
and must specify  data delivery schedules. All
information must accompany the client's request
for SAS services.

    The CLP QC  program for RAS laboratory
analysis is structured to provide consistent results
of known and documented quality.  Sample data
packages contain QC documentation that allow an
experienced chemist to determine the quality of

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CLP User's Guide
the data and its applicability to each sampling
activity.  In addition, laboratory contracts contain
provisions for sample reanalysis if specified QC
criteria  are not met by the contract laboratory.
Each CLP laboratory is also encouraged to develop
additional internal QA/QC procedures.
    The minimum QC requirements of the RAS
programs consist of both an initial and ongoing
demonstration  of  laboratory  capability  to
generate  acceptable performance  with  the
contract methods.  The contract laboratory must
demonstrate that instrument calibration criteria
have  been  met,  that interferences from  the
analytical system are under control, and that
spike and  duplicate  recoveries falling outside
contract acceptance  windows are attributable to
sample matrix interferences and not to laboratory
analytical errors. The QC requirements for each
RAS program are  provided in the following
sections.

A. Organic Routine Analytical  Services
    Organic  Routine Analytical Services  are
comprised  of four analytical contracts  which
allow  the  analysis  of  different media and
concentrations. Figures 5-8 detail each of these
four analytical contracts.

B.  Inorganic Routine Analytical
    Services
    Inorganic  Routine Analytical Services are
comprised  of three analytical contracts  which
allow  the  analysis  of  different media and
concentrations. Figures 9-11 detail each of these
three analytical contacts.

C  Dioxin/Furan Routine Analytical
    Services
    Dioxin/Furan Routine Analytical Services are
detailed in Figure 12.

D. Special Analytical Services
    In  addition to  the standardized analyses
available under the RAS program, SMO provides
Regional clients with specialized analyses under
the  SAS  program.   While these  analytical
services are beyond the  scope of RAS contract
protocols, they are consistent with CLP objectives.
Services provided through the SAS program
include fast  turnaround analyses, verification
analyses, analyses  requiring  lower  detection
limits than  RAS methods provide, identification
and  quantification  of non-TCL constituents,
general waste characterizations,  analysis  of
nonstandard matrices and other specific analyses.

    As part of the SMO contract with EPA, Viar
and Company solicits, awards  and administers
SAS subcontracts.  By utilizing subcontracts, SMO
can procure specialized  services in a  timely
manner on an as-needed basis.  Due to the often
unusual nature of SAS requests, users must plan
their projects in advance to allow SMO sufficient
time to procure these services.

    For each SAS  request, the  client provides
SMO  with the necessary analytical methods,
QA/QC requirements and acceptance criteria in
writing.  SMO procures SAS by subcontracting
with laboratories with RAS  contracts  in  the
appropriate analytical  program.   When  RAS
laboratories  cannot  meet   the  analytical
requirement of the SAS, requests are solicited to
other laboratories which have indicated  the
ability  to  meet   program   performance
requirements.  RAS  contract laboratories  are
evaluated  for current RAS performance  before
they are considered for SAS solicitations, and are
not solicited for SAS work if deficient in this
area.   Other  laboratories qualify to  perform
certain types of  SAS  work by  successfully
completing  performance evaluation sample
analyses or by justification of unique analytical
capability.

    Once the laboratory community is determined,
SMO provides the community with  the particular
requirements of the SAS. Laboratories are asked
to bid firm, fixed-price(s) for the performance of
specific types of analyses on a defined number of
samples.

    A laboratory's ability to bid for SAS work and
the prices  being bid may vary depending  on the
size or scope of the  analytical request, data
turnaround  requirements   and  analytical
parameters  of a  particular task,  weekly RAS
sample loading,  and  laboratory  operating
conditions at the  time  of solicitation.   SMO
evaluates laboratory bids in terms of bid price and
responsiveness to the specified task.  The  SAS is
awarded to the lowest bidding laboratory which
responds to the client's analytical requirement. A
written, individual SAS subcontract agreement is
then made between the laboratory and Viar.
                                         8

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                                             Chapter II - Description of Analytical Services
FIGURES. ORGANIC ROUTINE ANALYTICAL SERVICES, MULTI-MEDIA, MULTI-CONCENTRATION
SOW Reference


Concentration
Matrices

Fractions


Compounds
Identified &
Quantified
Volumes Required
and Required and
Preservation
Techniques

Contract Delivery
Requirements
























Data Package
Contents



Analytical
Procedures

QA/QC Summary



Statement of Work for Organics Analysis
Multi-Media. Multi-Concentration
Document Number OLM01.0
Low or Medium
Water
Soil/Sediment
Volanles (VOAs)
Semivolatiles (SVs)
Pesticide/Aroclors
Target Compounds
Library Matches of 10 volatile components
Library Matches of 20 semivolatile components
Consult Sampler's Guide or Regional instructions



Deliverable

• Updated SOPs






• Sample Traffic Reports
• Sample Data Summary
Package
• Sample Data Package

• Complete SDG File

• Quality Assurance Plan



• Data in Computer Readable
Form
• GC/MS Tapes

• Extracts


Delivery Schedule

45 days after contract receipt






3 days after receipt of last sample in SDG
35 or 14 (see contract) days after receipt
of last sample in SDG
35 or 14 (see contract) days after receipt
of last sample in SDG
35 or 14 (see contract) days after receipt
of last sample in SDG
Submit copy within 7 days of written
request by APO


35 or 14 (see contract) days after receipt
of last sample in SDG
Retain for 365 days after data submission,
or submit within 7 days after receipt of
written request by APO and/or EMSL/LV
Retain for 365 days after data submission.
or submit within 7 days after receipt of
written request by APO or SMO.
Description

Updated copies of all required SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.



See "Data Package Contents."

See Exhibit B, Sections 111 and IV of
SOW.
The QAP must present, in specific terms,
the policies, organization, objectives,
functional guidelines, and specific QA
and QC activities designed to achieve the
data quality requirements in the contract
See Exhibit H of SOW.






1. SDG Narrative
2. Traffic Reports
3. Volatiles Data
4. Semivolatiles Data
5. Pesticide/Aroclor Data
Sample Preparation and Storage
GC/MS Analysis
GC/EC Analysis
Matrix Spike
Matrix Spike Duplicate
Per Sample Delivery Group For Each Matrix and Concentration On Per-Fraction Basis
• Various Instrument QA/QC (see SOW)

-------
CLP User's Guide
FIGURE 6. ORGANIC ROUTINE ANALYTICAL SERVICES, LOW CONCENTRATION WATER
SOW Reference

Concentration
Matrices
Fractions


Compounds
Identified &
Quantified
Volumes Required
and Preservation
Techniques

Contract Delivery
Requirements























Data Package
Contents



Analytical
Procedures




Statement of Work for Low Concentration Water for Organics Analysis
Document Number OLC01.0
Low
Water
Volatiles
Semivolatiles
Pesticides/Aroclors
Target Compound List
10 non-surrogate organic compounds for volatile
20 non-surrogate organic compounds for semivolatile
Consult Sampler's Guide or Regional instructions


Deliverable
• Updated SOPs






• Sample Traffic Reports
• Sample Data Summary
Package
• Sample Data Package
• Complete SDG File

• Data in Computer Readable
Form
• GC/MS Tapes


• Extracts


• QAPlan



Delivery Schedule
45 days after contract receipt






3 days after receipt of last sample in SDG
21 days after receipt of last sample in SDG

21 days after receipt of last sample in SDG
21 days after receipt of last sample in SDG

21 days after receipt of last sample in SDG

Retain for 365 days after data submission,
or submit within 7 days after receipt of
written request by APO and/or EMSL/LV
Retain for 365 days after data submission,
or submit within 7 days after receipt of
written request by APO or SMO
Submit witin 7 days after receipt of
written request by APO


Description
Updated copies of all required SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.



See "Data Package Contents."
See Exhibit B, Sections ni and IV of
SOW.
See Exhibit H of SOW.







The QAP must present, in specific terms,
the policies, organization, objectives,
functional guidelines, and specific QA
and QC activities designed to achieve the
data quality requirements in the contract.
1. SDG Narrative
2. Sample Traffic Reports
3. Volatiles Data
4. Semivolatiles Data
5. Pesticides/Aroclors Data
GC Analysis
GC/MS Analysis
GC/EC Analysis for pesticides/Aroclor
Surrogate Spike Recovery
Laboratory Evaluation Sample
Blanks
GC/MS Instrument Performance Checks (BFB and DFTPP)
Initial and Continuing Calibration Data
                                 10

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                                            Chapter II - Description of Analytical Services
FIGURE 7. ORGANIC ROUTINE ANAL YTICAL SERVICES, LOW CONCENTRATION WATER -
VOLATILES ONLY
SOW Reference
Concentration
Matrices
Fractions
Compounds
Identified &
Quantified
Volumes Required
and Preservation
Techniques
Contract Delivery
Requirements





Data facKage
Contents
Analytical
Procedures
V^W*- nummary
Statement of Work for Low Concentration Water for Volatile Organics Analysis
Document Number OLV01.0
Low
water
. Volaules
• Target Compounds
• 10 non-surrogate organic compounds
Consult Sampler's Guide or Regional instructions
UellveraDle
• Update SOPs
• Sample Traffic Reports
• Sample Data Summary
Package
• Sample Data Package
• Complete SDG File
• Data in Computer Readable
Form
• GC/MS Tapes
• QAPlan
Delivery schedule
45 days after contract receipt or within 14
days of request by APO/TPO
3 days after receipts of last sample in SDG
7 days after receipt of last sample in SDG
7 days after receipt of last sample in SDG
7 days after receipt of last sample in SDG
7 days after receipt of last sample in SDG
Retain for 365 days after data submission,
or submit within 7 days after receipt of
written request by APO and/or EMSL/LV
Submit within 7 days after receipt of
written request by APO
Description
Updated copies of all required SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.

See "Data Package Contents."
See Exhibit B. Section HI of SOW
See Exhibit H of SOW

1. SJLXi Narrative
2. Sample Traffic Reports
3. Volatiles Data
Sample Preparation and Storage
GC/MS Analysis
Diamt Analysis
Laboratory Control Samples
Performance Evaluation Samples
Various Instrument QA/QC (see SOW)
                                     11

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CLP User's Guide
FIGURES. ORGANIC ROUTINE ANALYTICAL SERVICES, MULTI-MEDIA, HIGH CONCENTRATION
SOW Reference


Concentration
Matrices

tractions


Compounds
Identified &
Quantified
Volumes Required
and Preservation
Techniques

Contract Delivery
Requirements






























Contents




Procedures


Statement of Work for Organics Analysis
Multi-Media, High Concentration
SOW No. Rev. 9/88 including Rev 4/89
High
Water
Soil/Sediment
Volanles
Ex tractable;
Aroclors/Toxaphenes
Target Compounds
10 volatile components
20 extractable components
Consult Sampler's Guide or Regional instructions


Deliverable
• Contract Start-Up Plan





• Updated SOPs





• Sample Traffic Reports
• Sample Data Summary
Package
• Sample Data Package
• GC/MS Tapes


• Extracts


• Complete Case File Purge








Delivery Schedule
7 days after contract award





120 days after contract award






35 days after receipt of last sample in SDG

35 days after receipt of last sample in SDG
Retain for 365 days after data submission,
or submit within 7 days after receipt of
written request by APO and/or EMSL/LV
Retain for 365 days after data submission.
or submit within 7 days after receipt of
written request by APO or SMO
Submit 180 days after data submission or
7 days after receipt of written request by
APO or SMO







Description
Proposed schedule for receiving samples
starting with the 30th calendar day after
award and ending with the date the
contractor is capable of receiving the full
monthly sample allotment stipulated in
the Contract
Updated copies of all required SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.



See "Data Package Contents."






Includes all laboratory records received or
generated for a specific Case that have
not been previously submitted to EPA as
a deliverable. These items include but are
not limited to: sample tags, custody
records, sample tracking records, analysts
logbook pages, bench sheets.
chromatographic charts, computer
printouts, raw data summaries, instrument
logbook pages, correspondence, and the
document inventory.
1 . Case Narrative
2. Traffic Reports
3. High Concentration Volatiles Data
4. Extractables Data
5. Aroclor/Toxaphene Data
GC/MS Analysis
GC/EC Analysis
Following Sample Preparation/ Extraction
Matrix Spike Sample Analysis (per 20 single phase units/14 calendar days, whichever most frequent)
Method blank (per Case/20 units/14 calendar days/extraction, whichever most frequent)
                                   12

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                                              Chapter II - Description of Analytical Services
FIGURE 9. INORGANIC ROUTINE ANAL YTfCAL SERVICES, MUL TI-MEDIA, MUL TI-CONCENTRA TION
SOW Reference

Concentration
Matrices

Fractions

Compounds
Identified &
Quantified
Volumes Required
and Reservation
Techniques

Contract Delivery
Requirements


























Data Package
Contents

Analytical
Procedures


QA/QC Summary





Statement of Work for Inorganics Analysis
Multi-Media, Multi-Concentration
Document Number ILM01.0
Low or Medium
Water
Soil/Sediment
• Total Metals or Dissolved Metals
• Cyanide
• Metals
• Cyanide

Consult Sampler's Guide or Regional instructions


Deliverable
• Updated SOPs






• Sample Traffic Reports
• Sample Data Package
• Data in Computer Readable
Form
• Complete SDG File
• Quarterly/Annual
Verification of Instrument
Parameters







• Quality Assurance Plan




Delivery Schedule
45 days after contract receipt






3 days after receipt of last sample in SDG
35 days after receipt of last sample in SDG
35 days after receipt of last sample in SDG

35 days after receipt of last sample in SDG
Quarterly: 15th day of January, April,
July, October








Submit copy within 7 days of written
request by APO



Description
Updated copies of all required SOPs
submitted with prebid PE sample
results. SOPs must address any and
all issues of laboratory performance
and operation identified through the
review of PE sample data ana
evaluation of Bidder-Supplied
Documentation.

See "Data Package Contents."
See Exhibit H of SOW.

See Exhibit B, Sections 111 and IV of SOW.
The Contractor shall perform and report
quarterly verification of instrument
detection limits and linear range
methods specified in Exhibit E for each
instrument used under this contract
For the ICP instrumentation, the
Contractor shall also perform and report
annual interelement correction factors
(including method of determination),
wavelengths used and integration times.
The QAP must present, in specific terms, the
policies, organization, objectives, functional
guidelines, and specific QA and QC
activities designed to achieve the data
quality requirements in the contract.
1. Cover Page
2. Sample Data
3. Sample Traffic Reports
Following Sample Preparation/Distillation
ICP Analysis
Flame, Graphite Furnace and Cold Vapor AA Analysis
Cyanide Analysis
1U1MU5 Analysis (at beginning and end ot analysis run or minimum or twice per K fir shift, whichever is more frequent
Spiked Sample Analysis (per matrix/concentration)
Duplicate Sample Analysis (per matrix/concentration)
LCS Analysis (per group/batch)
ICP Serial Dilution (per group/batch)
Other QA/QC (see SOW)
                                       13

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CLP User's Guide
FIGURE 10. INORGANIC ROUTINE ANALYTICAL SERVICES, LOW CONCENTRATION WATER
SOW Reference




fractions



Compounds
Identified &
Quantified

Volumes Required
and Preservation
Techniques

Contract Delivery
Requirements

























Data Package
Contents

Analytical
Procedures

QA/QL iiummary









Statement of Work
Low Concentration Water for Inorganic Analytes
Document Number ILCO 1 .0
Low
Water
Total Metals
Cyanide
Total Nitrogen

23 indicated elements
Cyanide
Total Nitrogen
Fluoride
Consult Sampler's Guide or Regional instructions


Deliverable
• Updated SOPs




• Sample Traffic Reports
• Sample Data Package
• Data in Computer Readable
Format
• Complete SDG File
• Quarterly/Annual
Verification of Instrument
Parameters







• ICP/MS Diskettes/Tapes


• Quality Assurance Plan




45 days after contract receipt




3 days after receipt of last sample in SDG
14 days after receipt of last sample in SDG
14 days after receipt of last sample in SDG

14 days after receipt of last sample in SDG
Quarterly: 15th day of January, April,
July, October








Retain for 365 days after submission; or
submit them within 7 days of written
request by APOorEMSL
Submit within 7 days of written request
byAPO




Updated copies of all requires SOPs
submitted with prebid PE sample
results. SOPs must address any and
all issues of laboratory performance
and operation identified through the
review of PEsample data and
evaluation of Bidder-Supplied
Documentation.

See "Data Package Contents."
See Exhibit H of SOW.

See Exhibit B, Sections in and IV of SOW
The Contractor shall perform and report
quarterly verification of instrument
detection limits and linear range
methods specified in Exhibit E for each
instrument used under this contract.
For the ICP instrumentation, the
Contractor shall also perform and report
annual interelement correction factors
(including method of determination).
wavelengths used and integration times.



The QAP must present, in specific terms,
the policies, organization, objectives,
functional guidelines, and specific QA
and QC activities designed to achieve the
data quality requirements in the contract.
1 . Cover Page for the LC-lnorganic Analyses Data Package
2. Sample Data
3 . Sample Traffic Reports and Cover Sheet for each sample
ICP Analysis
ICP/MS Analysis
Graphite Furnace, Flame, and Cold Vapor AA Analysis
Cyanide, Total Nitrogen, and Fluoride Analysis
ICjf and l(J.tYMi> Interference Check; Sample (1C6) Analyses
Matrix Spike Sample Analysis (S)
Duplicate Sample Analysis (D)
Laboratory Control Sample (LCS) Analysis
Performance Evaluation Sample (PES)
Serial Dilution Analysis (L)
Internal Standards for ICP/MS
Instrument Detection Limit (IDL) Determination
rnterelement Corrections for ICP and ICP/MS
Hydride ICP (HYICP) and Furnace AA QC Analysis
Other QA/QC (see SOW)
                                  14

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                                             Chapter II - Description of Analytical Services
FIGURE 11. INORGANIC ROUTINE ANALYTICAL SERVICES, MULTI-MEDIA, HIGH CONCENTRATION
SOW Reference


Concentration
Matrices

fractions



Compounds
Identified &
Quantified
Volumes Required
and Preservation
Techniques

Contract Delivery
Requirements























UatafacKage
Contents

Analytical
Procedures




QA/QC Summary





Statement of Work for Inorganic Analysis
Multi-Media, High Concentration
Document Number IHC01.0
High
Water
Soil/Sediment
Metals
Cyanide
pH
Conductivity
Target Analyte List


Consult Sampler's Guide or Regional instructions


Deliverable
• Updated SOPs





• Sample Traffic Reports
• Sample Data Package
• Data in Computer Readable
Format
• Complete SDG Hie
• Quarterly/Annual
Verification of Instrument
Parameters







• Quality Assurance Plan




Delivery Schedule
45 days after contract receipt





3 days after receipt of last sample in SDG
35 days after receipt of last sample in SDG
35 days after receipt of last sample in SDG

35 days after receipt of last sample in SDG
Quarterly: 15th day of January, April,
July, October








Submit within 7 days of written request
byAPO



Description
Updated copies of all requires SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.

See "Data Package Contents."
See Exhibit H of SOW.

See Exhibit B, Sections 111 and IV of SOW.
The Contractor shall perform and report
quarterly verification of instrument
detection limits and linear range methods
specified in Exhibit E for each instrument
used under this contract. For the ICP
instrumentation, the Contractor shall also
perform and report annual interelement
correction factors (including method of
determination), wavelengths used and
integration times.
'ITie QAP must present, in specific terms,
the policies, organization, objectives,
functional guidelines, and specific QA and
QC activities designed to achieve the data
quality requirements in the contract
1. LioverJfage
2. Sample Data
3. Sample Traffic Reports
UJF Analysis
HYICP Analysis
CVAA Analysis
Cyanide Analysis
pH Analysis
Following Sample Preparation/Extraction
ICP Interference Check Sample (ICS) Analyses.
Matrix Spike Sample Analysis (S).
Analytical Spike Sample Analysis (A).
Duplicate Sample Analysis (D).
Laboratory Control Sample (LCS) Analysis.
Method Detection Limit (MDL) Determination.
Interelement Corrections for ICP (ICP).
Hydride ICP (HYICP) QC Analysis.
                                     15

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CLP User's Guide
FIGURE 12. DIOXIN/FURAN ROUTINE ANALYTICAL SERVICES
SOW Reference

Concentration
Matrices



Compounds
Identified &
Quantified








Volumes Required


Contract Delivery
Requirements




















Contents


Procedures


Statement of Work for Analysis of Polychlorinated Dibenzo- p-Dioxins (PCDD) and Polychlorinated
Dibenzofurans (PCDF), Multi- Media, Multi-Concentration
Document Number DFLM01.0
At least 10 parts per trillion for water samples or 10 parts per billion for soil, fly ash and chemical waste samples.
Water
Soil
Fly Ash
Chemical Waste
Total tetrachlorinated Dibenzo- p-dioxins
Total pentachlorinated Dibenzo- p-dioxins
Total hexachlorinated Dibenzo- p-dioxins
Total heptachlorinated Dibenzo- />-dioxins
Total octachlorinated Dibenzo- /ğ-dioxins
Total tetrachlorinated Dibenzofurans
Total pentachlorinated Dibenzofurans
Total hexachlorinated Dibenzofurans
Total heptachlorinated Dibenzofurans
Total octachlorinated Dibenzofurans
17 specific "2,3,7,8-substituted PCDDs/PCDFs"
2 L for Water samples
3 oz. for Soil, Fly Ash and Chemical Waste samples
Deliverable
• Updated SOPs





• Sample Traffic Reports
• Sample Data Summary
Package
• Sample Data Package
• Complete SDG File
• Quality Assurance Plan



• GC/MS Tapes


• Extracts


Delivery Schedule
45 days after contract receipt





3 days after receipt of last sample in SDG
45 days after receipt of last sample in SDG

45 days after receipt of last sample in SDG
45 days after receipt of last sample in SDG
Submit within 7 days of written request
byAPO


Retain for 365 days after data submission.
or submit within 7 days after written
request by APO or EMSl^LV.
Retain for 365 days after data submission.
or submit within 7 days after written
request by APO or SMO.
Description
Updated copies of all required SOPs
submitted with prebid PE sample results.
SOPs must address any and all issues of
laboratory performance and operation
identified through the review of PE
sample data and evaluation of
Bidder-Supplied Documentation.



See "Data Package Contents."
See Exhibit B, Section n of SOW.
The QAP must present, in specific terms,
the policies, organization, objectives.
functional guidelines, and specific QA
and QC activities designed to achieve the
data quality requirements in the contract.






1. SDG Narrative
2. Traffic Reports
3. PCDD/PCDFData
High Resolution GC/Low Resolution MS

• Matrix Spike Sample Analysis (S)
• Duplicate Sample Analysis (D)
• Other QA/QC (see SOW)
                                   16

-------
                                                 Chapter II - Description  of Analytical Services
   SAS requests are separated  into two basic
categories, "RAS Plus SAS" and "All SAS". These
categories are utilized in defining client requests
and pursuant SAS solicitation and contract award.
Analytical  services available through  the  SAS
program are described below.

1. RAS Plus SAS

a. Fast Turnaround

   Fast  turnaround requests require  the
application   of   existing  RAS   analytical
parameters, methodologies and detection limits
with a  shorter timeframe for performance of
analysis and/or delivery of data. Procurement for
fast turnaround SAS is dependent upon program
sample  load,  laboratory  capacities   and
laboratory operating conditions at the time of the
request. Because of constant fluctuations of these
factors, it  may not  be possible to obtain fast
turnaround service on an unlimited basis.  Fast
turnaround contracts  are solicited  only in
situations of demonstrated  need and are used
primarily to support EPA emergency actions and to
meet impending litigation deadlines.

   The following illustrates common "RAS Plus
SAS" fast turnaround requests. The SAS portion is
underlined:

    •   RAS organic target compound analysis
       with data delivery in seven days.
    •   RAS inorganic target compound analysis
       with data delivery in fourteen days.

b. Special  Requirements in Addition  to RAS

   A client may need to access the standardized
RAS  programs  and add  to  the  contract
requirements.  The following examples  illustrate
common "RAS Plus SAS" requests.  The  SAS
portion is underlined:

   (1) Organic
   •   Organics RAS TCL analysis with
       additional non-target compounds.
   •   Pesticide target compound analysis with
       minor alterations or additional procedures
       applied.
   (2) Inorganic
   •   Metals and cyanide analyses with special
       rigorous sample homogenization
       requirements.
    •   Metals analysis at lower detection limits
       than required by the RAS requirements.
    •   RAS metals and cyanide analysis with
       minor alterations or additional
       analytical procedures applied.
    (3) High Concentration Organic
    •   RAS High Concentration Analyses
    •   RAS analysis at lower detection limits
       than required by the High Concentration
       protocol.
2.  All SAS

    CLP  clients  frequently request  types of
analyses  that are not directly applicable to the
RAS program. These requests occur most often
with samples of difficult or unusual matrices and
measurements  of   analytical  parameters  not
provided through the RAS  program.  The SAS
program  accommodates unusual analytical
requests  on  an  "All SAS" basis.   Complete
methodology and  QA/QC  specifications must
accompany the request.  These types of analyses
include, but are not  limited to, the following:

    •   Volatile target compound analysis at
       lower detection limits than required by
       the IFB.
    •   Seven TCL Aroclors analysis only (i.e., not
       the entire IFB pesticide fraction).
    •   Non-target compound analyses.
    •   RAS compound /analyte analysis by non-
       RAS methods.
    •   Specified  RAS elemental analysis only
       (e,g., cadmium, mercury and selenium).
    •   Metals analysis by non-RAS methods.
    •   Air samples (e.g., tenax, charcoal and
       florisil tubes) for specific organic
       analyses.
    •   Methods comparison/evaluation studies.
    •   Asbestos analysis.
    •   Acid deposition parameters.
    •   Non-Superfund analytical services of any
       type.
    •   Geotechnical/Geophysical tests on soil
       samples.
    •   Radioactivity analyses.
    •   Leaching procedures (TCLP, EPTOX).
    •   Wet chemistry procedures.
    •   Physical tests.
                                         17

-------
CLP User's Guide
3.
•  Bioassays.
•  RCRA parameters.
•  "Explosives" Analyses.
•  Others as defined by client.
Contract Delivery and Quality Control
Requirements
   SAS contracts require delivery schedules for
sample extraction, analysis and data reporting,
and  require  laboratory QC procedures and
reporting of QC parameters as defined  by the
client requestor. Delivery and QC requirements as
detailed in RAS program contracts may be used as
a guide but must be specified by the client at the
time of request.  The requestor must specify all
deliverables   required   to  ensure  that  the
appropriate data packages are received.  Clients
are encouraged to maintain a high level of QC in
all analysis requests, unless there is substantial
reason for deleting certain QC requirements.

E. Analytical Methodology
   Improvement/Development

1. Protocol Standardization and Improvement

   In  order  to  maintain  state-of-the-art
protocols and accommodate newly  defined or
changed requirements of the Superfund effort, CLP
participants   are   constantly  refining  and
improving analytical protocols.  To  accomplish
this, program participants submit comments and
suggestions to the NPO.  The NPO  reviews all
submitted   information  and   considers
recommendations for program modification on a
periodic basis.

   Since 1982, the NPO has planned technical
meetings to utilize all  available resources  in
updating analytical program methodologies and
data reporting requirements. Technical meetings -
such as workgroups, and caucuses - are initiated by
the NPO on a periodic basis.  Participants include
the Regions, NPO, EMSL/LV, EMSL/Cincinnati,
NEIC, SMO,  contract  laboratories,  program
support contractors,  other EPA  programs, and
other government agencies, as appropriate. These
meetings are  instrumental  in improving CLP
protocols and ensuring that deliverables meet user
needs.

    EPA personnel review the discussions of the
technical meetings and compile recommendations
for protocol changes.  Following NPO approval of
recommended changes,  existing  laboratory
contracts are modified by the Contracting Officer
to include the recommended revisions. Whenever
possible, all  laboratory  contracts within an
analytical program are changed simultaneously to
maintain consistency within the program.  NPO-
approved protocol  revisions are included in any
new IFB solicitations.

2.  Method Development

    Development of new analytical methods may
be initiated by a newly identified or  redefined
Agency  analysis  requirement.   Analytical
methods utilized  in the CLP  are  based on
methodologies  developed and approved by EPA.
The NPO,  EMSL/LV,  the  Regions, and the
contractor  community have  historically
contributed to  the development of new program
analytical methodologies. Methods are reviewed
by  several  sources  and  are tested  prior to
implementation to the extent possible to meet
program requirements.
                                        18

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                                               Chapter III - Utilization  of Analytical Services
                                    CHAPTER IH

               UTILIZATION OF ANALYTICAL  SERVICES
  In this chapter...
  Analysis Request Procedures
   RAS Initiation Process
   SAS Initiation Process
   Procedures for Making Changes to Analytical
     Requests
  Regional Organic/Inorganic Allocation System
  Sample Documentation
   Sample Traffic Report
   SAS Packing List
   Sample Number
   Sample Tag
   Chain-of-Custody Record
  Sample Packaging and Shipment
   Packaging  Requirements
   Shipping Instructions
   Shipment Coordination
  Procedures for Problem Resolution
   Resolving Problems  Concerning Sample
     Shipment and Analysis
   Resolving Problems  Concerning Analytical
     Data
   The CLP provides clients with prompt access
to laboratory  services  through a documented
system of sample scheduling and tracking.
Individuals  interested  in  obtaining  CLP
analytical support must contact their Regional
EPA office's  RSCC.    SMO coordinates  the
scheduling of sample analyses through the CLP
and tracks the progress of samples from collection
through final data production.
   The RSCC is established by the EPA Regional
Administrator  and is centered in each Region's
Environmental  Services  Division  or  Waste
Management Division (see Appendix B).  The
RSCC,  consisting of one or more individuals,
places analytical requests.  SMO is authorized to
accept  analytical  requests only  through  the
RSCC.  In addition, the RSCC is responsible for
ensuring Regional compliance with the CLP's
projection/allocation system.  The primary RSCC
determines analytical priorities  for the Region
when conflicts occur.
   SMO  seeks  to   effectively  match  the
analytical needs of program clients with the
capabilities of contract laboratories. To this end,
SMO tracks  current  utilization, availability of
resources and laboratory performance limitations
for each program.
   The success of the CLP scheduling  process
depends on two factors:
   •   ongoing communication among the RSCC,
       field sampler,  SMO and laboratory
       personnel, and
   •   correct use of sample scheduling and
       tracking documents by the RSCC, field
       sampler and laboratory personnel.
A. Analysis Request Procedures

1. RAS Initiation Process
a. User Information Required
   To  initiate  a RAS request, the  RSCC  or
Regional designee contacts the appropriate SMO
Coordinator by telephone  or fax and provides a
complete  description  of  the   analytical
requirement.  (SMO personnel are identified in
Appendix B.) The information SMO requires to
initiate a RAS request is listed in Figure 13.
   The RSCC or  designee  is responsible for
estimating the number and types of samples and
the sample shipment dates  for the  analytical
request. Overestimation of the number of  samples
to be collected or miscalculation of shipment dates
unnecessarily ties  up  available  laboratory
capacity and lessens program responsiveness.
Underestimation of  the number and types of
samples to be collected may result in unavailable
services for any additional analyses needed.

b. Lead-time  Required
   By  noon EST on the Wednesday of the week
prior to the scheduled start of a planned sampling
activity, the RSCC or designee contacts  SMO to
place a request for RAS services and to  provide
scheduling information to SMO.  Allowing this
lead-time makes  laboratory scheduling  and
resolution of  sampling questions easier.  It also
                                        19

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CLP User's Guide
allows the sampler time to prepare the required
sample documentation  prior to field activity, if
appropriate.  Advance  scheduling  is available
and should be utilized whenever necessary.  Late
scheduling  requests  (i.e.,  requests received
between  Wednesday  noon  and  Friday)  are
accommodated   with  laboratory  capacity
availability.    To  avoid  possible  shortfalls,
Regions are strongly encouraged to submit all RAS
scheduling requests by  Wednesday noon, where
possible.

FIGURE 13.  RAS ANAL YSIS REQUEST
PROCEDURES - USER  INFORMATION
REQUIRED
Name of the individual RSCC, or designated requestor.
Name(s), association and telephone number(s) of sampling personnel
Name, city and state of the site to be sampled.
Superfund site/spill ID (2 digit alpha-numeric code).
Number and matrix of samples to be collected.
Type of analyses required.
• Organic: Volatiles (VOAs),      •  Low Concentration Water for
  Semivolatiles (SVs),             Organic Compounds: VOAs,
  Pesticides/Aroclors.            SVs, Pesticides/Aroclors.
• Inorganic: Total Metals, Dissolved
  Metals, Cyanide.
• High Concentration Organic: VOAs,
  Extractables, Aroclors/Toxaphenes.
• High Concentration Inorganic
  Metals, Cyanide, pH, Conductivity.
Scheduled sample collection and shipment dates.
Nature of sampling event
  Preliminary Assessment
  Site Investigation
  Expended Site Investigation
  Remedial Investigation/Feasibility
  Study
                       Low Concentration Water for
                       Inorganic Analytes: Total Metals,
                       Cyanide, Total Nitrogen, Fluoride.
                       Low Concentration Water for
                       VOAsOnly: VOAs.
                       Dioxins/Furans.
  Remedial Design
  Remedial Action
  Enforcement Lead
  Emergency Response (Removal)
  National Priorities List Delete
  Operation and Maintenance
  State Lead Preliminary Assessment
Suspected contaminants associated with the sample and/or site.
Other information which may affect sample scheduling or shipment (i.e.,
anticipated delays due to site access, weather conditions, sampling equipment)
Name(s) of Regional or contractor contacts for immediate problem resolution.
Other — describe
                       State Lead Site Investigation
                       Slate
                       National Dioxin Study
                       Facility Assessment
                       Compliance Monitoring Effort
                       Enforcement
                       Ground Water Monitoring Task
                       Force
                       Resource Conservation and
                       Recovery Act
                       Office of Water
                       Clean Air
C.
Case Number Assignment and Laboratory
Scheduling
    At  the  time  of request,  SMO assigns  a
sequential Case number to each RAS sampling
activity for identification throughout sample
tracking and data production.  A Case number
designates a group of samples collected at one site
or geographical location during a predetermined
and finite time period.  The RSCC records the
Case number and uses it in referencing that request
throughout sampling and analysis.
    SMO then schedules  the requested analyses
through  an  appropriate  RAS  laboratory.
Laboratory selection is determined by

    •   the types of analyses,
    •   number of samples,
    •   contract capacity,
    •   sample balance among the various
        laboratories,  and
    •   laboratory loading and instrument
        conditions.
    Laboratory selection is also  based  on the
Regional Distribution  of Laboratories  System
developed by the NPO and designed to minimize
the number of laboratories producing data for any
one Region.  When possible, the nearest available
laboratory is assigned in order to minimize sample
shipping costs.

    Once RAS laboratory assignments are made,
SMO contacts the RSCC or designee to confirm the
field   investigation   plans,   identify  the
laboratories to be used for the Case, and  answer
any  further  questions  regarding program
procedures or documentation. At that point, the
RSCC or designee  must indicate all known or
anticipated  sample  scheduling changes.  Any
further changes should be communicated to SMO
immediately upon  identification  to  ensure the
timely  resolution of conflicts and  the  optimal
allocation of program resources.  After the initial
placement  of the RAS request,  the RSCC or
designee may assign a logistical contact,  such as
the  team leader  in  the  sampling  effort, to
coordinate with  SMO  in  finalizing sampling
requirements, and initiating and arranging sample
shipment.

d.  User Knowledge  of Analytical Protocol

    Each RSCC is responsible for gaining and
maintaining a working knowledge of current RAS
protocols and analytical services.  SMO provides
each Regional TPO  (listed in Appendix  B) with
Master Copy notebooks of each RAS program IFB
Statement of Work  (SOW).  The Master  Copy
notebooks are periodically updated to  reflect
program protocol changes.

    The  SOW represents  the" standardized
requirements  that  each  individual  RAS
laboratory is contractually bound to follow. The
analytical SOWs contain specific information on
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                                                    Chapter III -  Utilization  of Analytical Services
    •   sample types suited to RAS analysis,
    •   compounds identified and quantified,
    •   analytical methods, protocols, detection
        limits,
    •   deliverable requirements, and
    •   quality control requirements.
    Program users should consult the appropriate
SOW to confirm that the RAS program is suited to
an analytical request.

2.  SAS Initiation Process

a.  User Information  Required

    Analytical requirements  differing  from RAS
parameters  are processed  through  the SAS
program as  described in Chapter II, Section  D.
Initiating a SAS request is a two-part process.

    •   The RSCC or designee sends a copy of the
        SAS client request, appropriate
      ,  attachments (if needed) and a copy
        requested analytical method to SMO.
    •   The RSCC or designee contacts the
        appropriate SMO Regional Coordinator
        by telephone and provides a complete
        description of the analytical requirement.
    The information SMO requires to  initiate a
SAS request is listed in Figure 14.

FIGURE 14.  SAS ANALYSIS REQUEST
PROCEDURES-USER INFORMATION
REQUIRED
Name of RSCC or client requestor.
Name(s), association and telephone number(s) of sampling personnel.
Name, city and state of the site to be sampled.
Superfund site/spill ID (2 digit alpha-numeric code).
Number and matrix of samples to be collected.
Specific analyses required/ appropriate protocols and QA/QC limits.
Required detection limits.
Matrix spike, matrix spike duplicate, duplicate or LCS frequency, if applicable.
Data turnaround and data format
Justification for fast turnaround request, if appropriate.
Scheduled sample collection and shipment dates.
Nature of sampling event.
                          State Lead Site Investigation
                          State
                          National Dioxin Study
                          Facility Assessment
                          Compliance Monitoring Effort
                          Enforcement
                          Ground Water Monitoring Task
Preliminary Assessment
Site Investigation
Expended Site Investigation
Remedial Investigation/Feasibility
Study
Remedial Design
Remedial Action
Enforcement Lead
Emergency Response (Removal)
National Priorities List Delete
Operation and Maintenance
State Lead Preliminary Assessment
                          Force
                          Resource Conservation and
                          Recovery Act
                          Office of Water
                          Clean Air
Suspected contaminants associated with the samples and/or site.
Other information which may affect sample scheduling or shipment (i.e.,
anticipated delays due to site access, weather condition, sampling equipment).
Name(s) of Regional or contractor contacts for immediate problem resolution.
    Most SAS requests are made in writing using
the  SAS client  request form.   In  emergency
situations, the verbal request may be made prior
to a written request. Following the verbal request,
the RSCC  must submit a completed SAS Client
Request form to SMO.  This form  serves as the
written record to clarify and confirm the client's
requirement for specialized analytical work.

    The RSCC is responsible for estimating the
number and  types of samples and the  sample
shipment  dates   for  the   SAS   request.
Overestimation of  the number of samples to be
collected or miscalculation  of  shipment dates
unnecessarily  ties  up  available  laboratory
capacity lessening  program responsiveness.
Underestimation of the number and types of
samples to be collected may result in unavailable
services for  any  additional analyses needed.
Depending  on  the  size  and  extent  of  the
miscalculation, the  entire request may have to be
resolicited and  sampling  plans  postponed
accordingly.  SAS  solicitations result in binding
contracts.  If  the contract has been awarded, it
may not be possible to make changes.

b.  Lead-time  Required

    When a sampling activity has been planned,
the RSCC  contacts SMO and places the specific
written request for SAS services.  Because SAS
services  are individually  procured  on  a
competitive basis,  a minimum lead-time of  two
weeks,  from receipt of the request, is required to
process a properly completed SAS request. Three
to four weeks lead-time is strongly recommended
whenever possible. SAS solicitation will not be
started  until  the SAS requirements have been
completely defined by the RSCC.  Modifications
to any SAS request  will cause the entire process to
begin again.  Fully  defined requests initiated with
less  than  two  weeks  lead-time  may  not be
solicited and awarded in time to meet the original
shipment date.

    Certain types of SAS requests require a longer
lead-time.  A  minimum lead-time of two to three
weeks is required for SAS requests which involve
distribution of protocols (see item d, below).  A
minimum  lead-time of four or  more weeks is
recommended  for  large  scale,   analytically
complex or Non-Superfund SAS requests.  Award
of Non-Superfund  SAS subcontracts may  only be
made after the appropriate  funding  process  is
complete. The RSCC should contact SMO several
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CLP User's Guide
weeks in advance if there is a question regarding
the lead-time needed to schedule a particular
SAS request.
c.   SAS Number Assignment  and Laboratory
    Scheduling
    At  the time of request,  SMO  assigns a
sequential SAS number to each SAS sampling
activity for identification  throughout  sample
tracking and data production. If SAS services are
being provided in association with RAS services,
SMO also assigns a Case number.  Like the Case
identification, the SAS number designates a group
of samples collected at one site or geographical
location during a predetermined and finite time
period.  The RSCC or designee records the  SAS
number and Case number (if applicable) and uses
both numbers in referencing the request throughout
sampling and analysis.
    SAS laboratory selection is based on a verbal
and written  solicitation  process  for  each
individual request.  This solicitation results  in a
written  SAS  award  to the lowest qualified
bidder.   Once SAS laboratory  assignments  are
made, SMO notifies the RSCC of the laboratories
that will be performing the analyses.
    The nature of the SAS laboratory  solicitation
process requires the  RSCC to be as  exact as
possible with all elements of a request at the time
of request.  SMO  understands that  actual site
conditions can vary considerably from expected
conditions and necessitate changes in the sampling
plan.  However, the requestor is responsible for
notifying SMO immediately of any changes to
allow sufficient time to amend the SAS contract(s)
to meet the changed needs.  If an original request
is changed  significantly,  the original SAS
contract will be voided, and the entire analysis
effort will be  resolicited.  SAS  resolicitation
requires additional time before sample shipment
can take place.

d.  User Provided Analytical Protocol

    At the time of request, the RSCC must provide
the analytical  methodology  and quality control
requirements to  be utilized for  the SAS request
before SMO can initiate a solicitation.  For  SAS
requests that are based on the use of amended RAS
protocols, the RSCC must specify modifications or
additions to these protocols.  If such changes are
extensive, the client request preparer must submit
changes under the SAS to SMO in written form two
to three weeks in advance of scheduled sample
shipment. For SAS requests which require use of a
method  that  is not  commonly available,  the
RSCC must submit the method two to three weeks
in advance of sample shipment.  Additional lead-
time is required for  protocol distribution and
review by solicited laboratories.

    SAS  requests  which  cite well  known
analytical publications do not require additional
lead-time for distribution since laboratories have
immediate access to this information.  Examples
of frequently  utilized method manuals are  as
follows:

    •   Methods for Chemical Analysis of Water
       and Waste, USEPA, Current Edition, or as
       specified.
    •   Test Methods for Evaluating  Solid Waste,
       Physical/Chemical Methods, SW-846,
       USEPA Office of Water and Waste
       Management, Current Edition, or as
       specified.
    •   Standard Methods for the Examination of
       Water  and Waste  Water,  APHA,
       AWWA, WPCF, Current Edition, or as
       specified.
    Further analytical references  are supplied in
Appendix C.  The  RSCC should contact SMO
several weeks  in advance  if there is a question as
to whether a particular  method  will require
additional lead-time for distribution.

3.  Procedures for Making Changes to Analytical
    Requests

    The RSCC or designated  logistical contact
must  immediately notify  the appropriate SMO
Coordinator of all  changes in sampling plans
before and during the sampling  event and after
shipment of samples to the laboratory. Changes
in plans include changes in  sample matrices,
numbers of samples, analyses requested, detection
limits,  shipping  dates,  postponements   or
cancellations.  Failure to notify SMO of such
changes  can  result in delay in  sampling  to
accommodate scheduling changes, delay in start of
analysis  due  to conflicts, unsuitability of  a
particular sample to an  analytical  program,  or
analysis data inappropriate for client purposes.
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                                               Chapter III - Utilization of Analytical Services
B.  Regional Organic/Inorganic
    Allocation System

    The NPO  has  established  an allocation
system to   equitably   apportion  available
laboratory capacity to the Regions during periods
of  heavy sampling  activity  and   limited
laboratory capacity.   Currently,  capacity  is
available  for  the projected  sample  demand;
however, when the allocation system is in effect,
all  organic and inorganic RAS and "RAS  Plus
SAS" Cases will be scheduled accordingly.

    During the last month of each fiscal  year
quarter, the NPO provides the RSCC  with the
Region's  monthly  allocation  of organic  and
inorganic  sample analyses for  the following
quarter.  The RSCC is responsible for planning
monthly sampling activities in accordance  with
the NPO allocation.
    Under the scheduling/allocation system, the
RSCC requests sample analyses for  all planned
Regional sampling activities for  a week on the
Wednesday of the  prior week  and assigns  a
priority, if requested by  SMO, to each request.
Upon receiving the Region's analytical requests,
SMO makes laboratory assignments for the week
and schedules received  requests  up to  each
Region's allocation limit. Requests in excess of the
monthly allocations will not be processed by SMO
until  all Regional requests which  fall  within
allocations have been placed at a laboratory. At
this time,  any excess laboratory capacity for the
week is determined, and the NPO prioritizes
Regional   sampling  requests  that  exceed
allocations.  SMO assigns  available laboratory
capacity for sampling activities as prioritized by
the NPO.  For additional information concerning
the allocation system, users should  contact the
SMO Regional Coordinator or  Analyst for  their
Region (see Appendix B).

C  Sample Documentation

    Each sample processed by the CLP must be
properly documented to ensure timely, correct and
complete analysis for all  parameters requested,
and most importantly, to support the use of sample
data in potential enforcement actions.  The CLP
documentation system provides the means  to
individually identify, track and monitor  each
sample from the point of collection through final
data reporting.   As used herein, a sample  is
defined as a representative specimen collected at
a specific location of a waste site at a particular
time for a specific analysis. The term sample may
refer  to field  samples, duplicates, replicates,
splits, spikes or blanks that are shipped from the
field to a laboratory.  Whenever questions arise,
samplers should contact SMO or the RSCC for
direction and clarification concerning the proper
completion and distribution of CLP paperwork.

1.  Sample Traffic Report
    RAS  organic  and  inorganic  samples are
documented with  corresponding  CLP sample
Traffic Reports  (TRs), a four part carbonless form.
Each TR may  document up to twenty samples
shipped to one CLP laboratory under one Case
Number  and  one RAS analytical  program.
Samplers must complete the appropriate TRs for
every shipment of  RAS  samples  to a CLP
laboratory.   Copies of properly completed TR
forms are included in the CLP Sampler's Guide.
    TR forms must also be used when an individual
sample is to be analyzed for both RAS and SAS
parameters. A  SAS Packing List must not be used
for RAS + SAS  Cases.  Both the Case number and
the SAS number must be entered at the top right of
the form in order to clearly identify and track the
sampling event. Samplers must take caution not to
include the Case number on "All SAS" samples
taken at the  same  site.   Additionally, the
sampler  must  briefly  describe   the  SAS
requirement on each TR (e.g., "VOA - 1 ppb
detection limit").

    Each TR form includes a Chain-of-Custody
Record.  Information about the Chain-of-Custody
Record follows.
    SMO provides TR forms  to  each Region
through the RSCC.   The RSCC should contact
SMO  two or more weeks in advance to  order
additional TR forms.

2.  SAS Packing List

    For "All SAS" samples, samplers should use
the SAS Packing List (PL), a four part carbonless
form.  The PL provides space to list up to twenty
samples on one form.  SAS samples  are numbered
using  the SAS  number followed by a two digit
number beginning with "01" (e.g., 4100-E-01,4100-
E-02, etc.).  If the sampling activity extends over
several days and more than one PL is used, care
must  be taken not to repeat  sample numbers.
                                        23

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CLP User's Guide
Regions should consult SMO to verify that the PL
is appropriate to use in their situation.

    Alternatively, the samplers may also use TRs
for all SAS requests but must be careful to ensure
that RAS Case numbers  do not appear on those
forms.
    Each SAS PL includes a  Chain-of-Custody
Record.  Information regarding the Chain-of-
Custody Record follows.

    SMO provides SAS PL forms to each Region
through the RSCC.  The RSCC  should  contact
SMO two or more  weeks in advance to order
additional SAS PL forms.

3.   Sample Number

    A unique sample number, recorded on the TR
and SAS PL, identifies each sample. Inorganic
and organic/VOA sample numbers have different
formats and are not interchangeable.  Strips of
adhesive  labels  preprinted with individual
sample numbers are provided by SMO with TR
forms.   Samplers must  provide sample labels,
marked in indelible ink with the  appropriate
SAS sample numbers, for use with "All SAS"
samples.

    The sampler affixes  the sample label to the
corresponding containers that make up the sample
and, if appropriate, to the outside of the metal
can in which the sample  is packed (see Section D
for packaging requirements).  The top edge of the
label should be placed at the level of initial
sample volume so that any loss of volume can be
easily detected. In order  to protect the labels from
the effects  of  water and solvent,  labels are
covered with clear, waterproof tape.

4.   Sample Tag

    Each sample removed from a waste site and
transferred to a laboratory for analysis must be
identified by a sample tag which contains specific
sample information as defined by NEIC.  Sample
tags are retained  by the laboratory as physical
evidence of sample receipt and analysis.  Sample
tags may be obtained through  the Regional office;
in some instances, sampling contractors may be
required to provide their own sample tags.  An
example sample tag is shown in Figure 15.

    Additionally,  the  sample  tag  contains
appropriate spaces for noting that the sample has
been preserved  and indicating the analytical
parameter(s) for which  the sample  will  be
analyzed.  After the  sample tag is  completed,
each  tag  is  securely  attached  to  the sample
container. Samples are then shipped under chain-
of-custody  procedures as  described in  the
following section.
5.  Chain-of-Custody Record
    In accordance  with Agency enforcement
requirements, official custody of samples must be
documented from the time of collection until the
time of introduction as evidence during litigation.
The Chain-of-Custody Record is not a separate
document and is included as part of  the Sample
Traffic Reports and SAS Packing Lists.

FIGURE 15. SAMPLE TAG
'8
            6 Ğ•ğ
              O
              fcs
                      Preservative:
                       Y CD N CT
                        ANALYSES
                      BOO Artons Solids
                      TSS)(TOS)(SS)
                      COO. TOO. Nutrients
                      Phenolic*
                      Metal*
                      Cyanide
                      VOAorgaract
                      Pesticides
       TagN
       7712
    A sample is considered to be in an individual's
custody if any of the following criteria are met:  1)
the sample is in your possession or it is in your
view after being in your possession; 2) it was in
your possession and then locked up or sealed to
prevent tampering;  or 3)  it is in a  secured area.
The team member  performing the sampling is
responsible for  the care and custody of the
collected  samples  until they are  dispatched
properly. In follow  up, the sampling team leader
reviews all field activities to confirm  that proper
custody procedures were followed during the field
work.

    The Chain-of-Custody Record is employed as
physical  evidence  of  sample custody.   The
sampler completes a Chain-of-Custody Record to
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                                                Chapter HI - Utilization of Analytical Services
accompany each cooler shipped from the field to
the laboratory.  Chain-of-Custody Record forms
can be obtained through the Regional office.
    The sampler records the project  number,
samplers' signatures and the Case and/or SAS
number as header information on the Chain-of-
Custody Record. The commonly known name of the
site should not be included since CLP laboratories
may perform work for the responsible party of
that site.  For each station number, the sampler
indicates  date, time, whether the sample is a
composite or grab, station location, number of
containers, analytical parameters, CLP sample
number(s) and  sample tag number(s).  When
shipping  the  samples, the sampler signs  the
bottom of the form and enters the date  and time
the samples are relinquished.  The sampler enters
shipper  name  and  airbill number  under  the
"Remarks" section on the bottom right of the form.

    The  custody record  is  completed using
waterproof ink.  Any corrections are  made by
drawing a single, ball-point pen line  through,
initialing and dating the error, then entering the
correct  information.  Erasures or use of fluid
correction procedures are not permissible.

    The original signature copy of the Chain-of-
Custody Record is enclosed in plastic (with CLP
sample documentation) and secured to the inside
of the cooler lid.  A copy of the custody record is
retained  for the sampler's  files.   Whenever
samples  are split with a source or government
agency,  a separate  Chain-of-Custody Record
should be prepared for those samples to indicate
with whom the samples are being split and
sample tag serial numbers from splits.
    Shipping coolers are secured and custody seals
are placed across cooler  openings.  As long as
custody forms are sealed inside the sample cooler
and custody seals  remain  intact,  commercial
carriers are not required to sign off on the custody
form.

    The laboratory  representative  who accepts
the incoming sample shipment signs and dates the
Chain-of-Custody Record to acknowledge receipt
of the samples.  Once tfte sample transfer process
is complete,  the laboratory  is responsible for
maintaining internal logbooks and records that
provide  a custody record throughout sample
preparation and analysis.
D.  Sample Packaging and Shipment

1.  Packaging Requirements
    Samples processed through the CLP must be
packaged for shipment in compliance with the
most current U.S. Department of Transportation,
state,  local, and  commercial carrier regulations.
All required government and commercial carrier
shipping papers must be filled out and shipment
classifications  made  according   to  these
regulations.  (Consult Appendix C for shipping
references.)
    Waterproof, metal or hard plastic ice  chests
or coolers are the only acceptable type of sample
shipping container.  Inside the cooler, sample
containers must be enclosed in clear plastic bags so
that sample tags and  labels are visible.  Water
and soil samples suspected to be of medium/high
concentration or soil samples suspected to contain
dioxin must be enclosed  in a metal can with a
clipped or  scalable lid (e.g., paint cans). The
outer metal can must be labeled with the number
of the sample contained inside.  Containers  which
do not fit into paint cans should be double bagged.
    Shipping containers should be packed with
noncombustible, absorbent packing material (e.g.,
vermiculite) surrounding the sample bottles or
metal  cans containing samples to avoid breakage
during transport.  Earth or loose ice should never
be used to pack samples; earth is a contaminant,
and ice melts resulting in container breakage.

    Water samples for low level organic analysis
and low/medium level cyanide analysis must be
cooled to 4° C  with ice when shipped.  Shipping
with  ice  is   optional  for soil  samples for
low/medium  level  organic analysis  or
low/medium level cyanide analysis.  Ice  is not
required in shipping high concentration water or
soil samples  for organic analysis  or  for any
matrix/concentration samples for metals or dioxin
analysis.  Ice should  be in  sealed plastic bags to
prevent melting ice from soaking packing material
which, when soaked, makes handling of samples
difficult in the laboratory.

    Low level inorganic and VOA water samples
require chemical  preservation. Users  should
consult Chapter  II as well as the analytical
method  and  Regional  requirements  for
preservation techniques.

    TRs, SAS PLs, Chain-of-Custody Records, and
any other sample documentation accompanying
                                         25

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CLP User's Guide
the shipment must be enclosed in a waterproof
plastic bag and taped to the underside of the
cooler lid. Coolers must be sealed with custody
seals in such a manner that the custody seal would
be broken if the cooler were opened.
    Shipping  coolers must have  clearly visible
return address labels on the outside.  Shipping
coolers that  are labeled  in this manner will be
returned to the sampler by the laboratory within
fourteen days  following  laboratory sample
receipt.
2.  Shipping Instructions

    All samples should be shipped through a
reliable commercial carrier, such  as Federal
Express,  Emery,  Purolator  or  equivalent.
Sampling offices are responsible for sample
shipping charges.
    Samples for organic analysis must be shipped
for overnight delivery. If shipment requires more
than a 24-hour period, 40 CFR sample holding
times might be exceeded, thus compromising the
integrity of  the sample analysis.   Samples for
inorganic RAS analysis  should  be held until
sampling for the Case is  complete and  then
shipped for  two-day delivery.  In the  inorganic
RAS program, three days is the recommended
period for collection of a Case of samples.

    The NEIC/Denver and the ERT/Cincinnati
hazardous waste site manuals provide  extensive
information on EPA-approved sample packaging
and shipment techniques.  References  for these
materials are provided  in  Appendix C.   In
addition, general  questions concerning sample
packaging and shipment may be directed to SMO.

    To facilitate return of the coolers, shippers
should clearly mark the name and address of
return destination on the coolers.  Use of stencils
and paint is  highly recommended for permanent
identification.

3.  Shipment Coordination

    To enable SMO to  track the shipment  of
samples  from the field to the laboratory and
ensure timely laboratory receipt of samples, the
sampler must notify SMO of all sample shipments
on the day of shipment.   At that time,  the
sampler  should  provide   the  following
information:

    •   Sampler name and phone number.
    •   Case number and/or SAS number of the
       project.
    •   Exact number(s), matrix(ces) and
       concentration(s) of samples shipped.
    •   Laboratory(ies) to which samples were
       shipped.
    •   Carrier name and airbill number(s) for the
       shipment.
    •   Method of shipment (e.g., overnight, two-
       day).
    •   Date of shipment.
    •   Suspected contaminants associated with
       the samples or site.
    •   Any irregularities or anticipated
       problems with the samples, including
       special handling instructions, or
       deviations from established sampling
       procedures.
    •   Status of the sampling project (e.g.,  final
       shipment, update of future shipping
       schedule).
    Sample shipments made after 5:00 p.m. EST
should be called in to  SMO at the start of business
the next day (8:00 a.m. EST).   SMO must  be
notified by 3:00 p.m. EST Friday of sample
shipments intended for Saturday delivery. CLP
laboratories remain  open to receive  Saturday
shipments only upon advance notification by SMO
and only when shipment information has been
provided to SMO by the sampler.

    The success of sample shipment coordination
depends on the proper use  and handling  of the
sample tracking  forms and  timely,  complete
communication among the RSCC, samplers, SMO
and  laboratories.    Any   postponements,
cancellations, changes in the number or type of
samples to be collected  or changes  in shipping
dates must be communicated to SMO immediately.

E  Procedures for Problem Resolution

1.  Resolving Problems Concerning Sample
    Shipment and Analysis

    Program laboratories notify SMO of problems
with sample receipt  or during sample analysis.
SMO immediately contacts the RSCC to relay the
problem and to assist in formulating a solution.
SMO  then contacts the laboratory  involved to
communicate the recommended action  and to
authorize processing of the sample(s) in question.
Timeliness is the key  to problem resolution since
                                        26

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                                                 Chapter III -  Utilization  of Analytical Services
delays could affect contractual time requirements
for sample extraction  and analysis  and, if
extreme, could invalidate the analysis.
    Users should refer general questions regarding
sample  shipment, required sample analysis,
laboratory contracts  or the  status  of data
deliverables on a particular Case or SAS to the
appropriate SMO personnel through the RSCC.
Technical questions regarding contract analytical
procedures should be' referred to the TPO of the
laboratory or the APO if the TPO is unavailable.
2.  Resolving Problems Concerning Analytical
    Data
    In  the   CLP's   Regional/Laboratory
Communication  System, authorized Regional
personnel  can  contact  specified  laboratory
personnel to resolve questions regarding  the final
data package. This system may only be used after
laboratory data submission and may never be used
to initiate additional analytical work to resolve
data questions.   All communications  between
laboratories and Regional contacts are recorded by
each  party  on  a  Telephone Record  Log.
Documented information includes Case and/or
SAS number, individuals making contact, subject of
the discussion and its resolution. As  a follow up,
the Region and  laboratory  send  copies of
completed telephone logs to SMO, where the logs
become a permanent part of the Case/SAS file.
Telephone Record Logs are available from SMO.
    Prior to the laboratory's submission of the
final data package, client queries regarding those
analyses or data are handled by SMO through the
RSCC. Depending on the nature of the question,
SMO will respond or will direct the  client to the
appropriate  NPO  official  for   resolution.
Comments regarding laboratory performance,
whether positive or negative, should be directed
in writing to the TPO of  the laboratory with a
copy provided to the APO.
                                         27

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                                    CHAPTER IV

                      AUXILIARY SUPPORT SERVICES
  In this chapter...
  Shipment Management Program
   Sample Coolers
   Contract Compliance Screening Results
  Information Services
   Backlog Status Reports
   Sample Status Information
   General Program Information
  Enforcement Support
   Generation of Known Quality Data Suitable
     for Use in Enforcement/Litigation
   Additional CLP Enforcement Support
  Cost Recovery Substantiation
  Contract Compliance Screening
  Data Review Services
    The CLP provides several supplementary
services  that have  developed  as a  natural
extension of the program's analytical services.  A
description  of each  auxiliary service and the
procedures for accessing the service are provided
in the following sections.

A. Shipment Management Program

    The  Shipment  Management  Contractor
establishes, maintains and monitors all shipping
accounts for the transportation of CLP materials.
Currently, the Contractor coordinates accounts for
the shipment of sample containers, sample coolers
and contract compliance screening results. Other
items that are routed for CLP use may also be
addressed by this program at the request of the
NPO.
1.  Sample Coolers

    Field  samplers package samples into coolers
for transportation to contract laboratories per the
procedures specified  in Chapter III, Section D.
Sampling contractors  are  responsible for clearly
marking a return address  on the outside of each
cooler. Contract laboratories are required to return
each cooler to  the indicated sampling office
within fourteen  days of  sample receipt.   The
Shipment Management Contractor is responsible
for tracking and paying for cooler shipments from
the laboratories to the sampling offices.
2.  Contract Compliance Screening Results
   After reviewing each data package via the
Contract Compliance Screening (CCS) process (see
Section F), SMO distributes  the results  to
EMSL/LV, the appropriate Region and the
appropriate laboratory. SMO also sends a copy of
the  air  carrier  manifest  to  the  Shipment
Management Contractor who uses the manifest to
verify and pay shipping invoices. If any problems
arise regarding the shipment of CCS results, both
SMO and the Shipment Management Contractor
should be notified immediately.

B. Information Services

1.  Backlog Status Reports
   SMO distributes  the  Laboratory Sample
Backlog Status Report  and Regional Sample
Backlog Status Report. These reports  show the
status  of each sample until it is complete  or
continues to be incomplete for a maximum of 180
days. These reports are distributed twice monthly
to all TPOs, RSCCs and Contract Laboratories.
a.  Laboratory Sample  Backlog Status Report

   The Laboratory  Sample  Backlog  Status
Report  is  available  by laboratory  contract.
Information is presented  by laboratory contract
number and Case number.  Contract  type and
Regional Lab location are  indicated for each
contract.  SDG number; sample  number; sample
suffix; data due date  (DDD); data receipt date
(DRD), if  applicable;  number of days  late,  if
applicable; data  complete  date (DCD) and  a
status message are also indicated.

   The sample  suffix  column  is  used  to
distinguish additional  analyses performed on an
original sample. These  codes include:
       B
       M
       D
       Q
       R
Blanks
Matrix
Duplicate
Requested Rerun
Replicate
                                        28

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                                                       Chapter IV - Auxiliary Support Services
       X      =      Automatic Rerun
       L      =      Laboratory Control
                     Sample
    There  are six  sample  status  messages.
Samples only appear under one status message.
The status messages are as follows:

    (1) Data Not Due - This message indicates
       that samples have been received by the
       laboratory, but the data have not been
       received and are not yet due.
    (2) Data Late - This message indicates that
       the due date has past and data have not
       yet been delivered by the laboratory. If
       this message appears in the status column
       for a sample,  the number of days late will
       appear in the days late column.
    (3) In CCS Review - This message indicates
       that data for a sample have been received
       and the results of the Contract
      • Compliance Screen have not been sent to
       the laboratory.
    (4) In 10 Day Resolution Period - This
       message will appear in the Status column
       for any sample data which have been
       received, screened and screening results
       sent to the laboratory, but the 10 day
       resolution period has not yet passed. The
       resolution period is 10 days from the date
       the laboratory receives the screening
       results. The laboratory  has 10 days to
       resolve any noncompliance issues,
       including technical noncompliance and
       incompleteness.
    (5) Incomplete After XX Days - This message
       will appear when data  have been
       received, screened and the 10 day
       resolution period has passed, and the
       sample data remain incomplete.  The
       number of days since the lab received the
       initial screening results  is printed in the
       status column. This sample will continue
       to appear on the backlog list until it
       remains incomplete for 180 days.
    (6) Complete - This message will appear in
       the Status column for any sample made
       complete since the last Backlog Status
       Report was generated.
b.  Regional Backlog  Status Report

    The Regional Sample Backlog Status  Report
is very  similar to the  Laboratory Report. The
status information is presented by Client, rather
than by laboratory.  The laboratory code name
and contract type are listed for each sample next
to the sample suffix column.

   Both the Laboratory and  Regional  Sample
Backlog Status Reports include three totals at the
end  of each  report.  The  "total number of
outstanding samples" includes samples for which
data are not due, late, in 10 Day Resolution period
or are incomplete. The "total number  of samples
late" includes only those samples which do not
have an initial data receipt date.  If data were
received, but were incomplete, it would not count
in this  category.  "Total Number of Samples
Incomplete" refers to samples that either are in
the  10 Day  Resolution  Period or  remain
incomplete after the 10 day resolution period has
passed.
2. Sample Status Information

   After  scheduling  analysis, SMO  tracks
samples from shipment through data reporting
via manual and computerized tracking systems.
SMO maintains ongoing communication with the
TPOs, RSCCs and laboratories regarding sample
status and responds to inquires from concerned
parties, as appropriate.
3. General Program Information
   Under the direction of CLP management, SMO
serves  as  the  program's information center for
incoming  calls and correspondence.  Program
participants and other  interested parties may
request from SMO information and materials on
program services and procedures.  SMO provides
this information when possible and refers callers
to the proper sources for additional information.

C Enforcement Support

1. Generation of Known Quality Data Suitable
   for Use in Enforcement/Litigation

   One major objective of Superfund is to recover
costs incurred in the investigation and  clean up of
hazardous waste sites from responsible  parties.
The process by which these parties are identified
and determined to be responsible often involves
litigation.  Frequently, procedures necessitate the
use of  CLP data generated from the  analysis of
samples  collected at a given site.   The CLP
supports these and other enforcement requirements
of Superfund by ensuring that CLP analytical data
are  documented and  available  for  litigation.
Through NEIC, the CLP has established detailed
                                         29

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CLP User's Guide
procedures and documentation to ensure that
sample data meet Agency enforcement standards.

   Each CLP analytical  contract requires the
laboratory   contractor  to   implement   a
comprehensive document control system and to
employ strict chain-of-custody documentation
procedures in the receipt and handling of samples
throughout  the analytical and data reporting
process. The laboratory must have the following:
    •   written standard operating procedures for
       receipt and log-in of samples,
    •   maintenance of sample security after log-
       in,
    •   tracking of samples through all steps of
       preparation and analysis, and
    •   organization and assembly of all sample-
       related documentation on a Case-specific
       basis.
    At a minimum, required document control and
chain-of-custody records include

    •   custody records,
    •   sample tracking records,
    •   analyst logbook pages,
    •   bench sheets,
    •   chromatographic charts,
    •   computer printouts,
    •   raw data summaries,
    •   instrument logbook pages,
    •   correspondence and document inventory.
    Before a laboratory is awarded a CLP contract
and continuing periodically throughout the life of
the contract, NEIC  audits  each laboratory
facility  to  ensure compliance with chain-of-
custody and document control requirements. In
addition  to facility audits,  NEIC  reviews
laboratory data and evidence documentation on a
regular basis.
2. Additional CLP Enforcement Support

   Court  appearances  and  other  mandated
deadlines often do not allow sufficient time for
completion of the normal complete SDG File, data
package, and traditional  file purge  package
submission, review and  audit process.  In this
event, enforcement activities require direct CLP
support.   Data  package  evaluation  and/or
testimony from laboratory or CLP personnel may
also  be needed.  Through SMO,  the CLP has
established procedures to  coordinate and respond
to short term (no more than 180 days) enforcement-
related  requirements.   These procedures  are
detailed in  Figure 16.
   OWPE  provides this  CLP information  along
with documentation gathered from other sources
to the Regional case development team in the full
cost recovery package.
 FIGURE 16. ADDITIONAL CLP ENFORCEMENT SUPPORT
Request
through
NPO















Lead
Time
2 weeks















Request Procedures
• Submit the enforcement-
related request in a
memorandum to the NPO.
• NPO reviews the
memorandum, determines the
CLP response, and forwards
the request and directions to
SMO.
• If a request requires
immediate response, the
requestor should contact
SMO directly by telephone
and follow up with a written
request memorandum to the
NPO.


Requestor Information
Required
• Name and telephone number
of Regional contact
coordinating the enforcement
activity
• Case/SAS number(s) of
specific site sampling(s)
• Sample number(s)

• Date(s) of sample collection
• Laboratories) that
performed the analysis
• Type of support needed




Documentation Provided
By CLP
• Arranges for the timely
delivery of all laboratory and
evidence documentation
relating to specific sample
analyses (within a minimum of
seven days of request, if
designated).
• Obtains information relating
to sample analysis or handling
not specifically required
under laboratory contracts.
• Assists in arranging for
expert testimony by
laboratory or CLP personnel.
• Augments Regional resources
for analytical data review.
                                         30

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                                                      Chapter IV - Auxiliary Support Services
FIGURE 17. COST RECOVERY SUBSTANTIATION
Request
through
OWPE










*>


Lead
Time
4-6
weeks












Request Procedures
• Complete a Cost Recovery
(CR) checklist
• Mall completed CR checklist
to OWPE
• OWPE collects and organizes
cost-related documentation








Requestor Information
Required
• Name and state of site
• Site/Spill ID
• Date the cost report is
needed










Documentation Provided
By CLP
• Financial Summary ,for Cost
Analysis
• Summary of Invoices,
Vouchers and Canceled
Checks
• Routine Analytical Services
Cost Report
* Routine Analytical Services
Case Sample List
* Special Analytical Services
(SAS) Cost Report
• Copies of all SAS-Related
Canceled Checks and
Laboratory Invoices
D.  Cost Recovery Substantiation
    The CLP provides documentation for program
analytical costs  to  the  EPA's Office  of Waste
Programs Enforcement  (OWPE) in support of
Superfund cost recovery efforts. These procedures
are detailed in Figure 17.

E.  Contract Compliance Screening (CCS)
    SMO performs CCS on all RAS data produced
by the CLP.  Modified CCS can also be performed
on a case-by-case basis on "RAS Plus SAS" or "All
SAS" data.
    CCS is a structured review which determines
completeness of data deliverables and compliance
of   QA/QC  parameters  with  contract
specifications. The primary objectives of CCS are
to resolve identified discrepancies  in  a timely
manner and to identify  the liquidated  damages
category for data not in compliance.  Data which
meet all  CCS  criteria at  initial  receipt are
recommended for 100%  payment of the amount
due.  Data with CCS defects are recommended to
have   some  payment   withheld,  either
temporarily or permanently, depending on the
nature and extent of the defect identified.
    CCS procedures are applied  to  organic,
inorganic and dioxin  data.  CCS  results are
produced on a fast-turnaround basis (fifteen days)
and identify compliance discrepancies  by  code,
criterion, fraction  and  sample.   Results are
distributed to the relevant laboratory, Region and
EMSL/LV.
   Results are accumulated in the CCS Database
in order  to  produce  routine  and  requested
summaries  of laboratory performance  and
compliance trends.

F. Data Review Services
   A full range of review services are  used to
assess CLP data. Objectives of the review services
are:
   •   To determine the useability and
       limitations of data given particular field
       or policy assessment criteria.
   •   To maximize the amount of useable data
       by identifying critical properties of data
       and by resolving or proposing solutions to
       analytical or quality control problems.
   •   To provide systematic and standardized
       data quality assessment and status
       summary to determine method, laboratory
       and program performance.
   These review services are performed by a
number of operations:
   •   Review for data useability is performed
       by Regional personnel and contractors.
       Recommended review procedures have
       been standardized and organized into
       functional guidelines for evaluating CLP
       data.  EPA Data Validation Workgroups
       have produced specific documents for
       review of organic, inorganic and dioxin
       analyses.
                                         31

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CLP User's Guide
FIGURE 18. DATA REVIEW SERVICES
Request
through
SMO,
APO,
RSCC










Lead
Time
2 weeks












Request Procedures
• Complete SMO Data Review
Request memorandum
• Submit copies of the
memorandum to SMO (Attn:
Data Review Team), the SMO
APO and the RSCC.

• Upon APO approval, SMO
schedules the review and
notifies the requestor of the
date of scheduled completion.
Data review cannot be initiated
until all deliverables lor the
subject Case(s) have been
received from the laboratory.


Requestor Information
Required
• SMO Case number
• Site name
• Analytical laboratory name(s)
• Number of samples
• Sample list

• Type(s) of review requested
• Requested date for review
completion
• User name and contact
* IntGndod USG of d3ls




Documentation Provided
By CLP
• An evaluation report that
includes a sample/result matrix
and supporting statistics and
documentation is produced for
each type of review. For each
sample fraction, the report
indicates whether the data are
considered acceptable,
acceptable given qualifications
noted or unacceptable.
Reasons for the designation
are discussed and complete
data review forms for each of
the areas of performance are
included in the report to the
client.
      Comprehensive QA review is performed
      by EMSL/LV on specific data packages.
      Review and assessment of some program-
      wide QA results are also performed by
      EMSL/LV to evaluate method and
      laboratory performance and  the quality of
      analytical data.
      Under direction of the CLP management,
      EMSL/LV and/or SMO may perform
      additional data review to assess a
      problem Case or provide a second opinion
      on data useability.
      Under direction of the CLP management,
      SMO third party data reviews may be
       used to resolve disputes, especially for
       SAS cases.
    All requests for SMO data review services
should be placed using the SMO Data  Review
Request  memorandum available from SMO.
Request procedures are detailed in  Figure 18.
Copies of the request should be submitted to SMO
(Attention:  Data Review Team), the SMO PO and
the RSCC. Upon authorization by the  APO, SMO
schedules the review and notifies  the requestor of
the date of scheduled completion. (Data  review
cannot be initiated until all deliverables for the
subject Case(s) have  been received from the
laboratory.)
                                       32

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                                   CHAPTER V

               LABORATORY SELECTION AND STARTUP
  In this chapter...
  Laboratory Selection Process
   Qualification Requirements
   Bidder Responsibility
  Laboratory Startup Process
   APO
   APO/TPO/SMO/Laboratory Communication
  Laboratory Performance Evaluation
   Performance Evaluation Sample Analysis
   On-site Laboratory Evaluation
   Corrective Action
A. laboratory Selection Process

   From time to time, when EPA needs to replace
existing IFB contract resources where contracts are
due to expire, to increase capacity over what is
currently provided under existing contracts, or to
initiate a procurement for a new type of analysis,
EPA solicits laboratories for the CLP.  This
process is summarized in Figure 19. EPA solicits
bids from interested laboratories, evaluates each
laboratory on  the  basis of the criteria  listed
below, and awards contracts to qualified, low-
bidding laboratories.

1.  Qualification Requirements

a.  Bid Price
    The first criterion for laboratory selection is
bid price.  Following bid opening, the bid prices
are reviewed  and evaluated by NPO and
Contracts Management Division (CMD) officials.
The lowest  competitive bidders will be sent
performance evaluation (PE) samples  at  the
direction of the Contracting Officer (CO).

b.  Preaward Performance Evaluation Sample
FIGURE 19. THE CLP LABORATORY SELECTION PROCESS
                Bid Sol
     Bid Evaluation
Contract Av\
Bidders are required to
aubmrtvwth PE sample
results
1) functional descnptions
and detailed resumes of
key personnel,
2) inventory of laboratory
equipment and description
of laboratory space, and
3) written Standard
Oper
iting Procedures.


                                       33

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CLP User's Guide
   Analysis
   The second criterion for laboratory selection is
acceptable preaward PE sample analysis.  PE
samples are sent to laboratories at the direction of
the CO.
   PE  samples,  distributed  by  EPA,  are
representative of the types of field samples that
the laboratory would be routinely analyzing under
the subject  procurement.   The laboratory is
required  to  analyze PE  samples  according to
contract procedures set forth in the IFB and to
report PE  sample data  according  to  IFB
requirements. The turnaround time for PE sample
data submission is indicated in each IFB.  Bidders'
PE sample  data  are  evaluated by  NPO and
EMSL/LV personnel for compliance with contract
requirements and accuracy of determination of
compounds at  the levels known to be in the PE
samples.   Analysis results are  rated  by  a
scoresheet developed by the EPA;  currently, the
acceptable performance  score  is  seventy-five
percent.
2. Bidder Responsibility

a. Bidder-Supplied  Documentation
   At the time of submission of PE sample data,
bidders are required  to submit documented
evidence that they have the internal procedures,
equipment and personnel in place  for successful
performance of contract requirements.  Required
documentation includes:

    •   functional descriptions and detailed
       resumes of key personnel;
    •   inventory of laboratory equipment;
    •   description of laboratory space; and
    •   written Standard Operating Procedures
       (SOPs).
   Submitted documentation is reviewed by NPO
and EMSL/LV personnel and is utilized by the
EPA in performance of the site evaluation. After
contract award, bidders are required to submit
revised SOPs to the APO.

b. Laboratory  Site  Evaluation

   NPO,  TPO,  CMD,  EMSL/LV  and  NEIC
personnel  participate in  on-site evaluations of
laboratory facilities of bidders which scored
acceptably on  the PE  sample analyses and are
within the EPA-determined competitive range.
The  results  of  the  on-site  evaluation  are
considered in the final determination of bidder
responsibility for contract award.

B. Laboratory Startup Process

   Laboratories are expected to  be  capable of
receiving full contract sample requirements upon
award.   At award,  laboratories  must provide
standards in compliance with the performance
specifications supplied in the contract.

1.  APO Review of First Data Packages

   Initial  data  packages   are  targeted for
immediate review and evaluation by the  APO,
EMSL/LV and the Region. This intensive review
focuses on any problems the laboratory may have
in  applying methodologies or in reporting data.
The  APO  and TPO supply feedback to the
laboratory concerning the status of the data and
work with  the laboratory  in identifying and
remedying problems. Depending on the extent of
the problems found during the review of an initial
data package,  the APO or  TPO  may  visit the
laboratory  facility  and  work   on-site  with
laboratory personnel to rectify problems.

2.  APO/TPO/SMO/Laboratory Communication

   Telephone communication is the most widely
applied  method  for  problem-solving  and
maintaining efficient laboratory  operations
during both the laboratory startup  phase and
throughout the performance of the contract. In
general,   the  laboratory  notifies   SMO
immediately upon identification of any problem
regarding the samples.  Any questions regarding
difficulties encountered in  analysis  should be
addressed to the  TPO of the Region of sample
origin with SMO serving as a go-between to record
resolution of the issue.  SMO routinely resolves
sample-related problems in coordination with the
Regional client  and  refers technical problems to
the APO or TPO, who then contacts the laboratory
to  resolve the problem.  The resolution and any
specific  actions  taken  are reported  to the
appropriate SMO personnel who records this
information as part of the permanent Case record.
The  laboratory also records the problem and
resolution in the narrative portion of the sample
data report so  that the Region will consider this
information when evaluating and using the data.
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C  Laboratory Performance Evaluation

1.  Performance Evaluation Sample Analysis

    EPA may distribute PE samples to contract
laboratories for analysis.   EMSL/LV evaluates
the laboratories' PE  sample data, and the NPO
uses  this  evaluation  in  formally  assessing
laboratory  contract performance.  Additionally,
EMSL/LV  enters  PE  sample  data into  the
program's QA and Results Database. These data
are utilized, along with other laboratory data, in
trend analyses and  evaluation  of  contract  QC
criteria. Refer to Chapter VI, Section C for a more
detailed description of PE samples.
2.  On-site Laboratory Evaluation

    Regional, NEIC and EMSL/LV personnel visit
each  contract  laboratory  facility  in order to
evaluate laboratory procedures or to identify
laboratory problems for correction. The frequency
of on-site  evaluation depends, in part, upon
laboratory  performance.   The  APO and TPO
utilize the  evaluation reports which result from
these on-site visits in identifying and remedying
laboratory  performance problems.  Chapter VI,
Section  E  details  the  on-site  laboratory
evaluation  process.
3.  Corrective Action
    The APO and TPO, work closely with each
laboratory to  correct  identified  laboratory
performance problems. Depending on the scope of
the problems, the laboratory may be placed on
temporary  hold and will not receive additional
samples for analysis until the problem has been
corrected.
    If the laboratory's noncompliance to contract
performance or delivery requirements continues,
the NPO may request the CO to initiate a contract
action such as  a Show Cause Notice or a Cure
Notice.
    Chapter V - Laboratory Selection and Startup


    A Show Cause Notice requires the Contractor,
within a ten-day period, to present any facts the
government  can  use  to  determine  if  the
Contractor's failure to perform arose without any
fault or negligence on the part of the Contractor.
The Contractor must  submit substantial evidence
to demonstrate that  the contract should not be
terminated for default.   A recovery plan is
generally included as part of the Contractor's
response to the Show Cause Notice.  NPO and
CMD officials review the  Contractor's response
and proposed recovery plan to determine whether
the Contractor has presented sufficient evidence
to  demonstrate  timely  remedy   of  the
noncompliance.  Following this review, if  the
Contractor has presented  acceptable evidence
toward recovery, the government issues a Cure
Notice to the Contractor.
    A  Cure Notice specifies the  Government-
accepted recovery plan  that the Contractor must
follow to  avoid contract termination.   The
recovery plan includes actions and time schedules
for completion of each step of the recovery process,
and specifies an overall time period acceptable
for completion of recovery.
    Should  the  Contractor not comply with  the
recovery schedule, the Government's next and
final step may be contract termination for default.
In addition  to terminating the  laboratory's
contract, this  action affects the evaluation of the
laboratory's responsibility for award under future
CLP solicitations.
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                                     CHAPTER VI
                      PROGRAM QUALITY ASSURANCE
  In this chapter...
  Laboratory Quality Control Criteria
    Standard Operating Procedures
    Quality Assurance Plan
    Analytical Standards Traceability
      Requirements
  Analytical Data Review
    Contract Compliance Screening
    Regional Data Review
  Laboratory Evaluation Samples
  GC/MS Tape Audits
  On-Site Laboratory Evaluations
    Quality Assurance On-Site Evaluation
    Evidentiary Audit
    Discussion of the On-Site Team's Findings
  Corrective Action Reports For Follow-Through
   to Quality Assurance and Evidentiary Audit
   Reports
  Quality Assurance and Data Trend Analysis
  Data Management
    Quality assurance (QA) and quality control
(QC) are integral parts of the CLP.  The quality
assurance process consists of management review
and oversight at the planning, implementation,
and completion stages of the environmental data
collection activity. The QA process ensures that
data provided are of the quality required. The
quality control process includes those activities
required during data collection to produce the
data quality desired and to document the quality
of the collected data.

    During the planning of an environmental data
collection program, QA activities focus on defining
data quality criteria and designing a QC system to
measure the  quality of data  being  generated.
During the implementation of the data collection
effort, QA activities ensure that the QC system is
functioning effectively, and that the deficiencies
uncovered by the QC system are corrected.  After
environmental data are collected, QA activities
focus on assessing the quality of data obtained to
determine its suitability to support enforcement or
remedial decisions.
    A complete QA/QC program includes internal
laboratory QC criteria that must be met to ensure
acceptable  levels of performance.   These
performance levels are determined by QA review.
External review  of  data and procedures is
accomplished by the monitoring activities of the
NPO, the Regions, SMO,  NEIC and EMSL/LV.
Laboratory evaluation samples, magnetic  tape
audits and laboratory on-site evaluations provide
an external QA reference for CLP. A feedback loop
supplies the  results  of  the  various review
functions to  the  contract laboratories  through
direct communication with the APOs and TPOs.
The following sections describe overall  QA/QC
operations and how the CLP meets the  QA/QC
objective.

A.  Laboratory Quality Control Criteria

1.  Standard Operating Procedures

    In order to obtain reliable results, adherence
to  prescribed  analytical  methodology  is
imperative. In any operation that is performed on
a  repetitive  basis,  reproducibility  is  best
accomplished through the  use  of Standard
Operating Procedures (SOPs). As defined by the
EPA,  an SOP  is  a written document which
provides directions for the  step-by-step execution
of an operation, analysis, or  action which is
commonly accepted as the method for performing
certain routine or repetitive tasks.

    SOPs prepared by the Contractor must be
functional: i.e., clear, comprehensive, up-to-date,
and sufficiently detailed to permit duplication of
results  by  qualified  analysts.   All SOPs,  as
presented to the Agency, must reflect activities as
they are currently performed in the laboratory.  In
addition, all SOPs must:

    •   Be consistent with current EPA
       regulations, guidelines, and the CLP
       contract's requirements.
    •   Be consistent with instrument
       manufacturers' specific instruction
       manuals.
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                                                        Chapter VI - Program Quality Assurance
a.
    •   Be available to the EPA during an On-
       Site Laboratory Evaluation. A complete
       set of SOPs shall be bound together and
       available for inspection at  such
       evaluations. During on-site evaluations,
       laboratory personnel may be asked to
       demonstrate the application of the SOPs.
    •   Provide for the development of
       documentation that is sufficiently
       complete to record the performance of all
       tasks required by the protocol.
    •   Demonstrate the validity of data
       reported by the Contractor and explain
       the cause of missing or inconsistent results.
    •   Describe the corrective measures and
       feedback mechanisms utilized when
       analytical results do not meet protocol
       requirements.
    •   Be reviewed regularly and updated as
      . necessary when contract, facility, or
       Contractor procedural modifications are
       made.
    •   Be archived for future reference in
       useability or evidentiary situations.
    •   Be available at specific work stations as
       appropriate.
    •   Be subject to a document control procedure
       which precludes the use of outdated or
       inappropriate SOPs.
    SOP FORMAT:
    The format for SOPs may vary depending upon
the kind of activity for which they are prepared,
however, at a minimum, the following sections
must be included:

    •   Title Page
    •   Scope and Application
    •   Definitions
    •   Procedures
    •   QC Limits
    •   Corrective Action Procedures, Including
       Procedures for Secondary Review of
       Information Being Generated
    •   Documentation Description and Example
       Forms
    •   Miscellaneous Notes and Precautions
    •   References
b.  SOPs Delivery Requirements
    Within  forty-five (45)  days  of contract
receipt, a complete set of SOPs, relevant  to the
contract shall be sent to the Technical Project
Officer, SMO and EMSL/LV. Also, during the
term of performance of the contract, copies of SOPs
which have been amended or new SOPs  which
have been written shall be sent to the Technical
Project Officer, EMSL/LV (quality  assurance
SOPs) and NEIC (evidentiary SOPs).

2.  Quality Assurance Plan

    The  Contractor shall establish  a quality
assurance program with the objective of providing
sound analytical  chemical measurements.  This
program shall  incorporate the  quality control
procedures,  any necessary corrective action,  and
all documentation required during data collection
as  well as  the quality assessment measures
performed by management to ensure production of
acceptable data.
    As evidence of such a  program, the Contractor
shall prepare a written Quality  Assurance Plan
(QAP) which describes the procedures that are
implemented to achieve the following:

    •  Maintaining data integrity, validity, and
       useability.
    •  Ensuring that analytical measurement
       systems are maintained in an acceptable
       state of stability and reproducibility.
    •  Detecting problems through data
       assessment and establishing corrective
       action procedures  which keep the
       analytical process reliable.
    •  Documenting all aspects of the
       measurement process in order to provide
       data which are technically sound and
       legally defensible.
    The QAP must present, in specific terms, the
policies, organization,  objectives, functional
guidelines,  and specific  QA and  QC activities
designed to achieve the data quality requirements
in  each contract.   Where applicable,  SOPs
pertaining to each element shall be included or
referenced as part of the QAP. The QAP must be
available during on-site  laboratory evaluation
and upon written request by the Administrative
Project Officer.

    The following elements should be contained in
the Quality Assurance Plan.
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CLP User's Guide
   A.  Organization and Personnel
       1.  QA Policy and Objectives
       2.  Q A Management
          a.  Organization
          b.  Assignment of QC and QA
              Responsibilities
          c.  Reporting Relationships
          d  QA Document  Control Procedures
          e.  QA Program Assessment Procedures
       3.  Personnel
          a.  Resumes
          b.  Education and  Experience Pertinent
              to this Contract
          c.  Training Progress
   B.  Facilities and Equipment
       1.  Instrumentation and Backup
          Alternatives
       2.  Maintenance Activities and Schedules
   C.  Document Control
       1.  Laboratory Notebook Policy
       2.  Samples Tracking/Custody Procedures
       3.  Logbook Maintenance and Archiving
          Procedures
       4.  Case File Organization, Preparation
          and Review Procedures
       5.  Procedures for Preparation, Approval,
          Review, Revision, and Distribution of
          SOPs
       6.  Process for Revision of Technical or
          Documentation Procedures
   D.  Analytical Methodology
       1.  Calibration Procedures and Frequency
       2.  Sample Preparation/Extraction
          Procedures
       3.  Sample Analysis Procedures
       4.  Standards Preparation Procedures
       5.  Decision Processes, Procedures, and
          Responsibility for Initiation of
          Corrective Action
   E.  Data Generation
       1.  Data Collection Procedures
       2.  Data Reduction Procedures
       3.  Data Validation Procedures
       4.  Data Reporting and Authorization
          Procedures
   F.  Quality Control
       1.  Solvent, Reagent and Adsorbent
          Check Analysis
       2.  Reference Material Analysis
       3.  Internal Quality Control Checks
       4.  Corrective Action and Determination
          of QC Limit Procedures
       5.  Responsibility Designation
    G.  Quality Assurance
       1.  Data Quality Assurance
       2.  Systems/Internal Audits
       3.  Performance/External Audits
       4.  Corrective Action Procedures
       5.  Quality Assurance Reporting
           Procedures
       6.  Responsibility Designation
3.   Analytical Standards Traceability
    Requirements
    The U.S. Environmental Protection Agency
may not supply analytical  reference standards
either for direct analytical measurements or for
the  purpose of  traceability.    All  contract
laboratories may be required  to prepare from neat
materials or purchase from private  chemical
supply  houses  those  standards  necessary  to
successfully and accurately perform the analyses
required in this protocol.

a.   Preparation of Chemical  Standards from the
    Neat  High Purity Bulk Material

    A laboratory may prepare their  chemical
standards  from neat materials  unless  their
contract specifies otherwise.  Commercial sources
for  neat  chemical  standards pertaining  to
compounds listed on the Target Compound List are
given  in the  Appendix C  of the  "Quality
Assurance  Materials  Bank: Analytical Reference
Standards"  Seventh  Edition,  January  1988.
Laboratories  should  obtain the highest required
purity when purchasing neat chemical standards;
standards purchased  at less than 97% purity must
be documented as to why a higher purity could not
be obtained.

b.   Purchase  of Chemical  Standards  Already in
    Solution

    Solutions  of analytical  reference standards
can be purchased by Contractors provided they
meet the following criteria:

    1.  Laboratories must maintain the following
       documentation  to  verify the integrity of
       the standard solutions they purchase:
       a.  mass spectral identification
           confirmation of the neat material
       b.  purity confirmation of the neat
           material
       c.  chromatographic and quantitative
           documentation that the solution
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                                                       Chapter VI - Program Quality Assurance
           standard was QC checked according to
           the following section
    2.  The Contractor must purchase standards
       for which the quality is demonstrated
       statistically and analytically by a
       method of the supplier's choice.

    The laboratory  is responsible for the quality
of the standards employed for analyses under this
contract.

c.  Requesting Standards From  the EPA
    Standards Repository
    Under special  or emergency circumstances
only, solutions of analytical reference materials
can be ordered  from the  U.S. EPA  Chemical
Standards Repository, depending on availability.
The Contractor can place an order for  standards
only after demonstrating that these standards are
not available from  commercial vendors either in
solution or as a neat material.

d.  Documentation of the Verification and
    Preparation of Chemical Standards
    It is the responsibility of each laboratory to
maintain the necessary documentation to show
that the chemical standards they have used in
the performance of CLP analysis conform to the
requirements  previously  listed.    Weighing
logbooks,  calculations, chromatograms, mass
spectra, etc., whether produced by the laboratory
or purchased from chemical supply houses, must be
maintained by the laboratory and may be subject
to  review  during on-site inspection visits.
Documentation of standards preparation may be
required to be sent to EPA for verification of
contract compliance.  In those cases where the
documentation is supportive of the analytical
results of data  packages  sent  to EPA,  such
documentation is  to  be  kept  on file by the
laboratories for a period of one year.

B.  Analytical Data Review

    Upon  completion  of  analysis and  data
reporting, the contract laboratory simultaneously
sends a copy of  the complete data package to
SMO, EMSL/LV and the Regional client. Each of
these groups  performs complementary aspects of
data  review.   SMO CCS  review  identifies
contractual discrepancies;  EMSL/LV review
determines technical quality and consistency; and
Regional data review relates  useability of the
data to a specific site.
1.  Contract Compliance Screening

    CCS is  one  aspect  of the Government's
contractual right of inspection of analytical data.
CCS examines the Contractor's adherence to the
contract requirements based on the sample data
package delivered to the Agency.

    CCS is performed by the Sample Management
Office (SMO) under the direction of the EPA. To
assure a uniform review, a set of standardized
procedures have been developed to evaluate the
sample  data package submitted by a Contractor
against the   technical   and  completeness
requirements of the contract.
    CCS results are mailed to the Contractor and
all  other data recipients.  The Contractor  has  a
period  of  time to correct deficiencies.   The
Contractor must  send all corrections to  the
Regional Client, and SMO.

    CCS results are used in conjunction with other
information  to  measure  overall Contractor
performance and to take appropriate actions to
correct deficiencies in performance.
2.  Regional Data Review
    Contract  laboratory data are  generated to
meet the specific needs of the Regions. In order to
verify the useability  of  data for  the intended
purpose, each Region reviews  data from the
perspective of end-user,  based  upon  functional
aspects  of data quality.  General guidelines for
data review have been developed jointly by the
Regions and the National Program Office.  Each
Region uses these guidelines as the basis for data
evaluation. Individual Regions may augment the
basic guideline review process with additional
review  based on Region-specific or site-specific
concerns.  Regional reviews, like the sites under
investigation,  vary based on the nature of the
problems under investigation and the Regional
response appropriate to the specific circumstances.

    Regional data reviews,  relating useability of
the data  to  a  specific  site are part  of  the
collective assessment process. They complement
the review done  at the Sample  Management
Office, which is designed to identify contractual
discrepancies and the  review done at EMSL/LV
which is designed to evaluate Contractor and
method performance.     These  individual
evaluations  are  integrated  into a  collective
review  that  is necessary for program  and
laboratory administration and management and
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CLP User's Guide
may be used to take appropriate action to correct
deficiencies in the Contractor's performance.

C  Laboratory Evaluation Samples

    Although   intralaboratory   QC   may
demonstrate Contractor and method performance
that can  be tracked  over time,  an external
performance evaluation program is an essential
feature of a QA program. As a means of measuring
Contractor and  method performance, Contractors
participate in interlaboratory comparison studies
conducted by the EPA. Results from the analysis
of these laboratory evaluation samples will be
used by  the EPA to verify  the  Contractor's
continuing  ability  to  produce  acceptable
analytical data.  The results are also used to assess
the  precision  and accuracy  of  the analytical
methods for specific analytes.
    Sample sets may be provided to participating
Contractors  as  frequently as on an SDG-by-SDG
basis as  a recognizable QC sample of  known
composition; as a recognizable QC  sample of
unknown composition; or not recognizable as a QC
material.   The laboratory  evaluation samples
may be sent either by the Regional client or the
National Program Office, and  may be used for
contract action.

    Contractors are required to  analyze the
samples and return the data package and all raw
data within the contract required  turnaround
time.

    At a minimum, the results  are evaluated for
compound  identification, quantification,  and
sample contamination.  Confidence intervals for
the quantification of target compounds are based
on  reported values using population statistics.
EPA may adjust the scores on any given laboratory
evaluation  sample   to  compensate   for
unanticipated  difficulties  with  a  particular
sample.   Contractors are  required to  use the
NIST/EPA/MSDC mass  spectral library to
tentatively identify a maximum number of non-
target compounds in each fraction that are present
above  a   minimal   response.     Tentative
identification  of these compounds, based on
contractually described  spectral interpretation
procedures,  is evaluated and integrated  into the
evaluation process.

    A  Contractor's results on the laboratory
evaluation   samples  will   determine   the
Contractor's  performance as follows:
1.  Acceptable, No Response  Required (Score
    greater than or equal to 90 percent):
    Data meet most or all of the scoring
    criteria. No response is required.
2.  Acceptable,  Response Explaining
    Deficiency(ies)  Required (Score greater
    than or equal to 75 percent but less than 90
    percent):
    Deficiencies exist in the Contractor's
    performance.
    Within 14 days of receipt of notification
    from EPA, the Contractor shall describe
    the deficiency(ies) and the action(s)
    taken to correct the deficiency(ies) in a
    letter to the Administrative Project
    Officer, the Technical Project Officer and
    EMSL/LV.
3.  Unacceptable Performance,  Response
    Explaining Deficiency(ies)  Required
    (Score less than 75 percent):
    Deficiencies exist in the Contractor's
    performance to the extent that the
    National Program Office has determined
    that the Contractor has not demonstrated
    the capability to meet the contract
    requirements.
    Within 14 days of receipt of notification
    from EPA, the Contractor shall describe
    the deficiency(ies) and the action(s)
    taken to correct the deficiency(ies) in a
    letter to the Administrative Project
    Officer, the Technical Project Officer and
    EMSL/LV.
    The Contractor shall be notified by the
    Administrative Project Officer or
    Technical Project Officer concerning the
    remedy for their unacceptable
    performance. A Contractor may expect,
    but EPA is not limited to, the following
    actions: Reduction of the number of
    samples sent under the contract, suspension
    of sample shipment to the Contractor, a
    site  visit, a full data audit, analysis of
    remedial PE samples, and/or a contract
    sanction, such as a Cure Notice.
    Note: A Contractor's prompt response
    demonstrating that corrective actions
    have been taken to ensure the Contractor's
    capability to meet contract requirements
    will facilitate continuation of full sample
    delivery.
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                                                      Chapter VI - Program Quality Assurance
D.  GC/MS Tape Audits (Organks Only)    1.  Quality Assurance On-Site Evaluation

    Periodically, EPA requests from Contractors
the GC/MS magnetic tapes corresponding to a
specific case in order to accomplish tape audits.
Generally, tape  submissions and audits are
requested for the following reasons:
    •   Program overview
    •   Indication of-data quality problems from
       EMSL/LV, SMO, or Regional data
       reviews
    •   Support for on-site audits
    •   Specific Regional requests
    Depending upon  the reason for an audit, the
tapes  from a recent  case, a specific case, or a
laboratory evaluation sample may be requested.
Tape  audits  provide  a mechanism  to assess
adherence to contractual requirements  and to
ensure the consistency of data reported on the
hardcopy/floppy diskettes  with that  generated
on  the GC/MS tapes.   This function provides
external monitoring of Program QC requirements
and checks adherence of the Contractor to internal
QA procedures. In addition, tape audits enable
EPA  to  evaluate the  utility, precision, and
accuracy of the analytical methods.
    The GC/MS tape shall include raw data and
quantitation  reports   for  samples, blanks,
laboratory   evaluation   samples,  initial
calibrations,  continuing calibration, BFB and
DFTPP associated with the case requested.

    Upon  request of  the Administrative Project
Officer or EMSL/LV, the required tapes and all
necessary  documentation shall be submitted to
EPA within seven days of notification.

E  On-Site Laboratory Evaluations

    At a  frequency dictated by  a contract
laboratory's  performance,  the Administrative
Project Officer,  Technical Project Officer or their
authorized representative will conduct an on-site
laboratory evaluation.    On-site  laboratory
evaluations  are  carried out to monitor the
Contractor's ability to  meet selected terms and
conditions specified  in the contract.   The
evaluation process  incorporates  two separate
categories: Quality Assurance Evaluation, and an
Evidentiary Audit.
   Quality  assurance evaluators  inspect  the
Contractors facilities to verify the adequacy and
maintenance of instrumentation, the continuity of
personnel  meeting experience  or education
requirements, and the acceptable performance of
analytical and QC procedures.  The Contractor
should expect that items to be monitored will
include, but not be limited to the following items.

    •   Size and appearance of the facility
    •   Quantity, age,  availability, scheduled
       maintenance and performance of
       instrumentation
    •   Availability, appropriateness, and
       utilization of SOPs
    •   Staff qualifications, experience, and
       personnel training programs
    •   Reagents, standards, and sample storage
       facilities
    •   Standard preparation logbooks and raw
       data
    •   Bench sheets and analytical logbook
       maintenance and review
    •   Review of the Contractor's sample
       analysis/data package inspection
       procedures
   Prior  to an  on-site  evaluation,  various
documentation pertaining to performance of the
specific Contractor is integrated in  a profile
package for discussion during the evaluation.
Items that may be included are previous on-site
reports, laboratory evaluation sample scores,
Regional review of data, Regional QA materials,
GC/MS tape audit reports, results of CCS,  and
data trend reports.

2. Evidentiary Audit

   Evidence  auditors  conduct  an  on-site
laboratory evaluation to determine if laboratory
policies and procedures are in place  to satisfy
evidence handling requirements as  stated in
Exhibit F.  The evidence audit is comprised of the
following three activities

a. Procedural Audit

   The procedural audit consists of review and
examination of  actual  standard  operating
procedures and accompanying documentation for
the following laboratory operations:
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CLP User's Guide
    •   sample receiving,
    •   sample storage, sample identification,
    •   sample security, sample tracking (from
       receipt to completion of analysis) and
    •   analytical project file organization and
       assembly.
b.   Written SOPs Audit
    The written SOPs audit consists of review and
examination of the written SOPs to determine if
they are accurate and complete for the following
laboratory operations:

    •   sample receiving,
    •   sample storage,
    •   sample identification,
    •   sample security,
    •   sample tracking (from receipt to
       completion of analysis) and
    •   analytical project file organization and
       assembly.
c.   Analytical Project File Evidence Audit

    The analytical project file evidence audit
consists  of review  and  examination  of the
analytical  project  file documentation.    The
auditors review the files to determine:

    •   The accuracy of the document inventory
    •   The completeness of the file
    •   The adequacy and accuracy of the
       document numbering system
    •   Traceability of sample  activity
    •   Identification of activity recorded on the
       documents
    •   Error correction methods
3.   Discussion of the On-Site Team's Findings

    The  quality  assurance  and   evidentiary
auditors  discuss  their  findings  with  the
Administrative Project Officer/Technical Project
Officer prior to debriefing the Contractor.  During
the debriefing, the auditors present their findings
and recommendations for  corrective actions
necessary to the Contractor personnel.

4.   Corrective Action Reports For Follow-
    Through to Quality Assurance and
    Evidentiary Audit Reports

    Following an  on-site evaluation, quality
assurance and evidentiary audit reports  which
discuss deficiencies found during the on-site will
be forwarded to the Contractor.  The Contractor
must discuss the corrective actions taken to resolve
the deficiencies discussed during the on-site visit
and discussed in the on-site reports in a letter to
the Administrative Project Officer,  Technical
Project Officer, EMSL/LV (response to the quality
assurance report)  and NEIC  (response to  the
evidentiary report) within 14 days of receipt of
the finding or within  the  time agreed upon
between   the   Administrative    Project
Officer/Technical  Project  Officer  and  the
Contractor. If SOPs are required to be written or
SOPs are required to be amended, the Contractor
must provide  the SOPs  to the Technical Project
Officer, EMSL/LV (quality assurance/technical
SOPs)  and NEIC (evidentiary SOPs)  within 30
days of receipt of the  finding or within the time
agreed upon between  the Administrative Project
Officer/Technical  Project  Officer  and  the
Contractor.

   If the Contractor  fails to  take appropriate
corrective  action  to  resolve  the  deficiencies
discussed in the on-site reports, a Contractor may
expect, but the Agency is not  limited  to,  the
following actions:  reduction of the number of
samples  sent under the contract, suspension of
sample shipment to the Contractor, a follow-up
site visit, a full data audit,  analysis of remedial
PE samples and/or contract sanction, such as a
Cure Notice.

F. Quality Assurance and Data Trend
   Analysis

   Data submitted by laboratories are subject to
review from several  aspects:  compliance with
contract-required QC, useability, and  full data
package evaluation.  Problems resulting from  any
of these  reviews may determine the need for a
GC/MS  tape  audit, an on-site  laboratory
evaluation  and/or  a  remedial laboratory
evaluation sample.  In addition, QC prescribed in
the  methods  provides  information  that is
continually used by the Agency to assess sample
data  quality,  Contractor  data  quality and
Program data  quality via data trend analysis.
Trend  analysis is accomplished by entering data
into a computerized data base.  Statistical reports
that  evaluate  specific  anomalies  or  disclose
trends in many areas are generated from  this
database.

   Program-wide statistical results are used to
rank laboratories in order to observe the relative
                                         42

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                                                       Chapter VI - Program Quality Assurance
performance of each Contractor using a given
protocol against its peers.  The reports are also
used to identify trends within laboratories. The
results  of  many of these trends analyses are
included in overall evaluation  of a Contractor's
performance, and are reviewed to  determine if
corrective  action  or  an  on-site  laboratory
evaluation  is indicated in order to  meet the
QA/QC requirements of the contract.

    Contractor performance over time is monitored
using these trend analysis techniques to detect
departures of Contractor output from required or
desired levels of quality control, and to provide an
early warning  of Contractor QA/QC  problems
which may not be apparent from the results of an
individual  case.

    As a further benefit to the Program, the data
base provides the information needed to establish
performance-based criteria in updated  analytical
protocols,  where advisory  criteria has been
previously used.  The vast  empirical  data set
produced by  contract laboratories is carefully
analyzed,  with  the  results  augmenting
theoretical  and research-based  performance
criteria. The result is a continuously monitored set
of  quality  control  and  performance  criteria
specifications of what is routinely achievable and
expected of environmental chemistry laboratories
in mass production analysis of environmental
samples.  This, in turn, assists the Agency in
meeting its objectives of obtaining data of known
and documented quality.

G.  Data Management

    Data management procedures are defined as
procedures  specifying  the acquisition or entry,
update, correction, deletion, storage and security
of computer readable  data  and  files.   These
procedures must be in written form and contain a
clear definition for all databases and files used to
generate or resubmit deliverables.  Key areas of
concern include:  system organization (including
personnel and security), documentation operations,
traceability and quality control.
    Data manually entered from hard-copy must
be reevaluated  through quality  control measures
and the error rates estimated.   Systems should
prevent entry of incorrect or out-of-range data and
alert data entry personnel of errors. In addition,
data entry error rates must be estimated and
recorded on a monthly basis  by reentering  a
statistical  sample  of the  data entered  and
calculating discrepancy rates by data element.

    The record of changes in the form of corrections
and updates to  data  originally  generated,
submitted, and/or resubmitted must be documented
to allow traceablilty of updates.  Documentation
must include the following for each change:

    •   Justification or rationale for the change.
    •   Initials of the person making  the change
       or changes. Data changes must be
       implemented and reviewed by a person or
       group independent of the source generating
       the deliverable.
    •   Change documentation must be retained
       according to the schedule of the original
       deliverable.
    •   Resubmitted diskettes or other
       deliverables must be reinspected as a part
       of the laboratories' internal inspection
       process prior to resubmission.  The entire
       deliverable, not just the changes, must be
       inspected.
    •   The Laboratory Manager must approve
       changes to originally submitted
       deliverables.
    •   Documentation of data changes may be
       requested by laboratory auditors.
    Lifecycle  management  procedures must be
applied to computer software systems developed
by the laboratory to be used to generate and edit
contract deliverables.  Such systems  must be
thoroughly  tested  and  documented  prior to
utilization.

    •   A software test and acceptance plan
       including test requirements, test results
       and acceptance criteria must be
       developed, followed, and available in
       written form.
    •   System changes must not be made directly
       to production systems generating
       deliverables. Changes must be made first
       to a development system and tested prior
       to  implementation.
    •   Each version of the production system will
       be given an identification number, date of
       installation, date of last operation and
       archived.
    •   System and operations documentation
       must be developed and maintained for
                                         43

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CLP User's Guide

       each system. Documentation must include       •   System operation and maintenance
       a users manual and an operations and               including documentation and training.
       maintenance manual.                         .   Database integrity, including data entry,
    Individual(s)  responsible for the following          data updating and quality control.
functions must be identified:                          .   Data and system security, backup and
                                                       archiving.
                                         44

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                               APPENDIX  A
                          LIST OF ACRONYMS
AA       Atomic Absorption
AMIS     Analytical Methods Implementation Sections
AOB      Analytical Operations Branch
APO      Administrative Project Officer
AR       Authorized Requestor
B/N/A    Base, Neutral, Acid Extractable Compounds
CCS      Contract Compliance Screening
CEAT     Contractor Evidence Audit Team
CERCLA  Comprehensive Environmental Response, Compensation and Liability Act
CLP      Contract Laboratory Program
CMD      Contracts Management Division
CO       Contracting Officer
CR       Cost Recovery
CRQL     Contract Required Quantitation Limit
DCD      Data Complete Date
DDD      Data Due Date
DR       Delivery Request
DRD      Data Receipt Date
EMSL     Environmental Monitoring Systems Laboratory
EPA      Environmental Protection Agency
ERT      Environmental Response Team
ESAT     Environmental Services Assistance Teams
FIT       Field Investigation Team
FR       Federal Register
FSCC     Fused Silica Capillary Column
GC/EC    Gas Chromatography/Electron Capture
GC/MS    Gas Chromatography/Mass Spectrometry
HRGC     High Resolution  Gas Chromatography
HRMS     High Resolution Mass Spectrometry
HSED     Hazardous Site Evaluation Division
ICP/MS   Inductively Coupled Plasma/Mass Spectrometry
                                   45

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CLP User's Guide

   IDL       Instrument Detection Limit
   IFB       Invitation for Bid
   LCS       Laboratory Control Sample
   NEIC      National Enforcement Investigations Center
   NIST      National Institute for Standards and Technology
   NPM      National Program Manager
   NPO      National Program Office
   ORD      Office of Research and Development
   OSWER   Office of Solid Waste and Emergency Response
   OWPE     Office of Waste Programs Enforcement
   PE        Performance Evaluation
   PEST      Pesticides
   PL        Packing List
   QA       Quality Assurance
   QAP      Quality Assurance Plan
   QC        Quality Control
   QTM      Quick Turnaround Method
   RAS      Routine Analytical Services
   REM      Remedial Action Team
   ROS      Regional Operations Section
   RSCC      Regional Sample Control Center
   SARA     Superfund Amendments and Reauthorization Act
   SAS       Special Analytical Services
   SDG      Sample Delivery Group
   SICP      Selected Ion Current Profile
   SIM       Selected Ion Monitoring
   SMO      Sample Management Office
   SOP       Standard Operating Procedure
   SOW      Statement of Work
   SV        Semivolatile
   TAT       Technical Assistance Team
   TCL       Target Compound List
   TIC       Tentatively Identified Compound
   TPO       Technical Project Officer
   TR        Traffic Report
   VOA      Volatile Organics Analysis
                                        46

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                                    APPENDIX B

                                 CLP  DIRECTORY
National Program Office

USEPA Analytical Operations Branch (OS-230)

   401 M Street, SW
   RoomM-2624
   Washington, DC 20460
   202/382-7906 FTS 382-7906

   Hans Crump-Weisner, Branch Chief
       202/382-7906 FTS 382-7906
   Joan Fisk, Deputy Branch Chief
       202/382-3115 FTS 382-3115
   Howard Fribush, CLP Project Officer
       202/382-2239 FTS 382-2239
   Karen Bankert, CLP Project Officer
       202/382-7942 FTS 382-7942
   Angelo Carasea, National Organic Program Manager, CLP Project Officer
       202/382-7911 FTS 382-7911
   Michael Hurd, National Inorganic Program Manager, CLP Project Officer
       202/382-7908 FTS 382-7908
   Russell, McCallister, CLP Project Officer
       202/382-7908 FTS 382-7908
   Lynn Beasley, Regional Operations Section, Acting Chief
       202/475-8607 FTS 475-8607
   Patricia Wiltshire,  SMO Project Officer
       202/382-7943 FTS 382-7943
   David Eng, ADP Officer
       202/382-4619 FTS 382-4619
   Jim Baron, QAC

   Chuck Sands, Data Integrity Specialist
USEPA Contracts Management Division (MD-33)

    Alexander Drive
    Research Triangle Park, NC  27111

    Janet Simmons, Contract Officer, Acting Procurement Branch Chief
       919/541-4081 FTS 629-4081
    Marian Bernd, Contract Officer
       202/382-0532 FTS 382-0532
    Vira Burnett, Contract Officer
       919/541-3045 FTS 629-3045
    Larry Presnell, Contract Officer
       919/541-3166 FTS 629-3166
                                        47

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CLP User's Guide


USEPA Environmental Monitoring Systems Laboratory (EMSL/LV)

    944 East Harmon Avenue
    Las Vegas, NV 89108

    Mailing Address:
    P.O. Box 93478
    Las Vegas, NW 89193-3478

    Data To:
    EMSL/LV Executive Center
    944 East Harmon Ave.
    Las Vegas, NV 89119
    Attn: Data Audit Staff

USEPA National Enforcement Investigations Center (NEIC)

    Denver Federal Center 53, E-2
    P.O. Box 25227
    Denver, CO 80225
    303/236-5111  FTS 776-5111

USEPA Environmental Monitoring Systems Laboratory (EMSL/Cincinnati)

    26 W. Martin Luther King Dr.
    Cincinnati, OH 45268
                                        48

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                                                                    Appendix B - CLP Directory
Sample Management Office
   Mailing Address:
   USEPA Contract Laboratory Program
   Sample Management Office
   P.O. Box 818
   Alexandria, VA 22313
   703/557-2490 FTS 557-2490
   Street Address:
   Viar and Company, Inc.
   300. N. Lee Street
   Alexandria, VA 22314
   703/684-5678
Sample Management Office Regional Coordinators and Analysts
                                                Analyst
                                                Terri Shaughnessy
                                                Diane Cutler
                                                Diane Cutler
                                                Terri Shaughnessy
   Region VI
   Region VII
   Region VIII
   Region IX
   Region X
Coordinator
Vikki Denslow
Bret Elderd
Elenor McLean
Tom Sigler
Loren Minnich - SAS
Blake Henke  RAS
Elenor McLean
David Mack
Monica McNeil
Susan Grove
David Mack
Terri Shaughnessy
Terri Shaughnessy
Diane Cutler
Diane Cutler
Diane Cutler
Terri Shaughnessy
                                        49

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CLP User's Guide
USEPA Region I
   *USEPA Region I, WMD
   J.F. Kennedy Federal Bldg
   (HPC-CAN7)
   Boston, MA 02203
   (617) 573-5707  FTS 833-1707
  . USEPA Region I, ESD
   60 Westview Street
   Lexington, MA 02173
   (617) 860-4300
   FTS 828-6300
   *Nancy Barmakian
   Michael Hurd
   Deb Szaro, Moira Lataille
   David  Tordoff
   *Don Smith
   *Nancy Smith
   Leonard Wallace
   "Heidi Ellis
   *Nancy Barmakian
   John Carlson
   *Rick Leighton
   *Kathy Castagna
FTS 883-1797
FTS 382-7908
617/860-4312
617/860-4362
FTS 833-1648
FTS 833-1697
617/860-4694
617/573-5798
FTS 883-1797
617/860-4300
FTS 883-1654
FTS 833-1609
ARCS Project Officer
CLP Administrative  Project  Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         50

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                                                                      Appendix B - CLP Directory
USEPA Region II
   *USEPA Region II
   26 Federal Plaza
   New York, NY 10278
   (212) 264-2525
   FTS 264-2525
   USEPA Region II, BSD
   Woodbridge Avenue
   Building 209
   Edison, NJ 08837
   (201) 321-6754
   FTS 340-6754
   *Shaheer Alvi
   Angela Carasea
   Lisa Gatton
   Michael Polito
   Amy Brochu
   *Ben Conetta
   Richard Salkie
   Philip Guarraia
   Shaheer Alvi
   Michael Polito
   *Cathy Moyik
   *Derval Thomas
FTS 264-2221
FTS 382-7912
FTS 340-6676
FTS 340-6652
FTS 906-6802
FTS 264-6696
FTS 340-6657
FTS 340-6997
FTS 264-2221
FTS 340-6652
FTS 264-8123
FTS 264-1829
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         51

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CLP User's Guide
USEPA Region III
   *USEPA Region III,
   Superfund Branch
   841 Chestnut Street
   Philadelphia, PA 19107
   (215) 597-0992
   FTS 597-0992
   USEPA Region IE, CRL
   839 Bestgate Road
   Annapolis, MD 21401
   (301)266-9180
   *Fran Burns
   *Roy Schrock
   Angela  Carasea
   Stevie Wilding
   *Steve Jarvela
   *Bob VanFossen
   *Tony Dappalone
   *Margaret Jennis
   Dennis Carney
   Colleen Walling
   *Bill Hagel
   *Bob VanFossen
   *Elaine Speiwak
   *Jeff Barnett
FTS 597-4750
FTS 597-0913
FTS 382-7911
FTS 266-9180
FTS 597-7915
FTS 597-3152
FTS 597-3153
FTS 597-3437
FTS 597-0992
301/266-9180
FTS 597-3435
FTS 597-3152
FTS 597-8183
FTS 597-6688
ARCS Project Officer
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         52

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                                                                     Appendix B - CLP Directory
USEPA Region IV
   *USEPA Region IV
   Superfund Branch
   345 Courtland Street., N.E.
   Atlanta, GA 30365
   (404) 347-4727
   FTS 257-4727
   USEPA Region IV, BSD (ASB)
   Analytical Support Branch
   College Station Road
   Athens, GA 30613
   (404) 546-3111
   FTS 250-3111
   *Doug Thompson                 FTS 257-2234
   Howard Fribush                 FTS 382-2239
   Tom Bennett                     FTS 250-3112
   *Fred Stroud                    FTS 257-3931
   *Narindar Kumar               FTS 257-5065
   'Deborah Vaughn-Wright        FTS 257-5065
   *Doug Lair                      FTS 257-3931
   Bill Bokey                      FTS 353-2270
   *Ken Meyer                     FTS 257-2234
   'Carol Monell                   FTS 257-3931
   *Doug Thompson                 FTS 257-2234
   *Rowena  Sheffield              FTS 257-2234
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         53

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CLP User's Guide
USEPA Region V
   USEPA Region V, BSD
   536 S. Clark Street
   Tenth Floor, 5SCRL
   Chicago, IL 60605
   FTS 353-3808
   *USEPA Region V, WMD
   230 S. Dearborn Street
   12th Floor (HR-12)
   Chicago, IL 60604
   (312) 886-7579
   FTS 886-7579
   *Susan Heston
   *Stephen Nathan
   *Carl Norman
   Russell McCallister
   Pat Churilla
   Jackie Van Bosse
   Charles  Brasher
   Gail Nabasny
   *Jeanne Griffin
   *Mary Gade
   Jan Pels
   Gail Nabasny
   Steve Faryan
   *Eva Howard
   *Lorraine Kosik
   *Fred Norling
FTS 886-9553
FTS 886-5496
FTS 886-5495
FTS 382-2239
FTS 353-2313
FTS 353-1908
FTS 353-7625
FTS 353-1056
FTS 886-3007
FTS 353-9773
FTS 353-2720
FTS 353-1056
FTS 353-9351
FTS 886-7274
FTS 353-6431
FTS 886-4510
ARCS Project Officer
ARCS Project Officer
ARCS Project Officer
CLP Administrative  Project  Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         54

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                                                                       Appendix B - CLP Directory
USEPA Region VI
   *USEPA Region VI Laboratory
   10625 Fallstone Rd
   Houston, TX 77099
   (713) 983-2100
   FTS 730-2100
   USEPA Region VI
   First Interstate Tower
   1445 Ross Avenue
   Dallas, TX 75202
   (214) 665-6491
   FTS 255-6491
   Julie Brown                     FTS 255-6720
   Michael Hurd                   FTS 382-7908
   'William (BJ.) Verrett          FTS 730-2139
   Chris Petersen                   FTS 255-2270
   Ed Sierra                       FTS 255-6491
   Jana Harvill                    FTS 255-6740
   Charles Gazda                  FTS 255-2270
   Jim Mullins                     FTS 255-2270
   *Myra Perez                    FTS 526-9425
   Eve Boss                        FTS 255-6720
   Chris Petersen                   FTS 255-2270
   Karen Witten                   FTS 255-6720
   Rena McClurg                   FTS 255-6780
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         55

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CLP User's Guide
USEPA Region VII
   *USEPA Region VH
   726 Minnesota Avenue
   Kansas City, KS 66101
   FTS 276-7050
   (913) 236-2800
   USEPA Region VH, ESD
   25 Funston Road
   Kansas City, KS 66115
   FTS 757-3881
   (913) 236-3881
   FAX (913) 236-2934
   Rebecca Thomas
   Karen Bankert
   Larry Marchin
   Ronald McCutcheon
   Pete Culver
   Ron McCutcheon
   Shelley  Welker
   William  Keffer
   Nicole Roblez
   Karen Flournoy
   Paul Doherty
   Maureen Hunt
   Paula Eager
FTS 757-2856
FTS 382-7942
FTS 757-3881
FTS 757-3888
FTS 757-2856
FTS 757-3888
FTS 757-2856
FTS 757-3888
FTS 757-3881
FTS 757-2856
FTS 757-3888
FTS 757-2856
FTS 757-2852
ARCS Project Officer
CLP Administrative Project  Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         56

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                                                                      Appendix B - CLP Directory
USEPA Region VIII
   USEPA Region VIII
   999 18th Street, Suite 500
   Denver, CO 80202-2405
   FTS 330-1720
   (303) 293-1720
   *Denver Federal Center
   Building 5
   Wl Entrance, 2nd Floor
   Denver, CO 80225
   FTS 776-5064
   (303) 236-5073
   Montana EPA Office
   301 South Park
   P.O. Drawer 10096
   Helena, MT 59626
   FTS 585-5414
   (406) 449-5414
   Graig Hargreaves
   Jeff Mashburn
   Russell McCallister
   Steve Callio
   Mike Zimmerman
   Gerald Snyder
   Paul  Arell
   John Giedt
   Floyd Nichols
   Tammy Kozak
   Greg Hargreaves
   Jim Knoy
   Sam Marquez
   Rolland Lech
FTS 330-1187
FTS 330-7156
FTS 382-7908
FTS 330-7511
FTS564-7081
FTS 330-7504
FTS 330-7598
FTS 330-7142
FTS 330-7167
FTS 330-7507
FTS 330-1187
FTS 330-7162
FTS 330-7151
FTS 564-1516
ARCS Project Officer
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         57

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CLP User's Guide
USEPA Region IX
   USEPA Region IX, OPM, P-3-2
   1235 Mission Street
   San Francisco, CA 94103
   FTS 556-6458
   (415) 556-6458
   FAX (415) 556-6874
   Laboratory
   *USEPA Region DC
   944 East Harmon Avenue
   Las Vegas, NV 89119
   Peter Rubenstein                 FTS 454-0307
   Karen  Bankert                  FTS 382-7942
   Kent Kitchingman                FTS 556-5033
   Chris Weden                    FTS 454-8132
   Douglas Frazer                  FTS 454-7305
   Lisa Nelson                     FTS 454-7701
   Kathleen  Shimmin               FTS 454-7745
   RobbyHedeen                   415/744-1244
   Rob Stern                       FTS 454-7406
   William  Lewis                  FTS 454-7464
   Judy Walker                    FTS 454-0748
   Lucy Mlenar                     FTS 454-8386
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Region Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         58

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                                                                      Appendix B - CLP Directory
USEPA Region X
   USEPA Region X, ESD
   1200 Sixth Avenue
   M/S ES-095
   Seattle, WA 98101
   FTS 399-1200
   (206) 442-1200
   Laboratory
   *USEPA Region X
   P.O. Box 549
   Manchester, WA 98353
   FTS 399-0370
   (206) 442-0370
   Joanne LaBaw
   Howard Fribush
   *Gerald Muth
   Jeff Webb
   William Longston
   John Osborn
   David Bennett
   James Everts
   Carolyn Wilson
   Joanne LaBaw
   Carl Kitz
   Mike Slater
   Shirley Towns
FTS 399-2594
FTS 382-2237
FTS 399-0370
FTS 399-1196
FTS 399-1196
FTS 399-0837
FTS 399-2103
FTS 399-1196
FTS 399-1632
FTS 399-2594
FTS 399-1196
FTS 399-0455
FTS 399-2586
ARCS Project Officer
CLP Administrative Project Officer
CLP Technical Project Officer
ERCS Deputy Project Officer
ERCS Deputy Project Officer
FIT Regional Project Officer
NPL Coordinator
Regional Response Team Coordinator
Regional Sample Control Coordinator
REM Project Officer
TAT Deputy Project Officer
TES Project Officer, CERCLA
TES Project Officer, RCRA
                                         59

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CLP L/ser's Guide


Miscellaneous Information

Cooler Returns

   T. Head and Company
   950 Herndon Parkway
   Suite 230
   Herndon,VA 22070
   703/473-3886

ERT Edison

   USEPA Environmental Response Branch
   GSA Raritan Depot
   Woodbridge Avenue
   Edison, NJ 08837
   FTS 340-6649,6689,6743
                                       60

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                                                                      Appendix B - CLP Directory
Regional Sample Control Centers
Address

USEPA Region I, WMD
J.F. Kennedy Federal Bldg.
Boston, MA 02203

USEPA Region II, ESD
Woodbridge Ave. Bldg. 209
Edison, NJ 08837

USEPA Region III, CRL
839 Bestgate Rd.
Annapolis, MD 21401

USEPA Region IV, ESD
Env. Compliance Branch
College Station Road
Athens, GA 30613

USEPA Region V, ESD
536 S. Clark St.
Tenth Floor, CRL
Chicago, IL 60605

USEPA Region VI
Monterey Park PI. Bldg. C
6608 Hornwood Dr.
Houston, TX 77074

USEPA Region VII, ESD
25FunstonRd.
Kansas City, KS 66115

USEPA Region VIII
999-18th St.
12th Floor
Denver, CO 80202

USEPA Region IX, OPM
215 Fremont St.
San Francisco, CA 94105

USEPA Region X, ESD
1200 Sixth Ave. E/S 095
Seattle, WA 98101
Regional Sample Control
Coordinator

Heidi Ellis
Philip Guarraia
Colleen Walling
Bill Bokey
Jan Pels
Myra Perez
Nicole Roblez
Tammy Kozak
Robbie Hedeen
Carolyn Wilson
Phone Number

617/573-5798
FTS 833-1798
201/321-6997
FTS 340-6997
301/266-9180
404/546-3300
FTS 250-3300
312/353-2720
FTS 353-2720
713/953-3425
FTS 526-9425
913/236-3881
FTS 757-3881
303/294-7507
FTS 330-7507
415/744-1244
206/442-1632
FTS 399-1632
                                         61

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CLP User's Guide
Regional Technical Project Officers
   Region I
   Region n
   Region HI
   Region IV
   Region V
   Region VI
   Region VH
   Region Vni
   Region IX
   Region X
Deb Szaro, Moira Lataille
Lisa Gatton
Stevie Wilding
Tom Bennett
Pat Churilla
William (B.J.)  Verrett
Larry Marchin
Steve Callio
Kent Kitchingman
Gerald Muth
617/860-4312
FTS 340-6676
FTS 266-9180
FTS 250-3112
FTS 353-2313
FTS 730-2139
FTS 757-3881
FTS 330-7511
FTS 556-5033
FTS 399-0370
                                         62

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                                    APPENDIX C

                                   REFERENCES
NOTE:  The references in this appendix are supplied for general information purposes and do not
        necessarily represent methods or procedures utilized in the CLP.

Analytical References

   American Public Health Association, American Water Works Association, Water Pollution Control
Federation. Standard Methods for Examination of Water and Wastewater. 14th ed. rev. 1975.

   American Society for Testing and Materials. Annual Book of ASTM Standards. Part 31, Standard
D3223-73; 1976 (p. 343).
   Bishop, J.N. Mercury in Sediments. Ontario Water Resources Comm. Toronto: 1971.
   Brandenberger, H.; Bader, H. The Determination of Nanogram Levels of Mercury in Solution by a
Hameless Atomic Absorption Technique. Atomic Absorption Newsletter 6:101; 1967.
   Environmental Monitoring and Support Laboratory, U.S. Environmental Protection Agengy. Interim
Methods for the Sampling and Analysis of Priority Pollutants in Sediments and Fish Tissue. Cincinnati:
October 1980 (rev.).
   Environmental Monitoring and Support Laboratory, U.S. Environmental Protection Agency. User's
Guide for the Continuous Flow Analyzer Automation System. Cincinnati: 1981.
   Garbarino, J.R.; Taylor, H.E.  An Inductively-Coupled Plasma Atomic  Emission Spectrometric
Method for Routine Water Quality Testing. Applied Spectroscopy 33:3; 1979.
   Goulden, P.D.; Afghan, B.K. An Automated Method for Determining Mercury in Water. Technicon.
Adv. in Auto. Analy. 2; 1970 (p. 317).
   Hatch, W.R.; Ott, W.L. Determination of Sub-Microgram Quantities  of Mercury by Atomic
Absorption Spectrophotometry. Analytical Chemistry 40:2085; 1968.
   Kopp, J.F.; Longbottom, M.C.; Lobring, L.B. Cold Vapor Method for Determining Mercury. AWWA
64:20; January 1972.
   Martin, T.D.;  Kopp, J.F.; Ediger, R.D. Determining Selenium in Water, Wastewater, Sediment and
Sludge by Flameless Atomic Absorption Spectroscopy. Atomic Absorption Newsletter 14:109; 1975.
   Martin, Theodore D. Inductively Coupled Plasma-Atomic Emission Spectrometric Method of Trace
Elements Analysis of Water  and  Waste. Method 200.7.  Modified by CLP Inorganic Data/Protocol
Review Committee.
   Office of Solid Waste  and  Emergency  Response, U.S.  Environmental Protection Agency.
Modification (By Committee) of Method 3050. SW-846,  2nd ed. Test Methods for Evaluating  Solid
Waste; July 1982.
   Organochlorine Pesticides  and  PCBs, Method 608;  2,3,7,8-TCDD, Method  613; Purgeables
(Volatiles), Method 624; Base/Neutrals, Acids and Pesticides,  Method 625; Federal Register 44(233);
December 3,1979  (pp. 69501,69526,69532,69540).
   Owerbach, Daniel. The Use  of Cyanogen Iodide (CNI)  as  a  Stabilizing Agent  for Silver in
Photographic Processing Effluent Sample. Photographic Technology Division, Eastman Kodak
Company. Rochester, New York.


                                        63

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CLP User's Guide
    Technicon Industrial Systems.  Operation Manual  for Technicon  Auto Analyzer  IIC System.
Technical Pub. No. TA9-0460-00. Tarrytown, New York: 1980.
    U.S. Environmental Protection Agency. Handbook for Analytical Quality Control in Water and
Wastewater Laboratories. USEPA-600/4-79-019.
    U.S. Environmental Protection Agency. Handbook for Monitoring Industrial Wastewater. USEPA
Technology Transfer; 1973.
    U.S. Environmental Protection Agency. Methods for Chemical Analysis of Water and  Wastewater.
USEPA Technology Transfer; 1974.

    U.S. Environmental Protection Agency. Methods from Chemical Analysis of Water and Waste.
USEPA-600/4-79-02; March 1979.
    U.S. Environmental Protection Agency. Procedures Manual for Groundwater Monitoring at Solid
Waste Disposal Facilities. USEPA 530/SW-611; 1977.
    Winefordner, J.D. Trace Analysis: Spectroscopic Methods for Elements. Chemical Analysis 46: 41-
42.
    Winge, R.K.; Peterson,  V.J.;  Fassel, V.A. Inductively  Coupled  Plasma-Atomic  Emmission
Spectroscopy Prominent Lines. USEPA-600/4-79-017.
    Wise, R.H.; Bishop, D.F.; Williams, R.T.; Austern, B.M. Gel Permeation Chromatography in the
GC/MS Analysis of Organics in Sludges. Municipal Environmental Research Laboratory,  U.S.
Environmental Protection Agency. Cincinnati.

Quality Assurance References

    American Chemical Society Committee on Environmental Improvement, and Subcommittee on
Environmental Analytical Chemistry, "Guidelines for Data Acquisition and Data Quality Evaluation
in Environmental Chemistry", Analytical Chemistry, Volume 52, Number 14, December 1980.

    Environmental Monitoring Systems Laboratory, U.S. Environmental Protection Agency, Analytical
Reference Standards and Supplemental Data:  The Pesticides and Industrial Chemicals Repository,
EPA-600/4-84-082, October 1984.

    Environmental Protection Agency, "Guidelines Establishing Test Procedures for the Analysis of
Pollutants Under the dean Water Act; Final Rule and Interim Final Rule and Proposed Rule", 40 CFR
Part 136, Federal Register, Vol. 49, No. 209., pp 43234-43442, October 26, 1984.

    Fisk, J.F. and Manzo, S.M. "Quality Assurance/Quality Control in Organics Analysis", Proceedings
from the Water Pollution Control Federation Meeting, May 1986.

    Health Effects Research Laboratory, U.S. Environmental Protection Agency, Manual of Analytical
Methods for the Analysis of Pesticides in Humans and Environmental Samples, EPA-600/8-80-036, June,
1980.

    Health Effects Research Laboratory, U.S. Environmental Protection Agency, Manual of Analytical
Quality Control for Pesticides and Related Compounds In Human and Environmental Samples-Second
Revision, EPA-600/2-81-059, April 1981.

    Laidlaw, R.H., "Document Control and Chain of Custody Considerations for the National Contract
Laboratory Program," Quality  Control  in Remedial Site Investigations: Hazardous and Industrial
Solid Waste Testing, Fifth Volume, ASTM STP 925, C.L. Perket, ed., American Society for Testing and
Materials, Philadelphia, 1986.

    Moore, J.M. and Pearson, J.G.  "Quality Assurance Support for the Superfund Contract Laboratory
Program", Quality  Control in Remedial Site Investigation:  Hazardous and Industrial  Solid Waste
Testing, Fifth  Volume, ASTM STP 925, C.L. Perket, ed., American Society for Testing and Materials,
Philadelphia,  1986.
                                         64

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                                                              Appendix C - References
    Office of Monitoring Systems and Quality Assurance, U.S. Environmental Protection  Agency,
"Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans", QAMS-005/80,
December 1980.

    Office of Solid Waste and Emergency Response, U.S.  Environmental Protection  Agency, Test
Methods for Evaluating Solid Waste, Third Edition, SW-846, November 1986.

    U.S. Environmental Protection Agency. Guidelines Establishing Test Procedures for the Analysis of
Pollutants Under the Clean Water Act; Final Rule and Interim Final Rule and Proposed Rule. 40 CFR
Part 136. Federal Register 49(209); October 26,1984 (pp. 43234-43442).

Safety References

    Committee on Chemical Safety. Safety in Academic Chemistry Laboratories. American Chemical
Society Publications. 3d ed. rev. 1979.

    Department of Health, Education and Welfare, Public Health Service, Center for Disease  Control,
National Institute for Occupational Safety and Health. Carcinogens-Working with Carcinogens. Pub.
No. 77-206; August 1977.

    Occupational Safety and Health Administration. OSHA Safety and Health Standards,  General
Industry (29 CFR 1910). OSHA 2206. rev. January 1976.

    Wallace, R.A.; Fulkerson, W.; Shults, W.D.; Lyon, W.S. Mercury in the Environment-The Human
Element. Oak Ridge National Laboratory. ORNL/NSF-EP-1; January 1971 (p. 31).

Sampling References

    Environmental Response Team, U.S. Environmental Protection Agency. Field Monitoring and
Analysis of Hazardous Materials. EPA Training Manual. Course No. 165.4. Cincinnati: 1980.

    Huibregtse, K.R.; Moser, J.H.  Handbook for Sampling and Sample Preservation of Water and
Wastewater. USEPA-600/4-76-049; 1976.
    Municipal Environmental Research Laboratory, U.S. Environmental Protection Agency. Samplers
and Sampling Procedures for Hazardous Waste Streams. EPA-600/280-018. Cincinnati: 1980.
    National  Enforcement Investigations Center. Enforcement Considerations for Evaluation  of
Uncontrolled Hazardous Waste Sites by Contractors. EPA Office of Enforcement. Denver: 1980.

    Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency, Sampler's
Guide for the Contract Laboratory Program, First Edition,, December 1990.
    Olson, D.M.; Berg, E.L.; Christensen, R.; Otto, H.; Ciancia, J.;  Bryant, G.; Lair, M.D.; Birch, M.;
Keffer, W.; Dahl, T.; Wehner, T. Compliance Sampling Manual. Office of Water Enforcement, EPA
Enforcement Division, Compliance Branch; 1977.
    Weber, C.I. Biological Field and Laboratory Methods for Measuring the Quality of Surface Waters
and Effluents. USEPA-670/4-73-001; 1973.

Shipping References

    Federal Express Corporation, Hazardous Materials Department. Telephone: 1-800-238-5592.

    U.S. Department of Transportation. A Guide to the Federal Hazardous Materials Transportation
Regulatory Program; 1983.
    U.S. Department of Transportation. U.S. Department of Transportation Regulations.  49 CFR, Parts
100-199; October 1,1978.
                                         65

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                                      INDEX
AMIS3
Analytical data 1-8, 17-23, 27-31, 34-43
Analytical Methodologies
    Development 18
    Improvement 18
Analytical Operations Branch (see AOB)
Analytical Standards Traceability
    Requirements 38
AOB 3
APO 3,4,27,32-36
Case Number 20,23
CCS 5,28-31,39,41
CERCLA1
Chain-of-custody 4,24-26,30
Chemical Standards 38, 39
CLP 6
    Clients 1
    Non-Superfund clients 1,7
    Objective and Orientation 1
    Structure 1,2
    User community 1
    Users 1
CMD 33-35
CO 33-35
Comprehensive Environmental Response,
    Compensation, and Liability Act (see
    CERCLA)
Contract Compliance Screening (see CCS)
Contract Delivery Requirements 7
Contract Laboratory Program (see CLP)
Contracting Officer (see CO)
Contracts Management Division (see CMD)
Cost Recovery 29,31
 EMSL/LV 3,4,18,28,31-42
 Enforcement 30
 Environmental Monitoring Systems
    Laboratory in Las Vegas (see
    EMSL/LV)
 Environmental Services Assistance Team
    (see ESAT)
 EPA
    Regions 1
 Evidentiary Audit
    Analytical Project File Evidence Audit
        42
    Procedural Audit 41
    Written SOP s Audit 42
 GC/MS Tape Audits 41

 H	
 Hazardous Site Evaluation Division (see
    HSED)
 High Concentration RAS
    Inorganic 6,16
    Organic 6, 7,12
 HSED 3

J	
 IFB 33, 34
 Inorganic RAS 8
    High Concentration 6,16
    Low Concentration Drinking Water 6,
       14
    Multi-Media, Multi-Concentration 6, 7,
       13
 Invitation for Bid (see IFB)
Data package 1, 7,18, 27-34, 39-41
Data reporting 18,23,29,30, 38,39
Data review 3,31, 32,39,41
Data Review Request 32
Data usability 31, 32, 37, 39,42
Dioxin/Furan RAS 6,8,16
 Laboratory 1-8, 17-43
 Laboratory capacity 19, 20-23, 33
 Laboratory Evaluation Samples 40
 laboratory selection 33
 Laboratory Selection Process 33
 Laboratory Startup 34
 Liquidated damages 7
 Low Concentration Drinking Water RAS
    Inorganics 6,14
    Organics 6,10
    Volatile Organics Only 6, 11
                                         67

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CLP User's Guide
N
R
National Enforcement Investigations
    Center (see NEIC)
National Program Office (see NPO)
NEIC 4,18,24, 26, 30, 34-37,42
NPM3
NPO 3-5,18, 20, 23, 27, 28, 33-36
Office of Acid Deposition 1
Office of Solid Waste 1
Office of Solid Waste and Emergency
    Response (see OSWER)
Office of Waste Programs Enforcement 31
Office of Water 1
Organic RAS 8
    High Concentration 6, 7,12
    Low Concentration Drinking Water 6,
        10
    Low Concentration Drinking Water for
       Volatiles Only 6, 11
    Multi-Media, Multi-Concentration 6, 7,
       9
OSWER 3
 PE Samples 33, 34,35
 Performance Evaluation Samples (see PE
    Samples)
 Problem Resolution
    Analytical data 27
    APO/TPO/SMO/Laboratory
        Communication 34
    Cure Notice 35
    First data package 34
    Performance 35
    Sample Analysis 26
    Sample Shipping 26
    Show Cause Notice 35
 Program Information 29
 Program Utilization
    RAS 19
    SAS21

_Q	
 QA 3,4, 8,17, 31-43
 QA Coordinator 3
 QAP37
 QC 3, 7, 8,17,18, 31, 35^3
 Quality Assurance Plan (see QAP)
 Quality Control (see QC)
RAS 6-8,17- 24, 26, 31
    Case Number 20,23
    Dioxin/Furans 6,8
    Initiating a RAS Request 19
    Inorganic 6,8,13,14,16
    Laboratory selection 20
    Lead-time required 19
    Organic 6, 8-12, 20
    Scheduling 19, 20
    Traffic Report 23, 26
    User knowledge of protocol 20
RCRA1
Regional Organic/Inorganic Allocation
    System 23
Regional Sample Control Center (see
    RSCC)
Reports
    Laboratory Sample Backlog Status
       Report 28
    Regional Sample Backlog Status
       Report 28, 29
Resource Conservation and Recovery Act
    (see RCRA)
Routine Analytical Services (see  RAS)
RSCC 1, 5,19-29, 32
Sample Delivery Group (see SDG)
Sample Management Office (see SMO)
Sample Number 24
Sample Packaging 25
   Coolers 5,25-28
Sample Shipping 26
   Coordination 26
   Problem Resolution 26
   Return of coolers 26
Sample Tag 24
SARA1
SAS 4,6- 8,17,18, 21-27, 31, 32
   All SAS 7
   Changing a SAS request 22
   Client Request Form 21
   Delivery requirements 18
   Eligible laboratories 8
   Fast turnaround 17
   Initiating a SAS Request 21
   Laboratory availability 8, 17
   Laboratory selection 8, 22
   Lead-time requirements 21
   Packing List 23, 26
   RAS plus SAS 7
   SAS Number 22,23
                                         68

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Index
    Scheduling 22
    User provided analytical protocol 22
SAS Number 22,23
SAS Packing List 23, 26
Scheduling
    RAS19,20
    Regional Organic/ Inorganic Allocation
       System 23
    SAS 8,17, 22
SDG7,28,30,40
Shipment Management Program 5,28
Site evaluation 34, 35, 41,42
SMO 1,4,8,18- 41
SMO Coordinator 19
SOPs 34,36,37,38,41,42
SOW 20, 21
Special Analytical Services (see SAS)
Standard Operating Procedures (see SOPs)
Statement of Work (see SOW)
States 1
Superfund Amendments and
    Reauthorization Act (see SARA)
Technical Project Officer (see TPO)
TPO 4,20,27-29,34-36
Traffic Report 23, 26
                                         69
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